ML20072J074
| ML20072J074 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 01/07/1982 |
| From: | Potts W GENERAL PUBLIC UTILITIES CORP. |
| To: | |
| References | |
| TASK-*, TASK-01, TASK-02, TASK-03, TASK-04, TASK-05, TASK-06, TASK-07, TASK-08, TASK-1, TASK-2, TASK-3, TASK-4, TASK-5, TASK-6, TASK-7, TASK-8, TASK-GB NUDOCS 8306290909 | |
| Download: ML20072J074 (176) | |
Text
dab UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK
___.__________x GENERAL PUBLIC UTILITIES CORPORATION, s
/'
JERSEY CENTRAL POWER.& LIGHT COMPANY,
' (,'
METROPOLITAN EDISON COMPANY and PENNSYLVANIA ELECTRIC COMPANY, Plaintiffs, 80 CIV. 1683 (R.O.)
-against-THE BABCOCK & WILCOX COMPANY and J.
RAY McDERMOTT & CO.,
INC.,
3 Defendants.
_ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _x Deposition of WILLIAM E.
PDTTS, taken by Defendants,, pursuant to Notice,'at the offices of Davis Polk & Wardwell, Esqs.,
i One Chase Manhattan Plaza, New York, New York, t
!j on Thursday, January 7, 1982, at 9:40 o' clock h
j in the forenoon, before Robert Capezulo, f
a shorthand Reporter and Notary Public within and for the State of New York.
8306290909 820107 PDRADOCK05000g N-T O
DOYLE REPORTING. INC.
N CERTIFIED STENOTYPE REPORTERE 369 Lax:NGTON AVENUE
{
WALTER SH APIRO C.S.R.
Ngw Yemet. N.Y.
10017 CHARLES SHAPIRO. C.S.R.
Tat.,EPNO N E 212 *- 867-822o
l s
1 2
b 2
APPea rance s:
3 KAYE, SCHOLER, FIERMAN, HAYS & HANDLER, ESQS.
Attorneys for Plaintiffs 4
425 Park Avenue New York, New York 3
5 By:
MYRON KIRSCHBAUM, ESQ.,
6 of Counsel 7
8 9
DAVIS POLK & WARDWELL, ESQS.
Attorneys for Defendants I
10 One Chase Manhattan Plaza New York, New York 10005 11 By:
KAREN E.
WAGNER, ESQ.,
12
'of counsel 13 l
14 i
15 16 Also Present:
17 SUSAN HANSON, Paralegal Davis Polk & Wardwell, Esqs. -
18 19 20 i
- 1 22 l
O 24 l
o5 l
i
,m r
n
1 3
2 IT IS HEREBY STIPULATED AND AGREED 3
by and between the attorneys for the 4
respective parties hereto that the sealing, 5
filing and certification of the within a
deposition be, and the same hereby are, 7
waived; and that the transcript may be 1
8 signed before any Notary Public with the 9
same force and effect as if signed before I
10 the court.
11 IT IS FURTHER STIPULATED AND AGREED 12 that all objections, except as to the form 13 of the question, shall be reserv.ed to the 14 time of trial.
15 16 17 i
18 19 20
~1 9
- (
22 23 i
~ j
'24 25 I
1 4
P O TT S, having been
~ duly sworn by the Notary Public (Robert 3
first 4
Capuzelo), was examined and testified as 5
f o l,l o w s :
6 EXAMINATION BY MS. WAGNER:
7 Q
What is your name and address?
8 A
William Potts, Mount Joy, Pennsylvania.
9 MS. WAGNER:
I would like to have marked t
I as B&W 380, a copy of a resume of William E.
11 Potts which he has just presented us.
12 7_s (Resume of William E. Potts marked U
13 B&W Exhibit No. 380 for identification, as of 14 this date.)
15 Q
Is B&W 380 a copy of your resume?
16 A
I'm not certain what B&W 380 is.
17 Q
The document in front of.you~
18 A
That is a copy of my resume.
19 Q
Is it up to date?
20 A
Yes.
21 Q
Your resume starts with your experience 22 in the U.S.
Navy.
Can you briefly recount for_me your 23 educational experience prior to that time?
A(_)
24 A
Prior to the Navy?
25 Q
Yes, if any.
And high school and up.
I
1 Potts 5
CE)
~
2 Grade school we don't have to worry about.
3 A
'I was a high school graduate when I joined 4
the United States Navy.
5 Q
When you joined the U.S. Navy, what was 6
your first position?
7 A
Recruit.
8 Q
What did you do as a recruit?
9 A
I'm not certain what you mean.
A recruit 10 is in recruit training.
11 Q
Was any of your training involving nuclear 12 matters?
13 A
No.
14 Q
'Were you ever ihvolved in your time in the 15 U.S.
Navy in any kind of nuclear' experience or training?
16 A
I was not trained in nuclear technology in 17 the U.S.
Navy.
18 Q
Were you trained in any kind of engineering 19 technolo'gy?'
20 A
I was trained in technology in the Navy, 21 electronics technician, computers, inertial navigation.
(
22 Q
Did you ever_ serve aboard any ships?
23 A
Yes.
).
24 Q
Were any of those nuclear-powered ships or 25 submarines?
4 1
Potts 6
2 A
I served on a nuclear-powered submarine, 3
USS GEORGE WASHINGTON.
4 Q
During your time aboard that submarine,
(
5 did you have any duties relating to nuclear activities 6
of that ship?
7 A
No, Id did not.
I 8
Q What was your last rank in the U.S.
Navy 9
in 19667 10 A
Electronics technician, fikst class.
11 Q
Your resume indicates "SS."
What does 12 that mean?
13 A
Qualified in submarines.
14 Q
Your resume indicates in-1966 you went to 15 Penn State.
What did you. study'there?
16 A
Electrical' engineering.
17
'Q Did you get a degree in that?
18 A-I received a Bachelor's degr e.
19 Q
In 19707 20 A
Yes, ma'am.
21 Q
Did you go immediately from.Penn-State to-k.
22 the Saxton Nuclear Experimental Corporation?
23 A
Yes.
24
-Q
'What was your first job.there?
25 A
Test engineer.
t
1 Potts 7
\\j 2
Q What were you testing?
A
'The test program at Saxton involved 3
4 different nuclear fuels.
5 Q
You'were testing how those fuels operated?
6 A
Yes.
7 Q
Were you testing the fuels by using them 8
in a nuclear. plant?
9 A
Yes, we,were.
10 Q
Were you licensed at S ax to'n ?
i 11 A
Yes, I was.
12 Q
When were you licensed?
13 A
I had a senior operator's. license I believe 14 in 1970.
I'm not absolutely certain of the date.
15 Q
How long did you hold the license at 16 Saxton?
17 A
Two years approximately.
18 Q
During the test program at Saxton, were you i
19 actually involved in manipulating controls of a reactor?
i 20 A
Not as part of my job duties.
-In order to 21 license, it is necessary to perform I believe it's two 22 startups.
I performed the startups sufficient to get 23 my license.
O)
(,
24
'Q What was the purpose of your getting a 25 license if you were not intending to manipulate the
t 1
Potts 8
O 2
controls?
- MR.
KIRSCHBAUM:
Objection.
I don't think 3
he testified as to any intent.
4 i
()
Q What was the purpose of your getting a 5
6 license?
A The license was a requirement of the 7
8 technical specifications at that time for the position l
1 9
of Supervisor, Reactor Plant Services.
10 Q
What were your specific dukies as Supervisor 11 of Reactor Plant Services?
12 A
I supervised the Health, Physics, Chemistry O
13 and Maintenance Groups.
14 Q
What activities were the Maintenance Groups 15 inv lved in?
I 16 A
Maintaining the reactor plant, maintaining-17 the secondary systems and the auxiliary systems.
18 Q
You did not have supervisory responsibility 19 at that time for reactor operators?
20 A
I did not.
91 Q
Who did have such responsibility at the k.
~
time that you were there?
22 23 A
The Supervisor of Operations.
24
. Q Do you recall who that was?
25 A
There were several Supervisors of Operations
1 Potts 9
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~
2 during my period at Saxton.
3 Q
'Can you give me some of their names?
4 A
Mr. Herbein.
I'm sorry, I just don't 5
remember the others.
6 Q
Your resume indicates in 1972 you went to 7
the Metropolitan Edison Company, is that correct?
8 A
That's correct.
4 9
Q And your first position was Supervisor -
10 Quality Control, is that correct?
11 A
Yes.
12 Q
What were your responsibilities as O
13 Supervisor of Quality Control?
14 A
I supervised the Quality Control 15 organization for Three Mile Island Unit 1.
e 1G Q
When you indicate Quality Control 17 organization, what activities did that organization 18 undertake at that time?
19 A
The organization inspected the Main'tenance, 20 Warehousing and Operations and Engineering Groups at 21 Three Mile Island Unit 1.
22 MS. WAGNER:
Could I have the answer read 23 back.
(
24 (Record was read back.)
25 Q
When you indicate the organization i
1 Potts 10
("h
\\_J 2
inspected the Operations Department, what do you mean 3
by that?
4 A
We performed inspections of the operations 5
on a random basis to provide the corporation the 6
information on the operations and maintenance and 7
to meet the requirements of the Appendix B,
Part 50.
8 Q
When you speak of operations in this 9
context, do you include the operation of the nuclear E
10 plant at TMI-17 11 A
Yes, I do.
12 Q
Would that include inspections of operator -
13 activities in the control room, for exampic?
14 A
Yes, it would include that.
15 Q
How would you then have conducted such an e
16 inspection?
17 MR. KIRSCHBAUM:
Are you asking what did he 18 do or what would he do?
19 MS. WAGNER:
What his normal course of 20
. inspection was.
21 MR. KARSCHBAUM:
You are asking for what-33 actually happened?
23 MS. WAGNER:
Yes.
g w) 24 A
An-inspection would be assigned to an 25 inspector.
He would the inspection scope would be
1 Potts 11 v
2 defined.
He would review the procedures and develop 3
an inspection checklist.
4 Q
When you say reviewing procedures, which 5
Procedures are you talking about?
6 A
What procedure was involved with the area 7
of the inspection or the scope of the inspection.
8 Q
That could include operating procedures 9
for the nuclear plant?
10 MR. KIRSCHBAUM:
Objectioni, I don't 11 understand what you mean by "could include."
12 MS. WAGNER:
I don't know what procedures 13 he is talking about.
I am asking if it could 14 include one of those.
~
15 MR. KIRSCHBAUM:
I think he is testifying
' nspections of various groups.
If you i
16 there were 17 want to ask him about a particular. group, I suppose 18 he might be able to tell you.
19 MS. WAGNER:
All of these questions have to 20 do with the Operations Group.
I am wondering if' 21 one of the procedures would be the operating 22 procedures for the nuclear plant.
23 Q
If you don't understand, tell me and I will n
(
)
-24 try to rephrase it.
25 A
I'm not absolutely certain I understand
1 Potts 12 2
your question.
Would you please rephrase it?
3 Q
You mentioned that your inspectors would 4
review procedures.
Can you give me a list of every kind 5
of procedure they would review under any circumstance?
6 A
I don't believe I can give you a total list.
7 Q
Can you give me a partial list?
8 A
The operations maintenance procedures, the g
warehouse procedures, engineering procedures.
10 Q
I,take it the list would ekclude operating 11 emergency procedures fok the nuclear plant?
12 A
No.
(3 s
13 Q
They would be included in.that list?
14 A
They would be included if the-inspection 15 scope included that area.
16 Q
I interrupted you in the middle of your 17 answer.
The inspector would review procedures, create 18 a checklist and what do you do next?
19 A
Starting back to reviewing the procedures, 1
20 the scope of the inspection would be defined.
Those 21 procedures that were involved within the scope of the k'
23 inspection would be reviewed to determine what the 23 acepetance criteria would be for the inspection checklist.
p(_)
24 The inspection checklist would be prepared.
The 25 inspector would then observe.the~ actions that took 11 '
~
1 Potts 13 2
place within the scope of that inspection and make 3
c mments as to did they or did they not meet the 4
inspection checklist.
(
5 An inspection report would be prepared and 6
submitted.
7 Q
When you speak of acceptance criteria, 8
where would you draw the acceptance criteria from?
9 A
From the procedures that were within the 10 scope of the inspection.
I 11 Q
In a situation in which operating emergency 12 procedures for the operation of the nuclear plant were
(~)
\\ #'
13 being inspected, would the operators b,e told that they 14 should take the actions required by that procedure?
15 How would you be able to-inspect an e
16 emergency procedure unless an emergency happened?
17 MR. KIRSCHBAUM:
Objection.
I think there 18 is more than one question on the record.at this 19 point.
20 Q
How wocid you inspect an emergency procedure?
21 MR. KIRSCHBAUM:
When you say, "How would 22 you inspect," are you asking how the witness 23 personally would inspect?
I-don't know that there s
)
24 is any testimony about his performance of an m/
s 25 inspection.
1 Potts 14
(~~N
.%-)
2 Q
How would your inspectors inspect such a j
3 procedure?
4 A
During my tenure as Supervisor of Quality 5
Control, the inspections of emergency procedures I 6
believe took place during drills.
7 Q
What do you mean by " drill"?
8 A
We periodically drilled or performed drills 9
using the emergency procedures.
10 Q
Do you mean by " drill," yok would ask 11 somebody what the procedure called for or you would 12 somehow simulate a situation calling for the procedure?
O\\
13 MR. KIRSCHBAUM:
Is the qu.estion what he 14 means by " drill"?
15 MS. WAGNER:
Yes.
16 A
What I meant by " drill" is that the 17 operating staff which in that context means more than 18 just the operators, the entire staff ofhMI-1 would periodically perform drills in which we would simulate 19 20 and train on the emergency procedures.
21 During that period it is possible to inspect 22 those actions of various parties.
23 Q
I am going to try to give'you~an example.
/~'N A
j 24 If you were. inspecting, for example, the LOCA procedure v
l' 25 that is loss of coolant accident, do you. understand?
1 Potts 15 O
~
A Y***
2 Q
If you were to inspect the LOCA procedure during that time period, am I correct in assuming you 4
w uld n t reate a LOCA?
-5 MR. KIRSCHBAUM:
Objection.
I think the 6
question should be whether or not he recalls j
7 8
inspecting a procedure for a LOCA.
MS. WAGNER:
I would like to ask him if 9
he has any idea how his departme'nt might have 10 done such a thing.
11 lo Q
Is there no course of performance in this
'13 department?
g4 MR. KIRSCHBAUM:
There might be but find 15 ut whether or not there was a course of 16 performance that he knows of or recalls as to 17 the particular procedure you are asking about, 18 because you are no longer asking about procedures 39 in general.
Q Do you know if the LOCA procedure was ever 20 inspected?
og A
I d n t recall whether we inspected the 22 23 LOCA procedure.
Q Do you know if any. emergency procedure 94 25 was ever inspected during your tenure?
1 Potts 16 2
A I don't recall specifically.
3 Q
Do y u believe based on your experience 4
during that time that emergency procedures were
(
5 inspected or was that something you believe was not 6
done?
I 7
MR. KIRSCHBAUM:
Objection.
The witness 8
has testified he doesn't recall whether or not 9
the LOCA procedure was inspect'ed.
I don't know E
10 what more you are asking.
11 MS. WAGNER:
I am asking whether he believes 12 emergency procedures were inspected by his O
13 department.
14 MR. KIRSCHBAUM:
He testified that he 15 doesn't recall.whether or not they were.
What 16 are you asking?
17 MS. WAGNER:
If that is his testimony, fine.
indicatedyoualsoinspehted engineering 18 Q
You 19 procedures, is that correct?
20 A
Yes.
21 Q
What are engineering procedures?
k 22 A
Procedures that define how engineering 23 would be accomplished, how engineering papers would (n) 24.
be distributed, how engineering papers would be v
25 reviewed and approved.
Potts 17 mU Q
Are there or were there at that time a 2
specific set of procedures called " Engineering Procedures"?
4
{
A I don't believe they were called " Engineering Procedures."
6 Q
Do you recall what they were called?
A Specifically I don't recall the title.
g Q
Do you know where I would find a set of such procedures today?
t A
No.
g MR. KIRSCHBAUM:
Objection.
Where?
12 MS. WA'G NER :
Where would I find them?
g MR. KIRSCHBAUM:
Where would you find them g
in written form you mean, physically?
15 S.
WAc. R:
Physica11y.
1, A
I have used an imprecise tit 1.e for those g
cal [ engineering procedures.
Those' procedures that I 18 procedures within the ability of my memory' right now 19 are called something like " Administrative Procedures"
'and they would be a body.of procedures that were at l
TMI.
22 Q.
Do you have any recollection today which department I~might go to to find such procedures?
\\s
~
MR. KIRSCHBAUM:
' Excuse me, you are asking g
- ~
1 Potts 18
,lO him today if he knows where between 1972 and 1976 2
3 yuw uld go to to find them?
You seem to want 4
to know where to go to today, but you ask whether 5
he recalls from '72 through '76 where you would 6
90-7 Ask whether he knows.
8 MS. WAGNER:
He might not remember today.
9 MR. KIRSCHBAUM:
Then he will tell you he 10 doesn't.
He will tell you he might not know 11 today.
12 Q
Do you understand the question?
13 A
No.
14 Q
I am talking about procedures which you 15 have described as engineering procedures and 16 administrative procedures, whatever their title is.
17 Do you know where I would go to today to-find them, 18 what building, department, if you can give me a clue 19 where I can go to f'ind them?
20 A
I believe that a request to the manager 91 of Administration.
22 Q
Who is the manager of Administration?
23 A
Mr. Christman.
24 Q
You mentioned in your responses concerning 25 engineering inspections, procedures, engineering reports,
1 Potts 19 2
When you were speaking of those reports, are those 3
reports generated within Metropolitan Edison or generated.
4 elsewhere?
Where were they generated during '72 to '767
-(
5 A
The procedures I was speaking of were 6
generated by TMI personnel.
7 Q
The reports which you were inspecting, were 8
they generated also at Metropolitan Edison?
9 A
Yes.
10 Q
Did the scope of your actijities or your 11 department's activities during this time period include 12 review or inspection at any time of any engineering
(~T
\\~
13 documents produced by somebody other than the Three Mile 14 Island staff?
15 MR. KIRSCHBAUM:
Read the question back, l
16 P ease.
17 (Record was read back.)
suhe how you use 18 MR. KIRSCHBAUM:
I am not 19
" inspection."
The witness didn't testify to an 20 inspection of documents.
21 MS. WAGNER:
He hasn't testified to 22 MR. KIRSCHBAUM:
I understand the use of the 23 word " inspection'." ' He[is using it differently
(
h and maybe we ought to. find out how he is using 25
.it.
l
1 Potts 20 0
2 Q
Can you answer the question or not?
A I'm n t certain that the scope did include 3
4 others.
(
5 Q
Do you recall for that time period whether 6
there was any other department at Metropolitan Edison 7
which would have, as a matter of routine, been reviewing 8
engineering reports or documents created by somebody 9
other than the Metropolitan Edison staff?
10 A
There were other departments that reviewed 11 documents prepared by others.
12 Q
Do you recall what d ep artments those were?
t 13 A
I'm not certain what documents you are 14 referring to.
15 Q
An engineering report, for example.
16 MR. KIRSCHBAUM:
Prepared by whom?
You 17 are talking about something prepared by other than 18 Metropolitan Edison.
Prepared by dhom?
19 MS. WAGNER:
Anybody.
20 A
Engineering documents or reports prepared 31 by others would be reviewed by the Engineering 22 Department and perhaps others.
23 MR. KIRSCHBAUM:
I would like to take a j
I^h o4 short recess.
\\_)
~
25 (Recess taken.)
l l
1 Potts 21 2
MS. WAGNER:
May I have the last question 3
and answer read back.
4 (Record was read back.)
5 BY MS. WAGNER:
6 Q
During that time period, did.the Quality,
7 Control Department have any responsibility for reviewing 8
or inspecting the review of such engineering reports 9
created by others by the Engineering Department?
10 A
I don't recall.
E 11 Q
During this time period, was the inspection 12 by Quality Control done pursuant to a quality control 13 plan?-
14 A
Yes.
'P 15 Q
Is it correct that you helped to generate-e 16 that plan?
17 A
Yes.
~
18 Q
When did you first become in olved in that?
19 A
I don't recall the time.
{
i go Q
Was there a quality control plan in 21 existence when you arrived at Met Ed?
l C
22 A
Met Ed did not have a quality control plan 23 when I arrived.
l l
. f'%)
24 Q
Is it correct to say that you were involved i
25 in actually. creating the first one?
1 Potts 22 t
2 A
Yes.
3 Q
Do you know where today I would find a copy 4
of the present quality control plan?
(
5 A
No.
6 Q
Do you have any idea which department I 7
would g; to?
I assume Quality Control.
If I am wrong, 8
will you tell me where you think I can go?
9 A
I'm not certain where you would go to obtain 10 it.
(
11 Q
Is the quality control plan part of the 12 final safety analysis report, to the best of your f^%
Q 13 knowledge?
14 MR. KIRSCHBAUM:
Are you asking as to 15 whether it is part of the FSAR now?
e 16 MS. WAGNER:
Yes.
17 A
I'm not certain whether it is part of 18 the FSAR.
l 10 Q
Can you give me some idea what work you 20 personally did with respect to the quality control' plan
~
21 to generating it?
22 A
I read a number of documents and drafted 23 early revisions, early drafts, participated in the-I., ~%)
24 review by the Met Ed group, i
25 Q
Do you have any: recollection today what
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.,.I t
- i ip 1
Potts 23 4
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u.
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1 2
documents you read prior to drafting this document?
/
1 3
A I recall reading Append!.x B to Part 50
- 4 prior to drafting the document..
s s
5 Q
Do you recall whether y,ou had at your 6
disposal at that time any qualit'y !. contre i. plan from 1
7 any place other than from Met Ed?
s s
g 8
A
-I don't recall specifica13/ wHat plans I s
?^
9 had available.
,)
- \\
(
3 Do you believe you hadar'y. plans available\\.
10 Q
11 or do you recall?
12 MR. KIRSCHBAUM:
What do you nean by 13 "available"?
Did they. exist, did he have them 14 in his office?
e 15 MS. WAGNER:
Did'h,e have them, 4
use them, 16 review them.
v s
4 17 MR. KIRSCHBAUM:
That is\\three different j[
s
\\
?,
18 questions.
e i
s 19 Q
Did you have them?
s 20 A
I don't recall..
- i. y
.\\
21 Q
Do you recall if.you reviewed them?
/. n;I.
.v 22 A
I, don't recall if I:revieded them or not.
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indicated you pargic'ipated;in a rev'iewk.
23 Q
You p
I' sj 24 by the Metropolitan Edison group' ef -various I
draf tc -. of, 3 <
v 25 the plan,.is that correct?
j q
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Potts 24 1
s a
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A N
2 A
Yes.
3 J
Do you recall who it was at Met Ed who was involved in the review of the plan?
q
(
5 A
Mr. Arnold, Mr. Herbein.
I'm not certain s
6 of the others.
7 Q
Did anyone ever tell you why'a quality b
'! ~l, i 8
control plan was being written?
L 9
A I don't recall.
10 Q
Do--you recall whether you 'had any.
~
~
a 11 understanding.from any source as to why such a plan
.y
-s 12 was being vritten?
a 13 MR. KIRSCHBAUM:
The witness may be having
/
/ a problem with the use of the word " understanding.'
- 14 1
15 Are you asking whether he recalls being told by 4
- . )
"/
?
.y 16 anyone?
f')
4 t
- /
, 17 MS. WAGNER:
Whether he has any information
~
18 from any source as to why a plan was being 19 written.
20 MR. KIRSCHBAUM:
Whether then he had any i
21
.information from any source as to why the plan
(
/ /s 22 gas being written?
9 7'
k}23 MS. WAGNER:
Right.
- h) n.
t
[Theplanwaswrittento f/ 2?..
A conform to the
= )
i 25
', requirements of Appendix B to Part 50.
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...?..
1 Potts 25
/
I 2
Q Was Appendix B at that time a recently 3
enacted regulation?
4 A
I don't recall when that appendix was
(
5 enacted.
6 Q
As part of the responsibilities of the 7
quality control group of which you were supervisor, 8
did you or your department ever inspect pieces of 9
equipment?
10 A
Yes.
ti 11 Q
Did you inspect equipment which was used 12 in the nuclear steam system?
[
'b/
13 A
Yes.
14 Q
As a matter of general course, would your 15 department have inspected overy piece of equipment or 16 random pieces of equipment?
17 MR. KIRSCHBAUM:
I object to the question a matter of genera [ course."
18 in terms of "as Are
~
19 you asking whether they inspected every piece?
20 MS. WANGER:
If there was any practice.
21 MR. KIRSCHBAUM:
If
- k.
- there was a practice 22 to inspect every piece?
23 MS. WAGNER:
Right.
24 MR. KIRSCHBAUM:
Within any given period 25 of time?
8 n
.,.s
1 Potts 26 O
\\,m/
2 MS. WAGNER:
At the time he was supervisor 3
of qua'lity control.
4 MR. KIRSCHBAUM:
I mean to inspect every
(
5 piece within any particular period?
6 MS. WAGNER:
No.
No time constraints.
7 A
Would you please repeat your question?
8 Q
Do you recall whether your group would 9
inspect every single piece of equipment that was used e
10 in the nuclear steam supply system?
11 MR. KIRSCHBAUM:
I object to the question 12 as to form.
13 You may answer.
14 A
I don't recall if we had a practice to l
15 inspect every piece.
f 16 Q
Do you recall anything about your practice 17 if there was a practice?
Was there any practice that 18 you can recall with respect to inspection of equipment?
10 A
I don't recall the practice'at that time.
20 Q
Did you personally inspect any piece of 21 equipment?-
22 A
I don't recall if I inspected items 23 personally or not.
24 Q
Do you recall whether any inspector who 25 reported to you inspected any piece of equipment?
1 Potts 27 O
p A
I recall having inspectors who inspected 3
equipment. -
4 Q
Was there any subsection in the quality
(
5 control group who would be involved in inspecting 6
equipment only?
I don't recall.
7 A
1 8
Q Were there any subsections at all in-the 9
quality control group at that time?
10 A
I don't recall that d e t a il'.,
11 Q
Do you recall how many people were in the 12 group at that time, at the time that you were supervisor?
13 A
I don't recall how many pe ple were in the 14 group at that time.
15 Q
Do you recall if it was greater than 50?
e 16 A
Yes.
17 Q
Greater than a hundred?
18 A
I recall that it was I recall whether 19 or not it was greater than 50 and it was not greater i
20 than 50.
21 Q
was it greater than 107 r
22 A
I don't recall now.
23 Q
Do you recall to whom you reported during
)
24 that time?
25 A
I recall who I reported.to during part of
I 1
Potts 28 l
l 2
that time.
3 Q
Who was that?
l 4
A I reported to the manager of Quality f
(
5 Assurance.
I 6
Q Who was that?
(
1 7
A Mr. Lawyer.
+
8 12 Who is the manager of Quality Assurance 9
for Met Ed?
10 A
correct.
E 11 Q
Do you recall who reported to you?
You can 12 give me titles as opposed to names.
(
)
13 A
Quality assurance specialist.
Quality
)
14 e ntrol specialist.
15 Q
There were more than one of these people e
16 that reported to you, I take it?
17 A
Yes.
18 Q
Do you recall during the time period that 19 you were supervisor of Quality Control whether the 20 pilot operated relief valve which was used at TMI-1 21 was inspected by your department?
33 A
I don't recall that.
23 Q
Do you recall whether as a matter of
().
24 practice that is a type of piece of equipment which 25 would have been inspected?
m-
l l
1 Potts 29 l
2 MR. KIRSCHBAUM:
Objection as to form.
3
'You may answer if you are able to.
l 4
THE WITNESS:
Can you repeat the question,
(
5 please.
6 (Record was read back.)
i 7
A I don't recall.
'8 Q
Do you have any reason for thinking right
'9 now that that would have been excluded for some reason.
10 from your inspection?
By "you,"
I mean the departmental 11 inspection.
12 MR. KIRSCHBAUM:
Objection.
There is no O
13 testimony as to any foundation here for his
{
14 recollection of whether specific pieces.of 15 equipment were all or some were or were not' 16 inspected.
II MS. WAGNER:
-I am trying to get his 18 foundation now.
1 19 MR. KIRSCHBAUM:
But you are assuming 2
20 something and you are asking a question in terms 21 of an exclusion, assuming there was a group of I
km 22 equip,ent as to which there was a practice ~and 23 something may have been excluded from that as
~
(T g_)
24 Lopposed to whether there was a practice.
25 MS. WAGNER:
Whether there was a practice
4 1
Potts 30 is
,/
2 to exclude any particular pieces of equipment 3
such is this.
4 MR. KIRSCHBAUM:
You have not established
(
5 yet there was a practice as to defining pieces 6
of equipment which were to be inspected and 7
therefore I don't think the use of the term 8
" exclusion" has any foundation.
9 That is my objection.
10 Q
Do you recall whether any 'particular pieces 11 of equipment were, for any reason, excluded from review 12 by the Quality Control Department during this time O
'd 13 period?
14 MR. KIRSCHBAUM:
Objection as to form.
15 You may answer.
16 A
I don't recall.
17 Q
You don't recall whether or not there was 18 such a policy?
I don't understand your answer.
19 A
I don't recall whether or not we excluded 20-certain types of equipment which I thought was your 21 question.
22 Q
Do you recall whether during the time period 23.
you were supervisor, the candensates polishing system 24 of TMI-1 was ever inspected by your department?-
L 25 A
I don't recall..
1 Potts 31 (D
U 2
Q During this time period, would your 3
department have had at any time reason to inspect 4
pieces of equipment related to TMI-2 as opposed to
(
5 TMI-1?
6 MR. KIRSCHBAUM:
Objection.
I am not clear 7
as to what you mean by "would have had reason to 8
inspect."
9 Q
Did they inspect?
10 A
I don't recall if we in spe'e t ed items from 11 Unit 2 or not.
12 Q
Do you have any recollection as to any f'%
(ss/
13 practice at that time of your department with respect
]
14 to inspection of equipment which was to be used in 15 TMI-27 16 A
My' recollection is that my organization did 17 not inspect items for TMI-2.
18 Q
was there a similar organiza ion at that 19 time for TMI-27 20 A
Yes, there was.
21 Q
Do you recall whether'or not you as 22 supervisor.had any contact with that'other organization?
23 A
Yes, I did.
24
'Q What kinds of' contacts would you have as a 25 matter of routine?
p-
=,
1 Potts 32
,r 2
A As a matter of routine, that organization was available to provide assistance to me.
3 4
Q what type of assistance?
(
5 A
Certified nondestructive examination 6
testers, advice.
That is the extent of my recollection.
7 MR. KIRSCHBAUM:
Could you read back the 8
last question and answer, please.
9 (Record was read back.)
10 Q
Was the TMI-2 group similakly available to 11 you for such testers or advice during that time period?
12 A
Repeat that question.
/G q..)
13 Q
You indicated that the TMI.
I said that 14 wrong.
15 Was your department, the TMI-1 department, 16 available to the TMI-2 quality control supervisor for 17 similar advice or testers or other assistance?
18 A.
I don't recall that.
19 Q
When your inspectors inspected equipment, 20 what did they use in terms of acceptance criteria?
21 MR. KIRSCHBAUM:
I am not sure what you 22 mean there.
Are you asking the specific 23 criteria, sources from which criteria might have
(%,
.( )
24 been derived?
25 MS. WAGNER:
I am asking what the criteria 1
l
1 Potts 33 O
2 were.
3 MR. KIRSCHBAUM:
Fine.
I didn't understand 4
it that way.
(
5 A
You are asking for specific criteria?
6 Q
Not specific criteria for a specific piece 7
of equipment.
In general, where would they go to get 8
criteria?
Was there a procedure some place they would 9
use or did they have to go back to blueprints?
10 when they inspected, what did they use for 11 acceptance criteria?
12 MR. KIRSCHBAUM:
You first said you 4
\\/
13 understood it one way and from y ur question it 14 appears you understood it the other way.
15 Are you trying to get to the criteria e
16 themselves or the sources?
17 MS. WAGNER:
The criteria themselves.
18 A
I can't recall the criteria [hemselves.-
19 Q
Can you recall the sources for criteria?
20 MR. KIRSCHBAUM:
Any of the sources, all of 21 the sources?
.k 22 MS. WAGNER:
Any or all.
I 23 A
B&W design criteria, Guilbert's Design
[~)-
24 Criteria ~.
~ 25 Q
To the best of your recollection, was-the
- i
Potts 34 1
Ov 2
process that the piece of equipment would be compared 3
to those design criteria just to see if they matched?
4 Is that basically what the process was?
(
5 A-Yes.
6-Q Did the Quality Control Department during 7
this time ever inspect the entire nuclear steam supply 8
system as a unit?
9 MR. KIRSCHBAUM:
At one time?
10 MS. WAGNER:
Yes.
11 A
I don't recall.
12 Q
Do you recall-whether the department O
13 inspected the entire plant of TMI-1 as a unit at one 14 time?
15 A
I don't recall.
16 Q
What were the functions of the Quality II Control Department with respect to the w&rehouse?
18 A
Receipt inspection of materi 1.
19 Q
Can you explain what you mean by that?
20 A
When material'was received by'the warehouse,
-21 it would be inspected to see that-it' conformed to the 22 engineering specifications.
23 Q.
-Similarly, what were the responsibilities
[h j
\\_/
24 of the-Quality Control. Department with' respect to 25 -
maintenance?
i i
1 Potts 35 OV 2
A To randomly inspect the maintenance.
3 Q
Any P ace in the TMI-1 plant?
l 4
A Yes.
(
5 Q
That would include maintenance of the' 6
nuclear steam supply system?
7 A
Yes.
8 Q
For the inspections of maintenance of the 9
nuclear steam supply system, what acceptance criteria 10 were used?
11 THE WITNESS:
Repeat that question for me, 12 Please.
AN]
13 (Record was read back.)
14 A
I don't recall _specifically.
15 Q
Do you recall generally where the 16 acceptance criteria were drawn from?
17 MR. KIRSCHBAUM:
For inspection of the 18 maintenance Of'the nuclear skeam supply 19 MS. WAGNER:
20 system..
21 A
Sources'for inspection criteria would 22 include the vendor's engineering spec and the 23 maintenance procedure itself.
)
' Q During'the time period when you were 24
(
25 supervisor of Quality Control, were there specific
~
1 Potts 36 2
procedures for maintenance of the nuclear steam supply i
3 system?
4 A
Yes.
(
5 Q
Were they called maintenance procedures?
6 A
I can't recall the exact title of those 7
procedures'.
)
8 Q
During the time that you were supervisor 9
of Quality control, did your department have any 10 responsibility for inspection of nucidar instrumentation 11 in the TMI-1 system?
12 A
Yes.
13 Q
Do you recall whether your department had 14 any such responsibilities with respect to the TMI-2 15 instrumentation?
16 A
We did not have that as a scope of our-
- 7 responsibility.
18 Q
Do you recall whether any such activities 19 were undertaken by your department even though it was-20 not within your scope of responsibility?
21 A
I don't recall evez inspecting TMI-2's-22 instrumentation.
. hen you say you don't recall, do you 23 Q
W
(~%
(,)
24 include your department?
25 A
I do include my group or my department.-
4 1
Potts 37 1
~
2 Q
Do you recall whether your department had any participation at all with respect to th e -
.3 4
setting up, designing of the TMI-2 control room?
1
-(
5 A
We did'not.
6 Q
Did you have any such responsibilities, 7
1.e., with respect to the design of the control room 8
for TMI-17 i-9 A
We did not.
10 Q
Do you recall who was supervisor for i
11 Quality control at TMI-2 during the time period when j
12 you were supervisor for TMI-17 I
13 A
I don't. recall.
14 Q
Do you recall who took your position after 15 you-left that particular position, supervisor of 4
t 16 Quality Control?
17 A
Yes.
18 Q
Who was that?
19 A
Mr. Cotter, C-o-t-t-er.
20 Q-Did your department ever have responsibility--
21 I am talking about Quality Control now for TMI-1 -- did
(:
22 you ever haveLresponsibility for inspection of training
- 23
.for TMI-1 reactor operators?
'l
.( )
24 A
.I don't recall if we had'the responsibility.
f25 for: inspecting training or not.
1 1
Potts 38
"'\\ -
(d 2
Q Do you recall if there was anybody else 3
who you think at this time might have had such 4
responsibility?
(
,5 MR. KIRSCHBAUM:
Objection.
You are asking 6
him to recall something or you are asking 7
whether he --
i 8
MS. WAGNER:
Whether he recalls now whether 9
some other department would have had that t
i 10 responsibility.
11 A
I don't recall that.
12 Q
Do you recall whether or not during that O
13 time period inspections of training were performed by 14 anybody?
15 A
I don't recall.
16 Q
Do you recall during the time you were 17 supervisor:of Quality Control, whether your department 18 had any responsibility for radiation monitors in the 19 TMI-1 nuclear steam supply system?
20 MR. KIRSCHBAUM:
Responsibility for 21 inspecting?
22 MS. WAGNER:
Responsibility for inspecting 23 them, yes.
f(,%.)
24 A
I don't recall if _the radiation monitors 25 were in our scopelof responsibility.
1 Potts 39
/%
(_) -
2 Q
Do you recall whether calibration of the radiation monitors was within your scope of 3
4 responsibility?
5 MR. KIRSCHBAUM:
Inspecting calibration?
6 MS. WAGNER:
Inspecting calibration, yes.
7 A
I don't recall.
8 Q
Do you recall whether that was the D
responsibility of any'other department at Metropolitan E
10 Edison during this time period?
11 A
I can't recall.
12 Q
During the period you were supervisor of 13 Quality control, did you hold a license on TMI-17 14 A
- No.
15 Q
Have you ever held a license at either 16 plant at TMI?
17 A
No.
18 Q
Have you ever held a license any place 19' else other than Saxton?
l l
20 A
No.
l 21 Q
Your resume indicates in July of 1976 you k
22 became supervisor of Licensing.
Was that for-23 Metropolitan Edison?
1 24 A
'Yes.
mj 7
L 25 Q
What were your responsibilities in that
1 Potts 40 J(~%
2 job?
A Supervise the licensing efforts of the 3
4 fossil and nuclear licensing group.
(
5 Q
When you speak of licensing efforts, does 6
that include the obtaining.of a license for the plant, 7
the operating license?
8 A
No.
g Q
What does that include?
10 A
It includes the licensing 'ef f orts af ter 11 operation -- after the operating license was issued.
12 Q
I am still not exactly clear.
'~
13 Do you include in that the obtaining of 14 licenses for the reactor operators?
15 A
No, I don't include that.
16 Q
Are you including then only changes to the 17 operating license once it is obtained?
I am talking 18 now about the plant operating license.
19 A
It included changes to the pl'nt operating a
20 license.
21 Q
What else did it include?
22 A
NPDES, EPA, DER, Corps-of Engineers.
I'm 23 not certain that is a complete-list.
I) 24 Q
What is NPDES?
\\v 25 A
National Pollution Discharge Elimination-
~-.
n -
1 Potts 41
/~g.
1
_ V 2
System, or something.
3 Q
What about DER, what is that?
I 4
A Department of Environmental Resources.
(
5 Q
Do you recall which department at i
6 Metropolitan Edison was responsible for getting the P ant operating license?
l 7
8 A-No.
g Q
Was it, in fact, Metropolitan Edison who 10 obtained that license, do you know?
E 11 A
I don't k n o w'.
12 Q
Did your responsibilities include changes 13 to the FSAR of TMI-1 or TMI-27 14 A
No.
15 Q
Do you know who at the. time period 1976 16 to 1979 would be involved in such changes?
By "who,"
17 I mean departmental.
Whowasinvhlvedorwhat?
18 MR.'XIRSCHBAUM:
19 MS. WAGNER:
Who was. involved, yes.
20 A
I don't recall who was involved in such 21 changes.
22-Q' You don't recalliany department which was j!3 involved?
24 -
A I'really don't understand your question 25' is what my difficulty-is.
~
+-
1 Potts 42 2
Q You don't understand changes to the FSAR?
A I understand that.
3 4
Q Can you tell me what you don't understand
(
5 and I will try to clear it up.
6 A
I believe you have included by reference 7
to the earlier questien both TMI-1 and TMI-2 FSAR's.
4 8-Q I have, yes.
g A
That is why I can't answer yet.
10 Q
Start with TMI-1's FSAR.
D,o you know what
-11 departments were involved in the changes there?
12 A
I'm not sure TMI-1's FSAR changes took 13
- place, e
14 Q
Whether or'not you are certain they took 15 place, do you know which department would have had 16 responsibility for such changes or did have such 17 responsibility for such changes?
18 MR. KIRSCHBAUM:
I think you will have to 19 take one or the bther.
The questions up to,now 20 have been who was involved.
Now he testified 21 that he is not sure the changes took place.
22 Obviously, he can't testify who.was involved in 23
.the changes.
[d) 24 MS. WAGNER:
He can testify to his
'u 25 knowledge'as.to who had responsibility for changes
l' Potts 43
(~)
(_/
2 in the FSAR, whether or not he knew changes took l
P ace.
3 4
-MR.
KIRSCHBAUM:
Who had the responsibility
(
5 for effecting changes?
6 MS. WAGNER:
Who had responsibility for 7
being involved in changes.
8 MR. KIRSCHBAUM:
You are asking in terms 9
of the corporate structure, who in the corporate I
E 10 structure, what department had a, responsibility?
11 MS. WAGNER:
Right.
12 MR. KIRSCHBAUM:
From the corporation to be 13 involved?
14 MS. WAGNER:
That's right.
15 MR. KIRSCHBAUM:
And the corporation is e
16 Metropolitan Edison?
17 MS. WAGNER:
I believe he testified that 18 that is who he has been working for, yes, 19 A
The-Licensing Department would be involved
21 Q
.Would the Licensing Department be involved 22 in TMI-2 FSAR changes?
23 A
Yes.
A k_) -
24 Q.
Why did you have trouble with my earlier 25 questioning about TMI-1 and TMI-2 FSAR's if, in fact,
1 Potts 44
. (V.
~
2 they were both in the Licensing Department?
3 MR. KIRSCHBAUM:
I objsct to the question.
4 He had a problem with the question.
I don't 5
beileve it is pertinent as to why he had a 6
problem.
~
7 MS. WAGNER:
Unless I hear the answer, I l
8 don't know whether it is pertinent or not.
9 Are you going to permit him to answer?
E 10 MR. KIRSCHBAUM:
No.
11 Q
Was there any difference in the way TMI-1 l
12 and TMI-2 FSAR's were handled by Metropolitan Edison O
13 during this time period?
14 A
During that time period, there was a change 15 in handling FSAR changes.
16 Q
What was that change?
17 A
When TMI-2 became operational, responsibility 18 for its changes became part of the TMI licensing group's 19 responsibility.
20 Q
Who had the responsibility for it'before 21 TMI-2 became operational?
22 A
GPU Service Corporation.
23 Q
Did GPU Service Corporation draft the first O
,4 FSAR for TMI-27 L./
25 A
I don't know.
=
1 Potts 45 2
Q Do you.know if GPU Service Corporation 3
obtained TMi's operating license?
4
-)UR.
KIRSCHBAUM:
What do you mean by 5
"obtained"?
Put the license in its name, is 6
that what you.mean?
7 MS. WAGNER:
Got one for TMI-2.
8 MR. KIRSCHBAUM:
I am not sure what you mean.
9 I object to.the question as to form.
~o 10 The witness may answer.
11 THE WITNESS:
Please repeat the question.
12 (Record was read back.)
O 13 A
I don't know the answer to your question.
i 14 Q
Do you recall when it was in time..that the 15 Metropolitan Edison Licensing Department,became 16 responsible for the TMI-2 FSAR and/or changes to that?
I 17 Was it during the time period that you were supervisor?
18 That is my question.
19 A
Yes.
20 Q
But you have no recollection of how the FSAR 21 got into whatever stage it was in before the Licensing
~
t 22
-Department took over control of it?
23 MR. KIRSCHBAUM:
Repeat the question.
- /\\
- 1
(_,/
24 MS. WAGNER:
'I will rephrase it.
25
- Q What was the administrative procedure by-y e
y*
.ww
--w---.-
.wi V -
,y
,y
---r
1 Potts 46 2
which the Licensing Department became responsible for the TMI-2 FSAR?
3 4
A I don't recall the procedure how we became
(
responsible.
5 6
MR. KIRSCHBAUM:
When you say " responsible 7
for the FSAR," you mean responsible for the 8
changes in the FSAR?
9 MS. WAGNER:
I believe he testified that 10 Licensing was responsible for th% FSAR for whatever 11 had to be done for it which I assume were changes
~g 12 at this point.
_]
13 Q
What activities did the Licensing Department 14 undertake with respect to the TMI-2 FSAR, if any, after 15 the time that the Licensing Department became. responsible 16 for it?
17 THE WITNESS:
Can you repeat that for me.
18 (Record was read back.)
19 A
I don't recall.
~
20 Q
Did you ever read the TMI-2 FSAR?
f 91 MR. KIRSCHBAUM:
The entire FSAR?
22 MS. WAGNER:
Yes.
23 A
I don't recall.
(~
(_j) 24 Q
Do~you recall whether you have ever read 25 any part of it?
1 Potts 47 f
2 A
Yes.
3 Q
Do you recall for what purpose you read any 4
of it?
5 A
I don't recall the purpose for reading it.
G Q
Did you ever read the section of the FSAR 7
'which concerns design basis" accidents?
This is the 8
TMI-2 FSAR.
9 A
I don't recall.
e 10 Q
Do you recall what portions you did read?
11 A
I recall having read parts of.the TMI-2 12 technical specification.
13 Q
Do you recall which. parts?
14 A
No.
15 Q
Do you recall why you read that, parts of 16 the technical specification?
17 MR. KIRSCHBAUM:
Are all thede-questions 18 relating to the period '76 through January 19797 19 MS. WAGNER:
Yes, they are.
20 A
one of the reasons I read parts of TMI-2 21
. technical specifications was because we were in the 22 process of drafting a TMI-1 technical specification in 23 the same format as TMI-2, that is the standard technical
~
I x_/
24 specification format.
1 25 Q
Had'you been involved in any capacity in 1
1 Potts 48 2
drafting the standard technical speci,fications for TMI-27 3
A No.
4 Q
But the technical specifications in the FSAR
(
5 for TMI-2 at the time that you became cognizant of the 6
technical specifications were in the standard technical l
7 specification format, is that correct?
8 A
Yes.
9 Q
What exactly are the standard technical 10 specifications?
11 A
It's a format that the NRC has prepared, 12 issued and require technical U
specificayions to be 13 prepared.
i 14 Q
Do you recall when this requirement came 1
15 into being?
16 A
No.
II
-Q Is there a difference between the standard
{
18 technical specifications and the technical 4
j 19 specifications which were at TMI-1 during this time 9
20 period?
'21 A
Yes.
22 Q
Is the difference one simply of format f
l j.
23 or are-there substantive differences as well?
I ' ['i
(,)
24 MR. KIRSCHBAUM:
I think he said the 25 standard technical specifications were a format.
1 Potts 49
/~
(_)T l
2 Q
Is that all they were, just a format, or l
i 3
",a s there any substantive difference, is my question, 1
4 in the technical specifications?
(
5 A
I don't recall.
6 Q
You don't recall whether there was any 7
substantive difference?
8 A
That's correct.
9 Q
Did you ever have any understanding from 10 any source as to why the NRC requiredtthe standard 11 technical specification format?
12 A
I don't recall why the NRC required that.
(~%
\\~
13 MR. KIRSCHBAUM:
When you use the word 14 "ever," again I assume July 1976 through January 15
'797 16 MS. WAGNER:
My question was broader.
I 17 meant at any time did he have an understanding
'8h.
18 between 1960 and 1980 or '81 or 19 A
The answer would be the same.' I don't know 20 why the NRC required that format.
21 Q
Was the Licensing Department during the 22 time when you were supervisor responcible for.
Z3 compliance with 10 CFR Part 217 I
)
24 THE WITNESS:
Repeat the question.
"Q/
25-(Record was read back.)
l 1
Potts 50 2
A I don't recall.
3 ftR. KIRSCHDAUM:
Let me get a clarification 4
and then you can answer again.
+
1
(
5 Are you talking about seeing to it that 6
the forms required by Part 21 were filed?
4 7
MS. WAGNER:
I am talking about any aspect i
8 of compliance with 10 CFR Part 21.
9 Why don't we just establish a basis.
10 Q
Do you know what 10 CFR Pdrt 21 is?
11 A
Yes.
12 Q
What is it?
(
~
13 A
A regulation issued by the NRC requiring
.14 reporting of defects to the NRC.
15 Q
To the best of your recollection, was 1
16 10 CPR Part 21 in effect during the time you were l
l 17 supervisor of Licensing?
18 A
Yes.
19 Q
Do you' recall which, 1f any, department 20 at Met Ed had responsibility for making sure that 21 whatever Part 21 required was done?
I j!2 THE WITNESS:
Repeat that for me, please.
i i
l l
oj (Record was-read back.)
24 A
No.
l 25 Q
You do not' recall?
-i
1 i
i Potts
~
51
(
,i
.g A
I don't recall.
1
/
3 MR. KIRSCHBAUM:
I would like to take a i
4 break now.
3
-/'1
(
.[
5 MS. WAGNER:
0.K.
s s
6 (Recess taken.)
+
'i i
I 1
i 7
MR. KIRSCHBAUM:
May I,have the it,s t questior s
8 and answer, please.
j l
1 ' \\
B 9
(Record was read back.1 t i 10 BY MS. WAGNER:
1,
\\
11 Q
Is it correct that you c'urrently have a job
./
12 at TMI-17
..$ (
13 A
Yes.
\\.,j, t
i
/
1 14 Q
Do you know if 10.CFR'Ptrt A1.is st.ill in s
i 4
15 effect today?
. 4f 16 A
Yes.
) N '[,.
b
1-J.\\
v/
is, '.if anybody, ;l. /)' ',s 3
1 17 Q
Do you know today who it I
f,,
'c j.
's 18 I mean a department, at Met'Ed~has responsibility, for
.\\
i l
ls insuring that whatever it is 10 CFR Part 21 requir,es 4
., e
_i 20 is, in fact, done by MutfEd?
.[f ^
+-t 21 MR. KIRSCHNER:
By "respo si il'i ty, " are'you 1*
22 saying sole responsibility or Ihey have anyl role s
()
y t
b 23 to play?
i
~
m
.c 24 MS. WAGNER:
Any responsibility.
l-s
~,
f e,
25 MR. KIRSCHNER:
I.?wa s n ' t;,s ure that we."s
<.i:
3r c
.s
?
~
'~
i
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1 Potts 52 (k
u 2
clear in the prior question.
3 A
I know what my responsibility under 21 is 4
and my present department's responsibility and I know
(,
5 what the Licensing Department responsibility was.
4 6
Q What was the Licensing Department's 1
7 responsibility?
8 A
We were responsible for filing the reports 9
to the NRC under Part 21.
10 Q
Did you have such responsi'bility between 11
'76 and '797 By "you,"
I mean your department.
g4 12 A
Yes.
N_
13 Q
Do you recall whether you filed any such 14 reports during that time period?
4 15 A
I don't remember if we filed a Part 21 r
16 report, or reports, or not.
17 Q
Do you know whether for t'h*-time period 4
18 there was any procedure at Metropolitan Loison for 19t compliance with 10 CFR Part 217 A
'Yes.
20
~
21 Q
where was that procedure?
'A 22 MR. KIRSCHBAUM:
Where was it physically
</
./
23 located?
.i s
Y f't
.- ;( j 24 MS. WAGNER:
Yes.
Q There were a number of locations for that 25 l;.
- .r y 4 y, ;
/
3.
}
1 Potts 53
' O 2
procedure.
3 Q
Was it located within any body of documents 4
like administrative procedures or some other group of
(,
5 procedures?
6 A
I don't recall a specific location or 7
locations.
8 MR. KIRSCHBAUM:
I just want to point out 9
my problem with the question was physical' location 10 meaning in some building, in som'e file cabinet 11 and the next question was where was it located 12 within the company procedures.
l 13 MS. WAGNER:
I changed the question.
14 Q
During the time period 1976 to 1979, were 15 you aware of where a copy of that procedure was?
16 A
Yes.
17 Q
Where was it at that time either physically 18 or in any way that you can describe where the procedure 19 was?
20 MR. KIRSCHBAUM:
You are asking if he 21 knows now where it was?
22 MS. WAGNER:
He just testified that he knew 23 where it was.
(
24 MR.,KIRSCHBAUM:
He testified that he knew 25 then where it was.
Potts 54
(
\\
Q Where was it?
A I knew then where it was.
I don't recall now.
4
(
Q Do you know now where it is?
A No.
Q You have no idea where I might be able to 7
fi d a copy of that procedure, I take it?
8 MR. KIRSCHBAUM:
Objection as to form.
"Y u have no idea now" is very broad.
I am sure 10 he could suggest a number of locations.
That w uld be surmise and not testimony.
12 You may answer to' the extent that you can.
A I don't recall its location, no idea.
I j st don't know how to answer.
15 Q
Do you recall whether the procedure had a 16 name between 1976 and 1979?
I.
s A
No.
18 Q
Do you recall whether it was p' art of the gg body of administrative procedures?
20 A
No.
k
~
Q D
y u re all whether the Licensing 22 Department had any method between 1976 and 1979 for 3
(v) insuring that compliance with Part 21 was carri.ed out?
, 4 MR. KIRSCHBAUM:
Do you mean the compliance 25
1 Potts 55 O
2 insofar as its role was concerned?
3
'MS.
WAGNER:
Yes.
4 A
Yes.
(
5 Q
What was that method?
6 A
The action item system.
7 Q
could you describe that system for me, 8
please?
9 A
The action item system was an automated 10 information system that controlled due. dates.
11 Q
Due dates on what?
I 12 A
on either regulac'ory items or vendor-produced O
13 items.
I4 Q
Was the action item system something used 15 solely by Licensing?
16 A
No.
17 Q
Was it used by other departments at Met Ed?
18 A
Yes.
19 Q
Which other departments if you can recall?
20 MR. KIRSCHBAUM:
Are you referring to the 21 action item system at Licensing, whether it was 22 used by other departments?
23 MS. WAGNER:
He said the action item system 24 was used by other departments.
I am asking which 25 other departments.
f 1
Potts 56 2
MR. KIRSCHBAUM:
I am trying to clarify 3
whether you are referring to the action item 4
system used at Licensing.
l 5
MS. WAGNER:
Whatever he is. talking about.
6 MR. KIRSCHBAUM:
The existence of which 7
he has testified to?
4 8
MS. WAGNER:
That's correct.
9 A
The action item system was available for 1
10 use by anybody within the Met Ed systdm.
11 Q
How did something get into the action item 12 system?
~
13 A
An action item for was fille'd out.
14 Q
Did every department at Met Ed have access i
15 to the action item forms, do you know?
e v
16 A
I don't know if every department had access 17 to them.
18 Q
What did the. form look like?
a
~
i 19 A
It was a form of pressure sensitive paper q
,i 20 and had various blocks to be filled out.
i i
21.
Q Do you know if there was a uniform action k
22 item form which was used by departments other than --
23 I mean by.various departments or were there specific
()
24 forms used by specific departments?
25 A
The action item system I'm talking about t
_ ~.
1 Potts 57 2
had a form for its use.
3 Q
To the best of your recollection, once a 4
form was filled out, what would happen to it physically?
(
5 A
I don't know the entire set of details.
6 It was a computer driven system, input to the computer 7
and printout.
8 Q
I take it from your answers that the input 9
to the computer was coming from Licensing and other 10 departments, is that correct?
t 11 A
That's correct.
12 Q
What types of information would be recorded l O 13 on an action item form?
)
14 MR. KIRSCHBAUM:
Are you asking what types 15 were or if there was any practice?
16 MS. WAGNER:
What types were.
17 A
Any regulatory body ~who sent,to Met Ed
~
18 correspondence requiring an answer, any vendor that
?
19 provided us information that required action, any 20 permit due dates such as a renewal date for a permit.
21 Q
Is that it?
22 A
I can't testify that that's the total but 23 that's what I recall.
()
24 Q
Is it correct to say then that the. action-25 item system, to the best of your recollection, was f
- ~,
1 Potts 58 r^g O
2 related to regulatory matters alone?
A It war not restricted to regulatory matters 3
4 alone.
k 5
9 Can you give me an example of something 6
that would have been part of that system which would 7
not have been a regulatory matter?
8 MR. KIRSCHBAUM:
I am not sure what you 9
mean by " regulatory matter."
Do you mean 10 notification from a regulatory a'gency or are you 11 referring to anything that might have regulatory 12 ramifications?
O 13 MS. WAGNER:
Anything that would require some 14 kind of communication to a regulatory body of 15 some kind.
16 MR. KIRSCHBAUM:
Anywhere along the line?
17 MS. WAGNER:
Right.
18 MR. KIRSCHBAUM:
Read back t e question, 19 Please.
20 (Record was read back.)
21 A
An example would be correspondence from 22 a vendor, perhaps B&W who asked a question, suggested i
23 something, recommended something and required action.
24 Q
Was the method by which Licensing would 25 respond or would perform its duties with respect to l
~
I
^
1 Potts 59
/"'S i
I v.
2 10 CFR Part 21, part of this action item system?
j MR. KIRSCHBAUM:
I don't understand the 3
4 question.
I will object to it as to form.
5 Q
Was the action item system used by Licensing 6
with respect to its responsibilities under 10 CFR Part 7
217 8
A I don't recall if it was used or not.
9 Q
Does the action item system still exist 10 today?
11 A
I don't know.
12 Q
Do you use it today?
f.(
13 A
No.
14 Q
Durin'g the time that you were familiar with 15 the action item system, what kind of information came 16 to you from the computer and how did it work?
17 Once you fed into it, what information came 18 out to Licensing?
How was it used in Licensing?
19 A
' We' received a printout that listed-the actiort 20 item, the.pr.rty and the due date.
21 Q.
Would you get a printout of action items 22 for anybody in the company who was using the action item 23 system or was it just Licensing action items.for which h)
~
(
24 you would get a printout?
25 MR. KIRSCHBAUM:
I don't understand the
1 Potts 60 2
question again because the action iten system I believe he testified was a Licensing Department 3
4 system that others
(
5 MS. WAGNER:
He didn't testify to that I 6
don't believe.
7 Q
My understanding is this was a system used 8
by Licensing among others, is that correct?
9 A
That's correct.
10 Q
When you get a printout oftit, are you 11 getting a printout only of your Licensing use of that 12 system or a printout which includea other people's use 13 of the system?
14 A
The printout I recall included those items 15 I was responsible for.
e 16 Q
When you say that you were responsible, 17 are you referring to yourself personally.or to your 18 department?
19 A
The department.
20 Q
During the time period 1976 to 1979, did 21 it ever occur that somebody in the company outside of
- 22 Licensing perceived that some issue was reportable under 23 Part 21?
A
- (v)-
24 MR.cKIRSCHBAUM:
Are you asking whether he 25 recalls gaining information at that time that o
Y w
~
---"t 9
1 Potts 61 O
2 somebody had perceived such an instance?
3 EMS. WAGNER:
Right.
4 A-I don't recall.
l 5
Q Do you recall whether there was any 4
6 methodology in place at that time whereby if somebody 7
had had such a perception, there would be a particular 8
path along which he would pass this information?
9 A
Yes.
10 Q
What was the system?
11 A
That was the procedure.
12 Q
The procedure that you have already 13 discussed?
l 14 A
Yes.
15 Q
Do you remember what exactly the procedure 16 required?
17 A
No.
18 Q
Was the procedure something which was 19 familiar to all Metropo'litan Edison employees?
20 MR._KIRSCHBAUM:
Objection,as to form.
-How 21 can he testify as to what all Met Ed employees were 22 familiar with?
23 Q
Did Licensing have any knowledge as to i
(jT 24 '
whether all Met Ed employees were familiar with this 25 procedure?
6
-9
, + -
--g
1 Potts 62 0
2 MR. KIRSCHBAUM:
Objection.
3 Q
- You may answer the question, I believe.
4 MR. KIRSCHBAUM:
You may answer if you can.
(
5 A
Id n't know.
6 Q
Was there anybody in the Licensing Department 7
who was particularly responsible for Part 21 during '76 8
to '797 g
MR. KIRSCHBAUM:
What do you mean by E
10 "Particularly responsible"?
11 MS. WAGNER:
Did that more than e her 12 PeoP e did.
l 13 MR. KIRSCHBAUM:
Other people in Licensing?
4 14 MS. WAGNER:
Yes.
15 A
No.
4 16 Q
Who was in the Licensing Department between 17 1976 and 19797 18 A
I don't remember all of the eople that 19 were in that department in that period of time.
20 Q
Do you remember roughly how many people 21 were in the department?
22 A
Yes.
23 Q
How many?
(m) 24 A
Somewhere between six and ten.
25 Q
Can you give me a few names?-
1 otts 63
~%.
2 A
Courtney Smythe, Roy Harding, Roan Stevens, 3
Dave Mitchell, Erick Nielsen, Jerry Masters.
4 Q
Were all of those people involved in both
(
5 nuclear and fossil licensing issues or were they split 6
between nuclear and fossil?
7 A
I believe you have asked me two questions.
8 Repeat the question, please.
9 Q
Was there any split in your department 10 between licensing for nuclear matters gnd licensing 11 for fossil matters?
12 A
Yes.
13 Q
Who were the people involved in nuclear?
14 A
Courtney Smytle, Roan Stevens, Roy Har' ding.
15 Q
Were you supervisor of those people?
16 A
Yes.
17 Q
Did they have any other supervisor for 18 nuclear matters, any other immediate supervisor?
19 A
No.
20 Q
Who was your supervisor at that time?
21 A
Manager of Quality Assurance.
22 Q
Who was manager of Quality-Assurance?
23 A
During that time period, there were two
~ O) 24 managers of Quality Assurance.
One was Mr. Lawyer and
.ss.
25 another was-Mr. Troffer.
9 y
a w
n v
1 Potts 64 2
Q During the period that you were supervisor 3
of Licensing, where were you physically located?
Was 4
it at TMI or Reading?
f 5
A At Reading.
6 Q
Were Mr. Lawyer and Mr. Troffer also located 7
at Reading during this time period?
4 8
A Yes.
i 9
Q Where were the Licensing Department 10 employees whom you just described, the', nuclear employees, 11 located?
12 A.
At Reading.
13 Q
When you were supervisor f.or Quality control 14 for TMI-1, where were you located?
15 A
At TMI.
e 16-Q During the period when you were supervisor-i 17 of Quality control, did you maintain any personal files?
18 A
No.
19 Q
Did you maintain 'depar-tmental files?
Were 20 you responsible for their maintenance?
21 A
only insofar as '
pervised the people 22 who were responsible for.
aing those files.
23 Q
Did you atLtha have a correspondence
-fg y,/
24 or chronological file,'a persona 11 file?
25 A
Not a personal file, w
e y
m a
n
.m y
1 Potts 65 7._
k.
2 Q
Was there a departmental file?
3 A
Yes.
4 Q
I take it you are no longer in custody of
(
5 that file?
6 A
That's correct.
7 Q
During the time period you were supervisor 8
of Licensing, did you maintain any personal files?
9 A
No.
10 Q
Did you maintain any deparlmental files?
11 MR. KIRSCHBAUM:
Personally?
12 MS. WAGNER:
Departmental.
O 13 MR. KIRSCHBAUM':
Did he pe,rsonally maintain i
14 departmental files?
15 MS. WAGNER:
Right.
16 A
No, I did not personally maintain departmental 17 files.
18 Q
Were there departmental files?
19 A
Yes.
20 Q
Wh'at kinds of files were they?
21 MR. KIRSCHBAUM:
Are you asking for what 22 subjects were covered in the files or how they 23 were set up, what topics?
( ).
24 MS.' WAGNER:
What' topics were listed.
25 A
I don't recall topics of the file.
$h N w
M
1 Potts 66 (s
2 Q
For example, was there a chronological file for the' department?
3 4
A I just don't remember.
f 5
Q Did you ever write any letters?
6 A
Yes.
7 Q
Do you know what happened to copies of those 8
letters?
9 A
They were filed.
A copy was filed.
10 Q
Did you receive letters?
11 A
Yes.
l l
12 Q
And they were filed, also?
l 13 A
Yes.
14 Q
Do you have any recollection as to how they 15 were filed?
16 MR. KIRSCHBAUM:
As to what?
l 17 MS. WAGNER:
Subject matter, thronological 18 that he either forwarded or received.
19 A
There was a filing system, but I don't recall 20 very much about that filing system.
21 Q
Who would know about it?
22 A
I don't know who to tell you to see.
23 MR. KIRSCHBAUM:
That wasn't the question.
/G
()
24 The question is who would know about the maintaining.
25 of the files.
Not who you would tell her to see.
1 Potts 67 i\\)
2 THE WITNESS:
Who would know would be the 3
group that was responsible for the filing.
4 Q
The group within Licensing?
l 5
A No.
6 Q
There were no separate files for the 7
Licensing Department?
8 MR. KIRSCHBAUM:
Your question, I take it, 9
is directed to who would know or who knew at that 10 time as to how the files were sey up?
11 MS, WAGNER:
Right.
How the Licensing files 12 are set up.
()
13 A
The "who" is a problem.
I don't remember 14 who that was.
15 Q
Do you remember whether the "who" was in the 16 Licensing Department?
17 A
No.
18 Q
Do you recall ever having a need when you 19 were supervisor of Licensing to review a piece of paper 20 which you had sent.to the' files?
21 A
Yes.
22 Q
Do you recall how you would obtain that 23 piece of paper during that. time period?
(mi 24 A
.I would ask my secretary for it.
. x,) -
25 Q
What was your secretary's name during that
Potts 68 O
time period?
2 A
Toby Stanislaw.
3 Q
Do you know whether your secretary is still employed in the Licensing Department, if that person
(
5 is still employed in the Licensing Department'i A
She is not employed in the Licensing Department.
Q In January of 1979 you became superintendent for Technical Support for TMI' Unit 1,
s that correct?
A Yes.
11 Q
What did that job enrail?
A Supervision of the engine [ ring group at 13 e
TMI Unit 1.
Q here were you physically located for that 15 16 A
TMI-1.
1 4 Q
How many people were in the sngineering 18
' group?
A Approximately eight to ten.
20 Q
What kinds of things was the engineering 21 group at TMI Unit 1 doing?
22 A
The major effort that I recall was in the 23 refueling -- preparing for the refueling of TMI Unit--1, 25-Q hat, genera 11y' speaking, is the role.of the
1 Potts 69
[)
r V.
2 engineer or was the role of the TMI-1 engineer with 3
respect to refueling?
4 A
Planning refueling, providing engineering 5
support for the maintenance.
6 Q
Maintenance of the plant?
7 A
Yes.
8 Q
When did the refueling occur or when was it 9
supposed to occur?
10 A
It occurred in late Februaky of 1979.
11 Q
What kinds of things were the engineers 12 involved in after the time of refueling during the year Cn l
13 that you were superintendent for Technical Support?
14 Actually, I should ask what were they involved in between 15 late February and March, I guess.
e 16 MR. KIRSCHBAUM:
What is the question?
17 MS. WAGNER:
Late February and March, after 18 refueling but before the TMI accident.
19 A
The refueling was the major effort during 20 that period.
21 Q
Is the engineering group at TMI-1 or.was it, 22 I should say, a permanent group at TMI-1 prior to the 23 accident or was the group there solely to'do the
/~'N
! Q 24 refueling function?
t
_ 25 A
No, it was a permanent group.
w
1 Potts 70 2
Q Did you have any understanding at that time f any f the other kinds of activities that that group 3
4 eng ag ed in aside from refueling?
l 5
Yes.
~
6 MR. KIRSCHBAUM:
"At that time" being 7
MS, WAGNER:
At the time he was TMI Technical 8
Support superintendent.
9 MR. KIRSCHBAUM:
Or at any time while he 10 was TMI Technical Support superihtendent?
11 MS. WAGNER:
What other kinds of activities 12 did they get involved with.
-r 13 A
Outside of the refueling,,they would get 14 involved in providing technical assistance for 15 maintenance that occurred,-procedure review.
I can't t
16 provide you with a complete list at this time.
17 Q
When a trip occurred at TMI-1, was it no rmal 18 procedure for engineers to become involv d in any 19 analysis of that trip?
20 MR..KIRSCHBAUM:
Are you asking about 21 whether a trip occurred between any particular 22 period or a company procedure or practice?
i 23 MS. WAGNER:
A procedure.
If.the engineers
'{
(~%
)
24 had a role when a trip occurred.
t
~
25 MR. KIRSCHBAUM:
Unless you are asking.about' j
1 Potts 71 2
whether there was a practice, I would suggest --
3 MS. WAGNER:
A practice.
4 MR. KIRSCHBAUM:
Regardless of whether one
{
5 occurred?
6 MS. WAGNER:
Right.
7 A
I don't recall the practice for trip 8
reviews.
9 Q
Was there any practice with respect to the 10 engineer's role in transient review?
11 MR. KIRSCHBAUM:
Again, are you asking 12 before the accident?
'i 13 MS. WAGNhR:
Before the accident.
14 MR. KIRSCHBAUM:
I would appreciate if you 15 make that clear.
e 16 MS. WAGNER:
All of my questions will be l
17 before the accident unless I specifically say 18 they are after the accident.
19 A
I don't remember.
20 Q
Do you remember whether you pe sonally 21 ever became involved in any transient review during'your 22 time as superintendent of Technical Support'aad before j
23.
the accident at TMI-27 O)J
(_
24 A
During my tenure as superintendent of 25'
' Technical _ Support, there were, to the best of my w
n
-w,
1 Potts 72 2
recollection, no transients to review.
3 Q
'Who took your position as supervisor of 4
Licensing when you left?
(
5 A
Mr. Hilbish.
6 Q
In December of 1979 you became manager of 7
Radiological Controls for TMI-1, is that correct?
8 A
Yes.
9 Q
Do you know who took your role as 10 superintendent of Technical Support fo'k Unit 17 11 A
No.
12 Q
Who did you report to as Technical support 13 superintendent?
a 14 A
.The unit superintendent.
15 Q
Who was that?
16 A
Mr. Seelinger.
17 Q
who do you report to today as manager of 18 Radiological Controls?
19 A
The director of Radiological and 20 Environmental Controls.
21 Q
Who is that?
22 A--
Mr. Heward.
23 Q
During the period you were superintendent
- (^)N q,.
24 for Technical ~ Support, at any. time during that period,
~
25 before or after the accident, did you maintain any g
m
+
w w
1 Potts 73 O
v 2
personal files?
3 A
No.
4 Q
Did you maintain personally any departmental l
5 files?
6 A
No.
7 Q
Were there any departmental files?
8 MR. KIRSCHBAUM:
Any departmental files for 9
what department?
t 10 MS. WAGNER:
I don't know.* That'is why I am 11 asking the question.
12 MR. KIRSCHBAUM:
Well, I mean --
13 Q
Were there any files which-you used during 14 that time period?
15 A
The time period again, please?
16' Q
1979, the whole year.
17
~
A I don't recall.
18 Q
Do you recall whether you wr te or received 19 any letters during that year?
20 A
Yes.
21 Q
Do you know if they were filed any place?
1 22 A
I don't recall.
23 Q
Do you recall whether you used to throw s
\\
24 them in the wastebasket?
l 25-MR. KIRSCHBAUM:
Objection.
Potts 74
[
'd A
I did not throw my memos in the 2
wastebasket.
3 Q
Do you believe they Jiled up on your desk i
or do you think they went some place?
(
A I believe --
6 MR. KIRSCHBAUM:
Objection.
A I believe they were distributed to the 8
addressees.
9 Q
what if you were the only pddressee?
g MR. KIRSCHBAUM:
Then what?
MS. WAGNER:
What happened to the letter 12 after he read it or the communi[ation, whatever it was.
A You apparently are talking about memos I e
received and not memos I wrote.
6 The memos I received would be either sent to one of my subgroups, if sction was reciuire d, or if 18 it was strictly information, it would be put in the g
garbage.
Q Which subgroups were in existence during 21 l
this time period to which some of your correspondence y
1 might have gone?
A There was a nuclear engineering group, an instrument control engineering group, electrical g.
1 Potta 75 2
engineering group and mechanical engineering group.
3 Q
Do you recall whether copies of letters or 4
other communications which you sent out were maintained
(
5 any place?
6 A
No.
7 Q
Did you have an office as superintendent of 8
Technical Support?
9
- A Yes.
10 Q
Did you have a library, bob,k shelves?
11 A
I had several books.
I did not have a 12 library in my use of the word " library."
13 Q
Did you have any pieces of, paper in~that 14 office besides the books?
15 A
Yes.
16 Q
What other pieces of paper did you have in 17 your office?
I am talking about pieces of paper relating 18 to your job.
19 MR. KIRSCHBAUM:
At any given time?
20 MS, WAGNER:
Yes.
At any-given time in 1979, 21 A
I recall I had a copy of the technical 22 specifications, the FSAR.
I'm not certain what more you
-23 need.
A(,)
-24
.Q Anything else you might have that you can 25 remember at this. point?
i
1 Potts 76 O
2 A
Normal office supplies.
I'm sure you are 3
exempting such things as dictionaries and things like 4
that.
(
5 Q
Did you ever receive a request from anybody 6
to produc e documents for this litigation?
7 A
Yes.
8 Q
Did you respond to that request?
9 A
Yes.
10 Q
Did you produc e any docume'nts?
11 A
No.
12 Q
Is that because they were not in your O
13 possession?
14 A
Yes.
15 Q
Have you ever previously given any testimony e
16 in any context?
17 MR. KIRSCHBAUM:
Could you define 18
" testimony"?
19 Q
Have you ever given any sworn testimony 20 before a court reporter about anything, in any context?
21 A
I have testified with a court reporter and 22 under oath.
23 Q
Can you tell me in what context?
)
24 A
I've testified at the TMI-1 restart hearings.
25.
I've testified at.several~ fossil plant licensing
_n l
1 Potts 77 2
hearings.
3 Q
Have you ever testified with a court 4
reporter present but not under oath?
{
5 A
I don't recall that.
6 Q
Have you ever given any 1,nterviews to any 7
investigatory body which interviews were transcribed in 8
some fashion?
9 A
Yes.
10 Q
Can you tell me about those?
11 MR. KIRSCHBAUM:
What about those?
12 Q
When did you give them?
O
13 A
I don't remember the date.
I 14 Q
Do you remember generally what year?
15 A
It was subsequent to the TMI-2 accident.
16 I believe it was in
'79.
17 Q
Do you recall to whom you gaye these 18 interviews?
19 A
The NRC.
~
20 Q
How many where there?
21 A
Two.
22 Q
When you received a license at the Saxton 23 nuclear plant, what kind of training did you undergo
[d) 24 to.obtain the license?
i i
25 A
The training I undertook to obtain that-l l
~
e V
~
1 Potts 78
.T Q
2, license was on my own.
Q Can you remember what you did?
3-4 1
s.
' \\\\
4 4
A Studied plant description and technical sl 5
specifications.
As I said earlier, performed aeveral l
6 startups.
7 Q
Were the startups on the reactor itself?
8 A
Yes.
I spent time discussing the plant s
1 g
and its operation with several supervisors.
10 Q
Can you recall the names n6,w of any 11 supervisors?
12 A
Are you speaking about Saxton?
O 13 0
Yes.
14 A
Jack Herbein.
15 Q
Did you ever take an examination administered t
g 16 by the Nuclear Reactor Commisciof or the Atomic Energy s -
t 17 Commission?
E, s +
s,
+t i
,[\\
18 A
Yes.
19 Q
That was for the Saxton licenhe?
x 20 A
Yes.
21 Q
I take it you passed?
s-22 A
Yes, I did.
s' s
i.
' t. 23 Q
Did you use any textbooks ~at all'from which v.
4 M ; ',m D % ).
time p)riod?
d (
4.g
.to' train yourself during this
~
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- N A
I can?t recall.
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- Potts, 79 f
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er
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2 Q
Did yoti over u.:Jeygo anystrai'ning during,
.i a t
/
3 your tenure at Three Mile Island,a*g..,d, working for a
c
/
I 4
Metropolitan Edinon, training 1for/ reacto/,, opera ; ion?
4
,/
j g
(
5' A
I was trained on'the B&W simulator.
/
f i
~
6 Q
That wasithe onlyftraining you t,eceived'?'
bl u
t l
L',
s t
/...
7 A
For operations, ya e.
a i
1 j
[
8 Q
Why were you, /if ' you kncW, why were you 1
,b p
receiving training on'the si:aulator?
7 l
~d 8
}
10 A
I don't know.),
I ' don ' t r e c'a ll..'
s..
.f-
_, []
't
'j 11 Q
Do you recall when that was?
~
4; 12 A
Sometime in 1972.;
-e s
x-
. c, y
13 Q
,Was tl hat; part of. any praEram at Metropolitan m
./
- f 14 Edison or whs'it.j'st'--
u y.
,1
'N 15 MR.'KIRSCHBAUM:
Was.what part of anyt 16 progran?.
Qr ~ ~
)
17 3 MG. WAGNER:
The B&W, training.
~
q
/,
/
s
~j 18 A
I d o n ' t' '.T e c a ll.
v Whataoth,'5er kin'ds of t'. raining" ', nave. you h ad.
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19
,Q
=
- s n
m.
e g'
q q.
20 during yo'U,r t enu:.e
'; -i cf.;<g/Me tropoli t.an Edison,11f4cny?t at
.i
,,g ;3
,s
,..-t
,,y j\\
c 21 A
Ma. nager, De're30pment School, a : cotirs e on s
?
t z
22 co:nsunicat-ionsistwo courses,on qdality sontrol.
f,
</ 1
.7 c
l j.
y g.
o >
- - l 23 Q
Who administe(c( ths7 courses /on, quality S
.,?
e m
24
' control?
hf i J
b
., ; 3 reme:: pe$y,/e '<:omp*sny 's S
.s Ei Y
25
,A I 'd o n.'. t name.
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.1 Potts 80 y
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3
- 1. y,'
2s Q
It was an outside vendor?
s
.g.
1 f)'
3 A
Yes.
)
4 Q
I'm sorry, I interrupted you.
Were you
(
5' going to say something else about your training?
f m
v'
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i J
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~
No.
I-6 j' ;
t-
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7
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Q~
During your tenure at Met Ed, did you ever
>c j
. u
<r 8
receive any training from any source in nuclear 1-i y,
engineering?
j -
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l
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/
i 7/
10
/
A No.
E F.
".i l; <-
~
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.i.i i
l l ', / ' ~ ' '
fil Q
Did you receive any training in physics?
, -f j y:
- '.(:1
- j
- a...
f-1 1
12 A
No.
T' h,
d (.:!
l,
},
5 N.
1.:
13 Q
Did you receive any training other than
)
s I
'i [I~
14 the B&W training in any aspect of the operation of a
~'
t 15 t,uclear power plant?
....g s
e 16 '.
A No.
t u.
..r.
~.' /1f. '
Q Was the Licensing Department.ever responsible
)
u)<
.N -
c}!} i (during-the time that you were supervisor for t ri
< b; 4,
.3 19
. administering any training to reactor operators?
i
-f
'20 A
No.
+
.-c v
sj j
/
- [,,
21(
Q Was the Licensing Department-in any way 7
l Vf -
.c
![
32'
, involved in auditing,-for example, training given to
];@j#r" w
^-
l23 '-
t reactor operators?
w u~
l
?
L24 A
No.
- w.,
-#y W
+
u'
- 25 Q:
I believe you-testified'previously -- I
.t-
'1
~.
, _ x m
"$.~,
+..... - -. -,
- ~ ~ -
,,. f
4 1
Potts 81 2
just want to make sure I understood -- the Licensing 3
Department didn't play any role in the licensing of 4
reactor operators?
(
5 A
That's correct.
6 MS. WAGNER:
Excuse me a second.
I have a 7
Phone call.
8 MR. KIRSCHBAUM:
Let's take a short break.
i" (Recess taken.)
9 10 BY MS, WAGNER:
E 11 Q
Do you recall whether in the time that you 12 were involved in the Licensing Department, there was ever O~
.c 13 a time when you or anybody within the Licensing 14 Department tried to obtain or did obtain from either 15 utilities or the NRC any clarifications or explanations e
16 of the requirements of Part 21, 10 CFR Part 21?
17 A
I don't recall requesting clarifications.
18 MR. KIRSCHBAUM:
I think the question was 19 obtaining and not requesting, right?
20 MS. WAGNER:
Requesting or obtaining.
21 Q
Did you obtain it somehow, even though you L
22 didn't request it?
23 A
I don't recall that either.
('a)
24 Q
I would like to show you a document and ask 25 you if this is the procedure for Part 21 which you
1 Potts
-82
~
referred to?
If it is, I will mark it.
Otherwise, I 2
w n't.
3 4
MR. KIRSCHBAUM:
Whether this is the entire
(
5 procedure?
6 MS. WAGNER:
Yes.
7 A
This is not the procedure I was referring to.
8 Q
Do you know for the time period you were 9
in Licensing 10 MR. KIRSCHBAUM:
Can we have that marked 11 anyway?
12 MS. WAGNER:
Why not.
Let's mark as B&W
/
13 381, two pages stamped for production W15838 and 14 W15839 which are pages from the GPU Service 15 Corporation Manual.
e 16 (Two pages from GPU Service Corporation 17 Manual with the heading " Division:
Generation, 18
Subject:
NRC Regulation 10 CFR 21" bearing n
19 Production numbers W15838 and W15835 marked 20 B&W Exhibit No. 381 for identification, as of 21 this date.)
,,k 33 Q
During the period when you were involved i
23 in licensing at Met Ed, do you recall who was the
[h 34 Vice President - Generation for Metropolitan Edison?
w.)
25 A
Yes.
1 Potts 83
~\\
(V
~
2 Q
Who was that?
3 A
Mr. Arnold and later Mr. Herbein.
4 Q
Did you ever discuss Part 21 with them, 5
either of them?
(
6 MR. KIRSCHBAUM:
While he was at I,1c e n s ing ?
7 MS. WAGNER:
At any time.
8 A.
Yes.
9 Q
When did you discuss it?
10 A
I don't recall the dates.(
11 Q
Do you recall whether it was before or 12 after the TMI-2 accident?
O' x-13 A
It was before.
14 Q
Do you recall with whom you discussed it, 15 of those two?
16 A
Both.
17 Q
Separately or together?
18 A
I recall separately.
19 Q
Do you reca'll the subjects you were 20 discussing in the context of Part 217 4
21 A
There were a couple of occasions I can recall.
23 In general, I think I discussed the Part 21 with 4
23 Mr. Arnold and its implications with Mr. Herbein.
B&W 5
[~)
24 had made a Part 21 report at one time.
\\_/
25 Q
You were discussing the B&W Part 21 report
1 Potts 84 O
2 with Mr. Arnold and Mr. Herbein?
3 A
. With Mr. Herbein.
4 Q
Do you recall what about the report you i
5 were discussing?
({
6 A
No.
7 Q
Am I correct that you testified that part 8
of your engineering group as superintendent for Technical 9
Support at Unit 1 was an instrumentation and control 10 subgroup?
g 11 A
Yes.
12 Q
Do you know if at any time before the O\\~)
13 accident, the instrumentation and con rol subgroup was 14 involved in determining which instrumentation and 15 control would be put into the TMI-1 or the TMI-2 16 control room?
17 A
No, I don't recall.
18 Q
You don't recall one way or t'he other or 19 you don't recall that happening?
20 A
I don't recall that happening.
21 Q
Did you have an understanding during that 22 time or knowledge or experience with respect to how 23 the various instrumentation and controls in the control-
/'
24 room of TMI-1 worked?
Were you familiar with them?
's.,,))
25 MR. KIRSCHBAUM:
There are two different.
.l 1
Potts 85 1
1 2
questions there entirely.
3 Q
Were you familiar with them?
4 MR. KIRSCHBAUM:
Before the accident?
l
(
5 MS. WAGNER:
Before the accident.
6 A
I was familiar with some of them.
7 Q
What was the basis of your familiarity with l
8 any of them?
9 MR. KIRSCHBAUM:
I object to the question 10 as to form.
I don't understand khat you mean by 11
" basis for your familiarity."
12 Q
Did you go to classes to learn how they 0
13 were used?
I4 A
No.
15
~
Q How did you learn about them?
e 16 A
Through the discharge of my responsibilities 17 at that time.
18 Q
What exactly were you doing that familiarized.
19 you with these pieces of equipment?
20 MR. KIRSCHBAUM:
Are you talking about 21 instrumentation and controls?
j 22 MS, WAGNER:
Yes.
23 MR. KIRSCHBAUM:
At the TMI-1 control room?
O t
24 MS. WAGNER:
Yes.
(,)
25 A
Working with my engineers on several1of
1 Potts 8G O(~'T.
2 their projects in providing the support for maintenance.
3 Q
What instrumentation and controls are 4
relevant to maintenance?
(
5 A
Any~ instrument that they are maintaining 6
Q So your function there was maintaining the 7
instrumentation and controls and that is how you became 8
familiar with them, is that correct?
3 MR. KIRSCHBAUM:
The witness' function or 10 the department's function?
E 11 MS. WAGNER:
The department's.
12 A
Our function was not to maintain any 13 instruments.
i 14 Q
What exactly were you doing as engineers 15 which related the instrumentation and controls to
?.
16 maintenance?
17 A
Engineering would provide technical 18 assistance to the maintenance personnel ho were 19 maintaining the instruments.
20' Q
Did you ever provide, I mean your department; 21 provide technical assistance to whoever was maint aining 22' condensate polishers?
23 MR. KIRSCHBAUM:
Prior to the accident?
(
)
24 MS, WAGNER:
Prior to the accident.
25 A.
I don't-recall.
1 Potts 87 O'
2 Q
You don't recall one way or the other?
3 A
One way or the other.
4 Q
Are you faalliar with the condensate
(
5 polishing system at TMI-17 6
A I have certain familiarity with it.
7 Q
I should have asked were you familiar with 8
it before the accident?
9 A
I'm not -- I don't recall.
10 Q
Were you familiar before the accident with 11 the TMI-2 condensate polishing system?
12 A
No.
\\'
13 Q
Do you recall any involve ent as I
~
14 superintendent of Technical Support in instrumentation 15 and controls for the PORV in Unit 17 e
16 MR. KIRSCHBAUM:
Prior to the accident?
17 MS. WAGNER:
Prior to the accident.
18 A
I. don't recall.
19 Q
Were you familiar with any instrumentation 20 and controls relating to the PORV prior to the accident?
21 A
I have some familiarity with the i
t 22 instrumentation.
23 Q
What instrumentation was used in TMI-17 i
V l
('}
24 MR. KIRSCHBAUM:
Asato what?
\\
i v'
25 MS.. WAGNER:
PORV.
Potts 88 O
2 Q
What instrumentation are you familiar with?
3 MR. KIRSCHBAUM:
What instrumentation is he 4
familiar with that was used in connection with the
(
5 PORV prior to the accident at TMI-17 6
MS. WAGNER:
Right.
i 7
A The instrumentation that I'm familiar with 8
is a pressure sensor and a variable set point contro11er.
r, Q
The piece of equipment which controls the 10 opening and closing of the PORV, is that correct?
11 A
Yes.
12 Q
Were you familiar with instrumentation or
\\-
roomrelbting 13 controls in the TMI-2 control to the PORV?
14 A
No.
15 Q
Do you recall whether in.the TMI-1 control 16 room there was any instrumentation in the control room 17 which indicated the position of~the PORV7, 18 MR. KIRSCHBAUM:
Again prior ~to the accident?
19 MS. WAGNER:
Yes.
~
20 A
No.
21 Q
You do not recall?
22 A
I don't recall.
23 Q
Were you-familiar with the utility printer
-(
)
24 in TMI-17 n.-
25
' MR. KIRSCHBAUM:
I am having a little m
+
~
1 Potts 89 O(~h' Problem with the use of the term " familiar."
I 2
3 d n't think it has been clearly defined.
4 Q
Have you ever heard of a utility printer?
({
5 A
After the accident I have heard of a utility 6
Printer.
7 Q
Before the accident, you had not heard of it?
8 A
I don't know.
9 Q
Then you don't'know whether you knew 10 anything about the TMI-1 utility printar?
11 MR. KIRSCHBAUM:
Before the accident?
12 MS. WAGNER:
Right.
O 13 A
That's correct.
14 Q
Prior to the accident, did you know 15 anything about thermal couplers?
e j
16 A
Yes.
4 17 Q
What was your understanding then of what
~
4 18 thermal couplers were?
temp'rature.
19 A
A device used to measure e
20 Q
Prior to the accident, had you ever heard of 21
.something called the operator group trend recorder?
22 A
I don't remember that.
23
.MR.
KIRSCHBAUM:
The question is whether h) 24 you recall having heard of.it prior to the
%j 25 accident, not whether you remember it-now.
a
+
r
+-
+ -.
9
'l Potts 90 2
A No.
3 Q
Prior to the accident, had you heard of 4
something called the operator's special summary?
5 MR. KIRSCHBAUM:
What was that?
6 MS. WAGNER:
Ope,rator's special summary.
7 A
No.
8 Q
Were you aware that, prior to the accident, 9
that there were instruments in the TMI-1 control room 10 which could record information on a tr.ending or 11 historical basis?
12 A
Yes.
13 Q
Which such instrument were you ' ware of?
a 14 A
There are four trend recorders on the 3
i-15 control console that I'm aware of.
i 16 Q
Which ones were those?
17 A
I don't know what they were.,
18 Q
Did you have an understanding prior to the 19 accident as to what their use was?
~
20 MR. KIRSCHBAUM:
In the TMI-1 control room?
21 MS. WAGNER:
Yes.
22-A No.
23 Q
Did you ever use information from those O;_
_24 trend recorders.for any purpose?
. N. /
25 A-No.
i
Potts 92 g
'v) 2 Q
Did anyone from your department, to the 3
best of your knowledge?
4 A
I don't know.
To the best of my knowledge,
(,
5 no.
6 Q
Which department at Metropolitan Edison 7
at any time that you were there was involved, if any, 8
in licensing of operators?
9 A
I'm not certain who they were.
10 Q
Do you believe it was the Training 11 Department?
, 12 A
Yes.
13 Q-I take it there were-no joint
~
14 responsibilities between you and the Training
~
15 Department?
I mean Licensing and the Training 16 Department, with respect to such operators' licenses.
17 A
No.
18
-Q Is it correct that the final safety analysis 19 report for TMI-1 and TMI-2. contained a description of 20 training to-be given to reactor operators?
21 A
I don't know.
22 Q
You never had occasion in your tenure at 23 Licensing to review taht section of either FSAR?
-[
24
.A I don't remember reviewing-it.
xy 25 Q
.Do you know if the Quality Control or b-
1 Potts 92
.2 Licensing Departments at Met Ed or any other department l
3 '
had any role with respect to auditing or reviewing 4
training administered to Metropolitan Edison reactor j{
5 operators by vendors, i.e.,
personnel other than TMI 6
personnel?
7 M'R. KIRSCHBAUM:
Read that question back, 8
please.
9 (Record was read back.)
10 MR. KIRSCHBAUM:
Are you asking for a 11 specific department or just whether anybody?
12 MS. WAGNER:
Anybody.
13 A
I know that the Licensing epartment did not 14 have such responsibility.
I don't recall the Quality 15 Department having such responsibility and I'm not aware e
16 of any other details.
17 Q
Is there a Quality Assurance., Department or
~
18 was there at Metropolitan Edison as well'as a Quality 19 Control Department?
20 A
The department was Quality Assurance.
I 21 have used the terms interchangeably far too often.
1
.\\
22 Q
Well, as long as I understand there were not 23 two departments.
There was just one, is that correct?
[~)h 24 A
That's correct.
There were two different
\\,.
25
-groups, a quality control group and quality assurance l
e
1 Potts 93
~
2 group but they worked for the manager of the Quality Assurance.
3 4
Q What was the difference in their function, 5
Quality Control and Quality Assurance?
(,
6 A
Quality Assurance was a location.
It was 7
located at Reading and Quality Control was located at 8
TMI.
9 Q
Was there any difference in what they did?
10 A
Yes.
g 11 Q
What was the difference?
12 A
Quality Assurance, for example, would O~
13 review a purchase specification where Quality Control 14 would review material, inspect the material because 15 of the location.
16 Q
Is it correct that at sometime during your 17 tenure at Metropolitan Edison you were on the Generation 18 Review Committee 27 19 A
I don't recall if I was a member of GRC-2 t-20 or not.
21 Q
Do you recall being a member of any GRC?
'(.
22 A
No.
l 23 Q
Did you have any role at any time in your 24 tenture'at Metropolitan Edison, prior to the accident,
'%)' -
25 in reviewing procedures for the operation of the nuclear l
1 Potts 94 2
plant at either TMI-1 or TMI-27 3
A Yes.
l 4
Q What was your involvement in the procedure
(
5 review?
6 A
I was a member of PORC which reviewed the 7
operating procedures for TMI-1, changes to operating 8
procedures.
j g'
Q During what period were you a member of PORC?
10 A
I was chairman of the PORC during the period 11 I was a unit superintendent of Technical Support. I was a 12 member of the PORC when.I was supervisor of Quality O
13 control.
14 Q
What did PORC stand for?
Plant Operating 15 Review Committee, is that it?
e 16 A
Yes.
17 Q
Is there a separate PORC for, Unit 1 and 18 Unit 27 19 A
Yes.
~
20 Q
Did the two PORC's conduct their business 21 separately or.did they ever conduct it jointly, to the (L-22 best of your knowledge?
23 MR..KIRSCHBAUM:
Are you asking did the two
[\\
24 PORC's ever meet jointly or as a matter of
\\_-
25 practice, did they meet n
1 Potts 95 i
t\\~'
2-MS. WAGNER:
Did they ever meet jointly.
3
,MR.
KIRSCHBAUM:
While he was a member of 4
PORC7
({
5 MS. WAGNER:
To the best of his knowledge, 6
at any time.
7 MR. KIRSCHBAUM:
Prior,to the accident?
8 MS. WAGNER:
Prior to the accident.
g A
I don't know if they met jointly.
They did 10 not while I was unit superintendent.
e H
11 MS, WAGNER:
Mr. Reporter, please mark as 12 B&W 382, a two-page memorandum dated January 8, 13 1979 from Mr. Herbein to GRC-2 Members and 14 Alternates.
I 15 (Two-page memorandum dated January 8, 1979
~
16 from J.
G.
Herbein to GRC-2 Meabers and Alternates, 17 subject, "GRC-2 Membe.rship Appointments" marked 18 B&W Exhibit No. 382 for identificat' ion, as of this 19 date.)
20 Q
Mr. Potts, I would like you to review that l
21 for the purpose of refreshing your recollection as to 22 whether or not you were ever a member of'the GRC-2.
l 23 A
In any degree at all, I recall GRC-2 l
24 Q
You now start to recall GRC-27 h
25 A
Yes.
-w
l 4
1 Potts 96 i O 2
Q Is it correct that you were a committee 3
chairman of.GRC-2?
4 A
I don't recall from memory.
However, the
((
5 paper lists my name as a committee chairman.
6 Q
The paper lists your name as a committee 7
chairman for two committees.
The LER Committee snd the 8
Tech Specs Committee.
9 Do you have a recollection of either of those
.10 committees?
e 11.
A No.
12 Q
Do you have any recollection as to the time
\\
13 period during which you were involved with either of 14 those committees?
15 MR. KIRSCHBAUM:
If any.
I believe he said e
16 he doesn't recall the committee.
17 A
I have no-recollection of the time period.
18 Q
Do you'have any recollection'of any other 19 personnel involved in either of those committees?
20
-A No.
21-Q I take it you don't recall anything you did 22 during these committees, if anything?
23 A
That's-correct.
]
[
24-MS. WAGNER:
I would like'to ask the 25 reporter to. mark'as B&W 383, a-document. entitled
P 1
Potts 97
.fm u
2 "TMI Unit 2 Generation Review Committee."
The 3
d cument appears to be physica'lly a charter for 4
the GRC-2.
(
5 Q
I would like you to review it and in 6
general, I don't think there is a need for you to 7
review every page.
But does that refresh your 8
recollection in any respect with regard to GRC-27 9
(Document entitled "TMI Unit 2 Generation 10 Review Committee" marked B&W Exhibit No. 383 for 11 identification, as of this date.)
12 Q
Have.you ever seen B&W 383 before?.
x-13 MR. KIRSCHBAUM:
Are you including within 14 your question -- put it this way: 'Are you 15 excluding documents reviewed in preparation for e
16 the deposition?
17 MS. WAGNER:
No.
18_
A I have -- I don't recall see[ng this
~
10 document.
20 Q
Do.you recall ever seeing any GRC log 21 records or logs?
L 22 A
No.
i 23 Q
Do you recall ever seeing any documents i
,)
24 generated by the GRC-27 25
-A No.
I
j i
(.
i 1
Potts 97A I -
2 MS. WAGNER:
Why don't we break for
?
'3 lunch.
9 s
4 (Whereupon, at 12:30 p.m.,
a luncheon 4
k i
. {-
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1 98 f
2 (AFTERNOON SESSION) 3
.(Date:
January 7, 1982) 4 (Time noted:
1:50 p.m.)
POT T S,
resumed, having
({
6 been previously duly sworn, was examined and 7
testified further as follows:
8 EXAMINATION (Cont'd.)
p g
BY MS. WAGNER:
10 Q
You indicated, I believe, this morning in 11 your testimony that you were at one point or another 12 on the PORC for Unit 1,
is that correct?
-O(_/
s 13 A
That's correct.
14 Q
.Were you ever on the PORC for Unit 2?
~15 A
No.
~.
16 Q
During your tenure or I guess two tenures 4
17 on the PORC at Unit 1,
do you recall -whether or not 4
18 '
PORC'raviewed the lucal procedure for Unit 17
~
19 MR. KIRSCHBAUM:
Before or aft'er the 20
-accident?
21 MS. WAGNER:
Before.
(L 22 A
No, I don't recall.
23
. g Do you recall whether the PORC reviewed L f~}
24 the procedure for. pressurizer failure?
- v
.25
)UL. KIRSCHBAUM:
Are all these quest' ions h
E
l 1
Potts 99 O
2 before the accident?
3 "MS.
WAGNER:
Yes.
4 A
No, I don't recall.
(
5 Q
Do you recall whether the PORC at any time 6
when you were involved with the PORC reviewed any 7
emergency procedures?
Again before the accident.
8 A
I don't recall.
9 Q
You don't recall any emergency procedures u
10 being reviewed?
~,
11 A
That's correct.
12 7g Q
Do you recall any operating procedures
(_
^
13 being reviewed?
f 14 A
No.
15 Q
Do you recall any procedures at all being 16 reviewed?
17 A
No.
~~
18 MR. KIRSCHBAUM':
In the past you have 19 qualified that by saying "one way or the other or 20 you don't ~ recall it happening."
You didn't do 21 that this time.
I think the witnesc may have been 22 expecting that in the answer.
23 MS. WAGNER:
I don't understand.
("\\.
(,)
24 MR. KIRSCHBAUM:
This morning'in a. number.
25 of instances where the witness testified.he didn't
i i
1 Potts 100 2
recall, you then put one of two possible 3
interpretations of that answer to the witness 4
and you have not done it in this instance and
(
5 he has given a line of answers.
6 I am not sure which --
7 MS. WAGNER:
I assume he is saying he 8
doesn't recall any procedures being reviewed by 9
the PORC when he was involved.
10
.Q Is that correct?
11 A
I don't recall whether we did or not before 12 the accident.
13 Q
Do you recall before the accident whether 14 you had any understanding of how the PORC would review 15 a procedure?
16 A
Yes.
17 Q
How would the PORC review a procedure?
18 A
Ask your question again, ple se.
19 Q
What was your understanding as to how the 20 PORC would review a procedure?
I am speaking of a.
21 procedure for the operation of a nuclear power plant.
22 A
The procedure change would be brought to 23 the PORC by one of'its members and the PORC would
/~N
'k j 24 discuss the change. request and either review or approve 25 either review or' reject it.
w
1 Potts 101 2
Q How would the PORC review the change?
What s
was the methodology?
3 4
MR. KIRSCHBAUM:
Your question again goes
(
5 to his understanding pre-accident as to what the 6
methodology was?
7 MS. WAGNER:
Correct.
8 A
We would review it and that included 9
discussions by several members of the PORC.
10 Q
Are you saying that your review consisted 11 only of discussions?
12 A
No.
A-)
13 Q
What else would it include?
14 A
We are not talking of a specific procedure 15 but in general?
16 Q
Correct.
17 PR. KIRSCHBAUM:
An understanding that you 18 had prior to the accident to the m$thodology.
19 That is my understanding of the lin'e of 20 questioning.
l 21 MS. WAGNER:
That's right.
33
.A We would request and receive input from l
23
-whatever_ organization we felt we needed input from, i.
24 then we would review the procedure to insure that it 25 met with the technical specifications, administrative
~
1 Potts 102 0
2 Procedures and accomplished its scope or purpose.
3 Q
.Where during this time period did the change 4
request originate for a procedure, again as a matter
(
5, of methodology?
How did it get to the' PORC?
6 A
Procedure change requests were submitted I
)
7 to the PORC secretary and then placed on the agenda.
8 Q
By whom were they submitted to the PORC g
secretary?
10 A
That would depend on who originated the 11 change request.
12 Q
Was there any uniformity?
Who would
[l A-13 originate change requests?
Anybody?
Was there any particular group that would originate change 14 requests?
15 MR. KIRSCHBAUM:
I think in the context e
16 of this line of questioning as to methodology 17 pre-accident, I think that needs clarification.
18 You are asking who --
19 Q
Would anybody in theLwhole Met-Ed submit a 20 change request before the accident?
Could it come from 21 any. source in_the whole company?
22 MR. KIRSCHBAUM:
Was there any methodology 23 or procedure or practice as to.that' issue?
. f ')
24 MS. WAGNER:
That.is what I am asking.
\\s 25 A-I don't recall what the methodology or
1 Potts 103
.O g
I l
'd 2
Practice was for who could submit change requests.
3 Q
Do you recall who did?
Was there any 4
uniformity in that?
5 MR. KIRSCHBAUM:
Those are two different 6
questions.
Does he recall who did submit them 7
and was there any uniformity.
8 Q
Do you recall who did?
9 A
Change requests were submitted by engineers, 10 by Operations.
Recommendations for change requests were 11 submitted by B&W which were operated on by engineers to 12 fill out the change request form.
O 13 Q
So the change request from the PORC would 14 cdme from the engineers?
15 A
Yes.
16 Q
Was there any methodology by which if a i
17 change were made in a procedure at TMI-2,,
that change 18 would somehow be brought before the TMI-1 PORC so that 19'
' Procedures in TMI-1 could also be reviewe'd pursuant 20 to the change made in TMI-2?
21 MR. KIRSCHBAUM:
Pre-accident?
22 MS.' WAGNER:
Yes.
23 A
I don't recall if in the Unit 2 procedures
,['h 24.
change requests were reviewed by Unit 1 PORC.
%.,) -
25 Q
Are you familiar with the term " reportable
Potts 104 f
i 2
occurrances"?
A Yon.
3 Q
Prior to the accident, were you familiar with that term?
A Yes.
6 Q
What was or what is a reportable occurrence r what was your understanding before the accident of 8
what a reportable occurrence was?
MR. KIRSCHBAUM:
In what context?
10 t
MS. WAGNER:
Any context.
A A reportable occurrence is one of the
' (]s 9
terms used for a licensee event report ~.
t
(-
Q Did every transient that occurred at TMI result in a licensee event report?
" ^
^#*
Y "9
16 practice?
MS.
AGNER:
No.
18 MR. KIRSCHBAUM:
You are asking whether or
,j' g
not he can say that every transient'which decurrad' at TMI prior to the accident results in a licensee t
21 i
1 event report?
'[
l MS. WAGNER:
Right.
23
.eN A
I don't know.
k,,,j s
Q Do you know if there was any practice
- prior g
- t s, t
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s
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1 v
1 Potts 105 C
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f 2
to the accident? \\
q-i-
3 A
There was a practicesprior to the accident.
h' 4
Q What was the practice?
Y
,,Y r
- (.'
5 A
xTo review and submit LER's pursuant to tihe t
~N
- 6 techs spqc.
m G'
'I Q
'Pyrsu' ant to the tech spec, would every
,i q,
'8 s
transient have to be reported as a LER, to the best
~.
t
(.
9 of your recollection?
o N%
is 10 MR. KIRScHBAUM:
Are you asking his 11 recollection of the tech specs, what they provide?
-.s 12 MS, WAGNER:
Right.
.p '>r w
j
,L 13 A
I don't recall the tech spec requiring a 14 retrangient.
.A; 15
'Q, Do you recall now what criteria would rc,sult t
.y i,
s 16 in,an LER being' filed or submitted?
a s
\\
17 c'
MR. KIRSCHBAUM:
' Criteria under - the tech s '
'k s
18 criteria pTre-accident [
specs;.or any s
s
,~
3 s,
d.. s.
3 x
. Any criteria.
1 19
. g MS.'x i
' WAGNER:
a
~
20 A
(
I recall there wer.e.. several criteria.
- s. >.,
s
"{
Q
%f%
a 21 Q
.Can you recall any mf'them or all of them?
(.
(
. w w
22 A.
I could not'qu'ote.to you those criteria.
'.. s AS 23 sq g
y
\\-
Can you give.me p(ay idea of what Q
kinds of f
24 things they were?~
4
.a
'~~ ;
I 20.
MR. KIRSCHBAUM:
' Objection as.to form.
3.>
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t:
x y,
i
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w_
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=
1 1
Potts 106 2
I think it is,a'little too vague.
i 3
A No, thern were specific criteria.
4 Q
Diel they have to do with the severity of
((
5 radiation release, for oxample,,o r the amount of 6
radiation release?
7 A
Since I don't recall the specific criteria, 8
I don't believe I can answer that question.
9 Q
Who was responsible for drafting LER's?
10 MR. KIRSCHBAUM:
When?
t 11 MS. WAGNER:
At any time prior to the 12 accident.
13 A
Either an engineer or operator would be J
14 assigned to draft an LER.
15 Q
Did the Licensing Department have any role 16 in reviewing an LER?
17 A
Yes.
18 Q
Did the Licensing Department ~have to review 19 it before it was submitted to the NRC?
20 A
Before the written report was submitted, 21 yes.
L 22 Q
In the normal procedure after an operator 23 or an engineer drafted an LER, what levels of review n
.( }
24 would it go through aside from the Licensing Department 25 review, if any?
1 Potts 107 2
A PORC reviewed it, the unit superintendent 3
approved it, Licensing reviewed it, the Vice President 4
of Generation reviewed it and signed it prior to its g
5 submittal to the NRC.
4 6
Q Did the reviews occur in the order which f
7 you have just stated them?
8 A
I don't recall the order in which I stated 9
them.
10 MR. KIRSCHBAUM:
Read it back.
11 (Record was read back.)
12 A
Yes, that was the sequence.
g A
13 0
During the time that you were in the 14 Licensing Department, ~ did you personally review LER's?
15 A
Yes.
16 Q
Did you review LER's for Unit 27 17 A
Yes.
18 Q
And for-Unit 17 19 A
Yes.
20 Q
To the best of your recollection, did you 21 review every LER submitted during that time period, 22 at the time when you were supervisor of Licensing?
23 A
I don't know if I reviewed every one or not.
[~)
24 Q
Do you recall whether you had any practice
\\_J 25 with respect to reviewing them?
1 Potts 108
(
)
2 A
The practice was for me to review them but 3
I can't say if I was on vacation, for example.
4 Q
This morning we were discussing briefly
.({
5 the Generation Review Committee.
6 You indicated you don't recall much about 7
that.
I was wondering if you recall keeping an LER 8
file for the Generation Review Committee?
9 A
No.
10 Q
When you reviewed an LER as supervisor of 11 Licensing, what were you reviewing for?
12 MR. KIRSCHBAUM:
Are you asking if there IT
\\-)
13 was a practice for reviewing certain items or 14 what he did look at when he looked at LER's?
15 Q
What did you look at?
IG A
I looked at the LER to see how it conformed 17 to toch spec requirements, to NRC requirements for subm'itted within 18 submitting LER's, to see that it was 19 the correct time frame, to see that its language was 20 precise in indicating what happened, to insure that 21 it had been reviewed by the appropriate parties we have 22 talked about.
23 That is what I can recall.
I f )
24 Q
Do you know if LER's were ever reviewed L j' 25 by operators at TMI as a routine matter?
_ -.. =...
1 Potts 109 O
2 A
I don't know.
3 Q
Did you have any understanding during that 4
time period as to what the purpose was of writing
(
5 LER's?
6 MR. KIRSCHBAUM:
Which purpose?
7 MS. WAGNER:
Any purpose.
8 MR. KIRSCHBAUM:
My question --
9 MS. WAGNER:
Any purpose of any person.
l 10 A
Yes.
(
j 11 Q
What was the purpose?
12 A
one of the purposes was to conform to 13 technical specification.
14 Q
Did you have any understanding at that time 13 as to whether the technical specification had any 16 purpose?
17 MR. KIRSCHBAUM:
I am not clear what you mean 18 by " purpose."
The purpose within the NRC regulatory 19 scheme?
20 MS. WAGNER:
Any purpose the witness might 1
21 be aware of.
The witness probably understands
(_
l i
22
" purpose."
1 23 MR. KIRSCHBAUM:
I am sure he does.
The 4
(-
i I
j 24 word " purpose" depends on context, I think, t
25 especially when you are talking about the document
1 Potts 110 2
you are talking about.
3 MS. WAGNER:
I am referring to every 4
possible meaning.
{
5 MR. KIRSCHBAUM:
I object to the question 6
as to form.
7 You may answer to the extent possible.
1 8
THE WITNESS:
Can you repeat it for me, 4
9 please.
10 (Record was read back.)
11 A
Yes.
i 12 Q
What was your understanding?
1 13 A
It was issued by the NRC to provide limits i
14 on the operation.
That is my understanding.
15 Q
The technical specification was issued by 16 the NRC to provide limits on operation?
Is that what 17 you meant by the last answer?
18 MR. KIRSCHBAUM:
That is exac ly what he 19
- said, t
I j
20 MS. WAGNER:
I didn't know which "it" he j
21 was referring to, the tech spec or the LER or 22 what.
l 20 Q
Were you referring to the technical
(
24 specification?
25 A
Yes.
l l
l
l 1
Potts 111 g
t Q
So your only understanding of why LER's were in being at that point was that the tech spec 3
required it and the NRC required the tech spec?
MR. KIRSCHBAUM:
I object.
The word "so" impli s the answer to the question that he gave 6
would lead to that conclusion.
That is misleading 7
because in your question you say defining it q
8
.i 3,
any way possible and his answer could not be a
j a
n as meaning "so."
10 Q
Is there any other purpose you can think g
I of?
()
MR. KIRSCHBAUM:
Objection'to the question g
as to form on the same grounds as before.
~
j g
4 A
Yes, it was one of the ways of providing i
16
-safe peration.
Q When you say "it,"
are you referring to the t
i.s tech spec?
~
18 A
g
. Technical specification.
i Q
Did you have any understanding at this time as to what the NRC did with the LER's that were submitted 21 i
to it?
A I don't recall having an understanding.
Q Did you ever see an LER submitted by another g
g plant?
r 4
1 Potts 112 2
MR. KIRSCHBAUM:
Submitted to the NRC by 3
another plant?
4 MS. WAGNER:
Yos.
((
5 A
I don't recall having seen another LER 6
submitted.
7 Q
Did you as supervisor of Licensing as a 1
1 8
routine matter review LER's submitted by plants other 9
than TMI-1 and TMI-2?
10 A
I don't recall.
11 Q
You don't recall having done so or you 12 don't recall one way or the other?
13 A
I don't recall one wey or.the other.
14 Q
Did the Licensing Department have a file 15 of TMI LER's?
16 A
Yes.
17 Q
Did the Licensing Department ~-have a file 18 of non-TMI LER's?
19 A
I don't recall having such a file.
20 Q
Did you at any time become aware of a 21 concern in approximately 1978 that changes could be made 22 in the process for acquisition and'use of information 3
23 about incidents at other nuclear plants?
l
)
24' MR. KIRSCHBAUM:
Read'the~. question back, 25 please.
l
j 1
Potts 113 2
(Record was read back.)
3 MR. KIRSCHBAUM:
I object to the question 4
as to form because I don't understand it.
- Also, l
5 I want to clarify that yar are referring to 6
during the period of licensing.
7 MS. WAGNER:
Yes, 1978 or
'79.
8 Q
Did you ever become aware during that period 9
that anybody at Metropolitan Edison was concerned about i
10 the process for acquisition and 'ise oft information about 11 incidents at other nuclear plants?
The acquisition 12 and use of such information by Met Ed.
%l 13 A
I don't recall being. aware of that.
14 Q
Have you ever heard of the GORB7
+
15 A
Yes.
1 k
f.
16 Q
What is the GORB?
~
17 A
General Office Review Board..,
18 Q
What is that body?
19 A
A group of people who review 'he TMI t
20 Operation.
21 9-Is-that a body of people of Met Ed or General Public Utilities,.to the best of your 22 23 recollection?
-(O')
24 1A I don't-recall its composition.
25 Q
Were you ever a member of the GORB7
~.
1 Potts 114 O
2 A
No.
3 Q
Did you ever sit in any meetings of the 4
GORB at any time prior to the accident?
((
5 A
Yes.
Partial meetings.
6 Q
Can you recall under what circumstances you 7
sat in on meetings?
8 A
I made a report to the GORB at least on one 9
occasion and I think mor'e.
10 Q
Concerning what?
e 11 A
The TMI-1 refueling process.
12 Q
Was that during the time you were Technical
(~%
13 Support superintendent?
14 A
Yes.
15 Q
Do you recall when you were with Licensing 16 ever meeting with the GORB?.
17 A
No.
18 Q
Do you recall ever seeing a [ ORB action item?
19 A
Yes.
~
20 Q
Do-you recall which one or ones?
21 A
No.
22 Q.
Did you frequently see such action letters?
23 MR. KIRSCHEAUM:
What do you mean by b )h 24
" frequently"?
s-25_
MS. WAGNER:
More than once a' year.
1 Potts 115
(~~
\\~
2 MR. KIRSCHBAUM:
Prior to the accident?
3
.M S. WAGNER:
Prior to the accident.
4 A
I'm not certain.
'5 Q
Were you aware of any efforts by Metropolitan 6
Edison to train operators with respect to matters in 7
TMI LER's?
8 MR. KIRSCHBAUM:
I object to the question 9
as to form.
I don't understand it.
10 THE WITNESS:
Would you repeat that question 11 for me, please.
12 (Record was read back.)
13 A
I'm not personally aware, no.
14 Q
I take it that was not part of the function 15 of the Licensing Department while you were there, giving e
16 training on LER's?
17 A
I don't recall that being par,t of our 18 responsibility.
19 Q
Is it correct that during some peri'od of 20 time prior to the accident'" a were a member of the 21 B&W-owners group?
22 A
Yes.
23 Q
During what period.of time?
[J -);
24 A-During the period of timo that I.was 25 Licensing supervisor.
M m
v
'w
1 Potts 116 Od 2
Q More or less '76 to '79?
A
.I'm n t certain if it was the entire period 3
4 of time.
(
5 Q
what was the owners group?
6 A
A group of B&W licensees.
7 Q
Did the group have any purpose?
8 A
Yes.
9 Q
What was its purpose?
10 A
2 don't any longer remember its charter.
11 Q
Do you remember anything about why there 12 was this group?
')
13 MR. KIRSCHBAUM:
I object to the question 14 as to form.
Are you asking as to his understanding 15 of why it existed.
16 MS. WAGNER:
Yes.
17 A
Some of the reasons for its e,xistence were 18 to promote communication between the licinsees and to 19 discuss generic issues among the licensees and with 4
i 20 B&W.
21 Q
What do you mean by " generic issues"?
22 A
Issues that affected all or some of the 23 B&W licensees.
(~'T 94 Q'
What types of. issues.would these be?
%.)
~
25 MR..KIRSCHBAUM:
Objection.
What type of
...m,_
Tw--
1 Potts 117
(~h t).
2 issues were they?
3 Q
'What type of issues were they?
i 4
A We discussed the small break, Part 21 report l(
5 by B&W, we discussed how the group would interact 6
together to solve that problem.
7 Q
Is that the only problem you recall being 8
discussed by the group?
9 A
That is the only recollection I have.
10 Q
When you say B&W-licensed utilities, what 11 do you mean?
12 A
I mean those licensees who were operating O
13 B&W NSS-supplied systems.
14 Q
Is it correct Toledo Edison Company has 15 a nuclear steam supply system manufactured by B&W7 16 A
Yes.
17 Q
Do you recall that one or more people from 18 the Davis-Besse plant of Toledo Edison Company also sat 19 on the owners group?
20 THE WITNESS:
Repeat that, please.
21 (Record was read back.7 22 A
Yes.
23 Q
Can you recal'l~who it was from-Davis-Besse f'\\ '
c(,).
24 -
_who sat on the group?
25' A
No. -
L
g Potts 118 i \\
(_/.
Q Do you recall Fred Miller?
2 A
,Yes, I recall Fred Miller.
Q Do you recall whether the owners group ever C
discussed any problems with B&W-supplied nuclear plants g
Concerning pressurizer level being low?
A No.
7 8
Q Y u do not recall one way or' the other?
A I don't recall.
g 10 Q
What was the small break discussion that y u dis ussed previously?
What was the issue there?
11 A
The issue was B&W informed us, Met Ed, that 12 g_)
the safety analysis in the area of small break analysis 13 did not meet the ECCS final acceptance criteria and that it would have to be reanalyzed in that area.
10 16 Q
Was the matter reanalyzed?
A Yes.
g gg Q
Who did the analysis?
A B&W.
gg Q
Did Metropolitan Edison do anything with 20 respect.to that analysis?
g MR. KIRSCHBAUM:
Objection.
Did they do-g 23 anything with respect to it?
Does that mean before
,e'N the analysis or with.the analysis?
y
\\s-)
MS. WAGNER:
Either way.
25
-_______._._K--_----
- - - - - - - - - - ^
1 Potts 119 2
Q Did they have anything to do with the I
3 analysis?
4 A
We reviewed the analysis and we paid for
{
5 parts of it.
6 Q
Did you do any independent analysis?
By 7
"you,"
I mean Met Ed.
8 MR. KIRSCHBAUM:
What do you mean by 9
" independent analysis"?
10 MS. WAGNER:
Analysis ind ependent of B&W's.
11 MR. KIRSCHBAUM:
You mean.an analysis 12 totally divorced from the analysis received from 13 B&W7 14 MS, WAGNER:
Yes.
15 A
We had that analysis reviewed by GPU e
16 Service Corporation.
~17 Q
Did you participate in that review at all 18 personally?
~
19 A
No.
~
20 Q
Did.the Licensing Department become' involved 21 in any review of the analysis?
22 A;
We reviewed it prior to its submittal to 23 the.NRC docketing it for TMI.
[~}'
' $y '
Q Had the_ Licensing Department during the L- -
\\j 25
. time that you were supezvisor ever before reviewed y
+v v
v w'
1 Potts 120 0
2 any analyses involving operation of the plant?
3
.MR.
KIRSCHBAUM:
Reviewed analyses by B&W7 4
MS. WAGNER:
Any analysis of any kind.
(
5 MR. KIRSCHBAUM:
By any entity other than 6
a Met Ed entity?
7 MS. WAGNER:
Yes.
8 THE WITNESS:
Repeat the question, please.
9 Q
I will repeat it.
10 During the time you were supervisor of 11 Licensing, did Licensing ever review any analysis donc 12 by anyone other than Met Ed which was similar in that ON 13 it analyzed some aspect of the plant's operation, l
14 either normal operation or transient operation?
15 A
Yes.
I 16 Q
Was that part of the functions of Licensing, 17 that analysis function?
18 A
Yes.
19 Q
Were the personnel in Licensing during 20 that time who were performing reviews such as this 21 all engineers?
_ 33 MR.~KIRSCHBAUM:
Are you asking about any.
23 particular analysis?
24 MS. WAGNER:
Any analysis, anyone who was 25-involved in review of e.nalyses such as this and
1 Potts 121 0
2 including this.
3
.MR.
KIRSCHBAUM:
You are asking if anybody 4
who was not an engineer participated in the review
(
5 of any analysis?
6 MS. WAGNER:
If anybody in Licensing was 7
an engineer to start with.
8 MR. KIRSCHBAUM:
Why don't you start with g
that first.
10 A
Is that the question?
e 11 Q
Yes.
12 A
Yes.
D) 13 Q
Was everybody in Licensing an engineer?
14 A
No.
15 Q
How many people we're engineers?
16 A
All except two.
17 Q
Did the two who were not engineers review 18 analyses?
19 A
No.
i 20 Q
What kinds of engineering degrees did the 21 engineers have?
Nuclear engineering, electrical C
22 engineering, anything else?
l i
-23 A
Yes, mechanical engineering degrees.
l l
24 Q
As well as the two that I mentioned?~
v 25 A
- Yes, d
s e
a v-
~1 Potts 122 r
2 Q
Were analyses given to different people to 3
review depending on their particular expertise?
4 A
Yes.
l 5
MR. KIRSCHBAUM:
I think the witness would 6
like to clarify an answer he gave a minute ago.
7 MS. WAGNER:
Sure.
8 A
I'm not absolutely certain now what the g
question was when you asked me about a review of B&W's 10 small break analysis, e
11 I may have misstated.
What I asked and got 12 from GPU Service Corporation was a review of B&W's 13
- analysis, not a totally independent analysis.
14 Q
Is it correct that on several occasions 15 you attended: meetings in Lynchburg concerning the small e
16 break issue?
-17 A
Yes.
18 Q
Do you recall attending a mekting on 19 May 3, 19787
~
l 20 A
No.
21 Q
Do you recall attending a meeting on June 1,
l
(~
l 22 19787 23 A
I don't recall the dates.
[)
24 Q
Are you familiar with the complaint and f
h/
25 amended complaint in this action?
9 m
W 79
1 Potts 123 O~
2 MR. KIRSCHBAUM:
The use of the term 3
" familiar" --
4 Q
Have you read the complaint?
(
5 A
Yes, I have read the complaint.
6 Q
The complaint indicates that you attended 7
a meeting or two meetings in which "B&W officials 8
intentionally... misrepresented that the B&W high pressure 9
injection system was safe to operate."
10 MR. KIRSCHBAUM:
I obj ect to the question.
11 MS. WAGNER:
I haven't asked it.
12 MR. KIRSCHBAUM:
I object'to what you have 13 done so far.
You have partially characterized and 14 partially quoted a section of the complaint and 15 the characterization portion I don't believe-is 16_
quite accurate.
17 If you can, ask the witness a question about
~
' 18 that portion of the complaint.
19 Q
I_will show the wit' ness the amended complaint.
20, I will: ref er ' you to paragraph' 63 (c) of the complaint, 21 the amended complaint presently filed.
It~ starts at 22 the bottom of that page.
23
'Do you remember the meetings described.in
[Q
. 24' paragraph - 63 (c). of the amended complaint?
\\
25 A
I: remember ~ meetings with B&W.
As-I said
- e
~
l 1
Potts 124
(~%
2 earlier, the dates I don't recall.
3 Q
-Regardless of the dates, do you recall 4
meetings such as those described herein?
(
5 A
Yes.
6 Q
What is it that you believe was 7
misrepresented to you in one of those meetings or both?
8 MR. KIRSCHBAUM:
I object to the question.
9 By "you,"
are you referring to Mr. Potts 10 personally believing that someth'ing was 11 misrepresented or characterizing the allegations 12 by the company?
s 13 MS. WAGNER:
I am referrin,g to Mr. Potts 14 personally.
15 MR. KIRSCHBAUM:
I object to the question 16 because there is no foundation for his personal 17 belief.
10 MS. WAGNER:
Are you going to permit'him 19 to answer?
I t
l 20 g.
Mr. Potts, do you have any. reason to believe 21-anything said in either of those meetings was untrue?-
(..
22 MR. KIRSCHBAUM:
Objection.
Does he have i
23 any reason to believe that now or any' reason to --
' 'v) 24.
MS. WAGNER:
Now.
25 -
!MR. KIRSCHBAUM:
I object to the question
1 Potts 125 O
2 insofar as it asks for his present state of belief 3
and opinion.
4 I will instruct the witness not to answer
(
5 that.
6 The basis for the instruction, if you care 7
, to know it, in the fact that I have discovered 8
in reviewing transcripts in this case the last few 9
days, Davis, Polk'd attorneys, specifically 10 Mr. Fiske and Mr. Wise -- I d o n "t know if the 11 same applies to you personally because I have 12 not read every one -- Mr. Fiske and Mr. Wise 13 repeatedly instructed their witnesses not to
~~
14 answer questions concerning the present state of 15 their' minds or beliefs.
16 When that question and issue is-resolved 17
.by the court, then I think both parties will abide 18 by it and be on an equal footing in terms of.
19 discovery.
20 Until that time comes, I think we are 21 duty bound to instruct our witnesses not to answer
(
22 questions which the other side is being instructed
- 23 not to answer.
(R 24 MS. WAGNER:
.I must object to your
}.
l
'da characterization of any objections our partners
~1%
=
T'
1 Potts 126
' r~n 2
might have made to your questions in this matter.
3 However, it seems to me you have sued us for 4
$4 millions, and one of your complaints is a
(,
5 fraud allegation.
If I can't inquire of this E
witness what the basis is for your allegation 7
of fraud, I think we are going to have a little 8
Problem.
9 MR. KIRSCHBAUM:
You certainly can inquire 10 of this witness what the basis is.
You may 11 inquire of this witness specifically what he 12 recalls about the meetings that are alleged ir.
O 13 the amended complaint.
14 MS. WAGNER:
I cannot ask him what he 15 thinks was misrepresented?
1G MR. KIRSCHBAUM:
You can ask as to what 17 statements were made and you can ask him as to 18 information he may have had or may'have in terms 19 of facts to compare to those representations, but 20 I object to your asking as to his belief or i
OP nion on the subject.
21
' ~
22 And, as I'say, it is basically an objection 23 based on reciprocity, f[
jy I will say Mr. Fiske -- I am not saying
%s 25 this justifies it -- but,one of the-bases'for
1 Potts 127 gs
(_
2 Mr. Fiske's objections along those lines was that the question was "an ultimate question in 3
4 the case."
(
5 That was his basis for objecting and not 6
only objecting, but instructing the witness not 7_
to answer because he said it was an ultimate 8
issue of fact.
9 MS. WAGNER:
If you won't let the witness 10 answer the question, obviously, the witn'ess will 11 come back when a ruling is made by the court.
12 MR. KIRSCHBAUM:
We will be happy to do that 13 and would be, happy' to invite you witnesses to 14 come back as well.
15 Q
What were you told during either meeting 16 about high pressure injection?
17 A
I recall several meetings where the first 1
18 of which'Mr. Taylor made some introducto[y-remarks, 19_
introducedL Mr. Dunn, POe. Dunn made a presentation l
20 including some overhead' slides or projections that i
21 described the analysis, several break ~ sizes that were 22' included..
-23 I. recall the description that the safety
(}
24 analysis now met the final acceptance criteria for:
25 emergency' core cooling.
(' ':
I Potts 128 i
2 I remember questions and answers.
I recall 3
in the second meeting or a later meeting, discussions 4
where how would the arrangements be made to finance l(
5 the safety analysis.
The description of some follow-up 6
analysis that was required.
Schedules for follow-up 7
analysis.
8 That is all I recall right now.
9 Q
Can you tell me what you were told about 10 apr7 E
11 A
The HPI system would require a fix to 12 its system based on a location of a break at the 13 bottom of the pipe on the main coolant pipe simultaneous 14 with loss of power to the opposite train of HPI.
15 That is about all of my recollection.
16 Q
Have you ever come to an understanding that 17 it was incorrect that the HPI would require the fix 18 you have just described?
19 A
y'c,
20 Q
Did you ever come to an understanding that.
21 the HPI system after it received the fix described 22 would not meet ECCS criteria?
=23 MR.'KIRSCHBAUM:
Read the question back,
~
- r%-
1 24 please.
s.
25 (Record;was read back.)
L
l 1
1 Potts 129
('T
~
V 2
MR. KIRSCHBAUM:
Are you asking for his 3
understanding before or after the accident?
4 Q
Did you ever come to such an understanding?
{
5 MS. WAGNER:
Then I will find out when he 6
did-7 MR. KIRSCHBAUM:
I object to the question 8
on the same ground as I raised before.
You are 9
asking the witness for his present understanding _
10 as to --
e 11 MS. WAGNER:
If he ever came to an 12 understanding first.
13 MR. KIRSCHBAUM:
You are a king post-accident.
j 14 Post-accident, I object to the question.
15 As I said before, your firm consistently 16 objects and instructs witnesses not to answer 17 questions calling for their even pre-accident 4
18 understandings, but certa' inly postfaccident_
19 understandings on the grounds that 'an unexpressed 20 conclusion need not be testified to.
21 I can point to places in the transcript.
22 MS. WAGNER:
I would like an answer to the 23 question whether or not he had ever reached the
(
24 conclusion I just described.
25 MR. KIRSCHBAUM:
I object to the question Y
1 Potts 130 d('%.
and instruct the witness not to answer insofar as 2
3 the question is directed to a post-accident 4
understanding.
(
5 Y u may answer as to whether or not you 6
ever reached that conclusion before'the accident.
7 A
Before the accident, I did not reach that g
conclusion.
9 Q
Did you analyze HPI after the accident?
10 MR. KIRSCHBAUM:
Objection.
I don't it understand what that means at all.
Analy=e what?
12 Q
Did you perform any analysis on any aspect
(
\\~
of the HPI system at TMI-2 after the accident?
13 14 A
No.
15 Q
Did you at any time after the accident 16 obtain information concerning the operation of HPI at-17 TMI-2 which you had not obtained prior t9 the accident?
18 THE WITNESS:
Read me that qbestion again, 19 Please.
20 (Record was read back.)
21 A
Yes.
22 Q
What information was that?
23 A
I have read a number of reports,such as the es
(
'4
~4 Kemeny report, subsequent to the accident.
o
\\ ).
.25 Q
What'information d3
-u learn from whatever me r
n
1 Potts 133 2
source concerning HPI?
3
.MR.
KIRSCHBAUM:
After the accident?
4 MS. WAGNER:
Yes.
(
5 A
Specific information I don't recall.
I know 6
it is a large question in a number of reports, i
7 Q
What is a large question?
l 8
A That the HPI system is under question.
9 Q
What aspect of it is under question?
10 MR. KIRSCHBAUM:
What. aspect did he read 11 having been subjected 12 Q
What is it that you are talking about now?
O' 1
13 A
Both the operation and the safety analysig 14' that supports the use of the HPI system.
15 Q
You believe that is under question or it e
16 was in the reports that you read?
- 17 A
Yes.
18 Q
Is it still under question?
' 19 MR. KIRSCHBAUM:
Objection.
5s the HPI 20 system pre-accident still under question?
21 MS.. WAGNER:
I am asking-if the HPI system --
22 MR. KIRSCHBAUM:
As presently exists?
i 23 MS. WAGNER:
-- which he was describing-(
)
24-previously, whatever HPI system. was discussed in
-25 the post-accident'documentsLhe was referring to,
8
,\\
.i
\\
1 Potts 132
'l p)
\\-
2 is still under question today.
3 MR. KIRSCHBAUM:
I don't understand what 4
that means.
You are referring to whether or not
(,
5 a system which existed pro-March 28, 1978 and 6
was subjected to. question in documents that the 7
witness read post-accident are still being 8
subjected to questions in the sense of the same g
continuing question still being open?
10 MS. WAGNER:
Right.
t 11 MR.'KIRSCHBAUM:
I object to the question 12 except insofar as the witness has specific 0
13 information as to 14 MS. WAGNER:
I am asking for the witness' 15 information.
16 MR. KIRSCHBAUM:
If you are asking for his
'17 information, he can answer as to whether or not-18 he knows the present state of the [uestions that 19 have been raised or concerns that have been 20 raised concerning the HPI system as it was before i
21 the accident.
32 A
I don't know the present' state of those n
-questions.
A
( )1 24-Q Is there an HPI system at TMI-1 currently?-
w 25 A
Yes.
~*
e q.
l
^1' i
s -
s\\
1 "hv Potts 133 s
Q l\\:'
Q 2
's
( Q Is there'any question at the moment being
+
s
-, ts
' raise'd a's to its capability?
.s,%
4
?
3 4
A I don't k'now.
4
+
s n
- i
\\
' - different from the HPI system at Q \\'
) Is it C
oI 5
3
[' (
g TMI-2 prior to the accident?
.t
~
._s s
,i N.,
7 MR. KIRSCHBAUM:
Is the system that exists g.
N s;
s, 8
at TMI-1 now?
.s-s.
3
.s s
w
(,
1 t
s.
k MS. WAGNER:
Yes.
- (
10 l
'MR.
KIRSCHBAUM:
What do yp9 m5an by
\\
1 11 '
'" system"?
r.
MS..
WAGNER:
The witness and I have been 12 ;
s, N.
s g
s 13 italking about'the.,HPI system for some time.
I
\\
s N ' 'N y.
14
'think he an/. I know what we are talking about.
x i.
)
\\
' 15 i- [5
's MR. KIRSCHBAUM:
I want to be included in.-
g e
16 x t Q
'N What dol */qt mean by "HPI system"?
,1 y
yj(
N 17
'} '-
Am High pressure injection system.
r s
18.
MS. WAGNER: @oes that answer your question?
3~r-3 r
19 f MR. KIRSCHBAUM:
No'.
'J '
20 Q
-Can you further clarify the answer for your N
~
31 counse17 b
~
k" s
oo A
No.
4,c ' -
g, 23
)
Q Did you ever come to know that B&W knew s
q q
4
' 24 that 1 tis HPI system w$s not,sbfe to operate?
' s, c,%% ^\\
./
i
~, ~
125 MR. KIRSCHBAUM:1' Rhad the question back, g
s.is*
-\\
ji, y 4 iu
).
. [r
- q
,7.:..
1 Potts 134 V) 2 please.
3
.(Record was read back.)
4 MR. KIRSCHBAUM:
Are you referring to
([
5 pre-accident or post-accident?
6 MS. WAGNER:
Either.
7 MR. KIRSCHBAUM:
Again I will instruct the 8
witness only to answer as to pre-accident.
As to 9
post-accident, he is instructed to answer only as 10 to facts which came to his attention in terms 11 of what B&W knew.
12 MS. WAGUER:
That is what I am asking.
13 MR. KIRSCHBAUM:
As opposed to an opinion?
14 MS. WAGNER:
I am asking for facts.
15 A
Pre-accident we were assured by B&W it IG met the acceptance criteria.
It didn't come to my 17 knowledge contrary to that.
18 Q
Did it ever come to your knowledge, did you 19 ever hear from any source whatsoever that'B&W at any timt 20 before or after the accident knew that its high pressure 21 injection system was not safe to operate?
22 A
When they informed us that the Part 21 report 23 was going to the NRC that the safety analysis for the 24 small break LOCA was inadequate, yes.
25 g
After that, after the fix was enacted
1 Potts 135 f
s 2
Pursuant to the concerns about the small break LOCA, did y u ever ccme to know B&W knew that its high 3
4 pressure injection system wasn't safe to operate?
(
5 A
No.
6 Q
Did you ever come to know that anything 7
that was said to you at the meetings described in the 8
amended complaint was not correct?
9 MR. KIRSCHBAUM:
Objection.
Again, you are 10 including the post-accident peri.od?
11 MS. WAGNER:
Right.
I am asking for facts.
12 MR. KIRSCHBAUM:
I will permit the witness
-O 13 to answer as to facts, as to whether or not he
[4 received ~ facts.
You are'asking bobh pre and 15 post?
e 16 MS, WAGNER:
Correct.
17 MR. KIRSCHBAUM:
He should be permitted to 18 answer as to pre-accident and whether he received 19 facts post-acciden't that B&W knew
~
-~
20 MS. WAGNER:
I would like him to tell me 21 at any time if he received information which showed L
33 him that.something B&W said at the meetings was 23 false.
f',
34 Q
Is that your understanding of the question?
w 25 MR. KIRSCHBAUM:
I am not sure what you mean
1 Potts 136 2
by "inf ormation which showed him."
Again, I think 3
Y " ^#e getting away from facts and getting into 4
opinions he formed or conclusions based on facts.
(
5 Q
Did you receive any facts at any time which 6
indicated to you that something that was said to you 7
at this meeting about HPI was not true?
j 8
MR. KIRSCHBAUM:
I object to the use of g
the word " indicated" there.
10 Q
Did you ever receive any further information 11 about HPI after these meetings?
12 A
Yes, subsequent to those meetings, B&W s
13 submitted to us the analysis in which 'it stated that g4 the small break analysis now met the acceptance criteria.
15 Q
Have you received any information since 16 that time which indicates that that statement is false?
17 MR. KIRSCHBAUM:
Read that question back, 18 please.
~
i
~
19 (Record was read back.)
20 MR. KIRSCHBAUM:
Again, insofar as you are 21 referring to post-accident, the post-accident 22 period, insofar as you ask him whether or not he 23 reached conclusions and drew inferences and formed
['
()T 24 opinions,which I believe is included in the 25 question, I am-instructing him not to answer as
-e-
,y
,--r--
g Potts 337 2
to that.
3
-Insofar as you ask whether or not he 4
received facts, a fact which stated that something
(
5 that was' said was false, I will permit the witness 6
to answer.
7 Is my objection clear to you?
8 MS. WAGNER:
I think it is.
9 Q
Is it clear to you?
10 A
It's not clear to me.
(
11 MR. KIRSCHBAUM:
Can I have a minute.
12 (Recess taken.)
g s-13 MS. WAGNER:
Please read back the last 14 question.
15 (Record was read back.)
IG MR. KIRSCHBAUM:
The witness is instructed 17 to answer as to facts that he received.
18 MS. WAGNER:
At any time?
19 MR. KIRSCHBAUM:
At any time, yes.
But 20 facts only.
21 A
Subsequent to the accident, we received 22-both NRC bulletins and B&W instructions to revise the 23 operating procedures for the high pressure injection
[}
24 system.
As I mentioned earlier, I have read in the v
25
'Kemeny Commiss' ion report that changes were required
1 Potts 238 2
in the operation of that system.
. hat change or changes are you referring to?
3 Q
w 4
A The operation period of an HPI system was 5
defined under several conditions.
Some instrumentation
(
6 such as a Tsat meter was installed.
I don't recall the 7
additional instructions, but there were several.
8 Q-Has any analysis been done by Metropolitan 9
Edison or General Public Utilities to the best of your 10 knowledge with respect to operation of HPI since the 11 accident?
12 A
I'm not certain it is completed but GPU is 13 making an analysis.
14 Q
It is making an analysis of the hardware 15 aspects of HPI?
16 A
The operation and perhaps the hardware.
17 Q
Do you know who is involved i,n doing that?
18 A
Not specifically the individu'als.
19 Q
Do you know which departments?
J 20 A
The Engineering Department.
21 Q
This is of GPU?
22 A
Yes.
23 9
.Did you personally make any study of the
. ~
( -)
24 HPI system after the accident?
25 A
No.
p
,----m
- ~.
1 1
Potts 139 O
2 i
Q What aspects of the accident did you study, 3
if any?
4 A
I have read a number of reports.
I'm not
(
5 certain that is a study in your use of the word.
6 Q
Did you have any defined purpose for reading 7
reports or were you just reading them for your own interest's sake?
O A
For my own interest's sake.
10 Q
Have you been involved sin'ce the accident 11 in any post-accident analyses performed by Met Ed or GPU or any related company?
\\
13 MR. KIRSCHBAUM:
Read that back, please.
I4 (Record was read back.)
MR. KIRSCHBAUM:
Post-accident analysis of 16 l what?
MS. WAGNER:
Anything.
18 MR. KIRSCHBAUM:
Anything in the world?
19 MS. WAGNER:
Anything related to the accident.
20 MR. KIRSCHBAUM:
Any aspect of the accident?
21 MS. WAGNER:
Yes.
2 A
I was interviewed by the NRC subsequent 3
9 to the accident and relative to the accident.
(")T o4
~
\\_
Q Have you been involved in any analyses being 95
~
conducted by Met Ed or GPU with' respect to the accident?
4 s
r g
e
,rm.,
~-
1 Potts 140 4
2 A
NO-3 Q
Have you ever as part of your responsibilities 4
in any position at Metropolitan Edison prior to the
(
5 accident become involved in the review of events 6
occurring at other plents for possible application to 7
TMI ? -
8 A
We had a system in Licensing that reviewed 9
industry experience type documents which included --
10 well, the experience of the industry.c 11 Q
Do you recall what documents those were?
12 A
One of those documents was the Atomic
}
13 Energy Clearinghouse document.
Ther may have been 14 others.
15 Q
Did you review personally the Atomic Energy t
16 Clearinghouse document?
17 MR. KIRSCHBAUM:
Are you referring to any.
und$rstand, it is 18 particular document or as I
~
19 a publica. tion with many different issues.
20 Q
Did you review it as a matter of routine?
21 A
Yes.
22 Q
Did you review it during the entire period l
23 you were supervisor of Licensing as a matter of routine..
n
( s) 24 assuming every now and then you might have missed.one?
25 A
- Yes, j
i 1
Potts 142 1
2 Q
How did you review it?
Did you-read avery 3
Page of it?
4 A
It was routed to a number of people.
When l
5 I received it on routing, I would -- the Atomic Energy G
Clearinghouse has an index on the first page and I 7
would either read the entire thing or select from the 8
index articles that I wanted to read.
9 Q
How did you make selections from the 10 index?
t 11 A
One example that comes to mind would be a 12 boiling water reactor which we didn't have.
Then I may O'-'
13 or may not read that.
14 Q
Did it ever occur that you r ad something 15 in the Atomic Energy Clearinghouse publication which 16 you thought was relevant.in some way to TMI?
17 A
Yes.
18 Q
In such an instance, what did you do?
19 A
Fill out an action item request to have 20
-someone review the incident to determine its 21 applicability to the TMI unit.
22 Q
When you say to have someone review it, would 23 that be somebody in Licensing?
tm
-(
).
24 A
It might be Licensing, Engineering or the w
25 operating staff.
Potts 142 Q
Do you know if the action item requests were maintained in any files?
3 A
I don't know that.
4 Q
If you wrote an action item request, would
(
you send one copy to somebody else and keep one usually?
Did you have any procedure?
7 A
The copy did go to someone else.
I didn't keep a copy.
Q Did your secretary keep a copy?
l 10 t
1 A
I don't know.
11 Q
Do you ever instruct your secretary to keep 13 A
No.
Q How many copies of the action item request l a, are there in the normal -- I think you said it was a pressure sensitive document?
A Yes.
I don't remember.the number of pages to that.
Q But there are several?
.A Several.
21 Q
If someone in Licensing determined an event was of relevance to TMI, what would be the next step in the~ procedure?
- s. s MR. KIRSCHBAUM:- Can we make the question
.m A__u.um-_____-_____-____.-_...________._____.-_________-__.m.__m A_um-_
u.
1 Potts 143 2
definite or do you want to make it as a matter i
of routine?
3 4
MS. WAGNER:
A matter of routine.
(
5 A
It would depend.
The action would depend 6
a little bit on the type of item.
It may be directed 7
to the operating staff or the engineering group.
The 8
form was filled out and the article or the information 9
of interest was attached to the form.
It would go to 10 the individual.
The action item-form tself had a place 11 for a due date that would be returned.
That was part 12 of the computer system that I got to key me in that
%/-
13 something was due back to me.
14 Sometime in that period of time an answer 15 would come back with the article that created the 16 interest, created the action item.
The review chain 17 for its return would be through its management chain, 18 it to me.
And then depending upon the risults of the d
19 review, subsequent action may take place.'
20 Q-Did it ever occur that Licensing would 21 be taking the subsequent action that you have described?
22 MR. KIRSCHBAUM:
With respect to any 23 action item request?
[ ')
24 MS. WAGNER:
.Yes.
\\s l
25 A
well,.should one of those action-items be t
4 4
1 Potts 144
("%
\\'
2 generated as a result of a regulation change, a permit A
3 change, that kind of thing, yes, it would be natural 4
for Licensing to take that action.
(
5 Q
Did it ever occur to you in reading the 6
Atomic Energy Clearinghouse reports that some operational 7
event would be applicable to the TMI-1 or 2 while you 8
were in Licensing?
9 A
I don't recall specific events, but that 10 would be that would have been one of its purposes.
11 Q
Did you ever review any documents other 12 than Atomic Energy Clearinghouse reports?
s
~
13 A
Yes.
i
~
14 Q
Do you recall what those documents were?
15 MR. KIRSCHBAUM:
What documents are you 16 talking about?
17 MS. WAGNER:
In this area of(reviewing 18 events at other plants for applicab'ility to TMI.'
l' 10 A
As I said earlier, the Atomic' Energy 20 Clearinghouse is the one document that I recall.
21 Q
Do you recall a document called " Current 22 Events Power Reactors"?
23 A
No.
[~)\\
24 Q-Do you recall a document called " Nuclear 25
_ Power Experience"?
v
1 Potts 145
-m.
V-A No.
2 Q
Do you know what The Gray Book is?
3 4
A The Gray Book is one of several status books the NRC puts out.
-(
5 6
Q Did you ever review The Gray Book?
7 A
Yes.
8 Q
During the time that you were a supervisor 9
of Licensing?
10 MR. KIRSCHBAUM:
As I undgrs tand it, The 11 Gray Book also is in issues, consists of --
12 MS. WAGNER:
Issues.
~>
13 MR. KIRSCHBAUM:
Whether he ever reviewed 14 any issues of The Gray Book?
15 MS. WAGNER:
Yes.
e 16 A
Yes, I have.
17 -
Q Did you review every issue of The Gray Book 18 during that time period, barring periodid omissions for 19 vacations or whatnot?
20 MR. KIRSCHBAUM:
Your question is did he 21 have a routine of reviewing it?
Because you said 22
- all except not all."
1 23 Did you ever have a routine?
()-
24 THE WITNESS:
I don't recall if The Gray
'l
\\.,'
\\
25 Book was part of that routine'or not.
1 Potts 146 f^\\
~
2 Q
Did you ever hear, prior to the accident, fad cument entitled "The Reactor Safety Study" or 3
4
" WASH-1400"?
(
5 A
Yes.
6 Q
Did you see it prior to the accident?
7 A
I'm not certain if I have seen the WASH-1400 8
report prior to the accident.
9 Q
What did you hear about it prior to the '
10 accident?
e 11 MR. KIRSCHBAUM:
Are you asking for 12 conversations concerning WASH-14007 C'.
13 MS. WAGNER:
He said he heard of it.
14 Q
What did you hear of it?
15 A
What I-recall of it is that it was a 16 probablistic study of the safety in reactors.
One l
17 author's name which I cannot pronounce correctly --
18 Q
Rasmussen?
a follow-u'p to an earlier 19
'A Thank you.
It was 20 report which I believe was No. 740 and it had-a prefix.
f' 21 I don't recall.
22 Q
Do you recall whether you were aware prior 23 to the accident that this report was available some
/~h
./
- 24 place in Metropolitan Edison physically?
C 25 A
'I don't recall if it was available or not.
_ _ _ _ - _ = - _ _ _ _.
l
.1 Potts 147 2
Q Was there a library at Metropolitan Edison n the Three Mile Island location?
3 4
MR. KIRSCHBAUM:
When?
(
5 MS.-WAGNER:
At any time.
e 6
MR. KIRSCHBAUM:
Whether or not he was 7
stationed there?
8 Q
Well, if you know about it, yes.
g A
There is a library.
I don't know if there 10 was a library prior to the accident.
(
11 Q
Do you know whether at any time during 12 your tenure at Metropolitan Edison, Met Ed or GPU did O'
13 any analysis to determine which accid nts were most 14 likely to happen, a probablistic analysis similar to-15 WASH-14007 16 A
I don't know.
17 Q
Prior to the accident, did you ever see a 18 document which is sometimes called the Michelson Report?
19 A
Prior to the accident, I had'not seen the 20 Michelson Report..
21
'Q Did you see-it after the accident?
22 A
Yes.
23 Q
In what context did you see it?
j (s') '
24 MR. KIRSCHBAUM':
What does that mean?
q 1
25
- Q When did you see it?
1 Potts 148
("%
~
G~
2 A
Some months after the accident I got a copy f it.
3 4
Q Were you asked to review it?
(
5 A
No.
6 Q
Who sent it to you?
7 A
It was given to me by I don't remember g
who gave it to me.
It wasn't sent.
9 Q
Was there any purpose, to your knowledge, 10 of giving it to you?
11 MR. KIRSCHBAUM:
Any purpose on the part of 12 whom?
b 13 MS. WAGNER:
Anybody.
14 MR. KIRSCHBAUM:
I assume you mean the 15 Person who sent it.
Are you asking him to say 16 whether he knows of anybody's purpose?
17 MS. WAGNER:
Yes.
~
18 A
The purpose was to show that'the accident 19 was a -- a thing similar to the accident was described 20 by a man named Michelson.
21 Q
Was the giving of this report to you part of C
22 any involvement that you had with any analysis of 23 precursors to_the accident?
(
24 A
No.
The engineer gave it to me in a
~ kj) '
25 discussion with me.
I don't recall much more than that.
1 Potts 149 J(3
~
2 Q
Did you ever become familiar with an incident whicn occurred in March of 1978 at the Rancho 3
4 Seco plant of the Sacramento Municipal Utilities l
5 District in which a PORV failed open and depressurizatior 6
occurred?
7 MR. KIRSCHBAUM:
I object because it is 8
compound. You asked if he ever heard of an 9
accident or incident and you asked him about a 10 number of characteristics about the incident.
11 He may have heard about the incident without
' 12 hearing all the characteristics.
O
^ tell 13 Q
If you know of any aspect, please 14 me what you know about it.
15 MR. KIRSCHBAUM:
Are you asking pre or 16 post or both?
17 MS. WAGNER:
Pre.
18 MR. KIRSCHBAUM:
Before the accident in 19 2979, had he ever heard of an incident in '78 l
20 that you referred to?
21 MS. WAGNER:
Yes.
- k.
.22 A
I don't recall previous to the accident 23 a particular SMUD incident that you have described, n()
24 Q
Did you hear about it.at'any time after 25 the accident?
1 Potts 150 2
A Yes.
3 Q
What did you hear about it after the 4
accident?
(
5 A
It was mentioned in the Kemeny report.
It 6
has been discussed among several of the engineers.
It involved an electrical problem created by a lightbulb.
7 8
Q Do you remember anything else, being told 9
anything else about the incident?
10 MR. KIRSCHBAUM: Post-accident?
11 MS. WAGNER:
Yes.
12 A
The pressurizer level was extremely low.
O 13 The PORV opened.
That's about it.
14 Q
Did you ever have periodic contacts with 15 anybody from the Rancho Seco plant prior to the accidenti 16 MR. KIRSCHBAUM:
Did you ever have periodic 17 contacts?
I think that might be a, contradiction.
any time did you have per[ odic 18 Q
At contacts?
19 A
Yes.
~
l 20 Q
With whom?
21 A
Mr. Raasch who was the B&W's owners group representative from SMUD.
22 23 Q
Did it ever occur at-the owners group that I l 24 some representative of a plant'would discuss an event G
25
.which would occur at a plant?
e-
--o n
,y-
-sw
1 Potts 151 OV.
2 A
I don't recall a specific event that was discussed.
3 4
Q Do you recall whether as of any matter of
(
5 routine, events would be discussed?
6 A
I don't recall that.
7 Q
Have you ever heard of~the B&W users group?
8 A
Yes.
9 Q
Do you know what the users group is?
10 A
Not specifically.
(
11 Q
Do you know if anybody from Metropolitan 12 Edison was a representative on the users group?
(~
s
'~
13 A
I don't know that.
14 Q
Did you ever have any contacts with the 15 users group?
e 16 A
I believe I attended one meeting but I'm 17 not certain.
18 Q
Do you recall anything about khe circums t an ces 19 under which you might have attended one meeting?
20 MR. KIRSCHBAUM:
He can't1 recall whether 21 he attended the meeting.
I 22 Q
What else can you recall about this?
23 MR. KIRSCHBAUM:
About what?
O
(
i 24 MS. WAGNER:
lihat he just testified to.
w/
25 MR. KIRSCHBAUM:
He. testified to not being i
L
~
~
~_.
~..
Potts 152 g
able to recall whether he may have attended more 2
than one meeting.
4 3
MS. WAGNER:
He obviously recollects 4
l something about one meeting.
I want to know-(
5 what else he recollects.
6 MR. KIRSCHBLUM:
I don't know that is his 7
i 8
testimony, that he recollects something-about one meeting.
He recollects the possibility of g
10 having attended a meeting.
If h,e recalls the 11 meeting, certainly he ~ should be -- he is free'to 12 testify to that.
- ~)
k_/
13 A
Will you repeat your question, please.
14.
Q What do you recall, if anything, about 15 the possibility that you may have. attended a meeting 16 of the users group?
17 MR. KIRSCHBAUM:
I. object to the question 4
18 as to form.
19 A
The users group was attended by the 20 superintendents of the plant and'it's extremely vague l
21 fr m that-point on.
I think I was at a meeting with the unit 22 j-23 superintendent, that was the. users group.
Since I'm f
g '1 24 f
not certain what the users-group was,.it's difficult
' kJ e
to be definite.
E 25 1
i
,..v
1 Potts 153 e).
2 Q
Did you ever attend operating experience 3
seminars held by Babcock & Wilcox annually?
4 A
No.
(
5 g
Did you ever hear about an event which 6
occurred at Davis-Besse on or about September 24, 19777 7
MR. KIRSCHBAUM: Pre-or post-accident?
8 MS. WAGNER:
Pre-accident.
9.
A I don t recall a September event at 10 Davis-Besse.
1 11 Q
Did you hear about such an event after the 12 accident or you have never heard about it?
13 A
Subsequent to the accident, I have heard
~~
14 of that event.
15 Q
What did you hear about the event after the 16 accident?
17 MR. KIRSCHBAUM:
Are you asking for 18 conversations, things he read?
19 MS. WAGNER:
Anything, from any source.
l l
20 Q
What did you hear had happened at l-21 Davis-Besse?
22 A
Davis-Besse was operating at low power-i-
l 23 level at approximately 9 percent power level.
They had f~q l
(
j.
24 a trip which resulted in the PORV opening.and remaining v
. 25 OPen.
g
1 Potts 154 N
2 Q
Do you recall anything else?
A I recall it was a subject of much discussion 3
4 in the Kemeny report.
5 Q
Do you recall reading about any event 6
occurring at any plant prior to the. accident in any of 7
the documents that you reviewed periodically in which 8
a PORV had stuck open or stayed open for some reason 9
at a time when the PORV should have-been closed?
10 MR. KIRSCHBAUM:
Let's hedr that question 11 again.
12 (Record was read back.)
,,)
s
~'
13 MR. KIRSCHBAUM:
You are asking whether he 14 recalls reading that before the accident?
15 MS. WAGNER:
Right.
16 A
I don't recall reading that before the 17 accident.
18 Q
Before the accident, had you ever heard 19 of a PORV sticking open?
20 A
I don't recall any PORV sticking open.
21 Q
Do you recall ever speaking to Fred Miller' 22 about anything?-
23 MR. KIRSCHBAUM:
Ever?
r 1 !,
)
24 MS. WAGNER:
Ever.
.v.
'25 A-No.
L.__
1 Potts 155 2
Q Did it ever happen that you would, during the time period you were Licensing superintendent, speak 3
4-to personnel at other plants about licensing matters?
(
5 A
Yes.
6 Q
Do you recall any instance in which that 7
occurred specifically?
8 A
Yes.
9 Q
Can you describe several for me?
10 A
During the period of smallt break LOCA 11 reanalysis, there were regular conversations between the 12 licensing representatives from several plants.
O
\\-
13 Q
Do you recall that ever oc urring on another A
14 occasion?
15 MR. KIRSCHBAUM:
What is the that" 16 referring to?
17 MS. WAGNER:
Speaking to peop,le at other 18 plants about licensing matters.
19 MR. KIRSCHBAUM:
His speaking ~ to people
. 20 at other plants?
21 MS. WAGNER:
Right.
~
C l-22-A I recall calling Crystal RiverLabout an
(-
23 operation.
[ )-
24 Q
Do-you recall what operation that was?
q./
25 A
It was anfoperation of-the decay heat' pump.
r
+,a-
=v
-e
+-
,, w v 1
y w
a
1 Potts 156 b,ey.
Q Do you recall why you were calling 2
3 Crystal River?
4 A
I recall the shaft on the pump had sheared l
5 at crystal River and I called to find out what 6
information I could on it.
7 Q
Do you recall a time when you were Licensing 8
supervisor in which there was a -concern among -- there 9
was concern at Met Ed about depressurization events?
10 A
I assume you mean a particular 11 depressurization event?
12 Q
I mean in general there was a concern about O*
13 depressurization events.
14 A
Yes.
15 Q
When was that?
16 A
I don't know the time period.
17
'Q It was during the time when-you were 18 Licensing supervisor?
19 A
Yes.
20 Q
What was the concern?
21 MR. KIRSCHBAUM:
What was the concern
(-
22 expressed to him?
23 Ms. WAGNER:
What.is the concern he is n
(
I 24 recalling.now.
%,J 25 A'
.TMI-2 had tripped, the steam safety valves
,w.
=
,-M..ww
1 Potts 157 7x t\\
2 had opened and several remained open, causing a depressurization.
3 4
Q Do you recall that concern about that event
(
5
. was the cause of any conversations by people from other 6
plants, conversations had by you?
7 A
No, I don't recall that.
8 Q
Do you recall ever having a telephone 9
conversation with Fred Miller about anything prior to' 10 the accident?
t 11 A
No.
12 MS. WAGNER:
I would like to have marked as 13 B&W 384, a two-page document, bo h pages are 14 entitled " Verbal Communications Form."
They are 15 dated 11/8/78 and both appear to be submitted e
16 under the name of W.
E.
Potts.
17 (Two documents, both entitled " Verbal-and both date[ 11/8/78, 18 Communications Form" one 19 bearing the heading "TECO" and the other bearing 20 the heading " George Hurl - Toledo Edison Company" 21 marked B&W Exhibit No. 384 for identification, 22 as of this date.)
l 1
23 Q.
Have you ever seen B&W 384 before, f) 24 Mr. Potts, either the first or second page or both?
i v
25 A
I don't recall seeing these before.
v
_1
1 Potts 158 2
Q Have you ever seen forms such as these, 3
verbal communications forms?
4 A
Yes.
- C 5
Q Are they forms which you used to record 1.
6 conversations upon?
7 A
Yes.
8 Q
The first page of B&W 384 in'dicates, "I
g called Fred to discuss Davis-Besse 1 cooldowns.
Fred
+
10 informed me that their first cooldown was in September 11 1977, when the EM relief valve stuck open.
During 12 that cooldown the RC pressure dropped to 900 psi very
' (~)'
13 rapidly, aad' exceeded the cooldown rate contained in i
14 the FSAR."
15 Do you recall having this conversation 16 with " Fred"?
4 17 A'
No.
18 Q
Can you recall creating this memorandum?
19 A
No.
20 Q.
Down at the bottom there are cc's which 21 include'GJT, JGH, LGE, I'believe,'or LWH.
22 Do you know who any of those people are?
23 MR. KIRSCHBAUM:
Does he know who is N T
(
j 24 initialed on'the document?.
' 25
.Ms. WAGNER:
They' appear to bel typewritten w
we
,w w
w-'
1 Potts 159
(*
~
~ N,].
2 in.
3 Q
Do you know to whom copies would be sent, 4
what these initials would mean?
(
5 A
Yes.
6 Q
Who are they?
7 A
George Troffer, Jack Herbein, Roy Harding.
8 Q
On the second page of B&W 384, some initials 9
appear to be written in above the typewritten name 10 "W.
E.
Potts."
E 11 Do you recognize that handwriting?
12 A
That appears to be my initials.
13 Q
Do you have any reason to believe that 14 B&W 384 doesn't accurately reflect phone conversations 15 that you had?
16 MR. KIRSCHBAUM:
Objection as to form.
17 The witness testified that he doesn't recall the 18 conversations that these documents reflect.
19 A
I don't recall the conversations.
I have 20 no other reason to believe it.
21 Q
Mr. Potts, I would like to show you a 22 document previously marked as B&W Exhibit 172 and it is 23 the issue of " Current Events Power Reactors" dated rx
-(
J-24 December 1977..
25 I ask-you if you have seen that document
1 Potts 160 (a~T
~
2 before?
3 When I ask you if you have seen it before, 4
I will not include the first page necessarily but I am
(
5 really talking about the publication inside.
The 6
first page is
- a. routing slip which you may or may not 7
have seen.
8 MR. KIRSCHBAUM:
But you are speaking j
9 about this particular issue 7 10 MS. WAGNER:
Yes.
E I
11 Q
Do you recall seeing that publication before?
' 12 A
No, I don't.
13 Q
Do you recall, however, seeing " Current 14 Events Power Reactors" issues?
15 A
I don't recall.this publication.
t 16 MR.
KIRSCHBAUM:
You don't recall seeing 17 the publication entitled " Current Events Power 18 Reactors"?
It doesn't refresh you recollection 19 as to the entire publication?
20 THE WITNESS:
I don't remember this 21 publication nor this issue.
22 MR. KIRSCHBAUM:
That is all I wanted to 23 clarify.
(
24 MS. WAGNER: I would like to'take a.two-minute 25 break, please.
i 1
Potts 161
/~'i
~
U-2 (Recess taken.)
MS. WAGNER:
I would like to have marked 3
4 as B&W 385, a one-page document entitled "Small
(
5 Break LOCA" and bearing the production stamp W20796.
6 7
(One-page document entitled "Small Break 8
LOCA" bearing production number W20796 marked g
B&W Exhibit No. 385 for identification, as of 10 this date.)
t 11 Q
Have you ever seen that before?
12 A
I didn't see this document prior to the 13 accident.
14 Q
But you saw it after the accident?
/
15 A
I don't believe I have seen it after the e
16 accident with the exception of the last few days 17 perhaps.
18 Q
Do you know whose handwriting it is?
19 A
I don't recollect the handwriting.
20 Q
Do you recall during the discussions that 21 you were involved with concerning the small break LOCA 22 problem and the fix which we have discussed today, do t
23 you recall any discussions of the Davis-Besse analysis
(_3 f )
24 concerning operator action?
25 A
No.
1 Potts 162
'~) '
2 Q
What is a cavitating venturi?
A
.An orifice device to control flow.
3 4
Q Prior to the accident at TMI-2 in March of
(
5 1979, had you heard of an event occurring on TMI-2 on 6
March 29, 1978 which caused a reactor trip?
4 7
A I don't recall a -- March 21st was it?
8 Q
29th, I believe.
I 9
A I don't recall that.
10 Q
Do you recall hearing of any event occurring 11 at TMI-2 before the accident in which the TMI-2 PORV 12 remained open at a time in which it should have been
(~)
k' 13 closed?
14 MR. KIRSCHBAUM:
Does he recall hearing 15 about that before the accident?
i 16 MS. WAGNER:
Yes.
17 A
No.
j 18
-Q Did you hear at any time before the~
~
i 19 accident of any discussions concerning the need for a 20 indicator light in the control room of TMI-2 with 21 respect to the position of the PORV?
22 A
No.
23 Q
I would like to show you a-document l ~(/)
24 previously marked as B&W 181 and which has been 25 identified as the licensee event report for the event
1 Potts 163 2
on March 29, 1978.
3 My question is, have you ever seen this 4
before?
l 5
A I don't recall seeing this document prior i
6 to the accident.
7 Q
Does the document refresh your recollection 8
at all with respect to anything you might have heard 9
about that particular event prior to the accident?
E 10 A
No.
i 11 Q
I would like to show you what has been 12 previously marked as B&W 184.
It is a Unit 2 PORC
~
13 input for the special report required.by Tech Spec 3.5.2 14 concerning the March 2 9 ", 1978 event."
15 Again my question is, have you seen this 16 document before?
17 A
I don't recall seeing this document pri'or 18 to the accident.
19 Q
The f' irs't page of the document indicates i
20 that a cc of the document was sent to you.
21 Do you have any current knowledge as to 22 why a copy would have been sent to you?
l l
23 MR. KIRSCHBAUM:
Are you asking why, as a l
i
()
24 matter of routine, a document of this type was l
\\
l 25 sent to the witness or why this particular
~
1 Potts 164 (O) 2 document was sent to the witness?
Q Answer first with respect to this type of 3
4 document.
l 5
A This type of document would have been sent 6
to me so that the Licensing engineer could start 7
preparing the form the NRC had issued for reporting g
this type of event.
l 9
Q Do you mean the LER form?
10 A
Yes.
This would be the fogm.
11 Q
Would you read, as a matter of routine, 12 these documents when they came to you?
13 A
Yes.
14 Q
Did you have any purpose in reading them?
15 A
Yes.
16 Q
What was that purpose?
17 A
To insure that the Licensing. engineer had 18 sufficient information to make his report.
To determine 19 the date -that the report would be due to the NRC.
20' Q
Did you then review the draft of~the computer 21 form such as B&W 181 prior to its being sent to the l
22 NRC7
~
23 A
As a matter of routine, I would have
()
24 reviewed that form.
25 Q
Would you have reviewed that form as a l
l
l 1
Potts 165 f\\
'v.
2 matter of routine to determine whether everything in the document such as this, 184, that was necessary to 3
4 go into a document such as B&W 181 was, in fact, in
(
B&W 187?
5 6
A In addition to other things, yes s 7
Q A document such as B&W 184, would that g
document normally be sent any place outside of 9
Metropolitan Edison, do you know, as a matter of 10 routine again?
k, 11 A
I don't know.
12 Q
Would Licensing send it out of Metropolitan (2) 13 Edison?
l 14 A
I don't know.
15 Q
As a matter of routine, did the Licensing 16 Department ever take any action based upon what was 17 in a report such as B&W 184 other than to prepare a i
18 form such as B&W 1817 19 MR. KIRSCHBAUM:
Read the question back, l
P ease.
20 21 (Record was read back.)
1
(_
4 l
22 MR. KIRSCHBAUM:
I object to the question 1
23 because you have used the concept of a routine
( w) 24 together with a concept of whether they ever did 25
'anything which is_the opposite of a question
('
1 Potts 166
(~%
~
w/
2 considering routine.
3 Q
Was there a routine?
4 A
Yes.
(
5 Q
What was the routine?
6 MR. KIRSCHBAUM:
As to what?
7 MS. WAGNER:
Whatever he said "yes" to.
8 A
The routine was to review these when 9
commitments were made to accomplish something, then an 10 action item was drawn up to have that' commitment met 11 by its due date.
12 Q
Do you mean when somebody committed in a
[_s'\\
'~'i 13 document to do something, Licensing would do an action 14 item for that commitment?
15 A
Yes.
16 Q
It wasn't only if Licensing had committed 17 to do something that would cause Licensing to draw up 18 an action item, is that correct?
19 A
If we were committing to somebody Licensing 20 was submitting a document to, such as an LER, then we 21 would perform the action item or generate the action 22 item.
23 Q
Do you know with respect to B&W 184 whether
('%
l
(
)
24 an action item was generated for the conclusion on 25 page 2, conclusion No. 4 under " Equipment Performance"
1 Potts 167 g
l which says " Position indication for RC-R2 should be 2
3 provided.in the control room"?
4 A
I don't recall that specific equipment i
5 performance recommendation.
6 Q
Is this the type of thing for which you 7
have indicated Licensing would normally, as a matter 4
8 of routine, create an action item?
9 A
Yes.
10 Q
Similarly, would such an a'~ction item be 11 created with respect to a conclusion such as the one 12 under " Procedures" which indicates a need to develop
($)
13 certain procedures?
14 A
Yes.
15 Q
When such an action item was created, as 16 a matter of routine, who was it who was designated --
17 who had to take the action?
Somebody in,the Licensing 18 Department or somebody else?
19 A
In both of these conditions, it would be' 20 someone else.
21 Q
And the purpose of Licensing creating these.
22 action items is so Licensing can bother someone else l
23 and say, "Have you done it yet," is that the basic 24 theory behind this?
25 A
The word " bother" --
l-1 Potts 168 O
2 Q
To remind somebody that the due date has 3
come up?
4 A
Yes.
(
5 Q
I would like to show you a document 6
previously marked B&W 193.
It is a special report 7
- concerning the TMI-2 ECCS actuation on November 7, 8
1978.
9 Look at the document and tell me if you I
10' have seen it before, please.
11 A
I don't recall seeing this document.
12 Q
Do you recall the event described in the O
13 document?
14 A
No, I don't.
15 Q
The name of the preparer which appears on 16 the LER form is J.
F.
Stair,-S-t-a-i-r.
17 Do you know who that is?
18 3
y,,,
19 Q
Who is that?
20 A
Mr. Stair is an engineer that works at 21 Met ~ Ed.
22 Q
He is not in the Licensing Department, is 23 he?
24 A
He's not now.
s/
25 Q
Was he at the time this report was created?
1 Potts 169
[\\
U.
2 A
I don't recall the date when he left 3
Licensing.
4 Q
The last page of the document indicates
(
5 in the second to the last sentence of the second to the 6
last paragraph, " Calculations show the pressurizer was 7
not empty during the transient."
8 Do you recall any calculations done with 9
respect to this transient and concerning the emptying 10 of the pressurizer?
E 11 A
Yes.
12 Q
What do you recall about that?
[T
\\l 13 A
I recall a trip, I'm'not certain which trip
.i 14 or what date it was, that the indication of pressurizer 4
15 level was lost or low in which the TMI engineering group e
16 made calculations to determine if the level had been 17 lost or just went below their level indication and I 18 recall B&W also making calculations.
19 The calculations indicate that we had not 20 lost level.
We had lost indicator level.
21 MR. KIRSCHBAUM:
I don't know if that answer C
22 was responsive to the question.
I thought the 23 question dealt specifically with this.
(
24 MS. WAGNER:
My question deals with 25 calculations concerning pressuriser level.
l
t.
1 Potts 170 i ;,en
~k_
2 Q
Do you recall whether the calculations you
!j.
have described do relate.to this transient or are you 3
i i
4 nce certain?
4 j
l 5
A I'm n t certain.
i 6
Q Were you involved at all in reviewing or l
doing those calculations?-
1 6
8 A
No.
9 Q
Do you know if anybody in the Licensing 1
10 Department was?
t 11 A
The Licensing Department reviewed the report i
1 12 that said what the calculations said.
13 Q
Was there any particular person in-the y
T 4
. 14 Licensing Department who would, because of his or her
)
15 specific expertise, be the' person to review those sorts t
j 16 of calculations concerning pressurizer. levels during 17 the period when you were' supervisor of Licensing?
18 A
No.
l 19 Q
It.could have'been anybody in the department-j 20 A
I believe I testified that we reviewed'the 21-report that concluded from the calculations.that the l
22-level had not been lost.
I don't know that we reviewed 23 the-calculations themselves.
- (
24 Q
Would anybody in the-department review such 25 a report?
..I i~
1 Potts 171 i
fy.
i 2
A I don't know.
3 MR. KIRSCHBAUM:
You mean somebody 4
specifically?
(
5 MS. WAGNER:
Yes.
6 Q
was there somebody who, because of his or 7
her specific expertise, would be the person to review 8
that sort of a report?
9 A
There was not someone designated because 10 of his expertise to review that sort o'f report.
11 Q
You didn't have a pressurizer level i
12 specialist in the Licensing Department?
^
13 A
No.
14 Q
Did you have an understanding, prior to 15 the accident in March of 1979, as to whether or not the 16 loss of pressurizer level rather than the loss of 17 indication was a problem?
18 MR. KIRSCHBAUM:
Whether someone considered l
19 it a problem or whether he considered it a problemi 20 A
Whether you had any understanding as to 21 whether loss of pressurizer level was not something k-22 desirable in the operation of a nuclear power plant.
23 THE WITNESS:
Repeat that for me.
(v 24 (Record was read back.)
l 25 A
Yes.
_ -. - ~
1 Potts 172-2 Q
What was your understanding?
A If the level reduces below the heater 3
1 4
level, then it's necessary to determine if the heaters
(
5 are still functional.
6 Q
Did you have any understanding of any l
7 additional problems created by loss of pressurizer level?
8 MR. KIRSCHBAUM:
Pre-accident?
3 9
MS. WAGNER:
Yes.
I
~
10 A
I don't recall any furthert; understanding or 11 a different understanding.
12 Q
During the period that you were supervisor O
13 of, Licensing--did you ever review technical data reports i
l 14
-created by GPU Service Corporation or any other GPU 4
)
15 corporation?
16 MR. KIRSCHBAUM:
Does the question refer to
]_
17 a time period?
18 Q
While you.were supervisor of Licensing.
l 19 A
Yes.
20 Q
Did you review all such technical data 21 reports created with respect to events at TMI?
i A
No.
22 t
23 Q
Which ones did you review?
(
24 A
I recall reviewing safety analysis reports --
25 reviews of safety analysis reports from GPU on' reload
1 Potts.
173 2
report.
3 Q
I show you a document previously marked as 4
B&W 192 and ask you if you ever reviewed that document?
(
5 That is a TDR concerning the November 7, 1978 event at 6
TMI-2.
7 You are welcome to read the whole thing.
8 A
I haven't read the first three pages.
I g
don't recollect the document.
10 Q
I will refer you to page 1 1,- A.
Paragraph 11 C-5 indicates "Further analysis of these events using 12 computer simulation."
13 Under D it states, " Evaluate pressurizer 14 dynamic response including the effects of a larger 15 pressurizer."
16 were you ever aware of any computer simulation.
17 done to evaluate pressurizer dynamic reponse including 18 the effects of a larger pressurizer?
19 MR. KIRSCHBAUM:
Between the time of this 20 -
report and the accident?
21 MS. WAGNER:
Yes.
22 A
I didn't locate the paragraph.
23 Q
Do you have C-5 there?
24 A
Yes.
25 Q
It starts out, "Further analysis of these
i 1
Potts 174 a,
2 events."
subsection D concerning pressurizer dynamic 3
i 4
- response,
(
5 MR. KIRSCHBAUM:
What is your question?
i 1
6 Q
Were you ever aware of such a computer 7
analysis being done to evaluate pressurizer dynamic g
response?
9 A
No.
4 10 MS. WAGNER:
I have no mory questions about 11 this document so why don't we break now.
4 12 (Time noted:
4:30 p.m.)
4!O 13 14 s
j 15 William E.
Potts 16 Subscribed and sworn to before me i
17 this day of 1982.
b 18 19 20 g
21 1
22 1
20 24 I
25 i
1 175 p).
L 2
CERTIFICATE 3
STATE OF NEW YORK
)
- ss.:
4 COUNTY OF NEW YORK )
6 I,
ROBERT CAPUZELO a'
7 Notary Public within and for the State of New York, 8
do hereby certify that the foregoing deposition 9
of WILLIAM E.
POTTS was taken before tt 10 me on Thursday, January 7,
1982 11 That the said witness was duly sworn 12 before the commencement of his testimony and 13 that the within transcript is a true record of said 14 testimony; 15 That I am not connected by blood or 16 marriage with any of the parties herein nor 17 interested directly or indirectly in the. matter in 18 controversy, nor am I in the employ of any of the 19 counsel.
20 IN WITNESS WHEREOF, I have hereunto set
{
myhandthishW(, day of 21 1982.
co w, u,-,,
22 23 q
/
Om.
UN AuAuU 24 v
,c,,,,
c3,y,,sc 25 O
ie -
e 176 1
.J I N D E X WITNESS PAGE William E.
Potts 4
~pb;H 9i NUMBER FOR IDENT.
l 380 Resume of William E.
Potts 4
381 Two pages from GPU Service!
Corporation Manual with the heading " Division: Generation,
Subject:
NRC Regulation 10 CFR 21" bearing production numbers a
W15838 and W15839 82 i
382 Two-page memorand'um dated ~
January 8,
1979 f rom J.
G.
Herb'ein to GRC-2 Members and Alternates, subject "GRC-2 Membership Appointments" 95 383 Document entitled "TMI Unit 2 Generation Review Committee".'
97 7
384 Two documents, both entitled l
" Verbal Communications Form",
l and both dated 11/8/78, one bearing the heading "TECO" 1
and the other bearing the heading " George Hurl - Toledo i
3 Edison Company" 157 i
385 One-page document entitled "Small Break LOCA" bearing I
. production number W20796 161 k
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