ML20072H976
| ML20072H976 | |
| Person / Time | |
|---|---|
| Site: | Three Mile Island  |
| Issue date: | 06/28/1982 |
| From: | Pittman R BABCOCK & WILCOX CO. |
| To: | |
| References | |
| TASK-*, TASK-03, TASK-06, TASK-07, TASK-11, TASK-3, TASK-6, TASK-7, TASK-GB NUDOCS 8306290846 | |
| Download: ML20072H976 (142) | |
Text
{{#Wiki_filter:bt UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK , _x j GENERAL PUBLIC UTILITIES CORPORATION, j -. JERSEY CENTRAL POWER & LIGHT COMPANY,
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I MET ROPOLIT AN EDISON COMP ANY and : h / PENNSYLVANIA ELECTRIC COMPANY, Plaintiffs,
-against- 80 Civ. 1683
- (R.O.)
THE BABCOCK & WILCOX COMPANY and J. RAY McDERMOTT & CO., INC., : Defendants. : (
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- l Deposition of the defendant, The Babcock &
O "Wilcox Company, by ROGER L. PITTMAN, taken by Plaintiff, pursuant to agreement, at the offices of Kaye,Scholer, Fierman, hays & . Handler, Esqs., 425 Park Avenue, New York, , i New York, on Monday, June 28, 1982,'at 9:45 o' clock in the forenoon, before Nancy A. Rudolph, a Shorthand Reporter and Notary Public within and for the State of New York. 8306290846 820628 PDR ADOCK 05 COO 289 T PDR t DOYLE REPORTING. INC. CERTIFIED STENOTYPE REPORTERS 369 Lex!NGTON AvrNUr WALTER SHAPIRO, C.S.R. New Yong. N.Y. 10017 CHARLES SHAPIRO, C.S.R-TELapHow s 212 - 867 822o i
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i 2 N-
- 2 Appe arance s
i 3 KAYE, SCHOLER, FIERMAN, HAYS & HANDLER, ESQS. Attorneys for Plaintiffs 4 425 Park Avenue New York, New York (' 5 By: RICHARD C. SELTZER, ESQ., / 6 of Counsel 7 8 DAVIS POLK & WARDWELL, ESQS. Attorneys for Defendants 9 One Chase Manhattan Plaza ' New York, New York 10 ', By: RODMAN W. BENEDICT, ESQ., 11 of Counsel 12 Also Present: DAVID TkYLOR (Morning Session Only) 14 15 * *
- 16 17 IT IS HEREBY STIPULATED AND AGREED by i
18 and between the attorneys for the respective 19 parties hereto that the sealing, filing and i 20 certification of the within deposition be, l 21 and the same hereby are, waived; and that the 7 l A 22 transcript may be signed before any Notary 23 Public with the same fo rce and e f fect as if () 24 signed before the Court. 25 IT IS FURTHER' STIPULATED AND AGREED l i
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1 3 2 that all objections, except as'to the form of 3 the question, are reserved to the time of trial. 4 ( 5 6 (Four-page document, first of which is 7 a memorandum to B. A. Karrasch from D. F. Hallman, O subject: " Operator Interruption of High 9 Pressure Injection (HP I ) " dated August 3, 10 1978 marked GPU Exhibit No. 571 fo's 11 identification as of this date.)
- 19~
RO G E R L. P IT T MA N, having been f-(s. 13 first duly sworn by the Notary Public, was ' l I4 ' examined and testified as follows: 15 EXAMINATION BY MR. SELTZER: , } 16 Q State your name and address fo the record, 17 please. - 18 A Roger L. Pittman, Route 1, Box 150, 10 Lowry, Virginia 24570. 20 Q Mr. Pittman, take a look at what we have 21 just marked as GPU 571. It's a copy of Bert Dunn's ( 22 February 9 and February 16, 1978 memoranda which were 3 previously marked as GPU Exhibits 78 and 79 and Don o4 (A) ~ Hallman's memo of August 3, 1978 which has p re viously 25 been marked as GPU 80. i s va.. , - - - , . . . - - .
i 1 Pittman 4
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\~#' 2 Before we started, your counsel 3 indicated that you would be able to help us decipher 4 the handwritten notes that appear on the pages of
( 5 GPU 571. 6 Could you do that , . ple ase , starting 7 with the first page? 8 A Starting here with the Hallman to 9 Karrasch meno, is that where you want me to start? 10 g Yes. t 11 A That comment is a note from Bill. Street 12 to myself after I had asked Bill Street what the 13 status of these memos was. I cannot be 00 percent I4 certain, but I believe that stated "Here's'the 15 latest. Please return." 16 Q Is there anything written immediately 17 to the right of the word " return"? . 18 A I don't know. 19 Q Have'you asked Billy Street whether he 20 still has a copy of this?, 21 A I believe the copies that I had after the 22 Three Mile Island accident were sent.to me by Bill 23 Street, so whether Bill Street still has copies or not, 24 I don't know. 25 Q' Have you'done anything to P.ry and find
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i Pittman 5 f\
.x,,/ 2 a copy of this that doesn't have the words at the top i 1
3 cut off? 4 A The only thing that I have done was 5 following the Three Mile Island accident, these memos g 6 began to surface, the interest in them began to 7 surface, an d I asked Bill Street. I don't know if 8 I called Bill Street or whether I saw him in the 9 office or what, if he recalled the status of these 10 or if he had copies and Bill sent me what he had t 11 on that subject. 12 Q And these had been in your file ever 13 since? ' 14 A I don't know if they had been there ever 15 since. They probably have. 16 Q They had been in your file shoftly after i 17 the Three Mile Island accident? 18 A Yes. - d 19 Q What file were they sitting in?. 20 A I don't know what file they were sitting in. 21 I didn't have particular files on this subject or 22 anything else. 23 After I was requested to go through my gm 24 files to produce the documents that were requested in . l I
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25 discovery, I searched my files, but I don't know what _, , -w -w *"
1 Pittman 6 f\
\#~ 2 files they came in.
3 Q How did this one come up j ust in the 4 last week or two? (, 5 ,A I think this one came up in the last 6 week or two after I had -- I searched my files 7 several months back when.the initial request for 8 discovery came out. 4 I did not know that I had
- 9 anything that even related at that time to what 10 they were requesting in the discovery. (:
j 11 I got another call from Davis Polk i 12 some few weeks back, I don't remember how long, 13 requesting that I go back and make another search, , 14 , and at that time I went back, pulled practically 4 15 everything I had, whether it was pertinent or not, i 16 and just sent it and I suppose they were in it. I did 17 not'even know they were there. , 18 " Q On the next page of Exhibit 57i, what 19 ' '
- are the notes on that page?
20 A Which page is that? .The - second page of 21 the' exhibit beginning at the top? 22 l MR. BENEDICT: Marked as page.T25919. 23 A That is Bill Street and Cal.Goslow where 24 I had . put. their name on there to route this to-them. 25 Q so that is your handwriting.atLthe-top?
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1 Pittman 7 3 A Yes, well, it looks like my handwriting.
- . 3 Q What does the writing down at the bottom 4 say?
5 { A The writing at the bottom says, " Bill, 6 you may want to keep this on file." - 7 Q That's your handwriting? 8 A Again, it appears to be_my handwriting. 9
, Q On the next page of the exhibit, what does 10 the handwriting at the top say? e I
11 A I can only speculate what that says at 12 the top. 13 Q What do you think it says? 14 MR. BENEDICT: Wnll, give him what your 15 best recollection is. 16 A My best recollection is, " Bill, I forgot 17 how this was left. Do you remember?" _ 10 Q That's a note that you sent to Bill 19 . street? 20 A Yes. 21 That's y.our RLP? Q (' ' 22 A Yes. 23 Q What are the other writings? 24 A I have no idea. {~J] w 25 Q Are those somebody else's initials? i . l
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i 1 Pittman 8
\_/ 2 A I don't know.
I 3 Q When, to the best of your recollection, ! 4 did you write your note " Bill, I forgot how this was 5 left. Do you remember'?" ( , 6 A To the best of my recollection, I wrote 7 that shortly after receiving the February 9 memo. 8 I don't know if it was prior to receiving the
- 9 Feb rua ry 16 memo or shortly after receiving the 10 February 16 memo, but to the best of my recollection, 11 it would have been shortly after February 9 and some 12 time around February 16.
13 Q I would like to return to th'is later. 14 Did you bring with you today a resume 15 which you have prepared for purposes of today's e 16 deposition? 17- A This is the resume that's been prepared 18 for purposes of -today's deposition. 19 MR. SELTZER: I would like to mark it as 20 GPU 572, please. 21 (Resume of Roger L. Pittman marked 22 GPU Exhibit No. 572 for identification as of 23 this date.) 24 (~S Q Is GPU 572 an accurate resume for the
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25 information that it-contains?
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2-A I believe that this resume accurately , 3 contains my experiences, that's correct. 4 Q When did you firs t have any administrative 5 responsibility for site problem reports? 6 A The first -- my first involvement with
, 7 site problem reports was early in 1972.
E Q What was your involvement in 19727 9 A I was the NSSE responsible for obtaining 10 and coordinating _ resolutions to site proplem reports 11 from the Oconee 1 reactor during startup. 12 Q What does NSSE stand for? () 13 A That stands for nuclear serv' ice support 14 enginee r. > b 15 Q To whom did you report? 16 A At that time in 1972 I reportehtoJohn' 17 Ittner. l - 18
- Q What was the state of developm[nt of .
19 the site problem reports before you began-t6 function-20 on it in your capacity in 1972? 21 MR. BENEDICT: Could I.-hear that.again, 2' please? 23 (Record read back.) 24 (~}
\j MR. BENEDICT: Do you mean what was the
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25 - ' state of the procedure of-preparing site problem l l
1 Pittman 10 2 reports? 3 Q No, since you were responsible for 4 obtaining and coordinating resolution of site 5 problem reports, any particular report on which you 6 were going to function already must have been brought 7 up to some stage of completion before Roger Pittman 8 functioned en it, isn't that right? ; l
)
9 A I am really confused on what we are getting 10 h e re . t > 11 As far as development of the site 12 problem report --
) 13 Q Let me try and be clear.
14 A o.n. . 1 15 Q I would like to discuss with you typical l 16 site problem reports as you functioned on hem in 17 1972 as an NSSE. I would like to find out ,first 18 what had been done to prepare the site problem report
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19 be fore it came to you as an NSSE. ' 20 MR. BENEDICT: Now we are focusing on this 21
.. 1972 time period, is that right?
22 MR. SELTZER: I said as an NSSE. 23 MR. BENEDICT: All right, during all the 24 (~T time he served in that role. L.) 25 Q In 1972 when you' began working on them.
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2 MR. BENEDICT: ~ 0.K. 3 A What had been done prior to me receiving 4 the site problem report in Lynchburg, the engineers 5 at the office in the field or in the field office at 6 oconee would discover a problem that they felt I should be reported in accordance with the NP GD site 8 problem report procedure. They would fill the site 9 problem report cut, forward it to the hone office in 10 Lynchburg for a resolution to be obtained and 11 returned to the field office. 12 This was done in accordance with the
. 13 '
r l written procedures and nuch of it was done verbally 14 through telephone contacts also. 6 15 Q What were the different avenues of 16 resolution that were available in Lynchburg for a site 17 problem report? 18 ' A The different avenues, there were not very 19 ~ many different avenues, so to speak. 20 There-were the NSSE who was responsible 4 21
.for obtaining and coordinating the resolution. We 22 received many site problem reports, often sometimes 23 more than one a day, and we used the task engineers,
(~h 24 the individual task engineers throughout our
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25 organization to obtain_these resolutions. t L
1 Pittman 12 l O
- 2 g What were the various ways in which a i
3 site problem report could be resolved during the time 4 that you were an NSSE? i 5 A The ways that they could be resolved 6 were -- normally the ways they could be resolved was 7 by telephone contact to the task engineer, discuss 8 the problem, have a meeting with him, sent him the 9 site problem report. He could provide written 10 resolutions, often require meetings. Itt was a 11 coordinated effort in that respect. 12 Q Now, you are telling me the mechanics 13 for resolution. 14 ! I am trying to find out what actions 15 could be taken which were resolution, what would be 16 said, what would be written that ~ would con titute i 17 resolution? 18 A There was a block on the site p'roblem 19 report, and I don't remember what the block' stated, 20 but there was'a block for resolution.that the
- 21 resolution could be written on the site problem 22 report.and it could be transmitted back to the field 23 office through that written block.
24 ("} s.s It could also result in other 25 correspondence that may go back to the field in the w , we
1 Pittman 13 O N- 2 form of a letter. 3 Q Anything else? 4 A Not that I can recall.
, 5 Q Could a site problem report result 6 in a field change authorization?
7 A Oh, yes, it could. It could be cause 8 for a field change authorization to be prepared, 9 that is correct. 10 Q That's what I an looking for. g what are , 11 the kinds of things which could be directed which 12 lvould be the resolution of the. site problem report. ( 13 A Field change'authorizaticn, a written , 14 correspondence, a verbal communication. I;can't 15 recall others. 16 Q In the period that you were nuclear 4 17 support engineer, did what you have described continue 18 to be the procedure for obtaining-coordinating 19 resolution of' site problem reports? - 20 A I am not sure if I understand this 21 exactly. 22 Did the same procedure continue throughout, 23 the same revision of the procedure continue throughout, 24 is that what-we are asking? ("}
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s.) , 25 Q- Did the practice that'you have described
1 Pittman 14 s- - 2 for obtaining and coordinating resolution continue 3 to be the practice throughout the time that you 4 were a nuclear service support engineer? 5 A Yes, I believe that was generally the 6 accepted way of resolving site problem reports t 7 throughout this time, yes. 8 Q When you became technical support 9 supevisor, did you continue to have responsibility > 10 for site problem reporto? p. 11 A I had some because when I became 12 technical support supervisor -- the oconee job was e 13 essentially cenpleted, but there was so me remaining 14 remnants to be completed on that contract and I 15 retained responsibility for that. 16 ~ Q What we re your principal responsibilities 4-17 as technical support supervisor? 18 A The principal responsibility be'came 19 general administration and general supervisory 20 responsibilities.of'NSSEs. 21 Q so you were supervising the NSSEs who (? 22 were doing the coordinating and resolving site 23 problem reports? 24 A i I was providing gene.ral responsibilities w 25 for the5e NSSEs for that period'of time, and I assisted W
1 Pittman 15 r - k_)f . 2 them with some site problem reports on various 3 contracts as the work load dictated. 4 Q Were you responsible for supervising 5 the work that they were doing in obtaining and 6 coordinating resolutions of site problem reports? 7 A I was not responsible on a day-to-day 8 supervisory responsibilities role in these
*9 individuals, no.
10 If they needed assistance, I tried to 11 provide it. 12 Q In 197G you became unit manager at NPGD? 13 A R!. gh t . . 14 Q What unit were you i~n charge of? 15 A Mechanical equipmen t and fluid systems. 16 Q You had responsibility for administration 17 of the site problem report procedures while'you were 18 unit manager, right? - 19 MR. BENEDICT: Could I hear that again, 20 please? iti (Question read back.)
- 22 A I was unit manager of the mechanical 23 equipnent and fluid systems group from February '76 - 24 to June of '79.. Throughout this entire period I did V 25- not have responsibility for site problem reports.
1 Pittman 16 I \ 2 In the latter -- some time in 1977 I was. 3 given the administrative responsibility of that group 4 in addition to my other duties as unit manager of 5 mechanical equipment, fluid systems. 6 Q You said you were given administrative 7 responsibility of that group. 8 What group are you referring to? 9 A The technical support group or the NSSEs. t 10 Q So that in addition to being manager l
; j 11 .
of nechanical equipment and fluid systems, you were 12 also a managar of the technical aupport group? 13 A That was one of the function's that was 14 j put under my unit manager, mechanical equipment, 15 fluid systems group, right. 16 Q Who had been in charge of the technical 17 support group between February '76 and some time in. 18 1977 when you reassumed control? " 19 A Part of that-time there was a man named 20 Ed Walder. I don't know whether'he had it throughout 21 that entire period or not. 22 Q Don Hallman testified that prior to his 23 deposition,he came to you and discussed with you the r- 24 procedures by which site problem reports
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25 reviewed within B&W.
1 Pittman 17
\_ 2 Is it correct that you and he had that 3 conversation outside the presence of counsel?
4 A Don Hallman asked me several questions on 5 site problem report administration within the last 6 two or three months. I don't remember exactly when 7 it was. But we did have conv'ersations on how it was 8 done. 9 Q You told him how it was done while you 10 were the supervisor? ( 11 A I told Don as best I could recall 12 !everything that I knew. , ( 13 Q At one or more points in his ~ 14 deposition, Don Hallman told us you would know , 15 more than he did about it, and we deferred some of 16 our questioning on site problem reports fo$ your 17 deposition. 18 Rather than making this more cumbersome , 19 than need be, I would like to put in front of you 20 the site problem report procedures, pages 5 and 6, 1 21 and then I will have some questions that I want to 22 ask you about how site problem reports were being 23 processed in -late '77 and early 1978. (g 24 ME. BENEDICT: Just so you understand, N)
- 25. Mr. Pittman, you are not being asked to y
1 Pittman 18
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- 2 interpret these documents today.
3 Mr. seltzer is offering them to you 4 today to help you with your recollection of how 5 things were done. 6 Q Revision 6-has previously been marke/ as 7 GPU Exhibit 407, and also as GPU 345. O Can you tell from that document when 9 I Revision 6 was effective, as of what date? 10 A It appears to be 3/5/79. ( Q March 5, 19797 1 A Going by the date here.
% '3 Q Am I correct, March 5, 1979 is the >
I4 l effective date of Revision 6 to the cite problem
- 15 report p ro ce dure ?
i 16 A Our general way of effective date is to 17 have the effective date in the left-hand side. It 10 is marked "3/5/7S." I can't say that it wa's or was 1 19 not. I don't know. ~ 20 Q Given your familiarity with B&W's practice 21 and your familiarity with the site problem report 22 p roce dure s , do you believe that March 5, 1979 was the 23 effective date for this procedure? 4 24 MR. BENEDICT: I will object to the form 25 of the question, but you may answer it. o
I 1 Pittman 19 2 A I don't know. 3 Q As preposterous as that sounds.- 4 MR. BENEDICT: That's not a question. g3 5 Q Now, take a look at the revision status 6 of pages on page 1. 7 Do you see that? 8 A Yes. 9 Q That indicates that only two pages had ' 4
- 10 ieen changed in this precedure since Revision 5, i .
11 right? 12 A Where do you see that? 13 i Q Page'1 is Revision 6, page 2'is Revision
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14 5, page 3 is Revision 5, page 4 is Revision 5, et i 15 cetera. 16 A That appears to be correct. 17 Q The only two new pages that were re vis ed 18 t between Revision 5 and Revision 6_are pages'1 and 7, 4 19 isn't that correct? ' 20 A That appears to be correct. 21 Q In other words , .pages 2 through 6 in
- 22 Revision 6 are the same as pages 2 through 6 frou 23 Revision 57 1
^3 24 A Would you restate that, please?
{V 25 Q Look and see page :2 is Revision 5~, page'3 wi- y w - y7,-.p - - , - < w - - - , --+-,,,# e e -e n-g-
- 1 Pittman 20
( , 2 is the same Rev. 5, page 4 is Rev 5. 4 3 A Yes, that is correct. 4 MR. SELTZER: Let me mark as GPU Exhibit 5 573 Revision 5 of the B&W site problem report 6 . procedure. 7 (Revision 5 of the B&W site problem 8 report procedure marked GPU Exhibit No. 573 9 for identification as of this date.) I 10 ' 2 The reason I went through what I just l1 t ' 11 I did with you about the boxes on the bottom of page 1, l 12 there were some pages in GPU 573 which, as we received
) 13 them from Babcock & Wilcox, are not extremely
{ 14 legible and sinca you can see from Rev. ~6 that many 15 of the pages in Rev. 6 were unchanged from Rev. 5, 16 you may find a clearer copy of those pages*in , l 17 identical form in Revision 6. 18 Do you understand that? . 19 A Yes. . 20 Q In your position of responsibility for 21 site problem reports in 1977 and 1978, did you work 22 with the B&W site problem report procedures? 23 A occasionally I worked with the site 24 problem report procedures.
- o. 25 Normally when I work with them, it was
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1 i 1 e i c l
1 (? Pittman 21 ('s. ' is- 2 to provide a review or an overview on the -- on 3 perhaps a pending change to a site problem report l 4 procedure and in some cases provided the opportunity 5 to comment on it. 6 Q Are you familiar with GPU 573 and GPU 7 407? 8 A I am familiar with them, yes. 9 Q I would like you to the best of your I 10 recollection describe the procens f or i.Si tiation 11 and processing of a site proolem report, and I would 12 like you to describe that process as it existed in () 13 late '77 and early 1978. ' l I4 A The process for preparing a site problem 15 report in 1977 and 1978 was similar'to the process 16 that was used in 1972 that we previously talked 17 about. The field office personnel would recognize 18 and identify a problem that they felt was reportable 19 in accordance with the SPR procedure.and prepare a j 20 site problem report and send it to Lynchburg for 21 the NSSE to coordinate and determine a resolution. 22 Q Pardon me if I interrupt for one second. 23
, When you say " field office personnel,"
f-{. 24 are you re ferring explicitly to B&W field office
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'q, 25 personnel?
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l 1 Pittman 22 0 2 A Yes, our engineers that were in our 3 field offices in our sites is what I am re fe rring to. t 4 Q They would be the ones who would initiate 5 a site problem report, right? j 6 A I believe that is correct. I don't l l 7 think that Lynchburg people at that time initiated 1 i 8 any site problem reports. 9 Q Thera was a format for the field office l 10 personnel to follow? . i ' I 11 A A for at? 12 Q A fcrm. t i O 13 I A Yes, there was a form for them to l ! 14 follow in submitting a site problem report. 21 service support engineer and 1977 and 1978. {3 , 22 Take a look at the form that's at the back 23 of Exhibit 376 -- 24 MR. BENEDICT: I am going to make an i 25 objection to the preamble of the question. , c _, , ,, : + : 'y~b
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1 Pittman 23 !O 2 Mr. Pittman testified that the process l 3 was similar. He didn't say that it was the ; 4 same. 5 Q What were the differences there, if there i ! 6 were any? 7 A I don't know the differences. 8 If there ha'd been nany reiterations of l i 9 this procedure, I can't say that they were ideq+ical. 10 j They were similar, and that was my s ta t eine n t . ' i 11 They were similar in 1977 and 1979 to what they were ' o 12 '72, similar, but I c. a n ' t go through all the l Iin - i j 13 l differences without going thrcugh all the pr.ocedures, t I -l 14 l et cetera. i 1 i i i 3 21 supposed to prepare a site problem report and prepare 22 it in accordance with the requirements of NPGD site 23 problem report procedure. I don't remember all those j - + , 24 requirements, t 25 Q I put it in front of you, so please use
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1 Pittman 24
- 2 it to re fresh your recollection.
3 A I would have to make my statement that l 4 he would prepare a site problem report in accordance ( l 5 with this definition if the problem that he dis cove re d J 6 on site fell within this criteria. - 7 Q What definition and what criteria are 0 1 you referring to? I { S] A I'am referring to Section 6 of Rev. 6 10 to the site problem report procedure. . ! I l 11 ' Q So you are looking at the definition of l ' '2 site problem? t 13 A I am looking at Section 6, . Re v . 6 of the 14 site problem report procedure, site problem definition, i i l
. .l .
l 21 A Without reviewing it word for word, , 22 I don't know. 23 Q Take a moment and compare them. i i 24 MR. BENEDICT: I object. He does not 25 have to compare them. Anybody who can read the .
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1 Pittman 25 lO 2 English language can compare them and that's not j 3 what this witness is here to do. 4 Q Well, I was asking you, Mr. Pittman, 5 about 1977 and'1978, and you said that the fields ! 6 representative would have to comply with a de finition I ' l 7 in Rev. 6. l 8 Rev. 6 did not become e f fe ctive until I 9 1979 so what I am trying to call your attention to 10 is the identical de finition in Revision '5 and ask 11 you is that what the field personnel would have ' i
- 12 to comply with?
O 13 MR. BENEDICT: Do you mean that he i j 14 would comply with whatever the operative l { i i 1 1 l 21 Q Revision 5 was in effect in the latter l 22 part" of 1977 and throughout 1978, right? 23 A It was in effect in the latter part of '77 24 and I don't know how long it was in effect. l 25 Q It would be in effect until Revision 6 , i i l a aw. w - ~. - a =~~ " U~r M "~^% " "
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l Pittman 26 lO 2 was adopted, wouldn't it? i 3 A That would be correct, and would be to j 4 that date, that's correct. ! , 5 Q Was the site problum report to be filled i 6 out only if there was a problem with equipment that 1 ( 7 was part of B&W's scope of supply? 8 A At what time are we referring? It changed. 9 Q Right now we are just talking about late ] l 10 '77 and throughout 1978. ', I - ) 11 A In Rev. 5? 1 ! 12 Q Correct. O 1 13 MR. BENEDICT: Does looking at what I l 1 14 Mr. Seltzer has put in front of you refresh l i l I e ll 1 l j ) 21 on B&W-supplied equipment and also as stated problems l 22 outside the B&W scope of supply that affect B&W l 23 equipment. 24 Q What did you understand was the purpose 25 of having field personnel prepare site problem reports? _ A ,, s._ .h ..
. ..:~.. .. ~ . ~ J- L - a ail +-~~~#~~a*-
- 1 Pittman 27 lO 2 MR. BENEDICT: I will object to the form, 3l but you may answer it.
l 4 A I understand the purpose to be a mechanism I 5 that our field personnel could rep o rt back problems l
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6 that they discovered during the installation of our i l 7 equipment and perhaps during the pre-startup operation l l
! 8 of our equipment that they could report it back to the :
i 9 field office to obtain resolutions. 10 Q Did you understand that one ' purpose was I 1 l j 11 to permit B&W to take steps to try to avoid a 12 reoccurrence of that problem? i O 13 A I understood that that was one of the I l l 14 things that was done when the site problem report i , I l l l 3 21 at other B&W plants? i 22 A Essentially I believe I just answered 23 that, but, yes, I understood that the site problem , 24 report was a mechanism that could provide feedback 25 back to Lynchburg and that steps could be taken from
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1 Pittman 28 O 2 i the site problem reports to prevent the problem 3 happening at other plants. 4 Q After the site problem report was ) 5 originated in the field, who received it in 6 Lynchburg? , A In what time period? 8 j Unless I say otherwise, we are going Q 9 to continue talking fo r the next hour about late ' 77, ' 10 early '78. . 11 MR. BENEDICT: Early '78. Before you 12 said all of '78. O 13 Q All of '78. We are talking under I4 Rev. 5. 1 21
,{, could have perhaps been received by the man acting as i
22 the t e chnic.a1 support supervisor in that group and 23 then passed it to the nuclear service support engineer._' 24 Q There were several nuclear service 25 support engineers, right?
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1 Pittman 29 O 2 A Right. I 3 I Q In addition to the support engineer l' 4 for a particular plant getting the site problem 5 reports from that plant, did anybody else get the site 6 problem reports? 7 A Initially receive them? 8 Q Yes. 9 A There was some period of time in this 10 time frame we are talking about that the.NSSE may 11 l not have received the site problem report di re c tly . I 12 His acting supervisor in the technical support O 13 group may have received the site problem report and l 14 gave it to him. 21 if a possible safety concern existed and does it have 22 cross-contract applicability. This is in addition 23 to his responsibilities to determine, to coordinate 24 a resolution. 25 Q How would an NSSE determine if there
.a_,,,.. .
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i i-- A n % L " '~ " ~ - *A
I l 1 Pittman 30 l l 2 was a possible safety concern? 3 A Generally an NSSE would go about determining 4 that through his own previous expertise in addition ( 5 to consultation with the individual task engineers 6 throughout NPGD as well as reading the definition 7 of a possible or potential safety concern. l 8 Q What task engineers would he consult with? 9 l A He would consult with the task engineers 1 l 10 that were identified as being the applicable task, 11 engineers for the particular piece or component i 12 that the problem was written against. l (:) 13 Q What is a task engineer? 14 A A task er.gineer is a person within our i l i i I 21 engineer? 22 A There was a published list, a periodically 23 published list that I believe came from project l () 24 management, and the NSSEs retained that list and it l 25 went by that list to determine who received the
,u; _ . . . . - w~ .442;,z na w.~f ' I ,, r
l 1 Pittman l 31 2 site problem report. I l i 3 Q Did the published list show who was 4 the appropriate task engineer for each piece of ( 5 equipment delivered by B&W7 6 A I don't know if it showed for each piece l s I 7 of equipment. I would be speculating to say l 8 that it did or did not.
. 9 Q How did an NSSE use the published list i
j 10 to find the appropriate task engineer? ', l 1 11 A Simply by looking at the list and 12 re ferring to the site problem report in determining O e 13 what component was affected, and then going back 14 to the list and determine who had responsibility on I 21 number of people that an NSSE could send a site 22 problem report to. l 23 Q Was there a form on which the NSSE told () 24 the task engineer what type of work the task engineer 25 should do on the site problem report?
~
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- ._ .-_-_____~_.-n... - _ _ _ - _ _ _ - . - - . .
- 4 -
1 Pittman 32 0 2 A Yes, there was a cover letter form that " 3 the NSSEs used to transmit site problem reports 4 throughout the building to various task engineers. 5 There was a block on that form where l 6 he requested what action he desired. 7 Q Is there a place within NPGD where 1 8 for each site problem report there is kept all of the 9 memoranda, comments, notes, work orders that were 10 generated in connection with each partic'ular esite 11 I problem report? l 12 MR. BENEDICT: Are we now talking about < l 13 today? . 14 MR. SELTZER: Yes. 1 i l l l 1 l l
)
21 In addition, a working file was kept by
)
! 22 NSSEs. , i 23 Q The records center received all of the 24 accumulated memos and notes and forms that re fe rre d 25 to any particular site problem report? mw._.
. a
. . _ _ . . _ _ . _ . . _ . , _ .mm.mmoa _ .. -%u
. . ._ ~
1 Pittman 33 O 2 A I cannot say that they received all. 3 I don't know. 4 Q Was it your practice when you were 5 involved to send them all to the records center? 6 A Generally that was the practice, to send 7 the records center the copies of correspondence 8 dealing with site problem reports.
. 9 Q You said that one of the things which 10 the NSSE did was review the site problem, reports for #
11 possible cross-contract applicability; did you not? 12 A I said that f^ determined with the task O 13 engineer if it did have cross-contract applicability. I 14 Q " Cross-contract applicability" means to 21 1977, Dennis Rice was the NSSE. Whether he had it 22 the entire year, I don't know. 23 Q Did Doug Holsted pick up the ball at one 24 point? 25 A Doug Holsted assisted Dennis Rice on ,,, 2 c _ .
. o a:wdhi
- - ___-_ -_____-_- _____-_----___~__-__- __
44
1 Pittman 34 a 2 Davis-Besse in the time frame of 1977. 3 Q Let me show you what has previously been 4 marked as GPU Exhibit 133. It is site problem 5 report 372 for the Davis-Besse September 24, 1977 6 event. 7 A o.K. 8 Q Are you familiar with the form which 9 appears as the covering page of this exhibit? 10 t MR. BENEDICT: Are you talking about the 11 non-han dwritten part? 12 Q Just the form, not what is written in it, O 13 yes. . 14 A Yes, I am familiar with this fo rm . 15 Q Just above the dotted line in the 16 middle of the page, do you see the signature line for 17 nuclear service support engineer? ~ 18 A Yes. 19 Q Is that where the individualiwho had
- 20 receivad the site problem report from the field 21 after it had been originated would sign his name?
' 22 A To clarify that, I can't say that it's
- 23 i the individual that received it who signed his.name.
f')\ (, 24 It could perhaps have been received by his supervisor ~ - 25 l or it could have been received by this individual.
- e. - -., w -w a py- -
9 --9 -.u< - - g%**-e y y.- 99 +- f-'
I 1 Pittman 35 i 2 This I think more correctly stating it would be 3 that this would be the signator of the individual who 4 was transmitting it for action. ( 5 Q Is that person who is transmitting it l . 6 the NSSE that you were describing who would be 7 obtaining and coordinating resolution of the site 8 problem report? 9 A Yes, he is the individual that I was 10 describing as being the person, yes. ( 11 Q Is he the person who was responsible 4 12 for determining whether there was a possible safety 13 concern arising out of this site problem report? 14 A If he was the NSSE for this site problem 15 report, he would have been responsible for determining 16 possible safety concern and does it have cross-contract 17 applicability? Yes. I would like to add to that. 18 Unless he designated to.Holste or someone 19 who is assisting him, and I' don't know if he did or not. 20 Q You mean designated?
. 21 A' Well, I am saying Dennis Rice was the
- b.
22 nuclear service ' support engineer ~.for Davis-Besse. 23 To make-the statement that Dennis' Rice was the ( 24 individual responsible.for determining there .i s a 25 possible safety concern, does it.have cross-contract e ~ , n n , ,-
+w-
1 Pittman 36 O 2 applicability, he could have had assistance from i j i 3 another nuclear service support engineer who may have , 4 performed that function along with him. 5 Q You were indicated for a copy of GPU 133. 6 . Do you see that? 7 A Yes. 8 Q What is your understanding as to why in 9 the f all o f 1977 someon*e would be routing to you this 10 particular site problem report? What is'your 11 understanding, if any, as to why people were sending 4 12 this to you? 13 MR. BENEDICT: The question.is what do you 14 recall about this? 15 MR. SELTZER: Well, no,-that's not it. 16 MR. BENEDICT: Well, that's all you have
- 17 to answer. '-
18 MR. SELTZER: That's not my question. 19 Q My question is from your position at j 20 that point in time, what is your understanding today 21 of why you we re ' being sent site problem reports 22 including this one? 23 ~ MR. BENEDICT: If you have a general i l
/"T
( ,/ 24 recollection _-of why you received site problem-I 25 reports in that time,-you may testify _to it, e . _ _ , . -_. _ _, , -.
1 Pittman 37 C) - 2 but you don't have to speculate as to why you 3 g t this one. If you remember why you got that 4 one, that's fine. ( 5 A No. I have a recollection of why I
.6 received site problem reports at that time. At that 7 time I was unit manager of mechanical equipment 8 and fluid systems group. I generally received copies 9 of problems associated with mechanical aspects of the 10 plants. I had a group of engineers who I, passed these 11 problems along to revicw it. If the resolution was 12 a practical resolution, it could be sent back to the 13 field-14 My recollection would be that I received 15 it from mechanical aspects for that review.
16 Q When you got SPRs for review, what did 17 you do with them? - 18 A I had a group of field engineers, most 19 all who had had field experience, and'when I received 20 a copy of a site problem report, I would_ pass it along 21 to this individual for his review. He would review (. 22 "the site problem report in accordance with the 23 p ro ce dure in effect at that time, pass it back to (3 f _j 24 me for sign-off from the mechanical aspects of the 25 site problem report. rue
- 1 Pittman 38 (d- 2 Q What would the field engineer working 3 for you do, what was he -- what do you expect him 4
to be looking for, what useful function did you ( 5 expect him to perform, is my question. 6 A The field personnel in my group had 7 previous site experience. Often times the home office 4 8 engineer may not have had the extent of practical 9 experience in the field that this individual had, 10 so he was primarily reviewing it from practicality 11 of the resolution that the NSSE and the task engineer 12 had made a determination on. 13 Q You mean he would be looking.at it to 14 see if the NSSE and the task engineers had come up 15 with the right solution to the site problem? 16 - A I don't want to say he would r view it i 17 to determine if they would come up with the right solution to the problem. 19 I would want to say that he had the i 20 opportunity to review this from a practical aspect 21 of whether this resolution could be' implemented in 22 the field. l 23-Q Did you and your staff ever review the l 24 determination that was made by the-NSSE regarding 25 cross-contract applicability?
t 1 1 Pittman 39 O 2 A For any site problem report? 3 Q For the ones that were being routed to 4 you. (' 5 A I guess I don't remember what we reviewed 6 four years ago. I don't know.
~
i 7 Q I wasn't asking you what you reviewed. 8 I was asking whether it was part. of your 9 function of review to reappraise any determination 10 that had been made by the NSSE regarding', cross-contract 11 applicability. i ' 12
\
A I was providing a review in that group , 13 from a plant equipnent service manager viewpoint.
- 14 The plant equipment service manager was Le alred to 15 technically review the resolution to assure all
.2 - 16 aspects of the problem have been resolved. 17 Q Was'one of the aspects of resolution 18
, determining whether a problem had cross-contract 19 applicability?
I 20 A I don't recall if that was or not.. 21 The primary function was.on.the NSSE'to make that-22 determination. I really do not recall. 1 23 Q Was the determination of cross-contract ~ 24 applicability partiof.the resolution of all aspects 25 of a site problem? w- ^ w ' qwy e 5m , y se -w w 2
I Pittman 40 m 1
)
2 MR. BENEDICT: I will object to the 3 form. 4 You may answer the question if you
/ -
5 understand it. 6 THE WITNESS: Would you repeat that? 7 (Question read back.) 8 A Again, I would have to re fer back to the 9 procedure that required the NSSE to make the , 10' determination and determine cross-contract 11 applicability. The NSSE may have gone to the 12 individuals in my organization in additiyn O 13 task engineer. to the He was required,to determine with 14 the contract task engineer for appropriateness. 15 He may have felt the individuals in my group were 16 equally qualified or well qualified, and he may have 17 done that. I don't know how often that prictice was 18 followed. 19
- 12 How important did you think it was to 20 include in the site problem report procedure a 21 determination of cross-contract applicability?
l' 22 MR. BENEDICT: How'important compared to 23 what?- r^ - (,)g 24 Q Did you think that was important? Did you 25 think it was a significant thing to do? T - - , -
i 1 Pittman , 41 {
~s (d 2 A Do I think now?
3 Q Back then. 4 A I always felt that when a problem 5 occurred on one site that it shouldn't continue 6 to occur on site after site after site, and that 7 there should be provisions for making that , 8 determination, yes.
. 9 'Q Have you ever become aware e.t any point 10 in time whether the Davis-Besse site problem report 11 for the September 24, 1977 transient resulted in a 12 determination that there was cross-contract CE) 13 applicability?
14 MR. BENEDICT: As I recall, there were 15 several SPRs. Do you have any one in mind, 16 Mr. Seltzkr? i s 17 MR. SELTZER: Yes, the one that focuses
- 18 on the failure of the pilot operated relief 19 valve, 372.
20 MR. BENEDICT: You are talking about 21 SPR 3727 22 MR. SELTZER: Right. 23 THE WITNESS: Would you read that 1 (~% L (_) 24 questica, please?- - I 25 (Question read back.') 4 5
- ~
~ - . . .- . . -. .-. . . .. .. - -- - - __ ..
i i 1 Pittman 42 0 2 'A Following the Three Mile Island f 1 3 accident, tnis site problem report surfaced as a } 4 matter of interest. Shortly following that 2 l 5 accident, I directed people to the location i { 6 whe re this site problem report could be located and
- 7 at that time the site problem report was produced, !
j 8 I don't know where it was sent, and at that time 4 9 I saw the cover sheet on the site problem report T 10 that it had been indicated as having bee'n reviewed 11 and that was the first time of my knowledge. 12 Q Site problem report 372 has a history - i
; O 13 subsequent to the form in which it exist,s in front 14 of you.
I 15 Did you-ever determine that site problem 16. report 372 had been determined to have.cro s-contract
- 17 applicability? ^
, 18 A No, I-never determined that.
19 Following the Three Mile Island accident, 20 I observed the fact that a nuclear service support _1 . 4 - 21 engineer had'aigned'off,.that-it had been reviewed.- ,
'22 I.did not determine it.
23
- - Q Did you make any investigation'into
) ,
f L24 why.the NSSE'did not determine that there was 25 cross-contract-applicability? e , l H _.,._ ,, .. . ------. , _,,._ . .~ - _ . . _ , . . . . . . - . _ . . . _ . _ . . . . . , _ , , _ .
m__ - . 1 Pittman 43 2 MR. BENEDICT: I don't think Mr. Pittman'a 3 testimony has been that he knew one way or the 4 other what it was. I think he only said that 5 it had been reviewed. 6 May I hear the question again, please? 7 (Que s tion read back.) 8 MR. BENEDICT: I will object to the fo rm
. 9 of the question, but if you understand it, you 10 may answer it. L 11 A The only investigation that I did to make a determination on why the NSSE determined it was 12 13 not applicable, I believe I recall it had been signed 14 off as not being applicable by Doug Holsted. Doug I
15 Holsted is no longer with B&W. I inquired to Doug j - 16 Holsted why he had signed it off. Doug Holsted 17 mentioned that Davis-Besse.had different types of 18 relief valves. He told me something else. I don't 19 even remember what he said, and that was the extent 20 of the investigation or discussions that I had on 21 that subject. 22 Q Was Holsted still employed by B&W when 23 you spoke to him? 24 A. Yes. 25 Q .You spoke to him after the accident?
= . ._ .
1 Pittman 44 m 1 . 2 A Yes. 3 Q Did you understand at the time you were 4 talking to him that Davis-Besse had a pilot operated k 5 relief valve manufactured by crosby? a 6 A I probably did. I have known that 7 Davis-Besse had Crosby relief valves for a long period 8 of time.
. 9 Q Most of your other plants had Dresser valves?
10 A Most of them, yes. E 11 Q I take it when you said Holsted had 12 told you that Davis-Besse had a different kind of 13 valve, you were referring to the fact t h.a t they had a 14 Crosby valve whereas B&W's other plants had Dresser 15 pilot operated relief valves? 16 A Yes, that would be what I was referring 17 to. - l 18 Q Did you discuss with Holsted whether that 19 was a sufficient basis for not finding cross-contract 20 applicability? 21 A No, I don't recall discussing that with I 22 him at all. It was a very short situation and l 23 I don't recall discussing that. 24 Q Did you discuss with anyone else whether i 25 that was a sufficient basis for deciding that there V .
1 Pittman 45 2 was not cross-contract applicability for the failure 3 of the pilot operated relief valve at Davis-Besse on 4 September-24, 19777 5 MR. BENEDICT: Just so we have this 6 clear, Mr. Pittman said that he recalled that 7 Holsted told h'im several reasons,that he can 8 only remember that one, and you are just focusing
. 9 on that one, I take it?
10 MR. SELTZER: Yes, t j 11 A I don't remember having discussions with l 12 other people on the applicability of the Davis-Besse 13 contract to site problem reports to other contracts. 14 (Answer read back.) 15 THE WITNESS: May I rephrase that? e . 16 A I don't remember having discussions with 17 other people other than my short discussions with Doug 18 Holsted concerning the applicability of th 19 Davis-Besse site problem report to other contracts. 20 Q Did you tell Doug Holsted that you thought 21 that the mode of failure of the Davis-Besse valve 22 could be a mode of failure that could occur to any 23 other plant's pilot operated relief valve?
/O 24 A
\ j I don't recall telling Holsted,that 25 because I didn't -.I knew very little about the
_ __mm _._._________-----____m-- - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - -
I 1 Pittman 46 O *
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b 2 Davis-Besse site problem report. I probably would 3 not have known it had a difference. 4 I knew very little about the Davis-Besse
! ) 5 s.ite problem. report, so my recollection is I didn't 6 discuss in any detail with Doug Holsted whether his 7 generic review or determination of applicability 8 was eithersatisfactory or unsatisfactory.
9 Q After the "hree Mile Island accident, 10 l you did read the Davis-Besse site problem report, I' 11 didn ' t you? 12 A No, I did not. I saw a copy of the O 13 Davis-Besse site problem report. I recalled it was 14 very lengthy. I did not sit down and read it. I never 15 have read this site problem report. , i 16 Q What was your purpose in going to see 17 Doug Holsted? 18 A I knew Doug Holsted was leaving B&W and 19 after, before he left, I was interested in the event 20 that I ever did get' questioned on it later, what his 21 response was. 22 Q Where is Holsted now, to the best of your 23 .. knowledge? LO V 24 A I. don't know where Holsted is exactly. 25 He left B&W and went to work for a -- hiring himself
$w + - e y y
1 Pittman 47 O 2 out to a body shop. I don't know where. I 3 Q Do you know which one? i 4 A I recall about a year or two ago he was
$ 5 at the Palos Verdes plant. I don't know if he is 6 still there.
7 Q Working for which body shop? 8 A I don't know. I heard he was there. That 9 was over a year ago. 10 ] 4 (Recess taken.) '. . 11 BY MR. SELTZER: ' 12 Q After your conversation with Doug Holsted, 13 did you report to anybody that one of Do.ug's bases 14 for finding no applicability to other plants was 15 that the Davis-Besse pilot operated relief valve 16 was manufactured by a different company than had 17 manufactured other plants' PORVs? - 18 A I don't recall reporting that information 19 to anyone. i 20 Q was it just personal curiosity then that 21 led you to go talk to Doug Holsted about that subject? l 22 A I don't know-what led me to go talk.to Doug i i 23 Holsted about that subject. ! P g. l (_) 24 Q You have got in f ront- of you GPU 376. t ! 25 That's your handwriting on 'the front of~that, right?
1 Pittman 48 O 2 A Yes. 3 Q Do you recognize your handwriting on the 4 front of GPU 376? 5 A That appears to be my handwriting. " 6 Q Could you read what you wrote there, 7 please into the record? 8 A "The occurrence on this SPR is possibly 9 generic to other plants. It has been taken care of 10 ( by Ken Wandling writing an SIP to all sites to 11 maintain an inspection of these moving parts. The 12 ' S writing of this SIP should satisfy the generic J 13 concerns of this problem. " 14 It's signed "RLP, 7/16/75." 15 Q That means you wrote this on July 16, 16 1975? 17 A That is the date indicated here'. 18 Q You wrote that after reviewing the site 19 problem report, which is attached to your handwritten 20 remarks, right? 21 A I don't recall writing that. 22 Q You refer to "The occurrence on this 23 SPR." ((,,/ 24 SPR in your note means site problem 25 report,.right? l.
1 Pittman 49 , C)i u-2 A Yes. - 3 Q And from the context in which this 4 appears, do you recognize the site problem repcet ki 5 that is attached as being the site problem report' 6 relating to electromatic relief valve malfunction 7 that you were remarking on in your cover note? 8 A Since this is titled "Electromatic 9 Relief Valve Malfunction," the writing underneath 10 indicates that it was due to an electromatic relief' 11 valve malfunction, that is correct. 12 Q Your conclusion was that this site
) -
13 problem report was "possibly generic to.other B 14 plants," right? 15 A That is the statement that is made. 16 Q Does the phrase " generic to other plants" 17 mean that there was cross-contract applicability?- 18 MR. BENEDICT: Mr. Seltzer, he has testified 19 he doesn't remember the document. I don't know
~
20 exactly what'you are getting at. Are you asking 21 him to interpret this document today? I guess 22 that's my question. 23 Q I am asking you,10c. Pittman, as you used f
\. ,)
/ 24
~
the phrase " generic to other plants," whether that 25 phrase means the same as the other phrase we have
1 Pittman 50 [) v 2 been using today, namely, cross-contract
~
3 applicability? 4 MR. BENEDICT: And what I am saying is, 6 Mr. Pittman has testified he doesn't remember 6 writing it. 7 I want to know if you are asking him 8 to interpret this document today. 9 Q I am asking, as you used the phrase, 10 t
" generic to other plants" before the Three Mile 11 Island accident, did thht phrase mean the same to 12
-s you as cross-contract applicability?
13 MR. BENEDICT: If you had a common 14 . usage that you can remember, you may answer him. 15 A I commonly refer to "possibly generic 16 to other plants" as being similar to having 17 ~ cross-contract applicability. 18 Q So you thought that the electr matic 19 relief valve malfunction that.you were commenting on 20 here had cross-contract applicability, is that right? 21 MR. BENEDICT: Objection. He has 22 testified he doesn't remember writing the-23 document. l .
^N l _) 24 Are you asking him whether he remembers 25 that that's what he thought?
l 1 Pittman 51 U 2 MR. SELTZER: As refreshed by seeing his 3 own handwriting. 4 MR. BENEDICT: If your memory is 5 refreshed, Mr. Pittman, you may testify. 6 THE WITNESS: Read the question, please. 7 (Question read back. ) 8 MR. BENEDICT: In light of the fact that 9 he uses the term "pos sibly. " It's written i 10 right there. - 11 A I don't know what I thought when I wrote 12 this document at that time. 13 Q What is an SIP? 14 A It is a site instruction procedure. 15 Q You said that Ken Wandling had. written 16 an SIP to all sites to maintain an inspection of 17 these moving parts. 18 Do you see that? 19 A Yes, I see that.
- 20 Q Was there a mechanism chat existed in 21
{ 1975 for B&W in Lynchburg to send an SIP to all sites 22 where there were B&W plants? , 23 A A mechanism existed in Lynchburg for 24- sending SIPS to sites. When we used the word "all," 25 I' don't.know. l
}
1 Pittman 52 w) 2 Q What do you mean you don't know? 3 A Without looking back at the procedure 4 to verify it contract by contract for each individual
< 5 one, I could not make the statement that it existed 6
for all plants. Generally speaking, it did. 7 Q In July 1975 you were a technical s'upport " O supervisor. 9 In what way was it part of your job to have 10 r eviewed this site problem report which is part of 11 GPU 3767 12 MR. BENEDICT: I will object, to the form (1) 13 of the duestion because he hasn't indicated that I4 ' he remembers this particular site problem 15 ll report, but if you'can answer that question , 16 generally, I will let you do it. 17
~
MR. SELTZER: Rod, you-are being terribly 18 y non-law'er-like. The document clearly indicates 19 in words'that Mr. Pittman has read that he 20 did in fact review it, so for you to make the 21 ~ asinine objection that you don't think there, ' 09 is a sufficient foundation that he reviewea'it, ., 23 I Laink is uncalled for, it's ob s t'r u cti ve , p)
\_ 24 it's not lawyer-like, it's out of keeping"with ,
25
.the way lawyers in this case --
l'; . c ,. < .
$ ' ?
l i i Pittman 53 b ' 2 MR. BENEDICT: .And it's just what the 3 lawyers- for GPU have been doing. If you want } ) 4 to argue with me on that, I think of the 200
\
, 5 days of testimony,I can find plenty of instances 6 where partners of yours and associates of yours, 7
and you, have'done exactly the same thing, i
- 8 Let's try to keep this from being quite 9 so rude as you usually behave.
i I find the 10 expression " asinine" to be inapprohriate in the 4 11 extreme, and I think it says a lot about the ' ' 12 ~ucer of it. ~ (~) 13 MR. SELTZER: Will you read.the question,. ' a i
- 14 please?
i e 15 (Question read back.) . 16 MR. BENEDICT: You may. answer that '
~
17 generally from your recollection, fine. If you 18 don't remember the specific SPR, tha ' s O.K. 19 A I honestly don't~ remember why I would have 20 reviewed this SPR from a generic concern. 1 6 21 Q Do you know for generic concerns or'for- ' l 22 cross-contract applicability?
- i i
23 A- As I stated,for generic concerns. {. -i 1
) 24 Q Do you have-any information as to why-( 25~ the nuclear support engineer ~who-had reviewed this
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1 , Pittman 54 A '
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(_) 2 site problem report had apparently concluded that 3 this problem was not considered applicable to other 4 contracts? 5 A I have no idea what he had considered.
. 6 Q Do you see at the top of the first page 7 the third line beginning "This SPR"?
8 A Yes. t 9 Q It says there, "This SPR has'been reviewed 10 by. task' engineering groups and is applichble to 11 NSS - 00." 12 Do you see that?
. 13 A Yes. .
14 Q Do you have any idea how it is that 15 after task engineer groups had reviewed this SPR
~
16 and not found it applicable to any other B&W plant, 17 yoi reviewed it and found it possibly generic to
, i -
18 other plants? 19 MR. BENEDICT: I will object as asked 20 and answered, but you may answer it again.
. [ 21 A Our general way of marking these at the 22 time was if it applied to no other contracts, we-23 marked it "00." The-fact,.agal,n, x this is-my best .
3 (N (,) ' 24 recollection,, would be that if Ken.Wandling had-25 written an SIP taking care of it, it would then have e a e
I 1 l 1 1 Pittman 55 2 been marked as being no longer applicable. i 3 Q In the latter part of 1977 and 4 throughout 1978, was there any procedure for reviewing 5 the determination of cross-contract applicability? 6 A_ other than procedures that we produced, 7 I don't know -- I don't recall any other procedures. 8 Q You have lost me. I am asking you, can 9 you tell me was there any process for reviewing the 10 determination made by the NSSE of cross-c,ontract ' 11 applicability? 12 A I don't know of any process. ("h s/ 13 Q So if the NSSE determined that there was 14 no cross-contract applicability, there was nobody 15 in the B&W organization, to your knowledge, who 16 reviewed that determination? 17- A I didn't say that. I said I knew of no 18 procedure per se that made this requirement. 19 Q I am trying to advance the next step beyond 20 what the procedures said. 21 Now I am'asking you who are particularly 22 knowledgeable about how the SPR process worked, and 23 I am asking you to focus on the step after an.NSSE 24 has made a determination of no cross-contract 25 applicability, are'you aware of whether there was any
1 Pittman 56
~
U(~% i 2 further review of his determination made in late '77 3 or throughout 19787 5 4 MR. BENEDICT: You mean as a general 1 4 k 5 matter, I take it? 6 MR. SELTZER: Right'. 1 7 A I am not aware that there is or that there 8 is not. 9 Q As you sit here today, you can't recall j 10 any process that existed for reviewing that i 11 determination by the NSSE? 12 A n I can't recall any process, that's correct. b 13 Q Did anyone ever speak to you before tAe a , 14 Three Mile Island accident, either orally or in
; 15 writing, and inform you that they thought the 16 Davis-Besse site problem report 372 had cross-contract i
j 17 applicability? - 18 A Prior to the Three Mile Island accident, l 19 I don't recall the Davis-Besse site problem report 20 incident. 21 Q Are you familiar with the initials PCA l 22 as applied to something within B&W prior to the Three i 23 Mile Island accident? () g s_- 21 A I am familiar with the initials PCA . 25 I don't know at what time I became familiar with them. l" , . ._ -. .
l l l l 1 Pittman 57 2 Q What did you understand a PCA was? 3 A My understanding of a PCA was that it was 4 a form that was prepared by th NSSE if he determined k, 5 that a problem had cross-contract applicability. 6 Q Does PCA stand for preliminary change 7 authorization? 8 A I don't know. 9 Q What did you understand was the 10 function of a PCA? - 11 A My understanding of the function of a 12 O PCA was another form or another mechanism to notify %-) 13 the appropriate personnel of the existen.ce of a a 14 problem on one site for other sites. 15 Q When you say " appropriate personnel," 16 what are the groups of people who would receive PCAs? 17 A I don't know all the groups. Task engineers 18 would receive PCAs and generic project managers would 19 receive PCAs, and I don't recall who else would 20 receive them. 21 Q Before the Three Mile Island accident, k 22 are you aware that B&W audited its PCAs to see whether 23 ithe necessary action had been taken with respect to 24 them? 25 A- By "B&W auditing the PCAs," I am not sure. l
1 Pittman 58 2 I am confused on who is B&W in that case. 3 9 Y "" "E*"Y* 4 MR. BENEDICT: Do you mean did anybody ( 5 within B&W? I think that's the question, 6 Mr. Seltzer? . { 7 MR. SELTZER: Right. g Q Were you aware that within B&W an audit g- was pe rformed before the Three Mile Island accident [o to review the effectiveness of the generic PC As 11 that had been written following site problem reports? 12 A I am aware that an overview was made; 13 whether it was called an audit or not, I don't know. l 14 An overview of that system, and how it was working, 15 I think was made by someone in the technical support
/ ~
16 group at one time or another. 17 Q That review showed that there were 18 generic PCAs that had not been properly implemented, 19 isn't that right? 20 A My recollection of what that generic 21 review showed was.that they had all not been closed 22 out within the time frame that whoever the reviewer 23 was thought they should be closed down. [') s-24 Q Do you remember who the reviewer was7 25 A I don't remember. l l
- _ , _ . _ _ . ,_ , - _ . . _ . _ _ . . _. _ - . . _ _ _ _ . . ~ , . . - , . -
1 Pittman 59
).
2 Q Was anything done to get generic PCAs 3 closed out in a more timely fashion? 4 A Following the review by the person in 4
- f. , , 5 the technical support group, a letter was written 6 and was written to various section or department 7 managers bringing this to their attention, and 8 I am getting into the area of speculation, but
. 9 I believe they were all addressed by those people at 10 that time. *l J
11 Q You say to bring this to their attention. f~ 12 W'a s this a letter that was written to 13 tell people that generic PCAs should be_ closed out 14 more promptly? 15 A I believe it was a letter written to 16 make them aware of the results of the review or audit 17 or whatever we ended up calling it, and that 18 without looking at a letter, I don't know what 19 actions were requested. l 20 Q Who wrote the letter? . 21 A I don't know if I wrote the letter or 22 the person that I reported to wrote the letter. l 23 Q To whom did-you report? l 24 A I don't know if it was Ellison or Hal 25 Baker. l
~
f 1 Pittman 60 (~'s
- w.
2 Q Was the catalyst for the review of how ~ 3 efficiently B&W was handling generic PCAs a meeting 4 that an official from Consumers Power had asked for? k 5 A I don't remember what the catalyst for i 6 that review would have been. 7 Q Do you remember a meeting that you had 8 with Ron Bauman from Consumers Power in 1978?
. 9 A I remember a meeting I had with Ron 10 Bauman in that general time frame. E 11 Q Do you remember that the purpose of 12 Bauman coming to talk with you was to determine \- 13 the mechanism by which B&W assures that site problems 14 at other sites are reviewed for applicability to his 15 plant?
16 MR. BENEDICT: Mr. Seltzer, I don't know 17 whether we are having a memory test here or not. 18 MR. SELTZER:. We are. 19 MR. BENEDICT: All right, go ahead. 20 A I don't remember the purpose of Mr. Bauman's 21 meeting. kw 22 Q Do you remember.that one of the things ! 23 that was discussed at the meeting between you and 24 Mr. Bauman and others was.what mechanism B&W had for 25 assuring that site problems at one site would be
-l 1
Pittman 61 (3 %J 2 reviewed for applicability to the Consumers 3 Power plant? 4 A Yes, I~ remember that that was discussed 5 at the meeting with Mr. Bauman. - 6 Q Do you remember that the B&W personnel 7 at the meeting described the procedure by which 8 site problem reports are reviewed for generic 9 applicability? 10 U A I remember that was discussed and there 11 was a description given.' I don't remember who gave 12 it. v 13 Q Do you remember that Mr. Bauman expressed 14 sotne re servations about whether the procedure was j 15 adequate? 16 A It's been several years ago. don'.t know II' what Mr. Bauman expressed. .
~
18 Q Do you remember that Mr. Bauman said he 19 wanted to audit the records of identified generic 20 PCAs? l 21 A Again, I don'.t remember what Mr.--Bauman 22 said. i 23 Q Is it correct that in 1977 and 1978 it 24 was 3&W's policy not to show customers copies of 25 site problem reports?
-- ~ _ - _ _ _ - - - _ _ . _ _ . - _ - - _ _ . _ - - - - - - _ _ - - _ -
i l 4 1 Pittman 62 O L) 2 A I believe that's been our policy in that 3 time frame, yes. 4 Q That was B&W's policy even if B&W 5 determined that a problem at somebody else's plant had 6 generic applicability to a different customerls 7 plant, isn't that right? 8 A I believe it was B&W's general policy 9 not to show site problem reports to other customers. 10 Q Even where there was cross-contract 11 applicability? 12 A I don't believe there was any distinction O 13 made between site problem reports. 14 Q What is your understanding, if any, as 15 to why B&W wouldn't show its site problem reports 16 r.o customers for whose plants B&W had determined 17 l there was cross-contract applicability? - 18 A I don't know why that was B&W' position. 19 Q Is Baker still with B&W? 20 A H. A. Baker? Yes. 21 Q Had other B&W customers expressed an l 22 interest'other than Ron Bauman about B&W's procedures l s I 23 for identifying problems that had generic applicability? I l ( 24 A I don't remember who had expressed what back 25 then. t l l
. 1
l I 1 Pittman 63 2 MR. SELTZER: Let me mark for identification 3 as GPU Exhibit 574 a memo from Hal Baker to 4 Messrs. Pryor, Stanek, Suhrke, Pittman'and ( 5 others. The subject is " Generic SPRs" dated 6 May 9, 1978. 7 (Memorandum from Hal Baker to 8 Messrs. Pryor, Stanek, Suhrke, Pittman and 9 others, subject: " Generic SPRs" dated 10 May 9, 1978, marked GPU Exhibit No. 574 11 for identification as of this date.)
- 12 Q You are marked for.a copy of GPU 574.
O' 13 Do */ou recall receiving a copy of this 14 document some time after the meeting that you had with 15 Ron Bauman of Consumers Power? 16 A I am not sure I recall receiving the 17 do c umen t. I do recall the subject. - 18 Q In the fourth paragraph of the memorandum, 19 Mr. Baker states, "I understand that this is not the 20 first expression of interest by a B&W cus'tomer and is 21 not expected to be the last. I believe we can expect 22 an increased awareness on the part of everyone.since 23 it is often a subject provoked or instigated by I D
./ 24 roving NRC representatives."
25 were you aware before the Three Mile
1 Pittman 64
/
t 4 s - 4 2 Island accident that NRC representatives had been 3 intereste.d in'how B&W reviewed problems for generic 4 applicability? 5 MR. BENEDICT: I am going to object to 6 the form of the question because you are tying 7 it to that statement. I am not sure that that 8 sentence even says that the NRC was interested 9 in a B&W s stem, but if you understand the 10 question, you may answer it.
- 11 A I understand the question, but I don't 12 know what the NRC representative's interest was.
13 Q You never were aware that th.e NRC had any 14 interest in B&W's review of plant problems for generic } 15 applicability? e , 16 A I don't recall an NRC interest. 17 Q Did you know that other customers than 18 consumers Power were interested in the eff ctiveness 1 1 19 of B&W's review of site problem reports for generic 20 applicability? MR. BENEDICT:
~
21 Asked and answered, but 22 you may answer it again. 23 A Again, I-don't know what the other
-O
() 24 customer's in te r e s t was on that subject.. 25 Q You'never heard that any other customer
/
%. y ~ +s, . v- ,3 , * , - - - . ~ , w. . , , 2 .
/
1 Pittman 65 ( . U 2 was interested in the effectiveness of B&W's review 3 of problems f6r generic applicability? 4 MR. BENEDICT: Same objection. ( 5 A As I recall, I don't remember recalling
. 6- another customer expressing an interest on that.
7 Q Before the Three Mile Island accident, 8 did you ever attend B&W users group meetings? 5 9 A No. 10 Q Other than the site problem report 11 procedure, are you aware of any other program that B&W ' 12 b had for reviewing problems at its plants for-generic V 13 applicability? - 14 A Other than what is contain^ed in the'SPR 15 p ro ce d ure , I cannot recall any others. 16 Q In the third paragraph there is a 17 reference to Mr. Bauman of Consumers Power," and it 10 said, "He did indicate, however, that the procedure 19 p l.a c e s considerable emphasis on the task engineer 20 performing his responsibilities in handling the 21 identified generic PCAs." 22 i After this meeting with Mr. Bauman of l 23 l ._ Consumers Power in April 1978, a.re you aware of ( 24 anything that,B&W did to upgrade the performance of 25 its task engineers in identifying generic problems? I m- - , . , _ . . _ . , _ , - , _ _,, _ . , .
f 1 Pittman 66
;O 2 A I am not aware of what B&W did or did not 3- do to upgrade'the task engineers in their performance, 4 no.
{ 5 Q You don't know of anything that was done 6 to upgrade the performance, is that right? l s 7 A I cannot recall of any.
- 8 Q Do you recall anything that was done 9 after April 1978 to upgrade the performance of the
, 10 NssEs in identifying problems of generic (.
1 11 applicability? 12 MR. BENEDICT: Could I hear that again, 13 please. I 14 4 (Question read back.) l 15 A I cannot recall, period. j t . j 16 Q You can't recall anything that was done 17 along those lines? - i . I 18 MR. BENEDICT: Asked and answered, but 19 go ahead. 20 Q Is that what you mean? 21 A No, I cannot. 22 Q The paragraph that begins at the bottom r l 23 l of the first page talks about a spot check review i 24 - being conducted before the meeting with Mr. Bauman, 25 ~Do you see that? i I 4 ' l.
1 Pittman 67 (~)
\_)
2 A -Yes. 3 g The paragraph ends on the next page with 4 a statement, "We received the impression that some
< 5 task engineers were ignorant of the procedure and the 6 necessity for responding to the 'PCAs."
7 In early 1978 what responsibility did 8 task engineers have for responding to PCAs? l 9 A In early 1978 the task engineers -- I'm
- 10 sorry, I would be speculating. I don't know what 11 the task engineers' responsibility was, 12 MR. BENEDICT:
t I would like to make a O 13 small note here, Mr. Seltzer. . 14 Your partner, Mr. Glassman, objected 15 vigorously to my efforts to ask people questions 16 prefacing things with the contents of the i 17 document that the witness testified he didn't 18 recall. I am j ust pointing that fac
, out.
19 I think if it helps refresh Mr. Pittman's 20 memory, I don't have any objection to it, but 21 Mr. Glassman thought that that was just about 22 the worst thing you could do to a witness and 23 screamed'and yelled quite a bit about it, but
- 24 you may proceed.
j 25 MR. SELTZER: I'm"with you, Rod, if you i _ J
s I' 4 1 Pittman 68 l 2 thought it was proper to ask witnesses those i t 3 questions, I think it's proper ~also, d
.l i , 4 MR. BENEDICT . It's been proper so far.
l 5 I haven't seen anything to object to. 6~ Q Where would you go to attempt to discover ! 7 what responsibility task engineers had for responding j. I' 8 to PCAs?' ,' 9- A I would go to the site problem report 10 procedure which was in effect at that ti'me. 1 11 Q Would you take a look at the copy that's ! .12 in front of you and tell me what portion of it_-you-13 think is applicable. ' 14 MR. BENEDICT: I object to the form of 15 the question, but the witness may answer it. 7 4 4 16 A According to the site problem report-i- 17 ' procedure, Rev. 6, the affected task engineer was to l_ .18 determine the resolution and if-necessary 4 erform [ 19-various functions which are outlined underneath that \ 20 in his responsibility block. t 21 MR. BENEDICT: Why don't you identify. , 22' what-you are looking at', Mr. Pittman.- 23 A I am looking at Rev. 6 to.the SPR () 24 procedure, NPGD'0503-04, page 7, and'I am looking 25 toward the bottom.of the page- ~at the affected
. 1_ , _ . _ . . - _ _ _ ._. . ~ . . ~ . . . _ . . . . . , . _ _ . . _ . . _ . , . _ . - _ . _ _ . . _ _ , ._1 _ . . _ _- .,
I l l 1 Pittman 69 2 task engineers ' responsibility. 3 Q What does it indicate is his 4 responsibility with respect to responding to the k 5 PCA that you were reading a moment ago? 6 MR. BENEDICT > Mr. Seltzer, I let 7 Mr. Pittman help you out by pointing to what 8 he thought was applicable. He testified he 9 didn't know what the responsibilities are. 10 If you want to know if this kefreshes 11 his recollection, fine. But he is not obliged 12 to interpret this document. 3 (g ' a-
\- 13 MR. SELTZER: I was just asking him J
14 what he was reading from. 15 MR. BENEDICT: You were reading from the
~
16 lower right portion of the page, is that' correct? 17 THE WITNESS: Yes, that's correct. 18 g Well, page 7 is a page of the site problem 19 report procedure that was' revised since Revision 5. 20 It's a page that was not in effect in 1978. 21 MR. BENEDICT: The equivalent page on 22 Rev. 5 seems to be obliterated. 23 MR. SELTZER: Right. i That's the best copy t h) x_/ 24 that.B&W saw fit to produce for GPU in this, 25 litigation, however. i.
, - ,e -r - , , -~
r 1 Pittman 70 N_/ 2 MR. BENEDICT: I am almost sure that's 3 not true, but be that as it may, I am not 4 suggesting that it's your fault, Mr. Seltzer, ( 5 that it is unclear. 6 MR.. SELTZER: What I would like to request 7 if you can determine, if a clearer copy has 8 been produced, I would like to be able to show 9 that page to Mr. Pittman this afternoon so he 10 could at least identify based on h'4s familiarity 11 with this procedure whether there is something 12
', in Revision 5 that told the task engineer'what
(~/
\- 13 his responsibility was for responding to a 14 PCA.
15 MR. BENEDICT: Well, Mr. Seltzer, I am 16 not sure I can today find a page that's 17 clearer than that. - 18 Mr. Pittman-has testified to what 19 his recollection is. You are certainly welcome . 20 to do that. If there is some question about 21 the ability of this document to refresh his 22 recollection, that's fine, but he doesn't have 23 1 to testify what it means to him today. (~%
.g ) 24 MR. SELTZER: I am asking him based upon 25 l
hir familiarity from working with these documents, l l l
1 Pittman 71 2 working with them contemporaneous 1y, whether 3 there is a portion in Rev. 5 that told the 4 engineers what their responsibilities were for ( 5 responding to PCAs. He showed me where it was 6 in Rev. 6, and I would just like to conduct 7 the same examination on Rev. 5 based on this 8 man's unique familiarity with this procedure. 9 MR. BENEDICT: Mr. Seltzer, there is 10 virtually no record on Mr. Pit tma n ',s unique 11 familiarity and in particular there is 12 currently a record that indicates he had no 13 special familiarity with respect to the 14 handling of PCAs. ' 15 MR. SELTZER: I am not going to start e . 16 quibbling with you. I never win quibbles 17 with you because you are such a great quibbler. 18 I will stand on my request that I would-19 like to be able to examine Mr. Pittman this 20 afternoon on a legible copy of Rev. 5 if one 21 has been produced. 22 MR. BENEDICT: I assume, Mr. Seltzer, 23 that you have known about Mr. Pittman's [) q, 24 deposition for some time, in light of the fact 25 that you cancelled it twice, but if you don't 3
1 Pittman 72 n v 2 have a legible copy of an exhibit you wanted 3 to examine him on, that that was something you 4 took on at your risk in this case, so I am ( 5 not -- certainly I will try to figure out if 6 there is any place I can find you a better 7 copy at lunchtime, but I am not going to 0 agree that that is necessary before Mr. Pittman's 9 deposition can be concluded. 10 BY MR. SELTZER: - 11 Q You got' Bert Dunn's February 9 memo 4 12 and Bert Dunn's February 16, 1978 memo, right? 13 A, That is correct. . 4 Q You received each of them at or about 15 the time that they are dated, to the best of your 16 recollection? 17 A- To the best of my recollection; I did. 18 Q You have got copies of those in front of 19 you since they have previously been marked as GPU 20 571. 21 Before you got Bert's memos, had you 22 previously heard about the Davis-Besse September 24, 23 3977. event? O sj o4
~
A I really don'.t recall whether I had heard 25 about-the Davis-Besse incident or not.
~~
1 Pittman 73 O 2 Q - Before you got Bert Dunn's memos, had 3- you been-aware that there had been an event at a 4 B&W plant in which operators had shut off the 1 5 high pressure injection system while a loss of 6 coolant accident was still in progress? - 7 A I'do not remember knowing that prior 8 to receiving Bert Dunn's memos. 9 Q Before you got Bert Dunn's memos, 10 had you ever heard of an event where sat'$ ration had 11 occurred in the reactor coolant system of a B&W 12 plant outside of the pressurizer? 13 A I do not recall knowing of a.ny event. 14 Q Any event such as the one I just described? 15 A Right, prior to receiving these memos. e . 16 Q Before February 1978,- had you ever 17 received any simulator training? - 18 A I received some simulator trai ing way 19 back in early 1972; a familiarity course-with the 20 s imulato r. 21 Q Did you know before February 1978 that k. 22 during most loss of coolant accidents, pressure 23 falls in'the reactor coolant system? ( 24 A I don't remember what I knew about that 25' subject prior to February of '78. . - ~ . . m W
1 Pittman 74
- f3 t/.
2 Q You didn't know that loss of coolant 3 accidents are sometimes called depressurization 4 events? (, 5 A No, I didn't know that they were sometimes 6 called depressurization events. 7 Q And you don't recall whether you knew 8 that loss of coolant accidents depressurized a
. 9 reactor coolant system?
10 A I really don't know what I recalled back 11 then. 12 Q And you certainly don't recall today Ca 13 knowing that --
^
14 A I don't -- 15 MR. BENEDICT: Let him finish the = 16 question. 17 Q You are testifying that today you don't 10 recall knowing before February 1978 that a loss of 19 coolant accident causes pressure to fall in the 20 l reactor coolant system, is that right? l 21 A I am testifying that I don't know what 22 I recall knowing in 1978 about that. 23 g I am not asking for everything that you 24 [Jh
%. can recall. I am just focusing on one fact, and that 25 fact is that when a loss of coolant accident occurs
' b
1 Pittman 75
)
)
2 in a reactor coolant system, the pressure falls and 3 I am asking you today, do you recall whether you 4 knew that one fact prior to February 19787 l 5 A And, again, I would have to say I don't 6 know what I recalled about that in 19'78. 7 Q And the "that" that you are referring 8 to is pressure falling during the loss of coolant
. 9 accident?
10 A yes, t 11 Q Did you know before February 1978 that 12 for every loss of coolant accident that B&W trained O' 13 operators on, pressurizer level fell dur.ing a loss
! 14 of coolant accident?
15 A I had no involvement with B&W training 16
, of their operators and, therefore, I do n ' t know t
17 what they were training their operators as-far 18 as pressure and level. 19 g was it your understanding before ! 20 February 1978 that pressurizer level fell during a i 21 loss of coolant accident? 1 - 22 A I am confused on that question as to 23 whether pressurizer level -- I am confused on the 0) (, 24 question. 25 MR. SELTZER: Why don't you read it again.
~
1 Pittman 76
,e's .
t V. 2 (Question read back. ) 3 MR. BENEDICT: Now, you are asking 4 Mr. Pittman today to tell you that he recalls k 5 knowing about that before February of '78? ' 6 Q Does that help you? i 7 A I don't know that pressurizer level 8 would fall anc the reason for my confusion is if they
- 9 were making up water at the same time. I am not 10 trying to be cute about it. I just -- E g 11 Q If the makeup flow did not exceed the 12 water being lost from the system, did you understand
[ <
\' 13 before February 1978 that pressurizer level would 14 fall during a loss of coolant accident? '
15 A I understood that it could fall during a 16 loss of coolant accident. 17 Q Were you aware before February,of 1978 i - 18 of any loss of coolant accident in which p[essurizer 19 level would not fall? 8 20' A I cannot recall any. 21 Q You knew before February 1978 what a 22 loss of coolant accident was, didn't you? 23 A Yes,-I think -- yes, prior to 1978 I knew () 24 what a loss of coolant accident was. 25 Q You knew that it could result in core
- =.
1 Pittman 77
, O 2 uncovery? -
3 A I knew that a loss of coolant accident 4 could potentially result in core uncovery. '
'5 Q You knew that it conld result in fuel 1
6 damage? 7 A Yes, I knew that it could. 8 g. Did you know thatlit could result in
. 9 ruptured fuel cladding and a release of radioactive 10 fission products?
- 11 A I knew the potential existed for a 12 loss of coolant accident if severe enough to result 13 in potential release of fission products..
14 Q Before February.1978 was there any other 15 event besides a loss of coolant accident that you
- 16 knew could cause core uncovery and fuel damage?
17 A I don't recall knowing any. - 18 Q Before February 1978 was a los of i 19 coolant accident the most serious accident that you 20 were aware could occur at a B&W nuclear plant? 21 A I never really thought about what the i 22 most serious accident that could. occur'was. I 23 t Q After you got Bert Dunn's February'9, ( v 24 1978 memo,-did you attempt'to find-out anything more j 25 about the Davis-Besse event at. Toledo Edison.that. I S. , -er. . , , . , ,_. m . - , _ . , ~ ,
i 1 Pittman 78 1 - 2 Mr. Dunn was re ferring to? 3 A .I did not. . 4 Q You didn't ask anyone to bring you the t ( 5 site problem reports for that event? - 6 A I don't recall asking for that. 7 Q You.didn't check whether this is.an event 8 that had been identified as having cross-contract
, 9 applicability?
10 A I don't' recall checking it f'Qr anything. 11 Q" You wrote a note on the top of your 12 February 9 memo from Bert Dunn to Bill Street,.right? O- 13 A Yes.
- 14 Q Y o~u told us at 9:45 this morning that 15 your note says, as best you can reconstruct it, ; 16 " Bill, I forgot how this was'left.
i Do you remember?" 17 Am I correct in concluding from that 18 that you and Bill Street 'had previously discussed / ! 19 the matter that is in Dunn's February 9, 1978 memo? 20 4 A To the best of my recollection, Bill Street 21 and I discussed Bert Dunn's February 9 memo, and 22 I asked him to handle it. 23 Q
. You say you discussed it with him --
[)h L 24 A Let me rephrase that if I could. 25 We either discussed or I passed it to him.
1 Pittman 79 2 I can't-recall which I did. 3 Q In or about February 1978 do you have 4 a recollection of having any discussion with Billy l 5 Street about Dunn 's memos? 6 A Yes. , 7 g' Was anybody else present? 8 A After I gave Bill Street the memo and
. 9 asked him to handle it, I some time later asked him 10 how it was left. '.
11 He came back to my desk with a couple 12 of people from Don Hallman's group. Frank Walters
^
13 was there and I believe Cal Goslow was there, i I4 and we had a discussion at that time. 15 Q Was that discussion before Dunn's 16 February 18 memo came to you or af ter? 17 A I don't recall when that discussion took 18 place. 1 19 Q You say you asked Billy Street to handle 20 the matters raised by Dunn's memos, is that right? 21 A That's correct. 22 Q' What did you expect Street to.do?' 23 A. I don't recall today what I may have
' (,
O) 24 expected Bill Stree t to do at that time. 25 - ( Q At some. point after asking Street to ;
- /.
1 e 1 Pittnan 80 CE)- 2 handle Dunn's memos, you asked him how it was left I i 3 and he came back with Goslow and Frank Walters to give 4 you a report at your desk, is that right? (, 5 A After I asked him how it was left, 6 he came back and gave me a report. ' 7 Q Was your question to him about how it 8 was left the question that's written on the
. 9 top of Dunn's February 9 memo, or had you asked 10 Billy Street orally in addition to this kritten 11 note?
12 MR. BENEDICT: I will object to the form 13 ot that question. 14 My recollection at least is thdt 15 Mr. Pittman couldn't place exactly as to time t
- 16 when he wrote the note.
17 MR. SELTZER: I am trying to find out 18 if the request to Billy Street was in addition 19 to the note. It's irrespective of time, and 20 also you are wrong when you are saying he 21 couldn't place when the note was written. 22 He testified it was between February 9 and 23 , February 16 to the best of his recollection. /*N () 24 MR. BENEDICT: If that's what the record 25 is, I am not going to quibble with that,'but J
. _ .= - - _ . - . - - ..-. _-
1 Pittman 81 2 I want to point out that I didn't remember 3 that. s 4 You may testify to your recollection. l 5 I believe Mr. seltzer's question was did you > 6 speak with Billy orally or did you just bring 7 him a note or is there some other alternative. i 8 A I really don't recall whether I did or
, 9 did not,'and to set the record straight, to the best 10 of my recollection, I may have received the
, 11 February 16 memo which is what jogged my menory to 12 ask Bill Street did he remembe r how it was left. ws 13 I don't remember if I wrote.It between,the 9th and the 16th or perhaps the 16th memo could have
~
14 15 brought it back to my attention. I don't know. 16 Q About how long was the conversation 17 among Street, Goslow, Walters and you? , ' , ? ![ ,' i 18 A I don't know how long that conversation ' s 1
~ '
19 was.
,% i \
20 Q Who did most of the talking? s
. N i . \-
21 A I don't re me mbe r who did mo s t o f t,he , ' Tf
\ i ,
- 22 talking.
2 s 1 l - ) 23 Q What in words or substance was stated? 1 24 A I have very little recollection' of what \ ' [J) ., + [. . 25 was said in that discussion. I know a discusgidn '
,
- l (1
, * ( \i 5 *'!
& * *" Y
1 Pittman 82 O 2 about solid plant came up. That's the essence of 3 'swhat I recall. 4 ' Solid plant refers to a condition in Q l 5 which not only is the reactor coolant system outside l 6 the pressuriz'er is filled with water as it normally
\
7 is, but the pressurizer is filled with water? 8 A Solid plant referring to -- yes, pressurizer
. 9 filled also.
1 10 Q You sent Dunn's February 16 kemo not 11 ' \ only to Bill Street but also to Cal Goslow.
' {
12 Why did you send it to Goslow? O 13 A I can give you my best opinion. s . , 6 I4 ' MR. BENEhIC Well, I think Mr. Seltzer 15 is just intere'sted in what you remember., - 16 A I don't remember why I sent it to Goslow. 17 Q You have no recollection at all?
' 18 A w My recollection was that this was being 19 handled in Hallman's area and whether it had 20 already been over there or had not been over there, 1
21 which is th . purpose of my correcting the statement
\
wk. ' 22 on tile record 3 the, Neh'ruary 16 memo could have been. 23 what.the conversation s, could have occurred prior to ( 24 my receipt qf the debruary.16 memo. When I received s 25 it, they could already have been on board with this
, 'd? ,
. . . _ . _ - _ _ _ - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - ^ ^ - '
1 Pittman 83 (~h - (_ 2 subject and as to why I would have sent it to him. 3 That's my best recollection. 4 Q Why did you pick Billy Street as the l 5 initial person that you were asking to handle Dunn's 6 memos? 7 A For two reasons. Bill Street was 8 responsible in the mechanical equipment and fluid
. 9 systems gro up for preparation of procedures or 10 specifications for follow-on contracts th,at affected 11 mechanical equipment.
12 . Bill Street was a very good man with s/ 13 a license, senior reactor operator's license, 14 and I felt he would be the appropriate person to handle 15 that. 16 Q Is he still at Babcock & Wilcox? 17 A Yes. , 18 Q Who if anyone else did you give Dunn's 19 memos to? 20 A I don't recall giving his memos to 21 anyone else. 22 Q After the conversation in your office 23 with Goslow, Street and Walters, what is the next 24 conversation that you can recall having regarding 25 Dunn's instructions?
1 Pittman 84 V 2 . A The next conversation that I can recall 3 was after Three Mile Island when again these memos 4 became the center of attention some time after the l 5 accident, and I asked Bill Street where this was 6 left or what he had done; I am not sure what I had 7 asked him. 8 Q Are you saying you don ' t recall a meeting l
. 9 that you had in Ed Kane's office with you and Frank?
10 A I do not recall a meeting in ,Ed Kane's t 11 office. 12 Q Since the accident have you discussed 13 with Billy Street what you and he had b en *doing 14 regarding Dunn 's memos be fore the Three Mile Island 15 accident? 16 A I don't recall what I discussed with Bill 17 after the accident. I remember the gist oE it was 18
. I wanted to see what had been done with the memos 19 after the accident.
20 Q Where were you on the day of the Three 21 Mile Island accident? 22 A I went in to work that morning so I was 23 at NPGD, Old Forest Road. 24 Q Were you consulted during the day of 25 any B&W's actions with respect to the accident?
~
\
l l 1 Pittman 85 2 A I don't recall being consulted as to 3 B&W's actions, no. 4 Q Were you in the command center at all l, 5 during the day where reports were coming in from 6 Pennsylvania? 7 A As I recall, I went into the command 8 c'en t e r late in the afternoon on that day. 9 Q That was the first time you set Soot 10 in that room that day? E 11 A That was the first time. l 12 Q After the accident, is it correct that
\
s/ 13 you and Dave Culberson and Wandling conducted.a 14 review of prior events at B&W plants to see whether 15 there had been equipment failures or transients that 16 had any similarities to the Three Mile Island 17 transient? . 18 A I don't recall -- I recall that was done. 19 I don't recall that I personally conducted that review, 20 no. 21 Q Did you ever see any report or list or 22 any other writing that was generated as a result of j 23 that review? l i l 24 A Yes, I saw a list that was generated.
, 25 Q could you describe what that list looked l
1 Pittman 86
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2 like? 3 A There was a list of previous site f 4 problem reports that identified previous PORV failures, l[ 5 PORV SPRs. 6 Q That'4 all that it was? j 7 A That's all I can recall whe,n we are talking 8 about equipment failures, yes. 9 Q It didn't report prior problems with 10 fe e dwa te r ? 11 A Not that I recall. 12 Q It didn't report any prior problems 13 with condensate polisher systems? , 14 A Not to my recollection. 15 Q who, if you know, had directed that 16 a review of prior events be conducted? 17 A For previous PORV SPRs, I believe I had 18 re que s t e d a review be conducted. 19 Q Why did you request that? 20 A some time after the accident I started 21 receiving questions on that subject and rather than 22 answering these questions for each individual that 23 came by, it became a matter of interest and I requested . J ) 24 that that be done. . 25 (Whereupon, at 12:40 p.m. a lunch recess was taken.)
~
i 1 87 i 2 AFTERNOON SESSION 3 . (2 : 0 0 p.m. ) i 4 ROGE R L. P I TT MAN, resumed. l 5 EXAMINATION (Continued) 6 BY MR. SELTZER: 7 Q Can you tell me within B&W wh'at position-8 J. F. Carson held in 1978? 9 A No, I know he was in the training group 1 i 10 and that's all I know. t 11 Q Was he an instructor in training? 12 I don't even know that. - ) O 13 Q Do you know what J.F. stands for? s 4 14 A I know the J is for James. '
- 15 Q Is he'still with B&W7 1
16 A Yes. 17 Q Where is he now? . 18 A He still works in the training area. 19 Q You testified this morning that Iyou got t 20 Dunn's memos in or about mid-Fe,bruary 1978, right? 21 A Yes. 22 Q -Ix>-you hava any idea why in some answers l - 23 to interrogatories that B&W gave us last week they'said d I i 24 ' the approximate date on which you got Dunn's memos was ! r 25 unknown? i l l l
,n e,,,. - --
y,--+wr,m-- se a y -mw->- -a-p--, g- m. , . , e o yv- w4 g y e -
Pittman 88
. 1 2 A No, I don't know why that states that.
3 Q When Walters came in to discuss where 4 this had been left with respect to the matters in ( 5 Dunn's memos, did you have a copy of one or both 6 of Dunn 's memos out at the meeting? 7 A I don't recall if I did or not. 8 Q It is your best recollection that 9 Walters was at that discussion, right? 10 A Yes. ( 11 MR. SELTZER: This is strange. Since 12 Billy Street got his copies of Dunn's memos O l 13 from you and they list the app ro xi, mat e 14 date that Street got them as Februar 1978, 15 it's baffling that your attorneys said it 16 was unknown when you got them. A 17 MR. BENEDICT: Is that a question, 18 Mr. Seltzer, or,are you making a speech? 19 MR. SELTZER: I am making a speech fo r ,I 20 your benefit. 21 MR. BENEDICT: If you want to talk about
-22 the interrogatories, we can talk about them-off 23 the' record. If you think it's appropriate to /~
24 ( )N talk about them on the record, you go ahead. 25 I think it's a waste of time.
l 1 l I 1 Pittman 89 2 Q Did you ever take any steps before the 3 Three Mile Is1and accident to determine what if any 4 action had been taken to resolve the matters raised by Dunn in Als memos to you? 4 ( 5 6 MR. BENEDICT: Other than what he has 7 testified to previously today? 8 MR. SELTZER: Well, the only thing he 9 has testified to previously is that he sent it 10 to Billy Street to take some actiog and had a 11 meeting in his office with thrhe people who 12 said something about solid plant. 13 MR. BENEDICT: My question, Nr. Seltzer, 14 was whether or not you can recount wh'at it is 15 he has testified to. 16 Q other than those.two things that I have 17 just recited, did you do anything else that in any 18 way, shape or form was a followup on Dunn's~ memos 19 to you? - 4 20 A No. After we had the meeting in my of fice, 21 Frank Walters indicated that -- aither Frank Walters L 22 or Goslow or both indicated that that memo belonged 23 in their area and.they would handle it, and after that (~5 24 I didn't pursue the matter any further. 25 Q Did you read Dunn's February 9 memo when
9 1 Pittman 90 2 you received it? 3 A I. remember reading his memo along about 4 that time. ([ 5 Q Did you understand it? 6 A I don't recall that I had any understandrng 7 or anp misunderstanding about it, either. 8 I don't recall what my thinking was. 9 Q In February 1978 you knew who Bert M. 10 Dunn was, didn't you? 1 11 A I knew of Bert Dunn. I didn't know Bert 12 Dunn very well. 13 Q When you say you knew of him, you knew 14 before you got these memos that he was the manager of 15 B&W's emergency core cooling analysis unit, didn't e 16 you? 17 A I cannot say that I even knew he was the
~
18 manager of that group, no, I cannot. 19 Q Do you know if he was one of the' top people 20 in that group before you got these memos? 4
. 21 A I didn't know where Bert Dunn stood in it.
L 22 Q Did you know he was in that group? 23 A I didn't know what group Bert Dunn was in.
/~N 24 Q Did you know he was an employee of B&W \
25 before you got these memos?
1 Pittman 91 2 A Yes. 3 Q Did you know before February 1978 that 4 the high pressure injection system was part of the l( 5 emergency core cooling system in a B&W designed 6 reactor? 7 A Yes, I knew that it was part of it. 8 Q Did you know that the emergency core cooling 9 system was designed in B&W plants to function in the 10 event of a loss of coolant accident? E 11 A Yes, I knew that it was. 12 Q Did you understand before Febraary 1978 13 that for a certain size range of loss of. coolant 14 accidents, B&W depended on the high pressure injection 15 system to cool the core? 16 MR. BENEDICT: I object to the form of_the 17 question, but you may answer it. - 18 THE WITNESS: Would you read th t back, 19_ please? l 20 MR. SELTZER: I will restate it. 21 Q Did you understand before February 1978 22 that for certain range of loss of coolant accidents, j 23 B&W's design required the operation of the high pressure 24 injection system in order to achieve e f fe ctive core
~
25 cooling?
1 Pittman 92 0 2 A I knew we depended on that in those 3 situations. . 4 Q Did you underctand that for those ( 5 situations if there were not high pressure injection 6 operating, there would not be 'e ffective core cooling? 7 A I don't recall what I knew on that. 8 Q Did you know before February 1978 that 9 if there were premature termination of high pressure 10 inj ection during a loss of coolant accident that 11 required high pressure injection, that-that could lead 12 to a loss of effective core cooling?
%} 13 MR. BENEDICT: I object to the form 14 of the question, but you may answer it.
15 A Again , prior to ' 197 8 I don't know -- I 16 cannot recall on that. 4 17 Q I don't mean to trap you in som,ething l
' 1 18 that may just be our not communic ating e f fectively. .
19 I thought I understood you to say in-answer 20 to my question a moment ago that you knew there was l 21 a certain range of break sizes for which B&W's design f 22 depended on high pressure injection in order to 23 achieve ef fective core cooling. ['} 24 A Right. L/ - 25 Q And you said you. knew that be fore
1 Pittman 93 O 2 February 1978. 3 Doesn't it follow from that that if 4 there was not high pressure injection available for ( 5 that same certain range of break sizes, that B&W's . 6 plant would not have the ability to achieve effective 7 core cooling? 8 MR. BENEDICT: I am going to object to 9 the question. What are you asking him to do, 10 say yes, today that seems to fo llok_? 11 MR. SELTZER: No. I am asking him that 12 isn't that something as you sit back on it (/) s_ 13 today you know you must have known before 14 February 19787 15 MR. BENEDICT: Do you recall knowing that 16 prior to that time. 17 A I don't recall knowing that. , 18 Q I don't see how you could say y u knew HPI 19 was necessary to achieve adequate core cooling and 20 yet not know that if HPI wasn't available,' the plant I 21 would lack adequate core cooling. 22 Is there some explanation that you can l l i ! 23 give? fI I 24 MR._ BENEDICT: Mr. Seltzer, I think he has N !' 25 just told you-his' explanation, that he doesn't l I-
1 Pittman 94 O~ 2 remember knowing. - 3 Q can you explain why those two are 4 inconsistent? ({ 5 MR. BENEDICT: What is the point? Are 6 you asking him today to tell you,to sit down 7 and tell you whether those are inconsistent? 8 All he can testify to today is his memory. 9 Testify to your memory, Mr. Pittman. 10 A I cannot recall what I remembered prior 11 to 1978. I cannot recall today what I remembered in 12 1978. (_) 13 Q Did you know before February 1978 that 3 14 if there was a premature interruption of high 15 p re s s ure injection, that that could be a safety 16 proble m? 17 A Again, I don't recall what I m ay -- I don't 18 know that I even thought about it one way or the other. 19 Q In Dunn's February 9 memo to you", which 20 is part of GPU 571, you knew that Dunn was referring 21 to an event that had previously taken place at the 22 Davis-Besse plant, right? 23 MR. BENEDICT: Are you talking about I'h 24 does he remember knowing that when he read () 25 it or some time prior to the Three Mile Island
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w
- 1 Pittman '
95 2 accident, right?. 3 Q When Dunn writes "The dire'ct concern here 4 rose out of the recent incident in Toledo," you knew 5 he was referring to a Davis-Besse plant at Toledo (( 6 Edison? 7 A Again, when I read this, I don't know what 8 I remembered and what I didn't remember. 9 If I answered that I would have to 10 be going on what I read now. 11 Q I am asking you does this refresh your 12 recollection that when you read this, you knew (_ 13 that Dunn was writing about an event that had taken 14 place at the Davis-Besse plant? 4 15 A It still does not refresh my 16 recollection of what I was thinking when I read 17 Bert Dunn's memo, no. .. 18 Q How many nuclear. plants did To[edo
~
19 Edison have? 20 A Toledo Edison had one nuclear plant. 21 Q That was the Davis-Besse plant, right? 22 A One that I am aware of, yes. 23 Q- Dunn wrote at the end of the second 24 paragraph, "Had this event occurred in a reactor at 25 full power with other than insignificant burnup, it 1
l l l 1 Pittman 96 2 is quite possible, perhaps probabfe, that core uncovery 3 and possible fuel damage would have re'sulted." 4 Before February.1978 had you ever l( 5 received any other memorandum that you recall that 6 had forecast possible core uncovery and fuel damage? 7 A I don't recall ever having received any. 1 8 At the beginning of 1978 you would have Q 9 considered possible core uncovery and fuel damage a 10 safety problem, wouldn't you? t 11 MR. BENEDICT: Would have considered? 12 I don't know what you mean.
- Is this a 13 hypothetical question?
14 Q No, you knew in the beginning of 1978 a 15 that the possibility of core uncovery and fuel damage e 16 represented a safety problem, didn't you? 17 A I don't know what I knew on that subject 18 in the beginning of 1978.
~
19 Q That's terrific. Thank you for that 20 answer.. 21 .MR. BENEDICT: 'I object to that comment. 22 I don't know what the point of it was, Mr. 23 ' Seltzer. .I think.your normal snide attitude I (- 24 25 is slipping.over-into true rudeness today. I certainly hope you'could keep it back to at-
1 Pittman 97 2 least what we have come to expect from you. 3 MR. SELTZER: I apologize to you, Mr. 4 Pittman, if I have given you any reason to l 5 think I am being rude. 6 Q You are saying that you honestly and to 7 the best of your recollection today cannot recall 8 knowing that at the beginning of 1978 you thought 9 the possibility of core uncovery and fuel damage 10 was a safety problem, was that right? t 11 A That's right; I don't know what my 12 thinking was in the beginning of 1978. 13
- Q Before February 1978, what was your 14 understanding, if any,'regarding how B&W's 15 management expected you to respond if a problem 16 of possible core uncovery and fuel damage was 17 brought to your attention? ,
18 A My understanding of the B&W ma[agement 19 position on potential safety concerns that we l 20 were to review it in accor' dance with the potential 21 safety concern procedure, and if we felt t h a t 'i t 22 warranted in accordance with that definition, we 23 would file a PSC.
/~') \_/
24 Q Were you familiar with the PSC procedure 25 as it existed in the beginning of 1978?
1 Pittman 98
.(- .
L 2 A I was aware that we had a PSC procedure. 3 I knew where to go to find it in the event that I 4 needed to retrieve it. I did not recall all the (. 5 details of what the procedure said. 6 Q Are you saying that in 1978 in order 7 to evaluate whether something was a safety concern, 8 you would have had to get out the procedure for
. 9 p'reliminary safety concerns?
10 A Yes, I believe that's c o r r e c't . t 11 I would have had to retrieve the procedure 12 to refresh my memory with the definition of the O 13 requirements. - 14 Q When you got Bert Dunn's February 9, 15 1978 memo, which forecast possible core uncovery
- 16 and fuel damage, do you have any' recollection of 17 getting out B&W's procedure on preliminary. safety 18 concerns?
19 A No, I have no recollection of doing that. 20 .Q Do you have any recollection of asking 21 anybody else to review this memorandum from Mr'. Dunn 22 in terms of whether it rose to the level of 23 preliminary safety concern? e (m) 24' A I have no recollection of asking anyone 25 else either, no. t I
1 Pittman 99 A . 2 Q Do you recall any reason why this memo 3 did not rise to levels that would cause you to 4 determine whether it was a suitable matter for (( 5 preliminary safety concern? 6 MR. BENEDICT: Could I hear that again, 7 please? 8 (Question read back.) 9 A No, I don't recall. 10 Q Did you discuss with Bill S t're e t , Frank 11 Walters or Cal Goslow Dunn's forecast that th'ere was 12 possible core'uncovery and fuel damage if an event (~'
- s 13 such as had happened at Davis-Besse were to reoccur 14 in a plant that was at -full load?
- 15 A I do not recall whe ther that point was 16 discussed at our meeting or not.
17 Q After you read either of Dunn's memos, 18 did you seek clarification of what he meant in either 19 of those memos?' 20 A I don't recall seeking any clarification 21 on those memos. 22 Q You said you turned them over to Billy 23 Street to handle,them. f- } 24 what was there in these memos that you i' 25 thought neede'd handling? ) I
1 Pittman 3GG 2 A I don't recall, again -- again, I remember 3 reading the memos. I don't recall wha't my thinking 4 was when I read the memos. I passed them along ({ 5 to 3111 Street. Bill Street was responsible -- our 6 group was responsible for mechanical equipment 7 problems. I thought the memo had b'een misdirected, 8 as I recall, when it was sent to me. 9 I am mechanically oriented. I was 10 responsible for mechanical equipment, and I was not 11 responsible for operational procedures. 12 Q Have you ever told anybody else before O (,_/ 13 telling me today that you thought the memo had. 14 been misdirected? ' 15 MR. BENEDICT: Other than counsel? 16 A Other than counsel, I don't know if I 17 told anyone that or not. ., 4 18 Q You don't recall telling anybo[y else? 19 A I don't recall. If it came out~in those
.20 discussions at my desk, I don't know.-
21 Q since you thought it had been misdirected,.
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km . 22 did it occur to you to get in touch with Bert Dunn r 23 and find out'why.he had sent it to you? I} U 24 A- I have no recollection that that occurred 25 to me.
l i l i 1 1 Pittman 101 (~)
' ' ~
.2 Q Within B&W's internal procedures as 3 they existed in 1978, it wouldn't have been 4 improper for you to walk over and speak to Bart
( 5 Dunn, would it? 6 A It would not have been improper for me to 7 speak to anyone. 8 Q Did you ever conclude before the 9 Three Mile Island accident that any of the things 10 that Dunn had stated were inaccurate? 11 A I don't recall concluding anything like 12 that. 13 Q Before February 1978 di8 you know who 14 Jim Taylor was? 15 A Yes. 16 Q Did you know that he was the manager 17 of the licensing section at B&W7 . 18 A I knew at one time Jim Taylor was 19 manager of licensing. I didn't know what times 20 he had moved to another job and I didn't know what
. 21 times.
! k-22 Q After you got both of Dunn's memos which ( 23 are addressed to Jim Taylor,- did you ever go talk to l
,/ } - 24 Jim Taylor about what if anything was being done 25.. to : respond to. Dunn's memos?
1 l
I Pittman la2 ('T ' V. 2 A I never recall having a conversation 3 with Jim Taylor on that subject. 4 Q Are you aware, Mr. Pittman, that shortly (, 5 after the Three Mile Island accident, B&W sent each 6 of its operating utilities guidelines for the 7 operation of high pressure injection which included 8 a subcooling rule? 9 A I am aware some information was transmitted 10 following Three Mile on that subject. e 11 Q To the best of your knowledge, that's 12 the first time that B&W communicated subcooling
)
guidelines for the operation of high prebsure injection 13 14 to any of its utilities that had operating nuclear 15 plants, isn't that right? e 16 A I don't know another time. 17 Q Have you ever come to know that,the 18 subcooling guidelines that B&W sent out to operating 19 plants immediately after the Three Mile Islind 20 ~ accident are substantially identical.to the: guidelines 21 contained in Bert Dunn's February 16 memorandum to you? L 22 MR. BENEDICT: I take-it you are excluding 23 what he learned'in conversations with counsel?
/~ 24 MR. ' SELTZER:
Am) N- Right. ' 25 A~ Excluding those conversations, I'was.not _ 'Mc
, - m += w rv v y Y
1 Pittman 103 l r-)x . (_ 2 aware what the details -- I was not aware what i 3 the details of those guidelines were. 4 Q After the Three Mile Island accident, ( 5 did you ever get a copy of the small break operating 6 guidelines? 7 A I never recalled that, again, except in 8 the presence of counsel. 9 Q Do you have any idea how it is that the 1 10 documents which are marked as GPU 571 oni,y came to 11 light within the last couple of weeks and were not 12 produced to counsel for GPU earlier in this litigation?
-) 13 MR. BENEDICT: I consider the form of that 14 question unbelievably bad, but if you understand
- 15 it, Mr. Pittman, you may answer it.
e 16 A I don't know why they were just produced 17 in the last few weeks. . 18 Q The only reason you researched your 19 files in the last few weeks was because you were 20 going to be deposed, isn't that right? l 21 MR. BENEDICT: Mr. Seltzer, the reasons l 22 he may have been told to search his files are 1 1 M \ simply not something that you are entitled tc , I^h 24 probe. (_J You know as well as I do that you made 25 a request of the files of the people whose I
,h'
1 Pittman 104 l'h O. 2 depositions were still in the future with 3 respect-to the Bert Dunn memos,to have their 4 files looked at. You also know that our ( 5 communications with our clients are our own 6 business, so I honestly think that's an improper 7 question. 8 MR. SELTZER: I think it's shocking that 9 a document that is as important as Bert Dunn's 10 memos and Don Hallman's memo to Br'ce u Karrasch 11 in August 1978 could lie concealed in someone's 12 files and only come to light because we have A 13 noticed that person's deposition. .- 14 MR. BENEDICT: Mr. Seltzer, you really 15 don't want to get into a dispute about the 16 availability of people's documents only after 17 they become noticed for deposition? .I mean, 18 that's just beyond the pale compared to-19 what you guys are doing. 20 I have got two boxes of documents for 21 Lou Lanese's deposition. We requested them in 22 De ce mbe r of '81, and we got them during his 23 deposition in March of 1982.
.(Y, 24 MR. SELTZER: I am talking about'the 25 Don Hallman memos which I think are indisputably
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4 1 Pittman 105 2 the key memos in this casa. j l 3 MR. BENEDICT: Mr. Seltzer, if you think 4 this is going to achieve anything, you may make an application to the Court for an extension ( 5 I 6 of your trial date. 7 MR. SELTZER: I just wonder how many.other 8 copies of Dunn's and Ha11 man's memos are in 9 so mebo dy ' s file drawer. 10 MR. BENEDICT: I spend a lot .of my time 11 wondering what you people have withheld, so 12 why don't we proceed with the' questions and 13 stop with the colloquy. 14 MR. SELTZER: I think this is the second 15 time in two weeks that we have gotten copies 16 of Dunn's memos only in the course of 17 depositions rather than them being produced in
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18 a:more timely fashion. 19 MR. BENEDICT: If you want-to khep 20 discussing this, I am sure I can.go point to 21 point on you when documents have been produced. km 22 MR.' SELTZER: I would like'you to name one 4 23 as significant-as the.Dunn memos. 24 MR. BENEDICT:- What new information have 25 you learned from this memo? Do you want Eto
-- m-y-- ,, e- r+n--
I 1 Pittman 106 O 2 tell me? 3 MR. SELTZER: We have' learned a great 4 deal about one person shrugging off Dunn's l 5 - memos by. bumping it to somebody e'lse and then 4 6- not recollect the contents of it. 7 MR. BENEDICT: I don't think you have 8 learned any of that from the documents you are 9 holding in your hands. 10 BY MR. SELTZER: E 11 Q Take a look at the first memo which j 12 is on GPU-571. That's Hallman to Karrasch, 13 August 3, 1978. .\ . ! 14 You got this memo from Billy Street, 15 is that right? 16 A I believe I did. 17 Q After you got this, did you dis. cuss 18 it with anyone? 19 A I never recalled discussing this memo, 20 again except in the presence of counsel. 21 Q And that conversation with counsel-took u 22 place after the accident? 23 A Yes. 24 MR. BENEDICT: Mr. Seltzer, I believe 25 Mr. Pittman's testimony is th at he-got this
- . - _ . - _ _ - _ - ,,~ . _- -
1 Pittman 107 (_, N ' 2 document.after the accident. 3 MR. SELTZER: No, it says from Street to 4 Pittman, "Here's the latest. Please return." (, 5 MR. BENEDICT: Right, and Mr. Pittman 6 testified that after the accident, he reque sted 7' Mr. Street send him what he knew about it. 8 Q Did you get the only copy of Hallman's 9 memo to Karrasch that you ever saw after the Three 10 Mile Island accident? e 11 A I never recalled seeing Don Hallman's 12 memo to Karrasch until after the Three Mile Island 13 accident. 14 Q Did the copy of Hallman to Karrasch with , 15 Billy Street's note to you come to you for the e 16 first time before the accident? 17 I am not asking when you recall later 18 ' seeing it. 19 Did he write this note to you add send
~
20 this to you before the Three Mile Island accident? 21 A I believe he sent me this after the Three 22 M ile Island accident. Another way of saying it-23 is I don't recall ever seeing this prior to the I l [~} V 24 Three Mile Island accident. 25 Q why did Street send it to you after the
l 1 Pittman 108 l Y- 2 accident, if you know? 3 A well, as I testified this morning, 4 after the accident, these memos became documents of ( , 5 considerable interest. I asked Bill Street either 6 by telephone or in person, and I can't recall which, 7 to provide me where that was left. 8 Q After you got this from Street, did you 9 return it to him? 10 A I don't remember. ( 11 Q Did you discuss it with him? 12 A We had a phone call that I had received fh
\- 13 it. I would be speculating to say wh 'c I had 14 said on that phone call.
15 g other than in the presence of counsel, 16 did you ever find out what had happened to Dunn's 17 recommendation between the date of Hallman',s memo 18 and the Three Mile Island accident? 19 A Well, again, not knowing Hallman had 20 written the memo, the question is a little confusing. 21 MR. BENEDICT: Well, Mr. Seltzer'is' 22 ' fi interested in knowing right up to today 1 I i 23 except what you have learned through counsel,
;( ^
-> 24 what hap;cned t'o Mr. Hallman's memo prior to
[. 25 to the Three - Mile Islahd accident? W
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1 Pittman ' 109
'~% . s 2 Q No. The question is other'th'in s 3 communications that you have had in the presence of 4 your lawyers. Those are privileged. I don't v a'n t
(, 5 y u to tell me about those. Have you gained an 6 knowledge before stepping into this room today 7 about what happened to Dunn's concerns between the 8 date when Hallman wrote his memo and the date't at i g the PORV stuck open at Three Mile Island Unit 2 in ( , g 10 March 1979. " ) , 11 MR. BENEDICT: Do you understand the 12 question, Mr. 'Pittman? O_/ s 13 THE WITNESS: Yes. 14 A I don't recall learning anything else 15 about this subject from the time that it was - that
+
16 I was told that it would be handled'in the othe(' 17 group until after Three Mile Island. '
- Nk w
18 "A. &Et4 EDICT : I don't think th'at was what _
~
19 Mr :ed s, P was getting at. 20 What Mr. Seltzer is asking -- ; 21 MR. SELTZER: That's responsive. 22 Q Between February 1978 and March 1979, j -23 did you ever discuss with any other person who was , \ . [~') 24 listed as an addressee or copyee of Dunn's memos l -kJ - 15 any of the matters raised by Dunn? , l
P ,\ A 1 Pittman 110 I don't recall any discussions with the P x 2 A ,5 x ' 3 people on that list.
\ . 4 Q Did you from time to time see any of the l 5 people who were on that list? *
! x 6 A Generally speaking I see various
~,.. 7 individuals on this liet through the office.
8
-Q Which ones?
I 9 MR. BENEDICT: Are you talking now about
/10 the period from February '78 to March of '797 11 MR. SELTZER: Right.
t 12 MR. BENEDICT: And the question is, 13 did you see any of those people from time 14 to time in a 13-month period. 15 MR. SELTZER: No, that's not the question. 16 The question is which ones. 17 A Again, I can't recall seeing any of them 18 ~ in that period of time specifically. s 19 Q Which are people whom you gene r511y did ( i 20 see on business? 21 A Generally speaking I would have seen 22 Tom Scott and Jim Phinney more frequent by than any of 23 the other people. f^') s-24 Q Over a period of a year which of the 25 others would you see on business?
/
4
1 Pittman 111 ( 2 A I can't recall seeing any of them. 3 Q Ed Kane is not somebody whom you run 4 into on business matters from time to time over the ([ 5 course of a year? 6 A Generally speaking, I would, but whether 7 I did or not, I don't recall. 8 Q That's what I am talking about now. 9 Generally speaking who would you run into 10 over the course of a year on business other than 11 Kane, is there anybody else? 12 MR. BENEDICT: I object to the form (~h (_) . 13 2 of all these questions, but you may answer it. 14 I think they are hypothetical and 15 speculative, but go ahead. 16 A Generally speaking, I could have seen 17 Ed Kane. I could have seen Bruce Karrasch., I could
- 18 have seen Eric Swanson or Don Roy.
19 Did I see them or not, I. don't recall. 20 Q What about Henry Bailey? 21 A Rarely did I see Henry Bailey. 22 Q You got to Crystal River after they had i 23 already had the 1980 PORV failure, right? ! ['} (.- 24 A I was not stationed at Crystal River. 25 Q You were associate service manager for 1 l
1 Pittman 112 O G. 2 Crystal River at the time they had a PORV failure 3 in February 1980, right? 4 A That is correct. l 5 Q Did you hdve anything to do with the 6 review or analysis of that PORV event? l 7 A I was not the technical person to review ) 8 that incident, or that transient. 9 Whether I saw it or not or saw the output 10 of someone else's review, I don't know. I 11 Q Do you remember that they had an incident? 12 A Yes.
/~N .
13 Q , Do you remember that the ope.rators left I4 high pressure injection on and took the plant 15 solid during that event? 16 A I believe they did that. 17 Q Did you ever hear that the operators 18 - credited their post-Three Mil'e Island acci ent 19 training for their having left high pressure injection 20 on? 21 A I don't recall operators making that 22 statement, no. 23
.Q Did you ever hear that operators had made O)
( , 24 statements.such as that? 25 A I don't believe I'have.
1 Pittman 113 (- 2 Q What were your responsibilities as 3 associate service manager for Crystal River? 4 A Primary responsibility was contract ( 5 oriented to contractually and administrative 1y 6 manage the Crystal River contract reporting to the 7 serivce _ manage r on the job. 8 Q This morning I had asked you what 9 the responsibilities of the task engin'eer were in 10 connection with generic PCAs and you said that 11 would be covered in the site problem report procedure 12 that was in e f fe ct - in late '77 and throughout 1978.
-) 13 Let me show you a copy of Revision 5 14 which is more legible than the copy we had this 15 morning, and it's the most legible copy that r
16 counsel for either side has been able to find on 17 short notice. . 18 MR. BENEDICT: That page is a page of what 19 has previously been marked as GPU 456.' 20 Q Can you determine where in the procedure 21 the task engineers' responsiblilities, for handling 22 generic PCAs is described? 23 A Yes, I can determine that from what I am [) LJ 24 seeing, where it's located in the procedure. 25 Q Where is that?. u
1 Pittman 114 2 A (Indicating) 3 Q Is that step 197 4 A It appears to be step 19. It's a little ( 5 blurred. 6 MR. BENEDICT: Is that on page 7 of 7 Rev. 5 on the SPR procedure? 8 A Page 7, Rev. 5, yes. 9 Q I would like to show you what has 10 previously been marked as GPU 366. I t ' s',a transmittal 11 from Ken Wandling to Lee Rogers on May 9, 1978 12 dealing with a cooldown event at Three Mile Island (s .
\-- 13 Unit 2 which had occurred the preceding April 23, ,
14 1978. 15 You will notice that on page 864 your 16 signature appears, do you see that? 17 A Yes, I see that. . 18 Q Am I correct that according to that 19 signature box, you reviewed the document for accuracy? 20 A That appears to be my signature in that , 21 block. I do not recall reviewing this documen t for 22 accuracy. 23 Q What is the process of reviewing for [') 24 . accuracy as you can recall it from the spring 1978? LJ 25 A As it says, it would be a requirement to ___ _. 1_ - - ,
1 1 Pittman 115 2 review it on the basis of the knowledge that you 3 would have of whether any inaccurate information was 4 being transmitted. ( 5 Q Did you from time to time from documents 6 submitted to you which you were requested to review 7 for accuracy? 8 A From time to time I did, yes. 9 Q Was it your practice to read the document 10 carefully to determine whether it appeared to be i 11 accurate to the best of your knowledge and belief? 12 A It was not always my practice to read it 13 in great detail since in many cases I relied upon the 14 personnel in my group to provide such a detailed 15 review, and I would follow it up with discussions with 16 them. 17 Q So either you would review it $n detail 18 or you would have somebody in your group r[ view it in detail to see that it was accurate? 19 20 A That was generally our practice to do that. 21 Q You don't have any recollection that 22 something other than your regular practice was employed ! 23 for this document, do you? () 24 A I have no recollection of this document. 25 Q Would'you take a moment and review the i
,1
I l I 1-Pittman 116
' (O
_/ 2 ! doc ume n t since I have been asking you questions 3 most of the time that it's been in front of you? 4 MR. BENEDICT: Mr. Seltzer, do you want ( 5 the witness to read the whole document? ' 6 Because I don't think -- if you want to ask 7 him, point something out to refresh his recollection, 8 that's- fins.I don't think it's an appropriate 9 practice to ask the witness to read a 20-page 10 document. I 11 MR. SELTZER: It's only six and a third 12 pages.
-) 13 MR. BENEDICT: What'is all t is stuff at 14 the back? It looks like more pages bo me.
15 MR. SELTZER: Well, he can read whatever 16 he would like to. I don't know.how much of it 17 he would have reviewed for accuracy or discussed 18 with others who reviewed it for accuracy for 19 him before he felt that he in good conscious 20 sign his name in the reviewed for accuracy . 21 box on May 9, 1978, 22 MR. BENEDICT: Having testified that he 23 doesn't remember the document, what are you i [) V. 24 asking him to do now? 25 MR. SELTZER: I would like to re fresh his l L-
1 Pittman 117 Y' 2 recollection. I think it's very easy for - 3 him to say he doesn't recall this. 4 MR. BENEDICT: What you should do is look it over and say whether or not that ( 5 6 refreshes your recollection. 7 A In reviewing this, it does not in any way 8 refresh my memory about this document. 9 MR. BENEDICT: I might note, Mr. Seltzer, 10 that we agreed there was a limitat$on to this I 11' deposition and I haven't made a big deal about 12 it, but I don't see how this falls into any of 13 the four categories that we agreed to discuss. 14 MR. SELTZER: Given the witness' lack of 15 recollection, that would be a moot point. 16 Q Did Wandling work _for you in 1 787 17 A I don't believe he did in 1978. 18 Q Without getting to the specifids of 19 this communication back to Lee Rogers at thd TMI site, 20 youtare familiar with the subject matter that is 21 covered in this memo just from looking at it today, / 22 right? I i 23 MR. BENEDICT: The transient, is that i
- 24 the question?
25 MR. SELTZER: No, the fact ,that it talks l l g 7- 1 "
1 Pittman 118 ! i- ~ . U 2 about pressurizer voiding 1.s one subject. 3 MR. BENEDICT: Mr. Seltzer, I don't see 4 how you are going to tie this up into one of ( 5 the four categories we discussed. 6 MR. SELTZER: Here is all I want to ask, 7 and you can decide whether you want to make a 8 ruckus about it: 9 Q What was there about your responsibilities 10 in 1978 that would have made it part of 9,our 11 responsibilities to'be reviewing a communication 12 such as this? A
> 13 MR. BENEDICT: I object to the form of 14 the question.
15 In order to try and expedite this, 16 a Mr. Pittman, if you understand the question, 17 you may try to answer it, but I certainly 18 don't understand it. 19 Q What was there about your responsibilities 20 in 1978 that would cause people in the B&W organination-21 to submit this to you before it was issued as a site-22 instruction? 23 A Well, as I previously testified in 1978 [) s..- 24 I was unit manager for the mechanical equipment and
'25 fluid systems' group.
t n - - . - -n -
1 Pittman 119 O 2 From there I would have to look at the 3 contents and only speculate as someone perhaps thinking 4 this fell in my area. ( 5 Q Since you were responsible for 6 mechanical equipment and fluid systems, did that mean 7 that.the performance of the pressurizer was something 8 that was within your bailiwick? 9 A It primarily meant that I had a group 10 of field engineers who had previous sitetexperience 11 in the mechanical systems and fluid experience, 12 and these personnel were in my area and they were not
/~5 k-) 13 analysis-type. engineers; they had previous site 14 experience.
- 15 g .Was the performance of the pressurizer 16 with its associated mechanical equipment and fluid 17 systems something that fell within your jurisdiction?
18 A The engineering portion of the response 19 of the pressurizer would not have fallen in my 20 jurisdiction. 21 Q I would like you to put on one side what 22 your areas of responsibility were and on the other 23 side what this memo is covering and tell me whether f)
%.J 24 there is any ove rlap.
25 MR. BENEDICT: I object. We are beyond
s 1 Pittman 120 s - % = 2 the pale now, Mr. Seltzer. 3 MR. SELTZER: Let me explain so that 4 there is no needless controversy. (, 5 One of the areas that we are allowed to 6 cover under our stipulation is the 7 responsibilities and duties of the witness. 8 MR. BENEDICT: Right. 9 MR. SELTZER: I understand that he 10 doesn't recall functioning on GPU '-3 66, so I am 11 not going to try to analyze portions of the 12 document with him, but I would like to find out
- 13 whether there are areas covered by GPU 366 that 14 were within his areas of competence.
15 MR. BENEDICT: I understand -- 16 MR. SELTZER: I can take him through it 17 and read him particular paragraphs and say. 18 "Was that within your area of compet nee?" 19 If you want, I would do that. p 20 MR. BENEDICT: I would object to the 21 form of each and every one of those questions. 22 Now,as the subject mattersyou are entitled to 23 ask him what the area-is covered, but as'to the I. () 24 document, you are not allowed to say "Look over 25 this document and tell me whether or not it-
I l 1 Pittman 121 s - 2 includes things that you were responsible for." 3 That is simply an inappropriate way to 4 proceed in a deposition. That's not a ( 5 question. It's not proceeding in a question l 6 and answer form to have someone read a document 7 they don't reme mb e r. 8 MR. SELTZER: What I am trying to do is 9 find dut whether Mr. Pittman had the competence 10 to review this document for accuracy.. He signed 11 it, and I am just trying to determine whether 12 he was competent to sign it or whether he 13 j us t willy-nilly signed something which he had 14 no comprehension about and which was' divorced 15 from his areas of responsibility. 16 MR. BENEDICT: If you want to ask him 17 about a specific area and ask to what extent 18 that area was included in his purview, you are 19 welcome to, but the form of your quertion is 20 simply inappropriate and I am not going to 21 permit him to answer it because-it's unfair. L 22 It's also signed by two people from engineering. 23 BY MR. BENEDICT: 24 Q By early 1978 were you familiar from any 25 of your prior work with the rer.ponse of the fluid
1 Pittman 122 O . k . 2 systems and reactor coolant system which would cause 3 pressurizer water level to decline during an 4 ove rcooling event ? ' (' 5 THE WITNESS: Would you read that back?
. 6 Did you know that pressurizer water level Q
7 went down during an overcooling event? 8 A I believe I knew that. 9 Q In connection with any of'your 10 responsibilities for fluid systems and ah,sociated 11 mechanical equipment, did you understand by early
- 12 1978 whether there was any problem at all if
(~'
\
s 13 there was a loss of level low in a B&W pressurizer? 14 MR. BENEDICT: Could I hear th t again, 15 please? 16 (Question read back.) 17 A In response to that, I would have to say 18 that I have known for quite some time that it was j 19 not a desirable condition'to lose the pressurizer 20 level. 21 Q Why? 22 A Primarily you could end up flying blind l 23- as'far as knowing where the RCS inventory was.
) 24 Q ,
What'was the relationship between l 25 pressurizer indicated water level and reactor coolant - t
1 Pittman 123 ^
'D
' 2 system water volume?
3 A If you had an indicated pressurizer level, 4 you knew you had a good indication. That was a good (. 5 indication of where you were as far as water level. 6 Q You mean the pressurizer, when it had 7 water in it, gave a good indication of what th'e
, 8 total volume of water was in the reactor coolant ~
9 system? ! 10 A Well, it gave an indication pf the volume 11 in the reactor coolant system, and it gave an 12 indication that the bubble was in the pressurizer. 13 Q By "the bubble," you mean thh steam space? 14 A Yes. I 15 Q In other words, it was your understanding 16 in 1978 that so long as there was indicate level 17 in the pressurizer, the only place where there was a 18 steam space in the system was at the top of'the 19 pressurizer? ' 20 A I don't know that I thought it was the
. 21 only place. I knew it was an indication that the 22 steam space.was in the top of the pressurizer.
23 Q And that the rest of the system was .i (~]
'y,/
24 solid with water, right? 25 A I don't know whether I thought that or
.1 Pittman 124 s -N_)
O 2 didn't.think that. 3 Q Well, isn't it true that the rest of the 4 system had to be solid with water in order for ( 5 the pressurizer level to be an indication of the
-6 volume of water in the rest of the reactor coolant 7 system, isn't that something that.you recall knowing 8 in 1978?
9 MR. BENEDICT: Could I hear that again? 10 (Ques tion read back.) e 11 MR. BENEDICT: If you have a recollection. 12 A I don't know if I recall that or not. i [\
\/-
13 Q How could the wate r level in the ptossurizer 14 be an indication of the volume in the rest of the i 15 reactor coolant system if the~ rest of the reactor t
- j 16 coolant system was not solid with water?
17 MR. BENEDICT: I am not sure that -- I 18 don't understand the form of your qu[stion,
~
19 Mr. Seltzer. 1 20 How could it be? What are you asking
'l 4
21 him to.do, reason that out now?
-22 MR. SELTZER: No. In light of his 23 thinking in 1978.- I don't -think it. helps'for
,n I h 24 you and me to talk about it. If you-have an
\/
25 objection, you should state-it.
/
r- p - m = f +1 -w+-'
- . .. . ~.
d i 1 -Pittman 125
% ~
First, Mr. Pittman said that the level 2 3 of water in the pressurizer was'important i 4 because it was a good indication of the volume ( 5 of water in the reactor coolant system.
; 6 Then he said that he's not sure whether )
- j. 7 you needed to know that the rest of the reactor I- '
8 coolant system was solid with water in order } 9 f r water in the pressurizer to be a good
- l i
b 10 indication of the volume of water 4n the rest l of the reactor coolant' system. 11 12 Q So now I am asking you, based on what you 13 knew in 1978, isn't it a fact that for the~ water I-
, 1l4 level in the pressurizer to be a good indication l 15 of.the. volume of water in the-rest of the reactor
?
16 coolant system, you would have to be thinking chat 17 the rest of the reactor coolant system was water. I j 18 solid? 19 MR. BENEDICT: All right, I obj5ct 20 to the question because I object to your 21 characterization of his testimony. k-l 22 I object to the question because it 23 calls for.a hypothetical answer, and I object ) .. , 24 to the question because.it's been asked and l 25 . answer. l {
I 1 Pittman , 126 D s_/ 2- If Mr. Pittman can find a question in 3 there, he may answer it. 4 A My statement as to why I don't recall ( 5 what my thinking was on that subject in 1978 is very 6 truthful. I don't recall what my thinking was 7 at that time. 8 Q Did there come a point in time when you 9 first leanred that boiling in the reactor coolant 10 system could cause pressurizer water lev'ql to rise? 11 A I don't recall a time when that came to 12 my knowledge. 13 Q Since the Three Mile Island _ accident,
-14 you certainly have come to know that boili g or 15 saturation in the reactor coolant system can cause e .
16 pressurizer water level to rise, haven't you? 17 A Since the Three Mile Island accident? 18 Yes, I have. 19 g when there is boiling or saturation 20 occurring in the reactor coolant -sys tem, pressurizer 21 water level then is no longer a good indication of
'22 the volume of water in-the reactor coolant system, 23 isn't that right?
( )- 24 THE WITNESS: Would you-read that.back, 25 please?
. l
1 Pittman 127
~. 2 (Question read back. )
3 A I.would say it would leave'some question 4 as to the -- using that as an accurate indication. ( 5 Q And you have learned a question using 6 pressurizer water level as an accurate indication 7 of the volume of water in the reactor coolant system 8 only since the Three Mile Island accident, isn't 9 that a fair statement? 10 A Well, I don't know that I had put much 11 thought on that subject since the Three Mile Island 12 accident.' - 13 Well, you just articulated that Q 14 principle today. 15 Do you recall reaching that conclusion 16 at any time before the Three Mile Island accident? 17 A I don't recall reaching that conclusion,
~
18 no. l f 19 Q Would you turn to page 866 of GPU 366, 20 please. That's Attachment 2 to the document which 21 you reviewed for accuracy. 22 Do you see the graph there of pressurizer l 23 level and pressure during the April 23, 1978 transient
; 24 at TMI 25 A Yes, I.see that graph.
. i
1 I I Pittman 128 ) O 2 Q Do you see an arrow indicating the point 3 at which the operators throttled high pressure 4 injection? ( 5 A Yes, I see that arrow. 6 Q You didn't tell anyone at any time 7 during or after you had reviewed this document for 0 accuracy that you thought there was anything 9 incorrect about the operators having throttled 10 high pressure injection at that point i n', t i m e , did you? 11 MR. BENEDICT: I object to the form 12 of the question. O(,_/ 13 You may answer it. 14 A I never recall a discussion on that
~
15 subject. 16 Q You never told anybody that you thought 17 it was improper for the operators to have throttled 18 high pressure injection while pressure was still 19 ' decreasing, did you? 20 A Again, I don't recall even discussing that
, 21 subject.
22 Q You don't recall telling anybody that 23 you thought _it-was' improper for the operators at f~} s_/ . 24 Three Mile Island to have throttled high pressure 25 injection while pressure was-some 800 pounds below
o 1 Pittman 129 (~g t
\.)
2 the high pressure injection automatic actuation ! 3 point, do you?. 4 A I don't recall a discussion on that subject. l 5 Q You don't recall anybody saying to you in 6 words or substance that they thought after reviewing 7 this data that the operators had throttled high 8 pressure injection at the wrong time, do you? 9 A No. 10 MR. S E LTZ E R : - I would like to mark as 11 GPU Exhibit 575 a January 18, 1978 rendition 12 of SPR 372, signed on the first page by s- 13 Doug Holsted. 14 (J anuary 18, 1978 rendition of'SPR 372, , t 15 signed on the first page by Doug Holsted, 16 marked GPU Exhibit No. 575 for identification i 17 as of this date.) . 18 You said you discussed with Doug Holsted Q 19 his indication that the problem discussed in site
- 20 problem report 372 was'not considered applicable to-21 other contracts, is that right?
22 A That's what ~ I: stated,_right. 23 Q Had you seen this site problem report () i 24' on which Holsted had made his indication as to v-25 whether he did or did not consider this site problem
1 Pittman 130 2 report applicable to other contracts? 3 A As I stated earlier, the first time 4 I recall seeing this was shortly after the Three (' 5 Mile Island accident when this document was requested 6 and at that time I told people where to find it ' i 7 and I saw the document. I did not read the document. 8 Turn to the next page, please. Q 9 Do you see in the box -- and I am 10 pointing to down on the lower right-handtside -- where , 11 there is a notation for "Significant Deficiency, 12 Yes, No"? 13 A Yes, I see that box. 14 Q As you were familiar with this report 15 form, does that call for the preparer to' indicate 16 whether there is a significant deficiency within the 17 p eliminary safety concern procedures? - 18 MR. BENEDICT: You are'just ta king about 19 this as a form. I mean, you are not talking 20 about the-specific decision made here, right? 21 MR. SELTZER: That's right. 22 A Would you clarify the question, which form 23 are we referring to, this form or this form? r' (s)
~
24 EMR . BENEDICT: The second'page in the 25 lower right-hand corner. l-
-f
I I 1 Pittman 131 D> t 2 THE WITNESS: Can I hear the question? 3 Q Did you understand that the box that 4 calls for someonc to check off either yes, there is ( , 5 a,significant deficiency, or no, there is not a 6 significant deficiency is asking the preparer whether 7 there is a significant deficiency in the terms spelled 8 out in the preliminary safety concern procedures of 9 the Babcock & Wilcox Company? 10 A The preparer, no. That's the point of 11 confusion. 12 Q Was whoever prepared the response for this ON/ 13 s box supposed to do so in light of the definition of 14 significant deficiency in the preliminary safety 15 concern procedures? 16 A This box was put on this site problem 17 report form for the NSSE when he carried out his duties 16 in accordance with the site problem report procedure i ~ 19 to indicate that review. 20 Q The only question is was he supposed 21 to make a determination as to the-existence of 22 significant defielenc'/ based on the criteria in the 23 preliminary safety concern procedures..
~) 24 A' His responsibility _would have been had-
- l. ' (V l 25 he thought it was a significant deficiency to report, i
t
, , -u - -
l 1 Pittman 132 2 he would have indicated it yes or no in that block. , 3 Q I'am not even in the same room with you 4 on this question. 5 MR. BENEDICT: What Mr. Seltzer is asking, 6 the words that appear in that bcx, "Significant 1 7 Deficiency," and did you understand that prior 8 to the Three Mile Island accident that as those 9 words are used in that block, that they were 10 the same words and you had the samh definition 11 as is given in the PSC procedure of B&W. 12 THE WITNESS: Yes.
'"' 13 Q So that in filling out that box, whoever 14 filled it out was supposed to be applying the 4
15 preliminary safety concern procedures?
~
d 16 A Yes. His review would have been in 17 accordance with the preliminary safety concern , 18 procedures. . I 19 Q Now, you said it was the NSSE who would ! 20 fill out that box?. ( 21 22' A The NSSE was given that responsibility in the site problem report procedure.- He would'have l 1 23 likely had been the one to have filled out'that box. l 24 Q To the best of your knowledge, the NSSE 25 who would have been responsible for filling out that
l i 1 Pittman 133 (~ ' O) 2 box for this particular site problem report was 3 Doug Holsted, right? 4 A By what I read and what I see right now ( 5 in seeing Doug's signature, he would be the guy td 6 the best of my knowledge. 7 Q When you had your tete-a-tete with 8 Doug Holsted after the Three Mile Island accident, 9 did you discuss with Doug Holsted why he did not 10 perceive that this site problem report w'a s a matter 11 that rose to the level of a significant deficiency i 12 within the preliminary safety concern procedures?
\ 13 A I do not recall asking Doug.that question.
14 Q Did you ever hear of a fellow y the 15 name of Paul Perrone? e - 16 A Yes. 17 Q Did you ever meet him? . 18 A Yes. 19 Q Were you aware that Paul Perrone ever 20 reviewed site problem reports?. 21 A I was aware that he received some, and 22 I believe he reviewed some or several of those. 23 Q Let me show you what has previously been [x/ m
) 24 marked as GPU Exhibit 453. I would like you first p 25 to look at the next to the last page.. This is y g n w v - V -
l 1 l Pittman 134
~
V(~%. - 2 apparently another SPR where you and Holsted came s 3 together. 4 Do you see your signature about two-thirds i ( 5 of the way down on the left-hand side? i 6 A O.K. That appears to be my signature. 7 l Q Based on your familiarity with the 8 site problem report form, what does a signature appearing 9 in the space where your signature appears signify? 10 A .Again, it signifies to me thkt the site 11 problem report has been reviewed for technical adequacy 12 primarily in the practicality aspects of this 13 . resolution going to the field. 14 Prior to that review it would have 15 been reviewed from an engineering aspect by the , 1G engineering department and be formulated with those 17 guys. - 18 Do you have any recollection of revie~ wing Q 19 this site problem report? 20 A No, I do not. 21 Q Looking at the people who functioned 22 on this site problem report and viewing it'not in ; 23 terms of your having ~a nat'iral recollection of who I\ 24 participated on it because I understand that you don't
%-)
25 recall this spe ci fi c ally , which of the people on-here,
- 4. < - - - '- p w e 3 w
1 Pittman 135 e- ' Ug 2 j ust given the boxes.on which their names appeared and 3 your understanding of site problem reports, would have 4 had the responsibility for determining cross-contract i ( 5 applicability? 6 MR. BENEDICT: I will object to the form, 7 but you may answer it. 8 A Going back as I stated before, the 4 9 NSSE as determined by the site problem report 10 procedure would have been responsible to(make-that 11 determination. 12 That's Doug again? Q 13 A Yes. 14 Q On November 17, 1977, Paul Per one 15 wrote some SPR comments. 16 Is the form on which.Perrone wrote his 17 co mme nts something that was a standard-form for 18 use in conjunction with site problem reports? 19 A This was not a standard form, to my 20 knowledge. 21 Q Do you have any knowledge that Paul Perrone 22 made this form up just for his own use?
. )
23 A I have no knowledge about Paul's form on 24 ' this. f)% 25 Q. Have you ever caen an SPR comment form
, -- -- r n
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F W :~.. - , .,. 1 s , Pittm.an , 136 Da I - _ n s. ,,,
- x s s , . .
%n f ,.
. ., 2 o f this t;rpa that Paul Perrone has used?
i% . , MR._ BENEDICT:
~
3 Other than in the
.[ 4 ,p res en'ce- o f counsel.
('
\.
5 A I don't 're calf ever having seen it . ,
~
6 Q After you had signed the Davis-Besset ' N; 7 site problem report 366, did you ever learn that > - . s 8 somebody else within the B&W-companyShad, raised a-
,x ,.
9 question whether the modifications'that'were ...v 10 being made to the - Day 1.3-Be ss e pilo t operated relief I w s . 11 valve should also be inco.rporated in ot,her valves
~
12 to prevent similar fa. lures; from occurring N- , 13 elsewhere? 14 A- I don't~ recall that concern being raised, i 15 Q After an NSSE had determined whether
- i .
d6 l lanSPRhadcross-contract applicability, had you ever -
~
! 17 heard before the Three Mile Island accident of
.i , 18 somebody questioning that judgment and getting it 19 changed? l 20 A I can't recall any specific cases where 21 that was done.. 22 -(Recess taken.)' ' 1
, -23 BY MR. SELTZER:
[) V'
.24 7 Q Do you recall _that there came,a point
, .- 25 l in 1978 when-'Mr. LaBelle, the. head of the'sa'fety1 4 , c e de pa * ., = w w-*
1 Pittman 137 f\
\#
2 analysis unit, asked to be included more routinely 3 in the review of site problem reports? ( 4 A I recall an issue, along that time frame, (l 5 about that time frame, that someone in the safety 6 group had raised in wanting more immediate involvement 7 in site problem reports. 8 Q In fact, you went to a meeting where 9 that issue was discussed, isn't that right? 10 A I went to a meeting and discussed that 11 aubject.
~
12 Q Do you recall that as a result of'that-Os . . 13 meeting, changes were to be made in the site, problem s 14 report form? ' 15 A No, I don't recall thaa was an output of
. 'n 16 that meeting. ~ -
17 Q As a result of that meeting, do; you recall 18 a single thing that you did to get the . sa fe'ty ' analysis 19 unit involved more regularly in the review of site 20 problem reports?
- 21 A As I recall, whoever raised that concern, 22 whether it was Mr. LaBelle, raised the ' concern that 23 he wanted an immediate input and as I recall, there c
(~ 24 was not a form problem. There was j 'us t that he wanted
\_)) S
>\
25 to be involved immediately in that, and I believe E,">
, s 4 3 p.!4,
\ -l
1s Pittman 138 2 that came under Jim Phinney's area to make that
, 3 happen, so I don't know of any output that I had.
4 You didn't do anything to facilitate safety Q 5 analysis being involved more promptly or routinely {l 6 in the review of site problem reports? 7 A I don't recall anything. 8 In 1976 do you remember the issue Q. . 9 comine s up regarding what should be the steam 10 generator secondary side water level following a 11 trip? 12 A I remember discussions about that. () 13 Q Do you recall that during discussions 14 of that, a recommendation was made to reduce the 15 natural circulation level setpoint from 95 percent 16 to 50 percent? II A' I re c'all that it was changed. , 18 Q And that it was lowered, right?' 19 ' r. T believe it was lowered. 20 Q I tell you that I despair showing-you 21 documents because I don't think I found that a single
,22 document has refreshed your recollection on anything.
23 yet today. -
/~ 'A 24 MR. BENEDICT: I object to_that. I don't- ' N.)D 25 ,.
see what the point of tha t' statement was, b t.
/
l 'w, 1 o< ,
'r [ f('
; d, 61.ti 4 a . - --.
1 Pittman 139 (- 2 Mr. Seltzer. 3 I.f you want to babble, you are welcome to. 4 Q This is a 1974 memo from Karrasch to you 5 dealing with changing the setpoint on the steam {~ 6 generators. 7 MR. BENEDICT: It's been marked as GPU 8 Exhibit 517 previously. 9 What did you say the date was? 10 MR. SELTZER: February 7, 19,74. 11 MR. BENEDICT: Your previous questio'ns 12 related to something that happened in 1976.
) 13 MR. SELTZER: I misread the date.
14 The 4 doesn't come out that distinctly on 15 this, but I think that is a 4, 1974. 16 MR. BENEDICT: So in fact your question 17 related to something that happened in 1974?
~ 18 '
MR. SELTZER: Right. 19 Q Do you' recall getting GPU S17 from Bruce 20 Karrasch in or about 19747 21 A' I don't recall getting it. L 22 MR. SELTZER: I knew you were going to say , 23 l that. ' f 24 MR. BENEDICT: Is that on the record? (d~} 25 Q' At the time that you recal1~ consideration e -
1 Pittman 140
. 2 was given to reducing the natural circulation 3 setpoint on the B&W steam generators, do you recall 4 whether any consideration was given to whether (l 5 reducing the water level would have an adverse 6 effect during loss of coolant accidents?
7 A I don't know what was considered at that f 8 time in 1974. 9 Q Do you know that since the Three Mile 10 Island accident, the secondary side level setpoint 11 has been raised back up to 95 percent? 12 A No, I'm not even aware of that. ' 13 MR. SELTZER: I ddn't have any more 14 questions. 15 (Recess taken.) 16 MR. BENEDICT: I don't have any questions. 17 (Time noted: 4:00 o' clock p.m.,)
~
18 ROGER L. PITTMAN 19 20 subscribed and sworn to-before
- 21 me this day of , 1982.
22
-23 !
25
I 141 O
~
2 CERTIFICATE 3 4 STATE OF NEW YORK ) 4 ) SS. COUNTY OF NEW YORK ) ( 5 I, nancy A. PtmOLP H , a Notary
- 6 Public within and for the State of New York, do hereby 7
certify that the foregoing deposition of 8 R'OGE R' L . PITTMAN was taken before me 9 on June 28, 1982 ; 10 ', That the said witness was duly sworn before 11 the commencement of his testimony and that the 12 within transcript is a true record of'said testimony;
- 13 That I am not connected by blood or marriage 14 with any of the parties herein nor interested directly 15 or indirectly in the matter in controver'sy, nor am'I 16 in the employ of any of the counsel .
17 - IN WITNESS WHEREOF, I have hereunto set 18 TL. my hand this /d day of July . 1982. 19 20
-Qs 21 a r. ~
NANCY A( RUDOLPH ts /?e fr(d_ / f 22 '/ 23 24 25 l
142 I NDE X WITNESS PAGE Roger L. Pittman 3
. E XH I B I T S GPU FOR IDENT.
571 Four-page document, first of :3 d;g,ia. which is a memorandum to B. A. --1 i.~ '
*fgib Karrasch from D. F. Hallman, l
subject: " Operator Interruption l of High Pressure Injection (HPI) " dated August 3, 1978 Y 572 Resume of Roger L. Pittman 8 573 Revision 5 of the B&W site problem 20 report procedure 574
- Memorandum from Hal Baker to 63 Messrs. Pryor, Stanek, S uh r k'e ,
Pittman and others, subject: -
" Generic SPRs" dated May 9, 1978 575 January 18, 1978 rendition of -
129 SPR 372, signed on the first page by Doug Holsted P S h k k L O w .. .ie : * . ~;.u..a.rt.n . . , . r~. ~.:&.-~
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