ML20072J078
| ML20072J078 | |
| Person / Time | |
|---|---|
| Site: | Three Mile Island  |
| Issue date: | 11/17/1981 |
| From: | Ross M METROPOLITAN EDISON CO. |
| To: | |
| References | |
| TASK-*, TASK-01, TASK-02, TASK-1, TASK-2, TASK-GB NUDOCS 8306290912 | |
| Download: ML20072J078 (201) | |
Text
_ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ .
un dab UNITED STATES DISTRICT COURT
/~ SOUTHERN DISTRICT OF NEW YORK i
-- - - - - - - - - - - - - - - - - - - -x GENERAL PUBLIC UTILITIES CORPORATION, JERSEY CENTRAL POWER & LIGHT COMPANY, METROPOLITAN EDISON COMPANY and : l FENNSYLVANIA SLECTRIC COMPANY, Plaintiffs, 80 CIV. 1683 1
- (R.O.)
-against- l
- 1 THE BABCOCK & WILCOX COMPANY and ;
J. RAY McDERMOTT & CO., INC., :
f v
Defendants. :
-x l
Deposition of Metropolitan Edison f
V Company, by MICHAEL J. ROSS, taken by l
Defendants, pursuant to Notice at the Host Inn, 4751 Lindle Avenue, Harrisburg, Pennsylvania, on Tuesday, November 17, 1981, at 9:15 o' clock in the forenoon, before Joseph R. Danyo, a Shorthand Reporter.
O B306290912 811117 PDR ADOCK 05000289 T PDR Lv
. DOYLE REPORTING. INC CERTIFIED STENOTY PE REPORTEF 369 Lex t N GTC H AvtNut WALTER SH APIRO C.S.R. New Yenx. N.Y. 1o017 CH ARLES SH APIRO, C.S.R. TELapwoNE 212 - 867 822Q
r i
t 1 2 2 APPe arances:
3 WE, SCHOLER, FIERMAN, HAYS & HANDLER. ESQS.
- Attorneys for Plaintiffs !
! 4 425 Park Avenue
' ANDREW MacDONALD, ESQ.,
By:
6 of Counsel
, 7 8
DAVIS POLK & WARDWELL, ESQS.
g Attorneys for Defendants One Chase Manhattan Plaza 10 New York, New York 11 By: KAREN E. WAGNER, ESQ.
and-l 12 K. ANN MCDONALD, ESQ.,
(
- l. 13 of Counsel j 14 ,.
15 Also Present: !
L
)
16 SUSAN HANSON e-17 r
18 gg i
20 i
- 21 22 23 I ,
24 - . .l O 25 e-= - - - .v e . -.v,w - . - . - , , - , , - - ,. --& 3 . .e, , , , ,,-.,-,#-r _ - _ . . , ,.,_,,,.p_ 4 . , .,..,_.m ... - ,
t 1 3 i
' 2 O 3 IT IS HEREBY STIPULATED AND AGREED 4 by and between the attorneys for the j -g 5 respective parties hereto that the sealing, 6 filing and certification of the within
- deposition be, and the same hereby are, g waived; and that the transcript may be 9 signed before any Notary Public with the 10 same force and effect as if signed before l
11 the Court. .
2 12 IT IS FURTHER STIPULATED AND AGREED 13 that all objections, except as to the form 14 of the question, shall be reserved to the r
15 time of trial.
16 J
g-18 j 19 i i 20 I 21 9 22 23 l 1
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1 4
~
2 M I CHAE L J. ROS S, residing at 3 225 South Delta Street, Mount Joy, Pennsylvania, 4 having been first duly sworn by the Court 5 Reporter (Joseph R. Danyo), was examined and ll).
6 testified as follows:
7 MR. MacDONALD: I want to turn over two 8 notebooks of material and one folder for your 9 review which are unfortunately originals of 10 training material which seems to be related to 11 Unit 2.
12 I will give these to you for your custody 13 to look at.
14 EXAMINATION BY MS. WAGNER:
15 Q Where are you presently employed?
16 A Presently employed by Metropolitan Edison.
II Q How long have you been employed by them?
18 A Approximately 13 years.
19 Q What did you do before that?
1, 20 A Before Metropolitan Edison I was in the 21 U.S. Navy approximately eight years.
22 Q Before that?
23 ! A High school.
l ;
24 MS. WAGNER: I would like to have marked
, m l
- s. ) -25 as B&W Exhibit 300, a document which I believe 1
l 1 Roon 5 2 to be your resume, a three-page document.
3 (Resume of Michael J. Ross consisting of 4 three pages marked B&W Exhibit 300 for identification, as of this date.)
lll 5 I Q Have you ever seen this document before?
6 7 A Yes, I have.
8 Q Can you tell me what it is?
9 A It is a resume.
10 Q Was it prepared by you?
11 A Yes.
12 Q Does it accurately reflect your job 13 experience?
14 A It does.
15 Q During high school, did you ever study 16 Ph ysics?
17 A I don't recall.
18 Q Chemistry?
19 A Yes.
20 Q In the U.S. Navy Nuclear Power School which 21 you have indicated on this resume you attended, you 22 have also indicated you studied physics. Do you recall 23 .w hat textbooks you used?
24 ,
A No.
25 -Q Do you recall what areas of physics you were 1
1 Rose 6 taught?
2 ,
3 A Those areas that had to do with formation 4 of the atomic structure of atomic materials.
About what time were you at the U.S. Navy ll) 5 Q 6 Nuclear Power School generally?
7 A 1962.
8 Q Did you learn anything there about how 9 nuclear reactors work?
l 10 A Yes.
11 Q Can you remember what kinds of documents 12 were used, if any, in teaching you about how nuclear
, 13 reactors work?
- O 14 A No.
15 Q Do you recall if there were any textbooks i 16 used?
17 A There were textbooks.
I 18 Q Do you recall if they were published by the-19 Navy or by some outside group?
20 A I don't recall.
21 Q In the U.S. Navy Operating Nuclear Power 9 22 Plant Training, did you learn about how nuclear plants l operate?
23 i 24 l A Yes.
25 Q Do you recall for that training program I
n
'. )
l
. , . , , ., . . , . ~ -, - ,..
1 ROOD 7 2 what, if any, documents were used in your training?
3 A No, I do not.
4 Q Were you learning in the two courses we g 5 just discussed about all kinds of nuclear power plants 6 or any particular brand of nuclear power plant?
7 MR. MacDONALD: You are speaking of the 8 ' difference between PWR's and BWR's?
9 MS. WAGNER: -Yes.
10 A The teaching was aimed at PWP. operation.
11 Q Is that because PWR's are primarily used in 12 the Navy?
13 A I believe that to be correct.
14 Q What was the topic of. instruction in the l
15 International Correspondence School? What was your 16 training there, rather?
17 A I received courses in. electrical engineering.
18 Q Do you have a degree in electrical 10 engineering?
20 , A No, I do not.
21 Q Do you expect to obtain such a degree?
22 A Sometime.
~
23 Q Your resume indicates thatLyou spent over 24 six years while in the Navy operating and maintaining
.(_
O) 25 nuclear power plants. Can you give me some idea'what
1 Rooo 8 kinds of jobs you had with respect to those nuclear O 3 Power plants?
3 4 A Basically I was an operator of power plants 5 and I maintained them electroniewise.
ggg 6 Q What do you mean by that?
7 A I was an electronic technician and I 8 maintained some instrumentation systems.
9 Q You did obtain an operator's license?
10 A Are you referring to the Navy?
11 Q Yes.
12 A The Navy does not have operator's licenses.
13 Q Does it have any method by which people are O 14 j qualified to operate nuclear power plants?
15 A Yes. They have a qualification-type program.
16 Q Did you qualify to operate a nuclear 17 reactor?
18 A Yes.
19 Q What did you do when you were assigned to 20 the Atomic Energy Commission?
i 21 A I was a field representative and my job 8 22 basically was to make sure that the contractor who was 23 f running a training facility for the U.S. Navy - . to 24 fulfill the contractor's responsibilities.
25 Q which contractor was that?
1 Roos 9 2 A General Electric.
O 3 Q Was General Electric giving a whole spectrum 4 of training or was it training in just one area at this g 5 time?
6 A The majority of the training was practical i ,
on-hands training.
8 Q With the use of a power plant?
9 A With the use of several power plants.
10 Q Navy power plants?
11 A Yes.
12 Q on ships or on land?
13 A We were stationed on land and they were
' O 14 prototypes of shipboard power plants.
15 Q But they were actual plants, not simulators?
16 A That's correct.
17 Q Do you recall if you learned in the Navy 18 the basic principles of reactor operation? The basic 19 theory behind nuclear power plants, what they do and 20 how they do it?
l 21 A Yes.
O 33 Q Can you tell me now, can you describe for 23 me now your understanding of how nuclear power plants 34 , work, and I don't mean in extreme detail but generally. 1 25 MR. MacDONALD: As he sits here today or e% - +r - -- ,, - , - -, -
f
1 Roco 10 2 what he learned from the Navy?
3 MS. WAGNER: If he can recall what he 4 learned from the Navy.
ggg 5 A I wouldn't know how to field that question 6 in 50 words or less.
7 Q Maybe if I break it down a little bit.
8 Do you think you learned in the Navy what 9 the function of a nuclear reactor was? Why they are 10 built in the first place?
11 MR. MacDONALD: You are asking if he did 12 learn?
13 MS. WAGNER: Yes.
14 A Yes.
15 Q What is the purpose of having one? And all 16 of my questions are your recollection of what you 17 learned in the Navy right now.
18 A To provide a reliable source of power.
19 Q What did you learn about how a nuclear plant 20 produces power?
21 A I learned it used nuclear heat and 22 transported that heat into a secondary system producing 23 l steam and steam then drives equipment. That equipment i
24 l i
will vary with plant design.
I 4
_/- 25 Q Does the nuclear core produce heat?
j
1 RoDD 13 2 MR. MacDONALD: Again, does he recall 3
learning this?
4 Q All of my questions are based on your Navy 5 training. I am referring to your recollection of what 6 you learned in the Navy.
7 A Yes.
8 Q Does that heat become transmitted to the ,
9 primary system so the primary system is hot water?
A Ye8-10 l 11 Q Do you recall in the Navy whether the 12 primary system of most power plants that you saw was ,
3 13 at any particular range of temperatures or did they 14
?
vary completely?
15 A They varied.
16 Q Was the water in the primary system normally 17 boiling?'
18 A No.
19 Q Was it, to the best of your recollection, 20 normally at a temperature higher than 212 degrees 21 Fahrenheit?
22 A Yes.
23 l Q You recall knowing in the Navy or being 24 taught in the Navy why it was tlia t the water did not l-
- j. ((_ O). 25 ! boil if it was above the atmospheric-boiling' temperature?
l l
L 1 Ro0D 22 2 A Yes.
3 Q Why did the water not boil?
4 A Because of increased plant pressure.
5 Q How was pressure maintained in the reactors gg) 6 you learned about in the Navy?
7 A By the use of a pressurizing system and 8 pressurizer heaters.
9 Q Did a Navy reactor include reactor coolant 10 pumps?
11 A Yes. l 1
12 Q Did those pumps circulate water in the 13 primary system?
14 A Yes.
15 Q was it ever normal in a nuclear plant in 16 the Navy for the water in the primary system other than 17 the water at the top of the pressurizer to be boiling?
18 MR. MacDONALD: Normal operation, had he 19 ever seen that?
20 Q What was your understanding of the theory 21 of how it was supposed to operate normally at power?
9 22 A There was not supposed to be any boiling.
i 23 Q Did anyone ever tell you, to the best of l
l 24 your recollection, that boiling could happen in the i
Ds i primary system? That it was a conceivable physical
(_) 25 m ., y y w b - ' - - - - - - - - - - _ - _ _ - - - - w 7
1 rod 0 13 2 phenomenon?
3 A Not that I recall.
4 Q Did anyone tell you, to the best of your recollection, in the Navy what to do if the water did lll 5 G boil? j l
7 MR. MacDONALD: Are you speaking aside 1
8 from localized nuclear power? l 9 MS. WAGNER: I am talking of bulk boiling j 10 now. ;
1 11 ' A No. ;
)
i 12 Q What does it mean to be engineering officer
] of the watch? !
O 13 l +
l!
14 y A The senior person in charge of the plant. ;
15 g Does that mean in charge of the nuclear l
16 plant on the ship but not in charge of the whole ship 17 necessarily? !
18 1 A That's correct.
I 19 Q On board a ship in the Navy, how many people i
. 20 I, are the operators of a nuclear system? How many people i
21 normally staff it, just the nuclear plant?
9 22 MR. MacDONALD: You are talking about any i
23 l given ship?
t 2; MS. WAGNER: Yes.
O'
! 25 A It varies with design.
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I
_ , - . _ . -. , .- ._, , , _ . _ _ _ , ~
't' i 1 Ross 14 i
i N . 2 Q Is it at ; east one person at all times? ,
3 A Y***
. 4 Q Does the engineering officer df the yatch i
g 5 have the responsibility for those. people?
s ,
6 A Yes.
4 . .g 7 Q. What. rank did you obtain in the Navy? _
g A E6.
l L 9 Q What is E67 T A , g
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10 A It means first class,hlectronic technician. '(
When did you leave N
.the.Navgry i
11 Q ,
t
' T I' 12 A -1968. ,t .
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- 13 , Q What did you do in 1968 after leaving the l
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Navy?
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15 A .0ame to work for Metropolitan Edison.
_. i l
Ig Q Was that at the Saxton Nuclear Experimental i
'4 17 Corporation? -
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- +
18 A It was.
i i 19 Q Was the Saxton plant a commercial plant?
20 .
Was it intended to provide electricity for commercial 1
21 Purposes? :
9 22 MR. MacDONALD: You are asking whether it 23 did?
. t i 24 MS. WAGNER: Whether it did when he
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understood that to be his function when he was f
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i s 3 l' Ross 15 4
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2 employed there.t t
3 A It was a combination plant. It p,rovided
. s 4 power at occasions .
-s. s 5 Q Which was sold?
It was sold to people,
- 6 this power? s 7 A 4t mayJhave been.
8 Q What was your first job at Saxton?
\
.g _g A Reactor plant technician.
5
\ ,
10 l Q That is not the s a:ne thing as an operator, ,
- 3 l . - - '~, l g 11 i is it?
12 A It is.
i .
p 13 Q Was P.etropolitan Edicon the owner of the 14 Saxton plant? ,
43
^
15 A I am not sure of the, ownership arrangement. I
,s l' '
4
,- s 16 They were partial owners.
i g 17 Q who else was an owner? j i
s 18 A Westingnouse was involved. I am noc sure 19 of the arrangement. '
j 20 ,
Q Was part of the purpos of Saxton, as its
-c ,
i name suggests, an experimental purpose? '
21 1
3 22 A Yes.
l' !
23 : Q What type of experimentation occurred there s i G ,,: - i !
while you-were there? ,s iV'
. 24 ;
s ;
23 A Tried different fu loadings within the I
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i
,- 2 core itself. j
(~.s ) i 3 Q Does that mean different types of fuel or l
4 different combinations of fuel?
A Both. Different types, different lll 5 6 combinations. f i
8 7 Q How was the experiment performed? What !
l 8 . were you testing,to see how much energy was reJeased , j g or -~
i .
10 MR. MacDONALD: You are talking about a ;
11 ,
Particular experiment?
f
- 12 l MS. WAGNER: In general, what was the i,
13 Purpose of any of the experiments.
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l 14 ,; A To test the performance of fuel.
33 Q How do you test the performance of fuel, i
l 16 l by seeing how much energy it emits?
l l A You run it and see how long it w i ).1 run for 17 l '
1 and remcVe it and see what is left.
18 i
19 Q What kinds of fuel were you using there?
(! ,
I 20 ; What kind of fuel w'ere you testing?
21 A We tested various types and various loads.
33 Q Can you name a couple?
l 23 A We did run on plutonium at times down there.
34 ,
Q What did you do as an operator there when fs
) 25 l you first arrived?
I I
1 Ross 17 2 A I operated the plant. I helped change the 3 fuel.
4 Q What kind of a plant was it? A pressurized g 5 water reactor plant?
6 A Yes. !
7 Q Do you know who built the nuclear steam 8 system? l 9 A Westinghouse. l l
l . I 10 ! Q Is that plant still running? I
[ l l , .
' A 11 No. 1 l
, 12 ! Q Was it decommissioned? !
l ll i
13 !!
l A Yes.
O 14 p!l Q Do you know when it was decommissioned?
i ,
15 I A No. I 16 Q Do you know why? ',
i 17 { A No.
18 !! Q How long were you there at Saxton?
19 A Approximately two years. I 20 !. Q Did your job change at all while you'were i i 21 there? !
22 h't A No.
23 f Q You basically just operated the plant?
24 A Yes.
25 Q on' a shift basis?
i I
i e t
1 RoDD 18 o A Yes.
3 Q Did you receive any training while you were l
4 at Saxten?
g 5 A Yes.
6 Q Who administered the training?
7 A saxton. .
8 Q The corporation itself? l s
9 A Yes. l 10 ; Q It had a Training Department? l I
11 A We were very small. We only had one person .
i 1
12 in the Training Department at that time. .
13 ll Q How many operators were there? I O [4 i A I don't recall the exact number.
1 l ,
15 i Q Greater than ten? i i i 16 A Less than ten.
i l
17 ; Q Did you hold a reactor operator's license I !
18 issued by the Atomic Energy Commission on.that plant? ;
4 19 A Yes. ,
1 20 Q Did you obtain that while you were in the 21 Navy or did you obtain it after you began working at g- Saxton?
3 22 23 - A I obtained it at saxton.
?
34 .Q Can you describe briefly the training
() 25 Program you went-through in order to obtain the license?
I 1
1 Roso 19 l
t I
2l A Not in an,y detail. It has been a long time, i
(~}
(_/ i 3 Q can you tell me generally how long it was?
4 l
- I 4 Did it take a year or a week?
5 MR, MacDONALD: You are asking whether it g was a continuous program? Since you are asking 7 a time period. Did he attend a class every day 8 for a week or a year?
l 9 MS. WAGNER: Yes, until he got his license.
10 Q I am not talking of training after you i
11 received your license but before you received your 12 license.
A I don't recall.
13 .
\m I, 14 h Q Do you have any idea what topics were the I
15 subject of training?
I i 16 A Not specifically.
17 Q Generally?
!l 18 A Generally, nuclear power subjects, plant 19 systems. .
l l
20 Q Do you believe you. learned during that i
21 training course the theory of bew nuclear reactors work?
ID 22 f MR. MacDONALD: What you recall'.
}
23 A I believe I did.
33 Q Do you recall whether you had any physics
-25 training-in that training program?
s ,
i l- i l :
) Ro00 20 t
2 A I don't recall.
3
, Q D y u recall whether you used any l
4 documents in that training program, bcoks or manuals jf 5 or handouts or anything of that sort?
i 6 A I don't recall.
l
- 7 Q Did you maintain any such documents? Do ,I i
g you have them today? ,
9 A From Saxton?
t 10 Q Yes.
11 A Yes, I think I do.
12 Q Do you recall if you retained any notes ;
13 that you personally might have taken on the training !
14 you received at Saxton?
15 A All my personal notes I believe were !
. 16 destroyud lon.y ago.
I i 17 Q Did you maintain any books or handouts or ,
l i
18 anything of the sort from your Navy training programs?
]9 A Yes.
20 Q Did you ever have occasion to use your Navy.
, l 21 books after.you left the Navy? i 23 A Yes.
23 i Q For what purpose?
l 3 ,
A Mainly electronics, background electronics 1
23 in the Courses I was pursuing.
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1 Room- 21 2 Q You used them as reference documents?
3 A .xes.
4 Q Did you ever have reason to.use whatever books or documents you retained from the Saxton training gg 5 6
Program since you left Saxton?. ; i 7 A No.
I 8 Q Did you do any training at Saxton?
l',
9 A Yes.
10 g what type of training did you administer? ;
I i 11 l A On-plant, on-hands type training. i i
12 ,
Q Were you training other potential reactor 4 I
13 I Perators?
i 14 j- A.; Yes.
t
! Had you had any training yourself at that '
15 Q
. I 16 Point in training as opposed to in physics or nuclear .
17 P l ant cperation? Had anyone taught you how to train
+
t 18 somebody? ;
19- MR. MacDONALD: You are asking whether he
~
20 had ever done any training before? ,
'l 21 MS. WAGNER: Whether he had.ever been taught 33 to train anybody.
23 A Yes, I had.
i 34 Q. Where did you receive such training?
(~ 25 l
I A U.S.. Navy. .
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1 Roon 22 Q What program?
O 2 3
A Instructor / operator program at West Milton, 4 New York.
5 Q That was in 1967 and 1968, according to ggg I your resume here? I 6
i 7 A 1966 sometime. l I
g Q What did you do after you left Saxton? ;
I A I came to Three Mile Island. I g l 10 il Q Was the Saxton plant still operational at ,
I-I 11 the time you left?
l l 9
12 II' A Yes. ;
1 13 Q That was apprcximately 1970?
14 A Yes.
15 Q What was your first job at Three Mile ,
l I
16 Island?
l 17 A I was assigned duties as a shift foreman.
I i
18 ! Q Were you still working then for Metropolitan, I
I 19 Edison? {
i 20 A Yes. l t :
21 Q What were the duties at that time of a O g3 shift foreman?
i 23 A Prestartup duties.
34 ,
Q Would you define that a little more fully ,
i 1([) 23 I for me? I l .
f
1 Roos 23 2 A Assisting in writing operating procedures, 3
walking down systems, that type.
4 Q Were you assigned at that time to any 1
5 particular unit at Three Mile Island?
6 A Yes, initially I was slated to go to Unit 2.
7 Q So when you were first'a shift foreman, you g were a Unit 2 shift foreman?
9 A Yes.
10 Q At what stage in this development was Unit 2 11 at that time? -
i
- .12 A Just a hole in the ground. 2 i
13 Q But you had already begun writing procedures 34 for it even though it was just a hole in the ground?
15 MR. MacDONALD: Himself writing? '
i 16 MS. WAGNER: He indicated he was involved. .
i 17 MR. MacDONALD: He said he was assisting'in 18 some things.
i I
19 (Continued on the following page.) !
- 20 I
21 i h 22 23 ;
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. ._. . , . . _- - . - _._ . . . , ~ _ . , . -. . _ . _
bt 1 Ross 24 1
2 Q Were you involved in writing procedures -
3 or assisting in the writing of procedures for TMI-2? i 4 A No. 'At that time we were doing very g 5 little work for Unit 2. I was involved in some work G for Unit 1.
7 Q Can you give me a description, because 1
8 I am having a hard time understanding what you were '
i l 9 doing for Unit 2 for the hole in the ground. l t
10 A Review of documents or any procedure 11 writing that had to be done at that time for Unit 2. ,
12 ! Q What kind of procedures had to be done 13 at that time for Unit 2? '
14 tj A Mostly specifications at that time being ll .
15 ! reviewed.
l .
16 l Specifications of how the plant was Q
17 going to be built?
l!
I 18 A some specifications on how the plant 19 was to be built. l t$
20 l Q What kind o f specifications ?
l 21 A Like you arc looking at a specification S 22 for a feed pump, for a turbine, something.
23 When you reviewed these specifications, Q '
I What were you 1ook'ing for?
~
_24 what was your review for?
^ '
25 A Looking for incompatibilities ;
i I i
2 i Roos 25 2 Q At that point was Metropolitan Edison 3j basically putting together a system, one system with 4 another system and building up a plant, and you were g 5 supposed to be making sure that everything was going 6 to be working right? Was that basically what you 7 were doing?
8 A No, Metropolitan Edison had an architect /
9 engineer who was doing that work, and we were 10 reviewing their work.
l 11 Q Who was that at the time, the architect /
12 e n gin.ee r ?
i 13 A For Unit 2 it was Burns & Roe. ,
O 14 Q In the period of 1970 to 1972, were any l 15 operating procedures drafted for TMI-27 16 A I don't recall.
I 17 Q Do you recall if any amergency procedures '
N 18 were drafted? i l
19 A No, I do not.
f l
Would it have been, to the best of your Q '.
20 :.
21 recollection, the appropriate time for such procedures D 22 to have been drafted while TMI-2.was still a hole in 23 the ground?
MR. MacDONALD: Drafted by whom? ! l 24 i 1
25 MS. WAGNER: Anybody. ',
I
3 1 Roso 26 MR. MacDONALD: That assumes he had o
2
' knowledge, if 't was somebody else, it would 3
4 have been the appropriate time to be drafted 5 by a third party.
gg 6 MS. WAGNER: I am asking generally what j l
7 his understanding is of the progression of i 8 building a nuclear power plant.
9 A I don't know what the question is.
10 -
Q Do you believe that it would have
, i 11 l been normal, a normal progression, while there i
i 12 was nothing there at Unit 2 to already be writing I
13 operating procedures for it?
O 14 j a
MR. MacDONALD: I object. There is il 15 !I no background for instruction. I don't i I
16 think there is any foundation for his knowledge.
i 17 He may answer.
18 f A I don't think it would be unusual I ,
i 19 ! to have some operating procedures. You have to be 20 selective.
i !
I' i 21 Q Do you have any recollection at this :
22 point of any particular ones that'were being drafted?
i 23 : A I do not. I 21 si '
Q Were there any operators at that point, control room operators, assigned to TMI-27
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l 2 A No.
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+
3 Q Did you hold an operating license at this l l
. time?
4
- I 5 A In 1970, my license was still good at I
6 Saxton. j 7 Q Did you hold any license at Three Mile 6
8 Island? -
9 A No. i 10 .
Q Were you in training to obtain such a .
11 l' license? I I
~i
!' 12 A It depends upon the time period. Some ,
\
l ,
1 . 13 .I time period I was.
14 ji Q At any time pe riod be tween 1970 and 1972?
15 A I am not sure.
- ?
16 Q During that period when you were shift 17 foreman, did you have responsibility for any control 4
1 18 room operators, any licensed operators, I should say?
i 19 A No. i f
f' 20 Q Were there licensed operators at TMI-1 1
21 at that time? !
22 A No, i
I 23 Q I believe you indicated previously you 24 were also.doing some work for TMI-1, is that correct?
25 A Yes.
l' .
l , n i
e
<e.. - e -w w,.-, , ~w -- --.n - - . . - . - . . ,
w w ---.v- _n.- -r,--e-- w ,,n/-
1 .
I S 'Ross 28 2 Q What work were you doing for TMI-1 at 3 that time?
! l 4 A Some procedure review, some procedure 5 writing.
)
6 Q What kind of procedures were you reviewing I and writing? >
8 A It varied. System operating procedures.
l 9 Do you recall if any emergency procedures Q f IO j were being written or reviewed at that time?
I ;
11 l A I don't recall. i l 1 12 I Q Do you recall any of the procedures on f
, 13 which you worked pe rsonally?
14 A No, I do not.
i 15 Did you ever obtain a license on i Q
16 any plant at Three Mile Island? [
l 17 A Yes, I did. ,
18 Which one, or both?
Q +
19 .A The answer is both.
l 20 j. Q Was your first license a dual license, .
I !
21 your first license at Three Mile Island? I l >
lI> i 22 A No.
! f l
23 '
Which was the first one you obtained?
- 4 Q
24 i A TMI- 1. !
I~
I s/
,h 25 Q When did- you obtain that license?
l
, 6 i
O
6 I Ross 29 2 A Early 1974. g 3 Q Were you involved prior to 1974 in 4 any training program aimed at getting such a license?
g 5 A Yes.
6 Do you remember who administered the Q i I training program?
8 A Babcock & Wilcox administered the i !
9 training program in nuclear physics.
10 And the only people who trained you to Q
11 get your license were Babcock & Wilcox?
I 12 A I didn't say that. .l.
13 Who else gave you training?
Q 14 i A We had an ongoing training program i
15 conducted at our plants by our own people. I 16 How long was that program?-
Q ;
17 i A It varied with the classification. l 18 l It could be as long as a year.
I 19 j Q How long was your training program? t I,,
20 A I don't recall the exact time period.
l 21 Q It was less than a year? -
9 22 ' A The time period was longer than a year.
I 23 The program could have been less than a year.
24 Which time period was. longer than a year?
Q. ,
fV) o-0
-l A The time period to get my. license. ,
7 1 Roos 30 l l
i i
f~ 2 Q But during that time you were not in a N-)) l 3 training program the whole time? i I
4 A That's correct.
ggg 5 Q What kind of training was administered 6 at Three Mile Island by Metropolitan Edison? What 7 topics were covered? i i
8 A Virtually the subjects you cover f 9 in any power plant, _ system training, theory training, .
10 radiation protection training.
11 g Q What training was administered to you in 12 th a t training program by Babcock & Wilco 2?
( I l
13 A Babcock & Wilcox taught nuclear supply .
14 sys te ms , the reactor core components, reactor theory, i
15 heat transfer, even some radiation protection. I f
I i
16 Q Whe re was this training administered ,
17 by Babcock & Wilcox? ,
I8 A Some was administered at Crawford Station.
l 19 Some was administered on site. Other times we went ,
20 to B&W to have on-line simulator training.
21 Q That was at Lynchburg? ,
9 22 l
A Yes. i 23 Q Do you recall how long the Babcock &
24 Wilcox training program ' was?
l 25 .
MR. MacDONALD: Each.one of these?
l i
1 Ross 31 l
2 MS. WAGNER: Whatever was involved in that j 3 training program that he participated in in 1
4 1973, I guess it was, ggg 5 A Again, it varied. Eight weeks at 6 Crawford taught by B&W. I am not sure of the simulator 7 time. We were there various times for various lengths.
8 Q You~ indicated that you learned something ;
9 from B&W about heat transfer.
10 What is heat transfer?
11 A Metnods of trans ferring heat from one 12 component to another.
13 Do you remember what you learned about Q
\O.
14 heat transfer?
15 A Not from 1973 specifically.
16 Q Do you have any idea?
17 MR. MacDONALD: What, your recollection is.
18 Let's not get into speculating. You are asking 19 what he recalls learning from that program.
20 If you can separate that out from his 21 knowledge, then he can give an answer.
9 22 A I remember j ust the basic theory of-a 23 i reactor and heat transfer, i
24 Q Can.you possibly communicate that to me l ,
. j#') !
(_) 25 : in a few sentences, or is it too complicated? l i
1 Ross 32 2 A What I got out of that was the concept 3 of how heat was transferred.
4 Q What is the relevance or at that point ggg 5 what did you understand the relevance to be of heat 6 transfer to a nuclear power plant?
7 A You have to be able to move the heat 8 from it, you have to be able to transfer it to make i
9 steam.
10 Q How 1s heat transferred in a nuclear steam 11 system, and if you can give me your knowledge in 12 1974, fine. Otherwise, give me your knowledge now.
13 MR. MacDONALD: Let's break it down O 14 so if he gives it to you, we know which 15 knowledge it is.
16 Q what was your knowledge at the time?
17 A At the time of?
i 18 Q 1974, at the time you first obtained 19 an operator's license on TMI-1.
20 A Transfer by conduction or convection, two i
21 primary methods.
9 22 f Q Is the heat generated by the nuclear.
23 >
core, the heat that is supposed to be transferred?
24 Is that why you need heat transfer to get that heat I
~
J- 25 from the core some place else.to make steam?
i
1 Ross 33 9 A That is one of the reasons.
O
~
3 Q What are the other reasons?
4 A You have to transfer from there to the g 5 steam supply system.
6 Q In order to run the turbine?
7 A Yes.
g Q Do you recall during this training program r
9 if Metropolitan Edison Company used any kind of books 10 or manuals or other documentation in the training 11 program?
12 A In which training program?
13 Q The training program you received in 14 l 1973-1974 to obtain your operator's license.
15 A There were books and handouts used.
16 Q Do you remember any of them?
17 A Not specifically.
18 Q Did you retain any of them?
19 A Yes.
l 20 Q Did you take notes during that training 21 program?
9 22 A Yes.
23 Q Did you retain any of those notes?
I 1
(
l 24 A Yes. l t
p i
- (j 25 Q Are some of those notes by any chance '
l
t 1 Ross 34 2 what you produced to us today?
3 A No. This is recent training material.
4 Q Do you want to see anything else here?
5 A That would be fairly recent training ggg 6 material.
7 Q And the folder as well? It looks like it 8 is pretty recent.
9 A Yes, that would be recent; not necessarily 10 training material.
11 Q During this training program we have been 12 discussing, do you recall which personnel at 13 Metropolitan Edison were involved in the training?
14 A Not all of them. Some of them.
15 Q Can you give me some names?
16 A Richard Zeckman was one gentleman who 17 was involved.
18 Q Do you recall anyone else?
19 A No.
4 20 Q Was Richard Zeckman a member of a formal 21 training department at that time?
ID 22 A Yes.
23 Q Do you recall if there were any other i l
- 24. l people in that Training ^ Department?
I b
- \_/ ' 25 A I don't recall.
l
, , , . a --
l 1 Ross- 35 l l
2 Q Did you during that time, did Metropolitan 3 Edison have a building that was a school, or did it 4 have training in some separate facility.or --
lll 5 MR. MacDONALD: You are asking where they 6 had their trainin: in '73-747
, 7 MS. WAGNER: Yes.
8 MR. MacDONALD: Their on-site training?
9 MS. WAGNER: Yes.
10 A It varied. They had office space for 11 training at one point down some place on the 12 Island. Another point we built a building and 13 they had space in that building.
- O- .
4 14 Q This was in '73-747 t
15 A Yes.
16 Q Did Metropolitan Edison have a library 17 at any place which contained books on whatever subjects 18 you were trained in?
19 A I don't recall a library.
! 20 Q During this training period we have been 21 discussing, did you have any responsibilities other 9 22 than training?
23 [ A Yes, during some portions of it, there 4
i 24 l were systems taught by individuals like myself.
I N '
k- 25 Q Did you have any responsibilities outside l
.. ~ . - -
1 Rocs 36 2 of the whole training function or were you just 3 solely involved in training either giving it or 4 receiving it during that time?
ggg 5 A During which time?
i 6 Q '73-74, until you obtained your license.
7 A At that point I was a shift supervisor and 8 I had some responsibilities.
4 9 Q Are they the ones you described previously?
10 A They changed somewhat. It is a little 11 more of an ove rview , supervision of a unit and a crew.
12 Q By 1974, by the time you received your 13 license, was TMI-1 operating?
11 MR. MacDONALD: Commercial operation?
I 15 MS. WAGNER: Any kind of operati'on.
16 Q It was more than a hole in the ground 17 at that point, TMI-1, I take it?
18 MR. MacDONALD: You are asking him in '74 19 what was the status of TMI-1?
I 20 MS. WAGNER: Yes.
l 21 A It was a functional plant in 1974.
j 22 Q What was the status'of TMI-2 at that time?
l l 23 . A Still in the early stages.
L 24 j Q 'Were you still assigned to TMI-2.even b
k-25 though you were holding a TMI-1 operator's license?
1 Ross 37 o A No. .
3 Q When were you assigned from TMI-2 to TMI-17 4 A When I became a Station Shift Supervisor, g- 5 Q In July 1972?
6 A Yes.
7 Q Your resume indicates that at this time 8 among your responsibilities were " Coordinate and 9 supervise the operation of two 900 megawatt nuclear 10 power plants."
11 What were the two 900 megawatt nuclear 12 power plants?
13 A That time period goes through '78 and it O 14 is inclusive.
15 Q It includes TMI-1 and TMI-27 16 A Right.
17 Q After you received your operator's i
18 license, did you receive an SRO license immediately 19 or did you receive an RO and then an SRO? ,
20 A You take both exams and I got an SRO.
91 Q After you received that license, were 22 you involved in any further training for any purpose 23 at all?
3; MR. MacDONALD: You are speaking of after I
l
-p)
( 25 i
he received the license in '74?
1 Roco 38 2 MS. WAGNER: Yes.
3 A Yes, training was ongoing at all times.
4 Q Why was that?
ll)' 5 A It is for us to ensure we were well 6 qualified to run the. unit.
7 Q To the best of your recollection, was 8 there any requirement of the Atomic Energy Commission 9 or the Nuclear Regulatory Commission, whichever one 10 was there at the time, that training be ongoing 11 even after you obtained your license?
12 A I am not sure.
13 Q Have you ever heard of a document called 14 "The Final Safety Analysis Report" for TMI-1?
15 A Yes.
16 Q What is "The Final Safety Analysis Report" 17 which I will refer to as the F SAR f rom now on?
18 A It is basically a series of books to 19 describe our plant and its design.
20 Q Did you ever read it, the whole thing?-
21 MR. MacDONALD: Cover to cover?
22 MS. WAGNER: Cover to cover.
23 MR. MacDONALD: For Unit 17 24 l MS. WAGNER: For both units.
25- Q Did you ever read TMI-2's?
I
,1
1 Roco 39 2 MR. MacDONALD: At one time or does he
.%s 3 understand that he has read every section of 4 it at some point in-time?
g 5 MS. WAGNER: The latter.
6 A I don't think I can say I read every page.
7 Q I take it you have read some pages , though?
8 A Yes.
9 Q Why did you read any of it? Because you 10 were curious or because somebody said you had to?
11 A Just part of a training. We wanted to be 12 sure we were up to date on our units, g 13 Q Are you aware that there is a section of
%) .
14 the FSARlforbothplants which deals with the training 15 program?
16 A Yes.
17 Q Have you ever read that section of the FSAR7 18 A I have read it.
19 .Q Was it your understanding'at any time 20 before 1979 that whatever training program was l
I 21 described in the FSAR for whichever unit Metropolitan h .22 Edison was cbliged to carry out whatever training l
l l~ 23 l program was described?
I 24 f A No.
O() 25 I Q That was 'not your understanding?
i
1 Ross 40 l A 2 I didn't have an understanding.
Q Was the FSAR to the best of your knowledge 4 at that times or any time before 1379, did it have any function other than a training function?
lg) 5 6 MR. MacDONALD: You mean any function to 7 Mr. Ross?
9 g MS. WAGNER: As far as he knows, did it g ; have any fuention at all for any purpose?
10 MR. MacDONALD: For anybody else in the 11 company?
12 MS. WAGNEE: Yes.
13 A I am not sure what its function was.
34 Q Does TMI-1 presently have an FSAR?
15 A Yes.
16 Q Do you have any idea today what the 17 function of the FSAR is for Unit 1 today, if any?
18 A It is a public record that depicts what 19 our plant is designed to.do.
20 Q To the best of your knowledge, today, 21 is there any obligation imposed upon Metropolitan D 22 Edison as the operator of Unit 1 to operate according 33 to whatever the FSAR describes?
34 ; A Yes.
s./ !
25 ;
Q When did you first obtain that understanding?
u l
1
-. _ ~ -_.
I 1 Ross 41 2 A I can't put a quantitative time on it.
3 Q Do you recall if it was before or after 4 March 19797 lll 5 A I don't recall.
6 Q It could have been after?
7 MR. MacDONALD: Anything is possible.
8 He told you he doesn't recall.
9 Q You have no idea when you first learned 10 that?
11 A No.
12 Q Do you know who writes the FSAR?
1 13 MR. MacDONALD: What person?
14 MS. WAGNER: Person, company, anything. ,
15 A No.
16 Q You have no idea how it came into.being, 17 the TMI-1 FSAR?
18 A No idea is a big word.
19 Q Give me whatever ideas you have..
i 20 A I don't know the exact method it was 21 derived.
22 Q Do you know if Metropolitan Edison writes 23 ! it?
~ 24 ' MR. MacDONALD: In its entirety?
25 MS. WAGNER: Yes.
1
1 1 Ross 42 L
- '\,
2 A I know Metropolitan Edison'doesn't write y ~i 3 it in its entirety.
- c 4 Q Does it write any part of it?
)-
lll 5 A I am not sure.
f 6 Q You indicated it was a public d7cument.
7 What makes it a public document? Does it 8 get filed some place, published in the newspapers?
9 A It gets filed as part of your station 10 license.
11 Q What is a station lice n s e ?-
12 A It is a legal document for which we are 13 bound to operate by.
14 Q Did your duties change at all between 1972 15 and 1978? Your resume indicates during that whole time 16 you were a Station Supervisor.
17 I am wondering if at r,ny. time your duties 4
18 changed even though your title didn't.
19 A My duties stayed pretty much the same 20 throughout that time period.
4 21 Q At that time period, were you assigned 22 to TMI-1 for the whole time period?
23 , A No.
24 i Q At some point did you become assigned to (s- - 25 i TMI-27 i
I
.-,--r-~ , , ,_ , , ,# -,--,-e- , . ,.,1. , - ,,-y -..w-
l' Roan 43 2 A At some point I became usable in both O 3 units.-
4 Q Cross-licensed?
g 5 A Yes.
6 Q was that in 19777 7 A I think my license date was 1977.
8 Q After that time did you spend most of 9 your time in Unit 1 or Unit 2, or did you divide it 10 equally?
11 A After that time I spent virtually all of 12 my time in Unit 1.
13 Q Prior to obtaining a cross-license, did O 14 you engage in any special training program for 15 that cross-license, or were you engaged simply in 16 the ongoing training you previously mentioned?
17 A I think the answer is both. There was a 18 specific program and there'was an ongoing program.
19 . Q who administers the ongoing program?
20 A It varies. It can be contractors we have 21 brought in or it can be Metropolitan-Edison, Babcock 22 & Wilcox. It can be a number of people.
23 Q Who administered the cross-license program?
24 A My recollection is B&W had some involvement.
'( 25 in lectures on that.
_ , ____,__,_______________._-__-A. - -
1 ' Roco 44
~
- N (d 2 Q Did anybody else-have any involvement?
3 A Some1 lectures from Metropolitan Edison.
4 Q Were any books used or manuals or handouts of any kind?
lf 5 6 A I don't recall.
7 Q Do you recall whether you retained any?
8 A I did not retain any material virtually D from Unit 2.
10 Q If I recall your testimony correctly.
- 11 it sounds like pretty much your whole time at I
12 Three Mile Island you spent primarily on Unit 1, is
. 13 that correct?
14 A I think that is correct.
l$ (Recess taken.)
1t1 BY MS. WAGNER:
, 17 Q Just before we broke I was going to ask 18 you, since we.already established that much of your.
~
- 10 time was spent at Unit 1, why you obtained a
. 20 cross-license, i 21 A I obtained a cross-license in the' normal
- 22. function of my job as a Shift Supervisor. I received 23 . a promotion shortly thereafter which required my 21 i -trans fer and . involvemen t full time in.1978..
I
' 1 1 '
=
/c 25 Q That was in January 1978 when you became
-m __.m.m___.____..______...m5_ _--___.__m__m..m_.____.____m._-_______m--__m_______.--ma----'& -
1 Ross 45 1.
j 2 Supervisor of Station Operations?
1 3 A Yes.
4 Q You went and got your cross-license lh 5 and that was just sort of in the normal course of 6 having been an operator for a while? That is what 7 you did at Metropolitan Edison?
8 MR. MacDONALD: Are you asking.is it normal 9 for operators to receive the cross-license, or 10 was it during that time, or did it relate to 4
i 11 the job as Shift Supervisor?
I I 12 Q I am asking if that was the normal i
1 l
13 progression after you had been an operator for a '
14 while where you tried to get a. cross-license.
i 15 MR. Mac DONALD: He tras a Shift Supervisor 16 at the time he got his cross-license. There 17 may be some different procedure for a Shift 18 Supervisor than for a Control Room Operator.
19 A Control Room Operators were not
- 20 cross-licensed. They were specific to a unit. shift 21 Foremen'normally weren't cross-licensed. Shift 22 Supervisors were cross-licensed as a matter of job 23 function.
, 24 l Q Did most Shift Supervisors work at both i
- 25 plants?
, , , , , , . , > .- ,, ,.,,n. -
.,-e, , , . ,v w ,n+-. , ,, , ,--,-,,.,,e,,,.es,,, .ma y-, :-,g,,>m mp---
1 Ross 46 2 A Yes.
3 Q W uld they do that, did they change
, 4, every day or change every few weeks? What would be h 5 the rotation between the two units, if any?
6 A The Shift Supervisor had a licensed 7 individual charged with the operation of each unit g reporting to him. He wrote both units in an 9 overview-type fashion.
10 Q Where would the Shift Supervisor spend 11 his time physically? In one of the control rooms, or 12 did he have an office some place else?
() 13 A He had an office in each unit. He spent 14 his time where he was needed.
15 Q How did your duties change when you became 16 Supervisor of Station Operations?
17 A My total scope then became Unit 1.
18 Q Did your responsibilities remain the same 19 except that now they were just focused on Unit 1?
20 ,
A Instead of having responsibilities for an 21 operating shift, I took responsibility for all shifts 22 and their operation of my unit.
23 Q During that time did you work on a' shift 24 ! basis or were you there from 9:00 to 5:00 every day?
(~) 25 I
MR. MacDONALD: You are talking about the
1 Roso 47 f) 2 time he was Supervisor of Station Operations?
MS. WAGNER:
3 Yes, from the time he became
'4 Supervisor of Station Operations until March k 5 1979. That is the time period I will be talking 6 about for the next few questions.
7 A I was a daylight-type worker.
- 8 Q Your resume' indicates that you were 9 " Responsible for department scheduling, planning and 10 discipline."
l 11 What kind of planning does that refer to?
12 A Power reductions, re fueling outages ,
1 13 maintenance planning.
I 14 l Q And discipline, what does that refer to?
I 15 A In every department, any discpline has 16 to be done at some source, and I was that source.
17 Q Do you recall in the time period January 18 1978 to March 1979 any particular instances in which 19 you'were required to impose some kind of discipline?
20 A No.
gg 21 Q Do you believe during that-time period 22 you did have to at some point do something disciplinary?
! 23 A It is possible.
24 i Q You don't recall it now?
/
2a. A No.
l i
i i
l l
l' Ross 48 I
f'.-
2 -Q When you were the Supervisor of Station 3 operations, did you maintain any files?
4 A Yes.
5 Q Where were they maintained?
6 A Either in the control room or in my offices.
7 Q What kind of files did you maintain?
8 A Files that had to do with technical 9 specifications performance, surveillance performance, 10 operation surveillance where we looked at particular 11 pieces of equipment; basically system files.
. 12 Q What do you mean by " system files"?
( 13 A System files is where you keep a file 14 ; on a particular system, what we have done with it 15 'or what we are going to do with it.
16 g Did you write memoranda while you were-17 in that position?
18 A Yes.
4 19 Q Did you receive memoranda?
Il 20 1 A Yes.
ggg 21 Q Did you maintain files containing memoranda 22 you wrote or received?
I l
23 A Yes.
l 24 Q Did you have a secretary during this time?
25 A Yes.
l l
- 1 Ross 49 2 Q What was his or her name?
3 A Her name was Linda Ritter.
4 Q When you were Supervisor of Station 5 Operations prior to March of 1979, to whom did you i
6 report?
7 MR. MacDONALD: The person or the job 8 description?
f j 9 MS. WAGNER: Either one.
10 A I reported to the Station Superintendent.
11 Q Was that Gary Miller at that time?
12 MR. MacDONALD: For the entire time or
() 13 was he one of the persons?
f 14 MS. WAGNER: I thought it was Gary I
j 15 Miller for the entire period.
l 16
~
Q Was it he for any part of that period?
17 A Gary Miller was Station Manager. I 18 reported to the Station Superintendent.
19 Q Who was the Station Superintendent?
20 A Jim Seelinger.
4 i
g 21 Q For that entire time period?
22 A No.
! 23 Q .For which part of the time period?
f 24 A I am not sure of the time period.
Ci i
25 Who else.would have been in that position l Q
.- . . . . , . , _ , - . . . . , _ , . - - . , _ _ . - , ._..~,_...,_..._..--.m.._ -., . . . _ - .
c 1
Ross 50 2 for any part of that time period?
i 1
3 MR. MacDONALD: You are asking who else 4 was?
5 MS. WAGNER: Yes.
6 A James O'Hanlon. {
l 7 Q While you were the Station Shift 8 Supervisor from 1972 to 1978, to whom did you report?
9 A To the title of Supervisor of Operations.
10 Q Who preceded you in that position during 11 the time period you were reporting to that position?
12 A George Kunder.
f 13 Q Was he the only one?
14 A No.
15 Q Do you remember anyone else?
16 A James Floyd.
17 Anyone else?
Q 18 A No.
- 19 Q While you we re in the position of Shift' 20 Supe ~rvisor, did you maintain correspondence files lll 21 containing memoranda written or received by you?
22 A Yes.
23 Q
! After you changed jobs, did you keep those 21 files with you or did you leave ~them behind for whoever 25 took your position?
__ ___ ______.m.____m_. - . _ _ . _ _ _ _ . _ ___a-_._.-._._____
k1 1 Ross 51
) 2 A Basically, I incorporated them in my 3 pres'ent files.
4 Q Have you testified previously concerning 5 the accident at Three Mile Island or your 6 responsibilities at Three Mile Island in relation to 7 testimony concerning that accident?
8 A Yes.
9 Q Have you ever given a written interview to i
10 anybody, either Metropolitan Edison or an outside 11 group, concerning the accident at Three Mile Island?
I 12 A Written interview?
13 Q Yes, that is the word. Did you ever give 14 a document in writing concerning your recollection 15 about the day of the accident to somebody at
! 16 Metropolitan Edison?
17 A Not that I recall.
18 Q Do you recall ever giving any interviews 19 which were taped on a tape recorder to anybody after 20 the acciden't at Three Mile Island?
MR. MacDONALD: It this aside from prior lll 21 22 testimony or inclusive of prior testimony?
23 MS. WAGNER: Inclusive. Anything that was 24 tape recorded.
\O A Yes.
25 v - ., , . - , , - - e -w,- -- e , , m g m- y--
l' 1 Roos 52 What was tape recorded, if you can remember?
( 2 Q 3
Many, a few?
i 4 A Many.
1h 5 Q Did you retain the tapes of those interviews 6 whenever they were?
l
- A No.
i 8 Q Do you know if anybody has those tapes?.
g A No.
l 10 Q Did you retain the transcript of those 1 11 interviews?
I i
12 A some.
I would like to show you a transcript of 13 Q g4 an interview taken by the President's Commission on 1
15 May 10, 1979, which you are welcome to review, but I i,
i 16 refer you to page 16, which indicates that some written
) 17 statement was taken from you by Metropolitan Edison, 18 I believe. I am wondering if you can recall that.
19 MR. MacDONALD: You are asking if this 20 refreshes his recollection?
21 MS. WAGNER: Yes.
22 A It does not.
23 Q Do you recall that interview?
, 24 A No.
25 Q You don't recall having given any kind of l i
h I-t .- -
. . . . . = - - . .- - ..-. - .-. _- .. . . . - - - ..
.. . ._ .. . . . . . .~. . .=. . - - - . .. ..
4 I
1 RODO 53 2
i
) 2 interview around that time period to the President's 3
Commission.
4 A I have given interviews. I don't recall 5' that one.
6 Q You don't recall, then, whether or not this 1
7 interview was under oath?
i 8 A No.
4
- 9 Q And reviewing the transcript does not 10 refresh your recollection?
i 11 A No.
l 12 Q As you can see, there is a typewritten
() 13 transcript and on top of that there are some-14 handwritten words and things crossed out. Is any of 15 that in your handwriting? And now*I recognize'you are 1
16 not going to go through the whole thing, but sort of 17 generally looking at a couple of pages.
18 A No.
i
, 19 Q It is not your handwriting?
20 A No.
f 21 Q Do you recall if you gave any interviews 22 to the President's Commission which was not under oath?
i 23 ,
A I do not.
i !
t 94 Q Are you still Supervisor of Station 25 Operations for Unit 17 l
I l
l
f 1 Ross 54 2 A Y,e s . The title is different, but the job
] 3 is the same.
4 Q What is the title now?
i 5 A Manager of Plant Operations.
i-I '
6 Q Are you involved in the restart of TMI-17 1
7 A Yes.
I g Q Can you tell me generally what your duties 9 are with respect to the restart?
10 A Again, I function as a scheduling and 4
j
.11 execution type organization. As change modes are put in 12 the plant, we set up the plant conditions and set up the I work.
13 14 Q This is for all aspects of the plant or
! 15 just whatever the operators do or something else?
i 16 A Basically, for all aspects as far as the
- 17 actual plant system goes.
18 Q When is it going to full power?
i 19 A Soon. 4 I
j 20 Q Between January 1978 and March of 1979 when 1
21 you were supervisor of station operations, were you 4
22 involved at all in training at Three Mile Island, 23 training of operators?
i A Yes, I was.
24 25 Q. In what capacity?
- _ . . _ . _ . . . _ . _ _ . . . _ _ , _ , _ _ _ , . ~ . . . , _ , . _ _ _ . - _ _ . . . _ , . _ . _ . _ . , _ . _ , . _ _ _ _ , _ , _ .
1 Rose 55 A Basically a scheduling capacity. I
)
f~))-
\_
2 3
participated in training and at times I also gave some 4 material requests for training.
i llh 5 Q Do you remember what requests you made?
6 A No.
7 Q Were you involved at all during th at time 8 in suggesting or requesting that certain things be 9 shown on the Babcock & Wilcox simulator?
10 A Yea.
11 Q Do you remember with whom you communicated 12 about that?
() 13 A I don't know specifically, but the simulator people.
g4 15 Q When did you have communications with them?
16 A Prior to each simulator training session.
17 Q Would someone from B&W come onto the site 18 and talk to you or how would it work?
, 19 A Normally they would come to the site.
t 20 Q And I take it you would discuss what was 21 g ing to happen at the simulator with whoever was 22 g ing d wn the next time?
23 ,
A That's correct.
9';
~
Q Do you remember any specific suggestions I
25 that you ever made?
l l
1 Ross 56 I
A No.
) 2 Q Do you recall making suggestions of one L 3 4 sort or another?
e 3 A Yes.
6 Q Were you yourself being trained at that l-
< - time by anybody during this period?
1 8 A Yes, I rece 4ved the same training the i
9 operators received.
10 Q You were in the requalification program?
13 A Yes.
12 Q I would like to show you a document that 4 13 has been previously marked as B&W Exhibit 260 and ask y i you a couple of questions about that. If you will 15 turn to page 13.2-6.
16 MR. MacDONALD: Is this the Unit 2 --
4 1- MS. WAGNER: This is the Unit 2 FSAR.
18 Q Have you ever seen this document before?
j 19 A Yes.
20 Q Do you remember if you saw it priot' to i
21 March of 1979?
22 A No.
23 i Q Do you believe you did?
+
q
~
l MR. MacDONALD: You are asking for his i.
j 25 i
recollection?
l l ,
I I
- r. _ , .. - _ _ _ _ _ _ . ._ - , _ _ _ _ . . _ , _ _ _ ___ _ ..__. _ ,. ,
l
1 Ross 57
, 2 MS. WAGNER: He doesn't remember 3
Particularly seeing it.
4 Q But is it the kind of thing you think you h 5 have seen before?
6 MR. MacDONALD: His recollection.
7 If you have a recollection, testify to it.
l i
8 We are not here for speculation.
, 9 Q Do you have anything further to say?
10 You don't recall whether you might have seen it before?
11 A No.
12 Q If you turn to page 13.2-7, you will see a 13 description of lectures which would be part of the 14 requalification program for Unit 2. It continues for j
j 15 the next few pages. That page indicates that lectures 16 shall be held on a continuing basis and consist of a t
17 minimum of 60 scheduled hours per requalification J
18 Program cycle."
i l
19 Do you know what was the length of the 20 requalification program cycle?
i i
i 21 A No.
22 Q You were an operator on Unit 2, weren't you?
I 23 A Yes.
24 Q You don't have any recollection of what the 5
.25 , cycle was for the requalification program?
l i
, -.- ,-- , - - , . , -,. y , - - --, , g--.,,,e .q.g,, .,----,...,e,-r-n,--
f 1 Ross 58 MR. MacDONALD: I think he just told you
( 2 3 that.
4 Q Do you remember being involved in that
, 5 requalification program?
6 A I was involved in a requalification program.
7 Q For Unit 2?
8 A For both units.
9 Q Have you reviewed 13.2-7?
10 A I read it quickly.
11 Q To the best of your recollection, does it 12 describe a part of the requalification program that 13 you experienced as an operator on TMI-2?
14 A It was part of the requalification program 15 I took.
16 Q Do you remember going to lectures in the 17 requalification program?
18 A Yes.
l1 19 Q Do you believe you were supposed to i
j 20 1 attend 60 hours6.944444e-4 days <br />0.0167 hours <br />9.920635e-5 weeks <br />2.283e-5 months <br /> per year?
21 MR. MacDONALD: What your recollection is.
22 A My recollection is I had to attend a certain 23 ,
period a year.
I t
- 24 Q But you don't remember if it was that much I
25 or a week or two. hours or anything?
_gy_, p,. .- .. - e .:.,_..,.+--. -.gy- *m. . _ , - - , .,p.. g+ei,,,-q ,3r
..= . . . . _ . _ ... .
1 Ross 59 2 A No. ,
~
3 Q D you remember, now referring to page 4 13.2-8, any training in your requalification program
~
5 f r Unit 2 concerning the principles of operation of 6 TMI-2? This is now before March 1979.
, 7 MR. MacDONALD: Are you pointing to a 8 specific section?
9 MS. WAGNER: 13.2.2.2.2-8.
4 10 A Yes.
11 Q Do you remember what topics were covered 12 in this section of the requalification program? '
/~h- 13 MR. MacDONALD: You are asking whether he b
- 14 has an independent recollection?
i 15 MS. WAGNER: He indicated that he does 16 remember about these lectures, so I am asking i
a 17 about that recollection.
18 A Reactor theory.
. 19 Q Would that have included principles of 20 heat transfer and fluid flow?
J 21 MR. MacDONALD: You are asking him did it?
22 MS. WAGNER: Yes.
I 23 A- I-don't recall.
24 i Q Do you recall if'any.section in the i
O 95 i'
requalification program-covered heat transfer and fluid I
l-
t
'l Ross 60 l I
flow?
-a 2 ;
3 A I don't recall.
4 Q Did you consider that an important topic?
At the time he was taking 5 MR. MacDONALD:
6 it?
7 MS. WAGNER: At any time prior to March 1979.
t
, g A I don't think I ever gave'it much thought 9 because it wasn't a separate section of an exam or a 4
10 separate section of training given to us either by 11 B&W or Metropolitan Edison.
12 Q Did you believe it was important at any time
(). 13 prior to March 1979 that to understand the principle 14 of reactor operation, that you understand or that 15 others understand the principles of heat transfer and 16 fluid flow?
17 A I really hadn't given it much thought.
\
18 Q You indicated that you had learned or you
! 19 understood from your Navy training'that a pressurized 20 water reactor primary system is not supposed to be-21 operated in a bulk boiling mode, is that correct?
l
=
22 A Basic concept, that's correct.
23 Q Was that also true of your understanding i
I o4
! of the pressurized water reactor at TMI-1 or TMI-2?
[O
~
25 A Yes.
._ - , _ . , _ - _ . _ , , . . ~ _ . . , . ~ _ _ . _ , .- .
1 Ross 61
( 2 Q Did you receive any training at TMI prior 3
to March 1979 on what to do if the primary system in 4
fact did boil for some reason in any place other than k 5 the top of the pressurizer?
6 A No.
7 Q Is it correct that the water in the steam 8 generator in the secondary system is boiling at normal g power operations of a pressurized water reactor?
10 A Yes.
11 Q Is it correct that the steam generator 12 produces superheat?
[' A Yes.
V) 13 14 Q What is superheat?
15 MR. MacDONALD: As he understands it today?
16 Q Yes, as you understand it today for the 17- moment, so we can get a definition.
. 18 A Superheat is fluid that has a temperature 19 higher than a saturation temperature.
20 Q Do you know where you learned that or when l 21 yu learned it? l 22 A Not exactly.
i 23 - Q- Do you believe you knew it prior to March l 19797 24 l O 25 I A I think I knew the concept of superheat prior j i ,
i l
- - - - , , , _ ,- , - - - - -- - ,- y ,,c--, , - , ,---.-.-.--.m,r--.- ,----~,y__.,,y., -- - , . -
1 Ross 62 2 t March 1979, but I don't think I knew or reinforced it as much as we have lately.
3 4 Q Do you understand how superheat is created 5
in a steam generator?
6 A Yes.
- 7. Q How does th at happen?
g MR. MacDONALD: You are talking about the-j g state of his current knowledge?
10 MS. WAGNER: Yes.
4 11 A It happens by allowing steam to come in t
12 contact with tubing or piping which is at a higher 13 temperature to further heat the steam to a temperature 14 that is greater than its saturation temperature.
1 Do you recall when you first learned how 15 Q 16 a steam generator produces superheat?
17 A Not exactly.
18 Q Do you believe it was before March of 1979?
19 A Yes.
20 Q Had you ever, prior to March 1979, . heard of superheat being formed in the primary system of a 5 21 j 22 pressurized water reactor? And I don't mean e.
23 I necessarily that it had been formed someplace, but had a
24 that concept ever been introduced to you? :
ps Nj A No.
25 i
1 Ross 63
) 2 Q Had the concept ever been introduced to you 3
in any way pri r to March'of 1979 that the primary 4 system water could reach a saturation temperature in 5 any place ~ other than the pressurizer?
t i 6 MR. MacDONALD: _You are talking about
, 7- including localized boiling?
! 8 MS. WAGNER: I mean bulk boiling.
9 A No.
10 Q Prior to March of 1979, did you understand 11 that when a pressurized water reactor is operating i 12 at power, the pressurizer will be operating in a 13 saturated condition?
I 14 A Yes.
15 Q Why was it that the pressurizer operated in 16 a saturated condition?
l ;7 MR. MacDONALD: Now you are dealing with 1.
! 18 his understanding prior to the time?
19 MS. WAGNER: Yes.
f f- 20 A' To give some margin of pressure that would l
i 21 be higher than saturation for the system.
22 Q I don't quite understand. How does having 23 it operate at saturation allow you to.give a_ margin of i
24 Pressure?
s 25 A' In order to maintain the system pressure
- Ww -'
(h-'~gdN-V T "eq-*-"'w*~%w "'"# 9"l-w'" #H--@'Tt'-W* **
?
1 Ross 64 l I
l D) s_ -2 at whatever is normal operating pressure, the surge
, 3 volume it creates has to be at that saturation pressure 4 temperaturer therefore, the pressurizer must be at 5 saturation.
6 Q Can I try to rephrase it to see if I 7 understand it.
8 You mean that in order to have a surge 9 volume, you have to have a saturated pressuri.zer,oor did-10 I not get it?
11 A No, not to have a surge volume,-but to 12 have a volume that is designed to float your system at 4
) 13 a certain design pressure that is necessary.
(ns/ ,
l 14 Q Is that so that you have a steam bubble?
i i
15 You have a saturation because you want a steam bubble 16 because that will provide pressure?
17 A What you are trying to do is create a 18- volume indicator called the pressurizer for the RCS 19 system. To do that, that has te become your surge 20 volume, and its temperature must equal the saturation l
21 temperature of the system that you are working with.
22 Q You are saying that the pressurizer is a 23 volume indicator. That is what its design is?
fg 24 i A Yes.
i 25 Q Can you give me any further definition of 6
y
. , , ,, - ~ , - . . . . ~ , . - - - - . _ . . . .c e , . . - _ . . . . , g- r - - . c. - - -
9 1 Ross 65
(). 2 what you mean by a volume indicator?
3 A It will tell you whether or not the system 4 itself is increasing in volume, decreasing in volume.
5 It will also tell you whether or not the system itself 6 is at its prescribed level.
7 Q Is that, to the best of your understanding, 8 the function of a pressurizer?
g A Yes, it is a surge volume. One of its 10 functions.
2 11 Q Is that what the pressurizer at TMI-1 also 12 does? .
4 13 A Yes.
i g4 Q Does it have any.other function?
1 15 A It helps you maintain your pressure by i
16 having heaters and spray located within it.
I 17 Q Are both functions equally important?
18 A Yes.
19 Q Where did you learn all this about the l 20 pressurizer, if you can recall?
21 A In our training programs.
22 Q You believe you knew it prior to March of 23 19797 24 l A Yes.
O' 25 l
Q. Have you ever heard of a pilot-operated l
. -. - . n. . --.
1 Ross 66
() 2 relief valve at the top of the pressurizer?
l 3
A Yes.
4 Q Do TMI-1 and TMI-2 have pressurizers 5 which have PORV's at the top of the pressurizer?
6 A Yes.
7 Q What is the function of a PORV?
8 A To relieve pressure if its set point is 9 reached.
10 Q Prior to 1979, to March of 1979, was it 11 your understanding that the PORV opened prior to the i
12 high pressure trip point of the reactor at TMI-1 or 13 TMI-27 N. j 14 A Yes.
15 Q Were you aware that the PORV could be set 16 to open at a pressure higher than the high pressure 17 reactor trip set point?
18 A I don't recall.
19 Q Do you know that now?
20 A Yes.
I 21 Q Did you know prior to March of 1979 why the 22 set point of the PORV was lower than that of the 23 high pressure reactor trip : set point?
l l 24 ! A My understanding, it was part of the design i
' (:)- 25
! of the system to allow the system to ride out a turbine i
I
-1 Ross 67 s-
-l 2 trip. That system being the NSS supply system.
i' 3 Q When you say to ride out a turbine trip, 4 you mean to prevent a reactor trip if a turbine tripped?
5 A That's correct.
6 Q Was that something that was then-7 beneficial?
g MR. MacDONALD: You're asking if it was able 9 to do it?
10 MS. WAGNER: He testified it was able to do i 11 that.
12 MR. MacDONALD: He testified whae it was 13 designed for. ,
i 14 Q Was it something that was good ~or bad or 15 did you have any opinion about it at that time?
16 A I voiced no opinion. It is my 17 understanding it was part of the NSS design to be able 18 to do that.
19 Q You had no opinion, written, voiced, or I
20 1 thought, if that was a good or bad thing?
21 'A No.
22 Q Did you ever hear anybody else voice an i
23 opinion as to whether this was something good or bad 94 or useful or not useful?
25 A None I can recall.
,es. ., . , , , - , ~ . , -
..---.-y, _ , , , - y-7-- - , - - , , . , -w , , , , - , - . . , , - . - - , .
l 1 Rose 68
( 2 Q Prior'to Marsh 1979, were you aware-that a 3 nuclear core could reach a condition at which it would '
4 da' mage itself?
5 MR. MacDONALD: I don't quite-understand 6 what you mean by reach a condition that would 7 damage --
8 Q Were there any circumstances under which 9 a nuclear core would become damaged after it was put 10 into a plant? Had you ever heard of the concept of 11 core damage-prior to March 1979?
12 A Yes.
() 13 Q What was your understanding at that time 14 could cause core damage?
15 A Mainly overpower or lack of heat removal.
i 16 Q What could cause lack of heat removal?
17 A The inability to transfer heat out.
18 Q Could that be caused by a lack of water 19 in the primary system?
i I
20 MR. MacDONALD: You are asking him for.his 21 understanding prior to the accident?
22 MS. WAGNER: Yes. l 23 l A My understanding in trainin'g prior to the l
94 accident it never functioned at a water level at all, I i
('N y)- ' l
- 25 either at the B&W simulator.or at Met Ed.
i i
Ross 69 2 Q You never had any idea prior to the accident that if there was no water in the core, core 3
4 damage would be caused?
5 A When you say " idea," it is possible we had 6 an idea. It was never stressed or trained.
7 Q I am asking if you ever heard of it.
8 MR. MacDONALD: He-gave his answer.
j 9 Q Did you ever hear of the term prior to the 10 accident of loss of coolant accident?
11 A Yes.
12 Q What was your understanding prior to 13 March of 1979 of a loss of coolant accident?
14 A Basically, it was a leak in the reactor 15 coolant system.
16 Q Was that a good thing or bad. thing, a loss 17 of coolant accident?
18 A A bad thing.
19 Q Why? ,
I 20 ! A *Because it could lead to core trouble.
21 Q How could it lead to core trouble?
22 A Again, the concept was never stressed, how.
23; , Q You did not understand prior to the o4
~
- accident how a loss of coolant accident could cause 25 core trouble?- Is that what your testimony is?
1 Ross 70 O
,() 2 A My testimony is I didn't have it stressed, 3 how it was.
4 Q Whether it was stressed or not, did you 5 have an understanding prior to the accident?
6 A A detailed understanding?
7 l Q Any understanding.
8 A I have to classify it as a vague 9 understanding.
10 Q Can you describe to me your vague 11 ' understanding?
12 A No, it is that vague.
() 13 Q Prior to the accident, in March of 1979, 14 l did you understand that there was any relationship 15 between the temperature and the pressures in the steam 16 generators and the temperature and pressure of the 17 reactor coolant primary system?
18 A Yes.
i 19 Q What was that relationship, to the'best of 20 your recollection?
21 A The steam pressure on the-secondary side 1
22 of the plant was determined by the primary temperature.
! 23 Q If the primary temperature became lowered, 24 the steam temperature would become lower, is that how 25 'it worked or was it the opposite? What was the
1 Ro30 71 relationship?
r]O 2 3 A If the RCS temperature had become lowered, 4 the steam pressure would become lowered.
5 g Do you know why that was theoretically, 6 or I should say, did you know at that time?
7 A Basically, the temperature of the primary
~
8 fixes the steam pressure of the secondary, because it g forms the steam at that temperature. ~ There is a 10 temperature-pressure relation for that.
11 Q Prior to March of 1979, had'you ever heard '
12 of the phrase " transferring the bubble" as it relates
' ~
13 to a pressurized water reactor?
14 A No.
15 Q Prior to March of 1979, had you ever 4
16 encountered a situation in which, for whdtever reason, 17 the bubble in the pressurizer was lost in normal
.18 operations at power? e 19 A I have not. -
20 Q Had you ever, prior to March 1$79, been 21 trained that such'a situation'could occur for any 22 reason? , -
23 A No. , +
l ,
l Prior'to March 1979, was it your n .24 Q l
25 understanding that the pressurizer during normal -
s l
. . - - . . _ . . ._ ~ . . _ . _ _ , ,. _ . . , _ - .
1 Ross 72 2 operations was supposed to be the hottest point in the 3 system, in_the primary system?
4 A Yes.
5 Q Did you know why that was?
6 A The concept being the hottest point has a 7 bubble in it. Yes.
8 Q If it had not been the hottest point, did you 9
I have an understanding that the bubble would go 10 somewhere else or it would go away? Did you have l
.11 any understanding of what would happen if it was not i I
12 the hottest point in the system?
~N A There was a possibility.the bubble could (b 13 14 i form someplace else.
15 Q Did you have a concept where it would form 16 if the pressurizer were not the hottest point in the 17 system?
18 A Only that it would form at the hottest 19 point.
m 20 Q Was that something that you were trained 21 was good or bad in the normal operations of the 22 - pressurized water reactor, to have the bubble f o rm 23 !. somewhere other than at the top of the pressurizer?
s '
- i s3 34 i MR. MacDONALD: You are asking whether l
_ w 'N !ft 25 somebody taught.him it was either good or. bad?
- ' v JN s A w
.t.. , - - , , - . . , ~ .,, - - --, .- -
1 Ross 73 r
2 MS. WAGNER: That it was a good thing or 3 bad thing, not necessarily that someone taught 4 him, but if he understood it was a good or bad 5 thing.
6 MR. MacDONALD: That is assuming it was 7 good or bad?
8 MS. WAGNER: Or that it was a neutral thing.
g A It is a bad thing.
10 Q Why is it a bad thing?
11 A As I understand it now?
12 Q As you understood it prior to March 1979.
() 13 A My training prior to that focused on keeping 14 proper pressure control and having the bubble always 15 in the pressurizer. -
16 Q Did any of your training prior to March 1979 17 tell you what to do if you did have a bubble somewhere 18 other than at the top of the pressurizer?
19 A No.
20 Q At any time prior to March 1979, were you 21 familiar with steam tables?
22 A Yes.
23 -
Q Did you~ever use steam tables in the 4
~
24 j operation of a nuclear plant?
). e
^
25 l A Infrequentlyi l
.- ~ , 7 .,e. - , - .. - ., ,. . , . , . - . . . , . .
4 1 Ross 74
/
- () 2 Q Do you recall what it was that you would 3 use them for?
4 A Yes, the only time we ever used them were 5 'with closed cooling systems, systems outside the 6 reactor, to determine whether or not a particular pump 7 had the proper pressure and what temperature for that 8 system ought to be. We.never associated with steam i
9 tables with the use of the reactor system itself.
10 Q With respect to what you just testified 11 to, was it your understanding prior to the accident i
12 that you had to maintain certain pressure temperature
() 13 relationships in order to operate pumps?
14 A Yes.
i 15 Q Did you understand prior to the accident 16 why that was?
17 A Our understanding was it related to the 18 function of the pump itself.
19 Q Can you tell me how it related to the 20 ! function of the pump?
jg 21 A It would cause the pump to cavitate or not i
22 pump water.
23 Q When you say it would cause, you mean if 24 ; the temperature-pressure. relationship were such that M) L25 l
there was voiding or saturation: is that what you mean?
1 Ross 75
( 2 A Yes.
3 Q Prior to March 1979, were you familiar 4 with a system of the nuclear supply system called the h 5 high pressure injection system?
6 A Yes.
. 7 Q Did you know prior to the accident what its 8 function was?
9 A Yes.
10 Q Can you tell me what it was?
1 l
t 11 A It is a normal makeup system to the plant.
12 It is a chemical addition system to the plant. It 13 provides seal injection and makeup to the RC pumps.
14 It provides a source to add water to the core flood 15 tanks. It is an ESAS system that will actuate to 16 put water into the plant. It was a multipurpose system.
17 It was a chemical control system.
18 Q What do you mean by ESAS?
19 A Engineered safety systems actuation system.
I l
20 Q When the HPI system was in its ESAS mode,
! l what was its function, if you understood at the time?
{ 21 22 A It's function was to-put water into the l
23 .
plant and restore the pressurizer level.
r l
,_q 24 Q What would cause the plant to need water from 25 .
the,HPI system?
, 1 Ross 76 f 2 A A leak.
Q What was the actuation set point of HPI in 3
4 its ESAS mode, if you can recall?
h 5 A It depends on the unit.
t 6 Q Unit 2?
7 A 1600 pounds.
8 Q Does that mean 1600 pounds pressure in the 9 primary system?
10 A Yes.
11 Q Is it correct then that the actuation of 12 HPI in its ESAS mode related to pressure?
() 13 A The actuation signal was related to I
14 pressure.
1:
15 Q Did you understand why it was related to 16 -pressure?
17 A No, other than you had to pick an actuation 18 point. Pressure was picked for some reason.
19 Q Prior to March 1979, had you ever heard i
20 of a transient occurring at TMI-2 in which the reactor i 21 coolant system outside of the pressurizer reached gg) .
22 saturation conditions?
23 MR. MacDONALD: You are again talking of g . 24 bulk boiling?
YJ l
' MS. WAGNER: Yes.
25 l
f.
l l
\
1 Ross 77 2 A I have heard of the transient. ,
3 Q You have heard of a transient prior to 4 March of 1979 in which the system reached bulk boiling 5 conditions?
6 MR. MacDONALD: She is asking for your 7 recollection.
, 8 A Can you ask it again?
J 1 9 Q Prior to March 1979, had you heard of any 10 l incident at TMI-2 in which the primary system reached 4
t 11 saturation conditions, bulk boiling conditions, outside 12 of the pressurizer?
13 A No.
, 14 Q Do you recall ever receiving any training i 15 from Metropolitan Edison about an incident which j 16 occurred which did involve such saturation conditions?
i 17 A Any training?
18 Q Yes.
19 A No.
20 (Recess-taken.)
21 (Continued on next page)
Jgg 22 23 l j i 1
- i !
. (:) 25 l
I
1 Ross 78 Di (j 2 BY MS. WAGNER:
3 Q Just before you answered the last question, 4 you indicated that you had been told of some kind of 5 incident at TMI that saturation had occurred in the 6 primary system. Is that correct?
7 MR. MacDONALD: I don't think that was 8 his answer.
9 A No.
10 MR. MacDONALD: He said no.
11 A I think I said no.
12 .
MS. WAGNER: I don't want the answer read
() 13 back. I believe in answer to_one of my 14 questions where I was asking if he had heard 15 about events at TMI involving saturation, first 16 he said yes he had and then he clarified 17 and said no he hadn't.
18 Q I wonder if your clarification was based on 19 the time that you understood my question to be directed 20 towards or if clarification was based on something else?
i 21 A 'I think the clarification was based on
! Jgg 22 understanding of times.
23 Q So after the accident at Three Mile Island'
! 24 ,
in March 1979, did you hear of any transient occurring 1
25 at Three Mile Island Unit 2 prior to that accident
i 1 Ross 79 2 which involved saturation in the primary system outside 3 of the pressurizer?
4 A The time frame was after?
I 5 MR. MacDONALD: Aside from conversations 6 with counsel.
7 Q Yes.
8 A I had heard of something after.
9 Q What did you hear of?
l A Just something to the effect that there had 10 11 been the case where something had happened that caused --
12 and then the term wasn't even " saturation" or " boiling,"
( 13 I think it was more the loss of pressurizer level, a 14 problem, but I heard that after 1979, 15 Q Do you remember from whom you heard it?
16 A No.
17 Q Did you ever hear of an incident which 18 occurred at Three Mile Island Unit 2 which resulted in I
19 voiding in the upper head of the reactor vessel?
20 A No.
21 Q You didn't hear about that either before or 22 after the accident except for the accident itself?
1 23 1 A No.
24 i Q Have you ever heard of the concept of net
\v '
25 positive suction head?
, - - + - - , ,,p ,rn+ - * - - -i---- --~w- w ~e f - - - - -
.. ._ _ _ _ _ _ _ _ ~ ~ . . _ _ _ - .. . . . _
. 1 Ross- 80
- -s 2 A Yes.
3 Q I will refer to that from now on as NPSH.
4 What is NPSH?
5 MR. MacDONALD: His current knowledge?
2' 6 MS. WAGNER: Yes.
7 A It refers to the amount of pressure you have-8 available at the suction of a pump that is greater than 9 the saturation pressure of the fluid that the pump is 10 pumping. It refers specifically to a localized area 11 around the pump or to that specific system.
12 Q Prior to March 1979, were you ever familiar 13 with NPSH curves?
14 A Yes, I was.
15 Q Did you ever use those curves in operating 16 reactor coolant pumps?
17 A We used them in the operation of reactor 4
i- 18 coolant-pumps. We had a curve that we kept_the operation 19 within. .Our knowledge was that it pertained to the
-20 pump itself and was localized to the pump.
- j. ll 21- Q Did you ever understand prior to March 1979 L
!- 22 that - there was any relationship.between the net positive
- j. 23 . suction head curve and a saturation curve?
~ 24- -
A Yes, there was.a relationship. Here again, 25- it dealt with the pump, the localized condition around
1 Ross 81 2 the pump and at the impeller of the pump specifically.
3 Q Was the relationship in essence that if in 4
that localized area fluid was in saturated state that h 5 that would bear some relation to the operation of the 6 pumps?
7 A If the localized conditions at the pump were 8 such that there was flashing in the eye or the 9 impeller of the pump, it caused damage to the pump, 10 and it could cause a loss of pump capacity.
11 Q Prior to March 1979, were you aware of 12 something called the fuel pin compression curve?
()
gs 13 A Yes.
14 ,
Q Do you recall what that was?
15 A It was a curve that had been provided by
, 16 B&W that we tended to operate within the confines of.
17 Why was that?
Q 18 A It had to do with hydrating clad hydrides 19 and how they arranged themselves under a stress.
l
] 20 Q When you say you operated within the curve, 21 what were the elements of the curve? Was it a curve Jgg 22 based on temperature and pressure?
23 A It was a curve based on temperature and 24 pressure.
f3 b 25 Q What, to your understandingswould have been
1 Ross 82
/G
(_) 2 the result had you oper ated outside of that curve?
3 A Improper alignment of these hydridings 4 and weakening of the clad, although we also 5 understood it was not a big deal to violate it because 6 there was a lot of conservatism within the curve.
7 Q But I take it you nevertheless believed 8 that it was better to stay inside it than to go outside 9 it as a normal operating matter?
1 10 A Our goal was to stay, of course, within 11 he confines of that curve. It was supplied by our 12 vendor and we operated within those confines.
13 Q I take it you also tended as much as you 14 could to operate within the net positive suction head 15 curve?
16 A Yes.
17 Q Were you ever told' prior to the accident 18 in March 1979 of any instance at any plant in which 19 a PORV had stuck open?
20 l A I had knowledge of PORV openings or failure i
to close. I am not sure they.were stuck open.
tj ) 21 22 Q .What is the distinction you are drawing 23 between a failure to close and a sticking open?
I 24 A Some electrical malfunction causing them
("]N
\. r 25 ! to open and remain open.
1 Ross 83
,s j[ } 2 Q But you were familiar with some situation 3 in which they were open at a time when they should have 4 been shut?-
k 5 A Yes.
6 Q Did you have an understanding as to what 7 would happen in such a situation?
8 A I --
9 MR. MacDONALD: You are asking for his 10 recollection of what it was that happened when 11 he knew about these ones that failed to close?
12 MS. WAGNER: If he recalls having an 13 understanding of what the result was of a PORV 14 being open when it should have been shut.
15 A I have an understanding that it would cause 16 a transient. Cause an upset in the plant. We 17 never practiced that one and looked at it on the 18 simulator, nor did we ever specifically train, "This is 19 what you do for a failed-open PORV or open PORV."
20 Q You had never seen a stuck-open PORV 21 on the simulator? Is that your testimony?
22 A No, that wasn't my testimony. I said that 23 1 we had never carried one to where we could see the l l
1 24 ! effects of the PORV stuck open. It was always of a very O 25 short time duration, where you had an alarm.come in and i i
- - . .,. - . - ., . ~,- ,
. . ___ _ _ - ~.. -
f 1 Ross 84
, ; -~
2 you pushed the button and you stopped the transient.
i' 3 Then you would isolate it. But the transient was never 4 carried out to where you could see the effects of what lh' 5 would happen if you didn't.
6 But your training was that if you believed '
Q
? 7 a PORV to be open when it should be closed that you 8 should isolate it? Is that correct?
- 9 A Yes, I believe that is correct.
i' 10 Q Were you taught.at any time prior to l 11 March 1979 how to recognize that a PORV was open when i 12 it should be shut?
13 A' Yes, our training at the simulator always
- 14 focused around light indication and alarm indication.
}
i 15 Q There was a light at the simulator that 16 . told you when the PORV was open?
l 17 A There was an alarm.
18 Q~ What kind of an alarm?
19 A I don't recall but something would tell you 20 fofanalarmcondition.
i .
[ 21 Q That was the only. training you received .
22 about how to recognize an open PORV? >
23 A Here, again, we never picked out the PORV, :
l 24 i - "we" being B&W or Met Ed, that-there was a source that 0;' 25
, 'we would analyze step by step.all the way through --
i l
l l
L.
, . .-...u..___ --
i 1 Ross 85
( 2 these are all the systems of a PORV operating -- we 3 never did that.
4 Q You did indicate that on the simulator I 5 that you were taught to recognize if there was a PORV 6 open, you should isolate it. Taking that situation 7 alone, was the only symptom you were taught to 8 recognize some kind of alarm which you cannot remember?
9 A No. They had other symptoms that went 10 along with it.
11 l Q What were those symptoms?
12 A Those symptoms would be normal plant upset
() 13 systems, a decrease in pressure, a decrease in makeup 14 tank level.
15 Q Whatever the alarm was at the B&W simulator
} 16 which indicated that a PORV was open, did you have the 17 same alarm at TMI-27 18 A No. We had installed at TMI-2 as a result 19 of a problem at TMI-2, a light indicator that was our 20 main indication of the PORV position, g 21 Q Is it correct that that light indicator 22 was not.part of the B&W simulator?
23 A They didn't have a light that was exactly fs 24 l like that.
' I am not sure what their indication of AN-)
25 PORV was.
l I
y . - -
., ,,-y -
. . - . . - .._.,..~. , . , ,w,- ,,,-
1 Ross 86
, 2 Q To the best of your recollection, though, 3 it was something different from whatever was in 4 the TMI-2 control room?
I 5 A Yes. Supposedly, ours was new and improved 6 at the TMI-2 control room.
7 Q Because it was a different indication or 8 alarm or whatever from the one at the simulator, did 9 Met Ed ever give any training as to how to recognize 10 an open PORV? How to recognize it in the control room 11 at Met Ed.
12 A I don't think they ever stepped up and i w s 13 said, "These are the five items for PORV," but when 1
14 they installed the new light, it was a position 15 indication light as far as our people were concerned, 16 and our understanding was it was recommended by B &U ,
17 this installation, because of a problem we had. They 18 used it as a position indication. This is the indicator.
19 We had the problem. Now we put this indicator in to 20 do away with that problem. That was their understanding.
21 Q Did you believe this light was a position 22 indication?
23 A Yes. It was similar to other indications t
they had in the control room that indicated position 7-]
\J 24 ;
95 . indication. I i
l l
1 Ross 87 l
l
- s 2 Q And you understood this light to be a 3 position indicator at the time it was installed 4 and thereafter until the accident?
4 I 5 A I knew the light was an indicator derived 6 from the electrical signal, but we as operators took 7 it as a position indication.
8 Are you telling-me that even though you Q
$ knew it was not a position indication, you treated it 10 as if it were a position indicator?
11 MR. MacDONALD: I don't think he said he 12 knew it was not a position indicator.
(~ 13 Q What was your understanding as to what that I4 light indicated?
15 A My understanding of what that light 16 indicated was a signal had been sent to the PORV to 17 open.
18 g ~ You did not understand that was any different 19 from being an indication of what the position of the
~
20 PORY was; is that correct?
- 21 A I think I understood there was a slight l
22 difference, but as operators, when you have a position 23 l indicator, it is a position indicator. It is not a 24 special indicator that indicates only one particular l
25 type of event.
1 Roso gg
) 2 Q Who told you it was a position indicator?
3 A It was up there as a light as a position 4 indicator. Therefore, it was used as a position lh 5 indicator.
6 Q Nobody told you, to the best of your 7 knowledge, that this did not indicate directly the 8 position of the PORV; is that correct?
9 A I knew that it was an electrical signal, 10 sensor. I am saying once it comes on the console, 11 we treat it as a position indicator.
12 Q To the best of your knowledge, did the
() 13 other operators about whom you have been speaking 14 understand that the light was indicative of an electrical 15 signal rather than a position?
16 A I'm not sure of their understanding.
17 Q Are you aware of any training conducted 18 on that point?
19 A None that I can recollect.
20 Q Do you understand or did you understand at 21 that time how the PORV worked, not that it worked on 9
22 pressure but how the valve worked, how it was 4
23 , electrically set up?
i
- 24 ; A I had a basic understanding of it.
V 25 Q Can you describe it for me?
I
1 Ross 89 gs A An electrical signal was sent to a solenoid
(_) 2 3
and the solenoid ported pressure and allowed the 4 pressure to open a valve.
5 Q Did you have any understanding prior to 6 March 1979 based upon your background in various )
7 training programs, including training in electrical 8 engineering, that it could be possible for a signal to 9 be sent to the solenoid and for the solenoid or some ,
a l
10 other part of the valve to malfunction so the signal 11 would not in fact cause the position it was supposed to 12 cause?
() 13 A Can you repeat the first half?
14 (The reporter read back from the record 15 as requested.)
16 A Are you referring specifically to a PORV 17 or to any valve?
18 Q Why don't we take any valve at the moment.
19 Any valve which was in some way similar to the PORV 20 . in the way it was set up.
A- I would say'we had no training that said, g 21 22 - or at least none that I can recolle c t , tha t said this 23 was possible. I think I would say anything is l
,_ 24 ;
possible.
.. sg !
25 Q To the best of your recollection, I take i
1 Ross 90
() 2 it you do not recall any training at Metropolitan 3 Edison to the effect that this signal light might or 4 might not show PORV actual position and therefore that lll 5 other symptoms should also be used in terms of 6 determining what the PORV position was?
7 MR. MacDONALD: I object. I don't think 8 there is any foundation that he ever testified 9 that there were no other symptoms that might l 10 be used or that there was no training on other 11 symptoms.
12 MS. WAGNER: I believe he did so testify.
13 What is your-testimony as to what other Q
14 i training was provided, if any?
l 15 A The training I referred to was training at 16 the B&W simulator initially, and I don't know how you 17 made the tie between that and no other training. I am 18 a little confused.
'19 Q I am asking you if Metropolitan Edison ever 20 gave you any training before March 1979 concerning the 21 identification of a stuck-open or failed-open PORV 22 other than to use this light which was not a direct 4
23 indicator light?
I fs 24 A Again, I think I have said I don't recall
\~s 25 l any specific training on diagnosing a PORV by itself as
1 Ross 91
) 2 being a special class on a PORV or anything like that.
3 Q Were you aware that in March 1978 a PORV 4 had failed to close when it should have at TMI-27 h 5 A I can't say I was.
6 Q Do you recall prior to March 1979 ever 7 having any opinion as to whether it was important or not 8 important to be able to diagnose a PORV which had l 9 failed open?
I 10 A Yes, I am aware of an incident in Unit 2 l
11 where the PORV opened electrically through a faulty or 12 undesired electrical signal. I am aware of that 13 incident.
14 2 In that instance, was the PORV opened when 15 it should have been closed?
16 A Yes.
17 Q Was that a good thing or a bad thing?
18 A That was a bad thing.
19 Q Did that result in any training on how to 20 recognize a failed-open PORV, whether opened because of
.g 21 an electrical signal or some other reason, a PORV which 22 was open when it should have been closed?
23 ! A. My recollection'is that resulted in an l
-S 24 installation of this additional. monitoring light.
x){ 25 Did it result in any training aside from that Q
. , _ _ _ y .., , = - , + - y .-
1 Ross 92
}{~
v 2 monitoring light?
3 A I don't recall any additional material other 4 than the light itself.
h 5 (At this point, a recess was taken.)
6 BY MS. MCDONALD:
- 7 Q Was there a system within the secondary 8 plant at TMI-2 known as the condensate polishing 9 system?
10 A Yes, there was.
11 Who designed that system?
Q 12 A I am not sure who designed it.
( 13 Q Did there come a time when some entity 14 l id on that system, the making of that system?
15 A I am not sure.
16 Have you ever heard of L&A Water Treatment?
Q II A Yes.
18 Q Do you know if that company had anything i i
19 to do with the condensate polishing system at TMI-2? I
)
1 20 A That company provided the skid,-the '
g 21 components.
22 Q Do you know whether Burns & Roe.had 23 anything to do with the condensate polishing system at 24
{J
'~'}
25 j
l TMI-2? l l l A They were the architect engineer.
I I
i
, . ,,- , , , - e~ ~ , , - -- , ~. ~ - , ,
1 Ross 93 2 Q What equipment comprises the condensate l
3 polishing system in general? !
4 A In general, it consists of resin tanks and h 5 in addition, a resin regeneration tank and a resin 6 transfer tank. It consists of valves to put particular 7 resin beds in and out of service, and the ability to 8 transfer those resin beds back and forth to be 9 regenerated.
10 Q By resin tanks, are those also known as 11 the condensate polisher vessels?
12 .A That's correct.
() 13 Q Uhat is " condensate"?
14 A Condensate is a term we use in the power 15 plant to denote that water which you have just reclaimed 16 from the steam that went through the turbine.
17 Q What is feedwater?
18 A Feedwater would be a higher pressure section 19 of that system.
20 Q Is there any difference between condensate g 21 and feedwater? Is it the same water, just at a different 22 pressure?
23 ! A It ic the same water but probably has been
(~5 24 l treated differently having gone through the polisher,
(_ !
25 and it probably has gone through more components when
1 Ross 94 2 it.becomes feedwater.
[ 3 Q But volumetrically, it is the same water?
4 All I am trying to find out is, the feedwater goes lh 5 though the condensate polishers and eventually results 6 in being feedwater. Is there any addition to that 7 feedwater before it becomes feedwater?
8 A Yes, there are heater drains and other 9 things that tie into the system.
10 Q Where does the heater drain water enter into 11 this system? ,
12 A It depends on the plant, but normally, it
() 13 enters at the suction of the feed pumps.
14 Q Approximately what percentage of feedwater 15 comes from the heater drains as opposed to the 1
16 condensate?
) 17 A 20 percent.
i 18 Q What was the function of the condensate 19 polishing system at TMI-2, as you recall? ,
l 20 A Just do what its name says'. To polish 21 or remove any impurities, maintain water chemistry.
3 Why was it necessary to remove these 1
4 22 Q l
23 impurities?
I 24 A The stear supply system'on the secondary Q .25, side of the generator did not have a blow-down function,
1 Ross 95
- q,) 2' nor was it designed for one, therefore, you had to.have 3 very pure water.
4 Q Can you explain that? I don't understand lh 5 your answer.
6 MR. MacDONALD: Is there a portion --
7 MS. MCDONALD: I ask~him to expand on 8 his answer.
9 MR. MacDONALD: Is there a portion of the 10 answer that you don't understand?
11 Q What did you mear; by "it doesn't have a 12 blow-down function"?
(O
_j 13 1 A Scme plants have the ability to remove a 14 certain amount of their secondary water out of the 15 generator to get rid of solids. B&W doesn't.
16 Q What happened prior to March 1979 if these 17 impurities were not removed?
18 A It could lead to component problems either 19 in the steam generator or more likely in the turbine l
20 : blading itself.
I 21 Q By " component problems," can you suggest 22 some problems that might happen?
23 A Westinghouse turbines had had a history of s 24 j where a chemistry problem was present of having turbine (w/
. I 25 l blade problems in their final bucket' stages.
l
- _. u - . , , ., . . _ . .
1 Ross 96 2 Q By that, do you mean solids precipitating 3 out and attaching themselves to certain components of 4 the turbine?
'llh 5 A I mean that. I also mean a chemical attack 6 on that particular component.
7 Q Such as corrosion of some sort?
8 A It could be.
9 Q Did you have an understanding prior to 10 March 1979 as to generally how long it would take for 11 these problems to occur in the turbine or anywhere in 12 -
the secondary side if the impurities were not removed?
13 A No.
14 Q Did you know whether it could happen in a 15 period of three minutes?
16 A My understanding was it would not happen in 17 three minutes but it was undesirable.
j 18 Have you ever heard of a person called Q
19 william Bland?
4' 20 A No.
21 Q Do you ever recall having any conversation 22 with Mr. Bland, William Bland?
23 ! A No.
i 24 MR. MacDONALD: If he'doesn't recall the
.J 25 person --
1 Ross 97 2 Q Do you recall having any conversations with 3 anyone after the accident at Three Mild Island regarding 4 how long the TMI-2 plant could be operated at Ih 5 normal rated power with condensate passing through the 6 bypass route? In other words, bypa'ssing the condensate 7 polishers?
8 A No.
, 9 Q Can you explain very generally how the 10 concensate polishers worked?
11 MR. MacDONALD: His understanding prior 12 to the accident?
() 13 MS. MCDONALD: Yes.
14 A Basically -- l 15 Q At TMI-2.
16 A Basically, they were a resin bed and 17 water would go through the bed. Impurities were both 18 filtered out and taken out by a process called ion 19 exchange. The idea being to remove the impurities in 20 the bed, have the impurities attach themselves in the -
21 form of ions to the resin beds and put out good water.
22 Q At TMI-2, was it necessary to periodically 23 regenerate the resin bed?
24 A It was.
fS
! V -
l l 25 Q. In the process of regenerating resin beds, l
-,-e-e v - +=w'r "
n 1 Ross 98 9
,) - 2 was it necessary to transfer the resin bed from the i 3 condensate polishing vessel to the regeneration tank?
4 A Yes, it was.
h 5 Q How was that done?
l 6 A It was done by a method called sluicing, 7 where water was directed into the tank and the tank 8 resin was allowed to flow through pipes into the 9 receiver tank.
10 Q Where did the sluiced water come from?
11 A It came off a separate water system.
12 Q Did that have a name, that water system?
I) 13 A Yes, and I don't remember because it is 14 different from my unit.
15 Q Do you know whether it was called the i
16 demineralized water system?
17 A very possibly.
18
.Q Were there valves on the condensate polishers r
19 known as discharge or outlet valves?
5 20 A Yes.
g 21 Q What was'the function of those valves?
22 A They were an isolation valve. They allowed 23- i you to remove the vessel from' service ortput 15oin
.g 24 ; service.
25 LQ For a lay person, were these the valves out
'i.
^
\
1 Ross 99 J
lO' 2 of which the water flowed from the condensate polishers,
(_j 3 if they were open? *'
s s
s '
4 A Yes.
\
I 5, Q And if they were closed, would all flow from 6 the condensate polishers be stopped?
7 A Yes. s 8 Q 0; when.the discharger outlet valves from -
4 9 the condensate polishing system were closed, that s y s t e'm
10 woldd provide no con'densate for the feedwater system, 11 the main feedwate r systhm; is that. correct?
O s.
12 A If all valves.ofXall polishers were shut,
( 13 yes.
14 j Q Besides the c6Edensate polishing system, 15 was there any other source of condensate for the ,
a ..
16 feedwater system?
17 ~ A- Heater drain s 's t e n .
18 Q Had the . water and heater drains been i 19 already polished? ,
20 f. A Yes and no. It had been polished but it g 21 now is coming back virtuall-) raw. '
22 Q Was it not thobght necessary prior to the s s
23 .
accident in March 1979 to poi ~ish the water flowing from 1 % s
^ g~) 24 l the heater drains into the f,eedwater systen?
t /- >.
(
=
25- A It depended...We sworried about the. chemical ..
+
1 t i T ,
l ~
I;
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-Q s 3
,] . - - _ . . . _ _ -
-k ,, ._
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L
, sN,.
gg i Ross 100 1
i /~T -
sk / 2 content of the water itself, and based on that, we
, 3 would arrange the drains to d ump back so they would be T
4 purified at times. We could manually dump them back
- st 'g ~ _ 5 into the condenser and hence become condensate and go 6 through the polishers, s
7 Q Is the re any procedure of when you would do 8 that and when you wouldn't do that?
9 A I don't recall.
10 Q Do you recall whether there was normal
, 11 practice of doing that? Did that happen mo're often than 12 not or the other way around?
(
\m) 13 A I can't say. I left Unit 2.
Q You we re , I take it, familiar with the basic l l
15 design of Unit 2 as it was originally designed, the 16 condensate polishers?
L.
1~ A I was familiar.
i I 18 Q Do you know whether that basic design was 3
19 ever changed between the time polishers were originally 20 installed and the Three Mile Island accident?
jl 21 A It was.
22 Q What were the changes that you recall?
23 A I don't remember the changes specifically, 24 b'ut changes had.to do with sluiced water..and isolation
- 25 of sluiced water.
~. . . ..
1 Ross 101 2 Q Was that a change in procedure for 3 tran s fe rring resins from the condensate polishing 4 vessels tc the regeneration tank?
5 A That is my recollection.
6 Q Do you recall any mechanical changes to the 7 design of the polishers as opposed to procedure 8 changes?
9 A There was a mechanical change involved in i 10 that also.
11 Q Do you ever recall prior to the Three Mile 12 Island accident that TMI-2 experienced' dif ficulty in
, 13 transferring resins from the condensate polishing 14 vessels to the regeneration tank?
15 A Yes, I recall-it happened.
16 Q Can you describe what difficulties were 17 from time to time encountered?
18 A Not in detail.
~
19 Q Did it ever happen that the resins would 20 ! become plugged up in the transfer line from the g 21 polishing tank.to the regeneration. tank?
22 A I am not sure of the exact location, but l 123 there were clogs that we re pre sent.
I i 24 i Q Did there come a time when an inlet was t' k- l 25 [ installed in the bottom of the condensate polishing
]
1 Ross 102 2 tanks to provide something called fluffing air to the 3 resin beds? Do you recall that happening?
4 A I recall the connection. I don't recall it 5 being installed.
6 Q You are familiar with the term " fluffing 7 air"?
8 A Yes.
9 Q What is the function of fluffing air?
10 A Just that it fluffs the resin. Makes it 11 fluid.
- 12 Q The change that you described earlier
( 13 regarding sluiced water, do you know whether that change 14 had anything to do with fluffing air? Were they 15 connected in any way?
16 A Not to my knowledge.
17 Q How did the fluffing air enter the
, 18 condensate polishers?
19 A Right at the bottom of the tank through a 20 valve arrangement.
Do you know whether fluffing air lines-l 21 Q ;
22 were part of the original design of the TMI-2 23 condensate polishers?
24 i A I don't remember.
25 Q I would like to show you a document that has
1 Ross 103 J
2 been previously marked B&W Exhibit 164.
3 Just take a look at that.
4 My question will be, have you ever seen it 4
before?
5 1
6 A No.
7 MR. MacDONALD: This is aside from 8 preparation for deposition. All these questions 9 are 'a ride from preparation for depositions.
10 Q Prior to preparation for this deposition, i
11 you don't recall ever seeing this document; is uhat 12 correct?
(} 13 A That's correct.
14 Q I refer you to the first page of the 15 document, which appears to read, "The resins in the 16 polisher tanks cannot be satisfactorily sluiced to the 17 receiving tank without the aid of service air being
, 18 injected into the bottom of the resins. Provide a 19 permanent source of instrument or service ~ air to the i
20- bottom of each condensate polisher tank. "
j .21 Does that statement refresh your recollection
- 4. 22 in any way regarding any changes to install an air.
23 l inlet to the condensate polishing tanks?
l 24 A No, not particularly.
25- Q Do you recognize this document form which
- i. . . . -
1 Ross 104 :
I I
2 reads at the top, " Burns & Roe Field Questionnaire,"
3 just the form of the-document?
4 A Yes.
5 g what was the function of Burns & Roe 6 field questionnaires from 1977 through 1978?
j- 7 A My understanding is it was a form to 8 initiate problems and solve problems covered during the 9 start-up phase.
10 Did it occur from time to time that Burns &
Q 11 Roe field questionnaires would be submitte d to GPUSC?
12 MR. MacDONALD: You are asking whether he
~
13 ever recalls that happening?
%J 14 l Did it ever happen that you recall.
Q 15 A I don't recall specifically.
16 Do you have general knowledge about how i Q 1
1~ Burns & Roe field questionnaires were submitted from 18 entity to entity at TMI-27 19 A I am not familiar with the chain or the flow.
I 20 Q. Do you know whether at any time on the lg 21 condensate polishers at TMI-2 there had ever been an 22 air. inlet at the top of the condensate polishing tanks 23 as opposed to the bottom?
24 l A I don't recall that.
-(--
25
(.
Q In the.latter part of 1977, do you know, or c
_ _ . _ . ~_ _ .- , _ _ ___ ~ . . , - _ . ._
1 Ross 105 I i
I
(
2 do you recall now what the source of the air at the 3 bottom of the condensate polishing tanks was?
4 A No.
5 Q You don't know whether it was instrument 6 air or service air?
7 A No.
8 Q What is service air?
9 A Service air is air that is normally used in i
10 the plant for tools, that type of thing. Air-driven 11 type of equipment.
12 Q What is instrument air?
A Air that is normally used throughout the
} 13 14 plant.to drive instrument and control valves.
15 Q What was your understanding prior to the 16 accident regarding the source of either instrument or 17 . service air? Were there compressors somewhere?
18 A Yes.
19 Q Where were they?
l 20 l A They were located in the bottom floor of a 21 building in Unit 2.
22 Q Was there any method of connecting service.
23 l air lines and instrument air lines at TMI-27 94'
~ A Yes.
f~% l
\b 25 Q In normal operation of the plant, were those
1 Ross 106 k: f
( ) 2 lines generally connected? '
3 A I don't recall. ,
i i
4 Q Do you recall what the approximate pressure 5 of service or instrument air was?
6 A Approximately 100 pounds.
7 Q Did there come a time when in order to i:
[~ 8 force the resins from the condensate polishing tanks i-j 9 to the regeneration tank that pressure was somehow 10 built up in the condensate polishing tank in order to 11 try and move the resins into the regeneration tank?
12 Do you recall that happening, ever?
(}
13 MR. MacDONALD: At Unit 2 prior to the 4
- 14 accident?
i.. 15 Ms. MCDONALD: Yes.
1 16 A No.
l 17 Q Do you know what the pressure of the sluice d l 18 water, the approximate p re s's ure of the sluiced water f
19 was, coming into the condensate polishing tanks prior 20 to the accident at TMI-2?
A g 21- I don't recall.
22 g Was.that greater than 100 psi?
t 23 A I don't recall.
24 [ Q Are you familiar with a. type of valve known 1 ~ D. 25 I
as a check' valve?
r
.s' c E -- -- w e v, +w.n e -w v-as w y-* *--,+-,,.m,ere- -*--r-,--em, er s -mm e- **c . . - n,--,- e-g-----ee ..--mw-w-**v=,,rvy=,,%-ryv,-v<y, - r y =, e - ,-y-
1 Ross 107 l f~)' Yes.
( i. 2 .A 3 Q What is a check valve, generally?
4 A A. valve placed in line to restrict flow
'5 in the backwards direction. It acts as a check or 6 stop.
7 Q Was there a check valve in the fluffing 8 air line at TMI-2 to prevent water from backing up into 9 the line?
10 A I don't recall.
11 Q Are you aware of any of the check valves at 12 TMI-2? Can you remember any of them?
13 A No. I have been away a long time.
A 14 Q Are there check valves at TMI-17 15 A We don't have this particular system in 16 TMI-1.
17 Q Were you ever aware prior to the accident 18' at TMI-2 of check valves of any sort failing or leaking 19 - or having any problems?
20 A ;I am aware we investigated certain check
. i
,jgg 21 valves. I. don't know which ones they were today.
22- Q What do you recall about that investigation?
23 ;
A I recall looking to see if it was possible i
p ,- 24 they had back leakage through them. '
\_)'
25 Q Without asking you specifically what i
, g - ,. . , , , - , -#*e-- , _ _ _ , -#,-- .%- , - , , , - - - - + , ,-.c---,. .,w-,, ,.-, --.-
1 Ross 108 2
~
numeri cal numbered valves those were , do you remember 3 what aystem those valves were associated with?
4 A They were associated in some way with the 5 polishing system.
6 Q Did you personally look into the performance 7 of those valves?
8 A Not personally.
9 Q Did you assign someone else to do that?
10 A Yes.
11 Q Did you participate in reviewing the results 12 of that investigation?
13 A Yes.
14 Q Do you know what tests, if any, were done on 15 those check valves to ascertain whether they were working 16 properly?
17 A No.
18 If those check valves had not been working Q
19 properly, could water have backed up into the air lines 20 connected to the condensate polishers?
- g 21 MR. MacDONALD
- You are asking him as he 22 understood this system prior to the accident?
23 ,
MS. MCDONALD: Yes.
I
- g 24 A My understanding is it was possible. That s
25 is why we looked.
d
,. . .- . . .~ .- .
1 Ross 109
, 2 Q Were the condensate polisher discharge 3 valves air operated, as you understood it, prior to 4 the accident?
ib
'w 5 A Yes.
6 Q They operated by TMI-2 instrument air?
7 A They are operated by air but whether it is 8 instrument or service or whether they are cross-i 9 connected, I don't know.
10 Q Prior to the Three Mile Island accident, 11 did you have an understanding as to what the response 4
12 of the condensate polisher discharge valves would be d
13 upon a loss of whatever air operated them?
A My recollection is that they would fail l 14 15 shut after some time period.
16 Q Just so I understand, was it your 17 understanding that the valves would inte rpret a loss of 18 air as a loss of signal and therefore fail shut?
19 Do you understand my question?
20 A Yes.
) 21 I don't know why but my recollection is that 22 they would just fail shut.
23 Q Was there a bypass to the condensate 24 polishing system at TMI-27
\N-) 25 l A Yes.
- -, , - . , , -- . ~ . ~ . - s m . _ . , ,
1 Ross 310 2 Q Was this' bypass a possible means of supplying 3 condensate to the feedwater system in the event that the 4 flow of the condensate through the polishers was 5 interrupted?
6 A Yes.
7 Q was there a bypass valve that affected
, 8 this bypass?
4 9 A Yes, 10 Q Do you recall whether that valve was known i as Co-V12?
11 12 A My recollection is that is correct.
13 Q Other than the use o f valve CO'-V12, is 14 there any - other me thod by which condensate could be 15 directed around the condensate polishers and into the 16 feedwater system?
17 A None that I am aware of.
18 Q Do you recall prior to the accident at 19 Three Mile Island whether that valve, that bypass 20 system, was ever used?
r 21 A I don't recall us using it.
22 Q Could the condensate polisher bypass valve i
23 ,
be opened from the control room at TMI-27 i-24 A Yes.
25 g Was that an automatic valve?
1 Ross 111
[)
v 2 A No.
l 3 Q It could be manually' opened from the control l I
4 room is that correct, by pushing a button?
5 A Yes.
6 Q Was it also possible to open the valve i 7 by hand when you were right next to the valve?
8 A Yes.
9 Q was that a Limit Torque operated valve?
10 A Limit Torque is a brand name but it was a i
11 l motor operator.
12 Q Prior to the accident at Three Mile Island, 13 do you know or did you know why there was no automatic 14 bypass included in the design of the TMI-2 polishers?
15 A No.
16 Q Did you have an opinion regarding whether 4
17 there should have been an automatic bypass?
18 MR. MacDONALD: Did he ever state an 19 opinion?
20 MS, MCDONALD: Did he ever have an opinion.
MR. MacDONALD:
ll) 21 Let's stick to what he 22 said to somebody, vocalized or wrote.
23 Q Let's start with that. Did you ever voice 24 an opinion to anybody to that effect?
('N
.s > .
\~# 25
[ A Yes.
l l
l
1 Ross 112 (j 2 Q Does the Powdex system at TMI-1 have an 3 automatic bypass valve?
L A 4 It does.
-i 5 Q What is your understanding of the f netion 6 of that valve?
7 A To open in case of a high differential 8 pressure across the Powdex vessels.
9 Q Is having that bypass at TMI-1 a desirable 3
10 characteristic?
4
, [
11 MR. MacDONALD: I will instruct him not to i 12 answer if you ask him for his opinion today 1-() 13 because we are not here to get Mr. Ross' . opinion 14 as an expert. Whether he would be an expert 15 or not, he is here to testify as-to facts.
16 Q Did you have an opinion regarding the bypass 17 valve at TMI-l o f whether it was a desirable 18 characteristic of that plant prior to the accident at i 19 TMI-27 20 MR. MacDONALD: You are asking if he f . 21' ever wrote an opinion or vocalized an opinion?
22 Since that has been stated several. times 23 in the past, I will permit him to answer if he 24 j stated that, wrote- it, heard it from somebody, O' . k 25 ; but not'whether he may have formed an opinion-1 i
- , , , , ,----.-e-.,. - , - - - , , , - - .
, , , - , , --nn.n -. -,n.. ,,,-n. v.,-,r-, ,-,,
1 Ross 113 ,
( 2 and never expressed it to anyone.
3 MS. MCDONALD: I will ask him whether he 4 ever formed an opinion, whether he expressed it 5 or not.
6 MR. MacDONALD: I will instruct him not to 7 answer unless he expressed it or heard it.
8 MS. MCDONALD: What is the basis?
9 MR. MacDONALD: The basis of the 10 instruction, it is unfortunate that it has 11 happened. We encountered it from Davis Polk on
. 12 a number of occasions. If mental processes in l
13 opinion form were not vocalized or written, the 14 witness has been directed not to answer.
15 MS. MCDONALD: Do you have any authority 16 in the Federal Rules of Civil Procedure?
17 MR. MacDONALD: We are proceeding on that 18 basis. He is instructed not to answer.
19 BY MS. MCDONALD:
20 Q Did you ever voice or write or have any j 21 discussions about TMI-1 bypass valve prior to the 22 accident at Three. Mile Island?
23 A Yes.
l 24 : Q Can you describe those' discussions?
) 25 j A Having knowledge of that bypass existing
.. -_.-. . . , . _ .~. ,
M 1 Ross 114 l
2 at TMI-1, we questioned whether or not it ought to 3 be in TMI Unit 2, and we also questioned whether or 4 not that ought to exist in TMI-1. In our opinion, it 5 wasn't firm that you should or should not have it.
6 Q Does it exist today on Unit 1?
7 A Yes.
l 8 Q With whom did you have these discussions?
9 A Within a group that was formed to look at 10 polisher problems in Unit 2.
11 Q Was there an alarm in the control room at 12 TMI-2 indicating that flow through the condensate
() 13 polishers had stopped?
14 MR. MacDONALD: Prior to the accident?
15 MS. MCDONALD: Yes.
16 A I don't recall.
17 Q Do you recall any way that the operators 18 could know that flow had stopped through the t
19 condensate polishers?
20 A I am sure there would be other indications.
g- 21 Q Can you think of any?
- 22. A Feed pump trips.
l 23 Q Were the operators instructed to do anything 24 , in particular if they became avare that flow had b I
'25 ! stopped through the condensate polishers prior to the i
- -- - -- -+ '- ~~'
1 Ross 115 ;
2' accident?
3 A I am no longer familiar with the sp e ci fi c-4 procedure.
5 Q Do you recall that they ever were taught to 6 open the bypass valve if they became aware that flow 7 through the condensate polishers had stopped?
8 A I believe they were.
9 Q Do you recall if there was a written 10 procedure to that effect?
11 A No, I am no longer familiar with the i
12 procedures.
() 13 Q Do you have any recollection as to how they 14 might have been instructed to do that?
15 A. No.
16 Q I think I asked you this before. If all l 17 flow through the condensate polishers stopped, would 18 that result in a complete loss of main feedwater if 19 all the polishers were shut?
20 A It would result in a large percentage loss.
Upon a loss of the large percentage of main lh 21 Q 22 feedwater, what would ordinarily happen next at TMI-2 23 prior to the accident?
24 A The feed pumps would trip.
O 25 i Q What would happen after that?
--- - m - , . - - ,
1 Ross .116
( 2 A You lose flow to the secondary side of the 3 steam generators.
4 Q Is there some method by which that flow is 5 replaced?
6 A No.
7 Q Are you familiar --
8 A Let me go back. Emergency feedwater would 9 automatically actuate then.
10 Q Was there a time delay between the failure 11 of most of the main feedwater and the initiation of 12 auxiliary or emergency feedwat.er?
13 A There was some time period. I don't know 3
(
14 what that was.
)- 15 Q During this time period, there would be no 16 fe e dwate r supplied to the steam generators; is that 17 correct?
18 A That's correct.
19 Q Would a loss of feedwater condition at 20 TMI-2 result in a reactor trip or runback?
l 21 A Yes.
22 Q Did you become aware in October 1977 of a
'23 '
loss of feedwater condition that had occurred at TMI-27 i
- 24 l A Yes.
I c %j - '
25 Q How did you learn of that incident?
1 1 Ross 117
(/ j\
l 2 A I was working in the unit at the time or 3 someplace near the unit at the time.
4 Q Can you describe the incident?
O 5 A Not in detail.
6 Q In general?
7 A The plant was shut down. We had loss 8 through some upset in the polishers' condensate and 9 feedwater flow.
10 Q At the time, was the secondary plant 11 at TMI-2 still in the start-up and testing program? -
12 I A My understanding is yes.
I show you a docunent previously marked as
( 13 Q 14 i B&W Exhibit 165.
15 Have you ever ceen any part of that document 16 before?
17 A Yes.
18 Q Referring just to the first page, have you 19 seen that page before today?
20 MR. MacDONALD: This is all excluding 4
l 21 preparation for your deposition.
- 22 A No.
23 i Q Other than preparation with counsel, the 24 part of this document which you saw before was the O 25 typewritten' memorandum attached to the first page; is 4
1
. -. , . - , - -. * -g- , .-w--- --,y + . - , - . - - - , , , - , - - - -:y--, - e, - - - - -
1 Ross 128
.ss 2 that correct?
3 A Yes.
4 Q Do you know a person named J. A. Brummer?
5 A Yes, I do.
6 Q Have you eve r seen Mr. Brummer's. handwriting 7 before?
8 A I can't remember.
9 Q Have you ever seen his signature?
10 A I can't recollect that.
11 Q Does the memo attached to this first page l 12 relate to the investigatiohs which you referred to 13 earlier in testimony today regarding the condensate 14 polishers?
15 A Yes, it does.
16 Q And that includes investigations of the 17 check valves, whichever ones they might be; is that 18 correct?
19 A Yes.
20 Q And investigations and conversations
,ll 21 regarding the TMI-2 bypass valve;. is that correct?
22 A Yes.
23 Q The first page of this document appears i- .
24 to read,'" Based on a loss of feedwater occurrence l 25 on Unit 2 as' identified in attached letter, Met Ed
. _ . _ ____ _ . _ . _ , . . _ _ - . . _ . _ _ - . _. ,_ _ _ _ . . _ _ . . ~ . . _ _ _ . _
1 Ross 119 f~)
a 2 feels that Burns & Roe should reevaluate the 3 control of COV-12. The desirable change appears to be 4 a control in place of the present gate valve, motor 5 operator, with a control loop which will open the valve 6 either on high DP across the condensate polishing 7 system or low effluent flow. At a minimum, if the 8 above recommended change is not incorporated, B&R should 9 reevaluate the DP across COV-12 as it would not open -
10 as designed during the occurrence."
11 Do you recall whether either of those 12 suggestions were ever taken?
13 A No, I do not. I left the unit sometime 14 after this.
l 15 Q Referring to the memo which is attached to 16 the first page , referring specifically to the second 17 paragraph under " Summary of Events," in the middle of that 18 paragraph is a sentence that reads, "Upon detection, 19 the control room operator immediately trie d to open 20 COV-12 condensate polisher bypass valve; however, he was
]ll 21 unable to open this valve from the control room."'
22 What is your recollection regarding the i
23 l events of October 1977 with regard to the attempts by
. 24 , the operator to open that valve, namely, COV-12?
25 l A Just that he was unable to open.it from the
l I
1 Ross 120
- [O\ 2' control room.
3 Q Prior to the accident at Three Mile Island, 4 did you ever find out why he was unable to open that 5 valve?
6 A No.
7 Q Do you know whether anyone else at GPU or 8 Met Ed found out why that valve wouldn't open?
9 A No, I do not.
10 Q Do you know whether anyone investigated 11 why that valve could not be opened from the control 12 room?
(} 13 A No, I do not.
14 Q Do you recall who the control room operator 15 referred to in this document was?
16 A No, I do not.
t 17 Q Do you know a control room operator who ever 4
18 worked at TMI-2 by the name of Cooper?
19 A I know of-a cooper.
4 20 Q Was he a control room operator at some time?
21 A Yes.
22 Q Was he a control room operator at TMI-27 23 -A Yes. -
24 .
Q Do you remember the time period at all?
. /'N '
\') 25 l A No.
l i
, - . . - - . . - ..n.. .
.,--..a - ,- , - -
_ , _ . . . - -- .-- . _ = - _ . - .
m "k
I Ro06 t
121 4 /) 2 Q what participation did you have, if any, in
- .V 3 the preparation of this memorandum?
4 A This was a memorandum written out of our input as a group.
5 6 Q Was the group, did the group consist of 2= 7 yourself, Mr. Brummer, Doug Weaver, and certain i
i 8 operators?
9 A Yes.
10 Q Who is Doug Weaver?
11 A He is Instrumentation Foreman.
12 Q What was his position in October 19777 a
, 13 A 2 - I believe he was Instrumentation Foreman.
. 14 Q Is he still an Instrumentation Foreman?-
j 15 A Yes.
t 16 Q What was Mr. Brummer's position in or t
17 around October 19777 1
18 A He is an I&C Engineer.
I i-19 Q Is that Instrument & Control Engineer?
l 20 A Yes.
g) 21 Q Referring to the last page of this document, 22 i t bears your name. It appears to have been signed by 23 someone else for you; is that correct?
i 24 A Yes.
25 Q Who signed your name for you?
f
+~* - -e, 3--,. . - ---. ,.- .-r- ,,--,ur.,.-._,.--.w,,,~,,.n.,,.~, , ~ . . - , .-.y,wv.y y . -. y-_,_,...,---- ,m,.y--_s,mv. -._m-.-y., e.7 - . - ..-
1 Ross 122 2 A I'm not sure.
3 Q What does it say there?
4 A The last name is Marshall.
5' Q Does it say " Marshall for M. J. Ross"?
6 A Yes.
I Q Is there a Mr. Marshall who ever worked O at Three Mile Island?
9 A There is.
10 What is his first name?
Q 4
11 A Bubba.
12 Is he still at Three Mile Island?
Q 13 A To my knowledge, yes. '
I4 Q Do you have any recollection as to why 15 Mr. Marshall may have signed your name to this document?
16 A I may have been someplace else or something.
17 I have no real deep recollection.
18
, Q Do you recall instructing Mr. Marshall
- 10 to sign your name to this document?
I .
20 A I don't recall that specifically.
f l
21 Q Do you have any practice of having people ll
. 22 sign your name to documents when you don't know about 23 . it?
i 24 A Just like everybody else. I don't like that..
o
\
25 l Q Prior to your name being put at the end of f
.. , _ - . - - . . _ . .-,y , - - . . . . . . v . _ _ . . . . - - . - - _ . - , . , - . , . , , , - . - ~ _ _ , . . . , , . y
~
l 1
+
1 i
1 Ross 123 i-2 this document, did you review the document?
l 3 A I did.
i 4 Q At that time when you reviewe d it , was ;
5 it your understanding that this document accurately i
6 described the events of October 1977 at TMI-2?
- 7 A Yes.
- 8 Q Did you concur in the suggestion or i
- 9 conclusions contained in this document at the time ,
j- 10 you reviewed it?
11 A Yes.
12 (At this time, 12:50 p.m., a luncheon 13 recess was taken.)
i 14 15 1.
i 16 1.
- 17 18 f
19 i
20 l
.h 21 22 23 :
I 24 j= 25 l
i-l-
, - - , - - - _ - . , - ~ . - . _ . ~ - _ _ . , - . . . _ - _ _ . , - . _ - . . , _ - - _ . _ _ _ , , - - _ . - _ , . _ . ~ , _ _ _ . _ - -
1 y 124 2 AF T ERNOON S E S S I O N
=3 2:10 p.m.
4 M I CHAE L J. ROS S resumed 5 and testified further as follows:
6 EXAMINATION (continued) 7 BY MS. MCDONALD:
8 Q Before lunch, we were discussing B&W Exhibit 9 165, the document entitled " Water in the Instrument i
10 Air Lines.at the Condensate Polisher Control Panel and 11 Regeneration Skid Resulting in a Loss of Feedwater 12 Condition in Unit 2 on October 19, 1977."
i
() 13 Was this document sent t o tir . G. P. Miller
, 14 and Mr. J. L. Seelinger?
15 A Yes.
I 16 Q Was it also submitted by'Mr. Brummer to 17 Mr. Toole?
18 MR. MacDONALD: Are you asking if he 19 recalls?
20 MS. MCDONALD: Yes.
i j 21 MR. MacDONALD: He said he never saw it 22 before.
I I am asking whether you know whether the 4
23 Q i
24 memo was submitted to Mr. Toole.
25 A I don't know.
p , - , - - - - , - - . , , w ,,-y,,,v.+ - -,-,m-p4--ery,,,-, ,,vnva, 7, e ,,,7 w,,4, ~w -w-y- ,-rw-- --
,-+--ws -m , ws--, -
1 t
, 2 1 Ross 125 p
2 Q Did you have any conversations with Mr.
3 Toole regarding this incident prior to the accident?
4 A Prior to the accident, nothing that I 5 recollect.
6 Q Do you recollect that you had a conversation i
7 and you can't remember what was said, or you just do 1
8 not recollect at all?
i~
9 A I don't recall whether we did or didn't a
! 10 have conversations.
2 i
11 Q Do you recall any personnel that you i
12 discussed this incident with?
13 A The people that were involved with it and l 14 Mr. Seelinger.
15 Q Do you recall discussing this with Mr.
t 16 Seelinger?
17 A Yes.
1 18 Q Can you describe generally that conversation f
19 or series of conversations, whichever it was?
20 A Just the basic review of our findings.
21 Q- Can you remember anything Mr. Seelinger
! 22 .said?
- 23 A No.
! l 1
- 24 j Q Do you remember anything you.said?
O 25 A No.
t t'
_ .. . , , , _ , . , . - _ . _ . _ , . , . - , , - ~ . . . . . . . . . _ . . . , - , , _ , , . - - . . , . . _ _ - , . - . . . .., ...m.- -
& 4 e- _-
s t l' Ross 126
/
2 Q In the incident on October 19, 1977, am I
'b correct in thiriking that water was found in air lines 3
4 that were attached to the condensate polishers?
_, 5 A My recollection is there is water coming i.
. 6 out of some of the controls, that those controls would 7 be recording controls.
, 1 8 Q Did you at that time express an opinion, J
9 whether in this document or othe rwise , about how that 10 water could have come to be there?
11 A Not at that specific time. f,
/
12 Q Did there come a time later.when you i
13 expressed such an opinion? c 14 A We felt that we had to look a lot of places,
! 15 and we looked at all in te r e'a nne c tions , considered a 16 lot of ways it could have got th e re s. ,
?
i 17 Q Can you rbmember any of )theb po sible ways, rj 4- o 18 that you suggested it could have gotten there?
- ./
19 A It could have been through a c o n ne c ti'o n ,,
, s r.
. 20 through an existing system where we had an interface t
.g 21 between water and air. It could have been within the i
22 system itself and ehisted there. s This was kind of '
,l ,;I'* J 23 i our approach. <f i ,
I.
i ,
/ > ,
f
- it was 24 Q Did you ever,exp)ress an opinion that l 25 possible that the water, the sluiced
- water-in the i /
,' t l'
l -
l l l \: t l
.n ,e ;
l ,
, . - .-.... --, _.m._:- .
.-m.- - - . , , . - - J l. a , , fi .- - -- 1.-. . . -- . - - - - -
.T '
) %
1 ROSO '
127 ,
ID 2 condensate polishers had somehow boen forced back
\_)
3 through the abc line , through the check alves and, 4 therefore, into the instrument control area? Did you e 5 ever express that opinion?
s
~ '
6 A That was considered. '
7 Q You said that was considerad. Can you tell I \
8 me why that was considered at'the tigeY g 9 A We looked'at a' number of things and id'was '
s 10 one of the items we looked at.
11 Q How did you cose to think of that as a 12 possibility?
/~T 13 A We are trying to look at all possibi,11 ties V
' 14 with the end point of having water in the air. Wad,it s 1 15 in the air when we started? Was it in a cross connect?
X
' Was it in the system when we started.
16 We went from i
17 there. T'; s.
18 Q Confining ourselves to one of the many 19 possibilities you considered, namely,-that the water 20 ,
could have come from the sluiced water becking up into
,l g - 21 ' the air lines, how could that have happened as you 22 understood it back then? *
- y 4 . .
A 23 I am not sure today, but it,would be some ,
. 's .
(.
9
~4
- s. mechanism or failure in the check valve or some way in t
~'
i -
25 the interconnect" system. I am not really current on it.
'l
)3 t
5 1 Roco 128
(~' 2 Q As you understood it at that time, did the
(- ?*'
presence of water in the instrument air controls 3
4 4 disrupt the mechanism of the instrument air controls 5 in some way?
6 A We were never sure of the mechanism, how 7 that happened. We think it is a possibility. I am not 8 saying that water would disrupt the controls. We don't 9 know that to be a fact.
10 Q At that time did instrument air work by 11 having certain air pressure directed at certain 12 components of the system?
I s 13 6 A I don't understand the question.
O' 14 Q How did instrument air work?
Did you at 15 that time have any understanding at all of how 16 instrument air worked?
17 A Yes.
18 Q Can you explain it?
19 A Are you referring to instrument air as 3O related to the polishers or the system?
i 21 Q Generally.
22 A Generally, instrument air was a dried air 23 . source supplied to instruments and used in the
,.. V
, g4 ; positioning of. valves and/or instrumentation.
/ l .s
'(7,) 25 Q Do you know whether the condensate polisher l' i A- 1 3 l !
1 R000 129 2 outlet valves required a conctant source of air to
}
a 3
signal a change in position on those valves? By 4 constant source, I mean a source that would not be 5 disrupted by either foreign matter of any kind or water 6 getting into the lines.
7 A No, I don't recall.
8 Q At that time, would you have known that 9 back in 19777 10 MR. MacDONALD: You are asking did he know?
11 Q Did you know back in 1977 when you were 12 writing this memo?
rx 13 A I don't know whether I knew or not then.
t 11 Q Referring to page 2 of Exhibit B&W 165, you l
15 see on that page a list of certain items on that page?
16 A Yes.
17 Q Right above that list, the document reads, 18 "As a result of our findings, we feel that the following 19 should be acted upon to preclude a reoccurrence:
20 ! "1. Change / replace the dessicant condition 21 indicator on the instrument air driers."
22 Do you remember whether that suggestion 23 was ever carried out?
24 A My recollection is it was.
25 l Q What is the function of the dessicant
1 Roco '
() 2 condition indicator on the instrument air. driers? What 3 was it at that time?
i 4 A It tells you the condition of the drying or 5 filter arrangement in the instrument air drier.
6 Q What is the function of the instrument air 7 drier?
g A Remove moisture.
9 Q Do I understand correctly that it was 10 considered desirable not to have moisture in the 11 instrument air lines, therefore having the drier?
12 A That's correct.
( 13 Q No. 2, " Completely realign all air and l
14 4 water controls on the condensate polishing regeneration 15 system."
16 Do you know whether that was done?
17 A Yes, it was.
18 Q I refer you back to the first page of the 19 memo part of this document, the last paragraph, do you 20 see that, and specifically, "As directed, his people dismantled, inspected, cleaned and reassembled all lh 21 22 42 of the diaphragm-operated air valves on the 23 condensate polishing regeneration skid, since those 24 valves would provide an interface point in the event
) '
25 2 of a ruptured diaphragm. In addition, all instrument I
t
1 Roco 131 t
2 air lines have been blown down to insure that all 3 moisture has been removed from these lines."
4 I ask you whether No. 2 on the second page, !
5 whether the accomplishing of Ilo. 2 on the second page
!. 6 is what is being described in the first page. Do you 7 understand my question? '
8 A Yes.
9 No, I believe these are the follow-up
, 10 actions,that we felt we were doing this action separate 11 from the action on page 1.
. 12 Q What does No. 2 on the second page refer to?
13 A My recollection is that, also a manual 14 lineup, e verification that we didn't have,some source 15 that wasn't right, and also an instrument lineup lo setting the pressure controls, looking for a problem.
17 Q Do you recall whether anything was found 18 as a possible source of the problem when these valves 19 were realigned?
20 A To my knowledge, nothing was found.
No. 3, " Check out air control loop for valve g 21 Q 22 C-5 to insure proper operation."
23 What'is valve C-5 as.you recall it-at'that l
24 time?
25 A outlet control valve.
l l
t g o eme, m - m -,.v m-4 e e ,.m qm-- r- v w
. _. , .- - . - ~. . _- . . - . . - -. . _ _ ~ . - . - _ . . - . . .. _ __
1 Ross 132
() 2. Q What is it a valve for?
3 A Polisher outlet.
t l
I 4 Q No. 4, would you just review No. 4 and tell 5 me whether that was accomplished?
6 A To my knowledge, it was.
i i
j 7 Q Do you know whether the problem. report I-8 which is the first page of Exhibit 165 is the problem 1
9 report' referred to in No. 4 there?
- 10 A I don't know for a fact.
11 Q No. 5, " install drain trap on control
- 12 lines on condensate polisher discharge valves."- Was 1
l () 13 that ever done?
14 A I am not sure about that.
- 15 Q How about No. 6?
i A Was completed.
16 17 Q As you recall it then, that preventive l 18 ' maintenance program was instituted on a weekly basis
- 19. to take dew readings in the instrument air. system, is l.
i that correct?
20 L ,
21 A That is my recollection.-
4 22 'Q No. 7, "R'evise the operations' log to 23 , require blowing down the air compressors on each ;
i.
o4 - mid-shift and record the= amount of water in the~
I l
25 auxiliary operator's log. L[ganyabnormal.amountsof: -
1 I i e.
- ~
- -- 4& y ya q b-4g ( y - *w- p439sys >9 3y, eye _q ye w p m tv g--e-9 emWy g yp g 7 +-n y pas t-9W$w'Mw-
- 10 1 RoBD 133 l N moisture, indicating a leak."
2 3 Do you remember whether such a revision was 4 made?
5 A Yes, it was.
G Q Cah you explain No. 7 to me, what that 7 suggestion meant?
8 A That suggestion " blow down the inlet air g line," that actually feeds the condensate polisher i 10 control panel.
11 Q That was required then to be done each 12 mid-shift?
13 A Yes.
14 Q And if any water was found, that was to be 15 recorded in the auxiliary operator's log, is that 16 correct?
17 A Yes.
18 Q Between October 1977 and the Three Mile 19 Island accident, did you ever have occasion to review 20 the auxiliary operator's log?
21 MR. MacDONALD: For Unit 2?
l l
22 MS. MCDONALD: Yes.
23 A What are the dates again?
24 Q Between October 1977 and the accident.
O).
(s 25 l A I don't recall.
-e- , - - . -- , . , . - . - . = . , . _ . -
11 1 Roos 134
~
2 Q Just to go back, my questions have been
'b(~N 3
assuming that each one of these items re ferred to 4 Unit 2. Is that your understanding as well?
.h t
5 A Yes.
6 Q No. 8, " Review the operations log to require 7 blowing down the instrument air line that feeds the 8 condensate polishing control panel each mid-shift and 9 report any abnormal moisture levels in the auxiliary 10 operator's log indicating excessive condensation 11 problems."
12 Was that accomplished?
13 l A Yes.
3 v
14 Q Can you explain to me the difference 15 between No. 7 and No. 87 16 A Yes, No. 7 refers to blowing down-in the 17 area around the air compressor. No. 8 refers to blowing 18 down in the area around the polisher control panel.
19 Q As far as you know, No. 8 was accomplished?
20 A Yes.
21 Q No. 9, " Inspect the following check valves:"
22 SA-V360 and two check valves circled on Figure 1 which 23 .
follows this memo, is that correct? Do you remember 24 : whether check valves were inspected, whatever check C)
(_ 25 I
valves they might have been?
- - - ,m w- y ee --
9 <u--- m m+.- g-- P-
1 Roos 135 A Check valves were inspected.
(
2 3 Q was anything found as a result of that 4 inspection?
I 5 A To my knowledge, no.
6 Q After this October 1977 incident, wete all
~
7 of the air lines blown out and dried up so there was 8 no more water in them, as far as you knew?
9 A As far as I know, we didn't see a repeat 10 , of the problem.
I 11 Q That is not my question. I am asking, 12 after this incident,where water was found, was the 13 water somehow removed?
}
14 A I don't understand your question.
15 Q The water that was found in the air lines, 16 in the aftermath of the October 1977 incident, was that 17 water somehow removed from the system so it was no 1 18 longer in the air lines?
19 A Yes.
20 Q The air lines were cleaned out?
21 A Yes.
])
22 Q Did it ever come to your attention at any 23 time after. October 1977 that water was again found in 24 either the instrument or service air lines in or around l
25 the condensate polishers or their control panels?
l
1 , Ross 136 2 A No.
3 Q I show you a document which has been 4 marked as B&W Exhibit 166. Have you ever seen that 5 document before? The document is dated 5/15/78, 6 subject: Water in Service Air and Instrument Air.
7 Have you ever seen that document?
8 A No.
9 Q Does this document refresh your recollection 10 as to whether water was again found in the instrument 11 or service air lines around the condensate polishers?
12 A I have no knowledge of it.
() 13 Q This document does not refresh your 14 recollection in any way?
15 A No.
16 Q Whether or not you saw this document, did 17 anyone ever say to you prior to the Three Mile Island 18 accident that it is time to really do something on 19 this problem before a very serious accident occurs, 20 if the polishers take themselves off line at any jgg 21 high power level, the resultant damage could be very 22 significant?
23 .
A No.
24 Q Did anyone ever say or did you have any 25 discussions with anyone on that. topic,'even if those
14 1 Ro00 337 2 words were not used, prior to the Three Mile Island 3 accident?
4 A No.
5 .Q After the incident of October 1977, did 6 you ever have any further conversations regarding the 7 possibility of the installation of an automatic bypass 4
8 valve around the condensate polishers in Unit 27 i
9 A No.
10 Q I take it no such automatic bypass was 11 ever installed in Unit 2, is that correct?
12 A I don't know.
13 Q Does it exist there now?
14 A I am not sure.
15 Q I show you a document which has been marked 4
16 as B&W Exhibit 167 and ask you if you have ever seen 17 that document before.
18 A No.
19 Q Does anything in that document refresh your 20 recollection regarding any conversations you may have l
21 had about an automatic bypass valve being installed 22 in Unit 2 or with regard to water again being found 23 ! in instrument or service air lines?
l 24 i A No.
l A ;
k~ 25 l Q For the record, this document is dated May r
- - . , . . , , . . - , - . - , - ___m . . , . - . _ , - - -, .-y.,. ,- ,,-.,m, , , , . ,,~..w-, . -c.-~ .
15 1 Roso 138
.O) 2 16, 1978, subject: Water in IA.
3 After the document which is Exhibit 165 was 4 written with your participation, was it your 5 understanding that the problem was solved, or did 6 there come a time when you thought that the problem was 7 taken care of?
8 A When we wrote this, we really didn't find 9 a cause for this. We didn't find any repeatable thing 10 that would tell us that there was a trend or anything 11 like that. Shortly thereafter, I left the unit. I i
12 l have no knowledge.
13 Q So at the time you left the unit, there f"J)
\_
14 had been no conclusion as to why this incident 15 involving the shutting of the condensate polisher 16 valves and loss of main feedwater had occurred?
17 A To my mind, we had not reached a firm 18 conclusion.
19 Q Had you reached a conclusion that wasn't 20 firm, a tentative conclusion?
21 A No. I think we still didn't have the cause.
l 22 Q Did anyone ever come and tell you prior to 23 ! the Three Mile Island accident that someone had o4 ! determined what the cause was?
I l
~
25 A No.
l '
- 1. Ross 139
+ ~
2 Q Do you have an opinion today on what the 3 cause was?
4 4 A No.
5 MR. MacDONALD: I will instruct him not to 6 answer.
7 MS. MCDONALD: I think we have an answer.
8 Q Did you ever have any further conversations 9 as to why it might have happened that the bypass valve 10 could not be opened from the control room by the 11 operator?
12 A No.
13 Q Did anyone report to you or tell you that 14 any conclusion had been reached regarding that problem?
15 A No.
t 16 Q on the first page of 165,which I really only 17 refer you to in case it refreshes your recollection, 18 it says down at the bottom, "No further action required 19 by this problem report. If when the plant is restored go the p roblem is better' defined, we will resolve this l
21 problem."
22 Does that refresh your recollection as to j 23 whether anything further was done after the plant was 24 restored?
V- 25 A No.
l l
- 1 Ross 140 l l 2 Q Do you know Mr. Zewe? l f
! 3 A Yes.
1 '
l 4 Q Do you regard him as capable? Did you 4
i 5 before the accident?
6 MR. MacDONALD: Let's lay a foundation for i
- I i
7 that. An evaluation by somebody who may have I
1
] 8 had no contact with Mr. Zewe is not permissible. :
i y
i j g Q You knew Mr. Zewe, is that correct? ,
f 10 ! A Yes. ;
I i i 11 ! Q Did you ever work with him? ;
12 A Yes.
f' ,
1 13 Q Did you ever have occasion to think that '
f 14 g, his work was less than satisfactory when you were i'
j 15 working with him? !
i 16 A No.
f 17 'j . Q Did it ever come to your attention that. ,
i l' J .
.l j
4 18 ! sometime in November of 1978 the condensate polisher i
I~
19 I outlet valves had once again closed, causing a loss
- i. 1
! i
! 20 i' of feidwater transient?
?
t-
- 21 A Yes.
22 'Q What do you remember about that incident?
- i. 23 A Just that it was caused by loss of power.
j- ' '
24' , Q . Was there an electrical problem?
i A Yes.
.f. . 25 l
i'
.- - . ... . - . . ._. _ _ . . . ~ _ . - . . . - . . . _ _ _ _ - . . _ _ _ . - _ _ . . _ _ . _ . _ _ . _ .
J Y
18 i Ross 141 l
i
()' 2 Q Do you recall generally what that electrical I
problem was?
3 f l l 4 A A breaker was inadvertently opened. -
'5 j Q Did the reactor trip during that incident?
6 A My recollection is yes.
l 7 Q Did it ever come to your attention that 8 there was a loss of a condensate booster pump, causing
, 9 ,
a reactor trip on September 20, 19787 l
i
' A 10 , No. l l l l
11 ii Q You mentioned earlier on today when I asked ,
I i
12 ! you about possible design or changes of some sort i i between condensate polishing system as it was originally f( 13 P .
14 ;! built and then the time of the accident, and you ii .
15 ll mentioned something to do with a change in procedure l
16 for sluiced water; do you recall talking about that
, 17 j before?
' t 18 I A Yes.
19 ,
Q I would like to know whether you recall.
1 20 l any other changes to the condensate polishing system other than what you previously testified about between '
21 jgg 22 when they were installed and the accident. l i
1 23 : A No.
I i
. 3 l y Q Did there come a time at TMI-2 when the
{
l 25 power level of the plant was increased from what it had ;!
i- ~
I .
ru l
L ;
L
19 1 Ross 142 2 originally been? I may not be using the right words, 3 but I think you probably know what I mean. Do you 4 understand the question?
5 A No.
l 6 Q Did there come a time that the power level, 7 the megawatt level of TMI-2 was increased from what it i
8 had originally been designed to handle?
9 A Not that I am aware of.
10 Q Did you review the FSAR regarding any 11 . method by which the condensate polishers would be 12 bypassed? Did you review the condensate polisher
" ll :
13 part of the FSAR at any time? !
14 i; A Not that I recall.
15 Q So you don't know whether it was stated I
l .
16 I in the FSAR that there would be a method of bypassing ,
r 17 the condensate polishers? !'
li 4
18 A No, I do not.
6 19 Q Have you had any discussions with anyone? !
4
!I Have you heard from anyone that the question of whether 20 ;
- l. there would be an automatic bypass valve installed in '
21
.D
- 22 Unit 2 was discussed with the Plant Operating Review
+
Il 23 Committee?
24 i A No.
P 3
-t N ') 25 i Q Do you know whether the P O'RC reviewed i.
I I
l
, . . .- , . , ,...m m..
0 1 Ross 143 2l that qu,estion?
I' 3
A No, I do not.
4 Q Have you ever told anyone that it was your ;
)h 5 view that the PORC turned down the idea of the bypass
, 6 because it was too expensive?
i 7 A Not that I recall. g i
Q Did you ever have occasion to review the !
8 l
9l shift test engineer's logs for Unit 2 at any time?
A No.
10 l I
, 11 Q I show you what has been marked, or part '
I i
12 j of what has been marked as B&W Exhibit 176, and the i 1
~J
) 13 : j i
portion I am going to show you runs from pages WO6519 ,
14 !! through 06521, and I have just one question on that.
i.
11 15 a! MR. MacDONALD: Can we have some I
i 16 identification where this came from?
17 MS. MCDONALD: This was a portion of a ,
18 i document which has previously been identified as l i
19 Unit 2 shift test engineer's log, and it was !
20 . marked at Mr. Toole's deposition. ,
' i 21 .g Did you know what shift test engineer's j
, a 22 logs were? Did you know they existed?
- 23 A. Yes.
i 24 Q Did you know what the function was prior I
25 , to the accident? :
t i ;
1 i
i I L
,- < . - , . . , - . . , , . , - , - - . . . .- , , . , - . , , ,.v.. . ,
21 1 ,, Roco 144 l
- 2 A No.
3 Q Referring to the last, the entry beginning 4 at page WO6519 and continuing over onto the next page,
, 5 page 06520, I would like you to read that entry, and 6 I ask you if it re f re s ha s your recollection in any way 7 regarding the presence again of water in the instrument ,
8 or service air systems of the condensate polishing g system on May 12, 1978.
10 g Just so you know what I am talking about, 11 "Due to operator error, water entered service and 12 instrument air systems via cond. polisher fluffing air i
I
(} 13 il line. Polisher outlet valves went shut on loss of 14 j, air and tripped cond. and cond. booster pumps. Blew i
15 air systems down to remove water."
16 Does that refresh your recollection in any 17 way about an incident occurring on May 12, 1978?
i 18 A No. j i
19 ,
Q Did it ever come to your attention that ,
20 water had been found in the air lines around the :
i 21 condensate polishers during the accident of March 28, g .
22 19797 23 A No. l i
24 , Q .To this day, you never heard th at before? l
[)
v i
u i
- 25. r .A No. l l
6
\'
l
~. _ . . _ . . . _ _ . _ _ _ . . _ _ _ _ ._. - __ _ _ . . _ _ _ _ . . .. .
2 2 '. 'l Roos 145 t
2 Q To this day, have you heard from anyone of 3
any problem concerning the condensate polishers which I 4 might have occurred on March 28, 19797 h 5 A I have heard the problem started or an 4
'6 initiating event was triggered or revolved around the
)1 . 7 polishers, yes.
8 Q What happened to the polishers? The valves g closed?
10 A Something happened that the flow was lost l ,
2 !
s 11 through the polishers.
i 12 !' Q You never had any discussions with anyone concerning how that might have happened?
13
< l
',14 A No.
15 Q Since the Three Mile Island accident, have
. 1
[ 16 you been involved in any postaccident reviews of what j
) 17 might have happened to the polishers during the accident, I
18 . either within GPU or Met Ed or as a result of questions 19 by outside groups?
i
,1 -
20 i A No.
f 21 Q Did you provide.any information t,o a person 22 named M. A. Kopeka regarding the condensate polishing
! l' 23 system at TMI-2?
t 24 A Not that I' recall. l1
. (~) l
.(_/ 25 ;< Q Have you ever seen a report written by that l .
L i.
I !
l L 1 Ross 146 3
l l
l 2 gentleman regarding inspection of the condensate p lishing system at Three Mile Island No. 2? That i 3 l 4 was a report written after the accident.
5 A Not that I recall.
6 Q Did it ever come to your attention that I
7 anyone suggested that the condensate polishers had been i I
8 improperly wired at TMI-27 l
9 A No. I 10 Q Do you know whether pursuant to the design I
11 as it was originally intended at TMI-2, the solenoids
. i 12 on the condensate polisher valves were supposed to l 13 ,;
maintain the position of the valves upon a loss of a
O. f air or electrical power?
14 li In other words, that they l'
15 were to fail as is?
I 16 A No, I don't. !
17 Q It was always your understanding that upon 18 a loss of air or electrical power, they would fail 19 close, is that correct? !
t I
20
), A Yes.
i ,
Based on your experience at both TMI-2 '
21 Q 22 and TMI-1, is it easier to operate TMI-1 or TMI-2, or H i
I 23' are they the.same, or is it easier to operate TMI-27 a
24 MR. MacDONALD: I object to the form of ,
25 i the question. You are asking him for his present
- i I ;
I I i
i 1 Roos 147 L
t I
sense or present opinion as ,he sits here today?
( 2 f
I It is not a permissible question.
3i l
4 Q Have you ever had an opinion on that 5 subject of which was easier to operate or whether there 6 was a difference? i i
7 MR. MacDONALD: Again, unless it was l 1,
8l ,
conveyed as a writing or vocalized in some sense. ,
I 9l Q Prior to the accident at Three Mile Island, ;
b I 10 did you express an opinion or have any discussions of f
11 ! whether it was. easier to operate one unit or the other 12 l in terms of the condensate polishing systems?
I 13 A No. ,
BY MS. WAGNER:
14 li 15 l1' Q I believe you testified'previously that i
16 you were in the control room at TMI-2 at some point i
17 on the day of March 28, 1979. I would like to ask 18 ; you, when you arrived in the. control room, do you I
19 : remembe r what you saw in the control room, what the
,i 20 plant parameters were? Specifically, my first question 1
21- is, do you recall what roughly the pressure of the g
1 22 primary system was?
i 23 MR. MacDONALD: Are you asking him whether 24 he looked at that?
25 !
Q Did you --
! i
, t
+ -
4 : .- , . - , . -
- . , . - - - , - - - , ,-~,e r- - ~sw e a w ---m-+ ~
'5 1 Ross 148 2 MR. MacDONALD: That is assuming he walked !
3 in and looked.
4 Q When you walked in, did you have any 5 knowledge of what plant pressure was, a minute or two l i 6 after you walked in? I 1 i
- 7 A Not in that short time period.
l !
8 Q How soon after you walked in did you get I
gj some idea what primary pressure was?
i 10 A It was a period of minutes.
l 11 l Q Do you remember what in that period of time l
. 12 was your first information about what the pressure of I
i g-- 13 the primary system was? ;
\ i 14 A Somebody said what it was. I didn't see it.
15 Q What was said to you?
16 A My recollection is that the pressure was 17 13 or 14 hundred pounds. l 18 i Q Do you recall who said that?
f 19 I A No. !
- l. t i
20 - Q It was somebody in the control room?
21 A Yes. 1 Jgg 22 Q Did you receive any information, either i
i 23 I by seeing it or having someone tell you, as to what the
- 1. .
24 ; pressure level was? -
[~h- [ l
\s 25 I. A Yes.
I . ,
I .
l l
26 1 Ross 149 1
2 Q What was it?
3 A off scale high.
4 Q Did you receive any information, again 5 within the few minutes after you walked in, as to what 6 I was going on in the source range monitors, if anything? l i
7 A I don't know if it was a few minutes. I 8 had some input on the source range monitors increasing.
i I
9 j Q As best you can recall, was it a large ;
i !
10 ! increase? ! l l !
i I
11 A No quantitative number put on it. ;
l
- i 12 Increasing. I Did it concern you?
O Q 13 A Yes. i 14 t
15 Q so it was a large enough increase that it ,
l 16 did cause you some concern at least? l 17 A It shouldn't have been increasing. '
I '
18 Q Do you remember, again in the time period i
19 shortly after you walked in, what was the status of ;
I ll 20 l' the reactor coolant pumps?
21 A Not exactly, i g
22 Q Is it correct that they were turned off, 23 ! the last two pumps to be on were turned off sometime 24 ,
roughly about when you came in? ',
O l 25 ; A My recollection is they were off when I e - ,, . -
7 1 Ross 150 i
. i
(~ 2l got there. j
\_)/ \
3 Q Do you remember when you got there if you 4
noticed,-again within the first few minutes, what HPI 4l lh 5 was doing, whether it was on or off?
6 A No, I made an inquiry sometime thereafter.
I 7 Q Of whom did you inquire? j i
8 A I think I asked the shift supervisor. ,
9 - Q Was that Bill Zewe?
10 A Yes.
l I '
11 i Q What did he tell you?
12 i A I just stated when the source range counts ,
i 13 ! were reported as increased, "Are you injecting and is 14 i; HPI on" and his answer was "Yes."
t .
15 Q When you say "Are you injecting and is HPI !
I i
16 on," what is the difference between injecting and HPI?
17 - A My injection reference was to emergency 18 t boration. 8 i
l Did you have any knowledge, either because 19 i Q ;
I , l 20 he told you or because you looked at indicators 21 yourself, as to the amount of flow of HPI? Was it on no
-- full? i
! i
~
23 .
A I am not sure.
i' i
24 Q Do you recall giving some testimony on- ;'
i
-(
\
25 ! April 25, 1979 to the I&E of the Nuclear Regulatory i I
i 1 I
28 1 Roco 151
/"'i 2 Commission?
k_/.
. 3 A I am not sure of the date. I remember 4 talking to them.
}
5 Q I show you a copy of what I believe to be 6 your testimony, and I will be specifically referring !
i 7 to pages 5 and 6, but you are welcome to review as j i
8 much of it as you wish. l 9 I am going to refer you to two questions I
10 and two answers, beginning in the middle of page 5, a i 11 I question by someone called Hunter, "Any particular :
12 thing you looked at at that time," and ending on the I
l '
^s 13 l next page with a response attributed to Ross, saying, (V
1 I
14 , "Yes, the pumps was off."
15 My question is simply, were you asked ;.
I 16 those questions and did you give those answers? ,
i i
17 A I don't recall the specific question today. l i
18 I Q Whether you recollect the specific question, 19 ,
do you believe, based on the fact that you testified I!
20 '! .
you did give some testimony to the I&E, that this is I
21 a transcript of the testimony?
gg l l
22 A I believe that is a transcript of that.
i 23 '
Q Do you have any reason to believe that it 21 is inaccurate in any respect, at least with respect ;
(.- 25 i to these two questions and answers?
i
.I :
9 1 Ross .152 2 A No.
t I
3 I Q I would like to ask you now a couple of l
4 questions about one of the notebooks you produced for 5 us today.
6 Is it correct that this binder, entitled i
7 " Nuclear Instrumentation," is a document which you 8 delivered to us here today, a book? 3 e i 9 ' A Yes. i l
10 .
Q Can you tell us what it is? i 11 ' A It is training material. g 12 Q Maintained by you?
- i 13 j A Yes.
14 j' Q I take it this was something that was in ti 15 ' '
your personal files. It is not some departmental !
16 document?
17 gl A It came out of my office, but it was kind 18 ! of a personal book.
19 MS. WAGNER: Let's have deemed marked as i
20 !! B&W 301 this binder entitled " Nuclear k
21 !
.g ' Instrumentation" provided by Mr. Ross today.
22 Q I just have two questions on this. The 23 first one relates to the document appearing after the
^
24' ! tab called "ICS" and the question is, do you recall
- 25 when'you received that document?
I I i i f e
30 1 Ross 153
( 2 (Binder entitled " Nuclear Instrumentation" 3 was deemed marked B&W Exhibit 301 for 4 identification, as of this date.)
5 A I don't recallLthe exact date.
6 Q Do you recall whether it was before or r
7 after March 28, 1979?
8 A My recollection is it was after.
9 Q You don't believe you ever saw that before? !
l 10 MR. MacDONALD: He just guve you his 11 recollection.
12 A No. .
1
( _
13 Q The document is entitled " Babcock & Wilcox 14 l; Videotape Training Manual," and I believe it indicates ,
t 15 that it is part of a videotape course.
l l
16 Do you recall ever seeing a videotape l
- 17 related to this particular training -- this particular ;
! document? '
18 19 i A No. I
[ 20 Q I would like to refer you to the second tab Jgg 21 which is I think entitled " Heat Transfer," and my F i
l 22 question is, when did you first receive that document, '
23 if you recall?
l-
- _ 24 A I can't recall theLexact date. l QJ: r i
25 ! Q Can you recall whether it was before.or after-l .
l l l s l' l
[
.i i
3 1 Ross. '
154
} l 2 March 28, 19797 l 3 A My recollection is, after.
,- 4 Q Do you have documents, manuals, binders, 5 ,
similar to these which contain information that you i
6 had before the accident, aside from the ene that you i
~
l 7 produced to us today which is entitled Horse Book"? ,
! 8 A I have binders, yes. i
)
9l Q The horse book that you produced to us, l l' $
10 , without reviewing it at the moment, do you know whether i i
l I 11 it contained information from before March -- i 12 inf'rmation o that you received prior to March 28, 1979?
5 '
13 (- A I am not sure.
0 14 Q What is a horse book?
. ,I 15 ti A It is a book of, summarized training 1
16 , material. >
i
- r .-
17 y'J Q Who summarized it? l q
a 18 e A I am not sure who. I am sure it is work l
- i .
1 l
from a lot of people in there.
19 ll i
! / ii Do you know if they were people at 20 !l- Q 21 1 7 Metropolitan Edison?
'~
, 22 MR. MacDONALD: ' Exclusively? '
, :( .n
, , l; s
23 MS. WAGNER: Yes. ,
i
~
24
,A .I am sure it is a combination of' work'in O.L J~
j 25-there.
\_ /:
l s l - i
.} -l 9
l- . a .. _ !'j '
}. .y '
, T ':
. _ - ,,,_.r..,, . , _ . , - . . - + - , -
. _ _ _ ' r. h '
4 2 1 Ross' 155 s I
^
Q Why is it called the horse book?
- 2l ;
3 l A It is a quick re fe re nce study book for
! x 4 exams. ,
s ,
5 Q What does that have to do with horses? Do i
6 you have any information, other than custom or '
'l 7 something?
j! :
81 A Custom. l 9 Q How were operators selected to be operators
^
l 10 ; at TMI-2 prior to March 28, 1979? '
l A They were selected a number of ways. There 1
11 f '
i a
was a posting process based on qualifications and time 12 ll ll ~
13 ~or seniority for a man to become eligible for the 14 -program. There were other criteria. There is a mode 15- of progression basically to become a control room I' i i
/ t 16 operator. That mode starts as an auxiliary operator 4
l 17 in which he has prescribed training and a prescribed ;
18 time to be in the unit and his ability to bid on a i
19 control room. operator job. , '
20 Q Will anyone who. bids after following the g 21 ? mode of progression automatically become a control ,
22 room. operator, 'or are.;there other qualifications besides 23' going through the auxiliary Eperator program? ,
24 ' .A He wouldn't. automatically. One-is t.
)
E (/ !. .
25 i completion of the. auxiliary ,o;ierator program.
Onesis 4- ,
Tk Y
s g
y
)
13 1 Ro0D 156 I ) 2 background 1.n physic; and proper attitude and desire b i 3
to become an operator. There are a number of criteria.
l 4 Q Can you remember any of the other ones 5 specifically?
! A No.
6 I
7 Q Who was involved in hiring the auxiliary !
< l 8 operators? Who was prior to March 28, 19797 1
1
' I 9 MR. MacDONALD: By department or job 10 function?
11 MS. WAGNER: Job function.
12 . A The Supervisor of Operations.
I i
(%
13 (g Q Would he also be the person who hires l 14 , operators other than through the auxiliary program?
? \'
15 I should preface that by asking, are i
16 operators ever hired other than as the lowliest !
t 17 ' auxiliary operator and then working up through the ,
18 , ranks?
'19, A Yes. i
- x i 20 l Q You take operators sometimes from other i
'g i !
)
,l 21 I plants? l x , 22 ., A Yes. l I
ns
. l .
sa- 23 l '
At that time period, would~the same person
~ Q .
j ; <
l 24 .be involved in hiring? !
l
- 25 T A Yes.
\
.f b. _ ___ , _ _ , - , . . - _ , _ . - . . . . _ - , _ . . . _ . . . . . . . _._._;...- _ . _ , . _ , _ . _ . _ .
l 4 i Roso 157 l l
O
. ,O 2 Q Were there any minimum educational 5
3 qualifications before March 28, 1979 to be.a control 4 room operator?
3 3 A Yes.
6 Q Do you recall what they were?
7 A High school graduate, strong background in .
8 math and physics, a background in nuclear theory. i l'
i 9
' Q Would Metropolitan Edison administer some I i 10 kind of entry test to test the person's background I, 11 in mathematics or physics? l 12 A Yes, there was an entry-level exam. ,'
13 Q Would that same exam be administered to 14 someone who had Navy nuclear training?
i 15 ) A No.
l l 16 Q What were the qualifications which would 17 g be applied to those people, people who had become 18 operators in the nuclear Navy? ,
!r !
19 A They would have to exceed'the qualifications P
')0 [ of an auxiliary operator who had been there two and a l .
21 l half years, so each qualification was different. '
22 Q Were they administered some kind of 23 entry-level test also?
o.4 , A No. !
95 i Q Were their Navy records reviewed?
I f i
i
_ ~ . - . , . . . ,- . . - .- . - . - . . . . . - . , - , . - .
35 1 Ross 158
() 2 A I don't know.
3 Q To the best of your knowledge, prior to 4 March 28, 1979, were operators of TMI-2 ever asked by 5 anyone at Met Ed to go into the control room and make 6 suggestions on how the control room should be set up, l 4
l what instruments should be where, that sort of thing? !
I i
8 A No. .
4 9 Q As I understand the control room at TMI-2, l
10 it is quite a large place. Were operators taught !
I' 11 how to, in looking at this entire array of information 12 !! that was presented to them, how to scan for the most -
i important information? Was that ever part of their
( 13 14 training?
15 A I don't think it was a separate course, i
16 but the route in becoming an operator normally makes 17 , you make that distinction as you go through your
- I 18 training to where you pick out what is important.
19 l Q Just by being in the plant? ,
20 '! A Yes.
t i
,j g 21 Q Were operators taught at some point in lt 22 their training program what type of information was ;
li 23 available in the control room on a historical basis, as l l 24 opposed to merely a contemporaneous basis?
n]' '
25 A I don't know what you mean. '
I l
. !. j i
l
-1 Roos 159
~
2 Q Is it correct that there is some 3 -
instrumentation in the control room which,1f you ask 4 it, will give you some period of information of what h 5 has happened to that instrument in the past 30 minutes, 6 as opposed to other ones which simply tell you what ,
7 it 13 doing right this second? Is it correct there are 8 two types of instruments?
9 A Yes.
10 i Q Were operators taught which kind of 11 instruments would tell them what happened in the past .
12 X period of time, as opposed to which ones would tell
() 13 you what is only going on right now?
14 i! A No, there was no formal course either at i
15 i TMI or B&W simulator to do.that. .
I 16 l Q What type of information would be available I i 17 I on the utility printer, if you recall? l i
18 A Kind of a demand information. You have to 19 ask for something. ,
,1 Q Could you ask for any old thing or were 20 'l ,
21 you taught there were certain things it could tell you j
22 and certain things it couldn't?
i 23 A You have to ask for what~you wanted. 4 34 'Q Do you know now whether the TMI-2 utility ,
I
( ,
printer would give you~information on the temperature 25 !
i l
I l
, ,._ - _ .,c , - - - - - - -
_ . _ . m .
1 Ross 160
~
l ) 2 . of the ' thermocouple s , on the tailpipe,;eading from
- 3. the PORV?
4 4 A Yes.
5 Q It would give you that information?
6 A Yes.
7 Q Do you recall whether or not operators were .
8 taught that the utility printer would-give you that l
9 ll information if you asked for it?
10 i A There again,'they were taught there was a ,
! l 11 computer. They weren't taught a specific point was used
[
12 ! for this or tied in in conjunction with that. They
+
l .
[~ 13 II were taught it is there; to get it, you do this. l N
{
14 j; Q Do you know if the' pressure of the reactor b
15 'l coolant drain tank was available from the utility ,
i l 16 printer at TMI-27 ;
17 A No, I don't.
18 ! Q Was there a device. called the sequence ,
I 4
, 19 of events review? .
h 20 1 A Yes.
l 1
21 !
Q What'information would that give you?
,jg[
22 A It would give you the sequence and timing i 23 of significant-input events.
i 24 Q Would you have to ask it for a specific O-
\/
25 thing, or would'you just push a button and it would
- i
, , , , , - - .y-------r - - - - - - - - - , , - , . , , , , - , -
, , . - --w,
9 1 Ross 161 2 give you what it thought was important?
$ r 3
A Y u have to ask for the sequence of events, 4 and there was a prescribed amount of material that was 1h 5 already in that.
6 Q Was there a device called the operator .
l 7 group trend recorder, to the best of your recollection? j 8 A Yes.
9 Q What would that tell you?
10 A It would allow you to trend certain inputs. ;
l 11 Q For that one, were you able to select what l I
t 12 dnput you wanted trended?
() 13 I
A Yes.
14 'j Q Do you remember if that would tell you, I i 15 that would trend for you the tailpipe temperatures on
- 16 the the rmo coup.l s s leading from the -- thermocouple .
17 temperatures on the tailpipe leading from the PORV?
18 A No, I don't. !
i 19 Q Was there any method, to the best of your ,
20 .
recollection, by which you could find out whether or I
i jg '21 not HPI had actuated manually or automatically? !
22 A No. ;
l 23 i
Q You don't recall or there was no such
'- l 24 ,
method? l Cg) $ .
25 l A I don't recall. .
i 4 I I
! i
1 Ross 162 i
Do you recall that the sequence of events
( 2 Q 3
review w uld tell you that? l 4 A I don't recall. l Il h 5 Q Do you recall a device called the memory i
6 trip review? ;
7 A No.
8 Q Do you recall whether or not you could get 9 trend information concerning HPI actuation from the 10 Operator trend recorder?
11 A I don't recall. :
! 12 Q Do you recall whether the operator. trend
! l
\ recorder would tell you whether or not HPI had actuated
("/
s_
13 j
i 14 automatically or manually?
I lli 15 A I don't recall that.
i !
16 l Q Does TMI-1 have such an operator trend I
I '
17 recorder?
18 A Yes.
19 Q Do you know today whether it will tell you 20 il in the present TMI-1 control room' whether HPI actuates 21 automatically or manually?
-9 22 A No.
23 Q Who could I ask at'TMI-1 today who could 24 tell me whether the group trend recorder will tell me ,
25 l whether HPI actuates automatically or manually?
l I
l 1 ) 1 Ross 163
) _2 l A The computer programming people would have 3 that information.
4 Q Are the operators being given training 5 today on that subject, the TMI-1 operators?
6 A Not that specific subject.
7 Q Was there in TMI-2 a device called the
, t-
, 8 operator's special summary?
I I 9l A I don't-recall.
10 Q Is there such a device'in the TMI-1 control j 11 room today?
12 l A Not that I am aware-of.
13 f Do you recall whether or'not~ prior to
( Q 14 March of 1979 in any trending at-all it was indicated i i
, 15 to you'that there were times when it was important to 16 get historical information and not only current ,
1 17 information? By " historical," I mean the past 30 !
- 18 minutes, as opposed to this instant, 'with respect to .
l .
I 19 conditions in the system. t 20 A 'o, N we really had previous to this no use l i 21 for that type of information, nor did we stress it in jg j 22 our training or when we trained on the simulator.
- I 23 Q Do you recall in 1978, toward the end of
, i 24 ! '78, there was a change in shifts at TMI, when it went
' I l 25 I from'six sh'fts i to five? l l
1 1
1 r - - - ,.- . .._.-. -.-_
$1 1 Ross 164 We were in five shifts sometimes in 1978.
.( 2 A
3 Q Is it correct, while you were on six 4 shifts, the sixth shift would be devoted to training, 5_ the week of training?
6 A Yes. , j i
7 Q When you went from six shifts to five, is !
i 8 it correct that the fifth week would then be partly :
I i
9 training and partly-doing whatever was needed in the 10 , plant? j
! I 11 A Yes, the majority being training, though.
12 l Q Did you ever express any concern that ,
13 there was not enough time for training after this 14 : shift change to five shifts? q
- 15 A Yes, we were concerned about being in 16 five shifts. We did get our training. We felt that 17 the six shifts was a better organized training, 18 long-term training. ,
19 Q Did you ever express any concern about it 20 to anybody?'
21 A Yes.
g 22 l- Q- To whom did you express such concern?
i i
23- l 'A My director supervisors. ,
i 24 'Q Who was~ th at in'this time period?.
- I'T ,
V 25 l A Probably O'Hanlon.
. -t d
I 1 'I i
. _ _ _ _ . . _. _... . ...__m . - _ _ -
l l
1 Ross 165
() 2 Q When did O'Hanlon leave Metropolitan 3 Edison? Do you recall? !
4 A No, not exactly.
5 MS. WAGNER: I would like to have marked I
6 as B&W Exhibit 302 a two page document, the first l page a memo from someone whose last name is 7
8 Lawyer, subject: Training Requal for Attendance, .
I 9 dated September 19, 1978. The second page is t
10 j a memo from M. J. Ross to G. P. Miller, and it i
11 is undated.
12 (Two page document, first page a memo from I'l 13 i
( 4 L. L. Lawyer, subject: Training Requal for 14 i- .
Attendance, dated September 19, 1978, the second 15 ky page an undated memo from M. J. Ross to G. P.
16 Miller, marked B&W Exhibit 302 for !
17 ; identification, as of this date.)
. :I l
18 Q My question will be whether you ever saw ll ,
a 1
19 lh the second page of that document be fore . Have you ever i
20 l seen the second page of that Exhibit 302 before?
t gg 21 A I don't remember it, but I wrote it.
I 22 Q The first two sentences of the document 23 say, "I firmly feel the only way I can make a firm 94 training commitment is to be on six shifts. At that s
)
25 i time I will and can enforce scheduled training."
l -
1 Ross 166 !
l 2- Do you recall whether this memo reflected 3
some concern with a lack of training?
4 A This memo reflected a concern of lack of 5 l training attendance. People were not making the I
j I 6 scheduled training due to taking vacations, try to tie ;
7 the end of their training week together with a four-day a i 8 holiday.
9 My comment there is to say if I were on !
10 . six shifts, I would have no qualms about cancelling ,
I l ll 11 vacations to insure that they made their training as l ,
1 12 l scheduled.
() 13 Q The memo also appears to indicate that you 14 [ believed, and correct me if I am wrong, that cancelling ,_
ij - 1 15 l' vacations would be a grievable union problem. Is that I 16 ;
what this memo indicates? ,
IB 17 ,8 MR. MacDONALD: You are asking for his
!! l ii" 18 recollection? l l
19 MS. WAGNER: What his recollection is.
20 ! A My recollection is, I felt they would ,
i-21 grieve it, but I also felt we would win it, which meant
,gg i 22 'it wasn't a union problem.
23 Q Did there come a time when TMI was put I !'
back on six shifts?
(g) gn 24 i
- 25 ! A Yes, January 1979. .
I l i !
i .
1 Ross 167
( 2j Q Do you recall after submitting this 3
memorandum to Mr. Miller, seeing the memorandum which 4 is the first page of Exhibit 302?
5 A No.
i 6 Q The document indicates that you were copied 7 on it which is why I asked. j i
A Yes.
8 ll j i
9 Q Do you recall after writing the memo which !
l l
! i 10 ,
is the second page of the-exhibit, any discussions l 11 with Mr. Miller concerning your assessment as to .
12 whether or not requalification training would climb to !
() 13
?:
an appropriate attendance range?
14 l- A No, I don;'t.
h i
15 l MS. WAGNER: I would like to have marked i
16 as B&W Exhibit 303 a one-page document entitled i.
17 ! " Unit I/II Requal Program Attendance," written ,
18 by Don Goodman and addressed to a number of ,
19 I people, including Mr. Ross. l i
20 -' (one page document dated June 21, 1978, ,
i entitled " Unit I/II Requal Program Attendance,"
gg 21 l 22 written by Don Goodman and addressed to a number 23 of people, including Mr. Ross, was marked B&W
- 24 ,
Exhibit 303'for identification, as of this date.) l 25 , Q Do you recall ever seeing this memorandum
.i l
1 Ross. - 168 l l
() 2 r
before? '
l A No.
3l ,
4 I i t 4 Q . Do you recall ever hearing at some time !
l 5 in 1978 that overall requalification training l l
6 attendance was 44 percent for licensed personnel?
I 7 ,
A I don't recall the number.
8l Q Do you recall hearing that attendance was l
9 quite low? ,
t 10 , A It was less than desirable, yes. .
l t
, 11 MS. WAGNER: I would like to have marked i
4 12 l as B&W Exhibit 304 a one page document entitled t.
f'/
N.
T 13 N ll
" Unit I/II Requal Program Attendance" written '
i 14 p by M. L. Beers, dated September 1, 1978, and i '
l! .
15 I again addressed to a number of people, including '
i l
16 Mr. Ross.
17 (One-page document entitled " Unit I/II 18 d Requal Program Attendance" written by M. L.
l 19 l Beers, dated September 1, 1978, addressed to a i'
00 number of people, including Mr. Ross, was marked 4
g 21 B&W Exhibit 304 for identification, as of this 22 date.)
23 Q Have you ever seen this before?
I 24 A I don't recall it.
' -( -
25 , Q Do you recall that there was a continuing I'
t 4
%- -- s , .e4 -,w,ev.- -.--*r,*- - * - - - Ae-- *-*-1 ~ de- "W9'"*e- -m - - - - * ' - +- rme v
l 1 Ross 169
( 2 concern la 1978 by you and perhaps others concerning i
3 the training attendance in the requal program?
4 A Yes, I did.
5 g copies of this memorandum were sent to ;
I 6 lots of people. One of them, listed way down at the i
.7 bottom, is G. J. Troffer. Do you know who Mr. Troffer 8 was? !
9 A Yes. f 10 l Q Who is or was he?
l 11 A He was a gentleman that worked in i
12 Administration in the Reading home office.
() 13 Q To the best of your recollection, did.he i
14 h have any responsibilities for training at Three Mile i '
15 II Island?
I i 16 A I don't recall. ,
17 Q Another person to whom this memo was sent i
18 was K. P. Bryan. t I
I i
19 g A Yes. i I '
20 li Q Who was he?
21 A shift supervisor.
22 Q Is he still employed by Met Ed? i t
I 23 A No, he is not.
- 24 Q Do you know by whom he is employed? ,
(./ ,
25 , A No.
l 1 l
1 l ,
l
i I
I 1 ,.
Ross 170 l
()- 2j Q I believe that you indicated sometime ;
3 earlier today that among other topics of training l 4 -during the requalification cycle, and perhaps even 5
before that, this training concerned radiation 6 control and safety, is that correct? f i . !
7 l A Es. ,
i g , Q Do you recall receiving training at some :
f n
I 9
point while you were employed by Metropolitan Edison ,
' i 10 concerning radiation? .
I l ll ,
11 A Ye s .
l, .
13 Q That was prior to March of 19797 13 . A M8* '
il 4
g4 Q Did you ever receive any training as to
{l
- 15 what might cause a radiation release from the reactor .
., 'I -
- i 16 , coolant system?
17 A Can you clarify that for me? -
q 18 Q I take it in order to have radiation i ,
19 released in such a way as to cause damage'or harm to ,
f 20 .
people, for example, you would have to have something i
21
!g .wr ng in the system,-is that correct? I take it in i
22 the normal operation, the system does not emit radiation 23 to the public, is that correct?
gg A Normally it emits no detectable amount of 25 radiation to the public.
i I Q' No harmful amount of radiation?
I l.
,._,yy , - - - - , -.,,-y y - - , -
.. - ~ . .
l l 1 Ross 171 2- A Right.
. 3 Q Were you ever taught what might cause it t
4 to emit harmful-radiation to the public?
' 5 A Yes.
6 Q Can you give me an idea of what types of 7 things or if it is one thing, what would cause it to g i
8 do that?
9 MR. MacDONALD: How that would be done?
10 MS. WAGNER: What would happen in order
-11 to have that occur.
12 MR..MacDONALD: In the whole plant? l 13 MS. WAGNER: Whatever. I am not limiting-t 14 i my question. f 1
15 MR. MacDONALD: You had originally 16 started with the reactor coolant system.
17 MS. WAGNER: Any problem anywhere in the ,
18 plant.
19 ' A Basically, we were taught there were f l I i
! boundaries between the core and'the public, and we 20
- i 21 ! were taught you have to penetrate those boundaries,
- g 4
i 22 l those boundaries being the reactor coolant system i
! l i
23 , itself,.the building the coolant system is housed in, i
. I 34 so anything that would penetrate the reactor coolant -l
'I
..[)
l
'- system along with damage to the. fuel and penetrate the l 25 ;
i l I
i !
i
1 Ross 172 2 building could result in exposure to the public.
3 Q Were you ever taught at any time prior to 4
4 March 1979 that if a loss of coolant accident occurred, 5 one conceivable result could be radiation released to 6 the public, harmful radiation released to the public?
7 A Yes.
-f, 8 Q Was it part of the training at Met Ed to t 9l give training on events which had occurred either at l
10 l' Three Mile Island or at other plants prior to March I
11 1979, operational transients? I 1
I i 12 lt A Yes.
13- Q was such training administered? ,
14 g A Yes.
bl 15 h Q By whom? I
'l lt !
16 ! A Either the training department or my own .
I 17 !l!
'l department.
~
18 : Q -Were you yourscif involved in giving such L ,
I 19 l training?
20 !; A At times.
p .
, i 21 j Q How would your department prepare to give 22 such training?
I l 23 A We would attompt to get the information on-l t
24 the particular incident or whatever it was we were- ,
L) 25 i,
' going to train on, try to understand what really I
i i
1 Ross 173 I
("))
y, 2 happened, and try to train on what we would do 3 different at our plant.
4 ; Q I take it from your answer you are talking 5 about incidents at other plants.
6 A Yes.
7 ! Q How would your department obtain j i
i 4 8 information about events at other plants?
l 9 l A various ways. I&E bulletins, I&E notices, t 4 .
i !
10 i; notifications from B&W, a number of ways.
f
\ .
11 , Q After you heard about some events like ,
i !
i 12 b that, did you then go and try to get more information
() 13 N
about it? And by "you," I mean now your department.
14 {; A It depends on the incident. If we felt F i
, 15 8 it was significant, we would ask for it to be taught 16 l in training. If it was a nonsignificant, something we 17 fl l
J felt was applicable to us, we would try to teach. ,
i 18 ourselves. If it was very serious, we would teach ,
I i
19 h them prior to leaving the shift about the incident.
C
'i 20 l; Q Do you recall that ever happening?
21 A Yes. 2
! li i 22 j Q Do you recall what incidents or incident'
! i L 23 -it was that was so serious you had to teach it S 24 immediately?
X) 25 A' We had incidents where problems had l 6 i !
- 1 Ross 174 i
Y 2 developed in turbine vibration and people had not V
3 taken the correct action for vibration readings at 4
4 other plants. We taught people prior to leaving the h 5 shift that this was something you wouldn't-do.
6 Q Do you recall any other such events?
I A ones we trained specifically prior to !
7 I
8 leaving shift?
i 9 Q Yes. And also I am talking about prior to 10 March 1979. i
.i l, 11 A Nothing I can put my_ hand on, but I know I
' 3 12 there were times we did that. {
() 13 Q Prior to March 1979, were you aware of a r 14 publication entitled Current Events Power Reactors?
fl i 4 .t j 15 A Yes.
.[ f 16 Q Did you ever review that document?
8l l 17 A Yes. ,
18 Q Do you. recall if it ever occurred that you g i t-19 would read about an event in that document which would I
20 then be the subject of training?
i
]g 21. A It could be. t 22 Q Did you ever review LER's from other plants?.
l' 23 And again now I am referring to your office as well as I.. i I
24 yourself personally. .
i l - 25 j A Yes.-
I l
l~
- i l
..,m, -
-. . = - .- . -. ..
I 1 .
Ross 175
). 2 Q LER is a licensee event report, is that 3 correct?
l i
4 A Yes.
h 5 Q What is a licensee event report, or what j 6 was your understanding at the time?
4 i ,
7g l A Licensee event report is a report required
^
i!
8 underneath-your technical specifications because you ,
4 9! violated a limiting condition for operation or met one ,
t 10 of the other requirements that requires a report to be ,
11 j issued. '
l l
12 l Q To whom are the LER's submitted? j i
[)/
N 13 t
A They are sent to the NRC. '
14 I Q How did it come about that you would L
i 1
15 review an LER? Did you obtain it from the NRC?
1 i
16 A No, I am not sure. It would be sent to me 1
i i 17 ! by my supervisor.
J i
18 i Q Prior to the accident at Three Mile Island, 19 did you find that reviewing such documents was useful i
20 !" to an understanding of whatever event they were about?
a 21 A Yes.
gg 22 Q -Did you review LER's.that Metropolitan 23 ,
Edison drafted or submitted to the NRC?
'y MR. MacDONALD: All Met Ed or just --
25 : MS, WAGNER: All or any.
. sa m 8
.I I
-1 Ross 176 j i
2l A Yes.
f 3 Q Did you review all of them?
l 4 A No.
5 Q Were you ever involved in writing one or 1 -
1 I. 6 a portion of one? ?
7 A Yes, I 8~ Q As a normal rule at TMI, would the person l, l 9i who wrote the LER or who wrote portions of it have been b i i !
10 ; someone who was directly involved in the event? ;
I l
11 A The initial rough cut was done by someone 12 11 I who was'directly involved in the event. .
j 3
() 13 Q And then it would be reviewed and perhaps
- 14 changed by other people? ;
i yl, i 15 l I A Reviewed and possibly rewritten. I i
l '
16 Q I take it you were involved in both phases l
17 of that? ;
18 A At times. i 19 Q Did it ever happen that aside from an LER, '
'l!
20 a different kind of report was written by Met Ed l 1 21 personnel concerning an event at TMI? A report, but i
t 22 j, ;
'not an LER? j 23 A .Yes. 1 94 : Q What kinds of reports other than LER's ,
25- ; were written?
.s l
i l l'
- l. !
4
, n s ,,,n. +, e >
+ +s- - . , , , ..p. ,,-4-,.,,.y-- ,- ----ae m - - - . -p-- - a--n ,+---- y
1 Ross 177
) 2 A It would depend on the incident. They ,
3 could write a superintendent's event report.
4 Q Have you ever heard of the technical data 5 j report, TDR?
6 A Yes.
i 7 Q Would you review such reports, any or all? {
8 A Normally we don't get involved in the 9 writing of TDR's.
i 10 Q Would it ever happen that one.would be ~
11 submitted to you for purposes of training? l l
12 A Possibly.
() 13 Q Were there finals kept of reportable l 14 l occurrences which had occurred at TMI which were i
15 available for review by the operators?
l i
16 A Yes.
l 17 j Q Where were they kept?
18 A Control room.
19 , Q Were the operators responsible for ;
i i 20 reviewing such reports periodically?
g 21 A Significant reports were sent to them 22 when they were required to be reviewed.
23 Q Who sent them to them?
24
' A Normally, me.
J 25 ;- Q Did you make the decision'on what was t i
l 1 Ross 178 ,
N 2 l - significant and what.wasn't?
I !
A M st times. Sometimes I would have help i 3 j l
4 from outside.
l 5 Q Again for purposes of training, did you i 6 ever review TMI control room logs or shift supervisor I
7 logs or start-up logs or anything recording events l
8 that had occurred at the TMI plant?
I 9 A I don't understand the question.
l i
10 Q Did you over review logs for any purpose, l
11 any control room logs? ,
+
12 4 A Yes, we reviewed logs.
( 13 Q Which logs did you review?
1 14 .? MR. MacDONALD: Prior to the accident?
I 15 MS. WAGNER: Prior to the accident.
16 i Q And I will limit my-question right now to l
17 I when you were Supervisor of Operations. ,
'l; 18 A Control room shift foreman, shift ,
19 supervisor logs are required to be reviewed by me-20 0] weekly. I periodically look-at other logs.
i 21 .
Q Did you review any logs while you were 22 Shift Supervisor?
23 -
A. Yes.
24 l Q Which logs did you review then?
- 25 A Auxiliary operator logs, control room
, l l
l' Ross 179
( f 2 operator logs, control room logs.
3 Q Did you ever, and this is when you were a 4 shift supervisor in 1977, become aware of an incident k 5 described in one of the control room logs during which I-6 steam was trapped in'one of the hot legs of TMI-27 7 A No.
1
, 8 Q Did you ever hear at any time prior to the
, I s
9 accident of an incident in which-steam had become 10 ; trapped in the hot legs of TMI-2? l l
r i 11 A No. I 12 Q Did you ever hear of any such incident !
4 i !
with respect to TMI-17
( 13 .
} 14 A No.
i l
15 Q During the time period that you were 16 working for Metropolitan Edison, did you.ever become
. l l ;
17 aware of any incident in TMI-1 in which the reactor '
- 1 t
18 coolant drain tank rupture disk burst? ,
I i 19 A Yes. ,
20 Q Was that one time or more than one time?
.t g 21 A I can recall once. l 22 Q When was that? i
- 4
~
23 A It was.in the-prestart-up phase. It was ..
I, f 24 .
after a reactor trip.: l l !
25- l Q. sometime in_theJearly seventies?
l
'i.
i.
I _ . . _ . _ . _ , , . . _ _ _ . _ _ _ _ _ _ _ _ _ _ _ , . . _ _ _ . . . _ . . _ . . _ _ _ _ _ . . _ . . _ _ _ _ _ _ .
l 1 Rosa 180 2 A I would think early '74.
3 Q Do you know why the reactor coolant drain 4 tank rupture disk burst at that time?
5 l A I don't recall the exact reason. It was i 6 after a trip.
1 7 Q What causes the rupture disk to blow, l
8 burst? ,
9 A Increased pressure inside the tank.
i 10 , Q How does the tank get increased pressure?
11 I A Discharges something into it.
12 Q What discharges into the reactor coolant
( 13 drain tank? l i A Code safety valves, PORV valves, and some 14 ll 15 valve leak-off stems in TMI Unit 1. .
16 Q After the rupture disk blew on TMI-1, was 17 it replaced?
18 : A Yes.
I 19 (Continued on next page.)
20
- I 22 23 c
I 25 i
l I
i
i i l 1
1 Ross 'l I 2 Q Was the-design of the reactor coolant drain i '
3 tank changed at all?
j 4 A To my knowledge, no.
5 Q Do you know whether the reactor coolant 6 drain tank at TMI-2, the design of that tank was changed 7 as a result of the blowing of the rupture disk at TMI-1?
8 A No.
i 9 Q You don't know or you don't think it was 10 changed?
4 11 A I don't know.
12 Q During the time when you were a Shift j 13 Supervisor, did you ever review shif t. test engineers' 14 logs?
i
, 15 A No.
i 4'
16 (At this point, a recess was taken.)
a 17 I have a couple of questions about your
{ Q i
18 prior testimony.
i 19 When you were discussing the fact that you
- 20 would review certain in fo rmation as Supervisor of l jg) 21 Operations, you or your department, for purposes of i
22 giving training about prior events, were you talking about 23 giving. training just to Unit 1 personnel or to personnel l
- . 24 in both units?
t s.
25 A .I was referring to what. I know about, and
g
+ _
1 Ross 182
( 7 ..
- c. -
q) 2 that is Unit 1 at that time,
.3 Q Do you have any knowledge as to whether or 4 not there was any similar system in effect at TMI-2?
5 A I have no knowledge. , _
6 Q Was there a supervisor of operations at
/
7 TMI-2 --
, 8 A Yes.
9 Q --
during this time period?
10 A Yes.
11 Q Who was that?
12 - A James Floyd.
'13 Q Did you and he ever discuss what yo.u were 14 doing in this particular capacity with respect to 15 training concerning other events?
'16 A No. -
17 Q I believe we did discuss also training
- 18. concerning-events at TMI. '
19 Would you caminister training to TMI-1 20 personnel concerning events at TMI-2 or only events at
.g 21 .TMI-17 22 .
A It could be both.
l 23- l Q Back'to this document we had marked as 24 j~ Exhibit 301, and I was curious-about your indication
._ _) !'
- 25. that you believe you received the two sections that we
( .,
t'
J 1 Rcco 183 I
v
) 2 talked about after the accident. Tbc document entitled 3 " Basic Heat Transfer and Fluid Flow," which I will 4 return to you for your review, does not seem to have a 5 date on it, but I do see some dates on some of these 6 diagrams which appear to be 1971.
s 7 I wondered if you would tell me why it is 8 you believe you did not receive this document until 9 after the accident at Thrac Mile Island.
10 A I assume they used some pictures and display 1
11 6 devices that were out of existing material and they 12 comprised this handout from that.
(\_/') 13 Q Do you have any reason for believing that -
j 14 ll you can tell us now as to why you th' ink you got that m
15 after the accident and not before?
16 A Because the heat transfer course I 17 '
itself and as a separate training function was not '
18 stressed until af ter the accident by either E&W or 19 by us. ,
l 20 'Q Without regard to whether it was stressed I
S 21 or not, do you not rec'all ever havin? received any 22 1
information about heat transfer and fluid flow orior 23 to the accident? ~
s 24 A I am sure I got i formation but I never got
/ !
25 a handout labeled " Heat Transfer and Fluid Flow Training l 4
l
,4 1 -
Ross 184 t'
2 Lecture" or anything like that.
i 3 Q With respect to your belief concerning the
' i' N
4 do cumen ts immediately preceding that which is a Bsw 4 / 5 videotape manual, do you have any reason for believing 6 that you received that only after the accident?
T 7 A No, other than it is in notebooks in my 8 of fice ,. which means that I basically had it since I was 9 in Unit 2, and that is after 1978 sometime for surc.
10 It i s in a handout book, at least in this format, 11 that I know we did not ge t prior to this accident.
. 12 Q Do you have any idea when Met Ed received 4,
( 13 th'e Babcock & Wilcox videotape training manual of ty
- i 14 i'hich you have a copy in that notebook?
!!i '
A No.
I h 16 Q I take it you, to the best of your s
17 Y < recollection, have reviewed both of those documents since 18 the accident? I am not now referring to the first one B
19 but to the second and third ones.
20 A It is my belief that we have.
g 21 Q To the best of your recolledtion, was there 22 anything in either document that you can recall that you 23 kihad not known before that you learned from reading the p 24 ; document?
d {
, 25 A That is hard to say without sitting'down and i
s ,_
w e
t ? , - - -
1 Rosa 185 2 looking at the document in detail.
3 Q I wouldn't ask you to read the entire 4 document right this minute. I just wondered if you 5 could recall anything of that sort?
6 A It is hard to say without sitting down and 7 reviewing it.
8 Q Did you ever prior to March 20, 1979 hear 9 about an event at a nuclear plant at Davis-Besse in I
10 which the PORV stuck open?
11 A No.
12 Q Did you hear about it after the accident? ,
() 13 A I heard of a PORV problem after the accident.
14 Q At the Dadis-Besse plant?
1 15 A Yes.
16 Q What did you hear about it after the 17 accident?
18 A After the accident, I heard that the event 19 was very similar to what happened in Unit 2.
20 Q Who told you that?
21 A I don't recall.
i l 22 Q Do you know if it was somebody at L.
! 20 l Metropolitan Edison?
l f-%g 24 . A No, I do not.
1 25 Q Prior to March 28, 1979, did you ever
}'
[
1 Ross 186 4
2 have contact with anybody at the Davis-Besse nuclear 3 plant?
4 A No.
5 g Did you know there was a nuclear plant at 6 Davis-Besse?
7 A Yes.
l 8 Q Were you ever involved in users' group 9 meetings?
10 A only as a subcommittee member.
11 Q was there any member of that subcommittee 12 who was from Davis-Besse?
, () 13 A Not that I recall.
Prior to March of 1979, did Metropolitan 14 l Q 15 Edison administer any training to its operators 16 concerning the use of procedures?
17 A Yes.
18 Q In what training course was such training 19 administered?
20 MR. MacDONALD: The names?
g 21 MS. WAGNER: The general types.
22 Q Was it hot licensed training or requal 23 training or some other course?
i (s
AJ 24 l
A It was requal training. And initial
! 25 operator training.
1 Ross 187 l .
() 2 Q How were procedures taught?
3 A It varied. Some were taught in a classroom.
4 Some were taught at the simulator at B&W, Some were h 5 taught by walk-throughs. Various approaches.
6 Q Did you understand prior to the accident 7 in March 1979 that there could be a situation in which 8 there was no applicable procedure? l 9 A Yes.
l 10 Q How did you come to that understanding?
11 A Our administration procedures did say that 12 Q What are you referring to by "adminis t ra tion fm
) 13 procedures"?
v 14 A Administration procedure 1001 talks about 15 conduct during emergencies.
16 Q What does it tell you to do during 17 emergencies?
18 A It tells you that you have the responsibility 19 to take whatever action is necessary with or without 20 a procedure.
21 Q Do you recall whether any training was 22 administered concerning any guideliner or principles i
I 23 : to follow if you were in such a situation?
fw 24 i A No. We never addressed that specific
() l 25 incident even at the simulator. Specific emergency.
1 Ross 188
( ) 2 That was outside the bounds of our procedures.
3 Q Do you know who drafted the administrative 4 procedure 1001?
5 A No.
6 Q Do you know if training was administered 7 on that procedure?
8 A No.
9 Q Were you ever taught in any training program 10 prior to March 1979 that the system, the nuclear steam a
11 supply system was designed so that it could take care 12 of itself for some period of time so that an immediate
() 13 action --
and by "immediate" I will say within five 14 minutes -- was not necessary in order to prevent damage?
15 A No.
16 Q You do not understand that one of the i- 17 design bases of the plant was that it should be able to 18 take care of itself for some period of time greater than 19 five minutes?
l 20 A No.
I j) 21 Q With respect to the use of procedure s ,
22 and I will refer now solely to emergency procedures, l
! 23 the procedures normally have an initial section called 7-s 24 " Symptoms"; is that right?
D 5 A- Yes.
l l
l'
1 Ross 189
) 2 Q And those symptoms can be anything from 3
ne to several; is that correct?
4 A Yes.
5 Q Were operators taught that in order for the 6 procedure to be applicable, every one of the symptoms 7 must be present?
8 A No. They were taught that any or all of the 9 symptoms could be present or that symptom didn't even 10 have to be there.
11 Q Once they had decided that some procedure 12 was applicable, were they taught, assuming you are not O)
( 13 in a situation where it is not applicable, were they 14 taught to follow the procedure step by step until they 15 finished the whole procedure or taught to follow some 16 steps and then use their own judgment about what to do 17 next?
18 A They were taught to follow the procedure,
- 19 and should something happen in the course of following 20 that that would take them in another course, they were also taught to follow that course,
]ll 21 j .22 Q Were they given any guidance as to the order 23 or priarity between operating procedures and emergency 24 procedures? Suppose you believed an emergency procedure 7-v :
25 and an operating procedure were both applicable to some f
1 Ross 190 2
-( ). 2 event but they were in conflict, would one of those 3 take precedence?
4 MR. MacDONALD: You are asking for his 5 understanding based on his training?
6 MS. WAGNER: Yes, prior to March 1979.
7 A I think it depends on the situation. First 8 of all, did they recognize that conflict? If they 9 recognized the conflict, they would take the most 10 conservative of the two, if that was possible. There 11 are situations where it is not possible.
12 Q Assuming it were possible, would you also
( 13 - take the most conservative approach if there~ were a
- 14 conflict, for example, that you perceived between a 15 Tech Spec that you believed applicable and an emergency 16 procedure that you believed applicable?
17 A Yes. I think you would. You would attempt 18 to.
19 Q Is it correct that operators were supposed 20 to memorize the immediate' actions for emergency i
21 procedures?
l
+
22 A. Yes.
I
, 23 Q Is there anything else in the procedures l
[ . 24 , that they were supposed to memorize?
~
25 ; A No.
l l
. ., .,r.- , - . _ _ , . - , .--e. , , . ,- . - , - .
1 Ross 191
( 2 Q Were you familiar with emergency procedure 3 2202-1.5, which was called pressurizer system f ailure?
4 I will show you a copy of that document to refresh 5 your recollection.
6 MS. WAGNER: I will mark it as B&W 7 Exhibit 305.
8 (Multipage document, the second page 9 entitled "Three Mile Island Nuclear Station 10 Unit 2 Emergency Procedure 2202-1.5 Pressurizer 11 System Failure" was marked as B&W Exhibit No.
12 305 for identification, as of this date.)
13 Q Were you f amiliar with this procedure prior 14 to March 19797 15 MR. MacDONALD: This particular revision?
16 MS. WAGNER: I will tell you that this is 17 the procedure that was in effect in March 1979.
18 It has been so represented to us.
19 Q I will ask you if you were familiar at.that 20 time with this procedure?
jg -21 MR. MacDONALD: The reason why I ask is 22 because some of these revisions might have been-l 23 ,
after the time he left Unit 2. I see there are rs 24 l' things --
N_),
25 MS. WAGNER: I understood he was-cross-
1 Ross 192 2 licensed until March 1979.
3 Q Is that correct?
4 MR. MacDONALD: It doesn't mean that he 5 operated ' with the procedures.
6 Q Were you familiar with this procedure?
7 A I was familiar with a procedure like this.
8 g. You are not sure whether this revision is 9 the one you were familiar with, right?
10 A Right.
11 Q Is it correct that the first page of the 12 procedure, page 1.0 indicates the symptoms for a leaking A)
( 13 pilot operated relief valve?
14 A Yes.
15 Q Do the symptons indicate any reference to 16 the light in_the control room indicating signal to 17 the solenoid?
18 A No.
19 Q I would like to refer you now to page 4.0, 20 which. concerns a leaking code relief valve, and I jg). 21 specifically refer you to Se ction C. 3, follow-up 22 action No. 3, which is " Place Code Relief Discharge 23 Line temperatures on Analog. Trend Recorder."
rT 24 .
- We re you familiar before the accident with
.b 25 this' requirement?
E -
1 Ross 193 l
[))
2 A I don't recall. It is part of a follow-up 3
action. It is not something an operator would have j l
4 committed to memory.
ll 5 Q Do you know what an " Analog Trend Recorder" 6 is?
7 A Yes.
8 l Q What is it?
9 A A trend recorder on a computer.
10 Q I take it there is a method or there was 11 a method at that time by which you could place the code 12 relief discharge line temperatures on that recorder?
(} 13 A I don't recall it but there must have been.
14 Q Is there such a system at TMI-1 today, do 15 ycu know?
16 A An analog trend recorder?
17 Q -Yes.
18 A Yes.
19 Q On which you could place code relief 20 discharge line temperatures?
l 21 A I think you will find that ours has been 22 modified and you can't get pure data but you will get a 23 ,
dif fe rential temperature .
94 i Q- Do you recall whether you had any rs l' N_ understanding prior to March 1979 as to why this 25 i
.y= - p -q y w- y w. ww--- -r -y
--9 -=g--g ~w- yW-
. . . . - . - - . - . - . - - -- ..- - =~__._~ -_ _. - _
a l
1 Ross 194
(- 2 procedure required that you put discharge line 3 temperatures on an analog trend recorder?
4 A No, I don't recall. It is part of a follow-i' 5 up action. We didn't have it committed to memory. We i
i 6 probably wouldn't have sat'and trained on that specific 7 action.
8 Q I take it if you had encountered a situation 9 which you believed to be a leaking code relief valve, i
a
- j. 10 you would have referred to this procedure?
i' 11 A I would have, yes.
12 Q Page 5.0 refers to -- actually, I want to .
j-re fer to page 2.0, which refers to " Inoperative Pilot
{) 13 ,
14 operated Relief Valve," Section B.2, sub A, sub 2, for 15 a failed open.RC-R2.
i
- 16. Is it correct that'one of the symptoms of l 17 a f ailed open PORV is listed here as the actuation of i- 18 high pressure injection?
! 19 -A Yes.
i t 20 Q Does this procedure refer in any way to i
21- the. indicator light in the control room, the indicator r
22- light.which shows power to the solenoid of the PORV7 f
1 .
- 23 l' A
- No, it doesn't. -That . doesn't mean we i 24- wouldn't'have-used it.
4 25 'Q Do youJrecall any.other instance prior to t
a e
+
f
,, ,--y . [~ -
- ~ _ . ,-w,- , yy,-r---*
- vr w,er- w e,e e m e - = '+-+4-+e
- w=-r- +=<w-* ---,rw----- r wvrw w 9-y e -e-w-r--
. . ~ . -
.~
1 Ross 195 2 the accident at Three Mile Island in which you were 3
required to use an analog trend recorder?
4 A. An analog trend recorder was required to be 5 used for planned heat-ups and cool-downs.
6 Q What information did you put on it at that 7
time?
.g A~ Pressure on one plot, and temperature on 9 anothe r plot.
10 Q was the purpose of that to give you a
< 11 heat-up/ cool-down curve which you would follow in 12 heating up and cooling down?
() 13 A The purpose of.that was to document that we 14 didn't exceed our heat-up and cool-down rates.
15 Q Do you recall right now whether you were 4
f 16 . familiar prior to 1979 in March with a. procedure for 17 loss of reactor coolant, reactor coolant system pressure 18 at TMI-2 which has been previously marked as B&W 272?
19 A I was familiar with a procedure like that.
20 Q I w uld like to refer you to page 6.0 of 21 this procedure, which concerns leak or rupture of 22 significant size such~that engineered. safety features 23 ,
systems are automatically initiated. There are a.
[
.j_ - 34 number of symptoms listed on that page, and at the g
-\ -
l 95 ; bottom there is a reference to a way in which the t
I
_- . . - - --4-.- , _ - -- .- -, . ..-._ , . , _ ,- . . -
i 1 Ross 196 1
2 operator can distinguish between the loss of coolant 4
3 and OTSG tube rupture and a steam line break. It is i-
, 4 indicated that you can tell a loss of coolant by a 5 monitor alarm on HPR 227 " reactor building air sample."
1 6 Do you recall whether you were aware of this 1
i 7 part of the procedure prior to March 1979?
f 8 A I was aware of it.
i 9 Q Were you aware in particular of this HPR 227 5 10 monitor which was supposed to go off apparently if you i l 4 i 11 had a loss of coolant?
i 1
12 A I don't recall the number.
() 13 Q But you recall there was a radiation monitor
} 14 of some kind?
i 15 A Yes.
16 Q Do you recall whether you received any
. 17 training with respect to how the radiation monitor l
18 worked?
f
! 19 A Yes, we did.
20 Q Do you recall whether you received any
]g 21 documents with respect to how the radiation monitor
- 22' worked?
23 i, A No, I do not.
f, 24 Q Was it your understanding prior to March u 25 - 1979 that this procedure was applicable.for any event
l
l I
1 Ross 197
/~N I
~
kY 2 which resulted in a loss of system pressure to a certain !
3 point whether or not that was caused by a leak?
4 A No. This procedure may not have been 9 5 applicabla for such things as an overcooling event 6 or some other event that resulted in a loss of pressure. i 7 Q Did you believe it would only be applicable 8 if you had a leak out of the system somehow? l 9 A In its entirety, yes. l 10 Q Do you know who was responsible for placing 11 the radiation monitors in the reactor coolant system?
i 12 ' A I didn't understand.
/~
(,h) 13 ,! Q There is a radiation monitor referred to
'IF 14 l in the LOCA procedure. Do you know who was responsible 15 for putting that monitor-wherever it is and setting it 16 l to the right calibration so it would go off if a LOCA ,
I i 17 !
foccurred?
18 I MR. MACDONALD: A person?
19 MS. WAGNER: Function.
b 20 A No, I do not. I also don't think that t
.21 monitor was put there specifically as a LOCA monitor.
lh l
22 ' There were other.uses for it.
\i 23 Q Did you receive training on the use of this 4
- t]
(./
24 procedure prior to March 19797 ,
25 A ms.
l Q Were you involved at all in the process by I
1 Ross 198
( 2 which emergency procedures for TMI-2 were verified?
3 A Yes.
4 Q What was your role in that?
~
5 A Basically, we took the prepared procedure --
t 6 and the people who prepared it used B&W input and other 7 input -- we field-walked it to verify that valve numbers 8 were correct, switch locations were correct. More of a 9 location walk-down and a verification of field function.
10 Q Did you have any method, for example, to 11 verify that this procedure was a good procedure , and by 12 "this procedure" I mean the LOCA procedure.
() 13 A Yes. We used them at the B&W simulator.
, 14 We assumed they were good procedures because when it 15 was NSS specific, we normally got drafts from B&W.
16 Q But as far as you know, the only method Met 17 Ed used to verify that it was an appropriate procedure 18 was to try it out on the simulator?
19 A Try it on the simulator, field-walk it, 20 to verify it was specific.
g 21 (Time noted: 4:50 p.m.)
22 23 Michael J. Ross l
24 Subscribed and sworn to be fore me i
25 this day of , 1981 l
l
, _ _ - - __ _ . ~ . _
1
, 199 2
- _C _E _R _T _I _F _I _C _A _T _E 3 STATE OF NEW YORK )
- ss.:
4 COUNTY OF NEW YORK )
(*~
i 5
- s. ^&
V:
6 I,_ yostpH R. DANYo , a 7 Notary Public within and for the State of New York, 8
do hereby certify that the foregoing deposition 9 of MICHAEL J.'ROSS Was taken before 10 me on Tuesday, November 17, 1981 ;
11 That the said witness was duly sworn 12 before the commencement of his testimeny and 13 that the within transcript is a true record of said 14 testimony; 15 That I am not connected by bloed 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 1
19 counsel.
20 IN WITNESS WHEREOF, I have hereunto set
,:$ 21 my hand this [ day of freM/62 , 1981.
s N.
22 j -
24 Jc/s eph . R . Danylf(
25
'M L $
200 I N DE X WITNESS PAGE l
Michael J. Ross 4 E XH I B I TS
'B&W FOR IDENTIFICATION 300 Resume of Michael J. Ross consisting of three pages 5 301 Deemed Binder entitled " Nuclear Instrumentation" 153 302 Two-page document, first page a memo from L.
O Lawyer, subject:
L.
Training Requal for Attendance , dated September 19, 1978; second page, an undated memo from M. J. Ross to G. P. Miller 165 303 One-page document dated June 21, 1978, entitled
" Unit I/II Requal Program Attendance," written by Don Goodman, addressed to a number of people , including Mr. Ross 167 304 One-page document entitled
" Unit I/II Requal Program Attendance" written by M. L.
Beers, dated September 1, 1978, addressed to number of people ,
including Mr. Ross 168
-_.. . . _ ~ .- .. . -
9 1
201 t
4 1
!{ INDEX TO EXHIBITS (contin ue d) i B&W FOR
- IDENTIFICATION PAGE ,
i 305 Multipage document, the second page entitled l "Three Mile Island Nuclear Station Unit 2 Emergency ,
Procedure 2202-1.5
)
Pressurizer System Failure" 191 k
l i
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i 1
l I
i i
2 I
i I
?
e 9
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. _ - , . _ _ _ . . . _ . . _ - - _ . . - - . . . . . . _ _ _ _ . _ _ _ _ _ _ _ _ _ _ _ _ . . - . _ . _ . _ _ _ . . . . . - . _ _ - . _