ML20072J092
| ML20072J092 | |
| Person / Time | |
|---|---|
| Site: | Three Mile Island  |
| Issue date: | 05/06/1981 |
| From: | Joseph Kelly BABCOCK & WILCOX CO. |
| To: | |
| References | |
| TASK-*, TASK-01, TASK-02, TASK-1, TASK-2, TASK-GB NUDOCS 8306290920 | |
| Download: ML20072J092 (138) | |
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Q UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORY.
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. . . .__ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _x GENERAL PUBLIC UTILITIES CORPORATION, :
JERSEY CENTRAL POWER & LIGHT COMPANY, METROPOLITAN EDISON COMPANY and :
PENNSYLVANIA ELECTRIC COMPANY, Plaintiffs, 80 CIV. 1683 -
- (R.O.)
-against- ,
t .
THE BABCOCK & WILCOX COMPANY and J. RAY McDERMOTT & CO., INC., :
Defendants. I x
Continued deposition of Defendant The Babcock & Wilcox Company by SOSEPR J. KELLY, JR.,
taken by Plaintiffs, pursue.nt to adjournment, held at the offices of Kaye, Schol@r, E i e'rma n ,
Hays & Handler, Esgs., 425 P a 2. k Avenue, New York, New York, on We dnes day, May 6, 1981, at 9:40 o' clock in the forenoon, be fo re '
t
+
Joseph R. Danyo, a Shorthand Repo rter and i
Notary Public within and for the State of New Yo rk.
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/~ 8306290920 810506 ,
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\ PDR ADOCK 05000289 i 5 T PDR DOYLE REPORTING. I N C. , '
CERTIFIED STENOTYPE REPORTERS 369 LExt N GTO N AVENUE WALTER SHAPIRO, C.S.R. NEW Yo R K. N.Y. loo 17 CHARLES SHAPIRO, C.S.R.
TELEPNoNE 212 " 667-6220
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2 App e a ran ce s :
3 KAYE, SCHOLER, FIERMAN, HAYS & HANDLER, ESQS.
4 Attorneys for Plaintiffs 425 Park Avenue
- 1 3 '6 BY: RICHARD C. SELTZER, ESQ.,
\ -anda 7 ANDREW MacDONALD, ESQ.
4
, ,8 of Counsel _
4 0,. ._, ,
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10' DAVIS, POLK & WARDWELL, ESQS.,
^ Attorneys for Defendants 11 , One Chase Manhattan Plaza j
- 12 BY: DANIEL F. KOLB, ESQ.'
. . 13 i
14;
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- 15 Also Present
- m. 16 PATRICI'A VAUGHAN -
17 .
DAVID TAYLOR .-
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k._ . , i 2 J OS E P H J. KE L L Y , J R.,
3 having been previously sworn by a 4 Notary Public, was further examined
(' 5 and testified as follows :
6 EXAMINATION (Continued) 7 BY MR. SELTZER:
8 Q I am sure you know your tes timony .
l 9 today continues to be under oath, do you no t?
I 10 A Yes, I do. 1 11 Q You have previously identified a 12 meeting that you had with Don Hallman and O 13 Frank Walters in June 1979 at which you i 14 dis cusse d the Kelly-Dunn-Hallman-Walters
. 15 memoranda relating to your concern over i
i 16 premature termination of high pressure injection.
17 Where was that meeting held?
18 A In Frank Walters' o f fi c e .
19 Q Other than you, Don and Frank, 20 was anybody else in attendance?
21 A No.
22 Q How long did the meeting las t?
23 A I do n ' t remember.
w) 24 Q Approximately?
25 A Forty-five minutes app ro xima te ly .
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318 1 Kelly
[J Is your office and Frank's on the 2 Q 3 same floor? .Was it at that time?
4 A Yes.
( 5 Q How far away?
6 A Four or five minute walk, maybe.
7 Q Who suggested the meeting among 8 you, F' rank Walters and Don Hallman? ,
9 MR. KOLB: Obj ection to fo rm.
10 A I don't remember. E 11 Q Was it your idea?
12 A I do n ' t remember.
O 13 Q Did you bring anythi g to the 14 me e ti ng ?
15 A Not that I recall.
16 Q In your te s timony be fo re the staff 17 of the President's Commision at page 33 o f your 18 seco d day o f tes timony , you said "barly in 19 June, the first week in June, Don Hallman 20 called me on the phone and wanted to go over
.- 21 this series of memos."
k 22 Was that your best recollection 23 then of who had called you to suggest the 24 meeting among you, Don and Frank Walters?
25 MR. KOLB: We are giving the
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2 319 1 Kelly 2 witness a copy of the testimony.
3 Let us read the testimony in context,
- 4 and then you will get your answer i 5 on that.
i 6 (Record read by the reporter.)
l l
7 A I do n' t re me mb e r that now, but. it must i
8 have been my best recollection then. .
- 9 Q Would you look at page 40 of l 1
1 10 your first day o f tes timony be fo r'e the Kemeny 11 Commis sion Staf f previously marked GPU 4
12 Exhibit 150.
13 Do you see at the bottom of the 14 page where you said in line 20, "We went over j 15 the whole sequence."
16 A Yes.
17 Q You said there , "We went over the whole sequence of these memos that' you j us t 18 i
19 brought out. "
- 20 " QUESTION
- You and Hallman and
- 21 Walters?
22 " ANSWER: Right, and we just talked l
23 about that. With all this' paper work something
()
O 24 s ho ul d ' have happened, and we were at a loss 25 as to why it didn't."
I l
320 1 Kelly i u /.
2 At the top of the next page 3 you are asked " QUESTION: Did anyone o f fe r 4 an explanation of why it did not?
( 5 " ANSWER: No, we j us t came to 6 saying what did Bruce do with it?"
7 Were you asked the questions that 8 I read and did you give the answers that I ,
9 just read?
10 A Yes. t 11 Q When you refer to "all this pape r 12 work," were you referring to your November 1 13 memo, Frank's November 11, 1977 memo, Durn's 14 two memos in February and Hallman's memo in 15 August 1978? -
16 A Yes.
17 Q When you said "something should 18 have happened," what did you mean, that the 19 issues raised in those memos should have been 20 resolved?
21 A I do n' t remember.
22 Q It is a fa ct , is it not, that prior 23 to the Three Mile Island accident, the issues (q j\
24 raised in those memos were not resolved, right?
i 25 A You are asking me what I know today?
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(_1 2 Q Yes.
3 A Yes.
4 Q When you said on page 41 that
( 5 "no one offered an axplanation of why nothing 6 happened, we just came to saying what did 7 Bruce do wi th i t , " " B ru ce " refers to Bruce 8 Karrasch?
9 MR. KOLB: I object to the 10 form because I don't think tyour 11 paraphrase of the testimony is exactly 12 correct.
')
s/ 13 Q Is " Bruce," Bruce Karrasch?
14 A Yes.
15 Q Would you turn to page 34 of the 16 second day of your testimony before the Kemeny 17 Commission Staf f, GPU Exhibit 150. .
18 MR. KOLB: July 137 19 MR. SELTZER: Yes.
20 Q Am I correct that at page 34 you 21 are tes tifying about a conversation that you 22 had with the head of your Integration Unit, 23 Bruce Karrasch?
24 A Y e s ..
25 - g And you were testifying about a
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322 1 Kelly
~
2 conversation which you had had with him 3 during the week between your testimony to 4 the Kemeny S taf f on July 7 and the resumption
( 5 of your tes timony on July 13, is that right?
6 A Yes.
7 Q At line 5 and a half, you are 8 asked, "What was said in this conversation?
9 " ANSWER: I. told him that, a brief 10 summary o f what had happened while he was 11 on vacation in this area and about my previous 12 testimony, and I asked him what had happened oO 13 to that.
14 "Q UES TIO N : What di d h e say?
15 " ANSWER: He said that he had 9
16 the memo. He had gotten the memo, and that 17 he sat on it for a few months and that 18 periodically Don Hallman had called him and 19 asked him what the resolution was, ind Bruce 20 says that around the turn of the year, 21 Christmastime or early January of 1979 we 22 are talking about now, that he reread the 23 ' memo from Don Hallman, decided that he agreed
() 24 with.Bert Dunn and that he calle d Don Hallman 25 and told him so. That was the essence of what
l 323 1 Kelly 0 2 Bruce had told me happened to him.
3 " QUESTION: Did he say whether 4 he had ever sent a memo back to Hallman?
( 5 " ANSWER: He specifically said 6 he did no t. It'was all telephone conversation."
7 were you asked those questions and 8 did you give .those sworn answers? -
9 A Yes.
t 10 Q Were they accurate at the time 11 you gave them, to the best of your recollection 12 then?
13 A Yes.
14 Q Do you still believe they are 15 accurate?
16 MR. KOLB: ,Are you asking him 17 whether he remembers - today o r' do you 18 mean something else by your question?
19 Is there anything in what I read Q
20 which is inconsistent with your pres ent 21 recollection?
22 In other words, do you have any 23 reason to believe that anything you testifie d
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's .- 24 to in the portion that I just read is false?
25 A Again, there are two di f f e re nt situations.
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- 1 Kelly
- 2 I f yo u a re asking me what I remember about l that conversation with Bruce, .I think that j 3 4 I do not remember anything dif f e re nt than i
i
() 5 that. If you are asking me have I learned l
6 different things from hearing other people i 7 testify since then, then my answer is yes.
j 8 What other people are you Q ,
9 referring to?
l t 10 A t Bruce Karrasch. .
I 11 Q Have you heard Bruce Karrasch 12 te s ti fy about what he did wi th Don Hallman's
("< 13 memo?
! 14 MR. KOLB: " Te s ti fy" in 't he
- 15 sense of swo rn testimony?
16 Q Testify in the sense that you 17 used the wo rd " testify. " .
l ,
18 A Yes. ,
19 Q Did Bruce Karrasch give a different 20 s to ry than the one you tes tifie d to here?
21 A' It was slightly di f f e ren t , yes.
22 Q In what respects was it different?
23 A From wha t I remember o f Bruce 's testimony,.
) 24 where I'said that he decided that he agreed 25 with Bert-Dunn and that he . calle d Don Hallman
~
1 325 1 Kelly p.
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' d~ 2 and told him so , I remember Bruce t e s ti fyi ng
! 3 that instead of that being a telephone i 4^ conversation, that he had met Don Hallman in
(' 5 the hallway somewhere and told him verbally.
, 6 Q That it was a coincidental meeting 7 in the hallway that led to the conversation 4
8 in which Bruce Karrasch told Don Hallman that .
9 Bruce Karrasch agreed with Dunn's recommendations?
10 MR. KOLB: Coincidental meeting, 4
8 11 accident?
j 12 Q They didn ' t plan to meet, they 13 hadn't scheduled a meeting in the hallway.
d 14 That is what I mean.
15 A Yes.
16 Q Was there any o ther discrepancy 17 between what Bruce Karrasch testif'ied to and 18 what you testified to?
, 19 A Not that I can recall.
, 20 Q Did you ever raise with Bruce the 21 fact that you recalled him telling you that 22_ , he had communicated with 'Hallman over the i
23 telephone and Bruce had j us t testified that 4
() 24- the communication had been face-to-face?
25 A I don' t _ remembe r.
1 -
_ ___ . _ .. _ _ _ . ~ . _ _ . . _ . . . . . _ . _ _ _ _ . _ _ . _ . _ , . . . - .
326 i i
1 Kelly b
k- -
2 Q When you say that Bruce Karrasch 3 told you he had the memo, he had gotten the 4 memo, and that he sat on it for a few months,
( 5 is Se memo to which you were referring the 6 Hallman August 1978 memo?
7 MR. KOLB: I think it would be 8 best if you gave us the exhibit number.
9 We have been referring to these memos
{
10 in general. I don't think.it would I 11 hurt if you were a little more sp eci fic .
12 MR. SELTZER: I am referring to 13 GPU Exhibit 80, Don Hallman's memo 14 to Bruce Karrasch of Augus t 3, 1978, 15 subject: Operator interruption of high 1
16 pressure injection.
17 A Yes, that is the memo Bruce'and I were 18 re fe rri ng to.
19 Q You say that he sat on it for a 20 few months in your repeating what Bruce Karrasch 21 had told you, is that right?
22 MR. KOLB: Are you asking him 23 whether those are the exact words 24 Mr. Karrasch used?
[O~)
25 MR. SELTZER: No.
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327 l 4
1 Kelly 2 Q When you testified that Bruce 1
3 Karrasch said he had gotten the memo and he 4 sat on it fo r a few months, were you testifying
( 5 to the words or substance of the words that 6 Bruce Karrasch had said to you in your re cent 7 conversation with him?
8 MR. KOLB: There are two questions 9 there. Was he testi fying to the words?
10 That is one question. The 'second is ,
11 was he te s ti fying to the substance of 12 the words?
O 13 Q Tell us. Were thos e Bruce 's 14 wo rds or were those the substance of the 15 words he had used?
16 A That is what I remembe re d o f the meaning 17 of the wo r ds , s I
18 Q What does the expressioE that "he sat 19 on it for a few months" mean?
4 20 MR. KOLB: What did the witness
, 21 mean when he said that?
k 22 MR. SELTZER: Yes.
23 A He didn't take any action on it.
D
, ( j\ ' 24 Q Your testimony goes on to say .
25 " P e rio di cally , Don Hallman had called him and l
4
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l 328 1
1 Kelly l l
O 2 and asked him what the resolution was . "
3 When you used the word 4 "pe rio dically , " what did you mean?
4
( 5 A I meant to imply that he had called --
6 Don Hallman had called Bruce Karrasch a 7 couple of times, which is what I remember 8- Don Hallman telling me from the meeting with 9 Hallman and Walters and myself in early June.
10 I did not mean to imply it was atsystematic, 11 regular thing that he called me, but rather 12 just a few times he had called me.
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\- 13 Q You were testifying that Bruce 14 - Karrasch had told you that Don Hallman had 15 called him a few times, is that right?
16 A Again, in the substance of what I 17 remember, not the exact words of what Bruce 18 told me, yes.
19 Q Bruce told you that it w'a s no t 20 until the turn of the year, namely, the end 21 of 1978 o r early January 1979 that Bruce 22 Karrasch stopped sitting on the Hallman memo, 23 is that right?
[v) 24 MR. KOLB: The testimony doesn't 25 say that in so many words. It doesn't i- .
l l
l 329 l' Kelly
. O C. 2 say " stopped sitting on."
3 MR. SELTZER: Ri gh t .
4 MR. KOLB: I think if you are
( 5 asking him for his present recollection, 6 you ought to ask him for his pres ent 7 recollection and no t track the testimony 8 as if you were reading f rom exact 9 te s timony , which you are not.
10 can we have the ques tion in one 11 fo rm o r another so it is an accurate 12 recitation of the tes timony or a separate i
\- 13 que s tion as to his present recollection?
t 14 BY MR. SELTZER:
15 Q Did you understand from Bruce 16 Karrasch's conversation with you that Bruce 17 Karrcsch had sat on the Hallman memo and done 18 nothing about it until the turn o f the year, f
namely, Christmastime 1978 or early lanaury 19 20 19797 21 MR. KOLB: You are using the 22 phrases " sat on" and ",did nothing about 23 it" in the sense that the witness has (eg n 24 te s ti fi e d that the individual, Mr. Karrasch,
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25 took no action.
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330 1 Kelly U) 2 MR. SELTZER: Yes, that is what 3 I said. Sat on it or took no action.
4 A Yes.
(' 5 Q So for approximately five months 6 B ruce Karrasch had done nothing in respons e 7 to either Don Hallman's memo, GPU Exhibit 80, 8 or the s e ve ral requests that he re ceived 9 from Don Hallman for action on the memo, i
10 is that right? M t
11 MR. KOLB: Let's have the 12 ques tio n again.
O 13 (Record read by the reporter.)
14 MR. KOLB: I object to that 15 for three reasons. First of all, if 16 you are asking him what was said, 17 I don't believe there is anything in i 18 the record that indicates a computation
.; 10 of months.
20 Secondly, you are in di catin g that 21 the effect of the testimony is that 22 Mr. Karrasch did absolutely nothing, 23 and I don't think that is what the
() 24 witness said.
25 I think "take action" means something
331 1 Kelly
.i
)
2 different. You are implying it 3 means more than it does. Let's 4 hear the question again.
( 5 (Record read by the repo rte r. )
6 MR. KOLB: My final point is, 7 that "several" is a dif ferent wo rd 8 from the testimony as I understand it, 9 and I think, again, you are characterizing 10 the testimony in a fashion which is 11 inconsistent with what the witness has 12 said in so many words.
O 13 So I object to the question on all 14 three g ro un ds .
15 (Record read by the reporter.)
16 Q Isn't that your unders tan di ng?
17 A There is nothing he told me'that gave 18 me the imp re s sion that he did anything.
19 Q You have never learne d o'f anything 20 that he di d in those five months to take action 21 on the Don Hallman memo , . GP U Exhibit 80, isn't 22 that right?
23 A Yes.
/)
%,c 24 Q Yes, that is righ t?
25 A Yes, that is right.
i 332 1 Kelly
's t 2 Q You have never heard Bruce
, 3 Karrasch say to anybo dy that he did anything 4 or took any action on the memo in those
(, 5 five months , have you?
6 MR. KOLB: Are you drawing a 7 distinction between did anything and 8 take any action, or do you mean that 9 to be the same thing?
10 MR. SELTZER: You in your 11 obj ection seem to paraphrase my words t
12 for whether there is any di f fe re n ce ,
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i 13 and so I want to include both.
14 MR. KOLB: My question to you 15 is, do you mean those-two things 16 yourself?
17 MR. SELTZER: I mean them in the 18 sense that you find anything di f f e re n t 19 in them.
20 MR. KOLB: "Anything" means 21 possibly something beyond taking 22 action.
23 MR. SELTZER: To make'sure we have 24 a clear read --
25 MR. KOLB: Let me e xp lai n , if you
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l 333 1 Kelly 1 l
(3 v 2 have difficulty un de rs tan din g.
3 MR. SELTZER: I don't have any 4 dif ficulty unde rs tan ding. I don't
( 5 want a speech from you. I want the 6 testimony f rom the witness.
7 MR. KOLB: I think it should 8 be clear that the objection is clear.
9 MR. SELTZER: Let me make a )
10 statement. You have made your obj ection. l 11 The objection stands on the record.
12 If a judge wants to sustain your
'\
13 objection when we go to trial, that is 14 fine. You don't have to explain your 15 objection to me.
16 MR. KOLB: But I am entitle d to.
17 MR. SELTZERt I don't ~ want to hear 18 it, and I don' t want the witness to hear
~
19 it.
20 MR. KOLB: I understand that is 21 your position , but I want to state my 22 objection.
23 MR. SELTZER: I want the witness
'fv 24 to leave.the room.
25 MR. KOLB: I think the objection
334 1 Kelly 2 co uld be dealt with appropriately 3 with all counsel present.
4 Are you concerned if I state
( 5 my objection, the testimony may be 6 clarified, or would you rather have 7 it not clear? You are perfectly free 8 to hear what I say. If you don't think 9 it is an appropriate objection, you can 10 say so. E 11 MR. SELTZER: I do n ' t like co uns el 12 instructing the witness in the guise O'- 13 o f obj ections. ,
e 14 MR. KOLB: I am not doing that.
, 15 You don't even know what I am going to 16 say. You are already accusing me of 17 ' doing something inappropriate.
18 MR. SELTZER: I think what'is 19 happening now is foolish, and I withdraw 20 the que s tio n to forestall-any more 21 foolishness.
22 BY MR. SELTZER:
t 23 Q At your meeting in Frank's office i
/^\ '
() 24 .in June 1979, did Don Hallman in dicate that 15 he had eventually heard from Bruce Karrasch
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335 1 Kelly 2 prior to the Three Mile Island accident that 3 Bruce. concurred with Bert Dunn's recommendations?
4 A I don' t remember that.
( 5 Q Did Don or Frank indicate at the 6 June meeting that they had ever got any 7 response from Bruce Karrasch before the 8 Three Mile Island accident to the memo which 9 Mr. Hallman had sent on August 3, 1978, 10 GPU Exhibit 807 t 11 A Don mentioned the telephone conversations 12 with Bruce that I talked about earlier.
13 Q Which phone conversations, the 14 ones where he periodically asked Bruce I
15 Karrasch to take action?
16 MR. KOLB: Objection as to form.
17 A I don't remember him using the words 18 "to take action." It was more in shbstance 19 he had asked Bruce what was happening, what 20 was the s tatus of the memo?
21 Q At your June meeting, in other 22 words, Don Hallman told you before you had ,
23 heard it from Bruce Karrasch-that Don had f ) 24 c'alled Bruce several times to ask him -" Wha t
%/
25 are you doing about the issues ~ I raised
i
+
l 336 i Kelly
~
2 in my August 1978 memo"?
3 MR. KOLB: The question is 4 whether that is what the witness
( 5 remembers Mr. Hallman saying?
6 MR. SELTZER: Yes, in substance.
7 A It was more like a couple of times or 8 a few times than several,'but, yes.
9 Q By "a few," what range of numbers 10 are yo u encompassing? E 11 A Two or three.
12 Q At your June meeting, did Don n
N' 13 Hallman indicate whether he had ever gotten 14 a resolution from Bruce Karrasch of the 15 issues raised in GPU Exhibit 80, the August e.
16 memo?
17 A I do n' t remember that. .
18 Q At the meeting in June, did you 19, ask Frank Walters or Don Hallman whether- they 20 ever got a resolution from. Bruce.Karrasch?
21 A Not that I remember.
L 22 Q At the June meeting, what,'if anything, 23 did you say about the' fact that the concerns.
(O w] 24 r'aised in all of 'these memoranda that you 25 were discussing had not been resolved before
337 1 Kelly O
V the Three Mile Island accident?
2 3 A I don' t remember.
4 Q What did Don Hallman say about
( 5 the fact that the matter hadn' t been resolved i
6 before the Three Mile Island accident?
7 MR. KOLB: Objection to the form.
8 Q If he said anything.
9 A I don't remember.
10 Q What did Frank Walter's say about 11 the fact that the concerns raised in these 5
12 memos had no t been resolved before the O 13 Three Mile Island accident? .
14 MR. KOLB: Obj ection to the fo rm.
15 A Frank said he didn't think it would have 16 made any difference if they had been resolved 17 and the instructions gone out, because the 18 operators didn't pay any attention [o the 19 procedures they already had. ,
20 Q Did Frank indicate whether he had 21 reviewed the Three Mile Island Unit 2 22 Procedures prior to the June meeting that' 23 you were having? {
1 (i 24 A* I don't remember.
25 Q Do you know whether Frank had
j
, 338
! 1 Kelly O -
2 reviewed the Three Mile Island Unit 2 3 Procedures before the June meeting?
l 4 A I don't know. '
(' 5 Q Do you know specifically what 6 procedure Frank thought the operators had not 7 followed ,or what procedures Frank thought the 8 operators had not followe d?
9 A No.
10 Q Did you ask him which,ones he j 11 was specifically referring to?
12 A Not that I remember.
13 Q As you sit here today, have.you 14 ever examined the Three Mile Island Unit 2 15 Procedures that were in effect on March 28, e
16 1979?
17 A No. ~
4 s
18 Q Do you know, as you sit'here today, 19 whether there is any. specific procedure that 20 was in effect at Three Mile Island Unit 2 on
. 21 the day o f the accident which the. operators i 22 did not follow correctly?-
23 MR. KOLB: You are asking- for
T 24 his personal verification as opposed
-[Q 25 to his understanding? Or are you asking -
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339 1 Kelly 2 for his understanding?
3 MR. SELTZER: I am asking fo r 4 his knowledge as he sits here today.
l( 5 A If you are asking can I give yo u a 6 specific procedure , title, number o r name ,
7 the answer is no.
8 Q You have never reviewed the 9 procedures that were actually in effect on a
10 that date to determine whether th.e re is a ,
11 specific procedure that was not followed on 12 the day o f the accident, is that right?
4 C- 13 A I have never personally done that, 14 that is right.
15 Q Did yo u o r Don Hallman make any 16 comment or response to the statemen that 17 you have j ust attributed to Frank? ,
i 18 MR. KOLB: - Which stateme'nt?
10 Q That it wouldn't have made any 20 difference because the operators didn't follow 21 some unspecified procedure any way.
22 MR. KOLB: I object as to form.
23 Q Do y u know what. statement by f~N 24 Frank I am referring to at your June meeting?
\~
25 MR. KOLB: That is not my objection.
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340 1 Kelly 2 MR. SELTZER: I know.
, 3 A Yes, I know what statement you are talking 4 about.
-( 5 Q Did anybody make any response or 6 comment after F. rank had made his statement?
7 I will take.it seriatim.
l 8 Did you make any comment or 9 response that you can recall?
10 A I don' t remembe r any spe cific wo rds , no.
11 Q Do you remember the substance of 12 any words that you said in comment or response?
O' 13 A I remember agreeing with Frank.
14 Q Orally? You made a statement l 15 of assent?
16 A I don' t remember that.
17 Q Did Don Hallman make [ny statement i
18 or comment?
- 19 A I don't ree. ember that.
i 20 Q Would you turn to page 38 of i 21 GPU Exhibit 150, your testimony on July 7.
4 (2
22 Do you see in the niddle of the i
23 page where you are asked the question,'"Since
() 24 the 28th of March"?
- 25. A Yes.
-_ ____ , ....._J. . - - ~ . . . - - . - . _ _. . _ . _ . _ . . . _ - . . . . . . - . _ . _ . _ _ , _ _ _ , . . ., ,,,
l 341 1 Kelly U-,
2 Q You were asked, "Since the 28th !
1 3 of March, have you asked Karrasch about the 4 memo that Walters had been referring to?
( 5 " ANSWER: Yes.
6 " QUESTION: Tell me about that.
7 What did you ask him?
8 " A'NSWER : That was after I saw 9 this memo and I saw this memo after talking 10 to Do n Hallman , and I am talking ybout early 11 June 1979, and I don't remember the exact 12 date when Hallman showed.it-to me, and I was i '-
13 walking back t'o my desk af ter having talked l 14 to Hallman and ran into Bruce in the hall, and 15 I said -- this memo had been promulgated and 16 I asked Bruce what happened to it and if he.had 17 any knowledge o f it. " _
18 MR. KOLB: He said, "Wh t had 19 happened to it."
20 Q "He just laughed and said he 21 di dn ' t remember. He had not read it and 22 he had just said that. Do you know what I am 23 saying? I didn't wave it in front of him and l\_-) 24 s'ay what had happened to the memo, but I asked 25 if he had read the memo or whether Hallman had
342 1 Kelly O
2 asked you to resolve this high pressure 3 injection problem last August, and I hadn't 4 seen any more of it since, and Bruce didn't
( 5 say any more about it.
6 " QUESTION: Did he respond to 7 your ques tion?
8 " ANSWER: He di dn ' t say and I am 9 not sure if I am quoting correctly when I say 10 he didn't remember. I am not sure of any 11 response other than just indicating tha t he 12 didn't remember, and it may have been a shrug
(~h
\2 l 13 o f the shoulders or something. "
14 Where you asked those questions 15 and did you give those answers?
16 A Yes.
17 Q Were you tes tifying, then, to the 18 best of your recollection of this ibeident 19 where you ran into Bruce Karrasch in'the 20 hall . followin g a June meeting with Do n Hallman?
21 A Yes.
22 Q It was your recollection, then, 25 that Bruce Karrasch had laughed when you asked
[)
N._--
24 him abo ut the August 1978 memo, is that right?
25 MR..KOLB: Do you mean by that 1
l l
343 1 Kelly s
~ '
2 question that is all he di d?
3 MR. SELTZER: No.
4 MR. KOLB: But that is something
( 5 he did?
6 MR. SELTZER: Yes.
7, A Apparently that was my recollection.
8 That is what I said. es.
9 Q What, if any, other conversations
- 10 have you had with people since the Three Mile 11 Island accident regarding the fact that the 12 issues raised in th e s e rie s o f me mo s on
{T'- 13 inapp rop riate termination of high pressure 14 injection were no t resolved be fore the 15 Three Mile Island accident?
16 MR. KOLB: This is all apart 17 f rom couns el? _
18 MR. SELTZER: -Right.
19 Q You have testified already in this 20 deposition about a meeting with Frank and Don 21 in June 1979. You have tes tified to two 22 conversations with Bruce Karrasch.
23 Have you had any other conversations em
( ) 24 with anybo dy about the fact tha t the issues s_/
25 raised in these memos on operator termination
344 1 ,
Kelly
() ~ \
\)
? were not re so lve d i ^2 of high pressure injection
, 3, .
be fo re the Three Miled Island accident?
. \
x4 MR.h KOLB: Objection as to form.
's' ,' .
\
(r ,
g5 MR.(SELTZER: What is fo rmally
', i 6 wrong? , -
s - ,
7 \
- MR. KOLB
- I am not sure, in fact, t , ,
s .
,8 there )i vore i two conversations with Bruce 1 r., c 9 Karrasch. I am not questioning that 10 you may be 'r'easonable in your thinking g .
11 but I amgnot sure of that.
A 1, '
r
. , s 12 '
't M R.i d, FLT ZE R : He te.3 ti fi ed tha t i \ s ,
13 he saw Bruce 'for the firc e time just
/
i T ,
L, 4 '14 af ter he walked out of the June, meeting
, .s
-)
2 j J; -- 15 ' kand then he told the examiners that
.q, 'e ,.
16 between his July 7 deposition testimony 17 and his July 13 deposition tes timony
,1 18 i N he also spoke with Bruce.
,, s -
19 ' '
MR. KOLB: I think the question is 30 whether or not the prior te s timo ny
(; 21 accurately reflects what happened or not.
L .,
22 I i'm not saying you are wrong. What I am
\
23 saying is since we are dwelling very -)
plf g 24 heavily on individual conversations,-it-M 25 -
is good not to assume thingswhicheverk y '
345 1 Kelly I
%/
2 way it turns out. I think we o ugh t 3 to be as clear as we can.
I- 4 Q You spoke with Bruce Karrasch
( 5 twice, once after the June meeting with 6 Don Hallman and Frank Walters and again after 7 Bruce returned from vacation and you told him 8 about your tes timony in the July 7 session $
9 A Yes.
10 MR. SELTZER: Do you ygree, 11 there were two co nve rs a tio ns now?
12 MR. KOLB: I think the witness b(~\ 13 is the person who has to tell you what 14 the facts are. I want to be certain 15 we do n ' t slip over things and assume 16 things when we are not sure what the 17 facts are. '.
18 Q What, i f an,y , other conve rs atio ns
~
19 did you have with people about the apparent 20 failure to resolve the issues raised in these
-- 21 operator termination of high pressure injection 22 memos?
23 A We talked yesterday about my conversation (rx) 24 w'ith John MacMillan also.
25 Q Did you ever dis cus s it with
f 346 1 Kelly
[
. %J 2 John MacMillan at any other occasion than 3 that one quarter of an hour session in your 4 o f fice ?
(} 5 A No.
l 6 Q Did you and Eric Swanson ever 7 discuss it?.
8 A Yes, just recently. I g Q When?
10 A About two weeks ago. t l ,
11 Q Where?
12 A In my o f fice in Lynchburg.
O
\'
13 Q was anyone else present?
14 A Not that I reme mb e r.
15 Q How long did you discuss it?
16 A Sixty seconds.
17 Q What did you say to him.and what 18 did he say to you?
19 A Paraphrasing, I asked him if he thought 20 my original prescription was any good. Let 21 me --
if he thought it was still good today (w
22 based on what he knows today as opposed to my 23 original issue in 1977 is what I meant.
( g4 I didn't use all those words.
25 I asked him abo ut did he still think my
347 i Kelly
/7-
\_) 2 pres cription was valid. Eric responded that, 3 yes, it was still very good.
4 Q By " valid" a nd " ve ry goo d , " do you
( 5 understand or do you mean those words to 6 express the thought that those p ro ce dures 7 that you were recommending were the correct 8 procedures to follow with regard to operation 9 of high pressure injection?
10 MR. KOLB: When you say "the 11 correct," you mean the only correct i 12 or just would have been correct?
/"
V} 13 Q Were correct procedures for the 14 operation o f high pressure injection.
15 A Not exactly. He meant that they could 16 still be improved on. That they weren't all 17 inclusi ve but as far as they went, they were 18 in the ri ght direction.
19 Q Why did you ask him that question?
20 A I knew I was coming here to give a 21 deposition. Physically, Eric sits in the cube 22 next to mine. I was just-philosophizing.
4 23 Q Did you discuss anything else
() 24 w'i th Eric Swanson abo ut . the fa ct that B&W had 25 not sent out your pres'cription or Dunn's i
348 1 Kelly 2 prescription or the substance o f ei the r o f 3 those prescriptions.
4 MR. KOLB: Objection to the form.
( 5 A Not that I remember.
6 Q You never have discussed that 7 with him?
8 A No.
9 Q Have you ever chatted with Bert Dunn 10 about the failure o f B &W to co mmdni cate the 11 substance of either his memos or your memos l
12 on the subject of operator interruption of 13 high pressure inj ection?
14 MR. KOLB: Objection as to fo rm, 15 because you use the word " failure."
16 Do you mean, di d no t communicate 17 or do you mean something more than that 18 by the word " failure"?
19 MR. SELTZER: I mean the fact 20 that B&W never sent out the co mmuni ca tio n .
21 A Not that I remember, 22 Q Have you ever said a single word 23 or syllable to Mr. Dunn about that subject?
(O)'
24 A' Not that I remember, 25 Q With whom, if anyone, else have
I 349 1 Kelly
-s 2 you discussed the failure of B &W to communicate 3 the substance of either your memo or Bert 4 Dunn's instructions?
( 5 MR. KOLB: Same objection, because 6 of the use of the word " failure."
7 Are you using it in the same 4
8 sense that you j ust indicated a moment 9 ago?
10 MR. SELTZER: Yes. !
11 A None others that I can remember.
12 Q Have you ever talked with anybody
}
13 outside the company about the fact that B&W 14 failed to communicate the substance of your 15 prescription or Dunn's prescriptions before 16 the Three Mile Island accident?
17 MR. KOLB: Same objection.
18 You are continuing to uhe the
~
19 word " failure" to mean the same thing?
20 MR. SELTZER: I do n ' t have such 21- a vast lexicon in my mind that wo rds 22 become chameleons and change their 23 meaning from question to question.
(
E)h 24 I think it is fair to assume if 25 I told you what I mean by failure, it T - ^ "
e-v --71 y -
w w r 7 Yer-
350 1 Kelly 2 means that.
3 MR. KOLB: So the answer, the 4 simple answer to the que stion without
( 5 the speech is that you are using it 6 in the same sense as you used it in 7 the prior questions?
8 MR. SELTZER: Yes. 'I am trying 9 to forestall the repeated in terruption
( 10 by you once I have told youT,what I mean 11 by the wo rd " failure . "
, 12 MR. KOLB:- You could use simpler 13 words that do n' t carry implications, 14 and then we won' t have these 15 , p roblems . _. - -
16 A I do n' t remember talking to anybo dy 17 outside the company. .
18 Q In saying that, you were intentionally 19 omitting or unintentionally omitting the sworn 20 testimony which you have given in which you 21 discussed that failure to communicate, is that 22 right?
23 - MR. KOLB: Same objection.
( 24 Do you understand his question?
25 THE WITNESS: I understand the question.
_. _ m .
351 1 Kelly O 2 Q I don't mean to be cute about it.
3 It is a fact, isn't it, that you have given 4 sworn testimony about the failure of B&W to
(' 5 communicate the substance of your memo or 6 Bert Dunn's memo to operating utilities before 7 the Three Mile Icland accident, isn't that 8 correct?
9 MR. KOLB: Same objection.
10 A Maybe if you show me some df it, I 11 would remember an example.
12 Q Page 44 of the fi rs t day of
~
13 testimony before the Kemeny Commission Staff, 14 GPU Exhibit 150.
I 15 Do yo u s ee where you were asked 16 at line 17, "To the best o f your knowledge ,
17 was the s ub s tance of either your memo or 18 Bert Dunn's memos communicated to t e
- 19 operating utilities using B&W's steam supply 20 systems be fo re March 29, 19797 l
21 " ANSWER: No."
u ;
22 A Yes.
23 Q Does that refresh your recollection
() 2 th a t you did give testimony about the fact 25 that B&W had failed to communicate the substance
352 1 Kelly
/~T V 2 o f either your memo or Bert Dunn's menos?
3 MR. KOLB: Would you point the 4 world " failure" out to us in the
( $ testimony? I would like you to do that 6 so the witness has the full testimony 7 before him.
8 MR. SELTZER: I mean this testimony
, 9 right here.
10 MR. KOLB: Just that question and 11 that answer?
12 MR. SELTZER: Right.
(
'~' 13 MR. KOLB: Objection as to fo rm.
14 The te s timo ny does not include the 15 word " failure."
16 MR. SELTZER: Do you want to 17 swear in Mr. Kolb because he is te s ti fyi ng 18 now instead of the witness. $ think it 19 demeans Mr. Kelly for you to ie chiming 20 in so frequently now.
21 For the first two days, he has done 22 very well te s ti fyin g . Suddenly, to day 23 I think we are getting almost as much r\
() 24 transcript verbiage from you as we are 25 from the witness.
s -~ m y e e,y w- p ~ v -----n- y w y qrwe -m-e- p-y -(
_ - _ . .-. - __ ~ _ _.
353 1 Kelly 2 MR. KOLB: I think you are 3 unduly sensitive.
1 4 MR. SELTZER: We will weigh
( 5 the pages, yours versus Mr. Kelly's, 6 at the end o f today .
7 BY MR. SELTZER:
8 Q Does what I just read refresh your 9 recollection that on July 7, 1979, you did 10 testify about the failure of B&W Eto co mmunicate 11 ei ther the substance of your memo or the 12 substance of Bert Dunn's memo to operating 13 utilities before the Three Mile Island accident?
l 14 MR. KOLB : The same objection.-
15 The word " failure" does not appear 16 here.
, 17 MR. SELTZER: You may answer the 18 question.
19 Q Do you understand that ihe word 20 " failure" means did not communicate as~I have
, 21 explained previo usly?
kJ 22 A It.is not a question of refreshing my 23 me mo ry . I misunderstood your original question
() 1!4 w' hen you were using the phrase "Did I ever 1!5 ' talk.about B&W, the fact that B &W had faile d b '
e # - - -. > * - . . - - , --,.,r y-- -c- - --- . . , ,, - -,y y --, ,,, . - - ,--
T 354 '
1 Kelly O
V to transmit the messages." My mind was forming 2
3 a concept of " Di d I ever discuss" --
I don't 4 remember those words, the fact that we didn't send these things out. This kind of thing
( 5 6 did no t occur. Come to my mind.
7 I include this with the same kind 8 of testimony as our conversations with Hallman 9 and Walters and Karrasch, and all the things 10 we have been talking about. That.was my 11 hesitancy.
~
12 Q Were there any other conversations
(\-)/ 13 in which the subject o f th e me mo s , the
~
i 14 non-resolution of the memos, the lack of I 15 communication to the utilities on the subject j -
16 o f the memos was dis cus se d?
~
17 A Not that I remember. ,
18 Q What is Bruce Karrasch's position 19 now?
20 A He is a Manager in the Customer Service i
21 DeP a rtmen t.
, 22 Q Is he a Manager of any particular 23 section, unit, group?
() 24 A Yes, but I do n ' t remember the name of it.
25 Q What is the domain of that group.
f 355 1 Kelly f's O 2 A It has a marketing function.
3 Q What, if anything is your understanding 4 as to whether that move by Bruce Karrasch is
( 5 a demotion within the B&W organization?
6 A To me it doe s n' t appear to be a demotion.
7 Q To your knowledge, has Bruce 8 Karrasch ever been criticized for sitting on ,
9 the Hallman memo for five months?
10 MR. KOLB: Obj ection 'to the fo rm.
11 A Not to my knowledge.
12 Q Has Bruch Karrasch ever been praised O 13 for sitting on the Hallman memo for five months?
14 MR. KOLB: Objection to the fo rm.
15 A Again, I can't recall anything like that.
16 Q After John MacMillan came into 17 your office and told you that he bhought it 18 was unfortunate or regretful that B W had not 19 communicated your prescriptions or Dunn's 20 prescriptions, did you discuss with anybody 21 the s ubs tance o f what John MacMillan had said 22 to you?
23 M R. KOLB: Objection to the fo rm.
A 1,) 24 The witness gave testimony yesterday 25 as to what he recalls Mr. MacMillan
N 356 l Kelly O 2 . saying, and I object to your now 3 trying to summarize or characterize 4 that as part of another question.
( 5 MR. SELTZER: I have used the 6 exact wo rds that the witness u's e d 7 yesterday.
8 MR. KOLB: That is your j udgment. ,
9 Whatever the witness said, he said.
10 I simply object to the idea',o f ass uming 11 what he said in your questio n.
12 BY MR. SELTZER:
'O 13 Q Do you think I mischaracterized 14 anything regarding the conversation 15 Mr. MacMillan had with you?
16 but. KOLB: Read back the question.
17 (Record' read by the repo rte r . )
18 A Those two words were in my.pr vious 19 testimony, but there was more than that.
20 I don' t know what " mis cha ra ct e ri z e d" means.
f 21 Q Did the portion that I --
(
22 .MR. KOLB: It means take out of I
23 context. Among other things. '
)
(Gj 4
24 Q Did I mis rep re sen t anything of the 25 conversation that you had with John MacMillan?
1
-- . . - - --- - .--~ _-- -- _ , . - . . . . , -
357 1 Kelly
(
2 A Again, I used those wo rds.
3 Q Did you discuss John MacMillan's 4 words to yo u wi th anybo dy else af ter you
( 5 had that conversation with Mr. MacMillan ?
6 A Not that I remember.
7 Q Have you since run into anybody 8 else at B&W who said John MacMillan stopped 9 in and spoke to them on this same topic?
10 A I don't remember. .
11 Q Are you aware today from any source 12 o th e r than John MacMillan of whom else John
%l 13
~
went in and spoke to about the subject he 14 dis cusse d with you?
15 MR. KOLB: Objection as to fo rm.
16 A John told me that he was going to or he 17 was in the process of speaking to everyone 18 involve d with those memos, but I doe't have 19 any other verification of that that i can 20 remember.
21 Q I take it, you are aware that the re 22 was a transient at a B&W supplied nuclear plant 23 in the Harrisburg area that commenced on the f'j 34 morning of March 28, 1979, is that right?
\_/
25 A Yes.
+- - y iy
358 1
Kelly O 2 (Recess was taken.)
3 Q When did you first hear that a 4 transient had occurred or was occuring at
( 5 Three Mile Island Unit 2 on March 28, 19797 6 A It was on the morning of March 28.
7 Q who firs t advised you?
8 A Bob Winks. -
9 Q Then you went down into the classroom 10 next to the simulator where you were f briefed N
11 by Don Hallman and Bill Spangler regarding 12 wha t they knew of the events that happened
.] 13 at Three Mile Island that morning?
14 A Yes.
15 Q You have tes ti fied previo usly 16 that you went in to see Mr. Spangler and 17 Mr. Hallman at 9:30 that mo rnin g app roxi'ma tely :
18 is 'that still your best recollectio of when 19 you went in to see them?
20 MR. KOLB: I think if you are 21 going to ask a question about prior 22 testimony, you will'have to show us 23 the prior te s timony .
) 24 Q Is it still your recollection that 25 you went to see Mr. Spangler and Mr. Hallman
359 1 Kelly 4
2 at or about 9:30 A.M., March 28, 1979?
3 MR. KOLB: It still implies 4 that was his re collection be fore , so
( 5 I object to the form.
6 A Yes.
7 Q Did you know that Mr. Spangler 8 had been in telephone communication with ,
9 B&W representatives at or near the Three Mile 10 Island plant that morning? t 11 A He said he had been in conversation with 12 them.
13 Q Did he relate to you the data 14 that he had received from his telephone calls 15 with people at or near the plant that morning?
16 A I do n' t remember whether it was Bill 17 Spangler or Don Hallman, but one of them did, 18 yes.
19 Q After talking with Mr. Spangler 20 and Mr. Hallman, did you attend another 21 briefing at Lynchburg?
22 A No, that was the briefing in the classroom 23 beside the simulator with H'allman and Spangler.
1
) 24 Q Were Mr. Spangler and Mr. Hallman 25 just brie fing you, or were they briefing the
360 1 g,yyy 2 twenty-or-so other people who were in that 3 room?
4 A I was just one of several that were
( 5 in the room, yes.
6 Q So they were speaking to all the 7 people who were in the room?
8 A Yes. -
9 Q Is the room where this meeting 10 took place the war room? -
11 MR. KOLB: I object as to form.
12 A No.
O 13 Q The re is a room that was then 14 referre d to as the war room?
15 MR. KOLB: When you say ,"then,"
16 what point in time are you referring to?
17 This time when there was this ~ meeting 18 you were asking about?
19 MR. SELTZER: Yes.
20 MR. KOLB: At that particular point 21 in time, was there a thing called the 22 war room, is that your ques tion? -
23 MR. SELTZER: You couldn't be more
) 24 on target.
25 MR. KOLB: Thank you very much. {
i 361 1 Kelly 2 Q I don't mean that it was on the 3 door written " War Room," but colloquially, 4 people at B&W referred to a room as war room.
( 5 A Did they do this in March 1979?
6 Q At or about that time, was there 7 a room being referred to as the war room?
8 A I do n' t re me mb e r . .
9 Q Has there ever been a room that 10 has been referred to as the war r'com?
11 A Yes.
12 Q Was that a room that was used as 13 a command post or communications center when 14 there were site emergencies?
15 A That is the room -- the room was used 16 that way during the Three Mile Island transient.
17 Q Is that the room whe re you had 18 the morning brie fing on the dayofbhe transient?
19 A No.
i 20 Q So it was later in the day that l ,
21 that room became the command center, is that t
( 22 right?
l 23 A I don't know, j 24 Q When you say ' the room was used that 25 way on the day of the accident, what room were
362 1 Kelly G
V you referring to?
3 Were you referring to the 3 room where you got the brie fing that morning?
4 A I was briefed in a classroom next to l 5 the simula to r. The Project Con trol Center 6 is on the second floor. That is not where 7 the brie fing was.
8 Q Was the P roj e ct Control Center ,
9 used during the day o.f March 28, 1979 to be 10 a comnand center fo r receipt o f i'nforma tion 11 relating to the Three Mile Island accident?
12 A I do n' t know when they started using 4
13 it that way.
14 Q But at some point during the 15 accident, it was being used that way?
16 A When I use the term " transient," I was 17 re ferring to any time between Marbh.28 and 18 when I s ubs eq uen tly returned from Tbree Mile 19 Island. Then it was being used as a command 20 Post.
21 Q Is the training room where you 22 and some twenty others were briefed the only 23 room at Old Forest Road' that you were in that O)
( 24 day?
25 MR. KOLB: Objection to the form.
. . _ - ._- . - - _ _ . _ _ . _ _ = _ _ -
363 1 Kelly
, 2 Yo u said " twenty others" now a co uple 3 o f times , and the witness di dn ' t 4 affirm twenty in his tes timony this
( 5 morning.
6 Q There were abo ut twenty people who 7 had come into the room where you received your 1
8 brie fing the mo rning o f the accident, isn't .
9 that right?
10 A There were several people.E,There co ul d 11 have been as many as twenty, yes.
. 12 Is that the only room in which you Q
O 13 transacted any business or did any work at 14 Old Forrest Road that day?
15 Let me limit it to transact any 16 business or do any work with regard to the 17 Three Mile Island events. . .
18 A Yes.
19 Q Are there blackboards in that room?
20 were there blackboards in that room on that 21 day?
22 MR. KOLB: The question is as of a
23 that day.
(~)
(y 24 A Yes.
25 Q Had anybody copied onto any
364 1 Kelly O 2 blackboard in that room any of the data 3 relating to Three Mile Island plant?
4 A Yes.
( 5 Q was the information that 6 Mr. Spangler or Mr. Hallman were relating 7 at the briefing also written on the blackboard?
8 MR. KOLB: All of it? ,
9 Q All of it that you can remember.
10 The question is, you 'have said 11 Mr. Hallman and Mr. Spangler, both of them, 12 were briefing you and the others in the room, O 13 right? ,
14 A Yes.
15 Q They were briefing you about data 16 and events that they had heard reported from 17 Three Mile Island that day, right? -
18 A Ri gh t .
19 Q was that data and those events 20 repeated in writing on the blackboard?
21 A In summary form, yes.
22 Q Whom else do you recall being in .
23 the room that morning besides you, Mr. Spangler, 24 and Mr. Hallman?
25 A Bob Twilley, Bob Winks. I don't
__ -____-u . . _ _ _ _ _ _ _ _ _ _ - . _ _ _ _ _ _ _
f 365 1 Kelly A
2 specifically recall anybody else now.
3 Q Was Eric Swansen there?
4 A I do n ' t reme mb e r.
I 5 Q Was Dr. Womack there?
6 A I don't remember.
7 Q How would you characterize the type 8 of people who were in the room at that time? .
9 MR. KOLB: Could you be a little i 10 more explicit in what you mean by 11 " type of people"?
12 Q Just as you characterized the 13 people who attended your Training Room B 14 P res en tatio n , how would you characterize these 15 people?
16 A Spangler and Hallman were Managers.
~
17 Twilley, Winks and myself were people picked l 18
- to go to Three Mile Island. I do n' t remember 19 who else was there, so it is hard for me to 20 characterize it.
21 Q By 10:30, you, Twilley and Winks 22 had been told to go home and pack your bagc 23 and get up to Three Mile Island, is that right?
O) 24 A It was about 10:30, yes.
25 Q Who was in charge of the show in
366 1 Kelly 2 the room where you got the brie fin g ?
3 , MR. KOLB: Objection as to 4 form. Specifically to the word "show."
5 A To the be s t o f my recollection, both t
l 6 Hallman and Spangler were co-chairmen of the 7 meeting.
8 Q Did anybody else address the people -
9 in the room, and by " address," did anybody 10 else speak up talking to everybody else in 11 the room other than Mr. Spangler and Mr. Hallman?
12 A I don't remember.
13 Q Did you leave th e room at or about 14 10:30 A.M.?
15 A Yes.
16 Q Did you then proceed home to pack 17 and get out to the airpo rt? -
18 A Not directly, but, yes, eventually.
.. i 19 Q Did you talk to anybody else other 20 - than Mr. Winks and Mr. Twilley about the Three
_ 21 Mile Island accident between the time you left 22 the training room and the time you went home 23 to pack and go to the airport?
24 A I do n' t remember.
25 Q Did anybody say before ' yo u le f t
?
367 1 Kelly r'
2 Old Forrest Road, the B&W headquarters thL2 3 morning, to you or in your presence that it 4 looks like this Three Mile Island plant is
( 5 in serio us danger of uncovering its core?
6 A No.
7 Q Nobody s ai d tha t to you in words 8 or substance or said it in your presence? -
9 A Not that I remember.
10 Q Did you hear anyone say this plant
! 11 has suffered or is in the midst of suffering i
12 a serious loss of coolant accident?
13 Did they say that in.words or 14 substance?
15 MR. KOLB: Do you have the time 16 frame in mind?
17 THE WITNESS: He is still talking 18 about the morning before I le t. I assume 19 he means during the brie fing also.
20 A I do n' t remember that.
21 Q Did anybody say in words or 22 substance that you heard that morning this 23 plant has hit saturation, there is boiling
(_jI 24 in the reactor coolant system?
25 MR. KOLB: The same time frame.
, . _ - _ _ .~.
368 1 Kelly O
kJ 2 You said this morning. At morning.
3 I want to be sure we are talking up 4 to the point where he was at the
( 5 airport.
6 MR. SELTZER: Right.
7 A I don't remember that.
8 Q Did anybody indicate that they ,
9 recognized that there had been boiling or 10 saturation in the reactor coo lan t: system 11 at Three Mile Island that mo rning?
' 12 A Not that I remember.
13 Q When is the first time that you 14 recognized that there was serious danger of 15 co re un cove ry o r se rio us danger that the core 16 had already been uncovered at Three Mile Island?
17 A I don't remember. .
18 Q Was it sometime in the afternoon 19 af ter you arrived in the Harrisburg area?
20 A No.
21 Q When approximately was it?
22 A During the next couple of days when M I was on site.
b) 24 Q So at no time during March 28, 1979 25 did you either know that the' core had been
369 1 Kelly
~
d(~x 2 uncovered or have a belief that there was 3 a danger that the core had uncovered or could 4 uncover, is that righ t?
( 5 MR. KOLB: This is Mr. Kelly 6 personally, right?
7 MR. SELTZER: Yes.
8 A Not that I remember. ,
{
9 Q Did anyone tell you or say in !
10 your presence during the day of dhe accident 11 that they believed that the co re had uncovered 12 or that there was a danger of the core uncovering?
(D
~
13 A Not that I remember. .
14 (Whe re upon , at this time in the 15 p ro cee di n gs , Mr. David Taylor entered 16 the hearing room.)
1, 17 Q Do you know what the expression 18 " deja vu" means?
19 A A feeling of having been the re b e fo re .
20 Q Did you get a senso at any. time 21 during March 28 of deja vu based on your 22 Davis-Besse experience?
23 A Not that I remember.
i j 24 Q Prior to Three Mile Island's ,
25 accident, was Davis-Besse the only other 7 ,_ , - . - - 4 we
370 1 Kelly O 2 B&W experience you had had with the pressurizer 3 going solid?
4 MR. KOLB: Could I hear the
( 5 q ue s tio n .
l G Q Prior to Three Mile Island's 7 accident, was Davis-Besse the only other 8 B&W experiencs you had had with the pressurizer 9 going solid?
10 MR. KOLB: Objectiontto the fo rm.
11 Q Do you understand the question?
12 A Yes.
I 13 No, I conducted a few hydrostatic 1
14 tests of other B&W plants.
15 Q Hydrostatic tests are run be fo re 16 fuel is loaded, is that correct?
)
~
17 A Yes. {
l 18 Q So the reactor is not c$1tical.
~
19 The plant is not generating heat from a nuclear 20 core. It is not generating electricity yet, 21 right7
~
22 s
. A Right.
23 Q I am talking _about after a plant I~ i 24 has been . loaded with fuel' and has begun to
\_J -t <
25 generate thermal power from the core.
at:
1 Kelly
[
\ Had you ever had any experience 2 ,
3 ther than the Davis-Besse September 19, 1977 ,
4 transient in which a pressurizer had filled '
<\~';
( 5 completely with water or to use the phrase that s i 6 has become so current in this case, gone solid?
7 MR. KOLB: Objection to the form.
8 A No.
9 Q Other than the Davis-Besse transien't 10 in September 1977, had you ever had any 11 experience at B&W with a plant that had gone
- 12 critical blowing its reactor coolant drain tank gm .,
g,
(- 13 rupture disk? '
14 A I had heard about an incident like that,
~,
/
15 yes. -
16 Q Where had that incident occurred? ,
s 17 A' One of the Duke Powe r Oconee , Uni ts .
18 Q You pr++,cusly testified that
~
19 the re are onif .2ra valves which vent steam 20 or liquid water into the reactor coolant drain s
- 21 tank, namely, the two ASME code safety valves I
22 and the pilot operated relief va)ve on the top-
, y "'t 23 of the pressurizer.
47' -
24 At the Oconee plant, which valve
- {a~}l ,,
7
,y. ,
.25 had vented water to cause the rup ture disk to i j i
m ..j e ,
s i
e ,
s
\ 372 1 Kelly ,
/x ,
I ) !' ,
sm/ .
2 blow? ,
3 s 11 R . KOLB: Objection to the form.
\ 4 s A When we talked about tha t be fore , we
( _\ O were talking about the Crystal Rive r plan t '
6 specifically. There were other combinations 7- of di f fe rent plants , but I don't know which s 8 one failed at the Oconea Unit. Even if it was
\ s .
' ~
9 one of those three. I don't know. It co uld 10 have been others. '
't 11 Q Do you have any information that 12 the Oconee Uni t . to which yo u w e're < re fe rring
( ) A t s
\# 13 vents anything else other than the three valves 14 I have described into its reactor coolant drain 15 tank?
16 A No.
17 Q Is it'your understanding that it
~ ' .
18 is one of those three valves that vented into 19 the reactor coolant drain tank at the Oconee
.20 Unit?
L l ,
',7 I do n' t reme mb e r.
- A 21 l- (
22 Q Had -you heard about that be fo re 23 the Three Mile Island accident?
~
n i
I 24 A Yns.
25 Q How had-you heard about i t?
1 373 1 Kelly O
O' 2 A So me o n e told me.
3 Q What does the ph ra s e " primary 4 Pressure boundary" mean to you?
('
5 A It is the pipes and valves that contain 6 the reactor coolant.
7 Q In order fo r reactor coolant to 8 get into the reactor coolant drain tank at 9 a B &W plant, there has to be an opening in 10 the primary pressure boundary somewhere, right?
11 A Yes.
12 Q So there has to be a loss of
13 coolant from the reactor coolant ' system for 1
14 there to be a rup tu re disk blowing on the reactor 4
15 coolant drain tank, right?
I .
16 A To my knowledge, yes.
17 Q so the popping of the rupture disk 18 at the Oconee plant followed a loss of coolant 19 transie r t or loss of coolant a cci de n't at.
20 the Oconee plant, righ t?
, , 21 MR. KOLB: I think the witness L
22 had indicated the extent of his 23 knowledge doesn't permit him to
- [J.) 24 answer that que s tion , and what you are
' 25 asking him to do is deduce what occurred.
., , -. . . , - , ..- . -- =. - - . - - . , . -- - . .
- u.
374 1 Kelly 2 I think he can answer only to 3 the extent o f his actual knowledge.
4 I don't mind asking the question to
( 5 probe if he knows. If'he do e s n ' t know, 6 I think he should say so.
7 MR. SELTZER: I am entitled to 8 what he understands based on his .
9 experience at B&W.
10 MR. KOLB: You are entitled to 11 his knowledga 2: the occurrence. If 12 that knowledge comes from one source 13 or another, he can tell you, but you 14 are only entitled to what he knows about 15 the occurrence and nothing more than
.j 16 that.
17 Do you understand? ,
18 THE WITNESS: Yes.
19 (Record read by the reporter 20 as follows: "Q ASTION: So the popping 21 of the rupture disk at the Oconee plant 22 followed a loss of coolant transient 23 or loss of coolant accident at the b)
V 24 Oconee plant, right?")
25 A There must have been some kind of loss
t 375 1 Kelly
(~)
\.J 2 of coolant accident, yes.
3 Q Prior to the Three Mile Island 4 accident, had you heard in your B&W experience
( 5 of any other occasion on which a B &W designed 6 plant had had its rupture disk blown?
7 A I don' t remember any others.
8 Q So the only two occasions were the .
9 Oconee plant and the Davis-Besse plant, right?
10 A Yes. E 11 Q On both of those occasions, the 12 rupture disk had blown as a result of a loss 3
(O 13 o f coolant accident, right? .
14 MR. KOLB: You are now asking 15 him if he can confirm that positively.
16 Q That is your understanding, isn't 17 that right? -
18 A Yes.
19 Q Have you learned since he Three 20' Mile Island accident that the.Oconee transient 21 to which you have been referring was a transient 22 caused by a stuck open pilot operated relief 23 valve?
l
()
w- 24 A Not th a t I remember.
[ 25 Q You think you are h earing that fo r i
376 1 Kelly
~
2 the first time today?
3 A Are you telling me that is a fact?
4 Q Yes.
A That is the first time I have heard
( 5 6 that, that I can remember, yes.
7 Q During the Davis-Becse transient 8 in S ep te mb e r 1977, you testified that the 9 rupture disk blew and that released water 10 that then flowed into the containment Building 11 sump.
12 Was that water radioactivated?
13 A It contained radioactive materials, yes.
14 Q As one of the world's experts on 15 the Davis-Besse sequence of events, do you 16 know whether radiation monitors in the Davis-17 Besse Containment Building picked'up any rise 18 in containment radioactivity?
19 MR. KOLB: Objection to the fo rm, 20 sp e ci fic ally to the phrase "one o f the 21 world's experts."
22 MR. SELTZER: I think I said 23 " leading experts."
). 24 MR. KOLB: Objection to the " leading" 25 _
as well.
l
377 1 Kelly frg -
2 Why not just ask the questions 3 as factual questions instead of using 4 all those colorful words.
( 5 A I don' t remember anything about the 6 radiation monitors at Davis-Besse.
7 (Recess taken.)
8 Q When for the first time did you .
9 realize that there had been a loss o f coolant 10 accident at Three Mile Island? t 11 A- The evening o f the day after the accident.
12 Q On the day of the accident, O
13 March 28, 1979, did you hear anybody say in
]
14 wo r ds or substance that they thought there 15 had been a loss of coolant acci de nt at Three 16 Mile Island, or that there was a loss of 17 coolant ~ accident in progress at Three Mile 18 Island?
19 MR. KOLB: Daylight hours?
20 MR. SELTZER: No. Up through 21 midnight the 28th.
22 A Not that I can remember.
23 Q Did you take any notes of the
[)
%., 24 briefing in the training room the morning of 25 the accident?
_ i
378 1 Kelly n
(v) A Not that I remember.
2 3 Q Did Mr. Winks or Mr. Twilley take 4 any notes?
( 5 A I don' t know.
6 Q Going up on the chartered plane 7 later that day, did yo u, Mr. Winks and 8 Mr. Twilley exchange any written notes that 9 you had on the accident?
- 10 A No. t 11 Q Did you discuss with them the 12 information that you had received that morning?
13 A Yes.
14 Q Since the day of the accident,'
15 have you ever seen any notes or copies of 16 notes made by anybody of information that 17 had been received at Old Forrest Road about 18 the Three Mile Island accident? Let me try 19 it again.
20 Are you aware today that theru j 21 were people who were making notes in Lynchburg 1
22 of the data that was being received from the 23 Three Mile Island plant on the day o f the
-m()) 24 a'e ci de n t?
25 A I don't remember seeing any such notes.
I 379 1 Kelly D
hI 2 Q Right up to today, you don't 3 think you have ever seen anybody's notes 4 of information that was being received the
( 5 day of the accident?
6 A In Lynchburg?
7 Q Right.
8 A No.
9 Q When you got to Pennsylvania, did 10 anybody show vau notes that they I had of data 11 received from the plant that day?
12 A Yes,
^T i
[b 13 Q Whose no tes did you see?
14 A Greg Schaedel.
15 Q Had Greg logged in the information 16 showing the time of the day in which he 17 received it? .
18 A I don't remember.
~
10 Q Were these handwritten notes?
20 A Yes.
21 Q Were they written into a notebook?
(
22 A N o ,.
23 Q on what were they written? I
(~jN 24 A' They were written on the back of an 25 envelope that you would use in-the mail, an
380 1 Kelly b(% 2 envelope that would be about 18 inches by 3 12 inches.
4 Q Did Greg Schaedel copy his notes
( 5 onto something more conventional?
6 A I do n' t know.
7 Q Do you know whether that envelope
^
8 has been preserved?
9 A~ I don't know.
10 Q Have you seen that envelope 11 and Mr. Schaedel's notes since the day of 12 the accident?
' O' 13 A No.
14 Q Have you seen any sequence of 15 e ven ts or reflection of data prepared by 16 Mr. Schaedel from those no tes ?
17 A Not that I remember. .,
18 Q Have you seen any description of
~
19 the accident that was prepared with the 20 assistance o f those notes?
21 A Not that I was aware that his notes 22 we re involved in the preparation o f the 23 sequence o f events.
. ()
x-24 Q Did Mr. Schaedel's notes include 25 the information which you had been given at 4
381 1 Kelly O 2 the briefing in Lynchburg on the morning of 3 March 287 4 A I don't remember.
( 5 Q What did you understand was the 6 source of Mr. Schaedel's information?
7 A To my understanding, he was getting his 8 in fo rma tio n from Lee Rogers.
9 Q Where was Lee when he was transmitting 10 that i n fo rma ti on ? (
11 A He was on Three Mile Island.
12 Q In the control room?
O 13 A Yes, that-is my un de rs t a n di_ ng .
14 Q Have you been in the Three Mile 15 Island Unit 2 control room?
16 A Yes.
17 Q Did you speak with Mr. Ro ge rs 18 du ring the week of the accident?
10 A Yes.
20 Q Is it your unde rstanding that
~
21 Mr. Ro ge rs had access to all of the data that 22 could be re ad f rom charts , p rin to ut s , and 23 instruments in the co ntrol room on the day 24 o'f the accident?
- 25. MR. KOLB: I take it when you
-- . _ . - . _ - ~ _
.f 382 1 Kelly (j
u 2 re fe r to " instruments," you are 3 re ferring to some instrument as to which 4 the readings we re preserved?
( 5 You shook your head.
6 MR. SELTZER: I wasn't limiting 7 it to that. I also included an 8 instrument that you co uld walk up to 9 and see a current reading.
10 MR. KOLB: But you wd,uld only 11 be talking about a current reading?
12 MR. SELTZER: For that particular O 13 instrument, yes. That is why I had 14 charts which would preserve a reading 15 and instruments which may or may not 16 preserve a reading.
17 A I assume all that information was 18 available to him.
19 Q How early in the day did Mr. Ro gers 20 get onto the island, to your knowledge?
21 A I do n' t k no w .
22 Q What does the acronym "SOM" mean?
23 A My usage, that would be site operations
() 24 manager.
25 Q To the best of your knowledge,
383 1 Kelly
/~S ~
(_,/ '
2 was Mr. Roge rs on the island sometime during 3 the morning of March 28, 1979?
4 A Yes.
( 5 Q Yo u j us t don't know how early 4
6 in the morning?
7 A Yes.
8 Q Do you believe he was there by the 9 time you got the briefing in Lynchburg?
10 A I don' t know. I 11 Q Let me tell you what I am going 12- to be asking you about. I want to find out i
I '~'
13 how Lynchburg was getting information from 14 the Three Mile Island control, room,'and I am 15 trying to find out whether Lee Rogers 16 was calling the Lynchburg people directly 17 or whether Mr. Rogers was calling Mr. Schaedel, 18 and Mr. Schaedel was passing the i nforma tio n 19 on to Lynchburg the morning and earlh af ternoon 20 on-March 28, 1979.
21 could you tell me what your 4
22 understanding is of how Lynchburg was ge tti ng 23 in fo rma tion ?
() 24 - A' Greg told us that he was getting calls 25 from Lee Rogers. Lee would give him a current
- - - ,- ~ , - .,- -- n ,
384 1 Kelly 2 status, and then Greg would call Lynchburg 3 and relay the information. He was acting 4 as an intermediary.
( 5 Q It sounds pretty sloppy for 6 Mr. Schaedel to be copying the in fo rma tio n 7 tha t he was getting from Mr. Rogers on the 8 back of an inter-o ffice ' mailing envelope.
9 Was that the only place that 10 he was re co rding the information;that he was 11 getting from Mr. Rogers?
12 MR. KOLB: Objection to the form.
O 13 A I don't know of any other place he was 14 reco rding it.
15 Q Is this an inter-office mailing 16 envelope that has pe rfo ration s through it to 17 see if there is something inside bhe envelope?
18 A I don' t remember it being an inter-office 19 mailing envelope.
20 Q I thought you said it is the kind f
21 of envelope that is used for mailing things 22 between offices.
23 A I don't think I said "between o f fices . "
24 I'will repeat it. It was j us t a manila 25 envelope that you would mail something in-in I
e , , , , , . - , , - n , - ,,, - ~ . - ,, , .v -
385 1 Kelly r"N '
2 the United States Post Office.
3 Q so it was an unruled piece of 4 paper with a seam down the back.
l 5 Was he writing on the front or 6 the back or both sides?
7 A I don?t remember.
~
8 Q Did he run out of room on the 9 front and back and open it up and start 10 writing on the inside? t 4
11 A I don't remember.
12 Q After you arrived, did he continue 13 writing down information that he was getting 14 from the plant on the mailing envelope?
15 A Yes.
16 Q Did Greg have a speaker-phone 17 in his home or office where you were meeting 18 with him?
19 A We were meeting in his home. He had
! 20 no speaker-phone.
21 Q Were you able to get on an 22 extension-phone and - hear any o f the conversations 23 th a t Greg was having that day?
w 24 A' I may have been able to. He may.have 25 had an extension, but I didn't, if that is
,- _ . . ~ .
386 1 Kelly 2 what you are asking.
3 Q Were you sitting in the room 4 listening to Greg's side of the conversation
( 5 as he was talking with the plant and talking 6 with Lynchburg?
7 A I_only heard one side of the c'o n ve r s a tio n .
8 Q After Greg got off the phone with 9 the island, did he make it a practice to-10 call Lynchburg to relay the info rma tion he 11 had gotten from the island?
12 A Yes.
< t'~') 13 Q Did Greg ever discuss with you 4
14 the info rma tion that he was re ceivi'ng from 15 the island?
16 A Yes.
17 Q Did he ever tell you information 18 that he had received from the-islanb which you 19 did not hear him relaying to Lynchburg?
20 A Not that I remember.
21 Q Do you know a chap at B&W who 22 goes by the handle G.K. Uandling, Plant 23 Start Up se rvi ce s ?
1() 24 A' The name sounds f amilia r to me .
25 Q Do you think you would recognize
387 1 Kelly O 2 him if he walked in this room?
3 A Yes.
4 Q Let me show you some notes that k 5 G.K. put together f rom information being 6 received on March 28, 1979. It was previously 4
7 marked GPU Exhibit 138.
s 8 On the second page of Exhibit 138, 9 the first handwritten page, Mr. Wandling 10 notes a tele communication at 7:45 from 11 Lee Ro ge rs to Bill Spangler, and it is 12 described as first report o f incident at O' 13 Three Mile Island 2.
1-4 You have testified that when 15 you were brie fed, Mr. Hallman and Mr. Spangler 16 told you what they knew o f the events that 17 had happened that morning at Three Mile 18 Island. I would like to ask you wh ther you 19 were told in the briefing at LynchbuTrg the 20 morning of the accident about the following 21 things.
, 22 Were you told that there had been l
23 a turbine trip?
'A yl 24 A Yes.
25 Q Were you told there had been a loss
388 1 Kelly O 2 of feedwater transient?
3 A Yes.
4 Q Were you told that there had been L 5 a reactor trip on high pressure?
i 6 A I remember being told of the re ac to r
! 7 trip. I don't recall whether they said it 8 was on high pressure. .
9 Q Do you recall being told that the 10 pressurizer had gone solid and filled 11 completely with water?
12 A No.
C )-
13 Q Under normal opera tio.n, there is 14 an air space or steam space at the top of the 15 pressurizer, right?
16 A -A steam space, right. ,
17 Q Without a break at the top of the i 18 pressurizer, could there ever be enough 19 pressure applied to that steam space to make-20 the pressurizer go solid?
l
-(b' 21 MR. KOLB: Objection as to fo rm.
!. 22 A As the pressure went up , the relief 23 valves wo uld li f t.
\
(0
,,) 24 Q That lifting of the valves would l
25 he a break at the top of the pressurizer, f
l 389 1 Kelly l
2 a break in the primary pressure boundary 3 at the top of the pressurizer?
4 MR. KOLB: When you us e the 5 wo rd " break , " you do n ' t mean the 6 implication there is something wrong?
I 7 Just that there is an opening?
8 M'R . SELTZER: Ri gh t . ,
9 A Yes.
10 Q So in order fo r the p'ress urizer 11 to go solid, there has to be an opening at 12 the top o f the press urizer,' right?
O 13 A You could go. solid on a series of.
14 lifting and resetting of the pressurizer 15 relief valves.
16 Q Were you told before you lef t 17 Lynchburg on the morning of the accident that 18 the reactor coolant drain tank rupt re disk 19 had blown?
20 A I don't remember that.
21 Q Were you told that the pilot 22 ope rated relief valve had perhaps failed in 23 the open position?
l 24 A I don' t remember that.
l l 25
I l 390 1 Kelly 2 Q Were you told that there was 3 radiation detected in the dome o f the 4 reactor building?
( 5 A Yes.
6 Q Were you told there was a reading 7 of 800 rems in the Containment Building dome?,
8 A Yes.
9 Q What did you think had caused 10 that release of radiation into the Containment 11 Building, if you had any thoughts about that?
12 A I do n' t remember speculating on that 13 Point.
14 Q Do you remember anybody in the 15 room suggesting what might be the cause of 16 that radiation in the Containment Building?
17 MR. KOLB: When you shy,"in the 18 room," you mean in the room wbere the 19 presentation was made on the Aorning 20 of the accident?
- 21. MR. SELTZER: Exactly.
22 A No.
23 Q 800 rems in the Containment
_() 24 Building dome is not normal operating conditions 25 for a B&W designed plant', is it?
391 1 Kelly O
V 2 A Right. It is not.
3 Q It means something has gone wrong, 4 right?
( 5 A Yes.
6 Q You don' t recall anybody saying 7 in the room that this ra diation in the dome 8 means that there is something seriously wrong ,
9 at Three Mile Island, is that right?
10 MR. KOLB: Are you asking if 11 those words were spoken?
12 MR. SELTZER: Words o r s ubs tance .
13 MR. KOLB: Would you read the 14 question.back.
15 (Record read by the reporter.)
16 Q Do you recall anybody saying at 17 Lynchburg on the morning o f the accident 18 that the indication of high radiatibn in the 19 dome of the Containment Building in[icated 20 that there was something seriously wrong at 21 the Three Mile Island plant?
22 A No.
23 Q Do you recall being told that
() 24 morning before you le f t Lynchburg that there 25 was an indication of f uel failure in the L
392 1 Kelly 2 Three Mile Island Unit 2 Core?
3 A No.
4 Q Do you recall hearing that there
( 5 was or there possibly was a two-phase mixture 6 in the reactor coolant system?
I 7 A No.
8 Q Do you recall hearing that there 9 was or had been boiling or saturation in the 10 reactor coolant system? t 11 A No.
12 Q Did you understand when I asked O 13 you about a two-phase mixture that that meant 14 and would have meant to you on March 28, 1979, 15 that there was both steam and water in the 16 reactor coolant sys tem?
~
17 MR. KOLB: Read that bagk.
18 (Record read by the reporter.)
^
19 A Yes.
20 Q Did you know before you left 21 Lynchburg that the operators had tripped or 22 shut off all of the reactor coolant pumps?
23 A Yes.
( 24 Q Did you know before you lef t 25 Lynchburg whether natural circulation had been
393 1 Kelly i '
1 2 achieved?
3 A I don't recall.
4 Q When you got up to Greg Schaedel's l 5 place, you asked what the primary system 6 pressure and temperature was.
7 Do you recall that?
8 A Yes. '
9 Q If you had gotten the primary 10 system temperature and pressure , twould you 11 have been able to tell at Gre g ' s place 12 whether there was saturation or superheat 13 in the reactor coolant system?
l 14 MR. KOLB: That really is a l 15 hypothe tical que s tion. Under what 16 co ndi tions do you mean?
17 MR. SELTZER: With the knowledge 18 and resources that were at hi5 disposal 19 at Greg's house on March 28, 1'9 7 9 .
20 MR. KOLB: I think to ask him 21 what he might have been able to do if 22 he had info rmation, which he didn't have, 23 is not app rop ri at e .
, 24 Q On March 28, 1979, did you have N-25 the ability to determine whether the reactor
394 1 Kelly
^
2 coolant system was saturated?
3 MR. KOLB: From the data he 4 had available to him?
l 5 MR. SELTZER: No.
6 ,
MR. KOLB: What do you mean?
7 Q If data had been available to you 8 on temperature and pressure in the reactor <
f l 9 coolant system, did you have whatever else 10 it would have taken to know whether that 11 temperature and pressure combination indicated 12 that the reactor coolant system as at O 13 saturation?
i 14 MR. KOLB: When you say "what else,"
15 you mean other data?
16 MR. SELTZER: Maybe it do es n ' t 17 take data. Maybe it just takes being 18 smart.
19 MR. KOLB: Can you answ r that 20 question yes or no?
21 Q. It may depend on whether Greg had 22 a steam table.
23 MR. KOLB: That is the problem O)
( 24 with' a hypothetical.
25 Q I am asking factually, do you know g . . . . . .
395 1 Kelly
/*m k.
2 whether you did have in Greg's house on the 3 afternoon of March 28, 1979, the necessary l
4 -
k nowle dge and resources to determine whether 5 the reactor coolant sys tem in the plant was 6 saturated, if you' had had temperature and .
7 pressure data?
8 A No. -
9 Q No, yo u di dn ' t have the necessary 10 knowledge and resources ? Is thad.what you 11 are saying?
12 A I di d no t have a steam table at Greg's O 13 house.
14 Q You would have needed a steam '
15 table?
16 A Unless the answer were trivial, yes.
17 Q Do you know for a fact that there 18 was not a steam table at Greg's ho us e?
19 A No.
20 Q You didn ' t bring a copy o f the ASME 21- steam tables with you or a copy of Keenan &
l 22 K2yes?
l 23 A No.
j 24 Q Did Mr. Winks or Mr. Twilley have 25 a cop'y of either of those documents?
396 1 Kelly O
V 2 A Not that I remember.
3 Q Would you be able to have 4 recognized superheat based on your knowle dge
( 5 without having a steam table?
6 MR. KOLB: Are you asking 7 whether he had such information 8 available at the house that day to , l 9 recognize s up e rh e a t?
10 MR. SELTZER: Right on target 11 again.
12 A Not accurately, no.
O~ 13 Q What do you mean "not accurately"?
14 A What I mean is if I had combinations 15 of temperature and pressure such that within 16 my knowledge, my mind's knowledge of the 17 steam tables I could recognize it, .then I 18 would know, but if it was the least bit close or confusing to me, I wouldn't know.'
19 20 , Q You had done some work with the 21 steam tables when you were analyzing the 22 , Davis-Besse transient, right? ,
23 A Right.
24 Q At your office in ' Lynchburg or 25 cubical in March 1979, did you have a copy
- - _ . . . . . . . . . . .. _ _ . . =
397 1 Kelly O
' ). 2 of the steam tables?
A No.
3 4 Q Was a copy readily available?
( 5 A Yes.
6 Q Based on the knowledge that you 7 have today, do you know whether the 8 combina tion o f 5 0 0 poun d press ure and 700 9 degrees Fahrenheit is at or above the 10 saturation curve? t 11 A That would indicate superheat to me.
12 Q On March 28, 1979, did you have D
O' 13 a prio r knowledge and recollection of steam 14 con di tio ns so that on that date you would 15 have understood that 500 pounds pressure and 16 700 degrees Fahrenheit indicated superheat?
~
17 A Yes. ,
18 Q In order to reach superbeat, the 19 reactor coolant system has to go th r'o ugh j
20 saturation first, right?
21 A Yes.
22 Q You testified earlier that you 23 di dn' t recognize that there had been
[h
'- 24 saturation in the Three Mile Island Uni t 2 1 i u 25 reactor coolant system until the day after the
. . .c.
. 398 1 Kelly
~
2 day of the' accident.
~
~
~
3 .Is it also true that yo u didn ' t 4 recognize that there.had been superheat in
( .
5 , the Three Mile Ialand Unit 2 reactor coolant 6 , system until sorretime after March 28, 19797 7 MR. KOLD: Objection to the 8 form. ,
9 A I don't remember when I fi rs t believed l
10 that there was superheat in the r"e actor coolant 11 system, but it was after March 28, yes.
12 (Whe re upo n , at 12:45 P.M.,
O 13 luncheon recess was taken.)
14 15 16
~
17 *
/
18 4
~
19 20 _
21
{
22 23 24 25 3 -
m___m _ _ _ _ _ _ _ _ . _ _ _ m__ _ _____
~. - . - - - - . -~ . . _ . - . . - . .. ._
i ik h ' l 4
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399
, 1
3 (2:10 P.M.)
4 JOS EP H J. KE LLY , J R.
] ( 5 re s ume d , having been previously duly 6 sworn by a Notary Public, was further i
7 examined and testified as follows :
4 8 'EXAMINTION (Continued) *
+
9 BY MR. SELTZER: '
- 10 P rio r to the Three hile Island Q
11 event, did you from time to time review i
12 Licensee Event Reports, sometimes known in s
13- the trade as LE Rs ? '
4 14 A I only remember ever seeing one.
15 Which one was that?
, Q 16 A The one from the Davis-Besse transient 17 ~ of September 1977. -
18 Q Did you see tha supplement'to the -
19 Davis-Besse LER?
n.
20 A I don't remember. '
21 Q When did you see the Davis-Besse
,1 22 Sep te mbe r 1977 transient's LER?
, ;5 23 A It was part of the Site Probl'em Report I .
24 that I looked at.
25 ' Q
~
was it attached to the Site P roble m
-e ,
b s i .
I '
1.1 400 1 4 ,
Kelly r
(3 t t ,
%J ,
2 Report?
,3 In o the r wo r ds , was it part of 4 the SPR?
l 5 A I don't remember whether it was attached 6 or subsequently added to it when I fi rs t 7 -
saw it.
8' Q You believed, based on your .
9 analysis of Davis-Besse, that the operator 10 termination of high pressure inj e'ction when
,s - 11' the pressurizer water level was fi rs t rising 12 7_s was not a p rope r action to take, right?
N-) 13 A I believed.at the. time it was not proper 14 for him to terminate high pressure injection.
15 I don' t know whe ther it was ti e d to the 16 pressurizer water le ve 1~.
17 Q So it was not proper for him' to 18 terminate it at the time he termina ed it,
~
, 19 righ t?
i! , 3 20 MR. KOLB You are talking about e- 21 the first time?
(.
22 MR. SELTZER: Right. ,
23 A That was my concern, yes , that. it wasn' t O-t,j 24 p rop e r to.
25 Q To te rmina te -i t at titat time, right?
l I
w' , ;
,' 'T t.
+ i. . , , .- . - . - .
1 Kelly 401 ID '
L_). A Yes-2 3 Q So let me read you a sentence 4 and ask you if you believe that this sentence is accurate or inaccurate as applied to what
( 5 6 operators did during the Davis-Besse 7 September 24, 1977 transient.
8 " Operator action was timely and 9 proper throughout the sequence of events."
10 Do you believe that statement is 11 accurate or inaccurate?
12 MR. KOLB: Would you care to
(~'
(
13 show the witness what you are reading 14 from? -
i 15 'M R , SELTZER: I don't mind
- 16 showing it to him, and I wilkafter 17 he answers the question.
18 MR. KO.LB : I was talking about gg the full context of the documdnt.
20 MR. SELTZER: I want to get his 21 answer first to that sentence taken
('
-22 by itself, so you don't have to worry 23 about in its full context.
() 24 A Was the question, did I think that was 25 (C "D1""*d " # 11 "i"9 P"9*'I
402 1 Kelly i
. \J -
2 an accurate statement?
3 (Record read by the repo rter. )
4 Q I will rephrase it.
k 5 Based on your study and the 6 conclusions which you drew f rom your s tudy 7 of the Davis-Besse September 24, 1977 transient, 8 do you believe that the following statement .
9 is an accurate statement.
10 " Operator action was 4 timely and 11 proper throughout the sequence o f events. "
12 MR. KOLB: If you are asking 13 him whether as it appears in the 14 document itself, you have to show him 15 the document.
16 MR. SELTZER: I am explicitly 17 not asking him that question. I just 18 read him one sentence and I am asking 19 him whether that is an accura e sentence 20 in light o f what you know and what 21 you concluded from the Davis-Besso 22 transient.
23 " Operator action was timely and
/~N
() 24 proper throughout the sequence o f even ts. "
25 A No, I do n' t believe that is a correct
403 1 Kelly 2 statement.
l 3 MR. SELTZER: I would like to 4 mark for identification as GPU
( 5 Exhibit 153 the Supplement to 6 Reportable Occurrence , Davis-Besse 7 Nuclear Power Station Unit 1, Date of 8 Occurrence: September 24, 1977. ,
9 s The do cumen t is dated November 14, 10 1977. It is described on 1,ts cover 11 as Licensee Event Report NP-32-77-16 12 Supplement.
O 13 ( Do cume nt dated Novembe r 14, 1977, 14
Subject:
" Supplement to Repo rtable 15 Occurrence, Davis-Besse Nuclear Power 16 Station Unit 1, Date of Occurrance :
17 Sep tembe r 24, 1977," enclosing three 18 copies of Licensee Event. Repo t 19 NP-32-77-16, marked as GPU Exhibit 20 No. 153 for identification, as of 21 this date.)
22 BY MR. SELTZER:
23 Q Would you please take a.look at
() 24 GPU Exhibit 153 and tell me if you believe you 25 P re vio us ly received a copy of that document?
404 1 Kelly
/^
(
2 MR. KOLB: While the witness 3 is looking through the document, ;
4 because it is quite a lengthy document, I take it your question is only as to
( 5 6 its general appearance rather than the 7 verification of specific wording or 8 'fo r example , a verification of spe cific 9 charts all being there and that kind o f 10 thing? (
11 MR. SELTZER: Right.
12 Q Does it appear to be a copy of the 13 Davis-Besse LER which you re call previously 14 re ceivi ng?
15 A No, the LER I was talking about was 16 only one or two pages at most.
17 Q Could it have been the first two 18 summary pages?
19 A No, it had a dif fe rent fo rma t .'
20 Q Have you ever gone.back over the 21 data that was available to you on the day 22 o f the accident at the Three Mile Island and
)
23 reviewed it on a day subsequent to March 28, rs 19797 24 i
(%-)' 1 25 A Not that I remember.
~
405 .
1 Kelly
[)
v 2 Q Have you ever heard anyone say 3 or seen anybody note in writing something to 4 the e ffect "How could I have failed to know
( 5 from the data that was available to me that 6 Three Mile Island was in s e rio us trouble on 7 March 28"?
8 A I don't recall anything like that. .
9 Q When you were at Greg Schaedel's 10 house, did you ask for and receive any data 11 from the plant?
12 MR. KOLB: Are you talking about
- ~C
- )
13 something that would be in writing, or .
I 14 do you mean --
15 MR. SELTZER: No, over the 16 telephone.
17 A Yes. .
18 Q What data did you ask fo r and 19 receive?
20 A I a;ked Greg to find out fo r me why they '!
1 21 tripped the reactor coolant pumps.
22 Q What did you find out?
, 23 A They tripped them on high vibration.
'() 24 . Q When you learned that, did you 25 al 'o learn what the vibration was that had been
406 1 Kelly L) 2 observed prior to tripping?
3 A Not that I re me mb e r .
4 Q Did you believe when you heard that
( 5 that it had been a mistake to trip the pumps 6 when high vibration had been detected?
7 A I don't remember that conclusion, no.
8 Q Did you ask for and receive any 9 other data from the plant that day?
10 A Yes, Greg asked me --
e xc u s'e me.
11 Greg told me that they had attempted a 7 12 reacto r coolant pump restart but had tripped i \
~ 13 it righ t off again. I asked him to find out 14 why. They said they came back with an amperage 15 rating of about 100 amperes on the reactor 16 coolant pump mo to r , so they didn't believe 17 the pump was pumping any water, so they 18 tripped it off the line.
19 Q Did the 100 amperes reading indicate 20 that the re was any danger o f burning out the 21 motor?
22 A No.
23 Q Did you conclude that it was a r~
(_,N) 24 mistake to have tripped the pumps o f f line 25 after they got the 100 amperes. reading?
407 1 Kelly d 2 A I don't remember that conclusion.
3 Q Did there co me a point in time 4 during the af ternoon of March 28 when a l 5 recommendation came over the telephone from 6 Lynchburg that the Three Mile Island plant 7 operators should establish a high pressure 8 injection charging rate of 400 gallons per .
- 9 minute?
10 A I do n' t remember that. t 11 Q Di d the re co me a point in time 12 durin g the afternoon of March 28 when any O 13 recommendation came up from Lynchburg that 14 the operators at the plant should establish 15_ any rate of flow for high pressure inj.ction?
i 16 A I don't re me mbe r .
j 17 Q Do you remember Lynchburg making 18 any recommendations to the site dur ng
~
19 March 28, 19797 20- A I don't remember.
s . 21 MR. SELTZER: I would like to 22 mark as GPU Exhibit 154 for identification 23 Licensee Event Report NP-32-77-16 for
( 24 the Davis-Besse transient of September 24, 25 1977. The transmittal page is dated
.w..,. , ,, - - - - ,
- ,.m , , . ~ ,--,.,,,,,---an, , - , -
4 --,
408 1 Kelly gs
(
2 October 7, 1977.
3 (Copy of Licensee Event Repo rt 4 NP-32-77-16 for the Davis-Besse l 5 transient of September 24, 1977.
6 Transmittal page dated October 7, 1977, 7 marked as GPU Exhibit No. 154 fo r 8 i de n ti fic atio n , as of this date.) ,
9 BY MR. SELTZER:
10 Q Is GDU Exhibit 154 a? copy of a 11 Licensee Event Report for the Davis-Besse 12 transient which you believe you have seen 13 be fo ro ?
14 A Yes.
j 15 g Is that the LER which you were j 16 testifying earlier you believe you had seen?
17 A Again, I ha ven ' t read all the. wo rds ,
18 but it looks like the type of thing I re memb e r-19 re a di ng , yes.
20 Q Is there any re fe re nce in there 21 to the p remature te rmination of high p ress ure 22 injection?
23 A I have to read it, b) g, 24 MR. KOLB: I suggest the do cume n t 25 speaks for itself. Rather-than having
.I
- ~ , --
1 409 1 Kelly I i
() 2 the witness sit here and read through 3 a document that he doe s n' t stand in a 4 position to say he received for certain, k 5 it seems to me is a misuse of his time.
6 MR. SELTZER: I have a healthier 7 respect fo r the witness' ability to 8 understand technical documents than ,
9 my own ability to understand them, 10 and perhaps he will find a tre ference 11 in there that I don't fi nd .
12 MR. KOLB: Your healthy respect 13 notwithstanding, I think it is 14 inappropriate to ask the witness to 15 read a document unless he actually is 16 able to ve ri fy that he received it 17 word fo r wo rd be fo re. -
18 BY MR. SELTZER:
2 19 Q Do you see any re fe ren ce in the 20 LER fo r the Davis-Besse transient, GPU 154, 21 to ope rator interruption of high pressure 22 injection?
23 MR. KOLB: Let the reco rd show
() 24 that the witness has had a chance to 25 read the document through one time.
._ , , -- - .--. ,,-.--.g
N 410 1
Kelly 2 A I can't read all of the numbers because 3 of the re p ro du ctio n , but I don't see any 4 words that would lead me to believe they l 5 s topped high p ressure injection either.
6 g Do you see any reference in 7 there to pressurizer water level rising while 8 reactor coolant system pressure was falling? .
4 9 A Yes.
10 Where is that? E Q .
11 A In the description of the occurrence, 12 i t s ays , "The system was now in a cooled down O 13 depressurization cycle. Within six minutes, 14 the pressure had reached the saturation 15 pressure fo r the corresponding temperature, 16 and steam began to form within the re a cto r 17 coolant system causing an insurge of water 18 into the pressurizer. P re s s urize r e vel went 19 to its maximum (320 inches)."
20 Q Whe re does it say what is happening 21 to pressure at the time the pressurizer level 22 was going to its maximum?
23 A It says, "The system was now in a b)
(, 24 cooled down depressurization cycle." When' 1
25 it says "Within six minutes the pressure had s
l 411 1 1 Kelly O)
(_ 2 reached the sa+.uration pressure for the 1
3 corresponding te mpe ra ture , " that means 4 it is depressurized down to saturation and
( 5 the level is going up.
6 Q It do e s n' t say anywhere in that 7 text at or about that same time the operators 8 throttled or terminated high pressure inj ection, ,
9 is that right?
10 A Yes, that is right. It does not say
' ' 11 that.
12 Q In your tes timony , yesterday, you 13 described the fact that it was desirable to 14 have procedures which were symp tom o'riented 15 rather than ultimate event oriented.
16 In the ATOG program, were such 17 symptom oriented procedures created?
18 MR. KOLB: You say " created."
19 -What do you mean?
20 MR. SELTZER: Drafted. 1 l
'21 A Yes, we developed symptom oriented 22 p ro ce dure s in ATOG.
23 Q Have those symptom oriented 21 procedures been disseminated, communicated, 25 to B&W plant owners and operators?
( -
412 1 Kelly O
b 2 A A draft copy has been distributed for 3 review, yes.
4 Q Has it been favorably received
( 5 by plant owners and operators?
6 A Yes.
7 Q Have any plants adopted versions l 8 of those symptom oriented procedures , to your 9 knowledge?
10 A No. t 11 Q When did they get the B&W drafts 12 for the fi rs t time?
13 A We mailed them on July 31, 1980.
14 Q In the ATOG program, have you 15 attempte d to use event trees?
16 A We have used event trees, yes.
~
17 Q Has it been a useful tool?
18 A Yes.
19 Q In what way were event irees a 20 useful tool in the ATOG p rogram?
21 A Event trees gave us a pictorial view 22 of how the plant re sponded to multiple 23 casualties. It helped develop that view.
() 24 Q What do you mean by " multiple 25 casualties"?
l.
.! 413 I Kelly
> -s
\.
2 A More than one failure occurring during 3 a specific transient.
4 Q Are multiple casualty transients l 5 highly unusual events?
6 A I am having difficulty with " highly un-7 usual." Do you mean do they happen ve ry 8 o f ten , o r of all --
9 Q Among forced outages , in other 10 words, unanticipated transients, yorcing the 11 plant off line, are multiple casualties very 12 infrequent? -
13 A Most reactor trips which force the plant 14 off line do not i nvo lve multiple casualties.
15 Q In the ATOG program, is it correct 16 that B&W has placed greater stress on preparing 17 operators for multiple casualties than had 18 been the case prior to the ATOG program?
19 A Not in my opinion. ATOG j us t re fo rmulatec 20 what they've always been taught.. It puts it in 21 a simpler method of approach so that anybody 22 co uld understand it.
M Q Did anybody suggest ' including
() 24 e ven t tree analysis in the ATOG program or 25 more directly, where did the idea to use event
414 00 1 Kelly fm 2 tree analysis in the ATOG program originate?
3 A Eric Swanson, to the bes t o f my 4 knowledge.
l 5 Q Have you ever seen all or part of 6 the WASH-1400 Report?
7 A Yes.
8 Q And you recognize that as 9 Pro fessor Rasmussen's reactor safety study?
10 A Yes. E 11 Q It was first published by the 12 NRC in or about 1975.
13 A I do n' t reme mbe r the date.
14 Q When did you fi rs t see WASH -
1400?
15 A I do n' t remember.
16 Q Was it be fore or after the 17 Three Mile Island fiasco? ,
18 Objection as to form.
MR. KOLB:
10 A Before.
20 Q How did you come to see a copy 21 o f the WASH-14 00 Report when you saw it fo r 22 the firs t time?
23 A Eric Swanson gave it to me.
24 Q For wnat purpo s e?
25 A I do n' t remember, l
.415 1 Kelly 2 Q What did you use it fo r , if 3 anything?
4 A I was reading through how they handled
( 5 operator error in that report, and I was 6 reading it fo r general information , since 7 I had it.
8 Q Why were you interested in how 9 that report handled operator error?
10 A That is what I can't remember.
11 Q Did you ever do any work in 12 connection with an analysis o f possible cmall O 13 break in the pump discharge line?
14 A Not that I remember.
15 Q Have you reviewed any part of 16 WASH-1400 since the Three Mile Island accident?
17 A Not that I remember. .
18 Q Hasanybodyeverpointehout to 10 you or have you ever observed the extent to 20 which WASH-1400 accurately predicted the 21 probability of the Three Mile Island accident 22 occurring?
23 MR. KOLB: Objection as to fo rm .
/~ 'i 24 A- Not that I remember.
b 25 Q Do you know that WASH-14 00 predicts
i 416 1 Kelly 2 the probability of a pilot operated relief 3 valve failure?
4 A No.
l( 5 Q Do you know tha t WASH- 14 0 0 pre di cte d 6 the probability o f a total loss of auxiliary 7 feedwater?
8 A I remember many such types of predictions 9 on equipment failures. I don't remember any 10 of the numb e rs . t 11 Q I was first asking just whether 12 you knew that it contained a prediction of O 13 the frequency with which there could be or 14 would be a total loss of auxiliary feedwater.
15 Do you recall that that event was a
16 p re dic te d?
17 ' A I don't remember that event'particularly, 18 no.
19 Q Do you recall that the W' ASH-1430 20 Report relied heavily on event tree analysis?
21 A Yes,.I know that.
22 Q Why is event tree analysis, to your 23 ' . mind, particularly well suited for analyzing
( 24 multiple casualties?
25 A The way we did e vent trees in the ATOG
417 1 Kelly O 2 program, it gave you a pictorial fo rm right 3 in front of you o f many alternate scenarios 4 on how the plant could progress chrough a
( 5 plant with multiple casualties. It was 6 visually evident.
7 Q Were you and people who worked 8 with those mate rials able to see more easily 9 with the event tree logic what events might 10 occur simultaneously and sequentially?
11 A More easily than what? ,
12 Q More easily than without event 13 tree logic.
14 A Yes.
j 15 Q Just to clear up the "more easily 16 than what" question that you raised, multiple 17 casualties can be studied wi thout using 18 event tree logic, righ t?
19 A Yes.
20 Q. I f yo u do n ' t use event tree logic 21 to study it, is it more di f fi cult to perceive 22 what is happening simultaneously and what is 1
23 happening sequentially?
l t )
\v/
21 A' I do n' t know. I never tried it other
.25 than with event tree logic.
418 1 Kelly O 2 Q What is your present position at 3 B&W7 4 A I am a supervisory engineer.
k 5 Q To whom do you report?
6 A Ed Kane.
7 Q What is Ed's title?
8 A He is the Manager of Plant Performance 9 Engineering, the unit that I am in.
10 Q What section is Plant, Performance 11 in?
12 A Plant Engineering Section, b
v 13 Q Who is the head today of Plant 14 Engineering?
15 A Doug Le.
16 Q What division is Plant Engineering 17 Section in or what is --
18 A The Nuclear Powe r Generation bivision.
19 Q What is the step that is j us t 20 above --
21 A The Engi nee ring Department.
22 Q What was Doug La's position before 23 he became head of the Plant Engineering Section?
) 24 A He was a Unit Manager.
25 Q What Uni t?
. . _ . _ . . __ .= _
419 1 Kelly 2 A I don' t remember the title.
3 Q Who is currently the Manager in 4 charge of the Engineering Department?
( 5 A Do n Roy.
6 Q To whom does Mr. Roy r5 port?
7 A The Manager of the Nuclear Power
- 8 Generation Division, Doug Guilbert.
9 Q Doug Guilbert succeeded John 10 MacMillan?
- i 11 A Yes.
12 Q What is John MacMillan's title 13 now?
14 A I do n' t know.
15 Q To whom does the head of NPGO
, , r 16 report?
17 A John MacMillan. ,
18 Q Are you f amiliar with a report or ID letter that is co mmonly re ferred to as the 20 Michelson Repo rt?
21 A I have heard the name, yes.
22 Q Have you seen it?
23 A No.
) 24 - Q Have you discussed it with anyone? .
25 A Not that I remember.
420 1 Kelly 7
a- 1
( 2 Do you know that Mr. Michelson Q
3 wrote in his report before-the Three 4 Mile Island accident that there was a danger
( 5 that an operator might be confused by 6 rising pressurizer water. level._at-a time.
7 when pressure was falling?
8 MR. KOLB: Objection to the form.
9 A I have neve r seen that report.
10 Q Did you hear from anybody that 11 the report contained that warning?
12 A I read some thing like that a couple o f O 13 weeks ago in New Yorker magazine.
14 Q Did you read all or any part of 15 the reports published by the P re s i de n t 's 16 Commission on Three Mile Island?
17 A Insofar as my tes timony was part of that, 18 I have read that, but I do n ' t remember reading 19 any of the rest of the report.
20 Q Yo u s ay " insofar as your testimony.
21 was part o f it. "
22 A I f i t w a s , ,I should have said.
23 Q You have read the tran s c rip t . o f
()- 24 y'our testimony?
'25 A Yes.
- - - v- -
421 1 Kelly 2 Q Have you read any of the analyses 3 or reports put out by the President's 4 Commission which referred to your testimony?
Not that I remember.
( 5 A 6 Q Did you read any of Mitchell 7 Ro go vi n 's study done for the Nuclear 8 Regulatory Commission?
9 A Yes.
10 Q How much of that did tyou read?
11 A I read the first narrative volume of it.
12 Not any of the appendices.
t I N' 13 The first narrative is the one Q
14 that reads like a novel?
15 A Yes.
4 16 Q Did they refer to your November 1977 17 memo in that?
18 A. I don't remember.
19 Q In your work on the ATod program, 20 is it correct that you have- tried to change 21 the focus in accident analysis from low 22 probability, high risk events, to events 23 .that are higher p robability events?
( ,) 24 A Within the scopq o f ATO G _ a s developed.
25 we didn't make any di f ferentiation. It covers-both.
, 422 1 Kelly
(.
/~)N 2 Q Didn' t yo u re cognize in the course 3 of your ATOG work that there had been too much 4 focus on design basis or worst accidents
( 5 which had a very low probability of occurring?
6 I am talking about that there 7 had been such a focus prior to the ATOG 8 program.
9 A It is not clear to me what you mean 10 by a fo cus in procedures or a fo kus in what 11 the NRC was reviewing for licensing or a 12 fo c us in the industry. I am not sure what 13 you are talking about. That is why I was 14 hesitating.
15 Q A fo cus in the safety analyses 16 as presented in the SAR Chapter 15 to which 17 B&W had contributed be fore the Three Mile 18 Island acciden t.-
19 A I remember pickin %fferen J 20 events to study in ATOG than we re in 21 Chapter 15, because in my mind, the purpose 22 of the Chapte r 15 events which was the design l l
23 basis and licensing of a plant was different b)
%s 24 than what I was trying to accomplish in ATOG I
25 in reorganizing procedure fo rma t .
l
\
I
423 1 Kelly 2 Q Why were you reorganizing procedure 3 fo rma ts ? What was the purpose of that?
4 A We wanted to see when we started the k 5 P ro g ram, if there was some method of making 6 the procedures more simple in their use, so 7 that you could reduce even lower the burden 8 that the operator might have in having to 9 work with these things. If he is looking at 10 a multiple casualty, it might be{ cumbersome 4
11 to look at two or three procedures simultaneously.
,_ 12 Not unworkable but cumbersome.
13 I wanted to see if by shifting to 14 a symptom oriented procedure , I could make 15 that even simpler.
16 MR. SELTZER: I wo uld like to 17 mark as GPU Exhibit 155 a memorandum 18 from J.J. Kelly to Di s t rib utio n ,
19 S ub j e c t : ATOG Event Tree Preharation, 20 dated August 15, 1979, 21 (Memorandum from J.J. Kelly to 22 Distribution,
Subject:
ATOG Event Tree 23 Preparation, dated August 15, 1979, O)
( 24 marked as GPU Exhibit No. 155 fo r 25 identification, as o f 'this date.)
424 1 Kelly 2 Q Is GPU Exhibit 155 a copy of a 3 document which you circulated in or about 4 mi d- Aug us t 19797 k 5 A Yes.
6 Q Did you prepare GPU Exhibit 155?
7 A I had a great amount o f input from 8 Eric Swanson.
9 Q Did you review all of the contents 10 of Exhibit '; 5 5 be fo re it was fina'lized and 11 distributed?
i 12 A Yes..
D 13 Q On the second page o f the exhibit, 14 Item B, it states " Event trees should show all 15 systems and components participating in the 16 transient. Bo th safety and non-safety systems 17 should be diagrammed." -
18 Why did you believ'e tha no n-s a f e ty 19 systems sheuld be included in the e[ent tree 20 diagrams?
21 A They are abnormal transient operating 22 g ui de lin e s . No n-s a fe ty systems affect the .
23 -
way the plant operates, and should be incluoed.
(J
-u
) 24 Q What are some examples of a 25 no n- s a f e ty system?
425 i Kelly
/G V 2 A . Main fee dwate r system, main condensate 3 system, turbine, main turbine.
4 Q What about electromagnetic relief
( 5 valve?
G A Yes. Pressurizer heaters . Reactor a
7 coolant pumps.
8 Q What about the block valve behind 9 the pilot operated relie f valve?
i 10 A The block valve behind the yllot operated 11 relie f valve .
12 Q Is the auxiliary feedwater system U 13 a non-safety system?
14 A on some plants it is and on some plants 15 it is not.
16 (Discussion off the reco rd ensued 17 between the witness and his counsel.)
18 Q At TMI-2 on the day of the accident,
~
19 it was a non-sa fety grade system?
20 A Auxiliary feedwater?
, 21 Q Ri gh t .
k A 22 Right.
23 Q Am I correct only . Davis-Be ss e 's
(~%
! j 24 AFW was safety grade as'of March.28, 19797 25 A The consumer power auxiliary feedwater
~
426 1 Kelly
(%
%] 2 system is also, I believe.
3 g W uld you turn to the n'xt e page 4 of GPU Exhibit 155. You have the h eading
( 5 there " Specific Groundrules fo r Unusual 6 si.tu a tio n s . "
7 A Yes.
8 Q Under that you state , "The general 9 groundrules state that no systematic failures 10 will be considered. The exception is the 11 auxiliary feedwater system; e.ll' trains of this 12 system can be expected to fail."
13 Why did you make an exception 14 fo r auxiliary feedwater?
15 A By this time, the Nuclear Regulatory 16 commission had iss ued NUREG 05 78. One of
~
17 the requirements stated in NUREG 0 5,78 is 18 that these type o f guidelines must consider 19 complete failure o f the auxilia ry fiedwater 20 system.
21 Q Do you know what the phrase 22 " common mode failure" means?
23 A I can tell you what I think it means.
r"N qs-) 24 My problem is there might be some very '
25 Peculiar de finitions . depending on who is
, i ,
427 1 Kelly (n)
\-1 2 using that term.
3 Q what do you understand it means?
4 A Common mode failure to me means that
() 5 a single failure can simultaneously cause many 6 apparent redundant systems to fail.
7 Q With that understanding of common 8 mode failure, are you aware that the WASH-1400 l 9 Report anticipated that there could be a 10 common mode f ailure that would knock out the i
11 entire auxiliary feedwater system?
12 MR. K )LB : Objection to the fo rm.
I
\/ 13 A Not that I remember. -
14 Q In the NUREG that you just ci te d, 15 was it part of the NRC's expressed logic that '
16 a common mode failure could knock out all of ..
17 the auxiliary feedwater system? -
18 A I do n ' t remember.
-19 Q Is it your understanding that 20 there can be a common mode failure that can 21 kno ck out the entire auxiliary feedwater
, 22 system?
t 23 A I don ' t have any. l l
("T
,N.
24 .Q If .a maintenance crew le f t all of .-
i
, , 7 t
t 25 the auxiliary feedwater systems shut o f f! af ter .
- n. i r
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, D' 428 1 Kelly
-( .I MJ 2 a maintenance outage of the system, would 1
3 that be a common sode failure?
, , 4 A . No t in thi way I was de fining it.
( 5 Q Have' you ever heard o f something
~
6 like that happening? ,
^
+ 7 A I remember that being considere d as 8 one of the-causes for the v'a lve s being shut-9 at -- the auxiliary feedwater valves being 10 shut during the Three Mile Island accident.
11 Q In your ATOG event tree analysis, '
,/..
12 did yo u c.o' n side r operator a ction' as one O -
~'
~ , ; 1'h , possible cause o f casualties?
^
14 -A Yes.
-15 , Q You have the sentence just after 4
16 .
"th e one that I finished reading a. moment.ago
' ' 17 that says, "Any other redundant, " safety grade" 1 .
18 system will be shown to ' one rate (Reactor 19 Prote ctio n Sys tem, Emergency Safety Features 20 Act,cution System, High Pressure Injection, 21 ret; cetera.)' unless the operator defeats the
~
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- ,~
t
( , '
4 s y
, 23 MR.1KOLB: . Safety grade is in quotes.
i jq 21 Q 'Wh'a t did. you mean by that phrase
'yf-25 at the end, "unless the operator defeats the
429 1 Kelly 2 a ction. " Did you mean all the stuff that 31 you referred to in Item 47 4 A I was just going to ask, can I look
'( 5 at the rules for operator action?
! 6 Q Yes.
7 A The direct answer to your question is 8 that was intended to mean unless the operator 9 defeats the action as explained in the operator 10 actions section. "
I 11 Q Let's turn to the rules fo r
,_ 12 operator action which you have cited.
(_] 13 Would you look just above that 14 at I t e m " g" . You begin Item "g" by referring 15 to systematic failures, 16 Does that mean failures of a 17 complete system? -
18 A Yes.
19 -Q Would auxiliary feedwater be such 20 a system?
I 21 A Yes. .
22 Q You say " Systematic features 23 (i . e . , those features which assume an entire
. . 24 system to be de f eate d) -"
25 MR.-KOLB ' It is failures, not features.
- m... . _ , _ . , _ _ _ _ ,__
, . = _ . - -
430 1 Kelly A
U 2 Q " Systematic f ailures ,. (i . e . , those 3 failures which assume an entire system to be 4 defeated) will not be considered except l 5 those cases whe re an error of operato r 6 decision is possible."
7 What kind of error of operator 8 decision were you re ferring to?
9 A If you look at paragraph 4 b), the last 10 sentence in that pa ragraph says , '"Erro r to be 11 ass umed will be co mple te , i.e., he will no t i
12 manipulate one o f two identical components 13 correctly and the other incorrectly.
14' That is what I meant by his failures 15 would completely eliminate one system.__
16 Q If an operator operates one 17 redundant control inco rrectly, you made the i
< 18 assumption that he would operate thb other 19 control incorrectly also?
20 A That was the groundrule fo r the program,
, 21 yes.
22 Q Where you have redundant systems, 23' ,
then, if there is an incorrect operator decision,
) - 24 .that incorrect opera tor decision becomes 25 a common mode basis fo r failure of the entire 2 ,
1 431 1 Kelly i
V 2 re dundan t system, doesn' t i t?
3 A Yes.
4 Q Fo r example , operator decision
( 5 to valve out auxiliary feedwater would be 6 such a common mode failure of the complete 7 auxiliary fee dwater sys tem, right?
8 A The way we developed the groundrules 9 fo r the p ro g ram , that is right.
10 Q Yo u wo ul d a s s ume tha(if an operator 11 incorrectly valved out one part of AFW, he 12 valved out the whole AFW system, right.
O'- 13 A If I made tha t initial ass umption , it 14 would be completely within the system, yes.
15 Q Unde r Operato r Action Ass ump tions ,
16 your first. sentence states, " operator action 17 assumptions for event trees and analyses are 18 the most important feature of this evaluation 19 e f fo rt because they will be the fundamental 20 input fo r the operating guidelines."
21 Why would the operator action 22 assumptions be the fundamental input for the 23 operating guidelines?
ry (v) 24 A' I do n' t remember why I wrote that sentence 25 or even if I wrote that pa rticular. sentence.
I i
432 1 Kelly J
2 It may have been one of Eric's.
3 Q Whoever wrote it, you te s ti fied 4 you reviewed it be fo re it was finalized and
( 5, distributed. The sentence doesn't mince 6 any wo rds . It says "the most important 7 feature," and it says "will be the fundamental
~
I 8 i np ut. "
9 was it your unders tanding when 10 this was circulated that operator action ,
11 assumptions wo uld a t least be an important' 12 feature and at least a fundamental input fo r 13 the operating guidelines? f 14 What I am driving at is even if 15 yo u do n ' t give operator action assumptions 16 a Bo Derek 10 rating, was it your belief
'17 when you circulated GPU 3xhibit 155.that.
a 18 operator action assumptions were a hery 19 impo rtant component of the operating guidelines 20 which were going to be developed under ATOG?
! 21' A When this was written, we had no l -
i 22 guidelines, . nor did we know what they were .
i i- 23 going to look like when they were done. This f- .
>. ?!\ 24 was an important ground wo rk to set up -- i' 25~ groundrule to set up, so tha,t ' we co uld i
1
, ,. .4 , , , _ ,, w v- w w-*v'- - * ~r * ' " ' " ' " ^ ' ' ' " ~~"
433-434 1 Kelly O 2 systematically inves tigate the whole plant 4
3 response.
i 4 From tha t sense, the operator
( 5 actions are important inputs to developing 6 the methodology to develop g ui de li ne s .
7 But at this time, I di dn ' t know what the guidelines 8 were going to look like, so I can't say it was 9 going to affect the final guidelines .
10 Q Have operator action' assumptions 11 affected the g uidelines that were developed 12 by the ATOG program? Let me break it down.
73 N-13 In developing the ATOG guidelines, ,
14 you used event trees, right?
15 A Yes. .
16 Q The event trees you used to 17 de velop those guidelines included event 18 paths that were based on incorrect op e rato r 19 action, right?
20 A Yes.
21 Q Were those event trees that 22 included paths of incorrect operator action 23 relied upon in developing the ATOG operating C\ .
(_) 24 guidelines?
25 -A Yes.
-- - . .. . ._ =
435 1 Kelly O 2 Q What are the ATOG operating
, 3 g uideline s ?
4 MR. KOLB: Are you asking him
-l 5 to recite them?
6 MR. SELTZER: No, what are they
. 7 generally?
8 MR. KOLB: I don't understand 9 what you mean. Their purpose?
10 What do you mean? (
11 Q What do they look like? Are they 12 in a book?
O 13 A The draft copies are in th re e volumes 14 that comprises one set.
15 (Recess taken.)
16 Q What does the phrase " single 17 failure criterion" mean to you? .
18 A When the NRC requires a safety analysis, 10 they ask that if your analysis call [ for the 20 operation of a particular system that one of 21 the instructions is normally there is a L single 22 --
the wo rst possible single thing that I 23 fails in that system, then the system still
( ) 24 hIas to meet its basic safety objective even 25 with that one particular f ailure .
~ _ _ . _ _ _
436 1 Kelly i
2 Q Do you understand that requirement 3 to include as one of the possible single 4 f ailure s that can occur an operator failing
( 5 to take proper action or an operator taking 6 in co rre ct action?
7 A In my e xpe rience , single failure does 8 not normally include ope ra to r e rro rs . It is 9 equipment related.
10 Q Are you aware of anything in the 11 NRC guidelines that limits single failure to 12 equipment failure and excludes op erato r
' \-Q 13 failure?
, 14 A I am not aware of anything like that.
1 15 Q You say it usually includes just 16 equipment failure. Are you aware of situations 17 where B&W has included operator failure in j 18 its analysis of single failure?
10 A Not that I can ~ remember.
20 Q In the ATOG p rogram, you do include 21 the study o f consequential e f fects o f incorrect 22 operator action , is that right? ,
23 A Yes. ,
II L/ 24 Q So that is a change f ro m the 25 single failure analysis that had been done M g-w- - m-- =* -e-- --- 1
f 437 1 Kelly O 2- p reviously by B&W7 3 A ATOG isn't a single failure analysis.
4 Q I know. It is a change from that.
( 5 Is that ri gh t?
6 A Yes.
7 Q You said the ATOG guidelines have 8 been promulgated in three volumes.
9 MR. KOLB: " Promulgated"?
10 Q Written. '-
11 A Yes.
, 12 Q To whom have copies of the ATOG 13 guidelines been dis trib ute d?
14 By "to whom," I mean to which 15 ope rating utilities.
16 A Arkansas Power and Light, Flo ri da Power 17 and Light. I am sorry. Florida Power 18 Co rpo ra tion. SMUD, Sacramento Munibipal 19 Utility Di s t ri c t .
20 Q They are the owners of Rancho Seco?
21 A The operators of Rancho Seco.
22 Toledo E dis co n. GPU. Duke Power' l:
i 23 Company. I believe, although I am no t positive , .
l 24 that we sent copies to Consumer Power. All of 25 these are Arkansas draft gui de li ne s .
438 1 Kelly s -
)
2 Q Why did you send everybody Arkansas' 3 guidelines?
4 A When we started the ATOG program, the
( 5 objective was to develop guidelines for each 6 one of these utilities. Arkansas was selected 7 as the firs t plant, and we did all the fi rs t 8 of a kind work on Arkansas. First of a kind 9 development.
10 When we produced the ' Arkansas 11 guidelines, we sent them to all.the.other 12 participants in the program so that they would O 13 be able to see what fo rma t and general contents 14 theirs was going.to look'like and make any 15 comments they wante d to , so that when we 16 developed their plant's specific guidelines, 17 we would incorporate those co mmen ts .
18 Q Have you received comments from 19 most of the utilities to whom you sent the 20 Arkansas Power and Light draft?
21 A No.
22 Q Do you remember ATOG guidelines 23 include the 50-degrees subcooling rule?
24 A' A version of that.
! v 25 -Q .What do you mean by " ve rsion" o f it? -
439 1 Kelly O 2 A When developing the ATOG guidelines ,
3 we decided instead of using a blanket 4 50 degree subcooling, we would use actual
( 5 instrument errors, calculated instrument 6 e rro rs , and instead of a 50 degree subcooling 7 margin, they would have a variable subcooling 8 margin depending on what instrument error 9 was for any given p ressure.
10 Q That sounds more cumbersome than 11 just simply having a 50 degrees rule.
12 A The advantage is it gives the operator O 13 a larger area to operate the plant and more 14 time to throttle high pressure injection 15 when it is app rop ri ate .
16 Q Is the ATOG subcooling margin , ;
17 something that you proposed would be built into a 18 digital computer that would automatically 19 show whether the plant was safely under the 20 subcooling curve?
21 A It could be done that way. It could 22 be hand plotted on a picce o f Plexiglas , too.
23 Q If it were hand plotte d, then it D) t 24 w'o uld be ' pas te d up o n wha t? Why do it on 25 Plexiglas?
440 1 Kelly O 2 MR. KOLB: Is the question 3 "Why do it on Plexiglas?"
4 MR. SELTZER: Ri ght . ,
( 5 Q When you could just as easily do 6 it on a business mailing envelope?
7 A You could do it on a business mailing 8 envelope.
9 Q Is there any particular reason yo u 10 selected Plexiglas as the medium?,
11 A No.
12 Q Do the ATOG guidelines include O 13 the small break operating guidelines?
14 A Yes.
15 Q Do the ATOG guidelines include the 16 inadequate core cooling guidelinesi 17 A Yes. -
18 Q Would you turn to page Bates 19 .-- stamped 15322.
20 Can you identify what this page l
21 and the succeeding pagos in GPU Exhibit 155-22 are?
23 MR. KOLB: All o f the succeeding 24 pages?
25 MR. SELTZER: The succeeding pages
441 1 Kelly
[ 2 that are part of what begins on j 3 page 332.
! 4 A It appears to be a version o f the
( 5 proposal we made to our operating plants 6 to develop the abnormal transient operating 7 gui deline s . -
8 Q Did you write or review this?
9 A I don't remember seeing this particular 10 ve rsion be fore. (
11 Q Have you see other versions of it?
12 A Yes.
O 13 Q Later versions? _
14 A This is not the version that was issued 15 to the customers. The one I saw was issued 16 to the c us to me rs , so in tha t sense it must 17 ha ve been later. I do n' t know when. this one 18 was do ne .
~
19 Q So if I looked in what you people 20 sent to GPU, I would be able to find a later 21 version o f this?
22 A I assume so, yes.
23 Q Would you look at the i ntro duc tion
( 24 t'ha t is on page 323. It begins "As a result 25 o f the TMI-2 incident," et cetera.
442 1 Kelly 2 Is the ATOG program some thing 3 that was develope d as a result of the TMI-2 4 i nci den t?
(' 5 A I do n ' t know.
6 Q What is your understanding?
7 A I think it was.
~
8 Q This full sentence is, "As a result 9 o f th e THI-2 incident, the NRC staff and 10 Industry Groups have made several,recomnendations
- 11 to provide additional operator guidelines for 12 mitigating the consequences o f abnormal V
13 transients. In consort with these recommendations, 14 B &W has fo rmulated the following: a. Realistically 15 in ve s tiga te a wider range of reactor plant 16 transients, including failures not no rmally 17 conside red in licensing do cume n tatio n ; "
18 Why was it intended to investigate 19 f ailure s not normally co nside re d . in licensing 20 documentation? ,
f= 21 In the preamble o f this introduction,
_(
22 it says "There were recommendations to provide 23 additional operator guidelines. " Do you see 24 t' hat?
25 MR. KOLB: I personally see the
l 443 i l
1 Kelly ;
O 2 wo rds , but I am not sure it is a 3 preamble. If we can have the 4 question without that characterization.
( 5 Q You see the reference to " additional 6 guidelines for mitigating abnormal transients"?
7 A Yes.
8 Q I as s ume "in concort with" means 9 in f ul fillme n t of, right? Is that what you 10 unders tand that fancy' phrase mean's?
11 A I don't know what " consort" means.
12 Q I have heard it used in other O
\_) 13 contexts, like consorting with the enemy.
14 "In co nso rt with the se recommandations, B &W 15 formulated the following -four things . "
e 16 MR. KOLB: "Has fo rmula te d . "
17 MR. SELTZER: Ri gh t . -
18 One is "To investigate a wide r Q
19 range of _ transients including failures not 20 normally considered in licensi ng do cumen tation. "
21'- How is such an investigation of a 22 wider range of transients going to co nt rib ute 23 to p roviding additional operator guidelines for
()
ss 24 mitigating the consequences o f - abno rmal ~ transie nts ?
., .25 Would you like me to help you?
a.
s -.
1 Kelly I
g -
2 A My problem is I di dn ' t wri te these 3 words. You are asking me, I believe, to 4 to try to interpret what they mean, f
( 5 Q Right.
6 MR. KOLB: If you don' t know, 7 don't speculate.
i 8 A I do n ' t know.
9 Q You think Eric Swanson would be 10 a better person for me to ask questions 11 about this section, is th e.t right?
s 12 A He was mo re f amiliar with the development
(_
13 of the program requirements and this 14 documentation. More-familiar than I am.
15 MR. SELTZER: I would like to 16 mark for identification as GPU 17 Exhibi t 156 a do cumen t dated May 8, 18 1979, Plant Integration Comme ts on 19 - " Operating Guidelines fo r Sma 1 Breaks."
20 ( Do c umen t dated May 8, 1979, 21 Plant Integration Comments on " Operating 22 Guideline s for Small Breaks," marked 23 as GPU Exhibit No. 156 for identification ,
(\j 1 24 as of this_date.)
25 Q Have you ever seen or received a
445 1 Kelly O 2 copy of GPU Exhibit 1567 3 MR. KOLB: Is this part of 4 something else?
( 5 MR. SELTZER: Not to my knowledge.
6 A I rever remember seeing this.
7 Q Do you recognize 'he t fragmentary 8 bit of penmanship in the upper right-hand g corner where somebody has put the date?
10 A No. ?
11 Q Do you know who makes those type 12 of asterisks which appear in the left-hand i
/~N; y
V- 13 margin?
14 A I do n' t re cognize -them.
15 Q Did you participate in any effort 16 by Plant Integration to comment on a draf t 17 o f the small break operating guidelines ?
. l 18 A No.
19 MR. SELTZER: I would like to 20 mark as GPU Exhibit 15 7 a memo - from 21 Mr. Kelly to Al Womack , S ubj ect :
22 Potential Simulator Updating for ATOG 23 Training, February 27, 1980.
( 24 -(Memo'from Mr. Kelly to Al Womack, 25
Subject:
Potential Simulator Up da ti ng
446 1 Kelly O 2 for ATOG Training, dated February 27, 3 1980, marked as GPU Exhibit No. 157 4 for identification, as of this date.)
( 5 BY MR. SELTZER:
6 Q Is GPU Exhibit 15 7 a copy of a 7 memorandum which you sent to Al Womack on or 8 about Feb rua ry 27, 19807 9 A Yes.
10 g You also sent copies'to Norm-11 Elliott and Frank Walters?
12 A And Danny Napir, yes.
4 13 Q Under the heading " Background,"
14 you said that "The ATOG program is chartered 15 to produce gui deline s based on realistic E
16 plant response to vario us transients. To 17 support this e f fo rt, Engineering bs. running 18 emergency' transients using the TRAP computer 10 code with inputs keyed to Arkansas hower and
- 20. Light, Arkansas Nuclear One, Unit 1."
21 Was Engineering running analyses 22 on its T RAP computer code that had previously 23 no t been run?
R k, ,) 24 In other wo rds, were they doing
-1 25 new analyses in order to s uppo rt .the ATOG program?
4 447 1 Kelly l A Yes.
2 >
3 Q were they studying transients 4 that were in addition to transients that C. 5 had previously been analyzed with computer 6 codes?
7 MR. KOLB: Other than transients 8 that had previously been analyzed ever?
9 -Is that what you mean?
10 MR. SELTZER: To this' witness' 11 knowledge, ever.
12 A Yes.
O 13 Q Were there multiple casualty 14 transients that were being analyzed for the 15 firs t time on computer' 16 A There were first time analyses insofar 17 as'the inputs were mo re realistic and 18 assumptions were -realistic as . compared to 19 possibly the same scenarios which hai been analyzed 20 before only with safety analysis type of 2
21 as s ump tio n s .
22 .Q How we re the ' assumptions that 23 were being used for ATOG more realistic than l
( 24 t'he assumptions that had been us ed fo r analyses 25 done be fo re the ATOG program?
I t
I'
448 1 Kelly
(~M
- 2 A The input data consis ted o f Arkansas 3 Power and Light pump head capacity curves as 4 opposed to a generic head capacity curve.
( 5 The analyses started within average parameter 6 bands with reactor at power as opposed to 7 th e design case and safety analysis where 8 yo u are always at the highest temperature 9 and lowest pressure or conversely the lowest 10 temperature and higher pressure depending on 11 which type of transients you are going to 12 analyze.
Ok' 13 The compute r inp uts we put into 14 the ATOG analyses assumed that all of the 15 co ntrol rods would trip on command-where as o
16 a safety analysis assumes the control ro d 17 sticks out. -
18 Th ere fo re , - i t is a worst case 19 transient. That is what I mean'by realistic 20 assumptions.
1 21 Q What, if anything, did you believe 22 was the bene fit to be derived from using the i
. Z3 more realistic assumptions?
O g ; 24 A' The results would be closer to as expected we 25 during the transient. Something the operator.
449 1 Kelly V)
[
2 would be expected to see as opposed to a 3 design extreme, and, there fo re , the guidelines 4 development would be something for the operator
(, 5' to use that he would be expected to see as 6 opposed to fo r instance an enormous LOCA 7 o f some sort which we never expecte d to see, 8 but which is a design assumption.
9 Q Once the ATOG program had produced 10 operating guidelines based on redlistic plant i
11 response to various transients, did you want 12 to make sure that there was simulator training g- _
(_/
13 that wo uld complement the ATOG analyses and 14 operating guidelines?
15 MR. KOLB: Objection as to form.
16 A My intention was to:make sure'in 17 advance that the simulator would be- ready 18 and any required changes would be m de.
19 At this point, I didn't know 20 that it had to be corrected,.but I wanted to 21 anticipate.
22 Q, -To your knowle dge , have steps 23 been taken to mo di fy the simulatbr so that O(,) 24 it does reflect the analyses do n e in support 25 o f ' the ATOG pro gram?
~.
l l
i 450 )
1 Kelly l O 2 A I don't know if even such steps were a
3 required. It may have already met those 4 co ndi tio ns .
(, 5 Q Did Frank Walters run analytical 6 outputs on the simulato r to determine whether 7 changes were necessary?
8 A Yes.
9 (Time noted: 4:40 P.M.)
10 -
t 12 '$ E P J./ KELLY, JR. [*
'O 13 /
14 Subscribed and sworn to 15 before me this /Y day 16 of M , 1981 18 Notary Public -
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20 /
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q 136 451 h CERTIFICATE
{
2 STATE OF NEW YORX )
3
- ss.:
COUNTY OF NEW YORK )
4
{ ,
I, JOSEPH R. DANYo , a Notary
~ 0 6
Public of the State of New York, do hereby certify that the continued deposition of 7
JOSEPH J. KELLY, JR. Was taken before 8
I me on Wednesday, May 6, 1981 consisting of pages 317 through_ 4 5 0 ; .
I further certify that the witness had been previously sworn and that the within
'2 (l >
13 transcript is a true record of said testimony; That I am not connected by. blood or la, marriage with any of the said parties nor
, interested directly or indirectly in the matter i
in controversy, nor am I in the employ _of any g of the counsel.
~
IN WITNESS WHEREOF, I have hereunto set my hand this day of '
r7Y ,39g3,
/ -
( 21 k e h4
/
JosdPH R. DANYo [
24 25
t
't 452
(~5 May 6, 1981 b-I i
I N DE X WITNESS PAGE Joseph J. Kelly, .T r . 317
~
E XH I B I TS GPU FOR IDENT.
I 153 Do cume n t dated November'14, 1977,
Subject:
Supplement to "? portable Occurrence, Davis-Besse Nuclea r Power f- Station Uni t 1, Date of
(_g) Occurrence: Sep tember 24, 1977," enclosing three" copies o f Licensee Event Report
- NP-32-77-26 403 154 Copy.of Licensee Event e Repo rt NP- 3 2- 7 7- 16 fo r the Davis-Besse transient of September 2 4, - 19 7 7 i . Traishi ttal 408 page dated October 7, 1977 155 Memo randum f rom J.J. Kelly to Distribution,
Subject:
ATOG Event Tree Preparation, dated August 15, 1979 423 156 Doc ume n t dated May 8, 1979,
( Plant Integra tion Comments on " Operating Guidelines fo r Small Breaks" 444 157 Memo from Mr. Kelly to Al Womack r'
Subject:
Potential Simulator k_N)- Up da ting fo r ATOG Traini ng ,
dated February 27, 1980 445
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