ML20072J153
| ML20072J153 | |
| Person / Time | |
|---|---|
| Site: | Three Mile Island  |
| Issue date: | 04/14/1982 |
| From: | Cartin L BABCOCK & WILCOX CO. |
| To: | |
| References | |
| TASK-*, TASK-02, TASK-07, TASK-10, TASK-2, TASK-7, TASK-GB NUDOCS 8306290966 | |
| Download: ML20072J153 (100) | |
Text
_ _ _ . -- ~___ -
114 v!J t UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK j __ __ _ ___ __________ _ .x GENERAL PUBLIC UTILITIES CORPORATION, :
i . JERSEY CENTRAL POWER & LIGHT COMPANY, j '( METROPOLITAN EDISON COMPANY and :
PENNSYLVANIA ELECTRIC COMPANY, I
~ .
' Plaintiffs,
-against- 80 Civ. 1683
- (RO)
THE BABCOCK & WILCOX COMPANY a,n d J. RAY McDERMOTT & CO., INC., :
e Defendants. -:
-- - - - - ----------- - - -x _
Continued deposition of Th'e Babcock &
Wilcox Company by LUCIUS ROSCOE CARTIN, taken by Plaintiffs, pursuant to a dj o urnme nt , at the 9
offices of Kaye, Scholer, Fierman, Hays &
- Handler, Esqs., 425 Park Avenue, New York, l
New York, on Wednesday, April 14, T982, at 10:05 o' clock in the forenoon, be fore Nancy A. Rudolphi,a Shorthand Reporte r and Notary Public within and for the State of New L York.
g 8306290966 820414 PDR ADOCK 05000289
/ PDR w
DOYLE REPORTING. INC.
CERTIFIED STENOTYPE REPoaTERS 369 LEXINGTON AVENUE WALTER SHAP!RO, C.S.R. NEw Yonx. N.Y. 10017 CHARLES SHAPIRO, C.S.R.
TEi.E PHO N E 212 - 867-8220 kJ, -
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0 2 A p p"e a r a n c e as 3 ,
4 4 KAYE, SCHOLER, FIERMAN, HAYS & HANDLER, ESQS.
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Attorneyh for Plaintiffs 5 425 Park' Ave'nue s ' '
6 '
By: RICHARD SELTZEit, '2SQ. ,
7 ,
j s of counsel 8
9 10 DAVIS POLK & WARDWELL, ESdS. E Attorneys for Defendandd, 11 One Chase Manhattan Plaza New Yorkh New York 12 '
T By: KAREN WAGNER, ESQ. r J 13 '
-and-NNN MCDONALD, ESQ., -
s 14
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of counsel 15
. . ;s 16 Also Presents
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17 DAVID TAYLOR \
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2 LUCI US ROS COE CART I N, 3 resume'd, having been previously duly sworn 4 by the Notary Public, was examined and
( 5 testified further as follows:
6 EXAMINATION (Continued) 7 BY MR. SELTZER:
8 Mr. C artin, I am sure you are aware that Q
9 today's testimony, like all of yesterd.ay 's tes timony ,
10 is under oath? .
- 11 A Yes.
12 Q Do you recall yesterday that I was O 13 asking questions and you were giving testimony 14 with regard to an analysis of small break loss of 15 coolant accidents with the pumps on and with the ,
16 reactor coolant pumps off?
17 A Yes, we discussed that. -
18 Q Is it correct that in Decembe 1978 you 19 thought that leaving the reactor coolant pumps on 20 after the start of a small b re ak loss of coolant 21 accident was better than shutting the pumps o'f f ?
22 s A Yes. I believed that tripping the pumps a
23 as assumed in the past analysis was the worst case than
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having the pumps run continuously.
25 Q And it was wo rs e in terms of what?
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1 Cartin 117 r^3 m .
2 A In terms of event consequences; namely, 3 a challenge to core uncovery and the potential for 4 a cladding temperature excursion.
k 5 Q By July 1979 you knew that it was 6 safer to shut the pumps off rather than leave the 7 pumps on once a small break loss of coolant accident
-a 8 was in progress, isn't that right?
9 MS. WAGNER: I object to the form.
10 A would you repeat that, please?
11 Q , I am asking you now about a period after 12 7g the Three Mile Island accident, and I am focusing on 13 July 1979.
14 The question is by July 1979 you knew 15 that it was better to shut the reactor coolant 16 pumps off rather than leave them on oneg a small 17 break loss of coolant accident was in progress, isn't 18 that right?
19 MS. WAGNER: I object to the form.
20 A At about that time we had concluded that 21 with the pumps running continuously the consequences 22 of a small break were acceptable. We also found that 23 there were some small break accidents for which a
) 24 pump trip at some time during the accident could 25 result in worse consequences than when had previously
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1 cartin 118 O 2 anttelpated.
3 Q In fact, you discovered that for certain 4 small breaks a pump trip during the transient was
( 5 worse than having the pumps off from the beginning 6 of the transient, isn't that true?
7 A For certain cases that's true.
8 Q In other words, you knew by July 1979 9 that part of what you had been thinking in September 10 1978'was wrong? ",,
11 MS. WAGNER: I object to the form.
12 Part of what he was thinking about what?
O 13 A I have no correlation of why you are 14 raising these particular dates.
15 Q In December '78 you thought that leaving 16 the pumps on was better-than shutting the pumps off 17 at the start of the accident? ~-
18 A In December of '78, that's co rect.
19 Q By July '79 you found out that 20 for certain transients leaving the pumps on left 21 open the possibility that there could be a loss of 22 off-site power and a tripping of the pumps in the 23 middle of the transient, isn't that true?
24 MS. WAGNER: I object to the form.
- 25 A Again, I don't know why you are bringing
1 Cartin 119
/m b 2 up July.
3 After TMI we did some analyses and found 4 ut that for some cases a pump trip during the
( 5 accident would lead to more severe consequences 6 than a pump trip at the beginning of a reactor trip.
7 Q The only reason I am using July is it 8 was my understanding that it was in or about 9 July that B&W issued the revised instructions saying 10 the operators should trip the pumps at ta start of 11 the transient rather than leave the pumps 12 running during the transient.
G
's- 13 A That is true. I apologize. I don't 14 remember the dates very well.
15 MS. WAGNER: You don't have to worry about 16 dates. Also, you should wait for Mr. Seltzer 17 to ask you a question rather than responding 18 to his comments.
19 Q You did not learn until af ter the Three 20 Mile Island accident that a pump trip during a small 21 break loss of coolant accident could produce worse 22 results than a pump trip at the start of that same 23 small break, isn't that correct?
/ 24 A Would you repeat that?
25 (Re cord re ad back. )
i 1
Cartin 120 2 A That's correct. -
3 Q To that extent you learned after the 4 Three Mile Island accident that part of what you
( 5 had assumed in December 1978 was no longer valid, 6 isn't that also true?
7 A We found out through analyses that there 8 were certain cases for which the previous assumptions 9 were found to be invalid.
10 Q The reason that some of the. earlier 11 assumptions proved to be invalid had something to do 12 with the f a'e t that leaving the reactor coolant pumps t
13 on during a small break loss of cool'nt a accident -
14 resulted in less water remaining in the reactor 15 coolant system than if the pumps had been tripped, 16 isn't that right?
17 MS. WAGNER: Objection to the* form.
18 THE WITNESS: May I have that read back?
~
19 (Record read back.)
20 A That's a very genera'1 statement. It has 21 to be clarified as to what the timing, the specific 22 events in question, the assumptions made, and were 23 you trying to make that claim. In general, for some
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() 24 cases and for some time during the transient with the 25 pumps on versus the pumps off you can at one point
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l 1 Cartin 121 S
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2 in time have less water.
3 It does not necessarily mean that would 4 be unacceptable.
k 5 Q Isn't it correct that if there is a loss 6 of coolant accident and the reactor coolant pumps are 7 on the circulation under forced flow conditions is 8 going to push a greater mass of coolant out of the 9 break than if there were no forced flow caused by 10 the reactor coolant pumps? ".
11 MS. WAGNER: I object to the form.
_ 12 Mr. Seltzer, is your question referring
\_
- 13 to all breaks in any place? .
A 14 MR. SELTZER: All small break loss of 15 coolant accidents.
16 A Your question has some points in it
. _ _ . ___._.17 that are not in agreement with my interpretation of l
18 what occurs.
19 When the pumps are running, they don't 20 push water out the break. With the pumps running,
! 21 you tend to make the system more homogeneous fo r l - . . . - - --- - . . -
22 which the break can relieve more water because the 23 inlet fluid has more water at that point in space,
(_) 24 the water has more opportunity to see the break. It 25 is not pushed out.
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9 1 Cartin 122
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U 2 MS. WAGNER: You answered Mr. Seltzer's 3 question.
4 He may ask another question.
(, 5 Q Let me accept then your qualification 6 that it's not a pushing out mechanism.
7 Isn't it a fact that with the reactor 8 coolant pumps on a greater mass of coolant is going 9 to leave the reactor coolant system through a break 10 than if the pumps are off? ',
11 A The question as stated I cannot respond 12 to. There is a given mass within the system.
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13 In general, you will relieve mass, 14 whether it be steam or water, through a reactor 15 coolant system of which it can be recirculated and 16 therefore whether one case relieves more mass 17 integrated over some time period, they may be the same 18 or one may be slightly greater.
19 If you could redirect your ques tion to 20 be more specific to a time frame or to a particular 21 event, I may be able to give you a better answer 22 Q What types of events would produce 23 greate r dis charge of water with pumps on during a (O
q j 24 small break loss of coolant accident as contrasted 25 with pumps off?
k
1 Cartin 123 3
2 MS. WAGNER: Could I hear the question 3 again, please?
4 (Record read back.)
( 5 A What do you mean by " types of events"?
6 Q Well, you said it would vary and that 7 there would be some events where you would get 8 a greater discharge of water for pumps on versus 9 pumps off.
10 A You have to be very specific for size, 11 location, and the time period.
12 At some time during a small break you can O 13 have a small amount of water. 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> later, you 14 might predict that.there might be a considerable 4
15 amount of wate r. It depends on how much you have 16 p ut back into the system and what the current pressure 17 and temperature conditions are. ~
18 . What were the conditions whic Q led B&W 19 to in'struct all the operators of its plants that 20 it was safe r to shut off the reactor coolant pumps 21 rather than leave them on?
22 Ms. WAGNER: If you know.
23 A We found that for certain break sizes rm
( ,) 24 an d for that particular break size, range, that the 25 system could evolve to a high void fraction for a given t
m _ _ _. .
1~ 1 Cartin 124 2 time period and should a pump trip occur during that 3 time period when the syste'n void fraction is high, that 4 it would be inadequate water to cover the core should k 5 the pumps trip and there would be inadequate safety 6 system injection to refill the core in a time period 7 to prevent cladding temperatures from exceeding 2200.
8 All these analyses were done with models 9 conservatively ~ built to meet Appendix K requirements.
10 Q In other words, you were doing the analyses 11 required by the NRC for the licensing of nuclear plants?
12 A That's right. They used those conservative 13 set of assumptions.
14 Q So for certain break sizes, l'eaving the 15 reactor coolant pumps on could result in a higher void e
t 16 fraction in the reactor coolant system than would 17 shutting the reactor coolant pumps off at_the start of 18 the transient, is that right?
19 MS. WAGNER: Mr., Seltzer, I object to you 20 rephrasing the witness' answer which I believe he 21 has given you twice as to what he believes has
.L-22 happened in this event.
23 Q You may answer.
( 24 A Repeat that.
25 Q So, in other words, for certain break sizes,
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1 cartin 125 10 V a higher void fraction would result in the reactor 2
3 , coolant systen if the reactor coolant pumps are left 4 on during the transien't' than if the pumps are turned 5 .off at the start of the transient, is th,at right?
6 A For a given period in time that is correct.
7 Q The reason that a higher void fraction would 8 result for those certain break sizes is the same reason 9 that was illustrated to,you by Bob. Jones in his 10 December 11, 1978 memo, GPU Exhibit 3 3 0,,, right?
11 MS. WAGNER: Mr. Seltzer, are you referring 12 to one of the several reasons in this memo or c
t 13 all of them?
14 MR. SELTZER: I am referring to the 15 discussion in the second paragraph of GPU 330.
16 A The second paragraph identifies both
.. . 17 p.ositive _and negative aspec.ts.of keeping. the pumps l .
18 running. Some of the positive things that are said l
19 here is that you can maintain natural circulation 20 longer which would give you primary to secondary heat 21 transfer and would aide system depressurization that will
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22 give you a higher safety injection flow.
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l 23 It goes further to say that you can have l
l (v 24 lower quality fluid will exit through the break. That 25 in itself does not necessarily lead to unacceptable h
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1 Cartin 126 C(3.
2 consequences.
3 Q I am not talking about.whether this memo 4 predicts unacceptable consequences right now. My l
5 question was isn't it correct that GPU Exhibit 330 6 described the mechanism by which leaving the reactor 7 coolant pumps on would result in less water remaining 8 in the reactor coolant system for certain break sizes?
9 MS. WAGNER: Objection to the form.
10 Mr. Seltzer, the witness is trying to respond to 11 you because you are basing your question on this
- ,s 12 whole memo. He has answered that question. I
(_J 13 don't think he can really respond to your 14 question any differently unless you want to be 15 more specific.
16 MR. SELTZER: I have tried to be very 17 specific in my last question. I would like to 18 have the question reread and I would like you to I .
19 answer, please, t
20 (Record was read back.)
21 A This one sentence says that you can have 22 lower quality fluid exiting through the break. That 23 does contribute to the phenomena that was. observed when 24 the analysis of the pumps running case was conducted.
25 It is part of the reasons why for those cases a high Y e o g-m- -- ~ , .e, -
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1 cartin 127
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V 2 void fraction was seen for certain time periods and 3 for certain small breaks.
4 Q In your answer you used the phrase " lower
( 5 quality fluid" and you also used " higher void fraction."
6 To put it in correct but simpler English, it is a fact, 7 isn't it, that this memo, GPU Exhibit 330, described 8 a loss of water from the system being greater for pumps
. 9 on than for pumps off, that was the same mechanism 10 for water loss that led to the revised'Anstructions 11 on terminating pump operation after the Three Mile 12 Island accident?
13 MS. WAGNER: I object to the form of the 14 question.
15 Mr. Seltzer, I think you know you are 16 trying to limit the meaning of this memo to 17 something which it is not limited to.
18 Q Would you like to have the question reread?
19 A Yes.
20 (Record was read back.)
21 MS. WAGNER: I obj ect further insofar as P
22 you are trying to suggest that that was the entire 23 basis for any later B&W instruction.
24 You may answer the question.
25 A I believe my comments previously were
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. I cartin 128
/
2 correct. Your question, I interpret it as meaning this 3 memo d es describe a way at which for certain time 4 Periods during the transient more water can be lost
(' 5 for a given time period with the pumps running as 6 opposed to the pumps being off.
7 I know at the time this memo was written 8 we were at that point in time not considering the 9 possibility of the pumps tripping during a transient.
10 MR. SELTZER: Let's go offtthe record.
11 (Discussion off the record.)
12 Q You testified at the start of this morning O
13 that you believed in December 1978 tha leaving the pumps 14 on during a small break loss of coolant accident was 15 better than shutting the pumps off.
16 It is a fact, isn't it, that you held that 17 belief because you relied on the reactor , coolant pumps 18 being able to continue pumping throughout the
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19 transient? Isn't that right?
20 MS. WAGNER: Objection to the form.
21 A I don't believe your statement regarding 22 what I testified to this morning was correct.
23 g In what way was it not right?
() 24 A I think the last -- you didn't clarify of 25 tripping the pumps at what time. At the times assumed
1 Cartin 129 O
O.
2 in the analysis, which was a loss of off-site power '
3 at reactor trip.
4 Q You assumed the premises in 1978, you
( 5 believed that it was safer to leave the pumps running 6 throughout a small break loss of coolant accident than 7 to trip the pumps at the start of a small break loss 8 of coolant accident?
9 A That's correct.
10 Q Your December 1978 conclusion as to which 11 was a safer situation for the plant was based on your 12 reliance that the reactor coolant pumps would be able (3 '
Q) 13 to function successfully throughout a small break 14 transient, isn't that right?
15 MS. WAGNER: Objection to the form.
16 A Yes.
17 Q There is a range of small break loss of. ___. __
18 coolant accidents in which the loss of coolant exceeds 19 the capacity of the high pressure injection pumps, is 20 that right?
21 MS. WAGNER: Objection. Could I have that 22 reread?
23 (Record was read back.)
() 24 MS. WAGNER: I take it, Mr. Seltzer, you 25 are assuming normal HPI in your question?
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f 1 Cartin 130 2 MR. SELTZER: Full flow, full throttle 3 HPI.
4 A That's a very general statement. It would
( 5 be much better if you clarified it to be at a given
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6 pressure, number of HPI pumps, but in general that is 7 a true statement, there would be some break size for
-a 8 which the HPI could not keep up with it.
9 Q Could not keep up with the loss of fluid?
10 A For a given pressure and given inlet 11 condition at the break for a given break size, they
_ 12 are all interrelated and for some breaks you may not
(~') 13 he able to keep up with it immediately but you may be 14 able to keep up with it two hours later, so it is a 15 ' very vague statement but in general it is true for 16 certain instances.
v 17 Q When you were in ECCS analysis and doing 4
18 analysis of small break loss of coolant accidents, you 19 studied certain break sizes and time periods during 20 which you had to deal with. accomplishing effective core 21 cooling even though the loss of fluid for that size L
22 break and time and other conditions exceeded the 23 capacity of the high pressure injection pumps; isn't f~S, q,) 24 that right?
25 A That's correct.
1 cartin 131 C.
2 Q For such breaks and for a certain period 3 of time during that transient as 0.he transient progressed ,
4 the inventory of water in the reactor coolant system
( 5 decreased, right?
6 MS. WAGNER: Objection to the form.
7 A It can decrease over certain time periods, 8 yes.
9 Q As the. water inventory decreased, the void 10 fraction in the reactor coolant system ,t increased, right?
11 A In general, yes. -
12 Q That means there was more steam and Icss
~# 13 water in the reactor coolant system? ,
14 A Essentially, yes.
15 Q In December 1978, whe.t information did you i e I 16 have about the ability of the reactor coolant pumps to 17 continue operating with increasing void fractions in 18 the reactor coolant system?
19 A I don't remember what specific information, 20 if any, I had at that time. Given we were under the i
21 general evaluation of given that the pumps could run, l k-l 22 we were assessing what the impact' was.
l l 23 Q What did you rely on for an assumption that
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t j 24 the pumps could continue to run during a small break loss 25 of coolant accident?
l
1 Cartin 132 2 MS. WAGNER: Objection to the form.
3 A At that time I was conversing with ECCS who 4 were looking at the pumps running and I really didn't 5 question their bases for assuming that they could run.
6 Q Who in ECCS told you that they were assuming 7 as a basis that the reactor coolant pumps could continue 8 to run?
9 A I had discussions at that time with Mr. Jones 10 and Bert Dunn. Whether we talked spec [fically about 11 the pumps' ability, I do not remember.
73 12 Q Do you remember talking to anybody in r 1 -
V 13 that time period about the ability of the pumps to 14 continue running?
15 A I don't recall any specific conversations, 16 no.
17 Q Based on what Jones and Dunn told you about 18 their assumption that the reactor coolant pumps could 19 continue to operate during a small break loss of 20 coolant accident, did you feel there was no basis for 21 any safety concern being flagged under the B&W 22 preliminary safety concern procedures?
23 MS. WAGNER: I object to the form of the b(_j. 24 question and, Mr. Seltzer, I think you have 25 mischaracterized the witness' testimony. He
1 Cartin 133 p
2 didn't say, I don't believe, that either of 3 those' people told him anything about the ability 4 of the pumps to run.
k 5 MR. SELTZER: Let's clear that one up.
6 Q Didn't either Dunn or Jones tell you that 7 they were assuming that the pumps could continue to run 8 during a small break loss of coclant accident?
9 A They were basically making an assessment 10 o,f the impact on the system of the pum's p on or the 11 pumps off. I do not remember having specific 12 conversations regarding the specific function of --
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13 capability of the RC pumps at that time, either 14 two-phase conditions.
15 Q It would have invalidated the conclusions 16 that you were getting from ECCS analysis about the 17 pumps running case if the reactor coolant pumps were 18 incapable of successfully functioning throughout l
19 small break loss of coolant accidents, wouldn't it?
l 20 MS. WAGNER: Objection to the form.
l l 21 A If we found that the pumps did not perform i (i ,
22 as our models predicted them to perform, yes, our
, 23 conclusion would have usen wrong.
24 Q In 1978, who, if anyone, in B&W's ECCS
( 25 analysis unit did yod consider to be particularly i.
1 Cartin 134 3
i *
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2 knowledgeable regarding the operating characteristics 3 of reactor-coolant pumps?
4 MS. WAGNER: I object to the form.
( 5 You may answer if you thought anybody was 6 particularly knowledgeable.
7 MR. SELTZER: Ms. Wagner, my question began 8 who, if anyone. -
9 MS. WAGNER: I apologize, I didn't hear that.
10 A At that time the ECCS unit yas composed of 11 analysts. There were probably several individuals there 12 that were very familiar with the analytical models that
'~% _
13 used actual pump' characteristics to model the 14 performance of the pumps and their computer codes.
15 There were, in my opinion--they we're not hardware e
16 experts-- there were several that were knowledgeable v
i 17 of the capabilities of their models. .
18 Q You worked with those models when you were 19 in the ECCS analysis unit, right?
l 20 A When I was there, we had very simple models l
21 and they were upgraded as a part of 10 CFR 50.46.
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22 Upgrades in our analytical capabilities : did interface, t,
23 a limited amount. I was in no way an expert.
( 24 Q .You did the interface after you joined l
25 plant integration, right?
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1 cartin 135 2 A Plant integration interfacing was something s
3 entirely different.
4 Q What was the interfacing that you were
( 5 referring to in your last answer?
6 A At the time that those new models were 7 developed, I was a supervisor and did not actually run 8 the computer codes and therefore did not develop any 9 of the inputs and therefore did not become intimately 10 familiar with those particular models e 11 MS. WAGNER: I think Mr. Seltzer just wants 12 to know which department you were in at that time.
I'~l ,
2 13 Is that right, Mr. Seltzer?
14 MR. SELTZER: Yes, t 15 MS. WAGNER: What department were you in 16 at the time you were just talking about, ECCS or 17 integration? .
18 THE WITNESS: I have lost the time frame.
l l 19 MS. WAGNER: At the time when'these models 20 were being upgraded.
21 THE WITNESS: I was in ECCS.
22 MS. WAGNER: Is that what you wanted, 23 Mr. Seltzer?
24 MR. SELTZER: Yes.
25 g You said you didn't know of anyone in the
1 Cartin 136 2 ECCS unit that worked particularly with hardware as 3 opposed to computer models, is that right?
4 MS. WAGNER: This is of RC pumps?
( 5 , MR. SELTZER: Right.
6 A In general, yes.
7 Q Just because an ECCS model assumes that 8 there are void fractions in the reactor coolant sys' tem 9 following a small break loss of coolant accident doesn't 10 mean that the equipment that'is operati,ng with that 11 reactor coolant system is able to handle increasing 12 void fractions, does it?
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13 MS. WAGNER: Are you asking for his 14 current understanding or his understanding at 15 the time?
16 MR. SELTZER: His understanding at the l
- 17 time he was working with these models.
18 A In general, the models are as closely 19 geared to reality as possible. I can't rule out the 20 possibility that any and all models may not cover all 21 situations.
L 22 Q Well, up until 1978 for purposes of 23 compliance with 10 CFR 50.46 and Appendix K, B&W had 4
( 24 assumed the reactor coolant pumps were tripped at the 25 start of a loss of coolant accident, correct?
'I
1 Cartin 137 G
2 A That's correct. .
3 Q so for all of the modeling that was done, 4 B&W's ECCS analysis unit had never had to consider 5 before 1978 whether the reactor coolant pumps could 6 continue functioning during a loss of coolant accident, 7 isn't that right?
8 MS. WAGNER: Objection to the form.
9 A I believe you showed me a memo or a letter 10 yesterday where that had been considerdd for a large 11 break, which probably was considered for large break 12 analyses for the 205 Appendix K application. It was C)
'^'
13 not considered for small breaks, to the best of my 14 knowledge.
15 Q Have you ever heard that anyone in ECCS 16 analysis did anything'to check in 1978 to determine 17 whether in fact the reactor coolant pumps- could continue 18 to function successfully during a small b eak loss of
. 19 coolant acci. dent?
20 A They may or may not have checked. I am not 21 aware if any checking was done.
22 Q Did you ever ask anybody in ECCS analysis 23 whether there was any basis for the assumption that 24 the reactor coolant pumps could continue to operate 25 successfully during a small break loss of coolant
?
I cartin 138 O
O 2 accident?
3 MS. WAGNER: Are you asking this at the 4 time period when the assumption was made, I take
( 5 it, if ever?
6 MR. SELTZER: Let's take it right up to 7 today.
8 Q Have you ever asked anybody in the ECCS 9 analysis unit if they ever had anything which they 10 based their acsumption on that the reae, tor coolant 11 Pumps could continue to operate during a small break 12 loss of coolant accident?
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13 MS. WAGNER: Maybe I have missed something 14 here but I am not aware that the witness has ever 15 testified that that assumption was made.
16 MR. SELTZER: He has and it is implicit.
_ _ _ _ _ . _ . . 17 He was talking to Dunn and Jones about a pumps 18 running case during a small break lbss of coolant 19 accident.
20 Q If you are not assuming that the pumps 21 are going to run, then you don't have a pumps running 22 case at all. If you are not going to assume that the 23 pumps are running during a small break loss of coolant 24 accident, then you haven't got a pumps running case at 25 all. Isn't that right?
l' Cartin 139 2 A A pumps running case, you make the assumption 3 that the pumps run.
4 Q Now, let's go on to the next question.
( 5 Did you ever hear anything which indicated to you that 6 anyone in the ECCS analysis unit had ever done anything 7 to verify that in fact the pumps had the capability to 8 continue operating during a small break loss of coolant 9 accident?
10 A If my memory serves me correctly, that has ,
11 been evaluated at one time or another. I don't 12 remember the specific circumstances or the exact
(~h *,.
\) 13 ' document where I read that. I myself do not remember 14 specifically asking a direct question of that nature.
15 Q Do you have any recollection what the answer 16 to that question was?
17 MS. WAGNER: The answer whether the pumps 18 could --
l
{
i 19 Q The answer to whether ECCS ev$r specifically i
20 looked into the physical ability of the pumps to i 21 continue running during a loss of coolant accident?
[ 22 A Again, I just finished stating I vaguely l
23 remember reading something to that effect, that they had
) 24 considered that and examined that. I don't know where l 25 I read that specifically, though.
l l
f
l 1
1 Cartin 140 2 Q Do you know when you read it?
3 A Wo-4 Q Do you know when the document was written?
( 5 A No.
6 Q Do you know who wrote the document?
7 A No.
r 8 Q In 1978 B&W had a pumps unit, didn't it?
9 MS. WAGNER: A unit that has something to do 10 with pumps? E 11 A We had people who were responsible for 12 coordinating the procurement and implementation of
()%
\-- 13- the pumps on the contract, yes.
14 Q Did you have people who were' involved in 15 design specification for reactor coolant pumps?
16 A Yes.
17 Q In 1978 or early 1979, did you ever check l .-
l 18 with anybody in B&W's pumps unit to see if the assumption j 19 made by ECCS analysis was correct,.namely, that the 20 reactor coolant pumps could continue to function during 21 a small break loss of coolant accident?
22 A No, I don't remember making any check of 23 that nature.
D)
( 24 Q In other words, without any evidence from l
l 25 Dunn's unit and without any checking with B&W's pumps I
4
- . . . - . . . . - - - ~ - . y_ - _ _- _ . - - , , . , . - - , -, , , . , - 7,-y,.-,.y-.m---
1 Cartin 141 O
C /.
2 unit, you just accepted the assumption that the reactor 3 coolant pumps could continue to operate during a small ,
4 break loss of coolant accident?
( 5 MS. WAGNER: Objection to the form.
6 THE WITNESS: Would you repeat that?
7 (Record was read back.)
8 A I at that time had no reason to question 9 that assumption. I did not do any checking.
10 Q At the time that you wrote (GPU Exhibit 122, 11 you were responsible for monitoring or supervising the 12 engineering interface on this pumps'ru'nning issue,
{)
Y>
13 weren't you? -
14 MS. WAGNER: Objection to the form.
15 THE WITNESS: Would you repeat that?
16 Q At the time that you wrote GPU Exhibit 122,
- 17 your assignment in plant integration was to perform an 18 engineering interface function on the issue of reactor
- 19 coolant pumps running during a small break' los s ,of -
20 coolant accident? -
21 A No, my exact job at that time was to, in l
22 integration, was to assist the analysis groups in 23 preparing responses to direct Davis-Besse questions that had resulted out of general issues regarding V)
[ 24 25 pressurizer level indication.
k
- . , . ..~ _ .- -- . - - , - - - _ _ _ - _ , _ . . - . . .. . -
a
/
1 Cartin 142 f
k The analysis was being done principally in 2 Q 3 ECCS analysis on this question of pumps running, right?
~
4 MS.' WAGNER: Objection.
( 5 A They were -- the ECCS analysis was 6 responsible for all issues regarding LOCA analysis.
7 Q Weren't you on behalf of plant innegration 8 providing an interface function?
g A I was providing a function of here's the 10 questions, how much resources requirements do you need?
I 11 I will secure them for you. I also served the function 12 of inquiring as to their status- as to certain periods 13 of time and I wrote status memos as a means to minimize 14 man-hours required for people to report on their 15 various ctatus of their individual jobs.
e 16 Q Did any of the recipients of GPU 122 tell
. ._. 17 ..you after.they_.got..your memo that they thought you 18 were wrong to recommend not advising the NRC about
~
19 possible deficiencies in B&W topical reports previously 20 submitted?
21 MS. WAGNER: I object to the form of the 22 question and direct the witness not to answer.
23 You have misstated what is in the memo and what hJ 24 his prior testimony is.
25 Q Did anybody from B&W tell you after they got 5 '
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e- ~
n
+
s
,s s ! ', ,..3
\'
i .
I 1 , C'a r ti n '
143
/S -
I 1.j s \ '.
2 your memo that thef(thought the statement that you made
,)
3 about what B&W should,or should no.t tell the NRC was
- w ...'
4 wrong? O' 8
s.
( 5 MS. WAGNER: 4 I object to the questio'n; 6 Could I hear'the question again, please?
~.
7 (Record was read back.) '
1 8 MS. WAGNER: Mr. Seltzer, perhaps you could 9 refer the witnesc to what it is that discusses '
10' statements to the NRC about which you would like 11 to ask a question. s 12 MR. SELTZER: (Iamreferring to the second (N 13 and third sentences in item 6 on page 2.
14 A
}
Those particuldrsent'ene s did not make any 15 recommendations of what to'tell the NRC one way or the 16 othe . , ,
~
\
17 Q Weren't you saying that if the NRC were to g
1 18 ask a 4t: Ct13n aboutithe B&W small break topical reports
~ .
19 t xp . } aust be in a position to tell the NRC that the
., ,= N 20 topicals have ' already cons'iderid trie worst possible
\
condition? 'N-21, e y o L
22 A At this p61nt 'i n . $iine , 'we were specifically 23 pushing to s cure some fundingsto do that analysis and 24 to docume.nz that basic assumption and in the event that s ~.
25 that topic'ever came up again, *e would have a clear i
k
' 6
~
r
1 .
Cartin 144
(~) -
(J 2 analysis by wh'ich to back up our engineering assessment.
3 Q You didn't have those. analyses available 4 at the time you wrote this memo, did you?
f 5 A That is correct.
6 Q Did anybody ever communicate with you after 7 getting this memo and say that it was wrong for you 8 to have indicated, "The customer should not be informed 9 of the ECCS analysis' efforts to examine the pumps ~
10 running case"? E x
-11 A As I testified yesterday, I believe those 12 were poor choices of words. My intent there was we 13 should have our schedules defined and work scopes 14 defined and resources secured and at that time would 15 be the best time to notify the customer. I also 16 testified that the customer was well aware of the 17 bases for his LOCA analysis and what analyses existed 18 with the pumps running.
19 MR. SELTZER: I move'to strike that as 20 nonresponsive. -
21 Q Did anybody tell you after they got your 22 memo that it was wrong for you to indicate that the 23 customers should not be informed?
() ~ 24 MS. WAGNER: Objection.
25 A After writing this memo, I went on vacation
g Cartin 145 f\
V' fI approximately three weeks. Upon returning, I don't 2
remember receiving any comments at that time regarding it.
4
( 5 memos while you were gone?
A I don't remember receiving any memos 7
g providing comments on this memo.
9 10 BY MR. SELTZER: g 7
Q Let me show you what was produced to us 12 late in the night two nights ago after 6:30 just before
(.' y ur dep sition commenced. It is a pile of documents 13 g labeled "L. R. Cartin Control File 1978."
5 Can you describe what type of material you placed in this file and how this file was maintained?
16 g A This file was maintained by a, secretary.
18 Normally when she did typing for me, she 'would stick gg the original in this file and I would get'a copy and from that original, the distribution would be made, g Q Who put the C's in the upper right-hand L rner the document in the file?
22 g A I don't know specifically.who. The secretary sometimes puts things on it to tell her something but 24 25 I don't know exactly who put that C on there or what it n
1 Cartin 146 ,
r" -
k_S) means. -
2 3 Q so all the documents in here are documents
~~
4 which you wrote and the secretary was keeping a
( 5 hronological copy for you?
6 A In general those would be my documents.
7 on occasion I have asked her to put something that I 8 didn't actually write in there just so that I could find 9 it because it related to something I had written.
10 Q Take a look at the document that is stamped 11 21765. After you have had a chance to read that, could 12 you tell me what it is.
' 13 (Three-page document entitled " Supplemental 14 Information for Figure 15E.6.2" marked GPU 15 Exhibit No. 495 for identification, as of this e
16 date.)
i 17 ___ MS. WAGNER: The question I t,hink, Mr Cartin ,-
18 is what is this document?
19 A During this time period I prep'ared some 20 sequence diagrams that showed the various safety 21 functions for Chapter 15 events. It was done for the 22 PASNY contract and the consumer's contract. This looks 23 like some information I had prepared for one of those I can't tell which plant it was l
(n),
24 particular diagrams.
25 appropriate to from the information here.
dP
1 Cartin 147
~(
s_. - .
s 2 Q -How would your preparation of this which 3 we have marked as GPU Exhibit 495 _ relate to sequence 4 diagrams?
( .
5 A We generally provided some additional 6 discussions that were supplemental to the sequence 7 diagram.
- 8 Q What is a sequence diagram?
9 A A sequence diagram is a graphic -- well, 10 it is not graphic. It is an illustrati,on of a transient 11 that attempts to show what safety systemc must work 12 or have been assumed to work in the analysis. It gives 13 the NRC a picture of why you assume HPI to work in your 14 analysis.
~
15 Q GPU 495 is a written description that you 16 prepared to go along with the graphic or diagrammatic v
17 description of system operation, is that right?
18 A Yes, but I am not aware that this is the 19 final form of a particular document that $ released.
20 Q From its location in your chronological 21 file ~ can you state approximately when you prepared 22 GPU 4957 23 MS. WAGNER: I guess it should be noted 24 for the record that there doesn't appear to be a 25 date on the document.
I 1 cartin 348 l'
V) A Based purely on the fact that there is 2
a mem , unrelated memo of date June 23, 1978 before 3
4 it and an unrelated memo of June 26, 1978 after it,
( 5 that may indicate it was written around June of 1978.
6 Q What did you refer to in preparing the 7 information that is on the first page of GPU 495?
g A I don't remember the exact information I had 9 at my disposal at the time I prepared this document.
10 It was prepared to supplement an FSAR.E ,
11 Q Did you believe that the instructions ,
12 which you gave in the third paragraph beginning with 13 the words "This condition" were the proper instructions 14 for the operaulon of high pressure injection?
15 MS. WAGNER: I object to the form.
16 A The intent of this information was not 17 to provide guidelines or instructions on Aow to control 18 anything. It was primarily to identify those areas 19 that may require some action on the part of the operator.
20 Q Did you believe that the operator action 91 which you described in this paragraph was the correct k.
22 operator action to be taken for a small break loss of 23 coolant accident of the type described in this exhibit?
D MS. WAGNER: I object to the form. I don't
[/
s_ 24 25 believe the exhibit describes such an accident.
1 Cartin 149 A
(.) 2 Q Isn't it a fact that the document does 3 describe a small break loss of coolant accident? ,
4 A The document is in reference to an instrument
( 5 line break.
6 Q Instrument 1Ine f rom the primary system, 7 right?
8 A That's correct.
9 Q The primary system holds reactor coolant?
. 10 A Yes. t 11 Q And a break in that line would be a loss of 12 coolant accident of the small break size, right?
13 A If the break is in the rig t location, yes.
14 Q Now, would you answer the question that I 15 posed before, did you believe that the statements that 16 you made in the third full paragraph about operation 17 of the high pressure injection system described a 18 correct method for operation of the high pressure 19 injection system during a small break loss of coolant 20 accident?
21 MS. WAGNER: I obj ect to the form.
22 A The statements here were intended to say 23 that the operator will be required to control HPI
() 24 following this particular accident since once it is 25 actuated, it more than matches the leak rate thereby
4 1 Cartin 150 2 terminating the accident as far as 10 CFR 50.46 goes.
3 Q Did you believe at the. time you wrote this 4 that the descriptions of when and how the operators i (, 5 should regulate high pressure injection were accurate?
6 A Again, this was not meant to be specific 7 guidance given to the operators.
8 Q I didn't say that it was.
9 A It was generally to indicate that the 10 operator would be required to control kPI once he had 11 a normal pressurizer level for this particular. break.
12 Q You said that this was to ndicate that
/~T V 13 .the operator would be required to control high pressure 14 injection. Do you believe that the descriptions in i
15 this paragraph of when he would be required to control 16 -HPI and how he would be required to control HPI were 17 accurate? - - - - - - -
I 18 MS. WAGNER: Mr. Seltzer, I think for the 19 record it would be appropriate to demonstrate j 20 what in this paragraph you think tells you when 21 you should control HPI, and as I read it, the I
4
(
22 paragraph --
23 MR. SELTZER: Fine, let me do the examining.
24 Q Do you see the third sentence that says, 25 "That is, the operator must control pressurizer level to
l 1 Cartin J51
+
2 prevent the HPI pumps 'from filling the pressurizer and
~
3 increasing the system pressure"? It goes on and says, 4 "This is accomplished by securing the HPI pumps."
( 5 Do you see that?
6 A Yes.
7 Q Did you believe that the descriptions in
~
8 this paragraph of when and.how the operator was to 9 control the high pressure injection pumps was accurate?
10 MS. WAGNER: Mr. Seltzer, d, gain I must 11 object to your question. You haven't pointed 4 %
12 to anything here which says when you must do it.
O "
\_l 13 . I wouldn't continue with my objection 14 unless you have a problem in understanding it.
15 Don't answer the que'stion until Mr. Seltzer 16 responds.
v 17 Q Isn't it a fact that this says the 18 operator must regulate high pressure injection in order 19 to control pressurizer level? -
20 A For this particular event that would be a 21 reasonable action, yes.
i 22 Q And he must throttle high pressure injection 23 when it is necessary to do so to prevent the pressurizer (v
24 from filling and system pressure from increasing, right?
25 MS. WAGNER: I object to the form.
1 Cartin 152
(~ .
\~J A 2 From the standpoint of identifying operator 3 actions for a safety function of this particular event, 4 he would, could throttle HPI to prevent the system from 4
l, 5 going water solid. This is a very, very small break, 6 one that is immediately matched by high pressure 7 injection when actuated.
8 .Q Did you understand at the time you wrote 9 this that B&W believed it was desirable to prevent 10 the reactor coolant system from going water solid?
11 MS. WAGNER: Are you asking him in this 12 case or in general?
'/ 13 MR. SELTZER: In general. In general, but 14 I want to limit it to small break loss of coolant 15 accidents.
16 MS. WAGNER: Do you understand what the 17 full question is now? _
18 Q Did you understand at the time you wrote 19 GPU 495 that B&W's engineering department believe that -
20 it was desirable to avoid letting the reactor coolant 21 system going water solid during a small break loss of 22 coolant accident?
23 MS. WAGNER: I object to the form.
24 A Per definition, this break is at the point 1 25 that it is generally not defined as a small break loss
1 Cartin 153 2 of coolant accident, a small leak which is very 3_ close to normal operation as far as the system is 4 concerned, so in general it is not generally viewed a
( 5 small break LOCA. It is a small -- it is a size range S that is categorized as a small leak which is used to 7 size your high pressure injection.
8 Q It is a fact, isn't it,.Mr. Cartin that 9 this is a break of sufficient size to require the 10 actuation of the high pressure injecti6,n system?
11 A That is correct but it is immediately 12 matched by the flow introduced by that system.
13 Q For breaks in the reactor oolant system 14 that could be matched by flow from the high pressure 15 injection system, did you understand in.1978 that B&W
- 16 intended that the reactor coolant system should not 17 become water solid? .
18 MS. WAGNER: Objection to the form.
19 A Preventing water solid conditions would be 20 advisable actions provided those actions do not put the 21 plant in an unsafe condition. The operator has to 22 review all the plant parameters and take actions as 23 appropriate.
24 Q Do you see the sentence which is the next 25 to the last sentence in your third paragraph, "The HPI f
k - - - - -
l 1 cartin 154 O
v.
2 pumps can then be stopped manually once a normal 3 pressurizer -level is established"?.
4 A Yes.
l, 5 Q At the time you wrote that sentence, did 6 you believe that was an accurate statement?
7 MS. WAGNER: Objection.
8 A For this accident as described in the FSAR 9 and as this information related to the sequence diagram 10 prepared to supplement that,,that would,be a correct 11 statement of what the operator could do because the 12 system would be highly subcooled.
~h (d
13 Q Based on your understanding of the 14 operation of the B&W plant and the analyses that you 15 were familiar with for small break loss of coolant 16 accidents, did you believe that that statement about 17 high pressure injection pumps being stopped manually 18 once normal pressurizer level is established was a j 19 correct statement for small break loss of coolant 20 accidents within the capacity of the high pressure 21 injection pumps?
22 MS. WAGNER: Objection to the form.
23 A This particular information was prepared 24 specifically for one accident. This one in a given 25 FSAR. I prepared this information to supplement that
I 1 Cartin 155
. (D t/ .
2 particular accident specifically.
3 Q Now- I am asking you a.slightly different 4 question. I am telling you it is a slightly different
( 5 question. I am not limiting this question now to breaks 6 in instrument line or lines from the primary system.
7 Do you understand that?
8 A You are not limiting it to that? '
. 9 Q That's right. Now I am expanding it to a 10 class of small break loss of coolant ab,cidents including 11 this particular small break loss of coolant accident N
,_ 12 that is within the capacity of the high pressure o s .
NI 13 injection pumps to overcome the loss of co ol'a n t .
14 Are you familiar with breaks of that size 15 range?
16 A Yes.
v 17 MS. WAGNER: Mr. Seltzer, I have to object
- 18 to one thing. He has testified this is not a 19 small break loss of coolant accident. You are 20 welcome to ask him about small break loss of 21 coolant accidents within the capacity of HPI.
__ ~ '
22 MR. SELTZER: I think his testimony is what 23 it is. He did say earlier that this is a small 24 break loss of coolant accident.
25 MS. WAGNER: I don't think he did but anyway,
. . . , , - - - . . . , - - , - , - , , . ----n r - - -
l 1 Cartin 156 O 2 regardless of what he said, go ahead.
3 Q For small break loss of coolant accidents 4 within the capacity of the makeup pumps, isn't it a l, .5 , fact that it was your understanding in 1978 that for 6 those breaks the high pressure injection pumps can be 7 stopped manually once a normal pressurizer level is 8 established?
9 A That statement is made in direct reference 10 to a specific break assumed to be at atspecific location ,
11 within the FSAR. For that particular.insthnce, that 12 statement was an indication or was intended to be an
^
13 indication that the operator would have to take control 14 would be -- the operator would not have to, but the 15 operator would be advised to take control actions once 16 a normal pressurizer level was obtained.
17 Q Based on your knowledge in 1 9.7 8 , are you 18 aware of any reason why that would not be the correct 19 operator responsc to any other small break loss of 20 coolant accident within the capacity of the high 21 pressure injection pumps?
22 A At that --
23 MS, MCDONALD: Can I have that read back?
() 24 (Record was read back.)
25 A Could you define for me what" correct
I 1 cartin 157
?m '
-(
\"') ' 2 response" is?
3 Q .The response which B&W thought was the .
4 appropriate response, just as B&W thought that stopping
( 5 the pumps manually once normal pressurizer level was 6 established for this particular response described in J
7 GPU 495 --
8 A Pressurizer level is not the only indication 9 which an operator would use to control HP'I flow. This 10 information was not to be a verbose discussion of the ,
11 why's and wherefore's of operator action. It was to 12 supplement a diagram that said the operator would take 13 manual action to control HPI flow and that was its 14 intended intent.
15 Q It is a fact, isn't it, that there are 16 instrument lines that are in the steam space at the 17 top of the pressurizer? .
18 A That is correct.
19 Q when you wrote this, you were writing t
20 descriptions that would apply to a break in those 21 instrument lines, is that right?
L, 22 A If my memory serves me correct, the break 23 in this particular instance was assumed to be within f%- 24 the primary loops.
25 Q Does that include the pressurzer?
- - - . - - n,- ,
- - , , , , - , , - - a,-,, , .e-- m,,.,- - - - . _ - - , - - . , . , . , . - - - -- , , - ,..,-,_,..,,w, - , - -
Cartin 158 J l
,(~) =a=aa
(_/ A No, the break was within the wat=* l I
af the primary loops, the cold legs or hot J Q Is there anything in GPU 495 tha ,,
that? ? -.
Is that question directed to me: O A og b-I Q Yes. 4
~
Do A Not specifically, no.
Q There is no reference in your d.
on high pressure injection control to a subcooling margin, is there?
A No, there is not.
Q There is no reference in your description of high pressure injection control to saturation
' conditions, is there?
A No, there is not.
f MS. WAGNER: I think, Mr. Seltzer, that ac ,
the record would be more complete if it were noted ,that the paragraph from which you have been reading refers to actions to be taken "with the I ""Z~TII l reactor temperature and pressure below the normal
' hot' shutdown condition."
Q You were involved in late 1978 and early 1f'9 in meetings with Toledo Edison and with the NRC ,,,
I k
' rsgarding problems of pressurizer level indication, l
m M
I 1 Cartin 159 O' 2 i s n' ' t that right?
3 A That is correct.
- 4 'Q' What was your responsibility in connection l 5 with that issue of pressurizer level indication?
6 A With integration I essentially performed 7 an interface function. I was given a set of questions 4
8 that Toledo wanted specific answers prepared for. I 9 went out and identified whom I thought were the
. 10 appropriate people to answer those queqtions. I j 11 secured a commitment from them regarding the amount 12 of money required to answer those questions and a 13 schedule as far as when the questions could be answered I
14 in and assisted them in securing those and coordinating
- 15 that type of interface between the analysis group and 1 -
16 our service organization who talked directly to the
_ __ . __ _ _ . _ _17 customer. _ _ _ . . _ -
18 Q I would like to show you GPU 5xhibit 82 l
19 which is a memo that you sent to Bruce Karrasch on 20 November 29, 1978. Is GPU Exhibit 82 a copy of a l
l 21 memorandum which you prepared on or about November 29, l
(_
22 19787 i
23 A Yes.
24 Q And you attended a meeting two days earlier 25 among B&W and Toledo Edison Company personnel?
l I
s
- . - - _ . -- . - _ = _ _ - . _ - - _ -
1 Cartin 160
(\
2 A Yes.
3 Q on page 1 in the first. paragraph, do you 4 see the sentence beginning, "This meeting"?
(, 5 A Yes.
6 Q It says, "This meeting was required to 7 identify and resolve present problems associated with 8 establishing steam generator level control set points 9 which would maintain indicated pressurizer level 10 during normal reactor trip ovents." e 11 What is your understanding as to why it 12 was thought to be important to maintain indicated
('-)# 13 pressurizer level during normal reactor trip events?
14 MS. WAGNER: I object to the~ question. I 15 don't think the memo indicates that it is 16 important but the witness can answer the question.
17 A The pressurizer level issue was essentially 18 viewed as an operational inconvenience. It is desirable 19 that under normal reactor trip events design condition 20 would be that pressurizer level indication would remain 21 on scale. Several of the plants were experiencing 22 problems, TECO being one,that indicated level would 23 go off scale momentarily and therefore the operator
() 24 had no pressurizer level indication.
25 Q Why, if you know, was it deemed advisable
1 Cartin 161 O
V' 2 for th'e operator to maintain a pressurizer level 3 indication? ,
4 A Would you repeat that?
( 5 Q why, if you know, was it' deemed advisable 6 for the operator to maintain a pressurizer level?
7 A The pressurizer level issue here was being 8 raised as a result of questions received by TECO from 9 the NRC. We'were trying to assist them in preparing 10 a response to specific NRC questions. t i
11 -
Pressurizer level, although desirable, was 12 not an indication that was required to maintain plant
\ 13 safety for the conditions of question Nere.
. 14 (Continued on the following page.1 15 i 16 17 I 18 i
l 19 20 I
21 l
l 22 l
l 23 i
24 25 i
t 1 Cartin 162
(~
~
%J 2 Q Take a look at page 3 of your notes.
3 Do you see section 3 entitled " Criteria i
4 for Pressurizer Sizing"?
5 A
({ Yes.
6 Q Your first sentence under that states, 7 "The need to maintain pressurizer level 8 during normal accident conditions was discussed at 9 length."
10 Who was it who was discussikgat length 11 the need to maintain pressurizer level?
12 A This general meeting was primarily
/~%
N -) 13 chaired by Eric Swanson, although I don't remember 14 specifically most everyone in attendance. It was an 15 open discussion-type meeting. ,
16 I in general tried to give a air l
17 record of what went on. .
18 Q Did anybody at the meeting di cuss 19 problems associated with losing pressurizer level 20 indication going on the high sider in other words, 21 the water level rising above a level at which the k, .
22 operators can read pressurizer level in the control 23 room?
[~)
\_/
24 A Without -- my only basis for memory would 25 be to review this document in detail. Right now
1 Cartin 163
+ -
O(3 . 2 I don't remember that being an item of discussion, 3 although it could have been.
4 Q Do you remember any discussion at this 4
{ 5 meeting about the operators having .been confused by 6 rising pressurizer level indication during a transient 7 that had occurred at Davis-Besse?
8 A I don't remember that being an item of 9 discussion.
10 Q Did Bert Dunn say anything $t che meeting 11 about incorrect operator action in terminating 12 high pressure injection in response to a rising l)
k/
13 pressurizer water level?
14 A I don't remember Mr. Dunn making any 15 statements to that effect, e
16 Q You refer in this same paragraph on page i
- 17 __.3 to a table attached to your minute s ,- Tab-le-2.---
18 Did you review Table 2 before including it 19 in your memorandum, GPU 827 20 A I believe I prepared Table 2 to be 21 consistent with the information written on a 22 blackboard and the open discussion at that meeting.
23 Q Who had put the information on the
[%.)) 24 blackboard during the mee, ting?
25 A some of the information in part was put up
\6 g? .' -
1 Cartin 164
/~N LI 2. by Eric Swanson. There may-have been others, s
3 Q -In Table 2 do you see the column at the 4 far right-hand side headed "LOCAs"?
( 5 . MS. WAGNER: I think we should state for 6 the record that it is kind of hard to read this. .
7 MR. SELTZER: Let me see if we can give
. 8 you a better copy. That's the copy from 9 year chronological file.
10 A Yes, I see it. E 11 Q what was the purpose of the entries on 12 that column.
(~h :
\- 13 A May I review the table for_a few minutes 14 and see if I can put it in the right frame?
-15 Q Certainly.
16 THE WITNESS: Would you repeat the 17 que s tio n. .
4 18 Q What were the entries in the last column 19 under loss of coolant accidents intended to t
20 indicate?
21 A The table in general were trying to write 22 down some general items regarding pressuri=e r level 23 during various accident conditions and normal operation,
- 24 trying to list what we knew at that time to be the 25 steam generator level control set points assumed in
1 1 Cartin 365 ,
1 2 the analysis of those accidents or normal operating 3 conditions, -and we wrote down some-general things 4 that were possible following items to be investigated
([ ' 5 after this meeting.
6 Q What is the entry under "Small Break" 7 loss of coolant accidents?
8 MS. WAGNER: At.any point on the chart 9 or all of them? The first entry?
10 A Loss of pressurizer level fs a natural
~
11 consequen ce of the accident.
12 Q Did that mean loss of level low?
/~T ,
kJ 13 A I would interpret that to be the intent 14 of that statement.
15 Q When is the first time that you learned 16 that during a small break loss of coolant accident
, 17 it was possible for pressurizer level to go off 18 scale high as a natural consequence of th accident?
19 MS. WAGNER: Objection to the form.
20 A I think when you look at LOCAs, you have f
. 21 to be very specific as to where their location is L 22 for a break outside of the pressuri=er is generally a 2,3 natural consequence to the level to go low.
(s- 24 For a break at the top of the pressurizer, l
4 25 it would be a general consequence of the level to go
,- , . . - - . . . - - , - , - , . , . .- -- - -- ,. ,. ._n . . , - - - --,-- .
f
~
Cartin d66
(~h
- ~
2 up. Everybody knew that. It was a natural 3 consequence.. It wasn't an expected. condition.
4 Q I am not asking you to testify to what l{ , 5 people in China know, to what people in Africa know.
6 I don't want you to tell me what everyone knows 7 because I don't think you know what everyone 8 knows, do you?
9 MS. WAGNER: I don't think you need to 10 yell at the witness. The witness is trying 11 to respond to four questions and if you want
- - 12 to ask him in a polite tone of voice, he may
[ ~\ '
\_/ 13 answer the question.
14 Q You don ' t know what everyone knows, 15 do you?
16 A That is correct.
17 Q When is the first time that you 18 learned as part of your active understand ng of the 19 operation of a B&W reactor coolant system 'that 20 pressurizer level could go up as a natural consequence 21 of a small break loss of ecolant accident? '
(L 22 MS. WAGNER: Mr. Seltzer, could I inquire 23 what you mean by " active understanding" as opposed
(~N
, I 24 to regular understanding?
v 25 MR. SELTZER: I mean not when does O
f 1
Cartin 167 r~% '
2 .
Mr. Cartin now believe it would have been 3 implicit in his knowledge.
- 4 I want to know when he explicitly knew
( 5 as a fact that pressurizer water level would 6 rise in response to certain small break loss 7 of coolant accidents.
8 A In general, an analyst; when he --
9 Q Not in general an analyst. I want to know
, 10 when you learned for the first time.
11 A I do not know the exact time I gained 12 that knowledge. One of my first jobs as an analyst
(~)
\~J -,
13 at.B&W was to analyze a break at the top o f th,e 14 pressurizer in regard to an accident. It was an 15 expected condition then the pressurizer level would 16 rise.
17 Q Who expected it? --
> 18 A In general before an analyst attempts to
- 19 make an analysis, he has some expectation of what i
20 he expects to see. It's good engineering practice I
21 to say this is what I anticipated to find, and if your 22 detail calculations confirm that,that's the normal 23 way that at least I would go about running an analysis.
f~}
L 24 Q Did you have detailed calculations that 25 con firmed that p re ssurizer wate r level would rise 4
1 Cartin 168 eQi e,
2 in response to a break in the steam space?
3 A The calculations that I performed indicated 4 that.
(- 5 Q Where are those calculations?
6 A I have no knowledge of their whereabouts 7 today.
8 Q Be as s.pecific as you can.
9 What writings do you recall existed at 10 the time that you are describing which would 11 describe a rise in pressurizer water level in 12 response to a reak in the steam space at the top 13 6f the pressurizer?
14 MS. WAGNER: .Are you including in that 15 que s tion wha't , for instance, computer runs you 16 could draw that inference from or a e you asking 17 for a sentence that level will go up, if there 18 is a break at the top of the steam s' pace?
19 MR. SELTZER: I believe that Mr. Cartin 20 testified that he saw something in writing that 21 described a rise in pressurizer water level in 22 response to a break in the steam space at the 23 top of the pressurizer.
[ 24 THE WITNESS: That is incorrect.
(
25 Q You do not recall seeing anything in
Cartin 169
_ (~N
'\-)' 2 writing that described a rise in pressurizer water 3 level in response to a break in the steam space at 4 the top of the pressurizer?
A
( 5 At or about the time I was doing those 6 paxticular analyses, no. Pressurizer level 7 wasn't exactly pertinent to showing acceptance as to the 8 criteria that we were trying to demonstrate.
9 Q So you did not c re a,t e and you don't 10 recall anything in writing that describ.ed a rise in 11 pressurizer water level in response to a small break 12 loss of coolant accident, is that right?
- s. 13 A I do not remember preparing a document 14 of that nature.
15 Q And you don't remember seeing a document 16 of that n atu re , is that right?
i 17 MS. WAGNER: Again, just to clarify the 18 question, because I am not sure thab it is 19 clear on the record, you are talkin'g about
! 20 something which says in the English language, t
, 21 this is what yo u s e e . You are not talking l -
22 about numbers from which one could draw that 23 conclusion; is that correct?
I') 24 MR. SELTZER: Well, let's take first a i (_./ -
25 description in words that describes a rise in
'A-
=
1 370 Cartin 0 2 pressurizer water level in response to a break 3 at the top of the pressurizer.
4 Q Is it a fact that you never saw such a 5 description?
(( '
6 MS, WAGNER: At or about the time that 7 he is talking,about, obviously.
8 A At or about the time in 1972 or '717 9 Q Whenever you were doing the ATWS analysis, s
10 A No, I never saw a description of that 11 nature.
12 Q Did you see any mathematical representation f^%
(_,)
13 of the response of pressurizer water level to a break 14 in the steam space at the top o f the pressurizer?
15 A The run I was examining was a break 16 equivalent in size to I believe a pressurizer safety l
l 17 valve under ATWS conditions. .
18 i
The code would have indicated a rise in 19 liquid volume within the control volume simulating 1
20 the pressurizer during the early parts of a transient.
i
, 21 Q You say it would have?
l .
22 A Yes.
23 Q When is the last time you saw those 24 calculations?
25 A I don't ever remember re-looking at those
- e. %
v ,
0 1 Cartin i
3 . ur
- s 2 calculations since that analysis was completed.
3 Q So more than a-decade ago you are talking
., 's 4 about?1'.s
( 5
, 'A ' i
~(
It's been at least approximately ten
)
6 years. '
7 Q You asid that it's your belief that the 53 5 ,
8 calculations \would have shown that.
. s 9 ,Do you have any specCfic recollection .,
10 of noticing that the calculations did in fact show -
i 3
11 th'at ?
3
. w 12 A I don't remember my exact' review process r ,
4 13 at that time. 1 l
- h.,
14 'In . ge .ne ra l , my genera 1' practice in
' 4
, s 15 conducting an analysis wo'uld be to examine plots of
, -1 3 16 what the system perforeance was and asking myself 17 whether they were reasonable and what I expected.
18 g s ,Ldt me be very clear. I don'$ want you 19, to speculdte on what yoa would have done. ~ _
6
. 20 -
I am.asking you do you recall today, i
21' ten or 11 years later, that ,
you actual'ly looked at C 22 this mathematic'al data an d' notice d that it showed a 23 rise in pressurizer water level for a break at the 24 . top of the pressurizer? ,
25 A I do not remember' making that exact
g h Cartin 2 s
.l I ?
observation, but I may have.
3 l
Q Did you ever tell anybody after the 4
Three Mile Island accident that you had some ten 5
years earlier reviewed data that showed a rise in 6 ~.
pressurizer water level in response to a small 7
break at the top of the pressurizer?
8 -
MS. WAGNER: '
I object to the form.
9 A No, I saw no reason to. I U3 Q Since the Three Mile Island accident, ',
I have you ever discussed with anyone other than 2 's counsel the fact that you think you saw data more 3( Ithan ten years '
ago that predicted there would be a i
rise in pressurizer wate r level in response to a small i
break at the top o f the pressurizer?
3 A
I don't remember any specific conversations, no.
~~ _
2 - >
I d Q At the November 2 7, 1978 meeting among I
Toledo Edison and B&W personnel to discuss problems with maintaining pressurizer level, did you point '2 "*"
i out to the attendees that in addition to the .
pa$sibility of losing pressurizer level indication low in response to a small break loss of coolant accident, m
3
\
' Ju knew that pressurizer level indication could clco go high in response to a small break loss of j
'(;
. 6) AJ [
1 ,
cartin 173
~~
2 coolant ac .
3 MS. N NER: Mr. Seltzer, I think you are 4 drawing an unfafr assumption from the witness'
( 5 te stimony.
6 ,
MR. SELTZER: Do you have an objection 7 to the testimony? Why don't you state it g instead of makfng a speech?
g MS. WAGNER: I object to the fact,that 10 you are eliminating f rom your que'stion an element '
11 of the~ witness' testimony, i.e., the analysis
< 12 that he did was under ATWS conditions.
13 ~
T u may answer the question.
J 14 A No, I do not remenBer making statements f that nature. I think they wouldn 't have been (i
15 16 appropriate.
f 17 Q Why woulan 't they have been appropriate?
18 A We were looking at a loss of[ressurizer
, 19 level in the opposite direction. -
_ 20 Q Do you have any recollection of discussing 21 with.anyone prior to the Three Mile Island accident L the anticipated fact that pressurizer water level 22 23 could rise in response to certain small break loss bg o4 of coolant accidents?
25 (c ntinued on the following page.1
3 1 Cartin 374
/~s ~
s 2 MS. WAGNER: Objection to the form.
1 3 A As a result of the ATWS analysis that 4 I conducted, I did prepare sone presentations l, 5 on the outcome of that analysis. I don't 6 remember the exact contents, and I do not re me mbe r 7 whether I made specific statements regarding the 8 calculated response of water volume or other 9 parameters that would relate to a pressurizer level.
10 Q So you are not sure that even in relation 11 to the anticipated transient without scram studies 12 that you did in or about 1972 whether you mentioned t^ . .r
(. 13 this unusual response of pressurizer level rising
. 14 following a small break loss of coolant accident, 15 is that right?
16 MS. WAGNER: I object to the form.
17 A I would not say it was an unusual 18 response for that particular accident. Ib was the
- 19 expected response.
20 Q You don't recall studying that response 21 even with regard to that ATWS study, right?
22 A I do not recall any specific instances 23 where I did, but I may have.
[~h 24 Q And you don ' t recall discussing it in t
's_)
25 any context other than that ATWS study, do you?
v - F , - - -- -%-. . , - _ . _ , , - , , . y
4 1 cartin 175
[ 'l
- ~
2 A Not at that time period, no.
3 Q .What about any time period prior to the 4 Three Mile Island accident?
5 A No, not that I remember.
.l{
6 Q You said you took issue with my calling 7 the rise in pressurizer water level an unusual 8 response.
9 Isn't it a fact that for all loss of 10 coolant accidents except a break in the steam 11 space at the top of the pressurizer, the normal 12 response of pressurizer water level is to drop?
(~)
(_/ 13 MS. WAGNER: Objection.
14 THE WITNESS: Would you repeat that, 15 ple as e ?
16 (Record re ad back. )
17 A It was not an unusual response for the 18 break that I analyzed.
19 I will agree with you for brea'ks outside 20 of the pressuriter, the initial response during the
. 21 LOCA would be a drop in pressuriser level.
L 22 Were you aware before the- Three Mile Q
23 Island accident that for system transients other than 24 a small break at the top of the pressurizer reactor 25 coolant system pressure and pressurize r level moved
I i
5 1 Cartin J76 2 in the same direction?
3 MS. WAGNER: Could you.rcad that back?
4 (Record read back.)
l 5 MS. WAGNER: Did you intend that to be 6 limited to LOCAs or any transients?
7 MR. SELTZER: Any transients.
8 A I don't believe I ever thought of that 9 particular relationship in that context. I was 10 aware that I could give you an e s timati'o n for a 11 given tran'sient as far as what pressurizer level 12 and pressurizer pressure would do.
(~ -
\- 13 I don't think I ever thought about that 14 particular concept insofar as direction.
15 Q Are you aware of any other transients e
16 besides a small break at ths' top of the pressurizer 17- which produces movement of pressurizer ~wate r level 18 that is in a direction opposite reactor e olant 19 system pressure?
20 MS. WAGNER: Are you asking for his 21 current understanding?
L 22 MR. SELTZER: No, his knowledge before 23 the Three Mile Island accident.
() 24 A Again, I had never thought of the concept 25 of pressure and pressurizer level moving in the same 5$
49 l \
6 1 Cartin J77 e n. -
\
2 direction.
3 .I prefer not to answer.that unless I was 4 . given adequate time to think about it and evaluate 5 it since it's a new concept to me.
(
6 MS. WAGNER: I don't think Mr. Seltzer 7 wants you to evaluate something now. He wants 8 your recollection of whether, some time before 4
9 March 1979, you thought about that.
10 A I had not thought about that concept in 11 particular.
12 Q Since the Three Mile Island accident, 13 have you ever discovered any transient that causes 14 pressure and pressurizer level to go in opposite
. '15 directions other than a small break loss of coolant 16 occurring at the top of the pressurizer?'^
l l 17 MS. WAGNER: Just before we go on, so 18 the record is clear, I take it you dnders tand 19 what Mr. Seltzer now means by pressurizer level l
20 and pressure. going in opposite or the same 21 directions," is that correct?
g 22 THE WITNESS: Yes.
23 MS. WAGNER: Now, why don't you answer his 3
(~}
U 24 question.
-25 A I really haven't thought about it.
-,y
- p , -
wn m - - - .eg t"
I 4 7 1 Cartin 178 h~
' ~
2 MR. SELTZER: Let me mark as GPU Exhibit 3 82-A a, clearer version of what'has previously
, 4 been marked as GPU Exhibit 82.
(( 5 This is a memo from Cartin to Karrasch 6 dated November 29, 1978, subject: "TECo - B&W 7 Meeting Minutes." It's' stamped with the 8 identification No. T21883 on the firs t page.
9 (Clearer copy of GPU Exhibit No. 82 10 marked GPU Exhibit No. 82-A for identification .
11 as of this date.) -
t 12 Q Did you ever discuss with anybody after 13 the Three Mile Island accident howmanfpeople in 14 Eric Swanson's group knew before the Three Mile 15 Island accident that a break at the top of the e
16 pressurizer would produce a rise in pressurizer water 17 level? .
18 MS. WAGNER: Objection to the form.
~
19 A Would you repeat that?
- 20 Q After the Three Mile Island accident, i
- 21 did you ever have a discussion among the people in 22 Eric Swanson's group to see how many of them 23 actually knew before the Three Mile Island accident 24 that a break at die top of the pressurizer would 25 cause pressurizer water level to rise?
-' - - - - - -- -
- wu---"'-*-'
1 Cartin .179 bi v.
2 A No.
3 MS. WAGNER: Objection to the form.
4 Q Did you ever have any discussion wich
( 5 Be rt Dunn after the Three Mile Island accident to 6 ask him what his understanding was prior to the 7 Davis-Besse event about whether a break at the top 8 of the pressurizer would cause a rise in pressure 9 water level?
10 A No. I don't remember a co'nversation 11 of that nature.
12 Did you ever have such a conversation
, Q k- 13 with Bruce Karrasch?
14 A- I don't remember talking about that 15 subject to Bruce Karrasch.
16 Q Did you ever talk with anybody about i
17 when they first knew that a break in the steam 18 space at the top of the pressurl=er would produce 19 a rise in pressuri=er water level?
l 20 MS. WAGNER: Objection to the form.
21 A I believe I would guess I had talked
(
22 about that after the accident. I believe I also 23 addressed that particular subject in the preparation n 24
( of ATOG guidelines.
25 g You are missing my point.
1 Cartin 180 U- . 2 The question is did you ever discuss 3 with anybody after the accident when, prior to the 4
accident, they gained actual knowledge that a break
( 5 in the steam space at the top of the pressurizer would 6 produce a rise in pressurizer wate r level?
7 A No.
0 Q After the Three Mile Island accident, 9 do you re, member working with D. G. Newton on 10 developing operating instructions for a'. stuck open 11 pilot operated relief valve?
12 A I worked on that area briefly, yes.
F)
", 13 Q Who was D. G. Newton? .
14 A He was another engineer within our group.
15 Q He was Eric Swanson's group?
16 A Yes.
17 -
Q I would like~to~showpou GPU Exhibit ~~297 10 and ask you if this is a copy of a memorandum which 19
, you and Newton prepared and circulated on or about i
20 April 8, 1979.
21 A This must be the predecessor of a memo I
k ,,
that possibly was released, but I didn't actually sign 23 the memo. It does have my name on it. _
p 24 t Q Newton had prepared an earlier draft of -
25 this, hadn't he?
t -
h
1 Cartin 181 s
/ 2 A I don't remember the exact circumstances 3 under which ,these guidelines were prepared. Both he 4 and I worked on various parts of them. I don't know who prepared the actual drafts.
( 5 6 Q Take a look at the second page of the 7 exhibit.
8 - Do you see the item numbered 3 at the 9 bottom, " Symptoms of a Stuck Open PORV"?
10 A Yes. t j * .
11 Q Under 1 you have, " Decreasing reactor 12 coolant p res sure ," with "A, Pressuricer level 13 incropsing or indicated high; B, stabl or increasing 14 reactor coolant temperature."
15 How did you know that a symptom o f a 16 stuck open pilot operated relief valve would be 17 pressurizer level increasing or indicated,high?
18 MS. WAGNER: Object to the fo$m.
19 A I don't remember the exact bas'es for 20 developing this symptom other than intuition.
21 Q Let me show you what D. G. Newton had 22 drafted earlier that same day and I will mark it as 23 GPU Exhibit 496. It's a memo from Newton to Womack,
-(']
\ms 24 subject: " Operating Instructions for Stuck Open 25 PORV" dated April 8, 1979, 12:57 a.m.
1 Cartin 182
('~\ ~
U~ 2 (Memo from Newton to Womack, subject:
3 " Operating Instructions for Stuck Open PORV" 4 dated April 8, 1979, 12:57 a.m., marked 5 GPU Exhibit No. 496 for identification as of
(
6 this date.)
7 Q What I want to call your attention to is 8 page 3, item 4, " Symptoms of a Stuck Open PORV."
9 Mr. Newton has identified the symptoms 10 of a stuck open PORV as " Decreasing RC ressure 11 or pressurizer level with no decrease in RC temperature 12 or increase in let down flow."
(/
s.
)
13 Do you see that?
14 A Yes.
15 Q In preparing GPU 297, did you notice 16 that Mr. Newton had been in error in what he had 17 described as the symptoms of a s tuck open, PORV in the
~
18 draft he had prepared earlier that day?
19 MS. WAGNER: I object to the f'rm.o 20 I don't believe the witness has testified that 21 he did prepare GPU 297, although he may have; L 22 nor do I think it was established that he ever 23 saw GPU 496 prior.to any later memo.
- 24 A I don't remember specifically this meno.
25 MS. WAGNER: Re ferring to 496 from
1 1 Cartin 183 D)-
(~ 2 Mr. Newton to Mr. Womack.
3 Mr. Cartin, I will advise you now not 4 to interpret these documents. Mr. Seltzer 5 wants to know about the preparation of these
{
6 documents.
7 If you have a recollection, give it to g him, but if you don't, don't inte rp re t these 9 documents.
10 A I did assist in the preparation of this e
11 memo, or onc that was changed subsequer ly to it, i
12 but not to my recollection this memo.
()
(~h 13 MS. WAGNER: The witness identified 14 GPU 297 as the one he worked on but not GPU 15 496.
16 Q Did you ever tell Newton that'he was 17 wrong in thinking that the symptoms of a s tuck 18 open pilot operated relief valve include d -decre asing 19 pressurizer level? -
20 MS. WAGNER: Objection to the form.
21 A I believe Mr. Newton and I were in agreement 22 as to the symptoms we indicated in the memo that he and 23 I -- the memo, GPU 297.
24 Q In other words, to the extent that the 25 symptoms in GPU 297 are dif fe ren t from those in GPU "f m w - -m- o -,ww w
I Cartin 184 2 496, Newton's views had changed?
NS. WAGNER: Objection-to the form.
3{
4l The witness has not identified having g 5 knowledge of 496. I don't think he can answer 6 a question about Newton's views based on two 7 memos, and I'dir'tect him not~ to answer.
8 Q You made a statement earlier that everyone 9 knows something about what happens to pressurizer 10 level in response to a break at the top. of the 11 pressurizer.
12 when you made that statement, you didn't
(~)N
(_, 13
- have in mind what Newton's thinking had been in 14 April 1979, did you?
15 MS. WAGNER: Objection to the form.
16 A I was not particularly thinking of Mr.
17 Newton at the time when I made that statement.
18 The statement was one, of an issue that w$s at least 19 obvious to me.
~
20
- MR. SELTZER: I don't think we have any 21 further questions.
L 22 Do you want to cross-examine later?
23 MS. WAGNER: I do.
fT a 24 (Whereupon, at 12:50 o' clock p.m., a lunch I 25 recess was taken.)
I 185 2 AFTERNOON SESSION 3 - L4:40 p.m.)
(' 5 resumed.
6 EXAMINATION BY MS. WAGNER:
7 Q Mr. Cartin, you have been asked questions 8 during this deposition about GPU 330, which is a 9 memorandum writter. by Mr. Jones to you on December 10 11, 1978, e 11 Did you have an understanding at or 12 about that time of whether or not Mr. Jones had a
[h
\/
13 position with respect to the issue of pumps running 14 about which you have testified during this deposition?
15 A It was my understanding at that t me that 16 Mr. Jones' position was that tripping the pumps 17 early in the event as assumed in the past. analyses 18 bound the consequences that would occur if the RC 19 pumps were assumed to operate continuous 1y.
20 Q Did you know at or about that time whether 21 he had any position with respect to whether an analysis, k _ _ _ . . _ _ _ . .
22 a further analysis was needed?
23 A At that time he agreed with my previous
() 24 recommendation that it was --
it would be very 25 helpful to document and make this issue clear,
1 Cartin 186 l s
! 2 obviously clear that tripping the pumps early was 3 a worst case should this issue be raised in the 4 future.
( 5 Q What was the basis for your unders tanding 6 just testified to about Mr. Jones' position?
7 A Both this memo and discussions I had 8
with him after this memo was issued.
9 Q What was the subject of the conversations 10 af ter the memo was issued? L 11 MR. SELTZER: I object. For you to be 12 introducing this through cross-examination of p
0 13 your own witness when it's clearly hearsay I 14 think is improper.
15 -
MS. WAGNER: You think it is hearsay for 16 this witness to testify about the subject i
17 of his conversation with Mr. Jones?-
18 MR. SELTZER: Yes. If you are asking 19 him to testify about the substance of what 20 Jones told him, that's the heart of hearsay.
21 MS. WAGNER: I am asking him to t e s ti fy l .
22 about what his unders tanding was based on 23 what Jones told him.
(j 24 MR. SELTZER: I object; that's clearly 25 hearsay.
1 Cartin 187 I' )
2 Q You may answer the question, Mr. Cartin.
3 A During those discussions we talked 4 briefly about the items identified in his memo and 5 specifically about the resource requirements that
{
6 I had specifically requested of him.
7 Q After this conversation was an analysis 8 performed?
9 A Yes, it was, and it was started in January 10 of the next year. e 11 Q In that analysis, what assumption, if 12 any, was made abo ut reactor coolant pumps?
(,)
13 A Reactor coolant pumps were assumed to 14 operate continuously during the small break analyzed.
15 Q Do you recall that you testified earlier 16 that you did not at that time have a basis for 17 assuming one way or another whether the pumps 18 physically could run under those circums$ances?
19 A Yes.
l 20 Q Was'it any purpose of the analysis l
i 21 that was performed, to the best to your knowledge, 22 to determine whether or not the pumps physically 23 could run in the circumstances assumed in that analysis?
24 A No. The exact purpose was to evaluate 25 what the system response would be assuming the pumps I
j 1 Cartin 188 i
2 e opernted continuously.
3 Q Was any assumption made in that analysis 4 about a change in the pump status?
{ 5 A No, for that particular analysis the 6 pumps were assumed to operate continuously.
7 Q At or about this time were you aware of 8 any analysis in which any assumption was made with 9 respect to the pump status other than the one you 10 have just testified to or which you prgviously .
11 testified to the pumps tripped status?
12 A No. At that time the only assumptions (h
\_) 13 under consideration was assuming a' pump trip due to '
14 a loss of off-site power at reactor trip and the 15 second situation was continuous RC pump operation.
{ 16 Q Did there ever come a time when a pump
- 17 status other than what you have just described was
~
[
18 considered? -
19 A Following the TMI 2 event, the status of 20 the RC pumps was further evaluated for loss of I
21 coolant accidents under a set of assumptions not i
22 previously considered,PSC was issued that identified 23 that a pump trip during the course of a LOCA could fT
'd 24 result in more severe consequences than previously 25 predicted.
I
._ . . _ _ . , , . _ , . . . _m , _ , - _ _ - - - - . - - . - - , , - - - - - . . ~ - - ~
1 1
Cartin 189
\ l' Was any analysis done to your knowledge 2 Q 3 with respect to the issue you have.just described?
4 A Yes, a detailed analysis was done.
{ 5 Q What was the conclusion of that analysis?
6 A That analysis generally showed that there 7 is a break, a range of small break sizes approximately 8 .02 to .2 square foot in area for which or during 9 which a pump. trip at certain times in the event 10 could lead to more severe consequences.
11 Q Do you know what the size cf the opening 12 was in the opening of the TMI-2 PORV?
13 A It's approximately .007 square f ee t.
14 Q Was a break of that size addressed by 15 the conclusions reached in the analysis o f the p ump 16 trip at some time other than the reactor trip?
- - - - - 17-- -
A That analysis would indicate that the pump 18 status would have no bearing on the overall 19 acceptability of the f ailed open PORV unde'r standard 20 LOCA assumptions.
21 Q - . . this analysis that you have just
( . - - - -
22 described, was any assumption made with respect 23 to the status of high pressure injection?
("]
v 24 A To the best of my knowledge, that analysis 25 included at least the minimum flow from at least one 9
1 Cartin 190
< (~%
- 2 train of HPI.
3 Q Do you know if that assumption was also 4 made in the analysis of pumps running that you have
[ 5 described was done in January of '79?
6 A Not specifically, but that would be the 7 standard LOCA assumption ~ for small break analyses.
8 Q Mr. Cartin, do you recall yesterday, 9 I believe, testifying about an interview you had with 10 an I&E inspector? E 11 A Yes.
12 Q Was that interview in any way recorded?
'N ,
s 13 A
, No.
l 14 Q Was it tape recorded?
15 A No.
16 Q Was it recorded by a stenographer?
17 A No. .
18 Q Were you ever asked by anyone to review 19 any summary of that conversation for accurhey?
20 A No.
21 Q Mr. Cartin, Mr. Seltzer asked you some 22 questions about what was marked this morning as GPU 23 Exhibit 82-A for identification. He was asking you I~h 24 questions about Table 2, I believe, about the column b
25 entitled "LoCAs."
1 Cartin 191
('
2 I would like to ask you some questions f
3 about the column entitled " Condition'2 Events."
4 What are condition 2 events?
5 A
{ Condition 2 events are generally events 6 of moderate frequency. That is, they are expected 7 to occur on the order of at least one per year.
8 Typical examples that we considered here 9' was the loss of off-site power, stuck open secondary 10 side relief valve and loss of main feedwater. .
11 Q What would be included in a definition 12 of a stuck open secondary side relief valve?
-~
s_/ 13 A That may include the opening either 14 partial or full open of a relief valve, a~ secondary
, 15 safety valve, or even a turbine bypass valve.
16 When you refer to a relief valve, you are Q
17 referring to a relief valve on the secondary side?
18 -
A That is correct.
~
19 MS. WAGNER: I have no further' questions.
21 Q You have referred in your testimony to L 22 the analysis o f the p ump s running case that was 23 done in January 1979.
/~N 24 Who did that analysis?
k_
25 A It was conducted by the ECCS unit.
1 Cartin 192 0 2 Q Were you aware before the Three Mile 3 Island accident that they were doing that analysis? ,
4 A Yes.
( 5 Q What was your involvement with t'at h 6 analysis?
- 7 A At the t.ime the analysis was conducted, 8
I had no involvement.
9 Q ,How did you know the analysis was being 10 performed? ;
11 t
A I had been involved in the recommendation .
19~
,-s leading up to the analysis.
13 Q Did you stay in contact with the ECCS 14 analysis unit personnel who were performing that 15 analysis? .
16 A I talked to them on occasions.
17 Q Did they let you know how the* analysis
! 18 was coming along?
I A I do not remember any specific occasions 0
where I inquired specifically.
l 21 Q Did they let you know at least that i L 22 their analysis in January was. supporting the 3
conclusions which Jones had described to you in 24 December of the previous year?
25 A I had knowledge of their results at the
4 1 Cartin 193 o 2- time the analysis was conducted. I do not remember 3 how I actually came to acquiring that knowledge.
4 Q So you knew that their analysis showed 5 that even though there were increasing void fractions
{
6 for certain break sizes, the pumps running case 7 turned out to be a safer situation than pumps off at 8 the time of transient initiation?
9 MS. WAGNER: I object to the form.
10 A Their analysis showed that(most limiting 11 consequences occurred with the pump tripped at the 12 beginning of the accident.
13 Q And it showed that even though with the 14 pumps on for certain cases very high void' fractions 15 were produced, is that correct?
. 16 MS. WAGNER: I object to the form.
_ _ _ __ 17 - A._ -. .L did not -re view.ln de tail the calculations 18 performed. I only had knowledge of the bas'ic conclusions 19 reached.
20 Q Were you aware that when they did that 21 analysis, they found that increasingly high void 22 fractions resulted for certain void sizes with the 23 pumps running?
t 24 ,
MS. WAGNER: Objection.
25 A To the best o f my knowledge, they only h
JP ,'
1 Cartin 194
~
U(~\ 2 analyzed one break. I was not generally aware of 3 what void fractions were calculated.
4 Q Take a look at GPU 282, please, which
( 5 is the PSC report for the pumps running case.
6 Do you see the paragraph that begins just 7 below the single-spaced entry?
8 A Yes.
9 Q It begins with the words " Examining this 10 case." t 11 A Yes.
12 Do you see in the second sentence where Q
("~)h
(_ 13 it says that the case that was run also shows 14 that the reactor vessel would contain only approximately 15 550 cubic feet of water in ten minutes after the break?
16 A Yes, I see that.
~17 Are you aware that that means,that less Q
18 than 20 percent of the total inventory of water in
~
19 the reactor coolant system would be left in the 20 reactor coolant system?
21 MS. FAGNER: I object to the form.
22 Now, Mr. Cartin, he is not asking you 23 to analyse it. He is asking you if you are 24 aware of that.
25 MR. SELTZER: I am asking for a little bit
1 Cartin 195 O 2 of analysis. If he knows what the total 3 inventory in the reactor system is and knows 4 that 550 feet constitutes less than 20 percent, 5 then he knows the answer.
(( '
6 MS. WAGNER: I will state my objection, 7 but I will allow the witness to answer.
8 A The total inventory of the RCS is about
, 9 10,000 cubic feet or more. I don't know off the 10 top of my head what percentage 550 would be, but if 11 simple mathematics was done, it could be easil;r 12 determined.
(-)b
\- 13 Q Were you familiar before the Three Mile 4
14 Island accident with the concept of cavitation in 15 a water pump?
16 A Not in detail. I had heard the term, yes.
U Q You knew what it meant? ,
18 A only vaguely.
Were you familiar with something' known 19 Q 20 as a net positive suction head?
21 A In general I had considered it. Today 22 I probably couldn't give you an accurate definition.
23 Q But before the Three Mile Island accident, I
t -s
(} 24 you were familiar with the concept of net positive 25 suction head as applied to a reactor coolant pump?
1 Cartin 196
\'
2 A I don't ever remember examining that in 3 detail.
4 I have heard of the term " net positive
( 5 suction head" both at B&W and previously in college.
6 Q Were you aware that B&W issued net positive 7 suction head curves that governed the range of 8 operatability of reactor coolant pumps?
9 A No, I am not specifically aware of that, 10 no. t 11 Q Did it ever occur to you before the 12 Three Mile Island accident that operating the O)
\/ 13 reactor coolant pumps in a highly voided environment 14 would cause destructive cavitation?
15 MS. WAGNER: Objection to the form. ,
16 A No, I had never thought specifically of 17 that. .. ..
18 Did you know be fore the Three Mile Q
19 Island accident that operating reactor coolant 20 pumps in a highly voided system could result in 21- increased vibration?
L 22 A Not specifically, no.
23 Q Did you know that B&W in its limits I)
V 24 and precautions precluded operation of reactor 25 coolant pumps with vibration exceeding certain
_ _ . _ _ - . _ _ ~ -_.
_ _ .. _ . _ _ _. . - _ _ _ _ . _ _ . _ _ _ _ _ - . = . _ . _ . _ _ _ _ _ . _ _ .
') .
1 l Cartin 197
, 2 specified limits? *
! 3 A No, I did not.
- b. -
4 Q Did 'it ever occur to you that continuing 5 to operate the reactor coolant pumps under the
({
6 conditions specified in the pumps running case would 7 violate B&W operating instructions?
i 8 MS. WAGNER: I object to the form.
9 A Prior to TMI-2, no.
10 i
Q After TMI-2, did that occur to you? ..
i 11 A I had heard that raised as a reason, as t
12 a supposed reason why they cut the pumps off at 13 TMI-2.
14 Q Did you ever verify whether what 15 - you had heard was correct?
16 A No, I did not.
17 Q You never made any attempt to., find out- -- --
i 18 whether B&W had limits on net positive subtion head 19 or on vibration?
20 A No, I did not.
21 Q Did you know that cavitation is caused L 22 by steam in a water pump?
23 A In concept, yes.
{ 24 Q You knew.that before the Three Mile
, 25 Island accident, right?
5'r JP 4
1 Cartin 198
\ 4 O 2 A Yes.
3 Q You knew that steam could cause 4 pitting on the veins of the pump, didn't you?
5 A No, sir.
{
6 MS. WAGNER: Objection to the form.
7 Q You knew that cavitation was an undesirable 8' feature of pump operation, didn't you?
9 A . I was not a pump expert and really did not 10 unders tand in detail the impact of cavitation on 11 pump performance.
12 You knew that cavitation worsened the Q
13 performance of a pump as opposed to ma ing it better?
14 A In general, that's correct.
15 Q And you knew that the performance steam 16 that was introduced into a liquid pump, the more 17 cavitation would occur, didn't you? .
18 A No, not specifically, no.
19 Q You had never hea'rd that be fo r'e the 20 Three Mile Island accident?
21 A I would not say I could stand up and 22 defend that based on my knowledge.
23 Q Did you ever ask anybody when you heard
( 24 about the study of the pumps running case, did you 25 ever ask anybody whether running the pumps in a voided
4 r
g i
! e n 1 -
Cartin a- 199 s
' ^
r
_QO). i s ,
2 environment would cause excessive, cavitation?
3 A No, I did rot. '
4 cQ Do <you knowlwhether anybody else was j a y ,
C 5 raising a question abc.ut that?.
zy ;
/
6 ' , ,
~h I was raavare of that at that timeo 1 , 1 , ,
7 Do you undersjapd ,that 'one of the items
~
Q I
L 8- for which,B&W was fined 1.y' thc NRC was the failure
~
to report to the NRC the item 6 in, y'our meNtoran dum,
,9
, 10 GPU 122? I
.7 I
11 MS. WAGNER:
~
,0bj1t0 tion to the form.
r
'12 [A No, I do not'ktow that'for a fact.
j' 13 Q I.e t me sho.w you yogr copy of GPU 122
- j. s. / ,, , .
T 14 taken from your flies hS.ch we',w$.Il mark as GPU 122-A.
o 10 (Copy- ofOPU(Ephibit]y
/ ;\ i\
j ,
.i 122 taken from t
16 Mr. CartIn's fih*.s Ir'arke'didPU Exhibit No. 122-A
~3,,/ ,-
7, e
r, 4
17 for ident4fication ag of't'his date.)
\ i .
18 J) ,
~
Q That 's your han writing i$' ~the right-hand 10-
- m'argin of GPU 122-A, is the.t correht? '
s _
! 20 'A Yes. ,
,p , 2 ' ', , g ,e ,
.-' / 21 Q Read what you wrote in'the margin, ,
Q, '.
- / 's .
l, please.'
22.
l ,c '
e t -
\
' > 4 I
23 -n A; Thi . firs t ,ccmnent to the ri ght- he,n ct, marginof'} item 6 i's "Conkithon6clieved[tobe
~
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sif e .
6 c' ,- '
25 Need documentation."
r /, j f
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a s \'
l I
1 Cartin 200
[ }
"#~
2 Q What is the next comment in the margin?
3 A ." B & W to define schedule and document 4 position. No need for additional schedule pressure."
Q Do you see the 3s that you wrote in the
([ 5 6 left-hand margin?
7 A I did not write those 3s.
8 Q Do you know who did?
9 A No, I don't.
10 Q When is the first time you noticed that 11 those 3s were there?
12 A I don't remember putting any bearing on
(\m)'h 13 their being there one way or the other.
14 Q Let me show you a copy of the citation 15 which B&W received from the NRC, April 10, 1980, 16, fining B&W a lot of money for violating NRC rules 17 and regulations. ,
18 MS. WAGNER: I object to the f'o rm .
I
! 19 We will mark this as GPU Exhiblt 497.
l 20 (Letter to The Babcock & Wilcox
, 21 Company from United States Nuclear Regulatory 22 Commission dated April 10, 1980 marked GPU 23 Exhibit No. 497 for identification as of I
/~N 24 this date.)
25 Q This is a copy of the NRC's citation of a
__e m., , - 9 m --
t -* - - -- -"
f y $
l 1 Cartin 201 2 B&W resulting from.the TMI-2 accident which was l
3 produced from your files in this litigation.
4 MS. WAGNER: I object to the form of that
( 5 comment.
6 Q Would you turn to the appendix page 2, 7 please.
8 Do you recognize your handwriting in the 9 left-hand margin? ,,
10 .A Yes, e 11 Q What did you write next to item 37 12 A I wrote that "me" and "me."
O k./ -
13 Q ,
Those are your comments next to item 2 14 and item 3, right?
15 A That is correct.
16 Q And it's a fact, isn't it, that you 17 wrote "me" next to each of those because you recognized -
18 that those two items referred to actions which were 19 allegedly taken by you, isn't that right?'
20 MS. WA'GNER: Objection to the form.
21 A I wrote that because the topics here were 22 items that I had worked on or I had been associated 23 with to some extent.
eO t/
24 Q Item 3 you say re ferred to a topic that 25 you had worked on. Specifically, that is the same
1 Cartin 202 2 topic that's in item 6 in your report, GPU 122, isn't 3 that right?.
4 A I would like to read this item if that's 5 acceptable.
(
6 Item 3 of the NRC letter, GPU 497, and 7 item 6 of GPU 122-A do address a common subject.
-a 8 That is an analysis with the RC ' pumps running.
9 Q So this does now refresh your recollection 10 that B&W was fined and cited by the NRC for acts 11 relating to matters that you were responsible for?
12 MS. WAGNER: I object to the form of the s
d(~h 13 question.
14 You may answer it.
15 A I have no exact knowledge o f the final 16 reasons why fines were levied or pa,id.
17 But you know that the NRC citation that Q
18 was issued to B&W cited B&W for acts that you were
~
19 dealing with with regard to the pumps running analysis, 20 isn't that right?
21 MS. WAGNER: I object to the form. The
..k_.. 22 document does not indicate acts taken by 23 Mr. Cartin were the subject of a fine.
24 A
( I acknowledged that several topics that 25 I worked on were discussed in the NRC letter.
e
1 Cartin 203
/^N '
2 Q Now, *he NRC said in item 3 of GPU 497 3 that, "a small break LocA analysis wSth reactor 4 coolant pumps running had not been performed for
[ 5 Babcock & Wilcox plants."
6 Do you see that in the first sentence of 7 item 37 8
MS. WAGNER: I believe,.Mr. Seltzer, it 9 indicates a time frame, "as early as November 10 1978." tt d
11 MR. SELTZER: Fine.
12 A Yes, I see that.
(~)
k/ 13 Q It says, in fact, that " senior engineers 14 at Babcock & Wilcox were aware as early as November 15 1978," that such an analysis with pumps running had 16 not been performed.
17 It's correct, isn't it, that as of 18 December 1978 you specifically were aware that 19 there was no documented analysis of the pumps running l
20 case for small break loss of coolant accidents, 21 isn't that right?
L 22 MS. WAGNER: Mr. Seltzer, this has been 23 asked and answered a number of times.
( 24 A At that time I was not aware of any 25 documented analysis, that is, computer calculations
l
)
l l
1 Cartin 204
[ )
'# 2 and calculational files in support of those for RC 3 pumps running during a small break.
4 Q You testified yesterday that you knew
{ 5 that you had to have a documented analysis in order 6 to comply with 10 CFR 50.46.
7 Did you ever discuss with anybody other 8 than counsel whether the lack of a documented analysis 9 o f the p umps running case for small break loss of 10 coolant accidents constituted a defect tunder part 21 11 of.the NRC rules?
12 MS. WAGNER: Mr. Se ltce r , I object to your I
\_/ 13 comments made prior to your question which 14 I believe misstate the witnesses te s timo ny ,
15 Could you repeat the question?
1 16 MR. SELTZER: I was only trying to avoid 17 what you said. I am asking the same questions
~
18 I asked yesterday.
19 Let me ask the same question a'g a in .
l l
20 Q Isn't it a fact that in order to 21 demonstrate complian ce with 5 0. 46 B&W has to have L 22 documented analysis?
23 MS. WAGNER: Object to the form, i
/~h 24 A We perform analyses and submit that V
25 analysis to show compliance to 10 CFR 50.46. Some
1 Cartin 205
~
of our assumptions are based on engineering
- 3 assessments .and enginee ring j udgments.
4 Q But the analysis to demonstrate compliance
{
5 with 50.46 has to be documented and avilable for NRC 6 review and it has to be in writing, doesn't it?
7 MS. VAGNER: Objection.
8 A Anclyses conducted are generally documented 9 per the requirements of our internal procedures.
10 I don't think 10 CFR 50.46 lays out int.ernal 11 documentation requirements.
12 Q Well, in fact, you had to submit topical C~.)) 13 reports in writing to the tiRC to demonstrate complian ce I4 with 50.46, didn't you?
15 A That is correct.
16 Q Those weren't oral reports, were they?
17 A No. ,
18 Q You didn't have any written report for 19 the pumps running case in the end over 1978, did you?
20 A That is co r re c t'.
21 So you couldn't have demonstrated Q
-22 complian ce with 50.46 with any written presentation as 23 of the end of 1978, could B&W?
24 MS. WAGNER: Objection to the form.
25 I believe there are documents introduced
1 Cartin 206
.gS -
. %-)
2 during this deposition which bear on that 3 issue..
i 9
4 A At that time our engineering assessment' ,
4 5 was that a pump trip due to a loss of off-site power
(
6 at reactor trip was a worst case assumption, and based 7 on that, the topical report submitted to the NRC 8 with that assumption demonstrated compliance to
.9 10 CFR 50.46.
10 Q Did you ever discuss with abybody at B&W 11 outside of counsel whether the lack of any written 12 analysis demonstrating the pumps running was not the
(~
N- 13 worst case constituted a defect in B&W'.s work that ,
14 should have been reported to the NRC under part 21?
l 15 MS. WAGNER: Mr., Seltzer, are you using e
i 16 the term " defect" in its normal English usage?
l
- - - - - - - - - -- 17 MR. SELTZER: I am using it in the sense 18 in which it is used in the sentence which has 19 the word "me" written next to it by Er. Cartin.
20 MS. WAGNER: I will object insofar as l 21 your question calls for Mr. Cartin to
.(_ -22 draw a conc [usfon wi$h respect to the analysis 23 of a regulation.
( 4 Mr. Cartin can certainly testify to his 25 understanding of the practice in B&W.
1 Cartin 207 2 Q Mr. Cartin, all I am asking you is, did 3 you ever discuss this with anybody, not a lawyer?
4 A I do not remember discussing that, no.
5 Q After you got a copy of GPU 497, didn't you
{
~
6 discuss item 3 with people who weren't lawyers?
7 A Only with my immediate supervisor I had 8 a conversation.
9 Q That's Eric?
10 A I had a conversation with E_ric Swanson.
11 He may not have been my immediate supervisor at that 12 time.
Os- 13 Q Did you also have a conver[ation with 14 whomever was your immediate supervisor at that time?
15 A No.
?
16 Q Did you and Swanson discuss whether the 17 lack of a documented analysis of the pumps running ,
18 case in 1978 constituted a reportable defect, in 19 other words, something that should have be~en reported 20 to the NRC?
21 A I don't remember a discussion to that 22 effect.
23 Q Did you ever discuss with Eric whether f'} 24 the absence of a pumps' running analysis should have
%)
25 been reported to the NRC7
4 1 Cartin 208 (T ~
. (_/ 2 A I don't remember discussing that with 3 Mr. swanson. ,
4 Q Did you ever discuss that with anybody 5 at any time?
C 6 Ms. WAGNER: Other than counsel.
7 A No, I don't remember discussing that.
8 Q Did you ever discuss with anyone whether 9 you or any other engineer should have reported to 10 James Taylor the fact that there had b en no documented 11 pumps running analysis done by B&W prior to the end 4
12 of 1978?
() 13 A No, I don't remember discu[sions to that 14 effect. ,
15 Q Until the analysis was done of a pumps 16 running case, didn't it occur to you that it was
, 17 at least an open question whether pumps off was a 18 worst case? -'
19 A No, we were of the opinion, both ECCS 20 and I agreed with their assessment that the 21 assumptions made in the previous analysis were indeed
- (- 22 worst case and appropriate for use. I at no time 23 considered the pumps running to be more severe.
t 24 I did recommend that we do analyses so we can have
's 25 it documented, and it was done very quickly.
- e w , , w- ,,- n w-m--- ww-, g,e,- -m-- y -nv_,a-m, y-yy,.ga y- m.y 4 7 e y -g ,.+------.,ng, - - < - - - --
1 Cartin 209
[)
\_/ 2 Q You knew that the NRC would expect 3 you to have documented analyses of.the pumps running 4 case, didn ' t you?
5 MS. WAGNER: Objection to the form.
C 6 A I knew that it was --
it would be very 7 good that if this issue was raised,'that we would have 8 documented analyses.
9 Q It was your view that if this issue 10 were raised with the NRC, the NRC would insist on 11 documented analyses, isn't that right?
12 MS. WAGNER: Objection to the form.
['\ 13 A
( ,; Not necessarily.
14 Q Wasn't it your view that if you were not 15 able to satisfy the NRC with documented analyses, i
16 that there was a serious danger that the NRC would i
17 derate or shut down all B&W operating plants ?
18 MS. WAGNER: Objection to the ~ form.
19 A My view was if that issue were raised and 20 the NRC did not accept our engineering judgments, 21 they could request an analysis and the worst thing k 22 that could happen is that they could take some interim 23 action o f some nature, possibly derating a p. nt.
~
24 They could take an interim action until that analysis
~s 25 was completed.
i i
L
I
, Cartin 210 fw -
2 Q And you anticipated that they could take 3 that action because they might consider the lack 4 of a documented analysis a serious safety concern, 5 isn't that right?
6 MS. WAGNER: Objection to the form of 7 the question. There is nothing like that in 8 -any testimony or document.
9 You may answer. -
10 A In our opinion we did not qonsider it a 11 serious safety concerns only a matter of lack of 12 detailed documentation.
[\
'y/ 13 MR. SELTZER: I move to str"ike that as 14 not responsive.
15 MS. WAGNER: It's perfectly responsive.
16 You asked him if he thought it was a safety 17-- ---- -- - -problem and he s aid he didn't think so.
18 MR. SE LTZER : Why are you argding with me?
19 This isn't the time for arguing the motion.
e 20 would you repeat the question.
21 (Record read back.)
L 22 Q In other words, I am not asking you whether 23 you considered it a serious safety conccrn. I am
('
\
24 saying, isn't it a fact that when you anticipated 25 that the NRC might derate or shut down all B&W I
gr ,'-
T 1
Cartin 211 rN -
( )
N/ 2 operating p1nats, you were thinking that the NRC 3 would consider this a very serious. safety concern?
4 MS. WAGNER: Objection.
r 5 A I was trying to put the actions, the 6 potential actions of the staff in the worst type of 7 atmosphere to support funding availability for 8 the analysis. I was not trying to say this is what 9 I expect them to do. Only that can never be ruled 10 out as a possible action by the staff f.o r wha te ve r
-~~~, .-
11 reasons they deem appropriate.
12 Q Isn't it a fact that you were anticipating
( ) 13 that the NRC might shut down all B&W p[ ants because 14 the NRC staff perceived the lack of a pumps running 15 analysis as a significant safety issue?
16 MS. WAGNER: I object to the question.
17 It's been asked and answered, but you may answer
~
18 it again.
19 A I was fairly confident that ou'r engineering 20 assessment would be directly accepted by the staff.
21 I was only trying to use the argument of potential 22 staff actions as a means to convince people that that 23 analysis ought to be done and f un de d .
24 Q It's a fact, isn't it, that you believed
(~))
Q 25 B&W should not report the lack of a pumps running
1 Cartin 212
\/ 2 analysis to the NRC.because you were afraid that B&W 3 would have all of its operating plants shut down?
4 MS. WAGNER: I object to the form.
5 A -That's totally not true.
6 Q Isn't it a fact that you also believed 7 that B&W shouldn't even disclose this problem to 8 its customers because they would be required to 9 report the matter to the NRC and the ,NRC might shut 10 the B&W plants down?
i e
11 MS. WAGNER: Objection.
12 A That is not true.
(,)
- 13
-: M R . SELTZER: I have no fudther ques tions.
14 MS. WAGNER: We will take a two-minute j 15 break.
~
i 16 (Recess taken.)
17 MS. WAGNER: We have no f u rthe r que s tions .--- -
l 18 (Time noted: 5:30 p.m.)
~
19 -
LUCIUS ROSCOE CARTIN 20 21 Subscribed and sworn to
- 22 before me this day 23 of , 1982.
G 24 L) 25 l
e 1
213
/)
V- 2 CERTIFICATE ,
i STATE OF NEW YORK )
- 3 .
- ss.: i COUNTY OF NEW YORK ) !
4 I' I, NANCY A. RUDOLPH
_ , a Notary
(,
6 Public of the State of New York, do hereby certify that the continued deposition of LUCIUS ROSCOE CARTIN Was taken before me on April 14, 1982 consisting of pages 114 through 213 ;
I further certify that the witness had been previously sworn and that the within transcript is a true record of said testimony; That I am not connected by blood or marriage with any of the said parties nor interested directly or indirectly'in the matter in controversy, nor an I in the employ of any of the counsel. -
18 IN' WITNESS WHEREOF, I have hereunto set my.
20 hand this c2 Y ay of #M y
, 1982.
,AS 21 j
L 22 20 + =^ %
NANCY 0
RUDOLPH
~
[
q o .y :I
- i i
e 25
)
. 214 i I
l IN DE X WITNESS PAGE
> q. . .
) ' s Lucius Roscoe Cartin 116 1
)
1
';,y; Di*tf6 , \;- & [,
GPU FOR IDENT.
82-A Clear copy of GPU Exhibit No. 82 178 122-A Copy of GPU Exhibit 122 tak'en 199 from Mr. Car' tin's files 495 Three-page document entitled 145
" Supplemental Information for Figure 15E.6.2" .
496 Memo from Newton o Womack,"subjecti 182
" Operating Instructions for Stuck Open PORV" dated April 8, 1979, 12:57 a.m.
497 Letter to The Babcock & Wilcox 200 Company from United States Nuclear Regulatory Commission.
dated April 10, 1980 ,.
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