ML20072J139
| ML20072J139 | |
| Person / Time | |
|---|---|
| Site: | Three Mile Island  |
| Issue date: | 03/10/1982 |
| From: | Brummer J GENERAL PUBLIC UTILITIES CORP. |
| To: | |
| References | |
| TASK-*, TASK-08, TASK-11, TASK-8, TASK-GB NUDOCS 8306290954 | |
| Download: ML20072J139 (156) | |
Text
{{#Wiki_filter:r- ] I f f i UNITED STATES DISTRICT COURT es (v l SOUTHERN DISTRICT OF NEW YORK ______________________________________x
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GENERAL PUBLIC UTILITIES CORPORATION, : JERSEY CENTRAL POWER & LIGHT COMPANY, METROPOLITAN EDISON COMPANY and : PENNSYLVANIA ELECTRIC COMPANY, t., : Plaintiffs, cb
-against-THE BABCOCK & WILCOX COMPANY and J. RAY McDERMOTT & CO., INC.,
Defendants. :
--------------------------------- L----x i
Deposition of JOHN A. BRUMMER, taken by De fendant , pursuant'to letter agreement and Rule 3 0 (b) (6) , at the l offipes of Davis Polk & Wardwell, Esqs. , i One Chase Manhattan Plaza, New" York, New York, on Wednesday, March 10, 1982, at 10:09 o' clock in the forenoon, before Charles Shapiro, a certified Shorthand Reporter and Notary Public within and for the State of New York. 8306290954 020310 PDR T ADDCK 05000289 PDR , t t b)
'% d DOYLE REPORTING. INC.
CERTIFIED STENOTYPE REPORTERS 369 LEXINGTON AvrNur WALTER SHAPIRO. C.S.R. New YomK. N.Y. 1o017 CHARLES SHAPIRO, C.S.R. TEl.EPHONr 212 - 867 8220 6
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2 Appe aran ce s: 3 KAYE, SCHOLER, FIERMAN, HAYS & HANDLER, ESQS. Attorneys for Plaintiffs 4 425 Park Avenue New York, New York (# 5 By: JOEL KATCOFF, ESQ., 6 of Counsel. 7 8 DAVIS POLK & WARDWELL, ESQS. Attorneys for Defendants 9 One Chase Manhattan Plaza New York, New York 10 *. By: WILLIAM A. WURTZ, ESQ., 11 of Counsel 12 (_ 13 LeBOEUF, LAMB, LEIBY & MacRAE, ES S. Attorneys for the Witness,' John A. Brummer 14 1333 New Hampshire Avenue, N!W. Washington, D. C. 20036 15 , By: KEVIN M. WALSH, ESQ.,
- 16 of Counsel i 17
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18 Also Present:
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' JONATHAN QUINN 20 DONALD NITTI i
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%J 2 IT IS HEREBY STIPULATED AND AGREED by I l
3 and among the attorneys for the respective 4 parties hereto, that the sealing, filing and ( 5 certification of the within deposition be, 6 and the same hereby are, waived; and that the 7 transcript may be signed before any Notary 8 Public with the same force and effect as if 9 signed before the Court. 10 IT IS FURTHER STIPULATED AND AGREED 11 that all objections, except as to the form of
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trial. 14 15 * *
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%s 2- JO HN A. B RUMME R, having been 3 first duly sworn by the Notary Public, was 4 examined and testified as follows:
( 5 MR. KATCOFF: This deposition is taken 6 pursuant to Rule 30 (b) (6) and stipulation 7 between the parties that these depositions 8 would not involve questions on substantive 9 issues, such as training, Davis-Besse, prior 10 transients or operator action during the 11 accident. 12 MR. WURTZ: Off the record. 13 (Discussion off the record.) - 14 MR. WURTZ: Will you please mark the 15 resume of John Allen Brummer as B&W Exhibit , i 16 591. 17 (Two-page resume of John Allen Brummer 18 was marked as B&W Exhibit 591 for I 19 identification, as of this date.) 20 EXAMINATION BY MR. WURTZ: 21 Q Mr. Brummer, did you prepare this resume? 22 A Yes. 23 Q This is an accurate statement of your (3 () 24 l education, training and work experience as of today? 25 A Yes.
I 1 Brummer 5 O
-V 2 Q Your resume states that in the period from 3 1974 through 1980, you took graduate engineering 4 courses at Pennsylvania State University.
( 5 Could you describe the content of those 6 courses? 7 A The content was working toward a Master's 8 of Engineering Science degree, where I took a number 9 of courses in various engineering fields dealing 10 with thermal dynamics, digital electron!ics power 11 distribution, -and I had a course in atomic physics. 12 Q What degree program were you in? It was T (\ 13 a Master's degree? 14 A It was a Master's of engineering in 15 engineering sciences, the program I was enrolled a 16 in at that time. I 17 Q So engineering sciences was the area as 18 defined by the university? 19 A Yes. l r 20 Q Was that intended to include a number of 1 21 engineering fields? l 22 A Yes. I j 23 Q could you identify those engineering [) v 24 fields? 25 A Well, the criteria established by the l l
1 Brummer 6 A 2 school allowed me to elect, I just couldn't major 3 in one specific field, so I took courses in mechanical 4 engineering and electrical engineering. gs 5 Q I see that you hold a senior reactor 6 operator license on Three Mile Island Unit 2. 7 When did you receive that license? 8 A The license is dated July 18, 1979.
'9 , Q' ' Prior to that time, did you have a 10 reactor operator's license? E
, 11 A No. 12 g .So the first license you got was the
\d 13 senior reactor operator's license?
14 A That is correct. l 15 Q After you graduated from Tennessee 16 Technological University in 1974, did you go to work 17 for Met Ed? - 18 A Yes. 19 Q Your position was that of a plant 20 instrumentation engineer at that time; is that correct? l 21 A Yes. I ! 22 Q And you held that position until August of l 23 1979; is that right? i i
.O 24 A Yes.
25 Q To whom did you report during that period
1 Brummer 7 2 of 1974 to 19797 3 A It was broken into severh1 phases. The 4 first phase I reported to, the position was called 5 the station engineer when I was first hired. ({ 6 Then I reported to the unit superintendent 7 and after that there was a new position, which was 8 a unit superintendent technical support, which I 9 reported to. 10 Q. Could you identify the stadion engineer 11 you reported to? 12 A By name? 13 Q By name. . 4 14 A Tom Baer. 15 -Q could you spell that, please? 16 A B-a-e-r, I believe.
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17 Q During what time period was that? 18 A It was approximately from March 1974 19 through October 1974. 20 Q 'Then you began reporting to the Unit 2
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21 superintendents is that correct? { 1-h 22 Yos. Af 23 Q could you identify that person? s fs ,- .
- I, 24 j A ,,, Gary Miller.
25
, Q How long did you continue to report to him?
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1 1 Brummer 8 A 2 A From approximately October 1974 through 3 approximately mid-1975. 4 Q At that time, you began reporting to 5 the Unit 2 technical support superintendent; is ({ 6 that correct? 7 A Yes. 8 Q Who was that? g A Jim Seelinger. That position -- he 10 changed positions later on. I'm not s d,r e of the 11 approximate dates. 12 Q And then you reported to Mr. Kunder when C_ 13 he took that positions is that correct? e A 14 Yes. 15 Q I believe Mr. Kunder took that position J 16 in December of 1978. 17 A That's correct. I think. . 18 Q Did you ever have any responsibilities 19 on Unit 17 i 20 A Yes. 21 Q During what time period? 22 A The very beginning in 1974 when I came 23 with the company. () 24 Q How long did that last? 25 A Approximately five months.
1 Brummer 9 (v 2 Q Could you describe those responsibilities? 3 A At that time, I was a shift surveillance 4 engineer. My responsibilities were to review the 5 surveillance procedures run during the shift I was { 6 assigned. 7 Q You mean review them after they had been 8 carried out by the technicians? 9 A That's right. I was to insure that the 10 proper sequence was followed as far as,.you know, 11 the procedures were supposed to have been run. 12 w Q For what equipment? N- 13 A It was all tech-spec related equipment. 14 Q So it went beyond the radiation equipment 15 to all tech-spec surveillance; is that correct? 16 A Yes. 17 Q- Were you reporting to Mr. Baer during 18 that time? 19 A Yes. That's who I had worked for. ! I was 20 temporarily assigned to Unit 1 under him. 21 Q And then in the summer of 1974 you were 22 assigned to Unit 2; is that correct? 23 A Could you repeat that? [] U-24 Q- Is it correct that in approximately the 25 I summer of 1974, your responsibilities shifted to L L
1
, Brummer 10 ~)
(J . 2 Unit 2? 3 A At the end of the summer, yes. 4 Q What assignment did you receive in Unit 27 gr 5 A I continued my duties as plant N 6 instrumentation engineer. 7 Q What did those duties involve? 8 A At that time, it was reviewing system 9 descriptions prepared by various architect engineers 10 and beginning to review procedures which were prepared 11 by the architect engineer, and just a general review 12 of the supplied equipment for TMI-2.
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13 Q What system descriptions we,re you reviewing 14 on Unit 27 15' A I don't remember specific names of , 16 specific system descriptions I reviewed at that time.
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17 Q Can you categorize it in any fashion? 18 A There were the operating systems, system 19 descriptions. ' 20 Q so your review went beyond instrumentation 21 to other systems and components? 22 A The main emphasis of my review was on the 23 instrumentation. [) v 24 Q When you say " instrumentation," what things 25 do you include in that?
f f 1 Brummer 11 f
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2 A Devices such as pressure indicators, , 3 pressure transmitters, flow transmitters. 4 Q Anything else? 5 A Any type of indication that would be (' 6 provided to an operator, be it local, remote. 7 Q You stated that you were reviewing 8 procedures during that time period. 9 What kinds of procedures? 10 A The kinds of procedures thA,t were 11 developed by the architect engineer at that time 12 were process procedures for balance of plant systems.
' 13 Q What do you mean by that? .
14 A By " balance" -- 15 Q Well, " process proce dures. " 16 A Process operating procedurer. They were 17 not specific instrument procedures or electrical IS' maintenance procedures. They were operating 19 procedures. 20 j Q For the running of balance of plant , 21 equipment? (- 22 A Yes. 23 Q You were doing equipment drawing review rh () 24 during that time period also? 25 A The review of the drawings was to see that
1 Brummer 12
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2 it was consistent with the procedure. 3 Q could you identify the balance of plant 4 systems that you were involved with? 5 A some of the balance of plant systems would ( 6 be to circulate water, circulating water system,- 7 feedwater system, condensate system, to name a few. 8 Q Did your responsibilities change at some 9 point? 10 A I worked as instrumentation', engineer 11 throughout that time frame. There was a time frame 12 of about three months when I was in license training, 13 in which I worked with another instrumentation 14 engineer because I could not be in full-time support
- 15 of instrumentation activities.
l 16 Q What I am trying to determine here is 17 I see that for the period 1974 to 1979 you- held the 18 position of plant instrumentation engineer in Urent 2. 19 What I would like to do is move through 20 that period and understand what your specific 21 respon.sibilities were in each time period, and I L 22 understand that the first time period in Unit 2 23 you were reviewing the system descriptions and the 24 process procedures for balance of plant. t We just 25 l discussed that. l-
f 1 Brummer 13
, 2 Did there come a time when your 3 responsibilities as an instrumentation engineer 4 changed?
(, 5 A Could you be more explicit about 6 responsibilities? Are you talking about -- 7 Q Well, what I mean is, you didn't review 8 system descriptions from 1974 to 1979, I take it. , 9 What I am asking is what is the next thing 10' you did, what is the next thing you were responsible 11 for? I would just like to go historically from 12 1974 to 1979, if you can break that time period into 13 major divisions, and tell me what your key 14 responsibilities were in each of those time periods 15 in the maj or divisions. 16 I think that would be the fastest way to 17- proceed. .
, 18 A Can I take a break at this point?
19 Q Sure, if you need to. 20 MR. KATCOFF: Do you want to talk to me ! 21 or your private counsel? 22 THE WITNESS: Y,e s . 23 MR. KATCOFF: O. K., let's have a break. 24 (Recess taken.) 25 l
1 Brummer 14
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2 BY MR. WURTZ: 3 Q Just before the short recess, Mr. Brummer, 4 I had asked you if you could tell me what your 5 specific responsibilities were as plant instrumentation ({ 6 engineer during the period 1974 to 1979. 7 A O. K. The next logical phase was I 8 served as a PORC member, which is plant operations i 9 review committee, reviewing additional procedures 10 which were prepared and. submitted to PdK C as a first 11 draft, and at that time it was mainly operating 12 procedures.
'~ 13 Simultaneously with that, was reviewing 14 the systems as they were being constructed and in the 15 initial phases of turnover were reviewing the 16 instrumentation packages that were prepared by the 17 constructor. -
l 18 Q What time period did these responsibilities , 19 fall into? l 20 A Those responsibilities fell into a period 21 of -- from mid-1975 through '76. (. 22 Also during that time period, O. K., I was 23 working with the radiation monitoring system. That i
) 24 l was a prime system that Met Ed had interest in insuring 25 - that it was accepted.
1 Brummer 15 p O 2 After that time period, I was working with 3 the start-up and test group testing the radiation 4- monitoring system, which lasted a period of about 5 nine months of testing, and that was consistent with ( {T 6 the construction effort as it was completed. 7 During that time period, we were receiving 8 systems for turnover, in which I was responsible for 9 reviewing the packages and I was -- continued to be a 10 PORC member reviewing plant operations! documents. 11 Q So that would cover the first nine months 12 of 1977 when you were doing the start-up work on the 13 radiation monitoring system? 14 A That actually -- the radiation monitoring 15 system actually drew into -- it was completed around s 16 February 1978 j ust prior to fuel load. 17 Q The start-up testing was? . 18 A The start-up testing was. 19 Q Then for the period beginning in February? 20 A o. K. 21 Now, also during that period, I was working 22 with the tech-specs and developing surveillance 23 procedures to satisfy the tech spec requirements. [) v 24 Q Were those surveillance procedures 25 developed by early 1978 when the start-up testing on
1 Brummer 16 (s) 2 the radiation monitoring system was completed? 3 A Yes, that was a requirement, that the 4 surveillance procedures be prepared prior to starting ( 5 the plant up. 6 Q so when the reactor initially went cri ti c.al 7 in March of 1978, I believe, the surveillance 8 procedures and the start-up testing for the radiation 9 monitoring system had already been completed; is that 10 correct? ', 11 A The surveillance procedures, O. K., were 12 prepared; however, the surveillance procedures, the i N/ 13 data that was required by them, was also included 14 in the test procedures, so therefore, the test 15 procedures were used as the initial run of the 16 surveillance procedures. That data was transposed. l 17 The test procedures were more comprehensive than what l 18 the surveillance procedures required. 19 Q After the time when the surveillance 20 procedures for the radiation monitoring system got 21 developed and the initial start-up testing got 22 completed, what responsibilities did you have? 23 A I was -- continued to be responsible for
) 24 plant instrumentation systems, O. K., in general. And 25 in --
that was a period up through 1979.
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I 1 Brummer 17 2 During a period from approx'mately 3 september to December, I was designated as the plant 4 tuning coordinator and was responsible for insuring 5 prope r . tuning of the systems. (( 6 Q What year was that, 19787 7 A '79. 8 Q That is when you became lead g instrumentation engineer? 10 A Lead instrument -- 1 was id.ad 11 instrumentation engineer for a period prior to that, 12 which was from February, approximately February of O' 13 1978 through until approximately December of '79, at 14 which time I then became an instrumentati'on engineer, 15 because I went into a license training program. There 16 was a little break in there. 17 Q Just so I have this clear, beginning in 16 early '78, after you completed the startbp testing 19 on the radiation monitoring system, you continued 20 throughout 1978 as a plant instrumentation engineer? 21 A No, I am qualifying that.
- 22. Q All right.
23 A During 1978, I was given the title of lead ( ' 24 instrumentation engineer for the unit. 25- Q I see. So that is a correction to your
1 Brummer 18 2 resume here, which says August of 1979, in fact that s 3 happened in .1978, as you recall? 4 A Yes. There was a break there. Yes. 5 Q So in fact in August of 1978 you became ({ 6 lead instrumentation engineer for Unit 2? 7 A No. I became lead instrumentation engineer 8 sometime in the spring of that year. I don't remember 9 the specific month. 10 Q In the spring of 1978? t 11 A In the spring of '78. 12 Q What were your responsibilities as the l .
's 13 lead instrumentation engineer?
14 A My responsibilities did not change 15 specifically. I was just the lead engineer at that 16 time. 17 Q How many people reported to you as lead 18 instrumentation engineer? 19 A I had one permanent Met Ed employee. 20 Q Who was that? 21 A Jim Paules. 22 Q Could you spell that, please? 23 A P-a-u-1-e-s. r 24 As lead instrumentation engineer, I take (} Q 25 it you were responsible for all instrumentation on
1 Brummer 19 C' (m 2 Unit 27 3 A 'Yes. 4 Q What aspects of instrumentation did that ( 5 include? Was it the ongoing surveillance program
- 6. or maintenance or all of the above?
7 A It included all instrumentation; if there 8 were modifications that had to be made, I had to 9 initiate the proper paper work. I worked with 10 ( maintenance to resolve maintenance type' problems. 11 Q Were you responsible for ongoing 12 surveillance? U 13 A I was not directly responsible for it. 14 If a problem happened with the surveillance 15
; procedure where it required correction, I,was called in ,
16 as needed to provide the engineering input. 17 i I Q You did not review and sign off or approve , j 18 ! surveillance activities as lead instrumentation . 19 engineer? 20 A l That was not a specific function of myself, 21 no. k' 22 Q You were a lead instrumentation engineer 23 and were in the spring of 1978. 24 How long does that continue? 25 A It continues into the fall of '78.
1 Brummer 20 n. 2 Q What happened then? 3 A At which time -- during that period I 4 went into a -- I began getting very much involved ( 5 with tuning an d I worked with another instrumentation 6 engineer who assumed the position in the late fall, 7 after which time I went into my license training 8 program for the SRO license. 9 Q You said you got involved in tuning in the 10 fall of 1978. ', 11 What do you mean by that? 12 A Tuning was the setting up of the control s 13 system supplied as part of the plant. 14 Q What control systems? 15 A Specifically, the ICS, which is the 16 integrated control system supplied, and the non-nuclear 17 instrumentation system and the nuclear instrumentation 18 RPS system, reactor protection system. 19 Q So in the fall of 1978 somebody else took 20 the position of lead instrumentation engineer; is that 21 correct?. 22 A Yes. 23 Q Who was that? O) ( 24 A Ivan Porter. 25 Q Also in the fall of 1978, you entered the
1 Brummer 21 A U 2 training program to get a senior reactor operator -- 3 A -That was the late fall. It was late 4 fall, very beginning of '79. ( 5 Q How long did your training last? 6 A The training lasted approximately three 7 months. 8 Q Was it all classroom training? 9 A No. 10 Q Could you describe what kid,d of training 11 it was? 12 A The training involved a series of 13 classroom lectures, followed by outlined programs 14 which I was following. 15 Q Self-study programs?
- 16. A As supplements to the classroom, yes.
17 control room training, actually standing
'18 shifts, working with operators, including simulator 19 training.
20 Q Where was the simulator training? 21 A Lynchburg, Virginia at B&W. 22 Q Do you recall when? 23 A February 1979. ( 24 Q You would actually stand shift with 25 licensed operators as part of your training? F =- - --
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I 1 Brummer 22 2 A I Participated in control room operations, s 3 nt assigned to a specific shift. 4 Q Then you took your SRO exam in the spring 5 of 1979; is that correct? g{ 6 A March 1979. 7 Q What position did you take.after the time e of your examination? 9 A I went back to being an instrumentation 10 engineer. I did not assume the positidn of lead 11 engineer. 12 Q So that -- O-
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13 A Until approximately August of '79. 14 Q So for a two-month period, yo'u were an 15 instrumentation engineer and then you returned to 16 your old position of lead instrumentation engineer 17 in August of 1979? . 18 A No, that's not correct. l 19 Q o . .K. 20 Let's try to get this straight, then. 21 You finished your studies and took your 22 exam in March of 19797 , 23 A Yes. m
) 24 Q What happened then?
25 A Then for a period of almost five months, e + - - m - _ , -
4 2 1 Brummer 23 ( V 2 I was a plant instrumentation engineer. 3 Q That was from March to August of 19797 4 A Right. And at that time, I then became 4 (~ 5 lead instrumentation engineer again. 6 Q You continued in that position, as your 7 resume indicates, for two years, from August of 2979 8 to August of 1981; is that correct? 9 A That's correct. 10 Q When you became lead instrdmentation 11 engineer in August of 1979, did you displace Mr.
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12 Porter in that job? (~N 13 A Yes. 14 Q What position did he take at that time? A 15 I do not recall the exact title.. 16 Q What was the function of the job? 17 A Start-up and test engineer. Supervisor. 18 Q For what facility? i 19 A TMI-1. 20 Q For TMI-1, and this was in August of 19797 21 A That was restart. 22 Q I see. 23 From August of 1981 to the present, you ( 24 have been working at the Oyster Creek facility; is 25 that correct?
1 Brummer 24 Ch 2 A That's correct. 3 Q Have you had any responsibilities at TMI-2 4 since. August of 19817 5 A Yes. ( 6 Q could you describe those? 7 A I have been doing some work with them as 8 far as instrumentation in answering questions and 9 maintaining a license, which includes attending shift 10 watches, attending training. i 11 Q In what areas of instrumentation have you 12 worked on Unit 2 since August of 1981? (~~) ~ k/ 13 A I have been assisting by answering questions 14 on the nuclear instrumentation and radiation monitoring 15 system. 16 Q Could you describe those activities in 17 the area of the radiation monitoring system? 18 A There were questions that we resolved on 19 HPR -- the station _ vent monitor and the reactor 20 building, air sample monitor, as just p rior to leaving 21 I initiated changes to put both those monitors in 22 service. 23 That's been a very minor role on my behalf I [~^; 24 i in dealing with the work at TMI-2. \_/ }
.25 Q The station vent monitor is what number?
1 Brummer 25 s/ 2 A HPR 219. 3 Q -And the sample air monitor? 4 A HPR 227. ( 5 Q could you describe the work you have done 6 in connection with monitor 2277 7 A Just prior to leaving TMI-2 in August of 8 1981, we initiated a program to restore HPR 227 to 9 service. 10 Q what did that program invol'ye? 11 A The program involved decontamination of the 12 monitor, replacement of the sample pump and some 13 minor piping changes within the unit to. bring it to 14 an operable status. 15 g could you describe what was done in the 16 course of this? 17 A I initiated the event of restoring it. 18 I did not actively participate in the restoration 19 of it. 20 Q Did you do this by writing a document 21 of some kind? 22 A There were some engineering changes, 23 change modifications known as EC:s which were [) 24 i initiated to make these modifications. 25 Q Did you prepare those?
1 Brummer 26 C t
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2 A I worked on preparing them. I was not 3 the sole preparer. 4 Q Were these engineering change modification (' 5 documents the means by which you started this 6 program to restore the 227 monitor to service? 7 A That was the means by which the work 8 could be done. There were verbal communications 9 prior to that about restoring 227. 10 Q To whom were those communichtions made? 11 A There were discussions with my direct 12 supervisor at that time about restoring 227 to service. A 13 Q Who was that? 14 A Branch Elam. 15 Q could you spell that, please, for the 16 record? 17 A 7 D-r-a-n-c-h E-1-a-m. - 18 Q What was his position? l, 19 A Director of plant engineering, l ! 20 Q Who else worked on the EC -- they are 21 called ECM's? l 22 A That's correct. 23 Q Who else worked on those? ( 24 A David Kulp, K-u-1-p. 25 Q What was his position?
E l 1 Brummer 27
/m 2 A Instrumentation engineer.
3 Q Did these ECM's outline the steps taken 4 to restore the 2277 5 A The ECM showed the changes that were to { 6 be made. They did not necessarily provide a step-by-7 step installation type procedure. 8 Q What changes were to be made? 9 A HPR 227 had originally been two sample 10 pumps, it was going to be modified to Have only one 11 sample pump and the sample pump was to be replaced 12 with a new type of sample pump that involved some f3 kl 13 piping modifications to allow the three channels to 14 be utilized -- to utilize the one pump. ' 15 .Q Any other changes? , i 16 A There were some other changes required on 17 the tubing runs due to the fact that just.after the ! 18 accident, the sample panel was reworked to allow i 19 samples to be periodically taken more easily from the 20 i re actor building. I i 21 Q So the changes in tubing were to create L 22 a situation where on an ongoing basis samples could 23 be more easily taken from the building; is that ( 24 . correct? 25 -A Yes, that's correct. In addition, it
1 Brummer 28 2 would allow there to be a slightly lower dose rate 3 ***** 4 Q The monitor itself would draw its sample ( 5 from a lower dose rate area? 6 A That's not correct. The modifications 7 that were made eliminated the monitor originally. 8 Q I'm sorry, I am lost here. 9 The modifications eliminated the monitor? 10 A The original modifications k-11 Q Yes. 7~ 12 A -- which were made just after the accident, U 13 took that monitor out of service totally. 14 Q I see. 15 A We were now placing that monitor back into 16 service. 17 Q Yes. - 18 A So therefore, we had to do piping. It's 19 tubing at that point. We had to do tubing changes 20 to put that back in service. 21 Q And you made a reference to a " lower dose 22 area" before. 23 What were you referring to? r I 24 A The monitor is located about five feet 25 from the sample pump -- pardon me -- five feet from
1 Brummer 29 n 2 the sample panel which is associated with it. The 3 monitor is closer to an area which is -- had a 4 higher dose rate due to the pipes which were on the 5 floor below, so therefore, the changes were made 6 to just use the sample panel with a portable or 7 temporary pump which would have been in a lower 8 dose rate area. 9 Q When you say " lower dose rate" or " higher 10 dose rate," as caused by the accident ?t; 11 A Yes. 12 S Q Besides the ECM's, did you prepare any 13 other documents in connection with the program to 14 restore the 227 to service? 15 A Not that I remember. 16 Q You said that after the accident, the 227 17 was taken out of service. . 18 when did that happen? 19 A Approximately the beginning of 1980. 20 Q What was the reason for taking it out of 21 service at that point? 22 A The reason was to obtain better samples 23 in a lower dose rate area.
) 24 Q At the time you took it out of service, 25 had you already planned to make the modifications and
j 1 Brummer 30 2 put it back into service? 3 A No. 4 Q At the time you took it out of service, 5 what did yo.u put in its place? ({ 6 A we used a sample panel, which was existing, I which drew grab samples only. 8 Q Could you describe what the sample panel 9 is? t i 10 A The sample panel is a metal', panel which 11 had various tubing and valving in to allow for a 12 Marenelli Beaker sample to be drawn, I guess a sample O
%) 13 to be drawn and Tritum Bubbler to be installed to 14 detect the amount of tritum inside the reactor building.
j l 15 Q You stated that during the period from 16 mid-1975 to early 1978, you were a member of the L 17 l PORc. - ( - 18 Did you remain on the PORC after early 19 1978 or did you leave it at that point? 20 A I remained on the PORC until my position 21 was changed and Ivan Porter assumed lead instrumentation 22 engineer and when he went to TMI for the restart l 23 I reassumed that position. 1 24 Was your first involvement with the Q 25 Unit 2 radiation monitoring system in the period from i
1 Brummer 31
%( )
,2 June 1975 through 19767 3 A That was the approximate time fraue.
4 Q Could you describe in some detail your (' 5 activities concerning the Unit 2 radiation monitoring 6 system during that time period. 7 A I got involved in the beginning when the 8 specification as written by the architect engineer 9 - was out, the bid was approved, the manufacturer 10 had constructed the radiation monitori$g system 11 and it was at his facility ready to be shipped. 12
/~~'T At that time, Met Ed reviewed what had
' 13 been done as required by the specification and by 14 the manufacturer's procedures and identified areas 15 which we were concerned with and wanted f,ur the r 16 calculations performed on.
17 At that time, I prepared an amendment to 18 the specification by which the equipment was purchased 19 to do a more comprehensive calibration of the system 20 above and beyond what the manufacturer n'ormally would
, 21 have done. This included using various point sources k
22 and actual gas and liquid ef fluents to identify the 23 concentrations and the sensitivities of the units Ch
.(j 24 as being supplied.
25 Upon the manufacturer accepting our f
1 Brummer 32 t'% 2 request, I periodically reviewed at his facility the 3 w rk that was done, including the calibrations, A 4 and reviewed the da t,e . 5 After that point, the equipment was ( 6 shipped to Three Mile Island, cad as construction
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7 was working on installing it, I periodically reviewcd 8 the status, and when construction was completed in g installing it -- by " installing" I mean locating the 10 monitor and installing the tubing, doing the wiring 11 verifications required by construction procedures -- 12 I began the start-up test phase. (~h (l 13 While construction was goi$g on, I 14 prepared the test procedures, which were reviewed by
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15 the TWG, which was the test working group, and then 16 began the test procedures as the equipment became l 17 available. i 18 Q O. K. 10 What we should do here perhaps'is to take l- 20 this one step at a time and clear things up as we go 21 along. 22 A O. K. l 23 , Q Because this is the principal area of i
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b) 24 the deposition and I want to get a detailed l 25 understanding of what your involvement was in this. t I
1 Brummer 33
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2 At the time you first got involved, had 3 the specifications drawn up by the architect-engineer 4 been approved? ({ , 5 A Yes, they were approved.
.6 Q Were you involved in that process? ,
7 A No, I was not. That was done prior 8 to my. . . 9 Q Who was involved in that? 10 A I cannot answer that. , 11 Q What did the architect-engineer 12 specifications include? rx . 13 A It was a detailed engineering specification 14 outlining the basic sensititivy of the units, what 15 standards it would be built to, a basic outline of 16 how it would be installed such that the vendor would 17 know what accessories to supply and construction 18 have a control room panel associated with the radiation 19 monitoring system. 20 Q Did this include drawings showing the , 21 intended location of each of the monitors? L 22 A The drawings that were included in the 23 specification were drawings showing the sample locations,
'Oj 24 not the exact location of the monitor inside the 25 building.
l
s 1 Brummer 34 _J 2 ,Q When you say " sample locations," what do 3 you mean? 4 A The atmospheric monitors which sampled
) (( 5 the particular ion gases -- pardon me, iodine gases 6 of sample tubes and ducts, which could be located i
6 7 differently from where the monitor was, so it would i, 8 not show the detailed tubing run as to where the f 9 monitor physically was located. 1 10 Q But it vould show you the a' yea in the l 11 building from which you were to draw the sample; is 12 that correct?
, '\ .
13 A Yes. 14 Q Then if you wanted to stretch a tube to l 15 a monitor that would be physically located somewhere j 16 else, that was something that was separate and apart i 17 from this specification? - 18 A That is correct. I ! 19 Q Do you know that there were employees at 20 Met Ed who approved the architect-engineer's 21 specification? ( 22 - A I have no knowledge of that. i 23 Q At the ' time you got involved, had the ( ) 24 manufacturer of the equipment been selected? 25 A Yes. r i
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, 2 Q ANd that was Victoreen; is that correct?
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5 alreddy built by the time you got involved? ) 6 1
'Q A =Yes.
4 N ' 7.+ 3 t Q 3o your assignment was to review whether 3 8 this equipment already built met the specifications
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My assignment was based on -- based on
\\ 15 what v,t'h'a~d learned from TMI-1, had we had sufficient s_, - 4
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y 16 calib' ration on the TMI-2 system, and I reviewed the i,
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g D; M 17 docnmentation based on that. It was just concerning s - s.. s> . s'
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review some Unit 1 information
.\- / 7.'.s L: J b 20, in,-, connection with your assignment?
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21' Y A- I had talked with and followed some of
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s- 22 I thii Unit 1 work, yes. m -
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25 '( A As part of this assignment. 4
1 Brummer 36 O V 2 Q With whom on Unit 1 did you have 3 communications on this subject? 4 A The lead instrumentation control engineer. 5 Q Who was that? 6 A Vic orlandi. 7- Q could you spell his name? 8 A O-r-1-a-n-d-i. 9 Q Who asked you to undertake this assignment? 10 A My supervisor'at that time was the Unit 2 11 superintendent. 12 Q O And that was Mr. Miller? \') 13 A Yes. 14 Also, I worked with Mr. Herbein discussing 15 the outline of the program.
~
16 Q Concerning checking the calibration? 17 A Right. ~ 18 Q ~ What had you learned from Unit 1 regarding 19 calibration of the monitors? 20 A The Unit 1 specification was considerably -- 21 was different.from Unit 2, since there were two 22 architect-engineers and the Unit 1 data that had been 23 obtained at the factory had proved to be very useful .( ) 24 from doing a calibration at the plant during the 25 start-up program, and therefore I was assigned to review
1 Brummer 37 O () 2 and try to establish a program like that for Unit 2. 3 Q So you wanted to make sure you had as much 4 information as they had on Unit 1; is that correct? 5 What I am trying to get at is, did somebody identify ( 6 a shortcoming in Unit 1 that you wanted to remedy in 7 Unit 2, or did you want to live up to the high 8 standards already met on Unit 17 9 A We wanted to establish the standards that 10 were already established on TMI-1 as fa'r as being 11 able to identify specific sensitivities for our 12 monitors. (~h ( 13 Did you make a judgment in this connection Q
,14 that more calibration work was required than the 15 architectSengineer called for?
?
16 MR. KATCOFF: When you say "you," you 17 mean personally? - j' - 18 MR. WORTZ: Well, I will say Me t Ed. 19 Q In this program that you were carrying out. , 20 A Yes, Met Ed had determined that we needed , 21 more calibration than was originally identified in l C. ! 22 the specification. i l 23 Q Did you then, Mr. Brummer, prepare an
) 24 amendment to the specification?
f 25 A Yes. i L
1 Brummer 38 I \m-) . 2 Q And that is the architect-engineer's 3 spe ci fi c ati o'n ? 4 A Yes. It was submitted to them. ( 5 Q It was submitted to Burns & Roe and they 6 approved the amendment; is that it? 7 A Yes. 8 Q And then you submitted this amendment 9 to Victoreen and asked them to comply with it; is that 10 it? ',
~
11 A No, that was not my responsibility. 12 Q somebody did that, though? O 13 A Yes. 14 Q Was the additional calibration work to 15 apply to all of the monitors or just some? 16 A The additional calibration work applied to 17 all the monitors; however, not all the monitors were 18 gaseous effluent isotopic calibrated. 19 Q so I understand from what you just said 20 that some received more calibration than others; is
, 21 that correct?
L 22 A That's correct. 23 Q Could you describe the two groups of Oj s 24 monitors or if there were more than two, describe the 25 groups that you established.
1 Brummer 39 O 2 A
, Yes. The particulate and iodine 3 monitors were subjected to more point source 4 information, including linearity checks using sources
( 5 purchased by Met Ed, the gaseous monitors included 6 the point sources and the linearity checks and were 7 further subjected to actual gaseous effluents of 8 known activity to determine their sensitivity. 9 The liquid monitors were subjected to 1 10 the points, more point source in linearity checks 11 and I believe what was only one monitor that was 12 subjected to an-actual liquid effluent, calibration. 13 Q which one was that? 14 A That was the unit discharge monitor, 15 WDLR 1311. , 16 Q What is that monitor? 17 A. That is the liquid discharge from TMI-2. 18 Discharge from where? Q 19 A The discharges from the reactor coolant 20 clean-up systems and miscellaneous waste clean-up 21 system. 22 Q I see, the final discharge? 23 A The final -- well, co rre ction . (_)\ 24 Q Into the river? 25 A No. It is the final discharge from that
i i Brummer 40 g-(. ! 2 unit, TMI-2, to the discharge path, which has one 3 common discharge monitor at the effluent to the 4 river. ( 5 Q Did all of the gas monitors or gas 6 channels of particular monitors receive the gas 7 effluent checks? 8 A As far as I can remember, yes.
~9 Q What did you understand you would 10 (
accomplish by carrying out this more comprehensive 11 calibration? 12 A The curves which were submitted to Met 13 Ed as part of standard Victoreen documentation i' 14 had typical curves for gaseous effluent 15 sensitivities. By actually' putting in through t 16 known gaseous effluents and isotopes of known 17 concentration, we would be able to specifically identify { 18 the sensitivity of our monitors being supplied and 19 therefore could more accurately determine the release 20 concentrations. We did this for two isotopes. 21 Q So the gas monitors, you have two separate 22 tests to get the sensitivity, two separate gas 23 effluent checks? \ (~% ( ,1 24 A That is correct. 25 t Q What was your role in reviewing Victoreen's i
1 Brummer 41 f
'L/ ,
2 activities? What did you do? 3 A 'I reviewed and participated as an observer 4 in the tests that were run, both the point, source (' 5 checks, the linearity checks on certain monitors, 6 not all monitors, I was there to be present and I 7 witnessed the gaseous effluent and the liquid 8 effluent test on the monitors. 9 Q Was this your major responsibility during 10 ( the last half of 1975 and during 19767 - 11 A This was my major effort, yes. 12 Q What percentage of your time was spent 13- at Victoreen? - 4 14 A My overall percentage of my time spent 15 at Victoreen was approximately 20 percent g with most 16 of that time being done when'the calibrations were 17 scheduled by Victoreen. ' 18 Q What did you understand this more 19 comprehensive calibration process would get you? 20 MR. KATCOFF: I object to the form of 21 the question. 22 You can answer if you understand. 23 Q If you don't understand that question, I 24 will try again. 25 I am just trying to ask you what you I
1 Brummer 42 2 understood the purpose of this more comprehensive 3 calibration'was, why you needed it and what you were 4 going to do with it that you could not do with ( 5 the standard manufacturer's calibration? 6 A I feel we covered that answer already by 7 saying that we would know specifically what the 1 8 sensitivity of our monitors would be for the gas 9 and liquid effluents we calibrated for. t 10 Q What did that permit you to.do? 11 A That permitted us just to know what the 12 sensitivities were for those specific isotopes, 13 g What was the purpose of wanting to know 14 those sensitivities, those specific sens tivities? 15 A To be able to document the typical 16 curves for our monitors, 17 Q Why was it useful to you to b-e able to 18 do that? 19 A We would then know for our monitors if 20 we had a release, we would be able to more accurately 21 go back and determine the concentration of that 22 release. 23 g By " release," you mean release of i f~)T q, 24 I radioactivity? 25 A Release of radioactivity as monitored by
1 Brummer 43 p-
\,.
2 those monitors. 3 Q 'In what ways had you found the more 4 comprehensive calibration data useful on Unit 17 5 A By being able to have more assurance of (( 6 the curves that were supplied by the vendor, i 7 Q Had there been specific occasions where 8 you had in your judgment made use of those curves 9 and found them to provide something that a standard 10 t manufacturer's curve would not? - 11 A My answer would be speculative. 12 .Well, what was Q your underst,anding? You 13 said that the Unit 1 data had proved to be useful and 14 so a decision had been made to get that same data 15 for Unit 2, and I am trying to determine what you 16 understood was the useful aspect of the data on 17 Unit 1 and what you understood led to the" decision to 18 try to get it on -- not try to but to get it on Unit 2 19 as well. 20 A I understood if you had a monitor with a 21 typical curve, the monitor is built to give 22 tolerances for which you really do not have the exact 23 number sensitivity for the specific gases, so therefore
) 24 by performing this calibration we would know for our 25 monitors what our specific numbers were and would
t:
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1 Brummer 44 A
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2 provide better documentation by'doing this calibration. 3 Q 'Did you consider this more comprehensive 4 and accurate calibration information -- I am using { 5 the word " accurate" -- is that correct, specifically 6 tied to these monitors and there were specific tests 7 such as the gas effluent checks, did you understar.d 8 that this information that you got would be of greater 9 use in determining set points, for example? 10 t A Yes. . 11 Q Was that one of the reasons that you were 12 doing it?
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13 A It was one of the outcomes.. It was not a 14 specific reason for doing it. - 15 Q What was the specific re,ason for doing it 16 as you understood it? 17 A The specific reason was such that if we 18 did have a release we would be able to identify, at 19 least for those isotopes which we had tested; the 20 concentration going out the stack and could thereby 21 determine what was released from the unit. 22 Q And an outcome, as you put it, was that 23 you also had the information for use in determining
) 24 the set points?
25 A That is correct. i l
1 Brummer 45 3 (Q 2 Q What effect would this more comprehensive 3l calibration have on set, point determination? 4 MR. KATCOFF: I object to the form of ( 5 the quescion. 6 Q You can go ahead and answer. 7 MR. KATCO.7F : You can answer if you 8 understand the question. 9 I object to the "would it have " part of e 10 the question. If you would like to rephrase 11, it, fine. If he would like to answer, O. K. 12 MR. WURTZ: () I guess he doesn't remember 13 the question anymore. 14 Q What did you understand would be the effect 15 on the set points of having this calibration data 16 that resulted from the program?
.17 A We would know the specific s en'si tivi ty s 18 for our monitors which we could apply in the set point 19 calibration = to determine the count rate that it 20 should be set to for the alarm points.
21 Q Did you in fact use this calibration data 22 in determining set points? 23 A some of the information that was attained ( 24 by the calibrations was used for set point 25 determination, yes.
l 1 Brummer 46 o/ v 2 Q You qualified that by "some of it." Can 3 you explain that? 4 A The point source calibrations in s linearities were used as reference calibrations, not 6 for determination of set points ; the gaseous 7 effluents were used for set point determination. 8 Q The gaseous effluents were actually used 9 and the point source in linearity checks were used 10 in references; is that right? ', 11 A Yes, those we would use to calibrate the 12 - monitors af ter they were initially supplied by n
\- 13 Victoreen. .
14 Q But they were not used in the fixing 15 of the set points? 16 A That is correct. The sensitivities are 17 not determined from those. - 18 Q From the point source in line rity? 19 A From the point source of linearity. 20 Q Any sensitivity information that you got 21 from this amended calibration program, you used in L 22 connection with your set points? 23 A That was incorporated in the manual, yes, t 24 to do that. 25 Q What manual was that?
1 Brummer 47 2 A The Victoreen manual. 3 Q So the work done by Victoreen in this 4 process was put in a Victoreen, manual?
- 5. A Yes.
6 Q That was going to be my next question 7 to you. 8 Where did this work get documented? 9 A That's where it got documented. 10 Q So all of it is in the Vic6,oreen manual? 11 A Yes. 12 Q It might be useful for us, we have a \- 13 copy and I would like to show you that and determine 14 if in fact I have the copy that contains the 15 information. 16 MR. WURTZ: Off the record. 17 (Discussion off the record.) . 18 BY MR. WURTZ: 19 Q I have here a Victoreen manual called 20 " Operating Instructions for Radiation Monitoring 21 System, Unit 2." This was provided to us by your L 22 co un s el . 23 Is this the Victoreen manual that contains [) \_/ - 24 the amended calibration information (handing)? 25 MR. KATCOFF: To the extent that you can
1 Brummer 48 /'~ (N) 2 tell by just looking through it. 3 A To the extent I can tell by just looking 4 through it, this is the partial copy of the manual ( 5 which contains the calibration information. 6 Q You say " partial." **
, 7 Could you describe the manual and what 8 parts it has and how this fits into the overall 9 picture?
10 A From a brief overview of what has been 11 presented, this appears to be.the operating and 12 maintenance instructions and calibration sheets of ( ~ N-the m'a n u a l ; the parts not included are the specific
=
13 14 bulletins of othe r manuf acturers ' equipment that was 15 used in the overall construction of these monitors . 16 and the Volume 2 would consist of all the drawings 17 associated with the monitors. . 18 Q But the calibration work that we have 19 been discussing is contained in this volume? 20 A Yes. 21 MR. WURTZ: I think we better mark that 22 as the next exhibit, which is B&W Exhibit 592. 23 (copy of multipage document, the first 1 f- )~ 24 page entitled " Operating Instructions For... 25 Radiation Monitoring Systems," was marked as
1 Brummer 49 O U 2 B&W Exhibit 592 for identification, as of 3 this d'a te . ) 4 MR. WURTZ: Do you want to take a brief 5 break? ({ 6 MR. KATCOFF: Fine. 7 (Recess taken.) 8 BY MR. WURTZ: 9 Q We have marked part of a Victoreen manual 10 as Exhibit 592 and this part contains the amended 11 calibration information, as I understand it; is that
, 12 correct?
13 A Yes. 14 Q Was there just one version of this 15 Victoreen manual? l . 16 A To my knowledge, yes. 17 Q Was there any documentation of this I
- 18 calibration activity, the results of this calibration i
19 activity, other than in the Victoreen manual? 20 A Not to my knowledge. 21 Q In the amendment to the Burns & Roe L 22 specification, did you set forth the kind of calibration 23 you were requiring? f j (Q f 24 A Yes. 25 Q The next step, as I understand it, is that
'l Brummer 50 0 2 after this calibration work got completed, the 3 Victoreen equipment was shipped to the site; is 4 that correct?
A ( 5 That's correct. ( 6 Q And that occurred in early 19777 7 A Approximately. 8 Q What happened then? 9 A The equipment was stored until installation. 10 Q When did installation begin? 11 A To the best of my knowledge, parts began (~ 12 installation as soon as it was received. . 13 Q Could you describe your responsibilities 14 in the installation process? 15 A My responsibilities in the installation 16 process were essentially nonexistent. There was a 17 construction effort which I reviewed or oversaw v .- 18 just from an observation standpoint. 19 Q What was your next active role in the 20 setting up of the system? 21 A It was the generation of the test procedures 22 and the surveillance procedures. i 23 Q Did you have any assistance in that task? Ok Q 24 A Yes. 25 Q Could you identify the people?
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1 1 Brummer 51 O ; '%J 2 A I worked with Doug Weaver, who was the 3 maintenance foreman for instrumentation, to get the 4 maintenance input to the procedures. ( 5 Q Anybody else? 6 A Not that I can recall that ,specifically 7 had input to the calibration. 8 Q Let's start with the test procedures. 9 Could you describe what those were and 10 what they were to accomplish? . 11 A The test procedures were designed to 3 12 check out the functional ability of the system,
%)
13 perform the initial calibration at the. site, to verify 14 the f un ction al actuation of the interlocks 15 associated with the system. Those were procedures 16 generated for the three specific types of monitors. 17 Q We have documents which I believe are 18 those test procedures which I thought we could mark 19 now for the record. 20 Mr. Brummer, I would like to show you 21 a file bearing the number 2363-12-1, which I believe 22 is a control number that Met Ed uses in connection 23 with documents produced in this litigation, and I 24 will ask you if you can identify this document 25 (handing document to the witness).
l 1 Brummer 52 y5 .
\]
2 A This document appears to be test 3 procedure 360/1B. I cannot say that the whole , 4 document is here, but some of it is, in that I can 5 identify at least the cover page is missing. (~ 6 Q What does that test procedure cover? 7 A This test procedure deals with the 8 calibration functional test of the liquid monitors 9- as described in the purpose of the procedure. 10 . Q Is this thetestproceduref,that you 11 developed in 1977 for the liquid monitors?
- 12 A Yes.
V 13 Q Does your signature appear,in various 14 places throughout that do cumen t? 15 A Yes. 16 - Q What does your signature in there j 17 indicate? - 18 A Approval of the steps as outlined in the t 19 procedure of the data taken and the -- where i 20 exceptions and deficiencies are noted, the identified 21 cause and resolution of. 22 Q Could you describe what this document 23 represents as far as the liquid monitors are l (_j 24 concerned? i 25 MR. KATCOFF: I object to the form of the {
1 Brummer , 53 g question. 3 Y u can answer if you understand it. 4 Q What I am asking is, is this the initial ([ 5 site calibration and the initial testing of the 6 functioning of the monitors that occurred during the 7 start-up period? 8 A Yes. This is the initial calibration 9 setup of the monitors, liquid monitors, at TMI-2. v. 10 MR. WURTZ: I will ask that this be marked 11 as B&W Exhibit 593. 12 (Multipage document, the first page 13 bearing No. 2363-12-1, the second page entitled 14 "Three Mile Island Unit II, TWG, Radiation 15 Monitoring System Test (Liquid) ," was marked 16 as B&W Exhibit 593 for identification, as of
~
17 this date.) l 18 MR. WURTZ: Off the record. 19 (Discussion off the record.) 20 MR. WURTZ: I found a page bearing the [ 21 microfilm number 1368-1169. 22 Q Is this in fact the cover page to the l 23 exhibit (handing)? 24 A Yes, this is the cover page. l 25 MR. WURTZ: So why don't we place that i
1 Brummer 54 V 2 right below the " Litigation Folder" page and 3 we have the document in correct order. 4 Q When you did the start-up calibration, 5 did you use the sensitivity information that came out ({ 6 of the expanded calibration program? 7 A No. The calibration was done using the 8 point source data which got back to the original 9 effluent sensitivity as it performed under the 10 expanded calibrations on the Vi c t o r e e n .', 11' Q Maybe it would help if you described this 12 initial calibration, how it was carried out. 13 A O. K. . 14 What we did, first of all, we went through 15 the calibration to verify that the proper voltages 16 were found internal to the modules to know that the 17 electronics was properly set up and performed the 18 electronic calibration. 19 At that point, we took the point source 20 data obtained from the Victoreen calibration, decayed 21 the source down to the existing date, put the source 22 on the detector and calibrated it to the expected 23 number, and we used the tolerances identified in the O () 24 procedure to either adjust it or accept it as found. 25 Q In addition to calibration, you said the
1 Brummer 55 n sm/. 2 other part of the start-up testing was to check 3 the functioning. 4 What did that involve? ( 5 A certain monitors have certain electrical 6 ' interlocks which would stop pumps, open or close 7 applicable valves, and those interlocks were checked 8 by the initiating signal of the radiation monitor 9 to insure proper actuation. t 10 Q Was there any other part of the start-up 11 testing or part to the start-up testing?
- 12 A That was pretty comprehensive.
13 MR. WURTZ: I would like to have marked 14 as B&W Exhibit 594 a document called " Radiation 15 Monitoring System Test-Atmospheric , Monitors," 16 also having the number TP 360/1A. 17 (Copy of multipage document entitled 18
" Radiation Monitoring System Test-Atmospheric 19 Monitors," bearing number TP 360/1A, was marked 20 as B&W Exhibit 594 for identification, as of 21 this date.)
22 Q Mr. Brummer, could you identify Exhibit 23 594 (handing)? I O(_/ 24 A This is the TWG approved procedure for / 25 functional test of the atmospheric monitors TP 360/1A.
1 Brummer 56 m (V i 2 MR. KATCOFF: Off the record.
~
3 '(Discussion off the record.) 4 BY MR. WURTZ: ( -5 Q You referred to the TWG approval. That
- 6. is an acronym standing for the test working group; 7 is that correct?
8 A Yes. 9 Q Could you describe that group, who was in 10 it and what its purpose was? . 11 A The purpose of this group was to review 12 and approve all start-up and test procedures that I (') ' 13 were done on TMI. It had a GPU representative, a 14
. Met Ed representative, Nuclear Steam Supply System 15 representative and an architect-engineer ,
16 representative. l 17 Q Is Exhibit 594 the procedure,~then, that 18 was used in the start-up testing on the 10 atmospheric monitors? 20 A Yes. 21 Q In this -- 22 A It is the procedure with no results in it. 23 Q All right. That was going to be my next
-s k_) 24 question.
25 I notice that various pages are not signed
1 Brummer 57 O O 2 by you in this one. Is there a copy of this where 3 you did sign'and approve the various steps in the 4 testing program? ( 5 A Yes. I did do this procedure and I 6 signed it off where applicabic. 7 MR. WURTZ: Just so we don't forget 8 about this, Joel, let me give you two requests 9 right now ; one is the amendment to the 10 specification regarding the calibration and 11 the second is a signed-off copy of Exhibit 594.
~
_ 12 MR. WURTZ: I would like to mark as B&W 13 Exhibit 595 test procedure 360/1C, which is 14 the radiation monitoring system test-area 15 monitors. 16 (Copy of multipage document entitled 17 " Radiation Monitoring System Test-Area 18 Monitors" was marked as B&W Exhibit 595 for 19 identification, as of this date.) 20 Q Mr. Brummer, is Exhibit 595 a signed-off 21 copy of the test procedure used in the start-up testing 22 on the area monitors (handing)? 23 A Yes, it is a signed-off copy, TP 360/1C j 24 l used for area monitors. 25 g Is this the procedure that you prepared
1 Brummer 58 v 2 and carried out in connection with the starc-up 3 testing on the area monitors? 4 A Mr. Pels prepared part of this procedure. (' 5 I aided in that and I ran the procedure. 6 You will note.that his name is as the 7 cognizant engineer on the front. 8 Q And you were the cognizant engineer on 9 the start-up procedures for atmospheric monitors 10 and liqui,d monitors? . 11 A That is correct. 12 Q The cognizant engineer has the overall As 13 responsibility for writing the procedure; is that. 14 - correct? 15 A Yes. 4 16 Q But you aided Mr. Fels in writing one for 17 the area monitors?
- 18 A Yes.
19 Q As I understand it, the start-up testing 20 continued throughout 1977 and was completed in early 21 1978, approximately; is that correct? L 22 A That's correct. 23 Q During that same time period, you were also b') w./ 24 preparing surveillance procedures. 25 Could you describe your activities in that
1 Brummer 59 /'N N- . 2 area? 3 A The technical specifications for TMI-2 4 required that at given frequencies certain types of 5 tests be performed on specific radiation monitors. (( 6 I prepared procedures to see that those criteria 7 could be met; in addition we prepared procedures 8 that would cover the calibrations of the monitors that 9 were not specified in the tech spec also. 10 Q Who assisted you in develobing these 11 procedures? 12 A Mr. Weaver assisted me in preparing these (> \~ 13 procedures from a review standpoint for maintenance. 14 Q How did you determine whethe a particular 15 monitor was within the tech spec surveillance program 16 or outside that program? 17 A The technical specification identified 18 typically by associated equipment which monitors 19 would be required. 20 MR. WURTZ: I would like to mark as 21 B&W 596 a Unit 2 surveillance procedure L 22- No. 2302-R3, Revision 1. 23 (Copy of multipage document entitled () I 24 " Unit #2 Surveillance Procedure 2302-R3, 25 Radiation Monitoring System" was marked as
1 Brummer 60 O (f 2 B&W Exhibit 596 for identification, as of this 3 date.) 4 Q Mr. Brummer, can you identify Exhibit 5 296 (handing)? ({ 6 A This is a copy of Unit 2 surveillance 7 procedure 2302-R3, radiation monitoring system 8 calibrations. 9 Q Were you involved in the preparation of 10 this procedure? ( 11 A Yes. 12 Q How does this procedure fit into the O) L- 13 surveillance program? 14 A This procedure identifies the tech spec 15 paragraphs which require specific monicors to be 16 calibrated and denotes the app '.i c a b le surveillance 17 frequency and modes in which it must be done. 18 Q This is one of the surveillance procedures 19 that you developed during the course of 1977? 20 A Yes. 21 Q What part of the surveillance is carried 22 out in this procedure, Exhibit 596? 23 A Excuse me? Could you repeat the question? 24 A Yes. l %- 25 My question is, what type of surveillance
'l Brummer 61 0 2 is carried out pursuant to Exhibit 5967 3 A 'This calibration of the ratemeters and 4 detectors.
(' 5 Q Could you explain generally how that 6 calibration is carried out? 7 A O .' K. 8 The steps that are followed are -- you 9 start out with a background determination to determine 10 what the. applicable background is on tbe monitor. 11 You then obtain the sources required by the procedure, 12 align the sources on the detector in accordance with O 13 the procedure, you determine by . test equipment 14 using a scaler the count rate that is being emitted 15 by the detector, you take the readings of the 16 ratemeter and the recorder and you compare that to ( 17 an expected count rate as obtained by decaying the 18 applicable source from the original data to the date , 19 and determining if it is within the acceptance criteria i
- 20 of the procedure. It it is, the procedure is i-21 essentially completed except.for a check course check 22 an d a set point check. If not , the procedure tells 23 you to go to the various appendix to set up the 24 final calibration and repeat the source check of the 25 instrument. And then return it to service.
l
sk 1 1 Brummer 62 0 2 .Q Does this procedure apply only to tech 3 spec monitors? 4 A Yes. ( 5 Q So calibration of non-tech spec monitors is 6~ done under some other Unit 2 procedure, is that correct? 7 A That is correct. 8 Q How often is the calibration under this 9 procedure done? Is it 18 months? 10 A The specified frequency ist18 months. 11 Q And that's from the tech specs? 12 A Yes, that's in accordance with the 13 definitions of the tech specs for the required R 14 surveillance frequency. 15 Q How did that 18-month frequency get , 16 determined? l 17 MR. KATCOFF: If you know. . l
- 18 A It was a definition in the technical I _
19 specification. Other than that, I have no knowledge. 20 Q Did you consider that to be an adequate l 21 frequency for this calibration? 22 A Yes, I considered that that would be j l applicable. 23 24 l Q And that it would be adequate? i
,i 25 A Yes. It was in line with the technical f i l
1
s-o a-( . 2 i Brummer 63
\
2 ' specifications as outlined. It would be, therefore -- if we elected to do it on a refueling basis, which is 3 I
\ 4 1 the way we did it more frequently than 18 months, that
( 5 could be allowed, but the tech spec identifies a given
\1 6 tolerance for the frequency.
\
j Y' Q Did you in fact carry out this tech spec l 8 calibration procedure on an 18-month cycle? v 9 MR. KATCOFF: When you say "you," you mean I 10 Met Ed? , s 11 , MR. WURTZ: Met Ed, yes.
, 12 's A Up to the point of the accident, we had not O 13
-reached that applicable point for all monitors. We had s .
. - 14 bagun a more stringent or less than 18-month frequency, ? '
' 15 but we were just getting into that, e
16 Q I see. 17 ,
, What frequency had you decided to use for n )'
, 19 f the tech spec monitors?
, 19 A Where possible, okay, we were trying to t
a s
- 20' ' N impr'ove on the 18 months by going to something in the
, t >) 't
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L*o ,21 , range of every year. l, ( O
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l' l w., 32 ) Q Were there any particular monitors singled
i
/. l 23 ,
out for the 12-month calibration? rN 't' 3 is ). , p, ;24 l A No. The one thing that we should add at thisi l , 25 point is that this is not the only procedure for i .\ y
'. i' 4
- - - - . - . _ . _, + -- . , , - - . - - , - _ _ - . . - . , _ .
1 Brummer 64 D (v calibration of tech spec monitors in that there are 2 3 procedures that have frequencies that were annual 4 frequencies which were performed on the specified l[ 5 12-month basis. 6 Q What are the other procedures for the 7 surveillance of tech spec monitors? 8 A I would have to review a procedure index to 9 identify those. 10 Q Where is there a procedure'.index, what kind 11 of index do you have for that? w 12 A There is a computerized index which is
}
13 updated periodically and I am not sure.of the frequency 14 which identifies the current revision of the procedure, 15 the procedure number and title. 16 Q What kinds of surveillance got done in the 17 other tech specs surveillance procedures? 18 A The other surveillance procedures were 19 associated with the environmental tech specs which were 20 the release point monitors which identifed the gaseous 21 and particulate activities and iodine activities 22 that were released from the plant. Those were specified i 23 in the environmental tech spec. 24 Q At the time that you prepared Exhibit 596, i 25 did you have meetings or discussions with various
1 Brummer 65 O 2 people in that connection? 3 A Yes, there were meetings associated or 4 discussions with people who reviewed the procedures to k 5 make sure that it was correct as it stood. 6 As.you will note, the procedure in front of 7 us -- this procedure was prepared in '77, but the 8 original draft was late '76. 9 Q Did you prepare that one also? 10 A Yes. . 11 Q Then this procedure was approved by the 12 PORCs Mr. Seelinger was chairman at the time. 13 Were you a member of the PORC also at that i 14 time? 15 A Yes. 16 Q Was this procedure discussed at a PORC 17 meeting or PORC meetings? - i 18 A Yes. 19 A when this surveillance is actually done, 20 I understand you generate filled out data sheets like 21 the one on page 27 of this Exhibit 596, is that correct? 22 A That is correct. 23 i Q Is that the entire documentation of the (3
\_) 24 performance of this calibration procedure for the tech l
25 spec monitors?
1 Brummer 66 (-m. 'N 2 A This is the entire documentation of the 3 specific data that was generated from performance of 4 this procedure. What happens to those data sheets after ( 5 Q 6 they are filled out? , 7 A The data sheets after it is filled out is 8 signed by the person who performed the procedure and 9 dated. It is then sent to a supervisory person, 10 usually the foreman, who will review the data to make 11 sure it is within the acceptance criteria and sign it as 12 approved. \~' 13 After that, it is sent to a group which 14 coordinates and logs the completion of the procedure at 15 the specified frequency and the date done,-and then it 16 is forwarded to the control room for storage in the 17 fireproof file cabinet. . 18 MR. WURTZ: I would like to mark as 19 Exhibit 597 Unit 2 Surveillance Procedure 2303-M9, 20 Revision 4, entitled " Containment Monitor - RMS 21 Channel Functional Test." (_ (Unit 2 Surveillance Procedure 2303-M9, i 22 l l 23 Revision.4, entitled " Containment Monitor - RMS ( O) 24 Channel Functional Test" marked B&W Exhibit 597 25 for identification, as of this date.)
1 Brummer 67 2 Q Mr. Brummer, were you involved in the 3 preparation of Exhibit 5977 4 A Yes. ( 5 Q what was your involvement? 6 A Generating the original procedure in draft 7 form. 8 Q What is the purpose of this procedure? 9 A The purpose of this procedure is to perform 10 a functional test of the interlocks ass.ociated with the 11 containment purge system, containment meaning reactor
- 12 building.
13 There are pages here on th.is document, 14 Exhibit 597, which do not appear to be part of this 15 procedure, however. 16 Q .Could you identify those pages? 17 A Those pages following page 12 do not appear 18 to be part of this procedure. 19 MR. WURTZ: Why don't we remove those 20 pages then so that Exhibit 597 stops at page 12. ! *1 Q You said that this is a functional test of ! k 22 the interlocks. What do you mean by that? ! I ! 23 A The procedure involved here deals with l 24 ! opening the signal from the detector, injecting a signal 25 gene rator which is a test device, running the signal
T 1 Brummer 68 2 generat r up to the point where the alert alarm and high alarm are actuated, as indicated on the module 3 4 by the-alarm, and verifying that the applicable ( 5 automatic action has occurred for t'he two monitors on that containment purge systems A and B. 6 Q Is this procedure a tech spec surveillance 7 g procedure? g A Yes. 10 Q The frequency of this is monthly. I 11 ' A That is correct. 12- Q If you would look at page 1, paragraph 1.1 O ' 13 and the subparagraph under that, 4.4.6.1, it states, g4 "The leakage detection system shall be demonstrated 15 ope rable by (a) a containment atmosphere particulate 16 monitoring system-performance channel fu etional test 17 at least monthly." , gg A Yes. 19 . Q How is that test documented? 20 A since the containment leakage monitor 21 HP-R-227 does not have any associated interlocks, the 22 pr cedure described, to go through the procedure 23 injecting the simulated input signal and verifying the l h) s og i l. alarm set points, the audible annunciator identified on data sheet 1, page 5. 25 l
1 Brummer 69 2 You will note it says "HP-R-227, P, I and s 3 G," and the specific columns for the data to be 4 recorded. ( 5 Q And this procedure required the preparation 6 of a document like data sheet No. 1 every month, is 4 7 that correct?
;. 8 A That's correct.
1 t 9 Q Let's just take the 227 particulate channel 10 and go across the chart. ', 11 Will you explain what each of the columns 3 12- indicates?
.) 13 A
~
The first column "Ratemete.r Setting"
~
4 14 refers to step 6.5. 15 Q And that involves what? 16 A That involves going to the set point in 17 accordance with procedure 2105-1.12. - 18 Q So basically you record the set point there 19 for that step, is that it? 20 A At that -- yes. 21 Q Is that the alarm set point or the alert
..k 22 set point?
l 23 A This would be the high alarm, because step . [/) N._ 24 6.6 verifies that both the alert and the high alarm 25 1'ghts are on and the RMTS trouble annunciator and
Il 9 1 Brummer 70 ; ' ~ 2 audible alarm is on. 3 Q That's the next three columns on the data 4 sheet then? l A ( 5 Yes. 6 Q So for the first column, you write the , 7 number of the set point in the box, is that correct? i 8 A Yes, because that's the input signal you put 9 in. 10 Q And you put that signal int,o the monitor? 3 11 A Yes. 12 Q A signal equal to that many counts per 13 minute? 14 A Yes. 15 Q Then you check to see that the alert light, i 16 the alarm light and the annunciator are all functioning, i' 17 is that correct? . 18 A That is correct. i ) 19 Q .Is the alert light part of the monitor
; 20 itself?
J 21 A Yes, it is part of the ratemeter. 22 Q Part of the ratemeter. 23 , And that is located back on panel 12 in . t l ([) 24 the control room? i 25 A Yes.
I 1 Brummer .71 gs (./ 2 Q And in that same ratemeter you have that 3 high alarm also? 4 A Yes. l 5 Q What color is the alert light?
~
6 A Amber. 7 Q And the alarm light? 8 A The alarm light or high alarm as it is 9 referred to is red. 10 Q Then the next column referb,to the 11 annunciator and audible. What are those? g- 12 A The radiation nonitoring system has one
%-)
13 - Ennunciator, which is RMS trouble, and.it is located on 14 panel 12 and it has an audible alarm associated with 15 it, such that when an input comes in, the alarm light 16 will light up and flash and the audible alarm will sound. 17 Q What is the next column af ter " Annunciator & 18 Audible"? l 19 A The next column is " Background Reading" { 20 associated with step 6.9. At this point you have i 21 reconnected the detector to the ratemeter and you are ; l 22 now reading the background radiation level. , 23 Q What is the purpose of that step? , I 24 A To record the background reading of that ! 25 detector. l
11 1 Brummer 72 (~h (_) - 2 Q What is that information used for? 3 A That information is used in accounting for 4 the check source reading which is taken in step 6.10. ( 5 Q The column that says "Significant Increase," 6 you mean? 7 A Yes. 8 Q Could you describe what that step involves? 9 A on the front'of the ratemeter is associated 10 a pushbutton which is labeled " Check Sb,urce." When you 11 depress that button, you energize a solenoid which 12 pulls a check source in front of a window at the ['T *
\~) detector.
13 This will then see an increase in count rate. 14 due to the source being there and when the button is I t 15 released, the check source goes back behind the window 16 and should return to the background reading. 17 Q Was this -- , 18 A Well -- l i l 19 Q Excuse me. , 1 20 A The background reading of 6.9 is used to i 21 determine what a significant increase is due to, some 22 ; radiation monitors being located in higher areas. 23 Q So you need to know what the background is l ( s) N- 24 so you can see whether the check source is having any ! I i 25 effect and how much effect it is having, is that it? i
1 Brummer 73
/"%
2 A Yes, that's true. 3 Q The column is labeled "Significant 4 Increase" ( 5 Under what circumstances do you write 6 comething in there? Do you always make an entry there 7 in that box? 8 A You note if a significant increase occurred a 9 in accordance with the note of step 6.10. 10 Q If the monitor is working borrectly, there 11 would be a significant increase, is that correct?
~ - 12 A That is not indicative of the monitor 13 working correctly. .
14 Q It means the ratemeter is working correctly? 15 Well, let me ask you what it,means. 16 A Okay.
~
17 If the monitor is located in~the high 18 radiation area, the check source might not be strong 19 enough to induce a significant increase due to high l -20 background; therefore, that doesn't mean the system i 21 doesn't work or the channel doesn't work. So, therefore,' i 22 it is not indicative of that. l 23 Q What is the reason for doing this particular 24 -test? l 25 A The reason for doing it is to see if -- to i l
1 Brummer 74 C') v 2 assure yourself of proper operation in that the detector 3 is responding to an increaseed count rate due to 4 exposure to a source. ( 5 Q You are saying that in some cases this test 6 doesn't work because the background is high? 7 A That could be the case, yes. 8 Q Was this the case with 227, do you know? 9 MR. KATCOFF: At what time? 10 A To my knowledge -- 11 MR. WURTZ: At any time before.the accident. 12 A O To my knowledge before the accident, no. t Q. 13 Q Then the next column says " Record. Trace 14 Marked." What does that refer to? 15 A That refers to the recorder t, race. Each 16 monitor outputs to the recorder. 17 Q What kind of mark is supposed to be made 18 according to this data sheet? 19 A Step 6.1.2 says " Mark the individual channel 20 recorder traces to indicate where the abnormal levels
. 21 were imposed during this test." So that step is to 22 denote that this is the area of that chart reading where ,
l 23 this procedure was performed. ! l
~(_(~)'\ 24 Q What is the purpose of that information?
25 A To identify the increases that -- in count
14 1 Brummer 75 (*% 2 rate which weald occur on the recorder chart due to 3 this functional test. 4 ~Q So you know'it is not from something in the (, 5 building? 6 A That's correct. It is to identify that this 7 test is being performed at this time. To truly evaluate g what was going on at that time, you would come back to g this procedure. 10 Q Did this testing representhd by data sheet 1 11 get done on a monthly basis? 12 A To the best of my knowledge, it was
~s 13 performed on a monthly basis in accordance with the 14 technical specification requirements.
15 Q Who carried out this testing? 16 A The instrumentation group carried out the 17 testing for these monitors, for this procedure. 18 MR. WURTZ: Just to keep my list complete, 19 we don't have the data sheets representing T 20 implementation of this procedure. I will define 21 a time period for those. 23 MR. KATCOFF: I would appreciate it if you 23 would send a letter after the deposition listing , ( 24 I all the things you want us to follow up on. I 25 MR. WURTZ: Okay. l
t I 1
! .' l 4
i j d q'- 14-A 1 Brummer 75-A r ! S 2 Off the record. ! 1 l 3 (Discussion off the record) { t ! l l 4 . (Lunch recess taken at 12:45 p.m.) i
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5 1 76 O AFTE RN OO N S E S S I ON 2 3 1:57 p.m. 4 J OHN A. B RUMME R resumed 5 and testified further as follows: (( 6 MR. WURTZ: I would like to mark as the 7 next exhibit, No. 598, one part of TMI tech spec. 8 This is the definitions section. 9 (Definitions section of TMI tech spec 10 marked B&W Exhibit 598 for identification, as of 11 this date.)~ 12 EXAMINATION (continued) I~D .
~
13 BY MR. WURTZ: 14 Q Mr. Brummer, I would like you to look at 15 pages 1-2 and 1-3, paragraphs describing testing on J
, 16 the radiation monitoring system.
17 There is a paragraph there en, titled " Channel 18 Calibration."
~
19 Is Exhibit 596, the surveillance procedure 20 we looked at this morning, the procedure that you 21 Wrote to implement paragraph 1.97 22 A That's correct. 23 Q Then there is a paragraph 1.10 called the I) (~/ o
~4 j
" Channel check." It reads "A channel check shall be 25 the qualitative assessment of channel behavior during
,, ,__ . . ~ . . . _ . _ . _ . _ _. .. _ . . . - - . . __ _ - .
16 1 Brummer 77 m
)
2 operation by observation." 3 Did you prepare a procedure to implement 4 the channel check requirement? ( 5 A No. Not a separate procedure tb do that. 6 Q Who carried out that step? Was it an 7 operator or a technician? 1 g A Who performed that step? 1 9 Q Yes. 10 A The operations department.L , 11 Q So that it is the control room operators that 19
~ did that?
13 A Yes. g4 Q Was there any document telling them what to 15 do? 16 A Yes. The shift and daily surveillance procedure. I 17 . 18 Q And that had various boxes gi ing them 19 instructions? 20 A As I recall, yes. 21 Q And the title of it was what? l t~ I 22 A Shift and daily surveillance procedure. 23 That might not be the exact title. ( ) 24 l Q Yes. That is a specific procedure that 25 contained the data sheets as part of the procedure? i
7 1 Brummer 78 2 A Yes. 3 Q 'How did the -- 4 A I might clarify that. That was on those ( 5 tech specs which required the channel check to be done 6 on a shiftly or a daily basis. 7 Q As defined in the tech spec itself? 8 A Yes. 9 Q What was done to make the qualitative 10 assessment referred to in paragraph 1. i,0 of the 11 definitions section of the tech specs? 12 A Typically, that was the actuation of the O 13 check source. , 14 Q Is that the same procedure or step that is 15 required as part of that monthly functional testing on s 16 the 227 monitor? 17 A I don't remember the exact words of the 18 procedure to say that. 19 Q In general terms, what would be done? 20 A In general terms, the check source would be
, 21 pushed, the pushbutton that is, and you would look for k an indication that the detector is responding to the 1
22 j 23 radiation field now that the source is within the , 24 window. 25 g was there a requirement that a mark be put ,
18 1 Brummer 79 O 2 on the strip chart to indicate that the check source 3 button had been pushed? 4 A I don't remember. ( 5 Q Would a data sheet be filled out in 6 connection with doing this channel check? 7 A Yes. 8 MR. WURTZ: Off the record. 9 (Discussion off the record) 10 Q Mr. Brummer, I would like k,ou to look at 11 what has previously been marked as Exhibit 308, B&W 12 Exhibit 308. 13 can you identify the data sheets that are 14 part of B&W Exhibit 3087 15 A No. 16 Q By that, I mean is this the form used by 17 the operators to perform the channel check pursuant to 18 paragraph 1.10 of the tech specs? 19 MR. KATCOFF: Apart from any whiting on 20 the document. 21 MR. WURTZ: Yes. I am just asking whether 22 this is the form that was used to perform the 23 procedure. 24 A I cannot state affirmatively, because it 25 doesn't have the procedure number on the top, okay. If - I
i 1 Brummer 80 0 2 you go by the note that is on the front where it says 3 SP 2301 S1,'the handwritten note across the front -- 4 Q I see, yes. (' 5 A -- I believe that is the procedure, the 6 correct data sheet. 7 Q Yes. That is the surveillance procedure 8 for the shift and daily surveillance, is that it? 9 A I believe so. 10 Q Did you prepare that procedure? 11 A No. 12 Q Then paragraph 1.11 of the tech spec refers (~h
\_) 13 to a channel functional test.
14 Is Exhibit.597 the procedure prepared to 15 implement that part of the tech specs? 16 A For that applicable tech spec which is 17 covered under that procedure, Exhibit 597, that is true. 18 MR. WURTZ: Please mark as B&W Exhibit 599 19 a Unit 2 operating procedure 2105-1.12, I L 20 " Radiation Monitoring System Setpoints, Revision . 21 6." 22 (Unit 2 operating procedure 2105-1.12, 23 " Radiation Monitoring System Setpoints, Revision , i 24 6," marked B &W Exhibit 599 for identification, as f l 25 of this date.) f l-
20 1 Brummer 81 g w\ s
'V .
2 Q Mr. Brummer, could you identify Exhibit 5997 3 A This is TMI-2 operating procedure 2105-1.12, 4 revision 6, Radiation Monitoring System Setpoints. ( 5 Q Did you have any role in the preparation of 6 this document? 7 A Yes, I was the main person that developed it. 8 Q Could you describe the process by which you g developed the set points in this document? 10 A The process by which theset were developed 11 is dependent upon which monitor it was and that was 12 based on the location. The TMI-2 tech specs was used O)
\',
13 as a basis; the TMI-2 FSAR was used as a basis; the , 14 TMI-2 environmental tech specs was used as a basis also. 15- Q Did anyone work with you in preparing these? 16 A res. 17 Q Will you identify the people,who did? 18 A The people who helped me with the original 19 outline and definition of these set points is Dick 20 Dubiel, Tom Mallevay, 21 Q Dubiel I guess is D-u-b-i-e-l? l l A Yes. l 22 l l 23 Q How do you spell the second one? , 5 (es)
,m/
24 A M-a-1-1-e-v-a-y. i 1 25 Q Mallevay? , I l
21 1 Brummer 82 O 2 A Mallevay. 3 Q Anybody else? 4 A And I had Porter Gertz Consultants as a 5 reviewer of the document. (( ' 6 Q Could you spell that? 7 A P-o-r-t-e-r G-e-r-t-z. 8 Q That is a consulting outfit? D A That is a consulting outfit. 10 Q Where are they located? ( 11 A Philadelphia. 12 Q What was their role in this? O
\~ 13 A They reviewed the basis and the calculations 14 that I made for the set points. '
15 Q From what standpoint did they review it? 16 A Health ph sics's'tandpoint. And off site -- 17 off-site dose assessment. . I 18 Q What was Mr.Dubiel's role in the preparation 19 of this document? 20 A Mr. Dubiel was the head of health physics 21 at that time. He and Mr. Mallevay helped me develop -- ( - helped me develop the basis to go to develop the set 22 , \ , ! 23 points. I came up with a lot of the set points and ( 24 then we sat down and we served like a committee and 95 reviewed them, and then we made modifications and we had l
! 1 Brummer 83 0 2 Porter Gertz review the final document.
Q Was it then presented to the PORC7 3 4 A Yes. Q That was after the Porter Gertz review? ( 5 6 A Yes. 7 Q When it was presented to the PORC, what was g provided to them? 9 A This document in the draft form. 10 Q Was there any supplementart, material 11 provided together with the document? 12 A No. v 13 Q It was just the procedure itself? 14 A Right. 15 Q In the course of developing the set points !. 16 contained in this procedure, what kinds of documents t 17 did you create? . 18 A This was the main document in developing the 19 set points. There was no other document which would , 20 identify the basis or anything. It was all self-l l l 91 contained. [ i 22 Q Any explanation for the set points would be 1 23 put right in the document, is that correct? i (~\I l A Yes. Q 21 ,
! 3 l 25 Q Did you have notebooks or working papers or 4
1 Brummer 84 O 2 calculations as you went along? 3 A Yes. As I made the draft, I had 4 handwritten, you know, drafts. ( 5 Q when this document was presented to- the 6 PORC for review, was it gone over monitor by monitor? 7 A I don't specifically remember. 8 Q Was it discussed at more than one PORC g meeting? 10 A I don't specifically rememb,er that either. 11 Q Do you have any recollection of the process 12 by which the PORC reviewed and approved this document? O 13 A I know that the procedure was discussed. 'I 14 know that a number of them were discussed individually, 15 but as to whether, you know, what each PORC member did 16 prior to attending the PORC meeting, I cannot describe l 17 that action. . 18 Q I am looking at the front page of Exhibit 599. 19 It appears that revision 0 of this procedure was 20 prepared in September 1976. That is just looking at 21 page 1 there. Is that correct. I 23 A That's correct. That's what it says. ) 23 Q It was revised from time to time up to 24 November of 1978, which is the date of Exhibit 599. l l Were you involved in the revisions that 25 l
1 Brummer 85 C\ (_/ 2 occurred over that time period? 3 A Yes, to the best of my knowledge, I was 4 involved with all of them. ( 5 Q could you look at page 65, which is the 6 set point calculation for the radiation monitor No. 720. 7 A Yes'. 8 Q There is a number there for the sensitivity 9 of the monitor. Where is that number from? 10 A It would be out of the Victoreen manual. 11 Q Would that be the document we marked earlier lo today? ( ' 13 A Yes. 14 Q As Exhibit 592? 15 A Yes. 16 Q Just to use this as an example, could you 17 indicate in there where that number is and how this set 18 point got developed based on that number?
- 19 MR. KATCOFF
- He didn't testify that that 20 set point was based on that number.
21 MR. WURTZ: Well, if it wasn't, he can say 22 so. I mean, it's here on the paper. I 23 MR. KATCOFF: All right. I just want to l 6 () 24
! make sure that the witness is testifying and not I
I 25 you. w- .m- -m-r -m , ----,e .
l 1 l 5 1 Brummer 86 m h 2 BY MR. WURTZ: 3 Q Can you find that sensitivity number in 4 Exhibit 5927 (, 5 What 1 would like you to do is have you work 6 through this set point for the 720 monitor so we can 7 reach an understanding of how this process occurred. 8 A From this draft, I cannot specifically 9 identify the isotope for which the sensitivity is given. j 10 But typically what was done, you would 'yo to the 11 calibration curves submitted by the vendor, look up the 12 gamma energy level of the isotope of concern and find n
\- the sensitivity.
13 . 14 Q So in the case of the 720, what isotope 15 was involved? 16 A I don',t remember right now. I would have... 17 Q Where is that information recorded? 18 A I don't know. 19 Q Is there a curve in the manual there for 20 the 720 monitor? 21 A Yes. 22 Q How many isotopes appear on the curve? 23 n There are four specific isotopes on the I ( 24 curve. f 1 25 Q Does any one of those isotopes correspond I
1 Brummer 87 2 to the sensitivity number that we have in the set point 3 procedure? 4 MR. WURTZ: Off the record. (i 5 (Discussion off the record) 6 A It appears that the re is a factor of ten off. 7 If it were a line for cesium 137 or cobalt, but I cannot 8 specifically identify it by this revision of this g procedure, the isotope. 10 Q Is there anyplace that the'pensitivity 11 number could come from other than from the curves that 12 you are looking at? 13 A Not to my knowledge. 14 Q And you in fact did the set p'oint 15 determination for the 720 radiation monitor, isn't that 16 correct? i 17 A Yes. - 18 Q Let me give you a chance to just look at the 19 manual there. Take whatever time you need. 20 (P aus e ) 21 A Okay. There exists to be an inconsistency 22 in the manual which I would have to go back and review , , 23 in that the curves that are submitted in the back here 24 for the failed fuel monitor are for a sampler model 25 840-4P, and the data sheet says we have a sampler i
7 1 Brummer 88
/D V
2 model 841-4P, so therefore I would have to go back. One 3 would have t'o look at the appropriate data sheets, and 4 they don't appear to be here, to identify that 5 sensitivity. 6 Q Maybe you could go slowly, step by step here, 7 so I can follow what it is you are saying..As you do 8 that, and go slowly at it -- 9 A Yes. 10 Q -- refer to page numbers wEere you are 11 looking at in the Victoreen manual. 12 A Okay. We are going to work with two pages. 13 Q Okay. . 14 A This is the calibration data sheet out of 15 the calibration section, page 13 for MUR 720. 16 Q Okay. 17 A It denotes that you have a sampler model 18 number 841-4P. 19 Q What does that mean,. sampler number? 20 A That's the model number. 21 Q Model of what? 22 A The Victoreen model number of the failed 23 fuel sampler. That's the lead chamber and sample : l b' (_sl chamber that's associated with the monitor. 24 t 25 .Q So this is the monitor itself, that's its
i f 1 Brummer 89 j O 2 serial number? 3 A 'That's its model type. 4 Q Okay. 5 A okay? In that sits a detector.
- 6 Q Okay.
7 A Which counts the radiation. , 8 Q Yes. 9 A Which is an 843-30. 10 Q That's the detector itselfI. 11 A That's the detector model number. 12 Now, the curves which are submitted for 13 the failed fuel system on page 227, 228, 229, also 226, , 14 are for a failed fuel sampler 840-4P.
~
15 Q When you say " failed fuel curves," what 16 do you mean? 17 A MUR 720 is named a failed fue1 monitor. 18 Q Okay. 19 A So these curves were put in this package, 20 okay, for that monitor. However, there is an 21 inconsistency in the sampler number. [ 22 Q These' curves show the way the 720 reacts l e 23 to various -- l s i i 24 l A Energy levels of isotopes. I 25 Q Okay. You are saying the number on the
~r ,
.?-
s 1 Brummer 90 l g- curve is a different model type for the sampler? 3, A That's correct. 4 ,
, Q So what do you conclude from that then?
?
- j ,5 A That would be speculative, my conclusion, e , N ..
- :
4 Q No, it would be a logical process here. I A'l . 7 . am-{ust.caying, looking at this evidence, by a process
,-1 8
f , l o g'i c , do you have a hypothesis as to what's going 9 on here? Is there a page missing from the book? l s
$10
,' A We do not have the proper d,u rve s for the
.' 11 , sagpler which was supplied and is this sampler. These lo~ -
calibration curves say we have an 841. This is actual
.: /~N -l "-,
lt ] , 13
~
data taken off the sampler when it was calibrated s , andIhere the curves are for an 840-4P. I
, '14 So, therefore,
.a >
15 i the curves are inappropriate for the chamber. 4 16 i Q So that curve on pages 226 to 229 cannot
. e 4 ]~. provide.the sensitivity for use in the set point
,e 1,7 s,* .I -
g 18 . calculation, is that right?
' A 1r6 It would have to be verified by Victoreen
, e ', % /, \ ...
y 4 [ ', 20. j j as'to,which curve i ! to obtain the curreet curve-
, 1- , ,
4 { _,' x .s21 ' Ol Are there some pages missing from this
/
,ci qTf victoreen document in the back, did you notice?
r l S3
! jA I cannot tell.
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_.Th e re don't appear -- to the extent to which 25 * /A .
. , /
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. . . < . . - . ..w - - - - - . , - . -. - . - .. - . . . .
1 Brummer 90 ("%
'(
2 curve is a different model type for the sampler? 3 A T h m.: ' s correct. 4 Q So what do you conclude from that then? l 5 A That would be speculative, my conclusion. 6 Q No, it would be a logical process here. I o 7 am just saying, looking at thir evidence, by a process 8 of logic, do you have a hypothesis as to what's going 9 on here? Is there a page missing fron the book? 10 A We do not have the proper d,urves for the 11 sampler which was supplied and is this sampler. These 12 calibration curves say we have an 841. This is actual O 13 data taken off the sampler when it was calibrated 14 and here the curves are for an 840-4P. So, the re f o re , 15 the curves are inappropriate for the chamber. 16 Q So that curve on pages 226 to 229 cannot 17 provide the sensitivity for use in the set point 18 calculation, is that right? 19 A It would have to be verified by Victoreen 20 as to which curve -- to obtain the currect curve. 21 Q Are there some pages missing from this 22 Victoreen document in the back, did you notice? 23 , A I cannot tell. , 24 Q Well -- 25 A There don't appear -- to the extent to which '
, = - _ - - - _ .
1 Brummer ,91 2 the pages go, I cannot tell, you know, I cannot find
~
3 any page numbers missing in a rough look through. 4 Q -Are you aware of any place where there are
. 5 any curves relating to the sensitivity of the 720 6 monitor other than in the Victoreen manual?
7 A I don't reme mbe r. 8 Q You are not aware of any? You don't recall 9 if there were any? i 10 A I don't recall any. , ! 11 Q From that calibration record on page 13, 12 you cannot get a sensitivity for the 720 monitor, is C* 13 that right? 4 14 A That's correct. 15 Q Can we continue then with the procedure. 16 There is a high alarm set point set forth i 17 there, the value is 5.0 times 10 to the 5th CPM. 18 Does the CPM mean counts per minute? 19 A That's correct. l 20 Q How did you arrive at that high alarm set 21 point? { 22 A By reading the basis on page 65, the basis , 23 l assumes that the total activity of the primary coolant . 24 I at 1 percent failed fuel is 360 microcuries per CC. 25 Now, if you take the 360 microcuries per CC and
1 Brummer .91 ( . O 2 the pages go, I cannot tell, you know, I cannot find 3 any page numbers missing'in a rough look through. 4 Q Are you aware of any place where there are ( 5 any curves relating to the sensitivity of the 720 6 monitor other than in t,he Victoreen manual? 7 A I don't remember. 8 Q You are not aware of any? You don't recall 9 if there were any? 10 A I don't recall any. ', 11 Q From that calibration record on page 13, gg 12 you cannot get a sensitivity for the 720 monitor, is 13 that right? 14 A That's correct. 15 Q Can we continue then with the procedure. 16 There is a high alarm set point set forth 17 there, the value is 5.0 times 10 to the 5th CPM. 18 Does the CPM mean counts per minute? 19 A That's correct. 20 Q How did you arrive at that high alarm set 21 point? 22 A By' reading the basis on page 65, the basis i 23 assumes that the total activity of the primary coolant , i i fs (_) 24 at 1 percent failed fuel is 360 microcuries per CC. ! 25 Now, if you take the 360 microcuries per CC and i I
31 1 Brummer 92 f i 2 multiply it by the sensitivity above, you will come up 3 with 3.67 times 10 to the 10th counts per minute. 4 This monitor has a range of 10 counts per ( 5 minute to 10 to the 6th counts per minute. Therefore, 6 the note was applied which states, "Since this is above 7 the range of the monitor, conservatively set the g setpoint at 5 times 10 to the 5th count per minute." 9 Q Was there a collimator installed on this 10 monitor? We are looking at the 720 in',the gross mode 11 on page 65, just to keep the record clear on that. 12 A To my knowledge, I have no knowledge of Q) 13 the collimator being in place. . 14 Q You have no knowledge today? I mean, have 15 you heard today that there was one in place? 16 A No. I didn't say that. 17 Q What I am asking you as you sit here today, 18 have you heard at some point that there was a i 19 collimator in place? 20 A No. 91
~ Q You have never heard that with respect to i 22 this monitor?
- i 23 ; A Not that I can recall.
l
,Q l \m ,/ 24 Q When you prepared the set point and got this; 25 set point approved, you did not include a collimator
31 1 Brummer 92 0 2 multiply it by the sensitivity above, you will come up 4 3 with 3.67 times 10 to the 10th counts per minute. 4 This monitor has a range of 10 counts per fI 5 minute to 10 to the 6th counts per minute. Therefore, 6 the note was applied which states, "Since this is above 7 the range of the monitor, conservatively set the 8 setpoint at 5 times 10 to the 5th count per minute." 4 9 Q Was there a collimator installed on this 10 monitor? We are looking at the 720 in the gross mode 11 on page 65, just to keep the record clear on that. 12 A To my knowledge, I have no knowledge of f-(- 13 the collimator being in place.
~
14 Q You'h' ave no knowledge today? I mean, have 15 you heard today that there was one in place?
- 16 A No. I didn't say that.
I 17 Q What I am asking you as you sit here today, I - 18 have you heard at some point that there was a i ~ l 19 collimator in place? 20 A No. l 91 Q You have never heard that with respect to (. 22 this monitor? 23 A Not that I can recall. l , t 21 Q When you prepared the set point and got this 25 set point approved, you did not include a collimator l l
1 Brummer 93 2 attenuation factor in your calculation, is that correct? 3 A According to this document, that's correct. 4 Q Before the accident, you were not aware of (- 5 any collimator being attache <! to this 720 radiation 6 monitor in the gross mode? 7 A Clarify that <tatement, please. . 8 Q In what way~r g A I need a clarification on the " attached to." 10 Q Placed on the monitor in ady fashion so as 11 to provide an attenuation effect. 12 A As long as-you put "to provide the 13 attenuation effect," no. . 14 Q Were you aware there was one affixed to 15 this monitor in some fashion? I don't want to get 16 tied up in words here. Was there -- 17 A I cannot definitively say that the collimator 18 was in place or out of place, but typically it would 19 be kept with the monitor. 20 Q You mean it came with a collimator? 21 A Yes. It came with a collimator. That was 22 an option to be installed. 23 Q And the collimator was left on the monitor, , 24 but not put into a position so that it would provide 25 attenuation? _ . . _ . . _ - _ _ . _ _ . . ,_- ~ , _. , _ .._ ___. . - _
1 Brummer 93 2 attenuation factor in your calculation, is that correct? 3 A According to this document, that's correct. 4 Q Before the accident, you were not aware of ( 5 any collimator being attached to this 720 radiation 6 monitor in the gross mode? - 7 A Clarify that statement, please. 8 Q In what way? 9 A I need a clarification on' the " attached to." 10 Q Placed on the monitor in ady fashion so as 11 to provide an attenuation effect. A As long as you put "to provide the n V 12 attenuation effect," no. 13 b 14 Q Were you aware there was one' affixed to 15 this monitor in some fashion? I don't want to get 16 tied up in words here. Was there -- 17 A I cannot definitively say that the collimator 18 was in place or out of place, but typically it would 19 be kept with the monitor. . 20 Q You mean it came with a collimator? 21 A Yes. It came with a collimator. That was 22 an option to be installed. 23 l Q And the collimator was left on the monitor, t 24 but not put into a position so that it would provide 25 l attenuation?
1 Brummer 94 2 A That's correct. 3 Q And as you understood it, for the time . 4 period up to the accident, the collimator was not in such ( 5 a position that it would provide attenuation? 6 A To the best of my recollection, yes. 7 Q In the immediate aftermath, was any 8 investigation done of the 720 monitor? 9 A Yes. I believe so. 10 Q Could you describe that inkestigation? 11 A What I recall is that a scaler was put on ns 12 the detector to try and determine what the output was.
\ms) 13 Q What is a scaler?
14 A A scaler -- it's a means by w'hich you can 15 count the pulses, the analogue pulses which are coming e 16 up from the detector. 17 Q when was that done? - 18 A Shortly after the -- within the first few 19 days after the accident. 20 Q What was the result? 91 A As I recall. 22 I don't recall the specific results. I 23 Q Were those results recorded? l l 24 : A I cannot say that they were specifically 1 25 recorded or where they were specifically recorded, if
1 Brummer 94 i V 2 A That's correct. 3' Q And as you understood it, for the time 4 period up to the accident, the collimator was not in such ( 5 a position that it would provide attenuation? 6 A To the best of my recollection, yes. 7 Q In the immediate aftermath, was any 8 investigation done of the 720 monitor? 9 A Yes. I believe so. 10 Q Could you describe that inv,estigation? 11 A What I recall is that a scaler was put on 12 the detector to try and determine what the output was. U What is a scaler? 13 Q 14 A A scaler -- it's a means by w'hich you can 15 count the pulses, the analogue pulses which are coming 16 up from the detector. 17 Q When was that done? - 18 A Shortly after the -- within the first few ( - j 19 days after the accident. 20 Q What was the result? 21 A As I recall. 22 I don't recall the specific results. j 23 Q Were those results recorded? , l 21 A I cannot say that they were specifically
~25 ; recorded or where they were specifically recorded, if
1 Brummer 95 O they were. 2 3 Q was this done at your request? 4 A No. I was not involved with that at-that ( 5 time. 6 Q Was there any other investigation of the 720 7 monitor that you are aware of? 8 A To my knowledge, no. 9 Q I am including in that question now up to 10 the present time. . 11 A That is still an accurate statement. pg 12 Q In order to determine what activity level O 13 in the reactor coolant would give the high alarm on 14 the 720 monitor in the gross mode, is it correct that 15 you would take the number 5.0 times 10 to,the 5th count 16 per minute and divide by the sensitivity? 17 A That's correct. - f . 18 Q And the number you get from that calculation i 19 would be the activity level in the coolant that you 20 expected to put this monitor into alarm according to og
~
this procedure, is that correct? ( . 22 A That's correct. l l , l 93 Q Did this 720 monitor in the gross mode ever . l i (~)
\- / 24 I
! go into alarm prior to the accident, to your knowledge?
- 25 A To my knowledge, no.
l l t
1 Brummer 95 m U they were. 2 3 Q was this done at your request? 4 A No. I was not involved with that at that 5 time. 6 Q Was there sny other investigation of the 720 7 monitor that you are aware of? 8- A To my knowledge, no. 9 Q I am including in that question now up to the present time.
- 10 ,
11 A That is still an accurate statement. gg 12 Q In order to determine what activity level (_) 13 in the reactor coolant would give the high alarm on 14 the 720 monitor in the gross mode, is it correct that 15 you would take the number 5.0 times 10 to the 5th count 16 per minute and divide by the sensitivity? 17 A That's correct. - 18 Q And the number you get from that calculation 19 would be the activity level in the coolant that you 20 expected to put this monitor into alarm according to . 21 this procedure, is that correct? 22 A That's correct. . 23 Q Did this 720 monitor in the gross mode ever , (~% 4 (_) 24 l go into alarm prior to the accident, to your knowledge? 25 A To my knowledge, no. I
1 Brummer .96
'O
(_ g Q Did you ever get involved in any k 3 surveillance or repair work on this monitor prior to the L 4 accident? 5 A I was involved from the standpoint of doing 6 the initial calibration for the test procedures. 7 Q That was the start-up testing that we 8 discussed earlier. 9 A That's right. 10 Q Apart from that, do you re$all any 11 involvement in any surveillance or repair work on this 12 monitor prior to the accident? O 13 A Not specifically. . 14 Q I would like you to turn to page 66, which 15 is the 720 monitor in the analyzed mode. 16 What is the source of the sensitivity value 17 for this conitor? - 18 A The discussion about the sensitivity of the 19 gross mode applies to the discussion of the sensitivity 20 of the analyzed mode where I would have to go back and 21 look at the curves for the specific sampler with the 22 specific model number detector we had. l 23 Q You say you would have to go back and look 2 i 24 at the curves. 1 25 Where would you find those curves?
1 Brummer 96
-s\
(/. x_ 2 Q Did you ever get involved in any 3 surveillance or repair work on this monitor prior to the 4 accident? l 5 A I was involved from the standpoint of doing 6 the initial calibration for the test procedures. 7 Q That was the start-up testing that we 8 discussed earlier. 9 A That's right. 10 Q Apart from that, do you reE,all any 11 involvement in any surveillance or repair work on this 12 monitor prior to the accident?
-T (O A Not specifica11y.
13 i . 14 Q 1 would like you to turn to page 66, which 15 is the 720 monitor in the analyzed mode. 16 What is the source of the sensitivity value l l 17 for this monitor? - 18 A The discussion about the sensitivity of the l 19 gross mode applies to the discussion of the sensitivity l 20 of the analyzed mode where I would have to go back and l 21 lo k at the curves-for the specific sampler with the o9 specific model number detector we had. l l l 23 Q You say you would have to go back and look 24 at the curves. here weu1e yeu fine ehese cerves2 25 l i
l 1 Brummer 97 2 A As discussed before, I don't recall having 3 those curves. 4 Q In the case of the 720 monitor in the 5 analyzed mode, what was your understanding of the status 6 of the collimator in the period before the accident? 7 A The same as in the gross mode. 8 Q so again you understood that the collimator g was attached, but it was not moved into a position 10 where it would provide any attenuation',effect? 11 A That's correct. 12 Q Do you recall the 720 monitor in the V 13 analyzed mode being in alarm at any time prior to the 14 accident? 15 A Not to my knowledge. 16 Q Would that information have come to your 17 attention prior to the accident? - 18 MR. KATCOFF: I object to the form of the 19 question. I 20 A It would have been speculative. 21 Q Well, you mean you can't tell me that you 22 would have heard about every alarm, that's basically it? i i 23 ; I mean, you weren't in such a position that it was , 24 automatic, if an alarm went off, you heard about it? 25 MR. KATCOFF: I object to the form again.
1 Brummer 97 2 A As discussed before, I don't recall having s 3 those curves. 4 Q In the case of the 720 monitor in the 5 analyzed mode, what was your understanding of the status 6 of the collimator in the period before the accident? . 4 7 A The same as in the gross mode. 8 Q So again you understood that the collimator 9 was attached, but it was not moved into a position l 10 where it would provide any attenuation effect? 11 A. That's correct.
% 12 Q Do you recall the 720 monitor in the w
13 analyzed mode being in alarm at any time prior to the g4 accident? 15 A Not to my knowledge. 16 Q Would that information have come to your 17 attention prior to the accident? - i . 18 MR. KATCOFF: I object to the form of the 19 question. 20 A It would have been speculative. nt
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Q Well, you mean you can't tell me that you 22 w uld have heard about every alarm, that's basically it? i 23 I mean, you weren't in such a position that it was 24 automatic, if an alarm went off, you heard about it? l 25 l MR. KATCOFF: I object to the form again.
1 Brummer 98 O Q Do you understand what I am asking? 2 3 Was it your job, was your job one where 4 one of these monitors went into alarm, somebody let's ( 5 you know about it? Was that a practice or procedure 6 at Met Ed? 7 A That's a speculative answer on my behalf. g Q Well, prior to the accident, were you ever 9 advised that any radiation monitor had gone into alarm? 10 A I can't state a specific odp. 11 Q Do you recall that that happened? 12 A I don't remember being notified that anyone
- O 13 went into a high or an alert radiation. condition other 8
14 than for calibration.
- 15 Q Will you look at page 14 in the set point
, 16 procedure, Exhibit 599. i 17 Yes? - 18 A I seem to have a problem. It doesn't appear 19 to be in this copy. 20 MR. WURTZ: Off the record. l . - 21 (Discussion off the record) ! 22 A All right. ; i 23 Q On page 14 you.have the set points for the 3 j
\ 24 ' l 213 area monitor, is that correct?
l 25 A That's correct.
1 Brummer 98 f) V 3 Q Do you understand what I am asking? 3 Was it your job, was your job one where 4 one of these monitors went into alarm, somebody let's ( 5 you know about it? Was that a practice or procedure 6 at Met E4? 7 A That's a speculative answer on my behalf. 8 .Q Wella prior to the accident, were you ever 9 advised that any radiation monitor had gone into alarm? 4 10 A I can't state a specific ode. 11 Q Do you recall that that happened? 12 A I don't remember being notified that anyone 13 went into_a high or an alert radiation. condition other i 14 than for calibration. 15 Q Will you look at page 14 in the set point . 16 Procedure, Exhibit 599. 17 Yes? - 18 A I seem to have a problem. It doesn't appear 19 to be in this copy. 20 MR. WURTZ: Off the record. 21 (Discussion off the record) 22 A All right. 23 Q On page 14 you have the set points for the I (~% 213 area monitor, is that correct? () 34 25 l A That's correct.
1 Brummer 99 2 Q How did you arrive at the high alarm set 3 point specified there? 4 A The FSAR is identified as a reference ( 5 contained radiations on drawings, which is where the 6 design value came from, and based on -- I don't 7 exactly remember the reason for the two times design 8 value number. 9 Q First you went to the FSAR and got the' design 10 value for the particular part of the bdilding where this ! 11 monitor was, is that it? 12 A Yes. ' ~ 13 Q And then multiplied that by 27 5 14 A By 2. 15 Q As I understand it, the location of this 16 213 monitor was specified in the original Burns & Roe 17 specification, is that correct? - 18 A Yes. It was specified to the intent it 19 was called the in-core instrument panel area, monitor. 20 Q The specification said it should go in the 21 in-core instrument panel area and another drawing 22 indicated where that area was and -- l [ 23 A That's correct. l 24 l Q Did you at any time evaluate or review the 1 25 decisions that had been made relating to the location of
1 Brummer 99 m 2 Q How did you arrive at the high alarm set s 3 point specified there? 4 A The FSAR is identified as a reference 5 contained radiations on drawings, which is where the 6 design value came from, and based on -- I don't 7 exactly remember the reason for the two times design 8 value number. 9 Q First you went to the FSAR and got the design 10 value for the particular part of the b$11 ding where this 13 monitor was, is that it? I~o A Yes. (v 13 Q And then multiplied that by 27 14 A By 2. 15 Q As I under>tand it, the location of this 16 213 monitor was specified in the original Burns & Roe 17 specification, is that correct? 18 A Yes. It was specified to the intent it 19 was called the in-core instrument panel area, monitor. 20 Q The specification said it should go in the og
~ in-core instrument panel area and another drawing i 29 indicated where that area was and -- i i
23 A That's correct. l 24 Q Did you at any time evaluate or review the 25 decisions that had been made relating to the location of
l l 1 Brummer 100 O
\J 2 particular monitors? l A I looked at and reviewed the location cf 3
f ' 4 particular monitors. However, at that time it was 5 already established where they would be. 6 Q Did you review and approve what had already 7 been determined? 8 A No, I did not approve. I just reviewed. 9 Q Did you evaluate in some respect? I mean, 10 did you bring your own judgment to bea'r on it or were 11 you just accepting a decision that had been made 12 already? (~%
\l 13 A I was accepting the decision. Where it was
.14 questioned about a specific monitor and a specific 15 location, I might have had either verbal conversation 16 with the architect-engineer or written a field 17 questionnaire to him trying to make further 18 recommendations.
( 19 Q Do you recall any particular monitors for 20 which you did make recommendations either through og field questionnaires or orally? 22 MR. KATCOFF: You are referring to the i l i 23 location of the monitors? ; l ( 24 MR. WURTZ: Yes. 25 A Does this include all monitors or areas,
- _ . ~ , , , - , _ - . _ - . - - _ _ . , _ - _ . _ . - . , _ . . - _ _ . - - _ -, . . . . - . . . - . . - , . . - - - . . ,
1 Brummer 101 h V 2 monitors, liquid monitors? 3 Q All monitors. 4 A With regard to some of the atmospheric 5 monitors, I had discussed changes. 6 Q Which monitors? 7 A I don't remember all of the monitors that 8 I would have had discussions about. 9 Q Do you remember any of them? t 10 A They were atmospheric monitors, vice area 11 monitors, just atmospheric monitors is all I remember 12 making comments on. 13 Q Do you remember any of the. atmospheric 14 monitors on which you made comments? 15 A I believe it was HP-R-221A, 2,2 1 B , 222 and 16 228. 17 Q Did you make your recommendations in writing 18 or orally? 19 A I can't specifically remember. L 20 Q What was the substance of your 21 recommendations? { 22 A My recommendations were based on the length i 23 of sample tube between the sample point and the [) v 24 monitor. 25 Q What was your recommendation?
1 Brummer 102 f% J 2 A To reduce the length. 3 Q What was your reason for thinking that? 4 A The reasoning behind that was the fact that ( 5 the line of tubing was in excess and around 100 feet 6 long and that seemed like an awful long distance in 7 which to pull a sample through a tube. 8 Q Did you make this same recommendation with 9 respect to all the monitors you identified? 10 A Yes, that was a generic s t a,t eme n t . 11 Q Was there any other recommendation that you 7g 12 made for changes in the location of monitoring
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13 equipment? , 14 A Not that I can remember. 15 Q Now, we are looking at page 14, area 16 monitor 213. 17 Is that a tech spec monitor? - 18 A No. 19 Q What procedure governed surveillance of that
^
20 monitor? 91 A I would have to have a copy of the procedure
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22 index to give you a number. There was a calibration i 23 procedure for area radiation monitors, j (" / (,h Q Let me show you a copy of what was marked 34 25 I previously as B&W Exhibit 322, which is a calibration 1
.,--4. --
1 Brummer 103 O x_/ 2 procedure for GM tube area monitors. 3 Is that the procedure that was used for 4 -calibration of the 213 monitor? ( 5 A Yes, this would have been the procedure 6 for calibrating 213. 7 Q How is this calibration procedure different t 8 from the tech spec calibration procedure we looked at 9 earlier? 10 A By that, you mean the 2302d? 11 Q Right. I am thinking if there are any 12 general basic differences in the steps taken that you O 13 could identify. 14 A To my knowledge, there are no general 15 differences between the calibration of this GM tube 16 area monitor and P H-R-215,which is in procedure 17 22302R3. . 18 Q Were you involved in surveillance activities 10 prior to the accident? 20 A To what extent are you trying to -- 21 Q Did you go and look at the monitors from 22 time to time that you review surveillance sheets, did ; 2 ; 23 you have -- I am just asking really for you to describe , 24 what, if any, involvement you did have in surveillance 25 activities prior to the accident.
1 Brummer 104 s . . l 2 MR. KATCOFF: You are referring to after 3 the start-up and test period about which he has 4 testified? l 5 MR. WURTZ: Yes, he testified to that and 6 the period where he was preparing the surveillance 7 procedures and where he was -- 8 A Yes, I peri.odically, I went out and watched 9 technicians perform calibrations, reviewed data sheets. 10 It was more of a surveillance-type thin,g for me to go 11 out and just periodically do it, to check the status of 12 the system, than a specific designated requirement of O V 13 my job. , 14 Q Was this 213 area monitor in alarm at any 15 time before the accident, to your knowledge? 16 A Not that I remember. 17 Q After a set point is defined in the set 18 point procedure, Exhibit 599 --
, 19 A Yes.
20 Q -- who is authorized to change the set point 91 on the meter itself? 22 A The set point on the meter itself for the l 23 radiation monitors was typically done by I&C, except l l; 24 possibly for one monitor which had a variable set point 25 knob on the front. All others were calibrated and
. _ =
1 Brummer 105 2 adjusted by I&C. 3 Q What was the monitor with the variable 4 set point? ( , A I believe it is WDLR 1311, which the 6 operations department would have set based on releases. 7 Q To your knowledge, nobody was authorized 8 to change a set point other than the I&C technician? i 3 g A No. That's physically change. 10 Q That's physically change, fes. 11 A Yes.
/~N l~o Q And the I&C technician would be governed U 13 by Exhibit 599, which sets forth the various set points?
14 A Yes. 15 Q Was it possible for an operator to go up 16 and change a set point or was there a locking device 17 on the meter? . 18 A As I recall, because there were about three
- 19 different types of modules, the module had to be 20 withdrawn from the panel. It was on a slide type bar and 21 adjustments made by screwdriver adjusting pots, so, 22 therefore, it was not --
that I remember a front panel j i 23 adjustment except for the one we have previously ! t
) 24 discussed, 1311.
25 Q It wasn't like tubing in your stereo? I 1 -<- - -r- - g 4,~. . , -y - _
1 Brummer 106 (v/3 2 A No. 3 Q You had to pull it out and use a screwdriver, 4 is that right? ( 5 I was just testifying. I wanted you to 6 agree. 7 Could you look next at page 15, which is 8 the 214 monitor. 9 A Will you repeat the page number? 10 Q Yes, page 15 in Exhibit 599, the system 11 set point procedure. g 12 I see that you based your calibration on 13 a radiation level of 800 R per hour. . 14 Where did you get that figure of 800 R? 15 A I don't remember. t 16 Q Is there any document from which you got l 17 that? - l 18 A once again, I don't remember. 19 Q Do you recall any discussions concerning l 20 what number to set that at? 01 A Yes, there were discussions where to set it, I but I don't remember where the number came from. 22 l ! l 23 Q You don't remember the substance of any of l 24 those discussions? l 25 A Not specifically, no. I L
1 Brummer - 107 b \_,/ . 2 Q Was the selection of that 800 R number for 3 the alarm on the 214 monitor discussed with the PORC 4 members? l( 5 A I don't remember the details of the 6 discussion that would have gone on with that. 7 Q Do you remember anything about those. 8 discussions? 9 A No, not specifically. 10 Q Do you recall whether therd,was any 11 discussion of whether this was too high a number, for 12 example? (~h d 13 A I don't specifically recall. 14 Q Did you make any assumptions regarding the 15 coolant activity level in reaching this 800 R number? 16 A I don't specifically recall. 17 (Continued on next page) . 18 19 - 20 91
~ ;
22 f i 23 24 i 25
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['[ , j ,1 f Brummer 108 j f ;,. .
, . 2 Q. Is ' i't , cu rre ct that you would have had to
/
, J 3 make some ;yss~u/mptibn regarding the coolant activity 4 level,#to arrive $t ^t $at number?
t:
' (.e - 5 MR. KAVCOFF: '
I object to the quest; ion. f
', j 6 s A .. That would be speculative without knowing
].ld ' , ., Y' - 7 the) details'of it'. I can't remember. i ff
.g ,
/ 8
, ',, . yQ ' ,
' Well, is it a necessary part, a necessary
,f * *S }
j 9 lotrical pro [ess to carry out in arriving at the
!tl' ,'
t l to make certain assumpti'ons concerning 10
,, g(,800.
sq S per heuS a. . 11 ,th$ ' coolan t activity levels? z., 12 A My answer would be speculative. i 13 Q Well.,'I am asking really whether from 14 your understanding of the development of set points l. 1/ . 't ' _ , , 15 it is a necessary logical process to go through?
, a #
- g .
, 16 1 mean s _whe:.cver you have a number like 800 R, a y ,,
e j 17 ridi,ation) numb e r , that is produced by fission i 18 prodict' activity in the coolant; is that correct?
~~
19 I That is a speculative answer without 20 knowing all the boundaries by which you are looking 21 at...the analysis of the vessel inside the building,
? -
i 22 ct cetera. s k ..# 2P # l ,-
. Q You mean that there might be some variation r\ '
+
t J
+
24
- V;in-the. number you would come up with?
25 What I am asking is to get a reading of
1 Brummer 109 2 800 R per hour on the 214 monitor, did you understand 3 that a certa'in percentage of failed fuel was 4 required? ( 5 A And I am saying I don't remember the 6 assumption that went into the 800 R per hour number. 7 Q Did you understand before the accident 8 that to get a reading of 800 R per hour in monitor 9 214, which was the dome monitor, that fuel failure 10 was required? . 11 A Without doing an analysis, I can't -- that _ 12 would be a specuJative answer to say that failed fuel , 13 would have to occur. 14 Q You mean it was your understanding you 15 could reach the point of 800 R per hour without any , 16 failed fuel? 17 A I di dn ' t say that. I said there is an 18 analysis I would have to go through, whic I Jm 19 remember, that would tell me whether I had failed fuel 20 or not. 21 Q What kind of analysis? 22 A Once again, you have to accoun t for all 23 the boundaries around the assumptions that you are [h (_j 24 making. 25 Q Could you describe the kind of analysis
1 Brummer 110 2 that would tell you if you needed failed fuel or 3 cladding dam' age to get a reading of 800 R per hour 4 on the dome monitor? ( 5 A Those assumptions would be speculative 6 and very opinionated on my behalf at this point 7 to go through and describe. 8 Q well, before the accident did you 9 understand that you could do an analysis that would 10 tell you whether you needed failed fuel.or cladding 11 damage in order to get 800 R per hour in the dome 12 monitor? . . 13 A I don't remember. - 14 Q You don't know whether you understood there 15 was such an analysis you could do? , 16 MR. KATCOFF: That is what he is 17 testifying to. -
~
18 Q I am asking before the accident, did you 19 know that there was a way to tell, a way to answer t 20 that question, to get 800 R per hour in monitor 214, 21 do I or do I not have to have failed fuel? Did you k. 22 know before the accident that there was a way to answer 23 that question? i O) (_ 24 A I don't remember doing an analysis of l [ 25 whether we had to have failed fuel or not to get the I l
1 Brummer 333 i ,
\'
2 800 R per hour reading in the reactor building prior s 3 to the accident. 4 Q You did understand before the accident, ( 5 though, that there was an analysis you could do to 6 determine that question? 7 A That analysis takes a lot of input and a s 8 lot of assumptions on the boundaries that would be 9 speculative in nature and I do not remember doing 10 that analysis.
- 11 Q I understand that, you don't recall 12 doing it.
) -
13 My question was, you did understand there 14 was such an analysis; is that correct? There was --
, 15 A I don't know that an analysis like that 16 was ever performed.
l 17 Q What did you understand before the 18 accident an analysis like that would involve? What l 19 were the steps in the process of doing such an analysis? 20 MR. KATCOFF: Your question is to his 21 understanding before the accident? l 22 MR. WURTZ: Yes. I 23 A The way I would have to answer that would 24 be speculative, O. K., based on my logic of thinking 25 through what would have to be done. I l i
1 Brummer .112 10 V 2 Q Right, that is what I'm looking for. 3 'I understand you don't recall doing this 4 and you are not aware of anybody doing it, in fact. (, 5 A To do that analysis, you would have to 6 take into consideration the various breaks that could 7 occur and the conditions which would result of 8 those breaks in the core, the geometry of the building
~
9 with regard to the coolant system and with regard to t 10 the location of 214. - 11 Q Is it correct that you were responsible 12 for preparing the set point for this pa,rticular O. 13 monitor, No. 2147 - 14 A Yes. 15 MR. KATCOFF4 We have been going about 16 an hour and a half. Is this a good time to 17 break? ~ 18 MR. WURTZ: It's O. K., yes. 19 MR. KATCOFF: All right. 20 (Recess taken.)
,. 21 BY MR. WURTZ:
k 22 Q Mr. Brummer, we were discussing the 214 23 monitor before the break. I would like to continue () 24 that discussion. 25 You had a lead shielding around that
1 Brummer ,3 3 3 O 2 monitor -- 3 A 'Yes. 4 Q -- which you assigned a 100 times ( 5 attenuation factor to. 6 What isotope did you use to calculate 7 that attenuation factor? 8 A That came out of the Victoreen instruction 9 manual, that attenuation factor. 10 Q That came out of tables in .the Victoreen 11 manual; is that right? 12 A No, there is a drawing which shows the O 13 details of the shield assembly. 14 Q Could you locate that?
, 15 A Well, not having the whole ma,nual here --
16 I cannot find it in this copy of the manual. 17 Q Is it in that section or in a*different 18 section? l 19 A It is in this section (indicating). l 1 20 Q But it is not in this book here that we 21 marked as an exhibit? 22 A It is not in this copy marked as an 23 exhibit that I can find. One reason -- I don't know (~h. (_) 24 if you want this on the record. 25 Q Yes, yes.
.- . _ _ _ . . - -. ~, _ -. . _ . _ - - - . . _ . - .
1 Brummer gj4 O 2 A One reason is that it is a blueprint i 3 in this section of the manual (indicating) and you 4 might not have a copy of the blueprint. This appears ( 5 to be copies of all the 8-1/2 by 11 Xeroxable sheets, 6 if you will. 7 Q And you got the attenuation factor from 8 a blueprint which is part of this volume; is that 9 correct? 10 A That is correct. . 11 Q Was that attenuation factor based upon a
- 12 single isotope?
13 A I can't answer that without 1 coking at i 14 the blueprint. 15 Q You don't have any understanding of i .
=
16 , whether-it was based on one isotope or an average of 17 a number of isotopes?
- 18 A I don't remember, no.
19 Did you understand before the accident Q 20 that the 214 radiation monitor would not go into
; 21 alarm until cladding damage had occurred in the core?
22 A Not specifically, no, in that there might 4 23 have been other causes for the alarm. 24 Q well, I am trying to determine what you 25 understood when you prepared and submitted this
1 Brummer 115
- s/
2 set point for approval. 3 'Did you understand you were proposing a 4 set point that would lead to an alarm only in a ( 5 case where cladding damage had occurred? 6 A I understood that the set point was based 7 on a LOCA. 8 What did that mean to you? Q 9 A LOCA is a loss-of-coolant accident. 10 And? Q . 11 A Do you have a specific question? 12 Q My question is, what did that mean to you? O 13 You said it was based on a LOCA. 14 A That a LOCA had happened inside the 15 building. 16 Q Did you understand when you prepared and 17 submitted this set point for approval that the LOCA 18 would have to lead to cladding damage before the alarm 19 would go off? 20 A I do not remember the analysis being done i 21 to say that the LOCA had to occur and then fuel 22 cladding damage to get the alarm. 23 MR. WURTZ: Will you read that back, b) (_ 24 please. 25 (Record read.)
y Brummer 116 2 Q Did you have any understanding at the time 3 you submitted this set point for the 214 monitor as 4 to' whether cladding damage was required to cause ( 5 the monitor to-alarm? 6 A Once again, I don't remember an analysis 7 being done to show that it had to do cladding damage 8 to get the alarm. 9 Q I understand that you don't recall any 10 analysis. ', 11 What I am asking.now is whether you recall i 12 having an understanding on this? p What I am asking 13 for is what was your purpose here in proposing this 14 set point? 15 A The purpose in proposing the set point 16 was to identify a number which would be indicative 17 of a LOCA inside the reactor building. - 18 Q were you trying to identify [ LOCA before l l 19 fuel damage occurred or only a LOCA that led to fuel i 20 damage?
. 21 A I don't remember the specific basis for l 22 the LOCA.
1 l 23 Q Did you understand before the accident t () 24 that you were required to have an area monitoring 25 system that would detect LOCAs of various sizes? l l
1 Brummer i m 117. 2 MR. KATCOFF: I object to the question 3 on the' grounds that you don't specify required 4 by whom. ( 5 Q You can answer that question. 6 MR. KATCOFF: If you can. 7 A I can't answer that question. 8 Q You can't answer that question? You can't 9 tell me whether you understood before the accident t 10 that there was a requirement that you have an area 11 monitoring system-that would detect a LOCA? 12 A The technical specifications required 13 you have a dome monitor to monitor the levels inside 14 the containment. It did not specify or I don't 15 remember the specification of the analysi,s as to what 16 size LOCA. 17 Q Well, did you understand that*you were 18 required to have an area monitor to detec LOCAs 19 up through and including a maximum hypothetical 20 accident?
< 21 A I do not remember the specific minimum k
22 size LOCA by which this analysts was done. 23 That is not the question I asked. Q
\
()_ 24 MR. WURTZ: Could you read the question 25 back, please, i i
1 Brummer
.318
[
'~
2 (Record read. ) s 3 Q That is the question. 4 A So you are pressing that the second time? ({ 5 6 Q Yes. 7 A At the time, it was my understanding 8 for small LOCAs that the dome monitor would not go 9 into alarm right away. "Small" being between zero and 10 10 GMP, approximately. E 11 Q What monitor was designed to pick up a
'2 LOCA of that size?
'} .-
.3 A There was no specific radiation monitor 14 designed to pick up anything of that small a 15 magnitude. That's my understanding, that anything 16 based on that would be an analysis of the airborne 17 as possibly detected by HPR 227. .
18 Q So 227 was the monitor that would pick up 19 the small LOCA defined as zero to 10 GPM; is that 20 correct? 21 A Approximately. Small amounts of leakage 22 from the system would not be detected, in my 23 understanding, by 214 or a dome monitor. l () 24 Q Or by any other area monitor; is that 25 correct? i
1 Brummer 119 (\_/-) 2 A Not unless the specific leak was in the 3 vicinity - 'the direct vicinity of the area monitor. 4 Q Was the 214 monitor designed to pick 5(r 5 up LOCAs of a size greater than 10 gallons a minute? 6 A I do not remember the specific analysis 7 that might have been done to determine what size LOCA 8 it could pick up and detect. 9 Q Was it your understanding or was it your 10 assumption that the 214 monitor would 'ni fact pick 11 up LOCAs greater than 10 gallons per minute in size? 12 A No, it was not my understanding. b\ v 13 Was it your understanding .that there was Q 14 some other area monitor designed to pick up LOCAs 15 greater than 10 gallons per minute in size? 16 A No. 17 Q What did you understand was the purpose 18 of the area monitors as far as LOCA detection was 19 concerned? 20 A Area monitors were there mainly for 21 personnel doing synnetry readings, and it was my 22 understanding they would detect small leakage 23 in the various systems that had activities. However, r' T i
- l
() 24 they were not qualified as accident devices and would 25 not withstand high dose rates for long periods of time.
av , l Oc 1 1 Brummer 120 (~\ ' V 2 Q These are the area monitors other than the s 3 214 monitor?' 4 A Yes. ( 5 Q Were not qualified as accident devices? 6 A That is correct. 7 Q I would like to show you a copy of I 8 Chapter 12 of the Unit 2 FSAR, and ask you to turn to 9 paragraph 12.1.4, entitled " Area Monitoring," and in 10 particular paragraph 12.1.4.1, entitled," Design 11 Criteria." 12 Did you review this document in connection 13 with preparing the set points for the radiation 14 monitoring system? 15 A Yes. This was reviewed. . 16 Q Were you familiar with this section entitled 17 " Design Criteria" at the time when you pr'epared the 18 set points for the Unit 2 radiation monitoring system? 19 A I had read it. 20 Q Did you understand that it was relevant to 21 the work you were doing on developing set points? 22 A I understood that it applied, yes. ! 23 Q I vould like you to look at the second ; (~)/ s_ 24 i paragraph under the heading " Design Criteria." 25 A Yes.
1 Brummer 121
' f} .
U 2 Q A sentence there reads: "The detector 3 functions, 1ocations, ranges and set points as described 4 in Table 12.1.5 were selected to monitor normal plant ( 5 operations, and to monitor and provide additional 6 r.larms during and following abnormal operations or. 7 accidents up through and including a maximum hypothetical 8 accident." 9 MR. KATCOFF: Has this document been marked 10 in a previous deposition? t 11 MR. WURTZ: I don't know. I know it 12 hasn't been marked yet. I will mark it when we O 13 finish the discussion. , 14 MR. KATCOFF: Okay. 1 15 Q Did you understand that it was one of the 16 design requirements here to apply this standard to the 17 set points you were developing? . 18 A It is my understanding that we used the 19 information contained in Chapter 12 as reference in 20 developing the set points. n1 Q Did you attempt to provide set points that km 4 22 would provide alarms during accidents - rough and , 23 , including a maximum hypothetical acc ;
/~T
(_) 24 A It was my understanding ti alarms 25 which I helped develop would in fact provide indications
9 i Brummer 122 0 2 for abnormal operations an'd accidents up to and 3 including th'e maximum hypothetical accident. 4 Q Which of the area monitors did you understand 5 would do that? 6 A Do what? 7 Q Which area monitors did you design to carry 8 out that function of providing alarms up through and 9 including a maximum hypothetical accident? 10 A That depends on the location of which 11 monitor you are talking ab o ut . 12 Q Well, I am asking what area monitors you 13 intended to satisfy that function. . g4 A The abnormal operations for accidents that 15 weren't less than the maximum hypothetical accident or 16 the maximum hypothetical accident. 17 Q The whole range starting at the small 18 accident and going up to the maximum hypothetical 19 accident? 20 A That's a speculative accident, dependent 91
~
upon the location of where the accident occurred in the k. 22 systems. t 23 Q Well, what monitors did you intend to e l l ( 24 satisfy that standard when you developed the radiation 25 monitoring set points?
l 1 Brummer 123 O 2 A The set points as developed were such that s 3 they would m'onitor an abnormal operation in the area 4 in which it was located and would provide a reading of ( 5 the dose rates in that area which could then be
- 6 analyzed for what was happening within the area.
7 Furthermore, if you will read the next 8 statement, which says the reactor building dome monitor 9 has sufficient range to record radiation levels inside 10 the reactor building following a maximum hypothetical 11 accident, that implies that that is the only one that's
~s 12 capable of doing that in the reactor building.
13 Q Was that your understanding before the 14 accident, that the 214 was the only one capable of 15 doing that? 16 A For a maximum hypothetical accident, that is 17 true. - 18 Q Before the accident, did you intend the 19 214 to have any role in providing information for 20 accidents that did not reach the point of a maximum 21 hypothetical accident? 22 A The design of the monitor with the 100-to-1 l i 23 attenuation on it had to be accounted for and, the re f o re ,l: 24 it would depend on the dose rates of the condition that 25 was resulting inside the reactor building.
1 Brummer 124 O 2 Q Well, my question is what area monitors 3 were designe'd and intended to tell you you had a LOCA? 4 A Once again, that's a speculative answer ( 5 based on the size of the LOCA and its location. 6 Q Well, you knew that there could be LOCAs of 7 different sizes, is that correct? 8 A That's correct. 9 Q What did you do in designing the radiation 10 monitoring system to take that fact int.o account? 11 A I didn't design the system. 3 12 Q What did you do in developing the set points 13 to take that fact into account? . 14 A I don't remember the analysis that I did 15 to get the 800 R per hour which is the set point for IG HP-R-214. 17 Q What did you do in connection with 18 developing any set point to take into account the fact 19 that there were LOCAs of different sizes? l 20 A We set the alert alarm set point for
-21 HP-R-214 at 34 RM per hour.
22 Q What number? ! l 23 A 2, the alert condition, which is 2.5 per ; l i () 24 I i hour inside the containment , accounting for the 100-to-1 l 25 i attenuation.
1 Brummer 123 (-
\ ~J 2 Q What was the purpose of doing that?
3 A If y u read the basis, it s ays ,"While the 4 reactor is operating, HP-R-214 is not relied upon for personnel protection. However, it may be used as ( 5 6 preliminary indication of radiation conditions in the 7 reactor building prior to any entry." 8 Q You are saying the alert set point was 9 intended to provide information in the form of an 10 alarm, an alert alarm in the case of a smaller LOCA? 11 A I am saying that the alert alarm set point 12 is set conservatively with respect to the high alert (- . . . 13 set point and would provide an earlier warning or 1,; indication of abnormal conditions in the reactor 15 building. 16 Q Was that alert alarm set point intended 17 to provide an alarm before the time of cladding or fuel , 18 damage? 1
. 19 A once again, to my krowledge the analysis l 20 was not done to show what alarm set point should be l 31 determined for that.
I (. 22 Q Will you look at page 52 of the set point l l 23 ! procedure which is the set point for monitor 227 , i l [ l ol particulate.
\_/ -
t i' 25 Did you develop the set point shown for the l
1 Brummer 126 2 227 particulate monitor? 3 A Yes. 4 Q Is this the set point that was in effect ( 5 on the day of the accident? 6 A Without having a procedure index to know 7 which revision of this procedure was in effect on the 8 day of the accident, I cannot answer the question. 9 MR. KATCOFF: Off the record. 10 (Discussion off the record)! , 11 MR. WURTZ: We will just mark, for the 12 record, chapter 12 of the FSAR that we discussed n U 13 earlier. , 14 (Chapter of the FSAR was marked B&W Exhibit 15 600 for identification, as of this date.) IG MR. WURTZ: Please mark as B&W Exhibit 601 17 Revision 9 of operating procedure 2405-1.12. 18 (Revision 9 of operating procedure 1205-1.12 19 marked B&W Exhibit 601 for identification, as of 20 this date.)
. 9
~1 l BY MR. WURTZ:
(_ 22 Q If you look on the front cover of that, do I i 23 you see page 52, the entry is May 4th, 1978, revision 24 No. 4? 25 A Yes, I see it now.
. _ . _ _ _ _ . , _ . . . . ~ . _ _ _ , _ . _ _ . _ - . . - - . . _ _ _ _. . , . . _ _ __
1 Brummer 127 C
> (
2 Q This document, Exhibit 601, is dated after 3 the time of the accident. Does it in fact contain the 4 same set point calculation that appears in Exhibit 5997 ({, 5 A Yes, it appears so. 6 MR. KATCOFF: Without proofreading? 7 THE WITNESS: Without proofreading. 8 Q Do you conclude from that that page 52 in 9 Exhibit 599 was in effect on the day of the accident? 10 A Yes, that would be a good 6onclusion. 11 Q Looking at Exhibit 599 at page 52 -- 12 A Yes. (~)/
\- 13 Q -- you have a sensitivity identified.
g4 Where did that sensitivity come from? 15 A The victoreen manual. 16 Q Could you find it in there? 17 A I have it. . 18 Q What page is it? 19 A Page 224. 20 , Q What number appears there? i 21 A The number that appears here, you go to the g3 curve and you read for strontium 90. The number that 23 appears is 5.3 times 10 to the 12th count per minute l 24 per microcurie per CC. 25 : Q 5.3 times 10 to the 12th? i
1 Brummer 128 (M V 2 A Yes. The note that goes along with this 3 curve says that " Note: Divide values by 10 for TMI II 4 moving tape particulate samplers with 843-2A detectors." ( 5 Therefore, you come up with a sensitivity of 5.3 times 6 10 to the plus 11 counts per minute per microcurie per 7 CC. 8 Q My next question is, the .28 krypton 88, 9 where did you get that figure from? 10 A I don't remember. E 11 Q What are the possibilities? C lo
~ A That would be speculative in nature.
/") N. J 13 Q No, I am asking you, since you did this, if 14 you can narrow this universe for me. 15 A I don't remember. 16 Q Is it a value you got from measuring the 17 coolant activity level at Unit 2? Did it.come from a 18 book? What is the source of it? 19 A And again I don't remember. 20 Q You can't even tell me that, whether it came og out of a book, whether it came from doing a test on the k_ 22 coolant or throwing a dart at the wall? What was your l 23 practice in doing this? This was in May of 1978. I i ( 24 A I don't remember. 25 Q How did you carry out the calculation that
1 Brummer 129 n 2 led to the high alarm set point here? s 3 A Do you want to go through the calculation? 4 I mean -- ( '5 Q Can you describe to me what you did here? 6 Yes. 7 A All right. We assumed that we had a one-8 gallon-per-minute reactor coolant leak at a 10th of a
.9 percent failed fuel, that the reactor boiling volume 10 of 5.95 times 10 to the 10th, let's sed., th at was --
11 CC's, cubic centimeters, in other words, so I took one s 12 gallon per minute times 63.3 cubic centimeters per (d 13 second per gallon per minute times 2.8.microcuries per 14 CC times 3.7 times 10 to the 4th -- 15 Q Just a minute. I don't want you to read 16 the document. I want you to take the three parts of 17 the calculation and tell me the reason you are doing 18 that, the objective you have in mind and why you are 10 applying these particular factors. 20 Do you understand what I am getting at? You 21 start out assuming one gallon a minute length at a tenth 22 of a percent failed fuel, and you arrive at a figure 23 in counts per minute that will give you an alarm? l l Q[~'s 24 A Yes. 25 Q Under those circumstances, is that correct?
1 Brummer 130 v 2 A That's correct. 3 Q What happens then? 4 A After I get the count per minute? ( 5 Q After you get the counts per minute based on 6 a leak of one gallon a minute at a 10th of a percent 7 failed fuel -- 8 A Right. 9 Q -- what do you do next? 10 A okay. Then I come up with'.-- that's not 11 a graduation you can read on the meter, so therefore I 12 set it more conservatively than that actual count rate, 13 which in this case was 5.274 times 10 to the 4th 14 counts pe r minute , so I elect to set it at 5 times 10 15 to the 4th counts per minute and that becomes the 16 set point. Then, to come up with the alert set point, 17 I take 50 percent of the high alarm set point. 18 Q Did you understand that this monitor was 19 required by the tech specs to detect a leak of a 20 gallon per minute? 21 A I do not remember the specific basis of the ! km f, 22 tech spec. , 23 . Q You don't remember whether this monitor was , r% l l (_) 24 l required to pick up a gallon-per-minute leak? I 25 A I don't remember the specific number of the
1 Brummer 131 4 2 basis of the tech spec as to'what size leak it was s 3 supposed to pick up. 4 Q Did you, in consulting Exhibit 596, look at ( 5 any information on this? 6 A No. I don't believe you will find it in 7 the tech spec. 8 MR. WURTZ: I would like to mark as Exhibit 9 602 pages 1047 and 1048 of the Unit 2 tech spec. Y i 10 (Pages 1047 and 1048 of the, Unit 2 tech 11 spec marked B&W Exhibit 602 for identification, i , 12 as of this date.) 13 Q Are you familiar with this _section of the 14 tech spec? 15 A I am now, yes. 16 Q Well, were you familiar with~it before the 17 accident? - 18 A Before the accident, yes. 19 Q Do you see there it states that the reactor 20 coolant system leakage shall be limited to, and then og subparagraph b., "1 GPM unidentified leakage"? 22 A Yes, I understand that. 23 Q And then down in the surveillance i l )- 24 l requirements on the same page, page 1047, using the l 25 microfilm number on the bottom, it states, " Reactor
~
1 Brummer 132
~
\
(~'/ N_ 2 coolant system leakages shall be demonstrated to be 3 within each of the above limits by: 4 "a. Monitoring the containment atmosphere ( 5 particulate radioactivity monito'r'at least once per T2 6 hours." 7 A Okay, g Q Is that the 227 monitor? 9 A That would have been 227, yes. 10 Q Does this particular page 6,f the tech spec 11 require monitoring of the 227 monitor to see whether the 12 leakage limits defined here are met? ('N *. t ! . 13 A The surveillance requirements states that l the" Reactor coolant system leakages shall be demonstrated 14 15 to be within the above limits by: a. Monitoring the 16 containment atmosphere particulate radioactivity 17 monitor." . 18 Q To sum up, does this particular page of the 19 tech spec say that every 12 hours you checked the 227 20 particulate monitor to see that there is not more than og one GMP unidentified leakage? no A Within the containment, that's the , 23 qualifying statement that must travel with that, because e's their monitor only monitors within the containment. I ( ) o4 x_ - 25 Q Did you understand that before the accident,
r i Brummer 133 (a3 2 that this monitor was to tell you when you had more 3 than 1 GPM unidentified leakage in the containment? 4 A That's what the alarm set point is based on. ( 5 g so you did understand that fact then? 6 A That's what the alarm set point is based on. 7 Q And in fact, it was your intent to have this 8 monitor go into high alarm when there was more than 9 one GPM unidentified leakage from the reactor coolant 10 system, is that correct? i 11 A That's the intent of the alarm response --
-s 12 the set point. That is correct.
13 Q Did you understand before the accident that 14 the coolant activity level would affect whether this 15 alarm went off at a point when there was a leak of one 16 gallon per minute from the reactor coolant system? 17 A That's factored into the alarm set point, 18 where it was based on a 10th of a percent failed fuel. 19 Q Did you understand before the accident that 20 if there was less than a 10th of a percent failed fuel, 91
- that that monitor would not alarm when there was a leak
(_ 22 of one gallon per minute? + 23 A I understand that the radiation monitoring ' i 24 system responds to activity in the reactor coolant 25 system and that th at is dependent upon whether you are
1 Brummer 134 n 2 going to get any reading at all from the monitor. 3 Q Did you understand that if the coolant 4 activity level in the actual coolant were below the ( 5 coolant activity level assumed in your set point 6 calculation, that the monitor would not pick up one 7 gallon per minute in leakage? 8 A Before continuing with the answer to that, 9 I would like to read the basis for this surveillance. 10 Q You can't answer that withkut reading the 11 tech spec? 12 A Well, I understand that the level -- the (~#')
^
13 activity level of the coolant system is directly related 14 to what this monitor is going to see based on a leak 15 rate. 16 Q Okay, that's all I am trying to establish. 17 You understood the principle that if the activity level 18 in the actual coolant were below the activity level
. 19 assumed in the calculation, then the monitor would not 20 show a gallon per minute of leakage just as a matter 21 of the operation of this principle.
22 A I understood that the set point which I 23 , developed was based on one-tenth of one percent failed . i /'] fuel, which implied a certain activity which is assumed \ / 24 ' l 25 here in the basis, the reactor coolant activity of
1 Brummer 135
%J 2 krypton 88 of .28 microcuries per CC.
3 Q If y u had a different activity level in the 4 actual coolant, then the monitor would not alarm at a ( 5 one-gallon-per-minuta leak rate if you had a lower 6 activity level than what you assumed in the calculation? 7 A I understand that the activity level in the 8 coolant is dependent upon what this monitor is going to 9 detect, given a leak, yes. 10 Q Did you, prior to the accident, from time to i 11 time check the actual coolant activity level to see 7s 12 whether it was in accordance with the assumptions made 13 in the calculation for establishing the high alarm g4 set point? 15 A I do not remember if I did that. I knew of , 16 the coolant activity based on my requirements to 17 participate in control room operation. - I t 18 MR. WURTZ: Could you read that back, 19 please? l 20 (Record read) 31 Q You mean you learned about the actual 22 activity levels in the coolant in the course of some i i 23 work you were doing? l i O(,/ 24 ; A Yes. 25 Q Could you explain how that came to happen? l t
t 1 Brummer 136 i
\~J / ,
2 A Standing or participating in operations in s 3 the control room, you are submitted the chemistry of the 4 reacto,r coolant system, which includes the gross beta, 5 the gamma readings in most cases, so therefore I knew j6 fof the activities of the coolant system. 7 Q Did you determine whether the actual 8[ _ coolant activity level was the.same as the coolant 9 setivity level assumed in the set point calculation
. t 10 for the 227 monitor? -
'll THE WITNESS: Could you read that question 12 , again, please.
v
, 13 (Record read) -
t I ' # 14 ,
+
A I,do not remember doing that.
... ,i , ,. i
- /j 15 ,
Q Do you know that you did not,do that? -r , _- x - >,4 y , 1
'/ , g 16 ), A No, I don't know -- I don't remember whether 1 :- ,
" ~
17 "I did'it o r n o ti . j, > 18 '
' ,, j g 'Af,ter the time this 227 particulate set point
/ ,
l, 19 n got pre' pared and approved in May of 1978, was there i ,, ,I I' 2DI ^ ' any Met .f G employee other than yourself who had ongoing t
,, . 'e 21 ,. responsibil'ity f5: reviewing or revising that set point?
l p i {
#2[o.,' A - # Not'to my knowledge.
.. ,jj. c i' .
[ A" yN1; d.h:/ fr.Q , Did yotr know before the accident that the { l
'J ;,. f *. .
l*
\,- .' :' / 24 l 227 mo'riitor was identified in the LOCA emergency
.. f t , _ l -[,',l ll_
m[ ! )<
' ?3 proceduf'e as e, symptom unique to a LOCA?
g* . n D' .
> f.
fb. -
+ ' '
1 Brummer 137 b v 2 MR. KATCOFF: I object to the question as 3 being outside the scope of the deposition. 4 Q You can answer. 5 MR. KATCOFF: You cannot answer. 6 MR. WURTZ: This was a question on the 7 radiation monitoring system. I don't see how you 8 can -- 9 MR. KATCOFF It is not a question on the 10 operation of the system. It's n$t a question 11 about operator system in response to readings. 12 MR. WURTZ: How can you operate the radiation O 13 monitoring system if you don't know that the 14 monitor is used in a LOCA procedure? How can you 15 know what to do with the radiation monitoring 16 system? i l 17 I am putting this question again. If you
?
l l 18 want to instruct him not to answer, you do that 19 on the record. 20 Will you read the question back, please.
*1
~ (Record read) 22 MR. KATCOFF: I object to the question and 23 I direct the witness not to answer. '
34 BY MR. WURTZ: 25 g Did you know before the accident that the i e - - - -
1 Brummer 138 2 227 monitor was in the LOCA procedure and that the 3 perators were trained to look at that monitor in 4 determining whether there was a LOCA in progress? (, 5 MR. KATCOFF: Again I object and direct the 6 witness not to answer. 7 Q 7 hen you developed the' set point for the 227 8 monitor, were you aware that the 227 monitor was a LOCA 9 symptom?' 10 A When I developed the set p51nt, the cet point 11 was based on a one-gallon-per-minute leak rate of the 12 reactor coolant system and that is stated in the basis 13 of 2105-1.12. 14 Q Did you understand that it was part of the 15 LOCA detection system? 16 A I understood that it was a means of 17 determining a reactor coolant system leak, given a specific activity of the coolant system, and that'it 18 i 19 would respond to it. . t 20 (Continued on next page) 21 l (. i 22 ,
}
23 i t 24 25 L
1 Brummer "139 \ 2 Q Did you understand that this monitor was 3 intended to go into alarm when a small LOCA occurred? 4 A I understood that this alarm set point was ( 5 based on the one-gallon-per-minute reactor coolant 6 system leak with a given percentage of failed fuel. 7 Q Was it your intent in developing the 8 set point for a high alarm on this monitor to have a 9 monitor go into alarm in the course of a small LOCA? 10 A It was my intent to have th,is monitor go 11 into alarm with the one-gallon-per-minute leak in 12 the reactor system with a tenth percent failed fuel.
) ' '/ 13 Did you understand that that would include Q
14 a situation where a small LOCA occurred? 15 A I understood that anything greater than 16 one-gallon-per-minute reactor coolant system leak 17 with a tenth of a percent failed fuel would cause 18 this monitor to go into alarm. 19 Q Do you recall any action of any kind that 20 you took before the accident to determine whether 21 this monitor would go into alarm in the case of a 22 one-gallon-per-minute leak given the actual coolant 23 activity levels at TMI-2? () 24 MR. KATCOFF: May I have the question 25 back, please.
1 Brummer 140 O V 2 (Record read.) s 3 A 'I do not remember. 4 MR. KATCOFF: Can we take a short break. ( 5 MR. WURTZ: Well, w
'e are not going to 6 keep going much longer.
7 MR. KATCOFF: Off the record. 8 (Discussion off the record.) 9 (Recess taken.) 10 BY MR. WURTZ: - 11 Q Mr. Brummer, I just want to clarify 12 something. (~h ' 13 Did you_ understand before the accident 14 that the tech spec required that the 227 particulate 15 monitor go into alarm when there was a one-gallon-per-16 minute leak from the reactor coolant system in the 17 containment building? - l 18 A I understand that by the words of the tech 19 spec, the " Reactor Coolant System leakages shall be 20 demonstrated to be within each of'the above limits. 21 which covers the one-gallon-a-minute limit inside the 22 reactor building, by " Monitoring the containment 23 atmosphere particulate radioactivity monitor at least I() 24 once per 12 hours." 25 Q Were you aware of that requirement at the
- , . . - , . - . . _ - - - - - . . ~ -- - .- -- - - - . , . - - - , ,-
l 1 Brummer 34 (~)^ v 2 time you prepared the set point for the 227 s 3 particulate' monitor? 4 A I do not -- I cannot exactly say that I ( '5 was aware of this particular requirement when the 6 set point was developed because I do not know when 7 the tech spec was issued. There is no issue date 8 on the tech spec. 9 Q Well, were you aware at the time you 10 developed the set point that there was'a requirement 11 that this monitor go into alarm when the reactor _ 12 coolant system had leakage in excess of one gallon G 13 a minute? _ 14 A What I stated before was the fact that 15 I am not sure that this tech spec limit (indicating) 16 was issued to Met Ed when the original set point 17 was generated. There was an issue date on the tech 18 specs which is not identified on these pages. 19 Q O. K. You mean you don't know whether 20 the tech spec was issued by May of 1978 when the 21 set point was calculated; is that it? The date is 22 May 19787 Page 52. - 23 A I was aware of the tech spec in May of 24 1978. 25 g Was it your intent in calculating,
1 Brummer 142 yb 2 in developing the set point for the 227 particulate 3 monitor to comply with the tech spec by having the 4 monitor go into alarm when leakage from the reactor ( 5 coolant system exceeded one gallon per minute? 6 MR. KATCOFF: May I have the question 7 back, please. 8 (Record read.) 9 A Once again, the basis states that the t 10 reactor -- the set point is based on a ,one-gallon-11 per-minute reactor coolant system leak at a tenth of ., 12 a percent failed fuel. And that anything in excess 13 of that would also cause it go into alarm. 14 Q That is the reason for my question. 15 Was it your intent to have it go into 16 alarm when leakage exceeded a gallon a minute or 17 was it your intent to have it go into alarm when 18 leakage exceeded a gallon a minute only if there was 19 also a tenth of a percent failed fuel? . 20 A The basis of the set point states that it 21 was one-gallon-per-minute leak rate at a tenth of a 22 percent failed fuel and I understand that the monitor 23 is dependent upon the activity of the reactor coolant b gj 24 system. l 25 Q Did you understand that the tech spec
1 Brummer 143 O U 2 applied only in the case when there was a tenth of 3 a percent failed fuel? 4 A The tech spec states that you have a (' 5 one-gallon-per-minute leak, the set point is based 6 on that, it is based on a tenth of a percent, and 7 I understand if you -- if the amount or the alarm 8 set point is also based on the activity of the 9 reactor coolant system that the assumption in 10 the alarm set point states that the re d,c to r coolant 11 level for krypton 88 activity would be .28 12 microcuries per CC. (~' .- 13 Q Did you understand before the accident 14 that the tech spec required that the 22 7 particulate 15 monitor go into alarm whenever leakage from the 16 reactor coolant system exceeded one gallon per minute 17 without respect to the coolant activity level even 18 in a circumstance where there is no failed fuel? 19 A I do not remember all the conditions under i i
- 20 which the one-gallon-per-minute tech spec limit was 21 applied for this set point.
km 22 Q Were you aware of any provision in the l 23 tech spec that limited the application of the one-i 24 gallon-per-minute leakage limit to situations where 25 you had a tenth of a percent failed fuel?
1 Brummer 144 I<~,i O 2 A I do not remember the basis for the tech 3 spec which we are dealing with, reactor coolant system 4 leak rate. ( 5 Q was it your understanding before the 6 accident when you prepared the set point for the 227 7 particulate monitor that the monitor was to go into 8 alarm whenever there was a one-gallon-per-minute 9 or greater leak from the reactor coolant system? 10 A I do not remember the -- I do not remember 11 the criteria by which the amount of activity in the 12 reactor coolant system was applied to the one-gallon-(~ .
\#
13 per-minute leak. . 14 Q Do you recall whether it was your objective 15 in developing this set point to have the monitor go 16 into alarm whenever leakage from the reactor coolant 17 system exceeded one gallon per minute? - 18 A The objective of this alarm is as 19 described in the basis where it would be detected of 20 one-gallon-per-minute reactor coolant leak at a tenth 21 of a percent failed fuel. 22 Q What I am trying to get is, is that 23 because you thought there was a tenth of a percent ( 24 failed fuel in the actual coolant? 25 A I don't remember the specific activity
1 Brummer 145
^
2 level of the coolant system for which this was 3 applied or looked at for, except that I know that the 4 activity of the coolant system is directly dependent ( 5 upon what this monitor is going to see. 6 Q so you understood it was important in 7 the calculation, the actual coolan t activity level? 8 A I understood that the coolant activity 9 level had to be considered and it was considered in I 10 this se t point. . 11 Q Now, you recall it was considered? 12 A It states it right here that the reactor 13 coolant activity for krypton 88 would be .28 14 microcuries per CC. That was the basis. That's what 15 I assumed. 16 Q Is that from the actual coolant activity, 17 the .287 - 18 MR. KATCOFF: He already testified to 19 that several times. 20 MR. WURTZ: He just testified that the 21 .28 was from the coolant and that is what I am 22 asking. 23 A I testified that that was the assumption.
? 24 Q O.'K. 's )-
25 , A O. K., and I am saying that it still is
1 Brummer 146 O 2 the assumption. I am saying I don't recall the point 3 where I got that from. 4 Q And I am asking you, was it your (, 5 objective to have that number reflect the actual 6 coolant activity level? 7 A For a tenth of a percent failed fuel, yes. 8 Q Was it your understanding that the 9 actual coolan t activity level was at the tenth of a 10 percent failed fuel level? ', 11 A It was my understanding that assumption f-12 had to be made based on a given activity level and 13 which was tied to a tenth of a percent. failed fuel 14 for this set point. 15 Q Well, let's try this again. 16 You understood that the actual coolant 17 activity level would affect the set point; is that 18 correct? 19 A I understood that the coolant activity 20 - level has a cirect effect on what the detector will 21 detect, yes. 22 Q Did you attempt in developing this set 23 point to reflect the actual coolant activity levels I)) 24 or did you just take an assumed value? 25 A I don't remember what I did. I know what
1 Brummer 147 A U 2 the basis says and that's what I have to go on right 3 now. 4 Q Apart from the words right here on the (, 5 page, you don't recall? 6 A That's correct. 7 Q Was it your purpose in developing the 8 set point to have it go into alarm whenever leakage 9 exceeded a gallon a minute? 10 MR. KATCOFF: Again, you have asked this 11 question about a dozen times. He answered the 12 question about a dozen times.
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I b 13 MR. WURTZ: You can see that is an 14 outstanding question here. I have to determine 15 whether the objective was to measure a j 16 gallon a minute'regardless of activity levels 17 or measure a gallon a minute only when there was 18 a tenth of a percent failed fuel, and that is j 19 the question. 20 MR. KATCOFF: You asked the question
. 21 several times and he answered it several times.
L 22 MR. WURTZ: I still don't belie ve I have 23 an answer so I think, you know, the easiest [J 24 way to go about this is to see if we can get 25 it clear and then it will be resolved.
1 Brummer 148 O 2 could you' read that question back, please. 3 (Record read.) 4 A It was my purpose as described in the ( 5 basis for this monitor that at one-gallon-per-minute 6 reactor coolant leak rate at a tenth of a percent 7 failed fuel, that the monitor would go into alarm, 8 and in fact, the set point is set more conservatively 9 than that, so at s o n.e fraction less than one percent -- 10 one gallon per minute, pardon me. . 11 Q Now, my question was, was it your purpose 12 to have it go into alarm whenever there was a O 13 gallon-per-minute of leakage from the reactor coolant 14 system? Can we agree that the tenth of a percent 15 failed fuel assumption effects that if the actual 16 coolant activity level is different? We can agree l l 17 on that? " 18 A I understand that. i 19 Q so what I am asking is, was it your l 20 objective here to pick up on this monitor 21 a gallon-per-minute or greater in leakage no matter 22 what the fuel activity level was, and it so happens 23 that you believed it was a ten th of a percent failed I i l (/ s- 24 fuel? ! 25 A And I am saying that based on coolant L
1 Brummer 149 {') v 2 activity, you have to assume something and I assumed 3 a tenth of a. percent failed fuel as discussed in the 4 basis (indicating). I do not know how to be more ( 5 clear. 6 Q Did you consider the possibility that you 7 did not have a tenth of a percent failed fuel in the 8 activity level in the coolant? 9 A I do not recall evaluating the activity t 10 of the coolant system to the tenth of a percent 11 failed fuel criteria. f~ 12 Q After you developed the set point and 13 went to the PORC and got it approved by the PORC, 14 did you believe that you had a set point in place 15 that would cause the 227 monitor to alarm whenever 16 leakage from the Unit 2 reactor coolant system exceeded 17 one gallon per minute? 18 A I Based on the basis of the set point, yes.
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19 Q You are saying only under circumstances l 20 where there was a tenth of a percent failed fuel? I t f . 21 A I am saying that that was an assumption l i Q 22 l made in the basis, which is based on the activity 23 level of the reactor coolant system and I do not 24 remember reviewing the activity level of the coolant 25 system to the tenth of a percent failed fuel criteria,
d i 1 Brummer .150
/
U 2 so that is where it is. s 3 Q so,as I understand it, you do not have 4 any recollection of your purpose apart from the i (, . 5 words you see on the set point page here; is that 6 correct? 7 A Apart from the basis, I do not recall 8 the considerations I made, that is true. 9 MR. WURTZ: We are five minutes past 10 our agreed-upon stopping point. *I would 11 like to ask you a couple of quick questions 12 about Exhibit 308. , 13 Q This exhibit you looked at.before. It 14 is the channel check data sheet for the 227 monitor 15 where the operator does a surveillance every shift.
- 16 What is the meaning of the sign-off 17 there in the box, do you know? -
18 A Which box do you mean? 19 Q Here across from the 227 particulate l 20 monitor, the third shift, somebody wrote the letters 1 21 SAT, and with the first and second shifts there is 22 just an arrow drawn down from a D on the top. 23 can you tell me what that indicates?
) 24 A I can't tell you what that D indicates 4
25 without looking at the entire submittal of this data
- m --m - -. _ . . , 4 -y. ..w.,e. . , ,.n., ..--m- .ym., ,,,,.-,e.,, -...~.,-,-p, , - - , , w y.m m ..% ,g.,pp,- w,-rw--, v
1 Brummer 151 ba 2 sheet. 3 Q What-was the operator supposed to record 4 in the box there? ( 5 A Whether the check source provided an 6 indication when the pushbutton was pushed. 7 Q And what was that supposed to tell you? 8 A It was supposed to tell you that the 9 detector was responding to radiation source, the check 10 source being a small source. e^ 11 Q Was it necessary to look at the background 12 first in doing this channel check? ("% 13 A I don't recall the specific step of the 14 procedure and the specific words, O. K. So, therefore, 15 I really can't answer that. I would have to read 16 the steps of the procedure to evaluate that. 17 Q In the case of a source check where you 18 push the button, is the button right on the ratemeter? 19 A Yes.
- 20 Q How big a source is it, how does it send 21 the meter?
22 A It depends on the detector itself and 23 i the actual physical geometry of the check source coming
) 24 out, how strong the solenoid is.
25 g In the case of the 227, is the check source i
1 Brummer 152 (~%
, )
sa 2 strong enough to put that monitor into alarm? 3 A 'I don't recall. 4 Q Well, on that monthly procedure that we ( 5 looked at before, you have to record that you have 6 an alarm; is that correct? 7 Q But that is using a simulated electronic 8 input, not the check source. 9 Q I see. That was my question. That is t 10 using some different source; is that right? 11 A That is using an electronic source into
12 the input circuitry for the detector.
13 Q I see. . 14 A As it comes into the ratemeter to give you 15 that response. That's not the check source reading. 16 MR. WURTZ: O. K. I guess we will 17 adjourn. ~ 18 MR. KATCOFF: I may have a couple of 19 questions. I would like to take a short break. 20 MR. WURTZ: I haven't finished my i 21 questioning yet. The deposition is adjourned. L, , 22 MR. KATCOFF: I thought you were finished i 23 alt o g e tt.e r . 24 MR. WURTZ: Well, no, I am not. 25 MR. KATCOFF: O. K. I will wait until l l \
1 Brummer 153 0 2 you are through, then. 3 MR. WURTZ: I suppose I could let you 4 question now if there is just something -- (, 5 MR. KATCOFF: I have at most two 4 6 questions. 7 MR. WURTZ: If you want -- 8 MR. KATCOFF: If you want to wait, we 9 will wait. E 10 MR. WURTZ: If you want to clear something 4 11 up, fine, but I want it understood I am not 12 finished. 13 MR. KATCOFF: Fine. 14 MR. WURTZ: You need a conference to do 15 it? 16 MR. KATCOFF: Yes, just for a minute. 17 MR. WURTZ: Well, O. K.
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18 (Recess taken.) 19 MR. KATCOFF: Off the record. 20 (Discussion off the record.) 21 MR. KATCOFF: I have no questions at this 22 time. 23 John A. Brummer g , Subscribed and sworn to before me s.,/ 24 this day of , 1982. 25
1 154 2 g E R T_ 1 E I E A_ T_ g 3 STATE OF NEW YORK )
- ss.:
4 COUNTY OF NEW YORK ) { 5 0 I, CHARLES SHAPIRO 3 a 7 Notary'Public within and for the State of New York, 8 do hereby certify that the foregoing deposition 9 of JOHN A. BRUMMER was taken before 10 me on Wednesday, March 10, 1982 ; 11 That the said witness was duly sworn 12 before the commencement of his testimony and b 13 thatthewithintranscripth.satruerecordofsaid 14 testimony; 15 That I am not connected by . blood or 1G marriage with.any of the parties herein nor 17 interested directly or indirectly in th6 matter in 18 controversy, nor am I in the employ of any of the 19 counsel. 20 IN WITNESS WHEREOF, I have hereunto set 21
't 6
{ my hand this !S day of O f'M. ' C ., 1982. 22 20
- tl l ri
( j '2a , U ,. C
- 1 li.fs Charles Shapiro, CSR 25
f 155 r8
!, I x/
I N D E X s WITNESS PAGE John A. Brummer 4 C' E XH I B I TS B&W FOR IDENTIFICATION 591 Two-page resume of' John Allen Brummer 4 592 Copy of multipage document, the first page entitled (~') " Operating Instructions
\/ For... Radiation Monitoring Systems" 48 593 Multipage document, first page bearing No. 2363-12-1, second page entitled "Three Mile Island Unit II, TWG, l Radiation Monitoring System Test (Liquid) " ' . 53 1 *
! 594 Copy of multipage document entitled " Radiation Monitoring i System Test-Atmospheric Monitors," bearing number TP 360/1A 55 595 Copy of multipage document I ( entitled " Radiation Monitoring l System Test-Area Monitors 57 l 596 Copy of multipage document entitled " Unit #2 f~'t
\- Sulveillance Procedure 2302-R3, Radiation Monitoring System" 59 l
1
f l l 1 l 156 Ch U INDEX TO EXHIBITS (continued) s B&W F O R~ IDENTIFICATION PAGE 597 Unit 2 Surveillance { Procedure 2303-M9, Revision 4, entitled " Containment Monitor - RMS Channel Functional Test" 66 598 - Definitions section of TMI tech spec 76 599 Unit 2 operating procedure 2105-1.12, " Radiation Monitoring System detpoints, Revision 6" 80 600 Chapter of the FASR 126 [) V 601 Revision 9 of opera ~ ting procedure 2105-1.12 126 602 Pages 1047 and 1048 of the Un'i t 2 tech spec 131 O e I O) t v I _ __ __ _ __}}