ML20072J143
| ML20072J143 | |
| Person / Time | |
|---|---|
| Site: | Three Mile Island  |
| Issue date: | 03/20/1981 |
| From: | Dunn B BABCOCK & WILCOX CO. |
| To: | |
| References | |
| TASK-*, TASK-06, TASK-07, TASK-6, TASK-7, TASK-GB NUDOCS 8306290958 | |
| Download: ML20072J143 (102) | |
Text
{{#Wiki_filter:_ _ _ _ _ _ _ - _ _ _ _ _ _ _ _ _ 500 /^ b) UNITED STATES DISTRICT COURT O I pt t SOUTHERN DISTRICT OF NEW YORK L Q1 " dot e __x GENERAL PUBLIC UTILITIES CORPORATION, ( JERSEY CENTRAL POWER & LIGHT COMPANY, METROPOLITAN EDISON COMPANY and : PENNSYLVANIA ELECTRIC COMPANY, Plaintiffs,
- 80 Civil 1683
-against- (R.O.)
THE BABCOCK & WILCOX COMPANY and J. RAY McDERMOTT & CO., INC., : e Defendants. :
---------------------------------------x U/ , Continu.ed deposition of the Babcock &
Wilcox Company, by BERT MERRIT DUNN, taken by plaintiffs pursuant to adjournment, at the offices of Kaye, Scholer, Fierman, Hays
& Handler, Esqs., 425 Park Avenue, New York, New York, on Friday, March 20, 1981, at 9:47 o' clock in the forenoon, before Charles Shapiro, a Certified Shorthand Reporter and Notary Public within and for the State of New York.
DOYLE REPORTING. I NC. CERT!FIED STENOTYPE REPCRTERS 369 t.zx:N GTO N AVCNUC 8306290958 810320 New Yo m <. N.Y. ICCt7 PDR ADOCK 05000289 T PDR Tct.gewo n g 212 - 867 8220
1 501
, O V' 2 App e aranc e s:
i 3 KAYE, SCHOLER, FIERMAN, HAYS & HANDLER, ESQS. 4 Attorneys for Plaintiffs 3 # 425 Park Avenue 5 New York, New York {. 6 By: RICHARD C. SELTZER, ESQ.
-and-
-7 ANDREW MacDONALD, ESQ.,
't of Counsel 8
9 DAVIS, POLK & WARDWELL, ESQS. 10 Attorneys for Defendants One Chase Manhattan Plaza i 11 New York, New York 12 By: ROBERT B. FISKE, ESQ. -
- i. > ,
-and .
J 13 RODMAN W. BENEDICT, ESQ., of Counsel i 14 15 l Also Present: 16 DAVID TAYLOR l 17 PATRICIA VAUGHAN ~ 18 19 20 21 * *
- 22 23
[] v 24 25
1 502 2 B ERT MERRI T DUN N, having 3 been previously duly sworn,' resumed and 4 testified further as follows: (' 5 EXAMINATION (continued) - 6 BY MR. SELTZER: 7 Q Mr. Dunh, you know that your testimony 8 today is again under oath, do you not? 9 A Yes. 10 Q Could you or your counse find a 11 copy of what we have marked as GPU Exhibit 96. 12 Approximately how long were you at
~
13 the 11 a.m. meeting on March 28, 1979? I know 14 you said you came in a little late. 15 A I am not sure. I think it was about a half 16 hour. 17 Q Was all of the attention at the 18 meeting for the half hour you were there devoted 19 to the Three Mile Island incident which was then 20' taking place? 21 A I believe so. 22 Q Who was doing most of the talking? 23 A Allen. 24 Q And that is Allen Womack? 25 A Yes.
1 Dunn 503 O7~ - 2 Q Was it he who was relating or relaying 3 what information was available from Three Mile 4 Island to the others in the room? ( 5 A That is my understanding. 6 Q If there was a two-phase condition 7 in the primary system, that would mean that the 8 primary system had hit the saturation point; 9 right? 10 A Yes. > 11 Q Bob Jones's notes indicate on the 12 second page of GPU Exhibit 96 marked for O 13 identification "Possible two-phase primary." 14 Do you see that notation? 15 A Yes. 16 Q Do you recall learning at any time 17 at or during the morning of March 26, 1979 that 18 there was a possibility of two-phase conditions i 19 existing in the primary system at Three Mile l 1 20 Island?
- 21 A I don't recall.
k 22 Q Do you recall receiving any 23 information which indicated that there might be () 24 saturation in the primary system? I am talking 25 about during the morning of March'28th. L
i i
\
\ >
1 Dunn 504
- a ON 2 A.
No, I do not recall.
~ >
s. 3 Q Do you see the indication in Bob 4 Jones's notes tdssolid hressurizer?
\
( ') 5 A Yes. I believe PRZ would' stand for t-. 6 pressurizer. 's , 7 Q A'nd PZR? 4 ,
+
8 A s' And PZR. 'N 9 Q D
,o you recall Allan Womack or anybody
/
10 else at the morning meeting relaying,information s - 11 to the effect that the pressuriser at Thr'ee Mile 12 Island war.' solid or had been solid? ,, CT 1
+
)
i L, 13 _ A At this time, I do not recall. t 14 , Q Since the .Three Mile Island accident,
- 15 have you ever reviewed with Bob Jones his notes 16 ,
which are GPU Exhibit 967 3
- 17 A other thhtn perhaps immediately after the .
I . 18 meeting, no, I don't believe so. l 19 Q Do you believe that immediately l i 20 after the meeting'you discussed the meeting 21 with Jones? 22 A I don't know one way or the other. 23 Q Is Jones somebody that you do a lot e-d 24 of work with? km 25 A Yes. , s
\
i .
\
1 Dunn 505 f -- O v 2 Q Is he your right-hand man in the 3 ECCS Unit? 4 A Yes. () 5 Q Do you write evaluations of the 6 performance of the people in your unit on a 7 periodic basis? 8 A I either write or review evaluations of 9 the performance of the people in the unit on a 10 yearly basis. , 11 Q I missed something. You either -- 12 A Write or review. f ) 13 - Q When you don't write but you review, 14 in what form do you review, or is the review 15 sometimes written also? 16 A No, the review is not written unless f l i 17 .there is a complaint about the evaluation. Then 18 the review might be written.
~
19 Q To whom is the review given? 20 A Generally the structure is that performance 21 evaluation is performed by the.immediate l - l 22 supervisor, so I would evaluate the people 23 reporting directly to me. My supervisors 24 evaluate the people reporting to them. l 25 In order to insure a continuity l l l
I Dunn 506 3 1 2 amongst the supervisors of performance evaluation, 3 I review each of the supervisor's evaluations 4 to make sure that what ~ evaluations are given to ( 5 a person by one supervisor are not overly 6 strict or stringent relative to what another 7 supervisor may be doing, or vice versa. 8 Q For how many years has Bob Jones 9 reported to you? 10 A In one position or another, approximately 11 eight, maybe nine, since he came with the company. 12 Q How have you rated his ability (R . \~ lj3 generally over the years? 14 MR. FISKE: Mr. Seltzer, I think if 15 you are getting into performance evaluations, 16 I think we are getting into an area that 17 at least we ought to have some discussion 18 about before we let Mr. Dunn answ'er these 19 questions. 20 MR. SELTZER: Where and when would
, 21 you like to discuss it?
w 22 MR. FISKE: Well, it just seems to 23 me that my understanding at least is that I~) \_/ 24 there is a legitimate reason not to allow 25 inquiry into personal evaluations and I am
1 Dunn 507 2 not prepared to cite you a line of cases 3 at this moment, but -- because this is 4 the first time this came up, but it seems ( 5 to me my position is not so unreasonable. 6 MR. SELTZER: Let me allay your 7 concerns if I can. I am not interested in 8 Burt Dunn's sexual proclivities or sexual 9 preferences, I am not interested in anything 10 that is not closely related tg his . 11 performance of work in the ECCS analysis 12 unit, and particularly his ability to I
\_/ 13 function on matters of importance in this I 14 litigation that is all.
i 15 MR. FISKE: I understand and I would i 16 assume that your inquiry would be related , 17 to his job performance. l 18 MR. SELTZER: Right. 19 MR. FISKE: Rather than other things. , 20 MR. SELTZER: I also won't tell Jones 21 what Mr. Dunn tells me. 22 MR. FISKE: Well, I am sure we would 23 all appreciate that, but I am not sure that 24 totally solves the problem.
}
. 25 I think what I would like to do with
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1 Dunn 508 2 this one is at least defer it. I am not 3 saying that I eventually won't let him 4 answer, but I think before we open up this ( 5 , whole area which obviously has broad l . 6 implications beyond this one question, it I 7 . seems to me that everyone is justified in 8 giving this some more thought. 9 MR. SELTZER: I disagree with what 10 you are saying and I will not defend your 11 right to say it either. I 12 I don't think that these pauses for (~'s k- 13 thought about the kinds of instructions l l 14 you give are really appropriate. I think -- 15 well, let me ask some questions that are 15 less global than the one I asked, and if 17 you feel you have to make an objection, 18 obviously you will make it. 19 MR. FISKE: Yes. I will make it j l 20 clear that I am not necessarily making this 21 as a permanent instruction, but I think 22 that this is an area where at least before 23 I allow Mr. Dunn to answer these questions () 24 and open this up, it is something that I 25 would like to consider and it has just come I
. . _ - _ , . = . _ _ _ . _ . . , - _ . _ .. .. . . . , _ , , _ . _ _ _ _ _ _ _ _ _ _ _ _ , _ _ _ . _ . _ . . . _ . _ . _ , _ _ _ . . . . . _ .
1 _Dunn 509 O 2 up at this point and that is the reason 3 for my position. And I do think it has 4 implications beyond Mr. Dunn and Mr. Jones. () 5 MR. SELTZER: Bob, I can empathize 6 with what you are going through, but i 4 7 I am sure that it has occurred to you that 8 you may want to ask Gary Miller, how did
; 9 he rate the performance of the control i
10 room operators prior to the Three Mile f a 11 Island accident, and it would not have l
, 12 occurred to me, and it still doesn't occur 13 to me, that it would be rational to block 14 examination of Gary Miller, the Manager of 15 Three Mile Island Station, on his reports
, 16 on the competency of the control room I 17 operators who were in the control room the I 18 day of the Three Mile Island accident. I i 19 just -- I would be surprised if you or your 20 partners or associates who were doing an ! 21 examination of our people don't get into
.I 22 those areas of examination, and I frankly 23 am a little surprised that you are even f~') %/
24 thinking you need to contemplate further l 25 my examining your witness on this same 1 w
1 Dunn 530 fm d 2 subject. 3 MR. FISKE: Well, I am not talking 4 about contemplating this any longer than () 5 perhaps the rest of the morning. So if 6 we decide to let this go forward, we will 7 certainly let it go forward today. 8 MR. SELTZER: Do you want to take the 9 witness outside and tell him what he can 10 and can't say? i 11 MR. FISKE: No, that is not the point. 12 It has nothing to do with talking to Mr. CE) - 13 Dunn. It is just a qu,estion of policy 14 as to whether we do or do not want to 15 take the position that would make personal 16 ratings a relevant line of inquiry in this 17 litigation. That is the simple issue 18 which involves, among other things, a 19 better understanding of the law than I have, 20 just sitting here at this moment, as to what 21 right we would have to object if we did 22 object, but before I just say "go ahead 23 and ask him," I would at least like to be () 24 sure that I am on firmer ground. 25 I may decide I have no foundation for
- p. s 1 Dunn 513
(~h
\- 2 this objection at all, in which case I 3 will tell you.
4 MR. SELTZER: O.K. Bob, I will 5 accept your offer then to let us know by the ( 6 end of the morning what your position.is on 7 this. 8 MR. FISKE: All right. 9 - MR. SELTZER: I would like to mark 10 for identification as GPU Exhibit 97 Mr. 11 Dunn's polygraphic notes entitled " Notes 12 on Wednesday & Thursday day of event." (O _) 13 (Handwritten notes of Mr'. Dunn, three 14 pages, was marked GPU Exhibit 97 for 15 identification, as of this date.) 16 Q Is GPU Exhibit 97 a copy of 17 handwritten notes which you created sometime 18 shortly after March 28, 19797 19 A It appears to be. 20 Q What was your purpose in creating 21 these notes? (_ > 22 A At the time I felt it might be useful l 23 for future purposes to have some small amount 24 of record of the events the first few days of 25 the Three Mile Island accident and jotted down
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1 Dunn 512 4
\./ 2 some short notes for that purpose.
3 Q Did you send these notes to anyone? 4 A I don't know. g 5 Q You referred yesterday and you also 6 refer in point 5 of GPU Exhibit 97 to someplace 7 called the war room. 8 Is that your designation or have 9 others at asw called it the war room? 10 A Yesterday I referred to a room in the 11 project management area of the building. 12 Others within the company use the () 13' tit 1e " war room" for that room. 14 MR. FISKE: Can I hear that answer, 15 please. I 16 (The reporter read the record.) 17 MR. FISKE: Excuse me one second. 18 Q Do you want to add to or change your
~
19 answer in any way? 20 A The term " war room" came about in 1975 i 21 or 1976 in that'it was created by the head of 22 project management as a project control center, 23 with some use in marketing, or at least it was l I 24 our understanding in Engineering it would have 25 some use in marketing our products and staying
1 Dunn 533 O 2 on top of the market, and to the distaste, I 3 think, of the project manager of project 4 management, the engineers in the building started ( 5 fondly referring to it as his war room or command 6 center. j 7 Q In the war room were there devices
- 8 or equipment hooked up or available on March 28, 4
9 1979 for recording conversations in the room? 10 A As I recall, there were small , tape 11 ' recorders of a dictaphone nature in place and 12 the telephone was connected to a loud speaker. O(_/ 13 As to how much those devices recorded 14 or how extensive their use was, I don't know. 15 Q Do you know whether any recording 16 was being done during the afternoon meeting on 17 March 28th, 1979 in the war room? r 1 18 A No. I know the devices were present. 19 Q Have you ever seen or do you believe 20 that there exists any notes of the March 28th 21 morning meeting, other than Bob Jones's notes? 22 A I have not seen other notes and I have no 23 basis for believing whether or not such notes f~) V 24 exist. 25 Q Did you take any notes at the morning _ _ ,- _ . . . _ _ _ . _ .., _ _. _ _ _ _ J n _ . . _ ___ _ . _ _ ___ _-
1 Dunn 534 O 2 meeting? 3 A No. 4 Q Were there any recording devices 5 present at the 11 a.m. meeting in Allen womack's ({' 6 office? 7 A Not that I recall. 8 Q Would you turn to the second page 9 of GPU Exhibit 97, please. 10 I am sorry. Since that begins in the 11 middle of a sentence, could you read what you 12 . have written in your handwriting beginning six (~h () 13 lines from the bottom of page 1 where it says 14 "About 10 to 30 seconds..." 15 A "About 10 to 30 seconds after this Lou 16 Cartin and I looked at each other and said super 17 heat. We immediately told management that we 18 were loosing and at one time had probably 19 uncovered the core. We asked for a charge rate of 20 around 400 gpm. And started explaining to
, 21 management how an uncovered core was consistent
- k. 22 with full pressurizer level."
23 Q could you go on, please. ['} 24 A " (Ko siba ) and many others about one-half V 25 hour later (enough time to seriously damage
f... l 1 Dunn 535 2 an undamaged core. Management decided to try and 3 tell TMI." 4 Q Thank you. I () 5 Is it correct that the "we" at the 6 bottom of page 1 when you say "we asked for a j 7 charge rate" refers to you and Lou cartin? 8 A That was the reference intended in writing l 9 these notes.
- 10 Q When you refer to a charge rate of 11 400 gpm, is that a requested rate of flow of 12 400 gallons per minutes from the high pressure (m/ 13 injection system?
14 A Yes. 15 Q When you refer to a half-hour later, 16 does that reference mean that approximately 17 half an hour later management decided to try and 18 tell people at Three Mile Island that it was 19 the recommendation of Babcock & Wilcox that 20 high pressure injection be on at a flow rate 21 around 400 gallons per minute? 22 A Yes. 23 Q In other words, about half an hour 24 after you and Lou cartin had asked for that 25 high pressure injection flow rate; is that the E
1 Dunn 516
- 0. 2 meaning of this?
3 A Approximately. 4 Q You say that when you and Lou Cartin ( 5 asked for a high pressure injection flow of 6 around 400 gallons per minute, you;" started 7 explaining to management how an uncovered core 8 was consistent with full pressurizer level." 9 Were there people in the room who 10 initially didn't understand or at least did not 11 appear to you to understand how "an uncovered 12 core was consistent with full pressurizer level"? 13 MR. FISKE: Well, Mr. Seltzer, I' l l 14 think you ought to ask him about the i l 15 conversation, who said what. 16 MR. SELTZER: He has already said 17 that it took half an hour to 40 minutes to 18 convince people that there was possible 19 super heat going on. He says here that 20 they started explaining how an uncovered 21 core was consistent with full pressurizer 22 level. 23 Q My question, Mr. Dunn, is: Are
. 24 there people who appeared initially not to 25 understand how an uncovered core was consistent
- _ _ _ _ . . - _ _ _ . - _ _-_ _. _ _ r ; _ _ _ _ _ _ _ _ --
1 Dunn 537 2 with full pressurizer level? 3 MR. FISKE: I will object to that. 4 MR. SELTZER: 0.K. ( 5 Q You may answer. 6 THE WITNESS: May I answer? 7 MR. FISKE: Yes. 8 I am going to object to the form of 9 the question. I think it is -- but go 10 ahead, if you can, answer it.e 11 I think it is improper avidence, but ] 12 I will allow it for discovery. ( 13 . MR. SELTZER: Thank you. I appreciate 14 that very much. 15 A I don't think today I can say whether 16 there were people that appeared not to understand 17 about the relationship of core uncovery and 18 the possibility of a full pressurizer level, 19 or wh'ather there were people that appeared not 20 to understand the meaning of super heat within f 21 the upper regions of the system and what that (! 22 meant relative to the amount of water that was 23 available to cool the core. t 24 I can say that we spent approximately c [-~)s 25 a half-hour explaining these relationships and
I f 1 Dunn 538
- 2 what must have been an approximation, happening 3 in the system at that time, to people, and that 4 Dick Kosiba was the first person that I remember i
5 understanding what I was saying. (( } 6 Q And you do recall testifying to the f 7 Rogovin Commission that it took you half an 8 hour to 40 minutes to convince the others in i j 9 the room that there was possible core uncovery? , 10 MR. FISKE: Where did he, say that? 11 Q Do you recall, referring to your 12 testimony at page 79, that it took you 13 approximately 40 minutes to convince others in l 14 the room that the Three Mile Island plant was in 15 trouble? 16 A I recall talking about thi.s area in both l 17 the Kemeny Commission and the Rogovin Commission i - 18 depositions. 19 Q At the time you gave the testimony 20 that you gave to those commissions, did you 21 believe that you were telling the truth? 22 A Yes. 23 Q And were you testifying to the best
/"' 24 - of your recollection to both of those commissions?
25 A Yes.
t 1 Dunn 539 O 2 Q what, as best you recall, did you 3 say to the management who were in the war room 4 to explain how an uncovered core was censistent (() 5 with full pressurizer level? 6 A well, I don't remember exactly what I 7 said. 8 Q In words or substance. 9 A I was using words and illustrating with 10 my hands how the levels of the fluid in the 11 reactor coolant system proper and in the 12 pressurizer could work as a function of the O. 13 overall hydrodynamics of a postulated event -- 14 Q overall hydrodynamics? 15 A Hydraulics. 16 Lou cartin at one. time drew a l 17 picture on the blackboard of the system in 18 cutaway and was doing essentially the same thing i
- 19 I was doing in words, putting postulated 1
20 positions on the blackboard for water and 21 illustrating how these positions could be 22 consistent with the configuration of the plant. 23 Q In the course of the explanations l () 24 that you and Lou cartin were giving, were you 25 describing to the people in the room how voiding i l .,_ , , - - - _ . _ , . . _ _ - , _ _ _ , , _ _ __ __ _ . . . _ , , _ , _ _ . - . , _ , . . , . . . _ . - _ , ~ . . _ _ .
1 Dunn 520 ('h
- 2 or steam formation in the primary system could 3 push water into the pressurizer?
4 A I don't recall one way or the other ( 5 talking about how the situation could happen. 6 I do recall illustrating how it 7 could be at least stable at a given time, how 8 it was consistent with the configuration that 9 these kind of situations could develop. I 10 Q For there to te an uncovered core l 1 11 and a full pressurizer, there would have to be 12 voiding in the primary systems right? s-) 13 A Yes. l 14 Q And at some point there would have 15 to be saturated conditions in the primary systems 16 right? 17 A Yes. 18 Q In fact there would be saturated 19 conditions. until all of the water had been boiled l 20 off into steam; right? 21 A Not necessarily. I 22 Q Would that generally be so in the 23 reactor vessel? 24 A There would be saturated conditions f~)h 25 somewhere within the system.
1 Dunn 521
=
}
2 Q would there be saturated conditions 3 in the reactor vessel until all of the water 4 in the vessel was boiled off?
)
l 5 A There would be saturated conditions -- 6 there would have to be saturated conditions 7 somewhere in the reactor vessel. 8 Q During the 30 to 40 minutes that you 9 and Lou cartin were explaining matters to 10 management, were you"and Lou getting any questions 11 from people in the room? 12 A Yes.
- 13 Q Who was asking the questions, as 14 best you can recall?
15 A well, you said any questions. i j 16 I was observing secondhand what Lou 17 was doing, so I should have responded with at 18 least I got questions. I got a question from 19 Dick Kosiba. I don't remember the question; I 20 remember giving the answer. ! 21 Q What was the answer? 1 l L 22 A The positioning of the water within the I 23 primary system and how these conditions made 24 sense. ( 25 Q Did anybody else ask you a question
I
. Dunn 522 g
2 or make a comment on what you were saying 3 during that half hour to 30 minutes? 4 A At this time I can't recall one way or the ( 5 other. - 6 Q Do you recall anybody in the room 7 making -- 8 A Excuse me. 9 Q Go ahead. 10 A Allen did ask me a question. , 11 Q what did Allen womack ask you? 12 A .In substance, to double-check and assure
~
, 13 myself that 400 gpm was the right number.
14 Q If you turn on the high pressure 15 injection pumps full bore at Three Mile Island, 16 they generate a thousand gpm; right? l 17 A It depends on the system pressure. 18 Q At the pressure that you we're hearing 19 about in the afternoon, what did you believe ! 20 they would be able to put out? 21' .A 4t this time I don't recall what pressure l 22 we were given. 23 Q Parks had told you after lunch that l 24 they were at 2,000 pounds. l 25 Do you know what flow the high
e 1 Dunn 523 1 2 pressure injection pumps could generate against 3 2,000 pounds back pressure? 4 A No. I would have to go to plant data to () 5 find out. - 6 Q when you and Lou asked for a charge 6
! 7 rate from high pressure injection of around 400 8 gallons per minute, whey didn't you recommend 9 just opening up the high pressure injection i
, 10 full throttle? ,
11 A I don't recall why we didn't recommend 12 opening it up full throttle. We did feel that s 13 400 was adequate to assure core coverage. 14 Q You didn't know what the level was 15 of the water in the primary system or what the 16 quantity of water was in the primary system at 17 the time you were making this recommendation, 18 did you? 19 A At that time I believed that the level 20 was then above the core. f 21 Q But you had taken half an hour to () 22 convince others in the room that there was super 23 heat and the plant was in serious trouble and (} 24 you yourself wrote that there was enough time 25 to seriously damage an undamaged core.
1 Dunn 524
'N 2 Did you consider changing your 3 recommendation during that half hour to open 4 the high pressure injection full bore instead
(. 5 of just to around 400 gpm-? 6 A No. 7 Q With a core that had been given 8 enough time to become seriously damaged, would 9 there be any reason for not recommending turning 10 the high pressure injection on full throttle? 9 11 MR. FISKE: I will object to the form
. 12 of that question. Mr. Seltzer, I don't (j 13 have any objection if you put the question 14 in terms of the time period.
15 MR. SELTZER: All right. 16 Q At the time the recommendation was 17 being made on March 28, 1979 with the telephone 18 call to Three Mile Island, in other words, after 19 the half hour which was enough time for the core 20 to become seriously damaged, was there any 21 r'eason for not recommending that they turn on 22 high pressure injection full throttle? 23 MR. FISKE: I object to the form of 24 the question.
~.> -
25 Q You may answer.
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_ - . - - = ._ - _ . ._ ( 1 Dunn 525 l 2 A At the time we were trying to have this be 3 our recommendation, I did not have any objection 4 to higher flows, s ({ ') , 5, Q You said that you and cartin did not 6 change your recomme.ndation from 400 gallons
- 7. per minute to anything greater before the phone 8 call was made.
3 Is there any information that you had 10 at the time the phone call was made ,that made 11 400 gallons per minute be a better charging rate 12 than full
- throttle? -
- 13 A Not that I can recall.
14 Q You said you didn't have any objection 15 to a recommendation for putting high pressure i 16 injection at full throttle. 17 Did anybody else in the room voice 18 any objection to recommending that Thre~e Mile i 19 Island have its high pressure injection pumps 20 on full throttle at that time? i 21 A Not that I recall. 22 Q- At the bottom of page 83 of your 23 Rogovin Commission testimony and the top of 24 page 84, you were asked at the top of 84 to (V") 25 place a time on the perceptions and conversations l .. . - - . . .-. . _ . _ - , . , , - - . . . - . - . . - - - . - - _ - -. . ~ . _ - - - - - - -- - - . . . - -
1 -- Dunn 526 2 that you had had. on the previous page, at line 3 4, you were asked: "1 tow , this was around somewhere 4 between, say, three and four o' clock in the ( 5 afternoon? . , 6 " Answer: Yes, right." 7 Now, turning back to page 83, you 8 said: "At that point in time I envisioned a 9 water level somewhere around the middle of the 10 core decreasing." ,, 11 Do you see that? 12 MR. FISKE: May I make a suggestion, n k_) 13 Mr. Seltzer? - 14 MR. SELTZER: Sure, absolutely. 15 MR. FISKE: Can we just take a 16 minute and permit Mr. Dunn to read all 17 of these pages concerning the incidents 18 at this meeting, from the beginning to the l 19 and, so that he has the whole thing in 20 perspective? I don't want to be critical
< 21 of you for picking out one question here km 22 or there.
23 MR. SELTZER: I am not taking it as criticism at all. ( 24 25 MR. FISKE: I think it would be useful.
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1 Dunn 527 U- 2 MR. SELTZER: I assumed that you and i 3 he had gone over this sentence by sentence 4 several times already. ({ 5 MR. FISKE: Well, it is certainly 6 true that Mr. Dunn has read this over 7 prior to appearing here for this deposition, 8 but now --
, 9 MR. SELTZER: Please do. I am just 10 being cute. ,
11 MR. FISKE Now that you are zeroing 12 in on specific sentences, I think he i
<m
_ ) 13 should be permitted to review this. 14 (Paus e . ) 15 THE WITNESS: O.K. 16 MR. FISKE: 0.K. Mr. Dunn has 17 completed his reading assignment. 18 Q Would you take a look at page 81, 19 please. 20 "During the afternoon meeting, you 21 testified that it was your perception that the 22 high pressure injection system at Three Mile 23 Island was throttled back considerably." 24 And your answer at line 7 was, "Yes." 25 were you asked that question and did l i
1 Dunn 528 O
\ /- 2 you give that answer?
3 A I have no reason to doubt that I did. 4 " Q You were asked, When did you become 5 aware of that?" (( 6 And you said, "At about the same time." 7 " Question: So that was part of that 8 same phone call at about three to 3:307 9 " Answer Yes." 10 Were you asked those que,stions and 11 did you give those answers? j 12 A I have no reason to doubt that I did. () 13 Q You then went on to say, at line 12, 14 "I did a quick Hewlett-Packard calculation." 15 I take it that is a free advertisement 16 for the pocket calculator that you were using 17 at the time. 18 - A It seems reasonable. - 19 Q You go on to say that you " requested 20 that they advance the charging rate to 400 21 gallons per minute." 22 " Question: So at that time you 23 recommended increasing the charging rate to _ (~T 24 400 gallons per minute?
.Q 25 " Answer: Yes."
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1 Dunn 529 U) 2 Does that mean that the charging 3 rate which was passed on or requested of the 4 people at Three Mile Island in the telephone (( 5 conversation with them at about three to 3:30 6 was 400 gallons per minute, to the best of your 7 recollection or as you see what you testified 8 to somewhat earlier? 9 A Excuse me, I think I presupposed a question. 10 I would like to have it read back. . 11 Q I will ask it again. 12 At the time of the phone convers'ation (1) - 13 'with the Island about three to 3:30, is it 14 correct that you have previously testified in 15 the pages that you have in front of you that 16 Three Mile Island increased the charging rate i 17 on high pressure injection'to 400 gallons per 18 minute? 19 A Is it correct that I previously testified 20 that Three Mile Island -- 21 Q I am just asking you -- 22 MR. FISKE: They recommended it. 23 MR. SELTZER: That's right. He () 24 has used " requested" in line 13, and 25 " recommended" is in the question on line 14.
1 Dunn 530 __ k- 2 MR. FISKE: Yes. 3 Q was it your testimony earlier in 4 response to questions by the Rogovin Commission 5 attorneys that you recommended over the telephone ( 6 that the rate of flow from the high pressure 7 injection be increased to 400 gallons per minute? 8 A No. I 9 Q was somebody else relaying your 10 recommendation over the telephone? ,
'11 A I made the recommendation to the room. It 12 was my understanding that that was eventually 13 relayed over the phone. '
14 Q Turning to page 83, do you see in 15 the last paragraph at the bottom of the page 16 where you say" "I mean'now that is where I was 17 at. At that point in time I envisioned a water 18 level somewhere around the middle of the core 19 decreasing." 20 Do you see that? 21 A Yes. 22 Q Dc you see on the next page, line 4, 23 where you were asked: "Now this was around 24 somewhere between, say, three and four o' clock 25 in the afternoon?
1 Dunn 531 (U 2 " Answer: Yes, right." 3 was that your testimony before the 4 Rogovin Commission? ( 5 A I have no reason to doubt that that was 6 my testimony before the Rogovin Commission. 7 Q Is it correct that at the time that 8 you envisioned the water level in the Three Mile 9 ' Island plant at around the middle-of the core 10 and decreasing, your recommendation was being 11 relayed to the Island to adjust the flow on the 12 high pressure injection to 400 gallons per minute? 3 ' 13 A Today I don't recall why I testified in . I 14 this fashion, and as to whether the timing was 15 at the same time or close, I don't believe I 16 can distinguish.
/
17 Q At the time you were explaining , 18 to management how an uncovered core was consistent 19 with a full pressurizer level, it is a fact, 20 is it not, that you believed that the Three Mile 21 Island core could be partially uncovered at the 22 time you were speaking; isn't that right? 23 A Could be uncovering or the water level could be decreasing to where it might start ( 24 25 uncovering.
~
, s J A + 7 s t.
I
}
, Dunn 532 2 Q At the tide that you were talking, j '3 x you didn't know'whether the core was approaching y ,
i e4 uncovery or par'tially uncovered already, did you? (j .f /- ' s 5 A we were under the impression at the time we received the informatio'n -- I believe we~
; ' 6t l
7 were under the impression'at the time we received
*o - ; y ,
8 the information.on the super heat that the core L l 9 was covered. i l
, 10 Q What information gase yciu that
; s ,
/r s 11 impression?
y
~l 12 A As I recall, we' wer told that'the; plant ; p -
e gV 4 s i, - 13 was letting water down, which means releasing
- 1. s 14 water from the reactor coolant system'--;I can't t
l 15 recall the term for the piping, but it is the
- e 16 piping normally used in the makeup mode to
'; i ?
t' . . 17 exchange water with'in the RCS, and I interpreted
, .j ,
i j 18 that'to $,ean that they had'to'havn' water at
.1 , ,
19 that time.in the nozzle belt' vicinity of the l e s 20 reactor vessel. > (% , 21 , Q ,w hen you,,said on page } of_your GPU 22
, Exhibit 97 memo that the haff-hour conversation m, \ > ;
z a 2j / or explanation was "enough time to > ser:iously
) ~ j'
~
i
~
.(, 24 damage an undamaged core," did you mean that the x-
, ,, p 7
25 , half h'our was enouch tine to partially uncover a i <
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. f i s #
1 Dunn 533
's 2 the core and cause damage to it?
3 A Yes, that given the right circumstances, 4 a half hour or 40 minutes could have been enough ({ 5 time for a core to have boiled to an extent where 6 a serious degree of core uncovery would occur. 7 Q Notwithstanding that, you don't know 8 any reason why you recommended only 400 gallons 9 per minute instead of full throttle in the high 10 pressure injection; is that your testimony? 11 MR. FISKE: I will object to the form i 12 of the question, but you can answer it. I r ( 13 A 400 gallons per m'inute would assure 14 turnaround of the process in that 400 gallons 15 was enough to absorb core decay heat without 16 forming steam so a positive increase in vessel 17 inventory would occur simultaneously with the 18 achieval of 400 gallons per minute. 19 other than that, I know of no reason 20 why I wouldn't have recommended full high pressure ! 21 injection. I (. 22 Q If the core were partially uncovered 23 by the time your instructions or recommendations (} 24 were communicated, wouldn't it have helped 25 re-cover the core faster if the charging rate
-m
. . . . ~
1 Dunn 534 f3
~
2 were higher? 3 A Yes. 4 Q Wouldn't that have been better for ( 5 the plant if the damage to the core had not 6 already been irretrievable? 7 MR. FISKE: Well, I object to the form 8 of that question. 9 I think you are now asking Mr. Dunn 10 to express an opinion on something that 11 involves a lot of other variables. The first 12 part of the question I don't have any I'h . . (m/' 13' . problem with, but the last part of it 4 14 I think is objectionable.
- 15 MR. SELTZER
- 0.K.
16 Q Based on just the knowledge that 17 you had or the belief that you had that possibly i ! 18 the core was uncovered to some partial extent, i 19 wouldn't it have been better to have a higher 20 charging rate to re-cover the core? 21 A Re-covery of the core would prceeed 22 faster if the charging rate were higher. We 23 felt that charging rate was adequate. O
> 24 Q What people from the morning meeting \_/
25 were also at the afternoon meeting at Lynchburg e _ . , ,,.--,r,,-,. -- , ,,.,y--- ..-.,v ,. - + - - __
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a 1 Dunn 535 2 on March 28th, 1979. 3 By the morning meeting, I mean the 4 meeting you attended at about 11 o'clo~k, c and ( 5 the afternoon meeting I am referring to is 6 the war room meeting. 7 A At least Allen Womack. 8 Q Anyone else? 9 A An answer as to someone else'would have 10 to be an expectation on my part. t 11 Q Whom else do you have an expectation 12 with respect to? y(~%') l 13 MR. FISKE: I don't think this is 14 particularly useful. 15 MR. SELTZER: Well, it is reasonable 16 calculated to lead to the discovery of 17 admissible evidence. We will ask these i ! 18 other people whether they were actually 1 19 there. 20 A I believe Bruce Karrasch was in the afternoon 21 meeting, and I cannot recall positively whether 22 or not he was in the 11 o' clock meeting. l 23 Q The 11 o' clock meeting was a meeting 24 for unit managers in the Design Section; right? 25 A Yes. l
1 Dunn 536 O d 2 Q And Bruce was a unit manager in the 3 Design section at that time? 4 A Yes. (. 5 Q Is there anybody else whom you 6 believe or expect was at both meetings? f 7 A Not that I recall. 8 Q Did Bob Jones come into the afternoon 9 meeting at all? 10 A I don't recall whether he came-in or not. . 11 Q Did you have a copy of Bob's notes 12 with you when you attended the afternoon meeting? l (~') -
\- 13 A I don't believe so.
i 14 Q Do you think Allen Womack had a 15 copy, to the best of your recollection, of Bob i 16 Jones's notes from the morning meeting? 17 A I have no idea. 18 Q Did anyone say anything at the 19 afternoon meeting which indicated that they 20 were having difficulty understanding how there l could be core uncovery with a full pressurizer? 21 22 A I testified earlier I didn't recall the 23 nature of the questions being asked or the one l l l s_ 24 question that I do remember, I do recall making l 25 explanations in that arena.
1 Dunn S37 O V 2 I take it it was your feeling at the Q 3 time that there were people in the room who were 4 in need of explanation in that area; is that ( 5 right? - 6 MR. FISKE: Well, I am going to 7 object to that unless you clarify what 8 you mean. I mean obviously -- 9 MR. SELTZER: Go ahead. 10 MR. FISKE: He obviously made an 11 explanation. 12 MR. SELTZER: Right. Now I am just (~)
\/ 13 taking what I think is a --
14 A Well, for whatever reason, I don't think
, 15 I like the way you phrased the question, in that i
16 it sounded slightly derogatory to me. 17 Q To you, no. I apologize if I sounded 18 that way at all. 19 & Derogatory to the others in the meeting. ! 20 I did give the explanation. i 21 Q Why did you give the explanation? 22 A Other than saying that I don't recall the 23 particular questions that were asked to any
; 24 extent further than I have already testified, s
25 the explanations were given. I have no reason to i
1 Dunn 538 i 2 doubt earlier testimony on the issue and the 3 answer as to why would be speculation. 4 Q Let me ask you, since you previously
\
({ 5 testified that you had difficulty convincing 6 other people in the room that the plant was in 7 trouble, was the explanation that you were 8 giving 0. bout the consistency between an uncovered 9 core and a full pressurizer part of what you 10 were doing to convince the others in the room
- 11. that the plant was in trouble?
12 - MR. FISKE: I think he said "could s/ 13 he in trouble," is the'way he mentioned 14 . that yesterday. 15 MR. SELTZER: Fine. 16 A It was part of the effort I was making to 17 get us to recommend increased charging by the 18 HPI system, the particular number in question 19 being 400 gpm. 20 Q I take it you were trying to convince 21 people that 400 gpm charging should be recommended 22 because you believed the plant could be in 23 trouble without that high pressure injection; () 24 isn't that right? 25 A Yes. I used the term " loosing." By that c -. . , - - . . - . . - . . . . - - - - . ,,,,,---,n., -.-,,--,-w.- .-+--,...-,--c-.,-.-m.
f I Dunn 539 O V 2 I meant that although it was my perception at 3 the time I heard the super heat information 4 that the core was covered, it did not appear ( .' 5 that short of some increase in the charging rate 6 that it would necessarily stay that way. 7 Q since March 28, 1979, have you sat 8 down with others from B&W and reviewed what was 9 happening at Lynchburg on March 28, 19797 10 A Yes. I 11 Q Have you done that more than ence? t 12 A Yes.
- 13 g When was the first time that you 14 did it?
15 A sometime within a few days of the accident. 16 Q When was the next time you did it? I 17 A I am not sure of the time of it,.the timing i 18 of it. 19 Q About when? 20 A The next recollection of such a discussion 21 could be any time within a couple of months. 22 Q When was the next time that you had 23 such a discussion?
) 24 A That I recall, it was in preparation for 25 the Kemeny commission.
l 1 Dunn 540 l'~~\ N.) 2 Q When is the next time? 3 A That I recall, it is the Kemeny Commission 4 deposition itself. l) 5 Q When thereafter? 6 A Preparation for the Rogovin deposition. 7 Q Why don't you continue and tell me 8 each subsequent discussion. 9 A The Rogovin deposition, and I believe in 10 discussions with Rudy Straub concerning the 11 nature of what type of response mechanism for 12 an accident like this should be created within O 13 B&W. 14 Q And you wrote Rudy a memo on that? 15 A I did write a memo on that. I don't 16 believe the memo discusses the events of the 17 day, though. 18 MR. FISKE: On the assumption that 19 you are now going to go through these 20 discussions one at a time, this might 21 be a convenient time to take a break. I 22 have to make a couple of calls. 23 MR. SELTZER: Sure. i ( 24 (Whereupon, a recess was taken.) 25
1 Dunn 542
/'T .
2 BY MR. SELTZER: 3 Q You said that you had participated 4 in a post mortem of activities in Lynchburg s ([] 5 on March 28, 1979; the first retrospective 6 analysis was within a few days of the accident. 7 with whom were you discussing 8 events on that occasion? 4 9 A Byron Nelson. 10 Q Is he the famous golfer?r 11 A No. 12 Q A different Byron Nelson? O U 13 A Yes. P Ml
- 14 Q Was anybody else present?
15 A No. 16 Q Why were you talking about it with 17 Mr. Nelson? . 18 A It was my understanding he was trying to 19 create some kind of record of what occurred 20 that day. 21 Q Did you write anything down for Byron 22 Nelson? 23 A During the meeting, no. () 24 Q Subsequently, did you? 25 A I am not sure. b
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1 Dunn 542 b(~\ 2 Q Do you believe you did? A No, I don't believe I did. 3 4 Q Who is Byron Nelson? ( ', 5 A At this time he was. head counsel for the 6 legal activities in contracts at the B&W office i 7 in Lynchburg. 8 Q was the conversation that you and 9 he had within a few days of the accident one 10 in which he was acting in his legal , capacity? 11 A I don't know. 12 Q What did you say to him, in words-13 or substance? 14 MR. FISKE: Well, I will ob. ject to 15 this conversation. I think this is clearly 16 a privileged communication. 17 Q Were you seeking any legal advice 18 from Nelson? 19 A No. 20 Q Yu said that within a couple of 21 m nths of the accident, you had another discussion 22 of the events at Lynchburg on the day of the 23 accident. 24 with whom was that discussion? 25 A I believe the discussion was with Allen.
. _ _ , - - . - - - -_ _- . ._----.-__r_ ._ : ::_ - - . - .
1 _ Dunn 543 b(~N 2 Was anybody else present? Q I 3 A I don't know. 4 Q Where was that conversation? ( 5 A I am not sure. It was at the old Forrest 6 Road building, j 7 Q About how long did you and Allen 8 Womack discuss the events of March 28, 1979? 9 A I don't believe I can recall. 10 ' Q As best youcanrecall,g.nwordsor 11 substance, what did you and Allen Womack say 12 to each other? (~/h
\- 13 A I don't Demember Allen's communication to 14 me during the meeting.
15 What I remember about it is that I 16 was communicating to him my feeling that if we 17 were going to have responses to accidents, where 18 we were going ~to serve that function, we ought 19 to rethink how we could do that, because I was 20 feeling that our capability of generating the 21 recommendation of 400 gpm had taken too long in
' 09 terms of the possible time frame of an accident.
i 23 Q Did you suggest to Allen Womack what
) 24 B&W could have done to come up with recommendations 25 faster on the day of the accident?
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1 Dunn 544
/~T \*.) 2 MR. FISKE: Could I hear that question, 3 please. .
4 (The reporter read the question.) ([ 5 A No. - 6 Q what, as best you can recall, did 7 you say to Allen womack about it having taken 8 too long to come up with a 400 gallon per minute 9 recommendation? 10 A Well, that or my opinion in that area, and 11 I was couching the discussion with a future
- 12 orientation.
- - 13 Q ,
Is there anything else you can recall 14 discussing with him on that very specific subject? 15 A No, no particulars. 16 MR. SELTZER: I would like to mark 17 for identification as GPU Exhibit 98 a 18 memorandum from Bert M. Dunn to Rudy 19 Straub, subject: Emergency Response t 20 Procedures Comments, April 23, 1980. 21 (Memorandum dated April 23, 1980, 22 to Rudy Straub from B. M. Dunn, was marked 23 GPU Exhibit 98 for identification, as of () ^ 24 this date.) 25 Q Is GPU Exhibit 98 a copy of a _ _ . _ . _ _ . _ _ _ _ _ . _ _ - . _ _ _ . _ _ _ __ ___ ..~_.-__, . _ __ _ ,. . ~ _ . ~ . . _ _ _ . _
a 4 1 Dunn 545 2 memorandum which you sent to Mr. Straub on or 3 about April 23, 19807 t 4 A Yes. l- (f 5 Q. Since April 23, 1980 has B&W 6 developed procedures and put procedures in place 7 for responding to emergencies? 8 A Since April 23rd, 1980? 9 Q Right. 10 A some procedures are in place. , 11 Q Are they procedures that were 12 formalized after April 23rd, 1980, .t o the best 13 of your knowledge? l 14 A The ones I recall were formalized to the 15 most extent before April 23rd. 16 Q Your first recommendation in GPU 17 Exhibit 98 was that the emergency response team
~
18 should consist -- in the first line -- of people 19 who are at lower levels within the B&W Company; 20 right? 21 I am sorry, I have confused two 22 different levels in that question. 23 Your recommendation was that the first people who would be contacted by a site ( 24 25 during an emergency and who would be making
1 Dunn 546 O
\'
2 recommendations to a site during an emergency 3 should be lower level people; is that right? 4 A I identify two phases for_the~ response 1 ( 5 to an accident, an early response, and suggest 6 that that team who would be active at that time 7 he made up of people who have an immediate and 8 intimate knowledge of the system, capable of 9 extrapolating to emergency conditions, and 10 suggest further that those are people who are 11 probably at a lower level in the organization
- 12 than those indicated in the respons'e organization s- 13 that I was reviewing at the time.
14 , Q I take it, for emergency response 15 there were people from what was the Plant Design 16 Section that would be called upon under the plan 17 that was proposed in the April 18th memo and l 18 in the proposal that you are making; is that i 19 right? 20 A Yes. l 21 Q What is the level of people from 22 the Plant Design Section that you felt it would 23 be appropriate to be involved in the first phase () 24 of an emergency response procedure? 25 A The level should really be explained in
1 Dunn ~ 547 n v 2
. terms of a sentence in the middle of the 3 paragraph in which I say that during this phase, 4 the early phase, I believe the response team l 5 should be organized out of individuals who have 6 the primary knowledge immediately available 7 within their craniums, within their heads, 8 and I would, in general, not expect that to be 9 a level above unit managers and, in some 10 circumstances, not unit managers. ',
i 11 Q Your second numbered paragraph 12 refers to people who would be receiving plant (:) 13 data during the emergency; is that right? - 14 A Yes. 15 Q Here again you thought that the 16 people that should be receiving the information 17 directly should be the lower level people who 18 would be performing the calculations and working 19 immediately with the data; is that right? 20 A I did not mean it to exclude the upper 21 level people, but rather that the data should 22 be available directly to the people performing 23 whatever calculations might be required.
) 24 Q In the third paragraph which appears 25 on the second page of GPU Exhibit 98 marked for
1 Dunn 548
'(\~'
2 identification, you refer to the present emergency 3 response organization. 4 Do you see that phrase? ( 5 A Yes. - 6 Q You say: "I believe, were we to 7 construct as an example, a problem with a plant 8 which would require strong diagnostic efforts 9 and issue this as a work order to the present 10 Emergency Response organization we would find 11 that organization ill equipped to provide i 12 assistance in a critical time frame. This O-N- 13 arganization would appear to trork best from day 14 two of the incident through closure as it did 15 during TMI. This organization was in place 16 during the morning of TMI and it worked extremely l 17 ineffectively for many reasons." . l 18 when you say "this organization was in 19 place during the morning of TMI," what organization 20 are you referring to? 21 A This would be secondhand information, but 22 at the time that I wrote this memo I was under 23 the impression that a team of people had been l 24 collected in the morning at B&W to deal with 25 the accident in some fashion at Three Mile Island.
, _ . _ . ... ._- . _ _ . - . _ _ ~ . . _ ,_ _ _ _ _ . . _ , _ _ _ _ . _ _ . . _
r 1 Dunn 549 D (G 2 I was not a member of the team and I really do 3 not know what they were trying to do or whether 4 they had information upon which to do anything.
-{) 5 Q You said that "this organization was 6 in place during the morning of TMI and it worked 7 extremely ineffectively for many reasons."
8 In what way did you feel, when you 9 wrote this, that the organization had worked 10 extremely ineffectively for many reasons? 11 A 'I do not want to testify to the accuracy 12 of the information, but at the time I wrote this n/ N- 13 line, I was under the belief that some 14 information about the accident was available to 15 those individuals and I had no information that l 16 they had been able to improve the situation at 17 Three Mile Island. 18 Q What do you mean, improve the 19 situation? 20 A I mean just that, that I can't tell you 21 what I -- what information they had, whether 22 they knew or not, for example, that the high 23 pressure injection had been terminated or was () 24 at that time terminated -- well, at least So it was a very general impression 25 ramped back.
1 Dunn 550 2 at the time I wrote the memo and could have been
-3 inaccurate.
4 Q You'say it worked ineffectively for l 5 many reasons. - 6 what reasons were you thinking of d 7 when you wrote this memo? 8 A I don't recall today. 9 Q As you reread your words today, 10 can you reconstruct any of the many geasons that 11 you believed the organization worked extremely , 12 ineffectively? O1 13 A No. 14 Q Did the organization that was in 15 place, as you understood it was in place on the 16 morning of the Three Mile Island accident, include 17 the lower level people who have primary knowledge 18 available within their heads? 19 A I don't-know who was involved in that team, 20' so.I can't answer your question. 21 Q Have you ever heard of any of the 22 lower level people that you would consider 23 appropriate people to be involved in the first 24 phase purportedly having been involved in the 25 emergency response organization that was in
, --, , ,- ,. . - . - - - - - - , , , , - - - . . , . - ~ ~ - - , . - , - . . - - . - - - - - - - - - - - - - - -
1 Dunn 553 (~T
%-) 2 place during the morning of the Three Mile 3 Island accident?
4 A No, not one way or the other. l 5 Q Do you know the name of anyone who 6 was part of the organization that was in place 7 during the morning of the Three Mile Island 8 accident? 9 A No. i 10 Q Do you have any belief as to who any 11 of the people were who were involved in that 12 organization? " (~h * (/ 13 A I believe that at one time I was told that 14- Bruce Karrasch was involved in it. 15 Q Anyone else? 16 A No. 17 Q Do you have any expectation as to 18 whom else was involved? 19 MR. FISKE: I will object. 20 Q You may answer. 21 MR. FISKE: I will object to the 22 form of the question. 23 A Yes. ) 24 Q Who? 25 A I would expect Don Hallman to have been
1 Dunn S52
% 2 involved.
3 Q Anyone else? 4 A No, I don't hold other expectations. ( 5 Q From what do you have the belief or 6 expectation that Hallman and Karrasch were 7 involved in the response team on the morning of 8 March 18, 19797 9 A For Mr. Hallman, because of his position 10 and because I believe he was involved intimately 11 in the afternoon sessions and following the 12 accident, throughout the day, and from the 13 response we gave to crystal River, which I recall 14 Don Hallman being in charge of the communications 15 to the plant. And Mr. Karrasch, because of the 16 statement I believe I was told, that he was 17 there. I 18 Q Do you have any belief or expectation I l 19 as to anybody else being invopved in,the morning 20 response organization? I 21 A No. I have a belief that there were more l -
- 22 people involved, but no expectation or belief 23 about who they were.
i 24 Q After you sent your memo, GPU Exhibit (s~)/ 25 98 marked for identification, did anybody who 4
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1 Dunn 553 r~ 2 received it ever discuss any aspect of it with 3 you? 4 A I discussed aspects of it with Rudy Straub 5 after that. (f 6 Q Did you discuss it with anyone else?
, 7 A Not that'I recall at this time.
8 Q What was Rudy Straub's reaction to 9 your memo, as he expressed it to you? 10 A The discussion that I had with Mr. Straub 11 centered around the possibility of utilizing 12 the computing facilities in Lynchburg for data (~h .
\_) 13 display. Mr. Straub was doubtful that a system 14 as I envisioned it could be put in place without 15 a great deal of investment, and I was trying to 16 convince him to remove that doubt and to explore 17 the possibilities, in that I did not feel such 18 a system would cost a tremendous amount of money 19 or effort to put in place.
20 Q Did you discuss with Rudy Straub 21 how the B&W organization had responded on the 22 day of the Three Mile Island accident? 23 A I do not recall.
) 24 Q Did anybody ever get back to you 25 in words after April 23, 1980 and tell you that
- ~
1 Dunn 554
.2 you were all wrong in saying that the organization 3 at B&W had worked extremely ineffectively on the 4 morning of the Three Mile Island accident?
{ 5 A No. 6 Q Did anybody get back to you and 7 say that you were in any way wrong in saying 8 that the organization that was in place during 9 the morning of the Three Mile Island accident 10 had worked extremely ineffectively? v 11 A No. 12 Q Did Don Hallman, whom you copied on ss/ 13 this memo, eyes.say anything to you about your 14 accusing the organization of having worked 15 extremely ineffectively? 16 A Not that I recall. 17 Q Did Allen Womack ever get back to you 18 and say that you were off base in accusing the 19 B&W organization of having worked extremely 20 ineffectively on the day of the accident? 21 A Not that I recall. 22 MR. SELTZER: I would like to mark 23 for identification as GPU Exhibit 99 Bert l ![) w/ 24 Dunn's memo to Jim Taylor, subject: .04 25 Squa,re Foot Pump Discharge Break Analysis,
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1 Dunn 555 2 dated April 14, 1978. 3 (Memo dated April 14, 1978, to J. 4 Taylor from Bert M. Dunn, was marked GPU 5 ( Exhibit 99 for identification, as of this 6 date.) 7 Q Is GPU Exhibit 99 a copy of a memo 8 you sent to Jim Taylor on or about April 14, 1978? 9 A Yes. 10 Q This refers to the same problem of 11 compliance with 50.46 for small breaks in the - 12 pump discharge line that we were discussing [\-') 13 yesterday; right? 14 A Yes. 15 Q Did someone in your unit prepare the 16 table that is attached to GPU Exhibit 99 marked 17 for identification? 18 A Yes. 19 Q was the table prepared at your 20 request? 21 A I don't know. 22 Q TMI-1 and TMI-2 are listed as plants
- 23 in the left-hand column of the table.
24 Do you see that? O.- N 25 A Yes.
- _ . , _ ~ _ _ . , . - ~ -
1 Dunn 556
/) 'J 2 Q What is the heading over the third 3 column? Could you read it, please.
4 A "Is current HPI acceptable." 5 Q What does that heading mean? (! 6 A For operation at the power levels indicated 7 in the second column as the current HPI system 8 flow rate acceptance point, 10 CFR 50.46, to 9 mitigate the accident. 10 Q And keep the core ef fectively cooled? 11 A To the requirements of 10 CFR 50.46, yes. 12 Q And the answer for all.of the type (~)
\_/ 13 177 plants that were then in operation were 14 lowered loops negatives right.
15 A Yes, although that answer would appear 16 to be wrong for Crystal River 3 and Midland 1 17 and 2. 18 Q You are saying that just because 19 those plants were not operating above zero power? 20 A Yes. ! 21 Q Do the percentages in the fourth ! (. 22 ! column mean that if Three Mile Island Unit 1 1 23 were constrained to operaterbelow 70 percent of f}
%)
24 full power, its high pressure injection system 25 would be able to operate in conformance with
1 Dunn 557 ( 2 10 CFR 50.46? 3 A Yes. 4 Q And similarly, if Three Mile Island 5 Unit 2 were constrained to operate at less than ({ 6 64 percent of full power, its high pressure 7 injection system would be able to function in 8 conformance with 10 CFR 50.46; right? 9 A Yes. 10 Q And above those power le,vels for 11 Units 1 and 2, the high pressure injection system 12 would not be able to meet the crite'ria of O k./ - 13 10 CFR 50.46 for effective mitigation of an 14 accident and effective core cooling; right? 15 A Yes. 16 Q What do the percentages in the sixth 17 column signify? 18 A Acceptable power levels envisione'd at
' 19 that time for the plants if the high pressure 20 injection system was cross-connected so that 21 four points of penetration for the ECCS would be 1 22 achieved in the event a single pump was operating.
23 Q Could that cross-connection be 24 either manual or automatic? 25 A I don't believe we refined the position one
1 Dunn - 558 O 2 way or the other on manual versus automatic 3 at the time we issued this memo. 4 Q What I meant was -- and maybe I ( 5 didn't phrase it as clearly as I was trying to. 6 The cross-coupling that you are referring to 7 there is a cross-coupling that for purposes of . 8 these percentages could be achieved either 9 through manual cross-coupling or through some 10 other automatic cross-coupling; is that right? 4 11 A Yes, that is correct. But I am not sure 12 we have truly explored at the time we wrote.the .i 13 memo the time constants associated with the manual-14 cross-coupling, and if they were long-time 15 constants, they would not be acceptable. 16 Q What does that mean? What do you 17 mean, if they were long-time constants? 18 A Well, to stretch the point to illustrate it, if 19 it took an hour to achieve the cross-coupling 20 of the high pressure injection system, I don't i 21 believe that these power levels would be (. 22 acceptable. 23 g so the percentages of full power () 24 which make the high pressure injection acceptable 25 depend on the speed with which the cross-coupling
i i Dunn 559 . (~)
~ (_/ 2 could be achieved?
A Y*** 3 4 Q Even if the cross-coupling is 5 achieved immediately, doe,s column 6 mean that ({ )
-6 at Three Mile Island Unit 2 the high pressure 7
injection would still not be able to comply g with 10 CFR 50.46 for operation above 93 percent I" P **#2 > 9 A No. 10 , e , , 13 Q What does that mean? 12 A It means that at the time that we wrote 13 this memo, we could not justify operation above -- l ! 14 we c uld not, in our opinion, justify operation l [ 15 above 93 percent power for that plant. 16 Q Did you since do any' analysis in--your l 1 17 unit that justified higher power levels?
~
i 18 A Yes. ig Q What power level did you justify? l E*# * " ' ' 20 i g Q Who did that work? L 22 A ECCS. Q Is there somebody in your section or 23
-- unit who is particularly familiar with those 24 25 ""*1Y"** '
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, '_ s Dunn 560 ,
2 *7 A Well, I am familiar with the analyses to r T f / 3 u an extent, Bob Jotie s','is familiar with them, 4 ' Q Whatfis the d a.f f e re n ca between the ( 5 analysis that produced the 93 percent figure 6 and the analysis that you say,has since pro [uced
~
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7 a 1'0 0 'p'e r c e n t figura? ' l 0 A ,The analysis th t produces the 93 percent
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9 figure is an extraholation/ based on previous
~
10 experience and our ovaluation at thit time of the r 11 .04 squaIe foot break. 4
' I2 The analysis which justified 100
,'N
[G 13 percent operation for.TMI-2 utilized improvements 14 in the basic evalastkion model and was a full 15 computerized simulati n of-a spectrum of small
- 16 break a
- :ea accidents.
17 MR. SELTZER: I would like.to mark l l 18 for identification as GPU Exhibit 100 a i 19 handwritten memo from Mr. Duns to Cliff s 20 Russell, subject: ECCS Small Break Analysis, 21 May 9, 1978. . 22 (Handwrittsn memo from Mr. Dunn to 23 Cliff Russell, dated 5/9/78, was marked O d 24 -' GPU Exhibit 100'for identification, as of 25 tilis date.) '
,, - , t 9 -q , , - - , - , , . . . .
1 Dunn 561 2 Q Is GPU Exhibit 100 a copy of a memo 3 that you sent to Cliff Russel on or about May 4 9,, 19787 i ({ 5 A I don't know. - j 6 Q Is that your "Bert M. Dunn" on the 7 second line? 8 A Yes. 9 Q Does it appear that the preposition 10 "from" and a colon is immediately to the left of-i 11 your-name? 12 A Yes. (- 13 MR. SELTZER: 'Would this be a good 14 time to have lunch? 15 MR. FISKE: My impression is that 16 it would be. 17 MR. SELTZER: All right. , 18 (Whereupon, at 1 30 p.m. a lunch 19 recess was taken.) 20
. 21 22 23 25
1
. 1 562 /~} *
(_/ 2 AFTERNOON SESSION 3 1:55 p.m. 4 BE RT ME RR I T DUNN, resumed. () 5 6 MR. SELTZER: We have resoled off the record the dispute we had this morning 7 over whether I can ask Mr. Dunn about his 8 evaluation of the performance of Bob Jones. 9 Mr. Fiske has advised me that he will 10 withdraw any objection to my p,ressing that 11 question. Is that right, Mr. Fiske? 12 MR. FISKE: Yes, that is correct, as 13 long as it is understood our allowing Mr. 14 Dunn to answer this question in this l 15 deposition is without prejudice to any 16 position we may or may not want to take 17 with respect to a similar inquiry later. 18 EXAMINATION (continued) ' 19 BY MR. SELTZER: 20 Q What is Bob Jones's principal area i 21 of expertise? l C. 22 A Loss-of-coolant accident evaluations. , 23 Q Have you reviewed and evaluated 24 Bob Jones's work in doing loss-of-coolant 25 accident evaluations?
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1 Dunn 563 O U 2 A Yes. 3 Q How have you rated his ability in 4 that area? A I have rated Bob with the highest possible ({ 5~ 6 rating within the B&W system. 7 Q Does that mean that you have given 8 him a 107 9 .A B&W uses a scale of 1 to 6. I.have given. 10 him a 6. ,. 11 Q Have you consistently rated him as 12 high as the scale goes, to the best of your
\ 13 recollection?
14 A Certainly I have done that since he -- I 15 became Unit Manager. 16 Q Does Bob Jones comprehend things l l ! 17 quickly? 18 A In my opinion. 19 Q In your opinion, what? 20 A He comprehends things quickly;
, 21 Q Does he think clearly?
I k-22 MR. FISKE: You know, Mr. Seltzer -- 23 Q From what you have observed? MR. FISKE: Mr. Seltzer, I am not ( 24 25 sure that I understand this particular
1 Dunn S64 f
2 line of questions. I assume you are not 3 talking now about some rating that Mr.
4 4 Dunn has given Mr. Jones, you are asking 5 ({ him a lot of genera 1 questions about Mr. 6 Jones, which I am not sure really can be 7 answered in the abstract. 8 MR. SELTZER: I am talking in terms 9 of the evaluations 'that Mr. Dunn has done , 10 of him, the formal evaluations, and the 11 consideration that has gone into those 12 formal evaluations. O' 13 What is the pending question? 14 MR. FISKE: I guess maybe you haven't 15 asked Mr. Dunn whether the questions you 16 are asking him are part of his formal 17 evaluation process. I would like to know 18 whether the questions you are ask'ing him 19 now are encompassed within the review that 20 led to this rating, or whether you are , 21 justing going off on some line of questioning 22 which is outside or different from that. 23 MR. SELTZER: Well, I think you are being constructive. ( ) 24 25 Q What does it take to get a perfect 6?
1 Dunn 565
/%
2 What qualities are embraced by the award of a 3 perfect 67 4 A I don't know that I have ever faced the i 5 issue of what it takes to get a perfect 6. 6 Q Are you an easy marker? Does
- 7 everybody get a6 from you?
8 A No. I am not an easy marker. 9 Q So that it is an indication of 10 significant approval and high estimation that 11 you have given a 6 to Bob Jones? 12 . A That is correct.
/" i ' '
A- 13 Q What are the qualities which 14 distinguish Jones, who gets a 6, from people 15 whom you have rated lower than a 67 16 A Extras in the performance of his duties, 17 things that are clearly above and beyond the 18 call of normal expectation.
, 19 Q What has he done beyond normal 20 expectations?
21 A Tc answer the question completely, I would L 22 want to review the documentation I provided 23 on his rating. [\
\- .
24 One representative possibility, which 25 is_ applicable to Bob, is that he is able to serve F
1 Dunn 566 A 2 very well as my replacement when I am involved 3 in travel or vacation. 4 Q when you return from travel or i 5 vacations, do you.sometimes sit down with Bob {i 6 Jones and review the work that he has done in 7 your absence? 8- A We would generally review the work that he 9 did in my absence, which was in the fashion 10 of work that I would normally do, with particular 11 attention to items which remained open and would 12 Tequire further action on my part. A k_ 13 Q Did I understand your prior answer _ 14 . to be that you felt he h$s handled situations 15 in your absence with a high degree of competence, 16 a very high degree of competence? 17 A Yes. 18 Q Did you think that he was able to 19 comprehend new situations that arose in your 1 20 absence well? 21 A Yes. C. 22 Q In GUP Exhibit 98 you recommended 23 that lower level people who had primary knowledge 6 24 immediately available within their brain should 25 be the first people to be on call at B&W when
1 Dunn 567 ( ) s_/ 2 there was an emergency at a B&W plant. 3 Do you recall that? 4 A Yes. 5 Is Bob Jones the kind of person that ( Q 6 you would recommend within that context be 7 available at B&W7 8 A Well, I don't think we have a proper 9 formulation for making a recommendation of 10 any individual in dront of us, but in a very 11 general response, I believe Bob Jones would be
- 12 the type of person or a person which we might -
~
~
%- 13 well recommend.
14 Q What do you mean, we don't have a 15 proper for'mulation? j 16 A We have a general idea of the kind of 17 people that ought to be there. We haven't 18 decided whether we are going to make these lower l 19 level people an express team which might be 20 extensively trained, we haven't decided whether i * , 21 we are going to try and pull them out of the 22 existing organization. The idea is not formulated 23 yet in that memo. i () 24 Q As of the date of the Three Mile 25 Island accident, did you believe that Bob Jones
1 Dunn 568 cm 2 was the kind of person who was well qualified 3 because of the primary knowledge immediately 4 available in his head to participate in a B&W 5 emergency response team? - {i 6 A Yes. 7 Q In the licensing analysis, if that is 8 a phrase that makes sense, that was done during 9 the years up through 1977, it is a fact, isn't 10 it, that one of the assumptions that was made 11 was that there was a loss of offsite power when ; 12 a transient occurred? - O 13 A No. 14 Q For what types of loss-of-coolant 15 accidents did you assume,as part of the design 16 basis,that there was a loss of offsite power? 17 A For those accidents in which a loss of 18 offsite power would be a more severe condition l 19 than a continuation of offsite power. 20 Q For small break loss-of-coolant l 21 accidents, was it considered conservative to 22 assume that there was a loss of offsite power? 23 A Yes.
) 24 Q In other words, it was thought that 25 more severe consequences followed from a loss
I Dunn 569 (D V 2 of offsite power at the same time that there was 3 a small break LOCA? 4 A Yes. 5 Did there come a point in time in ({ Q 6 1978 when ECCS analysis discovered that for 7 some small breaks it was nonconservative to 8 assume loss of offsite power? 9 A I don't think so. 10 Q Didn't you do analyses in 1978 that 11 demonstrated that for certain small breaks it 12 was not clear that leaving the reactor coolant FN -
\~s 13 pumps running resulted in an enhanced ECCS 14 situation?
15 MR. FISKE: Just read the question i 16 back, please. l 17 (The reporter read the record.) 18 A Again, I don't think that is what we did. 19 Q What was the evolution in ECCS 20 knowledge at B&W in 1978 regarding the pumps-01 running case? k_ 22 A In regards to recent considerations on pump I l 23 behavior during small break LOCA, and not pinning I~T 24 myself down to particular dates, we had been U) j 25 asked the question by other people, about the m + -- - -u e v -w - r -e
1 Dunn 570 2 condition of the reactor coolant pumps and 3 whether or not it was a worse case to assume 4 that they were off or on, and because our I ({- 5 decisions in the area were basically subjective, 6 we did do an evaluation of a pumps-running 7 small break loss-of-coolant accident, which 8 verified our position that pumps off would be the 9 appropriate basis upon which to perform licensing 10 calculations. , 11 Several months after that, following 12 the TMI accident, it was discovered *that the A (_) 13 timing of a loss of offsite power, f.or example, 14 or any other mode or action which could terminate 15 the function of the reactor coolant pumps 16 would be more conservative if placed some time 17 into the accident. 18 Q In other words, the worst case for 19 certain small breaks was one in which the reactor 20 coolant pumps continued to operator for some 21 time into an accident and then were shut off; k 22 is that correct?
~
23 A Given the analytical techniques available 24 at the time and the analytical techniques 25 available today, yes.
I Dunn 572 ('h 2 what in the phrase " void fraction"? 3 A " Void fraction" is a term used to express 4 the volumetric ratio of steam content versus 5 liquid water content, the fraction is expressed (( 6 as the percentage or literal fraction of steam 7 in a fixed volume over the fixed volume. 8 Q Is it correct that your ECCS Analysis 9 Unit has studied the ability of a core to 10 remain effectively cooled with a combination of 11 reactor coolant pumps running and high void - l 12 fractions? 13 ,A Yes. l 14 Q When was that analysis or study done? 15 A I don't recall all of it. 16 Q You don't recall what? ( 17 A All of it.
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18 Q When is the earliest that you recall 19 any portion of it being done? 20 A The first explicit evaluation that I can 21 recall at this time was an evaluation of a core L 22 floodline break performed in 1972 or 1973. Now, l 23 it had high flows but did not involve the status l l( 24 of the reactor coolant pumps. It had high 25 flows for -- in the core and high void fraction l
. _ - - - . _ _ , , . _ _ r: . _-
1 Dunn 573 m U 2 cooled acceptably. 3 Q What is the earliest that you can 4 recall any study being done at B&W of the 5 ability of the reactor coolant pumps to maintain (( i 6 effecitva cooling of the core with high void 7 fractions? 8 A I think we should draw a differentiation 9 between reaching an assumption or reaching a 10 conclusion in a study, and that a study may 11 indicate specific computer analysis rather 12 than the generation of opinions. O kl 13 The one I recall today that would 14 be in the form of a study on the subject is the 15 work in -- I believe, in later '78. 16 Q Who did that study? 17 A I believe it was Mr. Nehru Shah. 1 l 18 Is he in your_ unit? Q 19 A Yes. Well, he was at that time. 20 Q Were there analyses that had been 21 done earlier that evaluated this phenomenon or 22 question? In other words, were there analyses 23 that had been done before the Nehru Shah study () 24 that resulted in the generation of some 25 information on the ability of the core to remain l -_ -. . _ _ _ . _ - . . .
1 Dunn 574 ' O 2 effectively cooled with high void fraction and 3 pumps running, even if that wasn't the purpose 4 or focus of the study? 5 ({ A, well, I mentioned the earlier evaluation 6 on the core floodline break. 7 g . Yes, but you said the pumps weren't 8 running. 9 A No, but it indicated high flows and high 10 void fraction would create acceptable core 11 cooling, and then, or in addition, experimental 12 information on the performance of pumps in voided 13 situations, which indicate that the pumps will l 14 generate such flows. 15 Q Who did that work on pumps? 16 A The first work in the area was derived from l l 17 a textbook on pump performance. The second piece ! 18 of work in the area was the work by, I believe it l l l 19 was Idaho Nuclear at that time -- I could be l 20 wrong on that -- in which the semi-scale facility 21 pumps were tested in flow regimes varying 22 from solid water to ste 23 Later,B armed similar 24 experiments at the B. ? ump Company in 25 Portland, Oregon, and Comoustion Engineering has
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1 Dunn 575 m; 2 since performed similar experiments under an 3 EPRI contract. 4 Q when did B&W perform the Bingham (, 5 Pump tests? - 6 A I don't recall. 7 Q Before the Three Mile Island 8 accident? 9 A Yes. 10 Q Years before it? , 11 A That would be my expectation. 12 Q Have you seen a report of the Bingham n ts,) 13 Pump tests? - 14 A Yes. 15 Q Did they show the ability of reactor 16 coolant pumps to keep on pumping with high void 17 fractions?. i 18 A Yes. 19 Q How would you go about finding that 20 report if you were back at Old Forrest Road? 21 A I would ask Joe Cudling. 22 Q What unit is Joe in? t 23 A Joe is the Unit Manager of Systems 24 Analysis Technology. 25 Q Systems Analysis Technology?
1 Dunn 576 m
- 2 A Yes.
3 Q Do you have a copy of the textbook 4 that discusses the ability of pumps to keep 5 running with high void fractions? ({ 6 A I don't think so. 7 Q From the reports and analyses done, 8 what is the highest void fraction at which 9 reactor coolant pumps can keep on pumping and 10 the core continue to be effectively , cooled? 11 A 100 percent. 12 Q How long can a Babcock & Wilcox
<n . .
(_) 13 177-FA plant's reactor coolant pumps continue , 14 pumping without failure with void fractions in 15 the neighborhood of 95 to 98 percent? 16 MR. FISKE: You mean how long will 17 the pumps keep working? l 18 MR. SELTZER: Right. 19 A I don't believe the answer would be unique. I 20 The pumps are not manufactured by B&W3 they i ! 21 are purchased from at least three vendors, I ( . 22 believe. l 23 I have been told that they will 24 continue to function for an extended period of 25 time. The actual answer should be obtained from
i 1 Dunn 577 , i 2 our pump experts. 3 Q When you say "an extended period of 4 time," what is an order of magnitude that you 5 are thinking of as you say that? (( i 6 MR. FISKE: You mean that he has 7 been told? 8 MR. SELTZER: I just am trying to 9 understand his last answer. 10 A Provided that certain coolant water is 11 provided to the pump -- I believe the term is 12 component cooling water -- and it is unclear on A k- 13 the need for seal injection in my mind at this 14 time, we are talking about times expressed in 15 days, to my understanding. 16 Q Is the seal injection injection of l l 17 oil to lubricate the seal? 18 A It is my understanding it is water. 19 Q What is the source of the water for 20 component cooling of the reacto'r coolant pumps? 21 A I do not know. l 22 Q Is it a reservoir that is distinct I 23 from the primary coolant system?
.() 24 A It is not the reactor coolant system.
25 Q That is what I meant.
~
1
1 Dunn 578 2 A In the form of a vessel, the various major 3 pipes, steam generators, et cetera. 4 Q So it is not either the primary loop 5 or the secondary loop that is supplying water. (( )
! 6 to cool the reactor coolant pump, right, to the 7 best of your knowledge? i 8 A I don't believe it is the secondary loop 9 either, but it is not the primary loop.
*10 Q So there is some independent system 11 that supplies cooling water to keep the reactor 12 coolant pumps cool and functioning; is that your I
13 understanding? - 14 A That is my understanding. 15 Q And is it also your understanding 16 that there is a source of water that cools the I 17 seals on the reactor coolant pumps that is 18 independent of the primary coolant system and 19 the secondary system? 20 A Independent of the primary system. 21 Q You don't know whether it is 22 independent of the secondary system? 23 A No, I don't. l 24 Q When did you first learn that the 25 reactor coolant pumps could run for days with l r n : rrn _ _ _ . . _ , _ , . _ _ . _ _
1 Dunn 579 ((' 2 void fractions in excess of 95 percent? 3 A I don't recall. 4 Q Is it something that you came to 5 know before the Three Mile Island accident? ( 6 MR. FISKE: I will just object to 7 the form of the question. 8 A I had that conclusion before the Three Mile 9 Island accident. 10 Q. Is that a conclusion tha,t you had 11 years before the Three Mile Island accident? 12 A I believe so. ((~/'s . _ 13 Q Prior to the Three Mile Island 14 accident, did you have any participation in the 15 development of draft procedures for the operation 16 of B&W nuclear plants? 17 A No. 18 Q Did you or your unit review any of 19 the procedures being drafted by B&W prior to the 20 Three Mile Island accident? 21 A Not that I recall. 22 Q To your knowledge, was there any 23 transfer of the work and knowledge of your unit f; v 24 into the procedures being drafted by B&W for 25 the operation of its nuclear plants?
1 Dunn 580 ('d
\
2 A I don't know one way or the other, without 3 speculation. 4 Q As you sit here, you don't have any ( 5 knowledge of such transfer of information; is 6 that right? 7 A Prior to the Three Mile Island? i 8 Q Right. 9 A Yes, I do'not know or have any knowledge 10 of such transfer, as to whether it occurred or 11 not. 12 - Have you ever discussed with anyone Q (~'N * *
) * .
13 whe'ther it would have been advantageous for 14 B&W to have had more input from ECCS Analysis 15 in drafting procedures prior to the Three Mile 16 Island accident? l 17 MR. FISKE: Can I hear that question 18 again, please. 19 (The reporter read the question.) 20 A I don't recall having such discussions. 21 Q Have you ever written to anybody or 22 received anything in writing from anyone else 23 which stated in words or substance that more (~b 24 input from ECCS Analysis into the drafting of () 25 procedures would have been advisable or beneficial
y Dunn 581
!O .C/ 2 Prior to the Three Mile Island accident?
A No, I don't think I can say yes to that. 4 Q Do you think you could say no to it? A As y expressed the question, I think I 5 6
# " '"Y "
- 7 Q Other than the occasional lectures 8
w i h you or others from your group sometimes gave in the training program prior to the Three 10 Mile Island accident, did your unit have any 11 ther input into training or procedures for 12 . B&W nuclear plants that you know of? 13 A Now, you would have to ask the people who wrote those draft procedures where they obtained their input, other than my efforts on HPI 15 management out of Davis-Besce of course, g7 Q But prior to the Three Mile Island 18 accident, those efforts never found their way i 19 int any Procedures or training, did they? A To my knowledge, no. 20 g Q You would have vanted them to have l g found their way into procedures and training, 23 * "10" D 7 "? A well, I wanted to assure myself on the methods for controlling HPI, and if that meant
1 Dunn 582 (~
\~' 2 they should find their way into procedures, yes.
3 Q Your unit, prior to the Three Mile 4 Island accident, had been doing analysis on the ([ 5 performance of emergency core cooling systems: 6 right? 7 A Yes. 8 Q Was your unit the principal place 9 within Babcock & Wilcox where analysis of the 10 performance of emergency core cooling systems 4 11 was being done? 12 A I would think so. n(_/ 13 Q Your unit had within it mei'e ' 14 knowledge about how to cool a core following a 15 loss-of-coulant accident than any other unit i 16 within B&Ws isn't that right? 17 A I don't know. 18 Do you know o.f any other area within Q L 19 B&W where there was greater knowledge about how , 20 to cool a core following a loss-of-coolant 1 21 accident? 22 A No. 23 Q Prior to the Three Mile Island 24 accident, no one came to you and said, in words ( 25 or substance, "Mr. Dunn, we would like you and
1 Dunn 583 p V 2 your unit to review whether the procedures 3 that we have for cooling the core following a 4 loss-of-coolant accident are appropriate 1 procedures"; is that right? ({ 5 6 A To the best of my recollection, yes. 7 Q It is also a fact, is it not, that 8 prior to the Three Mile Island accident no one 9 came to you and said, in words or substance, 10 "Mr. Dunn, we would like you or your unit to I 11 review the training which we are giving operators 12 to see if we are giving them proper training O 15 on emergency cpoling of the core following a
~
. 14 loss-of-coolant accident"; is that correct?
15 A As I recall it today, that is correct. 16 MR. SELTZER: Can we take a short 17 recess. , 18 MR. FISKE: Sure. 19 Lwhereupon, a recess was taken.) 20 BY MR. SELTZER: 21 Q You are familiar, are you not, with 22 WASH-1400, Professor Rasmussen's reactor safety 23 study, are you not? () 24 A I know of it. 25 Q Had you heard of it before the Three
i Dunn 584 2 Mile Island accident? 3 4 Q Had your-unit ever made any use of ( 5 it prior to the Three Mil,e Island accident? A Not to my knowledge. 6 7 Q Had you participated in any discussions 8 pri r to the Three Mile Island accident in which 9 the WASH-1400 was p2rt of the conversation? . 10 A I don't recall any at B&W. , , 11 Q Where had you participated in any 12 such discussion? . . 13 'A I went to a local"American Nuclear
- 14 S ciety meeting in which the presentation l
15 e nearned the probability of a nuclear accident, 16 and a lot of the source information that the g7 presentator used, he made reference to WASH-1400. 18 Q When was that.ANS meeting?- 19 A I don't really recall. I believe it was 20 before Three Mile Island. 21 Q Has it ever been pointed out to you L 22 in nversation or in writing the extent to 23 which the WASH-1400 report predicted the Three 24 Mile Island accident? A No. 25
, 1 Dunn 585 2 Q Are you aware that the WASH-1400 3 report discusses the probability of a pilot 4 operated relief valve failing open?
5 A No. r {l - 6 Q Are you aware that the WASH-1400 7 report discussed the probability of all 8 auxilliary feedwater being valved out? 9 A No. 10 Q Is this the first time you have heard 11 .that either of those subjects is discussed in 12 WASH-1400? 0 . 13 A I don't know. 14 Q Do you know what an event tree is? 15 A Generally. 16 Q Since the Three Mile Island accident, 17 has your unit used event tree logic in. analyzing 18 loss-of-coolant accidents? 19 A No. 20 Q Have you used fault tree analysis 21 since the Three Mile Island accident? 22 MR. FISKE: F-a-u-1-t, fault tree? 23 MR. SELTZER: Right. () 24 A I don't believe so. 25 Q Are you telling me your unit does not
1 Dunn 586 2 study the alternative courses which a transient 3 can take? 4 A No. I am telling you that I think you asked ({ 5 for whether we applied specific techniques 6 which we could call one of those. We have 7 evaluated alternate courses for loss-of-coolant 8 accidents. If we unconsciously used one of those 9 techniques, that is fine. 10 Q Maybe we are hung up onna semantic 11 distinction that is getting in our way. 12 what do you understand fault tree (~h . () 13 or event tree analysis to be? 14 A Well, I don't think I know what fault tree 15 analysis is, although I expect it might be like 16 failure mode and effects analysis. 17 I don't -- in addition, I don't think 18 I know what event . tree analysis is. I think I 19 know what an event tree is, which is a graphical 20 representation of the evolution of a certain set 21 of circumstances, with blocks on it indicating 22 where decisions or actions may take one of two 23 or three possible courses. 24 Q I didn't mean to be unduly mechanistic 25 in referring to event tree logic. I
1 Dunn 587 l'% V 2 As we have now discussed it, does 3 your unit perform analyses which are akin to 4 event tree analyses? () 1
} 5 A In the fashion that we create operator 6 guidelines for the management of small break 7 loss-of-coolant accidents, the guidelines are 8 constructed to provide suggestions for operator 9 response to system indications with the 10 availability or nonavailability of various 11 systems.and/or components, that word might be 12 close.
( 13 Q Were you doing that kind of analysis . 14 before the accident also? 15 A No. 16 Q What has induced you to do it since 17 the accident? 18 A First there was the NRC request for small i 19 break operator guidelines for safe management of 20 the accident after its initial phase, and i 21 following that, the recognition of the value of 22 programs like ATOG in which it is considered i 23 to be of benefit to have guidance to the () 24 operator which considers the availability of 25 various pieces of equipment and systems. i i
1 Dunn 588
.O V 2 Q Who considers it a benefit? Whom 3 were you referring to when you said it is 4 considered a benefit?
( 5 A I think B&W as a whole considers it a 6 benefit, I think our customers consider it a 7 benefit because they are paying us to do it, 8 and I believe the NRC considers it a benefit. 9 Q In ECCS analyses done prior to the 10 Three Mile Island accident, what, if(any, 11 assumptions were made about whether the pilot 12 operated relief valve had functioned or not? 13 A The analysis performed beforo Three Mile 14 Island would generally be pressurization 15 analyses in which it was assumed that the valve 16 would function to the extent that it would stay 17 closed. j 18 Did you do any analysis that assumed Q 19 that the valve had cycled prior to or at the 20 start of the transient? When I~say prior to, I 21 mean immediately prior to. I 22 A I don't believe so. 23 Q Did you do any analyses of the () 24 , response of the system to a loss of feedwater? 25 A Not within the licensing basis.
y I Dunn- 589 h G 2" Q What about outside the licensing r
' 3 basis? '
' .? . /
4 \A There was analysis on a mode of cooling which ( - 5 has c.been r a f f a ctio'nataly c termed. " burp . and..'s lurp., "
.6 in which you postulate a total loss of feedwater 7 -and ask yourself if you can still cool the core.
8 Q And does the burp and slurp method 9 of cooling involve intentional opening of the , .1 10 pilot operated relief valve to release energy? 11 A It does not dep,end on that.
- 12 Q How is the pystem burped?
h3 U 13 / A The system can be acceptably burped 2 s/ ,
. r ,
14 through the co..de safeties.
.sj 15 Q Was theie-any accident sequence t ; ,
16 that your unit studied in which the probability
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q 17 of failure of the pilot opery,ted relief valve 3 18 was taken into 5tecount prior' to'thea~ Three
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v 2 page of GPU Exhibit 75, please. 3 In the section headed " Areas of 4 Expertise Within Unit," " Unit" refers to the ( 5 ECCS Analysis Unit; right? 6 A yes. 7 g what does item 6 mean, " Development 8 of ECCS system performance criteria"? 9 A Specification of the flow rates required 10 at the reactor coolant system pressure boundary 11 for the HPI system and the LPI system, 12 specification of.the pressure inventory A i
~ 13 requirements for the core flood tanks, 14 specification of a minimum flow for assured 15 recirculation within the RCS following large 16 break loss-of-coolant accidents to prevent boron i
( 17 concentration to an unacceptable level. 18 Would you turn to the next page Q 19 under heading 5 where it says " Summary of Recent . 20 Experience." Item 4 says " Analysis of stuck 21 open pilot operated relief valve following a 22 small break (177 low loop generic)." U A Yes. l l-, 24 Q What work had your unit done to 25 analyse a stuck open pilot operated relief valve?
-m
1 Dunn 593 V(~h 2 A Following Three Mile Island, we studied 3 several sequences in which part of the event 1 4 was a stuck upon PORV. ( 5 . Q Who did that work? 6 A Almost everybody in the unit. I would say 7 Bob Jones, Bill Bloomfield, Maria Gharahkani, 8 Nehru Shah. 9 Q Were reports generated as a result 10 of that analysis?
- 11 A Yes.
12 Q Did 'you learn anything about the O 13 performance of the system that you hadn't known 14 or concluded prior to the Three Mile Island 15 accident? 16 MR. FISKE: That is a pretty broad 17 question. 18 MR. SELTZER: Yes. 19 MR. FISKE: Do you want to narrow it 20 a little? 21 Can you answer it that way? 22 THE WITNESS: Yes. 23 MR. FISKE: 0.K. i-m 24 A I have gone on record previously by saying (_) 25 that short of very fine-line information, these
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1
1 Dunn __ 592 (~h V 2 evaluations confirmed our earlier opinions 3 relative to the bouding nature of our previous 4 work. () 5 Q Did you learn- anything new about the 6 behavior of water in the pressurizer following 7 a stuck open pilot operated relief valve? 8 A No. 9 Q Item 7 refers to LOFT and semi-scale 10 experimental verification. . 11 What is LOFT an acronym for? 12 A Loss of fluid test, I believe. (~ . \-)) 13 Q Does that refer to the Idaho testing 14 also? 15 A I would take this as referring to the test 16 performed at the LOFT facility. 17 Q And the-LOFT facility is in Idaho? 18 A Yes. 19 g what recent experience has there 20 been with experimental verification on the LOFT 21 or semi-scale facility? 22 A At sometime following Three Mile Island 23 a small break experiment was performed at the 24 [(-)/ semi-scale facility and a blind test prediction 25 was required of the reactor vendors.
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1 Dunn 593 O 2 LOFT has performed, I believe, four 3 small break experiments since Three Mile Island, 4 two of which have been utilized or will be ( 5 utilized for a code verification. L31 is the 6 designation of the first such LOFT experiment 7 utilized. The verification as part of L36 8 is ongoing at this time. 9 And relative to the word " verification," 10 I believe that is a complete story.'. . 11 You did ask the question post the 12 TMI, didn't you? O- . 13 g Well, I said "recent" since that is s 14 the heading. 15 Item 8 is intriguing. That is 16 called "TMI-2 Accident Analysis." 17 Do you see that? 18 , A Yes. 19 Q what did your unit do under that 20 heading? 21 A We have performed a simulation of the 22 TMI-2 accident utilizing the evaluation model 23 employed by B&W previous to the accident,
*) 24 adjusting that model only as necessary for 25 removal of licensing conservatisms which one
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1 Dunn 594 A N_ 2 cannot use to create an experimental verification 3 or coincidence. 4 Q Yes. ( 5 A And achieved results which are highly 6 credible in view of the accuracy of the 7 information known about the accident. 8 Q The heading at the bottom of the 9 'page is " resource Available." 10 Under that is written that "The 11 load board is full for the next six months." 12 Do you see that? 13 A Yes. 14 Q Is the load board a reference to 15 a real list of projects that is maintained 16 somewhere in the unit? 17 A The load board is a list of committed 18 projects, including the manpower requirements, 19 proposed projects -- and forecast is the term 20 used -- projections, which are viewed as likely 21 but have not yet been proposed to anybody. 22 Q Was it a real board? 23 A No. 24 Q was it a real list? Oa 25 A Yes.
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1 Dunn 595 I)
'-' 2 Where is it kept?
Q 3 A It is maintained by one of my employees. 4 Q Who? (.' S A Mike Eberl. - 6 Q Does it show who was assigned to 7 each project or prospective project?! 8 A Recently it has been upgraded to do that. 9 Q Have you ever met with a gentleman 10 known as Carlyle Michelson?
- 11 A I have been involved in meetings in which 12 he was active and present. I believe I met him
(~/3 s_. 13 afterwards at one of those meetings. 14 Q Have you ever discussed with him 15 any concern he had over the extent of ECCS l 16 analysis performed by B&W? 17 A Verbally? 18 You mean orally? Q l 19 A Have I ever done it verbally or orally; f 20 that is your question? 21 Q Yes. 22 A I don't believe so. 23 Q Have you communicated with him in 24 writing? (J') 25 A The unit has communicated with TVA in
1 Dunn S96 2 writing and the communication was on concerns 3 raised by Carlyle Michelson. 4 Q Have you had any truck with Carl ( 5 since he j oined the NRC7 - 6 M R.. FISKE: Any what? 7 MR. SELTZER: Any truck. 8 A' I don't believe so. 9 Q Have you had any communications 10 with Zoltan Rosztoczy? > 11 A Yes. 12 Q Have you met with him? p\_/ 13 A Yes. 14 Q When is the last time you met with 15 Rosstoczy? 16 A I believe the last time I met with Zoltan 17 Rosztoczy was during the review of reports 18 prepared by B&W following the Three Mile Island 19 accident. 20 Q Did you ever have any conversations ! 21 with him off to one side that were not part of a 22 formal meeting? l i 23 A At one time. 24 Q When was that? l 25 A I do not recall when that was. i
-1 1 Dunn 597 , [N \#
2 Q Was it before the Three Mile Island 3 accident? 4 A I am not sure. i ( ') 5 Q What were you talking about then? 6 A There had been consideration given in the 7 NRC to revising the decay heat curve imposed 8 by Appendix K for utilizing -- for usa in 9 evaluating small break loss-of-coolant accidents -- 10 in evaluating loss-of-coolant accidents in 11 general. 12 There was evidence available that
-/ 13
- the curve was considerably conservative. I 14 was trying to tell him that I thought it would 15 be wrong to revise that curve for all loss-of-I 16 coolant accident conditions unless suitable 17 conservatism was in some fashion added,to the 18 small break evaluations because our major i
- 19 conservatism in that arena is the decay heat curve.
l 20 Q Would you look in GPU Exhibit 75 at 21 your resume, page 3. l 22 Item E at the top third of the pages 23 says " alteration" -- I am sorry. Item E appears [~')
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24 under the heading: The following major 25 accomplishments were made during this period, _ _ . , . _ . . , . . _ . . , . . . , _ _ . _ _ _ _ . _ . . . . . . _ . . ~ . _-_ .-.
- 1 Dunn 598
'l 2 and the period appears to be 1975 to 1980; is t
3 that correct? 4 A Yes.
; ( '; 5 g Item E says: " Alteration of I
l 6 ECCS evaluation model and the Nuclear Regulatory I 7 Commission approval of that model so that the 8 impact of previously unidentified accident 9 did not affect the operation of approximately 10 seven nte. lear power plants." , 11 What is the previously unidentified
. 12 accident?
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'(_) 13 A This comment is written in reference to 14 our discovery that the pump discharge break in 15 the small break arena was more severe than the 16 pump suction break which formed the previous 17 licensing basis.
18 Q Item G says: " Developed and obtained 19 the Nuclear Regulatory Commission approval of 20 the valuation techniques for subcooled, 21 decompression hydraulic forces." 22 That sounds like pretty interesting 23 stuff. Can you tell me what that refers to? 24 A During the very first phrase, very first ( 25 millisecond of a large break loss-of-coolant
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1 Dunn 599 k- 2 accident, the immediate area within the RCS 3 adjacent to the break will decompress to the 4 pressure, the saturation pressure associated (' 5 with' the temperature of the fluid in that 6 area. This will cause what has at times been 7 called a shock wave to propagate through the 8 system. The propagation is time dependent and 9 pressure forces will result on components 10 within the RCS because the wave may have arrived 11 at one side of the component and not at the other. 12 Q What induced you to leave Hanford?
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_) 13 A I was let go. - 14 I would like to expand on that a bit. 15 Q Please do. IJS A I was employed at Hanford approximately 17 two years before the requirement for weapons 18 grade plutonium was reduced by the coun'try, and 19 with the reduction in that requirement, several 20 of the reactors which had been operating at 21 Hanford were shut down. This resulted in an 22 overall reduction of force. As I was one of 23 the younger members of the engineering staff, 24 I was affected by that reduction of force. 25 Q Were you producing fissionable
1 Dunn 600 O. v 2 material for atomic weapons? 3 A Yes. 4 Q Where else in addition to B&W ( 5 did you apply for future employment? 6 A I don't know. One other place was 7 Physics International in San Diego, I believe. 8 Q What led you to apply to B&W7 9 A I had passed my resume to a professional 10 employment agency, they in turn passed it to 11 B&W, and B&W contacted me. 12 MR. SELTZER: Maybe instead of going r% ( ) . A> 13 ,into a new area, we will adjourn for today 14 and make it easier for you to get your 15 plane at 5:30. 16 THE WITNESS: I appreciate it. 17 MR. SELTZER: We will resume at 18 9:30 Monday morning. " 19 (Time noted: 4:00 p.m.) l
/f M" 21 Bert Me'rrit Dunn 22 23 Subscribed and sworn to before me
( 24 this c2 9 day of O " 198k
+ [1 d &. & -K 25 4 %
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1 7 601 ( CERTIFICATE 2 STATE OF NEW YORK ) 3 : ss.: COUNTY OF NEW YORK ) 4 (, I, CHARLES SHAPIRo , a Notary Public of the State of New York, do hereby certify that the continued deposition of 7
'BERT MERRIT DUNN was taken before 8 -
me on March 20, 1981 consisting 9 of pages 500 through 602 ; , t I further certify that the witness had been previously sworn and that.the within g 12 , V transcript is a true record of said testimony; 13 That I am not connected by blood or marriage with any of the said parties nor interested directly or indirectly in the matter in controversy, nor am I in the emp.loy of any
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of the counsel. 18 IN WITNESS WHEREOF, I have hereunto set my 19 9tt
'L hand this day of SPR I L ' , l'1S/
20 21
% )
Charles Shapiro, CSb . 24 25 _, , , - - - , , . _ _ . . 3 .r .-i
--y .
602
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( I N D EX - V) WITNESS PAGE Bert Merrit Dunn, resumed. 502
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. .a EX H I B I T S GPU FOR IDENTIFICATION 97 Handwritten notes of Mr.
Dunn, three pages ". 511 s 98 Memorandum dated April 23, 1980, to Rudy Straub from fry , B. M. Dunn 544
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99 Momo dated April 14, 1978, to J. Taylor from Bert M. Dunn 555 100- Handwritten memo from Mr. Dunn to Cliff Russell, 7 dated 5/9/78 560 l l . I I l
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