ML20072H994
| ML20072H994 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 02/18/1982 |
| From: | Billingsley Q GENERAL PUBLIC UTILITIES CORP. |
| To: | |
| References | |
| TASK-*, TASK-02, TASK-03, TASK-06, TASK-07, TASK-2, TASK-3, TASK-6, TASK-7, TASK-GB NUDOCS 8306290855 | |
| Download: ML20072H994 (159) | |
Text
00 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK (A) o
______________________________________x GENERAL PUBLIC UTILITIES CORPORATION, a JERSEY CENTF.AL POWER & LIGHT COMPANY,
[
METROPOLITAN EDISON COMPANY and PENNSYLVANIA ELECTRIC COMPANY, a
Plaintiffs,
-against-80 CIV. 1683 (R.O.)
THE BABCOCK & WILCOX COMPANY and J.
RAY McDERMOTT
&,CO.,
INC.,
a s
' Defendants.
_______________x Deposition of GENERAL PUBLIC UTILITIES CORPORATION, by QUINCY BILLINGSLEY, III,
(
taken by Defendant, pursuant to Notice, at the offices of Davis Polk & Wardwell, Esgs., One Chase Manhattan Plaza, New York, New York, on February 18, 1982 at 10:00 o' clock a.m.,
before Charles Shapiro, a Certified Shorthand Reporter and Notary Public within and for the State of New York.
9 DOYLE REPORTING. INC.
CERTIFIED STENOTYPE REPORTERS f%
369 LExlNGTON AVENUE WALTER SHAPIRO, C.S.R.
NEW YCnic. N.Y.
1o017 CHARLES SH APIRO, C.S.R.
TELEPHONE 212 - e67 8220 8306290855 820210 PDR ADOCK 05000289 T
1 2
[V')
2 App e ara nc e s :
3 KAYE, SCHOLER, FIERMAN, HAYS & HANDLER, ESQS.
Attorneys for Plaintiffs 4
425 Park Avenue New York, New York BY:
STEVEN J.
GLASSMAN, ESQ.,
6
-and-JOHN EICKEMEYER, ESQ.,
7 of Counsel 8
9 DAVIS POLK & WARDWELL, ESQS.
10 Attorneys for Defendants One Chase Manhattan Plaza 11 New York, New York 12 BY:
ROBERT F.
WISE, ESQ.,
'~N 13 of counsel
(
14 15 ALSO PRESENT:
1 16 NINA RUFFINI 1
l 17 18
-oOo-19 20 IT IS HEREBY STIPULATED AND AGREED by 21 and between the attorneys for the respective 9
22 parties hereto, that the sealing, filing and 23 certification of the within deposition be, and 24 the same hereby are, waived; and that the
(
i
\\
25 transcript may be signed before any Notary
1 3
[~]'S 2
Public with the same force and effect as if 3
signed before the Court.
4 IT IS FURTHER STIPULATED AND AGREED that 5
all obj ections, except as to the form of the 6
question, are reserved to the time of trial.
7
-oOo-8 QU I NCY B I LL I NG S LEY I I I 9
having been first duly sworn by the Notary 10 Public (Charles Shapiro), was examined and 11 testified as follows:
12 EXAMINATION BY MR. WISE:
(y 13 Q
Mr. Billingsley, will you state your full
%)
14 name and business address for the record, please?
15 A
My"name is Quincy Billingsley, III.
MT 16 business address is GPU, 100 Interspace. Parkway, 17 Parsippany, New Jersey.
18 Q
Are you currently employed?
l l
19 A
Yes, I am.
20 Q
By whom?
21 A
GPU.
ID l
22 Q
What is your current residence address?
23 A
36 Henry Court, Mount Arlington, New Jersey.
l 24 Q
Your counsel has provided us with a g~
k-)
25 brief resume this morning.
l
1 Dillingoloy 4
r~N 2
MR. WISE:
I would like to have it
~Y 3
marked as B&W Exhibit 427.
4 (Resume of Quincy Billingsley marked 5
B&W Exhibit 427 for identification, as of
,9-6 this date.)-
7 Q
Mr. Billingsley, is Exhibit 427 an 8
accurate statement of your education and work experience 9
as of today?
10 A
ies, it is.
11 Q
Under education the first item is BSME.
12 I take it that stands for a Bachelor of 13 Science in mechanical engineering?
%-]
14 A
Correct.
15 Q
Your resume states that between 1972 and 16 1974 you attended the University of Connecticut School 17 of Law.
18 Did you graduate from that school?
19 A
No, I did not.
20 Q
How far through the course of study did 21 you get before stopping?
O 22 A
I attended two years.
23 Q
How close to graduation were you when you 24 stopped?
/'T
(,)
25 A
Two years away.
1 3i111ngolcy 5
2 Q
Your resume also states that you have a gY y
N_
3 Masters in business administration from the University 4
of Hartford obtained in 1978.
Is that right?
5 A
Correct.
6 Q
was there any spacial area that you worked 7
in in getting your MBA in marketing, finance, anything 8
of that nature?
9 A
Finance.
10 Q
Finance you say?
11 A
- Yes, 12 Q
Your resume lists your first job after 13 graduating from the University of Connecticut with G'
14 your Bachelor of Science degree as " facility engineer" 15 at Connecticut Yankee Atomic Power Company.
The 16 resume indicates you were employed there from 1971 17 through 1978, 18 was that a full-time job?
19 A
Yes, it was.
20 Q
I take it your attendance at the University 21 of Connecticut School of Law was a night course?
O 22 A
correct.
23 Q
would that also be true with respect to 24 th e MB A that you received from the University of O
\\_j 25 Hartford?
1 Dillingoloy 6
2 A
Yes.
-m I
i Q'
3 Q
For how many years did you study for the 4
MBA that you received in 19787 5
A Four years.
,9 6
Q So you would have begun your study for 7
that in 1974 or '57 8
A
'74.
9 Q
where was your place of work while you 10 were employed by the Connecticut Yankee Atomic Power 11 Company?
12 A
I worked at the station at Connecticut 13 Yankee Atomic Power Company.
I worked at the site.
I, \\
V 14 Q
Where was that located?
15 A
Haddam Neck, Connecticut.
16 Q
What kind of a reactor is that?
l 17 A
Pressurized water reactor.
18 Q
Who is or was the vendor of the nuclear 1
19 steam supply system?
20 A
l 21 Q
Prior to your joining Connecticut Yankee 22 Atomic Power Company had you had any training or 23 courses in the operation of a nuclear power plant?
24 A
No.
,,~
(,)
25 Q
Upon arriving at Connecticut Yankee Atomic l
l l
l
1 BillingG1Cy 7
,3 2
Power Company, what training or cources did you J
3 undergo in connection with your employment there?
4 A
I received on-the-job training as well as 5
attendance of the reactor operators licensing school 6
run by the facility.
7 Q
Could you describe what that school 8
consisted of?
Did it have a simulator or was it 9
classroom training?
10 A
It was classroom training combined with 11 on the board training at the facility.
The simulator 12 was not involved.
13 Q
When you say on the board training, you Q) 14 mean actual training in the control room itself?
l
~
15 A
Correct.
f 16 Q
Approximately how long was the classroom 17 training portion of the course?
I am asking really l
l 18 to describe it, not to give me necessarily hours or 19 days.
1 20 In other words, was it something you 21 would go for so many hours a week for a certain S
22 period of weeks?
How would you describe the length 23 and duration of that course?
24 A
I attended the school full time for i
r~'N
'()
25 approximately nine months.
1 Billingoloy 8
2 Q
Could you give some rough allocation of
,-s.
t%)
3 the percentage breakdown between the classroom training 4
and, as you put it, "on the board" training?
5 A
It would be very rough because of the 6
period of time.
This was going back 11 years.
7 I am guessing.
8 MR. GLASSMAN:
I don't think the witness 9
should be guessing but just giving the best of 10 his recollection if he has a recollection.
11 A
I would say ten percent of the time was on 12 the board.
The remainder being classroom, 13 Q
Did you receive instruction during the O
14 classroom phase of the training on the basic principles 15 for the operation of the pressurized water reactor?
16 MR. GLASSMAN:
Objection.
l 17 I am not sure what is meant by the 18 verbiage" basic principles." Are there particular I
19 items that counsel has in mind?
l 20 MR. WISE:
We can break it down.
l 21 Q
Did you receive training on the 9
22 thermodynamics of the primary system in a pressurized l
l 23 water reactor?
l 24 A
- Yes, w
25 I
)
Q Did you learn that water boils at t
{
1 BillingolGy 9
2 different temperatures depending upon the pressure
,S L) 3 it is under at the time?
4 A
Can I say that I did not learn that in 5
training, in operator's training school.
6.
Q Excuse me?
7 A
I cannot say that I learned that in 8
operator's training school.
9 Q
Did you know it before you came to the 10 school?
11 A
Yes.
12 Q
Did you receive training towards obtaining 13 and operating license?
,_s
/
i
~
14 A
Yes, I did.
15 Q
Did you ever take the Nuclear Regulatory i
16 Commission examination to obtain an operator's license?
17 A
Yes, I did.
18 Q
Did you obtain such a license?
19 A
No, I did not.
20 Q
What was the reason that you did not 21 obtain the license?
9 22 MR. GLASSMAN:
You want what was in his 23 own mind as to why he did not obtain a license l
l 24 or anybody else's reasoning?
I don't believe n(,)
25 he can give anybody else's reasoning.
1 sillingoloy 10
(~T 2
MR, WISE:
I was trying to shortcut it, V
3 Q
Did you pass the exam?
4 A
No, I did not, 5
Q Did you attempt to retake the examination qgg 6
at any time?
7 A
No, I did not, 8
Q What were your duties and responsibilities 9
as a facility engineer at the Connecticut Yankee 10 Atomic Power Company between 1971 and 19787 And if 11 they changed over that period of time, if you could 12 describe what the changes were and approximately when 7-'
13 they took place.
O
~
14 A
In 1971 I came on board at Connecticut 15 Yankee as a reactor engineering assistant.
I held 16 that position until approximately 1974 or
'5 at which 17 time I became a facility engineer, 18 My duties as a reactor engineering 19 assistant included core start-up testing and 20 surveillance of secondary side equipment and components 21 and various primary side equipment and components, O
22 As facility engineer I was involved in 23 plant design changes and modifications, equipment 24 overhauls, repairs and troubleshooting.
O)
\\~
25 Q
Was the Connecticut Yankee reactor
1 Dillingoloy 11
(}
2 critical at the time that you joined the company in V
3 1971?
Had it started up?
4 A
Yes.
5
,8>
6 best y,ou can recall?
7 A
In 1967.
8 Q
I am confused then.
9 You said that one of your duties as a 10 reactor engineering assistant was core start-up testing.
11 A
Yes.
12 Q
I take it that refers to some activities 13 that occurred after the plant was already commercial
(-
O' 14 and operating?
15 A
Correct.
16 Q
Could you describe what was included under 17 the term " core start-up testing"?
18 A
After each refueling you would have to 19 go through physics testing of the core and measurement 20 of various parameters related to continued operation 21 after start-up.
22 Q
The other area that you mentioned was 23 included within your responsibilities as a reactor 24 engineering assistant, surveillance of secondary CT
's._/
25 and primary side equipment and components.
1 BillingalOy 12
(~T 2
could you describe in more detail what
\\v' 3
that entailed?
4 MR. GLASSMAN:
Objection.
I believe the 5
testimony was that his work related to surveillance qgg 6
of secondary side equipment and some primary side 7
components, just so that there is no over 8
breath of the assumptions of counsel.
9 MR. WISE:
All right.
10 A
secondary side equipment was measuring 11 equipment performance with respect to heat transfer N
12 capabilities, any degradation in the equipment 13 operation and expected values provided by the
"-3 d
14 vendor for which the component was to perform to.
15 That would include things like heat exchangers and 16 pumps.
17 Primary side, and I must qualify primary 18 side and confine it to that equipment located in the l
1 i
19 containment structure which would include fans and 20 pumps and some heat exchangers, measuring the l
21 performance of those items.
dBi l
l 22 Measurement of core performance was 23 limited primarily to start-up testing.
Additional l
24 performance measurements will be made in the events l
[
N-25 of plant shut downs and restarts.
1 Billingoloy 13
('~s 2
Q Does a Westinghouse pressurized water
)
x_/
3 reactor of the type that was used at the Connecticut 4
Yankee station include a pressurizer in the primary
'El 5
v * -'
6 A
Yes, it does.
7 Q
I take it that a pressurizer had certain 8
relief valves associated with it?
9 A
Yes, it does.
10 Q
Does the system also utilize reactor 11 coolant pumps?
12 A
Yes, it does, 13 Q
Does it utilize steam' generators?
r3 ty 14 A
Yes, it does.
15 Q
Did your duties and responsibilities at 16 connecticut Yankee during the 1971 through 1974 or
'5 17 period when you were a reactor engineering assistant 18 include any responsibilities with respect to the l
19 pressurizer, the reactor coolant pumps, the steam l
20 generators or any of the associated piping and 21 equipment auxilliary to those components?
22 A
Could you repeat that question again, 23 please?
24 MR. WISE:
I won't do it as well as I
/~'
(_)%
25 did the first time.
Maybe Charlie can read it
1 Billingolcy 14 (V) 2 back.
3 (Question read by the reporter.)
4 A
As I stated before, some of my
- g) 5 responsibilities did include the core itself and vessel.
6 I must ask you to qualify auxilliaries.
7 Q
I did not mean to confuse the matter.
8 I am simply trying to determin*e whether 9
during this first part of your work for Connecticut 10 Yankee you had any responsibilities with respect to 11 the major primary components that I have listed, 12 the pressurizer, the steam generators, the reactor
^
(\\ }
13 coolant pumps and the piping and associated equipment
/
14 that connects those components.
15 A
only in tangential ways, those ways would 16 include measurement of reactor coolant system flow, 1
17 measurement of moderated temperature coefficients 18 Q
I am sorry, I missed that.
l 19 A
Moderator temperature coefficients, l
20 measurement of Delta T across loops, reactor coolant 21 loops, but no direct involvement with steam generators e
22 in that time frame that you mentioned, no direct 23 involvement with reactor coolant pumps during that 24 time period that you mentioned and that would include
~#
25 the limit of my responsibilacies at that time, l
l
1 Billingsicy 15 m
(
h 2
Q After 1975 when you became facility w/
3 engineer your duties and responsibilities changed 4
as you have described them.
(ll 5
Did you, as a facility engineer, have 6
any responsibility for th'ose major primary components 7
that I have mentioned?
8 A
I was responsible as facility engineer 9
for steam generator surveillance as required by federal 10 codes, testing and all requirements for surveillance 11 of the steam generators.
12 I was also responsible for all testing
'T 13 and modifications to the reactor containment emergency (G
14 fan units.
I was also responsible for testing of 15 the containment structure as required by federal code.
16 Q
During any of the time that you were with l
17 Connecticut Yankee from 1971 through 1978 did you have 1
18 any responsibilities for the drafting, review or l
19 approval of operating or emergency procedures?
l 20 A
I cannot at this time recall whether I 21 had responsibilities for those particular types of 22 procedures.
l 23 Q
Did you have responsibilities for some l
24 types of procedures?
25 A
Yes, I did.
1 Dillingoloy 16
(
)
2 Q
Could you describe to the best of your v
3 recollection what procedures you were responsible for?
4 A
I was responsible for changes to, review 4ll 5
and in some cases approval of procedures related to 6
start-up physics testing, procedure development for 7
equipment overhaul and changeouts, procedure 8
modification and review and limited approval of 9
procedures for testing those items which I described 10 to you earlier which include containment, the 11 containment structure, containment emergency fan units 12 and any procedures required to perform my particular
/^T 13 function.
U 14 Q
Did you have any responsibility for 15 procedutes regarding emergency core cooling?
16 A
No.
17 Q
Did you have any responsibility for 18 procedures regarding a loss of coolant accident?
19 A
No.
20 Q
Did you have any responsibilities for l
21 procedures regarding the operation of the reactor l
22 coolant pumps?
l 23 A
No, 24 Q
Did you have any responsibility for
[_
l 25 procedures regarding the operation or possible failure l
l
1 Billings 1Cy 17
(~l 2
of the pressurizer and associated equipment?
G' 3
A No.
4 Q
Did you have any responsibility for sjh 5
procedures regarding natural circulation in the primary 6
system?
7 A
No.
8 Q
Did you ever have any responsibility for 9
procedures regarding a so-called steam line break from 10 the secondary side?
11 A
No.
12 Q
During the time you were with Connecticut
--)
13 Yankee from 1971 through 1978 did you ever have any J
14 responsibility for training of others at the company?
15 A
No.
I 16 Q
Your only exposure to training was the 17 training that you yourself received when you first 18 came to the company?
19 A
That's correct.
l 20 Q
Have you ever visited a simulator?
l l
21 A
No.
l 22 Q
To your knowledge, during the period 1971 23 through 1978,did Connecticut Yankee employ or retain 24 any company to provide simulator training to its
()l k-25 operators or operator candidates?
l l
c 1
Billingoloy 18
/\\
/
i 2
A I believe so.
V 3
Q what is the source of your knowledge 4
about that?
(ll 5
A Others in my company who attended the 6
simulator.
7 Q
Where was the simulator located?
8 A
I believe the simulator was at Combustion 9
Engineering.
10 Q
Do you know at what facility?
11 A
No, I don't.
12 Q
Based upon what you were told was the
('S 13 use of the simulator'for the purpose of training V
14 operators to obtain their license or was it used 15 primarily for requalification training or both?
16 A
- Both, 17 Q
Do you know during what period the 18 simulator was employed, the simulator training was 19 empicyed from the outset or did it start up at some 20 later time?
21 A
My company began using the simulator 22 training around 1975 or
'6.
23 Q
During the course of your study when you 24 first joined the company and were attempting to 25 obtain a control room operator's license did you review
1 Billingolcy 19
('%
i
)
2 operating and emergency procedures for the station?
3 A
For the station or for my training?
4 Q
I would have thought they would be the lll 5
same.
Perhaps I better ask another question, though.
6 were there at Connecticut Yankee operating 7
and emergency procedures in use for the operation of 8
the plant?
9 A
Yes, there were.
10 Q
During your nine months of training when 11 you first came to Connecticut Yankee, was it part of 12 the training to review and learn those operating and
[)
13 emergency procedures?
14 A
Yes, it was.
15 Q
Were there any procedures that you can is now recall with respect to a loss of coolant accident?
17 A
Yes, there were.
18 Q
Were there any procedures that you can 19 now recall with respect to a failure of the valves 20 at the top of the pressurizer?
21 A
I cannot recall.
22 Q
Do you recall whether you ever received 23 any instruction on how to diagnose and what actions 24 to take in the event of a failure of one of the g-V 25 valves at the top of the pressurizer?
1 Dillingoloy 20 (m) 2 A
Will you repeat that question again,
\\
3 Please?
4 Q
Let me break it down, il l 5
Do you recall now whether you ever 6
received any instruction concerning the diagnosis of 7
a failed valve at the top of the pressurizer?
8 A
No, I do not recall.
9 Q
one way or the other or are you saying you 10 recall now that you did not receive such instruction?
11 A
I don't recall receiving that instraction.
12 Q
I am just trying to make it clear whether 13 your lack of recollection is that you do not recall
('^'}
N/
14 one way or the other whether you received it or 15 whether you now recall that you did not receive it.
16 A
I don't recall one way or the other.
17 Q
okay.
18 Do you recall whether you ever received 19 any instruction on what to do in the event a failure 20 of one of the valves at the top of the pressurizer 21 occurred?
22 A
No, I do not recall.
23 Q
During the course of your training did 24 you receive any instruction concerning the relationship
)
~#
25 of temperature and pressure in the primary system?
1 Billingolay 21 r~w
(
)
2 A
Yes.
3 Q
Did you receive any instruction with 4
respect to the phenomenon known as saturation?
'lh 5
MR. GLASSMAN:
You are talking about in 6
thi~s particular nine-month period?
7 MR. WISE:
Yes.
8 A
That I don't recall.
9 Q
Do you recall whether you received any 10 instruction with respect to the so-called bubble 11 in the pressurizer?
12 A
I vaguely remember a discussion, but f^)
13 that is vag'ue.
v 14 Q
It is quite some time ago?
15 A
Yes, it is.
16 Q
Did you receive instructions with respect 17 to how to diagnose a loss of coolant accident?
18 A
Yes.
19 Q
Did the Westinghouse reactor at Connecticut 20 Yankee have an emergency core cooling system?
21 A
Yes, it did.
22 Q
Did it include some form of high pressure 23 injection in the event of a loss of reactor system 24 coolant pressure?
,_s s
~
25 A
Yes, it did.
1 Billingsley 22
()
2 Q
Did you receive any instruction during
(,
3 your training with respect to the operation of the 4
high pressure injection system?
5 A
Yes.
6 Q
Did it include when to leave it on and 7
when to turn it off?
8 A
That I do not recall.
9 Q
Do you recall being instructed as to what 10 its actuation meant?
11 A
Yes.
12 Q
What were you told?
13 A
Actuation of the -- we had two types, we q}
l 14 had high pressure and low pressure injection and the l
15 actuation of those emergency systems meant loss of 16 coolant typically.
17 Q
Your resume indicates that you left the 18 Connecticut Yankee facility in 1978 and went to work 19 for General Public Utilities Service Corporation.
20 What was the reason for your change of 21 positions?
l g
1 g
22 A
A better position and money.
23 Q
What was your new position at GPU?
24 A
My new position was senior engineer.
rxb 25 Q
Did you have any particular area that you 1
I 1
Billingcicy 23
(,
')
2 were assigned to?
%./
3 A
When you say area, do you mean department?
4 Q
Yes.
- h 5
A Yes.
6 Q
could you describe what it was?
7 A
I was assigned to the Productivity 8
Department.
Its primary function was to provide 9
liaison with corporate headquarters and site facilities, 10 fossil primarily,to improve their system efficiencies.
11 Q
When you say the Productivity Department, 12 are you referring to this smallest unit for which you
(
13 worked or was that some larger suborganization 14 within the company?
15 A
That was a suborganization of, I believe, 16 the Generation Division.
17 Q
The head of the Generation Division at 18 the time in 1978 I believe was Mr. Arnold?
19 A
Th at 's very possible.
I do not recall.
20 Q
Do you remember a Mr. Bachofer?
21 A
Yes, I do.
22 Q
What was his position?
23 A
He was a director at that time.
24 Q
Not a director of the company?
O 25 A
No.
He was a director of, I believe,
1 cillingoloy 24
( )
2 Generation, but I am not entirely sure.
I was not in 3
that position a very long time.
4 Q
I want to get the organization as best jll 5
I can but since you have indicated you were not in 6
your first position very long, perhaps you could 7
describe how long you were in it and what the next 8
position was that you held at GPU Service.
9 A
I worked in the Productivity Department 10 from January 15, 1979 to approximately the first week 11 in April of
'79.
12 Q
Your resume indicates that you went to
-(m) 13 work for GPU in 1978.
14 A
I am very sorry about that.
That is in 15 error and I didn't catch it.
16 I was given a position by GPU approximately 17 December
'78.
I left my company -- my former l
l 18 company, Connecticut Yankee January 15, 1979 and 19 went to work at GPU on January 15,
'79.
20 Q
You were in the Productivity Department 21 between January 15, 1979 and approximately the first 22 week of April of '79?
23 A
Yes.
I must explain that to you.
I 24 Officially I was in the Productivity l
3 25 Department all the way through 1980 -- all the way
1 Billingoloy 25 2
until approximately April of 1980.
3 The accident changed my role such that 4
although I was officially grouped in the Froductivity illl 5
Department I in fact did no work in the Productivity 6
Department.
7 Q
Let's come to the post-accident work that 8
you did later and let's concentrate on the period 9
between January and April 1979 for a moment.
10 A
Post or pre-accident?
11 Q
Pre-accident.
12 A
okay.
(~T 13 Q
Pre-accident.
C/
14 The accident occurred on March 28, 1979.
15 sometime, as I understand it, the first week of April 16 you began to concentrate your efforts on post-accident 17 matters?
18 A
Correct.
19 Q
so, looking at the period January through 20 March and just trying to get an idea of where you 21 were in the organization, my understanding is that 22 the vice president for the Generation Division was 23 Mr. Arnold.
24 I take it you don't recall that one way
.r%
\\'-)
25 or the other during that period?
1 Billingolcy 26
(_,I 2
A No, I don't.
3 Q
We have some charts which have been 4
produced to us by GPU Service.
They show in March
- lll 5
of 1979 Mr. Bachofer held the position of Director, 6
Generation Operations.
7 Does that ring a bell with you?
8 A
Yes, it does.
9 Q
He reported directly to Mr. Arnold 10 according to the charts we have.
11 MR. GLASSMAN:
Just so the question is 12 clear, maybe you are ringing bells with the
/' i
(
)
13 witness here, but I think it's important to
%./
l 14 distinguish between his knowledge and what a 15 chart says.
Obviously we are not converting l
l 16 the chart that has been produced here.
I am 17 just not sure this is the appropriate witness 18 to go through that with, 10 MR. WISE:
I am just trying to get to 20 a direct line to where he was in the organization, 21 that's all.
22 Q
Are you familiar with Mr. Long?
l 23 A
Yes, I am.
24 Q
The chart shows that he was manager of
\\J 25 something called Generation Productivity.
i
s
\\
1 Billingcicy 27
/
(
)
2 Is that your recollection of his --
w
-T'at is correct.
3 A
h 4
Q
-. position?
'jll 5
He reported at the time to Mr. Bachofer?
6 A
That is correct.
7 Q
And you reported to Mr. Long?
8 A
Correct.
9 Q
The chart lists your position as 10 Performance Analysis Engineer Senior 1-Mechanical 11 Engineering.
12 Ne have had testimony from previous rx i
13 witnesses indicating that at times they were not even (t-)
14 aware of the various designations that the Personnel 15 Department had for them, and I just am curious whether 16 you are familiar with those various titles and that 1
17 nomenclature for the job position that you held l
l 18 between January and March 1979.
l 19 A
No, I am not familiar with that entire 20 title.
l 21 Q
Are you familiar that you were working in l
l 22 an area known as Performance Analysis?
23 A
vaguely.
24 Q
When you mentioned the Productivity f3 j
25 Department, were you refarring to Mr. Long's unit in l
l l
1
1 Dillingoley 28
(
\\
()
2 essence?
3 A
Yes, I was.
4 Q
You described the function of the Productivity jll 5
Department to be a liaison between corporate 6
headquarters and various other places including the 7
sites where, I take it, GPU had generating facilities.
8 Just exactly what were you acting as 9
liaison for, what kind of information and communications?
10 MR. GLAS S MAN :
Are you looking now for 11 what Mr. Billingsley did or what the department 12 generally did?
(~)
13 MR. WISE:
I think what the department
(/
14 generally did.
Ok'y.
15 MR. GLASSMAN:
So far as he knows.
a 16 A
Generally the department would take a 17 look at various data requested from the plants, take 18 a look at the system efficiency losses, take a look 19 at those and try to provide them guidance on where 20 to make up for losses in their system generation.
21 when I say system, I mean a particular 22 site facility.
That was the primary function and 23 that was one of the primary duties of the department.
24 Q
There is another organization within the (s\\
25 Generation Division headed by a Mr. Wilson.
1 Billingolcy
,29 m
2 Did you ever know Mr. Wilson, R.
F.
Wilson v)
(
3 or know of him?
4 A
I know of him.
jll 5
Q He is director of something called l
6 Technical Services or at least was during March of
(
7 1979 according to the chart we have and he has a whole 8
array of people working for him including Mr. Keaton 9
and others.
l 10 What was the relationship as you 11 understood it between the area of the Generation l
12 Division that you were in and the area served by 13 Mr. Wilson's organization, the so-called Technical
(']'
l l
v I
14 Services group?
15 A
I cannot tell you what the differences l
16 were.
I don't even know what Mr. Wilson's charter 17 was.
I have no idea.
18 Q
You mentioned that during the January 19 to March period your responsibilities were primarily 20 with respect to the fossil plants; is that right?
21 A
Correct.
I 22 Q
Did you have any responsibilities at all 23 with regard to the three nuclear plants in the GPU 24 system at the time?
/, \\
\\' '/
25 A
Just prior to the accident, and I am
1 sillingoley 30
()
2 talking probably February time frame, I had a small
\\_/
3 involvement with taking a look at a computer that 4
they were buying for one of the Three Mile Island jll 5
units.
They were considering buying.
6 Q
Do you recall which unit?
7 A
I do not.
8 Q'
What was the function of the computer 9
to be?
10 A
I can only give you a broad overview 11 because I only attended one or maybe two meetings 12 which discussed this computer.
(~h 13 It was my understanding from those
'V 14 meetings that this computer was going to take a look 15 at various plant parameters and provide scan functions, 16 printout functions, things of that sort.
17 Q
Was this to be a piece of control room 18 equipment?
19 A
That I cannot say with complete certainty 20 but I would assume so.
21 Q
Who else was involved on this particular 22 proj ect from GPU Service?
23 A
Robert Long attended the meeting with me.
24 Other people involved I can't recall.
I was very O },
t k
25 new to the company at that point in time so there
1 Billingoloy 31 f ')
2 were a large number of people I didn't even know.
8J 3
Q Approximately how many people were at 4
the meeting?
Are you talking about 10, 20?
jll 5
A 10, 12 people maybe.
6 Q
Was there anyone there from Metropolitan 7
Edison, to your knowledge?
8 A
I cannot say.
9 Q
Was there anyone there from outside the 10 GPU system?
11 A
I cannot say.
12 Q
Were there any representatives of any
(~)/
13 vendors there?
w 14 A
I cannot say.
l 15 Q
How long did the meeting last?
16 A
I would guess an hour, an hour and a half.
17 Q
What was the conclusion of the meeting, 18 if any?
l 19 A
The meeting was primarily a presentation 20 of the computer they were considering purchasing.
21 The outcome of the meeting I cannot say 22 because it was more a presentation than anything 23 else.
There was some short question and answer period t
24 and that's all I can recall with respect to that l
/N 1
t 25 meeting.
l t
1 Dillingaloy 32
[
'}
2 Q
Who made the presentation?
%s 3
A I can't remember the fellow's name.
4 Q
Was he someone from within the Generation lll 5
Division of GPU Service?
6 A
I cannot say he was within the Generation 7
Division but I can say he worked for GPU.
8 Q
Were you ever told why you were invited 9
to that meeting?
10 A
No.
11 Q
Were you ever given any responsibilities 12 for assignments as a result of or in connection with 13 the possible purchase of a computer for the Three
(~~}
w/
14 Mile Island station?
15 A
I recall at one point in time I had taken 16 a look at some of the parameters they wanted a 17 computer to take, look at to review the feasibility 18 and the desirability of looking at those particular 19 parameters.
20 I do not recall, however, whether that 21 data requirements were associated with that particular 22 computer for which I attended the meeting.
23 Q
What parameters were you consulted on?
24 A
Pump vibration, equipment vibration
("h 25 monitoring and printouts.
Those are the ones that
1 Dillingoloy 33 m
2 stand out in my mind.
There were probably others.
(ms) 3 Q
Was there any reason why you were consulted 4
on those parameters as opposed to anyone else in
]ll 5
GPU Service?
6 MR. GLASSMAN:
As far as he --
7 MR. WISE:
As far as you are aware.
8 A
As far as my group or as far as I am 9
aware?
10 Q
As far as you are aware.
11 A
No.
12 Q
Did it come --
(T 13 A
I can guess.
%.]
14 Q
I don't want you to guess but I mean did 15
- it come as a complete surprise to you that someone 16 spoke to you about pump vibration?
17 A
No.
18 Q
What background had you had or involvement 19 had you had with respect to that particular parameter?
20 A
My former company I had a lot of 21 involvement with our in-house computer.
I had also 22 been involved with equipment performance.
Those are 23 the reasons.
24 Q
I asked you earlier and I may have missed
)
\\
25 it because of the various time periods, if you had
1 Dillingaley 34
('S
(,)
2 any involvement with respect to the performance of 3
certain maior nrimary system components including 4
the reactor coolant pumps while you were at Connecticut jll 5
Yankee.
6 Do I take it that during some period of 7
your employment there you were involved with the 8
performance of reactor coolant pumps?
9 A
No.
10 Q
Now, I am a bit confused.
I understand 11 your last answer to be that you had had some background 12 in equipment performance.
O,l 13 A
gorrect.
14 Q
And it did not include the reactor coolant 15 pump?
16 A
That's correct.
17 Q
when you arrived at GPU Service, one of 18 the parameters you were asked to look at involved 19 vibration'in the reactor coolant pumps; is that right?
20 A
I do not recall saying that, I recall 21 saying pumps.
22 Q
I see.
23 we are talking about some pumps other 24 than the reactor coolant pumps?
G 25 A
with respect to taking a look at the
1 Dillingelsy 35
[ ')
2 computer I could say that I am pretty sure that it v
3 did not involve computer -- did not involve reactor 4
coolant pumps.
jll 5
Q What pumps do you recall it involved?
6 A
I can't recall what pumps per se.
7 MR. GLASSMAN:
I will just include a 8
slight note that just as in Mr. Broughton's 9
deposition we find that while a rose was a 10 rose, a flow chart was not necessarily equal l
11 to every other flow chart.
I guess we have the 12 great knowledge that a pump is not necessarily f'S 13 a pump.
~. >
14 THE WITNESS:
It is not necessarily a r
l 15 reactor coolant pump.
I l
16 Q
Do you recall anything of the substance 17 of the presentation that was given concerning the 18 possible purchase of a computer for one of the TMI 19 stations?
20 A
Primary discussion centered around the l
21 scan rate of the computer, computer storage 1
1 22 capabilities and may have touched on interface 23 feasibility with other computers either in-house at 24 the time or possible future purchases.
O LJ 25 Q
Do you recall whether any particular model
l 1
BillingDloy 36
()
2 or make of computer was under discussion?
3 A
Yes.
I believe the model discussed at 4
that time was Mod-Comp.
lll 5
Q Who manufactures Mod-Comp?
6 A
I vaguely remember that to be Johnson 7
Controls or a subsidiary thereof.
8 Q
After the meeting did you have any further 9
involvement in the possible purchase of a new computer 10 for TMI up to the time of the March 28th accident?
11 A
No, I did not.
12 Q
You didn't hear anything further about it
~}
13 one way or another?
/
l
'\\J 14 A
No, I did not.
15 Q
We began this discussion of the possible 16 purchase of a computer when I asked the question l
i 17 whether you had had any duties or responsibilities 18 with respect to the three nuclear stations in the 19 GPU system and you have now described this one 20 activity.
21 were there any other activities that you 22 had between January 1979 when you joined GPU Service 23 and the time of the accident with respect to the l
24 three nuclear facilities in the GPU system?
)
25 A
Not to the best of my knowledge.
l
1 BillingDlGy 37
[ w)i 2
Q When did you first become involved in 3
the work related to the March 28, 1979 accident?
4 A
Approximately the first, second week in ijll 5
April.
6 Q
What happened then?
7 A
I was asked by my boss at the time, Robert 8
Long, to come down to Three Mile Island to work.
9 Q
What did he tell you?
10 A
Prior to coming there, nothing.
11 Q
What happened when you arrived at the 12 site?
("T 13 A
I began working in a trailer there that
(_/
14 was off site gathering and filing data.
15 Q
What kinds of data?
l 16 A
That I can't say.
I never really viewed i
17 the data that was presented.
I merely took it in 18 and provided a source for a collection, filing of 19 data as well as answering phones.
That was about 20 the extent of it.
21 Q
Was there any particular group or working l
9 22 task force that you were associated with at that l
23 time?
I l
24 A
Upor. my first arrival?
l (7,)
25 Q
Yes.
1
1 Dillingoloy 38
, -.( )
2 A
At TMI?
3 Q
Yes.
4 A
No.
lll 5
Q who gave you.your assignments?
How did 6
you know where to go and what to do?
7 A
My assignment when I first came there was 8
very clear.
This is your trailer and that you will 9
work in this -- let's call it data collection group.
10 Q
Who gave you that assignment?
11 A
Robert Long.
12 Q
How long did you continue performing f )a 13 essentially this data collection function?
14 A
For about two weeks.
15 Q
What happened then?
16 A
Then I came back to Parsippany and went 17 to work in a fossil group.
18 Q
Did that work have anything to do with 19 the March 28, 1979 accident?
20 A
No, it did not.
21 Q
When was the next time that you became 9
22 involved in any way in activities related to the 23 March 28 accident?
24 A
Some time in May, going back to Three f-
_]
25 Mile Island and worked for John Bachofer.
1 sillingolcy 39
()
2 Q
Who gave you that assignment?
U if 3
A I don't really know.
I was asked to 4
I would go down to Three Mile Island and report to lll 5
John Bachofer.
6 Q
Who asked you to do that?
7 A
I believe it was Personnel.
8 Q
When you returned to Parsippany and 9
between April and this May return to the island, you 10 were still working for Mr. Long?
11 A
Yes, I was.
12 Q
When you arrived back at the island in
,/~]
13 May, what happened?
V 14 A
I began working in a group that was 15 setting up reading air systems for workers going into 16 contaminated or highly active buildings on site.
17 Q
Did you have any other duties or l
18 responsibilities at that time?
19 A
No.
~
20 Q
How long did you continue doing that type 21 of work?
22 A
Until approximately the end of May, maybe 23 the first week in June.
24 Q
What happened then?
t, r
25 A
I came back to Parsippany and began I
e 1
Billingoley 40
[;
2 working again in the Productivity Department, v
3 Q
Did your work at that time have any 4
connection to the March 28 accident?
lll 5
A Not until I was in Parsippany maybe two 6
to three weeks.
My next assignment was to investigate 7
various areas as assigned.
8 Q
This would be in about mid June of 1979?
9 A
Yes.
10 Q
Who gave you the assignment to investigate 11 various areas?
12 A
Robert Long.
('N 13 Q
Could you be a little bit more precise
' j'
. 14 as to what it is he told you to investigate and when?
15 MR. GLASSMAN:
What time frame are we 16 now talking about?
17 MR. WISE:
Mid June when he first again 18 turned his attentions to the March 28 accident.
19 MR. GLASSMAN:
I am not sure the testimony 20 has been that he turned his attention to that 21 in June, but that's 22 MR. WISE:
I thihk he testified that he 23 returned to Parsippany from the island and 24 went back to the Productivity Department l
(~)
tJ 25 working for Mr. Long and I asked him when was I
1 01111ngsloy 41
(
j 2
the next time that he had any connection with v
3 the March 28th accident.
I believe his 4
testimony was that it occurred when several jll 5
weeks later Mr. Long asked him to investigate 6
various areas.
7 I am now focusing on that time when 8
Mr. Long first comes back to him and says 9
would you investigate certain areas.
10 Q
What is your recollection of specifically 11 what Mr. Long asked you to do at that time?
12 A
My firs t assignment was to investigate
()
13 make-up pump operation as it occurred during the March 14 accident.
15 Q
Prior to Mr. Long giving you this 16 assignment, had you in your work experience both at 17 GPU Service and Connecticut Yankee ever had any 18 involvement with the operation of make-up pumps?
19 A
Not per se.
20 My experience at Connecticut Yankee was 21 with pumps that had similar emergency operation 22 requirements.
Those pumps in my former experience 23 were called high pressure and low pressure safety 24 injection pumps, 3
l t
s"'/
25 At Three Mile Island they are called
1 Cillingaley 42 lq 2
make-up pumps and do not necessarily have all the
\\_/
3 same applications.
4 Q
At Three Mile Island it is correct, isn't lll 5
it, that the make-up pumps after automatic actuation 6
of the emergency system operate in a mode known as 7
high pressure injection?
8 A
That is correct.
9 Q
My understanding, Mr. Billingsley, is 10 that the pump is the same, it is one physical piece 11 of equipment, but that it can operate in more than 12 one mode; is that right?
())
13 A
- Yes, Q,
14 Q
One of the modes it can operate in is a 15 no rmal make-up mode, is that right?
16 A
Correct.
l 17 Q
And another mode is the so-called high i
18 pressure inj ection mode?
19 A
correct.
20 Q
When it is operating in the high pressure 21 inj ection mode it is part of the emergency core 22 cooling system?
23 A
correct.
24 Q
Did Mr. Long, in assigning you to
('
25 investigate make-up pump operation during the accident,
1 Dillingoloy 43
['}
2 give you any specifics as to what aspects of its s_-
3 operation he wished you to look into?
4 A
No.
I was told, however, to take a look lll 5
at the operation during approximately the first 24 6
hours of the incident.
7 Q
Did Mr. Long tell you why he wanted you 8
to make this investigation?
9 A
I vaguely remember it to be he wanted 10 me to take a look at when the pumps were operating 11 and when they were not operating during the accident.
12 Q
Were you told whether this was part of 7'N 13 the normal work of the Productivity Department or t
j 14 whether it was in connection with some special 15 investigation or task force activities that were 16 going on?
l l
17 A
I know it was not part of the activities l
18 of the Product Test Group.
I do not recall, however, 19 whether it was stated to me that this work was in 20 conjunction with a task force.
21 Q
What did you do to pursue the investigation?
S 22 A
I provided Robert Long with an outline 23 of how I would conduct the investigation and where I 24 would look and I proceeded accordingly.
C')
25 Q
was anyone else working on this investigation
1 Billingolcy 44 f's 2
with you?
Y 3
A No.
I did, however, as part of a normal 4
course of research, speak with various people.
lll 5
Q Did you eventually prepare a report for 6
Mr. Long?
7 A
Yes, I did.
8 Q
Do you recall about when that was done?
9 A
I believe a date is provided on the report 10 and to the best of my recollection I believe that 11 report was published maybe August of
'79, 12 Q
we will come back to that investigation
/~}
13 a little bit later in this deposition, but let me O
14 ask you this now because I a'm only trying to get a 15 chronology.
16 During the period from mid June 1979 17 through the time the report was published in August 18 of 1979, did you perform any other activities in 19 connection with the March 28 accident besides your 20 inves tiga tion of make-up pump operat. ion?
21 A
No, I believe that was
--I believe 22 that was it.
As far as in that time period I think 23 that was the only report that I had done, 24 Q
You weren't a member of any of the task
/9
\\
25 force or investigating teams that were working on
' ~ -
1 Dillingalcy 45
<x IU) 2 any other aspects of the March 28 accident?
3 A
No, not to the best of my memory, no.
4 Q
Were you ever interviewed or deposed by ll 5
any group at any time before today relating to any 6
connection you may have had to the March 28 accident?
7 A
No.
8 g
What happened after August of 1979 and 9
the time that you finished your report on make-up 10 pump operation?
What did you do next?
11 A
Next, my next assignment was to take a 12 look at the PORV history.
(~')
13 Q
When did you receive that assignment?
v 14 A
I believe that was around August.
15 Q
Who gave it to you?
16 A
That was Robert Long.
17 Q
What did he tell you he wanted you to do?
18 A
He wanted me to take a look at history 19 of the PORV at Three Mile Island and assemble as 20 complete a picture of the valve history as possible, 21 take a look at maintenance records, take a look at 22 how the item was procured.
I believe I provided 23 him again with an outline of how I expected to 24 proceed with that investigation as well, w-25 Q
Did he approve the outline or give you
1 tillingalcy 46
[;
2 any comments on it?
s_,
3 A
I Provided him with the outline.
I can't 4
recall if he had substantial comments and what those lh S
comments were.
I can't recall.
6 Q
Was anyone else working with you on your 7
investigation of PORV history?
8 A
Yes.
9 Q
Who else?
10 A
A fellow named Jim Correa, another fellow 11 whose first name I cannot recall, whose last name 12 is either Bogert or Bogart, I can't remember.
His
{~}
13 name should be written down.
v 14 MR. WISE:
Off the record, i
15 (Discussion off the record.)
l 16 (Recess taken.)
17 BY MR. WISE:
18 Q
Before we took our break we were l
19 discussing the investigation you made at Mr. Long's 20 request into the history of the PORV at TMI-2.
I 21 had asked you who else participated in that l
22 investigation and you mentioned Mr. Correa and 23 Mr. Bogert.
24 were there any others who assisted in 25 that investigation to your knowledge?
1 Billingolcy 47 m
(
)
2 A
No.
w, 3
Q When did you begin work on the investigation?
4 A
APProximately August of
'79, llh 5
Q What was Mr. Correa's position at the 6
time?
7 A
His title?
8 Q
Yes.
I will take that as a beginning.
9 A
His title, I believe, was Engineer.
What 10 level, I don't recall.
11 Q
There are a lot of engineers in GPU 12 Service.
f ')
13 was he connected with any particular wJ 14 department or unit within the company?
15 A
I believe he was in Generation, but I am 16 not sure.
17 Q
Do you know for whom he worked?
18 A
No, I do not.
19 Q
Do you have any idea what his background 20 was prior to the time you began working with him on 21 this investigation?
22 MR. GLASSMAN:
What do you mean by 23 background?
24 MR. WISE:
Anything that Mr. Billingsley g-(
/
25 can recall about this individual.
1 Dillingsloy 48
[)
2 A
I believe this individual had knowledge s/
3 and had done work with valves.
4 Q
With any particular type of valves?
lll 5
A I don't know of any particular type.
I 6
would just say valves in general.
7 Q
Did he have an office, to your knowledge?
8 A
Yes, he did.
9 Q
Where was that located?
10 A
His office was in the Mountain Lakes 11 Building in Parsippany.
12 Q
Was it in any particular part of the 13 building?
(~)T
'm 14 A
I can't recall if he was on the first or 15 second floor of that building.
I don't recall.
16 Q
Did you ever visit his office?
17 A
Yes.
l 18 Q
When you did so, did you become aware of l
19 what section or group his office was located next to l
20 or in?
21 A
some of the people located around his 22 office were Gary Capodanno and he may have been working l
23 for Gary at that time.
l
'4 Mike Kostry was also located in that I
(~h 25 area.
k
1 nillingcicy 49 f) 2 Those are the two primary individuals G'
3 that I can recall who worked in that area.
4 Q
How about Mr. Bogert?
What was his llh 5
position or in what area of the company did he work?
6 A
Mr. Bogert had, involvement with cur 7
Productivity group from the time I came in the 8
company, that's when I first met him at a couple of 9
meetings, until the time he left the employment of 10 GPU.
11 Q
Did he report to Mr. Long?
12 A
No, he did not.
(;
13 I don't know who Mr. Bogert reported to, d
14 Bogert, Bogart.
We will have to get the spelling of 15 that.
16 Q
What did he do?
17 A
He has some involvement with our 18 Productivity group.
Exactly what his function was, l
19 I can't say.
l 20 The thing you have to keep in mind here 21 is I was with the company a very short period of time l
22 and I experienced quite a bit of shuffling like 23 cards down in Atlantic City, so I didn't have a lot 24 of time to meet people or learn their functions.
25 Q
Did Mr. Bogert assist with the investigation
1 Billingalsy 50 fh 2
from its beginning to its completion?
v; 3
A Mr. Bogert was involved initially, I 4
would say for the first maybe month, month and a llh 5
half of the investigation.
6 g
What happened then with respect to him?
7 A
He took another job someplace else.
l 8
Q Within the GPU organization?
9 A
No, with another company.
10 Q
You said you began your work in August of 11 1979.
Was the work ever completed?
12 A
Yes, it was.
(^T 13 Q
When?
V 14 A
The final report was issued approximately 15 July of 1980.
16 Q
Your final report, I take it, was TDR-126?
17 A
No.
My final report was TDR, I believe 18 160.
19 Q
During the time that you were working on 20 the history of the PORV from August of '79 through 21 July 1980 did you have any other duties or 22 responsibilities or perform any other activities in 23 connection with the March 1979 accident?
24 A
Yes, I did.
25 Q
What other duties or activities were you
1 Billingoloy 51 I-s')
2 involved with?
LJ 3
A I became involved with another TDR.
I 4
was requested to help gather data to be used as input lll 5
into another report that was being written at the 6
time concerning PORV leakage.
7 Q
Who asked you to work on this project?
8 A
Ed Wallace.
9 Q
Who was Mr. Wallace at the time or what 10 position did he hold?
11 A
Mr. Wallace was a manager in the 12 licensing area.
f~N 13 Q
Were you reporting to Mr. Wallace at the G
14 time?
15 A
Yes, at the time I was reporting to 16 Mr. Wallace.
17 Q
When did you first begin to report to 18 Mr. Wallace as opposed to Mr. Long?
19 A
Approximately September of
'79.
20 Q
Did you become part of the Licensing 21 Department at that time?
22 A
No, I did not.
23 Q
Will you explain how you came to report 24 to Mr. Wallace in September of 19797
~>
25 A
Yes.
I believe the Productivity group
1 Billingaloy 52 f~}
2 had been disassembled and the members of that grcup
's J 3
went to work for various other people in the company.
4 Mr. Wallace came to me and asked me if lll 5
I would like to work for him and we discussed it and 6
I began to work for him at around September of 1979.
7 Q
This was while you were continuing with 8
your work on the assignment that Mr. Long had given 9
you concerning the PORV history?
10 A
That is correct.
11 Q
So that from September of '79 on you 12 were working for Mr. Long and for Mr. Wallace; is
(~T 13 that fair?
%.)
14 A
I was working for Mr. Wallace in reality.
15 I was still working for Mr. Long on paper, I believe, 16 with respect to the organization.
Some confusing 17 times.
I 18 Q
What did Mr. Wallace ask you to do l
19 concerning the PORV leakage investiga' tion?
20 A
As stated earlier I was asked to gather l
l 21 various data that was felt relevant to the report.
l 22 g
Were you asked to perform any analyses or 23 calculations with respect to that data?
l 24 A
No.
I did not perform any analysis of-(
l 25 the data.
/
1 Billingsloy 53 2
Q Were there other persons working with
(
j ss-3 you on the investigation of PORV leakage?
4 A
Yes.
lll 5
Q Who were they?
6 A
Some of the parties are Capodanno, Rochino.
7 Q
Let me suggest some names to you.
8 Was there a Mr. Shaw?
9 A
Shaw or Sheu.
~
10 g
Maybe Sheu.
It's a very bad copy that I 11 am reading from.
12 A
I don't remember that individual but I
/~)
13 believe his name does show up on that report.
LJ 14 Q
And a Mr. Maheshwari?
15 A
That was a name I recall but I knew that 16 you would be better pronouncing it then myself.
17 Q
I don't know why you came to that 18 conclusion.
l l
l 19 A
But I was right.
20 Q
Did you ever meet Mr. Maheshwari?
21 A
Yes, I did.
22 Q
Do you recall that he was working with you 23 on the inves tigation?
24 A
Yes, I do.
/,T L) 25 Q
Let me go through these names and see if
1 Dillingc1cy 54
, ~N
)
2 I can get your recollection of how they came to be on 3
the investigation with you.
4 Mr. Capodanno, what was his position and llk 5
to the best of your knowledge why was he working on 6
the investigation with you?
7 A
He was a manager in I believe that some 8
of the other people that worked on the analysis of 9
the report probably worked for him.
10 Who those people are, I don't know.
11 Q
was he a manager of anything in particular?
12 A
I cannot recall what group he was a
/m()
13 manager of.
14 Q
Do you know what his area of expertise 15 was?
16 A
No.
1 17 Q
In any event your recollection is that 18 some of the analyses and calculations were done 19 through his auspices?
20 A
I believe so.
21 Q
Mr. Rochino, what is your recollection of 22 his position and how he came to be on the investigation 23 with you?
3 24 A
Dr. Rochino may have been a manager at
( s>
s 25 that time.
I don't recall.
I believe he was but I
1 Billingoley 55 ol 1
2 can't recall with certainty.
\\_/
3 Q
Did he have any particular area of 4
expertise, to your knowledge?
lll 5
A I can give you what I believe was his 6
area of expertise at that time.
His area of expertise, 7
I believe, was heat transfer.
8 Q
Do you know for whom he worked?
9 A
No, I do not.
10 Q
Do you know if he was within the Technical 11 Services Section of the Generation Division?
12 A
I believe he was.
~
13 Q
You said that you did not remember (v}
14 Mr. Sheu very well.
15.
Do you remember anything about him?
16 A
Nothing.
17 Q
Not his area of expertise or what 18 contribution he made to the investigation?
19 A
No.
20 Q
Mr. Maheshwari, do you recall anything about what his position was at the time or how he came 21 22 to be involved in the investigation?
23 A
I don't recall his position as far as 24 title goes at the time.
I do know that he worked
]
25 on analysis of some of the data as well as the writing
~'
5
1 Billingcicy 56
[ ')
2 of the report.
TDR, I believe, 126.
U 3
Q Is Mr. Capodanno still with the company 4
to your knowledge?
lll 5
A Yes, he is.
6 Q
Is Dr. Rochino?
7 A
Yes, he is.
8 Q
Is Mr. Maheshwari?
9 A
No.
10 Q
Where is Mr. Mahedhwari now to the best 11 of your knowledge?
12 A
He is with another company and I don't
(~')
13 recall the company he is with.
(.)
14 Q
When did he leave?
15 A
I don't know.
16 Q
Where is the company located?
l 17 A
I don't know.
18 Q
What field is the company in?
19 A
I believe it is an engineering firm.
20 Q
Do you know whether it is in the New 21 York-New Jersey area?
22 A
I am fairly sure it is in the New Jersey 23 g g.r s.
24 Q
You said that you began work on this
/~.,')
(
/
25 PORv leakage investigation in September of 1979.
1 Billingolcy 57 f) 2 Was the investigation ever completed?
U 3
MR. GLASSMAN:
Are you talking about 4
Mr. Billingsley's work or the report itself?
lll 5
MR. WISE:
Perhaps there is a distinction.
6 Q
My understanding was that you were asked 7
to begin work in September of 1979 by Mr. Wallace on 8
the PORV leakage investigation.
9 A
Yes, I believe it was about that time.
10 Q
Did there come a time when your work was 11 finished?
12 A
Yes.
l (;
13 Q
When was that?
l
%)
l 14 A
I can't recall the exact month.
It may i
l 15 have been November.
I 16 Q
of what year?
17 A
I believe 1979.
18 Q
Was the entire investigation completed 19 at the time you finished your work?
20 A
I don't believe so.
My input was finished 21 before the report was published.
22 Q
You were aware that a report eventually 23 was published?
24 A
Yes.
f3 i
)
25 MR. WISE:
We are going to mark in a
1 Billingolcy 58 I
2 few minutes TDR-126 (V
3 Q
I believe it shows you signed it on 4
February 27, 1980.
lll 5
Would that correspond roughly with your 6
recollection of when the report was published?
7 A
Yes, that's probably a much better date.
8 Yes.
9 Q
After the TDR was published in February, 10 late February 1980, did you do any further work with 11 respect to the PORV leakage investigation?
12 A
No.
^%
13 Q
I had asked you what activities in (d
14 connection with the"Three Mile Island accident you 15 performed aside from the PORV history investigation 16 during the period July -- I'm sorry -- August 1979 17 through July 1980.
You have mentioned your activities 18 in connection with this investigation of PORV leakage.
19 Were there any other activities that you 20 undertook during that period that involved the March 21 1979 accident at TMI?
22 A
Yes.
23 Q
could you describe what others there were?
24 A
I worked on reviewing the sequence of
[j,'
\\
25 events that was provided by a consultant.
l l
l l
l
1 Billingolcy 59 p}
2 Q
What was the name of the consultant?
3 A
stafco.
4 g
Where were they located?
lll 5
A I vaguely remember their offices were 6
located in Washington, D.C.
7 Q
When did you become involved with the 8
sequence of events work?
9 A
This is extremely hazy.
10 I believe my involvement with that work 11 was maybe December of
'79, it may have started 12 January of '80 and that work continued through maybe (v~~^)
13 May of
'80.
14 Q
Was anyone else working with you --
15 A
Yes.
16 Q
-- on the sequence of events review?
l 17 Who?
18 A
Jim Flarethy.
19 Q
Is Mr. Flarethy a GPU Service employee?
20 A
No.
21 Q
By whom was he employed?
22 A
He was employed by Energy Incorporated.
I 23 Q
Who was Energy Incorporated?
24 A
That was a consultant on site at Three 25 Mile Island.
1 Billingoloy 60 em
/
)
2 g
Who asked you to undertake work on the U
3 sequence of events review?
4 A
Ed Wallace.
llh 5
Q What did he tell you to do?
6 A
He requested that I answer any questions 7
that the consultant group had, that I also review the 8
report for completeness.
9 Q
Was there any particular section of the 10 sequence of events for which you were responsible?
11 A
No.
12 Q
Who at Stafco did you talk with?
()
13 A
I believe a fellow named McEwen.
v 14 Q
Anyone else that you can recall?
15 A
At stafco?
16 Q
Yes.
17 A
No.
18 I believe there may have been one other 19 person but I can't recall who.
20 Q
After Mr. Wallace asked you to undertake 21 this assignment, what did you do to pursue it?
22 A
I worked along with Jim Flarethy and 23 also another individual who had also written a 24 sequence of events, compared sequence of events, 7_
25 reviewed each time frame taken in the sequence of
1 Billings 1sy 61
'~T 2
events of Stafco and of another individual at Three (d
3 Mile Island who was writing sequence of events as 4
well and reviewed for accuracy and completeness llh 5
and recommended changes where necessary, 6
Q Let me see if I have it straight how 7
many different sequence of events there were under 8
preparation at this time.
9 one was being prepared by Stafco?
10 A
correct.
11 Q
When did you first see a Stafco sequence 12 of events?
Was one already in existence for instance
()
13 at the time that Mr. Wallace gave you your assignment?
(_)
14 A
Yes, there was, 15 Q
Did you obtain a copy of it?
16 A
Yes.
17 Q
From whom?
l 18 A
I believe Ed Wallace.
I 19 Q
Did Mr. Wallace tell you who had retained l
l 20 Stafco to prepare such a sequence of events?
l 21 A
I don't believe he himself told me.
He 22 may have.
23 Q
What did you learn about how Stafco came 24 to have prepared a sequence of events which wound up r-)
25 in your hands?
1 Billingoloy 62
/~h 2
A The information that I had is that GPU O
3 had retained Stafco to write the sequence of events.
4 That is my total understanding.
llh 5
Q You mentioned that there was another 6
individual who had also written a sequence of events, 7
A Correct.
8 Q
Is that someone that was employed within the 9
GPU system?
10 A
Let me answer that question by saying I 11 believe he was employed by Metropolitan Edison.
12 Q
Who was it?
(]
13 A
John Putman.
\\_ /
14 Q
For whom did Mr. Putman work, if you knew?
15 A
I was never really sure who he reported 16 to, 17 Q
Did you ever learn what his area of 18 responsibility was within Met Ed?
In other words, what l
19 department or unit he was with?
I l
20 A
No.
1 21 Q
Did you ever learn how he had come to 22 write a sequence of events?
23 A
No.
Not to the best of my recollection.
l 24 Q
Had he prepared one as of the time that l
(~h 25 you were assigned this review task?
l l
l l
1 Billingaloy 63
(~)J 2
A Yes.
L 3
Q so there was in existence a sequence of 4
events draft prepared by Stafco and one prepared ll 5
by Mr. Putman of Met Ed.
6 were t.here any other draft sequence of 7
events in existence that you became aware of prepared 8
within the GPU system or for it by a consultant as 9
of December or January of 1980?
December 1979 or 10 January 1980.
11 A
I don't know.
12 Q
Specifically are you aware whether Energy, fS 13 Inc. had ever prepared a sequence of events draft?
%Y 14 A
No, I was not aware of that.
15 Q
Did you ever see an Energy, Inc. sequence 16 of events draft?
17 A
No.
18 Q
Why, to your knowledge, was Energy, Inc.
l 19 involved in the sequence of events work?
20 A
Are you talking about Jim Flarethy?
I 21 Q
Maybe we ought to go back.
You mentioned 22 Mr. Flarethy worked with you on this review?
23 A
Right.
24 Q
How did he come to do that, to your n
l l
x/
25 knowledge?
1 1
1
1 Billingoloy 64
/~
2 A
He may have also been asked by Wallace b) 3 to work with me on that.
4 Q
Did you ever come to learn why Energy, Inc.'s lh 5
services were being employed to look at the sequence 6
of events drafts that had been prepared?
7 A
The only reason that I would know of would 8
be because of Energy, Inc. was brought on site as a 9
consulting group, 10 Q
Did you ever learn whether Mr. Flarethy 11 had had any involvement with the preparation of a 12 draft sequence of events prior to the time you began
("';
13 working with him to review what work Stafco had done?
'w]
14 A
No, not to the best of my knowledge.
15 Q
Aside from the draft prepared by Stafco 16 and the draft prepared by Mr. Putman of Met Ed, did 17 you consider any other drafts in your review of 18 events?
19 A
Yes.
20 Q
What other drafts did you have?
21 A
I believe EPRI had a draft at that time, 9
22 Q
Were there any others?
23 A
Not that I can remember.
24 Q
You said your work continued through
(%
25 May 1980.
1 Billingoloy 65
(')
2 What happened in May of 1980 to cause V
3 a cessation of your work on reviewing the sequence 4
of events?
llh 5
A At about that time I took another job 6
with a group called Materials Management.
7 Q
Had the work on the sequence of events 8
been completed in May 19807 9
A No.
10 Q
Did it continue after you left, to your 11 knowledge?
12 A
I don't know.
/~3 13 Q
The job that you took in May 1980 in
,V 14 Materials Management is the one that you still hold 15 today?
16 A
Correct.
l l
17 Q
What are your duties and responsibilities l
18 in that job?
19 A
I am a senior staff administrator for 20 the Director of Materials Management.
My responsibilities l
l 21 include providing consultation and special proj ect l
I 22 assignments in various areas of materials management, t
l 23 Q
Is that a function that reports to 24 Mr. Glickman?
r^x 25 A
Correct.
l l
1 BillingDlGy 66 (v) 2 Q
Are you now working for the service 3
corporation or the nuclear corporation?
4 A
The nuclear corporation.
I 5
Q So that on your resume here where it says 6
" General Public Utilities Service Corporation Materials 7
Management Department," that should now read " General 8
Public Utilitie's Nuclear"?
9 A
That is correct.
10 Q
Let me go back and make sure that I have 11 a complete answer to my earlier question.
12 You have told us now about your work on
(~)'
13 the make-up pump operation during the accident, your G
14 participation in an investigation of the PORV history 15 before the accident, your assistance in an investigation 16 of PORV leakage before the accident and finally 17 your work on reviewing draft sequence of events that 18 had been prepared following the accident.
19 Are there any other assignments, tasks 20 or activities which you undertook through May 1980 21 relating to the Three Mile Island accident?
g 22 A
No, not that I can remember.
23 Q
Have you had any duties or responsibilities 24 or performed any activities since May 1980 relating
?
i 25 to the Three Mile Island accident?
1 BillingolGy 67 47%
(
\\
2 A
No.
%j' 3
Q I am going to now ask you some questions 4
concerning the work you did on your investigation k
5 of PORV leakage before the TMI accident.
6 Let me begin --
7 MR. GLASSMAN:
You are not talking about 8
work done after the accident regarding PORV 9
leakage which may or may not have occurred 10 before the accident?
11 MR. WISE:
That's correct.
12 Q
Let me ask you as a preliminary question,
(~')
13 have you ever met someone at GPU Service named LJ 14 Stubbs, S-t-u-b-b-s?
15 A
You are asking me where I met Stubbs?
16 Q
No, I am asking have you ever met such 17 a person, 18 A
Yes, I have, 19 Q
You know who he is?
20 A
Yes, I do.
l 21 Q
Who is Mr. Stubbs?
gg 22 A
Stubbs worked for, I believe, Energy 23 Incorporated.
24 Q
In what connection did you meet him?
O]
r
25 A
I originally met Mr. Stubbs because he l
l l
1 Billingsley 60 2
occupied the same trailer that I was in while I was 3
at TMI.
4 Q
Did you ever have any communication with lll l
5 Mr. Stubbs during the course of your work on the PORV 6
leakage investigation?
7 A
Yes, I did.
8 Q
Could you tell us in what connection that 9
occurred?
10 A
Yes.
Mr. stubbs had done some work with 11 looking at tailpipe temperatures.
He had also 12 gathered some data and reviewed data concerning 13 those tailpipe temperatures as well as looking at 14 some recorder data.
15 Q
How did.you come to be aware of his work?
16 A
I initially became aware of his work 17 because I was located in the same trailer that he 18 was in.
19 I later became more intimately involved 20 with his work as a result of my request to become 21 involved in TDR-126, 22 Q
TDR-126 was the one that covered PORV 23 leakage?
24 A
Correct.
25 Q
I guess my question now is how did you
1 Billingoloy 69
[]
2 link up with Mr. Stubbs during the course of that
\\_/
3 investigation?
4 A
I linked up with Mr. Stubbs because he had lll 5
done work in this area and I was able to obtain 6
information that he had had and may have still been 7
working on at that time and was able to transmit that 8
data back to people in Parsippany and I also believe 9
he may have been working for Ed Wallace at the same 10 time.
11 Q
Do you know someone named J,C.
- Birt, 12 B-i-r-t?
(~}
13 A
Birt, Birt, Birt.
Yes, I do.
'u.)
14 Q
Who is Mr. Birt?
15 A
Mr. Birt was also employed by Energy Incorporated and it appeared that he performed a role 16 17 of an assistant to, I believe, the manager of the 18 Energy Incorporated group who was a fellow named 19 Tom van Whitbeck, 20 Q
Was Mr. Birt involved, to your knowledge, 21 in any investigation of pressurizer valve leakage 9
1 1
22 before the accident?
23 A
Before the accident?
24 Q
obviously his involvement would have been 25 after the accident.
'~~
1 Billingoloy 70
(~)
2 I am speaking about leakage that occurred
'wJ 3
before the accident.
4 A
Okay.
lll 5
I don't know for sure.
6 MR. WISE:
I would like to have marked as 7
B&W Exhibit 428 a copy of TDR-126 entitled 8
" Investigation of TMI-2 Pressurizer PORV 9
Discharge Pipe Temperatures."
10 (Copy of TDR-126 en ti tl e d' " Investigation 11 of TMI-2 Pressurizer PORV Discharge Pipe 12 Temperatures" marked B&W Exhibit 428 for (J^]
13 identification, as of this date.)
14 Q
Mr. Billingsley, do you recognize B&W 15 Exhibit 428?
16 A
Yes, I do.
17 Q
can you tell us what-it is?
18 A
This is a report investigating PORV 19 discharge pipe temperatures.
' 20 Q
Was this prepared in connection with 21 your investigation of leakage from the top of the 22 pressurizer before the accident?
23 A
This was not my investigation.
This 24 report is in conjunction with data that I. helped
\\
('
25 provide as an input to this report.
1 Billingalcy 71
(~')
2 Q
Did you prepare any separate report with
%)
3 respect to the work that you personally did?
4 A
I prepared a report which referenced this lh 5
particular report.
6 Q
You are speaking of TDR-1607 7
A correct.
8 Q
That had to do with the history of the 9
PORV?
10 A
That's correct.
11 Q
I am now asking about the work that you 12 did specifically on leakage from the pressurizer valves.
(~
13 Was there any other report that you wrote G}'
14 aside from whatever may be reflected in TDR-126?
15 A
No.
16 Q
The cover page on TDR-126 contains a number 17 of signatures next to the typed names of the 18 originators.
Your name appears as one of the five j
19 originators and there is a signature next to it.
20 Is that yours?
21 A
That's correct.
g 22 Q
Under the approval column there is a l
23 signature that is quite difficult to read and based I
24 on prior testimony and other reports my understanding l
/~N 25 is that that is the signature of Mr. Croneberger.
l l
t
1 Billingaloy 72 7m 5
)
2 Do you recognize Mr. Croneberger's
(/
3 signature?
4 A
Based on this report?
khI 5
Q Well, you see that there is a signature 6
under the approvals column?
7 A
Do I know whose signature this is?
8 Q
Yes.
9 A
Yes, that is Mr. Croneberger's signature.
10 Q
Who is Mr. Croneberger?
11 A
He is a manager, I believe he is a manager 12 in what was formerly the Generation Division.
I
(
13 believe he works for Mr. Wilson.
14 Q
That is the Technical Services group?
15 A
Correct.
16 Q
Do you have any knowledge or information l
17 as to why he was the approving manager with respect 18 to this report?
l 19 A
Yes, I believe he had overall responsibility l
20 for overseeing the development of this report.
21 Q
I had understood that Mr. Wallace was 22 the individual who had assigned you to participate 23 in this activity.
24 Did Mr. Wallace report to Mr. Croneberger 25 with respect to this activity?
l l
l l
l
1-Gillingolcy 73
(~)
2 A
He may have.
V 3
Q What was your understanding as to the 4
relationship between Mr. Wallace and Mr. Croneberger lll 5
with respect to this particular report?
6 A
I never h'ad an understanding whatsoever 7
of the relationship, I never questioned it.
8 Q
During the time that you were working on 9
your investigation concerning leakege from the 10 pressurizer valves, who was your supervisor?
11 A
Mr. Wallace.
12 Q
Let me ask you a question that I have been (Q~]
13 asking everyone but not getting any answers to.
14 On the front page of this particular 15 copy of the TDR there is a stamp that reads "GPU 16 System Libraries TMI."
17 Do you see that?
18 A
- yes, 19 Q
Do you have any knowledge as to what that 20 stamp reflects or indicates?
21 A
No.
22 Q
Have you ever seen such a stamp before?
23 A
I may have.
24 Q
Do you know taa existence of anything at CT k-25 GPU called "GPU System Libraries TMI"?
1 Billingolcy 74 (J
T 2
A No.
3 Q
Aside from TDR-126 and TDR-160, which 4
we will be speaking about later, have you participated lll 5
in the preparation of any other TDR's?
6 A
Yes.
A TDR on make-up pump operation.
7 I believe the TDR number is 118.
8 Q
We will be e ming to that a little bit 9
later, too.
10 A
Yes.
11 Q
Aside from those three are there any 12 others that you recall participating in?
(N 13 A
No.
\\s')
14 Q
Attached to TDR-126 is an Appendix A.
It 15 begins at page 379 that was marked for the litigation.
16 Do you see that?
17 A
Yes.
18 Q
Appendix A appears to be a memorandum l
l 19 and certain attachments prepared by Mr. Stubbs.
There 20 is a cover memo dated February 22, 1980 addressed to 21 Mr. Wallace with a distribution to a number of l
22 people including yourself.
23 A
Yes.
l 24 Q
That's at page 880 as marked for the
[
)#
25 purposes of the litigation.
1 Billingsicy 75 T^N 2
Do you see that?
O.
3 A
Yes.
4 Q
Do you recall receiving a copy of the lhk 5
memorandum,that is the cover page of Appendix A and 6
the attached report that went with it?
7 A
Yes.
8 Q
You will note that under Mr. Stubbs' name 9
the title has been typed in " Accident Assessment 10 Group."
11 Do you see that?
12 A
Yes.
/~
13 Q
Do you have any knowledge or understanding N3) 14 as to what was meant by " Accident Assessment Group"?
15 A
I believe that was Energy Incorporated.
those three 16 I am familiar with that 17 words there, yes, I am.
That's the extent of my 18 knowledge about that word, those three words.
l l
19 Q
You think that was a title used within 20 Energy Incorporated rather than something that 21 included GPU system personnel?
22 A
I believe so.
l l
23 Q
Do you have any knowledge as to how the l
24 distribution list provided at page 880 was put Q2 25 together, that particular grouping of names
1 Billingoloy 76
(~')
2 including yourself?
NJ 3
MR. GLASSMAN:
You don't want the witness 4
to speculate?
k 5
MR. WISE:
I am curious as to whether he 6
has any knowledge or information as to whether 7
that represents some grouping of individuals.
8 A
I can only provide educated speculation.
9 Q
I don't want your guesswork.
I would 10 like whatever knowledge that you have that bears 11 upon how that list got put together or what it 12 signifies.
(~S 13 MR. GLASSMAN:
I have an objection to V
14 the form.
You have a number of questions there.
15 One, what knowledge he has as to how or why 16 it was put together.
Some other generalized 17 question as to what it signifies and I am not 18 sure --
19 MR. WISE:
We can take them one at a 20 time.
21 Q
Do you have any knowledge or information 5
22 as to how that list was composed?
23 A
No.
24 Q
Do you have any knowledge or information
\\l 25 as to the significance of that particular listing?
1 Billingoloy 77
'^h 2
MR. GLASSMAN:
Significance to whom?
3 Q
Any knowledge or information as to why 4
those individuals were chosen as opposed to others, h
5 A
No.
6 Q
At the time you received this memorandum 7
did you ever question why you were listed on the 8
distribution list?
9 A
No.
10 Q
Did this particular memorandum arrive out 11 of the blue on your desk?
12 MR. GLASSMAN:
Objection.
/~'
13 I don't know what you mean by "out of the k,)3 14 blue."
We all know things don't come from 15 heaven.
16 MR. WISE:
I think "out of the blue" is 17 a commonly used phrase, i
(
18 MR. GLASSMAN:
I will obj ect as to form.
l l
l 19 Perhaps if the question is directed as to 20 whether Mr. Billingsley was surprised to receive I
21 it or something of that nature, perhaps it's l
l l
22 appropriate.
l l
23 Q
Mr. Billingsley, what was your understanding l
24 when you received this memorandum as to why you got it?
I 25 A
My understanding was that I got this l
l l
I l
1 Dillingoloy 78 2
report because I had had involvement with PORV leakage U(~]
3 investigation that was being conducted and this 4
report, depending upon the date, may have an input h
5 to that.
Obviously it was.
6 MR. GLASSMAN:
Off the record.
7 (Discussion off the record.)
8 MR. WISE:
Let's break for lunch at this 9
time.
10 (Luncheon recess taken at 12:30 o' clock.)
11
-oOo-12 13
(-}
v 14 15 t
i 16 17 l
18 l
l 19 l
20 l
21 l
O 1
22 U
24 1
7%
25
1 Billingolcy 79 (V~')
(2:15 o' clock P.M.)
4 QU INCY B I LL ING S LEY I I I lhk 5
having been previously sworn, resumed, and 6
continued to testify as follows:
7 EXAMINATION (continued) 8 BY MR. WISE:
9 Q
Before lunch, Mr. Billingsley, we were
~
10 discussing B&W Exhibit 428 which is a copy of TDR-126 11 and you participated as one of the originators of 12 that TDR and attached to it is Appendix A which is s
13 a report under a cover memorandum by Mr. Stubbs 14 dated February 22, 1980 sent to Mr. Wallace and a 15 group of other people on the distribution list i
16 including yourself.
l 17 What I would like to do now is to mark l
l 18 a series of documents which I believe are connected l
19 and have them identified.
20 MR. WISE:
First is a memorandum dated 21 March 28, 1980 from Mr. Stubbs to Mr. Wallace 22 with virtually the same distribution list, 23 there are a few differences.
24 The title of the memorandum is " Investigation 1
25 of Three Mile Island Unit 2 Pressurizer Relief
1 Dillingolay 80 2
Valve Leakage Prior to March 28, 1979."
G 3
We will have that marked as B&W 429.
4 (Memorandum dated March 28, 1980 from llh 5
Mr. stubbs to Mr. Wallace titled " Investigation 6
of T,hree Mile Island Unit 2 Pressurizer Relief 7
Valve Leakage Prior to March 28, 1979" marked 8
B&W Exhibit 429 for identification, as of this 9
date.)
10 Q
Have you ever seen B&W 429 before?
11 A
Yes, I have seen this document.
12 Q
I am not speaking of the particular copy 13 which may have come from Mr. Keaton's files as U
14 indicated by the stamp, but you have seen a typewritten 15 version of the document that was sent to you?
16 A
Yes.
17 Q
Another copy.
l 18 Now, in the memorandum the text indicates 19 that the "results of the investigation to determine 20 the leakage path past the Unit 2 pressurizer 21 relief valve prior to March 28, 1979" are attached.
22 The second page of the memorandum at the 23 bottom presents a list which carries over on to the 24 third page of the memorandum of five analyses or
(~)i
\\s 25 reports.
1 Billingoloy 81 e'~x 2
MR. WISE:
I would like to now show you
\\~_/
3 and have marked five reports which I believe 4
are the ones referenced by Mr. Stubbs in this llh 5
cover memorandum, B&W 429.
6 The first of them is a memorandum dated 7
March 17, 1980 from Mr. Stubbs to file, the 8
subject is " Analysis of TMI-2 Plant Computer 9
Data Pertaining to Pressurizer Relief Valves."
10 I believe it is the first item listed in 11 his cover memorandum, 429 on page 2.
12 The particular copy I will note for the 13 record that we are showing you has come from f-b 14 your file and the first page of the exhibit is 15 a photocopy of the file jacket with some 1
1 16 handwriting on it.
l l
17 (Memorandum dated March 17, 1980 from l
I l
18 Mr. Stubbs to file, subject, " Analysis of TMI-2 19 Plant Computer Data Pertaining to Pressurizer 20 Relief Valves," marked B&W Exhibit 430 for 21 identification, as of this date.)
22 Q
First I would like to ask you, do you 23 recognize Exhibit 4307 I
24 A
Yes.
l
(~'T l
'\\_)
25 Q
Is the file which has been photocopied i
l
1 Billingolcy 82 0
2 the first page of the exhibit, a file that you
(
s q) 3 maintained?
4 A
Yes, it is.
lll 5
MR. WISE:
I would like to have marked 6
as B&W Exhibit 431 an exhibit which includes, 7
I believe -- well, let's de them separately.
8 We will do them one at a time.
9 As B&W Exhibit 431 a memorandum dated 10 February 22, 1980 from Mr. Stubbs to Mr. Wallace 11 and distribution.
The subject is " Analysis of 12 RAD Waste Disposal /RC Leakage Temperature
~'s 13 Multipoint Recorder Data."
That will bc 431.
(O 14 (Memorandum dated February 22, 1980 15 from Mr. Stubbs to Mr. Wallace and distribution, 16 subject, " Analysis of RAD Waste Disposal /
17 RC Leakage Temperature Multipoint Recorder 18 Data," marked B&W Exhibit 431 for identification, 19 as of this date.)
20 Q
Mr. Billingsley, do you recognize B&W 21 Exhibit 431?
l dBi 22 A
Yes, I do.
i l
i 23 Q
Is that one of the memoranda that l
l 24 Mr. Stubbs sent to you?
p_
i
(
)
25 A
Yes, it is.
1
,T' 1
Billingsley 83 x
2
.MR. WISE:
I would like to have marked 3
as B&W Exhibit 432 a copy of a memorandum i
4 dated February 15, 1980 from Mr. Stubbs to llh 5
'f il e.
The subj ect is " RAD Waste Disposal /RC 6-Leakage Temperature Multipoint Recorder 7
operation."
8 (Memorandum dated February 15, 1984 from 9
Mr. Stubbs to file, subject, " RAD Waste 10 Disposal /RC Leakage Temperature Multipoint 11 Recorder Operation," marked B&W Exhibit 432 12 for identification, as of this date.)
()
13 MR WISE:
Let me just go ahead, 14 Mr. Billingsley, and mark the other two that 15 we have.
16 Let's have marked as B&W 433 a copy of a 17 memorandum dated March 26, 1980 from Mr. Stubbs 18
' to f 61%
The subject is " Review of RC Leakage 19 It 'sta Results Prior to March 28, 1979."
\\
20 tCopy of memorandum dated March 26, 1980 s
21 from Mr. Stubbs to file, subject, " Review of S
22 RC Leakage Test Data Results Prior to March 28, 23 1979," marked B&W Exhibit 433 for identification, 24 as of this date.)
\\
25 1 MR. WISE:
I will ask to have marked as s
s s
I
..--,8.-.
1 Dillingolcy 84
\\
/
(
)
2 B&W Exhibit 434 a copy of a memorandum dated
\\J 3
March 17, 1980 from Mr. Stubbs to Mr. Wallace 4
and distribution including Mr. Billingsley.
k 5
The memorandum is entitled " Review of the 6
Three Mile Island Unit 2 Reactor Coolant Leakage 7
Test Procedure."
8 (Copy of memorandum dated March 17, 1980 9
from Mr. Stubbs to Mr. Wallace, entitled " Review 10 of the Three Mile Island Unit 2 Reactor Coolant 11 Leakage Test Procedure," marked B&W Exhibit 434 12 for identification, as of this date.)
()
13 Q
Mr. Billingsley, I have asked you if you 14 could identify the first two memorandum in the series, 15 B&W 430 and 431.
Let me just ask you whether the 16 same is true with respect to B&W Exhibits 432, 433 17 and 434.
18 Can you also identify those as copies of 19 memoranda that you received from Mr. Stubbs?
20 A
I don't recall 432 and 433.
I do recall 21 434.
22 Q
Do you recall whether when you received 23 B&W 429, which is the overall cover memo, the first 24 in the series, whether when you received that, which
'\\,.)
25 references and says that it has attached to it
1 Dillingalsy 85 m j 2
five reports which correspond in title to the five 3
reports we have just identified and marked B&W 4
Exhibits 430 through 434, there were in fact the llk 5
attachments annexed to B&W 429 that it says are 6
attached?
7 A
I don't recall.
8 Q
You have no reason to believe that they 9
were not?
10 A
I have no reason to believe they were not.
11 Q
Did you read these memoranda when you 12 received them?
(~]
13 A
I can assume that I did.
I don't recall.
'N_/
14 Q
Did you ever have any discussions with 15 Mr. Stubbs concerning any of these exhibits, B&W 429 16 through B&W 434?
17 A
Yes.
18 Q
When did that take place?
19 A
I dcn't recall.
20 Q
Which of the memoranda did you discuss 21 with Mr. Stubbs?
22 A
I don't recall.
23 Q
Did you have more than one discussion 24 with him about these?
O
\\-~'I 25 A
I believe that I did.
1 Billingolcy 86
,\\()
2 Q
Approximately how many discussions did 3
you have with him?
4 A
Maybe two or three.
llh 5
Q Did they take place withi n some time 6
fxame, say a month, a period of weeks, a period of 7
days?
8 A
I believe they were within a period of a 9
month.
10 Q
How long were thess discussions?
11 A
I don't recall.
j 12 Q
What was the subject of the discussions?
l r'
(w N 13 A
The subjects of the discussions were 14 one or more of these exhibits.
15 Q
Can you recall which ones were discussed?
16 A
I recall discussing Exhibit 431 and 432.
17 Q
432 was one of the ones I understood you l
l 18 earlier to say you did not remember ever seeing.
i 19 Do you now recall that you did sec it?
20 MR. GLASSM.,:
I will note for the 21 record that the witness has been sitting here 22 during a long pause and reviewing the documents l
23 and the question is directed as well to see 1
24 whether the document refreshes his recollection.
s I
%,)
25 MR. WISE:
Certainly.
1 Gillingoloy 87
[/
s
(,
2 Q
I wasn't saying you weren't being 3
candid with us earlier.
4 Do you recall, having gone through the I
5 documents, whether they refresh your recollection 6
that you had seen the entire set of exhibits?
7 A
I recall discussing 432 with Mr. Stubbs, 8
therefore I did see this document.
9 Q
Will you take a look at 433 which now is 10 the only one, if my recollection of your testimony 11 is right, you do not have a present recollection of 12 having seen and take a little bit closer look at it
[)
13 to see whether it helps refresh your recollection as v
14 to whether in fact you did see it.
15 A
Which document is that?
16 Q
B&W Exhibit 433.
The one entitled 17
" Review of RC Leakage Test Data Results Prior to 18 March 28, 1979."
19 A
I still don't recall reviewing this 20 document.
21 Q
You said that you remembered discussing g
22 with Mr. Stubbs B&W Exhibit 431 and 432, 23 Do you recall discussing with him any of 24 the other exhibits?
'v/
25 A
No, I do not.
1 Sillingoloy 88
)
2 Q
Let's take B&W Exhibit 431 first.
What 3
discussion did you have with Mr. Stubbs concerning 4
this exhibit?
It is entitled " Analysis of RAD Waste lh 5
Disposal /RC Leakage Temperature Multipoint Recorder 6
Data."
7 And by the way, I believe this is the same 8
memorandum that is attached as Appendix A to 9
TDR-126 of which you were an originator.
10 A
I remember discussing with Mr. Stubbs 11 the facts -- the fact that he was looking at a 12 substantial amount of data and that it was very time I
('N 13 consuming to do this particular job.
I also recall ^
q,/
14 and I can't recall if it is Exhibit 432 or 431, since 15 both of these documents refer to the multipoint 16 recorder, I recall him mentioning that there were 17 some problems in reading the recorder stripcharts.
18 Q
What is a multipoint recorder, in 19 particular, the one referenced by Mr. Stubbs in B&W 20 Exhibits 431 and 432?
21 A
I can't address this particular multipoint 22 recorder because I have never seen it and I myesif 23 don't recall reviewing any of those stripcharts.
l 24 I am familiar -- I have seen multipoint
/9 i
25 recorders but I can't address this particular
~'
1 Billingoloy 89
/~N.
(_,)
2 multipoint recorder.
3 Q
Did you have any understanding as to 4
what multipoint recorder Mr. Stubbs was referring to llh 5
in his memoranda?
6 A
Yes, I knew which multipoint recorder he 7
was addressing here, yes.
8 Q
Where was that recorder located?
9 A
I don't know.
10 Q
was it located in the control room?
11 A
I don't know.
12 Q
What was the purpose of the multipoint O
t j
13 recorder as you came to understand it?
'w /
14 A
Of this particular multipoint recorder?
15 Q
Yes, the one that Mr. Stubbs was taalking 16 about in his memoranda and that you discussed with 17 him.
18 A
My understanding of my discussion with 19 him was that the stripcharts off of that particular it was time consuming and at times 20 recorder was 21 difficult to read.
22 Q
What did the recorder show?
Did it show 23 plant parameters, television shows, what?
24 A
Plant parameters.
g-LI 25 Q
What kind of plant parameters?
P
1 Dillingsley 90 rx
'(,)
2 A
These were temperatures recorded by the 3
multipoint recorder for RAD waste.
4 Q
RAD waste would be radiation waste lll 5
products?
6 A
I-don ' t know for sure.
7 Q
You never came to have an understanding of 8
what was meant by that term, " RAD waste"?
9 A
It was not important for the purpose -- the 10 purposes that he was addressing.
11 Q
You became aware during the course of 12 your work on the PORV history and the PORV leakage f) 13 rate, those two investigations, that there were
%J 14 thermocouples both in front of and behind the various 15 relief valves at the top of the pressurizer, did you 16 not?
17 A
Correct.
18 Q
How many relief valves are there at the 19 top of the pressurizer at TMI-27 20 A
There are three.
21 Q
one of them is a so-called pilot l
l 22 operated relief valve, I believe; is that right?
i 23 A
correct.
l l
l 24 Q
And there are two others known as code gg t
25 safeties?
1 Billingsley 91
(~h
()
2 A
Correct.
3 Q
The code safeties are spring loaded 4
valves; is that right?
llh 5
A Correct.
6 Q
The pilot operated relief valve opens 7
and closes based on pressure; is that right?
j 8
A Correct.
G Q
The spring loaded code safeties open on 10 pressure but cannot be depended upon to reseat 11 following a drop in pressure; is that correct?
12 A
That's right.
()
13 MR. GLASSMAN:
I just should note that 14 the same question was not asked with regard to 15 th e PORV in terms of dependability and that 16 should not be taken as any indication on the 17 record that the witness has testified with 18 regard to the dependability of closure of other 19 valves.
~
20 Q
All three relief valves at the top of 21 the pressurizer valve I believe have pipes, so-called 22 discharge pipes that lead away from the valve to a 23 header which in turn runs down to a reactor coolant 24 draining tank; is that your understanding?
rS
(
)
u/
25 A
correct.
1 Billingoloy 92 7'
(N,)
2 Q
And is it true that thermocouples are 3
Placed on those discharge pipes that lead away from 4
the relief valves?
h 5
A correct.
6 Q
Is it also true that there are two 7
separate systems of thermocouples hooked up to those 8
pipes?
9 MR. GLASSMAN:
Is this question directed 10 to what the witness learned through his 11 particular work or are the questions directed to 12 that appear now to be what might or might not
/'N 13 be currently in place at the island?
I think (v) 14 I know that counsel is asking for the results 15 or the understanding that Mr. Billingsley gained 16 through his work but just so we are clear for 17 future questioning, I wanted to make that 18 distinction now.
19 The question as phrased appeared to ask 20 for some current knowledge of what might be 21 insignificant now and I think the witness 22 testified he has not worked on anything relating 23 to the TMI accident for some time, 24 Q
My questions in this area, Mr. Billingsley, g-(.)
25 are directed at what you learned about the design and
1 1
Billingsley 93 p) 2 condition of the system at the time prior to March 28,
(,
3 1979.
I don't know that anything has been changed 4
since then but if it has been that is not my area of 5
interest.
6 Let me repeat my question.
7 It is correct, isn't it, that there are 8
two separate systems of thermocouples in place or 9
were in place at the time of the accident for the 10 purpose of measuring discharge pipe temperatures?
11 A
I do not recall that that is specifically 12 the case.
.rh
(,)
13 Q
Let me ask you, did you ever learn that 14 there were three thermocouples hooked up to the 15 plant computer?
16 A
I did not learn that, no.
17 Q
Did you ever learn that that system was 18 separate from the multipoint recorder which had, I 19 believe, six separate thermocouples?
l 20 A
I do not recall that to be the case.
21 Q
You do recall discussing B&W Exhibit 431 ggg 22 with Mr. Stubbs?
l 23 A
Yes, I do.
24 Q
You had read it, I take it?
(~S
\\_)
25 A
Yes, I did.
1 Billingsley 94
(_)
2 Q
would you turn to the first page.
Do 3
you see on that first page a description of the data 4
points that were available through the multipoint 5
recorder?
6 A
Yes, I do.
7 Q
And you see there that there were six 8
thermocouples hooked up to the multipoint recorder 9
each with a separate tag number and location?
10 MR. GLASSMAN:
Are you asking for the 11 witness' recollection of what he understood 12 by this chart?
O) 13 I would note that -- well, there are
(,,
14 numbers on the particular page we are looking 15 at, unless I am reading it incorrectly, I 16 don't actually see the particular designation 17 of what those tag numbers stand for or not so 18 that in that sense the question is unclear.
19 Q
Mr. Billingsley, you were part of the 20 team that was invantigating PORV leakage before the ggg 21 accident, we have established that.
22 Did you never come to learn where the 23 thermocouples were located?
(']
24 MR. GLASSMAN:
I should object and note L.;
25 that the witness' testimony is not indicative of
95 1
Billingsley (3
(_)
2 as broad an involvement in an investigation 3
as counsel seems to indicate and therefore there 4
is an assumption in the question that is 5
unfounded, He obviously did some work in relation 6
to it and he testified to that.
7 If you have a particular question as to 8
whether he came to learn of a particular 9
thermocouple or locations or points, obviously 10 you can ask that.
11 MR. WISE:
Perhaps let's lay a foundation 12 for this and then the question will be more
(")\\
13 clear.
x_
14 Q
Did you come to have any understanding 15 as to why an investigation was being made of PORV 16 leakage before the accident?
17 A
I did not realize that an investigation 12 was being made before the accident.
19 Q
I am saying the investigation made after 20 the accident that you participated in, did you ever 21 come to have an understanding as to why that ggg 22 investigation into PORV leakage that had occurred 23 before the accident was being made?
(~'T 24 A
I know of one reason in particular.
%-)
25 There may have been a number of other reasons.
1 Billingsley 96
't
(,)
2 My understanding of why this particular 3
investigation was being run at the time was in 4
response to an NRC finding which may have resulted in k
5 a finding which addressed leakage of a valve.
6 Q
Let me refer you to TDR-126.
(
7 A
Yes.
8 Q
Which you are an originator.
9 Will you look at the front page and at 10 the abstract which appears beneath your signature 11 along with the signatures of the other originators 12 and the approval signatures.
b)'
13 It begins with a "Brief statement of q,
14 problem."
15 Then there in'a three paragraph statement.
16 The first paragraph speaks about the emergency l
l 17 procedure for pressurizer system failure and what it l
18 required.
The second paragraph states that prior 19 to the accident the thermocouples on the PORV 20 discharge piping were indicating temperatures ranging 21 between 165 degrees Fahrenheit and 200 degrees g
22 Fahrenheit.
And the third paragraph says "As a 23 consequence of this situation, an investigation and 24 analyses were performed to determine the causes of 25 the high tailpipe temperatures and to assess the
1 Billingsley 97
(.
x_
2 possibility of those temperatures being the result of 3
leakage through the PORV."
4 Does that accurately state your understanding 9
5 of the purpose of the investigation?
6 A
No.
7 Q
Did you read this at the time?
8 A
Yes.
9 Q
Did you tell anybody, Mr. Capodanno, 10 Mr. Rochino, Mr. Maheshwari or Mr. Sheu, the other 11 originators, that you disagreed with the statement 12 of the problem as presented there?
t'h
(_)
13 A
I do not disagree with the statement of 14 the problem.
I believe I was asked why was this 15 investigation started.
16 Q
I asked, I believe, whether you ever 17 came to learn what the purpose of the investigation l
18 was.
19 A
Yes.
And 'I am not so sure that these 20 three paragraphs state that.
l l
ll) 21 MR. GLASSMAN:
I should note that the 22 witness was asked this question before and did l
j 23 answer with regard to the reason as he
[~h 24 understood it for the work being done.
So I
'\\.)
25 am not sure what else we are getting at here.
1 Billingsley 98
,a(_j 2
MR. WISE:
I am just trying to lay a 3
foundation because you presented an objection 4
earlier to my question.
I am trying to h
5 determine what his understanding of what he 6
was doing was.
7 MR. GLASSMAN:
Is there a question pending 8
now?
9 MR. WISE:
Well, there was until you 10 made an obj ection, but I will pose another one.
11 Q
You indicate that you believe that the 12 statement of the problem on the front page of
('hl 13 TDR-126 which is B&W Exhibit 428 was inaccurate.
(,j 14 ME. GLASSMAN:
I should say that that was 15 not the witness' testimony.
He said that it 16 did not reflect his understanding in full of 17 the reasons for the investigation.
I think 18 the question was something different from a 19 statement of the problem.
The question of 20 counsel in which the witness answered related 21 to his understanding of why the work was done.
22 MR. WISE:
Let's stop and make sure we 23 have it right.
Let's have the witness'
/~]
24 answer repeaced, please.
\\_/
25 (Record read by the reporter.)
1 Billingsley 99
.rm
_)
2 MR. WISE:
After referring to the 3
questions and answers it appears that the witness 4
answered my question whether the brief statement h
5 of the problem that appears on the abstract on 6
the front page of TDR-126 accurately stated 7
his understanding of the purpose of the 8
investigation and he stated that it did not.
9 Q
My question now is, regardless of what 10 understanding you may have had prior to the 11 preparation and publication of TDR-126, did you come 12 to understand after reading TDR-126 of which you are
/~
(_)T 13 an originator, that the statement of the problem 14 presented in the abstract constituted the purpose 15 for the investigation?
16 MR. GLASSMAN:
The question is directed 17 to whether or not his understanding of the 18 purpose of the investigation changed as a 19 result of reading this report?
20 MR. WISE:
I think the question was 21 clear the way it was phrased.
g 22 MR. GLASSMAN:
I am 23 MR. WISE:
I will stand on the question
("]
24 the way it is.
%_.J 25 MR. GLASSMAN:
The witness may answer
1 Dillingaloy 100
/7()
2 insofar as he understands it.
3 THE WITNESS:
Could you repeat that 4
question, please?
lh 5
(Question read by the reporter.)
4 6
A As I understood it then?
7 Q
Yes.
8 A
And as I understand it now.
This statement 9
of the problem was presented in an NRC audit finding 10 and that is the intended purpose as I understood 11 it then and understand it now, that is the purpose 12 for which this report was intended to address, that
()
13 audit finding given to us by the NRC.
14 Q
What had the NRC found in your understanding?
15 What audit finding are you talking about?
16 A
I don't know if that is referenced here.
17 It was a letter from a Mr. Stello to GPU and if 18 it is referenced here, I will tell you exactly what 19 the title was and what the date was.
20 Unfortunately, I do not see it referenced 21 here.
22 Q
There is a list of references in the 23 exhibit.
24 A
I had sure hoped so, but there doesn't g-
%)
25 appear to be.
1 Billingsley 101 (D
(,j 2
Q Let me refer you to page 886 I am 3
sorry, that is part of the appendix, not part that 4
won't help you.
5 Let me refer you to page 871.
Do you 6
see there part 7 entitled " References"?
7 A
Yes.
8 Q
There are seven references listed there.
9 Do you see that?
10 A
Yes.
11 Q
Do you see any letter from the NRC there?
12 A
None of those references are here.
I
/ \\
(
)
13 mean the reference that I am looking for is not here.
x_s 14 Q
So the reference that you believe was l
15 th e purpose of the report is not mentioned in it?
16 A
No, it isn't.
17 Q
From your recollection can you tell us 18 what part of that letter from the NRC was the cause l
19 of this work?
What had the NRC said that caused you 20 and the others here to do this work?
21 MR. GLASSMAN:
You want the wi tness '
ggg 22 recollection of what was said where I assure l
l 23 as we all sit here we know there is probably i
24 a more accurate source of information as to
,gV l
25 what the NRC said.
A document has been provided 1
1 Billingsley 102
(},)
p' 2
in this litigation.
3 MR. WISE:
I will take his recollection 4
at'this point.
lh 5
THE WITNESS:
Okay.
6 A
That document stated that the PORV 7
required closure upon tailpipe temperature reading 8
130 degrees.
9 Q
That's essentially what the first 10 paragraph on the abstract says, isn't it?
11 A,
Yes, yes, that is.
12 Also that NRC letter I believe stated O(_j\\
13 that there was leakage on the FORV prior to March 28, 14 1979 and that's what I recall.
15 Q
So what was the purpose of doing an 16 investigation to address that?
17 A
The purpose --
18 Q
Were you trying to show something?
19 A
We were trying to show that in fact the 20 valve was not leaking prior to the accident of 21 March 28, 1979.
9 22 Q
Isn't it true that one of the prime things 23 that was looked at in order to make that determination
(~}
24 was the history of the thermocouple temperatures v'
25 before the accident?
1 Billingsley 103
/i
(_)
2 A
That's correct.
3 Q
In order to understand those thermocouple 4
readings was it not necessary to make some investigation k
5 of where they were located?
6 A
That is correct.
7 Q
Wasn't it also necessary to determine 8
what thermocouples existed?
9 A
Are you asking me how I would investigate 10 this or how in fact it was investigated?
11 Q
No.
I guess I am asking how it was in 12 fact investigated.
I am curious as to how an
( )\\
13 investigation was made if no one ever determined what 14 therm 6 couples existed.
15 MR. GLASSMAN:
I will just object to 16 the statement in counsel's question.
The same 17 objection I made before.
There has been no 18 testimony that such a determination was not 19 made.
If it turns out that this particular 20 witness does or does not know about that 21 material that does not mean that others knew 9
22 or did not know of other material relating to the 23 question.
I highly object to the inference in 24 the question that if this witness did not
{']j' t
25 become aware of a particular bit of input that
1 Billingsley 104 2
therefore the investigation did not occur or
(_j 3
that the information was not available.
4 MR. WISE:
That's fair enough, lh 5
Mr. Glassman, but as you may know during the 6
course of these depositions we have had a 7
great deal of difficulty at various points with 8
some witness es who seem to have a very narrow 9
interpretation of what is within their knowledge 10 and I certainly believe and it is our position 11 that we are entitled to ask questions and 12 obtain answers from witnesses with respect to (s) 13 any source of knowledge that they may have
- (
14 including sources such as matters that they 15 have read or have been told by others that 16 might not be admissible because of the hearsay i
17 rule or some other objection in a regular 1
18 trial.
i l
19 Unfortunately it's been our impression 20 during some of the examinations that have taken 21 place that witness es have been under a misimpression 22 perhaps that information that they may have 23 learned during an investigation from others 1
24 or things they may have heard or read, they 25 are not required to disclose in response to l
l l
t
1 Billingsley 105 r^s
(_)
2 questions concerning knowledge or information.
3 The purpose for my series of questions 4
here are trying to lay a foundation to establish I
5 whe,ther Mr. Billingsley personally performed 6
the investigations or not, whether he was in 7
a position to know and understand what the 8
investigation was about and what others were 9
doing and to make sure that he understands that 10 I am looking for any knowledge that he may have 11 gained even if he did not personally perform 12 the analyses and calculations that led to the
/m
(
)
13 report.
14 I think that I am entitled to find out 15 if he heard about what was being done and that's 16 the purpose of this whole line of questions.
I 17 find it somewhat hard to believe that if he 18 was involved in this investigation in any way 19 at all that he was not aware in some respect 20 that an investigation was being made of the 1
21 location, number and operability of the various 22 thermocouples.
It's a key to the investigation 23 and it's mentioned throughout TDR-126 and 24 during some of my earlier questioning I had g-)g
\\.
25 the impression that he was saying that because l
w--
-a-
1 Billingolcy 106 (m) 2 he didn't personally go do that work that he 3
had no knowledge with respect to them, 4
That's the reason for the line of llh 5
questions.
I am prepared to proceed, but since you have objected and raised 6
that's 7
the question as to why we have gone on about 8
- this, that's the reason for it.
9 MR. GLASSMAN:
As you have just stated 10 it, you may of course question Mr. Billingsley 11 and I have not and will not interfere.
12 However, I find it necessary to take fm
(
)
13 offense with regard to some of the comments v
- 14 that counsel has just made on the record.
15 First of all, the absolutely unwarranted 16 implication that there is any restrictive 17 reading of the word " knowledge" or any intent i
1 18 in that record on this witness or any other 19 witness.
There is no evidence of that and it 20 is quite possible that what counsel is referring i
21 to is a narrow reading of such words which has 1
22 unfortunately been taken by B&W witnesses in 23 this case.
I take offense at that kind of a 24 comment here.
It is especially out of place.
g, l
(_/
25 In terms of counsel's additional comments
I 1
Billingaloy 107 m
(_,)
2 about his difficulty in believing what a 3
witness does or does not know, that is also 4
obj ectionable.
I 5
The witness is here and has sworn to 6
tell the truth and to the best of my knowledge, 7
and certainly I would think to yours as well, 8
there is nothing to the contrary.
9 The witness is trying to give his testimony 10 as best he possibly can.
There is no support 11 for a statement that counsel find it hard to 12 believe that a witness worked on one aspect
()
13 of a project and not on another.
In the 14 engineering world that frequently h'appens, but 15 you may proceed with the questioning.
16 MR. WISE:
I think we have both stated 17 our positions.
18 BY MR. WISE:
19 Q
Let me ask you this, Mr. Billingsley, 20 just exactly what did you do with respect to the 21 PORV leakage investigation?
22 A
I was initially asked to get data on, I 23 believe, the reactor coolant system leakage tests 24 that were run at some frequency prior to the accident.
e-]
\\_/'
25 I was able to get that data from Three Mile Island
1 Billingoloy 108
,es()
2 either the document control center, had that forwarded 3
up to Parsippany, 4
I believe I also plotted some of that llh 5
data, then turned it over to either Wallace or someone 6
working for Capodanno.
7 I also, during the time frame of Jim 8
Stubbs' reports, I was also requested by Mr. Ed 9
Wallace at various times to contact Mr. Stubbs, to 10 see how he was progressing on his various reports.
11 I was also requested to obtain certain data that 12 Jim Stubbs may have and to have that information fD 13 and data forwarded to Parsippany for review.
\\_)
14 In essence, when certain data was 15 requested and I may have had knowledge on who may 16 have been working in a certain area or were to 17 obtain knowledge, I would gather that.
18 The primary reason I saw my role being 19 the role that it was was because I had spent a 20 substantial amount of time at Three Mile Island 21 whereas none of the parties, to the best of my 22 knowledge, except for maybe Capodanno and maybe 23 Don Croneberger, none of these individuals had spent 24 any real length of time on the island to become s
's_)
25 familiar with either personnel or the location of i
l
1 Billingsley 109 O..
(
)
2 data.
%./
3 Q
You mentioned as one --
4 MR. GLASSMAN:
Just a moment.
llh 5
(counsel conferring with the witness off 6
the record.)
7 Q
You mentioned that one of the activities 8
was to check on the reactor coolant drain tank levels?
9 A
heactor coolant system leakage.
10 I may have becone involved with the drain 11 tank levels but I really cannot recall.
I think the 12 reason for that is those data sheets that I collected f~s) 13 had various types of data on it, t\\_/
14 Q
What data was relevant to the reactor l
15 coolant system leakage investigation you were making?
l 16 A
They ran -- the operators ran what I 17 believe was called a leak rate test at some frequency 18 and I remember that it was run often only because 19 of the piles of paper that I had received from 20 Three Mile Island.
It was quite a stack.
21 Q
Was that the primary source of data for 22 your work?
23 copies of the leak rate tests run by l
24 the operators?
fg I
'% )
25 A
Yes.
1 Billingsley 110
,(,)
2 Q
Were there any other sources of data 3
that you used?
4 A
Jim Stubbs.
lh 5
Q You mentioned that you obtained data from 6
Mr. Stubbs.
What kind of data did you obtain from him?
7 A
I believe I received some plots that he 8
had made on tailpipe temperatures.
9 Q
Where had he obtained that data?
10 A
He got those off stripchart recorders.
11 Q
Did you ever see the stripchart recorders?
12 A
No.
[ ')
13 Q
Did you ever see the actual data that he 14 prepared the plots from?
15 A
I may have seen the tapes in their 16 rolled up form, they are rolled up and that's it.
17 (Indicating.)
I never opened them or reviewed them to 18 analyze them.
l 19 Q
What happened to them?
20 A
To the stripchart?
21 Q
Yes.
22 A
I believe those remained at the island.
23 They were very strict about taking original data away
(~
24 from its location for fear of things being lost and N_,
25 never returned.
4 1
BillingolCy 111
)
2 I know you didn't ask this question but 3
I would like to add, as I got data that stuff left my 4
hands quick, okay?
llh 5
g You performed no analyses or calculations 6
with respect to it?
7 A
No.
Like I said, the only thing I can 8
recall doing is some graphs.
There may have been 9
graphs of leakage data, but I can't recall for sure.
10 Q
You mentioned that part of your activities 11 included pursuing a request by Mr. Wallace.
I have 12 forgotten the word you use, liaison or monitor
[ ')
13 Mr. Stubbs; is that right?
%/
14 A
I don't believe I used the word monitor, 15 but I contacted Mr. Stubbs at various times to see 16 how he was do'ing with his work.
17 Q
what was your understanding of what it 18 was he was doing?
19 A
My understanding was that he was taking 20 a look at cailpipe temperatures.
He was also taking 21 a look at leakage through the pressurizer relief 22 valves.
\\
xi P3 Q
Aside from collecting data from Mr. Stubbs, 24 which may have related to the tailpipe temperatures,
-.yb 25 did you yourself ever undertake any activities with
+
s
1 Billings 1Gy 112
,~;v) 2 respect to tailpipe temperatures as they existed 3
before the accident?
4 A
The only look I had with respect to tailpipe lll 5
temperatures was with respect to taking a look 6
at historical problems with respect to,the PORV.
7 Q
That was in connection with your work on 8
TDR-1607 9
A Correct.
10 Q
With respect to TDR-126 which was on the 11 leakage before the accident, you are listed as an 12 originator.
(V~)
13 Was there any part of this report that 14 you actually wrote or contributed?
15 A
No.
I did not write any part of this 16 report.
17 Q
Did you review it before it was published?
18 A
Yes, I did.
\\
l 19 Q
What was the purpose of your review, just 20 informatio.ul or did you have some input to the 21 report?
l 22 MR. GLASSMAN:
As Mr. Billingsley 23 understood it.
l 24 A
I had input to this report and for that
(
)
25 reason I reviewed it.
l i
r
1 Dillingolcy 113 n
(
)
2 Q
What parts of it did you contribute or 3
have input on?
4 You will note that most of the second llh 5
half of the report is actually Mr. Stubbs' report.
6 A
Yes.
7 Q
I take it you did not contribute to 8
Mr. Stubbs' report which is Appendix A?
9 A
No, I did not contribute to his report.
10 Q
So you had no contribution to Appendix A t
11 to the report?
12 A
The only contribution I would have had
()
13 to this would have been some raw data and exactly V
14 where this raw data shows up I can't say exactly 15 because I can't remember all the raw data that I 16 presented.
I tried to give you to the best of my 17 knowledge that raw data which I gathered.
I can 18 only say that it was probably used and in what l
19 context, I don't know at this point in time.
20 Q
Would you look at the first page of the 21 report?
l dBt 22 A
Yes.
23 Q
You will see a section labeled Roman 24 numeral II Summary of Key Results and it completes p-N~,I 25 the bottom of the first page and carries over through
1 Billingsicy 114 p) 2 the second page and then there is a third section (v
3 labeled Roman number III Conclusions that appears on 4
the third page of the abstract, page 857 marked for llh 5
purposes of the litigation.
6 Did you have any input to either Roman 7
numeral II or Roman numeral III, the summary of 8
results and conclusions?
9 MR. GLASSMAN:
Is the question whether 10 Mr. Billingsley had any input to the writing of 11 this particular material on these pages or whether 12 he supplied some input which had some relationship
,,)
13 to these, this summary?
(
's_/
14 MR. WISE:
No.
15 Q
No, I mean did you have any contribution 16 to the writing, the drafting, the redrafting, the 17 editing, et cetera, of what appears on these two or 18 three pages?
19 A
No, I did not.
20 Q
Did you personally have any basis for 21 agreeing or disagreeing with the conclusions stated 22 on the third page of the abstract?
23 To put it another way, are these your 24 conclusions or someone else 's conclusions that you
,-U 25 simply read?
1 Billingoloy 115
('x.
()
2 A
These are someone else's conclusions.
3 Q
You personally didn't reach any conclusions 4
and attempt to have them put into this report?
llh 5
MR. GLASSMAN:
You may read the conclusions.
I am sure I had -- I had ideas on 6
A I
7 this subject but I can't say that those ideas as 8
written there are mine.
9 Q
To the best of your knowledge whose 10 work is this, this summary of key results and the 11 conclusions, if it is not yours?
12 A
This work is primarily --- and the only
(
13 reason I know that is because I saw the guy when 14 he was writing -- is the second originator on here.
(
15 You are much better pronouncing that than me.
l 16 Q
Maheshwari?
l 17 A
Yes.
l l
18 Q
Did you ever have any discussion with 19 any of the other originators abo'ut the results of 20 the inves tigation or the conclusions as reflected in 21 the abstract?
22 A
Yes, I did.
23 Q
Who did you discuss them with?
24 A
Ed Wallace.
g3 (j
25 Q
Which parts of the results and conclusions
1 Billingsley 116
(_)
2 did you discuss with him?
3 A
I can't recall the exact sections of this 4
report I discussed with him.
llk 5
Q Did you discuss the results?
6 A
No, not per se.
7 Q
Did you discuss the conclusions then?
8 A
No, not per se.
9 Q
What did you discuss with Mr.
10 A
I knew that was coming.
11 Q
-- Wallace?
12 A
I told Ed Wallace that I felt that we r~'y
(_)
13 needed a little more detail in the report.
I felt 14 that we needed more detail.
15 Q
What led you to that feeling?
Were you 16 aware of additional data that had not been reflected 17 here for instance?
18 A
No, it's from a reviewer's point of view, 19 from this reviewer's point of view, myself, I felt 20 it was difficult to go from A to Z in the report 21 because I wasn't able to sit there and plug and 22 chug and get the same numbers they got because it 23 was difficult for me to do that.
24 Q
Had you attempted to do that?
(~~;)
Q, 25 A
In the time frame in this report it was
1 Billingsley 117
/T
(_)
2 not possible for me to do that.
3 MR. GLASSMAN:
Can we have a break for 4
a second?
h 5
MR. WISE:
Sure.
6 (Recess takan.)
7 BY MR. WISE:
8 Q
Continuing with respect to B&W Exhibit 9
428 which is a copy of TDR-126, will you look at 10 page 3 of the report.
It is marked 861 for litigation 11 purposes.
12 At the top of the page there is a sentence f~s
()
13 "The following summarizes the thermocouples and their 14 location and recording."
Then there is a chart 15 beneath that which has three columns, the first column 16 gives the thermocouple tag number, the second column 17 lists the temperature that was monitored by that 18 particular thermocouple and the third column is a l
l 19 list of the place where the output of the thermocouple 20 is sent.
l 21 Do you see that chart?
l l
22 A
Yes.
23 Q
Do you recall seeing it when you read this g"3 24 report?
t I
wi 25 A
I don't vividly recall all of what I l
1 Billingsley 118
/ ~
t s
(_,/
2 saw in this report as I look at it today but I 3
reviewed the report, it is there, it was there at the 4
time I reviewed it.
lh 5
You are talking about a report now that is 6
a year and a half, two years old.
7 Q
Did you have any understanding of what 8
is shown on this chart?
9 A
Yes, at that' time I did.
10 Q
Is it correct that the chart shows six 11 thermocouples that are hooked up to the multipoint 12 recorder and three thermocouples that are hooked up
(_,/
13 to the plant computer?
14 MR. GLASSMAN:
You are asking for the 15 witness' current interpretation of this 16 document?
l 17 MR. WISE:
No, I would like to know what l
18 he understood back at the time.
19 A
I don't know that because I don't see that 20 written here.
I do not see what is hooked up to 21 what.
Let me go not on this page.
22 Q
I don't want you to try to interpret the 23 document today.
That won't get us anywhere.
l
(']
24 All I am trying to determine, Mr. Billingsley, LJ 25 is whether sitting here today you are able to recall
1 Billingsley 119 m
2 whether during the course of the various investigations 3
you made, including whatever work you did on this 4
report and whatever reviev you made of it --
h 5
A Yes.
6 Q
-- you came to have any understanding 7
of the two systems of thermocouples that were hooked 8
up to the discharge pipes behind the pressurizer 9
relief valves and whether this chart which appears 10 here in a report which you reviewed at the time 11 helps to refresh your recollection as to what you 12 understood those systems to be and how they were 13 hooked up?
14 A
No, looking at this chart does not refresh 15 my memory to that fact.
16 Q
You have testified that you did not 17 participate in the drafting or editing of the summary 18 of results and conclusions that appear in TDR-126, 19 Let me just ask you this:
One of the 20 conclusions thkt is in this TDR is that the PORV 21 was not leaking prior to March 28, 1979.
.O 22 Did you perform any investigation, 23 calculations or analyses that led you to form an
~N 24 opinion one way or the other as to whether or not (b
25 the PORV was leaking prior to March 28, 19797
1 Billingsley 120
/~~
(_,s) 2 A
Yes, I had an opinion.
3 Q
What was your opinion based on?
4 A
My opinion was based on some data I had lll 5
seen during some of my investigative work and also 6
upon this report (indicating).
7 Q
Let's put aside this report for a moment 8
since you did not participate in its drafting or 9
editing and concentrate just on that data that you 10 had as a result of an investigation that you personally 11 made.
12 What data did you have upon which you
/^N t,)
13 based your conclusion?
14 A
My data that I had that I had discovered 15 on my own was not conclusive.
16 Q
So that based on your own personal 17 investigation you had not reached a conclusion one 18 way or the other?
19 A
That's correct.
Mine was very limited.
20 g
so the only conclusion you had is based 21 upon your reading of this report?
22 A
Correct.
23 Q
And you were not able to verify one way
/~N 24 or the other the numbers that Mr. Maheshwari relied
(_/
25 upon as you just testified?
4
1 Billingsley 121
(
(._)
2 A
That's correct.
3 Q
So basically all you know is what it says 4
here?
hk 5
A That's correct.
6 Q
Well, let's move on to something you do 7
know about.
8 Let me ask you a few questions about 9
Mr. Stubbs' memoranda, Exhibits 429 through 434 and 10 see if you can help with any of those.
11 Look first at Exhibit 429, if you would.
12 Exhibit 429 is Mr. Stubbs' cover memorandum of
(_)
13 March 28, 1980 to which his five reports were 14 attached.
15 If you would look at the sedond page of 16 the memorandum, it states in the second full 17 paragraph, "Certain data which was supposed to be 18 stored under the Unit 2 records management system 19 could not be found for review due to either being 20 misplaced, lost or destroyed."
21 Did you ever have any discussion with 22 Mr. Stubbs concerning his inability to find certain 23 data as referenced in this paragraph?
24 A
Not to the best of my knowledge.
(j^'s
\\.
25 Q
Did you personally ever become aware as
1 Billingsley 122
/8 2
a result of any investigation you made that data that 3
was. supposed to be stored under the records management 4
system had been misplaced, lost or destroyed?
h 5
A
.No.
6 Q
Let me ask you to look at B&W Exhibit 7
432 which is one of his backup reports, this one 8
dated February 13, 1980 concerning the RAD waste 9
disposal /RC leakage temperature multipoint recorder 10 operation.
11 I believe you testified you recalled 12 discussing this particular memorandum with Mr. Stubbs;
/
(_)
13 is that right?
14 A
Yes.
15 Q
What parts of it did you discuss with 16 him?
17 A
I can only speak about this report at 18 this time on a generic basis.
I did not address 19 this, on each specific area of this report.
20 Q
Do you remember generically what it 21 was you discussed with him?
22 A
Yes, generically we discussed the fact 23 that charts from the multipoint recorder were f')
24 difficult to read, at times I recall him saying it x_/
25 looks like the pins would cross, the colors of the
1 Billingsley 123 x_.)
2 pins woitid mix and as a consequence there were times 3
where it became difficult to distinguish between 4
- points, I
5 Q
Is that the best of your recollection of 6
the conversation?
7 A
Yes.
8 He mentioned also, I believe, event 9
markers on the charts.
That's all I can remember, 10 Q
What is an event marker?
11 A
7.n event marker is where someone marks the 12 start of the chart, they may date it and put a time p)
(_
13 on it to show when the chart starts.
They may also 14 mark it to indicate on, any number of things, but 15 typically it's where you put the paper in and you 16 date it when it starts and you might do that on a 17 daily basis or you might do that on an hourly basis 18 but the chart speed made it difficult to determine l
19 exactly when the chart was recording at any particular l
20 point in time.
21 Q
Whct did you and Ifr. Stubbs have to say 9
l 22 about that fact?
l 23 A
I listened to his comments.
I really
(^T 24 was not in a position to say much on the matter since
\\._)
25 I did not investigate that area.
l
1 Billingsley 124
(_)
2 Q
Did Mr. Stubbs tell you that the 3
multipoint recorder was out of operation during the 4
early morning of March 28, 19797 llh 5
A I don't recall him saying that.
6 Q
Would you look at page 7.0 of B&W Exhibit 7
4327 8
A Yes.
9 Q
It is in the section labeled " conclusions."
10 A
Yes.
11 MR. GLASSMAN:
What page is that?
12 THE WITNESS:
7.
O)
(
13 MR. WISE:
7.0.
14 Q
His conclusion is, th'e second sentence 15 in that opening paragraph reads, "Of significant 16 interest is the total lack of information available 17 from this instrument during the TMI Unit 2 accident 18 due to complete chart drive mechanism failure early 19 in the morning of March 28, 1979."
20 Do you recall at any point discussing the 21 statement in this sentence with Mr. Stubbs?
22 A
No.
23 Q
Did you ever make any investigation as
(-]
24 to whether the multipoint recorder was in operation V
25 on March 28, 19797
1 Billingsley 125 n.
2 A
Never.
3 Q
Did you ever learn of anyone else making 4
such an investigation?
j 5
A No.
6 Q
Do you have any knowledge or information 7
as to whether it was in operation on March 28, 1979?
8 A
Nothing other than this report.
9 C
D you have any knowledge or information 10 as to if it was not in operation why it was not on 11 the morning of March 28, 19797 12 A
No, I do not.
m 7
3
(_)
13 Q
In the course of your conversation with 14 Mr. Stubbs did you come to learn how the multipoint 15 recorder charted the data points?
In other words, 16 physically did you look at a sample copy of a chart 17 and come to learn how the points were recorded?
18 A
I don't recall that discussion, no.
19 Q
So you are not familiar enough to 20 testify today about how the charts were prepared and 21 vhat they showed?
- 9 22 A
No.
23 Q
Do you know who Mr. Stubbs was talking I~T 24 to about the multipoint recorder?
Who was he getting k) 25 his information from?
1 Billingsley 126
,r~N)
\\#
2 A
No, I don't know how he got his 3
i nf o rma tio n.
4 Q
Did you know of anyone at Met Ed who
'lll 5
was more familiar with the operation of that piece 6
of equipment than anyone else?
7 A
No.
8 Q
Let me ask you now to look at B&W Exhibit 9
433.
I recognize that you testified that you do not 10 recall having received or reviewed this particular 11 memorandum, but in any event, I would like to point 12 to several items in it and ask if they help refresh
(~'N k-13 your recollection concerning the subjects discussed 14 there.
15 On the second page of the exhibit there l
16 is a section entitled " Analysis of Test Data."
17 Do you see that?
i 1
18 A
Yes.
19 Q
This particular report is titled " Review 20 of RC Leakage Test Data Results Prior to March 28, 21 1979."
,9 22 You were, as part of your investigation, 23 I take it, looking at reactor coolant leakage?
I
(;
24 believe you testified earlier that that was one of 25 the areas that you did actually participate in.
1 Billingsley 127 p
2 A
Yes, that was not my investigation.
I 3
worked with a group of people who were investigating 4
but that was not my investigation.
lll 5
Yes, I did obtain that data for the group.
6 Q
That was the group that consisted of 7
the others listed as originators in TDR-126?
8 A
Correct.
9 Q
Referring again to the section of B&W 10 433 antitled " Analysis of Test Data" you will see 11 that there is a listing of five so-called problem 12 areas as identified by Mr. Stubbs.
,a 13 Do you see that?
14 A
Yes.
15 Q
Do you recall ever having any discussion 16 with anyone, Mr. Stubbs or anyone else, about these 17 problem areas as listed here?
18 A
'N o.
19 Q
Do you remember coming to learn at any 20 point about negative test results?
21 A
No.
g 22 Q
Missing information?
23 A
No, not to the best of my memory.
(m r
24 Q
The third item which is listed as program x
25
- dropout, did you ccme to learn about that?
1 Billingsley 128 kI 2
A No.
3 Q
The fourth item "RC Draintank level 4
decrease - level decreased without entry for tank
'llh 5
pumpdown."
6 A
No.
7 Q
And the final item he lists " Questionable data resulting in leakages not consistent 8
data 9
with RCS conditions or trends in prior leakrates."
10 A
No.
11 Q
Do you know what Mr. Stubbs' source was 12 for the information that appears here?
(..
13 A
No, I don't.
14 Q
Will you look at the next page in the 15 report.
16 There is reference in the next to the 17 last sentence to a " temporary change to the RCS 18 leakage procedure which compensates for the density 19 of the water in the RC drain tank."
20 As a result of any of your work on 21 the FORV leakage before the accident, did you come 4S 22 to know about the temporary change mentioned by 23 Mr. Stubbs here?
[V')
24 A
Where is that sentence in here?
I am 25
1 Billingsley 129 2
looking for that sentence here.
3 Q
All right, I am on page 3.
4 MR. GLASSMAN:
I would just note that jh 5
this just emphasizes what I have been withholding 6
as a continuing objection, that the witness has 7
said that he does not recall receiving this 8
particular document and we are now seeming to 9
be going through it and asking him questions on 10 it.
I think it would be appropriate if counsel 11 wishes to persist in this to be specific as 12 to the particular portion of the document and g
(
i 13 ask him first whether it refreshes the witness 14 regarding ever having seen the document.
15 otherwise we are really spinning our wheels.
16 MR. WISE:
I think I will just proceed 17 with this line and see if we get it over with.
18 Q
I am on page 3.
19 A
Right.
20 Q
You see the last sentence on that page 21 which begins "As can be seen"?
22 A
Yes.
23 Q
Looking at the sentence before that, and rx
(
)
24 the last portion of the sentence before that, you 25 will see that there is mention of a temporary change
1 Billingsley 130 g
2 to the RCS leakage procedure?
3 A
Ycs.
4 Q
Now, whether you learned about it from lll 5
this memorandum or from some other source during 6
the course of your investigation, did you ever become 7
aware of a procedure change, temporary change such as 8
that described by Mr. Stubbs in this memo?
9 A
No.
10 Q
Let me now ask you to look at B&W Exhibit 11 434.
That's Mr. Stubbs' report of March 17, 1980 12 entitled " Review of the Three Mile Island Unit 2
/~'s 13 Reactor Coolant Leakage Test Procedure."
14 I believe you testified earlier that you 15 did recall receiving this particular report?
16 A
Yes.
I did recall, yes.
I did, yes.
l 17 Q
Would you look at the first paragraph 18 of the report.
19 A
Yes.
20 Q
It begins "An examination was made of 21 Three Mile Island Unit 2 surveillance procedure 22 2301-3D1, RC system inventory, Revision 4 of January 14, 23 1980 to insure that it reflects the most accurate 24 indication of reactor coolant leak rate.
This 25 review was requested after analysis of leakage data
1 Billingsley 131 k-2 prior to the March 28, 1979 accident showed that 3
certain corrections necessary to reflect actual RCS 4
conditions had not been made."
lll 5
A Yes.
6 Q
Do,you have any knowledge as to who 7
requested Mr. Stubbs to examine the January 14, 1980 8
revision to the RC system inventory surveillance 9
procedure?
10 A
It comes to mind I remember Stubbs doing 11 this.
I don't recall who would have assigned him 12 this.
It's possible Ed Wallace was the person but p(_/
13 I can't recall positively.
14 Q
Do you recall who did the analysis of 15 leakage data prior to the March 28, 1979 accident i
16 which showed that certain corrections necessary to 17 reflect actual RCS conditions had not been made?
Is l
18
.that something Mr. Stubbs had done or something you 19 had done or someone else?
20 A
I don't know who would have done it.
l l
21 Q
You don't know what he is referring to 22 there?
23 A
No.
[ ))
24 Q
Did you ever make any analysis of the
'm 25 leakage data prior to March 28, 1979 which showed
a 1
Billingsley 132 v
2 that corrections were necessary in ord.er to reflect 3
the actual RCS conditions?
4 A
Never.
h 5
Q Did you ever have any discussion with 6
Mr. Stubbs concerning that finding that he reports?
7 A
I don't recall it.
O Q
Did you ever have any discussion with 9
him concerning any part of this memorandum recommending 10 changes?
11 A
No, I don't recall having any discussion 12 with him, b
13 Q
Let me show you some handwritten notes, 14 a handwritten memo dated July 25, 1979.
15 MR. WISE:
I will ask to have this 16 marked as B&W Exhibit 435.
j 17 (Handwritten memo dated July 25, 1979 18 marked B&W Exhibit 435 for identification, as 19 of this date.)
l i
20 Q
Exhibit 435 is a handwritten memorandum l
g from Q. Billingsley to R.L.
Long, subject, 21 22 "Electromatic Relief Valve Investigation," dated 23 July 25, 1979, 24 Mr. Billingsley, is Exhibit 435 in your 25 handwriting?
1 Billingsley 133
'~
2 A
Yes, it is.
3 Q
Did you write it?
4 A
Yes, I did.
h 5
Q Does this help refresh your recollection 6
as to when Mr. Long first asked you to begin work on 7
an investigation of the PORV?
I believe you testified 8
earlier it was towards the end of August 19797 9
A Yes.
10 Yes, this gives a much better picture 11 of when that work was begun.
12 Q
Sometime earlier?
p t
)
\\'
13 A
Yes.
14 Q
As early as July of 19797 l
l 15 A
Yes.
16 Q
You state at the opening of your memorandum l
?
17 "A review of information currently on hand is about l
l l
18 70 percent complete."
l 19 Is that correct?
l l
20 A
Yes.
l 21 Q
Do you know for how long you had been 22 working on this project before July 25, 1979?
23 A
No, I don't.
I
/~'s l (,j 24 Q
The next sentence says, "As expected, 25 however, infcrmation gathering has been slow.
During i
1 Billingsley 134 2
the week ending July 14, 1979 various parties were 3
contacted to expedite information flow which has 4
resulted in bringing the investigation closer to llk 5
answering some of the more basic questions of the 6
assigned task."
7 Does reading that help refresh your 8
recollection as to how long you had been working on 9
the investigation?
10 A
Not really because I gave you prior what 11 was my best recollection and obviously it's wrong.
12 Q
There is a reference here in your writing C'i
\\J 13 to the basic questions of the assigned task.
l l
14 Can you tell us what the basic questions 1
15 of the assigned task were?
j 16 A
Some of the basic questions were what 17 modification work had been done, if any, what kind of 18 repair work had been done, if any, whether or not 19 the valve failed open or closed, what kind of 20 incidents had happened at other locations, failure 21 modes and mechanisms.
Those are the more basic 22 questions.
23 Q
will you look at the second page of s
}
24 your handwritten memo, please?
25 A
Yes.
1 Billingsley 135
/~'s
/
2 Q
It reads " Progress had been made in the 3
following areas assigned in this task:
1.
4 Preliminary information indicates that TMI-2 had a 5
five to six gallon per minute primary system leak 8
for some period of time prior to the accident.
Some 7
plant operators feel the electromatic may have 5
been the reason."
9 What preliminary information did you have?
10 A
My memory at this time as far as that 11 is ne better than the paper I have in front of me, 12 so the only information I can say at this time was l'h, 2
13 probably discussions with plant operators.
14 Q
The sentence, the second sentence in 15 the paragraph concerning the feeling of some plant 16 operators that the electromatic relief valve 17 may have been the reason for the five to six gallon 18 per minute primary system leakage, did that come as 19 a result of your personal discussions with plant 20 operators?
21 A
I can't say for sure.
g 22 Q
Did you ever have discussions with plant 23 operators concerning the PORV?
("T 24 A
Yes.
- %,)'
25 Q
can you recall whether any of them ever
1 Billingsley 136 g
's 2
told you that they felt that the leakage before the 3
accident might have been through the PORV7 4
A No, I do not.
lh 5
Q You have no recollection today of w.-iting 6
that particular sentence?
7 A
Well, I know I wrote that.
8 I can't recall every sentence you write 9
in a period of a couple of years, but if it's there, 10 I wrote it, that's the only thing I can tell you.
11 Q
You don't have any recollection of why 12 the operators felt the way they did?
(~N
(_)
13 MR. GLASSMAN:
Objection.
14 There has been no direct testimony that l
15 the opera. tors said this.
Mr. Billingsley i
l 16 has indicated this is a note which is here 1
1 17 and that's all he recollects.
He doesn't 18 recall the source of the information, therefore l
19 there is an assumption in the question here 20 that assumes the truth of particular statements
'g 21 not in evidence.
l w
22 MR. WISE:
I disagree with you as to 1
l l
23 whether they are in evidence.
I think we can i (')
24 argue that at another time, but I think the N/
(
25 question is a fair one.
A statement is made 1
1 l
1 Billingsley 137
\\l 2
in a writing by an employee of a party.
It's 3
a direct statement which he has testified he 4
made in this writing.
h 5
My question now is whether he has any 6
recollection of anything that operators may 7
have said as to why they felt the electromatic 8
relief valve, which is the same as the PORV, 9
was responsible for the leakage that was occurring 10 before the accident.
11 MR. GLASSMAN:
I would just note that 12 counsel has said there was a direct statement
(~s
\\,_)
13 in this document.
There is a statement in the 14 document but the witness had just testified 15 several moments ago he did not recall actually l
l 16 discussing this with operators.
l 17 MR. WISE:
My question stands.
l 18 MR. GLASSMAN:
You may ask the follow up l
l 19 question and my obj'ection stands.
20 MR. WISE:
Yes.
l 21 MR. GLASSMAN:
Do you understand the 22 question?
23 THE WITNESS:
Now, after all of that, will
[~)
24 you repeat the question?
\\J 25 g
What, if anything, do you recall as to l
l
1 eillingsley 138 f
)
~'
2 why the operators felt that the electromatic 3
or PORV was responsible for the leakage that was 4
occurring before the accident?
lh 5
MR. GLASSMAN:
Objection.
That assumes 6
they felt this way.
It is not established.
7 A
I don't recall.
8 Q
Mr. Billingsley, I would like to show 9
you what we will have marked as B&W Exhibit 436 which 10 is a copy of some handwritten notes with a date of 11 July 12, 1979 at the upper right-hand corner.
12 (Handwritten notes dated July 12, 1979
[\\ ')
13 marked B&W Exhibit 436 for identification, as 14 of this date.)
15 Q
Do you recognize B&W Exhibit 436?
16 A
Yes, I do.
17 Q
Is that your handwriting?
18 A
Yes, it is.
l 19 Q
Do you recall what this document reflects?
20 A
Yes, this reflects my route to be taken 21 in investigating the electromatic relief valve l
22 at TMI.
23 Q
Does it outline the task that Mr. Long
/^\\
(J 24 had given you with respect to that task?
)
m 25 A
This is not an outline of the task as
n s?
I f
\\
1 Billingsley 139 1 -
s
\\
T
' N s3 2
given by him, but merely an outline of how I wanted s
s s'
3 to proceed withsfulfilling the task requirements, s
4 Q'
Roman numeral I at the top of the page lh 5
roads "The task."
Do you see that?
6 A
Yes.
1 i!
Q Listed beneath that are four subsections 8
labeled A, B,
C and D, and I believe section D in 9
-turn has five subsections to it and then at the end 10 there is a section E.
11 Do you see that?
12 A
Yes.
t' ')
\\_-
13 Q
what were you trying to present in 14 these various subsections?
What does this represent?
15 A
This represents where and how we should l
l'6 investigate the electromatic relief valve and what 17 route to take to do it.
18 Q
Would you look at the second page of your l {'
19 handwritten note?
20 A
Yes.
l d
t 21' Q
The item listed as 5 under section D.
l 22 A
Yes.
23 Q
D reads, "One thing should be kept in the x
I~T 24 back of our minds:
The valve may not have failed.
\\-)
25 It's quite possible that an accessory associated with 11,,
't A
1 Billingsley 140 g^s, 2
the valve may have been the failure mode."
3 What prompted you to write that?
4 A
Two things.
One is my past experience k
5 with equipment and the other is prior to the accident 6
I had begun working on a root cause analysis 7
system for GPU.
8 Q
What is that?
9 A
Root cause analysis is a systematic 10 way of approaching equipment and/or component 11 failures.
12 Q
What about that system led you to think
[^')
\\_/
13 that it might not be the valve itself but some 14 associated accessories that were to blame for the 15 failure?
16 A
The valve itself was not strictly 17 mechanical in nature.
There were also electrical 18 aspects to that valve.
l l
l 19 Q
You are talking about the way it was l
l 20 wired?
g 21 A
Yes.
22 Q
You have a point listed under item 5 as l
23 subparagraph b which reads, "At some point during the 1
(
28 accident the operators were able to stroke the valve."
25 What did you mean by " stroke the valve"?
l
1 Billingsley 141 (3
k-2 A
Move the valve up and down.
3 Q
What was the source of your information 4
for that statement?
lhI 5
A I cannot say because I do not recall.
6 That is strictly preliminary information.
7 Q
Do you recall whether you ever pursued 8
point 57 9
A I believe I did.
10 Q
What did you do?
11 A
I had spoken with various people who I 12 cannot recall on site concerning whether or not the
<~s k_)
13 valve was stroked.
There was some preliminary 14 opinions that it was.
Some of these facts weren't 15 cleared, not just this point, but other points t
16 weren't cleared until later on when various people 17 put together sequences of events when they actually l
18 went back and analyzed various aspects of the accident.
l 19 This may have been done by somebody else.
l 20 Q
Do you recall whether you were ever able 1
21 to clear it?
gg 22 A
No, I do not recall that.
l l
23
- 4 R. WISE
Let me have marked as B&W
/~
24 Exhibit 437 another set of handwritten notes N~.)h.
25 carrying the date in the upper right-hand
1 Billingsley 142
/~T i
K/
2 corner of August 22, 1979.
3 (Handwritten notes dated August 22, 1979 4
marked B&W Exhibit 437 for identification, as lll 5
of this date.)
6 Q
Are these notes in your 14andwriting?
7 A
Yes, they are.
8 Q
Were they part of your PORV history 9
investigation?
10 A
Yes, they were.
11 Q
The second page of your notes actually 12 carries the date August 23, 1979, one day later and
(%_/
13 is labeled " Design Data."
14 Do you see that?
15 A
Yes.
16 Q
It reads, "The electromatic relief valve 17 was QA inspected on 5-18-72."
18 "QA inspected" I take it means quality 19 assurance?
20 A
correct.
21 Q
It continues " Dresser purchase order S
22 number 022660LS and is a 2 1/2 inch valve, catalog 23 number 31533VX-30," and there is a description there.
(^)
24 Then the rest of it is rather hard to make out on
()
25 the copy that I have.
1 Dillingsley 143
\\
2
" Identification on the print RC-RV2."
3 I take it by print you are referring to the drawings?
4 A
Yes.
h 5
Q You continue, "It should be noted that 6
this valve was ordered by Jersey Central,"
7 Why was that something worthy of note?
8 A
It was worthy of note with respect to 9
locating documents and also was something that I 10 had learned so I recorded that information.
11 Q
When you say it was ordered by Jersey 12 Central, did you mean that they ordered that l '8 i,)
13 particular valve directly from Dresser?
14 A
I can't say who they ordered that valve 15 from.
16 Q
What did you mean when you said "this 17 valve was ordered by Jersey Central"?
Ordered from 18 whom?
19 A
I cannot say who it was ordered from.
20 I only know that it was ordered by Jersey Central.
21 Q
How did you come to know that?
gg 22 A
Probably by the print itself.
l 23 Q
Did you ever see the purchase order for 1
(~]
24 that particular valve?
V 25 A
Well --
s
1 Billingoloy 144 O)
(_
2 Q
You reference the number, the purchase 3
order.
You say it is Dresser purchase order number 4
022660LS.
Do you see that?
llh 5
A Yes.
6 Q
Had you obtained a copy of that particular 7
Purchase order?
8 A
If I did it would be in my report.
I 9
can't say unless I take a look at that report.
10 In some cases drawings have purchase 11 order numbers on it, by the way.
12 Q
The paragraph concludes "The numbers (3
()
13 used to identify the electromatic relief valves are,"
14 and then there is one number listed for Unit 2, another
~
15 for Unit 1 and one listed for the warehouse.
16 I take it that the one listed for the 17 warehouse was a spare?
18 A
Yes.
19 Q
That was ordered by whom?
20 A
I do: 't know, l
21 Q
Do you know when it was bought?
22 A
I don't recall.
23 Q
Do you know if it was bought by someone i
g-24 in the GPU system directly from Dresser?
(/
25 A
I don't recall.
1
1 Billingsley 145
/~T f\\~-)
2 Q
Do you recall whether it was supplied 3
by the NSS manufacturer, B&W7 4
A I don't recall.
I 5
Q
,You never looked into those matters?
6 A
No, not per se.
7 Q
How did you determine which particular 8
valves were associated with Unit 1,
Unit 2 and the 9
spare?
How did you link up the numbers of the valves 10 with the units?
11 A
That was a very difficult task, very 12 difficult.
The reason -- well, it was just a very CT
()
13 difficult task.
It has 8-23-78.
I can't say this 14 is the final word on those identification numbers.
15 Q
Were you ever able to reach a definitive 16 conclusion on which valve was actually on TMI-2 on l
17 the date of the accident?
18 A
Yes.
19 Q
How were you able to do that?
20 A
I had to go back and take a look at 21 dates when valves were shipped for repair work.
I g
22 had to take a look at dates on when valves were
(
23 placed on one unit to the next and on the basis of l
f~}
24 those >2tes I was able to make a final determination w/
25 of identilfcation numbers on the valves and what l
1 Billingsley 146 m
l
)
\\/
2 valve was where.
3 Q
Has anyone ever looked at the valve that 4
is now on TMI-1 to determine what its serial number I
5 is?
6 A
I vaguely remember that that was done.
7 Q
Was that reported to you?
8 A
When that was done, I was long since done 9
with my investigation.
10 Q
I guess that doesn't answer my question.
11 was it reported to you what had been 12 found?
(
(,'
13 A
I don't believe so.
14 Q
Did anybody ever look at the serial 15 number on the spare valve that was in the warehouse?
16 A
I don't recall.
17 Q
Do you know whether that has been done 18 as of today?
19 A
I don't know.
20 Q
So that your determination as to which 21 valve was on Unit 2 on the day of the accident is l
g 22 based solely on the paper trail; is that your testimony?
23 A
My conclusions are based on the paper
(~N 24 trail, yes.
i
)
\\/
25 Q
Do you know whether anybody else has
1 Billingsley 147 r
()
2 done any investigation besides you to determine 3
which valve it was that was on the pressurizer on 4
TMI-2 on the day of the accident?
I 5
A Not to the best of my knowledge.
6 MR. WISE:
Let me have marked as B&W 7
Exhibit 438 a collection of handwritten notes 8
of various dates, the top page bears a date 9
in the upper left-hand corner of August 28, 10 1977 but I don't believe that's the date of 11 the preparation of these notes.
12 THE WITNESS:
No, I don't think so.
(~h q_)
13 MR. WISE:
Some of the other notes in 14 the group bear dates in August and Sep'tember i
15 of 1979.
The exhibit consists of a total of 16 six pages of handwritten notes.
l 1
17 (Handwritten notes of various dates, 18 the first of which is dated August 28, 1977, 19 consisting of six pages, marked B&W Exhibit l
l 20 438 for identification, as of this date.)
21 Q
Mr. Billingsley, will you take a look g
22 at B&W 438 and tell us if these six pages are in 23 your handwriting?
(~T 24 A
Yes, they are.
()
25 Q
Are these notes that you made during
1 Billingoley 148 1
((~\\)
2 the course of your investigation of the PORV history?
3 A
Yes.
4 Q
The first page of the note is listed llh 5
" valve railures."
Three items are listed on the page.
6 One fo,r October 5, 1977, one for August 17, 1977 and 7
one for March 29, 1978.
8 What was your source of information for 9
the notations made there?
10 A
I believe these were problem reports.
11 Q
Did they include failures at both TMI-1 12 and TMI-27
(}
13 A
I believe this list was restricted to 14 TMI-2.
15 Q
Where did you obtain the problem reports 16 that served as the source for the information here?
17 A
I can't recall.
It could have been a 18 number of sources.
I can't recall exactly where.
19 Q
Will you look at the second page of the 20 notes.
This is on page titled " Summary of Failures" 21 and has the date at the right-hand side of the page 22 September 7, 1979.
23 Will you look at the item listed for 24 the date August 3, 1978.
\\, _/
25 Do you see that?
1 Billingolcy 149 l3 2
A Yes.
f l
3 Q
It reads " Modification made to setpoints,"
4 There is a parenthetical which is difficult to lh 5
make out.
I believe it is "(ECM9093): since HPI 6
setpoint is 1640 and reactor coolant low pressure 7
reactor trip setpoint is 1900 psig, it will be 8
advisable to have the reactor coolant pressure low alarm enunciator setpoint moved to 1700 9
low 10 psig because of the apparent advantage of reducing..."
11 It's very hard to read.
12 MR. WISE:
Off the record.
f~')
13 (Discussion off the record.)
V 14 Q
I am not sure what the next two words 15 are there, but then there are two words which are 16 difficult to make out on this copy, Mr. Billingsley, 17 and then it continues " emergency safeguards actuation, 18 additionally the low pressure computer alarm 19 presently set at,"
I believe it is "1900 psig."
20 A
I think that's 1700, but I can't tell l
21 either.
l 22 Q
All right.
23 Do you have any recollection as to what 24 that notation is all about?
LJ 25 MR. GLASSMAN:
You don't want him to
1 Dillingolcy 150
(}j t
2 try to speculate now but you want his 3
recollection?
4 MR. WISE:
That's what I asked for.
h 5
Q Do you have any recollection of what that 6
is all about?
7 A
No.
8 Q
You have no recollection as to why this 9
comment regarding HPI setpoints was included in 10 your summary of failures of the PORV?
11 A
Yes, I do.
12 Q
Can you tell us what your recollection is?
("T i
13 A
Part of my task was to identify any x_/
14 modifications that were made with respect to the 15 PORY and this particular modification was made in 16 consideration of PORV operation.
l 17 Q
Was this included in some sort of site 18 problem report?
19 A
I believe so.
20 Q
What is the reference ECM90937 21 A
Emergency change modification 9093.
1 22 Q
Is that the same thing as a problem 1
23 report or something different?
eg 24 A
It's different.
l 25 Q
What had prompted the emergency change i
l
1 Dillingaley 151
/"%
(,)
2 modification, as best you now recollect it?
3 A
As best I can remember -- I can't say 4
with complete certainty only because I only have llh 5
notes here and I don't know what was totally in 6
my mind at the time.
I would have to take a look 7
at my complete report to know how that tied in.
8' Q
We will be looking at the complete 9
report temorrow.
10 A
I ar sure I will, 11 Q
Perhaps we will put it aside until then.
12 Did you, in the course, however, of your
()
13 inve s tigation actually see the emergency change 14 modification 90937 15 A
I believe I did.
16 Q
Did you talk with anyone about it or 17 simply read --
18 A
I believe I talked to someone about that.
19 Q
Who did you talk with?
20 A
I can't say who.
I can say that I most 21 likely -- I most likely talked to either an engineer g
(
22 or an operator, but I can't say exactly who I spoke to.
l 23 Q
Was it someone at Met Ed?
24 A
I can't say.
l
\\_/
25 Q
Did you make any notes of your conversation
1 Dillingaloy 152
('h
- l 2
with whoever this was?
w-3 A
I may have.
4 Q-Do you know whether those notes were still llh 5
in existence as of the time that documents were 6
collected for purposes of this litigation?,
7 A
I turned over everything I had and if I 8
had notes they have been turned over.
9 Q
Is your testimony that you don't know 10 one way or the other whether or not those were in 11 existence or weren't?
12 A
I cannot testify as to whether or not
()
13 I wrote that particular fact down.
14 Q
will you look at the next page in your l
15 notes which is labeled "PORV Failures" and has the i
16 date at the right-hand side August 10, 1979.
There 17 is a list of three items on that page.
18 will you look at the one listed for 19 August 28, 1977.
It reads, " Block valve failed to 20 open using the motor.
Also tried to drive it back 21 without success.
Corrected the problem by increasing 22 the torque switch setting from one inch to one inch 23 and a quarter," it looks like or something like that.
well, it continues and it's very 24 "Found that" l
g3
,kr) l 25 difficult to read.
1 Dillingoloy 153 (v) 2 The only point is do you know for which 3
unit this note was made?
4 A
This was for Unit 2.
k 5
Q Did you have any talk with anyone 6
concerning what had occurred on August 28, 19777 7
A I may have.
8 Q
Do you recall who you talked with --
9 A
No.
10 Q
-- if you did?
11 A
No.
12 Q
Was there a site problem report or I
13 any documentation of this problem?
j LJ 14 A
I believe there was a report written.
15 I am not sure if it was a prablem report or not, but 16 I am sure there was a report written on this.
17 Q
Do you know what happened to that 18 report, whatever format it took?
l 19 A
This report should be included in my 20 report, TDR-160.
On the other hand, it may not ggg 21 have been because this is on the block valve.
I 22 Q
Do you know what, if anything, you did l
l 23 with the report?
l 24 A
If I have a copy of it, it should be in l
fy k_
l 25 my files.
i l
l
[
1 Billingsley 154 2
MR. WISE:
Let's break at this point 3
for the evening.
4 We will resume tomorrow.
5 (Time noted 5:07 o' clock P.M.)
6
-ooo-7 QUINCY BILLINGSLEY, III 8
9 Subscribed and sworn to before me 10 this day of 1982.
11 12 C
L~.h 13 14 15 16 17 18 19 20 h
22 23 94 A
25
1 155 bbb$kb1bb$b 3
STATE OF NEW YORK
)
- 'SS.:
4 COUNTY OF NEW YORK )
5 6
I, CHARLES SHAPIRO
,a 7
Notary Public within and for the State of New York, 8
do hereby certify that the foregoing deposition 9
of QUINCY BILLINGSLEY was taken before 10 Febnary 18, 1982 me on 11 That the said witness was duly sworn 12 before the commencement of his testimony and 13 that the Ulthin transcript is a true record of said 14 testimony;
~
15 That I am not connected by blood or 16 marriage with.any of the parties herein nor
- 17 interested directly or indirectly in the matter in 18 controversy, nor am I in the employ of any of the 19 counsel.
20 IN WITNESS WHEREOF, I have hereunto set g
my hand this day of fEfAbe(if 1982.
21 22 SDAA-6 CHARLES SHAPIRo,k.S.R.
g 2s
Fchrucry 18, 1982 156 INDEX O(_)
WITNESS PAGE Quincy Billingsley, III 3
g EXH IB ITS B&W 3XHIBITS FOR IDENT.
427 Resume of Quincy Billingsley 4
428 Copy of TDR-126 entitled 70
' Investigation of TMI-2 Pressurizer PORV Discharge Pipe Temperatures" 429 Memorandum dated March 28, 1980 80 from Mr. Stubbs to Mr. Wallace titled " Investigation of Three Mile Island Unit 2 Pressurizer Relief Valve Leakage Prior to March 28, 1979" 430 Memorandum dated March 17, 1980 81 from Mr. Stubbs to file, subject,
" Analysis of TMI-2 Plant Computer Data Pertaining to Pressurizer Relief Valves" 431 Memorandum dated February 22, 82 1980 from Mr. Stubbs to Mr. Wallace and distribution, subject, " Analysis of RAD Waste Disposal /RC Leakage Temperature Multipoint Recorder Data" 432 Memorandum dated February 15, 83 1980 from Mr. Stubbs to file, l
h subject, " RAD Waste Disposal /RC Leakage Temperature Multipoint Recorder Operation" 433 Copy of memorandum dated March 26, 83 1980 from Mr. Stubbs to file, subject, " Review of RC Leakage s)
Test Data Results Prior to March 28, 1979"
Fchrucry 18, 1982 157 EXHIB IT S B&W EXHIBITS (continued)
FOR IDENT.
434 Copy of memorandum dated 84 March 17, 1980 from Mr. Stubbs to Mr. Wallace, entitled " Review of the Three Mile Island Unit 2 Reactor Coolant Leakage Test Procedure" 435 Handwritten memo dated July 25, 132 1979 436 Handwritten notes dated July 12, 138 1979 437 Handwritten notes dated August 22, 142 1979 i
438 Handwritten notes of various 147 dates, the first of which is I
dated August 28, 1977, consisting of six pages t"%
! (-
i
-ooo-O
_~ ---
m
)
UNITED STATES DISTRICT COURT U
SOUTHERN DISTRICT OF NEW YORK
X GENERAL PUBLIC UTILITIES CORPORATION, JERSEY CENTRAL POWER & LIGHT COMPANY, METROPOLITAN EDISON COMPANY and 80 Civ. 1683 (RO)
PENNSYLVANIA ELECTRIC COMPANY, AFFIDAVIT Plaintiffs, against -
THE BABCOCK & WILCOX COMPANY and J.
RAY McDERMOTT & CO.,
INC.,
Defendants.
X STATE OF NEW JERSEY
)
[
COUNTYOFk(t\\h)
) ~
v I have read the transcript of my deposition taken on February 18, 19 and 25, 1982 and together with the attached corrections, it is accurate to the best of my knowledge and belief.
\\\\\\M \\\\
%~N
\\\\ T Quincy Billingslyy I
Signed and sworn to before me thisjd day of Octoh.., 1302.
e
?rfsW
.k f,.,&
, Notary Public h r-h hIlasc,'/'ss' h. ->
t
Corrections to Q. Billingsley Deposition October, 1982 Page Line Correction 39 15 delete " reading" I
43 18
" Product Test Group" should read " Productivity Group" 54 7
" manager in I believe" should read " manager in engineering.
I believe" 150 21, 25
" Emergency" should read
" Engineering" 151 13
" Emergency" should read
" Engineering" 192 22
" brochure" should read " pro-cedure" l
254 12 "I did personally not" should read "I did not personally"
(
270 16 "must print out," should read
" print out,"
l 286 15 "GPl" should read "HPI" 304 2, 10 "241" should read "2:41" 304 3, 10 "515" should read "5:15" 354 22 "a lever like level that came" should read "a lever that came" 359 6
" fuel" should read " flow" 362 10 "whether you be" should read "whether you would be" 371 11
" don't" should read "doesn',t" 391 23 "high pressure." should read "high pressure pumps."
O
--