ML20072J134
| ML20072J134 | |
| Person / Time | |
|---|---|
| Site: | Three Mile Island  |
| Issue date: | 03/24/1981 |
| From: | Dunn B BABCOCK & WILCOX CO. |
| To: | |
| References | |
| TASK-07, TASK-7, TASK-GB NUDOCS 8306290950 | |
| Download: ML20072J134 (121) | |
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Continued deposition of THE BABCOC:$ ,
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E s 2 A P P.e a r a n,e e s:
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'n 3 KAYE, SCHOLER, FIERMAN, HAYS & HANDLER, ESQS.
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Attorneys for Plaintiffs
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4 425 Park Avenue
.O By: RICHARD C. SELTZER, ESQ.
6 -and-1 ANDREW MacDONALD, ESQ.,
7 of Counsel 8
9 10 DAVIS POLK & WARDWELL, ESQS.,.
y a Attorneys for Defendanta 11 One Chase Manhattan Plaza New York, New York 12
, , p By: ROBERT B. FISKE, ESQ.
d 13
.-and-RODMAN W. BENEDICT, ESQ.,
, 14
- /' of Counsel
. 15 16 17 Also Present:
18 DAVID TAYLOR
,. 19 i
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23 s,
24 25 l
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- _ . - . _ _- . _=_ -
1 728 f
\ 2 B ERT M. D UNN, resumed, having 3 been previously duly sworn, was examined i
4 and testified further as follows:
(, 5 EXAMINATION (Con t ' d . ) .
6 BY MR. SELTZER:
i- 3 7 Q Mr. Dunn, you understand that i
8 everything you say today is going to be testimony 9 given under oath?
10 A Yes. ,
11 Q Have you ever been employed by any 12 company other than B&W that manufactures nuclear
~
13 steam supply systems? ,
I 14 A No.
! 15 Q Who was the individual at Westinghouse 16 whom you testified yesterday held a position at 17 Westinghouse that was analagous to yours?
18 A Vince Esposito.
19 Q How frequently do you see Esposito?
20 A It's irregular.
21 Q When did you first meet him?
22 A My first contact with him was on a telephone 23 call approximately three, four years ago.
24 Q Have you since met him face to face?
GT .
25 A Yes.
( _ _ _ _ _
- _ _ . . -= .- -. -- . . . - . . - _ , _ - - . _ _ _ . - - - . - . - -
1 1 Dunn 729 2 Q Approximately how many times would 3 you say you have met him in the fle sh as it were?
4 A Five or six.
( 5 Q Do you serve on any committees with
! 6 Vince Esposito?
, 7 A No.
8 Q Have you served on any trade 9 association committees?
- 10 A Two. .
i 11 Q Which ones?
4 12 A An ad hoc committee on containment O 13 evaluation sponsored by the AIF and an ANS P
- 14 committee, also on containment evaluation.
15 Q Does that refer to primary r
16 containment or secondary containment?
! 17 A Primary. It refers to the reactor j 18 building.
19 Q The wall between the world and the 20 nuclear plant?
l -
4 21 A I suppose that's one way to phrase it.
! w 22 It is the final containing mechanism.
- 23 Q Is that usually called the t
i 25 A I don't believe so.
1 1 Dunn 730 0 2 Q I may be using BWR terminology then.
3 when did y u serve on the Atomic 4 Industrial Forum committee?
A I'm not sure. I believe I would put it in
( 5 6 the '76 time frame.
7 Q when did you serve on the ANS 8 committee?
g A '77, '78 time frame. I could be wrong.
10 Q ECCS. Analysis does not generally 11 deal with evaluating the containment building, 12 does it?
t
\_/ 13 A Well, I used the t e rm "co nt ainmen t studies" 14 and I was probably too global.
15 The "we" in ECCS and people in the 16 field of ECCS who would understand the words 17 " containment studies," what the committees were 18 actually dealing with were the forcing functions 19 caused by a LOCA to which the containment would 20 be designed, pressure and temperature in the 21 bu'ilding as a whole and within the subcompartments.
22 Q Is it correct that the building is 23 designed to experience under normal operating
'() 24 conditione a negative pressure?
25 A In some cases; not generally.
1 Dunn _ 73J x
2 Q In the 177 plants, is there a 3 negative pressure maintained in the containment 4 under normal operating conditions?
( 5 A There is an' allowable pressure range under 6 normal operations. I have never heard of our 177 7 plants referred to as subatmospheric.
8 Q Does your ECCS Unit study the 9 ability of the containment building to withstand i
10 forces that are released in a loss of coolant 11 accident?
12 A No. We compute the forces and pass those O
k~s 13 on to structural personnel. .
14 Q Had any of your computations 15 anticipated the possible hydrogen explosion that 16 occurred in the TMI-2 containment building?
17 A No.
18 Q Have you analyzed the phenomenon 19 of that possible hydrogen explosion since the 20 TMI-2 accident?
21 A I recall the subject being raised with 22 attention to the apparant hydrogen bubble that was 1
23 within the upper head of the reactor vessel and fA d 24 perhaps in one of the hot legs.
25 Q You and I may be talking about two
1 Dunn 732 2 different things.
3 I am referring to something that 4 occurred on the day of the accident when there was a reported sound of an explosion within the
( 5 6 containment building.
7 Aro you familiar with what I am 8 talking about?
9 A Yes.
10 Q I didn't mean to interrupt you if 11 tha't was what you were focusing on.
12 A As I was saying, relative to the 13 possibility of a detonation of the bubble in the 14 upper head of the reactor vessel and possibly 15 located additionally in the hot leg, B&W made 16 some efforts. I don't know of efforts to -- within 17 B&W to reduce or analyze the apparent detonation 18 which occurred in the first day of the accident.
19 Q Have you seen any study or analysis i
20 of that apparent detonation?
21 A I haven't seen one. I have heard of one.
22 Q Whom did you hear did it or what I
23 unit did you hear did it?
A Well, I wasn't speaking inside of B&W
[v) 24 25 necessarily.
1 Dunn 733 (v 2 What I have heard is that one of 3 the contentions relative to how much oxidation
- 4 occurred during the accident is how much hydrogen
( 5 would have to be produced to cause that amount 6 of explosion if, in-fact, it was caused by 7 hydrogen and that relates back to the expectation 7 8 for core uncovery.
1 4 -
9 As a result, the information has 10 been fed to me loosely by an individual I have had
doing some studies in the area of core uncovery.
11 12 Q Is the source of the hydrogen 2
13 oxidation the zirealloy cladding and, if not, 14 what is the source?
15 A It is my understanding that the primary 9
16 source of oxidation is the oxidation of zircalloy 17 cladding.
18 Q You were aware during the days 19 immediately following the March 28th rumpus that 20 there was a concern over a hydrogen bubble within 21 the reactor, right?
22 A Yes.
23 Q You knew that there was a concern 24 being aired in some circles that the bubble 25 might explode, right?
l
1 Dunn 734 2 A Yec.
3 Q At the time that that was first 4 being floated, did it occur to you that there was
( 5 no free oxygen present in the reactor? ,
6 A No.
7 Q At the time you heard about the 8 formation of the hydrogen tubble in the reactor, 9 did you believe that it could explode?
10 A At the very first hearing of >such a 11 bubble -- I think my reaction was yes, however, 12 I also realized that I was not very well informed
/ 13 on detonation processes. I didn't know about 14 them. I didn't know what might happen or might 15 not happen.
16 Q Did you subsequently learn from 17 others in B&W that the possibility of explosion l
I
- 18 was very low?
19 A Yes.
l 20 Q How quickly after the hydrogen l -
21 bubble was known to exist did you learn that there l 22 was very little likelihood of it exploding?
l 23 A I'm not sure at what time during the course l
1
/~} 24 of the recovery process the hydrogen bubble was 25 identified.
f 1 Dunn 735 2 My first information that it was 3 unlikely to explode was passed to me about 4 four or five hours after I had heard about the
( 5 existence of the bubble..
6 I don't know that at that time I 7 learned that information definitively, I think 8 definitive learning on the subject occurs after I
g the whole story is put together because other 10 people were primarily working on that, not me.
11 Q What did you ultimately learn made 12 it highly unlikely that the hydrogen bubble could p
13, explode?
14 MR. FISKE: Mr. Seltzer, I assume 15 that sooner or later this is going to get 16 connected up to something that is relevant 17 to our case?
18 MR. SELTZER: I won't take very
'19 long.
j 20 MR. FISKE: 0.K. That's why I 21 haven't objected so far.
22 A Well, I don't think I really learned the
$ 23 process of why it was very unlikely. I heard -
[~ 'i 24 some stories relative to oxygen content and i \)
25 recombinations and the detonation concentrations L. .
1 Dunn 736 r
2 were not possible, people were talking about the 3 difference between explosion, detonation and one 4 other mechanism that can combine hydrogen with k 5 oxygen, I suppose, and I.think that's the state of 6 my knowledge.
7 I recognized these people were being w
8 responsible in the field and I accepted their 9 say-so. -
10 Q Other than Vince Esposito, have you
~
11 had any other contact with people at Westinghouse 12 engaged in nuclear plant design or nuclear plant O' 13 analysis?
14 A Yes.
15 Q Who?
16 A I have met Jim Cermac at one time. There
- 17 was a Westinghouse representative on the ad hoc 18 committee --
excuse me, that was not the ad hoc 19 committee, that was the ANS committee. I don't 20 remember his name. And there is another fellow 21 at Westinghouse that I have talked to occasionally 22 on experiments and his name is reasonably well-known 23 but I will be doggoned if I can remember it doay.
24 Larry IIockwriter.
25 Q From your conversations with any of
i 1 Dunn 737
~.
w 2 the people at Westinghouse, do you believe that 3 Westinghouse has chosen cost over performance in 4 its nuclear plant safety hardware?
I 5 A In the conversations I have had with the 6 individuals involved, there has been no basis 7 for a belief one way or the other.
8 Q From your conversations with them, 9 did you have any basis for a belief as to whether 10 Westinghouse had adopted proper attitudes towards 11 safety and design philosophy conducive to handling 12 emergency si.tuations?
(D
\~l 13 A From the conversations I have had with 14 those people, I couldn't deduce that again one way 15 or the other.
16 Q Have you had conversations with it people at Combustion Engineering from.which you 18 could deduce what Combustion's attitudes were 19 towards safety and design philosophy?
20 A No.
21 Q Have you had cont;rsations with 22 people from General Electric from which you could 23 deduce General Electric's attitudes toward safety
,m
( ) 24 and design philosophy 7 25 A No.
r
1 Dunn 738
(~N d 2 MR. SELTZER: I would like to mark 3 for identification as GPU Exhibit 105 for 4 identification. a memo from Dr. Roy and
( 5 Mr. Kosiba to Distribution, subject 6 " Preparation of Operating Guidelines for 7 Small Breaks in Reactor Coolant Pressure 8 Boundaries," April 28, 1979.
9 (Memorandum dated April 28, 1979 10 from D. H. Roy and R. E. Kos'iba to 11 Distribution, subject " Preparation of 12 Operating Guidelines for Small Breaks in r
13 RC Pressure Boundaries" marked GPU Exhibit 14 No. 105 for identification, as of this 15 date.)
16 Q Your name appears on the Task 17 Force in Attachment 1 to GPU Exhibit 105 and 18 the Task Force members are marked for a copy of 19 , GPU 105.
20 Is this a copy of a memorandum which 21 you received in the regular course of business in 22 or about late April 19797 23 A I don't recall receiving it but I don't
() 24 doubt that I did.
25 Q Is Attachment 1 a correct
1 Dunn 739
. ,rx i
2 description of the organization of the Task Force 3 that developed small break guidelines?
4 A Yes.
5 Q Did the group that was working 6 on this Task Force get together for meetings?
7 A Yes.
8 Was there any office space set Q
9 aside temporarily for the Task Force?
10 A Yes. ",
11 Q Was Kane the head of the Task Force?
~
12 A Yes.
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13 Q What role did he play?
I 14 -
A He had provided services to the Task Force 15 in arranging for typing and other things. He was 16 responsible for the assembly of the drafts and 17 the final product. During the meetings of the 18 Task Force, he functioned as a coordinator and 19 administrator for the memb'ers.
20 Q Kane had been on the distribution 21 list of both of your February 1978 memoranda.
{
22 After the Three Mile Island 23 accident, eithez in connection with any meetings
) 24 of the Task Force or otherwise, did you talk with l
25 Kane about the fact that your instructions for
1 Dunn 740
~
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k- 2 operation of high pressure injection had apparently 3 not been sent out by B&W7 4 A I do not recall doing such.
( 5 Q Did Kane ever say anything to you 6 after the accident about the fact that you had 7 created instructions regarding dealing with the 8 small break.such as the one that had occurred at 9 Three Mile Island?
10 A Again I do not recall such. .
11 Q Do you have any belief that you 12 and Kane discussed your instructions after the -
(~h ~
( ,/ 13 Three Mile Is1and accident?
14 MR. FISKE: Well, I am going to 15 object to that, Mr. Seltzer, unless it is I
16 based on a recollection.
17 A I couldn't base it on a recollection.
18 Q Do you have any other basis for 19 a belief that you and Kane discussed your 20 February 1978 instructions after the Three Mile 21 Island accident?
22 MR. FISKE: I don't know what basis 23 there can properly be when he has no 24 recollection.
25 MR. SELTZER: I don't know what
l, 1 Dunn 741 O
V 2 code words you have given this witness to 3 associate with the word " recollection," but 4 he frequently --
- k' 5 MR. FISKE . None.
6 MR. SELTZER: -- testifies to his 7 beliefs about what has happened. If he has 8 a belief now that he and Kane discussed g his February 1978 prescription after the 10 Three Mile Island accident, I would like 11 him to testify to the best of his 12 knowledge. -
O
\-
^
13 MR. FISKE: Well, let's get a couple 14 of things straight. First of all, there 15 are no code words or any other instructions 16 given to Mr. Dunn with respect to what 17 recollection means. Everybody_ understands 18 what recollection means and I assume 19 Mr. Dunn is testifying when he says he 20 recalls or dosn't recall based on what 21 everybody understands a recollection is 22 and I never objected to the question 23 asking Mr. Dunn for his beliefs so long
() 24 as it is clear that the belief is based 25 on a recollection so that we are including
1 Dunn 742 0 2 a recollected belief within the concept 3 of recollection, but beyond that, it seems 4 to me it is just speculation.
( 5 Q What does " recollection" mean to you?
6 A That I have a distinct memory that an 7 exchange took place and I can recall at least some 8 of the circumstances around the exchange.
9 Q Earlier in your deposition, I had 10 asked you whether you could recall people with 11 whom you discussed your February memoranda and 12 you had a memory about some conversations and 13 then I asked you do you have a belief that you
[4 discussed it with anybody elce and you added 15 "Yes, I believe I discussed it with Jim Taylor,"
16 and then you described what you believed was a i
17 conversation that you had had with Taylor about l 18 your February 9, 1978 memorandum, so I think the i
l l 19 record so far as it is clear is that you do have 20 a memory of some conversations which you do not 21 elevate to the level of a distinct recollection, 22 is that right?
23 A I believe that's true.
i
(~)
v 24 Q If you have a memory of a 25 conversation with Kane after the Three Mile Island
l i
l i
1 Dunn 743 C) 2 accident in which you and he discussed or you i
3 believe you discussed your February 1978 4 instructions, I would like you to tell me about
,l 5 that.
6 A I have tried to be consistent on that i 7 Point throughout the deposition and if I had such 8 a memory, I would have used the term either belief 9 or recollection.
10 Past that, I could only interpret 11 the circumstancial evidence or information that 12 was obviously occurring at that time.
- k 13 MR. FISKE: Just so we are a"ll 14 clear here, I don't have any ebjection to 15 questions based on Mr. Lunn's memory 16 if that is distinct from a recollection.
17 MR. SELTZER: 0.K.
I 18 MR. FISKE: I consider the same 19 synonymous but if there is any difference, 20 you can use them both.
21 Q So, in other words, if you have any 22 memory of a conversation or communication or a 23 belief that a conversation or communication took
() 24 Place, if that belief is based on any memory that you have of it, I think your attorney is saying he l 25
I 1 ~. Dunn 744 O 2 would understand that you should testify to it.
3 MR. FISKE: And that is, of course, 4 distinguished from reconstructing something k 5 based on circumstantial evidence.
6 MR. SELTZER: I don't know any 7 court in the land that says circumstantial 8 evidence isn't admissible and I think people 9 do have memories based on evidence of the 10 circumstance. I think it is 'only laymen 11 who think that circumstantial evidence 12 is not good evidence.
13 - MR. FISKE: Again it is a question 14 of whether it is a memory or whether it 15 is a reconstruction.
16 MR. SELTZER: All right.
17 MR. FISKE: That is the differen:e.
18 Q What is your belief about any 19 conversation with Kane following the Three Mile 20 Island accident?
21 MR. FISKE: Well, not to run this 22 into the ground --
23 Q Let me just ask-you-this. Do you 24 believe you had a conversation with Kane after 25 the Three Mile Island accident in which you and
1 Dunn 745
(%
k- 2 he discussed your February 1978 prescriptions?
3 MR. FISKE: And, again, I have no 4 objection if that is based on a memory or
( 5 recollection. .
6 A Not that I could put into the category of 7 memory or recollection.
i 8 Q What category would you put it into?
9 A circumstance. It seems impossible to have 10 issued the small break operating guidelines and 4
11 the instructions that are contained in there -
12 without having had a discussion of the content
(~h -
4
(.,) 13 of either the April 7th instructions we put out 14 or the February 16th memorandum.
15 MR. FISKE: I will move to strike 16 that. answer.
17 Q You don't have a recollection as 18 you sit here today of any actual conve'rsation 19 with Kane discussing your pre-accident 20 prescriptions?
21 A No.
22 Q Have you ever asked Kane what he 23 did with the copies of your memo? I am referring
(~T 24 to your February 1978 memoranda.
N_Y .
25 A I don't recall asking him that.
1 Dunn 746
)
'~' 2 Did you ever ask him whether he had Q
3 taken any steps to get your instructions issued 4 to operators?
( 5 A I don't recall asking him that.
6 Q Don Hallman is listed as a member 7 of the Task Force. Under Hallman, Walters and 8 -Veenstra are listed.
J g Who is this fellow Veenstra?
10 A This would be Jim Veenstra and as I recall, 11 he was a supervisor or principal engineer reporting 12 to Don Hallman.
(^)N
\_ 13 Q What role did Hallman, Walters and 14 Veenstra play on the Task Force?
15 A They reviewed and provided comment on the 16 operational guidance that I was suggesting, 17 they participated placing the final guidance 18 into the language that is used to communicate 19 operational guidance to customers and this served 20 as a check and balance to be sure that what 21 guidance was provided would not cause problems 22 to the reactor facility.
23 Q What role did Norm Elliott, whose
~N name is spelled wrong, play in the work of the Task
{d 24 25 Force?
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l 1 Dunn 747 3
(O 2 A Norm provided review guidance on language 3 with particular attention to whether or not the 4 words we were utilizing would be understood in the
( 5 fashion that we wanted by operators.
And, of 6 course, everybody reviewed the whole procedure.
7 Q Attachment 1 lists consultants.
8 Were there consultants who worked s
9 with the Task Force?
10 A Yes. >=
11 Q Who?
12 A I do not recall. We di~d have people from 13 the operational staff of the utilities. At this 14 time, I don't recall whether the NRC ever 15 participated directly in the guidelines. Members 16 of the NRC were in Lynchburg at that time, however.
17 Q What role did you and the people 18 working with you have in the work of the Task l
19 Force?
20 A The first task we had was to illustrate l 2 and make understandable the range of possibilities 22 in terms of the condition that the reactor system 23 might be in following stabilization of ioss of 24 coolant accident.
25 We then had to provide suggestions l
t w g ,,- 4
,, -gy ,,
1 Dunn -- 748 m
U 2 for management of that condition to cold shutdown 3 which is what we were trying to -- that was the 4 and point for the instructions, and further, we
( 5 had to explain why certain operations might or 6 might not accomplish such a task and where 7 certain other operations might or might not be 8 dangerous.
I 9 Q How long did it take to complete 10 the work of the Task Force? -
11 A I believe approximately three weeks.
12 Q During those three weeks, did you k 13 talk to any operators? -
14 A I don't recall. We had representatives 15 from the operational staffs available to us. I 16 don't know whether they were actual operators, i
t 17 had previously been operators or were just members 18 of the staff.
l 19 Q Representatives of what operational 20 staffs?
21 A There were two or three individuals who met i
! 22 with us from time to time who fit that category.
23 I believe one of them was from the Duke Power
() 24 Company. I'm not sure where the other one was l 25 from.
i
( __ __- - - -
1 Dunn 749 O 2 In answer to a previous question, I 3 should answer that we also prepared a physical 4 description of the small break transients
{ 5 explaining how the course of various variables 6 observable to the operator could proceed depending 7 on the boundary conditions for the accident and 8 that appears in the guidelines as a chapter, a 9 chapter on background.
10 Q what is your understanding as to 11 why you were preparing small break guidelines?
12 A originally it was a request from the NRC Gi .
13 that guidelines for the safe management,of a small i 14 break loss of coolant accident following the 15 initial stah".lization and proceeding to cold 16 shutdown'be prepared.
l 17 Q Did anybody say to you,,in words 18 or substance , that B&W had already prepared, 19 before the Three Mile Island accident, guidelines l
20 or procedures that were substantially what the 21 NRC was asking for?
22 A No.
23 Q In preparing this small break operating guidelines, did the Task Force work from
( 24 25 anything that had been written by B&W before the l
1 , Dunn 750 2 Three Mile Island accident?
3 A Yes.
4 Q What?
( 5 A within the immediate response section of 6 the small break operating guidelines, the 7 instructions for high pressure injection 8 management are the same in essence as those 9 issued in April.
10 Q April of what year? o 11 A That year, j 12 Q 19797 i
("N
(_) 13 A Yes. The instructions issued shortly 14 following the Three Mila Island accident.
15 The chapter on the physical basis 16 for the instructions which explains the course of 17 the variables, the possible course of the various 18 variables within the reactor coolant system and 19 how they would proceed during the early phase of 20 the loss of coolant accident was based on ECCS
/ 21 personnel's cumulative understanding of small (t
22 break loss of coolant accidents and in that 23 fashion relied, to some extent, on our earlier T 24 documented work.
J 25 Q That is, - 1 4.e r documents within 6
r w. n. - -
1 Dunn 751 2 the ECCS Unit? Is that what you are referring to?
3 A Yes, yes, SAR material.
4 MR. SELTZER: I would like to mark
( 5 as GPU Exhibit 106 for identification, a ,
6 handwritten memorandum by Mr. Dunn entitled 7 "Small Break Indications" bearing no date..
8 (Handwritten memorandum by Mr. Dunn 9 entitled "Small Break Indications" marked 10 GPU ' Exhibit No . 106 for identification, as 11 of this date.)
12 Q Are the first few pages of GPU 13 Exhib'it 106 marked for identification pages which 14 you wrote?
15 A It appears to be my handwriting.
16 Q Would you identify, please, what 17 GPU Exhibit 106 is? .
l 18 MR. FISKE: You mean the whole thing?
19 MR. SELTZER: Yes.
20 A It's written in the form of an initial 21 set of notes on what a smal'1 break procedure 22 might be and that refers to the first four pages 23 of 106 which are then repeated in the document
- - 24 with two copies of the first four pages. I'm not 25 sure what the remaining section of the report is.
1 Dunn 752 2 Q After the repetition of the first l
3 four pages, there is an attendance list.
4 Do you see t'na t ?
( 5 A Yes. .
l 6 Q Do you see your fine hand on the 7 attendance list?
8 A Yes.
9 Q And you signed in right above Zoltan 10 Rosztoczy, right? b 11 A Yes.
12 Q It looks like R. C. Jones signed in C) ,
13 also.
14 Do you recognize that as being 15 Jones' penmanship?
16 A Yes. I believe that's the way he signs 17 his nane or prints it, rather.
18 Q Do you recall attending a meeting 19 at or about the time you were developing small 20 break guidelines at which some or all of the people 21 on this attendance list were present?
22 A '*e
. s.
23 Q were you sitting next to zoltan Rosctoczy?
(A} 24 25 A Maybe.
_~_, _
, ,\
4.-
1 Dunn 753 2 Q What, if anything, do you call him 3 for short?
4 A I generally refer to him as Zoltan.
l 5 Q What was the subject of the meeting 6 with these gentlemen?
7 A The subject of the meeting I am recalling 8 was the review of the work which would be performed 9 for submittal to the NRC by May 7th in support of 10 the restart at that time for our operating plants l .
l 11 following the negotiated and scheduled shutdown l
l 12 following reaction to Three Mile Island.
13 'Q Is it your belief that these notes, 14 GPU Exhibit 106, were drafted sometime after the 1$ creation of the small break guideline Task Force I ,
16 and prior to May 7, 1979?
d f
17 A I believe I would be close to speculation 18 in agreeing with your statement.
19 Q Is there any other time when you 20 think'these notes were written? I am focusing on 21 the first four pages, your handwritten notes.
22 A From reading these notes, I think it would 23 be unlikely that they were generated at another
'h
[d 24 time. l 25 Q On the first page of GPU Exhibit 106, y
a
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2 yo'1 })aved,isted "Pos sible Alarms . "
These are alarms xJ s 3 which woe,4d; indicate thtt occurrence'of a small ,
s 4
s hreak loss of coolant aedid nd;).4s r khat corrdct?
(
t =
',. +
f , ,
5 A .,They are alarms,ydhd. cts , may~ Indicate 'the
, , i;5' f
s
's ,,
- 6 possible existence of,a small bteak' loss of
, d
. , s 7 coolant, accident.- ,t '
8 Q Who developed tshis list of the 9 eleven possible alarms? '
10 A I do not recall. F 11 Q You have both low pressurizer level 12 and high pressurizer level on the list of alarms.
O' 13 Do you see that?
14 A Yes.
15 Q Low is opposite high, right?
16 A Yes.
17 Q How is it possible to have both 18 low pressurizer level and high pressurizer level 19 as possible alarms for the same accident?
20 MR. FISKE: Well, I think you are 21 misstating the exhibit, Mr. Seltzer.
22 MR. SELTZER: Well, I am not really 23 trying to pose it as an enigma. I just 24 want to get the explanation.
-( G 25 What do you think I have misstated?
w - . . _ . . --,e.-- . , , , _- ,, - - , , . , , , . . , ,
,..,.,---m. ,,, y . , - , . . . . , . - - , - - . , . , . - - , , . . - - - , , . - - . . - . -
1 Dunn 755
\/ 2 MR. FISKE: You are assuming that 3 the document indicates both low pressurizer 4 level and high pressurizer level as an alarm i () 5 for the same accident.
6 MR. SELTZER: All right. For the 7 same class of accidents.
8 MR. FISKE: We can save a lot of 9 time --
10 MR. SELTZER: I will rephrase it and 11 try and do it more coherently.
12 Q How is it that you could list both I\ ,
(_) 13 low pressurizer level and its opposite, .high -
14 pressurizer level as possible alarms for the same 15 class of accidents, namely, small break loss of 16 coolant accidents?
i i 17 MR. FISKE: I think if you can
~
18 answer the question, it will become clear.
- 19 Go ahead and answer it.
I 20 A The intent of such a procedure would 21 probably have been to cover all loss of coolant 22 accidents which form a continuum in both break 23 sizes and in position for the rupture of the 24 primary system. If the rupture occurs in the 25 reactor coolant system piping, the low pressurizer
1 Dunn 756 O
O 2 alarm is likely. If the rupture, occurs in the 3 pressurizer, particularly high in the pressurizer, 4 the high pressurizer level alarm is likely.
k 5 Q Could you read your note that appears 6 beginning in the text just above the middle of 7 the page?
8 A With the asterisk?
9 Q No, just after that.
10 A "The nonstarred alarms will be indicated 11 for all except very small LOCA's."
12 Q Fine. That's all I want.
O .
\- 13 'Did ,that mean that the possible 14 alarms that have stars next to them would not 15 always occur during a small break loss of coolant 16 accident?
17 THE WITNESS: Excuse me, would you 18 read that back.
19 (Record was read back.)
20 A You used the tyrm "Did not mean" --
"Did 21 that mean," excuse me, and I would have to a
22 interpret the meaning of that sentence today 23 because I do not recall putting this paper together.
( 24 Q Since you are undoubtedly the author i
25 of the paper, why don't you go ahead and explain 1
I
- g. Dunn 757 O t O 2 it.
3 MR. FISKE: Mr. Seltzer, I think if 4 Mr. Dunn says he doesn't remember writing k 5 this paper and doesn't remember what he 6 had in his mind at the time, I don't think 7 there is anything else to ask him.
8 MR. SELTZER: Well, I think the g world would agree that he is probably the 10 best interpreter of words that he has 11 previously written. Even if Beethoven 12 couldn't remember what he had in mind when
) -
13 he first wrote Eroica, if he sat down 14 at the piano he could probably do a pretty 15 good job of interpreting it at a subsequent 16 date.
17 MR. FISKE: I don't know if that 18 analogy is proper or not. If Mr. Dunn 19 does not recall what he had in mind when 20 he wrote this, then I don't think it is 21 proper to ask him to just look at it now 22 and tell us what he thinks it means now.
23 I have absolutely no objection if he remembers what he had in his mind when
( 24 25 he wrote it but that'is the only proper
1 Dunn 758 O 2 question.
3 MR. SELTZER: I thought I remembered 4 from a law school evidence course that a
< 5 witness could be asked to look at something 6 which he has previously written and after 7 you have exhausted his past recollection 8 refreshed, you could then ask him what it 9 means to him today.
10 MR. FISKE: Well, yousmust have 11 -
taken a different law school course at a ,
12 different law school because I am not
\~ 13 aware of such thing.
14 Why don't we take a break. It is 15 11:15.
16 MR. SELTZER: All right.
17 (Recess taken.) ,
l 18 MR. FISKE: Where we were was, you 19 had a question pending where Mr. Dunn 20 had said he did not recall writing this 21 memo.
22 MR. SELTZER: Right.
23 MR. FISKE: And you were asking him
! 24 to now read it and construe it and I was f~S>
~- .
25 taking the position that that was not
1 Dunn 759 O
U 2 proper.
3 MR. SELTZER: Have;you thought 4 better about that proscription?
{ 't 5 MR. FISKE?- I haven't changed my 6 mind. I thought the instruction was 4
7 appropriate.
8 MR. SELTZER: That brings us to 9 this important crossroads.
3 10 Are you going to instruct him not t
- 11 to answer the question?
12 MR. FISKE: Yes, I think so.
O-
\- 13 MR. SELTZER: You are going to 14 throw down the gauntlet?
15 MR. FISKE: I don't know if it's 16 throwing down the gauntlet. I am taking
+
17 the position on this document, ,as to others, 18 as a matter of procedure it is not proper 19 to ask a witness today to read something 20 and ask him what is his construction of it.
21 MR. SELTZER: Fine.
22 MR. FISKE: I think the fact that 23 he wrote it as opposed to somebody else really doesn't make any difference if he
( 24 25 has no recollection of having written it.
1 Dunn 760
/ In other words, the fact that this 2
d cument happens to be in his handwriting 3
4 as opposed to being typed by someone else really d esn't change that.
( 5 6 MR. SELTZER: I assume you abide 7
by the notion that what is sauce for the g goose is sauce for the gander?
g MR. FISKE: I think at least as a 10 general proposition. ,,
11 MR. SELTZER: All right, because 12 I think that this is no more nor less 13 applicable to one side th*an the other. -
g4 If that is what you think ought to be the 15 law of this case, so be it.
i 16 MR. FISKE: That is the law of the l
g7 case for this document.
18 MR. SELTZER: Come on now, let's gg not --
I am sure you don't want to be that 20 small about it.
(
MR. FISKE: We don't have any other 21 22 situation in front of us at the moment.
MR. SELTZER: You weren't blocking 23
(% y testimony just based on the nature of this
( ,)s
~
25 particular document. I thought you were l
~~
I 1 Dunn 763 2 enunciating what you thought was the 3 applicable rule of evidence.
4 MR. FISKE: That is the rule of l 5 evidence applicable to this document, yes.
6 And it may or may not apply to other 7 documents as well.
8 MR. SELTZER: We will certainly 9 cite Fiske on GPU Exhibit 106 when the 10 issue comes up and you are asking us to 11 construe documents.
12 MR. FISKE: If it's a valid
[~h .
\2 13 - citation, fine.
14 MR. SELTZER: I can just see one 15 of your people saying, " Wait a minute, 16 this isn't GPU 106 anymore."
17 I would like to mark as GPU Exhibit 18 107, a memo from Kane to Roy, the subject, 19 "Small Break Procedures," dated April 30, 20 1979 with a copy to Mr. Dunn.
21 (Memorandum dated April 30, 1979 22 from E. R. Kane to D. H. Roy, subject 23 "Small Break Procedures" with copy to
( ) 24 Mr. Dunn marked GPU Exhibit No. 107 for
\m/
25 identification, as of this date.)
1 Dunn 762
(~h
~
2 Q Is GPU Exhibit 107 a copy of a 3 memorandum which you received in the regular course 4 of business on or shortly after April 30, 19797 A
( 5 It's a copy of a memorandum I received i
- 6 on or about April 30, 1979.
7 Q In the box at the top of the page, 8 there is something called file number or reference.
9 Do you see that?
10 A Yes. n 11 Q What is 20A3.07 .
12 A It's an alpha-numeric character which O
k/ ~
13 indicates the location within the filing system 14 at which this particular memo could be retrieved.
15 Q Do you know what the description of 16 that file was?
17 A No, I do not.
18 Q Item 3 in the memorandum says, 19 "ECCS (B. M. Dunn) will put together in words and 20 figures the various small break scenarios (see 21 attachment) from which the adequacy of the procedure 22 can be verified."
M Did you do that?
A
( 24 We put together such a text including 25 words and figures of the various scenarios for
1 Dunn 763 I~)
2 small break loss of coolant accident, yes.
3 Q Where is the work that you and Jones 4 and others in ECCS did for the small break Task l* 5 Force? -
6 A This particular work?
7 Q This and all the work you did on the 8 small break Task Force.
9 Where did you file it?
10 A I don't recall filing anything except the 11 final product.
12 Q What did you do with the rest of the O
/ 13 materials that you had drafted?
14 A Relative to all of them, I'm not sure.
15 I think some may have been contained 16 in a packet of information which I had stored 17 beside my desk in Manila folders.
18 Q Was that turned over to attorneys 19 for consideration for production in this lawsuit?
~20 A The packet was segregated on the basis of 21 was'it connected to Three Mile Island and I believe 22 it was turned over for possible production.
23 Q 'Who made the segregation?
24 A I made the segregation.
x_ -
25 Q Did you believe that this stuff was
.,,m---.-vW
1 Dunn 764 A
}
\/ 2 related to Three Mile Island?
3 A well, that was the basis. I put everything 4 that I had done for probably the first one or two months--I'm not actually sure when I cut off
({ 5 ,
, 6 filing it in this fashion and started filing in 7 the normal fashion--into those packets when I 8 was basically through with them for on-line 9 responsibility. I just kept them there.
10 Q Had you put together,,in words and 11 figures, various small break scenarios similar 12 to these small break scenarios prior to the Three A
V 13 Mile Island accident?
14 A Not in the fashion thct these were put 15 together and not as extensively as these were put 16 together.
1 17 Q How was the way in which you put 18 these together different from the way in which 19 you had put any previous materials together?
20 A Previous material was put together for 21 licensing purposes and organized in a fashion 22 which would demonstrate the capability of the 23 ECCS systems, 24 These materials were put together f
s 25 in a caricature fashion to illustrate the possible
1 1 D.un n 765
/~s 2 conditions that the operators might find present 3 in a -- in the reactor coolant system following a 4 small break loss of coolant accident with
({ 5 particular stress to the continuum of the possible 6 conditions.
7 Q What does that mean, "the continuum"?
8 A Well, where a curve was illustrated, we 9 did not intend that the operator or the people 10 reading the material should believe,that that 11 curve was the exact result to be expected but 12 rather a curve similar to that which could vary (3
\_/ 13 on either side of it was possible. .
14 Q Were these graphic materials 15 included in the small break guidelines that were 16 subsequently issued?
17 A Yes.
18 MR. SELTZER: Let me mark those 19 and then maybe you can show me more 20 specifically what you mean by this 21 continuum.
22 I would like to mark as GPU Exhibit 23 108, the Babcock & Wilcox Operating Procedure 24 Guidelines for Small Breaks of May 5, 1979 25 which have a cover sheet from Don Hallman
.._ - . . . _ . _ . _ . . _ _ _ _ . _ _ _ _ _ _ _ _ . _ _ ~ _ , ~ . _ _ - . _ _ _ _ _ _ , ~ . _ . . _ - - - _ . _ _ . . - _ _ _
1 Dunn 766
'i '
[~/
\- 2 to Ellison of May 7, 1979.
3 (covering memorandum dated May 7, 4 1979 to K. R. Ellison from D. F. Hallman 5 with attached Operating Procedure
((
6 Guidelines for small Breaks dated May 5, 7 1979 marked GPU Exhibit No. 108 for 8 identification, as of this date.)
9 Q Do you recognize GPU Exhibit 108 10 as the small break operating guidel,ines on which
~
11 you had been working and which B&W issued to its 12 plants on or about May 5, 1979?
I 13 A Yes.
14 Q Can you explain by reference to the i
15 charts that are included in this exhibit what 16 you mean by showing the continuum?
17 A Yes.
18 Q Which figure would you like to --
19 A Figure 1 I think does a reasonable job.
20 Q --
start with?
21 A Within Figure 1 there are several possible 22 pressur scenarios indicated. The differentiation 23 between the possible scenarios is primarily break l
! 24 sizes and the intent of such a figure was to i
I 25 communicate that almost any pressure course for 1
s
.m.,. - - - . - ._. , , , _ _ , _ - , , _ . , ~ , , , . , _ , , _ . _ , , ~ , , - . . _ _ . . _ . - . . - . . , . , _ , , . . , . . , _ _ . . .
I Dunn 767 2 the transient would be possible.
3 We see an indication in item 1 of 4 a very large small break; in item 2 of a smaller
( 5 break which takes longer.to depressurize; 3 is a 6 smaller yet; 4 is an illustration of the accident 7 we termed a . 01 to a .02 square foot break with 8 possible interruption of natural circulation; and 9 5 would most 1.tkely be characterized as a leak 10 instead of a break. r 11 The function of 5 is that it 12 stabilizes mass in and mass out and does not lose 13 natural circulation.
14 Q Is 5 a break that is within the 15 capability of one makeup pump?
16 A Not necessarily. The same thing could be 17 had with the high pressure injection system.
18 Q The curve for 4 shows the reactor 19 coolant system repressurizing within less than 20 10 minutes, is that right?
21 A Yes, the curve does.
22 Q Figure 2 is a companion to Figure 1 23 depicting the performance of the pressurizer water 24 level, is that right?
, [')h
\~
25 A yes, 4
, -v, ,,,.m --w,. , . ,
--,.----,-.-y--,---------.-,m - - , , ,
1 Dunn 768 O 2 Q It depicts the performance of 3 pressurizer level for the same breaks that are 4 ,
enumerated in Figure 1?
l 5 A Yes. .
6 Q So that for the break that is 7 numbered 4 as the reactor coolant system 8 repressurizes, pressurizer level recovers, is 9 that right?
10 A In 4, yes.
11 Q What is the break that is numbered 12 6 on Figure 2?
~
13 A I would have to go into the text to find 14 out.
15 Q When you find it, could you let me 16 know what page of the text it is on, please?
?
17 MR. SELTZER: Off the record.
18 (Discussion off the record.)
19 Q How about page 5 where there is 20 a reference to Curve 6, it shows refilling by 1
i
- 21 the high pressure injection.
i 22 A Unless it is mentioned elsewhere in hare, 23 the information on page 5 does not appear to be
] sufficient to characterize what that accident is.
) 24 25 Q So you can't figure out from the 3
.-_..._,_--,,_.,,,,,,-...,_..,.,_m-_..-,.....,..,..r.,_.,_._ ,,..,,,,,r,,,_ m,
. - - . . . . . - .,_.._._,,_m,m._,..r.,..,.,. .
1 Dunn 769 2 B&W small break guidelines what type of break 3 would produce Curve 6 in Figure 2?
4 A well, I said the information on page 5 was l) 5 not that clear. -
6 I would be put in a position of 7 interpreting the result and interpreting what was 8 meant.
9 Q In other words, you don't find 4
10 anything in GPU Exhibit 108 that clearly explains 11 what produces Curve 6 on Figure 2?
12 A well, it clearly explains that it is
, P) x_ 13
~
a refilling by the high pressure injection system.
14 It does not clearly identify what accident 15 sequence went along with that but a refill by f
16 the high pressure injection system could have i
17 that response.
18 Q Have you ever discussed the small 19 break operating guidelines with any B&W plant 20 operators since the guidelines were sent out?
21 A Not that I recall. Not in detail.
22 Q Has any operator ever indicated to i
23 you, either directly or indirectly, whether he 24 found these guidelines comprehensible?
J}
25 MR. FISKE: I am going to object to
1 Dunn 770 O
\~/ 2 the form of that question. If you are 3 asking about a conversation with an 4 operator, that's fine.
( 5 MR. SELTZER: That is what I am 6 asking.
4 7 MR. FISKE: You mean did an operator 8 tell him that he found these guidelines 9 comprehensible?
10 MR. SELTZER: Right. ,
11 Q In words or substance.
12 A No.
O(_/ 13 Q Did any operator tell you'he found 14 these guidelines incomprehensible?
15 A Not that I recall.
16 Q What conversation did you have with 17 an operator regarding these guidelines? i 18 A I had from time to time made myself 19 available to operators during a lecture I have 20 been in the habit of giving on modes of natural 21 circulation possible during a small break LOCA.
22 A latter portion of that discussion is a question 23 and answer series on any issues that they might i
24 want to raise with me.
25 One time I recall asking how they
1 Dunn 77J 2 felt about the guidelines or something to that 3 extent, and I did just recall that a minute ago, 4 and the operator responded that they did not have k 5 the guidelines. .
6 Q What plant were these fellows from?
7 A I could give candidates but I could not 8 be specific.
9 Q Were these operators from a plant 10 that was already in operation? n 11 A Yes.
12 Q Did you ask them whether they had f'h s/ 13 received your April 4th or April 17th instructions?
14 A No, I did not.
15 Q Did you ask them whether they had 16 received any other communication which conveyed 17 the substance of your small break operating 18 guidelines?
19 A No.
l 20 Q How soon after May 5, 1979 was the l 21 meeting with these operators to which you have l 22 just adverted?
23 A This was within the last year.
()
s 24 Q Did you take any steps after the 25 meeting to confirm whether B&W had sent the small
_. - _ - _ . _ _ . . - . _ . _ . ~ . . . _ . , __ ___
~l Dunn 772 b
U 2 break operating guidelines to that particular 3 utility?
4 A No.
( 5 Q So with respect to that particular 6 utility, you have not verified-that there was 7 closure on the small break operating guidelines?
8 A Yes, I believe I have.
9 Q What did you do?
10 A Well, I had verified that there was closure 11 on that issue before that time.
12 Q What had you done to verify that
-this particular utility had received a copy of 13 14 the small break operating guidelines?
15 A The small break operating guidelines are 16 released to all operating utilities with B&W l
17 plants and I have seen the release. I generally
( 18 sign the final release.
19 Q The release goes to the B&W 20 site representative at the operating plant, 21 right?
l 22 A I'm not sure of the actual transmittal l
23 mechanism.
[~)
N-24 Q Do you see the stamp that has haen 25 affixed in the upper right-hand corner of GPU
. -. _ . ~ . . . . - . - - . - - _ - . . - - . . .
1 Dunn 773
/^\
2 Exhibit 108?
A Y***
3 4 Q Do you see the distribution marked to 3, 4, 6,~et cetera?
l 5 5,
6 A Yes.
7 Q 'Do you see the indication of g response requested from or required from 3, 4, 5, 6, 7, et cetera?
9 10 A. Yes, y 11 Q Do you have an understanding that 12 that means that GPU Exhibit 108 was distributed b)
(_ 13 , to B&W site *reprecentatives a't plants numbered 3, 4, 5, 6, 7, et cetera and that a response 14 15 indicating transmittal to the plants was required 16 fr m those site representatives?
17 A No.
18 Q Have you ever verified that the gg plants which were intended to receive the small 20 break operating guidelines actually got the small 21 break operating guidelines?
A In terms of direct contact with the customer, 22 23 I have not. I considered it adequate that once an instruction got to this stage, that the process
{',}
~
24 25 w uld be followed through.
i
1 Dunn 774 2 Q -Did you ever take any steps to find 3 out why the operators that you were talking to 4 believed they had not received the May 5th small
( 5 break operating guidelines?
6 A Well, at the time I was talking to these 7 operators--we really shouldn't be talking about 8 May 5th, the document has undergone revision--
9 but, no, I did not take any steps.
i 10 Q At the meeting that you had with 11 these operators, did you volunteer to give them 12 a copy of the current version of the small break
[
A/ 13 operating guidelines?
> 14 A I don't recall whether I did that or not.
l
! 15 Q Is there any company policy that 16 would have made it improper for you to offer them 17 a copy of the small break operating guidelines 18 at that time?
19 A I don't believe so. ,
l 20 Q Did you say anything to Hallman or 21 Kosiba or anybody in Customer Service about the 22 fact that some operators had apparently not 23 received the small break operating guidelines?
24 A I don't believe I did.
f~]T
\_ -
25 Q Do the lecturers from ECCS who
. . . . - . - .-_.-.,,.....~.-.-..=..-::-;.---,. - . . - . .--
1 Dunn 775
)
a 2 participate in the training program at B&W include 3 the small break operating guidelines as part of 4 their presentation to operators?
( 5 ,
A They would not include the detail that is 6 contained in Part II to an exhaustive extent, 7 rather they would lecture around the possibilities 8 contained in Part I with providing information 9 on the general character of Part II and how it 10 accomplishes its task.
11 It is not the function of these 12 lectures to provide' detailed training on any given
(' >) 13 procedure.
i 14 Q In GPU 107, item 3, it says that 15 you were going to put in words and figures the i
16 small break scenarios "from which the adequacy 17 of the procedure can be verified."
18 What does that mean, "the adequacy 19 of the procedure could be verified"?
, 20 A I would have to interprct that.
21 Q What did you understand it meant?
22 A Well, at the time that this memo was 23 issued, things were moving very rapidly and there was a great deal going on. I don't believe that
( 24 25 I made an effort to criticize that particular
1 Dunn 776 i
\/
\
=
2 phrase, l
3 Q Do you have any notion how at that 4 time it was intended that the adequacy of the
( 5 procedures for management of small break loss of 6 coolant accident would be verified?
7 MR. FISKE: Can I hear that question 8 again, please.
9 (Record was read back.)
10 A No, not at that particular time.
11 Q Returning to March 28, 1979, the 12 day of the accident, you attended a meeting in 13 Allen Womack's office or it was Allen Womack's 14 meeting about 11 ' clock in the morning, then you 15 went to lunch, played cards, and then you came 16 to a meeting in the war room sometime in the 17 afternoon.
\
18 When did you first realize that 19 there was or had been a loss of coolant accident 20 at Three Mile Island?
21 MR. FISKE: May I hear the question
, (.
22 again, please.
4 23 (Record was read back.)
24 A I'm not sure.
f' V
- 25 MR. FISKE
- Are you, just so it is
1 Dunn 777
(~h
\ l- 2 clear, are you asking him when did he make 3 that determination or are you asking.him 4 when did it first appear to him that it was
'( 5 a possibility? In other words, you say 6 " realize," do you mean when did he actually 7 conclude that there was a loss of coolant 8 accident?
9 MR. SELTZER: That is a good wag 10 to say it. ,,
11 Q When did you first conclude that 12 there had been a loss of coolant accident or that I )* '
13 there was in progress a loss of coolant accident?
14 A As I indicated, I am not sure.
15 Q Do you believe that you had concluded 16 that there was a loss of coolant accident before 17 you went to lunch on March 28th?
18 A I believe that there was or I had indicated 19 that there was a possibility that we knew prior to 20 lunch that the core had been involved. In that 21 case, the extent that that in its limited sense is 22 a loss of coolant accident, I may have known it 23 then. To the extent that it later turned out
.( 24 and to the serious nature of it, I don't believe 25 I had become aware of that until after lunch.
} _ _ _
1 Dunn 778 O 2 Q It is part of the design of the 3 plant, prior to the Three Mile Island accident, to 4 lift or open the pilot operated relief valve in j (' 5 response to certain anticipated transients, right?
6 A Yes.
7 Q When the pilot operated relief valve 8 opens in response to certain anticipated transients, 9 do you call that a loss of coolant accident?
10 A No. P 11 Q When do you believe you first knew 12 or concluded that there had been saturation in w 13 the primary coolant system at Three Mile Island?
1 14 A Again, I'm not sure.
15 Q Do you believe that you knew or 16 concluded that there had been saturation in the l
17 primary coolant system before you went to lunch?
18 MR. FISKE: You are again asking 19 him about his recollection, right?
20 MR. SELTZER: Right. Or memory or 21 belief.
22 MR. FISKE: Well, no, it's memory 23 or recollection.
MR. SELTZER: I am including belief
( 24 25 because he uses belief to encompass things I
1- Dunn 779
~T (G 2 that he can remember, also.
3 MR. FISKE: As long as it is memory 4
4 or recollection.
l 5 MR. SELTZER: For me, belief is good 6 enough.
7 MR. FISKE: Well, the question for 8 Mr. Dunn is what he remembers or recalls.
9 A Yes. I'm trying to use the word "bclief" 10 to indicate a positive memory to some extent and 11 I'm not sure.
12 Q You are not sure whether you knew 13 that there-was saturation before you went out to 14 lunch?
15 A That's correct.
i i 16 Q when is the first time that you l 17 recall you were concerned about whether there had 18 been or was proper use of high pressure injection?
19 A In the afternoon when we found out about 20 the super heat.
21 Q So before lunch, you were not 22 concerned about whether there had been adequate 23 use of high pressure injection, is that right?
() 24 MR. FISKE: Well, I will object 25 to the form of that question.
-J7My+ m e, =-t--w-
1 Dunn 780 1
N/ 2 You'can answer it.
, 3 A I left the 11 o' clock meeting with the 4 understanding that the plant was in a stable
( .5 condition. .
8 6 Q Did you have --
7 A or rather an acceptable condition.
8 Q Do you recall having any concern 9 before lunch on March 18, 1979 regarding whether 10 high pressure injection had been pr,operly 11 employed at Three Mile Island?
12 A . No, I do not recall having the concern one 13 way or the other.
14 Q Do you recall anyone at the morning 15 meeting on March 28, 1979 raising any question 16 about the employmen't of high pressure injection 17 at Three Mile Island that day?
18 A I do not recall it. ~
19 Q On M$rch 28, 1979, who, to your 20 knowledge, would be the person most expert at
' 21 B&W on when high pressure injection should be 22 used in response to a loss of coolant accident?
23 A I think there would be two equally capable i
- 2. caneieaees.
c7) 25 Q Who?
,- - . _ . . . _ . _ . _ _ _ _ . - _ . , _ . _ , _ . _ _ , _ , . . ~ , _
i 1 Dunn 78J d 2 A Myself and Mr. Bob Jones. Definitely 3 using your word "most."
4 1 Q As of March 28, 1979, do you believe k 5 that Allen Womack was to any extent expert in the 6 use of high pressure injection in response to a 7 small break loss of coolant accident?
8 MR. FISKE: Well, I think we are 9 going to have a little trouble here with 10 what you mean by " expert." e 11 MR. SELTZER: Knowledgeable.
12 -
MR. FISKE: Was he to any extent O~ 13 knowledgeable?
14 MR. SELTZER: Yes.
15 MR. FIS KE : Well, I guess you can 16 answer that question yes or no.
- 17 THE WITNESS
- Let me have the question 18 one more time, please.
19 (Record was read back.)
20 MR. SELTZER: I will rephrase the i
- 21 question so that with respect to Allen kw 4
22 Womack it is.
23 Q on March 28, 1979, do you believe that Dr. Allen Womack was to any extent
( 24 25 knowledgeable about the proper use of high pressure i
-. ...--,---..,_.~,-..-,~---~--,-------,._.,,.,--.n,,
1 Dunn 782 O
V -2 injection in response to a small break loss of 3 coolant accident?
4 MR. FIEKE: You can answer that yes l 5 or no. Just yes or no. Was he to any 6 extent knowledgeable.
7 A Yes.
8 Q On March 28, 1979, was Bruce
. 9 Karrasch to some extent knowledgeable about when 10 it was appropriate to use high pressure injection 11 response to a small break loss of coolant 12 accident?
- x. 13 A I don't know.
14 Q On March 28, 1979, was Mr. Labelle 15 to some extent knowledgeable about when it was 16 appropriate to use high pressure injection in 17 response to a loss of coolant accident?
18 A I don't know.
19 Q on what were you basing your i
20 affirmative answer to the question about whether 21 Allen Womack was to some extent knowled,geable about 22 the appropriate use of high pressure injection?
23 A I'm not sure the word " appropriate" was 24 utilized in the question.
(
- 25 Allen, it was my understanding, had
.. __ , ...___-m,.. . _ - _ , . _ . - _ , , - . . . , . . - . . . -.,__.-..~,.,-_.-.v... _ _ . . ___a .--_
o 1 Dunn 783
/~% ~
d 2 been involved with nuclear power for some period 3 of time. He had been in a pro' ject management 4 position associated with the M-K project at_BBR l 5 during the times that I interfaced with him and 6 it was my belief at the time that he would have 7 picked up some knowledge about the intended 8 operation and role of the ECCS system.
9 Q What created the conclusion in your 10 mind before you went to lunch and played cards 11 on March 28th that the Three Mile Island plant was 12 in a stable condition, if you can recall?
13 A I don't recall the specific thing that-14 created it. It was as a result of the meeting.
15 Q Was Allen womack on the phone to 16 anybody in Pennsylvania during the course of the 17 morning meeting?
18 A I don't recall whether he was or wasn't.
, 19 Q You weren't there for the entire 20 meeting, were you?
21 A No, I was there for the second half.
22 Q At any other time, have you ever 23 been consulted for advice while a loss of coolant
) 24 accident was in progress?
25 A Yes.
i
g Dunn 784
[\
2 Q When?
3 MR. FISKE: Mr. Seltzer, I don't 4 really see the relevance of whether f 5 Mr. Dunn was consulted on some other 6 occasion or not. The last half hour I have 7 been sitting here very patiently wondering 8 what this has to do with anything.
9 MR. SELTZER: You're kidding?
10 MR. FISKE: I certainly don't see 11 what the relevance whether Mr. Dunn was 12 consulted on another accident has to do 13 with this. It is marginal relevance what 14 conclusions he may have drawn from
, 15 fragmentary information that he may or may 16 not have received at various intervals 17 during the day of March 28th but if you 18 want to ask him about that, I d'on't object, 19 but this, now if we are going to do the 20 same thing for some other accident that 21 isn't even the accident in this case, it 22 seems to me we are way, way afield.
23 MR. SELTZER: We are at the time 24 for lunch. Why don't you let me find out 25 what the other accidents were and then over
i 1 Dunn 785 2 lunch, I can consider whether I want to 3 fly into the teeth of the gale and persist 4 in trying to ask questions.
() 5 MR. FISKE: All right.
6 Q What were the other accident or 7 accidents where you were asked for advice while 8 the LOCA was in progress?
i 9 A . Well, I mentioned earlier that I wasn't sure 10 that the LOCA was still in progress,during this 11 event. It is the Crystal River event and I was 12 certainly consulted and involved from the time 13' that I was able to get to the communication center 14 which was actually just an office in Customer 15 Service that placed us in communication with the 16 control room and the time at which we felt the 17 important phase of the accident had been resolved.
18 Q Other than Crystal River, were you 19 ever consulted for advice while a loss of coolant l 20 accident was in progress or while the plant was
. 21 dealing with the aftermath of such an accident?
L 22 A No.
23 MR. SELTZER: A quarter of 27 l
24 MR. FISKE: Fine.
25 (Luncheon recess -
12:35 p.m.)
- ---- - _ . . . - , . . . . . ~ , - _ . --- ,- , , _ , _ _ _ _ _ , _ . _ _ . _ , . , . . . , , _ , , - _ . _ . - - _ , . . . - - - - -...-.~.,m.. .._
1 786
- (~{ '
2 AFTERNOON SESSION 3 1:52 P.M.
4 B E RT M. DUNN, Resumed.
5 EXAMINATION (CONTINUED) 6 BY MR. SELTZER:
7 Q Mr. Dunn, in your resume which is part 8
of GPU Exhibit 75 you describe as one'of your major 9 a6complishments during the period you have been 10 Unit Manager the specification o f op'erational ,
11 ' procedures for handling of loss-of-coolant 12 accidents. '
13 Is that a reference to your role in 14 the development of the small break guidelines?
4 15 A Yes.
16 Q You also wrote that "These procedures l
l'T may have prevented a second incident similar to 18 TMI-2."
l 19 A Yes.
20 Q That second incident you have 21 previously said is the Crystal River event; right?
(
! 22 A That is correct.
23 Q The small break guidelines had b,een (ss .
24 distributed to operating utilities prior to the 25 Crystal River event?
1 Dunn 78:
2 A To be sure I would want to check the dates 1
3 again, but when I wrote this, I was under the 4
4 impression that they were.
l 5 g o,g,
- 6 A I would also have included the April 7
l instructions in the general phraseology here 8
(indicating).
9 Q Is it your understanding that the 10 actions taken by the operators at Crhstal River 11 were consistant with the April 1979 operating i 12 instructions and the small break guidelines?
% 13 Let me make it easier for you.
14 All I'm referring to is the actions 15 which you heard or which were reported to you 16 to have been taken by the ope rators .
17 MR. FISKE: In other wordsi the 18 question is based on what he was told i
19 i about the actions taken by the operators, t
20 did he draw a conclusion one way or the 21 other as to whether they were consistent with 22 the April guidelines, April instructions?
l 23 MR. SELTZER: The April instructions
()
21 and the subsequently issued small break l 25 guidelines.
1 Dunn 788 O)
\_
2 MR. FISKE: Can you answer that?
3 A I did not conduct an in-depth review, point 4
for point, looking for consistency, i 5
MR. FISKE: It seems to me, Mr.
6 Seltzer, the question of whether the operators' 7
actions at Crystal River, assuming for 8
the moment that they may be relevant to this 9
case, are facts that can be established; and 10 whether they are consistent with the 11 guidelines or not is also something that can 12 be determined at an appropriate time as,a O' 13 conclusion, but'I don' t know that it h'1ps e 14 very much to ask Mr. Dunn based on what.
15 somebody else may have told him, which is 16 certainly not going to be admissible under 17 any circumstances.
18 MR. SE LTZE R : I am asking s ubj ect to 19 later connection. If it turns out he heard 20 correctly what the operators' actions were, 21
{ then nis view as somebody who lists as one 22 of his major accomplishments the drafting of 23 these procedures is ve ry significant, whether
() 24 he believes that these actions were 25 consistent with the guidelines.
L
-~-,-w ,- , , - , , , - - , - , - - - - -,,-,,,,-n-,..,n--,,a- - - - - , - - _ -----,,-n. - - - , - - - , , - - , ~ - - . - ,
_ 1 Dunn 789
/O V 2 MR. FISKE: I-don't -- if that is 3 what you are trying to do, then I think you 4 then have to establish specifically what k' 5 Mr. Dunn was told the operators did, so that 6 you have those --
7 MR. SELTZER: O.K., fine.
8 MR. FISKE: If he can answer that.
9 BY MR. SELTZER:
10 Q What were you told the operators did?
11 A Well, I participated --
12 Q' Let's start this way: On the day of (2) - 13 the Crystal River accident, how soon after the 14 start of that transient were you first contacted 15 with respect to that transient?
16 A I am not sure in that I have not recorded 17 the actual time the event started in my memory.
18 I think it is within an hour.
19 0.K. Where were you*when you were Q
20 first contacted with respect to the Crystal River 21 event?
22 MR. FISKE: Mr. S e lt ze r , this is where 23 we were before lunch in terms of the contacts
() 24 that they had with him during the Crystal 25 River accident.
Dunn 790 2 MR. SELTZER: Mr. Fiske, I have to 3 beg you not to interrupt this way. I am 4 trying to proceed in the way that you have 5 suggested to get at the facts in a proper 6 way. I have changed my line of examination 7 since we came back from lunch to pick up 8 what you were suggesting would be the 9 proper way to proceed, and I think that it 10 is not proper for you now to b'e blocking 11 this avenue of inquiry,' which is specifically 12 following up on what you have recommended
~
. 13 would,be the proper way to proceed.
14 MR. FISKE: No. Let's get a couple 15 of things straight. I said if you are going
- 16 to at some point later try to establish a 17 predicate for asking Mr. Dunn about 18 conclusions based on the small break 19 operating guidelines you need to establish 20 specifically what he was told the operators I
21 did, that's got nothing -- and you can ask
(
22 him that; but I don' t see what that has to 23 do with the point in time at which he was (J
u-24 contacted, going through some sort of a 25 chronology. However, I am not sure that
- , ~ - . . . . , - - . . , . , - . - . ------ ,v. - , _ - - - , , . . , - - - - - . . . . - . , - - -
-e ....w.- . - --- - - . - - , . , . . , , , , .,
1 Dunn 7.93 2 in the end this is going to make very much 3 difference as long as it doesn' t take very 4 long.
5 BY MR. S ELTZE R:
6 Q Go ahead with your answer.
7 A The question was, where was I at the time I 8 was informed of the incident at crystal River?
9 MR. FISKE: I am also going to -- I i
l-10 think I better make it clear, .just so you 11 know where we are going on this, I am not 12 sure that --
I am not going to allow Mr.
O NJ 13 Dunn to answer a question in any event as to 14 whether he believes today the operators' 15 actions at crystal River were or were not l 16 consistent with the guidelines. I mean, I 17 am not going to let him answer that question, 18 in any event. So, if you are --
l 19 MR. SELTZER: Let's just proceed.*I 20 think that hearing you talk and hearing me 21 talk really doesn't advance the ball. If 22 there is one thing that is cle arly in-23 admissible, it is what you and I say.
i
( 24 MR. FIS KE : The ques tion is whether 25 this has any relevance at all. What he was s
--- ,- . , , , , . , . . . - . ..w..,,.-- - - , , , - , , . , . . . - , -.. --, - .. - - . . , - - --
1 Dunn 792 2
told at Crystal River is absolutely -- I 3 mean, if you want to ask him that for the 4
purpose of discovery, I suppose you are
( , 5 .
entitled to do it; but it seems to me we 6 are wasting an awful lot of time in a
^
7 deposition that on occasion has been 8
characterized by that.
9 MR. SELTZER: Are you casting 10 aspersions on the way I have ebnducted this 11 deposition?
12 MR. FISKE:
I have told you on several O 13 occasions that I thought the particular line 14 '
i of inquiry that you were engaged in was 15 one that was irrelevant and was not going to 16 lead to the discovery of admissible evidence, 17 and in words or substance that we'were i
18 wasting time. I believe I have made that 19 point on several occasions, and I am making 20 it again now.
l 21 MR. SELTZER: I will just have to 22 suffer that accusation as manfully as I can.
23 MR. FISKE:
Well --
( 24 BY MR. SELTZER:
3 i
25 Q Go ahead, Mr. Dunn.
I
_ _ _ . , _ . , - . , _ . , _ . , _ ~ . . . ,
_ _ _ . . . . - . , _ _ , _ _ _ _ . , .,,.--_,__._,,.___-,_._-.._.,,,,___,,,_,_._...,_,___,._,_..,m,_, ._, , . . _ . ,
4 1 -- Dunn 7 92 2 A I was in one of the training rooms giving a 3 lecture on the modes of natural circulation within 4 the reactor coolant system during small break loss-l' 5 o f-coolant accident.
6 Q were you called out of that teaching 7 responnihility to participate in a --
8 A I was informed of the incident and told of 9 the location of the telephone communication with 10 the site, and I proceeded to that location.
11 Q where was that?
12 A In an office in the customer service'section
'- 13 towards the front wall just down the right-hand 14 side of the east entrance to that section.
15 Q Was this in the morning or the 16 afternoon?
17 A As I recall, it was just before lunch. I am 18 not sure of that.
19 Q Who was assembled in the room when 20 you arrived there?
21 MR. FISKE: Mr. Saltzer, I would just
] 22 point out that in reviewing my notes of the 23 examination on March 19th, there was an
( 24 extensive line of ques t. ions , on this 25 whole situation, including virtually
. - - . - _ - _ _ . _ . - - - - - - - - - - . - - - - . - - - - - ~ ~ ~- - - - - - -- --
1 Dunn 794
/Q V 2 everybody he talked to about this at the 1
3 times the question as to whether he had 4 spoken to people in the Crystal River 4
( 5 control room at the tima of the transient, 6
did he speak to the site representative, 7 has he spoken with Mr. Kallman, has he 8 spoken with Jones.
9 MR. SELTZER: Does it indicate who 1
10 ~
was in the room'in Customer Ssrvice that -
11 morning receiving information from the ite?
12 MR. FISKE: No, I am not sure -- I don't 13 know whether that specific question has b.een 14 asked.
i 15 MR. SELTZER: 0.K. That is the 16 pending question.
17 l MR. FIS KE : Well --
IO j MR. SELTZE R: I appreciate your 19 pointing out we asked other questions about l 20 Crystal River.
21 MR. FISKE: I am not sure how long I 22 . will allow this to go; but you can answer 1
23 this question.
l 24
( A Don Hallman was in charge. There were 25 several other people in the order of five or six
. . . _ _ _ _ - _ _ . - - - . . . ._ ~ _ - _ ___ ,_ _ _ _ __ _ _ . ,___ _ _ ,___ ._ _ _ _ _ _ ,, . _ ____. _ _ -
1 Dunn 795 p
2 in or around the room.
3 I could not be positive other than 4 Don who was specifically in the room at that time.
( 5 g what information did you get in the 6
room that morning about what had happened at 7 Crystal River?
8 A We had a blackboard representation of plant 9'
parame ters ; our response at that time was in a 10 diagnostic sense, particularly with ' stress on 11 whether there remained or was --
I think maybe 12 better than " remained," was any opening in the 13 primary system, was concern that d's might have 14 a hung open code safety involvement.
15 Q Did the parameters that were listed 16 on the blackboard indicate whether there was 17 saturation in the primary system?
18 MR. FISKE: Now I think I am going to 19 object to all of this, Mr. Seltzer. I just 20 don't think that the inquiry as to what f 21 information they were getting from the Q l 22 control room at Crystal River a year after 23 the Three Mile Island accident has any 24
( relevance to this case at all.
25 so I am just going to instruct him n
l 1 Dunn 796 N._/
2 not to answer any more questions on this 3 or at least -- well, I should say at least 4 with respect to -- I will certainly object
{' 5 to the pending question unless you can- tell 6 me --
7 MR. SELTZER: Bob, I don't understand 8 how you think we can examine whether the 9 actions that the operators were taking were 10 consistent with the April 1978, prescription 11 if we don' t know what conditions the operators 12 were reacting in response to.
(:) -
13 -
certainly the April prescription which 14 Mr. Dunn has testified is virtually the same 15 as his February 1978 prescription is very 16 relevant to this case.
17 MR. FISKE: Well, it may or may not 18 be relevant to find out what the operators 19 at Crystal River did, that may or may not be 20 relevant. But certainly what was reported 21 to B &W that they did is clearly not going 22 to be admissible in any event, j
23 MR. SELTZER: I am not --
b (j 24 MR. FISKE: Well --
25 MR. SELTZER: --
going into it for the l
1 Dunn 797 ~
2 truth.as to what the conditions were at 3 Crystal River. I am going into Mr. Dunn's 4 understanding as to what was done at Crystal
( 5 River.
6 He is not an expert witness. I am 7 not going to be able, Mr. Fiske, to present 8 to him a state of f acts and say assume this 9 is what happened at Crystal River, does this 10 conform to the small break guidelines?
11 So I believe the proper way for me to 12 proceed is to find out what his knowledge
(~)
E/ . -
13 is of what he understands happened at Crystal 14 River from his experience, and then ask him 15 whether his knowledge of what happened at 16 Crystal River is consis tent with what he 17 believes the small break guidelines would 18 call for.
19 MR. FISKE: Well, I am not sure that 20 this whole line of inquiry is appropriate; 21 but go ahead. I will take it one question 22 at a time.
23 BY MR. SELTZER:
t 24 Q Mr. Dunn, did the parameters , as v
25 engineers like to call it --
1 Dunn 798 O 2 MR. FISKE: I would j ust say, bearing 3 in mind at the end whether what the 4 operators did a year after the Three Mile
(( 5 Island is or is not in accordance with 6 instructions that were issued after the 7 Three Mile Island accident is of dubious 1
~
8 relevance in any event.
9 -
MR. SELTZER: I am not asking you to 10 waive an objection to relevance at trial.
11 MR. FISKE: I understand. I certainly
. 12 haven' t done that.
ht
\_/ 13 'Do you need to hear the question? ,
14 THE WITNESS: Yes, I don't think I 15 have any idea of it.
16 A The question was?
17 Q The ques tion was : Did the parameters i
18 which had been reported -- what are " parameters,"
19 just so the jury understands when they hear this?
i 20 MR. FISKE: Assuming --
21 A It is used in more than one sense. In this 4
22 sense it means the values of the particular 23 variables and their value that can describe the
("} 24 state of the system, such things as pressure,
'v' 25 temperature.
_._. _.__.._. ____.____.________._ _ _._ T ': -__.~~1.__.._._ . . _ . . _ _ _ _ _ .
1 Dunn 799 O
2 Q Pressusizer level? .
3 A Pressurizar level. Maybe value position 4 might be considered a parameter.
() 5 Q From the conditions or parameters that '
6 had been reported in the room where you were on 7 the morning of the crystal River accident, did you 8
understand or believe thst there had been 4
- 9 saturation in the primary system?
I 10 A I don' t believe so.
(-
11 At any time have you come to know that Q
. 12 there was saturation in the primary system of O
f 13 crystal River during that transient?
[ 14 MR. FISKE: I object to the form. *
- 15 A That question was asked earlier in the 16 deposition. I believe my answer was then, and l 17 still is today, that whether or not there.was
- 18 saturation at one time during the incident did i
l 19 not appear remarkable to me. I would need to have 20 the specific data presented to me to respond to 21 the question.
22 Q why did the ques tion of whether there e
! 23 was saturation not appear significant to you?
(}
24 A It is my understanding there had not been i
25 any interruption of high-pressure injection.
I i i =
1
..,m,-, , , - -- - , . . _ - .,..._c-y ,...c.,,---,-,_ _--..__,.-%.-.,-.,_ , , . . - . . . . - _ . , . . _ . . _ -...__,___._c-,... , . - . , - _ , - - .
f 1 Dunn 800 7"%
~
2 Further, from the data as I recall it, 3
there is a tima .in the transient in which the i
values of the parameters approached saturation, l 5 they may for a short time cross into it, they may 6
not quite have made it; but they recover very 7 shortly thereafter to a solid subcooled condition.
8 You said you knew that the Q
9 high-pressure injection had been on continuously.
10 when did you learn that?,
11 A I believe it was after the accident, the 12 in cide n t.
O
(_) 13 g ~
when you were in the special command 14 room at B &W the morning of the Crystal River 15 incident did you take steps to determine tnat 16 the high-pressure injection was on?
, 17 A No, I think I was informed of its status.
18 Q You mean you didn't have to ask? You 19 were informed?
20 A Yes.
21 Q How long did you remain in the command i 22 center at Lynchberg?
23 MR. FISKE: I will object to the fo rm 24 of the question. Nobody has called this the l
25 command center. I think undoubtedly the
i Dunn 801 O
V 2 commanding was going on at Crystal River.
3 It was referred to as a controlling or 4 central center. I don't rememb,er the
( 5 term, " command center," coming from Mr.
6 Dunn.
7 Q Kow long were you in the control center 8 command module?
9 A I was in that for a few hours. I made 10 contact with the -- maintained contact with them 11 for a period of time until late that evening, and 12 response coordination was at sometime during that o'
t 13
, afternoon shifted to the room we have called the 14 War Room previously.
15 Q so, in other words, for a few hours 16 you remained in either the command center or in the 17 War Room, whichever was the focal point of 18 Lynchberg's contact with the Crystal Rive,r plant?
19 MR. FISKE: ,Well, I will object to j 20 the form of the question.
21 A For the most part, let's say.
- 22 Q How many hours was that?
23 A I am not sure. I would place it on the I
I
() 24 eight-hour time frame.
25 Q That day you didn't go to lunch and
1 Dunn 802
,~
2 play cards?
3 A If it occurred in the morning, that day I i
4 did not go to lunch and play cards, no.
( 5 Q It is your recollection that at some e
, 6 point in that transient the temperature and 7 pressure brought the plant to, or close to the 8 saturation curves is that right?
9 A Yes.
10 Q The small break guidelines and the 11 April 1979 guidelines and the Bert Dunn February 12 14th, 1978 instructions called for having high
/
\/ 13 pressure injection on a't such a time; right?
14 A Yes.
15 Q Did you believe that the actions by 16 the Crystal River operators in handling high 17 pressure injection on the day of the Crystal River 18 transient were consistent with those various 19 instructions on high press ure injection?
20 MR. PISKE: Well, are you referring, 21 Mr. Seltzer, to the question whether it was 22 consistent with the instructions to leave 1 23 HPI on at a time when temperature and (a) 24 pressure indicated that they were close to 25 the saturation curve?
1 Dunn 803 2 MR. SELTZER; That is a good first 3 question.
4 MR. FISKE: Well, it is the only one
( 5 you have established a predicate for.
6 MR. SELTZER: 0.K.
7 A When -- the time frame for my belief, please.
i 8 The day of the accident.
Q 9 A I don' t think I believed one way or the 10 other. I didn't ask the question. ',
11 Q Were you mentally comparing the status 12 of high pressure l',njection of Crystal River with
'- 13 the small break guidelines?
14 A Yes.
15 Q For what purpose were you comparing 16 them?
l 17 A For determining what the present status of 18 the HPI should be. *
(
19 Q From what you heard was the status of 20 the high-pressure injection, did you believe it 21 conformed to the small break guidelines?
22 A At the first time that I reviewed the data 23 we had available to us from the site, which was
() 24 information being relayed to us and updated 25 periodically at the time that it was related,
-._...----_ _._.~._ _ _ _ . .__ _ _ _ _ _ _ _ _ . . _ _ _ ,-
i 1
Dunn 804 t's 2 the plant was in a condition that was well 3 subcooled. They could have been doing anything 4 with the HPI as far as I was concerned in those
(' 5 circumstances. .
6 Q Did you either directly or indirectly 7 communicate any advice to the Crystal River 8 operato rs regarding operation of high-pressure 9 injection that day?
10 A We passed on the words to the 'B &W site 4
11 representative that we wanted to be sure the 12 plant maintain its 50 degrees sub cooling margin.
's 13 Q Did you pass on the word that it would 14 be appropriate to terminate high-pressure 15 injection so long as the 50 degrees s ub co oling 16 margin existed?
17 A I don't recall whether we passed.that on or 18 not.
f 19 , Q Was Bob Jones at the B&W offices
- 20 in Lynchberg that day?
i 21 A I do not recall.
22 Q Do you recall whether you had any 23 communication with Bob Jones regarding the C rys tal ,
() 24 River incident on the day of the Crystal River
! 25 event? -
1 Dunn 805 s- .
2 A No, I cannot recall whether I did or did not.
3 Q Would you look at the firs t page of 4
GPU Exhibit 108, please. Would you turn to
( 5 Part I.
6 Who, to the-best of your recollection, 7
wrote the section, " Background Information for a 8
Spectrum of Loss-of-Coolant Accident"?
9 A It was a combined effort between Mr. Bob 10 #
Jones and Mr. Bob Sa'lm. ",
11 Q Did you review the small break 12 guidelines"before they were finalized?
13 A Yes. -
'14 .
Q Were you satisfied with the contents?
15 A
I was satisfied that the contents were .
16 sufficient for issuance at that time.
17 Q In other words, you believed that the 18 material. contained in it was accurete?
19 A
Sufficiently accurate for the purpose being 20 served and worthy of distribution.
i 21 2
Q At the end of the fir [t paragraph of 22
, the background information section there is a '
23 sentence that begins, "The existence..." Do you
- 24 see that?
25 A Yes.
1 Dunn 806
\ >) 2
, Q It states there, "The existence of 3 saturated conditions within the reactor system is 4 the principal longer-term indication of a
(- 5 loss-of-coolant accident."
6 Let me ask you first, as background, 7 it is correct, is it not, that the principal 8 difference between your February 9, 1978 and 9 February 16, 1978 instructions were the addition 10 of the 50 degrees subcooling margin?
11 A No, I don' t think I woul'd phrac e it that way.
12 How would you phrase it?
Q
{'%
N- 13
. MR. FISKES Why don't we get them ,
14 out and we can look at them.
15 A I think the principal difference was the 16 subcooling margin could exist and be appropriate 17 at a variety of pressures as opposed to the 18 specific pressure co ntaine d in the February 9th 19 memo.
20 Q The February 9th memo does not make
- 21 any specific reference to saturation, does it?
22 A No.
23 Q The February 16th memo specifically
() 24 refers to saturation, right?
25 A In the recipe or the instruction. It does
1 Dunn 807 2 not specifically mention saturation.
3 Q In the February 9th memo, right?
4 A In the February 9th memo. ,
( 5 Q The recipe or prescription on Februar{
6 16th does refer specifically to saturation, right?
7' A It refers to the saturation temperature 8" corresponding to the existing reactor coolant 9 system pressure.
10 It thereby refers specifically to Q
11 the occurrence of saturation or to a margin that s.
12 is necessary to be maintained below saturation;
\ -
13 is that right?
14 A It does refer to a margin to be maintained 15 below saturation; that is correct.
16 Q The April 4th and the April 17th l 17 instructions on operation of high-pressure 18 injection both included specific references to 19 maintaining a margin below saturation; righ t?
20 A That is correct. '
21 Q When did you first become aware of the
[
l 22 fact that the existence of saturated conditions 23 within the reactor system is the principal
() 24 longer-term indication of a loss-of-coolant
- 25 accident?
1.
l , - , . . - , , , . - . . - - -
.. .. .. . . . ~. . _ _ - _ _ - - --- - .-
1 Dunn 808
(:) 2 A The question of distinguishing between loss-3 of-coolant accidents and othe r accidents which 4 could involve a depressurization of the reactor
() 5 coolant system was primarily raised for the first 6
time in my belief in constructing the operator -
7 small -- the small-break operational guidelines ,
- 8 that this occurrence was a principal indicator 9 of most -- excuse me, most small-break loss-of-10 coolant accidents was known and established, I 11 think, as early as 1973.
12 Q Known and- established by whom?
["h ,
\-) 13 A The ECCS Group Unit , although we had a 14 different title then.
15 Q Is it something that yo knew in 1973?
16 A Yes.
17 Did you have.any discussions with'
^
Q 18 anyone after the Three Mile Island accident abcut 19 the appropriateness of hinging instructions for 20 high-pressure injection operation on the detection 3
21 of margin to saturation?
22 MR. FISKE: I am sorry; I would jus t I 23 lika to hear that question again, please.
- [~_,) 24 (Question read.) .
25 A Yes.
B
--..,-w -.,e> w .rme- ,---.--..mm. -+r.. -w- - _ _ . . . .,2, ~ . . -.es-, e-, .. . , . - ,- . . 'w= --
i 1 Dunn 809 O 2 Q When is the firs t time that you had i
3 such discussions?
4 A When Taylor and Elliott met in my office k 5 to discuss what type of instructions we would issue.
6 I explained why theso instructions were formed 7 the way they were, what they were intended to do 8 which was to assure a given physical amount of 9 water in the system by noting that the temperature 10 and pressure combination at a given* location 11 within the plant could not be that o f s te am .
12 Q When you refer to maintaining a given 13 amount of water, you meant liquefied water?
14 A Yes.
15 Q Did either Taylor or Elliott at any 16 point indicate that they thought appropriate 17 instructions could be issued without reference to 18 the occurrence of saturation or the maintenance 19 of a margin below saturation?
20 A I don' t recall them saying such. I recall 21 us agreeing that these would work.
22 Q Did anyone on the group that worked 23 on the small break guidelines say or suggest at
() 24 any point that the reference to saturation was 25 not app ropr iate ?
i i
l E . _ . _ . - - _ - _ _ _
1 Dunn 810 A
b 2 A I don't believe so.
3 Q Was it your understanding when you 4 finally issued the April 4, 1979 instructions that 5 that was the first time that B&W had issued 6 . instructions on operation of high-pressure 7 injection which were keyed to saturation or margin 8 below saturation?
9 A No, because I was not familiar with whatever 10 instructions we had previously issued or that we 11 had in fact even issued any differentiating between 12 preparation of draft material and actually O 13 issuing instructions.
14 Q Did you have an understanding that B&W 15 had not previously prepared ins tructions or draft 16 procedures which tied the operation of 17 high-pressure injection to the specific recognition 18 of saturation or the specific recognition of a 19 margin below saturation?
20 A Nd, I don' t believe I had that understanding.
21 Q At any time since the Three Mile Island 22 accident have you come to have that understanding?
23 MR. FISKE: Before you answer this, s
24 can I hear the previous question and the 25 answer?
, _ - . . - , . , . _ , , . -_ _ ~ _ . - . . , . - - - , . . - -..-y-_ _ , , _ _ , -
..__.m_ _ _ . _ _ . . . _ , _ . - , _ . - . _ . .
1 .
Dunn 811 0 2 (Record read.)
3 A I don' t think I have~ an unde rs tanding.
4 I have a belief.
( 5 Q what is your belief?
6 , MR. FISKE: Well, I am going to 7 object to that unless it is based on 8 something that makes the question 9 worthwhile.
10 Q Go ahead and answer. (
1 11 MR. FISKE: Why don' t you start by 12 answering what your belief is based on 13 without saying what the belief is.
14 A My belief would be based on the many 15 interactions that I have had since the Three l
16 Mile Island accident, the issuance of the
(
17 various small break operating guidelines and 18 other procedures , the interest in the use of j 19 certain meters and/or s copes at our facilities l
20 but I would say no real specific recollection.
- 21 Q If your belief is based on all of k-22 those personal experiences, why don't you tell 23 me what it is.
() 24 MR. FISKE: I don't think this makes 25 very much difference.
1 Dunn - 812
/~T b 2 MR. SELTZER: 0.K.
1 3 A It is my belief we have not issued HPI 4 management instructions relative to maintaining a k 5 subcooling margin following the accident previous 6 to Three Mile Island.
7 MR. FISKE: I might say once again 8
that is a factor -- either it is a fact 9 either they did or didn ' t.
10 MR. SELTZER: Now, I w i l'1 b e t that 11 there is not going to be any one person who 12 is going to know for sure what was issued and O .. _,
13 what was not issued, and we may go to "
14 trial and this may go to the United States 15 Supreme Court without it ever being 16 established as a fact whether B&W issued it, 17 but there will be many people who will have 18 beliefs that they didn' t issue it, and it i
19 will probably be that that is how the 20 fact will be determined not based on you 21 coming in with something engraved in tablets 22 that were handed down at Mount Ararat saying 23 either the company did or didn' t issue it.
() 24 I don't think that is how fact is determined.
25 MR. FISKE: I can guarantee it won't
1 Dunn 813
)
2 be determined what Mr. Dunn is stating today.,
3 what his belief is based on, is a series of 4 unrelated incidents.
5 MR. SELTZER: That is what makes it 6 interesting.
7 , BY MR. SELTZER:
8 Q Whom do you believe would be mos t 9 knowledge able at B&W about whether operating 10 instructions had been issued prior do Three Mile 11 $sland that were tied to maintenance of a 12 subcooling margin?
13 A The filing system. .
14 Q The filing assistant?
15 A The filing system.
I 16 Q Are there any individuals who have 17 their finger on the pulse of communication with 18 customers in this area who might know?
19 A Yes.
20 Q Who?
21 A I would first ask Don Hallman.
22 Q. Do you have any second choices?
23 A The peopla.that report immediately to Don
( 24 and the files of the project managers-on the i
25 operating plants.
I
_ . _ , __ __ _ = _ _ _ _ _ _ _ _ . . _ _ . - . _ _ . . _ _ _ _ _ . . _ _ . , . _ _ _ _ . .____a
1 Dunn 814 O 2 Q In the instructions that were issued 3 since the Three Mile Island accident for proper 4 operation of high pressure injection, did you
( ,
5 believe that the instruction relating to 6 maintenance of a. subcooling margin was an 7 important ins truction?
8 A Yes.
9 Q What is there about that instruction 10 that you believed made it an important instruction?
11 A It is important be cause - it guarantees us a 12 certain inventory of liquid coolant within the Os 13 reactor coolant system before any action should 14 be taken to retard or shut off the supply, the 15 additional supply of coolant to the system.
j 16 Q once a plant hits saturation,. steam 1
17 is formed in the primary system, right.?
18 A steam would start to be formed if it went j 19 a little bit past saturation.
l l 20 Q If the plant is then effectivel'y 21 brought into the subcooling range through l 22 high-pressure inj ection, what happens to the 23 s te am that has been formed according to the
() 24 analyses that your unit has done?
25 A There are many possibilities.
N
~
1 Dunn 815
('"h V 2 Q What are the more probable?
,3 .A It would depend on the amount of steam that i
4 was formed while the plant was at saturation.
( 5 MR. FISKE : You understand I will 6 object to this line of ques tioning unless 7 Mr. Dunn is testifying based on analyses 8
that have already been made.
9 MR. SELTZER: Right. That is what I 10 assumed I was asking him abou(.
11 MR. FISKE: Is that what you meant?
12 MR. SELTZER: Yes.
f)
\/ 13 MR. FISKE: 0.k.
14 g Let us say the plant, if this is 15 something that you have studied, has been at 16 saturation for 10 minutes.
Have you done analyses 17 that would show what would happen to the quantity 18 of steam that would be generated in the primary 19 system?
20 A To answer that ques tion, I would have to l 21 quote details from our analysis.
22 I am not prepared to answer that t
23 question today.
() 24 g Ara those analyses which had been 25 done prior to the Three Mile Island accident?
l i
l
- i. _ _ _ . - . _ , . _ _ . _ - . _ - _ _ _ . . - - . - . - . - - - - - - - - - .
1 Dunn 816 2 A In general I could base my response on 3 analysis performed before Three Mile Island.
4 Q Are you able to say from what you can 5 recall from those analyses what the variety of 6 different things are that could happen to the 7 plant? Let me just ask this --
8 A Yes.
9 Q Go ahead; tell me what are the variety 10 of things. '.
11 A We would express the steam content in 12 terms of cubic feat or s'ome volumetric measure, C:)
13 expressing it in terms of time would require the 54 specification of a given break size or a given 15 break scenario.
16 If the amo unt o f s te am was small, then 17 there is the possibility that some s te am would 18 remain collected in.the upper head of the reactor 19 vessel, some steam would initially collect in the 20 upper regions of the 180-degree bend in the candy 21 cane, and that steam would eventually be co nde ns e d .
{
22 I am hypothesizing that there is a 23 finite time for steam formation, and at sometime
() 24 the high-pressure injection is either capable of 25 overcoming the break or we have se cured the break
1 Dunn 817 2 somehow.
3 There is the possibility that steam 4
might only have been formed in the pressurizer,
( 5 in which. case it would colle ct there . If a larger 6
amount of. steam is formed within the primary system 7
itself,. excluding the' pressurizer, a significantly 8
sized steam bubble could appear in the upper head 9 of the reactor vessel, a significant size bubble 10 '
could appear in the top of the two hot legs, which 11 again would be. gradually condensed, but that is 12 provided the bhbbla in the hot leg is not large 13 enough to totaby stop natural circulation.
14 If the bubble is large enough to 15 totally stop natural circulation and the resultant 16 energy balances between the hot legs and the l 17 steam generator and cold leg sections are not 18 sufficient during the remainder of transients i 19 to induce circulation, the ste am would stay in l 20 those locations for an extended period of time, 21 gradually condensing as energy was lost to the 22 environment.
23 Q There are no windows built into the 24 primary coolant system, are there?
l 25 A Not other than the ins trume n ts .
l t
1 Dunn 818 O 2 Q So you can' t send an operator over to 3 the reactor coolant system and tell him t'o look 4 through the glass. and see whether there is steam 5 or water at. different points in the system, can 6 you?
7 A No.
8 Q In order to determine whether there is 9
a two-phase mixture in the reactor coolant sys tem, 10 what types of instruments were avail'able , to your 11 knowledge, in ,the Three Mile Island plant on March 12 28, 19797~
g .
\
13 A Hot and cold leg pressure and temperature, 14 pump flow.
15 What pumps?
Q 16 A Reactor coolant pumps.
17 I think pump flow is probably wrong.
18 Flow measurement. Those would be the direct ones.
19 Q would you need to know pressure?
20 A I mentioned pressure, I thought.
21 THE WITNESS: Didn't I?
22 MR. FISKE: No.
23 A (Continuing) I would need to know pressure.
( ) 24 MR. FISKE: I didn' t hear it, either.
25 MR. BENEDICT: In connection with hot
f 1 Dunn 819 0 2 leg temperature and pressure and cold leg 3 temperature and pressure.
4 THE WITNESS: That is what I thought.
( 5 MR..FISKE: For once we agree.
6 Q Where would you need to know the flow, 7 the flow at what point?
8 A You asked what would indicate saturation in 9 the primary system?
10 Q Right. ',
11 A If all the reactor coolant system pumps are 12 running, the flow which would be measured would be O
\/ 13 a gradually reducing flow because of the nature 14 of the measurement instrumentation as saturated 15 conditions progressed to higher and higher void 16 fractions.
17 If you had the temperature and Q
18 pre s s ure in the hot and cold legs that would show 19 whether the reactor coolant system was at 20 saturation or not; is that right?
21 A Well, th,a re is an accuracy involved in 22 instrumentation and that is the reason -- one of 23 the reasons for the margin that is utilized in
() 24 the calculation that would indicate it was at 25 saturation. You could not determine the void 1
, , . . -. --.. ..-..,_,,....n . . . , - _ . - - ,, , , . - . - - - - , , , - - , - - , , . , . , , , . , , , , , , - , , - , - _ - . - , . - , , , - . , - , - - , ~ - , . , _
1 Dunn 820
-s
~'
2 fraction from those measurements.
3 Q So, in other words , if the reactor 4 coolant pumps are on, you could know from the
(' 5 , flow whether you had steam in the primary system; 6 is that right?
7 A Well, you. could not exclude the upper head i
8 of the reactor vessel.
9 Q What does that mean?
10 A Well, it is possible to place 'the plant in 11 a configuration in which a two -- a solid water 12 liquid state, circulation exists around the loops, 13 throEgh the generators, ba.ck.into the vessel 14 -
through the core and back out the hot leg, and 15 at the same time have a steam bubble in the upper 16 head of the reactor vessel.
17 Q If that existed, you would.not be 18 able to tell just from the flow through the i 19 primary coolant pumps th'at there was s te am in I
20 the reactor coolant system; is dhat righ t?
21 A That's correct.
I 22 Q If the hot and cold leg temperatures 23 were 30 degrees below the saturation curve, that
() 24 would merely indicate that there was not j 25 saturation occurring in the primary system at that
1 Dunn 821 0 2 time, right?
3 MR. FISKE: Mr. Seltzer, it seems to 4 me you.are just now engaging in a
( 5 colloquy with Mr. Dunn concerning his 6
present analysis of the questions that you 7 are asking him. I don't think any of these 8 questions are based on any analysis that Mr.
' 9 Dunn. made prior to the accident or even 10 since. P 11 MR. SELTZER: Well, I am still basing 12 it.on what I thought I had established -
13 starting these questions, that is, I want 14 to know what the instrumentation was to 15 his knowledge in the Three Mile Island 16 plant on. March 28th, 1979 and what he would ,
17 expect from those instruments, what he would 18 have to -- what those instruments would 19 have to be telling him in order to 20 conclude there was saturation in the 21 primary system.
22 MR. FISKE: Yes, I understand what 23 you are asking him, and that is exactly
() 24 my point. You are asking him to take the 25 instrumentation that was available on 4
.,,-,~,y -..--, - ---. -,,-- - -- , , ,,,, _-. _ _ ,.. -,_, , . - ,,,...,,,. ,..,.y .~ , ,. -----,---,..._y -. , ---. - , - - _ _ , _ . - - - - , - .
1 Dunn '
822 O 2 March 28th, 1979 and now you are asking him 3 a series of questions about what would have 4 to ha shown.by those ins truments to determine
( 5 whether or not there was saturation.
6 .It seems to me that is precisely the 7 question of asking Mr. Dunn for his present 8 analysis of that instrumentation, and I.think 9 that- is not proper.
10 MR. SELTZER: I am askitig him what his 11 knowledge was of that instrumentation on 12 March 28th, 1979 and what he can . re call', of O -
13 his knowledge of that instrumentation on 14 that date would show, given history.
15 MR. FISKE: I think he .has told you 16 what the instrumentation was. You have 17 asked him that question, and he has given 18 you.the answer.
19 MR. SELTZER: I don' t disagree.
20 MR..FISKE: Now you.are starting to 21 ask him a. series of hypothetical questions ,
22 if it was this, if it was that.
23 MR SELTZER: I am j us t trying to 24 understand his last answers. I am really 25 not trying to write a textbook of
1 Dunn 823 2 thermodynamics.
3 MR. FISKE: I'think we all know what 4 you are trying to do. The question is
( 5 whether it is proper or not.
6 I think ha has answered the question.
7 From this point on, I think it is a bunch 8 of hypotheticals that Mr. Dunn is not 9 required to answer.
10 while- yo u -are thinking about that, 11 I have. to just make one quick phone call.
12 (Recess taken.)
O 13 MR. SELTZER: I would lika.to mark 14 for identification as GPU Exhibit 109 a 15 blue book, sabcock.& Wilcox' ' Evaluation of 16 Transient Behavior and Small Reactor i
! 17 Coolant. System Breaks in the 177 Fuel Assembly I
18 Plant,'May 7, 1979," Volumes I and II.
l l 19 (volumes I and II.of the book 20
" Evaluation of Transient Behavior and Small 21 Reactor Coolant System Breaks in the 177 22 Fuel Assembly Plant, May 7, 1979," by Babcock 23
& Wilcox was marked GPU Exhibit 109 for (m)- 24 identification, as of this date.)
25 BY MR. SELTZER:
l 1 Dunn 824 2 Q When you were getting reports from 3 Three Mile Island on March 28, 1979, have you 4 already described the instrumentation which was
)
( 5 in the plant which you. believed could indicate the 6 existence of saturated conditions?
7 A Yes.
8 Q You have identified the flow of the 9 reactor coolant pumps and the ins truments 10 measuring temperature and pressure in the hot and 11 cold legs; right?
12 A Yes. ~
O 13 Q It is a fact, is it not, that the 14 instruments recording temperature and pressure 15 in the hot. and cold legs would only show whether 16 the plant was currently at saturation; isn't that
! 17 right? -
18 A That's true.
l l 19 Q Those instruments could not show 1
l 20 whether saturation had previously occurred but 21 was not now occurring; righ t?
22 A I don' t know actually.
23 Q If the plant had previously been at l
~) 24 s aturation so that steam had formed and maybe it I
25 was sitting at the top of the reactor vessel but
.__ _ _ _ . . . _ - . . _ . _ . - . _ ~ _ _
. . _ - . _ _ _ _ _ . . - ~ . . - . _ _ , . _ _ . ~ __ . __
~~
1 Dunn 825 2 the water in the hot and cold legs then came 3 down to a temperature and pressure that was 4 below the saturation curve, isn't it a fact
(\ 5 that it was your understanding on March 28th, 6 1979 that those instruments would then show 7 readings below the saturation curve?
8 A At that time they would show it. The 9 reason I said I was not sure was that some 10 of these instruments have attached.sErip 11 charts which would indicate history.
12 Q Did Three Mile Island Unit 2 3 -
13 have strip charts?
14 A I do not know. They did have a 15 reactimeter.
16 Q What is a reactimeter?
l 17 A A da'ta logger of some fashion.
18 Q During March 28, 1979 did you 19 or others who were'with you at B & W call for 20 data from the log of earlier plant paramaters?
21 What I mean is, did'you ever ask for data on
(
-22 what had happened.at some earlier time during 23 March 28th, 19797 i
(_/ 24 A During that day I did not. I don't l
25 know what others did.
I l
1 Dunn 825A
~s 2 Q Can you identify, please, what 3 GPU Exhibit 101 is other than just reading 4 the title?
5 A GPU Exhibit 109 is a copy of a report 6 issued by Babcock & Wilcox in support of its 7 177 fuel assembly operating plants on.May 7th 8 and the report was issued to the Nuclear Regulatory 9 Commission.
10 Q You have referred to GPU Exhibit 11 109 as the blue book; right?
12 (Continued on page 826.)
gg ~
(_/
13 .
14 15 16 17 18 19 20 21 22 23
(~N
(_) 24 25 l ,.--
( ..
l 1 Dunn 826 O
V 2 A Yes.
3 Q Why?
4 A When it was originally issued, the front and
( 5 back covers of it were blue.
6 Q Did you assist in the preparation of 7 the blue book?
8 A Yes.
9 Q N'as the blue book generated by the 10 same task force that produced the small break 11 operating guidelines?
12 A Some of the small-break operating guidelines
! 13 are contained within the blue book as an appendix, 14 but a majority of the work documented in the i 15 report was produced by other personnel.
16 Q What other personnel worked on it?
17 A Personnel with ECCS Analysis and, personnel 18 with Safety Analysis.
19 Q That is Labe11e's outfit?
20 A Yes.
21 Q Will you turn to Page 4521 way up near 22 near front.
23 A 4521.
24 I was looking for another type of page
}
25 number.
p---- .e g - a.y pw&r v-, y, %-v----y-y g y 9a w -----
wvw- - - - - - - - -
1 Dunn 827 2 Q At the bottom of the page do you see 3 where it says, "The work documented in this 4 report..."?
(i 5 A ,
Yes.
6 Q It says, "The work documented in this 7 report leads.to the following conclusions:
8 al. Analytical codes are available 9 that accurately predict plant response to various 10 transients and small break scenarios. These codes 11 have been. benchmarked against the TMI-1 data."
12 Do the analytical codes include CADDS 13 and CRAFT-27 14 A Yes.
15 g was this a reference to any other 16 codes?
17 A I would have to review the document to 18 answer that question.
19 q what is your belief?
20 MR. FISKE: Well, if he has to review 21 the document, he can review it.
22 MR. SELTZER: All right.
23 Q Is the re anything that you could turn 24 to easily within the document to refresh your
- (' }
25 . recollection? If so, please do.
t
1 Dunn _ 828
>O V 2 A Within the s ummary and conclusions , the only 3 codes mentioned are CADDS and CRAFT.
4 Q When you say that these codes have
( 5 been benchmarked, what does that mean?
6 A The appropriate boundary conditions from 7 the incident at Three Mile Island were utilized 8 in a simulation of the event with the codes.
9 Following the simulation, the product of the codes 10 was compared to the data judged to have a 11 sufficient level of accuracy.
12 Q Were these codes in use at Babcock &
. (- 13 Wilcox at the time of the Davis-Besse transient?
14 A I can't testify to the use of the CADDS 15 code.
1G . Essentially the CRAFT code was in use l 17 at'that time.
{
18 Q Did you benchmark the CRAFT code 19 against the Davis-Besse Sep te mber 24, 1977 20 transient?
21 A No.
22 Q Is benchmarking a way to test the 23 accuracy of a computer code?
24 A It.is one way.
(
25 Q Is that why you benchmarked CADDS
.-y -
1 Dunn .829 O
V 2 and CRAFT against.TMI-27 3 -A No.
4 Why did you benchmark those. codes Q
(' 5 against TMI?
6 A There were two reasons. One was to 7 demonstrate that the codes would essentially 8 reproduce the Three. Mile Island. accident. The 9 second one, reason, was to gain some insight 10 over and above the data as to what had occurred 11 to the fluid volumes within the reactor coolant 12 system during the transiant.
(O) 13 You said the first purpos.e was to Q
14 determine that the codes would reproduce the 15 Three Mile Island accident.
16 Why did you want to determine that?
17 A r wanted to demonstrate it. I didn't use 18
" determine."
19 Why did you want to demonstrate that?
Q 20 A At the time I initiated the evaluation, 21 I thought there would be interest in that, and 22 . I thought it would have usefulness in future 23 licensing arenas.
24 Q Would you look at Page 518, please.
25 A 4518?
I
1 Dunn 830 2 Q Right. In the second paragraph of the Introduction it says, "
3 This report documents 4 recent analytical work performed by Babcock &
( 5 Wilcox in connection with small breaks. These 6 analyses were performed to develop further 7 understanding of plant response during various 8 small break scenarios."
9 ' The reference to analysis includes 10 work performed by ECCS Analysiss rig,ht?
11 A Yes.
12 It goes on to state, "The results of Q
\~-) 13 these analyses were used as a basis for 14 developing operating procedure guidelines which in 15 turn will form the basis for the development of 16 further' training and detailed operating procedures 17 where necessary." -
18 Are the operating procedure guidelines 19 that are referred to there the small break 20 guidelines that were previously marked as GPU 21 Exhibit 108?
22 A Yes.
23 Q was it your understanding at the time
() 24 that the blue book was issued, GPU Exhibit 109, 25 that the small break operating guidelines were
-- - ., - - - . , , - , - - - - - , . - -7,- v, ., - , , - , , , , , , -w,, --------,,-y --
1 Dunn 831 2 going to be used as the basis for the development 3 of further training and operating procedures?
4 A Yes.
J( 5 Q As a result of these analyses did B&W 6 develop a further understanding of the plant 7 response during various small break scenarios?
8 A I phrased my opinion on these analyses as 9 being basically. confirmatory of our previous 10 positions. I certainly created a computerized 11 set of data which is of use in ?xtrapolation and 12 in understanding things to a greater detail than 13 is necessary to rdach the conclusion of bounding 14 analysis.
15 B2rther they spec'ified or allowed us 16 to specify certain points such as the minimum
( 17 time for <.
initiation of high-pressure injection
- for total loss of feedwater event.
l 19 Q Would you turn to Page B 4519, 1
20 Do you see the last paragraph on that g' 21 page?
\.
22 g 7,,,
23
, Q It states there, "This report also 24 describes some equipment changes which will i
' g -
provide greater assurance that the most likely
r 1 Dunn 832 2 small leak (opening of the pilot operated relief 3 valve - PORV and reactor trip on loss of feed 4 water) will not occur and other changes that, i
(' .
5 should a leak occur at any point, will aid the 6 operator in diagnosinc plant status so that 7 correct actions will be taken."
8 when did you first learn that the 9 opening of the pilot operated relief valve was 10 the most likely small leak in the reactor coolant 11 system?
12 A About two minutes ago.
13 Q .Do you understand the phrase, "small
~
14 leak," to be used here in the 15 same sense ECCS analysis sometimes uses the 16 phrase, "small break," or commonly uses the phrase, i 17 "small break"?
18 MR. FISKE: I will object to that, 19 Mr. Seltzer, unless Mr. Dunn reviewed this 20 at the time and.had some understanding then.
21 Q Did you review the blue book before it 22 was issued?
23 A Not totally.
24 Q what parts did you review? Well, let 25 me ask you first: Did you review the
---,e,, - , - - - , , - ,
(
1 Dunn 833 2 introduction and summary and conclusions?
3 A I don't recall whether I did or not.
4 Q Did you receive a copy of the blue
() 5 book?
1 6 A Yes.
7 Q 'Did you receive a copy on or about 8 May 7, 1979?
9 A Yes.
10 Q Do you keep a copy in your office?
11 A No.
12 .
Q Has anybody ever called you up from t -
J 13 the operating plants and said, "Mr. Dunn, we have 14 got a problem; can you help us?" Or words to 15 that effect?
16 A Not usually. But I get those kind of t
17 questions from the engineering staffs.
18 MR. FISKE: You mean at B&W?
19 MR. SELTZER: No, the customers.
20 Q Prior to the last ten minutes had
)
l 21 anybody at B&W ever told you that the sticking 22 open of the pilot-operated relief valve was a 23 highly probable small break?
24 MR. FISKE: I object to the form of 25 that question.
1 Dunn 834 2 You mean that it was -- are you asking 3 him whether anybody from B&W told him that 4 it was highly probable that the PORV would 5 ytick open? Is that what you are asking him?
6 MR. SELTZER: 0.K., that's a good 7 question.
8 tiR . FISKE: Good.
9 THE WITNESS: Is that the question?
10 .MR. FISKE: Yes. ' '
11 Yes.
Q i 12 A No.
O' 13 Q Do you believe that the statement on 14 Page 4519 is incorrect in saying that the pilot 15 operated relief valve is the most likely small 16 leak?
17 A Yes.
18 Q Is that the first time you have ever 19 told anyone that?
l 20 A I don't believe so.
21 Do you think you spotted this error Q
22 in here before?
A You asked for my belief?
() 24 Q Right.
A I would not say that that is an error.
1
~ ~ ~
s Y \
1 '
, Dunn 835
~.
'O 2 Q You don'tithink it is an error, I.
.\
I I
I 3 don't want to push it. ,
4 What were the equipment changes that
( 5 were made to provide assurance that there would 6 not be a break caused by thIopening~ofthepilot l 7 operated relief valve? -
1 8 MR. FISKE : Maybe he.can direct 9 us to the cage of the re' port.
10 MR. SELTZER': Fine. You mean where
- x _
11 am I reading from?
12 MR. FISKE: No. It says the report p) s, 13 also describes' some_ equipment chan'ges.
I 14 assume that[is what you a're asking'him',
15 s what changeuare de'seribed.
I thought.it y s 16 m ght-save' time'if we can just find the page, 17
- vuich N' don',t carry around in my head. ,
'1 i .'
18 A ,
We ll ', it might be difficult. I don't see i s 10 an indication of'where ittmlght be in the Table '
29 of Contents. ~
' s, 5 21 Q Would you turn to Page 4534, please.
22 K 4534.
- .(
-- Q Is t,his section,on CRAFT.. analysis the t ,
( _section that wis I written by your section, your 25 unit? .
3 m
1 Dunn 836 A
I i
\_/ A This is one of the sections.
2 3 Q Did you review this before it was 4 finalized?
A I
( 5 I reviewed it for intended content. I did 6 n t have the opportunity to review in detail the 7 actual words.
8 Q The introduction describes the fact g that the CRFET-2 code was run in a simulation of 10 the first hour of the Three Mile Island transient, 11 'right?
12 A Yes.
(h
(- .
13 Q In th'e middle of the second paragraph
. 14 it states, " Actual HPI flow rates after ten 15 minutes into the transient are not available.
16 However, plant data indicate that the HPI was 17 throttled and manually controlled by the operator.
18 Therefore, an estimated value of 200 gpm was used 19 for the remainder of the analysis to show that 20 system voiding had occurred even though the 21 indicated pressurizer level shows that it was full km 1 22 of liquid."
23 Does that mean that after some early 24 point in the accident you assumed that high 25 pressure injection had been manually throttled back l
I
\
1 Dunn 837 i 2 to a rate of 200 gallons per minute at Three Mile 3 Island?
4 A For the purposes of this specific analysis,
,I ( 5 yes.
6 Q You then continued to run the code 7 simulation to see what the response of the reactor 8
coolant system was to the reduced emergency l
9 injection and the continued loss of coolant l 10 through the stuck open pilot operated relief valves i
11 is that right?
12 A Yes, I believe so. *
~
13 Q When you did that simulation, the 14 analysis showed that system voiding occurred and 15 that refers to voiding in the reactor coolant 16 systems is that right?
17 A Yes.
1B Q " voiding" is another word Uor 19 saturation?
20 A No.
21 Q In this sense does voiding refer to 22 the occurrence of saturation in the primary 23 coolan t system, as used in this context? Does
- 24 the word " voiding" refer to the fact that 25 saturation occurred in the reactor coolant system?
1 Dunn 838 O 2 MR. FISKE: In the context of the 3 third paragraph on Page 4534?
4 MR. SELTZER: No, the second
(* 5 paragraph.
6 MR. FISKE: I'm sorry. Oh, yes, I'm 7 sorry, yes. The last sentence?
8 MR. SELTZE R : Yes.
9 A The statement that voiding occurs indicates 10 that the system would have been at a saturated 11 state and expanding for a period of time, the 12 Three Mile Island and this analysis}were at a i
l O s 13 saturated state from, I think, approximately 14 ten minutes on. I would need to review the date i
15 to give an exact time.
16 Q " Voiding" means that there was steam l
17 being fo rme d , right?
18 A Yes.
19 Q And your analysis showed that steam 20' was being formed even though the indicated l 21 pressuriser level showed that the system was full 22 of liquid, right?
23 MR. FISKE: I am not sure that is i
24 what that sen tence means.
25 MR.. SELTZER: That is why I am asking
_~.-__-_--_.--,_- _. _ _ ---
a 1 Dunn 839 2 the question.
3 A I am not sure of the author's implication 4 in that sentenca, ei th er. I can read it two ways.
( 5 g What are the two ways you can read it?
6 MR. FISKE: Well, this is ridiculous.
7 MR. SELTZER: Everything you obj ect 8 to is ridiculous. Why don't you just say '
9 you object to the form of the question?
10 MR. FISKE: Well, I do;.and I don't 11 see asking Mr. Dunn to read it now and tell 12 you what the two different options are meaning
(,)
(~%
13 anything. It seems we ought to ask the 14 Person who wrote it.
16 Q Who wrote it?
17 MR. SELTZE R: Probably Mr. Dunn wrote 18 it.
19 A No, I did not, write it.
20 Q Who wrote it?
21 A Either Bob Jones or Bill Bloomfield.
L 22 MR. FISKE: My real obj ection was 23 that I think you were misstating what the 24 language of the exhibit is.
25 MR. SELTZER: Well, the pronoun "it";
1 Dunn 840
(~h '
k- 2 and the ques tion is , what is the antecedent 3 of "it" as it appears in the next-to-last 4 line of the second paragraph.
1
( 5 Q As you read-this when it was being 6 issued in or about early May 1979, what was your 7 understanding as to what the "it" referred to?
8 -
A I indicated that I reviewed this for 9 intended content. I did not review the words.
10 That I recall I did not review the words.
. 11 Q What does the "it" refer to as you 12 read it now? *
("% .
\m) 13 MR. FISKE: I will not let him answer 14 that. -
15 MR. SELTZER: Are you going to direct i
16 him not to answer?
17 -MR. FISKE: Yes, I don't think there 18 is much point in. having him answer it l
i 19 because it's a worthless answer in terms i
l 20 of any meaning.
21 MR. SELTZER: Why don' t you obj ect; 22 your objection is preserved, and I think that 23 it is the proper way to proceed.
24 MR. FISKE: All right. This is your
(
25 last question of the day. I will let him
_-~;_... _ - - - - . - _ _ _ .
1 Dunn 841 2
answer this subject to the clear objection 3 that this is totally improper.
4 Go ahead, Mr. Dunn.
(, 5 A I would expect it refers to the pressurizer.
6 Q You said earlier it could refer to 7 either of two things. What was the other thing 3 .
you were testifying about it could refer to?
9 MR. FISKE: I object no that. He 10 told you what he thinks it re fe rs to. I 11 ,
I thAnk that i s going too f ar , and it is
.12 certainly going too far to ask him what 13 -
all the other possible options are.
14 He does have to get his plane at 15 4:15. He does have to leave to get his 16 plane by 4:15, by my watch, if not by 17 Charlie's.
18 MR. SELTZER: Well, on that --
19 MR. FISKE: At that level?
20 MR. SELTZER: Yes, at that level let's 21 call it a day.
l 22 i
We will resume this deposition at 23 another time to be agreed on.
24 MR. FISKE : '
We will discuss that 25 s ub j ect.
(~
1 Dunn 842 2 MR. SELTZER: We have the deposition 3 of Mr. Walters, which is scheduled for the 4 week of April 13th, and we have the i (s 5 deposition of Mr. Kelly scheduled for the 6 week of April 27th; is that righ t?
7 MR. FISKE: That's right. I will 8
gu'arantee you that whatever resu:nption of Mr.
9 }
Dunn's deposition, if any , will be be fora.
l l
10 April 13t.n but I think at least we ought 11 to proceed in an orderly fashion.
12 MR. SELTZER: Fins.
13 MR. FISKE: We will talk. about it.
14 (Time noted: 4:16 o' clock p.m.)
15 S
17
%d/2-aERT M. DUNN 18 Subscribed and sworn to before me 19 this d 9 day of O 198h I 20 21 Notary Public 22 ga 9.ceh
\ 2, sw "w % g: _A s nr3 O 24
- U .
25 s'
i
1 1 843
/ -
(m) . CERTIFICATE STATE OF NEW YORK )
3 : ss.:
COUNTY OF NEW YORK )
4 CHARLES SHAPIRo, C.S.R.
I, , a Notary Public of the State of New York, do hereby certify that the continued deposition of BERT M. DUNN wag taken before 8
me on_ .\ arch 24, 1981 cons 12 ting of pages 726 through 842 _; ,
I further c.ertify that the witness had oeen previously sworn and that the within (v 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 am I in the employ of any of the counsel. -
18 IN WITNESS WHEREOF, I have hereunto set my 19 TN hand this 10 day of Mdi t. ' , 1981.
20
.- 21 ls 22 J9 .
kvMr Charles Shapiro A o 25 4
~7
, . . , . - , ----~ - - . . . - - - , - - - - - - - - - - , - - - - - .
l n... -
844 I N DE X 4 ,
- . WITNESS PAGE
. BERT M. DUNN, Res ume d 728 to ._
T I . f '
-r .
b E XEI E ITS f;fh;g~
'; ) .
I[i GP U FO R IDENTIFICATION 1
103 Memorandum dated April 28, 1979 from D. R. Roy a n d 8.R . E.
Kosiba to Distribution, ,
subject: " Preparation of Operating Guidelines for Small Breaks.in RC Presaure O Boundaries" 730 106 Kandwritten memorandum by M5. Dunn entitled "Small Break Indications" 751
( 107 Memorandum dated April 30, 1979 from E. R. Kane to_D..H.
,' Roy, subject: "Small Bre ak Procedures," copy to Mr. Dunn 761 108 Covering memorandum dated i May 7, 1979 to K. R. Ellison from D. F. Hallman, with
, g attached Operating Procedure s'\_c Guidelines for Small Breaks dated May 5, 1979 766 109 Volumes I and II of the book,
" Evaluation of Transient O'ss Behavior and Small Reactor Coolant System Breaks in the 177 Fuel Assembly Plant, May 7,,
1979" 823
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