ML20072J013
| ML20072J013 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 04/27/1982 |
| From: | Scheimann F GENERAL PUBLIC UTILITIES CORP. |
| To: | |
| References | |
| TASK-*, TASK-01, TASK-02, TASK-06, TASK-1, TASK-2, TASK-6, TASK-GB NUDOCS 8306290870 | |
| Download: ML20072J013 (167) | |
Text
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557 UNITED STATES DISTRICT COURT
,,-m k
SOUTHERN DISTRICT OF NEW YORK
_____._________________________________x
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GENERAL PUBLIC UTILITIES CORPORATION JERSEY CENTRAL POWER & LIGHT COMPANY, cb METROPOLITAN EDISON COMPANY and PENNSYLVANIA ELECTRIC COMPANY, Plaintiffs,
=
-against-80 CIV. 1683 (R.O.)
THE BABCOCK & WILCOX COMPANY and J.
RAY McDERMOTT &
CO.,
INC.,
Defendants.
______.-__________ _ _____ __.,_____ _ x Continued deposition of Plaintiff GENERAL PUBLIC UTILITIES CORPORATION, by FREDERICK J. SCHEIMANN, taken by Defendants pursuant to adjournment, at the offices of Davis Polk & Wardwell, Esgs., One Chase Manhattan Plaza, New York, New York, on.
Tuesday, April'27, 1982, at 9:55 o' clock in the forenoon, before Nancy A.
- Rudolph, a Notary Public within and for the State of New York.
4 DOYLE REPORTING, INC.
CERTIFIED STENoTYPE REPORTERS p
5 369 LEXINGTON AVENUE WALTER SHAPIRO, C.S.R.
NEw YomK. N.Y.
1o017 CHARLES SHAPIRO, C.S.R.
TELEPHONE 212 - 867-8220 8306290870 820427 PDR ADOCK 05000289 T
PDR l
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1 558 2
Appe aran ce s:
3 KAYE, SCHOLER, FIERMAN, HAYS & HANDLER, ESQS.
Attorneys for Plaintiffs 4
425 Park Avenue New York, New York
')
5 By:
ANDREW MacDONALD, ESQ.,
G of Counsel 7
8 DAVIS POLK & WARDWELL, ESQS.
O Attorneys for Defendants One Chase Manhattan Plaza 10 New York, New York 11 By:
WILLIAM L.
WULTZ, ESQ.,
of Counsel k
12 i
13 KILLIAN & GEPHART, ESQS.
14 Attorneys for Federick J.
Ocheimann 4
Box 886 15 Harrisburg, Pennsylvania 17108 16 By:
JANE G.
PENNY, ESQ.,
of Counsel 17 18 19 Also Present:
20 JONATHAN QUINN
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23 24 I
25 l
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1 559 2
FRE DE RI CK J.
S CH E I MA N N, 4
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3 having been previously duly sworn, was examined 4
and testified further as follows:
)
5 EXAMINATION (continued) 6 BY MR. WURTZ:
7 Q
Mr. Scheimann, I would like to continue 8
where we left off several weeks ago.
9 Before the accident, did you understand 10 that in a situation where you had low reactor coolant 11 system pressure, high outlet temperature on the POa7 i.
l' 12 discharge line and high temperature in the drain tank, 13 that a stuck open PORV was a possible cause of those 14 symptome?
15 A
Yes, I understand that it would be i
16 theoretically possible to be one of the causes.
17 However, if I had other conditions at the time that 4
l 18 would indicate that it was caused by some other problem 19 or a normal situation, I wouldn't necessarily think 20 that it was a stuck-open PORV as long as I had 21 indication that the light was out.
22 Q
Did you know that even when the light was 23 out if those symptoms were present, a stuck-open PORV 24 was a possibility?
25 A-Sir, I did not necessarily have that i
I l
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Scheimann 560 2
understanding.
If I knew that some other situation O
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was causing those parameters with that light being 3
4 out, I would not assume that that valve was stuck
)
5 open.
I f,I had some other valid reason for why I had 6
those conditions, I would not think that the PORV was 7
stuck.
8 Q
Let's take the situation before you have 9
concluded or before you know with certainty what is 10 causing those symptoms.
Did you understand that even with the 11 ;
12 l
light off, a stuck-open PORV was a possible cause of 13 those symptoms?
s 14 A
Yes, sir, I understood that it could be a v
15 possible cause of those symptcus.
However, as I 16 men ti one d, chances were I might have seen some other 17 thing that had occurred within a short period of time, 18 namely, simultaneously with the start of the increase
'19 of the temperatures, and if I could state that, yes, 20 I knew I had a cycling of the PORV, then I would not 4
21 even think to consider that the PORV was stuck because
)
22 that would account for all those symptoms.
23 Q
Well, we will get to the other possible 1
24 causes in.a minute.
I would just like to go 25 systematically here so that I understand what your o
I
l 1
Scheimann 561 2
position is on these points, and I read the record
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3 on this questfon of the light, and I want to make sure 4
it is clear how you stand because there was some
)
5 question in my mind after reading the prior transcript.
6 Is it correct that you understood that even 7
when the light was off, it was possible to have a 8
stuck-open PORV, that the light was not a conclusive 9
indicator?
10 MR. MacDONALD:
What you are dealing with 11 is his understanding prior to the accident, 1
12 l
whether he understood prior to the accident?
13 MR. WURTZ:
'le s.
)
14 A
What I understood prl.or to the accident a
t 15 pcrtaining to that lignt is that it was my primary 4
16 indication and if that light was out, I had no reason 17 to believe I had a stuck-open PORV.
18 Q
Did low pressure, high outlet temperatures 19 and high drain tank temperature give you a reason to l
20 believe that a stuck-open PORV was possible?
21 A
No, sir, not if I could attribute it to 22 some other condition.
23 Q
And if you could not attribute it to some 24 other condition?
I 25 MR. MacDONALD:
Are you asking him whether
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Schnimann 562 2
he ever encountered that situation?
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3 MR. WURTZ:
I am asking for his 4
understanding.
')
5 A
Sir, I don't think I ever considered the 6
possibility of that being stuck open.
Most of the time 7
I would have the_ conditions right away that would tell 8
me, yes, it was caused by something else.
9 Q
I am asking about your understanding 10 before the accident, and the question is, did you 11 understand that with the light off and these other 12 symptoms present, that until you could determine what 13 was causing these symptoms ar.d concluded that it was 11 not the PORV, that the PORV was a possible cause of a j
15 stuck-open POK77 16 A
fir, with that light out, I would be 17 able to tell right away generally if I did have another 18 problem and generally it would be due to the result 19 of a cycling of the valve that had caused _those 20 temperatures.
21 Q
But until you could decide what was 22 causing it, you had to understand that a stuck-open 23 PORV was possible; is that correct?
24 A
Sir, I would have seen the other things
_g 3
25 Prior -- no, I would say no, because I would have
1 Schaimann 563 2
seen the othe: conditions prior to the point where l')
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3 I would have even thought about it being a stuck-open 1
4 PORV.
')
5 Q
Did you understand that if you could not 1
6 immediately determine that it was something other than 7
a stuck-open PORV that in that situation a stuck-open 8
PORV was a possibility even with the light off?
9 A
No, sir, I don't believe I had that 10 l
understanding because as long as that light was off, 11 we were never under the impression that we were to 12 aesume it was a stuck-open PORV.
13 Q
When the light was off, did you understand 14 you were to make any further inquiry or do any 15 rurthe r checnir.g in relation to a possible stuck-open g
i 16 PORV7 17 A
Sir, what my understanding was, was that 18 if we saw that the light was off and we had reason 19 we wouldn't have had reason to believe that the valve 20 was stuck.
If that light was off, we were under the 21 impression the valve was shut.
I was under the 22 impression the valve was shut.
23 Q
Let's take the situation where low reactor i
24 system pressure comes to your attention in that f (
25 situation.
Did you have a reason to believe the PORV
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Scheimann 564 2
could be-stuck open even with the light off?
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3 A
No, sir, not necessarily.
i 4
Q Did you realize or did you understand
')
'5 before the accident that a stuck-open PORV was a 6
possible cause of that low pressure even with the 7
light off?
8 A
Yes, sir, a stuck-open PORV could have 9
been one of the several causes for that.
10 Q
And did you understand before the accident 11 that when you had low reactor coclant system pressure 12 and high PORV outlet tempcratares, that a stuck-open 13 PORV was a possible cause even in a situation when I
14 the light was off?
15 A
Sir, I dor. ' t believe I had that 16 understanding because of the simple fact we were under 17 the understanding that if that light was off, the valve 18 should have been shut.
19 Q
Did low reactor coolant system pressure 20 and high PORV outlet temperature give you a reason to 21 believe that it might be stuck open?
22 A
No, sir, I don't honestly believe that it 23 would have; not in itself.
24 Q
Well, what do you mean by "not in itself"?
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25 What does that mean?
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Schaimann 565 1
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A What I mean is I could have just have the g\\_/
3 PORV cycled and if the PORV had cycled, I would 4
expect to see those conditions.
)
5 Q
I will ask you now in a few minutes to 6
list for me all of the possible things that could 7
explain these symptoms.
8 Right now, I would like you to concentrate 9
just on whether a stuck-open PORV is possible.
I am 10 not saying in my question that it was the only 11 explanation.
12 Do you understand?
I am using the word 13 "possible" and that means that it is one of two or
()
14 more or several explanations.
15 Now, what I am asking you is, in a 16 situation where the light is off, did you understand 17 that when you had other symptoms, namely, low system 18 pressure, high outlet temperature and drain tank 19 conditions, that even'with the light off that a 20 stuck-open PORV was a possible cause of those symptoms?
21 A
No, sir, I don't recall having that 22 understanding.
23 Q
So that it was your understanding that you 24 could use the light alone and exclude the possibility-i}
25 of the PORV being. stuck.open?
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Scheimann 566 2
A Sir, it was my understanding that if that O")
light was out, we had no reason to believe that 3
4 that valve had stuck in any position other than 5
closed.
6 Q
Well, I just gave you three reasons to 7
believe it was stuck open.
Is it your testimony that 8
you reject all of those reasons?
9 MR. MacDONALD:
Can I have the question?
10 Is there a question there, to hic recollection prior to the accident 11 12 MR. WURTZ:
What was his understanding.
I 13 g
unat about those three reascns I just bl g /
14 l
gave yout 15 MR. MacDONALD:
What is the question 16 about, what about those three reasons?
17 MR. WURTZ:
It is a pure follow-up.
He 18 said "I have no reason to believe when the 19 light is off." My question is, isn't low 20 system pressure, high outlet temperature and 21 high drain tank temperature not one but three 22 reasons to believe that a stuck-open PORV is 23 possible.
24 MR. MacDONALD:
You are asking for his
(N 25 understanding prior to the accident?
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scheimann 567 l
2 MR. WURTZ:
Yes, all of these questions D
3 are that 4
Q Your understanding prior to the accident.
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5 A
And I would still have to say no, sir, in 6
themselves there would not be indication to me that 7
the valve was stuck open if the light was out.
8 Q
What do you mean by "in themselves"?
You l
9 qualify that answer and I don't know what is in your 10 mind when you say that.
11 A
Si r, what is 1r3 my mind when I say thet, 12 if I know why, I knew I had those symptoms, 13 other than that, I would have no reason to think about I
i
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a stuck PORV, EG long as that light was Out, I was 15 under the understanding that that valve was supposed 16 to be shut.
17 h
Before you understood what was causing 18 those symptoms, did you understand that even with the 19 light off, you were to consider a stuck-open PORV as 20.
a possible cause?
21 A
.No, sir, because as can be seen, on most 22 occasions we would see the symptoms, we would see the i
23 cause before we would possibly see the symptoms.
We 24 would know that.possibly the valve had cycled, as'a
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25 result, we saw the symptoms, we saw the light was out,
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l 1-Schnimann 568 2
our primary indicator.
I would not have thought that O~/
the PORV was stuck.
3 4
Q Did you understand before the accident
)
5 that by looking at the light alone regardless of 6
anything else, you could exclude the possibility of 7
a stuck-open PORV7 8
A I would have to say yes, sir.
My 9
understanding of that light was that so long as that 10 light was out, I was to understand that that valve was 11 l closed.
4 12 Q
No matter wl.at elc3 was goir.g on, if the 13 light was off, it was your understanding that the 14 )
val,e tras closed; is that. correct?
15 A
As best I can recall, yes, sir.
16 Q
And so, is it fair to say that by looking l
17 at the' light alone it was your understanding that you 18 could exclude the possibility, even the possibility 19 of a stuck-open PORV?.
i i
20 MR. MacDONALD:
Are you asking if he had 21 that understanding?
i h-22 MR. WURTZ:
Yes.
i 23 A
As best I can recall, I would have to say, 24 yes, sir, i
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25 Q
When.was the light put into the Unit 2 I
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Scheimann 569 2
control room?
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A Sir, I really don't have a recollection 3
4 of when that light was put in.
)
5 Q
Do you recall that it was put in sometime 6
in the spring of 1978?
-7 A
I don't have a recollection of the time 8
for that, sir.
9 Q
After the time that it was put in, did 10 you receive training from Met Ed regarding the light?
11 A
Yes, sir, I had received training.
12 However, I don't recall exactly at what time frame-it 13 was on that particular light.
14' Q
Where was the training, was it in a 15 classroom, was it out at the console, where was it?
16 A
Again, I really couldn't say.
It could 17 have been at either place.
It could have been down i
18 at the trining center, it could have been down at the 10 console.
20 Q
Who conducted the training?
I 21 A
Again, sir, I can't recall who it was l-
]I 22 that particularly conducted that training session.
l 23 Q
Do you know that in fact Met Ed-gave you l
24 training on the use of the light?
(N 25 A
Yes, sir, I do recall having training on l.J'
I 1
Scheimann 570 2
how that light worked and what caused it to go off.
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3 Q
Were you shown diagrams of the light?
4 A
By " diagrams" are you referring to the
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5 electrical schematics?
6 Q
Were you given any written materials 7
concerning how the light worked?
8 A
As best I recall, the only thing I really 9
had on it was a diagram on it and that was explained 4
10 to us.
11 Q
What was that diagram?
12 A
The diagram was the electrical schematic 13 for that car a copy of the schenatic for that light.
()
l 14 2
What were you told about how the light 2
15 worked in the Met Ed training?
16 A
As best I can recall, we were told that.
17 there were two conditions when that-light should come 18 on automatically.
It would all depend on the matter 19 of whether you were in the NDTT position on the 20 switch for the light.
As you got up to your given 21 setpoint for pressure, the light would light, indicating 22 that the solenoid had been picked up for the pilot-23 operated relief valve.
When you got down below 24 the set pressure to the closed set pressure, the light g
25 would go out, indicating that the valve was shut or
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Schsimann 571 2
loss of signal was shut.
)
3 Q
What were you told would trigger or cause 4
the light to go on, what was it keyed to?
)
5 A
As far as actuating signal, sir?
6 Q
Yes.
7 A
Triggered on pressure and also on manual, 8
that is essentially what we were told.
9 Q
It would be triggered on pressure when 10 the primary presrure would exceed the PORV setpoint; 11 is that correct?
l 12 A
Yes, sir, when you got up above the PORV 13 setpoint, then you would get the valve opening.
()
14 Q
You said it could also be triggered on 15 manual.
What are you referring to there?
16 A
Essentially, we had a controller that 17 allowed us to manually operate the valve.
18 Q
How did that work?
19 A
Essentially, it was just a common switch 20 where you opened or you shut on it.
I can't recall l
21 what the-exact position on the switch was.
l 22 Q
Under what circumstances would you use 23 the manual control?
I 24 A
As best I can recall, I have never used it 25 or I am not really sure anymore when it would have
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Scheimann 572 2
been used.
4
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3 Q
What was it there for?
4 A
Sir, I really don't recall what the manual
')
5 function was there for.
6 Q
You don't recall ever using it?
i 7
A No, sir, I don't.
8 Q
What in the manual system caused the 9
light to go on or off?
j 10 A
I don't even recall that anyncre, sir, 11 having not used it.
i 12 Q
Well, you said it was triggered on manual; I
i 13 what were you referring to when you said that?
)
14 A
It was part of the electrical circuitry, 15 as best I can recall.
1 16 Q
Well, describe the circuitry, what are 17 you re' ferring to?
4 1
18 A
The circuitry I had mentioned-before that 19 controlled the operation of the solenoid light.
20 Q
So when you had it in manual, if you i
I 21 gave it an open signal, tli e light would go on; 'is 22 that what you mean?
. 23 A
I am not sure about that anymore.
I don't 24 even recall it as far as what the manual would do.
25 l
The only one I re. call is that the pressure would
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Scheimann 573 2
actuate it.
3 Q
Did you understand that when the pressure 4
dropped below the PORV setpoint the light would go
)
5 off?
6 A
Yes, sir.
7 Q
Were you taught that this could happen i
8 even in a situation where the valve stuck open if th,e 9
pressure dropped?
10 A
No, sir, we were told that when that light i
i 11 goes out, we were to assume that that valve had no 12 reason to be open.
4 13 Q
So you were not taught that when the
~
14 pressure dropped below the PORV setpoint the light 15 could go off and the valve could still be sticking 16 open?
17 i
I do not recall being taught that, sir.
18 Q
Were you taught by Met Ed that the light 19
-in fact told.you what the physical position of the' i
20 PORV was at any given time?
21 A
No, sir, I was not.
However, we were told 22 that that was our primary indication.
23 Q
But you were not taught that it told you 24 the physical ~ location of the valve; is that correct?
25 A
No, sir, to the best I can recall.
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1 Scheimann 574 2
Q What were you taught that the light did
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give you in information?
4 A
We were told that the light strictly
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5 gave us indication of what solenoid power it was to 6
the valve, whether it energized to the valve or 7
whether it was nc...
8 Q
So if the light was on, it would power to 9
the solenoid, and if the light was off, there was 10 no power to the solenoid; that is what you were L
11 taughc?
12 A
Yes, sir.
13.
Q Eut you were not taught that in a situation
()
b 14 where there was no pcsier to the solenoid the valve 15 could be stuck open; is that correct?
16 A
Sir, I don't have a recollection of it.
17 Q'
And before the accident, you did not 18 understand that in a situation where the light was 19 off, it was possible for the PORV to be stuck open; is f
20 th at correct?
21 A
I really don't have a recollection of 22 having that understanding, yes, sir.
i.
4 i
23 Q
You were not taught in the Med Ed training
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24 that in a situation where the PORY opened on high,
I l
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Schoinenn 575 2
setpoint, that you could have a situation where the s
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valve stuck open and the light would be off?
i 4
A Sir, I don't recall having that
)
5 understanding.
6 Q
You say you were taught that by Met Ed, 7
that your light should be your primary indicator of 8
whether the PORV was stuck open.
What do you mean by 9
" primary indicator"?
10 A
No, sir, I did not say that that light was i
11 the primary indicator that the valve should be stuck 12 open.
i 13 Q
Primary indicator for you to tell the
(^N
(,)
14 status of the valve, whether it was stuck open or 15 closed, whether it was open or closed?
16 Let me start again.
17 You testified earlier that you were taught 18 by Met Ed that the light was the primary indicator 19 for you to look at in telling whether the PORV had 20 closed; is that correct?
21 A
Yes, sir, it would be the primary 22 indicator that the valve had opened or closed for us.
23 Q
What do'you mean by the term " primary 24 indicator," what did you understand that to mean?
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25 '
A What I meant by the term " primary l
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1 Scheimann 576 2
indicator" was that that would usually be the first
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)
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3 thing we would check.
4 Q
What was the second thing you would check?
)
5 Mk. MacDONALD:
Is that an assumption
\\
6 that there is a second thing?
7 MR. WURTZ:
Yes.
8 A
Secondly, if the light was out, I wouldn't 9
go any further in an everyday s'ituation where the 10 valvt: had cycled.
It Q
So you would look at the light and that 4
12 would be it?
13 A
If the light was out, I would have no m
f)
[4 reason to go any further.
15 Q
And you would conclude on the basis of 16 the light that the valve was closed?
17 h
Yes, sir.
18 Q
And your conclusion would not be changed 19 in any way in a situation where you had low system 20 pressure, s high PORV outlet temperature or a_high 21 drain tank temperature; is that correct?
{
22 A
No, sir, because if that valve had opened 23 and cycled, I would expect to see that, and if the
.3 24 light went out I would have no reason to doubt that r^'
25 I still had those. conditions.
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1 Scheimann 577 2
Q Now you are introducing the cyclying as
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3 an explanation, is that correct, you are saying that 4
you understood if cycling caused it you would have
')
5 no, reason to think the PORV was stuck open?
6 MR. MacDONALD:
I want to make it clear 7
we are talking about a situation where pressure 8
goes up and opens a valve and then pressure 9
drops back down below the setpoint and closes 10 the valve, with the light indication?
This is 11 the situation we are talking about, right?
12 MR. WURTZ:
I am talking about the light 13 being off, yes.
()
14 Q
And my question is, you said that the 15 fi rs t thing you would look at would be the light and l
16 based on the light, you would conclude that the valve 17 had closed; is that correct?
18 A
I would say yes.
19 Q
And my question is, would that conclusion 20 be affected if low system pressure, high PORV outlet 21 temperature and high drain tank temperature and 22 pressure came to your attention?
23 A
No, sir, I don't believe it would have 24 because I would have'been expecting those conditions O\\
25 after the valve had cycled.
l 1
Scheimann 578 l
2 Q
Let's take a situation where you have low 3
. reactor coolant system pressure and high PORV outlet 4
temperature and high drain tank temperature.
Before
)
5 the accident, what did you understand could cause 6
those symptoms?
7 MR. MacDONALD:
Any one of those symptoms?
8 MR. WURTZ:
Those three together.
9 MR. MacDONALD:
At the same time?
10 MR. WURTZ:
At the same time.
11 MR. MacDONALD:
At what point in time in 12 the transient?
We are dealing with three 13 symptoms out in nowhere here.
We haven't tied
)
14 it to a specific situation, whether there is a 15 time period involved, whether there is a specific i
16 transient involved, whether they occurred 17 simultaneously or at or about the same time.
If 18 you would be a little clearer with the question, 19 that might help,the witness with his answer.
20 Q
Let's start with those symptons occurring 21 in the early minutes.
22 A
Early minutes of what, sir?
l 23 Q
You have had a high pressure spike and i
24 you have tripped the reactor on high pressure, and l
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25 follo' wing that,'you see the symptoms, low reactor e-g..-
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1 Scheimann 579 2
coolant system pressure, high PORV outlet temperature 3
and high drain tank temperature and pressure.
What 4
did you understand could be the causes of those three
)
5 symptoms together?
6 A
At that point, sir, I would expect only 7
one cause and that was cycling of the PORV.
8 Q
And that would be in the early stage 9
you think it would be cycling; is that correct?
10 A
well, I would know it had cycled.
11 Q
Now, how would you expect the primary 12 pressure to behave after a cycling of the PORV, what 13 was your understanding before the accident?
i 14 A
It would depend on how far pressure 15 drove down following the cycling.
In most cases that 16 I can recall hearing about, and in particular on Unit 2, 17 on a trip on high pressure, generally pressure ended 18 up going down far enough to pick up high pressure 19 injection.
20 MR. WURTZ:
Could you read that answer 21 back.
22 (Answer read.)
23 Q
It is your testimony that you understood 24 that every time there was a PORV cycling, it would go
(~T 25 down far enough to start high pressure injection; is V
i
1 scheimann 580 2
that your testimony?
3 MR. MacDONALD:
I object.
He didn't 1
4 testify that every time that is a fact.
)
5 MR. WURTZ:
I am asking that.
6 MR. MacDONALD:
I think that is a 7
misleading statement.
If you want to ask him 8
the question, fine, but don't try to 9
characterize his prior testimony.
10 MR. WURTZ:
I am trying to understand the 11 testimony.
12 Q
What did you understand would happen to 13 pressure in the case of a cycling of the PORV on a
()-
14 high pressure trip?
15 A
Sir, in most cases I am not saying all 16 cases, but in most cases I had been aware of pressure 17 having gone down to the point where we ended up 18 picking up high pressure injection.
19 Q
In what case did that happen?
20 A
I can't recall specific cases.
~21 Q
In-what year?
_).
22 A
I can't recall the specific year.
.23 Q
Was it on Unit 27 24 A
Yes,. sir, it was on Unit 2.
r yg 25 Q
What happened after HPI came.on?
'd
l 1
Scheinann 581 2
A In what regard are you referring to there, p
3 sir?
1 4
Q What happened to the pressure?
')
5 MR. MacDONALD:
In a specific case, now?
f 6
MR. WURTZ:
In the LT, stances he just 7
referred to, yes.
He just referred to his 8
experience and I am asking him what happened.
g A
I really don't recall specifically what
-10 had happened in that particular case other than the 11 fact, in any particular case, other than the fact that 12 we did drop pressure initially.
13 Q
What caused the trip in those cases?
()
14 MR. MacDONALD:
In each instance 15 what caused the reactor trip?
16 MR. WURTZ:
In any one of them.
17 Q
Are you talking about more than one 18 instance where you had a high pressure trip and a 19 cycling and a drop in pressure to HPI?
Did it happen 20 more than once?
l 21 A
It happened several times.
l 22 Q
Were you ever there?
23 A
I really don't recall-if I had been on shift 24 at the time it occurred.
(
(~h 25 Q
How-did you learn about it?
%.)
i
..~., ~.,
H 1
Scheimenn 582 2
A Probably from LER's.
O 3
Q Well, did you learn it f rom LER's or didn ' t 4
you?
')
5 A
I am not sure where I learned it from, sir.
6 Q
What did you learn?
7 MR. MacDONALD:
What do you mean, what 8
did he learn?
9 Q
What did you learn about these events?
Tell 10 me everything you learned about them.
11 A
Sir, I can't recall every little thing 12 I learned about those events.
13 Q
Well, tell me the big things, then.
(w) 14 MR. MacDONALD:
Welli he can tell you 15 what he recalls, I'm sure.
16 Q
Yes, that is what I am asking for.
What 17 you consider a little thing I may not, so tell me 18 everything you recall.
19 MR. MacDONALD:
Ask the question, Mr. Wurtz, 20 there is no reason to raise your voice when you 21 are talking to the witness.
Just ask your 22 questions.
23 MR. WURTZ:
Well, I am asking the questions.
24 A
Sir, the best I can recall, in most of the e~N 25 cases where we had a pressure trip on,'or on high I
i V
N 1
Schaimann 583 2
pressure of the reactor, we ended up dropping pressure 4
(3-
\\-
3 to the point where we ended up getting high pressure 4
injection.
And that's about the main thing I recall
')
5 from those instances.
6 Q
Did you receive training on those cases?
7 A
I would say, yes, at one time or another 8
we received training on the LER's that resulted from 9
them.
10 Q
What were you taught?
11 A
Sir, I really don't recall that much 12 about it anymore except that we had been told that we 13 had actually had high pressure trip to the reactor and
)
14 we had ended up on injection in several cases.
15 Q
What brought about the trip?
16 A
Sir, I don't even recall that.
17 Q
What happened after the HPI came on?
18 A
Sir, I don't have a recollection of that.
L 19 Q
What did you conclude from this training F
20 that you received from Met Ed?
i 21 A
I really don't recall having made any 22 conclusions one way or the other based on it.
It's 23 been a while since I have had it.
24 Q
Did you expect HPI to come on every time 25 there was a high pressure trip?
g( S l
-l
l 1
Schaimann 584 2
A I think I would have conceivably expected
(
)
3 it.
4 Q
You were taught that by Met Ed?
)
5 A
I don't recall that they came out and said 6
that in so many words.
7 Q
Was that the understanding you had as a 8
result of the training they gave you?
9 A
I don't know necessarily that my 10 understanding based on that was based strictly on 11 what I had been given in training.
12 Q
Now, we were talking about three symptoms, 13 low system pressure, high PORV outlet temperature m/
14 and a high drain tank temperature, and these symptoms s
15 appear in the early stages after a high pressure trip.
16 You have testified that you thought a cycling could 17 bri'ng this about; is that correct?
18 A
I knew a cycling would account for those.
19 Q
Now, in a situation where the same symptoms 20 exist at 15 minutes into the transient what did you s
21 understand possible causes to be?
.)
22 MR. MacDONALD:
Well, symptoms all exist 23 simultaneously now 15 minutes into a transient 24 that was_ initiated by a high pressure reactor C' '
25 trip?
(j l
1 Scheimann 585 2
MR. WURTZ:
Yes.
t },
f
'/
3 MR. MacDONALD:
Anything else?
4 MR. WURTZ:
No.
)
5 MR. MacDONALD:
No other transient is 6
continuing on for 15 minutes.
7 MR. WURTZ:
Those symptoms exist.
8 MR. MacDONALD:
And did he have an 9
understanding at or about a 15-minute's mark 10 into that situation.
11 Q
What was your understanding of the possible 12 causes of those three symptoms all together?
13 A
As best I can recall, I never really got p
(,)
14 into a situation where I saw a transient carried out 15 to that duration of time on the simulator and as a 16 result, I still would have been under the impression 17 that that could conceivably have still been a normal 18 thing to have as a result of the cycling previously.
19 Q
How long a cycling?
20 A
Sir, I really couldn't give.you a time 21 for that, but I would assume that at that time I 22 assumed that I could see that for a while.
I had 23 never really seen o'ne carried out in any duration.
l 24 Q
So you understood that a normal cycling
(~')
25 of the PORV for a. period of 10 seconds could produce
\\
/
{
[
l
. _... ~.,,
1 1
Scheimann 586 l
2 those symptoms for a loing period of time; is that your 3
testimony?
4 A
No, sir, I did not have an understanding 4
')
5 of a time of cycling; however, I did have a basic i
6 understanding that I could expect to see those symptoms 7
around for a while following a cycling of the valve.
8 Q
Did you understand that in a case where 9
the pressure went up above the setpoint and then 10 dropped immediately below the PORV setpoint and 11 continued to drop for a time period after the pressure 12 was below the setpoint, that that was being caused by 13 the opening and closing of the valve?
O t()
14 Do you understand the question?
15 A
No, evidently I don't, sir.
16 Q
Did you understand that you could look at 17 the pressure, reactor coolant system pressure strip 18 chart and see the time period for the PORV open and 19 closed, the length of the cycling?
20 A
No, sir, I don't think I ever gave that 21 much thought.
22 Q
Did you understand that you could look 23 at that pressure strip chart and tell when the 24 pressure was below the PORV setpoint?
25 A
Yes, sir.
I could tell by looking at the
[
)
%J J
u-+
y
,e
I 1
Schsimann 587 2
chart what pressure I was at.
f_s
(
\\
G' 3
Q Now, did you understand that in a 4
situation where the pressure continued to drop all the
)
5 way down to HPI, that that was caused by a cycling of 6
the PORV7 7
MR. MacDONALD:
That is the only cause 8
for it or is a possible cause?
9 MR. WURTZ:
That could be caused by a 10 cycling of the PORV.
I am assuming here that 11 the PORV opens and closes the way it is supposed 12 to.
13 A
I would have to say yes, I have the A
k_)
14 understanding that that could cause pressure to drop 15 down.
16 Q
Even after the PORV had closed again, 17 the opening and closing could cause the pressure to 18 continue to drop; is that correct?
That was your 19 understanding?
20 A
No, sir, what my understanding was, 21 was even though -- once the light was out, it would 22 still take a finite period of time for that valve to 23 close and during that time you could see a continued 24 drop in pressure.
How long a time, I really couldn't O
25 say.
Q
\\
~
l 1
Schnimann 588 2
Q But once the valve closed, you wouldn't i
s/
3 see a drop in pressure anymore, is that correct, that 4
was your understanding?
')
5 A
Not from the valve itself any longer, no.
6 Q
So now you say that the light could be 7
off, the valve could still be open for some period of 8
time; is that correct?
9 A
on its way shut.
10 Q
on its way shut?
11 A
It might be, you know, an infinitesimally 12 small period before the valve would close.
13 Q
What was your understanding of the time (v) 14 period?
15 A
I didn't have an understanding of the amount 16 of time.
It was usually dealt with as being 17 simultaneous.
18 Q
It was close to simultaneous; is that your 19 understanding?
20 A
Essentially, yes.
21 Q
So that if you had a situation where the 22 pressure continued to drop for a minute or two minutes 23 you could exclude the cycling of the PoRV as the cause 24 for that pressure drop; is that correct?
t'~3 25 A
I would have to say, yes, I probably could.
i
)
v
]
1 scheimann 589 2
Q And by looking at the primary pressure 4
3 strip charts on the panel where you were standing, 4
you could observe the primary pressure drop that had 5
occurred?
6 A
Yes, it would be on a recorder.
7 Q
And before the accident, in a situation 8
where primary pressure continued to drop after the 9
time when the PORV had closed or appeared to have 10 closed from the light, and when you had a high PORV 11 outlet temperature and high drain tank temperature, 12 what did you understand could be the cause of those 13 symptoms?
f~
5 14 A
Could I have that again, please?
15 (Question read.)
16 A
I don't recall having addressed those 17 exact symptoms prior to the accident in that we never 18 really saw a case where pressure continued to drop 19 following the closure of the PORV.
20 Q
You mean yo2 personally did not participate
{
21 and see it on the panel?
22 A
No, I personally did not, nor did I hear 23 of it.
24 Q
And you were never told by Met Ed about I'N 25 the stuck-open PORV that occurred in March of 1978
'\\.
i t
1 Scholmann 590 1
3 on Unit 2; is that correct?
'( /
3 A
I may have been but I don't have a 4
recollection of it one way or the other whether I
')
5 had or not.
6 Q
You knew from the pressurizer failure 7
procedure that those three symptoms were symptoms 8
of a possible stuck-open PORV, didn't you?
\\
g A
Yes, sir, I also knew they were symptoms 10 of a cycling of a PORV, a cycling of a code or a 11 stuck-open code.
12 Q
Were there any other causes you understood?
13 A
There could have been several different
/3
(_)
14 things that could have resulted in some of those 15 conditions but not necessarily all of them.
16 Q
so for all three of them to be present 17 the possible causes are a cycled or stuck-open PORV 18 or a cycled or stuck-open code; is that correct?
.19 MR. MacDONALD:
I am going to object.
20 I don't think that was his testimony.
Are you 21 talking about a situation now where those three 22 symptoms would exist simultaneously and you 23 are asking for what events or combination of l
l 24 events could produce that, or are you looking A
25 for something else?
U
u 1
Schaimann 591 2
MR. WURTZ:
It was just testified to.
3 Could you read back the previous question 4
and answer.
)
5 (Record read.)
6 Q
And the question is, to follow up on that, 7
you have given what you understood were the possible 8
causes of those three symptoms together, and as I 9
understand it, the possible causes were a stuck-open 10 code, a stuck-open PORV or a cycling of the code or 11 PORV; is that correct?
12 MR. MacDONALD:
I object.
I don't think 13 that was his testimony.
14 MR. WURTZ:
Well, that is what I am 15 asking.
16 A
Those could account for the symptoms as 17 well as any number of things could.
18 Q
What are the other things?
19 A
You could have a ' case where you could 20 have a steam leak in the building; you could have a r
21 primary to secondary leak involved with that steam k
i 22 leak.
You've got some drainage into the RC drain tank l
23 from valve leak-offs.
l 24 Q
I am talking about causes for all three l
/)N 25' things together, not for any single thing but for all
(
l
f 1
Schaimann 592 2
three together.
(~h N-3 MR. MacDONALD:
I am going _to object to 4
the form of the question.
He has given an
)
5 answer.
6 Q
Isn't it correct you could exclude a 7
steam leak when you have high PORV outlet temperature
-8 and high drain tank temperature?
9 MR. MacDONALD:
I object to the form of 10 the question.
I don't think that is a proper 11 question.
12 Q
Do you understand the question?
13 MR. MacDONALD:
Is the question whether O)
(_
14 or not a steam leak would produce those two 15 particular events?
16 MR. WURTZ:
We are talking about three 17 symptoms existing together.
I am trying to get 18 a comprehensive list of the thin ~gs Mr. Scheimann 19
~
understood before the accident could cause them.
20 I thought I had a comprehensive list.
Now after 21 some coaching, we have gotten some additional 22 things, so now what I want to do is go through 23 those and determine step by step what a 24 comprehensive list is.
[~')
25 Q
Now, if you say a steam leak could cause
\\,J t
~
1
\\
1 Schsimann 593 i
2 those three things together, I want to know how it
~ x/
3 could do that.
4 MR. MacDONALD:
There is no coaching.
')
5 There is an objection to the form.
He has 6
already given you answers that were several 7
other things before I interposed an objection.
8 MR. WURTZ:
I want to know what those 9
other things are.
10 MR. MacDONALD:
Secondly, he has told you 11 there are several other things that could give 12 you some of those symptoms at the same time.
13 That is what he is testifying to.
()
14 MR. WURTZ:
I am not talking about some
~
15 of those symptoms.
I am talking about those 1
16 symptoms, period.
17 Q
Is it your testimony that a steam leak 18 could cause those symptoms?
19 A
It is my testimony that a steam leak could i
20 result in some of those symptoms.
21 Q
And that is why my question was, could a 22 steam. leak produce those symptoms, not some of those 23 symptoms, those symptoms, period.
I am not carving 24
-out one here and carving out one here. I have specifically c
25 asked yoo, could.a stean.lgak caus.e those three g-s
\\h
. -.. ~..
~
u
,1 1
Schsimann 594 2
symptoms.
\\
3 MR. MacDONALD:
A transient involving a 4
steam leak?
)
5 MR. WURTZ:
Whether a --
6 MR. MacDONALD:
A steam leak itself or a 7
transient that results in the steam leak?
That 8
is why I am not clear and I think it has got to 9
be cleared up on the record for the witness.
i 10 Are you asking whether a steam leak on the 11 secondary side, which is what you presume, that 12 that steam leak on the secondary side, that leak d
13 is going to produce those symptoms, or the O
i
',/
14 transient that follows on from that may produce
\\
15 those symptoms?
I think it is two different 16 questions and I am not sure what you are asking 17 and that is what my objection is based on.
I 18 think.if you are focusing on just a leak in the 19 secondary side causing those symptoms or whether 20 you are focusing on a transient causing a steam 21 leak --
22 MR. WURTZ:
I am not making any distinction l
23 between those two situations.
I am asking for i
24 a comprehensive list of what he understood could
("'g 25 cause those.three symptoms.
~ \\j -
l
1 Schaimenn 595 2
MR. MacDONALD:
So you are talking about a
/~~s.
3 transient, now.
4 MR. WURTZ:
I am talking about situations.
)
5 I am not accepting any artificial word games G
here.
7 Q
I am asking a simple question here.
What 8
would produce to your understanding those three 9
symptoms, and if you are testifying it is a steam J
10 leak I want to know how that would happen.
11 MR. MacDONALD:
And the question is, how 12 could a steam leak produce those three symptoms?
13 Q
I am asking for a complete list of what
(_j 14 could produce those three symptoms.
I have a stuck-15 open PROV and a stuck-open code or a cycling of those, 16 and I want to know if there is anything else that you 17 want to add to the list and then we will go through 18 these things one at a time.
19 A
Other things that could cause you to have 20 those symptoms would be leaking of the PORVs, leaking 21 of the codes; they would result in symptoms similar to l
22 that; any transient that could cause you to get into 23 a condition where you would build up pressure in the 24 RCS system would cause the PORV to operate and as a (Y
i 25 result cause you to get into those situations.
l
\\-
l
ll 1
Scheimann 596 2
(Recess taken.)
O, 3
BY MR. WURTZ:
4 Q
Mr. Scheimann, did you understand before
)
5 the accident that when you have all three symptoms, 6
low primary pressure, high PORV outlet temperature, 7
high drain tank temperature, that the possible 8
causes were a problem with the codes or a problem 9
with the PORV; is that what it comes down to?
10 MR. MacDONALD:
I object to the form of 11 the question.
12 A
I would have to say, no, sir, not those 13 by themselves.
Any condition or transient which
(_/
14 could cause a high pressure in the reactor coolant 15 system could result in opening of that and thereby 16 giving you those symptoms.
17 Q
You mean that any time there is a high 18 pressure trip, it could produce a problem with tha 19 codes or a problem with the PORV; is that what you 20 are saying?
21 MR. MacDONALD:
I object to the form 22 of the question.
23 A
No, sir, I am not referring to the fact 24 that they could cause a problem with the codes, f~'
25 However, they could possibly cause a cycling of the
' \\.s)
< =
1 Scholmann 597 2
PORV, which would in turn give you the symptoms.
('\\)
3 Q
So we are back to the codes or the PORV 4
as the possible causes for these symptoms, as you
)
5 understood it?
6 A
No, sir, what I said was those in 7
conjunction with whatever transient would cause you 8
a high pressure condition in the RCS.
9 Q
And there you are referring to a high 10 pressure in the primary which resulted in an opening 11 of the PORV or an opening of the codes; is that what 12 you are referring to?
13 A
It could result from a high pressure in 14 the RCS.
15 Q
Well, if the PORV or the codes did not 16 open, then these symptoms would not be present; is that 17 correct?
It would have to be a high pressure, high 18 enough pressure to open one or the other, wouldn't it?
19 MR. MacDONALD:
Well, are you asking for 20 his understanding today, his recollection prior 21 to the accident?
22 MR. WURTZ:
That's right, this is all 23 to your understanding before the accident.
24 THE WITNESS:
Could I have that aaain?
(N_
25 Q
Well, this is a simple question.
I am (V
i-l-
L
~
I 1
Scheimann 598 2
just trying to get a list of the things that could O
t
\\-
3 cause these symptoms so that I can then ask you 4
about the items on this list, and as I understand it,
)
5 the items on the list are a problem with the codes 6
or a problem with the PORV7 7
MR. MacDONALD:
I object to the form of the 8
question.
He hasn't said it is a problem in 9
any of his prior testimony.
He has told you it 10 wasn't a problem, so if you are trying to 11 characterize the testimony, it is misleading.
12 Q
The symptoms could be caused by the code 13 or the PORV.
A cycling is not a problem.
I am
(%
(_)
14 intending to include all of those three things but 15 the three symptoms that I gave you would be connected 16 to the codes or the PORV; is that correct?
Those 17 are the two possibilities?
18 MR. MacDONALD:
All three symptoms, now?
19 MR. WURTZ:
Yes.
20 MR. MacDONALD:
Low pressure, high tail 21 pipe temperatures and high temperature and 22 pressure in the drain tank.
23 MR. WURTZ:
High PORV, I said specifically I
24 high PORV temperature.
/')
25 A
No, sir, you wouldn't be limited to just u
I scheimann 599 2
those.
You would be limited by -- several other
(""
, (-
conditions could cause you to get symptoms like that.
3 4
You could have the case, for example, where you took l
')
5 and you had the high pressure in the steam generator 6
such that you lifted open the safety valves on the 1
7 steam lines.
In that event, your pressure would be 8
high.
You would have the possibility of the PORV 9
cycling.
In addition, you could have an over-cooling 10 which could af fe ct it.
If the main steam safety 11 line valve stayed open, you can have an over-cooling 12 type condition such that you would see the pressure 13 drop.
()
14 Q
So you are saying an over cooling could 15 produce those symptoms?
16 A
Depending on the cause of the over-cooling 17 situation, it could give you similar situations.
18 Q
What situations?
19 A
The situation I pointed out to you where 20 you had a steam valve opened and then failed to 21 re-shut.
22 Q
That is an over-cooling, is it not?
23 A
It would be.
24 Q
What produces the high pressure _ trip in 25 an over-ccoling?
g
l 1
Schaimann 600 2
A The initial cause of why the valves n
3 lifted to begin with.
4 Q
That is high pressure in the steam
)
5 generator, not in the primary system?
6 A
Yes, sir, but what caused the over-cooling?
7 Say, for example, you had a loss of feedwater, your 8
pressure in the steam generator as well as your 9
pressure in the primary plant is going to increase, 10 and as it increases, it could conceivably lift the 11 PORV and continue leaking past the steam safety valve, 12 could result in a reduced pressure.
13 Q
Well, you are describing a situation where mk,)
14 first you have a loss of feedwater and then over-cooling; 15 is that what you are describing?
16 A
Essentially, that could take place.
17 Q
And the loss of feedwater would cause the 18 pressure to go up in the primary and open the PORV; 19 is that correct?
20 A
It could, as well as resulting in a 21 reactor trip.
22 Q
Now, if pressure then began to drop after l
23 that happened, did you understand that the cause of the 24 pressure drop would be either that the PORV was still
['}
25 open or that an over-cooling had taken place or had l
\\J t
H 1
Scheinann 601 2
started?
s N-3 A
My understanding would have been that the 4
restoration of feedwater would have been sufficient
')
5 to start pressure downward.
6 Q
So as long as you had feedwater restored 7
then you could exclude the open PORV as the cause of 8
the pressure dropping; is that correct?
9 A
As long as the light indication for the 10 PORV was out and I saw that I had a condition that 11 could result in those symptoms, I would say yes.
12 Q
And the co'ndition that could result in 13 those symptoms in this particular situation we are
(
14 talking about is the over-cooling going on in the 15 steam generator; is that correct?
16 A
I would say at that point that would be 17 responsible for the reduction in pressure.
18 Q
Now, did you understand that in a s'ituation 19 where there was no over-cooling in the steam generator 20 that the pressure drop was being caused by a stuck-21 open PORV?
22 A
I don't recall having that understanding, 23 sir.
24 Q
Is there any other possible cause in that
{~N 25 situation?
%./
- -- J
~
1 1
Scheimann 602 2
MR. MacDONALD:
You Are asking for his l
\\
(/
\\-
3 understanding prior to the accident?
4 MR. WURTZ:
Yes.
')
5 MR. MacDONALD:
If pressure dropped where?
6 MR. WURTZ:
In the primary system.
7 MR. MacDONALD:
To any particular point 8
or just pressure reduction?
9 MR. WURTZ:
Continuing pressure decline.
10 MR. MacDONALD:
Continuing.to where?
Are 11 you talking about down to 200 psig?
12 MR. WURTZ:
Continuing to'well below what 13 it should be, which is 2155, continuing'well
(~s q_)
14 below that.
15 MR. MacDONALD:
I object.
I don't 16 necessarily know what you mean.
17 You can answer the question.
18 A
I am not sure I really understand what you 19.
are referring to there.
20 Q
I will go back and try to set the stage 21 here.
)
22 We have got a situation where you have had 23 a loss of feedwater.
The loss of feedwater has caused l
24 an increase in the primary pressure.
The primary i
("%
25 pressure has increased to a_pcint where the POllV had
[
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v c-p
+'m
-t-
-?
t-9' RP$
fr----
-c T
l 1
schsimann 603 2
opened and then the primary pressure begins to drop, 3
a situation where you do not have an over-cooling on, 4
and in fact where you do not have any feedwater at all
~)
5 going into the steam generators.
Did you understand 6
that the reason the pressure was continuing to drop 7
was that the PORV was leaking er stuck open?
8 MR. MacDONALD:
And this is prior to the 9
accident if he had an understanding about that 10 particular situation that you described?
d 11 Q
Did you understand that about the system 12 response?
13 A
No, sir, I do not recall having that 14 understanding.
I do not recall having dealt with a 15 case like that.
16 Q
Well, you studied this system and how it 17 works dor at least six years before the accident:
18 isn't that correct?
19 A
I had studied the system and how it 20 operates for a period of time.
21 Q
Well, my question is based on that 22 understanding in a situation where you knew that 23.
over-cooling was not causing this pressure decline, 24 did you know that a stuck-open PORV was a possible
/^x 25 cause?
i
\\s/
. = _
1 Schsimenn s
604 I
~2 MR. NacDONALD:
And the' situation is also 3
where there is no feedwatdr at all, main or w
i 4
emergency?
5 Q
A situation where you could exclude oher -
']
6 cooling and in a situation where you could exclude 7
over-cooling as the cause.
+
8 MR. MacDONAbD:
I think he has answered it, s
9 but go ahead.
10 A
No, sir, I d o n ',t believe I had an 11 un de rs t andin gf'o f that nature by nature of the fact that 12 we were never under a situation, genera 41y where we
,\\
13 could lose feedwater and not get'ft ba'ck by means of
/~N
()
14 the emer'gency feedwater system.
15 Q
Well,'besides an over-cooling, what 16 could cause a decline in primary pressure that you
'4 17 understand?s f
18 MR. MacDONALD:
What kind of decline 1
1 19 in primary pressure are wedtalking about?
-4
.e 20 m
MR. WU RTZ.: *A continuing declin'g.below i
MR. MacDONALD:
Below 2155? )
N 21
~
, s q-u, K 22 MR. WURTZ:
Yes.-
N
\\
\\
N\\
w 23 A
As I pointed out,\\cyc. lying of the PORV' 24 could well bring lyou down belowJ2155.
- pd 25 Q
That pressure drop would stop if the PORV 1
1 w
y
.-----9
-..---._t
--s, i
l 1
Scheimann 605 2
closed; isn't that correct?
\\_/
3 MR. MacDONALD:
You are assuming nothing 4
else is happening in the system; is that your
)
.5 assumption?
6 MR. WURTZ:
My assumption is that you have 7
excluded over-cooling.
That is my only 8
assumption, that you have excluded over-cooling.
9 Q
Let me ask this.
If there is no feedwater 10 at all going into the steam generator, you can 11 exclude over-cooling; isn't that correct?
12 A
I would say that would not necessarily be 13 true. If you developed a steam leak along at the same
()
14 time, you could still conceivably have over-cooling 15 conditions.
16 Q
You understood you could have over-cooling 17 even in a situation where there was no feedwater 18 at all being added to the steam generators?
19 A
I had the understanding that if we 20 developed a steam leak, we would be removing more 21 steam from the system than we were putting into it 22 and thus we could have indications of over-cooling.
23 Q
Did you understand you could have over-24 cooling in a case where you were not adding any r
{^'}
25 feedwater at all to the steam generators?
l x_-
l
..., _.. _..,,, _. -. -.... -. -.. ~
~
l 1
Schaimann 606 2
MR. MacDONALD:
Isn't that just the same ni')
3 question you asked him?
4 MR. WURTZ:
Yes, I am asking it again
- )
5 because I didn't get an answer.
6 A
I did answer that.
7 Q
You said that a steam leak could cause it.
8 I asked you specifically whether you could have it 9
when you have no feedwater, none at all being added to 10 the steam generator.
11 A
Sir, as best I recall, if you had a steam 12 leak, just about at any time you had it, you would be 13 removing more heat than what would be put into the 14 RCS and you would show symptoms of an over-cooling 15 type situation.
16 Q
Even when you didn't have feedwater 17 being added to the steam generator?
18 A
I would say, yes, it is a possibility.
19 Q
That was your understanding?
20 A
As best I can recall, I would have to l
l 21 say on a steam leak, I would expect to see conditions l
22 that would represent an over-cooling type situation.
l l
23 Q
once again I am trying to get a specific 24 answer to a question here.
L
("N 25 Even in a situation where there was no l
\\
)
u./
w,
~,
r
~
l 1
scheimann 607 2
emergency feedwater and no feedwater at all, you
~
\\
"I understood there could be over-cooling?
3 4
MR. MacDONALD:
I am going to object to
')
5 the form.
I think you have asked that specific 6
question and he has given you a specific answer 7
two or three times.
You can ask the question 8
again.
9 MR. WURTZ:
I think it is still unclear.
10 MR. MacDONALD:
I don't think it is 11 unclear.
12 MR. WURTZ:
If you want to stipulate what 13 the answer is, then I.will take your stipulation;
()
14 otherwise, it is unclear.
15 MR. MacDONALD:
I am not going to 16 stipulate an answer.
I am saying for the record 17 I know that particular question was answered 18 twice before.
19 MR. WURTZ:
You tell me what the answer is.
20 MR. MacDONALD:
I am not here to testify.
21 It is clear from the record.
22 BY MR. WURTZ:
23 Q
The question I have is, are you saying 24 that it was your understanding that even in a case
('}
25 where there was no feedwater, no feodwater of any kind L ).
i
, +-
,n--
,<_.,.-n,,-,a.,
.n
~
l 1
Scholmann 608 2
being added to the steam generator, that you could O'/
have an over-cooling?
3 4
A Sir, first of all, I don't recall having
)
5 dealt with a situation where I totally had a loss 6
of feedwater.
My situations that I have dealt with
~
7 and have learned about have been cases where we 8
always were able to get emergency feedwater back in, 9
and a steam leak under a condition where you lost 10 feedwater initially would show you the symptoms of 11 an over-cooling situation.
Depending on how fast you 12 got the emergency feedwater back would depend on how 13 far down temperature and pressure.would go.
14 Q
I guess we have got three situations now 15 or three explanations for the symptoms.
We have got 16 the codes, the PORV and a situation where you had 17 high pressure trip followed by an over-cooling; is that 18 correct for the three symptoms?
19 A
I would say those are three of the things 20 that co ul'd cause those symptoms.
There are probably 21 more.
I just can't recall what they are at the present 22 time.
23 Q
What do you mean, "there are probably 24 more"?
If there are probably more, what are they?
(~N 25 A
Sir, what I said is I can't recall what l
x/
t l
1 Scheimann 609 2
they are at the moment.
You could probably set up
(-
3 several different conditions in the plant that would 4
give you similar conditions.
I just don't at the
')
5 moment recall what they are.
6 Q
Let's take these one at a time.
7 First the codes.
8 Did you understand that the setpoint for 9
the codes was higher than the setpoint for the PORV?
l 4
10 A
Yes, sir.
11 Q
Did you understand that the setpoint for 12 the codes was higher than the trip setpoint?
13 A
Yes, sir.
14 Q
Did you know that in a normal reactor 15 trip the codes would not open?
16 A
On a reactor trip the codes should not 17 lift.
18 Q
Did you know that you could tell from the 19 strip chart on the front panel whether the codes i
20 had lifted and whether the pressure had reached the 21 code setpoint?
j 22 A
Yes, sir, by the strip charts you could 23 see what your peak pressure was.
24 Q
Now, on the day of the accident, did you
N
'25 consider the codes as a possible cause of the low
\\J
~
l-1 Scheimann 610 2
pressure and the high PORV outlet temperature?
O 3
MR. MacDONALD:
When you say the " codes,"
4 you mean the codes lifting on high pressure?
)
5 MR. WURTZ:
Anything 6
Q did you consider the codes in any 7
respect, in any way, in relation to those symptoms?
8 A
As best I can recall, I could use the PORV 9
to account for I mean the code safety to account 10 for the high pressure and the tail pipe initially 11 into the problem because we had been running with one 12 code safety that was slightly higher than the other 13 two valves.
h s_/
14 Q
Well, you knew that pressure was low, 15 in fact, the pressure was below the HPI setpoint 16 and you knew that PORV outlet temperature was high; 17 is that correct?
18 MR. MacDONALD:
At what point in time are 19 we talking about, on the day of the accident.?
20 Q
Did you know that at any point in the, s
21 first two hours?
22 A
I knew at one time that I had a high or 23 a higher than what was being recorded temperature on 24 the-tail pipes.
I don't recall at what particular I (')
25 time I knew that.
N)
I f
I l
4
I 1
Schaimann 611 2
Q Did you consider the codes as a possible 0('
cause of the low pressure and the high outlet 3
4 temperature on the PORV discharge line?
')
5 A
I knew that the PORV had cycled, so that 6
I knew that my parameters were going to show that 7
I had indications of the symptoms of a lifting PORV.
8 I also knew prior to coming in that day that we had 9
indication that o n 'e of the codes had a higher tail 10 Pipe temperature than the other codes and the PORV.
11 Hence, I would have thought it was possible that I j
12 would see a temperature for a longer period of time 13 hanging up higher as a result of the one code safety 14 valve.
15 Q
But you did not think that the codes had 16 been challenged on the day of the accident?
17 18 A
I don't recall having thought that the 19 codes had been challenged.
20 Q
So you are saying that you thought before 21 the accident that the codes had been leaking and you 22 thought that that ongoing leak was'having an effect 23 on the PORV discharge temperature; is that correct?
24 A
Yes, sir, I believe that was showing some
{~N 25 of our temperature, why we would account for some of v
i l
s
1 Scheimann 612 2
our temperature being up.
/~h
s /
3 Q
Is that'the only role that in your mind the 4
codes had in explaining the symptoms that you were
)
5 seeing?
6 A
As best I can recall, I believe that would 7
have been the case.
8 Q
Now, on the day of the accident, you 9
didn't consider a stuck-open PORV at all, as I 10 understand it, it never even crossed your mind?
11 A
Yes, sir, that's true, I didn't even think 12 about a stuck-open PORV.
13 Q
How did you explain the fact that the rh
( s) 14 pressure dropped down below the HPI setpoint?
u 15 A
I expected it to drop below the HPI 16 setpoint because the cause of the trip was high 17 pressure in the primary plant.
18 Q
Why would a high pressure trip produce 19 HPI, as you understood it?
20 A
Sir, I don't recall my understanding of 21 why the high pressure trip resulted in said conditions.
22 I just recall hearing that it had taken place beforep.
23 as a result of a high pressure trip, the PORV lifted 24 and dropped pressure down to the HPI setpoint.
25 Q
Did you also understand that in order for
4 1
Scheimann 613 2
a PORV lifting to do that, the PORV would have to stay 3
open during the entire time that the pressure was 4
dropping?
')
5 A
No, sir, I don't recall having that 6
understanding.
7 Q
How did you understand the pressure drop 8
came about?
9 A
Sir, I told you I don't recall what I 10 understood pertaining to how that pressure drop came 11 about.
12 Q
Well, you knew it couldn't be caused by 13 the PORV closing; is that correct?
I mean, once the 14 PORV closes, the pressure drop stops?
15 MR. MacDONALD:
You are asking for his 16 understanding now, not for him to draw any 17 conclusions today?
18' MR. WURTZ:
Yes.
l 19 A
Sir, as I mentioned, I don't recall what 1
20 my understanding was as to the cause of that pressure
. 21 drop.
22 Q
This is the pressure drop on a high Z3 pressure trip you are referring to now?
Is that 24 correct?
~
O 25 A.
Once the PORV had opened.
,)
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I 1
Scheimann 614 2
Q And you say you don't recall what you 3
understood would cause pressure to drop down to the 4
HPI setpoint?
)
5 A
That's what I said, sir.
6 Q
What did you understand were the possible 7
causes of a drop in pressure down to the HPI 8
setpoint?
9 A
Sir, I don't recall what my understanding 10 on that was.
11 Q
Let me ask that again.
12 It is your testimony that you don't recall 13 what you understood were the possible causes of a
_)
14 drop in pressure down to the HPI setpoint?
15 MR. MacDONALD:
Are you talking about 16 what transient could bring that about or what 17 instances?
18 Q
Did you understand that that could be 19 caused by a stuck-open PORV?
20 MR. MacDONALD:
Is that a question in,and 21 of itself?
22 MR. WURTZ:
Yes, that is the question.
23 A
I don't recall having that understanding.
24 Q
Did you understand it could be caused by
/"N 25 a LOCA?
k.
- =
l 1
Scheimann 615 2
A That would depend on the severity of the
\\/
3 LOCA, whether pressure would drop or not.
4 Q
But it could be caused by a LOCA?
')
5 A
A LOCA could cause reduction in pressure.
6 Q
Did.you understand there were any other 7
possible causes for a drop in pressure?
8 A
Over-cooling could cause a drop in 9
pressure, a cycling of a code or a PORV could cause 10 a drop in pressure.
11 Q
Did you understand before the accident 12 that a normal opening and closing of the PORV on a 13 high pressure trip would cause a drop in pressure to
- p) 14 the HPI actuation point?
15 A
I understood that in most of the cases 16 that that took place, we did have high pressure 17 injection actuation.
18 Q
In most of the cases where you had high 19 pressure trip, you are saying?
20 A
Yes, sir.
21 Q
And you don't recall any incident where 22 this happened that you can testify to; is that 23 correct?
24~
A Where what happened, sir?
/"N(
25 Q
Where you had a high pressure trip and Nj
I 1
Scheimann 616 i
2 a PORV cycling and a drop in pressure to the HPI
/}
l
~Y 3
setpoint?
4 A
I do not recall a specific time when that
)
5 occurred.
6 Q
You understood from your training at Met 7
Ed that you would get an HPI actuation every time there 8
was a cycling of the PORV; is that' correct?
9 A
No, sir, that is not what I said.
What I 10 said is most of the times I had heard about where they 11 had a high pressure trip, they ended up with a high 12 pressure injection actuation.
13 Q
Where did you hear about these?
(O) 14 A
I don't recall exactly where I had heard 15 about them.
I could have heard in talking to other 16 operators.
I could have heard in LER discussions.
17 It could have been from any number of sources.
18 Q
Did you understand that if the pressure 19 in the primary system continued to decline after a 20 time when the light was off, the PORV indicator light l
i 21 was off, that that was an indication that the PORV 22 was stuck open?
l
[
23 A
-No, sir, I don't recall having that t
l
- 24 understanding.
("]
25
.Q How could you exclude a stuck-open PORV V
'l 1
Scholmann 617 i.
2 in that situation?
M
'w /
3 A
It would depend on what was happening to 4
the plant.
t
')
5 Q
How could you exclude a stuck-open PORV
[
6 as a possible cause?
You know the PORV had opened?
7 MR. MacDONALD:
Are you asking him of any a
i i
8 situation prior to the accident where he i
g developed this understanding, if he had one?
i 10 MR. WURTZ:
Yes, his understanding.
t l
11 A
I don't really recall having seen a 12 situation prior to the accident where we did have the 13 PORV cycle and then after the PORV closed, pressure I
14 continued to drop.
t 15 Q
Well, you can understand things-that you 16 haven't personally seen, can't you?.
I am asking you i
1 17 whether you understood that if the light was off --
t j
18 you have a PORV cycling, the light goes off.
You see l
l 19 pressure is continuing to drop.
Does that raise the 20 question in your mind that maybe the PORV is still 21 open, maybe it didn't close?
.)
22 A
I honestly don't think that would have 23 raised that question in my mind at that particuiar gg time.
4
(~%
25 Q
And that is because the light was off?
V 4
1 1
Scheimann 618 2
A Yes, sir.
O(-
Q Now, to go back to this situation where 3
4 you have the three symptoms present, you have low
')
5 pressure, high outlet temperature and high drain tank 6
temperature.
In a situation where the light was off 7
did you understand that a possible cause of those 8
symptoms was a stuck-open PORV?
9 MR. MacDONALD:
I am going to object.
I 10 think we have been over this quite a few times.
11 Q
You can answer.
12 A
No, sir, I don't believe that those three 13 symptoms would necessarily indicate to me that I had
)
14 a stuck-upon PORV, especially if I knew that the 15 valve had cycled previously.
I would expect those three 16 symptoms.
17 Q
Now, if primary pressure is at 1100 and 18 PORV outlet temperature stays in alarm and the drain 19 tank temperature stays high, did you understand that 20 in that situation even with the light off, that a, 21 stuck-open PORV was a possible cause?
22 MR. MacDONALD:
I object to the form of the 23 question unless the witness had an understanding 24 of that particular situation prior to the
(~T 25 accident.
I. t is extremely hypothetical.
If 3
V
1 Scheimann 619 2
he had an understanding of that specific f\\
\\/
3 situation, I don't think there is even enough 4
information to answer it, but if he had an
)
5 understanding of that specific situation prior 6
to the accident, he can answer it.
7 Q
This is a way, Mr. Scheimann, of asking 8
you about how the system worked, and that is the 9
question I am asking.
Did you understand based on 10 your training in the way the system worked, that in 11 a situation where you had continuing low pressure 12 at a level below the HPI actuation point and where you 13 had a continuing PORV outlet temperature above the t()
14 200 degree alarm point and you had a continuing high 15 drain tank temperature, that a stuck-open PORV was 16 possible even in a situation where the light was off?
17 MR. MacDONALD:
I am going to object to 18 the form of the question again.
I don't think 19 it is clarified'enough as to how long continuing 20 low pressure or continuing PORV outlet t
21 temperature or high drain tank temperature 22 continued, what period of time we are talking 23 about, what the other parameters are.
I think i
l 24 now you are starting to deal in very hypothetical
('~)]
l 25 questions and areas.
I won't cut it off right l
I scheimann 620 2
now if he can answer the question but based on O(/
3 his understanding prior to the accident, but 4
I think it would be helpful if you clarify
)
5 the terms continuing low pressure and continuing 6
PORV outlet temperature and continuing high 7
drain tank temperature, continuing when, for how 8
long?
9 MR. WURTZ:
I will say 30 minutes, let's 10 take that.
I 11 MR. MacDONALD:
Did he ever have an 12 understanding of that situation prior to the 13 accident?
14 MR. WURTZ:
Well, no 15 Q
I am asking you did you understand 16 based on your. training that in that situation, a
'17 stuck-open PORV was a possible cause?
18 MR. MacDONALD:
And the situation is 19 where you had continuing for 30 minutes a 20 low pressure situation, low pressure below the 21 HPI actuation setpoint 22 MR. WURTZ:
I already did that.
23 I
MR. MacDONALD:
No, you haven't.
You 24 said pressure was 1100 pounds, then you changed
~'
25 that to continuing low pressure.
l
l 1
Schoimann 621 2
MR. WURTZ:
I will do it again to make
.r k')\\
3 it easier.
4 Q
Based on your training, before the i
)
5 accident did you understand that in a situation where 6
at a point 30 minutes into a transient where you had 7
pressure below the HPI actuation point, PORV discharge 8
temperature over the alarm point of 200 degrees i
9 Fahrenheit and a high drain tank temperature that a 10 stuck-open PORV was a possible cause of those symptoms 11 even when the PORV indicator light was off?
12 A
No, sir, I don't recall having that i
13 understanding simply by nature of the fact that g,1 14 whenever we did a PORV transient on the simulator, 15 it was never carried out for an excessively long period 16 of time.
Essentially, what had happened would be that 17 the cause would be so prominent that the valve had 18 malfunctioned that the operator was able to take and 19 jump right on it and clear the t ran sient immediately.
20 Also, we had never dealt with a situation that would 21 really portray those-specific symptoms that you had-22 mentioned.
23 Q
So now it is your testimony that you 24 were exposed to a stuck-open PORV transient on the
{v"'
25 simulator; is that right?
t y
_,.._,.___.,,%,.7
_.-7 r
y__._
-,-m.
1 scheimann 622 2
A Essentially, yes.
I myself may not have
/,'
' ( >)
3 been participating in it.
At the time I was in 4
training down on the-simulator, we were generally
)
5 broken down into groups of people and one group might 6
not -- well, one group might participate in a set 7
number of casualties while another group would 8
participate in other casualties.
9 Q
Well, you were just making that testimony 10 about it so what was that based on, were you standing 11 there watching or what were you doing?
12 A
What I was basing that on primarily is j
13 I may have heard of other groups that had that O
(_)\\
14 transient on the panel.
I would not necessarily 15 have reached each and every transient as the 16 controlling operator.
i 17 Q
You just gave testimony about what had 18 happened on the simulator and I am asking you what i
19 that was based on.
20 A
That may have been based on hearing what 21 some other people had had happened on that particular 22 transient.
23 MR. WURTZ:
Could you go back and read 24 that answer.
h>
25 (Record read.)
~-
l
~
l 1
Scheimann 623 2
Q We just had your answer read back and you
- 3 just heard that you testified, "...whenever we did 4
a PORV transient on the simulator..."
5 Did you hear that?
6 A
Yes, sir.
7 Q
Now, what was that testimony based on?
8 Who is "we," is that you?
I g
A That "we" could have been either myself 10 pe rsonally having done the transient or it could have 11 been some other operator performing the transient and 12 then we discussed it afterwards.
' 13 Q
one way or the other, you were exposed to 14 such a transient on the simulator; is that correct?
15 A
I would have to say yes, one way or the 16 other, whether I was involved in the discussion on 17 it or whether I was involved in actually performing 18 the transient.
19 Q
You mean either you did it yourself or 20 one of your fellow operators told you about doing it; 21 is that correct?
22 A
I would have to say yes.
23 Q
Now, you said in that situation you learned j-24 that the cause was prominent.
What was the cause?
i e~s 25 How did you diagnose it in those situations on the
~
l l
1 Scheimann 624 2
simulator?
l\\/
3 A
I don't recall what they exactly did at 4
that particular point on the simulator.
)
5 Q
Well, you said that the cause was prominent.
6 What cause?
7 A
The fact that the valve had stuck open.
8 Q
What was prominent?
9 MR. MacDONALD:
I object.
I think he just 10 answered the question.
11 Q
What were you talking about in your 12 testimony about three minutes ago when you said the 13 cause was prominent?
)
14 A
That the valve was stuck open.
15 Q
How did you tell that?
16 MR. MacDONALD:
Are you asking now a 17 specific situation that he recalls, how did he 18 tell, if he can recall a specific situation, 19 how the valve was stuck open?
20 MR. WURTZ:
I am asking him what he based 21 his testimony on that he gave two minutes ago.
22 A
I don't recall the exact means that 23 was used to determine that the valve was stuck.
24 Q
But it was diagnosed immediately; is that 25 right?
1-scheimann 625 2
A As best I can recall, it was found rather l'~)
(,/
3 quickly.
4 Q
And the operator closed the block
)
5 valve to stop the transient; is that right?
6 A
I am not sure what action went on after 7
that particular time when he confirmed it was a 8
stuck valve.
9 Q
Was there any other way that you know of 10 for stopping a stuck-open PORV transient other than 11 closing the block valve?
12 A
No, sir, I don't have any other 13 recollection of another way.
)
14 Q
And now it is your testimony that you 15 don't recall what was looked at in making this 16 immediate diagnosis; is that correct?
17 A
I don't recall what the particulars were 18 involved in that particular situation.
19 Q
Do you know if the operator looked at the 20 quench tank pressure?
21 A
I don't recall, sir.
22 Q
Do you know if the operator looked at the l
23 PORV outlet temperature?
24 A
I don't recall what was used to determine 25 that the valve was stuck.
\\-
I 1
Scheimann 626 2
Q Did you understand that one way of telling b
k >'
3 whether the PORV was stuck open was to close the 4
block valve and see?
Did you understand that before
)
5 the accident?
6 A
I have no recollection that I would hava 7
closed the block valve just to see if the PORV was 8
sticking.
9 Q
Did you know that that was one way to 10 diagnose whether the PORV was stuck open?
11 A
No, sir, I don't recall having used that 12 as a diagnostic tool.
13 Q
Did you understand that it was possible g_)
14 to do so?
15 A
I don't recall having an understanding 16 that we that that would be a possibility of doing --
17 that they can diagnose it.
18 Q
How do you close a block valve, what steps 19 are involved?
20 MR. MacDONALD:
Prior to the accident?
21 Q
Yes, you were standing there at the panel 22 at the intersection of panels 3 and 4.
If you wanted 23 to close the block valve, what would you have to do 24 from where you were standing?
(y 25 A
They have an open/close switch right in
\\,J
_ _ ~.. _... _,
h 1
Scheimann 627 2
front of you on the panel.
' t 3
Q Is it right in front of you?
4 A
Yes, it would be in the area where I was
)
5 at.
6 Q
What did you do, reach up and flip a 7
switch?
8 A
It is not a toggle switch.
It is a 9
switch that you have to turn.
10 Q
So you would just reach up and turn a 11 switch; is that it?
12 A
Yes, and that would close the block valve.
13 Q
Did you know before the accident that r
s_)
14 after a reactor trip in a situation where you had 15 symptoms consistent with a possible stuck-open PORV, 16 it would not hurt to close the block valve?
17 A
No, sir, I did not have that understanding.
18 We would normally not close the valve because you 19 were always concerned about the point that you might 20 have a problem with that valve.possibly not being able 21 to reopen it upon doing that test and then you would 22 lose that pressure control that you had.
l 23 Q
Had it ever stuck shut before?
i l
24 A
I don't have a recollection of whether it
(
25 did or not.
ws i
t l
__~__1._,_______ _ _. _. _ _ _
.. c
l 1
Scheimann 628 2
Q You can't identify any time when it did?
f~,
- k 3
A I can't identify a time, no.
4 Q
And you are not aware of any specific
')
5 time when it did stick shut?
6 A
I don't have a recollection of a specific 7
time.
'8 Q
Other than this concern that it might stick 9
shut, is there any other harm associated with closing 10 it?
11 A
Other than the possibility of the valves 12 sticking, I don't recall having an understanding of 13 any situation one way or another that would be
(-,J
)
14 harmful or not harmful about closing that valve.
~
G 15 Q
Do you know Mr. Frederick?
16 A
Yes, I know Mr. Frederick.
17 Q
Mr. Frederick on April the 6th, 1979 18 testified that before the accident, the block valve 19 wasn't closed even though the outlet temperature was 20 high, that Met Ed had indicated the reason for this 21 was the valve might stick shut, and he said that*,
22 "that sounded like a screwy argument."
i, 23 Do you agree with him?
'24 MR. MacDONALD:
I object and will not l
(~N 25 let him answer unless you show him the testimony
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I 1
Schsimann 629 2
and let him read the surrounding questions and r'%
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3 answers.
I don't think it is proper to ask 4
somebody about the testimony of another
)
5 witness without showing him what the testimony 6
was.
7 Q
I am going to read you a question and 8
answer from Mr. Frederick's testimony of April 6, 1979.
9 The question is, "Did RC-RV-2 ever 10 stick open before?"
d 11 The answer is "A valve has been leaking for 12 weeks.
We had a leaking relief valve but we weren't 13 doing anything about it.
It was either one of the I(,j 14 tuo code safety valves or RC-RV-2.
Prior to the 15 accident, we didn't want to cycle the isolation valve 16 (RC-RV-2) because we were afraid it might stick shut.
17 It sounds like a screwy argument to me.
I think they 18 should have shut it anyway to see if they could stop 19 the leaking.
I know for weeks we had to process a-20 lot of water and had difficulty keeping boron 21 concentration equalized in the primary system."
~22
' MR. MacDONALD:
Do you want to show him 23 the testimony?
24 Q
It is right there at the bottom.
Do you (v) 25 see it?
Do you see that testimony, Mr.. Scheimann?
h' i
1 Scheimann 630 m
2 A
Yes, I see that particular statemon_t down
' '/
5 3
there.
l 4
Q Do you disagree with that opinion
)
5 expressed by Mr. Frederick?
6 MR. MacDONALD:
I am going to object to 7
the form of the question and instruct him not to n
8 answer.
If you are dealing with his t
9 understanding today, _he wasn't at'the particular 10 interview.
He has no idea 1what Mr. Frederick 11 meant when he' testified.
If you want to ask 12 him separate an d ap. art ~ from,'thi,s what' his 13 understanding was in that situation, fin a.,
but 14 I am not going to let you ask questions about 15 testimony when he wasn't even there.
16 Q
Did you have the v'iew before the accident 17 that it was a screwy event?
18 MR. MacDONALD:
I am going to object to 19 the form of the question'-because I don't knov 20 what you mean by " screwy event," and I think if
' 21 it is. directed to what Mr. Frederick said, that 22 there is no basis for that question.
23 Q
Did you understand that the possibility l
24 that the block valve might stick shut was not a very 1
/
25 good reason for not closing the block valve when you h.,
I.
i I
~
1 1
Scholsonn 631 2
thought a stuck-open PORV mioht be present?
f'N 3
A I do not recall having formed an opinion 4
one way or the other in that particular type
)
5 situation.
6 Q
But you understood before the accident 7
that if a stuck-open PORV was possible, the fact that 8
the block valve might stick shut is no reason not to 9
try the block valve, did you not?
10 A
I do not recall having even considered 11 that particular situation.
12 Q
You understood that an open PORV involved 13 the loss of coolant, didn't you?
(_j 14 MR. MacDONALD:
What are we talking about 15 now?
16 MR. WURTZ:
In the case of a stuck-open 17 PORV, he had a loss of coolant going on.
18 Q
Is that such a difficult question, 19 Mr. Scheimann?
Isn't it obvious when the PORV is 20 open you have a loss of coolant going on?
Why does 21 it take several minutes to respond to that?
22 MR. MacDONALD:
I object to that 23 characterization.
24 MR. WURTZ:
If it is not simple, tell me.
("T 25 MR. MacDONALD:
We have already been
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Scholmann 632 a
2 through this ground.
s 3
MR. WURTZ q That's right.
4 MR. Ma c DO!!ALD :
There is no reason to
] ' ~'
5 ask a question that has already been answered.
6 s perfoNtly proper for a witness
~
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s to' sit ther'e and think what his recollection 7
i 8,
and understanding s'was at a partic'Ilar time, I.
L 9'
an'd if you are s ayin g' that a witness can't do
- t g,
8 10 that, I think that is totally isproper for an 11 dxaminer to do.
It la totally proper for the
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s 12 witness to sit there and think abouta que stion i
6 1
4
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13 and formulate an answer to your question and I t
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,{4 thir.k that is exactly what't,he wite.ess was 7
i l
doing.
3 15 s
in 4,
l 16 MR. N U R T 3.*-
I was just as}finq as a matter 17 of curiosity' wh th t questiondabso complicated v
18 and so. difficult.
It is very puzzling that
/
(
N is a licensed operator has io sit there and look J-
. ~
20 puzzled about a question about whether a stuck-open PORV involves a LOCA.
This man has told 31 3
N 22 the NRC and has told the public that he can 23 operate a nuclear reactor safety.
It is curious
=
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h 24 and outrageous t
- "~'3.,
s-25 MR. MacDONALD:' If you are going to start
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1 Scheimann 633 l
2 that, we are going to stop right now.
Your l
4 3
questions are fine.
His answers are fine.
But 4
4 don't start berating the witness for sitting
)
5 here and taking the time to answer your 6
questions to the best of his recollection.
7 You are dealing with his recollection, not his 8
understanding today.
Just ask the questions t
9 and don't make comments on the record as to 10 whether or not it takes 10 seconds, 20 seconds, 11-40 seconds to answer the question or he answers 12 it right away.
That is no concern of anyone.
13 MR. WURTZ:
I think that is a concern 1
(
14 and that is why I noted it.
15 MR. MacDONALD:
It is not a concern.
j 16 If you wanted a general practice in all 17 depositions that every time a witness pauses a
18 before he answers a question, for that pause and 19 the length of that pause to be noted on the f
20 record, we could have started that a long-time t
21 ago, and the judge doesn't care one iota about
]).
22 that and that is why-it is not recorded in l
23 depositions.
24 MR. WURTZ: -When a licensed operator of a
.'(s) 25 reactor sits here and puzzles whether he
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1 Schsimsnn 634 2
understood a stuck-open PORV involves a loss 3
of coolant, it is worthy of note.
4 MR. MacDONALD:
It is not worthy of note.
(
)
5 I object to the question.
6 BY MR. WURTZ:
7 Q
I will put the question again.
8 Did you understand before the accident 9
that a stuck-open PORV involved a loss of coolant?
10 A
Sir, as best I can recall, a stuck-open 11 PORV would not necessarily result in a loss of 12 coolant.
A stuck-open PORV under proper conditions 13 would cause water to go into the RC drain tank, which n
(_
14 in turn was returned to the bleed holdup tanks, 15 which is part of the volume inventory control in the 16 system.
Now, if the PORV was leaking and pressure 17 built up such that you had a relief into the building, 18 the relief lifted onto the drain tank or the rupture 19 disk went, I would at that time possibly consider 20 that you could have lost some coolant overall, 21 Q
Did you understand that even before that, 22 I mean you have a -- is a stuck-open PORV a hole in 23 the primary system, in effect?
24 A
Again, I would have to say it would f, ')
25 depend on the circumstances.
If it was such that the j-a.
y
1 Scheimann 635 2
inventory was not lost but maintained in the volume
(
3 control system as well, I would not have considered 4
that to be a hole in the primary plant as long as I
)
5 could replace the fluid.
6 Q
Coolant was going out of the primary 7
system and coming back into the primary system 8
through the makeup system, is that correct, in that g
situation you are talking about?
10 A
Yes, the makeup system would continue to 11 add water to the primary to compensate for it.
12 Q
So coolant was being lost and then i
13 coolant was being replaced; is that correct?
O k
14 A
The coolant was not being lost, it was 15 being transferred to the volume control system.
16 Q
It was leaving the primary systen, though, 17 there was some abnormal pathway for coolant out of 18 the primary system; is that correct?
19 A
There would have been fluid leaving the 20 primary system and there would have been fluid coming 21 into the primary system via the makeup system.
).
22 Q
Now, in a situation where you understood 23 that a stuck-open PORV was a possible cause for 24 symptoms including low pressure, did you understand
/~T 25 that the possibility that the block valve would stick h
, - - -,, -,, ~
~
~
l 1
Scheimann 636 2
when you closed it was not a reason not to close the 3
block valve?
4 A
Can I have that one more time, please?
')
5 Q
Did you understand that in a situation 6
where you saw in the system symptoms consistent 1
7 with a stuck-open PORV even though you could not 8
conclude absolutely that it was a stuck-open PORV, 9
that you should close the block valve?
10 A
No, sir, I don't recall having the 11 understanding that I should close the block valve 12 just because I had the symptoms.
13 Q
Did you understand that the system could N*
14 be run and could even be critical if the PORV closed?
15 A
Yes, sir, it would be normal that the 16 system would be running with the PORV closed.
17 Q
Excuse me, with the block valve closed, 18 did you understand that the system could run and be 19 critical with.the block valve closed?
20 A
I don't recall having that understanding.
21 Q
Was it your understanding before the 22 accident that in order to run the reactor you had to 23 have the block valve open?
l 24 A
Sir, I don't have a recollection of'whether 25 I had that understanding or not.
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Scheimann 637 2
Q Did you understand that the purpose of
\\/
the PORV was to prevent a reactor trip in certain 3
4 high pressure situations, that is, that it allowed
)
5 a runback and relieved pressure before a trip could 6
occur?
7 A
I had had the understanding that 8
theoretically the valve was there to give you initial 9
pressure protection.
However, il most cases that I 10 had ever heard addressed, once the valve lifted 11 we generally did get up the pressure enough to get 12 the reactor trip.
13 Q
Did you understand that the purpose of sj 14 the PORV was to avoid unnecessary trips by relieving 15 pressure before it got to the reactor trip setpoint?
16 A
I don't recall whether I had that 17 understanding or not, to tell you the truth.
18 Q
Did you understand that in a situation 19 where the block valve was closed, the codes would 20 be there to protect the system against 21 overpressurization?
22 A
Sir, I don't recall having dealt withthe 23 fact that if we had a PORV isolation valve closed 24 and what would be expected to relieve pressure, what f'J 25 would be expected.to happen as a result of that valve 4
4..
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l 1
Scheimann 638 2
being closed.
('M N
3 Q
Well, you knew there were codes there on 4
the system?
)
5 A
Yes, sir, I knew there were codes.
6 Q
Did you understand that those codes 7
would still be there even when the block valve was 8
closed?
9 A
I understood, sir, that those codes were 10 not isolable.
However, I never dealt with a 11 situation or I don't recall having discussed the 12 -
situation of when the bicek valve was closed what 13 would happen.
14 Q
Did you understand from your training 15 that the codes would still be there to relieve 16 pressure even when the block valve was closed?
17 A
I understood, sir, that the codes would 18 be available to relieve pressure.
However we never y
19 discussed, as best I can recall, what would happen 20 with the block valve shut.
The codes, as I pointed 21 out, are unisolable so you would still have. the codes 22 available to lift. yes.
However, we did not get 23
. into discussions about operations with the PORV block 24 valve shut.
/N 25 Q
Did you in fact decide on the day of the U
l
'l Scheimann 639 t
1 2
accident at or about the time Mr. Mehler arrived O
\\l 3
that it wouldn't hurt to try closing the block valve?
.4 A
Once Mr. Mehler directed me to close it, i
)
5 I went and closed it.
I don't know that I thought 6
it wouldn't hurt, one way or the other, at that 7
particular time but upon being directed to close' it, 8
I did close it.
9 Q
What was the basis for doing it?
10 A
Sir, I don't recall having formulated an 11 opinion as to whether it would have hurt to close it 1
12 or not.
All I recall is that Mr. Mehler suggested 2
13.
that I close it and I closed it in compliance with 14 his request.
i 15 Q
.You don't recall that you decided it 16 wouldn't hurt to try it?
17 A
Sir, I don't have a recollection of forming 18 an opinion at that time as to whether it would have
!i-19-hurt to try it or not.
20 Q
What was the reason for closing-it?
21 MR. MacDONALD:
Whose reason?
He just 22
~
said he didn't have one.
23
-Q Your reason.
24 A
My reason, I was directed or requested to O
25 close it.
-,.. -. _. _ _.. _. _ _ _, _,. _.. _ _ _ _. _. _... _ _ _,. ~ -
~
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Schsimenn 640 2
Q That was your only reason?
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3 A
At the time, that's all I thought.
4 Q
Did you disagree with it?
')
5 A
I don't have a recollection of whether I 6
agreed or disagreed at the moment.
7 Q
Did you say to Mr. Mehler, " Hey, it might 8
stick shut"?
9 A
I don't recall having made any comment 10 to Mr. Mehler except going to close it.
11 Q
So you didn't say to him, "I don't know 12 whether we should do this, this block valve might 13 stick shut," you didn't say that in substance to him
()
14 at any point; is that it?
15 A
I don't have a recollection of having 16 said such.
17
'Q Do you recall thinking that?
18 A
I don't have a recollection of thinking 19 that either.
20 Q
Did you say that to anybody at that time 21 when the block valve was about to be closed, to any
)
22 of your fellow operators?
23 A
No, sir, as best I recall, I don't recall 24 having made a comment to that effect.
t
(g 25 Q
You said nothing about the possibility
%)
I
I scheimenn 641 2
that the block valve might stick shut, you didn't
,.,\\
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3 even interject that idea into the discussion at all?
4 A
I don't have a recollection of having
)
5 done so.
6 Q
Did anybody else?
Did Mr. Zewe 7
or Mr. Frederick or Mr. Faust say to you or to 8
Mr. Mehler, "Maybe we shouldn't do this.
The block 9
valve might stick shut"?
10 A
I don't have a recollection of whether 11 somebody else might have said it or not.
12 Q
Did you have any reason at the time
-13 Mr. Mehler arrived for closing the block valve that j
14 you did not have at 4:30, 30 minutes into the 15 transient?
16 MR. MacDONALD:
Could I hear that 17 question again.
18 Q
The question is, did you have any reason 19 at 6:15 for closing the block valve that you did not 20 have at 4:307 21 A
Yes, sir, Mr. Mehler suggested that I try 22 closing it.
23 Q
Was there any other reason?
24 A
I don't have a recollection of another
(g 25
. reason involved for why I closed it at that V
I 1
Scheimann 642 2
particular point.
[\\
\\/
3 Q
What did he say to you?
4 A
I don't remember the exact substance,
)
5 but it was to the effect "Why don't you close the 6
block valve."
4 7
Q Did he say there was no harm in trying 8
it?
9 A
I don't have a recollection of the exact 10 wording that took place.
11 Q
Did you find this to be a puzzling 4
12 suggestion?
I mean, you were sitting there for two 13 hours1.50463e-4 days <br />0.00361 hours <br />2.149471e-5 weeks <br />4.9465e-6 months <br /> and 15 minutes and the stuck-open PORV never
" ('s
(_)
14 crossed your mind and now he walked in and he ordered 15 you to close the block valve.
Did this strike you 16 as a puzzling suggestion?
17 MR. MacDONALD:
I object to the form i
18 of the question.
i 19 A
I don't really have a recollection of 20 being puzzled at his request.
J 21 Q
Well, did you find it, consider it a 22 natural and reasonable thing for him to ask you to do?
- 23 A
I don't really have a recollection of 24 what my thought.was at that particular time.
/^T 25 Q
Did you agree with his suggestion?
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1 Scheimann 643 2
A Sir, I believe I already answered to the
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3 fact that I don't recall having agreed or disagreed 4
one way or the other.
)
5 Q
Mr. Scheimann, I would like you to look 6
at what has already been marked as Exhibit 537, 7
which is testimony that you gave to the President's 8
Commission on July 25, 1979.
9 I would like you to look in particular 10 at the testimony you gave on page 189.
11 I would like to read a series of questions 12 and answers to you beginning in the middle of that 13 page.
O)
(
14
" Question:
Were you in the control room 15 when the PORV was discovered to be open?
16
" Answer:
Yes.
I myself isolated the valve 17 on direction from another supervisor who had come in 18 fresh and thought he had spotted what might possibly 19 have been a problem, 20
" Question:
And who was that?
j i
21
" Answer:
I believe that is Brian Mehler.
22
" Question:
And he directed you to close 23 the safety valve?
,~
l l
24
" Answer:
He suggested that I try closing l
(]s 25 the safety valve and see if that stopped the problem.
l N-
I 1
Scheimann 644 2
" Question:
And did he explain to you why?
A 3
" Answer:
At the time, again, things were
~
4 hectic, and I don't recall anybody giving any long,
)
5 in-depth explanations of why we were doing much of 6
anything.
7
" Question:
Did you agree with him?
8
" Answer:
I thought it wouldn't hurt to 9
try it, at which time I closed the isolation valve, 10 and pressure started coming up again."
11 Mr. Scheimann, does that testimony refresh 12 your recollection that when Mr. Mehler came in and 13 gave that instruction your thought was that "it r(,\\/
14 wouldn't hurt to try it," closing the block valve?
15 A
That is testimony that I had given at 16 one hearing or another and according to what I had 17 said there, I had said that I didn't think it would 18 hurt to try.
L
[
19 Q
Did you have any reason to think at 20 6:15 that it would not hurt to try closing the block 21 valve that you did not have at 4:30?
22 MR. MacDONALD:
Are you asking him if he 23 thought about it at 4:307 i
24 MR. WURTZ:
Yes.-
25 MR. MacDONALD:
You are assuming he thought
1 1
Scheimann 645 2
about it at 4:307 3
Q No, I am saying, can you give me any 4
explanation
~)
5 MR. MacDONALD:
You are not asking for 6
his present explanation now.
You are going to 7
have to ask him on the day of the accident 8
did he understand something.
9 Q
I am saying, is there any reason that 10 you can tell me why you thought at 6:15 it wouldn't 11 hurt to try it and did not think that at an earlier 12 time, let's say, 4:307 13 MR. MacDONALD:
I am going to object.
14 If you are asking for any reason that he can 15 think of today --
16 MR. WURTZ:
That is what I am asking.
17 MR. MacDONALD:
No, we are not going to 18 deal in what his understanding is of what he is 19 here to testify today about.
20 Q
What reason did you have at 6:15 for 21 thinking it wouldn't hurt to try-it?
22 A
The idea was suggested by a superior.
23 Q
After the block valve was c 1'o s e d, did you 24 conclude immediately that you had a LOCA going on 25 through the PORV?,
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Scheimann 645-A 2
A I. don't really have a recollection of what i
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my exact conclusion was at that particular point.
a l
4 (At this time, 12:30 p.m.,
a luncheon af) 5 recess was taken.)
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646 2
AFTERNOON SESSION n
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1:30 p.m.
4 F RE DE RI CK J.
S CHE I MAN N,
)
5 resumed.
~
6 EXAMINATION (continued) 7 BY MR. WURTZ:
8 Q
Mr. Scheimann, you testified earlier 9
today that you received training from Met Ed on how 10 the PORV indicator light worked and you described the 11 training you got and how the light worked.
12 Did you also receive training on how to 13 use the light?
14 A
In what way are you referring to there, 15 sir?
16 Q
What significance did you attach to it, 17 when to use it, how to use it, did you receive training 18 from Met Ed on that?
19 A
As far as the light indicator, we were 20 essentially told that if the light indicated, lit, 21 that the solenoid received power, then the valve i
22 would open.
Once the valve had completed its cycle 23 and the light was deenergized, the valve would be 24 closed.
(}
25 Q
So you were told in your Met Ed training
'% J
l 1
Scheimann 647 2
that when the light wsa off, the valve would be 3
closed; is that it?
4 A
Yes, I believe so.
)
5 Q
So is it correct that you were not told 6
by anybody at Met Ed in training that in a situation 7
where the light was off, it was possible to have the 8
valve stuck open, the PORV7 9
A I don't have a recollection of it, sir.
10 Q
And before the accident, did you 11 understand that in a situation where the light was 12 off, it was possible to have t. h e PORV stuck open?
13 A
I don't have a recollection of having that
)
14 understanding, sir.
15 Q
Do you recall that it was your 16 understanding before the accident that whenever the 17 light was off, the valve, the PORV would be closed?
18 A
As best I can recall, sir.
I l
19 Q
You were never told of any situation, as 20 you recall, by Met Ed where that would not be true?
21 A
I don't have a recollection of it.
l 22 Q
Did you understand before the accident i
23-that as far as diagnosing an open PORV was concerned, 24 you could disregard the symptoms that are identified
-/" N.
25 in the - pre ssurizer. f ailure procedure ?
~
l 1
'Scheimann 648 2
MR. MacDONALD:
I object to that.
3 I think we went through that for about three.
4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> this morning.
If you want to go back i
)'
.5 for another three hours this afternoon, you 6
are welcome to.
7 MR. WURTZ:
Do you want that read back?
8 THE WITNESS:
Yes, I would.
9 (Question read.)
10 A
Sir, what my understanding on that was, 11 was that if the PORV had cycled and the light went 12 out, we would expect to see those symptoms by nature 13 of the fact that the valve had cycled.
I would not, 14
.once I had indication that the light was out, I would 15 not necessarily go back and check all the other 16 symptoms.
17 Q
How were you taught at Met Ed to diagnose 18 a stuck-open PORV?
19 A
As_best I can recall, we talked about the' 20 pro ce dure for the stuck-open relief valve, which did 21 list things that would be indicative of a stuck-open 22 PORV.
23 Q
Anything else?
24 A
That-is the extent of what I recall as
/'N 25_
far as that particular area.
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Scheimann 649 2
Q You discussed the symptoms in the t
3 pressurizer failure procedure; is that it?
4 A
Yes, sir, on occasion we had talked about f
5 the symptems in the pressurizer failure procedure.
6 Q
And this was training for how to diagnose 7
a stuck-open PORV; is that correct?
8 A
It was training on the emergency 9
procedures that we had dealing with the pressurizer 10 system failures, which would have encompassed a stuck-11 open PORV among several other situations.
12 Q
What were you taught about how to 13 diagnose an open PORV7 14 A
If we had an open PORV, we would have the 15 light on that would be telling us that the PORV had 16 opened.
17 Q
You were taught that in training.
Were 18 you taught anything else at Met Ed?
19 A
That once the valve had -- once the 20 pressure in the system had reduced to below the 21 setpoint, we would lose the light and the PORV should 22 he shut.
23 Q.
Anything else?
24 A
We. reviewed the emergency procedure for
[~h 25 pressurizer failure.
m l
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I l'
Scheimann 650 i
2 Q
Did you review the symptoms in the 3
emergency procedure for pressurizer failure?
4 A
Yes, sir, at one time or another.
)
5 Q
Did you review the three symptoms we have 6
been talking about, the low system pressure, the high 7
PORV outlet temperature and the high drain tank 8
temperature and pressure?
9 A
Yes, sir, we did.
We also talked about 10 it in the sense that we could have gotten those 11 conditions from other than a stuck-open PORV.
12 Q
What use were you taught to make of those 13 symptoms in diagnosing a stuck-open PORV?
h) 14 A
We were taught that they were primarily
(_
15 a diagnostic tool and nothing more than that.
They 16 would be indicative of a condition existing.
If the 17 condition for a fact did exist, then we were trained 18 to use the emergency manual actions.
I 19 Q
How were you taught to tell if it did" 20 exist?
21 A
We were essentially taught more along the 22 line that if the light was not out, we could still 23 have those conditions and not have that exist.
We 24 were taught that just because you had the symptoms,
(}
25 it did not necessarily mean that you had that problem, s_-
I i
- - - - - -, - - - ~~
I 1
Scheimann 651 i
2 Q
Well, what were you told to do when you 3
got the symptoms?
4 A
That would depend on the nature of why
')
5 I got the symptoms.
If I knew the PORV had cycled 6
open, I would expe ct the symptoms.
I would not go 7
through and close the block valve under that 8
circumstance so I would not be carrying out my manual 9
actions.
10 Q
So you were taught that if you got those 11 symptoms in a case where the PORV had cycled, that 12 at least initially you would do nothing; is that 13 correct?
14 A
Initially, there was no call to do anything 15 because the symptoms were expected for the conditions 16 that had taken place.
17 Q
So how were you taught to determine if a 18 situation had arisen where the PORV had stayed open, 19 what means were you taught to use to tell that in 20 your training at Met Ed?
21 A
If the symptoms could not be pointed at as 22 being caused by some other reason or some other 23 effect, it could be assumed at that point that you 24 could possibly have had a stuck-open valve.
In'most
('h 25 -
cases that we had seen or I had seen or heard about V
l 1
schsimann 652 2
was a case where you usually could tell right away 3
if y u had another problem or another situation that-4 caused you to have those symptoms.
')
5 Q
S y u were taught to investigate the 6
cause of those symptoms; is that the procedure you 7
were told to follow?
8 A
Investigation in this particular case 9
might not take any exceptionally long period of time.
10 The cause could be evident before you actually see 11 the symptoms, in which case you would have the 12 reason, "ies, this is what caused my temperatures 13 to go up, this is what caused my pressures to go up.
(~)%
\\
(,
14 I know what caused the symptoms."
Therefore, 15 if the valve indicating light was shut and I had 16 those symptoms which would be expectable, I would 17 have no reason to believe that I had other than a 18 cycle of the valve.
19 Q
That is in the initial stage, that is what 20 you were taught, is that correct, for the initial 21 stage of a transient you would expect to have the 22 symptoms identified in the pressurizer failure 23 procedure; is that right?
24 A
I would expect to see them on a cycle of
(
25 the PORV.
l t
l 1
~.
_... _..., _. ~ _.,. _... _ _.
l 1
Schaimann 653 2
Q When you say the symptoms, what were you O\\_)
told to expect to see on a cycling of the PORV for 3
4 each of those symptoms?
')
5 A
I would see a decrease in RCS pressure 6
Q Let's go one at a time.
7 How far?
8 A
That would vary.
I couldn't come out 9
and say for a given situation I would expect to see a 10 given drop of so many pounds.
11 Q
For a normal cycling of the PORV, how 12 far did you expect pressure to drop or what were you 13 taught in your training at Met Ed?
)
14 A
In talking about some of the instances 15 that led to a PORV cycling open, in particular a 16 reactor trip due tc high pressure, it would not be unusuak to see the pressure drop down to the point of 17 18 the high pressure injection system coming on.
19 Q
That is what you were taught?
20 A
I had heard that from one point or another.
21 I can't say that I was verbatim taught that.
I don't 22 recall that I was verbatim taught that.
23 Q
How far down did you expect pressure to 24 drop from a normal cycling of the PORV?
/~T 25 A
Again, you can't really say a normal (v)
,..-r
1 Schsimann 654 2
cycling of the PORV, but in a case where the thing
[
j
\\/
3 had -- pressure had gotten up high enough to cause 4
that to lift, as I pointed out, I would not be
)
5 surprised to see it come down to the point where I 6
had high pressure injection.
i 7
Q Did you understand that the PORV would 8
open based on high pressure?
9 A
Yes, the PORV did have'a high pressure 10 setpoint.
11 Q
And then it had a low pressure setpoint 12 as well, did it not?
13 A
Yes, sir.
s,)
14 Q
Approximately what was that low pressure 15 setpoint?
16 A
I don't recall what the number was at 17 the present time.
18 Q
Did you know that it was above 2,000 19 psi?
20 A
I really don't recall what it was at 21 present, sir.
22 Q
Well, I ask if you understood that it was 23 above 2,000 psi?
24 A
Sir, I said I don't have a recollection f"h 25 of a number.
I am not just going to say, "Yes, I v
l 1
Scheimann 655 2
understood it was above a certain pressure" when I (3
3 don't really have a recollection of what the low
~
4 pressure was.
)
5 Q
You can't even come that close to it, 6
then?
7 A
I can't recall, sir.
8 Q
We went through this once before.
Your 9
Procedure shows that the icw pressure setpoint of 10 the PORV is 2205 psi.
r 11 Does that sound right to you?
j 12 MR. MacDONALD:
Are you asking if that 13 refreshes his recollection now?
14 MR. WURTZ:
Yes.
15 MR. MacDONALD:
Do you want to show him 16 that section?
17 Q
Does that sound right to you?
18 MR. MacDONALD:
Let's keep the question j
19 dealing with his recollection, not in the present l
20 sense of his understanding.
21 The question is, does that refresh his 22 recollection, 2205.
If you have something to show j.
23 him from the procedure, fine.
I have no problem 24 with that.
L 25 A
It might if I saw it, sir.
I really
l 1
Schsimann 656 2
couldn't say without seeing it.
O 3
Q But apart from that, you don't recall even
~
4 whether you knew that it was above the normal
)
5 operating pressure of the unit?
6 A
Sir, what I said was that I didn't recall 7
what the value was.
8 Q
That is why I asked you whether you knew 9
it was above 2,000 psi.
Do you recall that you knew 10 that?
11 A
Sir, I don't recall what the setpoint was.
12 Q
Well, that isn't what I asked you.
I 13 asked whether you recalled that you knew it was above
)
14 2,000 PSI.
15 A
I don't have a recollection that it was 16 necessarily above any set pressure.
17 Q
Did you have some kind of indicator on 18 the panel that showed you what the lower level 19 pressure setpoint was for the PORV?
20 A
I don't have a recollection of one, sir.
21 There may have been, there may not have been.
22 Q
I am looking at your pressurizer 23 operations, operating procedure, at figure 2,
which 24
'shows that the PORV opens at a pressure of 2255 and
(~'\\.
25 it closes at a pressure of 2205.
Is it fair to say h.
_____m
__-.___._n.--__
I 1
Scheimann 657 2
that you were aware of that, those numbers, on the
[k
\\/
day of the accident?
3 4
MR. MacDONALD:
Do you want to show him
)
5 that particular document?
6 MR. WURTZ:
Well, I am representing that 7
is what it says.
I mean, what is the point?
8 Q
I am asking if you were aware of that.
9 A
Gir, on the day of the accident I did 10 know what the setpoints were of the valve.
I merely 11 don't recall what they were at the present time.
12 Q
Now, did you understand that when the s
13 low pressure setpoint of the PORV was reached, that rh (j
14 the PORV was supposed to close?
15 A
Yes, sir.
16 Q
Did you understand that any pressure drop-17 caused by the open PORV'would stop a t' t h a t point?
18 MR. MacDONALD:
I object.
This was 10 asked and answered this. morning at least twice.
20 We have been through it.
If you want to go 4
21 through it again, fine.
I just don't think 22 there is any ne.cessity to do that.
23' MR. WURTZ:
Could yoniread the question 24 back.
(}
25 (Question read.)-
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V f
A y'9 y
A 3
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I 1
Schaimann 658 2
A Sir, at the point where the valve closed, p) t
(_/
the pressure drop due to that valve being open should 3
4 stop.
1
)
5
/
Q Now, since in a normal cycling of the 6
PORV it would close at 2205, what did you understand 7
produced the drop in pressure down to 1640, which is 8
the HPI actuation point?
9 A
Sir, as I answered this morning, I didn't 10 have a recollection as to what the cause of that 11 particular drop was.
2 12 MR. MacDONALD:
I object to the form.
13 Q
You never asked anybody?
i
's g_)
14 A
Not as best I can recall.
15 Q
You never discussed that with anybody?
i 16 A
I don't have a recollection of it.
k You had a pressure drop for no known 17 18 reason and you never asked a question?
i 19 MF N gDGNALD:' I object to the form.
20 A
2 it. ' - have a recollection of whether I 21 did or did not ask.
22 Q
But as you recall, you didn't know of 23 any reason why pressure would continue to drop after 24 the PORV closed; is that right?
f~N 25 MR. MacDONALD:
Are you talking about a q,.
3s
-- y i_ -
1 Scheimann "3
s g
659
+
e 1
'N 2
situation no,w.., h e :- e it is just a reactor trip, w
s (h
fx [
is thNt,what'we are dealing with, no other 3
w 4
transient or cause for that reactor trip?
5 MR. WURTZ:
The PORV opened on a high 6
(,
pressure' trip.
_~
s '
7 Ar If the PORV opened with no outside 4,
8 infiuence, at the Yime the PORV closed the pressure 9
dr,op should stop.-
5_
t
.(
3
~
10 Q
Now, you say that you understood before 11 the acciden$ that one of the symptoms of a normal s
x drop in pr'imary 12 n; cycling of the PORV could be a i
s s
s 13 pressere ill the way to the HPI actbation point; is
[
14 that'right?
m, s
x
'N.
e 15 A
That's right, we had seen pressure as low x
16 as thefHPI injection point.'
s s
s i
17
'Q From a normal cycling of the PORV?
s s
s 18 A
Sir, agair., the term " normal" is misleading.
s s
\\
^
19 From a cycling of the--PORV we had seen that condition.
s
\\
20 Q
And you don't have uny Eecollection of 21-what caused that condition?.
)
22 A
Sir,.that's what I had said.
^
23 Q
So based on-your training at MeY Ed[and 24 your experience as of the tiime of the accident, a drop l
~
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f'\\
25 in' primary pressure to the HPI actuation point could t
Q)
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Scheimann 660 2
be explained by a cycling of the PORV?
0s i
3 A
The condition had arisen in more than 4
one instance.
)
5 Q
With nothing else, just a cycling of the 6
PORV?
7 A
As best I can recall, yes, sir.
8 Q
And you say that as of the day of the 9
. accident, you understood that that had happened 10 before?
3.
i 11 A
As best I recall, yes.
12 Q
But you cannot identify when?
13 A
No, sir, I cannot identify a specific time.
4 14 Q
And you don't know who told you that?
15 A
No, sir, I do not.
F 16 Q
Do you know that somebody at Met Ed told 17 you that?
18 A
I don't recall who told me or where I 19 picked up that information.
i 20 Q
And as you understood it, this drop in 21 primary pressure to the HPI actuation point was not 22 associated with any other cause other than a cycling 23 of the PORV7 l
l 24.
A I don't have a recollection of another i
25 cause.
.~.-.,_-....,.,4
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,-,-.x
-..,, -, ~
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...+r.,-.-..
7,.,...
~
l 1
schaimann 661 2
Q So the first symptom in the pressurizer O
Y 3
failure procedure, the low reactor coolant system 4
pressure, you believed it could be as low as the
)
5 HPI point and you would still find that consistent 6
with the normal cycling.
7 Now, the question I have is, how long did 8
you understand pressure could remain low consistent 9
with the normal cycling?
10 MR. MacDONALD:
You mean below the 11 actuation point of HPI, now?
12 MR. WURTZ:
Yes.
13 A
That would depend on several factors.
O()
14 Q
What would they be?
15 A
It would depend on how much cold water 16 you had to put in the pressurizer by the high pressure 17 injection to raise the system volume back up.
It 18 would depend on whether the reactor coolant system 19 was cooling down in the normal post-trip manner.
You 20 could expect to see pressure hanging low for a 21 period of time de..ending on how much cold water you 22 were putting in.
23 Q
And in that event, the cause of the 24 pressure being low would be shrinkage, is that correct, r'}
25 in the primary system?
v
i l
\\
1 Schsimann 662 2
A One of the causes would be shrinkage,
("s
\\
the other would be that you are adding a cold volume 3
4 of water and it is going to take a while to build
)
5 that up to temperature.
6 Q
Isn't it correct that unless there is 7
shrinkage, adding water would increase the pressure?
8 A
Adding water will not necessarily result 9
in a direct increase in the pressure.
What we added 10 water to the system for by the high pressure injection 11 system was volume control, water inventory in the 12 system.
13 Q
Not pressure control?
(
14 A
No, sir.
1 v
15 Q
It didn't have anything to do with 16 pressure; is that it?
17 A
Sir, we primarily used high pressure 18 injection for water inventory control.
19 Q
Pressure wasn't important?
20 A
I didn't say pressure was not important.
21 What I said was the reason why we used high pressure 22 injection was for inventory control.
23 Q
Now, you said that pressure could stay 24 low because cold water was coming into the system.
l
[
fN 25 What I am asking is, does the low pressure
1 Scheimann 663 2
result from shrinkage occurring in the primary system?
O 3
A Indirectly,'it could result from shrinkage
~
4 due to the reduced temperature.
You might be cooling
)
5 down more rapidly than on a standard post-trip 6
cool-down.
7 Q
Did you understand that in a case where 8
the addition of cold water was producing the low 9
pressure, that primary temperature would have to be 10 dropping?
11 A
That would not necessarily be true.
12 Q
So as you understood it on the day of the 13 accident, could primary temperature be increasing q_j 14 when this low pressure from cold water was present?
15 A
As best I can recall, it could.
I could not 16 give you an exact set of circumstances which would 17 cause it.
18 Q
so as you understood it, you could not 10 exclude over-cooling by looking at the primary 20 temperature increasing?
l.
21 A
Again, it would depend on the severity of 22 the incident.
You could initially see an increase 23 in the temperature and then eventually have the 24 over-cooling come in to where your temperature does
("N 25 come down.
'\\_/
1 l
l m
y-w-
,g-e y y
+-e g
y
i 1
Schaimann 664 2
Q Now, what were you taught to do as far as
(_/
3 diagnosing an open PORV with a low reactor coolant 4
system pressure?
')
5 A
Sir, as best I can recall, in the reactor 6
coolant system, the reactor trip emergency procedure, 7
we had steps in there that said if pressure was 8
reducing, we would manually start an additional 9
makeup pump as necessary to maintain inventory in the 10 system.
11.
Q You say it says start of makeup pump to 12 maintain inventory; is that right?
13 A
As best I can recall.
It was based on a A()
14 decreasing level in the pressurizer.
15 Q
Now, what I am trying to just not to 16 get too far afield -- I am trying to understand what 17 you were taught to do to diagnose a stuck-open PORV.'
18 Let me try this again.
19 Why don't you tell me step by step what you 4
20 were supposed to do?
Did you know that a PORV could 21 stick open before the accident?
22 MR. MacDONALD:
I object.
We have been 23 through this for about three hours this morning.
24 You know you have gotten an answer to that
(~T 25 question and.a million others relating to this
'\\
~
l l
1 Scheimann 665 2
topic.
We can go on all afternoon relating t'~
(-)/
3 to that ground but I don't think that is very 4
fruitful for_ finishing this deposition.
I
~)
5 know you have gotten an answer to that and so 6
do you.
I am not going to instruct him not 7
to answer but I think you have exhausted moct of 8
the discussion on this topic.
9 MR. WURTZ:
We are in a subject here where 10 I have not exhausted it, and that is, what he 11 was trained.
12 Q
And the question is, what were you trained 13 to do at Met Ed to diagnose a stuck-open PORV7 g )
14 MR. MacDONALD:
My objection stands.
15 A
Sir, as I indicated before, we were trained 16 in the emergency procedure for the pressurizer failure, 17 pressurizer system failure.
We also had the 18 understanding that if we got the symptoms, in this 19 case the reduced reactor coolant system pressure, high 20 tempersture on the tail pipes and the temperature l
21 change and pressure change in the drain tank, if we 22 could account for the fact that we had opened the PORV, 23 that the PORV had cycled and if the light'was out, we 24 would attribute those symptoms to that PORV cycle.
i f
(N 25' Q
And on that basis, you would exclude, N.]
1 1
scheimann 666 2
you were taught you could exclude the possibility of
\\~'
a stuck-open PORV?
3 4
A Sir, as long as we had indication that
)
5 that valve, indication that the valve was closed, we 6
expected those symptoms and we would not proceed any 7
further.
8 Q
What I am trying to determine, then, is 9
how would you ever determine that the PORV was open, 10 since you expected all of the symptoms that are 11 identified in your procedure from a normal cycling?
12 If the light is off, how would you ever determine 13 that the PORV was open?
Are you basically saying there 14 was no way or what?
What were you taught on that?
C 15 MR. MacDONALD:
Taught on what?
You 16 just asked the question on what he was taught 17 and he gave you his answer.
18 Q
The question is, how do.you l
19 determine when the PORV is stuck open, what were you l
20 taught by Met Ed?
21 A
If that light for the PORV was indicating --
22 was out, I would have no reason to expect to think 23 I had a stuck-open valve.
I 24
.Q And you were taught that all of the
(j 25 symptoms in the pressurizer failure procedure would
\\_/
l 1
Scheimann 667 2
occur with the normal cycling of the PORV7 A
k~
3 A
Sir, all those symptoms would occur with 4
a cycling of the PORV.
~)
5 Q
So then, you would look at the light 6
and if you see that it is off, then you would exclude 7
the PORV as a possible cause; is that correct?
8 A
I had no reason to believe that the PORV 9
was not closed.
10 Q
Now, did you understand that the PORV 11 discharge temperature would go above the alarm point 12 from a normal cycling of the PORV?
-13 A
I understood that the temperature.on that 14 tail pipe could exceed the alarm point in the event 15 of a cycle.
16 Q
Did you understand that after the PORV had 17 closed, PORV discharge temperature could continue 18 rising?
19' A
Yes, sir, I did have that un de'r s tan ding.
20 Q
For how long could it continue r isin g ?,
i 21 A
I don't have a feel for the time but it
)
22 could continue rising.
i 23 Q
Did you understand that at some point 24 after the PORV had closed, that the PORV outlet 25 temperature would begin to drop?
1 Scheimann 668 2
A Sir, I had an understanding that eventually b)
\\.-
3 it would tend to drop off.
As far as how long it 4
would take, I don't.have a feel for that.
)
5 Q
Did you understand before the accident that 6
if the PORV outlet temperature was higher than the 7
code outlet temperature, that that indicated that 8
the PORV was stuck open?
9 A
No, sir, I do not recall having that 10 understanding.
11 Q
You knew befcre the accident that they were 12 all at about the same temperature; is that correct?
13 A
I recall that they were all at about the A
(
).
14 same temperature, with the one code valve being 15 slightly higher.
16 Q
Did you understand before the accident 17 that if the drain tank rupture disk burst, that that 18 was indication of a stuck-open PORV?
19 A
No, sir, I do not recall having that 20 understanding.
21 Q
Did you understand that a stuck-open PORV 22 was a possible cause?
23 A
I don't recall having an understanding 24 that that would be the case.
("}
25 Q
Now, since you were trained that the
\\_/
~
l 1
Scheimann 669 2
symptoms in the pressurizer failure procedure could
.. tO)
\\m 3
occur from a normal cycling, what symptons were you 4
trained to look at to determine when the PORV was in
)
5 fact stuck open?
6 MR. MacDONALD:
I will object.
7 A
Sir, as long as I had indication on my 8
panel that my light was out for the PORV, I had no 9
reason to believe that the PORV had stuck open by 10 nature of the fact that I would receive symptoms as a 11 result of the cycling of that valve.
i 12 Q.
The symptoms that appear in the pressurizer 13 failure procedure you understood could be produced by
-]'
14 a normal cycling and therefore they did not indicate f
15 the PORV was open; is that correct?
16 A
As long as my light indication was out, r-17 they would not have indicated to me that the PORV was l
18 stuck.
10 Q
Before the accident, did you understand i
20 that there was anything that could happen with those 21 three symptoms that would indicate to you that the 22 PORV was stuck open, was there any set of circumstances t
23 related to those symptoms that, as you understood it, 24 indicated the PORV was stuck open?
l l
(v~}
25 A
Sir, as long as I had been. aware that l
l
[
l 1
Scheimann 670 2
there was a cycling of that valve and that light
("N 3
was out, if I had those symptoms I would not think of 4
it as a stuck-open PORV.
)
5 Q
And so you would exclude a stuck-open PORV 6
even in a case where you knew, for example, that 7
the drain tank rupture disk had burst?
8 MR. MacDONALD:
Are you asking him if he 9
had that understanding prior to the accident?
10 Q
Yes, was it your understanding that even 11 in a case where the drain tank rupture disk burst, 12 that if the light was off there was still no reason to 13 believe that the PORV was stuck open?
14 A
I don't recall whether I had that exact 4
15 understanding or not.
16 Q
Before the accident, did you consider a 17 continuing high pressure and temperature in the drain 18 tank and eventually a burst of the rupture disk 19 in the drain tank to be consistent with a cycling of r
20 the PORV?
21 A
I don't have a recollection of whether I 22 considered that necessarily or not.
23 Q
Well, did you understand that that was
.24 consistent with the cycling of the PORV?
("N 25 MR. MacDONALD:
I think he has told you
\\_
e
1 1
Scheimann 671 2
his answer to that.
Ok-)
3 A
Sir, I don't have a recollection of whether 4
that was my understanding or not.
'}
5 Q
So it is possible that you thought that 6
was consistent with a normal cycling of the PORV, to 7
have the drain tank rupture disk burst?
8 MR. MacDONALD:
I object to the form of 9
that.
Are you saying it is possible in that 10 sense?
11 Q
Yes, I mean if that is what your testimony 12 is 13 A
I just don't have a recollection one way
()
14 or the other whether I thought that or not.
15 Q
Therefore, it is possible that you did 16 think that.
It is possible you did, it is possible 17 you didn't?
18 MR. MacDONALD:
I object to the form of 19 that.
20 A
- Sir, I do not have a recollection of 21 whether I thought that or not.
22 Q
You can't rule that out, though, as you 23 sit here today?
24 A
I can't recall whether I would have thought g-'
25 that or not, sir.
N.)g '
p 1
Scheimann 672 2
Q So you can't rule it out, is that correct,
\\-
3 is that your testimony?
4 MR. MacDONALD:
I will object.
He can
)
5 answer.
6 I think he has told you what his 8
7 understanding was but he can answer the 8
question.
9 A
I don't feel that I can answer that 10 question based on what my recollections at that time 11 were.
12 MR. MacDONALD:
What he is asking you, 13 Mr. Scheimann, is, if you don't have a O)
(
14 recollection one way or the other, you can't 15 rule it out, you can't rule it in.
That is 16 the same question as he is asking you.
17 A
Well, it is kind of hard for me to 18 speculate on something that I couldn't recall whether 19 I had an understanding or not.
20 Q
What I am asking you is basically whether-1 21 this is a piece of information or knowledge that you 22 know you can well, forget it.
23 MR. WURTZ:
Will you read me the last few 24 questions and answers.
f~N.
25 (Record read.)
s_)
l r
l 1
Scheimann 673 2
(Recess taken.)
\\-
3' BY MR. WURTZ:
4 Q
Mr. Scheimann, I have just a few
')
5 additional questions on what your understanding was 6
with respect to these symptoms in the pressurizer 7
-system failure procedure.
And what I want to know is 8
what you understood was consistent with a cy. cling of 2-9 the PORV.
As I understand it from your testimony, 10 that you considered a drop in pressure to the HPI 11 actuation point to be consistent with the cycling of 12 the PORV, is that correct, and that you testified to 13 earlier?
(_j 14 A
'In most of the cases that I had heard of 15 of a high pressure condition resulting in a reactor 16 trip, that is what we had seen or what had been seen.
17 Q
But you did not have any understanding 18 as to what was causing that drop in pressure?
19 A
I don't have a recollection at present of 20 having an understanding of what was causing it.
21 Q
Did you understand that if pressure 22 stayed low, below the HPI actuation point, that that
.23 was con sis ten t with a cycling of the PORV?
24 MR. MacDONALD:
Are you talking about for a i
25 period of time here?
-lN l-
1 1
Scheimann 674 2
MR. WURTZ:
For a period of time, yes,
(/
s s-3 continuing.
4 MR. MacDONALD:
We are dealing with the
')
5 same 30-minute time period you had stated 6
previously in some questions, or do you have a 7
different time period in mind?
8 Q
Well, let's take the 30-minute period.
9 A
Well, sir, I really have no recollections 10 based on a time frame in mind, but it would depend on 11 what was happening in the plant at the time that the 12 PORV had cycled as to whether pressure would tend to 13 stay down.
I\\
14 Q
But, in other words, a cycling of the PORV V
15 could not, as you understood it, produce a continuing 16 low pressure situation, is that correct, a cycling of 17 the PORV alone?
18 A
That in itself could still result in 19 pressure staying down, depending on what pressurizer
.20 level was prior to the cycling.
If you had been at a 21 lower pressurizer level, it is going to take more h
22 colder water to fill that, and I would have expected 23 pressure to maybe stay for a bit of time.
How long, 24 I couldn't really say, r
l gs 25 Q
But a. time period of 30 minutes would not L
i
.. ~.
I 1
Schsimann 675 2
have surprised you; is that correct?
tO
\\')
A Sir, I really can't recall a time frame 3
4 being discussed as to how long it would be before I
)
5 would be concerned.
6 Q
Well, what was your understanding?
7 A
Sir, what my understanding was, was that 8
it could conceivably stay down for a while.
I don't 9
have a feel for how long would be involved.
10 Q
For as long as 30 minutes?
11 A
Sir, I really don't have a feel for how 12 long I would expect it to stay down.
13 Q
For as long as an hour?
O)
(j 14 A
Sir, I really don't have a feel for the 15 time frame involved.
16 Q
Well, is there a time where you would reach 17 a point in time where you would be concerned?
18 A
I just don't have a recollection of the 19 time frame involved in that particular situation.
20 Q
But as you understood it, the pressure 21 could stay low for a considerable period of time 22 as a result of a cycling of the PORV?
23 A
Yes, based on what conditions you had l
24 along with it.
Or at a point at which pressurizer
~N 25 level would rise,.at what point in that level it had
~>
i l
l 1
Scheimann 676 2
cycled.
3 Q
Now, I am thinking of a situation where you 4
don't have an over-cooling to explain the low pressure.
)
5 Were you responding with that understanding?
6 A
No, sir, I was responding to that 7
particular question based on a low level in the 8
pressurizer just at the onset.
9 Q
Let me just define the situation.
10 You have a cycling of the PORV, pressure 11-in the primary system has dropped below the HPI 12 actuation point and it stays below the HPI actuation 13 point.
There is no over-cooling going on.
You have O)
(_
14 determined that.
15 Did you understand that such a situation 16 was consistent with and could be caused by a cycling 17 of the PORV?
18 MR. MacDONALD:
Are you asking for his 19 understanding of the situation as you described 20 it prior to the accident?
I 21 MR. WURTZ:
Right.
I 22 -
A Prior to the accident, I had never seen a 23 condition similar to that that I can recall, so I l
l 24 really don't know that I would have necessarily had i
l
- ('g}
25 that understanding.
s-
i 1
Scheimann 677 2
Q Well, you say you had heard of a situation
.O)
\\'
3 where a cycling of the PORV led to HPI actuation?
4 A
Yes, sir, I had heard of conditions such as
)
5 that.
6 Q
And as you understood it, such a situation
~
7 even when there was no over-cooling involved could be 8
consistent with a cycling of the PORV?
9 A
In most cases that I heard of, we had had 10 high pressure injection or I had heard of high 11 pressure injection on the cycling of the PORV.
l 12 Q
Did you know that there was no over-cooling 13 present when that occurred?
()
14 A
I don't have a recollection of whether 15 there was an over-cooling situation with it or not, 16 sir.
17 Q
Before the accident, did you understand 18 that in a situation where there was no over-cooling, 19 a normal cycling of the PORV could not produce an HPI 20 actuation?
21 A
I do not recall having that understanding.
22 Q
And as you understood it before the accident, 23 a continuing low primary pressure below the HPI 24 actuation point was also consistent with a normal
('N 25 cycling of the PORV?
\\..
~
'l 1
Scholmann 678 2
A Sir, that is not what I had said.
What
(
3 I had said was it could occur with a cycling of the x
4 PORV, depending on plant conditions.
')
5 Q
For it to occur with the cycling of the 6
PORV, did you have to have over-cooling present?
7 A
No, sir, I do not believe that you 8
necessarily had to have over-cooling.
When you trip 9
the reactor, an inherent characteristic of a reactor 10 trip is that the reactor coolant system will start to 11 cool down.
As a result, you would have some cooling 12 and that could possibly lead to reasoning for why l
13 pressure might stay down for a period of time.
)
14 Q
But.there would be some cooling associated 15 with the low pressure; is that right?
16 A
Yes, sir, it could result in some cooling, 17 as, you know, by nature of the normal trends of 18 cool-down after it trips.
19 Q
If there was no cooling associated with 20 the low pressure, is it fair to say, then, that the 21 only other explanation is that you are losing inventory?
22 A
Sir, I do not necessarily -- I do not 23 recall having that understanding because whenever the 24 PORV did trip, cycle, and we did have a resulting
/~.
.5 reactor trip, the. system would have cooled down.
l i
Scheimann 679 2
Q How far?
A A
And from past situations I had seen or 3
4 heard about --
)
5_
Q How far?
it should cool down to the neighborhood 6
A 7
of approximately 545, 550 degrees because your turbine 8
bypass valves would be controlling steam generator 9
pressure to maintain that temperature.
10 Q
Did you understand, Mr. Scheimann, before 11 the accident that when the temperature dropped to 12 545 to 550 degrees Fahrenheit, that that was a 13 sufficient cool-down to result in a continuing pressure 14 below the safety injection setpoint?
15 A
I don't recall whether that in itself 16 would have been sufficient or not, to tell you the 17 truth,' sir.
18 Q
But, is it fair to'say that if the 10 primary press'ure remained below the safety injection 20 setpoint, that you did not understand that low pressure 21 to have been caused by the cycling of the PORV but l
22 rather by some kind of cool-down?
l 23 A
I did not have the understanding that1a 24 cycling of the PORV would result in a continued low
('}
25 pressure.
I did~have an. understanding that other
'%J
. - ~
~
l 1
Scholmann 680 4
2 things could occur, such as a cooling situation, that t\\/
3 could cause the temperature to stay down.
4 Q
Now, be fo re the accident, did you
)
5 understand that in a case where the drain tank 6
temperature and pressure continued increasing after 7
the PORV had closed, that that was consistent with a 8
cycling of the PORV?
9 A
I don't recall whether I had that 10 understanding or not, sir.
11 Q
You don't recall ever discussing that?
12 A
No, sir, I don't recall whether I had or 13 had not discussed that.
4
)
1-4 Q
Do you recall whether you understood that 15 a drain tank temperature that stays high is not 16 consistent with the cycling of the PORV7 17 A
I do not recall having discussed that one.
18 Q
Did you have an understanding that that 13 was inconsistent with a normal cycling of the PORV?
20 A
I don't recall whether I had that 21 understanding or not.
22 Q
Did you understand before the accident 23 that a continuing high drain tank temperature indicated 1
24 a continued venting to the drain tank?
()g 25 A
No, sir, I don't recall having that
'L
I 1
Scholmann 681 2
understanding by reason of the fact that we do also
's /
3 collect leakage in that tank from several valves in 4
the primary plant which could also reflect in
)
5 temperature holding at an elevated point.
6 Q
In a situation where the temperature rose 7
to a high point after the time of a cycling of the 8
PORV, did you understand that that was a symptom 9
that that PORV may not have closed properly?
10 A
I don't recall having that understanding, 11 sir.
12 Q
Mr. Scheimann, did you understand 13 before the accident that the safety injection was a i
14 safety system, HPI?
-15 A
Yes, sir, I was aware -- I did have an 16 understanding that it was a safety sys tem.
17 Q
Did you understand that the reason it was 18 there was to prevent core overheating?
19 A
No, sir, the reason -- what I understood 20 the reason it was there was to continue maintaining 21 RCS in ven to ry.
22 Q
Why?
23 A
So that we could keep water in the 24 reactor coolant system.
(A) 25 Q
Why?
I 1
scheimann 682 2
MR. MacDONALD:
Are you asking him why?
O N '"
3 MR. WURTZ:
Yes, why.
4 MR...M a cDONALD :
Why what?
Just a little
)
5 more of the question might be helpful.
6 MR. WJRTZ:
I think it is clear.
7 Q
You understand what I am asking, don't you?
8 A
I am not sure that I do.
9 Q
You say you had it to keep water in the 10 system.
Why do you want water in the system?
11 A
To keep the core covered and cooled.
12 Q
That is what I asked you at the beginning, 13 is the reason for safety injection to' keep the core 14 cooled?
15 A
That is not the direct reason for why 16 safety injection was used.
The direct reason was to 17 keep reactor coolant system in inventory.
By keeping 18 that inventory, we did keep the core covered.
19 Q
Well, is there any other reason for putting 20 water in there other than to keep the core cooled?
21 You don't do it to clean out the pipes, do you?
I 4
22 mean, you do it to keep the core cooled; isn't that 23 the reason it is designed and put there?
24 A
The system itself was designed to keep 4
i. ['h 25 RCS water inventory such that the core would be covered L)
l 1
Scheimann 683 2
and cooled.
The purpose was not directly the fact n
3 to keep the core covered.
However, it was a fact 4
that the purpose was to maintain inventory.
~)
5 Q
And keeping the core cooled is just an 6
incidental by-product of putting water in there?
7 MR. MacDONALD:
I object to the form.
8 Q
Is that what you are saying?
9 A
Let me have that one again?
10 Q
My question is, isn't it correct that the 11 reason you have safety injection is to assure that 12 the core stays cool?
13 A
High pressure injection, as I pointed out,
/~N
~)
14 maintains water inventory in the system, which in
- g 15 turn does keep the core covered and cool.
16 Q
You knew before the accident that HPI 17 goes on automatically in certain circumstances; is j
18 that correct?
19 A
Yes, sir.
4 20 Q
It goes on automatically when the pressure 21 drops to a certain point?
22 A
Yes, sir.
23 Q
And that point was 1640 psi on Unit 2; 24 is that correct?
05 A
As best I can recall.
! (
l l
r
l 1
Scholmann 684 2
Q And the reason the HPI goes on is to raise G
3 the pressure above 1640?
4 A
The reason HPI goes on is to maintain RCS
)
5 inventory.
G Q
Well, let's take an over-cooling situation.
7 You don't lose any inventory in an over-cooling, do 8
you, in the primary system?
9 A
In an over-cooling type situation, you have 10 apparent loss by nature of the fact that the fluid 11 in the system is shrinking.
As a result, HPI will 12 come on to bring the inventory up to its proper level.
13 Q
The inventory stays the same; isn't that (D
(,/
14 right?
The same inventory is just shrunk to a smaller 15 volume, isn't that correct, in an over-cooling?
16 A
The think you changed in an over-cooling is 17 density of the fluid.
Hence, when you have an 18 over-cooling type situation, you would expect to see 19 pressurizer level coming down, which would be 20 indicative of the fact that you want to keep water 21 level in the pressurizer, so high pressure injection 22 will come in, supply additional inventory to the 23 system and it will maintain pressurizer level in its 24 appropriate band.
(')'N 25 Q
And it will restore pressure back above
1 Scheimann 685 2
the HPI setpoint, will it not, if the over-cooling
-,O8
\\l is not too severe?
3 4
A Eventually, pressure in the system will
)
5 turn and tend to increase back above the setpoint.
6 The prime function of the high pressure injection, 7
though, is to take and insure that we have sufficient 8
water inventory.
9 Q
Well, we know in an over-cooling, though, 10 that the inventory does not change any, don't we, the 11 inventory stays the same?
12 A
By indication, you have indication that you 13 have a decrease in pressurizer level.
/N
, v) t, 14 Q
But you do know, and you understood 15 before the accident, that in over-cooling, the primary 16 inventory stays the same?
17 The exact amount of gallonage that you have 18 in the coolant system would remain the same.
The 19-volume affected would decrease as a result of the over-20 cooling, thus giving you the need to take and supply 21 additional inventory to the system in order to keep 22 the core covered and cooled.
[
23 Q
What you are doing there is adding 24 additional inventory; is that right?
You are not
/i 25 replacing inventory, you are adding additional i
LJ
(
1 Schoinonn 686 2
inventory?
3 A
You are compensating for the reduction in 4
density in the system.
)
5 Q
By adding new inventory?
6 A
Essentially, yes, you are adding inventory 7
to the system to compensate for the change in density.
8 Q
And you continue to do that until you 9
go above the HPI setpoint of 1640; is that correct?
10 A
As best I can recall, you continued 11 adding inventory to the RCS until you reached a point 12 where your pressurizer level was in its normal band.
13 Q
Was the purpose of the HPI to restore p)
\\,
14 pressure above the prescure setpoint?
15 A
Sir, as best I recall, the purpose of the 16 high pressure injection was to take and rise 17 water inventory in the system.
18 Q
Well, you knew that the HPI was set to go 19 off based on pressure, not on prescurizer level, did 20 you not?
1 21 A
Yes, sir.
22 Q
Since it was set to go off on pressure, 23 did you understand that= maintaining pressure was 24 the purpose of the HPI?
(J~'}
25 A
No, sir, I did not.
The purpose of HPI t
l
i l
1 Schoimenn 687 2
was to maintain RCS water inventory.
- (s 3
Q Why wasn't it set to go based on inventory, 4
then?
')
5 A
Sir, I didn't design it.
I don't know 6
why they made it setpoint on pressure at the present 7
time.
8
-Q You can't think of any reason why they 9
set it up'so that it would go off based on pressure?
10 MR. MacDONALD:
Are you asking for his 11 recollection at the time?
i s
12
--Q You were not aware before the' accident of 13 any reason why it was set to go off on pressure; is s,
14 that right?
15 A
No, sir, what I said is I don't recall why 16 it was set on prescure.
17
.h Did you know before the accident that 18 if press re~ were raised above the HPI'setpoint, that 19.
HPI would get reset?
In otherTwords, in a case
~
t
\\
20 where.pscasura droppe'd below the.HPI setpoint, HPI 21 went on and then'as a result o f._. he HPI coming on, 22 pressure got increased above the setpoint.
Did you 23 understand that She automatic mechanism.got reset?
24 A
- $o, sir, I did not; as.be'at I can recall, u("N we always had to manuall'y reset the high' pressure 25
~
~
~
_ ____, _ -. - - - - - - - - - - ' - - - - - " - - - - - - - - - - - ~^
~ ~ ~ ~
l 1
Scheimann 688 2
injection trip modules.
. 73
\\-
3 Q
So in a case where HPI was able to raise 4
primary pressure above the setpoint, you would reset
')
5 manually the HPI actuation setpoint?
6 A
Sir, when we would reset HPI it was not 4
1 7
based on pressure in the system.
We would reset 8
based on pressurizer level.
9 Q
Now you are talking about manual, when you 10 do a manual bypass?
I 11 A
Yes, sir, i
12 Q
I am talking about a situation where there 13 is no manual bypass, O.
K.
HPI has come on on low 14 pressure and the pressure has been restored above the 4
15 HPI actuation point.
If there is no manual bypass i
16 and then the pressure'again drops below, the HPI setpoint,
)
17 will the'HPI come on again?
18 A
Sir, if the HPI was not manually bypassed, 19 the HPI would not have been turned off.
In order to 4
20 take manual control of the HPI system, you would have l
21 to manually bypass it.
22 Q
Could you take manual control -- when the 4
23 pressure rose above the actuation point, could you 24 take manual control without bypassing the automatic
[~}
25
-setpoint relays?
v
]
1 Schaimann 689 2
A As best I could recall, sir, you had to
,~,
3 bypass it in order to take manual control.
4 Q
Let's take a situation where HPI came on
)
5 at 1600 psi and restored the pressure to 1700 psi.
6 Could you at that point, at 1700 psi, 7
take manual control of HPI without doing a bypass?
8 A
As best I could recall, no, sir.
9 Q
So at 1700, you had to bypass, as you 10 recall it?
11 A
Sir, as best I can recall, at any time we 12 wanted to get out of the high pressure injection 13 mode, we had to manually bypass ES.
(-~)
14 Q
At 1700 psi, could you throttle the 15 sixteens without bypassing?
16 A
Sir, as I pointed out, any time we wanted 17 to take and perform any manual evolution to the HPI 18 system, we had to bypass ES.
19 Q
And what I asked you was, could you 20 throttle the sixteens at 1700 psi after an automatic 21 initiation?
22 A
I would not throttle the sixteens based 23 on pressure.
I would thr'ottle the sixteens based 24 on level in the pressurizer and I could not do that
(~';
25 without bypassing.ES.
4
~
d 1
Schaimann 690 4
2 Q
So you could not adjust those valves 3
at'all without first doing a bypassing; is that 4
correct?
')
5 A
That is correct, sir.
6 Q
Even when the pressure is above the 7
safety injection point?
8 A
As best I can recall, once ES is initiated, 9
you had to manually bypass it to control any function.
10 Q
Now, did you understand before the 11 accident that a loss-of-coolant accident could bring 12 about an HPI actuation?
13 A
Sir, that would depend on the severity of
- 14 the loss of coolant.
a 15 Q
You understood it was possible for that 16 to happen?
17 A
Depending on the severity, you could have 18 an HPI as a result of the loss of coolant.
19 Q
And in that event, the purpose of the
'i 20 HPI was to replace the coolant being lost through 21 the hole in the system; is that correct?
I-22 A
Yes, sir, it was for a reactor coolant 23 system inventory.
24 Q
And as you replaced the coolant being lost,
~%
25
'you.would restore,the-pressure to the system; is that
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g.e e-e a w
is-
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f
1 Scheimhnn 691 2
correct?
3 A
sir, that would not necessarily be correct.
4 It would depend on the severity of the event.
)
5 Q
You understood there were LOCA's of 6
different sizes, in other words?
7 A
Yes, sir.
8 Q
Now, did you understand that there was a 9
-LOCA where the HPI actuation point would never even 10 be reached where the makeup tank and the makeup 11 pump could restore coolant sufficiently to maintain 12 pressure?
13 A
Yes, sir, there was such a case.
14 Q
Did you understand that there was also a 15 size of LOCA where the pressure would drop to the 16 point where HPI would occur and with HPI coming into t
17 the system you would be able to restore pressure 18 above the HPI actuation point?
19 A
Again, sir, that would depend on the 20 severity of the loss-of-coolant accident.
21 Q
What I am asking is, did you understand 22 that there was a type of LOCA where the hole in the 23 system was big enough so that pressure would drop and 24 HPI would go on but that that HPI would be able to
(g 25 restore pressure above the HPI actuation'setpoint?
N]
2 l
~.
. ~ - -
H 1
Schsimann 692 2
A There was a type of LOCA that you could
[
3 have pressure drop low enough to reach the high 4
pressure injection setpoint, at which point the 4
)
5 high pressure injection would initiate and you would 6
bring your water inventory up to its proper band of 7
operation and at the same time you would conceivably 8
see the benefit of an increase in pressure.
9 Q
So that HPI would be able to restore the 10 pressure above the HPI actuation point?
11 A
Eventually, you could get to a point 12 where pressure would be restored above the HPI pressure 13 point.
O)
\\,
14 Q
What do you mean by " eventually"?
15 A
You might not see it tend to turn right IG away is what I am getting at there.
It might be 17 -
some time before you saw pressure come up.
You would 18 initially see the change in the pressurizer level.
19 Q
The pressure would not continue to drop 20 in a LOCA of that size; is that right?
21 A
If you had sufficient water inventory 22 going in, eventually you would see pressure just 23 turn and then gradually start to come up if it was in 24 the capability of the high pressure injection system
(/j 25 to maintain coolant inventory.
\\_
H 1
Schelmann 693 i
2 Q
And then did you understand there was
,~
3 also a LOCA that would be of such a size that 4
pressure would just keep dropping until you got to
')
5 the point of low pressure injection?
6 A
Yes, but before you hit the low pressure 7
injection, you hit the point of the core flood 8
system.
9 Q
And at what point do you hit the core 10 flood system?
11 A
I believe that was around somewhere 650, 12 700 pounds.
13 Q
Where do you hit the low pressure f -
(
14 injection?
15 A
Approximately 400 pounts or a little 16 under that.
l'T Q
Now, did you understand that in some cases 18 a loss of coolant is isolable, it can be closed off?
1 10 A
That would depend on where the loss of 20 coolant was taking place, sir.
21 Q
Well, for example, if a loss of coolant 22 is occurring through a stuck-open code safety, you 23 can't isolate that; is that right?'
24 A
No, sir, you can't isolate that.
/~%.
25 Q
whereas, if the loss of coolant is through i
~
1 Scheimann 694 2
a pressurizer spray valve, you could isolate that?
[\\
\\_/
3 A
Yes, sir, if the valve had failed in some 4
4 position, you do have an isolation for it.
')
5 Q
Or through the seal or return line, you 6
could isolate that?
7 A
Yes, again that would be isolable.
8 Q
Were you aware before the accident that 9
there was a procedure, an emergency procedure, for 10 loss of coolant, loss of reactor coolant system 11 pressure?
12 A
Yes, sir, I was aware that there was such 13 a procedure.
()
14 Q
Were you familiar with that procedure?
15 A
At that particular time, I had been 16 familiar with it.
17 Q
Did you review it in training?
18 A
Yes, we reviewed that one, among other 19 emergency procedures, at various times.
20 Q
Did you memorize parts of that procedure?
f
[
21 A
Yes, sir, at times at the time prior 22 to the accident, we were required to know what the 23 immediate actions were.
l 24 Q
Wore you required to know what the symptoms 25 for diagnosing a loss of coolant were?
{x
1 Scheimann 695 2
A Yes, sir, at that time we were.
(~')
\\_/
3 9-Did you understand that the purpose of 4
this procedure was to correct a loss of reactor
~)
5 coolant system pressure resulting from a loss of 6
coolant?
7 A
That would have been one of the purposes 8
of the procedure, as well as making sure that you 9
had RCS water inventory, which would be the primary 10 one.
11 Q
Did you understand that an important 12 purpose of the procedure was to treat. a low pressure
.13 situation in the reactor coolant system?
()
14 A
That would have been one of the two v
15 purposes o f it.
However, the primary one was to 16 insure you had water inventory.
17 h
Why do you call that the primary one?
18 A
I call that the primary one because that 19 is what all our training and everything else was 20 geared towards, maintaining the core covered.
21 Q
You were aware that that procedure was 22 called loss of reactor coolant, reactor coolant 23 system pressure?
24 A
Yes, sir, I was aware that is what it was
-(N 25 called.
t a
i
\\w).
I I
r~
'1 1
scholmann 696 2
Q Were you aware that the procedure ret. ired
'N 3
you to restore pressure above the HPI actuation 4
point?
[)
5 A
That was one of the conditions that the C,
procedure required you to do in addition to primarily 7
getting yourself back, maintaining your RCS water 8
inventory.
9 Q
Does it say in the procedure that inventory 10 is more important than the pressure?
4 11 A
I don't recall it coming out in the 12 procedure and saying verbatim that inventory is more 13 important.
14 Q
Is there anything in the procedure that 15 caused you to conclude that?
16 A
I don't have a recollection as to whether 17 there was or was not anything in that procedure that 18 caused me to conclude that the inventory was more 19 important.
1 20 Q
Now, did you understand before the i
I 21' accident that it was important to diagnose and treat 22 a LOCA when you had one?
l 23 A'
Yes, sir, if you were assured that you had 24 a LOCA, you would treat it.
You were supposed to
('N 25 treat it.
\\_/
l
)
1 Scheimann 697 2
Q Did you understand that it was important O
k-to diagnose a LOCA?
3 4
A Yes, sir, it would be important.
)
5 Q
Did you understand that an untreated LOCA 6
could lead to core damage?
7 A
Sir, I don't recall discussing an 8
untreated loss-of-coolant accident by nature of the 9
fact that primarily, when you got your loss-of-10 coolant accident type situation, if it were within 11 the capability of the makeup system, it wouldn't be 12 untreated.
If it were in the capability of high 13 pressure injection, it would not be untreated.
High
(%)
14 pressure injection would come on and you would be 15 making up water inventory.
16 Q
Did you understand that if it went 17 untreated, the consequences would be severe and could 18 include core damage?
19 A
I understood that theoretically you could 20 get core damage as a result of not maintaining RCS 21 inventory.
22 Q
Did you understand that you could get 23 core damage from not maintaining RCS pressure?
24 A
No, sir, I did not, based on the fact
. ()
25 that our reactor trip envelopes were sucn that O
l 1
Schaimann 698 2
had we increased in pressure, the reactor would N
3 have tripped and the heat source would have been u
4 removed.
)
5 Q
Didn't you understand that after a trip 6
there was decay heat?
7 A
Yes, sir, I understood there was decay 8
heat.
However, the decay heat was in a relatively 9
small percentage compared to power operations.
10 Q
You didn't understand that decay heat 11 could lead to core damage if the pressure was not 12 maintained at a sufficiently h'igh level?
13 A
Sir, I do not recall having an p(
14 understanding of that nature.
15 Q
So the reason that you did not think that 16 you could get core damage after a reactor trip from 17 not maintaining sufficient primary pressure is that 18 you thought the decay heat was at such a level that 19 there wouldn't be a problem; is that right?
20 A
I don't think I understood what you are 21 asking for there.
22 Q
Well, I ask you, did you understand 23 before the accident that you could get core damage 24 from not maintaining pressure in the primary system,
(~'N 25 and you answered "no"; is that correct?
I 1
.. S c h.e i man n ----- - -- -
-- - - 69 9 -
2 A
Yes, sir.
3 Q
And the reason that you did not think you 4
could get core damage from not maintaining pressure
)
5 was that all you had to deal with was decay heat, 6
not the amount of heat produced when the reactor was 7
at power; is that right?
8 A
Sir, the reason why you wouldn't 9
necessarily be in a problem area is because after the 10 reactor tripped, the system does cool down.
11 Q
And, therefore, you didn't consider it 12 important to maintain primary pressure in order to 13 avoid core damage?
O(
14 A
Not for the purpose of avoiding core 15 damage.
Based on the fact that once you had your 16 reactor trip, you were no longer in the DNBR type 17 considerations.
At that particular point, you 18 would drop down onto your cool-down curve, which the 19 primary bases for th,e different pressurizer and 20 temperature limits were based on component structures.
21 MR. WURTZ:
Could I have the answer 23 read back.
23 (Answer read.)
24 Q
So that as you understood it before the
(']
25 accident, there was no minimum pressure that you V.
. 1.
...S c ha i nann.__..___
700__
2 had to maintain in order to avoid core damage?
/~T i
\\-)
3 A
As best I can recall, the heat-up and 4
cool-down curves were based strictly on the
)
5 components in the RCS.
6 Q
And as you understood it, there was no 7
minimum pressure required to prevent core damage?
8 A
I don't recall that as being one of the 9
bases for the heat-up and cool-down curves.
10 Q
And, therefore, you were aware of no 11 minimum pressure requirement related to avoiding core 12 damage?
13 A
As best I can recall, no, sir.
f'\\
g j) 14 Q
And you understood the reason that there 15 was no minimum pressure requirement after a trip to be 16 that the core was producing less heat at that point, 17 it was producing just decay heat; is that right?
18 A
I don't recall that that was the reason 10 why there wasn't pressure for preventing core 20 damage.
21 Q
That is the re'ason you understood that you 22 didn't have to maintain pressure to prevent core 23 damage, though; is that correct?
24 A
Could I have that again?
I kind of got
/"N 25 things mixed up there a little.
(
1 Scheimann 701 2
Q The fact that after a trip you just have
\\
3 decay heat produced in the core, which is far less 4
heat than you have produced during a trip, was the
)
5 reason that you understood it that you didn't have 6
to maintain pressure in order to avoid core damage?
7 A
No, sir, the reason that I understood 8
we didn't have to -- we didn't have a pressure set 9
to maintain prevention of core damage was that upon 10 tripping the reactor, we went from the operating 11 band curves down to the cool-down curves, which did 12 not, as best I can recall, give a condition for the 13 prevention of core damage.
They were primarily for 14 the protection of equipment.
+
15 Q
And as you understood it, those cool-down 16 curves had nothing to do with protecting the core?
I'T A
As best as I can recall, they were 18 primarily for the protection of the equipment itself.
10 Q
Did they have anything to do with 20 protecting the core?
I 21 A
I don't really have a recollection that 22 they did.
23 Q
Now, in a situation where you had symptoms 24 that were consistent with a LOCA and some other cause, l f'h 25 did you understand that you were required to l
V
\\
~
l 1
Schsimnnn 702 2
investigate to see if there was a LOCA involved?
(')
N_/
3 A
Sir, that would depend on what the symptoms 4
were that were being displayed and what elsa was
')
5 happening.
6 Q
Well, I am just asking you whether you 7
understood you were required to investigate.
You are 8
saying that would depend on something?
What would that 9
depend on?
10 A
It would depend on what the plant 11 conditions were, what you were seeing in addition to 12 those symptoms.
There could have been some other cause
' 13 for those symptoms.
14 Q
Well, did you consider it to be one 15 of your obligations to find out what the cause was if 16 the particular symptom could be caused by a LOCA?
17 A
If we had symptoms, we would take and 18 see what all our symptoms were at a given time and 10 we would go ahead with the emergency procedure that 20 would be representative of those symptoms.
21 Q
If you had a symptom that could be caused 22 by a LOCA, did you understand that it was important 23 to investigate to see if you had a LOCA?
24 A
Sir, that would depend on if I knew what
(~N 25 was causing that condition.
l
\\v
+,
~
g 7
.-s
I I
scheimann 703 2
Q If you knew it was not a LOCA, then you
^N s-)
i 3
w uld have explained it; is that what you are saying?
4 A
Essentially, if I knew that symptom was
(
)
5 caused by something else, I wouldn't go to the LOCA 6
procedure.
7 Q
But until you had concluded what was 8
causing the symptom in a situation where you knew that 9
a LOCA could cause the symptom, did you understand 10 that y'ou were obligated to investigate to see if a 11 LOCA was occurring?
12 A
In the event of receiving symptoms up in 13 the control room, generally you get the symptom rather
(
14 rapidly and you can generally rather rapidly determine 15 what was causing the symptom.
And in that regard, if 16 I could determine what the cause of that symptom was, 17 I would not proceed to the LOCA investigation.
18 Q
In the situation where you could not 19 determine what the cause was and you knew that a LOCA 20 was possible, did you know that you were obligated 21 to investigate to see if a LOCA was going on?
22 A
If I-didn't know what the symptom -- what 23 was accounting for the symptoms and I had all of 24 the symptoms or the majority of the symptoms for a
('
25 loss of coolant, I would tend to investigate in that D}
l 1
Scheimann 704 2
direction.
However, if I did have a cause for a given
(-)
3 set of symptoms that was other than a LOCA, I would not.
4 Q
For example, let's take a high reactor
)
5 building pressure, did you understand that that 6
symptom could be caused by a LOCA?
7.
A It could be caused by a LOCA.
It could 8
also be caused by a broken feedwater line or a broken 9
steam line.
That in itself would not necessarily tell 10 me that I had a LOCA.
11 Q
When you had a situation where there was 12 high reactor building pressure, did you understand 13 that it was important for you to investigate to find p) 14 out what was causing it?
v 15 A
It would be important to know why you had 16 the high building pressure.
17, Q
Did you know that you had various means "18 available t.o you for investigating the cause of that 19 high reactor building pressure?
20 A
I maybe don't see what you are getting 21 at there.
22 Q
Well, do you know that you could look at 23 what was happening on the panel as part of your 24 investigation, look at the meters to see what they
("T 25 were reading for various paramaters?
\\._) ~
i 1
Scheimenn 705 2
A Yes, sir, you could use that as part of
/~T k-3 your investigation as to'why you had high building s
4 pressure.
You could also look over at the second
')
5 plant, or the secondary plant and feewater system 6
conditions.
7 Q
And that is something that you would do 8
in investigating high reactor building pressure, is 9
it not,look over at the secondary to see what is 10 happening?
11 A
I would tend to do that.
12 Q
Could you also review strip chart 13 information available in the control room?
i-s()
14 A
some of the parameters in the control 15 room have strip charts; quite a few of them don't 16 though.
17 Q
For those that do have strip charts, you 18 could look at those for another source of information; 19 is that right?
20 A
It could possibly be one of the sources.
a-l 21 Q
And you understood before the accident 22 that these were available for purposes of diagnosing 23 whether reactor building pressure, a reactor building 24 pressure increase was caused by a LOCA on one hand or
(~]
25 by a problem with.the steam generator?
\\.J
I 1
Scheimenn 706 2
A
'No, sir, I did not.
The purpose of those
(~N
(-)
3 charts was just to indicate a trend in that 4
particular parameter.
)
5 Q
Did you understand before the accident G
that the trend shown on the strip chart could be of 7
use in diagnosing the cause of a particular symptom?
8 A
It could or maybe it wouldn't.
9 Q
Now, did you understand before the 10 accident that during the time period when you are investigating whether high reactor building pressure 11 12 is being caused by a LOCA on one hand or by a steam 13 line break on the other, that the safest course during
~s 14 that time period is to treat a LOCA?
15 A
No, sir, I do not recall having that 16 understanding.
What my understanding was pertaining 17 to determination of which event you had was that you 18 had unique symptoms that would occur for each of 19 them that you could tell them apart rather rapidly.
20 Q
And what was the unique symptom for a 4
21 LOCA?
22 A
In the case of a unique symptom for a 23 LOCA, you would see indication on primarily HPI 227 24 which would be the reactor building sampling.
L
(~N 25 However, you could.also get indication on that from a i
\\s, i
c:
I i
1 Scheimann 707 2
couple of other problems also, but if you had the
[
(_/
3 pressure drop in a system and you had that alarm 4
and a few of the other parameters, it was indicative
')
5 that you might possibly have a LOCA.
However, as 6
I was pointing out, you could also have a condition 7
where you had a primary to secondary leak and you 8
had a steam leak in the building, that could also 9
give you that.
10 Q
But in that case, you would also have 11 t'he VAR 748, would you not?
12 A
In that particular case, I would expect 13 to see a VAR 748, although not necessarily.
It
(%}
r 14 would depend on the severity of the leak.
15 Q
so what you are saying here is that 16 there might be a situation where you couldn't tell 17 immediately; is that right?
18 A
A situation could occur that you would get 10 the indications of a LOCA from some other cause.
20 Q
Mr. Scheimann, is what you are saying here i
21 that there might be a situation where.you could not 22 tell right away if you have a LOCA?
23 MR. MacDONALD:
Are you talking about what 24 from the unique symptoms, now?
rN 25 MR. WURTZ:
Yes, the question was
\\
i
%d
l 1
Schaimann 708 2
I mean, we have a series of questions.
You k/
3 can't assume that.
We are both sitting at the 4
same table hearing these questions and answers.
)
5 It becomes very difficult.
6 Q
I had just said, is there a situation 7
where it could take some time, and you said no, they 8
are unique symptoms you can tell right away, and I 9
said, what are they.
You said one is the 227 but you 10 can't always tell from that.
So my question to you 11 is based on that series of questions and answers 12 and my question is, did you understarid before the 13 accident that there could be a situation where you
()
14 wouldn't be able to tell immediately that a LOCA was 15 a cause for a particular symptom, and the symptom 16 that we had talked about was high reactor building 17 pressure.
18 A
Yes, sir, there would be a time when you 19 could not tell that the high reactor building pressure 20 was due to a LOCA.
21 Q
You could not tell that immediately; is 22 that correct?
23 A
Yes, sir.
24 Q
Now, did you understand before the l (']
25 accident that in such a circumstance, that during the V
~
l 1
Schaimann 709 2
time you were investigating to see whether it was a
[/
\\-
3 LOCA causing that or something else, that the safest 4
course for you as an operator was to treat a LOCA?
')
5 A
No, sir, I did not have that understanding 6
that I can recall, 7
Q You did not understand that you were to 8
treat a LOCA until you knew it was not a LOCA?
9 Let me put it again.
You look puzzled.
10 Did you understand before the accident 11 that when you had a symtom that could be caused by i
12 a LOCA and you had not been able to rule out the 13 possibility of a LOCA, that you were required to O)
(
14 treat a LOCA?
15 A
No, sir, I did not have that understanding, 16 as best I can recall.
17 Q
Did you know that a LOCA'is the most 18 serious kind of accident you can have?
19 A
Sir, that would depend on the severity of 20 the LOCA.
21 Q
Were you trained during your eight years 4
22 in the navy that in a situation where you had symptoms 23 consistent with a LOCA and with some other cause, 24 that until you knew that it was not a LOCA, you should i
(N 25 assume it was a LOCA and treat a LOCA?
)
V
-w
- -, - - =
.r w
I scheimann 710 2
A I don't have a recollection of what my
\\s-3 understanding from that point of time was.
4 Q
Were you ever told in the course of your
)
5 training at Met Ed that in such a situation where 6
you knew a LOCA was possible and you didn't know what 7
was causing the particular symptom, that you should 8
assume it was a LOCA and treat a LOCA?
9 A
Sir, I do not recall that for a given 10 symptom I was required to take and perform actions 11 on an emergency procedure.
12 Q
What did you understand you were to do 13 when you knew a LOCA was a possible cause of a
/N
(
)
14 symptom and you could not rule out a LOCA because you v
15 didn't know what was causing the symptom?
16 A
I would have to find out what the cause 17 of the symptom was.
18 Q
What were you trained by Met Ed to do 19 during the time when you were trying to find out what 20 the cause was?
21 A
It would depend on what the parameter was
'22 as to what my action would be during the investigation 23 phase.
21 Q
Well, we were talking about high reactor
(~N 25 building pressure.
Did you understand that to be a v) t
.~
H 1
Scheimann 711 1
2 serious condition?
('h
()
3 A
It would be a serious condition.
4 Q
And during the time when you were
')
5 investigating to see whether that was caused by a 6
LOCA or by a steam break, what steps did you 7
understand you were to be taking?
8 A
You would investigate to determine what g
the cause of the symptom was, i
10 Q
Did you know and understand that during 11-the time you were doing that investigation, it was 12 possible that a LOCA was going on?
13 A
Based on one symptom, I don't necessarily f
14 I would not think that a casualty was happening.
b 15 Q
Well, you knew that a LOCA was a possible 16 cause for high reactor building pressurer is that 17 right?'
18 A
I knew that a LOCA was a possible cause 19 for high reactor building pressure but I also knew 20 that a broken feed line or steam line could also 21 give me a high reactor building pressure.
22 Q
And, therefore, until you knew which of 23 those things was causing the high building pressure, 24 you understood that it was possible that a LOCA was 25
-going on?
l
\\)
r 1
Scheimann 712 2
A It would be a possibility that that
(-
i
)
\\_/
3 could be occurring as well as a possibility that a 4
steam line could be broken in half or leaking badly
')
5 or a feed line could be leaking badly.
You couldn't 6
just go to that one symptom and say, yes, this is my 7
p ro blem.
8 Q
Before the accident, did you ever become 9
aware of the idea that during the time when you could 10 not tell whether it was a LOCA or a steam line break 11' or a feedwater line break, that you should assume that 12 it is a LOCA and treat a LOCA?
13 A
No, sir, I do not recall having that U) 14 understanding.
i 15 Q
You don't recall ever even hearing that 16 idea; is that it?
17 A
I don't have a recollection of it.
18 Q
Mr. Scheimann, you attended simulator 19 training at B&W in a period in early 1976; is that 20 right?
21 A
I had attended simulator training on 22 several occasions.
I just don't recall what the dates 23 involved were.
24 Q
Do you recall in connection with
/^1 25 attending simulator training at B&W where you received i
1
I-Scholmann 713 J
2 a book of procedures?
s 3
A Yes, sir.
4 Q
And, in fact, you earlier testified that
)
5 each trainee got a copy of those procedures?
6 A
Yes, sir.
7 Q
In fact, you kept your copy and we 8
marked it earlier in this deposition as Exhibit 535.
9 MR. WURTZ:
I have some pages from that 10 Exhibit 535 which I would like to mark as the 11' next exhibit.
12 These pages constitute the cover from the 13 volume and the procedure entitled " Loss of 14 Reactor Coolant / Reactor Coolant System 15 Pressure."
The number on it is Procedure 16 1202-6.
17 I will ask that this be marked as 18 Exhibit 614.
19 (Cover and pages from procedure manual, 20 procedure entitled " Loss of Reactor Coolant /
i I
21 Reactor Coolant System Pressure," No. 1202-6, 22 were marked as B&W Exhibit 614 for 23 identification, as of this date.)
i 24 Q
Mr. Scheimann, have you had a chance to
/~N 25 look at the sinulator procedure we have marked as i
t r
. ~,
1
- Scholmann 714 2
Exhibit 6147 3
A I have glanced at parts of it.
4 Q.
Do you recognize that this procedure is 7}
5-one of the procedures provided to you by B&W during 6
the course of your. training?
7 A
This would,have been -- this was one of 8
theJOld Forest Road procedures that we used on the 9
simulator.
I 10, Q
Did you read the procedure at some point 1
4 l
11-during your training?
12 A
At one time.during my time at.the l
^ 13 simulator, I had read the emergency procedures that D
14
. we had there.
15
-Q Did you review the procedures, including 16 this procedure for a loss of reactor coolant / reactor l'
17 coolant system pressure?
i
' 18 A
.I had looked at that on occasion.
t i -
-19 Q.
Did you look at it during the time you-r l
20 received training at B&W7 l-
- i 21 A
Yes, sir,1when we were performing the l
22' different types of casualties during a simulator M
training.
24
.Q And then after you left B&W and went-back
.g I ?r N
.25 -
to.TMI, did you also look at this procedure from-time.
s 4
e
, - =.
- m. e.w
--n e % er-eme-e re-ce e g-tw r-e gW'e<wrN erm+ -ew gW-1,g-ee.-
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4,,,
i
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=P
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A No, sir,' I did not, not back at the Island
., s J
4 be ca u s e inis was n'ot our operating procedure.
.i,
(
,%s 5
Q So it was a procedure that you used at
=
6
.B&W, then?
i 7
'A At.that particular session of training.
s 0
MR. MacDONALD:
You are talking about the s'
3 9
1976 time period, now?
i 10 Q
Well, during the time peri'od when you 11 received this bodic of simulator precedures.
12 -
MR.]MacDONALD:
My question is, during sig c
. y.
13
,f'.
the entir,i' time period in the different 14 instancils h'e was down at the simulator he
+
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a 15 always used those, is that the question,'or is 4
t s
,U 16 i
N the question in the time period 1976 he used 17
'those procedures?
18 Y
Q Let me ask that.
During'the t i m, e you 4
e 19 received this book, did you nake us'e of those t '
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20 procedures?
r a
1
.1' 21
.A During the trainEng period that we were s}
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22 down there, we'did make use of these p ro c'e dure s.
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. it
'f, y>s'
' 23
-/ Q I have the original c'qpy.of 5xhibit 535, y,
,\\
24
.which is the entire booh,of.qroce.dures, here.
I have,
\\
i Q
g
- p)..
.25
'it o'p e n e d to the one we,' ave harked as Exhibit 614, n
/t a
. t Q. t,j' s, g e
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ny
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Scheinmann 716 2
~ which is the LOCA procedure.
./ 3 ss) 3 Do you see that on the original, the O's are 4
all filled in with red on that first page?
')
5 A
Yes, sir.
G Q
Do you recall doing that?
7 A
I. don't have a recollection of whether 8
I did it or not or for what reason, even.
9 Q
Do you recall that you did that from 10 time to time?
11 A
I had been known to take and doodle from 12 time to time.
13 Q
I would like you to look at that first b,j, 14 page of the LOCA procedure under the title
,v 15
" Description," and in particular, at the middle 16 paragraph there.
17 Do you see that?
i 18 I would like to read that into the record.
19 It states,,"The initial symptoms could be caused by 20 a malfunction of the makeup system or by a steam 21 line rupture, as well as by a loss of coolant from 22 the RC system.. The operations should assume the cause 23 of the symptoms described above as an RC leak or 4
24 rupture, unless another cause can be immediately l
25 established."-
TA) i r
. ~..
- - - - +
v
-r-
l 1
Schsimann 717 2
Does that refresh yoar recollection that (s_/
3 before the accident you did hear of the idea that in 4
a situation where symptoms could be caused by a
')
5 LOCA or by a steam break, you should assume a LOCA 6
until another cause was established?
7 A
No, sir, it doesn't seem to refresh my 8
recollection.
9 Q
Mr. Scheimann, I would like you to look 10, at an exhibit that has been marked as B&W Exhibit 418.
11 This is a preliminary draft LOCA procedure that was 12 provided by B&W to Met Ed in June of 1970.
13 Mr. Scheimann, my question is whether in 14 the course of your training on Unit 1 when you went 15 to work at Met Ed you saw any of the preliminary 16 draft emergency procedures that B&W had provided to 17 Met Ed?
18 A
Sir, I don't have a recollection of seeing 19 in particular this one, I don't have a recollection 20 of seeing preliminary drafts of the other procedures.
21 Q
So you don't recall seeing any draft 22 emergency procedures for Unit 1 during the time of your 23 training?
24 A
I don't have a recollection of seeing them.
~}
25 Q
Now, en the day of the accident, did you
\\_)
l 1
Schsimann 718 2
make use of the Unit 2 LOCA procedure?
3 A
As best I can recall, sir, no.
4 Q
Well, the title of the procedure includes
'}
5
" Loss of Reactor Coolant System Pressure," does G
it not?
7 A
Yes, sir, the title does include that.
8-Q You had a loss of reactor coolant system 9
pressure, did you not?
10 A
I had pressure decrease, yes.
11 Q
Did you take that procedure out at any 12 time?
13 A
To the best I can recall, no, sir.
/~')
14 Q
Did you review it in your mind since you
.y 15 had not committed it to memory?
16 A
I don't have a recollection of having 17 done so.
18 Q
Did you discuss the LOCA procedure and its 19 contents with anybody?
20 A
I don't have a recollection of having 21 done-so, h
22 Q.
Did you at any point act according to it, 23 or pursuant to the LOCA procedure?
24 A
As best I can recall, no, I did not.
25 MR. WURTZ:
I would like to mark as
[V i
n 1
Scholmann 719 2
Exhibit 615, a copy of a transcript of a
/
3.
statement transcribed by the NRC, a statement 4
made by you to Mr. Rutford and Mr. Long on
'}
5 March 30, 1979.
6 (Copy of transcript of a statement by 7
-Mr.
Scheimann to Mr. Rutford and Mr. Long on 8
March 30, 1979, transcribed by the NRC, was 9
marked as B&W Exhibit 615 for identification, 10 as of this date.)
11 Q
Mr. Scheimann, I would like to read to 12 you from the bottom of page 9 and the top of page 10.
13 Do you want to take the copy that the
'[)
14 reporter has marked.
N-l 15_
At the bottom of page 9 Mr. Long says 16 to you, Mr. Scheimann, "Did you use any procedures?"
17 And you respond on the top of page 10,'"Yes, sir; as 18 soon as we got over the initial actions on the trip 19 itself, we pulled out our emergency procedures drawer --
~20 books, rather -- and we went through the turbine trip, 21 reactor trip, and let's see, what was the other one
']h 22 we looked at?
Well, the loss of coolant loss-of-
- 23 pressure procedure, we were looking at."
1!4 Do you see that testimony,. Mr. Scheimann?
25 A
Yes, sir.
m
~
l 1
Scheimenn 720 2
Q Did you give that testimony on March 30, 3
19797 4
A I don't recall for sure the date involved
').
5 and I don't exactly recall the exact wording.
6 Q
-Does reading that testimony refresh your 7
recollection that on the day of the accident you did 8
in fact look at the LOCA procedure?
9 A
No, sir, it doesn't.
10 Q
I would like you to look at what has been 11 marked as Exhibit 357,-which is your testimony given 12 to the President's Commission on July 25, 1979.
13 I would like you to look at the bottom of
\\
14 page 184.
The question is, "Do you remember which gs_ j 15 procedures that maybe you did not pull the exact 16 written copy of the procedure, that you remembered 17 relying on from memory?"
18 And your answer is, "Well, I am sure we 19 worked with the ES procedure, as we had to take,and 20 clear off the ES signal in order to take manual control 21 of the system.
I more than likely had been acting 22 according to the loss-of-coolant procedure or loss of 23 pressure.
Again, it is a case where you are in the 24
-middle of things like'that.
You do. things that come
(g 25 to you from -- how do I want to say it long use
\\._ s,i i
l
l 1
SchLimann 721 2
and long practice.
You might not necessarily refer, 3
word for word, to this or this or this, but you 4
react according to what your symptoms are without
')
5 really being totally alerted to your doing this.
6
" Question:
You indicated that from 7
memory you relied on the loss-of-coolant pressure?
8
" Answer:
I may have.
9
" Question:
Did you remember what symptoms 10 you saw that you pulled that procedure out of your 11 memory?
12
" Answer:
At the present time it has been 13 a while and I can't really recall what may have
)
14 triggered what in my mind."
15 Mr. Scheimann, does that refresh your 16 recollection that you made mental reference to the 17 LOCA procedure during the accident?
18 A
No, sir, it doesn ' t refresh my mind to 19 that fact.
20 (Time noted:
4:30 p.m.)
$h 22 Frederick J.
Scheimann 23 Subscribed and sworn to before me 24 this day.of 19E2.
($
25
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1 722 j
CERTIFICATE 2
[')-
i i.
STATE OF NEW YORK
)
3
- ss.:
COUNTY OF NEW YORK
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4 s
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I, NANCY A.
RUDoLPH
, a Notary 5
Public of the State of New York, do hereby 6
certify that the continued deposition of FREDERICK J.
SCHEIMANN was taken before 8
me on Tuesday, April 27, 1982 consisting 9
of pages 557 through 721 I further certify that the witness had-been previously sworn and that the within transcript is a true record of said testimony;
(~N That I am not connected by blood or s) 14 marriage with any of the said parties nor interested directly-or indirectly in the matter in controversy, nor am I in the employ of any of the counsel.
18 IN WITNESS WHEREOF, I have hereunto set my 10 EL hand this h day of 1/c-1982.
20 12:2) 2' 22 KA. / -, f. -(
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23' Nancy A.
Rudolph
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24 fN y
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723 I NDE X WITNESS PAGE Frederick J. Scheimann (resumed) 559 E XH I B I TS B&W FOR IDENTIFICATION 1
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614 Cover page and various pages from procedure manual, procedure entitled " Loss of Reactor Coolant / Reactor Coolant System Pressure,"
No. 1202-6 713 615 Copy of transcript of a statement by Mr. Scheimann to Mr. Rutford and Mr. Long, transcribed by the NRC; said statement made on March 30, 1979 719 4
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