ML20072H986
| ML20072H986 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 02/03/1982 |
| From: | Broughton G GENERAL PUBLIC UTILITIES CORP. |
| To: | |
| References | |
| TASK-*, TASK-07, TASK-10, TASK-7, TASK-GB NUDOCS 8306290850 | |
| Download: ML20072H986 (140) | |
Text
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(
UNITED STATES DISTRICT COURT f.
SOUTHERN DISTRICT OF NEW YORK GENERAL PUBLIC UTILITIES CORPORATION,
('
JERSEY CENTRAL POWER & LIGHT COMPANY, METROPOLITAN EDISON COMPANY and PENNSYLVANIA ELECTRIC COMPANY, a
Plaintiffs, 80 CIV. 1683 (R.O.)
-against-THE BABCOCK & WILCOX COMPANY and J.
RAY McDERMOTT & CO.,
INC.,
s-t Defendants.
_ _ _x Continued deposition of GEN $RAL PUBLIC UTILITIES CORPORATION, by T.
GARY BROUGHTON, taken by Defendants, pursuant to adjournment, at the offices of Davis Polk & Wardwell, Esgs.,
One Chase Manhattan P2.aza, New York, New York, on Wednesday, February 3, 1982, at 9':50 o' clock in the forenoon, before Nancy A.
- Rudolph, a Shorthand Reporter and Notary Public within and for the State of New York.
s' L
8306290850 820203 PDR ADOCK 05000289 T
PDR bb DOYLE REPORTING. INC CERTIFIED STENOTYPE REPORTER!
369 LgxtNGTON AVENUE WALTER SHAPIRO, C.S.R.
New Yomsc. N.Y.
10017 CHARLES SHAPIRO, C.S.R.
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156 1
O 2
Appeara n c e s:
3 4
KAYE, SCHOLER, FIERMAN, HAYS & HANDLER, ESQS.
Attorneys for Plaintiff 5
425 Park Avenue New York, New York 6
By:
STEVEN GLASSMAN, ESQ.,
7 of Counsel 8
9 10 11 DAVIS POLK & WARDWELL, ESQS.
Attorneys for Defendants 12 One Chase Manhattan Plaza New York, New York 13 By:
ROBERT F.
WISE, ESQ.,
14 of Counsel 15 16 4
17 18 Also Present:
l 19 NINA RUFFINI 20
(
21 22 23 l
24 l
(
25
1 1
157 1
I) 2 T.
GARY B P. O U G H--T O N,
- resumed, 3
having been previously duly sworn, was examined 4
and testified further as follows:
5 EXAMINATION (Cont'd.)
6 BY MR. WISE:
7 Q
Mr. Broughton, you recognize you are still 8
under oath?
9 A
Yes, I do.
10 Q
Yesterday
,e discussed durkng the course of 11 the testimony your attendance at a meeting in Lynchburg 12 involving the anticipated transient without scram issue.
13 You mentioned that you were there with_a Mr. Courtney i
14 Smyth, I believe?
15 A
Yes.
16 Q
Where is Mr. Smyth now?
17 A
He is now at TMI.
I believe he is the 18 supervisor of TMI-1 Licensing.
19 Q
At the end of the day we were discussing 20 the April 23, 1978 transient at TMI-2.
I believe I had I
21 shown you what has been marked B&W Exhibit 186 which
(_
22 is a copy of the so-called task force report on the 23 TMI transient of April 23, 1978.
I believe you have a 24 copy of that in front of you.
25 A
Yes, I do.
i l.,.
1 1
Lroughton 158 l
2 Q
Am I correct that the task force concluded 3
that in fact flashing had occurred in the reactor 4
vessel?
(
5 MR. GLASSMAN:
That is not what his 6
testimony was.
I think the testimony has been 1
i 7
relating to the reactor vessel head and it has 8
been testified to that respect several times.
9 Q
Is the reactor vessel head in the reactor 10 vessel?
11 MR. GLASSMAN:
I don't think he should 12 answer that question.
i 13 A
Yes.
14 Q
There was flashing in the reactor vessel, 15 isn't that right?
l' 16 MR. GLASSMAN:
Mr. Wise, I mean we are I
17 trying to be precise in the questioning and the l
18 answers and you have already gotten your answer i
19 to this question several times yesterday.
I 20 don't know why we are going over this again.
l l
21 We all know that the head is part of the vessel 22 and it is a particular part of it.
l 23 MR. WISE:
I am just asking.
24 MR. GLASSMAN:
I object to you trying to 25 get something on the record that would seem to
1 Broughton 159 l
O 2
be more imprecise than the testimony supports.
3 MR. WISE:
I don't understand your comment 4
at all and I press the question.
(
5 Q
Was there or was there not flashing in 6
the reactor vessel during the course of the April 23, 7
1978 transient?
8 A
As I recall, our RETRAN analysis showed that 4
9 it was likely that there was flashing which occurred 10 in the head of the reactor vessel and yhe reason that 11 the distinction.is made between the head and the 12 reactor vessel, in general, it was also a conclusion 13 that there was no flashing-in the loops of the reactor 14 coolant system and additionally that there was no 15 flashing in the core region of the reactor vessel.
16 Q
Flashing occurs when saturation has 17 been reached, is that right?
18 A
That is correct.
l 19 Q
And it was your conclusion that during l
20 the course of the April 23, 1878 transient saturation i
21 had been reached in the primary system outside the i
22 pressurizer, is that correct?
j 23 MR. GLASSMAN:
Again, that question also
()
24 has been asked and answered.
I have the same 25 objection as to your last set of questions of l
l
160 1
Broughton 3
\\_Y-2 trying to get testimony that seems to generalize 3
something where the testimony has been very 4
Explicit and the question is purely designed to
(
5 obfuscate the record.
6 MR. WISE:
Are you directing him not to 7
answer?
8 MR. GLASSMAN:
No, he can answer.
9 A
Our conclusion was more specific than the 10 general statement you have provided.
However, it 11 is true that there was flashing in the reactor coolant 12 system outside of the pressurizer.
/~}
13 Q
Aside from the preparation of the task 14 force report, was there other work being done on the 15 April 23, 1978 transient by you?
16 A
There was a second report being prepared 17, on this transient for the purpose of, in.more detail 18 describing the RETRAN analysis performed.
19 Q
Let me show you what has been previously 20 marked as B&W Exhibit 188.
Do you recognize B&W 21 Exhibit 1887 22 A
Yes, I do.
23 Q
Can you describe it for the record?
24 A
This is a technical data report prepared 25 to document the RETRAN analysis performed of the
1 Broughton 161
'o
(~h
~
~
2 April 23, 1978 transient at TMI-2.
3 Q
Is this the final copy of that report?
4 A
To my knowledge, it is the final copy.
(
5 Q
You see there is a list of distribution 6
over on the left-hand side of the page, cover page?
7 A
Yes.
8 Q
Do you know by whom the decision was made 9
as to who would receive copies of this report?
10 A
I don't specifically recall.
11 Q
Were you involved in that decision?
12 A
I normally would have been and I just 13 don't recall if I was or not.
There is no reason why 14 I would not have been involved in that.
15 Q
I note in the left margin of the 16 distribution column several of the names have an 17 asterisk placed next to them.
At the bottom of the 18 page, there.is a notation with an asterisk saying, 19
" Cover page only."
20 Is it your understanding that the people 21 whose names have an asterisk next to them did not
(
22 receive anything more than the cover page of this 23 report?
24 A
Yes.
25 Q
Why was that done, if you know?
1 Broughton 162 (a\\
2 MR. GLASSMAN:
Is the question as to why 3
this is done might have been generally or does 4
this question relate solely to this specific
(
5 report?
6 MR. WISE:
To this specific report.
7 A-I don't have a good enough recollection of 8
the distribution of this report to be able to say.
9 Q
You note in the distribution list the name 10 W.
E.
Potts?
11 A
Yes.
12 Q
Mr. Potts worked for Met Ed, did he not?
t'
(
13 A
Yes.
14 Q
He was in the Licensing Section?
15 A
I believe at that time he was in the 16 Licensing Section.
J 17 Q
Why would he not receive a copy of this 18 report, if you know?
19 MR. GLASSMAN:
You are asking for his 20 knowledge, not speculation.
21 MR. WISE:
Knowledge, not speculation, 4
22 Q
This indicates that he didn't.
Do you know 23 why he did not?
()
24 A
As I said, I don't recall well enough the 25 construction of the distribution list to be able to
.--e--
163 1
Broughton
('b) 2 answer that question.
3 Q
Mr. Seelinger is listed as one of the 4
People who received a copy of the cover page only.
(
5 Mr. Seelinger was an employee of Met Ed, was he not?
6 A
Yes, he was.
7 Q
In fact, he was the technical superintendent 8
for TMI Unit 2, wasn't he?
9 A
I don't know what position he occupied at 10 the time of this event.
l 11 Q
Did you ever know whether Mr. Seelinger 12 was technical superintendent for TMI-2 regardless of O
13 the dates?
14 A
I believe at the time of the TMI-2 15 accident in March of
'79, he was technical superintendent 16 for Unit 2.
17 Q
Whether that is actually true or not, and 18 I believe it is not quite, you did at some point know 19 that Mr. Seelinger was technical superintendent for l
20 TMI-2?
I believe the rec 6rd will indicate, 21 Mr. Broughton, and we have had Mr. Seelinger's 22 deposition, that he was technical support superintendent l
I 23 for a period of time through '78 at some point and then i
24 switched over and became superintendent for Unit 1 and 25 his place was taken at TMI-2 by someone else actually
d 1
Broughton 164
' O O
2 at the time of the accident, but you were aware, were 3
you not, at some poing during the 1978-77 period that 4
Mr. Seelinger held the position at Met Ed of technical
(
5 support superintendent at TMI-27 6
MR. GLASSMAN:
Just so the record is clear, 7
I am not sure that every word counsel uttered 8
regarding Mr. Seelinger's testimony is or is not 9
true.
All we are looking for here is 10 Mr. Broughton's recollection.
E 11 It seems to me a gross waste of time.
He 12 either was or wasn't.
Mr. Seelinger had whatever 13 position he had.
14 Go ahead.
15 A
I have a recollection that sometime 16 Mr. Seelinger was technical support superintendent for 1
t 17 TMI-2.
18 Q
Do you have any knowledge as to why he 19 received a cover page of this report onlyi 20 A
I have no recollection as to what went into 21
. constructing the distribution list of this report.
22 Q
Would you look at page 400-6 of your report.
i 23 It has been marked 0109 for purposes of this litigation
(
i 24 in the bottom right-hand corner.
25 The last sentence on that page reads, l
1 1
Broughton 165
/~N O
2
" Sensitivity runs indicated that approximately 3
5 percent of the upper head flashed at about 86 seconds 4
since this resulted in the best prediction."
(
5 Does that accurately reflect your conclusion 6
after performing the RETRAN analysis as to the amount 7
and timing of flashing in the reactor vessel upper 8
head during the April 23, 1978 transient?
9 A
My recollection is that there were several 10 volumes in the model, in the upper heay in order to be 11 able to match reactor coolant system pressure data.
12 As this paragraph describes, one of these 13 volumes, which was the smaller of the two, was 14 maintained stagnant and was the one in which the 15 flashing occurred.
16 My recollection is that the other volume, I
17 the larger of the two, did not flash during the 18 simulation and therefore the last sentence which reads, 19 "Approximately 5 percent of the upper head flashed 20 about 8f seconds," I believe really refers to the 21 stagnant volume which previously in the next to the 22 last sentence of this paragraph is referred to as the 23 upper / upper head and the only reason I point that out i
1 )
24 is'because 5 percent of the total upper head is a i
25 greater volume than 5 percent of the upper / upper head
166 1
Broughton A
2 anc was modeled in the simulation.
And without doing more review of this document, I can't be sure if there 3
4 were other considerations; but I do see that there is
(
5 a possible inconsistency in the words used in this 6
last sentence with the rest of the paragraph.
7 Q
What is your understanding as to the 8
percentage and timing of the flashing in the reactor 9
vessel head based on all the work you did on the 10 April 23, 1978 transient?
E 11 MR. GLASSMAN:
Are you asking Mr. Broughton 12 to review the entire document now and make some
~
13 analysis?
I think he just answe ed that question.
14 He said that without further analysis he couldn't 15 be more precise.
16 MR. WISE:
If he doesn't know the answer, 17 he can say he doesn't know the answ.er.
We have 18 a sentence here and he says he believes the 19 sentence is wrong.
Now I want to know what he 20 believes is right.
21 MR. GLASSMAN:
Well, I thought he did 22 testify as to what the problem was with that 23 sentence but if he has a more precise recollection
(
24 of actual percentages, he can testify to that.
25 A
My recollection of flashing in the upper
3 1
Broughton 167
/^%
U' 2
head during the April '78 transient at TMI-2 was that the flashing occurred at approximately the time that 3
4 the pressurizer level indication recorded zero inches,
(
5 that it involved a relatively small volume within the 6
upper head of the reactor vessel and that that voiding 7
within the upper head of the reactor vessel had been 8
condensed, the upper head had become subcooled again 9
at perhaps three or four minutes after the initiating 10 event, the reactor trip.
t 11 Q
Did you in the course of your work on 12 the April 23, 1978 transient attempt to determine the A
.,. 6 13 various factors which would influence pressurizer level 14 during the course of such a transient?
15 MR. GLASSMAN:
Could I have that read back?
e 16 (Record was read back.)
17 A
During this analysis work we were attempting 18 to match the code prefixes with measured data.
One of 19 the pieces of measured data which we had was pressurizer 20 level so we attempted to match the code prefix of 21 pressurizer level with the recorded values.
22 In order to do that, we had to make some 23 assumptions about high pressure injection flow since
()
24 that is a factor which influenced level and there was 25 no recorded data for that, so we were in fact looking 4
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14 1
Broughton 168 2
at factors which.could influence recorded pressurizer 3
level as part of this analysis.
4 Q
At some point you in fact made up a chart,
(
5 I believe, showing the various influences on 6
pressurizer level, isn't that right?
You may wish to 7
look at page 400-9A which has been marked 0113 in 8
your report, B&W Exhibit 188.
g A
This report this chart, which you 10 referred to, was not specifically constructed to 11 address factors which influenced pressurizer level 12 but rather to represent the various interrelationships
("
13 that existed during the transient and had an influence 14 on the data which was recorded during the transient.
15 Q
The name of this chart is Transient 16 Parameter Interrelationship.
Do you see that at the 17 top?
18 A
Yes.
19 Q
Would you look at the bottom half of the 20 chart, you see there the box labeled " Pressurizer 21 Level"?
22 A
Yes.
23 Q
There is a box above that labeled " Primary
()
24 System Temperature," a box immediately to its right 25 labeled "HPI Flow" and a box to its left labeled
1 Broughton 169 N'J 2
" Primary System Flashing."
Do you see those?
A Yes.
3 4
Q Beneath the box labeled " Pressurizer
(
5 Level" is a fourth box labeled " Primary Pressure."
6 Do you see that?
7 A
Yes.
8 Q
By the way, who prepared this chart?
9 A
As I recall, this chart was constructed 10 with inputs from all of the people working on the 11 Project, Mr. Harrison, Mr. Trikouros and myself.
12 Q
You participated in this preparation?
\\~'
13 A
Yes, I did.
14 Q
Now, you will note that the boxes labeled 15
" Primary System Flashing," " Primary System Temperature" 16 and "HPI Flow" all show arrows pointing towards 17
" Pressurizer Level."
~
18 What do those arrows indicate?
19 A
These arrows indicate the -- a cause and 20 effect relationship between the information contained 21 in two boxes.
(
22 Q
That is cause and effect relationship betweer.
23 the parameters?
()
24 A
Yes, with the cause being at the tail of 25 the arrow and the effect being at the head.
It is an
1.
Broughton 170 Q/
2 oversimplification of the process, but that's the general 3
intent of this particular diagram, is to show those 4
types of relationships.
(
5 Q
Now, taking primary system temperature 6
as a cause influencing pressurizer level, the effect, 7
could you explain what the interrelationship between 8
that cause and effect is?
In other words, whr.t will 9
a variation of primary system temperature do,in your 10 understanding,to pressurizer level?
{
11 A
Keeping all the other factors-constant, 12 a decrease in temperature would result in a decrease
(")
13 in level.
14 Q
And an increase in temperature vice versa?
15 A
That's correct.
16 MR. GLASSMAN:
Are we looking to the I
17 witness' current interpretation of this chart 18 or to the meaning of the chart at the time it 19 was prepared?
20 MR. WISE:
The meaning of the chart at the 21 time it was prepared.
22 Q
This was prepared before March 28, 1979, 23 was it not?
O(j 24 A
Yes.
25 Q
Now, looking at the box immediately to the i
1
- - ~ -.
1 Broughton 171 G
2 right, which says "HPI Flow," I note there is an arrow 3
g ing fr m that box to " Pressurizer Level."
Do I 4
take it that this indicates that variation in HPI flow
(
5 will cause a variation in pressurizer level?
6 A
That is correct.
7 Q
Could you explain what the relationship 8
is?
9 A
That for this particular transient under 10 consideration, an increased HPI flow, if other 11 influences on pressurizer level remain constant, would 12 cause an increase in pressurizer level.
O l
13 Q
Are there other transients where if 14 everything else remains constant, an increase in HPI 15 flow would have some different effect on pressurizer 16 level?
17 A
There are other transients for which this 18 representation of influences on pressuriz'er level 19 would not be complete.
And, therefore, I'think that 20 this particular set of interrelationships should be 21 considered in light of this cooldown event which would C
22 be analyzed to prevent extrapolations which may not 23 be applicable.
( )
24 Q
You are saying that there are other 25 parameters that might influence pressurizer level?
1 Broughton 172 O\\J 2
A There may be for other transients.
For 3
this particular transient, I believe that this is a 4
complete representation of the influences on
]
(
5 pressurizer level.
6 Q
Now, looking at the parameters that you 7
did analyze here, particularly primary system 8
temperature, HPI flow and primary system flashing, 9
it is true, is it not, that when looking at any of 10 these factors and trying to determine what effect a 11 variation in it would have on pressurizer level, and 12 holding other factors constant, the interrelationship
(
\\'
13 would be the same regardless of the particular 14 transient?
15 MR. GLASSMAN:
Just so the record is clear, 16 I am not clear of the direction of this question.
17 Are we talking about just attempts,to determine 18 influence of these parameters or are we trying 19 to talk now about the actual, whatever 20 influences were determined to exist?
21 MR. WISE:
I am trying to find out what 22 was meant by this chart.
If this chart means 23 that HPI flow only influences pressurizer level 24 in a twin transient that looks exactly like 25 April 23rd, that's one answer.
i 1
Broughton 173 b)
V 2
If, on the other hand, the witness is 3
able to tell us that this chart was prepared 4
with the knowledge that in fact HPI flow would
(-
5 influence pressurizer level in any transient 6
and that that influence would generally be the 7
same, all other factors being held constant, 8
that's another answer.
9 I am trying to determine which it is the 10 witness is s ay'ing.
11 MR. GLASSMAN:
If that was considered at 12 the time.
-\\J 13 MR. WISE:
It had to be considered at the 14 time.
I don't see that as a valid distinction.
15 I see that as a possible way for the witness 16 to avoid answering the question.
Either at the 17 time when this was prepared it was understood 18 i
that this was only applicable to the April 23, 19 1978 transient and if he wants to say that, he 20 can, or it was understood that these factors 21 would generally have the influences shown on 22 this chart.
23 MR. GLASSMAN:
Well, if that was the 24 purpose of the chart.
I don't know what the 25 purpose of the chart was or wasn't, but that is
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+
,an-, -,, - - - - - -,,
-r,--.
- - -, -, - ----, - - - -, - - - -, - - - - -, - ~ - -
20 1
Broughton 174 t' 'l
~
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2 for Mr. Broughton to testify to.
3 MR. WISE:
I don't care what the purpose 4
of the chart was.
I am interested in finding
(
out what he knew as a result of this investigation 5
6 of the April 23rd transient.
7 MR. GLASSMAN:
Well, that's fair.
8 THE WITNESS:
I am ready for a question.
9 MR. GLASSMAN:
All right.
We will put it 10 to you again.
(
11 Q
Let's take a specific HPI flow.
This 12 chart indicates that HPI flow will have an influence n
~
~)
13 on pressurizer level, right?
14 A
It does.
15 Q
All other factors being constant, HPI flow 16 will always have an influence on pressurizer level, 17 will it not?
18 MR. GLASSMAN:
Are you asking now for a --
19 Q
You knew at the time you wrote this that 20 HPI flow would always have an influence on pressurizer 21 level, all other factors being equal?
22 A
If HPI was actually injected into the 23 reactor coolant system, that is a true statement.
()
24 Q
And the influence that it would have on 25 pressurizer level, all other factors remaining equal,
1 g
Broughton 175 p
G w uld be the same in any transient?
2 A
well, again, we did n t apply this 3
interrelationship in a general way to' any other 4
(
5 6
Q That has become obvious after March 28, 1979 and that is what we are attempting to prove here 7
8 but I am now asking the question whether you understood at the time you wrote this that the injection of HPI g
10 fl w w uld have the same influence on pressurizer gg level regardless of the transient, all other factors 12 being equal?
A I d n't recall considering that at the 13 time we constructed this.
I don't recall considering 14 15 all other transients.
The transient we were looking 16 at was a cooldown event and that is what this chart 37 was constructed to deal with.
18 Q
What did you conclude would b'e the effect 19 of the injection of HPI flow on' pressurizer level?
A For the cooldown event under consideration, 20 l
gg HPI flow would have tended to increase pressurizer
(
1*V81*
22 23 Q
Did you ever make an analysis of the 24 March 28, 1979 accident at TMI-27 MR. %ASSMAN:
We are now jumping to a 25
1 Broughton 176
(>\\
2 different time frame?
3 MR. WISE:
Yes.
4 A
Yes.
5 Q
Did you ever consider what effect the 6
injection of HPI flow during that accident had on 7
pressurizer level?
8 A
Part of our analysis looked at the effect 9
of HPI flow on pressurizer level and in particular 10 during the first, I believe, ten minut'es of the 11 transiegt.
12 Q
Did it tend to decrease it or increase it?
7g 13 A
I don't recall the details of the things 14 we looked at, whether we looked at small HPI flows 15 versus large HPI flows but the presence of high 16 pressure injection flow tended to increase the level 17 during the period of approximately the first ten minutes 18 of that transient.
19 Q
The direction of the influence was the 20 same in both the March 28, 1979 accident and the 21 April 23, 1978 transient?
22 MR. GLASSMAN:
Are you asking whether this 23 witness ever made such a comparison?
- O
(_j 24 MR. WISE:
No, I am asking based upon what 25 he knows was a fact as a result of his
y Broughton 177 O
2 investigation of the March 28th accident and what he knew as a fact based upon his 3
4 investigation of the April 23, 1978 incident
(
5 if he is able to testify today that in fact the 6
direction of the influence was the same in both 7
events.
8 MR. GLASSMAN:
You are asking him to make 9
an analysis today of what happened?
I mean the 10 facts are what they are.
E 11 MR. WISE:
Are you directing him not to 12 answer?
You are obstructing this examination.
13 MR. GLASSMAN:
No, I am not.
It is 14 inappropriate for him to make comparisons unless 15 he actually made such a comparison.
For him 16 today to sit here as an expert witness trying 17 to compare different events is wholly 18 inappropriate.
19 You can get this witness' testimony on 1
20 what the facts are and what he recalls and what 21 work he did.
22 MR. WISE:
That is what I am trying to do, 23 whether in fact as a result of that work his
-()
24 conclusion was that the HPI injection influenced 25 pressurizer level in the same direction in both l
178 1
Broughton 2-events.
3 MR. GLASSMAN:
If he made that kind of i
4 conclusion and did that kind of work, fine, then i
/"
he can answer it.
5 6
MR. WISE:
No, I won't take'ithat-kind 7
of a limitation.
I really won't.
You people...
l 8
have really tried to cut us off on our ability 9
to seek effective discovery in this case.
We 10 haven't done it to you and it istbeginning to 11 annoy me.
You have had witness after witness 4
12 of B&W up there and been allowed to ask question
[\\
~
13 after question regarding people',s current 14 knowledge of the system and what they learned i
15 after the accident, whether they went back and 16 compared it to anything they knew before the 17 accident and so on and so forth.
18 MR. GLASSMAN:
I will let you ask those 19 kind of questions if he made that kind of 20 comparison exactly in the way you presented it.
21 Q
In fact, Mr. Broughton, you did conclude 22 following the March 28, 1979 incident that high 23 pressure injection influenced pressurizer level in
( )
24 an upward direction, right?
25 A
We concluded that with regard to the very 1
--n-
--r
--c
179 1
Broughton early state of the transient.
I don't recall at the 2
time how much investigation we did into the effects 3
4 of high pressure injection flow on pressurizer level
(
5 at later stages within the transient.
6 Q
with respect to the April 23, 1978 transient, 7
y u concluded that high pressure injection influenced 8
pressurizer level in an upward direction, isn't that 9
right?
10 A
That is correct.
t 11 Q
Now, look to the left of the pressurizer 12 level box.
There is a box labeled " Primary' System O
kl 13 Flashing" with an arrow pointing towards " Pressurizer 14 Level "
15 Do you see that?
16 A
Yes, I do.
17 Q
Do I
take it that that indicates that 18 primary system flashing had an effect on'the pressurizer 19 level?
20 A
Yes.
21 Q
What was that effect as you found it 22 following the April 23, 1978 incident?
23 MR. GLASSMAN:
And the question is directed 24 to not some general fact but determination,1f any, 25 made by the witness?
4 JAK/1 296 O
C UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK
_x r.
GENERAL PUBLIC UTILITIES CORPORATION,2 JERSEY CENTRAL POWER & LIGHT COMPANY, METROPOLITAN EDISON COMPANY and PENNSYLVANIA ELECTRIC COMPANY, Plaintiffs, 80 CIV. 1683'
-against-(R.O.)
THE BABCOCK & WILCOX COMPANY and J.
RAY McDERMOTT &
CO.,
INC.,
c Defendants. :
__ __ x a
Continued deposition of Plaintiff GENERAL PUBLIC UTILITIES CORPORATION by T.
GARY BROUGHTON, taken by Defendants pursuant to ad j o urn:c e n t, at the offices i
of Davis Polk & Wardwell, Esgs., One i
Chase Manhattan Plaza, New Yo$k, New
~ ~ ' - ~
l York on Thursday, February 4, 1982 at f
10:00 o' clock in the forenoon, before i
I Nancy A.
Rudolph, a shorthand Reporter r(
(.
and Notary Public within and for the State of New York.
r DOYLE REPORTING, INC.
CERTIFIED STENOTYPE REPORTERS 369 LEXINGTO N AVENUE WALTER SHAPIRO, C.S.R.
New Yons:. N.Y.
10017 CHARLES SH APIRO, C.S.R.
l Tel.zpNo NE 212 - 867 8220
1 Broughton 180 C' '~
2 MR. WISE:
Yes, I want to know what effect 3
he f und primary system flashing had on the 4
pressurizer level.
5 A
In the analysis of this overcooling event,
{
6 we found that if there was flashing in the upper head 7
of the reactor vessel, that that would tend to leave 8
more water in the pressurizer than if that flashing 9
had not been present, so the effect would be to provide a greater volume of water in the pressurizer.
10 more 11 The reason I say volume of water to distinguish it 12 from level is because this effect predominantly occurred 1
,/
13 during this transient when the volume was below the 14 indicating range of the level instrument, so while we 15 could show with a code that there was more fluid in 16 the system, it was not obvious from looking at the 17 recorded data that there had been more fruid in the 18 system.
19 Q
Well, that was a lot of words~and let me 20 see if I understood it right.
21 MR. GLASSMAN:
Can we go off the record 22 for a moment.
23 (witness conferring with counsel off the
(~
24 record.)
(
25 Q
Let me see if I understand what you are
i Broughton 131 OV 2
saying.
With the primary system flashing, as you 3
f und it, it. increased the level of pressurizer or not, 4
,all other factors being equal?
5 MR. GLASSMAN:
As determined during the 6
course of uhis particular work?
7 MR. WISE:
That's right.
8 A
In this overcooling event that we analyzed, 9
flashing in the reactor vessel upper head would have 10 Put more water in the pressurizer which if we had been 11 able to see the level would have increased the level 12 that we saw.
(]
13 Q
Why were you doing this anilysis of the 14 April 23, 1978 event?
15 A
There were several things that occurred 16 during that event for which there wasn't recorded data,
.17 for example, the performance of the main, steam safety l
18 valves was unknown in terms of whether or'not the valves i
19 were open, whether they were shut, what position they 20 might have occupied in between, what the flow rate was.
21 There were questions about the response of the l
22 integrated control system which couldn't be answered, l
23 again because of lack of data.
There was also a l
(~')
24 question of the response of the primary system once the C/
t l
25 level in the pressuri'zer went below zero inches and O
1 Broughton 182 p,
~s 2
by performing an analysis with RETRAN in attempting 3
to match the code prefix with the recorded data, we 4
could infer what had taken place with respect to 5
the nonrecorded data.
{,
6 Q
Why did you care particularly about 7
Pressurizer level?
8 A
I think in particular we cared about the 9
things on the secondary side, the safety valves and 10 the control system, and with respect to pressurizer 11 level, the question there was was there voiding in 12 the system and if there was voiding in the system,
. y 13 where was that voiding.
14 Q
So what?
Why was anyone concerned about 15 that at GPU Service?
16 MR. GLASSMAN:
You are not asking the 17 witness to speculate, you are askin,g him if there 18 was any concern?
19 MR. WISE:
Yes.
20 A
well, I don't recall any particular concern 21 about the loss of level indication in the pressurizer 22 because the data that was available showed that the 23 system had remained subcooled and therefore there would C)
/
24 have been adequate cooling of the core and transfer of 25 heat from the core to the steam generators.
3 1
Broughton 183 2
Q Mr. Broughton, maybe I can cut through it.
Is it your understanding and testimony that in 3
4 Performing the work on the task force and in performing 5
the work on this RETRAN analysis and preparing the
[
6 report which is B&W 188, you had no concern with 7
attempting to increase GPU Services and let Ed's 8
understanding of the system and how it worked?
9 MR. GLASSMAN:
Just an objection to form 10 and to the use of the word " concern" here as 11 Opposed in prior questions.
It has apparently 12 different meanings and interpretations.
You are 13 making the record intentionally knelear.
14 He can answer it if he understands it.
15 A
There were certainly other benefits that 16 we wanted to derive from performing this kind of 17 analysis.
There were benefits to us in making sure 18 that the analytical tool that we brought'in to do this 19 kind of work could in fact do it.
There were benefits 20 to us in making sure that we understood what the real 21 cause of this event was and,what took place throughout w
22 the event to make sure that there wasn't something 23 which could be revealed which might otherwise have been j
(
24 overlooked through lack of this kind of analysis.
25 Q
Wasn't it one of the purposes in performing
~
1 Broughton IO4 f~\\
\\
2 this to try to understand the event better and learn fr m it?
3 4
A In a general sense, I would not disagree 5
that that was a goal of doing the work.
6 Q
You say you wouldn't disagree.
That is 7
awfully lukewarm.
Isn't that in fact true?
8 A
If I had to weigh-that' intent with the 9
other intents of the work, I would say that that was 10 Probably one of the things that weighed less' heavily 11 on performing the work.
There were other serious i
12 questions about equipment performance and overall 13 plan-: performance that were really the motivation for 14 Performing this detailed analysis.
15 Q
At the time you did this work, did you 16 know whether anybody at GPU Service Corporation or l
17 Met Ed was concerned about learning from prior transients,
I 18 at TMI-27 t
19 MR., GLASSMAN:
I have the same objection i
i l
20 as before in terms of. lack of clarity and what l
l 21 the question means about " concern" in the
(-
22 context of the question.
23 MR. WISE:
I will take my chances.
l l
{~/
h 24 A
I am not aware of any concern on the part N._
25 of the company with regard to learning from events.
t
1 185 Broughton
)
,J.
2 I think that the intent was to 1 earn from events and 3
certainly in a case like this, events where there was 4
an opportunity to learn, that should have been a purpose 5
that it was put to.
6 Q
Now, looking at this chart which shows the 7
transient parameter interrelationships, was there any 8
intention in your mind to learn from the April 23, 1978 9
transient regarding the interrelationships of the 10 parameters shown on this chart?
t 4
11 A
As I recall the purpose of constructing 12 this chart, it was to,first of all, aid us in performing A
13 the analysis, since it was a rather complex analysis; 14 and, secondly, to be able to use this to explain 15 primarily to other analysts the process we had gone 16 through to conduct the analysis.
17 Q
Did it ever occur to you, Mr. Broughton, 18 that the influence of primary system flaEhing on 19 pressurizer level might be something that'ought to be 20 passed along to the people who were opearting TMI-27 21 A
What occurred to us was that this particular 22 event and the things that happened during the event 23 should be passed along to others.
I don't know --
(
24 I don't recall specifically discussing that the 25 influence of pri, mary system flashing and pressurizer
i Broughton 186 level should have been emphasized.
2 Q
Do you recall ever having a conversation 3
with Mr. Seelinger following the preparation of the 4
task force report concerning whether there had been flashing in the primary system outside the pressurizer?
6 A
I don't recall such a discussion.
7 8
Q Do you recall that Mr. Seelinger had concluded that there had been no flashing in the g
10 primary system outside the pressurizer during the i
e urse of the April 23,-
1978 transient?
11 A
No, I do not.
12 d
13 Q
In fact, the Met Ed report'doesn't mention flashing, does it?
74 MR. GLASSMAN:
Are you asking the witness 15 to reread the whole thing now?
16 MR. WISE:
I am asking him if he recalls g7 18 whether in the Met Ed report there was any menti n f the flashing outside the-pressurizer.
19 A
I recall a poruion of the Met Ed report which discussed what might have happened when the g_
(
pressurizer emptied and the fact that there may have been 22 flashing -- or that there may have been part of the g
ht leg volume occupied by voids but I do not recall O
24 O'
that being a conclusion of the report.
25 y
y - -
-,4
-a e- - -
f 1
Broug h. ton 187
(.
2 Q
Well, would you take a look at page A2-5 3
of the Met Ed report which is a part of B&W Exhibit 186 4
or rather I should say an attachment to the task force 5
report which is B&W 186.
It has been marked for 6
purposes of this litigation as page 0588 in the bottom 7
right-hand corner.
8 A
The next to the last paragraph on that page, 9
which is a part of the a two-page synopsis of the 10 event, reads:
" calculations performed.immediately 11 after the event and subsequent chemistry analysis showed 12 that the core remained covered at all times.
Although
(/)
into one or
\\_
13 the bubble left the pressurizer and went 14 both hot legs, the hot-leg with the bubble, if only one 15 had it, was at least still filled with water halfway 16 up the height of the leg."
17 Q
In fact, Mr. Broughton, your work on the 18 task force and on the RETRAN analysis concluded that
~
19 that description was not correct, isn't that right?
20 A
That was our conclusion.
21 Q
Did you ever get back to anybody at Met Ed 22 to tell them that they had made an incorrect conclusion 23 with respect to what happened to the bubble in the
(~)T 24 pressuri=er and the hot legs?
\\_
25 A
I don't specifically remember talking to
1 Broughton 188
(
2 them.
3 Q
Do you remember having a' conversation with 4
Mr. Seelinger in which you explained flashing in the 5
primary system?
C 6
A No, I do not.
7 Q
Do you remenber Mr. Seelinger saying to 8
you that he did not understand what you were talking 9
about?
10 A
No, I do not.
4 11 Q
Did you ever have a conversation with 12 Mr. Seelinger concerning the task force report?
(k--
13 A
Not that I recall.
14 Q
Did you ever receive any comment back from 15 anybody at Met Ed on the task force report?
16 MR. GLASSMAN:
We are talking about l
17 Mr. Broughton personally?
i 18 MR. WISE:
Yes.
~
i
(
19 A
Not that I recall.
~
l 20 Q
To your knowledge, did anyone at GPU 21 Service undertake to inform the people at Met Ed that 22 GPU Service disagreed with the conclusion that Met Ed 23 had reached concerning the bubble in the pressurizer
(
24 and the hot leg?
25 A
To my knowledge, the task force report was 1
w 1
Broughton rx i
\\
\\~l discussed with people at Met Ed.
2 3
Q Who had that discussion?
4 A
I don't recall.
5 Q
Y u did n t?
6 A
I did not.
7 Q
We have asked Mr. Keaten and he said he 8
did not.
Is there anyone else whom you suggest we 9
should ask?
10 MR. GLASSMAN:
We are not,asking for general 11 suggestions of the witness, Mr. Wise.
I mean, 12 obviously you are free to ask anyone you wish.
/~~N
(_)
13 If this witness has particular knowledge, you can 14 obtain that, but we are not here to give the 15 witness general suggestions as to how you should 16 approach your case.
{7 MR. WISE:
I agree that the form of the 18 question is probably improper.
I can put it
~
i 19 into proper form.
l 20 Q
Mr. Broughton, do you have any information 21 or knowledge as to wh'o within GPU Service, if anyone, k-22 actually conducted any conversations with people from 23 Met Ed concerning the task force report and its 24 e nelusions?
25 MR. GLASSMAN:
I think the witness already
1 Broughton 190 2
testified that his recollection was that there 3
were such conversations.
4 MR. WISE:
Now I am asking if he has any 5
knowledge or information as to who it is.
6 A
I don't and I note in reading the 7
introduction of the task force report, it says that 8
such discussions were held but it does not indicate 9
who held them.
10 Q
Would it surprise you if It told you that 11 Mr. Seelinger has testified under oath that you were
-12 the one who discussed it with him?
13,
A It would not surprise me because I stated 14 I do not recall.
15 Q
I see.
You are saying you may have 16 discussed it with him but now you don't remember one 17 way or another?
d 18 A
I said I'do not recall discussing the report i
19 with anyone at Met Ed.
I did not deny discussing the 20 report with anyone.
21 Q
I misunderstood your earlier testimony.
(
d 22 My telling you that Mr. Seelinger has given 23 that testimony does not help refresh your recollection?
()
24 A
No, it does not.
25 (Recess taken.)
-v w,,y g
,_..-_m
1 Broughton 191 2
BY MR. WISE:
3 Q
Before the break, Mr. Broughton, we were 4
discussing B&W Exhibit 188 and your RETRAN analysis 5
report on the April 23, 1978 incident and, particularly,
(
6 we were looking at figure 400-1 in that report which is 7
at page 0113 for purposes of this lawsuit.
8 Beneath " Pressurizer Level," there is a 9
box labeled " Primary Pressure."
There is an arrow going 10 from the box labeled " Pressurizer Leve toward the 11 box labeled " Primary Pressure."
12 Do I take it, Mr. Broughton, that that was
~T
[\\~)
13 meant to indicate that a change in pressurizer level 14 would have-an effect on primary system pressure?
15 A'
Yes.
16 Q
Is it true that a drop in pressurizer level 17 would result'in a drop in primary pressure, all other 18 things being equal?
19 A
Let's see, the other thing that we have to 20 consider here is primary system flashing since that's 21 the other factor that could influence primary pressure.
22 Q
Let me first ask you this.
Primary system 23 flashing would not occur immediately upon a drop in 24 pressurizer level, would it?
25 MR. GLASSMAN:
Are we asking now some
1 Broughton 192 I
2 hypothetical question or understanding at the time the chart was prepared or what?
3 4
Q Mr. Broughton, it was your understanding at the time you prepared this that during normal
{
5 6
peration of a pressurized water reactor such as at 7
TMI-2, there is a subcooling margin maintained in the g
primary system, isn't that right?
A That's correct.
9 10 Q
Consequently, an initial drop in pressure 11 will not result in immediate saturation in the primary 12 system, all other things being equal, beginning from
(~\\
T-13 all perating levels, is that. correct?.
A That's not entirely correct.
The'Trimary 14 15 System Flashing" box that we have indicated here 16 encompasses the loops, the reactor vessel and in g7 particular the upper head of the reactor vessel and 18 you will note that the relationship betwe'en primary 19 system flashing and pressure is different-from the 20 relationship between most other pairs of parameters here in that in this case, it is not a clear cause 21 f
22 and effect relationship between flashing and pressure.
23 Flashing can cause changes in pressure and pressure 24 changes can cause flashing, so this relationship here
(
was a little bit more complex.
25
r i
Broughton 193 O
~
O 2
Q Well, a change in the pressurizer level has some effect on primary pressure, we are clear on 3
that?
4 A
No, we are not clear on that.
It would 5
{
6 depend up n the condition of the primary with respect 7
to flashing. Given that:the. primary is subcooled in all 8
of its parts and that there are no voids in the primary, then it is true that a pressurizer level change would g
10 have a direct effect on primary pressupe.
11 Q
Let's take that case first.
Is it correct 12 that a decrease in pressurizer level would correspond 13 to a decrease in primary system pressuie, again assuming 14 all other factors equal and assuming no primary system 15 flashing?
16 A
For this transient, that is correct.
I 17 should also add that as we start to talk about the 18 relationship between pressurizer level an'd primary 19 pressure for this transient, it is not the same 20 relationship as exists during normal operation in that we have left out other influences on primary 21 22 system pressure.
23 For example, during normal operation, 24 pressurizer level can be changed without changing 25 primary pressure because there are heaters in the
194 1
Broughton 2
Pressurizer which affect primary pressure.
There is the capability to put spray flow into the pressurizer, 3
4 so,'again, I think that points out the applicability of this particular interrelationship to the transient
(
5 6
under study.
For that transient under study, if there 7
8 was no primary system voiding, a change in pressurizer level would have a direct effect on primary system g
10 Pressure.
it Q
Where I started in this was trying to get 12 what that effect was.
Can we not agree that a drop
~
13 in pressurizer level, all other factors being equal, results in a drop in primary system pressure?
14 15 A
A drop in pressurizer level will drop 16 Primary system pressure if there is no voiding in the i
17 primary system.
~
18 Q
And other factors are equal?
t 19 A
The only two factors that we would be 20 considering here would be level and primary system i
21 flashing.
We would not be considering heaters or' spray because we are restricting this to an overcooling 22 l
l 23 transient.
i.
g We w uld n t be c nsidering HPI flow, 24 25 Primary system temperature and perhaps other parameters l
l
- l. __
1 Broughton 195 2
that might influence primary system pressure, right?
3 A
The effects of temperature and HPI flow are 4
not directly on primary system pressure.
Those are 5
effects on the pressurizer level for this relationship.
(
6 Q
You understand that changing the primary 4
7 system temperature can have an effect on primary 8
system pressure in a pressurized water reactor, do you 9
not?
10 A
The effect is not a direct.effect.
It is 11 an effect first on. pressurizer level which then affects 12 pressure and probably to be even -- if this were to O
13 be extrapolated to a more general case, there is really l
14 a relationship between primary system temperature and 15 primary system flashing which we haven't shown here, 16 again because it was not important for this transient.
17 Q
Now, between the box labeled," Primary
~
18 Pressure" and the box labeled " Primary Flashing" are i
I 19 two arrows, one going from " Primary Press'ure" to 20
" Flashing" and one going from " Flashing" back to 21
" Pressure."
t 22 What is the meaning of that?
23 A
What we were indicating by this was that a l(
24 decrease in primary system pressure could lead to 25 primary system flashing.
When the primary system was
2 i
Broughton 196
/
N,.J '
2 flashing, that could influence primary system pressure.
3 9
8 "2 A
In the particular case we looked at here 4
f r vare ling, flashing tended to reduce the rate of 5
6 pressure decrease compared to a case where there was 7
no flashing or where there was a different amount of --
8 a lesser amount of flashing.
9 Q
Are you saying that it tended to stop the 4
10 continuing decrease in primary system pressure?
11 A
It didn't stop the decrease but it slowed 12 the rate of decrease.
13 Q
During the TMI-2 accident'on March 28, 14 1979, it is a fact that as a result of the primary 15 system reaching saturation during the early minutes 3
^
16 of the transient, primary system pressure halted its 17 decrease?
[
ig MR. GLASSMAN:
You are.asking for the l
19 results of Mr. Broughton's analysis?
MR. WISE:
Yes.
20 21 THE WITNESS:
Would you reread that back.
MR. WISE:
Let me lay more of a foundation.
22 23 I may have jumped into it too fast, f ( ).
24 Q
I want to now change your attention for l
l 25 a m ment to the March 28, 1979 accident at TMI-2 which I
I
- 3 1
Broughton 197 I
(~'\\
2 you have testified earlier you did make certain 3
investigations about.
4 A
Yes.
((
5 Q
You learned, didn't you, that during the 6
course of that transient, primary system pressure 7
. decreased during the early stages of that event?
8 A
Yes.
9 Q
At some point it got down under a thousand 10 psi, I believe, is that right?
t 11 A
I would add, however, that before it had 12 decreased to a thousand psi, there was always a period C'4 13 in which it increased for a short period of time and 14 then decreased.
15 Q
But eventually during the early stage of 16 the transient, it got down somewhere to a thousand psi, 17 you understood that?
18 A
Yes.
19 Q
You understood that flashing occurred in 20 the primary system after about six minutes?
21 MR. GLASSMAN:
Understood when?
Are we 22 talking about after the fact of his analysis?
23 MR. WISE:
Yes.
()
24 A
Yes.
25 Q
It is also a fact, isn't it, that primary
1 Broughton 198 i
/^)
after V
2 system pressure stabilized during the first the first 20 minutes of the transient approximately?
I 3
won't tie you to one minute as opposed to another, but 4
within that range?
5
{
6 A
That is my recollection, primary pressure stabilized about 20 minutes.
7 g
Q That is because the primary system had 9
reached saturation, was it not?
10 A
Yes.
t 11 Q
Mr. Broughton,.did you ever make up a chart 12 of the transient paramater interrelationships for the C
13 March 28, 1979 accident similar to the' chart that you 14 prepared for the April 23, 1978 accident?
13 A
I don't believe that such a chart was
^
16 prepared for the March '79 accident.
17 Q
Let me ask you one other question, a series 18 of questions about the April 23rd incident.
19 During the course of that incident, HPI was 20 initiated, i. s that right?
21 A
Yes.
22 Q
Do you remember appro::imately how far into 23 the incident HPI came on? Was it a matter of minutes,
(~)
24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />?
V 25 A
I believe it was within the first minute
1 Broughton 199 r\\
k) and a half.
9 2
Q A tually HPI ame n twice during that 3
incident, isn't that right, it came on again about 4
44 minutes into the transient?
5
{
6 A
I don't recall that part of the. transient.
7 Q
In any event, looking at the first HPI 8
initiation, which I believe you are correct occurred in the first minute and a half or so of the event, 9
10 did y u ever become aware of whether the operators took manual control of HPI?
gg 12 A
I recall trying to determine what had been h('s -
13 done with high pressure injection flow'since it was an unree rded parameter.
I don't recall all the details 14 of what we found when we looked at that but our attempt 15 16 was to find out what the flow might have'been versus time since it wasn't recorded and it had an influence 17 18 on the analysis work.
19 Q
What did you find out?
A As best I recall, there had been an estimate 20 made by people at Met Ed that high pressure injection 21 flow had been reduced by securing, I believe, one pump 22 at a certain time in the sequence and I believe after 23 ur analysis, we thought that the actual securing of 24 that pump may have taken place later.
25
1 l
1 Broughton 200
~
2 Q
Did you ever have an opportunity to discuss 3
with anybody from Met Ed why the operators had secured 4
the HPI pump?
5 A
No.
6 Q
Who had the conversations with the operating 7
staff concerning the securing of the pumps?
8 A
I don't know who conducted discussions with 9
the operating staff.
10 MR. WISE:
Let me have marked as B&W 11 Exhibit 388, a copy of some handwritten notes, 12 which I believe were produced to us from 5-13 Mr. Broughton's files.
14 (Multipage document consisting of handwritten 15 notes dated 4/23/78 and graphs. bearing production 16 numbers. 1313-9194 through* 1313?919h' marked.B&W 17 Exhibit No. 388 for identificationi as of1this 18 date.)
19 Q
Mr. Broughton, do you recognize B&W 3887 l
20 A
No.
l 21 Q
Do you know whose handwriting that is in?
s 22 A
No.
l 23 Q
Have you ever seen it before?
(
24 A
I don't know whether I have or not.
25 Q
Do you know someone named J.
Flint who works
O 201 1
Broughton f)
\\_/
at GPU Service?
2 A
Yes, I do.
3 4
Q Who is Mr. Flint?
A I d n't know that he works for GPU Service,
{
5 6
but Jo:in Flint.
7 Q
Where does Mr. Flint work?
8 A
I believe he was working with the startup and test group and at one time he was a B&W employee.
9 10 I don't know who he is employed by now.
11 Q
During the period immediately following the 12 April 23, 1978 transient, do you know who he was working
~\\
(d 13 for?
14 A
Nor for sure.
15 Q
Did you ever see any sequence of events 16 prepared for the April 23, 1978 event by'the operating 17 staff?
18 A
I believe there was a sequence of events 19 as part of the operating staff's report, which I saw.
20 Q
Let's take a look at that.
It begins, I 21 believe, at page A2-8 of B&W Exhibit 186 which has been 22 marked for purposes of this litigation as page 0591.
~
23 If you will look at the second page of the sequence of
(
24 events, which is the following page in the exhibit, you I
25 will n te at the time marked for one minute and eleven
1 Broughton 202 seconds into the transient, there is a notation, " safety
)
2 inje tion A and B side due to low pressure. 1630 psig."
3 4
Do you see that?
A Ye.,
I do.
6 Q
That would refer in your understanding of it to the high pressure injection pumps, is that right?
7 8
A Yes.
9 Q
Further down the page, there is a notation 10 at 1:17, " Safety injection bypassed."
t 11 Am I correct, did you understand at the time i
12 that that simply meant that the automatic feature of 13 the system had been bypassed, not necessarily that the 14 actual flow through the pumps had been throttled?
I 15 A
It did not mean that pumps that flow 16 through the pumps had been throttled.
I'believe that i
17 bypassing safety injection does more than simply 18 prevent automatic initiation.
It permits certain 19 components to be manually controlled and it may do other things but it does not mean that in fact other 20 l
21 things were done to change flows or component status.
22 Q
Y u will note at the time labled one minute 23 and forty seconds, there is a listing of HPI flows.
I A
Yes.
24 25 Q
There is an asterisk notation, by the way, l
l 1
203 1
Broughton 2
there, with respect to the first two HPI pumps, A and 3
B, and the notation says, " Flows low primary due to 4
MUV 17 and 18 being open."
5 Do you know what that referred to?
(
6 A
No.
7 Q
Do you have any idea what the MUV 17 and 8
18 are?
9 A
They would be valves in the makeup systen.
10 I don't know what particular function,those valves 11 would perform.
12 Q
Now, you note at one minute and forty-eight
(^h
(_/
13 seconds into the incident there is a notation that 14
" Pressurizer level restored to the indicating range."
15 Do you see that?
16 A
Yes.
17 Q
Was it your understanding of the incident 18 that pressurizer level had gone off scale ~ low at sometime 19
.before one minute and forty-eight seconds?
20 A
Yes.
21 Q
In fact, there is a notation at one minute L
22 and eight seconds where it went off scale low?
23 A
Yes.
(~T 24 Q
Do you have a recollection of what pressure b
25 was doing at one minute and forty-eight seconds into
1 Broughton 204
(~)h the incident?
It was still decreasing, was it not?
(_
2 MR. GLASSMAU:
We are not asking for an 3
4 interpretation of this particular chart here, or 5
are we asking for some recollection of 6
Mr. Broughton's?
7 MR. WISE:
Yes, based on the investigation 8
that he made.
9 A
Yes, pressure was still decreasing at one 10 minute and forty-eight seconds.
(
11 Q
As a matter of fact, if you will look on 12 the next page at the time marked three minutes into 13 the incident, there is a notation that'"RCS pressure 14 reached its lowest value of 750 psig before turning 15 and increasing."
16 Do you see that?
17 A
Yes, I do.
18 MR. GLASSMAN:
Which page~are we now talking 19 about?
20 MR. WISE:
The page marked 0594 for purposes 21 f this lawsuit.
(-
22 MR. GLASSMAN:
Two pages after the one we 23 a,r e on?
MR. WISE:
I thought it was only one page.
(~5 24
\\_
25 My copy of the exhibit seems to be missing a page.
I
i i
Broughton 205
(^)
2 THE WITNESS:
They are out of order for a 3
g d reason.
They appear to be mislabeled in the 4
task force report and perhaps in the Met Ed 5
report.
6 Q
In fact, it appears that page 9 follows 7
page 7 and page 8 follows page 97 g
A Yes.
9 Q
In any event, having cleared that up, it is 10 clear that the page marked 9 continues a sequence of t
11 events that is carried on the page that is marked 77 12 A
Yes.
(O
,)
13 Q
Turning back to where we were, pressurizer g
level was increasing after one minute and forty-eight 15 seconds, right?
16 A
Yes.
17 Q
And primary system pressure was still 18 decreasing at that time?
19 A
Yes.
20 Q
And continued to decrease for another minute and twelve seconds before turning around, right?
21
(-
22 MR. GLASSMAN:
Do you want his recollection 23 or some interpretation of this chart?
MR. WISE:
I want his recollection based on 24 25 the investigation he made.
1 Broughton 206 A
2 A
Well, I certainly don't recall the exact 3
times at which these events occurred.
These times 4
don't appear to be particularly out of order and I would 5
agree with the sequence of level going off scale, level
(
6 coming back on scale and then pressure beginning to 7
increase.
(
8 Q
In fact, you were aware during your review 9
of the April 23rd incident that at least for that minute 10
.and twelve seconds indicated in this s quence of events 11 primary system pressure and pressurizer level were 12 trending in opposite directions, were you not?
iO i,_)
13 A
I don't recall ever having come to a 14 recollection that would have used those words.
I do 15 recall that pressure was decreasing and level was 16 off scale low.
Level was regained and started to 17 increase prior to tha pressure beginning to increase.
18 Q
Did anyone ever, to your knowledge, h a*ie any 19 discussion with the operators concerning what their L
20 perception of that relationship between pressurizer 21 level and pressure was?
22 A
I don't know-of any such discussions.
23 Q
Did anyone indicate to you that the operators 24 were in any way confused by the fact that pressure and 25 pressurizer level were going in opposite directions
3 1
Breughton 207 O
2 during the.t part of the transient?
A I d n't recall anyone indicating that.
3 4
Q Did anyone look into whether the operators 5
had taken any action with respect to HPI based upon what 6
they saw?
7 MR. GLASSMAN:
Let me just object.
I note 8
there has been no foundation laid for what it is l
9 the operators actually saw as opposed to what 10 appears in the sequence of events as such, i
11 MR. WISE:
You mean you won't let me ask 12 this question unless we had the operators in here
)
and they all testified to this?'
13 14 MR. GLASSMAN:
I don't know if it is a e
15 fact.
We know there are differences between what 16 operators may actually have seen, understood or 17 what happened in terms of after-the-fact analyses 18 or what people were able to piece together.
19 Q
You didn't become aware the re-was any 20 loss of instrumentation during the April 23, 1978 21 transient, did you, on pressure or pressurizer level?
22 A
I am not aware of any instrumental functions 23 that would have rendered those instruments unusable.
f 94 Q
Nobody ever reported that to you during m
~
(
25 the course of all the work that was done on the i
1 Broughton 208
(~).
2 April 23, 1978 incident?
\\_
A No.
3 4
Q Now, going back to my original question, did 5
anyone look into whether the operators took any 6
action with respect to high pressure injection during the course of the April 23, 1978 transient based upon 7
8 the fact that pressure and pressurizer level were going 9
in opposite directions during the time period we have 10 indicated?
11 MR. GLASSMAN:
You are talking about this one 12 minute and twelve seconds or so?
13 MR. WISE:
Yes.
~
14 A
I don't know of any discussions with the 15 operators about what the basis for their actions were
^
16 with respect to what they observed.
17 Q
And you don't know at this point when they 18 actually did throttle HPI?
Or how much they throttled 19 it?
20 A
I do n t know what the high pressnre 21 injection flows were versus time because that is.not
(
(-
22 a parameter which is reported.
l 23 Q
But there had been an effort during the
/"
24 investigations following the April 23, 1978 event, to b) j 05 your knowledge, to pin that down, had there not?
l 1
1 Broughton 209 s/.
2 A
It was an effort to try to determine what the most likely flows versus time were for the purpose 3
of inputting that to the model and the results of 4
that effort suggested that there was more flow --
r 5
6 the results of the modeling analysis suggested there 7
was more flow than what the plant's sequence of events 8
had indicated might exist.
9 Q
I guess what I am trying to get at now, 10 Mr. Broughton, is the extent to which you have knowledge 11 of the lengths to which the investigation went to try 12 and find out from the operators and from the hard data n
k) 13 that was available following the incident what the 14 flow rates were.
15 A
I do not know --
16 Q
Let me put it another way.
People did 17 try and find out from the operators what they had done 18 with HPI flow, didn't they?
19 A
There were certain questions about HPI flow 20 that they were trying to get answered.
I don't know 21 that they tried to find out everything that the
(-
22 operators did with respect to HPI flow and what the 23 basis for them doing it was.
24 Q
Let's put aside for the moment the basis 25 f r what they did.
I just want to know whether anybody f
rw
.sv7-wr r
- + + *
--***w----m-----
w-
---=w---
-e
~~-wee
+ - -
--'e-
i Broughton 210
.A(~j at GPU Service ever got any better information from the 2
3 perators or any hard data that was available following 4
the April 23rd incident concerning what the flow rates were besides what we have here before us?
5 6
A I don't know if there is any better data 7
than this scenario.
8 Q
None ever came to your attention?
t.
3 y
A The only thing that came to my attention s
10.,
on high pressure. injection flow was that based on the a
11 analysis,we believed that HPI flow was maintained N7 12
' longer than was reported by this coquence of events.
l t
13 As I recall, that was commented on in either the task f rce report or in the RETRAN analysis report.
That is
- 14 15 the only thing I recall about the results of looking 16 atthigh pressure injection flow.
1 And you don't remember sitting here today 17
- Q
\\'
18 any.othed investigation or report or set of conclusions j,
~
conce'ning HPI flow derived from the operators or the r
19 s
h ',
20 hard data'besides what you have got here?
21 i N o,, I don't.
A 22
.Q Andsjust so I am sure I am reading this m
23 right, this doesn't tell you, these three pages, do not
\\_\\ --
24[
q.
g-tell'you when they: throttled back HPI?
/ ~,
' 'ghe thing I read on these pages is that t
N; 25 A
S, a
w j
3'
211 1
Broughton 2
time, three minutes, on page A2-11 of the task force v.
3 rep rt, a note which says " Stopped MU -1C, opened 4
MUV-36 and 37."
5 Q
MUP-1C would refer to one of the high
{
6 Pressure injection pumps?
A That's correct.
And my recollection is that 7
8 the analysis showed that it was unlikely that the pump was stopped this early because if it had been, we vere 9
10 not able to match calculated pressurizer level with it recorded pressurizer level.
I don't k.ow that'we 12 determined what an appropriate time for stopping that 13 Pump was but I do recall that we felt, ~ based on the 14 analysis, that the pump may have been stopped later 15 than that which would indicate that there was actually
^
16 more high pressure injection flow beyond three minutes 17 that this sequence would lead you to believe.
18 Q
Did you ever determine who the operators 19 were who were on duty on April 23, 19787 -
20 A
I did not.
21 Q
Y u never had any personal discussions with 22 them to determine their recollections of the event?
23 A
No.
O 24 Q
D you know if anyone from GPU Service N) 25 conducted such interviews?
i Broughton 212
>O 2
A I don't know of any that were conducted by 3
Service Company people.
4 Q
Did anyone ever determine what procedures were in use by the operators during the course of the 5
6 April 23, 1978 transient?
7 A
I don't know if anyone did that or not, g
Q You are not aware of anyone having done it 9
from the Service Cor pany, in any event?
10 A
I am not aware of anyone a the Service 11 Company or anywhere else having done that.
12 Q
Did anyone at the Service Company ever 13 consider the question whether operator' action during 14 the course of the April 23, 1978 transient had been 15 correct?
'onsidered.
16 A
I believe that question was c
17 Q
By whom?
18 A
I recall discussing it with others and I am 19 not sure who the others were.
A discussion was in 20 relationship to an action that the operators took with 21 feed pumps following the initiating event.
22 Q
Is that the only area of examination within 23 the Service Company of operator action during the O) 24 transient?
25 A
That's the only one I recall.
213 1
Broughton O
\\_).
2 Q
B&W 188, which was your RETRAN analysis of the April 23rd event, has on it a stamp on the cover 3
4 page which reads "GPU System Libraries - TMI. "
Do you see that?
5
{
6 A
Yes.
7 Q
Do you have any knowledge or information 8
as to what that stamp indicates?
A No, I don't.
g 10 Q
Have you ever heard of som,ething called 11 the GPU System Libraries - TMI?
12 A
I don't remember hearing it.
0)
(
13 Q
I believe Mr. Keaten testified that there 14 was a technical document center maintained somewhere in 15 Parsippany.
Are you familiar with that?
16 A
Yes.
17 Q
Is there also a GPU library of some sort at 18 Parsippany?
19 A
There is a library, which is independent of l
i 20 the technical functions department and it is located 3
21 in Parsippany.
One of its branches is located in 22 Parsippany.
23 Q
Who assigns a TDR numbers to a report?
(~h 24 MR. GLASSMAN:
Now, then?
When?
V 25 Q
Let's.say during the period following the
1 Broughton
.214 O
V April 23rd transient which was, I believe, the start of 2
the TDR system and then you can tell us if it has been 3
changed since then.
4 A
As I recall, the number was assigned by an 5
individual who was involved with document control.
I 6
don't recall who that individual was but it was a 7
8 centralized numbering system and that individcal l
would assign a number when you identified that report 9
10 that was going in the system.
gi Q
Is that someone in the technical document 12 conter or some place else?
13 A
It would have been someone within technical functions and they probably would have had 14 a relationship with the document center.
I don't know 15 what that relationship was.
16 17 Q
Is there any kind of a form that one fills 18 out or did during this period to have a TDR number 19 assigned to a particular project?
A Not to my knowledge.
20 21 Q
well, f r instance, this one is marked TDR No. 006.
What is your recollection of how you got 22 23 that number for this report?
A My recollection is that a phone call was 24
%)
made to the individual who assigned numbers and a number 25
1 Broughton 215 O(-
2 was assigned for a document with this title.
3 Q
Diil you have to tell the person at that 4
time the title or name of the report?
5 A
I am not sure.
6 Q
Do you know whether that person kept 7
any log or listing of the various numbers what were 8
given out?
9 A
I don't know, but since the numbers were 10 assigned sequentially, I would imagine some log was 11 kept.
12 Q
Is it like the lottery and you call up, he
\\_)
13 could give you some sort of a number,4you don't know 14 one way or another whether he kept a log.or what kind 15 of indices were kept?
16 A
No, I don't.
i 17 Q
There was a transient at TMI-2 on l
18 November 7, 1978, I believe.
We have discussed it 19 in brief earlier in your testimony.
2p A
Yes.
21 Q
You did some work in connection with that, 22 I believe?
l 23 A
Yes.
l l
(~)
24 Q
How did you come to work on that?
I
\\_/
l 25 A
I don't recall.
I l
.=
216 2
i Broughton f
i f\\
1 2
Q What kind of work did you do?
)
A I recall 1 king at the data from the plant, 3
4 generated right before and during and after the transient.
I recall Preparing a report jointly with another section 5
6 within GPU, and that's all I recall right now.
7 Q
First, why don't you take a look at B&W g
Exhibit 191.
That is a report of a reactor trip on November 7,
1978 having a cover memorandtra by Mr. H11bish 9
10 of Met Ed.
It is addressed to Messrs. Miller and 11 Seelinger of Met Ed and there is a long list of 12 individuals noted on the covering memorandum as having O
\\,)
13 received carbon copies, among whom you'are listed, 14 Mr. Broughton, 15 Let me ask you first, looking at Exhibit 191, i
16 have you seen that before?
l i
17 A
Yes.
I I
18 Q
That is a copy of a report prepared by Met Ed 19 on the November 7, 1978 transient?
20 A
Yes.
21 Q
Did you participate in any way in the 22 preparation of this report?
23 A
No.
24 Q
Did you read it when you received it?
25 A
Yes, I did read this report.
I L
1 Broughton 217
(N
\\-
2 Q
What if any use did you put this report to?
3 4
A Well, shortly after the. report was issued, this was used as a basis for the further work that we 5
6 did on TDR 017.
Subsequently, after the TMI-2 7
accident, there had been addEtional use made of the g
report for input to operator training.
I don't recall 9
any other use of this information.
10 Q
That happened after the TMI-2 accident?
t l
11 A
The application of this to traiaing by 12 myself was after the TMI-2 accident.
/
s 13 Q
Do you know whether anybodp at Met Ed'had 14 used the material and information learned during the 15 November 7, 1978 transient for operator training before
^
16 the March '79 accident?
17 A
I don't know.
18 Q
What was your understanding of what occurred 19 on November 7, 1978 at TMI-2, in brief?
20 A
As I recall, the plant was in the startup 21 test program performing some measurements related to 22 temperature coeff'icient.
The reactor coolant system was 23 at a higher than average temperature to perform these 24 measurements.
The power level was near to full power, 25 I don't remember the exact value, and during'the
1 Broughton 218 f~)
2 performance of the test, there was loss of one feedwater 3
Pump.
The plant began a runback, which is the normal 4
response for loss of one feedwater pump, and during 5
the runback, the reactor scrammed on a -- either a low
(
6 pressure or a combination of low pressure /high temperaturo 7
signal.
8 After tha scram, there was a cooldown low, 0
the normal temperature for stabilization after scram.
l' 10 Cooldown resulted in an actuation of the high pressure 1
11 injection systen, and I believe that the cooldown was 12 not terminated until perhaps ten minutes or so after the
[/h N
13 event, I think because of a malfunctioning turbine 14 bypass valve.
15 g
would it be fair to say that the November 7, 16 1978 transient at TMI-2 was an overcooling event?
17 A
Looking at,the portion of the transient from 18 the time of the reactor trip, I would classify that as an 19 overcooling event.
20 g
Will you look at the Met Ed report, which 21 is B&W Exhibit 191, and in particular, Appendix A.to
(-
22 the report.
It begins on page 1677 as marked for 23 purposes of this lawsuit.
()
24 You will see that that has been titled 25
" Pressurizer Level Calculations."
Do you have that?
1 Broughton 219
.p 2
A Yes.
3 Q
And f 11owing it are two pages which
_4 apparently comprise the total of Appendix A.
5 Do y u know who made those calculations?
6 A
No, I don't.
7 Q
Do you have any information as to why they 8
were made?
i 9 j A
I believe they were made becausa of l
1 to l pressurincr: level decrease -- indication decreasing 11 below sero inches in f.ho transient.
12 Q
You notice the first paragraph which is 13 in handwriting, it begins, "The following is a rough i
14 estimate to determine the extent of steam bubble 15 formation in the RCS following the rapid cooldown 16 on November 7, 1978."
17 Do you see that?
18 A
Yes.
19 Q
Did you ever have any discussions with any 20 of the Met Ed people involved in preparing this report 21 concerning steam bubble formation in the primary 22 system during the November 7, 1978 transient?
23 A
I don't remember any conversations like that.
24 Q
Do you have any knowledge as to who actually 25 did the work on this Met Ed report?
Either who was in
1 Broughton 220 r~s N'
2 charge of it or who actually was performing the legwork?
A No, I do not.
3 4
Q Did you ever have any conversations with Mr. Hilbish concerning this report?
5
(
6 A
Not that I recall.
7 Q
Did you review the pressurizer level g
calculations contained in Appendix A to the report at I
g ar y time in conr!scrion with your work on the November 7,
s P
^
10 l 1978 transient?
i 11 A
1 don't recall if I personally reviewed 12 these calculations.
13 Q
Would you look now at B&W Exhibit 192.
14 That is titled " Review and Analysis of November 7, 1978 15 Partial Loss of Feedwater Scram and ES Trip."
TDR 16 No. 017.
The originators are listed as yourself and 17 Mr. C,apodanno.
18 I take it you are familiar with B&W Exhibit 19 1927 I
I A
Yes.
20 21 Q
Who is Mr. Capodanno?
22 A
Mr. Capodanno was employed by.GPU Service l
23 Company at the time of this report and he was I
(~)
24 believe he was the manager of mechanical systems.
~s 25 Q
Do you have any knowledge as to why he
.- = - _.
1 Broughton 221 4
2 was assigned to be your co-author on this particular report?
3 A
This report addressed things which were 4
under the cognizance of mechanical systems, in particular 5
6 the operation of the heater drain system.
7 As I recall, we chose to combine his work l
8 with the work to look at'other items in one report as s
l l
oppoced to writing two or more reports.
9 I
I i
10 Q
As a result of your vork ol1 the November 7, l
1978 transient, did you become aware whether the PORV, 11 i
12 the pilot operated relief valve, had lifted during the 13 course of the transient?
14 A
Yes.
15 Q
Had it?
16 A
As I recall, it had lifted I*believe twice 17 prior to the reactor trip.
And no times after the 18 reactor trip.
19 Q
Did it lift on high primary system pressure?
20 A
We have no way of telling that by looking 21 at data but the pressure was increasing when the
(-
22 valve lifted and the lift was at the time of the lift-23 and the pressure was consistent with the valve having 24 lifted on high primary system pressure.
25 (Record was read back.)
1 Broughton 222 i)
%~.
2 Q
Is that what you meant to say?
3 A
That sounded accurate to me.
4 Q
Did you determine what happened to primary 5
system pressure upon the opening of the PORV7 6
A I guess I had better say a few words more n
7 about how we deduced the primary pressure was being 8
affected.
i 9
There is to recorded indication which was 10 artilable to us that vould indiccte when the PORV I
l 11 h oponad or when the PORY shun.
There was, however, 12 primary syst-an presartre recorded, and ba. sed on the t
(3
(- /
13 primary system pressure trace, decreases in primary 14 system pressure were consistent with when the PORV 15 should have opened and the termination of those
.16 decreases and the beginning of an increase were 17 consistent with when the PORV should have shut, so our 18 conclusions withrregard-to what the PORV[should'.have'done 19 were based on inferences looking at reactor coolant 20 system pressure.
21 Q
Did you a' iso look at pressurizer level?
22 A
Yes.
23 Q
what did you find pressurizer level did while
-(
24 the PORV was open?
You may want to look at one of 25 the graphs that you prepared as part of B&W 192 and,
223
)
1 Broughton
)
'~
2 in particular, you might want to look at the page that 3
has been marked 0176 for purposes of this litigation.
4 It is a rather poor copy but I think you can make out
(
5 the general outlines of what has.been shown there.
6 A
Yes, as I recall, this graph focuses on 7
the time frame after which the one feed pump tripped 8
and may extend to the point where the reactor tripped, 9}
and during that time periad, the pressurizer level i
10 l was increasing during thees inferred PORV optrations.
s 11 Q
Old anyone conuider it abnormal that the 12 pzessurizer level vas increasing while primary system 13 pressure was decreasing during the period of time that 14 the PORV was open?
15 A
well, in looking at this data, what was 16 looked at was the fact that reactor coolant system 17 temperature was increasing prior to the t, rip and it
~
18 was consistent with that temperature increase that t
19 pressurizer level would go up and the pres'sure responses, i
i 20 that is, increases when the PORV was assumed to be shut 21 and decreases when it was assumed to be open, were k.
l 22 consistent with what should have happened given the l
l 23 PORV was opened and the pressurizer level was increasing.
rm
)
(V 24 Q
so you at the time believed that the t
j 25 pressurizer level increase was attributaole to the
b j -
O l'
Broughton 224
- - n/
2
. rising temperature in the primary system?
That is 4
3 your testimony?
4 A
Yes.
5 Q
Did you ever do any studies or calculations 4
6 to determine the overall effect of a decrease in primary 7
system pressure on pressurizer level versus a 8
corresponding incret'e in primary system temperature, 6
9 j given the values that had occurred during the i
l l
10 Ncvenber 7, 197E transient?
Could I have that read back?
(Record was read back.)
12 s
13 MR. GLASSMAN:
I am not sure I understand 14 the question.
15
- MR. WISE:
Let me break it down.
It might 16 be confusing the way it is.
17 Q
During the November 7, 1978 transient, we 18 have established that the PORV opened not once, but 19 twice, right?
B' sed on the data you had..
a A
Yes.
20 21 Q
And the data showed pressure in the primary
(-
22 system decreasing during the times that you inferred 23 that the PORV was open on both occasions?
A Yes, we actually inferred that the valve 24 25 was open because the pressure decreased.
1 Broughton 225
\\J 2
Q
- Y u would expect pressure to decrease while the valve was open?
3 4
A Yes.
5 Q
And, in fact, the data shows that the 6
pressurizer level was increasing throughout the times that the PORV was inferred to be open, we have 7
3 established that?
A Yes.
9 l
10 2
You Roew at the time you performed this t
11 analysis, did ycu not, that a loss of,ressurizer lev 91 12 vould decrease primary systep pressure, all other 13 factors being equal?
14 A
I am finding it very hard to jump from i
15 what I have just.been looking at, wnich is an increase 16 in pressurizer level, to a case where we'are not talking 17 about decrease of pressurizer level and making sure I 18 understand the context in which the question is being 19 asked.
20 Q
It is a difficult questio'n, I recognize, but the point that you raise is exactly my point as 21
(-
on well.
In fact, you had a pressurizer level increase l
23 here as we have established.
Isn't it true that all
/"]
24 other factors being equal, that is, assuming no rise v
25 in primary system temperature or any other changed 4
-n.--
,.,,,,,,-,,-,n.-
.,.,..,..--,e-.
-,--..---n~+,
...., -.. - -,. ~..., - - -... -
A y
Broughton 226
()
2 parameter, that one would expect on decrease pressure to find decreased level in the pressurizer?
3 MR. GLASSMAN:
We are asking for the 4
witness.
3 6
MR. WISE:
We are asking for what he understood at the time he prepared this.
7 g
A At the time I prepared this, my understandirig of the effect of pressurizer level on pressure was g ;
l-l i
that a decreased pressurizer level could read -.either gg t
I result in a decreased pressure but dep ndiry upon the gg 9
12 event and the other considerations, for example, heaters, 13 spray, relief valve and so forth, it is not always true that a decrease in pressurizer level produces a decrease 14 15 in primary system pressure.
16 Q
I guess what I am trying to get at, Mr. Broughton, it is not that hard.
Pressurizer level 17 18 went up during this incident.
There are --
gg MR. GLASSMAN:
Just so it is clear, we are l
c 20 talking about a particular time frame here.
MR. WISE:
Yes, I'm sorry.
21-(-
l 22 Q
During the time frame that we are talking 23 ab ut, pressurizer level went up?
x re -
(7) 24 25 Q
Which is the period up to the time of the
.. _ = _
3 1
Broughton 227 r%
(' ')
2 reactor scram?
3 A
well, it is really up to the time shortly 4
.after the relief valve shuts for the second time.
5 Q
All right, I will take that.
My next bunch
(
6 of questions has-to do with that time frame, just so 7
it is clear.
I am trying to isolate the factors that l
8 resulted in pressurizer level going up.
You have i,
9 mantioned onc of the fa:ters being an increase in i
10 j primary system tempera'ture.
Let me asp it this way.
I
=
11 Were you aware cf any other factors et the 12 time you prepared this which could account for
('h n
(_,1 13 pressuriser level increasing during tie time period 14 we are discussing?
15 A
There are other factors which would have 16 been influencing pressurizer level, and in particular I
17 the operation of the makeup and letdown systems.
I
{
18 don't know what those systems were doing'to pressurizer j
19 level in this time frame.
20 Q
High pressure injection, as you understand 21 the transient, did not occur until sometime after the 22 PORV had reclosed for its second time?
23 A
My understanding is high pressure injection 24 occurred after the reactor scrammed, t
25 Q
So that the injection of high pressure flow l
l
e 1
Broughton 228 A
'\\
l w uld not have influenced pressurizer level during this ms.
2 Period of time we are talking about when the two PORV 3
4 Penings occurred?
A That's correct.
5 6
Q Let me come back to the question that I asked before.
Influences on pressurizer level causing it to 7
g increase,you havernow mentioned besides primary system 9l temperature, the possible influence of makeup flow and 9
10 ll 1etdaten on pressurircr level.
At the PAme ye2 prepared
!l 11 this, were you aware of any other influences on 12.
prnssurizer level that would ca2se it to rise during the
> <n
(/
13 time period that the PORV vas open?
14 A
No.
15 (whereupon, a luncheon recess was taken 16 at 12:45 p.m.)
17 18 19 20 21 22 23 N
24 j
a 25 l
i 1
229 A
k).
(AFTERNOON SESSION) 2 s
(Dat e :
February 3,
1982) 3 4
(Time noted:
2:30 p.m.)
T.
oAaY
,,oooaTo,
- resumed, 6
having been previously duly sworn, was examined and testified further as follows:
7 g
EXAMINATION (Cont'd.)
A BY MR. WISS::
g 10 Q
Mr. Broughton, before the lunch treak, we 11 were discussing the November 7,
1978 transient at TMI-2.
12 You have before you M W Exhibats 191 and 192 previ.ously 13 merked.
191 la the Met Ed report on that incident.
4 14 192 is an analysis prepared by you and Mr. Capodanno 15 of the Service corporation on that report.
16 Would you turn now to page 7'of your 17 report, Exhibit 192.
Does that page represent your 18 findings concerning system operation during the first 19 minute of scram?
That page and the following page.
A Yes, that's what this particular Section 20 4.3 report addressed.
21 22 Q
Is it correct that you concluded that some 23 flashing had occurred in the reactor vessel upper head O
24 during the first minute after scram in the November 7,
(_)
25 1978 transient?
If it helps, you may want to look at
230 1
Broughton l'~)
~
\\/'
2 the+1ast sentence on page 7 of your report.
A L
king at that last sentence, I don't 3
4 conclude that there was flashing.
The statement says 5
that it is likely that some flashing occurred.
I don't g
6 recall doing any particular calculations that would 7
have have shown that in fact flashing did occur.
8 Q
What was the basis of the statement as 4
3 appears in the report?
since we are talking about it, 10 I suppose we ought to put it in the re ord.
It roads:
"It is likely that some flashing ll 11 12 in the reactor vessel upper head occurred."
i )
\\/
13 The question now is what whs the basis for 14 that statement in this report which you wroto?
15 A
As best I can recall, the basis for that 16 statement was that pressurizer level had'gone off scale 17 low due to the cooldown and primary system pressure l
18 reduction had been lower than we would normally expect 1
19 to see following a trip.
Because the pressurizer level l
l 20 went low zero and because the pressure was lower than 21 we would expect to see, we could not rule out the 22 possibility that there had been some voiding in the upper 23 head of the vessel and in fact we came to the conclusion 24 that it was likely that there was some flashing.
25 I don't recall exactly why we thought it
31 1
Broughton O
\\#
was likely as opposed to why we just couldn't rule.it 2
ut.
3 4
Q Flashing in the upper vessel head would be 5
caused by pressure declining below the saturation 6
temperature for the water in the head, is that right?
Did I put that right?
7 8
A system pressure would have declir.ed below 9 l the saturation pressure corresponding to the teuperature l 10 of water in the head.
That would have caused voiding 11 in the upper head.
Again, we were hampered by lack 12 os data in that we did rce know what the temperature 13 was in the upper head of the reactor vssuel.
That's 14 why a conclusion about looking at data about the 15 flashing head was not possible.
16 Q-Just as a matter of clarification, are you 17 in the practice of using the terms " flashing" and 18
" voiding" interchangeably when speaking of those 19 phenomena within the primary system?
20 A
I probably have used those interchangeably.
I don't associate the two different words with particular 21 22 different phenomena.
23 Q
Will you take a look now at page 11A of your
}
24 report.
It has been marked 1073 in the bottom right-hand 25 corner for purposes of this lawsuit.
1 Broughton 232 7'
kN)-
2 Let me ask you first, page 11A is a ntinuation of a section that begins, I believe, two 3
pages before, labeled "5.
Conclusions and 4
aecommendations.-
3 6
Do you see that?
A Yes.
7 g
Q And page 11A, I believe, is the last page I
g j of those conclusions and reccunendations, right?
i 10
^
285*
t 73 Q
Would you look at recommendation C4 which 4
i 12 reada, " Pre-and post-even?, data Jogging of key 13 Parameters is required to permit accura o analyais of i
14 plant operation.
A permanent capability for this should 15 be provided at TMI-2."
16 Did you consider in making this recommendation 17 the desirability of having such data logging available 18 to the operators during the course of an event?
19 A
No.
20 Q
was your recommendation directed entirely at the post-event analysis stage?
21
(-
A Y*8*
22 23 Q
D y u know whether anyone considered the desirability of having pre-or post-event data logging
(~3 24 O
25 f key parameters for the operators during the course of
233 1
Broughton (v) 2 an event?
3 MR. GROSSMAN:
At any time?
4 MR. WISE:
At'any time before the accident 5
on March 28, 1979.
C 6
A would as a result of this incident or as a 7
result of anything in generaly?
8 Q
Let me ask it this way, Mr. Broughton.
9 An a result of thic incident you made this recommendatica, I
10 C4.
I take it that you were of the op, inion when you 11 made the recommendation that the data logging of 12 parameters as it then existed was not adequate for O(_/
I 13 accurats ar.alysis of plant operation?
14 A
That's not entirely correct.
15 Q
Did you find some fault with the then 16 current data logging system of key parameters?
17 A
The existing system for data logging at 18 TMI was the plant computer as the install'ed 19 permanently installed capability.
And in addition to 20 that, during the test program, a reactimeter was 21 installed which is a piece of test equipment.
22 In analysis of this event, the data which 23 was provided by the reactimeter was useful, and it was f~)
24 it's the intent of this comment to indicate that a V
25 permanent capability like a reactimeter or perhaps a
1 Broughton 234
/~N ij
\\
2 different device but permanently installed would be a 3
desirable feature to have in the power plant.
4 So with respect to this event, we felt that r
5 having data from the temporary re(ctimeter was useful 6
and this was to indicate 'that we should permanently 7
have that type of capability.
8 Q
Would you refer back to the previous page, 9
that is pags 11 of the report, and look on the middle 10 of the page, you will find a series of,1;scounendationo 5
i 11 that are preceded by the prefix 3 all under the heading i
12 "During operation, the following are recommended."
13 Recommendation B4 is, " Ret'ain the reactimeter 14 in operation."
15 What is the difference between your 16 recommendation B4, that the reactimeter e retained in 17 operation, and recommendation C4 for a permanent 18 capability to log data concerning key par'ameters?
19 A
well, B4 was intended to address the 20 conditions as they were at the plant, immidiately 21 following this event, that in the immediate future we 22 should continue to use ~ the reactimeter.
C4 discusses 23 how in the future we might do something other than the
(~T 24 reactimeter but the key point of C4 is that we should
\\-)
l 25 preserve the capability to have pre-and post-event I
81 1
235 3 roughton
~'
2 data logging.
3 Q
were you aware of any reason at the time 4
that you wrote this why the reactimeter could not be 5
kept permanently in operation at TMI-27 6
A I was not aware of any reason why it could 7
not be kept in operation.
My understanding was that it 8
was a piece of test equipment which normally would have 9
been removed following the completion of the test.
10 program.
t 11 Q
What kinds of capability did you have in 12 mind in writing recommendetion C4, the one that speaks
/~T k s!
13 of a permanent capability to log-key parameters?
r 14 A
I don't recall having any detailed concept 15 of what this device would be.
I think this is under a 16 heading that said these are things that should be 17 considered for future implementation and I don't believe i
18 that at the time this was written we had given a lot of 19 thought to the specifics of criteria such'as a data 20 logging system.
21 Q
Did you subsequently?
22 A
Subsequently consideration has been given 23 to what type of system we would like that is in ID 24 conjunction with work that has taken place recently at U
25 TMI following the March '79 accident.
1 236 2'
1 Broughton
<g 2
Q Between the time that this report was 3
prepared in November of 1978 and the March '79 accident, 4
was any consideration given to carrying through on 5
recommendation c47
(
6 MR. GLASSMAN:
By whom?
7 MR. WISE:
By Mr. Broughton or anyone else, 8
to his knowledge.
S A
Between November '78 and March
'79, I don't 10 know what additional consideration was given to item C4.
11.
Q What happened to TDR'e such as the one.you 12 wrote, B&W Exhibit 192, on the Novenber transient?
Was 13 there any system or procedure for fo111 wing up on the 14 recommendations contained in it or did it just go in a 15 file some place?
^
16 A
I am not aware of any formal system or 17 procedure.
There were recommendations here that in fact l
18 we were following on before the plant sta'rted again 19 and I believe that's why the TDR was revised, was to t
20 address recommendations which should be accomplished 21 before startup and to differentiate those from ones L
22 which would be accomplished later.
23 Q
Let me see if I understand.
You and I
24 Mr. Capodanno wrote this in November of '78 and there 25 is a signature line that indicates you signed it on
237 1
Broughton
+
l
\\-
November 17th and again on November 21, 1978.
J 2
3 D
y u see that on the cover page?
4 A
Yes.
' ' l t
l 5
Q Mr. Keaten signed it on Novembe'r-17th, 't i
6 appears, 1978.
Do you see that?
7 A
Yes.
8 l Q
Now, after all of you had signed this, what l
9 did you do with it next?
10 MR. GLASSMAN:
Is your question what 11 Mr. Broughton did with it?
12 MR. WISE:
Yes.
?~)
(_)
13 A
I don't specifically remember what I did 14 with this particular TDR.
In general, what I would have 15 done with a TDR is insure that it was dictributed after 16 being signed.
And in a case like this where there were 17 items that we had recommended to be accemplished.before l
18 restart, there would have been discussic'.: with s'ome other t
t i
19 Party to make sure that the items wera in-fact completed.
20 Q
Who was responsible for conducting those 21 discussions?
22 A
well, again, I don't recall for the specific 23 TDR.
I can only indicate what the normal practice would n%./
24 have been.
me ask on this particular one, did you 25 Q
,Let l
l
i 1
238 1
Broughton s
O t$ose, discussions?
~
conduct 2
~.
A' I d
"'t **""11*
' '3 You' don't recall one way or the other f
, x
\\
4 Q
~
'whether you did or didn't?
s 5
-(
6 A
No, I do not.
7 Q.
Do you know whether Mr. Capodanno did?
s t
g A
I don't know whether he did.
s j
g Q
Do you know whether Mr. Keaten did?
10 A
No.
4 gg Q
.Is there anyone else who you would know U
who would h' ave discussions concerning the recommendations 12 (o,,/ -
13 you made in your report?
1 i'
A I don't know who for certain would have 14 gg
' ha'd such discussions.
16 Q
Let me ask you to look back for a second at B&W 186 which is the TDR prepared by the task force g7 18 investigating the April 23, 1978 transient.
19 MR. GLASSMAN:
Could I have the last question s
and answer read back for a second.
20 I
(Record was read back.)
21
(-
22 Q
Do you have that before you, Mr. Broughton?
23 A
Yes, sir.
(~%)
24 Q
Did your task force make recommendations
\\s/
25 in the TDR7
.c s
a.
1 m
-w--7
- p
.,,-,ry-y
,m
-..,,a m
-.w.
_._.-_m.,
239 1
Broughton
'd -
A There are recommendations in this TDR.
2 Q
If y u w uld turn to page 56 of the task 3
force report, which has been marked 0582 for purposes 4
f this litigation in the bottom right-hand corner, 5
6 you will see a section labeled " Recommendations."
7 It proceeds through that page and the following two 8
Pages.
Do you see that?
A Yes.
9 10 Q
Would you look at the last page of your 11 recommendations under C, those labeled " Longer term."
12 A
- Yes, b
V 13 Q
Would you look down at recommendation 6 14 which reads, "To permit accurate post-event analysis, 15 the possibility of obtaining up to five minutes of 16 Post-trip, five resolution data, such as'that available from the reactimeter, should be investigated.
Action -
17 I
18 GPUSC."
19 was that one of the recommendations that was made fell wing the April 23, 1978 incident?
20 A
Yes.
21 22 Q
Had that been completed as of the November 23 1978 incident?
A I don't know.
24 25 g
who within GPUSC was responsible for
~.
240 1
Broughton
('/.
^
T 2
fol10 Win 9 up on the April 23rd recommendation, I should s-say the rec mmendation that grew out-of the April 23, 3
4 1978 incident?
5 MR. GLASSMAN:
A particular individual?
gr 3
6 MR. WISE:
If there was anyone.
7 A
I don't know.
8 Q
When you prepared your recommendations 9
foll wing the November 1978 transient and particularly 10 recommendation c4 concerning the additgon of a
11 permanent capability for event data logging of key
}
12 parameters, did you have occasion to look back at your 13 recommendations following the April 23, 1978 transient?
14 A
I don't remember.
15 Q
D you remember whether you looked at 16 recommendation c6 on page 58 of your report on the i
17 April 23rd transient, B&W Exhibit 1867 18 A
I don't remember.
19 Q
And it is your recollection that as of 20 March 28, 1979, the recommendation under C4 in your 21 28 port on the November transient had not'been completed?
22 A
I believe I stated that I did not know if it 23 had been completed.
24 Q
Did you ever find out whether within the l
l 95 GPU system anywhere anyone before March 1979 had in fact i
f 1
Broughton 241 2
had discussions or looked into the installation of a 3
permanent capability for logging of key parameters 4
during an event at TMI-27 5
A I don't recall ever looking into that
(-
6 question.
7 Q
You are not aware at this point of anyone 8
who did?
9 A
I am not.
10 Q
was there any system or prgcedure within 11 the GPU system, to your knowledge, that required some 12 kind of written documentation concerning the completion 13 of recommendations made in post-event analyses such as 14 B&W Exhibit 192 or B&W Exhibit 1867 15 A
I am not aware of any such system or 16 procedure.
17 Q
Would you look at recommendation C5 in 18 B&W 192.
B&W 192 is your report on the November '78 19 transient.
It reads, "Further analysis of these 20 events using computer simulation to:
(a) determine the 21 cause of the scram; (b) simulate plant performance 22 during a scram to determine unknowns such as the 23 existence of two-phase mixtures in the primary when f'}
24 pressurizer level was below indicating range; v
25 (c) quantify the steam demand during cooldown; and
242 1
Broughton
['T
\\-
2 (d) evaluate pressurizer dynamic response including 3
the effects of a larger pressurizer."
4 Do you know whether any of these analyses 5
that were recommended in your November 1978 report 6
had begun as of March 1979?
7 A
Yes, there were some analyses begun that 8
fall under recommendation C5 before March
'79.
9 Q
Would you describe those for us?
10 A
As I recall, we had begun,an analysis using 11 a model of the pressurizer in the RETRAN code and I 12 believe also in a B&W code which we had access to 13 through the B&W computer system.
And ' hat study would t
14 have been addressing item (d) under CS, that is 15
" evaluate pressurizer dynamic response."
16 I don't believe that it had progressed to 17 the point of looking at the effects of larger 18 pressurizer.-
And it may also have been a'ddressing 19 item (a) with respect to the cause of the-scram.
20 Q
Was any work ever done on analyzing the 21 event to determine unknowns such as the existence of
(
22 two-phase mixtures in the primary?
23 A
I don't recall any work that would have 24 been done to address that item before March of
'79.
25 Q
Why had such work not been begun before
243 1
Broughton
/~
(\\-
2 that tima?
3 MR. GLASSMAN:
If there was a particular 4
reason for that?
5 MR. WISE:
If there was any reason.
g 6
MR. GLASSMAN:
You don't want any speculation 7
here?
8 MR. WISE:
I don't want any speculation.
9 He said it wasn't done and I just want to know 10 why.
If there was no reason, he can state that.
t 11 MR. GLASSMAN:
So you are saying aside from 12 the heading that appears in this section of the
(^)
~
13 report about future implementation and s-14 consideration?
15 MR. WISE:
Right.
16 A
I know of no specific reason why that 17 item wasn't done or even why it wasn't begun.
18 Q
I would like to show you next'a document 19 which we will mark as B&W Exhibit 389 which is mostly 20 in handwriting.
21 (Multip ag e handwritten document, first 22 page entitled "RETRAN, Version (blankl, Pressurizer 23 Study, Three Mile Island Unit 2" marked B&W I
24 Exhibit No. 389 for identification, as of this 25 date.)
244 1
BroGghton r"N 2
Q Do you recognize this document?
3 A
Yes.
4 Q
Will you describe it for the record, 4
5 please?
(
6 A
This document is an outline of a study which 7
would have reviewed the response of the TMI-2 pressurizer 8
and compared it to observe pri' mary data and other codes.
9 Q
Was it in any way connected with the 10 November 7, 1978 transient at TMI-2?
g 11 A
This study was outlined following that 12 November '78 transient and would have used data from
('N
(-
13 that transient as a -- for a comparison against the 14 calculated results.
15 Q
Well, for instance, if you would look at 16 the page which has been marked 8646 in tbe lower 17 right-hand corner for purposes of this litigation which 18 immediately follows the table of contents', list of 19 tables and a list of figures, we find something marked l
20
" Introduction" which reads, "This report describes the 21 analysis of an operational transient which occurred l
22 on November 7, 1978 at Three Mile Island Unit 2 23 (TMI-2 ) Nuclear Generating Station during startup 24 testing."
25 In fact, this pressurizer study grew out of
1 Broughton 245 fw k-2 the November 7, 1978 transient, isn't that correct?
A Yes.
3 4
Q Was this study done pursuant to the 5
rec mmendation in B&W 192, your report, on the 6
November 7th transient, that further analysis should be 7
done to evaluate pressurizer dynamic response?
That g
is recommendation C5 (d) on page 11A of the report.
A Yes, this study would have been a study g
10 that would have addressed recommendation C5 (d).
t 11 Q
When was this study begun?
12 A
I don't recall the exact date but I believe 13 it was done it was started fairly soon after the 14 TDR 017 which would have been perhaps as early as 15 late November.
16 Q
19787 17 A
1978, yes.
l 18 Q
Again referring to page 8 6 4 6,- t h e l
19 introduction paragraph, the second sentence reads, "The transient resulted in large primary system pressure 20 i
21 changes due to" -- well, there is an insertion here and I am having trouble reading it, it appears it says, 22 "due to pressurizer in and out surges and pressurizer 23 l
24 relief valve actuation."
25 Is that a correct reading?
L
1 Broughton 246
(~\\
- ,,) -
\\
2 MR. GLASSMAN:
Are you asking him to try 3
to interpret this?
4 MR. WISE:
It is his handwriting.
5 MR. GLASSMAN:
Yes, we just haved't 6
absolutely established that on the record.
7 Q
Mr. Broughton, is that your handwriting?
8 A
This is my handwriting.
9 Q
Ha7e I read it correctly or have I 10 mischaracterized your handwriting?
t 11 A
I would have read it exactly the same way.
12 Q
What did you mean by " pressurizer in and O.
t 4
V 13 out surges"?
14 A
That would refer to water being transferred 15 from the reactor coolant system loop piping up through 16 the surge line and into the pressurizer, that would 17 be an in surge.- And then water.travelingxfrom the 18 pressurizer back into the reactor cooland piping, that 19 would be an out surge.
20 Q
" Pressurizer relief valve actuation," I take 21 it, would refer to the opening and closing of the pilot 22 operated relief valve at the top of the pressurizer, is 23 that right?
(}
24 A
Yes.
25 Q
Was it your conclusion, based upon the
I 1
Broughton 247 2
analysis that you had done up to the time that you wrote i
this draft, that the large changes in primary system 3
4 pressure that occurred during the November 1978 transient 5
at TMI-2 were due to these two factors, in and out
{
6 surges from the pressurizer and actuation of the PORV?
7 A
At the time this draft was written, it was my 8
belief that those factors were the only factors 9
controlling the system pressure during this transient.
10 Q
What effect on primary system pressure
.h 11 changes did the opening and closing of the pressurizer 12 relief valve have in this particular transient?
13 MR. GLASSMAN:
As he understood it at the 14 time the report was written?
15 MR. WISE:
Yes.
16 A
I should probably also point"out that this 17 discussion of effects on pressurizer, pressure and system 18 pressure really refers to the time in the transient 19 before the scram which is the same period -of time that we looked at previously.
And with respect to the effect 20 21 f the pressurizer relief valve on primary system 22 pressure, it was my understanding that when the valve 23 was open, the pressure would drop.
When the valve was 24 shut, the pressure would increase if there were an 25 in surge.
l
i 1
Broughton 248 O
V-2 However, I would again point out that we r88117 in 8Er8d Pr888uri2*r r8118f valV8 Peration based 3
n those changes in pressure.
We had~no other data to 4
5 indi ate that when the pressurizer relief valve actually
{
6 Opened or actually shut.
7 Q
Are you familiar with the term " loss of 8
c lant accident"?
A Yes.
l 9
10 Q
That describes the loss of coolant from the 11 Primary system, is that right?
12 A
Yes.
13 Q
Normally, the primary system should be Closed?
g4 A
Closed with limited leakage.
The system 15 16 is designed to have certain leakage in the makeup or l
17 certain leakage.
Loss of coolant accident applies to 18 leaks greater than a certain minimum design leakage gg value.
20 Q
Was it your understanding before the March 1979 accident at TMI that a loss of coolant 21 accident would result in decreasing primary system 22 23 Pressure?
A Before the March '79 accident I would have l
24 l
25 associated a decreasing primary coolant system pressure - -
g Broughton 249 OV I w uld have considered that to be one of the symptoms 2
f a ss of coolant accident.
3 (Witness conferring with counsel.)
4 5
Q Did you in the course of your study of 6
the pressurizer, a draft which we marked as B&W Exhibit 7
389, look at the magnitude of the effect on primary 8
system pressure that would be caused by an open PORV?
g Perhaps a better word to use, I think it's one that you 10 used in your report, was the sensitivity of primary t
gg system pressure to an open PORV.
12 MR. GLASSMAN:
Any particular language you 13 had in mind here?
MR. WISE:
There is, but first I want to 14 see what the witness' answer is.
15 A
Let me again comment on exactly what this
(
16 i
17 document is.
This is a draft of a report which could i
18 have been used to document the study butein fact the 19 draft came before the study so it is more-like an utline of a report even though there are sections of 20 it which are filled in to a greater detail than would 21 on normally be done in an outline, so the point I am making here is this' document we are looking at came before the 23 w d to look at the eMeets of various influences on a 24 25 pressurizer.
s 250 1
Broughton
[('
2 This does not incorporate results of that work even to the extent that they might have preliminary 3
4 results.
5 MR. WISE:
Well, let's have marked as B&W 6
Exhibit 390, another set of handwritten material 7
which appears to be part of the same report.
8 (Multipage document consisting of handwritten 9
pages bearing production numbers 1314 8579 through 10 1314 8621 marked B&W Exhibit No. 390 for 11 identification, as of this date.)
12 MR. WISE:
This exhibit is approximately 13 42 pages long based upon the number stamping 14 system used in this litigation.
15 Q
Are you familiar with this particular 16 document?
17 A
Yes.
18 Q
Will you describe it for the record?
19 A
This is a subsequent draft of-a report of the of a pressurizer study on the Three Mile Island 2 20 21 Pressurizer.
22 Q
Subsequent to B&W Exhibit 389?
23 A
Yes.
r~h 24 MR. WISE:
Let me have marked next as B&W b
25 Exhibit 391, what appears to be another draft of
1 Broughton 251 g.
2 the same report.
\\
3 (Multipage document, first page entitled 4
"RETRAN, Version (blank), Pressurizer Study, 5
Three Mile Island Unit 2" bearing production 6
numbers 1314 8622 through 1314 8640 marked 7
B&W Exhibit No. 391 for identification, as of 8
this date.)
9 MR. WISE:
This document is approximately 10 18 pages long based on the numbering system we t
11 have used and is all typed.
12 Q
Do you recognize B&W Exhibit 3917 13 A
Yes.
14 Q
Would you identify it for the record?
15 A
This appears to be similar to B&W 390 16 except it has not been expanded upon with additional 17 information and comments as has B&W 390.
~
ig Q
As of the time that B&W Exhibits 390 and 19 391 were prepared, had any of the work been done on 20 actually carrying out the study?
21 A
I don't remember the dates.
However, the 22
. word processing slip that would have prepared B&W 23 Exhibit 391 has a date on it of December, which I 24 believe to be a representative date of when this N,.
25 document was prepared and notes that are part of B&W
252
)
i Broughton O2 l
2 Exhibit.390 are dated February 14, 1979 and those notes 3
indicate that some work had been started on the study 4
as of February 14, 1979.
5 I don't know how much analytical work had 6
_been performed as of December.
7 Q
When was work completed on the study?
8
.A Work was never completed on this study.
9 Q
At what stage was the study when work on it 10 ceased?
g 11 A
As best I can recall, the models in RETRAN 12 and DYSID had been constructed.
And the input data had D(_)
13 been prepared and some preliminary run$ with that data 14 had been made.
I have no other recollection of where l
15 the study was at the time it was terminated.
16 Q
Do you recall whether you had any other 17 written data or report on the results of what runs had 1
18 been made as of the time of the cessation"of work on l
l 19 this. project besides those that are reflected in B&W
\\
20 Exhibits 389 through 3917 21 A
I don't recall any other information that I 22 had in the form of documents.
23 Q
In what form did you receive data on the 24 runs that had been made?
I mean, did it come to you in 25 a computer printout sheet or did somebody write out a
._.... _.. _. _.....,. _ _. _... ~
1 Broughton c '..
- n
()
2' report to you or how would it come to you when one of these runs had been done and you wanted to find out what 3
the results were?
4 5
A As I recall, the information I was getting 6
on this study was primarily verbal information at this 7
early stage in the study.
g Q
Who was actually manipulating the computer 9
and getting the data out?
10 A
The bulk of the study and perhaps all of 11 the study was being performed by Lou Lanese.
12 Q
Was the reason that the study was not 13 completed that the March 28, 1979 accident intervened?
14 A
Yes.
l 15 Q
Will you look at B&W Exhibit 390 and turn 16 to the page that has been marked 8617 for purposes of 17 this litigation.
You will see there a figure labeled 18 400-6, "TMI-2 Pressurizer Study" -- I'm sorry, I have 19 the wrong figure.
I want the one on the previous page, 20 8616, the figure 400-5, "TMI-2 Pressurizer Study, 21 Relief Valve Flow Sensitivity."
22 Do you see that?
l l
l 23 A
Yes.
~
24 Q
Is that a page which you prepared?
v 25 A
Yes.
i
1 Broughton 254
(~
\\
Q What does the graph that is presented on
)
2 that page purport to show?
3 A
This is an example of the figure which 4
5 was being considered as to be included in the report 6
which would help us show the effect of different relief valve flows.
The figure is not based on any analytical 7
8 results.
It simply is an indication of how we might 9
present the results in a report about the study.
10 Q
Well, this graph has aserpes of lines.
11 Actually it appears to be a peak and then a second peak 12 which has been done in triplicate with a line.
13 Was there any significance to that or was that simply doodling?
74 A
Well, the relief valve flow sensitivity 15 w uld have evaluated pressure response, sssuming l
16 i
different flows when the relief valve opened, and it 17 18 was postulated that in doing that study,.we would see 19 different rates of change of pressure when the valve 20 was open for the different valve flows and therefore f r the study we were doing, we might see pressure 21
(-
trays which looked like these in the sketch.
22 23 Q
The sketch has a vertical and horizontal access and there is a line starting at the left-hand
(~g g
L.)
side of the horizontal access.
It swings upward to a 25
1 1
Brcughton 255 rx 2
peak and then falls back down again to a valley and 3
then there are actually three separate lines coming up 4
from that valley to a second peak and then falling 5
again to a valley before dropping off the scale.
.(
6 Are those lines intended to represent 7
pressure?
8 A
Those lines would have represented pressure 9
as a function of time.
10 Q
So that the vertical access, if their 11 graph had been completed, would show various pressure 12 levels?
^T 13 A
various pressures.
14 Q
Now, beneath the lines on the graph, there 15 are what appear to be a series of boxes, some of them
^
16 overlapping.
There is a series of three boxes to the 17 left underneath the first peak and a series of three 18 boxes to the right underneath the second' peak.
19 Do you see those?
20 A
Yes.
21 Q
What do those boxes represent?
I realize 22 they may not be boxes.
I may be describing them that 23 way simply for the convenience of whoever is trying to 24 read this transcript and make some sense of it.
25 A
Those would look like rectangles in this
I I
256 Broughton f3 2
proposed figure and they would represent flow through 3
the relief valve as a function of time.
4 Q
How would they do that?
I mean how would 5
I interpret this as you drew it?
6 A
Looking at the three overlapping rectangles 7
on the left, this graph would indicate that if a relief 8
valve opened, there would be an increasing vertical line 9
and then the horizontal portion of the box would 10 correspond to the flow rate through the valve and the 11 decreasing vertical line would indicate that the valve
-12 was-shutting so that any one of those boxes would 13 indicate when the valve opened, when the valve shut and 14 the flow rate through the valve when it was open.
15 Q
I take it that the horizontal access would 6-16 be time?
17 A
Horizontal access would be time and to be 18 able to determine flow rate based on the horizontal line 19 for the valve, a second scale would be required in the 20 vertical access which would correspond to flow rate to 21 the valve or alternately valve position but something 22 that indicates the difference of what had been assumed 23 in each of the runs with respect to the valve.
! N 24 Q
Will you turn to the page that precedes V
25 that.
This page has been marked 8615 and is labeled
.=
i Broughton 257 i
" Figure 400-3, TMI-2 Pressurizer Study, Factors 2
Affecting Pressure," and there is a handdrawn graph there.
Could you describe what that was intended to 4
I represent?
5 A
The best I can recall this would be a plot 6
of pressure versus time in the dashed line, level versus 7
time in the solid line from the November 7, 1978 event 8
"I~
9 10 Q
There are also some rectangles on this t
31 particular figure.
Two of them appear to have been 12 shaded in and one of them that overlaps both has not O)
/*
been shaded in.
13 g4 Do you see that?
~
A Yes.
15 16 Q
What did they represent?
i A
As I recall, the two shaded rectangles would g7
(
l 18 have represented the opening and shutting.of the PORV 1
l with the height of that rectangle having some gg l
relationship to -- the flow through the valve and the 20 unshaded rectangle would have been the period during 21 k
which the spray valve was open and again the height 22 f that rectangle having some significance with respect 23 i
to the spray valve.
24
<m. cess teen.,
2,
1 1
Broughton 258
("~)
k /-
2 BY MR. WISE:
3 Q
Would you look, Mr. Broughton, at a page 4
which has been marked 8607 and is a part of B&W 5
Exhibit 390.
6 A
Yes.
7 Q
That page at the top has a section labeled 8
"432 Relief Flow Rate."
That refers to the PORV at the 9
top of the pressurizer?
10 A
Yes, it does.
t 11 Q
There is some handwriting over at the 12 right-hand side of the page under that section that
/"T
(_)
13 I have not been able to read and I won $er if we could I
(
14 enlist-your aid, since it is yours, to tell us what 15 that says if you can.
I am speaking about the part 16 that begins with the word " Noticeable."
17 A
Yes, perhaps it would help if I explain what 18 the rest of the things under this title m'ean because i
19 those notes really amplify on that.
20 Q
All right.
21 A
This is again an unwritten section of this 22 report.
It is part of an outline which would indicate 23 that we wanted to discuss the effects of relief valve
]
24 flow rate on the analysis results and --
25 Q
You mean the effects on the primary
5 1
259 Broughton 2
pressure?
3 A
The effects of relief valve flow rates on 4
primary pressure 5
g Before we move on, just let me refer you, 6
if it would help, to the preceding page which has the 7
general label "430 Sensitivity studies."
I take it 8
in the numbering system you are using 432 would be a 9
subsection under section 430?
10 A
That's correct.
t 11 Q
so that the description on page 8606 under 12 the general topic "430 Sensitivity Studies" would 13 apply to the specific studies which you have labeled 14 431, 432, 433, is that right?
15 A
That's correct.
16 Q
And on that page, you have written, "Several 17 additional analyses were performed to det, ermine the 18 sensitivity of pressure to various inputs'and assumptions 19 Then there is a description of the various analyses that 20 you have done.
21 So would it be correct that the section that 22 you had intended to write under 432 would show or 23 analyze the sensitivity of primary system pressure to 24 flow rate through the PORV7 a
25 A
Yes, that is right.
260 i
1 Broughton k-).
2 Q
Now, we are back to your analysis of the 3
handwriting that appears in this draft under the 4
specific section relating to PORV flow rate.
5 A
Right, this outline indicates that we would
(.
6 be looking at a base case, which would be a reference, 7
case, and that relief valve flows which differed from 8
that base case by a plus or minus 10 percent and the 9
notes on the right say " Noticeable with respect to 10 magnitude and timing" and the second one says, "Not 11 significant with respect to trends."
12 Q
What did you mean by those notations?
ja)
(_
13 A
With respect to the first dotation, 14
" Noticeable.fith respect to magnitude and timing,"
15 that was what we expected to see in the sensitivity 16 study, that the different flows would afdect the 17 magnitude of pressure changes somewhat and the timing 18 of when the valve opened and shut.
And the second 19 note, "Not significant with respect to trends," indicated 20 that we expected that we would still expect to see the 21 same general increase and decrease in pressure that 22 we saw in the base case.
23 Q
As part of this pressurizer study, was there f'}
24 any intention to look at the sensitivity of pressuriser N_/
25 level to various parameters?
1 Broughton 261 O)-
- (s 2
A In the section that would have dealt with 3
of various different physical dimensions the effect in the pressurizer, greater di$ meter or smaller 4
5 diameter, greater or smaller height, there would have 6
been changes in pressurizer level from the base case 7
simply due to that effect.
8 Q
Well, I guess I am looking more at the g
question of whether it was intended in the course of 10 the study of the TMI-2 pressurizer as it existed at t
11 the time the work was going on, was there any intention 12 to see what effect variation in the parameters you (I
13 had selected would have on pressurizer-level?
14 A
With respect to the existing-pressurizer 15 at TMI-2, there wasn't any part of this study which 16 would have addressed effects of various parameters l
l 17 on pressurizer level.
i
~
l 18 Q
Pressurizer level was one of<the levels i
19 affecting pressure, was it not?
l i
20 MR. GLASSMAN:
Where, when, how?
l 21 Q
During the transient on November 7,
1978.
(-
22 Take a look, for instance, at page 8615, the figure you 23 drew labeled " Factors Affecting Pressure."
I believe
[ gT 24 yu testified before the break we took that there were
~ %.)
25 various parameters shown there, the dotted line l
t y
iye--y-
+
m--,
-g m---
--a
.262 I
1 Broughton rb ak-2 represented pressure and the solid line represented 3
pressurizer level.
4 You have also got flow rate through the 5
PORV and another line or piece of the graph
(
6 representing the letdown flow, I believe.
7 A
Spray flow.
8 Q
Spray flow, I'm sorry.
Pressurizer, you 9
knew when you were doing this study that pressurizer 10 level was a factor that would affect primary system 11 pressure?
12 A
That is correct.
/~%
(_)
13 Q
And that was with the existing pressurizer 14 at TMI-2?
15 A
Yes.
16 Q
Now, I guess my question is in your study 17 of the extent to which various parameters would affect 18 primary system pressure, was it not necessary to consider 19 as well pressurizer level in connection with the 20 transient?
21 A
It was, and if I said a few words about how 22 we did the study, that might indicate of how that was 23 accounted for.
With the models that we constructed, we
(~')
24 used as an input condition or a driving function for'
%/
25 the transient, the surge flow rate into or out of the
39 i
Broughton 263
,_/
2 pressurizer.
That surge flow rate was attained by 1
king at the recorded plant data for pressurizer level 3
4 and differentiating that to get the rate of change of mass in the pressurizer.
5 6
when we ran the model using this surge rate, the level predicted by the model should have agreed with 7
8 the level observed in the plant data if our surge rate was correct.
And it was from that reference that we 9
10 then conducted the other sensitivities to see how 11 valve flow rate or spray valve operation would have 12 affected pressure.
13 so in order to get comparable results for 14 evaluating the effects of things like spray and relief 15 valve capacity, we held'the pressurizer level component 16 constant for the study.
17 Q
Did you ever consider that the opening of 18 the pressurizer relief valve could in and-of itself 19 affect the pressurizer level?
Or if you will, the surge l
flow in and out of the pressurizer?
20 i
A For the purposes of this study, no.
21
(-
l 22 Q
Were y u aware at the time that you were 23 w rking on this study that the opening of the PORV would have an effect on the surge into the pressurizer of
/~
24 N_))
mass water?
25
3 1
Broughton 264 s
\\
2 2'
A For the particular transient under study, 3
I was not aware of that particular effect.
4 4
Q Did you believe at the time you did this 1
r 5
study that the opening of the PORV would have2 any 6
effect on pressurizer level?
7 MR. GLASSMAN:
You are asking for belief 8
now?
j
-9 MR. WISE:
I am asking for what his knowledge 10 was at the time.
If I use the word " concern,"
i t
11 you object to that.
If I use the word " belief,"
t 12 you object to that.
If I use the word " interest,"
13 you object to that.
14 I think they are all commonsense English 1
15 ways to describe the man's knowledge.
t 16 MR. GLASSMAN:
It is probably easier to use 4
17 the word " knowledge" and not confuse things.
1 I
18 THE WITNESS:
Would you read the question 19 back?
t i
MR. WISE:
I will repeat it.
20 21 Q
At the time that you were working on this 22 study, did you have any knowledge as to whether the 23 existence of an open pressurizer relief valve would have 24 an effect on eressurizer level?
25 MR. GLASSMAN:
I thought that was just asked e
w:
yy
---.-y
--,-,--,--,-,,w-~,,y
--7,e.y,v....,-n,--,.,-..--,,m-,,.
,.,...,-w-..mw,,.,m,,
. - -. - - + =, - -
11 1
Broughton O
V and answered.
2 MR. WISE:
You were making an objection.
3 4
MR. GLASSMAN:
I am talking about the 5
question that was answered.
6 MR. WISE:
I don't think it was.
A My recollection is that the previous qtiestion 7
8 dealt with the effect on surge rate of the relief valve and this question deals with the effect on lavel of the 9
10 surge valve?
4 e
11 Q
Yes, pressurizer level.
12 A
of the pressurizer level based on operation 13 of the relief valve?
j (
14 Q
Yes.
l'-
15 A
And I think at the time we did tihis >stu ly, 16 there was discussion about the fact that'in/the RETRNil-l l
17 model when the relief valve is opened,.itjwill remove l
ig mass from the pressurizer which would result in a small
,i.
i 19 change in indicated level as a result of that ;.*/alve l
20 being open.
- /
3 4
(
r In the DYSID model, which wa's the other 21 l
e n l
22 model used for the study, my recollection is' tiha ei
/l
/,
/
23 opening the relief valve had no effect o n.'t h e '.n a s s in' s
24 the pressurizer and therefore it would have had no
~
effect on the level, and I believe that in locking 'at
\\
25 r.
. fd*
1-q i
s
\\
1 266 i 1 i
Broughton y
2 this, we realized that we would have to consider that 3
difference in the two models, but that we did not expect 4
that it would be a significant difference in level 5
as a result of that effect.
^
6 Q
Are you familiar with how a pressurizer works?
\\
7 i
8 A
I have some familiarity with how it works.
9 Q
were you familiar with how it works at the 10 time you undertook to work on the pressurizer study for i
L l
11 GPU Service' Corporation?
l 12 A
I had some familiarity of how it works at 13 that time.
l l
14 Q
It is a pressure vessel, is it not?
15 A
It is a pressure vessel.
Q Its function is to maintain and control 16 t
s
, 17 pressure In. the primary system, is that right?
i
. /
18 A
y Yes.
19 Q
How'does it do that?
s s
20
.A There is an interface between water and 21 steam in the priissurizer.
The water is maintained at
' 22 -
'the saturation temperature for the desired system
-pressure [sn,d by 23 the interface which exists between y
[]
the water and steam in surges into the pressuriser or 24 l
'u,
25 out surges from the pressurizer result in either s
x
- m..,
pr n
y Broughton condensation of steam as the volume is contracted, or 2
vaporization of water as there'is an out surge to try to expand the steam volume and that condensation and 4
vap rization tend to minimize the pressure changes due 5
6 to in surges and out surges.
Q The surge line is located near the bottom 7
8 f the pressurizer, is that right, as opposed to the P
9 A
It's located such that it communicates with 10 e
the water space on the pressurizer.
11 12 Q
And that surge line runs to the hot leg or ne f the hot legs in the primary system?
13 A
That's correct.
g4 15 Q
And there is water in the. surge line?
1 A
Yes.
16 j
17 Q
And the pressuriser is partially filled with gg water, is that correct?
l A
Yes.
19 Q
And above the level of the water, there is a 20 steam space, is that right?
21
(
(
A Yes.
9.9 I
I 23 Q
And there are heaters in the pressurizer, is that correct?
24 A
There are heaters.
l 25 l
[
1 Broughton 268
\\-
2 Q
By increasing the heat,one raises the 3
temperature in the pressurizer, is that true?
4 A
Yes.
5 Q
And depending upon the particular level of 6
pressure in temperature one is at, saturation is created 7
at the interface between the water and the steam space, 8
is that right?
9 A
Yes.
10 Q
By increasing the heat, on will increase the 11 amount of steam being produced in the pressurizer, is 12 that right, increasing the heat through the heater 13 through the pressurizer?
14 A
Yes.
15 Q
And the increasing steam is enclosed in the 16 pressurizer so that it cannot escape during normal 17 operations, isn't that right?
18 A
That's correct.
19 Q
And as there is increased steam at the top 20 of the pressurizer, the pressure in the primary system 21 will increase, all other factors being equal, is that
(-
22 true?
23 A
If the steam is increased by heating the
/~%
)
24 water so that the two stay in equilibrium, then the
\\/
25 pressure would increase.
i Broughton 269 g
Q That is because if steam attempts to expand 2
and it can't, it places pressure on the water, is that right?
4 A
And it cannot condense because the water is the 8ame temperature.
6 Q
And that is what creates pressure in the 7
8 Primary system, other factors being held equal?
A Yes.
g 10 Q
Now, at the top of the pressurizer, it is 4
my understanding there are certain valves, at least gg called code safeties and one called a pilot operated 12 i
relief valve. Is that your understanding?
13 A
Yes.
g4 Q
Y u understand that when you were working 15 n this study?
16 3
A Yes.
17 18 Q
If one f those valves should.open,the steam at the top of the pressurizer could escape, isn't that gg
- 9 20 A
Yes, steam would start to leave the top of g
(
the pressurizer.
As-itJdid, some of the water in the 22 23 pressurizer would flash the steam to take its place.
Q Was it your understanding when you were working on this pressurizer study that as that flashing 5wi.9--
y-9
---m-
-p wwww
,w
,*w'gw-v-r--
- w
- - - * - ~ + + + - - +
b
5-1 Broughton 270 2
took place in the pressurizer, water from the primarf 3
system would flow into the pressurizer to take its 4
place?
5 A
No.
The steam that leaves the pressurizer 6
through an open relief valve is replaced by water in 7
the pressurizer which evaporates and which flashes 8
into steam.
The only effect.that would have on water j
9 in the primary system itself would be that the water is 10 now slightly less compressed and if you reduce the 11 pressure on the compressed water, it will tend to expand 12 a very small amount.
13 That's a second order effect, it is not a 14 one-for-one relationship'between the water -- the steam 15 that leaves the pressurizer and the water that would 16 come up into the surge line.
The point i am trying to 17 make is that in the example you have given of steam 18 leaving the pressurizer, the level in the steam in the 19 pressurizer may be reduced slightly because some of l
20 the water is flashing'to steam but the water that may 21 surge in from the loops would be much smaller in mass l
22 relative to what it left at the pressurizer, so in a 23 study like this, for example, a second order of effect V(~T 24 like that, even if it was predicted by the codes, would 25 have been almost insignificant to the effect of having
.,------.---.y
1 Broughton 271 f~
('
2 the valve open.
3 Q
Do you ever go back and look at the 4
instances where the PORV had lifted prior to the 5
March 28, 1979 accident to see what happened to 6
pressurizer level during those incidents?
7 A
I don't recall looking at them specifically 8
for that purpose.
I think this is an example of an 9
event where the PORV opened and we did not go back to
~
10 look specifically at what happened to pressurizer level.
11 Q
You drew several graphs that we have looked 12 at today showing the pressurizer level increasing during
[
\\-
13 the period of time the PORV was open?
14 A
Yes.
15 Q
You certainly were aware that it did that?
16 A
We were aware that the pressurizer level was 17 increasing during the event and that othe,r things were 18 taking place also. The PORV opening that 'ee looked at
~
19 during this event I think probably was looked at with 20 respect to what effect pressurizer level had on it.
It 21 was the pressurizer level increase which caused the 22 pressure increase which caused the valve to open.
23 Q
But after the valve opened, the pressurizer
(
24 level continued to increase?
25 A
It did but not because the valve was open.
I 1
Broughton 272
[~h
(_)
2 Q
Who performed the analysis that concluded 3
that?
4 A
I don't know that I can point to an analysis 5
that concluded that.
That was our evaluation of the data 6
from this e v e n,t.,
7 Q
Whose evaluation?
You say "ours."
Are 8
you referring to yourself and somebody else or is this 9
something that is essentially your opinion?
10 A
well, I don't recall specifically discussing 11 this with anyone else.
12 Q
So this is your opinion?
Eh
(_)
13 A
It may just be my opinion.
14 Q
What analysis did you perform in order to 15 arrive at your opinion?
i 16 A
The analysis I performed was'a review of the 17 data from the event which indicated that average system 18 temperature was increasing during the period the 19 Pressurizer level was increasing and it is the increase 20 in reactor coolant system temperature which would have 21 Provided the increase in pressurizer level.
22 Q
Did you ever perform any calculations to 1
23 determine the amount of pressurizer level increase that 24 would be expected given the amount of primary system 25 temperature increase that occurred during the transient?
9 1
Broughton 273
/~
(T) 2 A
I did not recall making any such calculations and I wanted to check that there were none in here.
3 4
There are calculations which address changes in 5
Pressurizer parameters due to a cooldown but I do not 6
recall making any calculations that would have compared a change in reactor system temperature to pressurizer 7
8 level for this event.
9 Q
In performing this pressurizer study, did 10 you make any attempt to go back and look at the t
11 March 29, 1978 stuck open PORV transient at TMI-2 to 12 see what happened at pressurizer level as a result of 13 that relief valve being open?
14 A
No.
15 Q
What is behind the relief valve at the top 16 of the pressurizer, to your knowledge?
j 17 A
You are speaking of the flow stream?
l 18 Q
In other words, it is true there are l
l 19 discharge pipes connected to the pressurizer where l
20 the valves are, isn't that right?
I l
A Yes.
21
(-
22 Q
And those discharge pipes run down to a l
l 23 drain tank, is that correct?
l A
Yes.
24 w.)
25 Q
And the pressure in the drain tank is at l
.g-
--,w
~r
,, - ~ - -
1 Broughton 274
(~h t
k-2 atmospheric or close to atmospheric pressure, is that 3
right?
4 A
Yes.
5 Q
And that is true for the pipes running 6
from the relief valve down to the drain tank, is that 7
correct?
8 A
Yes.
9 Q
So that when one of those valves comes 10 open, the system, the interface of the, system, is 11 between the pressure and the primary system which may 12 be as high as 2,000 psi, give or take a couple hundred 13 one way or the other, against basical1Y atmospheric 14 pressure, is that right?
15 A
Yes.
16 Q
What is atmospheric pressure,' by the way?
17 A
It's zero pounds gauge or 14.7 pounds 18 absolute.
7 19 Q
And the interface would be between that
(
20 0 to 14 versus something over 2,000 pounds when one of I
21 those valves comes open?
22 A
Yes.
i 23 Q
Did you ever consider the effect on the 24 mass inside a system under such pressures of being 25 exposed essentially to atmospheric pressure such as 4
[
1 Broughton 275
("%
N-) -
t 2
would occur when that relief valve opens up?
'3 A
You mentioned the mass in the system.
I 4
am not sure that I know what you are referring to.
5 Q
Inside the primary system and the pressurizer 6
which is attached to the primary system there is water, 7
right?
8 A
Yes.
9 Q
Some of it is liquid and in the top of the 10 pressurizer some of it is steam, righty 11 A
Yes.
12 Q
All of that is normally kept under pressure O)
\\_
13 so long as the relief valves at the top of the 14 pressurizer remain closed, right?
15 A
Yes.
16 Q
And both the steam and the liquid water 17 are under essentially the same pressure, give or take l
~
i 18 minor differences?
19 A
Yes.
l l
20 Q
And that would run at over 2,000 psi during 21 normal operation of TMI-2, is that correct?
22 A
Yes.
l 23 Q
My question now is if you pop one of those 24 relief valves open and expose the water and steam inside 25 the primary system to the' atmospheric pressure at the
1 Broughton 276
(~h Nl 2
top of the pressurizer, did you ever consider the effect of that on the water and steam in the system, 3
4 how they would react to that event?
A 5
6 Q
Did_you conclude that there would be any 7
tendency on the part of the water and steam inside the g
primary system to move towards the opening at the top of the pressurizer?
g 10 A
No tendency other than the phenomenon I tried t
11 to describe earlier of the change in pressure on the 12 solid reactor coolant system allowing some expansion
(~)
f that water and resulting in a small' amount of that
(_/
13 water transferring to the pressurizer.
I described 14 t
15 that as a second order effect in terms of the amount 16 of mass involved in that transfer compared to the amount l
17 of mass that would be leaving the pressurizer.
l 18 Q
You will have to forgive me because I am a layman and not a scientist but I think everyone has 19 seen television shows or movies in which somebody is 20 21 UP in an airplane and they are flying along in a
(-
Pressurized cabin and for one reason or another, somebody 22 23 P Ps a hole in the thing and all hell breaks loose and
.j-N chairs and people and everything else start flying 24 b
towards the opening in the pressurized cabin.
I think 25
1 Broughton 277 O() -
2 most laymen are familiar with that phenomena.
3 If y u take a system that is under pressure 4
and you pop a hole in it, there is a tendency on the 5
part of the materials inside that pressure system to 6
rush toward that hole and to be sucked out of the 7
pressure vessel and I guess what I am trying to get at 8
is did you ever consider whether there would be such en effect on the water as a result of having the valve 9
10 at the top of the pressurizer open up and suddenly I
11 exposing the system to essentially atmospheric pressure 12 when the material that was inside the system was at a 13 much higher pressure, namely, 2,000 psi?
~
14 A
That was considered and I think I can 15 explain to you why there is a minimal effect.
If you 16 compare the opening in the primary system that exists 17 when the PORV.has been opened, compare it to the size 1
18 of the primary system, the opening is very, very small.
S even though there is mass in the pressurizer 19 20 attempting to go into the lower pressure area, because that opening is so small, a very small amount of mass 21 k
22 can g through it and the result is that the pressure 1
23 in the primary system doesn't drop very fast compared to what it would drop if we had a large opening.
24
\\
J l
25 To go back to your airplane analogy, if I
1 Broughton 278 i
2 instead of a door or window opening, if instead there were a small pinhole leak in the pressurized part of 3
4 the airplane, you wouldn't expect to see things drawn ut of that very small leak.
5 6
Q Since the TMI-2 accident, are you aware of 7
any analyses that have been done to determine the cause g
of pressurizer level rising during the early stages of that accident?
g 10 A
Yes.
e gg MR. GLASSMAN:
I just want to hear the 12 question and answer again.
O
\\v/
13 (Record was read back.)
g4 Q
In fact, during the TMI-2 accident, 15 pressurizer level did increase throughout some portion f the early stage of the accident?
I believe there 16 was an initial jog during the first few seconds of the
.g7 gg event but thereafter there was a steady increase in 19 pressurizer level, isn't that correct?
A As I recall, after the initial decrease, 20 there was an increase of pressurizer level to the point 21
(-
where the indicated level eventually went off scale high.
22 23 Q
I am speaking of that increase to the point where it recovered and following the initial decrease to 24
)
8 the point where it went off scale high, wac there any 25
1 Broughton 279 V
2 analysis after the accident to determine what had caused that?
3 A
'Yes.
4 5
Q was that done by somebody in GPU?
6 A
GPU did some analysis on that and I believe 7
other organizations also did analysis on that part of g
the transient.
9 Q
Did y u ever do any work on that?
10 A
I don't recall actually performing any work.
L 11 I did supervise some of the work that was done.
12 Q
Did you see the results of the work?
13 A
Yes.
14 Q
what were the results?
15-A As best I recall, the results were that 16 the pressurizer level increasing during that part of 17 the event-was due to a combination of factors which 18 included high pressure injection flow, an increase in 19 reactor coolant system average temperature and the third item would have been the creation of voids in the 20 reactor coolant system.
21 k
Q My understanding was that flashing did not 22 23 occur in the TMI accident until sometime after six minutes following the initiation of the event.
24
-(/
25 Is that consistent with what you found as a
1 Broughton 280
['}
\\_/.
result of your investigations following the accident?
2 A
I re all that flashing in the loops occurred 3
at about six minutes into the event.
I believe there 4
was also speculation and perhaps conclusions drawn r
5 6
that flashing may also have occurred in the reactor 7
vessel upper head prior to the flashing in the loops.
8 Q
Is it flashing in the upper head that g
you are referring to when you speak of the factors 10 influencing the rise in pressurizer level during the it early part of the transient?
12 A
If in fact flashing did occur in the upper 13 head, that would have influenced pressurizer level in the early part of the accident and when the loops 14 15 saturated, that would have also influenced pressure.
16 All of those factors would have been contributors.
g7 Q
You are aware that the operators during 18 the accident at TMI-2 on March 28, 1979 terminated 19 high pressure injection before six minutes into the 10 accident, are you not?
A Yes.
21 22 Q
You are aware that they have said that 23 they did so based upon increasing pressurizer level,
^h 24 are yun t?
x)
A Yes.
25 t
I
- ~.
- _ -.,...,. - - - - - - - - - - - - +~
- = -
1 Broughton 281
(~
\\_J.
2 Q
So that looking at the time period between 3
the initiation of the event and the point where the 4
operators terminated high pressure injection, we cannot 5
account for the increase in pressurizer level by looking 6
to flashing in the hot legs, isn't that correct?
7 A
.That is correct.
8 Q
I am focusing really on that initial time 9
period between the beginning of the event and the point 10 where the operators terminated high pressure injection t
11 flow.
Did the analysis that you looked at address 12 what was causing a rise in the pressurizer level during fs k_,
13 that period of time specifically?
14 A
That's the period of time up to and including 15 the time that high pressure injection flow was reduced?
16 Q
Yes, I believe that was somewhere between 17 a two-and four-minute period.
I have forgotten the 18 exact time but certainly well before six minutes.
19 A
I believe that we did do an analysis that 20 addressed that time period.
21 Q
Who did that, Mr. Lanese?
22 A
Mr. Lanese was the primary person working 23 on that and he may have been the only person working on
("}
24 that.
\\J 25 Q
And he reported his results to you?
I 1
Broughton 282 A
~
2 A
Yes.
3 Q
As I understood your testimony just a few minutes ago, the factors that resulted in increasing 4
5 pressurizer slevel were HP injection, increasing
{
6 primary system temperature and flashing, is that correct?
7 8
A Yes.
9 Q
Were there any other factors causing 10 pressurizer level to increase as a respit of the it analysis that was done and reported to you?
12 A
Not that I recall.
13 Q
After the operator terminated HPI, that rem ved that factor, I take it?
14 A
Yes.
15 16 Q
D you know what happened to pressurizer 17 level after HPI was terminated?
~
18 MR. GLASSMAN:
You are talking about the I
19 result of the analysis that was done after the accident?
20 l
MR. WISE:
Yes.
21 22 Q
It c ntinued to increase, did it not?
i f
23 A
It did.
There was one point at which it either leveled out or decreased but that was over a 24 small time period.
The general trend was still in the 25
1 Broughton 283
)
2 increasing direction.
Q s
that increase could not be accounted for 3
4 by the injection of high pressure flow?
A C rrect.
5 6
Q That leaves us with primary system 7
temperature and flashing?
8 A
Yes.
9 Q
Flashing did not occur in the hot legs until I
10 after six minutes, we have established that?
11 A
Right.
12 Q
So then either we had flashing somewhere 13 else in the system before six minutes or else the
+
i 14 entire pressurizer level increase would have to be i
15 attributed to primary system temperature after the point f
16 at which the operator terminated high pressure injection, is that right?
17 18 A
- First of all, the way you posed the question 19 it was an either/or and as I recall, our analysis indicated tha from the time the high pressure injection 20 flow had been reduced, the system did begin to increase i
21 i
k in temperature so that factor was definitely present 22 23 and would have itself resulted in increase in pressurizer i
1***1*
O 24 iD
(
25 If there was also flashing occurring e--
e
..,e-
.m,c.,
..-r
- - ~,. -,
1 Broughton 284 n
V-somewhere other than in the loops, then that would 2
have_c ntributed further to the increase in pressurizer 3
level, so the temperature increase was definitely 4
5 present.
The flashing in some other part of the 6
reactor coolant system may have been present.
7 Q
Is it correct that as a result of your 8
analysis, you were able to determine that the increase in primary system temperature during the first eight 9
10 minutes of the event was attributable to the lack of gi emergency feedwater to the steam generators?
12 Perhaps I ishould say the lack of all 13 feedwater.
If you had neither main feedwater nor 14 auxiliary feedwater.
A During the period when primary system 15 16 temperature increased, the increase was due to the lack j
17 of main feedwater, emergency feedwater and high 18 pressure injection.
During the period when main and gg emergency feedwater were absent but high pressure injecti n was present, there was essentially no 20 1
21 temperature increase.
(
k 22 Q
Did Mr. Lanese ever write up his findings 23 in any kind of a report that you are aware of?
A As I recall, the analysis that Mr. Lanese 24 l
did that concerned pressurizer level was part of a 25
1 Broughton 285
(~%
\\-
2 report on a modeling effort undertaken by GPU to 3
simulate the TMI-2 accident.
4 Q
Would that be TDR 045?
Perhaps we can show 5
it to you later.
We have marked a RETRAN analysis of 6
the March 28th accident that was performed over the 7
summer of 1979 and I believe became TDR 045.
8 A
The work Mr. Lanese did would have been 9
part of that report.
Again I am not sure what the 10 number is.
g 11 Q
Well, we will be showing you that a little 12 bit later on.
\\
\\__)
13 During the course of your work on the 14 pressurizer study, did you have occasion to examine the
~
15 effect, if any, of various operator actions that could 16 be taken during the course of a transient such as occurre d 17 on November 7, 19787 18 A
No.
~
19 Q
You were not concerned with the operator 20 interaction with the various parameters that you were 21 looking at?
22 A
No, we were not.
23 g
Did you ever have occasion to take a look
(
24 at the operating or emergency procedures for TMI-2 to 25 see what they had in them about the pressurizer system?
I
1 Broughton 286
/(-),
2 A
Not in conjunction with this study.
Q Did'you have an occasion to do that at any 3
time before the TMI-2 accident?
4 A
I d n't recall ever looking at the 5
6 Procedures regarding pressurizer operation before the TMI-2 accident, 7
g Q
Did you ever look at any of the TMI-2 9
operating or emergency procedures before the accident 10 in March 1979?
As best you can recollect, I am not t
11 going to hold it to you if one day one was laying on a 12 table in a room that you happened to be sitting in.
C)
D y u have a recollection of having an occasion for
(
13 14 some business reason to look at the procedures at 15 TMI-27 16 A
Not that I recall.
17 Q
When did you first become aware that there 13 was a pilot operated relief valve at the top of the 19 pressurizer at TMI-1 and TMI-27 Again, I won't hold 20 y u to a specific date, Mr. Broughton.
I don't want 21 y u to ponder over that.
Was it something learned
(-
relatively soon after coming with GPUSC or was it 22 23 relatively late?
A I believe I learned that relatively shortly 24 after I came to work for GPU.
25
1 Broughton 287 O'
2 Q
Did you gain any understanding as to why 3
that valve was there?
4 MR. GLASSMAN:
At the time he first 5
learned about it?
6 MR. WISE:
Yes, at the time he came to 7
GPU Service and learned that it was sitting 8
there.
9 A
I believe I did.
10 Q
What was your understandin.g at that time 11 as to why there was a pressurizer relief valve provided 12 at TMI-1 and TMI-27
's_-
13 MR. GLASSMAN:
If the witness is taking 14 a long time to answer, I again assume this 15 question relates to if he has a recollection of 16 what his understanding was back then, without 17 trying to 18 MR. WISE:
Sure.
- e.i:...
19 Q
I am not asking you to do something you i
20 can't do.
I am really looking here for generalities 21 as a background to some more specific questions that 22 are going to come.
4 23 A
I don't know that when I first learned
}
24 about the valve that I had a total understanding of 25 what its function was, but I had at least a partial
1 Broughton 288 l
L 2
understanding of it being present in the system to be available t relieve Pressure increases prior to the 3
i 4
pressure reaching the set point of one of the code safety valves.
5 6
Q Have you ever heard the term " runback"?
4 A
Yes.
7 8
Q Did you come to have an understanding of i
the meaning of that term before the accident?
l 9
10 A
Yes.
t 11 Q
What does that term mean?
12 A
Runback as referred to in the reactor meant that the power would be reduced to a predefined 13 level based on the control system havingl detected a 14 15 certain event had occurred such as a turbine trip or 1 ss of feed pump.
16 i
17 Q
Did you have an understanding as to 18 whether the PORV would have any role to play in the i
19 runback feature at TMI-1 and TMI-27 A
Yes, it was my understanding that the valve r
20 l
i w uld open prior to the pressure reaching the scram 21 k-set point and might be successful in preventing the 22 l
23 pressure from reaching the scram set point so that the runback can be successful.
i 24 l
ss 25 Q
was there any value in that, to your
(
l l
I
_. - _. _ - -,. _ _ - - - - -. - - - ~ _ _ _. - _ - -. _, - - - - -. - _ - _ -,, - - - - -.
- - _ _ - -.., - - --- _---- ~.
1 Broughton 289 ps
(
_/
2 understanding?
MR. GLASSMAN:
You are talking about at the 3
4 time he first came to GPU?
5 MR. WISE:
During the time up to the 6
Period of the accident as he grew to understand 7
what the PORV was and why it was there.
g A
You asked if there was value in that and I am not sure what that refers to.
9 10 Q
I am speaking about the role that the t
11 PORV would play in the preventing of a reactor trip 12 during a runback event.
()
13 A
If the PORV were successful in preventing 14 a reactor trip during a runback, then 'there would be 15 a value to it.
16 Q
What was your understanding as to why you 17 would want to prevent a reactor trip?
18 A
The runback might allow you to keep 19 operating the plant even though it was at,a reduced 20 Power level, whereas the trip shut down the plant 21 and required a recovery period to restore it to 22 Operation.
23 Q
That would be an economic value of having 24 it, is that correct?
O_'
MR. GLASSMAN:
You are asking whether the 25 i
I
1 Broughton 290 I) witness considered economic value, you are not
(_
2 asking him to try to speculate?
3 4
MR. WISE:
I am asking him with respect to the testimony he just gave, isn't it true that 3
e 5
6 that consideration, prevention of a scram and 7
plant shutdown, would be of economic benefit to 8
the utility?
MR. GLASSMAN:
And you are asking for the 9
10 witness' understanding of it, no for him to gg speculate on such a matter?
12 MR. WISE:
That's right.
13 A
It was my understanding that a runback 14 w uld be preferable to a scram for economic reasons.
15 Q
Were there also safety reasons?
16 A
I am not aware of any safety' reasons which 17 would make a runback more preferable to a scram.
18 Q
Isn't it true that, although the plant is gg designed to shut down safely on a reactor trip, that there is always an increased chance of something going 20 21 wr ng when you have a reactor trip and it is therefore
(-
Preferable to prevent trips, if possible?
22 i
23 MR. GLASSMAN:
Can I hear that back.
24 (Record was read back.)
v 25 MR. GLASSMAN:
We are not asking for his
1 Broughton 291 2
expert testimony, as to what does or doesn't-3 happen, always or sometimes or anything of 4
that sort.
I think if the witness gave 5
consideration to this kind of an issue, he can 6
testify to it.
7 MR. WISE:
I will take that amendment to 8
the question.
9 Q
Did that enter your mind that there was i
10 a value to having the PORV and preventing reactor trips 11 which would be more than an economic benefit but might i
12 also provide some safety benefit?
13 MR. GLASSMAN:
Now we have'got a different 14 question from.what we had before. 'Now we are I
15 talking about some possible value.
16 A few moments ago you used a' question 17 that used the word "always."
This is becoming 18
[
very muddled here.
I think we ought to have a 19 clear question on the record so there will not 20 be any confusion as to what'the testimony is.
21 Q
Nuclear power plants such as TMI-1 and 22 TMI-2 are designed to withstand a reactor trip, isn't l
23 that your understanding, and wasn't that your 24 understanding before the accident at TMI-27
[
25 A
Yes.
1 Broughton 292 O)
(_,
2 Q
Nonetheless, is it not true that, generally speaking,the chances of something going 3
4 wrong increase upon the occurrence of a reactor trip?
MR. GLASSMAN:
I am not sure what you mean 5
i 6
by something which has gone wrong.
It is 7
really a vague, general question.
8 Q
Isn't it true that it is desirable to avoid g
reactor trips for safety as well as economic reasons?
10 MR. GLASSMAN:
This witness' understanding?
t 11 NR. WISE:
Yes.
12 A
That is not my understanding that that 13 is desirable.
14 Q
You were aware before the March 1979 15 accident that the pilot operated relief valve might 16 fail in an open position?
17 MR. GLASSMAN:
Are you talking about 18 whether the witness considered this.?
l 19 MR. WISE:
Whether he was aware of the fact that that was a possible occurrence.
20 A
I don't recall ever having considered that 21
(
the valve might fail in an open position.
22 23 Q
Y u were aware of the March 29, 1979 transient when that happened?
24 A
Yes.
25 1
- i 1
- /
1 Broughton 293 f
l' G
,/
k-)
2 Q
And it did fail in the open posy. tion?
v j
c f,4 '
3 A
Yes.
i, j
i'
\\
)l to your pts,e'ntien c
4 Q
So it had been brought i
i 5
sometime prior to March 1979 that sometimes that valve 6
might be stuck open?
7 A
Yes.
s s
8 Q
Did you ever attempt to determine whether 9
the possibility of the valve being stuck open had been 10 reflected in any operating or emergency procedures 11 provided to the operators at TMI-1 or TMI-27 12 MR. GLASSMAN:
In what time frane are we 13 looking here?
/
14 MR. WISE:
Before the accident on 15 March 28, 1979.
i 16 A
I don't ever remember attempting to l
l 17 determine that.
18 MR. WISE:
Let's break here.
19 (Time noted:
5:05 p.m.)
20 l
21
(-
22 T.
Gary Broughton 23 Subscribed and' sworn to before me 24 this day of 1982.
25
,,,.,--.g-.-n-,.-y,#3-w-
-w
-mm,yo.-.--9 e
,,,.-6
-_m.-
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l s1 294 l
I CERTIFICATE STATE OF NEW YORK
)
3'
- ss.:
COUNTY OF NEW YORK
)
4 I,
NANCY A.
RUDoLPH 5
, a Notary
,( -
u Public of the State'of New York, do hereby 6
certify that the continued deposition of T.
GARY BROUGHTON was taken before me on Wednesday, February 3, 1982 consisting of pages 155 through 293 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
,G s
in controversy, nor am I in the employ of any of the counsel.
IN WITNESS WHEREOF, I have hereunto set my 19 Tb hand this /2 day of February 1982.
20
! 'i 21 t
W N
CY A.
RUDOLPH l
C a
i 25 i
295
[)
Y
~
INDEX WITNESS PAGE
)
I T.
Gary Broughton (resumed) 157 4
4 4
EXHI B IT S
. p :,.,;'i:
-.t.,.
NUMBER FOR IDENT.
388 Multipage document consisting of handwritten noten dated 4/23/78 and graphs bearing'.
production numbers 1313 9194 through 1313 9199 200 389 Multipage handwritten document,
, ()
first page entitled "RETRAN, i
Version (blank), Pressurizer l
Study, Three Mile Island Unit 2" 243 390 Multipage document consisting of handwritten pages bearing production numbers.1314 8579~
through 1314 8621 250 391 Multipage document, first page l
entitled "RETRAN, Version e
(blank), Pressurizer Study, Three Mile Island Unit 2" bearing production numbers 1314 8622 through 1314 8640 251 l
)
e e
e l
)
.m
.-