ML20072J126
| ML20072J126 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 03/12/1981 |
| From: | Dunn B BABCOCK & WILCOX CO. |
| To: | |
| References | |
| TASK-*, TASK-01, TASK-02, TASK-1, TASK-2, TASK-GB NUDOCS 8306290943 | |
| Download: ML20072J126 (130) | |
Text
,
bt UNITED STATES DISTRICT COURT 134 SOUTHERN DISTRICT OF NEW YORK iu
_ _ _ _ _x{ } } \\ A GENERAL PUBLIC UTILITIES CORPORATkON, JERSEY CENTRAL POWER & LIGHT COMPANY, METROPOLITAN EDISON COMPANY and PENNSYLVANIA ELECTRIC COMPANY, Plaintiffs,
-against-THE BABCOCK & WILCOX COMPANY and J.
RAY McDERMOTT & CO.,
INC.,
Defendants.
_x Continued deposition of The Babcock &
Wilcox Company, by BERT MERRIT DUNN, taken by t
Plaintiffs, pursuant to adjournment, at the offices of Kaye, Scholer, Fiernan, Hays &
Handler, Esqs., 425 Park' Avenue, New York, New York, on Thursday, March 12,,1981, at 9:40 o' clock in the forenoon, ba[ ore Cgarles Shapiro, a Certified Shorthand Reporter and Notary Public within and for the Etate of New York.
..\\l DOYLE REPORTING. I N C.
C ERT!FIE: STENOTYPE. R EPC RTERS 369 LzxiNcTo N AvtNur 8306290943 810312 sc, yew, y,y, tooi7 PDRADOCK05000g I
Trt.zP4C N C 2II " $67 8220 m..
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__= _-
6 1
135 C
~
2 Appe arance s:
3 KAYE, SCHOLER, FIERMAN, HAYS & HANDLER,'ESQS.
Attorneys for Plaintiffs l
4 425 Park Avenue New York, New York By:
RICHARD C.
SELTZER, ESQ.,
6 ANDREW MacDONALD, ESQ.,
MARK MOLTEK, ESQ.,
7
-and-ROCHELL HANSON, ESQ.,
(PM SESSION) 8 of Counsel 9
l
-and-10 11 BERLACK, ISRAELS & LIBERMAN, ESQS.
26 Broadway 12 New York, New York 13 By:
JESSE M.
MEER, ESQ.,
=
14 of Counsel 15 I
16 DAVIS, POLK & WARDWELL, ESQS.
Attorneys for Defendants I
17 One Chase Manhattan Plaza '-
18 By:
ROBERT B.
FISKE, ESQ.,
19
-and-RODMAN W.
BENEDICT, ESQ.,
20 of Counsel 91 l
L 22 Also Present:
23 DAVID TAYL R ROBERT KEATEN 24 PATRICIA VAUGHAN 25 l _
.,, _ _ _.. _ _. _ _ ' 2, _.I _...
I 136 i
- resumed, 3
having been previously duly sworn by the 4
Notary Public, was examined and testified
(
5 further as follows:
6 EXAMINATION (Continued) 7 BY MR. SELTZER:
8 Q
Mr. Dunn, I am sure you are aware 9
that your testimony today continues to be under 10 oath, do you not?
t 11 A
I am.
4 12 Q
You testified yesterday that shortly O(_)
13
_ after the Davis-Besse September 24, 1977 transient I
14 you had a conversation lasting about 15 minutes 15 with Don Roy in his office.
16 Do you recall that?
17 A'
I recall that I testified to that er. tent 18 yesterday.
19 Q
Prior to your writing your memoranda 20 in February 1978, did you have any subsequent 21 conversations with Dr. Roy regarding premature 22 termination of high-pressure injection?
23 A
I don't believe so.
~N{d 24 Q
,You had testified yesterday that at 25 some point in your meeting with Roy shortly
. [_ _; n
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l '
1 Dunn 137 2
after the Davis-Besse incident, you related your i:
3 concern and he said something to the effect f
4 of "Go take care of it, do something about 13."
5 Did you ever report back to him on 6
anything that you were doing to work out your 9
7 concern?
I 8
A Not that I recall.
9 Q
After you sent the February memoranda 10 to Jim Taylor and prior to the Three$ Mile Island 11 accident, did you have any conversations with Don 12 Roy about your concern and about the subject of 13 termination of high-pressura injection?
14 A
Not that I recall.
I 15 Q
Where are the monthly staff meetings 16 of the Design Section held?
17 A
Some are in the Old Forrest Road
- office l
18 building.
19 Q
Is - there any place where Don Roy 20 generally held those meetings when he was the
()
21 head of the Design Section?
22 A
I don't know whether Don had a preference 23 for any particular location or not.
24 Q
Where did he tend to hold the meetings?
i 25 A
I don't recall whether it was a tendency
- (-
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~
L.
Dunn 138 2
of one location over another.
3 Q
Just can you give me the plurality of 4
places where Don Roy convened the Plant Design
(
5 Section staff meetings?
6 A
Yes.
7 Q
where?
8 A
There are six conference rooms, three 9
training rooms, and three or four classrooms within 10 the Old Forrest Road office building".,
11 These staff meetings would have been 12 held in one of those rooms on an as-avilable basis.
f~
13 Q
Has Allen Womack, when he took over the
~.
14 Plant Design Section, continued the practice 15 of having monthly staff meetings?
I used the 16 wrong verb.
17 I know he is currently not.the head 18 of the Plant Design Section.
Did Allen Womack
~
19 continue the practice of having monthly staff 20 meetings when he took over from Don Roy as 21 Manager of the Plant Design Section?
22 A
In approximation.
23 Q
In approximation, yes?
[)
24 A
Yes.
In approximation, yes.
V l
25 Q
Was there a day each month when those
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1 Dunn 139 2
meetings were generally held under Dr. Roy?
s 3
A No.
4 Q
It wasn't the first Tuesday of each month, 5
something like that?
P 6
A No.
7 Q
How long did the meetings generally 1
f 8
last?
9 A
Between one to two hours.
10 Q
Did anybody prepare note's or minutes 11 of the meetings?
12 A
No.
13 Q
You seemed tq take a while in responding.
14 Were people taking notes at the meetings?
15 MR. FISKE:
I don't think Mr. Dunn took 16 any longer to answer that question than he has 17 taken to answer any other, but go ahead, 18 Mr. Dunn.
19 A
Yes.
20 Q
on either an occasional or regular basis,
(
21 were anybody's notes of the meetings circulated 22 after the meeting?
23 A
I can't recall any.
24 Q
Whom do you recall generally taking 25 notes at the Plant Design Section meetings?
1 Dunn 140
/~r 2
A All of the staff.
3 Q
Including you?
4 A
Yes.
5 Q
Have you kept your notes?
6 A
Some of them.
7 Q
Where?
8 A
I would expect it to be many locations.
9 Q
Do you keep them in a file that would 10 be labeled in any way that would ind{cate that 11 they contain notes of meetings such as this?
12 A
No.
(_/
13 Q
What kind,s of file designations do you 14 believe you have given to the files in which you 15 keep those notes?
16 A
I didn't say I kept them in a file.
17 Q
Where did you keep them?
18 A
In many locations.
19 Q
You said that a while ago.
20 What are the locations?
.(
21 A
They could be in desk drawers, in a log book 22 or just stacked up on my desk.
23 Q
Do you generally have a log book 24 in which you are making current entries?
25 A
Not generally.
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Dunn 141 0
2 Q
Could you describe the log book in 3
which you believe you would have taken notes at 4
Plant Design Section meetings?
5 A
It's a permanently bound book with an 6
imitation leather cover, I believe the paper in it 7
is eight and a half by 11, about three-quarters 8
of an inch thick.
9 Q
Is it a looseleaf binder?
E 10 A
No.
11 Q
How many of those log books have you 12 maintained in the five' years you have been s
13 Unit Manager?
14 A
I maintained one book for some period-of 15 time. Maintenance is probably the wrong word.
16 I used it from time to time.
17 Q
Was that log book turned over to l
18 anybody in connection with the obligation to l
19 produce documents in this lawsuit?
20 A
Yes.
I
(
21 Q
Did you search all of your desk drawers 22 for material which would be responsive to requests 23 for production in this lawsuit?
b
's_/
24 A
Yes.
25 Q
Do you know whether you turned over l
~
1 Dunn 142
/~'s 1 V 2
for possible production in this lawsuit notes 3
of meetings of the Design Section staff?
4 A
Yes.
5 Q
Yes, you did?
6 A
Yes, I did.
7 Q
At any of the Design Section staff 8
meetings which were held on a regular basis each 9
month or any other Design Section meeting, 10 a meeting of members of the Design S*ection, was 11 the subject of termination of high-pressure 12 injection ever discussed before the Three Mile f.
13 Island accident?
14 A
Your question was at any of the Plant 15 Design staff meetings or any other meetings involving i
16 Plant Design personnel, was the subject of 2
17 termination of high-pressure inj ection -dis cus s ed 18 prior to the accident at Three Mile Island, is that 19 correct?
20 Q
Yes.
(
21 A
Yes.
22 Q
At what meetings was it discussed?
23 A
The meetings I testified to yesterday.
24 Q
Those were generally one-on-one 25 meetings that you had with separate individuals, p
- ese 6=
h
1 Dunn 143 3
2 right?
p 3
A Thao is correct.
4 Q
At a meeting that was more generally 5
attended by a larger group of people from the 6
Plant Design Section, was the subject of 7
termination of high-pressure injection ever 8
discussed?
9 A
Not that I recall.
10 MR. SELTZER:
I would like to mark 11 for identification as GPU Exhibit 76 a 12 memorandum from J.
J.
Kelly to Messrs.
/~%
13 Karrasch, Swanson, Finnin,.Dunn, LaBelle, 14 Elliott, and Hallman, dated Lavember 1,
- 1977, 15 subject:
" Customer Guidance on High-Pressure 16 Injection operation."
l 17 (Memorandum from J.
J.
Kelly to 18 Messrs. Karrasch, Swanson, Finnid, Dunn, 19 LaBelle, Elliott, and Hallman, dated 20 November 1,
1977, subject:
" Customer (i
21 Guidance on High-Pressure Injection Operation" 22 marked GPU Exhibit No. 76 for identification 23 as of this date.)
24 Q
Is GPU Exhibit 76 a copy of a memorandum 25 which you received in the regular course of
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1 1
Dunn 144 2
business in or about early November of 19777 s
3 A
I dbn't know.
4 Q
Did you receive a copy of this Cl 5
memorandum at any time before you wrote your i
6 February 1978 memoranda?
i 7
A I don't know.
)
8 Q
When is the first time you recall 9
seeing a copy of GPU Exhibit 767 i
5 10 A
I guess I don't recall the first time I saw i
11 a copy of this.
12 Q
Do you believe that you saw a copy 13 of this before your President's Commission 14 deposition?
15 A
Ye8-16 Q
Do you believe you saw a copy of this 17 before the Three Mile Island accident? -
18 A
Yes.
i 19 Q
Do you have any way that you could 20 approximately fix a time span, however broad,
()
21 in which you believe you first received a copy l
22 of GPU Exhibit 767 23 A
I believe I saw the copy -- a copy of this 24 at approximately November 1st, 1977.
25 Q
Just so that I can avoid three to l
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1 Dunn 145 p\\
1V.
2 five minutes of questioning the next time I 3
introduce a document, can you tell'de why, when I 4
first asked you did you receive a copy of this
(
5 in or about early 1977, you said no?
6 MR. FISKE:
He didn't say no.
7 MR. SELTZER:
He said he didn't recall.
O Q
Is that what you told me?
9 MR. FISKE:
He said, "I~ don't know,"
10 I believe was his answer.
t^
11 Mr. Seltzer wants to know why you gave i
12 that answer.
OO
~
between the work "know,"
13 A
The difference I
14 received it today -- "know" being very explicit,
'15 very definite knowledge that I received it -- and 16 a less definite impression or knowledge to 17 the -- what was the word we were using yesterday?
18 g
3,11 f, 19 A
-- belief is one word that might be 20 appropriate -- when you use the word "know," I 21 am trying to distinguish something that I actually 22 could testify to as a very positive item.
23 Q
If I had used the words "Do you believe
()
24 you received a copy of GPU Exhibit 76 in or about 25 early November 1977," would you have responded yes?
n-.-,
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I-1 Dunn 146 t
i 2
A Yes.
3 Q
Had Joe Kelly discussed with you, prior 4
to November 1, 1977, the fact that he was preparing a memorandum such as GPU Exhibit 767 5
i 6
A I believe so.
7 Q
What, as best you can recall, did he 8
say to you and you say to him in words or substance?
9 A
In substance I believe Joe indicated to 10 me that there had been a follow-on event, a second 11 incident involving possible inappropriate. termination 12 of high-pressure injection and that e was going (1s) 13 to issue a--memo on the subject.
14 In substance, I responded with " Good."
15 Q
In other words, you encouraged him to 16 send out a memorandum such as GPU Exhibit 767 17 A
Yes.
t 18 Q
Did he discuss with you, as best you 19 can recall, the individuals to whom he would 20 distribute such a memorandum?
21 A
Not that I recall.
l
(
22 Q
We have discussed and you have told 23 me who several of the individuals are in the 24 distribution list.
25 Who is R.
J.
Finnin?
I 4
1 Dunn 147 m
%.J.
2 A
I believe that to be Mr. Ron Finnin.
3 Q
Do you know in what unit he worked, and 4
what type of work he was doing in the fall of 19777 5
A Not exactly.
6 Q
Would it refresh your recollection if 7
I showed you an organization chart for the 8
Nuclear Service Department that has his name on 9
it?
(Handing document to the witness)?
10 A
I believe at that time Mr. Finnin was a 11 member of Nuclear Service.
12 Q
Was he in the unit that reported to 13 Don Hallman (indicating) a member of the Plant 14 Performance Unit?
15 A
According to this chart with which I am not l
16 familiar, he is indicated that way.
17 MR. FISKE:
Do you want to. mark that 18 since he referred to it?
19 Q
Are you familiar with this as being 20 typical of the format of the organization charts l
21 within B&W7 k'
32 A
Yes.
23 MR. FISKE:
We won't insist on a 34 foundation; just to mark it.
25 MR. SELTZER:
No, I am not.
I am just
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1 Dunn 148 lT
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2 trying to understand.
I am not going to 3
offer it in evidence yet.
We can mark 4
anything for identification.
5 Q
Finnin is listed as being in charge 6
of start-up testing in the Plant Performance 7
Services Unit.
8 Do you know what start-up testing 9
is responsible for?
10 A
No.
t 11 Q
Have you ever had any dealings with 12 Mr. Finnin?
(
13 A
Yes.
14 Q
In what connection?
15 A
In a private connection.
16 Q
You mean it had nothing to do with the 17 business of B&W7 18 A
our first my first connection with 19 Mr. Finnin had nothing to do with the business at 20 B&W.
21 Follow-on or later connections, it
(
22 involved work from time to time and at this time 23 I don't recall the nature of those connections.
()
24 Q
Did Kelly ever tell you, or do you have 25 any other understanding as to why Kelly sent GPU gp e
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1 Dunn 149 s
A.
2 Exhibit 76 to Mr. Finnin?
3 A
I doh't believe Joe ever told me that.
4 Q
Do you have any understanding why he 5
sent it to him?
6 A
Not other than Ron is a member of 7
Customer Service.
8 Q
Is Customer Service the name 9
b that is now given to the department that used I
10 to be Nuclear Service?
11 A
I am not sure of that.
I refer to both 12 of them as the same.
w
\\_))
(
13 Q
So that when you use "Cu,stomer 14 Service," it means the same thing as Nuclear 15 Service?
16 A
To me, yes.
17 Q
D.
W.
LaBelle, the Manager of the 18 Safety Analysis Unit, received a copy of GPU Exhibit 19 76.
i 20 Are you familiar with Mr. LaBelle?
(
21 A
I know Mr. LaBelle.
22 Q
Is he a Unit Manager in the same 23 section that you are a Unit Manager?
24 A
At that time he was.
25 Q
What is he today?
1 Dunn 150
(\\
O 2
A He is a member of an organization within 3
B&W dealin'g with advanced energy concepts, either 4
as a Unit Manager or a Supervisory Engineer.
\\
5 Q
Is there still a unit within B&W 6
known as safety Analysis?
7 A
Yes.
8 Q
Who is the Manager of that now?
9 A
Mr. Barkley Andrews.
10 Q
Prior to the Three Mile 1,sland 11 accident, did you ever have any conversation with 12 LaBelle on the subject of termination of g
13 high-p re s s u r"e injection?
14 A
I am not sure.
I don't believe so.
15 Q
Would LaBe11e's unit have any 16 responsibilities that would touch on the operation 17 of high-pressure injection?
18 A
Not generally.
l 19 Q
During the years that you have been 20 the Manager of ECCS, has Safety Analysis ever
(
21 done anything that touched on high-pressure 22 injection?
23 A
Yes.
24 Q
What?
l 25 A
For certain secondary side transients, the I
5
t l
i 1
Dunn 151
(~)
V 2
high-pressure injection system is actuated.
3 In analyzing those transients, safety Analysis 4
would have to deal with that fact.
- (1 5
g Did you ever consider consulting 6
LaBelle regarding prescriptions that you thought 7
should be sent out on when it would be appropriata 8
to terminate high-pressure injection?
9 A
Not that I recall.
10 Q
Do you know whether LaBe[le was ever 11 consulted after the Three Mile Island accident 12
(-]
with respect to the Small Break Guidelines?
V 13 A
No.
14 Q
Or believe.
15 A
I don't believe he was consulted relative 16 to the small Break Guidelines.
i 17 Q
Norm Elliott you testified yesterday was 18 the Manager of the training operation at B & W.-
19 That is your understanding, is that right?
20 A
Yes.
(
21 Q
Have you met Norm Elliott from l
22 time to time?
23 A
Yes.
r 24 Q
Have you ever been invited to participate 25 in any aspects of training?
l
,1 1
Dunn 152
\\
sI 2
A I believe so.
3 Q
Have you ever participated?
4 A
Yes.
5 Q
In what training activities have you 6
participated and in what capacity?
7 A
The ECCS would occasionally be asked to give 8
lectures to utility personnel as part of 9
training programs conducted by B&W for the utilities.
10 Q
When asked, did you serve,,7
~
11 A
Yes, or had one of my people do the job.
12 Q
Prior to the Three Mile Island accident, O
12 had ECCS been asked to give lectures?
14 A
Yes.
I 15 Q
Subsequent to the Davis-Besse
'16 transient.in September of 1977, but prior to the 17 Three Mile Island accident, had the ECCS Unit 18 been asked to give lectures?
l 19 A
I don't believe so.
20 Q
On what subjects had ECCS given
(,
21 lectures prior to the Three Mile Island accident?
l 22 A
Generally on the subject of ECCS analysis, 23 the materials we supplied in supoprt of the 4
)
24 license for the plant, building analysis.
I l'
25 Q
Building?
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A Yes.
3 And perhaps internal forcing functions.
4 Q
Did you personally deliver any of the 5
lectures?
6 A
Yes.
=
7 Q
Did you ever talk about the fundamental 8
purposes of ECCS?
9 A
Yes.
L 10 Q
How many times did you give lectures, 11 you personally?
12 A
I'm not sure.
-- 13 Q
Were you a regular featu're on the 14 training lecture circuit?
15 MR. FISKE:
I don't think there is 16 any circuit, Mr. Seltzer, in that sense of 17 the word.
They are all home game}s.
I 18 Q
Were you a regular participant in.the 19 training programs?
20 A
I don't know.
(
21 Q
Approximately how many operators 22 were exposed to an original Bert Dunn lecture on l
l 23 ECCS?
24 MR. FISKE:
I'm sorry, I don't understand 25 what you mean by " original."
. - ~
I
_j 1
Dunn 154 l
2 MR. SELTZER:
By Bert,Dunn in 3
Person, not through --
i 4
MR. FISKE:
You mean in sum total
)
(I 5
how many different operators listened to any 6
lecture he gave as part of the training l
7 program?
8 MR. SELTZER:
Yes, approximately.
9 Q
Prior to March 28th.
e 10 A
I would estimate between 40 and 50.
B 11 Q
Do you know whether any of those
(
12 included personnel from Metropolitan Edison Company?
13
~ A No, I do not.
~
14 Q
In lecturing to 40 or 50, how 15 many different lectures do you believe.you 16 delivered?
In other words, how many different 17 groups do you think you lectured to?
18 A
Two or three.
19 Q
In all of the two or three lectures, 20 do you believe you devoted time to the fundamental
(
21 purposes of, emergency core cooling?
22 A
Yes.
23 Q
What are the fundamentals that you O
24 believe you imparted to your students?
25 A
One would be the accident basis for each of 2
A _
W
1 Dunn 155
~~
('T V.
2 the emergency core cooling system components; s
3 another would be the description of how the 4
components function during classical or simplified 5
accident scenarios to illustrate how they 6
accomplished their purposes.
7 Q
Does that describe the fundamentals 8
that you related?
9 A
It describes the fundamentals relative 10 to the emergency core cooling systemI 11 Q
Did you ever discuss when is the 12 appropriate time for termination of high-pressure 13 '
injection?
14 A
No.
15 Q
Did you ever discuss the concept 16 of 50 degrees subcooling margin?
17 A
Prior to March 28th?
18 Q
Yes.
19 A
No.
20 Q
Did you ever discuss maintenance of
(
21 any subcooling margin prior to March 28th, 19797 22 A
I am not sure.
23 Q
As we have used "subcooling margin" in Ol 24 this question and in the previous one, did you 25 understand that I meant the margin below the
~'
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.1 Dunn 156 2
temperature at which saturation is achieved?
3 A
That's how I took your statement.
4 MR. SELTZER:
Off the record.
5 (Discussion off the record.)
6 BY MR. SELTZER:
7 Q
Do you want to modify anything that 8
youhavesaidalreadyinlightofyourconfarbee 9
with counsel?
(
10 A
The part of the lecture dealt with the 11 fact that important or limiting small breaks 12 required continuous operation of tha high-pressure 13 injection up until the. time that the' critical 14 phase of the accident had been passed.
15 Q
You told the operators that?
16 A
In substance.
17 Q
Did you tell them that at 11 two 18 or three lectures that you delivered?
19 A
I couldn't testify to that directly.
20 I believe so.
('
21 Q
That prescription requires that the 22 operators have first identified that there is a 23 loss of coolant accident in progress, right?
C) 24 A
I don't know that I communicated a 25 prescription.
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2 I told them how a small break 3
accident would involve -- evolve and what were some 4
of the things necessary to deal with it.
k 5
Q Did you testify a minute ago that 6
during a small break loss of coolant accident, it 7
is important to maintain continuously high-pressure 8
injection?
9 A
I testified that during the limiting 10 small break loss of coolant accidents, it is 11 important in order to mitigate the accident to the 12 degree that the licensing basis for the plant 13 is maintained, to maintain continuou'i high-pressure 14 injection.
15 Q
Did you ever discuss with your students 16 how they should know when they were in the critical l
17 point of the accident and should not terminate 18 high-pressure injection?
~
{
19 A
No.
~
l l
20 Q
Who else from the ECCS Unit delivered 21 lectures to the Training Group before the Three Mile j
22 Island accident?
23 A
I'm not sure.
24 Q
Whom do you believe gave such 25 lectures other than yourself?
e
-. ~
1 Dunn 158
('s 2
A I believe Bob Jones gave some lectures.
3 Q
Do you believe anybody'from ECCS 4
gave luctures to operators ccming for training
(
5 between the time of Davis-Besse's incident in 6
September 1977 and March 28th, 19797 7
(
A No, I do not believe we did.
8 Q
When the participation of ECCS 9
people was being invited for training, who would 10 convey the invitation?
g 11 A
I don't think the invitation was unique.
12 Q
Could you describe how those requests
)
13 came in?
14 A
By phone from somebody in the Training 15 Department.
16 Q
Did the request to the best of your 17 recollection ever come from Norm Elliott?
18 A
I have no idea.
19 Q
To the best of your recollection, l
20 did the request ever come from Walt Perks?
l 21 A
I have no idea.
3 22 Q
Do you have any recollection of 23 anybody in Training making a request that somebody
()
24 from ECCS come over and give a lecture?
25 MR. FISKE:
You mean any specific t-
i
~~
1 Dunn 159 U('%.
2 individual?
3 MR. SELTZER:
Yes, thanks.
4 A
No, I did not retain anybody's particular 5
name.
6 Q
Prior to the Three Mile Islan d 7
accident, did you ever make any suggestion to Norm 8
Elliott or anybody else in Training that it 9
could be useful for somebody from the ECCS Unit 10 to come over and give a lecture?
11 A
I don't believe I did.
7 12 Q
Since the Three Mile I:sland accident,
\\
'13 have you ever expressed to an'yone yo.ur view 14 on the quality of the B&W training program as 15 it existed prior to the accident?
16 A
No.
, 17 Q
Have you ever stated anything in
(
~
18 writing about the quality of the B&W training 19 program?
l i
20 A
I don't believe so.
(
21 Q
Have you ever expressed any 22 opinion about the capabilities of the people who l
l 23 have conducted or are responsible for the B&W training program?
24 25 A
Since March 28th?
- ~ ~
~~
. _. ~ _
1 Dunn 160 2
Q Yes.
1 l
3 A
Yes.
4 Q
In what context did you express such
(
5 views or opinion?
6 A
I believe I complimented one of the instructors 7
on his presentation.
8 Q
Was this a presentation given before 9
or after the accident?
10 A
After the accident.
e 11 Q
Did you ever compliment an instructor 12 before the accident?
/
13 A
Not that I'm aware of.
14 Q
Have you ever expressed an opinion 15 about the capability of Norm Elliott?
16 A
I don't believe so.
17 Q
Have you or any of the othe,r 18 ECCS lecturers prepared any written materials 19 in connection with the lectures you delivered 20 before the Three Mile Island accident?
21 A
We would use illustrated viewgraphs during 4
22 the lectures.
23 Q.
Did you hand out any written materials?
()
24 A
I don't believe so.
25 Q
When I was asking you previously
f 1
Dunn 161 2
about whether you have expressed any opinion about the quality of the training program or the 3
r 4
competence of the people that ran it, I had 5
asked you whether you had expressed such views after 6
the accident.
i I
7 Had you ever expressed any views on either 8
of those subjects before the Three Mile Island I
accident?
g I
10 A
Not that I recall.
t 11 Q
After the Davis-Besse transient 12 but before the Three Mile Island accident, O
13 did you ever discuss with anybody th possibility 14 that you or somebody else from ECCS or the 15 Engineering Department should give a lecture as 16 part of the training program on termination of 17 high-pressure injection?
18 MR. FISKE:
I think he ans[ered 19 that question before, but go ahead.
20 A
I don't belie've so.
21 Q
Are you familiar, other than just 22 from GPU Exhibit 76, with the October 23, 1977 23 incident at Davis-Besse?
24 A
No.
25 Q
Have you ever heard what led the y
,w, w.
.,,_r.
,.--,e
,e
,--.7
1 Dunn 162 2
operator to bypass high-pressure injection on 3
october 23, 19777 4
A I don't know that I do know what led to
(
5 him -- led to it.
6 Q
Do you have a belief as to what led 7
them to terminato it?
8 A
Yes.
9 Q
What?
10 MR. FISKE:
I think you ought to 11 first ask what the belief is based on.
12 Q
What is the belief based on?
(9 13 A
I am not sure I can recall.
14 Q
O.K.
What is your belief as to why 15 they te rminated?
16 A
I believe that the pressurizer level 17 increased again.
18 However, that may have noth1ng 19 to do with the actual reason.
j l
20 Q
Joe Kelly says in the first sentence
(
21 of GPU Exhibit 76, "Two recent events at the Toledo 22 site have pointed out that perhaps we are not giving 23 our customers enough guidance on the operation of
()
24 the high-pressure injection system."
25 "The Toledo site" refers to Davis-Besse
.s
.f
l' t
4
~~
1 Dunn 163 s
~
\\
-s.,
s 2
Unit I, does it not?
A I believe it does.
3 4
Q Kelly has said in that first sentence 5
that those events pointed out that "perhaps we are 6
not giving our customers enough guidance on the 7
operation of the high-pressure injection system."
8 You subsequently took actions which 9
reflected your agreement with that statement, l
I 10,
did you not?
e 11 A
I took actions which were based on my
.i.o.
' assumption that this statement is reasonably q
~
13
- - accurate.
~
s 14 Q
Why did you believe that B&W should i
15 give its customers more guidance on the operation l
of the high-pressure injection system?
16 17 A
Because for whatever reasons I felt 18 that operators were terminating high-pressure 19 injection at inappropriate times.
'\\
s 00 Q
Why did you believe B&W should give i
21 greater guidance instead of leaving it to each
~
\\s q'
22 customer to try to figure out how to operate s,
Q
~
s s
' T
.. 23
, }
the,high-pressure injection system?
O) m.
1 A
A '
Because it's important to operate the
(
24 4
1 4
25 system properly in the event that there is a
~w 3
1
~
E
_.. _I ; 'iT
lP 1
Dunn 164 2
critical small br al, and we had evidence 3
that in two circumstances it had been f
4 operated inappropriately in our belief.
5 Q
Was it your thought that B&W 6
had observed certain experience which other customers f
7 could profit from?
I didn't phrase that as 8
aptly as I should.
9 Was it your view that Btw had t
10 gained certain experience from its observation 11 of the Toledo Edison incident which other
(~5) 12 customers of B&W could profit from? -
\\>
13 A
We had gained information whic'h our 14 customers could I believe profit from.
15 g
Is there any other reason why you 16 believed B&W was in a good position to give t
17 greater guidance on the proper operation of 18 high-pressure injection rather than leaving it to 19 each customer to figure out for itself?
20 MR. FISKE:
I think I will object to the
(!
21 form of the question, but you may answer it.
l 22 A
Well, it's my understanding that each customer 23 as an organization is responsible for its operations
(~)
24 and no, I don't believe there were other reasons.
1 25 Q
In the box at the top of GPU Exhibit 76 i
I Dunn 165
(~h
-J 2
marked for identification what does the s
3 heading "Cust." refer to?
4 A
Excuse me?
()
5 Q
(Indicating.)
1 l
6 Is that short for customer?
I i
1' 7
A Yes.
8 Q
After the abbreviation for customer, 9
Joe Kelly has written " Generic.*
10 Did you understand Kellytto mean that 11 this was customer guidance on high-pressure 12 injection system operation which should be made gs 13 generally available to all customers at B&W 14 plants?
l 15 A
I would interpret that as meaning that 16 to whatever purpose Joe felt this memo would 17 serve, he considered the issue applicab.le to all 18 customers.
19 Q
Do you see the next to the last 2O sentence in the first paragraph that begins with 21 the phrase "As a result"?
(
22 A
Yes.
23 Q
Kelly states there, "As a result, the 24 transient continued on with boiling in the RCS, etc."
25 Does that mean that the temperature s.o w
.~
I i
1 Dunn 166 O
V 2
in the reactor coolant system exceeded the 3
saturation point during the Davis-Besse transient?
4 A
I would not infer that.
5 Q
Can you have boiling in the reactor 6
coolant system primary control volume without 7
having r'eached saturation?
8 A
For the system as a whole, yes.
9 Q
From your kncwledge of the Davis-Besse 10 transient at the time you received GPU Exhibit 76, 11 do you believe you were aware that saturation 12 had occurred in the primary control volume on
(:)
13 September 24, 19777 14 A
My study and deduction of the September 24th, 15 1977 transient indicated to me that saturation 16 had occurred in the reactor cooling system.
17 Q
when you say " saturation had occurred 18 in the reactor cooling system," you are' referring 19 to the primary control volume, not the solume 20 in the pressurizer, right?
Because it is my 21 understanding from Al Womack and others that 22 you always have saturation from the pressurizer 23 under normal operation.
24 A
With the understanding of that addition, yes.
25 Typically I refer to the primary 7-,
.__.y..
7
1 Dunn 167 2
system as the remainder less the pressurizer.
3 Q
Were you telling me a minute ago 4
that you wouldn't understand the "As a result" 5
sentence to refer to the existence of saturation 6
in the reactor cooling system?
7 A
I don't believe I told you that.
8 Q
Does the sentence, "As a result, the 9
transient continued on with boiling in the 10 RCS, etc." mean that saturation temph,rature had 11 been reached in the reactor cooling system?
12 A
The sentence could not ' int interpreted
(~S.
('/
13 to mean that uniquely.
14 Q
Did you understand it to mean that?
15 MR. FISKE:
You mean based on 16 everything he knew about the accident?
17 MR. SELTZER:
Yes.
18 A
Yes.
19 Q
Just to perfect my knowledge, is it 20 true you can't exceed the saturation temperature
(
21 in water until you have boiled off all the 22 liquid water?
23 A
No.
24 Excuse me.
You said in water, 25 didn't you?
s.
m
I 1
Dunn 168
,OLi 2
Q Yes.
L 3
A That answer is yes, except under extremely 4
unusual circumstances.
5 Q
Does the steam which stays in 6
close proximity with boiling water also remain 7
near the saturation temperature until all the 8
water has been boiled into stean?
9 MR. FISKE:
Mr. Seltzer, I would 10 cuggest, if you are asking thet questions for 11 general information, you have a highly
~
12 qualified individua1 to your right that
('h 13 you can ask.
l 14 MR. SELTZER:
What?
15 MR. FISKE:
On your right who can 16 answer all those questions as well as l
17 Mr. Dunn can.
l 18 MR. SELTZER:
This is very relevant i
i l
19 to what I am going to be getting into.
20 I am not just asking for general edification.
21 MR. FISKE:
Well, why don't you read l
22 the question back.
23 (Question read by the reporter.)
24 A
First, water is a word used to describe a 25 chemical substance, described more accurately as
,w
...3
~,.w
,-----.--,.g gw.4,
-..p-
--,7 e,
w-,
y,.m
1 Dunn 169
/~T
'%f 2
H20. For the purposes of the remaining 3
discussion', I will term water as being a liquid 4
state.
I will also have to say that I will be
(
5 talking about normal occurrences, the general rule 6-in answering your question, and occurrences typical 7
of small break loss of coolant accidents, and 8
the ancwer would be yes.
9 Q
Are you familiar with the term 10 "superheat"?
L 11 A
Yes.
12 Q
Does superheat refer to an elevation O
13 of steam temperature above the tempe ature 14 of saturation?
15 A
Yes.
16 Q
Kelly concluded in his memo 17 by saying "I would appreciate your thoughts on this 18 subject."
19 Do you see that?
20 A
Yes.
(
21 Q
Did you, subsequent to receiving 22 this memo,ever give Kelly your thoughts on the 23 subject, namely, the subject in his memo?
O( _/
24 A
I don't know.
25 Q
Do you believe that you did?
N'
Dunn 170 1
O A
I believe that Joe and I had intercourse 2
n the subject of the meno and on'my thoughts 3
about the particulars of items "a" and "b."
.As 4
(,
to whether that was subsequent to the memo or noe, i
I d n't know.
6 Q
What did you believe would be the next 7
l' g.
_ step to obtain any implementation of these guidelines or communicating tasse guidelines to customers?
i g
A I believe the next step would ge an open forum 10 c f discussion.
11 12 Q
Did you think that that was going to be a f rum inv lving pe pie sitting around in a roon 13 or somewhere discussing it orally?
14 A
I believe that to be one possibility.
15
~
Q Did you believe that the forum could 16 i
also be conducted through exchange of written 17 views?
^
18 A
Yes.
19 Q
What led you to believe that a forum 20 f either nature would ensue?
21 A
I felt that people would want to understand 22 why Joe had written this memo, why he had recommended 23 "a"
and "b."
34 Q
Whom did you expect or what group did 25 4
,vn-,
.------enm
-.,w r,--,-,-w
,n
,g
---r, r,- -, - - - - - - - -,-
e
1 Dunn 171 2
you expect would take th'e initiative in creating 3
such a forum?
4 A
I don't believe I had any expectations
)
5 of one group or another taking the initiative.
6 Q
Did you believe it could be any of 7
the several people included en the distribution 8
list who could initiate such a torum?
9 A
Yes.
10
!!R. FISKE:
Is this a good time to 11 break?
I 12 MR. SELTZER:
Sure.
([)
13 (Recess taken.)
14 BY MR. SELTZER:
15 Q
To the best of your recollection, 16 was the October 23, 1977 Davis-Besse occurrence 17 ever discussed at a Plant Design Sectio.n meeting?
3 18 A
I don't recall such a discussion.
19 Q
Bruce Karrasch is on the distribution
, 20 of GPU Exhibit 76 marked for identification, 21 and Bruce Karrasch was also on the distribution of i
(
22 your February memoranda.
23 Did you ever have any discussions
(
24 with Bruce Karrasch prior to the Three Mile Island 25 accident about the proper time for terminating
1 Dunn 172
(^)T 2
high-pressure injection?
3 A
I don't believe so.
4 Q
Joe Kelly's guidelines for when you 5
should terminate high-pressure inj ection are not 6
related to whether the reactor coolant system 7
la subcooled, is that right?
8 MR. FISKE:
Not specifically.
9 MR. SELTZER:
Specifically, generally, 10 or otherwise.
11 Q
Lst zo ha as specific as I can be.
12 i Joe Kelly's guidelines in GPU Exhibit 76 aye O-13 not tied to whether the reactor coolant system is 14 at a temperature lower than saturation, is that 15 right?
16 A
They are not uniquely tied tc that, no.
17 Q
In other words, they don't. prescribe that 18 the operators determine that the reactor coolant 19 system is below saturation before terminating 20 high-pressure injection, do they?
I 21 A
Not that I can see.
(
22 Q
That was a fundamental 23 improvement which you made in your guidelines 24 when you formulated them for Jim Taylor 1.1 your 4
25 February 16, 1978 memorar.dum, isn't that right?
i
I 1
Dunn 173 O
V 2
MR. FISKE:
I think I will object to 3
the" form.
4 You may answer.
5
.A The characterization of'the recipe 6
that I_gave in the February 9th memo --
7 Q
I don't mean to interrupt, but I was 8
referring to the February 16 memo.
9 A
Very well.
10-The chsracteriaation givhn in the i
11 February 15th memo duals with subcooling and I
12 is therefore a change from the characterization 13 given in the November 1 Kelly memo.
14 Q
At the time that you made that change, 15 you believed it was an important change, didn't 16 you?
17 A
I believe that the instructions or 18 recipe contained in the February 16th emo was 19 a more direct measurement of appropriate l
l 20 conditions for termination of high-pressure
(
21 injection.
22 Q
Do you know of an individual at l
23 Babcock & Wilcox named J.
F.
Walters?
24 A
Yes.
25 Q
Is he somebody that you have spoken l
I
f 1
Dunn 174 C\\
U 2
with from time to time?
3 A
I believe we are referring to the person 4
I term Frank Walters, and I know who he is and have 5
spoken to him from time to time.
6 Q
Is Frank Walters somebody who is in 7
Castomer Service and reports to Don Hallman?
't i
8 I A
No.
I I
l 9 !
Q Did he report to Don Hallman in tne t
5 l
e i
10 1 fall of 19777 t
l l
A I bailevre so.
11 12 Q
And he was in Customer Service at
~
13 that time?
14 A
Yes.
15 Q
Did you ever talk with Frank Walters 16 prior to the Three Mile Island accident about 17 termination of high-pressure injection 2 18 A
To the best of my knowledge today, no.
19 Q
Prior to the Three Mile Island 20 accident, did you ever have any conversations 21 with anyone in Training about the subject of
(
22 termination of high-pressure injection?
23 A
No.
24 Q
Is the Training Servi,ces Group 25 located in the same Old Forrest Road building tv -
- 4 a*
--,--,w-
1 Dunn 175 e
\\_/
2
.that you were located in in the fall of 1977?
3 A
Y e s.-
4 Q
Is there anyone in Training Services 5
that you were socially friendly with in the 6
period between the Davis-Besse incident and the 7
Three-Mile Island accident?
8 A
No.
. I g
Q Is Norm Elliott someone that you 10 have ever from time to time just called up and 11 said "How about having lunch together today"?
12 A
No.
()
i
\\#
13 Q
Between the time of the Davis-Besse 14 incident in September of 1977 and the Three Mile 15 Island accident, did you have any conversations 16 on any subject with anyone in Training?
17 A
Not that I recall.
I 18 Q
On February 9, 1978 you sent a 19 memorandum to Jim Taylor on the subject:
" Operator 20 Interruption of High-Pressure Injection."
21 What prior contact had you had with 22 Jim Taylor?
23 MR. FISKE:
You mean on anything?
()
24 MR. SELTZER:
Yes.
25 A
Many prior contacts.
o-e--
e
1 Dunn 176
~
(~'N, O
2 Q
Had you worked together with him on 3
licensing matters?
4 A
Yes.
5 Q
Is that a fair characterization of all G
of the things that you had done together?
7 A
Most of them.
8 Q
Eat other thir.gs had you done with
(
f Jite Taylori l
9 10 A
Previous to Jim's assignment a3 Section I
11 l Manager fo r.1.iconsing, Jim had been assigned as 12 a Manager fo,r a gro2p who.se function was coordination bv 13 with Brown Boveri Reactorate and we_had technical 14 interchanges and relationships during that period.
15 Q
At page 82 of your President's 16 Commission deposition, you were being asked 17 about the February 3, 197a memorandum and at line 18 10 you were asked what led you to address it to 19 Mr. Taylor.
You said, "Mr.
Taylor is a Manager of 20 Licensing.
I considered this a significant issue for
(
21 which I had not been able to create action by i
22 other means and felt that Mr. Taylor could influence 23 such action to take place."
O()
24 What did you mean when you said "I had 25 not been able to create action by other means"?
1 Dunn 177
(~5
~
(_)
2 What other means were you referring to?
3 A
The discussions with Integration and the i
4 request that Integration instigate a forum for k
5 review or a forum for resolution of my concern.
6 Q
If you felt that you wanted Integration 7
to create a forum for the resolution of your concern,
't 8
why didn't you speak to Bruce Karrasch, the head l
of Integration?
9 i
10 A
I don't know.
(
11 Q
Was there any hostility at the time 12 hetweer. you and 3ruce Karrasch?
?
- \\'
13 A
No.
s 14 Q
Had you had any run-ins with him that 15 made you disinclined to talk to him?
l 16 A
No.
I 17 Q
Is he somebody that you conversed with i
l 18 at Plant Design Section staff meetings?
19 A
Yes.
20 Q
Is he somebody that you felt you l
21 could talk to openly in the course of B&W's 22 business?
1 l
23 A
Yes.
()
24 Q
Is he somebody that you discussed other 25 things with during the period between the su..
.: v
1 Dunn 178 Ou 2
Davis-Besse transient and the Three Mile Island 3
accident?'
4 A
Yes.
5 Q
Were you bashful about discussing it 6
with him?
7 A
No.
I 8
Q What in particular was there about 9
Mr. Tsy2 or that mcde you select him as the r
10 l principal rocipient of your February.9 and s
g 11 February 16 memoranda rather than John MacMillan or 12 Olds or somebody else in the company?
(_)
13 A
The issue in my belief was,, safety-related.
i 14 Mr. Taylor was a Manager of an organization 15 connected with the licensing function and thus, to l
16 some extent, connected to safety considerations.
I 17 Mr. Taylor is also a highly-influential 18 person within Babcock & Wilcox, and I elt that 19 that influence would be useful.
l 20 Q
What do you mean by " highly influential"?
(
21 A
Jim is well-respected.
He is a Section Manager.
22 He has many contacts, and in my belief thought to be 1
23 a very capable person.
24 Q
You say "many contacts."
25 Do you mean contacts with management at k-w
+
,-.-r c
1 Dunn 179 O'
2 B&W that were senior to him among others 3
with whom he had contact?
4 A
I think I meant more generally, just contact
(
G with a great many people in B&W.
6 Q
Did those contacts include people 7
who were in senior management at B&W7 8
A Yes.
9 g
Who was the head of the Engineering 10 Department ac che time of the Davis-Qesse 11 accident?
~
12 A
I believe at the time of the Davis-Besse O
s
~
k-13 -
accident the head of the Engineering Department 14 was Mr. Jim Deddens.
15 Q
What types of contact did you have with 16 Jim Deddens while he was the head of the Engineering 17 Department?
18 A
Administrative contacts in the fo'rm o f 19 information meetings, meaning contact for review 20 of critical business issues.
21 Q
Were there any periodic meetings 22 that you and Deddens attended?
23 A
During what time period?
()
24 Q
During the period that you were Unit 25 Manager prior to the Three Mile Island accident.
p
.ep
---+-,--y
1 Dunn 180
~~
O 2
A One.
3 Q
When was that?
4 A
Well, it wasn't unique.
5 Q
Y u mean there was one type of meeting?
~
6 A
Yes.
7 Q
It was held rocurrently?
i A
Yes.
g l l
l 9
Q What was that type of meeting?
l l
I A
j A generni departunnt inforeation useting.
i 10 11 Q
How fraquently were those held?
12 A
Approximat21y once every year.
(~T 13 Q
At what time of the year?
y A
The practice has been discontinued and I 15 believe they were in the spring but I could be 16 wrong.
17 Q
Were technical subjects ever discussed 18 at those meetings?
19 A
No.
20 Q
S if y u had a serious concern about 21 potential for operator action to terminate l
22 high-pressure injection, would that have been an 1
23 appropriate thing to discuss at the general 24 department information meeting?
25 A
That would have been a highly inappropriate i
e
' lL:
l' Dunn 181 0
2 thing to discuas at that meeting.
3 Q
' Why would it have been highly 4
inappropriate?
(
5 A
The meetings were to discuss general 6
business plans and goals for the corporation.
7 Well, our part of the corporation.
d j Q
An imporuant safety concern would I
5 not as appropriate to discuss at such a meeting?
l 10 A
Not in ny mind.
j 11 Q
Your concern about high-pressure i
l 12 in'jection was an important safety concern in your 4
t_
13 mind, wasn't it?
14 A
I considered the issue of control of 15 high-pressure inj ection as a serious issue and as 16 related to safety.
17 Q
Is Deddens somebody whom you ever 18 dropped in to talk to without making an appointment 19 ahead of time?
20 A
No.
(
21 Q
Did you ever make an appointment 22 to see Deddens?
23 A
I don't believe so.
f~h
(_)
24 Q
Did you ever discuss with Deddens 25 your serious concern about inappropriate
_-m-,
i f
1 Dunn 182 Iv 2
termination of high-pressure injection?
3 A
No..
4 Q
Before sending your February memoranda 5
to Jim Taylor, did you discuss with Don Roy the 6
fact that you were having trouble getting action 7
on your serious concern?
6 A
I don't believe so.
xl g l MR. SELTZER:
I would like e.o nark
- 0 for identification as GPU E"hibit 77 your ji ll 11
,l February 9 memo 40 rTin Taylce, s ub j r> c t :
i i
I 12
" Operator Interruption of High-Pressure sd 13 Injection."
14 MR. FISKE:
Off the record.
15 (Discussion off the record.)
16 MR. SELTZER:
I would like to mark 17 for identification, at Mr. F is ke ',s suggestion, 18 the organization chart for the Nu' clear Service 19 Department for, it looks like Dec5mber 1,
1977, showing Mr. Finnin's position and 20 21 from which the witness was testifying a 22 moment ago.
23 (Organization chart of Nuclear I~
(_-]
24 Service Department dated 12-1-77 marked 25 GPU Exhibit No. 77 for identification as s
. rv e v
7 4
y e --
, -. + -..i.-- - -. -.
n m,.
- - - + -
--w
--ye-m--
p --
1 Dunn 183 2
of this date.)
3 (Two-page memorandum dated February 9,
4 1978 to Jim Taylor from Bert M.
Dunn 5
marked GPU Exhibit No. 78 for 6
identification as of this date.)
7 BY MR. SELTZER:
8 Q
Is GPU Exhibit 78 a copy of a memc l
9 which you authorad and rant to Jim Taylor on or i
i i
10 about February 3, 19797
(
11 A
Yes.
12 Q
D.id you also send it to each of the O
13 individuals listed as a copyee on page 2 of the 14 document?
15 A
I believe so.
16 Q
Eric Swanson is your first copyee.
j 17 He was in the Plant Integration Section at the 18 time, right?
j 19 A
Yes.
20 Q
Why did you send it to Eric Swanson?
(
21 A
Primarily for information.
22 Q
Why did you think this was information 23 that you wanted Eric to have?
(~( )j 24 A
I had been discussing the subject of 1
25 termination of high-pressure injection with
^
J.
-J~
1 Dunn 184
(
2 Mr. Swanson and I wanted to keep him informed f what I.was doing.
3 4
Q Don Roy was the Manager of the Plant 5
Design Section at the time you sent GPU 6
Exhibit 76 to himi is that right?
7 A
Yes.
g Q
He was also at that tima your boss, 9
right?
10 A
Correct.
t l
0 11 Q
And he is che same Don Eoy who had 12 told you go do it, take stups to resolve your O-43 concern over inappropriate termination of 14 high-pressure injection, right?
15 A
We had agreed to my doing that.
l 16 Q
Why did you send Dr. Roy a copy of 17 GPU Exhibit 78 marked for identification?
18 A
For information.
19 Q
Why did you believe that this was 20 information which should come to Dr. Roy's attention?
l A
I don't know.
21 22 Q
Prior to the Three Mile Island i
i 23 accident, did Don Roy ever say anything to you about 24 the contents of your February 9 and February 16 s.
25 memoranda?
l
,-.,._,,-,-,,e
,-.-w.
7
_.,p.
p
1 Dunn 185 O
~
s A
Prior to the March 28th accident at Three 3
Mile Islarid?
4 I believe he did not.
5 Q
You also sent a copy to Bruce 6
Karrasch, the Manager of the Plant Integration 7
Gection.
O Why did you believe that you wanted 9 l Brucs Karrasch to havs the information containad l
10
!t in Get E.chibit 75 mar.ked for identification?
l l
11 Let me ask a pre'.irsinary qusstion.
12 Did you still bela.evo at the time you O
t 13 sent GPU E::hibit 78 that Plant Integration 14 would be an appropriate unit to create a forum 15 for the resolution of your concern?
16 A
I believe they would be an appropriate unit, 17 but I also recognised that the forum had not yet 18 been created.
19 Q
Did you also feel that you had 20 waited a sufficient amount of time for
{
Integration to move the ball forward?
21 22 A
Yes.
23 Q
And that now you wanted to pursue other y) 94 avenues?
25 A
Not necessarily.
- bk * - -
m
. _~
1 Dunn 186 f~T LJ.
2 Q
This is the first time you brought 3
your conce-rn to Jim Taylor's attention, isn't 4
that right?
5 A
I believe so.
6 Q
When I said " pursue other avenues,"
7 I didn't mean pursue them to the exclusion of 8
continuing to pursue having Plant Intagrution,,
9 create a 2crum.
10 It's a fact, isn't it, that in sending l
11 this to Jim Taylor, you wire pursuinn another 12 avenue for resolution of yo'2r concern other
(~)
13 than waiting for Plant Integration to act?
14 A
I think that's fair.
15 Q
Why did you send Bruce Karrasch the 16 information that is in GPU Exhibit 787 17 A
For information.
l anything you hoped he 18 Q
Is there 19 would do with the information?
20 A
I don't think I can recall whether there was 21 anything specific I hoped he would d,o with the 22 information.
23 Q
This is the first time that you had 24 communicated your concern directly to Bruce Karrasch, 25 isn't that right?
k i
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1 Dunn 187
['#
2 A
I believe so.
3 Q
Did you have any reason to believe 4
that Joe Kelly or Eric Swanson had communicated
(
5 your concern to Mr. Karrasch before' February 9,
6 19787 7
A I don't know.
8 Q
Did you have any desire that Mr. Karrasch 9
raight take come action or interest in your ;oncern 19 )
as a result o* receiving your February 9 memorandum?
11 A
I had the general desire that people take I
12 I interest or action.
f~\\
5
's /
13 Q
And that general intcrest would extend 14 to the people that you were sending this memo to?
15 A
Yes.
4 16 Q
All of.them?
i 17 A
No.
18 Q
Did it extend to Bruce Karr'asch?
19 A
The general desire, yes.
20 Q
At the time you sent H.
A.
Bailey 21 a copy.of GPU Exhibit 78, he~was in a Licensing 22 Unit that reported to Jim Taylor, is that correct?
23 A
That is correct.
l
(~T 04 Q
What was his particular function as you i
l
%.]
25 were aware of it in or about early 19787 l
L.
1 Dunn 188 A
2 A
Henry was a member of the generic licensing 3
unit and primarily represented lic'ensing for ECCS 4
matters.
l l'
5 Q
In sending the information in GPU 6
Exhibit 78 to Mr. Bailey, did you want him to be 7
supportive of your request that Jim Taylor, 8
who was the head of Licensing, take some action?
9 A
Well, I don't think I asked Mr. ' taylor to take 19 any action, t
11 I asked that action be taken in the t
12 foru thnt I wanted Henry tt, suppcrt the idea that
(~
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13 action should be taken.
3 14 Yes, I would have wanted his support.
15 Q
You also sent a copy to E.
R.
Kane 16 who was in the Operating Plant Licensing 17 Unit reporting to Mr. Taylor.
18 Did you send it to him becEuse you 19 wanted his support in obtaining action through 20 the Licensing Unit or Licensing section?
21 A
Again, I was seeking that action take place.
22 I am not sure that I was thinking it particularly 23 important that it take place through the Licensing
()
24 Section.
In the forum that I was seeking action, 25 I would have been desirous of Mr. Kane's support.
i 6
1 Dunn 189 O
~/
2 Q
In sending it to Jim Taylor, were you 3
asking that Taylor, possibly with the support of 4
others in his Licensing Section, initiate
(
5 the action to resolve your concern even if they were 6
not going to complete the action themselves?
7 A
Excuse me, I missed the first clause.
8 Q
Were you asking that Taylor 9
and others in Licensing initiate the action even if I'
they were not going to carry forward the action 10 l
1; entirely by themselves to resolve ycur concern?
12.
Maybe cctalyze instead of initiate 13 would be a better verb.
14 A
I was seeking help in starting action.
15 I would say start or cause to be started 16 action. If that's catalyzation, fine.
17 Q
That's what you were looking for from 18 Jim Taylor and others in Licensing in' sending 19 this memo to them on February 9, 1978, is that 20 right?
21 A
Yes.
22 Q
You also sent a copy to J.
D.
Agar 23 who was in a Contract Licensing Unit reporting to 24 Jim Taylor.
25 were you looking for his support in 1
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1 Dunn 190
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getting action initiated by the Licensing Group?
3 A
I was looking for his support in getting 4
action initiated.
l 5
Q was there anything particular about 6
Mr. Agar and the role that you know he had I
7 previously perforded -that led you to select hin c
8 5 as a recipien t of GPU Cxhibit 78?
3 A
Not that I can recall.
10 Q
What about Nr. Kanei t
11 A
I believe.I was aware that Mr. Kane was
.-e 12 connected with o erational plaats -- operating (A/
13' plants.
,~'
14 Q
So that he might be well positioned 15
,for initiating the action of communicating with'
~
l 16 operating plants, is that your thought?
l 17 A
No.
E
~
i 18 Q
What was his connection to' operating encouraged you to,sen'd him dPU 19 plants that 20 Exhibit 787 1
21 A
That I felt he ha d a position ' connected l
22 with operating plants and the Licensing area and l
l 23 would be interested in this type of a subject.
/
(~
24 Q
Are you aware of whether Kane had l
l 25 some role working for Taylor of reviewing safety 4 I
/
/
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Dunn 191 s
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2 concerns including PSCs?
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s-A I don't believe so.
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Q
~ What does PSC stand for?
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- A Ereliminary safety concern.
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6 Q '-
Did you believe that there was anybody 4
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reporting to Taylor who had as one of his O \\y
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g responsibilities monitoring PSCs for the Licensing s,
'Section?
t 9
3 3
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,10 A
Yes.
I 3
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Q Who was that?
3 12 A
I don't know.
L 0:
~ 13 Q
Among the universe of pe,ople whom it
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14 coul'd have been, would Kane have been one of s
15 them?
[ 16
'A I don't know.
'17 Q
You-don't have any reason to exclude g
[*-
18 Kane, do you?
l 19 '
A No.
i j.
20 Q
You also sent a copy of the l
(
21 February 9 memorandum to R.
L.
Pittman who was l
22 a Manager of Mechanical Equipment and Fluid Systems 23 in the Nuclear Service Department.
l dp 24 What prior contact had you had with l
25 Pittman before you sent him this memorandum?
1.
1 Dunn 192 2
A I don't believe any.
3 Q
Why did you decide to communicate 4
the information in GPU Exhibit 78 to Mr. Pittman?
f k
5 A
I wanted to communicate the information in 6
my memo to representatives of Nuclear Service.
I 7
I believe I discussed who those representatives i
8 might be with either Eric Swanson or Joe Kelly 9
and at that discussion arrived at these names.
I 10 Q
Why, if you can recall, did they 11 suggest Pittman to you?
12 A
I do not recall.
i
- ' x 13 Q
Who is J.
D.
Phinny?
14 A
I'm not sure.
15 Q
Why did you send it.to Phinny?
16 A
For the same reason the memo was sent to 17 Pittman.
18 Q
Did you believe that Nuclea'r Service I
19 or Customer Service, as you sometimes call it, 20 would be an appropriate group for communicating i
21 your concern and your prescription for proper i
l 22 operation of high-pressure injection to customers?
23 A
Yes.
24 Q
Was that one of the reasons why you l'
25 sent'it to people in Nuclear Service?
I tI.
,_.___.._P
I Dunn 193 (m.
g w
A Yes.
3 Q
T.
Scott was in Test Planning in Nuclear 4
Service.
(
5 Had you had any prior dealings with 0
Scott before you were kind enough to send him 7
GPU Exhibit 787 0
A I agree that I was very kind to send him 9
that memo.
10 I do not believe I had previous 11 interactions or at least cannot recall them.
1 Q
Is he somebody whose name had been b
\\J 13 suggested to you by Eric Swanson, Joe Kelly, as 14 an appropriate recipient of this memo?
15 A
That is correct.
16 Q
Did you get any response to this i
17 memo either orally or written from Eric,Swanson?
A Not that I recall.
Q By this memo, let me re-ask'the 19 20 question and add this memo or the February 16 21 memo.
2 A
Not that I can recall.
23 Q
Did you get any response to l-A 94
(]
either your February 9 or February 16 memoranda l
25 from Dr. Roy?
1
1 Dunn 194 f
\\
2 A
Previous to March 28th, 19797 3
Not that I can recall.
4 Q
After March 28th, 1979, what, if k
5 any, response to your one-year earlier 6
memoranda did you get from Dr. Roy?
7 A
I can't recall the specifics of responses.
8 Q
What did he say in words or substance?
9 A
Well, the two memos in question were 10 discussed a great deal by various parties 11 after March 28th, 1979, and I wanted to respond 12 accurately to your question, and not indicate l)
\\~/
13 that nobody had talked about them at all after March 14 28th, 1979.
15 Don at one time after March 28th, 16 1979 indicated disappointment that more action 17 had not taken place because of the memo,s and 18 the concern raised in substance.
19 Q
Did he indicate that he believed you 20 should have done more to incite action?
21 A
I don't believe so.
{
gg Q
Did he indicate that he believed any 23 other particular individual should or could have
()
24 done more?
25 A
No.
1 Dunn 195 2
Q He didn't say in words or substance 3
that he thought Jim Taylor could have done more 4
to take action?
(
5 A
No.
6 Q
When he spoke to you after the 7
accident about your February 1978 memoranda, 8
did he indicate in any way that he remembered 9
that you and he had discussed your concern over 10 high-pressure injection being terminated prior to 11 the Three Mile Island accident?
12 A
I'm not sure I can answer.
g
%.)
13 Q
Was there anything in your conversation 14 with Don Roy that would create the belief or 15 impression that Roy remembered you and he had discussed 16 your concern at some time prior to the Three Mile 17 Island accident?
18 MR. FISKE:
Wait a second.
19 Can I hear that question again, please?
20 (Question read by the repo rte r. )
21 A
I'm not sure I can answer.
22 Q
What is inhibiting your answer?
23 A
Privileged communication.
D) 24 Q
You mean that Don Roy may have said
(
25 something to you on the subject in the presence
1 Dunn 196 u).
2 of an attorney?
3 A
Yes.
4 Q
Did Don Roy indicate to you after the k
5 Three Mile Island accident that he should have 6
done more to take action on your concern?
7 MR. FISKE:
Did he say that, is that 8
the question?
9 MR. SELTZER:
Yes.
Did he say that 10 in words or substance.
(
11 A
Again, I am not sure I can answer that.
12 MR. FISKE:
For the same reason?
A 13 THE WITNESS:
For the same reason.
14 Q
I don't want to press it because I think 15 your counsel may need to know a little bit more 16 from you about the nature of the communication.
17 I want to press, but if you want to talk in whose presence a[d to whom he 18 to him first about 19 was talking and were they seeking legal counsel 20 at the time the statement was made before I press 21 the question, feel free to.
22 MR. FISKE:
Yes, I think obviously 23 for the time being, unless you want us to stop
(~h o
(y
~4 and do it now.
25 MR. SELTZER:
Yes, could you?
,- - - - ~-
4
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1 Dunn 137 2
MR. FISKE:
I mean we can step outside 3
for a moment.
4 MR. SELTZER:
Why don't you do that.
(,8 5
MR. FISKE:
O.K.
6 (whereupon, Mr. Fiske and the witness 7
left the room.and returned thereafter.)
8 (Recess taken.)
9 MP. FISKE:
I have discussed this 10 subject with Mr. Dunn and if it will save 11
'any time, without precluding you from 12 aski,ng any questions you want to ask, it is 13 Mr. Dunn's recollection that he statements 14 by Dr. Roy were made as part of a meeting 15 in which Mr. Dunn participated with Dr. Roy and 16 others with George Edgar who was counsel to 17 B&W and the purpose of the meeting and 18 the purpose of the communication was to make 19 Mr. Edgar aware of the facts in connection l
20 with Mr. Edgar's representation of the 21 company at the Kemeny hearings, so we 22 would take the position that that is a 23 privileged communication.
()
24 BY MR. SELTZER:
25 Q
Did you ever discuss the same subject
-r,w,
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1 Dunn 198 2
matter with Don Roy out of the presence of 3
Mr. Edgar?
4 A
I don't know.
l 5
Q Do you believe that you did?
6 A
No.
7 Q
At any time before or after the 8
Three Mile Island accident, did Bruce Karrasch 9
ever respond to your February 9 or February 16 10 memorandum?
(
11 A
No.
12 Q
Did Mr. Bailey ever resp nd to either O
13 memorandum?
14 A
No.
15 Q
Did Mr. Kelly ever respond to either 16 memorandum either before or after the 17 accident at Three Mile Island?
18 A
Not to my knowledge.
19 Q
Did Mr. Kane ever respond to your 20 February 9 or February 16 memorandum?
21 A
Not to my knowledge.
22 Q
Did Mr. Agar ever respond to your 23 February'9 or February 16 memorandum?
O) 24 A
Not to my knowledge.
g 25 Q
Did Mr. Pittman ever respond to either
~..
. f.1 -
1 Dunn 199
/~g C
2 your February 9 or February 16 memorandum?
3 A
Not to my knowledge.
4 Q
Did Mr. Phinny ever respond to your
.)
(
5 February 9 or February 16 memorandum?
6 A
Not to my knowledge.
7 Q
Did Mr. Scott ever respond to your 8
February 9 or February 16 memorandum?
9 A
Not to my knowledge.
10 Q
In other words, the onlytperson who 11 responded to either your February 9 or February 16 12 memorandum was Dr. Roy?
13 A
The testimony I gave relative to Dr. Roy's 14 response was a short, quick, verbal communication 15 and not in essence a response to the memo.
16 Q
So none of the people whom you sent 17 copies to responded either orally or in writing 18 to either the February 9 or the February 16 19 memorandum, right?
Is that your testimony?
20 A
Yes.
21 Q
That leaves Jim Taylor as the 22 last hope of mankind.
23 Did Jim Taylor ever respond orally l
)
24 or in writing to either your February 9 or February 25 16 memorandum either before or after the Three Mile 9
w
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1 Dunn 200 t0 2
Island accident?
3 MR. FISKE:
I would not object to the 4
question part of that.
l 5
MR. SELTZER:
I will withdraw the 6
characterization of who Jim Taylor is.
7 Q
Do you understand what is left of g
the question?
9 MR. FISKE:
Did Mr. Taylor ever 10 respond to your memo, e
11 A
I am not sure.
12 Q
Other than in the presence of the 13 illustrious Mr. Edgar, did he ever respond?
A I am not sure.
g4 15 MR. FISKE:
Off the record.
~
16 (Discussion off the record.)
17 BY MR. SELTZER:
~
18 Q
Do you believe that he responded to 19 you?
l i
20 A
Yes.
/
21 Q
What is your belief as to when he k
22 responded?
23 A
Within a few days of the February 9th memo.
{aT 24 Q
Prior to receiving the February 16th 25 memo?
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y
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1 Dunn 201 2
A Yes.
3 Q
And was that an oral response?
4 A
I am talking about my belief that the
(
5 response occurred.
Yes.
6 MR. FISKE:
Well, let's make clear 7
once again as to whether the belief is based 8
on a recollection.
9 MR.. SELTZER:
I am going to press where 10 it was, who else was there, whpt was said.
11 Q
Where do you believe you had the oral 12 conversation with Jim Taylor following the 13 February 19th memo?
14 MR. FISKE:
I have no objection to 15 that, if you just substitute the word 16
" recall" for " belief."
17 Q
You said you believe you had a 18 conversation with Jim Taylor after Febr'uary 9, i
19 before February 16.
20 Where do you recall, to the best of 21 your recollection, such a meeting taking place?
l 22 A
I was in my office.
23 Q
Did he come to your office or did he
~'s 24 speak to you over the telephone?
(O 25 A
He spoke to me over the telephone.
?
~
l
~
w
I Dunn 202 l'
2 Q
How long a conversation was it, to l
3 the best of your recollection?
4 A
Subject, again, to the belief that this
(
5 took place, it was five or ten minutes.
6 Q
In words or in substance what do you 7
recall he said to you?
8 A
He asked me about the validity of my concern 9
and asked me to explain it.
10 Q
Did you explain your concern as best 11 you can recall?
U A
Yes.
g 4
13 Q
What in words or substance did you 14 explain to him was the basis of your concern?
15 A
That the operation of high-pressure injection 16 for certain critical small breaks required that 17 the high-pressure injection be on during the entire
~
18 course of the transient up until the critical phase 19 of the accident.
~
20 Q
Did you discuss with him what the 21 consequences of prematurely terminating high-pressure 22 injection could be?
23 A
I believe so.
()
24 Q
Did you te,ll him in words or substance 25 that the consequences of premature termination
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1 Dunn 203 2
could be possible core uncovery?
3 A
I believe so.
4 Q
Did you tell him that that could lead 1
(
5 to possible fuel damage, or would that go without 6
saying?
7 A
No, that does not go without saying.
8 I indicated that core termperature 9
excursions for critical small breaks would be t
10 more severe than computed for the licensing 11 base if significant interruption of the high-pressure 12 injection prior to the critical phases of the O
13 accident occurred and this could possibly lead 14 to core damags.
15 Q
Did Mr. Taylor indicate in this telephone 16 conversation that you believe took place that 17 he didn't believe what you were saying was accurate?
18 A
I don't think so.
19 Q
Did he say anything to you about 20 what, if any, action, he intended to take as a 21 result of getting your February 9 memorandum?
22 A
I'm not sure.
23 Q
Do you have any recollection of asking (Ng_)
24 him what action he would take?
25 A
No.
o
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1 Dunn 204
(-
2 Q
Was there any resolution reached in your 3
telephone, conversation with him?
4 MR. FISKE:
The resolution of what?
(
5 MR. SELTZER:
Of any subject thAt was 6
being discussed with him on the telephone.
7 A
I don't believe so.
g Q
Did he leave you with anything.that 9
he wanted you to follow up on and report back to 10 him?
g 11 A
No.
12 Q
Did you believe at the end of that
,~
(
13 conversation that there were any gaps in g4 Mr. Taylor's knowledge that needed to be filled 15 in order for him to,act upon your February 9 16 memorandum?
l 17 THE WITNESS:
Could I have that 18 repeated to me, please?
19 (Question read by the reporter.)
20 A
No.
l 21 MR. SELTZER:
Do you want to take a kw 22 break for lunch or shall we just continue on?
l i
23 MR. FISKE:
No, this is a good time.
(%
24 MR. SELTZER:
0.K.
'.,)
~
25 (Lunch recess taken at 12:40 p.m.)
i
1 205 2
AFTERNOON SESSION 3
(2:13 p.m.)
4 BERT MERRIT
- DUNN, resumed.
{
EXAMINATION (Continued) 6 BY MR. SELTZER:
7 Q
It's a fact, isn't it, that prior 8
to February 1978 B&W had submitted to the NRC g'
Licensing documents that describe the effectiveness 10 of core cooling during a small break loss of 11 coolant accident, isn't that correct?
12 A
Yes.
7-s 13 Q
For certain small break ioss of coolant 14 accidents, the Licensing documents submitted 15 required the continued operation of high-pressure 16 injection until a critical point in the loss 17 of coolant accident, isn't that correct?
18 A
That assumption was made in all s'uch 19 analyses.
20 Q
If in fact operators under certain small break loss of coolant accident conditions 21 22 were terminating high-pressure injection before 23 the ' critical point was reached, then the effective 24 cooling that was predicted in the Licensing documents 25 would not be maintained, isn't that true?
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1 Dunn 206
.(
2 A
Not necessarily.
3 Q
Isn't it true that in some instances, 4
if high-pressure injection were terminated
()
5 before the critical point effective cooling would 6
not be maintained?
7 A
That's true.
t 8
Q In --
9 A
Excuse me.
Effective cooling to the level i
10 predicted by the Licensing calculatLons t
11 would not be maintained.
12 Q
What is the level of effective
(^h x_/
13 cooling which the GDC required?
14 A
I can't answer your question.
15 Q
what is the level of effective cooling 16 which 50.46 requires?
17 A
50.46, Code of Federal Regulations, expresses 18 effective cooling in terms of four or Eive results i
i 19 of the accident measured by other param'eters, 20 people normally think it as clad temperature i
21 below 22 hundred degrees Fahrenheit.
22 Q
And that's the cladding on the fuel rods?
l l
23 A
Yes.
(
24 Q
You said there were four or five 25 critera?
l s
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I 1
Dunn 207 2
A Yes.
3 Q
Do all four or five go to maintaining 4
clad temperature below 2200 degrees?
(
5 A
No.
what were the other four or five?
6 Q
7 A
Local calculated oxidation of the clad 8
during the accident shall not exceed 17 percent.
9 The intigrated degree of cladding oxidation over 10 the entire surface of the core shall not 11 exceed one percent of the theoretical 12 maximum oxidation for zircalloy. The core shall
'g
~
13 be maintained in a condition amenable to core cooling 14 and a long-term cooling process should be established.
15 Q
Are those five parameters the 16 criteria of effective core cooling set forth in 17 10 CFR, Section 50.46, as you understand it?
18 A
Yes.
19 Q
Do the General Design criteria also 20 specify what is effective core cooling?
21 A
I am not sure.
k-22 Q
Do you ever do work in ECCS I
23 Analysis that requires compliance with the General
\\
24 Design criteria of the NRC?
t
\\/
l 25 A
I believe that as far as the emergency i
.l:
~
1 Dunn 208
~
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~
2 core cooling system is concerned, the General Design 3
criteria are very non-specific.
In practice, 4
meeting the criteria set forth in 10 CFR, 50.46 is k
5 recognized as providing systems in compliance with 6
the General Design criteria.
7 Q
Do you ever do work in your ECCS 8
Analysis Unit that requires conformance to the 9
NRC Standard Review Plan?
10 A
No.
E 11 Q
Do you ever do work in your unit 12 A
Excuse me.
I made a mistake.
O' 13 The answer to the previous question 14 should have been yes.
15 Q
In other words, you do work in 16 which you attempt to confo rm to the criteria l
17 of the Standard Review Plan?
18 A
Do work in which we will comply with some 19 Standard Review Plans.
20 Q
Which Standard Review Plans?
21 A
That would depend on the type of analysis l
22 that we were performing.
I would be talking l
23 most often about responsibilities for containment 24 calculations, internal forcing functions i
25 calculations, subcompartment calculations.
L
1 Dunn 209 2
Q Did you say internal forcing functions?
A Y e s.-
3 4
Q Do you ever concern yourself in the ECCS k
Analysis Unit with the single failure criteria?
5 A
We apply such a criteria to our work.
6 7
Q Do you try to apply it so that you can 8
determine whether no single failure results in a loss of effective core cooling?
9 10 MR. FISKE:
Are you talking 11 n w or pre-Three Mile Island or ever?
12 MR. SELTZER:
Ever.
-(:)
13 A
No.
14 Q
How do you apply it?
A The Licensing basis of the plant is constructed 15 4
16 around a bounding single failure made up of one 1
17 complete train of emergency systems considered to be 18 out of service during the accident.
19 Q
Do you do analyses in your unit of 20 multiple casualties?
A We have.
21 l
Q Do you do analyses of multiple 33 23 casualties in which after one train is assumed to
)
24 be out of service, a subsequent casualty affects the operation of the remaining train?
25 j.
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1 Dunn 210
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A I don't believe I would term them analyses.
3 Q
What would you call them?
4 A
We have passed opinions on the results
('
5 of those types of things.
6 Q
Do you mean pass an opinion?
7 A
Expressed an opinion.
8 Q
What do you express an opinion on?
9 What have you expressed an opinion on?
10 A
Can we have that qualified a little bit?
11 Q
You said that " pass an opinion" meant 12 have expressed an opinion, and I want to.now O
's 13 get back to what is it that you have expressed an 14 opinion on with respect to multiple casualties 15 occurring.
16 You said you didn't do analyses, but 17 you have passed opinions?
l 18 A
You gave me a very specific mult[ple casualty.
j 19 Q
O.K.
20 A
And we have expressed opinions on, for example, i
B 21 the time required for a total core boil-off with no 1
22 ECCS whatsoever.
That would be a multiple casualty i
i 23 like you discussed.
- ()
24 Q
You said you passed an opinion on that L
25 but you haven't done an analysis of it?
l A
A
,,m
-4,
1 Dunn 211 0
2 A
No.
3 Q
No what?
4 A-No, we have not done a detailed analysis k
5 of that.
6 Q
At the time you wrote GPU Exhibit 78 7
marked for identification to Jim Taylor, you were i
4 8
referring to the termination of high-pressure 9
injection in response to an indicated high-pressurizer 10 water level, right?
e 11 A
I was talking about the termination of i
12 high-presure injection during the September 24th n/
~
\\-
13 Toledo incident.
14 Q
And you indicate in the beginning 15 of the second paragraph that it was terminated due to 16 "an apparent system recovery indicated by 17 high level within the pressurizer," do you see that?
18 A
Yes.
19 Q
If high-pressure injection is terminated 20 at that time and not resumed, would the ability to 21 keep the core effectively cooled within the 22 criteria of Section 50.46 be imperiled?
23 MR. FISKE:
Could I hear the question
[)D 24 again, please.
~.
25 (Question read by the reporter.)
'e+
m e
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Dunn 212
+
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A Not necesarily.
3 Q
In a reactor that had been at full 1
4 load immediately prior to the start of such a i
5' transient, would the ability of the core to 6
continued to be effectively cooled be imperiled?
7 A
Not necesarily.
8 Q
Under certain circumstances would it be?
9 A
Under the assumption that we are talking about 10 the events as they occurred at Toledo on 11 September 24th, 1977 under certain circumstances, 12 the ability to cool the core would be imperiled.
' /-
13 Q
What are the circumstnac s that would 14 lead to the ability to cool the core being 15 imperiled?
16 MR. FISKE:
Are you asking Mr. Dunn 17 for what was in his mind at the t.i.me he wrote 18 his memo?
19 MR. FISKE:
Yes.
20 A
As an example, the block valve for the PORV 21 in this accident was closed at 20 minutes.
Had 22 that block valve remained open for an extended 23 period of time, the ability to cool the core
(
24 would have been imperiled.should something have 25 happened to the reactor coolant pumps.
1 Dunn 213 bu 2
Q You mean if there was a loss of off-site i
3 power, for example?
4 A-That would be one possible way to 5
terminate reactor coolant pump f unction.
6 Q
If the reactor coolant pumps were 7
manually arrested and couldn't be restarted, 8
would that be another?
9 A
Yes.
10 Q
Are you saying that t
that would 1
11 imperil effective core cooling in the context t
12 of the Davis-Besse plant which was only at 9 percent O
13 of full power when the transient began?
14 A
I had thought we were talking about a plant 15 that was at full power.
I believe my answer would be 16 as good at 9 percent power.
f 17 Q
You mean your answer would be the came?
18 A
Yes.
I 19 Q
At the conclusion of the second paragraph
(
l 20 o f GPU Exhibit 78 marked for identification, you 21 said, "Had this event occurred in a reactor at
- {
l 22 full power with other than insignificant burnup it 23 is quite possible, perhaps probable, that core
/~N
(_)
24 uncovery and possible fuel damage would have t-25 resulted."
i l.
L* *:.,
^
1 Dunn 214
/~S U.
2 Were you assuming when you made that 3
statement that the scenario at Davis-Besse was 4
the same as it was, that the sequence of events was
('
5 the same except that the reactor was at full power 6
with other than insignificant burnup?
7 A
For the purposes of the sentence I was 8
enhancing the result to some extent; it would have 9
also been a requirement to have had the PORV opened 10 for a somewhat extended period of time over the 11 events of that day.
12 Q
When you say " opened for some extended 13 period of time," do you mean longer han the 20 minutes 14 it was open without the block valve shut?
15 A
Yes.
16 Q
Have you ever done or seen any 17 analysis or calculations of how long a, block 18 valve would have to remain open for the'.
19 consequences that you have described here 20 to occur?
21 MR. FISKE:
"The consequences" being 22 "quite possible, perhaps probable, that 23 core uncovery and possible fuel damage j
24 would have resulted"?
25 MR. SELTZER:
Yes.
1 Dunn 215 2
A I don't believe so.
3 Q
When you wrote GPU Exhibit 78 to the 4
Manager of Licensing, Jim Taylor, did it occur 5
to you that you were raising a licensing concern 6
with him since the termination of high-pressure 7
injection could imperil the ability of the plant 8
to keep the core effectively cooled within the g
requirements of 50.467 10 A
No.
t 11 Q
Is that an issue that you believe 12 you discussed with Jim Taylor in your telephone f"
k-13 conversation with him shortly after February 9th?
14 A
No.
15 Q
Has it ever occurred to you that 16 it raises licensing concerns?
17 MR. FISKE:
Well, I will object to 18 that question.
~
19 Q
Have you ever discussed with anybody 20 that the inability to keep the core effectively 21 cooled because of a premature termination of 22 high-pressure injection can imperil the ability to 23 cool to the levels required by Section 50.467
(
24 A
I believe so.
25 Q
With whom have you discussed that?
^^
1 Dunn
~
216 r~s U
2 First let me ask you, have you had 3
such discussion prior to the Three Mile Island 4
accident?
)
(
5 A
I believe so.
6 Q
with whom?
7 A
Mr. Eric Swanson, Mr. Joe Kelly, Don Roy, 8
and Jim Taylor; Bob Jones.
9 Q
Were the discussions that you had, 10 discussions that you had simultaneously with 11 all of them present or were those several l2 different discussions?
(~
l
}'
la A
These were.the same discussions I have 14 testified about earlier.
15 Q
In other words, all of these are 16 discussions which you had after the Davis-Besse 17 event of September 24th, 1977 and befor,e the 18 Three Mile Island accident?
19 A
All of these discussions were.
l i
f l
20 Q
When did you discuss the inability l
1 91 to cool effectively to the requirements of section l
C
~
50.4'6 with Mr. Taylor?
22 23 A
I think I may have answered inappropriately l
)
24 a minute ago.
l 25 The discussion with Mr. Taylor was t
>ma n y
a em-w m----re w, - - -
n
-9 mv-
I 1
Dunn 217 2
in the phone conversation whic I said I believe 3
I had, so I can't state with assurance that 4
I had -- that discussion with Mr. Taylor would 5
have been during that telephone conversation.
(
6 Q
You believe during a telephone 7
conversation shortly after you received your 8
February 9, 1978 memo you discussed with him the g
fact that if high-pressure injection were 10 terminated during a small break loss of coolant t
11 accident, it could imperil the ability to maintain 12 effective core cooling up to the requirements of
()
13 section 50.46, is that your belief? ~
14 A
My best belief is that the communication 15 said that the cladding temperatures would be 16 higher than calculated for the licensing basis 17 and could in fact proceed to extrene 18 temperature which would violate the requirements 19 of 10 CFR 50.46 20 MR. FISKE:
I think there is one J
21 aspect of the question that may be a little 22 confusing.
23 When you asked him whether he 24 discussed the fact that terminating HPI O
25 could affect the ability to cool the core
" 2.1
4 1
Dunn 218 2
within the requirements of 50.46, I am 3
not sure it's clear whether you are asking 4
him whether he actually referred to that
((
5 conclusion or whether he referred to facts 6
from which you could draw that conclusion.
7 I think his answer perhaps illustrates 8
that.
9 Q
In talking with Jim Taylor in the 10 conversation you believe you had with him, you 11 discussed the effects of such a sequence of 12 events on cladding temperature, right?
(~())
13 A
Yes.
s 14 Q
Did either of you state, to the 15 best of your recollection, that such a rise in 16 cladding termpeatures would exceed the permissible 17 upper limit under Section 50.467 18 A
I don't believe so.
19 Q
From your familiarity with Jim Taylor, i
20 would he be well aware that extreme claddi'ng 21 temperatures.would violate the criteria of l
22 Section 50.467 i
23 MR. FISIE:
I object to that question.
l (
24 I don't think Mr. Dunn should have to answer l
25 that.
l e
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1 Dunn 219 n
2 Q
From your experience -- and I mean 3
your actual experience dealing with Jim Taylor -- has 4.
he shown by his actions, including his statements
-f, 5
and his writings, that he is somebody who A
.g 7-u.\\,'
6 understands the criteria of Section 50.467 Tf e.
.s c '-
7 MR. FISKE:
I am going to object to
( 4 8 {
that, Mr. Seltzar.
That's an extremely broad s..
h-9
question.
, 's
\\ '!0 MR. SELTZER:
I will limit it, at your
's i
\\
11 suggestion, Bob, to the five criteria s
12 of effective core cooling.
^13 This is somebody who said he had s
x 14 numerous dealings with Jim Taylor in
\\
15, licensing contexts.
u s
16 MR. FISKE:
If you want to ask him y
s 17 whether he has discussed those requirements with 18 Mr. Taylor, I have no problem.
~
19 MR. SELTZER:
.T will start there, thanks.
20 MR. FISKE:
But you are asking him to form s i a co'nclusion which I am not sure that he is 21 s
22
any more qualified to form than anyone else.
g 23 MR. SELTZER:
I appreciate your help.
5
(~
24 Q
x Have you dealt with Jim Taylor on U}l
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g 25
'i licensing matters where compliance with Section 50.46
?
3
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1 Dunn 220
~
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/ '-
2 was an issue?
s 3
A Yes.
4 Q
~Have you dealt with Him Taylor where 4
1
(*
5 complying with the requirements of effective core 6
cooling under 50.46 was a significant issue?
7 A
Yes.
8 Q
Did you converse with Jim Taylor about 9
the several criteria for effective core cooling 10 under section 50.467 j
11 A
Yes.
12 Q
Did you converse with him about the
)
13 fact that maximum cladding temperatu e was one
~
14
.of the effective criteria for effective core 15 cooling under section 50.46?
That was a little 16 less than fully articulate.
17 Have you conversed with Jim 18 Taylor about the fact that maintaining cladding 19 temperatures less than a certain maximum is one 20 of the criteria for effective core cooling 21 under Section 50.46?
22 A
Yes.
23 Q
From those conversations with Taylor, V("N 24 do you believe that Taylor understands the criterion 25 of maintaining cladding temperature less than 2200 i
l
' ' (
'f f~!
- - ^ ~ '
~~ ' ~ ~ ~ -
1 Dunn 221 2
degrees?
3 MR. FISKE:
I am going to object to 4
that again, Mr. Seltzer.
The facts are
((
5 the facts and you can ask Mr. Taylor.
6 MR. SELTZER:
I can ask Taylor, but I
7 I think I,am entitled to ask other people 8
whether --
9 MR. FISKE:
Whether he thinks he 10
+
knows?
11 MR. SELTZER:
Yes.
12 MR. FISKE: I don't think you can do ON 13 that.
14 MR. SELTZER:
I am flabbergasted if you are 15 -
concerned that somebody is going to say that the 16 Manager of Licensing at the great Babcock &
17 Wilcox Company doesn't understand the core 4
18 cooling criteria of 10 CFR 50.46.
19 MR. FISKE:
Believe me, Mr. Seltzer, 20 I invite you to ask Mr. Taylor and 21 you will get a forthright answer.
22 As a matter of principle, I don't 23 think it is proper to ask Mr. Dunn or any
()
24 other witness to speculate what he thinks 25 somebody else knows about something.
i
..~.C._,___.-.
..,...__m.__
1 Dunn 222 2
MR. SELTZER:
I am not asking him 3
t speculate.
4 I am asking from statements that Jim
(
5 Taylor made and actions Jim Taylor has taken, has 6
Jim Taylor evidenced a. comprehension of:this 7
particula:r aspect of 10 CFR 50.46.
8 I think people can ask whether they have 9
seen Reggie Jackson exhibit proper fielding 10 talents in right field at Yankpe Stadium and it 11 is not a proper objection to say, "Why don't 12 you ask Mr. Jackson?"
O k_)
13 Now, this man has witnesied Jim Taylor 14 displaying certain skills in discussing 15 and using the tools of 10 CFR 50.46.
I would 16 like to ask his conclusion whether, from the l
17 display that he observed, Taylor was showing i
18 a comprehension of that.
i 19 I think it is pretty elemental.
20 MR. FISKE:
I don't think it's a big 21 deal, so go ahead.
23 Q
Have you ever seen Reggie Jackson
~
24 field a ball at Yankee Stadium?
25 A
No.
T
-w e
, ~ - - - - --,,
, - - - ~.,.
1 Dunn 223 b
\\'
2 Q
So I won't ask you about that.
3
, You have had conversations with Jim 4
Taylor regarding maximum cladding temperatures
(
5 permitted under the criteria of 50.46, right?
6 A
Yes.
7 Q
From what you have observed in 8
Taylor's statements and writings, does Taylor show 9
a comprehension of the maximum clad. temperature 10 permitted for effective core cooling under 11 Section 50.467 12 MR. FISKE:
On this one I will settle
[ )h
(,
13 for an obj ection as to form.
14 Q
You may answer.,
15 THE WITNESS:
Does that mean I may 16 answer?
17 MR. FISKE:
You may answer.
18 A
Yes.
19 Q
You said in your earlier-testimony 20 that you talked with Taylor about the fact that 21 when you terminate high-pressure injection under 22 the circumstances described in GPU 78 it would 23 lead to extremes in cladding temperature.
'~'
24 By the use of the word " extremes," did 25 you mean temperatures in excess of 2200 degrees?
+*
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_.,,..-,u-
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1 Dunn 224 G
i a
V 2
A In a general way, depending on how long 3
the emergency core cooling system was terminated 4
prior to the critical time during an accident,
{,
the temperatures could be in excess of 2200 degrees 5
6 Fahrenheit, s
7
/
Q Is that what you were intending to 8
convey to Mr. Taylor in your conversation with him?
9 A
That was part of it.
10 Q
In your conversations with Don Roy 11 in which you say you discussed the fact that 12 effective core cooling would be imperiled by
)
13 the inappropriate termination of high-pressure 14 injection, did you or he, to the best of your 15 recollection, ever specifically mention compliance 16 with Section 50.467 17 A
Not to my knowledge.
18
~
Q In convarsations with Eric Swanson, 19 did you ever mention compliance with Section 50.46?
20 A
Not to my knowledge.
21 Q
In your conversations with Kelly c
22 or with Jones regarding the problem of premature 23 termination of high-pressure injection, did p/
24 you ever mention or did they ever mention to you
(._
25 that this could imperil compliance with 50.467 l
1 Dunn 225
_,/.
2 A
I do not believe so.
s 3
Q From your work with it,-is it your 4
understanding that Section 50.46 sets forth 5
criteria which have to be met in order for a
({
6 Plant to be licensed?
7 A
No.
8 Q
What, if anything, is the relationship 9
between Section 50.46 and licensability of a nuclear 10 plant in the United States of America?
(
11 A
50.46 puts forth criteria which must be 12 met by certain plants to receive licenses for 13 operations in the United States.
14 Q
Is it correct that all of the 177 and 15 205 nuclear plants supplied by B&W to operators i
16 in the United States have had to meet the criteria 17 of Section 50.46 in order to be licensed?
18 A
No.
19 Q-WHich ones have not had to meet 20 50.467 l
l 21 A
I am not sure.
I 22 Q
How do you know that there are some 23 that haven't had to comply with it?
24 A
10 CFR 50.46 was issued at a time after l
25 which certain of our plants had already operated, l
r
1 Dunn 226 k-2 operatad under another rule for a period of time.
3 Q
Do you believe that Davis-Besse has 4
had to comply wth 50.467 (1
5 A
Yes.
6 Q
Do you believe that Three Mile 7
Island Unit 2 had to comply with it?
8 A
Yes.
9 Q
You said that in the first sentence 10 of your memo to Jim Taylor, GPU Exhib t 78, "This 11 memo addresses a serious concern within ECCS Analysis."
12 Do you see that?
13 A
Yes.
14 Q
With what other members of the ECCS 15 Analysis Unit had you discussed the serious concern 16 addressed by this memo?
~
17 A
Mr. Bob Jones.
18 Q
Any others?
~
t 19 A
I'm not sure.
20 Q
Do you believe that there were others 21 whose names you can't positively recollect?
22 A
I don't know.
23 Q
Was it your practice in 1977 and 1978 24 to hold periodic meetings among some or all of 25 the members of the staff of ECCS Analysis?
1 Dunn 227 J
2 A
No.
3 Q
Did you ever hold team' meetings?
4 A
Yes.
(,
5 Q
Do you conduct them on a non-periodic 6
basis?
7 A
Yes.
8 Q
Did you have any meetings of some or 9
all of the members of ECCS Analysis prior to February 10 9, 1978 when you discussed any of thq implications 11 of the Davis-Besse transient or termination of 12 high-pressure injection?
13 A
I don't know.
l 14 Q
Do you believe that you did?
I l
15 MR. FISKE:
If you put it in terms 16 of recollection, I won't object.
17 Q
Do you have any recollection of such a 18 conversation?
19 A
I do not recall one.
20 (Recess taken.)
21 BY MR. SELTZER:
22 Q
In your telephone conversation with 23 Taylor which you believe took place, did Taylor
(~)g 24 say anything to indicate whether he had previously 25 been informed of the Davis-Besse transient of l
~
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1 Dunn 228 O
2 September 24, 19777 3
A I don't recall.
4 Q
Do you remember whether Jim Taylor was
{
5 at the Training Room B meeting. shortly after the 6
Davis-Besse transient?
7 A
I do not remember.
8 Q
At any time during your conversation 9
with Jim Taylor regarding your February 9 memorandum, 10 did Taylor say anything to you whichtin words or 11 substance informed you of any action which Taylor 12 was going to take or was considering taking as a
13 result of your memorandum?
14 A
Yes.
15 Q
What did he say in words or substance?
16 A
In substance that he was going to ask Nuclear 17 Service to follow up on the issue.
18
~
Q Did he indicate how he was going to ask 19 them to follow up?
~
20 A
No.
21 Q
Did he 22 A
Not that I recall.
23 Q
Do you recall whether he indicated 24 who in Nuclear Service he was going to ask to do the 25 following up?
wwv
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r, t
+,p+
y N
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m--r-
+-=u-
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k 1
Dunn 229 0
(_s!
2 A
I don't believe he did.
3 Q
, What, if anything, was'your' response 4
to that statement by Mr. Taylor?
(
5 A
I agreed.
6 Q
You agreed that that would be a good 7
next step to take, is that right?
8 A
That that would be a next step to take.
9 Q
You concluded your memo, GPU 10 Exhibit 78, by stating, "I believe this is a very 11 serious matter and deserves our prompt attention and 12 correction."
D( j) 13 Do you see that?
'~
14 A
Yes.
15 Q
.When you used the pronoun "our,"
were 16 you referring to Babcock & Wilcox?
17 A
Yes.
18 Q
I take it when you made that statement, 19 you believed that that was a proper conclusion?
'20 A
That what was a proper conclusion?
21 Q
That this is a very serious matter and 22 deserves B&W's prompt attention and correct.
23 A
Yes.
r-24 MR. SELTZER:
I would like to mark as
(_g 25 GPU~ Exhibit 79 for identification your next S e=am 4
-,,w..
o,.-
I Dunn 230 m
s 2
correspondence with Jim Taylor dated 3
February 16, 1978, subject:
" Operator 4
Interruption of High-Pressure Injection."
()
5 (Memorandum dated February.16,. 1978, 6
subject:
" Operator Interruption of 7
High-Pressure Injection" marked 8
GPU Exhibit No. 79 for identification 9
as of this date.)
10 Q
Is GPU Exhibit 79 a copy,of a memorandum 11 which you sent to Jim Taylor on or about 12 February 16, 19787
()
13 A
Yes.
14 Q
Did you also send a copy to each of 15 the individuals listed after "cc:" at the bottom of 16~
the page?
17 A
I believe so.
18 Q
Who is that chap, R.
Davis?-
19 A
That would be Ron Davis.
20 Q
Was he the Manager of Control Analysis 1
21 at that time?
i l
22 A
At that time.
23 Q
Why did you decide to add him to the 24 distribution?
25 A
I don't recall.
t
..---y,-
.c w
1 Dunn 231 s
2 Q
Control Analysis is a unit in what 3
section?
4 A
The Plant Design Section.
1
(
5 g
Did you ever get any response from 6
Davis to your memorandum?
7 A
Not that I recall.
O Q
You begin your February 16 memorandum 9
by telling Jim Taylor, "In review of my earlier 10 memo on this subject, dated February
- 1978, 11 Field Service has recommended the following 12 procedure for terminating h'igh-pressure injection m
)
13 following a LOCA."
14 Is Field' Service different from Customer 15 Service?
^
16 A
It may be.
Not in my terminology.
i 17 Q
So in your terminology, Field Service, I
IS Customer Service, and Nuclear Service a r'e tautologies?
19 MR. FISKE:
That means they are the same?
20 MR. SELTZER:
Yes.
21 A
Yes.
22 Q
Who in Field Service had reviewed your 23 earlier memorandum?
(
24 A
I don't know.
25 g
Do you have a belief as to whom it was.
m
I Dunn 232 b)
(_
2 who recommended the following procedure for terminating 3
high-pressure injection?
4 A
My belief, the person that participated
{
5 with me, and in fact recommended parts of this recipe, 6
was Mr. Kal Goslow.
7 Q
What were the circumstances under which 8
you got together with Goslow to discuss this?
a g
A As I recall, Kal telephoned me indicating that 10 he was looking at my February 9th memo and wanted to
(
11 have a discussion, and we met shortly'thereafter in my 12 office.
()
13 Q
Did Kal Goslow indicate to you from 14 whom he had received a copy of your February 9 15 memorandum?.
16 A
No.
~
l 17 Q
What was Kal Goslow's contribution?
18 A
To the February 16th memo?
19 Q
Yes.
20 A
Basically the outline of the second allowable l
21 condition for high-pressure injection termination 22 was Mr. Gowlow's.
23 Q
In other words, instead of keying the 21 second criterion to a specific temperature or O
25 a specific pressure, he suggested tying it to some
1 Dunn 233
/~}
~
2 safe margin below saturation?
3 A
To my understanding, that'e correct.
4 Q
Who was it who thought 50 degrees was
({
5 a nice round number to take for the subcooling 6
margin?
7 MR. FISKE:
You mean who recommended the 8
50 degrees?
9 MR. SELTZER:
Exactly.
10 A
At this time I can't recall.
g 11 Q
Did Goslow indicate to you that he 12 had discussed your February 9 recipe with 13 anyone else in his section?
14 A
I don't recall.
15 Q
Did he indicate that he had discussed
~
16 any of your concern regarding high-pressure 17 injection with anyone in customer Service, 18 Nuclear Service, Field Service?
19 A
I dont re' call.
l
~
20 Q
Why'did you pick ten minutes as the 21 appropriate time period in both paragraphs 1 and 2 22 of the recipe?
23 MR. FISKE:
I object to the form of 24 the question.
25 MR. SELTZER:
Why?
l
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' ' ' ' ' ' ~ ~ ~ ' ' ' ' ' ' ' ~ " ' ' ' ' ~ "
I Dunn 234 2
MR. FISKE:
Well, I don't think.he did 3
pick, ten minutes in the second part (indicating).
4 MR. SELTZER:
I suggest that possibly ten
(
5 minutes will be the adequate time.
6 Q
I will stand corrected.
I am just 7
asking how did you come up with ten mintues as being 8
the time that you inserted for any purpose in 9
paragraphs 1 and 2.
10 A
It was a subjective decision.
11 Q
On April 2, 1979, B&W sent out 12 to all of its customers guidelines for when it is
()
13 appropriate to terminate high-pressure injection.
14 Are you aware of that?
15 A
April of '79?
16 Q
Yes.
17 A
Yes.
18 Q
The April 4, 1979 prescripti~on or; as you 19 have called it, recipe was verbatim, the-items 1 20 and 2 that you have here except that a time period 21 of 20 minutes was used instead of ten minutes, 22 isn't that correct?
23 A
No.
24 (Recess taken.)
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e m-
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1 Dunn 235 O
\\/
2 BY MR. SELTZER:
3 Q
. In any of your monthly ' reports 4
did you ever make reference to the area of concern
(
5 described in your February 9 or February 16 memoranda?
6 A
I don't know.
7 Q
Do you have any belief as to whether 8
you did?
9 A
No.
Not one way or the other.
10 Q
subsequent to the telephqne conversation 11 with Mr. Taylor, did you ever follow up with him, 12 prior to the Three Mile Island accident, to see
~
(,-
13 what, if anything, he had done?
14 A
Not other than this memo on February 16th.
15 Q
Were there occasions between February 16, 16 1978 and March 26, 1978 when you spoke with Jim 17 Taylor?
18 A
Yes.
~
19 Q
were there occasions when you spoke 20 to him face-to face?
21 A
Yes.
22 Q
Did you assist him on licensing matters 23 during that period of approximately a year and one f~N 24 month?
25 A
Yes.
4 F
1 Dunn 236 (N- '
2-Q Did you assist him on licensing matters 3
on more than one plant?
4 A
Yes.
(
5 g
Is Taylor somebody that you felt 6
you could converse with informally?
7 A
Yes.
0 Q
Prior to the Three Mile Island 9
accident, is he somebody into whose office you 10 could stop for conversation without an 11 appointment?
12 A
Yes.
13 Q
Did you from time to' time?
14 A
I have done that from time to time.
15 Q
Did he sometimes stop into your l
16 office to talk?
17 A
Yes.
18 Q
During the period from Febrdary 16, 19 1978 through March 28, 1979, did you ever ask Jim 20 Taylor what he had done with the ideas you 21 had expressed in your February 9th and 16th memoranda 22 to him?
23 A
Not that I recall.
(~N 24 Q
Did he ever mention anyt.hing to you 25 during that period about what he was doing with
1 Dunn 237 O.
{
2 respect to either of your memoranda?
3 A
Not that I recall.
4 Q
What was Kal Goslow's reaction
(,
5 to your concern as he expressed it to you?
6 A
I don't know that he expressed his reaction 7
to me.
8 Q
Did he say anything that indicated that 9
he thought advice should be sent out to customers 10 regarding when it would be appropriate to terminate 11 high-pressure injection?
12 A
No.
()
13 Q
I take it he indicated to you that he 14 knew the recipe that you were preparing was a 15 recipe to be sent to operators of B&W plants, 16 is that a fair statement?
17 A
You should ask Kal.
18 Q
I will tell him you sent him.
19 After February 16, 1978, what was 20 the next involvement you had with any action taken 2
i 21 on the concerns you were expressing in GPU
\\
22 Exhibits 78 and 797 I
l 23 A
Shortly following the Three Mile 24 Island accident?
I
)
s 25 Q
Yes.
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1 Dunn 238 O
2 For more than a year after February 16, 3
1978, did you speak to anybody about the concerns 4
that you had voiced in the Exhibits 78 and 79?
(
5 A
I don't believe so.
6 Q
Did you write to anybody or did 7
anyone write to you about the concerns you had 8
voiced in the GPU Exhibits 78 and 79 marked for 9
identification?
10 A
I did not write to anybody and(I c'o n ' t 11 believe anybody wro'te to me.
12 Q
Except Hallman who gave you a
(,
13 copy of his August 3, 1978 memo to Karrasch, right?
14 A
Correct.
Hallman put me on distribution for 15 that memo.
16 Q
Did you take no further action after 17 sending the February 16 memo because you understood 18 that Taylor was going to be taking what$ver 19 further action was necessary?
20 A
No.
21 Q
Did you take no further action because 22 you believed Nuclear Service was going to be taking 23 whatever further action was necessary?
O 24 A
Yes.
25 Q
Did you have that belief because l
l
~~
1 Dunn 239 l
2 of what Taylor had told you over the telephone?
A No.
3 4
Q From what did you gain the belief that
((,
5 Nuclear Service would be taking whatever 6
action was necessary?
7 A
I am not sure how I get that belief.
8 Q
Is it possible that it came from 9
what Taylor had told you over the telephone?
10 MR. FISKE:
I object to the form
(
11 of the question.
12 Q
You may answer.
13 A
No.
14 Q
Is there anything else that you recall 15 that you would say was the source of that belief?
16 MR. FISKE:
I think he just'said he 17 doesn't know how.
18 MR. SELTZER:
I am just asking a 19 second time.
20 A
Would you repeat 21 THE WITNESS:
Can you read the question
~
22 back to me, please?
23 (Question read by the reporter.)
24 A
I don't know that I can answer that question.
V 25 Q
What is it about the question that Em
--.-----,,y.,._
,v.
1 Dunn 240 r
2 makes it difficult to answer?
3 A
The ','anything else that I recall that I 4
would say," that seems to require speculation.
((
5 Q
Is there anything else that you recall 6
that gave rise to that belief, that Nuclear 7
service was going to take further action with 8
regard to your concern?
9 A
The interaction between myself and Mr. Goslow 10 led me to that assumption.
t 11 Q
You mean somebody in Nuclear 12 Service must have given Kal Goslow the memo because O(_)
13 they thought it was a concern worth pursuing, is that 14 the assumption you were making?
15 A
No.
16 Q
Explain how your assumption worked, 17 please.
18 A
That's what I can't explain.
~
l 19 Q
So you are saying the appearance of l
20 Kal Goslow in your of fice with a copy of your 21 memorandum in his hand from February 9 and his l
22 desire to discuss it with you created in your mind 23 the assumption that Nuclear Service was going
{~}
24 to take some further action?
w/
25 A
That, and our follow-on agreement of an
{
ww*
AtWw-
1 Dunn 241
?\\
~
I alternate recipe which was for the most part 3
created by Mr. Goslow or someone else in Nuclear 4
Service and communicated to me by him.
5 Q
What do you mean when you say "our 6
I follow-on agreement"?
What was the agreement?
7 A
The words in the February 16th memo, item 2.
8 Q
Those were words which you had agreed 9
upon with Kal Goslow?
10 A
Yes.
g 11 Q
Kal Goslow isn't marked for 4 copy of 12 your February 16th memorandum.
()
13 '
Do you have any belief teat you sent 14 him a copy?
15 A
I don't recall.
16 Q
Do you have any belief that you sent
[
17 copies of the February 9th or 16th memorandum to 18 anybody who is not marked for copies on'those 19 memos?
~
l 20 MR. FISKE:
You mean recollection?
21 MR. SELTZER:
Yes.
22 A
I have no recollection one way or the other.
23 Q
Do you have any belief that you sent
(~N 24 it to people other than the listed copyees 25 and addressee?
/
1 Dunn 242 2
A No.
Not one way or the other.
.1 3
Q Prior to the Three Mile Island accident, 4
had you ever been asked to review an SPI before it 5
was sent out?
(
6 A
What is an SIP 7 7
Q A Site Instruction Package.
8 A
I don't know.
9 Q
Had you ever been asked before the 10 Three Mile Island accident to review any instructions 11 sent out by B&W to customers?
12 A
I don't recall.
()
13 MR. SELTZER:
I would like to have 14 marked as GPU Exhibit 80 for identification 15 Don Hallman's memo to Bruce Karrasch 16 with a copy to you and others dat'ed 17 August 3, 1978, subject:
Operator 18 Interruption of High-Pressure Injection 19 (HPI)."
r 20 (Memorandum to Bruce Karrasch from 4
21 Don Hallman dated August 3, 1978, subject 22
" Operator Interruption of High-Pressure 23 Injection (HP I) " marked GPU Exhibit No. 80
(-
24 for identification as of this date.)
\\,/
25 Q
Don Hallman says in the first sentence e
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1 Dunn 243
(~)
(_j 2
of GPU Exhibit 80, " References 1 and 2 (attached) 3 recommend a change in B&W's philosophy for 4
high-pressure injection system use during 5
low-pressure transients."
1 6
What is a low-pressure transient as 7
you understand its use here?
8 A
I'm not sure to the extent which it is used.
9 My interpretation would be that transient which 10 evolved to system conditions below normal.
L reherences to works 11 Q
References 1 and 2 are 12 that you authored, right?
(m) 13 A
Yes.
~
~
14 Q
Don Hallman gives you credit for 15 recommending a change in B&W's philosophy.
16 Do you see that?
17 A
Yes.
18 Q
Did you believe that what you were 19 recommending was a change in your company's i
20 philosophy?
21 A
I don't think I considered it that way.
22 Q
Do you think what you were recommending 23 was consistent with B&W's philosophy for the use S
24 of high-pressure injection?
%Y 25 A
I don't think I considered it relative to any e
_.,.-,,m
1 Dunn 244 (3
'N_)
2 B&W philosophy to decide one way or the other.
3 Q
you think Hallman was over-Do 4
intellectualizing the subject?
I 5
MR. FISKE:
I object to that.
g 6
MR. SELTZER:
I withdraw it.
7 MR. FISKE:
You just wanted to see if 8
I'was still awake.
/
9 (Laughter) 10 Q
Do you have any idea what Hallman was 11 referring to when he used the phrase "philosphy 12 for high-pressure injection system"?
i( )
~
13 A'
,No.
14 Q
I don't mean to cover terraine we covered 15 yesterday, but just let me set the stage.
16 You understand the August 3' memo from 17 Hallman is raising a concern about going solid, 18 right?
19 A
I would rather stick to his exact words.
20 Q
What do you understand Hallman's concern 21 is as expressed in GPU Exhibit 807 22 A
I would quote him.
23 Would you like me to do that?
24 Q
Whatever you think is necessary to d
25 correctly respond to the question.
wm-
1 Dunn 245 2
A A concern on what would happen if the pressurizar 3
goes solid with one or more HPI pumps continuing 4
to operate as to whether or not there would be 5
a pressure spike before the relief valves opened 6
which could cause damage to the RCS and a concern 7
over what damage would a water surge through the 8
relief valve discharge ~ piping and quench tank cause.
9 Q
At any time prior to the Three Mile 10 Island accident, did you and Bruce Karrasch 11 discuss Hallman's concerns as Hallman has expressed 12 ~
them in this memo?
( )
13 A
At any time prior to the Three' Mile Island 14 accident?
15 Not to my knowledge.
16 Q
At any time prior to the Th'ree Mile 17 Island accident, did you discuss Hallman's 18 concerns with anyone?
19 A
Not to my knowledge.
l 20 Q
At any time before the Three Mile Island 21 accident, did you discuss with anybody any concerns 22 or reservations regarding the prescriptions which 23 you had suggested in your February 16 memo?
(g 24 A
I am not sure.
V 25 Q
At any time before the Three Mile 1
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1 Dunn 246
['}
(_/
2 Isiand accident and after the February 16 memo, 3
did you learn that anyone had'any reservations 4
about the prescription which you had advanced?
5 A
In the February 16th memo?
)
6 Q
Yes.
7 A
No.
8 Q
so I take it that if you never learned 9
after February 16 that anyone had any reservations 10 about what you had expressed there th,at you 11 didn't have any discussion with anybody after 12 February 16 about such rdservations, is that
()
13 correct?
14 A
Prior to March 26th, 1979.
15 Q
You mean that is correct, prior to 16 March 26th, 19797
~
17 A
Yes.
18 Q
Were you on vacation in August of 1978?
19 A
I don't recall.
20 (Continued on next page.)
21 L
22 24
~
s_/
25
.,,,p-
247
+
1 Ounn
\\
2 Q
Do you have any recollection of t[t 3
receivingGPU Exhibit 80 in or about early August
~
4 of 19787 N
5 A
No.
Q ' \\ What is your normal practice when you
'y 6
7 receive memorfsnda addressed to you?
What do you 3
8 do with them'?s s
f g
MR. FISKE:
.I don't mean to be i
10 technical.,,but by " address to," do you mean t
11 any maiso' he gets - a copy of ?
12
' MR. SELTZER: Yes.
s O'
13 A
The mail, which may be more than memoranda, 1
14 is sortediby my secretary and placed in one of two 15 reesivingSaskets for my attention.
l 16 Q
What is the difference between the two 17 receivin'g baskets?
l
~
l 18 MR. FISKE:
Are you talking about the 19 Procedure back in or about August of 19787 20 Right?
it 21 MR. SELTZER:
Yes.
.(
l 22' A
.An attempt to sort out information 23
' requiring my attention or action and information i
24 passed ons for -- letters passed on for information.
l l
l g3 In general, memos or letters written
+
e
248 1
Dunn i
2 directly to me would be in the higher priority i
3 review box; where I had been copied for i
J 5
4 information, it would be in the other box.
)
5 Q
what was it your practice to do in 6
or about mid-1978 with memos that were in the 7
information box?
1 8
A To skim them for content as soon as 9
possible in view that the other information I 10 would need to attend to, the other information 4
e i
11 received as well as the other obligations of my 12 job.
l f()
13 Q
If you had received and rea,d a memo
~
14 like GPU Exhibit 80 marked for identification, 15 what would have been your normal practice on 16 what you would do with it after you finished 17 reading it if you had a normal practice?
t 18 MR. FISKE:
I will object.to that.
f 19 I don't see how there can be a normal i
20 practice.. Every memo is different in terms 21 of the subject matter.
I think this is j
i 22 clearly a hypothetical.
23 Q
Do you keep subject files in which f
24 you file correspondence you receive?
25 A
From time to time I have kept such files.
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1 Dunn 249 2
Q Have you ever made any attempt to 3
locate a copy of GPU Exhibit 80 in them?
4 A
No.
5 g
Do you sometimes do that with memos 6
that you have received, meaning do you sometimes 7
forward them to people in your unit?
8 A
Yes.
9 Q
Have you ever asked your secretary 10 to try to find your copy of GPU Exhibit 807 i
11 A
No.
12 Q
Will you take a look, please, at
()
13 GPU Exhibit 75 marked for identification.
Will you 4
14 turn to your resume.
15 Did you prepare your resume which is 16 included there?
17 A
Yes.
18 Q
Approximately when was that resume 19 prepared?
20 A
I really don't know.
Within a year.
21 Q
Within the past year?
22 A
I think so.
23 Q
Will you turn to the second page of 24 your resume.
At the top of the page it states i
25 that for six years you have been Unit Manager of i
s
+
l
1 1
Dunn 250 s /-
2 Emergency Core Cooling System Analysis.
3 Is what appears in the next two 4
paragraphs below that I am sorry, the next 5
four paragraphs including the paragraph below the l
6 note, that is a description of the responsibilities 7
which you have. discharged as Manager of the 8
EECS Analysis Unit?
9 A
It's a reasonable practical description as 10 opposed to a job description or pogition 11 description.
12 Q
Y-ou say at the beginning of the first 13 paragraph that you have been " Responsible for
~
14 technical evaluation of performance of the 15 emergency core cooling system for light water 16 nuclear reactors during loss-of-coolant accident 17 conditions."
1 18 You also say you have been~ responsible 19 for communicating those evaluations to' operators 20 and owners and that you have handled management 21 of customer interfaces related to such evaluations.
22 What do you mean by " customer 23 interfaces related to such evaluations"?
/~N 24 A
Explanations of our work to customers on a 25 technical level, negotiation of the requirements
- ia l
1 Dunn 251 O
k) 2 of the customer input on a technical level.
3 Q
You also say that you,have been re-4 responsible for " creation and implementation of 5
Company policy and positions on ECCS performance
)
6 and related technical issues."
7 Could you explain to what extent you 8
have been responsible for creation and implementation 9
of Company policy and positions?
10 A
I would be a key consultant to the Licensing
(
11 Department who is literally charged'with the 12 responsibility for the creation of company policies
()
13 in that area in deciding what our policy should 14 be in areas that require the policy ~.
15 Q
What do you mean by a company policy 16 on ECCS performance?
17 Let me ask you perhaps a simpler 18 question and we will come back to that, question.
19 Is don't shut off the high, pressure 20 injection unless you are 50 degrees subcooled a i
21 current B&W policy on ECCS performance?
k.
l 22 A
I would say it is a standard B&W 23 recommendation but I would not upgrade it to the s
24 word policy.
25 Q
Maybe we are creeping up on what a
' _ -. i M.
..,-a
i Dunn 252
(_j 2
policy is then.
3 Can you tell me now what rises to the 4
level of company policy on ECCS performance?
5 A
There are not too many policies directly 6
on ECCS performance with the regulations
.j 7 involved in the area.
It is not rea'11y required to 8
add further guidance.
9 Q
So you really weren't sdying you 10 were responsible for very much when you said you
(
11 were responsible for creation and imp 5ementation 12 of company policy'on ECCS performance, is that right?
(
13 MR. FISKE:
Well, that's -a little
~
l 14 argumentative.
15 MR. SELTZER:
I am just trying to 16 understand whether those words have content 17 or they are devoid of content.
l 18 A
within the area of evaluation, there is the 19 procedure with which you will perform an-evaluation.
20 That procedure becomes part of the policy.
21 g
Do you notice at-the bottom'of'the page 22 you have the heading, "The following major 23 accomplishments were made during this period "
l l
24 Do you see that?
25 A
Yes.
-g'94-J<
I Dunn 253 2
Q Major Accomplishment (c) reads, 3
" specification of operational procedures for handling 4
of loss of coolant accidents (these procedures 5
may have prevented a second incident similar to 6
TMI-2 on at least one occasion since March 28, 1978.."
7 I take it that should ha' March 28, 1979.
8 A
yes.
9 Q
Am I correct that the second incident 10 that you were referring to there is the Crystal t
11 River incident?
12 A
yes.
~
(v) 13 Q
And are the procedures t h'a t you claim 14 were a major accomplishment the small break 15 guidelines?
Maybe I shouldn't put words in your 16 mouth
~
3 17 What are the operational procedures 18 for handling of loss of coolant accidents that 19 you referred to in item (c)?
20 A
I would be referring -- I am referring 21 to the culmination of the efforts to communicate 22 appropriate high-p*; essure injection operation 23 philosophy to the operators.
This involves the 24 instructions issued by the NRC, recommendations and gg
\\_
25 letters issued by ourselves, the small break operating whew
1 Dunn 254 2
guidelines as well as Training, and I don't mean to 3
take credit for all of that, but a' good portion.
4 Q
Are the guts of that the recipe as 5
you have called it for when it is appropriate 6
to terminate high-pressure injection?
7 Let me not get so tangled up in jargon.
8 Is the essence of that the prescription 9
that you developed for when it is appropriate 10 to terminate high-pressure injection?
t 11 A
Yes, it's part.
12 Q
The essence of this major accomplishment?
I'h 13 A
That's part of it.
(_)
~
14 Q
All of the other things grow out 15 of that, don't they, or are a part of the 16 implementation of them, aren't they?
~
l 17 A
I believe they could be expressed as part of l
18 the implementation.
l 19 Q
Did the pilot-operated relief valve 20 fail at crystal River?
21 A
I am not sure that's a proper terminology 22 for what happened there.
23 Q
What is your understanding of what 24 happened there?
(~')
25 A
It is my understanding that the pilot-operated w
y y
-v-----
1 Dunn 255 2
relief valve was opened for a period of time.
3 9
was it opened for a longer period of 4
time than was intended by the design?
5 A
That's my belief, or at a time not intended 6
by the design.
7 Q
In what way was the Crystal River 8
incident "similar to TMI-2"?
9 A
In my mind it is similar because it involves 10 a transient, it involves some discharge of
(
11 fluid from the pressurizer, and it involves, I 12 believe, a high-pressurizar level.
(
13 Q
Is it your understanding'that 14 at Crystal River there was boiling or saturation in 15 the reactor coolant system?
)
16 A
I don't know that one way or the other.
17 Q
Is that a conclusion which you have drawn 18 in the pressurizer level?
19 A
No.
20 Q
Have you heard anyone discuss whether there 21 was saturation in the Crystal River reactor during 22 its transient that you are referring to here?
23 A
I don't know whether I have heard anybody discuss 24 that or not.
t\\_)
25 Q
Have you ever read anything or discussed t
. ~.
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1 Dunn 256 2
with anybody what caused the rise in pressurizer 3
level at crystal Rivar?
s 4
A Again, I will have to say I don't know.
5 Q
Do you,believe,that you have ever C,
6 discussed that with anyone?
Do you have any 4
7 recollection of discussing.that with anyone?
i 1
8 A
I have a recollection of examining the data 9
from crystal River.
I have recollections of 10 discussions of that data but the particular points t
11 that you have mentioned in your questions I can't 12 he sure whether they were discussed or not'.
(
13 Q
If I showed you data that' contained 14 temperatures and pressures during the Crystal River 15 transient, would you be able to determine whether 16 they had reached saturation?
~
17 MR. FISKE:
You may answer that yes or 18 no, if you can.
19 A
Depending on the degree of accuracy of the 20 data you provided me.
21 Q
What was the basis for your statement
~
22 that, "these procedures may have prevented a 23 second incident similar to TMI-2" at Cyrsta 24 River?
O 25 A
From the information we received in Lynchberg
, +, ~ -.,,
n
m..
1 Dunn 257-O(_)
2 following the Crystal River event.
I believe 3
I was informed that the operator, during the early 9
4 phase of the accident, made a conscious decision 5
to maintain high-pressure injection even under 6
the expectation that he would force water through
?
his pressurizer safety valves because he was unable 8
at that time to determine reactor coolant system 9
primary variables of pressure and temperature and 10 therefore was not assured that he knew the conditions t
11 within the RCS.
12 Q
How did that indicate to you that these
()
__13 procedures, which you took some major credit for, 14 had prevented an incident similar to TMI 27 15 MR. FISKE:
Mr. Seltzer, he didn't say 16 that they had prevented it.
]
17 MR. SELTZER:
May have prevented it.
18 MR. FISKE:
May have prevented it.
19 A
The procedures on the small break operating 20 guidelines and the resultant training on that along i
21 with the inclusion in the small break operating 22 guidelines of descriptions of the expected course 23 of a small break loss of coolant accident in my 24 opinion effectively stress the need to know positively
%./
25 that we can assure core protection prior to
,..~_-,,__,,,,,,,.,,___,.,,..._.s
_c.w-.--.----e.9.---
,y-y
1 Dunn 258 2
terminating an emergency system.
3 Q
The need to do what?
4 THE WITNESS:
Would you read me back 5
the answer?
6 (Answer read by the reporter.)
7 MR. SELTZER.
"In my opinion" what?
8 Will you please read that again?
9 (Answer re-read by the reporter.)
10 Q
So you are saying that the new small break t
11 guidelines and the training that was developed to 12 implement those guidelines effectively stressed (O
13 the need for the operator to assure himself that-14 there was effective core cooling before terminating 15 high-pressure injection, is that correct?
16 A
I can generally accept that.
We are talking j
17 about the inventory in the RCS?
I l
18 Q
Yes.
19 A
Not the instantaneous cooling.
20 Q
In saying that, are you also saying that i
l l
21 you believe, or do.you also believe that prior to 22 the development of the small break guidelines 23 and the development of training to implement those 24 guidelines, it was not effectively stressed to the O
P 25 operators that they should assure themselves that
1-Dunn 259
(
2 there was core protection before they terminated 3
high-pressure injection?
s 4
A No, I am not saying that.
5 Q
Do you know whether the prior 6
procedures effectively stressed it or not?
7 MR. FISKE:
I am going to object to that 8
question, Mr. Seltzer.
I don't think 9
Mr. Dunn should have to express a conclusion 10 as to whether they effectively stressed it or
(
11 not.
12 Q
Have you reviewed the procedures and
()
13 training that was in effect prior to 'the implementation 14 of the small break guidelines?
15 A
Not in detail.
16 MR. SELTZER:
Why don't we ' suspend for 17 today and resume tomorrow.
18 MR. FISKE:
Fine.
19 (Time noted:
4:38 p.m.)
20 BERT MERRIT DUNN 21 22 Subscribed and sworn to before me this A9 day 23 of O&
198h b
k o
k w [w. M #- g,t w
4
bt 1
260 0
~
2 CERTIFICATE s
STATE OF NEW YORK
)
3
)
ss.
4 COUNTY OF NEW YORK )
('~
5 I,
CHARLES SHAPIRO. CSR.
,. Notary Public 6
of the State of New York, do hereby certify that the 7
continued deposition of BERT MERRIT DUNN 8
was taken before me on March 12, 1981 Consisting 9
of Pages 135 through I further certify that the witnbss had been 10 11 Previously sworn and that the within transcript is a l
l 12 true record of said testimony;
~13 That I am not connected by blood or marriage 14 with any of the said parties nor interested directly l
15 or indirectly in the matter in controversy, nor am I l
16 in the employ of any of the counsel.
17 IN WITNESS WHEREOF, I have hereuntio set my hand
'tH 18 this M
day of A1 ARCH 1981.
19 20 CHARLES SHAP O,
CSR c( '
21 22 23 OV 24 25 4
2.G1 2
j
- 4
- a...v 4..:
- i.
1' INDEX
- a..
s g..',
4 WITNESS
. F. t i PAGE
' /.,]f.
- Bert Merrit Dunn
.136
+
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'" ]q, EXHIB ITS l-hl;$j
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= = b5 5 Y $ Y k!-
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. W,'
'.76 Memorandum from J.
J.
Kelly 143 to Messrs. Karrasch, Swanson, Finnin, Dunn, LaBelle, Elliott,
, e and Hallman, dated Nodember-1, t
1977, subject:
" Customer.
Guidance on High-Pressure Injection Operation" 77 Organization chart of Nuclear 182 service Department dated' -
2-1-77
~
78 Two-page memorandum dated 183 February 9, 1978 to Jim Taylor from Bert M.
Dunn
. 7 79 Memorandum dated February 16, 230 1978, subject:
" Operator Interruption of High-Pressu're Injection" 80 Memorandum to Bruce 242 Karrasch from Don Hallman dated August 3,
1978, subject:
" Operator Interruption of High-Pressure Injection (HPI)"
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