ML20072J005
| ML20072J005 | |
| Person / Time | |
|---|---|
| Site: | Three Mile Island  |
| Issue date: | 02/02/1982 |
| From: | Broughton G, Broughton T GENERAL PUBLIC UTILITIES CORP. |
| To: | |
| References | |
| TASK-*, TASK-03, TASK-04, TASK-07, TASK-10, TASK-3, TASK-4, TASK-7, TASK-GB NUDOCS 8306290865 | |
| Download: ML20072J005 (154) | |
Text
sa f) UNITED STATES DISTRICT COURd SOUTHERN DISTRICT Or N2W YORX
_______________________________________x GENERAL PUBLIC UTILITIES CORPORATION, :
) JERSEY CENTRAL POWER & LIGHT COMPANY, i, METROPOLITAN EDISON COMPANY and :
PENNSYLVANIA ELECTRIC COMPANY, Plaintiffs, 80 CIV. 1683
=against- (R.O.)
THE BABCOCK & WILCOX COMPANY and J. RAY McDERMOIT & CO., INC., s Defendants 6 :
I
_______________________________________x i
Deposition of the plaintiff, GENERAL PUBLIC UTILITIES CORPORATION, by T. GARY f
BROUGHTON, taken by defendants, pursuant to Notice, at the offices of Davis Polk &
Wardwell, Esgs., One Chase Manhattan Plaza, New York, New York, on Tuesday, February 2,
1982 at 9:45 o' clock in the forenoon, before Nancy A, Rudolph, a Shorthand Reporter and Notary Public within and for the State of p(. i
( New York, 8306290865 820202 PDR ADOCK 05000289 T PDR O DOYLE REPORTING, INC.
\
, CERTIFIED sTENOTYPE REPORTERS 369 LrxlNGTON AVENur WALTER SHAPIRO C.S.R. Nrw YostK. N.Y. 10017 CH ARLES SHAPIRO, C.S.R. TELappons 212 - 867-8220 T * - -v
1 2 s
2 'A p p e a rance s :
3 KAYE, SCHOLER, FIERMAN, HAYS & HANDLER, ESQS.
Attorneys for Plaintiffs 4 425 Park Avenue New York, New York BY: STEVEN GLASSMAN, ESQ.,
6 -and-JOHN EICHEMEYER, 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.,
13 ,
of Counsel 14 i 15 Also Present:
3 16 NINA RUFFINI 17 -oOo-18' ' IT IS HEREBY ST1PULATED AND A' GREED by and 19 , between the attorneys for the respective 20 parties hereto, that)the sealing, filing and 21 certification of the within deposition,be, and r
i 22 the same hereby are, waived; and that the i
l 23 transcript may be signed before any Notary 24 Public with the same force and effect as if
{)
25 signed before the Court.
5 t
i
1 3 t
N -
2 IT IS FURTHER STIPULATED AND AGREED 3 that all objections, except as to the form 4 of the question,.are reserved to the time of 5 trial.
6 -oOo-7 8 T. GARY B ROU GHTON , having 9 been first duly sworn by the Notary Public 10 (Nancy A. Rudolph), wrc examined and testified i
11 as follows:
12 EXAMINATION BY MR. WISE:
) 13 Q Mr. Broughton, would you give the reporter 14 your full name and current business address for the 15 record?
1 .
16 A Thomas Gary Broughton. I am with GPU 17 Nuclear, 100 Interpace Parkway, Parsippany, New 18 Jersey.
19 Q What is your residence address?
20 A 8 Ripplewood Drive, Lake Hopatcong, New 21 Jersey.
l (L 22 Q How long have you been employed by GPU l
l 23 Nuclear?
, ~T 24 A GPU Nuclear just became a company a few
~.)
25 months ago, but I worked for and I have been with i
L
1
\
1 Broughton 4
,~ -
- 2 GPU Nuclear since it was formed. I have been with 3 the service company prior to GPU Nuclear since May )
4 of '76. It's about five and a half years.
( 5 6
MR. WISE: Mr. Glassman, we have adopted a convention of exchanging resumes. I don't 7 know whether you have one for Mr. Broughton.
8 If you don't, we do.
9 MR. GLASSMAN: I believe that you are 10 referring to a resume that was p epared in 11 conjunction with restart hearings which you do 12 have and which we do not have an additional
() ..
(_)
13 resume.
14 MR. WISE: I would like to have marked 15 as B&W Exhibit 387, a copy of what appears to 16 be a resume for Mr. Broughton, whibh I believe 17 was prepared in connection with his testimony l 18 during the TMI-1 restart hearings.'
l 19 (Resume of T. Gary Broughton marked B&W
! 20 Exhibit 387 for identification, as of this i
i 21 date.)
l 22 Q Now, Mr. Broughton, have you seen Exhibit l
l 23 387 before?
'N l 24 A Yes, I have.
i N_<
25 Q could you describe it for the record?
l
1 Broughton 5 em -
ss - 2 A It is a resume which I prepared for use 3 as a witness in the TMI-1 restart hearings.
4 Q Do you know about when you prepared this, l'
5 sometime in 1980?
6 A I believe it was in 1980. Probably in 7 the summer.
8 Q Could you tell us for the record what 9 additions to the resume should be made to bring it 10 up to date from the time it was prepar d in 1980 to 11 the present, if any?
12 A Under experience I would now add the
,b) q,j 13 position which I currently hold in GPU' Nuclear which 14 is the Systems Analyst Director and I would not make 15 any other changes.
~
l 16 Q The resume indica'e t .at you graduated 17 from Dartmouth College in 1966 with a B.A. in .
18 mathematics; is that correct?
l 19 A Yes, it is. -
20 Q Have you had any other formal education l
21 since that time?
l 22 A I have not had any formal education l
23 through college or university or any other l
l (~N 24 correspondence courses or night courses that might l Q)
- 25 be considered formal education. I have listed the l
1 Broughton 6
(~ 2 education I have had as part of the navy, but outside 3 of the navy I have not had any education.
4 Q Your resume indicates that you joined the 5 navy immediately upon graduating from college; is 6 that right?
7 A Yes, it is.
8 Q Did you go immediately into the nuclear 9 navy, if that is the proper term?
10 A when I went into the navy,( it was as 11 part of the nuclear program. The first several months 12 I had duty in the navy it was outside of the
(~h s.,,) 13 nuclear program, it was simply a holding period to 14 get into a class in the nuclear ~ program.-
15 Q And your resume indicates that you were 16 in the navy for ten years from 1966 to 1976. Were 17 you in the nuclear part of the navy throughout that 18 period?
~
19 .A Yes, the entire time I was cohsidered 20 part of the nuclear navy. Some of my assignments 21 were not directly related to nuclear power, but they 22 were ones which for career reasons, someone who was 23 in nuclear power would be assigned to as part of a
- 24 nuclear development program.
(v~}
25 Q During the time you were in the nuclear i
1 Broughton 7
\- 2 navy did you ever have any responsibility for training?
3 Did you train other people?
4 A Yes. I spent two years stationed at 5 a prototype which is a training facility and during 6 some of that two-year tour, I was involved in 7 training the people who would be power plant operators 8 and also training staff members at the prototype.
9 In addition, part of my job as the engineer officer 10 on board an attack submarine was to train the crew t
11 members that were part of that nuclear engineering 12 department on the submarine.
O Let me go back to the firs [ thing that
'O 13 Q 14 you mentioned, the two years at a prototype plant.
15 First, and recognizing that there may be 16 areas here that you cannot discuss because they 17 may be covered as national security matters, I take 18 it the prototype plant was a nuclear plant of some 19 sort? '
20 A It was a nuclear plant.
21 Q The individuals whom you trained to 22 operate ~were they enlisted personnel or officers?
23 A They were both enlisted personnel and 24 officers. In addition, there were some contractor 25 civilians who were enrolled in those training programs.
1 Broughton 8 A
2 Q Did your training responsibilities 3 include training on, if you will, the basic 4 fundamentals of reactor operation?
5 Mr. Broughton, I don't mean to confuse
'6 the issue, I am simply trying to get a picture as to 7 whether your training responsibilities related to 8 something that was relatively esoteric and specific 9 to this reactor or whether you had a broader training 10 program and in effect were training dgaling, if not 11 with people who were raw recruits, at least people 12 who knew very little about nuclear power and in 13 effect you were having to teach them the basics of 14 what is a reactor and how does it heat up the water 15 and so on and so forth. I'm trying to get a basic 16 idea of what your training functions werb.
17 MR. GLASSMAN: There are a couple of 18 questions here. I may be slightly' confused 19 now. It appears there is one set of questions 20 which related to the kinds of people, the 21 experience of them, who were being trained; C- 22 the second question related to the nature of l
23 the training offered in terms of some concept 24 of basic training, whatever that might be.
{S N/
25 Do I understand that there are two
1 Broughton 9 (x
~
l 2 separate sets of questions?
3 MR.. WISE: I thought I had gotten an 4 answer to the first question when I was told he trained enlisted people, officers and
.{ $ l 6 civilian contractors. Now, I am really trying 7 to find out what type of training he gave, 8 whether it was more basic or whether it was 9 related to the specifics of the system and 10 somehow tied specifically to th(s particular 11 plant.
12 A Perhaps, if I indicate the type of i -
13 training that these people went throudh and then 14 where I interacted with them, that will address your 15 question. !
16 The navy nuclear power program has two 17 major phases. One is a classroom type phase which I 18 is conducted separately from the prototype in a 19 different physical location and that is the phase i 20 in which the basic principals and general concepts 21 are primarily covered.
22 The prototype phase follows the classroom 23 phase and the general focus of the prototype phase t
i 24 is to then begin to apply those basic concepts to 25 operation of a specific power plant. So our focus
1 Broughton 10 (m
%-) 2 at the prototype was really to train people how to 3 apply what they learned in terms of basics to the 4 operation of the specific power plant and to insure 5 that they developed other skills like standing watches, 6 taking logs, supervising the operation of power plants, 7 things which could be better taught at the prototype 8 as opposed to in a classroom.
9 Q Are you familiar with the term simulator?
10 A Yes.
11 Q How would you compare a prototype to a 12 simulator, or are they comparable?
13 A Well, let me start with sihulator.
14 Simulator is used in many different contexts and if 15 the -- if we compare a simulator that might be 16 used for training individuals in how a ndelear power 17 plant worked and call it a training simulator and 18 then compared that to prototype, there are many 19 differences and there are many similarities.
20 Q I guess, Mr. Broughton, what I am driving 21 at is would it be fair to say to some extent what 22 you were doing at the prototype was in any way 23 comparable to the training similarities used in the 24 nuclear power district?
25 MR. GLASSMAN: I am not understanding l
1 Broughton 11 r'% -
- 2 what the general question relates to.
3 Mr. Broug4. ton already told you there are 4 similarities and differences.
( 5 6
MR. WISE:
Mr. Broughton?
Is the question clear to you, 7 THE WITNESS: Would you mind repeating 8 it?
9 Q Where was this prototype located? ,
10 A This prototype was in Wesg Milton, New 11 York.
12 Q What exactly was it a prototype of?
13 A It was a prototype of a po'wer plant 14 which was first installed in a small nuclear service 15 ship. .
16 Q This prototype in New York was on land?
17 A It was on land.
~
l 18 Q What was the purpose of having a prototype i
i
! 19 as you understood it? Was it to perform a training l
( 20 function or was'it experimental?
l i 21 A The prototype performed several different 22 functions. One of its functions was training. I 23 was involved in that function. There w re other 24 functions which had to do with validating particular 25 design features of plants and exactly what proportion l
l t . - ..- -__ .-. . _ _ _ _. . _ _ .
1 Broughton 12 s i' -
2 of the facility was used for which features, I don't 3 know.
4 Q I think you have answered my ques tion as
{ 5 far as the use of the prototype for training goes 6 which is what I was trying to get out earlier by 7 the comparison of the simulator.
8 During the course of your stint in the 9 nuclear navy, did you have any occasion to be involved 10 in the preparation or approval of opeqating procedures 11 for nuclear reactors?
12 A I was involved in preparation and review
( 13
~
and approval of procedures which were used on the 14 ship that I was the engineer officer aboard. However, 15 these procedures generally applied to the steam plant 16 rather than the reactor plant and the navy nuclear 17 program. The reactor plant procedures were provided 18 to the ships by the naval nuclear program that was 19 based in Washington, so your procedural writing and 20 approval was limited to those things which did not 21 come under the cognizance of the navy nuclear program.
22 Q Would that be comparable to the secondary 23 side of the plant in a commercial nuclear power plant?
24 MR. GLASSMAN: Would what be comparable?
25 MR. WISE: The steam procedures that he
1 Broughton 13
(~N b 2 mentioned or the procedures for the steam side 3 of the system.
4 MR. GLASSMAN: I am not sure what you 5 mean by comparability of procedures.
{
6 MR. WISE: I am trying to compare the 7 difference between when he was in the nuclear 8 navy and the kinds of procedures that would be 9 available at a commercial nuclear power plant.
10 MR. GLASSMAN: I don't kno.w how you 11 can compare generally procedures of this sort.
12 I mean, if you are asking whether there were
(~
i 13 procedures applied to a steam p ant, I think 14 that's been answered.
15 MR. WISE: I don't know that anybody 16 reading this record knows exactly what a steam 17 plant is in a nuclear navy ship. I am trying 18 to make the record clear, what he did and l '
i 19 didn't do.
t 20 MR. GLASSMAN: I suggest if what you are 21 trying to find out is what the nature of a l
' C 22 steam plant is on the kind of a ship that 23 Mr. Broughton is testifying about, you just
(~N 24 ask him, but to start relating procedures into
\_]
l 25 some general comparable sense I think is 1
1 Broughton 14 D
~
2 simply confusing issues and not readily 3 understandable.
4 MR. WISE: I think you are just slowing this deposition down for some reason.
{ 5 6 BY MR. WISE:
7 Q Mr. Broughton, in a nuclear commercial 8 facility you are aware there is a primary side and 9 a secondary side; are you not?
10 A In a commercial pressurized water reactor, 11 yes.
12 Q The primary side contains the reactor n '
k_) 13 core; is that right?
14 A Yes.
15 Q And the secondary side produces steam which e
16 runs a turbine generator; is that right?
17 A Yes.
18 Q Now, in the nuclear navy I tak'e it that 19 one of the purposes of the reactor on the~ ship was 20 to produce steam?
21 A That is correct.
L 22 Q Those are pressurized water reactors as 23 I understand it?
24 A Yes.
25 Q They have a primary side and a secondary
1 Broughton 15 s
2 side?
3 A Yes.
4 Q With respect to the procedures that you 5 mentioned, that you were involved in reviewing,
(-
6 preparing and approving, did they relate to the 7 secondary side of that system?
8 A They did. In particular, they related 9 to systems like condensate systems, feedwater systems 10 and we also were involved in non-propulsion plant 11 procedures.
12 Q You did not work on any procedures while
(")
(_) 13 you were in the navy that would be effective on the 14 primary system? .
15 A We did not write any or approve any 16 procedures which would apply to the primary.
17 Q While you were in the nuclear navy, did 18 you have occasion to perform any safety snalyses 19 with respect to nuclear reactors? -
20 A safety analyses is a rather broad term' 21 which was -- I don't recall using that term in
(_ - 22 conjunction with my work in the naval programs.
23 Q Just so that I am clear on this and the
("h 24 record is clear, when I use the term safety analysis, LJ 25 I am referring to the type of work that is performed
1 Broughton 16
(~
\~J - 2 under that title and has become a sort of term of 3 art in this litigation.
4 You are familiar, I take it, with the
( 6 5 concept of a safety analysis performed for licensing purposes on a commercial nuclear reactor?
4 7 A I am not familiar with any particular 8 definition that safety analysis may have taken as 9 part of this proceeding. There are several things 10 that I would associate with the term' safety analysis, 11 some of which I have been involved in and some of 12 which I have not.
f,_)/ 13 Q Let's take, for instance,'your resume 14 which you wrote. If you would look down!at the 15 second paragraph under the experience section, you 16 will see in the second sentence you have written, 17 " Performed and supervised nuclear licensing,
! 18 environmental licensing and safety analysis for 19 oyster Creek, Three Mile Island and Forked River l 20 plants."
i 21 Now, that section refers to a period of
(- 22 time when you were out of the navy and employed by i
23 GPU, but my question is now when you wrote this 24 " safety analysis," what did you have in mind?
25 A The safety analysis that I was involved
- - - - - , --- - w -w m_,-
9-. 9------y- y - - - - -
.-- - . =_ - ..
1 Broughton 17 b,% /)
2 in during that period of time were analyses of plant 3 response given certain design basis accidents.
4 Q Now, my question is, during the time you 5 were in the nuclear navy, did you ever have occasion
{'
6 to perform similar analyses as you have just described 7 you did?
8 MR. GLASSMAN: By similar you are 9 referring to analysis of plants response with 10 respect to design basis accidents?
11 MR. WISE: Yes, that's what I believe he 12 defined safety analysis to be as he uses the
~
13 term.
14 A In the navy I had no involvement with
~
15 performing analyses that would evaluate the plants 16 with respect to design basis.
17 Q While you were in the navy, did you have 18 any occasion to work on computer modeling in 19 connection with a nuclear power plant? -
20 A No, I did not.
21 Q Your resume indicates that you left the 22 navy in 1976 and joined GPU Service Corporation.
23 What was your first position there?
(~N 24 A I was employed initially as a licensing 25 engineer.
t 1 Broughton 18
- 2 Q What were your duties and responsibilities 3 in that position?
4 A As a licensing engineer when I first 5 began to work for GPU I was assisting in the final
{ ,
6 stages of licensing of Three Mile Island Unit 2.
- 7 What types of things did you do in order Q
8 to render such assistance?
]
9 A I was primarily involved in the open l
10 issues from the safety evaluation repo.rt and in l 11 attempting to close those issues by providing j 12 additional information or analyses or whatever, was i
13 required to close those issues.
i 14 Q Did you actually perform any analyses?
r.
15 A I did not perform any of the analyses 16 .that we have discussed previously as being safety 17 analyses, that is, comparing plant response to design 18~ basis criterior.
19 Q What kinds of analyses did yo'u perform-j 20 in connection with this initial licensing period in 21 your career?
i
( 22 A I don't specifically remember performing i
23 any. I am sure that I did not perform any of the 24 category that we have called safety analyses.
( Those 25 analyses were performed for us by B&W.
I.
. - . - _ ,_ ,.,-_ ,,. - - ~ ,.----- _ _ -. _ .. _ .. _ ,., - _ _ .._,. _..-- __ _ _ _-..--. _.. _ ., - --. _ -- --- - _--
1 Broughton 19
- 2. Q Did anyone else perform safety analyses 3 for GPU Service with respect to the'TMI-2 plant?
4 A With respect to those needed to license 5 the plant for -- to show that the plant met licensing 6 criterior, I am not aware of anyone else who performed 7 those analyses.
8 Q Have you ever seen the final safety 9 analysis report for TMI-27 10 A I have seen portions of that document.
11 Q You have never seen the whole thing?
12 A I couldn't say for sure if I have ever O
\_) 13 seen the whole document or not.
14 Q How was the licensing section organized 15 when you first arrived?
16 A This would be the licensing section that i
17 would have been GPU Service Company? ,
[
! 18 Q .Yes, the portion that you were connected
! 19 with.
l 20 A There was a licensing manager and within l
l l 21 the section, engineers, licensing engineers were l
22 assigned a specific project to oversee.
23 Q who was the licensing manager at that
- N 24 time?
l -
25 A Tom Crimmins.
1 Broughton 20 O
U 2 Q He reported to Mr. Thorpe?
3 A Yes, he did.
4 Q Do you remember Mr. Thorpe's title?
5 A At the time I began to work for the
{
6 service company, I do not remember his title.
7 Q Was he manager of -- environmental affairs, 8 does that help refresh your recollection?
9 A I believe that's the title that he held 10 at the time. e 11 Q How many licensing engineers reported 12 to Mr. crimmins beside yourself? I don't need to (sh/
13 know the exact number. Are we talking about 10, 20, 14 a hundred?
15 A As best I can recall, five or six.
16 Q Were there other people in that section 17 or unit besides licensing engineers? ,
~
18 A I believe all the people who reported 19 to Mr. crimmins were li c e r.s ing engineers.~ There 20 may have been one exception. There may have been an l
l 21 individual listed as a safety group coordinator or 22 a title that was different from licensing engineer, 23 but he's the only exception I can recall.
l
() 24 Q I have been looking at an organization i
25 chart for GPU Service that is at a somewhat later time, i
-. . _- - _ - =_ _- -. ~ .... - - - - _ _ _ . . . -
1 Broughton 21 O 2 I believe March of '79. So it doesn't necessarily j 3 correspond, but the chart that I am'looking at has 4 a number of different titles under the licensing
~
{ 5 manager including such things as Engineer III -
Safety 6 and Licensing; another title is Engineering Associate 7 Senior II -
S & L; another title is Engineer I - Safety 6 s Licensing, and then there is something called 9 Analyst II -
Licensing, Administrative Assistant i
10 I - Licensing.
11 Were there titles such as that when you 12 first joined the Licensing section? Was that 13 something that came.later?
14 A I am not sure if the titles you have there i
15 are the titles used by personnel in terms of identifying f 16 the experience level or the qualifications as opposed 17 to the more common everyday titles that I was applying 18 with individuals in the group to indicats what they 19 normally do. There also were some changes in the 20 organization of the Licensing group between the time 21 that I joined the company in '76 and March of '79 22 .that may explain some of the things you see on that 23 chart.
/T 24 Q What was the charter, if you will, of
, \_)
05 Mr. Crimmins' groups what areas were you supposed to I.
l l
1 Broughton 22 U 2 cover?
3 A The Licensing group, as I recall, in 4 May of '76 covered nuclear licensing for projects 5 that the service company was involved in. It covered 6 environmental licensing and I believe that was also 7 just for the projects that the service company was 8 involved in. And it provided support to one of the 9 internal safety review groups, the General office 10 Review Board and that support was in the form of a 11 technical secretary. There were also activities 12 under way to provide some analysis capability within 13 the group to be able to analyze performance of the 14 integrated power plant and of the containment of 15 the power plant during transients and accidents.
16 Q Why?
17 MR. GLASSMAN: Why what?
18 Q Why was that under development?
19 MR. GLASSMAN: Where are we going, with 20 the last item that he mentioned?
21 MR. WISE: Yes.
22 A We were developing in-house capability 23 in the analysis areas to apply to our power plants
("S 24 to enable us to answer certain questions that came d
25 up in the design process. There were probably
1 Broughton 23 b(m. 2 several other reasons why we were doing that, but 3 that's the one which comes to mind.
4 Q You mentioned that your group was
{ 5 providing support to the General Office Review Board 6 in the form of a technical secretary. I take it 7 from your resume that at some point you acted as 8 technical secretary to the GORB?
9 A Yes, I did.
10 Q During what period did you. do that?
11 A I am not sure of the exact dates, but as 12 best I recall it would have been fall or winter of m
13 '76 for a period of about one year.
14 Q what did that entail?
15 A The primary function was to attend 16 scheduled and unscheduled meetings of the Review Board 17 and to provide minutes of the discussions and decisions, 18 recommendations, made by those -- at those board 19 meetings.
20 Q what was the function of the board as you 21 understood it?
22 A I don't recall the exact wording of their 23 charter, but they performed a review function with I'~ 24 the intent of looking at potential safety problems D) 25 at the power plants.
1 Broughton 24 p
O 2 Q That's rather broad. I wonder if you 3 could be more specific. What exactly did they 4 review?
5 MR. GLASSMAN: You are asking him what
(
6 events they reviewed or what documents?
7 MR. WISE: I am not sure what to ask.
8 I am trying to get some idea of what this board 9 did. This man was secretary of the board for 10 a year and the only way I know how to get at 11 it is to ask him what it is they reviewed?
12 MR. GLASSMAN: I will allow him to
[
13 answer, but I understand it to be a general 14 question.
15 A There were certain documents that required e
16 review and I believe that the Tech Specs required 17 review o f certain documents and those documents were, 18 as best I recall, proposed changes to teEhnical 19 specifications, inspection reports from inspections 20 conducted by the NRC and it was --
I believe they 21 reviewed not only the report but the response to the
\
22 report. In addition to having specific documents 23 that they were required to review, they were also free to look into other areas which they might feel
( 24 25 their experience could provide some assistance to
1 Broughton 25
[\-/-
)
2 the plant management in either identifying potential 3 safety concerns or in reviewing these areas and 4 being fairly confident that there were no safety concerns.
[ 5 6 Q Who were the members of the GORB? I am 7 not going to pin you to names, but generally, as you 8 understood it, what was the makeup of that group?
9 A The group was composed of members who 10 were employees of GPU Service Company or the plants 11 with operating nuclear plants or companies with 12 nuclear plants, plus they wer'e consultants to the s_) 13 company who were also part of the Gene'ral Office 14 Review Board.
15 Q what consultants do you recall were on 16 the GORB during the time that you were technical 17 secretary?
18 A On the Three Mile Island General Office 19 Review Board I believe that Bill Lowe was' a member.
20 There was a member from Babcock & Wilcox, George 21 Kulynch. I an not sure that George was a member at 22 exactly the time that I was the secretary. I 23 participated in GORB activities after I was secretary
/~T 24 and he was a member at some point. I don't know if O
25 our terms overlapped. John Miller was also considered 2
1 Broughton 26 2 a consultant. He had been a former employee of, 3 I believe, Metropolitan Edison.
4 Q Mr. Miller at one time had been a project 5 manager for TMI?
{
6 A I don't recall.
7 Q Is there anyone else --
8 A I can't think of anyone else who were on 9 the TMI GORB at that time. There may have been others.
10 william Lowe was associated with the Q
11 firm of Pickard & Lowe; is that correct?
12 A That's correct.
O 13 Q Do you know what business Pickard & Lowe 14 was in?
15 A other than knowing that they provided 16 consulting services that were sometimes used by the 17 nuclear industry that dealth with general issues 18 and dealt with some environmental issues and some
~
19 physics issues, I cannot better characterize what 20 they did.
21 Q Did they perform the type of work that 22 you just described for GPU and Met Ed?
d 23 MR. GLASSMAN: Are you talking about who 24 they reported to ?
25 MR. WISE: I am trying to find out what
1 Broughton 27 A
( 1
\- '
2 they did for GPU Service Company, whatever it 3 was that they were working for at TMI during 4 this time.
5 MR. GLASSMAN: You mean separate and
(
6 apart from the GORB?
7 MR. WISE: I guess I am trying to find 8 out why Mr. Lowe was sitting on the GORB and 9 I don't want to ask the witness that question that 10 way. I am trying to find out to what extent 11 he has knowledge of what Mr. Lowe was doing 12 for the company. I am defining the company
(~ s
\- 13 to include all the various affiliates of GPU.
14 MR. GLASSMAN: To the extent he knows, 15 he can testify.
16 A Is the question what was Mr. Lowe doing 17 or what was the firm doing? ,
18 Q Let's start with what was he'doing and l
19 see if that's any different from what the' firm was i 20 doing, L
! 21 A The only thing I know Mr. Lowe was doing
( was with the GORB.
22 He was a member and was I
l 23 engaged as a consultant to sit on that review board.
24 g what was his firm doing, to the best of 25 your knowledge?
1 Broughton 28 2 A There are two areas which I recall his 3 firm was providing his assistance in. One was in the 4 area of fuels work and I believe it related specifically to relosds and reload licensing of the
[ 5 6 Oyster Creek plant. The second area his firm was 7 working on or had worked on, and the work may have 8 been done before I was involved with the company, I 9 believe it had to do with cooling tower problems at 10 Three Mile Island. I don ' t know anything about that 11 work firsthand. That's work that I believe someonn 12 had mentioned to me was done. There was other werk f\%l 13 that we did with Pickard, Lowe & Garrick, 14 I would like to ask, if I can, what the i
15 time frame is that you are interested in?
16 Q Let's take the time period before the 17 March 28, 1979 accident at TMI-2. What work had you l
l 18 done with that firm before that time?
, 19 A I believe that they had also 'one d some i
20 work for us in the area of aircraft' impact probability 21 and I don't know if that was TMI only or Oyster Creek
('
22 only or some combination of those two plants.
23 Another area in which we worked with them
( 24 before March of '79 was the risk assessment projects 25 for the oyster Creek power plant. And the principals
1 Broughton 29
(~)) 2 involved in that from Mr. Lowe's firm were John 3 Garrick and the firm at some time in our relationship 4 changed from Pickard & Lowe to Pickard, Lowe &
( ', 5 Garrick and that work on the oyster Creek was done 6 before the accident.
7 Q Are you familiar with that project?
8 A I have some familiarity with it.
. 9 Q What was its purpose?
4 10 A The Oyster Creek risk assdssment project 11 had the purpose of looking at the Oyster Creek power 12 plant and attempting to evaluate public risk due to t"%.
k_) 13 operation of that power plant.
14 Q Who commissioned the project to your 15 knowledge?
16 MR. GLASSMAN: Objection to form. There 17 is no statement as to what commission --
18 MR. WISE: I will take my chances with 19 the question.
20 A : don't know if it was Jersey Central 21 -Power & Light or GPU Service Company who actually 22 initiated the project and selected the contractor 23 and administered it from that standpoint.
() 24 Q During the period you were familiar with 25 the proj ect, who was overceeing it from within the
j 1 '2 Broughton 30 2 company? .,
3 A There were several' people who were itvolved 4 in the proj ect from the standpoint of being company
{, 5 interfaces. 'one was Tom Crimmins and at that time 6 he was the Jersey Central Manager of Engineering, I 7 believe was his title. And a second person involved 8 was. Nick Trikouros who acted as the project manager 9 and had most of the frequent interaction with the 10 consultant. e t %
11 Q When did the work begin on this project, 4D 12 to ycor knowledge?
(O)
N/
i '
, 13 A Iadon't recall exactly. I think it was 14 in 1978, probably early '78, but I could be mistaken 15 on the date.
ll 6
-7 ; , x .
16 Q Has the' work been completed?
l
/
17 A I don't know if the original, scope of work
~
18 hs 2 been completed.
7 1 .
I h3 Q Have you ever seen a report on the project?
t 1
20 A I have seen a draft report.
i 21 Q When was the last time you saw such a i
1
,h 22 draft?
23 A well, we have copies of the draft i
24 available in our offices and we have referenced
%)
i t 25 portions of that with regard to Oyster Creek work.
1 Broughton 31 2 Q I guess what I am asking is when was the 3 last draft that you have seen prepared?
4 A I believe that the draft we are using 5 was prepared in about May of '79.
{
i 6 Q Do you know whether there has been any 7 work done on the proj ect since May of 19797 8 A Yes, there has been.
1
. 9 Q Do you know whether there have been any 10 additional drafts prepared? t 11 A I don't know that.
12 Q Who would you go to ask if you wanted to 13 know the answer to that question today?
14 A I would go to Pickard, Lowe &,Garrick.
, 15 I don't know the name of the project manager now for l 16 that project with them.
17 Q Is there anybody within the GPU system 18 that you could ask?
19 A Nick Trikouros is involved in the work 20 that's going on in this area now.
I 21 Q Where is Mr. Trikouros now, what position 22 does he hold?
23 A He is now the safety analyst and plant 24 control manager.
25 Q Does that mean he works for you today?
1 Broughton 32
(- -
U 2 A Yes, he does.
3 Q Now, going back to the overall areas 4 covered by the licensing section at the time you 5 joined in May 1976, you mentioned that nuclear 6 licensing for GPU Service Company projects. Was TMI 7 a service company project at that time?
8 A TMI-1 was not. That was a Met Ed 9 project for which Met Ed had responsibility, so 10 licensing for TMI-1, for example, would have been 11 done by Metropolitan Edison. TMI-2 was a service 12 company project.
[^T
- / .-
s- 13 Q What was your understanding as to what 14 unit within the service corporation had responsibility 15 for the final safety analysis report for TMI-27 16 MR. GLASSMAN: What, if any?
17 MR. WISE: If anybody at GPU. Service 18 had responsibility, to your knowlebge, for the 19 final safety analysis report for TMI-2.
20 A I don't know for sure that ther'e was 21 anyone who had that responsibility.
22 Q Are you familiar with a preliminary 23 safety analysis report done for TMI-27
) 24 A I know that one exists. I don't think 25 I would say that I am familiar with it.
1 Broughton 33 O 2 Q Had it been completed prior to the time 3 you joined GPU Service in 1976?
4 A To my knowledge it was completed before
{ 5 I joined in '76.
6 Q Are you aware of a requirement that a 7 final safety analysis report be prepared and submitted 8 to the Nuclear Regulatory Commission in connection
- 9 with the licensing procedure for a plant such as 10 TMI-27 E 11 A Yes.
1 12 Q Did you ever come to know whether such 13 a report was in fact submitted for TMI-27 14 A Yes, such report was submitted.
15 Q Do you know about when that occurred?
16 A I don't know when the final safety 17 analysis report was first documented. .
18 Q Do you know whether it occurbed before 19 the time that the plant was granted an operating 20 license?
l t
21 A Yes.
22 Q Do you know when TMI-2 got an operating 23 license?
24 A I do not recall the date of the operating 25 license.
l I
1 Broughton 34
/~s -
2 Q Did TMI-2 have an operating license 3 before it began power operations?
4 A Yes.
5 Q Did it have a license before nuclear
{
6 fuel was loaded?
7 A Yes.
8 Do you know when nuclear fuel was loaded Q
9 at TMI-27 10 A No. ",
11 Q You know that it was during the period 12 1977 through 1978; do you not?
O 13 Let me put it this way: You know that i
14 on January 1, 1977 there was no nuclear fuel loaded 15 on TMI-2; you know that today, don't you?
16 A I wouldn't say I know that. I would have 17 to look at something that would refresh my memory
- 18 on that point.
l 19 Did you ever become aware of a transient Q
20 that occurred in September 1977 at TMI-2 that 21 involved so-called hot functional testing?
22 A From that description I am not aware of 23 any.
() 24 Q Are you f amiliar with the term hot 25 functional testing?
, 1 Broughton 35
[~h '
2 A Yes.
3 Q Do you know whether hot functional 4 testing was done at TMI-27 Yes, it was done.
{ 5- A 6 Q Do you have any idea when it was done?
7 A I have an idea that it was done in 1977.
8 Q Is it your understanding of hot functional 9 testing that nuclear fuel has been loaded in the 10 reactor vessel at the time that testin.g takes place?
11 A I don't know that it is on a commercial 12 plant.
s- 13 Q In fact, it is not; isn't that true?
, 14 A I don't know for sure.
15 MR. GLASSMAN: The witness said that he 16 didn't know and you are trying to put words in 17 his mouth. ,
18 MR. WISE: I am just asking him another
~
19 question to see whether or not it would help 20 jog his memory.
21 Q So just so the record is clear, you are 22 not able to say when nuclear fuel was loaded at 23 TMI-2 aven to the year?
I'h D 24 A I don't recall to the year. I would have 25 to make a supposition. I just don't recall.
1 Broughton 36
~
(~h N_ ) -
2 Q You know that nuclear fuel had been 3 loaded by March of 1978, do you not?
4 A Yes.
5 Q So it was sometime after that?
(
6 A Yes.
7 Q Do you know whether nuclear fuel had been 8 loaded at the time that you arrived at GPU Service
. 9 Company in 19767 10 A Fuel had not been loaded When I came to 11 work for the service company. Fuel had not been 12 loaded at TMI-2.
~T .
13 (Recess taken.)
14 MR. WISE: What was the last' question 15 and answer?
16 (Record read by the reporter.)
l 17 BY MR. WISE: ,
l 18 Q Do you know whether the fina safety 19 analysis report had been prepared and submitted at 20 the time you came to GPU Service?
21 A As best I can recall, it had been.
C.
I 22 Q Did you personally do any work on the 1
! 23 final safety analysis report after it had been
- (\
q ,1 24 submitted?
25 A I was involved in preparing some of the
1 Broughton 37 l
\
f^h
\/ '
l 2 amendments to the final safety analysis report.
3 Q Do you remember what areas you worked on?
4 A I recall that the amendments covered a t
'( 5 variety of areas and as an example one of them had 6 to do with financial aspects of the company.
7 Q How would that work, that is to say, how 8 would an amendment such as that be prepared?
. 9 MR. GLASSMAN: How was it prepared?
10 MR. WISE: Yes. E 11 Q What was the process by which an amendment 12 was prepared, to what extent was the licensing unit n 13 that you were involved with responsible for the 14 substantive material that would be submitted to the 15 NRC?
16 MR. GLASSMAN: There seems to be a 17 number of different questions involved there 18 again.
19 MR. WISE: I am trying to speed this 20 along. We will not finish in four days at this 21 rate.
22 If you want me to ask each question one 23 by one, I will. I want to get an overview of
() 24 how a system operated, when an amendment would 25 be prepared to the safety analysis report, how
.. .. =. .- .
1 '
Broughton 38
~
O. 2 would it be processed, what were the procedures, 3 but I guarantee you I will not finish in four 4 days at that rate. It's up to you.
( 5 MR. GLASSMAN: I take note of the fact 6 that the problem here is not hours. I mean, 7 all I am trying to do is speed things along as 8 well and focus on the questions. If you are 9 trying to find out what Mr. Broughton's general 10 knowledge is about how amendments l were processed, 11 written, fine, but if you are trying to find 12 out what he did personally, fine, but I am not O 13 sure what you are focusing on.
14 MR. WISE: We'll go the long way, but I-15 guarantee we won't finish in four days.
16 MR. GLASSMAN: I am trying to distinguish 17 between general knowledge and Mr. Broughton's 18 work. I wasn't sure what your question was.
19 I am not asking you to take a long time or go 20 through any long way. You can. cut through this 21 and ask a general question if you want.
4 22 Q The question is directed, Mr. Broughton, 23 at the general procedure within GPU Service at the 1
p.
V 24 time you were in the licensing unit for the preparation
- 25 of amendments to the final safety analysis report i
-r - - 3r- ,, - ,..-,w.-- -
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,- . - = - . - . _ _ .. . _ - - . _ _
d 1 Broughton 39 2 for TMI-2.
-3 A As I recall, a question would-come in 4 from the Commission which would require that the FSAR 5 he modified to reflect the answer and depending upon
{
! 6 what the question was, we would ask the appropriate 7 part of the organization, and the organization may 8 have been GPU Service. It may have been Metropolitan s
9 Edision. It may have been B&W. It may have been 10 Burns & Rowe, the architect engineer.E But whoever 11 was responsible for that particular area we would 12 ask them for a response and if that response required a
13 changing the design or something' greater than simply 14 exchange what existed. There were other parts of 15 the organization that got involved in those decisions, e
- 16 but once the decision was made as to how to respond 17 to this question, then Licensing focused.on taking i 18 that information, packaging it in a mann$r consistent i .
19 with the FSAR and providing that information 20 initially back to, I believe it was Gilbert Associates, 21 who had done the writing of the FSAR and then the 22 actual amendment would be physically produced, I 23 believe it was by Gilbert, and distributed and so 24 forth.
25 There was also a step in there which
1 Broughton 40
~~
2 involved a certification or a signature from someone
~
3 in the company that really said that this was an 4 official amendment to the FSAR. I believe that 5 those were signed by Metropolitan Edison. The
{
6 service company acted in the name of Metropolitan 7 Edison for the purpose of constructing the FSAR.
8 Q Metropolitan Edison became the licensee 9 for TMI-2; isn't that right?
10 A I believe the initial license application
.- 11 was in their name. It would have been jointly 12 with Jersey Central, but I don't believe the s e'rvi c e -
h :
(~J
\- 13 company was ever listed as an applicant. The 14 application was listed in one or more of the operating _
15 companies.
16 Q But is it your testimony that the 17 responsibility for overseeing the licensing function, i .
18 at least during the time you were in the company, 19 rested with CPU Service for TMI-27 20 A It rested with GPU Service for TMI-2 l
21 until the time the license was obtained. At the
- k. 22 time the license was obtained then that function of 23 overseeing the FSAR went to Metropolitan Edison. We
( 24 still provided them with assistance but Metropolitan 25 Edison then dealt with TMI-2 as they were dea *ing
1 Broughton 41 fh A
2 with TMI-1.
3 Q Did Metropolitan Edison have a licensing 4 section of its own?
A Yes. They became a primary interface.
( 5 6 Q Who was in charge of licens'ing at TMI-2 7 for Metropolitan Edison while you were in the 8 licensing section of GPU Service?
9 A I don't know that there was a specific 10 licensing engineer assigned to TMI-2 before we 11 transferred that responsibility to Metropolitan 12 Edison. There may have been one, but I don't know.
'- 13 Q That transfer would have occurred sometime 14 before March 1978; is that right?
15 A Yes.
16 Q We went through the scenario before of
- 17 trying to establish when the operating license had 18 been obtained and when fuel was first loaded and I 19 believe as close as we could come was sometime before l
20 March of i378.
l 21 A Yes.
22 Q You don't recall exactly when that 23 transfer took place?
() 24 A No, I don't.
25 Q I recognize that you went out of the
,+,-,.s..yy . - . . , , --- - - . .__w. .p,_ _#,-.,
,-.-7._y, - - - - - , _ . , . , - - , _ _ _ - - - - - - - , _
1 Broughton 42
-w .
[V \
2 Licensing Department at some point along the way, but 3 do you have knowledge as to who at Metropolitan 4 Edison took over the licensing function at the time 5 of the transfer?
{
6 A I am not sure. As a matter of fact, I 7 am not even sure that they would have assigned that 8 to one individual.
9 Q Do you know whether before March 28, 1979 10 there was a licensing department or unit within 11 Metropolitan Edison?
~
12 A There was a licensing unit. I don't
('~}' 13 know what they called it, whether it was a section 14 or department, but there was a licensing function 15 established within Metropolitan Edison.
16 Q Do you know who was in charge of that 17 before the accident?
18 A I am not certain. It may hahe been Bill 19 Potts.
4 20 Q Now, with respect to the procedure for 21 handling amendments to the FSAR, you said that the i
( 22 reques t or whatever it might be would come in from 23 the NRC. I take it you meant that the request would 24 first be sent to the Licensing Department?
25 A I believe that the NRC letter was addressed I
1 Broughton 43 O
u 2 to Metropolitan Edison and there were various copies j 3 that we -- we also got directly from the NRC and 4 I believe that the licensing copy either came
(' 5 directly or it came via the project.
6 Q And it was within the licensing section, 7 as you understood it, that the decision was made.
8 .Who within the system or outside the system would
,. 9 prepare the substantive response?
10 A If there was a particular ' decision to be 11 made as to who was responsible, the Licensing
, 12 Department would have gotten guidance from someone O
\- 13 else. If it was relatively clear who was responsible 14 and that person agreed that they were responsible, 15 then it would have been a communication between
=
i l
16 Licensing and that responsible group.
! 17 Q Did the Licensing Department. perform any l
l l
18 review function when the material came back from the 19 responsible individual?
20 A There was a review performed.
21 Q what was the purpose of the review as k.
22 you understood it?
I 23 A I am sure that the review performed I
( 24 varied considerably depending on what the issue was, 25 but in general the types of things that would be 1
i
1 Broughton 44
(~
kJ 2 looked for would be consistency of that response 3 with'other licensing positions which the person who 4 gave us that response might not have been involved 5
{ in and we certainly did a review for consistency of 6 format with the existing FSAR and we may even have 7 altered formats so it was consistent with the FSAR.
8 Was any review performed of the substance Q
9 of the material?
10 A I would say in general we*did not look 11 at technical material to see if it was technically 12 sound, if it was from the responsible technical n- 13 organization within the company or am ng one of the 14 support companies. We did not try to perform, say, 15 an independent technical review. The review was 16 really focused on the licensing impact of the response.
17 After you joined the licensing section Q
18 in 1977, did your job position or title change at 19 any point?
20 A In 1977 I assumed the position of the 21 licensing manager.
22 Q That was Mr. Crimmins' prior position?
23 A Yes, it was.
O 24 i) s Q Where did Mr. Crimmins go?
25 A He went to Jersey Central. I believe it
l l
1 Broughton 45
(~g '
V 2 was called Generation Engineering and his position 3 there was manager of engineering.
4 Q Do you know whether he is still with the 5 GPU system?
{
6 A He is no longer with the GPU system.
7 Q Do you know where he is?
8 A I believe he is with Pennsylvania Power &
9 Light.
10 Q Do you know at what lo c ati'on ?
11 A I believe he has an office in Allentown.
12 I don't know the title, the organizational unit.
(~}
\J 13 Q How long did you remain manager of 14 Licensing?
15 A It was about one year.
16 Q what was your next position?
17 A I was then assigned as the control and 18 safety analysis manager.
19 Q That would be in 1978?
20 A Yes, I believe it was in October of '78, 21 Q Who assumed your position as licensing 22 manager?
23 A Ed Wallace.
4
()
v 24 Q Mr. Wallace still held that position at 25 the time of the Three Mile Island accident on
1 Broughton 46 A
U.
2 March 28, 19797 3 A Yes.
4 Q What were your duties and responsibilities
( 5 in your new position, the one you assumed in 19787 6 A The control and safety analysis section 7 was involved in developing analytical models of not 8 only nuclear but fossil plants to provide an in-house 9 capability to look at integrated plant operations for 10 the purpose of aiding in design decisions and 11 improving our understanding of operation.
g 12 Q That's something that you had been working
(_ 13 on while you were in Licensing; isn't.it?
14 A While I was.in Licensing we were working i 15 on a piece of the analysis development which we l
- I 16 brought over into the control safety analysis section.
17 We expanded the areas we were looking at as part of 18 the reorganization which created control and safety 19 analysis section.
l 20 Q To whom did you report?
21 A As control and safety analysis manager I 22 reported to Bob Keaton.
23 g was control and safety analysis doing l 24 anything else besides developing the analytical 25 capabilities that you mentioned?
1 Broughton 47
(~)
N./ -
2 A We were heavily involved in fossil plant 3 preliminary design and looking e.t issues that crossed 4 the boundaries of several other design disciplines
(' 5 and we were not developing models to do that. We 6 -were performing reviews of standards for how control 7 systems should work. So there were activities in 8 addition to developing models that we were involved 9 in.
10 Q I am trying to get a bette"r handle on 11 what those activities were. Can you describe them 12 = any more specifically?
O 13 A I can give you an example.of some of the 1
14 work we did in th'e fossil area that was related to 15 models.
16 Q I would be much more interested in the 17 nuclear area, as you know this litigation is about l
18 a nuclear power plant.
19 MR. GLASSMAN: The witness was focused i
l 20 on the fossil plant work and as I understood 21 your ques tion, that's what he should have k.
22 been --
23 MR. WISC: I had understood that you did
) 24' some work or were doing work on development of 25 analytic capability.
i
1 Broughton 48 2 Q That's a computer modeling project?
3 A Yes.
4 Q Now, aside from that, were you doing
( 5 anything else that had to do with nuclear power 6 plants?
7 A We took the project management aspect of 8 the Oyster Creek risk assessment into the control 9 and safety analysis group. We were involved in 10 review of the Forked River response to.both design
- 11 basis accidents and operational c o n c e r n's . In terms 12 of the nuclear area as compared to the -- our nuclear
's .
13 area work was not changed significantly from when 14 we were in Licensing. It was really the fossil 15 plant area that had really expanded and was receiving 16 a lot of our attention at that time.
17 Q So it is your testimony that,other than I ,
18 what you just mentioned, you cannot recall any other 19 work that you were doing related to nucle'ar power 20 plants during the period 1978 through March 28, 19797 21 A I recall no other general areas that we 22 were involved in. I am sure there were specific 23 questions that came up that were on the nuclear
[ 24 issues --
that had to do with nuclear plants, but in 4
> N -}
25 terms of general project areas, I don't recall any 1
, , , - - - , . , , _ . - - . - . , ,_.,n..- , , , - - - ,
,- .-..-n.. ,--,,
1 Broughton 49
(~ ~
V) 2 other work.
3 Q I would like to talk for a minute now 4 about the development of the analytic capability.
(' 5 How were you going about doing that?
6 A We were bringing computer codes into 7 the GPU system. That is, we were getting copies 8 of those codes and installing them on our computer
, 9 so that we would have access to them. The codes 10 were once related to modeling of a total power 11 operation, the RETRAN code for example is one in 12 which we were bringing into the system at the time.
('
13 we had two other codes available to us 14 that had already been installed on our system. one 15 was a containment performance code concept and a 16 second code was used for the oyster Creek reload 17 , licensing called PTS. So our activities.beginning -
18 in october of '78 were to continue develbping the 19 RETRAN model, once the code is brought in it's i
20 necessary to develop a model of the power plant and 21 that was the primary activity that we had under way.
22 Q Where did GPU obtain these codes, in 23 particular, RETRAN?
fv 24 A RETRAN was available through the Electric 25 Power Research Institute. It had been developed by
1 Broughton 50 b 2 funds provided by member utilities.
3 Q Had RETRAN been approved by the NRC for 4 use in performing safety analysis for licensing 5 purposes?
((
6 A No.
7 Q Did GPU ever consider purchasing a code 8 which had such approval, to your knowledge?
9 A I don't know that we never considered 10 one, but our primary purpose in brinsi'ng codes in 11 was not to do licensing analyses, so we were looking 12 towards a code like RETRAN which was developed to
(~' .
13 primarily for use by utilities and for our intended 14 use is that we didn't require a code that could do 15 licensing analyses, 16 Q Who made the decision to purchase 17 RETRAN as opposed to something else? .
18 A That decision had been made prior to the 19 control and safety analysis section being formed. I 20 don't recall at what level in the organization we 21 had to get approval to do something like that.
22 Q Putting aside how far up you had to go 23 to get approval, who was involved in the actual
() 24 evaluation of what to buy; were you involved in that?
25 A I had involvement in it; Nick Trikouros
. .- . .= .. ---
1 Broughton 51 2 had involvement in it, and Tom crimmins had an 3 involvement in it and there may have been others.
4 Q What considerations did you look at in
(' 5 making your choices?
6 A Well, I think the choice was basically 7 whether to bring the code in or not to bring it in.
8 It was not a choice between RETRAN and another code 9 and the considerations involved in deciding to bring l 10 the code in concerned the available mdppower that 11 we would have to actually learn how to use the code, 12' develop the models and be able to justify the O 13 expenditures to get the model ready, when you are 14 using the same people involved in licensing issues.
15 Q How was all that resolved as best you 16 recall?
17 A Well, the resolution was to bring the 4
18 code in and to rely on assistance from a consulting 19 firm to help set up the model and to realize that i
20 if we had work that we would like to do with the 21 code, but we didn't have the in-house manpower to i- 22 support it, that we might be forced to use a ID consultant to help us in that area.
2 24 Q Before March 28, 1979, was any consultant 25 in fact employed by GPU in connection with the RETRAN
1 Broughton 52 v) 2 code?
3 A We had used a consultant to help develop 4 the model and to do -- to help us with some analysis.
5 Who was that?
{ Q 6 A That was Energy Incorporated.
7 Q With whom at Energy Incorporated did you 8 work?
. 9 A With respect to model development and 10 analysis we worked with people who were primarily 11 out of the Richmond, Virginia office.
12 Q Do you remember any of their names?
O
\- 13 A Let's see, Jim Harrison. I believe Adi 14 Irani, and the only other name that comes to mind is 15 Dan Denver.
16 Q Was the RETRAN code ever used to your 17 knowledge before March-28, 1979 to perform analyses 18 of events at TMI?
19 A We used the RETRAN code to look at --
two 20 events that I can recall prior to March of '79.
21 Q What were those two events?
22 A The first event was a trip of the turbine 23 from full power in which the reactor did not trip.
24 The power level was reduced to approximately 15 25 percent.
1 Broughton 53 O) e V.
2 The second event was an event -- I should 3 say that the first event was a TMI-1 event and we 4 had test data from a test conducted at the plant
( 5 in which'this transient took place and the purpose 6 of doing the analysis was to see if the computer 7 code predicted what the plant data had shown.
8 The second event occurred at TMI-2 in 9 April of '78 and it was an event in which steam 10 safety valves remained open below thefr reset 11 pressure and the RETRAN analysis of that event was 12 used to obtain a better understanding of what 13 happened during that event.
14 Q Are you familiar with a transient that 15 occurred at TMI-2 on November 7, 1978?
~
16 A I am familiar with the date and that -
17 there was a transient. I can't characterize the l 18 transient.
l 19 Q Mr. Broughton, there was an event on l
20 November 7, 1978 which involved a partial loss of 21 feedwater flow at TMI-2 from 90 percent power followed by a reactor scram.
22 Are you familiar with l
23 that event?
24 A Yes.
25 Q was there a RETRAN analysis done of that l
t
1 Broughton 54 O)..
x.
2 event?
3 A There was not an analysis done in the 4 same. sense that there was an analysis done for the first two events I described. There may have been
( 5 I
6 some work done with RETRAN to look at parts of that 7 transient, but I don't recall any details of that 8 and I don't recall that we ever published a report 9 o f -- bas ed on a RETRAN analysis for that event.
10 Q We'll come back to that a Ilittle later.
f 11 Do you recall any other events where 12 the RETRAN code was used before March 28, 1979 than O 13 those we have just discussed? ,
14 A I don't recall any other uses that we 15 made of RETRAN in control,and safety analysis to 16 analyze power plant events.
17 Q what was the purpose, as you. understood 18 it, of performing a RETRAN analysis on a transient?
19 A well, there could be several purposes.
20 For example, the analysis performed of the turbine 21 trip at TMI-1 was performed primarily to show that 22 the computer code would give results of --
that its i
23 predictions would agree closely with what was actually
('N
(,) 24 observed in the plant. And that was -- in fact the 25 reason why we performed that analysis. It was part
1 Broughton 55 O /
\
2 of a program to verify that the code would be useful 3 for this type of work and that the model which was 4 set up was a model which would give you results that 5 agreed with plant data.
{
6 Q Given that it is nice to verify that the 7 system works, I assume that's not the end of it.
8 What was your understanding before the 9 accident of what purpose the code was going to be 10 put to other than verifying that it worked?
11 A our purpose in having the code and having 12 the capability was so that we could use it to A)
(
13 evaluate different designs. If we had unanswered 14 events that we wanted to make sure we understood, 15 we co.uld use it for that as we did in the April '78 t 16 transient.
17 Q Let me go back for a moment to the time I
f 18 when you were in the Licensing section.
19 During that period did you become familiar I
20 with the Nuclear Regulatory Commission requirements 21 for licensing?
22 A During the period that I was in the 23 Licensing section I became familiar with some of the 24 requirements of the Nuclear Regulatory Commission.
25 Q Are you familiar with the term design
1 Broughton 56
/\
C/.
2 basis as it is used in connection with the licensing 3 requirements of the NRC?
4 A Yes.
( 5 Q What is your understanding of that term?
6- MR. GLASSMAN: Current understanding?
7 MR. WISE: I can ask it either way.
8 g Let's go back to what your understanding
. 9 was at the time you were in the Licensing section.
10 A As best I can recall, my understanding 11 of what the design basis was, was some criterion which
,, 12 had to be met by the facility.
(d 13 Q Is that the extent of your knowledge of 14 what was meant by the design basis of a nuclear power 15 plant for licensing purposes? I am speaking about 16 the period when you were manager of Licensing for 17 GPU Service. -
18 A As a general definition I would say 19 that's my understanding. There were many specific 20 ' things that constituted that basis, but I think in 21 general that was my perception of what was meant by l
22 design basis.
23 g Where were the criterion contained as 24 you understood it while you were manager of Licensing?
25 A The criterior that had to be met were i
{
1 Broughton 57 2 contained in the code of federal regulations. I 3 don't recall the exact parts and sections.
4 Q Do you recall something that's been
( 5 referred to directly as Appendix K7 6 A Yes.
7 Q What was your understanding at the time 8 of Appendix K, generally what it covered?
- 9 A My understanding was that Appendix K 10 dealt with loss of coolant accidents dpd it addressed 11 such things as inspections thag had to be made in
_ 12 andlyzing the accidents, analysis methods. It
%. - 13 did not, however, address the criterior for the -- for n .
14 acceptable performance. It did not list the criterior 15 for acceptable performance.
16 Q What did?
17 s A I believe it was Section 50.46 of the 18 regulations which listed specific numeri al criterior 19 that would be predicted by the analysis and that then 20 had to be met in order to show aatisfactory performance.
21 Q Was it your understanding that there was 22 any relationship between 10CFR50.46 and Appendix K?
23 A My understanding of the relationship b)
(_ 24 was that Appendix K was a guideline for performing 25 analysis and 50.46 was an acceptance criterior.
s
( e 3 r 1
- 3. s.
t 1; 1 Broughton 58 J s ,
t ' 2 Q Are you saying that they had a relationship L s 3- or that they had no relationship?
. 4 '
. A They were related in that to answer the
,\\
( 5 qdestion of compliance with regard to LOCA's m
s4 6 you would have to reference both Appendix K and
- i 7 50.46, 8 Q Let me put it this way
- In determining 9 whether the acceptance criterior of 50.46 had been 10 met, was one to any referen.ce to Appendix K? .
11 MR. GLASSMAN: Mr. Broughton's
,, , 122 . , understanding?
d '
s 13 -
MR. WISE: Yes. -
14 A 'If-the purpose of showing -- if the
[ e ,' 13 purpose'o'f doing the analysis was to show that for r
i
.\ 16 licensing reasons you met the criterior, then you o,
t 17 'would use the methods of Appendix K. If'the question 18 were to evaluate whether the design met the criterior 19 i y
og 50.46 without regard to the licensing assumptions, s y s
\, 41 1g 20 '
then-it would not be necessary to look at Appendix K.
i 21
'f( Well, 50.46 is part of the licensing l
. (A 22 p rogr air.; isn't it?
3'. ,
23 j (
, Yes.
i-f, .
~
24 7 Q I am afraid'I don't understand the last t
e 25 pJ d of your answer. When would 50.46 be " sed other
't ,
I 3 ,iy i l' 4 ,
f l ;'s , ,
1 Broughton 59 t
2 than as part of the licensing program as I understood 3 it?
4 A If an analysis were done which did not
( 5 consider all of the licensing required conservatisms 6 and it was desired to determine if the response of 7 the plaat would cause certain limits to be reached 8 as might be specified by 50.46, then the analysis 9 requirements of Appendix K would not have to be 10 applied to that analysis.
- 11 Q Did GPU Service ever perform such an
_ 12 analysis before the accident on March 28, 1979?
(_# 13 A I am not sure what you mean by such an
-14 analysis.
15 Q The one that you described.
16 A I was a little confused by it, too.
17 GPU never performed any loss of coolant 18 analyses within GPU. Any loss of coolant analyses 19 which were performed for TMI-2 were performed for us 20 by B&W. To my knowledge the only analyses which
, 21 they performed were ones which would evaluate the 22 plant with respect to licensing criterior and would 23 use Appendix K.
A
() 24 Q Did anybody at GPU Service, to your 25 knowledge, ever ask B&W or anyone else to perform n
1 Broughton 60 2 safety analyses outside the licensing criterior? And i 3 in particular, for loss of coolant accidents before 4 March 28, 19797
{ 5 A I have no knowledge of such request.
6 Q Were you familiar with the assumptions 7 contained in Appendix K wnile you were licensing 8 manager?
9 A I recall that I read through them but I 10 was not using those on a frequent basis, so I i
11 hesitate to use the word familiar in describing my 12 knowledge of it.
O 13 Q Did you become familiar with the term 14 single mode failure?
i 15 MR. GLASSMAN: when?
16 MR. WISE: while he was manager of 17 Licensing. -
18 A I.became familiar with the term single 19 failure. I don't recall talking about single mode 20 failure.
21 Q was it one of the assumptions as you 22 understood it with Appendix K with respect to 23 analyzing loss of coolant accidents that only a
) 24 single failure had to be assumed?
25 MR. GLASSMAN: Can I have that read back?
1 Broughton 61 2 (Question read by the reporter.)
, 3 A My recollection of Appendix K was that it
~
4 required that you look at the failure in the ECCS 5 system which would give you the and I don't recall
({
6 the exact wording -- but it would give you the least 7 favorable results or put you closest to the limits 8 but there were other requirements, for example, that 9 had to do with loss of off site power which were 10 imposed simultaneously on the accidends. So I don't 11 recall the wording that you only -- that you consider 12 only a single. failure.
(')
13 Q Well, was it your understanding that 14 for purposes of 10CFR50.46 and Appendix K in 15 analyzing loss of coolant accidents, the licensee 16 had to submit analyses showing that every possible 17 accident had been analyzed? .
18 A Again, I don't remember the words every 19 possible accident. I think the words were more 20 along the lines of the analysis had to address the 21 full spectrum of breaks and locations, 22 Q Putting aside the spectrum of breaks and 23 locations, was it your understanding that the 0)
(_ 24 analysis had to, submitted by the licensee, had to 25 include every possible permutation of failures and
)
1 Broughton 62 O
Q -
2 operator action that could possibly occur?
3 MR. GLASSMAN: I think that's been asked 4 and answered, but I will let him try again.
( 5 A Again, I don't think there was a requirement 6 to submit a large number of analyses, but simply to 7 be able to address the fact that studies had been 8 done which showed that the analyses that you had 9 done represented sequences which would put you as 10 close to the limits, the closest to th's limits.
11 .Q And before the accident on March 28, 1979, 12 did you ever look at the portion of the final safety f -
13 analysis report for TMI-2 that covered loss of 14 coolant accidents?
15 A I don't recall if I did or not.
16 Q You have testified, I believe, in 17 connection with the restart hearings before the ASLB 18 with respect to TMI-1; is that right?
l 19 A That's correct.
l 20 Q Do you know whether there is a final i
21 safety analysis report at the NRC for TMI-1?
22 A There is an FSAR for TMI-1 and it has i
23 been filed with the NRC.
O)s_ 24 Q Does it provide some safety analyses i 25 with respect to a loss of coolant accident at TMI-17 i
l 1
Broughton 63 2 A Yes.
3 Q In fact, you testified before the ASLB 4 with respect to loss of coolant accident questions, 5 did you not?
({
6 A I did.
7 Q Did you review the FSAR before giving 8 that testimony?
9 A Yes.
10 Q Are you familiar generally".with what is 11 in it with respect to loss of coolant accidents?
12 A It's been long enough since I have looked 13 at it that I wouldn't say I am familiar with it.
14 Q It's gone out of your head since then?
15 A Other things have taken its place.
16 Q Do you know whether in the TMI-1 FSAR 17 for loss of coolant accidents every possible accident 18 has been analyzed? I am using the word possible, 19 advisable.
20 A I think the thing that's giving me trouble 21 answering your question is whether it's been analyzed.
22 Usually when we speak of a loss of coolant accident 23 analysis we refer to analysis of one specific break O)
(_ 24 location under one specific set of conditions, so to 25 say that we have performed an analysis for every
1 Broughton 64
~~. .
A /
2 possible break and mean that to be that we have a 3 computer run for every possible break, I think the 4 answer to that is no, but I don't think that's a requirement for an Appendix K and 10CFRSO.46.
{ 5 6 Q Why not? Why don't you think it's a 7 requirement?
8 A The requirement is that you address a 9 complete spectrum of breaks but I don't know if it 10 says in that document or if it's simply my belief 11 from either sources that that does not mean that you 12 attempt to do an infinite number of analyses to Os 13 address the complete spectrum. Instead you do 14 enough analyses so that the general sensitivity of 15 the plant with respect to break location and size is 16 determined and you then focus in on the particular 17 location and the particular size break which gives l -
l 18 you the results that are closest to the limits and l
l 19 you have to demonstrate that in fact you have picked 20 the proper break.
21 Q And in analyzing those various break
! (- 22 sizes, is it your understanding that the performer l
I 23 of the analysis is permitted to make certain
()
24 assumptions?
l 25 MR. GLASSMAN: Permitted by what?
i.
1 Broughton 65 0
2 MR. WISE: By the requirements of 3 10CFR50.46 and Appendix K.
4 A Well, the assumptions for doing the
( 5 analysis are spelled out in Appendix K. I am not 6 familiar with doing that analysis and I am not in a 7 position to say that there are additional assumptions 8 that an analyst can make that Appendix K doesn't 9 address.
10 Q But in connection with you*r TMI-1 restart 11 testimony ycu did not go through and become familiar 12 with what those assumptions were?
13 A Well, I reviewed the assumptions that 14 are required by Appendix K and part of our review 15 of the work we submitted was to insure that the 9
16 analysis did not make any assumptions which were not 17 valid for TMI-1 -
18 Q Did you find that the portion of the FSAR l 19 covering loss of coolant accidents for TMI-1 was 20 consistent with the assumptions in Appendix K?
21 A Well, I don't recall specifically looking L
22 at FSAR and trying to compare the analyses in 23 Appendix K. I think the statement that was made in
[~
(_j) 24 the restart hearings was that the analyses that were 25 performed for TMI --
that were performed generically
1 Broughton 66 b
v 2 by B&W were applicable to TMI-1 and met the requirements 3 of Appendix K. I don't recall specifically referencing 4 the FSAR to say those words for us.
Since the March 28, 1979 accident have
( 5 Q 6 any amendments been made to the TMI-1 FSAR cooling 7 accident that you are aware of?
8 A Not that I am aware of.
9 Q While you were manager of Licensing, did 10 you become familiar with something kndwn as 10CFR217 4
11 A Yes.
12 Q What was your understanding of what that
/s)
\ .-
/
13 particular provision covered? ,
14 MR. GLASSMAN: We are talking about during 15 the time he was manager of Licensing?
16 MR. WISE: Yes.
17 A Well, the best I can recall,.it was a 18 requirement to report, to evaluate and then in the l -
l I
19 case of an evaluation which indicated possible 20 safety impact, to report that fact to the NRC and 21 my recollection is that it applied to people who had
(
?
22 a license from the NRC and to manuf acturers , power 23 plant -- nuclear power plant vendors and it may
( 24 have also applied to people providing consulting 25 services.
i
, ,-- .- -. _. ..___ _ . ~ . . . _ . - - _ _ _ _ _ _ .___
1
, Broughton 67 2 Q While you were a manager of Licensing, 3 was there any written procedure, to your knowledge, 4 within GPU Service Corporation concerning compliance
() 5 with 10CFR21?
6 A There was a procedure. I think it was 7 a service corporation procedure, but I could not be 8 certain.
9 Q Where was that procedure maintained?
10 A Well, since I am not sure if it was a 11 service corporation procedure, I don't know how I 12 can answer where it was maintained.
O 13 Q Who wrote the procedure? .
14 A There were -- the requirements of 10CFR21 15 I believe resulted in modifications to several e
16 existing procedures and may have generated a new 17 procedure. -
18 Q The question was who wrote the procedure?
19 A Well, the existing procedures would have 20 been written by whoever they -- had originated them.
21 In Licensing we had input to change in the existing 22 procedures due to 10CFR21 and would have had input 23 on a new procedure if a new one was in fact required.
(m)
, 24 g When did 10CFR21 go into effect?
25 MR. GLASSMAN: From this witness'
1 Broughton 68 s
2 understanding?
3 MR. WISE: Yes.
4 A To the best of my memory, it was probably
- ( 5 early 1978 and possibly January 1, 1978.
6 Q That was while you were still manager of 7 Licensing?
8 A Yes.
9 Q what steps did you take to change procedures 10 upon the effectiveness of 10CFR21 whil'e you were 11 manager of Licensing, if any?
_ 12 A I don't recall any personal involvement
,) '
13 in changing procedures, but I do recall that from 14 the licensing section we were providing guidance to 15 other people who had procedures that might be effected i .
16 by 10CFR21, as to what that effect was, and that 17 would also have extended to making sure that the 18 change that they made to their procedure was consistent 19 with 10CFR21.
l l 20 Q Can you attach any names to this? This l
l 21 is rather general. Who was writing the procedures, l 22 what procedures were they writing and who was l
l l
23 providing the input?
(~%
() 24 MR. GLASSMAN: Are we talking about new l
25 procedures or advising old procedures?
1 Broughton 69 2 MR. WISE: I think the question is clear.
3 MR. GLASSMAN: You would like a general 4 question, what Mr. Broughton can contribute.
((j 5 A I think the projects organization had 6 one or more procedures that were effected. And the 7 reason I think that is because there already have 8 been procedures that required that they report certain 9 deficiencies. I don't know who in the projects was 10 responsible for those and who would ha'Ye worked with 11 them.
12 Q You weren't personally involved with 13 interfacing with somebody in the project?
14 A Not at it. I certainly talked to the 15 manager of projects to make sure that he knew that e
16 there-was a new requirement and that we would work 17 with his people to implement that new requirement.
18 Q Who in your shop was actually doing the 19 work of checking over these procedures and assisting i
20 people in changing them?
21 A I don't recall specifically. It would 22 most likely have been Lou Lanese since he was 23 involved in TMI-2 licensing. However, at the time 24 the Forked River proj ect was favorably active, and 25' I don't recall if they had different procedures than
1 Broughton 70
[V 'l 2 TMI-2 and if we interacted from Licensing differently 3 with Forked River than we did with TMI, There is a 4 possibility more people were involved if they were
( 5 dealing with different projects.
6 Q What do you recall was the substance 7 of what your section was telling these other procedures 8 writers about 10CFR217 9 A I am not familiar with the details of 10 what might have had to be changed in the procedure.
11 What I do recall is that because of the fact that
, 12 we were involved in construction and supporting N.] ~
13 construction work I don't recall that.10CFR21 had any 14 great impact on our reporting requirements. We 15 were already making reports of the type required by l
16 10CFR21 through other provisionJ in the regulation.
17 Q Prior to 10CFR21 coming into- ef f ect, it 18 is my understanding there was a procedure for reporting 19 significant deficiencies. Are you familiar with 20 that during the construction phase of the nuclear 21 power plant?
22 A There was a p ro c e du re for making reports.
I 23 I don't know the significant deficiencies --
it i
f~)
(,/ 24 may have been the title of it.
l I am not sure.
25 Q What is your best understanding of what i
1- Broughton 71
(~'/
N.
2 that prior procedure was ?
3 MR. GLASSMAN: His current understanding 4 of what that procedure was?
(I 5 MR. WISE: No, when he was -- Mr. Glassman, 1
6 I don't know the purpose of that comment. I 7 mean, I am trying to find out what this 8 witness' understanding as manager of the 9 Licensing section was and --
10 MR. GLASSMAN: All I was doing was 11 objecting because it was unclear from the
- 12 question whether you were now focused on his
%-)
13 understanding in that time frame or somehow 14 had moved to the current time frame. The I
! 15 question was not clear. -
(
16 A At the time I am sure that significant 17 deficiency would have meant something to me. I don't 18 remember now whether that's what we called the l -
19 procedure or whether that was what it was designed 20 to report. What I do recall is there were requirements 21 that existed before 10CFR21 that we report certain 22 deficiencies that were uncovered during the construction 23 process and we had procedures in place to do that.
24 That's the type of procedure we would have looked 25 at with respect to 10CFR21 to see if it required
1 Broughton 72
\ms -
2 change.
3 (Record read by the reporter.)
4 Q Do you have any recollection today as l 5 to whether that prior procedure related primarily 6 to equipment deficiencies as opposed to things such 7 as procedures and other software items, if you will?
8 A I know we had requirements to report, 9 not only construction hardware type deficiencies, 10 but al'so to report software deficiencies. I don't 11 know if it was part of the same reporting procedure f- 12 or if it even stemmed from the same reporting 13 requirement, but we had proceduros to.do both.
14 Q What was your understanding while you 15 were manager of Licensing as to what kinds of matters 16 required reporting under 10CFR21?
, 17 MR. GLASSMAN: I think there- has been i
l 18 an answer to that. In a general sense. Is i
I 19 the question trying to go on to specifics?
20 MR. WISE: Yes.
21 A To the best of my recollection, the 22 types of things that would be reported would have 23 been things that would have been --
could have had I 24 potential safety significance and again I think the 25 impact with respect to Met Ed and GPU at the time
1 Broughton 73 O
2 was minimal in terms of reporting requirements and 3 I don't believe that it actually encompassed anything 4 that was not covered by our existing reporting l 5 requirements.
6 Q But that, unfortunately, Mr. Broughton, 7 doesn't help me much since I can't find out what the 8 existing reporting requirements were. I am trying 9 to get your best understanding and recollection today 10 of what you understood during the time'.that you were l
11 licensing manager in 1977, '78, was required by 12 10CFR21.
13 MR. GLASSMAN: I thought that's been 14 asked and answered twice now. We can try once 15 more. I hope we do speed it along. .
16 MR. WISE: I don't think I have got an 17 answer to that except some reference to prior 18 procedures which he can't remember.
19 MR. GLASSMAN: Well, I think at least
~
I 20 twice there has been a reference to potential 21 safety significance or possible safety impact.
22 MR. WISE: Let me try and approach it 23 ,another way.
(
O) 24 Q Was it your understanding as licensing 25 manager that any possible conceivable event which
1 Broughton 74
, u0 V
2 could occur and would pose a safety concern had to 3 be reported to the NRC7 4 A I don't think that was my understanding.
( 5 I would say that if it was something which was within 6 the design basis for the plant and information became 7 awailable that said that in evaluating how the plant ~
8 met that design basis and you found out that it no 9 longer met it, then I think that'becomes a reportable 10 item. ',
11 Q And you are using the term design basis 12 as you defined it earlier, it is a term of art?
13 A I think I am using it more specifically 14 than I defined it earlier in that I am now talking 15 about the design basis of a particular plant. For 16 example, the design basis for TMI-1 included 17 provision against aircraft impact. That-design 18 basis does not apply to all nuclear power plants.
19 Q It was your understanding then, that an 20 event which was outside the design basis of the plant 21 was not reportable under 10CFR217 22 MR. GLASSMAN: Are you asking for his 23 recollection of his understanding back then?
k 24 MR. WISE: Yes.
25 A The only problem I have with that
1 Broughton 75 O 2 characterization is that if you discover an event 3 which was not considered in evaluating your plant 4 against the design basis and you then evaluate that
( 5 event and find out that it does violate some 6 requirements appropriate to the design basis, then 1
7 it is reportable.
8 Q Isn't it possible, Mr. Broughton, to 9 conjure up any number of events outside the design 10 basis that would violate the safety adalyses for a 11 plant?
12 MR. GLASSMAN: We are now engaging in 13 hypotheticals. Isn't it possible to conjure 14 something up. I think this is really not 15 appropriate testimony.
16 MR. WISE: If you are objecting to the 17 form, I will rephrase it. .
18 MR. GLASSMAN: I am also not clear whether 19 this question is directed to whether it is 20 now possible, whether it might have some time 21 ago been possible. I don't know where this 22 one is going. It's very confusing.
23 Q It is a fact, is it not, Mr. Broughton, 24 and it was a fact in 1978 when you were licensing 25 manager, that it is and was possible to conjure up
_. . . . = _ = - - - _ - _ . .
1 Broughton 76 j~% '
, \_].
2 an event outside the design basis of the plant which 3 would violate the safety analysis for that plant?
4 MR. GLASSMAN: I have the same objection,
( 5 but he can answer.
6 A Yes, but that's not the event which I L
7 was describing.
8 Q I am trying to understand what it was 9 you were describing.
10 A The events I was describing was one in l 11 which everyone would agree, that is, the licensee
_ 12 and the NRC, would agree inside the design basis d 13 but for some reason or other that event was overlooked 14 or that event -- yes, that is the case, the one
' 15 where there is an event which was overlooked and e
- 16 therefore may not have been addressed by the initial
{ 17 FSAR. May not have been addressed by any of the l -
18 reviews the NRC performed and for some reason an j 19 event like that should be discovered which is in the 20 design basis. It is then required that that be i.
21 r epo rt eu . That is my understanding of a reporting 22 requirement that existed at the time.
4 23 Q For instance, while you were manager of 24 Licensing, did you understand that one of the 25 reportable events would be that the operators would
+r -,,---y-- - ,,,,,,s.. -
,- .-- , ,.,,-..-r
1 Broughton 77
, (x_)s' .
2 go crazy and purposely blow up the plant; was that 3 part of the design basis?
4 A Not to my recollection.
5 Q Why not?
(( )
6 MR. GLASSMAN: If such was ever considered?
7 MR. WISE: Yes.
8 Q I am trying to get some feeling for these
. 9 other events outside the design basis that apparently 10 you feel or felt then might be include'd in some way.
11 A No, you are still trying to assume that
,_ 12 these events were outside the design basis-and I have 13 tried to clarify that they were not ones outside 14 of the design basis.
15 Let me give you an example.
16 As part of the design basis I look at 17 the effects of loss of power to different parts of i
l 18 the electric system. If in my initial r view of i
19 these I believe that I have identified all the loss 1
20 of power which could have sa'fety consequences and
, 21 I analyze those and I put them in my SFAR I have 1
C.
22 put my requirement as part of the safety analysis, i
l 23 If a year later I have discovered I have another l
24 possible loss of power which I had not considered 25 and I go off and consider it and I find out that my
1 Broughton 78 b(N 2 results are worse then I expected and in effect 3 violate some design basis requirement, that is a 4 reportable item. It is clearly within the design 5 basis. That is a reportable item.
{
6 Q Where would one go to find the design 7 basis for TMI-27 Is it contained in the FSAR?
8 A I think the FSAR addresses the design 9 basis. It probably addresses more than the design 10 basis. The safety evaluation report kritten by 11 the NRC would address the design basis for TMI-2 and i
_ 12 it's possible that the records gene. rated during the
(_'> 13 licensing process for TMI-2 would also add to that.
14 MR. GLASSMAN: I would like to go off the 15 record for a minute. Can we have a brief 16 conference?
17 (Witness confers with counsel.)
18 Q I have just a couple more questions in 19 this area, then we'll break for lunch.
20 Let me see if I can nail down a little 21 bit more the design basis of the plant.
k.
22 You mentioned several places where you l
l i 23 might look. Where did you as manager of Licensing l
O)'
(_ 24 in the 1977, 1978 period believe you could find the 25 design basis of TMI-27
[ -
1 Broughton 79 2 A Well, I don't recall ever addressing that 3 comprehensive question at that time, but the question 4 did come up, for example, what would be the design 5 basis for a particular event and so I did address
((
6 it in that context.
7 Q What was your source for when something
. 8 did come up in a particular context, where would you 9 go to find out what the design basis of the plant was?
10 A The first place that I wod1d have gone 11 would have been the FSAR and I would back that up with 12 the regulations to see if -- because the regulations
(#)
'~ 13 really are the basis and the FSAR is an attempt to 14 explain how the plant meets that basis.
15 Q Where in the regulations would you have 16 found the requirements for the design basis?
17 A I don't remember the specific citings, 18 but there was a section that addressed general design 19 criterior. Really a section that addresses nuclear 20 power. .
21 MR. WISE: Why don't we break for lunch 22 at this point.
23 (Luncheon recess taken at 12:30 P.M.)
24 25
.- _=. - _ - - . - - - - - - _ . . . .- ..
1 Broughton 80 7~
k_
. 2 AF T ERNOON S ES S ION 3 (2:25 o' clock P.M.)
4 T. GARY B ROUGHTON , having
( 5 been previously duly sworn by the Notary 6 Public, resumed, and continued to testify as 7 follows:
8 EXAMINATION (continued) 9 BY MR. WISE:
10 Q Mr. Broughton, before we br'hke for lunch 11 we were discussing licensing and in specific 10CFR, 12 part 21.
13 After the March 28, 1979 accident you 14 were involved in various reviews and analyses of that i 15 event; were you not?
16 A Yes, I was.
17 Q Those resulted in the preparation of a 18 number of reports, I believe.
19 A Yes.
20 Q In particular, you prepared a report 21 analyzing operator response during the transient?
22 A Yes, I was the co-author of that report.
23 Q Did that report get sent to the NRC to y 24 your knowledge?
25 A Not to my knowledge,
1 Broughton 81 0 2 Q I believe there was also a RETRAN 3 analysis done of the event on March 28, 1979.
4 Are you aware of that?
( 5 A There is a RETRAN analysis done of portions 6 of the event and documented in a preliminary TDR.
7 Q You were the auth,or of that preliminary 8 TDR7 9 A I was a co-author. I don't recall how 10 many co-authors there were. I was -l ,I provided 11 input to that.
,s 12 Q Did that preliminary report get sent to
\_
13 the NRC, to your knowledge? ,
14 A I am not aware of that having been sent 15 'to the NRC, no, 16 Q There also was a task force formed after 17 the accident to review certain aspects of it. Are you 18 aware of that, chairmaned by Mr. Keaton?
19 A Yes.
20 g You helped provide some input into the 21 task force work?
L 22 A I was involved in some of their work and 23 I did provide some of their input.
( 24 Q And that ended up being a written report?
25 A Yes, it did.
1 Broughton 82 s -
U 2 Q Do you know whether that got sent to the 3 NRC7 4 A No, I do not know.
5 Q After the March 28, 1979 accident did
({
6 you ever initiate the procedure under ~ 10CFR, part 21 7 with respect to any aspect of the March 28, 1979 1
l 8 transient?
9 A I did not.
10 Q Do you know whether anybody else within 11 GPU did?
1 12 A No, I don't.
13 Q Did you ever consider initiating a 10CFR, 14 part 21 writeup on the March 28, 1979 transient or 15 any aspect of it?
- 16 A No, I did not.
17 Q Was there any reason why you,did not?
18 MR. GLASSMAN: I assume he thought about 19 it.
20 A well, first of all, I don't remember 21 thinking about it, but secondly, it was my understanding C 22 that we were providing the -- the company was 23 providing information to the NRC with respect to I
) 24 the accident and the real interface on that was 25 through other people in the company rather than
---% *-g -ei --w .-7,#my e .-- - - - - , g- --y e- --
1 Broughton 83 2 myself and if information had been appropriate to 3 provide it, it normally would have been done through 4 some other channel. For example, we had -- we
( 5 distributed our draft material with respect to the 6 accident to several different groups including 7 licensing and document group and it was my understanding 8
that it was the function of one or more of those 9 other groups to be providing that kind of interface 10 with the NRC and with other outside oEganizations.
11 For example, the Kemeny Commission, other investigative 12 bodies.
O G 13 Q
Did it ever occur to you that any of 14 the conclusions or matters uncovered as a result of 15 the various post-accident analyses and investigations 16 that you worked on should be the subj ect of a 17 10CFR, part 21 filing? -
10 MR. GLASSMAN: I will object. I don't 19 see where this is even vaguely relevant as 20 to what he ever considered, but he can answer 21 it.
22 A I don't recall having considered whether 23 we should be filing things under 10CFR21 or under
'O Q 24 some other requirement that we have for reporting.
25 g Did you conclude that any of the things
1 Broughton 84
/,~~~)
2 that were looked into as a result of the March 28, 3 1979 accident raised a substantial safety concern?
4 MR. GLASSMAN: I object in that there 5 is no foundation for this type of question.
(
6 The witness has already testified that the 7 question of reporting to the NRC post-accident 8 was an area that fell under the responsibility 9 of others. So whether or not he had some 10 kind of conclusion of this s o r t ,', i t is just 11 utterly irrelevant.
12 MR. WISE: I don't think it is and I
['N
\~
13 think you may be mistaken about the requirements 14 of part 21, but we can argue that at another 15 time.
16 MR. GLASSMAN: Well, the witness may 17 or may not be mistaken about part 21.
18 MR. WISE: Not the witness, Mr. Glassman.
19 MR. GLASSMAN: Either of us may be 20 mistaken about that. Obviously part 21 is 21 available for us to look at. We can see what 22 it says.
l 23 MR. WISE: Since I have Mr. Broughton 24 here today, why don't I ask the question. If I 25 later find out that it is irrelevant, you can
1 Droughton 85
\'
2 preserve your objection with the judge at the 3 appropriate time.
4 1 MR. GLASSMAN: You may proceed.
() 5 MR. WISE Would you like the question 6 " reread?
7 THE WITNEF3: Yes.
8 (Question rend by.the reporter.)
9 A I don't think that anything I looked into 10 or any conclusions I reached were ones that I would 11 have label'ed substantial safety concerns. The 12 reports that I was involved in preparing drew
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13 conclusions and made recommendations and some of 14 those conclusions and recommendations addressed 15 issues which we felt needed to be improved, but I 16 don't think that I ever considered them in the light 17 of substantial safety' concerns with respect to 18 reporting requirements.
19 Q I would like now to talk abou't a different 20 area.
21 You are aware of the existence of
(_- 22 so-called operating.and emergency procedures for 23 TMI-1 and THI-27
() 24 A Y e s '.
25 g After you joined spu service in 1976 did
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A I don't recall ever undertaking any is
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4'eview came the turbine, trip test data.
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3 ,
1 s >Q Do_you know if there was any practice
~', oI' ,"aNtGPUService before t'he' time'you arrived to 13 14 analyze operating events! that occurred a't TMI-1 or 15 oyster Creek? -,
i ;,; ^ , ,
16 , MR. GLASSMAN: Could I have the question 17 back for a second? .
18 (Question read by the reporter.)
19 A I don't know of any particular practice 20 sto do that.
s ,
.s Qt For instance, we will be talking in a 21 ;l '
(I ,'/ 22
\
fdw morc,ents about thef task force report that was
/
t l 23 .done following the April 23, 1979 transient at i
)h 24 TMI-2'and I have noted that that task force is 25 ' labeled TDR001. I have seen a number of other TDRs o .
- 5? . , . '
1 Broughton 88
("%
(_ -
2 in connection with document productions made during 3 this case and they seem to have a sequential numbering 4 system that continues.
({ 5 The ques tion I am driving at is whether 6 there was any prior series of reports or analyses 7 under some other numbering system or perhaps without 8 ,
any numbering system that may have existed before
. 9 the TDR system was started up for operating events i
10 at the nuclear plants within the GPU dystem? -
s 11 A well, you had asked about the service 12 company previously and the answer to th a,t was I don't
('-
13 ' recall that there was any system ther . However, 14 within the operating companies, I believe there was 15 a system of reporting on various plant events but 16 I am not familiar with what the range of events 17 that were covered by that reporting was,.
.18 Q You say reporting. Are you speaking of
, 19- the licensing event reports required by the NRC?
20 A No, I am speaking of a separate report
, 21 which may have led to a licensing event report but km 22 I don't know that all of these led to licensing I 23 event reports.
() 24 Q Let me try and get at it another way.
25 Suppose you were interested in trying to find out
1 Broughton 89 rN -
i 4
\/- 2 what types of events had occurred at TMI-1, for 3 instance, from the time that it became commercial 4 up through 1979. Where would you have gone to look
-5 for that kind of information, was there some kind of
(.i j 6 a filing system or central repository for those 7 sorts of reports?
8 A First of all, I would have looked at the 9 plant at TMI-1 for TMI-1 events and Oyster Creek for 10 oyster Creek events and I don't know where I have 11 looked there. I would have contacted someone who 12 was in charge of preparing those reports and the n,-
,_. 13 one type of report which I would expect to find at 14 TMI-1 would be a reactor trip report and I don't 15 know if there were other types of reports that they 16 kept.
17 Q Suppose you were interested in finding 18 out whether any analysis of *.he v'arious
~
19 events had been done at the GPU Service company, 20 where within GPU Service would you look?
21 A Within GPU Service I would have gone to C 22 the proj ect office for that particular plant, but 23 I don't know of any comparable system of trip reports
(~N 24 or analysis reports that existed prior to this
(_.)
25 TDR system.
1 Broughton 90 2 Q Which was initiated in 19787 3 A Yes, and the TDR-system is a document control 4 system for a variety of types of documents, It is
( 5 not simply limited to documents that would discuss 6 plant events.
7 Q Mr. Broughton, is it fair to say that 8 before 1978 GPU Service did not have a regular
, 9 -practice of performing analyses on operating plant 10 events? t 11 A There was no regular practice of 12 performing those analyses by GPU Service that I am
'> 13 aware of since the responsibility for those plants 14 in analyzing those events was with the operating 15 companies.
16 Q In 1978 a practice was begun of performing I
i 17 those analyses, isn't that right, within,the service l 18 company?
19 A Not to my knowledge. In 1978'there 20 was an event which occurred at TMI-2 in which the i
l 21 service company was asked to perform an analysis 22 or an investigation, but I don't know that that was 23 the establishment of a practice to do that. My
() 24 understanding is that that was done at the request l
25 of the plant rather than as a matter of routine.
I I
1 Broughton 91 2 Q There was another event in November of 3 1978 at TMI-2 which the service company was also i
4 asked to analyze; is that right?
5 A This was the November 7 partial loss of
{
6 feedwater event?
7 Q Yes.
8 A The service company was asked to provide 9 some assistance with that. My memory is not that 10 clear on what assistance we were. asked to provide 11 and especially how that assistance might have 12 compared to what we were asked to provide in April 13 of '78. For example, in April of '78, as I recall, 14 a task force was set up to investigate that event.
15 I don't recall that a similar action was taken on 16 the partial loss of feedwater events in November.
17 Q Are you aware of any particu,lar objective 18 criterior that were in use during 1978 tb determine 19 when the service company would become inv'olved in i
20 performing an analysis and an investigation with 21 respect to operating events?
22 MR. GLASSMAN: Are you looking for
! 23 criterior of the service corporation or criterior 24 of some other corporation?
25 MR. WISE: Any criterior in existence
1 Broughton 92 0 2 within the GPU system under which it could be 3 determined whether the service corporation 4 would or would not become involved in an
{j 5 analysis and investigation.
6 A I am not aware of any criterior. There 7 may have been criterior, but I am not aware of it.
8 Q During the period 1976 through March of 9 1979 did you subscribe to any industry periodicals?
i 10 A I don't personally remember subscribing 11 to any industry periodicals during that period.
12 Q Did you as a regular practice review any 13 industry periodicals?
? 14 A I reviewed some periodicals that were 15 received by the company and routed.
16 Q Which of those do you remember reviewing?
l 17 A I recall Nuclear News. That's the only
~
18 periodical I recall.
19 Q Did you ever review licensing' event 20 reports or summaries thereof for various operating 21 nuclear plants in the United states?
22 A Not regularly.
23 Q Do you know whether anyone within the GPU
['
(
24 system received copies of licensing event reports 25 or summaries thereof on a regular basis?
1 Broughton 93 O 2 A I know that summaries of event reports 3 were received. I don't know who all the recipients 4 were.
Q Well, did you or anyone in your section
( 5 6 or command, if you will, regularly receive those 7 s ummari es either when you were manager of Licensing 8 or when you went into your new duties as manager of 9 Contr61 and Safety Analysis?
10 A I recall -- t 11 MR. GLASSMAN: Just so the question is 12 clear, are you now still talking about the
('T .
\- 13 time period before the accident?
14 MR. WISE: Yes. -
15 A I recall reviewing the summaries in 16 the Licensing section. I don't know whether those i
17 were sent to Licensing or whether they were sent to I
L l 18 someone else and' routed through Licensing'. I don't 19 recall looking at the summaries after we formed the 20 Safety Analysis section.
I 21 Q With respect to the ones that you reviewed C 22 while you were in the Licensing section, on how many 23 occasions that you can recall did you initiate a I
(~/
x
') 24 further action at GPU or one of the operating companies
'25 as a result of having read the summary of an LER?
1 Broughton 94 p
G 2 MR. GLASSMAN: We are talking about 3 Mr. Broughton personally?
4 MR. WISE: Yes.
5 A well, first of all, the review that I
(
6 recall doing was not for the purpose of issuing 7 actions based on review, and I don't recall if there 8 were actions issued by others who reviewed either 9 the summaries or individual LER's.
10 Q Do you know whether anybody within GPU 11 Service corporation had the responsibility for 12 reviewing LER's to determine whether some action N- 13 needed to be taken as a result?
14 A I do not know.
15 Q what, if anything, did you do either 16 when you were in the Licensing section or later when 17 you were manager of Control and Analysis.before the 18 TMI-2 accident to keep yourself abreast of operating 19 events at other nuclear plants in the United States?
20 A I don't recall doing anything specific 21 with regard to operating plant events. Our focus L 22 prior to March of '79 was on supporting construction 23 activities and it was in the framework of things
( 24 that were happening in other plants that effected 25 construction activities that we really focused.
_ _ . ._ _~ _ - . - . . ._. . - . . .
l I
1 ~
Broughton 95
(~%
'2 Q What did you do in that regard to 3 keeping yourself abreast of events that would impact 4 on whatever construction responsibilities GPU 5 Service had?
6 A one of the primary things that we did 7 was subscribe to the Licensing Information Service 8 which is an industry-sponsored group that provides 9 information from all different plants that are 10 engaged in licensing activities with the NRC and 11 makes that available to each of the members of the 12 service.
ks- -
13 Q Was there anything else?
14 A That's the only formal thing that comes 15 to mind, but I think it's also true that in our l 16 reviews of things like industry periodicals or 17 information about general information about 18 nuclear plants, our focus was primarily o'n looking 19 at things that were related to the design ~, construction, 20 licensing process.
21 Q TMI-2 was still a GPU Service Corporation L 22 responsibility at the time you joined that company, 23 was it not?
24 A Yes.
25 Q It was not transferred to Met Ed's
1 Broughton 96 O'
2 responsibility until sometime in 1978, isn't that 3 right?
4 A It could have been the end of '77, but 5 it was before March '78.
6 Q Would it help refresh your recollection 7 if I told you that fuel was first loaded at TMI-2 8 in February of 1978?
9 A No, it doesn't.
10 Q Do you know when TMI-2 f i r.s t went critical?
11 A I don't know for sure. I believe that 12 it was in March of '78.
f's
( 13 Q I think you are right.
14 Did you ever attend any meetings or 15 discussions with representatives of companies that 16 owned plants employing B&W nuclear steam supply 17 equipment before March 28, 1979? ,
18 A I certainly attended meetings' at which 19 there could have been other B&W plant own 'e r s there, 20 but I think what you would like to know is did I 21 specifically go to a meeting that involved B&W-owners
- k. 22 to discuss D&W owner issues and I recall one which 23 I attended to discuss the issue of anticipated 24 transients without scram which I am confident was I
(")T
(
25 before March '79.
1 Broughton 97 O 2 Q Where was that meeting held, as best you 3 recollect?
4 A That was in Lynchburg, at the B&W i
5 Generation Division headquarters.
(
6 Q Did anyone besides yourself from the 7 GPU system attend?
8l A I believe Courtney Smyth from Met Ed 9 attended.
10 Q Is there anyone else thats.you recall?
11 A I don't recall anyone else.
12 Q What was Mr. Smyth's position?
' s. 13 A He was part of the licensing group at 14 Met Ed.
15 Q He would have worked for Mr. Potts?
16 A He would have if Mr. Potts was in that 17 position at the time. I don't recall if,he was.
18 Q Was this meeting held while you were 19 still in the licensing section at GPU Service?
20 A To the best of my recollection it was.
21 Q What was the purpose of the meeting?
( 22 A It was to discuss the anticipated 23 transient without scram issue. I don't recall I [ 24 exactly why the meeting was called. I really can't 25 recall anything else about the purpose of the meeting.
U
1 Broughton 98
[\
' ~ '
2~ Q Who else was present besides the GPU
- 3. representatives?
4 A Well, there were of course people there 5 from B&W. There were representatives from some other
{
6 B&W utilities but I don't recall which utilities 7 were represented.
8 Q Who was there on behalf of B&W?
9 A I can't remember.
10 Q Had you been invited to the meeting 11 directly or learned about it through some other 12 method?
)
N/ 13 A I don't recall.
14 Q How long did the meeting last?
15 A No less than the better part of one day 16 and it may have been longer.
17 Q Do you think it might have lasted as 18 long as two full days?
19 A There is a possibility that it did, but 20 I don't recall.
21 Q What was the anticipated transient without 22 scram issue, as you put it?
, 23 A Anticipated transient without scram is
(}
24 a generic licensing issue which existed prior to my 25 joining GPU and is still considered to be an unresolved l
- r. . -
1 Broughton 99
(~%
4 2 generic issue and it concerns transients in which 3 the reactor protection system should cause a scram 4 but for some reason does not and involves the study 5 of what the plant respons e might be, discussions of
(
6 how to both reduce the probability of such an event 7 and mitigate the consequences of such an event.
8 Q During the course of your involvement 9 in that issue was the subject of high pressure 10 inj ection ever discussed? t 11 A Does your question refer to the meeting 12 that I attended on that issue?
O
- k. / 13 Q Let's take it first that way and we'll 14 limit it to the meeting and then I will broaden it.
15 A I do not recall if that was discussed 16 at the meeting.
. 17 Q Did it ever come up in the course of 18 your work on the anticipated transient without scram l
~
l 19 issue?
20 MR. GLASSMAN: During what work? I am l
21 not sure what work we are talking about now.
22 MR. WISE: Mr. Broughton attended a l
l 23 meeting concerning this issue and he testified I
f')
\/
24 that it was an issue before he came to the l
25 company and it is still an issue and to the l
1 Broughton 100 i i I
\/ extent that he did any other work besides 2
3 going to the meeting, my question now is can 4 he recall whether the subject of high pressure f
5 injection, its initiation, its continuation 6 and its possible termination ever arose in 7 connection with that work.
8 A I don't recall for TMI, either 1 or 2, 9 discussing high pressure injection with regard to 10 ATWs. t 11 Q Have you ever,become aware of an event 12 at TMI-1 in which the ruptured disc on the reactor 13 coolant drain tank blew?
14 A I don't remember.
15 Q You don't remember whether you have ever 16 become aware of that-or not?
17 A That's correct, I don't.
18 Q During the course of the various 19 investigations that you were involved in following 1
20 the accident at TMI-2 on March 28, 1979, do you know 21 whether you or anyone working with you attempted to 22 determine whether sucn an event, that is a ruptured 23 disc blowing, had occurred at TMI-1 before the TMI-2 24 accident?
4 N,
25 A I don't remember ever trying to answer
2.
1 Broughton 101
(
\ /' 2 that question.
3 Q Before the accident on March 28, 1979, 4 are you aware of any systematic procedure or practice 5 within GPU Service or the operating utilities to
{
6 incorporate information learned during operating i
7 events into procedures and training?
8 A I am not aware of any. I am not aware 9 of it.
10 Q Have you ever become awar of an event 11 at TMI-2 that occurred on March 29, 1978 involving 12 loss of power to a bus and consequent opening of the b)
\_/ 13 PORV, or I should say failed open PORV7 14 A Yes, I am aware of that event.
i 15 Q .when did you first learn of that event?
16 A I first heard of the event shortly after 17 it happened, most likely within days, so that would 18 have been March or early April of '78.
19 Q What were you told about it at that time, 20 as best you can now recall?
21 A As best I can recall, I have been told 22 that there had been a loss of power to instruments, 23 one of which provided a pressure signal for the 24 control circuit of the PORV and that on the loss of 25 power to that instrument the valve failed in the l
1 Broughton 102 2 open position.
3 Q How did you learn about this? Was this 4 a telephone call or casual chat in the hall or some g 5 kind of written report; how did this come to your 6 attention?
s 7 A I don't recall a written report. I 8 believe it came to my attention through discussions 9 with someone at the service company who was working 10 in the Parsippany area. I don't recal1 discussions 11 with any people at the plant site.
12 Q Do you recall whether there was some
, (-
O) 13 specific reason for your being inform [d about the 14 events?
l I
15 A I don't recall a specific reason insofar I
16 as we were asked to do anything about it. I believe 17- that we were informed because it related to the ,
l 18 test program and as a matter of keeping people 19 who were involved in the project advised o f the 20 status of the program, I think that's the reason 21 that we got the information.
' oo Q Were you still involved in the TMI-2 l
23 program as of March and early April 1978?
f'T u>
24 A We were still involved to the extent 25 that if questions came up during the test program in r
I
[ . .. . . - - . . - - - - - . - - . _ - - _ . . ... . - - - - - - , . - - , , _ , _ - - _ -
1 Broughton 103 O
%-] 2 which we had had the lead in providing answers to 3 or would be involved in providing information from, 4 we would participate in those discussions. We did 5 not have the lead from the standpoint of the
{
6 licensing lead.
7 Q Was there some aspect of the March 29, 8 1978 transient at TMI-2 that bore upon whatever 9 continuing responsibility GPU Service Corporation 10 had for the plant? t 11 A I believe that GPU Service Corporation 12 still had the responsibility for making design O-s- 13 chmnges which might have been identified through 14 the test program and therefore the parts of the 15 organization that were involved in that had 16 responsibility.
17 Q After you were informed abou,t the events, 18 what if anything, did you do next with respect te it?
~
19 A I don't recall taking any particular 20 action with regard to the avents.
! 21 Q Did you ever perform any analyses of the l 22 event before March 28, 19797 l 23 A Not to my recollection.
24 Q Did you ever become aware before March 28,
(
25 1979 that design changes had been instituted at TMI-2 l
1 Broughton 104 1
2 as a result of the March 29, 1979 incident?
3 A Yes, we were aware of design changes 4 that were made in response to the March '79 event.
( 5 6 of?
Q What design changes did you become aware 7 A As I' recall there were two, one was a 8 change in the logic circuit for the valve, such that 9 if the power supply to the sensor failed as it 10 had done, then the valve would not faisl in the open 11 position, And I believe that the second was 12 installation in the control room of an indicating 13 light which indicated that the solenoid to open 14 the valve was energized.
15 Q What was your involvement, if any, in 16 the second design change you mentioned, the indicator 17 light? ,
,1 18 A I don't recall having any involvement
( .
19 in that.
20 Q Do you know whether anybody reviewed l '
21 that change from a licensing standpoint?
22 A No, I do not.
23 Q Who was responsible for the design change O
U 24 with respect to the indicator light?
25 MR. GLASSMAN: By responsible you are i
l
1 Broughton 105 O 2 not asking him to draw some legal conclusion 3 or anything like that. I assume you are 4 asking for who did any work on this without gr 5 regard to ultimate responsibility?
6 MR. WISE: Yes.
7 Q what is your knowledge as to who was 8 in charge of that proj ect?
9 A "I don't know.
10 Q You never heard? g 11 A I guess since that time I have heard 12 that there were certain groups involved, but I don't n/
\_ 13 know who was responsible for doing it[whoprovided 14 the conceptual design or the final design, who 15 was involved in design approvals. I never looked 16 into that.
l 17 Q After the Three Mile Island accident on 18 March 28, 1979, did you ever make any indestigation
^
19 into that design change?
20 A I don't Eecall doing anything that might 21 ,
be termed an investigation.
22 Q Let me remove that word if it is giving 23 you trouble.
, [T 24 Did you do anything as far as the
\m.
25 March 29, 1979 incident and the instal'1ation of an
4 1 Broughton 106 A
2 indicator light for the PORV is concerned?
3 THE WITNESS: Could you read that back 4 to me, please?
5 (Question read by the reporter.)
{
6 Q My question is directed now at the 7 period of time after the accident, 1979, and 8 specifically to any investigations or analyses that 9 you did following the accident.
10 A That would have related to the March 11 '79 event?
12 Q Yes.
,Os
\- J 13 A I thought that was two qubstions and I 14 wanted to make sure that if you wanted to know about 15 analysis than I would address that part, 16 Q Let's take the PORV indicator light 17 first. After the PORV accident in March,1979, did 18 you do anything as far as looking into the installation 19 of that indicator light at TMI-27 20 A I personally do not recall looking into 21 tha modifica tion of the PORV.
L 22 Q Do you know if anybody else did?
23 A I don't know for certain that someone else did.
( 24 25 Q What is the best of your information as
1 Broughton 107 2 2 to whether someone else did?
3 A I believe that was looked into.
4 Q Do you have any information as to who
( 5 6
looked into it?
A I have a vague recollection that it was 7 looked into as part of the task force report on 8 the March '79 event.
9 Q Do you have any information as to who 10 the individual was? ,
11 A No.
12 Q Have you ever seen or heard the result 4
\s,/ 13 of whatever looking into was done on [ hat issue?
14 A I' don't know that I ever heard the 15 final results.
16 Q Have you ever heard the prelkminary 17 results?
18 A I may have heard some results'. I don't 19 have a clear picture of what was looked into or i 20 what the conclusions were or who was involved in the l
21 design.
22 Q Did you ever make any investigation
, 23 following the accident in March 1979 to determine I
whether the operators who were on duty during the
(}
\--
24 l
25 first few hours of the accident had referred to the
I 1 Broughton 108
\~# indicator light for the PORV?
2 3 A My recollection is that the operators 4 did refer to that indicator light to determine 5 the position of the valve, but I don't recall what
{
6 my source of information was, whether it was reading
. 7 an interview of an operator conducted by someone 8 else or just exactly what the source of that information 9 was, but that is my recollection.
10 Q You personally interviewed or were 11 present during interviews of the control room 12 operators on several occasions, were you not?
(~) ..
(/ 13 A I was present during some task force 14 interviews but I don't recall that any o'f those that 15 I was present through were control room operators.
16 Q Did you interview the operators on the l
l l 17 day following the accident, March 29, 19797 ,
~
i 18 A I did not.
l l
19 Q I have seen some notes of you'rs, 20 Mr. Broughton, which we'll mark a little bit later 21 that indicate that there was an intention to interview 90 the operators at 11:00 P.M. on March 29, 1979.
i 23 Do you have any recollection of any f ['T 24 plan to interview the operators on the evening of i d i 25 the 29th?
i i
I
i l
l 1
i 1 Broughton 109 !
O
~
2 A Yes, and my recollection is that 3 operators were interviewed. They were not interviewed 4 by me. I was not present at that interview.
5 Q Who was, to the best of your knowledge?
6 A To the best of my knowledge Jim Moore 7 was there and probably conducted at least part of 8 that interview.
9 Q Who is Mr. Moore?
10 A He was a service company gmployee. I 11 believe his position at the time was manager of 12 either mechanical systems or mechanical components.
13 Q- Do you know whether any record was 14 made of those interviews conducted by Mr. Moore?
15 A I don't know for certain. I would be 16 surprised if there weren't at least notes of that 17 interview, but I don't, for example, know whether 18 there was a tape recording or a transcript.
19 Q You have never seen a recording or a 20 transcript of that interview?
21 A Not as far as I know.
L 22 Q You were aware on March 29, 1979 that 23 the operators had given statements during the early 24 morning of March 29; were you not?
(~')i 25 MR. GLASSMAN: To who? Statements to
1 Broughton 110
('h 2 anybody?
3 MR. WISE: Yes.
4 A I don't recall that.
g 5 Q we'll come back to this when we have 6 some materials that may help refresh your recollection.
7 I didn't really mean to get into it at this point.
8 Let me go back to the PORV indicator 9 light. You said that you had gained the impression 10 either from interviews or reading inte,rviews of 11 the operators that they had referred to the indicator 12 light during the course of the March accident?
O 13 MR. GLASSMAN: I don't believe that's 14 the testimony. I believe the testimony was 15 that Mr. Broughton simply did not recall the 16 source.
17 MR. WISE: All right. ,
18 Q You didn't recall the source,'but you 19 gained that impression one way or another?
20 A Yes.
21 Q Did you ever gain any impression as to L 22 whether the operators during the accident were aware 23 that the indicator light did not show the actual
~
24 position of the valve, but only showed whether
. 25 power was on or off to the solenoid which governed
1 Broughton 111 O' 2 the valve?
i
, 3 MR. GLASSMAN: Aware at what point in 4 time?
5 Let's ask first whether at any point '
{ Q 6 during the course of the accident. I don't want 7 to go through it hour by hour. If it's relevant, 8 we can do that. Let's see what the opening answer 9 is and I will pursue it further if need be.
10 A I don't recall that that question was 11 asked or answered. I don't recall whether the 12 operators thcught what they were looking at was
(~h
\_)
13 actual indication or indication of power to the 14 solenoid.
15 Q Following the March '79 accident at 16 TMI-2 did you make any investigation to determine
. 17 what if anything the operators had been told following 18 installation of the PORV indicator lighth 19 A I don't remember looking into'that.
20 Q Do you know whether anybody did?
21 A I don't know.
L 22 Q Did you ever become aware of how long 23 the PORV had remained open at TMI-2 on March.:29, 24 19797 25 A Are you asking for my understanding on
1 Broughton 112 O
\~l 2 March 29, 1979 or sometime after that?
3 Q Sometime after that, In other words, had 4 you ever become aware of the length of time that
( 5 6
the PORV was open during that incident?
MR. GLASSMAN: Up until today?
7 MR. WISE: Up until today.
8 A Yes, one of the things that we looked 9 at and we looked at the accident data, was information 10 which would have led us to conclude how long that 11 valve was open. And also how long the block valve 12 which can also stop flow through the valve was open (3
s._/ 13 and shut. We looked at both of those' things.
14 (Witness confers with counsel.)
15 Q Is-it clear that I am speaking about the 6 1978 accident now?
17 A No, I was not clear. I was addressing the 18 '79 accident.
19 MR. WISE: I had a suspicion.- Let's 20 clear it up.
21 MR. GLASSMAN: I thought there was some 22 misconception there as to what dates we are 23 talking about here. As we all know there has 24 been tendencies to confuse March 28, 1979 and 25 March 28, 1978.
- - - , v , w-. -.
1 Broughton 113 (h
U 2 MR. WISE: I am now back on the earlier 3 transient, Mr. Broughton, and speaking of the 4 March 1978 transient.
{, 5 Q Did you at any time become aware of the
-6 length of time that the PORV remained open during 7 that incident?
8 A After the March '79 accident we went back 9 and looked at data from the March 28 stuck open 10 PORV event and did determine how long 'the valve had 11 been in the open position.
12 What was your determination?
Q
\ 13 A As I recall it was on the order of 14 six minutes.
15 Q During the period of time that the valve 16 was stuck open in March 1978 was there an initiation 17 of the emergency safeguard system, high pressure l
i 18 injection?
19 A My recollection is that the high pressure 20 injection system did actuate.
21 Q Was the high pressure injection system
~
j 22 left running until after the PORV had been closed?
l 23 MR. GLASSMAN: We are asking for this
( 24 witness' knowledge at some point in time or 25 what he learned? He wasn't actually there so I
1 Broughton 114 Qs/- 2 I d o'n t think he can testify from firsthand 3 knowladge. ,
4 MR.' WISE: I don't think he can, _ I am t
s 5 only trying to get what the result of his 6 investigations were.
7 A I don't recall looking at the timing of 8 when the system was terminated.
9 Q After the March 1979 incident rather, 10 accident, you were not interested of w en the 11 operators in; March '78 had terminated HPI following 12 a sticking open of the PORV7 5
(_ 13 A No, and I will be glad to explain to you 14 ' -why we were looking at the March '78 stuck open 15 PORV. The motivation was to try to get an idea of 16 yhat . position the PO.R,V Dight have been in on i
17 March 28, 1979. It was not known initial 1y when we 18 first started to'look at data for the March '79 l , . .
19 accident whether the' valve was --
the PORV was 20 fully open or in some intermediate position or l 21 perhaps nearly shut and just leaking so one of the
( 22 ways that we tried to determine that was by comparing 23 the rate of1 pressure decrease in March '79 with
(~N 24 the rate oh pressure decrease that we saw in March N- ,
' 78 and we knew that in March78 the valve had been 25 t
7 -s
^
~\
f A
-~ y -,m,--
_ _ . , ~. - . ..
i i
1 Brough, ton 115
(\
'/' 2 fully open,that that was really the basis for going 3 ,back to that data and looking at that data to see how 4 we could apply it to the March '79 data.
5: Q 'What.did you find?,
6 A We found that the rate of pressure 7 decrease in both events was similar and therefore 8 we b'eganlour analysis by assuming that the PORV was 9 stuck in its fully open position and the later 10 analysis that we did confirmed that the valve was in 11 a fully o' pen or nearly fully open position.
12 (Recess tcNen.)
a n '
_ 13 BY MR.1 WISE:
14 'Q Before the' break, Mr. Broughton, we 15 were discussing the Merch 1978 transient at TMI-2.
16 Have you ever had an opportunity to 17 review a staff report prepared by the U.S. Nuclear 18 Regulatory Commission sometimes referred"to as NUREG 19 0560, also sometimes referred to as the Tedesco 20 Report?
-21 A Yes.
L 22 Q Are you familiar with the fact that in 23 that report there is a description of the March 1978 24 transient at TMI-27 25 A No, I am not.
1 1 Broughton 116 b);
\_ 2 Q I asked you how long the PORV remained 3 open during the 1978 transient and I believe you 4 testified that ypu thought it was about six minutes, r
5 The Tedesco Report, for what its worth, 6 indicates that the PORV was open for approximately 7 four minutes. t.Do e s that in any way help refresh your 8 recollection? -
9 MR. GLASSMAN: Of what, of the Tedesco 10 Report? 2-11 MR. SISE:
. No, of how long the PORV was 12 open.
) 13 A I saAd about six minutes.' If it was 14 really four minutes, that would not --
I~ think four 15 minutes was included in my "about six minutes."
16 Q Did.you ever learn what had" happened to 17 the reactor coolant system pressure during the time 18 that the PORV. remained open? -
19 A Yes.: -
20 Q What had occurred with respect to pressure?
21 A Pressure had continuously decreased from
(
A- 22 the time the valve was opened until the time the 23 valve was reshut.
(~ 24 Q How : low did pressure go?
U}
25 A My recollection is that it dropped to I
1 Broughton 117 O' 2 approximately 1200 psi.
3 Q Do you recall at what point during the i
4 transient high pressure injection was initiated?
5 A No, I don't.
6 Q You testified earlier you don't recall 7 when it was terminated?
8 A That's correct.
9 Q Was any investigation made into pressurizer 10 level during the course of the first f,ew minutes of 11 that March 1979 transient?
12 MR. GLASSMAN: Are you asking whether 13 there was any investigation made at any time?
I -
j 14 MR. WISE: Yes.
15 A I don't recall the investigation in
?
16 the pressurizer level.-
17 Q Following the March 1979 TMI-2 accident 18 to your knowledge did anyone investigating the '79 l
19 accident ever go back and take a look at what had 20 happened to pressurizer level during the 1978 21 transient?
22 A I don't know if that was looked at.
23 Q Did you ever become aware that during
~N 24 the March 1978 transient certain. instrumentation 25 had been lost?
l
1 Broughton 118
^x
)- A This is March '787 2
3 Q Yes, the early transient.
4 A Yes, certain instrumentation was lost.
5 Q Do you have a recollection as to whether 6 pressure, reactor coolant system pressure, was one 7 of the areas of instrumentation that became unavailable 8 during the course of that transient?
g Let me read you from the Tedesco Report 10 at page 3-4 and let me know if this helps refresh 11 your recollection. After a description of the 12 initiation of events it says, "The operators took f~h
'\_,) 13 immediate acticn by closing the RCS l$tdown isolation 14 valve and verified the required safety injection 15 component started. Follow up action was hampered 16 by the loss of temperature - compensated pressurizer 17 level indication and reactor coolant system pressure ,
18 indication powered from vital bus 2-1v."~
19 Does that in any way help refresh your 20 recollection as to the loss of inst 11 mentation during 21 the course of the March 1978 transient?
22 A Yes, I recall,that some pressure 23 instrumentation was lost, not all was lost, and that 24 some pressurizer level indication was lost. I don't 25 know if any pressurizer level indicution was retained.
1 Broughton 119 O
b- 2 Q To your knowledge was any investigation 3 ever made into whether during the course of the 4 March 1978 transient any flashing had occurred in 5 the reactor coolant system as a result of the
(
6 decrease in primary system pressure?
7 A I recall having looked at the data from 8 the March '78 transient sometime after the March '79
, 9 accident at TMI to see if the pressure had gotten low 10 enough to cause saturated conditions to exist in 11 the loops. I don't recall exactly when that was 12 looked at. It was sometime after the March '79 0- 13 accident.
14 Q First, let me ask you what sources of 15 information did you have in looking into that question?
16 A The data that I recall we had was from 17 the reactimeter which is a piece of test. equipment 18 which was installed inoperable in recording data.
~
19 We also had some data from the plant computer but I 20 don't recall what data that was and whether it was 21 from instruments which had power or did not have L 22 power.
23 With respect to the reactimeter data, I
( 24 do recall that we had a pressure instrument which 25 did have power as part of that reactimeter data.
a 1 Broughton 120 ra 2 Do you recall whether there was an Q
3 instrument showing pressurizer level that was 4 recorded on the reactimeter?
5 A I do not recall whether t.here was a
{
6 pressurizer level instrument recorded.
7 Q How did you get your hands on that 8 reactimeter data? We have been trying to for a 9 while.
10 A I don't specifically remember what we 11 did to get that data.
12 Q Do you know where it came from?
'i ,
13 A For that particular event I do not.
14 Q Do you remember where it went to after 15 you had it?
16 A I still have it.
17 Q In the course of this litigation do you 18 know if you have ever been asked to go through your 19 files for information relating to the Mar'ch 1978 20 event?
21 A I don't specifically remember that, but 22 in general I remember going through files to collect 23 data.
24 Q Do you know whether you have ever turned 25 over to your lawyers copies of the material that you
1 Broughton 121 f]'N
\
- 2 had relating to the March 29, 1978 accident?
3 A I don't know for sure.
4 MR. WISE: Mr. Glassman, obviously we 5 are interested in the March 29, 1978 transient 6 and I believe it has been covered by the 7 previous document requests. We would like 8 production of any files that Mr. Broughton 9 has relating to that transient. obviously 10 it will impact somewhat whether1,ve can conclude 11 this examination this week depending upon when 12 we can get those files and have an opportunity 13 to review them.
14 To this point it is my understanding 15 that we have never been provided with that 16 data.
17 MR. GLASSMAN: I am not aware precisely I
18 as to what data y~ou have been provided 19 with and what the situation is in r' elation to 20 the document request, but I think this is a 21 reques t here and certainly we'll do our best 22 to see if we can provide it.
23 g what kind of files do you have on the i 24 March 29, 1978 transient? Do you have a couple of m) 25 them, one of them; is it a thick file, a thin file,
1 Broughton 122
<^s'
. ('
2 lots of computer materials, how would you describe it?
3 A I remember one thin file with a report 4 generated by someone who may have been part of the 5 test group, the reactimeter data and some data from 6 the plant process computer.
7 Q How much reactimeter data was it, was it 8 big and thick or thin? How would you describe it?
9 A It looks like a standard high speed 10 printer output and it's probably 20 pages.
11 Q How about the material from the computer 12 printout?
13 A That may be half a dozen sheets, standard 14 size sheets of paper.
15 Q what else is there in your file relating 16 to the March 29, 1978 transient?
I 17 A I don't recall anything else.
18 Did you make any notes or writings?
Q
~
19 A I don't recall.
20 Q did you check-to see what had happened 21 to reactor coolant drain tank temperature and 22 pressure during the course of the March 1978 transient?
23 A I don't recall looking for that. And I 24 don't know if it was -- if there was data for that.
25 Q Did you ever make any search to determine
1 Broughton 123
['T
(_/ 2 if there was any information or data with respect 3 to what happened in the -- or what happened to the 4 thermocouples in the discharge line leading from 5 the relief valves at the top of the pressurizer 6 during the March 1978 transient?
7 A At what point in time?
8 Q At any time. Have you ever gone to see 9 whether there was any information relating to the 10 discharge, discharge line temperatures during the 11 course of that transient?
12 A I don't recall looking for that. As I
(~Ns_) 13 say, our focus was on pressure but I c'an ' t recall --
I 14 might --
we might also have looked for data like that.
15 Q You cannot recall now whether you found 16 any such data?
17 A No.
18 Q Did you ever determine what the operators 19 perceived was happening during the course-of the 20 first five or ten minutes of the March 1978 transient?
21 A I don't recall looking into that or seeing k- 22 the results of someone else look into that.
23 Q Did you ever determine whether any "3 24 written analyses or reports had been prepared by (L )
25 Met Ed concerning the March 1978 transient?
1 Broughton 124
(~s
\-- 2 A I mentioned that there was one report 3 which we received, but I did not recall who that 4 was from. It could have been from Met Ed, but it
( 5 could have been from someone else.
6 Q How long a report was that? We are 7 talking about something that's a hundred pages, a 8 thousand pages?
9 A No, it was brief. Perhaps three or four 10 pages, t 11 Q Was it typewritten?
12 A I don't recall.
~
1
\ 13 Q You mentioned at some point you did look 14 at reactor coolant system pressure during the March 15 1978 transient to determine whether flashing had 16 occurred in the primary system.
17 What conclusion, if any, did you reach?
. 18 A The conclusion was that therd had not 19 been any flashing in the primary system as a result 20 of the valves sticking open.
21 Q How did you reach that conclusion? ,
22 A By comparing the temperature in the 23 primary system to the lowest saturation temperature j 24 that existed during the depressurization and noting
- 25 that the temperature was always below the lowest
1 Broughton 125 N- 2 saturation temperature.
3 Q What happened to primary system temperature 4 during the first five or six minutes of the March
( 5 6
1978 transient?
A As I recall, it was constant or very 7 nearly constant.
8 Q Had the plant been operating at a reduced 9 power rate at the time of the transient?
10 A I believe that the plant was
,, in low power 11 physics testing at the time of the transien'. which 12 would have had the power in the intermediate range 13 below the point of adding heat.
14 Q Approximately what was the range of the 15 hot leg temperature during the course of the transient?
16 A I believe it was about 532 degrees.
17 Q Why were you investigating whether 18 saturation had occurred?
19 A That particular conclusion that 20 saturation wasn't reached was -- I don't believe it 21 was the result of any particular investigation. As 22 I recall, we were reviewing information that we had 23 from various plant events to see if it would be of 24 use in the training program and in particular part
[v'N, 25 of the training program that we were developing one
1 Broughton 126 2 of the things that we were using to show the course 3 of the transient was a plot of primary system 4 pressure versus primary system temperature and in 5 looking at this transient on that type of plot it 6 was obvious that the system had remained subcooled 7 throughout the transient. I believe that's the 8 only evaluation that we had done of whether or not 9 saturation conditions existed during that event.
10 Q Was this something that was done after 11 the Three Mile Island accident in March 1979?
12 A Yes, thic looking at material for use of
( 13 training had been done later on in 1979. Probably 14 the fall of '79.
15 Q Did you ever attempt in connection with
~
16 that work to go back and ask the operators whether l
l 17 they focused on saturation during the course of the 1
i 18 March 1978 event? -
l l 19 A I don't remember asking that.
I l 20 Q Did you ever become aware of whether'the i
21 operators at TMI-2 had received information concerning
- 22 the March '78 transient before the occurrence of I 23 the March 1979 accident?
l l gg 24 A I don't know.
A 25 Q were there any changes made to TMI-2
1 Broughton 127
\/ 2 operating or emergency procedures following the 3 March 1978 transient as a result of that transient?
4 A I don't know.
( 5 6
Q Do you know whether anybody ever reviewed the procedures for pressurizer system failure to 7 determine whether they were adequate in light of the 8 events on March 29, 19787 9 A I don't know.
4 10 _
Q Did anyone review the emer.gency procedure 11 covering loss of reactor coolant system pressure or 12 zeactor system coolant to determine its adequacy in 13 light of the March 1978 transient?
14 A I don't know.
15 Q Did anyone ever perform an analysis to 16 determine what the consequences would have been 4
17 during the March 1978 transient if power had not ,
18 been restored at the time it was?
19 A If power had not been restored to the 20 valve, the circuit that effected the valve?
21 Q That's right. In other words, did 22 anybody look into the consequences of what would 23 have happened if that valve had remained open for
, 24 some period beyond the time that it actually closed?
25 A well, before the TMI-2 accident in March
l 1
1 Broughton 128 m.
_ - 2 of '79, I don't know if anyone looked at that.
3 Cortainly in the training material that we put 4 together that possibility was looked at, the training r 5 material that we put together after the March '79 6 accident.
7 Q Let me ask just one further question in 8 this area.
9 Did you ever interview any of the operators 10 who were on duty during the course of t the March 1978 11 transient at any time with respect to that transient?
12 A well, before the March '79 accident, no.
p) g, 13 I don't recall if in our interviews after the March 14 '79 accident if there were discussions about the 15 March '78 stuck open valve.
16 Q You don't recall any such discussions 17 at this point?
A
~
18 No, I don't.
19 Q When did you first become aware that an 20 incident had occurred on April 23, 1978 at TMI-27 21 A I don't remember the date when I first 22 became aware of that.
23 Q Before we lo the April 23 incident,
N 24 let me pick up on one s revious incident that
.25 we touched on earlier, bu_ ,ust want to make sure
l l
l 1 Broughton 129 p)
(, 2 that we covered it entirely.
3 Yu testified earlier that you were not 4 familiar with an event that occurred in September 1977 5 during hot functional testing. Am I correct that 6 you have no knowledge of any such event even sitting 7 here today?
8 A There is no event that occurred at g TMI that I associate with September and hot functional 10 testing. That doesn't recall anything, t
11 Q Did you ever become aware that during 12 the course of hot functional testing an incident I)
\~/
13 occurred in which a bubble got into the loops and 14 there was difficulty in compressing it and removing 15 it?
16 MR. GLASSMAN: Objection ins'ofar as the I
17 question assumes facts not in the record.
18 MR. WISE: I will take my chances that 19 we can lay'a foundation for it at some other 20 point.
21 A Again, with the description you are
(- 22 giving me, I can't be sure that I either did or did 23 not hear something about such an event.
(- 24 Q Well, just to make sure that I am n >t V
25 missing something here, are you aware of any events
1 Broughton 130
~
(^}#
\'- 2 at TMI-2 before March 1978 in which saturation 3 conditions had been reached in the primary system 4 and a bubble formed in the hot legs?
5 A I am not aware of any events in which 6 the system saturated and we had bubbles in the hot 7 legs.
2 8 Q Mr. Broughton, would it change your 9 answer if instead of a bubble or steam being trapped 10 in the hot legs the incident involved (some form of 11 hot water being trapped in the hot legs? You are 12 not being technical with me in distinguishing between f)'T
(_ 13 an event involving steam? I gather that some pcaple 14 apparently believe the event involved steam and 15 other people have characterized it as hot water and 16 I guess you can go around and around on it.
17 A I would be happy to look at a document 18 that you have that addresses this event and tell you 19 if I recall it or don't. But from the de'scription 20 that I have heard so far, I cannot put my finger on 21 any event. .
22 Q Let's go forward to the April 23, 1978 23 event. Who told you about it?
/~N 24 A I don't remember how I first heard about
\s.j 25 it. One of the people that would have told me about
1 Broughton 131 A
.) 2 it would have been Bob Keaton. I don't know if he 3 was the first or if there were others.
4 Q Just to make it clear for someone reading 5 the record, could you describe your understanding 6 of the basis of the April 23, 1978 event?
7 A As I recall, this was an event which 8 occurred during the power range testing portion of g the startup program. I believe the plant was at 10 3 0 percent power. It was in an abnormal primary 4
11 configuration in that one coolant pump was operating 12 in one loop and two coolant pumps were operating in 13 the other loop. I believe there was an electrical 14 noise'in the nuclear instrumentation system which 15 caused a reactor trip -- following the reactor 16 trip one or more of the steam safety valves on the 17 secondary side of the plant failed to fully close at 18 their normal reseat pressure. The event was an 19 over cooling event. Those are the major things I 20 recall.
21 Q was there an initiation of high pressure
(' 22 injection during the course of the event?
23 A Yes, there was.
(' 24 Q What caused that?
25 A That was caused by low pressure in the
1 Broughton 132
- 2 primary system.
3 Q How long was high pressure injection 4 allowed to continne running?
r 5 MR. GLASSMAN: You are asking for the 6 results of the investigation?
7 MR. WISE: Yes.
8 MR. GLASSMAN: I again point out 9 Mr. Broughton was not really there.
10 Q Based on the investigatioq following the 11 incident, what did you learn about how long the 12 high pressure injection system had been allowed to
(~b x_) 13 continue operating?
14 A I don't recall.
15 Q Did you become aware at some point the 16 operators terminated it?
17 A I don't recall becoming aware of that.
18 However, if they had not terminated it, I am sure 19 that I would have recalled that because i~t would 20 have been abnormal.
21 Q At some point following the April 23, 22 1978 incident there was a task force appointed 23 within GPU Service to look into it?
' N, 24 A Yes.
-]
25 Q You became a member of that task force?
1 Broughton 133 r^N -
2 A Yes, I did.
3 Q Mr. Keaton was the head of the task force?
4 A Yes, he was.
( 5 6
Q And Mr. Cutler and Mr. Lentz and Mr. Wallace also served on it with you?
7 A Yes.
8 Q You have before you what has previously 9 been marked as B&W Exhibit 186 and identified during 10 prior depositions of being a copy of TDR number 001.
11 It's entitled TMI-2 Transient on April 23, 1978, 12 Task Force Report.
, 13 Are you familiar wich B&W Exhibit 1867 14 A Yes, I am familiar with this document.
15 Q Do you recognize that as the task force 16 report prepared by your task force on the April 23, l 17 1978 transient? ,
~
18 A Yes.
l 19 Q Would you look at attachment ~1 to the 20 task force rep' ort which appears on the page which 21 has-been marked for purposes of this lawsuit as 0585 22 in the bottom right-hand corner.
23 Do you see that?
24 A Yes.
25 Q That's a copy of a letter dated May 2,
1 Broughton 134
.I )
2 1978 from Mr. Arnold to Mr. Keaton.
3 Have you seen that letter before?
4 A Yes.
5 Q Is that the letter that sets up the task 6 force?
7 A Yes, it is.
8 Q Following that on the next page marked 9 0586 in the bottom right-hand corner for purposes of 10 this lawsuit, beginning with what appears to be 11 another report. The page numbers appear in the 12 bottom center of each page sequentially numbered f)
(_ 13 through to the end and then at the upper right-hand 14 corner someone has typed in additional page numbers 15 beginning with A2-3.
16 Do you see that?
17 A Yes, I do. ,
18 Are you familiar with the document that Q
19 begins on page 0586 as marked for this la'wsuit and i
20 continues through to page 0675 as marked for purposes 21 of this litigation?
C 22 A Yes, I am familiar with that section of 23 the document.
24 Q Do you know what it is?
25 A I believe this is the report that i
e t
1 Broughton 135
[~h
(/ 2 the -- that was generated by Metropolitan Edison 3 prior to the task force investigation.
4 Q Would you look at page -- well, for 5 purposes of this litigation, page 0588.
6 A Yes.
7 Q You will see there that in the middle of 8 the page beginning with the second full paragraph 9 there is a listing of various technical specifications 10 and limits and precautions that were, ccording to
- 11 this, violated during the course of the April 23, 12 1978 transient.
13 Do you see that?
14 A Yes, I do.
15 Q Do you.know whether any similar review
^
16 of technical specifications and limits and precautions 17 was made with respect to the March 29, 1978 event?
18 MR. GLASSMAN: By anyone?
19 MR. WISE: By anyone. -
i 20 A I do not know.
l 21 Q Did you ever find out why Met Ed had 22 prepared this report which is attachment 2 to the 23 task force report?
1
("3 24 A I don't recall ever looking into that.
25 Q We have here a Met Ed report that's
1 Broughton 136 2 nearly a hundred pages long and it is an attachment 3 to a TDR prepared by your task force that is some 4 58 pages in length and all that concerns the 5 April 23, 1978 incident, and I guess my question is:
6 Do you have any information which you could give us 7 today as to why all this work was done on the 8 April 23, 1978 transient when we haven't been able 9 to find any reports done on the March 29, 1978 10 transient?
(
11 MR. GLASSMAN: That's a rather compound 12 question. I don't know that the witness is e-(_%) 13 qualified to answer that without' getting into 14 speculation.
15 MR. WISE: I don't want him to speculate.
16 I am looking for any information h'e has, 17 either things he heard or learned or became 18 aware of through whatever means as-to why the 19 April 23, 1978 transient generated nearly 20 a one hundred page report from Met Ed and a 21 nearly 80 page report from GPU Service and at 22 least insofar as we are aware no such reports 23 were prepared for the March 29, 1978 transient.
24 MR. GLASSMAN: And your question is 25 whether he had any knowledge --
1 Broughton 137
/~T 2 MR. WISE: Or information as to why 3 that is.
4 A Well, I have no knowledge or information 5 as to why Mr. Arnold directed Mr. Keaton to perform 6 this additional analysis or what direction the plant 7 might have gotten to perform their analysis.
8 Q Continuing with page 0588, the listing 9 of technical specifications and limits and 10 precautions that were violated during he April 11 1978 transient, there is a notation that the "B&W 12 fuel pin compression cool down curve" had been
/'N s ,)
13 violated during that transient.
14 Did you read this report at or about the 15 time you were working on the task force?
16 A Yes.
17 Q Did you ever perform any work to determine 18 whether the fuel pin compression cool down curve had 19 been violated during the transient? '
20 A No.
21 Q so you are not able to confirm or deny 22 what is stated there?
23 A No, I am not.
24 Q -
Do you know what the fuel pin compression
- Ni
{~'}
25 cool down curve is?
1 Broughton 138 f'% *
- k. 2 A Yes.
3 Q What is your understanding of what that 4 is?
4 5 A It's a relationship between pressure 6 and temperature based on a fuel pin consideration, 7 Q What pressure and temperature are you 8 referring to?
9 A This would be reactor coolant system 10 pressure and reactor coolant system te perature, 11 Q Would that be average temperature or 12 would it be the temperature in one of the legs?
s i 13 A I don't know.
14 Q There is a curve available to the 15 operators with respect to fuel pin compression cool 16 down?
l l 17 MR. GLASSMAN: I am not sure what you 18 mean by "available to the operators." I don't 19 know how the witness can answer that question.
20 MR. WISE: I guess what I am asking is, 21 is the limit and precaution to your knowledge t
- 22 expressed in the form of a graph, a curve that 23 is written down someplace?
r'N 24 A I have seen a graph which has the fuel 25 pin compression cool down curve on it. I believe
1 Broughton 139
\ 2 that that graph is part of a procedure in the plant 3 procedure system.
4 Q Is it true that that graph plots 5 temperature against pressure?
6 A It is my recollection that it is pressure 7 against temperature.
8 Q What is it used for?
9 A I don't know.
10 Q What is meant by fuel pin tcompression?
11 MR. GLASSMAN: Mr. Broughton's 12 understanding?
f~%
(_)
13 MR. WISE: Yes.
14 A I don't know.
15 Q You know what a fuel pin is?
16 A Yes.
17 Q What is it? What is a fuel pin?
18 A It is a rod with fuel pellets in it 19 that is sealed and combined with others to perform 20 a fuel assembly which is part of the nuclear core.
l 21 Q Have,you ever asked anybody what is l
l
(- 22 meant by a fuel pin compression cool down curve?
l 23 A I don't recall.
I 24 Q During the time that you were Manager of b(~N 25 Licensing or Manager of Control and Safety Analysis
1 Broughton 140 did you have any understanding of what the fuel pin
'2 3 compression cool down curve was?
4 A Not that I recall.
5 Q Immediately beneath that notation the 6 following paragraph reads, "The net positive 7 suction head for the reactor coolant pumps was not 8 violated."
9 Do you see that?
10 A Yes, I do.
(
11 Q Have you ever heard the term net positive 12 suction head?
() 13 A Yes.
~
14 Q What is your understanding of the meaning 15 of that term?
16 MR. GLASSMAN: Current understanding?
17 MR. WISE: Yes.
18 Q And, Mr. Broughton, if your current 19 understanding is any different than it ever was, 20 please tell me how it is changed?
21 A My understanding of net positive suction
- 22 head is that it is a value of pressure calculated at 23 the suction of the pump which includes factors such
(~N 24 as static pressure, elevation head, fluid temperature.
\_
25 I think I have always had the same understanding of
1 Broughton 141
,r'%
2 the term.
3 Q What is your understanding of what the 4 not positive suction head is used for during the 5 operation of the reactor coolant pumps?
6 A During reactor coolant pump operation the 7 net positive suction head would be maintained above 8 a minimum value to insure proper operation of the
, 9 pumps and prevent possible damage to the pumps.
10 Q That is a minimum value fqr the pressure 11 measured at that particular point at the suction to 12 the pumps?
~
13 A The minimum value of net positive suction 14 required varies depending on several different factors.
15 But that you would keep a net positive suction head 16 within the system which was above the minimum 17 required for the system conditions.
18 Because there may be people reading this Q
(
19 transcript that are not fully familiar with all the l
(
20 terms, all I am trying to do is establish that when 21 you talk about a minimum value you are talking about
(. 22 a pressure value. That is the parameter that is 23 measured which must meet a certain minimum level; N 24 is that right?
I (~Y
\-
l 25 A In the case of the reactor coolant pumps I
l
- ++a -? - - ' '
- g. g- yy g4 wi+ y-ep 4y -.q--.i
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\ b i N s Broughton 142
., s (D
V 2 that is correct. The(otner factors are constant t ,
3 enough that they are not included in the operational I 4 limits. s
'Does the minimum level vary depending
( 5 6
Q upon tha temperature'in the primary system?
7 A '
lI don't understand what minimum level 8 refers to. \
s -s 2
9 Q Well, you said that the net positive s
10 suction head' requirements demanded tha,t pressure be 11 kept abova a certain mininum level for operation of 12 the pumps; is that right?
13 A A certain minimum pressure for a given 14 temperature.
I 15 Q 'So thtt as the temperature varied in
. . s x
the primary s/ystem thelmittimum level of the pressure .
16
,( %
17 would also vary; is that right?'
18 A The mininum valun of'tnA. pressure would 19 also vary, that's correct. -
20 Q would it be t r'u e that' higher temperatures s
21 in the primary systgm would} require higher pressures
-; e ,
k 22 in order to meet the. minimum '1'e el?
~ .
23 A In ordpr to meet the required net 3 w
, p 24 positive suction hea8 you would require a greater V \'
25 pressure for greater temperature.
s .
h
i n
1 Broughton 143 s_.) 2 Q How, if at all, does the curve for net 3 positive suction head relate to a saturation curve?
4 MR. GLASSMAN: Mr. Broughton's current 5 understanding?
6 MR. WISE: Yes.
7 A with respect to the net positive suction 8
head curve for the TMI-1 or 2 reactor coolant pumps, 9 I am not that familiar with curve to be able to
. 10 answer the question. (
, 11 g 'You are familiar with what a saturation 12 ~- cu've is?
(3 -
\v> 12 A Yes.
14s , , Q That shows pressure against temperature?
^
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i .
15'l A yesf.
16 /
'I 8
'Q Is it tdue that a net positive suction
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17 Y' he'd.
a curve is essentially a saturation curve?
1 l ,
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.);If; A' One element of' computing net' positive
. ;- ,s - - e
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.su$tian head relates t.o staturation temperature, so
- I / ,
' 20 thati'is) an input'to determining that suction head.
i ,
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,. ., i 21 There.are other inputs also. I am not familiar s
22 , 'enou h with the T -1 pump requirements to know if lc w 23 those other considerations can be ignored in favor
, 42 .<
f.
h("I 24 of simply satab ation or if' in f act they are germane
() i
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/l? 25 to ldevel'oping jthat. change.and would change the
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1 Broughton 144
. s_/ 2 temperature or pressure.
3 Q Did you ever look at the net positive 4 suction head curve for TMI-27 5 A I have looked at that curve.
6 Q Following the accident?
7 A Yes.
8 Q Did you find that it was essentially a 9 saturation curve?
10 A I don't recall ever looking at it in an t
11 attempt to make an evaluation.
12 Q Following the accident at TMI in March
() 13 1979, did you ever attempt to find out'whether the 14 operators knew what a net positive suction head 15 curve was?
16 A I don't recall looking into hhat.
( 17 Q Following the April 23, 1978 transient l
l 18 which is the subj ect of this report tnat'has been i 19 marked B&W Exhibit 186, do you know whether anybody 20 made an investigation to find out whether the 21 operators on duty during that transient understood l.
l k- 22 what a net positive suction head curve was?
i 23 A No, I do not.
rT 24 Q What role did you play in the task force
, k-)
l 25 work on the April 23, 1978 transient?
. 1 Broughton 145
/"'s
() 2 A I was primarily involved in reviewing 3 the data from the transient and in providing computer 4 simulation of the event.
5 Q For what purpose?
6 A Well, we were reviewing the data to make 7 sure that -- we were reviewing the data primarily to 8 determine what it was that had taken place. It was 9 unknown at-the time, shortly after the event, exactly 10 what had been responsible for the over cooling and 11 there were several unanswered questions that, by 12 looking at the data and by providing a simulation, 13 we hoped to be able to gain answers t o'.
[v') t 14 Q Were any of those questions related to i
15 the performance of the primary system during the
^
16 transient?
17 A With respect to the primary system, a 18 question which we looked at was what happened within 19 the primary system when the pressurizer went below 20 zero on the indicating range.
~
21 Q Why was that a question of interest?
i- k_ 22 A We were interested in finding out whether 23 the pressurizer had fully emptied, whether there were i
-s 24 voids formed inside the reactor vessel head.
's_
25 Q Why? What sparked that curiosity?
1 Broughton 146 fw t
~
1 As ,/ 2 A The fact that the pressurizer level 3 indication went off scale low.
4 Q Was there some reason why that was a 5 matter of interest?
6 A There were several questions that were 7' related to that concerning whether the core remained 8 in a subcooled condition. There were questions 9 related to the pressurizer heaters and the possible 10 effect of the transient on the heaters. I think 11 those are the questions that we started out with.
12 Q Was it ever a matter of concern,
("%,
( ,) 13 Mr. Broughton, that the pressurizer might have
~
14 emptied entirely and the bubble transferred into 15 one of the loops?
16 A I believe that that --
I dont. recall 17 if that was -- how that was addressed in the plant's 18 report. Certainly we wanted to know where the voids 19 were in the primary system, if 'there were- any , and i 20 in doing the analysis we attempted to identify where 21 those voids were.
(m 22 Q I am not sure that answered my question.
23 Let me make sure that I have got it.
24 was it or was it not of concern to you l (s. ,
l 25 in your work on the task force whether the pressurizer
1 Broughton 147 i
V 2- level had entirely emptied and the bubble transferred 3 into one of the hot legs?
4 A I don't think I would use the word 5 concern. I would say that that is one of the questions 6 that we were trying to get an answer to.
7 Q Did you ever get an answer to that?
8 A Yes, we did, 9 Q What was the answer?
10 A The answer was that the hot legs remained 11 subcooled throughout the event. That is, there was 12 no voiding in the reactor cooling system loops as a n
) 13 result of this cool down.
14 Q Isn't it also true that you concluded 15 that the pressurizer level had not entirely emptied?
16 A We performed some analysis which
! 17 indicated that the pressurizer level probably -- that 18 the pressurizer probably did not empty. 'I think the 19 strength of that conclusion is different,'however, 20 from the strength of the conclusion that there was 21 no voiding in the hot legs. And the reason is in 22 the case of hot leg voiding we had recorded data 23 from plant instruments which showed subcooling 24 existed and a code, a computer code was not necessary
!- (()3 25 to confirm that, whereas in the case of what happened
1 Broughton 148 2 to void in the pressurizer, there was no recorded 3 data once we got below zero inches and therefore there 4 was a lot less certainty in the conclusion that 5 the pressurizer did not completely empty.
6 Q The fact that the level indication showed 7 zero inches did not necessarily mean that the 8 pressurizer had entirely emptied, did it?
9 A No, it did not.
10 Q That's because the indication range is 11 less than the full size of the pressurizer?
12 A That's correct.
fm t
s )- 13 Q You say you did, however,' reach a 14 conclusion that in fact the pressurizer had not 15 entirely emptied --
16 MR. GLASSMAN: That's not wh'at he said.
17 MR. WISE: I thought that's what he 18 said. -
19 MR. GLASSMAN: I thought he said he 20 reached a conclusion that the pressurizer may 21 not have entirely emptied and made a further
- 22 statement with regard to the nature of the 23 conclusion or its reliability.
24 MR. WISE: I think the conclusion that f
L 25 it may not have is not much of a conclusion
T 1 Broughton 149 l 2 since I suppose anything is possible but 1
3 his testimony will stand.
4 Q You did conclude, Mr. Broughton, that
( 5 6
the pressurizer had in fact not emptied entirely, just to clear up Mr. Glassman's question? That 7 was your conclusion, wasn't it?
8 A We had done analysis which showed that 9 it was likely that there was water still in the 10 pressurizer. I don't believe we drew L conclusion 11 that was contrary to that analysis. I don't remember 12 how we worded the conclusion but I don't --
13 Q After you had done all you'r work and 14 whatever was involved, RETRAN analysis, investigation 15 and so on, you came up believing, did you not, that
. 16 the pressurizer had not entirely emptied?
4 17 MR. GLASSMAN: We are now looking for 18 his belief rather than conclusion?'
19 MR. WISE: I don't know if there is any l
20 difference, but you keep drawing a distinction.
21 I want to find out what this man ended up
- 22 believing after he did all his work.
23 MR. GLASSMAN: I am not sure what 24 belief is here.
(~N 25 MR. WISE: It's a predicate to some
1 Broughton 150 2 questions that are going to follow.
3 MR. GLASSMAN: You can answer it.
4 A Based on the analysis we did we thought i
5 there was still water left in the pressurizer even 6 though the level had gone below zero.
7 Q What was the basis for that thought as 8 you put it?
9 A It was the analysis of the events that 10 was done using the RETRAN model of TMI.
11 Q If you can do so, can you state briefly 12 why it was that the pressurizer did not entirely
(("%) 13 empty? ~-
14 MR. GLASSMAN: Can I have the question 15 back again?
16 (Question read by the report'er.)
17 MR. GLASSMAN: Why they concluded that?
18 MR. WISE: Yes. -
19 MR. GLASSMAN: Or that it might not 20 ' entirely have emptied, whatever his testimony 21 is?
k_ 22 MR. WISE: Right.
23 A The results of the analysis done with
<s 24 RETRAN showed that in order to match the measured 25 pressure'in the reactor coolant system it was necessary
1 Broughton 151
-~ -
\s / 2 to assume that some voiding had occurred in the 3 upper reactor vessel head and that voiding would 4 have compensated for the contraction of the reactor 5 coolant system due to the cool down. And therefore 6 it would not be necessary for the pressurizer to 7 fully empty during this transient.
4 8 In layman's terms would it be fair to Q
9 say that the generation of a bubble in the reactor 10 vessel head had the net effect of keeping pressurizer 11 level up?
12 MR. GLASSMAN: Or it might have had that
() 13 effect?
14 MR. WISE: Or it might have had that 15 effect.
16 MR. GLASSMAN: I think that this question 17 is directly -- was really the same question 18 asked before and which the witness'did answer, 19 although perhaps given some more steps in 20 between.
21 MR. WISE: That's right. I am just
+ 22 trying to sum it up and put it into laymen's 23 terms to see if that's a fair characterization, 24
('N
's A A The only part of that summary that
- 25 bothers me is saying that it keeps pressurizer level i .
1 Broughton 152
(~ '
(_)% 2 up. Because the part of the analysis that we were 3 addressing was the part when pressurizer is below 4 the indicating range of the instrument. So from 5 the standpoint of what you would see on a level 6 instrument, if you read it, you would not have seen 7 any difference because you are below zero in both 8 cases, so --
9 C Let me put it, if I can --
10 MR. GLASSMAN: Could the witness finish t.
t 11 his answer?
12 A If by level we mean, say, volume of
() 13 liquid within the pressurizer, then th'e effect of 14 a bubble in the head would be to have more volume 15 in the pressurizer.
16 MR. WISE: That's a good pla'ce to stop.
17 (Time noted: 5: 10 o' clock PM)
- 18 * * * -
19 -
T. GARY BROUGHTON 20 21 Subscribed and sworn to before me
- 22 this day of , 1982.
23
(- 24 U) 25
1 1
153 2g32IE1qA1g 3 STATE OF NEW YORK )
- ss.:
4 COUNTY OF NEW YORK )
' Qj 5
@ I, NANCY A. RUDOLPH ,a 7
Notary Public within and for the State of New York, ,
8 do hereby certify that the foregoing deposition 9 of T. GARY BROUGHTON Was taken before 10 me o February 2, 1982 ;
11 That the said witness was duly sworn 12 before the commencement of his testimony and 13 that the within transcript is a true' record of said 14 testimony; 15 That I am not connected by blood or 16 marriage with any of the parties herein nor 17 interested directly or indirectly in the matter in 18 controversy, nor am I in the employ ol' any of the 19 '
counsel.
20 IN WITNESS WHEREOF, I have hereunto set w 21 my hand this /'/ day of j, 3m m . , , 1982.
22 23 w.vi /2 0 k NANC A. RUDOLPH
, 25 i
p ,., , _ _ , , ,.y, , _ _ _ - _ _ , _1,.._,,_w_,_
February 2, 1982 154
.~
I N D EX WITNESS PAGE T. Gary Broughton 3 E XH I B I T S B&W EXHIBITS FOR IDENT, 387 Resume of T. Gary Broughton 4 ti O
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6 4
O L . .