ML20072H985
| ML20072H985 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 04/15/1981 |
| From: | Walters J BABCOCK & WILCOX CO. |
| To: | |
| References | |
| TASK-03, TASK-3, TASK-GB NUDOCS 8306290849 | |
| Download: ML20072H985 (145) | |
Text
290 dab /l UNITED STATES DISTRICT COURT
[
}
SOUTHERN DISTRICT OF NEW YORK LJ.
_x GENERAL PUBLIC UTILITIES CORPORATION, JERSEY CENTRAL POWER & LIGHT COMPANY, METROPOLITAN EDISON COMPANY and PENNSYLVANIA ELECTRIC COMPANY,
- r Plaintiffs, CIVIL ACTIC NO. 80 CIV.
-against-1683 (R.O.)
THE BABCOCK & WILCOX COMPANY and J.
RAY McDERMOTT &
CO.,
INC.,
Defendants.
x Continued deposition of The Babcock &
Wilcox Company, by JAMES FRANKLIN WALTERS, taken by Plaintiffs, pursuant to adjournment, i
at the offices of Kaye, Scholer, Fierman, Hays & Handler, Esqs., 425 Park Avenue, New York, New York, on Wednesday, April 15, 1981, at 9:35 o' clock in the forenoon, before Charles Shapiro, a certified Shorthand Reporter and Notary Public within and for the State of New York.
k.,
I DOYLE REPORTING. INC.
CERTIFIED STENOTYPE REPORTERS ses tem r u Avesue 8306290849 810415 PDR ADOCK 05000289 New YomK. N.Y.
10017 T
PDR TELEPHONE 212 - 867-8220
l 1
291 2
APPe a ran ce s:
3 KAYE, SCHOLER, FIERMAN, HAYS & HANDLER, ESQS.
Attorneys for Plaintiffs 4
425 Park Avenue New York, New York By:
RICHARD C.
SELTZER, ESQ.
6
-and-ANDREW MacDONALD, ESQ.,
7 of Counsel 8
9 10 DAVIS POLK & WARDWELL, E S Q S.'-
Attorneys for Defendants 11 One Chase Manhattan Plaza New York, New York 10005 12 By:
DANIEL F.
KOLB, ESQ..
13
-and-LINDA E.
CHATMAN, ESQ.,
14 of Counsel 15 16 17 Also Present:
18 DAVID TAYLOR 19
~
20 22 23 fM
' \\,_)
24 25 f
nc,
292 1
- !-~$
sl, n
2 J AME S F RA N KL I N WA L T E RS, i
3 resumed, having been previously duly sworn, 4
was examined and testified further as (l
5 follows:
6 EXAMINATION (Cont'd.)
7 BY MR. MacDONALD:
8 Q
You.are aware, Mr. Walters, that 9
your testimony today continues under oath?
10 A
I am.
(
I 11 Q
GPU Exhibit 132, Mr. Walters, that 12 you sent to Mr. Kelly on 11/10/77, you have a
- n\\ /
13 copy marked for R.
J.
Finnin.
14 What was Mr. Finnin's position in i
15 November of 19777 16 A
He was Supervisory Engineer of the Startup 17 Reactor Group and in the Plant Performance Service 18 Section.
r
~
l 19 Q
Which was your equal to the Operating i
20 Unit within PPS?
21 A
Yes.
22 MR. KOLB:
Would you read the l
23 question back.
L 24 (Record was read back.)
25 MR. KOLB The witness jumped in
l
?
I walters rx
(
2 with his answer but I will object as to i
3 f rm.
I don't think that question was 4
clear.
(
5 MR. MacDONALD:
I think the witness 6
understood it.
7 MR. KOLB:
Well, that is your S
opinion.
9 Q
Do you want to supplement your 10 answer?
e 11 A
Yes.
I understood that to be -- my answer 12 to mean that Mr. Finnin was a Supervisory Engineer s
13 equivalent to my position in the Operating 14 Reactor Section.
15 Q
Did you. send a copy of your 16 November 10, 1977 memo to Mr. Hallman?
17 A
No, I do not believe I did.
18 Q
Did you discuss the conkents of 19 the memo with Mr. Hallman?
20 A
I don't recall.
21 Q.
You don't recall that you did?
L 33 A
I don't recall that I did.
23 Q:
Do you have any recollection at all
[')
24 of discussing this subject with Mr. Hallman in or v
25 around the time that you wrote your memo to
\\
I walters 294
..Os
. i 1
2 Mr. Kelly?
3 MR. KOLB:
When you say "this 4
subject," are you referring to the memo?
1(-
5 MR. MacDONALD:
The subject that 6
was in the memo.
7 MR. KOLB:
The subject matter of 8
the memo?
9 MR. MacDONALD:
That's right.
4 10 A
I do not recall at this time having 11 conversations with Mr. Hallman about this particular 12 matter.
[)
\\_-
13 Q
Did you speak to Mr. Finnin at all 14 regarding the subject matter of GPU Exhibit 1327 15 A
I don't recall either speaking to him or 16 not speaking to him about this matter.
17 Q
The particular memo or"even the 18 subject matter dealt with in the memo?'
19 MR. KOLB:
I would ask you to break 20 that down.
It is really two questions.
21 Q
You don't recall speaking to 22 Mr. Finnin regarding this memo specifically, l
23 is that correct?
l
' l 'I ~
24 A
That's correct.
'w !
i 25 Q
Do you recall speaking to Mr. Finnin
^
a 1
Walters 295
~Q Y'/ '
2 regarding the subject matter of the memo, GPU Exhibit 1327 3-4 MS. CHATMAN:
He has answered that
('
5 question.
6 MR. KOLB:
I think that's correct.
7 And I think there is a pattern that has 8
been developing here in our sessions and 9
you are asking the questions over and 10 over again.
.I would ask you not to do that.
11 MR. MacDONALD:
He answered the 12 question as to whether or not he spoke O(/
13 to him about the memo, about the subject 14 matter surrounding the memo.
I think that 15 he has not answered that question and --
16 MR. KOLB:
I disagree with you, t
.17 I think he answered that questlon first 18 and that you are just asking him to give 19 you another answer to the samePquestion.
20 Now, I will let him answer this 21 time but I really do encourage you not k.
22 to ask duplicate. questions.
This deposition f
23 has gone on long enough as it is.
It
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24 doesn't help us to go over the same
%/
25 subject matter.
A
1 t
T-1 Walters 296
\\
2 Mr. Walters, can you answer the 3
same question again?
4 A
I believe that I did have discussions or
(
5 a discussion or a conversation with Mr. Finnin at 6
sometime'about the general concern or general 7
information in this memo.
8 Q
Do you recall when that discussion 9
took place?
10 A
Yes.
1 11 Q
When was that?
12 A
Somewhere around the middle of November
(^h
\\/
13 of
'77.
14 Q
Where was the discussion, where 15 did the discussion take place, where was the J
16 location?
17 A~
In between his and my office 1.n the 18 building.
19 Q
How close are your offides?
20 A
They are adjacent.
21 Q
was there anyone else present 22 during this discussion?
23 A
I don't recall that there was anyone else
-j.,-)
24 present.
.Q) 25 Q.
-Did Mr. Finnin seek you out to
t 1
Walters 297
/~T V~
2 initiate the conversation regarding this 3
subject?
4 A
No.
('
5 Q
Had'you sought him out to initiate 6
the discussion on this particular sabject matter?
7 A
Yes.
8 Q
Did you want to obtain his thoughts 9
on the subject matter contained in your letter 10 to Mr. Kelly in November of 1977? g 11 A
Well, I don't want to mislead you.
12 I think my conversation was with N/
~13' Mr. Finnin -- was of the nature of the SPR or the t
14 data of_that particular Davis-Besse transient 15 that Mr. Kelly was talking about in his memo.
16 Q
What was the substance of what 17 you said to Mr. Finnin during the c o u,r s e of that 18 conversation and what he said to you? ~
19 A
I don't recall the substance. "The only 20 thing that I recall is asking for some information.
- 21 Q
Prior to your discussion with 22 Mr. Finnin, had you read any portions of the 23 SPR'on Davis-Besse?
i
[
}
. 24 A
Not'that I recall.
\\_/
25 Q
During the. course of your discussion y
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y----w tw
,--y 9++
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I 1
Walters 298
/%
N.
2 with Mr. Finnin, did you discuss the subject 3
matter contained in the SPR for Davis-Besse?
f 4
A I believe I did but I'm not sure.
(
5 Q
Did you review the document with 6
Mr. Finnin?
7
'MR.
KOLB:
Meaning the SPR7 8
MR. MacDONALD:
The SPR.
9 A
That's what I'm not sure of, that the i
10 data that we looked at was indeed an SPR.
It i
11 wasn't the form, if I recall, the SPR form that 12 I reviewed.
C'-)
13 Q
What was the form that you reviewed?
14 A
It was, as best as I remember, it was 15 some Xerox of graphs from the control room at 16 Davis-Besse and I believe a sequence of events 17 or something of that nature.
18 Q
What type of.information was
~
19
.contcined on the graphs from the control room 20 at Davis-Besse?
21 A
I don't recall the details.
There were 22 the trend recorder data of two or three variables.
23 Q
What'were those variables?
()
24 A
I don't recall how many of them there 25 were that I looked.at at that time.
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,,e
.f-1 Walters 299 (3
V~
2 Q
Were the variables, did they contain 3
parameters of pressure level, temperature and 4
time?
(
5 A
The only one I recall was RCS pressure 6
versus time but there may have been others.
7 Q
In your discussion with Mr. Finnin, 8
what information did you ask him for regarding 9
the Davis-Besse transient?
10 A
I don't specifically recall what I asked 11 him for.
12 Q
In response to your asking for 13 information, did he produce the graphs from the 14 control room and the sequence of events?
15 A
Yes, I believe he did at some point in 16 time.
17 Q
Is the sequence of even,ts that you 18 reviewed of the Davis-Besse September 1977 19 transient a printed version of the sequence of-l l~
20 events?
l 21 MR. KOLB:
Would you explain what l
22 you mean by " printed"? RDo you mean printed I
l 23 in the formal sense of printing?
l-
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24 MR. MacDONALD:
Typed or printed v
l 25 as opposed to handwritten.
y r>
yw w n-nw4>r
,rv-w w
y,(q yy,r e--,
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-y+yg-4m-a
I 1
Walters 300
- (_/.
2, MR. KOLB:
All right.
3 A
No, I bslieve they were actually 4
handwritten.
1 t.
(
5 Q
Do you know who had authored that 6
sequence of events?
.7 A
I do not recall.
1 8
Q Did Mr. Finnin state or tell you 9
who had authored that sequence of events?
10 A
I don't recall that either.t 11 Q
But it was a sequence of events 12 from the SPR on Davis-Besse?
1
/
13 A
No, I'm not sure that they were the 14 sequence of events, if there was one, that was I
15 attached to the SPR.
I accepted them as a l
16 sequence of events or revised or limited portion 17 of it, if there was a computer printout.
i 18.
Q The sequence of events that you
)
19 looked at, how far in time were the eFents 20 described on that handwritten sequence?
21 MR. KOLB:
I think that is confusing.
L i-22 What do you mean by "far in time"?
i 23 MR. MacDONALD:
I will rephrase
[
)-
24 the question.
'Qf
-~
L
' 25 Q
How long into the Davis-Besse a--
s
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1 s
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'l Walters 301 s
.f) 15 -
2 transient in terms of the time evolution of that 3
particular September 1977 transient did the 4
sequence of events that you looked at_with
('
5 Mr. Finnin go?
6 A
I don't recall.
7 Q
Let me hand you a copy of a 8
handwritten sequence of events that is' attached 9
to the site problem report of 10/11/77 for the i
10 Davis-Besse September 24, 1977 transient and I i 11 will ask you to look at that and tell me whether i o
12 or not that was the sequence of events that you
\\_)
13 saw and discussed with Mr. Finnin during that 14 discussion with him?
15 MR. KOLB:
Is the document you have 16 handed the witness an exhibit?
j 17 MR. MacDONALD:
No, it isn't 18 MR. KOLB:
I think if the witness 19 is going to examine a document ~'it ought 20 to be marked as'anx exhibit.
j 21 MR. MacDONALD:
Before I mark it, 22 I want to know whether or not it i.s worth 23.
examining him on, if he saw it during the i-
}
24' course of his discussions.with Mr. Finnin.
%J-25 MR. KOLB:
If you'are going to ask i
l'.
n-w-
+ - -
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,. c vr e
w,
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I Walters 302
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2 a witness about a document, it has to be 3
clearly marked so the record will be 4
certain as to which document you showed
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5 him.
2
~
6, MR. MacDONALD:
We have identified 7
the document.
I don't think --
8 MR. KOLB:
The document has'--
T 9
MR. MacDONALD:
There is not a big i
10 deal to marking it.
l 11 MR. KOLB:
It has many pages and 12 the purpose in marking exhibits at a 5
13 deposition is to assure that there is no 14 confusion later.
r 15 MR. Ma; DONALD:
We will mark what i
16 has previously been described as GPU 17 Exhibit 133.
~
18 (Handwritten' sequence of events 19 attached to Site Problem Report of 20 10/11/77 for the-Davis-Besse S ep t e mb e r. '2 4,.
s
.i 21 1977 transient marked GPU Exhibit No. 133 22 for identification, as of this date.)-
l 23 '
MR.,KOLB:
Now, can we have the
! (~'I
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24 question read back, please.
U 25 (Record was read back.)
-6
.3 4
$.~w 1
Walters 303 g
2 MR. MacDONALD:
It is page 15 of 85 3
which has the Bates number D42341.
4 MR. KOLB:
Yes, that is a further 7
('
5 page.
(
6 Do you understand the question?
A 7
Q Was this a sequence of events that 8
you discussed with Mr. Finnin?
9 A
We are talking about this one page only 10 (indicating)?
Are we talking about this one page 4. 4 11 only?
12 Q
Yes.
Was this part of or was this 13 any part of the sequence of events that you and 14 Mr. Finnin looked at and discussed during the 15 discussion we have just been speaking of?
16 A
I'm not certain that it is.
17 Q
Does it appear to you to be the 18 handwritten document that you did discuss with 19 Mr. Finnin during that discussion?
~
20 MR. KOLB:
What do you mean does it 21 appear to him to be?
I don't know what k.
22 you are getting at.
23 MR. MacDONALD:
Does he believe that 2,(
'(k 24 this was, as he reads it now, the handwritten i
- ( /
25
. document that he discussed with Mr. Finnin.
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1
~
1.
t s ',.. i
304 I
Walters T'
Y_)N.
2 MR. KOLB:
He says to you in 3
testimony that he is not certain whether 4
this is the document and then you ask him
(
5 whether he believes it is the document?
6 I think you ought to explain to him what 7
the difference is between what he believes and what he can confirm as a certainty.
8 9
MR..MacDONALD:
He said he is not 10 certain.
I want to examine-whether he has 11 any recollection at all as to whether or 12 not this was the document that he discussed
['T
\\l 13 with Mr. Finnin during the discussion that 14 we have been speaking of for the last ten 15 minutes.
16 MR. KOLB:
Is that just another way 17 of asking him whether it could be?
18 MR. MacDONALD:
It is wbether he 19 has any recollection at all as lo whether 20 or not this is a document that he and 21 Mr. Finnin saw and discussed during the 22 discussion that we have been speaking of 23 over the last ten minutes.
O(
~24 MR. KOLB:
Mr. Walters, do you 25 understand the difference between this
-c.
l 1
Walters 305 jm a
\\/
2, question, assuming there is a difference, 3
and the question you answered before?
e 4
THE WITNESS:
No.
l 5
Q Let me ask you, do you have any 6
recollection at all as to whether or not this 7
document, page 15 of this document, is a copy of 8
the document that you and Mr. Finnin discussed 9
in or about November of 1977 in the hall outside 10 your office?
e 11 A
I just do not recall that this is in fact 12 the document I saw.
O
\\/
13 Q
Does it reflect the parameters and i
14 the sequence of events as you recall discussing 15 it with Mr. Finnin in mid-1977 around your 16 office?
17 MR. KOLB:
Is your question whether 18 the detailed information that ippears here 19 is the information he discussed, if he 20 recalls, at that time?
4 21 MR. MacDONALD:
Is the information 22 that appears on that page information that 23 he recalls as a chronological sequence of
(~}-
24 events discussing with Mr. Finnin in that V
E 25
' conversation outside his office?
L t
i i
1 1
Walters 306
['
)
/
' ' " ~
2 HR. KOLB:
You can answer that 3
question, if you remember.
4 MR. MacDONALD:
It is always if he
(
5 is able to, I believe.
6 A
I just have no recollection that this is s
7 the exact document I saw.
8 Q
Whether or not it is the exact 9
document, does the information contained in this 10 document parallel the discussion that you had 11 with Mr. Finnin regarding the sequence of 12 events of the Davis-Besse transient?
f,Mh 13 A
I believe it does.
14 Q
Did you discuss with Mr. Finnin 15 that the electromatic relief valve was stuck open 16 at Davis-Besse and that RCS pressure decreased as 17 No. 4 of page 15 of this document shows?
18 MR. KOLB I will object' as to form.
19_
You say it shows it.and you are~ implying s
20 that it states the facts as they were and 21 I don't think you have yet established 22 that that is the case through the testimony 23 of this witness.
Also, the question is
'[
')
24 long and I would appreciate it if you could x_/
25 take it in parts.
1 Walters 307
\\
2 Q
Did you discuss with Mr. Finnin 3
outside your office in or about mid-November that 4
the electromatic relief valve or the PORV had
(
5 stuck open at Davis-Besse?
6 A
I don't recall at this time.
7 Q
Do you recall whether you discussed 8
that the RC system pressure decreased during the 9
Davis-Besse transient?
10 A
I don't recall that either.(
11 Q
Do you recall discussing whether 12 or not the high pressure injection pumps were b
\\~
13 initiated during the Davis-Besse transient?
14 A
I don't recall that subject matter either.
15 Q
Did you discuss whether or not 16 pressurizer level rose at all during the 17 Davis-Besse transient?
18 A
No, I do not remember that discussion 19 either.
20 MR. MacDONALD:
Let's take a short 21 break.
22 (Recess taken.)
23 BY MR. MacDONALD:
m(Y 24 Q
Mr. Walters, at the time you had i
25 your discussion with Mr. Finnin in or about e
l9 1
Walters 308 2
mid-November 1977, it is a fact, is it not, that 3
you knew on the basis of Mr. Kelly's November 1,
4 1977 memorandum that the pilot operated relief
(
5 valve at Davis-Besse had stuck open?
6 MR. KOLB:
Is your question whether 7
he had read that statement in Mr. Kelly's 8
memo or whether he was in a position to 9
verify that as a fact?
10 MR. MacDONALD:
He knew that from 11 reading Mr. Kelly's memo.
12 Q
Did you not?
. )
j 13 MR. KOLB:
If that is your question, 14 I object to it as being inappropriate 15 because you are trying to get him to assume 16 that the facts are correct' based on 17 secondhand information.
4 18 If you want to ask him 'what he 19 read, what the secondhand information 20 consisted of, that is appropriate but he 21 is not in a position to verify directly 22 what happened an'd you shouldn't ask him 23 as if.he was.
24 -
Q Did you understand, Mr. Walters, 25 from Mr. Kelly's memo when you received a copy of
1 Walters 309
[h v'
2 it that the pilot operated relief valve at 3
Davis-Besse during the September 24, 1977 4
transient stuck open?
l 5
A Yes, I believe I was aware of that 6
statement.
7 Q
. Were you also aware that the high 8
pressure injection system at Davis-Besse had 9
automatically initiated as stated in Mr. Kelly's 10 memorandum?
(
11 MR. KOLB:
My objection is still 12 the same.
If you want to ask him what he
(~T kl 13 understood from Mr. Kelly's memo or what 14 the memo said or whether he read it, that's 15 fine,but just as a matter of principle, 16 it is inappropriate for you to ask the 17 witness questions that ask him to verify 18 facts when you know his.only i$ formation 19 is secondhand.
~
20 MR. MacDONALD:
I am not asking him 21 to verify the fact.
I am asking from his L.
22 reading of Mr. Kelly's memo, was it his 23 understanding that the high pressure fi 24 injection system'had automatically initiated m.J 25 at Davis-Besse.
1.
4 1
Walters 310
~'
.(d.
i 2
A Yes.
3 Q
Was it also your understanding that 4
the operator had stopped HPI when pressorizer
(
5 level began to recover without regard to primary 6
pressure?
7
.MR.
KOLB:
Is this now based just 8
on the reading of the Kelly memo or --
9 MR. MacDONALD:
His understanding 10 based on what he read from Mr. Kelly's 11 memo.
12 MR. KOLB:
Mr. Walters, do you
(')s
\\-
13 understand you are being asked for your i
14 separate understanding, if;you had one, 15 based on reading Kelly's memo?
i 16 MR. MacDONALD:
His understanding 17 when he read Mr. Kelly's memo.
have no separate understandibg at
'18 A
I the 19 time of' reading -- separate from reading 20 Mr. Kelly's memo at that time.
21 Q
You understood, did you not, when
'22 you read Mr. Kelly's memo it was your understanding 23-
' based on reading that memo that the operator
, ('s,)
24_
stopped HPI when pressurizer level b'egan to t
c E5 recover?
f 8
1 Walters 311 (D
\\'d 2
MS. CHATMAN:
I think'that is the 3
same question.
4 A
I read that in Mr. Kelly's memo if that is
(
5 the question.
6 Q
Did you understand from reading 7
Mr. Kelly's memo that the operator stopped HPI 8
when pressurizer level began to recover at 9
Davis-Besse?
10 MR. KOLB:
I think he has now 11 answered that question as best he can 12 several times.
I think if you go on s
I
/
13 and inquire generally about his 14 understanding at the time, you will begin 15 to understand why his answer is what it is.
16 He has given you his best answer to that 17 question, I believe, and I.have allowed you 18 to ask him several times in different ways 19 because I understand we are in-an area of 20 some significance to the case.
21 Q
You also understood from Mr. Kelly's 22 memo that the transient at Davis-Besse continued 23 on with boiling in the reactor coolant system
/s 24 after the operator had terminated HPI?
V 25 MR. KOLB:
Would you read.the
-1 Walters 312
(
l 2
l question back, please?
3 (Record was read back.)
4 A
I only recall having read Mr. Kelly's memo
(
5 and what is stated in the memo.
6 Q
Did you subsequently have,any 7
understanding.different from the understanding 8
that you gained from the words that were stated 9
in Mr. Kelly's memo of November 1,
19777 10 MR. KOLB:
I will object to that 11 because you are assuming a degree of 12 understanding from Mr. Kelly's memo which
[\\/
13 may be somewhat inconsistent with the 14 testimony that he has given and I would 15 ask you also to break the question down 16 because you are really focusing on two 17 points in time.
18 MR. MacDONALD:
I think'he already 19 t'estified there were certain th'ings he 20 understood from reading Mr. Kelly's memo.
21 All I am asking is at any time after the 22 date of this memo did he develop any 23 understanding different from what he gained
<mv) 24 from his reading of Mr. Kelly's memo about
-i 25 the events that occurred on September 24,
1 Walters 313
/'\\
\\
l
#~
2 1977 at Davis-Besse, 3
MR. KOLB:
That is a slightly 4
different question and I would only ask
(
5 now that the reporter read that question 6
back so the witness has the reinterpretation 7
of the question clearly in mind.
8 (Record was read back.)
i 9
A As a result of other information, I made 10 an evaluation and I do not recall whether it was 11 different from or agreed with Mr. Kelly's memo 12 at this time.
13 Q
You made an evaluation as to the 14 sequence of events at Davis-Besse?
15 A
Yes, I think that could be -- that 16 terminology could be used.
~
17 Q
How did you,come to that evaluation?
18 A
It was,the best I remember, it'was as a 19 result of the information that I obtai~ned from 20 Mr. Finnin in the form of graphs of variables, 21 Plant variables.
22 Q
What was the evaluation that you 23 formed regarding the sequence of events at l
V[ )-
24 Davis-Besse as a result of that discussion with 25 Mr. Finnin?
. ~.,,
1 Walters 314 O) '
\\
2 A
As a result of examination of the graphs 3
r plots, I formed an evaluation that the operators 4
had indeed found themselves in a problem, they
(
5 evidently knew that they had a LOCA, went about 6
their job in a manner at which I think they were 7
properly trained or had experience and that there 8
was occurring some problem.
They found what the 9
problem was, corrected that problem and then 10 proceeded to stabilize the plant. t 11 Q
You stated that the operators went 12 about their job as they were trained or as their
[ )
\\d 13 experience had taught them to do at Davis-B e s s e.
14 What led you to that belief?
15 MR. KOLB:
His testimony was 16 specifically that he had reviewed some 17 graphs and had evaluated the s,ituation.
.18 Now, the record speaks Eor itself 19 as to his statement of that evaluation and i
20 you are certainly entitlted to ask him now
- 1 what'he did to reach the conclusion but I k
23 think that we should leave the statement on l
23 the record as it is and not have you in i -(G) 24 your question state your understanding of 25 what he said, i
f.
r
1 Walters 315 O} '
f 2
If you just ask him what he based 3
his conclusion on, we can go forward.
4 MR. MacDONALD:
I am not asking him
(
5 to restate anything.
What I am asking him 6
to do is to explain the words that he 7
used and phrases that he used in his 8
answer and I am attempting to understand 9
what he meant when he said that the 10 operators at Davis-Besse went about their 11 job as they had been trained and as their 12 experience had taught them.
13 I am just attempting to learn from 14 Mr. Walters indeed what he meant by using 15 that phrase.
16 A
Well, my phrase simply means that I believe 17 on a counting of the situation, based on much the op'rators would 18 dialogue over many years, that e
19 respond as I though they simply shoul'd have.
20 MR. KOLB:
Will you just read the l
21 answer back, please.
22 (Record was read back.)
23 THE WITNESS:
I think I meant
)
24
" believed."
v 25 Q
You stated in your last answer k'
r 1
Walters 316 f}
\\ l' 2
" based on dialogue with people."
3 Was this dialogue with people within 4
B&W over a number of years?
l 5
A They were some of the people.
6 Q
Do you have any specific people in 7
mind?
8 A
No.
9 Q
You said " responded as they should 10 have."
g 11 Did you mean by that that they 12 responded as they should have in all aspects of lN/
13 the September 24, 1977 Davis-Besse transient?
14 MR. KOLB:
As he then understood it?
15 MR. MacDONALD:
Yes, at that time.
16 A
Based on my evaluation of the information, 17 I thought they had responded as they should have.
18 Q
That information was information that 19 you had gleaned from Mr. Kelly's memorandum and 20 the discussion you had with Mr. Finnin, is that 21 correct?
22 MR. KOLB:
He stated before what 23 the basis was for his understanding and l.
[~)
24 you are just asking the question again and LJ 25 you are putting it in a way which is i
i 1
Walters 317
(~3 2
different from his testimony before.
l 3
MR. MacDONALD:
No, I think that he 4
stated that there were some different
(
5 sources, he had a discussion with Mr. Finnin 6
and that indeed some of this evaluation was 7
done at that point in time.
I want to find 8
on the basis of what information was that
.9 evaluation formed up until mid-November 10 1977.
t 11 MR. KOLB If you put the question 12 that way then.
I think it is repetitive
(~/',
s 13 but again because we are in an area of 14 some significance, I will let him answer 15 again but don't paraphrase it in a manner 16 that is inconsistent.
Don't try to 17 paraphrase the testimony.
Just ask him-18 straight out.
~
19 MR. MacDONALD:
Let's just deal i
20 with questions and answers.
21 Q
Mr. Walters, this belief that you km 22 had that the operators at Davis-Besse had 23 responded as they had been. trained and as they
(")
24 should have was based on information that you had V'
25 learned up through the middle of November of 1977, i
i n
1 Walters 318
[
2 is that correct?
3 MR. KOLB:
I think that is very l
4 confusing.
You are asking whether some
(
5 information he got during that period is 6
the basis for his evaluation or are you 7
..asking him whether all the information 8
he got?
I don't know what you mean.
9 I think if you just ask him the question 10 on what basis he got it, we, don't have 11 to argue between us.
It is so simple.
12 Q
Mr. Walters, your belief that the f'.
x 13 operators at Davis-Besse responded in the manner 14 they should have in the light of their training 15 experience was based on what?
16 A
My evaluation of the couple of graphs 17 or data that I had received, I think, from 18 Mr. Finnin.
19 Q
Was it based on any other
-20 information that you had available to you at that 21 point in time in mid-November?
22 A
I do not recall.
23 Q
In GPU Exhibit 132, in the last
. f')'i 24' paragraph, the second page, you state, "If you
\\_
25 intend to go solid, what about problems with
i 1
Walters 319
\\'~
2 vessel mechanics."
3 What did you mean by the phrase 4
" problems with vessel mechanics"?
(
5 A
I had nothing in particular in mind about 6
associated with vessel mechanics as such.
7 Q
What did the phrase " vessel 8
mechanics" mean?
9 A
I was simply saying was there a problem 1
10 with overpressurization of the system under 11 solid water condition.
12 Q
That is what you meant by the b) i,_
13 phrase " problems with vessel mechadics"?
I 14 A
Yes.
l 15 Q
what kind of problems from 16 overpressurization of the system woul'd arise in 4
17 your mind when you wrote this in November of 19777-18 MR. KOLB What kind of ~ problems 19 did he have in mind, is that the question?
20 MR. MacDONALD:
That's correct.
21 A
I was asking what would be the problems 22 if we did have an overpressuri=ation of the 23 system, did this mean that there would be
[].
24 resulting problems that we would have'to work out V
25 before the utility could return to power?
Mainly.
4
1 Walters 320 p
l 2
paper work.
3 Q
Were you concerned that in an 4
overpressurization situation, that the code
(
5 safety valves would be called upon to open?
6 A
Yes, I was concerned that the code safety j
l 7
valves would be forced open.
8 Q
In your next sentence, you state, 9
"Also will the code and electromatic valves 10 relief water (via steam) at significant flow rate 11 to keep the RCS from being hydroed."
12 Did you know at the time that you
(~)h
\\_
13 wrote GPU Exhibit 132 whether or not the code 14 and electromatic relief valves were able to 15 pass water in its liquid state?
16 A'
I don't recall ever asking mys' elf that 17 question as you state it.
18 Q
Do you know whether they were 19 tested for their ability to have water flow pass 20 through them?
21 MR. KOLB:
At what point in time?
22 MR. MacDONALD:
At the point in i
23 time he wrote the memo.
/~'T o4 MR. KOLB:
Do you mean were they k,/
25 tested at that particular point in time or
12 1
Walters 321 I
3 2
do you mean had they been tested before
~
3 the time of the memo to the extent he knew?
4 Which do you mean?
(
5 MR. MacDONALD:
At the time he wrote 6
the memo, did he know that these valves 7
had been tested prior to that point in time
-8 for their ability to pass water.
9 MR. KOLB:
I will object to the 10 way you put it because you have assumed 11 a fact, you have assumed that they were 12 tested before.
If you simply change it 4
(~T k/
13 to did he know whether they had been tested 14 before, I would have no objection.
15
~
MR. MacDONALD:
I will substitute 16 "whether."
~
17 A
No, I did not know whether they had been 18 tested or not for solid water flow.
19 Q
Did you know at this poi'nt in time 20 whether they had been tested for steam flow?
21 A
I don't think I recall seeing a document 22 that I drew that conclusion from either.
l 23 Q
Whether or not you say a document,
-['N 24 did you have any basis on which to draw that
~-)
l 25 conclusion from discussions or conversations or l~
i
~
4 1
Walters 322
/~')
5' 2
anything else?
3 A
Yes, I think I was aware that this -- that 4
they were tested for steam flow.
(
5 Q
What was the basis of that belief?
6 A
An acceptance of the design function of 7
the valve.
8 Q
The design function of the valve 9
was to pass steam?
10 A
That's correct.
11 Q
Did you discuss with Mr. Finnin 12 in the conversation outside of your office in O
\\ms 13 mid-November of 1977 any problems that r
14 overpressurization of the RCS might cause?
15 MR. KOLB:
Will you please repeat 16 the question.
17 (Record was read back.)
18 A
I do not recall any conversation with 19 Mr. Finnin about overpressurization problems.
20 Q
You are saying you don't recall 21 during the course of the conversation you mentioned 22' earlier discussing. with Mr. Finnin any problems 23.
regarding overpressurization of the RCS?
/'
24 A-I do'not recall those.
N ]T 25 Q
Did you discuss with Mr. Finnin
i 1
Walters 323
(\\~ ~
2 during that conversation the ability of the 3
code or electromatic relief valves to pass water 4
in its liquid state?
(
5 A
I do not recall a conversation of that 6
type.
7 Q
In or about the middle of November 8
of 1977, what was the normal operating pressure 9
of a 177 FA lowered loop plant?
10 A
The normal operating pressure is 2155 psig.
11 Q
At that same point in time, what 12 was the pressure at which the code safety valves 13 would open?
14 A
I believe it was approximately 2500 psig.
15 Q
Is it true that in order to hydro
~
16 the system and open the code safety valves, the 17 pressure in the RCS would have to rise above 18 2500 psig?
19 MR. KOLB:
Are you asking whether 20 that was known to him at the time?
21 MR. MacDONALD:
In or about November 22 of 1977.
23 MR. KOLB:
Are you asking whether
[']
24 that was true under all conditions?
'wJ 25 MR. MacDONALD:
To open the code l
t
l 1
Walters 324
^
t
\\
2 safety valves, yes.
3 MR. KOLB:
Now, can we have the 4
question again.
(
5 MR. MacDONALD:
This colloquy and --
6 I will restate it if he is going to have 7
trouble understanding it.
8 Q
In or about November of 1977, in 9
order for the RCS to be hydroed and the code safety 10 valves to open, did pressure in the. RCS have to 11 rise above 2500 psi?
12
.A For the code safety valves to open, the b\\._/
13 pressure has to rise above 2500 psi.
14 Q
So to hydro, using your terminology, 15 the RCS, the pressure in the RCS during an 16 overcooling transient would have to be above 17 2500 psi?
18 A
Equal to or greater than.
19 Q
Isn't it true that in Mr. Kelly's 20 prescription in GPU Exhibit 131, part (b), that 21
-that permits the operator to terminate high 22 pressure injection if primary pressure is above 23 1600 psig?
- l' ) -
24 MR. KOLB:
Are you asking for what
\\_j 25 -
he understood at the time?
k
F 1
Walters 325
\\
v 2
MR. MacDONALD:
That's correct.
3 A
That is not the way I read that.
4 Q
In Mr. Kelly's memo, subsection
(
5 (b), "Once h'igh/ low pressure injection is 6
initiated, do not stop it unless," and it goes 7
on, "TAVE is stable or decreasing and pressurizer 8
level is increasing and primary pressure is at 9
least 1600 psig and increasing."
10 Do you see that portion of 11 Mr. Kelly's memo?
12 A
Yes, I do.
N
)
13 Q
Isn't it true that during an 14 overcooling transient that before the pressure 15 reaches 2500 psii that the operator would be 4
16 Permitted under Mr. Kelly's prescription to 17 terminate high pressure injection? ~
18 MR. KOLB:
Didn't we go over this 19 yesterday?
20 MR. MacDONALD:
Not the particular 21 point.
22 MR. KOLB:
I have a different 23 recollection, I think we covered all.that, i
[/
t 24 Also, again I would like.to find out are w
25 you'asking about his understanding at the t
]
1 Walters 326
. Ng -
2 time?
3 MR. MacDONALD:
That's correct.
4 MR. KOLB:
I think the witness has
(
5 covered this ground.
6 Do you understand the question, 7
Mr. Walters?
8 THE WITNESS:
I don't believe so, 9
it's such a lengthy question.
10 MR. MacDONALD:
I will restate it.
11 Q
During an overcooling transient, 12 before the pressure in the reactor coolant system Q\\
13 reaches 2500 psi and the system goes solid, did 14 not Mr. Kelly's prescription permit the operator 15 to terminate high pressure injection in such a 16 situation? And I am talking about Mr. Kelly's 17 prescription (b) in GPU Exhibit 131..
18 MR. KOLB:
It sounds to me like
~
19 you are asking him whether he has an 20.
opinion on that subject today.
21 MR. MacDONALD:
At that point in L.
o2 time.
We are dealing in and around November 23 of 1977.
~(w-
~_j 24 MR. KOLB: 'Did he have an p
l l
25 understanding, on your. question, at that e
e-
8 1
Walters 327
{
V-2 time?
3 MR. MacDONALD:
That's correct.
4 A
I don't recall making an evaluation of
(
5 that at that time.
6 Q
Have you since made any evaluation 7
of whether or not before the pressure in the RCS 8
system reaches 2500 psi and the system goes solid, g
whether Mr. Kelly's prescription in his November 1,
10 1977 memo would permit the operator to terminate 11 HPI in an overcooling transient?
12 MR. KOLB:
The question calls for Q(_/
13 a yes or no answer.
14 A
No.
15 Q
Have you ever discussed with anyone 16 at B&W whether or not Mr. Kelly's prescription
~17 in item (b) of GPU E9:hibit 131 would permit 18 operators to terminate HPI before thc' system goes 19 solid in an overcooling transient?
~-
20 MR. KOLB:
All these questions are 21 apart from counsel?
22 MR. MacDONALD:
Yes.
23 A
I don't recall.
,[^Y 24 Q
You don't recall having.any such N./
L 25 discussion?
't E
1 1
Walters 328 I\\'
2 A
That's correct.
3 Q
At the time you read GPU Exhibit 131, 4
did you understand what Mr. Kelly was talking about
(
5 in the first part of his prescription at the 6
bottom of the page labeled (a)?
7 A
I believe that I recalled that I 8
understood the (a) portion of it.
9 Q
Did you understand his (b) portion 10 of the prescription when you read it in or about 11 November of 19777 12 MS. CHATMAN:
That has been asked e
s/
13 and answered.
14 MR. MacDONALD:
I don't think 15 exactly in that form it has.
16 MR. KOLB:
I think it has been.
17 You keep going over the same ground.
18 Also, may I ask you are'you asking 4
19 did he think he meant at the time o r --
20 MR. MacDONALD:
Did he understand it 21 at the time.
22 THE WITNESS:
I'm sorry,-is there a 23 question?
[^)
24 Q
Yes.
Did you understand item (b)
-%)
25 of Mr. Kelly's prescription when you read it in
1 Walters 329 g3 Q'
2 November of 19777 3
A I read it and developed my own understanding 4
of it, if that*s the question.
l 5
Q so you believe you understood it
(
6 in November of 1977 when you read it, correct?
7 A
I said that I read it and drew my own 8
conclusions to what it meant.
9 Q
In light of those conclusions, did 10 you understand that in an overcooling transient, 11 that Mr. Kelly's prescription would permit 12 operators to terminate !!P I prior to the time that (D
\\~)
13 pressure reached 2500 psi and the. system went 14 solid?
15 MR. KOLB:
You have gone over this 16 at least twice aEd I think that is 17 enough.
You have,got an answer on that.
18 MR. MacDONALD:
I don't think he 19 specifically answered that in.Iight of his t
20 testimony that he'had his own, formed his 21 own evaluation of this or had his own
\\
22 understanding of Mr. Kelly's memo in 23 November of 1977.
[" _
24 MR. KOLB: tYou have been all over v
25
_this now several times.-
I think that is i
l 4
e I
Walters 330
,8
(
es I
v.
2 enough.
We~are not going to answer the 3
question again.
?
4 MR. MacDONALD:
Are you instructing f(
5 him not to answer?
6
'MR.
KOLB:
Yes, because it is s
7
-duplicative.
It is important to move 3
8 along.
This deposition is becoming much 9
too long for no good reason.
f-10 MR. MacDONALD:
I think we have ha dj t'i 11 to go over the same ground to'get a, clear g
s' 12 answer.
For instance, the conversation A'
\\se')
13 with Mr. Finnin, which only came out the s
14 second time or maybe it was the third.
i :'
15 MR. KOLB The witness' testimony 16 has been very clear and careful and I "think it is unnecessary to repeat over and 17 18 over again. I have allowed some repetit{on
,s 19
.because I appreciate the fact t}.a t some of 20 these matters require some' probing but I 21 don't think we have to do it three, four 22 or five. times.
23 MR. SELTZER:
We get different 24 answers when.the question is asked: two a n d'.
'[
~
- r. w
^,
-25
.three times.
'l,i -
=
331 1
Walters
()
2 MR. KOLB:
Sometimes.
i.
3 Q
The first paragraph of the letter to 4
Mr. Kelly, GPU Exhibit 132, the first sentence 1
('
5 reads, "The operators at Toledo responded in the 6
correct manner considering how they have been 7
trained and the reasons behind this training."
i h." ~
8 In that sentence, referring to l
9 "how they had been trained," did "they" have a 10 reference to the operators at Toledo Edison?
W:q 5 i;,
11 A
Yes.
- /
12 Q
And the training they received was
/~)
0%).
13 training from B&W7 14 A
My secondhand understanding of.how I 15 thought operators had been tra'ined.
16 Q
Your secondhand understanding how u.
17 you thought they had been trained by B&W7 t
18 MR. KOLB:
Is your question whether 19 he means B&W alone, B&W and someone else 4
20 or someone else?
21 MR. MacDONALD:
My question is 22 B&W.
23 Q
Will you please answer that f")-
24
-question.
's/
25 A
Yes, I am referring only to B&W training.
,~
.n
-s-
1, Walters 332 O'
2 Q
Who were the training personnel 3
that you talked to regarding the manner in which 4
the operators acted at Davis-Besse?
- (
5 MR. KOLB:
Objection as to form.
t 6
A The personnel I am referring to here in 7
this memo were Mr. Smith and a Mr. Goslow who 8
at that time were ex-training people, personnel.
9 Q
These were discussions you had 10 with Mr. Smith and Mr. Goslow prior to writing 11 GPU Exhibit 132?
12.
A Yes.
.Y 13 (Continued on the following page.)
14 15 16 17 18 19
.20
~~1 9
(.
22 23
.h).
24
-25
1 Walters 333 D
\\
\\
2 Q
Did you have-any other discussions 3
on this subject with training personnel or 4
former training personnel of B&W?
{
5 A
They are the only two I recall addressing 6
this subject matter with, s
7-Q Did you have any conversations with a 8
Mr. Street?
9 MR. KOLB:
On this subject?
10 MR. MacDONALD:
On this subject.
11
-A I don't recall that I did.
12 '
Q Do you know a Mr. Bill Street?
O)
(_
13 A
Yes, indeed.
'14 Q
Does he work for B&W7 15 A
Yes.
16 Q
In what section or department does he-17 work?
18 A
Now?
19 Q
currently?
~
20 A
Currently.
He is in the Nuclear Service 21 Department.
22 Q
Do you know the section in which he 23
. works?
[}
24 A
I believe it's the Operating Plant Services A,/
25 Section.
4.
1 Walters 334 A.
2 Q
At the time you wrote this memo do 3
you know in what department Mr. Street worked?
4 A
I do not recall.
(
5 Q
In the first sentence of the second 6
paragraph it is stated, "My assumption and the 7
training assumes first that RC Pressure and i
8 Pressurizer level will trend in the same 9
direction under a LOCA."
10 what did you mean by the word " trend" 11 in that sentence?
12 A
Meaning to move in the same direction.
13 Q
so that if pressurizer level went up, ss 14 RC pressure would also be rising?
15 MR. KoLB:
You are now just trying to 16 find out his meaning, right?
17 MR. MacDONALD:
Correct.
18 A
Yes.
19 Q
And if pressurizer level was falling, 20 RC pressure would also be falling?
21 A
Yes.
22 Q
In the first portion of that sentence 23 you have, "My assumption and the training b
24 assumes."
'V 25~
Your assumption was the assumption
1 1
Walters 335 2
was the assumption of J.
F.
Walters in or about 3
November of 19777 4
A That's correct.
(
5 Q
And that assumption was based on your 6
knowledge'and concerns during the time that you 7
were at B&W?
8 A
That's correct.
9 Q
What did you mean by the phrase "the l
10 training assumes"?
i 4
11 A
Exactly what you just said, my experience 4
12 and training at B&W.
(\\
i A/
13 Q
Your experience and your training?
14 A
Yes.
15 Q
The phrase says "and the training 3
16 assumes."
17 You didn't mean anything,other than 18 your training by that phrase?
I' 19 A
Thet is correct.
~
20 Q
Back in 1970 and 1971, you had a 21 ten-day course on the simulator, is that correct?
22 A
Yes.
23 Q
Did you have any classroom training
[ )
24 that went along with that?
l LJ
(
25 A
Yes.
=egli*-
4 m
pp e*
f
--g-r 3
w
'T-g
-'T'
1 Walters 336 2
Q What did the classroom training 3
consist of?
4 A
An introduction to the B&W NSS fluid paths,
(
5 the integrated control system, how it worked, how 6
it-was interrelated to all parts of the plant, 7
the control rod drive system and its 8
interrelation to the ICS and to control of the 9
control rods are the ones that I remember at this 10
- time, e
.11 Q
How many classroom sessions did you 12 have?
\\ ')
13 A
I don't recall the exact number.
14 Q
Did you have several?
15 A
Yes.
I 16 Q
You also had hands-on simulator
~~
17 training?
18 A
Yes.
19 Q
When you wrote in the fi r st sentence 20 of the second paragraph, "My_ assumption and the 21 training assumes," were you basing your assumptions 22 and training in part on those classroom and 23 simulator training sessions that you_had back in
[
24 1971 and '727
- \\s}
25 A
I don't recall having that in mind when I
+
-m, o.
,-~m-e-n--e r
yv
.m-
,r-w-
1 Walters 337
[J 1
N 2
wrote this memo.
3 Q
That was part of your overall training 4
experience at B&W though, was it not?
l 5
A That's correct.
6 Q
And that's what you were basing the 7
phrase "My assumption and the training assumes" on, 8
your overall experience at B&W7 9
A My overall experience at B&W, yes.
10 Q.
Did you assume at a point in time 11 that you wrote this memo that the training that the 12 Davis-Besse operators had from B&W was similar A
13 to the training that you had experienced on the 14 simulator in '71 or '727 15 MR. KOLB:
Would you read the question 16 back, please.
17 (Record read.)
~
18 MR. KOLB:
Did he think about that at 19 the time, is that the question? '
20 MR. MacDONALD:
Did he assume that 21 in drafting this memo.
22 A
I don't recall that that came to mind.
23 Q
At the time you wrote the memo,
[')'
24 what information did you have about how Davis-v 25 Besse operators had been trained by B&W7
1 Walters 338
_(D G!
2 A
A very general conversation or 3
conversations with personnel over a period of 4
years.
(
5 Q
Those personnel included the 6
ex-training personnel, Mr. Smith and Mr. Goslow?
7 A
Yes, it would include those two.
8 Q
Did it include anybody else that you 9
can recall specifically?
10 A
over a period of' time is the; question?
11 Q
Yes.
12 A
Is that the question?
13 Q
Yes.
14 A
Yes, there were other people over a period 15 of years.
16 Q
Can you recall the names of any of 17 those people?
18 A
Mr. Bill Street, Mr. Phil Griffin.
They 19 are the only ones I can-recall at this point.
20 Q
Who was Mr. Phil Griffin?
2 21 A
He -.who is he?
22 Q
Is he employed by B&W7 23 A
No, he-is not today.
[
') '
24 Q
Was he at some point in time employed LJ 25 by B&W?
1 Walters 339
~
2 A
Yes.
3 Q
In what capacity was he employed?
4 A
He was in the Training Department.
(
5 Q
Was he employed-by B&W in any other 6
capacity during the time of his work for the 7
company?-
8 A
I don't recall.
9 Q
When did Mr. Griffin leave B&W?
10 A
I don't recall exactly, '75 or
'76.
11 Q
Do you know where Mr. Griffin is 12 today?
i s-13 A
Yes.
14 Q
Where is he?
15 A
He works for Florida Power & Light.
~
16 Q
You stated in the last few words of 17 the first sentence in that first paragraph, "the 18 reasons behind this training."
19 What were the reasons behind this 20 training that you had in mind?
21 A
The reasons I had in mind at the time I wrote-this was my understanding that the 22 23 operators were trained to assess their situation
- (#'I 24
.at all times especially under any emergency
- '\\_)
25 condition and try to ascertain where they were O
9 e
w-w w
w T
r.
l l
1 Walters 340 O'
2 in response to various inputs that they had, if 3
they were able to determine where they were 4
then take corresponding action to mitigate or
(
5 stabilize the plant.
6 Q
Did you assume for purposes of the 7
memo that the Davis-Besse operators had been 8
trained that pressurizer level and pressume would g
trend in the same direction?
10 MR. KOLB:
Wait a second.
Are you 11 asking that question separate and apart from 12 the discussion of what he meant by reasons
(\\_
13 behind training or do you mean did he consider 14 that as part of his consideration of what 15 reasons behind training meant?
A 16 MR. MacDONALD:
I think the question 17
. stands on its own.
18 MR. KOLB:
Separate?
19 MR. MacDONALD:
That's c o r 'r e c t.
20 MR. KOLB:
Can we have the question 21 again, please?
22 (Record read.)
23 BY MR. MacDONALD:
[()
24 Q
Did you assume for purposes of the 25 memo that Davis-Besse operators had been trained 1
__-____-_-_A
1
- Walters 341 p-2 that Pressurizer level and pressure would trend 3
in the same direction?
4 A
I don't recall ever making that assumption
((
5 when I wrote this memo.
6 Q
From your experience and 7
conversations, was that your understanding that 8
the Davis-Besse operators had been trained to 9
recognize that pressurizer level and RCS pressure
' 10 would trend in the same direction?:.
11 MR. KOLB:
When you refer to Davis-12 Besse operators, are you referring to the I(--
13 actual operators who were on the scene 14 at the time of the transient that we have 15 been discussing?
16 MR. MacDONALD:
No, just the 17 Davis-Besse operation in genera 1.
~
18 MR. KOLB:
Just the population in-19 whole, all the Davis-Besse operators,.is t
20 that correct?
21 MR. MacDONALD:
No, the Davis-Besse 22 operators who were there and acted at the 23 time in the manner that Mr. Walters knew f
24 or had reason to understand that they acted sz-25 and did he assume that they had been trained n'
en g
y,
g w-w w
m
--t-M e
n+
p-W w
v w-o-
-wm-Me
1 Walters 342
(\\
/
2 to recognize the pressurizer level and 3
RCS system pressure trended in the same 4
direction.
l 5
MR. KOLB:
Do you understand the 6
question?
7 THE WITNESS:
I think so.
8 MR. KOLB:
You can try to answer it 9
then.
10 A
I don't believe I ever recall having made 11 the exact analysis that you referred to in 12 reference to a specific group of operators.
(")%
k-13 Q
Based on your experience in your 14 conversations with training personnel, had you 15 assumed that the Davis-Besse operators or other 16 operators trained by B&W had learned that 17 pressurizer level and RCS system pressure would 18 trend in the same direction?
19 MR. KOLB: That's two quest' ions.
You 20 have asked one part of it with respect to 21 Davis-Besse operators and the other part 22 MR. MacDONALD:
Let's leave it 23 it operators trained by B&W, non-limited s
i 24 to Davis-Besse.
%.)
25 MR.'KOLB:
Could you state that e-
---n--
1 Walters 343 y
.g 2
question again so the witness has the 3
question clearly in mind?
4 BY MR. MacDONALD:
(
5 Q
When you wrote this memo in or about 6
November 10, 1977, based on your assumptions, 7
concerns and your conversations with training 8
personnel that you had had, did you assume that 9
operators trained by B&W had learned that 10 pressurizer level and RCS system pressure trend 11 in the same direction?
12 MS. CHATMAN:
From B&W or elsewhere?
A
-13 MR. MacDONALD:
We talked about 14 B&W training.
15 MR. KOLB:
Incidentally, when we 16 talking about trending in the same direction, 17 are we talking about it under'the 18 circumstances described in the memo?
19 MR. MacDONALD:
Under a LOCA, as he 20 uses it in the memo.
21 A
I believe A cel y made the assumption that 22 in that I was addressing that during the LOCA 23 condition.
[~ )I 24 Q.
Are you saying that in addressing-G 25 the level and pressure'trendingfin the same
1 Walters 344 5..
(o)
' \\
2 direction under a LOCA condition you were assuming 3
that operators had received training that such 4
trending in the same direction would occur?
(
5 A
That they would occur under a double-ended 6
break LOCA condition.
7 Q
what do you mean by a double-ended 8
break LOCA condition?
9 A
The generally accepted worse case scenario 10 for a LOCA, double-ended rupture of the RCS 11 piping, I believe.
12 Q
At the time you wrote this memo,
.{\\
13 did you know that there would be any difference 4
14 under any other LOCA situation in terms of level 15 and pressure trending in the' same direction?
16 A
I do not believe that I knew any different.
17 Q
So you assume that this would occur 18 for all LOCA's?
19 MR. KOLB:
Are you asking'whether he i
20 deduced from what he has testified that in 21 fact this would occur under all LOCA's?
22 MR. MacDONALD:
He has testified M
under worst case.
I want to ask whether
. h')
24 or not he-assumed that the worst case, the
%./.
25 trending together in the worst case LOCA
.~.
1 Walters O
2 that he described would occur under all 3
LOCA conditions.
4 MR. KOLB:
Are you asking whether he
(
5 thought about that at the time?
4 6
MR. MacDONALD:
Whether he understood 7
that was the case at the time he wrote this 8
memo?
9 A
I don't believe.I generalized or -- about 10 all cases.
t 11 Q
About all LOCA cases you mean?
12 A
Yes.
13 Q
Was it ~ intended that the bounding 14 analyses performed for loss of coolant accidents 15 would include all LOCA cases?
}
16 A
If I did make that assumption, I certainly 17 don't recall ever addressing it at'that time.
18 I don't recall that I ever made 4
19 an evaluation or knew that they would'~be 1
20 different.
21 Q
Under different types of LOCA's?
k-22 A
That's correct.
.23 (Continued on following page.)
p.
\\s) 24 25
.. ~ _.
1 Walters 346 O
(A n
m/ -
2 Q
Why were you concerned about double--
3 ended LOCA's as a worse case break in the i
4 context of your memo of November of 19777 l
5 A
Did you use.the word " concern"?. Did I hear I
6 that correctly?
7 Q
That's correct.
8 A
I don't know when I wrote this memo if I 9
was concerned.
I was just stating: a fact as I
'10.
thought I knew it.
11 Q
Well, in double-ended LOCA's, is HPI 12 used as a mitigating factor?
ps 13 A
Yes, it is.
14 Q
At the time you wrote GPU Exhibit 132,
{-
15 for how long had you had the understanding that i
16 pressurizer level and RCS. system pressure would
'17 trend in the same direction'during a loss of 18 coolant accident?
l 19-A I can't recall a specific amount of time.
20 Q
Did you know at about this point in 21 time' November of 1977, whether or not the
{-
22 simulator at B&W could simulate pressurizer level 23 and RCS system pressure trending in any other l("%.
I 7,)'
24 direction but together?
l 25 MR. KOLB:
Would you read the question l.
i
W l
1 Walters 347
.. C\\
S
\\s -] -
/
2 back, please.
3 (The reporter read back the last 4
question.)
(
5 MR. KOLB:
Is this with respect to 6
a LOCA or not?
7 MR. MacDONALD:
With respect to a 8
LOCA.
9 A
I have no knowledge of total capabilities
.10 o f th e B &W simulator.
(
11 MR. MacDONALD:
This is a good time 12 for a break.
13 MR. KOLB:
Fine.
14 (Whereupon, a recess was taken.)
1 15 BY MR. MacDONALD:
4, 16 Q
After you sent your November 10, 17 1077 memo to Mr. Kelly, did you have any 18 subsequent discussion with Mr. Kelly regarding
.19 the subject matter of your memo?
20 A
-I don't recall that I did.
21 Q
The best of your recollection is that 22 you did not have any subsequent discussion with 23 Mr.. Kelly?
/^Y t.
j 24 A
That's correct.
25 Q
Returning briefly to GPU Exhibit 132,
~, _
I Walters 348 L
2 your memo, at the top of the memorandum it has 3
" File No. or Ref.,"
and I see a Roman Numeral 4
Volume VIII and a numerical 3.
(
5 Could you tell me what the 6
significance of that notation is?
7 MR. KOLB:
Would you read the 8
question back, ple ase, d
9 (The reporter read back the last 10 -
question.)
11 MR. KOLB:
- I would just like to note 12 for the record that in fact the notation O
13 does not say " Volume VIII."
There is 14 simply a Roman Numeral VIII.
15 MR. MacDONALD:
All right.
16 MR. KOLB:
With that qualification, 17 the witness can try to answer the question.
18 A
I have no-idea what that relates to.
~
19 Q
Did you make that. notation?
20 A
I certainly don't believe I did.
21 Q
Do you know who did?
m i
22 A
No, I do not.
23 Q
Is th e re such a file or reference
!(m) 24 category at B&W?
25 A
I have no idea of any-reference to that.
1 Walters 349 t'"%
~ ~
2 Q
Does this refer to any reference 3
within your own filing system?
4 A
Certainly within my own filing system there k
5 is no reference to a Roman Numeral VIII.
6 Q
After your discussion with Mr. Finnin 7
in or about mid-November of 1977, did you have 8
occasion after that to discuss the Davis-Besse 9
transient or Mr. Kelly's prescription with him J
10 on any subsequent occasion?
s.
11 A
Your reference is up until the present?
12 Q
Prior to the Three Mile Island
/]
\\>
13 accident.
14 A
I don't recall any discussion with Mr. Kelly 15 Prior to the Three Mile Island accident in this i
16 '
Particular scenario.
(
17 Q
The question is Mr. Finnin.
l l
18 MR. KOLB:
Do you want to state the 19 question again so that the witness has 20 clearly in mind what the content of the 21 question is, h.
22 Q
After the point of your discussion 23 with,Mr. Finnin in the hall outside your office l'^j 24 in or about mid-November of 1977 and prior to
'w/
25 the TMI-2 accident, did you-have any occasion in i
n
.~
' ' ~
~.., _.
1 Walters 350 fyO 2
which you discussed the events of Davis-Besse or 3
Mr. Kelly's prescription with Mr. Finnin?
4 A
I don't recall any.
N 5
Q Did you have any discussions with i
6 Mr. Hallman after the time you sent your memo 7
to Mr. Kelly in mid-November of 1977 regarding 8
the Davis-Besse transient or Mr. Kelly's 9
prescription?
10 A
I don't recall any discussion with 11 Mr. Hallman.
12 Q
After the time you. wrote this memo,
[ ')
\\'
13 did you have any discussions with Mr. Hallman on 1
14 the subject of high pressure injection termination 15
.during a LocA prior to the Three Mile Island 16 accident?
17 A
I don't recall any.
18 Q
Did you draft a letter for Mr. Hallman.
19 in or about August of 1978 to be s e n t' to Mr.
Bruce Farrasch?
20.
A Yes, I did.
k' 21 22 12 What, if any, discussions did you have 23' with'Mr. Hallman at that time regarding the L[
drafting of that memorandum?
24
- s. f 25 A.
I think the conversation was that ILhad been-i
~..
I Walters 351 2
asked or some reference had been made from one i
3 of my engineers about a question from one of 4
my engineers about a particular subject matter
()
5 and this I recall then that this particular matter 6
was still open, and I went to Mr. Hallman and 7
asked him did he not think we should write 8
another memo or might write a memo to Mr.
9 Karrasch and try to get a resolution between the 10 different concerns.
~11 Q
When you say the subject was still 12 open, do you mean the subject of termination of 13 HPI during a LOCA that had been addressed by Mr.
14 Kelly in his memo of November 1,
19777 15 A
It was not the specific reference that I was 16 making to.
17 Q
But you were talking about, the 18 termination of HPI during a LOCA and the 19 resolution or resolutions that had.been proposed 20 by people within B&W to be sent to customers;. is 21 that correct?
,.Y 22 A
It was in reference to operation of the HPI 23 system.
[J j
34 Q'
And Mr. Kelly had raised questions 25 about the operation of the HPI system in his
1 Walters 352 2
November 1,
1977 memo; is that correct?
3 A
That's correct.
4 Q
And he had prescribed new operator
/
5 guidelines to be sent out by B &W in that memo; 6
is that correct?
7 MR. KOLB:
Well now, we have gone 8
over what the memo means and we have had g
a discussion as to what Mr. Hallman 10 understood Mr. Kelly was doing, and I don't 11 think it is appropriate for you to i
12 characterize that now and try to get a
\\~-
13 general answer when there had been so many 14 specifics, which are inconsistent, I might 15 say, with the way you put it.
4 16 MR. MacDONALD:
I am attempting to 17 get a general understanding of'what was 18 going on i
in August of 1978 as relates to 19 what went on in November.of 1977'and I am
+
20 asking Mr. Walters, isn't it a fact that l
you were dealing with the same 21 Q
22 questions in August of 1978 regarding prescriptions t
23
.for HPI injection termination as had been discussed
(' )
24 and written.about in November of 1977?'
.v
-25 MR. KOLB:
The "same' questions"
e 1
Walters 253
(
)
2 meaning each and every detail or the same 3
general subject matter; is that what you 4
mean?
(
5 MR. MacDONALD:
The same subject 6
matter.
7 A
It did involve the same general subject 8
matter.
9 Q
Which was under what conditions 10 could operators terminate high pressure 11 injection during a LOCA?
12 A
Yes.
Ik-13 Q
Between the time that you sent your 14 memo in early November 1977 and February 9,
- 1978, 15 did you have any discussions with anyone within 16 B&W regarding the subject matter of either 4
l'7 your memo or Mr. Kelly's memo?
18 A
I don't recall any.
4 19 Q
You don't recall that you had any?
20 A
That's correct.
21 MR. KOLB:
Would you read the 22 question back, and the answer, please.
23 (The reporter read back from the
[ ')~
24 record, as requested.) _
v 25 '
Q Did you receive a copy of a memo that I-
~
1 Walters 354 2
was sent by Bert Dunn to Jim Taylor, the Manager 3
of Licensing at B&W in or about early February 4
19787
(
5 A
I did receive a copy of the memo.
6 Q
How did you receive a copy of that 7
memo? -
8 A
I received it from a Mr. Lill Street.
9_
Q And what position did Mr. Street hold 10 at that time?
11 A
He was an engineer in the Mechanical 12 Equipment Section, Nuclear Services.
13 Q
And he gave you a copy of Mr. Dunn's 14 memo?
15 A
Yes, he did.
16 Q
Was that in or about early February
[7 of 1978?
18 A
I believe that's correct.
your undetstandini of why 19.
Q What was 20 Mr. Street gave you a copy of that memo?
21 A
He was questioning the particular group
.(-
22 that this particular' item was appropriate to pursue, 23 which group it was.
)
24 Q
He was asking you that question?
A That's correct.
25 e
y p y-t.n w----4e-
,--e-y e
g%,y-w y--
355 1
Walters f ~).
J 2
Q Did he say how he received the memo?
3 A
I don't recall that he told me explicitly.
4 Q
Did he tell you generally?
(
'5
' A I believe he said he received it from Mr.
6 Pittman.
7 Q
Who is Mr. Pittman?
8 A
At'that time?
9 Q
- What position did he hold at that 10 time?.
r.
i 11 A
I believe he was a Supervisory En'gineer 12 in the Mechanical Equipment Section.
l:o 13 (Continued on the following page.)
14 15 p
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9
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I bt 1
Walters 356 2
Q During the course of your conversation 3
with Bill Street when he brought you the memo, 4
what in substance did Mr. Street say to you and
'(
5 you say to Mr. Street?
6 A
As best I can remember, it was along the 7
lines that he came over and asked the question 8
whether or not Plant Performance Services was not 9
a better group to follow up on this' matter or 10 take any action that might be necessary in this 11 matter via his group, the Mechanical Equipment
'12 Service Section, and I agreed with him that it was.
~
13 Q
Why would your group be a better section 14 to follow up than his group?
15 A
Because we had responsibility for operating 4
16 procedures, drafting those, and this, if it became 17 such, would be a change to an operating procedure.
18 Q
Do you know whether or not Mr. Dunn had 19 sent a copy of his memo to anybody within the' Plant 20 Performance Services Section of B&W7 21 A
I don't recall that anybody had. received-22 one in Plant Performance Services.
23.
Q You mentioned a moment ago that there f~)j 24 was a change..to an operating procedure that may 25 have been required as a result of Mr. Dunn's
357 2
1 Walters i
(3
.y.
2 concern.
3-would that have been a change to a 4
B&W draft operating procedure; is that what you
(
5 alluded to?
6 A
Yes, that's correct.
7 Q
Do you recall which one that would 8
have been?
9 MR. KULB:
I object as to form because 10 the question assumes there would be just one.
J 11 Q
Do you recall. which ones might have 12 to be changed?
s 13 A
I don't remember making'a judgment on 14
,how many or which particular ones had to be changed.
15 Q
At the time you received Mr. Dunn's 16 memo from Mr. Street, did you undertake to do 17 anything about Mr. Dunn's memo?
18 MR..KOLB Would you read the question 19 back, please.
20 LQuestion read by the reporter.)
.i s-g
(
A I did.
21 33 Q
What was that?
23 A
I read the' memo, drev'some conclusions y
\\
t y
\\
w
~
l 24 or understood phe memo, had a couple of concerns j
m-g
-(
s
' 25 about the end 'p$cduct of the,mem'o, and* assigned,
\\
\\
lc s
s s.
3 s
t l
3 1
Walters 358 t
I ms-2 one of my engineers to go down and talk with 3
Mr. Dunn about my concerns and his prescriptions 4
as they were stated in that meno.
(
5 g
what were your concerns about his 6
prescriptions as they were stated in his memo?
7 A
They were two folds the first one being simply 8
that the prescription was very dif ficil'.'t, I thought,,
i 9
to pass along to the operators so that he would 10 understand it in a very simple nature; and secondly, 11 that if I followed his prescription -- prescription-12 literally and under all circumstances, I would fT v
13 create unnecessary LOCAs by doing so.
r s
14 Q
How wou.d you create unnecesary LOCAs 3
15 by following his prescription literally?
s 16 A
I felt 17 MR. KOLB:
What was the last word?
g 18 (Record read by the reporter.)
19 A
I felt that if we were to follow that-20 prescription in an overcooling, type of transient _,
21 that there was insuffichent evidence to tell,the 22 operator when to.terninkte HPI'and therefore.
,\\
t a
- 3 s 7
'e L
k 23 possibilities o f goi.n' ' solid in: the aCS,sould g
I
,r ~\\
()
24, result and thereby possibly failingfco;de relief 3
1 s
25 valves and thereby ensuing an, unnecessary LOCA \\to j
. 6
- t 1,N ' *.
f, 4
4' I
Walters 2
occur.
3 Q
I would like to show you a copy of a 4
memorandum that we have been discussing, Bert
. (
5 Dunn to Jim Taylor, February 9, 1978.
It's been 6
previously marked as GPU Exhibit 78.
(Handing I'
7 docuruent to the witness.)
8 Is this a copy of the memo that you 9
received from Mr. Street in or about early February 10 of 19787 N
11 A
I believe it is.
12 Q
The prescriptions you were speaking of
' O i
N J.
13 are the prescriptions that appear on the second 4.
hy[g 14 page of this February 9,
1978 memo?
5 3
15 A~
Generally, yes, right.
~
16 Q
At the bottom of page 1 of Mr. Dunn's Y, i t
','r 17 memo he states, "I therefore l'emmmend that a'
i' [
18 operating procedures be writ ter. co allow for d54 19 termination of high-pressure injection under the 20 following two conditions only:
21 "1.
Low pressure injection has been
[I}
22 actuated and is flowing at a rate in excess of the
,7 '
23 high-pressure injection capability and that i ' )%
g.4,/
24 situation has been stable for a period of time "j bE
- 8' c-,'
25 (ten minutes).
z
5 1
Walte_s 360
,a 2
"2.
System pressure has recovered to 3
normal operating pressure (2200 or 2250 psig) and 4
system temperature within the hot leg is
(
5 less than or equal to the normal operating 6
condition (605F or 630F)."
7 Could you explain in light of Mr.
8 Dunn's second prescription or recommendation for 9
termination of HPI how in words has he used 10 them in that prescription would that lead to 11 hydroing the RCS and opening the code safety 12 valves in an overcooling transient?
'tO 5
13 MR. KOLB:
Would you read th'at back?
14 It's rather long.
15 (Question read by the reporter.)
16 A
As best as I can remember, my concern was that 17 if we leave the HPI system on for some. period 18 of time in an overcooling transient, do not 19 terminate it at some period of time or based on some 20 parameters that due to the influx of the mass fr m the HPI system that the ensuing transient,
/
21
_(
22 vercooling transient, once the paramters stablize 23 and begin to recovery, if we go back to 2200
/~m
(
1; 24 pounds or some number in-the system, 605 or -- that wJ 25 by that time you will have so much volume,
- ~
i' 6
1 Walters 361 additional mass in the system, that you will be 2
up against the codes and therefore force them to open.
4 t
Q Now, the code safety valves open at
- 5 2500 psi?
6 A
Approximately, that's correct.
Q And Mr. Dunn in this p~rescription 8-
- would allow operators to terminate HPI when 9
-pressure had returned to 2200 or 2250 psi, correct?
A I read it that way.
gy Q
That would allow operators to terminate 12
)
RPI before the system-reached a pressure high 3
enough to open the code safety valves or to take i
j
. the system solid, Oorrect?
A I beg your pardon.
Mr. Dunn's memo says --
he has an and" in there, both pressure and 1,4 temperature have to be satisfied.
g Q
Under Mr. Dunn's second prescription, 79 he would pe rmit or allow the operator to. terminate
. 20 1.
HPI in an overcooling transient with the 21 t
(a-system temperature in the normal operating range
. 22 and before system pressure had reached the set
'}.
point for. opening of the code safety valve at 2500
%l.
' '~
psi,. correct?
i-d----4m
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4-+p.+
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- A
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m
362 7
1 Walters
- n 2
MR. KOLB:
Now read the question back 3
so the witness can have it clearly in mind.
4 (Que s tion read by the reporter.)
f 5
A I believe that's what that says.
6 Q
And that would permit the operator 7
to terminate HPI before the system was in your 8
term hydroed or solid before it opened the code 9
' safety valves?
10 A
I believe that would be correct based on this 11 few minutes that I reflected upon it.
1 12 Q
Wouldn't that also be the case fo r O
13 Mr. Kelly's prescription in item B of GPU Exhibit 14 1317 15 MS. CHATMAN:
That's been asked and 16 answered.
17 MR. MacDONALD:
No, I think we are doing 18 a little bit of expounding on where we were.
19 Q
Wouldn't that be the case, would be that 20 the operator would be allowed to terminate HPI 21 before RCS system pressure reached 2500 psi and 22 the syste.m went solid in an overcooling transient?
23 A
If all parts of Mr. Kelly's prescription
[s) 24 were' satisfied, I believe that's correct.
25 Q
Did you know at the time that you read
8 1
Walters 363 g
(
~
2 Mr. Kelly's memo that under his prescription, 4
3 an overcooling transient, that the operator 4
would be permitted to terminate HPI befort the
(
5 system went solid or hydroed as you used the term?
6 MR. KOLB In the sense that he just 7
testified?
8 MR. MacDONALD:
Yes.
9 A
I don't. recall that I ever came to such a 10 conclusion.
t 11 Q
You didn't do any evaluation or 12 analysis of Mr. Kelly's prescription in
{~N s-13 relation to your concern about hydroing the system 14 that would have led you to understand that in an 15 overcooling transient, his prescription would 16 have permitted the operator to terminate HPI 17 prior to the system going solid?
18 MR. KOLB When you say "i vestigation" 19 or " analysis," are you talking aEout something 20 beyond what-he has.already testified to in the 21 form of examination of his memo and 22 conversations?
23 MR. MacDONALD:
That or anything else
( )
21 that he may have come to do at that point in v
25 time.
~
l 9
1
~
Walters 364 2
MR. KOLB If you ask about that, l
3 meaning both the materials he has already 4
testified about and conversations, if you
({
5 include that within analysis, then that's one i
6 thing.
7 If you are asking about more than what t
8 he has already testified to, then that's 9
another thing.
10 MR. MacDONALD:
We are talking about 11 right now in terms of what evaluations or 12 thought processes or conversations went on
(~T 3*sl 13 at the time.
t 14 MR. KOLB:
But you have been all over 15 the conversations and material that he has 16 examined and so forth and I don,'t.think it's 17 appropriate to go back over all that again.
18 MR. MacDONALD:
We are not going over
[
19-all that again.
I am not delvini back into l
20 any of those conversations or anything else.
21 All I am attempting to get at is whether 22 or not at the time of Mr. Kelly's memorandum, i
l 23-
'when he voiced -- when Mr.-Walters voiced l 'lY 24' his concern about hydroing or having the
\\_)
t 25 system go solid, whether he had performed any l
h
=
365 10 1
Walters 2
evaluations or analysis, or learned from 3
any discussions with anyone, or had established 4
in his own mind that Mr. Kelly's prescription
(
5 of an overcooling transient would permit 6
the operators to terminate HPI prior to the 7
system hydroing or going solid.
g A
I did no analysis as such -- running codes, 9
I am talking about -- and I don't recall any 10 other conversations or -- where I came to the j
11 conclusion that that would allow termination of 12 HPI in an overcooling transient.
13 Q
When was the first time after either Mr.
14 Kelly's or Mr. Dunn's memorandum when you came to 15 the conclusion that their prescription in an 16 overcooling transient would permit the operators 17 to terminate HPI prior to the system ~ going solid 18 or hydroing?
19 MR. KOLB:
Objection as to ' form because l
20 you are assuming there was such a point in 21
- time, fk-22 MR. MacDONALD:
I think he testified'that 23 indeed, in looking at that, that's true.
[^')
24 I am attempting to determine when he came v
25 to that conclusion.
1 1
Walters 366 gm I
)
2 A
I don't recall any thought processes along 3
that line other than the previous testimony here.
4 Q
You didn't come to that understanding i
5 prior to the Three Mile Island accident?
6 A
That is correct.
l 7
Q So I take it that would mean that 8
you didn't have any discussions or perform any 9
evaluations or analyses prior to the Three Mile 10 Island accident that would have told you that 11 either under Mr. Kelly's or Mr. Dunn's prescription 12 that the operators would be permitted to q
l 13 terminate HPI before the RCS went solid or 14 hydroed?
15 A
I did not make any analysis, that meaning 16 code analysis, and only to the evaluations that 17 I have previously testified to.
18 Q
Aside from code analysis,'any other 19 ~
analysis or thought processes, not foEmalized 20 code analysis, regarding whether or not these 21 two prescriptions would permit the operator to 22 terminate-HPI before the RCS went. solid or 23-hydroed?
X()
24 MR. KOLB:
This must now be about the 25-sixth' time that we have gone over this.
av e-w-
ev
1 Walters 367 2
I will let him answer one more time and 3
then that's it.
4 MR. MacDONALD:
He has been confining
('
5 his answers somewhat to analyses, he 6
refers to code analyses.
I want to find 7
out if there is anything else.
I don't 8
know whether code is a catch phrase or --
9 MR. KOLB:
He covered this 10 as well as the codes.
He has been very 11 specific.
I want you to realize I will 12 not let this go on beyond this' question.
\\_ )
(
13 I understand it is necessary for you to 14 probe and I have been tolerant about that, 15 but I will not let it go on forever.
16 Now, Mr. Walters, do you have the 17 question in mind?
18 THE WITNESS:
Yes, I think so.
19 A
I do not recall any other evalua'tions other 20 than the ones I have already testified to concerning 21 these two prescriptions and whether or not they L
22 would indeed allow the termination of HPI.
,23 Q
In the first sentence of Mr. Dunn's
~ ()
34 February 9, 1978 memo, he states, "This memo V
25 addresses a serious concern within ECCS Analysis
I walters 368
,b 2
about the potential for operator action to a
3 terminate.high pressure injection following 4
the initial stage of a LOCA."
{
5 When you read this memo, did you 6
agree that this was a serious concern about the 7
potential for operation action to terminate high 1-8 pressure injection following the initial stages 9
of a LOCA?
10 MR. KOLB Do you mean-did he agree 11 that ECCS had a serious concern or was 12 it his evaluation that this was a serious 13 matter?
14 MR. MacDONALD:
Was there a serious 15 concern regarding the potential for 16 operator action to terminate high pressure 17 injection following the initihl, stage of a
~
~
18 LOCA.
jus't asking 19 MR. KOLB:
You are not 20 about the state of mind --
21 MR. MacDONALD:
I am not asking L
22 within the ECCS Analysis which he may not I
23 know.
g'i 24 MR. KOLB:
0.K.
l t
'w) 25 Q
Did you believe it was a serious
1 Walters 369 f~%
concern?
2 3
MR. KOLB:
That's the question?.
4 MR. MacDONALD:
Yes.
(
5 A
All I recall is that I was reading the 6
memo and understanding that Mr. Dunn was 7
addressing what he thought to be a serious 8
concern.
9 Q
Did you believe that the matter that 10 he was addressing about the potential for 11 operator action to terminate high pressure 12 injection following the initial stage of a LOCA ps 13 was a serious concern?
14 A
I accepted that it would be if the -- or 15 was allowed to happen or occurred.
16 Q
And was Mr. Dunn in his memo of 17 February 9th speaking of an instance.at Davis-18 Besse on September 24, 1977 where that situation 19 did indeed happen?
~
20 MR. KOLB:
Which situation?
21 MR. MacDONALD:
Potential for
(.
22 termination of HPI following the initial 23 stage of a LOCA, the actual termination f~%()
24 of HPI--let me correct tha t-- following the 25 initial stage of a LOCA.
{
i i
1 Walters 370 n
2 A
Yes, I believe that Mr. Dunn was referencing 3
the TECO transient.
4 Q
And that TECO transient was the one
((
5 on September 24, 1977 where operators did 6
terminate high pressure injection following the 7
initial stage of a LOCA?
8 MR. KOLB:
You are asking for the 9
witness' understanding at the time I take 10 it?
t-11 MR. MacDONALD:
At the time, yes.
12 A
I don't recall that it was the particular s
\\-
13 date of the transient, but I believe it was the 14 Toledo transient.
15 Q
At the time you read Mr. Dunn's memo 16 you didn't know whether or not he was talking 17 about the September 24, 1977 t r a n s i'e n.t that Mr.
18 Kelly had referenced in his-November 1st memo?
19 A
No, I don't recall that I reca15 what I 20 thought at that time.
21 Q
Did you have an understanding at the 22 time you read this that he was speaking of the 23 September 24, 1977 transient at Toledo Edison?
i 24 A
Yes, I think I understood that that was
'\\_/
25 the case.
1 Walters 371 G
A 1
\\d.
2 Q
In the second paragraph of his memo, 3
the second sentence, Mr. Dunn states, "During 4
the accident the operator terminated high
(
5 pressure injection due to an apparent system 6
recovery indicated by high level within the 7
pressurizer."
8 At the time that you read this, what 9
did you understand that Mr. Dunn was referring 10 to when he said " apparent system recovery 11 indicated by high level within the pressurizer"?
12 A
I don't recall any specific thought process
['N k-13 other than what he has written here.
14 Q
Did you understand that to mean the 15 level of water within the pressurizer?
16 MR. KOLB:
Is your question whether 1
17 he understood the words high leyel to refer 18 to water?
19 MR. MacDONALD:
In the con' text of 20 the rest of the words in the sentence, l
21 correct.
22 A
I don't that I did either way.
23 Q
Yo-o understanding of what f) 24 Mr. Dunn meant by phrase, "High leval within
\\~x 25 the. pressurizer"?
1 Walters 372 2
MR. KOLB:
He didn't say what you just 3
said at all.
He just said he didn't recall 4
that he remembered, what he was thinking
(
5 at the time.
6 Q
Is it your testimony, Mr. Walters, 7
that you have no recollection as to what you 8
understood Mr. Dunn to mean by, "High level within 9
the pressurizer"?
10 THE WITNESS:
Can you read back the 11 question, please.
12 (Record read.)
)
\\_/
13 A
No.
What I said was I just don't recall 14 any specific thought process when I read this 15 memo at this time.
4 16 Q
Did you understand that the phrase 17
" terminated high pressure injection" m, cant that 18 the operator manually terminated high' pressure 19 injection?
20 A
I accept that from the words, yes.
21 Q
And that was your understanding at L
22 the time you read Mr. Dunn's memo?
23 A
Yes.
[)
24 Q
What was your understanding as to the 25 operating terminating high pressure injection
1 Walters 373 p.
-]'
2 due to the apparent system recovery?
3 MR. KOLB:
Is your question how, if 4
he recalls, he interpreted those words in
{
5 the memo?
6 MR. MacDONALD:
He just stated he 7
understood at the time that he read the 8
memo that to him at that specific time 9
that the operator terminated high pressure 10 injection to mean that the operator manually 11 terminated high pressure injection, that 12 was his understanding at the time he read
/3 k_/.
13 the memo and I am asking him to explain to 14 me what his understanding was about that 15 termination as Mr. Dunn uses the phrase 16 "due to an apparent system recovery," and 17 what his understanding was of t, hat phrase.
18 MR. KOLB:
Of the phrase "due" 19 MR. MacDONALD:
"...to an ' apparent 20 system recovery."
21 A
That particular parameter was coming back 22 to a normal condition.
23 Q
That parameter being the pressuricer
/
'I 24 water-level indicator?
%J 25 A
I believe he refers later on in the sentence
I walters 374 2
to high level in the pressurizer.
3 Q
And you: understand that to mean 4
pressurizer water level?
(
5 A
I don't recall having any other particular 6
assumption or meaning for it other than that.
7 Q
In the next sentence Mr. Dunn goes on 8
to say, "This action would have been acceptable 9
only after the primary system had been in a 10 subcooled state."
t 11 What was your understanding at the 12 time of Mr. Dunn's use of the term "subcooled
[')
\\/
- 13 state"?
14 A
Are you asking me what I had in mind at the 15 time I read the memo, or did I understand these 16 words, what these words mean?
17 Q
Did you understand what'M.r. Dunn was 18 saying when he said "subcooled state"?
19 A
I'think so, yes.
20 Q
And what did you understand Mr. Dunn-21 to mean when he said "subcooled state"?
22 A
That the RCS was not in a saturated state.
23 Q
Was Mr.-Dunn also saying;in that-
. [}
24 sentence that termination of HPI would have been
. v.-
25 acceptable after the primary system had been'in a V
w w
q s
w,-
e-
-w--w,-
.-~v-e--m-n-e-
1 Walters 375
~
2 subcooled state?
3 MR. KOLB:
Would you read the question 4
back, please.
(
5 (Record read.)
6 MR. KOLB:
Are you asking for what 7
he understood Mr. Dunn to be saying?
8 MR. MacDONALD:
Yes, what he understood 9
Mr. Dunn to be saying.
10 A
I believe that's what Mr. Dunn says.
11 Q
That's what you understood Mr. Dunn 12 was saying?
A
~s 13 A
I understand that to mean.
14 MR. MacDONALD:
We are at a point.
15 where we can take a break for lunch.
16 MR. KOLB:
That's fine.
17 (Whereupon, at 12:30 p.m.,
a lunch 18 recess was taken.)
19
~
20 g
22 23
/
h 24
'-Q 25
1 376 2
AFTERNOON SESSION 3
2:10 p.m.
4 o0o
(
5 JAMES FRANKL I N WALTE RS 6
having been previously duly sworn, resumed 7
and testified further as follows:
8 MR. KOLB:
Will you please repeat the 9
last few questions and answers.
10 (Record read.)
(
11 EXAMINATION (Continued) 12 BY MR. MacDONALD:
r'%U 13 Q
Mr. Walters, in the second paragraph 14 of Mr. Dunn's memo of February 9th, do you see 15 the third sentence which begins, "This action..."?
16 A
Yes, I do.
17 Q
And that reads, "This action would 18 have been acceptable only after the primary subcooled state.l 19 system had been in a 120 A
Yes, I see it.
21 Q
What did you understand at the time 22 Mr. Dunn was speaking of when he referred to 23 "This action"?
-( m) 24 A
That he was referring to the previous x_-
25 sentence, the action in the previous sentence.
I..
I->..
c aw
1 Walters 377 2
Q You understcod that action was 3
termination of high pressure injection due to 4
apparent system recovery indicated by high
(
5 level within the pressurizer, is that correct?
6 A
I don't recall that I did.
7 Q
Well, you understood the pl. rase 8
"This action" to refer to the prior sentence, 9
is that correct?
10 A
Yes, taken at face value in the memo.
11 Q
You understood the action in the prior 12 sentence was the operator terminating the high A
13 pressure injection?
14 A
Yes, I believe that's so.
15 Q
In the fourth sentence of that 16 paragraph it reads, " Analysis of the data
~
17 from the transient currently indicate,s that the 18 system was in a two-phase state and as such 19 did not contain sufficient capacity to' allow 20
'high pressure injection termination."
21 Do you see that-sentence?
22 A
Yes,.I do.
23 '
Q What.did you understand Mr. Dunn to
[
)
24 be referring to by the words "two-phase state"?
</
25 A
Again, I don't recall reflecting upon that i.
bt 1
Walters 378
[)
~
2 particular sentence at this time.
3 Q
Did you understand at the time you read 4
this memo that Mr. Dunn was referring to a mixture
(
5 of steam and liquid water within the reactor 6
coolant system?
7 A
Yes, I assume that I did.
8 Q
And a mixture of steam and water a
9 within the reactor coolant system would signify the 10 existence of saturation?
.~
11 A
Yes, I believe I will agree to that.
12 Q
Mr. Dunn, when he stated "did not V
13 contain sufficient capacity," did you understand 14 what Mr. Dunn was saying by the term " sufficient i
15 capacity"?
16 A
I don't believe I remember at this time.
17 Q
Did you understand that the sufficient 18 capacity was. referencing the volume of liquid 19 inventory in the reactor coolant system?
20 A
Is the question what I think I remember at 21 that time or what I actually recalled at that time?
22 Q
What you understood at the time 23 you read the February 9,
1978 memo in regards to L.
(,N
/~
l
)
24 Mr. Dunn's phrasing in the sentence, " sufficient 25 capacity." The question is whether you understood y
y
1 Walters 379
/
2 what Mr. Dunn was saying was the " sufficient 3
capacity" was the volume of liquid inventory in the 4
system.
5 MR. KOLB:
He is asking you to tell 6
him what you remember, not to speculate 7
on what you remember.
8 MR. MacDONALD:
What he understood 9
when he read the memo.
10 MR. KOLB Right.
11 A
Well, I don't recall what I remembered at 12 that time about the particular sentences.
n
\\~
13 Q
Do you recall that you understood them 14 at the time you read them?
15 A
I would assume that I did.
16 Q
What do you understand Mr. Dunn meant 17 hy the term " sufficient capacity" as he used 18 it in the February 9, 1978 memo?
19 MR. KOLB:
Would you read the question 20 back, please?
21 (Question read by the reporter.)
22 MR. KOLB:
That asks him to form an l
23 opinion today, an interpretation of what
'(n) 24 Mr. Dunn meant and that is not appropriate.
25 If you want to ask him what his recollection l
1 Waltern 380 0
2 is of the events at the time, opinions 3
he formed at the time, that's fine.
4 MR. MacDONALD:
Well, I think what I am
(
5 asking is whether or not in the review of 6
this memo at any point in time prior to today 7
whcther he has formulated an opinion as to 8
what Mr. Dunn meant or what he understood 9
Mr. Dunn meant from the term in the sentence, 10
" sufficient capacity."
11 MR. KOLB But I won't let him answer 12 as to any opinion he might formulate here
~s
'13 and now as he sits here.
14 MR. MacDONALD:
No, what he understood --
15 MR. KOLB As to whetl.ar,he formed 16 an opinion on that particular subj ect, he may 17 answer that question yes or no."
18 He already told you he doesn't remember 19 exactly what he thought about e ch individual i
20 sentence, but I will let him answer whether 21 he formed an opinion along the lines you have 22 suggested.
l 3
Q' Let's get up until today.
l
(-[
24 MR. KOLB I won't let him answer as to l
25 anything he formulates on the spot here as an
1 Walters 381 b)
N/
2 opinion as to what somebody else meant in a 3
memo back in 1978, but if he is a participant 4
in the events, I won't impede you in any way
(
5 as to fair questions about his recollection 6
of those events.
7 Q
Do you have an understanding of what 8
Mr. Dunn meant when he used the term " sufficient 9
capacity" in his February 9, 1978 memo?
10 MR. KOLB Are you asking for his 1
11 present understanding?
Is that the intent 12 of the question?
'O 13 MR. MacDONALD:
Any recollection fo'rmed 14 before today.
15 MR. KOLBt O.K.
16
.A I don't recall what my recollection was at 17 that time.
18 Q
At any other time other than the point 19 in time that you received this memo, did you 00 formulate an understanding of what Mr. Dunn meant l
21 by the term " sufficient capacity" as he used it in 22 this memo?
23 A
I don't believe I understand the question.
o)
(_
24 Q
At.any point in time have you formed 25 a belief about an understanding of what Mr. Dunn
I 1
Walters 382
.,n,
]
2 was referring to by the phrase " sufficient 3
capeity" as used in the fourth sentence of GPU 4
Exhibit 78, the second paragraph?
l 5
MR. KOLB:
Do you understand what he 6
means?
7 THE WITNESS:
No.
8 MR. KOLB:
I think the problem here 9
is that he has told you he doesn't remember.
10 MR. SELTZER:
Let me say something.
11 MR. KOLB:
Let me finish.
12 MR. SELTZER:
I didn't mean to interrupt.
O 13 I'm sorry.
14 MR. KOLB. And your questioning, which 15 is obviously intended to try to probe his 16 recollection, becomes quite confusing because 17 you are trying to find other ways to ask him 18 what he might remember, but if he doesn't 19 remember, he just doesn't remember and there 20 is not much we can do about that.
I am not 21 sure it does much good to debate back and 22 forth between counsel on the point.
He told 23 you repeatedly that he read the memo, he told ex
. (v) 24 you on a number of occasions that the 25 specific words are words he believes he t
1 Walters 383 OU 2
understood at the time but that he doesn't 3
remember a lot, or at least as much as you 4
would like to inquire about beyond that, l
5 and I just think it would be well to take his 6
lack of recollection on some of these points 7
at face value.
8 You are not going to be denied the 9
opportunity to probe fairly, but I do think 10 we have to face the fact that there is just a 11 limit to how much the man can recall about 12 every word and every line as opposed O
13 to just a general recollection about the 14 whole subject.
15 MR. SELTZER:
Mr. Kolb, I think you know 16 that's monkey businass and I know that 17 it's monkey business that you are pulling, 18 and I don't like to get harsh, but 19 what you are doing is just an attempt to 20 block examination of a witness on relevant 91 subjects.
L 22 The witness says that he doesn't have i
23 a present recollection of what words meant (s) 24 to him two years ago when he first got a l-
.25 -
memorandum, but the words he does admit were
l l
I Walters 384 2
understood by him when he read the memo.
3 What he presently thinks these simple 4
English words mean is highly probative of what
(
5 he understood them to mean two years ago, G
and I think that it's entirely proper, it's 7
reasonably calculated to lead to the 8
discovery of admissible evidence to ask him 9
what his present understanding of these simple 10 English words is.
11 MR. KOLB I'm sorry that you feel 12 it's necessary to use remarks like " monkey 13 business."
We at least won't do that.
14 As far as my --
15 MR. SELTZER:
I hope I don't give you 16 cause to use it.
17 MR. KOLB:
As far as my position is, t
18 the difficulty that we have here, you really 19 are from time to time asking hiA to now j
20 make an interpretation which so far as I can i
21 tell he may not have made at all back at the 22 time, and I don't think that's appropriate.
23 Now, I gather you disagree with me, D)
(
24 and the only way you know how to express that i
25 is in harsh terms but I am not going to do f
(,,
v v
~'
3._
A.
1 st
/-
N
\\ \\.
f
'\\
1 Walters 385 (s
t.
andfIwill stand on my position.
i 2
that
,e 3
MR.3 71a cDONALD :
Are you instructing
.y i
s 1
\\,
4 him not to answer?
s x
x 3
(
5 MR. KOLB:
Well, at this point!I think i
6 we ought to hear the question again because i
7 obviously each question has to be,as 8
has been the case up to now, assessed on its i
9 own merits.
- (
3
/
~
1 T
i 10 BY MR. MacDONA$D:
N 4
b[
s 1
11 Q
Do you have an understanding, Mr. Walters/ '
-]
g
,t
- ~
12 of what Mr. Dunn meant in his February 9, 1979 memo 13 when he used the term in the fourth. sentence of s
s 14 the second paragraph "suf ficient capacity"?
l 15 MR. KOLB:
I direct hin not to answer 3
16 because,you are asking for his p re.s e n t i
17 understanding rather than his understanding I.
L 18 at the time of events 3that.are relevant to,
. h,. (
'g 4
3 19 the lawsuit.
\\.
tf y
s 20 May we have a moment?
\\
j s
21 MR. MacDONALD:
Yas.,
\\
22
(. Recess,taken.L 1
3%
23 BY MR. MacDONALD:
J, j
s f ;
' f%
l 's' i('
8 s
tv) 24 Q
Mr. Walters,ido syo's have any underatanding., '
t 25 that you formulated prior to today regarding ghat,
y y f
a t
t' f
5
'g'*..
N r
$3
. l*
\\'
is.
s s
').:
- fib d -.
5
s -
,(
' g.
s 4
i y
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\\
1 Walters.
386
- y' '+
c-
_z v
2 Mr. Dunn meant in his February 9, 1978 memo 3
when he used the term in the.f:ourth sentence of the 4
second paragraph, "as such didgnot contain
(-
5 sufficient $ capacity to all.ow high-pressure s
6 injection termination"?
i i
7 A
No, I do not' recall any.
1,.
, i.
8 Q
After yo'u received this memo from r
i 1-9 Mr. Dunn, did you speak to anybody regarding 10 Mr. Dunn's memo'?
5
.i 11 A
Yes, I did.
~
L
\\
12 Q
And who was that?
13 A
A Mr. Kal Goslow.
}
,i l
14 Q
What was Mr. Goslow's position at i
15 that point in time?
/
16 A
He was an -engineer that reported ~to me f,
t 17 tpart time.
c 18 g-l
,, Whondid he report to/the other part
,s 8
19 cf the time?
).
I~
20 inA
'Mr.
Hallman.
l.
i i i
21 (i
Q Did hd have a job'kitYe other than r -
22 Engineer?
s 23 -
A-
-I' don't, recall that he sdid.
n 24 Q.
When - did. you 'have 1 h
'conversatihnsy/
m i
m." n
- 25
' with Mr. Goslow?
l{
< 3, J
,l l
4 e,
?_
c
.-m
... a. _ w..,,. - _ -.
k; 1
Walters 387 YI
.u 2
A Soon after February 9th of
'78.
3 Q
Where did the convursation take place?
- V',
4 A
Either at my desk or his desk.
-(
5
'Q Did you initiate the conversation?
6 A
Yes.
7 Q
During the course of that conversation, s., '
't 8
what in words or substance did you say to Mr. Goslow.
9 and what did Mr. Goslow say to you?
l*'
10 A
I asked Mr. Goslow, or stated.to Mr. Goslow s,
11-some concern or need of additional information f
12 conce rning Mr. Bert Dunn's memo of February 9th,
^'
13 and my understanding of a prescription or -- that 14 he was offering in that particular meno, and I s
'.5 believe I asked him to -- after I relayed this
- +('
16 to him -- go and talk to Mr. Dunn about it, 17 or something of that nature.
t e, ', i
~
u' i
18 Q
Did you inform Mr. Goslow during the 19 course of this conversation of your concern about 20 Mr. Dunn's prescription possibly leading to 21.
taking the system solid or hydroing the system?
22 A
I believe I did.
23 Q
What in words or substance did
~p
\\j 24 Mr. Goslow say to you during the course of that 25 conversation?
e 9
y._.3
1 Walters 388
~\\
%)
2 A
I don't recall any of Mr. Goslow's responses 3
back to me.
4 Q
Did you show Mr. Goslow a copy of l
5 thc. Dunn's February 9, 1978 memo?
6 A
I don't recall that, either.
7 Q
Did you speak to Mr. Goslow regarding 8
the subject matter of your November 10, 1977 memo 9
to Mr. Kelly during the course of that conversation?
10 MR. KOLB:
Would you read the question 11 back, please.
12 (Question read by the reporte r. )
13 A
I don't recall that that subject came up.
14 Q
Did you show Mr. Goslow a copy of your 15 November 10, 1977 memo during the course of your 16-discussion with him?
17 A
I don't believe I did.
18 Q
Did you discuss with Mr. Goslow the 19 subject matter of }Or. Kelly's memo of November 1,
20 19777 21
'A I don't~believe I did at this point in time.
- 22 After reception of the Dunn memo.
23 Q
Did you, during your discussion with 24 Mr. Goslow, show Mr. Goslow a copy of the Kelly v
25 November-1, 1977 memo?
4 i
.g.
.tr
.g i.i.
-l Walters 389 d(^T.
2 A
I believe I testified before that I showed 3
him a copy of the Kelly memo at some time back in 4
November of
'77.
(
5 Q
At this point in time, when you had 6
the discussion, though, with Mr. Goslow, 7
did you show him a copy of the. Kelly memo?
8 MR. KOLB:
This is the point after he 9
receives the Dunn February 9th, 1978 memo?
10 MR. MacDONALD:
Yes.
(
11 A
No, I did not show him a copy of the Kelly 12 memo at this time.
'~
13 Q
Did you ask him to go and reread or 14 look at again the Kelly november 1,
1977 memo?
15 A
I don't recall.
16 Q
You don't recall that you did?
17 '
A Or didn't.
18.
Q Did you ask Mr. Goslow to compare 19 the prescriptions of the November 1st' Kelly memo 20 with Dunn's February 9, 1978 prescriptions?
21 A
I don't recall that I asked him to do that.
22 Q
As best you can recall, what did you say 23 to Mr. Goslow regarding your going solid concern?
I 24 A
As best I recall, I ask'ed him -- I related 25 my concerns that if we relied on Mr. Dunn's l'
1 Walters 390 r~s,
(
b
'g 2
prescription without any qualifiers,~that I was 3
concerned that this might lead to going solid 4
in the reactor coolant system and other transients
'(
5 and the local transient of which Mr. Dunn was 6
passing along this information, and because of this, 7
I believe I asked he and Mr. Bill Street to go down 8
and talk to Mr. Dunn about his prescription and my 9
concerns if we used his prescription literally.
10 Q
Did you discuss with Mr. Goslow the 11 question of vessel mechanics?
12 A
I don't recall.
(
13 Q
Did you discuss with Mr. Goslow the 14 question of whether or not the code safety valves 15 or electromatic relief valves were tested for 16 two-phase flow?
~
17 A
I don't recall that we talked about that l
18 specific item either.
19 Q
Did you request that both Mr. Goslow I
20 and Mr. Street go to see Mr.-Dunn?
l 21 A
'To the best of my recollection, that's what I
e
_22 I asked.
i I
23 Q
Mr. Street did not report to you,-
24 is that' correct?
25 A
That'is correct.
1 Walters 391
^
2 Q
Did you ask Mr. Goslow to speak with 3
Mr. Street or did you speak with Mr. Street 4.
directly?
I 5
A I don't remember in what context that 6
happened.
t 7
Q For whom did Mr. Street work directly?
8 A
Roger Pittman.
9 Q
Did you speak to Mr. Pittman?
I 10 A
No, I did not.
11 Q
Did you consider going to speak to n'
12 Bert Dunn yourself regarding your going solid
'~'
13' concerns?
14 A
I don't remember if I ever entertained that 4
15 thought or not.
16 Q
You don't recall that you did?
17 A
I don't recall that I did or I did not.
18 Q
Did you ever'considei goi g to speak 1
19 to Mr. Kelly yourself regarding your going solid
-20 concerns?
21 A
I don't recall that, either.
22 Q
Around the-time that you received i
23-Mr. Dunn's memo, did you speak to Mr. Hallman at d
24 all.regarding the subject matter of Mr. Dunn's
- 25 memo of February 9,
1978?
4
1 Walters 392 D
t 4
N/
2 A
I recall talking to Mr. Hallman just briefly 3
but I do n t recall at what time that I did that.
4 Q
What do you recall was the substance f
5
.of that conversation?
6 A
I don't recall the substance of the conversa-7 tion.
4 g
Q Do you recall anything about what was 9
discussed during that conversation?
10 A
No, I don't.
t 11 Q
At or around the time that you 12 received a copy of Mr. Dunn's February 9 memo,
(/
\\
13 did you consider going to speak to Mr. Hallman g4 regarding the subject matter of the memo?.
15 A
To speak'to Mr. Hallman about the subject 16 matter?
I don't believe I did at this time.
17 Q
Did you speak to Mr. Finnin in or 18 around the time that you received the Dunn February 9 J
19 memo?
1.
20 A
I do not recall talking to.Mr. Finnin about the Dunn-memos.
91 22 Q
Was Mr. Finnin still a member of PPS 23 a t' this point in time, February 9, 1978.
.y
(
J-24 A
To the best of my recollection,'it was that v
25 he was.
I f
r
s 1
Walters 393
/~T
\\
)
'~'
2 Q
Was his office still adjacent to yours?
A Yes.
3 4
Q How far away in physical location was
(
5 your office from Don Hallman's?
6 A
My office was adjacent to his also but 7.
his was an enclosed office.
8 Q
As a matter of regular business 9
practice, did you discuss business problems with 10 Mr. Hallman during the time that you were a 11 Supervisory Engineer and he was the Manager of PPS?
~
12 MR. KOLB:
Do you mean by that-was
(~~
13 it a frequent occurrence?
14 MR. MacDONALD:
Yes..
Did he discuss 15 these things on a regular basis with Mr.
16 Hallman?
17 MR. KOLB:
But.what I am trying to find 18 out is what you mean by " regular."
" Regular" j
19 could be scheduled --
20 MR. MacDONALD:
Frequency.
og MR. KOLB:
Frequency.
22 '
A I' don't think there was any frequency set 23 up_that we talked, specific frequency, I mean.
r%
)
34 Q
You weren't hesitant, were you, to go
\\/
25 into Mr. Hallman's office and discuss an issue
1 Walters 394
[h
' v 2
that related'to the business of B&W7 3
A No, not at all.
4 Q
You weren't hesitant to go in and speak
(
5 with Mr. Finnin on an issue that regarded the 6
business of B&W7 7'
A That is true.
I ~ was not hesitant.
8 Q
Had you indeed in many instances done 9
that with Mr. Finnin?
10 A
On several occasions, yes.
11 Q
Had you also done that on many occasions 12 with Mr. Hallman?
1 N
13 MR. KOLB:
Objection as to form.
14 Q
Had you also discussed B&W related 15 issues on many occasions with Mr. Hallman in his
-16 office 7 17 MR. KOLB The same objection.
18 You may answer.
19 A
I have had many meetings with Mr. Hallman 20 over the years concerning the business that we i
j 1
21 were working on.
f-22 Q
Did you have occasion during your
'23 employment'at B&W to discuss business' issues I f's i
}
.24 with members of the Engineering Department?
i.
x._ s 25
'A
.Yes,=I did.
9 r-i-r-g-+g y
twt y-e y--W m,
y,m-cyyw w-y-
^ Pt
1 Walters 395 I\\~'
2 Q
Did you ever discuss such business issues with Mr. Dunn?
3 l
4 A
I don't recall any discussions with
(
.5 Mr. Dunn up through_this period of time.
6 Q
At any period of time while you have 7
been at B&W have you discussed business related 8
issues with Mr. Dunn?
9 A
Numerous times since TMI-2.
10 Q
Prior to TMI-2, had you discussed 11 any B&W related business issues?
12 A
I don't recall that I did.
13 Q
Have you had discussions with 14 Mr. Kelly regarding business related issues?
15 A
Yes, I have.
16 Q
Did you have such discussions prior 17 to the time of the Three Mile Island'ageident?
18 A
Yes.
~
19 0
And you have had such discussions 20 also after the time of the Three Mile Island 21 accident?
22 A
That is correct.
l jg Q
On how many_' occasions'can you recall
-[ )~
T that you had business related discussions with 94
(
~
25 Mr. Kelly prior to the Three Mile Island accident?
E I
i l
l' Walters 396
.p G
2 A
Well, I would have to respond to that by 3
periods of time.
There was a period of time that 4
we were together at the site at Arkansas
(
5 and we spoke on a daily basis.
6 Q
During the time that you were at 7
Lynchberg?
8 A
Several times a month.
9 Q
You felt no hesitancy in speaking 10 to Mr. Kelly about B&W business related issues?
11 A
None at all.
12 Q
Did you feel any hesitancy about
~'
13 speaking to Mr. Dunn regarding any EcW business 14 related issues prior to the time of the Three 15.
Mile Island _ accident?
16 A
Not if I had thought the situation warranted.
-17 Q
Did you think the situation involving 18 Mr. Dunn's February 9, 1978 memo warranted such 19 discussion between you and Mr. Dunn?
20 A
I don't recall evaluating, after reading og Mr. Dunn's memo, as a serious concern that I should gg go down and talk with him at that time.
23 Q
You don't believe that after you read
/~)
- f )
24 his' memo you believed that it was of.the nature 25 f.a serious concern that you should speak directly
,_,4 l
6
+
+-K*
1 Walters 397 7s
'N 2
with Mr. Dunn about the substance of the memo?
3 A
No, I did not evaluate it as that type of 4
concern.
(
5 A
At this point in time, February 9,
- 1978, 6
Mr. Dunn was Manager pf ECCS Analysis, is that 7
correct?
8 A
That is correct.
9 Q
What does ECCS Analysis stand f o r ?-
10 A
Emergency Core Cooling Systems Analysis.
11 Q
And that was a unit of the Plant Design i
12 section of B&W7
(~T
\\/
j 13 A
Yes, I'believe that's correct.
14 Q
And Plant Design was a section of the 15 Engineering Department of B&W at that time?
i 16 A
Yes, it was.
17 Q
And by the nature of Mr. Dunn's 18 job as Manager of ECCS, was he in charge of issues l
19 dealing with the Emergency Core Cooling Ssytems 20 and on B&W NSS?
21 MR. KOLB:
Can I hear the question
[
22 again, please.
i 23 (Question read by the reporter.1
(]j
/
24 MR. KOLB:
How far do you mean to take j
i, 25 -
the words "in charge"?
h w ~
v e
w-r
1 Walters 398
,6 L
2 MR. MacDONALD:
Was it his responsibility 3
as the Manager of ECCS?
4 MR. KOLB:
Just so we are clear, l
5 do you mean was it his sole responsibility --
6 MR. MacDONALD:
No.
7 MR. KOLB:
--that he was the only 8
one or do you mean that was a responsibility 9
of Mr. Dunn?
10 MR. MacDONALD:
That was a responsibility 11 of Mr. Dunn's.
12 MR. KOLB Do you understand that?
13 Would you mind stating it again in that 14 form so the witness can understand it clearly?
15 Q
As Manager of ECCS, do you understand 16 that Mr. Dunn was responsible for the emergency 17 core cooling system analysis performed.on B&W NSS 18 systems?
19 MR. KOLB:
Responsible in the sense that.
20 you described a moment ago?
og MR. MacDONALD:
Yes.
k.
~
22 A
Yes, I accept Mr. Dunn's responsibility in 23 that area.
rx jns)-
24 Q
And part of the responsibility that 25.
Mr. Dunn. held as Manager of the ECCS Unit related t
1 Walters 399
,O 2
to issues involving the high-pressure injection 3
system?
4 MR. KOLB: Would you read the question 5,
back, please.
6 (Question read by the reporter.)
7 A
Yes, in that that's a component of the emergency 8
core cooling system.
9 Q
Was it also part of his responsibility 10 as Manager of ECCS, as you understood it, to perform 11 analyses regarding loss of coolant accidents?
12.
A Yes.
O'
\\~J 13 Q
Was it also, a part of Mr. Dunn's 14 responsibility as Manager of ECCS to analyze the 15 use of the high-pressure injection system in relation 16 to its ability to mitigate small breaks?
17 MR. KOLB:
Small break LOCAs?
18 MR. MacDONALD:
Small break LOCAs, thank 19 you.
20 THE. WITNESS:
Would you read the r
21 question back, please.
t
(
l l
22 (Question read by the reporter.)
23 MR. MacDONALD:
Small break LOCAs.
l l
(~h 4._)
24 A
-I don't know that I ever made a distinction of 25 any particular type of analysis by name, only that
l' J
i 4
=1-Walters 399A i
( -
j.
he was responsible for emergency core cooling 2'
+
l 3
systems which were designed to protect the core i:
r 4
in the event of a LOCA condition.
I f
-(
5 (continued on next page.)
I
'6 4
i 7
)
i 8
l
-10 E
11' 12 t
13 i
~14 a.
f 15 T
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-16 l
17 18 19 20 l
6 i
21 s
s.-
22 23 24 u.
l' 25 5
f g.
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. -.,.-, -.,----_._~,,, -.-,,-,,-.,_..
.._m,
1 Walters 400
.f~\\
\\
2 Q
On the last page of Mr. Dunn's 3
February 9, 1978 memo, he concludes with the 4
- sentence, "I believe this is a very serious matter
(
5 and deserves our prompt attention and correction."
6 After reading that sentence, did you 7
consider giving Mr. Dunn a ring on the telephone 8
or walking down to his office and speaking with 9
him personally regarding what he considered a 10 "very serious matter which deserves'.our prompt 11 attention and correction"?
12 A
I don't recall.
O
13 Q
It is a fact, is it not, that you 14 did not speak with Mr. Dunn at or around this 15 period of time either on the' phone or in person 16 regarding the substance of his February 9, 1978 17 memo?
18 MR. KOLB:
You already asked that 19 question or a question which is in 20 substance identical to that.
21 I will let the witness answer it
._.(.
22 again but I think you should try to limit 23 the number of instances where you go over
&()
24 the same ground.
25 A
I did not speak to Mr. Dunn at any time
I walters 401 2
around the February time frame of 1978.
3 Q
Or at any time thereaf ter prior to 4
the TMI-2 accident regarding the subject matter
(
5 discussed in his February 9, 1978 memo?
6
'A I don't believe I ever discussed it with 7
him prior to TMI-2.
8 Q
Did Mr. Goslow and Mr. Street go and 9
discuss with Mr. Dunn the substance of the 10 prescriptions that he set forth in'his February 9, 11 1978 memo?
12 A
I assume that they did.
(~h V
13 Q
Did either Mr. Street or Mr. Goslow 14 report back to you and tell you that they had 15 indeed spoken with Mr. Dunn in or around the 16 middle of February 1978 regarding the substance 17 of his February 9, 1978 memo?
18 A
Yes.
19 Q
Did Mr. Goslow tell you that?
20 A
Yes, he did.
21 Q
was Mr. Street involved in that 22 conversation?
-23 A
-I was not present during the meeting-so I
$)
24 do 'not have firsthand knowledge that he was.
25 Q
Mr. Goslow came back and told you
t 1
Walters 402 i
2 that they discussed the substance of Mr. Dunn's 3
memo with Mr. Dunn; is that correct?
4 A
That's correct.
(
5 Q
Did Mr. Street ever tell you that he 1
6 had discussed the substance of Mr. Dunn's memo 7
with Mr. Dunn and Mr. Goslow?
8 A
I do not recall Mr. Street passing that 9
information along to me.
10 Q
In the course of the conversation i
11 that you had with Mr. Goslow, could you relate 1
12 what you said'to him and what he said to you 13 in words or substance?
14 '
MR. KOLB:
Would you read the
-15 question back, please.
16 (The reporter read back the last 17 question.)
18 MR. KOLB:
I object as to form.
19 I think 'the question is confusf6g.-
I' 20 Q
In the course of the conversation gg-which you had with Mr. Goslow regarding Mr.
22 Goslow's meeting with Mr. Dunn, can you relate 23 to me as best.you recall what Mr. Goslow said to
~
(l 24 you and what you said to Mr. Goslow?
25.
MR. KOLB:
'I think the same' problem
r i
l 1
Walters 403 f~ '.
\\/
2 exists.
The question is confusing.
You 3
seem to be switching from one statement 4
which sounds like it is a description 5
of the conversation to another which is a
(-
6 question that I don't understand.
7 MR. MacDONALD:
I am trying to set 8
up the time and the place of the 9
conversation.
He has testified, I believe, 10 that Mr. Goslow came back and told him 11 that he had a conversation with Mr. Dunn.
12 The question is when Mr. Goslow came back
(\\_)
13 and informed Mr.'Walters of that, what did 14 Mr. Goslow say in words or substance to 15 Mr. Walters and what did Mr. Walters say in 16 words or substance to Mr. Goslow.
17 MR. KOLB:
That's fine.-
18 A
Mr. Goslow, as best as I remember, related 19 to me that he and Mr. Street had talked with 20 Mr. Dunn about the memo _and'my concerns.
He 21 said that -- at least I inferred from his 22 conversation that they had not reached any specific 23 conclusions, however, Mr. Dunn would follow up
/)
24 with a second memo on the particular subject.
\\._/
25 Q
What did you say to Mr. Goslow in
1 Walters 404 2
words or substance during the course of that 3
conversation?
4 A
I don't recall.
(.
5 Q
Did Mr. Goslow tell you that he had 6
spoken with Mr. Dunn regarding your going solid 7
concern?
8 A
I don't recall that specific conversation.
9 Q
You don't recall that specific item 10 coming up in the conversation which".you had 11 with Mr. Goslow?
12 A
That's correct.
13 Q
After your conversation with Mr.
14 Goslow, did you consider going to speak to Mr.
15 Dunn personally to establish what course of action 16 he was taking at the present time?
17 A
I don't recall.
18 Q
Did Mr. Dunn issue a second 10 memorandum regarding the subject of operator 20 termination of HPI. subsequent to your conversation 21 with Mr. Goslow?
22 A
Yes, he-did.
23
'Q Did you receive a copy of that Y'\\
()
24 memorandum?
25 A
Yes, I did.
I 1
Walters 405
. (~g V
2 Q
How did you receive a copy?
3 A
Via the same route I received the first one, 4
from Mr. Bill Street.
(
5 Q.
Who in turn had received it from 6
Mr. Pittman?
7 A
That's correct.
8 Q
Did you receive that memo in the mail 9
from Mr. Street or by hand?
10 A
I don't recall.
11 Q
Did you have any discussion 12 s.ubsequent to your receipt of that memo with Mr.
13 Street regarding the substance of the memo?
14 A
I don't recall that either.
15 Q
Did you have any discussions with 16 Mr. Goslow after the receipt of the second Dunn 17 memorandum regarding either the memorandum or
'18 the substance of the memorandum?
L 19 A
As best I remember, I did.
l 20 Q
was that a conve rsation ' that took place i
I
-(b-21 over the phone or in person?
22 A
In person.
23 Q
Was the conversation taking place in
.m
)
24 you'r office?
A I don't recall.
25,
1 l
L;
.x
1 Walters 406
. A
~ U.
2 Q
Do you recall where it took place?
3 A
No, I do not.
4 Q
As best you can recall, could you
(
5 recount in words or substance what you said to 6
Mr. Goslow at that time and what he said to you?
7 MS. CHATMAN:
Can I have that
-8 question read back, ple a s e..
9 (The reporter read back the last i
10 question.)
(
11 A
I do not recall the substance of that 12 conversation.
0,'
\\4 13 Q
Do you recall anything about the 14 conversation at all?
15 A
I certainly don't.
4 16 Q
Do you recall after receiving Mr.
17 Dunn's second memo coming to the conclusion that 18 your solid concerns still had not been satisfied 10 to your satisfaction?
20 MR. KOLB:
Do you mean his going i
21 solid concerns?
22 MR. MacDONALD:
His going solid Z3 concerns.
- f~'
m) 24 A
You asked did I at some time think about my 25
- concerns not having been acted upon?
I -
A-w 1
Walters 407 3-2 At some point in time, yes.
3-Q Do y u recall ~when that was?
r c
4 A
'Not the exact. time period, no.
l l(
-. 5 Q
Was it shortly after the receipt of 6
the second Dunn memorandum?
7
- A I don't recall.
i
}-
8 Q-Was it prior to the TMI-2' accident?
9 A
Yes.
10 Q
After the receipt of Mr. Dunn's memo,'
~
11 did you consider going to speak.to Mr. Dunn L
- 12 either personally or over the phone regarding 1
L 13 the resolution of your solid concern?.
~
14 MR.. KOLB:
' Going solid?.
'15 MR. MacDONALD:
Going solid, I'm i~
16 sorry, I just use them.synonymously.
~
17 A
I don't recall either way.
18 MR. KOLB:
Off the record [
l 19 (Discussion off-the record'.)
l
~20 (At--.this point,.a recess was taken.)
21-BY MR. MacDONALD:
k
- 22 Q.
Do you recall speaking with Don t
- 23
- Hallman at,any point in time between-the-receipt
[
- 24 of the'second'Dunn. memorandum andfthe memorandum
.25' HY.ou described early'in your testimony that you L
i h
if
,a
..sw,.-.w,
..n.,. - - - -
1 1
Walters 408 U
2 sent to Mr. Karrasch in August of 19787 3
MR, LOLB:
Are you asking about 4
conversations other than conversations
(
5 that might have taken place at or about 6
the time of that August memo?
7 MR. MacDONALD:
Yes.
8 Q
Let's go back and clarify this a g
little bit.
10 What conversations did'you have-with i
-l 11 Mr. Hallman subsequent to the date of the second 12 memorandum and August of 1978 regarding the
-]
13 substance of either the Dunn memorandum or the 14 Kelly memorandum or your November memorandum?
15 MR. KOLB:
It is still not clear 16 whether you mean to include within that
~
17 question conversations he might,have had l
18 with Mr. Hallman around the time of the i
19 August memo.
l 20 MR. MacDONALD:
Any conversation 91 before that memo was sent and subsequent l
l~
22 to the Dunn February 16th memo.
l l
23-MR. KOLB:
So that would include any t
24 conversations at or about the time of that 25 second memo?
,.m,
-v
l l
1 Walters 409
,em
\\'
3 MR. MacDONALD:
Yes.
3 MS. CHATMAN:
Do you mean the Dunn 4
memo or memos?
((
5 MR. MacDONALD:
The second memo, 6
2/16/78.
7 BY MR. MacDONALD:
8 Q
Mr. Walters, can you recall any 9
conversations that you had with Mr. Hallman 10 regarding the issues involved in the Dunn 11 memorandum which conversations took place 12 between mid-February 1978 and the early part of 13 August 1978?
14 MS. CHATMAN:
Which Dunn memorandum?
15 MR. MacDONALD:
The February Dunn 16 memorandum, both, in or about February.
17 I am not trying to place it to a specific
~
18 day or date.
I am just trying t'o make it 19 as easy for Mr. Walters as I can.
~
A The only conversation that I recall is in 20 91 early August or late July.
J 22 Q
You don't recall any earlier 23 conversation that you had with Mr. Hallman after
~}
mid-February 1978 regarding the subject matter of
('J 24 25 either of.the Dunn memoranda?
-1 Walters 410 7-s U
2 A
I cannot recall any discussions of this
'3 particular subject except this late July or 4
August conversation.
(
5 Q
From the middle of February 1978 f
6 until the early part of August 1978, did you 7
have discussions with any individual within B&W 8
regarding the subject matter of the two Dunn 9
memoranda of February 9th and February 16th, 19787 10 A
Yes, I did.
(
.11 Q
Was that a conversation with Mr.
12 Goslow?
/%
\\\\~')
13
- A He was one of the persons.
14 Q
Who were the others?
15 A
The others were Mr. Kane and Mr. Pittman.
4 16 Q
Were these three separate 17 conversations?
18 A
I believe there were two different 19 conversations.
l 20 Q
who was - involved in these two separate 21 conversations?
22 A
As best I remember, I talked to Mr. Goslow, 23 he and I talked, and some other period of time i
(m L
4
)
o4 Mr. Kane, Mr. Pittman and I' talked.
~
\\J 25 g
when did y u speak to Mr. Goslow?
l uDW w
q M '
=
ge-w-
r-t-
e1v--
e+-
+
-1
4 1
Walters 411
' h 2
A I recall that I talked to him at least a 3
couple of times over the period that we are 4
talking about from February to July but not
(
5 any specific dates.
6 Q
Can you recall approximately when 7
those conversations took place?
8 A
I think it was at least in the April /May g
time frame, and the next time I am not sure 10 but it was when he returned from the Florida 11 Crystal River site that year, but I'm not sure 12 exactly when that was.
\\-
13 Q
Crystal River is a nuclear plant 14 operated by Florida Power & Light?
15 A
Yes.
16 Q
In your conversation that you had 17 approximately in April /May 1978 with Mr. Goslow,
~
~
18 could you recount in words or substance what 19 Mr. Goslow said to you and what you sald to Mr.
20 Goslow?
1 21 A
I do not recall the substance of that
.- {
-22 conversation.
23 Q
Do you recall that the subject matter
(~N
' 94 was involving the Dunn memorandum, however?
%)
~
25 A
.The.best I recall is that I mentioned or
e 7 _.
j 4
i
(
,i
?
(
.[ /}
a 1
dalters
/
412 A-k(
.n 2
there was some c'onversation about that ma f.te r}
d
\\
3 Q
Was this a fade-to-face convers a thn ?
4 A-Yes.
f
g C
5 g
Where did',the conversatio.. take place?
s
- N., [
6 A
I don't recall where it was.
t j
3 y
Q Do you recall whether or not you
(
8 initiated the conversation?
g 9
A No, I don't recall that either.
\\*
\\
v 10 Q
During the course of this convhysaticn,
^l v.
s e '.I
- s 11 do you recall whether or not you asked him what i
12 the status was of Mr. Dunn's 2/16 arid 12/9. ( n n
5 1,,.
i s.
/
13 memoranda?
- t
,/
t 14 A
The best 2.Temember, one or the other of us.)
f 15 said something about the'Dunn memorandum', and I
- .s 16 don't recall the specific context of it.
.i s
17 Q
Did Mr. Goslow tell you "that he ' llad 18 spoken to anybody'rsince your last dis 6ussion 19 regarding the Dunn memoranda?
3 -[
s v
A As best I recall, there ~ was something he
-u+
20 related to me that he had ei*cher,* spoken to 21
{
s 99 somebody in Engineering or tha,t he'hadn't.. spoken 23 to somebody.
I cannot recall'exa'ctly whatrthat l'
~
conversation was or any' details of.it.
g4 o
l 25 Q
Do you recall whether or not he told v
~,
\\
/,
1 Walters 413
(_)
4(
2 you that he spoke to a Mr. Cartin in Plant 3
Integration?
f i
4 MR. KOLB:
Could you please repeat
(
5 the question.
6 (The reporter read back the last 7
question.)
8 A
I don't recall that he told me that.
9 Q
Have y u ever learned;at any point i
10 in time prior to today that Mr. Goslow did speak 11 to Mr. Cartin j..' Plant Integra ion sometime 12 between February 1978 and Augu't of 1978?
s 1
13 MR. KOLB:
I just want to interject, l
14 when you say " learned," I take it what<you 15 mean is has he been exposed toJany 16 information which might.suggest that; is 17 that correct?
18 MR. MacDONALD:
That's right'.
19 A
I remember at some time, or something, 20 either the Kemeny Commission or the Rogovin og Commission where that fact came out or did not 22-come out.
I do remember a conversation that he 23 did or he did not talk to Mr. Cartin and-I don't
(
)
24 remember now which one it was.
wJ 25 L
_ _ _ ---_ __--_ _ _ _ _ ---_ ----- _ -_ - - -- J
p e
~
1 Walters 414
'. ;s 2
Q I would like to show you a copy of YO 3
the testimony you gave under oath before the 4
Kemeny Commission at a public hearing held tji
(
5 Wednesday, July 18, 1979 at which on page 157 6
you were asked, "Am I correct in understanding 7
that in conversations you had since your deposition 8
you determined that Mr. Dunn was not contacted is 9
after February 16th but rather Mr. Cartin of 10 Plant Integration was?"
11 Mr. Walters replied, "That's true."
12 Further on on the page you were i
AJ 13 asked, "And you believe Mr. Goslow had perhaps 14 one contact with Mr. Cartin from the time after 15 February 16th?"
16 You replied, "That is correct."
17 I will show you the two pages on
~
18 which that appears.
~
19 MR. MacDONALD:
Off the record..
20 (Discussion off the record.)
l 21 BY MR. MacDONALD:
Q And I will ask you the question 22 l
23 whether you indeed gave that testimony, whether l '[~)
24-indeed you were asked those questions and gave v
25 those answers under oath?
s
~.
1 Walters 415 2
A Yes, I was asked those questions and gave 3
that testimony.
4 Q
Do you recall what the substance of 5
the second conversation you had with Mr. Goslow
({
6 was around the time that he returned from Crystal 7
River in 1978?
8 A
The only thing I remember from that 9
conversation was that Mr. Goslow asked me, and 10 I am not sure of the words, something to the 11 nature or had I received a resolution on the 12 Dunn memos.
4
\\_
13 Q
Do you recall what your response i
14 was?
15 A
No, I do not.
16 Q
Do you recall about what period of 17 timo you had the conversation that you mentioned 18 earlier with Mr. Kane and Mr. Pittman?
~
19 A
It was in the period probably bracketed 20 within a week between the first Dunn memo and 21 the second Dunn memo.
h oo Q
What position did Mr. Kane hold at l
23
.that point in time at B&W?
! - (^'
24 A
As best as I recall, he was an engineer i- (
L L
25 on special assignment or something in the e
I,
I walters 416 Cs) 2 Licensing Department.
3 Q
Do you know who he reported to?
4
.A Yes, sir.
({
5 Q
who was that?
6 A
Mr. Taylor.
7 Q
was Mr.. Taylor the Manager of the 8
Licensing Department?
9 A
That is correct.
10 Q
where did this conversation take 11 place?
12 A
It took place in Mr. Kane's office.
13 Q
was this conversation initiated by i
4 14 Mr. Kane?
15 A
No, it wasn't.
16 Q
Do you recall who initiated the
.17 conversation?
18 A
Either I did or I and Mr. Pittm'an together.
19 I don't remember exactly.
20 Q
Had you spoken to Mr. Pittman before 21 you and Mr. Pittman went to see Mr. Kane?
About this subject?
23 MR..MacDONALD:
Yes, about this I
24 subject.
25 A~
I don't remember in what context we talked
1 Walters 417 rs 2
and arrived at the decision to go see Mr. Kane.
3 Q
But you and Mr. Pittman did have a 4
conversation together before you then went to
({
5 see Mr. Kane?
6 A
I believe so.
7 Q
Which one of you suggested going 8
to see Mr. Kane?
9 A
I don't recall that.
10 Q
Why did you go to see Mr. Kane?
11 A
As best as I remember our conversation was 12 along the lines of what kind of actions or he n.s
~
N 13 questioned me had we taken any action on it and I 14 said that we had and as a result of some ensuing 15 conversation which I do not recall,we decided 16 to go and talk to Mr. Kane to get his opinion 17 on the matter.
~~
18 Q
When you say "on it," do you mean 19 on the Dunn February 9, 1978 memo?
20 A
I believe it to be the first memo.
21 Q
How long was the conversation that 22 you had with Mr. Pittman before you went to see 23 _
Mr. Kane?
. /T '
~4 A
I don't recall that.
0
\\_,)
25 Q
Could you recount, as best you can
)
1 Walters 418 p(
2 recall,what was the substance of the conversation 3
among Mr. Kane, Mr. Pittman and yourself in Mr.
4 Kane's office on this subject?
(
5 A
As best as I recall, Mr. Pittman and I went 6
to him and asked him did he know about the Dunn 7
memoranda and followed up something to the nature 8
of how I was handling it, that we had talked to 9
Mr. Dunn and I don't remember any detail of the 10 rest of the conversation that led to the point 11 about did he think we ought to do something different 12 or was us handling it with Mr. Dunn at that time
[/
~
)
k-13 in trying to get a resolution a proper way of 14 proceeding.
15 Q
What was Mr. Kane's response to your 16 inquiry of him as to whether he knew of the Dunn 17 memoranda and the concerns voiced in it?
18 A
I only remember that he was aware of it.
19 That's all I remember.
20 Q
What was Mr. Kane's response when you 21 explained to him how you were handling the concerns 22 raised by Mr. Dunn in his February 9, 1978 memo?
23 A
The only thing I remember his coming away
()
24 from the meeting feeling that or agreeing that
'q/
25 we were headed in the right direction, that the
1 Walters 419 CE)
~
2 actions so far uas in the correct path to go.
3 Q
Why did you come away with that 4
feeling?
(
5 A
As best as I can recall, it seems.to me 6
that I asked the question when we went in l
7 whether or not Mr. Kane or Licensing or Mr.
8 Taylor was following up on it in a parallel manner, 9
something to that nature, and if he was then, 10 should we continue on or wait for some comment 11 from him and that's about the extent that I 12 remember.
13 Q
What was Mr. Kane's response to your 14 inquiry as to whether Licensing was following up 15 in a parallel manner to what you had already
~
16 done in response to Mr. Dunn's February 9th memo?
+
17 A
I don't recall any; response i n',t h a t area, 18 only that we agreed that the way we were handling 19 it at the moment was O.K.
to continue 'that way.
20 Q
Did you tell either.Mr. Kane or Mr.
21 Pittman that you were handling the matter with Mr.
22 Dunn or that someone else was doing it for you?
23 A
I don't remember in.what context I told him A{}
24 that it was being handled.
25 Q
But you told him that you were l
P e
n
,w i, - -
1 Walters 420
(~h k.)
2 handling the first Dunn memorandum, taking 3
action on it?
4 A
I am not sure that I told him that.
I told 5
him that maybe we were handling it and I don't
(
6 know that we didn't refer to just Plant 7
Performance Service Section.
8 Q
Did you have any subsequent converaations 9
after the one you have just described with either 10 Mr. Kane or Mr. Pittman on this subject prior to 11 the TMI-2 accident?
12 A
I don't recall of any additional meetings 13 or conversations with either one.
14 Q
During the course of that meeting 15 that you described a few moments ago, did Mr.
16 Kane express any of his own views on Mr. Dunn's 17 February 9th memorandum?
18 A
I don't recall.
~
i 19 Q
Did Mr. Pittman?
20 A
I don't recall that, either.
21 Q
Were you aware at the time you spoke 22 to Mr. Kane that he was responsible for the L
23 Preliminary safety concern issues that arose within 24 B&W7 25 MR. KOLB:
Objection as to form.
I
1 Walters 421
(~8 2
It assumes a fact that he was responsible.
3 MR. MacDONALD:
I will rephrase it to 4
make it a little easier.
(
5 BY MR. MacDONALD:
6 Q
Did you know at the time you spoke 7
to Mr. Kane,.the conversation you had with he 8
and Mr. Pittman, whether or not Mr. Kane was 9
responsible for the issues involving preliminary 10 safety concerns which arose within'B&W?
11 A
I was not aware that he was if he was.
12 Q
Did you ever become aware at any
-O
\\
a N/
13 subsequent point in time, prior to the TMI-2 14 accident, whether Mr. Kane was responsible for 15 the preliminary safety concern issues which arose 16 within B&W7 17 A-I believe I became aware of t' hat only after 18 the' fact when-he wasn't any longer -- and I am 19 speaking of the -- around the Kemeny Uommission 20 time hearings or something along that nature.
21
-Q
- You didn't become aware of it prior 22 to the TMI-2 accident?
23 A
I don't believe I did.
24 Q
In or about August of.1978, did you 25 have any conversations with Mr. Hallman regarding
1 Walters 422
/^N
'_]
2 the status of the subject matter involved in 3
the Dunn memoranda?
4 A
Yes, I did.
(~
5 Q
Did you have more than one such 6
conversation?
7 A
I believe I did.
8 Q
How many do you recall having?
9 A
I don't recall'any specific number.
10 Q
Can you describe for me what, to the 11 best of your recollection, you said to Mr. Hallman v
12 in words or substance and what he said to you-s 13 during the course of those conversations regarding 14 the subject matter of the Dunn memoranda?
15
. A As best I remember, I went to Mr. Hallman 16 at sometime late July or the first of August and 17 talked with him about the Dunn memora.ndum and that 18 they were -- if a resolution were to be obtained,
~
19 we had not gotten it yet and that maybe we should 20 write a letter to Mr. Karrasch of Plant L
21 Integration to see if we could come to any
~
(-
k-22 resolution of my concerns on the Dunn memoranda i.
23 if indeed it was necessary to do such.
1 V[ D.
24 Q
What was Mr. Hallman's response?
i
).
25 A
I think I made some comment about sending i-s
1 Walters 423 2
the memo, he agreed that yes, it would probably 3
be a good idea to go ahead and draft a memo and 4
send it to Mr. Karrasch.
(
5_
Q Did he tell you to draft that memo?
6 A
I don't recall that he gave me that in-7 struction.
8 Q
Did you draft the memo?
9 A
I did draft the original draft of the memo.
10 Q
Was it a memo that went out under 11 Mr. Hallman's signature?
12 A
Yes, it was.
s-)
13 Q
Why did you suggest that the memo be 14 sent to Mr. Karrasch?
15 A
Well, it was my feeling that the proper 16 group within B&W or had been established within 17 B&W to bring a resolution between two,different 18 parts of Engineering or Engineering and Services 19 was the Plant Integrations Group, and"also that 20 Mr. Kelly and Mr. Cartin were in that group 21 and I felt this was a good place to get resolution.
k.
22 Q'
Did you give any consideration to 9
23 either.you or Mr. Hallman picking up the phone
("}-
24 and calling Mr. Karrasch to express your concern 25 that you hadn't heard of any resolut' ion on -the
1 Walters 424
~~
2 question?
3 A
I don't believe I entertained such an idea.
4 I don't know whether Mr. Hallman did or not.
(
5 Q
Did you speak to Mr. Goslow at all 6
around this point in time in an attempt to find 7
out' whether 'lus had any further communication with 8
anyone from Plant Integration regarding the 9
subject matter?
10 A
The best I remember Mr. Goslow had come 11 back from a site visit or something and asked me 12 did I have a resolution or had I obtained a
(h
\\-
13 resolution to the Dunn memoranda and that caused 14 me to remember that I had not and that led to the 15 discussion with Mr. Hallman.
16 Q
I would like to show you a copy of a 17 memorandum from D.
F.
Hallman to B.
A.. Karrasch 18 dated August 3,
1978, previously marked as GPU 19 Exhibit 80.
20 MR. KOLB:
Off the record.
21 (Discussion off the record.)
s 22 Q
Hr. Walters, is this a copy of a 23 memorandum that you draf ted for Mr. Hallman's A
(
24 signature on or about August 3rd, 19787 x
25 A
Yes, it is.
1 Walters 425
,/~m
(
^
2 Q
The two references at the top of the 3
document are to Mr. Dunn's February 16th 4
memoranda, is that correct?
]{
5 A
Yes, it is.
6 Q
And those were on the subject of 7
Operator action and the termination of high
~
8 pressure injection?
9 A
That is correct.
10 Q
The first sentence of the first 11 Paragraph in GPU, Exhibit 80 reads, " References 12 1 and 2 (attached) recommend a change in B&W's 13 philosophy for HPI system use during low-pressure 14 transients.
Basically, they recommend leaving 15 the HPI pumps on, once HPI has been initiated."
~
16 Could.you explain how that was a 17 change in B&W's philosophy for HPI use?
18 MR. KOLB:
I think it would be well 19 to finish the sentence.
You cidsed the 20 quote after the comma, not after the end 21-of the sentence, and it could be significant 22 that the remaining part of the sentence
[-
23 qualifies what you read.
['^')._
24 MR. MacDONALD:
Well, if Mr. Walters
%)
25 wants to point that out, "until it can 4
7
1 Walters 426
-(O
\\/
2 determined that the hot leg temperature 3
is more than 50 degrees Fahrenheit below 4
((
5 Q
I don't think that's the part that 6
is a change, but the question, Mr. Walters, is how 7
does that represent a change in B&W's philosophy 8
for HPI system use?
9 A
I don't recall what I meant specifically 10 by a change in B&W philosophy, only that I 11 interpreted it to be different than what I 12 understood to be in our procedures if any i
i s_/'
13 instructions were there at that particular time.
14 Q
Did you know whether instructions 15 regarding HPI use were in place at that time?
16 A
I had a general knowledge of what was in 17 the B&W specific LOCA procedure.
18-Q was what was in that proc 5 dure 19 something that would call for the termination 20 of HPI at some point in time before the RCS 21 system went solid?
22 A
I don't recall coming to that conclusion.
2J Q
How then Nould the recommended change
(~N 24 leaving HPI pumps on differ from the prior LOCA t) 25
~ procedure that you recall was in place at that
i 1
Walters 427
...b 2
time?
3 A
I don't believe I can recall specifically --
)
4 or I don't believe I can recall making a judgment
(,
5 on that at this time.
6 Q
In items No. 1 and 2 in that memo i
7 you were asking, "We believe the following 8
incidents should be evaluated:
"1.
If the pressurizer goes solid 9
I 10 with one or more HPI pumps continuing to operate, 11 would there be a pressure spike before the reliefs 12 open which could cause damage to the RCS?
l 13 "2.
What damage would the water surge 14 through the relief valve discharge piping and 1
15 quench tank cause?"
16 were those two incidents,that you 17' were asking Mr. Karrasch to evaluate, issues that 18 dealt with vessel mechanics?
(
19 A
Yes.
l 20 (Continued on following page.)
t l
21 22 23 (w.
24 r
25
/1 1
Walters 428 0
2 Q
Were they similar to the same 3
questions that you had regarding vessel mechanics
- 4 in your November 10, 1977 memo?
(,
5 A
They were similar.
6 Q
Is this the first time that you can 7
recall either. discussing with anyone or writing 8
to anyone regarding those issues, vessel 9
mechanics, since the November 10, 1977 memo?
10 A
This is the only time I recall addressing 11 that subject to any particular person-other than 12 Mr. Hallman in preparation for this letter.
13 Q
Did you show this memo to 14 Mr. Hallman before he signed off on it?
15 A
Yes.
0 16 Q
What, as best as you can recall, 17 were the words or substance of that'c,onversation?
18 MR. KOLBt He didn't testify 19 specifically that there was a" 20 conversation.
You asked him whether he 21 shoed the memo to Mr. Hallman and he
(
22 answered that question.
23 Q
Did you have a discussion with
'fx j.
24 Mr.' Hallman at that point in time when you-showed
(
y 25-Mr. Hallman this memo for him to sign?
4 i,em in,..,
~ i
1 Walters 429 f's J
2 A
I don't recall.
3 MR. KOLB:
I think it is a good 4
time to break.
It is well past 4:30.
('
5 MR. MacDONALD:
If I could just 6
have five minutes, I think we can complete 7
the memorandum.
8 Q
Did you have any conversations with 9
anyone after August 3, 1978 regarding the issues 10 -
of vessel mechanics that you raised in your memo?
11 I will qualify that by saying prior to the time 12 of the Three Mile Island accident.
(~
13 A
I don't believe I had any conversations 14 where I used the words or concerned " vessel 15 mechanics" at any time prior to TMI.
16 Q
Well, don't limit it necessarily 17 to the words " vessel mechanics."
18 In light of the inciden$s that you 19 asked Mr. Karrasch to evaluate, did yo'u have any 2C conversations or write'any. memoranda which dealt 21 with that subject matter prior to the TMI-2 l
22.
accident?
23 A
The only conversations I remember are
'(m) 24 some in passing conversations with Mr. Kelly.
i l r,!.
'25 Q
When were those conversations?
_n e
1 Walters 430 mU 2
A I'm not certain.
It was sometime during 3
the last part of 1978, I believe.
4 Q
What was the substance of those
('
5 conversations?-
6 A
I seem to remember at one time I asked 7
him was he -- when was he going to respond to 8
this Mr. Hallman memo and he related to me at I'm sorry, I'm getting that confused 9
sometime 10 with later testimony at the Kemeny. Commission.
11 If I remember correctly, he kind 12 of gave me a blank stare and walked off because
'i 13 he did not know of what memo I was talking about.
14 Q
He wasn't copied on this August 3, 15 1978 memo, was he?
16 A
That's correct.
17 Q
Did you or Mr. Hallman ever receive 18 any communications from any of the gentlemen who 19 are listed as cc's on this August 3rd" memo, 20 Mr. Kane, Mr. Phinney, Mr. Street, Mr. Dunn?
I l
21 MR. KOLS:
You are excluding 32 Mr. Walters?
(
23 MR. MacDONALD:
Yes.
')
34 A
I do not recall receiving any. communications l
GJ 95 from those people addressed to myself.
L
.j
1 Walters 431
/~
2 Q
Do you recall now whether 3
Mr. Hallman received such communications?
4 A
I do not recall that he did.
(
5 Q
Do you recall speaking with G
Mr. Hallman at any point in time after this memo 7
regarding the subject matter of this memorandum 4
8 or of the Dunn memorada prior to the TMI-2 9
accident?
1 10 A
Yes, sometime during the late portion 11 of '78 and maybe in '79 but the later part of 12
'78 I asked Mr. Hallman at least twice, I'm not P
13 sure exactly how many times, whether or not we 14 had heard or had received any communication from l
15 Mr. Karrasch on our memo.
11 Q
What was Mr. Hallman's reply?
17 A
I only recall that I did not'get a response 18 that, "Yes, we have received communicEtions" or i
19 "Yes, we have a memo" or something of that nature.
20
. Q Did you at any. time suggest to 21 Mr. Hallman that another memo should be sent out
. 22 on the subject?
23 A
I don't recall.
f,x.
' - s ):
24' Q
You don't recall that you did?
25 A'
or didn't.
l
~
,e
t Walters 432 2
Q Did you suggest to Mr. Hallman that 3
either you or he get in touch directly with any 4
individual within B&W to further follow up on
(
5 this subject?
6 A
The best I remember is as a result of 7
me asking him one day, he made some comment about 8
talking to Mr. Karrasch about the memo.
9 Q
He made a comment that he had spoken 10 to Mr.
11 A
That he --
12 Q
-- Karrasch about the memo?
13 A
That he would take that action to talk to 14 Mr. Karrasch.
15 Q
Did you subsequently speak to 16 Mr. Hallman and find out whether or not he had i
17 indeed followed up and spoken with Mr. Karrasch 18 prior to the TMI-2 accident?
19 A
I conversed with Mr. Hallman at~ least once 20 more that I remember,and he replied that 21 Mr. Karrasch had made some verbal comment that 22 there was no problem and I asked were we going 23 to receive a memo or was is that where the 34 subject stood and I don't remember any ensuing a
25 conversation after that.
g Walters 433 2
Q Did he explain to you what he had 3
understood Mr. Karrasch to mean by his statements?
4 A
No, he did not.
(
5 Q
Did you ask him specifically what 6
he believed Mr. Karrasch meant by his statements?
7 A
I don't recall that I did.
8 Q
Did you ask Mr. Hallman whether or 9
not this meant that the Dunn prescription. could 10 be sent out to customers of E&W?
11 A
I don't recall making that consideration.
12 MR. MacDONALD:
This is a good
/
L-'
13 place to break.
14 MR. KOLB:
O.K.
15 (Time noted:
4:45 p.m.)
16 17 18 James Franklin Walters 19 Subscribed and sworn to before me 20 this day of 1981.
s 22 23 g
24 25
7 1
434 CERTIFICATE 2
STATE OF NEW YORK
)
3
- ss.:
COUNTY OF NEW YORK
)
4 I,
CHARLES SHAPIRo, C.S.R.
and a Notary Public of the State of New York, do hereby certify that the continued deposition of l
JAMES FRANKLIN WALTERS was taken before 8
me on Wednesday, April 15, 1981 consisting of pages 290 through 433 I further certify that the witness had been previously sworn and that the within transcript is a true record of said testimony; That I am not connected by blood or marriage with any of the said parties nor interested directly or indirectly in the matter in controversy, nor am I in the employ of any 18 IN WITNESS WHERE0F, I have hereunto set my 19 hand this hy day of April 1981.
20
(
21 e
- 3
~
CHARLES SHAP o,
C.S.R.
24 25
435 3
1 i
sJ I N D E X WITNESS PAGE
- f....
James Franklin Walters (resumed) 292 E X H I B I T S GPU NUMBER tt FOR IDENT.
133 Handwritten sequence of events attached to site Problem Report of
{^'}
10/11/77 for the Davis-Besse September 24, 1977
'~
transient 302 O
e 1
4
..