ML20072J036
| ML20072J036 | |
| Person / Time | |
|---|---|
| Site: | Three Mile Island  |
| Issue date: | 07/14/1982 |
| From: | Noll R METROPOLITAN EDISON CO. |
| To: | |
| References | |
| TASK-*, TASK-02, TASK-04, TASK-06, TASK-10, TASK-2, TASK-4, TASK-6, TASK-GB NUDOCS 8306290885 | |
| Download: ML20072J036 (138) | |
Text
_ _
BK 1 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK
-- - - ----- - - - -- - --- ----x GENERAL PUBLIC UTILITIES CORPORATION, JERSEY CENTRAL POWER & LIGHT COMPANY, METROPOLITAN EDISON COMPANY and :
(' PENNSYLVANIA ELECTRIC COMPANY,
, Plaintiffs, 80 Civ. 1683(R.O.)
-against-THE BABCOCK & WILCOX COMPANY and J. RAY McDERMOTT & CO., INC., a Defendants. :
x Deposition of RICHARD C. NOLL, taken by P)
% Defendants, pursuant to notice, at the offices of DAVIS POLK & WARDWELL, Esqs., One Chase Manhattan Plaza, New York, New York, on Wednesday, July 14, 1982 at 9:55 a.m., before Walter Shapiro a Certified Shorthand Reporter and Notary Public within and for the State o f New York.
l
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f 8306290885 820714 PDR ADOCK 05000289 T PDR l
1 r
(_) ' DOYLE REPORTING. INC.
CERTIFIED STENOTYPE REPORTERS 369 LEXINGToM AvrNUE WALTEM SHAPIRO. C.S.R. New Yonst. N.Y. 10o17 CHARLES SHAPIRO, C.S.M. TettpNoNr 212 - 867-8220
1 2 2 APPe arance s:
3 KAYE, SCHOLER, FIERMAN, EAYS & MANDLER, ESQS.
j Attorneys for Plaintiffs 4 425 Park Avenue New York, New York C' 5 BY: STEVEN J. GLASSMAN, ESQ.,
- 6 of Counsel 7 E 8
9 DAVIS POLK & WARDWELL, ESQS.
Attorneys for Defendants 10 One Chase Manhattan Plata New York, New York 11 BY: ROBERT F. WISE, JR., ESQ.,
12 of Counsel
. O 14 15 16 Also Present:
17 SUSAN HANSON 18 1
j 19 '
-ooo-20 21 43 22 l 23 .
l I 24 f~T l
s) 25 ,
i 5
, l -- . . .- - , -----><-,,v.w,- - - -- ,,---v ,, .. -
l 1 3
() 2 IT IS HEREBY STIPULATED AND AGREED by and tween the attorneys for the respective parties be- i 3
4 hereto that the sealing, filing and certification 5
of the within deposition be , and the same 6 hereby are waiveds that the transcript may be 7 signed before any Notary Public with the same 8 force and effect as if signed before the Court.
9 IT IS FURTHER STIPULATED AND AGREED that 10 all objections, except as to the form of the 11 question, are reserved to the time of trial.
12
- 13 c:)
14 -ooo-15 16 RICHARD C. N O L L, having i
17 been first duly sworn by the Notary Public, 18 testified as follows:
, 19 EXAMINATION BY 20 MR. WISE:
21 Q Mr. Noll, please state your full name and ggg.
22 current business address for the record.
23 A' Richard ~ Charles Noll, Metropolitan Edison ;
i 24 Company, Post Office Box 542, Reading, Pennsylvania 19643.
25
1 Noll 4 l
() 2 Q Is there a street address where you 3
maintain your offices?
l 4 A Titus Gensrating Station.
hl 5 Q Where is that located?
6 A outside of Reading.
i 7 Q What kind of a generating station is Titus?
8 A 330 megawatt fossil unit.
9 Q It burns coal?
10 A Yes.
11 MR. WISE: Let me have marked as 1
12 B&W Exhibit 896 a copy of a resume which was 13 provided to us,this morning by your counsel.
(
14 (Document consisting of a copy of 15 the resume of Richard C. Noll was marked 16 B&W Exhibit 896 for identification.)
17 Q Mr. Noll, did you prepare B&W 896 which i 18 appears to be a copy of a resume for you in 19 preparation for this deposition?
20 A Yes.
- 21 Q Does it accurately reflect your educational ,
i 22 experience and the various jobs you have held since ;
23 ' graduating from college?
i 24 A Yes.
l
~
25 Q Your resume indicates you graduated from l l
1 Moll 5 2 Drexel University in 1971 with a bachelor of science O 3 degree in electrical engineering.
4 Have you had any other formal education h 5 since that time?
6 A No.
7 Q Your resume indicates that upon graduation 3
8 from school you went to work for Metropolitan Edison 9 and with the exception of a military leave of absence 10 from September 1971 to February 1972 you have worked with 11 that company ever since, is that correct?
12 A Correct.
13 Q When was the first time that you had any l
14 involvement,in the commercial use of nuclear power to 15 generate electricity?
16 MR. GLASSMAN: I am not sure what you mean 17 by involvement.
18 Q Did you take any nuclear engineering 19 courses while you were in college?
l i 20 A No.
l 21 Q Your resume indicates that your first 22 position upon joining Metropolian Edison was in the f I
23 system p1anning department.
24 Did that have anything to do with the 25 commercial'use of nuclear power to generate electricity?
l' Noll 6 4
l 2 A No. ,
3 Q "h*" "*" th* fi"** *1"* 1" th' **#1 ""
4 jobs yoQ have held at Met Ed that you had a position l
that involved responsibility concerning a nuclear {
lhf 5 6 power generating station?
1 7 A January of .1977.
8 Q What happened then?
9 A That's when I joined the generation l 10 engineering department, the electrical and control 11 engineering section as an engineer.
12 Q Where did the generation engineering 13 department have its offices at that time?
14 A The main office of Met Ed, 2800 Pottsville 15 Pike.
16 Q That is in Reading, Pennsylvania?
17 A Yes.
18 Q How was that department organized at the 19 time you joined it?
20 A There was a manager of engineering, 21 under him various departments. The one department I 22 was in was the. electrical control engineering section ,
l 23 and I was an engineer assigned to that section. '
24 Q Who was the manager of the generation C$ 25 engineering department at the time you joined it?
1 Noll 7 l
2 A Dick Klingaman.
3 Q Who headed the electrical control 4 engineering section at the time you joined it?
h 5 A George May.
6 Q How many people were in the electrical 7 control engineering section besides Mr. May and 8 yoursel.$ and I am speaking now of professionals, I am 9 excluding the clerical and support staff?
10 A Two, two other engineers.
11 Q What were their names?
2 A Al Tothero and Al Tribble.
13 Q How many ogher sections were there in 14 the generation engineering department at that time?
15 A I don't recall the total. There was three' 16 or four others.
17 Q What were the other ones as best you now 18 recall them?
19 A Mechanical section, environmental section, 20 economic section. -
21 Q can you recall any others?
22 A No. j 23 Q- Who headed the mechanical section? l l
24 A Rudy Lefin.
25 Q Who headed the environmental section?
i i
e
+ 9 -,
1 Noll 8
./~N
() 2 A Jim Mudge.
l 3 Q Did the environmental section have anything l 4 to do with licensing requirements?
lh 5 A Not that I recall. l i
6 Q Who headed the economic section?
7 A Norm Williams.
8 Q What was your understanding of what the 9 areas of responsibility were for the electrical 10 control engineering section?
11 A Our responsibilities were to conduct an 12 independent safety review for the nuclear stations, Provide engineering assistance for any generating
) 13 ,
14 station for electrical and control engiceering only.
15 Q I guess that is what my question is really 16 aimed at.
17 Could you briefly describe for us what you 18 understood to be the ambit of the electrical and 19 control engineering work?
20 A Could you clarify that? I am not sure 21 what you mean.
22 Q Electrical and control engineering may i 23 have meaning to you, but it may not to a layman or a i i
fN 24 judge. If you could try and describe in simple terms
( )
R./
25 briefly what the electrical control engineering
1 NO11 9 2 consists of.
A It would -- let's see, keeping it brief, 3
4 it would consist of any electrical system or control l/ 5 . system in a power station that would require 6, engineering assistance to resolve a problem or 7 something, a change or modification or something like 8 that.
9 Q Maybe one way to get at this would be to 10 have you briefly describe your understanding of what 11 the other sections handled and then perhaps we can 12 see the difference between what your section was .
13 involved in and what the others were.
14 First, perhaps, take the mechanical 15 engineering section.
16 A They would be responsible for any 17 mechanical, piping or systems-type approach for power 18 plant equipment.
19 Q what do you mean systems approach?
20 A An example of a system would be control 21 air system, startin, from the air compressor including g
22 all the piping running to a valve, they would have l responsibility for that area. I 23 24 Q I take it those are systens or components
(% -
l k- 25 that may use electrical controls at some point?
1 Noll 10 ,
I
() 2 A correct, and we would be an associate 3
with them if they needed assistance.
4 Q But they would be responsible pr'imarily 5 for the mechanical features as opposed to the 6 electrical features of such systems?
I 7 A correct.
8 Q What did you understand the e.nvironmental 9 section to be responsible for?
10 A Their responsibility was environmental 11 conditions, permits, associated with the generating 12 station, securing tne permits, administrating the 13 conditions of the permits, filing them, reports that i 14 were necessary for the permit, that type of function.
15 Q To your knowledge did the environmental 16 section deal with the requirements of the Nuclear 17 Regulatory Commission or was that handitd somewhere 18 else in the company?
19 A That I understand was handled by our 20 ' quality assurance , group, our licensing group.
, 21 Q You also mentioned there was an economic g
- 22 section shown that was part of the generation .
t ,
23 engineering department. !
24 'What was the responsibility of:that 0)
- 25 section as you understood it?
l
-, - -n,
g Noll 11 2
A They looked at plant performance in the economy of generating.
Q Approximately how many people were in the 4
c ,
mechanica1 engineering section, and I am again s,eaxing 6
f pr fossionals and excluding clerical or support staff.
7 8
MR. GLASSMAN: You don' t want the witness 9
to guess. He was'not in the section.
10 Q W uld y u have approximate knowledge?
gg Would it be something over 100 people?
12 A No.
13 Q Would it be over 10 people? .
O 1. A Yes.
15 Q W uld it be over 207 16 A I d n't recall.
37 Q Could you give us the range? Do you think I 18 there were at least 10 and perhaps as many as --
19 MR. GIASSMAN: Do you want the witness 20 to guess?
21 MR. WISE: No, I am asking him for his 8 knowledge of the range. He knows there weren't f
22 23 m re than 100.
A The range, 10 to 20.
3 25 Q Y u mentioned the quality assurance ,
1 Noll 12 department. Who headed that up at the time you were
) 2 3
there in early '777 i
4 A Sandy Lawyer.
, 5 Q Did that department also have its offices 6 in Reading?
7 A Yes.
8 Q Did it have various sections?
9 A Yes. .
10 Q Are you familiar with what those were?
11 A The two sections I am familiar with are 12 licensing and quality assurance.
13 Q What was your understanding at the time
(
14 as to what the functions were of the licensing 15 section and then the quality assurance sections and-16 take that in two questions if you wish.
17 A The licensing section was responsible for 18 licensing the nuclear plans and all appropriate, you 19 know, administration of those licenses. ~ Quality 20' assurance was what the name implies, responsible for 21 the quality assurance of the generating station.
22 Q Who headedfthe licensing section at that' -
23 time?
l !
_,A 24 A Bill Potts. !
25- Q Who_ headed the QA section at that time? i
1 Noll 13 2 A Ron Prabhakar.
3 Q Again I w n't hold you to any specific 4 number, but can you give me some idea lh- 5 aPProximately how many people you understood were in 6 the licensing section in early ,'777 7 A I couldn't even guess because it varied.
g Q Can you give us a range?
9 A The bounds would be so big, I wouldn't 10 know.
11 Q Would your answer be the same for the 12 quality assurance department?
13 A Yes.
)
14 Q Did you have regular contact with the 15 members of the licensing and quality assurance 16 sections of the QA department during the time you were 17 in the electrical control engineering section of the 18 generation engineering department?
19 A What do you mean by regular contact?
20 Q Day-to-day.
A I would see them and say hello, yes. Not g 21
~22 necessarily, no. ;
i !
23 l Q Were they in the same building?
1 24 A Yes. i
, f -
l
' ( i o5 Q Were they on the same floor that you were
1 Noll 14 i (N located on? I 2
(_ !
3 A res.
4 Q Were there ever occasions before the ll) 5 accident at Three Mile Island in March, .1979 where 6 you worked directly with members of the QA department?
7 A Not directly, no.
8 Q So that for you personally it would not be 9 normal for you to work jointly on a project with a 10 member of the QA department?
11 A No.
12 Q As of January, 1977 how many electrical 13 generating plants was Met Ed operating?
(']
'% /
14 A Four.
15 Q What were those?
16 A Titus, Portland, TMI-1, York Haven.
17 Q Is it true that Titus, Portland and York 18 Haven were coal fired units?
19 A Titus and Portland are coal fired. York
~
20 Haven is hydro.
21 Q Hydro. Was the generation engineering i
22 department responsible for providing engineering i i 23 assistance to all four plantc? !
I 24 A res.
> t'>
2 25 Q During early 1977, can you give us any O
1 Noll 15
'T idea of the percentage of your time that was spent on (b 2 TMI-1 matters as opposed to the other three 3
4 generating plants?
5 A The exact percentage I couldn't give you.
6 Q I don't want an exact percentage. Would 7 you say you were spending all your time on the TMI-1, 8 a small part of it, about 50-507 9 A A major part.
10 Q During early 1977 did you have any 11 responsibi'lity for the TMI-2 nuclear generating 12 facility?
~N 13 A No.
\
.)
14 Q Your resume indicates that you remained 15 in the electrical and control engineering section 16 of the generation engineering department from January 17 1977 through to the end of 1977. It also indicates 18 that in January 1978 you undertook a new assignment 19 at the Three Mile Island nuclear station.
l 20 Could you describe what that assignment i
21 was?
22 A It was temporary assignment to assist the ;
i 23 Unit 2 lead electrical engineer in startup.
24 Q Who was the Unit 2 lead electrical f )
~_/ 25 enginear? j l
l l l
1 Noll 76 2 A Dick Bensel.
(~/)
\_
3 Q For whom did he work?
4 A Jim Seelinger.
h 5 Q Both Mr. Seelinger and Mr. Bensel as I 6 understand it were Met Ed employees?
7 A correct.
8 Q Did you interface at that time with any 9 employees of GPU Service Company?
10 A No.
11 Q Was there an electrical and control 12 engineer for the service company on the site at that
(~' 13 time to your knowledge?
14 A Yes.
15 Q Do you know who that was?
16 A Ivan Porter. I 17 Q Is it correct then that your work on 18 electrical and control engineering matters was done 19 separately from the work that Mr. Porter was doing 20 for the service company?
21 A correct. Correction, it was just 8 electrical there also, i
22 i 23 Q Excuse me?
l 24 .A It was only electrical functions, the {
t'~'r
control engineering dropped during this assignment.
25 I
I 1 Noll 17
^
j
()s 2 Q So.you were responsible only for electrical 3
but not for the control engineering?
4 A correct.
I am not sure I understood from your l() 5 Q 6 earlier description exactly what the distinction 7
between electrical and control engineering was.
8 Perhaps you could describe that.
9 A Okay. Earlier the control area would 10 include control of the electrical components plus 11 its appropriate instrumentation. During the 12 assignment at TMI it was strictly the electrical I 'T 13 aspect, the instrumentation was handled by an V
14 instrument engineer, and I was not involved in that 15 area.
16 Q Who handled that?
17 A John Brummer who was the Unit 2 lead 18 instrument.
19 Q During the time that you were temporarily 20 assigned to Unit 2, did you perform your work I
21 actually at the site?
l 22 A Yes.
23 Q Your resume indicates that you were there w 24 for six months from January of 1978 to June of 1978, 25 is that right?
1 Noll 18 2 A Correct.
3 Q Prior to going to TMI-2 on this temporary 4 assignment, had you received any training concerning li 5 the electrical systems in the TMI-2 nuclear station?
6 A No.
7 Q what method did you use to familiarize 8 yourself with the design of the TMI-2 electrical 9 systems?
10 A On-the-job training.
11 Q That began when you arrived there in 12 January of '787 13 A correct.
14 Q What was your understanding as to why you 15 were temporarily assigned to TMI-2 at that time?
16 A To assist Dick Bensel with startup duties, 17 whatever assistance I could provide him to ease his 18 workload.
19 Q Did you understand at the time that he 20 had more work to do than he could accomplish by
'21 himself?
22 A Yes. I 23 Q Your resume indicates that as at-the end 24 of June, 1978 and beginning in July, 1978 you
-O: 25 returned to the generation engineering department in
i Noll 19 1
2 Reading, is that right?
A correct.
3 1 4 Q And you remained there until the time of the THI-2 accident at the and of March, 19797 5
6 A Correct.
Q Your duties and responsibilities from 7
g July, 1978 through the time of the accident remained 9
the same as they had been during 19777 10 A Yes.
11 Q Up to the time of the March 1979' accident i
12 at TMI-2, did Mr May continue to be the section head
}3 of the electrical and control engineering sections?
14 A Y88-Q Did the size of that section change up to 15 16 the time of the March, 1979 accident?
17 A No.
18 Q I understand that Mr. Klingaman continued as 19 manager of the generation engineering department through the time of the March, 1979 accident, is that right?
i 20 21 A Yes.
^
l Q Just let me clear up a couple of things l 22 s
on the post-accident matters. Your resume indicates 23 24 that after the accident during the period April,'1979 1(;'ju 2s to aune, i979 vou ,rovided engineering support at i
1 l .
. - m - - - . - , y. . ,e. - ,
1 Noll 20
/~' 2 TMI-2, is that right?
3 A correct.
4 Q You were actually down on the Island at 5 that time? ,
6 A Yes.
7 Q What sort of things were you doing?
8 A Assisting the plant engineering staff in 9 procedure writing review, revision and also with the 10- modifications necessary to restore the plant to e 11 stable condition.
12 Q That was essentially part of the recovery s 13 effort?
~) A Yes.
14 15 Q" You were not performing an investigative 16 function at that time?
17 A No.
18 Q Your resume indicates that in July 1979 19 you returned to the generation engineering department i
20 where you remained until October 1979. I take it l 21 that you were then performing the same duties and ggg 22 responsibilities that you had earlier? l 23 A Yes.
l 24 Q Did you have any connection with the im
-) 25 investigation of the TMI accident during the period +
1 Noll 21
/"N 2 July to October 19797
' ,)
\
3 A , No.
4 Q Your resume indicates that after October hi 5 1979 you took a position at the Titus Station and 6 that you have held varicus positions since that time up 7 to the present at Titus, is that right?
8 A Yes.
9 Q Since October 1979 I take it you have had 10 no connection with nuclear power generation?
11 A Correct.
12 Q And you have had no further connection with g- 13 the THI-2 accident?
b) 14 A Correct.
15 Q And you have had no participation in any 16 investigations or analyses that have been performed 17 concerning the TMI-2 accident since October 1979?
18 A Can you rephrase that again?
19 Q Is it true that since October 1979 you 20 have personally had no involvement in any 21 investigations or analyses that have been performed 22 respecting the TMI-2 accident?
23 A Correct.
24 MR. GLASSMAN: Off the record.
l s
( ,) 25 (Discussion off the record.)
i
g Noll 22 t'D 2 Q Turning back now to the period between U
3 3*""**Y' 1977 "h*" Y"3 I"*d th" 9'"*#^*1 "
4 engineering department and the time of the TMI-2 accident, what was your understanding as to the h 5 6 responsibility of the Met Ed generation engineering 7 department regarding events or transients that 8 occurred at TMI-1 or TMI-27 9 A' I guess I don't understand what you mean 10 by " responsibility" did you say?
11 Q We Will.come at it more slowly.
12 A Yes.
T 13 Q You understand what I mean by a transient d
14 at a nuclear plant, do you not?
15 A could you explain it, what you mean so I 16 know. My interpretation may be different than what 17 you call it.
18 Q What is your understanding of a transient 19 at a nuclear plant?
20 A Abnormal occurrence.
21 Q Let's use that definition.
S A okay.
I I
22
- 23 Q You understood that from time-to-time ,
I 24 transients occurred at TMI-17 l
( '
25 A Yes.
1 Noll 23 You understood that they occurred at TMI-27
( 2 Q 3
- A During this time, January of '77 to f December of '77, no, no awareness of TMI-2, strictly 5 TMI-1.
6 Q Let's just limit it to TMI-1 for the 7 moment. -
8 To your knowledge did the generation 9 engineering department in Reading have any regular 10 function with respect to transients that occurred at 11 TMI-17
~
12 A No.
13 Q What was your understanding as to whose
}
14 responsibility it was to investigate and analyze to 15 the extent it was necessary to do ao, transients that 16 occurred at TMI-1 during 19777 17 A Plant staff.
18 Q That is the Met Ed personnel who were 19 located at the Island itself?
20 A Yes.
21 Q During 1977 can you recall any instances l 9 in which the generation engineering department in I
22 23 Reading was called upon by the plant staff to provide l l
,_ 24 engineering support regarding transients that had I t
'~
25 occurred at TMI-17
1 Noll 24 A I don't recall any.
( 2 3 Q To your knowledge during 1977 was there any 4 system in place in the generation engineering lh 5 department of Metropolitan Edison for reviewing on a 6 regular basis publications concerning operating events 7 at nuclear plants in the United States?
8 MR. GLASSMAN: You are talking about 9 anywhere in the department or in Mr. Noll's 10 section?
11 MR. WISE: Anywhere in the department.
12 MR. GLASSMAN: I don't know that he is 13 competent to testify about that kind of thing, (V'T 14 Mr. Wise. He told you he had a particular 15 function in a particular section. The question 16 is objectionable.
17 MR. WISE: If you want to bring out on 18 cross examination any limitations on what he 19 knows,you are free to do so. I think it is a 20 fair question. -
21 MR. GLASSMAN: Can we have it read back?
t 22 (Question read. ) !
r 23 MR. GLASSMAN: And he will see if he can
,_ 24 answer it with regard to his knowledge if he has !
l )
'v' ,
1 Noll 25 2 (Answer read.)
3 A I wasn't aware of them.
4 Q Did you personally ever undertake to make a 5 Periodic or regular review of publications concerning l 6 operating events at nuclear stations in the United 7 States?
8 A No.
9 Q . In 1977 were you even aware of what the 10 publications were that reported on operating events ,
l 11 for nuclear plants in the United States?
12 A No.
13 Q Would your answers he the sam,e concerning 14 your awareness of such publications during 1978 and 15 up to the time of the accident at TMI-2 in March, 16 19797 17 A Yes.
18 Q Did you ever receive any reports during 19 1977 on the progress of the startup and test program 20 that was taking place at TMI-27 i 21 A Not that I recall.
22 Q Do you know whether anyone in your ,
1 23 section did?
24 A Not that I recall'.
i
- 25 Q You_ don't know one way or.the other, or i i
.\
1 Noll 26 gj s
2 you believe that they did not? Your answer was 3
ambiguous. I am not sure which you meant.
4 A I am not aware that anybody received them lh 5 in our section.
6 Q To the best of your knowledge,they did not?
7 A To the best of my knowledge they did not.
8 Q When you arrived at TMI-2 in January, 9 1978, did you personally undertake any rev'iew of 'he 10 existing logs and data that had been accumulated 11 concerning the startup and test of TMI-27 12 A No.
I Q Did yo'u at any time during the period you C) 13 14 were on site at TMI-2 from January, 1978 through June 15 of 1978 make a review of the startup logs for Unit 27 16 A No.
17 Q Did you ever see those logs?
18 A Yes.
19 Q Who maintained those logs as you 20 understood it?
91 A GPU.
22 i Q That is the service company?
23 A Yes.
I At that time Unit 2 was still a service I i 24 Q Ix ;
L.)
25 company responsibility as I understand it?
i \ \. -
).., ,
1 Hall 27
- o., m
+
t i
[) MR. GLAS5 MAN) Is that a question or a'
-2
\A s g.'
! statement?
3 +
1 4 Q Is that right, d o e 's that conform with 6 5
y ur understanding? ;
s 6 A My und3rstanding , yes.
I s 7 Q It-h d not yet baen turned over to Met Ed 8 for opetsiion,t,is that correct?
5 s s
s9 A Correcte ,
- 1
\
,10 ,
Q Am I correct that fuel was first leaded
\
All at TMI-2 during February, 19787 l 12 ,
A To my be'st recollection, yes.
/
); 13' A And the first criticality of the unit V 14' occurred, I believe, '6n March 28, 19787 h
15 A I'am not su're of th'e exact date.
, t 16 Q Yl>u were there when the plant first went
! 17 ciitical?
l 18 A Yes.
1 19 Q You remember that as an event?
- s 20 A Yes.
21 Q Regardless of the exact day whether it was 22 the 28th or the 29th or the 27th, am I approximately ,
23 correct that it was in late March, 1978 that the unit l
24 first went critical?
fw i i
%~,l 25 A Yes.
g Noll 28 h 2 .
Q At any time before the accident at TMI-2 3
in March, 1979, did it come to your attention that 4 there had been an event during hot functional testing h 5 in mid-September, 1979 at TMI-27 6 MR. GLASSMAN: You have the wrong year.
7 Q At any time before the accident at TMI-2 8 in March, 1979 did it come to your attention that there 9 had been an event during mid-September, 1977 during 10 hot functional testing of Unit 27 l
11 A No.
12 Q You mentioned that you had seen the GPU 13 logs. To your knowledge were those under the control 14 of the service corporation?
15 A To my knowledge, yes.
16 Q I take it you did not personally make 17 entries in those logs?
18 A No.
19 Q Did you ever see any Met Ed personnel l l
20 making entries in those logs?
g 21 A No.
t 22 Q Was it your understanding at the time'that i i
23 those logs were kept by the service personnel?
24 A Y*8-O 25 Q Do you know where they were kept?
1 Noll 29 A In a room outside the control room.
( 2 3 Q Was that room kept locked?
4 A To my knowledge, no.
5 Q Were the logs kept locked up?
6 A I don't recall.
7 Q Did you ever make a request to see the 8 1ogs?
9 A- No.
- 10 Q You don't know at this point what 11 Procedures, if any, there were for who could have i
12 access to the logs?
13 A No.
'14 Q You mentioned a moment ago that the plant 15 first went critical on March 28, 1979. I don't 16 believe you were able to testify to the day.
17 However, I will represent that we have had 18 established through other records that I believe it 19 was March 28, 1978 when the-plant first went critical.
20 Do you recall that shortly after the plant' 21 went critical there was an event at TMI-27 ggg 22 'A What do you mean by " event"? I s
23 MR. GLASSMAN: I was going to make the
~
24 same objection, the meaning of the word " event."-
p
\
J ' 25 Q There was an abnormal occurrence a't TMI-2
--- r -
- w e ,- -wm'-r
_ N m
1 Holl 30 h, 2 within 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> of the time that the plant first went 3 critical?
4 MR. GLASSMAN: Same objection, I don't t 5 know what you mean by abnormal. If there is a 6 particular kind of event you have in mind why 7 don't you tell him and we can get on with it.
8 MR. WISE: I think we can get the 9 witness' answer.
10 Do you recall anything unusual happening Q
11 following the first criticality of the unit in late 12 March, 19787 13 A There were a lot of unusual occurrences 14 with a few plants going critical. I don't know what 15 you would be --
3 I really don't remember a rather 17 significant event that occurred within forty-eight 1R hours of the plant going critical.
' I can remember a lot of significant 20 events.
l g 21 Q What is the most significant event that 22 you can recall happening within forty-eight hours 23 after the plant went critical?
l 24 MR. GLASSMAN: Mr. Wise, I am,not going fm
/ 25 I
to have this witness evaluate significance or
. . =- ._
l 1 Noll 31 2 lack of significance of something within a 48-h ur period. I think we know that you have some-3 4
thing in mind. If you can identify it I am 5
sure the witness can tell you whether he knows 6 anything about it.
7 MR. WISE: I am afraid I am going to press 8 the question. I think it is important what his 9 understanding was and what his attitude was 10 towards the startup and test of this nuclear 11 station..
12 -Q Can you remember something ,significant 13 happening within 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> of the time that the plant J
14 first went critical?
15 A I don't recall within 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> aything 16- significant.
17 Q Do you recall that on March 29, 1978 18 there was a failurs of an electrical bus at TMI-27 19 A I don't recall a failure of an electrical 20 bus. ~
L l
21 Q Do you recall that there was some 9 problem with an electrical bus?
22 23 .A What do you mean-by problem?
24 Q It didn't work as it was supposed to.
O.
I k-< 25 'A I don't recall that, no.
l '- .
-.- , ,, .- .- , . - - . . . . . . . . .- a, . . -
. l 1 Noll 32 2 Q Do you recall that there wa,s an emergency safeguards actuati n at TMI-2 on March 29, 1978?
3 A I was aware of an ES actuation. The exact )
4 1 k 5 date I am n t sure of.
6 Q Do you remember what caused the ES 7 actuation?
8 A Reactor coolant pressure dropping below 9 its ES setpoint.
10 Q- What kind of an event was going on at the 11 time that occurred?
12 A ES testing.
1 s 13 Q Do you recall an event in which a failure 14 to one of the electrical buses resulted in a loss of 4
15 instrumentation and a loss of power to the pilot 1G operated relief valve for a period of some four or 17 five minutes on March 29, 19787 18 A Yes. The exact date I am not sure of, but
! 19 I recall the occurrence.
20 Q How did-that first come to your attention?
21 A I was in the control room.
22 Q What happened?
23 A I was assisting. Dick Bensel-in performing _ !
24 ES testing.
f^ -
\- 25 Q And what occurred at that time? ,
O o - -
<~- , ,>v <, ~ ~,,,--,,w - - - , -
1 Noll 33
( A- While doing the testing the plant
(_/ 2 3 experienced a trip and ES actuation.
4 Q Is that all you know about it?
h 5 A ,
well, at that time that is what I knew 6 about it. I was new and I just stood there, I didn't 7 know what was happening.
8 Q What time of day did this occur?
9 A My recollection, morning.
10 Q Were you aware at the time how long the i I
11 plant had been critical?
12 A No.
O
(_) 13 Q You don't remember that it was the day
}
14 after the plant went critical that this occurred?
15 A No, I would have no reason to know that.
16 I was involved with the electrical. I was new. l l
17 Q You do remember the plant going critical?
18 A oh, yes.
19 Q That was quite an event as it has been 20 described to me by others.
! 21 A To_ people that were there permanently ,- it ggg 22 would have made more impact than me who was a l 23 temporary assistant. <
l l t t'~'i 24 Q But there was some celebration going on Q) 25 as a result?
l l
1 Noll 34 2 MR. GLASSMAN: Celebration? Are you O. ,
talking about a party? I don't know what 3
4 you're talking about.
5 Q People were remarking on'it, it was not 6 an everyday event at the Island the fact that the ,
7 unit had gone critical?
1 8 A I was aware it was not an everyday event, 9 yes. The time table in between, I was not aware of.
10 Q What were you and Mr. Bensel doing on the 11 morning of the 29th when this event took place?
12 A I was watching Dick Bensel assist the r- 13 technician or operator, whoever it was, perform ES
(
14 testing which was required by the tech specs.
15 Q What was being done, when you say ES 16 testing?
17 A Tech specs required surveillanco testing
- 18 of the engineer and safeguard system. This was one 19 of the routine tests that was going to be performed 20 that day.
21 Q Could you describe'the test?
gg {
i 22 A Basically what the test does is 23 simulate the need for actuation and that all the i
i
- I l 24 engineering safeguards components do in fact start.
w t
) 25 Q How was the need for actuation simulated?
l l
1 Noll 35 2 A I don't recall the exact technical way it
., ..s simu1.t.e.
4 Q Was the test in progress at the time the 5
event occurred?
6 A Yes.
7 Q Were there other Het Ed employees besides 8 you and Mr. Bensel present in the control room?
9 A Yes.
10 Q Do you recall approximately how many 11 PeoPl e were there?
12 A I would be guessing. -
13 Q Were there members of the service 14 corporation present at the time?
15 A I would be guessing also.
I 16 Q You don't have any specific recollection 17 of anyone being there?
18 A Being new I don't --
didn't know~that many 19 PeoP l e at that time.
20 Q As the test was proceeding what was the ,
21 first thing that alerted you that something had 22 happened that was not supposed to happen?
l
! 23 A someone yelled "The reactor tripped,"
l I
24 then various alarms came into'the control room and
.b i/ there was anxiety or confusion amongst eve rybody that j
_ 25 r , - m e.- , w- , - - - - -
1 Coll 36 was in there on what was going on.
) 2 Q Wh was in charge at that time?
3 4 A It would have been the shift supervisor.
5 Q Do you recall who that was?
6 A Marshall Beers. ,
7 Q What is your best recollection as to what 8- was done following the reactor trip by those in the 9 control room?
10 MR. GLASSMAN: You are talking about i 11 anyone in particular or by some undesignated 12 group?
13 MR. WISE: Just what he recalls the people
(
14 in the control room did.
15 A I don't know what they did because I had 16 no idea what they were doing, being new in there at 17 the time of the occurrence. I just stood there and 18 watched.
- 19. Q Did you personally observe any of the 20 parameters in the plant?
21 A No.
.O 22 Q You don't remember what happened to 23 pressure during the. event?
. 24 A. No.
25 .Q You' don't'know what happened'to i
~
l 1 Noll 37 2 Pressurizar level during the events?
3 A 8'*
4 Q You don't know what happened to reacter lhi 5 coolant system temperature during the event?,
6 A No.
7 Q Did you make any observation of the 8 instrumentation in the control room at that time?
9 A No.
10 Q Were you aware during the event that there 11 was an actuation of the emergency safeguard system?
12 A Personally, no.
13 Q Did you find out that there had been after I T
14 the event was over?
- 15 A Yes.
s 16 Q Who told-you about that?
17 A Dick Bensel.
18 Q How long after the event was over did he 19 advise you of that? _ Was it something within a few 20 minutes after the. event or was it something you 21 learned weeks and weeks later?
9 A As I recall, a few hours.
I 22 l I
23 . Q How long did the event take? Was it over i
I 24 in a matter of minutes'or did it take an hour or two" s/ 25_ to square it away?-
, , , - . . - - - - - - - - . - , .- - - + -
1 Noll 38 2 A I recall a few minutes.,
f^hw) 3 Q It was then your impression that the plant 4 had been put back under control?
h' 5 A Yes.
6 Q What occurred or transpired in the control 7 room immediately following the first few minutes of 8 th e event?
9 A Operators were going about the various 10 stations turning controls on and off. I assume they 11 were doing what thep were supposed to be doing.
12 Q Did you have any understanding as to r' , 13 whether the plant was going to be put back on line N.))
14 immediately or whether the plant was going to be 15 cooled down?
16 A I didn't know.
17 Q During the event, did you continue g 18 discussing matters with Mr. Bensel?
19 A No.
20 Q What did Mr. Bensel do?
21 A He went out and did something. I just 22 stood there, you know, observing, not ever experiencing .
23 anything like that, just watching.
24 MR. GLASSMAN: Off the record.
(~h)
(
'/ 25 (Discussion off the record.)'
1 Noll 39 2 Q After the event was over, when was the 3
first time that you had an o'pportunity to speak with 4 anybody about what had happened?
lh 5 A within a few hours Dick Bensel informed me 6 of the occurrences and what had transpired.
7 Q What did he tell you?
8 A To my best recollection, the ES testing 9 had interrupted a power supply to a vital bus because 10 an inverter that normally supplied that vital bus had 11 switched over to an alternate source. This alternate 12 source, in turn, was designed to be tripped during 13 ES testing and it did in fact work. By tripping that 14 vital bus it interrupted power to the NNI 15 instrumentation which NNI instrumentation served as 16 a control for the pressurizer relief valve.
17 The pressurizer relief valve opened up, 18 thereby reducing system pressure to below the ES 19 actuation point causing ES to totally actuate.
20 Q What else did he tell you about the event?
21 A That was it that I recall.
22 Q Did he explain how the event had been :
23 terminated?
24 A No.
25 g Did you ever come to learn how the event
1 Noll 40 was terminated? -
. O 2 A Yes.
3 4 Q What did you learn?
Learned that power was restored to the ll) 5 A 6 bus and the relief valve closed.
7 Q Did you personally make any investigation 8 of the event after it occurred?
9 A My investigation was strictly limited to 10 the reason the inverter failed.
11 Q So you did participate in the 12 investigation following the event?
13 A Strictly of the inverter failure.
14 Q Who else was investigating the event?
15 A To my knowledge plant staff and GPU 16 Service Corporation.
17 Q You don't know who else was working on it?
18 A No.
19 Q Who asked you to undertake the specific l 20 aspect that you mentioned?
l 21 A Dick Bensel.
! l 22 Q Did you make a written report to him?
l 23 ~ A No, I followed through with the Met'Ed I. :
l l -24 electrical maintenance department-and restoring the
(~h .
\s_/ 25 inverter to its proper operation.
1 Noll 41 2 Q So that no writing resulted from your (V~)
3
" *k?
4 A Would have been the work procedure for 5
w rking on the inverter.
G Q But in terms of a report or analysis?
7 A None.
8 Q To your knowledge, did anybody else 9 prepare a report or an analysis with respect to the 10 event? ,
I i
11 A I don't recall if they did. '
12 Q You don't recall ever seeing any such report or analysis?
('/
Ni 13 I
\_
14 A No. I 15 Q You don't recall
- knowing of anyone who j 16 was working on an analysis or report?
17 A No.
18 Q Do you know what the operators did with 19 HPI after it came on?
20 A No. .
21 Q Did you ever hear any discussion 22 concering how the operators had managed HPI during l
23 the course of the March 1978 event?
l 24 A I don't recall.
/s
( I 25 Q Did you ever hear any discussion of what
1 Noll 42 2 had happened to pressurizer level during the course 3 of the March 1978 event?
4 A I don't recall that.
5 Q Following the March 1978 event, did you 6 become aware of any desire on the part of the 7 Operating staff to have an indication light installed 8 in the control room which would show the position of 9 the pilot operator relief valve?
10 A Yes.
11 Q How did you first become aware of that?
12 A Dick Bensel informed me that a request 13 was going to be made to not pnly install an 14 indicating light but to change the controls so that 15 loss of power to the instrumentation did not cause it 16 to open.
17 Q When did he inform you of that?
18 A Within a few days of the occurrence.
19 Q Were you to have any responsibility with 20 respect' to that. work?
g 21 A No.
22 Q Who was?
23 A GPU Service Corporation.
24 Q Did Mr. Bensel say anything else to you
f 25 at that. time'concerning the installation of an
1 Noll 43
() 2 indicator light?
3 A Not that I recall.
4 Q Did you perform any further work at that 5 time concerning the installation of an indicator 6 light?
7 A No.
i 8 Q Was that the last you heard of it before 9 the March, 1979 accident?
10 A No.
l 11 Q When did you next hear about it?
12 A When I was back in generation engineering.
13 It would have been prior to the accident a request l (
14 was made from Unit 2 to change the indicating light 15 pick-up point.
l 16 Q We will come to that later.
17 A Okay.
18 Q You were actually standing in the control 19 room at the time the March 1978 event occurred.
20 Can you recall after the event was 21 terminated and operators regained control of the ggg 22 P l ant, what was the - - -
how would ycu describe the ,
23 atmosphere in the control room at that time?
24 A Normal.
)
'( O '
25 Q Did People seem in any_way excited by
- . _ , .a- - - -. - - ,
1 Noll 44 I
1
/~ what had happened? l
( )) 2 l A IW uld P h rase it as concerned, not 3
4 excited. They were anxious to determine what had l' 5 happened. I mentioned earlier that is when Dick Bensel 6 informed me what had happened, within a few hours.
7 Q Did you remain in the control room for 3 several hours after the event occurred?
9 A No.
10 Q When did you leave the control room?
11 A To my best recollection within an hour 12 of the ~ occurrence.
13 Q You were also at the Island when an event b(~N 14 occurred involving one of the main steam relief valves 15 on the secondary side sticking open, were you not?
16 A Yes.
17 Q Do you recall that that occurred in late 18 April, 19787 19 A Approximately in that time frame.
20 Q We have established through other 21 documents and witnesses that the event took place 9
- on April 23, 1978.
I 22 l 23 Does that roughly conform with your j
, 24 recollection?
i r i "" / i 25 A Yes. i i
l
'l Noll 45 Q When did you first learn of that event?
[)>
x- - 2 3 A My rec 11ection would hava been the next 4 day.
h 5 Q You weren' t present on the site when it 6 occurred?
7 A No. I was on my way home.
8 Q Did anybody notify you at home that g evening that the --
10 A No. i 11 Q --event had taken place?
12 A No.
/~) 13 Q What did you learn when you came in the
%_J 14 next day?
15 A That they had a trip and a gain that they i
16 had ES actuation.
l 17 Q Who told you about that?
l 18 A Dick Bensel.
19 Q You mentioned that they had an ES 20 actuation. Did Mr. Bensel explain to you the 21 significance of that?
9 l 22 A What do you mean by significance? ;
23 Q You mentioned that both with respect to l i t 24 the March '78 event and the April '78 event. Did you
,f-~
! /
25 over come to have any understanding as to what the ;
1 Noll 46 2 significance of what an ES actuation was?
A Due to my area of responsibility being 3
4 in electrical, significance in my interpretation l() 5 was that the actuation did occur and that all the 6 components functioned the way they were supposed to.
7 Q You understood what the emergency 8 safeguards system was all about? ,
9 A I understood it was a safety system.
10 Q It is not really funny. Some people from 11 your company said they really didn't understand what 12 i t was about.
13 MR. GLASSMAN: Wait a second, Mr. Wise.
14 You know, I don't know what is funny or what is 15 not or what implication you are trying to make 16 here. I wouldn ' t know what one person knew or 17 what another person knew. I don't know what 18 relevance it has here.
19 MR. WISE: It seems to me you both thought it 20 was awfully funny and I am just poin' ting out there 91
- have been witnesses we have had in here who didn't (B,
22 seem to know what the system was for, so it's not '
23 a silly question. ,
24 MR. GLASSMAN: Mr. Wise, we did not think 25 that the emergency safeguards system was funny.
1 Noll 47 2 I think if you were remarking on expressions of counsel in this particular situation, that 3
4 relates to the fact that the witness had h' -5 smiled because he told you that he had certain 6 .
understandings froe the perspective of his I
7 background as an electrical engineer, but g obviously that did not mean that he understood everything about the system's operation. Your f 9 10 question seemed to imply that everybody should
! 11 know everything. We all know that is not true 12 in life.
i 13 MR. WISE: I certainly didn't mean to 14 imply that by the question. I was simply trying, 15 to gain an understanding of what this witness 16 knew about the emergency safeguard system, I
17 what its functions were and how it operated l
18- during the time period of early 1978 when he was 19 at the site and two very significant events 20 occurred.
21 MR. GLASSMAN: You are entitled to ask him
'gg 22 any question you would like answered. !,
23 BY MR. FISKE:
.I 24 Q Let me go back again then.
9.h 25 -Hed you come to have an understanding by l
l I
,i i
g Noll 48
[~)
%/ '
2 the spring of 1978 as to what the emergency safeguard 3
system at Unit 2 was?
4 A I would recall I felt that I understood l h 5 what the system encompassed, yes.
6 Q How did you come to learn what the 7 emergency safeguard system was and what it was for?
8 A Through my experience of job, 1977 in g generation engineering and.a similar, system being on 10 Unit 1.
11 Q Did you understand that it was to provide 12 water to the primary system in the event o'f a loss
(~S 13 of coolant?
A 14 MR. GLASSMAN: Is your question whether 15 this was the only function of the ES systems or 16 whether this was a function?
17 MR. WISE: A function.
18 A It was a function, yes.
19 Q What other functions did you understand i
i 20 the system had?
t
& 21 A It was my understanding the engineering W !,
22 safeguard system was designed to help mitigate an 23 hypothesized accident that may occur at a nuclear 24 generating station.
f'3 .
25 C What kinds of accidents?
L
1 Noll - 49 2 A Loss of power, LOCA.
3 Q You mean LOCA the loss of coolant 4 accident?
/ 5 A Yes. Steam generator, main steam line 6 break, those types of occurrences that were analyzed 7 in'the FSAR.
8 Q Where did you gain your understanding of f l
9 the emergency safeguard system?
10 A Through my experience with Unit 1 ahd 11 its equivalent system -- it also had an ES system.
12 Q When you say your" experience," you mean 13 you were there when there were various emergency 14 safeguard actuations?
15 A No, through reviewing again the FSAR and 16 its distributions and doing my job back in generation 17 engineering the first 1977 period.
18 Q Is it fair to say that you gained your 19 knowledge of the system primarily through reading 20 the FSAR?
21 A Yes.
22 Q You never took any training courses?
i 23 A No.
(~Y- 24 Q- Or attended any classroom sessions
\._/
25 concerning thefoperation of that system? .
I
!: i
, -- - .r , -
, , --,m- - - , ----,,,a,v--
1 Noll 50 j
i / 2 A No.
3 Q Turning back to the April 23, 1978 event, 4 after Mr. Bensel informed you that the event had 5 ,
occurred, what, if anything, were you assigned to do 6 with respect to it?
7 A My recollection is I would have been -- I 8 w as assigned the responiibility to make sure that the 9 ES system did in fact work properly and that its 10 components that were supposed to come on did in fact 11 come on.
12 Q Did you make an investigation of that?
A I made a revew of it, no formal
( 13 14 investigation.
15 Q What did you do?
16 A I checked the -- I can't think of the 17 name -- alarm printout in the control room to 18 verify that ES components did in fact come on when 19 they were supposed to.
20 Q Did you do anything else besides check the alarm printout?
gg 21 22 A Talked to operators or shift foremen to !
23 get their understanding if, in fact, the ES system i i
gy 24 did in fact work properly.
! J x- ,
25 Q Who did you talk to? ;
}
1 Noll 51 I don't recall the individuals' names.
f',}
- x. -
2 A 3 Q Did you talk to the sh'ift foreman who was 4
on duty during the events?
5 A M re than likely, yes.
6 Q You don't have any recollection today one 7 way or the other?
8 A No.
9 Q Y u do recall that you talked to some 10 of the operators who were on duty during the event?
11 A Yes.
12 Q Did you make any writings reflecting 13 your conversations with them?
b(~'
14 A No.
15 Q Did you do anything else besides check ;
i 16 the alarm printer and have conversations with the I i
17 operators or some of them who were on duty during the
- 18. event?
19 A Not that I recall, no.
20 Q Based upon that review, what conclusions ;
I 21 did you draw? l lk '
3 22 , A That the ES system did, in fact, actuate .
k !
23 l and performed properly as designed.
_ 24 I
Q During your review, did you come to have
,s
( )
~~
25 any understanding as to how long the ES system was l
i Noll 52 1 l 2 allowed to continue in its automatic mode?
I 3
A I d n't recall reviewing the time.
4 Q Did you learn at any time that the 5 operators had bypassed the emergency safeguard 6 system and taken manual control of high-pressure 7 injection?
8 A Could you repeat that question?
9 MR. WISE: Would you read it back?
10 (Question read.)
! 11 A Yes.
12 Q When did you learn that?
13 A Either the next day after the occurrence O. when I was investigating it or a day after that.
14 15 Q Did you learn that from the operators?
16 A No, I questioned Dick Bensel who informed 17 me that was a normal procedure.
18 Q Did you check the procedures to see 19 whether Mr. Bensel was correct about that?
20 A I don't recall checking them.
g 21 Q Did you ever question the operators why w I 22 they took that action?. ;
23 A No.
.. . 24 Q To this day you don't know why they did?
t %
\I 25 A- To this day, no. I would say I probably i
1 Noll 53
(~ know now because of the post-accident exposure.
V) 2 3 Q At no time up to the time of the TMI-2 4 accident did you come to learn why they had taken 5 control of HPI manually?
6 A No, I considered it a normal occurrence 7 for operators to do.
8 Q Based on what Mr. Bensel had told you, 9 that is the only source of your knowledge as to what l
10 would be normal under the procedures, is that true?
I i 11 A Yes.
12 Q Did you learn what the operators did with
/'T 13 HPI after they had taken manual control during the D
14 event in April, 19787 15 A I don't recall what they did. I knew they 16 took control, but I don't recall what they did with it.
17 Q Did you learn that they throttled HPI?
18 A I would say yes.
19 Q Did you make any investigation as to what 20 happened to reactor coolant system pressure during 21 the April 23, 2978 event?
jgg i
l 22 A Yes.
23 Q You had to do that in order to determine :
24 whether the emergency safeguard had actuated at the '
l r~N 25 Proper time? !;
i
1 Noll 54
() 2 A Correct.
3 Q You f und, I take it, that reactor 4 coolant system pressure fell during the event?
5 A correct. ,
6 Q And as it fell it reached a setpoint 7 upon the emergency safeguard actuation?
8 A Yes.
9 Q That is approximately 1640 psig at Unit 27 n
10 l A From what I recall, yes.
11 Q At that time the emergency safeguards 12 came on?
13 A Yes.
14 Q Did pressure continue to fall?
15 A I don't recall if it did or not. I was ,
l 16 just looking at the trace to confirm that it did in 17 fact hit the actuation point. That would have been the 18 and of my review of it.
19 Q You were familiar with the electrical 20 aspects of the operation of the emergency safeguard 21 system?
22 A Yes. !
i 23 , Q You are the first person I found who is-i 1 -
24 so you may have to help me a little bit on some of
, >(
l 25 these questions.
l.
I J
1 Noll 55
() 2 My understanding is that when the setpoint is 3
reached the system will actuate and cause various 4 related systems such as the high-pressure injection 5 system to automatically initiate, is that right?
6 A correct.
7 Q I understand that certain of the controls 8 actually automatically lock into position on an 9 emergency safeguard actuation, I am speaking 10 particularly about the HPI controls.
11 A I don't know if " lock in" is a correct 12 term. They are under the ES control at that time.
() 13 Q could you describe for us what happens 14 at the HPI makeup control panel when there is an 15 emergency safeguard actuation?
16 A My understanding when there was an ES 17 uctuation the makeup pumps would c onte on and the 18 high-pressure injection lineup would be automatically 19 set, and you would have high-pressure injection into 20 the system.
ggg 21 Q In the control room there was a panel 22 where the operators could manipulate various controls i 23 in order to regulate the flow of water from the makeup .
l gg 24 pumps, is that right?
U A Yes.
25 u .
1 Noll 56
() 2 Q When there was an emergency safeguards 3
actuation, do yo'u know what happened to those controla 4 and levers and whatnot at the makeup station?
lhI 5 A They were under the control of the ES-6 system until such time as they became bypassed.
7 Q I guess what I am getting at: It is my 8 understanding that some of the levers would actually 9 move, I mean they would just jump into a certain j 10 position as a result of an electrical signal.
i If you were standing there and you had 11 12 your hand on the valve that regulates makeup pressure
, ()
~
13 and there was an emergency safeguards actuation, that 14 valve w uld literally jump out of your hand into 15 the automatic position?
16 A That's the way it was designed, yes.
17 Q My understanding further is that so long 18 as the system remained in its automatic mode those 19 high-pressura injection pumps will continue to pump 20 at 1,000 gallons a minute or whatever the appropriate 21 rate is?
22 A Yes. .
23 Q There is no control system that throttles l
i i 1 24 back HPI automatically? )
l I
25 A No.
l 1
- . . .=. - -. . . . =.
I 1 Noll 57
( 2 Q So it just continues'to run until somebody 3
takes manual control, is that right?
4 A Yes.
I' 5 Q Now, it is my understanding that the 6 emergency safeguard system can be bypassed manually?
7 A Yes.
8 Q once that happens, is the system in any 9 w ay reset so that if the conditions which originally 10 caused the actuation reoccur the system will go back 11 into an automatic mode?
12 A I don't recall without looking at the
() 13 prints exactly if that could occur.
14 Q Let me make the example more-specific 15 and see if it helps.
16 HPI actuates on an emergency safeguard l
17 signal as I understand it approximately 1640 psig. !
18 Assume the pressure continues dropping past the 19 setpoint, continues below the setpoint. At'the time 20 that an operator manually bypasses the emergency 21 safeguard system and takes manual control what in your gg 22 understanding in the electrical system prevents that 9
23 system from automatically snapping back and going l 24 into the emergency safeguard mode again?
O 25 A I don't recall the actual technical I-t l
l
1 Noll 58
() 2 design of what prevents it from doing that if it in 3
fact, you know, does that without, you know, looking 4 at the prints.
63 5 It has been a number of years since I have 6 been away-from them. I would have to trace down 7
through the prints and that takes a lot of time.
8 Q You don't recall, sitting here today, g what the design of the automatic features in the system 10 was regarding reinitiation of emergency safeguards 11 following manual bypassing by an operator?
12 MR. GLASSMAN: That has been asked and
()* 13 answered.
MR. WISE: I just want to make sure.
14 15 A No, I don't recall sitting here.
l 16 Q During your investigation of the April i
17 1978 transient, did you come to have any understanding 18 as to whether there was more than one emergency
- 19 safeguards actuation?
l 20 A I don't recall.
In fact there was only one I believe, is lll Q 21 22 that right? }
! 23 A I know there was one. I don't recall if ,
f I
24 they had subsequent ones or not.
( 25 Q During your inv6atigation, you didn't come ,
l I
1 Noll 59 2 across any?
A I d n't recall.
3 4 Q Did you make up any writings as a reshit l 5 of your investigation?
6 A No.
f 7- Q Did you participate in the preparation of 8 a written report prepared by the Met Ed operating 9 staff concerning the April '
78 event?
, 10 A No.
- 11 Q Let me just make sure I have got this
12 As I understand your testimony during t'he course of 13 your review and investigation you never determined j O 14 what the operator's rationale was for the way they
! 15 managed HIP during the event?
16 A No.
17 Q Do you know whether anybody did?
18 A I don't recall.
19 Q Did you at that time have any familiarity
- 20 personally with the emergency procedures for TMI-27 A No . . Well, let me correct that.
g 21 22 Emergency procedures, I would have been familiar with t
23 the electrical emergency procedures, the loss-of power 24 emergency procedure. '{
i i
O. 25 Q But not the whole gamut such as the loss .
w -,._.y.4...-c.
- , , ,,.,,....._,.y ,..r, , _ _ , . . - , ..~...,nm. , #
, 1 Noll 60 2 of reactor coolant / reactor coolant pressure procedure.
3 A No.
4 Q You were aware that the April 23, 1978 5 event involved a stuck'open main steam relief valve?
6 A Yes.
7 Q Were you aware of any consideration by 8 Metropolitan Edison following that event about 9 preventing a, reoccurrence of it?
10 THE WITNESS: Could you repeat that?
11 Q- Let's focus for a moment on the mainstream 12 relief valve. Do you know what was done after the 13 April '78 event about that problem?
14 A I know an investigation was conducted to 15 determine (1) , the cause and then (2), what remedies 16 would fix.it.
i 17 Q Did you participate in that investigation --
18 A No.
19 Q --in any way?
20 Did you ever become aware that consideration 21 was given to providing better indication to the ggg 22 operators in the control room of the position of the ;
1 23 main steam relief valve?
24 A Not at that time.
t
25 Q Did you become aware that a recommendation
1 Noll 61 2 was made that an audible alarm be installed with
[V~h 3
respect to that valve?
4 A No.
.5 Q To your knowledge who was doing the work on 6 the main steam relief valve?
7 A GPU Service Corporation.
8 Q Did they keep you advised of what they 9 were doing?
10 A No.
11 Q Do you know whether they kept anybody at 12 the generation engineering department in Reading 13 advised of what they were doing?
14 A Not that I know of.
15 Q Did you receive regular reports after 16 you returned to Reading on what was going on at TMI-27 l
17 A No.
18 Q Did you have any involvement from July, 19 1978 through the end of '78 in the events that were 20 occurring at TMI-27 1
21 THE WITNESS: Could you repeat that?
ggg 22 Q Let me go back. Your resume indicates ,
t 23 ;
that you left the Island at the end of June, 1979.
24 A Correct.
O' 25 Q You went back -- ,
(
1
_ , . _ _ _ _ , .-- - . _ _ . ,~ - , _ . _ . . . _ _ , - - , _ _ . _ , . . . _ , . _ . , _ . _ _,
1 Noll 62 MR. GLASSMAN: 1978.
( ,
2 MR. WISE: '78, I'm sorry.
3 4 Q And you went back to Reading and resumed
?
5 your position in the ' electrical and controls section?
6 A correct. ,
7 Q of the generation engineering department.
8 Following your going back to Reading what 1
l 9 responsibility, if any, did you continue to have for 10 what was happening at TMI-2, if any?
11 A I don't recall any.
! 12 Q You had no regular responsibilities to follow events that were occurring at TMI-27 f~)a 13 14 A No.
15 Q were you consulted from time to time about 16 things at TMI-2 or did that simply just leave as part 17 of your job responsibilities?
. 18 A It didn't leave as my job responsibilities.
19 If I was assigned a task to assist TMI-2, I would have, 20 of course, accomplished that but there was no regular 21 basis to do that function.
. 22 Q Do you recall being assigned anything i
23 during the latter half of 1978 with respect to TMI-27 24 A I don't recall any particular job around
.O~
25 that time.
f a
, ~ - , . . - . , . , , = , .,--,n, w ,_,a
1 Noll 63 i
() 2 Q Were you aware of an event that occurred 3
at TMI-2 on November 7, 1978 involving a secondary 4
side upset with resultant reactor trip and emergency 5 safeguards actuation?
6 A No.
I 7 Q Were you aware of a similar event that 8 occurred on December 2, 1978 at TMI-27 g A No.
10 Q You were not in any way involved in any 11 investigations or analyses of those events?
12 A No. -
13 Q Were you involved in the investigation .
O(~N 14 or analysis of any other reactor trips that occurred 15 at TMI-2 besides the two that we have discussed?
l MR. GLASSMAN: What time frame are we '
16 17 talking about?
18 MR. WISE: During 1978 19 Q We discussed the March 29, 1978 event and 20 the April 23, 1978 event. My question n'ow is: Can 21 you recall any other reactor trips where you were 22 asked to participate in an investigation or an l l
23 analysis of the event during 19787 24 A No.
25 Q Would the answer be the same through the
- . _ . _ , - . . . - - - ~ . ., _. , 4., , ._ . _ , , . - .m, . . , , , . .
1 Noll 64 O
O 2 time of the March, 1979 accident? ,
3 A What do you mean by "through the time"?
4 UP until the accident?
5 Q Yes.
6 A The answer would be the same.
7 MR. GLASSMAN: Could we take a break?
i 8 MR. WISE: Sure.
9 (Recess taken.)
10 Q At any time through the end of 1978 had 11 you personally performed any work concerning the 12 design or operation of pilot oporated relief valves? ,
13 A No.
I 14 Q What did you know about their operation as 15 of that time?
16 MR. GLASSMAN: What time now?
17 MR. WISE: The end of '78.
18 A I knew they were on the pressurizer, 19 acted like a safety valve.
20 Q That is they would open and relieve 21 Pressure and at some point they would reclose?
22 A Right. {
- I 23 Q Where had you gained what knowledge you .
I 24 had about pilot operated relief valves, just on the 25 job? l l
l 1
i
1 Noll 65 A On the job, reviewing again the FSAR, b
o 2
3 doing my job responsibilities in generation engineering.
4 Q Had you ever had an occasion ~to make a 5 specific review of the pilot operated relief valve 6 design or function?
7 A No.
8 Q So it was just part of your general -
9 knowledge?
10 A Yes.
11 Q Had you ever made any review of the 12 transients where the pilot operated relief valve 13 had been used or --
\O 14 A Is that the question?
15 Q Yes.
~
16 A No.
17 Q Have youiever made any investigation to 18 determine what effect on system parameters the
- 19 opening of a pilot operated relief valve would have --
20 A No.
i ggf 21 Q --as of the end of '787 i
22 A No.
23
. Q Have you ever reviewed the emergency or 24 operating procedures for the pressurfzer at TMI-27 25 A No. ,
- l l
1 Noll 66 l
2 Q At TMI-1. ,
A "
- 3 4 Q Were you familiar with the emergency 5
Procedure for pressurizer system failure as of the end j 6 of '787 7
A No.
8 Q I believe you already testified that you were not familiar with the emergency procedure for I
! 9 10 loss of reactor coolant / reactor coolant system f 11 Pressure?
12 A No.
13 Q You had never read those to the best of 14 your knowledge?
15 A To the best of my knowledge, no.
l 16 Q Is it true that you were not aware of the 17 symptoms that were prescribed for the emergency 18 conditions described in those procedures?
19 A No, I was not aware of_them.
20 Q During early 1979 were you assigned to 21 review a request that was forwarded from the TMI staff 22 to Med Ed engineering in Reading.to install an 23 improved indicator light in the TMI-2 control room 24 for the pilot operated relief valve.
25 MR. GLASSMAN: Could I have that read back.
- -- - - . - ~ - , - - - - - - , ,- --. , . . - , - -- , , , . .
Noll 67 1
2 (Question read.)
.. m s_ , . hat eo ,ou m.an ,y the word " improved"? Whether that kind of request I 4
was made?
J h 5 ,
g A change, modification and one assumes it 6
7 was supposed to be a change for the better rather than g one for the worse.
A I gt requests for a change modification 9
10 to that indicator light.
g Y u understood they wanted something that j 11 12 would make the indication better not worse, did you?
13 A No.
V 14 g You thought that they wanted to do 15 something that would make the indication worse?
16 A They wanted to do something to the n indication.. Until I reviewed it I didn't pass 18 judgment whether it was better or worse.
19 Q Didn't you understand the staff was 20 looking for an improvement by putting in a change 21 modification?
22 A The word " improvement" would throw me off.
23 I I don't know if -- you know I can't sneak for them , ;
24 whether they thought it was an improvement. They had 25 ~ reasons to submit the change which I don't recall i
, ,. - , , . , . - . . - . , , . nn. w .. ,
g Noll 68 2
what their reasons were, would have beeneto do that.
l 3 Q You received the change modification 4 request?
A Yes.
l/ 5 6 Q Had you ever received one of those before?
7 A Yes.
8 Q What was the purpose in the system of 9 f orwarding change modification requests to Met Ed 10 engineering in Reading?
11 A We were required by tech specs to conduct 12 an independent review on changes or modifications to 13 certain components at the nuclear stations in 14 accordance with tech specs and also in accordance 15 with company procedures.
i 16 Q What kinds of change modifications did you 17 understand were required to be submitted to Reading 18 for review?
19 A Any changes to a safety related system 20 or any changes to a component or system that was 21 identified on the QA systems list were required for an 22 independent review by generation engineering.
23 Q Before you received the change modification .
I 24 request regarding the indication light for the PORV 25 at TMI-2, can you give us some idea of approximately
-g,- e
,, c ,- 3 - - , ,- .<-- - , -- , , . ~ , - c. ,y- --
v.- w-- .
1 Noll 69 2 how many other change modification requests you had -
received? In ther words, is this something that would 3
4 happen daily or something that would happen monthly 5 or something that would happen only once or twice 6 before in your experience?
7 A From what unit are you talking about?
8 Q Either, both.
i 9 A Okay.
2.0 Q Either and both.
1 A I received requests for numerous change 12 modifications from Unit 1 over my time in generation 13 engineering. From Unit 2, very few.
0 14 Q Let's take Unit 1. When you say 15 " numerous," d5 you mean you received several a day?
l 16 A No.
17 Q Several a month?
i 18 A Yes.
I Q All told from 1977 through early 1979 you '
19 20 had received pr bably in excess of two dozen?
21 A That would be a fair guess.
O 22 Q You said you received very few from TMI-2.
23 Do you have any understanding as to why that was? .
I 24 A Basically, I would not receive a change 25 modification for Unit 2 because the systems were not
1 Noll 70 2 turned over to Met Ed. Until such time they were ,
turned over to Met Ed they would still be under the 3
4 cognizance of GPU Service Corporation and I would not, 5
or generation engineering, I should say, would not have lh)
- 6 been requested to review the changes.
4 7 Q When, if at all, did that begin to change?
8 A I am not sure of the exact date. When the 9 plant began commercial operation would definitely have 4
10 been when that change would have taken place.
i 11 Q I think there are records that establish 12 that the plant began commercial operation on l
13 December 28, I think, 1978 --
a day or two one way 14 or the other?
15 A Yes.
r 16 Q From that time on change modifications 17 would be required to go through Reading as you 18 understood the system?
I 19 A My understanding, yes.
i 20 Q What was your usual practice with regard i
i 21 to change modifications that you received from the i 22 operating staff?
23 A Initiate it by reviewing it with a cursory 1
24 glance at the task assignment, what its priority was and just the general familiarization with it. I 25 L
L 4
, ~ , . . . . - ,c,. --- ,, . , + . - - , , - - , . , . - - -- , , , , , , - - - ,-,.a- - , - ~ . - - - ~-
1 Noll 71 2
would then set my own priorities of when I would work on that particular task. Once I got through that task 3
i 4 I would utilize whatever reference materials I had available at the office in reviewing the change and h 5 6 determining (1), if an unreviewed safety question did 7
exist; (2), I would also review it from an engineering 8 judgment, not necessarily specified in any license i
g or technical specification but just a basic general 10 good engineering judgment.
11 Once I made my, engineering judgment or 12 determination of the event, I would write a memo in 13 accordance to a procedure that we had in our 14 engineering group, review the memo when it came back 15 for actually being one I wrote, you know, verifying 16 it was what I wanted, sign it and then sign off the 17 task of being complete and forward it to my boss for 18 his review.
19 He would review it. If he concurred, he i 20 would forward it to the manager of engineering who
.21 would review it and if he concurred he would approve
! k l
22 it. It would then go to the quality assurance 23 department in Reading for their review. If they i
24 concurred and it was basically an audit function, ;
( ) 25 another independent review, they signed-it, it'was
Noll 72 1
then returned to the Island and work could proceed 2
- " 1**
3 4 Q Was it your practice to have oral h discussions either over the_ phone or-face-to-face with 5
6 the operating staff who had initiated the request?
A I would do that from time to cime to get 7
8 .a better understanding of the change, and also to insure that I had the latest revision of prints, 9
i 10 information and stuff that would be. appropriate for it.
11 Q Was it your usual practice to attempt to 12 find out either from the papers or through oral 13 discussions why a particular change modification had 14 been initiated?
15 A Basically it was stated on the change 16 mod that would come through with the task.
1, Q Did_you consider it part of your job, 18 though, to determine why it had been initiated?
19 A Most of the time, yes.
20 Q Let me show you what has previously been
- 21 marked in this lawsuit as B&W Exhibit 767.
22 (Document handed to witness.)
23 Would you take a look through that. I i
24 am going to have some questions for you about it.
< 25 A okay.
1 Noll 73 2 Gause) 3 Q You have seen this document before I take 4 it?
MR. GLASSMAN: Are you excluding review h' 5 l
6 with counsel I assume?
7 MR. WISE: No.
8 MR. GLASSMAN: Are you asking whether he I
! 9 saw all the pages before or some or when or what?
i 10 MR. WISE: I thought it was a : lear question, ,
'I 11 but maybe it wasn't.
', 12 Q You have seen this document before, <
i -
13 haven't you? .
O) k- 14 A Parts of it, yes.
15 Q What parts of it have you not seen before?
1 16 A The last page.
17 Q You never saw that before today?
.i 18 A .'No, excluding discussions with counsel.
19 Q Then you did see it before today?
20 A In discussions with counsel, yes.
i 21 Q As a matter of fact you went oyer this l IB> ,
22 entire document in discussions with counsel, is that l 23 right?
24 MR. GLASSMAN: Objection. We obviously l
! , 25 Prepara our. witnesses,as you prepare yours, i h
I
1 Noll 74 l
2 Mr. Wise. We will not let that go any further. ;
C'g .
J 3
MR. WISE: Mr. Seltzer has asked 4 repeatedly during the depositions of B&W lh 5 witnesses when they last saw a document and your 6 witnesses have'been permitted to answer that. I 7 am not asking for what advice was given nor am 8 I asking the general question what documents 1
9 were shown to the witness which I think would be 10 objectionable, but as to a specific document 11 which I put before him, I think I am entitled 12 to know when he last saw it and when he has had
% 13 an opportunity to refresh his recollection,with 14 respect to it that is relevant to the testimony 15 to come.
16 BY MR. WISE:
17 Q You have seen this recently in preparation 18 for your deposition I take it?
19 A Yes.
~
20 Q All of it?
21- A Yes.
l 9 Before your preparation for this deposition, 22 Q l
L 23 when was the last time previous to that that you saw l
24 these documents?
I'"}
(m/ 25 A It would have been March 16, 1979. l I
i 2.-. , - , - - - , - - , , - - - -y., . %.. ,3---- , ..r-,-e--- ,,
1 Noll 75 2 Q On what is your recollection based?
-'O . A When I signed the task sheet in the front, 3
, 4 project complete date, that would have been the last 5
I had seen this task provided there was no discussion
, 6 on the prior that someone didn't agree with my 7
conclusion which there was none to my recollection.
8 Q Let's go through this exhibit and i
9 identify its various parts, putting aside the cover 10 sheet which is nothing more than a Xerox of the file 11 jacket from which the documents were taken.
12 The first page with any substantive 13 writing on it is labeled " Task Assignment Form."
O 14 Are you familiar with this form?
15 A Yes.
i 16 Q Was this something that was commonly used 17 in the generation engineering department at Met Ed?
18 A Yes.
19 Q In the lower right-hand corner of the page 20 there are some signature. lines, one of them is labeled l
" Cognizant Engineer" and there is a handwritten !
ol
! l 22 signature that appears to be yours on that line.
l . ,
23 Is that your signature? i 24 A Yes.
25 Q When was this form normally completed? l 4
r , , -, . . - , , , ,.--y.. , - , -+--%+-,.,,,,y-,- - - . . , . ,,-m._ . , , , ,
I t 1 Noll 76 f'] 2 A This form was completed when I signed the V
3 men discussing the -- my determination of the change 4 modification.
h 5 Q And you would take out a blank copy of 6
this form and fill in the various spaces with the 7 required information?
8 A No, it was on my carbon paper. There were actually four of these sheats together. I would sign 9
10 the top one.
11 At various stages of the assignment the 12 other pages would be taken off for administrative 13 ! tracking of the task.
14 Q Putting aside the separation of multiple 15 carbon copies of the same form, I guess my question 16 is, when would you start to fill out this form?
17 A The only part on this form I would fill 18 out would be the project complete date and my 19 signature.
'20 Q who would fill out all the other i
21 information that has been written in horo?
gg 22 A The project coordinator for the manager 23 ! of engineering would have filled out down to the l l 24 cognizant section head of the form, and also the projected
25 required date and also the mandating agency.
-1
_ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ __ - - - - - _ - - -. J
1 Noll 77 2 Q Aad that would all be completed at the 3
time y u received the assignment?
4 A Yes.
lh) 5 Q so that this task form would come to you 6 with the other papers relating to the assignment?
7 A Yes.
8 Q This was something that was filled out '
9 l at least down to the bottom of the page where you 10 have indicated before you ever began your work on it?
11 A Correct.
12 Q The next sheet in the exhibit is on the 13 letterhead of Metropolitan Edison Company and the e 14 subject of this is change / modification number 2-0298, 15 it is addressed to Messrs. Klingaman-and Troffer.
r 16 Mr. Klingaman was the manager of the 17 generation engineering department, is that right?
18 A Yes.
19 Q Mr. Troffer was manager of the QA 20 department?
21 A Yes.
g 22 Q= There are two typed signatures, one by ,
23 l G.P. Miller, station superintendent and one by D.M.
! l I
24
' shovlin, superintendent of maintenance. There is a i (~~\
\/ 25 handwritten signature above Mr. Shovlin's typed name.
l
1 Noll 78 The date of this document is January 30,
{~)
v 2
l' 9' 3
4 Had you seen a form similar to that which
, lhI 5 appears as part of this exhibit?
6 A Yes.
7 Q Was this the usual cover sheet that would 8 accompany a change modification request?
A Yes, this was the transmittal cover sheet.
9 10 Q The next document in this exhibit is a ;
it two-page printed form which has been filled out with 12 various handwriting. The form is entitled " Major / Minor 13 Change / Modification Request Form."
{)~
14 This particular one has been given the 15 change / modification number 2-0298. It indicates that 16 it is for TMI Unit 2.
17 Have you seen a form similar to this before?
18 A Yes.
19 Q Was this the usual form that accompanied 20 a change / modification or in fact this~is the change /
21 m dification request, is that right?
22 A Correct. ,
23 Q- Attached to the request form or l
24 immediately behind it are several pages of engineering 25 drawings and data.
1 Noll 79 4
2 Do you see that?
O' A Yes.
1 3
4 Q Do you know what these are?
h 5 A That's the supportive documentation with 6 the change request, descr,1bing what the ch,ange/
7 modification actually is.
8 Q Following the engineering drawing and 9 towards the back of this exhibit is a one-page form 10 that bears the number W-38018 as marked for purposes 11 of this lawsuit. It is entitled " Metropolitan Edison 12 Company Quality
- Assurance Document Review Record."
13 Have you seen a form similar to that 14 before?
15 A Yes.
16 Q Was that normally completed after you had
, 17 performed your work?
18 A Always after.
l 19 Q That then indicated that the people in 1
t 20 Mr. Troffer's department had reviewed it and whatever l
j 21 comments they had were reflected on the form,_is that ggg 22 right? ,
23 l A Correct.
24 Q The next document'in the exhibit appears .
/~ l k_/ 25 on the letterhead of Metropolitan Edison Company, !
V l I
, y . , - -% , - . , , - . , - . . . . y -
. ~ , _ . . - , , . _ , ,,,,. -.-, ,
1 Noll 80 i
and it is a memorandum submitted to Mr. Shovlin, the
) 2 3
s ub j e ct is " Change / Modification 2-0298, RC-RV2 4 Indicating Light," the date is September 4, 1979 and
- 5
-it bears immediately beneath it a number for 6 identification " GEM 1429."
7 Are you familiar with this form?
8 A Yes.
9 MR. GLASSMAN: You are talking now about 10 the particular document or the general fermat?
11 MR. WISE: General form'at.
12 A YWs.
13 Q What was the purpose of this type of form?
(
14 A This was the official answer to the 15 change / modification request either approving or 16 disapproving it.
17 Q When would this form be completed?-
18 A It would be -- by whom? 'That makes a 19 difference.
20 Q Let me ask you first who initiated this 21 form.
g 22 A I did.
l 23 Q Who filled out the text of the form?
^
! l 24 A I did. !
r 25 Q When vould you do that?
9 9m- --~
y 9- --&r -
- , - - ,.c , - - - - , , , . ~v . -. ,. - e-w -- =
1 Noll 18 1 2 A After reviewing the change / mod requ,est, 3
making my engineering judgment on it and writing the 4
memo under the guidelines of a procedure that was in l(f 5 the generation engineering group, explaining how to 6 set up the format on the memo.
7 Q Would you write it out by hand or dictate S it?
9 A By hand.
10 Q What did you do with the handwritten --
11 .A Sent it to typing with a request that it 12 be typed in the format it is in .
13 Q And then when it cane back you would sign 14 it?
15 A I would sign it and sign off the task as 16 being complete.
l 17 Q That is the form which we discussed first 18 at the top of this exhibit?
19 A correct.
20 Q And then what would you do with the task ,
21 assignment form'and the memorandum?
q
'22_ A I would forward it to my boss who was j 23 .Mr. May at the time.
- 24 Q You.would send it through some sort of
( .;
\--- 25 inter-departmental mail?
, -- - - - .,gm v v s. --
a
1 Noll 82 2 A Inter-departmental mail.
3 Q Attached to this axhibit are two 4 handwritten notes at the very end. I take it that you lh) 5 did not see either,of those notes before your 6 Preparation for this litigation?
7 A That is correct.
8 Q Mr. May was your immediate superior?
I 9 A Yes.
10 Q would you take a look at the last page of .
I 11 the exhibit, this is the note that you had not seen 12 before your preparation for this deposition. You will 13 note that it is initia11ed at the bottom with the O 14 date August 17, 1979.
15 Do you recognize the handwriting?
16 A Yes, George May.
17 Q Let me go back to the material that was 18 submitted by the TMI staff beginning with the cover s 19 memo from Mr. Shovlin to Messrs. Klingaman and Troffer 20 and the attached change / modification request. -
21 Do you have any recollection of when you j 9 first received these?
. I 22 j 23 l A My recollection is the beginning of I
i 24 February, 1979, in that tfme f r am e .
O)
(s 25 Q Do you recall receiving them? g l
i L
- -l
, N. I S . ;3
- . . . .. . _ _ _ - _ - = - - _ _ . - _ .. . _ _ _ _ - _ . . ._ .- - - - - . . . __
1 Noll 83 2 A Yes.
( ,
3 Q What happened?
4 A I, as I explained earlier, gave it a I 5 cursory glance, looked at the priority on the task 6 assignment form to determine its urgency and then put 7
it with the rest of my workload and determined when I 8 would get at it first of all.
9 Q From whom did you receive it?
10 A Through the mail and it would have come 11 from the -- from George May who had back on the task 12 assignment form entered in the cognizant engineer 13 responsible for it, that being myself.
14 Q Did you have any conversations with 15 Mr. May concerning this particular request at the 16 time you received it?
- , 1" A No.
_[ 18 Q Did you have any conversations with anyone N'
19 else about it at the time you received it?
20 A No.
w 21 Q If you look at the change / modification G' 22 request form submitted by the TMI staff, you will I
g 23 note that on the first page in the. upper-right hand ,
24 corner there is a series of'four items beginning with i l
- (~h
, .. ' \- 25 the change / modification number and then immediately .
s s i Q,
N - - - _ _ . ._
g Noll 84 g3 2 beneath that priority, then operator training, then U
3 quality control.
4 Do you see that?
ll) 5 A Yes.
6 Q You will note that in the blank next to 7 priority someone has written in the number 1.
8 Do you see that?
9 A Yes.
10 Q Do you have any understanding of what was 11 meant by priority as used on these forms?
12 A No, that was assigned at the site. I was 13 not familiar with their definitions of their priorities.
O 14 Q Were there priorities within the Met Ed 15 generati~on engineering group in Reading?
16 A Yes.
17 Q Were you familiar with what those were?
18 A Yes.
19 Q You don't have any knowledge as to whether 20 they were the same or different from those that 21 existed at the site? l' I
22 A I don't know if they were the same or 23 different. I 24 Q If you would go to the task assignment 25 form at the top of the exhibit you will note that it 1
1 Noll 85 2 has a box labeled " Priority."
3 A Yes.
4 Q Someone has written in the number 2.
5 A Yes.
6 Q What did the number 2 priorty mean in the 7 Met Ed system as you understood it?
8 A My understanding would be it would be a g lower priority than a priority 1, okay. What the 10 exact definition of those priorities is, I don't 11 recall now.
12 Q How many different pri'orities were there?
14 A Three 1, 2 and 3.
14 Q 1 being the most urgent?
15 A correct.
16 Q 3 being the least?
17 A 3 being the least. .
18 Q Were there any general procedures as to 19 time period within which the different priorities l
20 had to be resolved?
l l 1 '
21 THE WITNESF: Would you read that back j I
g 22 again, please. i i
l 23 (Question read.) ;
I l 24 Q Do you understand what I am asking?
' ('~\ l l
\- 25 A I understand. I am not sure if there was ,
1 Noll 86
( 2 a definition that said that certain priority had to b The 3
be ace mplished within a certain time frame.
4 project coordinator who assigned this would have h 5 assigned also the priority, but also would have ,
6 assigned at the same time the projected or required 7
date.
8 Q What did it mean to you to receive
( 9 something that was priority 2 as opposed to priority 1 10 or priority 37 l
11 A It was not as important as priority 1 and 12 therefore I myself would have not assigned it as
(~N 13 high priority as some of my other tasks that would
(_) .
14 have been a priority 1.
15 Q You would complete a priority 1 task, 16 before you would pick up and commence on a priority 27 17 A If at all possible. You know, I would 18 try to comply with the projected required date, the 19 urgency of trying to make that date wasn't as great 20 as if it would have been a project --
a priority 1.
! 21 Q Going back to the change / modification l 22 request form. The form indicates that the system 23 involved is the reactor coolant system and the 24 particular component was the RC/RV2.
I ') !
k 25 Did you have an understanding of what the i
1 Noll 87
() 2 RC/RV2 was? ,
3 A At the time I received this?
I 4 Q Yes.
IE;- 3 R xe..
6 Q That is the pilot operated relief valve?
7 A If that is a question, yes.
8 Q The change modification request as i
g described as follows on the form: " Connect the open 10 light for RC-RV2 to the limit switch on RC-Rv2 vice 11 the reactor relay contact in the control circuit for 12 RC-RV2."
["D 13 The reason for the change modification is V
14 described as follows: "To provide an indication that 15 RC-RV2 is open," and the request is' signed by someone 16 for.the supervisor of maintenance and dated 17 December 23, 1978.
18 What was your understanding when you 19 received this of what it was the plant operating staff 20 was requesting?
21 A They were requesting to change the pickup 22 point for the'RC-RV2 indicating light from a point 23 where it was to a limit switch which was supposed to 24 he on the valve or somewhere on the valve.
gg .
U 25 g what is a limit switch?
Y
s 1 Noll 88 A Limit switch is an electrical contact that
(~) 2 V
3 either makes or breaks when a cortain mechanism 4 actuates it.
I What was your understanding of how the l{} 5 Q i 6 limit switch operated in the pilot operated relief 7
valve that was in issue with respect to this request?
8 A When I received this request?
- g. Q. When you received it and when you began 10 work on it.
11 A okay. When I received it I was not familiar 12 with the limit switch at all. That is why I would have 13 reviewed the information that was available to me as to 14 what they were and where they were.
15 Q What information did you review?
16 A Prints, drawings that were available at the location where I was.
17f 18 Q That is in Reading?
19 A Yes.
20 Q What kind of prints and drawings were 21 available-there regarding the pilot operated relief k '
22 valve? l 23 A All the prints and drawings for the .
. I 24 station we were -- the generation engineering !
(~T l 1-s) 25 department was responsible for maintaining the i l
1 1
( -5
1 Noll 89
'^k 2 up-to-date drawing file for the unit.
)
3 Q Did y u actually get out a copy of the
~
4 drawing for the design of the PORV?
f 5 A Yes.
6 Q And you determined where the limit switch 7 was in the valve?
g A Through the drawing and through 9
discussions with an associate engineer that was more 10 familiar with the actual PORV valve.
11 Q Who was that?
12 A Jeff Fritzen.
13 Q Where did he work?
14 A He worked for Rudy Lefin in the 15 mechanical section. He would be more cognizant of the 16 valve itself.
17 Q what did he tell you about the valve?
18 A He pointed out to me that the limit 19 switches were in fact on the solenoid operator of the l
20 valve and not the valve proper.
21 Q Could you explain what the significance 22 of that was? > .
, l 23 A The. significance to me was that after I '
i 24 learned of where they were and what type they were, -
25 then I was familiar with that application of a limit
1 Noll 90 i
2 switch through my experience at TMI and at the other 4
3 generating station. My experience had been that these 1
4 were not very reliable limit switches, they had a l 5 tendency to slip their adjustment points or actually 6 where they were activated, and I did not feel that it 7 w as an adequate determination for the valve actually 4
8 being opened since it was on the solenoid and not on 9 the valve itself. l 1
10 Q Did anyone info'rm you that at TMI-1 the 11 indicator light was hooked up to the limit switch on 12 the PORV7 s 13 eA No, they did not, and in fact I would have 14 checked Unit 1 and it is not hooked up to the limit 15 switch.
16 Q Is there an indicator light at Unit 17 17 A Yes.
18 Q Did you check that out before the March, i
19 1979 accident?
~
20 A Yes.
21 Q What did you find was the situation with.
22 respect to the indicator light at Unit 17 A - It was identical to the existing indicating- '
23 l
24 light for Unit 2 except that it had a green indicating- I light which was additional over Unit . Unit 2 on1h 25 - 2.
+-
g,- g y y =i r.-JN y y- -yw--g> g y y J -r yy e-- m.g y' e gs-w ev- 9 9 msy y y my ,_- - p
I 1 Noll 91 2
had a red indicating light indicating when it was 3
Pen, it didn't have a green to indicate when it was 4 closed.
h' 5 Q Did you find out who had designed and 6 installed the indicator light at Unit 17 7 A I knew that it was a Gilbert design who 8 w as the architect engineer. It was on a Gilbert 9 drawing.
10 Q Did you learn whether that had been 11 installed originally or whether that had been a
, 12 change or modification that had been added at some 13 time after the unit was originally de, signed?
Os c-14 A I didn't pursue that.
15 Q You don't know today whether the demand 16 indication light installed at Unit 1 was there from .
17 the beginning or whether that was added at some later 18 time?
1 19 A That's correct.
20 Q During your conversations with l 21 Mr. .Fritzen did you become aware that there were reasons why the pilot operated relief valve might be 22 f L I i
23 in the open position despite the fact that there was 24 electrical power onto the valve?
.25 A Yes.-
r-
+-
1 Noll 92 =
l Q You understood that that could occur?
( 2 3
A Yes.
4 Q And in fact that was one of the reasons 5 why you believed that the limit switch was no better 6 than the solenoid as far as being the point for 7 hooking up the indicator light?
8 A I would say that was the reason, being 9 more concerned with the reliability of the actual l
10 - limit switch itself.
11 Q But in any event hooking up the indicator 12 light to the limit switch in your view would not have 13 improved the reliability of the indicator light in the 14 control room?
15 A Just the opposite. My engineering 16 judgment, it would have possibly decreased the 17 reliability providing the indication for the light in 18 the control room.
19 Q Going back to the change in modification 20 request form, you will note that the reason for the requested modification, as I read before, was to gg 21 22 provide an indication that the PORV is open. ,
23 .
After you determined that the request i . ;
24 would not result in an improvement in the reliability ;
25 of an indication, did you have any conversations i I
1 Noll 93 with members of the plant staff regarding your
( 2 l 3 conclusion?
4 A Yes.
5 Q Did you understand that they wanted a 6 better-indication than they already had that the PORV 7 was open or closed? -
8 MR. GLASSMAN: You are asking him whether 9 he had a conversation to this effect?
10 MR. WISE: Yes.
11 A I had a conversation with the plant staff 12 c,oncerning the c'hange mod request to change this
() 13 particular connection point to the limit switches and my concern that I felt it was a reduction in 14 15 reliability and that I was subsequently going to i 16 disapprove itsso I had a conversation with Mr. Georgea 17 Kunder, Mr. Dick Bensel along with Mr. Klingaman 18 where we discussed this fact and at the end of the 19 conversation we, to my recollection, all mutually 20 agreed that they would disapprove this change l
1
' g 21 modification. j
- '22 Q Let me ask you first
- This conversation 23 i that you have described, did that occur after you had I '
24 your conversation with Mr. Fritzen?
25 A Yes.
1 Noll 94
'() 2 ,
Q Did it occur after you had reached your 3
conclusion that you were going to disapprove the 4 change request?
/ 5 A Yes.
6 Q How was that conversation set up?
7 A I phoned Mr. Bensel and said that I would 8 like to discuss the change mod with him and Mr. Kunder, 9 and also would like to get Mr. Klingaman's thoughts 10 on it.
11 Q Why?
12 A Him being the manager of engineering, he had to either approve or disapprove the pequest. He
( 13 14 w as the final approval or disapproval. As you know 15 on the memo I wrote, I submitted it, he approved it.
I 16 Q How did you come to include Mr. Kunder l 17 in this discussion?
18 A okay, Mr. Kunder was at that time 19 Mr. Bensel's supervisor.
20 Q Did you feel that this issue was 21 important enough that you should have Mr. Kunder and G !
22 Mr. Klingaman involved? ;
23 A The reason I would have included them, i
l 3 24 from being at the Island I had a rapport with the 25 engineers up there and it had been my normal procedure j s
t
+ - -.n. . , , . - .., , , , . -. . , . , ,
l 1 Noll 95 2 that when I was-going to disapprove a request that they 3 had submitted I would contact them ahead of time as a 4 formality, a nicety, and try to explain.
5 I always felt it was better if I could 6 personally explain to them why I was disapproving 7 rather than have a memo show up in the mail saying 8 it is disapproved.
9 Q After your conversation with Mr. Bensel, 10 how did you proceed to set this up, this conversation?
11 A I said I would go in with Mr. Klingaman l 12 and we would call himself and Mr. Kunder back when I 13 could get in with Mr. Klingaman and of course set up Os 14 a time that we could have the conversation.
15 Q This was a conversation that occurred over 16 a speaker phone?
17 A Yes.
18 Q You and Mr. Klingaman were in Reading while
- 19. Mr. Kunder and Mr. Bensal were at the Island?
20 A Yes.
~
21 Q Do you know about when this was?
22 A It would have been early March, 1979.
t 23 Q sometime before the accident? .
I, 24 A Yes, sometime before the-final signature s/ 25 that I had signed the task off.
1 Noll 96 i
. 2 Q Can you relate what was said during the e nyersations by the various participants?
3 4 A well, from what I recall, the Island said 5
they requested the indication, they requested that it 6 he changed over to limit switches. ,
What I recall is 7
they were thinking it might improve the reliability of 8 an indication.
9 Then I expressed my concerns that I thought 10 it would be the opposite, decreasing the reliability 11 based on my experience and knowledge about the limit 12 switch which in f act was called a read switch, l 13 Through my experience that had been civing 14 false indications and spurious indications. In further 15 discussions, it was mutually agreed,they agreed with my ,
16 position and it was mutually agreed to disapprove this 17 Particular change mod request.
18 Q Did anybody in that conversation say why 19 they had initiated this particular request?
20 A Not that I recall.
21 Q Did they mention there had been any 22 Problem with the indicator light that they currently ,
t 23 had?
i l 24 A I don't recall it.
! [)
\-- 25 Q Did they mention to you an event that l I l
-. _ _ ~ -
1 Noll 97 2
occurred in October 1978 when the indicator light showed
(
that the valve was open when it was actually closed?
3 4 A Not that I recall.
l 5 Q Did you ever learn that such an event 6 had taken place?
7 A What time frame are you talking about, 8 when I was doing this?
Q All right, let's take that first: When 9
10 you were doing that did you learn that such an event 11 had taken place?
12 A No. ,
13 Q Did you subsequently learn that it had?
14 A Sitting in the room today, yes. ,
15 Q This'is the first you ever heard of that?
I 16 A Except for discussions with counsel, yes.
17 Q Was there any discussion during the 18 conversatien that you and Mr. Klingaman had with 19 Mr. Kunder and Mr. Bensel about the possibility of 20 some other form of indication concerning the position 21 of the PORV?
ggg 22- A I don't recall any.
f I am a bit confused. The plant staff -
! 23 Q I
! 24 = had put in a request seeking some change in the l l .(~h \
f 25 indication light. , We have established that. l
, l l
1 i
1 Noll 98
)
() 2 A Change to the electrical schematic pickup 3
Point for the indication light, that is correct.
4 Q If I understand your testimony, you lh 5 never f und ut why they wanted that?
6 A In the conversation with them I testified 7
they probably told me that they wanted an improved 8 indicating light with this change / mod being electrical 9 improvement.
10 Q We have established that they wanted an 11 improved light that 4s clear.
MR. GLASSMAN: We have established, 12
() 13 Mr. Wise, what they probably wanted; in 14 Mr. Noll's words, we have not established a 15 Particular reason. In fact, Mr. Noll hasn't 16 testified that he Jid not actually know their 17 reasons or what they really wanted in that sense, 18 their reasons for it.
19 MR. WISE: The documents state the reasons, 20 that's provided-in the papers that we have.
The document say s whatever it says. -
21 22 All I am trying to do_is. determine whether 23 t".is witnes.g ever learned from the. plant staff.why l
24 they> wanted something diff orent than what they had. >
f-25 MR. GLASSMAN: You'are not as, king the i
1 l
1 Noll 99
() 2 witness to guess, you just want his recollection?
3 MR. WISE: That's right, I don't want him 4 to guess.
k 5 q During the course of your review of this
. 6 change request, was it a concern of yours to find out 7 why they wanted an improved or different indicatica 4
8 light than the one that they had?
9 A By " concern" I would have been, in 10 reviewing why they wanted the change since the 11 change / mod says to provide an indication, my first 12 response would have been upon checking, I would have
() 13 told them " Hey, do you have an indication now?" Then 14 they would have come back and said, "Yes, we do, but i
15 this change has been sent in to change the electrical i
16 pickup point for that."
17 Q Did they ever explain to you why they I
18 wanted to do this?
19 A Not that I recall, no.
20 MR. GLASSMAN: Don't speculate.
21 A No, it would have been speculation on my G 1 22 Part.
-' -t 23 Q How long did this conversation that'you-
, l
- 24 and Mr. Klingaman had with Mr.'Kunder and Mr. Bensel i
l - l 25 about this issue last? ;
I i
Noll 100 1
I) 2 A My recollection would be five, ten V -
3 minutes, if that long.
4 Q And you never learned what their reasons 5
were for wanting to move the connection for the l
6 indicator light from the solenoid to the limit switch? i 7
MR. GLASSMAN: Mr. Wise, he alraady 8 answered that question several times. We can just have it read back. The reporter could find 9
10 it just a few lines up; go back and find it 11 again. The witness fully testified to what he 12 learned or didn't learn. If you want him to 13 guess, it's out of order. If you want his 14 testimony, he has given you that.
15 MR. WISE: I think this is another example 16 of what ws have run into. If I ask one question 17 in an area you assume all these questions 18 answered.
19 MR. GLASSMAN: If you have a different 20 question, you may ask it.
I 21 MR. WISE: It is a different question.
gg
'22 MR. GLASSMAN: Can we'have the question i
L 23 l' read back.
I 24 LQuestion read. ) -
O 25 A To the best of my recollection, no. {
l
1 Noll 101
() 2 Q Did Mr. Kunder or Mr. Bensel in that I
3 conversation indicate to you that there had been any l 4 problem at all with respect to the indication light 5 they presently had?
6 A I don't recall any.
7 Q Did they indicate to you any 8 dissatisinction with the present light that they had?
9 A I don't recall any.
10 Q when you spoke to them about this, did 11 they know anything about this request for chan ge/-
i 12 modification that had been put in?
13 A Yes.
(
14 Q They heard of it?
15 A Yes.
16 Q And it was something that they wanted?
17 A Yes.
18 Q But you had no understanding as to why they 19 wanted it?
20 A I understood electrically why they 21 wanted it. They wanted to change from the demand qgg 22 signal on the valve to the limit switch on the valve l 4
23 electric pickup point.
1 24 Q That Eis what the document itself says?
7-N_] 25 A. Yes.-
l
. m-, &w .. .,
,-v- m --,-%..n, y
1 Noll 102 l
(~b) Q You didn't understand why they wanted to
( 2 3 d 'that?
4 A No.
h' 5 Q And that never came up during your 6 conversation?
7 A I don't recall it. I would be guessing if 8 I did.
9 Q Did Mr. Klingaman say anything that you 10 recall during this conversation?
11 A I don't recall the specifics of what he 12 said.
13 Q Did he agree with your position?
(
14 A Yes.
15 Q At the end of the conversation did 16 Mr. Bensel and Mr. Kunder express an agreement with 17 your conclusion?
18 A Yes.
19 Q Did they indicate that they were going to l
20 Pursue the question of indication for the PORV any 1
1 21 further?
22 A I don't recall. l l
23 Q As you understood it at the end of the 24 conversation was there going to be any further action
- 7. 3
)
25 taken regarding indication for the PORV7 I l
1 Noll 103 I'h 2 A My understanding was there would be no b
3 further request on my part for indication on the PORV7 4 Q Did you have an understanding at the time l l() 5 whether it was important that an indicatio,n exist for 6 the position of the PORV?
7 A I knew, due to my being at the site in g 1978 when it had opened,and the operators didn't know g that. It was from my understanding a nicety for the ..
10 operators to know if it in fact was demanding to be 5
11 openeds and that is why the indication light was 12 originally put in.
() 13 that?
Q You say a nicety. What do you mean by 14 15 A It was information available to the 16 operator, but it wasn't necessary for him to perform 17 his duties in my understanding.
18 Q Was it your understanding that he had other 19 indications of the position of the valve?
20 A No.
21_ Q what was your understanding?
gg 22 A Well, he did not'have any indication in t
l 23 the control room of the position of that valve. ,
i 24 Q Did you have an_ understanding as to whether
~
25 it was important 1 that he did have a reliable '!
1 Noll 104 I) 2 indicLtion of the position of the, valve in order to V
3 operate the plant safely?
4 MR. GLASSMAN: You are now talking about 5 back in 1978 or '797 6 MR. WISE: Yes.
7 A You are talking.
8 Q when this particular change modification g request was under review, did you understand that it 10 , was important for him to have -- for the operator to 4
11 have information concerning the position of the PORV 12 in order to operate the plant safely?
, 13 A I don't really understand your question.
14 Q You understand what I mean by " operating 15 the plant safely"?
16 A Not really, no.
17 Q You understand that there are safety 18 concerns about nuclear plants?
19 A Yes.
20 Q You understand that one of the objects in 21 operating nuclear plants is to run it safely?
ggg 22 A Yes. .
23 Q Did you understand that it was important i
24 to operating a nuclear plant safely that the
{
i [\'
25 operators have some indication in the control room
w l
1 Noll 105 2
as to the position of the pilot operator relief valve?
A No, n t my un'derstanding, that was not my 3
area of responsibility or expertise to speak of. My 4
5 area was looking at how the light got lit, not why.
6 Q In connection with your work on this 7 particular change modification request, I take it you 8 did.not go back and review the emergency operating 9- Procedures for TMI-27 10 A No.
11 . Q Did you not make an effort to go back 12 and review the various transients or events that 13 occurred at TMI-2 or TMI-1 to determine whether 14 anything in those events pertained to this particular 15 change request?
I 16 A No.
17 Q Other than the one conversation that you a
18 had described with Messrs. Kunder and Bensel, did you 19 have any other conversations with members of the
' 20 TMI operating staff concerning this change request?
21- A No.
22 Q Is that the only conversation you had 23 with anyone concerning this change request?
24 A To my recollection, yes.
s/- 25 'MR. GLASSMAN: You should note for
'l
1 Noll 106 2 completeness, Mr. Klingaman may have been
[)
3 menti ned as part of that conversation.
4 MR. WISE: The conversation with 5
Mr. Klingaman, Mr. Kunder and Mr. Bensel.
6 MR. GLASSMAN: Then there was some prior 7 testimony --
4 8 MR. WISE: Conversations with Mr. Fritzen.
9 BY MR.-WISE:
10 Q other than those conversations, you did 11 not have any?
12 A correct.
13 Q You did not travel down and talk to anybody
}
14 there about this?
15 A No.
I 16 Q other than Mr. Klingaman and Mr. Fritzen 17 there isn't anybody else that you can remember in the 18 Reading group that you talked to about this?
19 A No.
20 Q You note that on the change / modification 21 request' form someone has checked under the priority gg 22 box " operator Training," and they have marked "Yes."
23 A Yes.
~ 24 Q Did you have any understanding as to what 1:~) 25 . .that meant?_
t,
1 Noll 107 2 A My understanding was it was an f^J')
w administrative function for the cognizant engineer 3
assigned this change modif.d. cation at the Island to ;
4 5
insure that whatever information or procedures that 6
needed to be trained for, operator traininy,were in 7 fact accomplished.
8 Q You didn't have any function with respect 9 to operator training?
10 A No - ;
1 11 Q That was not your concern?
12 A No.
/~'s 13 Q And you don't know what operators had i V
14 been trainied about the existing indicator light?
15 A No.
16 Q And you don't know what, if anything, was ;
i 17 ever said to them about this change modification?
18 A No.
19 Q 'During your review of this change 20 modification did it ever cross your mind that the 21 existing indicator light at TMI-2 and at TMI-1 would 22 not be an accurate indicator of PORV position in all 23 , instances?
24 A I wouldn't know how to answer that in all l, rN '
( !
\ 25 instances. I wouldn't know what all instances would'mean.
1 Noll 100-109
() 2 Q Did you understand that there could be mechanical failures of a pilot operated relief valve?
3 4 A Ch, yes.
h 5 Q Did you understand that the light that 6 existed at TMI-1 and at TMI-2 would not be an accurate 7 indicator in the event that there was a me chanic al 8 failure? ,
9 A Yes, I quite possibly considered that, it 10 . would give an indication that due to mechanical i
11 failure would not be a true inf.ication.
12 Q Did you mention that to anyone?
13 A I don't recall that I did.
}
14 Q Do you recall whether that came up during 15 the course of your conversation with Messrs. Klingaman,
.i 16 Bensel and Kunder?
-17 A No, I don't recall.
18 Q Did you expect at the time that they 19 understood that-there could be mechanical failures of 20 the pilot operated relief valve?-
I A Are you asking did I understand? [
S 21 Yes, was it your understanding --
, j 22 Q '
^
f i 23 A 'Their thoughts? .
I Q I am not asking whether they actually -j
! ~ 24 i i'
' k'_)N 25 did.think that. I am looking towards your state of l
. . . .- . - _ . . - . . - . - . - ,. .. .. ... . .'a 1
1 Noll 110 2 mind at the time.
3 At that time did you expect that they 4 understood that there could be mechanical failures of h 5 aPilot Operated relief valve? ,
' You are asking 6 MR. G,L,AS SM AN : Objectidn.
7 whether he expected that they had an understanding 3 of something. ' ,
g ,
- ER . WISE: That's right.
/
10 MR. GLASSMAN: That is hopelessly --
11 .A I wouldn't want to conjecture on their 12 thoughts.
() 13 Q Ifdon't want you to conjecture. ,
14 A or understanding.
15 ' ,
Q I am not asking you anything about their j 16 thoughts or understanding. I am simply asking you as 17 a member of the generation-engineering' department 18 having a discussion with Mrs-Klingaman who was your 19 superior.and Messrs. Bensel and Kunder, and I believe
/
20 you testified that you worked with Mr. Bensel at the 21 Island for a period of some six months?
9 22 A Correct. i I
23 Q Whether at the time that you had this conversation in February or early March, 1979 it was
-)
\m) 24 25 your expectation that those gentlemen would .
, 1, 1 Noll 111
, - , s
() 2 understand just as you did that there could be mechanical failures of a pilot operated relief valve?
3 4 MR. GLASSMAN: You are asking whether de s
2 5
recollects having such a specific expectation 6 at that time?
7 MR. WISE: Well --
8 MR. GLASSMAN: It is very confusing z, o
)
'~
9 otherwise, Mr. Wise. You are going back to a ,
10 recollection of an expectationsof a ;. ,
i 11 8
understanding as to what I said before. I don't ;
12 know what else you are asking.
MR. WIS; I don't think it is anywhere 13 {
14 l
near as difficult aquestionasyouaremakingout.l ' .
l
- 15 11 These were gentlemen that he knew and i worked with all the time. The issue is* an -i 16 17 important one to this. case and that is the extent 18 of understanding within Metropolitan Edison of
~
19 a pilot operated relief valve's work. ,This 20 witness testified to his understanding.-
. 21 -All I am trying to do is determine 7 heth e r 1,
22 it was his expectation at the time that he w as ' i
~
t, W 23 working with these other gentlemen that they '
j e l 24 knew as much about-it as he did. - ,
O 25 MR. GLASSKAN: I just don't want him t5 u ms t
,s \ '
i-L
+* \ l
~ 4 .- ;
. . -_. - _ . . - - _ . _ _ s
1 Noll 112 2 guess. If he recalls he had a particular
, .....tauon, ,in., he can give it to ,om.
x l'4 A I w'ould think their knowledge of the valve h >
5 was as.much as mine if -- at the time.
'2 6 Q Did you have:any understanding of what l
i o'
4 would happen in Se. event that the pilot operated 8 relief valve rem'ained in the open position and the L
9 perators failed to discover it during ncrmal power 10 i operation? -
11 A ' At the time I was reviewing this change / l 12 mod? -
13 . Q Yes. -
{ .
14 A No.
g Y u knew that-the pressure would decrease? l 15 9
l i 16 M 'Yes, because that's the way a safety valve i
17 worked through my experience at fossil generating
."~
\f 18 s t a tio'ns '. if s e n a safety. valve opened up it reduced
- x. '1' N
- i. 19 pressure.
-- s .
^
l
-=20 . Q You knew that also by looking at the
! c
, ,3- ,
n
~i March 29', 1978 event? ?
gj '
I 29 i ' A' " Correct.- i lq *-
s }. s Ot - ' l l
23 4 Q You knew you would' eventually go down to l l v s l' ,. a i l .
- 24 1
.l..
the,initia' tion point for emergency safeguards and the l l
+
s qN l.
l
A ' ,\. 25 HPI. system?j
.l l
~
1
, pr4 1 i met- 1 5 g K
.- \ ,.
i i
! ,'*" ,0 * '
(*
]f q , ,
( q :
z l a.s-r :
1 Noll 113 MR. GLASSMAN: What do you mean by
) 2 3 "*V'"t"*11Y"?
4 Q If pressure continued to fall as a result 5 of the open PORV, eventually the setpoint would be i 6 reached for the emergency safeguards system?
7 MR. GLASSMAN: Are you asking whether the 8 witness thought about this in any context other 9 than the March '78 loss of power cituation to 10 . which.hc testified?
11 MR. WISE: I don't understand that 12 comment.
(} 13 MR. GLASSMAN: I don't understand your
, 14 1 question otherwise, Mr. Wise. I mean --
15 Q Mr. Noll, who was the first ?iesident of 16 the United States?
17 MR. GLASSMAN: Oh, come on now, Mr. Wise. ,
i, 18 MR. WISE: I just want to make a point 19 because I am tired of these objections.
20 MR. GLASSMAN: I will not him go into the 3; history of the United States, Mr. Wise. l G b l t
23 Q You know who the first president was?'
23 i A Yes. .
I
- 24 Q ~It was George Washington, right? !
f~ . ;
\ )h- 25 A Yes. i i
1 Noll 114 2
Q And you knew that yesterday, right?
3 3 y,,, l Q Did you think about that at all yesterday?
5 A No.
6 Q .But now that you knew it yesterday --
A Yes.
Q --whether you specifically happened to have 0
! an occasion to sit down and recollect about it and
'- 10 think about it you know that yesterday you knew who l
- 11 the first president was. '
12 Now, it is in the same sense that I am asking these questions. I don't care whether you 14 specifically sat down and thought about it and happened to be sitting at a table and thoug'ht who was ;
the first president or specifically some particular 17 thought about HPI actuation.
!- I am asking the questions in the same 19 sense as the ones I just asked about the first 20 president. It-is basically did you have that-knowledge i'
lll during that. time period such that it was available j 22 to you in the event that you had thought about it 23 nod whether you specifically sat down and spent l 24
("] some time cogitating about one specific issue or
(_/ I 25 another. Now, let me go back. ;
i 1
l
- ~
e-' m w-e 4 +- wy-- --
r--- -gy n g-g---, gayw ,---g-we- e ,-+wve *,Mg 7$ t-y
l' Noll 115 2 What I am asking is did you have an
? -
3 understanding-or did you have knowledge in February 4 1979 that as a result of a pressure decrease following O an open PORV, eventually the safeguards actuation 6 setpoint would be reached and high-pressure injection 7 would begin?
8 g yes, 9 Q You had seen that in the March 1978 event?
l 10 MR. GLASSMAN: Hsit a second. You are f
- 11 talking about he saw that? I think he testified
- 12 as to what he saw in the control room as 13 opposed to what he may have learned at some 14 subsequent time.
15 When I say "seen" I mean it had been Q
i 16 reported'to you and you wara aware that that had i
17 occurred?
18 After the occurrence, yes.
l ,
A I
19 During the March 1978 ev.ent?
Q 20 g yes, h 21 Q Were you at all concerned in February, 22 1979 that if the pilot operated relief valve were to 23 -remain open and if the operators did not have a true ;
!. j I
' 24 indication of its~ position, that a serious accident 25 might take place? I
4 1 Noll 116 2 A No.
Q Did y u have an understanding in February, 3
4 1979 of the basic principles governing the operation lh 5 of a pressurized water reactor?
6 A A general understanding.
7 Q Did you understand that the reactor i
g coolant system was kept under high pressure?
9 A Yes. -
10 Q Did you understand the relationship l
11 between pressure and temperature with respect to the 1
12 boiling point of water?
13 A Yes.
}
I 14 Q Did you understand that as pressure increases ,
t
. 15 the boiling point of water increases?
i 16 A Yes.
17 Q Did you understand the-opposite was true 18 as pressure decreased the boiling point of water 19 decreased?
20_ A Yes.
l l
21 Q Did you understand that boiling in the f k
j 22 reactor coolant system except in the pressurizer was c
23 ,
something that wasynot supposed to occur in a
! i l i
' 24 pressurized water reactor? l
[ !
D)- 25 A Yes. I i
h l-t-
l 1 Noll 117
() 2 Q Did you understand what the consequence 3
f a continuing decrease in pressure would be in a 4 pressurized water reactor?
5 A Generally, yes.
6 Q Did you understand that it would eventually 7
result in saturation once the pressure decreased to the 8 saturation pressure for water at the temperature 9 existing in the system at the time?
-10 MR. GLASSMAN: Can 1 have that read back?
11 (Question read.)
12 MR. GLASSMAN: Are you asking him whether .
l
()
13 these concepts were something that he understood 14 in terms of a pressurized water reacto'r or whether 15 he understood in some theoretical context what 16 saturation was?
17 MR. WISE: No, in the context of the 18 operation of a pressurized water reactor.
19 A I think generally I understood that if 20 the pressure decreased you had the possibility of
,21 boiling occurring in the system, yes.
ggg 22 l Q Did it occur to you in' February and early i
23 '- March, 1979 when you had this change / modification ,
,: I, 24 under consideration that one of the consequences of 75 '
O, the operators not having a true indication.of the 1
I 25 i
l l
1 Noll 118
() 2 position of the PORV was that pressure might decrease 3
to the saturation point?
i 4 A No.
5 Q Did you have any understanding as to whether 6 the operators had any other indication of the position 7 of the pilot operated relief valve besides the 8 indicator light that was then existing?
9 A You asked about the position, if they had 10 any other indication of the position of the PORV valve?
11 Q That's correct.
12 A No, I did not know.
13 Q And you knew at the time that the indicator i
-( )
14 light that they had might not provide a true picture 15 of the valve position, isn't that right?
A That is correct. l 16 l
j 17 Q Did you have any understanding at the time i
18 as to whether the operators had been made aware that 19 the light that they had would not provide a true i 20 indication of valve position under certain circumstances?
21 MR. GLASSMAN: Can I have that read.back?
22 (Question read) j 23 l A No, I wasn't aware that they were.
l !
! 24 l Q Did you have any belief one way or the D
l (V 25-l other about what the operators know? j.
. - - - . . _ . - . . - - . - - - . ._,.y. ,m.--.,-- .-.
1 l' Noll 119 I
() 2 A No. ,
g Did you care?
3
!. 4 MR. GLASSMAN: Are you asking whether l llf 5 that was something that was part of his 6 responsibility or personal function or concern?
I 7 Q Did it bother you in any way or was it a 8 matter of concern to you whether the operators 9 understood what the existing indication light showed?
10 MR. GLASSMAN: Objection. I still don't 11 know what you are talking about " concern." If 12 it is something he inquired.into or something
() 13 lue knew about then the're might be-a basis'for
- 14 the question whether there was a< concern. You
- 1' 15 are getting awfully abstract here. ,
I I
16 MR. WISE: I don't think it is abstract.
17 I will stand on the question.
18 A My understanding would have been that the
- s .
19 Operators understood the operation of the plant, you i 20- know, the various equipment there that they were to know l
21 the operation of; that would have been my thought.
22 MR. GLASSMAN: I would like to have a break l j 23 for judt a moment. Come outside.
l y% 24 (Recess taken.)
G 25 MR. WISER Let me have the last question
[
t .
1 Noll 120
,p 2 and answer read. .
MR. GLASSMAN: Let me talk to you one 3
4 more second.
' (Recess t,ak en . )
5 6 BY MR. WISE:
7 Q During your work on this particular change /
8 modification request, what efforts, if any, did you 9
make to determine what event had occurred at TMI or 10 any other nuclear stations involving the PORV sticking 11 OPen?
i a
12 .A None.
() 13 Q Did you have any knowledge one way or the 14 other whether that had ever occurred besides the one 15 event that you were aware of that occurred in March, ,
I 16 1978 at TMI-27 I
e i
17 MR. GLASSMAN: You are talking about the
, 18 event of loss of power?
19 MR. WISE: Yes.
i l 20 A No, t
21 Q You never made any investigation to find ggg 22 out whether such events had occurred at TMI or other !
23 Pl ants?
I l < ;
D_ 24 A No.
( I
~
! 25 Q Did you at that time make any {
i I
l l
l
- Yv
1 Noll 121 l
2 investigation t7 determine whether there had been any mechanical failures discovered with respect to the 3
4 PORV's at TMI-1 and TMI-27
/ 5 A No.
6 Q It did not come to your attention at that 7
time that there had been a problem on the TMI-1 8 PORV?
l 9 A No. =
10 Q You did not learn at that time that the 11 TMI-1 PORV had been rdmoved and shipped back to its 12 manufacturer, Dresser Industries't 13 A No.
14 Q Did it come to your attention that there 15 had been a mechanical problem with the PORV at TMI-2 i
16 which was discovered during startup and test in late 17 August, 19777 18 A No.
19 Q You knew nothing about either of those 20 instances that I have just mentioned while you were 21 working on this particular request?
9 22 A correct. ,
23 Q Neither Mr. Kunder nor Mr. Bensel ever 25 them?
Noll J22 1
-( ,
2 A Not that I recall.
l Q They did not mention the October, 1978 3
4 situation where the valve remr.ined closed despite i 5, an indicator light showing it was open?
6 A Not that I recall.
Q After the conversation, I take it, you 7
8 wrote up in longhand the memorandum which was 9 dispositive of the request?
10 A Yes.
11 Q Did you do that right afterwards?
12 A From what I recall very close to it, yes.
l
() 13 Q In a couple of days? ,
14 A Definitely, yes.
15 Q And at the same time you would have signed 16 the task assignment form which is the first part of 17 this exhibit?
18 A Correct, when the typed version came back 19 and I signed the typed version , I would have s.igned i
20 the task as being completed and put the date in there.
21 Q And on this task assignment form the ggg 22 project complete date is listed as March 16, 1979, 23 is that correct?
I I
<~g 24 A Right.
I- ]
L 25 Q Is that.something that you filed?
i l
i
.- _ , . . . . . _ _ . . ,m ,,.._..._v,.,..,,
1 Noll 123 A Yes.
) 2 3 Q L oking at the typed version of the 4 memorandum, it is dated September 4, 1979. I don't r 5 understand why there is the divergence in dates?
6 A Okay, the normal procedure for the 7 generation engineering with quality assurance 8 procedure was the memo got typed, a number was 9 assigned, but the date was not put in.it was left 10 blank until the person at the bottom signed it. So 11 the September 4, 1979 date would be the date that Ron ,
I 12 Prabhakar signed it for George Troffe'r.
() 13 Q So it is your understanding that this ' t 14 particular sheet, dispite the fact it is dated 15 September 4, 1979 was actually completed and filled 16 in with the exception of the signatures and the date 17 sometime in March, 1979?
18 A Correct, March 16 to be exact.
19 Q Now, looking at the memorandum which you 20 wrote, the discussion contains a section labeled 21 " Background."
ggg 12 MR. GLASSMAN: You are talking about page 23 W3801a of B&W 7677 t 24 MR. WISER Yes.
/ s, 25 Q It begins "After inadvertent operation of i
. .. . ~ _-. . . . . . . _ . _ _ _ _ , _ _. - _ _ _ _
f 1 Noll 124 RC-RV2 d' iring startup at TMI-2 it became apparent that
( 2 3
inoication of the status of the pressurizer 4 electromatic relief valve, RC-RV2, was necessa ry . "
h 5 I take it that is a reference back to ,
6 the March, 1978 incident?
7 A correct.
8 Q When you wrote this who was it that you 9 had in mind that "it became apparenu that indication 10
' of the status of the valve was necessary"? 3 11 A Whoever submitted the request for the 12 indicating light.
l '
13 Q That was s om ebo dy on the GPU staff?
I 14 A I don't recall who it would have bean.
15 Q You remember reviewing the Burns and Roe 16 change / modification form? It is mentioned in the 17 very next sentence.
l 18- A Correct, when I reviewed the request for 19 that I would have reviewed that engineering change 20 memo.
I 21 Q And that is what you weretrelying on when !
l l
22 you wrote this? ;
23 ; A That change memo told me as r. s engineer
_ 24 how the indicating light was installed.
'~' I guess what I am driving at, Mr. Noll, 25 Q {
1 Noll 125 2 you didn't have any other convercations with operating 3
staff or anyone else which led you to conclude that 4
after the March 29, '78 incident there was an awareness
! 5 of the need for indication of PORV position?
6 A No.
7 Q The only thing you were relying on is the 8 fact that there was a document as mentioned in the 9 following sentence indicating that the change / j l
10 modification was put through?
11 a Yes.
12 Q Do you know of any reason why after you 13 submitted this on March 16, 1979 nothing was
(}
14 apparently done with it entil August of 19797 15 A No, I don't.
16 Q That never came to your attention?
17 A No.
- 18 Q on March 16, after you. submitted this, 19 this was the last you ever heard of-it until we called 20 upon you here today?
l 21 A Yes.
22 Q During any of the investigations that t
23 ~ .followed the accident, did anyone from GPU ever come l 24 around to you and ask you any questions about his t
'~~
25 requested modification to the indicator light? !
1 Noll 126
(~N
() 2 A No.
3 Q Did you ever seek out anyone and mention 4 to them that you had had this particular request under 5 review shortly before the accident?
6 A No. l 1
l 7 Q You were aware, were you not that during 8 the accident the pilot operated relief valve stuck 9 .open? ;
10 A By "during the accident" --
l i a 11 Q You are aware of the accident in March, 12 1979 at TMI? .
13 A Yes.
14 Q You are aware that that accident involved 15 a stuck"open PORV?
16 MR. GLASSMAN: .You are asking whether he 1
17 is aware of that now?
18 MR. WISE: Yes.
19 A Yes.
20 Q You became aware of that shortly after 21 the accident, didn't you?
ggg
! 22 A Yes.
I - l 23 Q That was generally known knowledgeoat the t
(y 24 Island at the time?
~%) '
25 A Yes.
. ,+ , - . ,- ~-,a r.- , . - - .
I 1 Noll 127
.( f 2 Q You were there for three or four months, 3 I believe, after the accident?
~4 A Working, yes, assisting in the recovery.
5 Q You are aware that during the first two 6 hours and 15 minutes or so of the accident the operators 7 were unaware that the pilot operated relief valve was 8 in the open position?
9 MR. CLASSMAN: Are yoa asking whether he 10 ever had heard about that?
11 MR. WISE: I will ask the -- let me withdraw 12 the question. ,
During the three nonths th at ' you vere at
( 13 Q 14 the Island following the accident, did anybody ever 15 tell you that operators had been unaware for a period P
16 of over two hours that the pilot operated relief valve 17 was open?
18 A I don't recall.
, 19 Q That didn't come to your attention?
20 A I knew the pressurizer relief valve was 21 open. How long it was open, I don't recall.
22 Q You knew that the operators had failed' '{
23 to discover its open position?-
g3 24 MR. GLASSMAN: When or what? He learned Q,
25 something of that. sort? Did someone tell him
1 Noll 128 2 something like that?
('
3 Q Did you think that what happened at TMI-2 4 on March 28, 1979 was particularly significant?
5 MR. GLASSMAN: Can I have that read back?
. 6 (Question read.)
7 MR. GLASSMAN: What are you talking about, 8 Mr. Wise? I mean everyone knows we had an 9 accident I mean this is a ridiculous line of 10 questioning. .
l 11 MR. WISE: Dc yo2 object to the quostion?
i 12 MR. GLASSMAN: Yes, I mean --
13 . MR. WISE: I stand on it. I would like an 14 ansver.
15 Q Did you think it was signidicant?
- 16 MR. GLASSMAN: When?
i 17 Q Did you think after the accident it was 18 a significant event that occurred at TMI-27 19 A I don't know the definition 6f 20 significant. I knew there was an event that occur i-21 Q Mr. Noll, you are fencing with me.
gg 22 You knew that-the accident at TMI-2 was {
l-l 23 : major event?
l i
24 A Serious occurrence.
n
\)
25 Q Everybody at Met Ed was aware,of what I
1 Nall 129 2 happened?
v 3 A Everybody in the country was aware of it.
4 Q It got on national news?
5 A That is correct.
6 Q And shortly after the accident, you got 7 down to the Island, is that right?
8 A Correct.
9 Q - And the main topic of conversation down 10 at the Island was the accident and the recovery from l '
d l 11 the accident, isn't that right?
12 A Recovery from the accident, right.
}
13 Q During -he course of that, did it over 14 come across your attention what had csuaed the i
15 accident?
16 MR. GLASSMAN: Objection. You know, we are 17 talking about what had caused the accident. We 18 obviously have a lot of testimony in this case, 19 in fact, the whole case about what caused the l
20 accident, Mr. Wise. I don't understand what the 21 object of this question is.
22 Q Were you interested in finding out how
~
23 the accident had happened?
I I
24 A I think everybody was interested in finding 73 l i 25 out how the accident happcned. I
i 1 Noll 130 ,
l 2 Q And during the course of that time you 3 learned that the PORV had remained open at TMI-2 for ,
4- some period of time during the early part of the j
/ 5 accident, right?
6 A As far as general information that was 7 'available to everybody, yes.
8 Q Why don't you tell me what you learned 9 when you get down there and you worked there for three :
)
10 } months about what had happened during the accidelit 11 . during the first two hours. Just very briefly if you
'l 12 know anything at all about what happened.
() 13 MR. GiASSMAN: Wait a second, Mr. Wise. You 4 14 are asking what he heard.from someone? Are 15 you asking him to somehow, you know, attempt to 16 reconstruct what was on the news media? -
17 Are you asking him what?
18 I mean this is a strange line of questioning 19 here what one heard during a three-month period 20 of some sort relating to the accident. I am sure 21 there is plenty of speculation, I am sure there 22 is fact. This witness wasn't there when that !
l
~
23 occurred.
t l.
l 24 What is the object of this line of
^) -
RJ 25 questioning? .
i
& w + y -wgew. vy--- g
1 Noll 131 O)
(_ 2 MR. WISE: I stand on the question; you put 3 your objection on the record.
4 THE WITNESS: Coul'd you read the question 5 back?
6 BY MR. WISE:
7 Q Let me just restate it f or you.- Can you 8 tell us very simply in your own words when you got 9l down to the Island immediately after this accident 10 ld that occurred at the end of March what was your 11 understanding as to what had happened in the accident?
12 A I wasn't sure what happened because when (n) 13 initially we got down there I was busy with the 14 recovery of the unit to get it to a stable condition.
15 Q At any point after you got down there, 16 did you learn what had happened during the accident?
17 A I don't think I learned what the cause of 18 the accident was, no. A lot of speculation.
l 19 Q Put aside the cause of the accident, did
~
20 you learn what happened? How did the accident begin?
21 MR. GLASSMAN: What do you mean by " learn"?
22 I mean, are you asking whether he conducted an l 23 investigation? Are you asking whether he had a l l 24 l conversation in the street or in a bar?
/);
\
25 '2his witness didn' t do an investigation of
1 Noll 132
( 2 , how the accident occurred, Mr. Wise, that is why 3 we are'here in this case.
4 MR. WISE: I think you'are being 5 obstructive at this point, and I really think 6 this is silly.
7 MR. GLASSMAN: I think the line of 8 questioning is silly.
9 MR. WISE: I think I am entitled to ,
10 establish and find out whether this witness 11 learned that durit.g the course of the March 28, 12 1979 accident the PCRV remained open for a period
{
() 13 of over two hours, and I think I am entitled 14 to establish that it was this uitness who was 15 working for Met Ed,went down to the Island 16 and was working for three months and didn'.t know 17 that. I would like to get that in the record 18 so the judge can have some idea of the extent 19 of knowledge of the people who Met Ed sent to i
1 20 work.
21 MR. GLASSMAN: Mr. Wise, the witness
.22 already answered your question. Let me finish i !
23 my statement, Mr. Wise. I object to your l
24 interrupting my putting even a sentence on the t
U 25 record here.
1 Noll 133
(~'N 2 The witness was asked that question just N-]
3 a few moments ago. He told you that after the 4 accident he became aware thau the PORV had been Opened, and he was not aware of the amount of lh) 5 6 time it was opened.
7 That was on the record a few moments ago.
8 We can have the reporter read it back, if you I
9 like. i i
10 MR. WISE: Since the timo that I asked the j
l l 11 question, approximately 15 or 20 minutes ago, 12 and you took a break and went out of the room
/ 13 for some period of time, I have had an objection k
14 to virtually every question I have asked. It is ;
15 obvious there has been a change in tener in your 16 defense at this deposition. I had hoped to 17 conclude it rather rapidly.
18 If this obstruction is going to go on, we 19 will take a lunchbreak and be here all afternoon 20 because I am not going to stop on this, and we 21 will just keep continuing.
22 MR. GLASSMAN: Mr. Wise, it is 1:10 in ,
i 23 the afternoon. We have gone past the normal 4
24 lunch break time. I have indicated to you when !
r~N l
\' - )
25 we just took a brief break that we were hungry, l
4 1 Noll 134 2 but we were willing to continue the questioning
)
3 even if we were hungry if you thought you could 4 get done quickly. If you have got,some line of h 5 questioning'that you want to finish go ahead 6 and do it. ,
MR. WISE: Let's see if we can proceed 7
8 without any further speeches.
9 BY MR. WISE:
10 Q Can I just get an answer to the simpic l g l'
question: It in true th at y9u learned after the 11 l 12 accident the PORV had been open during the accident?
t 13 That was the cause of the loss of coolant, isn't'that
]
14 true?
15 A My understanding, yes.
1.
16 Q And it was your understanding that the i
17 operators had not diagnosed that during the course of 18 the accident the first two hours?
19 A That wasn't my area. I don't know.
m 20 Q You knew it had remained opened and there 21 had been a loss of coolant accident at TMI-27 S
22 A Yes.
23 Q Did it ever-occur to you to go back-to i
- 24 Mr. Kunder or Mr. Bensel and discuss with one.of them 25 the coincidence that shortly before the' accident,
.- j
.. _ - _ . - - . , _ . ~ - . -- - - - - .
g Noll 135
/
(_) 2 as a matter of fact, within two or thre e weeks of the 3
accident you had had a phone conversation with them 4
concerning the supply or installation of an indicator 5
light at TMI-2 for PORV valve position?
0 Coincident with what, MR. GLASSMAN:
Mr. Wise? I don ' t know what you are talking about 8
here.
O Are you talking about the fact that there
, was an indicator light which mLy have operated, i
-11 '
- think did operate on the day of the accident?
I' -
12 I mean I don't know what this witness knows.
I~h 13
(_) , MR. WISE: That's a good argument and I am 14 glad the reporter got it down so whoever is 15 reading this can have the benefit of your speech.
17 Now, I would like an answer to my question. '
18 I will stand on the question.
19 A No.
! 20 MR. WISE: I think.those are the only gg questions I have.
22 I MR. GLASSMAN: We will take a quick break. ;
23 ,
24
()
A_.)
(continued on the next page.)
! 25
_ _ _ _ , - . - .. -_-. . .= . - . . .
Noll 135-A l'
2 (Recess taken.)
.O 'M R . GLASSMAN: I have no questions of this 3
4 witness at this time.
h 5_
MR. WISE: Okay.
i
.6 (Time noted: 1:16 p.m.)
7 -ooo-
- 8 9 RICHARD C. NOLL 10 subscribed ar.d sworn to .
i 11 before me this 12 day of , 1982.
. O 14 .,
i 15 16 17 18 i .
19 20 21' 22 j ,
l l 23 ;
24 25 l
1 Noll 136 l
,, =
SEE$1E1bd$E 3 STATE OF NEW YORK )
- ss.:
4 COUNTY OF NEW YORK )
5 6 WALTER SHAPIRo, CSR I, ,a 7
Notary Public within and for the State of New York, 8
do hereby certify that the foregoing deposition 9 of PIcHARD C. NoLL t
was taken Defore 10 me on_we dn e s d ay , .7uly 14, 1982 ;
4 11 That the said witness was duly sworn 12
-s before the commencement of hi8 testimony and
'L / 13 ~
that the within transcript is a true record of said 14 testimony; 15 That I am not connected by blood or 16 marriaSe with.any of the parties herein nor 17 interested directly or' indirectly in the matter in 18 controversy, nor am I in the employ of any of the 19 counsel.
20 IN WITNESS WHEREOF, I have hereunto set 21 my hand this M day of I \ , /Tb v
22 i
23 7 I i
O .Y ' N kJ 24 WALTER SHAPIRo V 25
IV 82 337 I N D E Z
)
WITNESS: PAGE S RICHARD C. NOLL 3
E X H I B I T S B&W FOR IDENTIFICATION 896 Copy of the resune of Richard C. 4 Noll.
b O .
4 L
-oOo- -
'I
/ ,
+
4 i
s /
Q > < ,
i
/
' /
e s ";
RICHARD C. NOLL i EDUCATION: -
Drexel University, B.S.
Electrical Engineering, 1971.
EMPLOYMENT:
June 1971 - September 1971: Metropolitan Edison Company; System Planning Dept., Engineer.
September 1971 - February 1972: Military Leave; Army National Guard February 1972 - December 1976: Metropolitan Edison Company; various positions at Titus Station, including Plant Engineer, Maintenance Engineer, Maintenance Foreman, -
Station Engineer..
January 1977 - December 1977: Metropolitan Edison Company; Generation Engineering Department; Generation Division - Electrical and Control Engineering Section -
Engineer.
() January 1978 - June 1978: Metropolitan Edison Company; Three Mile Island Nuclear. Station; assisted lead electrical engineer in Unit 2 start-up prcgram.
July 1978 - March 1979: Metropolitan Edison Company; Generation Engineering Department (see 1/77 - 12/77).
April 1979 - June 1979: Metropolitan Edison Company; I Three Mile Island Nuclear Station;
, engineering support following
,TMI-2 accident.
s July 1979 - October 1979: Metropolitan Edison Company;.
Generation Engineering Department (see 1/77 - 12/77) .
October 1979 - June 1980: Metropolitan Edison Company; Titus Station, Shift Foreman.
l June 1980 - January 1981: Metropolitan Edison Company;
} Titus Station; Supervisor of '
Maintenance.
January 1981 - present: Metropolitan Edison Company; Titus Station, Supervisor of Operations. '
m; Doyle .% g ::::::::::::::
he. n.,u a , ... s