ML20072H965
| ML20072H965 | |
| Person / Time | |
|---|---|
| Site: | Three Mile Island  |
| Issue date: | 04/14/1981 |
| From: | Walters J BABCOCK & WILCOX CO. |
| To: | |
| References | |
| TASK-*, TASK-02, TASK-03, TASK-07, TASK-2, TASK-3, TASK-7, TASK-GB NUDOCS 8306290840 | |
| Download: ML20072H965 (125) | |
Text
. . _ . .
! 164 %<
UNITED STATES DISTRICT COURT i
SOUTHERN DISTRICT OF NEW YORK
-( ;
GENERAL PUBLIC UTILITIES CORPORATION, :
JE RS EY CENTRAL POWER & LIGHT COMPANY, METROPOLITAN EDISON COMPANY and :
PENNSYLVANIA ELECTRIC COMPANY, Plaintiffs, CIVIL ACTION
- NO. 80 CIV.
-against- 1683 (R.O.)
i :
THE BABCOCK & WILCOX COMPANY and J. RAY McDERM'OTT & CO., INC., :
. Defendants. :
__ _ _ _ _ _ ______ ---,_-x i .
Continued deposition of THE B ABCOCK &
WILCOX CCMPANY, by JAMES FRANKLIN WALTE RS ,
.O '
taken by Plaintiffs, pursuant to notice as adjourned, at the offices o f K ay e , Scholer, Fierman, Hays & Handler, Esqs.,,425 Park Avenue, New York, New York, on Tuesday, April 14, 1981, at-9:41 o' clock'_in the forenoon, be fore Charles Shapiro, Certified Shorthand Reporter and Notary Public within
- and for the State o f New Yo rk .
Af'.
DOYLE REPORTING. INC.
CERTIFIED STENOMPE REPORTERS 369 Lzx N c.?:: N AVENUE New Yonx. N.Y. !Cct7
I -
.i 1 165 2 Appe aran ce s :
}
3 KAYE, SCHOLER, FIERMAN, H AYS & HANDLER, ESQS.
4 Attorneys for Plaintiffs l
425 Park Avenue
~
( 5 New York, New York 6 By: RICHARD C. SELTZER, ESQ. l
-and- !
7 ANDREW MacDONALD, ESQ.,
, of Counsel 8
9 DAVIS POLK & WARDWELL, ESQS.
10 Attorneys for Defendants 1
One Chase Manhattan Plaza 11 New York, New York 12 By: DANIEL F. KOLB, ESQ.
-and-
', 13 LINDA E. CHATMAN, ESQ.,
of Counsel 14 15 16 * * *
~
17 ,
18 J AME S F RAN KL I N WAL T E RS, 19 having been previously duly sworn, was 20 examined and testified further as follows:
21 EXAMINATION (CONTINUED) 22 - BY MR. MacDONALD:
23 Q You are aware, Mr. Walters, that your testimony today continues under oath?
[%..)) 24 25 A' Yes, I do.
~ _ , . . , ._.,_y . . - . _ . . ...c . , _ . , , , , , , , - . , , . . . . . . . , , , , ._ , , , , . . , , . _ , . , - .y a
2 1 Walters 166
- 2 MR. MacDONALD
- I would like to mark 3 as GPU Exhibit No. 129 a memo from Don 4 Kallman to E. R. Kane, July 27, 1979, a
(' 5 "ce" to J. F. Walters.
6 (Memorandum from D. F. Hallman to 7 E. R. Kane, subject: LE R Review, copy 8 to J. F. Walters, among-others, was marked .
9' GPU Exhibit 129 for identification, as of i
10 this date.) t 11 (Document handed to the witness.)
12 BY MR. MacDONALD:
13 Q Mr. Walters, is this a copy of the 14 document you received on or about July 27, 1979 15 in the regular course of business?
16 A I assume I received this document.
. 17 Q I will draw your attention to the 18 first paragraph where it says, "I havb reviewed 19 F. R. Fahland's proposed system for handling 20 LE R' s . Overall, it sounds workable and useful."
21 Had you seen a copy of F. R. Fahland's 22 proposed system for handling LER's?
23 A No, I have not.
- () 24 Q _The next paragraph says , "As we-25 discussed, we also intend to form and maintain i
I i
1 Walters 167 2 Emergency Operating Guidelines (EOG's) to instruct l'
3 our plants on how our NSS should be handled during 4 off-normal conditions."
a
( 5 What are Emergency Operating 6 Guidelines, as referred to in that paragraph?
7 A As best as I know it, we are talking about 8 either the past Emergency Operating Procedures .
9 or any new procedures that would be written that 10 would have the title of Operating Guidelines 11 or Emergency Operating Guidelines.
12 , Q Have you seen such copies of
( a
\ - 13 Emergency Operating Guidelines?
14 MR. KOLB: Are you asking him 15 whether he has seen the specific ones 16 referred to in.the memo?
17 MR. MacDONALD: Copies of_the 18 Emergency Operating Guidelines.
19 MR. KOLB: Are you talking'about i
20 Emergency Operating Guidelines as 21 specifically described here, or just 22 emergency operating guidelines in general?
23 MR. MacDONALD: In the general sense.
-l' (_-)
24 MR. KOLB: In the general sense, t
25 A I think, yes, generally I have seen at i
..- , ._ . _ . _ . . , . . , , y-. _ - _ _ , ~ , . . . - , _ , , . , _ - . . - , - , _ - - , . . . _
1 Walters 168 O~ 2 least one I would consider an emergency operating 3 guideline.
4 Q What were the contents of that 5 guideline?
. ({
6 A It was a procedure titled as a small Break 7 Operating Guideline.
8 Q That is Small Break Ope rating ,
9 Guidelines produced after the TMI-2 accident?
10 A Yes, it was . e 11 Q Do you know what F. R. Fahland's 12 proposed system for handling LE R's was ?
r
(
13 A I do not recall that in any detail at all.
14 Q Do you recall it at all generally?
15 A No. I am not sure that I ever saw this 16 proposed system.
17 Q Ead you ever discussed it.with anyone?
18 MR. KOLB: Will you read the 19 question back, please? i 20 (Question read.)
21 A I don' t believe I have ever discussed it 22 with-anyone.
I l
23 A Had you ever heard it discussed at any '
[~) 24 point in time?
v 25 A Yes.
l l
1 Walters 169
^(
-(_ :
2 Q When was that?
3 A I think only in a general nature and I 4 believe in some casual conversation with Mr.
( 5 Hallman stating to me that he had been to certain 6 meetings where this had been discussed, and we 7 would probably receive some procedures as far as 8 handling this in the future. .
9 Did he describe what the system was
.Q 10 to entail? ',
11 A No. The only thing I recall was that there 12 would be additional or possible additional review 13 of LER's by the Plant Performance Service Section.
14 Q What review of LER's was there prior 15 to the TMI-2 accident by PPS?
16 A I don't recall ever having reviewed an 17 LER prior to that time.
18 Q Aside' f rom you pe rsonally, was there 19 anyone within PPS who reviewed LER's ' prior to 20 the time of the TMI-2 accident?
21 A I am not familiar with anyone in my 22 organization that did review them.
23 Q Do you know if anyone in B&W who was m
n,
( ) 24 charged'with the review of-LER's prior to the
~./
25 TMI-2 accident?
1 Walters 170 i 1 2
A I don't recall any specific person, no.
i 3 Q Was there any specific group or 4 section or unit that reviewed such LER's at B&W
( 5 prior to the TMI-2 accident?
6 A I don't believe I was aw ar e at that time of 7 any group that did.
8 Q What distinguishes the Emergency 9 operating Guidelines, one, of which you described 10 as small Break Operating Guidelines, from other 11 B &W instructions to sites or draft procedures 12 that existed prior to the TMI-2 accident?
. 13 A Are we talking about the title of the 14 document? Why the difference in title?
15 No.
Q The title and subject matter, 16 substance.
17 A Generally I think they were the.same 18 content as previous documents had had.
19 Q Are you saying the Small Break 20 Operating Guidelines contained substantially the 21 same material as did draft procedures be fore the 22 TMI-2 accident?
23 A substantially the same, yes.
i 24 Q Were there any revisions that were 25 made in the Emergency Operating Guidelines after
1 Walters 171 1 -
_V.
2 the TMI-2 accident from those draft procedures 3 prior to the TMI-2 accident?
4 A I am not aware of any changes that were k 5 made to emergency procedures that were in 6 existence before TMI-2.
7 Q What emergency procedures were there 8 in existence prior to TMI-27 .
9 A I don' t know if I can recall then all.
10 There were a LOCA procedure, loss o f RCS pressure, 11 main steam line break procedure, procedures such l 12 as ejected rods or dropped red, unin tentional
'- 13 boron dilution of the system, others. I don't 14 recall the name of them right now.
15 Q Prior to the TMI-2 accident had you 16 ' ever seen any LER's for any B&W plants?
17 A I don't recall having seen a document that 18 I identified as an LER.
19 Q When you say you identified as an LER, 20 do you recall seeing some other document that may 21 have recounted the same information as an- LER 22 but whicht you didn't identify as such?
23 A I simply don' t believe I was aware of an
[)\
m.
24 LER document as such.
25 Q . subsequent to the time of the TMI-2
1 Walters 172 V(~h -2 accident you have reviewed LER's for B&W plants; l 3 correct?
4 A I think so.
l 5 Q Do you do that on a regular basis?
6 Does that come into PPS?
7 A I don't recall whether it --
I saw them on 8 a regular basis or not.
9 Q Have you see,n LER's after the TMI-2 10 accid ent that deal with non-B&W plants?
11 A I may have, yes.
12 Q Do you recall any such?
n\7 13 A I certainly don't.
14 MR. MacDONALD: I would like to have 15 marked as GPU Exhibit 130 for identification 16 a memo from J. F. Walters to PPS P e'rs onne l 17 dated October 10th, 1979. .
18 (Memorandum dated October 10, 1979 19 from J. F. Walters to Plant Performance 20 Services Pe rsonnel, _ subject: Quick Look 21- Reports, was marked GPU Exhibit 130 for i E
22 identification, as of this date.)
23 (Document handed to the witness.)'
E['
24 _ Q Mr. Walters, this is a copy of a 25 _ document you authored on or about October 10,
5 1 Walters J73 t
- \_-
2 1979 in the regular course of business?
3 A Yes, it is.
4 Q The first paragraph states , "Since we
( 5 are now receiving site problem reports for 6 analysis and resolution from all reactor trips 7 on operating plants, this memo is to define our O specific tasks within PPSS."
9 Was this the first time that the Plant 10 Pe rfo rmance services Sectior. personnel were 11 receiving site problem reports (or analysis and 12 resolution from all reactor trips on operating N- 13 plants?
14 MR. KOLB: When you say, is this 15 the first time, what particular date are 16 you referring to?
17 MR. MacDONALD: I am talking around 18 the date of the memo.
19 A on a regular schedule basis, yes.
20 Q You had prior to this point in time.
f ,
21 been receiving SPR's on a nonregularly scheduled Qi 22 basis?
23 A Yes, by that, meaning from time to time
- f')
x._ /
24 we'would receive SPR's on trips or other 25 problems.
, , .- .,. - - . . . ~ . - . -
1 Walters 174 ff').
b 2- Q- The second paragraph says, "PPSS and 4
i 3 Power Systems and Controls in Engineering have 4 initial responsibility for analysis of resolution
_( 5 of these SPR's."
i' 6 was this procedure of PPSS, Plant
- 7 Performance Services Section having initial
, 8 responsibility for analysis of resolution of i
9 SPR's a procedure that was put into place after ,
- - 10 t the TMI-2 accident? '--
b 11 A Tes, I believe it was.
l 12 Q Also in that second paragraph it i
13 talks about " Quick Look Report" prepared by Power 14 Systems and Control and Plant Performance
-15 services Section.
16
- Will you describe what a " Quick Look 17 Report" is? -
18 A It would be a quick ~ analysis, a quick look of 19 the data contained in the SPR that would be
~
20 received and an evaluation of that data as to j 21 whether or not the ensuing transient had
.Q _
22 responded as we thought plants should have 23 under that particular transient or were they l( 24 deviations from what we .would have expected.
25 Q Prior to the TMI-2 accident'the
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I walters 175 T-}
~ ~
2 Plant Performance Services Section of Nuclear 3 Services had responsibility for categorizing and 4 analyzing-SPR's; is that correct?
(. 5 A Yes. ,
6 Q Do you know why that responsibility 7 was shif ted af ter the TMI-2 accident to the 8 Plant Performance Services Section and Power 9 Systems and Controls?
10 A I do not recall the specific, reasons why a 11 different policy was brought about.
l 12 Q Do you recall any reasons in general?
13 A No, I don't recall any.
l 14 Q Have you had any discussions with 15 anybody in B&W regarding the change?
16 A I don't recall any.
17 Q In the third paragraph, the second 18 sentence reads, "Also, the new SPR pr'ocedure 19 prioritizes the SPR's..." ^
20 In what priority order are SPR's now 21 arranged?
22 A As best I remember, they were giving a 23 , priority'of one to four with each of those
[J R
) 24 numbers representing what the specific service 25 manager assigns a priority to that SPR.
s 1 Walters 176 i
2 Q Have you assigned personally 3 priorities to SPR's?
4 A No, I have not.
g 5 Rave you had other individuals within 6 your section assign priorities to SPR's?
7 A No, I don ' t beli' eve so .
8 Q Have you seen SPR's that have been 9 prioritized?
10 A Yes.
(
11 g Will you describe for me what the 12 I
numbers assigned 1 through 4 mean in the priority 13 range for SPR's?
14 A As best I remember, it was a -- I believe t
15 it was on a time basis of a single day, a week, e I
16 but I seem also to recall whether or not it was 17 an SPR that they had evaluated to prevent the i
18 plant restarting or if the plant was down for 19 some other specific reason that-we should -- it
, 20 was also prioritized as this had to be cleared 21 up be fore the plant went back to power. Something 22 along those natures.
23 Q Would the 1 be the highest priority
[>
~-
24 and 4 be the lowest in this numerical sequence? .
\
25 A As best as I recall.
. - _ . .. . - _ . _.. - = , _ . . . - _ _ ,
l V
l g Walters 377 D
(J 2 Q The SPR's that were prioritized with l 3 a number 1 had to deal with safety concerns of 4 issues that needed action quickly or immediately?
l (l 5 A I don' t believe that the classification 6 of safety was the one that required it to be of 7 a timely turnaround. I don't remember the 8 details of it.
l 9 Q Wno would you ask to find out the 10 details of what the priorities o f t,he SPR's mean?
11 A Well, I am saying at this time I don't 12 recall what those psrticular numbers meant. I am
\/ 13 sure I did in October of '79. .
14 Q Who would you ask today if you 15 wanted to determine what those priorities mean?
16 A Any of the service managers or assistant 17 service managers in the Operating Plant 18 Performance Group, Section.
19 Q Who would they be today?
20 A By name?
21 Q The ones you can recall.
22 A Rudy Straub, Mr. Williamson, Mr. Pittman, 23 Mr. Cuvelier, Mr. Finnin, Mr. Veenstra. .I
[/ 1 24 beleive tnere are one or two more. I am drawing 25 a blank on their names at the moment.
1 Walters 178
~ f%
O 2 on Page 2 of your memo, the first Q
3 paragraph states, " Reactor Systems, at the
- 4 moment, has the' lead in PPSS in trying to
( 5 analyze transients from reactor trips and 6 de te rmine 'How the plant is responding,' as.
7 designed or not, 'How the ICS is functioning,'
8 and if the operators took the correct action
} 9 during the transient."
,~ 10
\
Reactor systems was your group, Mr.
11 Walters?
l
- 12 A Yes, it was.
[h N/ 13 ,
Q When it says, " Reactor Systems, at the r >
i' 14 moment has the lead in PPSS in trying to analyze 15 transients from reactor trips..." does that'mean 4
16 ~
at the time or around the time that this memo j 17 was written in october of 19797 .
l -
18 A That is correct.-
l- 19 For how long had you had that t Q
, 20 responsibility? .
L 21 A I don't recall.
22 Q Was it-a number of months, a number of
, 23 years?
(s._.). 24 A No. I think it was mainly a -matter of 25 weeks preceding this memo.
T p- M e v,M-u- --ee p- T y -T-* --r% - -- ->- y- p *g -a
- g. --
% $ re- - 'Tr*we' 4 Th
I 1 Walters J79 O
V 2 Q In that section I just read it has 3 "... determine 'How the plant is responding,'
4 as designed or not, 'How the ICS is functioning,'
. 5 and if the operators took the co rre ct action 6 during the transient."
7 Are these some of the procedures 8
and analyses that you would use in analyzing the 9 SPR's In-plant Performance Services Section when 10 l that came tc your attsntion? ( ,
11 A I don't believe I understood the question.
12 Q How would you analyze the SPR's if O'- 13 they came to your attention? What.would you do 14 to determine whether or not the SPR should be 15 arranged in priority 1 to 47 16 A 9 ~I did not prioritize them. They came to 17 me that way. -
18 Q How would you determine, and what 19 would you look at within the SPR to determine 20 how the plant was responding as that language 21 is used in the first paragraph on Page 2?
22 A we would look at the information contained 23 in the SPR. It would consist of plotted data, coiumnar data, va rio us input from the particular
) 24 v
25 transient from that site, 'from a sequence of
. - . . - . ~ . - - --- -. . . - - - - - .
J
- I 1 Walters 180 2 events off the plant comp ute r , any -- generally 3 any information that was obtained attached to 4 - the SPR came to us, we would as best we could i
( ). 5 look at that particular information and see if 6 it was responding as we thought the plant should i-7 during that type of transient.
t
-8 Q During the course of your review
?
3 of SPR's prior to the time of the TMI o t~
' 10 accident, did you also review thoue SPR's in i 11 the same manner?
12 s MR. KOLB: Would' you . read the CI) 13 ques tior. b ack , please?
4 14 i (Question read.)
l 15 ER. MacDONALC: I will withdraw that.
16 I will ask this' question instead.
17 Q On the first page of'GPU Exhibit 130, 18 the last paragraph, the firs t sentence states:
19 "At this time there is no clearly defined path 20 -for our analysis of each event and charge.
- 21 numbers for such work."
22 -It continues on: "It is hoped that 23 this'will change..."
1 i() 24 ;What advantages did'you hope would.
- 25 result from this change thatL you talk' about in ,
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1 walters 1st f
(
2 the second sentence of GPU Exhibit 130, the last 3 paragraph, the firs t page?
4 A That in the near future that we would get
( 5 a normal work function and therefore charge 6 numbers, administrative charge numbers in places, 7 so that we -- that I knew that we had a 8
continuing and regular piece of work load that 9 would be coning in.
10 Q Why in that better than the method 11 that was employed previously?
12 A Previously I had no generally scheduled I
\/ 13 work load that would require -- that was being 14 performed on SPR's. Therefore, from time to 15 time we would receive SPR's and to work on 16 them required certain administrative details 17 be solved by myself or charge numbers obtained 18 for -- from the service managers to work on
~
19 these pieces of information; and as a matter 20 of doing business it is much more formal and 21 much easier, administrative 1y speaking, to 22 have a standard charge number; when the project 23 comes in, you immediately go to work on it, 24 you know you have got a good charge number and
.[J)
~
25 freely flow through the project.
.......A
1 Walters 182
/T U 2 Q Was one of the reasons why this was 3 done after the TMI-2 accident because SPR's 4 needed-to be analyzed as they came in and not
_( 5 pushed aside for any length of time before they 6 were evaluated?
7 MR. KOLB: Objection as to form.
8- Where does " pushed aside" come from? ,
a 9 MR. MacDONALD: Let ne go back and I
10 l rephrase that. '
i 11 Q Was the reaon that there was the 12 change in procedure that you just discussed t
i N~ -
13 after TMI instituted because you needed a timely 14 evaluation of SPR's as discussed in this aemo 15 on Quick Look Reports that was present --
that 16 was not present prior to the TMI-2 accident?
17 MR. KOLB: Objection as to form.
2 !
18 The question assumes some thing and it is 19 also very confusing.
20 Q You can answer.
21 MR. KOLB: Do you understand the 22 .-
question, or do you find it confusing?
23 A It is confusing.
[)/
x-24 MR. KOLB: Why don't you restate it.
25 (continued on fo'11owing page.)
4 1
ep "'+i + v ----,me sey rv e- u = -- r--we-y,u,e- ---
.e p- ,- - - -* -,6-- - -
y-,r- -- - - -
- J' 1 Walters 183 i
2 Maybe break it down into parts.
. 3 Q These changes that you have just 4 discussed and that were put into place
(' 5 administratively by you to review SP R's after 6 the TMI-2 accident were done to provide quicker 7 evaluation of the substance of the material in 8 those SPR's; is that correct? ,
9 A I don' t recall or have any firsthand 10 l knowledge of why the procedures or>the policy 11 was changed: that was related to me by Mr.
12 Hallman, that v.his would be our ensuing policy f)
As/ 13 on thes? SPR's when they arrived.
14 Q You just implemented that policy?
15 A That's correct.
16 Q Did you have any discussions with 9
17 Mr. Hallman regarding that policy? ,
18 A I am sure I did in certain contexts, but 19 I certainly don' t recall any discussion today.
20 Q Did the new system make work on the 21 SPR's flow more quickly and efficiently after L 22 the TMI-2 accident?
23 A Administrative 1y it certainly did.
[')
x_/
24 Q Was the " Quick Look" program 25 intended to provide the resolution to the
,., , - , , - - - - . . , . , . .- , . - - , . , - - , , . - . - - , . - ~ . . _ , . .
1 Walters 184
'/
L/. 2 SPR's?
3 MR. KOLB: Objection as to form.
4 I am not sure what you mean by resolution
( 5 of the SPR's, j 6 Q Tas it intended to resolve the t .
7 issues that may have been raised by the SPR's 8 which is in the second paragraph? ,
- 9 NR. KOLB
- .Would you be specific
{
10 as to which part of the second paragraph?
- '
- 13 MR. KOLn: Actually I am not a-14 certain whether it matters, but the 15 phrase here is, I think, somewhat different 16 from what you just said. It says, "have 17 initial responsibility for analysis of 18 resolution of these SPR's."-
19 MR. MacDONALD:. The question is 20 whether or not'the Quick Look Report is i
.21 intended to provide some resolution of these 22 SPR's.
23 A 'As.best I remember, we'had the initial 24 _ responsibility to evaluate the information on the (JY s.
! 25 ' transient data that we had received.
1 Walters 185
)
2 At that point in time and based on 3 whatever priority had been assigned to it, we 4 would then _ evaluate ourself or probably in most
.( 5 cases go and talk with the Power System & Control 6 Section and Engineering and pass along our 7 opinion as to our evaluation of that particular 8 site problem report, and at that time agree that ,
9 farther work was needed or that tne resolution 10 was that w2 wav no problem with thct particular 11 information.
12 On fage. 2, the end cf the first Q
(
% IJ paragraph, the sentecce reads, "The bottem line 14 is that we are trying co establish how a B&W NSS 15 responds during all transients."
16 was this a new outlook on the 17 evaluation of SPR's that was initiated after the
~
18 TMI-2 accident?
19 MR. KOLB: I am going to ask you to 20 define "new outlook." What do you mean 21 by that?
22 MR. MacDONALD: Was this a new 23 procedure, a new way of evaluating SPR's l vf~') 24 after the TMI-2 accident?
25 A I think the procedure formalized an
\
1 Walters 186
(~'\
~
2 analysis of the data that came in. This allowed 3 a much better approach to the specific 4 information or the SPR data that was coming in 5 for essentially a dif ferent purpose than we had
({
6 in the past. <
7 Q You used the phrase "much better 8 approach."
D What did you mean by "much better i-
, IC approach'?
11
, MR. KOLS: Just so we are clear, 12 would you specifically indicate which 13 l phrase you are referring to, so that the
- 14 record is clear?
l 15 MR. MacDONALD: I just did. I 16 thought I said you used the phrase, "much 17 better approach." .
18 MR. KOLB: I know --
19 MR. MacDONALD: It'was in his 20 answer.
21 MR.,KOLB: You are not talking about i 22 the memo?
23 MR. MacDONALD: No, I am talking t
24
. A) i about his last, answer.
25 MR. KOLB: Oh, all right.
1 Walters 187 O
\ /
2 A It offered a more thorough approach in 4
3 th at the information obtained from the side, 4 the complete procedure for handling it offered 5 a more thorough
{ evaluation of that 6 information in all transients where in the past 7 we m'ay have done this only on transients that 8 ~
were made aware to us by the specific utility. ,
9 Q You stated in your answer that the 10 I
phrase that you used was for differen: purposes 11 than it had been used in the past.
12 will you explain what you mean by f(,N) 13 "different purposes"?
14 A Well, in the past we usually knew about-10 transients that were more than normal, let us 16 say, transients. Now we had-a process by 17 which we were looking at each transient that 18 occurred on a plant, and this allowed a 19 categorization or process of identifying a much
~
20 wider range of transients whether it be only 21 slightly abnormal, whether it be an entirely 4
22 normal transient that had occurred at a plant, 23 so we were now developing -- or we had developed
('} 24 in this case the capability of
%,J looking at all 25 transients and giving an evaluation of each of
1 Walters 188
%J 2 these transients.
3 Q What was there about the transient 4 response of the NSS that was not known by B &W
( 5 at the time that this new procedure was put into 6 place?
l 7 MR. KOLE: Objection as to form.
8 You are assuming that something was not 9 known. I don't believe that's been stated.
10 MR. MacDONALD: Let's go to the 11 last sentence of the first paragraph on 19 tlie second page.
N 13 Q I am trying to establish how a B&W I
14 NSS responds during all transients. "j l
15 A That simply means that B&W analysis covers 16 a wide range of transients. However, the B &W 17 NSS is dependent on a secondary plant and 18 how it functions, and we -- that varies from 19 time to time on a specific utility-as'well as 20- from one plant to the other.
21 What was your understanding as to Q
22 why B&W embarked on this expanded analysis of 23 plan t transients after the TMI-2 accident?
24 A I remember only that Mr. Hallman had
)
25 related to me that a new policy had been
l 1 Walters 189 O' 2 communicated to him for evaluation of or 3 looking at transients on the B&W NSS. '
4 Q Did you have any discussions with
{ 5 Mr. Hallman as to why this new procedure was 6 being implemented?
7 MR. KOLB: We already had that 8 question, and he gave you an answer.
9 , MR. MacDONALD: I will just ask~iE 10 again if indeed it has been asked.
11 MR. KOLB: I am not sure what you 12 said. You said you are asking it again?'
, 13 MR. MacDONALD: Yes, if indeed it has 14 been asked.
15 MR. KOLB: I think as a general
~
16 proposition that we ought not to ask the 17 questions over and over; and that one was 18 asked just a few minutes ago. '
19 The witness can try to ans'wer again, 20 but I wish you would try to avoid 21 duplication as much as possible.
22 Do you understand the question?
23' THE WITNESS: I would like to have it ,
4
[') 24 read back.
\m/
25 _
(Question r.e a d . )
y e- o- .o == .,- ,- m e- w- , m ,-r--<---,~mn g - , . + , - - m ,,p -
3 - a~t e--9 -
'I t .s 1 Walters 190 f~%
2 A I don't recall any_ conversation with Don c,
3 about why it wa's being implemented oth er than 4
whaE I previously said, that he said it had been 5
{; passed along to him to institute such a program.
6 Q You mean you wrote this memo without 7 any understanding as to why'the Plant ,
8 PerfSrmance Services Section was going to analyze .
9 all transien ts ? .
10 A I don't believe I camE to that conclusion, 11 no.
12 em Q Then you did have some understanding
_) 13 as to why there was to be analysis of all 14 transients. ' T ,
15 A I have my own opinion why we would do it.
16 Q' . What is that opinion?
17 A It l's my. opinion that this is certainly a ,
18 positive approach that all-transients,'given 19 infiniate funding and manpower,should be looked i
20 at.
21 Q That was not the case prior to the 22 TMI-2 accident at B&W7 23 MR. KOLB: At B&W as a whole, or
() 24 are you just talking about at the section?
1 N.)
1 Walters 191 i
[h 2 A I am not aware that there weren't people 3
that -- within B&W that didn't --
I am not aware 4
that there are sections that didn't look at
() 5 each of the SPR's that came in before my Plant 6
Performance Service Section did.
7 Q In your previous answer you used the 8
phrase " positive approach."
9 Why is it a positive approach to 10 analyze all transients? (
11 A Well, as an engineer it is certainly 12 beneficial to be able to broaden your data base
[~')
(/ 13 at any time for experience purposes .
14 Q It would broaden the knowledge 15 within B &W, the capabilities of its NSS during 16 transients?
17 A Yes, it certainly would occur. .
18 Q What changes might need to be made 19 in operating procedures or design bas [s in order 20 to effectuate a better NSS system?
21 MR. KOLE: Could I hear the question 22 .again, please?
23 (Question read. )
(~h 24 -)U1. KOLB:
U I don't understand that
.25- question. I will object to it as to form.
y, ,w v w .-e,n-- ---.y - -r - - - - - < e --
1 Walters 192 f
I
\
2 A If the information was evaluated as 3 something that could lead to a better NSS or a 4 higher, higher availability for an NSS, yes, it
{ 5 would res ult in changes.
6 Q Prior to the TMI-2 accident did that 7 result from any analyses of SP R's , that is, 8 changes in procedures for operator action or 9 design of the NSS system?
10 MR. KOLB: I will object to that, 1 11 and I will ask you to rephrase it. I mean, 12 it is just too confusing.
(~)%
k- 13 MR. MacDONALD: Well, I don't think 14 there is anything confusing about it, but 15 if the witness has trouble, he can ask me 16 to rephrase the question.
17 MR. KOLB: I have trouble, and I 18 think you ought to restate the question.-
19 Do you find it confusing? ~
20 THE WITNESS: Yes, I would like to 21 have it restated.
ka 22 MR. MacDONALD: All right.
23 Q Were there any changes to operating j t 24 procedures or design of the NSS that arose out 25 of analyses of SPR's prior to the TMI-2 accident?
l l
1 Walters 193 f~h U 2 A Yes, I remember over a period of time that I
3 there was probably specific hardware changes 4 and/or changes to set points or information of
(_ 5 that sort made as a result o f SPR's . I am not --
6 I don't remember any specific ones right now.
7 Can you recall how long some of Q
8 those changes took?
9 MR. KOLB: I don't understand.
! 10 "Took" in what sense? !
11 MR. MacDONALD: Took to resolve in 12 either the production of new operating
/~T U 13 procedures or the design change of the NSS.
14 MR. KOLB From what point?
15 MR. MacDONALD: From the point in 16 time that the SPR's were analyzed.
17 A Again I am -- there were certain SPR's I
18 that I am sure resulted in a very quick 19 turn a round , and there were other SPR's that took 20 quite significant time to get a resolution to.
2I Q Was the information from the Quick-22 Look Reports, evaluations o f the SPR's 1
23 disseminated throughout B&W?
24
() _ A I-don't' recall the extent of the 25' distribution of the Quick Look Reports.
1 Walters 194 O 2 Q Who was in charge of distributing 3 the Quick Look Reports?
4 A I believe Mr. Denny Napir was.
5
(( Q In what section was Mr. Napir?
6 A He is a project manager in the customer Service Department.
8 Q On Page 3 of your October 10, 1979 0
mema there is a graph, and on that graph it has 10 a left-hand section, "Pressuriser Level inches,"
11 "RC Pressure PSIG, "TAVE," those three parameters, 12 at least.
- 13 Will you explain to me what each of 14 those will tell you about - the state of an NSS 15 ^
during a transient?
16 MR. KOLB: objection as to form.
17 You can try to answer if-you understand the question.
A The specific parameters called out here 90 were -- are the usual parameters that you would 21 initially look at to compare with any previous 29~
. analysis, calculations or data available from a 20 variety of sources. They are essentially a I 24-( .
very quick and good parameter for categorising 25 a particular transient.
. ~ .- .-. . -, - , . , -
1 195 Walte rs O 2 Q What does the "Tave" stand for?
3 A It's the average temperature in the RCS.
4 Q The average temperature between the
( 5 hot leg and the cold leg?
6 A Yes, that is correct.
7 Q What does that parameter tell you 8
about the condition of the system?
9 A It tells you the ene rgy content that the 0
system retains during a transient or has during 11 a transient as compared with an analysis or an 12 expected reading of this particular parameter.
13 Q Is it a good parameter for measuring 14 the performance of the system during a transient?
15 A It is one of various parameters that are 16 good, yes.
17 Q The other two parameters that I 18 mentioned were pressurizer level and RCS pressure.
19 What were your reasons for' selecting 20 pressurizer level and RCS pressure on that graph?
21 MR. KOLB: I will object as to form 22 again.
23 A~ simply that as an initial evaluation of any 24 transient, there are various parameters that f)'T 25 should be looked at for an evaluation of that
t 1 Walters 196 2 transient.
3 I chose these four, one of my 4
4 engineers chose these five parameters, or as the
( 5 first ones to lesk at when we received the 6 information.
l 7 Q One. of the things you would look at 8 is whether RCS pressure and pressurizer level 9 were going in the same direction during a 10 transient? t 11 A I don't recall making that assumption.
12 Q Did ~,ou know that RCS pressure and 13 pressurize levu11ag go in opposite directions 14 during a transient?
15 A At what point in time?
16 Q At any point in time during a 17 transient. .
18 MR. KOLB: Why don't you read the l 19 question back? ~
20 MR. MacDONALD: Let me rephrase that, 21 and try it this way.
L 22 MR. KOLB: O.K.
23 Q Do pressurizer level and RCS pressure 24 always go in the same direction during the course 25 of a transient?
W al te rs 197 (3
V 2 MR. KOLB: I still have trouble with 3 your asking him again factual information 4 as he sits here today.
5
(( If you want to ask him what he knew 6
at the time of the events in issue or at 7 the time of a memo that is relevant, that 8 is different --
9 -
MR. MacDONALD: Let's do it at the 10 time of October 10, 1979, when he wrote 11 the memo, since we are discussing the memo.
12 MR. KOLB: Why don't you repeat the
\
13 question so Mr. Walters has it in mind?
14 MR. MacDONALD: Let me just restate 15 it so Charlie doesn't have to go back and 16 read it.
17' BY MR. MacDONALD: -
18 Q At the time you wrote this memo, Mr.
19 Walters, did you know that pressurizer level and 20 RCS pressure always trend in the same direction
. 21 during a transient?
L 22 MR. KOLB: I object to this as.to 23 form. You are assuming a fact. You are 24 assuming that that's correct.
[m-s}
25 . MR. = SELTZER: He is asking if that
+
t 4
1 Walters 198 i
fx
(' ' ' 2 is correct.
3 MR. KOLB: He did that when he
'4 phrased the question previously, but this
( 5 time he assumed it was correct.
- 6 MR. MacDONALD
- I am just asking 7 Mr. Walters.
O MR. KOLB: Why don't you just ask it 9 again as a question and not assume a fact.
10 BY MR. MacDONALD: S-11 Q You may answer.
12 A Would you ask -- I would like to have the
\' ' 13 question asked again.
I4 Do you know whether pressurizer level Q
15 and RCS pressure always trend in the same 16 direction?
4 17 MR. KQLB: And you are asking his 10 opinion as of the time of this memo?
19 A At the time I wrote this, October 10th, 20 1979 memo, I indeed knew that they_do not always 21 trend in the same direction in every case.
22 Q When did you firs t learn'that they do 23 not always trend in the same direction in every
- [D 24 case?
\_)- '
25 A I. don't remember.
1 Walters 199 t'h
%.) ' 2 Was it prior to the time of the Q
3 TMI-2 accident?
4 A I really don't recall that, either.
( 5 Q Do I understand that from your last 6 answer it is your testimony that prior to the time 7 of the Three Mile Island accident you did not 8 know whether or not pressurizer level and RCS 9 pressure could trend in opposite directions during 10 the course of a transient? t 11 MR. KOLB: First of all, you are 12 asking him what his testimony was just a s 13 few moments ago. It seems to me --
14 MR. SELTZER: He is trying to i
15 clarify --
16 MR. KOLB: May I finish? You are 17 asking him to tell you what he just 10 testified 'to, and you can read that yourself.
19 Secondly, you are mischaracterizing 20 the testimony, and I think you did it 21 with intent to mischaracterize'the 22 testimony; and I object to that.
23 MR. MacDONALD: No, I don't think i 24 I did it with intent.
25 MR. KOLB: Why don't we go back and i
_ , _ . _ , , _ _ _ , ___ ~
I Walters 200 read the testimony he just gave.
2 3 MR. MacDONALD: I am asking for an 4 understanding of his answer that he just
{, 5 gave, and I think I am entitled to know 6 what he meant by his last answer; and I 1
7 would like to know whether or not it was i
8 his understanding that prior to the time .
9 of the Three Mile Island accident he did 10 not know that pressurizer level and RCS 11 pressure could trend in opposite directions.
12 MR. KOLB: Now, the way you put the
("%
13 question is confusing because you have put 14 into it a couple of phrases that are 15 ambiguous.
16 If you want to ask the question 17 specifically, I don't have any objection to that, but you have to be cle[r; and I 19 won't let you go back and mischaracterize 20 prior te s timony . Just ask him the question 21 straight out.
MR. MacDONALD: I don't think I am 23 mischaracterizing the prior testimony.
4 BY MR. MacDONALD:
25-Q The question was: It is a fact, is 1
t 1
Walters 201
[)
\'
2 it not, that prior to the TMI-2 accident you did 3 not know the pressurizer level and RCS pressure 4 could trend in opposite directions?
() 5 A I just do not remember at what time I 6 became aware of that, of their coincident or 7 not trending on those two variables.
8 So, as you sit here today, you Q
9 couldn't positively testify that you did know that 10 RCS pressure and pressurizer level could trend in 11 opposite directions prior to the TMI-2 accident?
THE WITNESS: Would you read the A
' 13 question back, please?
14 (Question read.)
MR. KOLB: I am going to object as i
16 to form, because I think the question is 17 still confusing. I don't know if the 18 witness is able to answer this one or not.
THE WITNESS: I believe I have 20 already said that I can't remember when I 21 became aware of that, of that particular 22 instance.
23 Q So you can't positively testify
(~]
's.)
24 today that in fact before the TMI-2 accident you 25 knew that RCS pressure and pressure level could
1 Walters 202 2
trend in opposite directions; is that correct? .
3 A I cannot testify when I became aware that 4 they trended in opposite directions, at what 5 point in time I learned that.
(
6 When did you firs t learn of a Q
7 transient that occurred at the Davis-Besse plant 8 on September 24th, 19777 9 A I don't remember when I first became aware 10 of the transient. -
11 Q Was it sometime after the transient 12 occurred?
rm C_j 13 A That is safe to say.
14 Q How soon after that September 24th, 15 1977 transient do you believe that you became 1
16 aware that such transient did occur?
17 Approximately. .
A Sometime prior to November of that year.
19 Q. November of 19777 20 A Yes.
.21 Q Do you recall from whom you learned 99 I
~~
that a transient had occurred at the Davis-Besse plant on November 24, 1977.
24 MR. KOLB: Are you asking who he 25 learned from first?
- . ~ .
Walters 203
.1
(]-
'so 3 MR. MacDONALD: That is correct.
3 A I do not recall the person that I had 4 first communications with on that particular 5 transient.
{
6 Q What was the first discussion that you 7 can recall regarding the Davis-Besse transient 8 in September of 1977?
9 A I believe the first discussion I recall 10 was a memo from --
(
11 MR. KOLB: He is asking for 12 discussion.
f%
(_) 13 A I thought I already answered that question.
14 I don't recall the first discussion 15 with anyone, any specific person.
16 Q Do you recall any discussions at any 17 point in time regarding the Davis-Besse transient 18 in. September of 1977?
19 A
~
, I cannot positively say that I recall 20 discussion with any particular person on that 21 transient.
22 Q Do you recall in general any l
23 discussions with people at B&W regarding that {
[ 24 transient?
-25 MR. KOLB: I just want to be certain
1 Walters 204 ry V' 2 that we are clear. You are not talking 3 now about the first time he had discussions, 4 you are just asking about whether he had 5 any discussions at alls is that correct?
(
6 NR. MacDONALD: Yes.
7 MR. KOLB: Do you understand that 8 any discussion at all is the question.
9 Earlier the question was as to the first.
10 A Yes, I have had discussions about that 11 particular transient with people.
12 Can you recall the first of those Q
p
(. 13 discussions?
14 MR. KOLB: I think you have asked 15 that question now a couple of times.
16 I will let him tell you again, but I 17 think we pretty well covered that question.
MR. SELTZER: I thought he is asking 19 ~
now of the conversations which-he can recall 20 which.is the first one.
4 .21 MR. KOLB: That is not the way I m
22 understood the last question; but I will 23 certainly take that-question and allow the
/~N 24 witness to answer it tha t way, tha t is , if 25 ' you.know.
1 Walters . 205
[2-T N-2 Do you understand it? Which is the 3 first one you remember?
4 Q Of the discussions that you have just
( 5 stated that you recall, which one was the first 6 one that you can recall having?
7 A I believe the first discussion on that 8 transient that I recall was with Mr. Herb Smith. .
9 Q When was that?
f 10 A I believe it was sometime in: November of '77.
11 Did you review any written material Q
12 regarding the Davis-Besse transient on September c
13 24, 19777 14 MR. KOLB: You are not asking him 15 whether he reviewed the material on that 16 date; you are asking him whether he 17 reviewed anything about the transient on 18 that date?
10
! MR. MacDONALD: Yes.
20 A I believe I did, but I am not certain at j l
21 what point in time. '
L 22 Q. Isn't it a fact that you reviewed 23 the SPR's that were written at B&W regarding 24 (n) that September 24, 1977 transient at Davis-Besse?
25 A I would not have as a matter of course
~. . _ _ - . . . _ _ , _. , _ - _ . , . _ . _. .
, 1 Walters 206
/
2 reviewed that SPR.
3 Q That wasn't my question.
4 My question was, did you indeed 5 review those SPR's regarding the Davis-Besse
((
6 September '77 transient?
7 MR. KOLB: SPR's or SPR?
8 MR. MacDONALD: Well, I said 9 SPR's before.
10 A I don't recall reviewing an SPR on that 11 transient.
12 Q I would like to call your attention to 13 a question and answer you gave in response to 14 qu e s tions at the NRC 'Special Inquiry; Group 15 L
deposition Tuesday, October 2nd, 1979 at Pages 6 16 and 7 of your deposition, wherein you state, 17 "My knowledge of that transient was peripheral at 18 best. I believe Lee looked at the transient 19 plotted data, at the time I made a res'ponse to Mr.
20 Kelley's memo, and that's about it. I'was not 21 a part of the evaluation team that went into the 22 transient in detail.
23 " Question: How did you acquire the
)
% .)
24 information that you had?
25 " Answer: It was part --
I believe
_._ _ _ - . ~ . , - _ _ . _ _
1 Walters 207 O
N- 2 it was part of an SPR, site problem report, that
, 3 was submitted from the site."
4 Was that testimony accurate at the 5 time you gave it, Mr. Walters?
6 MR. KOLB: Would you read that 7 question back so the witness has the 8 question?
9 MR. MacDONALD: The question was:
10 was that testimony accurate at the time you 11 gave it?
12 MR. KOLB: Why don't you take a s_,/ 13 moment to read it.
14 (Transcript handed to the witness.)
15 THE WITNESS: Would you repeat the 16 question, please.
17 (Question read.)
18 A I don't recall if that is indeed how I 19 ~
obtained the information or not.
20 Q Were you indeed asked the question 21.
and did you indeed give the answer which I read 20" into the record at Page 6 and 7 of your Rogovin 23~
testimony?
24
( -A' Yes, I did.
25 Q And at the time you gave it was it a
- n n ,- -p *- e-.e ae +r-- p-- w ~r
1 Walters 208 j'- -
2 truthful answer? I l
3 A To the best of my knowledge.
4 Q And as you sit here today is it still i
{, 5~ a truthful answer?
- 6 MR. KOLB
- I know the' question is j
7 intended to get at a particular point, but i
, 8 I think we have to parse out for 'the witness j 9 what you mean by " truthful."
i 10 Do you mean, did he mean was he 11 honest in his response initially or is he 1
12 able to sit here today and tell you it is 13 accurate? There is a difference.
i 14
.MR. MacDONALD: Well, we are looking 15 at the truthfulness at this point in time f
16 as he sits here today, is it an honest '
17 answer.
- i. .
18 MR. KOLB: " Honest" meani g was he 10 trying to tell the truth when h[ gave the
.20 prior testimony, or is he able to affirm 21 today that that is accurate? I don't mind (c 22 if you ask him both of those questions 23 separately, but I think[,it's something he is
() 24 entitled to have you break that down so
> .25 that he can distinguish between his '
L , ,
s . . _ . . . . . _ . ,......,m. _..% . . . , __ , . . . . , . . , . ../.. . , _ , . . . , ~ , . , _ . . . . . , , , , , _~ . , . . _ , , , . , , , . . . -
k 1 Walters 209
('s 2 honesty or his credibility and his ability 3 to state that everything he has said there 4 is accurate.
l 5 BY MR. MacDONALD:
({
6 Q At the time you gave that answer 7 that was an honest and truthful answer, to the 8 best of your knowledge as you sit here today; 9 correct? '
10 MR. KOLB: I have the sane problem.
11 As he sits here today are you asking him 12 whether at the time he meant his answer to
, (^h
.N_) 13 be truthful; is that what you are asking 14
,, him?
15 MR. MacDONALD: That's correct.
16 A Yes, I meant my answer to be truthful at
'II that time. _
Q In that answer you said that you 10 looked at transient plotted data in the context 20 of a Kelly memo, I don't know whether the date 21 is in that answer, but is that a memo that Joe 22 Kelly wrote on or about November 1st, 1977?
2 A I believe that is correct.
/r 94 (y
- Q Was that transient plotted data that 25 you reviewed part of an SPR on Davis-Besse?
1 Walters 210 2 MR. KOLB: I object as to form, 3 because you are now assuming that he in 4 fact reviewed the data referred to in 5 that answer and he has just told you a few
((
6 momen ts ago that he can't recall.
7 MR. MacDONALD: No --
0 MR. KOLB: So you are not entitled 9 to assume it to be a fact. I don't object 10 to your asking him the question straight out.
11 MR. MacDONALD: I am asking him a 12 i
different question from the SPR. I am s- 13 asking him, was that transient plotted data 14 that he refers to in his answer transient 15 plotted data that was included in the SPR 16 in Davis-Besse.
17 A It may have been. I do not recall.
18 MR. MacDONALD: Why don't we take a 19 short break?
20 MR. KOLB: Yes, that is a good time for ;
i
.21 it. j E
(Recess taken.)
BY MR. MacDONALD:
-r
( f 24 Q Mr. Walters, did you attend any 25 meetings at B&W within the time frame of a couple
1 Walters 211
's-) ' 2 of months after the Davis-Besse September 1977 3 transient at which the transient and what 4 occurred during the transient was discussed?
{ 5 A I don't recall going to any meetings that 6 the specific transients were discussed.
7 Q You don't recall attending a meeting 8 that was presided over by Mr. Kelly at which 9 some 30 to 40 people at B&W were present shortly 10 after the Davis-Besse transient? I 11 A I recall that I was not present at that.
12 Q Do you know when that meeting took O
d 13 place?
14 A No, I do not even recall when it took place.
15 Q Have you had any discussions with 4
16 anyone about that meeting?
17 MR. KOLB: Apart from counsel?
18 MR. MacDONALD: Apart from counsel.
19 A I don't believe I have.
20 Q Do you know who was in attendance at 21 - that meeting?
22 A No, sir.
23 Q At any point in time after the r"N . 59
) Dav'is-Besse transient did you have any discussions 25 with anyone at B&W regarding what went on at that i
- m -
v -ww -
1 Walters 232
/3 V 2 meeting held at B&W shortly after the Davis-Besse j 3 transient?
4 A To the best of my knowledge I had no
( 5 discussions with anyone about that particular 6 meeting.
7 Q Did you have any discussions with 8 anyone at which the subject of that meeting came 9 up?
10 MR. KOLB: I take it all these 11 questions are apart from counsel?
12 MR. MacDONALD: That is correct.
fm
- 13 MR. KOLB: So I don't have to keep 14 interjecting.
15 A I don't recall any conversations with anyone 16 about that particular meeting or information from 17 that particular meeting. .
Q You stated earlier that y u did have I
discussions after the Davis-Besse September 1977 90
~
transient regarding that event, one of which you 21 mentioned was a conversation with Herb Smith in 29 or about November of 1977.
23 Can you recount for us what the
[ 'i 24 T ,/ sub' ject matter of that conversation was?
25 MR. KOLB: Would you repeat the
t 213
- 1 Walters Ci- 2 question, please?
3 (Question read.)
4 A The subject matter of that particular 5 conversation was a memo that I had received from (l
6 Mr. Kelly.
7 Q And when did you receive a memo from 8 Mr. Kelly?
9 A Around the early part of November of '77.
10 Q And Mr. Smith was a member of the 11 Plant Performance Services Section of B&W?
12 A No, he wasn't.
/^)s
(_ 13 Q What group was he in at B&W7 14 A He was in the Mechanical Equipment Section 15 of Nuclear Service.
4 16 Q To the best of your recollection what
[ 17 did you say to Mr. Smith at that point in time 10 and what did he say to you?
19 A I don't recall an initial conver$ation with 20 him.
2 21 Q You don't recall in substance what you 2
said to him and what he said to you during that
- 3 conversation in or about November of 1977?
() 4 A The conversation I recall was concerning or 25 of the idea that here was Mr. Kelly's memo, would
1 Walters 214
' '- ~ he provide any comments to me on this memo, 2
3 something of that nature.
4 Q Did you show him a copy of Mr. Kelly's memo? ks
( 5 6 A Yes.
7 Q Did you ask him for any written 8 comments on that memo?
9 A I don't recall asking for any specific 10 written comments, no. g 11 Q Did he read the memo in your 12 presence? ,
w s 13 A No, he did not.
14 Q Did he provido you with any comments 15 on the memo at any subsequent point in time 16 after that discussion?
17 ,A Yes, he did.
18 Q What did he say to you?
19 A He made some comment about there was too 20 many "and's" in the prescription as provided by 21- Mr. Kelly in the memo.
22 Q What was the reason that you asked i
23 Mr. Smith for his comments on the memo?
i
[~)
'V 24 A Upon reading the memo I had formed certain i
25 conclusions or concerns about the. memo, and I
1 Walters 215 O 2 took it to Mr. Smith to get another opinion on 3 the particular subject of my concerns.
4 Q Why did you go to Mr. Smith in
{ 5 particular?
6 A I have a habit of seeking out people that 7 I think are aware or knowledgeable on certain
! 8 items. Mr. Smith had been a training instructor 9 future -- previous to this time, and I had 10 conversations in the past with him along general 11 or specific topics.
12 Q Did you seek comments from anybody O
( 13 else within B &W on the Kelly memorandum?
14 A I am not certain. I believe I did.
15 g who would those people be?
16 A The only other person that comes to mind i 17 is Mr. Cal Goslow. .
18 Q Who is Mr. Goslow?
19 A Mr. Goslow was an engineer that' reported 20 to me,at least part of his work he reported to l
21 me.
22 Q You stated a moment ago that you said 23 "I had concerns after reading the Kelly memo.."
f~)
V 24 What concerns did you have after reading 25 the memo that prompted you to go and speak to
1 Walters 236 2 Mr. Smith?
3 A Initially I had the concern that the J
4 prescription as offered'by Mr. Kelly in his memo
(' 5 would be difficult or at least would require 6 quite a bit of thought; and how to pass this 7 along to the opeiators so they would understand it 8
in a very easily and readily acceptable manner.
9 Q Did you think that Kelly voiced a 10 valid concern in his meno that he sent to 11 Distribution?
12 A I really don' t recall coming to a 0
(_ 13 conclusion either way.
14 Why did you seek out Mr. Cal Goslow Q
15 for his comments on the Kelly memorandum?
16 A For essentially the same reasons I had 17 previously talked to Mr. Smith. He had similar 18 background as Mr. Smith.
19 Q In the Training Department?
20 A That's correct.
. 21 Q As an instructor?
km
.22 A Yes.
23 g Rad he ever been a lead instructor?
[~T 24 A I believe that is correct.
I
%.)
25 Q nad Mr. Smith?
, , ,.--n , . . , -
4 1 Walters 217 h
(V 2 A I think so also.
3 g was the conversation that you had 4
with Mr. Goslow at or about the same time as 5
(l the conversation you had with Mr. Smith?
6 A I think in a week of each other.
7 In substance what did you say to Mr.
Q 8
Goslow and what did he say to you during the 9 course of that conversation?
10 A As best I remember, I rel ated, some details 11 or some words of the transient to Mr. Goslow, and 12 A we talked in a very general nature about how the 1 - 13 transient had unfolded, something of that nature.
14 Q Did you show him a copy of the Kelly 15 memorandum?
16 A I don't recall that I did or I did not show 17 him the copy of it. .
18 Q Can you recall what Mr. Goslow's, 19 the substance of Mr. Goslow's commentA during 20 the course of that discussion were?
21 A I only remember something pertaining that 22 we believe the operators had responded in a 23 correct manner or that maybe we didn' t see 24' (a) anything specifically about the transient that 25 caused us any specific concern.
1 Wal te rs 218
\
'^ 2 In other words, in your discussion Q
3 with Mr. Goslow about the Kelly memorandum, you 4 came to the conclusion that the operators had j 5 acted correctly during the course of the 6 Davis-Besse transient?
7 MR. KOLB: Are you trying to say 4
8 that that is what he just said, or are you 4
9 asking a fresh question, is that the 10 conclusion.he reached; is that your intent?
11 .M R . MacDONALD: That is the question.
12 MR. KOLB: That wasn't the question.
O(,) 13 You asked him whether he meant by his prior 14 statement what you just stated, and I don't ,
f 15 think.that is at,all fair.
8 16 Why don' t you ask the question again?
17 -
M]R . MacDONALD: head back the 18 question. I will stand on that' .-
19 (Question read.)
'__ .s' 20 A I don' t recall that I came away with that i
21 Particular understanding to that particular 22 , conversation.
1
.s.
23 Q But at the time of the conversation
("}
w./
24 was that your understanding of the action of the I 25 operators that in fact at the Davis-Besse
,3 ,
1 Walters 239 f
l
-~.( -
2
, transient their actions had been correct?
3 A I think I made up my own mind to the 4
information that I had at that time that that
( 5 was correct.
6 Why was the training background that Q
7 Mr. Goslow and Mr. Smith had important in 8
analyzing the concerns that Mr. Kelly raised? _
9 A only in the context that they were people 10 that I generally contacted with respect to their 11 opinion on any of a number of issues.
12 Q Was it their background and the
{')N s- 13 dealing they had in the past with the actual 14 training of operators at B &W that you considered 15 gave them better insight into what operator 16 actions might be in response to the particular 17 transient that was being discussed? ~ .
18 MR. KOLB: Would- you read the is 19 "
question back, please?
20 (Question read.)
21 A I don't believe I ever came to a realization 1
(.
s 22 that I was asking_them for their opinion on what 23 they had actually trained operators. We were
( (' 24 discussing the matter.at hand, the particular I L A-)/
l\'
i- '
25 Kelly memo at hand, and that is essentially 3
h3-
i 1
Walters 220 2 about all I remember about it.
3 Q Did you consider their background 4 in training of operators important to your
( 5 understanding of the concerns that Mr. Kelly raised 6 in his memo?
, 7' A Yes, I -- part of my reason for talking to l- 8 them was their background in training. .
9 Q Where did you obtain your information 10 on how the transient e volve d at Davis-Besse during ,
11 your discussion with Kal Goslow?
12 A I don't recall any specifics in that x_ 13 discussion with Mr. Goslow.
14 Q Did you discuss with Mr. Goslow the 15 evolution of the Davis-Besse transient, the e
16 sequen ce of events?
17 A I must have, but I don't recall that.
18 Q Did you do the same with Mr. Smith?
19 A I must have, but I don't recall the specifics 20 or any general conversation.
-f 21 Q Where did you obtain the information 22 regarding the evolution of sequence of events of 23 the transient that you discussed with both Mr.
("T . 24 Smith and.Mr. Goslow?
d_# '
25 MR. KOLB: Would you read the question I
,~m . , - - , - -e, e --ev , r p m- - -a- , , a e- -
.-,y s-v. - g-wem ea-----e--
. . . .=
1 Walters 221
' O' D 2 back, please?
3 (Question was read.)
2 4 MR. KOLB: I will object as to form,
( 5 because you are assuming facts.
6 The. witness can answer if he is able.
7 A I don't recall where I obtained the 8 information.
9 Q Was one of the sources the Kelly 10 memorandum? (
11 A Yes.
12 Q were there any other sources?
p.
k- 13 A The best that I can say is that there was.
14 Q Do you recall what those other sources 15 were?
16 A I certainly don't. At least where they 17 came from.
~
18 Q Eow did you obtain a copy of the 19 Kelly memorandum?
20 A It came to me in my in-basket-from Mr.
21 Hallman.
22 MR. MacDONALD: I would like to 23 mark as GPU Exhibit 131 a copy of a memo
[\,_/) 24 from J. J. Kelley to Distribution, 25 November 1, 1977.
1 222 Walters
. O]
\.
2 (Memorandum dated November 1, 1977 3 from J. J. Kelly to Distribution, subject:
4 Customer Guidance On High Pressure
([ 5 Injection operation, was marked GPU 6
Exhibit 133 for identification, as of this 7
date.)
0 (Do cument handed to the witness.) .
9 Q Mr. Walters, is this a copy of a 10 memo that Mr. Hallman routed to you,in or about 11 November, early November of 1977?
12 A Yes, it is.
O 13 Q In the top right-hand corner it has 14 the initials "JFW" and says, "What do you think?"
15 Is that Mr. Hallman's writing?
16 A Yes, it is.
17 Q And that was a question to you from 18 Mr. Hallman?
19
-A That is correct.
20 Q Did you have any discussions with Mr.
21 Hallman about the contents of the Kelly 22 memorandum?
- 23 A I don't recall any discussions with him.
/~%
24
() Q Either before or after the receipt 25 of this memo?
. - . . - . - -. - -- - - - - - l
1 Walters 223
~
(""\
~
2 A In the time frame of this memo, I don't 3 recall any discusssions with him.
4 Q Do you recall any discussions with
( 5 him about this memo outside of the time frame.
6 that the memo was written?
7 A I don't recall that, e ith e r .
8 Q You don't recall that you had any?
9 A That's correct.
- 10 Q In the third line at the top of this 11 memo it says "Cust. Generic."
12 Does "cust." stand for customer?
13 A Yes.
14 Q Does " generic" mean it is generically 15 applicable to all 177 plants?
16 A Yes, that's the way I read it.
17 Q In the firs t sentence o5 .this 18 memorandum Mr. Kelly states, "Two recent events at 19 the Toledo site have pointed out that 'perhaps we 20 are not giving our customers enough guidance on 21 the operation of the high pressure injection 22 system."
23 Did you know at any point in time 24 before you received this memo'what the details
(~'-)
s.
25 were of the two events that Mr.' Kelly referred
1- Walters 224 2 to in the first sentence of his November 1st, 3 1977 memo?
4 A I do not believe I knew any details prior
( 5 to receiving this memo of those events.
6 He gives a reference in that first Q
7 paragraph. to the transient that we have been 8
speaking of, the September 24, 1977 transient, .
9 and also to one on October 23rd, 1977.
10 Do you know what the circumstances 11 were in the October 23rd, 1977 transient?
12 MR. KOLB: Are you asking what 13 he knows now or did he know t the time?
14 MR. MacDONALD: At the time he 15 received the memo.
16 A I do not believe I was aware of the second 17 transient at TECO. .
' 18 Q At the time you received the memo or 19 at any time thereafter did you know'of the 20 circumstances of the second transient on 21 October 23rd, 19777 22 A I don't recall that I did.
23 He says in the last sentence of that Q
, ) 24 first paragraph that "In_a similar occurrence on 25 October 23, 1977, the operator bypassed high
, Walters 225 O' 2 pressure injection to prevent initiation, even 3 though reactor coolant system pressure went 4 below the actuation point."
( 5 At any time subsequent to the 6 Nove mb er 1st, 1977 memo did you learn of any 7 other events which occurred on October 23rd, 8 1977 at the Davis-Besse plant that expanded on 9 what Mr. Kelly has stated in that sentence?
10 MR. KOLB: When you say "at any 11 time," do you mean to bring this up to 12 the present or --
(^%
- I3 MR. MacDONALD: Let's deal with 14 it at any time prior to the TMI-2 accident 15 and we will deal with it afterwards.
I 16 MR. KOLB: Fine.
17 A I don't fully remember the question.
18 Q Aside from-the information that Mr.
I 19 Kelly conveyed to you or that you understood from 20 that particular sentence, at any time after 21 November of 1977 did you come to know of any 22 more information about that October.23rd, 1977 23 transient --
24 MR. KOLB: Up to the time --
-(
25 Q Prior to the TMI-2 accident.
~1 Walters 226 i O 2 A I don't recall that I ever had any 3 information that I directly related to the 4 Cctober 23rd incident at Davis-Besse.
({ 5 Q Did you ever discuss that october 6 23rd incident at Davis-Besse with anyone up 7 until the time of the TMI-2 accident?
t 8 A Not that I recall. .
9 Q You never discussed it with Mr.
d 10 Kelly that you can recall? '_
11 A I am almost certain I never discussed it I 12 with him.
13
-Q or with Mr. Hallman?
14 A I do not believe I discussed it with him.
15 Q Subsequent to the TMI-2 accicent 16 have you discussed that transient of october 23, 17 1977 with anyone within B&W7 -
, 18 MR. KOLB: All these questions are
)
19 apart from counsel?
20 MR. MacDONALD: Yes. '
21 A I do not have any recollection of ever 22.
discussing that particular transient with anybody.
23' Q At any point in time have you ever seen
( )' 24 ' .or read any documents'that expand on the 25 information provided by Mr. Kelly in his memo on.
l
1 Walterc 227 f}
\_/. 2 November 1, 1977 about that October 23rd, 1977
'3 transient at Davis-Besse?
4 A Again I don' t remember reading or having
(; 5 anything that called to my attention that the 6
information I was reading was concerning that 7 October 23, 1977 transient.
8 Q Did you read any information that 9 related in any way to the events that occurred 10 or that you knew occurred from what Mr. Kelly 11 recounted to you on October 23rd?
12 A I certainly don't recall any.
\' 13 Q Did you read an SPR or look at an 14 SPR for the October 23rd, 1977 transient?
,15 A I don't recall that I did.
16 Q Did you speak to anybody at Toledo 17 Edison about the October 23rd, 1977 transient?
I0 A No, I spoke to no one at Davis- esse.
19 Q That being synonymous with Toledo
~
20 Edison?
21 A Yes, it is.
C 22 Q Did you ever speak to anybody at 23 Toledo Edison about the September 24, 1977 C
\,.j .
24 transient?
25 A No, I never spoke to anyone at Toldeo about
._. . . - _ _ ,_ - . . - _ . _ _ . - _ . . - - ~,,
I walters 228
- O, .
2 that transient, either.
3 Q. Or about the significance of the 4 events that occurred during that transient?
{; 5 A No, I did not.
6 Q Did you speak to anybody at the NRC 7 about the October 23rd, 1977 transient?
8 MR. KOLB: Do you mean to include i
9 any testimony he may have given?
10 MR. MacDONALD: Let's say apart from 11 testimony he has given and then I will ask 12 him about the testimony.
13 A No, I have not talked.to anyone at the 14 NRC about it.
15 Q Have you given testimony about it to
\
16 the NRC?
17 A Yes.
18 Q What was the substance of that 19 testimony and when was it given?
20 MR. KOLB: Are you asking him to k
21 recount for you what is in the record you 22 have?
23 MR. MacDONALD: l I don't know whether it !
() ; 24 is in this record or not.
Q.f 25 MR. KOLB: I have no reason to think
_ _ . - - J
Walters 229
/~N 1 2 you don't have what he is talking about.
3 MR. MacDONALD: I want to clarify if 4 that is indeed what I do have.
MR. KOLB: Why don't you ask him
( 5 6 when and so on.
7 BY MR. MacDONALD:
8 Q When was the testimony given before the g NRC?
10 A I don't remember when. It was a deposition 11 to the Rogovin Commission in Lynchburg.
12 Q That is the only time you have s- 13 testified before the NRC7 14 A Yes.
15 Q Is that the only time you have ever 16 given a statement to anybody from the NRC?
17 A Yes.
18 Q Did you ever review any LE R's on 19 the october 23rd, 1977 transient? -
20 A I don't recall that I did.
21 Q Did you ever ask anybody that 22 reported to you or anyone else within B&W to 23 look at either the SPR or the LER for that o
} 24 October 23rd, 1977 transient?
25 A I don't remember doing that, no.
i.
s
. c ~_.4 _.-..,-_,,7 ,. ,_.e , , , , - , . . , . . . _ . . , , .._n
y Walters 230 J. E Q In that first sentence where Mr.
3 Kelly says "...perhaps we are not giving our 4
customers enough guidance on the operation of 5
-( the high pressure injection system," did you 6
understand at the time that you read this memo 7 that Mr. Kelly was advocating providing additional 0
_ guidance from B&W to the customers,to its 9
customers, on the operation of the high' pressure 10
, injection system? t 11 A I don't recall having a specific 12 recolle ction of that scenario.
13 Q Did you have a general _ understanding 14 from reading the entire document that that was 15
. indeed what Mr. Kelley was proposing?
16 A I don't think I recall reflecting on any 17 or rather coming to any conclusion that we 18 t
were or were not talking about sending additional 19 information onto the operators at that time.
20 Q You didn't. understand that it is 21 what Mr. Kelly was proposing by stating in the 22 second paragraph, "I wonder what guidance, if 9
23 any, we should be giving to our customers on f ).
~
24 when they can safely shut the system down 25 following an accident? I recommend the J
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. - .. . . . . _ ~
h
~
1 Walters 231 f"%
~ '
2 following guidelines be sent."
L 3 A I only recall the memo was recommending !
4 certain additional items be-considered, and I
( 5 responded to Mr. Kelly, giving my thoughts to 6
him on that particular subject.
7 Q Was it your understanding that Mr.
8 Kelly was only recommending that certain 9'
additional guidance be considered as a result of 10 reading this memo? .
A Yes, that is the way I recall reading it.
12 Q What did you understand by the O.
phrase "I reco.mmend the following guidelines be 14 sent"?
15 A I. don't recall havingLany specific reaction 16 to what he was intending there at this time.
17 Q But it is your testimony that.you 18 don' t recall understanding from this emo that 19 Mr. Kelly was proposing additional operator 20 guidelines be sent by B&W to its utility 21 customers? .
22 MR. KOLB: Would you repeat the 23 ques tion, please?
, ('v ) 24 (Question read.)
25 A e
I remember that Mr. Kelly was presenting.his
-4 , ,-e e r ~ ...-e. -
.s- . , , - , - - . . , , , , . - ,-_.v , - - - - . - - , - . ,, , _ , , - - - - - . - . . - . . , - .
I 1 l
, Walters 232
(')
\_/.
~
2 thoughts on the subject, and I think I reflected
. 3 that in my own mind there were procedures in 4
place that should address the particular items A
{ 5 that we were talking about he re , and I responded 6
to Mr. Kelly in the matter of my thoughts on his 7
two particular suggestions in a) and b) of the 8
memo.
9 Q At the time you read and discussed 10 this memo,what in here, in Mr. Kelley's memo, 11 led you to believe that he was not proposing or 12 reccmmending that his prescriptions labeled a) x- 13 and b) be sent to customers?
14 MR. KOLB: There is no testimony 15 to that effect. You are assuming that that 16 is what he has testified to.
4 17 MR. MacDONALD: I think he testified 18
, that he believed at the time he read it that 19 Mr. Kelly was just proposing certain things 20 for consideration and that is what the 21 words suggested to him.
C.
22 MR. KOLB: That is different from 23 4
what you just said.
[)
%j 24 MR. MacDONALD: Well, I think that 25 what I am asking him at this point in time y % y- ,- , we a- -
---g m e w- -+-
- y-- --~-y- - + -'rt-<rm-- y ----+-'---t +M$ r-- +-
1 Walters 233
/9
.h' 2 is what suggested to him -- well, let me 3 withdraw that and ask you this question:
4 BY MR. MacDONALD:
( 5 Q Did you believe at the time you 6 read this that Mr. Kelly was not proposing that 7 these prescriptions a) and b) be sent to 8 customers o f B &W to provide guidance on the 9 operation of high pressure injection?
10 A I don' t believe I came to that conclusion.
11 Q What did you believe that Mr. Kelly 12 meant when he stated that he would recommend O)'
\ ~- 13 that the following guidelines be sents when he 14 said "be sent," what did you understand that to 4
15 mean? .
16 A I thought he was saying that this is 17 information that based on what he had.done, 18 whatever that might be, as far as analysis of 19- the transients, would be to either an ' improvement 20 to or additional information to procedures already 21 in place, as I knew them, meaning the procedures 22 that B&W had sent to the utilities.
23 Q And Mr. Kelly was proposing that these 24 additions to the procedures be sent to customers
[%.)T 25 in his memo of November 1, 19777
, 1 Walters 234 2 .A I think I read this with the context 3 that he was asking indeed from a number of 4 people, should indeed this be sent out.
.( 5 Q You understood that his dealing on it 6
as stated in his memo was that he felt that the 7 guidelines should be sent?
8 A I don't recall coming to any -- to that 9 conclusion at this time.
10 Q In the second sentence (of Mr. Kelly's 11 memo he states: "On September 24, 1977, after 4
'12 depressurizing due to a stuck open electromatic O 13 relief valve, high pressure injection was 14 automatically initiated."
15 Do you recall that this sequence that i
16 i Mr. Kelley described was the beginning of the 17 sequence of events at the Davis-Besse transient 18 on September 24, 19777 19
- a. MR. KOLB: Are you asking him whether 1
20 J
he-recalls that this was Mr. Kelly's 21 description, the beginning of events, or 22 -are you asking him whether as an 23 objective fact he understood at the time I 24
.\s) that those were the -- that that was the 25 beginning of the event?
, _ _ . _ ~ . . . . , . . , _ . ~ , . . - , . , _ _ . , . . . . . - , , . , .- . . . . . , _ _ _ , . . . -_
1 Walters 235 2 MR. MacDONALD: What he understood 1
3 at the time as to whether or not that '
4 reflected the beginning of the Davis-Besse
( 5 September 24, 1977 transient?
6 MR. KOLB: Also the time we are 7 talking about --
8 MR. JiacDONALD: Around the time of the 9 November '77 memo.
,10 MR. KOLB: 0.K. ',
11 A I don't recall coming to any specific 12 conclusion about this particular sentence.
U 13 Q What did that sentence mean to you 14 when you read it?
15 A Simply that the high pressure injection 16 system had initiated automatically on a 17 depressurization of the RCS. .
18 Q Also that depressurization was caused 19 by a stuck-open electromatic relief valve?
20 A Yes, sir.
21 Q The electrometic relief valve is k 22 another way of saying a PORV?
23 A That is true.
24 Mr. Kelly goes on in the next Q
25 sentence to say, "The operator stopped HPI when
l l
1 Walters 236 2 pressurizer level began to recover, without i
3 regard to primary pressure. As a result, the j 4 transient continued on with boiling in the
( 5 RCS, etc."
6 When.you rea'd that at the time yo6 7 received a copy of Mr. Kelly's memo to Mr.
8 Hallman'in or about early November of 1977, .
4 9 what was your understanding of the sequence of 10 events as Mr. Kelly has recounted them in that 11 first paragraph?
12 A I don't remember any conclusions that I
%> 13 came to at this time concerning that~particular 14 paragraph or sentence.
15 g You stated your understanding of the 16 previous sentence that b'egins, "On September 24, 17 1977, after depressurizing..." -
. 18 What understanding did yo come to 19
- regarding the sequence of events from what ~ Mr.
20 Kelly stated as the operator stopped HIP when i 21 pressurizer level began to recover without regard to
+
22
-primary pressure and as a result the transient 23 continued'on with-boiling in the RCS...et cetera?
[ - 24 A
%;} - I just don't recall any specific or general- t
- 25
- recollection upon reading.that other--than what-
+ - , e v.v ,,- -,,e,-r- .e,-,p--,-,--y-e y- -e , ,-,--,e-.e~p.,,e-m--,,n ,,_......,mve.r-,wnw-.-,--.-%.-e,,.-,y ---,-nr -v,- .w.r,-n.--,,e,r.,wm- e y.w--sw---
1 Walters 237 2 it says.
3 Q Did you understand at the time that 4 after depressurizing due to a stuck-open PORV
( 5 that high pressure injection was automatically 6 initiated at Davis-Besse on September 24, 19777 7 A Yes, that's what the memo says.
8 Q Did you also understand at that ,
9 point in time as Mr. Kelly recounted in the
, 10 second sentence that,'the operator stopped HPI 11 when pressurizer level began to recover, 12 without regard to primary pressure. As a result, 13 the transient continued on with boiling in the 14 RCS."
15 A I still -- I don't remember any particular 16 information that I gleaned at this time that I 17 remember from that particular sentence, other 18 than what is stated here.
19 Q At the time you read that sentence 20 or had your discussions with Mr. Smith and Mr.
21 Goslow about the sequence of events, and the 22 phrase, "the operator stopped HPI," did you 23 understand that to mean that the operator 24 manually terminated the high pressure injection 25 system?
._ . _ . _ , , . - -, ~- - _.
i Walters 238 2 A Yes, I believe I did.
3 Q And did you understand that he did 4 that when pressurizer level began to recover
( 5 without regard to primary pressure?
6 A , I don't believe that I ever remember 7 making any conclusion.from that that was indeed 8 the case.
9 Q What did you understand when you 10 read the words, "when pressurizer level began 11 to recover without regard to primary pressure"?
12 MR. KOLE: I think I might just
' Ns) 13 interject. I think the witness is saying, 14 has said, that he doesn't have an 15 independent recollection of what he 16 thought beyond what the words say. He 17 said that now two or three times.
18 I am not sure at this point that we
~
19 are getting anywhere. I am certainly 20 not going to obstruct you from asking him 21 what he thought at the time, but if he
, 22 doesn't remember what he thought at the time, 1
t 23 he doesn't remember.
1
[)
\s' 24' MR. MacDONALD: I think he stated in i
25 response to some of my questions that he
k 1
Walters 239 A
ks 2
did understand at the time what certain 3 of these phrases meant in terms of the 4
chronological sequence of events.
( 5 I am just trying to explore what some 6
of the other event sequences were at the 7
time of the transient and at the time he 0
read this memo from Mr. Kelly. -
9 Let me ask this 10 question --
11 MR. KOLB: I took him to mean, and 12 I think he said that he was reading the bi
\_/ 13 literal words and could read.them now and i 14 could say that those are facts that he read 15 but that is different from having an 16
, independent recollection beyond what those 17 words mean. I think that without going 18 back and taking each word of the transcript 19 it is-important to get clear the 20 difference between the situation where ho 21 remembers something separate and apart from the 22-
, document and the case where he can actually 23 read the words and tell you he knows what r~~
(g) 24
.they mean.
25 MR. MacDONALD: I think he has already
- I Walters 240
)
2 stated that he did have an understanding {
l 3- at the time he read this document of what 4
the depressurizing due to a stuck-open
( 5 electromatic relief valve meant, and high 6
pressure injection was automatically 7
initiated. I think the record will speak 0
for itself on that. We are just moving -
9 on to the next sentence; and I am trying 10 to understand at the point i[i- time that he 11 1
read this memo what he believed the next 12 sequence of events was from the words 13
, that he read. We are moving on to the 14 next sentence. I think he has already 15 stated on the first one, I am just .
16 attempting to get that on the next I
chronological event sequence. -
10 So, perhaps if I br ak it down a little 19 more.
20 BY MR. MacDONALD:
21 Q By " operator stopping HPI," at,the time 22 you read this memo, did you take that to mean 23 that the operator manually had terminated the 24 high pressure injection. system at Davis-Besse on 25 september 24, .19777
1 Walters 241 2 A Yes, I think so.
3 Q What did you understand by "when 4 Pressuriser level began to recover," did that
(' 5 mean to you at that point in time that 6 Pressurizer level was rising?
7 A Yes.
I 8 Q Is that what you understood that to ,
9 mean?
10 A Yes. t 4
11 Q Without regard to primary pressure, 12 did you understand that to mean that pressure was 13 not rising correspondingly with th pressurizer 14 level?
15 A I don't remember making any association 16 there.
17 Q When you read that sentence, did you 18 understand that the operators had terbinated
~
'19 HPI based on the rising pressurizer level?
20 A I don't remember that I drew that conclusion, 21 either.
22 Q At the time you read this memo 23 what did you understand the phrase, "without
, r^
regard to primary pressure," to mean?
i (v) 24 25 A I assume I read it just as it is written.
i 1 Walters 242
- i 2 Q How is that? What does the phrase
! 3 mean,."w'ithout regard to. primary pressure"?
4 A That we assumed that the operator stopped
( 5 the HPI looking at pressurizer level and did 6 not consider the primary pressure at that time.
7 Q In the next sentence Mr. Kelly goes 8 on to state, "As a result, the transient continued 9 on with boiling in the RCS, etc."
10 What did you understand,at the point in 11 in time you read Mr. Kelly's memo that that meant i
12 in regard to the chronological sequence of events?
(~h
'/
13 A .Just as it states, that evidently the --
14 he assumed there was boiling going on in the 15 core -- in the RCS.
16 Q After the time that the operators 17 terminated HPI? .
18 A Yes, I think that's true.
19 Q What was the significance,' if any, 20 to you of the fact that the transient continued
- 21 on with boiling in the RCS, when you read this 22 memo?
l 23 A I don't recall any significance other than f
( I)
L/
24 the fact that the letter says it was boiling l 25 going on in the RCS .
... _ . ~ . _ ,
1 Walters 243 O 2 Q What did you understand by the 'l 3
phrase, " boiling in the RCS," what did that mean 4
to you? That was a two-phase mixture of both
(, 5 steam and water within the reactor coolant 6
system?
7 A Yes, that is true.
Q Does that mean there was saturation 0
in the RCS?
10 g y,,,.that's a fair assumptions 11 Q Did the phrase, "the transient I2 continued on with boiling in the RCS," indicate b- 13 to you that there was something wrong in the 14 reactor at that point in time?
A I assumed that it did at that t,ime.
I don't i
16 recall making that judgment.
Q Did you have any understanding at that point in time of why pressurizer level was 19 rising during the Davis-Besse transient?
20 MR. KOLB: Would you read the question, 21 please?
22 (Ques. tion read. )
23 MR..KOLB: Are you confining that
) 24 question to the information in this memo, 25 or are you asking a broader question as to
1 Walters 244
- /')N
(_
+
2 whether at about this time he gathered 3 any information about the transient?
4 MR. MacDONALD: I think he has
( 5 testified that he was gleaning.the 6 information from the memo regarding the 7 transient. I am asking him what he 8 understood at the time he read this memo.
9 MR. KOLB: So you are confining it 10 to the memo itself? (
11 MR. MacDONALD: For this particular 12 point, yes.
t N- 13' MR. KoLB: o.K.
14 A Now, if I get the specific question you 15 asked.
16 MR. MacDONALD: Will you please 17 read the question back. .
, 18 (Question read.)
~
19 A I don't recall coming to any conclusion 20 at th at time about that particular item.
21 Q Did you make any connection-between 22 the boiling in the RCS and the phrase that Mr.
23 Kelly stated, "The pressurizer level began to p)
( 24 recover"at the time you read this memo ?
25 A I don' t believe I did.
. ~ _ . . _ _ _ . _ . . _ . . . . _ .
l 1
, y Walters 245 O 2 Q Is it a fact that there was boiling in a
3 the RCS indicat e to you at that time that 4 there was a loss-of-coolant accident occurring?
( 5 A I' don't believe I made that conclusion.
6 MR. MacDONALD: Is this a good time 7 to break for lunch?
8 MR. KOLB: Whenever you're ready.
9 MR. MacDONALD: All right, fine.
10 (Whereupon at 12:42 o'61ock p.m.,
11 a luncheon recess was tak en . )
i 12 13 14 15 16 17
~
18 19 20 21 22 l
l 24 l
x_
i
- l. 25 i
s 1 346 s ,
[~T
() 2 i
AFTERJOON SESSION 3 2:15 P.M.
4 JAME S F RANKL I N WA LT E RS, ;
l{ , 5 resumed and t'estified further as follows:
6 EXAMINATION (CONTINUED) 7 BY MR. MacDONALD: .
8 Q Are you aware, Mr. Walters, that 'your 9 testimony continues under oath this afternoon?
10 A Yes, I am.
- l 11 -
-Q Did you come to know at some point in 12 tine ~ after the TMI-2 accident that boiling in the O
\- 13 RCS was an indication that the re was a loss-of-14 coolant accident in progress?
15 MR. KOLB: When you say ,. did he come to 16 know, do you mean know for the first time?
17 That is the implication of "come to'know."
18 -
MR. MacDONALD: That is correct.
19 A Yes.
20 Q Kow did you come to that knowle'dge?
21 A I think I must have come to that knowledge 22 either during or slightly after the TMI-2 event.
23 Q was it a result of reading any
.r.
[a) 24 par'ticular documents or discussions with 25 individuals?. .
M
. ik
,. 't %
I
, Walters
(_- ,
2 A I don't believe I understood that it was
\\ ' 3 as a result of any specific documents. I am sure 4
at sometime during the course of the accident (t , 5 that I had discusssions with someone or -- and 6
the results came to that conclusion.
7 Q You say during the time of the 8
accident, you are talking about the TMI-2 9
accide' nt?
A Yes, sir. .
s ,
, Q Was it at that point in time that 12
_ ,_s you came to the realization that boiling in the
\_ 13 RCS was an indication of loss-of-coolant i
14 accident?
15 A Well, I really don't know what we mean by _
boiling in the core. In what context are we 17
, talking about, that phrase?
- 18
, Q As we have discussed it here earlier 19 this morning, as used in Mr. Kelly's memo, I
" 20 think we were talking about it in terms of 21 saturation in the RCS, boiling in the RCS.
j,, +1 MR. KOLB: (Indicating)
L 23 TEE WITNESS: Yes.
i%
24
. (J l A Again, I don't remember any specific or 25 general conclusions on my part, at least I don't s
y 6-- ,, , .w - ---,- .-- ,,,_-. .,- , ,. -- - ,
. -. .- .- . . . - - - . - - - - - . _ . -. . - = .
Walters 248
). 2 remember from reading Mr. Kelly's memo these 3 particular words here.
4 In Mr. Kelly's memo opposite the Q
(- 5 prescriptions there is a handwritten note. It t 6 says, "All hydro-systems."
7 whose writing is that?
8 A I am not certain whose writing that is.
j 9 Is it the writing of Herb Smith, do you Q
I believe? E 11 A I don't believe so.
12 -
Q Do you have any idea who wrote that 13 note? .
14 A. Yes, I think I do.
15 Q who would that be?
16 A Well, I can't say with all certainty, but
- 17 I believe it's mine. -
18 Q It looks like your handwriting?
19 A From this reproduction I really can't tell.
20 But you believe that you wrote the Q
21 phrase, "All' hydro-systems"?
22 A very possible.
23 Q Did you mean by that that you felt O 24
( ,/ Mr. Kelly's prescription could take the plant 25 solid?
4
--. _.. - _ _ - . . . _ . , _ . _ _ , . . _ . _ . . , . . _ . _ . . _ . _ . . ~ , . . , _ - . _ _ _ . . .
r-1 Walters 249 O 2 A I think I drew the conclusion that if I 3 relied upon his prescription here that in certain 4 instances the plant could -- the plant could
( 5 be taken to a solid condition, yes.
6 Q Do you have any recollection of why 7 you placed an exclamation point after the phrase, 8 "All hydro-systems"? ,
9 MR. KOLB: You are assuming it is his 10 writing. t II I think he testified MR. MacDONALD:
12 to the best of his belief it is his writing.
O 13 MR. KOLB: He has been.very explicit 14 as to the state of his belief; and I 15 don't think that, given the care with 16 which he has testified about that that 17 you ought to just lightly assume it is 18 his writing.
'19 MR. MacDONALD: Well, I think that 20 most individuals know their own writing, 21 and if he believes it is --
22 MR. KOLB: He can't say that with 23 certainty. I don't know why you are trying 24 O) g . to change his testimony.
25 MR. MacDONALD: I am not. Most people i
____._____.__________.-___________________.__-_d
1 Walters 250 2 when they write something trill be able to 3 look at it and understand who wrote it.
4 I was very surprised that it took three
( 5 questions to get to the fact that he indeed 6
was the author of that little note.
7 MR. KOLB: He has not testified that O
, he was. .
9 MR. SELTZER: I thoguht he said he 10 believed he wrote it. That sounds pretty 11 good to me.
12 MR. KOLB: He testified that the 13 reproduction is difficult to. read, and he 14 has difficulty giving testimony with 15 certainty that that is his writing. Now 16 we get a question that as s ume s it.
17 MR. MacDONALD: To the best of his O
recollection.
19 MR. KOLB: That is not appropriate.
20 MR. MacDONALD: I think to the best 21 of his recollection he already said it is 22 his belief to the best of his recollection 23 that indeed it is his writing.
(' 24 If that is his testimony, then I am 25 perfectly willing to go ahead and ask him
.=. --. _ ._
1 Walters 251 s
b 2 what the exclamation point after that 3 phrase meant and why it was placed there.
4 BY MR. MacDONALD:
~l(. 5 Q Do you have an answer to that 6 question, Mr. Walters?
7 A I certainly do not recall why -- if I did 8 that, why I put that exclamation point there. ,
9 Q There are some handwritten notes at 10 the bottom of GPU Exhibit 131. t i 11 The first few words read, "Too many 12 and's." "And's" is underlined.
(~T ,
\- 13 Do you know who wrote those words?
14 A Yes.
15 Q Who was that?
16 A Mr. Herb Smith.
17 Q Did you give Mr. Smith a copy of 18 this memo to review at some point in time?
19 A Yes.
20 Q Did he review it in your presence?
21 A I don't recall.
22 Q Were these words written by Mr.
-23 Smith in your presence?
A.
(,_,) 24 A No.
25 .Q Did you discuss what Mr. Smith wrote
1 Walters 252
[v')
2 in the bottom of GPU Exhibit 131 in relation to the 3 words "Too many and's"?
4 A Yes.
l 5 Q What was the substance of that 6 conversation?
7 A Mr. Smith, after I assumed reviewing the 8 memo, came back to my desk at some point and .
9 handed me the memo with the -- with the subject 10 words on it (indicating). At leas.t this is a 11 part -- that is what I remember happening.
12 Q Do you remember anything else that O 13 was discussed at that point in time? Did you 14 ask him why he wrote those words at the bottom 13 of the page?
16 A I think I probably did.
17 Q Do you recall what he said?
18 A I don't recall the specifics.
19 Q What was the substance of what he said?
20 A well, it was concerning my previous comments 21 to him or my concerns about the prescription that 22 Mr. Kelly had supplied here and as he came back 23 over and gave me this copy, I read it and A
f y ,) 24 probably, as best I remember, agreed with him 25 that I thought.that was the case, too, my sentiments
1 Walters 253
. O 2 exactly that there were too niany "and's" in the 3 prescription as outlined in this memo (indicating).
4 Q So your concern with the prescription
( 5 was that it was difficult or would be diffiult 6 for operators to understand if it was sent out 7 in its present form?
8 MR. KoLB: You e.re saying your .
1 9 concern. Are you asking whether that is 10 his only concern, or a concern or --
11 MR. MacD0NALD: His concern.
12 A Y e-s , that was a concern of mine as to how 13 to pass along this information to the operators 14 if we deemed it necessary to do so.
15 g Under the phrase, "too many and's,"
16 there is another sentence that reads, "Suggest:
17 Pressurizer level is greater than pressurizer f
18 heater cutoff and R.C. pressure / temperature is 19 within the operating curve . ."
20 Then a signature; it looks like 21 " herb."
22 Was this suggestion written by 23 Mr. Herb Smith?
24 A I think that is a fair statement.
25 Q Did you di=cu~ss this suggestion that
, e- , . , .
- - - . - - ---y-..,,-r# , , - , ,- -- , . --.y ,w-
1 Walters 254
,~
2 Mr. Smith had made with him?
3 A I do not recall discussing that particular 4 sentence with him at this time.
( 5 Q Did he return to you the memo that 6 you had given to him?
7 A Yes.
8 Q Did it have these comments on the .
9 bottom of it?
10 A I think it would be fair to day that he did, 11 although I do not recall specifically those 12 particular words.
l ')
k/ 13 Q Did you ask him what he meant by the 14 comments?
15 A I don't recall that.
16 Q Did you ever have any discussions at 17 all with Mr. Smith regarding the comments he made 18 at the bottom of the page?
19 MR. KOLB: Just so we are clear, 20 are you including the "Too many and's" 21 comment?
L 22 MR. MacDONALD: I am not including that.
23 MR. KOLB: You are not including that; (A
s._/
) 24 is that what you said?
25 MR. MacDONALD: I am not including
1 Walters M
- _/ 2 \
that.
3 MR. KOLB: Not including "Too many 4 and's."
l( 5 A I must have, but I can't testify to that 6 as a fact I did.
7 Q You don't recall any such discussions 8 as you sit here today? ,
9 A I recall talking to Mr. Herb Smith about 10 the specific prescriptions as outlined in Mr.
4 ,
11 Kelly's memo.
12 I do not recall any substance other f-')s
\_ 13 than that particular conversation.
14 (Recess taken.)
4 15 Q Mr. Walters, Mr. Kelly had two 16 proposed guidelines, the firs t of which was ,
17 "Do not bypass or otherwise prevent ~ the actuation 18 of high/ low pressure injection under any 19 conditions except a normal, controlled plant 20 shutdown."
, 21 What did you understand that to mean 22- when you read that prescription in or about early 23 November-1977?
/~'N ' 24 A I think essentially.what the words say. I
, 25 don't recall any specific,.other than the meaning
. - ~ , .. -. . . _ . - . - . -
I t
i 1 Walters 256 O 2 of the words here.
3 Q Did you understand that Mr. Kelly was i
4 saying that you should not prevent the actuation 3
l 5 or the initiation of high or low pressure 6 injection except in the normal controlled plant 4
7 shutdown?
8 MR. KOLB: Would you please repeat the 4
9 question.
10 (Question read.) t 11 MR. KOLB Is there some implication 12 to the word " initiation" as opposed to the
('T .
13 word " actuation"?
14 MR. MacDONALD: No.
15 MR. KOLB: Do you mean them to be 16 synonymous?
17 MR. MacDONALD: We can hust use 18 " actuation" --
19 MR. KOLB: You are withdrawing the S
20 " initiation" from the question?
21 MR. MacDONALD: It is there.
22 MR. KOLB: I don't know whether you 23 mean --
- l. R
() 24 MR. MacDONALD: " Actuation" means 25 initiation of the high and low pressure 1
l
1 Walters 257
~
2 injection. I am just asking if he agrees 3 with what he understood Mr. Kelly to mean 4 when he read it in November of 1977.
A I think that is what I took the words to mean.
( 5 6 Q Did you believe at that point in time 7 that that part of the prescription would cause a 8 hydroing of the RCS?
9 A No, I be~.ieve I accepted that.
10 Q The second part of the grescription 11 l ab eled "b)" reads, "Once high/ low pressure 12 injection is initiated, do not stop it unless:
13 Tave is stable or decreasing and pressurizer level 14 is increasing and primary pressure is at least 15 1600 PSIG and increasing."
16 Is that the portion of the prescription 17 that Mr. Smith's comment, "Too many.and's," was 18 addressed to?
19 A Yes.
20 Q And that is a portion of the 21 prescription that you agreed with Mr. Smith 22 contained too many "and's"?
23 - A That is correct.
m-I 24 Q of those three phrases that are
. .J 25 connected by "and's" in that portion of the
1 Walters 258 O 2 prescription, which ones did you feel were not i
3 needed or could be eliminated if an "and" was 4 removed?
(' 5 MR. KOLB: I sill object to the 6 question. It contains an assumption as 7
to his belief which you haven't established, 8
and also it is two questions. -
9 MR. MacDONALD: Let's do it this way:
10 Q Did you believe all th$eeparts of this 11 this prescription were necessary?
12 A I don't believe I remember drawing a O 13 conclusion that they were necessary or were not 14 necessary.
15 Q Do you believe that in your agreement 16 with Mr. Smith that there were too many "and's" 17 in that particular portion of the pre'scription that 18 one or more of the sections of the prescription 19 were not needed or were not necessary to 20 accomplish the guidelines that.Mr. Kelly wanted 211-to send out?
22 A I don' t believe that I came to that 23 conclusion.
24 At the time you read this and Q
25 discussed it with Mr. Smith, which "and"-did you
1 Walters 259 4
/~'N V' 2 consider superfluous?
MR. KOLB: I will object as to form.
4 You are assuming a fact.
C 5 Q Which "and" did you consider was 6
too many of the three that are in there?
7 MR. KOLB: The same objcction.
8 A Well, my concern goes past the words. I -
9 didn't really reflect on just the word "and."
10 e Q To the extent that you and Mr. Smith 11 agreed that there were too many "and's" in this 12 gg portion of the prescription, which "and" did you 5-) 13 feel was too many or which was not needed?
14 MR. KOLB: Same objection as before.
15 You're assuming a fact.
16 A I don't recall coming to the conclusion 17
- that any of them were superfluous.
18
, Q What was wrong with the "and's,"
19 then, as they were stated in this portion "b)"
20 of the prescription of Mr. Kelly?
A Simply that I thought that it was a very
(
cumbersome sentence and that we should try to t
23 l find some better way of saying it in a more -
! - (C\
ss f 24 simple and logical format if we were to pass i
25 it along.
1 Walters 260
/9 2 Q So your objection was not to the 3 content of the prescription , but to the grammar?
4 MR. KOLB: Are you referring just to
( 5 the two many "and's" comment, or are you 6 now referring to his view of the situation 7 as a whole?
O MR. MacDONALD: His view of the .
9 situation as a whole.
10 MR. KOLB: Will you klease repeat 11 the question.
12 (Question read.)
b) 13 Q In regard to the "and's"?
14 MR. KOLB: Well, now, you have 15 indicated before I had the ques tion reread 16 that we were talking about this in general 17 and now you are -- am I correct you are 18 saying in fact the question is only-19 directed at the too many "and's" comment, and 20 and you're not asking him in general?
l.
21 MR. MacDONALD: That's correct.
! 22 MR. KOLB: Do you understand that, i
23 Mr. Walters?
p-m .
(w. 24 Q Your objection --
( 25 THE WITNESS: No.
l p -
w - w w s,w- w
l' 1 Walters 261 2 Q -- in regard to the too many "and's" l
3 was not to the content of the pres cription, but 4 to the grammar that was used?
5 MR. KOLB: Would you tell us what l(
6 you mean by " grammar" in your ques tion?
7 Do you mean grammar in the. sense of the i
8 s choolboy 's grammar book, or -- -
i l-9 MR. Mac DONALD: The usage of the 10 "and's" in the context of the ,
English i 11 sentence.
i 12 A Yes, I objected to it, and in the context f%
0 13 that the -- I did not like, if I was to have to 14 do so, to pass this particular wording along.
15 I thought it was very cumbe rsome.
16 Q Did you speak to anyone regarding your 17 ideas on the "and's" in this particular part of 18 the prescription?
19 A Yes, I believe I did.
20 Q Aside from Mr. Smith, with whom?
21 A No, I think he was the only one.
22 Q Well, you didn't talk to Mr. Hallman
. 23 or Mr. Kelly or anyone else regarding your
[l s
) 24 beliefs on the too many "and's" in the second 25 part of Kelly's prescription?
. . - . . ~ , ,, . , , .. , , . . . . . - = - . - - . , , . - - - .
1 Walters l /' 'g 2 A I don' t believe I talked to either one of 3 those gentlemen on those subj ects . At least, I
,4 do not recall doing that.
( 5 Q Prior to the time of the TMI 6 accident did you speak to anyone regarding the 7 problem of Mr. Kelley's prescription and the way 8 it was worded in terms of the usage of the ,
9 "and's" grammatically?
10 MR. KOLB: Will you read the 11 question back, please.
12 (Question read.)
13 MR. KOLB: Are you asking whether 14 he spoke to anyone other than Mr. Smith?
15- MR. MacDONALD: That's correct.
16 A I don't believe I did.
17 Did you attempt to reformulate that Q
18 prescription yourself to make it read'in a 19 manner which you thought would be better 20 understood and in a less cumbersome manner?
21 A I don't recall doing so.
22 Q Did you have any other questions 23 which arose out of that item "b)" of Mr. Kelly's
() 24 prescription which you discussed with any 25 - individuals at B&W prior to the TMI-2 ' accident?
1 Walters 263 2 A Yes, I believe I did.
3 g And was that in relation to the 4 comment that you believe you wrote in the l 5 lef t-hand column of GPU Exhibit 131 regarding 6 all hydro systems?
7 MR. KOLB: I object as to form.
8 A I believe it was in that context. ,
9 Q Will you explain how Mr. Kelly's 10 prescription in item "b) " in your mind as you ,
11 read this in November of 1977 could have led to 12 hydroing the system?
t
\/ 13 A What I remember is that when I read Mr.
14 Kelley's prescription, that it occurred to me 15 that if we relied upon this prescription across 16 the board that it was possible I thought in other 17 transients, that meaning different 'than a LOCA, 18 that we could wind up if using this prescription 19 literally wind up in going and having a solid 20 water system in that he says, "Do not stop the 21 HPI injection unless."
22 I questioned whether or not there
~
23 was sufficient thought that had been given to
- (q) ~j 24 --
indeed, would this not -- indeed, would this 25 cause unnecessary LOCA's if we followed this
1 Walters 264 d 2 pres cription.
3 Q What other transients are you 4 referring to other than the LOCA that you were
( 5 thinking about at the time?
6 A I was mainly thinking along the lines of 7 overcooling transient or overcooling of the RCS.
8 And how could that lead, in your
. Q ,
9 view, to hydroing of the system with the 10 prescriptions that Mr. Kelly set forth in his 11 November 1st, 1977 memo?
12 A Well, I was unsure whether or not that we C) 13 were giving additional instruction to leave the 14 HPI running to prevent from going to a solid 15 system in the case of a non-LOCA situation, we 16 would also need instructions to say when to 17 terminate the EPI system to preventi going to a 18 solid, solid conditior.s in the RCS.
19 MR. MacDONALD: Will you read that t .
-20 back, please, Charlie.
21 (Record re ad. )
22 Q Doesn't Mr. Kelly have in.his 23 prescription "b)" a wording that allows for
[
24 stopping of HPI under the conditions that he
- ~
25 sets forth? '
l_
i 1 Walters 265 2
A Yes, he says that under those conditions 3 you could stop the -- or I infer from that you 4 can stop the HPI system.
5 And you didn't believe at that point
{ Q 6 in time in November of 1977 that that would bc 7 sufficient in a non-LoCA overcooling transient 0 to lead to termination of HPI before the system 9 went solid?
10 A Yes, I think I was very unsure as to t 11 whether or not those conditions would indeed i 12 prevent that from happening under those I A
- 13 circumstances.
14 Q Is there a difference in your mind 15 between hydroing and a system that is solid a .
16 with water?
17 A No, I use a solid water system and 18 hydroing synonymously.
~ '
19 Q What part of Kelly's prescription do 20 you believe would enable or perhaps pe rmit a 21 plant to go solid'in a non-LoCA or in an 22 overcooling transient situation?
23 MR. KoLB: Objection as to form.
l m 24- The question assumes it is a single J
L 25 part of it that does that, i
,,, , t . , , - , , c_,,,_ , . . .- , _ . . - ~ . , - . . . - _ . , . . . - , . , , - . , - . - , . , .
. _ - -. -- .. - . - - . _ _ - . - - . . - _ _ _-. - _=
1 Walters 266 2 A I don't believe I drew a conclusion as to 3 any specific one would indeed result in that 4
4 happening.
( 5 Q Kow would the operators take the 6 system solid if they followed Kelly's 7 prescription?
8 A I don't believe I reflected on how it would 9 9 happen. It was -- I was reflecting on could it 10 happen by following these instructions. ,
11 Q What were your thoughts on how it
- 12 could happen if these instructions were followed?
O
\- 13 A I don't believe I recall making this 14 particular judgment *along this line.
15 Q You didn't do any analysis or 16 evaluations of how Mr. Kelly's prescription might 17 enable operators to take the system s.olid in or 18 -about November of 19777 l
19 A well, I am sure I did no analysis, if you 20 mean by running codes or in that nature. Other 21 than that, I don't recall any specific evaluation 22 at this time.
23 Q Why did you think the prescription l
[
l f)
%d 24 would lead then to an operator possibly taking the 25 system solid?
1 Walters 267 '
's I
+ - \-
2 A I think mainly because I did not think at 3 that time to distinguish between the LOCA and 4 an overcooling transient in sufficient time to
( 5 prevent if literally following this prescription 6 that in the case of an overcooling event, we 7 would go solid.
8 Q Well, in-the case of an overcooling 4
9 event, how literally, if these prescriptions 10 were followed, would an operator take a plant 11 solid?
12 A I don' t believe I --
I don't remember
{~T s-) 13 making any evaluation of that at that time.
14 Q Did you look at Smith's suggestion 15 on the bottom of the page and evaluate or think 16 of it in terms of the prescription that might be 17 recommended to operators. .
18 MR. KOLB: Are you referring to the 19 one below --
20 MR. MacDONALD: The one that 21 starts with "Suggest," yes.
22 Q In relation to guidelines to be 23 suggested to operators at utility plants?
/~T 24 A I don't recall.
O 25 Q- You don't recall looking at it in
1 268 Walters 2 terms of whether that might cause a system to 3 hydro in an overcooling or non-LOCA situation?
4 A Yes, I don't recall reflecting on that
(' 5 in either way, that it would or it wouldn't.
6 Q Will you explain what would happen 7 to the key parameters of the reactor coolant 8 system during an overcooling transient if 9 Kelly's HPI instructions --
if the HPI is open 10 consistent with Kelly's instructioss?
11 , MR. KOLB: You mean, was open?
12 MR. MacDONALD: Yes.
O 13 THE WITNESS: Will you read that 14 back, please??
15 MR. MacDONALD: I will restate it.
16 Q Will you explain what would be 17 happening to the key parameters of the reactor 18 coolant system during an overcooling transient 19 if HPI's initiated consistent with Kelly's 20 prescription in his November 1st, 1977 memo
! 21 was open?
22 A In an' overcooling transient within the i
23 , first few minutes of the transient, both
/~
24
( 5-). pressurized -- both RCS pressure and RCS 25 temperature would be trending in a downward 4
t wg, y . -._r s - .m- r -m t 7 " e -'r m -----t - - - - - - - -v v - - - "
1 Walters 269
/~
V} 2 direction. The pressurizer level would be 3 also trending in a downward direction for some 4 period of time. Of course, it would depend
( 5 on the circumstances as to how long this would 6 continue to happen.
7 During the whole period of time 8 that the HPI system was on, we are injecting 9 unnecessary water in the case of an overcooling 10 transient that I thought in the case of an 11 ove rcooling transient under certain scenarios 12 would wind up with the system coming into a 13 solid condition at some later point.
14 Q If HPI was left on, what would then 15 happen to the key parameters in this overcooling 16 -transient?
17 A My previous answer was the answer to that 18 question, with the HPI system left o n'. -
19 Q During the ove rcooling tra'nsient are 20 you saying that when the HPI is left on, that 21 the pressurizer level will continue to decrease 22 as well as pressure and temperature?
23 A. Some small amount of time, two to five
(- 24 minutes, some initial period of time.
Q After that what will happen to 25
i
)
1 Walters 270
(~h l Q.
2 those key parameters?
3 A Well, depending on the scenario, how 4 severe the overcooling transient is, at some
( 5 period of time we are talking about the time as 6 a factor, then the pressurizer level, RCS 7 pressure and temperature would then turn around 8 and begin to start --
start an increasing trend.
9 Q so that all three parameters that 10 you mentioned will then at a point in time two 11 to five minutes begin to increase if HPI is
,_ 12 left on?
13 A Well, it depends on the scenario or how 14 severe the overcooling transient is.
15 What would happen under the most Q
16 severe overcooling transient you have in mind 17 in regards to the key parameters if the HPI is 18 left on?
19 A I think mainly what I have already said 20 will happen, it will.just be displaced in time 21
[L be fore the three parameters begin to increase 22 from a small or mini overcooling transient.
23 Q How quickly would the three
/~'T
-(,) 24- parameters begin to recover in the severest -
25 overcooling transient?
__ . . . ~ . , , _ , . _ . - , _ _ _
1 Walters 271 m
)
2 A I have nothing really to base that on.
3 Q You didn't have anything to base that 4 on in November of 1977, either?
( 5 A Nothing specific.
6 Q Mr. Walters, how long would it take 7 to hydro the RCS under the worst case, under 8 an overcooling transient?
9 A I don' t have -- I don't believe I have a 10 specific answer to that question. t 11 Q Do you have an approximation?
12 A Not real'ly.
2 -
s
' 13 Isn' t it true that in a non-LOCA Q
14 situation where there is no hole in the reactor 15 coolant system, that HPI is left on the pressure 16 and pressurizer level will come up to such a 17 point or under Mr. Kelly's prescription HPI 18 can be terminated before the system goes solid.
~
19 MR. KOLB: Is your question whether 20 he can answer that now, today or whether 21 he had an opinion on that at the time?
22 MR. MacDONALD: Let's start with 23 an opinion at the time.
/~
24 A Well, I don't recall having reflected
( )N 25 upon th at at the. time.
1 Walters 272
. ,}
N) 2 Can you reflect upon it in light of Q
3 Mr. Kelly 's pres cription and tell us whether or 4 not that is possible?
( 5 MR. KOLB: Are you now asking him 6 for his present opinion? ,
7 MR. MacDONALD: At any point in 8 time before today did he think of this 9 situation, talk to anyone, discuss it 10 with anyone, evaluate it to understand 11 whether in fact you actually could hydro 12 the system and go solid under Mr. Kelly's f~
k- 13 prescription.
14 A Yes, I think I did.
15 g Will you tell us how that would 16 occur?
17 A I am referring to my memo to Mr. Kelly 18 around the first week of November.
19 Q 1977?
20 A Yes.
21 Q Did you explain to Mr. Kelly in that-22 memo how the RCS could go solid under Mr. Kelly's 23 - prescription as Mr. Kelly set it-forth in his r~%j_ November 1st, 1977 memo, GPU Exhibit 131?
l -( 24 25 MR. KOLB: Could we have the memo, i
l' ~
4
, 1 Walters 273 2 so he can look at it?
3 MR. MacDONALD: Mr. Walters' memo?
4 MR. KOLB Yes.
( 5 MR. MacDONALD: Sure.
6 I would like to mark as GPU Ex'hibit 7 132 a memorandum from J. R. Walters to J. J.
8 Kelly dated 11/10/77.
9 (Two-pagc longhand memorandum dated i
10 11/10/77 from J. F. Walte rs to J.*J. Kelly, !
11 subject: High Pressure Injection during ,
12 Transient, was marked GPU Exhibit 132 for O ,
.',a.
1 13 identification, as of this date.) >
r 14 THE WITNESS: Would you read back #
4 15 the last question, please? '
16 (Question read. ) '
17 A I don' t believe I mentioned it in the same '
s, 18 terminology that he did in his memo. s y\(~
19 Q Where in your memo did yon explain f
20 to Mr. Kelly that, using his prescription, you i
21- could take the system solid? ,
, 22 A My thoughts on that particular subject are.
23 in the third paragraph of Page 1 and the b '
! s (m ).
l v-24 continuing paragraph- on Page 2.
25- Q could you. read the portions of your . g.
f
1 Walters 274
.p y .
2 memo into the record that you believe dealt with 3 that concern?
4 A "In the particular case at Toledo there was
( 5 no LOCA of magnitude and with the small leak the 6 inventory in the system came back as expected, 7 but due to the cooling of the RCS the RCS 8 pressure cannot respond any quicker than the 9 pressurizer heaters can heat the cold water now ,,
10 pushed back into the pressurizer, leaving the 11 HPI system on af ter pressurizer level indicator 1
12 is losted high, will result in the RCS pressure
[h
\> 13 increasing and essentially hydroing the RCS when 14 it becomes solid. If this is the intent of 15 your letter and the thoughts behind it, then the i 16 operators are not taught to hydro the RCS every 17 ting the HPI pumps are initiated." .
18 Q In the portion of the paragraph you 19 3;Ac read, isn't it a fact that when the water 20 in a non-LOCA is pushed back in the pressurizer 21 that the RCS pressure will rise as does the level?
22 MR. KbtB: As does the level of 23 what?
(A) x-24 MR. MacDONALD: The pressurizer 25 level.
- 5
' A.
. ~ , , - , ._ __- ,_, ., , _ _ . - - -. .,4-.. . _ . . .
9 1 Walters 275
. 2 A I don't think I have it in my hands right 3 now, information based on the particular scenario 4 that that will or won' t happen.
( 5 Q Well, when there is no hole in the 6 reactor coolant system and the pressurizer level 7 is increasing, the level is rising within the 8 pressurizer, will not that result in an 9 increase in RC system pressure?
10 A Yes, it will. ',
11 Q And isn' t it a fact that before the 12 bubble is pushed back into the pressurizer and
(~N g ,
s 13 is compressed, the RC system pressure will have 14 had to have risen above 1600 psig?
15 MR. KOLB: I will object as to 16 form because I think you misspoke in the 17 middle of the question. -
18 I would ask that it be repeated.
19 You might see it yourself if you hear 20 it back.
21 MR. MacDONALD: All right.
L-22 (Question read.)
23 MR. MacDONALD: I will withdraw the
(~m
). 24 question. l v
i 25 Q Isn' t it a f act that before the
-l
- j . _
1 Walters 276 i
V 2 bubble in the pressurizer becomes compressed, the 3 RCS pressure will have to have risen above 1600 4 psi if there is no break in the RCS system?
( 5 A I don't believe I can be certain about 6 that at this time.
7 Q And why can't you be certain about 8 that? .
9 A It's not clear in my mind without some 10 reference to some specific documendation whether
\
11 or not the pressure in the system will rise above 12 1600 pounds. As you said before, the pressurizer 13 level is lost high due to the cooling of the 14 system fluid by the cold HPI injection flow.
15 MR. KOLB: Off the record.
16 (Discussion off the record.)
17 (Recess taken.)
- 18 BY MR. MacDONALD:
19 Q- Mr. Walters, where is the HPI, at what 20 point is the HPI injected into the RCS, what l
21 location?
22 A At what physica1' location is it injected i=
23 into the RCS?: It is injected into the four
() 24 cold legs of the_ reactor coolant system.
'25 Q And the water that goes into the
I walters 277 p's 2 pressurizer is from the hot leg?
3 A From the hot leg, yes.
4 Q Isn' t it a fact that in order to
( 5 compress the bubble in the precsurizer, that 6 RCS system pressure must rise in order to do that.
7 MR. KOLB: Would you read the question 8 back, please? .
9 (Question read.)
10 MR. KOLB: Unde r what t ,circums tances ;
11 just at any time or --
12 MR. MacDONALD: In the circumstances O
13 of an overcooling transient.
14 A I believe generally speaking, and-I can't 15 speak for all specific cases here now, but I 16 be lieve generally speaking that the RC pressure 17 does rise as the pressurize r level also rises.
18 Q So that in an overcooling transient, 19 in order to comp res s the bubble in the pressurizer 20 Lt.e RC system pressure must rise?
21 A Yes, into the transient, the RC pressure 22 will rise in an overcooling transient.
23 Q So that is the only way you get an
-( ) 24 increase in the pressurizer water level by the 25 rise in the RCS system pressure during an
1 Walters 278 2 overcooling transient?
3 A No, I don' t believe so. Again, I can't 4 address to it in all cases.
( 5 Q Before the bubble is compressed in the 6 pressurizer during an overcooling transient, you 7 must have rising RCS system pressures is that 8 correct? .
9 A Well, I can't address all cases. I would 10 believe that it would be possible due to the 11 overcooling of the system by the HPI injection 12 fluid for the pressurizer level to irse and at O
\ /
13 what rate the pressure is rising I can't speak, 14 just how long it is going to take to get to a 15 certain value.
16 Q Before the pressurizer fully 17 compresses, before the water in the pressurizer 18 fully compresses the steam space, isn't it a 19 fact that RC. system pressure in an overcooling 20 transient will have to be rising?
21 Q- I believe that generally speaking, that in 22' the case of an overcooling transient,that the 23 pressure will be rising before you compress
, ("j\ 24 completely the steam bubble in the pressurizer.
25 Q Did you know th at' in No ve mb e r o f
l l
l J
1 Walte rs 279
,~ -
2 19777 3 A I d n' t recall ever addressing that i
4 particular issue in that context in 1977.
( 5 g You never spoke to anybody about 6 that issue around November of 19777 7 A I don't recall any specific conversation 8 with anybody around that time about that .
9 specific subj ect.
10 Q Did you write any memos or do any 11 evaluations of that particular subject around the 12 time of the Kelly memo or your memo to Mr. Kelly 10 k/ 13 in November of 19777 14 A No, only my memo to Mr. Kelly addressing 15 my general thoughts or my response to his memo.
16 Q Did you speak to anybody else in 17 the Engineering Department?
18 MR. KOLB: On that subject?
~
19 MR. MacDONALD: Yes.
l 20 A I don't recall at this time in doing so.
i 21 Q Did you speak to anybody else within i k.
22 B&W on the subject at this point in time?
23 A- we are talking about in respect of this i ew 24 specific conversation-here on what pressurizer (u)'
25 level pressure will do?
1 Walters 280 2 Q Yes.
3 A I don't recall speaking to anybody else on 4 the context of that specific discussion.
(' 5 Q Are there any facts that you know 6 today that would lead you to the conclusion that 7 in November of 1977 you didn't know that an ,
8 increase in RC system pressure would occur 9 before the pressurizer water level went solid?
10 MR. KOLB: Would you. read that 11 question back, please?
12 r~g (Question read.)
b 13 THE WITNESS: Very. slowly.
14 (Question reread.)
15 MR. KOIB: That question is much too 16 confusing and also you are really asking 17 the witness to sift evidence and reach 18 conclusions for you which'is inappropriate;
)
/ -
19 so I object to it.
20 MR.'MacDONALD: I will withdraw that 21 question and try another one.
22 Q Are'there any facts that you know 23 today that you didn' t know in November of 1977 O
k.)
m 24 that would lead you to the conclusion that RC 1
25 system pressure will be rising before the steam '
1 Walters 281
.tp) .
%/
2 bubble in the pressurizer is fully compressed 4
3 in an overcooling transient?
4 MR. KOLB: Let me hear that again,
( 5 please.
6 (Question read. )
7 MR. KOLB: I think the question is 8 confus'ing. I don't unde rs tand the 9 reference to today versus the past.
10 The questions you had dsked, I 11 thought, previous to this, were for the 12 most part keyed to the opinions that he (A\'). 13 had expressed in his memo and that you 14 were questioning him about what the 15 conditions were as to overcooling events l
16 and so forth, because he had expressed 17 himself on that subject. -
18 To compare today to the p st, I i .19 think, is inappropriate because we don't 20 want to be having the witness sit here and 21 providing expert testimony for you. He 22 is not your expert.
i
, - 23 So I would ask you to put the r
[/
x_
) 24 questions in terms of the past, and the facts l
i 25 he knows and he either knows or he doesn't
1 waiters 282
. O
&J 2 know particular things.
3 MR. MacDONALD: The question 4 essentially.is, what did you learn, what
( 5 facts have you learned since November of 6
1977 prior to today that leads you to the 7 conclusion that you stated earlier that 0
RC system pressure will rise before the 9 steam space in the pressurizer will be 10 fully compressed in an over$coling 11 transient.
1 MR. KOLB: There is no basis 13 4
whatsoever as far as I know in the testimony 14 to suggest anything about facts he's 15 learned since the events that have 16 caused him to reach conclusions today.
17 You haven't got any predicate for that at 18 ,11, 19 MR. MacDONALD: I think he has 20 testified --
21 MR. KOLB: You are just assuming 22 there were some differences.
23 MR. MacDONALD: That's correct.
D. 24
(,) I think he has tes'tified that he did not 25 have that conclusion back in November of
'l
1' Walters 283 2 1977, and yet he has discussed that 3 conclusien just previously in his 4 testimony, and I am attempting to 5 elicit what facts he has developed since 6 November of 1977 that led him to that 7 conclusion.
8 MR. KOLB: I think the problem is 9 that when you put the question as to his 10 state of mind back at the tide you did it in 11 the context of the memo and the various 12 other events directly that we are talking 13 about. Now you are jumping to a i
14 conclusion and this is getting to be 15 somewhat confusing just because of the 16 way the questions and answers are being 17 put and because of the difficulties of 18 recollection. I don't think we should
- 19 make it more confusing by assuming facts 20 which you haven't established.
21 MR. MacDONALD: Let's back up a
{
22 little and try and break it down into 23 three smaller sections and do it again
( 24 so we can get this clear.
25 MR. KOLB: 0.K.
i 1 Walters 284 O
O 2 BY MR. MacDONALD:
3 Q I believe you have testified, and 4 correct me if I am wrong, that you recognized that
(. 5 in an overcooling transient pressure must be 6 rising in order to compress pressurizer -- the 7 bubble in the pressurizer; is that correct?
8 MR. KOLB: I would ask that the
, 9 question be put as to whether the facts 10 are correct, not as to whether he
~11 previously testified to that.
12 Is that a correct statement?
Q i
n'
'- 13 MR. KOLB: Do you have the question 14 in mind?
15- THE WITNESS: Yes, I think so.
16 MR. KOLB: 0.K.
17 MR. MacDONALD: Off the record.
18
. (Discussion off the recor .)
19 BY MR. MacDONALD:
20 Q I believe you testified that you I
- i. 1 21 did not know that in November of 1977.
22 MR. KOLB: You s ee, I think you are 23 mischaracterizing the testimony.
{f 24 Q Did you know that in 1977, November 25 of 1977,without characterizing.it?
_ , . . _ - _ . _ . - . . _ ~.. _ _ _ _ -. _ . ,, -
1 Walters 285 2 A I thought I had earlier testified that 3 I don't believe I reflected on it in either
.4 capacity.
-- 5 MR. KOLB: That is a dif ferent point.
6 Are there any facts which lead you Q
7 to your understanding at this point in time 8 regarding the rise in RC system pressure in an -
9 overcooling transient leading to compression of 10 the bubble that you didn't know in 19777 11' A I don't believe there is any facts today, 12 at least that I can recollect, that I didn't --
0 13 that I didn't reflect upon at the time in '77.
14 MR. MacDONALD: Will you please 15 repeat tite last answer? ,
16 (Record read.)
17 MR. KOLB: Off the record.
18 (Discussion off the record.)
19 MR. KOLB: Do you'want to go ahead 20 and clarify what you have just said?
.21
{ MR. MacDONALD: Why don't we have the 22 question repeated and let him give an 23 answer?
24 CRecord read. )
25 MR. KOLB: Please repeat the answer.
1 Walters 286 I%J 2
(Record read.)
3 BY MR. MacDONALD:
4 So, in other words -- I'm sorry, you Q
(. 5 wanted to say something.
6 MR. KOLB: Mr. Walters is still 7 pondering the answer. I think if he 8
wan ts to clarify it, he should have the -
9 opportunity to do so.
10 A As far as my response on ref$ecting upon 11 it, I don't think I reflected that in 1977, 12 that I ever reflected upon facts that I have 13 additional information today because I don't t
14 recall in '77 or at least at this time that I 15 addressed to this particular in any great detail.
16 Q In other words, the facts that you 17 have today regarding this subject matter are the 18 same facts that you possessed back in November
-9 19 of 19777 20 A I don't recall that they ch ange d .
. 21 Q I think that helps clarify it
\m .
22 somewhat.
23 MR. KOLB: I am going to sugges t
(.- .
24 that we stop. I think that the witness 25 observed during the break that he was l
l
. , , , _ . . _ . . ._ _ _.. ___ -U
s
, 1 Walters 287 ,
b V ' ..
2 getting tired and I think that is clear;
!- i and I think it is a good time to break.
3 I
4 It is about 10 after 4:00, anyway.
( 5 MR. MacDONALD: That is fine with 6 me. I don't want to push the witness.
7 We are at a logical breaking point.
8 MR. KOLB: Fine. ,
9 (Time noted: 4:10 o ' clock p.m. )
10 1
11 f
12 James Franklin Walters
- !' O 13 14 ' Subscribed and sworn to before me 1
15 this day of 1981.
16 t -17 Notary Public .
18 19-20 21 f.
l L.
22 j 23 i -
24 i
i 25 L-
1 l
i l
l 1 288 A
V CERTIFICATE f -STATE OF NEW YORK )
-; 3 : ss.:
- COUNTY OF NEW YORK )
4 CHARLES S H API RO , C.S.R. a Notary 7, ,
i {(- 5 Public of the State of New York, do hereby certify that the continued deposition of JAMES FRANKLIN WALTERS Was taken before 8 ,
4 me on Tuesday, April 14, 1981, consisting 287 of paSes 164 through ;
I further certify that the witness had been previously sworn and that the within 7
,,/ transcript is a true record of said testimony; 13 That I am not connected by blood or marriage with any of the said parties nor -
n We r.aher 16 in controversy, nor am I in the employ of any 18 IN WITNESS WHEREOF, I have hereunto set my 19 hand this N(11day of ' MRI L' , 1981.
20 21 22 n ,
j 23 q
q charles Shapiro U 24 l' 25 l -
I
, , .-- - . , . _ - . . - , . _ . __,...m-., , _ . . _ _ . - - . _ _ . , - - .. . ,. _- .. .- ,
289 I N DE X i s
i
5', WITNESS PAGE I {.,
, , - ! JAMES FRANKLIN WALTERS , Resumed 165 w
l f
'N '
E XH I B I TS i: ,
GPU FOR -
T
- t. IDENTIFICATION d
i '
129 Memorandum from D. F. H all,m an to E. R. Kane, s ub j e ct : LER Review 166 130 Memorandum dated October 10, 1979 from J. F. Walters td Plant Performance Services Personnel, subject: Quick .'
Look Reports 172 1
131 Memorandum dated November 1, 1977 from J. J. Kelly to
, Distribution, subject:
Customer Guidance On High Pressure Injection Operation 222 t ..
132 Two-page longhand memorandum dated 11/10/77-from J. F.
Walters to J. J. Kelly, I
subject: High Pressure Injection during Transient
(('.
~~
273 I
, u . -
, 3: .
- "
- : :;;&iW >
8 L <: d
- . , . . . . . . . _ . - - . . , . . ..-.-....~. - , . . . . . . - . ~ . . - . - . , '. - . - - - -.--,.-.