ML20072J105
| ML20072J105 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 03/19/1981 |
| From: | Dunn B BABCOCK & WILCOX CO. |
| To: | |
| References | |
| TASK-*, TASK-01, TASK-03, TASK-06, TASK-07, TASK-1, TASK-3, TASK-6, TASK-7, TASK-GB NUDOCS 8306290929 | |
| Download: ML20072J105 (114) | |
Text
,_.
e ot 390 e
UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK s
_______________________________________x
?rm GENERAL PUBLIC UTILITIES CORPORATION, JERSEY CENTRAL POWER & LIGHT COMPANY, g
i METROPOLITAN EDISON COMPANY and PENNSYLVANIA ELECTRIC COMPANY, Plaintiffs,
-against-80 Civil 1683 (R.O.)
THE BABCOCK & WILCOX COMPANY and J.
RAY McDERMOTT &
CO.,
INC.,
t Defendants.
_______________________________________x Continued deposition of Ihe Babcock &
Wilcox Company, by BERT MERRIT DUNN, taken by plaintiffs pursuant to adjournment, at l
l the offices of Kaye, Scholer, Fierman, Hays i
& Handler, Esqs., 425 Park Avenue, New York, I
New York, on Thursday, March 19, 1981, at i
l 9:40 o' clock in the forenoon, before Charles 1
Shapiro, a Certified Shorthand Reporter and I
Notary Public within and for the State of
?.
i l
t f}
DOYLE REPORTING. INC.
CERTIFIED STENOTYPE REPORTERS I
8306290929 B10319 l
PDR ADOCK 05000289 369 LgxNoroN AvtNur PDR New Yoms. N.Y.
1C017 T
"TetspNoNr 212 - 867 8220 g
e-r
).
2 Appearance s 3
KAYE, SCHOLER, FIERMAN, HAYS & HANDLER, ESQS.
Attorneys for Plaintiffs 425 Park Avenue 4
- (,
By:
RICHARD C.
SELTZER, ESQ.
-and-6 ANDREW MacDONALD, ESQ.,
of Counsel 7
8 g
DAVIS, POLK & WARDWELL, ESQS.
Attorneys for Defendants 10 One Chase Manhattan Plaza".
R.OBERT B.
FISKE, ESQ.
-and-I
12 RODMAN W.
- BENEDICT, ESQ.,'
of Counsel 13 14 15 Also Present:
16 DAVID TAYLOR 17 ANN BASS (a.m. only) 18 PATRICIA V3UGHAN 19 RALPH CORRELL (p.m. only) 20 (i
. 21 22 23 24 25
,e
-i y
--,-w-m,w
--ew,-w
?
392 2
B E RT ME RR I T D UNN, having 3
been previously duly sworn, resumed and 4
testified further as follows:
)
5 MR. SELTZER:
Mr. Fiske, I think you 6
~
and I reached an agreement over the 7
telephone at the beginning of this week 8
regarding certain instructions that you 9
had given the witness during testimony t
10 last week.
Do you want to state for the 11 record what your position is now?
f~h.
12 MR. FISKE:
Yes.
I told Mr. Seltzer a
13 on Monday that with respect to.the questions i
14 that were asked at the very end of the l
15' day on Friday, March 13th, that we would 16 allow Mr. Dunn to testify with respect to l
l l
17 questions that we had instructed him not 18 to answer relating to his conversation i
19 with Mr. MacMillan, and also certain 20 questions relating to the document which I
21 has been marked as GPU Exhibit 12.
And 22 my suggestion would be, Mr. Seltzer, that 23 you ask the questions and we will just go l
24 forward.
25 MR. SELTZER:
All right.
l l
. -a.u-
1 Dunn 393 f-(_]).
2 Am I correct that we also reached 3
a broader understanding that it is now 4
your agreement that it is proper to ask
(;
5 witnesses questions about the meaning 6
of what a witness has written and the 7
meaning about what a witness has said?
8 MR. FISKE:
Well, I certainly agree 9
to that with respect to the questions
(
10 that were pending at the end of the day 11 Friday, and I think.I also indicated that 12 that agreement would havs a broader 13 connotation.
14 I am not prepared to state at this 15 moment that there might not be.a question 16 asking for the witness's interpretation 17 of something he said or something that he 18 wrote that I might consider objectionable, 19 but I would have to wait to see.the 20 circumstances.
As a general proposition, 21 I would not object.
l 22 MR. SELTZER:
All right.
23 MR. FISKE:
But I think a lot does 24 depend on the context.
i I
25 MR. SELTZER:
We also had a disagreement mg.
g,.".
I
1 Dunn 394 2
last week regarding whether the witness 3
should be permitted to answer questions 4
relating to his impressions of what 5
someone had said when he has testified 6
he cannot recall the exact words that 7
someone has said, and you assured me that i
8 when we resumed, you would let me know 9
which of the Federal Rules of Evidence i
i 10 you were relying on in directing a witness 11 not to answer a question regarding 12 impressions.
i l
13 MR. FISKE:
I would continue that i
i 14 objection for the time being, and I will 15 give you the answer to that before the 16 end of the deposition.
17 I assume we are not going tffinish 18 today.
I
~
19 MR. SELTZER:
I would like to know 20 so that if we can't resolve that dispute 1
(
i L-21 between ourselves, we will have an I
22 opportunity to consider going before the l
23 Court on it.
24 MR. FISKE:
Sure.
f
-+AA s
-1 Dunn 395 N,].
u 2
EXAMINATION (continued) 3 BY MR. SELTZER:
4 Q
Mr. Duun, do you understand your 5
testimony today c tinues'to be sworn testimony 6
under oath to tell the truth?
7 A
I do.
O MR. SELTZER:
I would like to mark 9
for identification as GPU Exhibit 86 a 10 memorandum from Mr. Brazill to Sessrs.
11 Ham and Fairburn, the subject:
Supplementary Operating Instructions for High Pressure 12 13 Injection, dated April 17, 1979.
14 (Two-page memorandum dated April 15 17, 1979, to R.
E.
Ham and G.
T.
Fairburn 16 from G.
J.
Brazill, was marked GPU Exhibit 17 86 for identification, as of this'date.)
18 MR. SELTZER:
Mr. Dunn is indicated 19 for receipt of a copy at the bottom of the 20 first page of GPU Exhibit 86 marked for 21 identification, and there is a dramatic 22 leftward-pointing arrow adjacent to his name.
22 Q
Is GPU Exhibit 86 a copy of a O
24 memorandum which you received in or about mid-25 April 1979 in the regular course of business?
r
.~
1 Dunn 396 G r.
2 A
I believe so.
s 3
Q Under the heading " Engineering I
4 Department Review & Approval," do you see where
(.
5 somebody else has given h-is approval on your 6
behalf?
7 A
Yes.
t 8
Q Whose signature is that?
9 A
John Biller.
10 Q
Who is Biller?
11 A
He was a supervisory engineer reporting 12 to me at the time that this memo was issued.
(x ')
s/
13 Q
Did you ask him to review..and approve 14 it on your behalf?
15 MR. SELTZER:
Let me withdraw that.
16 Q
What is the significance of John i
~
17 Biller's signature?
l 18 A
The timing during when this meno was 19 issued, B&W was operating under a 24-hour-a-day 20 attention and at this time Mr. Biller was 21 charged with the responsibilities of unit manager 22 for ECCS, with the exception of certain 23 administrative tasks charged with my full OG responsibility and for a certain period of time 24 25 during the day.
1 Dunn 397 O
2 Q
In other words, because you could not 3
physically make yourself available 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> a 4
day, Biller was your deputy during part of the Cy 5
day?
6 A
Yes.
I 7
Q Prior to B&W's issuing GPU Exhibit i
8 86 to customers, did you review it or the i
f 9
substance of it?
10 A
I was party to the discussions which led 11 to the generation of the memo, although I am not l
12 sure today whether I reviewed the exact memo i
13 prior to its issuance.
14 Q
Among whom were the discu'ssions 15 that led to the generation of the memo?
16 A
There were approximately five to six people 17 involved in the discussion.
George Brazill is 18 the only one I recall at this time.
19 Q
What, as best you can recall, led l
l 20 B&W to issue this supplement to the HPI operating i
21 instructions that had been issued earlier in 22 April 19797 23 MR. SELTZER:
Let me back up and O
24 make it a little bit clearer.
\\
l 25 Q
On the second page of GPU Exhibit l
u 6
1 i
1 Dunn 398 O
2 86 there are three criteria for termination of s
3 high pressu: ) injuction; is that right?
l i
4 A
~That's correct.
k 5
Q The first two are the same as the I
6 criteria that had been issued to customers on 7
April 4, 1979; is that right?
8 I will show you GPU Exhibit 85 9
for comparison (handing), which is the April 4 I
(
10 instruction.
11 A
Yes, the first two appear to be identical.
12 Q
Is it correct that it is the addition 13 of the third criterion which is the d.ifference 14 between the April 17 operating instructions for 15' high pressure injuection and the April 4 16 instructions?
17 A
That is my understanding.
18 Q
As best you are familiar with it, 19 what facts or circumstances led B&W to add the 20 third criterion?
(_
21 A
There was a recognition that the specific 22 necessity of the second instruction, particularly 23 relative to the requirement for a 20-minute
(~/)
24,
time lag between initiation and the allowance 25 of termination of the high pressure injection k
m.
I
)
1 Dunn 399 gg
(,
i 2
collapse c,ause unnecessary challenging of the j
1 3
code safeties of the PORV in terms of primarily 4
water flow through those valves.
By code f'
5 safeties, I am referring to the safety valves 6
on the pressurizer and that we wished to lessen 7
the adamacy of requirement 2 for certain 8
circumstances.
j I
was it f
9 Q
By adding criterion 3, e
10 intended that some challenges to the pilot operated 11 relief valve or code safety valves could be i
l 12 avoided?
(
}
l 13 A
By adding criterion 3, we could. avoid or 14 allow there to be avoided some circumstance 1
15 in which water flow would be forced through the 16 valves.
l I
I 17 I don't think the word "charlenge" l
18 is strictly correct.
19 Q
I was just repeating your. word.
20 A
- Well, O.K.
I used " challenge" in terms 21 of water flow.
l 22
" Challenge" would mean utilization l
l 23 of the valve and we did not have concerns over O
24 utilization of the valve for steam flow.
25 Q
Why, if you did, did you have concern l-
I 1
Dunn 400
(
2 over utilization of the valve for water flow?
3 A
Hydraulically water will place a stronger i
4 force on the valves during operation than steam 5
would and the opportunity for valve failure is 6
enhanced to some extent if the valve sees 7
liquid as opposed to steam.
Q What do you mean, it would place 8
I 9
greater force on the valve?
i g
10 A
well, any device through which any kind of 11 fluid is flowing experiences a certain amount of 12 mechanical force.
G 13 If the fluid that is flowing is i
14 steam, then in general the force is o'f a certain 15 value.
If the same volumetric flow occurs 16 and it is all liquid, the force is generally 17 higher.
And that is about the state of~my 18 knowledge in this area on these valves.
19 Q
Is that a force measured in pounds 20 per square inch that would be greater?
(
21 A
Not necessarily.
I would, in terms of 22 defining the force, think about it as the 23 actual total pounds force, or to use perhaps a O
24 better defined term, newtons, which are actually
\\'l 25 on any given component of the valve.
s N m m-
s f
402 1
Dunn-c's h
,~Y 2
Q In the context that you have just 3
been explaining pressure and force, would steam 4
under a thousand psi pressure exert a different j
from water under a thousand psi of pressure?
i 5
force 6
MR. FISKE:
I am going to object to 7
the question unless Mr. Dunn considers 1
8 himself qualified to answer.
9 MR. SELTZER:
I am trying to make it i
10 just being in the same context that he has 11 been answering so you can understand his
(
12 past answers.
13 MR. FISKE:
This is in the context 14 of pressure ir. general or --
15 MR. SELTZER:
No, pressure in a 16 pressurizer of a B&W NSS.
17 MR. FISKE:
In terms of pressure on 18 the safety valves?
19 MR. SELTZER:
Yes, or a pilot operated 20 relief valve.
21 Q
Do you understand the question?
(_
22 MR. FISKE:
Maybe you better read it 23 back.
(h
\\',/
MR. SELTZER:
I will restate it.
24 25 MR. FISKE:
O.K.
(
~. -
1 Dunn 402
,f-~
U).
2 Q
Will steam under a thousand pounds 3
psi exert the same force on a valve as water 4
under a thousand pounds psi?
5 A
It is my understand-ing from other people 6
that the valve flowing steam with an inlet 7
pressure of a thousand pounds would experience 8
less force than a valve flowing water with an s
9 inlet pressure of a thousand pounds.
10 Q
when you use the word " water," you 11 mean water in its liquid phase?
{']
12 A
That's correct, yes.
s.-
13 Q
I believe you said earlier that it 14 was your view at the time that GPU Exhibit 86 15 was being prepared that a valve including either 16 a pilot operated relief valve or a code safety l
l 17 valve had a greater probability of failure if r
I l
18 it was passing water than if it was releasing 19 steam; is that correct?
I l
l 20 A
That may be correct.
It was our belief i
21 that that was correct.
l 22 Q
What, if anything, was your l
l l
23 understanding in April of 1979 regarding whether 24 the specifications for the pilot operated 1
25 relief valves for B&W plants had included i
. L:.
1 Dunn 403 f,)
v 2
their ability to pass water in its liquid phase?
3 MR. FISKE:
Could I hear that question 4
again, please.
5 (The reporter read the question.)
6 A
At that time I did not believe I had any 7
knowledge relative to the specifications.
8 Q
Did you have any belief regarding 9
whether B&W specifications called for the pilot 10 operated relief valve to be able to release 11 water pressure in addition to steam pressure?
[~}
12 MR. FISKE:
I think, Mr. Seltzer,
%.)
13 the specifications will speak for themselves.
14 MR. SELTZER:
I know.
An'd then I 15 want to find out whether the Manager of the 16 ECCS Analysis Unit knew what those 17 specifications were.
}
18 MR. FISKE:
I think he said he 19 didn't in April of 1979.
20 MR. SELTZER:
I think his answcr 21 was not quite so clear and I want to find 22 out whether he had any belief as to what 23 those specifications were.
24 MR. FISKE:
Well, you can answer.
25 A
well, you used the term relieve pressure 4-
l' Dunn 404 7-~g
(_j 2
and my belief was that the valve would relieve 3
pressure in either a steam or a water environment.
4 Q
Did you have a belief in April of 5
1979 that B&W had specified to the valve 6
manufacturers that the valve be designed and 7
delivered with a capability of relieving liquid 8
water pressure?
9 MR. FISKE:
I am sorry, could you 10 repeat the question again.
11 (The reporter read the question.)
12 A
A valve, I don't believe, was specified l
).
13 in terms of relieving pressure, be it -- and I 14 don't know what you mean by liquid water pressure 15 and I think you are just being inaccurate.
l 16 Q
Let me clarify the question if it i
~
17 is confusing you at all.
f 18 Did you have a belief in April of 19 1979 that B&W's specifications for the pilot s
l 20 operated relief valve called for the valve to 21 be capable of relieving water?
22 MR. FISKE:
I am not sure I understand 23 the question, Mr. Seltzer.
What do you mean O
24 by relieving water.
25 MR. SELTZER:
Pass water, permit l
l
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1 Dunn 405 (v~.,s
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2 water to go through it, as opposed to steam.
3 MR. FISKE:
Do you understand the 4
question?
5 THE WITNESS:
Yes, I understand the 6
question.
7 A
Relative to that question, I don'A believe 8
I had a belief one way or the other.
9 Q
Is it correct that you have since 10 learned that B&W's specifications for.the valve 11 only specified steam as the service condition
/~N 12 which the valve would have to %e designed and 13 delivered to meet?
14 A
No, relative to the service condition I 15 had a belief at all times that that was the 16 service condition specified in our specification.
I 17 Q
So in April 1979 you knew that steam 18 was the service condition which B&W had specified 19 for the pilot operated relief valve; 1s that right?
i 20 A
I had a belief that that was the service 21 condition specified.
22 Q
Do you also know or do you have a
23 belief that prior to the Three Mile Island b
\\'
24 accident the Dresser pilot operated relief l
25 valve had not boon tested for its ability to 4
s,ww,a' s
e 1
Dunn 406 O
2 pass water?
3 MR. FISKE:
Mr. Seltzer, I think
~
4 these questions should be put to Mr. Dunn 5
in terms of whether-he has knowledge on a
the subject or an understanding on the 7
subject, rather than a belief.
8 MR. SELTZER:
Bob, that is, I think, 9
not a fair objection because different 10 people couch their recollection',in 11 different ways.
This witness has 12 consistently over days of depositions 13 couched his recollection as beliefs and 14 he says "I believe this happene'd, I believe 15 that happened," that is the way he happens 16 to phrase his recollections, and I think 17 that you are just trying to block. relevant 18 testimony in trying to deter him from 19 using the buzz phrase that he uses 20 consistently to describe his recollection, 21 and I resent it.
I want you to know
(.
22 that I certainly resent it, and I think 23 this is one of the most important depositions in the Three Mile Island litigation and 24 I think you are doing your damnedest at 25
.k m
{
1 Dunn 407 bg 2
some times to interfere with the conduct s
3 of the deposition.
I really don't think 4
it is fair.
I have an enormous amount of 5
respect for you as one of the really fine 6
litigators in the country and I just feel 7
you are pushing a little bit too hard.
8 MR. FISKE:
Mr. Seltzer, let's'just 9
make a couple of things clear.
Nobody is
(
10 trying to block any relevant ing.uiry, but 11 it seems to me that the question of whether 12 the valve has been tested for water or
()-
13 the question of what the specifications 14 say are all facts -- I mean the 15 specifications say what they say and either 16 the valve has been tested or it hasn't 17 been tested.
It is not a matter of Mr.
18 Dunn's opinion or Mr. Dunn's belief.
Either 19 it was or it wasn't, and as long as the 20 question is directed to Mr. Dunn in a way 21 that asks him, does he know whether this 22 happened or not, I have no objection, but 23 if you are talking about in terms of O
24 some speculation on his part as to whether 25 he believes it was done or it wasn't done,
. WoWhm ' w ** * **,y m.g+
" * - ~ ' * ' - -
_ = _ _.... - _,
1 Dunn 408 2
he could very well be wrong and --
3 MR. SELTZER:
Bob, I don't mind 4
explaining the relevance of my question 5
to you because I th-ink I can put you at 6
ease very fast.
7 MR. FISKE:
I understand the inquiry 8
is highly relevant.
9 MR. SELTZER:
I don't think you am aski(ng this 10 understand at all why I 11 witness for his belief.
12 MR. FISKE:
I would be glad to hear 13 you.
14 MR. SELTZER:
0.K.
15 I think that the condition of a car's 16 tires may be a question of fact, I think 17 the driver's perception of the condition 18 of his tires is a completely independent 19 fact and I think that it is relevant in 20 an auto negligence case to ask a driver
(.
21 what his perception was of the condition 22 of his tires before the accident, and I 23 think that if he has a perception that 24 is important, it is a separate relevant 25 fact from the actual condition of the tires.
e-
409 Dunn 410
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4 It was my belief at the time that the
/civco had not been tested for their ability wer the to pcos water, Q
When you say "at the time," you mean st er about the time of the Three Mile Island front tire.
sccidcnt?
2gh to get 4
Yes.
Q That was your belief at that time?
t aght to hear 4
Yes.
Q To your knowledge or belief, have the 74 haor any of them been tested since the rhrco Mile Island accident for their ability e Pilot to pces water?
- ""##1Yi 9 I don't know.
Q Do you know who in B&W's organization anufacturers would be most likely to know the information?
4 I could point that individual out.
I can't 9"
givo you his name right now.
Q You mean in an organization chart 9*
/ou could point it out?
urers of pilot 4
No.
Off the record.
7(.)
ir ability to
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(Discussion off the record.)
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I could find that individual on the floor.
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MK.',.fISKE:
You b.4ve, persuaded me.
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>:a A,, SELTZER:
Thanks.
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.j M P,. FISKE: 'You canTanswer the 4
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Wh6re are we at?
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e M R. SFLTZER:
The left front tire.
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MR. FISFR " Maybe we ought to hear 10 f
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or,
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$he'qu,$stion.
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question is:
.Du you have any 2
g
'; i 13 know1rrio7f oE beliofdthat prior e t oth e Three Mile r
- f.;y 4 /
e e.
p 14 Island,acci3fd Dresser had test.ad_the pilot
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operated,s.
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an reli.ef valver which it was supplying f l,a, W
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,13 for B&W p3,4t[ts for their ability to pass water?
A
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A p I' am ndt"farriliar with tho manufaeturers 17,k 4
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r 16 used by BW"for the pilot operat*ed relief 9
19 valve and have not chosen to segregate my 20 beliefs relative to n.anuf acturers.
' {;
Q Do you have any knowledge or belief L'
21
~
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22 about wheth,er any of the manufacturers of pilot w.
g
)-
operated reli$f, valves bein
' supplied to B&W 23 C
sU 24 '
testing those valves for their ability to were
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25 pass water?
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i
I Dunn 413 I
6
(/
2 Q
what section is that individual in?
3 A
He is in my section, the same section that 4
I am a member of.
5 Q
Do you know what unit he is in?
6 A
If I were given an organization chart, I 7
could -- a current organization chart, I could 8
probably identify the unit.
9 (Document handed to witness.)
10 Q
Does that show the unit ik which the 11 individual you are thinking of works?
12 A
No.
13 Q
At Crystal River, to the best of 14 your knowledge, which of the three criterion 15 for termination of high pressure injection was I
16 relied up,on when the high pressure injection was i
i 17 ultimately terminated?
18 A
I do not know.
I would have to speculate.
l 19 Q
It certainly wasn't criterion 3 1
20 is that right?
21 A
No, I don't think I would make that 22 statement.
I I
23 Q
Didn't the pressurizer go high off 24 scale at Crystal River?
'~'
25 A
The instruments indicated such.
r
.__1-
__. _ =
I 1
Dunn 432 2
Q At Crystal River they took the 3
pressurizer solid, didn't they?
4 A
Yes.
5 Q
Have you spoken with any of the 6
people who were in the control room at Crystal i
7 River on the day that they had their transient?
i 8
By "on the day," I mean at the time the transient 9
occurred.
i 10 A
Have I spoken to people that we're in the 11 control room on that day?
/
12 Q
Let me recast it.
O) 13 Have you spoken'with people who were 14 in the control room at the time of the Crystal 15 River transient in February 19807 16 A
I spoke with a person who was in the 17 control room during the accident -- during the 18 recovery from the accident.
That is when I 19 spoke to him.
20 Q
Who was that?
(-
21 A
I can't recall his name.
He was the B&W 22 site representative.
i 23 Q
How soon after the start of the O
24 transient did you speak to him?
25 A
I am not sure.
It was within a few hours.
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W
I i
'l l
I Dunn 413 o
2 Q
Was the high pressure injection still 3
on?
4 A
I don't recall.
5 Q
You don't remember the name of the 6
B&W site rep?
7 A
No.
8 Q
Have you spoken to him since the 9
day of the transient?
10 A
I don't know.
11 Q
Have you spoken to anybody else 12 who was in the control room at Crystal River 13 during the Crystal River February 1980 transient?
14 A
Not with the knowledge that they were there.
15 Q
Did you discuss with the B&W site 16 representative the implementation of B&W's 4
17 operating instructions for high pressure injection?
~
l 18 A
No.
19 Q
Have you ever spoken with anyone 1
i 20 who was in the control room during the Crystal l
21 River transient about whether or how they used 22 the B&W supplemental instructions for operating 23 high pressure injection?
24 A
No.
25 Q
Have you ever had any conversation l
l l
414 I
Dunn
()N i
\\-
2 with anyone about the use of the B&W HPI 3
operating instructions during the crystal River 4
5 Let me make it very clear.
The 6
difference between this question and the prior 7
questions is I am not limiting the conversation 8
to people who were actually in the control room 9
at crystal River.
(
10 A
I understand that.
11 Yes.
12 Q
When and where did[those conversations
()
13 take place?
14 A
I believe the conversation took place.in f
Don Hallman's office.
The time frame was l
15 16 sometime after the crystal River accident.
17 Q
Who, if anyone else, was prbsent?
18 A
I can't recall whether anybody else was 19 present or not.
20 Q
Did you have any other conversations 21 with anyone regarding the application of the B&W I
w l
l 22 instructions for high pressure injection system i
I 23 operation during the crystal River accident?
p)
\\
24 A
I can't be sure.
v 25 Q
Do you believe that you did?
~v
'T w?-m, -,
4
l l
l 1
Dunn 415 2
A Yes.
f 3
Q with whom else do you believe you had 4
such conversations?
5 A
Bob Jones, and I think the other individual 6
I might name would be in a speculative nature.
7 Q
where did you have the conversation 8
which you believe you had with Jones?
9 A
Somewhere in the unit's physical boundaries.
10 Q
When, to the best of your'. recollection, 11 did you have the conversation with Jones?
(~}
12 A
very shortly following the accident.
U 13 Q
Was anybody else present?
14 A
I don't know.
15 Q
About how long was your conversation 16 with Hallman in his office?
l 17 A
I don't recall.
i L
18 Q
Did you go in to talk to him about i
i 19 the Crystal River accident?
20 A
I don't recall what started the conversation.
(
l 21 Q
As best you can recall, what did 22 you say to him and what did he say to you, in 23 words or substance?
(
(/
24 A
The substance was that the operator had 25 made a conscious decision to maintain high i.
Dunn 416 y
2 pressure injection until instrumentation had 3
been returned to the point where he could 4
verify his loop conditions, and that was from 5
Don, and my response was that I thought that 6
was good.
7 Q
When you say " verify his loop 8
conditions," are you referring to conditions in 9
the hot and cold legs?
10 A
Yes.
11 Q
Are the conditions that you are 12 referring to temperature and pressure?
13 A
That was my interpretation, what the key 14 variables were of importance.
15 Q
What, if anything, did you or Don 16 Hallman say about the operators applying the 17 new B&W instructions on high pressure injection 18 operation, the supplemental operating instructions?
19 A
Nothing more than what I have already said, 20 that I recall at this time.
1 21 Q
What was the substance of the 22 conversation that you believe you had with Bob r
23 Jones about the use of the B&W supplemental 24 instructions during the Crystal River accident?
25 A
In substance, I reiterated the words that f
x
s 437 Dunn 1
3(a a conscious decision to the operator had made 2
maintain high pressure injection until 3
instrumentation had been returned to the point 4
in time where he could verify his system 5
conditions, and that I felt very good that such 6
a decision had been made by an operator.
7 Q
Did you feel that the operator had 8
made that consious decision in reliance on the 9
supplemental operating instructions sent out 10 by B&W7 gg A
Not necessarily.
12 Q
Have you ever had any communication 13 which you understood or which led you to believe g4 that the operators had acted at crystal River 15 in February of 1980 in reliance on the supplemental 16 operating instructions received from B&W since g7 the Three Mile Island accident?
18
~
THE WITNESS:
Could I,get th e.t one 19 back, the first clause, please.
20 (The reporter read the record.)
(
21 A
Not that I. recall.
22 communication that Q
Did you get any 23
()
led you to believe that they were acting on 24 any instructions that they had received from 25
'~
I Dunn 428
[)
v 2
B&W on high pressure injection apuration since the 3
Three Mile Island accident?
4 A
Not that I recall.
5 Q
Have you ever made any efforts to 6
determine whether the operators were specifically 7
assisted by the B&W operating instructions or 8
suggestions issued after the Three Mile Island 9
accident?
10 A
No.
11 Q
In your resume, which is part of
('N 12 GPU Exhibit 75 marked for identification, you
\\_
13 described the specification of operational 14 procedures for handling loss-of-coola'nt accidents 15 as being one of your major accomplishments, 16 and you say, "Those procedures may have prevented 17 a second incident similar to TMI-2 on at least i
18 one occasion since March 26, 1979."
19 on what were you basing your 1
20 statement that these additional oeprational
(
21 procedures may have prevented a second incident 22 similar to TMI-27 23 A
On my decision that the operator had i
24 responded correctly and set appropriate criteria 25 for termination of high pressure injection in the
f 1
Dunn 419 0
2 Crystal River event and that he had had several 3
influences and items of training available to him, 4
two of which relate to it or are the small break 5
operating guidelines and the instructions for 6
management of high pressure injection.
7 Q
The instructions for management of 0
high pressure injection that you are referring 9
to are the April 4 and April 17 instructions; 10 is that right?
11 A
That is correct.
12 Q
The training that you referred to is 13 training that was implemented after the Three 14 Mile Island ac61 dent and based upon the small 15 break operating guidelines; is that right?
16 A
There was training, to my understanding, 17 on the small break operating guidelines <
There 18 was training shortly following Three Mile Island 19 on the particular course of that accident.
That 20 training does not relate to the small break 21 operating guidelines.
22 Q
when were the small break operating 23 guidelines circulated?
24 A
I could not give you a date.
25 Q
After the Three Mile Island accident?
Dunn 420 2
A Yes.
3 MR. SELTZER:
I would like to mark 4
for identification as GPU Exhibit 87 a 5
memorandum from Don Hallman to Mr. Ellison, 6
subject:
Reactor Coolant System S4bcooling 7
Limits Curve, May 10, 1979.
8 (Memorandum dated May 10, 1979, to 9
K.
R.
Ellison from D.
F.
Hallman, was marked t
10 GPU Exhibit 87 for identification, as of 11 this date.)
12 Q
Is GPU Exhibit 87 a copy of a 13 memorandum which you received in the regular 14 course of business on or shortly afte'r May 10, 15 19797 16 A
I believe I received a copy of the same 17 memo.
This one is addressed to Allen W6 mack.
18 Q
Is that your signature on page 2 19 of the exhibit?
20 A
Yes.
(.
21 Q
What is the curve that is attached i
22 as the last page of Exhibit 87 supposed to
(
23 accomplish?
24 A
As I recall the curve was to provide i
25 assistance to the operators in determining whether r
. (
1 Dunn 421
(~h v
2 their system conditions were in fact more or 3
less than 50 degrees subcooled.
4 Q
How would they use the curve to 5
determine that?
6 A
They would take the indicated reactor 7
system coolant pressure and the' indicated 8
reactor coolant system hot and cold leg 9
temperatures and either visualize or plot them i
10 on the curves depending on which side'.of the 11 curve they were on, they could determine whether 12 they were 50 degrees subcooled.
13 Q
To your knowledge, was this the 14 first time that B&W had circulated such a curve 15 to its customers?
16 A
To my knowledge, yes.
You testified earlier that you had 17 Q
18 had no personal involvement in operator training 19 at B&W from the time of the Davis-Besse incident 20 in September of 1977 through the date of the
(
21 Three Mile Island accident.
Could you describe generally what 22 23 kind of involvement you have had in training O)
\\_
24 since the Three Mile Island accident?
25 A
Yes.
I have seen the training film
I Dunn 422
(-]
\\_)
l 2
produced (or training on the accident at Three I.
3 Mile Island itself.
I have participated in a l
4 mock training session in w11ch we were given a l
5 short course on small breaks by an instructor.
6 I participated in the development of the small 7
break operating guidelines which, it is my 8
understanding, has since been utilized as a 9
basis for training and has been trained on.
And i
10 I have been in the habit of giving a short 11 lecture to operators, when requested, on the 12 modes of natural circulation wliich can occur in
(
13 a B&W plant, and have assigned an en'gineer 14 within my organization whose responsibilities 15 are to give lectures in the large and small break 16 arena, again as requested by the Training I
l 17 Department, and who is also charged with the l
18 responsibility _to maintain contact with the 19 general field of post-accident operations and 20 operations during the early phases of the 21 accident, to provide an ECCS overview to some w
l 22 extent of what information is being given to the 23 customers in this area.
24 Q
What area?
l 25 A
The area of operations and management of
.h-'
1 Dunn 423 2
accidents with attention to the small break s
3 accidents of course -- well, with attention to 4
loss-of-coolant accidents.
5 MR. FISKE:
I am supposed to call 6
somebody at 11.
Is this a' good time for 7
a break?
8 MR. SELTZER:
Yes.
9 MR. FISKE:
I mean if you are in the 4
10 middle of something --
11 MR. SELTZER:
No.
12 (Whereupon, a recess was taken.)
(
13 BY MR. SELTZER:
14 Q
Who was the engineer assi'gned from 15 your unit to give lectures on large and small 16 breaks?
17 A
Mr. Ed Anderson, that is, presently 18 assigned.
19 Q
O.K.
Since the Three Mile Island accident, 20 21 have others been assigned from your unit?
22 A
Yes.
23 Q
who?
OV 24 A
The original designee in that function 25 was Mr. Jim L -mon.
He did not function in that s
1 Dunn 424
/
2 position for an extensive length of time though.
3 Q
Have you ever given lectures since 4
the Three Mile Island accident on operator 5
response to loss-of-coolant accidents?
6 A
I don't believe so.
7 Q
Have you ever given any lecture 8
on system performance during a loss-of-coolant 9
accident?
t 10 A
Again, I don't believe so.
11 Q
Have you discussed with the people f'h-12 from your unit the contents of their lectures uJ 13 on large and small breaks?
14 A
From time to time, yes.
15 Q
Have you sat in on any of their 16 lectures?
17 A
No.
18 Q
Have they ever presented their l
19 lectures to you, any of them?
20 A
No.
j 21 Q
Have you ever reviewed any written l
l 22 materials which they use in conjunction with 1
23 any of their lectures?
I)#
24, A
Yes.
25 Q
What written materials have you seen?
e
t I
425 I
Dunn
(^s
(_
2 A
Mr., Anderson currently has a basic format 3
for his lecture, part of which is a written --
i 4
his written information descriptive of the
(
5 lecture, descriptive of 1arge and small break 6
accidents, and the scenarios played out within 7
the primary system during those accidents.
8 Q
Does he discuss breaks at the top 9
of the pressurizer?
(
10 A
I don't recall that specifically.
11 Q
Does he discuss saturation occurring 12 in the primary system?
(
13 A
Yes.
14 Q
What, as best you can recall, is 15 the substance of his instruction with respect 16 to saturation?
17 A
You asked whether he discussed it".
18 Saturation occurs within the prim'ary system for 19 all but the very smallest small breaks, and in 20 explaining the scenario of the accident, 21 explaining operator response, and in that form 22 he is discussing it.
23 Q
Does he discuss the three criteria 3
24 for termination of high pressure injection as 25 outlined in the April 1979 communication?
1 Dunn 426 i
gs 2
A Not exactly.
~
~
3 Q
What do you mean by "not exactly"?
4 A
The criteria are reiterated in the small 5
break operating guidelines.
I don't believe 6
them to be exact reproductions of the April 17th 7
criteria at this time.
And he discusses the 8
small break operating guidelines.
9 Q
How frequently are engineers from t
10 your unit called upon to give lectures as part 11 of the B&W training program?
Frequency would depend upon the, nature of
[ )'t 12 A
13 the training and the desires of the customer.
14 Ed gives lectures, on the' average, 15 approximately once every other week.
16 Q
Has he been giving lectures than 17 approximately once every other week for}more 18 a year?
19 A
Yes.
Those lectures would be grouped l
20 into a significant number over a month, and 21 then perhaps a month or two without lectures, 1
l 22 and then another significant number of lectures.
I 23 Q
Has Norman Elliott ever conferred 24 with you about the content of the B&W training l
25 program since the Three Mile Island accident?
.l
I Dunn 427 O
2 A
Not that I recall.
s 3
Q Has anybody in training ever conferred 4
with you about the content of the training program 5
since the accident?
6 A
Not other than tha content of the natural 7
circulation lectures I have been in the habit i
8 of giving.
9 Q
Who has conferred with you from i
10 training about the content of that lecture?
11 A
The instructors.
12 MR. SELTZER:
I would like to have 13 marked as GPU Exhibit 88 for identification
[
14 a document entitled "ECCS Analysis of 15 B&W's 177-FA Lowered-Loop SNN - R,evision 3,"
16 Topical Report, BAW-10103A, Revision 3, 17 July 1977, by Messrs. Dunn, Jones and l
18 Biller.
i 19 (Multipage document entitled 20 "ECCS Analysis of B&W's 177-FA Lowered-Revision 3," was marked GPU 21 Loop NSS 22 Exhibit 88 for identification, as of this 23 date.)
O 24 Q
Is GPU Exhibit 88 marked for 25 identification a copy of a report which you
-.. _,_ 1
=
m 1
Dunn 428 2
co-authored?
s 3
A Yes.
4 Q
This analysis was' intended for what 5
purpose?
6 A
It was a generic evaluation of the response 7
of the B&W 177 lowered-loop design for the purpose 8
of showing conformance to the criteria of 9
10 CFR 50.46, Code of Federal Regulations.
(
10 Q
Included in the class of plants 11 covered by this report is Three Mile Island Unit 12 2
is that right?
(}
13 A
That is correct.
14 Q
When you say this is done to 15 demonstrate conformance to the criteria of 16 10 CRF 50.46, does that mean that for all break 17 sizes and locations in the 177-FA lowered-loop I
18 plants your analysis showed that there would 19 be acequate core cooling?
?0 THE WITNESS:
May I have the question 21 read back, please.
22 (The reporter read the question.)
23 A
The analysis showed adherence to the O
24 criteria of 10 CFR 50.46, 25 Q
The criteria of 50.46 are criteria
_.. _ _ _. _. _ ~. _. _
I 1
Dunn 429 2
which specify -- I think you have already 3
tactified, five different measures of whether 4
there is adequste core cooling; isn't that right?
5 A
Yes.
6 Q
So the analysis that is set forth 7
in GPU Exhibit 88 is intended to show that there 8
is adequate core cooling within the definition 9
of 15 CFR 50.46 for all break sizes and locations; t
10 right?-
11 A
Correct.
12 Q
Is there anything in GPU Exhibit 88 13 which analyzes specifically' breaks at the top 14 of the pressurizer?
15 A
I don't believe so.
16 Q
So that is a break location that i
17 wasn't covered by GPU Exhibit 88; is thht right?
l 18 A
In my opinion, your statement is wrong.
1 1
19 Q
Where in GPU Exhibit 88 is that I
20 break location covered, namely, a break at the 21 top of the pressurizer?
I 22 A
A specific analysis of a break at the top 23 of the pressurizer is not covered in BAW-10103.
24 However, the intent of BAW-10103 is to show that 25 for accidents which provide the most serious k
1 Dunn 430
(~.
4 2
challenge to the emergency core cooling system, 3
the system is capable of adequately assuring 4
core cooling as defined by 50.46.
The accidents
(
i 5
directly evaluated in 10103 are more severe 6
relative to placing a requirement on the 7
emergency core cooling system than the specific l
8 one you mentioned.
9 Q
Is there any break described in
(
10 BAW-10103 which would cause pressurizer water 11 level to rise as reactor coolant system pressure 12 fell, and if so, would you tell me on what 13 page it is described?
14 A
No, I don't believe for any of these 15 events analyzed here the pressurizer water level 16 would rise.
17 Q
WouldyouturntoAppendixy, 18 please, which is entitled "Small Break Analysis."
19 A
Yes.
20 Q
Let me ask you --
21 MR. FISKE:
The pages are numbered 22 C at the bottom.
23 THE WITNESS:
Yes.
O 24 MR. BENEDICT:
Yes.
25 Q
You and two other individuals are Xu
I Dunn 433 O
i 2
listed as,the authors of 10103 which we have 3
identified as GPU Exhibit 88.
4 What was your role in the preparation 5
of this document?
6 A
During the preparation of the original 7
revision to the document, I was a supervisory 8
engineer charged with the responsibility to see that 9
that the analysis was performed and to see t
10 the document was produced.
11 During the work on Revision 3, I
in the unit manager capaci,ty.
()
12 was 13 Q
You supervised the preparation and 14 issuance of this document?
i i
15 A
Well, as I mentioned before, the document i
I 16 grows over a period of time and I directly 17 supervised the original version, and for Rev.
3, l
[
18 being in the position of unit manager at that l
deal to do with the production 19 time, had a great 20 of the document but I wouldn't say I directly f
f 21 supervised it.
w 22 Q
Did you review it before it was i
i 23 issued?
24 A
To the extent I deemed necessary.
25 g
Did you know at the time that x.
f 1
Dunn 432 r0 V
2 BAW-01003 was being prepared that it would be 3
submitted to the NRC7 4
A Yes.
.}
5 Q
Is it your understanding that an 6
analysis demonstrating conformance of NSS to the 7
criteria of 10 CFR 50.46 is necessary to obtain 8
an operating license for those plants?
9 A
Yes.
At this time.
I 10 Q
On page C-2 of Appendix C, in the 11 introduction, you refer to three different break 12 areas that are studied.
13 Do you see that reference in the 14 second paragraph?
15 A
Yes.
16 Q
The third break area is a 0.04 17 square foot break at the pump suction which you 18 say "was shown to be the most limiting small 19 break."
20 What do you mean by the phrase "the 21 most limiting small break?
w 22 A
That accident, which places the most 23 severe requirement for performance on the 24 emergency core cooling system within the small 25 break spectrum.
r-
.L.
e 1
Dunn 433 0
2 MR. FISKE:
Could I just hear the 3
answer, not the question, please.
4 (The reporter read the record.)
5 Q
What is the small break spectrum?
6 A
It is generally considered to be ruptures 7
of the primary coolant system pressure boundary 8
which will allow fluid discharge at a rate 9
in excess of the makeup system capability and 10 which are smaller in cross-sectional area than 11 one-half of a square foot.
12 Q
When you refer to the makeup capacity, 13 are you referring to the amount of water that 14 can be pumped into the system by the makeup l
15 pump?
16 A
Yes.
17 Q
And in the 177 plants there is 18 generally one makeup pump?
19 A
In the 177 plants the same pump is l
20 utilized for makeup and for high pressure l
21 injection, so there are three possibilities.
22 Q
What I was --
f 23 A
one pump is normally utilized for makeup.
d' 24, Q
O.K.
You have put your finger 25 right on the pulse of the ambiguity that I was t
F 434 1
Dunn g
)
2 concerned.with, s
3 When you say it is a break in excess 4
of the capacity of the makeup system, is it a
(
l 5
break-in excess of the capacity of one makeup p
i 6
pump or the combined capacity of all three
)
7 makeup high pressure injection pumps?
8 I am sure this isn't the first time 9
you have thought of that question.
(
10 A
The definition of the small size, small side 11 size of the break spectrum has not historically 12 been strictly defined.
There have been times
(
13 when the definition has included the discharge 14 of two makeup pumps thrcugh the single makeup i
15 train of piping; most frequently it is one makeup f
16 pump.
17 Q
You say that the 0.04 squar6 foot 18 break at the pump suction was shown to be the i
19 most limiting small break in BAW-01152.
20 Is 01152 another topical report 21 prepared by B&W?
22 A
That is correct.
And you were a' so a co-author of that 23 Q
rO 24 topical report is that er rect?
25 A
I believe so.
__ a _
1 Dunn 435 2
Q I will hand you a copy of 10052, 3
Revision 1,
and ask you if you recognize this as 4
a copy of that topical report which you co-authored.
5 A
This appears to be a copy of that report.
6 Q
Would you look at the chart that is 7
on page 2 of what we will mark as GPU Exhibit 89.
8 MR. SELTZER:
We will have copies 9
made of this and we can mark it after lunch.
t 10 Q
Do you see the third column labeled 11 Peak temperature Fahrenheit?
12 A
Yes.
13 Q
Is that the peak clad temperature 14 for each of the breaks described in the left-hand 15 column?
16 A
Yes.
17 Q
What does that mean, that these are l
18 the peak clad temperatures?
Is that the highest I
19 temperature which the zirconium alloy cladding l
20 is expected to reach during a break of the f
i 21 description in the left-hand column?
I 22 A
It is the highest temperature the cladding 23 has been calculated to reach using the assumptions
(
24 imposed by the accident and by the method of I
l 25 analysis.
1 Dunn 436
)_
2 Q
In the left-hand column you describe 3
three different size breaks occurring at pump 4
suction; is that right?
(
5 A
Yes.
6 Q
They are arrayed from top to bottom 7
in descending size of the break; right?
8 A
Yes.
9 Q
As the break gets smaller, the peak
(
10 cladding temperature anticipated increases; right?
11 A
That is indicated in the narrow range of
(-
12 this table.
13 Q
Specifically for a 0.3 square foot 14 break, the peak clad temperature is 780 degrees 15 Fahrenheit; right?
16 A
Yes.
17 Q
For a 0.4 square foot break", the 18 peak clad temperature is 978 degrees Fahrenheit; 19 right?
20 A
Yes.
21 Q
What is the significance of the 22 peak clad temperature?
23 A
Relative to what?
O 24 Q
Relative to topical reports analyzing 25 the ability of B&W nuclear plants to conform to g
u
\\.%
p.**
1 Dunn*
437
-s 3'
s s
2 to CFR 50.467 o
3 A
one of the criterion in.10.. CFR 50.46.
4 that the clad temperature shall not exceed 5
2200 degrees Fahrenheit.
6 Q
With the peak clad temperaturet
~
7 increasing as the break size gets smaller, how 8
did you determine that the.04 square foot break 9
was the most limiting small break?
~'
Throughconsiderationsofthe?mbchanisms 10 A
11 which lead to this result.
12 Q
Didn't you have anf concern that 13 there might be a smaller break that would ' produce 14 significantly higher peak clad temperatures?
15 A
No.
~
T 16 Q
Isn't it a fact that there are smaller 17 size breaks at the pump suction which would 18 produce higher. peak clad temperatures?
19 A
Not that I am aware of.
s 20 Q
Have you ever analyzed breaks smaller 21 than 0.04 square feet at the pump suction?
l 22 A
For this particular plant type, I don't t
i 23 believe that we have analyzed it in the fashion O
24 that we have analyzed these (indicating), in V
25 that these have specific computer evaluations i
__._,_m_. _
qN' ;3,) '-
x
,,. g s,
l ?
y t - 1
[,
(
b
+,,
-; /
l t
- m' a
c v
,r
+
l
< / <-
i j
. Dunn 438
/.
g j, I.
u d t&,
d 4
i sq J2 behind thhih.~"'j
<.,n
- p
.-a.
i t Y ",; h.m' f,
Y
'/ ~/
3 Q;
For "b eak that is incrementally e
r.
a
,M I
p-fi, ' ' f:
4' sma3lerrt).an 0,04 square feet at pump suction, e
^
R. :) ~;
.c fa 7; f 7,- f j
,5 is itjyour belio0 that the peak clad temperature
'p s,
j 6
v$uld-he greater than 978 degrees Fahrenheit?
i/
' k",
7,.
1
'.i.
't
]
- j 7 l
' 1 A
The term "incrementally," in my mind r
refers to a very small element typically used 3
a I; A j
x 9
in the derivation of the mathematical procedure
.=
(
LIO[
calculus.,
9 11 Q
That, is exactly the sense in which
~
12 I was using it.
- j J t
t.,
13 A
And I believe the trend would be that the 14 temperature would be incrementally smaller than 15 indicated here.
16 Q
Why do you believe the temperature l
i 17 would decline?
l t
l 18 A
The basis for the break spectrum was to 19 examine accident's which utilized different 20 portions of the emergency core cooling system 21 for mitigation of the accident.
Considering the 22 mechanisms of small break and the way in which 23 the accidents evolve, it is my judgment that 24 smaller breaks performed with this evaluation 25 technique and at the pump suction would utilize a=
a
i i
1 Dunn 439
)
\\-)
2 the initial inventory of the reactor coolant i
3 system to provide core cooling for a longer 4
time, allowing the high pressure injection system 5
more opportunity to build the coolant level 6
within the reactor coolant system, thus achieving 7
lower uncovery levels at a longer period of 8
time at which lower decay heat levels would 9
exist, and the calculated temperatures would t
10 therefore be slightly reduced.
11 Q
What is the break size at pump f h.
12 suction which produced the highest peak cladding G
13 temperature?
14 A
With these methods of analysis, it would 15 be reasonably close, if not exactly,.04; perhaps 16 slightly larger.
17 Q
Under the analysis in BAW-10103 and 18 10052, am I correct that no operator intervention 19 is needed to actuate emergency core cooling 20 systems in order to achieve cooling in conformance 21 with 10 CFR 50.46?
22 THE WITNESS:
Could I have that read 23 back, please.
24 MR. SELTZER:
I will restate it.
25 Q
At the time that BAW-10103A, Revision
'... & m
I Dunn 440 ggN 2
3 was isaged, was it your understanding that no 3
operator intervention was necessary to actuate 4
the emergency core cooling systems required to 5
maintain core cooling in conformance with 6
A Yes.
8 MR. SELTZER:
I would like to mark 9
as GPU Exhibit 90 a memorandum from Jim t
10 Taylor to distribution including. Mr. Dunn, 11 entitled " Preliminary Report of Safety 12, 1978.
12 Concern PSC 10-78," date,d April,
~
13 (Memorandum dated April 12, 1978, 14 from J.
H.
Taylor to Distribution, was 15 marked GPU Exhibit 90 for identification, 16 as of this date.)
17 Q
Subsequent to the issuance of 18 BAW-10103A, Revision 3,
did B&W discover that 19 operator intervention was necessary to achieve 20 core cooling in conformance with to CFR 50.46 21 for some of the breaks covered in that topical 22 report?
23 A
In the fashion that the topical report was 24 intended to bound breaks anywhere within the 25 primary system, B&W did discover the possibility r
t h-
1 Dunn 441 2
of alternate break size -- excuse me, an alternate break location could produce more severe 3
results than was indicated in BAW-10052 and 4
5 that mitigation of these accidents under the 6
assumptions -- assumptions posed by 10CFR 50.46, 7
Appendix K, required the rearrangement of the 8
ECCS discharge paths, which for a time was 9
accomplished in the plants by operator inte rvenE.io n.
10 11 Q
Am I correct that it was your section 12 which discovered this fact after 10052 and 10103 13 had been issued?
14 A
It was my unit.
15 Q
How did your unit happen to discover 16 it?
17 A
As I recall, we had been performing some 18
' work on the Babcock 205 design, and par of the 19 emergency core cooling system configuration on 20 the Babcock 205 design is a cross coupling of the high pressure injection lines and it 21 22 occurred to the engineer involved that the 23 general sizing of the high pressure injection D
24 systems for the 205 design and the 177 design
(-
2.5 were reasonably equivalent when normalized s
b % ; n-
--.a.,e
.a
l 1
Dunn 442
(N
%-]
2 against power, and he could not explain why 3
cross-coupling of the system was necessary for 4
the 205 design and not necessary for the 177
(
5 design.
6 Q
Is that your signature on the third 7
page of GPU Exhibit 90 marked for identification?
8 A
Yes.
9 Q
what does your signature at the t
10 bottom signify?
11 A
In this document my signature signifies 12 that the words contained in the remainder of the
(
13 doc 2 ment are a reasonable and accurate 14 representation of the intent of the author.
15 Q
Does it also mean that you had 16 reviewed the analysis presented by Mr. Jones 17 and that you felt that it was accurate?'
18 A
No.
19 Q
Have you reviewed the material 20 presented by Mr. Jones and believed that it was 21 accurate?
I 22 A
Yes, I had done that.
23 Q
In item 2 at the top of this third LJ of GPU Exhibit 90, it says, "On April 7, a
24 page 25 0.04 square foot small break analysis at the m'
1 Dunn 443 2
pump discharge on the SMUD plant was completed.
3 Results show substantial core uncovery.
4 The SMUD plant is a 177-FA lowered-5 loop plant; is that correct?
6 A
Yes.
7 Q
And it is a plant that was covered 8
by BAW-10103A; right?
9 A
Yes.
t 10 Q
And substantial core uncovery for 11 the 0.04 sugare foot small break at pump 12 discharge is a result that was'not described in 13 BAW-10103A; right?
14 MR. FISKE:
I am sorry, could I 15 hear the question, please.
16 (The reporter read the question.)
17 A
Yes, I think that is a fair statement.
18 Q
Under itcm 6, description of safety 19 concern, it states, "For small breaks.at the 20 pump discharge of the 177-FA lowered loop plants 21 (identified above), the high pressure injection-22 pumps are inadequate to control the accident to the 23 criteria of 10 CFR 50.46."
/~T You believed that was an accurate 24 25 statement at the -tme, did you not?
+
r e--,
y q
y n,,
-,.--eq
+-
--g,.-------+.--e--mr-v y---'--r
+---,r-w-daw-r=-ev'*--- - - -
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d 1
Dunn 444
-s
%J 2
A Taken in the context of the design of the s
injection trains and the mode of operation of 3
4 the injection trains at that time, I believe that L
5 to be an accurate statement, 6
Q And the reason that the high 7
pressure injection pumps were inadequate to 8
control the accident in conformance with 10 CFR 9
50.46 was that the use of those pumps and the connected at that' time was 10 way the trains were 11
" inadequate to maintain cladding temperatures
/h 12 below 2200 degrees Fahrenheit"; is that right?
Q) 13 A
A computation of the clad temperature which 14 would result had not been performed,'but out 15 of our experience in correlating core uncovery 16 to cladding temperature, we had expectations, 17 strong expectations, that the resulting cladding 18 temperature for this particular case would be 19 in excess of 2200 degrees Fahrenheit.
20 Q
And it is because of your belief 21 from prior calculations and experience that the 22 cladding temperature would excoed 2200 degrees 23 Fahrenheit you believed that for this particular f.
(._h
~
24 small break that the plant would not be in
/
25 conformance with 10 CFR 50.46 as then hardwared L*'
{
~
i 445 1
Dunn
~_).
z 2
and operated; right?
s 3
A Yes, given the assumptions imposed by 50.46 4
Q Based on that conclusion, you 5
agreed, did you not, with the boxes checked at 6
the top of the page, namely, that this problem 7
presented a "significant deficiency" and a 8
" substantial hazard"?
9 A
At this time I cannot recall the reason 10 for checking the particular boxes.
11 Q
Does "significant deficiency,"
12 as those words are used on the preliminary report I')
\\u./
refer to a deficiency from 13 of safety concerns, 14 10 CFR 50.467 15 A
I don't know.
I would have to reread the 16 definition given in our procedures at that time 17 to pass a judgment.
18 Q
It is a fact, is it not, that B&W 19 subsequently reported this safety concern to the 20 NRC pursuant to its reporting obligations under 21 10 CFR, Part 21; isn't that right?
22 MR. FISKE:
I will object to the form 23 of the question.
(uJ You can answer it.
24, subsequently reported 25 A
It is a fact that wo
1 Dunn 446 gs
}
iN/-
2 this concern to the NRC.
s 3
As to whether or not that was under 4
our obligation from ;0 CFR-- well, 20, part 21 r
5 or not, I don't recall.
6 Q
Jim Taylor, on the front page of 7
GPU Exhibit 90, says, in the second paragraph 8
of the document, that you received, "A preliminary 9
indication is that this concern will be reportable
(
10 to the NRC under the requirements of 10 CFR 21."
11 Do you see that?
'"N 12 A
Yes.
13 Q
What was your understanding at the 14 time of this reference to the requirements of 15 10 CFR 21?
In other words, what do you,think 16 he is referring to?
17 MR. FISKE:
You mean, what did Mr.
18 Dunn think then when he got the memo?
19 MR. SELTZER:
Yes.
20 Q
What was your understanding at that 21 time, Mr. Dunn, of the requirements of 10 CRF, 22 part 217 23 A
I can't say that I recall what my 24 understanding of the requirements of 10 CFR 21 25
.were at that time.
I Dunn 447
(~}
O 2
Q Did you have an understanding then that there were certain safety matters which B&W 3
4 management was under an obligation to report 5
to the NRC when they came to the attention of 6
B&W management?
7.
A Yes.
1 8
Q Did you understand that that 9
reporting requirement was described entirely or
(
10 in part in 10 CFR.part 21, or have you since come 11 to learn that?
12 A
I think it is fair to say that I understood
[)h
(
13 that that reporting requirement was described in 14 part in 10 CFR 21.
15 Q
Did you believe that there were 16 other sources of that reporting requirement?
o 17 A
I don't know that I can properly aistinguish 18 between that particular time and later times.
19 MR. SELTZER:
Is this a time when you 20 think it would be appropriate to have lunch?
MR. FISKE:
Sure.
21 22 (whereupon, at 12:30 p.m.
a lunch 23 recess was taken.)
s_-
2, 25
448 0
2 AFTERNOON EESSION s
3 4
BERT MERR IT
- DUNN, resumed.
5 (Topical Report, October 1975, 6
entitled "Multinode Analysis of Saall 7
Breaks for B&W's 2568-MWt Nuclear Plants -
8 Revis. ion 1" was marked GPU Exhibit 89 for 9
identification, as of this date.)
(
10 EXAMINATION (continued) 11 BY MR. SELTZER:
[ )/.
12 Q
Mr. Dunn, I am sure you know that 13 your testimony this afternoon continues to be 14 under oath.
15 A
Yes.
16 MR. SELTZER:
I would like to mark 17 as GPU Exhibit 91 a letter from Jim Taylor, 18 the Manager of Licensing at B&W, to Dr.
19 Ernst Volgenau at the NRC, dated April 20 14, 1978.
21 (Letter from James H.
Taylor to 22 Dr. Ernst Volgenau at the NRC, dated 23 April 14, 1978, was marked GPU Exhibit 91
^
24 for identification, as of this date.)
25 Q
Have you had a chance to look at t
1 Dunn 449 2
GPU Exhibit 917 3
A I have looked at the front of it.
I 4
have it in front of me.
5 Q
Goes GPU Exhibit 91 and the attached 6
report refer to the same item which was the 7
subject of the preliminary safety concern which 8
you put your name to in GPU Exhibit 907 9
A It appears to.
10 Q
Did your unit prepara the pages 11 that are attached to Jim Taylor's transmilial 12 letter in GPU Exhibit 91?
13 A
I believe we created input for_the pages I
14 but did not actually create the pages themselves.
l 15 But I don't know positively.
f 16 Q
Do you believe that your unit 17 prepared the text which is contained in-these 18 backup pages?
19 A
I don't believe so.
l 20 Q
Did you review the material that is 21 being transmitted by Jim Taylor to the NRC at 22 or before the time that your company sent this
.23 to the NRC?
24 A
I do not recall reviewing it or not reviewing 25 it, so I would have to speculate.
I - --
t
~
1 Dunn 450 2
Q From your familiarity with the 3
business practices of Babcock & Wilcox, would it 4
be the normal practice for the head of the ECCS s
5 analysis unit to review an evaluation of 177 6
fuel assembly lowered-loop ECCS concern before 7
such a report was transmitted to the NRC?
8 A
It wouldn't be necessary and the practice 9
is sometimes done that way, sometimes not.
t 10 Q
Would somebody in your unit, if not 11 you, review it, as a general practice?
(~T 12 A
More often than not, somebody in my unit
%-]
j 13 would review it, but it is not, again, necessary 14 to do that.
15 Q
Would you turn to the second page 16 of GPU Exhibit 91.
It says on the second page 17 of the document:
"This report documents the 18 evaluation of a concern wherein it was postulated 19 that for B&W 177FA lowered loop plants, the 20 analysis presented in BAW-10103A, 'ECCS Analysis 21 of B&W's 177FA Lowered-Loop NSS,' may be 22 nonconservative for a small break in the reactor 23 coolant pump discharge."
O' 24 Do you see the word "nonconservative"?
25 A
Yes.
w-r
---v---,-
,,,, - +,
1 Dunn 453
(/.
2 Q
That is a euphemism that refers 3
to the fact that there could be core uncovery 4
for small breaks in the reactor coolant pump 5
discharge?
6 A
No.
7 Q
Your analysis as of the time that 8
you were communicating with the NRC on April 14, 9
1978 showed that there could be core uncovery 1
10 for a small break at the pump discharge; isn't 11 that right?
12 A
I didn't catch your reference.
If you meant 13 the analysis which led to the production of the 14 PSC on April 12th, I guess dated April 7th, 15 that analysis indicated significant core uncovery.
l 16 Q
And isn't it a fact that it is the 17 significant core uncovery that made the prior 18 topical report on the 177 plant nonconservative?
19 A
No, it is the fact that the core uncovery 20 that occurred as -- is to a far greater extent 21 than the previous, the previous analysis had 22 shown.
23 Q
In what way was the prior analysis O~
24 nonconservative?
25 A
The prior analysis had portrayed the
1 Dunn 452 g3
~
(_)
2 accident -- excuse me -- had stated that the 3
accident at the pump discharge in the approximate 4
casa of.04 square foot could be viewed as the 5
worst small break accident for the purposes of 6
evaluating the capability of the emergency core 7
cooling system, emergency core cooling system's 8
capability of assuring adequate core cooling 9
in conjunction with 10 CFR 50.46.
t 10 At this time we are saying that that 11 may be nonconservative because we had indications 12 to believe that a different break or accident 13 would produce higher peak cladding temperatures, i
14 and thus we had information that the' spectrum, 15 which we thought had bounded the result,s in the 16 the results of accidents in the primary system 17 did not in fact or was not indicated an9 longer i
18 to bound those results.
~
19 Q
In other words, your previous 20 assumption that the.04 square foot break 21 bounded was wrong?
22 A
I don't know that I would use the word l
I 23
" assumption."
O 24 our previous representation of the 25
.04 square foot break contained in the document
.v.
1 t
t 453
'w 1
Dunn f~
N, one; here we 2
BAW-01152 was shown after this 3
have the indication of it.
It was shown after 4
this to be wrong.
r 5
Q You said a moment ago that as of 6
April 1978 you learned that there would be core 7
uncovery for the.04 square foot break to a 8
far greater extent than previously shown in the 9
10052 or 10103 topical reports, t
10 Did you misspeak?
I thought those core uncovery for the 11 topical reports showed no 12
.04 square foot break.
[)b 13 A
The -- well, I guess I would like t
i 14 to be sure and check the documents relative to i
I m,sspoke i
15 no core uncovery.
I do not believe 16 myself before.
17 Q
You have in front of you 10052 and 18 10103.
19 A
The evaluation in 10052 shows core uncovery l
20 for the.04 square foot break.
21 Q
on what page?
l l
22 A
46.
l l
23 Q
At what time does ccee uncovery l
[,)
L
\\~s 24, appear?
25 A
Slightly after 1600 cycles.
It would t.
1 Dunn 454 b
V.
2 appear to,be about 1750.
s 3
Q Is the line that says " top of 4
active region" the line that shows the volume 5
of water necessary to keep the core covered?
6 A
No.
7 Q
What on that chart signifies the 8
point of core uncovery to you?
9 A
A point at which the solid line crosses L
10 the dashed line indicated top of active region, 11 that the graph refers to mixture level and it
(~}
12 refers to inter-vessel regions,'which have specific
's /
13 definitions and do not refer to the amount of 14 water required to keep the core covered.
15 Q
Even with the fuel core unc,overy, 16 to a limited extent shown on page 46 of BAW-10052, 17 do I understand you to be saying that the peak 18 clad temperature is still within the margins 19 permitted by 10 CFR 50.46?
20 A
Yes.
21 Q
When you say "yes,"
you mean yes, at 22 the time that the analysis was done and issued 23 in 10052; right?
).
24 THE WITNESS:
Please repeat the last 25 few questions and answers.
m
1 Dunn 455 p
N_)
2 (The reporter read the record.)
3 A
Yes.
Mr. Seltzer, the record shows me 4
referring to liquid volume to keep the core r
5 uncovered.
I believe it should show liquid 6
volume, in the previous answer, to keep the core 7
covered.
8 Q
O.K.
I think the reporter also 9
read " inter-vessel mixture."
I think you said t
10
" inner vessel," did you not?
11 A
Yes.
t
!(/)
12 g -
It was only after BAW-10052 was
~
13 issued that you realized that the core uncovery I
14 for the.04 square foot break at pump' suction 15 could lead to peak clad temperatures in, excess 16 of those permitted by the 50.46 criteria; right?
17 A
No.
18 Q
It was at the discharge that the 19 criteria were violated; is that right?
20 A
That is correct.
21 Q
The uncovery of the core leading to l
l
)
22 violation of ECCS acceptance criteria contained 23 in 10 CFR 50.46 occurred if there was no
.O 24 operator action; is that right?
And I would call 25 your attention to analysis of occurrence on the L..
i i
Dunn 456 gg L) 2 fourth page of GPU Exhibit 91.
3 THE WITNESS:
Could you repeat that 4
question to me, please.
5 (The reporter read the question.)
6 A
In conjunction with the assumptions for 7
the evaluation of these types of accidents 8
contained in 10 CFR 50.46 and Appendix K, the 9
unacceptable results or the cladding temperatures
(
10 felt to be in violation of 10 CFR 50.46 occurred 11 with no operator action.
/~N 12 Q
It is a fact, is it not, that B&W i )
13 came up with a prescription for operator action 14 in order to bring the 177-FA plants into 15 conformance with 10 CFR 50.46; isn't that true?
16 A
Yes, that is true.
17 Q
What was the operator action which 18 B&W prescribed in order to bring its 177-FA 19 plants, including Three Mile Island Unit 2, 20 into conformance with 10 CFR 50.46 and Appendix K?
21 A
To rearrange the valving at the discharge 22 of the high pressure injection pumps to allow 23 for four points of penetration into the reactor
,3b 24 coolant system in the event that only one high 25 pressure injection pump was operating.
- ~
~
1 Dunn 457 f"%
U 2
Q The cross-connection is something 3
that would be performed manually by the operatore 4
is that right?
5 A
The instruction was-of an interim nature 6
to allow time for automation, and during the 7
interim it would be performed manually.
8 Q
Do you know how long it took or 9
was projected to take to make the cross-connection t
10 automatic?
In other words, how long would it 11 take to retrofit the plants?
12 A
I do not know that answer defin_itively.
13 Q
More than a year?
14 A
It is my recollection that the time frames f
15 discussed were possibly in excess of a year.
l 16 MR. SELTZER:
I would like to mark i
~ 92 17 for identification as GPU Exhibit _
18 another letter by Jim Tay1cr, this time 19 to Robert Baer, Chief of Reactor Safety 20 Branch at the NRC, dated May 1,
1978.
A 21 copy is indicated to Mr. Dunn.
l 22 (Lecter dated May 1,
1978, to Mr.
23 Robert L.
Baer at the NRC, from James H.
s
\\_
24 Taylor, with attachment, was marked GPU 25 Exhibit 92 for identification, as of this
1 Dunn 458 2
date.)
s 3
Q Is GPU Exhibit 92 a copy of a piece 4
of correspondence which you received in or about 5
May 1978 in the regular course of business?
6 A
Yes.
7 Q
Did you or your unit contribute to 8
the preparation of the analysis which is attached 9
to GPU Exhibit 927
(
10 A
Yes.
11 Q
Did you review it before it was sent 12 to the NRC7 13 A
Yes.
~
14 Q
Would you turn to the section that look at 15 is headed " Introduction" and would you,
16 six lines down, the sentence beginning "These 17 results show..."
18 Do you see that sentence?
19 A
Yes.
20 Q
It says there:
"These results show 21 that it is necessary to use operator action during 22 the early stages of the postulated accident, 23 to effectively mitigate the accident consequences
~
24 and meet the criteria of 10 CFR 50.46."
25 I take it you believed that that
,,-m-ge,7me__-,,.,_m,y,_
a._,,,
1 Dunn 459 O
2 statement was accurate at the time it was written; 3
is that right?
4 A
Yes.
5 Q
Would you look at the page numbered 6
2 at the bottom.
Do you see item k.
on that 7
page?
8 A
Yes.
9 Q
That item states:
" operator action is t
10 taken to increase the high pressure injection 11 flows to the intact cold legs at 10 minutes
[ D.
12 following the ECCS initiation signal."
NJ 13 Is that the operator action which 14 is required to meet the criteria of 10 CFR 50.467 15' A
This is the assumption used in the 16 analysis which is extracted from the required 17 operator action.
}
18 Q
The required operator action that 19 you are referring to is item 3 on page 5 and 20 continuing onto page 6 is that right?
21 A
Yes.
That being a generic description.
22 Q
At the top of page 6 it states:
23 "The above actions initiated at five minutes and O
24 completed within 15 minutes subsequent to the 25 ESPAS actuation ens ares adequate high pressure
I I
(~N 460 1
Dunn
(_)
2 injection flow for accident mitigation."
3 Does that mean that the operator was i
i 4
expected to begin taking the action necessary 5
to bring the plant into conformance with 6
10 CFR 50.46 within five minutes after the start 7
of the ESFAS actuation?
f.
8 A
That is my recollection.
9 Q
In order for the operator to know t
10 what he was expected to do, what would*the 11 operator have to recognize in those first five
[)
12 minutes?
\\_/
13 A
The details of the operator action were in 14 plant specifications and handled by the customers 15 within their own procedures.
Generically the 16 operator would have to recognize the occurrence l
17 of an ESFAS.
i l
18 Q
What is ESFAS?
19 A
I believe it stands for emergency safeguards 20 features actuation signal.
21 Q
I am sorry, I didn't mean to 22 interrupt you.
23 You would have to recognize an
'v 24 actuation of emergency safety features right?
25 A
Yes.
And that flow was occurring in only
1 Dunn 461
/T 2
one of the ECCS trains.
s 3
Q Now, according to GPU Exhibit 92 4
which you reviewed, the operator action was 5
supposed to be commenced at fivue minutes.
6 How much margin for error was there, 7
if the operator missed the five-minute mark?
8 A
That would be an answer that I would have 9
to specifically evaluate on a plant-by-plant t
10 basis in conjunction with the flows as' they 11 would actually occur.
()
12 There was margin for error.
13 Q
If the operator hadn't acted within 14 20 minutes, it is a fact, isn't it, t' hat at the 15 177-FA plants the core would be uncovered?
16 A
Under the assumptions posed by 10 CFR 17 50.46', yes.
18 Q
And it is also a fact, isn't it, 19 that in the 15 minutes between when he should 20 have initiated the operator action callr6 for 21 in GPU 92, and 20 minutes, without any opurator 22 action there would be fuel melting, wouldn't there?
23 A
I could not answer that question without g
x,)
24 detailed evaluation.
25 Q
In the 15 minutes of no operator b':2
,b
?
i Dunn 462 g
~Y 2
action, the peak cladding temperature would 3
exceed 2200 degrees Fahrenheit, wouldn't it?
4 A
I could not answer that question without i
5 detailed evaluation.
6 Q
Is there anything in GPU Exhibit 92 7
which would indicate what the cladding temperatures 8
become without operator action?
9 A
I don't believe there is anything in here
(
10 that would allow us to answer the question.
11 Q
Has your section done, or your unit 12 done analyses of at what point the peak cladding
( )-
13 temperatures exceed 2200 degrees?
14 A
To my recollection, not to the point at 15 which we could determine a specific time delay.
16 Q
Did you have any communication directly 17 with the NRC or any employee of the NRC with for 18 regard to B&W's analysis or prescription 19 dealing with the pipe break described in.GPU 20 Exhibit 927 21 THE WITNESS:
Would you read the 22 first clause of that back, please.
23 (The reporter read the record.)
b 24.
A Yes.
25 Q
What was the nature of that
. -.. ~ - -
. - - ~
1 Dunn 463
(']
'%)
2 communication?
s 3
A Description of the incident, disclosure 4
of the primary causes for the accident, 5
description of the analytical techniques 6
utilized to show compliance, explanations-of 7
why compliance resulted, defense of the break 8
spectrum utilized to demonstrate compliance.
9 Q
Was that an oral communication?
t 10 A
Both oral and written.
11 Q
Whom did you meet with?
O(,)
12 A
I don't believe at this time I'can recall 13 the individualst names.
14 Q
Did the NRC accept B&W's prescription 15 of operator action as a means for complying with 16 10 CFR 50.467 17 A
on the basis that it was an interim 18 measure and would be automated at some t_ime, it 19 is my understanding that they accepted it.
20 Q
Is proper operator handling of 21 emergency safety features something that is 22 incorporated in B&W's analysis of accidents 23 for compliance with 50.46?
g-
\\_/
24 A
During the interim period while we are 25 awaiting automation of this action, active
i 9
p 1
Dunn 464 NJ 2
operator response to the accident was a 3
requirement and part of the analysis and part 4
of the licensing basis for the plants.
5 Q
What, if any,- assumption is made 6
in analyses done by your unit that operators 7
will not interfere with the functioning of 8
emergency safety features which are required 9
for compliance with 50.46?
E 10 MR. FISKE:
Is this just k generic 11 question or are you referring to this
{)
12 specific evaluation (indicating)'?
13 MR. SELTZER:
I ~am not referring to 14 the specific evaluation.
15 MR. FISKE:
Could I hear the question 16 again, please.
17 (The reporter read the question.)
18 A
Subject to the possibility that so.meone 19 might interpret the operator action required 20 within GP'.' Exhibit 92 to be interference, the 21 assumption is that the operators will not, 22 during small break LOCA, interfere with the 23 functioning of the emergency core cooling systems.
g-
\\-/
24 Q
Is it correct that the assumption is 25 made that the procedures and training under which
.,..r
--.r.,
-.--c.
1 Dunn 465
~
v 2
the operators are functioning are such that they 3
will not interfere with the operation of r
4 emergency safety features which are required to 5
operate for conformance w-ith 50.467 6
MR. FISKE:
I will object to the 7
form of the question, but you can answer it.
8 A
I don't believe I would phrase it that way.
9 I would rather phrase it that within the analysis t
10 it is our assumption that the emergency core 11 cooling systems will continue to function during A)
I 12 the course of the accident.
13 Q
In making that assumption, are you 14 assuming that operators will not prematurely 15 terminate the function of the emergency core 16 cooling system during the accident?
17 A
Again we are assuming that at least one 18 high pressure injection train continues.to 19 operate during the course of the small break l
o 20 loss-of-coolant accident.
i 21 Q
It follows, from what you have just j
22 said, does it not, that you were assuming that i
(-}
operator intervention will not arrest the 23
%J 24 operation of that high pressure injection train 25 which you are depending on for conformance with
' ~ '
1 Dunn 466 2
10 CFR 50.46; isn't that right?
3 A
I choose to repeat my previous answer 4
as opposed to making any logical extension or 5
any extension whatsoever.-
6 Q
Isn't it a fact that operator 7
intervention is one way in which a plant could 8
lose the functioning of its high pressure 9
injection system?
t 10 A
operator intervention in the fashion of 11 terminating or what is sometimes referred to as
[h 12 securing the high pressure inj,ection system g,/
13 or low pressure injection system would have the 14 possible effect of depriving the facility of 15 high pressure or low pressure injection. flow.
16 Q
In making the assumption which you 17 said your analyses have made that flow through the 18 at least one train will continue during,
l 19 small break loss-of-coolant accident,- aren't you 20 assuming that there will not be operator 21
-termination of that high pressure injection flow?
22 A
During the analysis in response to the 23 requirements of 10 CFR 50.46 we made the
{~3
\\_/
24 assumption that for whatever reason, at least 25 one high pressure injection system or low Y.
~
i 1
Dunn 467
)
2 pressure injection system, depending on the 3
accident, continued to function throughout the
/
4 course of the transient.
5 Q
It is inconsistent with that 6
assumption for operator action to terminate or 7
secure all high pressure injection flow or all 8
low pressure injection flow, depending on the 9
accident; isn't that right?
t 10 A
Yes.
11 Q
You said you would have to see the (7
12 procedures for processing a safety concern to q_j 13 tell me what "significant deficiency" meant 14 as that term was used on the PSC form which was 15 part of GPU Exhibit 90.
16 MR. SELTZER:
Let me mark for "he 17 identification as GPU Exhibit 93 t
18 Babcock Administrative Manual, subject:
19 Processing of Safety Concerns, Revision 6.
20 (Babcock & Wilcox Company l
21 Administrative Manual, Policies and 22 Procedures, Revision 6, was marked GPU 23 Exhibit 93 for identification, as of this J
24 date.)
25 Q
Is this the procedure that you were
%w g
['}
I Dunn 468
%-)
2 referring to for the definition of a significant 3
deficiency?
4 MR. FISKE:
Mr. Seltzer, I don't 5
know whether you meant to give him this 6
one or not.
This says June 20,
'78.
7 MR. SELTZER:
Let me also mark 8
Revision 5 then, which is November 21, 1977, 9
and we will have both, t
10 (Babcock & Wilcox company 11 Administrative Manual, Policies and
()
12 Procedures, Revision 5, was marked GPU 13 Exhibit 94 for identification, as of this 14 date.)
15 Q
Are these the procedures th~a t you 1
f 16 were referring to for the definition of what l
l 17 is a significant deficiency?
i l
l 18 A
These procedures contain the definition 19 or the guidance that I would use.
20 MR. FISKE:
Off the record.
(
21 (Discussion off the record.)
22 (Whereupon, a recess was taken.)
23 MR. SELTZER:
I would like to mark i
i
~)
f 24, as GPU Exhibit 95 a B&W Policy and
(
25 Procedure regarding reporting of defects
[
L
,~
1 Dunn 469 4
2 and, noncompliance concerning safety, 3
10 CFR 21, dated December 6th, 1977.
(
4 (Babcock & Wilcox Company 5
Administrative Manual, Policies and 6
Procedures, Number 1716-A1, was marked 7
GPU Exhibit 95 for identification, as of 8
this date.)
9 Q
Can you identify GPU Exhibit' 95 ti 10 marked for identification?
11 A
I suppose so.
(G) 12 Q
Is it anything tha.t you have seen 13 before today?
14 A
I don't recall seeing this specifically.
15 Q
Do you think you have seen anything 16 like it or any part of it?
somethinhlike it.
17 A
Yes, I think I have seen 18 Q
Was GPU Exhibit 95 or something like 19 it circulated to you prior to the Three Mile 20 Island accident?
21 A
To me personally?
22 Q
Personally, impersonally, generally, T
23 specifically; anyhow.
s_/
24 A
Yes.
25 Q
How did it come to your attention?
-M
'M e
-y----
,----r
e 470
(T 1
Dunn
-Q!
2 A
I don't think I would phrase it as coming 3
to my attention.
5 4
I maintained a station in which all 5
policies appropriate or applicable to our i
6 division are maintained.
7 Q
What do you mean by " station"?
8 A
A set of books that is actually maintained 9
by my secretary.
e 10 Q
Prior to the Three Mile Island 11 accident, do you believe that you were aware of 95 12 this particular policy which is in GPU Exhibit s_)
13 or some policy substantially like it?-
14 A
In the fashion of " aware" meaning knowing 15 specifically that it is there and recognizing 16 its potential use, I don't think this is a 17 procedure that I paid a great deal of at"tention 18 to.
19 Q
Would you look at the last page of 20 GPU Exhibit 95.
21 Prior to the Three Mile Island 22 accident, do you have any recollection of seeing 23 that page posted at B&W7
(^3
(_/
24 A
I am not sure.
25 Q
Before the Three Mile Island accident,
1 Dunn 471
[
m.-
2 do you know if B&W had an officer who was 3
responsible for B&W's reporting requirements under 4
A I do not know.
6 Q
Putting aside your February 1978 7
memoranda, prior to the Three Mile Island 8
accident did you ever report anything to anyone 9
at B&W which you felt should be reported as a t
10 defect or noncompliance pursuant to 10 CFR part 11 217 4
12 A
My unit processed a preliminary'significant 13 deficiency report.
I believe it was my 14 understanding that that could be connected with 15 10 CFR 21 or 50, 55E.
16 Q
Are you referring to a PSC in addition 17 to the one contained in GPU Exhibit 907-18 A
No.
That I recall today, that is the one 19 I am referring to.
20 Q
The day of the Three Mile Island 7
21 accident you were at work in Lynchburg, Virginia; 22 right?
23 A
That is correct.
LJ 24 Q
You attended a meeting at about 25 11 a.m.
on March 28, 1979 at which yod heard
1 Dunn 473 2
Q
>Let me read to you from your 3
Rogovin Commission testimony at page 93 -- page 4
73, rather.
I think you can see on the botton 5
f page 72 there is a ref.erence to 10:45 in the 6
morning, and then continuing onto the next page 7
in your first answer at line 8 you said, "And 8
after that I was told to give a very short 9
briefing to people on the floor so they wouldn't t
10 find out about it first on the national news."
11 Do you see that?
12 A
Yes.
13 Q
Does that refresh your recollection 14 that you were told to give a short briefing to 15 PeoP e on the floor?
l l
16 A
Well, I don't believe I misrepresented l
17 myself in the Rogevin Commission, but instilling 18 any better recollection today, no.
i gg Q
Do you remember telling anybody on i
the floor what had happened at Three Mile Island?
20 A
Today I can't say I remember it one way 21 l
or the other.
22 23 Q
At a meeting in the afternoon at 24 Lynchburg, you and Cartin reco.gnized that super i
25 heating of the steam in the primary system was 1
1 Dunn 474 V
2#
occurring; is that right?
3 A
We recognized that the information we had 4
been given via telephone indicated the super 5
heat conditions existed w-ithin the reactor i
6 coolant systhm.
7 Q
Was that the first time that you 8
became concerned that something serious had 9
happened at Three Mile Island and that the t
10 situation had not been brought under dontrol 11 in the morning?
12 A
No.
13 Q
When did you first realize that the 14 situation had not been brought under control 15 at Three Mile Island?
16 A
I believe it to be a gradual process function "f various o
17 occurring that afternoon as a 18 inputs, and not really occurring at any one time 19 relative to " brought under control," starting l
20 with the question asked me by Mr. Parks.
L 21 Q
Parks?
l 22 A
Yes.
23 Q
P-a-r-k-s?
l g
\\)
24, A
P-a-r-k-s.
25 Q
When did Parks ask you the seminal
-~
1 Dunn 475
-(~]
(/
2 question,,1f I can dignify it that way?
3 A
I thought Seminole was an Indian tribe.
4 Q
That is a good joke.
That is 5
seminal.
6 A
The question was asked shortly after lunch.
7 Q
What did he ask you?
8 A
In substance, as to whether or not a plant 9
at low temperature could be depressurized to E
~
10 pressures at which the decay heat system could 11 be brought into a functioning state by opening
()
12 of a leak area the size of th e,' P ORV, + a s I recall 13 it.
14 Q
What were the other events or pieces 15 of information which you received successively 16 which contributed to your increasing awareness 17 that there was a problem at Three Mile Island?
18 A
When'I determined an answer to Mr. Parks' 19 question and attempted to communicate it, I 20 became aware that Mr. Parks had not directly 21 asked the question, but had referred the 22 question to me from Allen Womack and Allen was 23 the person that needed the answer.
24 I then attempted to find Mr. Womack.
25 I found him in a room in the project management
Dunn 476 q
I
+
w' area of the building.
I became aware that the i
2 telechone in that room was connected to somebody 3
relaying site information and the situation 4
C within the room did not indicate that the plant 5
was in a controlled state.
Sonetime after 6
giving my answer to Mr. Womack, I became aware 7
of the information to indicate super heat in the 8
upper regions of the system was passed on, and 9
at that point I did become most seriously 10 concerned.
11 Q
Who was in the room with Allen'Womack, 12 as best you can recall?
Cartin?
13 A
Well, Lou was there when we got the 14 information on the super heat content and the 15
~
apparent super heat content in the upper regions 16 f
of the system.
~
17 Q
That is Lou Cartin?
f 18 A
Lou Cartin.
19 Bruce Karrasch was there.
l 20 Q
Allen?
(
{
21 A
I believe I communicated the information 22 on the capability of on the super heat 23 depressurizing the plant through the break to 24 Allen in that room.
25
1 Dunn 477 w
(d 2
People were coming in and out.
3 Kosiba was there part of the time.
r 4
Q Was Don Roy there?
5 A
Part of the time.
6 Q
Don Hallman?
7 A
To respond definitively, I would rather 8
trust my earlier testimony on the issue.
9 I would expect that Don was there, E
10 but I don't actually recall him being~there 11 right now.
)
12 Q
Was Deddens there?
13 A
1 don't recall one way or the other on 14 Jim Deddens at this time.
15 Q
You have previously testified that 16 you had difficulty convincing the other people I
17 in the room that the plant was in troubl_e.
That l
18 is at page 79 of your Rogovin Cor.tmission testimony.
19 Page 79, line 21, you were asked:
"Did you have 20 any difficulty convincing the other people in r
I (b
21 the room that the plant was in trouble?
22
" Answer:
Yes."
t 23 were you asked that question and 7s f
(_
24 did you give that answer?
25 A
I have no reason to doubt that I did.
i
. ~ -,
478 1
Dunn 2
Q Do you still believe that that answer 3
is correct?
4 A
I might change "in trouble" to "could 5
be in trouble" as being more correct.
l 6
Q so if the question is, did you have 7
any difficulty convincing the other people in 8
the room that the Three Mile Island plant could 9
be in trouble at that time, your answer would be E
M 10 yes?
11 A
In my perspective, yes.
(O,)
12 Q
You testified on p. age 80,.you were J
13 asked after you explained it, did they share your 14 concern.
15 Answer at line 5:
"After I convinced 16 them.
17
" Question:
Approximately how long 18 did that take?
19
" Answer:
I have guessed at about 20 40 minutes in the past.
I wasn't keeping track 21 of the time."
22 were you asked those questions and 23 did you give those answers' Igelieve so.
24 A
25 Q
What were you telling the others in h.,
6
1 Dunn 479
~2 the room during those approximately,40 minutes 3
to convince them that the plant could be in 4
trouble?
5 A
We were illustrating how a plant can 6
achieve temperatures in the hot leg which we 7
had received via the phone and that this would 8
mean, these temperatures would mean that we had 9
no assurance that the water level within the t
10 plant was not critically close to the' top of the 11 core and that it was very important to be sure 12 that we had sufficient high pressure _. injection 13 to maintain that water level above the core.
14 Q
Am I correct in inferring from your 15 prior testimony that initially it was only you 16 and Cartin who, to your knowledge, perceived 17 the possible danger of core uncovery wh'en you 18 heard the hot leg temperatures?
19 A
That remains my impression, yes.
20 Q
Of those who were in the room with 21 you that afternoon, whom did you have the 1
22 greatest difficulty convincing, to use your word, 23 that the plant could be in trouble?
24 A
I am not sure.
25 Q
Well, who were among the people that
-1 Dunn 480 2
you had difficulty convincing?
3 A
Again, I am not sure.
4 Q
Is there anybody other than Cartin
]
5 who was a quick convert, in other words, perceived 6
rather quickly that the plant could be in trouble?
7 A
what I remember is the first person that 8
I felt understood what I was saying -- he may 9
not be the first person that understood what I t
10 was saying -- and that was Mr. Dick Ko'siba.
11 Q
After Dick Kosiba, whom do you i
12 believe or did you have a feeling was.-next to V
~
13 comprehend that the plant could be in danger?
14 MR. FISKE:
Let me just say, Mr.
15 Seltzer, I will object to this whole line 16 of questioning on the same grounds that l
17 I have objected before, that you a.re 18 really asking Mr. Dunn for his perception 19 of someone else's reaction, and as he 20 indicated himself in the last answer, it 1
may well be that people appreciated the 2
22 problem long before Mr. Dunn perceived 23 that they did, which is one of the problems 1
with this kind of questioning.
24, 25 I will let him answer this last
~
-~
~
]
1 Dunn 482
('Y
'x 2
question, but I do want to note on the 3
record that I think this is not a proper 4
line of questioning.
5 MR. SELTZER:
Well, I strenuously 6
disagree.
I am 100 percent confident 4
7 that this is questioning that is reasonably 8
calculated to lead to the discovery of 9
admissible evidence, and if he identifies t
10 some people who he believes comp'rehended 11 quickly, we may want to take their O) 12 deposition to find out why they,were so
(
13 smart, and if there were others' who he 14 says were relative dunderheads and it took 15 them the full 40 minutes to catch.-on, 16 we might want to depose them to find out j
lapses in their education ma$y have 17 what j
18 led to this difficulty in comprehending 19 something so fundamental.
But I think this 20 is reasonably calculated to lead to the e
I 21 discovery of admissible evidence.
I don't 22 think I am off base on this at all.
23 MR. FISKE:
Well --
24 Q
Your counsel says he will let you 25 answer the question.
').
f' a
/"N 1
Dunn
,482 V
2 After Dick Kosiba, who do you think 3
understood what you were trying to say before 4
you convinced everybody in the room?
5 A
I do not recall.
6 Q
Were there any people who even by 7
the time the telephone call was being made to 1
8 the Island to get the instruction through that 9
they ought to have high pressure on if it is t
10 not already on, who still were not convinced 11 that there was a danger that the plant was at
)
12 super heat conditions or could be at' super heat?
t 13 A
I don't know.
14 Q
Who was at the 11 o' clock meeting 15' that you came into when you first learn'ed some I
16 of the details as to what was happening at the 17 Island?
l 18 A
Allan Womack and the other unit managers 19 wi thin the plcnt design section, and Mr. Bob 20 J ones, as I recall it.
i 21 MR. SELTZER:
I would like to mark 22 for identification as GPU Exhibit 96 your 23 copy of Bob Jones's notes of the 11 a.m.
24, meeting.
25 (Notes of Bob Jones of 11 a.m.
3s:
l
[~5 1
Dunn 483 2
meet,ing were marked GPU Exhibit 96 for 3.
identification, as of this date.)
4 Q
Is that your handwriting on the
{~
5 front of GPU Exhibit 967 -
6 A
It looks like it.
7 Q
What does your handwriting say?
8 A
It is very difficult to read.
9 I believe it says " Notes of R.
C.
L 10 Jones on 32 a.m. March 28th, '79 staff briefing 11 for Plant Design," with my signature below it.
l3
'(_)
12 Q
what does the nota, tion " item 1" at 13 the top mean?
14 A
I am not sure I recall exactly, but I.think 15 this note was made in conjunction with'the 16 production of documents for this lawsuit.
17 Q
what do the other notations-at the 18
_ top mean?
19 A
I can't be sure.
20 Q
When did you get a copy of Jones's 21 notes?
22 A
I don't recall.
I would have to speculate.
23 Q
would you say it was the day of the 24 accident or shortly after the accident?
25 A
Again, I would have to speculate.
1 Dunn 484 2
Q Do you recognize the next two pages 3
as being a description of items of information 4
which were reported, whether accurately or not 5
accurately, at the Design Section meeting on 6
March 28, 19797 7
A I recognize these as being Bob Jones's 8
notes from that meeting.
9 Q
And do you recall that some or all t
10 of these items were items which were brought up 4
11 at the meeting, the 11 a.m.
Womack meeting, (O
12 as you have called it in your note in the upper
.)
13 right-hand corner?
14 A
I arrived at the meeting during the 15 middle of it, and independently of these notes, 16 I do not recall very much of the meeting.
17 Q
You have previously testified that 18 you believed you learned in the morning that the 19 pilot operated relief valve had stuck upen.
20 Is that your recollection, that in 21 fact you learned in the morning that the PORV had 22 stuck open?
23 MR. FISKE:
Can you refer us to the 24 page?
25 MR. SELTZER:
Page 73 there is one hr
i r~N 1
Dunn 485 0
2 refe,rence to that, and page 84.
3 Q
Page 84, line 21, you were asked:
4 "Do you know when that fact was known to you?
5
" Answer:
I believe that fact was 6
known as early as the 11 o' clock meeting at 7
Womack's office."
8 Do you see that question and answer?
9 A
Yes.
10 Q
Do you see that the prior question 11 and answer is:
"Did you know that the PROV had 12 failed open?
13
" Answer:
I think I did."
14 Then the question is:
"Do you know 15 when that fact was known to you?
~
16
" Answer:
I believe that fact was 17 known as early as the 11 o' clock meeting."
18 Were you asked those questions and 19 did you give those answers during your deposition 20 by the Rogovin Commission?
21 A
I have no reason to doubt that I was asked 22 those questions and gave those answers.
23 Q
Did you believe those answers were 24, truthful at the time you gave them?
25 A
Yes.
,w-,,
,---n-
,-ww-,--w,,r
,,--,,w
.,a,,-a-
.-e,,
,,w
---.m,-n-,-,
---m-
s g
Dunn 486 2
Q Is it still your recollection that 3
you first became aware that the pilot operated i
4 relief valve had failed open at the 11 o' clock 5
meeting in Allen Womack's office?
6 A
Well, I think I phrased it properly in 7
response to the Rogovin Commission, and my 8
recollection today, if anything, is worse than 9
it was at that time of that meeting. (
10 Q
Do you have any recollection of asking 11 at the 11 o' clock meeting what, if any, operntor I '))
(,,
12 action was taken in response t,o the failed open 13 pilot operated relief valve?
14 A
I have no recollection of asking that 15 question.
~
16 Q
Was there any discunsion at the 17 meeting about the failed open pilot operated 18 relief valve other than somebody conveying 19 information that it had failed open?
20 A
I have not attested to the fact that 21 there was a disclosure of a failed open relief 22 valve in the 11 o' clock meeting.
(~
23 Q
Well, I think your testimony previously
\\m))
i 24 was just what I read, that you believed that 25 fact was known as early as the 11 o' clock meeting v
[~D 1
Dunn
~
487
'\\-)
2 at Womack's office.
3 A
Yes.
4 Q
That is all I am referring to.
{
5 A
O.K.
6 Q
Other than somebody announcing that 7
fact at the meeting, was there any discussion of 8
the fact that the pilot operated relief valve 9
had failed open?
10 A
I don't recall one way or the other.
11 Q
Did you have a sense of deja vu
((,/
12 or a flashback to Davis-Besse when you heard at 13 the 11 o' clock meeting that a pilot operated 14 relief valve had failed open?
15 MR. FISKE:
You mean did he~ have it 16 at the 11 o' clock meeting?
17 MR. SELTZER:
Right.
18 A
Not that I recall.
19 Q
During lunch did you talk to anybody i
20 about the fact that another plant had failed 21 with a pilot operated relief valve open during i
22 a transient?
/"
23 A
Not that I recall.
b]
24 Q
Didn't it ring any kind of bell with 25 you that this was another plant sufferina a
1 Dunn 488 V
i 2
failed open pilot operated relief valve, at any 3
time before the afternoon meeting on March 28, 4
1979?
C.*
5 MR. FISKE:
Well, I don't think that 6
question is too clear.
I 7
Q Do you understand what I mean by
'8
" ring a bell with you"?
9 MR. FISKE:
Well, I will object to it.
0.K.
11 Q
Do you understand what I mean, Mr.
f
' f~')
12 Dunn?
(_j 13 A
I think you are saying, did it dawn on me 14 that this was another plant suffering a stuck 4
~
15 open PORV.
16 No, I don't believe that dawned on 17 me in the dramatic sense that ringing a-bell 18 intones.
l 19 Q
I take it you were aware as of 20 March 28, 1979 that the Three Mile Island Unit 2 L
21 had been in operation for several months prior 22 to the end of March 1979; is that right?
23 A
I was not in the habit of keeping tabs s -
- 24 of what plants were operating or not operating.
25 Q
It is correct, isn't it, that you know l-
D, 1
Dunn 489 U
2 that the plant had gone into commercial operation 3
months before March 1979, didn't you?
4 Let me withdraw that.
5 You knew that the plant had been 6
operating at full power prior to March 28th, 7
1979, didn't you?
8 MR. FISKE:
Just so the question is 9
clear,.you are asking him, as of March a
10 28th, did he know that the plant had been 11 operating at full power?
(
12 MR. SELTZER:
Yes.,
13 MR. FISKE:
All right.
I 14 MR. SELTZER:
And by " full power,"
i 15 I mean over 90 percent.
16 MR. FISKE:
I understand.
17 A
In terms of know, k-n-o-w --
all right,, go ahead.
18 Q
Let's spell it 19 A
I would say I did not know that.
l 1
20 Q
Did you have a belief that it had 21 been operating at full power prior to March 28th, 22 19797 23 A
Yes.
On March 18th, 1979 I had that belief.
24 Q
And did you have a belief on March 25 28th, 1979 that there had been more than minimal A..
+
4 1
Dunn 490
()
NJ 2
burnup of the fuel?
3 A
Yes, I had that belief.
4 Q
Did you also have a belief as a 5
result of the meeting on the morning of March 6
28th that the plant had been operating at or 7
about full power prior to the transient that 8
norning?
9 A
Yes.
t 10 Q
Did you ask any questions at the 11 morning meeting on March 28, 1979 regarding what, (3
12 if any, action the operators had taken with
(_)
13 regard to high pressure injection at the Three 14 Mile Island plant?
15 A
Today I do not recall that meeting very 16 well.
I do not recall asking such questions.
17 Q
Even though you believe you heard 18 that the pilot operated reliet valve had failed 19 in an open position, to the best of your 20 recollection you didn't ask what, if any, C
21 operator action had been taken with regard to 22 high pressure injection?
23 A
I said I did not recall doing such.
3 d
24 Q
Bob Jones's notes, which are part of 25 GPU Exhibit 96, indicate " Secured all pumps."
(
1 Dunn
~
491 4
2 Do you see that?
3 A
- Yes, b
4 Q
What pumps do you understand that 5
refers to?
6 MR. FISKE:
Well, just a minute.
I 7
am going to object to that, Mr. Seltzer, 8
unless Mr. Dunn has a recollection of the 9
conversation.
I mean, looking at this 10 document all by itself, he wouldn't have 11 any more reason to know it than I would.
,O
~
'g_)
12 MR. SELTZER:
Well, I think you are 13 demeaning Mr. Dunn a little bit by saying that, 14 since he works --
flat'tering 15 MR. FISKE:
Maybe I am 16 myself.
17 MR. SELTZER:
since he works all 18 the time with ECCS analysis, and I-think --
19 MR. FISKE:
I am going to ob. ject.
20 MR. SELTZER:
And you don't work 21 all the time with it.
1 22 MR. FISKE:
I will object unless it is
('Sg 23 couched in terms of his recollection.
Nl 24 MR. SELTZER:
Jones is also his 25 protege and he may have a great deal of y
~
,~r 7-u w.
,-m.
r'^
l Dunn 492 t
2 sense about when Jones says " secured all 3
pumps," that means all men to stations or
}
4 something, and he knows exactly the sense 5
in which Jones uses that phrase.
6 Q
Do you have any understanding what 7
that phrase means as it is contained in this 8
set of notes which you received from Jones?
9 MR. FISKE:
Well, I really am going t
10 to object to that.
11 MR. SELTZER:
Your objection is noted b) 12 for the record'.
All right.
I'will not q
13 appreciate it if you think this is an e
14 appropriate time to instruct this important 15 witness not to answer.
16 MR. FISKE:
Well, I am not going 17 to instruct him not to answer.
18 MR. SELTZER:
All right.
19 MR. FISKE:
Because I frankly don't 20 think it is that big a deal.
l 21 MR. SELTZER:
We will see.
I j
22 MR. ?ISKE:
But the question is l
l 23 clearly improper.
l rg
%)
24 MR. SELTZER:
You know, you are 25 terrific.
Maybe when you become Judge Fiske c.
['
1 Dunn 493 N.]/
2 you will satisfy this latent-desire you 3
have to make rulings at depositions.
I 4
have never seen a lawyer who arrogates to 5
himself not only the right to make the 6
objectior., but also to rule on the objection 7
and practically every time you make an 8
objection, you also instruct the witness
'9 not to answer, even though the Federal t
10 Rules of Civil Procedure are very clear 11 that the objection is preserved until ths
(
12 time of tria?, and the witness is supposed 13 to be permitted to answer.
14 MR. FISKE:
Please, just'because it 15 is 4:30 we don't have to end the' day in a 16 flurry of excitement.
17 I have not instructed him not to 18 answer.
I merely have stated my belief f
19 that the question is improper to give you 20 an opportunity to ask a proper question.
21 Q
What do you understand " secured all 22 pumps" means?
23 A
I think my answer would be interpretive,
<-]
\\)
24 speculative.
25 Q
What would you interpret it to mean
I Dunn 494 2
as you read it in this set of notes that you 1
3 received from Mr. Jones?
4 A
First, I do not recall what I interpreted 5
it to mean if in fact I interpreted it at all 6
that day.
i 7
Today it would be my interpretation, 8
which is at best a guess, that he is referring 9
to the reactor coolant pumps.
t 10 Q
Not to the high pressure njection 11 pumps?
()
12 A
correct.
13 MR. FISKE:
Before you put another 14 question, I do have to be at another 15 meeting at a quarter of five.
~
16 MR. SELTZER:
Is it uptown, I hope?
17 MR. FISKE:
It is 44th Street and 18 Sixth Avenue, so the answer is yes.
You 19 go ahead for a couple of more minutes.
20 MR. SELTZER:
0.K.,
I don't have 21 much more.
22 Q
Do you see the phrase " activity 23 went up in building"?
(~}
NJ 24 A
Yes.
25 Q
That doesn't refer to people running
[v')
1 Dunn 495 T,
around the building, does it, as you understand 3
this set of notes that you received from Bob 4
Jones?
5 A
As I understand it, it refers to _
6 radioactivity.
7 Q
And the measurable radioactivity 8
in the containment building went up following the 9
four a.m.
incident at Three Mile Island; that is t
10 how you would understand this?
11 MR. FISKE:
You mean as he reads it 12 now?
13 MR. SELTZER:
Yes.
14 A
That would be my first interpretation.
15 Q
At the bottom of the page where it 16 says "1/2 hour 250F to 450F" do you see that?
17 A
Yes.
18 Q
Is it your understanding today that 19 that means that in half an hour temperature 20 somewhere went from 250 degrees to 450 degrees?
21 A
I don't think the phrase is specific 22 enough to create an understanding or interpretation.
23 Q
Do you have any recollection of 24 getting a report at the 11 a.m.
meeting of 25 temperatures at Three Mile Island?
[
Dunn 496 1
2 A
No, I do not have a recollection.
3 MR. SELTZER:
0.K.,
why don't we 4
call it a day and return --
5 MR. FISKE:
On this high point.
at 9:30 tomorrow 6
MR. SELTZER:
i 7
morning.
8 MR. FISKE:
Fine.
9 (Time noted:
4:33 p.m.)
t.
10 444'lU p
12 Bert Merrit Dunn 13 Subscribed and sworn to before me this 2 9 day of L 198 M Q62h MA
'~Mg d hd Q, 16 e% % i, is ei 1,
18 j
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19 20
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21 22 O
24 25 I
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1 497 p.,
C CERTIFICATE 2
STATE OF NEW YORK
)
s 3
- ss.:
COUNTY OF NEW YORK
)
4 I,
CHARLES SHAPIRo a Notary
.e 5
Public of the State of New York, do hereby certify that the continued deposition of BERT MERRIT DUNN Was taken before 8
March 19, 1981 consisting De on 9
390 499 of pages through I further certify that the witness had been previously sworn and that the within pd transcript is a true record of said testimony; That I am not connected by' blood or marriage with any of the said parties nor interested directly or indirectly in the matter 16 i
in controversy, nor am I in the employ of any of the counsel.
t 18 IN WITNESS WHEREOF, I have hereunto set my h a n d t h i s'_____
d a y o f M fti t
, t i.?(
20 22 r
l Charles shapiroN SR 24 N._/
l l
25 J
y -
p T
(N 498 l
INDEX WITNESS PAGE IA Bert Merrit Dunn, resumed.
392 i
+ U/4 '
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v,EXHI B ITS
" % '. % ~'
GPU FOR IDENTIFICATION e
86 Two-page memorandum date'd April 17, 1979, to R.
E.
Ham and G.
T.
Fairburn from G.
J.
Brazill 395 O.
87 Memorandum dated May 10, 1979, to K.
R.
Ellison"from D.
F.
Hallman 420 88 Multipage document entitled "ECCS Analysis of B&W's 177-FA Lowered-Loop NSS Revision 3" 427 u
89 Topical Report, October 1975, entitled "Multinode Analysis of Small Breaks for B&W's 2568-MWt Nuclear Plants - Revision 1" 448 90 Memorandum dated April 12, 1978, from J.
H.
Taylor to
{~*j Distribution 440 91 Letter from James H.
Taylor to Dr. Ernst Volgenau at the NRC, dated April 14, O
1978 448 92 Letter dated May 1,
- 1978, to Mr. Robert L.
Bcer at the E'
.n,-
.. lNRC, from James H.
T a y l o r,-
.,;. 4,
457
']
Misuutad w di+2 hid d S cL a. wax.,nfjith attachmentl
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499 I
1 INDEX TO EXHIBITS (continued)
F
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GPU FOR IDENTIFICATION
. PAGE A,
, -O ^
93 Babcock & Wilcox Company i
s n-Administrative Manual, Policies and Procedures, 467 Revialon 6
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- y, y 94 Babcock & Wilcox Company Administrative Manual, Policies and Procedures, l
Revision 5
.468 1
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95 Babcock & Wilcox Company Administrative Manual, Policies and Procedures, Number 1716-A1 469 4
96 Notes of Bob Jones of 11 a.m.
meeting of March 482 28, 1979 h
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