ML20072J128

Deposition of Bm Dunn on 810407 in New York,Ny.Pp 845-968

ML20072J128
Person / Time
Site:	Three Mile Island
Issue date:	04/07/1981
From:	Dunn B BABCOCK & WILCOX CO.
To:
References
TASK-07, TASK-7, TASK-GB NUDOCS 8306290946
Download: ML20072J128 (129)

Text

--.c-I

• 845 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK t

- - - - - - - - - - ---- - - - - - - -x GENERAL PUBLIC UTILITIES CORPORATION,  :

JERSEY CENTRAL POWER & LIGHT, COMPANY, METROPOLITAN EDISON COMPANY and  :

(/ PENNSYLVANIA ELECTRIC COMPANY, Plaintiffs, CIVIL ACTIO

NO. 80 CIV.

-against- 1683 (R.O.)

THE BABCOCK & WILCOX COMPANY and J. RAY McDERMOTT & CO., INC.,  :

Defendants.  :

v

_ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _x Continued deposition ok THE BABCOCK v

, & WILCOX COMPANY, by BERT M. DUNN, taken i by Pldintiffs, pursuant to adjournment, at l

the offices of Kaye Scholer Fierman Hays

}

I & Handler, Esgs., 425 Park Avenue, New a

York, New York, on Tuesday, April 7, 1981, at 9:20 a.m., before Joseph R. Danyo, a Shorthand Reporter and Notary Public of the State of New York.

s t

DOYLE REPORTING, INC.

l CERTFIED STENOTY PE REPORTERS l 8306290946 810407 3e9 t ExmoToed AVENUE PDR T ADOCK 05000289 PDR New Yong. N.Y. 10017 retnewouc 212 - ee7 822o 1

I

1 846 0  !

kd 2 Appe arance s :

6 1

3 l

4 KAYE, SCHOLER, FIERMAN, HAYS & HANDLER, ESQS.,

i Attorneys for Plaintiffs,

( 5 425 Park Avenue, New York, New York 6 ,

BY: RICHARD C. SELTZER, ESQ.

7 and ANDREW MacDONALD, ESQ.,

8 of Counsel 9 -

10 "

DAVIS POLK & WARDWELL, ESQS.,'.

11 Attorneys for Defendants, f One Chase Manhattan Plaza, 12 New York, New York 13 BY: ROBERT B. FISKE, ESQ.

and 14 RODMAN W. BENEDICT, ESQ.,

of Counsel 15 i 16

I 17 ALSO PRESENT

18 l

l 19 DAVID TAYLOR l

20 l

21 00o 22 23 p

24 s

l i, 25 a t I

i

i 1 847 O 2 B ER T M . D UNN , having 3 been previously duly sworn, resumed and 4 testified further as follow:

j (i 5 EXAMINATION . (Continued) 6 BY MR. SELTZER:

7 Q Your testimony today continues to be 8 under oath. Do you understand that?

9 A Yes.

10 MR. SELTZER: I would 1,ike t o m a r.'" as 11 GPU Exhibit 110'a letter from D. R. Patterson, l 12 Chief of the Mechanical Engineering Branch b' 13 of Tennessee valley Authority, to Mr.

14. McFarland at B&W, April 27, 1978, subject 15 " Emergency Core Cooling System - Small 16 Break LOCA Analysis N4M-2-14 ( AR) ," with a 17 copy indicated to Mr. Dunn.

18 (Letter from D. R. Patterson to Mr.

19 McFarland dated April 27, 1978, marked 20 GPU Exhibit 110 for identification, as of 21 this date.)

22 BY MR. SELTZER:

23 Q Is GPU Exhibit 110 a copy of a

( 24 letter which you received in the regular course

' 25 of business in or about May 1978?

I l

- . . . , --....,. -n , --n. . e. . . , , _ , , , , . . _ . . , . . . . _ , . , . - - _ - - . . - . , , , , , . _ _ , , _ , _ _ _ . . - - - . . . , , - . _ , , . . , _ . , . . _ . . , _ _ . - . _ . - - , , - , .

r 1 Dunn 848

/^}

LJ 2 A 'I don't recall receiving it.

3 Q Have you had a chance to look through 4 it to refresh your recollection?

f 5 A Yes, I believe I am familiar with this 6 memo or letter.

7 Q When you say you are.'f amiliar with 8 it, what do you mean?

9 A I have seen it before.

10 Q In what connection have you seen it?

11 A At the first time that I actually read the 12 Michelson Report. This was a cover letter to a

(~%N-) 13 body report which followed, and I have seen the 14 two of them together most of the time. I don't 15 believe I have seen them separately, except in this 16 deposition.

17 Q Have you met with Mr. Pat,torson, the 18 author of GPU Exhibit 110?

19 A Not since the issuance of this memo.

20 Q Have you discussed the contents of r 21 GPU Exhibit 110 with Mr. Patterson or others 22 from TVA? <

23 A I recall one telephone conversation in '

24 which we were discussing the contents of this y,. .

25 memo and the contents of the Michelson report

1 Dunn 849 N- with TVA.

2 I am not sure who was the TVA 3 representative on the phone call.

4 Q Have you discussed the Michelson

( 5 report,with Carlyle Mich.elson?

~

6 A I don't believe so.

7 Q Have you discussed any subjects 8 relating to emergency core cooling with 9 Michelson?

10 A Sometime after Three Mile Island, Michelson 11 was appointed as an adviser to the ACRS. We have 12 had presentations before ACRS during that time x_ l 13 -

fr'ame in which he w'as an advisory member. Those 14 presentations dealt with~the emergency core 15 cooling, loss of coolant accident predictions.

16 Q Have you had any meetings with 17 Carlyle Michelson since he has assumed his new 18 post in the NRC?

19 A No.

20 Q Do you know what his new post is?

- 21 A It is my understanding, it is something 22 dealing with equipment, but that could even be 23 wrong. No, I don't know.

24 Q You don't know that he is in charge 25 of an office that deals with analysis of operating

/

1 Dunn 850 f~h 2 experience of nuclear plants?

i A No, I did not.

3 4 Q When you saw him after the Three

( 5 Mile Island accident, did you tell him you thought 6 he had done a nice job on his report?

I

] 7 MR. FISKE: Which report?

, 8 MR. SELTZER: The report that Mr.

9 Dunn has referred to as the Michelson

! 10 report. "

1 11 MR. FISKE: I object to the form of 12 that question. Ask him whether he had a -

\- 13 conversation about the report.

14 BY MR. SELTZER:

15 Q Did you say anything to him about the 16 report?

17 A I don't believe so. I believe we talked 18 about what happened that day.

19 Q Is it your best recollection that you 20 have never talked to Carlyle Michelson about the 21 Michelson report?

22 A Yes.

23 Q Is it correct that for certain small

(} 24 break loss of coolant accidents, the steam 25 generators are relied upon to remove a portion

~-

f 1 Dunn 851 i

p 5-- 2 of the decay heat?

! 3 A In terms of the licensing evaluations, yes.

4 Q In GPU Exhibit 110, TVA says at the 5 beginning of the third paragraph on the first l

('

( 6 page, that for small break LOCA's up to five-7 hundredths of a square foot, steam generators 8 must remove a significant portion of decay heat.

t 9 Is th at statement accurate?

10 A No, I think the sentence is zeasonable. I 11 don't think the way you paraphrased it and cut 12 it short was accurate. .

~

~

13 Q You think the steam generators must 14 remove a significant portion of the decay heat 15 during the initial phase of the loss of coolant 16 accident? Is that right?

17 A You should complete the sentence.

18 Q Adding what?

19 A "Otherwise reactor coolant system 20 'repressurization occurs since the break is 21 too small to remove all of the decay heat."

( -

22 Q Do you agree with the next sentence 23 which says, "Repressurization or even prolonged 24 high pressure operation could seriously limit D) m .

25 high pressure injection makeup during blowdown

f.

1 Dunn 852

/ '

(

2 and thereby adversely influence the peak clad 3 temperature for those cases wherein the core 4 uncovers during the blowdown"?

( 5 MR. FISKE: I object to that unless j~

6 it is couched in terms of what Mr. Dunn I

7 thought at the time he saw the memorandum.

I i

8 Q What did you think when you saw the 9 memorandum about the validity of that statement?

10 A That it was in essence wrong drawing from

, 11 combining two different accidents that cannot 12 physically combine.

13 Q What two accidents?

l 14 A One of the larger small breaks which has an l

15 opportunity for uncovering the core and the smaller 16 breaks which do not.

17 Q You said that for licensing, you do 18 rely on the steam generators.for removal of a 19 significant portion of decay heat, is that 20 right?

21 A Yes.

22 Q Is it correct that in order to take 23 licensing credit for decay heat removal through

() 24 the steam generators, you have to assume in 25 certain instances continuation of natural

i 1 Dunn 853 0 2 circulation?

3 A No.

4 Q If there is not operation of the

( 5 reactor coolant pumps, do you have to assume 6 natural circulation?

7 A Not by the definition that most people use 8 for natural circulation.

9 Q. What definition is that?

10 7. Solid water.

11 Q What do you mean? I know what solid

'12 water means. Getting back to your answer, not

(~)

'- 13 by the definition most people use.

14 A My definition of natural circulation is an 15 unforced process of mass transport from the 16 reactor core to some cooling mechanism, typically i

17 the steam generator, during which energy is also l

18 carried. That can occur in a reactor by three l

19 mechanisms. The latter two are thought by most i

20 people not to be included in the term " natural 21 circulation," although they are natural and they 22 are in fact unforced.

23 Q What are the latter two?

A bubbly two-phase froth mixture in the hot

( 24 A 25 leg that enhances the density difference between

,, _ . . _ , - . _ _ _ _ _ _ _ _ _ , _ . . . . _ . - - _ _ _ _ _ _ - - _ . . , _ . _ _ ._ . _ . . ~ _ _ _ . _ . .

1 __ Dunn 854

^[

v 2 the colder regions of the system, the hotter 3 regions of the system, which transports both 4 liquid and steam to the steam generators, and a

( 5 mode of operation termed. boiler condenser today, 6 and at one time after Three Mile Island 7 inappropriately termed reflection boiling.

8 Q How does boiler condenser circulation 9 or convection work?

10 A The circulation mechanism is*by boiling 11 steam in the reactor core passing the steam through 12 whatever suspended mixture may be above the n

13 reactor core out in the hot legs where it would

, 14 separate from the mixture region of the system, 1

15 be transported as steam up the hot leg over the 16 top of the candy cane down into the steam l 17 generator and condense on the secondary liquid 18 surface.

( 19 Q Does the NRC for licensing purposes 20 accept that as a method of natural circulation?

21 A The NRC accepts that as a method of pevv10ing 22 energy transport during small break loss of 23 coolant accidents.

{)

QJ 24 Q Does B&W take credit for that 25 as a means for heat dissipation in loss of

i 1 Dunn 855

)

2 coolant accidents for licensing purposes?

3 A Yes.

4 Q Has the NRC accepted it?

( 5 A Yes. .

6 Q on page 2 of GPU Exhibit 110, would 7 you look at the point that is numbered 3.

l 8 Do you see the second sentence in 9 point 3 that begins with the words " Decay heat 10 removal"? i 11 A Yes. -

1 12 Q It says, " Decay heat removal by N..) 13 condensation will cease when the water level t

s 14 inside the steam generator tubes exceeds the 15 secondary side water level."

16 At the time you received this document i

-i 17 and read it, did you believe that was,an accurate 18 statement?

l

! 19 A It is accurate, and I am talking about a l

20 state of knowledge at the time, but it does tend 1

21 to infer a necessity that a necessity remains for 22 heat transfer to the generator and in that 23 fashion, it intones something that is slightly 24 inaccurate.

25 I would like to put on the record, too, I

i

- . , - , , - - , , ,- - - . . . - - - - - - ,_, .- , , - , - - - - - - - - , + - - ,

I 1 Dunn 856 2 that the time at which I first read these and i

4 3 formed the conclusions I have been giving you 4 is after Three-Mile Island.

(l 5 You said at.the time I received this.

6 I want to make it clear that I did not recall 7 receiving this at the time it was issued.

i 8 Q When you saw this after the Three g Mile Island accident, is that the first time you 10 believe you got a copy of GPU Exhibit 1107 11 A I believe that is true.

12 Q It says in the last paragraph on page

('N

\l '

13 2, the seventh line down, the sentence beginning 14 "Also associated." It states, "Also associated

! 15 with operation in each of the above conditions 16 is a concern that the pressurizer level is not 17 a correct indicator of water level over the 18 reactor core. Because of the loop seal on the 19 pressurizer, it may be possible to have a full l

l i 20 pressurizer while the core is partially 21 uncovered."

22 At the time you read GPU Exhibit 110 23 for the first time, did you believe that those f~ 24 sentences made statements which you found

=

25 accurate?

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w-- w-m v w vy-- 3 -~m- y,-

1 Dunn 857 2 A The intonation about the loop seal being j 3 of importance, I would not find accurate. The i

4 concern about the possibility of the' pressurizer

( 5 being full while the primary system is partially

, 6 voiding or as they have expressed it that the r 7 pressurizer level is not a correct indicator of the 8 water over the reactor core, I would find true.

4 9 I did find true. ,

~

I 10 Q You still find it true, right?

t 11 A Yes.

12 Q That fact that you could have a full O

(_/ -

13 pressurizer while the core is partially uncovered 14 is one of the things you took some time to explain 4

15 to others at B&W on the afternoon of the Three 16 Mile Island accident, is that right?

17 MR. FISKE: I don't remember Mr. Dunn f 18 giving any testimony about pressurizer l

19- water level in relation to the afternoon 20 of the accident.

21 MR. SELTZER: We have introduced his l 22 notes in which he had written that he had l

! 23 explained that. GPU Exhibit 97.

(} 24 MR. FISKE: He can answerithe l 25 question.

i

,~n._m, ewe,, ,. -~ ,,-- ~,--+-.--nn,,, , ,-e ,-rg, e n-gm w--w m- .v - w,vw -,7m _-e,-e mmm-- w - - m, ,-----.,+-,.,,--g, -

1 Dunn _ 858

~

O 2 A The answer to the question is, that we 3 took some time to explain the consistency of a 4 pressurizer containing water while low levels

( 5 of coolant existe.d in the reactor coolant system.

6 Your statement related to a 7 partially uncovered core, and I am not exactly

8 sure that we treated it as a partially uncovered 9 core in those discussions. We were talking 10 about the need for high pressure injection.

11 (Continued on following page.)

12 13 -

.4 i 14 i

15 l

16 17 18 19 20 21 22 23 24 25

1 Dunn 859 2 Q Let me show you again GPU Exhibit 97 3 and spe cifically Page 2 of your notes in 97, 4 where you say -- I'm sorry, it starts on Page 1.

( 5 "We asked for a charge rate of around 400 gallons 6 Per minute and started explaining to management 7 how an uncovered core was consistent with full 8 Pressurize r level. "

9 Are those your notes?

10 A Yes. p 11 Q Does that refresh your recollection 12 that you had written that at your meeting on 13 the afternoon of the day of the Three Mile i

14 Island accident, you explained to management how 15 an uncovered core was consistr.nt with full 16 pressurizer level?

17 A Not really. The way I remember it is 18 explaining a need for high pressure injection 19 with the possibility that the water levels in the 20 core were not guaranteed; and that is pretty 21 much how I remembor it today. I don't deny I 22 wrote those notes.

23 Q When you wrote those notes, were you

(} 24 attempting to put your best recollection of the 25 day of the Three Mile Island?

I 1 Dunn 860

[

V 2

A Yes.

1 i

3 Q And your recollection was fresher 4

when you were writing these notes than your

() 5 recollection is todays is that right?

6 A Yes.

7 Q Would you turn to the last page of 8

GPU Exhibit 110.

9 The TVA author states there: "We 10 assume that the situ ations and concerns which s 11 have been identified above and in the attached 12 draft study have been considered in your own 13 in-house loss of coolant analysis and analysis 14 work."

15 As of the date that this is written, 16 which is April 1978, had the situations and 17 concerns which are discussed by TVA already been 18 considered in B&W's loss of coolant analysis work?

19 MR. FISKE: I think that is a pretty 20 broad question, if you ar'e really intending 21 to ask him. separately ab o ut each one of the 22 items that was covered in this letter and l.

23 in the report.

4

() 24 MR. SELTZER: If-he:would like to 25 take it item by item and tell me which ones

. , - . . - - . , , , - , . , - - - . . . - . . - _ . _ _ . - _ . - - , , , - <n, _ e r s.-.-

1 Dunn 861 rh m

2 had been considered and which ones hadn't, 3 that's fine. I didn ' t mean to lump them 4 together unfairly.

( 5 MR. FISKE: ..I just want to know 6 whether you have any particular situation 7 or concern that you are interested in ,

8 which might save us some time.

9 MR. SELTZERL Let's take the.three 10 numbered concerns on Page 2. F 11 A You want me to just answer?

12 g yes.

! (~T 13 k The first issue was considered in 14 determining the nature of the spectrum to be 15 utilized for licensing purposes. The accidents 16 which would have a potential to cause this effect t i l 17 are not severe and did not involve core uncovery 18 and thus did not challenge the emergency core .

19 cooling system.

l 20 Q Had you analyzed whether the l .

21 formation of a steam bubble at the top of each l C.

e 22 steam generator could interrupt natural l

23 circulation? ,

()

/ 24 A Not specifically. Our analysis of the

{ 25 situation went a little different.

I i

e t

e 1

Dunn 862 0 2 Q So you hadn't analyzed that?

3 A In terms of computer evaluation or a 4 specific case, no. I remain with my contention

( 5 that it is in the licensing basis, uhe point.

6 Q What do you mean, it is in the 7- licensing basis? It is bounded?

8 A Yes. . .

9' Q You mean bounded the same way you 10 had thought the discharge pipe break was bounded 11 until you studied that specifically, right?

12 MR. FISKE: .I object to the. form.-of -

O,. 13 the question.

14 Q You thought that the discharge break i

15 was bounded until you studied it, didn't you? .

l 16 A Yes, we felt we had determined the worst 17 case to be located for the smaller breaks at the 18 pump suction as opposed to pump discharge.

19

,. Q It wasn't until you studied pump 20 discharge breaks specifically that you learned 21 that was a worst case, is that right?

22 A For that particular plant. We had 23 studied discharge breaks for that plant, but in 24 the wrong break size range.

25 Q Since April 1978, has B&W in ECCS 1

g Dunn 863 O,

2 Analysis specifically analyzed the possibility of 3 a s te am b ubble forming either at the top of a 4 candy cane or at the top of a steam generator

(( 5 and thereby interfering with natural circulation 6 and decay heat removal?

7 A Yes.

8 Q Who did that work?

'9 A ECCS. -

10 Q Was there any particular individual 11 in your unit that was responsible for that?

12 A- The work has been done on several O)

\m 13 occasions for severa1 reasons. I would say there 14 are about four people, five people, significantly 15 associated with it.

16 Q Who in ECCS Analysis is most 17 knowledgeable about that work?

18 A Probably Mr. Bob Jones.

19 Q Have any formal reports been written 20 on the subject?

21 A At least one.

22 Q When was it written?

23 A May 7, 1979.

( 24 Q What is the title o f 'that?

25 A The blue books.

i ,

1 1

Dunn 864

\

' 2 Q Turning to point 2 on Page 2 ok GPU \

\

3 Exhibit 110, had the situation' and concerns '

- ' 3 s 1 4 , '

stated there been analyzed by 'B &W prior to ,1

( 5 April 27, 19787 i

\ ,

6 ' E '

A I make the same statemant on that that I i

~

t 7

made to No. 1.

The condition is bounded withib ( 1 f-8 the licensing evaluation. There was no s .\ \ \

N 9 particular analysis in the' form of sdetailed s >

f 10 3 '-

computer tuork done of s uch an. svent.

• 11 Q since April 1978,- has analysis been 1** -

g ,

performed specifically on that situation?

13 A Yes, it would be the same analysis 14 ^

mentioned in response to Ite'm No. 1.

15 Q Turning to Item 3, had work been done 1G in-house at B&W on Item 3 be fore l April 27, 19787  ;

17 A From the standpoint of seeing ourselves 18 that such events did not pos e a compromise to '

19 core safety, the point had bee'n c'onsidered and -

20 a certain way evaluated. Repressurizations werec 21 not computed in those evaluations; so we were not i 2'* '

finding that repressurization would occur.

23 The majority lof this paragraph seems 24 to deal with }.ong-term accident re cove ry , lwhich 25 was not specifically evaluated by ECOS at that L

i A

1 Dunn 865 O 2 time.

, 3 Q You did work subsequent to this on the 4

level of water that should be maintained in the m

( 5 secondary side of tha steam generator following 6

a loss-of-coolant accident, didn't you?

7 A Yes, we had do'e n such work, i

8 Q In fact, you came up with a 9

prescription to change the level of water that 10 should be maintained on the secondary side, didn't 11 you?

12 A We have altered the level for the 177 13

• plants. Design work is proceeding on the level 14 for the 205 plants. The work I was talking about 15 was the design work.

16

• Q You altered the level for the 177 17 plants after the Three Mile Island accident 18 s

right?

19 A Yes.

20 Q You increased the level from 50 i 21 percent to 95 percent?

hu s 22 A That's correct.

23 Q When was the work done that 24 supported the change from 50 percent to 95 25 percent?

i

l l

1 Dunn 866

[~h

\# 2 A Ge ne rally , within a few months of Threa 3 Mile Island.

4 Q Refore or after Three Mile Island?

() 5 A 1

After.

6 Q Khat if anything was perceived as t

, 7 the advantage of raising the level to 95 I

8 percent instead of leaving it at 50 percent?

i 9 MR. BENEDICT: By Mr. Dunn?

10 MR. SELTZER: Yes.

11 A A guarantee that whatever condensate was

• 12 available in the steam generators would have an 0w/ 13 opportunfty to return to the reactor vessel

. 14 and a better assurance of steam generator heat 15 transfer during post-accident situations.

16 Q You wanted to increase the decay heat 17 removal, right, in pos t-accident situations ?

18 A No. I would say we wanted to assure that 19 certain masses, i.e., the condensate in the steam 20 generators, could return to the core. It was more 21 a mass. concern than a decay heat removal concern.

22 The other part refers to keeping the 23 steam generator in a mode in which it can control I (~T 24 certain aspects of the primary system such as

.\-)

25 pressure. Decay heat removal itself I did think

1 Dunn 867 b

v 2 was a main concern.

3 Isn't the principal objective in Q

4 recovery from a loss of coolant accident keeping

( 5 the core cooled?

6 A Probably not at this phase of the accident.

7 Q what phase are you talking about?

0 A Post-accident recovery. Probably the 9

principal concern was control of the plant systems.'

10 Q At what point are you In pos t-accident 11 recovery?

12 MR. BENEDICT: In what sort of

() 13 accident are you talking about?

14 MR. SELTZER: The one that Mr.,Dunn 15 has been referring to.

16 MR. BENEDICT: Do you have a specific 17 accident in mind?

Q Do you, Mr. Dunn?

i 19 A I am talking about loss-of-coolant 20 accidents.

21 Q When does a loss-of-coolant accident 22 go into post-accident recovery phase?

23 A At such point as the break in the 24 high-pressure injection system can assure core 25 cooling.

1 Dunn 868 2 Q The present prescription by B&W for 4

3 response to small break loss-of-coolant accident 4 is to terminate operation of the reactor coolant

( 5 pumps within the first two minutes of the 6 accidents isn't that right?

7 A I want to look back at the actual paper 8 work to testify to the value of the two minutes 9 to terminate the reactor coolant pumps early.

10 Q The mode of core cooling that 11 .

follows termination of reactor coolant pumps 12 g in volves natural circulation; right?

~

13 A At sometimes.

14 Q Immediately after the reactor 15 coolant pumps are terminated, doesn't the 16 circulation of water shortly the reaf te r depend 17 upon natural circulation?

18 A For certain break sizes, depending on 19 when the reactor coolant pumps specifically are l

.20 tripped.

21 Q For those break sizes that depend on 22 natural circulation, when the pumps are tripped {

23 shortly after the start of the accident, does the

() 24 maintenance of a 95 percent level on the secondary i

25 side of the steam generators play a role in heat {

[

1 Dunn 869 4

O ,

2 removal?

i 3 A No. We're talking about 177 plants now.

4 It helps.

,( 5 Q What do you mean, it helps?

6 A It makes the situation better.

7 Q Are you saying that you would have 0

effective core cooling in the 177 plants even 9

if the level were down to 50 percent?

10 A That is what the analysis shhws.

11 Q Do you have a high degree in those 12 analyses?

13 A Yes.

14

, (Continued on Page 870.)

15 16 17 18 19 20 21 -

22 23 25

hd1 1 Dunn 870 0 2 MR. SELTZER: I would like to mark as 3 GPU Exhibit 111 a memorandum from Mr. Bailey 4 to Mr. Levandowski, subject "Small Break 5 Report," May 25, 1978.

6 (Memorandum dated May 25, 1978 from Mr.

7 Bailey to Mr. Levandowski on the subject 8 "Small Break Report," was marked GPU Exhibit 9 No. 111.)

10 BY MR. SELTZER: .

11 Q Who is Mr. H. Bailey?

12 A Henry Bailey who, at that time, was a member l

' [ 'T . .

i

\> -

13 of the Generic Licensing Group. Unit, I guess it is 14 a unit.

15 Q That was a unit that reported to Taylor, 16 is that right?

l 17 A Yes.

18 Q Who is Mr. F. J. Levandowski?

l 19 A It refers to Frank Levandowski. At this time, 20 I am not sure what he was doing.

L What is " Manager SLU"?

( 21 Q 22 A SLU doesn't mean much to me today.

23 Q Is Frank Levandowski still at B&W?

24 A Yes.

25 Q In GPU Exhibit 110, the last exhibit k

I 2 __

1 Dunn 871 0 2 that we saw, on the bottom of page 2, the next to 3 the last sentence concluded with the words "...it 4 may be possible to have a full pressurizer while t

5 the core is partially uncovered." The paragraph 6 goes on, "This could lead to incorrect operator 7 actions."

8 In GPU Exhibit 111, which is Bailey's 9 memo to Levandowski of May 25, 1978, he says 10 "A more valid concern may be the sudject of 11 operator action and the potential for erroneous 12 pressurizer levels."

13 Prior to the Three Mile Island 14 accident, were you aware that TVA had raised as a 15 subject of concern the fact that erroneous pressurizer 16 level could lead to incorrect operator actions?

l 17 A Yes.

l 18 Q How would you become aware of that?

19 A Mr. Bob Jones had received from our Project l 20 Management Team associated with TVA a report on small break phenomena. That report has since

( 21 i

I 22 been termed the Michelson Report.

I 23 In his review, he became aware that 24 .TVA was writing statements, this statement here, 25 the other statements that are contained in the l

L

3 1 Dunn 872 f3

(_)

2 remainder of the report, and he informed me that 3 TVA was concerned on that issue.

4 Q At the bottom of page 1 of GPD Exhibit 5 111 --

6 MR. BENEDICT: Are you going to ask 7 Mr. Dunn whether he has ever seen this 8 before?

9 MR. SELTZER: I wasn't planning to.

10 MR. BENEDICT: I am not sure we should a

! 11 ask questions about it. Why are you asking

- 12 him a question about a document that you have 13 not identif(ed yet?

14 MR. SELTZER: I have identified it for 15 the record.

16 MR. BENEDICT: You have noted it for 17 the record, but you have not identified it 18 as being something that he knows something 19 about.

20 BY MR, SELTZER:

( 21 Q At the bottom of page 1, it says: "No 22 addition communication with TVA has occurred on this i

23 matter and ECCS analysis has taken no action on this

[ 24 report. Bert Dunn plans to start looking at the 25 report next week to see what's there and to l

l 1

i 4 1 Dunn 873

~

(J\

2 consider what action or investigation should be 3 pursued (if any)."

4 Had you talked with Bailey in or about 5 May 1978 regarding the Michelson Report?

6 A I do not recall doing so.

7 Q Had you told anybody in or about May 8 1978 that you planned to start looking at the 9 Michelson Report to consider what action or 10 investigations should be pursued as a result of 11 the contents of the report?

g 12 A By that you mean personally look at it?

13 Q No, I give you a more royal presence.

14 You or your unit.

15 MR. BENEDICT: Could you read back the 16 question?

l l

17 (Record read) 18 A I am not sure of the timing. Bob Jones had l 19 read this report at some time. We had decided -

20 there was not anything critical on it and to handle

( 21 it as the remainder of the work load within the 22 unit allowed. That is pretty close to my total 23 recollection.

O

(,/ 24 Q Did there come a point when the work l 25 load of the unit allowed time to do further analysis en. -

e-- r -~w- , - - n , ----.-n-- - - - - - - - - , , - - , . , - - - - , - - - , - - --w - - -

5 1 Dunn 874 (m

N-2 of the Michelson Report?

3 A The first responses to TVA were, I believe, 4 around Christmas, either before or shortly after, 5 1978.

6 Q Were those responses in writing?

7 A' Yes.

8 Q Was there anything in the response 9 about the pressurizer level not being a correct 10 indication of water level over the beactor core?

11 A Yes.

_, 12 Q What did you say?

\'

13 A We agreed with TVA.

14 Q Who prepared the written response to

• 15 TVA that you say was sent out about Christmas 16 19787 17 A Bob Jones.

18 Q Did you review it before it was 19 sent out?

20 A I cannot recall reviewing it. I believe

( 21 it is my understanding that I did sign as a 22 reviewer.

23 Q What does it mean if you signed saying 24 reviewed and approved for conclusions drawn?

25 A Then I probably reviewed it. I did review

6 1 -

Dunn 875 O

\, /

2 it.

3 Q And approved it?

. 4 A Yes. I think I would like to, if we can, 5 produce that.

6 Q sure.

7 Did it occur to you prior to sending 8 TVA the response that Bob Jones drafted that you 9 could send them the substance of your February 10 1978 memorandum on operator response' to 11 pressurizer level?

i s 12 A Can I have it back again?

13 Q I will restate it.

14 In February 1978, you had written 15 to Jim Taylor that the operators at Toledo Edison 16 had inappropriately terminated high pressure l 17 injection in response to rise in pressurizer 18 level, right?

l 19 A Yes.

20 Q When you heard of TVA's concerns over

( 21 operators acting incorrectly in response to 22 pressurizer level, you made an association, I 23 think you already testified, between what they 24 were writing about and what you had_previously

(

25 written to Taylor about, isn't that right?

l l

i

r 7 1 Dunn 876 O 2 A That's correct.

3 Q After you became aware of TVA's 4 concerns, did.you say to anybody "Why don't we send

( 5 them the substance of what I have already written 6 to Jim Taylor in February 1978"?

i 7 A No.

8 Q Did you say to anybody, "Maybe we should 9 check and make sure that Customer Service has sent 10 out the instructions that I drafted'in February 11 1978"?

19

~ A No.

(:) .

13 Q Did you write.to anybody and suggest ,

14 that they check to see if your February 1978 15 instructions had been sent out to customers?

16 A No.

17 Q Did anybody tell you in the course of 18 discussing TVA's concerns, " Don't worry about that, l 19_ we already sent out Bert Dunn's February 1978 20 instructions"?

01 A No.

22 MR. SELTZER: I would like to mark as 23 GPU Exhibit 112 Jones to Lightle, signed by 24 Mr. Dunn, subject " Response to TVA Letter 25 K-5020," January 1 9 ,' 1979, i

r j8 1 Dunn 877 2 (Memo dated January 19, 1979 from R.

3 C. Jones to R. E. Lightle re " Response to 4 TVA Letter K-5020" was marked GPU Exhibit 5 No. 112 for identification as of this date.)

6 BY MR. SELTZER:

7 Q Is GPU Exhibit 112 a copy of the 8 response prepared by Jones that you were referring 9 'to in your testimony several minutes ago?

10 A Yes. ',

i 11 Q- You reviewed and approved this g 12 response, right?

\

13 A Yes.

14 Q Do you know whether your employer ever 15 sent this response to TVA?

16 A Yes.

17 Q Did they?

18 A Yes.

19 Q Did they send it in exactly the form 20 that appears here, to the best of your knowledge?

21 A I don't know.

(

22 Q If you don't know whether they sent 23 it in this form, how do you know they sent it?

' 24 A We had telephone conversations with TVA after 25 this, in which the subject matter of a transmittal n . --- - - - - - , , , , . , - , - -,e-, , , , , , , - - , - - - , , , , -.- , , , - - ,e,,r- e , , . , , , - - ,

9 1 Dunn 878 2 was discussed.

3 Q Did you discuss the response with Jim 4 Taylor?

5 A I don't recall. -

! 6 Q Did you discuss it with Bailey?

A 7 I don't recall.

8 Q Would you turn to the last page of 9 GPU Exhibit 112.

i 10 In the next to last p ar a'g raph , you 11 and Jones have stated: "As far as the 12 appropriateness of the operator using pressurizer 13 level indication to trip the HPI pumps, B&W agrees 14 that the level indication is not a reliable 15 indication of the state of the RCS. However, use 16 of the pressurizer lovel indication, along with 17 system temperature and pressure measurements to 18 ensure that the system is still in a substantially l 19 subcooled state, will provide sufficient guidance l

l l 20 for operator action."

21 That statement about insuring that the 22 system is still in a substantially subcooled state 23 is not nearly as extensive as the instructions

() 24 that you had drafted on February 16th and sent to 25 Jim Taylor, are they?

F 10 1 Dunn 879 -

I v

2 MR. FISKE: I think I am going to 3 object to the form of the question.

4 A It is not as explicit.

( 5 Q Did you ever consider when you were 6 reviewing GPU Exhibit 112 or any earlier draft of 7 it, did you ever consider inserting explicitly and 8 in full text instructions that you sent to Taylor 9 on February 16, 1978?

10 A No. ,

11 Q You didn't even consider it?

12 A No.

Eh V 13 Q Did you discuss with Jones sending him 14 those instructions?

15 A I don't believe so.

+

16 (Recess) 17 MR. SELTZER: I would like.to mark GPU 18 Exhibit 113, a memorandum from J. D. Carlton 19 to Alan Womack, subject "Small Break LOCA 20 Auxiliary Feedwater Requirements," May 17, 21 1979-22 (Memorandum dated May 17, 1979 from J.

23 D. Carlton to E. A. Womack re "Small Break 24 LOCA Auxiliary Feedwater Requirements," was 25 marked GPU Exhibit No. 113 for identification as of this date.)

E 11 1 880 Dunn 0 2 Q Is GPU Exhibit 113 a copy of a 3 memorandum from Carlton to Womack attached to 4 which is a description of auxiliary feedwater

( 5 flow required which you and Carlton prepared?

6 A It is a copy of a memo on auxiliary 7 feedwater from J. D. Carlton to E. A. Womack; and 8 on the final page where the table is shown, my 9 initial's are contained on the bottom.

10 Q Did you and Carlton prep'are the last 11 three pages of GPU Exhibit 113, which is what i 12 ' Carlton says in his cover meno to Womack?

G(~h 13 A I remember working with Jim in this area in 14 this approximate time frame, so I will say 15 probably.

16 Q In the first page of the attachment I

17 which you probably worked on, would you look at l 18 paragraph 3. It talks there about how auxiliary 19 feedwater flow is controlled to a specific level 20 on the sscondary side of the steam generators.

21 Is that a correct description of how L

22 auxiliary feodwater is automatically controlled?

23 A For the 177 plants, yes.

24 (continued on next page) 25 I

i

ok 1 1 Dunn ggg w

2 Q As a result of this automatic 3 control of auxiliary f e e dwate r , if the level 4 of primary water were the same or greater than 5 the level of the secondary water, would that

(

6 result in automatic shutoff of the auxiliary 7 feedwater?

8 A No.

9 Q Would it end up reducing the demand 10 for auxiliary feedwater? ,

11 A In some cases.

. 12 Q In what cases?

g- .

(_) 13 A In the case where that level had already 14 been reached.

15 Q What level?

16 A The shutoff level for auxiliary feedwater.

17 Q What is the level that shuts off 18 auxiliary feedwater, and how does it relate to i

19 the level of primary?

I 20 A It does not relate to the level of primary 21 at all. The level is presently 25 feet. Excuse 22 me. Ninety five percent on the operate range.

23 Q Before you changed the operate range 24 to 95 percent, what was the level at which 25 auxiliary feedwater was cut off?

i k

1 Dunn 882

(~)

2 A Fifty percent on the operate range.

3 MR. SELTZER: I would like co mark 4 for identification as GPU Exhibit 114 a

( 5 memo from Mr. Dunn to Mr. Duerson, subject:

6 CPR Work on RELOAD Contracts, January 18, 7 1978.

8 (Memo from Mr. Dunn to Mr. Duerson, 9 subject: CPR Work on RELOAD Contracts, 10 dated January 18, 1978, was marked GPU 11 Exhibit 114 for identification, as of this 12 date.)

r-

~ ~

13 Q Is GPU Exhibit 114 a copy of a memo 14 that you sent to Duerson on or about January 18, 15 19787 16 A Today I cannot recall sending this. That is i

17 my signature. I have no reason to believe that 18 it is not.

19 Q In fact, you have some pretty good 20 reasons to believe that it is, right?

21 A '

22 Q What was Duerson's role and 23 specifically why were you writing this particular

("}

V 24 memorandum to him?

25 A Not recalling generating it at this time, I

I 1 Dunn 883 p

(') 2 I would have to speculate.and let the memo stand 3 for itself.

4 Q You called Duerson a name here. You 1

({ 5 said he was the Generic Project Manager. What 6 does that mean?

7 A Generic Projects is the name for the 8 organization of project management which we have g referred to previously in the deposition as a risk 10 group.

• 11 Mr. Duerson was a Project Manager 12 within that organization responcible for k,_ 13 arranging for the evaluation of certain types

~

14 of product concerns.

15 Q When you say " arranging for the 16 evaluation," you mean securing funding within B&W?

17 A Yes.

18 Q Were you writing to hin in GPU 19 Exhibit 114 to seek funding for further 20 evaluation of pump discharge breaks?

21 A It is not clear from the memo. Again I 22 have to speculate.

23, Q As you reread this memo, do you 24 understand th a t you were asking Duerson to

[a) 25 reconsider finding funding for small break in i

1 Dunn 884

[)

2 the pump discharge line to be analyzed?

3 MR. FIS KE : This is something we 4 have been through before. Mr. Dunn can

({ 5 testify as to what his understanding of it 6 was at the time he wrote it. I have no 7 objection to that. But he doesn't recall 8 it now.

9 I don't think it is proper to ask 10 him to try to read it now and guess or 11 surmise what his purpose was.

12 MR. SELTZER: Would it help if I told 13 you your partner, Bob Wise, has been 14 asking a GPU witness within the last 15 couple of weeks what documents mean today?

16 MR. FISKE: I don't know whether it 17 helps or not. I don't think it. changes 18 what I am saying to you.

19 MR. SELTZER: You think it is improper 20 for Bob Wise to ask our witnesses for their 21 present understanding?

22 MR. FISKE: You know you are not 23 going to get me into a discussion of whether

(~D 24 questions Mr. Wise is asking, which I don't us) 25 know the contents o f, are improper or

1 Dunn 885 O 2 proper. All these things have to be based 3 on the individual questions.

4 I am just telling you what my position

((, 5 is with respect to this memo.

6 MR. SELTZER: I thought you were 7 enunciating a more generic position.

8 MR. FISKE: I am simply stating the 9 same thing I stated the last time this 10 came up with Mr. Dunn. >

r

. 11 MR. SELTZER: But you are espousing 12 it as a generic proposal, that it is not

-O~ 13 right to ask him what a document is today, 14 if they don't have a recollection of what 15 it meant when they first saw it or wrote it.

16 MR. FISKE: I said it in the context 17 of two particular documents that you have 18 shown to Mr. Dunn. Whether that has a l s 19 broader application or not, I don't know.

20 I just take them one document at a time.

I 21 MR. SELTZER: I think this document 22 is not of sufficient interest to me to 23 press the point, but I want you to be on

() 24 notice that you are creating a precedent 25 which we may apply.

6 1 Dunn 886

• ~

2 I daresay I vehemently disagree 3 with the principle you are espousing. I 4 think it is phooey.

5 MR. FISKE: You can call it anything

((

6 you want. Maybe some day some judge will

, 7 decide whether you are right.

8 MR. SELTZER: A lot of judges have 9 decided I am right on that particular point.

10 I think after you exhaust the witness' 11 recollection about what something meant 12 at the time he wrote it, you can advance

~

13 to what does it mean today.

14 MR. FISKE: We obviously disagree.

15 MR. SELTZER: You instruct the witness 16 not to answer that question?

l 17 MR. FISKE: Yes. I think that is what I

! 18 I did the last time.

19 ,

MR. SELTZER: I wanted to make sure 20 we joined the issue.

21 BY MR. SELTZER:

22 Q The small' break in the pump discharge 23 line that you are referring to in GPU Exhibit 114 24 is-the same break that you had sought funding 25 for through the risk group in April 1977, is that

.- ( . _ _ - . .

i 7 1 Dunn 887 2 right? I show you your April activities 3 report, GPU Exhibit 104, if y'ou want to refresh 4 your recollection.

(' 5 A 1

Yes, I think these are the same.

6 Q Would you turn to point 3 on the 7 second page of GPU 3xhibit 114. In the first 8 sentence you say, "In your decision to ask our 9 customers to pay for the two above analyses, I 10 would like you to consider the following 11 concerns."

12 "Your decision" refers to a decision

\_ 13 made by Duerson or'the risk group a 't B&W, right?

14 A Again, not recalling the circumstances 15 under which I wrote the memo or writing the memo, 16 I have to say that is an interpretation which 17 could be given.

18 Q An interpretation which you would 19 give it?

20 MR. FISKE: I object to that.

21 MR. SELTZER: He is writing to 22 Duerson. He says "in your decision." I 23 am asking does the "you" refer to Duerson

[~)

\~/

24 or to Duerson's risk group.

25 MR. FISKE: Or obviously drawing your

8 1 Dunn 888 2 own conclusions from that, which may not 3 be right.

4 MR. SELTZER: That is why I have a i

5 witness here who is sworn to tell tha

((

6 truth. I am asking if that is his 7 conclusion.

8 MR. FISKE: The whole point of this 9 exercise, if Mr. Dunn doesn't recall the 10 circumstances itself, while he certainly 11 will give you the truth, his truth is no 12 more relevant than your truth as to what

, 13 that means. I don't think the fact that he 14 has taken an oath has a great deal to do 15 with this.

16 MR. SELTZER: Let's not descend to a 17 petty level.

18 Would you let him answer this question?

19 MR. FISKE: I think we can all read 20 the memo. Why don't you proceed from there.

21 MR. SELTZER: The quest. ion is whether 22 the "your" refers to Duerson or his group.

23 MR. FISKE: Mr. Dunn has told you he 24 doesn't recall writing it. We can all 25 speculate as to what it means. You can

... - . . , _ _ _ . _ _ - . _ _ . . . - . _ _ _ , , _ , _ . _ _ . = , . . . . _ _ _ . , _ . _ _ . , . . _

1 Dunn 889 O 2 draw your inference. I can draw mine. I 3 suppose he can draw one, too.

4 MR. SELTZER: That is what I want.

5 His inference of words that he has written.

((

6 MR. FIS KE : I am not going to let him 7 answer, not that I think it is particularly 8 crucial with respect to this point. I 9 think in this particular case, I think we 10 would all agree what it means.

11 MR. SELTZER . You want to have a show 12 of hands.

O~/

13 MR."FISKE: Why don't you go on to 14 the next question.

15 BY MR. SELTZER:

16 Q You say "we have been aware of the 17 concern of the pump discharge break for nearly a 18 year. It is possible that NRC would consider

! 19 our reporting of the concern untimely."

20 Did's&W eventually report the pump 21 discharge break concern to the NRC?

22 A Yes.

23 Q Did you report it to the NRC sometime

')

( 24 25 after January 1978?

MR. FISKE: I think there has been a

4 0 1 Dunn 890 2 lot of testimony about this earlier 3 already. I think Mr. Dunn testified quite

4 thoroughly on that whole subject in one of

(( 5 the earlier days of this deposition.

6 Q At the time that you communicated the 7 pump discharge concern to the NRC, did you 8 indicate that you had been aware of the concern 9 for nearly a year?

10 MR. FISKE: I think you,are misstating 11 the testimony. Mr. Dunn -- I don't believe 12 Mr. Dunn ever testified that he communicated 13 the concern to the NRC.

l 14 MR. SELTZER: I am asking him whether 15 he ever communicated that they had the j

16 concern for a year or more.

17 MR. FISKE

Did ne ever communicate l

18 that to the NRC?

{

19 MR. SELTZER: Yes. ,

20 MR. FISKE: You can answer that i

, 21 question.

k.

l 22 A I am not absolutely sure, but I don't 23 believe so.

() 24 Q Do you believe that anybody else at 25 B&W told the NRC that you had been aware or a

I

r 1 Dunn 891 2 anybody at B&W had been aware of a concern over 3 a pump discharge line break for more than a year 4 prior to the reporting to the NRC?

( ,, 5 A I don't know.

6 Q You wrote in January 1978 that "It is

7 possible that NRC would consider our reporting of 8 the concern untimely."

9 At the time you wrote GPU Exhibit 114, 10 what was your understanding of when',the NRC 11 expected you to report concerns such as that?

12 A 'I don't know that I have had at that time

• O 13 a clear understanding of when the NRC would have 14 expected us to have reported this type of a -

15 concern. The NRC would have expected prompt i 16 reporting of the concern once it had been 17 validated or upgraded from its existence at this 18 time,..if. it remained a concern.

19 Q You wanted Duerson to consider three l

20 concerns, four concerns, that you were raising, 21 right, A, B, C and D?

22 A Again, that would be a conclusion that 23 could be drawn from the memo.

24 Q Why did you want him to consider the 25 fact that B&W had been aware of the concern of l

l I _ . . . . . _ . - - _ , _ , - - . _ - . . ~ _ , ,, , __ _ _ , . - - - _..

,1 3

7- .

~ '

• i,.

(1 ~x , > $,

f

• g\ r \

l' 6

j Ki . >

l Dunn i

• 892 s

i A./ 2 the pump clischarge break for nearly a year in, s 4 3 mal:ing up his mind as to whether to ask '

x ,

s +

, 4N 4 customers tot pay for analysis of that break? . i

) ' /. ,

(, 5 A I think I would have to speculate or

)

6 interpret to give you an answer.

~

7 'Q. Why don't you interpret?

\ ;2 8 MR. FISKE: No. This is a question I Q ,

9 where either he remembers why.or he do e s n

• t .' '

10 If he doesn't, I dca't think J.t is useful t -

11 to have him speculate at this point. ,

. 12 ME. SELTZER: .I don't think~it is' s 13 speculating. He said he could interpret it.

14 I think to get the author toJinterpret'is- .

lt <

15 important. j J -

l 16 I also think'it is sonethin7[ bc5f de.ri'ng ,-

.+ +

l ,

l 17 on a cover-up for yo'1 tr) be* putting wraps ' 't i

1' e< , +

l i . ,

! 18 on this witness at'a time when I am't.ryingh e

/ .- ,j ,

19 to explore,why for a year EkW would not pays l l'

~

i ,

. a ;i [

l 20 for an analysis of an ECCS concern. , and.

T

( n i ,.

~

21 t a f t'e r a y e a r , when this, man honestly thinks ..,.

l^ e 22 it might be untimely to let the NRC know ,

23 about it, B&W saying, let's throw this one l

24 onto the customer to let them pay to- b ri'n g s .

C ,

25 this plant in conformance.- .- e' 9 k

? ;f l < .

'j

't j */ , , ,

,e  ;

, . .a #

1 Dunn 893

) '

2 MR. FISKE: You are totally 4- 3 misstating the record. I am compelled to i

4 respond to your statement.

{, 5 MR. SELTZER: Why not let the 6 witness respond to it?

7 MR. FISKE: I am responding to your 8 comment which is totally inconsistent with g -._ g the facts. The facts are that this was 10 reported to the NRC. This ha,s nothing to 11 do with the Three Mile Island accident.

12 This is another one of a number of

() ~

13 totally extraneous matters that have 14 prolonged this deposition far beyond any 15 reasonable termination point, and one of 16 the reasons we go on day after day is you 17 persist in pursuing these irrelevant areas.

18 Now we have a situation where you 19 have an irrelevant memorandum that the 20 witness said he can't recall what was in

~

'a-* 21 his mind at the time he wrote it, and now

~ '~

22 you are asking him to speculate why he would 23 have said something in this memorandum when

/

, 24 he can't remember today the reason.

i .

25 It is clear he is not required to

4 1 Dunn 894 i )

\_/ 2 answer that question. A speech in which 3 you mischaracterize the facts is not going 4 to help you get an answer.

( 5 MR. SELTZER: I would like to mark 6 for identification as GPU Exhibit 115 an 7 April Activities Report from Mr. Dunn to Mr.

8 Roy dated May 2, 1978.

9 (April Activities Report dated May 2, 10 1978 was marked GPU Exhibit 1,,15 for 11 identification, as of this date.)

12 BY MR. SELTZER:

N . .

,,_) 13

, Q Is GPU Exhibit 115 a copy of your 14 April Activities Report for 19787 15 A Yes.

16 Q By April 1978 your unit had begun to 17 analyze the pump discharge break referred to in 18 GPU Exhibit 114, right?

~

19 A~ Yes, that is indicated by the progress 20 report.

21 Q Is April 1978 the first time that any 22 extensive examination had been performed by your 23 unit on the pump discharge line break?

/ 24 MR. FISKE: I think you ought to

'u 25 clarify what you mean by " extensive."

_ :_~ . .. - -

f 1 Dunn 895

(*h

(_) 2 Q The first time there had been a 3 serious investigation of the concern that you

~

4 had been voicing for over a year?

() 5 MR. FISKE: You can answer that.

6 A Sometime before April 10. April 10 is 7 given as the date we filed the PSC, although it 8 appears at that time it may have been referr'ed 9 to as a PSDR, so we would have performed an 10 evaluation sometime before that. ,,

11 Q Is the evaluation you commenced 12 sometime shortly before April 10 the first time

)

~

13 you had donc a serious investigation of the 14 concern over pump discharge line break?

15 MR. FISKE: He didn't say that it 16 started shortly before April 10.

17 Q How long before April 10 do you 18 believe you began work on the pump discharge line 19 break?

^ 20 A I am not absolutely sure. I do recall it 21 proceeded reasonably rapidly once funds were 22 identified for the project.

23 Q You worked two shifts a day, right, 24 ten to 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> a day, for nearly two and a half

/)i Q

25 weeks, isn't that right?

6 1 Dunn S96 78 2 A It seems like you are reading that.

3 Q Yes, page 3 from your writing, GPU 4 Exhibit 115.

MR. FISKE: I don't know what time

( 5 6 period you are referring to in your 7 question.

S Q Do you see the last paragraph on 9 page 37 10 A Yes. p

. 11 Q Did you write there that "In 12 obtaining our present status ECCS personnel

)~ 13 worked in two shifts, averaging 10 to 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> 14 per day, for nearly two and a half weeks"?

15 A Yes.

16 Q You were referring to the analysis 17 that had been done by your staff on the pump 18 discharge line break, right?

19 A Yes, and the analysis after April 10.

20 Q How much if any analysis had been 21 done before April 107 s

22 A Again I am not absolutely sure, but it was 1

23 I believe a single case which upgraded the concern )

24 in terms of its validity and led to th e filing of 25 the PSDR. I l

i

!E 1 Dunn 897 2 Q Did that analysis verify the concern?

3 A I think at the time we proceeded into that 4 analysis we did not believe that the

( 5 consequences would be as severe as the analysis 6 showed us, so it did not really verify it. It 7 actually made it something that was in a fashion 8 new.

9 Q Who performed that analysis for one 10 case? ,.

11 A I don't recall.

12 Q Was it a computer-assisted analysis?

()

\ j 13 A Yes.

14 Q About how long did it take to run?

15 A As I mentioned before, I believe that once 16 we obtained funds, we proceeded reasonably 17 rapidly. I think it was on the order of a month 18 to get through it.

19 Q A month to do the one case?

20 A Yes, from the time that it was funded to 21 the time when all the boundary conditions were 22 determined and the computer actually ran and the 23 results reduced and examined from the standpoint 24 of their validity. You can't just accept the 25 output of a computer. You have to determine that

18 1 Dunn 898 O -

2 it has done its job right.

3 Q As soon as you finished that month 4 of analysis, did you and Jones proceed to

(; 5 prepare the PS0?

6 A Yes. That is my recollection.

7 Q So if the PSC is dated April 12, 8 1978, and fou proceeded to write the PSC 9 immediately after the one month's work, is it 10 correct to conclude that the one month's work was 11 done in or about March 19787 12 A Yes. .

'/ 13 And the work done in March was the Q ,

14 first tim.e you had proceeded to do seridus, 15 detailed analysis of the concern that you had 16 had over the pump discharge line break, is that t

i 17 right?

18 A For the 177 plant, yes.

19 Q That was the first time you had done 20 serious, detailed work, even though you had 21 articulated that concern at least as early as L 22 April 1977, is that righr?

23 MR. FISKE: I think maybe the problem

( 24 in your question is, you keep using these 25 adjectives like " serious" and " detailed"

19 1 Dunn 899

~ .

(-) 2 and " extensive."

3 The document that you referred to, 4 which has been previously marked as an

() 5 exhibit, itself reflects that work was 6 initiated in performing this analysis back, 7 at the time in April. 1977. So the document 8 itself shows that work was done back in 9 1977.

10 MR. SELTZER: But appar,ently not any 11 serious, detailed work, because this 12 witness has just sworn that the first time

() -

13 they did serious, detailed work was March 14 1978, 15 MR. FISKE: I don't know whether he 16 said that was when they first did serious,

17 detailed work or not, but I think the 18 problem --

l l

l 19 MR. SELTZER: I think you are also l

20 mischaracterizing the document. It says 21 work was initiated on performing small 22 break analysis, and now he is seeking funds 23 to perform the analysis. When they 24 couldn't get the funds, apparently the

[

\

25 plant dried up and died and they were never

1 Dunn 900 2 able to do the serious, detailed work that i

3 was necessary.

4 MR. FISKE: I think maybe it would 5 be useful, instead of trying to deal with

({

6 these adjectives which one person can 7 construe one way and someone else would 8 construe another way, just ask him the 9 progress that was done on this matter. I 10 am sure he will tell you. Then we can all e-11 decide afterwards.whether that is serious 12 or detailed or whatever.

rm .

( _), 13 BY MR. SELTZER:

14 Q Would you look at page 3 of GPU 15 Exhibit 115.

16 In the paragraph j ust below the chart, 17 the third sentence, that begins with the words 18 "To be blunt." .

19 A Yes.

20 Q Correcting the typographical error, 21 I think you stated there, "To be blunt,.the 22 high pressure injection system on 177 or lowered 23 loop plants is undersized."

24 Is that a correct reading of what you s_ -

25 were saying?

1 Dunn 901 O.

(._) 2 A No, I think I.said "underdesigned."

3 Q I am sorry.

4 What did you mean by "underdesigned"?

A Did not provide sufficient flow to

( 5 6 mitigate the consequences of licensing accidents.

7 Q Did you ever tell the NRC that?

8 A I don't think I ever used the phrase "to 9 be blunt" with the NRC.

10 Q Did you ever tell them ,the high-11 pressure injection system was underdesigned?

12 A I would say that was the essence of what

() 13 we were communicating at that time.

That there 14 was insufficient flow provided by the high-15 pressure injection system for these accidents.

16 I don't know that the word "underdesigned" was 17 used.

18 MR. SELTZER: I would like to mark as

'l 19 GPU Exhibit 116 a memo from Mr. Duna to i 20 Ed Kane in Licensing, subject: Telephone f 21 Conversation with Zoltan Rosstoczy on May k-22 15, 1979 on Stuck Open PORV With Pumps 23 Running and No Auxiliary Feedwater, 24 May 29, 1979.

25 (Memo dated May 29, 1979 from Mr.

I 1 Dunn 902 2 Dunn to Ed Kane in Licensing, subject:

3 Telephone conversation with zoltan 4 Rosztoczy on May 15, 1979 on Stuck Open PORV With Pumps Running and No Auxiliary (3 5 6 Feedwater, was marked GPU Exhibit 116 for-

7 identification, as of this date.)

8 Q Is GPU 116 a copy of a memo you sent 9 to Kane on or about May 29, 1979?

10 A Yes.

P 11 Q Turning to_page 2, the first full 12 sentence, you stated, "As an over-riding concern, -

() 13 I pointed out that there is no intention within 14 the operating guidelines to cause an RC pump. trip 15 during the transient and that this is true 16 regardless of pump performance variables. In 17 other words, I restated our position that at i

18 least one pump per loop will run until it dies.

19 I confirmed that my experience with RC pumps l

20 running in high void systems has shown no 21 problems with their performance and that our i

22 pump experts indicate no concern in pumping a 23 two-phase fluid."

t 24 You previously testified the reactor l '3 b 25 coolant pumps could continue pumping with up to s

_ . , _ _ _ _ _ . _ . _ _ _ _ . _ , , __ _ , _ _ . , . , _ , _ , , , . . _ . . _ . , - . _ _ _ - _ _ _ _ _ _ _ . . . . ~ . _ . , . _ _ . . _ , . . , _ . . _ . _ , _ , , __

1 _ Dunn 903 0~ 2 and including a 100 percent void fraction, right?

3 A Yes.

4 Q You also said you understood that the 1

pumps could continue running with a 100 percent

( 5 6 void fraction for a matter of days, at least, is

, 7 that right?

8 A Yes, I expressed my expectation of the time 9 frame in the day frame.

10 Q In the days frame, is t, hat what you i 11 are saying?

12 A Days.

() 13 Q You weren't sure how many days, but t 14 it was several days, right?

i 15 A Yes.

16 Q Have you seen any reports at B&W that i 17 enunciate that finding.or conclusion?

l l 18 MR. FISKE: You mean on how long they 19 could continue running?

20' MR. SELTZER: Yes, namely, that the 21 reactor coolant pumps can. continue to run 22 for a matter of days at a 100 percent void 23 fraction.

f- 24 A I am not sure whether the Cudlin memorandum N.

25 addresses that time period or not. Other than

\ . .

I 1 Dunn 904 rN -

k_) 2 that, I don ' t believe I have seen any reports.

3 Q How do you spell "Cudlin"?

4 A C-u-d-1-1-n.

5 Q Who is Cudlin?

(

6 A Joe Cudlin.

7 Q Is he a B&W employee?

8 A Yes, he is a Manager of System Analysis 9 Technology.

10 Q What is the Cudlin report?

11 A It is a memo that indicates the .

12 capability of the pumps to pump two-phase fluids.

() 13 Q When did Joe Cudlin write that?

14 A I believe it was sometime after Three Mile 15 Island.

16 Q You testified that you knew before 17 the Three Mile Island accident that the reactor 18 coolant pumps were capable of c'ontinuing to pump 19- with up to 100 percent void fraction. What was 20 the source of your knowledge before the Three 21 Mile Island accident?

22 A There had been experiments in which pumps 23 had been involved in a two-phase testing in which 24 they had run for considerable lengths of time 25 during the testing procedure.

l

! t

~ ~ . , , . . , _ . . . _ . - - . . _ . . , , , . , _..._,_ - -, .-. . - _ . - - . _ _ . , ,

1 Dunn 905 1

(

a (m/ 2 Q Had the pumps been tested up to 100 3 percent void fraction?

4 A At least in one set of experiments.

(, 5 Q Are these experiments that had been 6 done at B&W7 7 A No.

t 8 Q Were they experiments that were done 9 for B&W7 10 A one of them.

v 11 Q Did the experiment that went up to 12 100 percent void fraction get performed for B&W7

(,g) 13 A No.

14 Q Who performed the experiment running 15 the pump up to and including 100 percent void 16 fraction?

17 A The NRC.

18 Q When was that done?

19 A I am not sure. I put it in the '74 time 20 frame.

21 (Continued on next page.)

l 22 ,

24 (v'~)

25 l

t .

1 Dunn 906 2 Q Are you-aware that at the time of the 3 Three Mile Island accident, B&W had issued limits 4 and precautions that were instructions on the r 5 operation of B&W supplied equipment?

6 MR. FISKE: I object to the form of 7 the question.

8 Q Have you heard the phrase " limits 9 and precautions"?

. 10 A Yes.

v 11 Q Are,you aware B&W had issued limits 12 and precautions before the Three Mile Island 13 -

accident?

14 Let me make it a simpler question.

15 Have you become aware at any time that B&W had 16 been issuing limits and precautions for its 17 nuclear plants prior to the Three Mile Island 18 accident?

19 A No, I think you are going to have to get 20 somebody more intimately involved with that 21 pro' cess to answer the question. I don't know.

22 I know that on certain pieces of equipment I 23 have become aware that we issued some types of 24 instructions.

0\

v 25 Q Did you know that B&W has issued j

, , , . , - s . -,,--r- . , , , , . . - - - _ , ...,e -

r i Dunn 907 in

(_) 2 some types of instructions for the operation of 3 reactor coolant pumps?

4 MR. FISKE: You are asking him before

,5 the accident?

{ .

6 MR. SELTZER: He can have the 7 awareness at any time.

8 Q But are you aware, including up to 9 today, that B&W had issued instructions for the 10 operation of reactor coolant pumps to its operators 11 prior to the Three Mile Island accident?

12 A No.

() 13 Q Do you know that as the void fraction .

14 increases, the vibration on the reactoAcoolant 15 pump shaft increases?

16 A No.

17 Q Have you ever known that as void 18 fractions in the reactor coolant system increase, 19 vibration on the frame of the reactor coolant 20 pump increases?

21 A No.

22 Q Have you ever come to know that during 23 the Three Mile Island accident, shaft and frame 3 24 vibration on the reactor coolant pumps were

'u]

25 increasing as the void fraction was increasing?

s

r 1 Dunn 908

'N 2 A Yes.

3 Q Had you forgotten about that when I I

4 asked you the previous questions about knowing

() 5 that shaft and frame vibration increase as void 6 fraction increase?

7 A No, I had not forgotten that.

8 Q Do you have any knowledge to the 9 .

contrary that negates your experience from i

10 Three Mile Island?

9 l 11 MR. FISKE: I object to this. You 1

. 12 are asking him now a question which is

• ~

(

13 asking for his present knowledge, and that ,

14 is objectionable in and of itself, but 15 beyond that, this is clearly an area in 16 which Mr. Dunn has no expertise.

17 MR. SELTZER: That is quite an

18 admission. The head of ECCS Analysis?

l 19 MR. FISKE: On the vibration of the 20 pumps.

I 21 MR. SELTZER: If the operation of the L 22 pump is important to continue the emergency 23 core cooling.

em 24 MR. FISKE: There is no point in s/

25 debating whether the core could be i

1 Dunn 909 2 cooled by the pumps or HPI or whatever.

3 BY MR. SELTZER:

4 Q I think you are a very good expert.

5 MR. FISKE: .The question is not

({

6 whether he is a good one or bad one. The 7 question is whether he is one.

8 Q Other than the Three Mile Ialand 9 accident, do you have any experience with 10 other situations in which you have heard reports 11 or seen reports of pump vibration as void 12 fraction increased?

() 13 A Yes.

14 Q What other reports have you

! 15 received?

16 A Pump vibration occurred in the Bingham

! 17 pump tests.

l l

18 Q Were those tests that were being run l

19 at various void fractions?

20 A Yes*

l 21 Q Was there more vibration on the pump 22 when it was pumping two phase fluids as 23 contrasted with solid water?

i 24 A That is my opinion generated from the i

j 25 communication I have gotten on that testing.

,e - -

1 Dunn 910

(,, 2 Q Have you received any reports which 3 showed no increase in pump vibration as the pumps 4 began handling increasing void fraction as 5 contrasted with operating with solid water?

i

((

6 A No.

7 Q So all of your experience is i

8 consistent with a conclusion that pump vibration 9 increases as the pumps are handling increasing 10 void fractions as contrasted with pumping 11 solid water, is that right?

12 A No.

f3 13 Q Do you have any experience to the 14 contrary?

15 A Yes.

16 Q what experience is that?

l 17 A Outboard motors.

18 Q What brand of outboard motor are you 19 talking about?

20 A I think I would say generally.

21 Q Have you run experiments on that?

22 A No.

23 Q How have you determined whether the vibrations are increasing on outboard motors as O J 24 the void fraction increases?

L5

- - - - - - , . - , . . . . . - . - . . . , , - - - - - - - - - -s

1 Dunn .9.1 1

\_/ 2 MR. FISKE: Are you suggesting that 3 Mr. Dunn's experience with outboard motors 4 has something to do with the Three Mile 1

() 5 Island accident?

6 Q Do you think your experience with 7 outboard motors has anything to do with the 8 Three Mile Island accident?

9 MR. FISKE: I don't think Mr. Dunn 10 is required to draw that conclusion.

11 MR. SELTZER: Then I wi 1 proceed 12 since he has injected his experience with

)

• 13 outboard motors as being relevant.

14 MR. FISKE: He answered a question 15 that you asked him which may or may not 16 be a relevant question. Go ahead. Answer 17 this. It is probably easier to let you 18 answer it than debate it for five minutes.

19 It is no further removed than any of 20 the other issues.

21 A No.

22 Q What was the question?

23 A Whether or not my experienca with outboard (g 24 motors had anything to do with the Three Mile

\_]

I 25 Island accident.

1 Dunn 912 2 Q When did you get the Bingham results 3 that showed increasing vibration as void fraction i

4 increased?

5 A I would have to go back and look. I

(

6 believe it was before Three Mile Island.

7 _. Q Are you aware that B&W instructions 8 to Met Ed set an upper limit on the permissible 9 mils of vibration that could be experienced on 10 a reactor coolant pump?

v 11 MR. FISKE: I object to the form of 12 the question and also Mr. Dunn said a O minute ago that he wasn't aware any instruc-Ly,) 13 14 tions had been issued. I think he answered 15 it.

16 MR. SELTZER: This may be a subset 17 of the previous answer.

18 A No.

19 Q In saying that your position was that 20 at least one pump per loop will run until it 21 dies, did you mean that the reactor coolant pump 22 should be left running regardless of the level of 23 vibration observed on it?

24 MR. FISKE: I object to that. I thi'nk 25 what he said is perfectly clear.

1 Dunn 933 2 Q You may answer.

3 MR. FISKE: Let me read this 4 paragraph before you answer.

(( 5 (Record read.)

6 MR, FISKE: I object to that question 7 unless you make clear what set of 8 circumstances you are contemplating in 9 putting that question to Mr. Dunn.

10 MR. SELTZER: During a, transient.

. 11 MR. FISKE: Any transient?

12 MR. SELTZER: During a transient as

("%

(_) 13 he has used that word on page 2 of GPU i

14 Exhibit 116. In the same sentence that 15 I have been reading from, "As an overriding 16 concern, I pointed out there is no intention 17 within the operating guidelines to cause a 18 reactor coolant pump trip during that 19 transient."

20 MR. FISKE: Now the question is?

21 (Whereupon, the record was read by 22 the reporter as follows:

23 "Q In saying that your position 24 was that at least one pump per loop will

(']

NJ 25 run until it dies, did you mean that the

1 Dunn 914 2 reactor coolant pump should be left running 3 regardless of the level of vibration 4 observed on.11t?")

5 A Yes.

( .

6 Q Did you also mean that it should be 7 left running regardless of the void. fraction i

8 in the reactor coolant system?

9 A No, I would have meant in voided circum-10 stances, where there was reason to guestion t

t 1

11 their results after termination of reactor coolant 12 pump, and the system had returned to a subcooled

(, 13 status and there was a reason to take the reactor i

14 coolant pumps out of service, I would have allowed 15 that.

16 Q You previously testified that effective 17 core cooling would continue so long as reactor 18 coolant pumps remained on with void fractions 19 up to and including 100 percent, right?

20 A Provided that there is some heat sink 21 available to keep the superheat content of the 22 steam from becoming significant.

23 Q Have you ever run an analysis or 24 case in the following situation: A pilot g-)s

\. -

i 25 operated relief valve stuck open, little or no k

1 Dunn 915 4

2 high pressure injection flow, reactor coolant 3 pumps on at least one pump per loop.

I 4 Let me add as a condition. AFW

)

({ 5 being supplied to the s team generator.

6 A No.

7 Q Has your ECCS unit ever studied such 8 a situation? Have you or your ECCS unit ever 9 studied such a situation?

10 A Yes.

i.

11 Q When?'

12 A At the time that we performed the pumps

() 13 running small break evaluatio,n, the 205 plants,

14 . I think it was in the early sp' ring of 1979 or 15 the winter of 1978. It could be timed earlier i

i 16 in the deposition in relationship to some Toledo 17 issues that came down and focused on whether or 18 not we had considered the pumps running case as 19 the worst case. We checked it, and post-Three i

20 Mile Island, we also considered it.

7 21 Q I thought Toledo has a 177 plant

\. -

22 and not a 205?

I 23 A It does.

24 Q Did you study it for the 177 plant 25 also?

w.

..,,.y_..9--_4 __

y ,

y___ . . _ ,,,..._.y,,. ,, ,,y__,_.y _ . , , , . , _ _ _ , , . _ y , , . - - - . . - , _ , . . , , . _ _ . - , , _ - _ _ _ , , , , . , _ _ _ - , ,

I 1 Dunn 916 (O

_j 2 A No, we considered the evaluation performed 3 to be generic.

4 Q How long could the core remain or 5 be maintained effectivel.y cooled with those (i

6 criteria prevailing?

7 MR. FISKE: Let's state the criteria 8 again. You are asking him what was shown 9 by this analysis that he testified was done?

10 MR. SELTZER: Yes.

n 11 A What the analysis showed was that for pump 12 steam flow, clad saturation, temperatures, and at -

(y r

j 13

~

a pressure of approximately a thousand pounds, 14 the rise in temperature across the core --

15 excuse me. The rise in the temperature cladding 16 was less than 100 degrees Fahrenheit. We had 17 concluded that almost any pumped steam media, if 18 the superheat did not get out of control, would be 19 able to provide effective core cooling. We have 20 not done the work to tell exactly how long that 21 situation could be maintained.

22 Q From the analysis that you have done, 23 what is the order of magnitude that the analysis 24 shows effective cooling could be maintained?

\-

25 A I don't think the analysis can give you

, - , ., . - - ,.n.

_.. ...as 1 Dunn 917

/ 2 that.

3 Q From the analysis, what is a minimum 4 time that the analysis would show you would still

( 5 have effective core cooling?

6 MR. FISKE: Can you answer that?

7 THE WITNESS: No, not for this 8 parciular case.

9 Q For what case would you be able to 10 make such a statement? ,,

, i 11 A The actual case that was evaluated which was 12 a different break size in the PORV.

• 13 Q Was it larger or smaller?

14 A I believe it was somewhat larger.

15 Q So you would have less mass loss 16 through a PORV break than 'you would through the 17 break that you studied, right?

l J 18 A Yes.

I 19 (Continued on following page.)

20

, 21 l

km l 22 23

[ 25

hd1 1 Dunn 918 2 Q So that if in the case that you studied, 3 the plant could have effective cooling for seven 4 hours, the PORV break would have effective cooling 5 for a longer period, is that right?

6 A Yes.

7 Q What is a conservative figure which 8 the analysis shows you would maintain effective 9 cooling for the case you studied?

10 A I believe that analysis progressed no 11 further than approximately one-half hour. It had 12 also not arrived at 100 percent void fraction.

j 13 The work on the 100 percent void fraction was a 14 hand calculation.

15 MR. FISKE: I think I should note here 16 that I have no objection to these questions i l'T in terms of general discovery. Obviously, l

18 in terms of anything probative, the report 19 itself or the analysis itself'is going to 20 have to be relied upon.

21 Q Who did the analysis that you have 22 been describing?

i 23 A Which one? We have two on the board now.

(} 24 Q What are the two?

25 A The hand calculation which showed that the core l

t

i 2 1 Dunn 919 2 coul,d stay effectively cooled with poor steam 3 fl w, and the computer evaluation which indicated 4 the nature of the transient with the pumps running.

' I

.l() 5 Q Who did the hand job?

6 A I am not sure.

I 7 Q Was it someone in your unit?

8 A Yes.

9 Q Who was responsible for the computer 10 calculation? ,.

11 A Nehru Shah.

~

12 Q For what purpose was the computer work O'

j 13 done?

14 A Internal questions had been ra'ised about our i 15 assumption that pumps running was a better case 16 than pumps off or that the significant challenges 17 to the high pressure injection system and other 18 parts of the ECCS system would occur for the 19 pumps-off case as opposed to the pumps-on case.

i 20 Q Have you ever discussed with anyone l

l 21 what the results at Three Mile Island would have 22 been if the reactor coolant pumps had been left l 23 on so there was at least one pump per loop in

}

24 continuous operation?

{~))

m 25 A I think so.

L

- , . - , ~ - - , - , . , - . - , , , - , , - -- , , - , - - - ---.,n- , . - , , , - - - , -.,.,~,,,,-,v-- .-,,n, -- --- -

?

,  ?! f 1

, )

1 ~-

3 '

Dunn i ,

920:s  !

O 2 Q I t,hink the records show that the ,

3 blocked value was closed two hoprs and 20 minutes' 4

4 into the transient. ' '

,- 4 l 5 ,From your discussions ad the repobts

., , i

_ , .. s '

6 that you have read on the>subje'et of, pumps runn'inyl -

q' l

/

~

7 would the core have remained affectively cooled if /

f 8 the reactor, coolant'pumpshadbeenkept on through '

s 1 9 the time that the blocked valve was closed? ,

10 MR. FISKE: I object to that' -

question, because you are asking' Mr.#:Dunn for 11 12 his present opinion. ,;-

A/ 13 MR. SELTZER: No, .I am asking whether,. ,,

14 he has discussed that or whether any of.thb4 '

15 analyses that he has done have --

-)

16 MR. FISKE: You are asking him.from the -

17 question to put together several_ analyses 18 that he has done. ,,,-- ' '

19 MR. SELTZER: Let me take it in smalle'r '

20 steps.

21 BY MR. SELTZER:

22 Q You said you have discussed with others 23 what would have happened if the reactor coolant I~ 24 pumps, at least one pump per loop, had remained on

~

%-)h 25 the day of the Three Mile Island accident?

I w

. - . _ _.,y -, , - - - - -

y,- - - - . _ . . , , , . - . . - . - . - .- , -- y-,. . .- . - - . . , - . . ..y , -.,----.m-e,w-- --

4 1 Dunn 921 Ob 2 MR. FISKE: He said he thinks he did.

i

' l 3 MR. SELTZER: Yes. That is what I want, 4 what he thinks.

] 5 BY MR. SELTZER:

, 4 6 Q With whom do you think you have had

. 7 such conversations?

- 8 MR. FISKE: I object to that unless it 9

. ,s 9 is based on a recollection.

10 MR. SELTZER: Why don't,you horsewhip

,e .

11 him outside of the room. I find it -

i 12 embarrassing to see it happen right in front 13 ,of me.

14 He testified he thinks he had a 15 conversation. I think you are trying to s

16 scare the pants off him, make him think li, i

r 17 "Oh, God, now we are getting into something 18 serious, don't testify 'c -"

19 MR. FISKE: Maybe a bell goes off every l

20 hour where you feel compelled to make some 21 saber rattling speech. It doesn't help very 22 much.

1

,. 23 You know the rules by which depositions 24 are conducted. Just because you shout and 25 scream periodically doesn't change the rules.

.i.

.+6- - , , . - - - - - , . - _ - - - - - . . . - _ - x- . . _ - , , - , . . . - . , _ -___._ _ ,_____..-.__ _ m_

5 1 Dunn 922 2 I have no objection to Mr. Dunn, as I 3 have said, testifying about his 4 recollection about conversations. I say

( 5 that again.

6 MR. SELTZER: He is a grown man, 7 responsible manager at B&W. I am sure he 8 understands that he is sworn to tell the 9 truth, and he is going to testify to things 10 that he only recalls and he is not going to 11 tell me about his dreams or fantasies.

12 When I ask him who he met with, I 13 assume he is going to tell me who he met 14 with.

15 MR. FISKE: That is precisely what I i

16 suggested he do.

17 BY MR. SELTZER:

18 Q could you answer the question.

19 A We are talking about seeing?

20 MR. FISKE: You are talking about l 21 recall.

22 A I recall where I think I discussed it.

l 23 Q Why don't you testify to that?

A In the Kemeny Commission depositions and as

( 24 25 a preventive measure when we formulated the

. _J,^ _ _ . . _ _ .

6 1 Dunn 923 O 2 instructions to keep the reactor coolant pumps 3 operating.

4 Q What is your best recollection as to l 5 what you .said would have been the effect on the 6 Three Mile Island accident if at least one reactor 7 coolant pump had been kept running per loop?

8 MR. FISKE: I think he said he 9 testified in the Kemeny Commission. Why 10 don't we get out the testimony,and see what 5

11 he said. Certainly, you wouldn't quarrel 12 with that, I assume.

13 Q Is that the only time you think you 14 said anything to anybody about what would happen 15 at Three Mile Island if the reactor coolant pumps 16 had been left on?

17 A I allowed the other circumstances, too. Yes, 18 when we determine, it is based on a recollection.

19 2 With whom else do you have a 20 recollection of discussing it?

21 A The question is have I had discussions about 22 what would have happened at Three Mile Island if 23 the reactor coolant pumps had kept running.

I said -- how did I say it?

( 24 25 MR. FISKE: I believe you said you

7 1 Dunn ~

924 2 thought you testified about that before the 3 Kemeny Commission.

4 A I thought I testified about that before the 4 5 Kemeny Commission, and in the form of the 6 preventive measure. I recall I think I talked i 7 about it during the meeting with Taylor and Norm 8 Elliott when we decided to write the instruction 9 to keep one pump operating, but that was in a 10 short time frame, not necessarily all that 11 happened at Three Mile Island.

12 Q The instruction to keep the pump O

• 13 running was an instruction that was sent out just 14 after the Three Mile Island accident, right?

15 A Ye'.

16 Q In the context of discussing the 1

17 advisability of sending out a pumps-running 18 instruction, you and Elliott and Taylor discussed 19 what would have happened at Three Mile Island if 20 they had left the reactor coolant pumps running?

21 MR. FISKE: With the HPI off?

22 MR. SELTZER: With the HPI doing 23 whatever it was doing. Ceterus parabus,

()

n 24 A I said I think we discussed it in the short 25 time frame.

N t -

8 1 Dunn 925

! U-~

2 Q What is the short time frame?

3 A Not an hour afterwards. Not from the I 4 standpoint of considering all the other things 1

5 that happened at Three Mile Island following that,  ;

6 but that the pumps were tripped in the condition j

! 7 where we still had two-phase fluid in the plant, J

8 and that is the time in which we expected things 9 started to really go favorably, and keeping the

! 10 pumps running could have extended that time.

11 That is why the instructions --

12 Q Let me try this, and then we will l

13 adjourn for lunch. The blocked valve was. closed i

14 at two hours and 20 minutes into the Three Mile 15 Island accident.

f 16 Have you ever discussed with anybody l'T whether there would have remained enough liquid 18 or steam inventory in the reactor coolant system

(

19 up to the point of two hours and 20 minutes to 20 keep the core effectively cooled, if the reactor 21 coolant pumps had remained on at Three Mile

(

22 Island?

23 Have you ever discussed that with I

24 anyone before today?

25 MR. FISKE: The question whether the I

9 1 Dunn 926 O 2 core would have continued to be cooled up l 3 to that point in time you referred to? -

4 MR. SELTZER: Yes. Cooled within the

( 5 criteria that you and Taylor and others talk 6 about effective core cooling.

7 A I indicated, I think, -- 0.K. I see the l

8' difference.

9 What I believe occurred in the Kemeny 10 Commission -- ".

11 MR. SELTZER: That is relevant.

3 12 MR. FISKE: I object to Mr. Dunn trying

, 13 to paraphrase what he said in the Kemeny 1

14 Commission. Whatever he said there, he 15 said there.

16 MR. SELTZER: Fine. Now we want to 17 find out any other.

18 MR. FISKE: Other than that in i

19 reference to the closing of the blocked 20 valve.

21 A Let me try it another way.

(

22 MR. FISKE: Just answer the question.

23 MR. SELTZER: I am sure he is trying 24 to.

25 THE WITNESS: Repeat the question.

l 10 1 Dunn 927 l (G

2 (Record read) 3 A Based on my recollection, if I did, it'was 4 in the Kemeny Commission.

5 Q Did you keep a copy of the hand I

6 calculation that you were referring to earlier?

l l

'7 A No.

8 Q When is the last time you saw the hand 9 calculation?

10 A I don't remember. '.

11 Q Does your analysis of pumps running 12 with high void fractions confirm that if there

(~b 13 were any void fraction'up to but less than 100 14 percent in the reactor coolant system at the time 15 the blocked valve was closed that the core would 16 remain effectively cooled thereafter if the 17 reactor coolant pumps stayed on?

18 MR. FISKE: I object to that question 19 because that is asking him for a present 20 opinion.

21 MR. SELTZER: I am asking whether the 22 analysis shows that.

23 MR. FISKE: No, you are asking him

() 34 whether to apply the analysis to that situation 25 which, I think, is asking him for his present

10A g Dunn 927-A O 2 opinion.

3 I Di*"**

4 (Luncheon recess: 12:30 p.m.)

5 6

7 8

'9 10 ..

11 12 13 14 15 16

\

17 18 19 20 21 22 23 25

/1 1 928 A

V- 2 (AFTERNOON SESSION) 3 (Date: April 7, 1981) 4 (Time noted: 1:40 p.m.)

( 5 B E RT M. D U N.N, resumed, having 6 been previously duly sworn, was examined 7 and testified further as follows:

8 EXAMINATION (Cont'd.)

9 BY MR. SELTZER: .

10 Q Where would you look at B&W today S

11 if you wanted to find any reports or data on 12 the Bingham pump tests?

g a s/ 13 A I'would talk to two individuals.first, 14 Dr. Joe Cudlin and Mr. Bob Winks.

15 Q winks?

16 A Yes.

17 Q How do you spell Winks?

18 A W-i-n-k-s.

I 19 Q Anybody else that you would speak

. 20 to to locate the Bingham test results?

l 21 A No. I am pretty sure that would be

! (. adequate.

22

! 23 Q Who at B&W, to your knowledge, is

("T 24 most knowledgeable about the ability of reactor

\_)

f 25 coolant pumps to operate at high void fractions?

l l

.- - . - - , . . - - . - - . ,..,,,. -n ..- -, --, . - . . _ , , _ _ - . . .

2 1 Dunn 929

,~

(

2 A I think you would have to define the word 3 "*Dili"Y" * ***

4 Q Let's say the performance of pumps

() 5 at high void fractions. . Who is most knowledgeable 6 at B&W about the performance of pumps operating 7 against high void fractions?

g A Dr. Cudlin. I think Dr. Cud 11n would be 9 the most knowledgeable person.

10 Q Where would you look f you wanted 11 to get a copy of the documents that relate to 12 Nehru Shah's analysis of core cooling with high O~ 13 void fraction?

~

14 A I would ask Nehru for a reterence number.

15 If that wasn't available, I would look in my own 16 unit files.

17 Q What do you mean by reference number?

18 A The calculation was documented in what we 19 term a calculation file and it has a unique number 20 assigned to it that would make it easier to find 21 it if I could determine in advance the number.

22 If not, we can find it in the files.

23 Q W uld the same file or similar file 24 include the hand calculations that you referred to?

25 A I d n't know.

, , , , - - - . , - -4. , . . . .,,_-.-..-.-..-r- _-,.m., -

1 Dunn 930 0 2 Q Where would you go if you wanted to 3 find the hand calculations?

4 A I'm not sure.

( 5 Q Whom did you say you thought did 6 the hand calculations?

7 A I didn't recall who.did the hand 8 calculations.

9 Q You have no idea how you would go 10 about trying to find them? ,,

11 A I would probably ask some people.

12 Q Who?

('_/'T s 13 A Bob Jones, Nehru Shah, Bill Bloomfield.

14 Q How would you refer to the 15 calculations that you were looking for?

16 A As back-of-the-envelope estimations on l

l 17 the cocling possible with steam-only flow at pump 18 flow rates.

19 MR. SELTZER: I would like to mark 20 for identification as GPU Exhibit 117, 21 Mr. Dunn's January 1979 activities report.

22 (Covering memorandum dated 23 January 31, 1979 from B. M. Dunn to E. A.

24 Womack enclosing January Actitivies Report 25 marked GPU Exhibit No. 117 for I . . . , , , , , . - - . - - . -.

1 Dunn

, 9.31 I >

2 identification, as of this date.)

3 Q Is this a copy of a monthly 4 activities report which you sent to Al Womack on

( 5 or about January 31, 1979?

6 A Yes.

7 Q On page 3, under the heading 8 " Unscheduled Activities," does that refer to the 9 hand calculations on pumps running that you were 9

10 just describing? ,

11 A I'm not sure.

12 -

Q From reading your monthly report, O' 13 does it appear to you that this could be another 14 analysis that you did on pumps running with steam 15 cooling?

16 A It appears that that is possible.

17 Q Do you know who did this hand 18 calculation referred to in GPU Exhibit 1177 19 A No.

20 MR. SELTZER: I would like to mark 21 as GPU Exhibit 118, a memorandum from Jones 22 to Taylor with a copy to Mr. Dunn dated 23 June 7, 1979, subject " Pumps Running 24 Analyses - Record of Telecon."

25 (Memorandum dated June 7, 1979 from

. _ _ . _ . _ - _ - - _n_____ __ -_..___.._,_Z_.

1 Dunn 932 U 2 Jones to J.

R. C. H. Taylor, subject 3 " Pumps Running Analyses -

Record of Telecon" 4 with a copy to Mr. Dunn, among others,

( 5 marked GPU Exhibit.No. 118 for 6 identification, as of this date.)

7 Q Is GPU Exhibit 118 a copy of a 8 memorandum which you received in or about mid-June 9 19797 10 A I recall the issue, not the memo.

11 MR. SELTZER: I would like to mark i

l 12 as GPU Exhibit 119, a memorandum from

(' ,

13 Taylor to Distribution, copy to Dunn, 14 subject " Longer Term Work Expected by 15 NRC," June 8, 1979.

16 (Memorandum dated June 8, 1979 from 17 J. H. Taylor to Distribution, subject 18 " Longer Term Work Expected by NRC," with 19 a copy to Mr. Dunn, among others, marked 20 GPU Exhibit No. 119 for identification, 21 as of this date.)

22 MR. SELTZER  : also would like to 23 mark a memorant H. A. Bailey to

[j 24 Distribution, in i Mr. Dunn, subject

%J 25 "Small Break LOCA with Reactor Coolant

g Dunn 933 d 2 Pumps - PSC," June 8, 1979.

3 (Memorandum dated June 8, 1979 from 4 H. A. Bailey to Distribution, subject

( 5 "Small Break LOCA with RCP's - PSC," with 6 a copy to Mr. Dunn, among others, marked 7 GPU Exhibit No. 120 for identification, as 8 of this date.)

9 Q Is GPU 119 a copy of a memorandum 10 which you received in or about mid-June 19797 11 A . I don't recall it.

12 Q You don't recall it?

(^x _ .

O 13

~

A No.

14 Q Is GPU Exhibit 120 a copy of a 15 memo which you received in or about early June 16 1979?

17 A I don't specifically recall this.

18 Q Prior to the analyses thit were 19 being done in 1979 on pumps running cases, what 20 guidance had B&W given the operators on when to 21 have reactor coolant pumps on and when not to 22 have them on during the loss of coolant accident?

23 MR. FISKE: I object to that 24 question.

25 MR. SELTZER: I will try to rephrase

l 1 Dunn 934 O

2 it.

3 Q Are y u aware of any instructions 4 that B&W was giving operators prior to June 1979 on the operation of reac, tor coolant pumps during

( 5 6 1 ss of coolant accidents?

7 A No, not one way or the other.

g Q Have you ever learned what, if any, 9 instructions B&W was giving operators prior to 10 June 1979 on whether to leave reactor coolant 11 pumps on or not on during the loss of coolant 12 accident?

c d(~h 13 A No.

14 Q W uld it be fair to say even though 15 you were the ECCS Unit Manager, you were not in 16 the general flow of information going from B&W 17 to operators on how to handle their equipment?

18 A Yes.

19 Q Was anybody in your unit, to your 20 knowledge --

21 MR. FISKE: I think he answered all 22 these questions once before but go ahead.

23 Q was anybody else in your unit

("% 24 reviewing instructions that B&W was giving Q]

25 perators on how to run their equipment prior to

, - . - . - , m+.my . , . - - , r , . - , , , -g ,

, , - - - - - ,m . . , . + - - . _ - . . , . - .

~

8 1 Dunn 935 (S

2 the Three Mile Island accider t?

3 MR. FISKE: I object to the form of ,

4 the question. You can answer it.

l 5 A No. .

6 MR. SELTZER: I would like to mark 7 as GPU Exhibit 121, a memorandum from 8 Cartin to womack, copy to Dunn, subject 9 "Small Breaks Guidelines," June 22, 1979, 10 (Memorandum dated June 22, 1979 g..

11 from L. R. Cartin to E. A. Womack, subject 12 "Small Breaks Guidelines;" with a copy to 1 .

, s/ 13 Mr. Dunn, among others, marked GPU Exhibit 14 No. 121 for identification, as of this 15 date.)

16 Q Is GPU Exhibit 121 a copy of a i

l i 17 document which you received in or about late l

18 June 19797 19 A I don't recall the actual receiving.

l 20 Q Are you familiar with the document?

21 A Yes.

l 22 Q Would you turn to page 3. In the l

23 first full paragraph, it begins with the statement, 24 "As indicated in Table 3, the assumptions regarding

('NV) 25 equipment availability are different than those l

3 Dunn 936 r) 2 in standard licensing submittals," et cetera.

3 Then it lists three assumptions.

4 Below that, it says, "The above

( 5 failure assumptions cannot be justified under 6 known regulatory rules for the operating plants 7 without design changes."

8 In what way did you understand when 9 you read this that these three failure assumptions 10 could not be justified under known regulatory 11 rules?

12 A I don't recall.

O

\~ 13 . Q You said you were familiar with 14 GPU Exhibit 121. From what are you familiar with 15 it?

16 A A great deal of the work contained in the 17 exhibit was generated within ECCS Analysis. The 18 operating guidelines given at the end in 19 Attachment 4 were prepared in conjunction with l

20 ECCS Analysis and the ECCS was participating in 21 the whole effort at the time that the memo was 22 generated.

23 Q Did you know that assumptions 24 regarding equipment availability were being made

(~')s L.

25 in the small break analyses that were different

10 1 Dunn 937 O 2 from those used in the standard licensing 3 submittals?

4 A In some of the analyses, yes.

l 5 Q Which assumptions were different 6 from those used in the standard licensing 7 submittals? Let me ask you -- I will withdraw 8 that.

9 Under the heading " Single Failure" 10 on page 3, the second item says, "If a failure 11 occurs which prevents an emergency steam-12 generator blowdown, 2 high pressure. injection pumps

/~h

(_)

13 ,

are assumed available."

14 Do you see that?

15 A Yes.

16 Q That assumption that two high pressure 17 injection pumps were available is diff.erent from 18 what is assumed in standard licensing submittals, 19 is that correct?

l 20 A That's correct.

I 21 Q What is assumed available in the 22 standard licensing submittals?

23 A One HPI is assumed available. One HPI 24 train. The subject of emergency steam generator l 25 blowdown is not treated.

4 1 Dunn 938

.\~/f')

2 Q In order to demonstrate effective 3 core cooling, was it necessary for your analysis 4 to assume that both or two HPI trains were

(~ 5 available? .

6 MR. FISKE: Which analysis?

7 MR. SELTZER: The analyses ,that were 8 done in support of GPU Exhibit 121.

9 A No.

10 Q Why, if you know, wer,e two HPI 11 pumps assumed available?

12 A To provide.some chance that the analysis 13 would produce the expectation of cladding 14 temperatures within the five criteria of 15 10 CFR 50.46.

16 Q "To provide a chance," what does that 17 mean?

18 A At the time this work was done,'I don't 19 believe that we were under the impression that i

20 even with two high pressure injection pumps 21 operating,that' we could assure that the peak 22 cladding temperatures could be held below 2200 23 degrees Fahrenheit, and we had strong indications that they couldn't be held below those values

(^}

s_-

24 i 25 for one HPI.

l t

l .

i Dunn 939

(-s) 2 Q What did the analysis eventually 3 show?

4 MR. FISKE: You mean as reflected

f 5 ,

in this exhibit? -

6 A I would really prefer being able to check.

7 ,Q What would you like to have at your 8 disposal to check? Table 57 9 A Yes, Table 5.

10 Q What is the answer? ,

11 MR. FISKE: What is the question?

12 (Record'was read back.)

b

\_/ 13 MR. FISKE: As to what?

14 MR. SELTZER: Whether even given 15 -

the chance the assumptions that were 16 less conservative than the licensing 17 standards, the plans could achieve 18 effective core cooling.

19 A- The resultant temperatures are indicated 20 in Table 5 and they indicate for the .075 square 21 foot break, the case with no steam generator 22 blowdown, two HPI's operating, it is expected 23 to exceed 2200 degrees Fahrenheit. The steam f 24 generator blowdown treatment with one HPI

(

25 available also expected to exceed 2200 degrees

1 Dunn 940 (s

2 Fahrenheit. A combination of steam generator 3 blowdown and two HPI pumps available is indicated 4 to exceed approximately 1600 degrees Fahrenheit k 5 and was believed to be below 2200.

6 Q subsequent analysis confirmed that 7 it is below 2200?

8 A The way the general evaluation proceeded 9 after this was to install a pump trip as opposed 10 to utilizing steam generator blowdown. I don't 11 believe any subsequent analysis on that particular 12 point has been made.

13 Q Install a pump trip to trip which 14 pumps?

15 A Reactor coolant pump trip.

16 Q would you turn to page 6 of GPU l

17 Exhibit 121. Do you see just above the middle 18 of the page where it says, "In summary, the results 19 from this preliminary analysis indicated the 20 following"?

,y 21 A No. Yes.

22 Q Item 2 of the summary says, "If an 23 arbitrary reactor coolant pump trip at the worst 24 time must be assumed, compliance to 10 CFR 50.46 25 cannot be shown with present plant equipment,

1 Dunn 941 ,

v

(~' >

^

2 realistic operator actions, and a single failure."

3 Is that conclusion a correct summary 4 of the analysis?

( 5 A I would.not say so today.

6 Q Did you believe it was a correct 7 summary of the analysis at the time it was written 8 in June 19797 9 A I don't know that I asked that question that 10 way. ,.

11 Q If the peak clad temperature exceeds 12 2200 degrees, then it has exceeded the limits of A

(,) 13 10 CFR 50.46, right?

~

14 A Yes.

15 Q Table 5 showed that for two of the 16 three cases, peak cladding temperature did exceed i 17 2200 degrees, right?

18 A Yes.

l 2

l 1

19 Q Was this the first time that the- ECCS l

l 20 Analysis Unit had apprised itself of peak cladding 21 temperatures for termination of reactor coolant

~22 pump in the middle of a transient?

23 A This is the first time we had performed

{

,/~ 24 in-depth analysis on accidents which involved the 25 termination of the reactor coolant pumps during

( ___

=_ . . - _ .

l 1 , Dunn 942 0 2 the course of the accident and had reasonable 3

high pressure injection flow.

4 Q Before doing these analyses,

( 5 ECCS An'alysis had assumed that no pumps running 6 was a worst case, isn't that right?

A We had assumed there were two conditions 7

g which had to be included in the licensing base, 9

n Pumps and continuous pumps.

10 Q Did you think that no, pumps and I

11 continuous pumps bounded the case of pumps 12 . terminated in the middle of a transient?

13 A No.

14 Q Are yoh saying that before you did 15 the analysis that is reflected in GPU Exhibit 16 121, you did not consider that you had bounded 17 the case of pumps being terminated in the middle 18 of a transient?

i 19 A That's correch..

20 Q Had you ever discussed within 21 B&W why the pumps terminated in the middle of 22 a transient case had not been analyzed prior to 23 3""* I9792 4

24 A Prior to approximately June 1979, it was 25 the established practice within the industry that

_--. _ ._ __ -__ . _ _ _.. . _ _ _ _ _ _ _ _ _ . . . - . . . _ ~ . _ . _ _

i 1 Dunn 943

\2 2 a loss of outside power would occur at the time 3

3 the plant was removed from the grid, and if the 4 loss of outside power did not occur at that time,

( 5 or reasonably quickly thereafter, power would be 6 available.

7 Q Was anything available to operators 8 that you know of prior to the Three Mile Island 9 accident that would alert them to the fact that 10 terminating pumps in the middle of a transient 11 might be a worst case than terminating pumps right 12 at the start of a transient or leaving pumps on 13 throughout a transient?

14 A Nothing was available that I know of.

15 Q on page 6, item 3 says, "If an early 16 pump trip is utilized, this action must be i

17 completed quickly (1 to 2 minutes after ESFAS 18 actuation)."

19 Does that refresh your recollection 20 that one to two minutes after emergency safeguards 21 actuation was the time within which B&W concluded 22 the reactor coolant pump should be tripped?

23 I think you testified this morning

/~)

' 24 that you couldn't recall exactly how many minutes.

%)

25 MR. FISKE: You mean concluded as a

1 Dunn 944

("h

\- 2 result of this analysis? You are talking 3 of this time frame of June 1979, right?

4 MR. SELTZER: Yes, after the Three

(, 5 Mile Island accident.

6 A This sentence indicates one to two minutes.

7 our evaluations have consistently indicated that 8 trip action is needed early. As to whether our 9 past or present decisions on what the exact time 10 might be, this does not assist my recollection.

11 . For the record, that sentence is 12 obliterated on the official copy or the first

~

13 line of it.

14 Q You said it was industry-established 15 practice that either you were disconnected from 16 the grid at the moment of the start of the

17 transient or you had off site power throughout 18 the transient.

19 Do you know what competing NSS 20 manufacturers were prescribing before June 1977 2; with respect to pumps running or pumps off?

22 MR. FISKE: You mean June 1979?

23 MR. SELTZER: Yes.

24 A No, I do not.

25 Q You don't know that Westinghouse e v - -- -y. .-. - --. _y ,-er. , - . m. --..z. .y...,_, , _ . - - . . - - , < ... -,,w..- --r,,,

1 Dunn 945 O 2 previously had been prescribing shutting off the 3 reactor coolant pumps at the onset of a transient? I 4 A No, I do not.

l. 5 Q Do you look at the topical reports 6 of your competitors?

7 A Not frequently.

8 Q Do you make it a practice to ask 9 people in your unit to review competitors' topical 10 reports? e 11 A Not frequently.

12 Q Is there some reason why you do not O- 13 think those are a source of useful information?

14 A Yes.

15 Q Why?

16 A They are mostly blank.

17 Q Why, because data is proprietary?

18 A Yes.

19 MR. SELT,ZER: I would like to mark 20 as GPU Exhibit 122, a memorandum from 21 Cartin to Luken, subject "Toleco Edison 22 Company Status Report," December 19, 1978, 23 with a copy to Mr. Dunn.

(Memorandum dated December 19, 1978

( )_ 24 i

25 from L. R. Cartin to R. C. Luken, subject

]

~ -

-, , .- , 7 T. _ , . . . . . . . , _ _ . _ . . - _ - ,,.... .-.., _.... _ _.... .,.. ,.,_.- -._.,-.-...- - -..._.- ... ._.._.,. _..

1 Dunn 946

.S 2 "TECO Status Report," with a copy to 3

Mr. Dunn, among others, marked GPU Exhibit 4 No. 122 for identification, as of this

( 5 date.) ,

I 6 Q Is GPU Exhibit 122 a copy of a 7 mem randum which you received?

8 A Again, I don't recall the receiving.

9 Q Are you familiar with it?

10 A I'm familiar with the subject matter 11 discussed. Certain parts of it.

12 Q Are you familiar with the subject 13 matter discussed in item 67 -

14 A Yes. ,

15 Q what is the dual setpoint control 16 logic that is referred to here?

17 A The steam generator setpoint control for 18 the level of auxiliary feedwater was to have been 19 one level for non-LOCA events and an alternate l

og level for LOCA events.

21 9 '

What did that have to do with the i

22 pumps running c a s ta ?

I 23 A At ne time, it was suggested that the l

1 24 key for switching from one setpoint to another 1

25 value could be the status of the reactor coolant m .__ - _ _ . . _ - _ - _ _ _ ._ .,_ . _ _ . . _;1 , _ _ _ _ _ _ _ _ _ - _ _ _ -

__1 Dunn 947

\_/ 2 pumps.

3 Q ,

Is this what triggered your study 4 of pumps rbnaing case?

( 5 A , Evaluation of the. pumps running case on the 6' 205 plant was performed because of concerns -

7 generated by Integration, concerns which to some 8 extent center out of Toledo issues at that time 9 and the Integration personnel were Mr. Cartin, 10 on the one hand, and Mr. Swanson on the other.

11 I think' that is about as much as I know. -[ ' 'i '

- /

12 Q Is the answer yes?

/ '[

n/

s,_ 13 A. No, the answer is what I said.

14 Q -

I thought you said , Ca' rtin an'd '

i 15 Swanson and Integration pus,hi$g for this study was ,,

(/

16 an outgrowth of Toledo Edison's concerns? ,

A .

17 A Yes, but as to~whether they were the ~' .

18 particular ones mentioned in this section here.--

19 Q' Do you see the note that' ends item o?I

,e 20 A Yes.

21 Q There is something referred to 22 there as a "FOAK analysis." Do you see tha't? -

23 A Yes.

(~}

Q,)

24 .Is FOAK B&W's secret code for "first of a~

O 25 kind"?-

J J f

i

/ ,-

u

e j'4

~

1 Dunn 948 O

O 2 A Yes.

3 Q The note writer says, "The customer 4 should not be informed of the ECCS Analysis

( 5 efforts to examine the pumps running case. It 6 is imperative that B&W be totally prepared to 7 defend an FOAK analysis of this type or to have 8 a planned course of action if results are 9 unacceptable."

10 Is it correct that as of December 19, 11 1978, ECCS Analysis had not studied the effects 12 of the pumps running case?

/~N r s .

\/ 13 A No, I don't think that is fair.

14 Q What had you done as of this date on 15 the pumps running case?

$ 16 A We had reached a judgment on the issue.

17 The judgment had been consistent since a time frame 18 on the order of 1973, that in the pumps running

!e 19 case, a small break -- in a small break, the core t

20 would be cooled by a flow process, and working 21 with the individuals involved in the Toledo effort, 7 22 there were questions in their mind about that 23 judgment.

24 Q There is a reference to B. M. Dunn 53, \-- .

_ 25 in the middle of item 6. Do you see that?

?

._ M "

b . _ _ m. - __ _ -

1 Dunn 949 A Yes.

Q The sentence that surrounds the use of your name says, "This course of action 4

will require identification of funding (B. M. Dunn ,

to secure) to resolve this unanalyzed small break."

What did you understand they were g referring to when they said "an unanalyzed small g

break" for which you were going to obtain the

"" "9 10 ,

A The resolution, chosen resolution, for the 12

" *#"* - raised by these individuals was to do a g computer evaluation of a small break and to demonstrate that*the pumps running situation was not more severe or did not pose as significant a challenge to the core cooling system as the pumps 1,4 off case.

18 Q S that was an ECCS analysis of a g small break with pumps running that had not been analyzed before?

A That was to computerize it.

Q It had not been computerized before?

22 l

A I'm not sure. At this time, we could not 23 i

recoup any computerization of such an accident.

i 3 24 w/ -

Q After you got Cartin's note saying, 25

,, ,- - , - . , - -_----r-m-, ,__m- ,-.% .- - _ _ - , _ _ - _ . . . -

1 Dunn 950 r"

\J 2 "The customer should not be informed of the ECCS Analysis efforts to examine the pumps 4 running case," did you then keep your work quiet fr m Toledo Edison?

5 ,

6 MR. FISKE: You mean did Mr. Dunn tell them?

7 MR, SELTZER: That's right.

8 g Q Or did you keep it a secret?

A I dnt recall whether Toledo was informed 10 gg of this or not. I don't believe I did any 12 i"f #"i"9' b)

( g Q You did not leak it to them?

MR. FISKE: I object to the foru of the question.

g A I did not respond to this note, if that is g what you are talking about, or any implication that gg anybody there can make me keep my mouth shut if I gg don't want to.

(Continued on the following page.)

( 21 22 23 24 25

I 95J Dunn-

[h v

2 Q The blue book was issued when, May 77 3 A Approximately.

4 ,Q 1979. Were any new analyses l 5 performed in order to generate what is the blue 6

, book?

7 MR. FISKE: What do you mean by 0

"new"? New after when?

9 MR. SELTZER: After the Three Mile 10

, Island' accident. -

11 Q Or was the blue book based on things 12

, that you already knew at least qualitatively?

\_, '

13 MR. FISKE: You are sort'of qualifying i 14 the question. I am not quite sure where i

15 it is now.

16 Are you asking him how much if any 17 additional work was done after the Three l

18 Mile Island accident before the blue book 19 was issued?

20 MR. SELTZER: No. That is a different 21 question. ,

22 Q Does the blue book rest on any 23 knowledge that was generated after the Three Mile O

\ ,/ 24 Island accident?

25 A In that the blue book contains specific

t 1

Dunn 952 2

numbers created by computerizing simulations of 3 certain events, it in part rests on information 4

put together af ter Three Mile Island.

( 5 Q You have referred in your testimony 6

to conclusions which you knew qualitatively. As 7

you have used that phrase, did the blue book 8

contein anything which you had not known 9

qualitatively prior to the Three Mile Island 10

• accident? .

11 MR. FISKE: Number one, I don't 12 remember Mr. Dunn using the phrase C)- .

13

" qualitatively," but I might be wrong .

14 In any event, I think it requires some 15 definition before he an swe rs this question.

16

, Q In discussing ECCS, you have 17 referred from time to time to understanding 18 something qualitatively, haven't yeu?

19 A I don' t know whethe r I have done that in the 20 deposition or not right now. I have done it 21 outside of the deposition.

22 Q what does that mean?

23 A I think it can have a great many meanings.

() 24 Q For example, as you use it, could it 25 mean knowing that the pumps ought to be turned

1 Dunn 953 2 off promptly but not knowing whether "p romp tly "

3 means one minute, two minutes, or four minutes.

4 MR. FISKE: I object to the form of

( 5 that question.

6 If you are asking him if he reached 7 that conclusion before~the Three Mile 8 Island accident, I will let him answer that.

9 -

MR. SELTZER: I am not using that as 10 a specific example of something he knew 11 qualitatively. I am just saying that 12 that is what I mean by " qualitatively."

13 You couldn ' t put a quantified judgment on 14 something, but you more generally 15 understood it.

16 Q Do you understand what I have just

( 17 said, or is that still confusing you?.

18 MR. FISKE

It is still confusing me.

19 Q You said that the only new analysis 20 that was incorporated in the blue books was on

- 21 compute r ge n3 rated numbe rs . Were all of the 22 concepts that were in the blue book concepts 23 that you had daveloped before the Three Mile 24 Island accident?

s.

25 A The entire blue book is not mine. Nor is l

1 Dunn 954

( -

2 it ECCS Analysis'.

3 Restricting my commen ts to Chapter 6, 4 which contains the analytical contributions by l ( 5 ECCS Analysis, the basic model u,tilized . for 6 those evaluations was model developed prior to 7 Three Mile Island. Certain alterations were made 8 in the model to demonstrate, or rather to 9 quantitatively evaluate specific transients.

10 The te rm " quantitative" is us'ed 11 because it was desired to compute numbers, and 12 the conclusions of those evaluations were O ~

\- 13 consistent with the assumptions and beliefs of 14 ECCS analysis prior to Three Mile Island.

15 Q What is the B&W Comprehensive 16 ausiness Plan?

17 A It is a high-level report generated by 18 the top officials of the company and meant to 19 communicate the general direction of the company 20 over the period indicated in the report.

21 Q How frequently is a comprehensive 22 business plan generated, to the best of your 23 knowledge?

( 24 A To the best of my knowledge, which is based 25 only on the periods of time in which I have been

4 i

1 Dunn 955 2

involved in it or come in contact with it is 3 once a year.

s '

4 Q I o you receive a copy of the

( 5 comprehensive business plan?

6 A I would say not normally.

7 Q Have you been asked for your comments 8

on any B&W comprehensive business plan?

9 A I don't recall being asked for any comments 10 on the comprehensive business plan.(

11 Q Why did G. E.. Anderson give you his 12 comments on the B&W comprehensive business plan in November 19'797 13 14 MR. FISKE: Which document is that?

15 MR. SELTZER: Anderson to Dunn, 16 November 23, 1979, subject: Comments on l

l 17 B&W Comprehensive Business Plan. It is 18 going to be GPU Exhibit 123.

19 Q Do you know why he gave you his i 20 comments?

l l

i 21 MR. FISKE: I object to the question 22 unless it is limited to something Mr.

23 Anderson said to him.

() 24 Q Do you know why Anderson was sending 25 you his comments on the B&W comprehensive

1 Dunn 956 O 2 business plan?

3 A I believe I do.

4 Good.

Q Tell us.

( 5 MR. FISKE: I don't object as long 6 as it is not speculation.

7 A At one time, Dr. Don Roy sent a document 8

around which was like a comprehensive business 9 plan. It w'as, however, no more than Don Roy's 10 support work for a B&W comprehenside business 11 plan. Employees in the company were asked to 12 .

comment on Dr. Roy's paper and provide feedback.

13 I believe this is feedback on that and 14 mislabeled as the B&W comprehensive business 15 plan.

16 I have not asked for feedback on a 17 B&W comprehensive business plan.

18 (Continued on next page.)

19 i

20

(.

22 23

() 24 25

,,,~wo,,-, --r---, - - --.----r-,--- - ,,, , ,4,,,.,-a,--.m , , - , , , , ,<,,,,,w,n-,-,--wy w--,-a-,- - -- -w--e, - -,, ,

I hd1 1 Dunn 957 2 Q On page 2, Anderson tells you that --

3 MR. SELTZER: Let's mark that.

4 (Two-page memo dated November 21, l 5 1979 from G. E. Anderson to B. M. Dunn, re i

6 " Comments on B&W Comprehensive Business 7 Plan" was marked GPU Exhibit No. 123 for I

8 identification as of this date.)

9 BY MR. SELTZER:

10 Q You see opposite page 13, Anderson ,

11 comments that "The details of 10 CFR 21 have not 12 been passed down to everyone in B&W Engineering."

Oi C/ i 10 CFR Part 21 is the portion of the 13 14 NRC regulations that require people who have 15 knowledge of defects in nuclear equipment to 16 notify the NRC and owners, right?

17 A Yes.

18 Q Did you ever talk to Anderson about 19 why he believed that the details of that Federal 20 regulation had not been passed down to everyone in B&T Engineering?

( 21 22 A No, I don't believe I did.

23 Q Did you keep a copy of Don Roy's

("%

( ,) 24 draft to which you believe Anderson is commenting?

25 A I don't know.

, r y -e r-- + - - - - - - , - ---, - - , - , - - - , . . -, . - , , - -.-. ,~-

2 1 Dunn 958 O

O 2 Q Anderson is the representative from 3 your unit who you say regularly gives lectures 4 at training sessions for operators, is that 5 right?

6 A Yes.

7 MR. SELTZER: I would like to mark 8 as GPU Exhibit 124 a memo from Mr. Dunn to 9 Mr. Parks, subject " Technical Training Program 10 for B&W," April 7, 1980. 9 11 (Memo dated April 7, 1980 from B. M.

12 Dunn to C. E. Parks, re " Technical Training n .

13 Program for B&W," was marked GPU Exhibit N'o .

14 124 for identification as of this date.)

15 BY MR. SELTZER:

16 Q When I referred to Andersen's 17 participation in training programs, that is 18 participation that he has had since the Three Mile 19 Island accident, right?

20 A Yes.

21 Q Is GPU 124 a copy of a memo that you

(

22 sent to Parks on or about April 7, 1980?

23 A Yes.

24 Q In the Anderson who sent you the 25 attached memorandum the Anderson who gives training

3 1 Dunn 959 2 courses on behalf of ECCS?

4 3 A Yes.

4 Q Since April 1980, has he been given

( 5

)

a chance to improve his background in thermodynamics?

6 MR. FISKE: who, Mr. Anderson?

7 MR. SELTZER: Right.

8 A I don't know. I don't share his opinion.

2 9 Q You don't share his low opinion of 10 his background in thermodynamics? .

11 MR. FISKE: I object to the form of 12 the question.

(:) -

13 -

what opinion of Anderson's don ' t you Q

14 share?

15 A That his background in thermodynamics has 16 hampered his working efficiency.

l .

17 Q Have you ever told him that?

18 A I don't know.

19 MR. SELTZER: I would like to mark as 20 GPU Exhibit 125 a memorandum containing

( 21 statements by someone and additions by Mr.

22 Dunn, Mr. Bingham, and no date.

23 (Memorandum undated, containing i

(_) 24 statements by someone and additions by Mr.

25 Dunn and Mr. Bingham was marked GPU Exhibit i

I l

4 4 1 Dunn 960

[h '

LJ 2 No. 125 for identification as of this date.)

3 BY MR. SELTZER:

4 Q This was produced very recently from 5 your files.

6 Can you identify the GPU Exhibit 1257 7 A GPU Exhibit 125 is the notes from a creative 8 decision-making process performed several years 9 ago on the general subject of what will happen 10 within the overall area of ECCS in the next few 11 years.

12 Q Who attended this consciousness raising (1) 13 session?

14 A I attended it. Bill Bingham attended it.

15 Q Bob Jones?

16 A I don't know. I am trying to place the 17 other person that I know of. I think it was Said 18 Farrek. There were approximately seven or eight 19 people in attendance.

20 Q From what group were those seven or 21 eight people drawn?

22 A In such a seminar, we draw from a wide 23 variety. We had some ECCS personnel, some systems 24 analysis technology personnel, and some people 25 from unrelated fields.

I a

5 1 Dunn 961 2 Q All from B&W7 3 A I believe they were all from B&W.

4 Q Would you turn to page 4, at the top 5 of the page.

6 What is item 16 at the top of the 7 page, "We should eliminate the Cat & Mouse 8 relationship between NRC and B&W"?

9 MR. FISKE: That is one of Mr. Bingham's 10 additions? ".

11 MR. SELTZER: No, that is under item 12 27, further discussion,*just before "We gs ,

(_ should hire a sexy pulic relations person..."

13 14 A In the creative decision-making process, and 15 I ar not sure if you are familiar with the process, 16 any and all ideas are put down as raised by an 17 individual. . No accounting that the individual 18 raising the idea is made, no negative comments 19 about any idea is allowed. This process took 20 place several years ago. I could only guess what 21 that means.

(

22 Q Was that your suggestion?

23 A No. I believe I was operating the process g4 and not allowed to make suggestions.

25 Q Why do you and Bingham have items

6 1 Dunn 962

\~.

2 that appear as Dunn additions and Bingham 3 additions?

4 A I think tha: --

I do not know actually. I 5 don't recall it that much. I was speculating.

6 Q was there any follow-up after this 7 list of ideas was generated?

8 A No.

9 As I recall, I wanted to follow up 10 with it and do something with it, ma'ke some use 11 of it, but my time became not available.

12 Q Do you do this often?

13 A Not as structured as this.

14 Q on page 78, in the lower right-hand 15 corner, --

i 16 MR. BENEDICT: Page 478.

17 Q -- you see item 18 at the top?

i 18 A Yes.

19 Q "We should engineer the plant before 20 we sell it."

\

21 Do you know whose idea that was?

{

I' 22 A No.

23 Q Did you think it was a good idea when 24 it was said?

25 A This process was several years ago. I don't I - - - -

7 1 Dunn 963 00 2 know what I thought at the time it was said.

3 Q What is the H atchet Committee?

{

4 A I recall the words " Hatchet Committee," the

)

C! 5 title, but I don't recall what it was or is.

6 Q Don't people in your business talk 7 about being hatcheted by the NRC?

8 A Yes.

9 Q What does that phrase mean?

10 A It can mean one of two process'es. The most i

11 prevalent use of the word refers to the

~

l 12 identification and working of one vendor through 13 a process and saving the other two for later. -

f 14 Within the vendo'r definition here, I am thinking l

15 of mainly the PWR's. Some problems would 16 involve the PWR's as well. Saving the other two 17 vendors, reaching a resolution to some. extent 18 with the first vendor, going after the second 19 vendor following that, and going after him to a 20 more severe level of compliance, and I am speaking of it as a vendor issue which certainly also

( 21 22 involves all the vendors' customers. .

23 The second use of the word is just 24 plain arm twisting by the NRC.

25 Q GPU Exhibit 125 reflects a serious

[

8-- 1 Dunn 964 2 effort to generate good ideas for future 3 operations, is that right?

4 A Yes, it did. At the time it was generated, 5 I felt it was a serious effort to develop some f

6 insight into what may be occurring over the coming 7 years in ECCS-related matters.

8 MR. SELTZER: I have no further 9 questions at this time.

10 Your witness, Mr. Fiske.,

11 MR. FISKE: I don't think we have any 12 questions for Mr. Dunn.

~

13- (Time noted: 3:45 p.m.)

14 15 BERT M. DUNN 16 17 Subscribed and sworn to 18 before me this 29 day 19 of b , 198 p o

g h & G M .d 21  % -

{ u-~ . Spg i, i m .

22 23 24 25

~- . - . - . . - . _ - _ - - _ - - . . - - - . . - . - - . - . . . . . -. . - - _ . _ - - - .

1 965 l

. O)b/1 CERTIFICATE 2

STATE OF NEW YORK )

3

ss.:

COUNTY OF NEW YORK )

4 JOSEPH R. DANYO l[- 5 I, , a Notary Public of the State of New York, do hereby certify that the continued deposition of ,

BERT M. DUNN was taken before me on April 7, 1981 consisting of pages 845 through 964  ; ",

I further certify that the witness had been previously sworn and that the within

( .

13 transcript is a true record of said testimony;

• That I am not connected by blood or marriage with any of the said parties nor interested directly or indirectly in the matter in controversy, nor an I in the employ of any of the counsel.

18 IN WITNESS WHEREOF, I have hereunto set my hand this day of , 1981, 20 .

_ 21 99 03

$$f r

/4/\llQ O

~

JOSEPH R. DANYO 1

v 24 25

_ - . _ _, . . . ~ _ _ _ . . _ _ _ . ,

April 7, 1981 966

^ '

IND EX uj Witness Page Bert M. Dunn 847

? .

o0o 1

E XH I B I TS f '

, 'GPU FOR IDENTIFICATION PAGE

~110 Letter from D. R. Patterson 847 to Mr. McFarland dated April 27, 1978. S.

111 Memorandum dated May 25, 870 1978 from Mr. Bailey to Mr.

• Levandowski, subject "Small O,. Break Report."

112 Memo dated January 19, 1979 877 from ".. C. Jones to R. E.

Lightle re " Response to TVA Letter K-5020."

113 Memorandum dated May 17, 1979 879 from J. D. Carlton to E. A.

Womack re "Small Break LOCA Auxiliary Feedware Require-ments."

114 Memo from Mr. Dunn to Mr.

882 Duerson, subject CPR Work

,o n RELOAD Contracts, dated January 18, 1978.

115 April Activities Report 894 dated May 2, 1978.

AN 4'e -W 4 - b e

1

. April 7, 1981 967 EXH I B I TS (Continued)

GPU FOR IDENTIFICATION PAGE 116 Memo dated May 29, 1979 901

~(1 from Mr.

117 Covering memorandum dated 930 January 31, 1979 from B. M.

Dunn to E. A. Womack en-closing January Activities Report.

118 Memorandum dated June 7, 931 1979 from R. C. Jones tg J. H. Taylor, s ub j e ct " Pumps Running Analyses - Record of Telecon," with copy to Mr. Dunn, among others.

O)

\- 119 Memorandum dated June 8, 1979 932 from J. H. Taylor to Dis-tribution, subject " Longer Term Work Expected by NRC,"

with copy to Mr. Dunn, among others.

120 Memorandum dated June 8, 1979 933 from H. A. Bailey to Distri-bution, subject "Small Break LOCA with RCP's - PSC," with copy to Mr. Dunn, among others.

121 Memorandum dated June 22, 935 1979 from L. R. Cartia to E. A. Womack, subject "Small Breaks Guidelines," with copy

(_ ' to Mr. Dunn, among others.

122 Memorandum dated December 19, 945 1978 from L. R. Cartin to R.

C. Luken, subject "TECO

/~'\ Status Report," with a copy to Mr. Dunn, among others.

.s ,- ,,a u a a w L w.n. i

j 968 April 7, 1981 EXH IB I TS (Continued)

I GPU FOR 4 ,

- IDENTIFICATION PAGE f, > -

123 Two-page memoranum dated November 21, 1979 from G. E.

Anderson to B. M. Dunn, re

. " Comments on B&W Compre- >

, ,. ; , hensive Business Plan." 957 1

124 Memo dated April 7, 1980 from B. M. Dunn to C. E.

p Parks, re " Technical Train-ing for B&W." , 958 125 Memorandum, undated, contain-ing statements by someone, and additions by Mr. Dunn and Mr. Bingham. 959 t O ,

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