ML20072J151
| ML20072J151 | |
| Person / Time | |
|---|---|
| Site: | Three Mile Island  |
| Issue date: | 01/04/1982 |
| From: | Keaten R GENERAL PUBLIC UTILITIES CORP. |
| To: | |
| References | |
| TASK-10, TASK-GB NUDOCS 8306290964 | |
| Download: ML20072J151 (90) | |
Text
_ _ _ _ _ _ _ _ _ _ _ _ _
pk UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK 4 _ _ - - - _ _ _ _ _ _ _ _
_x GENERAL PUBLIC UTILITIES CORPORATION, :
JERSEY CENTRAL POWER & LIGHT COMPANY, METROPOLITAN EDISON COMPANY and :
PENNSYLVANIA ELECTRIC COMPANY, Plaintiffs, 80 CIV. 1683
- (R.O.)
-against- l THE BABCOCK & WILCOX COMPANY and J. RAY McDERMOTT & CO., INC., :
Defendants. :
- _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _x Deposition of General Public Utilities
( )
Corporation by ROBERT W. KEATEN, taken by Defendants, pursuant to notice, at the offices of Davis Polk & Wardwell', Esqs., One Chase Manhattan Plaza, New York, New York, on Monday, January 4, 1982 at 1: 30 o' clock in the afternoon, before Joseph R. Danyo, a Shorthand Reporter and Notary Public within and for the State of New York.
eO g6gg4o N DOYLE REPORTING. INC T W CERTIFIED STENonPE REPORTEF 369 Lc xlN GTO N AvtNur WALTER 3 HAP!RO, C.S.R. NEW Yo m K. N.Y. 10017 CHARLES SH APIRO, C.S.R. Tct.cpwows 212 - e67-822o
_ u_._._____ _ _ _ _ . _ _ _ . . _ _ _ _
f i'
1 2 2 ,
Appe a ra nc e si l l I j 3I '
.; 4
- KAYE, SCHOLER, FIERMAN, HAYS & HANDLER, ESQS.
f Attorneys for Plaintiff l
i h 5 425 Park Avenue New York, New York 6
BY: STEVEN GLASSMAN, ESQ.,
( ,
1 4 i of Counsel i l; 8 f I 9 l A DAVIS POLK & WARDWELL, ESQS.
Attorneys for Defendants 1
10 l j One Chase Manhattan Plaza l
{
f' 12 BY: ROBERT F. WISE, ESQ., l e
13 of Counse1 'I
! I
! 14 l
! l
} 15 i Also Present: '
l I
16 NINA RUFFINI 4
i
. 17 j -oOo- [
i 18 ,
i 7
19 IT IS HEREBY STIPULATED AND-AGREED by and i 4 li between the attorneys for the respective parties 20
! l- t-21 hereto that the sealing, filing and certification 22 of the transcript of the within deposition be, 23 and the same hereby are, waived; that the' 24 , transcript may be signed before any Notary O 25 f Public with the e r .te force and effect as if i
f
1 3
/ 2 signed before the Court.
3 IT IS FURTHER STIPULATED AND AGREED that i 4 all objections, except as to the form of the
' I jg) 5 question, are reserved to the time of trial. l 6
7 -oOo-8 9 R OB E RT ,W. KE A T E N, having l 10 i been first duly sworn by the Notary Public l.
11 (Joseph R. Danyo), was examined and testified 12 as follows:
13 EXAMINATION BY MR. WISE:
O 14 Q If you would for the record, state your i I
i 15 full name and currect business address.
16 A My name is Robert W. Keaten. Business 17 address is GPU, 100 Interpace Parkway, Parsippany, 18 New Jersey, f i
19 Q What is your residence address?
k 20 A 45 Long Ridge Road, Dover, New Jersey.
l !
21 Q Do you have any idea about how far that
{
l 22 is from New York City? Is it more or less than a 23 hundred miles?
I 24 j A Less than a hundred miles.
( /- 25 i Q I take it you are currently employed by , .
1 Keaten 4 Ih
-(,/ 2 . General Public Utilities or one of its affiliates? l l !
3 A That's correct.
l 4 Q Which corporate entity are you employed by? ,
I i lll 5 A I believe it is now true that I am employed f 6 by GPU Nuclear Corporation.
7 Q Do you know when GPU Nuclear Corporation 8 was formed?
9; A Very recently. I don't know the exact date.g l .
Q Prior to GPU Nuclear Corporation, do you i 10 l i
! +
11 i know what other entities within the GPU system you I
12 have been employed by? i I
() 13 A I was employed by the GPU Service i
14 Corporation.
15 Q When did your employment with them commence?
16 i A In the spring of 1978.
i 17 Q Was that the first GPU-related company for !
18 which you worked?
19 A Yes, it is. !
20 l And you worked at GPU Service until that,
. Q i
21 through whatever corporata reorganization, became GPU 22 Nuclear, is that correct?
' l 23 A It is not quite correct that GPU Service ,
i l l
fg 44 corporation became GPU Nuclear. It is rather true that I
{
!'O
- .5 (; GPU Nuclear was a new corporation which_some of the i l i '
l l
1 Keaten 5 4
("N
(_) '2 previous GPU Service Company employees became employed 3
i 3 by. l Il Y l 4 Q In any event, your affiliation with GPU i l lll 5 has been either through GPU Service Corporation or GPU 6 Nuclear?
7 A That's correct.
8 Q Who now is the head of GPU Nuclear?
9 A Robert C. Arnold.
10 Q To whom do you report at GPU Nuclear?
I.
11 A I report to Richard F. Wilson. i i
12 Q To whom does Mr. Wilson report?
13 A He reports to the Office of the President, 14 which includes Mr. Arnold. .
I 15 Q Who else is in that office?
i 16 A Mr. Philip R. Clark, who is the executive 17 vice President. l 18 Q Is this the first time that you have given l
19 l
sworn testimony?
20 ; A No.
l l 21 Q When before have you testified? ,
22 MR. GLASSMAN: In this case or in relation--
1 23 MR. WISE: I know'this is the first time 24 he's given it in this case.
O 25 i
i Q How many times have you testified? If they l.
I I l l, .
. - . - -~, , - - - ,,, ---,----r - , - - -
1 Keaton 6 k'_)T ' 2! are irrelevant, we won't go into them. !
3 ; A Most recently, sworn testimony at the TMI-1 .
l '
4 ,
restart hearings. Prior to that, a sworn deposition in 5 the GPU lawsuit with Exxon Corporation. That is all ll 6 since I have been with GPU.
7 Q Did you give testimony to the President's 8 Commission investigating the accident at Three Mile 9 Island?
10 A Thank you. Allow me to correct my answer.
I 11 I did not give sworn testimony. Let me I i
12 correct that. I have lost track. I don't remember ;
) 13 whether I gav sworn testimony to the President's 14 Commission, but I certainly did give sworn testimony !
15 !, to the Nuclear Re gulatory Commist, ion as part of their 16 investigation of the accident. .
17 Q Are you speaking now of the so-called 18 Special Inquiry Group? +
19 l A No, I am referring to the NRC I&E 20 investigation.
I :
i 21 Q Do you recall'also whether you gave 22 testimony, whether sworn or unsworn, to the NRC 23 Special Inquiry Group, the so-called Rogovin Commission?
24 . A I don't recall. I gave two sworn pieces of
_)
25 testimony.
I
1 Keaten 7 2 Q Let me ask you if you remember giving a '
3 deposition in October 197- --
I can't read the last il 4 'j figure on this. October 10, 1979. I say that, although lll 5 the copy of the transcript I have has the last digit l
. 6 cut off, but the 7 is there -- before three fellows !
7 from the NRC Special Inquiry Group, Mr. Harnett, Mr. l 8 Schierling, Dennis Allison, and Barry Horvick?
9 A I remember giving a deposition at about
. 10 that time. Those names sound vaguely familiar. l 11 Q We may a little bit later in the deposition ,
i 12 have occasion to show you some parts of that transcript.;
() 13 I also have a transcript which indicates i
14 that you were interviewed on June 1, 1979 by a Mr. l 15 Marsh and a Mr. Fasano of the Nuclear Regulatory i-16 Commission, who appear from the transcript of the '
17 session to be members of the NRC's I&E staff. Does that' 18 help refresh your recollection as to that interview? .
19 A Yes, I recall the interview in question.
l 20 l
, It was the one I had earlier referred to.
21 Q Do you recall one way or the other as to 22 whether or not you were given an oath before that 23 interview?
i 44 A I don't recall.
O 25 l Q Did you give any testimony before any
?
l' 'l * '
-. ~. _ ..
! 1 Konton 8 i gs 2 Congressional Committee with respect to the Three Mile l
! l l '
3 ,
Island accident? 8 t
! 4 A No, I did not. l 5
l
, I i
lll 5 Q Let me go back to the GPU/ Exxon suit. What l
6 was the subject of your testimony in that lawsuit 4
7 generally?
8 A Generally, having to do with documents 9 related to the question of whether or not there was a i
10 I valid contract in existence between Jersey central and l
11 Exxon with respect to the supply of nuclear fuel for the.
l 12 Oyster Creek station.
l
() 13 Q Have you personally participated in any i
14 of the negotiations of the contract that was in issue? I i !
15 ' A No.
l 16 Q Generally, what was your relationship to 17 the contract dispute that you have just described?
18 A Practically nonexistent. My deposition was 19 taken I believe because I had received copies of 20 ,
certain documents that were of interest in the case.
i 21 Q Had you participated in any conversations, h
22 either internally at GPU or with outsiders such as 23 Exxon, concerning contract terms for the purchase of
! p 21 nuclear fuel? l i
V 25 ; A Not that I recall, other than some i
! 1 L l l
1 Konton 9 2 conversations with respect to the lawsuit itself.
l .
3 y Q Did you have any participation in connectionf l
r 4 ! with that lawsuit in conversations concerning any i l
lll 5 clauses in the purported Exxon /GPU, or whichever 6 subsidiary it was, contract relating to limitation or 7 exculpation of damages?
8 MR. GLASSMAN: You are talking about other 9 than conversations with counsel, if any?
10 MR. WISE: Yes.
i 1
11 A Not that I recall. l l
l 12 Q We have a resume which your counsel has I
( 13 provided us with this afternoon, and I would like to 14 have that marked as B&W Exhibit 335. ,
. t 15 (Resume was marked B&W Exhibit 335 for '
i 1G identification, as of this date.)
17 Q If you would take a look at B&W Exhibit ,
18 335, which appears to be a resume for you, and tell us 19 if that generally accurately reflects your educational l
20 ; background and work experience.
I 8
21 A Yes, I believe it generally does. ;
22 Q I also have a resume which I believe was ,
23 submitted by you or on your behalf in connection with i
24 your testimony before the ASLB in the matter of TMI-1
-)
25 ; restart-which I would like to have marked as B&W i
3 i
't,
h 2 Exhibit 336.
lp 3d l (Resume was marked B&W Exhibit 336 for ,
i i i 4l identification, as of this date.)
lll 5 Q Have you seen B&W 336 before?
6 A Yes, I believe I have.
7 Q Do you know who prepared it?
8 A Yes, I did.
9 Q You did?
I 10 : A Yes.
i 11 Q Was this in fact submitted on your behalf l i
12 in connection with the TMI-1 restart hearings before f 13 the ASLB7 14 i A I believe it was , yes. l I
l 15 l Q Is it accurate, to the best of your 16 l!'
9 knowledge and information?
f' i
17 ; A I believe that it is, except that my current; 18 title is different than shown here.
l 19 i Q When did you assume your current title, l,
20 [ which I note from B&W 335 is listed as Director, 21 Systems Engineering (1981-present)?
22 A At the beginning of 1981. ,
23 cl Q How did that position differ from your 24 earlier position as Manager, Systems Engineering, which I:
25 you held from 1978 to 1980, according to B&W 335?
i i !
I i
I l
1 Kanton 11 l
('. 2 ; A My present position includes a somewhat i
<J ?l 3 ;i.
expanded organization compared to the earlier one.
'N '
4 Q How does it differ? ,
It has additional organizational units and lll 5 A 6 some additional responsibilities.
7 Q We may want to come back to that and define 8 that more fully.
9l Let me first go back, if you will, in time l l !
10 to your educational experience. Both resumes, 335 and -
11 336, indicated that you graduated with a BS in physics i
12 l from Yale University in 1957. I also understand from
,ey 13 ! B&W 336 that you had postgraduate and professional l k_ i 14 l courses in mathematics, engineering and business taken I'
i 15 .I at UCLA between 1960 and 1972.
d I I assume you were not at UCLA full time 16 17 l during those 12 years?
18 A That's correct.
I 19 Q Could you tell us what courses you took, l
20 i f any , were in the degree program, if you received 21 any degrees, and if so, the approximate time periods 22 associated with that work?
i 23 A I did not receive additional' degrees.
24 Q Perhaps you could tell us then what
,o l
)' 25 specifically these courses that you tooX were in I
, ~: . . ,
e' s T. l' N- m 1 T Konton 12 y .
s 2 I' relation to?
3 l A These were largely evening courses taken to r ! ,
4 further my professional development. They included x
p r ,
lll 1 5 courses in mathematics, electronics, control systems N 6
,g ,
theory, engineering materials, and then some business
/7
., 7 and management courses.
t l 8 Q Approximately how many courses overall did I i
l 9 you take during this period 1960 to 1972? Are we ;
I j i 10 talking something of one or two or a dozen or maybe 207 -
i
)
11 A To the best of my memory, I would say about i 12 a dozen. l 1
1
.I 13 Q Tnese were all taught at UCLA, I take it.
I 14 A At one of the campuses of UCLA, yes.
I i '
15 Q Your resumes show that you worked from 1957 r- ,
16 to 1959 at Du Pont with the Savannah River plant. ,
l',
17 What was the Savannah River Plant? {
{
18 A Savannah River plant is an installation ,
19 whi ch produces nuclear materials for the military.
1 20 Q Is that located in Georgia?
e o" '
N 21 i A No, it is in South Carolina.
'Ill C2 h
{
, Q What was your title during that time, if s ,
,23 I you can recall?
gg- .24 5 A I believe it was Reactor Physicist.
.Q #
g, 2f) >
-MR. GLASSMAN: Off the record, i
(( ,
m ,s
' . 5'? . . }.
,y.
- s
1 Konton 13
~
2 (Discussion off the record) 3 .
Q During the time you were with Du Pont, did ;
I 4 I ; you have any connection with the use of nuclear power .'
lll 5 to Produce electricity, generate electricity?
6 A No.
7 Q Your next employment listed on the resume is 8 with Atomics International between 1959 and 1965. What J 9 business was Atomics International in?
10 ' A Atomics International was involved in a 11 variety of nuclear and nonnuclear programs, many of l l
12 which were related to the use of nuclear power to l i
i gs 13 produce electricity.
(_ l 14 Q Atomics International is a division of g I I ,
15 Rockwell? j l I
16 A At that time, it was a division of North [
17 American Aviation.
- 18 Q Did it at some later time become a division 19 of Rockwell? ,
20 'l A As a result of the merger between Rockwell 21 and North American Aviation, it became a division of '
9 22 originally North American Rockwell and subsequently 23 Rockwell International.
24
- l. Q Did that reactor ever actually produce or (s 25 i generate electricity?
i 1
{ 3 t i i-I !
_________.___....a _ . _ _ . _ _ . . . _ _ _
Y 1 Keaten 14
'\ 2 A Yes.
i 3 Q Where was it located?
4 4 A In the Santa Susana Mountains just outside lll 5 Los Angeles, California.
6 Q The next item on your resume is an 7 employment with the Halden Reactor Project. Who or what 8 company ran th'*r program?
9 A The program was run by the Norwegian 10 Atomic Energy Agency, but the project was an i
11 international project and was funded by the various ,
12 participants. I
() 13 l
Q What exactly did you do in connection with 14 I that? !
15 A I was the American representative to the 16 l project and so I both participated in the research 17 activities that were being carried out in the project 18 ! and also served as the liaison for information flow 19 - between the project and interested people in the United l>
ll 20 States.
j l
21 I should also clarify that during this 9 22 period of time I continued to be an employee of Atomics I
23 International.
24 Q What exactly was the Halden Reactor Project?
25 Was that actually a plant or experimental work or
. -+ - , - --,-
1 Kooton 15 2 perhaps you can describe for us just what it is we 3 ; are talking about. !
i 4
Y J A The project centered around a boiling heavy .
water reactor which was located in Halden, and the lll 5 6 project emphasized the use of the reactor in performing 7 experiments on various items of interest to nuclear i
8 power such as the irradiation of test fuel assemblies, 9 development of in-core instrumentation, and so forth.
10 Q Who had constructed the reactor, if you ,
t 11 know? Perhaps " constructed" is the wrong word. j 12 " Designed" might be the better terminology.
l 4
13 A It was done under the auspices of the 14 , Norwegian Atomic Energy Agency, and I don't know the 15 details. :
i 16 Q In other words, it would not be as simple i
17 i as saying it was a GE-designed piece of equipment or ,
l l 18 B&W-designed piece of equipment or some other company ,
19 that we may be familiar with in this country? ,
20 MR. GLASSMAN: If you know.
21 A I certainly know it was not a standard 22 product line of one of the U.S. nuclear vendors.
23 Q But you are not familiar with exactly who 24 the nuclear vendor was and what design it may have used O(_/ - 25 or employed?
i l ,
1
1 Kocton 16 i
2 A I am not sure. ,
l .
3 i Q Do you know whether that project was ever !
4 intended to be commercial?
lh 5 MR. GLASSMAN: Objection insofar as it.
6 seeks his knowledge of the intent of somebody 7 else. He can answer.
8 A I don't know what the original intent was.
9 It was commercial in the sense that it supplied steam 10 generated from the nuclear reactor for use in a paper l l
l I
11 factory across the road.
12 Q While you were there, it did not actually ;
1
() 13 generate e'lectricity for electrical power needs of l 14 Norway or anywhere else?
i 15 ! A That's correct.
16 Q You said that you were involved in or the 17 project included some work on in-core instrumentation.
h ,
18 l Did that include in-core thermocouples? j 19 A I frankly don't remember. Certainly the f
20 lla enphasis on the type of instruments being developed and 21 used was not on development of thermocouples. !
l 22 Q What kind of in-core instruments were being 23 studied?
i i 24 $ A- There were flow meters for individual fuel O
V 25 I;
assemblies which were used as part of the irradiation 4
4 l
l
1 Keaten 17 2 of test fuel assemblies. There we re small in-core d i 13 3j neutron detectors.
Those are the principal ones I i i ,
4 {d remember. !
h 5 Q What purpose would the flow meters serve?
6 What would they tell the operator that the operator 7 would want to know?
8 MR. GLASSMAN: What did they tell them?
9 MR. WISE: What were they designed to tell 10 them or from the standpoint of how the experiments l!
11 worked out, if they worked, what did they tell i
12 them?
l MR. GLASSMAN:
13 As long as we get his i
14 testimony as to what he recalls, not what he l l
15 il speculates.
16 7 The flow meters were directed primarily !
I 17 l for use by the experimenters rather than by the reactor l
[ l 16 operators. They were used to study phenomena such as 19 flow instabilities in the boiling heavy water reactor. .
4 1
20 j Q With respect to the in-core neutron 21 detectors that you mentioned, what purpose would that {
G 22 instrumentation serve?
1 23 A Again, it was directed toward the l 24 experiments rather than toward the operators, and as I 25 ,
remember, they were used to characterize the amount of !
l
1 Konton 18 2 ; irradiation that a test fuel assembly would receive.
l i
Q Was any of that instrumentation used to help 3 'l l
4 j the operators determine the conditicn of the core?
lll 5 A I don't know.
6 Q During your time at the Halden Reactor 7 Project, did you at any point take up the study of 8 in-core instrumentation as it related to operator 9 control of the reactor?
10 A To the best of my memory, I did not.
I 11 Q Do you know whether anyone in that project l l
12 was concentrating on that issue? !
A I believe there was some work of that type,
( 13 14 but I don't remember any of the details. l 15 Q Do you recall, for instance, who within
- 16 the project was interested in that?
17 A No. !
t 18 Q Do you recall whether any interest that 19 there-may have been resulted in any papers or i
20 !! 9 information that was provided to you?
B 21 A I mentioned earlier that one of the research 22 ll projects at Halden involved the application of digital <
23 computers to nuclear reactors. It may be that some of the signals that were used in that research were
( 24 t
t 25 lj from in-core detectors, and I did receive some i i
u i i
1 Kooten 19 m
2 information on that subject.
t l
3 i
Q Do you have any recollection of the 4 l specifics at this point? I h 5 A No, I do not.
6 Q The next item on your resume indicates that 7 you went back to Atomics International, where you held 8 two positions between the years 1969 and 1978. The 9 first is listed as Manager, Safety Analysis for Fast i
10 j Breeder Reactor Program. What years did you hold that 11 work responsibility?
12 A Let me first clarify that I don't remember l
13 the exact title, and in fact, during the time frame f 14 being discussed here, the title changed at least once. !
15 In your Exhibit 336, the title is listed as Manager of 16 Systems Engineering, which is also possible. I just
- 17 don't remember. In any event, that position or series 18 of positions was held from 1968 until I believe ,
19 sometime in 1974.
F ll 20 L Q From what sources, as bett you recall, was b '
21 Exhibit 336 prepared?
22 A I believe it was prepared from earlier 23 resumes that I had.
2I -
Q Do you recall about when 336 was prepared?
U' 25 A year ago, two years ago?
l .
. .. . - . . - ~ .
l- 1 Konton 20 2 A I believe it was about a year and a half i
t ago. i I
l-3 l 1 Q Did you have available to you at the time h 5 that you prepared 336 other resumes and information 6 which you believed at the time accurately reflected 7 the various positions that you had held with previous 8 employers?
A As I said, I had available at least one 9l 4 i
t .
10 i earlier resume, but I don't remember whether that '
l 11 ,
earlier resume had this title. ,
! i 12 Q I am just trying to establish whether we j l
13 can rely upon the accuracy of Exhibit 336 and'to what i 14 extent we can. f i
. 15 '
To the extent it was prepared from I i
16 information that you had available to you then which 17 !
may either not be available here or may be more than l
l 18 i when 335 was prepared, can we rely on in effect 336 19 !l as being more accurate?
20 MR. GLASSMAN: You would like Mr. Keaten's I'
21 current understanding? !
, 22 MR. WISE: Yes.
23 A I believe that 336 in general accurately I '
24 e' re flects my resume except as I mentioned, I have O: 25 ! reservations'about that specific title, and I-do
,c.
1 KGcton 21 l
(v ') 2 remember it changed at least once.
3 Q On Exhibit 336, the entry for 1968 to 1974 I
4 which we have been discussing indicates that you were h 5 responsible for the performance of cafety analyses, 6 the development of safety criteria and the development 7 of instrumentation control and safety systems design.
I 8 Did you have a staff assisting you in 9 carrying out those responsibilities? l l t 10 MR. GLASSMAN: The particular paragraph I 11 counsel is reading from relates to work in the i :
12 Light Metal Fast Breeder Reactor Program.
l
(] 13 MR. WISE: That's correct. l V
14 A Before I answer your question, I noted a 15 typographical error on that, and instead of " Light i 16 l Metal," it should say " Liquid Metal."
i 17 6 Q Would you like the question reread?
18 I A I remember the question. ,
! I t
19 j The answer is yes.
l 20 Q Hov many people did you have working for l
l 21 i you at that time?
22 A Reporting to me, there were a variable 23 number that went, as best I can remember, from a half 24 dozen to maybe 15 to 20.
,r) f 25 ,, Q What was the Liquid Metal Fast Breeder
1 Kooton 22
{}
's j 2 Reactor Program? i 3 ;
A This entry in my resume is really a .
I 4 shorthand entry for what happened during that period.
5 When I returned from Norway, the Atomics ll 6 International Liquid Metal Fast Breeder Reactor Program i
7 consisted of in part a joint effort with General Public 8 Utilities, looking at the design of a possible 1
9 commercial fast breeder, in part was a company-funded ,
10 program directed at the same goal, and in part was I
li 11 certain programs that were being performed for ,
12 then it was the Atomic Energy Commission.
() 13 Then I believe it was about 1971 or 1972, ,
14 the contract for the Clinch River breeder reactor was 15 awarded to Westinghouse with Atomics International as 16 one of the principal subcontractors, and this program ,
17 l at that point in time shifted over to work on those i 18 portions of the Clinch River project that were within 19 the Atomics International scope. ,
20 i Q Who at GPU was working on this project i
21 during the period of time that GPU was interested in 22 that? .
l 23 A The program as I understand it fell under g- 24 i the general responsibility of Bill Hirst of GPU, but b 25 we had interactions with other GPU employees as well.
l
[
'! l l
l
1 Kotton 23 2 I Q Did you work at all with any of the 3
! operating subsidiaries of the GPU system? l A We had a GPU representative at Atomics !
4 International who was from Jersey Central.
lll 5 6 Q Did you have anyone from Met Ed, as best you 7 can recall?
8 A Not stationed at Atomics International, no.
9 Q' Do you recall whether anyone from Met Ed l 1
10 ! participated in the work that you were doing?
11 A I do not recall any such participation, i
12 with one possible exception. The site which was being
() 13 discussed for the reactor was I believe within the Met 14 Ed territory. I went to the town close to that site i !
15 on one occasion to give a general talk on fast breeder i
16 I reactors to the local people who were interested, and 17 I believe I may have met someone from Metropolitan
! I 18 Edison as part of that trip.
i
. 19 ;l Q Was that anywhere near the Three Mile Island li 20 'l site?
21 A Not particularly. It was up above Scranton, 22 i Pennsylvania.
l 23 Q Let me ask a question, going to the next 2: [ item on your resume, just to see whether for-convenience lg L 25
- sake we should combine our discussion of the Liquid i
l lI I
- 4
1 Keaten 24
,m
( )
\> Metal Fast Breeder Reactor Program with your next 2l i
3 j' position.
,d 4 ,
The resume that has been marked as Exhibit l
lll 5 336 indicates that from 1974 to 1978 you were the 6 Program Manager for, it reads " Light" but I believe it 7 should be Liquid Metal Fast Breeder Reactor Technology i
8 at Atomics International, and your responsibilities l l
9 l included research and development programs, performed i
10 for the U. S. Department of Energy, including programs f I
i 11 in reactor physics, safety, and component development.
I i
12 Was that a continuation of the work that j
(~'; ;
I'
(_) 13 you have just described done on the Liquid Metal Fast 14 j Breeder Reactor Program that was developing into the I i 15 .I Clinch River Reactor, or was that something new or !
I 16 different?
i 17 A It was something new for me, although d
18 0 obviously there was a close relationship. These 19 l programs, the technology programs, were those which II '
4 20 ;; for the most part were not specifically associated 1
21 . with the Clinch River project, but for the most part 22 were more general technology programs.
II 23 I Q Let me go back then to the Clinch River
(~) 21 project and its predecessor, the work you were doing V
25 at Atomics International in part for GPU. I take it i
b
i 1 Keaten 25 O
.(_/ 2 that the idea there was the development of a commercial i
, I 6
i 3l plant? i i
4 A That's correct. -
l lll 5 Q That would require licensing by the NRC l l !
6 or as it may have then been called, the Atomic Energy -
7 Commission?
8 A That's correct.
9 Q were you in any way involved in the 10 consideration of the licensing of such a plant?
11 A Yes, I was. j 12 Q That last question may have been inartfully
() 13 phrased. Perhaps you can describe how your job i
14 related to the licensing process for the Clinch River 15 plant as it came to be known.
16 A For the Clinch River plant, Westinghouse 17 had the lead with respect to the licensing activities, 18 and the Atomics International role was really [
t l 19 restricted to providing certain types of information i' !
l 20 ; needed to support the licensing. I was involved, as t
21 I remember, in coordinating the Atomics International !
O 22 activity in this regard, but I would not say that that i!
23 was a very substantial part of the total licensing 21 process for Clinch River.
(~}
(_/ l -
25 !! Q Perhaps let me get at it this way.
i :
1 -
1 Kcoton 26
' I During your work, 1968 to 1974, on the
( 2.
I 3 Liquid Metal Fast Breeder Reactor Program, would it '
4 have been part of your responsibilities to become 4
lll 5 familiar with the NRC's licensing criteria or general 6 design criteria such as they were at the time?
7 A Yes.
8 Q And you would have been familiar with those?l 9 A Yes. l t
10 Q During the performance of your duties in 11 that time period, would you have occasion to use those l 12 design criteria on your work? i i
/~5 13 A Yes. l 14 Q The resume says " Responsible for performance l I
s 15 of safety analyses." Could you describe in more detail 16 what specifically was your responsibility for the li 17 ! performance o f safety analyses? ;
18
!l (Recess taken) ;
19 (Record read) 20 A The work on safety analyses during this i'
21 period really occurred as part of the earlie r AI 22 program in which GPU participated rather than the later .
I i
23 '
work on the Clinch River project. I was manager of the ,
21 group which was responsible for all of the safety work, O)
\_
25 but the work was performed in two different fashions.
1 l ! '
- . - - .= __ - ._ . - . . _
1 Keaten 27 2l Certain of the work was performed by those !
3 i people who worked directly for me. This work tended i I
4 to be the development of safety criteria, performing I l
llk 5 scoping type analyses, whereas the more involved type i
6 of safety analyses using elaborate computer codes, for 1
7 example, was done for me or engineers reporting to i
8 me, but was performed by a different portion of the !
l 9 organization, so in that sense, we were functioning as l
10 a matrix organization, and some of the work we did l i '
I 11 ourselves and some of the work we went to other portions l 12 of the organization to get done for us. l
() 13 ! Q Would I be correct that you and your staff I
14 ,
were not the ones who within the Atomics International ,
i I
15 i organization would be familiar with computer modeling i
16 and performance of analyses on the computer for safety l
17 purposes? If I haven't put that quite right, please ',
18 feel free to put it in your own words.
I 19 g A What you said is partially correct. There 20
!" were certain types of computer modeling and computer I t 21 analyses related to plant transient behavior.which were ,
22 .t done by people reporting directly to me, and there 1
0 23 r were other types which were done by other parts of the l
, 's 24 organization.
ms I;'
25 Q what was the distir.ction, as best you can f
f I
1 KGctGn 28
) 2l put it without getting too technical, between those ,
3l sorts of things which your organization would handle !
i 4 Il and these which you would go outside for? 5
-lhl 5 A In summary fashion, people working for me 6 worked with computer models of what I might describe l 7 as anticipated transients, whereas in fast breeder 8 reactors, a great deal of the safety analyses consider 9 situations which are more damaging to the system than 10 has classically been treated in water reactor safety l 11 analyses, and these kinds of calculations and models i l
12 which are very complicated were done by a different
() 13 I
part of the organization.
f 14 Q You mentioned earlier something called l ;
15 i scoping analysis. What is meant by a scoping analysis?
i 16 A I used the term to mean a very simple type ,
17 l of analysis or calculation that is used to get some ;
IS idea of the magnitude of a problem or some idea of the [
l possible result. I 19 I
20 Q Was there at this time we have been talking 21 about a generally understood definition of the term 22 " anticipated transients"?
23 MR. GLASSMAN: Understood by whom?
21 Q Was that in effect a term of art which had I
25 i; a technical meaning within the industry that you were i
b o
b.
Kocton 29 1
aware of?
j MR. GLASSMAN: I am not sure I understand 3 f !
the question. Are you asking whether Mr. Keaten j I
4 understands an industry meaning or are you asking for his own understanding?
6 MR. WISE: I am asking whether he understood, I !
the term " anticipated transients" to be a term j l
of art used in the industry, ard in particular -
9 with respect to safety analyses and any licensing 10 l criteria that might be relevant to those analyses.l 11 A I am not sure that that term was generally 12 l used in the industry.
's 13 Q Let me ask if you are familiar with the term l
" anticipated operating occurrence."
15 A Yes, I am. ,
i 16 !
Q Do you understand that to be a term that i 1,
has significance within the industry? !
18 l A Yes, I do. !
Q Isn't it correct that that is used in 20 >,
" connection with the licensing criteria for plants?
91
- h. MR. GLASSMAN: You are talking about today?
22 j MR. WISE: Today and throughout the 1970's 23 as plants were being designed.
24 .
A Yes, it is used as part of the licensing
[d~)
25 2
t-
1 Keaten 30 (s process.
2 1
I
^
Q With respect to the safety analysis work 3 i ' .'
4 that you were doing at Atomics International during the !
I 5 period 1968 to whenever it was that it went into the 1
6 Clinch River program, did you understand the term 7 " anticipated operating occurrences 'o have that i
8 significance in connection with the licansing criteria?
9 A At some point in that time, yes.
i 10 Q What was your understanding of the 11 definition of " anticipated operating occurrence"? !
l 12 MR. GLASSMAN: If you recall.
l
( 13 MR. WISE: All of my questions may be t
h 14 premised with the general instruction that we l
15 are looking only for your recollection such as ;
i l 16 it may be today.
i 17 I A To the best of my memory, during the time I l,
18 I frame in question, there was considerable discussion .
- t !
l 1
19 as to just exactly what that term meant. .
I 20 '!
Q Did you form any judgment or opinion for 21 the performance of your work as to what the term 9.
22 I " anticipated operating occurrence" meant?
23 MR. GLASSMAN: Objection. You are asking i
21 l for his judgment or opinion if you ask him if he 25 g had a personal understanding which he t
I l 1 o
d y w-, y.g g n n ,-
,im a, - -------,y q
1 Kocton 31 2 communicated to anyone, that is a more ;
h" 3 appropriate line of questioning. I I ,
4 1 MR. WISE: I think it is a fair question.
I 5 If the witness wants to put his answer in his own 6 words, he is free to do so.
7 A During the time frame that we are t
8 discussing, my best recollection is that we defined l l.
9 for the reactor concepts we were studying categories of l l s >
10 transients which were based upon the probability of I ,
11 l their occurrence. My recollection is that these did t 12 not bear a one-to-one correspondence with anticipated j i .
13 I operational occurrences, although the general concept 14 was the same. j l !
15 Q In other words, there might be occurrences i
1G i with a high probability of happening that would be i
1~ anticipated operating occurrences, and there might be ,
18 h ones that would not? I am just trying to understand ;
19 your previous answer as to what you meant by a -
i' d
20 : one-to-one correspondence. I guess I was thinking you 21 meant that the probability-of an occurrence, while it ,
22 bore some relationship as to whether it was an 23 anticipated operating occurrence, would not necessarily i'
21 ; always dictate that particular event would be classified j one way or the other.
25 [
i l .:
t a
1 Keaten 32 N' 2 l4 A You are testing my recollection, but the l
'l !
3 !l best of my memory is that as we at Atomics j i
4 International were working on our breeder concepts. In l h 5 this time frame we are discussing, we had three 6 categories which taken together covered the two 7 categories as they are in the water reactor criteria 8 of anticipated operational occurrences and postulated 9 accidents, so that our highest probability category 10 encompassed some but not necessarily all of the 11 anticipated operational occurrences. Some of the ! i I i 12 anticipated operational occurrences might have fallen !
l 13 in our second category, i
14 Q What was your second category? '
15 ,
A I don't remember the names we used. In I ,
16 fact, I am not even sure they had names. But they 17 were grouped according to the probability of occurrence, 18 j as are the names that are used in water reactor 19 criteria.
l 20 Q With respect to the safety analysis work .
21 that you did during this 1968, early 1970's time ;
22 period, did any of that result, to your knowledge, in i
23 , the submission of a preliminary or final safety 24 analysis report?
('J].
25 A Submission to?
i e
t
. 1 Konton 33 I
(~N To the NRC or its predecessor agency.
(_,J 2 j Q 3 i
' A We submitted a report to the NRC, but it was Y.
4 not a preliminary safety analysis report or final i 1
5 safety analysis report.
l 6 Q That is because there was no specific ;
f I
7 plant involved, I take it.
8 A It was rather because it was too early in l l
9 the design phase to have all the information that would 10 be needed even for a preliminary safety analysis report,!
11 so this was sort of a prepreliminary safety analysis j i
- 12 report.
)
i J) 13 Q To your knowledge, what happened to GPU's 14 l interest in the Liquid Metal Fast Breeder Reactor l
15 : Program? !
16 A It is my understanding that GPU concluded 17 that that program was too developmental in nature for 18 l GPU to be interested in conJtructing a commercial 19 liquid metal fast breeder reactor.
bl 20 !! Q Do you know about when they dropped it?
21 A I believe it was about 1972.
22 Q Do you know whether any work had been done 23 within GPU tcvards obtaining a construction permit?-
I ,
24 I am just trying to get a sense of how far they went l
%J i 25 ; with the program before they stopped. ;
l l-
,F N
1
P 1 Konton 34
( 2l A There was, as I indicated, a site that was .
I i 3
I tentatively selected, although it is my understanding , l i i .
4 that that was celected to be usable either for a fast ! )
h 5 breeder or for a light water reactor. GPU cooperated 6 with us in providing some preliminary site data to the ,
7 Nuclear Regulatory Commission, or I guess it would 8 be the AEC in that time frame, as part of the report 9 I referred to, but again not the level of information ;
10 that would be needed for a construction permit.
11 Q The next item on your resume is Program ;
12 Manager as we discussed for the liquid metal fast f breeder reactor technology, which included research
( 13 14 and development programs performed for the U. S.
1 15 Department of Energy in reactor physics, safety, and i
16 component development.
17 How did this differ from your earlier work i
18 on liquid metal fast breeder reactors?
19 l A The work I was involved in from 1968 to 20 1974 was work related to a specific project, earlier, 21 the work on the AI concept of a fast breeder reactor 22 and then later on the Clinch River project, whereas 23 the technology programs for the most part were not 4
7s 21 .
directed 'toward a'speci fic proj ect, but were rather U general development-type of research work.
25 d b
i
1.
1 Keaten 35 O 2 '
Q Were you still doing safety analyses?
i i
3 A There was still safety work, but it was of
! t 4 a different type and was mostly research rather than '
h 5 analytical.
6 Q Your resume shows, and you earlier testified 7 today that you joined GPU Service Corporation in 1978, 8 which would be the next employment following your work 9 in liquid metal fast breeder reactor technology for l l 4
l 10 Atomics International. j l
11 What was your reason for leaving ?.tomics f 12 International and joining GPU? l 13 A I was offered what I felt was an attractive l
14 position at GPU and, frankly, I was concerned about !
-l 15 i the future of the Liquid Metal Fast Breeder Reactor i
16 Program, i 17 .I Q Your resume states that your initial i .
I
- 18 position at GPU Service Corporation was Manager, l '
i 19 { Systems Engineering Department. It also says that you
!l 20 were responsible for the development and application i ,
21 of specialized analytical skills in such areas as ;
22 ,
nuclear core reloade and fuel management, plant dynamic I
23 k and safety analysis, system generating plant process 1-24 1l- computers, control and safety systems analysis and l
25 ,
analysis of plant. operating performance for nuclear l-c a
1 Keaten 36 M(_/ 2 j and fossil plants. Perhaps we could begin by asking i 3 ll what your responsibilities, initial responsibilities
, j' 4 were, upon your arrival at GPU and the assumption of 5 the position of Manager, Systems Engineering Department.
6 A Again, this resume was intended as a broad 7 picture and does not give every detail. When I first l
l 8 arrived at GPU, my position as I recall it was called ;
9 Manager of Engineering Projects with responsibilities 10 l quite different from what is shown on the resume. As i
f 11 l Manager of Engineering Projects, I wat responsible I !
12 for the project activities related to the Forked River j
() 13 Nuclear Station Seward-7, which is a large fossil-fired 14 s ; ion.
l .
15 j In addition, I was responsible for ;
16 l sveloping a new section called Preliminary Engineering, i
17 ! which was intended to perform some of the conceptual 18 engineering in house for the next coal-fired station.
19 ,l Q Do you remember about when in 1978 you b
20 ' joined GPU?
il 21 A It was March or April.
22 h, Q Your resume indicates April 1978. Is that I
23 basically consistent with your recollection?
21 A Either late March or April, 25 Q How long did you continue-as Manager of i
6
1 Keaten .37 O- 2 i Engineering Projects performing the responsibilities ,
1 3 f you just outlined? l 4i A officially until October 1st, 1978.
- 5 Q Was there something unofficial?
6 A Yes. There was a reorganization pending, 7 and I started assuming some of the duties associated 8 with my new position prior to October 1st. i I
What was the next position? !
9 . Q i
I l
10 ; A The next position was as listed here, I
' l I
11 Manager of Systems Engineering, although the :
I 12 responsibilities listed here are as they were about the
[
13 summer of 1980. .
14 Q We'll take them in order. Why don't we go 15 back to the time that you began performing as Manager 16 l of Systems Engineering. First let me ask when that I
17 was, approximately.
18 l A The position became effective October 1st.
i 19 l I would say I was doing some activities which were s
20 ! relevant to the new position for maybe a couple of l
21 i months prior to that time.
g 22 .
Q Sometime during the summer of 1978?
t i
23 A Yes.
21 Q Let me go back before we go forward with 25 . [' that to your initial pe riod, managing project il e .
1 Kooton 38 2 i activities, particularly for Forked River. That was 3 to be a nuclear plant, wsc it not? !
}' .
4 A That's correct.
5 Q Is it correct that GPU had sought bids from 6 nuclear vendors with respect to that plant?
7 A I don't know.
I 8
Q Were you in any way involved with the .
Y 9 preparation of specificati.ons for the proposed F.orked l
10 River ple,nt?
11 A No .' !
i 12 Q Do you know whether it had already been put i
() 13 out for bid at the~ time you arrived? ,
14 A Yes, I do'know, and it not only had been l
15 put out for bid, but an NSS vendor and arch'itect-
,i 16 engineer had been celected prior to tha time I arrived. ,
l '
17 Q Who was the selected NSS vendor? . ,
i l
j 18 j A Combustion Engineering.
ID Q And who was the architect-engineer?
. i .
20 l -A Burns & Roe.
21 Q Seward-7 as you mentioned was to be a 22 fossil plant. Are you aware of who the vendor for the 1
23 1 steam supply equipment was to be for that unit? Was that the one that B&W had been selected for?
~
t 28 .
I
~s_). '
25 A I think-so. -
i f '
l
- --. . = -.
1 Keaten 39 1
(~x (j 2 Q I think there were a number of them, and my i
3 recollection is hazy as to whether it was Seward-7 '
4 or one of the others. I was just curious if that was l
5 the one B&W had been selected for. l rl G A It has been too long. I think so. f' 7 Q Other than project activities related to I \
8 Forked River, Seward-7, and the new section No perform I f 9 l in-house work for the next coal-fired station, did 10 l you have any involvement with the operating nuclear ,
I I
I 11 l' plants in the GPU system during the period April 1978 I
12 l when you arrived up through the time that you began ,
.O
! ) 13 performing the functions of Manager, Systems Engineering?
\%./
14 A Yes.
15 ;
Q Let's establish what nuclear stations'were '
16 in the GPU system at that time. This is April through 1
17 the summer of 1978. My understanding is that there.i !
f 18 was Oyster Creek owned by JCP&L. That was a,GE nuclear s
l.
x 19 l' steam supply system. There was TMI-1 and TMI-2, 9
)
li ,
20 both of which employed a B&W nuclear steam supply, .i
)
! / '
21 i system. Those two units were operated as/I understand O .
, 'l 22 it by Met Ed. . .
/ \* 4 j /
23 First let me ask you, dqes that.,60mpor ,
S 7
x ') 4 with your understanding?: - t
[
it 3 25 "
A Yes, with one exception. oyster Creek was f
,,._, [,
a 9/
f #
,1,' +
~i '
1 y Keaten 40
- (
.l . ,'t (, s r
- :~
.. ! 4. ,
._'2
. /-
J ; 'e
,4 2 '!,,. ! operated by Jersey Central. I am not sure just how -
3 iuA.Ni 3.
,',};,
~ *
, i '. g 'q t 'h e ownership'is.
'/ -
ji 4 i Q Are you aware of any othe r nuclear plants h 5 owned pp operated within the GPU system in the spring
. l 6 or early summer of 19787
-(
$ l s
A Not active nuclear plants, no. .
7l I e
8 Q Were there inactive plants?
9 A Yes, the Saxton facility, j i
l 1
' 10 l Q What knowledge or involvement did you have :
- 4 s l
11 cong6rning Saxton?
i , :
+ t 12 A None. l
/
13 _.j. ,Q . Have you ever had occasion to do any work
=
.. .- v- >.
14 concerning or involving the Saxton reactor? !
~'
.a s 15 : A No.
j 16 Q Did you ever hear from anyone what the i'
" l
' J ," purpose of the Saxton reactor had been?~
17 l
,? - -
t
/ !j .
. f y, / V9 t' 18 [r.; ' ,
A m Yes, I'believe so.- i
- i V ,
s
-' ' ' e '
,j l i 19 / Q g Wh did-you hear or' learn? ,
r 3l.
' 20 y I ,\' A I believe I was told that its purpose or
. /
's s
_. J (,, ,*
one of its purposes was to gain experience which would 21 l
'O '
"a ' L j ' :,m~
. 1 y , -22 ? be useful for future, larger commercial nuclear plants.
9 23 l was Saxton a pressurized water reactor, j Q, ,
pn, g
, ,,,- , 8s# '
f' [ ,21 !.
t tothe[_tct -_.e of your knowledge?
s x4 A( i, Oru
=t :
25 j.
.I believe'that it was.
i
- f. .
-Y
~
4 ;
.f i
, ;y' : f'7y % . ; ,yl . .l R p ;j. ,
,9 . 23 . _.
v . ' v, v.s 1
1 KGaton 41 Are you aware that it employed a
( 2 Q
!; Westinghouse design? i 3 ,
I: ,
4 ll A I believe I have been told that, yes.
l I 5 Q Have you ever heard or learned what use, 6 if any, has been made within the GPU system of knowledge 7 gained from the Saxton reactor?
1 8 A Not to the best of my recollection.
I l
9 Q In particular, do you know whether anything 10 l learned at the Saxton reactor was ever used in l l
i t
11 training of operators within the GPU system? l t
t 12 A I don't know. j 13 Q Do you know whether any analyses were 14 performed of transients that had occurred at Saxton?
i
' A 15 I don't know. !
16 Q Do you know whether any use was made of 17 i operating experience generally that had taken place 18 at Saxton? !
t 19 A Generally, I don't know. I do know that 20 [ the representative from GPU who was stationed at Atomics 21 International had previously been at Saxton, and I ;
22 believe some of his experienecs there were factored i'
23 into comments that he made on the fast breeder program.
21 Q Have you ever become aware of any system or 25 program within the GPU system to get information and l
l'
[
1 Konton 42
[~T 2l experience learned at the Saxton facility to the !
(-)
i
! ; l 3 ! operators of the commercial plants within the GPU l
4 system?
l
-llh 5 A I have not become aware of any such program.!
6 Q Do you know whether the information and 7 records concerning the Saxton reactor were kept and I
8 located in any particular place within the GPU system? I i
9 A I don't know. j i
)
10 Q For instance, if you were interested in i i
11 finding out what transients had occurred at Saxton l I
12 during the time of its operation, do you have any l
?
1 13 knowledge as to where you might go to find that type y 14 o f material? :
l i-15 A I do not personally have such knowledge. I 16 Q Do you know whether~those records have
. i 17 been kept? l i
18 A I don't know.
19 Q I take it you wouldn't know where they were i 2 20 l kept, if they had?
! l .
I 21 A That's correct.
i 22 Q Do you know who operated the Saxton reactor, whether-it was one of the operating utilities or 23
[I
- 4 whether it was done through GPU Service?
i
(~T w/ 25 , A_
I' don't know.
I i
L i 4
1 , Konton .43 j '
2 Q We were discussing work that you performed ,
'l 3 after your arrival in April '78 for the operating i
4 l. commercial plants, TMI-1 and 2 and Oyster Creek, and I 5 we had come to the point where you were going to tell 6 us what your work for those plants involved during 7 that initial period.
8 A Shortly after I came, there was a transient I, I
9 which occurred at TMI-2. GPU personnel participated l 10 in an evaluation of that transient, and I was one of 11 ;I the people who participated in that.
12 Q I take it this is the April 24, 1978 g
( 13 transient at TMI-2 involving an overcooling incident?
14 1 MR. GLASSMAN: I don't know that there was !
I i 15 ll a transient on April 24. !
I 16 MR.' WISE: I may have~ the date wrong.
17 l MR. GLASSMAN: The 23rd.
18 ; MR. WISE: Is it the 23rd? -
I E
-19 l -Q On or about April 23, . 1978.
i 20 f A Yes, I believe that's' correct.
21 Q We'll come back to that;
'22, A The other involvement with operating plants i.
23 which I presently recall is that I was_made a. member q 24 of:the General Office Review Board'for Oyster Creek, l
.(V 25 '
and I participated in'those meetings.
! i s
S
-m- --, r - - . .
1 Keaten 44
[ , !
' During this initial period, what steps 2 i Q
3 l' did you take to familiarize yourself with the existing l 4 operating plants in the GPU system? I am speaking 5 specifically of the nuclear plants.
6 A I participated in tours of the principal 7 'GPU plants, including TMI-2 and Oyster Creek, and I 8 did some general reading about those plants to a degree, 9 but ~ I should clarify that my role and in general the l 1
10 role of the Service Corporation at that time was 11 l directed primarily towards its new plants and with only l 12 [' a few exceptions, we really became involved in the l I
existing plants primarily upon request of the operating l 13 u
I 14 9 utility. l b I 15 lj' Q Before April 1978, had you in your work 16 experience been involved with any commercial 17 pressurized water reactors? ,
18 -l A To the best of my memory, no. ,
19 , Q Would it be fair to say that there are major
! 4 20 ., differences between the. liquid metal fast breeder 21 reactor and a commercial pressurized water reactor !
22 such as TMI-1 or 2?
Y 23 - l A There are significant differences, yes.
24 You mentioned that the Halden project-was
{ '} Q 25 a boiling water = reactor. Other than that_ project, had l.i 1, .
7.- =
I Keaten 45 2 you had any experience with boiling water reactors in 3 commercial power plants?
I 4
I-A In commercial power plants, no.
5 Q When you first joined GPU Service in April 6 1978, to whom did 3ou report at that time?
7 A To Mr. R. F. Wilson.
! t I
8 Q What was his title then, if you can recall? i i
I 9 A I believe his title was Director of 10 2 Technical Functions.
11 Q Did you have anyone working for you at that !
i 12 time? '
l
() 13 A Yes.
14 Q How many people? f i
1 15 A The Project Engineering Manager of the l ,
16 lt Forked River project reported to me, and'he had about 17 eight or ten engineers under him. Then there was one l !
18 i GPU employee and one engineer on loan who were working .
l ! ,
19 f on the Seward-7 project who were reporting to me.
I Il 20 i Q The Combustion Engineering design is a g 21 pressurized water reactor, am I_ correct?
22 A Yes.
23 J' You wanted to' add something to1your last Q
21 answar? I
$- 1
,J. i 25 , A Yes..
I 5
l
1 Keaten 46 2h Q Please go ahead and do so.
l
'i 3y A In addition, during the time frame in li 4 question, I promoted a GPU employee to Preliminary
?
5 Engineering Manager. At least I believe it was during l 6 this time frame. Either during this time frame or 7 shortly thereafter, 1 hired two or three people for 1
8 the Preliminary Engineering Section. l
.' t 9 Q Concentrating just for a moment on the I
10 . Forked River project, because that is the only one of
! I 11 , these initial projects that was a proposed nuclear
! I 12 ! plant, what aside from the plant tours th'a t you had i
(
13 at TMI-2 nd at Oyster Creek did you do to familiarize j 14 i yourself with the technology of a pressurized water ,
l 15 ,
reactor such as-would be built at the proposed Forked i !
16 ! River plant? Did you attend any seminars, take any I
i i 17 -
evening courses, talk with people within the GPU I
18 system, read any specific literature or documents f,
19 that were available?
I 20 If you could give us some' flavor of how you 21 went about getting up to speed, if you will, on i
22 pressurized water reactor-technology in or about April 23 '78.
g 24 A I did some general reading about q ,)
, 25 !
pressurized' water reactors, and I had conversations with 1
n 4 . - . - . . -
1 Kosten 47 i
( 2 [,. GPU employees about pressurized water reactor
- l 3h technology.
4 ! Q Who within GPU did you talk with about that? l l
5 A Different people, depending-upon the I
! 6 specific topic. l l
7 Q Regarding the basic technology of the 8 nuclear steam supply system, and particularly the ,
4 9 operation of the primary system, who did you regard 10 l as most knowledgeable at that time within the GPU i '
11 l system?
- l 12 MR. GLASSMAN
- You are talking about Forked ,
. I 4
() 13 River?
14 MR. WISE: No, about learning the technology, 15 i hehind the pressurized water reactor in general.
f 16 A I don't remember that there was any one l
t 17 individual that I regarded as-the most knowledgeable.
18 'There-were a variety of people within the Service 19 Company that had knowledge in one or more aspects of
- ' . t 20 pressurized water reactor technology.
' 21 Q For instance, with respect to 22 'the rmohy d rr.uli c s or thermodynamics within the primary i
system, is there anyone within,the GPU system to whom
-23 }
- ') 1 you looked at that time as being knowledgeable?
V
- 25 l A Yes,-there was more than one person that I' I
i ,
' i
,v. . . , --
e- , - _ - - , + - - . , ,, _
1 Keaten 48 1
() 2 i:
q looked at as being knowledgeable in th at area.
3[ Q Who would you consider knowledgeable on ;
i
, 4! those types of questions?
. I 5 A At that point in time, Mr. Gary Broughton, I
I 6 Mr. Ed Wallace, and Mr. Nick Trikouros.
7 ! Q Is Mr. Wallace still with GPU?
s 8 A Yes, he is. !
9 j. Q Is Mr. Trikou'ros still with GPU?
f i 1
10 -
A Yes, he is.
i I l
11 Q Who within the system, if anyone, did you j
. 12 ,
look to as being most knowledgeable concerning safety- -
analyses for pressurized water reactors?
( 13
{
l 14 i MR. GLASSMAN: You are still-talking about I l 1 l 15 , the same time frame?
16 MR. WISE: Yes, during this time period
'. I I 17 I l when he was joining the company and learning about; I I!
18 h the types of commercial plants within the.GPU-l '!
i 19 h system.
i' 20 i! A To the best of my memory. I would say Mr.
i.
21 Broughton, Mr. Wallace,and perhaps Mr. Ron' Williams.
i 22 Perhaps others. I can't remember that clearly, l'
'23 >: Q Did you become familiar during this time
~
h 21 ' " period with the system which on the B&W' plants.was known-
- O 25 q as the high-pressure injection system?. It may have been i
t l.
. . . , _ . . _ - - . 4
l' Keaton 49 j ) 2 known by other terms on this combustion Engineering 3' N plant. Did you become familiar generally with that >
-4 , safety system as part of a pressurized water reactor ,
I llh 5 design?
6 A To the best of my recollection, I became 4
7 generally familiar with the functions of such a system, ,
8 probably not with the details of the design.
I 1
9 Q Who within GPU would you look to with !
- 10 respect to any questions you may have had at that time .
I i
11 regarding emergency core coolihg systems? , j 12 Who would you have regarded as knowledgeable in that l 13 area? ;,
]
14 A With regard to the functions and 13 .: requirements of such systems, it would be some of the i r 16 same individuals that I listed previously. '
17 Q What was Mr. Broughton's position at that i
18 l time?
f 19 f A He was Licensing Manager-for the Service i p 20 !! Company.
21 Q To whom did he report?
2 22 ,
A He reported to Mr. J. R. Thorpe.
23 Q Was that part of the same chain of command l' "4 that eventually got to Mr. Wilson, or was that in some
(~T
- 25. !'
other unit?'
i.
i
1 Koston 50 2 A It was independent of Mr. Wilson at that !
3j point in time. t i
4 l Q what unit was Mr. Wallace in? I 5 A At.this point in time, he was part of the l 6 Forked River project engineering group under me.
7 Q Jo he was working for you? l i
8 A Yes.
9 Q And Ron Williams?
10 '
A He was Manager of-Engineering.
i 11 Q Was that a position above or equivalent I
12 to where you were? I 13 A It was parallel to my position, also O
! i 14 reporting to Mr. Wilson.
15 i Q And Mr. Trikouros?
i !
+
16 ,
A Worked for Mr. Broughton in the Licensing. ,
I i 17 i Q Now let's move forward to the time when you ,
i .
18 ll became Manager of Systems Engineering in the summer of ,
l' t 19 1978 unofficially, and I take it officially. October 1st.'
. i i
, n 20 How did your duties and responsibilities change,at 21 that time?
.22 A. The two project engineering groups which I i
23 described earlier, namely,'the Forked River and the 21 Seward-7, were removed from underneath my_
s/ 25 responsibility and returned to reporting directly to f
I
[ 1 Koston 51 2 Mr. Wilson, as they had been prior to my arrival at i
3[ GPU, and two sections which had previously been part of a
n 4f the Engineering Department under Mr. Williams were i 5- transferred under me, those two sections being the j 6 Nuclear Fuel Section and the Process Computer Section, I.
7 and then a new section was formed, also under me, 8 with the title Control and Safety Analysis, which 9 assumed the responsibilities for the analytical t
10 activities that had previously been performed as part 11 of the Licensing Section. '
12 Q What analytic activities were those? h A Activities associated with any of the
( 13 14 safety analyses for the nuclear stations. f 15 Q Did this include both the existing stations l -
16 as well as planned additions?
17 A At this point in time, the activities as 18 lli I recall in this section were primarily directed i
19 I toward the future nuclear plant, namely, Forked River, i
'i
[. 20 !' but were really concentrated on' developing the
! i 21 capability to perform such calculations within-GPU 22 rather than relying on outside vendors.
I
- 23 Q Why was that?
l l
! l 28 , A This was a part of.the general change in
~
25 ' philosophy of the'GPU Service Company to build up the i
}
I l- .
I Keaton 52 j} 2l in-house capability for doing at least some engineering v .
I 3 '- work in all different areas of engineering that were 4 important to GPU.
lh 5 Q If a problem arose at one of the operating i
6 plants that required further safety analysis, would l
l 7 it be true as a result of this reorganization that that 4 i
1 8 work would come to your shop as opposed to some other j 0 unit within the GPU organization?
10 A Not necessarily. I l
11 Q I am interested now in trying to understand 12 I what responsibility you had for safety analysis at i (3 13 -l the operating plants as opposed to any othe r units j
\_) ;
14 within the GPU system. ;
l 15 : MR. GLASSMAN: Just so I understand the 16 question, I thought counsel'was seeking 17 clarification of an earlier answer in which Mr.
}
18 Keaten distinguished between the work of his j
i 19 j; group and the work of GPU vendors, rather than b
20 make a distinction between his group and _
21 operating plants, so that I am not sure that.I
'G- i-22 i understand the con..:ttion betweer. this question d
n 23 [ and the earlier one on which you' sought clarification.
21 [ -
O(_/ 25
[ Ma. WISE: Perhaps now'I am-confused. Let 1
i
1 Konton 53 '
4 2 i me restate it.
I 3 BY MR. WISE: .
4 -Q My understanding was that when you took over:
5 as Manager of Systems Engineering, two sections from i
6 Mr. Williams' group were-transferred to yourself as l 7 well as a third . section which was newly transferred
. I 8 from the Licensing area involving control and safety .
4 9 analysis, i i
10 A Yes, that's right. With respect to this 11 third section, Control and Safety Analysis, it assumed j ,
i 12 the responsibilities for some analytical work that had ,
13 previously been done' in the Licensing Section. The (V~) '
14 Licensing Section remained,'but without responsibility ,
1 15 for those analytical activities, but this was done I l i 4 16 within the confines of the general philosophy of the .
I
- ! 17 Service Company which was, with a few exceptions, that ,
I IS we were primarily looking at the new-plants, so the .
19 Licensing Section and the Service Company.and the
- 20 analytical activities that subsequently came out of 4
- 21 that were really directed toward in this case Forked g
i 22 i . River.
I i
23 I However, in order to build up the 21 ;
analytical capability, we were in fact starting to O 25 - j i
develop a pressurized water reactor transient analysis s
- - - , , , , . - - . . . -,.y- , ,, +-, g- -r, , ere,,, , e, - g
4 l
1 Keaton 54
/^% code, and we developed this using a model of Three i
() 2.[
N 3 Mile Island because we felt we needed to be able to f ,
I 4 i bench mark our model against actual available data, and !
I h 5 there was of course no available data for Forked River, l l
6 so while our philosophy was directed toward the future i l
7 plants, in fact the computer model that occupied a ;
8 certain fraction of the time was in fact a model of I ,
9l Three Mile Island Unit 2. .
}
l 10 Q Why did you choose Unit 2 rather than 11 Unit 17 i l
12 A It was a matter primarily of the April l I) 13 l transient. At that time, the activities were not
(_/ I 14 under my management, but as I understand it, the model !
l 15 was to the point that it seemed like ready to start I
16 l using it and here was a transient we were asked to ,'
t i 17 participate in evaluating, so it made a natural first l
18 application. In fact, the model has been used~ for both Il 19 ll Unit 1 and Unit 2.
l 20 <
Q Did that model have any name?
i 21 A The model is based upon a computer code G.
22' l called RETRAN, and so this became known as the TMI I
i l 23 l RETRAN model.
I.
I 24 h Q Who developed RETRAN?
7; O. '
L-l
() 25 ,. A LI t was developed by Energy, Incorporated.
'l l
I L.
1 Kocton 55 i
[ 2 i Q Did they sell that program to GPU?
V 6
'l 3 !! A The program development was paid for by i
I .
4 the Electric Power Research Institute, and we were able ,
t 5 to obtain it through EPRI. 1 6 Q Let me go back now for a second to the !
7 Control and Safety Analysis Unit and see if I got it I
8 right now. I understand what you have said, but I an ;
4 i
9 looking now at it from a slightly different angle i
10 , and that is, trying to determine who within the GPU !
t l
11 system would be performing safety analyses such as i i
12 they may have been required with respect to the
[}
U 13 operating plants.
14 Let me put the question to you this way. 4 i
15 Besides the Control and Safety Analysis Unit that'came 16 l under your management at this time, what other units 17 are you aware of that were also performing safety l
18 analysis work for the operating plants within the GPU
, 19 system?
I 20 A As part of the operating utility, there was i
21 a licensing section both for Three Mile Island and for
~22 Oyster Creek. Safety analyses which were required 23 for the operating plants, according to my understanding 24 of the organization as it then existed, would have been O
V 25 the responsibility of those organizations, but I'should I
i
I Konton 56 2 also point out that in general very little of the :
J(
a .
3 .l' safety analyses that were required either for the 4 lj existing plants or for the new plants were performed 5 by GPU. In general, we would go to the nuclear vendor l 6 to do such analyses for us. ,
l 7 Q What about with respect to secondary system ;
i 4
8 matters or balance of plant matters where the nuclear 9 vendor had not been involved?
10 i A In those cases, the general i.pproach would !
l !
i 11 l have been I believe to go to the architect-engineer, I
' l 12 although it is the nature of nuclear plants that most i
[)
V 13 of the safety analyses per se are associated with the f
i 14 I nuclear side of the plant.
Q You began your work as Manager of Systems 15 lI ll.I 16 i Engineering, as you said, unofficially in the summer 17 of '78 and officially in October, and you described the 18 h setup of that unit initially.
l l
19 1, could you detail what changes, if any, took l
20 place between that initial organization and the time i-f of the Three Mile Island accident, which was of course 21 i
- 22 at the end of March 1979?
d 23 A Organizationally, it remained the same i
24 during that period,_ although we were attempting to C)-
increase the staff' size, so we were hiring, but the 25 !I :s n
h I!
l-I
. _ , . - _ _.,o , , _ . . .
'l Konton 57
<- t
'(_,)/ 2l . organizational structure stayed the same. !
. 3 !! Q Did the functions of the unit change !
I .
4 ! during that time period? l t
, 5 A No, I don't believe they did.
6 Q Did your unit perform any safety analyses 7 with respect to TMI-1 or TMI-2 during that period? g I
8 A I am not sure.
i 9 Q Do you recall whether your unit was involved; 10 in investigating any transients at TMI-1 or TMI-2 i I
11 other than the April 23, 1978 event you mentioned '
12 earlier?
[))
13 A I don't recall that we were, as you say, I
i 14 investigating any transients during that period, j I
l 15 although I mentioned earlier as an ongoing development 16 l activity we were trying to bench mark our computer 1
i ,'
17 code, and so during some time frame, we have gone i g 18 back and taken data from other transients and used it 19 ,
to compare against the computer code.
l 20 4 Q Just to be sure that I have got it straight, 21 you have no recollection of any assistance that your 9
22 ,
unit may have provided'from the time of its existence l l
23 up through the time of the accident to the operating 21 . utilities with respect to any transients that they l
C 25' ,
may have had at TMI-1 or TMI-2? -
i f
l
1 KGaton 58 ,
I
( 2 i A That's correct, I have no such recollection.
9 Q Following the accident, could you briefly 3
ll I
+
4 describe how your responsibilities changed and the i 9 5 approximate time periods that are relevant to those 6 changes?
7 A Immediately following the accident, I and 8 many of the people in my department spent extended ;
9 periods of time at Three Mile Island in support of l 2
f 10 Unit 2. After we returned from those assignments, I I
i 11 the emphasis of the organization shifted substantially. .
I 2 12 As I recall, our activities were primarily-directed l [
/~ 13 toward a review of the TMI-2 accident and~related I Nh) I 14 l factors and in starting preparation for a restart of i t 15 TMI-1 and some work which we did relative to an Oyster l
16 Creek event which happened in May 1979.
I 17 Consistent with the changed state of the ,
18 GPU system, the Preliminary Engineering Section,.which 19 1l had been under me,'was dissolved and-activities
!I
! 20 i related to future projects, future coal-fired projects, g_ 21 wera either terminated or.were transferred-outside of -
22 the Se rvice Company. A new section'was formed under I .
23 me, and I don't. remember exactly when this occurred, 21 L called Plant Analysis.
[~N ! .
~%^) 25 what was the function of Plar.t Analysis?
Q I I l ~l ,
1 Koston 59 2! A Plant Analysis as oriainally conceived was l
l 3! intended to monitor the performance of the equipment i
f at the nuclear stations on a continuing basis in order 4 ! ,
I 9
- 5 to give feedback to the operators about probable l 6 problems that might develop.
7 Q Which unit of GPU had performed that l
8 function before the Plant Analysis Unit was put under I 9 your management? l l
- 10 A I don't know in general. There was a !
l 11 section within the GPU Service Company which was i
12 intended to monitor plant availability and' system and t 13 component availability for all of the GPU plants, but l
14 that does not encompass all of the intended functions ,
I 15 of the Plant Analysis Section. !
l ,
i i
1G Q Do you remember the unit, the name of the 17 unit that did that or who'it was under?
'l I
, 18 j A I believe it was a department, and it was 1
19 under Dr. R. L. Long, and I don't remember its name.
l.i
, 20 i! Q Do you know what general department Dr.
! Long was in?
21 Was he someone who repo rte d to Mr.
ggg 22 . Wilson or some other general organizational unit?
23 f A He did not report to Mr. Wilson. I l
21 believe --
I-am not sure where he reported.
.25 l Q Dr. Long is still with GPU, I take it.
i i
I i il l
. .. - . . -- ._ ~ .- . .
r __ _
1 Konton 60 h( '2 A That's correct. !
,1 .
Q Your resume that counsel provided us with 3 ll it ' !
4 0 .today, B&W Exhibit 335, shows a change in title which 5 _I think you testified earlier today occurred in G January 1981 to Director of Systems Engineering. We 7 touched on this briefly before and said we would come 1
8 back to it. I am afraid now is the time. j i
9 Could you tell us what changed in January l t
l i 10 f 1981 in connection with this change in title? '
11 A Generally, the department organization l t.
12 structure was expanded. Do you want the details of the !
13 expansion?
-( l 14 Q Yes, please, in general. I don't want to i 15 i know person by person, but what functions and 16 responsibilities were added or subtracted from the unit?
17 A There were two new sections established, ;
I 18 Radiological Engineering and Risk Analysis. In 19 addition, there was a new Assistant Department Head i
20 l position established with the Plant Safety Analysis gp 21 and Plant Control Section, which was simply a renamina 22 of the previous control and Safety Analysis Section.
l.
t 23 Those two sections _ reported to the Assistant Department 24 Head.
25 ' j Q- Who was that?
t 1
)
i l
l 1 Keaten 61 ;
l O. 2 j
i A Mr. Broughton.
O 3 j Q Who now has Licensing?
il I
4 A The Director of Licensing is Mr. J. R. ;
. 5 Thorps. The Manager of Licensing for TMI is Mr. Ed I
i 6 Wallace, and there are comparable sections for Oyster l 7 Creek, for Environmental Licensing, and for Generic j i
8 Licensing.
I I
9 Q Mr. Wallace reports to Mr. Thorpe? ..
I 10 A That's correct.
11 l Q In effect, Mr.-Thorpe has Mr. Broughton's !.
12 old job? l
() 13 A No. Back where we started, Mr. Thorpe was i
14 l Mr. Broughton's superior, but also under Mr. Thorpe {
l !
15 l were an Environmental Licensing Section which Mr. !
-t
[
16 Broughton did not have, and I believe one other 17 ,
section, but the other difference now is that the
\; .
18 i Licensing Sections which supported the operating plants i
19 l are now part of this organization which I am '
d 20 ; describing, so that for example, personnel located at ,
Y <
21 l Three Mile Island who were previously Met Ed employees ,
22 ,
are now part of Mr. Thorpe's-Licensing organization.
d 23 ! Q .And they work for GPU Nuclear?
I g 24 j; A That's correct.
,l 25 ,
Q The Risk Analysis Unit that you mentioned l
1
l 1 Konten 62 1
5 2 that was created in January 1981, how many people does 1,
3 !' i-that have in it?
4 A At present, it has two. l
)
9 5 Q Are you familiar with a Risk Analysis i
6 Report for the Oyster Creek plant that has been done 7 in the last year or two?
8 A I am generally familiar with it, yes.
9 ; Q Was that done by this unit within your f I
10 organization?
11 A No. It was done by an outside contractor ;
12 and was managed internally by a team that consisted of l l
13 people from Jersey Central and one or two people in the l I
.) 4 14 Service Company. l
?
15 Q Were you in any way involved in the review t
16 of that report? ,
i 17 A I was an attendee at the meeting at which ,
1 18 I the vendor made the presentation to GPU management on 19 the initial results of the study. In that time frame, 1
20 !; that is the only involvement I remember having.
P, 21 Q Have you read the study?
g 22 l A I have read parts of it.
ii 23 ll Q 'Who within GPU was primarily responsible 21 , for this project?
% 25 A The primary involvement-within GPU on that i
i.
1 Konton 63
() 2 _p roject was Mr. Broughton and Mr. Trikouros. Excuse 3 me. I answered your question within the context of 4 who within the GPU Service Company was primarily 9 5 involved.
I l
6 Q I take it that there may have been some 7 people from JCP&L who were also involved?
8 A Yes, and they played a very strong role in ,'
9 the study.
I 10 Q What was the reason, as best you know it, f l
for the study?
11 l i i,
12 A As it was described to me, there were two 13 basic reasons. One, recognizing that Oyster Creek is 14 l a relatively old station for a commercial station, i
15 l there was a desire to attempt to answer the question of IG whe the r the risk associated with operating Oyster
, 17 i Creek was substantially different than for a more Il 18 typical nuclear station, and secondly, there was a 19 1, desire to provide information that could be used in b
i 20 ;j making decisions such as, for example, what type of f
, i g 21 plant improvements would make the most contribution to overall safety.
22 l i
23 f Q That study considered a range of accidents, 21 as I understand it, some of which might result.in 25 l- serious core damage, is'that correct?
. i-
l' Konton 64 o
I 2 ^ '"-
. 1, l 3 Q Do you know whether as a result of that i
4 study any reports were made to the NRC pursuant to l 1 1 I 5 10 CFR 21?
6 A I am not aware of any such.
7 Q You are familiar with 10 CFR 21 in general?
6 i 8 A I have a general familiarity with it, yes.
9 Q Did you believe after your review of this I l
10 i study that any parts of it required reporting under l 11 10 CFR 21?
4 I
12 MR. GLASSMAN: You are asking for Mr. !
l 13 Keaten's belief? I 14 MR. WISE: I am just asking whether he ;
i formed an opinion that it was necessary for him 15
! I 16 to take action to make a report.
6-I 17 MR. GLASSMAN: Objection. I am not going i '
18 to let you probe his mental processes. If he 19 expressed an opinion, if he took any action, I il will let you ask that.
20 L Ii i
I- 91 Mk. WISE: I think I can live with that.
L IB>
- 22 ; Q Did you in fact take any action to 23 initiate a preliminary safety concern within the GPU 24 p system concerning the results of that study? I may have a p l
kf- 25 1,
used terminology you are not familiar with.
I 1
i
1 Koeton 65
- 1
(~N, - 2 { Preliminary safety concern is one term I have heard.
k/ }
3 ; Different systems or different operations may have i
4 i! different internal procedures for reporting concerns 5 that may result in a requirement to notify the NRC under 6 10 CFR 21. There may be a di f fe re nt terminology for it 7 within the GPU system. Whatever that terminology may 8 be, did you in fact initiate whatever process there is 9 within GPU which would lead to consideration of whether 10 or not a 10 CFR 21 report was required?
l 11 MR. GLASSMAN: Objection as to form. I f
i !
12 A I took no such action.
{
l . !
13 I Q Do you know of anyone else who did? '
l 1
- i i
~
14 j A I do not know of anyone else who did.
l 15 Q what.is Radiological Engineering?
16 i A As intended in this' organizational function, i
17 l, it is personnel who are specialists in various aspects 18 ,
of radiation effects,.both source terms, release of-19 radiation, shielding, and the-so-called ALARA concept.
20 Q Could you explain for the record what that' P
21 ! is?
I .
t 22 ' A ALARA stands for as low as reasonably i
23 achievable and refers to the concept that in designing 24 to cope with radiation as it exists in a normal
,-s t
(_ 25 h operating nuclear plant, that the regulations require n . '
'i 6 - 1 s
a n -r
r i
1 Koston 67 2 section Plant Analysis is still a separate section, f
{~)'}
N m ll l
each with a section manager. There is just an 3 g I
4 ! additional layer of management above them. !
I 5 I neglected to mention in describing the 6 o rg aniz ation that was formed at the beginning of 1981 7 that there is an additional function called Human 8 Factors Engineering which reports as a staff function 9 to Mr. Broughton. In terms of changes, the changes 10 which have occurred since the beginning of 1981 are 11 structural rather than functional in nature. There is 12 now an additional Assistant Department Head, and under {
g- 13 l
him are two section managers. The Assistant Department j
\_/ j!
Head is Nuclear Analysis and Fu els and under him now' 14 { '
l n
15 il there are a TMI Fuel Section and an Oyster Creek Fuel 8!
16 Section and the radiological engineering function.
17 l Q When was the Human Factors Engineering i !
I 18 :- function added?
O 19 A It was at the beginning of 1981.
f I
20 Q What is its purpose?
21 A Its purpose is to bring to bear the 22 ,
discipline o f human factors engineering into the design I
'F -
i 23 or layout of particularly the control rooms and also to i I' ,
21 other control sections.
( ((")h 25 .
Q Who presently is head or responsible for t
L i I
s t
1 Kocton 66
(
- ) 2 that shielding and other forms of radiation protection R,l l ,
. i 3h n t only meet certain specific numerical criteria, n,
l 4 il but must go beyond those criteria and result in, dose
'l \ l h 5 rates as icw as reasonably achievable. / f, J
6 Q Altogether today, how many employees do (
t l',
7 you have that report to you, roughly? 3 ,-
I>
8 A About 70. Of course, not all of those report ,/
9 3 directly to me. /,
Q I understand. You may 1, ave dehhrtme ntitl .
10 h. i
<1 l- '
~ al 11 I heads underneath you. ! ) .
< i l
12 A Yes. :
!/
,/] 13 MR. GLASSMAN: This question is directed i
\.J ,!
14 ll to 1982? ,
lll i
15 '! MR. WISE: Yes, today.
l
!\ i 16 A Yes, I interpreted it as today.7,i' ,t l
t ;i 3
/
Is the department today basically'the' 17 1 Q ,
O 18 jl same functions and responsibilities as you have hwe '
,1
. .-/ ,
19 i' described beginning in January of 1981, thdt is,
) r ',i l y -.j / ,
20 j' Radiological Engineering, Risk Analysis", -a'nd < a combine d ,
t e
y' ,.
y' ,
21 ! section that has Plant sis and Control and I
/
h l Analy\
Safety Analysis or its successor within it?
,d '
22 ll '
l
- '/
23 A Let me first clarify what I said ecrlin.
24 The section that is now titled Safety Analysis and l, 25 i Plant Control is still,a separate section, and the -
1 . :
h -
3
$' .l bl l G'
.A .
, .. . = . . _ - .
t .
.8 1
1 Konton 68 s
& /
2 that function?
i 3 ,
A As I indicated earlier, Mr. Broughton is i t ,
1 z~ 4i personally responsible for that. !
5 Q Who, though, underneath him is the primary l
/ 6 acter, if you will, on human factors engineering?
] .u '
s u 'i . '7 A We have two relatively junior specialists
- in this area which report directly to Mr. Broughton, so e s .
- N . Y,. he does in fact carry out the management activities !
r 33y +. j - i I t I
l'
\ 1 3 ,. TO ' c '- i'n this area.
,f, l-.
- +
I
. . l
) ,
," @ ,, # j Q- Before this responsibility was added to ,
6
.i j Q, ~ '/ )l t
{
g [ U. s s / "y Mr.' ,Brough ton 's duties , where within the GPU system, j y . . >
.i, p ,7
- , . .i to your knowledge, was this function being performed?
1
,' bj 13 -
t t , .
, s V i 14 ffy A For new plants, currently under design, the ,
/ .
,. j 15 (dtivities within CPU would have been done either in
' ( \\ <
i
- ,7 ( 16 the Engineering Department or in the Project Engineering 4 ',V i e
1
., i 17 Management Section, and I do not know what was the s \ :
a w A' k, 18 I situation with the operating plants.
g, t '
'/ 19 *'/ R I would like to go back int .1 moment to
. f- d 8-
/, e,
' t
-[ \ '
$0],'q1,978whenyou r
joined GPU. What system or procedure
- -_ l ;*
k . /. *!,[ ]
was{in.effect at that time with respect to reporting dg ..Tg u / Ns l 'y f .gr ,
y' h _
+<
2 ,!
l s a4 f.e ty.,= ,' con;:e rn s in compliance with 10 CFR Part 21?
r t
. 23 h'
a t MR. GLASSMAN: Objection; lack of g g , t'I A "b ., g .,
~24 L '3 i t ,f o u n d a ti o n .
1 4. 1 r ) %
3 1% JQ " h , , r- ' , ,
y- // ?J,y , &j .!5 , ; MR. WISE: I don't understand what the lack M j- g f 7f , -N..". T 4 .r
~
ll ej '? L, *
~
cr. . .. ,l r <
le T '/ * // i '
^
C s : e.
,' ;W) . *' s . .
f
- 8. (... , , _ ~ _ _ +
1 Kcaton 69 2 -! of foundation is.
3j MR. GLASSMAN: I don't think you have is 4 1 established this witness' knowledge of a 4
llk 5 particular regulation.
6 l MR. WISE: If he doesn't know, I will take ,
l 1
7 that answer.
i i
8 A I don't know.
l 9 BY MR. WISE:
10 Q When you joined the company, did anyone i 11 give you any instructions or information concerning i
! I 12 I compliance with 10 CFR Part 217 ! ,
t 13 A I don't recall any specific instructions j 14 with respect to Part 21. !
15 Q When did you first become aware that there 16 was such a thing as 10 CFR 21?
17 ! A While I was with Atomics International.
- 1 18 i Q Were you aware of changes that had occurred
, I j 10 ! in the 30 CFR Part 21 program in the summer of I 00 ~e believe it was.1977 to become effective early in 1978 i
I i
21 with respect to operating plants?
ID
" A I have no particular recollection of that.
l'!
23 Q old you have any understanding in April
-21 1978 as to the applicability of 10 CFR 21 to operating (O_) 25 plants, as opposed to plants under design or t
., . . - - , - - . - - , - - - - , .- - , --- ,y--
i 1 Keaten 70 2 construction? ,
I 3 A I don't remember what I knew in April 1978 I versus some other time on that subject, at least. I 4l 5 Q Did you ever come to have an understanding 6 that 10 CFR 21 applied to operating plants? l i
7 A I have been told that 10 CFR 21 does apply J
8 to operating plants.
9 Q Were you told that before the accident at I 10 TMI-2 in March 19797 I
11 A I don't know.
12 Q Is there today a procedure which you are l
13 familiar with for reporting safety concerns that may be 4
l 14 reportable to the NRC under 10 CFR 21 within~the GPU 1
1 4 15 system? *
- 16 A Yes.
i I
17 Q When was the first time you became aware 18 of that procedure?
19 ,
A I don't remember. ,
l 20 l! Q Do you remember approximately when that 21 procedure was instituted? '
?
22 A There is a relatively new procedure which-l I
- 23 l' is one of the technical functions procedures'which is I ,
21 intended to describe the responsibilities as they now a
j 25 { exist in the GPU Nuclear Corporation. PriLr to the i i I !
r
, - -,, ,- ,. - - , , . , -n, , - - , , - . - ~ , , . , - -
1 Kooton 71
(~T I GPU Nuclear organization formation, the responsibilities
(_) 2 i 3 for reporting events at the. operating plants lay with Il !
4 the operating utilities, not with the Service Company, 9 5 l and somewhere along the line I became generally aware 1
6 of that fact, but I don't remembe r when.
7 Q GPU Nuclear was formed after the accident, 8 as I understand it.
9 A GPU Nuclear has become officially a corporation only very recently. The GPU Nuclear Group, 10 l 11 which was the predecessor of the Corporation, was i 12 formed well after the accident.
() 13 ,
Q so if I understand your testimony correctly,[
i 14 you are not aware one way or the other as to whether '
15 l or not there was a procedure in place at GPU Service IG ! for the reporting of safety concerns that might be ,
17 reportable under 10 CFR Part 21 before the time of the l
18 accident? '
ID , A I think that is correct. I am not aware one b
20 way or the other.
g 21 Q If there was such a procedure, you are not -
22 able to tell us today what it was?
a 23 [ A That's correct.
l l 24 ( Q Did you ever have occasion before the g)
\_
\
25 (k l;
accident to consider whether a particular matter was I
.i l.
1 Keaton 72 2 reportable under 10 CFR 21 while you were at GPU? I ;
il i 3 - am picking up from 1978 on.
i 4 f MR. GLASSMAN: As I understand, the 5 questions relate to before the accident but 6 beginning 1978.
7 Q That's correct. I am looking at the period i
8 when you joined the company up to the time of the 1
9l accident, did you have occasion to become involved in !
I i
10 a matter which was being considered as a possible l l
3 11 i reportable safety concern under 10 CFR 217 -
12 A I don't know. f i
l Who currently within the GPU system is 13 O Q ! l 14 responsible for making a decision concerning possible f a 1 15 reportable safety concerns under 10 CFR 21 as you f i
16 understand whatever procedures are now in place?
l 17 A I believe that for the operating plants it I
18 is the director of the plant organization that has the ,
n.
l 19 l ultimate responsibility for making such a determination.
i 20 l Q What I am getting at, though, is, within
- 21 the unit which you head, what under the procedures-you
,. 22 currently understand is supposed to happen if one of the 23 people working for you_comes up with a matter which 4
24 he or she believes to be possibly a reportable safety 1
-- 25 l concern on a 10 CFR 21? What is your understanding of ,
i 1
i
, - ~ -y - ~ w o-
1 Kooten 73 2l how the procedure is supposed to work?
d 3d MR. GLASSMAN: I will note an objection on 4
4 !l! the record to this line of questioning, which I l
l I 5 will set forth as a standing objection. We seem l '
l 6 to be getting into areas that are just going to !
7 take up a lot of time and are clearly dealing i
8 with events and procedures well after the accidenti 9 that relate to something other than the accident. j i'
10 I don't know why we are spending so much time 11 l on this. !
! I 12 I will let the witness answer, but my
( l
() 13 objection is noted. I hope we don't spend too i
14 } much time on 1981, 1982 matters of this sort.
l 15 MR. WISE: We have_ spent gobs of time 16 during the depositions of B&W witnesses going i i 17 l through postaccident matters, so let me say that i
18 first. ,
ID f Secondly, I think the relevance of this is b
20 simply to find out who we should talk with within 21 ! the GPU organization to determine what their 22 philosophy is on the 10 CFR 21, which is an 23 extremely relevant matter, as I am sure you well 6
- 21 know from a reading of the amended complaint. I
(,): b 25 am trying to find that out from this witness,
[
f l
'l
1 Konton 74 D) i
( 2h find out what his understanding is of the process !
3l and who becomes involved in it so that we can i
4 ! then determine what further discovery we want to !
5 take.
6 . I am not deposing this witness as an expert 7 in 10 CFR 21. This is the only way I know of 8 to get that information.
9 MR. GLASSMAN: I will let you continue in 10 f that vein. Without getting into an extended ,
t i 11 l discussion here, I am sure you realize there are ,
12 l certain postaccident pieces of information and l
() 13 testimony that may be relevant to this m a't t e r ,
i and certainly you have asked about other
~
14 i l .
15 information that is not relevant.
i-i 16 MR. , WISE: I am sure you and I could have l, ,
?
17 lengthy arguments as to which things fall into 18 i which category.
19 l Perhaps the reporter could read back the i
20 1: question.
21 (Record read) 22 A I believe that the responsibility for 23 ! coordinating such concerns lies with-the Licensing l l
4 l
24 1: Department, and.if such a concern were to come to my i l 25 6 attention, I would immediately bring it to the i !
l i <
! l
., . ~ -- .
1 Koaton 75
'~N 2 : attention of the appropriate licensing manager. !
ii
'l That would be somebody in Mr. Thorpe's 3 :; Q b, i 4 1 unit? :
lh 5 A In Mr. Thorpe's department.
6 Q I would like now to discuss for a moment 7 your involvement in the April 23, 1978 transient at 8 TMI-2. When did you first hear that that event had i
9 taken place?
10 A It was shortly afterwards, but I don't 11 remember exactly which date. ;
12 Q You in several of your previous answers {
13 l, have mentioned the division of responsibility between ;
- i 14 ! the Service Corporation and the operating utilities with, 15 l respect to existing plants. Is it correct that I
16 i before the accident at Three Mile Island in March 1979 4
17 the Service Corporation would only become involved in ,
18 matters at operating plants upon the request of the L
19 operating utility involved?
I il 20 !! A In most cases that was true, although there 21 we re some exceptions to that, as I mentioned earlier.
9 22 Q To the best of your knowledge, how was it 23 decided within the GPU system which' matters would fall 24 ! within the purview, if you will, of the Service f~} k -
's,/ 25 !! Corporation, anc which matters would be handled solely i; i-l
~, c -, - c = ~ - - - - . , - , .-s , . ~ , . . - - -
1 Konten 76
/]
(j 2 i by the operating utilities?
3 A There were defined sets of responsibilities I
4 for the Service Company, and those areas where there !
lt! l h 5l was a continuing involvement with the nuclear plants l
- l l
6 were I believe well delineated.
Q What were those, as you understood them?
8! A The one that I am the most familiar with i
9 is in the nuclear fuels area, where the Service Company I !
10 in fact had responsibility for procuring the nuclear l l
11 fuel and associated nuclear and safety analyses for !
I i
12 ~ the operating plants.
13 Q were there any others that you can now I
14 il recall?
1 15 h A I mentioned earlier the gathering of '
H -
16 d reliability data. The GPU Gystem Laboratory was I '
Y '
d 17 0 believe part of the Service Company, and it performed N
16 laboratory type functions for the operating plants.
19 l Those are the only ones that occur to me at the moment.
il 20 But I should clarify my previous answer
- 21 slightly in the sense that I am referring to an' ,
22 - operating plant as one which had been turned over to the 23 operating utility by the Service Company. As I I
[
l-24 ': mentioned earlier, the Service Company had the 7-() 25 responsibility for the construction, including the .
I i
4 s- e
1 Kooten 77
() 2 i
startup and test of new plants, and so it then became !
- 3 , the responsibility of the operating company >nce it was
- j.
- 4 turned over. j lll 5 Q In April 1978, I believe both Oyster Creek 4
6 and TMI-1 had gone commercial. Is that your 7 7 understanding?
6 1 ,
, e 8 A That is my understanding. !
i
- l 9 Q TMI-2, as I understand it, did not go l l l
' t 10 commercial until December 1978. '
- +
i 11 A That is also my understanding.
i 12 Q In April 1978, had GPU Service turned over ,
a t l
I [^T 13 responsibility for TMI-2 to Metropolitan Edison? i
\_)
l l
l 14 A I don't know. l 1 !
[ '
4 15 i Q It certainly had turned it over by March 2
1 l 16 28, 1979, would that be correct?
17 $ A Yes, I believe that is correct. ,
n l 18 ! Q To your knowledge, did the operating
! . 19 subsidiaries maintain their own capability for
! I; 20 , performing safety analysis work?
21 A As I mentioned earlier, for the most part 22 , both the operating utilities and the Service Company 23 ,
contracted with others to perform the safety analysis i-24 i for them.
25 p Q Do I take that to mean that to your
1 Keaten 79 l l
(")
knowledge the operating utilities did not have a
' (_ 2 l i !
j 3 capability to perform safety analysis in house?
i l
4 i A I don't know what capability they had within lh 5 in house.
i 6 Q From the time that you joined GPU Service i 7 up until the time of tne accident, did you ever become 8 aware of any safety analysis work that had been g 9 '
performed, for instance, by Metropolitan Edison?
10 . A Not that I recall.
11 Q Did you have any liaison with anybody at l i
I 12 Metropolitan Edison with respect to safety Tnalysis 13 work?
i 14 A Not that I recall. I don't know to what !
l !
i 15 ; extent you would consider the analysis we did of the.
16 l April 1978 incident safety analysis. I think in the i
I ,
17 .; strict sense of the word,it was not,but we did have some t
i 18 ! liaison in the course of working on that incident.
d.
19 Q What were the circumstances of your-20 j, becoming involved'in the investigation of the April 1
21 l 1978 transient at TMI-2? 4 22 A To the best of my memory, Dick Wilson-23 called me in and indicated that we had been requested
. 24 to perform an evaluation in cooperation with
/'_ s 25 Metropolitan Edison personnel-of the inci~ dent, and he
- i 1 1
j- .
1 Konten 79 l
(T 3 asked me if I would head up that activity.
%.)
~
hl 9 How soon after the transient was that, as 3]
i best you can recall?
4 I don't remember exactly. I believe it lh 5 i A ;
I 6
was within a couple of days, but I am unsure exactly }
n when it occurred. .
l 8 Q What did you do as a result of your l l
I o conversation with Mr. Wilson? How did you go about ,
- i ;
10 . tackling this problem? ;
I !
ig A As I recall, we first discussed who should 12 participate from the Service Company, and as I. recall, I
^
T 13 i basically we went to TMI and sat down with members of i
the plant staff who had already been involved in such gg
("
I-13 [ an investigation. They had started before we had, and P
16 { we spent a considerable amount of time discussing with Y
17 h them their understanding of what had happened.
'l 18 ; Q Who besides yourself was involved from the a
19 l Service Corporation?
A I believe that Gary Broughton was. I 29 og [ believe that Ed Wallace was. I believe that Bob Cutler I
o3 was.
23 j Q Who was'Mr. Cutler?
gg A He was in the project management 23 ; organization and had been involved in TMI-2 I believe i
b
- I '
s m,
1 Kocton 80 6
() 3 1
during the construction stage.
j! Q was there anyone else from-the Service 3
a 4
' Corporation? >
I lll 5 i
A Those are the ones I remember at the 6 moment. I am not sure it is a complete list.
l 7 Q Who do you recall being involved from the 1
8 Met Ed plant staff?
9 A In our investigation, that role was played ,
10 by Jim Seelinger.
I 11 Q Mr. Seelinger I believe at that time was i +
l 13 l Technical Superintendent for TMI-27 ,
li 13 A I believe that's correct. l L(
Q Was Mr. Miller involved at all? I am 34 }
,. 13 f speaking of the Mr. Miller who was at the time TMI-2 It3 Superintendent. He may also have been station manager 1; at the time.
18 - j A He was not a member of the task force. Mr.
?
l 19 Seelinger had been intimately involved in the plant's investigation of the incident, and he therefore 20 [
! provided a liaison between us and the other plant o
~g h l 22 people that were knowledge ="'1 in that area, so he was, L
23
- as-I remember, the onl- plant participant in our
.I
_ l task force.
7-)g '
\_ Q Following your ... eial conversations at the 33 i
h n
. , -.. -_ . - . . ~ _.- - ._. -.
1 Konton 81 a
site, how did the task force proceed? How were things 3q 1
3y divided up and what various functions were performed 11 4 1 in order to pursue the investigation? I am speaking in general terms. I don't want to know a day-by-day !
5 !
, a 1
6 or week-by-week review. l 7 A As I recall, we basically divided up the 1
8 ,
responsibilities for looking at various aspects of the
- 9 transient and assigned them to individual members of .
i l i i 10 i the task force, and your asking that question triggers 5
11 my memory that Rich Lentz was either an official l 5
l 12 member of the task force or in essence served as one. ,
i s
[] 13 Q Who is Mr. Lentz and which company was he i 4 () i .
j 14 ; from? !
[
15 y A Mr. Lentz worked with the GPU Service t
li '
16 Company and specifically worked for Mr. Broughton.
17 ll Q Go ahead.
?
n 18 i A We divided up the activities and asked l
19 l individuals or groups of individuals to concentrate go ' on oner or more aspects of the transient and the i i; 21 l associated events, and then to prepare some written
! oo i material which summarized their area of activity. I l 1 33 I frankly don't remember whether we got together and had
- j f meetings or whether I got together with them O- 2")
I individually, or both. I don't recall.
n .
1 Konton 82 3 Q Do you recall about how long your work took?
i 3 f A My memory is a little shaky, but I have I;
4 a memory that we were asked to make a report to Met Ed management quite rapidly, and I think I remember that llh 5 :
I l
6 that was the order of one week after the transient or l after we got started. This report basically was view !
8 i graphs, and we did make such a presentation, and then i I i 9 l on a somewhat longer time scale, we developed a formal .
l 10 report.
I .
11 Q That would have been a much lengthier :
j 12 document?
13 A Yes.
I la q Q Who wrote the formal report, as best you 15 l recall?
i:
lei A I pulled it together. But different i.
17 sections of it were written by different people.
n i
18 Q Do you recall that Mr. Seelinger had written I]
a 19 h a section -- or perhaps "section" is not the right 1,
( go " phraseology for it -- had written a portion of the 21 I report which later became in co rp o'ra t e d in the overall l
22 report?
23 A I don't remember that Jim Seelinger wrote l g; - anything that was especially for our report. I believe t O {
. 2.3 that it is true that some of the material that he
! i.
!I c
l
1 Kocton 83 d
2[ prepared for the plant report was incorporated in our i
(~)'N
( i 3 report as well.
3.'
4J Q Were any computer simulations or models t .
5 used in -connection with your investigation?
6 A Yes and no. The early inves,tigation that I
7 I have described as lasting perhaps a week or so and 8 which gave rise to I believe essentially all of the 9 recommendations that we generated did not use any ,
10 computer simulations. On a much different time scale, i .
11 !i there was a computer simulation that was done of the 12 l transient, but I do not recall that that had any impact 13 ,
on the recommendations that we made.
Os i .
14 l Q The April 1978 event at TMI-2 involved, as l!
15 : I understand it, a problem on the secondary side with 16 ,, one of the steam relief valves. Is that your 17 . understanding?
S 18 A Several of the steam relief valves.
li..l P
19 '-
Q They apparently blew open or whatever the 20 . correct terminology is and began relieving steam, which 21 caused an overcooling transient in the system. Is that h b l
22 1 a fair statement of it?
23 A It is a slight oversimplification. They
[ 23 blew open as they should have. They just did not close i
s/ 25 i' when they should have, and that is-really what caused l
l
l I
1 Koaton 84 l
( 3 the overcooling transient.
3y Q During an overcooling transient, as I l 3
4 !! understand it, the secondary side takes off more heat 5 from the primary side than would be expected during i'
6 I normal operation, causing the primary side temperature t i
7 to drop. Is that a fair statement? j 1
8 A Yes, but with the interpretation that you {
. I g l said normal operation. This actually is occurring after 10 plant shutdown.
i 11 G The reactor has tripped at that point? ;
l 12 A That's correct.
Q As a result of the drop in temperature,
[)T 13 14 : there is a consequent drop in pressure, as I understand ;
1,5 ,f these events. Would that be fair?
4 li; A As a consequence of the drop in temperature, n ,
i 17 t! there is a shrinkage of the water in the primary fi 18 !!b system, and as a result of that shrinkage and a 4
19 k consequent drop in liauid level in the pressurizer, i
20 there is a decrease in pressure.
21 Q During the April 23, 1978 transient, am I 9 i correct that the pressurizer level indication went off 33 i
23 i scale low as the overcooling event proceeded?
g 3; -
A Yes.
33 Q Is it correct that the loss of~ indication I:
b ll i,
1 Kooton 85 of pressurizer level was a matter of concern within
( 2 I
3] Met Ed and GPU Service for your task force, if that is 4
" a better way to put it? -
i MR. GLASSMAN: Objection insofar as you h 5 l
6 l are asking by the wurds " matter of concern" for -
1 i 7 Mr. Keaten's interpretation of other people's 8 mental state. If you would like to.ask whether 9 anyone expressed any concern or whether there I i 10 I was any discussion of this, you can proceed. ;
11 MR. WISE: I will hold that question in 12 abeyance for a moment and ask this.
' /~' 13 Q Who was the head of the task. force?
- k. l 14 A I was. I l
i 15 Q As the head of the task force, were you g
l' concerned about the fact that level indication had 16 i,
O 17 0 gone off scale low in the pressurizer during the course l
18 l ,
of the transient?
i' 19 h MR. GLASSMAN: Objection. If you would -
20 like to ask him whether ne expressed his concern, li 21 p whether there was anything written down in this
)
22 regard, you can, but we are not here to find out 23 ; what his internal mental processes'are.
~' MR. WISE: I don't understand the basis of j
23 l that ob3ection at all. You and your partners and I
1 Koston 86 i
.() 3 associates have asked many, many questions of 3 '1 B&W witnesses concerning what they understood s
4 and what they meant about various documents and 5 events before the accident. Are you now saying
' I l that you are going to put an objection to any 6 l 7_ j questions directed at that?
f I' l
8 MR. GLASSMAN: You can ask him anything i I
9- about what he understood or what he meant, but you! t l
10 .. haven't put a document or a statement in front of 11 him. You are just asking him in the abstract ,
12 whether somehow he was concerned.
MR. WISE: I must say that that question
( 13 0 has been asked of numerous witnesses, particularly 14 ;i t
13 with respect to the issue of the internal ii 16 memoranda at B&W concerning the Davis-Besse
?
incident, and I am absolutely stunned that you 17 h 18 think there is anything wrong with that question.
h i P 10 d Are you directing him not to answer?
20 MR. GLASSMAN: Yes.
b MR. WISE: I think we better break at this 21 G I, 22 h'l point and consider that, because we may want to i
23 go to the Magistrate on that.
gs 2: If you are going to take the position that k- !
we can't ask one of your witnesses who is head of 25 }I n
}
b
1 Kocten 87 I
('N o [, the task force what he understood to be the
, I 3
problem in view of the fact .that you have asked
!i 4 i! repeatedly almost every BEW witness that you I
5 have had testimony from what they understood about 6 safety concerns and so on before the accident, l l
I think we've run unto a real problem. l 7
8 MR. GLASSMAN: I will let him answer the l 1 l 9 question as you have just rephrased it.
t '
10
- MR. WISE: Maybe you better read back the I
il 11 l question so the witness has it.
12 l (Record read)
/ 13 l BY 'MR. WISE:
il 14 h't Q As head of the task force looking into b
13 g this transient, did you understand that it was one of Is; [, the things that you were going to investigate, that the a
, 17 ,,
pressurizer level indication had gone off scale low 18 1 during the event?
I 19 li A I understood that one of the things we i:
20 were asked to investigate was the implications in the
, t l- primary system with respect to the pressurizer level 21 il>
F 22 f going off scale low.
I 23 Q Who selected that as something you ought to 33 investigate?
- s < 23 t A I don't know.
O F
b
- -. -- . - . _ .-a. . _ _ , , _ . ,
1 Keaten 88 I
3! Q Was that a direction given to you or 3
i something that the task force decided on its own was a i;
4 matter that should be looked into?
I 5 { A To the best of my memory, that was one of [
l 6 the items that was initially discussed with me at the i
7 time that the investigation was~ set up.
g Q Were you told why that was something that 9 you should look into? l 10 ,
A My memory is that we were asked to consider i i 11 what the implications of the pressurizer level being 4 12 of f scale low had in terms of possible steam formation
() [3 I
in other parts of the system outside the pressurizer.
14 i Q Were you either aware of or made aware of any implications that that might have for a report to 13 b; 16 h the NRC?
F 17 ll A To the best of my memory, the question of 16 !i reportability of events was not something that the li h
'l task force was asked to consider.
19 i
20 . Q Did you ever become aware of any 31 {i requirement of a report to the NRC in the e'v e n t the O ti 33 !;i pressurizer had emptied entirely?
l I r
l 23 : A I don't remember.
l >
2; Q Isn't it correct that the task force had 25 as one of its functions to make a determination as to L.
P r
I
?
_ _ _ - . _ _ . . . ~ . _ . . _ _ _ _ _ _ _ _ _ . _ . _ . _ _ _ . - . . _ _ _ _ . . _ _ _ _ _ . . . _ _ _ . _ _ _ _ _ .
!' 1 Konten 89 i
I O j, whether or not the pressurizer had actually emptied ll 4
39 during the course of that transient? '
<! l I 4 PI, A. I don't remember that specific item. As I indicated earlier, the task force generally was asked
- h 5 f
6 to consider where there might be steam in the system, l l
r
- 7 and you can interpret that as including just how much I l
I t
' t l
8 I void there was in the pressurizer. { ;
i 9 ,
(Time noted: 5:00 p.m.) .
} i l
f
}- i 10 l :,
i l 1' '
, 11
!q i ROBERT W. KEATEN i
f 12 I i
- 13 I
i Subscribed and sworn to i l- 14 ,1 l p before me this day of 15 li i t 1982.
1 V 16 j, f .
. 17 J 4
p i
18 i; 1
! 19 20 l +
F
- 21. ii -
22 il 22 i
3; f
Ob 1
l i
I
90 2
EEEIIEIEAIE Q
3 STATE OF NEW YORK ) ,
- ss.:
4 COUNTY OF NEW YORK )
9 3 6 I, JosEPI R. DANYo , a 7 Notary Public within and for the State of New York, 8 do hereby certify that the foregoing deposition 9 of ROBERT W. KEATEN was taken before 10 me on MONDAY, JANUARY 4, 1982 ;
11 That the said witness was duly sworn 12 before the co:::mencement of his testimony and 13 that the within transcript i's a true record of said 14 testimony; 15 That I am not connected by blood or 16 marriage with. any of the parties herein nor 17 interested directly or indirectly in the matter in 18 !
controversy, nor am I in the employ of any of the 19 counsel.
20 IN WITNESS' WHEREOF, I have hereunto set 1 g 21 my hand this /7 day of atM/ / /7/E 22 43 e (m e 24 ! / y /
J,o'EPE R. DANYO /
25 -;
i i
,-e,. - .,-. - _ -m-