ML20072J068
| ML20072J068 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 01/27/1982 |
| From: | Kennedy R BABCOCK & WILCOX CO. |
| To: | |
| References | |
| TASK-*, TASK-03, TASK-06, TASK-07, TASK-3, TASK-6, TASK-7, TASK-GB NUDOCS 8306290905 | |
| Download: ML20072J068 (102) | |
Text
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bt UNITED STATES DISTRICT COURT s
SOUTHERN DISTRICT OF NEW YORK
-x GENERAL PUBLIC UTILITIES CORPORATION, JERSEY CENTRAL POWER & LIGHT COMPANY, METROPOLITAN EDISON COMPANY and
(
PENNSYLVANIA ELECTRIC COMPANY, Plaintiffs,
-against-80 Civ. 1683 (RO)
THE BABCOCK & WILCOX COMPANY and J.
RAY McDERMOTT &
CO.,
INC.,
Defendants.
-__________--___t_x Deposition of The Babcock & Wilcox Company g
by ROBERT K.
KENNEDY, taken by Plaintiffs, J
pursuant to Notice, at the offices of Kaye, Scholer, Fierman, Hays & Handler, Esqs., 425 Park Avenue, New York, New York, o'n Wednesday, January 27, 1982, at 10:45 o' clock in the forenoon, before Joseph R.
Danyo, a Shorthand Reporter and Notary Public within and for the State of New York.
03j6
[o DR T
ra G
DOYLE REPORTING. INC CERTIFIED STENCTYP E REPCRTER 369 LEXIN GTO N AVENUE WALTER SHAP!RC, C.S.R.
New Yonx. N.Y.
IC017 CHARLES SHAPfRC. C.S.R.
TELEPMcNE 212 - 867 8220
_. - -..,.. - -. ~. -
1 2
0 2
App ea ranc e s 3
4 KAYE, SCHOLER, FIEPMAN, HAYS & HANDLER, ESQS.
Attorneys for Plaintiffs
(~;
5 425 Park Avenue New York, New York 6
By:
ANDREW MacDONALD, ESQ.,
7 of Counsel 8
9 10 11 DAVIS POLK & WARDWELL, ESQS.
Attorneys for Defendants 12 One Chase Manhattan Plaza
}
13 By:
RODMAN W.
BENEDICT, ESQ.,
14 of Counsel 15 16 17 Also Present:
18 DAVID TAYLOR
~
19 20 21 IT IS HEREBY STIPULATED AND AGREED by 22 and between the attorneys for the respective 23 parties hereto that the sealing, filing and
/~h 24 certification of the within deposition be, and
.V 25 the same hereby are, waived; that the transcript
1 3
O~
2 may be signed before any Notary Public with the 3
same force and effect as if signed before the 4
Court.
(
5 IT IS FURTHER STIPULATED AND AGREED that 6
all objections, except as to the form of the 7
question, are reserved to the time of trial.
8 9
10 rob E RT K.
KE NN E D Y, L
having 11 been first duly sworn by the Notary Public, 12 was examined and testified as follows:
(Ns'~3 13 EXAMINATION BY MR. MacDONALD:
14 Q
Have you ever been deposed before?
15 A
No.
16 Q
Have you ever given testimony of any 1
17 kind sworn under oath?
f 18 A
No.
l l
19 MR. MacDONALD:
I would like to mark as l
20 GPU Exhibit 430 a copy of the resume of Robert 21 K.
Kennedy which I received from counsel for 22 B&W this morning.
23 (Res ume of Robert K.
Kennedy marked
[~\\
24 GPU Exhibit 430 for identification as of this 25 date.)
1 Kennedy 4
~
2 Q
Is this a copy of your resume which you 3
prepared in preparation of this deposition?
4 A
It was prepared some time ago but
('
5 Q
It is current as to y.our most recent 6
position?
7 A
Ye8-l i
8 There is a statement at the top relative 9
to attending classes at night.
That is not really 10 correct at this point.
t i
11 Q
Under " Education"?
12 A
Yes.
t 13 Q
According to the resume, you came to 14 Babcock & Wilcox in April 1972.
15 A
That's correct.
2 16 Q
And at that time you were a senior engineer 17 responsible for technical requirements and application 18 of reactor coolant pumps and drive motors on B&W NSS2 19 A
That's correct.
4 20 Q
To whom did you report at that time?
21 A
I started out reporting to a B.B.
Cardwell 22 and then after several months I reported to W.
S.
23 Spangler.
24 Q
Both of these gentlemen were the managers 25 of the pumps and drives unit?
4 1
Kennedy 5
O' 2
A Yes.
3 Q
What section of B&W is the pumps and drives 4
unit a part of?
(
5 A
Now it is a part of the RCS component 6
engineering section.
7 Q
Was that different in some point in 8
time in the past?
9 A
Yes.
10 Q
What section was it a parttof at some point 11 in time before?
12 A
It was a part of the fluid and mechanical D)
(..
13 systems section before the reorganization.
14 Q
At the time ycu came to B&W into the pumps 15 and drives unit,who was the manager o f that 16 section, fluid and' mechanical system, do you recall 17 A
I don't recall.
18 Q
Who is it today7 19 A
Fluid and mechanical systems no longer 20 exists in that forn.
21 Q
In the form that it is in today?
22 A
F.
R.
Fahland.
23 Q
Did Mr. Stanek hold a position as section 24 manager of fluid and mechanical systemIat some point 25 in time?
1 Kennedy 6
(_/
2 A
Yes, he did.
3 Q
When was that?
4 A
Approximately 1978 to 1980.
(
5 Q
Pumps and drives unit and the fluid and 6
mechanical section in its present-day form is in the 7
engineering department?
8 A
Yes, it is.
9 Q
Has it always been a part of the 10 engineering department?
11 A
Yes.
12 Q
Since you have been at the company?
13
- A That is right.
14 Q
Do you know that you have been designated 15 by B&W as the person most knowledgeable regarding 16 the ability of reactor coolant pumps to function with 17 void fractions in the reactor coolant system?
18 A
Yes.
19 Q
Have you since the time you came to B&W 20 in April 1972 dealt with reactor coolant pumps and 21 their operation in the B&W NSs and in its reactor 22 coolant system?
23 A
Yes, I have.
[ ;
24 Q
According to your resume, you became u,'
25 unit manager o f pumps and drives in February 19767
1 Kennedy 7
L 2
A Right.
3 Q-As a unit manager in pumps and drives, 4
did you attend regular meetings of any sort of the
([
5 fluid and mechanical systems section?
6 were there such meetings?
l 7
A Yes, there were meetings of various 8
descriptions.
9 Q
Were they on a regular basis staff 10 meetings?
i 4
11 A
Yes.
r 12 Q
Was it a regular basis of a month or a week?
Cl) 13 A
It varied.
Perhaps from one week to a i
14 month.
15 Q
Were there different types of staff 16 meetings that were conducted on a regular basis?
7 l
17 A
Yes, administrative, technical, basically.
18 Q
What was discussed at technical meetings?
19 MR. BENEDICT:
You mean what sorts of 20 subjects came up?
21 MR. MacDONALD:
Yes, in general as 22 opposed to administrative.
23 A
A lot of the meetings dealt with integration I) 24 of technical functions at the staff level.
(/
25 Q
Among different units or departments?
i
1 Kennedy 8
O 12 A
Different units within a section.
3 Q
Did you ever attend meetings with other 4
units or other sections'outside of fluids and s
(,
5 mechanical systems or.its present form?
6 A
Yes.
7 Q
Were these held on a regular basis?
8 A
Not a regular basis.
9 Q
How often did you attend such meetings 10 that might have been held outside of ydur section?
11 MR. BENEDICT:
You mean how often did he 1-i 12 attend such meetings after he became unit
(~)T
(-
13 manager?
14 MR. MacDONALD:
Yes.
15 MR. BENEDICT:
What you recollect.
16 A
My recollection is it varies again.
17 It could vary from a week to a month.
~
18 Q
Were those meetings held with other 19 sections in the engineering department?
l 20 A
Yes.
21 Q
Were individuals who were in the plant 22 design section in attendance at some of those meetings?
23 A
Yes, they were.
24 Q
Prior to the time of the TMI-2 accident, 25 had you heard of a transient that occurred at
s 1
Kennedy 9
!-n U'
2 Davis-Besse nuclear facility in September 1977?
3 A
Yes, I had.
4 Q
How did you learn of such transient?
(
5 A
I learned I believe the day of the 6
7 Q
From whom did you learn?
8 A
Probably from the section manager who 9
was Mr. Stanek at that time.
10 Q
Do you recall what was related to you t
11 about the event?
12 A
I recall that there was a depressurization i
13 event and the plant had been shut down.
14 Q
Was this an oral conversation between 15 you and Mr. Stanek?
16 A
At that point in time, yes.
17 Q
Were you the only one present_?
18 A
I don't recall.
19 Q
Subsequent to that conversation, did i
I 20 you learn anything else about that transient at a 21 later point in time, all of this prior to the time 22 of the TMI-2 accident, other than it was a 23 depressurization event?
24 A
I don't recall specifically what I 25 learned.
~
1 Kennedy 10 O
2-Mr. MacDONALD:
I would like to mark as 3
'GPU Exhibit 431 a document whose first page 4
is a memo from J.
A.
Lauer to distribution,
(
5 October 11, 1977.
There are a number of 6
attachments to it.
It is a 21-page exhibit.
7 (21 -p a g e exhibit, first page of which is 8
a memo from J.
A.
Lauer to distribution, 9
October 11, 1977, marked GPU Exhibit 431 10 for identification as of this date.)
11 Q
You are noted on distribution on the 12 first page of this document.
[)
(/
13 Could you take a moment to look at it 14 and tell me if this is a copy of a document you 15 received on or about October 11, 1977 in the regular 4
16 course of business?
17 A
Yes, I believe it is.
18 Q
This document says in the third line 19 down from the top, "Cust. Toledo Edison Company 20 DB-1.
Subj.
Report on Depressurization Event."
21 To your understanding at the time you 22 received this document, it was related to the 23 Davis-Besse September 24, 1977 transient?
I\\
24 A
Yes, it was.
%,)
25 Q
Did you attend a briefing in the latter i
1
_.m
- y.,.. -., _,, _.
..m-
1 Kennedy 11
\\-
2 part of September with anywhere from 30 to 50 other 3
B&W unit and section managers and other personnel 4
regarding the Davis-Besse transient?
5 A
I don't recall such a meeting.
6 Q
Do you know whether anyone else in your 7
unit or section attended such a meeting?
8 A
It is possible but I don't recall.
9 Q
Did you ever have any conversations with 10 any individuals in or about this time of september or 11 October 1977 about such a meeting?
12 A
I don't remember that.
13 Q
Do you know a gentleman by the name of
)
14 Joe Kelly?
15 A
I am acquainted with Joe Kelly, yes.
4 16 Q
Did you know Joe Kelly prior to the time f
17 of the TMI-2 accident?
~
18 A
I don't remember specifically when I came t
19 to know Joe Kelly.
~
20 Q
You knew he was an employee for B&W?
21 MR. BENEDICT:
Did he know or does he know 22 now?
1 j
23 MR.
MacDONALD:
Did he know?
24 MR. BENEDICT:
Prior to the time of the 25 Three Mile Island accident?
1 Kennedy 12
\\, /
9 MR. MacDONALD:
Yes.
3 A
No.
4 Q
Do you know a gentleman by the name of
(
5 Bert Dunn?
6 A
Yes, I do.
7 Q
Did you know Mr. Bert Dunn prior to the 8
time o f the TMI-2 accident?
9 A
Yes.
10 Q
Did you know he was manager.of a unit in f
11 plant design named ECCS, emergency core cooling system?
12 A
Yes.
I) k/
13 Q
Did you have occasion prior to the time 14 of the TMI-2 accident to discuss with Mr. Dunn any 15 matters relating to B&W's business in regard to the 16 nuclear steam supply systems?
II MR. BENEDICT:
You want to know whether 18 he ever talked to Bert Dunn prior to the Three 19 Mile Island accident about B&W's NSS?
l 20 MR. MacDONALD:
Generally, did he ever 21 have conversations with Mr. Dunn prior to the
~
22 time of the TMI-2 accident that involved the "3
B&W NSS or any of its components in the course
~
()s 24 of his regular business.
l l
25 A
It is possible, but I don't recall.
1 Kennedy 13 O
%J.
2 Q
Are you in the same office building 3
physically as Bert Dunn?
4 A
Yes.
(
5 Q
On the same floor or somewhere else?
6 A
Now we aren't on the same floor.
7 Q
Were you back in 1977-19787 8
A We were on the same floor.
9 Q
Approximately how close were your offices?
10 A
Two to three hundred feet.'
11 Q
Were all the different sections of the 12 engineering department and units within the
\\~/
13 engineering department located on that. floor?
Was that 14 how it was divided up?
15 A
No, as I recall, they were not all on that 16 same floor.
17 Q
Did you know a gentleman by the name of 18 Don Hallman prior to the time of the TMI-2 accident?
19 A
Yes, I did.
20 Q
Did you know that he was manager of a 21 unit in customer and nuclear service in 1977 or 1978 22 or plant performance services?
23 A
Yes.
(/i 24 Q
Did you have contact with Mr. Hallman u.
25 regarding B&W's business on the NSS in any capacity
1 Kennedy 14
(~J h
s_
2 prior to the Three Mile Island accident?
3 A
I don't recall specifically.
4 Q
Was it part of your job prior to the
(
5 Three Mile Island accident as unit manager to interact 6
with any other personnel in the customer service 7
department regarding procedures that were sent to 8
B&W's operating plants, nuclear operating plants?
9 A
As a matter of routine, we are involved.
10 Q
Is it different today than"it was prior 4
11 to the time of the accident, because you used the 12 present tense "is"?
s' 13 A
No, it is not dif f e ren t today.
i 14 Q
What was that interaction between 15 yourself and individuals in customer service?
16 A
Reviewing, providing consultation on 17 procedures.
18 Q
On the technical portions of hose 19 procedures as it related to the areas within your j
' 20 bound of expertise?
21 A
That is right.
3 22 Q
Which would be the reactor coolant pumps 23 and their operation?
24 A
Yes.
25 Q
Who in customer service in the period
-~
l Kennedy 15 f
v 2
1977 to.1978 and prior to the tine of the accident 3
did you deal with on that matter?
4 A
I don't recall specifically who it was.
(.
5 Q
Was it one designated individual or was it 6
more than one?
7 A
It was a unit which had the responsibility 8
for providing procedures to the operating plants.
t 9
Q Was it Don Hallman's plant performance 10 service section?
t 11 A
As I recall, it was not.
12 Q
Was the individual Mr. Phinney?
\\
\\s 13 A
I don't recall who the individual was.
14 Q
How often did you meet or discuss or 1
15 communicate with individuals in customer service 16 regarding procedures and your input to them as to 17 reactor coolant pump operation?
18 MR. BENEDICT:
I object.
It hasn't been f
19 established that is what he was consulting on 2
1 20 but if you want to put that as a question to get 21 it in the record --
l 22 MR. MacDONALD:
Prior to the accident 23 I think he said'he had discussions with
()
24 individuals in customer service.
I am s_-
25 attempting to find out.
i I
i
1 Kennedy 16 i
n 2
MR. BENEDICT:
That is why I am saying 3
your question states a fact not in evidence 4
or presumes a fact not in evidence.
(
5 If you want to ask him what the subjects 6
were that he talked about and discuss how 7
often they talked.
I don't recall his answer 8
saying what the subject was.
9 MR. MacDONALD:
The record reflects what 10 it reflects.
11 I think he said it was regarding reactor, 12 coolant pump operation.
,/"'T
- k. l ~
13 Q
Is that what you were discussing when 14 you spoke with individuals from customer service 15 that part of your job as unit manager of pumps and 16 drives was reactor coolant pump operation?
17 A
By virtue of my responsibility, it would 18 have been pertaining to pumps and drives.
19 Q
Did you have conversations or communicate 20 with individuals from customer service on a regular 21 basis or was it sort of an ad hoc basis?
22 A
It was intermittent as the need arose.
23 Q
Directing your attention to GPU Exhibit (D
24 431, in the second paragraph it states that,. "The B & *d s_/
25 input to TECO's report should include four separate
1 Kennedy 17 2
sections.
SPR 372 may be used as the source 3
document for information regarding the transient."
l 4
I show you a copy of SPR 372 which has
(
5 been previously marked as GPU Exhibit 133 6
Is this a document that you used as a 7
source document?
8 MR. BENEDICT:
If you recall.
9 Q
For information regarding the September 10 24, 1977 Davis-Besse transient, t
11 A
I don't specifically recall.
12 Q
So you don't specifically recall not O)
\\N' 13 every page of the document but do you generally recall 14 using this document as a source document for information 15 regarding the transient?
16 A
No, I can't say that I do.
17 Q
Have you ever seen a copy of GPU Exhibit 18 133?
19 MR. BENEDICT:
Up until today?
20 MR. MacDONALD:
Prior to the time of the 21 accident.
22 A
I don't recall.
I don't remember that 23 either.
24 Q
On the first page of GPU Exhibit 431, down 25 at the bottom it says, "The responsibility and suggested
1 Kennedy 18 k'#
2 content of the sections is as follows:" and then it 3
sets out two sections and we come to " Kennedy 3.
4 Evaluation of RC pumps including, a.
cavitation
(
5 damage to impe11ers; b.
damage to bearings; 6
c.
damage to seals; d.
startup testing."
7 Do you see that?
8 A
Yes.
9 Q
Was that to be your responsibility in 10 relation to evaluating the Davis-Besse(September 24, 11 1977 transient?
12 A
That would be affirmative, yes.
13 Q
Who gave you that assignment?
14 A
This memo was transmitted by Mr. Lauer.
15 Q
It is your understanding that Mr. Lauer 16 was the one that gave you the assignment by way of this 17
- memo?
~
18 A
yes.
19 Q
Did you attend any meetings with any of 20 the individuals on the distr'ibution list and Mr. Lauer 21 to discuss the Davis-Besse transient and what your L
22 work was to be on that evaluation?
23 A
I don't specifically remember such a I~U) 24 meeting.
25 Q
Did you perform work regarding evaluation b
1 Kennedy 19
[D V'
2 of RC pumps during'the Davis-Besse transient of 3
September 24, 1977?
T 4
MR. BENEDICT:
There is a syntactical 5
problem with the question.
{'
6 You mean af ter did he perform work with 4
7 respect to the operation of reactor coolant pumps 8
during that time?
9 MR. MacDONALD:
Yes.
i 10 A
Yes, I did.
e 11 Q
What did that work consist of?
12 A
It consisted of evaluating the data made 13 available to us.
1 14 Q
What was that data?
15 A
Performance data made available to us from 16 the transient.
I 17 Q
How did you come to obtain such performance 18 data?
f i
19 A
I don't specifically remember how we came 20 on that information.
21 Q
Do you recall what the performance data 22 was?
23 A
I don't specifically remember what that f~h 24 would consist of.
%-]
25 g
You learned, did you not, at some point
1 Kennedy 20
/ ~'N r
i L.J' 2
in time after the Davis-Besse transient that during 3
that event the reactor coolant system at Davis-Besse 4
had operated at or near saturated conditions for some 1
(
5 period of time?
6 A
Yes, I learned that.
7 Q
Do you know where you learned that?
8 A
I don't recall specifically how I learned 9
it.
10 Q
You don't recall whether it was from 11 conversations or evaluating data?
12 A
No, I do not.
(N.
( )
~'
13 Q
Prior to that Davis-Besse transient, 14 had you known of any other transient at any B&W 15 operating nuclear plant at which saturation had occurred 16 in the reactor coolant system of the PWR?
17 A
No.
18 Q
Prior to Davis-Besse, had you known 19 at any nuclear operating plant,a PWR, that saturation 20 had occurred at any point in time in the reactor 21 coolant system?
22 A
I don't recall.
23 Q
You don't recall that you knew that?
f ')
24 MR. BENEDICT:
Whether he knew that?
u.-
25 A
I don't recall whether I knew that or not.
1
)
i 1
Kennedy 21 2
Q I would like you to take a look at GPU 3
Exhibit 431 and direct your attention to.a memo that 4
is part a letter that is part of that exhibit.
(
5 It begins on page E42881,.a letter from J.
Lauer 6
to Toledo Edison.
7 MR. BENEDICT:
Is there a reference in the g
cover memo that this is part of the exhibit?
g I see there is a reference to the exit 10 interview notes of October 7.
11 MR. MacDONALD:
In the second sentence of 12 the cover page it says, " Based upon the attached 13 B&W letters."
14 MR. BENEDICT:
They are obviously 15 numbered sequentially.
I didn't know whether
=
4 16 they belonged together or not.
Thank you.
17 Q
I note that, Mr. Kennedy, you are also 18 marked for a copy of this letter.
19 I direct your attention to the second 20 page, the firs t paragraph, "The reactor coolant pumps 21 were all operated at or near saturation pressure 22 (A2 and B1 for about one minute and A1 and B2 for about 23 45 minutes)."
/~
C)/
24 After performing your evaluation of the i
25 reactor coolant pumps and their operation during the
_ =
1 Kennedy 22
' O 2
Davis-Besse transient, did you transmit conclusions 3
based upon those evaluations to Mr. Lauer?
4 A
That would have been the nature of my
(
5 responsibility.
6 However, I don't recall specifically.
7 Q
Were you asked to review a copy of this 8
letter before it was sent out?
9 A
I don't remember.
10 Q
Relative to its substantive content?
11 A
I don't remember.
12 Q
Later on in that same paragraph that I just 4
O 13 referenced, I direct your attention to the line 14 that says, "We have reviewed these conditions with
~
15 the pump manufacturer and concluded that the risk of 16 damage is small."
17 Did you undertake such a review in the 18 course of your evaluation of the reactor coolant pumps 19 and their operation during the Davis-Besse transient?
20 A
Again, that would have been within the 1
21 nature of my responsibility.
22 However, I don't remember specifically 23 doing that review.
(
24 Q
Do you remember coming to the conclusion 25 based on that review or evaluation that the risk of I
.-m
- m. -
~._.m
1 Kennedy 23
\\m/
2 damage is small?
3 A
Yes, I think that that is fair to say.
4 I do remember that.
(
5 Q
And the fact that the risk of damage is 6
small was made with the knowledge that the pumps had 7
operated during the transient for some period of time 8
at or near saturation pressure?
9 A
Yes.
10 of course,there were requaiification 11 tests performed during the startup sequence which 12 provided additional evidence that the risk of 13 damage was not great.
14 Q
Who performed those tests?
15 A
Davis-Besse with the consultation of 16 B&W.
j 17 Q
Were you involved in that?
18 A
I was aware of those te s ts.
I was not 19 personally involved.
20 Q
Did you have any responsibility with 21 regard to those tests?
22 A
one member of my unit did par ticipate in 1
23 that.
24 Q
Who was that?
25 A
John Dempsey.
1 Kennedy 24 Iv 2
Q Does he still work for B&W7 3
A No, he does not.
4 Q
Do.you know where he works today?
(
5 A
I believe he is a consultant.
6 Q
Do you know for whom or where?
7 A
I don't know.
8 Q
The subsequent sentence in that 9
paragraph that begins, "Therefore, we have recommended 10 that the pumps be instrumented to measupe shaft v
11 vibration, seal cavity pressures, RC pressure, standpipe 12 leakage, and seal injection flow and temperature,"
13 do you see that sentence?
14 What was the recommendation as to the 15 pumps being instrumented to measure shaft vibration?
16 MR. BENEDICT:
I'm not sure I understand.
17 Are you asking him to interpret this letter?
18 MR. MacDONALD:
I am asking him what his 19 understanding was of a recommendation that the 20 pumps be instrumented to measure shaft vibration.
21 MR. BENEDICT:
If you remember what you 22 unde rs too d that to mean at the time this letter 23 was written, you may answer.
()
24 A
That means proximity sensing probes on the 25 shaft.
1 Kennedy 25 b
i
\\
/_
2 Q
Were there other measures of shaft vibration 3
in existence at the time at Davis-Besse?
4 A
I don't recall.
(
5 Q
Did you look at data from the Davis-Besse 6
transient that related to shaft vibration?
7 A
I don't remember that.either.
8 Q
Or frame vibration?
9 A
It is possible, but I don't remember.
10 Q
In order to come to a conclusion that 11' the risk of damage was small, is it your understanding 12 that you would have looked at shaft and frame vibration
(~'1 13 to come to that conclusion?
14 MR. BENEDICT: I object to the ques tion.
15 He may testify what he looked at or 16 what he knows was looked at, but he doesn't a
17 have to te s tify as to how that conclusion was 18 drawn by somebody else.
19 MR. MacDONALD:
I think he testified it ic 20 part of the conclusion that he came to on 21 reviewing the data.
I am attempting to ask 22 him whether or not in reaching that conclusion 23 based on his understanding of reactor coolant
( )
24 pump operation that one of the things that he 25 looks at or would look at would be shaft and
I l
Kennedy 26 fi x_/
2 frame vibration.
3 MR. BENEDICT:
I object.
4 You may answer the question as to what
(
5 you recall looking at to reach that conclusion 6
or what you recall -- what data you recall 7
was looked at by whomever it was that reached 8
that conclusion, but you don't have to testify 9
what somebody might have done.
10 MR. MacDONALD:
You instruct him not to 11 answer the question?
12 MR. BENEDICT:
As presently framed, y e s.,
p#
13 because it is improper.
14 MR. MacDONALD:
I disagree, but let's go on.
15 Q
During the course of your employment at 16 B&W, have you evaluated the performance of reactor 17 coolant pump operation in the B&W NSS at any other 18 time aside from this particular instance relating to 19 the Davis-Besse transient?
l l
20 A
That is part of the nature of my 21 responsibility.
22 Q
Do you do that on an ongoing basis?
23 A
As the need arises, yes.
24 Q
When you make such reviews, what 25 data do you look at to assess the performance of the
~.
l 1
Kennedy 27 s-u 2
' reactor coolant pumps in the B&W NSS?
A It includes various performance parameters 3
4 as it relates to the pump operation.
(
5 Q
What are those parameters?
6 A
Shaft seal performance.
Those parameters 7
include shaft seal leakage, shaft seal 8
staging pressure. The mechanical performance 9
parameters, shaft and frame vibration.
10 Those are the primary parameters that are 11 evaluated.
12 Q
Do you evaluate all those parameters i
\\#
13 when you evaluate the operation of the reactor coolant 14 pumps?
15 MR. BENEDICT:
In every case did he.
16 evaluate each and every one of those parameters ?
the question.
17 MR. MacDONALD:
That is not 18 MR. BENEDICT:
That is the question I heard.
19 You can answer it -- tha t is the only l
l 20 way I can understand what you asked.
.21 MR. MacDONALD:
Let's put it this way:
(.
22 Q
Do you recall ever evaluating the j
23 performance of reactor coolant pump operation at any i
24 time where shaft and frame vibration were not one of 25 the parameters that you evaluated?
i
... ~..
-.,.,., _., _ _ _ -, - _., _, _ _ _ _. _, ~.. _ _, _, - -
L, 1
Kennedy 28
('.3.)
2 A
Yes, I recall such an evaluation.
3 Q
When was that made?
4 A
We recently evaluated the performance of
(
5 shaft seals on the crystal River plant.
It did not 6
include the evaluacion of shaft and frame vibration.
7 Q
Did you do evaluations of the TMI-2 accident 8
of March 28, 1979 as it related to reactor coolant p
pump operation?
10 A
Yes, I did.
11 Q
During those evaluations did you 12 evaluate shaft and frame vibrations?
A 13 A
Yes, we did.
14 Q
That was a loss of coolant accident, 15 was it not?
16 A
-Yes.
17 Q
The Davis-Besse September 24,.1977 18 accident was a loss of coolant accident, was it not?
19 A
Yes.
20 Q
Do you have any reason to believe that 21 you did not evaluate shaft and frame vib ra tio n in L
22 evaluating the Davis-Besse September 24, 1977 transient?
23 A
Would you repeat the question?
IV) 24 Q
Do y u have any reason to believe that 25 you did not evaluate shaft and frame vibration in your
I 1
Kennedy 29 a
2 analysis and review of the Davis-Becse September 24, 3
1977 transient?
4 A
I don't remember what I did or didn't do.
(
5 Q
You have no reason to believe that you 6
didn't, do you?
7 MR. BE!! EDICT :
He answered the question.
[
8 I instruct him not to answer.
You do it, too.
9 You do it all the time.
You got your answer.
10 Live with it.
Go on to the next question.
4 11 MR. MacDONALD:
I am not here to engage 12 in colloquy with counsel.
13 I am here just to ask ques tions-,
s 14 of the witness and have answers.
15 MR. BENEDICT:
I agree and you got your 16 answer.
17 As I have sat through your defense of 18 Mr. Faust, I know you have given the same 19 instruction.
So let's proceed.
l 20 MR. MacDONALD:
On the contrary.
.I hav.e t
21 allowed at least four or five repetitive 22 questions before I finally terminated the 23 question after the answer was given four or five
()
24 times.
%s 25 My question was:
\\
- \\,
1 Kennedy 30
[
s 2
"Do you have any reason to doubt that 3
that was part of your evaluation of the T
s 4
Davis-Besse September 24, 1977 loss of
\\
j{
5 coolant accident?"
}
6 MR. BENEDICT:
His answer is he doesn't i
s 7
' remember one way or the other.
It is on the l; '~
y 8
record.
i s
9 Let's move on to the next question.
10 BY MR. MacDONALD:
1
+
11 Q
I direct your attention to the October 5, 12 1977 memo'from Mr. Lauer to Toledo Edison, specifically f
a r.
13 to the third' paragraph --
14 MR. BENEDICT:
It is not a memo.
It is a 15
- letter, y
r l
16 g'
The third paragraph reads, "The 17 reactor coolant pumps wer'o exposed to conditions which 18 could have caused cavitation damage to the impellers, 19
. damage to the bearings, and seal leakage or failure.
20 None of these things appear to have happened and we 21 feel that the pumps may be operated with only minor
(.
\\
22 risk of additional damage' to the pumps.
We suggest 23 a series of = progressive start-up tests under close 24 observation in order to minimize the risk of furthering 25 any latent damages.s This is not considered to be a k
.yg-g
,J g
1 Kennedy 31 2
safety concern."
3 You are copied on this memo.
4 Do you see that at the top?
(
5 A
Yes.
6 Q
Do you recall why it was not considered 7
to be a safety concern that the ~ reactor coolant pumps 8
l were exposed to conditions which would have caused 9
cavitation damage to the impe11ers, et cetera, as I 10 just read?
11 MR. BENEDICT:
I object just for a 12 moment because I am not sure the syntax of this O
13 paragraph allows you to take the,last sentence 14 in the paragraph and re fer back to the first 15 sentence.
46 It goes on to say it "may be 17 operated with only minor risk of additional 18 damage to the pumps.
We suggest a series of 19 progressive start-up tests" 20 MR. MacDONALD:
Fine.
It can be read in 21 conjunction with the succeeding sentences in the 22 paragraph.
23 MR. BENEDICT:
My only point is it is not
(
24 clear to me that the last sentence refers to the 25 past op e ration.
It could just as well refer to l
-., _ _ _ _ -, - ~, _ -. - _...
1 Kennedy 32 2
the "may be operated" sentence or the "We suggest 3
a series of progressive start-up tests."
4 MR. MacDONALD:
Now that you testified,
(
5 now I would like the wicness to answer.
6 MR. BENEDICT:
I agree.
7 When your question is clear, I will let 8
him answer.
9 MR. MacDONALD:
The question is clear.
10 The answer is what we are here to get.
11 His answer, not yourse i
12 MR. BENEDICT:
You want to stand by the
.p.
13 question you set forth?
14 MR. MacDONALD:
Yes.
15 MR. BENEDICT:
Could you read it back?
I 16 (Record read back.J 17 MR. BENEDICT:
I state my objection, but 18 you may answer.
19 A
I don't recall specifically why that 20 statement was made.
21 Q
Did you make a recommendation to Mr. Lauer 22 to that effect?
23 A
It is indeed possible, but I don't remember
(
24 specifically.
25 Q
Prior to the time of the TMI-2 accident,
1 Kennedy 33 O
2 B&W supplied, did it not, to each utility customer a 3
curve called the net positive suction head curve.
4 A
That is possible.
(
5 MR. BENEDICT:
Just give your recollection.
6 A
I don't recall that specifically, no.
7 Q
Did you ever see a copy of B&W limits 8
and precautions prior to the time of the TMI-2 9
accident?
~
10 A
I believe the answer to thdt is 11 affirmative.
12 Q
In relation to the reactor coolant 13 pumps, what did you understand was the purpose of the 14 limits and precautions?
15 A
To provide guidance to the operator 16 relative to the performance of the reactor coolant 17 pump.
18 Q
Did those limits and precautions prescribe 19 shaft and frame vibration limits for the operation 20 of the reactor coolant pumps?
21 A
Yes, they would have.
22 Q
Did you have input as the manager of 23 pumps and drives as to what those limits and
)
24 precautions for the reactor coolant pump's shaft 25 and frame vibration would be?
1 Kennedy 34 m
)
2 A
Yes, I would.
3 Q
How would you make such determination as 4
to what those vibration limits would be that were
{
5 inserted into the limits and precautions?
6 401. BENEDICT:
How did he make them?
7 MR. MacDONALD:
Yes, prior to the time 8
of the accident.
9 A
Those limits were set in concert with the 10 supplier, vendor, with the B&W approval.
Those 11 limits are arrived at by extensive experience with 12 this kind of machinery, and they are set to ensure the
(")
\\/
13 serviceability of these pumps for the design life.
14 Q
Prior to the time of the TMI-2 accident, 15 did you ever make any recommendations to anyone at 16 B&W that those vibration limits for shaft and frame 17 be changed in any way?
18 A
I don't recall.
19 Q
Is it your understanding that the net 20 positive suction head curve for the reactor coolant that prescrihes the limits for the 21 pumps is a curve L
22 operation of those pumps?
23 A
Yes.
[v) 24 Q
As you unders tood it in 1977, was 25 operation at saturation in the reactor coolant system
1 Kennedy 35
(~
2 within the confines of the net positive suction head 3
curve.
t 4
A Net positive suction head curve is
(
5 developed on the basis of solid water conditions, per 6
the definition.
7 Q
so in other words, operating at 8
saturation is operating outside of that curve?
9 A
That is right.
10 Q
Based on your knowledge of(the Davis-Besse 11 September 24, 1977 transient and the fact that the 12 reactor coolant pumps during that transient were 13 operated in a saturated system, did you make any 14 recommendations to anyone at B&W or any of the 15 operating utilities regarding such operation as 16 being outside the net positive suction head curve?
17 A
No, I did not.
I believe there was no l
18 reason to.
19 Q
Why was that?
s 20 A
The charheterization of the actual 21 environment of that pump during that incident is not 22 well known.
23 Q
could you explain what you mean by that?
O(j 24 A
The percent of void fraction, the actual 25 environment that the pumps are, including the percent n
.c
-,--w
-*-y w <
7--
=r
- -'rsus-e
+++tt --- v
- me N
-*er+1y
=
w a-
7-
r Kehnedy i
36 i
,4 V
2 of void fraction,is not qugntified.
l 3
Q Did you attempt after the Davis-Besse 4
accident to look at data so that you would understand
(
5 what the void fraction was that the pumps were 6
operating under during the Davis-Besse transient?
7 A
No, I did not, and there was no reason 8
to.
The pump is not required to perform in such an 9
environment.
10 Q
But you knew that it did, isn't that 11 correct?
12 A
No, I did not know that it did.
.13 Q
You didn't know that the reactor coolant 14 pumps at Davis-Besse operated during that
)~
15 transient, at least for some period of time, in a 16 saturated system?
17 A
I know that the system was in saturation.
18 I do not know that the pumps operated in a saturated 19 co nditio n.
20 Q
You knew hat the pumps were operating 21 in a saturated system?
22 A
In a saturated system, that is right.
23 Q
Dtd you do any evaluation of the b) q 24 flows through those pumps during that transient?
25 A
No, I did not, and there was no reason to.
1 Kennedy 37 2
There was no requirement that the pump perform 3
in that situation.
4 Q
Regardless of whether there was any
(
5 requirement, did you do any evaluation or study of 6
that?
7 A
No, I did not.
8 MR. BENEDICT:
He answered in the negative.
9 Q
Prior to Davis-Besse, you had never had 10 any occasion to learn that a reactor cdolant pump 11 had operated in a saturated system in a B&W nuclear 12 reactor,- had you?
O 13 MR. BENEDICT:
I object to the form but 14 go ahead.
15 A
Would you repeat the question.
16 (Record read back.)
17 A
The answer is no.
18 Q
Did you ever ask anyone at Davis-Besse 19 or B&W or any individual for that matter wnat the 20 percentage of void fraction was at Davis-Besse during tha 21 September 24, 1977 transient?
22 A
No.
There was no reason to.
23 (Recess taken.)
24 BY MR. MacDONALD:
25 Q
As I understand it, you didn't attempt
1 Kennedy
'38 q
'l >
2 to ask anyone at Davis-Besse or evaluate the 3
data from the Davis-Besse transient of September 24, 4_
1977 to determine what the void fraction was during that
(
5 transient, is that correct?
6 A
That is right.
There was no reason to.
I 7
Q You weren't interestod in the void fraction 8
of the reactor coolant system?
9 A
The pumps aren't required to operate 10 in that environment.
11 Q
Whether or not the pumps are not 12 required to operate in that environment, if they do
)
N/
13 have to operate in that environment, that was of 14 no interest to you, is that correct?
15 MR. BENEDICT:
I object.
What does that 16 means "if they do"?
In what case did they have 17 to operate in a voided environment?-
18 MR. MacDONALD:
He already testified that 19 he knew that the system was saturated at 20-Davis-Besse and that the pumps operated for 21 some period of time when the system was saturated 22 and there was a two-phase mixture.
That is l
23 the basis of my question.
[)
24 MR. BENEDICT:
Let me hear the question
~-
25 again.
1 Kennedy 39
<x
(
l
%/
2 (Record read back.1 3
MR. BENEDICT:
I object to the form of the 4
question, but if you can understand it, you can
(
5 answer.
6 A
I at that point had no concern about 7
the operation in that environment.
8 Q
Do I understand you had no concern, no 9
matter what the void fraction was in the reactor coolant 10 system, for a reactor coolant pump operation?
11 A
Let me clarify my concern.
12 My concern is relative to the need for that 13 pump to operate in that environment.
There are 14 concerns relative to the mechanical performance of 15 the pump in that environment.
4 16 Q
When you say "the need for that pump to 17 operate in that environment," do you mean that 18 because of shaft and frame vibration limits that the i
19 pump would be shut down at some point in time before i-(
20 the system reached saturated conditions?
l 21 A
Again my concern is that, No.
1, the L
I 22 pumps aren!t required to operate in that environment, 23 but, secondly, the pumps are not designed for that
/"%
( )
24 environment.
Therefore, they can sustain damage, 25 and there is no conclusive proof with regard to the i
l'
-- - - - = -
1 Kennedy 40
=
2 extent of the damage that the pumps can sustain in that 3
environment.
4 Q
In a saturated environment in the reactor
(
5 coolant system?
6 A
Yes.
7 Q
Tell me what your understanding was 8-prior to the time of the TMI-2 accident as to what 9
could cause a frame and shaft vibration on a reactor 10 coolant pump.
(
11 A
Out of balance conditions on the rotating 12 system can cause shaft and frame vibrations; operating 13 below the NPSH requirements can cause shaft vibration; 14 and if there are mechanical failures of certain 15 components within the reactor coolant pump and motor, 16 that can result in shaft and frame vibration increases.
17 Q
What types of components are you speaking 18 of?
19 A
Bearings, for instance.
20 Q
Anything else?
21 A
The part of the rotating shaft that 22 interfaces with the bearings, the journal.
23 MR. MacDONALD:
I would like to mark as 24 GPU Exhibit 432 a copy of a memo, J.
D.
Dempsey 25 to J.
A.
Lauer, October 18, 1977.
It is a
i 1
Kennedy 41 2
seven-page exhibit.
3 (S e ven-p age exhibit, first page of which 4
is a memo to J.
A.
Lauer from J.
D.
- Dempsey,
(
5 dated October 18, 1977, marked GPU Exhibit 6
No. 432 for identification as of this date.)
7 Q
You are marked for a copy of this on the 8
firs t page.
9 Is this a copy of a memo you received 10 in or about mid-October 1977 in the refular course 11 of business?
12 A
No, I don't recall it.
O 13 Q
Is the handwriting on the second page 14 your handwriting?
15 A
No.
16 Q
Who is Mr. Dempsey?
Did he work for 17 you in pumps and drives at that time?
18 A
Yes, he did.
19 Q
It says on the second page of this 20 exhibit opposite the time 6:00, " Steam formation, 21 pressure oscillation near PSAT for approximately 30 22 to 45 min."
23 Do you see that?
(
24 A
Yes.
25 Q
Is that something you knew about that transieat
1 3
Kennedy 42
- A
(~-)
2
.during the time you were performing your evaluation.
3 MR. 3ENEDICT:
If you recall.
4 MR. MACDONALD: Everything is to his
(
5 recollection.
6 MR. BENEDICT:
I know, but this memo he 7
already testified he doesn't recall.
8 I am not going to quibble with you as 9
to whether you are interpreting something 10 in here today.
Merely because hd. reads it here, 11 he shouldn't feel obliged to indicate that 12 that is something he knows.
All you care about 13 is what is in his mind.
14 MR. MacDONALD:
That is always what we are 15 here for in a deposition.
16 MR. BENEDICT:
That is what we try for 17 at least.
~
18 A
I recall the system did in fact go to 19 saturated conditions.
20 Q
Did you know that it stayed at or around 21 saturation for approximately 30 to 45 minutes during 22 that transient?
23 A
I don't remember the time.
(
24 Q
Did you consider it important at the time 25 as to how long the system stayed'at or near saturated
1 Kennedy 43 2
es 2
conditions?
3 A
In the context of potential damage to the 4
pump, that would be important.
(
5 Q
It was your conclusion based on your 6
evaluation of that transient there was no permanent 7
damage to the pump during the Davis-Besse event?
8 A
The conclusions were that there was the 9
potential for localized cavitation damage in the 10 impeller veins, but there was no apparent significant-11 damage that would reflect on the serviceability of the 12 pump.
13 Q
After the Davis-Besse event, did you 14 attempt to do any further evaluations regarding 15 the effect on reactor coolant pumps of saturation 16 in the reactor coolant system, all of this prior to 17 the time of the TMI-2 accident?
t 18 MR. BENEDICT:
By "you" I take it you mean i
19 Mr. Kennedy?
20 MR. MacDONALD:
Or his unit.
21 A
The answer is no.
There was no reason to C
22 perform such an evaluation, because it is not a 23 requirement of the pump that it operate in such an 7
24 environment.
(_/
25 Q
Do you know whether or not anybody else t
.. ~.
1 Kennedy 44
/~N
~
U 2
at B&W performed such evaluations?
3 A
I do not.
4 Q
Did you.tell any oth'ir'~ utilities or
(
5 utility personnel after the Davis-Besse event that 6
the reactor coolant pumps
't Davis-Besse had operated a
A 7
for approximately 30 to 45 minutes in a saturated 8
system?
9 A
The question is did I personally tell?
10 Q
You or any member of your u' nit.
4 11 A
No.
There was no reason that I should 12 tell them.
i
~
13 Q
On that second page of GPU. Exhibit 432, 14 down at the bottom under " Pump 2-2,"
it says, "4:20, 15 High vibration."
16 Do you recall knowing that there was 17 high vibration in regard to reactor coolant pumps at 18 Davis-Besse?
19 A
No, I do not.
l 20 Q
Did you inquire as to whether there was 21 high vibration?
L l
22 A
I don't specifically recall.
23 Q
Based on your knowledge and expertise I
(
24 in relation to reactor coolant pumps, is that something i
25 at that point in time that you would have been concerned i
l
(
1 Kennedy 45 7~\\
U-2 about?
3 MR. BENEDICT:
Could I hear that again?
4 MR. MacDONALD:
Based on his knowledge
(
5 and expertise as unit manager of pumps and
'6 drives, in reactor coolant pumps, is that 7
something at that point in time that he would 8
have been concerned about in evaluating that 9
transient, namely, high vibration?
10 MR. BENEDICT:
We have been,taking 11 depositions in this case, and neither side has 12 allowed the other to ask a witness what might i
'/
13 have been in his mind at that time, even if it 14 is based on his expertise at the time.
15 Both sides have limited their testimony 16 and have been limited in the taking of their i
17 testimony to the recollection someone has as to 18 what actually occurred, and I think that is 19 an appropriate limitation to have here.
20 We discussed earlier what variables one 21 would look into in a general sense when 22 considering' pumps.
I allowed you TS *go
- int ~o 23 that.
I don't think with respect to a document
-,x f
\\
24 or a specific transient you are entitled to ask N_/
25 for his speculation or what was or could have
1 Kennedy 46 2
been important to him whether or not it is 3
based on his years of experience, so if you can 4
reformulate the question, I would love it.
(
5 If not,we are going to come to heads on it.
6 MR. MacDONALD:
The question is quite simple.
7 BY MR. MacDONALD:
8 Q
In evaluating a transient such as the 9
one in Davis-Besse in 1977, based on your understanding 10 of reactor coolant pump operation, wasSt something 11 to be concerned about as to the vibration of those 12 pumps?
I
(_/
13 MR. BENEDICT:
With respect to the 14 general question that we talked about earlier 15 this morning, I didn't have an objection.
16 When we are talking of a specific instance, 17 I think it is improper, because you. are I
18 attempting to make an implication that since 19 today he thinks it might have been important 20 then, then in fact he did it.
21 If you want to ask him whether he looked L
22 at it, that is fine, but I don't think you are 23 entitled to ask him what he thinks might have m\\
[%.).
24 been important to him if he can put his mind 25 five years back..
..-. -.- -= -
l 1
Kennedy 47 s
1 w
2 MR. MacDONALD:
In 1977 or 1978 about 3
the time he was evaluating this transient, was 4
vibration on the reactor coolant pumps and
({
5 he is supposedly the most knowledgeable person 6
at B&W abo ut the operations-something he would 7
he concerned about in evaluating the Davis-Besse 8
9 MR. BENEDICT:
To the extent that 10 question hasn't been asked and answered, I 11 instruct him not to answer.
You asked the 12 question that you just asked except for the 13 amendment of "such as the incident at 14 Davis-Besse."
15 I don't think he is required now to 16 narrow it down and look at a document he I
17 doesn't remember now.
18 MR. MacDONALD:
I am not asking him to 19 look at a document.
It has to do with whether 20 or not vibration of shaft and frame would be 21 of concern to him when he evaluated reactor 22 coolant pump operation in a situation such as 23 Davis-Besse.
(( )
24 MR. BENEDICT:
If we can go on, I will 25 let him answer; but, Mr. Kennedy, limit your
1 Kennedy 48 5
i
.V-2 answer to what you recall was your concern 3
during that time frame in the analysis of 4
reactor coolant pump incidents.
. (
5 You don't have to speculate on what 6
you now know and plug it back in.
7 MR. MacDONALD:
I am not asking him to 8
speculate.
9 MR. BENEDICT:
I agree.
10 To the extent you are not dsking for 11 speculation, then he may answer the question.
12 A
One of the symptoms of a pump operating in 13 such an environment is an increase in the shaft and 14 frame' vibration.
15 Q
So in other words, you are saying that J
16 based on your understanding at that time it would 17 have been a concern to you?
18 MR. BENEDICT:
I object to your 19 characterization, but just ask another ques tion.
20 MR. MacDONALD:
That is my question.
i 21 MR. BENEDICT:
I object.
m 22 MR. MacDONALD:
I said based on his 23 understanding.
He can tell me if it is not 24 his understanding.
25 MR. BENEDICT:
Fine.
i, J
4 j
j 1-Kennedy 49 2
Answer the question.
J t
}
3 (Record read back.)
i 4
MR, BENEDICT:
You may answer in whatever j
(
5 words you want.
6 A
Based on the well-known postulation 7
that one of the symptoms of operating in a saturated i
j 8
environment is an increase in the mechanical vibration 9
of the shaft, I would say that, yes, that would have 10 been a concern.
11 Q
Did you attempt to look at-the limits 12 and precautions in effect, specifically for the
(\\
\\~/
13 Davis-Besse plant during your evaluation of that i
14 September 1977 transient?
4 15 A
I don't recall.
3 i
16 Q
Were the limits and precautions regarding 17 reactor coolant pump operation standardized to l
18 such an extent that knowing what the limits were,as l
19 to in gene ral,would mean you would know what they 20 were for Davis-Besse specifically?
I 21 A
Limits and precautions vary from plant 22 to plant because in this particular case, the pumps 23 are supplied by a number of different suppliers.
24 They have their own characteristics, so there is no i-25 certainty that vibration limits for Davis-Besse
}
r
. _. ~
1 Kennedy 50 r~s U
2 would be like another plant that you may pick.
3 I should say that there would have been 4
no reason to explore what is in the limits and
([
5 precautions pertaining to that incident, because 6
that particular operating environment is not a part 7
of the design requirements for the pump, nor are 8
they a part of the licensing requirements for the pump.
9 MR. MacDONALD:
I move to strike that.
10 It is not responsive to the quesdion.
11 MR. BENEDICT:
It is in the question.
12 We can argue over it later.
(~N 13 Q
Did you attempt to evaluate or correlate 14 the data that you obtained from your evaluation of the 15 Davis-Besse transient with any other pump data that 16 you had prior to that time regarding the operation 17 of the reactor coolant pumps?
18 MR. BENEDICT:
You mean regarding actual 19 field experience?
20 MR. MacDONALD:
Let's start with field 21 experience, and I will go to 22 MR. SENEDICT:
That is all right.
23 A
I don't know.
)
24 Q
Did you attempt to correlate it with l
25 any data that you may have had from tests on various
?
I
1 Kennedy 51
(~'$
V 2
models of reactor coolant pumps that were not field 3
data?
4 A
I don't remember that either.
(
5 Q
Did you talk to anybody after the 6
Davis-Besse transient-regarding the effects of 7
running the reactor coolant pumps when the system is 8
in a saturated state?
9 MR. BENEDICT:
Up until the day of the 10 accident or up until today?
11 MR. MacDONALD:
Up to the day of the 12 TMI-2 accident.
(
s 13 A
I don't recall such a conversation.
14 Q
Communication of any form is what I meant.
15 A
I understand.
I 16 Q
Your answer would be the same?
i 17 A
Yes.
l 18 Q
Did you speak to anyone after the
[
l 19 Davis-Besse transient and prior to the TMI-2 transient f
20 regarding whether or not the pumps should be run or 21 should be stopped when they are called upon to i
22 operate in a saturated environment? And by "you,"
23 I mean you or anyone within your pumps and drive unit.
(
24 A
I don't remember any such communication.
l 25 Q
Do you know whether or not B&W ever I
l l
l l -
1 Kennedy 52 0
2 communicated with Davis-Besse after the September 3
1977 transient regarding whether to maintain reactor 4
coolant pumps in operation or to shut them down whe
(
5 the RCS system was in saturated condition?
6 A
I don't know whether such communication was 7
made.
8 Q
You didn't have any yourself?
9 A
I did not.
10 Q
Or any members of your unit,that you know 11 of?
12 A
No.
O 13 (whereupon, at 12:35 o' clock p.m.
a lunch 14 recess was taken.)
15 16 17 18 1
19 20 21 L
22 23 24 25 I
1 53 2
AFTERNOON SESSION 3
(1:35 p.m.)
4 ROBERT K.
KENNE D Y, resumed.
(
5 EXAMINATION (Continued) 6 BY MR. MacDONALD:
7 Q
You are aware that your tes timony here 8
this afternoon continues under oath, are you not?
9 A
Yes.
10 Q
At any time after the Davis-Besse transient 11 of September 1977 and prior to the TMI-2 accident, 12 7-did you or anyone that you know of within your unit NY 13 give any consideration to running tests on full size 14 reactor coolant pumps to determine the effects of void 15 fractions on the _ operation of thos e pumps 7 16 A
The answer to that is no, we did not, 17 because there was no requirement that that pump operate 18 in that environment.
19 Q
The fact of the matter is, though, that 20 the pumps at Davis-Besse during that transient 21 operated in an RCS that was saturated for some period L-22 of time, is that not true?
23 A
Yes, I agree that is true.
)
24 MR. MacDONALD:
Let me mark a document 25 as GPU Exhibit 433, a two-page document entitled
1 Kennedy 54 s
)
2
" Mixed Flow Test RC Pumps," and also has on the top, " Lead Section Manager:
L.
J.
Stanek."
3 4
(Documen t entitled " Mixed Flow Test RC 5
Pumps," " Lead Section Manager:
L.
J.
Stanek,"
6 marked GPU Exhibit No. 433 for identification 7
as of this date.)
g Q
Have you seen a copy of this document before?
9 A
I don't recall.
10 Q
It has down under No.
5,
" Responsibility, 11 RK Kennedy, Unit Manager."
12 Did you participate in mixed flow tests s/
13 on reactor coolant pumps at some point in time during 14 your employment at Babcock & Wilcox?
15 A
No, I did not.
16 Q
Did you participate in any way with 17 a review or analysis to " Prove the capab'ility of the 18 reactor coolant pumps to operate within emergency 19 limits under mixed flow conditions"?
i 20 A
Ho, I did not.
21 Q
Do you know whether Mr. Anderson or Mr.
22 Bateman ever did?
23 A
It is my recollection that nobody in B&W
[ ')
24 has participated in such a test.
i
\\_/
25 Q
Was this considered at one point in time l
L
1 Kennedy 55
.,~,
2 by individuals at B&W7 3
A To my knowledge, no.
4 Q
You never had any discussions with
({
5 Mr. Stanek regarding this particular issue?
6 A
I don't recall such discussion.
7 Q
Or with anyone else at B&W7 8
A Right.
j 9
Q Did you ever hear anyone express any 10 interest in performing such a project dt any point 11 in time during your employment at B&W?
12 A
Yes, I have.
/~%
13 Q
When was that?
I 14 A
It was in connection with a proposal by.
15 B&W to assist and consult with EG&G in Idaho l
16 relative to performance of such a test under the 17 sponsorship of the NRC.
18 Q
When was that in terms o f. time ?
i 19 A
That was after TMI.
20 Q
Did you ever hear anybody express any 21 interest regarding the subject at B&W prior to the
[
22 time of the TMI-2 accident?
23 A
Prior to the time, no.
)
i 24 Q
Did you yourself have any interest in 25 performing such evaluations prior to the time of the i
l
1 1
Kennedy 56 Ov 4
2 TMI-2 accident?
3 A
Not prior to the time o f the TMI-2 accident.
4 MR. MacDONALD:
I would like to mark as
([
5 GPU Exhibit 434 a document whose first"page is a 6
letter from Edward E.
Chipman to T.
Fernandez 7
dated July 3,
1979.
8 (Seven-page document, the fi$st page of i
9 which a letter to T. ; Fe'ritande z from Edward E.
c'
.f 10 Chipman, dated July 3,
1979, marked GPU
~
11 Exhibit,No. 434 for identification as of this 12 date.)
(~h
\\l 13 Q
is this a copy of a document you received 14 in or about early July 19797 15 A
I don't remember whether I received it 4
16 or not.
17 Q
You are marked for a carbon copy down at 18 the bottom, are you not?
19 A
yes.
20 g
Do you recall this proposal?
21 A
I rec'all that there was a proposal made s
22 to EGGG.
I'-don't recall the proposal to EPRI.
23 Q
What was the purpose of it or the reason 24 behind, as you understood it, the proposal to EG&G7 25 A
At that point in time after TMI-2, it was
-1 Kennedy 57
)
\\m/.
2
' recognized, I think, by the industry, including B&W, 3
that reactor coolant pumps may be useful in such an 4
incident.
([
5 Q
You say "such an incident."
6 You mean a loss of coolant accident?
7 A
Yes.
8 Q
Small break loss of coolant accident?
9 A
Right.
10 Recognizing that sa feguard ' systems exist
~
11 in the plant which are designed per the licensing 12 requirements to provide adequate core cooling in such' l}
/
13 an event, the thinking was that reactor coolant 14 pumps are an asset and perhaps can be useful.
15 Q
Was -any work ever performed by EG&G resulting 4
16 in a proposal?
[.
s 17 A
There was a proposal made to the NRC
+
18 which B&W had a part in.
The proposal was not accepted.
19 The proposal to actually do the work was not accepted.
20 The proposal to do a feasibility study was, however, 21 accep ted.
I 22 Q
What were the results of that?
23 A
The feasibility study suggested that the t
[~h 5
j 24 test could be done on the Bingham test loop in Portland.
l.
x..s 25 Q
But to date you do not know that that t
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, Kennedy 58 v
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2 tedt has been performed?
s, 3
A The fest has not' been performed.
e s
s 4
Q It is a fact, is it not, that after the
. ('
' 5 TMI-2 accident B&W informed its' nuclear customers i
6 of changes. in operation for i ts. reactor o
coolant pumps 7
as opposed to procedures that had been in.e f fect
' \\,
s 8
prior to the time of the accident?
h 9
A Would you clarify're15tive to specific
,_a t
s 10 concerns?
11
. Q You were aware after TMI-2 that a procedure is 12 was ~sent out'by B&W which called for.the continuous
(~h
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13 operation.of the reactor ceblant pumps if the HPI
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T 4
14 system'.had been activated?
(-
15 MR. BENEDICT:
"Had been activated"?
-e s s
16 MR. MacDONALD:
Yes.
i 17 A
No, I don't resall such.
18 Q
I show you a copy of GPU Exhibit 85 which 19 has been previously marked.'
20 Have you seen a cop'y o f th is memo before?
.. g L
21 A
I don't recall.
{
22 Q
Have you seen $' copy o f this instruction 23
'~to B&W operating plants he'for2?
g
(
, 24 A
I don't recall.
or
\\ 251 Q
Do you recall whether yo~u were consulted 4
'r '
g
'.c,y-.
1 Kennedy 59
-(q) v-2 in relation to this particular instruction?
3 A
No, I don't.
4 Q
The last two lines read, "If the HPI system
([
5 has been activated and if RC. pumps are in. operation, 6
at least one RCP pump per loop shall be maintained."
7 Do you see that sentence?
8 A
Yes.
9 Q
Is it your understanding that these were 10
-the instructions that B&W sent out to 1,t s 11 operating utilities shortly after the TMI-2 accident 12 in March 1979?
I\\'
13 A
I don't know that to be the case.
14 Q
Did you know that there were instructions 15 sent out af ter the accident which in substance reflected 16 that in small breaks or loss of coolant accidents or 17 where you had HPI activated, if the RC pumps were in 18 operation that one should be maintained per loop?
19 MR. BENEDICT:
Could I hear it again?
i' 20 Q
Had you heard that after the TMI-2 accident 21 that B&W had sent instructions to its operating 22 utilities which stated in substance that once HPI had 23 been activated and if the RC pumps were in operation, f
f 24 that one pump per loop should be maintained?
(-
25 A
In the context that the industry recognized I
.,n
---,-.,-----,,....,n.v, a
1 Kennedy 60
(~5 i
)
% /.
2 that the pumps may be useful during such an event, 3
and this is beyond any licensing requirements, I am 4
saying that the need for these pumps to operate
((
5 per Met Ed's license did not include operation in 6
such an event.
7 In that context, it is reasonable for me 8
to believe that such a recommendation may have gone 9
out.
10 MR. MacDONALD:
I will strike that.
11 Q
I an asking you whether you were aware 12 that such recommendation went out.
That is all.
{'l g
A-13 A
I don't recall.
14 MR. BENEDICT:
That was pretty much asked 15 and answered before, but let's go on.
16 MR. MacDONALD:
It wasn't asked.
17 Q
In other words, you don't recall being 18 consulted in any way regarding an instruction such as 19 the one in GPU Exhibit 85?
l 20 A
I don't recall one way or the other whether 21 I was or not.
22 MR. BENEDICT:
This deposition has been i
23 somewhat pu=zling to me.
Your 30 (b) (6) notice 24 for this deposition indicated that you wanted 25 somebody to discuss the ability of the reactor
1 Kennedy 61 2
coolant pumps to operate effectively in voided 3
conditions in the reactor coolant system.
4 I understood that to mean that you wanted
(
5 somebody who could talk to the rotodynamic 6
and hydraulic characteristics of the pump in 7
such a condition.
That is Mr. Kennedy's 8
field.
9 To the extent that Mr. Kennedy was 10 involved in these events, I have'no objection i
11 to your going over them with him; but I want 12 you to recognize that neither B&li nor 13 Davis Polk intends to assert Mr.. Kennedy is the 1
14 expert on everything that ever happened with 15 respect to reactor coolant pumps.
16 We are presenting Mr. Kennedy as an engineer 17 who is knowledgeable about the rotodynamic and 18 hydraulic chara ct e ris ti cs of the pump.
To the 19 extent he was involved in these things, fine, he 20 was a player in them.
He is not the only person 21 at B&W who knows about these subjects.
I would hope that he is not 23 the only person at B&W knowledgeable about those
(
24 subjects.
25 MR. BENEDICT:
I wanted to set forth the
1 Kennedy 62 h
i -Q.
2 fact that to the extent you feel we read-your 3
30 (b) (6) notice to provide you with someone 4
who knows everything there is to know about
({ -
5 the reactor coolant pumps, including the history 6
and the emergency core cooling aspects of forced 7
flow, Mr. Kennedy is not that person and there 8
is no one person who knows all that.
9 Mr. Kennedy is being provided as someone 10 who is knowledgeable on the subjdet of the s
11 mechanistics and hydraulic cha.racteristics of 12 the pump.
s 13 MR. MacDONALD:
According o 30 (b) (6),
14 I would assume as we had testinony to earlier 15 that he is the person most knowledgeable e
16 about the operation of the reactor coolant pumps 17 in voided conditions and that basically is what 18 the course of this deposition has talked about, 19 reactor coolant pumps in voided conditions.
20 MR. BENEDICT:
I do not 21 MR. MacDONALD:
Obviously that i s what we 4
L 22 have been speaking about.
23 MR. BENEDICT:
I am not quarreling about
(
24 the propriety of the questions.
I am only i
25 observing on the fact that Mr. Kennedy's w
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1 Kennedy 63
~
2 presentation here as a 3G Lbl L61 witness rev lved ar und his choice as an individual at 3
4 B&W who was knowledgeable about the h.ydraulic 5
and mechanistic aspects of reactor coolant
(
6 pump operation including, to the extent there is 7
any knowledge on the subject, what the theoretical g
effects are in saturated conditions.
9 To the extent Mr. Kennedy is involved in 10 issues relevant to this case, I have no 11 objection to your inquiring into them but I want j
12 to set forth that B&W and Davis Polk did not
(-
13 seek-to find one person who knows everything 14 there is to know about pumps because we don't 15 think that person exists.
4 16 MR. MacDONALD:
I don't think we asked 17 for that.
18 MR. BENEDICT:
I told you the way we were 19 able to interpret your notice and having 20 recognized that we have to find a single person 21 to put forth that Mr. Kennedy's strong suit is 22 what I have articulated, rotodynamic and hydraulic 23 effects.
(
24 To the extent he was involved in issues r
25 or occurrences that are relevant to the lawsuit,
1 Kennedy 64 f
.s 1
~#~
2 you are welcome to inquire into them, but to 3
the extent you believe that what you have gotten 4
is the B&W historian on all events and
(
5 occurrences relating to pump operation, even 6
pump operation in voided conditions, you don't 7
have that person because I doubt if any one person 8
possesses all that knowledge.
9 MR. MacDONALD:
I never thought that any 10 one person possesses all the knowledge there is 11 about any one subject, only that Mr. Kennedy is G
12 the most knowledgeable person on those particular
(~h k/
13 subjects, as Mr. Hallman was the mos t knowledgeable 14 person on operating plant experience.
15 MR. BENEDICT:
To the extent we were able 16 to find one person who know enough about one 17 subject, we found Mr. Kennedy, because we 18 believed your interes t here was mechanistic and 19 hydraulic.
-20 I assume you weren't interested in 21 emergency core cooling.
22 These instructions, as you well know, 23 relate to more issues than the hydraulics of the
(
24 pumps.
25 I am only saying that maybe you need
1 Kennedy 65
~
2 another person on some of your ques tions.
3 I just want to set forth clearly what 4
Mr. Kennedy is here for.
I am not objecting --
(
5 MR. MacDONALD:
I think you have done that 6
clearly.
7 MR. BENEDICT:
I am not objecting to your 8
questions.
I am just making an observation.
9 (Re co rd read back.)
10 BY MR. MacDONALD:
1 11 Q
So you don't recall that you were consulted 12 as to whether or not the pumps were capable themselves
(~)
\\_/
13 of operating in such an environment as a saturated 14 environment within the reactor coolant system?
15 A
I don't believe anybody can say that the 16 pumps can in fact operate in a saturated environment.
i 17 I don't think that technology is known,but I don't 18 recall whether I was consulted or not.
19 Q
Do you know if anybody in your' unit 20 was consulted regarding the instructions in GPU 21 Exhibit 85?
22 A
No, I do not.
23 Q
You were aware prior to the TMI-2 I}
24 accident, were you not, that there were vibration limits N_/
25 for pump operation in the B&W limits and precautions,
t
1 Kennedy 66 O.
2 were you not?
3
.A Yes.
4 Q
After the Davis-Besse event, did you
(
5 attempt to do any evaluation or investigation of 6
what effects different void fractions would have on 7
reactor coolant pump operation as it pertained 8
to those vibration limits?
9 A
No, there was no need to because it was 10 not a design environment.
11 Q
Do you know whether anybody else did?
12 A
No, I don't know.
\\-
13 Q
You don't know that anybody else did, 14 to your knowledge?
15 A
To my knowledge, I don't know.
16 Q
Do you know that after the TMI-2 accident, 17 the shaft and frame vibration limits in the B&W limits 18 and precautions were changed?
19 A
Yes.
20 Q
Did you have any input into that change?
21 A
Yes, I was involved in that change.
22 Q
How were you involved?
23 A
In developing the recommendation.
24 Q
Was it pursuant to a request f rom some 25 individual or group of people that you developed a
-~.
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n
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J 1
Kennedy 67 2
recommendation?
2 3
A In the context of B&W providing advice and 4
consultation to TMI-2 in managing the situation after
(
5 the transient, we provided these recommendations.
6 Q
When you say "these," you mean changes in 7
shaft and frame vibration?
8 A
Yes.
9 Q
Did anyone else in your unit work on 10 those changes?
11 A
Yes.
12 Q
Who specifically?
("N 4
\\-
13 A
John Dempsey.
14 Q
Anyone else?
15 A
I don't recall specifically.
16 Q
Were these changes specifically for TM[-2 17 ~
or were there also other changes in the B&W limits I
18 and precautions regarding shaft and frame vibrations L
19 that were sent to all customers after the TMI-2 20 accident?
21 A
I don't know.
22 Q
Were you involved in any way in making 23 changes to the B&W limits and precautions regarding i
24 shaft and frame vibrations for the purpose of sending 1
l 25 those to B&W operating plants?
-~,-_,._ _..
1 Kennedy 68 y
V-2 MR. BENEDICT:
I want to object.
3 Several times, both this morning and this 4
afternoon, you used the expression "B&W limits
((
5 and precautions."
6 I don't know of any such thing as 7
B&W limits and precautions.
8 I assume what you mean by that is-9 whatever recommendations or instructions were 10 sent along with the operation of>,the pumps?
11 Is that what we are talking about?
12 MR. MacDONALD:
We are talking about GPU
/~'
\\'
13 Exhibit 349 which is labeled "Te chn ical Do cumen t, "
i I
14 this type of document.
15 g
what recommendations did you generate 16 with regard to the changes in shaft and frame vibrations 17 for TMI-2 after the accident?
18 A
Re co mmenda tio ns include what. you already 19 alluded to, that is, shaft and frame vibration changes.
20 Q
Were they changes to increase the shaft 21 and frame vibration limits?
(.
22 A
Yes, the changes were made to increase.
23 only in an emergency situation.
' ()
24 As I mentioned before, the limits are set 25 based on the operating experience and production test
1 Kennedy 69
'(Q V.
2 loop experience, and those limits are set with the 3
view in mind that the pump will in fact operate fo r 4
the designed life of the plant, so there is margin
({
5 inherently in those limits; and engineers experienced 6
in this discipline will, I think, vouch for that.
7 Q
It was your understanding prior to the 8
TMI-2 accident that if those limits were exceeded 9
that the pumps were required to be shut down, the shaft 10 and frame vibration.
11 It was your unders tanding prior to the 12 TMI-2 accident that if the prescribed limits in the 13 B&W limits and precautions for shaft and frame 14 vibration were exceeded, that the requirement was 15 that the pumps be shut down?
16 A
Yes.
17 Q
I show you a copy of GPU Exhibit 116 l
18 which was previously marked, a memo from hert Dunn to 19 E.
R.
Kane dated May 29, 1979.
20 Have you ever seen a copy of this document 21 before?
22 A
No.
23 Q
I direct your attention to the second
(
24 page.
The second sentence reads, "As an overriding 25 concern, I pointed out there is no intention within
~
- ~.
1 Kennedy 70
(~V) 2 the operating guidelines to cause an RC trip during 3
the transient, and that this is true regardless of
~
4 pump performance variables.
In other words, I restated
((
5 our position that at leas t one pump per loop will run 6
until it dies.
I confirmed that my experience with 7
RC pumps running in high void systems has shown no 8
problems with their performance and that our pump 9
experts indicate no concern in pumping a two-phase 10 fluid."
11 Did you ever have any conversations with 12 Mr. Dunn after the time of the TMI-2 accident?
n/
N-13 A
I don't recall.
14 Q
Regarding this particular subject?
15 A
No, I don't recall.
16 Q
Did you ever have any conversations 17 with Mr. Dunn or any of his ECCS people, either before 18 or after the accident, regarding this particular 19 portion of the paragraph I read?
20 A
I don't recall such a conversation.
21 Q
Do you know whether or not Mr. Dunn ever 22 spoke to anyone in your unit regarding this subject?
23 A
I don't know one way or the other.
[')
24 Q
Do you have any idea who Mr. Dunn' is v
25 referencing when he references pump experts?
F o
. _., _ - ~,,,, _ _ _ - - - -. _ _
't 1
Kennedy 71
. O)
L 2
MR. BENEDICT:
I object.
He never saw 3
this document before.
If you want to ask him 4
who the pump experts were at that time, who he
({ '
5 considered expert in the operation of pumps, fine, 6
but let's not do this.
7 MR. MacDONALD:
Your instruction is for 8
him not to answer?
9 MR. BENEDICT:
Absolutely.
10 Q
Aside from yourself, who ssW designated 11 the most knowledgeable person within the company 1
12 regarding RC pump operation in voided conditions 13 in the reactor coolant system --
14 MR. BENEDICT:
Within the confines of 15 what I spoke earlier?
16 MR. MacDONALD:
Within the confines of what 17 that position is all about.
18 Q
-- is there anyone else in B&%1 in or 19 around May 1979 that you know of that would have 20 your knowledge or experience regarding that subject?
21 MR. BENEDICT:
I object until I understand 22 what you mean by "your knowledge and experience."
23 How is the witness -- if you can answer 24 that question, go ahead.
25 I think that is totally unintelligible.
1 Kennedy 72 cm v:
2 A
I don't think I know.
3 Q
Do you know whether or not, at or around 4
the time of the TMI-2 accident, whether there is anybody
(
5 else within B&W with your background and experience 6
in reactor coolant pump operation in voided conditions 7
in the reactor coolant' system?
8 MR. BENEDICT:
I object to the form, 9
but go ahead.
10 A
Could you repeat that?
11 Q
At or about the time of the TMI-2 12 accident, do you know of anyone else within B&W O-13 who had your background and experience _with respect 14 to reactor coolant pumps and their operation within 15 a voided reactor coolant system?
16 MR. BENEDICT:
I object to the form, but i
17 you may answer.
18 A
I don't recall.
19 Q
You don't recall knowing of anyone?
20 A
Right.
21 Q
Did you ever speak to Bert Dunn after 22 the TMI-2 accident?
23 MR. BENEDICT:
Up to today you mean?
24 MR. MacDONALD:
Yes.
t 25 A
Yes, I have talked to Bert Dunn.
1 Kennedy 73
(^h
^
LJ 2
Q Have you talked to him about business 3
matters relating to B&W business in the nuclear steam 4
supply system area?
({
5 A
I don't remember specifically.
6 Q
Do you remember any conversations with 7
Mr. Dunn after the time of the TMI-2 accident that 8
related to reactor coolant pump operation?
9 A
No, I don't remember.
10 Q
Were you aware prior to the. time of the 11 TMI-2 accident of any analyses that were performed 12 at B&W that related to the continuous operation O\\Y 13 of reactor coolant pumps?
14 MR. BENEDICT:
Continuous operation of 15 reactor coolant pumps?
16 MR. MacDONALD:
In a-transient situation.
17 A
There were some B&W test p ro grams 18 sponsored by EPRI which were conducted relative to the 19 performance of a model of the reactor coolant pump 20 in a solid phase and a two-phase environment.
21 Q
When were those tests performed?
L 22 A
My estimate is somewhere in the time 23 frame between 1975 and 1977.
(
24 Q
B&W contracted with EPRI for those tests 25 to be run?
-l Kennedy 74 V
2 A
Yes, it did.
3 Q
Were you involved at all in that testing
-4 procedure or evaluation of the results?
({ _
5 A
I don't recall specifically.
6 Q
Do you recall generally?
7
'A No.
8 Q
Aside from that were you aware of any 9
other evaluations that have been performed by or for 10 B&W regarding the continuous operation of 6
11 reactor coolant pumps in transient conditions?
12 A
No, I am not aware o f any such analysis.
fh a
A/
13 Q
I take it you are not aware o f any analysis 14 performed by B&W prior to the time of the TMI-2' 15 accident relating to the ability of the reactor 4
16 coolant pumps to e f fectively cool the core if operated l
17 continuously during a transient, specifically, a loss 18 of coolant accident?
19 A
-No, I am not aware of any such analysis.
20 Q
Did either you or' your unit have any input 21 into the formulation of the small break operating
}
22 guidelines, specifically, reactor coolant pump operation I
23 section of those guidelines?
(
24 A
I don't recall.
25 Q
I show you a copy of GPU Exhibit 108 l
I 1
Kennedy 75 2
previously marked, a memorandum from Don Hallman to 3
K.
R.
Ellison, May 7, 1979, subject:
" Operating 4
Guidelines for Small Breaks."
.((
5 Have you ever seen this document before?
6 A
I don't remember.
7 Q
I direct your attention to part 2 which 8
is on Bates numbered page D733 entitled " Operating 9
Cuidelines for Small Break."
10 would you take a moment o r 's o to look at 11 that section?
12 MR. BENEDICT:
All of part 27 w/
13 MR. MacDONALD:
Yes.
I am not going to-14 reference the whole thing.
I want him to look 15 at it.
16 I will ask him if he has ever seen those 17 guidelines before.
18 MR. BENEDICT:
O.K.
Go ahead and do that, 19 but I think we will get f arther if you do it more 20 precisely.
We are talking of ten pages here.
21 Q
My specific question is:
(.
4 22 As a group have you seen this set of 23 guidelines any time prior to today?
[}
24 A
I don't remember whether I have or not.
%/
25 Q
Would you look at page 3 of the guidelines
I 1
Kennedy 76 h(~h.
2 under 4.2.
It says, " Actions with feedwater
^
3 available to one or both generators.
4.21, Maintain 4
1 RC': running per loop."
({
5 Do you know whether or not you ever 6
consulted or participated in tha formulation of 7
that particular guideline?
8 A
I don't remember.
9 Q
Was anyone in your group consulted?
10 A
I don't know.
t 11 Q
On page 9 of the guidelines, "4.3, Actions 12 if feedwater is not available.
4.32, If RCPs are i
ss' 13 operating, go to one pump per loop.
If R' cps are not 14 available, go to step 4.3.6 below."
15 Did you participate or were you in any 16 way involved or consulted in the formulation of that
~
i 17 guideline?
18 A
I don't know whether I was or not.
19 Q
Do you know a gentleman by the name of 20 Joe Cudlin?
21 A
Yes, I do.
22 Q
Who is he?
4 23 A
He is a unit manager at B&W in the
)
24 engineering department.
25 Q
Do you know what unit?
1 Kennedy 77 2
A I don't recall the name of the unit.
3 Q
What in substance does the unit do?
4 A
It is to develop methods.
5 Q
Is it within your section or some 6
other section of --
7 A
It is in plant engineering.
8 Q
cid that used to be plant design?
9 A
Yes.
10 Q
Have you ac any time ever spoken either 11 prior or after the accident to Mr. Cudlin regarding 12 his knowledge about reactor coolant pump operation 13 in a two-phase state?
14 A
I spoke to him in preparation for this 15 trip in the context of obtaining a report that he was 16 involved in.
L'7-MR. BENEDICT:
That was at ny, request, J
18 and I will consider the conversation work product 19 because we were preparing for this deposition 20 and it was done at my direction.
21 Other than that direction, he may talk
. l 22 about whatever he talked about with Joe Cudlin j
23 but not that.
24 Q
What is your understanding of Joe 25 Cudlin's knowledge regarding the operation o f
. ~
4 1
Kennedy 78 v
2 reactor coolant pumps in a two-phase mixture or in a 3
reactor coolant system in a saturated state?
4 MR. BENEDICT:
I am not sure how that
((
5 question can be answered by bifurcating his 6
knowledge, but exclude what you learned from 7
Mr. Cudlin in conversations that were held at 8
my request, to the extent that you know other 9
things about what he knows or does.
10 Q
Before you answer that, have you 11 spoken to Mr. Cudlin before this conversation you 12 just related at any point in time?
A 13 A
I don't remember such a conversation.
14 MR. BENEDICT:
Did you mean to limit it 15 to a conversation about his knowledge?
16 You just mean ever about any subject?
17 MR. MacDONALD:
Yes.
18 MR. BENEDICT:
Have you ever talked to 19 Joe Cudlin about any subject other than the 20 one we just talked about up to today?
21 A
Yes, I have talked to Joe Cudlin.
22 Q
What is your understandina of the
?3 state of Mr. Cudlin's knowledge as to reactor coolant
(
24 pump operation in a two-phase state?
25 MR. BENEDICT:
I object to the question.
I a
- ~,
n.-
,m.,
-m,-
a g
,a,w n
1 Kennedy 79
(~h C/
2 I don't understand what unless you 3
can tell me what the relevance is of Mr.
4 Kennedy's knowledge of Mr. Cudlin's knowledge, l[
5 I am going to direct him not to answer.
6 I can't understand how that is relevant 7
to this litigation.
8 MR. MacDONALD: It is relevant to the 9
extent that I am attempting to find out what 10 Mr. Kennedy understands is a fellow e mp loy e e ' s 11 knowledge on the reactor coolant pump operation 12 in a two-phase state.
13 MR. BENEDICT:
I understand that is what 14 you are asking and I can't imagine how that is 15 relevant.
16 If you want to ask him what Mr. Cudlin 17 has said to him about that subject,.that is 18 fine.
19 What Mr. Kennedy's divination of Mr.
20 Cudlin's knowledge is is irrelevant.
21 MR. MacDONALD:
We started on that tack.
22 MR. BENEDICT:
One conversation I directed 23 him not to go into because it is work product.
(
24 I didn't limit you on any other conversation.
25 Q
Have you talked to Joe Cudlin about his
...-~
1 Kennedy 80
~h (G.
t 2
knowledge or about the subject of reactor coolant 3
pump operation in a two-phase state at any point in 4
time prior to today other than the conversation that
(
5 you mentioned earlier?
i 6
A I don't recall one way or the other.
7 MR. MacDONALD:
I would like to mark as 8_
GPU 435 a copy of a semo from J.
J.
Cudlin p
to B.
M.
Dunn dated 5/4/79.
10 (Copy of a memorandum to B.', M. Dunn from 11 J.
J. Cudlin dated 5/4/79 marked GPU Exhibit I
12 No. 435 for identification as of this date.)
N/
13 Q
Have you seen a copy of this document before?
[4 MR. BENEDICT:
Outside of the presence 15 of counsel, and I might add that I have seen 16 this document before and it didn't have 17 anything attached to it.
18 MR. MacDONALD:
I didn't staple or 4
19 unstaple anything. I am just presenting it how 20 it was given to me.
21 MR. BENEDICT:
The microfilm numbers are L
22 in order, but that doesn't mean it is one 23 document.
(
24 MR. MacDONALD:
I am j ust marking it as 25 an exhibit.
1 1
Kennedy 81 u_J.
2 A
I have seen the first page in preparation 3
for this.
4 Q
Other than that, you have not seen it?
(~
5 A
No.
6 Q
In the second paragraph Mr. Cudlin states, 7
"I discussed the-subject with R.
K.
Kennedy (Fluid and 8
Mechanical Systems), and he cited the TMI-2 and 9
Davis-Besse transients as instances where the RCPs 10 have been subjected to two-phase flow dithout apparent 11 effect."
12 Do you recall a conversation with f')
13 Mr. Cudlin regarding this particular subject?
14 A
I don't recall such a conversation, no.
15 MR. MacDONALD:
I would like to mark as 16 GPU Exhibit 436 a document entitled "B&W 17 Comments" to L.
Rogers, TMI site, subject:
18 "B&W Review of TMI's Operating Procedure."
19 (Document entitled "B&W Comments" to 20 L.
Rogers, TMI Site, subject:
"B&W Review 21 of TMI's Operating Procedure" marked GPU 22 Exhibit No. 436 for identification as of this 23 date.)
()
24 Q
Have you ever seen a copy of this document s_-
25 before?
1 Kennedy 82
[^T
~
2 A
Yes, I have.
3 Q
Is that your signature on page 2 next 4
to the preparer?
(
5 A
Yes.
6 Q
Is this one of the procedures you were 7
referencing earlier in your testimony regarding 8
operational limits fo r shaft and frame vibration 9
that were changed with regard to TMI-2 af ter the 10 accidenti t
11 A
Ye8-12 Q
on page 2 it says, "2.0 E.
The Ok_)
13 recommended operational limits for the last remaining 14 pump are:
Shaft vibration greater than 70 Mils."
15 How was that arrived at, that figure, 70 16 mils?
17 A
Again, that was arrived at on the basis
~
18 of the experience in the field with pumps similar to the l
19 TMI-2 pumps.
That number recognizes the possibility i
20 of damage to the pump but in the context that it is 21 important that the pumps operate.-- and I am talking L
22 subsequent to the TMI-2 incident it was considered 23 important that the pumps operate to maintain flow l
f )/
24 through the core.
x 25 Again, I would like to point out that there
_,_l_
l 1
Kennedy 83 AV 2
were safety systems there per the design requirements 3
and licensing requirenents of the plant which were 4
totally adequate to provide core cooling.
s
((
5 MR. MacDONALD:
I move to strike the last 6
part because it wasn't responsive to how it 7
was arrived at.
8 MR. BENEDICT:
We have been through 9
this before.
I *. is in the record.
We can 10 fight about it later.
(
j 11 Q
You never made any recommendation, did you, 12 cfter the Davis-Besse. transient o f September 1977 4
's 13 regarding changes in Davis-Besse's or B&W's limits 14 and precautions with respect to shaft or frame 15 vibration?
4 16 MR. BENEDICT:
By "you," do you mean 4
17 himself?
18 MR. MacDONALD:
Mr. Kennedy or his unit.
19 A
No, I would not have made any such 20 recommendation.
21 Q
Do you know whether or not anybody else l
22 at B&W did?
l 23 A
I don't know.
24 Q
Based on your review of the data at
~
l 25 TMI-2, do you know whether or not during that
~ _,. _. _.
1 Kennedy 84 V(N 2
accident that.the pump vibration, either the shaft i
f 3
or frame, exceeded 70 mils?
4 MR. BENEDICT:
Can I have that back.
(
5 Q
Based on your knowledge of the TMI-2 6
accident, do you know whether or not the shaft 7
vibration during that accident exceeded 70 mils?
8 A'
I don't knew.
9 Q
Did you look during'your evaluativn 10 of that transient and of the reactor cdolant pumps' 11 performance during that transient at the shaft 12 vib ra tio n that occurred during the transient?
CT 13 A
We know that an alarm was received, the 14 magnitude of'which I am not sure.
15 Q
Did you or anybody in your unit ever 4
16 consider making a recommendation regarding the
.i 17 operational limits of the pumps with respect to shaft 18 vibration prior to the time of the TMI-2 accident 19 such as the one in E on page 2 of GPU Exhibit 4367 20
!!R. BENEDICT:
I object to the form, and 21 also it is asked and answered; but if he can 22 c$swer it.
)
23 (Record read back.)
talkinhincontext 24 A<
You are of " operational" 25 a two-phase environment?
~ - -.
-fl a.,g^
e --
c,.,.,
,e<w
,.c
1 Kennedy 85
.3 I
2 Q
I am talking of the general recommendation' 3
that shaft vibration not exceed 70 mils just as,a 4
an operating limit.
I am asking you whether or not
(
5 you or anybody else in your unit ever considered 4 t
6 making that recommendation prior to the time of the
\\.
7 TMI-2 accident.
s 8
A The answer is I don't recall.
9 MR. MacDONALD:
I would like to mark as 10 GPU Exhibit 437 a memo from R.
K.!, Kennedy and s
11 G.
G.
Anderson to L.
J.
Stanek dated August 28, 12 1979.
y
(~)
x-13 (Me mo randum from R.
K.
Kennedy and
.m 14 G.
G.
Anderson to L.
J.
Stanek dated August 28, 15 1979 marked GPU Exhibit No. 437 for identification 16 as of this date.)
17 Q
Have you ever seen a copy of this memo?
18 A
Yes, I have.
19 Q
Is this a memo that you and Mr. Anderson 20 wrote to Mr. Stanek in or about late August 19797 21 A
Yes.
L 22 Q
The second page of this document, the 23 paragraph reads, "If the above services and I
)
24 instrumentation are provided and proper emergency L/
25 limits ~ dopted, we see no reason why the RC pumps a
. - = _ _ _
(
%g y
y
,,4 1
' Kennedy 86 s
y j
~,
2 should be automatically tripped.
During any
^ ~ ^
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s.
)
\\~
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emergency condition, we believe the pumps, or at least
- y i
i
- 4 one pump per loop, should be kept operational until
- g t'
/
N,.,
/'
/
N5 the oporator has had 'a'dequat'e time to evaluate the s
t
.(
4 6
cause of the! transient and has established the best s
, s.
4
'7, method, of correcting the situation."
1 i
'8
~J ('
In those two sentences, what was your
~
4.
A 4
9 understa ding of the-term " transient"?
Were you n
~\\
10
i6cluding all transients?'
t 11 MR. BENEDICT:
Your recollection of what 12
(
yoh-meant when you wrCte that.
O b'
13 A-
, We were talkin{ in context of the TMI-2 t
1 14 transient.
a s.
s 15 Q
shocificallythe LOCA?
16 A
Yes.
E'.
i s.
T N ',
17 Q
Small break LOCA.
^
s V\\
18 Prior'No the time of the TMI-2 accident,
~
'T i
19 did u or anyone in your unit make any such
\\
I
,.,7H 20 recommendation as reflected in those two sentences?
's y
%,.21 A
No, we did not.
That' recommendation came y,
s
~
22 as a consequence of the TMI-2 incident and was a view i..
)
l 4
'l
' 23 adoptod by the industry that' pumps, RC pumps, may be y
.,,u,
.s f
f 4
g 5
24 '
effective in-providing some ccr'e cooling, the magnitude s
I-25 of which is not well known.
k
-m_
-... ~.., _, -, - -,...... -.... _ - -, - _ _ _ _
..x.
..,,-...c,..-_.s
3 1
Kennedy 87 2
Again, it was in the context of this is 3
an asset that may be available.
As such, perhaps this 4
asset ought to be used but the pumps are not required.
((
5 Q
You didn't know prior to the time of the 6
TMI-2 accident that the reactor coolant pumps were 7
an important &ctor in contributing to effective 8
core cocling?
9 MR. BENEDICT:
I object to the form, but 10 you may answer.
t 11 A
It had never been considered because 12 reactor coolant pumps were not required to operate b>)
\\-
13 in such an environment.
14 Q
So you had never considered prior to the 15 time of the TMI-2 accident whether or not the i
16 reactor coolant pumps were necessary in order to 17 effectively cool the reactor core?
18 A
In my view, the reactor coolant pumps 19 were not considered necessary both be fore or after 20 TMI-2.
21 (Recess taken.)
I would like to mark as 23 GPU Exhibit 438 a copy of a memo from B.
A.
(
24 Karrasch and R.
K.
Kennedy to R.
E.
- Ham, 25 January 21st, 1980.
~...-.
l 1
Kennedy 88 2
(Copy of a memorandum from B.
A.
l 3
Ka rrasch and R.
K.
Kennedy to R.
E.
Ham 4
dated January 21, 1980 marked GPU Exhibit 438 5
for identification as of this date.)
g{
6 Q
Mave you seen prior to today a copy of 7
this document?
8 A
Yes, I have.
9 Q
Is this a document that you and 10 Mr. Karrasch wrote to Mr. Ham in or about mid-January 11 19807 l
12 A
Yes.
13 Q
In paragraph 2 you say,."A set of 14 emergency limits has never been generated for use 15 during accident conditions."
16 I take it you meant prior to the time f
17 of the TMI-2 accident no such emergency limits had 18 been generated for use at B&W operating plants, is that 19 correct?
20 A
That's correct, nor was there a need for 21 such units.
(.
22 MR. BENEDICT:
I might point out that the 23 paragraph goes on to explain that there was 24 something done f o r TMI-2, and in the last 25 sentence it says, "These emergency limits need
1 Kennedy 89 O
2 to be made into a generic set applicable 3
to all operation plants."
4 MR. MacDONALD:
The document states what l{
5 it states.
6 MR. BENEDICT:
I agree.
4 7
MR. MacDONALD:
Basically --
8 MR. BENEDICT:
Taking a sentence out'of 9
context 10 5
+
MR. MacDONALD:
It is not dut of context.
11 You don't have to provide answers b'y reading 12 other portions of the document.
The witness 13 is perfectly capable of answering the question.
14 Q
Are some of those emergency limits reflected i
15 on page C9 7220, the page entitled "TMI-2 Experience 16 RC Pumps"?
17 A
Yes, they are.
18 Q
Were these sent to all B&W operating 19 plants after the TMI-2 accident?
20 A
I don't know whether they were or not.
21 Q
You were involved, were you not, in the 22 drawing up of some of these limits?-
23 MR. BENEDICT:
Asked and answered.
- o 24 co aheae.
25 A
Yes, I was.
1 Kennedy 90
(
G' 2
Q Prior to the time of the TMI-2 accident, 3
you knew, did you not, that vibration levels for the 4
reactor coolant pumps would increasecas reactor
(
5 coolant system void fraction increased?
6 A
I knew that pumps in general respond to 7
saturating conditions or saturation conditions 8
often times by increased shaft vibration.
9 Q
So I take it the answer to the question 10 is yes?
11 MR. BENEDICT:
I object.
His answer is 12 what he stated.
x 13 MR. MacDONALD:
I think his answer is 14 ambiguous.
15 MR. BENEDICT:
Then you can ask him 16 questions about it.
17 MR. MacDONALD:
That is exactly what I did.
18 MR. BENEDICT:
I object.
The question 19 has been asked and answered and I have heard 20 that directly f rom you in other depositions, 21 so if you want to look for p recedent, look to L
22 yourself.
23 MR. MacDONALD:
I won't engage in colloquy
/~N
( j 24 with you.
25 I am asking a very simple question.
._m 1
Kennedy 91
[J 2
MR. BENEDICT:
You are simply asking 3
the question again.
4 If you want to ask him something about
({
5 his answer, you may.
6 MR. MacDONALD:
If you obstruct the 7
deposition, that is your choice.
8 Q
I take it you understood prior to the time 9
o f the TMI-2 accident that reactor coolant pump 10 vibration levels-could increase as the void fraction 11 in the reactor coolant system increased?
12 MR. BENEDICT:
I object as asked and V
13 answered.
14 If you can answer it again, go ahead.
15 A
Reactor coolant pump is a pump, and as 16 I stated before, being a pump, one of the symptoms 17 of void fraction is shaft vibration.
18 Q
Prior to the time of the TMI-2 accident, 19 was it your understanding that vibration levels of 20 the reactor coolant pumps would decrease as the i
21 void fraction in the reactor coolant system increased?
22 A
No, I did not have that understanding.
23 Q
would the vibration levels stay the same 24 based on your experience and unders tanding irrespective 25 of what the void fraction was in t'he reactor coolant
-.. -. _..-.- - -. ~. -, -. - - - -.. - -
1 Kennedy 92
(
~
\\%-
2 system?
3 A
As I stated, one of the symptoms is 4
increased shaft vibration.
Normally that is what
(
5 you would expect.
6 I can't say absolutely that that would 7
always occur.
8 Q
Did you know, based on your experience 9
prior to the time of the TMI-2 accident, what void 10 fractions in the reactor coolant system would produce 11 vibration.*.evels on the frame of the reactor 12 coolant pumps greater than three mils?
\\-
13 A
No, I do not know what void fraction 14 would produce vibration greater than three mils.
15 I would add that there has been no te s ting 16 on reactor coolant pumps, control testing, which 17 would demonstrate the mechanical performance of the 18 pump in a void fraction environment.
19 MR. MacDONALD:
I move to strike the 20 second half of the answer.
21 Q
Did you know based on your knowledge L
22 and experience prior to the time of the TMI-2 accident 23 what void fractions would produce vibration levels on
(
24 the shaft greater than 25 mils?
25 MR. BENEDICT:
25 mils?
,_, - - - -., - - - ~. -
1 Kennedy 93 CE)
~
2 MR. MacDONALD:
Yes.
3 A
No evidence existed which would cause ma 4
to believe what void fraction would cause
((
5 vibration in excess of 25 mils, either test or 6
analysis.
7 Q
I take it prior to the time of the TMI-2 8
accident, you didn't know what vibration level on the 9
reactor coolant pump would be for either shaft or frame 10 at a void fraction of ten percent in tlie reactor 11 coolant system?
12 MR. BENEDICT:
Do you have any specific
(~\\
,b 13 plant?
Does it matter to you?
14 MR. MacDONALD:
No.
15 MR. BENEDICT:
Just a reactor coolant 5
16 pump in a B&W plant?
17 MR. MacDONALD:
Yes.
18 A
That's correct.
19 Q
And the same would be true for void 20 fraction of 95 percent?
21 A
Yes.
f 22 Q
I take it for 60 percent void fraction, 23 you wouldn't know what the vibration level would be
()
24 for either shaf t or frame either, is that correct?
25 A
The answer would be the same.
t i
1
-1 Kennedy
.94
(~)%
~
\\_
2 (Recess taken.)
3 MR. MacDONALD:
I would like to mark as 1
4~
GPU Exhibit 439 a copy of a document from
(
5 R.
K.
Kennedy to L.
J.
Stanek, November 27, 1979.
6 (Copy of a memorandum to L.
J.
Stanek 7
from R.
K.
Kennedy dt.ted November 27, 1979 8
marked GPU Exhibit No. 439 for identification 9
as of this date.)
10 BY MR. MacDONALD:
6 T
11 Q
Is this a copy of a document that you 12 wrote to Mr. Stanek in or about late November 19797 l'
13 A
Yes.
14 Q
Did you have any input into this document 15 from any other source aside from yourself?
16 A
I don't recall.
17 Q
Did you speak to any of your employees 18 in the pumps and drives unit to obtain input into 19 this document?
l-l 20 A
I don't recall.
21 Q
Let me refer to item I,
" Management 22 of Resources.
It appears that the engineering 23 department is not oriented toward the development of 24 solutions to problems which require swift and complete 25 response.
There is no ' traffic cop' to ensure that i
~
.,-..,.,,,,,...-,m.
-r_,,.,.,_.g
__,..y...,...p
1 Kennedy 95' O
2 the right disciplines are working on the right 3
problems at the right time.
A good example is the 4
development of the small break guidelines for which'
(~
5 RC pump and motor limitations were not considered 6
until af ter initial versions of the guidelines had 7
been issued.
The result was wasted effort and, 8
presumably, less than maximum responsiveness."
9 Who were you referring to when you said 10 "not considered"?
By whom?
t 11 A
My recollection would be the members of 12 the pumps and drives group.
f' 13 Q
Is that because you were not asked?
14 A
As the heading of this paragraph indicates, 15 I am talking about the effective use of resources, 16 and implied there is that we were eventually asked.
17 Q
But not until after the initial versions 18 of the guidelines had been issued?
19 A
I am saying that we would have been more 20 efficient had we been involved at the front end.
21 That was my opinion.
L 22 Perhaps the people involved in drafting 23 the initial version didn't think so.
[
24 Q
Under No. II, " Product Responsibility.
t 25 I
It appears that in some ins tance s -B &W tends not to
1 Kennedy 96
~)(J
~
2 face up to correcting operating problems (hardware 3
r software) if the proposed corrective actions are 4
perceived to have little market potential.
For
((
5 example, the funding required for the RC pump seal 6
failure analysis was initially considered an appropriate 7
product for sale to the utilities.
This thinking 8
was followed by extensive discussions on whether the 9
funding for this effort should come from G-order or 10 in-house R&D.
The result was an extended delay in 11 initiating this important engineering effort."
12 How long was the extended delay to which 13 you refer?
14 MR. BENEDICT:
I object unless you can 15 indicate to me some relevance of this RC pump 16 failure analysis to the lawsuit at hand.
17 MR. MacDONALD:
I think it [s. relevant 18 in that it goes to the ability of B&W to 19 properly manage itself,ias does No.
I, and I am 20 just asking whether or not he recalls what th'e 21 extended delay was that he referenced in 22 the last sentence.
23 MR. BENEDICT:
I object to this ques tion 24 and whatever ques tions follow on this subject 25 because they are beyond the designation of the i
1 1
Kennedy 97
.(d 2
3 0 (b) (6) deposition and because they are not 3
relevant.
4 We can go on this line for a while and
((
5 see how we are doing, and if things get completely 6
out of hand, I will start instructing him not 7
to answer, but you may answer this question.
8 Q
The question was what was or how long was 9
the extended delay that you were referencing in the 10 last sentence?
11 A
I don't remember.
12 Q
No. III, " Inter-Department Coordination,"
13 reads, "There is a perception that the, resolution of 2
14 operating plant problems is pursued with different 15 levels of intensity within NPGD.
That is, the 16 task engineer may identify a problem, develop and 17 transmit the resolution to the project management 18 function for implementation only to realize 19 that the problem is not perceived to be a problem by 20 the receiving organization.
An example is the seal 21 test fixture proposal which was developed by engineering 22 and transmitted to the project management function in 23 S ep t e mb e r 1978 for which'no action has been taken
(~)h 24 to date.
There should be front-en d management control
(
25 which will assure consistency in priority assignments i
..-.. ~,..
.. -. _,,.. -. ~
1 Kennedy 98 A
N 2
throughout NPGD."
3 Has any action, to the bes t of your 4
knowledge, been taken on that matter since November 27,
(
5 19797 6
MR. BENEDICT:
I object to this as 7
beyond the scope -- management operations 8
within the engineering department are beyond 9
'the scope of this deposition, and this is also 10 beyond the pale in terms of relevance.
11 This memo is written after the 12 accident.
I can't imagine what relevance it
,nd 13 has.
14 MR. MacDONALD:
He is speaking of a 15 problem here which ex'isted prior to the accident.
16 I am just asking whether he knows as of i
17 today whether any action was taken.-
18.
MR. BENEDICT:
I am not convinced this 19 memo is speaking of anything prior to the accident.
20 I don't know.
It is beyond the deposition.
21 (Record read back.)
22 MR. BENEDICT:
I object.
23 You may answer, but this is the last 0)
(
24 question on this subject.
25 A
I would simply point out that this is in
[
1 Kennedy 99 O
2 the context of engineers trying to solve problems, 3
and whether or not they get to solve problems is a 4
function of the.will of the management.
(
5 Q
I am just asking whether or not you-
'6 know that item III has been solved as of today.
I 7
A I don't know.
8 (Time noted:
4:00 p.m.)
i 9
ROBERT K.
KENNEDY 10 11 Subscribed and sworn to 4
12 before me this day 4
13 of 1982.
14 15 16 17 18
.1 19
.[
I 20 21 C
22 23 l 0
- m 25 a
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1 100 (U
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cgRIIgrcarg 3
STATE OF NEW YORK
)
- ss.:
4 COUNTY OF NEW YORK )
(
6 I,
JOSEPH R.
DANYO a
3 7
Notary Public within and for the State of New York, 8
do hereby certify that the foregoing deposition 9
of RosERT K.
Kenneny was taken before 10 me on January 27, 1982 i
11 That the said witness was duly sworn-12 before the commencement of his testimony and O
~
13 that the sithin transcript is a true record o~f said 14 testimony; 15 That I am not connected by blood or 16 marriage with. any of the parties herein nor 17 interested directly or indirectly in the matter in 18 controversy, nor am I in the employ of any of the 19 counse1.
20 IN WITNESS WHEREOF, I have hereunto set 21 my hand this,/ f day of k tvAfr 1982.
22 03 eseY 24 J
Pd R. DANY[
v 25
1 101 O
s.
I ND EX
(%
WITNESS PAGE 4
Robert K.
Kennedy 3
EXHI B IT S GPU FOR IDENT.
430 Resume of Robert K.
Kennedy 3
E 431 21-page exhibit, first page of which 10 is a memo from J.
A.
Lauer to 4
distribution, October 11, 1977 432 Seven-page document, firs t page of 41
(
which is a memo to J.
A. LAuer from J.
D.
Denpsey, dated October 18, 1977 433 Document entitled " Mixed Flow 54 Test RC Pumps," " Lead Section Manager:
L.
J.
Stanek" 434 Seven-page document, the first 56 page of which is a letter to T.
Fernandez from Edward E.
Chipman, dated July 3,
1979 435 Copy of a memorandum to B.
M.
Dunn 80 from J.
J. Cudlin dated 5/4/79 436 Do c um en t entitled "B&W Comments" 81 to L.
Rogers, TMI Site, subject:
"B&W Review of TMI's Operating Procedure" 437 Memorandum from R.
K.
Kennedy 85 O
and G.
G.
Anderson to L.
J.
Stanek dated August 28, 1979
-~-.
i i
102 i
s E XH IB I TS GPU 5
(Continued)
FOR IDENT.
1 438 Copy of a memorandum from hl.
A.
88 Karrasch and R.
K.
Kennedy to R.
E.
Ham dated January 21, 1980 l
t 439 Copy of a memorandum to L.
J.
Stanek 94
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from R.
K.
Kennedy dated November 27, 1979 i
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