ML20072J007
| ML20072J007 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 04/02/1982 |
| From: | Scheimann F GENERAL PUBLIC UTILITIES CORP. |
| To: | |
| References | |
| TASK-*, TASK-02, TASK-06, TASK-2, TASK-6, TASK-GB NUDOCS 8306290866 | |
| Download: ML20072J007 (37) | |
Text
_.
hd1 520 UNITED STATES DISTRICT COURT EOUTHERN DISTRICT OF NEW YORK
__x GENERAL PUBLIC UTILITIES CORPORATION,
'^
JERSEY CENTRAL POWER & LIGHT COMPANY,
}
METROPOLITAN EDISON COMPANY and
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PENNSYLVANIA ELECTRIC COMPANY,
-4 Plaint,1ffs, 80 CIV. 1683 (R.O.)
-against-THE BABCOCK & WILCOX COMPANY-and J.
RAY McDERMOTT & CO.,
INC.,
a m
Defendants.
_x s
Continued deposition of GENERAL PUBLIC A
UTILITIES CORPORATION, by FREDERICK J.
SCHEIMANN, taken by De f endantis, pursuant to adjournment, at the offices of Davis Polk & Wardwell, Esqs., One
' Chase Manhattan Plaza, New York, New York, on Friday, April 2,
1982, at 9 : 45 a.m., before Nancy A..Rudolph, a Sho rthand Repor"er and Notary Public l
of the State of New York.
N a)
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8306290866 820402 l
{DRADOCK 05000289 N
PDR I
DOYLE REPORTING. INC.
v)
T CERTIFIED STENCTYPE REPCRTERS 369 LEX 1NG7C N AvtNut' WALTER SHAPIRC, C.S.R.
Y New Yong. N.Y.
1C017
. CHARLES SHAPIRO, C.S.R.
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5
2 521 2
A_p p e arances :
3 e
4 KAYE, SCHOLER, FIERMAN, HAYS & HANDLER, ESQS.,
Attorneys for Plaintiffs, I
5 425 Park Avenue, New York, New York 6
BY:
ANDREW MacDONALD, ESQ.,
7 of Counsel 8
9 KILLIAN & GEPHART, ESQS.,
Attorneys for Frederick Scheimann, 10 216-218 Pine Street, Harrisburg, Pennsylvania 17108 11 BY:
JANE G.
PENNY, ESQ.,
12 of Counsel 13 14 DAVIS POLK & WARDWELL, ESQS.,
Attorneys for Defendants, 15 One Chase Manhattan Plaza, New York, New York 16 BY:
WILLIAM E. WURTZ, ESQ,
17 of Counsel 18 19 ALSO PRESENT:
20 JONATHAN QUINN j) 21
,(e DEBORAH JACOBS j
22 23 coo 24
("N_)
25
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522 2
F RED ERI C K J.
S C H E I MAN N, 3
resumed, having been previously sworn by a Notary
]
4 Public, and was examined and testified further as
)
5 follows:
6 EXAMINATION (CONTINUED) 7 BY MR. WURTZ:
i 8
Q Mr. Scheimann, at the close of the session 9
yesterday, we were on the subject of the PORV on the day i
10 of the accident.
You testified that you understood as 4
11 of the day of the accident that in a situation where you 4
12 had low primary system pressure, a stuck open PORV was a 13 possible cause, is that correct?
w,)
14 A
Yes, sir, that could be one of the possible i
15 causes.
16 Q
You understood on the morning of the accident 17 and you knew that the primary system pressure was, in 18 fact, low, is that correct?
19 A
Yes, sir.
20 Q
In view of those two facts, did you consider g
21 closing the block valve on the morning of the accident?
)
22 A
No, sir.
23 Q
Did you consider it during the first 30 i
24 -
minutes of the accident?
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25 A
Sir, I do not recall a time frame, but I
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1 Scheimann 523 2
do not recall considering it until I had been requested 3
to do so.
4 Q
You don't recall considering it during the 5
first hour of the accident, then?
6 A
sir, I do not recall a time frame.
7 Q
Did you consider closing the block valve at 8
any time before Mr. Mehler arrived?
9 A
No, sir.
As best I recall, I do not recall 10 considering closing the block valve prior to Mr. Mehler's
'11 appearance.
12 Q
In view of the fact that you understood it was 13 a possible cause for the low pressure you were 14 experiencing, is there a reason why you did not consider 15 closing the block valve?
16 A
Yes, sir, I had various conditions that could 17 also result in pressure remaining low.
18 Q
In other words, you thought it might be 19 caused by other things also?
20 A
Yes, sir, I recall believing that it,could 21 have been caused by other things at that time.
3
.)
22 Q
But you did not know what was causing it, is 23 that~ correct?
By "it,"
I mean the low pressure in the 24 primary system.
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25 A
Are you referring to the fact that I didn't v
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1 scheimann 524 4
2 know the exact cause of the reason why it was low, sir?
rh 3
Q That's right.
You were not able to exclude 4
4 a stuck open PORV as the cause, were you?
)
A sir, I don't have a recollection of 5
6 considering the PORV at that particular time'.
7 Q
Mr. Scheimann, before the accident, is it 8
correct that you knew that a stuck open PORV was a g
possible,cause of an increased PORV discharge pipe 10 temperature?
11 A
Yes, sir, I knew it was a possible cause.
12 However, there were several other things that could give 13 you the same indication.
14 Q
But a stuck open PORV was a possible cause, 15 is that correct?
16 A
It was a possible cause, yes.
17 Q
Did you know on the morning of the accident 18 that the PORV discharge pipe temperature was high, and 19 that the PORV discharge temperature alarm had gone off?
20 A
I don't have a recollection of the alarm 21 g ing off, sir.
22 Q
Did you know on the morning of the accident 23 that the PORV discharge pipe temperature was high?
24 _
A Yes, sir, I do recall being aware that the
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25 PORV discharge temperature was high.
However, we also N,)T g
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Scheimann 525 l
l had the two code discharge temperatures that were high 2
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3 at the same time.
i 4 i Q
Since you knew that a stuck open PORV was a
')
5 possible cause of a high PORV discharge temperature and G
since you knew on the morning of the accident that you l
7 had a high PORV discharge temperature, did you consider 8
closing the block valve?
l A
No, sir, I did not.
9 ;
I I
10 Q
Did you consider closing the block valve at 11 any point in the accident before Mr. Mehler arrived in I
12 the control room at approximate 6:15?
l l
13 A
Sir, I am not sure of what the time frame
)
14 was, but I had not considered it until Mr. Mehler had i
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l I
15 mentioned it.
16 Q
Since you understood that a stuck open PORV 17 was a possible cause of the high PORV discharge IS j
temperature you were experiencing, is the~re a reason why 19 you did not consider using the block valve?
l 20 A
At which time frame are you referring to t
21 here, sir?
Are you talking prior to or after or during?
22 Q
I am talking about during the first two j
i i
l 23 i
hours, before the time when Mr. Mehler arrived, and I l
24 I
am talking about the first 15 minutes, the firs I:
25 minutes, the first hour, the first hour and a half, the Os i
I 1
Scheimann 526 2
first two hours, at any point during that period.
3 A
And the question was?
4 Q
The question was since you understood that a 5
stuck open PORV was a possible cause of a high PORV 6
discharge temperature and since you were experiencing 7
a high PORV discharge temperature, is there a reason why 8
you did not consider closing the block valve?
9 A
There were several things that would not 10 necessarily have required me to take and close the block 11 valve or that would not lead me to take and close the 12 block valve.
13 Q.
Are you saying you excluded a stuck open PORV 14 as a possible cause of the PORV discharge pipe 15 temperature?
16 A
Sir, I don't recall really thinking that a 17 stuck open PORV at that particular time was the possible 18 cause of my situation.
19 Q
During the first two hours the possibility 20 of a stuck open PORV did not cross your mind?
21 A
Again, sir, I don't have a recollection of 22 time frames, but until Mr. Mehler came in, I don't recall i
23 a stuck open PORV coming to my mind.
l.
l 24 Q
Mr. Scheimann, before-the accident, is it
(}
25 correct that you understood that an increase in drain
1 Schoimann 527 2
tank pressure or' temperature could be caused by a stuck e
d
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3 open PORV?
In other words, that a stuck open PORV was a 4
possible cause of those drain tank conditions.
')
5 A
Yes, sir, that among other things could 6
result in that same temperature increase.
7 Q
But you understood that a stuck open PORV 8
was a possible cause of those conditions?
9 A
Yes, sir, it would be a possible cause.
10 Q
Did you know on the morning of the accident 11 that the drain tank temperature was high?
12 A
I don't have a recollection of that knowledge, 13 sir.
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14 Q
Did you know that the drain tank temperature 15 alarm went off at approximately two minutes into the 16 accident?
17 A
No, sir, I don't recall having known that.
18 Q
Did you know on the morning of the accident 19 that at approximately four minutes into the accident a 20 second drain tank temperature alarm went off?
21 A
No, sir, I don't recall having known that.
22 Q
Did you know that for the first 15 minutes 23 of the accident the drain tank pressure was increasing?
24 A
Sir, I don't have a recollection of knowing
(~N, 25 at what particular point in time the temperature of the N_s'
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1 Scheimann 528 2
drain tank was increasing or that the drain tank pressure
()
l 3
was increasing.
4 Q
Did you know on the morning of the accident
)
5 that the rupture disk on the drain tank burst at 6
approximately 15 minutes into the accident?
7 A
I don't recollect having a feeling of the 8
time, but I had heard sometime during the day that it 9
was suspected that the rupture disk had burst.
10 Q
Did you become aware in the first hour of 11 the accident that it was suspected that the rupture 12 disk had burst?
13 A
Sir, I don't have a recollection of when I
()
14 became aware of that.
15 Q
Did you know that the drain tank temperature 16 stayed high during the first two hours of the accident?
17 A
I don't have a recollection of the time or 18 the fact that the temperature stayed high.
19 Q
Did you at any point go to Panel 8-A and look 20 at the meters or alarms for the drain tank?
21 A
No, sir, I don't recall going to Panel 8-A.
22 Q
Did you instruct either Mr. Frederick or Mr.
23 Faust to go back there to look at the panel and see what 24 the drain tank conditions were?
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25 A
I don't recall whether I did or did not, sir.
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1 I
1 Scheimann 529 2
Q Do you know that, in fact, Mr. Frederick 3
did go back there and look at Panel 8-A?
4 A
Sir, I don't have a recollection of the fact
)
5 that he did go back.
6 Q
Were you ever told by Mr. Zewe, Mr. Frederick 7
or Mr. Faust that the drain tank temperature stayed high 8
and, at some point, the drain tank pressure and level 9
went to zero?
10 MR. MacDONALD:
Are you talking about on the 11 day of the accident?
12 MR. WURTZ:
Yes, I am talking about the first 13 two hours of the accident before Mr. Mehler got
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(_T) 14 there.
15 MR. MacDONALD:
O.K.,
that is where your 16 question is geared towards.
O.K.
17 A
I don't have a recollection of having heard 18 that, sir.
19 Q
Now, on the morning of the accident, you 20 understood that,as you testified, high drain tank 21 temperature or pressure was a symptom of a stuck open 22 PORV, is that correct?
23 A
Yes, sir, that would be one of the symptoms.
24 Q
In fact, it was so identified in the Unit 2
(
25 pressurizer system failure procedure?
l i
1 Scheimann 530 2
A Yes, sir.
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3 Q
You knew you had low primary system pressure 4
and you knew that you had high PORV discharge temperature l
)
5 and that a stuck open PORV was a possible explanation for 6
either one of those symptoms.
So my question is:
Did 7
this cause you to make any inquiries regarding the t
8 conditions in the drain tank during the time period i
9 before Mr. Mehler arrived?
1 j
10 A
Sir, in answer to your question, first, I 11 was aware of a low pressure.
I believe I testified that 1
12 I don't recall when I became aware of the high tail pipe 13 temperature in excess of the limit; you know, the alarm 14 point.
I did not take and send somebody to take a look 15 at Panel 8-A.
16 Q
Did you ask anybody about the drain tank i
17 conditions during the time period before Mr. Mehler 18 arrived?
19 A
I don't have a specific recollection of it, 20 sir.
21 Q
Before the time Mr. Mehler arrived, did you have 22 any information at all, you personally, about the 23 conditions in the drain tank?
24 A
I don't have a recollection, sir.
25 Q
You don't recall havin'g any information about
1 scheimann 531 2
the drain tank before the time Mr. Mehler arrived?
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3 A
I don't recall whether I did or I didn't, sir, i
4 Q
Before the accident, did you understand that
')
5 if the drain tank rupture disk burst, the drain tank 6
pressure would drop to ambient levels?
7 A
I don't have a recollection of that, sir.
8 Q
You mean you don't recall specifically 9
considering that?
10 A
I don't have a recollection of it.
11 Q
Now, I am not asking you whether you 12 specifically considered that question.
What I am asking 13 is whether you understood that principle before the 14 accident?
15 A
I don't have a recollection whether I did or 16 I didn't.
17 Q
Well, what I am asking is:
Does it sound 18 like a surprising result to you, a rupture disk burst, I
19 that pressure would drop to ambient levels?
l 20 MR. MacDONALD:
Just a second now.
If you 21 are asking for his present impression, we are 22 not going to deal with that.
If you are asking for 23 his recollection prior to the accident, fine.
I 24 don't mind you asking if he has got a recollection 25 of it or whether he understood it or was aware of i
s-l l
1 scheimann 532 2
it.
It sounded like your question may be geared
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towards what he may be thinking today.
3 4
MR. WURTZ:
I am trying to make clear what
)
5 my question is.
It is not. do you recall a specific 6
time when you considered this specific question.
7 My question is, rather, did you understand the 8
principle that when you have a tank and you increasc 9
the pressure in it and then you pop a hole in it, 10 that the pressure in that tank will go to ambient 11 levels.
12 Do you know what I mean by the word " ambient"?
13 I mean it will go to the level of the surrounding bd 14 reactor building.
15 A
Yes, I know what you are referring to 16 there, but I don't have a recollection as to whether or 17 not I did have that understanding at that particular i
18 time.
19 Q
Did you understand before the accident that 20 in a situation where the drain tank temperature went high 21 and stayed high that that was an indication of a 22 continuing venting to the drain tank?
23 A
Sir, I don't have a recollection of that
+
24 particular understanding.
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25 Q
You don't know whether you understood that J
l
1 Scheimann 533 2
fact or that principle before the accident?
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3 A
I don't have a recollection of whether I 4
did or I did not.
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5 Q
You understood that there was a cooling 6
system for the drain tank, is that correct?
7 A
Yes, sir, I understood there was a cooling 8
system.
9 Q
And that cooling system worked by what means, 10 could you describe that?
11 A
I don't at present have a recollection of 12 how it did work.
13 Q
Was the water in the drain tank circulated (n,,)
14 out through a heat exchanger?
15 A
Sir, I don't have a recollection of how it 16 worked.
17 Q
Did you know that the purpose of it was to 18 keep the drain tank temperature low?
19 MR. MacDONALD:
The purpose of what now?
20 MR. WURTZ:
The drain tank cooling system.
21 A
Sir, I don't have a recollection of the 22 purpose of the cooling system.
23 Q
Did you understand that the effect of the 24 drain tank cooling system was to lower the temperature of
/~T 25 the drain tank water in a circumstance where that water b
1 Scheimann 534 2
temperature got increased?
Cs 3
A Sir, I don't recall at present whether I 4
knew that was what the effect was or not.
')
5 Q
Well, what did you understand a drain tank 6
cooling system was to d o ?'
7 A
Sir, I don't have a recollection at present.
8 Q
Did you read the FSAR section concerning the 9
drain tank in the course of your training and in the 10 course of preparing for your CRO and SRO examinations?
11 A
Sir, at various times I have read parts of 12 the FSAR.
I can't recall if I had read that particular 13 section or not.
14 Q
But it is your testimony today that you don't i
15 re, call whether you understood before the accident that 16 the purpose and the effect of the drain tank cooling 17 system was to cool the drain tank water?
18 THE WITNESS:
Could I have that one more 19 times please?
20 (Question read) i 21 A
Yes, sir, that's what I said.
I don't recall 22 whether I had that understanding or not.
23 Q
Mr. Scheimann, I would like you to look at l
l 24 page 2 of Exhibit 305, which is the pressurizer system
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25 failure procedure for Unit 2.
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1 Scheimann 535 2
Do you see that this procedure on page 2 3
lists two symptoms of a stuck open PORV?
One is in 4
paragraph 3 and one is in paragraph 4.
The one in 5
paragraph 3 is a PORV discharge line temperature above
]
6 the 200-degree alarm point, and the one in paragraph 4 7
is drain tank temperature and pressure above normal.
8 MR. MacDONALD:
The question is:
Does he 9
see those two paragraphs?
10 Q
Yes, do you see that procedure provides two 11 symptoms for diagnosing a stuck open PORV7 I
12 MR. MacDONALD:
Are you asking for his 13 recollection now?
j
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14 Q
Yes, was that your understanding?
Let me 15 ask it again.
16 Do you understand here on page 2 that this 17 pressurizer system failure procedure gives the operator 18 two symptoms for diagnosing a stuck open PORV?
19 A
No, sir, actually I see three symptoms 20 there for a possible stuck open PORV.
l l
21
-MR.
MacDONALD:
He didn't ask you what you 22 see, Mr. Scheimann; he asked you for your 23 understanding prior to the accident.
24 Q
Well, what is the third symptom you see?
(
25 A
Sir, the third one I see is that RC system
1 Scheimann 536 i
2 pressure is below 2205 and RC-R2 fails to close.
4 3
Q Now, on the morning of the accident, you 4
knew that the reactor coolant system pressure was below 5
2205, is that correct?
6 A
Yes, sir.
7 Q
You knew that the PORV discharge line 8
temperature was above 200 degrees Fahrenheit?
9 A
Yes, sir, at some time.
10 Q
Well, did you know that PORV discharge pipe 11 temperature alarm occurred at one minute into the 12 accident?
4 13 A
I don't have a recollection of the alarm
.s 14 its e lf coming in, no, sir.
15 Q
You never looked back at the vertical panel 16 on the computer to see the alarm, to see that the alarm 17 was in?
At any time'before Mr. Mehler arrived, let's 18 leave it at a broad time period.
The record shows that 19 he arrived at approximately 6:15.
20 A
No, sir, I did not.
21 Q
But you did know the temperature was above 22 200?
23 A
At some point in the morning, I had heard 24 that.
[ ))
25 Q
How did you learn it?
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1 Scheimann 537 2
A I have a recollection of somebody saying g-(/
3 something about the temperature being above 200.
4 Q
Who?
i 5
A I don't have a recollection of who it was, I
6 sir.
7 Q
was it said to you?
8 A
I don't have a recollection of whether it 9
was directed to me.
10 Q
What do you recall was said?
11 A
As best I can recall, I can recall hearing 12 that the temperature was up above 200.
I don't recall 13 a specific number.
14 Q
What did you do when you heard that?
15 A
Are you referring to based on hearing that?
3 16 Q
Yes.
17 A
I don't have a recollection of doing anything 18 based on hearing,that particular piece of information.
19 Q
Did you ask for more information?
20 A
.I don't have a recollection of doing so.
21 Q
Did you hear this in the first five minutes 22 into the accident?
23 A
Sir, I don't have a recollection of when I i
24 heard it.
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25 Q
Did you hear it before the time you turned
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1 Scheinann 538 2
off the first two reacter coolant pumps?
g3U 3
A Sir, I don't have a recollection of when 4
in the day-I heard that particular piece of information.
5 Q
Do you know that you heard it before the 6
time that Mr. Mehler arrived?
7 A
Sir, I don't have a recollection of when I 8
heard it.
4 9
Q Were you aware that the PORV discharge line 10 temperature was requested by one of the operators on 11 the utility printer?
12 A
I don't have a recollection of having known 13 that.
I 14 Q
How many times did you hear that the PORV 15 discharge line temperature was over 2,00 degrees?
i 16 A
I don't have a recollection of how many 17 times I might have heard it.
18 Q
Was it more than one time?
19 A
I don't have a recollection, sir. I would 20 like to take about a couple of minutes break.
t 21 (Recess taken) 22 BY MR. WURTZ:
l 23 Q
Mr. Scheimann, before the break, you
(
24 testified that you did not recall how many times you
()
25 heard that the PORV discharge pipe temperature was over j
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1 Scheimann 539 2
200 degrees, a
3 Did you hear during the accident that, in 4
fact, it was 285 degrees?
5 A
Sir, I don't recall that I heard a specific 6
temperature.
7 Q
Did you know that on the morning of the 8
accident you had a number of means available for trending 9
the PORV discharge pipe temperature?
10 A
Yes, sir.
I 11 Q
Did you know that you could use the digital 12 readout on the computer to have the PORV temperature 13 displayqd at all times?
s./
14 A
Yes, sir.
15 Q
Did you know that you could trend a PORV 16 discharge pipe temperature on the CRT screen on the 17 computer?
18 A
Yes, sir.
It would have to be put into a 19 group, but it could be done.
20 Q
Did you know that you could also trund it 21 as a signal point on the CRT screen?
22 A
Yes, sir, if it was assigned to a group and 23-no other points were put on that group.
24 Q
Did you understand that you could trend the r
l ()
25 PORV. outlet temperature on any one of the four analog i
x l
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1 Scheimann 540 2
trend recorders or strip charts that you had available 3
on the computer?
4 A
Yes, sir.
)
5 Q
You understand that you could trend the PORV i
6 outlet temperature on the utility printer?
7 A
Yes, sir.
8 Q
When you learned that the PORV discharge 9
pipe temperature was over 200 degrees, did you consider 10 putting'the PORV temperature on any one of these i
11 trending devices available to you?
~
12 A
No, sir, I don't recall having considered 13
- that,
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14 Q
Though you knew the' discharge pipe temperature 1
15 over 200 degrees was a symptom of a possible stuck open 16 PORV, you did not consider using any of these trending 17 devices to get more information on the discharge pipe 18 temperature?
19 A
No, sir.
20 Q
You did not ask any more questions of the 21 person who gave you this information about the PORV 22 discharge temperature?
I l
23 A
No, sir, I don't recall having done so.
24 Q
Now, looking again at page 6 of the l
("N 25 pressurizer system failure procedure, did you understand
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3 1
Scheimann 541 2
before the accident that in a situation where you had
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3 primary pressure below 2205, where you had a discharge 4
line temperature above 200 degrees and where you had
)
5 drain tank pressure and temperature above normal, that 6
this procedure required that you close the block valve?
7 A
No, sir, I was not under that understanding.
8 Q
What did you understand this procedure told 9
you to do in the event you had those symptoms which 10 included all of the symptoms listed on the procedure as 11 stuck open PORV symptoms?
4 12 A
My understanding was that if I had those 13 symptoms and I could verify that they were not being (N) 14 caused by some other problem and I could verify that it
/
15 was a stuck open pilot operated relief valve, then I 16 would perform my manual actions.
17 Q
You mean then you would close the block 18 valve?
19 A
Yes, sir.
20 MR. WURTZ:
Would you read the answer before I
21 this one back, please?
22 (Answer read) 23 Q
So the way you understood this procedure 24 before the accident, even in a case where you had all f^g 25 of the symptoms identified in the procedure as being U
1 Schsimenn 542 2
indications of a stuck open PORV, you would still not
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3 at that point close the block valve, is that correct?
4 A
No, sir, I would not close the block valve
)
5 at that point if I did have a reason to believe those 6
symptoms came from some other cause.
7 Q
So before closing the block valve, you would 8
go and check every other possibility, is that correct?
4 9
A No, sir, I would not necessarily have 10 checked every possibility.
If I would have found the 11 cause before I got through all the possibilities, then 12 I wouldn't have prcceeded any further.
13 Q
But instead of closing the block valve, you O)
(
14 would go and check first to see if there was some other 15 cause other than a stuck open PORV, is that correct?
16 A
Yes, sir, I would have.
17 Q
As you understood this procedure only in a 18 case where you could not prove that it was something 19 else, would you decide it was the PORV and close the 20 block valve, is that right?
21 THE WITNESS:
Could you say that again for 22 me, sir?
23 Q
Yes, I am trying to get clear what you 24 understood this procedure required you to do as an
(~}
25 operator, and, as I understand it, you have testified V
i i
1 Scheimann 543 2
that even in a situation where all of the symptoms in O
3 a procedure for a stuck open PORV were present, you 4
would not at that point automatically close the block
)
5 valve, is that correct?
6 A
Yes, sir, there are several causes that I 7
could attribute to several of the symptoms.
8 Q
So before closing the block valve, you 9
would go and check the other possible causes of the 10 symptoms, is that correct?
11 A
Yes, sir.
12 Q
At what point would you close the block 13 valvd?
14 A
At the point I was convinced that it wasn't 15 due to some other problem.
16 Q
Did you understand that a stuck open PORV 17 was a form of losc of coolant or involved a loss of 18 coolant?
19 A
Yes, sir.
20 Q
Did you understand before the accident that 21 a loss of coolant accident was the most serious i
22 accident you could have in a nuclear reactor?
23 A
Sir, I don't recall whether I had an l
24 understanding of that or not.
(N 25 g
Did you understand that if a loss of l
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1 Scheimann 544 2
coolant was not treated that the loss of coolant could
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3 eventually lead to core damage?
4 MR. MacDONALD:
Are you asking him for any
)
5 loss of coolant accident?
6 MR. WURTZ:
Yes.
7 A
No, sir, I don't recall having that i
8 understanding.
9 Q
What did you understand the consequences of 10 an untreated loss of coolant to be?
11 A
Sir, it would depend on the severity of the 12 accident as to whether it would be a possibility of 13 core damage.
In the event where the makeup system could
(
14 handle the leak, you would not even see symptoms 15 necessarily.
16 Q
In a situation where the leak was big 17 enough so the makeup system could not handle it and 18 where no water was being added through HPI, did you 19 understand that the loss of coolant would eventually 20 lead to core damage, core uncovery and core overheating?-
21 A
I understood that that was theoretically 22 possible.
23 Q
Did you understand that in the situation 24 where you were investigating to see if some other
~
25 cause was producing the symptoms identified in the
I Scheimann 545 2
pressurizer system failure procedure that there could
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3 be a loss of coolant going on out through the PORV?
4 A
No, sir, I do not recall having that
)
5 understanding because the normal cycle of the valve 6
would reflect the same symptoms.
7 Q
Would they stay there?
8 A
Some of them would stay there for a period 9
of time.
10 g
Well, we will get to that question, but 11 what I want to focus on now is a situai.on where you 12 know a stuck open PORV was a possible cause of the 13 symptoms.
,)
14 During the time you were investigating 15 other possible causes, did you understand that there 16 could be a loss of coolant through the stuck open PORV?
17 THE WITNESS:
Could I have that again, 18 please?
19 (Question read) 20 A
No, sir, I did not have that understanding 21 because if I had other indications that would possibly 22 tell me it was another cause, I would not at that 23 particular time think that I had a stuck open PORV until 24 I could verify it by it not being one of the other r^x, 25 situations.
N,1
1 Scheimann
- 546,
/
2 Q
Well, I understand that and the s,ituation
/
3 I am describing to you is a situation where you 4
understand that a stuck open PORV is a possibility, and
)
5 the reason you think it is a possibility is that all of 6
the symptoms identified in the pressurizer, system 7
failure procedure are present, and what I am asking is:
8 Did yo~u understand that during the time w' hon you were b
9 investigating all the other possible.
causes that since,"'
10 a ctuck open PORV was a possibility, you could be l o s i,n'g,
/
11 coolant during the time thh,t yeu were conducting this '
12 investigation?
13 MR. MacDONALD:
Are you talking about prior 14 to the accident now, right?
4 1 15 MR. WURTZ:
Yes.
-x 16 A
No, sir, I would not have had that 17 understanding based o'n the day of the accident.
I did 18 not consider the PORV until a later point in time.
19 2
You mean when Mr. Mehler came in?
20 A
Yes, sir, as best I. recall.
21 Q
Well, I am not now talking about the day of 22 the accident; I am talking about your understanding f
/
23 before the accident of how you were to apply this.
24 procedure, pressurizer system failure procedure.
25 Now, in a situation,where yo,know that a m
I
~
1 Schsimann 547 2
stuck open PORV is a possibility and you know that
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3 certain other causes are a possibility, your testimony 4
is that you would not automatically close the block i
')
5 valve.
Instead, you would investigate the other i
6 possible causes until you could convince yourself that 7
the symptoms were not due to one of these other causes.
8' And my question is:
Did you undestand that during the 9
time you were doing this investigation, there was a 10 risk of a loss of coolant going on during that time, 11 possibly through the stuck open PORV?
12-A No, sir, I do not recall having that 13 understanding.
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14 Q
Well, you knew that in a situation where w
15 the symptoms in the pressurizer failure system procedure 16 were present that a stuck open PORV was a possibility, 17 is that correct?
18 A
Yes, sir.
19 Q
You knew that a stuck open PORV was the 20 LOCA?
l 21 A
Yes, sir.
l 22 Q
You knew that until you closed the block i
23 valve that LOCA would continue?
24 A
Yes, sir.
fg -
25 Q
Well, doesn't it follow then, as a matter 1
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Scheimann 548 x
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2 l of logic, that you knew that during the time you were m
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3 investigating the other causes, you knew that there was s 4
a possible LOCA going on.through the stuck open PORVN
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5 MR. M cDONALD:
I object to the form as a 6'
matter of logic
.He is n'ot here to testify what i
3 o
- 7 is logical or what makes it appear logical to s
8 him today, but what his recollection isy and if
'n 9
you are asking him based on those three things, 10 does_he recall prior to the ac e'idEn t, and then 11 your guestion, fine.
I don't want to get caught s
12 up on what he may think today as logic'al as i
s
._ - 13 opposed to what he recalled about these particular s,.
14 c'i rc um s tanc e s prior to the accident.
15 MR. WURTZ:
Well, I am assuming that his s
16 understanding before the accident has some 17 relationship to logic, and I think it is a correct 18 question.
I will take that word out of there if i
.a 19 l} _ _ q that will help things.
1~
20 Could you read back the questicn?
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21 (Question read) 3
)
s 22 gBY MR. WURTZ:
23 Y
Q I am going to modify _the question.
A s
's g.
7) s 24 Isn't it a fact that youTunderstood during 4
7, i g
s e 25 ghe time you were investigating tn: otherspossible t
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1 Scheimann 549 2
causes, that it was possible that there was a LOCA
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3 going on through the possible stuck open PORV?
4 A
Yes, sir, it would be possible.
- However,
)
5 the time involved was taking and making the determination 6
that it might be due to another cause.
It would not 7
necessarily be an extended period of time.
You might 8
know right away, looking at the panel, yes, I have got 9
this situation existing.
10 Q
Did you understand that you had a time 11 limit on how much time you were to spend investigating 12 before you closed the block valve?
13 A
No, sir, I don't recall a time limit based
(
14 on how long I could investigate before I had to close
,b 15 the block.
i 16 Q
Did you have a limit that you understood?
17 I see there is not one written in the procedure.
18 Did you have one that you used as a guideline?
19 A
Are you referring to a time limit again?
20 Q
Yes, for investigating before you closed 21 the block valve, in a case where symptoms of a stuck open 22 PORV are present.
23 A
I don't have a recollection of a particular 24 time limit.
i g
Did you understand that in some circumstances I s
25
1 Scheimann 550 2
it could take you a longer period of time to verify that
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3 it was not some other cause?
4 THE WITNESS:
Could I have that again?
)
5 (Question read) 6 A
Sir, when you are referring to "a longer 7
period of time," just what in particular are you 8
referring that to?
9 Q
Well, how long did you understand it would 10 -
take to investigate the other possible causes of the 11 symptoms?
You testified earlier that it wouldn't take i
12 that long.
i 13 A
I don't have a recollection of the specific
[)
14 timing it would take to find those other causes.
%J 15 Q
Well, I am trying to get some idea of what 16 period of time you were referring to there.
II MR. MacDONALD:
Are you asking him by his 18 answer whether there was one set period of time 19 that he was referring to in his answer?
20 MR. WURTZ:
Well, I don't expect it was a i
21 set period of time to the second; I expect some 22 time range, and I would like to know what time 23 range you had in mind when you earlier stated that 24 it wouldn't take that long to investigate the 25 7s other possible causes.
R >g l
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1 Schoimann 551 4
2 A
Sir, I don't recall that there would be a 3
set time range.
4 Q
Well, what time. period did you have in
)
5 mind when you gave your earlier answer?
6 A
Sir, I didn't have a specific time frame in 7
mind.
8 Q
Ne don't seem to be communicating here.
9 When you use the word " specific, I don't 10 know what meaning you attach to that.
I am trying to 11 get some feel for what time period you had in mind.
12 Can you tell me that?
Are you talking a l
13 few minutes, a few hours, a few days?
(
14 A
Sir, I can't recall whether it would be in 15 terms of any of those that you mentioned to me.
16 g
Well, when you answered earlier that it 17 wouldn't take that long to investigate it, I assumed 18 you were not talking about hours or days.
Was I 19 incorrect, you could have been refersing to a period of 20 time that long?
21 A
Sir, I don't have a recollection of what 3
22 the time frame would have been.
We might have seen it 23 as we were seeing the symptoms come in.
It might have 24 been at some period of time after that.
25 Q
How long did you understand it would take
(~S Qi!
1 Scheimenn 552 2
to investigate the other possible causes of the symptoms?
3 A
Sir, I don't recall what I understood at 4
that particular time for the length of time it would
)
5 take to explore the other possible causes.
6 Q
Did you understand that it could take more 7
than five minutes?
8 A
Sir, I don't recall whether it would have 9
taken more than five minutes or a specific time.
10 Q
Well, isn't it correct that you might have 11 been able to investigate the other causes immediately 12 within the first minute on one hand; but, on the other 13
. hand, it might have taken 30 minutes or an hour?
O)
I4
(,
MR. MacDONALD:
Are you asking him now for 15 his recollection, not to speculate?
16 Q
Yes, what was your understanding?
Didn't 17 you understand that it could take anywhere from 30 10 seconds to an hour or more to investigate the other 19 possible cause of symptoms in the case where a stuck 20 open PORV was one possible cause?
21 A
Sir, I do not recall understanding that 22 there was a time frame such as five seconds to 30 23 minutes in which it would take us to find the other t
24 symptoms.
25 f~)
Q Based on the fact that you had a senior v
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1 Scheimann 553 2
reactor operator's license and you have been in training
+
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3 and operating units 1 and 2 at Three Mile Island for six 4
years as of the day of the accident, and you had no
')
5 understanding that it could take anywhere from 30 6
ceconds to an hour to several hours to investigate the 7
other possible causes?
8 THE WITNESS:
Could I have that again?
9 (Question read) 10 MR. MacDONALD:
I object to the form of the 11 question.
12 A
Sir, I don't believe I understand what you 13 are asking me there.
f]
14 Q
well, all I am asking is whether you w
15 understood before the accident that investigating the i
16 other possible causes of the symptoms could take little 17 or no time on one hand or could take a lot of time on 18 the other hand, and I had suggested a little time as 19 being a minute or two and a lot of time as being maybe 20 longer than an hour.
21 A
Sir, I don't have a recollection of what
- )
22 my understanding had been about the time frame involved.
I 23 Q
Before the accident, did you understand that 24 in a case where your investigation of the other possible
(~
25 causes took longer than five minutes, you should N ]J
l' scheimann 554 2
automatically close the block valve?
3 A
sir, I do not recall having an understanding 4
that dealt with the length of time, a specific length of
-)-
5 time such as five minutes, to take and determine whether 6
I had to close the block or not.
7 Q
Did you understand that if your investigation 8
of other causes took longer than 15 minutes, you should 9
close the block valve?
10 A
Sir,- I do not recall having an understanding 11 that if the investigation required more than 15 minutes,.
12 I would be required to close the block valve.
13 Q
Did you understand that if the investigation
'()_
14 took longer than an hour, you were required to close the 15 block valve?
16 A
Sir, I do not have a recollection of having 17 an understanding that if my investigation were to take 18 an hour or any specific time, I was told to close the 19 block valve.
20 Q
You had no such understanding even though 21
-you knew that there was a possible LOCA going on for-22 that hour and continuing?
23
-A Sir, I do not recollect having that 24 understanding.
l 25 Q
Did youLunderstand you were required to I
p
i.
1 Scheimann 555 2
close the block valve when you knew a stuck open PORV 3
was a possible cause of the symptoms and when you did 4
not know what the cause, in fact, was of those symptoms?
)
5 THE WITNESS:
Let me have that again.
6 (Question read) 7 A
Sir, I don't recollect having had or not had 8
that particular understanding.
9 MR. MacDONALD:
Off the record.
10 (Discussion off the record.)
11 (Luncheon recess:
12:00 p.m.)
12 (Time noted:
1:45 p.m.)
13 O
14 FREDERICK J.
SCHEIMANN 15 16 Subscribed and sworn to 17 before me this day 10 of 1982.
19 20
)
22 23 24
)
1 556i I
I CERTIFICATE 2 ;;
i:
STATE OF NEW YORK
)
y
- ss.:
COUNTY OF NEW YORK
)
I, NANCY A.
RUDOLPH
, a Notary l
_)
5 1
Public of the State.of New York, do hereby certify that the continued deposition of FREDERICK J.
SCHEIMANN was taken before S
me on Friday, April 2,
1982 consisting 9
of pages 520 through 555 I further certify that the witness had been previously sworn and that the within i
i transcript is a true record of said testimony; 13 That I am not connected by blood or marriage with any of the said parties nor la, l
interested directly or indirectly in the matter 1G in controversy, nor am I in the employ of any of the counsel.
18 IN WITNESS WHEREOF, I have hereunto set my hand this day of d<~ b
,1982.
20
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W e,
23 l
$) '
e N NCY A.
RUDOLPH 2ch I
i 25 I
i k l
l l
l i
L.