ML20072H997
| ML20072H997 | |
| Person / Time | |
|---|---|
| Site: | Three Mile Island  |
| Issue date: | 02/19/1982 |
| 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 8306290859 | |
| Download: ML20072H997 (173) | |
Text
,
l sa 158
- g. UNITED STATES DISTRICT COURT q/ SOUTHERN DISTRICT OF NEW YORK
__________________________________________x GENERAL PUBLIC UTILITIES CORPORATION, :
' JERSEY CENTRAL POWER & LIGHT COMPANY, METROPOLITAN EDISON COMPANY and :
PENNSYLVANIA ELECTRIC COMPANY, a
Plaintiffs, i
-against- 80 CIV. 16
- (R.O.)
THE BABCOCK & WILCOX COMPANY and J. RAY McDERMOTT & CO., INC., :
Defendants. :
------------------------x Continued deposition of GENERAL
[
'~d PUBLIC UTILITIES CORPORATION, by QUINCY a
BILLINGSLEY, III, taken by Defendant, 1
pursuant to adjournment, at the offices of Davis, Polk & Wardwell, Esgs., One Chase Manhattan Plaza, New York, New York, on Friday, February 19, 1982, at 10:05 l
o' clock in the forenoon, before Catherine l
l 1
- Cook, a Shorthand Reporter and Notary Public within and for the State of New York.
i s, DOYLE REPORTING, INC.
pi CERTIFIED STENoTYPE REPORTERS
'N 369 LexlNGTON AVENUE WALTER SH APIRO, C.S.R. Nzw Yonst. N .Y. 10017 CH ARLES SH APIRO. C.S.R. TELEPHONE 212 - 867-8220 l 8306290859 830219 PDR ADOCK 05000289 T PDR
1 159 2 Appea ra nce s :
(~3
(_)
3 KAYE, SCHOLER, FIERMAN, HAYS & HANDLER, ESQS.
Attorneys for Plaintiff 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.,
p_
13 of Counsel i 1
'~ 14 15 Also Present:
16 NINA RUFFINI 17 _ooo.
18 19 QU I NC Y B I LL I N G S LEY , I I I ,
20 having been previously duly sworn by a 21 Notary Public, was examined and continued 22 to testify as follows:
23 EXAMINATION (continued) 24 BY MR. WISE:
O
( ,) 25 Q Mr. Billingsley, you understand you
Billingclay 160 1
are still under oath from yesterday?
~T 2 (d A Yes, I do und=rstand that.
3 4 MR. WISE: I would like to have marked 5 as B&W Exhibit 439 a set of notes from a file 6
that was produced to us by your counsel shortly 7
before this deposition began.
8 (Set of notes, the first page of which 9
is a copy of file jacket entitled "EMOV License 10 Submittal, 2-29-80" marked B&W Exhibit 439 for 11 identification, as of this dat e. )
12 Q At the top page of Exhibit 439 is a l
13 photocopy of the file jacket which I presume co ntairie d i
g3 b 14 the remainder of the notes in the exhibit. File l
15 jacket is labeled "EMOV License Submittal, 2-29-80."
l 16 EMOV is the same as the PORV; isn't it?
17 A Yes, it is.
18 Q Is this a file you maintained?
19 A Yes, it is.
20 Q What license submittal did this file .
21 refer to?
22 A You have to give me a few minutes to take 23 a look at this.
24 This is part of that submittal in
,a
(_)
6 4
25 response to an NRC audit finding. I believe the
Dillingsley 161 1
(( ,/ 2 response was made sometime in December to the NRC.
3 Q December 1979 or December 1980?
4 A I don't recall if it's '79 or '80. I I would have to see the document. I would have to 5
6 assume it was '80, but I would have to see that 7 document.
8 Q What is your best recollection as to 9 whether this file in any way related to the PORV 10 leakage investigation that was reflected in TDR-126 11 which we discussed yesterday?
12 A I believe this is directly related.
13 Q Were these papers part of that investigation?
(v) 14 A Yes.
15 Q I would like you to look at the back of 16 the exhibit first because it appears that the papers are placed in chronological order with the most 17 18 recent towards the top and the earliest toward the 19 back.
I 20 So beginning at the back of the exhibit, l
21 would you look at the page marked for litigation 22 purposes W23713 which is headed "PORV" and bears 17, 1980.
23 the date in the right-hand corner January gs 24 Page 713 I think is the first page of three pages 25 of notes that are the last three pages in the exhibit.
l
I 31111ngelay 162 2 Do you see the portion I am referring to?
v 3 A Yes.
4 Q Do you recall what these notes relate lll 5 to? Is this a meeting or some investigation you 6 were conducting?
7 A These pages were part of what I was 8 requested to obtain as far as data goes.
9 Q Who made these requests to you?
10 A These requests were made by Ed Wallace 11 and Don Croneberger, Additional requests may have 12 been made by other people but those stand paramount 13 in my mind.
t I
'~ #
14 Q Do you recall participating in some 15 reeting where these requests were passed on to you?
16 A I can't say these are meeting notes.
17 Q A portion of these three pages of notes 18 relate to insulation on the discharge pipe. leading 19 from the relief valves at the top of the pressurizer.
l 20 Is that right, on just brief review?
21 Have I correctly understood what these notes are 22 about?
23 , A I see one line that discusses insulation, 1
24 page 2713, the very last line.
A
(,,,I 25 Q The top line?
1 Billingoley 163
(~S 2 A The top line as well. Those are the
()
3 two places that I notice insulation is discussed.
4 Q Do you have any recollection -- before that let's look at the next page, 714. It starts lll 5 6 by saying "Stello says that conduction won't 7 support the temperatures we saw." Then there is 8 more information below that.
9 Mr. Stello was the gentleman from the 10 NRC?
11 A Correct.
12 Q Do you recall whether the material that 13 appears underneath that comment related to questions
)
14 of how well the discharge pipe was insulated?
15 A I can't say what the basis of Mr. Stello's 16 statement is.
17 Q would you look at the third page of the 18 notes, page 715. Could you read what you wrote there?
19 A "See Floyd or Sie'zlitz about insulation, 20 RCV3 spray valve, some insulation may have been .
21 removed, check control room and see pictures."
22 Q After looking at these three pages, isn't 23 it correct that these notes reflect consideration 24 being given by you to get informat. ion concerning
(~s\
~
25 insulation on the discharge pipes?
I 1 Billingsley 164
() 2 A That is -- well --
\~)
3 MR. GLASSMAN: Are you asking if these 4 notes refresh the witness' recollection as to lh 5 the entire document?
6 MR. WISE: Yes.
7 A I can say that this reflects insulation.
8 I cannot say this reflects insulation on the inlet 9 or the discharge. From what I have here, I cannot 10 tell.
11 Q Do you have any recollection of the work 12 that you did in connection with these notes, what 13 this is'all about, other than just looking at it g3 a
t
%)
14 today cold?
15 A Yes. This is all part of areas that 16 I was asked to try and obtain data for and information 17 for, all relating to TDR-126.
18 Q For instance , let's look at page 713, 19 the bottom note, " call Don Shovlin and find out 20 about insulation on code and electromatic." .
21 Do you see that?
22 A Yes.
23 Q The electromatic is the PORV?
24 A Right.
(O
(_,/ 25 Q Did you ever call Mr. Shovlin concerning
1 Billingoloy 165
()
2 that subject?
3 A I may have.
4 Q Do you have any reco11c: tion of doing so?
lh 5 A No, I do not.
6 0 D) you have any recollection of anything 7 you found out about insulation on the tailpipe leading 8 from the relief valves at the top of the pressurizer?
O A No, I don't recall any information about 10 what I found cut concerning insulation.
11 Q Do you recall whether you or the 12 individual who was responsible for gathering that
[~j 13 information and making some report with respect to L., '
14 it?
15 A I can say I was requested. I don't 16 know if anyone else was requested, but the final 17 information concerning insu?.ation was not obtained l
18 by me to the best of my knowledge.
19 Q Who did get it?
20 A I cannot say. I don't know.
21 Q Do these notes reflect your thinking 22 and work or are they simply to the best of your 23 recollection a transcription of what you were being 24 told by Mr. Wallace and others? For instance, look
' ~'
25 at page 714, the second page of your notes, comment C
1 Billingoloy 166 l
l makes a statement of some sort about tailpipe f 2
('^)
RJ _
j 3 temperatures and RCS pressure and so on.
4 Does that reflect work that you had done llI 5 in thinking that you had gone through or is that 6 simply a transcription of something someone was 7 telling you?
8 MR. GLASSMAN: Is the question directed 9 to item C?
10 MR. WISE: Let's take that as an 11 example and go beyond that.
12 A It's difficult for me to say. I have 13 a name written across "Stubbs." This may have been g3 N] information I was given and I wrote down. I cannot 14 15 say that this reflects my thinking nor my knowledge.
16 Q For instance, underneath this comment C 17 there is an item 1 which reads, "If we find that 18 at low pressure temperature is less than 170 degrees 19 Fahrenheit, must get data."
20 Is that something you thougnt or are you 21 simply reflecting something somebody else told yoin 22 there?
23 MR. GLASSMAN: You want the witness' 24 recollection?
! 4 K/ 25 MR. WISE: Yes.
I
I Billingolay 167 m
(v; 2 A I don't recall.
3 Q I guess what,I am trying to get at, 4 Mr. Billingsley, whether you were taking an active I 5 part in actually trying to make some determinations 6 and reach conclusions with respect to this investigation 7 or whether you were simply transcribing material 8 that others were giving you and chasing down 9 information for them?
10 A Yes, I think statement number 1 accurately 11 reflects what my role at this particular point was, 12 data gathering. There may have been, and I am sure
(i 13 there were, other people involved in data gathering v
14 as well.
15 Q Would you look at comment D which reads, 16 " Temperature Profile." The first item is, "Need
- 17 picture of pressurizer relief valve area that shows l
l 18 insulation."
i l 19 Was that something you were supposed 20 to do? .
21 A I cannot make a positive statement with 22 respect to that.
23 Q Do you know if you ever got a picture --
24 A I never saw a picture.of that area to
) 7- 3
~
25 the best of my knowledge, l
1 Billingoloy 168 l
t
(_/ 2 Q Second item, "Did TMI-2 ever do a 3 temperature profile of pressurizer area (top of 4 pressurizer)."
. .d 5 Was that something you were supposed to 6 find out?
7 A Yes, I believe so.
8 Q Did you?
9 A To the best of my memory I don't recall 10 ever finding that information out for TMI-2.
11 Q Third item, "Look at Unit 1 data 12 (temperature profile and insulation) ."
13 Was that something you were supposed to
()
14 do?
15 A I cannot say with certainty. No, I 16 don' t know.
17 Q Do you have any recollection as to why 18 you wrote that?
19 A This may have been something I was told.
20 There were a number of meetings that went on 21 concerning TDR-126 and what would be required to 22 be utilized in that evaluation and investigation. I 23 can't say that I in fact found that data. I can't 24 say that I was in fact solely responsible for
("]
G 25 locating that data.
l 1 Billingelsy 169
(\ ,/'s 2 Q Do you know whether anybody ever found 3 that data?
4 A I recall thec the temperature profile khk 5 was performed on Unit 1. I don't recall whether or 6 not I saw that particular data.
7 Q Who did the work?
8 A Someone in Unit 1. I don't recall the 9 name.
10 Q Do you recall anything about what that 11 profile showed?
12 A No.
r"3 13 Q Moving forward in your notes to the next U
14 preceding page which is 23712 it is marked 1-18-80 15 which is the day following the three pages of notes 16 we have just bcen discussing. The heading is "PORV 17 Responsibilities."
18 Do you see that?
19 A Yes.
20 Q There are six items listed underneath 6 21 that heading. This is in your handwriting, I take 22 i t?
23 A Yes.
24 Q In addition to several of the items that
,/7 i 1
25 we have just discussed that 'came from your January 17
Billingoloy 170 1
f) 2 notes, this January 18 memo has two additional O
3 notes E and F.
4 E reads, "Look at temperature detectors rings)
Ihk 5 inside containment around s/G shield wall ('D' 6 and see if a representative temperature can be 7 determined from the detectors for the pressurizer 8 and associated valves. "
9 Do you see that?
10 A yes, I do.
11 g Do you recall who asked you to do that?
12 A No, I do not.
13 Is that something you thought up on
(~'s Q N-]
14 your own or something somebody else asked you to?
15 A Someone must have asked me to do it.
16 Q Do you remember whether you did it?
17 A I don't believe I did this, no.
18 Q Do you know if anyone else did?
19 A I do not.
20 Q Item F, " Data on reactor coolant drain .
21 tank level and pressure from day 1."
22 What is your recollection of what that 23 comment meant?
24 A That was a request made to attain this
/ 25 data which I believe was from the data when the unit
1 Billingoley 171 2 first went into operation.
('~~' ) l
(,/
Q Is that something you thought up to do 3
4 or someone asked you to do?
lk 5 A someone asked me to do.
6 Q Did you ever perform that task?
7 A I believe I did.
8 Q What did you do with the data once you 9 had it?
10 A 1 had it transferred to Parsippany and 11 provided it to someone involved with the investigation.
12 Q You don't remember who?
13 A No, I don't.
+
rs \
n) 14 Q Would you look at the next two preceding 15 pages marked 23710 and '11. They constitute two 16 pages of handwritten notes, the first of which bears 17 the date of January 17, 1980.
18 Do you see that?
19 A Yes.
20 Q Were these handwritten notes that you 21 made during a meeting of some sort?
22 A I am not sure. These may have in fact 23 been meeting notes, but I am not sure.
24 Q Towards the bottom of the page there is
,r'y
\ _.) 25 a list of three items circled a,b and c.
I Billingolsy 172 T
t'^j
( 2 Do you see that?
3 A Yes.
4 Q Next to b which reads "TMI-2 ever do I 5 temperature profile at pressurizer area (top)," you 6 have written in the margin " Dave," it appears to 7 be S-1-e-a-r.
8 A Correct.
9 Q And Bill I-t-c-h-e-r.
10 Do you know who those people are?
11 A I know Dave Slear. I don't recall Bill 12 Itcher.
13 Q What did they have to do with these f',Nx) 14 notes?
15 A I can only say that there must be some 16 association between them and b, but I don't recall.
17 MR. GLASSMAN: I assume the question is 18 just his recollection, not for speculation?
I 19 MR. WISE: Just his recollection.
l 20 don't want his speculation.
21 Q Did you ever work with Mr. Slear in i 22 connection with the PORV leakage investigation?
l 23 A I don't recall working with Slear, 24 Q You don't recall asking him for any ess t \
l sj 25 information?
l l
Billingsisy 173 1
2 A No, I don't.
('\-j'<
3 Q Would you move forward now several pages to the page marked 23707. That's titled " Meeting on 4
5 PORV Investigation" and bears the date January 18, 6 1980. I believe your notes there consist of one 7 full page and it is unclear whether the following 8 page, 23708 is part of that or not.
9 Would you take a quick look at those 10 notes and see whether that helps to refresh your 11 recollection as to whether there was a meeting on 12 January 18, 1980 of a group connected with the PORV investigation?
( ') 13
'\J 14 A Yes, this reflects the PORV investigation.
15 Q Do you remember the meeting that these 16 notes refer to?
17 A No.
l 1
18 Q You don't remember who was at such a l 19 meeting?
20 A No, not on that day.
I 21 Q Did you remember a Mr. Jim Moore?
22 A Yes, I know Mr. Moore.
23 Q Do you remember having a meeting with 24 him sometime in January 1980 in connection with the
,o t \
'd 25 PORV investigation?
Billingsley 174 1
i,- - ) 2 A I don't recall if I met with him or not.
3 Q How about Mr. Rochino?
4 A I did attend a meeting with Mr. Rochino.
9 5 I recall one meeting.
6 Q Was Mr. Rochino working on the PORV 7 leakage investigation?
8 A Yes, he was.
9 Q You will note that item 4 of your notes 10 here reads, "Rochino says that at 115 degrees 11 Fahrenheit, thermocouple would be reading ambient."
12 Do you see that?
g (vj 13 A Yes.
14 Q Underneath the temperature 115 degrees 15 Fahrenheit someone has written " containment air 16 temperature."
17 Is that also in your handwriting?
18 A Yes.
19 Q Do you recall Mr. Rochino discussing the 20 containment air temperature and its relationship to 21 the thermocouple reading on the discharge line on g
22 the pressurizer relief valves?
23 A Yes, I believe we did discuss that.
24 Q The comment immediately above that says 3
[J
}
25 " Jim Moore also has information on TMI-1 temperature
Billingsley 175 1
,.m
( ) 2 profile."
V 3
Do you recall being told during that 4 meeting that Mr. Moore had the TMI-1 temperature lh 5 Profile?
6 A I don't recall that, no.
7 Q Comment 8 on this page reads "See 8 Julian," and then I can't make out what is written 9 there.
10 Could you spell it for us?
11 A I can spell you what is there.
12 A-b-r-i-m-o-i-e-i. I don't know if it's correct.
13 Q Who is that person?
/)
'% )
14 A I don't recall.
15 Q It says, "He plotted primary leak rate" 16 and was working with Jersey Central.
17 Do you recall ever going to see this 18 individual?
19 A No, I don't.
20 Q Do you recall anything about him at all 21 today?
22 A No, I don't.
23 Q Next comment which is labeled 9 reads,
" Compare piping arrangement of Unit 1 and Unit 2."
24
) Do you remember making that notation?
\' 25
1 Billingoley 176 2 A No, I don't remember making that.
^h (O Do you know whether you ever did perform 3 Q 4 a comparison of the piping arrangement?
lh 5 A I never did.
6 Q Do you know if anybody else did?
7 A No, I don't.
8 Q would you flip forward in the file now 9 to the page marked 23690. Unfortunately it's hard 10 to read, you might want to look at page '91 and 11 then the page before it because the stamp is
~
'90.
12 superimposed over some of the writing on page 13 On page '90 there is a memorandu; in 73 N/
14 handwriting from J. Stubbs to Q. Billingsley dated 15 January 23, 1980. The subject is RAD Waste 16 Disposal /RC Leakoff Temperature Recorder. Then there 17 is the letter and numeric designation for the 18 recorder and the memorandum consists of three pages 19 with a one-page chart attached which has been marked 20 23693 for litigation purposes. .
21 Do you recall receiving this memorandum 22 from Mr. Stubbs on or about January 23, 19807 23 A No, I don't recall receiving this, no.
24 Q Do you recall asking Mr. Stubbs for this
(.
(/' 25 information?
1 Billingolay 177
^') 2 A No.
[G You will note .the.beginning of his 3 Q 4 memorandum states "As requested in your letter to Ih 5 me dated 1/22/80, an investigation was made to 6 determine the validity of data recorded by the RAD 7 Waste Disposal /RC Leakoff Temp Recorder." Then it 8 goes on to state his conclusions.
9 Do you recall asking Mr. Stubbs by 10 letter to perform such an investigation?
11 A No, I don't recall.
p 12 Q Would you look at the third page in the
(N 13 exhibit which is marked 23680. You will see there L ,)
14 a handwritten note which begins "What is needed from 15 J. stubbs." There are two items listed below it.
16 The handwritten note is marked January 22, 1980. You 17 will note beneath the two items that are listed as 18 being needed for Mr. Stubbs, there is the comment 19 "gave Stubbs ink copy of this on 1-22-80."
20 Is that all in your handwriting?
21 A Yes, it is.
22 Q Does it help refresh your recollection 23 as to whether you made a request of Mr. stubbs on 24 January 22, 1980 for the information provided in
/,, i 1
\/ 25 his memo to you of January 23, 19807
Billingsley 178 1
Does it refresh my recollection? No.
2 A
[ )
G' 3 Q You have no rememberance of doing that?
4 A No.
I 5 Q Do you know why you asked Mr. Stubbs for 6 this information?
MR. GLASSMAN: Objection. If he has 7
8 no recollection of it -- I don't see how he 9
can answer something that he doesn't recollect 10 doing.
11 MR. WISE: If he has no recollection of 12 why he asked for the information, he can so 13 state.
(~]
't..J' I will allow him to 14 MR. GLASSMAN:
15 answer that.
16 MR. WISE: He may not remember asking 17 Mr. Stubbs for it. He may remember wanting 18 the information and why he wanted the 19 information. I don't think there is a 20 complete overlap.
21 A This information was requested by 22 Mr. Wallace and I complied with that request by 23 forwarding that on to Mr. S t' ~
Did Mr. Wallac ou why he wanted 24 Q O
t !
\/ 25 this information?
1 01111ngaley 179
) 2 A- I don't recall.
3 Q Would you 1cok again at Mr. stubbs' 4 January 23, 1980 memo to you and particularly to I 5 page 23692 which is the last page of the memorandum, 6 the next to the last paragraph he writes, "I have 7 attached a copy of the chart paper. This represents 8 a 'better than average' copy, the original being 9 a little easier to read. " Next paragraph, "Please 10 advise me of your intentions in analysing the 11 charts. I can be reached at ext. 8579 or 8482," and 12 signs his name, c',
13 Attached to this is a rather poor copy
( j 14 of what appears to be a chart from the multipoint 15 recorder, based upon my layman's judgment.
16 MR. GLASSMAN: Thank you, Mr. Wise.
17 Q Do you recall ever seeing a copy of the 18 multipoint recorder chart as attached to Mr. Stubbs' 19 memo?
20 A No, I do not.
21 Q Do you remember ever getting back to 22 Mr. stubbs to advise him of your intentions in 23 analyzing the charts?
24 A No, I do not.
l t
rS l i
's _/ You in fact made no analysis of the charts?
25 Q
{
1 Billingoloy 180
,y j 2 A Myself, no.
(
N/
3 Q Do you know if anyone else did?
4 A No, I do not.
h 5 Q Would you look at page 23686 again 6 moving forward in the file. Page 23686 begins a 7 chart which continues on to the next page, page '87, 8 of various parameters for a list of dates beginning 9 sometime in late March, 1978 and continuing through 10 June, 1978.
11 The chart purports to show columns 12 listing time, average temperature, pressurizer level
(~N s 13 and reactor coolant drain tank level.
N_J 14 Did you prepare this chart?
15 A No, I did not.
16 Q Do you know who did?
17 A I do not.
18 Q Do you know how it got in your file?
19 A I placed it there.
l 20 Q Do you know anything more than how it j
! 21 happened to get into your hands so it could get into
(
22 your file?
23 A Not on the basis of these charts.
24 Q You don't know where you obtained them
, f'\
h
\/ 25 from?
1 Billingolay 181
~
('a }' 2 A No, I do not.
3 Q You don't remember for w'aat purpose you 4 obtained them?
'llh 5 A No, I do not.
- 6. Q Would you look at the following page, 7 page 23688, there is a handwritten note there dated 8 January 22, 1979. It reads, " Spoke with Bill Fels 9 on 1-22-79 about reactor coolant drain tank level.
10 He says that no compensation was used to determine 11 level." The word "no" has been double underscored.
12 Do you recall a conversation with 13 Mr. Fels on or about January 22, 1979 concerning
(~~3 L.] 14 coolant drain tank level?
15 A I don't recall the date. I recall 16 discussing this with him.
17 Q Who is Mr. Fels?
18 A Mr. Fels is a computer engineer at Three 19 Mile Island.
l 20 Q Did he work for Met Ed or GPU?
21 A I don't know.
l 22 Q Why did you contact him on this subject?
23 A I don't recall.
24 Q Where did you get his name from?
7-.
k) - 25 A I knew Bill Fels prior to the investigation 1
1 Billingsley 182 l
g)
'N ,) 2 leading to the publication of TDR-126.
3 Q Did his job responsibilities or area of 4 expertise lead you to believe that he had information 5 that would be useful to you in the PORV leakage 6 investigation?
7 A Yes.
8 Q Why?
9 A Bill Fels was a computer engineer who 10 was involved with inputting various plant parameters 11 into the computer.
12 Q How would that relate to the PORV g
leakage investigation?
(_ 13 14 MR. GLASSMAN: You are asking him to 15 speculate now or his recollection?
16 MR. WISE: His recollection.
17 A I don't recall.
18 Q Do you remember Mr. Fels telling you 19 that no compensation was used during determining 20 of reactor coolant drain tank levels? .
21 A No, I don't recall that.
22 Q Do you know what you meant by " compensation" 23 in this note?
24 A No, I don't recall.
(')N Q
25 Q Let me make sure I understand. You are
1 Billingsley 183
~
drawing a total blank on this note. You don't
( 'N 2
_j 3 remember anything --
4 A Do you want me to speculate?
I I don't want you to speculate. I want 5 Q 6 to know if you have any rememberance of this 7 conversation that you had with Mr. Fels on the 8 subj ect matter of the conversation and what he told 9 you.
10 A I remember having the conversation, I 11 remember the subj ect matter, but I cannot recall 12 without speculation what is meant by the word 13 compensation.
7-t V 14 Q what was your recollection of what the 15 subject matter was?
16 A The subject matter concerned the 17 determination of reactor coolant drain tank level, i
18 Q what did he tell you about that?
19 A He said that there is no compensation 20 used to determine level.
l l
t 21 Q You remember him telling you that?
i 22 A No, I don't recall him telling me that, l 23 no, I do not.
24 On the basis of my written statement on l
O 1-22-79, he says that there is no compensation used
()_
25 i
aillingalcy 184 1
to determine level.
[/)
\_
2 Today you have no recollection of what 3 Q 4
back in January of 1980 you had in mind concerning 5
the compensation level or compensation when used in 6 determining the level?
7 A would you repeat that question again, 8 please?
MR. WISS: Let's break it up.
9 10 Q First of all, the note indicates 11 January 22, 1979.
12 I take it you would agree with me that
/'^'N 13 that's probably an error?
b I would agree it's an e; ror.
14 A Q It would be January 22, 1980?
15 16 A I agree it would be January 22, 1980.
17 Q Is it your testimony that you cannot 18 today remember what you knew or understood during 19 January 1980 about the need for compensation in 20 determining reactor coolant drain tank levels 21 accurately?
22 A I cannot recall in the absence of 23 speculation what would be required to determine 24 reactor coolant drain tank level.
' Q I am not asking you for the detailed 25
1 Billingsley 185 2 technical specifications of how to go about doing (q ))
3 it and the formulas that would be used and so on.
4 I am simply trying to understand what today you are 5 able to remember of the investigation in January ll 6 1980 and specifically what you are able to recall of 7 that aspect of the investigation that looked at 8 the need for compensation in determining reactor 9 coolant drain tank levels accurately.
10 Are you able to recall anything at al]
11 about that subject?
12 A I recall that I was requested to take a
(~' ; 13 look at reactor coolant drain tank level with respect V
14 to the computer printouts. I cannot recall in 15 detail my conversation with Bill Fels. I know I 16 spoke with him on this matter. I cannot recall our i
17 conversation and I cannot recall the conclusions l
18 drawn with respect to reactor coolant drain tank 19 level.
l 20 Q I guess that's not my question, 21 Mr. Billingsley. I want to know if you remember 1 22 anything today about what you understood in 1980,
! 23 particularly in January when you were performing 24 this investigation of the need for compensation in l (
' 25 determining accurately reactor coolant drain tank
1 Billingsley 186 k ,/ 2 levels?
3 A No, I cannot tell you that.
4 Q Sitting here today, you have no recollection llh 5 that there was or was not a need to make a 6 compensating calculation in order to accurately 7 determine levels?
8 A That I do not know.
9 Q You don't know whether it was or wasn't?
10 A I don't know whether it was necessary 11 or not necessary to make compensation.
12 Q You don't have any recollection of
~s (j) 13 making an investigation of it other than what appears 14 on the face of this page?
15 A That's correct.
16 Q would you look now at the page preceding 17 the chart we just referred to marked 23685. This is 18 another page of handwritten notes bearing the date 19 January 21, 1980 in the upper right-hand corner.
l 20 It begins, "J. Brummer name was given to me by 21 Putnam."
22 Und e rn ea th that, item 1, "Brummer remembers 23 a discussion being held, but can't recall who the g^) 24 discussion was held with and what the conclusion was."
'J w
- 25 Do you recall making that note?
1
1 Billingsley 187 rm ' 2 A Yes, I do.
l ,
(j 3 Q Who is Mr. Putnam?
4 A Mr. Putnam was an engineer whose office O 5 was in the same trailer that I operated out of at 6 Three Mile Island.
7 Q What was his areas of responsibility?
8 A His areas of responsibility at the time 9 that I knew him was development and writing the 10 sequence of events.
11 Q Did he have any connection with the 12 PORV leakage investigation?
13 A Not to the best of my knowledge.
U('3 14 Do you recall why Mr. Putnam gave you Q
15 the name of J. Brummer?
16 A No.
l 17 Q Do you remember having a discussion with 18 Mr. Erummer?
19 A No.
20 Q After seeing this note, do you have any .
21 recollection of what Mr. Brummer's statement which 22 is reflected here was about?
23 A Yes. My discussion with Mr. Brummer 24 concerned meetings held to discuss valve leakage.
k._) 25 Q Who is Mr. Brummer?
1 BillingslGy 188 2 A He is an individual at Three Mile Island.
(]
3 I do not recall his title nor who he worked for, 4 Q You don't know whether he worked for 5 GPU or Met Ed?
6 A No, I do not.
7 Q You said that there were discussions 8 c6ncerning leakage. Where these discussions that 9 had occurred before the accident or after?
10 A Before the accident.
11 Q What did Mr. Brummer tell you about 12 those discussions, as best you can now recall your
(~ 13 conversation with him?
V) He told me that meetings had been held 14 ,
A 15 to determine possible leakage in pressurizer safety 16 valves.
17 Q Did he tell you what had been said at 18 those meetings or what conclusions had been reached?
19 A I don't recall.
20 Q Beneath that there is a note which 21 reads, "Stubbs is calling NRC inspector who worked 22 on EMOV leakage. Stubbs is calling to determine if 23 NRC used computer thermocouple reading or one of 24 many thermocouple readings off the rad waste system f\
' stripcharts."
25
l Billingcicy 189 1
i 2 Then you skip a line and write, "Ask 3
Jim Stubbs if Wallace has any comment on the 4 increasing leak rate."
Do you remember making those notes?
llI 5 6 A vaguely.
7 Q I asked you yesterday if you were aware 8 that there were two separate systems for determining 9 the thermocouple temperatures at the discharge pipes 10 from the pressurizer relief valves.
11 Does this help refresh your recollection 12 as to the state of your knowledge in January 1980
- ) 13 concerning whether there were in fact two separate Q ,/
~
14 systems available for determining 'thos e temperatures?
15 A Yes, it helps. It helps me recall, yes, 16 it does.
17 Q There were two systems, were there not?
18 A Yes, there were.
19 Q They were independent of one another?
20 A That I don't know.
21 Q You understood that one of the systems 22 led to the computer which was in the control room?
23 A 1 do not recall with any great accuracy.
24 Q Do you recall what your comment at the
,s
(' ' '
) bottom means, " Ask Jim Stubbs if Wallace has any 25
Billingolcy 190 1
comment on the increasing leak rate"?
[J
' 2 No, I don't recall.
3 A
t 4 Q Is that something you were pursuing independently or were you simply asked to relay that (lh 5 6 question to Mr. Stubbs by someone else?
7 A I don't recall.
8 Q Go now two pages forward to the page 9 marked 23683. This has a page of handwritten notes titled " Deadline End of Next Week." Bears the date 10 11 January 25, 1980.
12 Is this in your handwriting?
A Yes, it is,
/~N 13 d Does this reflect work that you were 14 Q 15 doing?
16 A It reflects work that I was involved in.
17 Q Under the first item which is labeled 18 "Rochino analysis," there are four lettered sub-items.
19 Do you remember why you listed those various sub-items? Are those things for you to 20 21 follow ap on or do or get data or what?
22 A No. These weren't things for me to do.
23 Q For instance, the last item says "how 24 many thermocouples on each pipe."
( .I 25 Do you see that, item d under item 17
1 Billingoloy 191
(')
A Yes.
C/ 2 3 Q was that something you were going to 4 look into to determine how many thermocouples there I 5 were on each pipe?
6 A I don't recall.
7 Q Do you remember ever looking into that?
8 A No.
9 Q Beneath that is item 2 which reads, " Pull 10 from Lee and" -- I can't read that, whether it's 11 Itcher, "their reports and" and then you broke off 12 the comment.
,m i 13 Do you recall what that item referred to?
%s) 14 A No.
15 g would you look down at the bottom of the 16 page underneath the line which you have drawn through 17 the middle. There is an item " Tie 1977 data to 18 leakage (RCDT levels, repairs, reactant building-19 temperature). Do same for 1978 and 1979."
l 20 was that something you were going to do?
21 A I don't recall.
22 Q Do you remember doing it?
l 23 A No.
gy 24 Q At the bottom of the page is a comment I
! l v
25 "Ask Burley how arrived at 130 degree tailpipe l
4 1 Billingoley 192 temperature."
[w )l 2 3
Do you remember making that request of 4 Burley?
h 5 A Yes.
6 Q Who was he?
7 A An engineer at Three Mile Island.
8 Q Did he work for Het Ed?
9 A I don't know.
10 Q Do you rehJmber asking Mr. Burley about 11 this subject?
12 A Yes, I do.
f; 13 Q What was the point in asking, what were v
14 you interested in?
15 A I was interested in the technical basis 16 for 130 degrees.
17 Q Where had the figure of 130 degrees 18 come from as you had it?
19 A That figure came out of a procedure 20 that discussed tailpipe temperatures and leakage.
21 Q Had you been reviewing the procedure?
22 A I had looked at that brochure in 23 connection with TDR-126.
24 Q What did Mr. Burley tell you?
'" 25 A He said he didn't know.
1 i
1 Billingaley 193
,c,s 2 Q Did you ever pursue it with anyone t, e s.
3 else?
4 A No.
To this day do you know where the 130 h 5 Q 6 degree tailpipe temperature came from?
. 7 A No.
8 ,- Q Never found out?
9 A No, never.
10 Q Beneath that is the notation "When did 11 control room start leak rate calculation, reactor 12 coolant pump seal leakage" -- " leakoff" I guess is
, g 13 the word,.
' N ,li '
/ ,
14 Do you see that?
b ,,,
15 ' I. Yes.
t
,t 16 Q: Is that something you pursued?
f '
- , 17 - o - A I don't recall.
Did you ever find out when the control room i 1 lA' ;t .Q l >
. ;.. 3, t
?.9 starged their leak rate calculations?
- 20 -A' , 'I don'- '
recall.
F. l l .
"' 21 ' ,) _ < Q Would you look at the preceding page 22 marked 23682. It'.s a handwritten chart there labeled "Downstre'am Leakoff Temperatures Measured on r,
03 i / .;
I I 24 TR-7167 RAD Weste Disposal-RC Leakage Recovery Temp
' ,- l
(/ ._ .
25 MP Recorder." ,
m t'
{
i . ,, -,
1
/
s
. r: i If / ,
' ~'
,b , /
/
2 I Billingcisy 194 1 i
I
(-
_/ 2 Do you see that?
3 A Yes.
4 Q Who made up that chart?
lhI 5 A I don't know.
6 Q Where did you get it from?
7 A In the absence of speculation, I don't 8 know.
9 Q Why did you put it in your file?
10 A It was given to me.
11 Q I take it there are some things in life 12 that are given to you that you don't put in your file.
r
( ,
13 The question is why this particular 14 piece of paper was put into this particular file.
15 MR. GLASSMAN: If the witness knows.
16 A Because this related to the study that 17 was going on at the time.
IO How was it related?
Q 19 A I can't say how it was related back in 20 1980, 21 Q You have no recollection of what this 22 had to do with the investigation you were making?
23 A In the absence of speculation, no.
24 Q I don't want you to speculate, but seeing
(~N 3 C/
25 this doesn't help refresh your recollection as to what
I Billingsley 195
'T 2 it's about and why it related to the investigation?
[O 3 A These are based on the title here " Downstream 4 Leakoff Temperatures," and looking at all prior llk 5 documents, appear to be associated with RAD waste G disposal temperatures that we have been discussing 7 for the past couple of days.
8 MR. WISE: I would like to have marked 9 as B&W Exhibit 440 a set of handwritten notes 10 which bear the date -- it's not very clear.
11 Let's say we can't tell what the day is, but 12 it appears to relate to the reactor coolant 13 drain tank.
(~)
'u) 14 (Handwritten notes relating to the reactor 15 coolant drain tank marked B&W Exhibit 440 for 16 identification, as of this date.)
17 Q Are these notes on B&W Exhibit 440 in i
! 18 your handwriting?
l 19 A Yes, they are.
20 Q What does this chart reflect as best you 21 now recall?
22 A This chart reflects a log that I had 23 copie d.
l l 24 Q When did you do this?
\
(3 N.__/ 25 A The date at the top -- no, that's not my l
l I
Billingslsy 196 1
/'N 2 date.
NY Sometime after the accident, wasn't it?
3 Q 4 A Yes, 5 Q Was it in connection with the PORV leakage hlh 6 investigation?
7 A I can't say for sure.
8 Q Does this reflect a log of the times 9 that the reactor coolant drain tank was pumped down?
10 A Yes.
11 Q Why were you interested in that subject?
12 A I can't recall the basis for me taking 13 this data.
73 L,]
14 Q Do you remember what you did with it?
15 A I was taking this data down in connectior.
16 with TDR-160.
17 Q That's the TDR that covers the history 18 of the PORV?
19 A Yes.
20 Q What did the pumpdown of the reactor 21 coolant drain tank have to do with the history of 22 the PORV?
23 A I was taking a look at leakage and 24 looking to determine whether or not the reactor -- whether fs
-- I mean the block valve, the
() 25 or not the PORV was 1
Billingsley 197 1
PORV block valve was closed at any time.
() 2 V What did you find out?
3 Q 4 A on the basis of this data?
I 5 Q Well, either on the basis of this data 6 or any data you obtained in connection with that 7 work.
8 A I cannot make any determination on On the 9 whether or not the block valve was closed.
10 basis of all information that I was able to obtain, 11 I concluded it was not closed.
12 Q At any time during the period covered 13 by these notes?
7-s (s. s) 14 A That's correct.
15 Q While we're discussing the block valve, 16 let me show you some papers that came from files 17 identified as yours.
18 I will have them marked as B&W Exhibit 19 441, a copy of two pages of notes titled "RC-V-2 The first 20 (Block Valve for Electromatic Relief)."
1." The 21 page has at the left-hand margin " Unit 2." On 22 second page in the left-hand margin " Unit 23 the first page seven entries appear for various date:2 between July 1974 and April 1979. On the 24 (m second page for Unit 2 there is one entry for
(, 25
Billingsley 198 1
~* 2 September 1977.
( )
G' 3
Have you ever seen B&W Exhibit 441 before?
4 A I don't recall this document.
llk 5 (Two pages of handwritten notes titled 6 "RC-V-2 (Block Valve for Electromatic Relief)"
7 marked B&W Exhibit 441 for identification, as 8 of this date.)
9 Q Do you know who prepared it?
10 A No.
11 Q Do you have any recollection or knowledge 12 as to why it appears in your files?
13 MR. GLASSMAN: Objection. Lack of
(^
\,>
14 foundation.
15 MR. WISE: I will make a representation 16 subject to linking it up to the source list 17 showing that these documents were provided to 18 us and we were told that these came from 19 Mr. Billingsley's files.
20 Q Do you have any recollection as to why 21 this particular document was in your files?
22 A In the absence of speculation, no.
I 23 Q Let me go back to B&W 440, your handwritten 24 notes concerning the pumpdown of reactor coolant O)
\- 25 drain tank.
l l
Billingsley 199 1
2 Did you make up these notes from the
,/')
'wl 3 control room logs, so-called operator logs?
4 A Yes.
kh 5 Q If you look at the last page of those notes, 6 there is a comment which reads " Note: I reviewed 7 2301-3D1 and spoke with Bernie Smith who said there'd 8 be no reason to close the block valve to make an 9 actual leak measurement of PORV since they are 10 allowed certain amount of known (explained and 11 contained) leakage. I feel that the operator 12 should have extended himself to make a change in
~~ 13 system (close block valve). See line 24 of data (v! 14 sheet 1 and line 1 of data sheet 4."
15 The words "make a change in system" are 16 underscored by you.
17 First of all, 2301-3D1, refers to leak 18 rate calculation form in use at TMI?
19 MR. GLASSMAN: The witness' recollection 20 of that?
21 MR. WISE: I will show it to him in a 22 minute, but yes. I don't want to waste time.
I will show it to you. Let's mark it. B&W 23 24 Exhibit 442 will be a copy of the Three Mile
('S Island Nuclear Station Unit 2 surveillance
(_) 25
1 Billingsley 200 2 procedure 2301-3D1 consisting of a one-page
('
Lj}
3 procedure and certain data sheets which are 4 attached to it.
lhI 5 (Document entitled "Three Mile Island 6 Nuclear Station Unit 2 Surveillance Procedure 7 2301-3D1 RC System Inventory" with attached 8 data sheets, marked B&W Exhibit 442 for 9 identification, as of this date.)
10 Q You will note that B&W 442 has some 11 handwriting on it. I believe that's your handwriting; 12 isn't it, on the first page?
13 A Yes, it is.
g-~)
(/ These documents came from your files.
14 Q 15 Do you remember reviewing the surveillance procedure 16 for RC system inventory?
17 A Yes, I do.
18 Q You will note that the number for this 19 procedure is 2301-3D1. You will agree with me that 20 that's the same as the number that appears in your l
21 notes at the end of B&W 440?
22 A Yes, it is.
23 Q B&W 442 which is the surveillance 24 procedure is in fact the procedure that refers to
('M calculation by the operators-of reactor coolant
(., l 25
Cillingsley 201 1
/ n, i ) 2 system leak rate, is it not?
\~/
3 MR. GLASSMAN: Could I have that read 4 back?
!!k 5 (Question read by the reporter.)
6 A Yes.
7 Q Who is Bernie Smith?
8 A He is an operator at Three Mile Island.
9 Q Did you have a conversation with him 10 concerning the calculation of leak rates?
11 A No.
12 Q So your note which says "I reviewed 13 2301-3D1 and spoke with Bernie Smith" is wrong?
f~',}
w 14 A No.
15 Q I am sorry, I just asked if you had a 16 conversation with him about this.
17 A About leak rate, I did not discuss leak 18 rate. I discussed leakage. I did not discuss the 19 rate nor the calculation, how it was done. I 20 discussed the results which indicated that there .
21 was leakage. I did not discuss the basis of this 22 procedure. Maybe I misunderstood the question.
23 Q You remember having a conversation with 24 Mr. Smith, right?
(_q
~) .
25 A Yes, I do.
1 Billingsley 202 l
r~T l \
\J 2 Q You discussed with him leak measurement, 3 that's what your note says, Mr. Billingsley, isn't 4 it?
h 5 A Yes.
6 Q Are you telling us that leak measurement 7 is something different than measuring the leak rate?
O A No, it's the same.
9 Q Yot did discuss with Mr. Smith leak rate 10 measurement?
11 MR. GLASSMAN: We are getting into a 12 number of closely related terms.
/ \
k_,) 13 MR. WISE: The witness has chosen to 14 draw some very, very narrow distinctions so 15 I guess we'll have to go through it the long 16 way.
17 MR. GLASSMAN: I am not sure they are 18 narrow or not, but you can proceed with 19 whatever questions you like.
20 A Ask the question again.
21 (Question read by the reporter.)
22 A Yes.
23 Q Why did you feel that the operator 24 should have made a change in the system, namely
(~N
'w /)
25 closing the block valve in connection with making
1 Billingsley 203 r~'s 2 leak rate calculations?
)
x_/
3 A Based on my experience at another 4 facility, I was trained where possible to try to obtain any known leakages that you possibly could.
lh 5 6 Q How did you feel that closing the block 7 valve would help?
8 A It would allow you, if there was a leak 9 through that particular valve, it would allow you 10 to change that leakage and allow you to determine 11 known leakage.
12 Q Is that what you meant by the comments 13 that appear on the data sheet which is attached to 73 (v! 14 B&W Exhibit 442? I am looking particularly at the 15 last page of the exhibit which is labeled " Data 16 Sheet 1" and in two places there is handwriting 17 which I believe is yours. First comment, "As far as 18 I'm concerned this could include closing block valve 19 to reduce suspected leakage" and the same comment 20 is made or a similar comment is made a little bit 21 furcher down the page next to another section of the 22 calculations.
23 A Yes, that is what I meant.
24 Q Yesterday when we adjourned for the
/~
(,N) 25 afternoon, we were in the midst of going through some l
Sillingoley 204 1
i longhand notes from your file connected to your work
[)
'O 2
3 on the history of the PORV which eventually resulted 4 in TDR-160. I would like to now pick up with some more 5 of those documents.
6 First, I would like to show you and 7 have marked as B&W Exhibit 443 some handwritten notes 8 that do not appear to be in your handwriting but 9 came from your file.
10 (Two-page handwritten document marked 11 B &W Exhibit 443 for identification, as of this 12 date.)
13 Q Do you recognize B&W Exhibit 4437
\(~"N)
~,./
14 A Yes, I do.
15 Q Who wrote this?
16 A Jim Correa.
17 Q He was working with you on TDR-1607 i 18 A correct.
l 19 Q This was a draft of part of what l
20 eventually became the report? .
21 A Yes.
22 MR. WISE: I would like to have marked 23 next as B&W Exhibit 444 some more longhand 24 notes which I believe are primarily in
[h
(./ 25 Mr. Billingsley's handwriting.
1 Billingsley 205
[~) 2 (Set of handwritten notes marked B&W
'w) 3 Exhibit 444 for identification, as of this 4 date.)
I 5 Q You recognize B&W Exhibit 444?
6 A Yes, I do.
7 Q This is a handwritten draft of TDR-160, 8 is it not, or at least certain portions of it?
9 A Yes.
10 Q On the first page of the draft, there
- 11 appear some additional handwritten comments; do you 12 recognize whose handwriting that is?
r^x 13 A Yes.
14 Q Is that Mr. Correa?
15 A Yes.
16 Q You notice at the top, right underneath 17 the opening paragraph of the abstract there begins 18 a list of facts which the abstract states had 19 become apparent as a result of the investigation or 20 study.
21 The first one as handwritten by you, "The 22 Unit 2 PORV has experienced operating problems and 23 has undergone repair and modification." Someone has 24 crossed out the words " repair and" and has written
,rm i
k- 25 at the left-hand side of the comment or of the item, I,
1 Billingsley 206 2 " Modify, words are too harsh."
v)
(
Do you see that?
3 4 A Yes.
lh 5 Q Did you have a conversation with 6 Mr. Correa as to modification of this first item?
7 A I recall those words. I don't recall 8 my discussion.
9 Q In fact, the final TDR eliminates the 10 section -- the phrase "has experienced operating 11 problems," did it not? I will show it to you in a 12 minute.
13 Do you recall that those words were g-)
U 14 taken out?
15 A No, I don't recall.
16 Q Do you recall why Mr. Correa felt the statement as you originally wrote it was too harsh?
17 18 A No, I don't.
19 MR. WISE: I would like to have marked 20 next a letter dated October 18, 1979 from 21 Mr. Harding to Mr. Short of B&W. It bears a 22 stamp on the face of it. It appears to be 23 a routing stamp and Mr. Billingsley's name 24 has been written in. We'll have this marked
(_/ 25 as B&W Exhibit 445.
Billingaley 207 1
2 (Letter dated October 18, 1979 to 3
Mr. Short from Mr. Harding marked B&W Exhibit 4 445 for identification, as of this date.)
5 Q Do you recognize Exhibit B&W 4457 6 A I vaguely remember this.
7 Q You were attempting during your wcrk on 8 TDR-160 to determine how many times the PORV had been 9 actuated on reactor trips; is that correct?
10 A That's correct.
11 Q Is this letter something that you 12 gathered during the course of that work?
13 A Yes.
/N N.] This reflects a listing by Mr. Harding 14 Q 15 of certain reactor trips that had occurred at TMI-1; 16 is that right, and resulted in a PORV actuation?
17 MR. GLASSMAN: According to the letter ?
18 MR. WISE: According to the letter.
19 A That's correct.
20 Q Did you use this as part of your 21 investigation?
22 A I believe I did.
23 Q Did you ever come to any overall 24 determination of how many times the PORV had been T
xl 25 actuated at TMI-1 and 27 l
1 Billingsley 208 2 A Yes, based strictly on reactor trips.
3 Q What did you find?
4 A I don't recall the exact numbers, but I 5 can say that the PORV, to the best of my memory, had 6 more actuations for a given period of time at 7 TMI-2 than it did at TMI-1.
8 Q Do you recall ever learning that the PORV 9 at TMI-2 had cycled some odd 50 times prior to the 10 cool down transient that occurred on April 23, 1978 11 at TMI-27 12 MR. GLASSMAN: Could I have it read back?
f3
) 4
\ 13 (Question read by the reporter.)
14 A No, I don't recall that.
15 MR. WISE: I am going to mark next a 16 series of letters and memos, various documents
! 17 which were produced to us from Mr. Billingsley's 18 filec. I believe they all relate to the PORV 19 history investigation. They are items which l
20 were not included as exhibits to TDR-160. We i
have omitted those that were included as 21 l
l 22 exhibits because we're going to mark TDR-160 23 in a moment. These were in your tile and for 24 some reason or another they didn't make their l t xs
)
l 25 way into TDR-160 as exhibits.
l l
1 Billingsley 209
,a 2 I would like them identified now so we
()
3 know where they came from and what they relate 4 to.
I 5 First is a letter or memorandum dated 6 March of 1977 from a Mr. Shovlin at 7 Metropolitan Edison. It's rather difficult 8 to make out the subject matter based on the 9 poor quality of the copy that we have, but it 10 appears to relate to a field modi fication of 11 some sort to the PORV at TMI-2.
12 (Memorandum dated March 1977 from (m) 13 Mr. Shovlin marked B&W Exhibit 446 for KJ 14 identification, as of this date.)
15 Q Let me ask you something with respect to the 16 entire series of documents that I am going to mark.
17 Do you recall as part of your investigation 18 making a collection of documentation relating to-19 the TMI PORV -- TMI-2 PORV?
20 A Yes.
21 Q You went out and searched through Met Ed 22 files and GPU files in order to gather that 23 documentation?
24 A Correct.
\ !
25 Q You collected it all in your file?
1 Dillingsley 210 l
[ ) 2 A Correct.
'w) 3 Q Do you recognize this memorandum as being 4 one of the items you found during the course of llI 5 your study and investigation?
6 A I don't remember this particular document, 7 no.
8 Q I will tell you what we'll do. Let's 9 go straight through this and mark all of these and 10 then I will ask you some general questions about them.
11 It might go faster.
12 MR. WISE: As B&W Exhibit 447 I would
(~' 13 like to mark a letter dated March 29, 1978 from (Tl 14 a Mr. Bolger of Dresser Industries to Mr. Cotter 15 at Met Ed.
16 (Letter dated March 29, 1978 from 17 Mr. Bolger of Dresser Industries to Mr. Cotter 18 at Met Ed marked B&W Exhibit 447 for l
l 19 identification, as of this date.)
i 20 MR. WISE: As B&W Exhibit 448 I would like to mark a letter dated December 1, 1969
- 21 22 from Dresser Industries to B&W relating to 23 an order for an electromatic relief valve.
24 Attached to it are some certificates and rx i
l (N-) 25 reports, some of which are handwritten.
i
l cillingsley 211 1
(Letter dated December 1, 1969 from
[; 2
\J 3 Dresser Industries to B&W with attachments 4
marked B&W Exhibit 448 for identification, as 5 of this date.)
6 MR. WISE: By the way, on this particular 7 exhibit there is on the cover sheet a photocopy 8 of the file from which it was taken with the 9 notation " Design Data" written in.
10 Q Do you see that?
11 A Would you repeat it?
12 Q You see the front page of the exhibit 13 has -- is a photocopy of the file jacket from which
("'s J
14 these documents were taken. It bears a notation 15 " Design Data" in handwriting.
16 A Yes.
17 Q Is that your handwriting?
18 A Yes, it is.
19 MR. WISE: Next as B&W Exhibit 449 a 20 field questionnaire and problem report 21 relating to the PORV at TMI-2 and certain modifications being made thereto. The covering 22 23 page bears a date April 6, 1978.
24 (Copy of field questionnaire and problem O)
\/ 25 report, cover page bearing date April 6, 1978,
Billingsley 212 1
,c8 I
x_/
i 2 marked B&W Exhibit 449 for identification, as 3 of this date.)
4 MR. WISE: Next as B&W 450 a field k 5 questionnaire number 1874 which bears the date 6 May 25, 1977 and has attached to it various 7 drawings and reports.
8 (Field questionnaire number 1874 bearing 9 date May 25, 1977 with attachments marked B&W 10 Exhibit 450 for identification, as of this date.)
11 MR. WISE: As B&W Exhibit 451 a document 12 which appears to be a field change report l')
( )
13 relating to field change report 188 and attached 14 to it are various documents associated with 15 that field change request.
16 (copy of field change report with documents 17 attached marked B&W Exhibit 451 for identification, ,
18 as of this date.)
19 MR. WISE: Next as B&W 452 a letter 20 dated January 24, 1972 from Dresser Industries 21 to B&W relating to an order for a PORV.
22 (Letter dated January 24, 1972 relating 23 to PORV order marked B&W Exhibit 452 for 24 identification, as of this date.)
<'s (J
x.
I 25 MR. WISE: B&W Exhibit 453, a letter
1 Billingsley 213 dated October 5, 1976 from Dresser Industries
(_) 2 I.
3 addressed to Mr. Stuhrke of Burns & Roe 4 relating to some work done on the TMI PORV.
I 5 (Letter dated October 5, 1976 from Dresser 6 Industries addressed to Mr. Stuhrke of Burns &
7 Roe marked B&W Exhibit 453 for identification, 8 as of this date.)
MR. WISE: As B&W Exhibit 454, a two-page 9
10 quality assurance data sheet relating to 11 the Dresser PORV.
12 (Two-page quality assurance data sheet relating to Dresser PORV marked B&W Exhibit v) 13 14 454 for identification, as of this date.)
15 MR. WISE: Finally, as B&W Exhibit 455 16 a copy of a memorandum to file from Mr. Harbin 17 dated February 1, 1980. The subject is the 18 PORV.
19 (Cepy of a memorandum to file from Mr. Harbin dated February 1, 1980, subject, 20 21 PORV, marked B&W Exhibit 455 for identification, 22 as of this date.)
23 Q Mr. Billingsley, we have now marked 24 Exhibits 446 through 455. Exhibits 446 through 454 g-Y) 25 were produced to us from files represented by your
1 Dillingaloy 214
.s s 2 counsel to be yours. 455 was produced from
%,-)
3 Mr. Correa's files.
4 Would you look at 446 through 454, those lll 5 that came from your file and tell us if you recognize 6 those as being copies of various correspondence, 7 memoranda, field change reports and the like that 8 you collected during the course of your investigation 9 into the history of the PORV?
10 A I vaguely recall B&W Exhibit 450. I 11 vaguely remember 451. I don't recall 452. I don't 12 recall 453. I vaguely recall 454. The other 13 aforementioned documents that you cited.
[ )
\ '/
14 Q 446 through 449, ones that you have not 15 mentioned yet?
16 A The ones that I have not mentioned, I do 17 recall.
l 18 Q Of those you do recall, 446 through 451 19 and number 454, those are documents you collected 20 from the files of Met Ed and GPU in connection with 21 the history of the PORV?
22 A Yes.
23 Q Let's look at the two you don't recall, 24 452 and 453.
f"N
( ,) 25 452 is a letter from Dresser Industries
I Billingslay 215
(h 2 addressed to B&W dated January 24, 1972 and refers (x.s) 3 to an order numbered 022660LS.
4 Do you recall whether that is the order lll 5 number that relates to thn PORV originally ordered 6 for TMI-27 Does that number ring a bell with you?
7 MR. GLASSMAN: Obviously Mr. Billingsley 8 was not employed by GPU in 1972 so he cannot 9 have a direct recollection of that.
10 If the question were rephrased whether 11 he made such a determination, it would be 12 appropriate.
f~'} 13 Q Did you ever make a determination as L./
14 to when and under what circumstances the original 15 order for the PORV at TMI-2 was made?
16 A I recall making a determination of when 17 the valve for TMI-2 was ordered. I do not recall 18 whether or not I determined the circumstances 19 under which the order was made.
20 Q will you look now at B&W Exhibit 453 21 which is a letter from someone at Dresser addressed 22 to Mr. Stuhrke of Burns & Roe dated October 5, 1976.
23 Did you become aware during the course 24 of your investigation that in 1976 the valve which N/ '
25 had originally been ordered for TMI-2 was returned
1 Billingsicy 216 2 to Dresser Industries for refurbishing?
(V~')
3 MR. GLASSMAN: Could I hear that back?
4 A Would you repeat the question again, llh 5 please?
6 (Question read by the reporter.)
7 MR. GLASSMAN: Objection insofar as this 8 question tries to tie some investigation 9 conclusion of Mr. Billingsley to a letter he 10 doesn't recall seeing.
11 MR. WISE: I am trying to refresh his 12 recollection to see if we can determine what 13 relationship this letter has to those events,
(~))
14 but first we have to establish that those events 15 took place.
16 A I do recall that electromatic was sent 17 back to Dresser for refurbishing. I cannot recall 18 for which unit that valve was.
19 MR. WISE: Let's have marked at this 20 point your TDR-160. We'll have that as B&W 21 Exhibit 456.
22 (Multipage document, TDR-160, titled 23 "TMI-2 PORV Investigation" marked B&W Exhibit 24 456 for identification, as of this date.)
/~'si i
\~ 25 Q Exhibit 456 is a copy of your TDR-160; I
1 Billingsley 217 p( )
_ 2 is that right?
3 A That's correct.
4 Q That's your signature on the cover page llh 5 along with that of Mr. Correa's?
6 A Yes.
7 Q would you look at page 14 of your TDR.
8 Do you have that?
9 A Yes.
10 Q That page contains the beginning of a 11 section labeled "4.3 Valve Repairs and Modifications."
12 Do you see that?
e'
( ,s) 13 A Yes.
14 Q You will note that the Unit 2 PORV is 15 identified as BNO4233. During the course of your 16 investigation you were able to identify the serial 17 number for the PORV for Unit 27 i
l 18 A Yes.
, 19 Q That is the number?
l
! 20 A Yes.
21 Q Go down to the next paragraph which 22 refers to table 3 attached to the report. It says 23 that that particular table provides information on 24 the particular work performed on the valve.
(O"]
25 I take it that's the work performed on i
1 Billingelsy 218
(~3 2 the valve for Unit 2? Is that right?
'v!
3 A That's correct.
4 Q Final sentence says, "The table does not lh 5 contain work performed by Dresser Industries in 6 response to a purchase order dated June 8, 1976 7 (see Appendix 6)."
8 Do you see that?
9 A Yes.
10 Q If you turn to Appendix 6 to your report 11 which is at page 1354 as marked for purposes of 12 this litigation, and the actual appendix itself at
- 13 1355, you will find a work order or purchase order 14 dated June 8, 1976 addressed to Dresser Industries 15 from Jersey Central Power & Light.
16 Do you see that?
17 A Yes.
18 Q Does this help refresh your recollection 19 that in 1976 the Unit 2 PORV was the one that was 20 returned to Dresser Industries for refurbishing?
21 MR. GLASSMAN: Objection. Again, 22 Mr. Billingsley was not there at the time and l 23 he cannot testify as to firsthand knowledge.
~
l 24 The question would have to be appropriately f~% asked in terms of whether his memory is
! ,_,) 25
1 Billingsley 219 2 refreshed in terms of the results of whatever
[J) 3 investigation he happened to do in connection 4 with this TDR.
S 5 MR. WISE: That's fair enough. I will 6 accept that amendment to my question.
7 A Repeat that question because now I don't 8 know what the question is.
9 It's simply this: Does looking at these Q
10 papers help refresh your recollection that during 11 your investigation you learned that the TMI-2 PORV 12 was returned to Dresser Industries in 1976 for 13 refurbishing?
[~N)
LJ 14 MR. GLASSMAN: Objection in terms of 15 "as learned." Mr. Billingsley did certain 16 work and obviously he may have reached certain 17 conclusions. We don't know if others reached 1
18 other conclusions based on data that was given.
19 Learned in the context of what happened in l 20 1972 or 1976 can be misleading. .
21 MR. WISE: I will stand on the question.
22 A Unit 2 valve was returned to Dresser 23 per this purchase order.
24 Q Would you look at B&W.453 which is the (n) x- 25 October 5, 1976 letter from Dresser back to Burns &
l l
1 Billingsley 220 x- You will note that the subject is the 2 Roe.
electromatic relief valve BNO4233. You note that 3
4 that's the Unit 2 valve?
5 A BNO4233, 6 Q Do you remember during the course of 7 your investigation collecting all the documentation 8 that you could regarding the 1976 return of the PORV 9 for Unit 2 tp Dresser Industries for refurbishing?
10 A Yes, I gathered all information that I 11 could.
12 Q After going through this review of the
( ,s
(' ') 13 chronology and reviewing the serial numbers for the 14 valve, does this help refresh your recollection 15 that B&W Exhibit 453 is a copy of a letter that you 16 gathered during the course of your information of 17 the history of the Unit 2 PORV?
18 A My memory is not refreshed with respect 19 to Exhibit 453, 20 Q Would you look now at B&W 455. This is a file memo from Mr. Harbin dated February 1, 1980 21 22 which was produced to us from the files of Mr. Correa.
23 Do you remember whether you ever saw this
(~')s
(, 24 particular file note that Harbin had written?
l 25 A I don't recall seeing this document, no.
I
, r- ,,
) i,
- v 't v ... . .
1 l )lff .f /1
') }
Hn r Billingoloy 221 t' , !' :/
y e.
i > :'j e n, 's '
,i (Jl 2 . h [< r, , There is a reference on the -- let me
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)
, p- Ql <
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~
. ~ i /
x
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p'
'3
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begin again. <
4, Tnik file note from Harbin says that
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/5 Attached are summari e s of recent correspondence
, , J,
/~6 '
related,to the TMI-1 PORV. It takes into account l,
7 only correspondence found in the Unit 1 Superintendent's i 5 8 f !. l e'v as of January 30, 1980. These summaries
\ _ l ',c , -
i should be helpful in establishing future action l
- 9 j
' 10 re19ted to the valve, spares and associated piping.
f,- ,
11 Also attached are copies of excerpts from the TMI-1 12 Restart Report (thru Rev. 10) and NUREG 0578 and
(~'} ,/
13 0560 (?)."
y' .
14 Do you recall whether Mr. Correa ever i
/
15 discussed with you his efforts to gather materials j
r, .
,, 16 related to the TMI-1 PORV?
., 17 A Repeat that.
1 18 Q Do you recall whether Mr. Correa ever 19 discussed w'ith you his efforts to gather materials i
t 20 'related to the TMI-1 PORV?
21 ','
A No, I don't recall that discussion with 221 r esp ec t to TMI-1.
$ 23 Q Would you look at the second page of
- ' N Mr. Harbin's file note. You will note at the top
,o
? A
' - 25 of the page there is a section labeled " History" and s 4 i
e
1 Billingoloy 222
~
2 there are five chronological notations. The first
('s_)^,
3 one refers to July 30, 1975. A letter from Lee 4 Rogers to .T.G. Herbein, REM-I-131 warning of 5 corrosion products causing valves to remain open.
6 " suggests periodic inspections, etc."
7 Did you ever become aware or see 8 Mr. Rogers' July 13, 1975 letter to Mr. Herbein?
9 A I don't recall ever seeing that document.
10 Q Do you remember ever looking for it?
11 A No.
12 Q Let me show you what has been previously 13 marked as B&W Exhibit 163. It's a copy of a memorandum r~'x N-] dated September 27, 1973, from Mr. Heward, Project 14 15 Manager at TMI to Mr. J.E. Wright, TMI Site Quality 16 Assurance Manager.
17 Do you remember ever seeing a copy of 18 this memorandum and the attached memorandum of 19 september 14, 19737 20 A Never saw this. .
21 Q Would you look at the next letter in 22 the exhibit which is dated June 22, 1973 from a 23 Mr. Donald Ross to Mr. A. Giambusso concerning the 24 failure of an electromatic relief. valve at oyster (3
h,J 25 Creek.
1 Billingoloy 223 2 Did you ever see a copy of that letter?
L ;)
3 A Never.
4 Q Turn now to B&W 456, your TDR-160 5 concerning the PORV investigation.
6 Is B&W 456 the final version of the report?
7 A Yes, it is.
8 Q Was this report approved by anyone?
9 A Not to the best of my knowledge.
10 Q Was it regular procedure to have TDR's 11 signed by an approving official?
12 MR. GLASSMAN: You want this witness' 13 knowledge?
( )'
\_/
14 MR. WISE: Yes, to the best of his 15 knowledge.
16 A To the best of my knowledge, yes.
17 Q Was there any reason why this particular 18 one does not carry an approval signature?
19 A I have no idea.
20 Q who did you submit this to?
21 A I submitted a number of copies of this 22 report to Jim Correa who in turn was to submit this 23 to either his boss at the time, Jim Moore, I believe 24 that was his boss and/or Keaten, but that was my (m )
\-) 25 understanding.
I
1 Billingolcy 224 (Gi'.
~
2 Q Who decided on the distribution list 3 that appears on the first page of the TDR, Messrs.
4 Croneberger, Keaten, Long and Wallace?
4I 5 A I don't recall.
6 Q Were you able to conclude why the PORV 7 failed at TMI-2 on March 28, 19797 0 A No.
9 Q Were you able to conclude whether it was 10 the valve itself or associated equipment?
11 A No.
12 Q Do you know whether anyone within the 13 GPU system has been able to conclude that as of today?
("]3
\-
14 A No.
15 Q Would you look at the third page of the 16 TDR. There is a list of references which begins 17 on that page and carries over on to the next page.
18 Do you see that?
19 A Yes.
20 Q Did you make any file or repository 21 for those references, someplace where they would 22 all be collected and kept together?
23 A I will answer that question to the best 24 of my ability. To the best of my knowledge any
/' 't
's / 25 document that's shown here, I maintained a copy in
I Billingoloy 225 2 a file drawer.
(~')
'v 3 Q Would you look now at page 5 of your 4 report?
I 5 A Which would be what page on the document?
6 Unfortunately it's split there. I think Q
7 they meant 1299.
O MR. GLASSMAN: All the pages have 1299.
9 MR. WISE: The stamping appears to have 10 broken down at that point.
11 A Page 5 is references.
12 Q Page 5I have starts with " Methods."
~s 13 A Are you counting this first page here as
)
(-J 14 a page?
15 Q I am looking at the pages as you numbered 16 them. You will see the last paragraph there which 17 reads "It should be stated that while written 18 documents exist a lack of document organization 19 and control, with respect to the PORV, is 20 apparent. Investigative efforts were consequently 21 hampered which limited, in some cases, the depth 22 of detail."
23 Where did you go to find documentation 24 concerning the PORV history? Where did you look?
(- I looked in the warehouse, procurement
'-,/ 25 A
1 Billing 31oy 226
( ,/ 2 offices, I used the document control center that 3 was established at Three Mile Island. I went 4 through boxes of personnel files. I contacted 5 Dresser Industries. I utilized information found 6 by various commissions and consultants who have 7 worked in this area. I went to maintenance records.
8 Personal conversations and leads with people to try 9 and find out what their personal knowledge was which 10 would lead me to additional files. I believe I 11 spoke on a number of occasions with a fellow at 12 Three Mile Island named Lee Rogers. I believe at
( ) 13 one point in time I contacted Jersey Central for a
14 information.
15 Those are my primary sources. Also, 16 going back to the valve manuf acturer, if I didn't 17 mention that.
18 Q What kind of a response did you get from 19 the valve manufacturer, Dresser Industries?
20 A Less then satisfactory.
21 Q What do you mean?
22 A The valve manufacturer in my opinion was 23 extremely slow in providing any information whatsoever
~3 24 with respect to this valve and work that they had
'~'
25 performed on it and when the valve manufacturer i
1 Billingoloy 227
,'~s 2 finally did provide information, I didn't find it t l
'O 3 to be extremely valuable.
4 Q Did the valve manufacturer provide all 9 5 the information or responses to inquiries that you 6 had made?
7 MR. GLASSMAN: Are you asking if all this 8 requests were answered --
9 MR. WISE: Let's break it down.
10 Q You made a request of Dresser Industries 11 for certain information?
12 A Yes.
13 Q Did you write them a letter?
,x
/
( )i 14 A Mr. Correa wrote the letter.
15 Q That letter asked for various items of 16 information?
17 A correct.
18 Q Do I take it that when Dresser finally 19 did respond, they did not respond to all of the items 20 that had been requested?
21 A They either did not respond or did not 22 respond in what I thought was adequate detail.
23 Q In your report you and Mr. Correa 24 attempted to list the possible failure modes for (n_) 25 the PORV; is that right?
Billingoloy 228 1
2 A correct.
,e L _,]
3 Q They are presented in Table 1 of the 4 report; is that right?
5 MR. GLASSMAN: So I understand the 6 question, is the question whether Table 1 lists 7 all possible failure modes or if it lists 8 those that Mr. Billingsley considered?
9 Q Does Table 1 list possible failure modes 10 for the PORV that you and Mr. Correa identified?
11 A Yes.
12 Q In addition --
13 A Excuse me. I must qualify that statement.
7
( )
14 There was a third individual who worked 15 on this report for a short period of time named 16 Mr. Bogart. Mr. Bogart made -- reported this list 17 which was contained in the report signed by myself 18 and Mr. Correa.
19 MR. GLASSMAN: For the record, we are 20 speaking of Table 1 found at page 22 of the 21 report.
22 MR. WISE: Yes.
23 Q In addition to those possible failure 24 modes listed in Table 1, I believe you and Mr. Correa 7m, l, ) 25 wrote in your report that there were two potential
1 Gillingoloy 229 2 failure modes beginning on page 10 and carrying over f'~')
'w) 3 to page 11.
4 A Correct.
G 5 Q The first additional possible failure 6 mode is stated to be " distortion of the solenoid 7 coil which could cause the solenoid plunger to 8 stick in the down (valve open) position. To 9 understand and evaluate this mode of failure one must 10 examine the PORV history."
11 Then there is a paragraph which immediately 12 follows it which purports to lay out some of the 13 history.
.] 14 Did you have an understanding as to what 15 it was about that history that indicated that 16 potential failure mode?
17 A I had a broad understanding, yes.
l 18 Q What was your understanding?
l 19 A I cannot recall my understanding at this 20 time.
21 Q The paragraph reads, "In October 1974 22 work request No. 4650, for TMI-Unit 1 was initiated 23 to ' remove, replace, and/or overhaul the ele c t roma tic 24 relief valve to stop reactor coolant leakage.'"
g
(_) 25 I take it that's the reference to
1 Billingsley 230 g
Nl 2 remove the TMI-l PORV?
3 MR. GLASSMAN: The witness' recollection?
4 MR. WISE: Yes.
5 A That's correct.
6 Q As a result of that work Unit 1 PORV was 7 removed and the Unit 2 PORV was put into its places 8 is that right?
9 MR. GLASSMAN: You are asking the results 10 of the investigation?
l? MR. WISE: Yes.
12 A That's correct.
(_,) 13 Q The paragraph goes on to read, "One 14 item not mentioned in the work request is the fact 15 that the Unit 1 PORV has a 250V DC solenoid and the 16 Unit 2 valve has a 125V DC solenoid. It is possible 17 that the Unit 2 valve was installed and operated 18 with a 250V DC power supply."
19 Did you come to have any understanding 20 as to what effect that might have on the Unit 2 21 valve?
22 A Yes.
23 Q What effect might it have had?
I 24 A Stated in the previous paragraph "The
(}
N-25 first possible cause of failure is distortion of the
Billingsley 231 !
1
/
'^
2 solenoid coil which could cause the solenoid plunger v
3 to stick in the down position."
4 Q Did you and Mr. Correa or anyone else 5 to your knowledge make an investigation to determine 6 whether at the time the Unit 2 valve was installed 7
on Unit 1 some change had been made to correct the 8 voltage in the solenoid?
9 A I conducted a search for that information.
10 Q What did you find?
11 A I could not find any inforniation that 12 would document voltage supply to the valve.
,e '3 13 Q The other possible cause in addition (j'
14 to those listed in Table 1 presented on page 10 of 15 ycur report, "is distortion of the valve due to 16 stresses caused by differential thermal movement 17 between the valve and its discharge piping during 18 normal operation."
19 Who determined this as an additional 1
20 potential failure mode?
l 21 A Mr. Correa.
g 22 Q Did you have any understanding as to 23 what he had in mind with respect to this item?
24 A At the time, yes.
c (~b)
\/ 25 Q Did you have any understanding now?
Billingalsy 232 1
m 2 A Very broad understanding, i
s )
3 Q What is your understanding of what this 4 was about?
O 5 A My broad understanding at this time 6 that this concerned thermal stresses which could 7 possibly distort the valve.
8 Q Was it your understanding that the piping 9 and the valve were made of different materials?
10 A That I don't know.
11 Q Was it your understanding that that's 12 what is being suggested in this comment?
13 A That is not my understanding.
('v) 14 Q What would account for the difference in 15 thermal movement between the valve and its piping?
16 MR. GLASSMAN: You are asking the witness 17 to speculate.
18 MR. WISE: He did this report. I think 19 I can ask him what he understood and was l 20 meant by this statement.
21 MR. GLASSMAN: Fine.
22 A Repeat the question.
23 (Question read by the reporter.)
24 A You are asking me what would cause a
(, 'i N- 25 thermal expansion?
1 Billingsicy 233 2 There is a comment here that a possible
,' ~') Q
%_J 3 cause of the failure was distortion due to stresses 4 caused by differential thermal movemunt. I think 9 5 f<>r most laymen that's a lot of gobbledygook. I am 6 trying to get an understanding that if someone gets 7 this to read maybe they can make sense of this 8 comment. That's the purpose.
9 What thermal movement are you talking about?
10 What is the difference you are talking about? What 11 is your understanding of what this means in layman's 12 terms?
,-- 13 A My understanding of what this statement V 14 means in layman's terms is that temperature 15 differences can cause changen in metal expansion, 16 shrinking can be caused, cooled down, expansion of 17 metals can be caused by heat up. In the consequences 18 of those heat up and cool downs can cause stresses 19 on piping and valves such that typically in those 20 type of situations mechanical damage may be caused.
21 Q Look at page 11, that contains the g
22 beginning of a section labeled "4.2.1 PORV Failures 23 (Open Position) At Other Sites."
24 would you look at the second paragraph
(~)
(_j 25 in that section. Particularly the last sentence of I
1 Billingoloy 234 2 that second paragraph which reads " Appendix 3
(
3 provides a preliminary assessment of actuations 4 which have occurred at TMI Units 1 and 2."
9 5 I take it that refers to Appendix 3 which 6 appears at the back of the report beginning on page 1338 as marked for purposes of this litigation. Do 7
8 you see that? Does Appendix 3 represent the sum of 9 your investigation and assessments of PORV actuations 10 at TMI 1 and 2 before the March 28 accident?
11 A Yes, it does.
12 Q Do you know whether anybody has done any
(~T 13 further work to try and pin down the number and b 14 timing of those actuations?
15 A Not to the best of my knowledge.
16 Q Would you look at that appendix again 17 and take a look at the first part of it which is a 18 series of memoranda from Mr. Harbin to you and then 19 Mr. Logan and to Mr. Miller, with carbon copy to 20 you of which precede a two-page listing of reactor .
21 trips and turbine trips at Unit 1 which resulted in 22 PORY actuations.
23 Following that is a memorandum of a 24 phone conversation o n. September 17, 1979 from Jim
/\
)
i N/ 25 seelinger to someone named Dave with a listing of i
I Billingsley 235 .
2 actuations at THI-1 and second listing of actuations
('J
~.
)
3 at TMI-2.
4 Are these two listings the report of G 5 the phone message from Jim Seelinger, and the chart 6 on Unit 1 provided by Messrs. Logan and Harbin to 7 you the only listing that you received of reactor 8 trips that resulted in PORV actuation?
9 A I believe so.
10 Q Who is the Dave referred to in the phone 11 message memorandum?
12 A I don't know.
13 Q How did this particular piece of paper
(^N)
%.J 14 come into your hands?
15 A I don't recall.
16 Q You have no idea who Mr. Seelinger had 17 his conversation with?
18 MR. GLASSMAN: You are asking him to 19 speculate?
20 MR. WISE: I am asking if he has any 21 idea who it was.
22 MR. GLASSMAN: It sounds to me if he 23 has any idea, it asks for speculation. If 24 you ask if he has any recollection of who he
('s i 25 was, that's a different story.
1 Billingcisy 236
~
2 A I don't know who Dave was.
('v/'T 3 Q Did you ever examine any actual TMI 4 data to determine the number of reactor trips where 5 there had been a PORV actuation?
6 A No, I never reviewed any data.
7 Q Did you ever investigate or know whether 8 anyone else investigated whether leakage through 9 the PORV prior to the accident may have caused 10 thermal stress on the valve?
11 A I am not aware of such an investigation.
12 Q Would you turn now to page 14 of your
,.e') 13 report. On that page the section begins label V "4.3 valve Repairs and Modifications" which were 14 15 referred to earlier this morning.
16 In particular would you look at the last 17 sentence on that page which we also referred to 18 earlier this morning which concerns the work done 19 by Dresser Industries in June 1976 on the PORV 20 for TMI-2.
I 21 Did you ever find out who had requested 22 that that work be performed?
23 A I don't recall who.
24 Q Did you ever find out why it was
. /~'N I
( )
i \_/' 25 requested?
l l
1 Billingoley 237 2 A I believe so.
(~')
'N_/
3 Q What did you find out?
4 A That work was requested after the valve G 5 was removed from Unit 1. I think the bssis for 6 singling that valve out is included in this report.
7 To the best of my knowledge I did take a look at 8 why but I can't recall without looking at this report.
9 Q Is there any other section involving 10 valve repairs and modifications other than the one 11 we are looking at on page 14 and carries over to 12 page 15 and 16?
13 A This would be the only information that N.) 14 I would have on that repair. This is shown on 15 page 14 and 15 and contained in Appendix 6 and 16 Appendix 7.
17 Q You are welcome to look through those but 18 I don't think based upon my reading of them that l 19 there is anything in there as to why that work was i 20 done. ,
21 A Then I don't have it.
g 22 Q Would you look over on page 15, the 23 last sentence of the opening paragraph reads 24 " Metropolitan Edison Company (Reading) and Jersey 7 w) t 25 Cantral Power & Light Company were contacted to l
l
Billingcisy 238 1
[^j 2 locate all records associated with the purchase
\J 3
order dated June 8, 1976; however, as of this 4 writing, repair data detailing work performed has dh 5 not been located."
6 was it ever located?
7 A I never located it.
8 Q Do you know whether anyone else ever did?
9 A No, I don't.
10 Q Would you look now at page 17 of your 11 report. You will see that there is a section that 12 begins on that page labeled "4.4.1 GPUSC Leakage 13 Study." That references TDR-126, does it not?
r3 u,
14 A Yes, it does.
15 Q If you look at page 18 which continues 16 that section you will see in the middle of the page 17 a paragraph which reads, "The fact that 130 degrees 18 Fahrenheit PORV tailpipe temperature is incorrect 19 comes f rom two sources. "
20 I take it the reference to the 130 21 Fahrenheit tailpipe temperature, is to the 22 temperature given in the pressurizer system failure 23 in the emergency procedure as a symptom for a leaking 24 PORV is that right?
(-)
i n 25 A This is contained in the procedure that
1 Billingoloy 239 r3 2 is in response to a leaking PORV.
V 3 Q You give as a reason for why the 4 temperature is incorrect, two references. One is 5 TDR-126 which we have already discussed. The other 6 is GPU startup problem report number 5147, dated 7 October 5, 1977. You go on to state, "While TDR-126 8 was written after the accident, GPU Report number 9 5147 occurred almost two years prior to the accident.
10 The problem report established that the symptom 11 temperature for a leaking PORV is 60 degrees 12 Fahrenheit higher than the value stated in the p_
13 procedure (see Appendix 10)."
i
' J 14 If you refer to Appendix 10, you will 15 see the site problem report that you referred to, 16 number 5147.
17 Did you ever make any investigation to 18 determine why nothing had been done following the 19 site problem report in 1977 to correct the temperatures 20 given in the pressurizer system failure procedure 21 for a leaking PORV?
22 A No.
23 Q The site problem report which is 24 Appendix 10 states that the item is for resolution f
( ,) 25 by Mr. Shovlin, page 1392 as marked for litigation.
I
1 Billingoloy 240 2 Do you see that?
f~N L) 3 A Yes.
4 Q Did you have any discussions with I 5 Mr. Shovlin concerning this site problem report?
6 A No, I did not.
7 Q You learned during your investigation 8 that in August 1978 TMI-2 ordered a spare PORV, did 9 you not?
10 hR. GLASSMAN: Can I have that read back?
11 (Question read by the reporter.)
12 A I recall that a spare was ordered. I
- 13 don't recall which unit ordered it.
i
~'/ 14 Would you take a look at page 15 of Q
15 your report. There is a section beginning there
- 16 "4.3.1" titled " Valve Modifications Suggested By 17 Dresser I n d u s t r.. e s . " The section begins "On l
Id August 31, 1978 Metropolitan Edison Company issued l
l 19 Purchase Order number 239715 requesting Dresser l
20 Industries to supply (1) PORV, spare parts, and l
1 21 tools. All items requested in the purchase order l 22 are specified as ' Nuclear Safety Related'."
23 Do you recall looking at that particular 24 purchase order?
3 25 A I reviewed that purchase order, yes.
I
4 1 Billingsley 241 1
( ,/ 2 Q During the course of that, did you 3
understand that that spare was to be used at TMI-27 4 A I don't recall.
Ih 5 Q Your report goes on to state that in 6 late January 1979 Dresser Industries sent a memo to 7 Met Ed detailing improvements made in the valve 8 design.
9 Do you recall finding that out?
10 A I don't recall if I found that out or 11 Mr. Correa found that out.
12 Q You recall learning of that?
n 13 A Sure.
_)
14 Q Did you find out what happened to the 15 memorandum sent by Dresser concerning valve 16 improvements? What did Met Ed do about it?
17 A To the best of my memory, Met Ed didn't 18 do anything concerning those valve modifications to 19 be made in the spare PORV.
20 Q was your understanding that Dresser 21 also suggested that the modifications or at least 22 I believe five out of six of them could be made to 23 the existing PORV at TMI-2?
~
24 A I vaguely remember that.
(S
\. )
25 Q Do you remember finding out what, if
1 BillingolGy 242
('"] 2 anything, Met Ed did as far as possibly incorporating Q,)
3 those suggested modifications on the existing TMI-2 4 PORV7 k 5 MR. GLASSMAN: Can I have that read back?
6 (Question read by the reporter.)
7 MR. GLASSMAN: Objection. There has 8 been no testimony that this is something that 9 Mr. Billingsley looked into.
10 Q If you can answer the question, we'll 11 resolve both the objection and my question.
12 A To the best of my knowledge, nothing 13 was done.
i 4 G 14 Would you look at page 24 of your report.
Q 15 It's page 1304 as marked for litigation. That's 16 Table 1A which purports to list valve problem 17 reports at TMI Unit 2.
18 You prepared this table, I believe?
19 A correct.
20 Q Would you look at that first item listed 21 for August 3, 1978. Yesterday I attempted to read 22 from one of your handwritten notes what I believed 23 to be the same item. Here we have it in typewritten 24 form and it is a bit clearer. It relates to the (q
_) 25 setpoints or certain setpoints modified pursuant to
I Billingolcy 243
,._ 2 equipment change modification 9093 and it reads,
('~')
3 "Since HPI setpoint is 1640 and reactor coolant low 4 pressure trip setpoint is 1900 psig, it will be lll 5 advisable to have the R.C. pressure lo-lo annunciator 6 setpoint moved to 1700 psig because of the apparent 7 advantage of forewarning about ES FAS actuation."
8 ES FAS is emergency safeguards features 9 actuation systems is that right?
10 A I don't recall exactly the acronym.
11 Q It refers generally to the emergency 12 safeguard systems; is that right?
13 A Yes.
p
-' 14 HPI was part of that system; is that Q
15 correct?
16 A Yes.
17 Q Does seeing this in your report help 18 refresh your recollection as to what this equipment 19 change modification had to do with the pilot operated l
20 relief valve?
l l 21 A Without sitting down and carefully
- 22 reviewing this, it would only be speculation on my 1
23 part, l
24 Q Where can I find a copy of equipment l
rm 25 (v ) change modification of 90937 i
1 Billingoley 244 2 A It's not in this report?
3 Q I am afraid not.
4 A I am surprised.
llI 5 Q I would very much like to see it.
6 A I know you would. That's disappointing, 7 that's not in there. I must be quite honest with 8 you. It could possibly be in my files but I don't 9 know why it is not here. By any chance, did you 10 look at any of these documents to see if it's in 11 there?
12 Q I went through them. I am not an expert, 13 but I must say that I was not able to find anything
('N
)
\
14 that looked like that.
15 A I could find it at Three Mile Island 16 probably. As a matter of fact, B&W might even have 17 a copy of this. I say that sincerely.
18 Q Why do you say that?
19 A Because it's an engineering change 20 modification. It's possible that B&W may have that.
21 Q You have no recollection of what event 22 prompted the change modification?
23 A No.
24 Q The documents in Appendices 4 and 5 25 which begin at page 1345 came from Met Ed files; is
[a\
v 1 Billingsley 245
^' 2 that correct?
(\v)'
3 A correct.
4 Q Is that true also for the documents in llI 5 Appendix 6?
6 A Appendix 6.
7 Q Page 1354 and 1355, that's the purchase 8 order for the work done in 1976?
9 A Yes. 1355 came from Met Ed files.
10 Q Would you look at Appendix 8 which is 11 on page 1360 and the documents that appear as part 12 of that appendices. Did they come from Met Ed files?
13 A Yes, they did.
rN
( !
N/
14 Q Would you look at Appendix 9, the documents 15 that are contained as part of that. Did they come 16 from Met Ed files?
I 17 A Yes.
18 Q Next would you look at Appendix 10 which l
l 19 is the site problem report that we referred to 20 earlier. That came from Met Ed's files; is that l
21 correct?
22 A Yes, it did.
23 MR. WISE: Let's take our lunch break.
24 (Luncheon recess taken at 1:40 o' clock P.M.)
(-'r E-] 25 l
1 Billingoloy 346
['N 2 AFT E RNOON S ES S I O N NY 3 (2:43 o' clock P.M.)
4 QU I N CY B I LL IN GS LEY , I I I ,
I 5 having been previously duly sworn, resumed, 6 and continued to testify as follows:
7 EXAMINATION (continued) 8 BY MR. WISE:
9 Q Mr. Billingsley, did you ever become 10 aware that a task force had been formed to investigate 11 the TMI-2 accident that is internal task force 12 within GPU Service?
,- 13 A I understand that such a task force did
'w) 14 exist.
15 Q Did that involve Mr. Keaten, Mr. Long 16 and others?
17 A Yes.
18 Q Did you in any way participate in the 19 activities of that task force?
20 A My understanding is that the TDR's I 21 wrote were a consequence of that task force, yes.
22 Q Let me ask you to refer to B&W 456 which 23 is a copy of the TDR-160 on PORV history and 24 investigation. Take a look at the very last page
(-
(_) 25 of that exhibit which is Appendix 12.
1 Billingolcy 247
(,) 2 Do you recognize what that is?
3 A Yes, I do.
4 Q What is it?
5 A That is basically my charter for my 6 TDR-160.
7 Q Do you know where that page came from?
8 A I don't recall who made that page up -- who 9 made this charter up, I don't recall.
10 Q Do you remember if it was part of a 11 larger document?
12 A I can't recall.
r'^ 13 Q Let me show you what has previously (w/ )
14 been marked as B&W 340. B&W Exhibit 340 consists of 15 a cover memorandum dated July 26, 1979 from 16 Mr. Keaten to Mr. Arnold concerning the investigators' 17 plan of action. Attached to it is an outline which 18 we have identified earlier as the draft plan of 19 action for the investigators. If you will look at 20 the -- it's about four pages from the back under 21 task force PORV failure, mode team Long and Keaten.
22 A Yes.
23 Q Do you recognize that as being the page 24 at which ends up as Appendix 12 to your TDR-160 of
,z- s
', j 25 B&W 4567
Billingsley s 248 1
MR. GLAS? MAN: Objection. Are you
( ) 2
%J 3
asking the witness to compare these two 4
documents now or are you asking him whether 5
he knows whether the page appended as Appendix 6 12 to B&W 456 in fact came from a larger 7 document identified as 3407 I
8 MR. WISE: I thought I was asking 9 <
him whether he recognizes this particular page 10 as the page which occurs at'che end of his 11 TDR.
12 MR. GLASSMAN: Again the question is
(~'s, 13 confusing because we can all sit here and C/
14 read it and find out whether it's identical 15 or not.
16 MR. WISE: I am not asking whether it's 17 identical. I am asking whether seeing it here 18 as part of B&W Exhibit 340 he is able to tell us this is in fact where the last page of TDR -160 19 came from. We can see it's identical. It's 20 21 a visual exercise.
9 22 A I don't know for sure. .s I
23 Q You don't remember seeing 340 as a whole?
24 A No.
p]
\
x- 25 Where did-you obtain your copy of what Q
1 1 Billingoloy 249 9
(~; 2 became Appendix 12 to your TDR?
N.,)
3 A I don't recall.
, e 4 Q Did Mr. Long give that to you?
5 A I don't recall.
/
I' 6 Q You will note question f under subtask I,
/ 7 1 reads, "What was the leak rate prior to the 8 accident? Was the ' unidentified' leakage outside 9 of tech specs, and if so, why?"
10 You can look at either of them. It's 11 identical in both copies.
12 MR. GLASSMAN: I think it's inappropriate m 13 in terms of the question that he look at this f 3 N-] 14 one or the one attached to 456.
15 MR. WISE: Look at that one, if it makes 16 a difference.
17 A What's the question?
18 Item f, under number 1, did you consider Q
19 that part of your charter for work that you were to 20 perform in preparing TDR-1607 .
21 A Yes.
22 Q Did you ever do anything to get answers 23 to those questions?
24 A It was not necessary.
/^\
(_,) 25 Q Why was it not necessary?
1 Billingsloy 250 ,
1
/3
( ) 2 A Because the answer to that was addressed 3 in TDR-126.
4 Q Is it your understanding that TDR-126 5 contains a conclusion concerning whether the 6 unidentified leakage was outside the tech specs?
7 A Repeat that question again, please.
8 Q Is it now your understanding that TDR-126 9 contains a conclusion regarding whether the 10 unidentified leakage was outside the tech specs and 11 if so, why?
12 A Yes.
13 Q Let me show you B&W Exhibit 428 which f~')
v 14 is a copy of TDR-126.
15 would you take a look in there and tell 16 me where it addresses that subject?
17 A On page 1b of TDR-126 under section 18 "III. Conclusions," item 1, "The PORV was not leaking 19 prior to March 28, 1979."
20 Q You believe that answered the question 21 whether unidentified leakage was occurring at 22 TMI-2 outside the tech specs?
23 A Yes.
24 0 You thought that question referred only 7
\ !
25 to the PORV7
1 Billingsley 251 m
2 A Yes, correct.
- k. )
3 Q Are you aware that there were grand jury 4 proceedings instituted in Pennsylvania concerning h 5 the leak rate at TMI-2 before the March 28 accident?
6 A No.
7 Q You never heard of that up to this day?
8 A That's correct.
9 Q Did you participate in the writing of 10 any of the reports prepared by the investigators?
11 A The question is unclear to me.
12 Q You are aware that the investigators A eventually 13 which include Mr. Keaten and Mr. Long (v) 14 wrote some reports; are you not?
15 A vaguely familiar.
16 Q W e h av e identified in prior depositions 17 various drafts of the reports that were prepared IO batween September 1979 and the final copy of the 19 report issued in late 1980.
20 Did you participate in the drafting, 21 review or editing of those drafts of the report or j 22 the final report?
23 A No. I only wrote TDR-160 and TDR-118.
24 Q Let me show you B&W Exhibit 352 previously g~
t J
25 marked -- before we go to the task force report let
1 Billingsley 252
/^N
'- 2 me ask one additional question, 3 Do you recall reviewing Mr. Stubbs' 4 memorandum concerning unidentified leakage?
5 A I don't recall reviewing that memo.
6 Q Let me show you what's been previously 7 marked as B&W 352 which is one of the drafts of the 8 investigators' interim summary report. This particular 9 one is dated November 28, 1979.
10 I would ask you to turn to page 20 of 11 the report. You will see a section which begins on 12 that page labeled D, the pressurizer relief valve (7
(_,) 13 failure mode. The section continues through page 14 20 and on to page 21.
15 Would you take a brief look at that and 16 tell us if you had any hand in the drafting or 17 editing of that section of the draft task force 18 report?
19 A No, I did not.
20 Q Do you know who did?
21 A No, I do not.
22 Q Did you participate in the drafting of 23 any predecessor section similar to this for the task force report?
(~}
\ j 24 25 A No, I did not.
l l
Billingsley 253 I
o t 2 Q Let me show you the final copy of the iJ 3
task force report which has been marked B&W Exhibit 4 356. I should say this is the final summary report 5 dated December 15, 1980.
6 Would you take a look at page 24 of that Again there is a section labeled D, 7 report.
8 pressurizer relief valve failure mode. It begins 9 on that page and carries over on to page 25.
10 Do you see that?
11 A Yes.
12 Q I will not waste your time now by having 13 you compare this section with the section I showed
()
G you earlier from B&W Exhibit 352. I will represent 14 15 that I have compared the two and they are quite 16 different.
17 Do you know who drafted or edited the 18 section that appears on B&W Exhibit 356?
19 A No, I do not.
l 20 Q Did you have any hand in that?
21 A No, I did not.
22 Q Would you look at the chart that appears 23 on the following page, page 25 of 356, there is a 24 table there labeled " Table 3, Stuck Open PORV's in p
'- ' ' 25 PWR's." Did you have any hand in the preparation of
1 Billingcicy 254
_/ 2 that table?
3 A No.
4 Q Did you send any information to anyone I 5 for the purpose of having that chart prepared, to 6 your knowledge?
7 A Did I send any information to anyone?
8 Q Yes.
9 A That's signed on the front of B&W Exhibit 10 356?
11 Q Yes.
12 A I did personally not provide this report A
13 to any of the parties listed on 356.
(_)
14 Q You have no knowledge as to the source 15 presented in the chart on page 25 was?
16 A I only have speculation as to where the 17 source --
18 I don't want your speculation. Do you Q
19 .have any knowledge gained from any source as to where 20 that information came from?
21 A No.
22 Q Did you ever receive a copy of the GPU 23 Accident Review Task Force summary report?
24 A Never.
(']
'w/
25 Q Did you ever receive a copy of the
1 Billingglsy 255 77 2 interim report which I believe was issued in i )
x_-
3 December 1979?
4 A No, I did not.
9 5 Q I believe at the beginning of your 6 deposition you mentioned that you also performed 7 work on a study of make-up pump operation and during 8 the accident; is that correct?
9 A That's right.
10 MR. WISE: I would like to have marked 11 as B&W's next exhibit, I believe it is B&W 12 Exhibit 457, a copy of some handwritten
(~] 13 notes, perhaps a handwritten draft, titled
\/
14 " Things That Still Must Be Added to the 15 Report." Attached to that is what appears to 16 be a handwritten draft of certain portions 17 of what we'll later have marked as an exhibit, 18 a copy of TDR-118.
19 (Handwritten notes titled " Things That 20 Still Must be Added to the Report" marked 21 B&W Exhibit 457 for identification, as of 22 this date.)
23 Q Do you recognize B&W Exhibit 4577 l _
24 A Yes, I do.
)
' 25 Q There are at least two sets of handwritings 1
[
l
I Billingelcy. 256 A
(,,) 2 throughout the exhibit.
3 Do you recognize one of those sets of 4 handwritings as being yours?
O 5 A Yes.
6 Q In whose handwriting are the other 7 comments; are those Mr. Long's comments?
8 A' I believe so.
9 Q Do you recall preparing a draft report 10 on your study of make-up pump operation?
11 A Yes.
12 Q Is this a copy of your first draft of 13 that report?
(V) 14 A Yes.
15 Q Did you submit it to Mr. Long?
16 A Yes, I did.
17 Q Did you receive comments from him?
18 A Yes, I did.
l l 19 Q In fact these are the comments that he 20 gave you, those marked in the heavy dark writing?
l 21 A I believe so.
22 Q Would you look now at the cover page 23 titled " Things That Still Must Be Added to the 24 Report." Mr. Long's comment at the bottom has an
(~'N
\, ,l arrow referring to item 3 on the list of things that 25 l
\
Dillingoloy 257 1
'N / 2 still needed to be done. Do you see that?
3 A Yes.
4 Q Item 3 as you wrote it, " design change 9 5 must be elaborated on."
6 What design change were you discussing 7 there?
~
8 A I don't recall.
9 Q You had found, had you not, that the 10 wiring to the computer in the control room at TMI 11 had been changed at some point with respect to the 12 indications of pump operation, make-up pump operation?
13 A Are you asking me a question?
k_s) 14 Q Yes. You had found that, had you not?
15 A Without reading this report, I am not 16 qualified to make a yes or no statement.
17 MR. WISE: Let's mark the report and 18 see if we can get this clarified. We'll have 19 it marked as B&W Exhibit 458, 20 (Copy of draft TDR titled "TMI-2 21 Make-Up Pump Operation" marked B&W Exhibit 22 458 for identification, as of this date.)
23 Q You have seen B&W Exhibit 458 before, 24 haven't you?
(~N i s N ,/
25 A Yes, I have.
l
Billingsicy 258 1
Is that a copy of the final report that
(
\_) 2 Q i
3 you prepared as a result of your study of make-up 4 pump operation during the accident?
A No, this is only a draft.
5 6 Q Was there ever a final report prepared?
7 A Yes.
8 one that you signed?
.Q 9 A Yes.
MR. WISE: For whatever reasons, we do 10 11 not seem to have a copy of the signed report.
or if it 12 Either it hasn't been produced to us haven' t been able to find it.
~
/N 13 has, we ls_ /
14 MR. GLASSMAN: Off the record.
15 (Discussion off the record.)
There is an indication that 16 MR. WISE:
counsel for both parties are not aware of a 17 18 signed report.
19 Q You have a recollection of signing one?
20 A Yes. .
Q What did you do with it?
21 A
Should have been in everything I turned 22 it. TDR-118.
23 over. I believe it had a TDR number on Q
Let's work from the draft, B&W Exhibit 24
{~N) x ,/
25 458 seeing that seems to be the latest copy that we
Sillingoley 259 1
[^T have here today.
(J~
2 You recognize this as one of the drafts 3
4 of the report?
A Yes.
5 6 Q Would you take a look at page 4 of this "3.2 computer 7 draft, you will see a section labeled 8 Input Electrical Modification."
Do you see that?
9 10 A Yes.
to the next page, 11 Q It continues over on 12 page 5.
, would you briefly look at that and see 13
(_)
14 if it helps refresh your recollection that you discovered during the course of your investigation 15 16 that a design change had been performed with respect 17 to the wiring to the control room computer for 18 indication of make-up pump operation?
19 A This does refresh my memory.
20 Q Is that the design change you were 21 referring to in the item 3 cn B&W Exhibit 457, your 22 list of things that still needed to be added to the 23 report?
A I believe so, yes,
( 24
\_
25 Q Now would you look at Mr. Long's note
~~
260 Billingsley 1
g~3 N-] item. It reads 2
with an arrow pointing to that section. Should describe 3
"This needs a separate 4
reasons for ' design' change - when change was there was wiring 5 done - when it was discovered that 6 error - by whom? When corrective action was 7
taken - if not done (as you have told me) this should 8 also be stated (diplomatically)."
s with Do you recall having discussion 9
no correction 10 Mr. Long where you informed him that 11 to the wiring error had been made?
MR. GLASSMAN: Could I hear it back?
12
(]
v- Let me withdraw it and lay 13 MR. WISE:
14 some foundation for it.
What is the wiring error referred to in 15 Q Mr. Long's note?
You may want to refer to B&W 16 to refresh your recollection.
17 Exhibit 458, if it helps MR. GLASSMAN:
objection again in terms 18 Maybe 19 of what something is in Mr. Long's note.
to tell you Mr. Long is in a better position 20 21 what was in his mind.
A better question is what, if anything, 22 23 Mr. Billingsley understood as to this note.
f} MR. WISE:
That's fair enough.
~~ 24 report I can't recall simply because my 25 l A
Dillingsley 261 1
g) 2 discusses two change modifications because I don't i
Lj 3 know which one item number 3 of B&W 457 that this 4 refers to.
9 5 Q Did you become aware during your 6 investigation that as a result of a wiring error the 7 printout from the computer with respect to make-up 8 pump operation was casued to be in reverse, that 9 is the printout tripped when it should have been 10 operating and vice versa?
11 A I believe that was the case.
Do you remember discussing that error 12 Q
('s O
13 with Mr. Long at any point?
14 g yes, 15 Q Did you tell him that there was a wiring 16 error that resulted in that reversal?
17 A I believe so.
IE Q Did vou ever discover that corrective 19 action has been taken as to that wiring error before 20 the accident? t 21 A No.
22 Q How long before the accident did you 23 find that wiring error had existed?
24 MR. GLASSMAN: The question is, I assume,
[~'\/
during the course of Mr. Billingsley's work
-- 25 I
il
Billingsley 262 1
after the accident, what period of time did
(^x 2 3
his investigation show with regard to a prior 4 wiring error?
MR. WISE: I will break it down.
5 6 Q As a result of your investigation, were 7 you ever able to learn when the wiring error occurred?
8 A I don't recall.
9 Q Take a look at page 5 of the draft of 10 your TDR which we have marked as B&W Exhibit 458, you 11 will see a section there titled "3.2.1 30T Contract,"
12 I believe that should be contact, "/not part of
, ~s 13 Change Modification number 2-0126."
l I LJ Do you see that?
14 15 A Yes.
It reads, "The discussion in 3.2 above 16 Q 17 dealt with the wiring change in one of the two 18 30T contacts. For the purpose of disclosing a major 19 problem area, the remaining 30T contact will be 20 addressed at this time. As stated in Section 3.1.1, 21 Input Data, the 30T contact is wired in reverse.
22 The consequence of this error (reverse wiring) is 23 that pump status, as printed by the computer, will 24 be reversed."
l 25 You then give an example of the result t
ll
Billingsley 263 1
~
2 of that and continue, "On May 25, 1979, the TMI-2
('w ')\,
3 Computer Engineer Supervisor checked those MPX 4 points (3172, 3173, 3174) associated with the 30T 9 5 contact and verified that the computer is receiving 6 erroneous information due to a wiring error. As 7 of this writing the error has not been rectified."
8 Does reviewing this help refresh your
-- design 9 recollection as to which of the modifications 10 modifications was involved in the possible wiring 11 error or in the wiring error that occurred?
12 A Based on this writing in section
("3 13 3.2.1 of B&W Exhibit 458 this section does not i f N._/
14 address any of the design modifications.
15 g section 3.2 discusses two modifications, 16 is that right?
17 A Right.
18 Q One on October 5, 1978 and one on 19 March 27, 1979. Do you see that?
20 A Yes.
21 Q Am I correct that neither of those two g
22 modifications involved work on the so-called 30T 23 contact which was the -- which was responsible for 24 the reversal in the indication shown on the
,/
'J 25 printout for make-up pump operation?
Billingsley 264 1
. ~ .
(_,,I 2 MR, GLASSMAN: Could I have that read 3 back?
4 (Question read by the reporter.)
MR. GLASSMAN: Perhaps I an confused as 5
6 to the question, but I don't see particular 7
dates involved in the particular page here and 8 maybe counsel is reading from a different 9 page.
10 MR. WISE: I am referring to page 4 of 11 the draft which has a section entitled 3.2.
MR. GLASSMAN: I see the problem. Pages 12
/~N 4 and 5 are reversed in my copy. That's why 13 s , )
14 I had some confusion with counsel's question.
15 MR. WISE: 3.2 discusses two modifications, 16 one in October '78 and the one the day before 17 the accident in 1979.
l 18 If I am reading this properly, neither of 19 those two modifications, Mr. Billingsley says 20 in his paper, involve changes to the particular 21 contact that was responsible for the reversal 22 in the indications shown on the printout for 23 make-up pump operation.
g My question is: Is tha* correct,
,e 24
'a 25 Mr. Billingsley?
I Dillingsley 265 1
2 A That's correct.
(v) 3 Q Did you ever find out when the wiring 4 error did occur?
9 5 A No.
6 Q Consequently you have no idea for how 7 long it existed prior to the accident on March 28, 8 19797 9 A No.
10 Q Did you ever interview anyone to 11 determine whether any of the operators or operating 12 staff was aware of the reversal in indications
[~') 13 before the accident?
%.J J 14 A No.
15 Q Did you ever come to learn whether anyone 16 else had ever determined that from the operating 17 staff?
18 A yo, 19 Q Am I correct that as a result of this 20 wiring error that an operator looking at the 21 computer printout was told a pump was off when in g
22 fact it was on?
MR. GLASSMAN: Objection. The witness 23 24 cannot testify as to what an operator would 7.
Y., 25 or wouldn't be told. It's totally misicading.
1
Billingoley 266 1
2 We don't even know if an operator looks at (S
\vl these things, when he looks at these things.
3 4 Mr. Billingsley is in a totally different 5 position. It's a speculative question.
6 If you would like to find out the result 7 of Mr. Billingsley's investigation, that's 8 fine. To have him indicate what operators 9 would have seen, might have seen, when he 10 didn't talk to them about this, is inappropriate.
11 MR. WISE: Let's ask a few prefatory 12 questions then.
13 Q I take it that the investigation that 73
( )
14 you made involved looking at what instruments 15 printed out the status of the make-up pump in the 16 control room?
17 A No.
18 Q What did you investigate?
19 A My original charter was to investigate 20 when the make-up pumps were put into operation 21 either in manual or in automatic, determine when 22 the pumps were operating and at what times.
23 Q Did you ever find out whether any 24 instrumentation at all was provided at TMI with rr
( ,) 25 respect to the status of the make-up pumps?
e
Billingalsy 267 l 1
2 A Yes, there is a printer that prints out (s) s-3 the computer data which I analyzed.
4 Q Where is that printer located?
5 A I don't recall.
6 Q Is it located somewhere at TMI-27 7 A Yes.
8 Q In the control room?
9 A I don't recall.
10 Q What is that printer hooked up to?
11 A I can only assume based on my past 12 experience with computers and printers.
13 Q You mean in your investigation you (T
V 14 never bothered to find out where all these contacts 15 that you mentioned at length in your report were 16 located?
17 A That was not necessarily for the purpose 18 of my investigation.
19 Q Whether it was necessarily or not you 20 found out about it, didn't you, Mr. Billingsley? .
21 A Yes, I did.
22 Q Would you look at page 3 of your draft 23 report. You see the chart there, box diagram, flow 24 chart, whatever you want to call it. See where it
(\
(
'w /-
l 25 shows the computer, electrical circuit, pumps, input,
1 Dillingsloy 268 ,
/m\ 2 output, printer, input.
'% )
3 You did find out where that printer was 4 hooted up, didn't you?
O 5 A No.
6 Q You are telling me -- who draftec this 7 A I did.
8 Q You were the one who wrote the box that 9 says computer with an arrow pointing to the printer?
10 A Yes.
11 Q You made that up out of whole cloth?
12 A No.
13 Q Is that fantasy?
(~})
t
'm d 14 A That's based on my common knowledge of 15 computers and printers.
16 Q Common knowledge, you never bothered 17 to find out if this was in fact the case at TMI-27 18 A Physically looking at that, no, I did 19 not.
20 Q I am not asking if you yhysically looked 21 at it.
22 A That's the only way I could really come 23 to conclusion.
24 Q We have run into a problem we have run
/^'s I thought we went
(_) 25 into with several witnesses.
Billingsley 269 1
,~
I am not limiting my 2 through this yesterday.
(_)
3 question as to what you personally went and looked 4 at yourself. I am entitled to get the basis of 9 5 your knowledge even if you obtained it from sources 6 other than going to look at something with your 7 own eyes and feeling it with your own hands.
8 Did you talk to anybody or get information 9 from anyone or any source whatsoever indicating to 10 you that the printer whose output you were looking 11 at in connection with your investigation was hooked 12 up to a computer at TMI-27 MR. GLASSMAN: We are talking about aside (v ') 13 14 from the answer that Mr. Billingsley gave 15 earlier?
16 MR. WISE: I don't recall --
17 MR. GLASSMAN: He gave some information 18 about general knowledge but not the particular 19 equipment at TMI. The question is whether he 20 talked to anyone else about the equipment at 21 TMI, particularly?
22 MR. WISE: Yes.
23 A Are you asking me how I ran my investigation?
24 Q Yes.
,-ss
._/
25 A The way I ran my investigation was that
Billingeley 270 1
l 2 I initially started out with the computer printout 3
of the make-up pump operation during the March 28, 4 1979 accident. Upon a close investigation of 5 that computer printout, it came to my knowledge 6 that there was some discrepancies in what I had 7
earlier learned either through verbal investigation 8 and/or through various reports which had earlier 9 reported make-up pump operation on the date of the 10 accident.
11 Due to the discrepancies in various 12 information that I had gotten a hold of, I determined that it was quite necessary to obtain
()
w/
13 14 an electrical schematic of the contacts which 15 inputted to the computer and naturally a computer l
16 must print out, must provide an input to something 17 to provide physical hard core data which was the 18 printer.
19 As part of my investigation, it was not 20 necessary that I verify the position of computer .
21 printer. It was only necessary that I determine where the computer obtained its inputs. It was not 22 23 necessary that I determine exactly what piece of equipt .nt known as a computer -- known as a printer 24
( )
25 and know where that printer was located to evaluate
Billingsley 271 1
,-~\
2 the results of that computer printout.
(
%.]
3 so upon analyzing the electrical circuit, 4
I was able to determine what discrepant data the computer would print out. I analyzed the results k 5 6 which is the hard core printout and I analyzed the 7 input to the computer.
8 Q Did you ever make an analysis of whatever 9 information was available to the operator?
10 A No.
11 Q Would you look at your report which you 12 wrote at page 5. Take a look at section 3.3 which 13 begins 'there "Information Available to the Operator."
("])
L.,
14 Did you write that?
15 A Yes.
16 Q Did you make it up?
l 17 A No.
18 Q Is it still your testimony that you made l 19 no investigation of what information was made 20 available to the operator?
21 A Upon seeing page 5 of B&W Exhibit 458, 9 22 my memory is refreshed that I did get information 23 as to the operators.
24 Q As part of your investigation?
(\
! v 25 A Yes.
l l
Billingsley 272 1
4 2 Q You found out that the printer we have
[ )
LJ 3
been talking about was in the control room available 4 to the operators?
lk 5 MR. GLASSMAN: You are asking the witness 6 whether that particular paragraph which we 7 have ref erred the witness to refreshes his 8 recollection?
9 MR. WISE: I am asking what happened.
10 If he has a recollection from another source, 11 I would like to know that, too. We have 12 wasted a lot of time.
I 13 MR. GLASSMAN: We have not wasted a lot 14 of time. You have asked the witness without 15 showing a particular paragraph he didn't recall.
16 If you had shown him the paragraph to begin 17 with, maybe we would have saved some time.
18 MR. WISE: I am shocked that someone 19 doesn't know that the printer on the computer It's 20 is located on the control room of TMI-2.
i 21 taken a long time to establish what I think 22 most people have conceded as a very well known 23 fact.
24 MR. GLASSMAN: I am shocked at your i
,O I
kJ
\
25 statement here. I assume there are a lot of
Billingsley 273 1
( ,
\m / 2 people who don't know where things are located.
3 It was not something I was familiar with 4 earlier and not even familiar with at this particular point in time. I couldn't testify hI 5 6 on it. I doubt other people in this room 7 could have testified to it. I don't know 8 why you are beating on this witness because 9 he doesn't have a recollection. ,,
10 MR. WISE: Because GPU assigned him to investigate this point. He wrote a report. He 11 12 is now telling me that he doesn't know where the printer was located.
O() 13 14 MR. GLASSMAN: The document in front of 15 him was written sometime ago. If you would 16 like to save time, you should have shown him 17 the report and found out what it meant rather 18 than trying to lead up to it and just prolong 19 the deposition.
20 A Your question again, please?
21 (Question read by the reporter.)
22 A Yes, this information in Appendix 4 was 23 available -- let me put it this way: This information
[~]
L) 24 is in the control room.
25 Q What computer did you find the printer
1 Billingsley 274
,n
( ,)
s 2 was hooked up to? You testified earlier that you 3 looked at the electrical diagrams with respect to 4 it. It showed that there was a computer involved.
lll 5 A To the best of my knowledge there is only 6 one computer at TMI. That's hooked up to that 7 computer. The location of that computer, I don't 8 recall.
9 Q What is that computer used for?
10 A I don't know all the applications of that 11 computer.
12 Q Did you ever find out whether one of its (o) m/
13 uses was to provide data on plant parameters to 14 the operators in the control room?
15 A I know it provided this information.
16 Q As a result of your investigation were 17 you able to conclude that on the day of the accident 18 the printout that the computer was generating showed 19 the status of the make-up pumps in exact reverse of 20 what their actual status was?
21 A Yes.
22 Q Make-up pumps are the same physical 23 pumps that are sometimes referred to as the HPI 24 pumps; is that right?
7-s NJ 25 correct.
A
Billingsley 275 1
2 Q Is it true that when they were operating 3 the HPI mode their status would be shown in reverse?
MR. GLASSMAN: You are asking the witness 4
jh 5 to speculate --
6 Q Based on the investigation you made 7 following the accident.
8 A Correct.
9 Q Did you ever interview any of the 10 operators who were on duty on the day of the 11 accident to determine whether or not they were aware 12 th a t the printout was showing the pump status in 13 exact reverse of its actual condition?
V 14 A I don't recall whether I asked that.
15 Q Do you know whether anyone else did?
16 A No, I don't.
17 Q Did you ever make any investigation 18 to determine when the fact that the printout was 19 showing the pump status in exact reverse of its 20 actual condition was first discovered by anyone?
21 A To the best of my knowledge this is the 22 first time it was ever discovered.
23 Q That is when you made your investigation?
24 A correct.
['T
,) 25 Q You are not aware of any corrective action
1 Billings 1sy 276
<3 2 that had been taken at Met Ed before the March 28 (y ,/ )
3 accident to attempt to correct the error?
4 A Correct.
MR. GLASSMAN: I should note for the (jll 5 6 record that it's rather difficult for one to 7 answer the question differently if someone 8 didn't discover it until later on. It's rather 9 hard to do something until later on.
10 Q Let me ask you for a moment about alarms.
11 Am I correct that there is also located 12 in the control room something called an alarm 13 printer?
^ ~,!
14 A I have heard that word alarm printer 15 used. I am not sure at this point in time whether 16 it's a different printer or not.
17 Q Did you become aware that there was l 18 data available for the March 28 accident which 19 came from the so-called alarm printer?
l l
20 A I vaguely remember that, yes.
21 Q You saw some of that data?
O 22 A I can't say for sure.
23 Q Did you make an investigation to determine 24 which alarms would result in a notation on the
(~h 25 alarm printer? In particular I would ask you to
(_)
i Billingsley 277 !
1 l
2 refer to your section 3.3 at page 5 of your report ;
(~T l
(_/ and the various items shown in the appendix of TMI l 3
4 Unit 2, Appendix 4 which begins at page 4064 as marked for purposes of this litigation. You will note ill 5 6 that you have a ceries of pages each one appears to 7
describe a particular alarm related to the make-up 8 pump.
9 For instance, the first one is make-up 10 pump motor coolant flow lo and the second one talks 11 about make-up pump discharge pressure lo and so on.
12 Do you see that? ,
13 A Yes.
14 Q Do you know what those sheets are?
15 A Yes, this is a manual kept in the control 16 room which discusses the alarm panels.
17 Q Where did you get a copy of that manual 18 from?
19 A Came from the control room.
20 Q How did you get your hand on it?
21 A I went to the control room.
O 22 Q While you were there, did you notice 23 there was a printer in the room?
24 A I may have.
25 Q It's pretty hard to miss, isn't it,
I Billingsley 278 l 1
2 Mr. Billingsley?
MR. GLASSMAN: Wait a second. If you 3
i 4 were there, maybe you would like to be a witness.
5 We'll be glad to call you.
l(-
6 Q Looking at the sheets'which are part of 7 Appendix 4, did you collect all of the sheets that 8 you could find that describe alarms that were 9 related to the maxe-up pump operation?
10 A Yes, I did.
11 Q Did you include them all as part of this
- 12 appendix?
13 A I believe so.
14 Q Did you ever determine where these alarms 15 would print out, the ones described in Appendix 4?
16 A I don't recall.
l 17 Q Do you recall learning whether or not l
! 18 any of these alarms would be sent in for the 19 actuation of HPI?
MR. GLASSMAN: Could I hear that again?
20 l
MR. WISE: Let me rephrase it. I will 21 O 22 withdraw it.
I 23 Q Do you recall finding out whether or l
24 not there was any alarm that would print out on the 1 25 alarm printer as a result of. actuation of HPI on an
1 Billingeley 279 7"'s 2 emergency safeguard signal?
f )
v 3 A You asked me if anything of these were 4 printout?
No, I am asking as a result of your lll 5 Q 6 investigation, you ever determined whether an 7 actuation of HPI on emergency safeguard signal would 8 result in an alarm being put on the alarm printer?
9 A I don't recall if there was an alarm 10 that went on as a consequence of that.
11 Q One of the purpos es of your investigation 12 was to find out as described in Section 3.3 what
,y 13 sources of information the operator had as to the
\_ condition and status of the make-up pt!mp and whether 14 15 or not they were operating.
16 Could you find out if they could tell 17 the status of the make-up pumps by looking at the 18 alarm printouts?
19 MR. GLASSMAN: The question is not 20 directed whether or not the operator actually 21 saw something or determined something but O 22 whether there was some equipnent in the 23 control room to that effect?
24 MR. WISE: That's right. In other words, r^s
(_) 25 whether based on your investigation you were
1 Billingslay 280
('N 2 able to determine the fact that an operator b could not tell anything as to the status or 3
4 the operation of the make-up pumps by looking at the alarm printer.
lll 5 6 A I am thoroughly confused. Are you asking 7 me if -- Appendix 4, alarm printout?
8 Q That's a good start.
9 A To the best of my knowledge these do not 10 print out.
11 Q what are they?
12 A These are panel alarms. That does not 13 necessarily imply printing out.
,y
( )
w/ Did you find out whether there was any 14 Q 15 log or list of the alarms that would result in a 16 printout?
17 A No, I did not. Not to the best of my 18 knowledge.
19 Q Was there any panel indicator or alarm 1
20 that would show the status or condition of the 21 make-up pumps as to their operation?
22 A Yes, there are panel alarms that would l
23 show status and condition.
24 Q Would those panel alarms show whether (s. ,,I 25 or not the pump was operating in an HPI mode?
f Billingsley 281 I
2 A I don't recall.
(~]
N_/
3 Q As a result of your investigation, what 4 indications would an operator in the control room 5
have of whether or not the pumps were operating in
, l) 6 an HPI mode?
7 A I don't recall there ever being anything 8 to the best of my knowledge that stated that the 9 pump was in an HPI mode.
10 Q Could you get that off the computer 11 printer?
MR. GLASSMAN: You are asking him to 12 13 speculate?
(x s._/
)
MR. WISE: I am asking if he learned one 14 15 of the things that could happen before the 16 accident is that the operator could get the i
17 printout of the computer which would show 18 whether or not the pump was operating in an 19 HPI mode.
20 A Not to the best of my knowledge.
l 21 Q If I understand your report properly, and 22 I may not, printout that you discuss at length in your report would show various conditions for the 23 1
24 make-up pumps; is that right?
'(m,- 25 A What do you mean by various conditions, i
I
Billingalsy 282 1
("N 2 whether it was on or off?
(_
3 Q It would show more than on and off.
4 A Problems with the hearing temperatures, 5 things of that sort?
]g 6 Q Let's take a look at Section 4 of your 7 report which begins on page 7. You will note there 8 that you have a section covering manual pump start.
9 A Yes.
I' 10 Q You have a section covering attempted 11 manual start.
12 A Yes.
13 Q And on page 9 you have an example of 14 some of the printouts that might be seen as a 15 consequence of that such as failed start, second 16 start, successful start.
17 A Sure.
Those are examples of printouts that 18 Q 19 were available to the operators by using the computer; 20 is that right? .
Objection. The question 21 MR. GLASSMAN:
6 22 is now what is available to the operators. I 23 don't know what you mean by available.
24 Something that's physically in the control room that's one thing. The question is unclear.
) 25
1 Billingsley 283 2 MR. WISE: I never understood that
(~'}
\._ ,/
3 objection. It makes no difference to me.
4 Q These are examples of what the printout 5 would show?
ll 6 A Yes.
7 Q This was a printout that was run off 8 the plant computer?
9 A Yes.
10 Q It was the only computer there was?
f 11 A As far as I know, yes.
12 MR. WISE: We'll try to get testimony 13 that that was hooked up to the printer in the
,y N) 14 control, seeing you don't know.
15 MR. GLASSMAN: You are certainly able 16 to examine other witnesses. We have had many 17 witnesses here. We'll cooperate in supplying 18 other witnesses as you request them.
19 Q In fact, these three that are listed on 20 page 9 that these are the various kinds of printouts 21 that would be made from the computer with regard O 22 to the pump operations?
23 A That's correct.
24 Q There in fact are others; is that right,
(~T
\_)
s 25 various other printouts that are associated with?
1 Billingsley 284 2 There are other examples in your report. Next page
(']
'vI 3
there are five different examples or so given there.
4 Do you see those? One under " Automatic Start" on 5 page 10, " Cont 2921."
(l) 6 A Sure.
7 Q There are a couple of others given on 8 that page, right?
9 A Yes.
10 Q With respect to all those indications 11 that you mentioned in your report, do you see them 12 there?
g 13 A Yes.
14 Q What I want to know now is whether or 15 not you ever determined -- whether you determined 16 amongst the various indications that were available 17 through this system, was one that would show the 18 operators whether or not the pumps were operating in 19 the HPI mode?
20 MR. GLASSMAN: I think that was asked 21 and answered.
O 22 MR. WISE: I don't think so.
23 A I have never seen a printout that said 24 the pump was in the HPI mode.
O
(,,)
25 Q You saw a printout that the pump had
~
1 Billingsley 285
.S 2 actuated in the HPI mode?
i l N,/
3 A No.
4 Q Would you look at page 6 of your report, 5 You have a section titled "3.4 Engineered Safety gg) 6 Features /High Pressure Injection."
7 Do you see that?
8 A Yes.
9 Q Beneath that under 3.4.1 you have 10 something called "ES Signal," emergency safeguard 11 signal?
12 A Yes.
.- 13 Q You have an example under " Automatic ES"
\~') of what the printout would show, don't you?
14 15 A Yes.
16 Q "ES actuation A two-thirds logic, emergency 17 inj ection GP1 actuated;"do you see that?
18 A Yes.
19 Q That would show on the printout that 20 there had been an actuation of the HPI in the 21 automatic mode; is that right?
O 22 A It most certainly shows that.
23 Q You did learn that was available through 24 the printout?
(q) 25 A Yes, I did. Thank you for refreshing my
1 Billingalay 286 2 memory.
(~
(N) Q Was it your findings as a result of the 3
4 investigation that this printout would be reversed jg 5 given the wiring error that existed at TMI-2 on 6 March 28, 1979?
7 A I don't believe I ever came across 8 reversing of printouts for the emergency actuation 9 of high pressure injection.
10 Q Would you look at the first example you 11 give there.
12 Did you ever come to an understanding
-s 13 as to what that particular line would indicate on 7 i i
14 the printout, ES actuation A 2/3 logic, emergency 15 injection GP1 Act? What does that indication mean?
16 A I can only tell you generally what that 17 means. It's telling you that your emergency safeguard 18 system has been automatically actuated.
19 Q Do you know what the reference to GP1 is?
20 A No, I don't recall.
f 21 Q There are two sets of indications given, O 22 3 with the letter A and 3 with the letter B. Do you 23 know what A and B refer to?
24 A I don't recall, no.
/^\ Did you ever submit a draft of this report
(_) 25 Q
1 Billingsley 287 2 to Mr. Zewe to get his comments on it?
3 A I don't believe so.
4 Q Do you know whether anybody else did?
5 A Not to the best of my knowledge.
(g) 6 Q Did you ever receive comments from 7 Mr. Zewe?
8 A Not to the best of my knowledge.
9 MR. WISE: Let me have marked as B&W 10 Exhibit 459 a copy of a handwritten note 11 along with just the first page of what appears 12 to be -- cover page for TDR-118.
7- y 13 (Handwritten note with attached copy of t
\ _ >:
14 cover page for TDR-118 marked B&W Exhibit 459 15 for identification, as of this date.)
16 Q Exhibit 459 is a handwritten note from 17 Ed Wallace to GPM. I believe we have identified in 18 previous testimony that Gary P. Miller has those 19 initials. It is dated August 2 and reads, "Please 20 have Zewe plus any others of your staff review this 21 draft. Comments should be sent to Q. Billingsley 9 22 or Bob Long by 8/10. Thanks. Ed Wallace."
23 Did.you ever see a copy of this note 24 or know that Mr. Wallace sent it?
(3
( _) 25 A No.
Billingsley 288 1
(s 2 Q Did you ever receive any comments from N) 3 Mr. Zewe?
4 A Not to the best of my knowledge.
Did you ever receive any comments from qll 5 Q 6 Mr. Long which he identified to you as having come 7 from Mr. Zewe?
8 A No, not to the best of my knowledge.
9 Q Let me now ask you to take a look at 10 B&W Exhibit 458 which is your draft of the TDR and I 11 turn to the first page. Rather, the first page of 12 text.
13 You see you have a section entitled
,S, i :
L) 14 " Abstract"?
15 A Yes.
16 Q And various points are listed under that.
17 I believe there are five points.
18 Taking the first one which reads, " Computer 19 printouts of mak e-up pump (MUP) operation (starts 20 & stops) can be misleading, therefore, an analysis 21 is required of all printouts recording MUP starts O 22 and stops."
23 why did you believe that the computer 24 printouts could be misleading?
O 25 A Because reverse wiring, if the printout
(_,/
1 Billingsley 289
(~'N 2 said stop, I believe that the pumps may have been (j
3 stopped when the computer printed start. When 4 the computer printed start, the pumps had stopped.
g Is that the same explanation for your ll) 5 6 point 2, " Computer printouts having computer 7 multiplexer (MPX) identification numbers 3172 & 3174 8 for MUP MU-P-1A & 1C respectively provide erroneous 9 information"?
10 A I believe so, yes.
11 g Point 4, "MPX point 3173, for MU-P-1B, 12 is not operational." Why was that point not
,ew .,
13 operational?
s_--
14 A I would have to go through the text of l
15 the report to find out. Do you want me to do that?
16 Q We'll come to it in a minute. Let me i
17 go through these points and see if we can learn 18 anything else before going to the specifics. Maybe 19 we should take a look at that.
20 MR. GLASSMAN: Can I take a quick break?
(Recess taken.)
I 21 O 22 BY MR. WISE:
23 Q Before the break we were discussing l
24 B&W Exhibit 458 and in particular I was going l (~h s ,/ 25 through the list of five items contained in your m
l l
l
1 Gillingelc<y 290 abstract at the beginning of the report. I questioned
,< ~s 2 N,)
3 y u about the indication for make-up pump 1B which 4
is the f ot'rth item listed under your abstract and indicates that that particular point was inoperative.
lll 5 6 Would you take a look at page 3 of your 7 report, the very last line in the section under the 8 title "3.1.1 Input Data" reads, "The computer input 9 for MU-P-1B (MPX 3173) is not functional (does not 10 printout) . "
11 Based on my review that's the only 12 mention I see of that point in the entire report.
,s 13 Are you aware of any other point in your report
/
\ ']
'~ where it is discussed?
14 15 A I don't believe so. I don't believe it 16 is discussed any other place.
17 Q Did you ever find out why that point was
{ 18 not functional?
19 A I don't recall.
20 Q Did you find out whether it had been
(
21 functional on the date of the accident?
22 A I don't believe so.
23 Q For how long had it not been functional,
! i 24 to your knowledge, before the accident?
I /7 A I don't know.
) 25 l
l
1 Dillingsley 291 2 Q Did you ever make any investigation to 0 3 determine how long it had been non-functional 4 before the accident?
t 5 A I do not believe so.
fgg 6 Q If I understand your testimony right, you i
- j. 7 don't know why it wasn't functional?
j 8 A No.
9 Q You never found out?
10 A Not to the best of my knowledge.
11 Q What did you find out was the consequence 12 of that point not being functional?
13 A To the best of my knowledge, I don't 14 believe it made any difference whatsoever.
15 Q What is the reason as you found it that 16 it made no difference?
17 A I would have to go back and look at 18 this report in detail. But there are two sets of 19 multiplexer points, MPX points for the make-up l
20 pumps, the 29 series and the 30 series. I don't l
believe it was significant. I would have to go
. 21 9 22 back through this report, however, to take a look, i
23 I will if you would like.
24 Q What is the difference between a 29 25 series and 30 series that you recall?
--ww
Billingalcy 292 I 1 A I believe those are strictly contact
(~ 2
(
gj 3 numbers in the electrical circuit.
4 Q So that if a particular contact in one series was not o, perative, it would make no difference g 5 6 if the contact for that particular indication was 7 operative in the other series; is that what you are 8 saying?
9 A would you repeat that question again, 10 please?
11 (Question read by the reporter.)
12 A I b eliev e that to be the case, however, 13 again, I would have to go back and take a good look (7_
ej
)
14 at the report.
15 Q Let me switch to another topic.
16 would you look at page 5 of your report.
17 under the section labeled "Information Available to 18 the operator."
19 Did you make an investigation as to 20 what information was available to the operator on 21 the morning of the accident?
O 22 A No. It was not relevant to my study.
23 Q would you look at the third paragraph make-up 24 of that section which reads, "At 4:02:38 'B'
() once in the auto stop mode, all 3
l 25 pump auto stopped, i
t_
1 Billingsley 293 F
2 other make-up pump trips ('A' & 'C') pumps would be i
('} /
q./
3 blocked from actuating the panel alarm."
4 Does the indication 4:02:38 refer to a time?
ll) 5 6 A Yes.
7 Q Refers to a morning, to a time on the 8 morning of March 28, 1979, does it not?
9 A I would have to recall and I can't 10 whether that's real time or zero time. I am not 11 sure, but it's a time.
12 Q It's a time that occurred on the morning
- 13 of March 28, 1979?
I ,)
~~
14 A Again, I must say that if it's real 15 time or zero time.
l i 16 Q Putting aside --
l 17 A It's a time on the morning of March 28.
18 Q You did take a look at the chronology i
19 of what happened on the morning of March 28 in 20 connection with your section "Information Available 21 to the Operator," is that right?
O 22 A Yes.
23 Q You made this notation concerning what l
24 happened to make-up pump B, right?
,O
(_,) 25 A Yes.
l
Billingsley 294 1
2 You found that it automatically stopped?
[x.y ] Q 3 A Yes.
4 Q Your comment here is that once that had
,ll 5 happened all of the other make-up pump trips, that 6 is, the A and C pumps would be blocked from 7 actuating the panel alarm. What did you mean by 8 that?
9 A Based on how I read that statement 10 today --
11 Q Your counsel will object to that.
12 Do you have any recollection as to what 13 you meant there?
('~]
U 14 A No.
15 Q Do you have any recollection today as 16 to what the consequence was of having the B make-up 17 pump in the auto stop mode?
18 MR. GLASSMAN: Could you read that back?
19 (Question read by the reporter.)
20 A Based on the preceding paragraph of .
21 section 3.3, panel 8.D37 would not actuate.
O 22 Q Did you make a determination that after 23 4:02:38, whether that's real time or time from the 24 beginning of the incident on March 28, 1979, O
l x._)
i 25 because of the position of the B make-up pump panel
1 Billingsley 295 j
2 indications were unavailable with respect to trips (v)
3 of the A and C make-up pumps?
4 A Are you talking panel alarms?
That's what you were talking about ll) 5 Q Yes.
6 here in this memo.
7 A Yes, that's exactly what that was talking 8 about. I don't recall.
9 Q The A and C pumps are the ones used for 10 HPI, you learned that as a result of your investigation, 11 didn't you?
12 A I do not recall if safety injection is y-s 13 limited to just those two pumps.
b 14 Take a look at the next page.
Q 15 A Page 6?
16 Q Yes, the top, " Engineered Safety 17 Features /High Pressure Injection," Section 3.4, "The 1
l 18 make-up pumps are required for high pressure l 19 injection (HPI). During normal operation two of 20 the three pumps are in standby while the remaining 21 pump is used to service system requirements 22 (make-up & letdown). The preferred mode of pump l
l 23 operation, at TMI-2, is MU-P-1A & 1C in standby l
24 (HPI) and MU-P-1B in operation."
/~'N 25 Does that help refresh your recollection t
Billingsley 296 1
% 2 that at TMI-2 it was make-up pumps 1A and 1C that 5
3 were used for high pressure injection?
4 A Yes.
g would you look now at Table 1 of your
.ll 5
6 report?
7 A Yes.
8 Q What is that?
9 A Table 1 is an actual accounting of pump 10 status during the accident.
11 Q Begins on page 13 and carries over to 12 page 147 13 A correct.
v 14 Q Is this a chart that you prepared?
15 A Yes, it is.
16 Q From what in' formation or sources did 17 you get the data necessary to prepare this chart?
18 A Computer printouts and analysis of the 19 electrical circuit.
20 Q There is a column at the left-hand side .
21 marked " Time," do you see that?
O 22 A correct.
23 Q Is that real time or time from the 24 beginning of the event?
25 A I don't recall. I can't recall.
1 Billingnicy 297 r~s 2 Q Well, the time column contains various
( )
LJ 3
times, each of which has three parts separated by 4 colons. First, there is a single digit colon, double 5 digit colon and another double digit.
g] g 6 Do you see that?
7 A Yes.
I Is the number to the far left, is that 8 Q 9 meant for hours?
10 A Yes.
11 Q Digits in the middle are minutes?
12 A Yes.
13 Q And digits at the far right are the e' .
4
(
14 seconds?
15 A correct.
16 Q Do you have any recollection as to what 17 time the accident at Three Mile Island commenced on 18 the morning of March 28, 19797 l 19 A I don't recall.
20 Q Do you remember that it was about four 21 o' clock in the morning?
22 A If you say so. I don't recall.
23 Q You have no recollection of that?
24 A No.
C\ Do you know how long it was after the
( ,! 25 Q i
l l
l l
1 Billingoley 298
(~N 2 accident began that the operators began operation N.]
3 of the make-up pumps?
4 A No, I don't.
You were performing an investigation ll) 5 Q i
6 to find out when the make-up pumps were operating 7 during the accident?
8 A That's a fact.
' 9 Q You never found out how long after the 10 accident started the operators went and --
11 A I could tell you based on time, but I 12 must remind you that everyone in the industry played 13 games with time. some people used zero time and 7-
'w /l 14 some people used real time. Unless I can recall 15 what I took for time and when the accident occurred -- yod 16 are asking me for answers to facts which you have 17 immediately and I don't.
18 Q You prepared this?
19 A Yes.
l 20 Q You have columns on the left-hand side 21 of the page beginning with approximately 4:00:50 0 22 seconds.
23 A correct.
24 Q Are you telling me today that you do t i
( ,/ 25 not remember that that in fact refers to the real
t l
1 Dillingsley 299 !
time of the accident as it began on the morning of
(~]
t /
' 2 I w/
3 March 287 Do you really have any doubt --
4 A If you are telling me that you are sure that that is the real time that the accident lll 5 i started, I would be able to place this time -- I 6 ,
7 can give you what I believe my understanding of 8 what this time is. What time did it start?
I 9 Q Approximately 4:00 A.M. on the morning 10 of March 28.
11 Q Then this is real time.
12 Q You were i nvolved in the preparation 13 of the sequence of events, weren't you?
,g
\ .Y A Yes.
14 15 Q You were involved in that for several 16 months?
17 A Yes.
l 18 Q Did it ever come to your attention what l
i 19 time the accident started?
20 A Yes.
21 Q What time did it start?
O 22 A I can't recall.
I 23 Q Sometime in the morning?
24 A Sometime in the morning.
(D MR. GLASSMAN: We are wasting time. We
(_,1 25
1 billings 1sy 300
(~x, 2 can all get to the bottom of it very easily.
() MR. WISE: I agree.
3 4 MR. GLASSMAN: Your problem is that you 5
somehow have this great perception that every
]l}
6 witness has t o h av e a recollection of events 7 similar to yours. The witness wasn't at 8 Three Mile Island on the date of the accident.
9 He may have learned something, he may have 10 forgotten it. If you and I would like to 11 take this witness' testimony on this point 12 subject to our knowledge and understanding 13 which may be this witness doesn't recollect 7-N.Y that the accident started at about four o' clock, 14 15 we can go that way.
16 MR. WISE: Let's try and proceed.
17 Q Do you notice that on your chart, Table 18 1, you have an indication at 4:02:38. Do you have 1
19 an indication that make-up pump 1B was tripped?
l 20 A correct.
21 Q If I am right that the accident started l
22 about 4:00 A.M., it would mean that this make-up l
23 trip at approximately -
24 A Assuming base time is correct.
l l'h Assuming again it was almost four o' clock I ( ,) 25 Q l
i l
1 Cillingsley 301 2 on the nose, this would be about two minutes or some
(~3
( ,)
3 odd seconds into the accident?
4 A Correct.
(jg) 5 Q Do you remember from all your work on 6 the sequence of events and this investigation 7 whether in fact you learned at some point that the 8 operators at about two minutes or 30 seconds sp 9 into th e accident had stopped make-up pump 1B7 10 A I am not aware that the operator stopped 11 the pump.
12 Q That it had been automatically stopped?
13 A Based on my report, yes.
g- y N) 14 Q It had been automatically stopped by 15 an emergency safeguard actuation; is that right?
16 A That appears to be the case, yes.
17 Q Pump 1B which was the normal make-up l
l 18 pump would stop and make-up pump 1A and 1C would I
19 begin in the HPI mode; is that your understanding 20 based on the investigation that you performed?
21 MR. GLASSMAN: You are asking for the O 22 witness to tell you what's in this chart?
23 MR. WISE: I am asking for his recollection 24 of what he understood based on this investigation l r
(_)S 25 and based on the fact that he was involved in
e 1 Billingoloy 302 j
~ ' 2 the sequence of events which we'll come to ,
(/
z.
3 in a moment.
4 A Based on my understanding of TDR-118 which I prepared, I cannot speak to the sequence of lll 5 6 events which I do not have in front of me. C pump 7 started on emergency safeguard actuation. A pump 8 was already in operation.
9 Q Based on your investigation did you 10 determine what the printout was wired to show or what 11 the computer was set up to show for a pump which 12 had been in operation in a make-up mode and then was or received an emergency safeguard actuation and
(-}
\,_/ '
13 14 converted to the HPI mode?
15 MR. GLASSMAN: Could I have that read 16 back?
17 MR. HISE: Let me try to clean that up, i
l 18 It got a little messy.
19 Q Based on your investigation of the 20 printout indications that were provided from the 21 computer, did you ever determine what printout was O 22 supposed to be received in the event that a make-up 23 pump which was in operation before an emergency 24 safeguard actuation signal received such a signal
(%
1 <
L> 25 and went to the HPI mode?
I Billingclay 303 Let me make
()
V 2 A I understand your question.
3 sure I have got it right. The pump is in operation, 4 you have got an ES, you want to know what the 5 printout would look like when it's in operation?
(l) 6 Q Yes.
7 A I know what it looks like.
8 Q What should have been printed out?
9 A Based on my recall I am not sure that 10 you would get a printout for a pump that is already 11 in operation.
12 Q Did you ever determine that in connection 13 with your preparation of Table 1 because I note that 7-
!'n.)l at the time that there is an indication that make-up 14 15 pump 1C had gone into emergency safeguard actuation.
16 There is nothing on this chart indicating that pump t
f 17 1A likewise had gone into the HPI mode.
18 A That's correct. That pump was already 19 in operation, on that basis I make the statement 20 that I don't believe that there necessarily would 21 be a printout for a pump already in operation.
O 22 Q Did you ever determine one way or the 23 other whether in fact that should have occurred?
24 A I don't recall.
7-I note that there is nothing on your
() 25 Q
1 -
Billingsley 304 1
2 chart between 241 when make-up pump 1C'was shown 3 to have actuated in the HPI mode and 515 when there i
4 is an indication that pump 1C was tripped through 5 a manual stop. Do you see that? There are no qg) 6 indications of any printout in between those two 7 times.
8 A Pump A?
For either pump A, B or C. You go from
! 9 Q 10 241 to 515. There is nothing in between.
11 A You are correct.
12 Q Did you ever determine where on the 13 morning o f the accident the pumps either in their 14 make-up mode or their HPI mode had been turned on 15 or off between 241 -- two minutes and 41 seconds into 16 the accident and approximately five minutes and 17 15 seconds into the accident, again with my 18 assumptions about time?
19 A on the basis of this, no.
20 Q Did you ever learn as a result of your 21 work on the sequence of events that the operators O 22 had interfered with HPI operation between the time 23 241 approximately passed four o' clock in the morning 24 and 515-passed four?
ba
(_/ 25 MR. GLASSMAN: Objection to the use of i
- v
Billingsley 305 l 1
If they took some, 2 the word " interfered."
and he learned of it, fine. There are 3
4 implications in the word which are unfounded.
5 MR. WISE: You will hear a lot of it 1
g 6 at trial but I will go along with some other 7 word now. Actuation or termination of the 8 pumps.
MR. GLASSMAN: There has been testimony 9
10 not only that actuation and termination of the 11 pumps were a part of regular procedure that 12 they happened before, that they were sometimes 13 considered normal and that's the context in 14 which I object to the use of the word 15 " interfered."
16 MR. WISE: We'll fight that battle 17 another day.
18 A I can't say because I don't recall. I f
19 can't recall based on my current knowledge of the i
20 sequence of events. 1 21 Q Would you look at the indication for 9 22 approximately 4:11 A.M. You have there under
! 23 make-up pump 1A that the pump was manually stopped, 24 manually started and then manually started again.
25 What is your recollection of what
Billingsley 306 1
to the pump?
occurred there with respect
[')
G 2
Based on my analysis that the pump was 3 A 4 started, stopped and started and then started a pump.
You see
' 5 Q Go down a little bit further.
)
1A was 6 an indication that at 4:12:20 make-up pump 7 successfully started manually.
8 A At 4:12:20, yes.
9 Q Then there is nothing shown here between 4:12:20 A.M. and 7:20:50 A.M.
10 11 Did you ever determine as a result of a result of your 12 your examination on this TDR or as 13 work on the sequence of events, whether the 14 operators had started or stopped any of the make-up the morning 15 pumps between 4:12:20 and 7:20:50 on 16 of the accident?
I 17 A No.
18 Q That never came to your attention?
f 19 A Not to the best of my knowledge.
Table 2 is 20 Q Look now at Table 2.
labeled " summary of Table 1." This occurs at 21 9 22 page 15 of your report.
23 Do you see that?
24 A Yes.
r~
/ 25 Q You have at the left-hand side various l
l>
1 Billingsley 307
()
\_)
2 descriptions of total number of manual starts, total 3 number of manual stops, so forth and so on. Then 4 you have two columns to the right, one labeled 5 "Before" and one labeled "After." According to ggg 6 the notes, the "Before" column refers to pump 7 operation published in the preliminary sequence of 8 events for March 28. The "After" column refers to
, 9 your analysis of the computer printouts. Is that 10 correct?
11 A Yes.
12 Q Did you have available to you in gg 13 preparing TDR-118 a copy of a preliminary sequence L) 14 of events for March 28, 1979?
15 A I can assume that I did on the basis of 16 this statement, yes.
17 Q Do you renember making out this table?
l 18 A Yes.
l I 19 Q Do you remember what you made it up from?
l 20 A Yes.
l l
21 Q What did you make it up from?
h 22 A I made it up from my analysis and l
23 preliminary sequence of events dated 3/28/79.
l 24 Q You remember having that?
(-,
(._) 25 A On the basis of this, yes. I must have.
1
i l
1 Billingoley 308 l
1
()
%.j' 2 MR. GLASSMAN: I think the record 3 should state that the question is not directed 4 that you mus t have or should have, but p ggg 5 whether you actually remember having it.
6 Q What preliminary sequence of events did 7 you have to prepare the "Before" column?
8 A I don't recall.
9 Q You later came to work on the sequence
't 10 of events at some point?
11 A Correct.
12 Q In doing that work, did you channel in
-g~3 13 the results shown in the "After" column in Table 2
, 4 V'
14 of TDR-118?
15 A Did I channel 118 into my original on 16 the sequence of events?
17 Q Yes.
l t 18 A Yes, I did.
I 19 Q Did you make a designations and deletions l
l 20 as to when the make-up pumps started and stopped i
I 21 based on the work you had done here?
O 22 A Yes, I did.
23 Could I qualify that statement? I made 24 recommendations.
7
'(_,/ 25 Q You didn't have the final say on the 1
Billingsley 309 I
7 2 sequence of events?
l )
s_/
3 A No.
4 Q Would you look now at Appendix 1 which is the following page. That has something called 5
' g) 6 " Investigation outline."
7 Who prepared that?
8 A I did.
9 Q Did you pursue all these questions?
10 A I don't recall.
11 Q Question 7, "When a printer fails is there 12 automatic backup?"
13 Did you ever find out the answer to that
()
\_/
14 question?
15 A I don't recall.
16 Q Did you ever investigate it?
17 A I don't recall with certainty.
I 1
! 18 Q Would you look at item 9, "Has there l
l 19 been instances where, due to the quantity of 20 alarms and/or events, the computer has given i
21 erroneous alarms or messages?"
l 9 22 Did you ever find out the answer to that l
l 23 question?
24 A I found out that there are erroneous
(
[N/ ) 25 messages. I don't recall if I tied in quantity of r
1
! 1 Billingsley 310
- 2 alarms and/or events.
km Q Your last item, "Did anyone keep a 3
4 log of start /stop attempts on the pump?"
5 What pump are you referring to there, ijg) 6 make-up pumps?
7 A Yes.
8 Q Did you ever find out whether anybody 9 kept a log on that?
10 A I don't recall.
11 Q Would you take a look at Appendix 2 to 12 your report? Would you tell us what that is?
13 A This looks like a design modification
' that was made.
14 i
15 Q That's page 4053, 4054, 4055 and 4056.
16 Let me ask you this: Appendix 2 which l r
17 is 4053 appears to relate to something done in (
18 March 1979. You can note that by looking at the l
dates down at the bottom right-hand corner. You 19 will see the date liarch 27, 1979. It's very hard 20 21 to read. I think if you look you will be able to S 22 see it.
23 A Yes, it looks like that way.
24 Q So this document relates to the I
( ,) 25 modification that was made and noted in your report 1
Billingsley 311 1 l
2 on March 27, 1979, would that be right?
LJ 3 MR. GLASSMAN: Are you asking the 4 witness whether he knows that?
MR. WISE: Yes. We are not going to gg 5 6 finish if you keep objecting every time on that.
7 MR. GLASSMAN: The witness didn't seem 8 to h av e any answer before. You just showed 9 him a particular date which is somewhat 10 unreadable. I want to make sure he understands 11 the difference between reading this date and 12 saying that you read it correctly as opposed
,-~s 13 to his recollection of an event.
t
(_)8 14 A The question --
15 Q Take a look back. This is taking much 16 longer than I thought. One, go back to page 4041 17 of your report.
18 A That's it.
19 Q The remainder of these documents in 20 the appendix here come from the files of Met Ed?
21 Is that where you got these?
9 22 A This Appendix 27 23 Q Yes.
24 A Doesn't look like like everytning in Appendix
/~T
( ,)
25 2 came from Met Ed's files. Some of these are
1 Billingsley 312 l r- 2 drawings that I made.
\s x_
r Which ones?
3 Q
- 4 A Page 4061, 4062, 4063. Those are 5 drawings that I made out of the sources indicated ggg 6 on the drawings.
7 Q I believe those three drawings are a 8 part of Appendix 3. It's very hard to make out. If 9 you look at the top center towards the right you l
10 will see in very faint print there, Appendix 3, I I
11 think.
12 A Appendix 2 are items taken out of Met Ed
,._ 13 files.
l Y.~] 14 They all relate to the design modification Q
15 which you reference in your report in Section 3.2; 16 is that right, on page 4 and carrying over to page i 17 5? This is the backup documentation for those l 18 changes?
19 A That's correct.
20 Q There came a time when you were asked to 21 work on the sequence of events for the March 28 22 accident, I believe you testified to that already?
I 23 A That's true.
24 Q Let me show you what's been marked l /-
( ,N) 25 already as B&W Exhibit 466. Take a look at that and l
l i
1 Billingsley 313 1
You may tell us if you recognize what it is.
(~h 2 N.) want to look. I guess it's the second page of 3
4 the exhibit.
A Which would be page 23218?
g 5 Q Yours may be different. Let me see the 6
copy that was previously marked. This is the same.
7 8
Let me ask you -- the second page on the copy that I have is different than what you have got. We are 9
10 attempting to get the handwritten memo that appears 11 on at least one copy of this particular report which ,
i may help you. Until we get that report, does looking 12 13 through this help you remember whether or not you f-
'Lj' have seen a copy of this?
14 A Is there a cover page 15 We'll get one in a moment. There is a
'16 Q 17 note signed by you dated November 26, 1979 which l
18 reads, "This is the latest edition of the Stafco sequence of events.
Please have your people review 19 and pay particular attention to any mention of 20 l
thermal hydraulics. Forward your comments to me 21 If there are any problems, 1
22 by November 30, 1979.
please contact me." It's written to someone by 23 i
the name of Gary.
24
( ,) 25 I
i
1 Billingeley 314 2 510.
, _s
'~ (Handwritten note signed by Mr. Billingsley 3
4 dated November 26, 1979 marked B&W Exhibit 510 for identification, as of this date.)
lg 5 6 Q Is Exhibit 510 a copy of a note which 7 you wrote?
8 A Yes.
9 Q Do you remember forwarding a copy of 10 the Stafco report to Gary Miller for his review?
11 That's who the Gary is that's referred to in the 12 note, isn't it?
13 A I don't know.
c a
\/ 14 Q You don't remember forwarding this to 15 Mr. Miller?
l I 16 A No.
l 17 Q You don't remember forwarding anything 18 to Mr. Miller?
19 A Not this particular report. I have 20 dealt with a number of Garys.
21 Q Do you remember who you would have S 22 forwarded this to on November 26, 1979?
23 A No.
24 Q Did you ever submit one to Gary Broughton?
25 A I vaguely remember that being the
( )
1 Billingoley 315
,_ 2 individual, yes.
I%)l 3 Q Did you ever receive any comments from 4 Mr. Broughton?
ggg 5 A I don't recall.
6 Q Did you ever receive any comments from 7 Mr. Miller?
8 A On this?
9 Q Yes.
10 A I don't believe so.
11 Q You are asking someone to forward 12 comments to you by November 30. Do you remember 13 who , . i f anyone, forwarded any comments to you by
/ \
(N/ ) .
the end of November 1979 on the Stafco report?
14 15 A I can say what I remember with respect 16 to this and it's vague in my mind, Mr. Wallace asked 17 me to have Gary Broughton's group I remember -- Gary j
l l 18 Broughton's group to take.a look at the thermal 19 hydraulics section.
20 Q Do you remember whether you got any 21 comments on that?
O 22 A I don't recall getting any.
23 Q I guess we're back to the original 24 '
question which is whether you recognize the Stafco (m) 25 sequence of events itself which appears to be,
- x. s
I Billingsley 316 1
the first page 2
according to a handwritten note on of it, a November 2, 1979 draft.
3 MR. GLASSMAN: What document are we now 4
talking?
1 l 5 B&W Exhibit 466.
MR. WISE:
6 coming Q
Do you have a recollection of 7
8 into your hands?
I note an objection, that MR. GLASSMAN:
9 while for all I know this might be a stafco 10 work, that does not appear on the face of 11 looking the document and I guess what we are 12 13 for is the witness' recollection.
This is silly. This has MR. WISE:
14 15 become obstructive.
of A I have looked at a number of sequence 16 ev er.ts .
Stafco had one, John Putnam had one.
17
! Q Would you take a look at the first page l
18 It says Volume 2.
19 of this exhibit.
A Yes.
l 20 I
21 Q This volume describes the accident 9 22 that occurred at Three Mile Island Unit 2 on March 28, 1979. Supporting information in Volumes 23 l
I 24 3 and 4.
l i
A Yes.
25 l
1
Dillingsley 317 1
2 Q Do you know if Mr. Putnam's sequence (I
3 of events had four volumes?
4 A I don't believe so.
Did the Stafco sequence of events and lll 5 Q 6 reports have four volumes?
7 A I believe it did.
8 Q Would you take a look at the actual 9 sequence of events, the printed portion that begins 10 at time 00:00:14 seconds and continues for quite 11 a few pages thereafter.
12 You see how that's in a printed format
(, ,') 13 as opposed to typewritten?
L; 14 A Time 00 --
The whole thing, all of this stuff. Do 15 Q 16 you see how that's not in normal typescript?
17 A I guess it isn't. This could be 18 reduced. Jesus Christ, I don't know. If you say 19 it is, it is. It is printed.
20 Q Is there seriously any doubt in your mind j
21 that this is the Stafco report?
O 22 A If I was to testify to this under oath, 23 I can't say it is or isn't because there is no 1
24 identifying script on it that says Stafco. This l [~s\ Would you t' / could be EPRI's report for all I know.
25
Billingsley 318 1
, ~s
( ) 2 put your life on this statement?
3 Q It depends on whether or not you were 4
involved for several months with working on this report. You also were involved with working on
- ll 5 6 the EPRI report.
7 A I reviewed it.
B Q Now you are not able to tell the 9 difference between them?
10 A If you have codes or names on it, I I am under oath, ain't I. You are ;
11 will tell you.
12 asking me to testify to the best of my knowledge.
I If you say so, maybe that is Stafco's report.
[N._ /) 13 14 can't say for sure.
15 Q Who else besides you worked on the 16 Stafco GPU Service between November 1979 to May 17 1980?
18 A Jim Flarethy.
j 19 Q Is he the only person?
20 A Assigned, yes. I also worked with John
' 21 Putnam on this as well.
22 Q You were the prime GPU Service employee 23 who was responsible for reviewing the Stafco report 1
l 24 during that period of time; isn't that true?
l l l. )
' 'j 25 A That's correct.
I i l
Dillingsley 319 i 1 i 2 Q You are not able to identify because l j
x-3 it lacks identi.f.ication on it?
Mr. Wise, come now. We 4 MR. GLASSMAN:
You keep on 5 have been through this a lot.
h 6 expressing some personal chagrin at the 7 fact that a witness cannot look at a 8 particular piece of paper that he may have 9 looked at several years ago and tell you 10 without an identifying remark whether it's 11 a sequence of events prepared by one person 12 or another. It's a long document.
MR. WISE: Let's look at a few other
(^'j 13
\v 14 documents and see if that will help.
15 MR. GLASSMAN: I should note that if 16 one witness doesn't recall a particular item, 17 it's traditional to call another witness if The problem 18 you deem it important enough.
o 19 with the testimony of this witness, it's y'ur 20 examination of him, you persisted in asking .
21 more questions about documents that this O 22 witness did not author rather than ask 23 questions about documents that he did author.
l 24 As a result, you have obtained some blanks.
(
25 I think it's understandable and the problem I
320 Billingsley 1
p relates to the nature of the question rather
( ,) 2 3
than to the nature of answers.
MR. WISE: I disagree with you, 4
5' Mr. Glassman. I think this witness is the
)
concerning the Stafco 6 proper witness to testify report. He just said he was the prime GPU 7
8 Service person involved with reviewing it I cannot 9
for a period of over six months.
10 think of anyone else to call to ask about it.
11 ,
If your client wants a trial in 12 October 18, 1982, I guarantee you are not b) 13 going to get it if you persist in making I
(,j 14 us call every last author of every last piece f
in and deny 15 of paper, when they come 16 recalling something --
MR. GLASSMAN:
You have a particular 17 identifier 16 document here that doesn't have an 19 on it. The witness said he has worked on t
the Stafco report. You are free to ask him 20 it.
21 any questions you wish on l
I The question you are pursuing ad infinitum, 22 can sit here and tell you 23 whether this witness 24 now that this is stafco's report or not, if you rN k.) 25 want to cut time by serving a notice to admit
{
~
Billingsley 321 1
2 or doing some other procedure that might
)
3 allow us to short circuit this to save this 4
witness' time and all of our time, I am sure you know full well how to proceed expeditiously ll 5 a
'6 without wasting a half hour on identifying 7 particular document.
O BY MR. WISE:
9 Q Do you know Mr. Ankrum?
Yes. Not personally. I believe I have 10 A 11 spoken to him on the phone.
12 Q He worked for Stafco, Inc.?
13 A Yes.
14 Q Did you know Mr. McEwen?
15 A Yes. I believe I met him on one 16 occasion.
17 Q Mr. McEwen or Mr. Ankrum?
18 A Mr. McEwen.
Did you have correspondence with either 19 Q 4
20 gentleman?
l l A Yes, 21 22 Q What was the correspondence about?
f 23 A I had correspondence with Mr. Ankrum 24 and Mr. McEwen involving my review of Stafco 25 sequence of events.
1
322 Billingsley 1
Q Do you recall, Mr. Billingsley, becoming 2
i
( Mr. Ankrum had discussions with Jim Floyd .
3 aware that and 9 concerning the draft sequence 4 on November 8 5
of events prepared by Stafco?
4 h
6 MR. GLASSMAN: Could I hear that once 7 more?
8 (Question read by the reporter.)
9 A I believe Mr. Ankrum spoke with someone 10 at Three Mile Island, but I don't recall it being 11 Mr. Floyd. I can't say at this point.
MR. WISE:
Let me show you what I will 12 have marked as B&W Exhibit 511 which is a
(} 13 14' copy of a letter dated November 26, 1979 from 15 Mr. Ankrum to Mr. McEwen with carbon copies to Ed Wallace, Jim Floyd and Ron Neve.
16 letter dated November 26, 1979 17 (Copy of l
!' 18 from Mr. Ankrum to Mr. McEwen marked B&W as of this 19 Exhibit 511 for identification, 20 date.) '
I l
Q The memorandum reads, " Attached is the l
21 22 current list of outstanding questions on the i.e., Volume II, 23 Operational Sequence of Events, These questions i
24 Section 1.2 of the subject report.
25 have resulted from my discussions with Jim Floyd l
l l
1 f
i l
Billingsley 323 l I
s 2 on November 8 and 9 and from Mr. Quincy Billingsley's
()
letter to you of November 19, 1979. This list of 3
4 questions is being simultaneously sent to Ed Wallace I will incorporate h 5 at GPU and Jim Floyd at Met Ed.
6 their responses to these questions, along with 7 any other comments, as soon as possible after receipt."
8 Did you ever receive a copy of B&W 9 Exhibit 511 and the attachments to it?
10 A I can't say I recall the cover letter, 11 but these questions that are attached appear to 12 be questions I have seen before.
fm 13 In what connection did you see them?
(g) Q 14 A Working on the sequence of events to 15 respond to particular questions made by Stafco 16 and/or personnel at TMI.
17 Q Two attachments, one is dated 18 November 19, 1979. It is 8 pages long.
19 Do you see that?
20 A Yes.
21 Q Do you recall preparing an 8-page set 22 of questions and mailing it to Mr. Ankrum with your 23 letter dated November 19, 19797 24 A I would have to see that letter because
/"N U 25 I don't recall what it is.
t
?
324 Billingsley 1
Ankrum Q
You don't recall writing Mr.
2
( with vsrious questions and comments regarding the 3
had been prepared by 4 sequence of events that 5 Stafco?
)
A I may have.
6 Q
You don't recall it one way or the other?
7 A No, I do not.
8 9 Q You don't recall whether the particular is dated November 19, 1979 reflects 10 document that 11 your comments?
I don't know.
A These may be my comments.
12 13 l If you have the letter, I suggest you show it to time because it's getting 14 me. It would save us We haven't been provided 15 close to four o' clock.
If I had it, I would 16 with a copy of the letter.
17 show it to you.
18 Q Without the letter, you have no 8-page series of 19 recollection as to whether this i l
l questions is something you prepared?
20 A No.
21 22 Q You will note that a second attachment 23 begins following the 8-page sequence of events.
l l
24 It's titled "Stafco" typed by Al Ankrum.
f be?
A What document page would that 25
Billingsley 325 1
2 Q 3741 and continuing for the next 3
several pages through 3745, through item 60.
I am sorry. The second thing I was 4
(jg 5 talking about is another document that we'll mark 6 in a second.
7 The copy I have has the two of them 8 attached. You have got the copy that just has 9 3715 to 3722.
10 A That's correct.
11 MR. WISE: Let me withdraw my question 12 concerning the second one.
13 Let me snow you next a document which
/~N V
14 we'll have marked as E&W Exhibit 512.
I 15 (Handwritten document, two pages, marked 16 B&W Exhibit 512 for identification, as of this 17 date.)
18 Q Have you ever seen B&W Exhibit 512 before?
dated i
19 It's a copy of a two-page handwritten memo l
20 November 9, 1979 addressed to Ed and signed by Al 21 Ankrum.
22 A I vaguely remember this.
23 Q There is some handwriting at the top 1
24 of the page. Do you see that, " Questions:" and three l
O 25 items. That's your handwriting?
i
- - - - - - - . - ~ , , _ . , _ , _ . . . _ _ _ _ _ _
Billingsley 326 1
2 A That's correct.
t L
3 Q so you had a copy of this?
4 A Yes.
5 Q Was the "Ed" Mr. Wallace?
(lll 6 A I believe so.
7 Q Do you remember whether you received 8 this shortly after November 9?
9 A No, I don't.
10 Q This particular comment references three typewritten pages which reflect the comments 11 12 made by you and -- is that " Stack" or " Jack," Jack
~
13 McEwen?
[')
- x. J 14 A Where are you reading this?
15 Q From the front page of B&W Exhibit 512.
16 A on the top of this page?
It says, "3 17 Q It's about halfway down.
18 typewritten pages reflect the comments made by you 19 and Jack McEwen in Idaho Falls, along with some 20 that I added."
21 A Yes.
22 Q "Many of them were answered or 23 superseded during discussions with Jim Floyd 24 yesterday and today."
,7-
'\' ] Do you see that?
' 25
Billingsley 327 1
!% 2 A Yes.
(v) "Also attached (in very rough form) is 3 Q 4 a 15-page list of questions and comments generated As I told him, I'll be 5 in discussions with Jim.
l 6 getting these typed within the next couple of days and I'll send you a new copy.
" Signed "Al Ankrum."
7 8 MR. WISE: Let's have marked as B&W Exhibit 513 a three-page typewritten set of 9
10 comments on the sequence of events.
typewritten document entitled l 11 (Three-page 12 " Sequence of Events Comments" marked B&W 13 Exhibit 513 for identification, as of this
()
%J 14 date.)
15 (Discussion off the record.)
16 MR. WISE: We'll come back.
17 (Time noted: 4:00 o' clock P.M.)
18 QUINCY BILLINGSLEY, III 19 Subscribed and sworn to before me 20 day of , 1982.
this 21 9 22 23 24
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"' 25 l
1 ,
a CERTIFICATE 2
^ -
STATE OF NEW YORK )
( 3 : ss.:
COUNTY OF NEW YORK )
4 CATHERINE Cook , a Notary
( I, Public of the State of New York, do hereby
,g certify that the continued deposition of 7
QUINCY BILLINGSLEY, III Was taken before 8
February 19, 1982 consisting me on 9
of pages 158 through 327 ;
I further certify that the witness had 11 been previously sworn and that the within transcript is a true record of said testimony; 13 That I am not connected by blood or marriage with any of the said parties nor 15 interested directly or indirectly in the matter 16 in controversy, nor am I in the employ of any 17 i
of the counsel.
18 IN WITNESS WHEREOF, I.have hereunto set my hand this /0 day of NaCC, ,1982.
I 20
{ 21 0 -
(1 f 22 L-nowns, -
bad' 2s CATHERINE Cook 24 25
, *
- 9 9 ese
- O
-- - - - , - - - - - -e_ - - -' _ - - , , , ,,- - - - - ---,,,-m.,-,,.w----n.
329 Fcbrucry 19, 1982 INDEX
'"x .
PAGE WITNESS 159 Quincy Billingsley, III (continued)
B&W EXHIBITS Set of notes, the first page 160 439 of which is a copy of file jacket entitled "EMOV License Submittal, 2-29-80" Handwritten notes relating to 195 440 the reactor coolant drain tank Two pages of handwritten notes 198 441 titled "RC-V-2 (Block Valve for Electromatic Relief)"
(~%
_Y 200 442 Document entitled "Three Mile Island Nuclear Station Unit 2 Surveillance Procedure 2301-3D1 RC System Inventory" with attached data sheets I
Two-page handwritten document 204 443 205 444 Set of handwritten notes Letter dated October 18, 1979 207 445 to Mr. Short from Mr. Harding 209 446 Memorandum dated March 1977 from Mr. Shovlin Letter dated March 29, 1978 210 l 447 from Mr. Bolger of Dresser Industries to Mr. Cotter at Met Ed 211 l
448 Letter dated December 1, 1969
(~} from Dresser Industries to B&W
(_) with attachments
FChrucry 19, 1982 330 EXHIB I TS
(^m i 'j B&W EXHIBITS (continued) FOR IDENT.
449 Copy cf field questionnaire and 211 problem report, cover page bearing date April 6, 1978 Qlh 450 Field questionnaire number 1874 212 bearing date May 25, 1977 with attachments 451 Copy of field change report 212 with documents attached 452 Letter dated January 24, 1972 212 relating to PORV order 453 Letter dated October 5, 1976 213 from Dresser Industries addressed to Mr. Stuhrke of Burns & Roe 454 Two-page quality assurance data 213 sheet relating to Dresser PORV
[~')
Ne 455 Copy of a memorandum to file from 213 Mr. Harbia dated February 1, 1980, subject, PORV 456 Multipage document, TDR-190, 216 titled "TMI-2 PORV Investigation" Handwritten notes titled " Things 255 457 That Still Must be Added to the Report" Copy of draft TDR titled "TMI-2 257 458 Make-Up Pump Operation" Handwritten note with attached 287 lll 459 copy of cover page for TDR-118 Handwritten note signed by 314 510 Mr. Billingsley dated November 26, 1979 f~%
U
,, Fobruary 19, 1982 331
.~
\,,
- s EXH I B ITS B&W EXHIBITS (continued) FOR IDENT.
511 Copy of letter dated November 26, 322
.s s 1979,from Mr. Ankrum to Mr. McEwen
'\
512 Two-page handwritten document 325 513 Three-page typewritten document 327 i
entitled " Sequence of Events s Comments" bs , . .
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