ML20072J003
| ML20072J003 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 02/25/1982 |
| 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 8306290862 | |
| Download: ML20072J003 (81) | |
Text
l 332 on UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK
[y_,i
x GENERAL PUBLIC UTILITIES CORPORATION, a
JERSEY CENTRAL POWER & LIGHT COMPANY, CE' METROPOLITAN EDISON COMPANY and PENNSYLVANIA ELECTRIC COMPANY, Plaintiffs,
-against-80 CIV. 1683 (R.O.)
THE BABCOCK & WILCOX COMPANY and J.
RAY McDERMOTT &
CO.,
INC.,
Defendants.
x Continued deposition of GENERAL PUBLIC UTILITIES CORPORATION, by QUINCY bG BILLINGSLEY, III, taken by Defendant, pursuant to adjournment, at the offices of Davis, Polk & Wardwell, Esqs., One Chase Manhattan Plaza, New York, New York, on Thursday, February 25, 1982, at 10:30 o' clock in the forenoon, before Catherine Cook, a Shorthand Reporter and Notary Public within and for the State of New York.
DOYLE REPORTING, INC.
CERTIFIED STENOTYPE REPORTERS 369 LexlNGTON AVENUE
/
WALTER SH APIRO. C.S.R.
New Yonx. N.Y.
10017 CHARLES SH APIRO. C.S.R.
TettpHoNE 212 - 807-0220 8306290862 820225 PDR ADOCK 05000289 T
4 333 1
2 Appe aranc es :
KAYE, SCHOLER, FIERMAN, HAYS & HANDLER, ESQS.
3 for Plaintiff Attorneys 425 Park Avenue 4
GLASSMAN, ESQ.,
5 BY:
6 of Counsel 7
8 DAVIS, POLK & WARDWELL, ESQS.
for Defendants Attorneys 9
One Chase Manhattan Plaza New York, New York 10 11 BY:
ROBERT F. WISE, ESQ.,
of Counsel 12 CE)
-ooo-14 15 B ILLINGS LEY I I I 16 QU INCY sworn by a having been previously duly 17 was examined and continued 18 Notary Public, follows:
19 to testify as 20 EXAMINATION (continued) 21 BY MR. WISE:
still under oath You recognize you are I
22 Q
f rom the previous portion of your deposition?
23 24 A
Yes, I do.
last the end of the When we broke off at
^^-)
25 Q
J
1 BillingelOY 1
discussing B&W Exhibit 466 which session, we were
'~'T 2
is a copy of what has been identified in another
\\_,1 3
report prepared by Stafco a draft deposition as 4
the sequence of events during the TMI-2 accident.
k on 5
discussing some In addition, we were 6
believe we have marked B&W I
'related documents.
7 8
Exhibits 510, 511, 512 and 513.
Exhibit 510 is a of the concerning a draft handwritten note of yours 9
comments by November 30, 10 Stafco report and requesting 11 1979.
a mer.orandum from Exhibit 511 was 12 Stafco dated December 6, 13 Mr. Ankrum to Mr. McEwen of
,m3 questions
'79 with an attached 8-page list of ts 14 15 concerning the sequence of events.
Exhibit 512 is a handwritten note dated 16 Ankrum addressed 17 November 9, 1979 signed by Mr.
some handwriting to someone named Ed and bearing 18 bearing some handwriting at 19 which I believe page which I believe the first the upper portion of 20 identified was yours.
21 you Exhibit 513 is a 13-page list of 22 a sequence of events.
23 comments on establish the last What I was trying to 24 of our own with of events r~x some sequence k_
25 time was h
335 Billingsley 1
[')
2 respect to your work on the Stafco report and these
\\~)
various memoranda that I believe relate to it.
3 Let me just back track a little bit to 4
5 put it all into prospective.
(h You do recall, Mr. Billingsley, that in 6
7 November 1979, you did begin work on putting for the TMI-2 accident?
events 8
together a sequence of 9
A No.
I did not put together a sequence 4
10 of events.
I reviewed existing sequence of events and consultants.
has been proposed by other people 11 that identified the 12 Q
I believe last time you as one that you had.
13 EPRI sequence of events 1
14 A
Yes, I recall looking at that one.
I believe you also said one had been 15 g
Met Ed?
16 prepared internally at That's correct.
17 A
That was project undertaken by Mr. Putnam l
18 Q
19 of Met Ed?
20 A
That's correct.
l l
recalled that a And I believe you also 21 Q
l events had been prepared by Stafco?
22 sequence of 23 A
correct.
Ed to Stafco had been retained by Met 4
24 Q
25 do that, Met Ed or GPU?
i
's 9
. - - -. +..
e 3
336 Billingsley 1
A Yes.
/m 2
( s) believe you testified x
Q You are familiar, I 3
4 last time, with Mr. Ankrum and Mr. McEwen?
A Yes.
5 for Stafco?
They are gentlemen who work 6
Q A
correct.
7 involvement at all with 8
Q Did you have any the Stafco report?
9 respect to 10 A
Yes, I did.
Would you describe what your involvement 11 Q
12 was?
report My involvement with the Stafco 13 A
(~N 14 was to review it and resolve certain technical t
N._
/
at the site had been posed by people 15 questions that 16 or people at the home office.
I was also to review of other sequence of events 17 that document in light it for not only that had been published and review 18 I
l 19 consistency but also to review it with respect to l
-- with respect to technical l
20 questionable areas l
21 conclusions.
When did you begin that work?
22 Q
23 A
It's hard to say, based on the documents say November is a
24 in front of me.
I would have to
/-m
}
25 good time frame.
k'
n 337 Billingsley 1
November of '797 2
Q (V]
A correct.
3 as a result What were you supposed to do 4
Q
'h 5
of your review?
to forward that-I had I was 6
A Any comments 7
on to stafco.
any work to your knowledge 8
Q Was there Ed to develop a final going on within GPU or Met 9
sequence of events for the TMI-2 accident?
i 10 l
knew that was going on The only work I 11 A
internally was the work being performed by John Putnam.
12 as to what What was your understanding 13 Q
g-)
to be made of the stafco work on developing U
14 use was sequence of events?
15 a
l is vague in this area but 16 A
My memory with was that this report the impression I was left l
17
/
18 was going to be GPU's report that would be published unquote to the for lack of a better word quote, 19 20 world.
How did you gain that understanding?
21 Q
I don't recall.
I don't know.
22 A
responsible for Do you recall who was 23 Q
24 hiring stafco?
out a Ed Wallace had put 25 A
I know that c
338 Billingaley 1
2 purchase order.
I don't know if he was the initiator m(,)
3 or the person who authorized Stafco.
in reviewing During your involvement 4
Q to 5
Stafco's work, did you have any understanding as
!)lh 6
whom within the GPU system Stafco was reporting?
7 A
I got the impression that Stafco was 8
reporting to Ed Wallace.
9 Q
The memorandum from Mr. Ankrum to 10 Mr. McEwen which has been marked as B&W 541 and letter written by 11 is dated November 26 refers to a 12 you dated November 19, 1979 enclosing certain of sequence of regarding the Stafco draft r~x 13 comments
'O 14 events.
recollection of having 15 Do you now have a letter sometime during November to Stafco 16 written a on their draft report?
17 stating your comments 18 A
I believe I did but I can't recall when 19 it was.
20 Q
Do you recall how lengthy the letter was?
21 A
If my memory serves me correctly, there letter and a response to 22 was probably a cover 23 certain questions, so I would guess the document 24 might be a five or six pages in length.
O 25 Q
Do you recall how you would put together I
)
339 Billingcley 1
2 the responses to the comments, that is, from what
(~'y N) 3 sources was that prepared?
I utilized 4
A A combination of sources.
5 operator interviews, I utilized sequence of events lk In some that have been published by other people.
6 7
cases, raw data, whatever knowledge was available, 8
technical data that I could get my hands on and my 9
co-worker could get his hands on to provide information 10 to Stafco.
11 Q
Who was your co-worker?
12 A
Jim Flaherty.
Inc.?
13 Q
He was employed by Energy, f*
_]
14 A
Yes.
l 15 Q
This was a list of questions that you l
l a result of the review 16 and Mr. Flaherty developed as 17 of materials you just described?
The majority of questions that came 18 A
19 up were a result of reviews performed by other l
20 people.
Other people would have reviewed the Stafco 21 report and say I have problems in this area, I 22 don't think this is right.
I believe this actually 23 happened and not that.
So it was questions 24 developed by other people.
There may have also been
(,)
25 questions developed by Stafco.
Those are just some p
340 Sillingaley 1
2 of the sources that come to mind.
There may have
(']
from a think primarily we worked
/
been others.
I 3
I don't know, maybe Stafco sent a list 4
list that 5
of questions.
'h 6
Q Let's look.at, for instance, B&W Exhibit 7
512 which is Mr. Ankrum's handwritten memo of some handwriting 8
November 9 which contains in part 9
by you as well.
That mentions a three typewritten
- McEwen, list of comments made by Ed and Mr.
10 page Ankrum has added.
11 along with some Mr.
Exhibit 512, the handwritten You 'obviously did see 12 is on it.
I think memo,because your handwriting 13
!)J session we marked B&W Exhibit L
14 also at the end of last three-page list of typewritten 15 513 which is a l
16 comments on sequence of events.
I don't know how I
had gotten with 513 when we broke off.
17 far we l
18 Let me ask you to take a look at it now and tell us whether or not you did in fact receive 19 20 that three-page list of comments?
MR. GLASSMAN:
Do you want the witness' 21 O
recollection on whether he received it or 22 based on the review of the document?
23 MR. WISE:
He has to review the document 24 i
we are talking about.
He in order to see what n
)
25
341 Billingsley 1
(,)
2 can review it and see if he remembers it.
A I don't recall seeing this document, but 3
4 I know I saw it because I see my handwriting here, 5
but I don't recall this document.
lll 6
MR. WISE:
The witness is referring to some handwriting on the lower right-hand side 7
8 of the page next to the typewritten comment 9
numbered 11.
10 Q
Is that right?
11 A
That's correct.
12 Q
You are not able now to testify whether Ii 13 B&W Exhibit 513, a three-page listing of comments
\\_)
14 on the sequence of events, is the same as the list 15 referred to on the first page of B&W 512 as a 16 three-page typewritten list of comments on the 17 sequence of events?
18 A
No.
Because I don't recall seeing this 19 document.
20 Q
Also mentioned in B&W Exhibit 512 is a 21 15-page list of questions and comments generated in 22 discussions with someone called Jim.
I note that 23 looking at B&W Exhibit 511, Mr. Ankrum's memo to
(
24 Mr. McEwen of November 26, he does refer to 25 comments he received following discussions with Jim i
)
s
342 tillingsley 1
(~N 2
Floyd on November 8 and 9.
Let me now show you what I would like 3
4 to have marked as B&W Exhibit 550.
The reason for 5
skipping from B&W Exhibit 513 to B&W 550 is that lk 6
I understand there is a simultaneous deposition 7
going on of Mr. Shieman downstairs and in that deposition they have begun marking with the number 8
9 B&W Exhibit 514.
In order not to double mark 10 things, we'll skip to 550.
I just want the record 11 to reflect the reason for the gap.
12 MR. WISE:
B&W 550 is a 14-page set of handwritten notes which bear the date November 8,
13 1979 in the upper right-hand corner on the
%J 14 15 first page.
16 (14-page set of handwritten notes dated 17 November 8, 1979 marked B&W Exhibit 550 for 18 identification, as of this date.)
19 Q
Mr. Billingsley, do you recognize B&W 20 Exhibit 5507 21 A
Yes.
22 Q
Does it contain in part your handwriting?
23 A
Yes, it does.
550 is?
24 Q
What is your recollection of what that Jim These are series of questions 25 A
1
.4
343 Billingaley 1
(
)
2 Flaherty and myself worked on to resolve and provide fy answers where possible.
3 4
Q Recognizing that there are various handwritten comments that appear to be in your lk 5
6 handwriting, the underlined handwriting is not your 7
handwriting, is it?
8 A
No.
9 Q
Do you know whose it is?
10 A
I can't recall.
11 Q
Is it Mr. Ankrum's?
12 A
I can't recall that.
received the 13 Q
Do you know where you
(']
that
.s B&W Exhibit 5507
'w/
handwritten copy of comments 14 15 A
I can't say exactly.
I may have been l
but I can't recall.
16 given these by Ed Wallace 17 Q
There are various comments by you on 18 this copy of the handwritten notes.
Do you recall 19 whether you made those comments before your letter i
20 to Mr. Ankrum which he states was dated November 19, 21 19797 l
22 A
Are you asking me if these comments 23 from me -- would you repeat that question again?
i 24 Q
Let me back up.
I am only trying to 1
s i
/
\\
25 establish a sequence of events.
\\
)
344 Billingsley 1
2 A
I understand.
()
3 g
We have B&W Exhibit 512 which is a 4
November 9 memo from Mr. Ankrum to someone named 5
Ed.
You obviously got a copy at some point because (h
it.
It refers to two things 6
your handwriting is on 7
that came with it.
One was a three-page list of 0
comments on the sequence of events, typewritten.
9 And the other was a 15-page set of handwritten notes.
10 We have now identified B&W 513 which 11 is a three-page list of comments which you must have 12 received at some point 13 MR. GLASSMAN:
There has been no (G~)
i document and 14 connection drawn between that 15 the three-page document referred to in B&W 512.
16 MR. WISE:
That's correct, whatever l
17 inference the founder of the fact may wish to 18 draw of the similarity of description in 19 512 to what 513 is.
20 MR. GLASSMAN:
I am not sure that's 21 appropriate or not.
I want to make sure that 22 the record did not have an inappropriate 23 conclusion here or r-ference to testimony.
no testimony drawing such a connection.
24 There is
\\/
25 MR. WISE:
I agree Mr. Billingsley has
345 Billingaley 1
(/)
2 not been able to identify it.
I think we are
-s x_
entitled based on the similarity of 513 to 3
4 the description of 512 to at least present 5
evidence to the finder of fact from which he hhh 6
can draw an inference.
7 If you have contrary testimony, of 8
course you may present that at some point.
9 MR. GLASSMAU:
I am not sure I agree 10 with you, but the appropriate thing here is 11 to proceed rather than belabor the record.
12 Q
We have now identified B&W Exhibit 550 13 which is a handwritten set of comments dated
(/
\\_
14 November 8, 1979, again it looks to me that it 15 fits fairly closely the description contained in 16 B&W 512 of a rough form of questions generated by 17 Mr. Ankrum in his discussions with Jim.
18 MR. GLASSMAN:
I should note that while 19 B&W 512 talks about a 15-page document, what 20 has now been marked as B&W 550 is 14 pages.
21 I draw no conclusions from that.
I think the l
22 facts should be clear.
23 MR. WISE:
Again, if you have some 24 witness or some evidence that in fact B&W O
x' 25 550 is not the document referred to in Exhibit
(
)
l l
346 Billingsley 1
that at some of course you may present r~N 2
- 512,
(
)
time.
At this point I want to find through x.. '
3 Billingsley can testify discovery whether Mr.
4 that.
What I am one way or the other on I
5 is whether in fact trying to establish here 6
550 were the comments which appear on B&W 7
8 comments that were made by Mr. Billingsley between the date of the document which is 9
10 November 8, 1979 and the letter which 11 Mr. Ankrum refers to as having been sent on Billingsley to him.
12 November 19, 1979 by Mr.
entitled to proceed, 13 MP. GLASSMAN:
You are fi
\\
)
of connection between documents, 14 but in terns 15 I suggest that if that connection is B&W's to your presentation of 16 significant of 1
17 position that it might find better avenues 18 proof.
19 A
I can't say that this is the document 20 that came with this Exhibit 512.
21 Q
You can't say it is not?
22 A
No, I can't say it is not.
I can't say 1
23 it is.
At this point I don't know.
You asked me i
24 about the date November 19.
(~h' 25 Q
There is a reference in B&W 511 to a I
l 1
347 Billingsley 1
4.
Ankrum or Mr. McEwen
[
2 letter you wrote to Mr.
\\_/
dated November 19 enclosing certain comments on 3
B&W 512, 513.and 550 4
the draft sequence of events.
I am trying to have been identified and what 5
to 550 is whether you can 6
establish'with respect 7
recall'if in fact the comments on 550 were part 8
of what went into or was the source of whatever letter on or comments you transmitted to stafco by 9
10 about November 19.
Based on the time frame here and the time 11 A
I worked on these questions, 12 frame I know that I of November 19 13 doubt very much that the suggested memo
()
14 contained a response based on 550.
any Do you recall whether there were i
15 Q
concerning the lists of questions or comments 16 other i
17 draft of Stafco's sequence of events generated 1979 other than possibly B&W's 18 before November 19, identified?
19 Exhibit 512, 513 and 550 which we have if any others were written 20 A
I can't say 21 prior to the 19th or after the 19th.
I can't say, g
than one set of 22 but I believe there were more l
23 questions, to the best of my recollection.
in sequence.
Let's pick up with things 24 Q
some questions I would like to ask you 25 There are f
i 1
348 cillingsley I
(_)
2 about the questions and answers that resulted from ps 26 Ankrum memo which is B&W. Exhibit 511.
3 the November Let's go back and look at your comments 4
k 5
on B&W 550.
Those are comments on the handwritten 6
list of questions dated November 8, 1979 by someone 7
who you cannot now identify; is that right?
You the original document?
8 don't know who wrote 9
A 5507 10 Q
Yes.
11 A
I can't recall who wrote it.
12 Q
You don't recall where you got it from?
("%
13 A
No.
(,)
14 Q
Would you look at the first page of the 15 exhibit.
You will notice that the comments are l
I notation at the left-hand 16 generally preceded by a in the form of three 17 side of the page which appears 18 sets of digits separated by colons.
19 A
correct.
that those it your understanding 20 Q
Was 21 references were to the time of the accident?
22 A
Yes.
23 Q
That started from a time of when 24 the accident began rather than what you might refer to l
(~]
\\_/
real time, time of day?
25 as
349 I
tillin,gsley
/N
(,)
2 A
That statement is correct.
3 Q
Looking down the page at the bottom 4
comment.
It refers to the time 13 seconds after k
5 the accident began.
6 Do you see that?
7 A
Yes.
8 Q
Are you able today to read the handwritten 9
comment for that time period?
10 A
My comment?
11 Q
Let's begin with the comment by the 12 original author of the questions and then we'll pick im 13 up with your comment.
( )
v 14 MR. GLASSMAN:
The witness appears to 15 have some difficulty reading the handwriting.
16 I don't know what we gain by having him 17 attempt to read that now.
Perhaps counsel 18 could just as well try to read that.
19 MR. WISE:
I will be happy to.
It's 20 simply a predicate for his handwritten 21 comments that I want to ask him about.
I 22 think it would be meaningless to ask him 23 about his handwritten comments if we don't 24 know what he is commenting on.
<x I
\\
25 MR. GLASSMAN:
Subject to my objection --
L_)
350 Dillingsley 1
(/)
2 Q
My reading, "In remarks, state that 3
make-up pump B was running before the accident.
Also t.
4 state final that letdown flow was isolated."
Is that roughly your reading of that?
h 5
You are pretty good.
6 A
Yes.
7 Q
You have written a comment next to that 8
in a great deal clearer handwriting.
would you read that for us?
9 10 A
" Find out if it's a procedure requirement 11 to isolate letdown before starting" 12 Q
MUP, is that your abbreviation for 13 make-up pump?
(~}
V 14 A
Yes.
"make-up pump.
Sequence of events 15 say letdown isolated around 16 from stafco does not 17 this time period.
EI does say this was done."
18 Q
And that carries over?
19 A
Yes.
20 "But doesn't specifically state before 21 make-up pump was started."
22 Q
The reference to EI was EPRI?
23 A
Energy, Incorporated.
24 Q
Do you recall what you meant by a t
)
25 procedural requirement to isolate letdown before fm
351 Billingsley 1
2 starting the make-up pump?
,m (v) 3 A
Yes.
referring to there?
4 Q
What were you there referring to whether or not I
5 A
I was for performing this action.
an approved procedure 6
was 7
Q By isolating letdown you meant shutting 8
off the letdown flow?
9 A
Yes.
Letdown from the reactor coolant system 10 Q
11 takes inventory out of the system; is that right?
12 A
Yes.
an answer to the question 13 Q
Did you ever get
~
14 you posed in your comment?
15 A
I don't recall.
I am sure I did, but 16 I can't recall what it was.
17 Q
You today do not know whether there was 18 or wasn't an approved procedural requirement for 19 isolating letdown before starting a make-up pump?
20 A
I can't recal) that, no.
21 Q
Would you look at the next page, please.
22 Look at the last comment on that page for the time 13 seconds into the event.
23 indicated one minute and 24 My reading of that comment by the n
as follows:
" Indicated level
)
25 original author is
352 Billingsley 1
l was screwed up whenever the bypass valves were n
2
' \\,/
Make this a remark and where 3
passing steam.
indicated level."
4 applicable say out from your copy, Can you make that k
5 Billingsley?
6 Mr.
7 A
Yes, I can.
8 Q
Are you able to recall what that comment 9
related to?
10 a
wo.
take a look at B&W Exhibit 466 Would you 11 Q
identified during the deposition of 12 which was draft sequence i
copy of a Stafco 13 Mr. Floyd to be a
()
14 of events and turn if you will to page 23230 as You will marked for purposes of this litigation.
15 on that page shows the bottom comment 16 note that and 13 seconds into the time of one minute 17 a
indicated on the comment 18 accident, the same as Exhibit 550.
looking at on B&W 19 that we are The stafco draft sequence of events 20 "The condensor 21 identifies the action at that time as f
received.
The level well high level alarm was 22 hot 23 was 37.77 inches."
that?
I Do you see 24 D.
V 25 A
Yes.
i h
.---,._m-
353 Billing =1cy 1
r^x help refresh your recollection l
)
2 Q
Does that 3
in any way as to what the comment in B&W Exhibit 550 and 13 seconds referred to?
4 for the time one minute k
5 A
Yes.
6 g
Was it referring to the level in the 7
condensate hot well?
8 MR. GLASSMAN:
You are asking the refreshes speculate or whether this 9
witness to 10 his recollection?
11 MR. WISE:
I just asked precisely that 12 question.
13 MR. GLASSMAN:
Just wanted to be sure.
lQj A. s sure you wanted the 14 MR. WISE:
I am 15 witness to be sure, too.
16 A
It appears to be what 550 is addressing.
17 g
You will note that you wrote a comment 18 on B&W 550 next to the original comment for that 19 time.
Your comment reads, if I am reading it 20 properly, "See if a problem report was ever put in with operations."
21 on this, verify this statement 22 Did you ever find out whether a problem the item mentioned here?
23 report had been put in on 24 A
I don't recall.
g3
\\_ _/
25 Q
Do you recall finding out that the
)
6
354 Billingsley 1
O indicated level for the hot well was incorrect whenever 2
Did you ever the bypass valves were passing steam?
3 4
find out whether that was a true statement /
I vaguely remember discussing this lh 5
A 6
question, but I don't recall what my final conclusion 7
was.
8 Q
Do you know in what manner the hot well 9
level indicator would show an incorrect indication valves were passing steam?
10 when the bypass 11 A
No.
12 Q
You don't recall whether it would show 13 high or low?
14 A
The most detail I can recollect concerning t
the level 15 this is I vaguely recall being told that a floater that floated in 16 in the indicator was like 17 the hot well.
18 Q
What is floater?
19 A
It would be a level indicator that floats i
i I don't recall 20 on water level and I don't know 21 how that floater was arranged.
I don't know if it 22 was like a lever like level that came up it might trip 23 a level.
24 Q
Did you ever attempt to determine the 25 consequences of incorrect indication on the condensate
e 355 Billingsley 1
(',,)
2 hot well level?
'g it wasn't important to address this A
No, 3
4
- question, I understand your testimony, you do
-5 Q
If h
able to determine if recall now whether.you were 6
not i
had been put in before the accident 7
a problem report 8
cn this particular item?
9 J
A No, I don't recall.
the statement Were you able to verify 10 Q
in B&W 550 with the operating i
11 made in the comments, 12 staff?
Which statement are we MR. GLASSMAN:
13
(~N NY talking about?
14 now MR. WISE:
The statement that indicated 15 well was screwed level for the condensate hot 16 valves were passing 17 up whenever the bypass 18 steam.
t e s titao ny MR. GLASSMAN:
There has been no 19 that he did do that.
20 asked him that question.
MR. WISE:
I just 21 ever able to am asking him whether he was 22 I
gain that verification.
23 recall whether I did or not.
i 24 A
I don't
J 25 Q
Would you turn to the next page, please.
/
i
356 Gillingeley 1
(R.]~')
2 Would you look at the comment for the time, and two seconds after the beginning of 3
two minutes 4
the accident.
It reads, if I have it correctly, k
5
" Emergency safeguard features equipment all went indicated by the" 6
to its proper position as 7
A Board.
" board.
It appears to be white -- good 8
Q 9
human engineering."
Your handwritten comment next 10 to that is " Don't understand the point that they trying to make here."
11 are 12 First, let me ask you, do you recall into approximately two minutes 13 learning that at gs 14 the accident the emergency safeguard features
't.J 15 equipment actuated, including high pressure 16 injection?
17 A
No, I don't recall that.
18 Q
You do recall learning that that 19 equipment actuated at some point during the early 20 moments of the accident, whether it was 2:02 or 21 some other point?
22 A
You would have to ask me about specific The only equipment I personally 23 safeguard equipment.
investigation of was the make-up pumps.
24 did an p
Do you recall now why you wrote the 25 Q
'w.-
357 Billingsley 1
~~#
2 comment that you did?
I see 3
A I can speculate based on what I don't 4
here, but I don't recall the comment h
5 recall what I found.
These are very preliminary 6
comments, by the way.
7 Q
Whose are preliminary, yours or the 8
authors?
9 A
My comments are very preliminary.
10 Q
Would you look now at the comment 11 immediately below that for two minutes and four 12 seconds.
Comment reads, " Add at 76" T'N C/
13 A
At greater then.
"at greater than 600 pounds you 14 Q
15 don't get 250 gallons per minute per loop.
You get 16 something less but you get enough."
Your handwritten 17 comment on that, "Must check out, see pump curves, 18 neither EI nor Stafco mentions this."
19 Is that a fair reading of what is there?
20 A
Yes.
21 Q
Do you recall what the original or the 22 underlying comments for two minutes and four seconds 23 referred to?
24 A
No.
<s
(
)
v 25 Q
Would you look at the Stafco report
n
/
358
' illingc1cy 1
23232 as' marked for 2
B&W 466 and turn to page I^';
v You wfil note that the top 3
litigation purposes.
4 comment is listed for two minutes and four seconds and reads, " Reactor coolcnt make-up pump C started lll 5
1 A ande kc running.
6 automatically, leaving pumps 7
Discharge va'ves were open cd the'250 gallon per
'.oop throttled'positiosi" 8
minute per thht?
9 Do you see A
Yes.
10 j
11 Q
Yoc. vill note under the remarks there incompleta discussion is a discussios c[ an in an 12 13 because there arp. sone / blanks'in it, of the fact that i
l
(^)
\\)
14 slight 3y less
<>r somewhat less of 250, gallons per l
15 minute would be expected at reactor coolant pressures l
j 16 other than -- a blank has-been left for some psig.
l 17 Does that nelp refresh,.your recollection 18 as to what th6 original comment and your notation l
19 with respect to it on B&W 2xhibit 550 related to?
l 20 A
-Yes, it does.
21 Q
Isn't it a fact that that relates to the i
1 into the 22 amcunt of high pressure --inj ection flow into the accident?
23 system at approximately two minutes 24 A
That's correct.
/~~N
't. '
25 Q1 Your comment said "Must check out c pump f
1
'..~"
359
'N-a-
Dillingoley b
'1' N.
s Os i
m, -
s 3
\\
4 s
2 curves.
What does that refer to?
3 4
A That refers to an output curve telling what kind 5
you at what various output of pressure, dlk of fuel you'll receive out of the pump.
~
6 i
1 7
Q Where did you find or get a hold of
~
t 8
curves like that?
like that you could get from 9
,.jk Curve,s x
10 maintenance or operations.
recall whether you ever obtained 11 Q
Do you l
12 those curves?
s 13 A
I don't recall.
14 Q
Would you turn to the next page, please, 15 of B&W Exhibit 550, the comment at the top of the for the time three minutes and 26 seconds 16 page is, coolant 17 into the accident it reads, "Say the reactor 18 '
dr' sin tany was liquid full."
Your comment next to 19 that is " Check if there is level indication for the 20 tank.
How'do you know it's liquid full?"
I take it that comment refers to the t
21 22
. reactor coolant drain tank which is connected through 23 the discharge piping to the relief valves at the 24 top of the pressurizer?
25 MR. GLASSMAN:
May I have that read back?
4s s -
9 1
1 Billingsley 360 2
(Question read by the reporter.)
.y
)
%,,,,/
MR. GLASSMAN:
Is that a series of 3
4 questions?
5 MR. WISE:
I am trying to establish lll 6
that we are talking about the reactor coolant 7
drain tank that receives flow from the valves 8
at the top of the pressurizer.
9 Q
That is the one we are talking about, 10 isn't it?
11 A
That's correct.
12 Q
Did you ever check to see if there was 13 a level indication for the tank?
(_,
14 A
I don't recall what I found out with 15 respect to that tank.
I don't know what conclusions 16 I drew.
17 Q
Did you ever find out how the operator 18 would know if it was full of liquid, the second 19 part of your question on your comment?
20 MR. GLASSMAN:
Objection.
First, there 21 may be an inaccurate reading of the comment 9
22 and, second, it's impossible for Mr. Billingsley 23 to testify as to how the operators would know 24 something.
()
25 If you would like to ask him about whether n
1 BillingslGy 361
(
)
2 there was some indication which Mr. Billingsley
,7 3 LJ 3
looked at or whether he spoke to operators 4
and they told him something that they were 5
aware of, that would be appropriate.
ggg 6
MR. WISE:
I don't understand your 7
objection.
8 MR. GLASSMAN:
You are asking Mr. Billingsley 9
to speculate as to what operators would know.
10 MR. WISE:
The question is as he wrote 11 it, "How do you know it's liquid full?"
12 Q
Did you ever get an answer to that
(")
13 question?
L;'
14 A
I don't recall what the answer was to 15 that.
16 g
You look down a little bit further on l
17 the page to the comment listed for the time five 18 minutes and 54 seconds after the beginning of the l
19 accident.
The original comment reads, " Remark,"
20 underscored, " drain tank pressure increase indicates 21 relief from pressurizer."
You have written the "true."
I 22 comment, "on the surface this may" 23 think you omitted the word "be."
"But must look at l
steam tables to make sure steam wasn't passed.
A
/S
!' /)
I 25 safer statement would be:
Pressurizer relieved l
1
1 Dillingoley 362 e',
2 system inventory through PORV, therefore, reactor 3
coolant drain tank pressure increased."
v Do you recall your comment?
4 5
A Yes, I do.
ggg 6
g what would be the relevance of looking 7
at steam tables in connection with this remark?
8 A
Steam tables would be consulted to 9
determine for the given pressure at a point in time, 10 whether you be at a condition to create steam or 11 whether you would be in a liquid or whether you 12 would be in a two-phase flow environment.
13 Q
How would that effect the conclusion 7_
(
)
14 reached in the remark that the drain tank pressure 15 increase indicated an increase in the pressurizer?
16 MR. GLASSMAN:
What the witness had in 17 mind when he wrote this comment, is that 18 your question?
19 MR. WISE:
Yes.
Depending on whether you had steam or 20 A
I wasn't 21 liquid, you could vary tank pressure.
O 22 sure at that point in time whether anyone had drawn 23 any conclusions as to what passed through the PORV.
24 I know there were a number of discussions going on.
f~)
not sure whether or not there was an investigation 25 I am
( _,i
F 363 Billings 1cy 1
2 and I wasn't sure whether-or not there was a
,-~
3 conclusion drawn.
As you may find, some of these 4
some conclusions weren't reached to a l
5 questions --
ll to certain aspects two years later.with respect I
6
- year, of a sequence of 7
of the accident.
For the purpose conclusion, I felt l
until one had drawn that 8
- events,
[
there were substantial 9
that statements stating a fact and g
unknowns and you would be better off 10 refraining from conjecture until proper investigations 11 drawn.
12 had been conducted and conclusions l
Do you know whether any conclusions f
13 Q
to what passed through 14 were ever drawn with respect of the TMI-2 15 the PORV during the early minutes 16 accident?
17 MR. GLASSMANs Conclusions drawn by 18 whom?
19 MR. WISE:
Anyone.
to the best of my knowledge.
20 A
Not 21 Q
Did you ever come to any conclusion as O
in reactor coolant drain tank 22 to what an increase other than relief from the 23 pressure would indicate l'
24 pressurizer?
O
25 A
With respect to this accident?
d t
t
}
I Billingsley 364
)
2 Q
Yes.
3 A
Repeat that question again.
4 Q
Let me back up.
5 Does the remark here that the increase lll 6
in drain tank pressure indicate a relief from the 7
pressurizer?
As I understand your comment and 8
your testimony, you didn't agree with that conclusion.
9 What I am asking now is whether during the course of 10 your investigation and work you ever learned of any 11 other reason for an increase in reactor coolant drain 12 tank pressure of the type seen during the first five
(/)
13 minutes and 54 seconds of the accident at TMI-2 14 besides relief from the valves at the top of the 15 pressurizer?
16 A
Not to the best of my knowledge, no.
17 Q
Would you now go to the next page in 18 B&W 550.
There is a comment at the top of the page 19 for the time 11 minutes and 30 seconds into the 20 accident.
21 It reads, "When did drain tank temperature 22 pass through 212 degrees?
At this point reactor 23 building pressure would have started to rise."
l 24 Unfortunately on the copy we have, your
, ~3
( ')
is partially obscured.
However, the part we 25 comment
365 Cillingolcy 1
2 can read begins, " Diaphragm ruptured, therefore I (c)
Ask 3
don't see what importance this question has.
4 J.F. when he saw rise in reactor building pressure."
First, let me ask you, do you recall now
()ll 5
6 to whom the reference "J.F."
was?
7 A
Yes.
8 Q
Was that Mr. Floyd or Mr. Flaherty?
9 A
Jim Flaherty, a
I 10 Q
Did you ever find out from anyone what i
11 importance the comment on drain tank temperature 12 had?
13 A
I don't recall.
g']i
'w Did you ever find out why someone was 14 Q
15 interested in this question?
16 A
I knew what they were -- what I felt i
l 17 they were loop.ing for.
l 18 Q
What did you feel they were looking for?
19 A
That tank is an enclosed tank so as l
tank remained enclosed, it had no 20 long as that 21 effect on outside conditions.
I felt that they
{
22 were looking to determine when the rupture disc had 23 broken which would relieve pressure from the tank 24 to containment atmosphere.
25 Q
Did you ever ask Mr. Flaherty when a I
I' 366 Billingelcy 1
in reactor building pressure had been seen?
[ )
2 rise
'wJ A
Yes, we discussed that.
3 What did he tell you?
4 Q
We reviewed that A
He gave me an answer.
lll 5
6 together.
We got an answer for that, but I can't 7
recall what it was.
Flaherty getting his 8
Q Where was Mr.
information by the way?
Was he talking to operators 9
10 and operating staff?
route as I did.
He He went much the same 11 A
utilized prior sequence of events.
He utilized 12 the of events which had occurred during 13 graphs
(J knowledge he had gained w'orking
)
L 14 accident, operators, He had on other investigations he had, conducted.
15 16 various sources as well.
immediately beneath 17 Q
The following comment drain tank "If the reactor coolant 18 that reads, to see a pressure rise, 19 relief passed enough water start to reactor building pressure would not 20 If not 3 minute's 21 rise until 14 minutes and 50 seconds.
See O
there another leak (earlier) 22 and 20 seconds -- was From steam generator B7" 23 not reactor building?
Your only comment on that reads, "Stripchart 24 p
drain tank temperature."
'/
25 on reactor coolant
367 Billingsley 1
i Do you recall whether anybody ever
'~
2 3
looked into the matters raised in the comment I 4
just read?
5 A
It looks like that comment is all in llh 6
conjunction with the prior comment we just got 7
through discussing.
On that basis that question you 8
just read would have been approached along with the 9
prior question concerning when the drain tank 10 passed 212 degrees.
It's all part of the same 11 question.
12 Q
Do you recall why the reactor building f^ h start to k/
13 pressure would not have been expected to f
14 rise until 14 minutes 50 seconds into the event 15 if the relief was not passing enough water from the cause a pressure rise?
16 drain tank into the building to 17 A
I think what you are asking for -- would 18 you repeat the question again, please?
19 Q
Let me break it down.
20 A
I had to read the question.
(Question read by the reporter.)
21 22 A
This refreshes my memory, seeing this 23 in context now.
Apparently there is a relief valve on
,s 24 (v) 25 that drain tank.
The first part of your question is
368 Billingcicy 1
relief and this is if you are passing through the
)
2 3
why I would want to take a look at steam tables, 4
et cetera, take a look at what conditions you have k
5 coming out of the tank through the relief.
Apparently 6
that goes to containment atmosphere.
I am not sure.
7 This is long ago.
These questions are 1979.
The only other possible cause would be 8
So it appears on the 9
rupture of the diaphragm.
10 basis of reading this question in complete context 11 that 14:50 maybe, I say maybe, I would have to look 12 at a lot of data, maybe addressing when the diaphragm g
13 ruptured.
(
)
v 14 Q
Do you recall whether an investigation 15 had been made in connection with the sequence of 16 events work to determine when the diaphragm ruptured?
17 A
Yes, I believe so.
18 Q
Do you recall that it was around 15 19 minutes into the accident?
20 A
No, I don't.
21 Q
At the end of the comment there is a 22 discussion or a question regarding whether there 23 had been another leak into the reactor building i
24 perhaps from steam generator B.
rw Y-]
Do you recall whether there was any 25
369 Billingsley 1
aware of in connection investigation that you were
'N -
2 with the sequence of events, to find out whether 3
4 that was the case?
A No investigations that I can recall.
I 5
if any, was You don't know what answer, 6
Q 7
ever arrived at concerning that question?
8 A
No.
Would you turn to the next page, please.
9 Q
10 Look at the comment listed for time 38 minutes 11 11 seconds.
It reads, "Th'ere is conflicting testimony the rupture disc had 12 on whether the operators knew 13 broken."
Next to that in your handwriting is, "QB is_,)
testimony here,"
14 check out Did you in fact check out the testimony 15 knew whether the 16 concerning whether the operators 38 minutes and 11 seconds 17 rupture disc had broken by 18 into the accident?
19 A
First of all, I had a question here of 20 under time.
The time looks substantially out I will attempt to to the other times.
21 sequence as answer your question.
22 Yes, I did take a look at operator 23 testimony on this issue.
~
24
(
's,
\\m/
What did you find out?
/
25 Q
I
370 Billing 21ey 1
w.)
2 A
I don't recall.
3 Q
Would you take a look at B&W 466 which 4
is the draft Stafco sequence of events and turn k
5 to page 23243 as marked for litigation purposes.
6 Would you look at the comment listed 7
for the time for 38 minutes and 11 seconds, the same 8
as in B &W Exhibit 550.
That comment reads, "The auxilliary operator stopped reactor building sump 9
10 pump B."
The remarks under that comment are, "The 11 two reactor building sump pumps had operated for 12 31 and 28 minutes respectively based on the measured 13 capacity of each pump.
Approximately 8,260 gallons 73
()
14 of water was transferred to the auxilliary building.
15 The automatic pumping of the reactor building sump 16 was not considered abnormal since operators knew 17 that the reactor coolant drain tank rupture disc 18 had broken.
Sources for that are data and TMI 19 staff interviews."
20 Does seeing that refresh your recollection 21 as to why the time 38 minutes and 11 seconds appears 22 for the comment made in B&W Exhibit 550 concerning 23 whether the operators knew that the rupture disc had t
24 broken?
g3kj 25 A
It refreshes my memory as to the question.
i 371 Billingsley 1
f 2
But it does not refresh my memory as to when the i
3 operators had known when the dise had broken.
f 4
Q What was the answer as to why 38 minutes h
5 and 11 seconds had been picked as a time to which of the concerning operator knowledge 6
the comment 7
rupture disc blowing was attached?
Could I have that read 9
back?
(Question read by the reporter.)
10 11 A
This comment don't really tell you when 12 the operators knew the disc had blown.
This the fact that you
,s 13 only -- this really only addresses
(
)
\\_ '
sump pump running rather and a
14 have some pumps 15 why nobody considered it has no significance.
It 16 doesn't tell you when they knew the disc had blown.
You had written on B&W Exhibit 550 next 17 Q
18 to the time the question, "Where did this time come 19 from?"
I guess a better way to put my question is:
20 What did you find was the answer to your question?
21 A
I can't say.
I believe we pinpointed 22 it down to a time, but I can't say what that time 23 was.
I'T 24 Q
Would you look down at the bottom of the J
referring to of B&W 550 and note the 25 page we were i
372 Billingoloy 1
31 for the time one hour 20 minutes 2
comment listed
[
l L./
seconds which reads, " Isolate the time then make a 3
4 sequence remark about the relief valve temperatures."
- 402, some writing of various numbers, k
5 Then there is 6
403, 404.
Your comment underneath this item reads, 7
"QB will do."
8 Do you see that?
9 A
Yes.
10 Q
First let me ask you, do the numbers the computer points or I 11 402, 403, 404 refer to called multiplex points 12 think at some point they are 13 on the indicators available in the control room from
(~}
relief valve
'v' computer which would show 14 the plant discharge pipe temperatures?
15 16 A
I don't recall what the multiplex points 17 are for tailpipe temperatures.
Let me have marked as B&W 18 MR. WISE:
It single handwritten page.
19 Exhibit 551 a 20 appears to be in Mr. Billingsley's handwriting entitled "(From Typed Stafco Questions)" and 21 22 labeled " Question 19" and then it has some writing on that.
23 entitled (Single handwritten page 24 marked B&W g
"(From Typed Staf co Questions) "
t
/
25
373 Cillingalay 1
Exhibit 551 for identification, as of this 2
i,/
date.)
3 4
Q Mr. Billingsley, is Exhibit 551 in k
5 your handwriting?
6 A
Yes, it is 7
Q I believe this relates to later Stafco 8
questions, but because it is on the same point, we 9
might as well take it up now.
This document refers to an attached 10 11 computer printout.
I would like to have marked 12 MR. WISE:
()
13 as B&W Exhibit 552 a portion of a computer
%J printout which was produced to us from your 14 15 files.
marked computer printout l
(Portion of a 16 l
17 B&W Exhibit 552 for identification, as of this 1
1 18 date.)
19 Q
Do you recognize B&W Exhibit 552?
A Yes, I do.
20 portion of the computer printout 21 Q
Is that a 22 during the TMI-2 accident?
MR. GLASSMAN:
You are not asking the 23 witness to speculate?
24 7-)
MR. WISE:
I am not asking him to speculate.
l 25
374 Billingsley 1
to 2
Why don't you give him an instruction not
(
/
3 speculate.
Rather than every time I ask him 4
a question instruct him not to speculate 5
every time.
It's getting to be very repetitive lhk 6
each time.
counsel your witness not 7
If you want to for the deposition, 8
to speculate and prepare him 9
I prefer you, as a matter of fact I expect you Occasionally it's all right but every 10 to.
11 other question you tell him not to speculate, 12 it's getting out of hand.
13 MR. GLASSMAN:
I don't think it's getting
(,,)
14 out of hand when you show one sheet of a longer v
it doesn't have any 15 computer printout maybe, 16 identifications at the top of it exactly what 17 it is from and I don't want the witness to 18 guess.
19 A
Yes, this is dated 3/28/79.
Would you look at B&W Exhibit 551.
It 20 g
the
" Based on the attached computer printout 21
- says, You will note following points were printed."
22 j
23 you have a chart there at the left-hand column, a entries for 24 column for the time and you have four g )!
25 the time approximately 5:21 A.M.
\\
l
\\
l n
375 BillingclGY l
is headed "MPX" and The second column 2
fourth
[a) numbs-and the i
three digit identifying r
3 lists the right is headed the third column to 4
column --
" Temperature" and it lists various temperatures i
I 5
218 and and going through 211, I
beginning with 283 6
7 218 is the final entry.
1 and entries?
those columns Do you see 8
A Yes.
9 10 Q
Am I correct that the time column refers I
shown by the 11 to the real time or time of day as I
28, 19797 for the morning of March 12 computer printout in that statement.
you are correct 13 A
- Yes, d
1
('
)
to the multiplex
- %J Second column MPX refers 14 Q
computer printout?
15 point shown on the l
correct in that statement.
16 A
Yes, you are The numbers 402, 403 and 404 refer to l
17 Q
line piping for the discharge 18 the thermocouples top of the from the relief valves from the 19 leading 1
20 pressurizer?
f 21 A
Yes.
9 The final column which is headed 22 Q
for refer to the temperature shown l
temperature would 23 l
indicated?
particular thermocouple 24 that I
A Yes.
25 I
I li
376 Billingsley I
(f 2
Q You made up this chart from the information i
4 3
on B&W Exhibit 552 which is a portion of the computer and I note for the morning of the accident 4
printout 5
that it includes the indication or indications for llI 6
approximately 5:21 A.M.
7 A
Yes.
8 Q
Do you recall now what was the purpose 5517 9
of your making up B&W Exhibit 10 A
I would have to go back and take a look 11 at the original question.
12 MR. WISE:
We'll mark the Stafco I believe we have already done t '8 13 questions
()
14 that.
15 Q
If you would lock at B&W Exhibit 511 which 16 is Mr. Ankrum's memo to Mr. McEwen of November 26, 17 1979 attaching an 8-page list of sequence of events 18 questions dated November 19, 1979 and turn to page You will note the question 19 3 of the 8 pages.
20 numbered 19 references the time one hour and 20 21 minutes into the event.
22 Do you see that?
23 A
yes.
)
20 minutes would correspond 24 Q
One hour and
,r'y
()
25 to approximately 5:20 A.M.
by time of day?
377 Billingsley 1
p A
Yes.
(]
2 Q
on the morning of March 287 3
A Yes.
4 there or the question reads, Q
The comment
'lk 5
6 "What was the exact time when the operator requested 403 data points 402 (followed by a paper roll-down),
7 8
(a keying error), 403 and 404, which resulted in his reading 403, and 403 and 404 as 402, 403 and 4047 9
I 10 What temperatures were read to the Shift Supervisor?"
That's the end of the question for 11 12 item 19.
A Yes.
()
13 l
that help refresh your recollection Q
Does 14 15 theat B&W Exhibit 551, your handwritten comments were answer the question posed in item 19 16 an attempt to sequence of events questions attached to 17 in the i
18 B&W Exhibit 5117
{
A Yes.
t 19 this Q
What is your recollection of what 20 all baout, if you can question and your answer are 21 22 explain it in layman's terms?
23 A
The only thing I can recall is that 24 there were some questions as to what the shift O
for temperature readings on V
supervisor was providing 25
}
378 Billingoloy 1
the relief valves.
/
2 Who raised that question?
Q 3
A I don't recall.
And I was asked to 4
take a look at that statement and verify it or find
!k 5
would have been read.
6 out what in fact Exhibit 551 Your handwritten note on B&W 7
Q does it not, as to how one possibility, 8
discusses may have misread the computer printout?
9 the operators a chart the part where you have 10 I am speaking about two columns.
One has the bottom where you have 11 at reading and the other is possible 12 actual MPX point 13 error MPX 1.
7 '
set of possible N _)
referring to one You are 14 could have been made?
15 errors that 16 A
That's correct.
determine in fact Were you ever able to 17 Q
18 that was the error that was made?
for me There would be no way to --
19 A
No.
20 in hard cold facts to substantiate what error was 21 in fact made.
interview operatord or 22 Q
You didn't find out what they 23 l
follow up their testimony to this particular point?
24 said about 25 A
I may have.
I went through an awful lot
\\-
I u
379 Billing 21oy 1
to try and for some of these questions i
2 of interviews I may have in fact done that.
As 3
find out facts.
4 a matter of fact, I had some of the copies of the h
5 interviews.
You have no recollection today of 6
Q scenario that whether you were able to confirm this 7
Exhibit 551 the bottom of B&W 8
you have charted at remained actually happened or whether it 9
as what an hypothosis on your part?
10 simply never came up with a hypothosis on 11 A
I else's hypothosis 12 this.
This is strictly somebody In
/~.
13 that I was trying to check out and verify.
(
)
i l data, the absence of going to hard cold techn ca 14 absence of that, concerned, in the 15 as far as I was remained word of mouth.
16 there still remained word of mouth?
17 Q
What concerning the error.
This statement 18 A
not convinced In other words, you were 19 Q
in reading the temperature an error had been made 20 that l
computer printout?
21 of the It's not that I wasn't convinced.
A 22 A
and asked to verify it statement was made and I was 23 was either through hard the only way to verify it 24 had been
~
cold data or operator interviews which I ry j
25 i
J
380 Billingsley I
to In the absence of one I would have 2
taking.
[~'}'
as much verification Lj rely on the other to provide 3
4 of the statement as possible.
5 If you are asking me what this is saying, llh this is saying, my 6
I can probably tell you what 7
statement on 551 is stating.
That's all I could 8
do for you.
9 Q
What is your statement on 551 saying?
look and I will tell you.
- 10 A
Let me take a 11 My statement here is saying when the rolled down you have three multiplexer 12 paper was 13 points shown together, 403, 404 and 404.
With
\\_]
in this particular position, 14 the paper rolled down 15 it's possible for someone to interpret those three 16 multiplexer points put together as being 402, 403 17 and 404.
18 So what I am saying is that it's 19 possible for the computer to printout 403 and with 20 the paper rolled down it's possible for someone to 21 read that as 402.
22 Q
Assuming as you did here that they read I
nor the title of 23 neither the multiplexer point 24 the printout, either one of those would have told 25 the reader that he was not getting point 402, the f x.
(_,,/
381 Billingsley 1
out 2
reactor coolant pressurizer relief valve rn (v) temperature?
3 4
A That's correct.
was at Did you ever learn who it (lh 5
Q hour and 20 minutes into the 6
approximately one the relief valve temperatures accident who called up 7
8 on the printer and read them out?
A No, I don't recall finding out who that 9
10 was.
?
B&W Exhibit 550 If you would go back to 11 Q
12 at this point.
Would you turn to the next page in l' 'i 13 B&W Exhibit 550 and look at the comment listed for V
into the accident.
It reads, one hour 33 minutes 14 15
" Remark, initial rise was due to quenching rapid 16 drops were due to cooling."
Then there is a I believe reads, " saturation."
17 parenthetical which 18 Do you see that?
19 A
Yes.
20 Q
Your comment next to that is, or at "Isn't this the the word quenching,
21 least next to 22 same as cooling?"
Beneath that and perhaps referring l
23 to the entire comment, "No reason to put in report I
24 (sequence of events)."
that comment referred
/'s_j)
Do you recall what 25
382 Billingsley 1
["')
2 to, the one for one hour and 33 minutes?
v MR. GLASSMAN:
Mr. Billingsley's or 3
4 both?
5 A
No, I know you are going to refresh my llI 6
memory.
7 Q
If you would look at B&W 466, the 8
Stafco sequence of events, and turn to page 23248, 9
you will see a comment listed there for one hour 10 and 33 minutes which reads, "The control room 11 operators increased high pressure injection flow to the A loop.
12 to 150-200 gallons per minute per line 13 Reactor coolant system pressure peaked and dropped (m-)
'q_,1 14 rapidly and source intermediate range indications 15 sparked upward.
Source left range, source is 16 Nuclear Regulatory Commission's interviews and 17 plan stripcharts."
18 Does that help refresh your recollection l
I 19 as to what comments in B&W Exhibit 550 related to?
20 A
Yes.
21 Q
Did you ever find out that at one hour 22 and 33 minutes into the accident the operators had 23 HPI running?
24 A
I would have to go back and take a look the make-up pump operation.
i/
25 at
o 383 Dillingsicy 1
this remember doing any work on 2
Q Do you
(_j the one for one hour and 33 particular comment, 3
4 minutes?
remember it because of the word A
Yes, I h
5
. I I
6 quenching.
recall about that?
7 Q
What do you the word quenching or the work 8
A About 9
that I had done?
The work you had done.
10 I
Q honest recall very much to be 11 A
I don't 12 with you.
Why don't you tell us what you do recall?
(y 13 Q
(
)
remember the word quenching because 14 A
I from it meant by it.
Quenching didn't know what 15 I
the same as cooling and I 16 my understanding was 17 didn't know what the situation they were trying in the two words.
in the difference 18 to place Did you ever find out?
19 Q
20 A
I believe I did, but I can't tell you 21 what I found out.
the comment concerning l
Do you know whether 22 Q
injection flow f operator increase of high pressure 23 24 was still in the draft sequence of events as of l
in May 19807 gg 1
left the project L
]
25 l
the time you
'~'
J
i 384 Billingsley I
I 2
A I don't know.
Do you recall any discussion about 3
Q 4
whether that comment should be left in, taken out 5
or modified?
6 A
No, I don't.
7 By the way, to the best of my knowledge, ever getting back to me what 8
I don't recall Stafco to their questions, once 9
responses to my answers 10 I completed my work.
I don't recall Stafco getting 11 back to me on it.
you ever recall discussing with 12 Q
Do the the basis upon which Stafco had made
,- )
13 anyone t../
for one hour and 33 minutes 14 entry that appears concerning high pressure injection flow?
15 16 A
I don't recall other than to say the 17 only basis that I can determine right now is as 18 shown in the source is here.
19 Q
I guess I am trying to go behind that i
20 to see if you have any recollection of having any concerning how 21 discussion with the Stafco people g
f 22 they came to the conclusion that high pressure 23 injection flow had been increased at one hour 24 and 33 minutes to between 150 and 200 gallons 4
x_. '
25 per minute per line in the A loop.
I
385 Billingolcy 1
That's making a couple of assumptions.
2 A
(_)
3 Assumption A is that this is Stafco.
If you say 4
it is, I will agree.
I 5
Q we'll be able to prove this is Stafco's 6
report.
The other problem is that Stafco did 7
A 8
a cut and paste on a lot of their work.
They saw in some instances if 9
stuff from other people so --
10 another party who did a sequence of events made So will be carried through by Stafco.
11 an error, it 12 their comments may be exactly the same as comments l
)
13 from some other source.
z,
<.J I don't The answer to your question is 14 15 know how this comment 1:33 came about.
recall any discussion concerning l
You don't 16 Q
l 17 it?
18 A
No, I don't recall.
19 Q
Did you participate in any review of data 20 the reactor coolant system pressure charts to for the period around one hour and 33 minutes 21 i
22 determine what pressure was doing and why at time?
23 approximately that 24 A
I don't recall.
7-Do you know whether anyone did?
Q.)
25 Q
386 1
Billings 1cy 2
A No, not to the best of my knowledge,
)
8v 3
today, no.
4 C
You will note that for the comment in 5
the stafco report, B&W Exhibit 466 at one hour and jll parenthetical in the right-hand 6
33 minutes there in a 7
margin beneath the entry with the letter Q and 8
next to the section for remarks which is blank in 9
this particular draft of the sequence of events, 10 there is a parenthetical with the letter R.
11 A
Yes.
12
.Q Do you have any knowledge as to what 13 those parenthetica.is indicace?
7s
)
14 A
No, I don't remember.
15 Q
Look at the next page of B&W Exhibit 550 16 and the handwritten comnent for one hour and 42 17 minutes following the beginning of the accident.
It 18 reads, " Counts increasing again due to boil off."
19 Your comment on that reads, "What time does this 20 refer to?
Prefer to leave out but this is a true 21 statement."
22 You may wish to refresh your recollection 23 as to what the event at one hour and 42 minutes was.
24 You may do so by taking a look at page 23250 in
,a
(_)
25 BsW Exhibit 466, the Stafco report.
There is an
I s
i s
387 4
~
Dillingsley 1
A for one hour and 42 minutes which reads,
'( ).
2 entry 3
"The source range'c'ount level, followed by 4
intermediate range monitor input start upward 5
trend.
The control room operator reports llk
. t, 6
' emergency borated'.".Under remarks it reads, t.
7 "Over the next 15 minutes source range count rate
' s 8
level increased two decades without exhibiting previcusly observed oscillatory behavior."
9 10 Does that help refresh your recollection
\\
11 as to the comment on B&W Exhibit 550 for one hour to and 42 minutes,and your question with respect 12 n
13 the comment?
(
14 A
Yes, it refreshes my memory.
- However,
,e 15 there is a comment I have here that makes me wonder 16 abou theyntire statement.
I don't know what I N
17 meant by that I questioned it for some reason.
It 18 refreshes my memory.
~
19 Q
Why did you prefer to leave out the N
20 statemen't concerning the t'act that the counts were 21 increasing due to boil off?
22 is I don't know.
23 Q
The counts we are referring to are 24 indication of increasing radiation activity in 25 laymen term in the core; is that right, or the
j
\\
t a
-s
(
1 Billingsley 388
{
(~ )
'w) 3 A
I believe we are talking neutron flux 4
there, yes.
Q The boil off that is referred to in Jgg 6
the comment in Exhibit 550 is the boil off of 7
reactor coolant system inventory?
8 MR. GLASSMAN:
Is that a question or a 9
statement?
10 MR. WISE:
That's the question I am 11 asking.
12 Q
Wasn't that your understanding of this 13 comment?
,r ms L.)
14 A
In light of the comments here on 1:42, 15 I can't necessarily make that statement today.
16 Q
You don't recall what was meant by 1
17 boil off?
18 MR. GLASSMAN:
Are you looking for what i
19 who wrote this meant?
20 MR. WISE:
We don't have that individual 21 here.
We are looking for what Mr. Billingsley 9
22 remembers when he got this set of comments 23 and did some work on it.
He obviously read 24 it.
He wrote a comment on it and he must
/^\\
i._.,)
25 have had some understanding of the time of i
i e
1 Billingsley 389 2
what boil off meant.
I am simply asking (9v) 3 if he can now recall what his understanding 4
- was, 5
A No, I don't.
It could be a couple of lll 6
different things.
Therefore, today, I don't know 7
what I meant or what was meant here although I 8
may have then.
9 MR. WISE:
That concludes my questions 10 on B&W Exhibit 550 which I believe was 11 connected up with the material attached to l
12 B&W Exhibit 512.
j}
13 Q
Going back to B&W 511 which was the Q) 14 November 26 memorandum f3 m Mr. Ankrum.
We have 15 already established there is attached to that a 16 series of questions on the sequence of events.
I 17 believe it is about eight pages long.
18 Do you recall if you ever saw a set 19 of answers to those questions?
20 A
Some of these questions look familiar.
21 I think I developed the answers for them.
was done with the 22 Q
Do you recall what 23 list of questions on the sequence of events that 24 was attached to B&W 5117 Was it given to various 25 people and divided up for individuals to go out and
390 Billingsley 1
[U~)
2-attempt to develop answers?
Are you talking about these questions 3
A 4
here?
5 Q
I am talking about the questions in (ll to B&W Exhibit 511, 6
the eight-page attachment 7
Mr. Ankrum's memo.
8 A
Are you asking me about these questions 9
or the responses?
10 g
Let's take the questions first and see 11 how the responses were developed.
12 A
some of these look familiar to me.
13 obviously I worked on, for instance, number 19
.Os 14 in this package of 511.
Yes, I have seen these 15 questions, 16 g
Do you recall what procedure or what-f 4
I 17 the drill was, if you will, as to how these 18 questions were handled?
These questions may have been split 19 A
I don't up between myself and Jim Flarethy and 20 f
21 know how that split was done.
I knew at one time O
took the sequence of events, eyeballed the mid 22 we 23 point of the package and he got half, I got half 24 and we went off and worked on it.
In areas where 4
he he had particular knowledge or expertise, 25 s_/
t
i 1
i 391 Sillingsley I
i even if I was initially handled those questions, 2
If I had given that to respond to and vice versa.
3 a particular area of expertise, I would get those 4
questions that he may have initially worked on.
ll 5
Who had the area of expertise concerning Q
6 flow?
high pressure injection 7
A Flow?
8 Q
Yes.
9 Or the pumps?
A 10 Q
Flow.
11 A
Nobody.
We both were capable of taking 12 flow based on pump curves.
13 a look at
(
Q I take it you were the person 14
-- primarily responsible responsible for looking at 15 for looking at the operation of the make-up pumps 16 both in their make-up mode and high pressure 17 18 inj ection mode?
A I looked at the pumps strictly from 19 of view, how injection mode point high pressure 20 during the operated during the accident, 21 they were safety injection accident they were operated as 22 pumps or high pressure.
23 Based on what you can recollect on Q
24 did, based on the sequence i
all the investigation you 25
392 Billingsley I
2 of events or anything else that you did, are you x_-)
3 able to state whether the pumps were operated in l
4 the high pressure injection mode between the time 5
they were initially terminated at about the first lll 6
five minutes of the accident and the time that the 7
reactor coolant pumps were turned off at 8
approximately one hour and 40 minutes into the 9
accident?
l 10 MR. GLASSMAN:
Can I have that read l
11 back?
12 (Question read by the reporter.)
T 13 MR. GLASSMAN:
I assume the question is
[^J L
14 related to whether Mr. Billingsley ever made 15 any study or conclusion or in that regard.
You 16 are not asking him now to go back and 17 reanalyze what he did before?
18 MR. WISE:
I am not asking him to 19 reanalyze.
20 A
I took a look at the operation of the 21 make-up pumps during the accident.
I did not 22 evaluate reasons for operator action which is 23 implied in the question.
24 Q
I didn't think it was.
I thought it b
straightforward question.
N-
25 was a
i 393 Billingsley 1
It's implied because the problem with 2
A (O) a make-up pump and it's is it's the make-up pumps 3
looked at those pumps inj ection pump and I 4
a safety whether the accident, during the operation -- during k
5 Whether or I
they were on or whether they were of f.
6 as a safety injection pump that pump operates 7
not conditions.
I did not 8
is determined by plant ing necessarily investigate how the operator was us 9
I am reluctant to make a statement in 10 the pump.
to when looked specifically as 11 that area because I during the the pump was on and when the pump was off 12 13 accident.
/~T 14 Q
Maybe I am confused.
Can you tell from V
whatever they that you looked at, 15 the sorts of data whether that particular pump is 16 may have been, in its high pressure injection mode or 17 operating 18 the make-up mode?
19 A
You can tell in some instances because in and safeguard system comes 20 if the emergency the pump being fired off is fires the pumps off, 21 which is consequence of the safeguard system 22 a
to mitigate the 23 fired off, quote,
- unquote,
't N
24 '
consequences of an event.
would be high pressure Typically that event 25 u
. _ _ _ _. _, - _ _ _ ~.
394 Billingsley 1
',,/
2 injection, that's when it would come in and assist 3
actuation.
The operator can manually turn that 4
pump on and manually turn that pump off.
5 When you start asking about the llk 6
operation, you have to ask are you addressing 7
actuation of the safety system, which in that 8
particular instance is clear and straightforward 9
the purpose of the pump or are you asking when 10 the operator turned it on and turned it off.
In are asking what is 11 that particular instance you 12 operator action, what his response and why is he 13 doing.
I did not address that.
We are addressing (m
)
14 a pump with dual purpose.
15 Q
I am a little fuzzy on what it is you 1
16 can tell by looking at whatever data you have.
17 A
You can tell when the pump is on or 18
- off, 19 Q
You can't tell when the pump is operating 20 in the high pressure injection mode as opposed to 21 the make-up mode unless the high pressure injection 22 has been initiated upon an emergency safeguard 23 features signal?
24 A
Yes, that's true if you are looking l
l Q_,)
at when the pump is on and when the pump 25 strictly 1
395 Dillingsley 1
I
')
2 is off.
There may be particular valve lineups not important to s.s that I am not aware of that were 3
There may be particular valve my investigation.
4 tell you whether or not the pump lineups that may ilh 5
the other, that is being used for one purpose versus 6
safety injection.
I cannot give 7
is, make-up versus I take a look at knowledgeable answer unless 8
you a intended all aspects of the pump operation and its 9
10 purpose, that is, valve positions, how it started, l
11 what the ccaditions are in the system, which may to help you positively identify 12 give all keys purpose of pump operation.
13
(')
't.)
None of your work involved making such 14 Q
15 an analysis?
A I wasn't necessarily, no.
16 looked at, So based on the data you 17 Q
18 you are not able to state today at what times during cf the accident the 19 the first hour and 40 minutes in the high pressure injection pumps were operating 20 mode except for those instances where they were 21 22 actuated upon an ESF signal?
today would say based on my knowledge A
I 23 after which is approximately two and a half years 24 t
i the time period in which I did that report, that is
/~N N'
25 i
396 1
Billings 1cy 2
a true statement.
(
)
x-and the 3
Q Let me go back now to Bsw 511 4
attached set of questions.
It is my understanding i
5 that it was divided up.
You prepared some answers,
'jhI 6
Mr. Flarethy prepared some answers.
I I
7 Were there others who prepared answers 0
to these questions?
9 A
There may have been, but not to the best f
i 10 of my knowledge.
11 Q
Did you send out parts, for instance, 12 to Mr. Floyd, Mr. Miller, Mr. Zewe or others for 13 their response?
('t)~}
14 A
I may have.
15 Q
When you got all the responses from 16 whomever you may have asked plus your responses what was done with I
17 plus Mr. Flarethy's responses, 18 all that?
19 A
I believe they were all packaged up 20 and sent out to Stafco.
f 21 Q
What did Stafco do with them, to your dI>
22 knowledge?
23 A
I don't recall.
24 MR. WISE:
Let me have marked as B&W f'\\
a four-page typed set 25 Exhibit 553 a copy of
397 Billingeley 1
2 of responses labeled "Stafco" typed Al
[
q,)
3 Ankrum.
4 (Four-page typed set of responses 5
labeled "Stafco" marked B&W Exhibit 553 for h
6 identification, as of this date.)
7 Q
Do you recognize B&W Exhibit 5537 A
No, but I recognize my writing.
0 9
Q You do have some handwriting on there?
10 g
y,,,
11 Q
I don't want to waste a lot of time on this, but if you would just very quickly look at 12 13 the numbered ques tions on the list attached to B&W
(']J 14 Exhibit 511 and scan the first couple of numbered w
15 items on B&W Exhibit 553 which to my untutored eye appears to be a set of responses to the very -
16 17 questions asked in 511.
18 Would you see if that helps to refresh 19 your recollection that B&W Exhibit 553 is not in 20 fact the typed set of initial responses or perhaps 21 final responses to the questions in B&W Exhibit 511?
22 A
They appear to be the same questions or those questions posed in 511.
23 to possible responses 24 Q
Do you remember having any discussions
(~~'s S-concerning the responses in B&W Exhibit 553?
25
l U
398 Billingsley 1
2 A
No, I don't.
l
)
remember what, if anything, was
\\J 3
Q Do you 4
done with them?
5 A
No, I don't.
th been reviewing 6
Q The various papers we have seem to cluster around a period early 7
and documents November, perhaps early 8
November through the end of You testified during an earlier 9
December of 1979.
l i
10 portion of your deposition that you continued work until May 1980 when you 11 on the sequence o f events company.
took another position with the 12 further recall whether there were 13 Do you f}
L ;'
memoranda, series of comments and 14 documents, of comments prepared after the set 15 questions that were have been reviewing here today for 16 and questions we 17 November and early December?
I know the work continued with respect 18 A
of events.
19 to other aspects of the Stafco sequence all that was generated as 20 I cannot say that this is 21 a consequence of that work.
22 Q
Besides these materials which we have recall was done 23 been discussing, what else do you i
l on the stafco?
24 various times,
/~,
know we took a look at
\\/
25 A
I
399 Billingsley 1
/~h 2
aside from these questions, took a look at various f
V for compatibility between Stafco's version of 3
times 4
sequence of events and other versions of sequence 5
of events.
So I am pretty sure this is not all.
lll 6
Q Did you write further letters or l
7 memoranda to Stafco commenting upon their draft i
8 sequence of events?
l l
9 A
I don't know if I did.
I know, for f
10 instance, I had written a change order to give them the request of funding to continue work at 11 more 12 Ed Wallace.
13 Q
What is the best of your recollection 7"x to how you worked with Stafco, say, from January 14 as i
15 of '80 through May of '80; was it face-to-face, i
16 over the telephone or correspondence?
17 A
Correspondence and telephone.
18 Q
You continued to deal primarily with 19 Mr. Ankrum?
20 A
I think I had a lot of conversations the back of my mind it seems 21 with Mr. McEwen.
In conversations with Mr. McEwen than 22 like I had more l
l 23 Mr. Ankrum.
I Did you make notes of your conversations?
24 g
notes similar 25 A
Yes, with respect to I
400 Billingsley I
2 to what you have seen that I have done in the past.
r^x
()
whether you retained those 3
Q Do you know 4
notes in any file?
- I 5
A I have turned everything over.
Anything for me not to touch.
have would be back in my office 6
I labeled.
in boxes and they are 7
They are For whatever reasons we 8
MR. WISE:
seem to have nothing after this sequence of 9
10 memoranda.
I would obviously like to ask further notes or 11 Mr. Glassman if there are 12 documents referring to work done on the 13 stafco sequence of events following the
(~}
14 memoranda and notes that we have already
'w) we obviously would like to 15 marked here today, 16 have them produced.
17 Q
My recollection, Mr. Billingsley, in 18 that as of the time that you changed positions 19 May 1980, the staf co report had not been completed; 20 is that right?
that is a 21 A
To the best of my knowledge, l
l l
22 true statement.
23 Q
Were there a series of drafts that i
working on I
Stafco prepared over time while you were l'
24 l
(3
(_)
25 the project?
l l
1 401 Dillingsley 1
recall working with one draft, 2
A I only
[v) there may have been 3
but there may have been mvre There may have been 4
one before the one I got.
h 5
others subsequent to the one I got.
recall on a weekly or monthly 6
g You don't i
update reflecting all 7
basis that there would be an 8
the comments received to that point?
9 A
No.
I 10 Q
At most, the one that you had and you i
it was not i
have been one other but 11 think there might there were a series of drafts l
I regular thing where 12 a
/~'i 13 each one improving on the last?
'<.,]
14 A
That's ture.
I don't know what we used of events.
the final sequence 15 as
'. e i t ?
Who took over your job when you 16 Q
l 17 A
I don't know.
18 MR. WISE:
That's all I have.
g l
19 (Recess taken.)
l 20 EXAMINATION BY MR, GLASSMAN:
21 Q
I show you what has been marked as 8
8 G
Do you recall being asked some l
22 B&W Exhibit 456.
earlier in your testirony with regard 23 questions 24 to that document?
l (r) l 25 A
yes, I do.
1 1
I 402 Billingsley 1
I would like you to open up to pages
[~D 2
Q
%)
12 to 14 of that document for a moment.
3 Do you see those pages?
4 A
Yes, I do.
k 5
few moments to review l
would you.take a
6 Q
7 those pages, please?
8 A
Yes, I recall these.
to review those Have you had a chance 9
Q 10 pages?
I have seen it before.
A
- Yes, 11 the source of the information 12 Q
What was 13 contained in these pages regarding the nature of
("]
sites other than TMI?
v 14 PORV failures at The source?
15 A
16 Q
Yes.
17 A
The source of this information is taken To investigate from the Kemeny Commission report.
18 19 to TMI accident.
456 otherwise referred to When B&W Exhibit 20 Q
any knowledge' did you have TDR-160 was prepared, 21 as the Kemeny Commission's to or understanding as 22 of information?
23 sources A
No.
24 refer next to Table 2 g-s I would like to 25 Q
403
'Dillingsley 1
456 which appears on page 26 through 2
of B&W Exhibit
()
bears the identifying 39 of this exhibit.
It 3
4 numbers for purposes of this litigation 1307 through
'lh 5
1320.
review Have you had an opportunity to 6
7 those pages?
8 A
Yes.
for us the Can you briefly describe 9
Q of the material on those pages?
10 nature These are statements provided by the 11 A
12
-Kemeny Commission report on PORV failures and this particular data has been extracted verbatim from 13 (V~}
14 that commission report.
I would like you to turn to page 12 of 15 Q
16 B&W Exhibit 456.
The first paragraph on that page 17 begins with the sentence, "A more complete list of 18 PORV failures is contained in the Technical Staff the Kemeny Commission."
19 Analysis Report to and concludes The paragraph continues 20 21 with the following sentence, "It should be further 22 noted that the failures at Beznau (Westinghouse and with a power operated globe valve) 23 Plant f
with a Crosby PORV) do not 24 Davis-Besse (B&W plant (O
consideration if evaluating the reliability of
)
\\~'
25 merit
404 Billingsley 1
(m l
)
2 the Dresser PORV."
v 3
Do you see that sentence?
4 A
Yes.
5 Q
What was the basis of the statements lll 6
made in that last sentence?
7 A
The basis of these statements are from 8
the comments made in the Kemeny Commission report.
9 Q
When B&W Exhibit 456 also known as 10 TDR-160 was prepared, had you become aware of more 11 than one failure of the PORV at Davis-Besse?
12 A
Yes, there were two that I became aware of.
13 Q
Referring to pages 36 and 37 of B&W
[~ ;
'xs '
14 Exhibit 456 which have the pages indicated for 15 purposes of litigation number 1317 and 1318, could 16 you tell us what those two pages represent?
17 A
This is an accounting from the Kemeny 18 Commission report of two failures at Davis-Besse.
19 Q
Did you at any time perform any 20 independent investigation of the reasons for the 21 Davis-Besse PORV failures which are described at 22 pages 36 to 37 of B&W Exhibit 456?
23 A
No.
24 Q
Looking now at page 37 of B&W Exhibit
('y 25 456, bearing the page number for purposes of
405 Billingsley 1
2 litigation number 1318 it starts with the heading
(,,/
3 "Plante NSS-14 Davis-Besse I," Roman numeral one, and 4
it continues later on in bold face type the 5
notation, " Type of Malfunction:" then continues, lll 6
" Pilot valve stuck open during PORV testing."
Do you see that?
7 8
A Yes.
9 Q
Under that there is a notation " Summary 10 of Incident" and after a colon it continoes with a 11 sentence, "PORV was being tested following pilot 12 valve replacement as a result of incident described
,rx 13 in SPR 369."
- v Do you know what was meant by SPR 3697 14 15 A
No, I don't recall.
in this Referring to the prior page 16 Q
17 document, page 36, there is an indication, the 18 fourth line of that page of an SPR number 369.
19 Does that refresh your recollection to the meaning of the reference SPR 369 which 20 as 37 of B&W 4567 21 appears on page 22 A
Yes.
refresh your recollection?
23 Q
How does that 24 A
It's referring to a prior event where
,y 25 they had problems with the relay and it caused the
(
i R.J
406 Dillingsley I
to cycle numerous times.
O) 2 valve
(
Do you know the origin of the SPR 3
Q 4
numbers?
i 5
A No.
Ih 37 of B&W Exhibit Continuing on page 6
Q further bold face heading 7
456, there is a it reads as follows,
" Resolution," and after a colon 8
came to the site and "A Crosby representative 9
the after inspection he recommended increasing 10 stem and nozzle, valve 11 clearances between pilot The paragraph continues, 12 eliminating some binding."
i the time you prepared this document, At 13
[~')
the terminology what was your understanding of V
14 stem and nozzle"?
valve
" clearances between pilot 15 MR. WISE:
I object to that.
There 16 this witness examined is no foundation that 17 is the operated valve which 18 a Crosby pilot 19 subject of the comment on page 37.
Until you foundation, I don't established that I
20 have competent know how he can possibly give any l
21 testimony concerning the clearances between 22 on a Crosby valve.
the valve stem and nozzle 23 I
The question is not MR. GLASSMAN:
24 the Crosby valve.
O directed particularly to 25 I
1 407 Billingsley 1
in general whether The question is directed
's-)'
/
2 this witness had an understanding of what 3
" clearances between was meant by the terms 4
k 5
pilot stem and nozzle.
asking him to MR. WISE:
You are 6
in a writing he didn't interpret something 7
from the Kemeny He said it came 8
prepare.
know where the Commission and he doesn't 9
it.
Kemeny commission got 10 to a asking him to speak If you are 11 12 specific comment, which relates to a Crosby I don't think my objection stands.
13
/
- valve, f
s,
(,l testify foundation for him to 14 there is any to the construction and operation of that 15 as 16 valve.
MR. GLASSMAN:
We agreed that this 17 18 witness has not laid a foundation for The examination of a crosby valve per se.
19 to whether this 20 question is simply directed an understanding or had an witness has 21 understanding at the time this document was 22
" clearances between prepared of the meaning of 23 24 a pilot valve stem and nozzle" in any pilot i
U,/~N 25 operated relief valve.
r V
4 408 J
Billingoley 1
My objection stands unless I
MR. WISE:
G 2
/
this witness has
()
foundation that I
you lay a 3
operated relief an investigation of pilot made 4
in general and can speak with some valves h
5 only the Dresser valve but authority not 6
hat may be the crosby valve and other valves t i
7 on the market.
8 You are helping to MR. GLASSMAN:
am trying to make.
l 9
I the very point establish 10 ion the lack of particular investigat
?
- Namely, 11 Without in this regard by this witness.
12 to have really would like I
regard to that, 13 to edify
-s (V
answer the question jus t i
the witness 14 to his understanding for us on the record as 15 pilot valve stem of clearances between the 16 operated relief valve and nozzle in a pilot 17 of manufacturer.
regardless 18 for the My objection stands MR. WISE:
19 reasons I stated.
20 understand the' that I don't I will say 21 If you this line of questioning.
purpose of 22 this is a verbatim to stipulate that want us 23 l
the Kemeny Commission and GPU report out of 24 for this or will held responsible will not be s_)
25 t
409 Cillingsley 1
j admission to GPU, if that's not be held as an
/'~N 2
(
)
let's go to lunch.
I don't the purpose, 3
understand since he already testified that 4
investigation make an independent he did not 5
and he copies this out of the Kemeny Commission.
6 MR. GLASSMAN:
I will accept your 7
8 stipulation but I would like an answer to the can feu more and then we 9
question.
I have a 10 go to lunch.
MR. WISE:
My objection stands.
11 12 Q
Mr. Billingsley, you may answer.
13 A
I can't say that I do.
I am familiar
(~}
14 with the stem and nozzle components but I am not
'w, '
15 sure what is meant by clearances here.
the TMI-2 PORV have a pilot valve 16 Q
Does 17 stem?
18 A
Yes, it does.
19 Q
Does it have a nozzle?
20 A
Yes, it does.
B&W of your work on During the course 21 Q
G 22 Exhibit 456, TDR-160, did you ever review or 23 investigate the clearances between the pilot valve the TMI-2 PORV?
24 stem and the nozzle on (3
25 A
Never did.
410 Billingsley 1
(_j 2
Q Page 37 of B&W Exhibit 456 continues A
(
\\
"In addition, the pilot valve with the statement, 3
adjusted so that maximum travel is 0.125 inches 4
was 0.375 inches."
rather than the previous k
5 Do you see that statement?
6 A
Yes.
7
- document, the time you prepared this 8
Q At an understanding of the meaning of 9
did you have
" maximum travel" in connection with PORV's?
10 the term I
same objection stands.
MR. WISE:
My 11 is any foundation qualifying 12 don't think there to expert with respect this witness as an 13
(,/
14 PORV valves generally.
MR. GLASSMAN:
We were not trying to 15 such.
I am trying to find out 16 qualify him as in that regard.
if he had an understanding 17 MR. WISE:
My objection stands.
18 l
MR. GLASSMAN:
You may answer.
19 an understanding of A
No, I do not have 20 the valves are 21 what was meant there only because 9
22 small, extremely small valves.
(
B&W course of your work on 23 l
Q During the l
24 Exhibit 456, also known as TDR-160, did you ever r'~S the TMI-2 the maximum travel on
/
25 /
review or investigate
411 Cillingsicy 1
g3 2
PORV?
)
3 A
Not to the best of my knowledge.
37 on B&W Exhibit 456, 4
Q At the end of page "B&W Follow-up Action,"
5 after the bold face heading not considered 6
there appears the sentence, "None this is our only Crosby PORV."
7 generic since that?
8 Whose conclusion was I don't know.
This was taken from the 9
A I
10 Kemeny Commission report.
Do you know to what party the word "our" 11 Q
\\
12 refers to?
You are wasting I
s 13 MR. WISE:
I object.
(v) our time with this.
14 l
15 A
No, I don't.
already testified he didn't 16 MR. WISE:
He How could he possibly answer the 17 write this.
18 question?
answered the 19 MR. GLASSMAN:
The witness 20 question.
]
MR. WISE:
I have made my objection.
I 21 g
further questions.
22 MR. GLASSMAN:
I have no 23 (Time noted:
1: 00 o' clock P.M.)
I 24 QUINCY BILLINGSLEY, III g
(,jl to before me 25 Subscribed and sworn 1982.
this day of
412 1
CERTIFICATE
-1 STATE OF NEW YORK
)
3
- ss.:
COUNTY OF NEW YORK
)
4 I,
CATHERINE COOK
, a Notary
( 'll 5
Public of the State of New York, do hereby 6
certify that the continued deposition of 7
QUINCY BILLINGSLEY, III was taken before 8
February 25, 1982 consisting me on 9
411 332 through of pages 10 I further certify that the witness had 11 been previously sworn and that the within
(N transcript is a true record of said testimony;
( -)
13 That I am not connected by blood or 14 marriage with any of the said parties nor 15 interested directly or indirectly in the matter 16 in controversy, nor an I in the employ of any of the counsel.
18 IN WITNESS WHEREOF, I have hereunto set my 19 hand thi3 ll k day of kd NM
,1982.
20 g )\\0Aun P ;
g 22 if L
23 CATHERINE COOK
(
24 m
25 6
l 413 Fobruary 25, 1982 INDE X EXAMINATION BY PAGE WITNESS 333 Quincy Billingsley Mr. Wise (continued) 401 Mr. Glassman EXH I BIT S FOR IDENT.
B&W EXHIBITS i
550 14-page set of handwritten notes 342 dated November 8, 1979 entitled 372 551 Single handwritten page
"(From Typed Staf co Questions ) "
373 l
552 Portion of a computer printout 553 Four-page typed set of responses 397 I
labeled "Stafco" l
l l
1 l
R.)
,