ML20072J109
| ML20072J109 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 08/17/1982 |
| From: | Dominguez A GENERAL PUBLIC UTILITIES CORP. |
| To: | |
| References | |
| TASK-*, TASK-01, TASK-02, TASK-03, TASK-06, TASK-1, TASK-2, TASK-3, TASK-6, TASK-GB NUDOCS 8306290934 | |
| Download: ML20072J109 (122) | |
Text
l BK 1
("N UNITED STATES DISTRICT COURT
( >/
SOUTHERN DISTRICT OF NEW YORK
_ _ _ _ _ _ _ _ _ _ _ __ _ _ _ _ _ _ _ x GENERAL PUBLIC UTILITIES CORPORATION, JERSEY CENTRAL POWER & LIGHT COMPANY,
}
l METROPOLITAN EDISON COMPANY and PENNSYLVANIA ELECTRIC COMPANY, I
Plaintiffs,
-against-80 Civ.1683(R.0)
THE BABCOCK & WILCOX COMPANY and i
J.
RAY McDERMGTT &
CO.,
INC.,
i E
Defendants.
---x
[~N i
)
N~/
Deposition of Plaintiff GENERAL PUBLIC UTILITIES, by ANDRE J.
DOMINGUEZ, taken by l
Defendant, pursuant to subpoena, at the offices l
of Davis Polk & Wardell, Esgs., One Chase i
1 Manhattan Plaza, New York, New York on Tuesday, August 17, 1982 at 9:20 a.m.,
befor'e Nancy A.
3 Rudolph, a Shorthand Reporter and Notary Public within and for the State of New York.
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8306290934 820817 PDR ADOCK 05000289 T
PDR O
DOYLE REPORTING, INC.
CERTIFIED STENOTYPE REPORTERS 369 LEXIN GTO N AVENUE WALTER SHAPIRO, C.S.R.
NEw YonK. N.Y.
10017 CHARLES SHAPIRO, C.S.R.
TELEPHONE 212 - 867-8220 y
1 2
2 APpe arance s:
3 KAYE, SCHOLER, FIERMAN, HAYS & HANDLER, ESQS.
Attorneys for Plaintiffs 4
425 Park Avenue New York, New York
(,
5 BY:
STEVEN J.
- GLASSMAN, 6
of counsel 7
8 DAVIS POLK & WARDWELL, ESQS.
g Attorneys for Defendants One Chase Manhattan Plaza 10 New York, New York
(
11 BY:
ANN MCDONALD, ESQ.,
12 of Counsel
~
13 14 15 Also Present:
16 17 EDWARD HILL 18 19 20
-o00-21
(;
22 4
23 IT IS HEREBY STIPULATED AND AGREED by 24 and among the attorneys for the respective 25 parties hereto that the sealing, filing and 1
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certification of the transcript of the within 3
dep sition be, and the same hereby are waived; 4
that said transcript may be signed before any l(
5 Notary Public with the same force and effect 6
as if signed before the Court; and that all 7
objections except as to the form of the 8
question, are reserved to the time of trial of 9
this action.
10 t
11 12 -
[h 13
-oCo-14 15 16 AND RE -
J.
D0MI NGUE Z,
having 17
.been first duly sworn by a Notary Public, 18 testified as follows:
19 EXAMINATION BY MS. MCDONALD:
20 Q
Please state your name for the record.
21 A
Andre J.
Dominguez.
22 Q
Where do you live?
23 A
254 West Fourth Street, Bloomsburg,
()
24 Pennsylvania 17815.
25 Q
Mr. Dominguez, you are appearing here
Dominguas 1
4 O.
2 today pursuant to subpoena, is that correct?
s 3
A That's correct.
4 Q
And you are represented by Mr. Glassman of 5
Kaye, Scholer?
6 A
Correct.
7 MS. MCDONALD:
I would like to mark as 8
B&W Exhibit 908 the resume of Mr. Dominguez.
9 (Document consisting of one-page resume 10 of Andre.J. Dominguez, was markeh ~B&W Exhibit 11 908 for identification.)
12 Q
Mr. Dominguez, is this a resume you 13 prepared in order to come to this deposition?
14 A
Yes.
15 Q.
Is it an accurate and complete resume of 16 your job and education history?
17 A
Yes.
18 Q
I see you went to Pennsylvania State 19 University.
What did you study there, what was your 20 major?
21 A
Bachelor of science, mechanical 22 engineering.
~
23 Q
Did you take any physics courses while at 24 Pennsylvania State?
25 A
Yes.
Dominguez 5
g OY.
2 Q
How long did those courses or that course s
3 last?
4 A
I took a total of five physics courses.
(,
5 Each course lasted approximately three months.
6 Q
Did you take any course specifically di-7 rected at nuclear physicd?
8 A
No.
9 Q
Did you take any course which included 10 as part of what you were being taught s,o me nuclear 11 physics?
12 A
Yes.
\\'
13 Q
What was the name of that. course, if you 14 can recall?
15 A
I don't recall the name.
16 Q
Did you learn in that course about how a 17 pressurized water reactor works generally?
18 g
yo, 19 Q
When was the first time you were told 20 anything about how a pressurized water reactor works?
21 A
In 1966.
L 22 Q
And that was while you were in the Navy?
23 A
When I was in the Navy, yes.
()
24 Q
While you were at Penn State did any of 25-your training include discussions of thermodynactcc?
1 1
Dominguez 6
m).
2 A
Yes.
g'nerally about 3
Q Did you learn about,--
e 4
concepts of heat transfer and fluid flow?
(
5 A
Yes.
6 Q
Did you learn that the boiling point of 7
water rises as pressure is applied to water?
8 A
Just a minute.
Yes.
9 Q
And you learned that while you were at 10 Penn State?
E 11-A Correct.
12 Q
or before that?
13 A
Both places.
14 Q
You learned that also in high school, I 15 take it?
16 A
- don't recall.
17 Q
Have you taken any courses since being 18 at Penn State of any sort?
19 A
No.
20 Q
other than at your various jobs, I take 21 it?
22 A
That's correct.
l 23 Q
Did you learn about a concept called
(
24
" saturation" as it relates to water and steam while 25 you were at Penn State?
1 Domingue=.
7
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V 2
A Yes.
3 Q
What did you learn at Penn State on that 4
subject that you can recall?
()
5 A
Basically.that while in the saturated i
6 condition, temperature and pressure are dependent 7
upon each other.
8 Q
What do you mean by that, " dependent upon 9
each other"?
10 A
While in the saturation s t'a t e the 11 temperature will be constant for a particular pressure.
12 The opposite is also true.
/~D U
13 Q
You went into the Navy in 1965, did you 14 have any training there?
15 A
Yes.
16 Q
What was the first position that you held 17 in the Navy?
18 A
I was a naval recruit, E-1.
19 Q
What were your job responsibilities when 20 you first went into the Navy?
21 A
I didn't have any.
22 Q
Were you being trained?
23 A
That's correct.
)
I 24 Q
What training did you receive?
25 A
In that position I went to basic training,
1 Dominguez 8
./3 d
2 boot camp, and after we graduated from boot camp we 3
went on to the next rank.
4 Q
In the course of your approximately six
(
5 years in the Navy,.you I take it held various,
6 Positions?
7 A
That's correct.
8 Q
Can you give me the highlights?
9 A
Yes.
10 MR. GLASSMAN:
Would you j'us t like the 11 names of the positions or some more detail?
12 MS. MCDONALD:
As we go through the names O
13 of the positions, I would like to know what that 14 job entailed.
15 A
The best way to describe this would be 16 that for the first two-and-a-half years in service I 17 underwent training.
At that point I then held the A machineht mate is one 18 position of a machinest mate.
19 responsible to maintain, mechanical equipment. I also 20 was an engineering laboratory technician, the ELT 21 as they call it.
I was responsible for the health 22 physics, chemistry portions of the nuclear power plant.
23 As a machinest mate I was also a mechanical (m) 24 operator on a nuclear plant trained, and he does 25 basically the same things that a machinest mate on a
g Dominguec 9
2 fossil plant would do, and that being maintaining the 3
mechanical equipment, running, repairing, et cetera.
4 Q
What nuclear plant was that?
{
5 A
It was the USS GREENLAND submarine.
6 Q
Was that the only nuclear ship that you 7
served on?
8 A
That's correct.
9 Q
Mr. Dominguez, were you ever involved 10 while in the Navy in the operation of the primary 11 system of a nuclear reactor?
12 A
No.
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13 Q
Did you receive any training while in'the 14 Navy with regard to how a nuclear reactor works?
, 15 A
Yes.
16 Q
You mentioned that for the first two-and-a 17 half years approximately you were in training.
t 18 Can you describe what kinds o courses you 19 had with relation to nuclear reactors?
,I don't want 20 to hear about boot camp, but tell me about the nuclear 21 courses that you had in the Navy.
22 A
Okay, from what I can recall, we were 23 instructed as to the basic operation of the S5W type I
24 submarine which is a pressurized water reactor system.
25 We also received training concerning 7
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1 Dominguez 10
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1 2
radiation.
Basic thermodynamic principles, basic 3
nuclear physics, mathematics, chemistry.
That's all 1
4 I can recall.
([
5 Q
In the course of learning about 6
thermodynamic principles, did you learn about heat 7
transfer and fluid flow in a pressurized water 8
reactor?
t 9
A I cannot recall the specifics, but heat 10 transfer and fluid flow are things thah I can recall 11 the terms being used during those periods of time.
12 Q
Were you trained in the Navy that the OO 13.
water in a pressurized water reactor is.on occasion 14 maintained at a temperature substantially higher than 15 212 degrees Fahrenheit?
16 A
Yes.
17 Q
Were you taught why it was that that water l
18 didn't boil?
19 A
The water in a pressurizer always boiled.
20 Q
I am referring to the water in the 21 reactor coolant system other than in the steam space L
Ch in the pressurizer.
23 A
If I understand the question correctly,
)
24 you are asking why didn't the water in the reactor 25 coolant system itself boil?
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l 1
Dominguez 11 2
Q What I think we-can all agree to is 1,
3 the atomospberic boiling temperature' o f water?
4 A
Yes, they explained that to us.
(
5 Q
What did they say?
6 A
The reason why the water would not boil 4
7 in the reactor coolant system is because~ the pressure 8
was maintained above the saturation temperature of l
9 that water.
10 Q
How were you taught that that pressure 11 was maintained?
12 A
With the pressurizer.
O 13 Q
Were you taught that it was necessary to 14 keep a steam bubble at the top of the pressurizer in 15 order for it to fulfill its function of keeping the 16 steam pressurized?
17 Yes.
A 18 Q
Based on your training in the Navy, was
- 19 it possible to control pressure in a pressurized 20 water reactor with no bubble at the top of the 21 pressurizer?
L 22 MR. GLASSMAN: Ibrhaps I don't understand 23 the question, but that seems to be the same as
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- 24 the last question you asked.
)
25 MS. MCDONALD:
Let me explain.
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1 Dominguez 12 2
Q What I mean by " control" is raise the 3
Pressure or lower it in a planned way without a 4
bubble at the top of the pressurizer.
(
5 MR. GLASSMAN: I have the same objection.
6 "I think it's the same question.
The witness can 7
try again if he wants to.
8
.A Yes, I would like to clarify.
9 Pressure can be raised and lowered in a 10 controlled fashion without a bubble du' ring other 4
11 than normal operating periods.
During operating 12 periods the method that we' utilized and were
(_),\\
13 instructed was to control the pressure in the primary 14
- was the pressurizer.
15 Q
When you refer to raising or lowering 16 pressure with no bubble in the pressurizer, could you 17 explain what you were referring to?
18 A
Yes.
You can raise the pressure in the 19 primary system if it is solid, that being the 20 pressurizer is also full of water, by increasing the 21 pressure with high pressure pumps.
22 Once you raise the prescure utilizing 23 that kind of method, you can also lower it by 24 draining the water off.
25 Q
Did you learn in the Navy about what I
1 Dominguez 13 l
'O O.
2 will call solid system operation of a pressurized water reactor?
3 4
A Not that I can recall.
(
5 Q
When you were in the Navy, did you ever 6
see a solid system and by solid I mean comp'letely 7
full of water, the whole RCS including the pressurizer 8
completely full of water?
9 A
I don't recall ever seeing that situation.
10 Q
Based on your training in the Navy, if 11 you had a solid system, the whole RCS and the 12 pressurizer full of water and you turned on the high 13 pressure pumps as you just des'cribed them and started 14 pushing water into the system, would you expect a 15 rapid rise in pressure?
16 A
Yes.
l 17 Q
After you left the Navy, you,went to I
l 18 Metropolitan Edison, is that right?
19 A
No, I went to Penn State.
20
.Q You went back to Penn State?
I'm sorry, I 21 misunderstood you before.
22 A
No, I went to Penn State after I left the 23 Navy.
()
24 MS. MCDONALD:
Off the record.
25 (Discussion off the record.)
+ = -
y
1 Dominguez 14 v
2 Q
You went to Metropolitan Edison in 1975, 3
is that right, Mr. Dominguez?
4 A
That's correct.
l.
5 Q
And from 1975 through some point in 1976, 6
you were an engineer level 1,
is that correct?
7 A
Correct.
8 Q
What were the responsibilities of 9
engineer level 17 i
10,
A I would like to talk about,my 11 responsibilities.
12 Q
That's what I would like to know about.
fb
~
13 A
The primary job that I had,during that 14 period of time was a scheduler, and I worked on the 15 scheduling of the two major outages of Three Mile 16 Island.
17 Q
Refueling outages?
18 A
one was a reactor coolant pump seal 19 outage, the other was the first refueling outage.
l 20 Q
During your first year at Metropolitan 21 Edison, did you receive any training?
22 A
Yes.
23 Q
And what training was that?
,J 24 A
I received a systems course. I believe 25 that was the extent of that first year.
It was a w-
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1 Dominguez 15
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2 systems course.
3 Q
-After that year did you receive further 4
training at Metropolitan Edison?
(
5 A
We are talking from the period of time 6
from '76 to '787 7
Q Why don't we just do it this way:
Why 8
don't you describe to me after the systems course 9
what further training did you have at Metropolitan 10 Edison until you left Metropolitan Edison?
11 A
The other training which I received was 12 a, we will call it a TMI-2 systems course which was
,_s t
13 given in preparation of being a shift test engineer.
14 Q
How long did that training last or was 15 it ongoing or what?
l 16 A
Approximately three months, two hours a 17 day.
18 Q
Do you remember anything you learned in 19 that course?
20 A
Yes.
21 0
were you told anything about 22 thermodynamics?
23 A
I don't recall addressing thermodynamics
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24 in the courses, i
25 Q
once you became a shift test engineer,
1 Dominguez 16
/"i did periodic on-the-job training go on?
2 s
No.
3 A
4 Q
Do you remember any of the people that l,
5 taught this course on TMI-2 systems?
6 A
Yes.
7 Q
Can you name the ones that you recall?
8 A
Myself, Craig McMullin, John Ulrich, 9
Jack Garrison.
10 Q
Was there a Mr. Hawkins?
E 11 A
Hawkins.
12 Q
What was his position at that time?
G' 13 A
Assistant test superintendent.
14 Q
All of these people were GPU or 15 Metropolitan Edison employees, is that correct, the 16 people you have named?
17 A
Yes, that's correct.
18 Q
Did you know a person named Nelson?
19 A
Max Nelson, yes.
20 Q
What was his position?
21 A
I don't know what his position vas.
,k 22 Q
Do you know who he was employed by?
23 A
General Public Utilities.
O()
24 Q
Did you learn anything in this course 25 about procedures?
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1 Dominguez 17 2
A I don't recall that specific topic.
3 Q
.Did you learn anything about how a 4
pressurized water reactor works generally?
l 5
A Generally, yes.
6 Q
Did you learn about how pressurizer, 7
learn more,I guess I should say in your case, about 8
how the pressurizer works?
9 A
Yes.
10 Q
Did you recall anything thyt you were 11 told about how the pressurizer works in a pressurized 12 water reactor?
13 A
I can't specifically recall the things 14 that were instructed to us at that time.
15 Q
Did you know a f ellow n amed M.J. Perry?
16 A
I don't recall the name.
17 Q
How about Carl Gatto?
18 A
Yes.
19 Q
Who is Mr. Gatto?
20 A
Mr. Gatto was a startup test, engineer.
21 Q
At GPU?
22 A
He was an employee of GPU.
23 Q
R.R.
Lentz?
24 A
Yes, I recall the name.
He was an IEC 25 expert,that being instrumentation and control.
I
1 Dominguez 18 10 V
2 believe he was also employed by GPU.
3 Q
- Steve.Poje?
4 A
Yes, I recall Steve.
He was also a l
5 start'up test engineer.
6 MR. GLASSMAN:
Can we take a short break?
7 MS. MCDONALD:
What is the purpose of 8
this?
9 MR. GLASSMAN:
I would like a one-minute 10 break.
(
11 MS. MCDONALD:
To coach your witness, 12 Mr. Glassman?
This is ridiculous, Mr. Glassman.
(Ls) 13 You just walk out of the room!
14 (Recess taken.)
15 Q
Mr. Domiaauez, prior to coming to this 16 deposition were you asked to look for documents which i
l 17 might relate to this case?
18 A
Yes.
19 Q
Did you do so?
t
(
20
.A Yes, I did.
1 21 Q
And did you turn over to your lawyers 22 everything that you found?
l 23 A
Yes.
t 24 Q
Several notebooks have been produced to i
25 us by Kaye, Scholer, Mr. Dominguez' attorneys.
There j
/
/
/
1 Dominguez 19 O
2 are four notebooks. I wonder, Mr. Dominguez, if you 3
can identify those for us as documents that you 4
turned over?
l 5
A Yes, these are the documents I turned over.
6 Q
Did you turn over any other documents?
7 A
Yes, I turned over an entry in my personal 8
log that discussed a very brief conversation with an 9
NRC person.
10 MS. MCDONALD:
Mr. Glassmah, I specifically 11 requested any notes that Mr. Dominguez had of 12 conversations with the NRC.
I asked O
13 Mr. Eickemeyer for those things.last week, and 14 he tried to produce them, and I do not have 15 them and I specifically said to him I will ask l
16 Mr. Dominguez this.
17 It will certainly save time if you produce 18 them and we can call Mr. Eickemeyer right now.
~
19 He specifically agreed to this.
20 MR. GLASSMAN:
Ms. Mcdonald, perhaps, 21 there has been a problem with the mails or 22 something of that sort. I am familiar with 23 the file, and I had understood that
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k, 24 Mr. Eickemeyer or someone else.from our office 25 was forwarding it to you.
I can make a call,
1 Dominguez 20
['T V
2 but if not I happen to have a copy of that 3
document anyway and would be more than happy 4
to produce it for you here now.
((
5 MS. MCDONALD:
But you are not objecting 6
to its production?
7 MR. GLASSMAN:
No, as is our policy, when 8
you make a specific request for a document if 9
we can locate it we will produce it and we will 10 be glad to do so here as well.
(
11 MS. MCDONALD:
Well, I would appreciate 12 its production.
Thank you.
13 MR. GLASSMAN:
Off the record.
14 (Discussion off the* record.)
15 MR. GLASSMAN:
Although I believe that e
16 this has'been produced, so as to avoid any i
17 misunderstanding we herewith produce a copy 18 again.
19 MS. MCDONALD:
Mr. Glassman, I am sure 20 you intended to produce it. I am sure it was 21 not produced, but I thank you for producing it 22 now.
23 BY MS. MCDONALD:
(f 24 Q
Mr. Dominguez, what are those documents, 25 generally?
1 Dominguez 21.
[}
V 2
A They are lectures that were prepared by 3
the people who taught the TMI-2 systems courses.
4 Q
Did you turn over anything other than l
5 those documents and the personal log entry that we 6
just discussed?
7 A
No.
8 Q
In the course of this systems course, did 9
you have any training in transient response?
10 A
Not that I can recall.
E 11 Q
Were you ever asked to review any operating 12 emergency procedures for either TMI-1 or TMI-2?
s 13 A
I don't recall ever being requested to do 14 that.
15 Q
You said that you taught some part of this 16 course.
Can you remember what you taught?
17 A
Yes.
18 Q
What was that?
~
19 A
The types of lectures which I prepared 20 and taught were concerning support systems to the P ant, some examples would be Ammertap.
l 21 22 Q
What is Ammertap?
23 A
Do you want this on or off?
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24 Q
I have no idea what they are. Just 25 describe them generally.
I i
1 Dominguez 22 m
2 A
The Ammertap system is a water cleaning 3
-system.
They inject tiny little spo'nge balls into 4
They pass through the 5
tubes and scrub the tubes as they pass t'hrough.
We
([
6 collect the balls at the end and recirulate them 7
into it.
8 Q
Did you ever teach anything about the 9
condensate polishers?
You know what I am referring to?
10 A
Yes. I don't recall.
t 11 Q
Have you ever received any licenses, by 12 that I mean control room operator or senior reactor 9
13 operator licenseu?
14 A
No.
15 Q
From 1976 to 1978 while employed by 16 Metropolitan Edison you were a shift test engineer at 17 TMI-2, is that correct?
18 A
Yes.
19 Q
Did Metropolitan Edison run the startup 20 and test program at TMI-27 21 A
No.
L 22 Q
Was that run by GPUSC or GPU?
23 A
Yes.
[)
24 MR. GLASSMAN:
You are asking this tritness Ns/
25 either or, the question unclear.
1 Dominguez 23 m
2 Q
Who did run it?
3 A
-GPU.
4 Q
Did Metropolitan Edison loan GPU personnel
(
5 to assist with the startup'And-test program?
6 A
Yes.
7 Q
How did that come about?
8 MR. GLASSMAN:
Are you asking for this 9
witness' knowledge of how other people reached 10 such a decision or are you asking him what he 11 was told?
12 MS. MCDONALD: I am asking what he knows
[\\'
13 about why Met Ed personnel were working for 14 startup and test from whatever sources he knows 15 it.
obviously, if he knows it he must have been 16 told it.
Are you now asking 18 generally or of Mr. Dominguez?
19 MS. McDON LD:
denerally.
You are looking 20 for his knowledge, you are not asking him to 21 guess?
22 MS. MCDONALD: No, I don't want him to 23 guess.
I just want to know if he knows.
()
24 A
I don't know what was involved into the I
25 actual decision to have that come about.
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1 Dominguez 24
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2 Q
When in 1978 did you leave Metropolitan 3
Edison and go to Pennsylvania Power & Light Company?
4 A
ApProximately September.
(
5 Q
And your position at Pennsylvania Power &
6 Light beginning in 1978 and up to the present day is power production engineer, is that correct?
7 8
A Not completely.
In 1978 I had the 9
position of power production engineer and I have been 10 promoted to the position of senior proQect engineer.
11 Q
What does a senior project engineer do, 12 what do you do as a senior project engineer?
13 A
I am responsible to resolve problems that 14 arise in the residual heat removal system and I 15 manage 16 engineers.
l
~
16 Q
The Susquehanna steam Electric Station, 17 what kind of plant is that, it's not a nuclear plant 18 is it?
19 A
Yes, it is a nuclear plant.
20 Q
What kind of a nuclear plant?
21 A
It is a boiling water reactor.
22 Q
Do you recall being trained at 23 Metropolitan Edison as to what the normal operating p) 24 level of the pressurizer was?
(,
l 25 A
I recall that there was a normal operating
(
1 Dominguez 25
~'s (d
2 level in a band to operate between.
3 Q
-Do you recall that that level was 4
approximately 220 inches?
(
5 A
No.
6 Q
Do you recall that it was 400 inches?
7 It was less than 400 inches, 8
wasn't it?
9 A
It was less than 1000, it was greater than 10 3ero.
I don't recall.
L 11 Q
Do you recall how many inches the 12 pressurizer level could have an indication in TMI-27 G['N 13 A
No, I don't recall.
14 Q
Do you recall in any of your training up 15 to the time y,ou left Metropolitan Edison, and by 16 that I am including the Navy and Penn State and all 17 your training, hearing of the concept of flashing as 18 it relates to water and steam?
19 A
could you rephrase that.
I'm sorry. I l
20 don't need a rephrasing.
The question again, did 21 I recall being --
22 MR. GLASSMAN:
Could we have the question 23 reread?
24 (Question read.)
25 MR. GLASSMAN: I am going to note an I
l 1
1 Dominguez 26 O
2 objection as to form.
3 THE WITNESS:
Would you reread the question 4
again?
l!
5 MS. MCDONALD:
Why don't I ask it again.
6 THE WITNESS:
No, I can answer the 7
question.
8 Q
Up to the time you left Metropolitan 9
Edison, have you ever heard of the term flashing?
10 A
Yes.
t 1]
Q What did it mean to you?
12 A
Flashing to me means turning liquid into
(,_))
~-
u.
13 vapor.
14 Q
UP to the time you left Metropolitan 15 Edison, have you ever heard that flashing could occur 16 in the primary system of a pressurized water reactor 17 in a place other than the pressurizer?
18 THE WITNESS:
Could you rere d that, 19 please?
20 (Question r e a d. )'
21 A
I don't recall.
22 Q
Since the Three Mile Island accident, have 23 you ever testified under oath apart from today?
O,tj 24 A
No.
25 Q
Have you ever been interviewed by
1 Dominguez 27 2
anyone in connection with the Three Mile Island accident?
3 4
MR. GLASSMAN:
Are you talking about l
5 apart from conversations with counsel?
6 MS. MCDONALD:
Oh, yes, apart from 7
conversations with counsel.
8 A
No.
9 Q
After the Three Mile Island accident were 10 you ever interviewed by anyone relating to anything 11' at Three Mile Island?
12 A
No.
OV 13 Q
Have you ever heard of a Mr. John Craig 14 of the NRC?
15 MR. GLASSMAN:
Are you asking up until 16 today?
'17 MS. MCDONALD:
Yes.
18 MR. GLASSMAN:
Obviously cou sel is l
19 reading from a document which we just turned 20 over, a particular note there.
21 MS. MCDONALD:
Well, obviously 22 Mr. Dominguez knows about his interview with the l
23 NRC, and I &c trying to figure out what game
( )
24 is being played here.
f 25 MR. GLASSMAN: Let me interrupt, I
i
i Dominguez 28
{~~Tu ).
2 Ms. Mcdonald, I thought you were going to try to
)
3 express some question here.
I think 4
Mr. Dominguez told you a little earlier that he
(
5 did receive a phone call from someone at the i
6 NRC.
)
7 We have just produced another copy of this 8
document a few moments ago.
Perhaps you could 9
clarify this by asking him whether that was an 10 interview.
11 BY MS. MCDONALD:
12 Q
I would like to know why you h. ave excluded' fh u.)
13 an interview that'you apparently had on the phone with 14 the NRC from your answers to the last two questions?
15 MR. GLASSMAN:
Objection.
There has been 16 no basis established that there was an interview.
17 I mean, if you would like to ask him whether he 18 had an interview --
19 MS. MCDONALD:
Let's mark as B&W 909, the 20 document that has just been produced which 21 Mr. Glassman so desperately wants to put before 22 the witness.
23 MR. GLASSMAN:
It's up to you. I think 1
s,j 24 we are wasting time.
You are getting into a 25 semantics game. It's obviously a document that r
, ~ - -.-
n - - -
1 Dominguez 29 2
you are placing before the witness which begins,
" Received a call from John Craig (NRC). "
And 3
4 you can ask the witness any questions you want,
(
5 but I hope we don't get caught up in a sematics 6
game.
7 MS. MCDONALD:
It is not I who is being 8
caught up in a semantics game.
9 MR. GLASSMAN:
You can ask any questions 10 you like.
t 11 MS. MCDONALD:
Can we mark that document 12 as B&W Exhibit 909.
p 13 (One-page handwritten document marked 14 B&W Exhibit 909 for identification.)
15 BY MS. MCDONALD:
16 Q
Mr. Dominguez, can you identify B&W 17 Exhibit 909 for me?
18 A
Yes, that's a copy from my phrsonal log.
^
19 Q
Do you regularly keep a personal log.?
20 A
No, I do not.
21 Q
Why were you keeping this particular 22 personal log?
23 A
I have a logbook that I record bits of
/"
(%)
24 information that come across my desk that I would like 25 to recall. It's not a regular thing.
1 Dominguez 30 0-2 Q
How long have you been doing this?
A APProximately nine months.
3 4
Q What kinds of events or things that come
(
5 across your desk do you tend to write down in your 6
Personal logh 7
A Things which I believe will be of value 8
to me in the future.
9 Q
Mr. Dominguez, do you see the entry 10 opposite 5/21/817 E
11 A
Yes.
12 Q
That is your handwriting?
('T
(_/
13 A
Yes, it is.
14 Q
Is everything on this page your handwriting 15 other than the typed portion at the top that says 16
" Notes:
Andre' J.
Dominguez"?
17 A
Everything on this page is by my hand.
18 Q
Do you recall receiving a call from 19 Mr. John Craig of the NRC on or about May 21, 19817 20.
A Yes, I do.
21 Q
Did Mr. Craig tell you why he was calling 22 you?
23 A
Yes, he did.
f%()
24 Q
What did he say?
25 A
He said he was interested in a log entry r
.. -.., ~
--.,--.-.,n,-,--.,e-
,,m.
-c
---~.mm
1 Dominguez 31 cm 2
I had made in a. shift test engineer's log concerning i
s 3
an event which had occurred on September 1977.
4 Q
Did you respond to his inquiry?
i
(
5 A
Yes, I was very congenial.
6 Q
When you were on the phone with him, did 7
you pull out your personal logbook and take notes?
8 A
No, I did not.
9 Q
Did you, subsequent to the phone calls, 10 take some notes regarding what had transpired to the 11 conversation?
12 A
subsequent to the O
conversayion I made this 13 entry into the logbook.
14 Q
By "this entry" you mean the one on B&W 15 9097 16 A
That's correct.
17 Q
How long after the phone calr did you make 18 this entry?
l 19 A
Approximately three hours.
i 20 Q
At the-time you made this entry, did you 21 have a clear recollection of what had transpired in the 22 conversation at the time you wrote this, three hours l
l 23 later?
)
24 A
Yes, I did.
l 25 Q
Did you write down anything in this log
1 Dominguez 32 rm
(
l
\\~/.
2 entry that was false; in other words, that had not 3
transpired in the phone conversation?
4 A
The things that are entered into this log l
5 outside of the quotes, that being " formation of a steam 6
bubble in the loops" are my words and they're 7
interpretation of the phona conversation.
8 Q
Do you have a present recollection of 9
what transpired in the phone conversation?
10 A
I do not have a complete recollection of 11 it, but I do have a recollection of it.
12 Q
Do you recall that Mr. Craig asked you 7s
'~')
(
log for 13 about an entry in the shift test engineers 14 September 1977 concerning formation of a steam bubble i
15 in the loops?
16 A
Yes, I do.
17 Q
And did you tell him in words or substance, 18 and I am reading now from the document, that steam 19 bubble was not the most appropriate word, but rather 20 a vapor bubble of very low quality was specifically I
21 what had formed due to the cooling down of the loops =?
22 A
Would you read that back, please.
23 (Question read. )
O N._)
24 A
Yes.
l 25 Q
Did Mr. Craig tell you why he was
+em g,
q e--w e
m
>e-#-,-
e-a---
g c-n
--ye
1 Dominguez 33 7x 2
interested in finding out about this event?
s 3
A He indicated that it was due to a review 4
that the NRC had made in relation to the Three Mile
(
5 Island accident.
6 Q
Did he tell you or did you just know 7
what possible connection a steam bubble in the loops 8
could have to the Three Mile Island accident?
9 I will ask it in two questions:
Did he 10 tell you?
11 A
Yes, he did.
12 Q
What did he say?
s 13 A
He indicated that the particular word, 14 that being ". steam bubble formed in the loops,"
15 resembled something which had occurred during the 16 accident and he thought there was a connection there.
i l
17 Q
At the time you had this conversation, 18 did you know anything about the Three Mile Island 19 accident yourself?
20 MR. GLASSMAN:
Are you talking about did 21 he have actual knowledge or did he hear 22 something?
23 MS. MCDONALD:
Did he know anything from
()
24 whatever source he might have known it, whether 25 he was told it or he knew it.
1 Dominguez 34
()
u 2
A Yes.
3 Q
What did you know about the Three Mile 4
Island accident?
{)
5 MR. GLASSMAN: I object to the use of the 6
word "know" because there is no testimony that 7
P*oPle conducted an investigation.
8 MS. MCDONALD:
I would like to know his 9
state of mind.
10 MR. GLASSMAN:
That's f aiE.
11 THE WITNESS:
Could you define " state of 12 mind"?
13 Q
What did you know or think you knew about 14 the Three Mile Island accident?
15 A
I made it a habit not to know very much 16 of what occurred there because there was such a 17 proliferation of documents that came out. I basically 18 knew the sequence of events.
19 Q
And prior to the time you talked to 20 Mr. Craig, did you know that in the course of the 21 Three Mile Island accident voiding had occurred in 22 the primary system and resulted in formation of steam 23 bubbles in the primary system other than in the 24 pressurizer?
25 A
No, I didn't know that.
s
_,,_g
-.r--
-s---,
,-.------.-,,,r,
,w- -, -
,3-w
1 Dominguez 35 2
Q Mr. Dominguez,. what were your duties and 3
responsibilities as a shift test engineer in TMI-27 4
A Our duties and responsibilities were to
(
5 conduct the pre-operational testing of Three Mile 6
Island Unit 2 and they were pretty much limited to 7
that.
8 Q
In the course of your duties as a shift test 9
engineer, were you required to fill out any kind of 10 logs?
t 11 A
Yes, I was.
12 Q
What logs were those?
13 A
The shift test engineers log.
~
14 Q
What was the purpose of the shift test 15 engineers log?
=
16 A
The shift test engineers log supplied a 17 list of all the testing that we had performed. It 18 also documented or reviews what the shift test 19 engineers did prior to. conducting tests, and we also 2a used it to put pieces of information that would 21 be of value to both ourselves, the shift test 22 engineers and our supervisors.
23 Q
was there a procedure for filling out the i
l (3
/
j 24 shift test engineers logs?
25 A
I don't recall the procedure.
1 Dominguez 36
(~U) 2 Q
Did you receive any training?
3 A
Yes, we did.
4 Q
On how to fill out the log?
({
5 A
Yes, we did.
6 Q
Do you remember who that was from?
7 A
That was from Mr. Toole.
8 Q
What was Mr. Toole's position?
9 A
It was the startup and test superintendent.
10 Q
was it part of your respon'sibility to 11 fill out this log as accurately as you could, based 12 on your knowledge when you were filling it out?
f~%
13 A
Yes, correcc.
14 Q
When specific tests were being run, was 15 it the practice in filling out this log to write down i
16 the number of the test procedure in the margin of the 17 log?
18 A
Yes.
19 Q
Prior to assuming your position as shift 20 test engineer, was it your practice to review the 21 prior log entries back until your last entry?
22 A
Yes, it was.
23 Q
Was that required by the procedure for
(
24 filling out the log?
25 A
I am not familiar with the procedure.
q
-g s
s 1
Dominguez 37 i
t
\\
2 Q
Was it told'to you in your draining that 3
that is something that y'du should do?
t
't 4
,A-I believe it was.'
l(
5 g
was it your pract) o lo' consult withsthe i
s s
-6 shift test engineers who had the shift before you s
i-
,'s 7
came on as to what the condition of the plant was, l
8 and what tests had been conducted during your shift?
9
.'A Yes, it was.
,'n occasion c'9nsult with 10
'Q Did you also o
f 11 control room operators?
s 4
12 On occasion, y e,s.
13 Q
And shift fo'r eman ?
14 A
Yes.
'J 15 Q
And shift supervisors?
, s,.
j s
s s.
s' 16 A
Yes.
N 17 Q
Did you generally m'ake youhself aware s
s 18
- t
.a condition that the' plant was in when you came s-19 '
oe,.; tit?
20 A
Yes.
(
21 Q
Dc4 you know whether Mr.'Toole'made it a i
C l
22 practice to reviet! the log periodically ?
23 A
Mr. Toole reviewed the log.
24 Q-And on occasion did you see in that log I.
~
25 entries by Mr. Toole indicating that he had reviewed 1
h.
~_,
l...
n
1 Domingu'ez 38
/~
2 it, and then he would on occasion make certain 3
comments?
4 A
Yes.
(
5 Q
Did you ever record anything in the shift 6
test engineers log that at the time you were recording 7
it you knew to be false?
8 A
No.
9 Q
Do you know of anyone else who did that?
10 A
No.
t t'st, was not 11 Q
Even if a test, a specific e
12 in progress during one of your shifts, would you 13 nevertheless make entries into the lo the shift
'14 test engineers log?
15 A
That's correct, yes.
16 Q
And was it ycur practice to record any 17 unusual events or parameters that came tp your 18 attention in the log?
19 A
It was not our habit to recor'd any 20 unusual parameter.
21 Q
Was it your habit to record some unusual 22
- parameters?
23 A
Yes.
[v) 24 Q
Such as?
25 A
Those deemed significant at the time.
1 Dominguez
/~N 39
(,j.
2 Q
Let me just show you what's already been 3
marked as B&W Exhibit 173, and I am just going to 4
ask you if you have ever seen that document before.
I (
5 The document is entitled " Test i 6
Instructions Number 17 Shift Test Engineers Log, 7
Prepared by J.P. Miller."
8 A
Would you re-read that, please.
9 (Question read.)
10 t
A I don't recall ever having'seen this.
11 Q
While you were a shift test engineer, 12 were you familiar with something called an Unusual I\\/
13 Occurrence or Events Report?
14 A
No, I wasn't.
15 Q
While you were a shift test engineer, were 16 you aware of any regulations or laws requiring that II GPU or Met Ed report anything that came t'o their 10 attention which might endanger the public health and 19 safety?
20 A
There is such a law'. I am aware of it.
21 Q
Were you aware of it while you were a 22 shift test engineer?
23 A
Yes.
(_,),
(
o4 Q
While you were a shift test engineer, 25 were you told that you had any responsibility for
1 Dominguez 40 h
[V.
2 bringing to your superior's attention things that 3
might endanger the public health and safety?-
4 A
Yes.
l('
5 Q
Was it your understanding when you were a C
shift test engineer that certain things had to be 7
reported to the NRC, certain significant or unusual l
8 events?
i 9
A No.
10 Q
No one ever told you that Vhile you were 11 at Met Ed?
12 A
I don't recall ever being instructed as to O
13 the requirement or necessity to report specific types 14 of unusual events to the NRC.
l 15 (Recess taken.)
16 Q
Could you tell me, Mr. Dominguez, what you l
17 remember today about what went on during.the incident 18 that is referred to in B&W 9097 19 MR. GLASSMAN:
Are you talking about the 20 entire incident or a particular aspect described 21 on this document?
22 MS. MCDONALD:
The entire incident.
23 A
Foremost in my mind was that there was a 24.
resin migration into the nuclear services closed 25 -
cooling water system which forced all the pumps to I
1 Dominguez 41
,7 s
2 trip off after a period of time.
That system cools 3
the reactor coolant pumps and subsequently they had to 4
be turned off to prevent da, mage to them..
(
5 Q
Do you remember anything else about the 6
event?
7 A
It is not clear in my mind what we.did 8
directly after thac.
The only other thing that 9
really sticks out in my mind was the fact that there 10 was a lengthy investigation as to the' extent of the 11 resin problem.
12 Q
Did this event continue for a few days?
O' 13 A
As I recall it did.
14 Q
Do you recall that in the course of the 15 event a vapor bubble of some kind was formed somewhere 16 in the reactor coolant system other than in the 17 pressurizer?
18 A
I don't recall that.
19 Q
Referring to B&W 909, you testified before 20 that you told Mr. Craig of the NRC that a vapor 21 bubble of very low quality was specifically what had l
22 formed due to the cooling down of the loops.
I 23 When you told him that, did you have a o
24 recollection of that or were you lying to him?
25 A
As it relates to the incident in 1977,
1 Dominguez 42 O
V 2
September, I didn't recall formation of a steam 3
bubble.
What Mr. Craig had done here is to read 4
something which he indicated I had written.
I don't
(
5 recall ever having written that.
I don't know if 6
I ever did write it.
Under the assumption that
~
7 perhaps I had written it, I felt that the choice of 8
words " steam bubble" was inappropriate, but rather 9
that specifically if you had some kind of voiding 10 occurring in the loop, it would be a v'apor bubble 11 of very low quality.
They use thermodynamic terms 12 in here to describe it to Mr. Craig.
13 The conversation between m self and 14 Mr. Craig was at best a big guessing game.
He caught 15 me. completely off guard. I had no documents in front 16 of me, and I explained to Mr. Craig that everything 17 would have to be off the record because I really 18 wasn't sure what he was talking about.
19 Q
And at the time of your conversation with 20 Mr. Craig, as you testified before, you didn't know 21 what had happened really at Three Mile Island, is 22 that right?
23 A
That's correct.
O) 24 Q
So without knowing anything, 'very little, 25 anyway about what had happened at Three Mile Island,
1 Dominguez 43
(
'wi.
2 you knew that vapor could be formed in the reactor 3
coolant system outside the pressurizer, is that i
4 correct?
(
5 MR. GLASSMAN:
Objection as to form.
I 6
think he's answered already.
7 Q
Would you just describe what you were 8
trying to tell Mr. Craig, where did you get the 9
understanding that vapor could be formed in the 10 reactor coolant system outside the pre'$surizer?
11 A
Every time that you cool down the loops, 12 depressurize the pressurizer, something forms in the i
h (G
13 '
loops, the high points of the system,,that is what I 14 call a vapor space, or a vapor bubble.
15 What I had in mind when I was talking to 16 Mr. Craig was when you heat back up again you 17 p re s surize the pressurizer.
You have to force all 18 that void space, this vapor bubble out to make sure 19 the loops are filled with water.
And that's why I 20 said that specifically what you would have in a 21 situation like that would be a vapor bubble of very L
22 little quality because in my mind that's what it would 23 be called as opposed to a steam bubble.
24 Q
And I take it that you knew when you were 25 a shift test engineer at Three Mile Island that vapor i
-m
1 Dominguez 44
[]h N.
2 bubbles of very low quality could form in the reactor 3
coolant system outside the pressurizer, is that true?
4 MR. GLASSMAN:
Objection.
The witness
(
5 has already told you where specifically 6
that might or might not form as to his 7
understanding.
i 8
Q And I want to know if you knew what you l
9 just told us when you were a shift test engineer at 10 Three Mile Island?
E 11 Is that right?
12 A
We knew that when you cooled down and
[h
\\
13 depressurized that between the time that had occurred 14 and you pressurized back up again that the hot legs 15 and the other high points would have vapor in them.y
,c:
16 Q
Based on your understanding at that time, 17 why would the hot legs get vapor in them?
l 18 A
Geometry.
J IP Q
What do you mean by that?
20
~ A The highest points of the system are the 21 hot legs. If you let all the water drain down to 22 some level below that, you are going to create a 23 vapor space up there.
O)
(
24 Q
Was it your understanding that vapor could l
25 form prior to draining?
I I
1 Dominguez 45 t%d 2
A No, I never expected it to occur prior to s
3 draining.
4 Q
So you would have considered that to be
(
5 unusual, is that right?
6 MR. GLASSMAN:
You can't ask him to speculate abost what he would have considered 7
8 if he didn't actually consider it.
9 MS. MCDONALD:
Yes, I can.
10 MR. GLASSMAN:
No, you can't.
11 A
I would have to say I never really i
12 considered it.
13 Q
Based on your knowledge when you were a 14 shift test engineer that you just testified about, t
15 did you ever see vapor, experience vapor forming in 16 the reactor coolant system outside the pressurizer to
'17 the system being drained of water?
18 A
I can't recall ever seeing that happen.
19 Q
The cooldown that you have just been 20 describing where vapor sometimes formed was that a 21 normal cooldown that occurred in every cooldown based 22 on your understanding when you were a shift test 23 engineer?
(
24 A
Yes.
25 Q
Do you know whether the control room e-
. m
1 Dominguez 46 2
operators at Three Mile Island knew that?
3 A
No, I don't know.
4
.Q Did you ever have any conversations with
(
5 control room operators, shift test engineers or shift 6
foreman at Three mile Island regarding this phenomenon 7
during cooldown?
8 A
I don't recall having conversations of 9
that nature.
10 Did any control room opera' hor or shift Q
11 foreman or shift supervisor ever indicate to you that 12 he knew that vapor could form in the reactor coolant 13 system during normal cooldown?
14 A
I don't recall ever hearing that.
15 Q
How did you come to know tha,t?
16 A
I witnessed it.
17 Q
On how many occasions?
10 A
I can only recall one occasion.
19 Q
When was that?
20 A
I can't recall a specific date or time.
21 Q
Was it during the event which started 22 with the resin migration?
23 A
I can't recall.
24 Q
When I refer to the event which started 25 with the resin migtation, you know what event I am
1 Dominguez 47 2
talking about?
3 A
You are talking about the event 4
September 19777 l
5 Q
correct.
Do-you remember anything during 6
that event about behavior of the pressurizer level?
7 A
I don't recall anything specifically about 8
the pressuri.zer level.
9 Q
During the normal cooldown that you have 10 been describing in which on occasion vhpor may form 11 in the hot legs, was it your understanding that that 12 vapor would cause pressurizer level to rise?
O 13 A
No, it wasn't.
14 Q
Was it your understanding that that vapor 15 formation would have any effect on pressurizer level?
16 A
No.
17 Q
Were you ever taught while at Metropolitan 18 Edison an'ything about the desirability or 19 undesirability of operating Three Mile Island in the 20 solid state?
21 A
I don't recall any training that discussed 22 the operation in a solid state.
23 Q
Was it normal based on your experience I
)-
24 as a shift test engineer to operate the plant with 25 the pressurizer completely full of water?
I
-,. -..--~,,,
_--n.-
I l
1 Dominguez 48 b
O.
2
.A No.
3 Q
Did you ever see that happen?
4 A
I never saw operation of the plant with
(
5 the pressurizer full of water, no.
6 Q
Is it correct that the only time you saw 7
the pressurizer full of water was during hydrostatic 8
testin,g at Three Mile Island?
9 MR. GLASSMAN:
I think the witness just I
10 answered that he never saw it.
11 MS. MCDONALD:
He used the word " operation,"
12' I thought he might be making some distinction i
y 13 there.
14 THE WITNESS:
Yes, I was.
15 Q
Did you ever see the pressurizer full of 16 water, Mr. Dominguez?
(
17 A
I observed hydrostatic testing of the 18 l
plant. I don't recall what the condition of the 19 pressurizer was. It has to be full in order to do that.
20 Q
That hydrostatic testing is the only 21 occasion that you remember seeing the pressurizer 22 full of water?
23 MR. GLASSMAN:
Just so we are clear, the 24 witness just said he doesn't recall actually 25 seeing that.
1 Dominguez 49 (a
2 g
Do you remember any time other than the 3
obvious time of hydrostatic testing that the 4
pressurizer was full of water?
.(
5 A
I don't recall.
6 Q
Based on your_ training and your knowledge 7
while at Metropolitan Edison I wan't you to think back, 8
would you have considered it unusual to have the 9
pressurizer full of water while the plant was being 10 operated?
11 A
Yes, I would' consider that unusual.
12 Q
Now, Mr. Dominguez, I would like to show 13 you portions of the shift test engineers. log and the 14 pages I would like to show you come from what has been 15 previously marked B&W Exhioit 175, and the pages I am 10
(
going to hand you are pages stamped WO6066 through 06080.
I 17 I would like to ask you if you recognize that as part 18 of a shift test engineers log?
19 A
I recognize this as tha shift test 20 engineers log.
21 Q
Have you reviewed this portion of the 22 shift test engineers log since the Three Mile Island 23 ac ciden t'o th e r than with counsel?
I 04 (j
A No, I have not.
Q During this time period, namely
1 Dominguez 50
() ~
. ( /.
2 September 1977, up through the time you left 3
Metropolitan Edison, did the shift test engineers 4
have three shifts a day?
'(
5 A
Yes.
4 6
Q They were 8-hour shifts?
7 A
Yes.
8 Q
Did they go from 11:00 p.m.
to 7:00 a.m.
9 and then from 7:00 a.m.
to 3:00 p.m.,
and then from 10 e
3:00 p.m.
to 11:00 p.m.
were those shifts, the 8-hour 11 shifts?
4 12
-. A Give or take an hour, yes.
I don't recall Q -
13 the exact time.
14 Q
But there were three 8-hour shifts?
15 A
Yes.
16 Q
Would you refer to page WO6069, please.
17 Do you see the entry that begins at the 18 bottom of the page and is dated September 8,
19777 19 It starts " Relieved, Jack Garrison."
20 A
Yes.
21 Q
Can you tell based on your knowledge of 22 how these logs were kept that that is the entry for 23 the first shift on September 8, 19777 I note that the 24 entry previous to that is dated 9/7/77.
25 MR. GLASSMAN: I think we can stipulate
-~m,,.
~
.,.-__-__y,....cv-,
~ _,,,.. -
--..__.-,,_m.
~
1 Dominguez 51
/'N k
i v'
2 that that's what it appears to be.
Obviously 3
the witness is hard-pressed to recall and say 4
exactly --
(
5 MS. MCDONALD: I am asking for the added 6
knowledge that he might have known how these 7
logs were kept.
8 A
The time and day.
9 Q
Was it approximately the 11:00 to 7:00 10 shift give or take an hour?
11 A
Yes, I would say that was the first entry 12 for September 8th, that being the 11:00 to 7:00 shift.
O 13 Q
Would you turn the page.
.A t the bottom 14 of page 06070, towards the bottom, there is an entry 15
" Opened RCV155 and V137, and started venting the 16 pressurizer,to the reactor coolant drain tank."
17 Do you recall that at some point during 18 this event the pressurizer was vented to the reactor 19 coolant drain tank?
20 MR. GLASSMAN:
You are asking the witness 21 for a present recollection rather than an 22 interpretation of this document.
23 MS. MCDONALD:
or if this log refreshes
/~
(,T) 24 his recollection.
l l
25 A
I don't recall.
1 Dominguez 52 2
Q Do you recall that there were vent valves 3
on the t'op of the pressurizer which led to the 4
reactor coolant drain tank?
(
5 A
I recall that there was at least one, yes.
'6 Q
Do you recognize either one of these 7
valve designations as being valves at the top of the 8
pressurizer?
9 A
No, I don't recall those valve designations.
10 Q
When you say you recall ateleast one, which 11 one was that?
i 12 A
I recall that the ' pressurizer had a vent,
(~T v
13 how many valves were associated with it or how many 11 different vents there actually were, I don't recall.
15 Q
Were these vents at the top of the 16 pressurizer, generally?
17 A
Generally, yes.
18 Q
Would you turn over the page to page 06071.
19 Do you see your handwriting anywhere on 20 that page?
21 A
Yes.
L 22 Q
Is the entry beginning with " Relieved 23 John Ulrich," is that your entire entry in your
)
24 handwriting through to the next page where you signed 25 your name?
1 Dominguez 53
("N
\\
2 A
Yes.
f 3
Q What do you recall was occurring when you 4
took over this shift,and if this document refreshes
(
5 your recollection feel free to make use of it.
6 MR. GLASSMAN:
You want the witness' 7
recollection now?
8 A
I don't recall exactly where we were at 9
the time of this entry in terms of plant conditions 10 other than what is recorded at the top:.
11 Q
Sort of two-thirds down the page, do you 12 see an entry which says " Pressurizer level 13 unexpectably increased when venting the pressurizer, 14 and decreased pressure from 500 psig to 460 psig.
15 Pressurizer level increased about 150 inches during 16 this evolution.
Pressurizer temperature was about 340 17 Fahrenheit.
Apparently the reference legs have 18 flashed and there was no steam in pressurizer to fill 19 the reference legs one reference leg is going 20 to be filled to verify the correct level."
21 Do you see that?
22 A
Yes, I do.
23 Q
That is in your handwriting?
( )
24 A
Yes, it is.
25 Q
Do you recall that during this event
1 Dominguez 54 2
pressurizer level increased approximately 150 inches, 3
and that that was unexpected to you?
4 A
Yes. I would like to say one other thing.
4,
(
5 I don't really recall this particular conversation, I
6 but I believe it~to.be correct, that there was an 7
unexpected increase in level.
8 Q
Can you recall why you considered it to 9
he unexpected?
10 A
Prior to this time I had never entertained 11 the -- this particular situation from occurring so it 12 was unexpected.
l 13 Q
I thought that it's written here that i
14 pressurizer level unexpectably increased.
Did you 15 mean unexpectably by the way?
f 16 A
We didn't expect it.
l l
17 Q
This occurred when venting the pressurizer 1
j 18 and decreased pressure from 500 to 460 phig.
Had you 19 aver before experienced the phenomenon of' pressurizer i
20 level going up at the same time that pressurizer level i
21 was going down?
22 A
I don't recall ever having witnessed that 23 prior to this.
( )
24 Q
Was it your understanding when you made
.q, 25 this entry that opening a valve at the top of the
1 Dominguez 55 cm v
2 pressurizer and venting it would tend to decrease 3
pressure in the reactor coolant system, everything 4
else remaining.the same?
(
5 A
Oh, yes.
6 Q
You wrote apparently the reference legs 7
have flashed and there was no steam in the pressurizer 8
to fill the reference leg.
9 Can you recall what you meant by that?
10 A
Yes.
As we described before, flashing 11 would be that the reference leg liquid had flashed 12 into steam.
Since we knew there was no steam in the O
\\
\\
'/
13 pressurizcr, there would be no way to fill that 14 reference leg back up.
15 MS. MCDONALD:
Would you read that 16 answer back.
17 (Question read.)
18 Q
Fill that reference leg back up with what?
19 A
Liquid.
~
20 Q
You wrote apparently the reference legs 21 have flashed, what caused you to think-that~r 22 MR. GLASSMAN: Objection.
There nas been 23 no testimony that was Mr. Dominguez' thought or
()
24 anyone else's thought at this point.
25 MS. MCDONALD:
He wrote that.
Dominguez 56 y
/"V]
2 MR. GLASSMAN:
There has been no 3
foundation, you haven't asked him whether or 4
not particular notes reflect his thoughts or
(
5 someone else's thoughts or any or all of the 6
above.
7 There is no foundation.
8 Q
I,just want to know why you wrote 9
apparently the reference legs flashed?
10 A
The word "apparently" was bsed bec.ause 11 apparently there was no proof, if you will, that that 12.
was the actual cause of the observed phonomena.
b()
13 g
Did you write that because you suspected 14 that that might be one cause?
15 A
To me that seemed the most logical 16 explanation for what had occurred.
l 17 Q
So as far as you recollect, you wrote this 18 based on a conclusion that you thought might be 19 possible rather than someone else telling you this?
20 A
I cannot-recall if this is my own 21 original thought.
It wouldn't be unusual to have l
22 discussed it prior to coming to that conclusion.
23 g
while you were on this shift, do you 24
_ recall having any conversations with any of the 25 control room operators or shift formean or shift
1 Dominguez 57
/
(
2 supervisor who was in the control room?
3 A
I d n't recall having conversations with 4
.them.
('
5 Q
Based on your understanding at the time 6
you wrote this, why did you consider flashing of the 7
reference legs as a possible explanation for the 8
pressurizer level behavior?
9 MR. GLASSMAN:
Are you asking for his 10 current recollection of what he gas thinking 11 then?
12 MS. MCDONALD:
His recollection, unless 13 I say otherwise that's what I'm.asking him.
14 A
The conclusion would be drawn that there 15 would be an inaccurate level indication in the 16 pressurizer due to the reference legs being in some 17 other state than completely filled with 1iquid.
l 18 Q
Did it subsequently, subsequently to 19 this entry, come to your knowledge that in fact the 20 pressurizer level which was seen was in fact the 21 accurate pressurizer level?
22 A
I don't recall.
23 Q
You wrote here one reference leg is going (nV) 24 to be filled with water to verify correct level.
25 How does filling the reference leg with
1 Dominguez 58
(
~
kJ 2
water verify the correct level based on your 3
understanding at this time?
4 A
If the reference leg is filled with water
(
5 from another source then we know that the reference 6
leg is indeed full, there is a guarantee that in fact 7
everything that is in there is liquid.
If that is 8
the case then it would indeed be indicated the level 9
it we.s calibrated to.
10 Q
Would you turn the page to!page 06072.
11 Based on your uncerstanding of how these 12 logs were kept, can you review the log and tell me who 13 relieved you, apparently relieved you?_
14 A
Jack Garrison relieved me.
15
.Q Do you recall informing Mr. Garrison of 16 the unexpected pressurizer level behavior that you had 17 witnessed or that you had recorded?
18 I don't recall the conversation.
g 19 Q
Was it your practice to review with the 20 oncoming shift what had gone on with your shift?
21 A
Yes, it was.
22 Q
Do you see in the middle of the page 06072 23 an entry which reads, " Pressurizer level transmitter 24 RC-LT3 was backfilled at reference leg.
Comparison q,/
25 was made between LT1, LT2 and LT3.
All three were
---.------.e
,.-----e------,-----e--
e -
1 Dominguez 59
[\\
LJ 2
reading
-same.
Pressurizer level indication as 3
shown in control room is believed to be correct."
4 Do you see that?
('
5 A
Yes, I do.
6 Q
Do you recall being told or hearing 7
somehow'that the pressurizer level response which you 8
had described in your entry was in fact correct and 9
that the pressurizer level had in. fact increased?
10 MR. GLASSMAN:
Could I have that read 11 back?
12 (Question read.)
O)
L.
13 A
No.
14 Q
After you observed this unexpected 15 pressurizer behavior, did you mention that to 16 anyone, did you have any conversations about how this 17 could be?
18 MR. GLASSMAN: Objection.
I don't think 19 there has been any testimony that 20 Mr. Dominguez personally observe'd that.
He 21 talked about his notes, but I don't believe 22 he personally observed that.
23 MS. MCDONALD: He testified that he 24 remembered this happening.
25 MR. GLASSMAN: I think there may be some
1 Dominguez 60 0
~
2 ambiguity.
3 Q
Do you remember the pressurizer level?
4 A
I do not remember this particular
(
5 phenomenon occurring.
6-Q Were you accustomed to writing down false 7
things in the log?
8 A
No.
9 MR. GLASSMAN:
Objection.
I think the 10 nature of my prior objection and shat I had 11 suggested ti.at counsel ask really re' lated to 12 know whether it was true or false.
We all see
(
13 the note and the note is in front of us.
14 The objection was whether this was a 15 personal observation of Mr. Dominguez or 16 whether he recalls the source of the information 17 contained in the note.
18 That's all.
19 Q
Do you recall the source of the information 20 contained in the note?
21 A
No, I do not.
22 Q
Do you recall that shift test engineers 23 '
were required to try to make sure that everything they 24 wrote in the log was accurate?
25 THE WITNESS:
Would you resd the question
-n--
1 Dominguez
~61 (3
Q.
2 back, please.
3 (Question read.)
4 MR. GLASSMAN:
Objection as to form.
j 5
By "try to make sure," are you referring to 6
some investigation of it or are you referring 7
to just putting down impressions at that point 8
in time.
"Try to make sure" is somewhat vague.
9 MS. MCDONALD:
You may answer the question.
10 MR. GLASSMAN:
The witness.can answer the 11 question if he understands it.
~
12 A
Yes.
13 Q
Were you aware of any requirement saying 14 that the shift test engineers are solely responsible l
15 for the the accuracy of all entries in the log?
h 16 A
I don't recall that statement ever being 17 made.
18 Q
Do you recall anyone telling you that it 19 was imperative that all entries into the log be l
20 objective, factual, timely and not reflect personal 21 opinion or personalities?
22 THE WITNESS:
Read that, please.
23 (Question read.)
(~)
%j 24 A
Yes.
\\
25 Q
Who told you that, was that during l
1 Dominguez 62 rr 2
your training?
3 A
Mr. Toole told me that.
4 Q
Did you take that to heart and try to
(
5 comply with that?
6 A
Yes, I did.
7 Q
Again, on page 06072, do you see 8
an entry two-thirds of the way down the page it says 9
"Whenever RC-V137 was opened to vent pressurizer, level 10 would indicate an increase"?
t
'll Do you see that?
12 A
Yes, I see it.
n#
13 Q
Do you recall any conversations or do you 14 recall it in any way coming to your attention that 15 every time the pressurizer was vented pressurizer 16 level would go up?
17 A
I don't recall having a conversation of 18 that type.
~
19 Q
Would you turn to the next page.
20 Do you see the entry that begins right 21 below where it is written September 9, 19777 22 A
Yes.
23 Q
can you tell who relieved Mr. Garrison, 24 based on your understanding of how these logs were 25 kept?
7 m-t-
-y.,.-w,,
--,-r-
,e
,----,-,,,r
L 1
Dominguez 63 2
A Yes, John Ulrich relieved Jack Garrison.
3 Q
Do you know where Mr. Ulrich is presently 4
employed?
5 A
I believe he is employed with Metropolitan 6
Edison Company.
7 Q
Do you see kind of in the middle of that 8
Page, that's page 06073, it says " Closed RCV137 and 9
applied nitrogen to the pressurizer.
The pressurizer 10 level came down proving that there was.a steam bubble 11 in each of the hot legs.
Left nitrogen on until 12 pressure started to slightly' increase and secured 13 nitrogen."
14 A
Yes.
15 Q
Just for the record, Mr. Dominguez, N is 16 nitrogen?
17 A
That's correct.
18 Q
Do you recall having it come to your
~
19 attention that when the vent at the top of the 20, Pressurizer is closed and nitrogen was applied 21 Pressurizer level came down?
L 22 A
Please read that?
23 (Question read.)
(v~ ")
24 A
I do not recall the specific instance.
25 g
would you look at page 06074.
Can you
I r
1 Dominguez 64 l
[
2 tell from this log entry that you relieved Mr. Ulrich?
3 A
Yes.
4 Q
Again, was it your practice when coming
(
5 upon shift to discuss what had gone on in the plant with 6
the shift test engineer that preceded you on shift?
7 A
Yes.
8 Q
Was it also your practice, as I believe you 9
testified before, let me just ask it again, to review 10 the' prior log entries when you came on', shift?
i 11 A
Yes, it was.
12 Q
Do you have any reason to believe that you O
13 did not review Mr. Ulrich's log entry when you came on 14 shift on September 9, 19777 15 A
No.
16 Q
Do you recall having any discussions with 17 Mr. Ulrich regarding where he apparently had written 18 that the pressurizer level came down pro ing that there i
19 was a steam bubble in each of the hot legs?
20 A
I do not recall a conversation with 21 Mr. Ulrich.
22 Q
Based on your understanding of how the 23 system worked and your training up to this date, did 24 you understand how it could be that there would be a 25 steam bubble in the hot legs?
I
~
g
\\
\\
1 Dominguez 65 s
f, 2'
A No.
N 3
Q You don't recall. going and asking anybody 4 -
I
,4 how that could be?'
s s
(
5 A
I don't recall having conversati ns of 6
that naturd,
3 s
s s.
7
'Q was it y'our enderstanding at or about this 8
' time that in a reactor coolant system which was solid 9
and' filled with water that when nitrogen was applied 10 to the top of the prensurizer level would go down*or 11 would it stay the same?
k
' \\.
12 MR. GLASS!AN:
Are you asking him whether O
s'-1
\\
that was ever ccusidered?
13-
,s s
14 MS. MCDONALD:
I am asking whether based s
t k
C 15i ', '
on his knowledge at that time.
s i
16' THE WITNESS:
Please reread the question.
(Qu'es tion re'ad. )
Iil7
(
/
s s
18
'A I-don't belie've I ever considered the
,f 19 situation.
29 Q
We ll,, Mr'.
Dominguez, you had a bachelor N
(
s
, 21 of mechanical eng'ineering from Penn State.
You had
(_
M i 22 training on pressuriz,ed water reactors in the Navy.
23 You had several edurses in physics and you have had n
i
.s 20 some coursei. -in, thermodynamics.
You had been trained s.
25 l to a.certain estent at' Met Ed.
l t
s' h
p g
. -,. -. x :
1 Dominguez 66 OkJ 2
I am asking you not whether you 3
specifically considered that possibility.
I am asking 4
you based on all of the knowledge that you had
(
5 thinking back to what kind of' knowledge you had then, 6
what would you have expected to happen?
7 MR. GLASSMAN: I object to the totally l
8 hypothetical realm.
The witness said he did 9
not consider it.
Moreover,I think he testified 10 sometime earlier that he had never even seen 11 solid operations except in hydrostatic testing, 12 and even there he didn't know that he had 13 actually seen them so you can ask him a question
~
14 about something he recalls, but it's 15 inappropriate to get into some hypothetical area 16 about whether piecing together some part of some 17 education which we haven't identified --
18 MS. MCDONALD:
I have. identified it.
And
~
19.
I am entitled to ask him what all of his training 9
20 led him to know about the operation of a 21 pressurized water reactor.
I do not have to be 22 limited to things which actually happened in the 23 pressurized' water reactor.
D(,)
24 MR. GLASSMAN:
You can ask him that,what 25 his training told him.
1 Dominguez 67
/
\\
MS. MCDONALD:
That's all I asked him..
2 BY MS. M NALD:
3 4
Q Can you answer the question?
MR. GLASSMAN:
Do you understand the
(
5 6
question?
THE WITNESS:
Yes.
7 g
A If the loops are completely full of water 9
and the pressurizer is completely full of water,.and 10 Pressure is applied to the top of the pressurizer I 11 would expect to see no change in level of significance 12 in the pressurizer.
/
13 Q
Well, whether or not you remember discussing 14 Mr. Ulrich's apparent entry with him on that day,do 15 y u recall any conversations with anyone up to the time 16 you left Metropolitan Edison regarding the possibility 17 that a steam bubble had formed in the hot, legs during l
18 this September '77 event?
~
10 A
I don't recall having a conversation as to that nature.
20
(
Q Do you recall any surprise registering in 21 l
(_
22 your mind with regard to anything that happened in 23 this event regarding bubbles in the hot legs, possible
('
i bubbles in the hot legs?
94
\\_)
~
I 25 A
You are referring to John Ulrich's entry 1
1 Dominguez 68
/~N V
2 there?
3 Q
Yes.
4 A
I don't recall any particular reaction
((
5 after reading that entry.
6 Q
Would you refer to page 06078 of this log.
7 Do you see the entry beginning at the bottom of that 8
page, it says " Relieved Craig McMullin"?
9 A
Yes.
10 Q
If you would review the nekt couple of pages 11 through 06080, can you tell that that is in fact the 12 beginning of your entry, your signature appears to be f_U 13 on page 06080 with the exception of some writing on 14 06079 which may not be yours.
15 MR. GLASSMAN:
I am somewhat confused now.
16 MS. MCDONALD:
All I want to know is, 17 apparently, Mr. Dominguez began entering on 18 06078. It continues on 06079 and is interrupted i
19 ith some other writing and then continues on l
20 the bottom of the page and he signs it, 21 apparently, on page 06080.
l k.
22 Is that correct?
23 THE WITNESS:
That's correct.
24 Q
You talked before about Mr. Toole having l
25 the practice of reviewing the log.
Do you see an entry i
1 I
d 1
Dominguez 69
/~N b
2 in the middle of your entry on 06079 which appears to 3
be written by Mr. Toole?
4 A
Yes.
({
5 Q
Are you familiar with Mr. Toole's 6
handwriting for reviewing these logs?
7 A
No, I am not.
8 Q
Was it your practice to review whatever 9
Mr. Toole had written in the log?
10 A
Yes, it was.
t 11 Q
Towards the end of Mr. Toole's entry, 12 number 6 reads:
"There is no reason given for how we
.O 13
.got into problems on pressurizer level.
A change to 14 cooldown procedure could be made if we knew what to 15 do."
(
16 You will recall discussing with Mr. Toole 17 a problem about pressurizer level that had occurred 18 during this incident?
19 A
I don't recall having a discussion with 20 Mr. Toole concerning this incident.
21 Q
Do you recall reviewing this entry?
22 MR. GLASSMAN:
Aside from any review with i
23 counsel?
()
24 MS. MCDONALD:
Yes, reviewing this entry ss l
25 at or about the time it was written.
-1 Dominguez 70 '
O 2
A I don't recall reviewing it, no.
3 Q
But it was your practice to do so, however?
4 A
But it was my practice to do so, yes.
('
5 Q
What training, if any, did you receive 6
after this September incident to explain to you what 7
had happened?
8 A
The September incident?
4 9
Q This incident we have been discussing here.
10 A
Training subsequent to that particular 11 incident to explain it?
12 Q
To review or go over what had happened O-13 during the incident.
I4 A
Well, I don't recall anything.
I don't j
i 15 recall any training to explain the phenomena.
16 t
g As far as you recall up until the time f
l 17 you left Met Ed you never got an explanation of why 10 that pressurizer level had gone up unexpectedly?
As 19 far as you know no one ever told you why?
(
20 A
I don't recall receiving an explanation j
l 21 as to why that occurred.
22 Q
Do you know Who Mr. Illjes i::, Ted Illjes?
23 A
The name is familiar. I cannot recall what 24 position he had.
I 25 g
Do you have any recollection of what
1 Dominguez 71 (v~1 2
Mr. Illjes was doing, if anything, with relation to 3
this incident?
4 A
No, I do not.
({
5 Q
You testified that you were in part 6
concerned with the resin migration in this incident 7
is that right?
8 A
Yes.
9 Q
what did you do with respect to the resin 10 migration?
t 11 A
I was instructed to assist Metropolitan 12 Edison's staff in their investigation as to the extent"
(~h 13 of the resin migration and come up with plans to 14 determine the extent of it and means of resolving the 15 problem.
t 16 Q
So I understand, did you have to go 17 somewhere out of the control room to look at where the 18 resins might be?
19 Do you understand the question?
i 20 A
Yes.
The time frame of this would be 21 the investigation occurred several days after the 22 actual incident occurred.
The corrective action that 23 was taking place occurred over a period of a month or 24 so subsequent to the incident.
25 Q
As far as you remember you were not
'l
-g
+w-,
-.., - ~
1 Dominguez 72
[)
'O 2
involved in investigating what had gone on with 3
respect to the resin until a few days after the 4
event?
({
5 A
That's correct.
6 Q
At the time you wrote the entry that's on 7
page 06071, were you in the control room?
8 A
I would be unable to place my location in l
9 the control room at any specific time during the shift.
10 Q
Well, can you from reviewing the log and l
11 based on your knowledge how you made log entries tell 12 me whether you were probably in the control room when
'N.
,' )
13 you wrote something about pressuri=er level?
14 A
I was not in the control room. It was not 15 my habit to write entries into the log in the control 16 room, but rather in an office that was off to the side 17 of the control room.
18 Q
In other words, if you wanted to write 19 something in the log, you would leave the control room 20 and go to some other office?
21 A
Yes.
L 22 Q
Where was that office?
23 A
It was off to the side of the control room.
O) 24 Q
As far as you recollect, however, you t%s 25 weren't somewhere totally different, away from the
1 Dominguez 73 2
control room when you wrote this?
3 MR. GLASSMAN:
I think the witness just 4
said he couldn't tell you that.
(
5 MS. MCDONALD:
Well, I asked him based 6
on his knowledge of how he made log entries.
l 7
A From my recollection all log entries were 8
made in the office that was off to the control room.
9 Q
Do you recall having any conversations 10 about this event, by "this event" I me'an the one we 11 were discussing in September 1977 with Mr. Hartman?
12 A
I don't recall having a conversation with N_
~
13 Mr. Hartman concerning this event.
14 Q
Mr. Scheimann?
t 15 A
No.
16 Q
Mr. Frederick?
17 A
No.
18 Q
Mr. Faust?
t i
19 A
No.
l 20 Q
Mr. Zewe?
21 A
No.
22 Q
Have you ever had any conversations with 23 anyone other than a gentleman from the NRC and counsel 24 about this event?
25 A
I do not recall any other conversations.
. _ ~
. - -.. ~
1 Dominguez 74 O
2 Q
You never received any phone calls from 3
anyone at GPU or Met Ed to ask you what you remembered 4
about this event?
(
5 A
No, I never received them.
6 Q
Were you ever asked by anyone other than 7
counsel to review this document that I am about to 8
show you which has been previously marked as B&W 837.
i 9
I just want to know whether you have ever seen that?
10 The document is entitled " T2iI-2 Septem'ber 1977 Hot 11 Functional Testing Event."
12 A
No, I have never seen this before.
V 13 Q
Have you ever'seen what has been previously 14 marked as B&W Exhibit 838 entitled GPU Nuclear 15 Technical Data Report Analysis of TMI-2 September 1977 l
16 Event During Hot Functional Tests"?
17 A
I don't recall ever seeing this report.
I 18 Q
As far as you remember then you had no 19 input into these reports?
20 A
I don't recall ever having input to these.-
21 Q
In 1981 you were already employed by I
22 Pennsylvania Power & Light, were you not?
23 A
That's correct.
24 Q
I would like to refer you to some charts l
25 that are attached to B&W Exhibit 838.
The pages I
1 Dominguez 75 r
U) 2 want to refer you to are headed " Figure 2,
Pressurizer 3
Level Increase From 107 to 320 inches 6:30 a.m.
to 4
9:15 a.m.
9/8/77" and " Figure 3, Pressurizer Level
({
5 Increase from 305 to 385 inches, 2100, 9/8/77."
6 I want to ask you if this chart refreshes 7
your recollection in any way as to whether you ever i
8 saw pressurizer lever solid indicated at TMI-2 other 9
than possibly in hydrostatic tests?
10 A
No, it doesn't.
E i
11 Q
Do you see on Figure 3 that for a period of 12 time pressurizer level was somewhere between 350, at O
13 least according to this graph between,350 and 400 14 inches?
15, MR. GLASSMAN:
Objection.
We can all l
16 agree that the figure shows what it shows, but 17 this vitness hasn't seen it before,. so it's 18 inappropriate to ask him questions about that.
19 MS. MCDONALD:
I want to see if his 20 recollection is in any way reflected by this i
21 document prepared by GPU.
k.
99 MR. GLASSMAN:
I think he's already told 23 you that it wasn't, but you can ask him that
()
24 again:
The question is whether this document 25 refreshes your recollection.
l
g Dominguez 76
('%
V 2
A No, it doesn't.
3 Q
'I take it you have no reason to believe 4
that this chart attached to GPU technical data report l
5 is inaccurate?
6 MR. GLASSMAN: Objection.
I instruct the 7
witness not to a'nswer.
The witness has not 8
reviewed this document before.
He's testified 9
that he had not seen it.
10 Q
Have you ever had any conversations with 11 anyone from something called the Hart Committee, the 2
congressional committee?
A No.
14 Q
After the Three Mile Island accident had 15 you had any conversations other than the,NRC 16 conversation we have already talked about about 17 anything having to do with your employment at Met Ed?
18 MR. GLASSMAN:
Other than conversations 19 with counsel?
20 MS. MCDONALD:
Yes.
21 A
I can't recall any conversations of that 22 nature.
23 Q
Do you recall that any, change to the 24 cooldown procedure was made after this September event 25 as a result of what had happened?
e e
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1 Dominguez 77
- 7.,
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2 A
No, I don't.
3 Q
.D y u recall any conversations with 4
Mr. Toole regarding his entry, apparent entry, saying 5
a change to cooldown procedure could be made if we
((
6 knew what to do?
7 A
I don't recall a conversation with 8
Mr. Toole concerning that.
9 Q
Mr. Hawkins ?
10 A
or Mr. Hawkins.
t 11 MS. MCDONALD:
Off the record.
12 (Discussion off the record.)
O
\\-
13 Q
Mr. Dominguez, I have one other question 14 about this event:
Based on your understanding of how 15 the system worked at TMI-2, am I correct in thinking 16 that if the reactor coolant pumps are off that the 17 spray to the pressurizer is inoperable, was inoperable, 18 normal spray to the pressurizer?
19 A
I believe that's correct.
20 Q
I would like to'show you a portion of 21 what's already been marked as B&W Exhibit 174 which
\\
22 is a shift test engineers log.
23 Q
I am showing you pages 06000 through 06002
(
24 of B&W Exhibit 174.
25 On page 06001, do you see an entry made 1
.r
1 Dominguez 78 m
\\
(J 2
by you?
3 A
-Yes.
4 Q
The entry starts " Relieved Craig McMullin,"
{
5 and then continues on the next page until it is signed 6
by you, i~s that right?
7 A
Yes.
8 Q
And that's your handwriting and that's your 9
signature?
10 A
Yes.
t 11 Q
Is this an entry for August 12, 1977 42 according to the log, can you read the date next to 13 your name?
14 MR. GLASSMAN:
That's obviously what it 15 says?
16 A
Yes, I didn't hear the question, yes, it is.
17 Q
Referring to the bottom of page 06001 1
18 you wrote, " Started investigating makeup tank level
~
19 decreasing excessively.
Discovered NDTT relief 20 leaking by using downstream temperature indication 21 on computer.
Shut RC-V2 and cycled the NDTT relief and r1 22 reopened RC-V2 with no further leakage noted. "
23 I's that your handwriting?
24 A
- Yes, v
25 Q
Mr. Dominguez, was the NDTT relief valve
1 Dominguez 79
%)
2 the same valve as the PORV, but in a different mode?
^
3 A
.To the best of my knowledge, yes.
4 Q
The pilot operated relief valve was a 5
valve at the top of the pressurizer, is that right?
{
6 A
Yes.
7 Q
And at certain pressures, is it your 8
recollection that that valve's setpoints would be 9
changed; in other words, to make them the NDTT 10
.setpoihts.
c
^
11 A
I don't recall.
12 Q
But in any event this NDTT relief that's
(')%
t'-
13 mentioned here as far as you recollect was another 14 name for the PORV?
15 A
Yes.
16 Q
What downstream temperature indication on I
i 17 computer were you referring to when you wrote this?
18 A
I can only reword what is written.
l 19 MR. GLASSMAN:
You are asking'for his l
20 recollection?
l 21 MS. MCDONALD:
I am asking for his L
22 recollection of what indication there was, 23 downstream of what?
i
(
24 A
Downstream of the relief valve pipe l
25 there was a temperature indicator that was read l
1
. -. - - ~.
1 Dominguez 80 2
on the computer.
3 Q
. Based on your recollection did you 4
consider it possible to determine or to at least
(
5 investigate whether the pilot operated relief valve 6
was leaking by use of the downstream temperatures?
7 THE WITNESS:
Reread the question, 8
please.
9 (Question read.)
10 A
Yes.
e 11 Q
You went on to write " Shut RC-V2," is 12 that the block valv'e of the pilot operated relief?
O' 13 A
I believe it is.
14 Q
Based on your recollection of how the l
15 system worked why were you shutting the block valve, 16 cycling the relief and then reopening the block valve?
i 17 I mean, what is the purpose of that?
~
18 A
When you shut the block valve, you remove 19 the pressure on the relief valve.
When you cycle the l
i l
20 valve, you are giving it another opportunity to seat L
l 21 properly under a low pressure condition.
With that
(_
22 amount of information, that's why we chose to do this.
23 Q
While you were at Met Ed, was it your
. (
24 practice if you thought the PORV might be leaking to 25
' Perform this evolution or whatever you want to call l
I Dominguez 81 ps, V-2 it; namely, closing the block valve, cycling the PORV 3
and then reopening the block valve?
4 MR. GLASSMAN:
I don't know what you mean
(
5 by practice.
There has been no foundation as to 6
how often this occurred or whether it occurred 7
~
more than once.
0 MS. MCDONALD:
I don't mean to indicate 9
that it occurred a lot by use of the word 10
" practice" but if you thought the PORV was 11 leaking, what would you do?
12 A
I would use the same procedure.
V 13 Q
You wrote " Shut RC-V2 and cycled the NDTT 14 relief and reopened RC-V2 with no further leakage 15 noted."
e 16 How did you determine that there was no 17 further leakage?
~
18 MR. GLASSMAN:
Are you asking for his 19 recollection?
20 MS. MCDONALD:
I am asking for-his.
21 recollection, yes.
I am always asking for his 22 recollection, Mr. Glassman, and I think it's 23 inappropriate to constantly interrupt in an A()-
24 attempt to remind the witness that he might not 25 remember this.
1 Dominguez 82 2
MR. GLASSMAN:
I am not doing that at all.
I object to your comments.
There has been no 3
4 testimony whether his recollection is based on
((
5 a note by Mr. Dominguez or whether this note is 6
based on somebody else.
l l
l 7
MS. MCDONALD:
I don't think it makes any l
8 difference.
i l
9 MR. GLASSMAN:
Your question had a lack of i
10 foundation.
You assumed that Mr. Dominguez did 11 something.
12 MS. MCDONALD:
Wall, he wrote this.
x/
13 MR. GLASSMAN:
Well, he did write this, 14 yes.
15 MS. MCDONALD:
Does he just write things 16 out of the blue?
17 MR. GLASSMAN:
You know full,well as a 18 person with some experience that t h'e notes can 19 reflect various things and you are here to be l
20 able to ask him questions about it, not to make i
21 assumptions or guesses.
You may proceed.
22 Q
Mr. Dominguez, how was it possible to 23 determine that there was no further leakage?
)
24 A
It would be possible to determine there i
25 is no further leakage by using the downstream i
l
\\
i 1
Dominguez 83 (D
v 2
temperature indication on the computer.
3 Q
-Do you mean by that that the downstream 4
temperatura would then be lower than it was when you
(
5 thought it was leaking?
6 A
Yes.
7 Q
Do you recall where you got this information 8
that you wrote down here that you observed this or did 9
some control room operator tell you?
10 A
It was one or the other.
2 don't recall 11 exactly which one.
12 Q
Do you recall any conversations with A
13 anyone prior to the time you left Met d about how to 14 determine whether the PORV was leaking?
15 A
I don't recall having conversations of 16 that nature.
17 Q
Was that ever mentioned in your training?
18 A
Not that I can recall.
19 Q
Did the reactors with which you were 20 familiar in the Navy have relief valves at the top of 21 the pressurizer?
22 A
To the best of my knowledge, yes.
23 Q
Did you ever have occasion to
()
24 investigate leakage on any of those?
25 A
No.
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1 Dominguez 84 Od 2
Q Can you tell me which shift,this is 3
based on, your knowledge of how thes'e logs were kept?
4 This being your entry on August 12, 1977.
5 A ~
Well, Jack Garrison had the midnight shift
(
6 from 11:00 to 7:00 and -- well, excuse me, that's not 7
true.
Craig McMullin had the first shift on the 8
August 12, 1977, which would have been the 11:00 to 9
7:00 shift.
10 Q
And then you came on, is that right?
11 A
I relieved Craig McMullin so I had the 12 7:00 to 3 o' clock shift.
~
\\/
13 Q
I would like to show you another portion 14 of B&W 174 pages 06011 through 06015.
And specifically 15 I would like to refer you to page 06013 which appears 16 to be an entry by Jack Garrison apparently for l
17 August 17, 1977.
l l
18 Do you see that?
19 A
Yes, I see it.
20 Q.
Now, if you follow along in this log, do 21 you see that some later period you relieved 22.
Mc. McMullin on August 18, 1977 according to the log?
23 A
Yes.
[/D 24 Q
And again it was your practice to go 1
\\_
25 back and review the prior log entries?
I i
l
1 Dominguez 85 h
Y 2
A Yes.
i 3
Q
- Now, on page 06013 do you see an entry 4
that reads ?NDTT relief appears to be leaking into r(
5 reactor coolant drain tank" C1,osed RC.-V2 and manually 6
opened valve RC-RV2. Closed RC-V2 and reopened RC-V2.
I 7
Monitored downstream line temperature and reactor l
8 coolant drain tank level.
Indications were that valve 9
was still leaking.
Closed RC-V2 and allowed line to 10 cool to approximately 125 degrees Fahr'enheit.
Manually 11 cycled valve again and reopened RC-V2.
Indicates valve l -
12 is still leaking.
Issued PR Number 5055."
t 13 Do you recall this event?
14 A
I don't recall this particular event.
l 15 Q
Based on your review today, do you see l
16 that it's another example of what we were talking 17 about before?
18 MR. GLASSMAN:
Objection, the witness said 19 '
he didn't recall it. He is not here to tell you 20 now what he sees with regard to a document i
l-21 that he doesn't recall.
k 22 Q
Do you recall prior to leaving 23 Metropolitan Edison that on occasion the pilot operated 8
24 relief valve would leak and that would be determined 25 by use of certain indications such as downstream
1 Dominguez 86 m
2 temperature or reactor coolant drain tank level?
3 A
I can recall that that was a method which 4
I employed to deterpine whether the valve was leaking
(
5 or not.
6 Q
And as you testified before, part of that 7
investigation might on occasion involve closing the 8
block valve and then monitoring the temperatures you 9
- saw, is that correct?
10 A
Yes, that is correct.
E 11 Q
I would like to show you a portion of 12 again, B&W 174, pages 06144 and 06145.
Again this is O
13 part of the shift test engineers log.,
14 Do you see an entry on*page 061447 It 15 starts:
" Relieved by Andre Dominquez"?
e 16 A
Yes.
17 Q
And then do you see an entry that you 18 wrote, that is in your handwriting anyway?
19 A
Yes.
20 Q
Is that entry signed by you on page 06145?
21 A
Yes.
22 Q
Is there a date next to your signature, 23 October 7, 19777 24 A
10/7/77, yes.
25 Q
on page 06144 on the bottom, do you see,
4 1
Dominguez
~
87 CE) 2 it's written there, " Opened RC-VT ?
Again, that's the 3
block valve, is that correct?
4 A
Yes.
((
5 Q
"And temperature downstream RC-RV-2 remained i
6 at 123' degrees Fahrenheit"?
7 A
Yes.
8 Q
Do you remember, based on your understanding 9
and knowledge up to that time why you wrote that, what 10 that meant?
E 11 MR. GLASSMAN:
You don't want him to 12 interpret this document for you now, you want O
x_J 13 his recollection?
14 MS. MCDONALD:
Right.
15 A
I am not really sure, but it appears to l
16 be connected with some prior event as if, perhaps, I 17 was instructed to open the valve and record the 18 temperature.
l 19 Q
Based on your training and knowledge up i
20 to this time, was it your understanding that if the 21 block valve had been closed for a period of time and 22 then it was opened and the temperature stayed the same l
23 that was at least some indication that the PORV was
(
24 not laaking?
25 A
I believe that it could be interpreted
1 Dominguez 88 J.
2 as such.
3 Q
Having reviewed these log entries that 4
talk about the PORV, do any of them refresh your j
(
5 recollection about any conversations you may have had 6
regarding how to determine whether the PORV was 7
leaking or not?
8 A
No, they do not.
9 Q
Did anyone ever tell you in your training 10 at Met Ed that you must never close th'e block valve 11 to the PORV7 12 A
I don't recall that statement ever being 13 made.
14 Q
Do you recall anyone that you talked to 15 ever expressing concern about closing the block valve 16 to the PORV?
17 A
No, I never heard anybody expressing that 18 kind of concern.
19 Q
I would like to show you anotter portion 20 of the shift test engineers log, and this portion 21 comes from B&W Exhibit 174 again, and I would like to 22 show you pages 06042 through 06045.
23 I would like to refer you to page 06044 24 which appears to be an entry made by John Ulrich on 25 August 30, 1977.
Do you see towards the bottom
1 Dominguez 89
/~m
(
)
v 2
of that page is written, " Relieved by Andre Dominguez"?
3 A
Yes.
4 Q
Above where it says that, Mr. Ulrich has
(
5 apparently written "Successfully cycled NC-V2 af ter 6
open torque switch was set to 1.5.
Placed RC-R2 in 7
auto and raised RCS pressure to 2275 psig.
RC-R2 lif ted 8
at approximately 2250 psig.
Sprayed down pressurizer 9
to 2130 psig and RC-R2 never closed.
10 "The relay which actuates RC-R2 did drop out 11 so it looks like RC-R2 is mechanically binding."
12 Do you recall reading that entry?
k-)
13 A
I don't recall reading this entry.
14 Q
But again it was your practice to review 15 the prior entries and so forth, is that correct?
16 A
Yes.
17 Q
Based on your recollection of when you 18 were the shift test engineer at Metropolitan Edison, 19 can you tell me what relay is being referred to there?
20 I don't mean its designation, but just what it says.
21 A
A relay is a device which changes state, 22 that is, it's either on or off.
This particular relay 23 referred to in this entry is the device which will s
(
24 turn on or open the valve or instruct us, if you will, 25 to close.
1 Dominguez 90 2
Q It was, based on your recollection an 3
electrical device which commanded the valve to open?
4 A
Yes.
((
5 Q
And if it was off the valve was 6
electrically told to close, is that correct?
7 A
In a manner of speaking, that is correct.
8 Q
Do you recall it coming to your attention 9
while you were at Metropolitan Edison that even though 10 the status of the electrical signal to,the PORV was 2
11 telling the valve to close that it could nevertheless 1
12 stay open for some mechanical reason?
13 Did that come to your attention?
i 14 A
1 don't recall it coming to my attention 15 in this particular instance.
16 Q
Do you recall it coming to your attention 17 in general?
18 A
It's a matter of fact in any' case.
l f' r a 19 Q
That a valve can stick open o
20 mechanical reason despite the status of the electrical 21 signal that's going to it?
L 22 A
correct.
23 Q
Do you recall any specific instances at
()
24 TMI-2 of the PORV being open when it was supposed 25 to be closed or being closed when it was supposed to
1 Dominguez 91 2
he open, specific instances?
3 A
There was an occasion when the pressure --
4 excuse me, when the PORV was open, and the control
(
5 room did not have that knowledge.
6 Q
Do you recall that event occurring in 7
March approximately of 19787 8
A I don't recall the exact time.
9-Q Do you recall that there came a time when 10 a light was installed in the control room with respect 11 to the PORV7 12 MR. GLASSMAN:
Are you talking about the 13 TMI-2 control room?
14 MS. MCDONALD:
Yes.
15 A
I don't recall the actual installation of 16 a light.
What I do recall is that there was a light 17 indication given associated with that particular valve.
lighhwasput 18 Q
Do you recall that that in 19 after the event that you just described regarding the 20 PORV being open when it should have been closed?
21 A
Yes.
22 Q
Do you recall anyone from Met Ed or'GPU 23 telling you what that light was for?
()
24 A
I don't recall any specific instruction 25 as to what that valve excuse me, where that light
1 Dominguez 92 s
2 came from.
3 Q
You do, I take it, remember there was at 4
some point a light there in the control room?
((
5 A
Yes.
^
6 Q
Do you recall that that light showed 7
whether or not power was going to the solenoid, the 8
PORV solenoid?
9 A
As I recall that was the case.
10 Q
Was it your understanding,0in any event, 11 that that PORV could remain open for a mechanical 12 reason even though the electrical signal that was
(_/
13 going to the PORV was off?
14 MR. GLASSMAN:
The witness just gave us 15 his testimony a few moments ago about his general 16 understanding regarding valves and electrical 17 signals.
The question now is whether he particularly 18 understood that with regard to this valve?
19 MS. MCDONALD:
No, I think really to make 20 it more clear my question is:
21 Q
Did you understand that what the light N-22 in the control room showed was the electrical status 23 of the PORV?
' _m
/()
24 MR. GLASSMAN:
I think he just answered 25 that.
He understood that was power to the solenoid.
31 g
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Dominguez 93 i
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- I Q. [
Is chatYright?,
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A
.Yes.
' / l s
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I, "f
5
,4 Q
Am I correct i::. thinking /that' your
)
/
t 4
5 unde rs tanding;,' tha t you-testified dcut, before; namely,
(
t 6
that the valve could be open for a mejchanical reason desdiuk the electrical status of the.valv.e d'id not /
i 7
/
s
- 8 change in any way after the. light was installed in the
.i i
/
1 a
r g
g control' room?
, s 10 MR. GLA S SMAN's Ob'jectifn as to form.
The 1
- i s.
witness aar, answer it.
'l 11-r I
I My understanding did no,t change.
12 A
Did ' ou have' any conversations with 13 Q
y
'I
/
l 14 anyone a f t e r[ t h,e light was,< installed regarding the
)
1
~, I.
i 15 light?
/
1 a
16 A
Not that I can' recall.
17 Q
could you tell m'e again. *IJ'4now we went 1
l l
18 into this before, when you left Metropol tan Edisen, l
l~
19 approximately what month was that?
20 A
Approx'imately September.
21 Q
of 19787
(
r l
22 A
Yes.
l l
23 Q
I would like to show you now;another i
(A V;-
24 portion of the shift test engineers log.
This portion i
25 comes from B&W Exhibit 176.
I am showing you pages 1
I
/
1 I
[
)
y
1 Dominguez 94 2
06452.-through 06454.
3 On page 06454, do you se'e an entry 4
that reads " Relieved by Andr97Dominguez," signed 5
APParently " John Ulrich," dated March 29, 19787
((
6 A
Yes.
7 Q
And do you see an entry written by yourself 8
and then signed by you?
9 A
Yes.
10 Q
Now, could you take a look;at Mr. Ulrich's 11 entry and tell me whether you can tell that this entry 12 relates to the events that you testified to just now O
13 where the PORV was open when it shoul[have been Yl 1
14 closed?
l 15 Just review his entry and see if you can 16 determine that?
17 MR. GLASSMAN:
That's inappropriate.
18 If you are asking whether this refreshes his l
l 19 recollection that's appropriate, but he is not 20 here to interpret l
21 MS. MCDONALD:
All right, I'll ask that, k.
22 MR. GLASSMAU: It's not in his handwriting, i
23 that portion.
l O[
24 Can you rephrase the question?
25 Q
Do you see on page 06453 it is written
.,.._._m_,
m.
,_m..-
1 Dominguez 95 Q("T
~
2 that 1440, it appears at this time that during ES 3
testing the. fuses on 2-IV invarter blew and gave 4
a reactor trip and a full ES actuation.
The 5
electromatic relief valve lifted and pressurized the
(
6 RC drain tank to approximately 100 psig.
The 7
inverter was put on alternate source and the HP 8
injection stopped.
9 Does this refresh your recollection that 10 the events that you were referring to3.before occurred 11 on March 29, 19787 12 A
Yes.
b
\\-
13 Q
Mr. Dominguez, do you see Mr. Ulrich's 14 entry on page 06454, something that reads, "The 15 pressurizer level was increased to approximately 2,00, 16 inches.
RCS pressure decreased to approximately 1200 17 psig before recovery started."
18 When you relieved Mr. Ulrich,' did you i
~
19 have any conversations with him about that particular 20 entry that he had written, apparently written?
21 A
I don't recall.
L 22 Q
Again, it was your practice to review 23 prior log entries, is that right?
24 A
Yes.
25 Q
Do you recall any discussions while you
90*7 1
Dominguez
\\
2 were at Met Ed with regard to pressurizer level 3
increasing reactor coolant system pressure decreasing 4
during-this March 29, 1978 event?
5 A
No.
6 Q
Did you receive any training after this 7
March 29, 1978 event with regard to what had happened 8
during the event?
9 A
I don't recall any training.
10 Q
Based on all of your train ng and your 11 knowledge of how pressurized water reactors worked 12 up until this time, March of 1978, and again I want O's /
13 you to think back and give me your recollection, m
14 would you have considered it unusual to have 15 pressurizer level increase at the same time pressure 16 was decreasing?
17 MR. GLASSMAN:
If you are asking whether 18 this was something that was conside~ red, I will i
19 let him answer it, but if you are asking how 20 he might have responded to some hypothetical 21 situation which he doesn't recall then it's
(-
22 inappropriate.
23 MS. MCDONALD:
Mr. Glassman, we went
/")%
24 through this before, and you let him answer and
(
25 I said based on his training and his knowledge,
1 Dominguez 98 0) t'
2 his training from everywhere and his knowledge 3
of how pressurized water reactors worked, would 4
he have considered it unusual to have pressurizer
(
5 level increase while pressure was decreasing, 6
and I am not limited to whether he knows of a 7
specific event or anything like that.
8 MR. GLASSMAN:
You can ask whether he was 9
trained on that. I will permit him to answer 10 that, but to ask him whether he hight have
/
11 considered it to be unusual to see something 12 which he was not trained for is inappropriate.
(~)
13 You can ask him what he was trained on and if he 14 was trained on it.
15 Q
Mr. Dominguez, were you trained that it 16 was the usual reaction of a pressurized water reactor 17 that pressure would go down while pressurizer level 18 was going up?
19 A
I don't recall receiving that specific 20 instruction.
21 Q
In fact, weren't you trained the opposite?
k.
22 A
I don't recall.
23 Q
I take it as best you can recollect, you
[)\\
24 didn't express any surprise or astonishment to 25 Mr. Ulrich upon reading this entry?
1 Dominguez 99 (b
2 A
I don't recall whether I was surprised 3
or astonished or complacent after reading that.
4 Q
Did you receive any training after this 5
event which indicated to you that it was possible to
(
6 have reactor coolant system pressure go down while 7
pressurizer level was going up?
8 A
Not that I can recall.
9 (Recess taken.)
10 Q
Mr. Dominguez, prior to the Three Mile 11 Island accident, did you know that voiding could 12 occur in a pressurized water reactor in the p rimary
~
13 system outside the pressurizer, and that that voiding s-14 could cause pressurizer level to increase?
15 A
No.
16 Q
Do you know that now?
l 17 A
I really don't feel qualified in answering 18 that.
I have never assembled the facts o'f what had 19 occurred in Three Mile Island and so I really don't 20 feel qualified to say that.
21 Q
I am not relating my question to anything L
22 related to Three Mile Island. I am just wondering if 23 you know that today from any source?
24 A
I have never seen it written or 25 communicated to me that that was a source.
1 Dominguez 200
(-
2 Q
Just so the question is clear:
I am not 3
limiting my question to something you remember being 4
told or something you remember experiencing.
Human
({ '
5 beings know thLngs that they can't remember who told 6
them. I know that the sun came up on March 1,
1963.
7 I have no rscollection of either seeing it or being 8
told it.
9 I would like to know whether you know in 10 your brain that voiding in the reactor', coolant system 11 can cause pressurizer level to increase based on all 12 of your knowledge ahd training and college degree and O
13 information that cam,e into your head?.
s 14 MR. GLASSMAN: Pe'rhaps we are quibbling, 15 and this is a bit silly here, but it's a perfect l
16 example, when you say that the sun came up on 17 March 1,in some particular area it may have I
18 been cloudy,and you are saying, you know, you 19 are just assuming you know that.
You are just 20 assuming that.
That's precisely the point. It's l
[
21 a silly example, but, for example, in another
(.
22 part of the world,you could be in a part of the 23 world where it was cloudy.
24 MS. MCDONALD:
Are you saying that the sun 25 didn't come up if it was cloudy?
I am trying s-
+aw a.
-..-:.-i
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-- +-
e.v g,.p ee-
---.-,.**y
=-
i 1
Dominguez 101 s
2 to probe what this witness means by "no."
I 3
think you have totally distorted what that 4
means here.
(
5 MR. GLASSMAN:
I am not distorting anything.
6 I think the witness has told you what the state 7
of his knowledge is in this regard.
8 Can you ask him another question.
9 BY MS. MCDONALD:
10 Q
Mr. Dominguez, do you know(today that 11 voiding in the primary system of a pressurized water 12 reactor can cause the pressurizer level to rise?
O' 13 A
Let me put it to you this way:
I cannot 14 prove it, therefore I don't know it.
Aside from 15 anything you feel counsel may have done to me this 16 is something which I determined, you know, that's i
17 sort of the way I do business.
18 You must also recall that I haven't 19 even looked or thought of a pressurizer outside of 20 what I read in the papers since I left Metropolitan 21 Edison.
It's a subject distant from my mind for 22 almost three years.
23 Do I know it, no, I don't know it.
Does O) 24 it occur, I would say if there is documented evidence that
(,
25 says it does, I would say yes it would; I would draw
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1 Dominguez 102 f^h b
2 that conclusion, I would work.with it and I would in 3
fact believe it.
I don't feel I can sit here and 4
assemble facts to convince myself but perhaps I could
.(
' convince other people that it was true.
5 6
Q Ans when you read, according to your 7
Practice, Mr. Ulrich's entry in the shift test 8
engineers log saying the pressurizer level came down 9
proving that there was a steam bubble in each of the 10 hot legs, did you disbelieve that?
e 11 MR. GLASSMAN:
I just object.
The 12 witness said that he didn't recall actually
[h
\\/
13 reading that.
14 MS. MCDONALD:
He said it was his 15 practice to review the log entries,Mr. Glassman.
16 MR. GLASSMAN:
We agree on that, and he 17 said that several times, counsel, but there is 18 a difference between a practice and an actual 19 recollection of a particular entry.' He told 20 you he didn't recall reading that particular 21 entry.
L 22 Q
Did you ever recall reviewing any shift 23 test engineers log entry and thinking that what was I) 24 written there was impossible?
'w/
25 A
You are treading on the philosophical
,,._..-,.r-m_,
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_,-_..~__%
1 Dominguez 103 O
2 regions of the question.
3 Q
can you answer it?
4 A
I don't recall ever reading anything in
(
5 the shift test engineers log and thinking that it was 6
improbable.
7 Q
And when, and I know you don't recall 8
reading it specifically, and when according to your 9
practice, anyway, you reviewed Mr. Ulrich's entry 10 for March 29, 1978 which reads, "The pressurizer 11 level was increased to approximately 200 inches, RCS 12 pressure decreased to approximately 1200 psig before 13 recovery started."
14 Did that remind you of the entry that you 15 had made in September of 1977 where you wrote 16 pressurizer level unexpectably increased when venting 17 pressurizer and decreased pressure fr,om 500 psig to 18 460 psig pressurizer level, pressurizer level
^
19 increased approximately 150 inches during this 20 evolution.
21 MR. GLASSMAN:
The witness said he L
22 doesn't recall reading any of these particular 23 entries, it's impossible to say when reading 24 one brought back another.
25 He told you he doesn't recall reading
1 Dominguez 104
[ >b w
2 them, counsel.
I object.
3 Q
You don't recall thinking that there was 4
any similarity between the events of March 28, 1978 g{
5 and the events of September 8,
1977, you don't recall 6
thinking that?
7 A
I don't recall.
8 Q
When you heard about the Three Mile Island 9
accident,did that bring to your mind any events that 10 had occurred while you were at Three Mile Island?
11 A
No, it did not.
12 MS. MCDONALD:
Off the record.
i L/
13 (Discussion off the record.)
14 MS. MCDONALD:
We have copied certain 15 portions of the documents which Mr. Dominguez 16 produced, and I will represent that what I am 17 about to mark came from what he produced.
18 The first document I would 1[ke to mark is 19 a document entitled "Pressuriser Lecture 20 Outline Prepared By:
T.
Hawkins."
21 I would like to have that marked as B&W k.
22 Exhibit 91 0.
23 (Document consisting of a " Pressurizer p
F I
24 Lecture Outline Prepared By:
T.
Hawkins," was
\\_/
25 marked B&W Exhibit 910 for identification.)
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1 Dominguez 205
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iV) 2 Q
Can you tell me what that document is, 3
Mr. Dominguez?
4 A
That is a copy of the Lecture Outline
((
5 that Tom Hawkins used to instruct us about the 6
pressurir.er.
7 Q
Do you see your handwriting, little hotes, 8
anywhere on this document?
9 A
Yes.
10 Q
Are all the notes in the dargin and 11 otherwise your writing?
12 A
They should be.
/ "h 13 Q
Do you see anything that's not your 14 handwriting?
15 Just flip through it.
16 A
The notes on the letter " REM-II-7," the 17 signature of that, the handwriting on the three 18 pages following the letter.
That should be it.
l 19 Q
Is that a document that you maintained 20 while you were an employee of Metropolitan Edison?
21 A
This was a document in my possession
,k 22 while I was an employee with Metropolitan Edison, yes.
23 Q
And it was part of your training, is
()
24 that right?
25 A
Yes.
1 Dominguez 106
\\-).
2 Q
Is that true of all of the documents you 3
produced?
4 A
Yes.
((
5 MS. MCDONALD:
I would like to mark as 6
B&W Exhibit 911, a document produced by 7
Mr. Dominguez entitled " Decay Heat Removal 8
System Lecture Outline Prepared By:
S.G.
Poje."
9 (Document entitled
" Decay Heat Removal 10 System Lecture Outline-Prepared by:
S.G.
Poje,"
11 was marked B&W Exhibit 911 for identification.)
12 Q
On the second page of this document, is D
13 that your handwriting?
14 A
Yes.
15 Q
was this also a lecture outline prepared 16 for your training?
l l
17 A
Yes.
18 MS. MCDONALD:
I would like to mark as 19 B&W 912, a document entitled " Engineered l
20 Safety Features STE Briefing Notes Prepared By:
l 21 M.J.
Perry."
L 22 CDocument entitled " Engineered Safety l
(
23 Features STE Briefing Notes Prepared By:
l s
(,)
24 M.J.
Perry," was marked B&W Exhibit 912 for 1
25 identification.)
1 Dominguez 107 (J
~
s 2
Q As you go through that, Mr. Dominguez, 3
would you note if you see something that's not your 4
handwriting?
(
5 A
Yes.
Page 9 is not mine, page 10, page 11, 6
page 18, the questions on The ESAF Quiz are not mine, 7
the answers are.
O Q
Referring to that ESAF Quiz, do you see 9
comments on occasion under your answer appear to be 10 written in felt tip pen?
11 A
correct, those are not mine either.
Other 12 i
than the noted exceptions the handwrit ng the notes O/
13 on these lectures are mine.
14 Q
And again this was a document you 15 maintained as part of your training, is that right?.
16 A
Yes, I had it, correct.
17 MS. MCDONALD:
The next exhibit, B&W 913, a document called " Transient Analysis 19 Lecture Outline Prepared By:
M.A.
Nelson." -
20 (Document called " Transient Analysis 21 Lecture Outline Prepared 3y:
M.A.
Nelson,"
22 was marked B&W Exhibit 913 for identification.)
23 g
Again, could you please note the things O'j 24 that are not in your handwriting?
(
25 A
The handwriting on the letter entitled
1 Dominguez 208 2
TMI-2 Reactor Building Spray System. Figure 1,
the 3
drawing following figure 1; the felt tip writing on 4
figure 1-1; the printing on figure 2-1.
The printing
((
5 on figure 2-2; 2-3, 2-4, the two graphs following 6
figure 2-4.
Figure 2-7; other than the noted 7
exceptions the written notes are mine.
8 Q
Do you recall this lecture by Mr. Nelson?
9 A
I do not recall this particular lecture.
10 Q
Again, this is a lecture obtline that you 11 had as part of your training at Metropolitan Edison?
12 A
That's correct.
O>
>N' 13 Q
Do you recall why you were being taught 14 something about transient analysis?
15 A
It was required.
16 Q
By what?
17 A
By Mr. Toole.
18 Q
Should all the shift test engineers that 19 you knew of have had this similar training?
20 A
Yes.
21 Q
Was this training at which only shift 22 test engineers were present or other employees of 23 Metropolitan Edison and GPU present?
()
24 A
The training always had the four STE's 25 present.
There were on occasion seven other people s
7 1
Dominguez 109 2
that could have been present depending upon the nature of the subject.
3 4
Q There were seven other people, is that what 5
you said or several?
I didn't hear you.
({
6 A
seven, I said.
7 Q
Who were the seven?
8 A
Typically the startup test engineers were there, an example being Poje or Gatto.
I believe there 9
10 were four, Mr. Toole and Mr. Hawkins were' generally 11 present.
Depending upon the topic you would have a 12 special' lecture such as Lentz or Max Nelson.
(~)
\\-
13 Q
Do you recall what Max Nelson's position 14 was at Met Ed or GPU?
15 A
I don't recall what his title was.
16 Q
Do you know which organization he was 17 employed by?
18 A
GPU.
19 Q
Have you ever had any training from B&G?
i 20 A
Yes.
21 Q
What training was that?
22 A
On two occasions I attended their 23 simulator.
()
24 Q
When.were those occasions?
25 A
The first occasion was when I was an
1 Dominguez 110 OV 2
engineer level 1 with Met Ed.
3 The second occasion was following the 4
lecture series that we are discussing.
(
5 Q
And how long a period of time were you 6
down at Lynchb
.n each of those occasions, 7
approximately?
8 A
One to two weeks.
9 MS. MCDONALD:
I would like to mark as 10 as B&W 914, another document produced by 11 Mr. Dominguez entitled "TMI Unit 2 EP 2202-1.5 12 Pressurizer System Failure."
A 5
\\'-
13 (D ocume nt entitled "TMI Unit 2 EP 2202-1.5 14 Pressurizer System Failure," was marked B&W 15 Exhibit 914 for identification.)
16 Q
Mr. Dominguez, c an you tell me what this 17 document is?
18 MR. GLASSMAN:
Is this copied'by counsel 19 from part of the same materiale?
20 MS. MCDONALD:
Yes.
21 A
I don't recognize the documents.
L 22 Q
Mr. Dominguez,.let me show you the 23 original of that document in the notebook that you
(
24 produced.
Maybe it will help you.
This notebook 25 bears the file number 2857-3-1.
1 Dominguez 111 gO RJ 2
MS. MCDONALD:
Mr. Glassman, I take it 3
that was something put on by Kaye, Scholer, _i s 4
that correct?
{
5 MR. GLASSMAN:
I believe that was put on 9
by counsel for identification purposes, and 7
Perhaps so we are clear on it, it has a note on 8
the binding "SIU Training /A.J. Dominguez Books,"
9 then the first page of which has a mailing label 10 with Mr. Dominguez' home addrer.s on it and the 11 substantive page on it is a memorandum on GPU 12 Service Corporation stationery bearing the 13 heading " Training Schedule Update June 11, 1976."
14 And we are at this point looking at the 15 section which has the mark on it DG no, a 16 section which has a little marker in handwriting 17 that says " Emergency Procedure," or "?rocedures."
18 It's Proc., which is the fourth of'a number of 19 tabs which have been inserted on th'ese pages 20 about a third of the way through the book.
21 BY MS. MCDONALD:
22 Q
Mr. Dominguez, did you put these tabs on 23 this book?
(
24 A
Yes, I did.
25 Q
could you take a look at the cection which
r 1
1 Dominguez 112
(%d 2
is tabbed " Emergency Procedures," and I would just like to ask you if that refreshes your recollection as 3
4 to whether you had any training on emergency or 5
operating procedures while employed at Metropolitan
({
6 Edison?
7 A
No, it does not refresh my memory.
8 Q
The last page of B&W Exhibit 914, is that g
your handwriting?
10 A
Yes.
11 Q
On the front of B&W Exhibit 914 12 MR. GLASSMAN:
So I am clear on this:
We 13 have B&W 914, it's not stapled and the material 14 that's been pulled out as part of 914 contains a 15 number of typed pages starting at page 1.0 going.
1 16 through 11.0 and a separate page at the end that l
17 in handwriting says "compatability of material,"
18 and " corrosion minimize."
19 Q
Mr.,Dominguez, do you see in the original 20 of B&W 914 that the handwriting is in fact on the i
I 21 back of the last page of B&W 914?
I k.
l 22 It was just copied on a separate page l
l 23 when we copied it.
l l
24 A
Yes.
x) 25 Q
Can you tell me whether the handwriting
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1 Dominguez 113
/^N V) t 2
that Mr. Glassman just read in fact relates to the 3
next document in the original exhibit labeled 4
" Primary and Secondary Chemistry Plant Chemistry
(
5 Lecture Outline"?
6 A
I can draw a conclusion, but I couldn't 7
really say for sure.
8 Q
I take it seeing none of these documents 9
refreshes your recollection that you at any time c
10 reviewed the pressurizer. system.failurd, procedure 11 which is in yo book here?
12 A
No.
13 Q
Do you see on the front of that procedure 14 some handwriting, the first page?
15 A
Yes.
16 Q
Is any of it yours?
17 A
No.
IO Q
Do you see that somebody has ritten 19 there "PORC 12/11"?
20 n
Yes.
21 Q
Do you know what the PORC is?
22 A
Yes.
23 Q
What was that?
' {~h
(,)
24 A
It is the Plant Operation Review Committee.
25 Q
What was that committee for?
7_..
1 Dominguez 114 V(
2 Do you recall?
3 A
My recollection of the PORO was that it 4
was to review procedures in light of safety related
(
5 issues.
6 Q
Do you see the name " Miller" at the top 7
of B&W Exhibit 9147 8
g y,,,
9 Q
Is that Gary Miller to the best of your 10 knowledge?
(
11 A
Yes.
12 Q
Can you give me any explanation for why C) 13 this procedure appears in your book?
14 MR. GLASSMAN:
Are you asking him to 15 guess?
16 A
May I have the book back, please?
17 -
MR. GLASSMAN:
Are you asking.him to 18 l
review the book and see if that can give him 19 i
any indications 20 MS. MCDONALD:
Yes.
21 A
I can offer conjecture.
22 MR. GLASSMAN:
We are not here for that.
23 The question is whether reviewing the book --
t 24 let the record reflect that the witness has 25 attempted to review the entire book or at least
Y 1
Dominguez 115 t'~)
~
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apparently some beginning portions of it as well 3
as the portions that counsel referred to.
The 4
question is does reviewing this refresh your 5
recollection as to why emergency procedures,
(
6 in particular were included in a particular 7
section of this book?
8 THE WITNESS:
I am not sure why those 9
particular procedures were included in that 10 section.
11-MS. MCDONALD:
I would like to mark as 12 B&W 915, the beginning pages of the book that
('
13 we have been referring to.
14 Let me just ask you to identify what is 15 going to be marked as B&W 915 is, in fact, pages 16 from the notebook that you produced?
i 17 THE WITNESS:
Yes, they are.
- l 18 MS. MCDONALD:
I would like' t'o mark as l
19 B&W 916 the first page of the emergency l
20 procedures section, again, from Mr. Dominguez' 21 book, is that correct, Mr. Dominguez?
i
(
l 22 THE WITNESS:
Yes, that is correct.
23 (Document entitled " Training Schedule
)
24 Update June 11, 1976, was marked B&W 915 l
25 for' identification.)
I
T i
1 Dominguez 116
/~%
U 2
(Two-p ag e document entitled:
3
" Emergency and Abnormal Procedures," was.
4 marked B&W Exhibit 916 for identification.)
(-
5 BY MS. MCDONALD:
6 Q
I would like to ask you whether B&W 916 7
has your handwriting anywhere on it?
8 A
Yes, it does.
9 Q
Do you see opposite where it's written 10
" Pressurizer System Failure," that your.have written 11 something?
12 A
Yes.
13 Q
Does it say " Thermocouple High Temp, 14 Increase Pressure, Temp, Level in Reactor Coolant 15 Drain Tank"?
16 A
Yes.
17 Q
Is that your handwriting?
18 A
Yes, it is.
19 Q
Does seeing that there refresh' your 20 recollection as to whether you ever reviewed the 21 Pressure system failure procedure?
22 A
Quite truthfully, no.
23 MS. MCDONALD: I have no further questions.
f) 24 EXAMINATION BY MR. GLASSMAN:
25 Q
Mr. Dominguez, I believe at the beginning
r1 1
Dominguez 117 O
2 of your testimony today, you testified that when you 3
were in the. Navy that you had never 'actually seen solid 4
operations, is that correct?
5 A
That is correct.
(
6 Q
Do you recall being told or instructed 7
in the Navy whether or not it was appropriate to 8
operate in a solid condition?
9 A
Yes.
10 MS. MCDONALD:
Object to the form.
11 A
Yes, and we were instructed not to operate 12 in a solid condition.
O 13 Q
Were you inst'ructed as to any situation 14 where it would be appropriate to operate in a solid 15 condition?
16 A
No.
furt,her questions.
17 MR. GLASSMAN:
I have no 18 EXAMINATION BY MS. MCDONALD:
19 Q
Your training that you just described or 20 in the Navy uere you told why it.was considered 21 inappropriate to operate in a solid condition?
L 22 A
I cannot recall any specific reason why, 23 but to the best of my knowledge it's because it is 24 unsafe.
25 Q
Is that because to the best of your
f 1
Dominguez 118 t'
\\
2 recollection, is that because operating in a solid 3
condition can result in very rapid pressure increases?
4 A
To the best of my knowledge, yes.
C' 5
Q Based on your training in the Navy was it 6
your understanding that solid condition meant all of 7
the reactor coolant system full of water including 8
the pressurizer?
9 A
Yes.
10 t
MS. MCDONALD:
I have no further questions.
11 LTime noted:
1:25 p.m.)
12
-oCo-13 l
l 14 ANDRE J.
DOMINGUEZ 15 l
Subscribed and sworn to l
[
16 before me 17 this day of
,1982.
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8/17/82 120 I
N D
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WITNESS:-
PAGE ANDRE J.
DOMINGUEZ 3
1 E
X H
I B
I T
S 4(- 6
-s.
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B&W IDENTIFICATION 908 One-page resume of Andre Jg 4
Dominguez.
909 One-page handwritten document 29
(~T 910 Document consisting of a 104
'N /
" Pressurizer Lecture Outline,
Prepared By:
T.
Hawkins. "-
911 Document entitled " Decay Heat 106 Removal System Lecture Outline Prepared By:
S.G.
Poje."
912 Document entitled " Engineered 106 Safety Features STE Briefing Notes Prepared By:
M.J.
Perry."
913 Document called " Transient 107 Analysis Lecture Outline Prepared By:
M.A.
Nelson."
914 Document"TMI Unit 2 EP 1101-1.5 110 Pressurizer System Failure."
915 Document entitled " Training 115 Schedule Update June 11, 1976.
916 Two-page document entitled, 116
( }
" Emergency and Abnormal Procedures."
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_C _E _R _T _I _F _I _C _A _T _E l
3 STATE OF NEW YORK
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4 COUNTY OF NEW YORK )
1 m
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I, NANCY A.
RUDoLPE a
7 Notary Public within and for the State of New York, 8
do hereby certify that the foregoing deposition l
9 of ANDRE J.
DoMINGUEZ was taken before 10 me on Tuesday, August 17, 1982 j
11 That the said witness was duly sworn 12
- before the conmencement of his testimony and 13
~
that the within transcript is a true record of said
}
14 testimony; 15 That I am not connected by bloed or 16 marriaSe with any of the parties herein nor 17 interested directly or indirectly in the matter in 18 controversy, nor am I in the empicy of any of the 19 counsel.
20 IN WITNESS WHEREOF, I have hereunto set CA.
i 21 my hand this 5 7 day of N< ~,uX./9F2 (f
22 23 G. !
-a en NAN A.
RUDoLPH 25
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8/17/82
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4 WITUE S S :-
PAGE C. {..
3 ANDRE J.
DOMINGUEZ
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.' IDENTIFICATION
" s, 908 One-page resume of Andre Jg 4
j Dominguez.
l 4
<4
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,One-page handwr tten document
'29 909 4
i 910-Document consisting {of a
104 s
< " Pressurizer Lecture' Outline,
Prepared By:
T.
Hawkins."*
911 Document entitled " Decay Heat 106 Removal Systen Lecture Outlina Prepared By:
S.G.
Poj e. "'
j912 Document antitled'" Engineered 106 Safety Features STE Briefing
~
/
Notes Prepared Dy M.J.
Perry."
i 913 Document called " Transient 107 Analyo'is Lecture Outline Prepdred By:
M.A.
Nelson."
914 Document"TMI Unit 2 FP 1101-1.5 110 Pres suriz e :: System Failure."
915 Document. entitled'" Training 115 Schedulo. Update, June 11, 1976.
916 Two-page documont entitled, 116
-w
" Emergency and Abnormal. Procedures."
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UNITED STATES DISTRICT COURT C/
SOUTHERN DISTRICT OF NEW YORK
___________________________________________x GENERAL PUBLIC UTILITIES CORPORATION, JERSEY CENTRAL POWER & LIGHT COMPANY,
(,,
METROPOLITAN EDISON COMPANY and 80 Civ. 1683 (RO)
PENNSYLVANIA ELECTRIC COMPANY AFFIDAVIT Plaintiffs,
- against -
THE BADCOCK & WILCOX COMPANY and J.
RAY McDERMOTT & CO.,
INC.
Defendants.
e
,___________________________________________x iSTATE OF PENNSYLVANIA
)
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- ss.:
kJ l COUNTY OF / u 2. ex.N J'
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nr I have read the transcript of my deposition taken on il; August 17, 1982 and together with the attached corrections, it k
l
.is accurate to the best of my knowledge and belief.
E
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WJtL4 Ax 7.<fom/nguez i! Signed and sworn to before me g thisJ6 day of October, 1982.
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f Corrections to A.J. Dominguez Deposition Transcript
()
September, 1982 Page Line Correction 8
18 "machinest" should read " machinist" 8
23 "machinest" should read " machinist"
,s
)**
8 24 "on a nuclear plant trained,"
should read "on the nuclear plant,"
8 25 "machinest" should read
" machinist" 9
5
" Greenland" should read "Greenling" 22 6
"recirulate" should read "recirculat.
25 2
" level in a band to operate between" should read " level band to operate 1:
32 6
"they're" should read "they're an" 35 18
" documented or reviews what" should
()
read " documented reviews that" 42 11 "They use" should read "I used" 54 5
"particular conversation" should rea "particular log entry" 58 8
" indicated" should read " indicating" 75 8
" lever" should read " level" 86 15 "Dominguez" should read "Dominguez" 89 24 "us" should read "it" 102 6
"Ans" should read "And" 109 19 "B&G" should read "B&W" k.
O