ML20072J159
| ML20072J159 | |
| Person / Time | |
|---|---|
| Site: | Three Mile Island  |
| Issue date: | 01/05/1982 |
| From: | Keaten R, Keaten R GENERAL PUBLIC UTILITIES CORP. |
| To: | |
| References | |
| TASK-*, TASK-01, TASK-1, TASK-10, TASK-GB NUDOCS 8306290974 | |
| Download: ML20072J159 (116) | |
Text
- - _ _ _ _ - _
1 92 pk UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK V
_ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _x GENERAL PUBLIC UTILITIES CORPORATION, :
)
JERSEY CENTRAL POWER & LIGHT COMPANY, 1 METROPOLITAN EDISON COMPANY and S PENNSYLVANIA ELECTRIC COMPANY, Plaintiffs, 80 CIV. 1683
- (R.O.)
-against-THE BABCOCK & WILCOX COMPANY and J. RAY McDERMCTT & CO., INC., i Defendants. :
_ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _x Continued deposition of General Public Ch )
t Utilities Corporation by ROBERT W. KEATEN, taken I
by Defendants, pursuant to adjournment, at the offices of Davis Polk & Wardwell, Esqs., One Chase Manhattan Plaza, New York, New York, on Tuesday, January 5, 1982 at 9:45 o' clock in the forenoon, I before Joseph R. Danyo, a Shorthand Reporter and Notary Public within and for the State of New York.
9
(
L O
B306290974 020105 DOYLE REPORTING. INC PDR ADOCK 05000289 CERTiriEo sTENOTYPE REPORTER T PDR 369 LgxiNoycN AvgNut WALTER SH APIRO, C.S.R. N gw Yo se x. N.Y. 1C017 CHARLES SH APIRO C.S.R. Tgt.g pN o N r 212 - 867 822o
1 93 2 Appearance s: '
32 ,*
4 {!'i KAYE, SCHOLER, FIERMAN, HAYS & HANDLER, ESQS.
Attorneys for Plaintiff h 5 425 Park Avenuo New Yorkp New York I
6 BY: STEVEN GLASSMAN, ESQ.,
7 of Counsel 8
9 1 DAVIS POLK & WARDWELL, ESQS.
10 Attorneys for Defendants one Chase Manhattan Plaza ,
{
12 BY: ROBERT F. WISE, ESQ., )
13 of Counsel
' i 14 '
li d
}3 Also Presents b
Iti i- NINA RUFFINI I.
17 ,
i ,
i 16 h -oOo-
!i n
}9 I' 20 i
4 22 a It i.
23 ,
l 21 i
.3, .
p'
. . , . .. _ _ --- ~ . - .
l 1 94-i
[ 2 .! RO B E RT W. KEATE N, having
\ \
3 been previously duly sworn, resumed and was 4 . examined and testified further as follows:
ii ,
f 5 EXAMINATION (continued) l i
6 BY MR. WISE:
7 Q You recognize you are still under oath 8 today?
! {
9 i A Yes, I do. I i
l I
i 10 Q I would like to show you what has 1
l' t
i 11 previously been marked in this lawsuit as B&W Exhibit 12 l 186, which is a copy of what purports to be a 13 technical data report prepared by GPU Service, titled 14 TMI-2 Transient on April 23, 1978 Task Force Report.
15 [, Do you recognize B&W 1867 16 A Yes, I do.
17 l Q Is that the task force report that you 18 l; participated in the preparation of concerning the April I
19 $ 23, 1978 TMI-2 transient?
t, 20 1 A Yes, it is.
I 21 Q Would you look at attachment 1 to the '
II>
22 ! report, which appears at the page which has been -
23 !! stapled for purposes of this litigation in the lower 2! ; right-hand corner 12470585. Attachment 1 appears to be' 25 a memorandum to you dated May 2, 1978 from Mr. R. C.
[
t.
n i x i i
- s 1 K00 ton 95 t
, ;' 3 Arnold. The subject is listed as TMI-2 Cooldown 3 Transient of April 23, 1978.
!i 4l Do you recognize this memorandum?
N h 5
'! A Yes, I do.
l 6 Q What is it? ,
7 A It is the memorandum from Mr. Arnold which 8 documented the formation of the task force and which :
I t
9 gives some specific direction to the task force.
! 10 Q Yesterday we discussed some of the things l l !
, 11 l that your task force did in order to carry out the i 12 assignment. When did the task force begin preparation of the written report which we see before us as Exhibit O
13 i
14 186 in its final form? I i'
i 15 A To the best of my' recollection, some of the f i I -
t 16 l' material that appears on the final report was prepared 1; very early in the investigat' ion, within the first week, h
18 9 and the memorandum which is attachment 1 refers to a il 1p preliminary oral repory to.be presented at a meeting
- \ -
20 ' on Monday, May 8, 1978. That is-the meeting that I i I 31 was re ferring' to yesterday. ',
lll 33 f To the best of my recollection, right i
i' 23 after that meeting, I started pulling together the l 2; l information for the ' report. and ' then that centinued for
("% l
(_) 23 quite some time thereafter. 'S '
i ,
- f
- g l
. j l
r - - - +
7 y
1 ! K3cton 96 (m') 2 ;. Q Did you actually do the vriting of the '
l w./ q . ., 1
- . _s !
3 q report? -
': ft' 4 l! A Not c o:s p l e t e ly , no. /I reccived written
/ ;,
h 5 !
l material from others that I incorpc :catEN.' j
.,j,,
1 / 17
'/
./
1 Were you in', , e f fe ct ,, d'f
- pou Vill, th_c-editor
~
6 Q
? - r, t 7 of the report, taking pieces that ot!ers bad stibmOtte1 [
3 8 plus materials that you prepared yourselLf in order ;.
v.'
t r j 9 ;l to put together thd entire report? ,
.< / '.
10 i Q I think that is a' fair characte.rizatioy,, +' j,
^} '
I-11 ll yeS-
, e'/
12 ilt.
Q I note.'from the cover,page a date next tc ..
.M
("N 13 your signature which appears to be' August-10, 137G. ,
I ! ,
Q ,) ' ' ' ' i 1
14 ll am sorry the Xeroxing is rather poor. It is not l'
15 j ', entirely clear. It might be August 18. ,
h; ,
16 ll In any event, was i t' sorle time during the. '
v 17
[
pe riod August 10 to August 20, when , to the best of j,
[ <, . .
18 I your recollection, this report was put int o final form? ' f i; / , -
g- / /
r /
19 A don't specifically r,:c al L-t 6e ' da te , but
(,I ,
'I 29 ?l I have no reason' to challenge the dates tA rgt are here. ,
21 4 Q Ir:? a di a':e ly to the right of yobr signature i 1 , ,
j -
l 22 is another signature.which is rather difficult to make
? ') ~
23 I
out. Do you recogU'ze.that? j ;f ,
' I ' /* ,.
+
1 f
'l e ,n.
et Y ,e s , l'do.
2; ! A j .
,/ . ;
(3, i
's' 2Ti : Q' Is that Mr. ik . F . W .4,l s o n ' s signature?
I . /, < l
.,,,r.',
.1 , , i e
- ' l '
~ .,
f %,
y f
t g'-~--
'f (,
1 / Komton 97 u
.,, / / l':
I j'
~"'
3 f, / 1 A $ $e s ,' it is. I
, % }a ,, f fr*
- n ':) ;;',/ h ,'_; s f'
'Q There is on the cover sheet a distribution p- - 3 .// ,, -
-j j Y . y n gj . t
.; ) list and with a lengthy series of names. To the left
. ,._y 7: \' A ,. ,
su eM Q -
\
i a 3
. f o- U the names is a column which contains asterisks next :
9' < =., q 't' *
/ ,3 f to some of the names but not others. What is the
,. .J. . / f. i.;
y; d', significance, if you know, of an asterisk or in some
'. < ,. \
3.
A . =
8
.m
'f'p cases or in all cases two asterisks, next to the
.4
~/h Yq I . names of the people on the distribution chart?
) fc 1 l
s
's , ~ JE ,
,, Ip l
,.i
- /~ MR. GLASSMAN: The significance on this ,'
, *f particular; document?
713 h .
rA >\ '
l ,1
- 1
- , =^ 13 l MR.~' WISE
- Yes.
. / ,,".
,i . . V
. ' i
. ll :
.' .I i3 " l A I note that at the bottom of the page
\ !
14 lls underneath that column there first appears the term '
C, 15 !'! " Cover i page only," and although it does not show in u
s
- w [f - this,. reproduction , I believe that in the actual form J 8'
<- 17 h, used that that had a single asterisk in front of it.
~
/ l 'e
, 18 I note then underneath that there is the notation
<, / -: 8
- 19 ] /"Without appendices," and I don't believe that is a
./.J / r-20 7
.2 n'ormal part of this form.
.c t<
i ti,I *s . , J , .
~
[g h** To the best of my recollection, the people
(- :.,
6- j ll
- v 3.j I: who have double asterisks by their name received the
., 6a %.e- ,
, ,i,
.~i
- O. -
23 ' , , report without the appendices, t
c
- r. ,
t -
p-~p; a ; ; , Q What was the reason for that, if you know?
i.
23 ,
A Simply to hold down the amount of paper b
, t t
- afdj; s -
k l
< f,
- s V
I . - _, - --
1 1 Konton 98 2 which had to be reproduced and distributed.
4
. h(~N i 3 Q Perhaps my question wasn't clear. Why were 4 certain people on this list given the appendices and jgg 5 others not? What was the distinguishing factor as to 6 who fell into which group?
! 7 MR. GLASSMAN: If you know.
8 A To the best of my recollection, I tried to t
9 send the appendices only to people that I thought might 10 actually use them.
11 Q Were you the one who made the selection as 12 to which people would receive the appendix and which 13 ones would not?
~
14 A I don't remember.
i
- 15 Q Do you recall whether anybody made any i
+
16 response to you or further comments after distribution 17 of this final report concerning its subject matter?
4 18 A I don't recall one way or another except, 19 as I mentioned yesterday, that work in analyzing the 20 transient with the RETRAN code which.is alluded to in !
! 21 this report continued on past that period of time.
22 Q Do you have any recollection of anyone ,
i 23 disagreeing with any of the findings or conclusions in 21 tae report after the report was distributed? I am just
( l ls/ 25 l trying to determine whether this is the last word or
1-j 1 Konton 99 i i I'
2.
( whether there is something else we ought to be looking 3 .l at.
1 i 4 A I don't recall any disagreements with the I 5 findings in the report as they were issued.
j 6 Q Do you know of any further report on this
. 7 incident, written report, done after the distribution
{ 8 of B&W 186, and 1 will exclude for a moment the RETRAN 1
i 9 analysis TDR, which we'll come to later.
) 10 A With the exception of that report, I do not
{ 11 recall-any other reports issued later on this transient.
12 Q I would like to ask you a few questions 13 about the-transient itself just to make sure I 14 understand it.
f
]
j 15 Before we do that, let me ask you to look
! 16 at what is marked as page 2 of the report. It is i
! 17 actually the-fourth piece of paper in the document. It l 18 is listed as Table 1 and contains a list of the task-1 j 19 force members and certain additional participants.
4 i 20 ,
Is that, to.the best of your recollection, j I-21 an accurate reflection of the-task force members and 22 those who also participated?
l 23 ! A At.this point in time, I. frankly don't v-l-
24 recall.the roles that some of the people here played,
25 !
but again I have no reason to challenge the accuracy
,n , - - ,--e re -, ,s. - + , + , , e - - - - + , - - - ~ n--g , w ,o -m -- e e-
1 Kocton
- 100 2
( of the list.
3 Q Am I correct that of the task force 4 members, Mr. Seelinger and Mr. Toole were employees of lh 5 Met Ed and that the other four members, including 6 yourself, were employees of GPU Service?
7 A No, I do not believe that was correct. I 8 believe that Mr. Toole at that time was an employee of 9 the Service company.
10 Q Was Mr. Seelinger the only member then of 11 the task force who was an employee of Met Ed?
12 A To the best of my recollection and 13 knowiedge, that's correct.
14 Q Among the additional participants, Mr.
15 Lanese, Mr. Lentz, Mr. Moore, and Mr. Schmauss, were 16 there any Met Ed employees?
j 17 A To the best of my knowledge, no.
- 18. Perhaps I should clarify why that was true.
19 As I mentioned yesterday, there was a plant effort at i.
20 analyzing the transient which I believe consisted 21 primarily of Met Ed employees, and Mr. Seelinger served 22 as the go-between for this effort, which was primarily i
, t 23 the Service Company effort and the Met Ed effort. '
21 Q In. fact, I believe it is attachment 2 to
! .25 your task force report which begins at page 1247-0586 1 s.
i l l
i 4
1 Konton 101 4
i 3
-m 2 as marked in the lower right-hand corner for purposes
{}
, 3 of this litigation. It is a copy of the Met Ed report 4 on the incident, is it not?
A Yes.
llh 5 6 Q That is marked in the upper right-hand 1 7 corner page A2-3 through page --
it is difficult to 8 read, but I believe it goes to page A2-87, and then 9 there are an additional three pages which probably 10 are 88, 89, and 90, but it is almost i llegible on the j
2 11 copies I have. It may be also A2-91.
12 A I agree that it is illegible.
i 13 Q You see that the next page following that, 14 which is marked as 1247 0676 for purposes of this 15 litigation, starts attachment 3, which has been i 16 renumbered by someone in the upper right-hand corner i 17 TDR-001, which corresponds to the number of your task 18 force report, and underneath that page A3-1?
, 19 A That's correct.
I J
20 l Q Would I be correct that you adopted, you ;
21 or whoever typed this, adopted the convention of I 9 22 renumbering the attachments or appendices to your :
i i
! i 23 ; report, placing the prefix A followed by the attachment 24 number followed by a dash for the page number of the i
\~' 25 [ particular memo or report or whatever it was?
l l
-- w ,
1 Kcaton 102 l
n l, A I don't specifically recall that, but it
) -
a i
w uld appear to be correct.
3 4
Q Going back to where I was a moment ago, llh 5 which is the transient itself, if you would look at page 14 of your report --
do you have that? !
6
- A Yes.
i 8 Q Feel free to refer to anything in the l 9[ pretrip sequence which is on page 6, but I think most l 4
e .
10 of my questions will be directed at the events as they l 1
~
il 11 l! occurred during the accident. i i
12 i At the left-hand margin of this sequence lt -
i 13 of events, there are what appear to be a series of g4 times beginning with time zero and proceeding through 15 the events in the accident.
16 [ Who prepared the sequence of events that 1
1- appears here?
f !
16 .i! A I frankly do not remember.
19 !: Q Did you participate in the preparation of 20 it?
og A I don't have any recollection of Ibi k, 33 ri participating in it.
i 2:r ; Q You did review it, however, before it went 1
y ! into the final report, I take it?
I 25 l A Yes.
i y =q - -r=9; y &
1 Konten 103 I
() 2 Q And you are familiar with it generally?
A I was at the time the report was prepared.
3 I,f 4 Q Could you explain the initiating event l
h 5 which is listed as reactor trip due to NI 8 noise spike?
6 MR. GLASSMAN: Objection as to form.
i 7 MR. WISE: If you have an objection to i
" initiating event," I will strike that part of '
8 4
9 my question. I simply want to know what 10 started the accident without a review of all of l 11 the conditions of the plant.
12 MR. GLASSMAN: My objection is also based on the fact that Mr. Keaten said he did not
( 13 14 recall participating in the preparation of the I sequence of events; although there is some 15 16 ll material that appears at the top of this page, t
17 l I assume your question is directed to his 18 l recollection, not to his present review or 19 h assumptions regarding the page in front of him I.
go which he doesn't recall.
1 1
21 l MR. WISE: I think all I am looking for is l l
22 l his recollection. If this sequence of events 23 helps to refresh his recollection, that is fine.
~
y If it doesn't, and he isn't able to say at this-(~h
\- point what started the event, we'll~go on to the 23 L
I e
l l
_1' ,
Koston 104 t
i 2 next question.
3 MR. GLASSMAN: Very well.
i 4 ! A You have more than once referred to this 5 event as an accide..t, and we have not to my knowledge hl ,
6 used that terminology in that it did not result in any ,
i 7 . damage to the core or other major impact on the plant, t i 8 so we have referred to it as a transient rather than 9 an accident.
I 10 To the best of my memory, the sequence i
11 ,
was initiated by the reactor trip referred to here at l
12 time zero which was caused by we believe a noise spike 13 in the nuclear instrumentation, and NI stands for g4 nuclear instrumentation.
15 Q Was it ever determined by your task force l
i 16 l what had caused the noise spike in the nuclear l
1; j instrumentation?
ll A
18
( I don't believe that we ever determined 19 exactly what caused it. My memory is, and it is l
i go consistent with what that report says, there had been og
~ { previous problems with noise in that particular channel.
Ibi 33 Q The second event listed on the sequence is 1
23 a turbine generator trip. I take it that is expected
- .; ; to occur following a reactor trip?
33 A That's correct.
I,.
n.
e- .-- y - -
=,
1 Konton 105 3 Q The next event is a pressure spike in the B 3
steam generator. What was that caused by?
l 4 MR. GLASSMAN: Objection as to form. The same objection as before. The question here is lh 5 1
6 making assumptions based on a sequence of events l
7 which the witness did not participate in. I thinkl l
3 you would do better if you went along and asked 9 the witness his recollection of things without 2
i 10 assuming all the way down that the particular i
11 list is or is not correct.
12 MR. WISE: I was only using the list 13 because I thought it might help. If you want to 14 do this without the list, that is fine, but Mr.
13 Keaten was the chairman of this task force and i
16 has testified that he either wrote what is in it 17 ; or else acted as editor with respect to what 18 i others wrote to put into it, and I think it is l
19 f_ perfectly fair to set as a foundation for 8
20 questions to come to get his knowledge and review 31 the sequence of events.
33 I am only using this because it is in his !
23 report, and I thought it would be helpful.
I j MR. GLASSMAN: I have no problem with the 34 A
(_) 33 general approach, but the form of the question i
1 Koston 106 i i
4 2 was objectionable insofar as it seemed to be based solely on the particular page in front of 3h 0
i ;
him.
4 BY MR. WISE:
llh 5 .
6 Q You are free if you wish to mention any 1
other events or considerations that you now recall that ,
1 8 are not reflected here on this sequence of events.
1 :
9 MR. GLASSMAN: Objection. The statement 1
l
) 10 or question, and I can't tell which, of counsel ,
i l
~i
- 11 l seems to assume that Mr. Keaten has already
- 1
, 12 confirmed each and every sequence of events i 13 item listed here. ,
i 14 MR. WISE: Maybe we ought to clear that up.
I 13 ! Q Before you signed this report on the cover 1
16 l page, did you read pages 14, 15 and 16?
I !
1- A I believe that I did.
Did you note any objection to the material 18 Q J g i
19 that appears there?
5 l
.0 l.' A I don't recall.that I had any objection,
[
21 j but I did not in reviewing material like this that, to lhI .l 22 the best of my memory, was prepared by someone else
[
23 necessarily go through and confirm in my own mind that i
2g l it was accurate in every stage. I am perfectly willing
[)
\~' 25 I to rely on_other members of the task force for their t
.b \
k l I
i l 1 Kaaten 107 i
6
/
individual expertise.
J (v) 2 i
4 3 Q In writing this report and chairing the i
.; task force, did you become familiar with the sequence I
h 5 I
of events that had occurred during the events?
6 'A I became generally familiar with it, yes.
] 7 Q Going back to where we were before this ;
i i 8 discussion, following the turbine generator trip, what i
i 9 in your recollection is the next major event that j 10 occurred during this transient?
4 11 !
A I recall that one or more of the steam i
i I
- 12 safety valves were believed to have lifted.
13 Q Are those located on the secondary side i 1.t of the system?
1 !
j- 15 : A Yes, they are.
I l
- Iti j -Q What is the consequence of their lifting?
I 1; l A It releases steam to the atmosphere and 4 ,;
l 18 generally tends to reduce the pressure on the t
lll i 19 secondary side of the steam generators.
20 ( Q Would that have any effect on the parameters 21 i seen in the primary system?
l 9 oo i'
A Yes.
23 Q What effect would it have?
)
'; e MR. G L.T S S M A N : I am not sure whether the
. 'Y 25 question is directed to Mr. Keaten's current l,
i: .
1 Keaten 108 n knowledge or analysis back then. Obviously this 3
(} i 3
1s not of great weight at this point in the l
i 4 l examination, but I think the questions ought to be clear so we know whether we're'asking for Mr.
llh 5 i 6 Keaten's current knowledge or what. f 7 MR. WISE: I think all of these questions 8 concern Mr. Keaten's work as chairman of the task 9 force, investigating the event on April 23, 1978, 10 and are directed to his recollection of what the i
11 various events that occurred at that time were 12 and what effects they had on the system 13 generally, f~d) u ;
14 i A In terms of the analysis that was done by i
l 15
' the task force at the time, my recollection is that 16 I there was general agreement that lifting the steam l
17 -j safety valves on the secondary side of the plant and 18 j the consequent steam flow out these valves tends to or i
19 b tended to cool the primary side water in the steam
, l bl 20 - generator and thus to reduce the temperature in the f
21 l cold leg of the primary side.
22 Q Why does the release of pressure in the
, 23 ,
secondary _ side result in a cooldown as you described it I
2; l in the cold leg of the primary side?
. x
<G ' 2.5 MR. GLASSMAN: 'Why did it?
l
'l 1 Koaten 109
-f -2 Q Why did it if the tense helps?
3 MR. GLASSMAN: ~I.like to keep the question t- !
..4 clear-for the record. ,
jlh SL A- When the safety valves lifted, the. net 6 result was an increased steam flow out of the steam i i 7 generators. That steam is generated by removing energy .;
i 8 from the primary side, so the increased steam flow means
, i 9 a greater energy removal from the primary. side and thus 10 a' cooling of the primary.
11 Q What effect, i f ' any , did the cooling of the-4 12 l primary side that you have described have on pressure 13 in the primary side?
14 A As I believe we mentioned yesterday, the 15 cooling of the primary coolant inventory causes the 4
16 water to shrink, and the immediate effect of this is to i
a j 17 reduce the water inventory in the pressurizer, and that 18 in turn tends to immediately reduce the p re s sure of the
! 19 l primary side.
20 l
-Q During the event on April 23, 1978, did I.
i 21 primary side pressure decrease?
I 22 A My recollection is that it did decrease.
I i l
23 Q What at that time was the normal operating.
t 2; ! primary system pressure, approximately? l l
O 25 i
A It was approximately slightly above 2100
._ _ , _ _ _ _ . .2 ~.- ____ _. . -- - - - - - . - - - - -- - -
1 Konten 110 i
[ 2 pounde per square inch. i 3 l Q To what level did the primary system 4,
I pressure decrease during the event, approximately?
l 5 ,
A I don't recall exactly.
l i 6 Q I think there are some charts which may be !
i 7 helpful. If you would look two pages in front of the 8 sequence of events, there is a chart which is labeled ;
9 " Figure 4" on a piece of paper that bears the legend ,
t 10 " Burns & Roe, Inc." The chart has written in i
11 handwriting " Primary pressure" and appears to show some
. I 12 values for pressure against time. Do you see that?
13 A Yes, I do. I i
14 l Q The chart shows a pressure at time zero I
}
15 l of approximately, as best I can read it, 2200 some-odd 16 l pounds per square inch. It might be 2100. The 17 ! Xeroxing is very poor. A general downward s1cpe on the 18 chart getting down to levels in the 700 pound-per-19 : square-inch area.
20 MR. GLASSMAN: Is there a question?
I
! Q No. 1, do you recognize this chart?
21 O
22 A I frankly don't remember it very well.
l 23 Q Does seeing it now in any way refresh your 23 recollection concerning the amount of the decrease in h %'
i 25 . l primary system pressure that occurred during the-
~
l i.
1 I
l
1 Koston 111 2 April 23 incident? There may be other charts in the 3
report that may be more helpful. -
]
4 MR. GLASSMAN: The chart speaks for itself.
Just so you understand, the question is llh 5 6 whether the chart refreshes your recollection.
7 A My recollection is that.there was a very !
8 substantial decrease in the primary system pressure.
9 I don't specifically remember the lower number as ,
10 indicated in the graph.
11 Q Do you recall that primary system pressure 12 decreased to a level at which the emergency O
ud 13 safeguard system was actuated?
14 A Yes, I do.
15 j, Q That emergency safeguard system was high-ll 16 l pressure injection, is that correct?
i 17 A High-pressure injection is a part of the l
18 emergency safeguard system, and HPI was initiated, yes.
l I
19 Q Do .you remembe r how far into the incident 1
20 high-pressure injection actuated?
t li 21 l Let me refer you to the sequence of events, Ibi j 22 I; if it helps refresh your recollection. At 23 [ approximately one minute and eleven seconds, as 2; l indicated on page 15 of the report, safety injection in i'
{
\/ 25 l the A & B loops was initiated.
L !
t
1 KGaton 112 MR. GLASSMAN:
( 2 According to pag e 15?
MR. WISE: Yes. The notation remis 3 Il I
4 i
"Safet. injection A/B. RC pressure 1630 PSIG.
Operator checks that he has normal actuation."
llh 5 6 MR. GLASSMAN: Is the question --
7 MR. WISE: Does that help refresh his l 8 recollection as to how far into the accident it .
1 9 was that high-pressure injection came on?
10 , A I don't specifically recollect the exact 1.
I 11 numbers, but I do remember it happened quite soon after l
12 the transient start.
(~)
\/
13 ! Q_ Did your task force make any investigation l
14 l Of operator action concerning HPI during the incident?
l' 15 A I don't recall any such investigation.
16 Q There is a notation a little bit further 17 down in the sequence of events indicating that at one 18 I'll minute and 17 seconds, safety injection was bypassed.
19 ,! First, let me ask you, are you able to "O interpret for us what is meant by the notation that I i l-21 have just pointed to?
9 22 MR. GLASSMAN: I object to the form, to the 2,3 use of the word " interpret." The document speaks l
I
~y for itself.
l /~}-
l
(_/ '5 A I am having great difficulty in terms of i
l 1 Konten 113 2 distinguishing exactly what I knew at the time that 3
! this report went ort, versus what I know now, but I I
h, believe it is correct that I knew what that meant at 4
that time. My understanding of that term as it is h 5 6 used here is a ste p that is taken by the operators when the reactor experiences an automatic actuation of the !
7 8 high-pressure injection fluid. The operator may then g bypass the signal which automatically actuated 10 high-pressure injection. This has in itself no l
11 effect on high-pressure injection flow, but simply {
12 gives the operator the ability then to control that 13 flow rate to the extent that he feels that he should 14 .
control it. '
! Was any investigation made as to why the 15 Q d i 16 operators took that action during this incident?
17 !
A I don't recall any such investigation.
4 18 1 Q Do you recall whether the operators allowed 19 high-pressure injection flow to continue into the 20 [ system f o '.lowi n g their bypass of the automated, if you c
21 Il will, aspect of high-pressure injection? If it is of f
22 l any help, let me refer you to the Met Ed sequence of i
23 ! events as contained in attachment 2 to your report. ;
f I 23 { It appears at page 1247 0592 as marked for purposes of l i
((']
25 i this litigation. It is page A2-9 of your report.
1 Koston 114 I l
! )
\/ )
2 -
If you have that before you and look down 11 3 y the page to the time marked one minute and 40 seconds, 4 there is a notation of HPI flows in the four trains.
I 5 A My recollection ~is that high-pressure 6 injection flow was maintained by the operator at a 7 significant level well past the time indicated here 8 for bypassing the actuation circuit. .
l 9 Q Did your task force question the operators 10 as to why they had done that?
. .I 11 A Why they had done what? [
l 12 Q Left high-pressure injection flow running.
13 A I don't remember any such question. ;
14 Q Did you while you were preparing your 15 report have any question in your mind concerning the 16 operation of the high-pressure injection system and i
i 17 l its control by the operators during the event?
1 18 . A To the best of my recollection, the task f
i IU force did consider the general question of whether the 20 operators had responded.in what appeared to be an 21 appropriate fashion to the transient which occurred, 22 : and my recollection is that the task force concluded 23 that the operators generally had acted correctly.
23 ; Q Do you have any recollection as to whether
~) i 25 the task force specifically considered their actions 4
e , , -
4
-1 Kosten 115 with respect to high-pressure injection as part of
[) 2 l
3 .
its review of operator action?
9 4 A I do not specifically recollect.
5 Q Do you recall whether anyone brought to 6 your attention any practice or procedure generally 7 among the operators to terminate HPI flow during an 8 event as a matter of standard practice? Did anything 9 of that nature ever come to your attention while you 10 were working on this report?
11 MR. GLASSMAN: During what kind of an event? ,
12 During any event?
13 MR. WISE: During any event where it had
}4 been actuated.
15 ll A I have no recollection of that type of 16 I
discussion.
I, Q If I understand your testimony correctly, 17 l
18 l you cannot recall any examination of the reasons why 19 I the operators left HPI running during this event. .
20 ;! A I can only repeat what I said earlier, that 3
og I do recall that we considered the question of whether Ill 22 the operators had generally acted in a fashion that the i
23 task force thought was appropriate and that the y~ .
conclusion was that, yes,-they had, but I do not recall
(~S [
k~/ 25 I the details.
i $
l'
- - = ,
l l~ ;
1 Kosten 116 I
( p Q Did the task force interview any of the perators?
3 h
A As I mentioned yesterday, I believe the 4 ]
h 5 first principal activity on the part of the task force
, 6 was to attend a meeting at Three Mile Island with 7 some of the plant personnel for the purposes of f
, i g discussing the transient. I frankly don't remember
- i 9 whether any of the operators involved were at that I
10 'I meeting or not.
i 11 Q Do you know whether any members of the task '
12 force ever interviewed the operators in connection
() 13 with this report? '
11 A I don't recall any such interviews.
15 j Q Who on the task force was responsible for bl 16 ] evaluating the correctness or appropriateness, if that 17 i is the better word, of operator action during the event?
I 18 I; A I don't remember.
19 ! Q Was that considered by you as chairman of t',
i 20 : .
the task force to be an important as sect of the task I
og
~
you had been assigned?
h l
22 A I note that the second item in Mr. Arnold's 23 i memo which formally established this task force is i
y i "A review of the automatic response of the plant and 1
' l.
l 25 i l-the manual actions taken by the operator, the I
!I !
Y l c -ji I L .. -
l
1 Keaton 117 I i i
/")
\_/
2 consistency of both automatic and manual response with l
3 the design philosophy for the unit..."
l 4 f As chairman of the task force, therefore, !
llh 5 I certainly would have been interested in responding 6 to this part of the charter of the task force. l 7 MR. GLASSMAN: The witness was reading from l
8 page 1247 0585.
9 Q Are you able to recall any reason today 10 why the operators were not interviewed in connection 11 with preparation of the task force report?
12 MR. GLASSMAN: I don't think the witness 13 said they were not interviewed. He said he 14 ,
didn't recall whether they were interviewed.
I 15 Q Do you know whether you personally 16 interviewed any of the operators?
t 17 A As I indicated earlier, I was present at 18 l4 '
the meeting at Three Mile Island which had various
'l I
19 members of the plant staff present. I don't remember whether some of those were the operatore or not.
20 l-ot l However, let me comment that this task force 22 ,
was able to get very good information from the Met Ed l 23 personnel with respect to what had occurred, and I can 24 ; remember that I felt very comfortable with the amount gx i 25 of information that we had received.
p I
l
l 1 KGoton 118 1
3 2l Q That would be information that was coming J 6 3 through Mr. Seelinger?
4 . A He was the formal participant in the task l'
force from the TMI staff, but I do not believe that llh 5 t
6 our contacts with the Metropolitan Edison personnel 7 were limited to Mr. Seelinger.
t 8l Q All I am trying to do now is to find out
} f l 9 , where you got your information about operator actions.
I
'9 As I understand your testimony, you don't recall 10 l 11 interviewing the operators. Do you have any 12 information which you can give us here today as to
("}
V 13 whers, if anywhere, the task force was obtaining its 14 ,,
information concerning operator actions during the lI 15 event?
, b A To the best of my recollection, our sources 10 ['i
)
17 il!
l were as follows: first, there was the initial meeting li 18 at Three Mile Island in which we discussed the sequence
. 19 ! of events in detail. Second, there was the plant staff 20 report on the transient, and my memory is that we i 1 21 i received an early version of that basically about the 4
22 start of our investigation.
1 23 Third, we had direct access to some of the l .
23 i data printouts, strip chart recorders, computer
'- l i printouts, et cetera, and my memory is that some 25 I
, j:'
e
1 Konton 119 i
members of the task force took a fairly careful look
( 3 f at the data printouts and that where there were 3 dn 4] questions about what happened, whether it be the l
lll 5 operator response or anything else, that the people t
6 involved would have called someone appropriate at TMI [
I 7 and discussed that with them, and that might have been 8 Jim Seelinger and it might have been someone else. ;
9 That is all I recall about it.
10 Q Let's stop for a minute at.this point and 11 talk about the data available concerning what went on 12 during the event. What data sources were there? For 13 instance, the term "reactimeter" has come up several
{/)
w 14 times.
l 15 l Perhaps you could begin by explaining what i
16 a reactimeter was and generally what it showed.
1
[7 MR. GLASSMAN: The question is directed to 18 what data sources were available that were i
19 ; reviewed in the course of this task force work i.
20 or what data sources wers available in some li 21 i general source? I assume we're trying to focus k 1 22 ! in on the questions.
23 MR. WISE: Yes, let's start with the data i
, 2; [ sources that were available and that were used-in '
T !
(~J
\"
25 I
the investigation, and then I will ask the l
i i
I l
. i.
1 Konton 120 )
1
( 2 ,
question as to whether the task force ignored 1 0
[ 3 other data sources that were available to it. I ii 4 'l guess I am assuming you looked at what data i
lh 5 sources that were available, but as your counsel '
t 6 points out, that may be a false assumption, so
, 7 we'll square the corners and do it the hard way.
g l BY MR. WISE:
f 9 Q What data sources did you look at? And I
' thought I began by suggesting the reactimeter.
10 There 11 may be others.
- - 12 A I did not personally look at all of the 13 data that was used by others in considering the i
14 j transient, so my recollection is not necessarily i
15 f adequate to give you a complete list of the data that l
16 l was considered. The reactimeter is a data logger t
, 17 provided by B&W which, according to my understanding,
)
4
!l!
18 f was intended primarily for use during the startup 19 l testing of a nuclear plant. It automatically records f 20 preselected signals and maintains a record of these.
I o
~t l My recollection is that the data from the I
22 reactimeter was one of the things considered in L
23 L locking at this transient.
y Q Does the reactimeter show .information on 25 strip charts?
ld
1 Keaton 121 I
i 3 A No, generally I believe the reactimeter I,
3 :,
printout is a digital printout.
I' 4 Q What other sources of information were l 5 available to the task force, as best you recall?
6 A There were the summary sheets from.the plant 7 computer which give a time phase record of changes of ,
i 8 state of signals that are monitored by the computer.
i 9 There were the analog strip chart records of those 10 signals which are monitored on analog recorders. And 11 our task force also used the plots which had been 12 prepared by the plant staff based on the same types of 13 data sources.
14 Q Do you have any recollection as to whether i
15 i the plant computer data available for the transient on 16 l April 23, 1978 was complete?
17 l A I don't remember.
d 18 i Q Do you have any recollection as to whether i,
19 anyone ever brought to your attention any problem with I,
h respect to the plant computer and the availability of 20 I
og l
- information it was supposed to show during the dBi 33 gl transient?
j; I A I don't remember.
I 3; f Q Did it come to your attention that there I
's 23 i had been complaints concerning the slowness of the I
b h
l'
w ..;
s I K3cton 122 q 2 plant computer during the event?
n x 3i A I don't recall any such complaints.
4 Q Would you take a look at page A2-14 of your 5 report, which is part of the Met Ed report that appears'3, i
6 at page 1247 0597 as marked for this litigation. Look
particular line?
! 1 15 l MR. WISE: Yes, and seeing~this notation.
16 l A Frankly, I dors ' t : re membe r.
17
] i q Q Item 10 is noted, "The timd lag in selected h '
s 18 parameters such as fluctuation in the c'omput(r 3 \
19 l memory trip review must be resolved." '
f
- Y- - n 20 ' Do you remember that item as something %
- s 21
~\
that came to the attention of your task force? QN G l i
- 4
\'
22- A I don't remember iti g no.
i
'T 1 l 23 Do you have any information~ as to whether Q
r ,)
23 either of these two items mentioned iiMthe Met Ed s l i ~(
,- a, l report were ever resolved? ~
l l!
i- ,
l:, s.
l '7%-
s
, N-
I cKeaton 123 I
O 2 A I honestly don't know.
.Q n i
i l
3 l Q Do you know wheth.3r any investigation was 4 made by your task force conce'rLing the effect, if any, l'
h 5 of these items on operator performance during the s*~ -
- l 6 incident? ,_ y i
\ ;
7 A I don't re sce mb e r.
L :
8 'Q During the course of your task forc.e review, i'
- s I
9 .. did it come to your atte'ntion that the operators had l , x :
10 been confused'concerning what was happening during the 11 e ve.p t ?
. s-S -y
,, . 12 A Not that I recall.
t '
IDid it
/% 13 Q ever come to your attention that 14 h the cperators had only a marginal understanding" of g '
N' 15 some of what was coing on during,the event?
i 16 j MR. WISE: I am just asking whether that I
( }T i
r came to his attention. It,either did or it ij .. s' i s,4 '
s 18 1 didn't. ,
A i 4 . ,
% '\
19 A I'spn't recall any'such stntement.
3 i
[j - \
n s
. . w>t %
" 3p- Q Would you look a little further down the
.m x
,N 17 (
- i.jt l \ page under the notation " Philosophy," the second item, i '
_ji k3 L . which reads, "We must,stop and regroup-when something ly 22 x' c, i
-\1 s
. . - s
's ,
s, .p 23 is marginally working or ma.rginally understood. Adve r se ia
(.'p i
Q3s l affec:s" --
and I think it should be " effects," -- ::an
._ t
. be addit ive . "'
_ f 23y '
\
L g- u g h- ,s _
d >
4 i, ,Wq t
~<
) ~. '
i
_\
s
_ ..iu _ ._ \. - _ . . . - _ _ .% . __ . . _ -
I , j
~
1 , KCGton /[ j '124
, s ,
~
~'1; o
~ l Does that in s.ky -w ~*
ay, re f re' hs .yc e:r i ,
' / '
b , ',c -
, s 3 h, rec 11ection as to wh, ether it 'was ever prsught to'thr, -
F
.; 1 attention of the task hErce that there had been parts I
\
lll 5 l of the event marginally understood by the c>erators 6' during its course?
l 7 A !!y recollection is admittedly vaguc, but to 8 the best of my recollection, I did not interpret this 9
comment as apolying to the operators and their 10 understanding and actions during tne transient, but 11 rather to apply to an incomplete understanding of the 12 previous transient.
71 13 , Q Do you recall that one of the aspects of t,
) ! *
\/ !
11 l the April 23 event was the so-called slow response 13 of the feedwater valves?
16 A At this date and time, I frankly don't l
17 l, remember that.
16 ll Q Do you recall anything at all from the task h
19 force review which highlighted any problem with 20 ,
operator action?
,1 A When you say problem with operator action,
{
a3 ! you mean an action that was taken or not taken by the 33 li operator that in retrospect the task force felt 3;
l' something else would have been preferable?
/w j: 33 l Q No. What I am driving at and have been with i
l t 1 4
1l
.. .-,, ~ _. .. _
f.
r r I
i Konton 125 l
f
, +
( 2,j' I
this entire line of questions is to try and determine 3 hi to what extent the task force considered operator 1
4 i action as a significant part of this event. You have l
lll S. testified a little bit earlier that in the charge to is 3.; *. 6 your task force from Mr. Arnold, that was mentioned t 4 -
as one of the items that should be looked into, and you
,7 e 8 said that the conclusion was that operator action had i 9
L been appropriate.
10 - I am simply trying to determine whether
'll there was anything that you can recall from the tack 12 ,
force that concentrated on operator action as being a
[ 13 significant factor in this event or did you view it j4 as being entirely an equipment problem?
15 A I don't recall any of the operator actions l
1 16 or inactions that the task force felt had contributed 17 to the severity of the transient. The only operator
'i 18 ; action that I remember giving rise to a task force i
19 l recommendation was that the control room operators at U
20 j! the time of the transient were not sure early in the 1.
og i transient whether the steam safety valves had stuck I open, and since-there was no indication of that in the 22 23 control room, my memory is that we were told that they g; dispatched an operator to go to a location where he 25 ct 4 could see the exhaust from the steam safety valves and i
h .
1 Kooton 126 i
gl
} i thus visually confirm that they were in fact open, and 3 ll the task force felt that the instrumentation available ii;f 4y to the operators should be such that that type of l
lh 5 action should not be necessary, and that led to the 6 recommendation to provide some method of determining .
i 7 from the control room whether the safety valves were -
1 i
8 open or not. I 9 Q Let me refer you to page A2-13 of the Met i
10 i Ed report, which is page 1247 0596 for purposes of b
11 this litigation. That is the first page of the 12 "Conclusionc" section which you will note by looking at
(} 13 the immediately preceding page.
- 14 i MR. GLASSMAN: From the Met Ed report?
I 13 MR. WISE: Yes.
Ig; j Q You will see on that page at the top the 4
17 heading " Operator Action," and eight items are listed d
18 l beneath it.
19 i The first item states, " Operator response l go ,' to reactor trip was prompt and correct with one og l exception. The feedwater pump was not run back until 22 one minute and 20 seconds into the event."
23 Item 2, "While the operators responded
$ correctly to the reactor trip, they did not realize
(~g -ii
'~
33 . the casualty they were really dealing with as a major
l 1 Kocton 127 steam leak (through the relief valves)."
p Do you recall reading those items which are V
3 d" the first two items in the conclusions of the Met Ed 4 I l report at or about the time you were working on the 5l task. force?
6 ;
A Yes, I do have a vague recollection of 7 ,
i having seen that. .
8 Q Did any information come to the attention :
9 of the task force or to your attention indicating 10 that the matters listed in items 1 and 2 of the Met Ed 11 I plant staff conclusions were incorrect?
12 A I don't recall any such.
(~) 13 Did your task force make any investigation
(_/ Q 14 1 as to why the operators had apparently failed to 15 i realize the casualty they were dealing with?
16 l
q MR. GLASSMAN: Objection as to form. It 17 l assumes they did not realize something in this 18 l particular page. I don't think Mr. Keaten 19 ! .~
[, offered testimony to that effect.
20 MR. WISE: I don't understand the objection.
21 !
G j MR. GLASSMAN: I think there was an 22 l assumption in your question which was unfounded.
I 23 MR. WISE: I am reading from the Met Ed 28 l report which Mr. Keaten incorporated in his task
} ..> ,
t
- p. . _ _ _ _ ~ _ - _ _ _ _ _ _ . _ _ _ . . ._. _ _ __ _ _ -
\
l 1 Konton 128 'l I I '
() 2(
l force report. I am asking whether the task 3
f rce did anything, to Mr. Keaten's knowledge, t
4 : with respect to what is reported there.
I 5 MR. GLASSMAN: That is a slightly different 4
. G question. I will let him answer it in the 7 current form. You can look back at the record ,
8 I and perhaps understand the difference. He can L-c
- 9 answer this question.
A I frankly do not recall what we did with 10 l 11 respect to these two items.
12 (Recess taken) i
() 13 BY MR. WISE: .
14 Q Did it ever come to your attention on the i
i 15 ; task force that the operators had complained about the 1
16 number of alarms that they saw during tha April 23, i
i 17 ; 1978 transient?
4 I
18 A I do not remember.
i I 19 Q Do you remember whether the task force ,
- 24) l(l made any investigation with respect to the alarm l
& system at TMI-2?
og
~
i i l 22 }; 'A I don't remember any such investigation.
23 g Did you perform any work with respect to the og alarm system at TMI-2 in connection with the task
~
25 force?
h .
1 Konton 129 ,
( ) 2 A Not that I recall.
3 Q I w uld like to show you what has 4 previously been marked as B&W 264, which is a memorandum h 5 i that has been identified earlier as being written by 6 Ed Frederick, whose name appears at the end, and was
, 7 ,
addressed to Jim Seelinger. It is dated May 3rd, 1978. I
! l 8 Would you look at item 3, which is on the 9 second page, which reads, "The alarm system in the 10 ! control room is so poorly designed that it contributes I
11 little in analysis of a casualty. The other operators 12 and myself have several suggestions on how to improve our alarm system. Perhaps we can discuss them sometime,
( 13 j i
14 l preferably before the system as it is causes severe i
15 problems."
16 ;j Did anyone ever bring to your attention 17 l this comment by Mr. Frederick?
18 i A As part of the investigation of the April t
19 23, 1978 transient?
g d
20 Q Yes.
21 A Not that I recall.
g ,
22 l Q Are you aware that-Mr. Frederick was one of 23 the operators on duty during the April 23, 1978 -
og] transient?
23 MR.- GLASSMAN : Is he now aware of that?
a 2
~
e, .+
~ . ,
.-,.y , w e ,y.. ,_yy- -g pyemy q y w
l 1 Kooton 130 i
2 Q Yes, are you now aware of that?
3 A Not really, no.
r
- Obviously you weren't aware at the time 4 !l! Q the task force report was being prepared, I take it.
llh 5 6 A Not to my knowledge.
7 Q Am I correct that you don't know one way or 8 the other whether anybody ever talked to Mr. Frederick i
l 9 to get his comments as part of the task force review?
10 . A As part of the task force that I was 11 chairman of, I don't remember exactly who in the plant i
12 staff we talked to.
13 Q To your knowledge, did Mr. Seelinger ever t.; bring Mr. Frederick's comment to the attention of the i
15 ( task force, his comment concerning the alarm system?
I 16 , A I have no racollection of that.
I 17 Q Do you recall whether there was any
'l' 18 consideration given by your task force to the role of I
19 i multiple casualties during the April 23, 1978 event?
I 20 ;I A I don't know how to interpret the question.
6 21 1 The task force was considering the events which did.
f occur, and my memory is that there was more than one 33 ;
23 event of interest, so in that sense, we were considering i
2; ,
multiple events, yes.
f' I k j3- Q Did the task force consider the effect of i:
N is.
. .-. _ _ _. _ . . , ._, ~ , .
i l 1 Konton 131 l
[
()
(~% multiple casualties on the operators and their ability, 2
3 given their training and procedures, to handle such I
i 4 { events?
I ll 5 ! MR. GLASSMAN: Is the question whether the 6 .
task force considered this event and also I
7 considered the training of operators with regard ;
i 8 to any such event? I am not sure I understand i
9 the question. .
i 10 MR. WISE: I think the question is clear. '
11 Let's have it read back.
t 12 l !
(Record read)
() 13 A As I said earlier, the task force that I g4 was involved in generally concluded that the operator's i
13 , response was appropriate, although my recollection has 16 been helped a little bit by the item you showed me i
17 l i varlier, and I do vaguely remember some discussion of J '
18 I the fact that the operator might have terminated l
19 ! feedwater flow sooner, but as I think is ext '.icitly I
r 20 f stated in our task force report, that even so, we 21 generally felt like the operator response was adequate.
, 22 I don't remember,any particular considerations past 23 l that point.
3 Q Let me read-to you further from Mr.
25 Frederick's memorandum to Mr. Seelinger. I am reading lf
!i l'
b .
_ - _ _ - u_ m , e,m p q + -+vw m 3 gA
7 132 1 Kooton l 2 from the next to last page in Exhibit 264, item 3
- 9. "Y u might do well to remember that this is 4l only the tip of the iceberg. Incidents like this lll 5 are easy to get into -- and the best operators 6 in the world can't c ompe ns ate for multiple casualties 7 which are complicated by mechanicci and control 8 failures."
9 Did Mr. Seelinger ever bring to the 10 attention of the task force Mr. Frederick's 11 comment?
12 MR. GLASSMAN: Objection. I think 13 it has already been asked and answered that 14 Mr. Seelinger -- at least Mr. Keaten did 15 not recall Mr. Seelinger bringing this 16 entire memorandum to the task force's
, 17 attention or to Mr. Keaten's attention.
18 MR. WISE: I asked him before 19 specifically with respect to the clarm 20 system. Now we are on the effect of og multiple casualities on the ability of 22 operators to cope with an event.
I 23 A I don't remember Mr. Seelinger raising og
~
this item of the Frederick memo, no.
1 f~l
\'# As a result of the investigation of the 25 i Q
1
l 1 Kcoton 133 2 April 23 incident, were any conclusions reached 3 regarding the need for better instrumentation 4 or different instrumentation to monitor the lll 5 Position of the steam relief valves on the secondary 6 system?
7 A As I said earlier, it is my recollection 8 that the task force did recommend some method be 9 porivided that the operators could know from the i
10 control room whether the safety valves were open '
11 or not, and I note on page 4 of the task force 12 report in the section titled Summary of Recommendations I 13 that under " Actions Recommended To Be Completed 14 As Soon as Possible," iter. 3 is install a means of 15 monitoring when safety valves lift, and if practical 16 when they recede.
17 Q Was anything ever done about that l
18 recommendation, to your knowledge?
19 A To the best of my recollection, 20 acoustical monitors were installed for that 21 Purpose.
22 Q Were any other kinds of monitors 23 1 considered?
i 24 A I don ' t know.
[T i
(_/ 25 l Q
~
Who did the work on that recommendation; i
1 Konton 134 2 that is, following up or. it after it was made?
3 MR. GLASSMAN: Which recommendation?
l 4
HR. WISE: The one considering better ll 5 instrumentation for the steam relief valves.
6 MR. GLASSMAN: You are talking about the 7
sentence Mr. Keaten just read on p;.ge 4 of 8 the task force report?
9 MR. WISE: Yes.
10 A I am not sure who did it.
gi Q Was any consideration given at that time 12 to providing dif ferent instrumentation for valves 13 in the plant other than the steam relief valves?
14 MR. GLASSMAN: Consideration by whom, 15 by the task force?
16 MR. WISE: Right. Or anyone else that g7 he can remember.
18 A I don't remember.
19 Q Was there a,ny reason why the recommendation 20 in y ur task force report was limited to the steam og
~
relief valves?
. h 22 A I don't remember.
23 Q What was. the instrumentation for the g steam relief valves as it existed at the time of the O '5 j April 23, 1978 transient, if'you can recall?
I ;
i l-
ae __- ,J - _ -
l 1 Konton 135 l
/^h o A I don't recall being made aware of b ~
l 3 any instrumentation in the steam safety relief 4 valves.
, lll 5 Q Were you aware that there was an 6 indication in the control room with respect to 7 the valves showing whether or not they had in 8 a layman's sense been instructed to open?
9 A On the steam safety valves?
10 Q Yes, existing at the time of the 11 transient.
12 A No, I was not aware of any such.
13 Q Were you aware during your work in 14 the task force that there had been another. event 15 at TMI-2 cecurring on March 29,.19787 16 A You are talking about my work in 1- conjunction with this task force on the Ap ril ' 7 8 18 event?
19 Q During the period from April '
78 20 through the time this report was finalized and 21 distributed, during th a t pe riod .. f time , were you 33 aware that there had been another event at TMI-2 23 which had occurred on March 29, 19787 I am sure 2 ! you know at this point the event I am. talking
(~ -
V 25 , about.
- 1 l
1 Konton 136 l
A Yes, I do. I am simply trying to
( 2 3
remember what I knew in that time frame. To the 4 best of my recollection in that time frame I was lll 5 not aware of it.
6 Q Have you ever learned any reason to this 7 date why you were not made aware of the March 29, 8 1978 incident at the time you were working on the 9
April 23, 1978 incident?
10 MR. GLASSMAN: By whom?
11 MR. WISE: By anyone.
12 MR. GLASSMAN: I am not sure I 13 understand the question. Are you asking J }
14 whether he knows what other people thought 15 or didn't think, or are you just asking 16 whether anyone told him whether -- even 17 brought up the subject?
13 MR. WISE: Mr. Keaten was chairman 19 of the task force looking at the April 23, 20 1978 event. As we have seen, there were 21 various aspects to that which were of 22 great interest and may have become of even ;
23 greater interest in light of the Three I
~y
- Mile Island accident that occurred almost !
l
- ([) 25 a year later. ,
i
1 Kooten 137 MR. GLASSMAN: We may disagree.
( 2 3 MR. WISE: There was another event 4 also very significant.
lll 5 MR. GLASSMAN: We may disagree.
6 MR. WISE: In the view of some people, 7 that occurred very shortly before that 8 April 23 event. Some of the recommendations 9 and conclusions that were reached in the 10 April 23 event, the investigation of the
, 11 April 23 event, might well have been fitted 12 from a review of the March 29 incident.
13 Mr. Keaten, as I think testimony will 14 show as we move through this deposition, 15 was intimately involved.in investigations 16 following the Three Mile Island accident. I 17 think my question now is directed in a much 18 more general way than my questions.up to 19 this point in the deposition have been to 20 whether he has had anything come to his 21 attention to this point as to why that task 22 force that was investigating the April 23, i l 23 l 1978 incident was not made aware of another l 34 ;
incident that had occurred less than.a month O i
~
'25 and a half beforehand at the same unit.
I l
l
1 Keaton 138 l
3 A I cannot recollect any discussions or 3 e mmunications on that subject at all, but in view of 4 your earlier comments, let me put the investigation of h 5 the 1978 April transient in perspective a little bit. '
G Your questions have been concentrating on i
7 the thermohydraulic behavior of the plant during that 8 transient and that is in fact one of the things which '
9 the task force did consider, but I think it is also l
i 10 important to note that from the standpoint of the real .
l I
11 impact on the plant, there were other aspects of that 12 transient that merited a great deal of attention, C' 13 namely, the failure of the bellows which were 14 associated with the safety valves and the discovery l
13 q that the transient had led to the injection of a 16 certain amount of chlorine into the primary system are i
}7 l two items that come to mind immediately, so a great 18 deal of the attention of the task force was focused on 19 i those types of items and was not restricted to simply 20 looking at the thermohydraulic behavior.
91 Given that as a background, it is not clear 9 ~
22 to me why we would have been asked to broaden our 33 investigation to include the March incident as well.
q Q Have you become aware that the March 1978 25 ovent at TMI-2 included a failed open PORV?
I L __ _ _ _ _ _ _ _ _ _ _ _ - _ - - _
(
1 Kocton 139 i
s k ,)
2 A Yes, failed open in the sense that the 4
3 signal, the demand signal to the valve, erroneously l
i i
4 required that it stay open.
h 5 Q Are you aware today that following that i
6 event, work was done to provide additional 7 instrumentation to the control room operators concerning i
8 the position of the PORV?
9 A I am aware that work was done to provide 10 additional indication to the operators of the status i
11 of the demand signal.
- l
[ 12 Q To your knowledge, was there ever any
() 13 .
I cross-fertilization between those working on the 14 l additional instrumentation for the steam relief valves 15 ,,
as a result of the April 23, 1978' incident and those li 16 working on the provision of additional instrumentation 17 ! for the pilot-operated relief valve as a result of the b
18 March 29, 1978 incident?
19 A I don't know.
20 [ Q Are you aware of any reason why acoustical i
l 21 l monitors were eventually placed on the steam relief 22 - [ valves but not on the pilot-operated relief valve?
l :
23 h MR. GLASSMAN: You are asking for Mr.
I 21 Keaten's current knowledge, if he has such f
I \_/
23 knowledge.
h h..
- - ~ - , - , - , , ,v ,,
l 1 Ksaton 140 2 A I played no role in the selection of the !
h]
3 'j instrumentation for the PORV, and I have really no 4 knowledge as to how the decisions were made.
ll 5 Q who would have that knowledge?
6 A The personnel who did the work, and I don't 7 know who they are.
8 Q When was the first time that you personally ,
9 became aware of the March 29, 1978 incident? ,
10 Let me make that question perhaps easier '
11 to respond to. Was it before or after the Three Mile .
l 12 Island accident on March 28, 1979?
I r'N I A To the best of my recollection, it was 13 b
g4 ,
after the accident.
I 15 Q Do you know whether anyone ever performed 16 a review and report on the March 29, 1978 event I
17 I! comparable or similar to the review and report that you 18 ' performed on the April 23, 1978 incident?
19 i A No, I do not know.
20 h't Q Let me turn your attention back for a moment I
ot
} to high-pressure injection. Were there any ID l 22 i consequences for the plant and its ability to restart 23 from the fact that high-pressure injection had g
.; initiated during the accident and had continued for
' I
-25 some period into it? I am sorry if I used the word d
1
2 " accident." Incident or transient.
l t!
3 !{ MR. GLASSMAN: I just want to make sure h
4 that question relates to the incident in 1978.
5 MR. WISE: Yes, I am referring to the April I
6 23, 1978 incident. l I
7 A The only impact that I can identify was i l
8 really sort of peripheral to the high-pressure ;
9 injection. It was associated with the fact that a]ong 10 with the high-pressure injection was an injection of '
11 l sodium hydroxide, and the sodium hydroxide had a ,
12 relatively high level of chlorine in it, so I believe 13 i that there was some work which was done in considering I
14 l the possible impact on the primarv system of having 15 injected the chlorine.
16 l However, to the best of my memory, that was i
17 not by any means the item which determined the restart l,
18 schedule, and the solution that was recommended, and i
19 to my knowledge taken, was to use an alternate supply 20 j of sodium hydroxide which had a much lower level of I.
21 chlorine in it.
9 l
{
33 Q Was there not also consideration of 23 changing the parameters that would call for the
.i
- injection of sodium hydroxide with high-pressure O 25 l injection flow?
g _ _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ - _ _ _ _ _ _ _ - _ _ _ - _ _
1 Konton 142 1
l i !
A There may have been.
( 3 I recall that there 3 li was a great deal of discussion of the sodium hydroxide i
4 l arrangement, and I don't remember the details right now.
I 5 Q Do you recall what the reason was that 6 people discussed this at great length?
I t
7 Let me ask the question this way. Wasn't j I
3 8 it true that the injection of large amounts of sodium j 9 ,
hydroxide with the high-pressure injection flow had 10 resulted in a condition that was expensive and messy !
1 11 to clean up following this incident?
i l A 12 It certainly required some cleanup. I ,
13 frankly don't remember any discussion of the expense 14 l associated with it. Again, I am having a continual 15 problem distinguishing between discussions that 16 . occurred in that time frame plus later discussions of I
I the sodium hydroxide system in other context, so 17 18 my memory is not perfect as to just what was when.
19 i Q As part of the task force investigation, l
20 d '
did you become aware of any instructions or recommended i
ot ) actions given to the operators as a result of the h l 22 l necessity to clean up that injection of sodium 23 hydroxide through the high-pressure injection system
.,4 which was caused during the April 23, 1978 incident?
_'( 33 I A Your question was specifically instructions I l'
4 1
1 Kocton 143 .
i 2 to the operators?
3 Q Yes. This thing made something of a mess.
4 As a result of this, did it ever come to your lll 5 attention that in fact the operators were being made 6 wary of leaving HPI running because of the mess that it 7 could create if it continued? ,
I 8 A I am not aware of any such attitude. While 9 you were asking the question, I was attempting to '
10 refresh my memory by looking at some of the items in '
i 11 the report, and as a result of that, I do now reme mb e r '
12 that we recommended that the logic under which sodium l
13 hydroxide be injected be changed so that it would be 14 ; a less frequent event and would only occur when it was 15 more likely to be nceded.
1 IG l Q Do you know whether that recommended change 17 w ss adopted at TMI-2?
j!!
18 A According to the report here on page h 4, h
19 l I,
the comment is made that that recommendation has now li go [ been completed at the time of the issuance of the 21 i report. I don't specifically remember that, but I have 1
32 no reason to challenge what f.he report says.
23 Q .You are familiar with a set of I
3; specifications usually referred to as " Technical f' i
\ss)/ 23 ! Specifications" for the plant, are you not?
1 m.- .. - . _ _ _ _ _ _ _ _ _ _ _
l 1 Konton 144 g A I am aware of the existence of such, yes.
t 3 Q During your work on the task force, did it Olh; come to your attention that during the course of the 4l lll 5 April 23, 1978 transient certain of the tech specs for i
6 TMI-2 had been violated or exceeded, whatever the proper-;
)
i 7
terminology is? I 8 A I frankly don't remember.
i 9 Q Let me refer you to page A2-5 of your 10 report, which is page 3 of the Met Ed report. It is i
11 marked page 1247 0588 for purposes of this litigation. j 12 Would you look at that page and particularly i
13 the second full paragraph, which reads, "The event g4 caused violations in technical specification action '
l g3 g statement entries in that." Then there is a list of gg j four items.
I 17 Would you review those for just a second
- 18 lll and see if that helps refresh your recollection as to i
19
! whether any technical specifications for the TMI-2 20 i plant had been violated or exceeded during the April 23, 1978 incident.
l.
dp ,
22 l MR. GLASSMAN: You are reading from the Met 33 Ed report which is an attachment to Mr. Keaten's
.q report?
j 33 i MR. WISE: That's correct.
[
t t'
S l
.ll
l 1 Konton 145 1
() 2 A Yes, this does to some extent refresh my 3 l recollection and on that basis I believe I do now 4 i recollect that in fact certain tech spec limits were lll 5 violated.
6 Q What if anything was your understanding i
I 7 of the consequence of a violation of a tech spec?
g MR. GLASSMAN: Are you looking for the 9 legal consequence?
l 10 Q What was required within the licensee for 11 the plant in the event its tech specs had been ,
l 12 excoeded or violated?
MR. GLASSMAN: Objection insofar as you
_( 13 g4 are seeking a legal conclusion of what might be 15 required.
I 16 [ MR. WISE: I am not looking for the legal i
17 conclusion.- I am looking for his understanding ll 18 l as to whether that was a matter of something of l
19 l concern that something had to be done about or 20
! was something that was of no concern whatsoever t
- 1 and he had no understanding of any requirements f
33 I that might be triggered by the fact that a tech
.33 spec had been violated.
.q ! MR. GLASSMAN: Now you seem to be going to 25 Mr. Keaten's personal concern or lack of concern.
,f.
fi a
i l.
1 Konton 146 l
2 If you want to ask whether he had some ll c
3 understanding of some particular action to be
]
k taken after this event, fine, but otherwise we l 4 !j
( lll 5 ;
are getting into an area where we re asking for i
i 6 him to answer questions which he is not capable l l
7 of answering. i 8 MR. WISE: I don't know who else to ask f I
i 9 except Mr. Keaten to find out what he as chairman 10 of the task force thought the fact that certain 11 tech specs had been violated required.
12 MR. GLASSMAN: I am not sure of whom.
We're not here to find out his thoughts in some
( 13 I
g4 abstract sense here. If you want to ask if he 15 .t did something or recommended that something be 16 ,
done or knows anything was done, fine.
17 j MR. WISE: I disagree. We're here to find d
18 out his thoughts, because it may very well have l
19 b a great deal to do with what occurred.
20 ! You have examined at great lengths B&W 21 lI People on conclusions they reached concerning 22 the Davis-Besse transient, and I believe I am 23 entitled to ask what thoughts he had concerning I
q this April 23, 1978 transient. '
25 MR. GLASSMAN: If he reached any il t
1
'f
_ _ . _ . . . . . . . . _ _ ~ _
1 Konton 147 conclusions regarding this transient, he can 2!
b 3 lj certainly testify to it.
ii I
4 MR. WISE: I want to know what his lll 5 ,
understanding was of what the violation of a tech 4
6 spec required in the way of action by the !
7 licencee. I am not asking for a technical, l
8 legal opinion. I am just asking,as the chairman l t
9 of the task force, what his understanding was of ;
10 the consequence of the matters noted on this I
11 page. '
12 MR. GLASSMAN: I object as to form. If 13 Mr. Keaten can answer what he recalls his 14 understanding of what was to be done, fine.
1 13
- A As best I can recollect, my understanding 16 ! at that time, violation of a tech spec would require 17 certain types of action, depending on what the 18 violation was. I think I believed at that time that
]
19 .l in some cases the technical specifications themselves i
20 a state what must be done if some requirement is not met, 4
ot ! but in general, based on my experience up until that 22 : time, I be3ieve I would have expected that an i
i 33 I evaluation would need to be made as to the impact on
{'
g the plant of the violation of the technical 25 specification and.further, that there would-be some l
l .'
l li a
t.
1 Keaten 148 2 reporting requirements to the Nuclear Regulatory 3 ll Commission.
Il 4 ,i Let me also take the opportunity to point I
h 5 i
ut, however, that the fact that a task force was 6 formed of basically or mostly Service Company employees 7 was not in my opinion intended at all to relieve the 8 plant staff of obligations that they might have, fer t
9 example, under the technical specifications, but rather 10 was intended to assist the plant staff in providing i
11 technical review of the incident.
I 12 l (Lunch recess taken at 12:30 p.m.)
O . '
l 14 ;
10 d
I!
16 II i
17 l:
e l
18 !!
l 19 20 og e -
i 4
-~
n l
2a t i
1 O b t
i .
1 149
( 2 j l
AF T E RN OON S E S S I ON 3 (Time noted: 2:15 p.m.)
.g ROBE RT W. KEATE N resumed k 5 and testified further as follows: ;
6 EXAMINATION (continued) ;
7 BY MR. WISE:
8 Q Before the lunch break, we were looking ;
I gj at B&W Exhibit 186 which is the task force report ,
10 and particularly at page A2-5, which is part of the Met 11 Ed report that was an attachment to the task force 1 J
12 report. You mentioned in your testimony just before the break that you were aware that violation of a
( 13 14 l technical specification could have reporting '
15 consequences for the NRC.
l 16 Do you know whether any report _was actually i
1; ! made by Met Ed or GPU Service to the NRC with respect 18 dl to the April 23, 1978 incident?
l 10 !, A I don't know.
20 Q Did you ever see a licensee event report ot
~ ! for the April 23, 1976 incident?
l 22 l A I frankly don't remembe r whether I did or 23 not.
i 24 i Q Are you familiar with what a licensee event
! - l 25 [ report is? !
N
s, .. y
\ '
l, '-
1 K00 ton
~' <
l150
\ .
() 2 ll A Yes.
3 , Q During the course of your work on the task l force, did you become aware that any of the tech spec l
I 5 violations that had occurred during the April 23 1 6 incident might under certain circumstances require a i
plant shutdown? !
7 g A I don't remember. ,
9 Q Specifically, do you recall whether the 10 l tech specs would require a plant shutdown if it were 4
11 concluded that the bubble in the pressurizer had-s 12 entered the hot legs of the primary system? s
%N- ;
)
A Again, I don't remember.
( 13 \
14 Q You don't remember that being a topic of I
15 tj concern within the task force? sg -
i -
16 A As I indicated earlier, and maybe I can i
17 ! state it a little more clearly, the task force that I l!
18 ; was involved in was not concentrating on violations I
h, 19 4 of technical specifications or reporting requirements. .
20 We were concentrating on technically what had happened og l and what we felt were the technical implications of ,
9 -
i what had hapoened in support of others who might.be
,M X
22 23 worrying about those things.
gg .Q Was it your practice during the period'you f' l
l
(_)
25 were working on the task force to keep a n o t eb o ok ', '
l t
I c .i
\ ,
y 9 -.,
s
' , , s g. , .
w,. ,
{,- 'L9 s
i 1 3 Konton 15i r .
L ... ,y 2'[ personal'no'tebook'of matters relating to the things
{
3r ,
,, y s- -
i
. .k,,,, t ,,
I you,were working on?- -
I l .
1
,} 7' A . , .' l It was my habit, as best I recollect,gt 4
a -
l
-h 5 that tl,?etokeep} totes generally in a spiral E
, G steriographer-type pad where there was some reason why '
! s .
, t i
.-, 7 I wanted to keep the notes, but not necessarily notes ;
l t .
- s 7, , m, e% _ q
\ l\ s\ 8' o f ever'y,s telephone conversation or even every meeting 4
, s ,,
sc l, ~ , ,..-.c ,
s
~
9 but just wh'ral u I dslt it'.was appropriate to keep them.
1
' [ %
- j 10 .
I' Q you
.+
putythings in there that you thought m' s i. ,
11 were significant?
- s N .
\
12 A In some cases, yes. s i
3 v
13 ,_
.MR. WISEt I wculd like to have marked as
- s s i
- 14 i B&W Exhibit 337 a photocopy of what appear 2 to l '
- 1. , ,
l~
i 1;, .i.i ibe a portion of a spiral notebook.
' I I ,
, 16 i (Portion of\ a' spiral notebook was marked s s 1
j( ,
1- .'
l B&W Exhibitj337for? identification, as of this s ,
, s s
. 18 date.) ,, \ {g - i
.)1 -
, , u _. \'
!!) : MR. WISE: Let me state for the' record,that
-L :s '
20 'I t. B&W 337 contains a photocopy of the front of the
.gk~j notebook with-handwriting-at the top'which reads
,# s
. 1 y% ,
4
\-
Keaten, Book No. 1,.from April-l t9, 1978 4
g 33
~: s; "R. W.
4 1- , , , t s 1 ,
f r>g w to Sept. ember 1, 1978.)A. Tne remain' der of the
- y. 1
/
, s . g. . 4
.N %.s ,
F' g
'exhhbit consists of/ handwritten notes 'which appear 4 25 t'o hav4 ' bee's copied ' f, rom the tebook.
et v. : ,
u - na '\N.
- 1 k_ r
- a. . .
v
1 Kocton 152
(D 2I l BY MR. WISE:
N.-]
3 Q o yu rec gnize Exhibit 3377 ll A It appears to be a copy of a notebook which 4h 5 I kept.
6 Q Will you look through the handwriting and l
tell us if that appears to be your handwriting.
f l
l 8 A Yes, I believe it is. ,
i 9 , Q Would you look at the page which has been I
10 ; marked for purposes of this litigation in the lower
, o it 8 11 !! right-hand corner as 3795. The top of the page has the Il
't 12 ; heading "RCA Staff Meeting, April 24, 1978."
l l l r 13 ;, Am I correct that RCA would refer to Mr.
tu )S !
14 : Arnold, Robert Arnold?
l I
15 h A Yes.
ll t
16 lj Q I note that the date April 24 would be one 17 jih day following the April 23rd, 1978 transient at TMI-2.
!l t
18 ji Do you see the first notation underneath the heading il 19 indicating "TMI-2 SG coupling leak? Trip due to spike
!~
20 on NI-8, got safety injection - blew liner out of 21 l valves (bellows liner)"?
l A Yes, I see that.
33 23 ,
Q I take it that refers to the April 23 l
I incident?
24 ,
(~n i 25 i A I believe it does. I will have to tell you 1
i i
e 1 i
i
h ,
i 1 K30 ton 153 I 2 that the first item there, the SG coupling, if that is 3 j! the word, right now I con't recall that one at all.
l ll 4 Q SG would stand for steam generator?
I lll 5 A That would normally be the way I would use 6 that, yes.
7 Q Would you look now at page 3805, which l t
i 8 is several pages after your initial notation.
i 9 Let me ask y,ou first to turn to page 3800.
10 i There is a heading there " Task Force Meeting at TMI-2, i
May 2nd, 1978"and then some notations, including the 11 ]!
12 names of various people.
13 Am I correct that this note reflects your y notes of the meeting at the site following formation 15 l of the task force about which you have testified l
16 earlier today?
17 A That certainly is what it appears to be.
18 !! Q Would you look at the list of names 19 , appearing immediately underneath the heading. I take ii 20 it RWK would be you?
og j A That's correct.
22 Q There is then a list of Bob Cutler, Lou 23 Lanese, Jim Moore, Bill Schmauss, Ed Wallace, Ron Toole, gg i Rich Lentz and Jim Seelinger. Then Jim Floyd, Sandy I
O 25 :
i I
Levin, Dick Heward, Steve -- and I can't read that --
h e
Il 1I Kocton 154
- p 3 Page?
3 A It looks like P-o-j-e.
4 l Q Do you know who that is meant to refer to?
h 5 A No.
6 Q The following name is almost impossible
' 7 for me to read. Ed something, and you'have a question !
t 8 mark following it. Do you have any better recollection ,
i today than you had at the time as to who that was? i 9 ,
10 , A No, I do not. I can't read it either.
11 , Q The following name appears to be Bill 12 Gunn.
13 ,
A I believe that is correct.
14 Q Do you know Mr. Gunn?
15 l A Yes.
16 i Q Who was he? ,
i 17 A I frankly don't remembe r what his role 18 in the organization was at this point in time.
ID f Q Was he a Met Ed employee?
20 i A I am frankly not sure.
I, 21 l Q The final name is John Barton. Do you l
22 l know who Mr. Barton was?
i i
'23 A I know who he is, but I am not sure that I 3; remember what his position was at this point in time.
(:) 25 t
Q .as he a Met Ee e ,1oye. or ePe serw1o.?
t 1;1
1 Kooton 155 2 A Again, I am not sure. Let me explain the '
3 problem that I am having. At this point in time, 4 since TMI was in the process of its startup testing, lll 5 it is my understanding that there were both plant 6 staff members who would be Metropolitan Edison employees 7 and GPU Service Company employees functioning in the I
8 ,
startup and test role, both involved in the plant j g l operations, and I simply can't recall who was where. .
I 10 l Q Were there othe r people present at this i
11 l initial meeting than those you have indicated here?
i 12 Did you attempt at the time you made these notes to Q
-(/
13 get a complete listing of the people who were present, 14 or was this a selective listing, as best you can 15 recall at this point?
16 A As best I can remember, it was not a i
17 { selective listing, but I am not sure that I got all I
k 18 I
of the names.
l 19 l Q Do you know whether any of these people 20 whose names we have just reviewed were control' room ;
21 operators who were present during the transient?
22 A I don't know that any of them were.- .There 23 are at least two names on here that I have really no 3; idea what their role was, and they may or may not have 25 been control room. operators.
1 a -
e e r- . - - - - r , ,-gy-- y --,w ,~v v.-,-- ---wr- ..,.r ~ , , . - +.w-
1 1 Koston 156 i
I 2 Q That would be Mr. Poje, and the name 3
f 11 wing his which is illegible?
i 4 f A That's right, and also I am not sure to lll 5 what extent John Barton might have been involved in
, 6 plant operations.
t t
7 Q Would you take a quick look at the page i .
8 immediately preceding the one we have been discussing 9 that is marked 3799 in the lower right-hand corner.
10 At the top of the page is a notation RFW. Would that 11 be Mr. Wilson? ;
12 A That would I assume be Mr. Wilson.
13 Q There is a list of seven items following 1,; that notation. Do you recall if you had a conversation
{'
15 j! with Mr. Wilson concerning these items?
j ,; ,II A I do not specifically remember such a d
17 i discussion.
18 ; Q You see item 3 listed there, which says
/
i 19 I . " Events Recorder." Do you remember at any time b
4 20 discussing with Mr. Wilson the events recorder at ot ! TMI-2 in connection with the April 23 transient?
ID 22 ;
A No, I do not.
23 Q The fourth item is " Gas Bubble." Do you I i
3; l have any recollection of discussing with Mr. Wilson the e3 l 25 issue of a gas bubble in connection with the April 23,
l 1- Kotton 157
("' 2l 1978 transient?
I 3 A I don't specifically remember discussing
{
4 , that with Dick Wilson. As I stated earlier, I do j 5 have a general memory that what happened with respect to 6 gas bubbles outside the pressurizer was one of the i: ;
7 things that the task force was initially asked to ,
8 consider. I 9 Q Do you have any information as te why the .
10 task force was asked to consider that? i i
11 A The only thing which I recollect now is 12 that somehow the question was raised as to whethe r or 13 not it was possible that there had been any uncovery O 14 .
l
- of the core. If that had happened, it would be 15 ll important for us to know about it, and that is the
] .
16 ;; only thing I remember with respect to the gas bubble.
17 There may have been other things.
16 h Q Who raised that concern?
d 19 A A'J a i n , I don't remember specific 20 0 conversations with anyone. I just remember that that i
91 l was one of the items that we were asked to consider.
22 i Q The seventh item on this page indicates I
23 sodium hydro xide properties. .Do you recall having a l i 24 conversation with Mr. Wilson about sodium hydroxide l
-O
\_/ 25 properties in relation to the April 23, 1978 transient?
,I i
l!
i
1 Konton 158
(~h 3 l A Again, I don't remember a specific 3 ccnversation. I do have a vague memory of having it g}
l h
4 brought to my attention in some way or another that l
lll 5 there was some question with respect to chlorine 6 contamination in the sodium hydroxide. '
l
- Q Do you have any recollection of any ;
i 8 .
conversation at all with Mr. Wilson at or about the {
I '
i 9 time the task force was put together as to what it was 10 _ going to do? l t :
11 A Frankly, I am drawing a blank. I find it I
12 f perfectly credible that we did have such a conversation.
I s
13 I find it credible that these are items that we 14 l discussed, but I can't remember that conve rs ation . '
i 15 .
(Discussion off the record between the i
16 witness and his counsel) 1; Q Beginning on page 3800 as marked for I:
18 l purposes of this litigation, and proceeding for the next 19 , several pages appear to be some notes taken at the 29 time of the May 2nd, 1978 meeting. Would that be t i correct, that the material that follows immediately 1
22 j and is numbered in sequence beginning at page 3800 1.
23 l with 1-4 and continuing with numbers 3801 with numbers 3; , 5 through 7 and so on to 3803, where No. 12 is O
)N / 25 indicated, vere all notes that you compiled during the I
f i
1 Koston 159 I
(~ gf course of the May 2, 1978 meeting?
V} t. '
3 A I believe that is correct.
4 Q On page 3803, a line has been drawn about lll 5 three-quarters of the way down the page and a new entry 6 starts, NI-8, which has been underscored. Does that I
7 indicate that this was --
that the material that l i ,
8 follows was learned at some other time or is it an :
,I 9 indication to you that these notes continue to be from 10 the May 2nd, 1978 meeting?
f 11 If it would help, you might wish to look at i 12 page 3816, which has as a heading " Task Force Meeting 13 May 3, 1978" and a whole new set of numbered items. ;
14 A To the best of my recollection, the line 15 that you referred to on the page that has been marked-16 3803 was not the completion of the meeting minutes, 17 ! but that they continued on past that point. Although
,l 18 ! I an not absolutely certain, I think that it is likely i
19 that the meeting minutes continue through and including 20 the page that has been marked 3815.
'l I Q What is a feedwater latch system?
23 l A It is a protective electrical system which 23 acts under certain conditions to terminate feedwater r
3; l flow to a steam generator.
-(s_/) 23 l Q Did that system play any part in the April
1 Kenten 160
'[~h a 23, 1978 transient?
. d ~
e A I have a vague memory of some discussions 3 ll l
4j about the feedwater latch system. I don't remember any h 5 specifies right now.
l 6 Q Would it control the operation of valves i
through which feedwater is channeled to the steam l l
8 generators? i 9 A I believe that is correct. ,
10 Q Let me refer you to page 3805 of your notes 11 as marked for purposes of this lawsuit. Would you 12 look down towards the bottom of the page and look at 13 the last two notations. One of the notations is "FW 14 ; latch system - designed for steam line break - shuts l
15 FW control and block valves."
l t
I 16 l I take it in that notation, FW would refer 1- to feedwater?
18 A I believe that is correct.
19 i Q The following notation reads,." Operator 20 sees signal to valves, but not whether valves are 21 closed!" and immediately to the left of that note are 22 two vertical lines indicated in the margin.
e 23 Do you recall whether during the course of l:
I 3; the review on May 2nd, 1978 it was brought to your
'O 25 attention that the operators had seen a signal to the i
i
1 Kocton 161
}.
E i
2 feedwater control and block valves but that that 3l signal had not tcid them whef.her or not the valves were 4 actually opened or shut?
lll 5 A No, I don't recall that.
l I
6 Q Do you recall whether the task force at any i
1 7 point looked into the instrumentation with respect to 8 this system and the associated valves to determine 9 whether or not it should be changed?
i 10 A The valves you are now referring to are the t
11 feedwater and control block valves? ,
12 Q Let me ask you. Looking at your notes
, 13 here which indicate immediately before the comment
(_
14 ,
concerning the signal to the valves that you were l l
13 j discussing the feedwater latch system and the feedwater
'l 16 control and block valves, are you able to recall today 17 i which valves you were talking about in your final Yl 18 i comment on that page?
I 19 h A I don't specifically remember this entry,
'i
~ i 20 !! so I don't remember what valves it was referring to.
l 21 j Q I asked you earlier this morning whether 9 ,
there was any problem with respect to the steam relief 22 f I'
23 i I-valves and the instrumentation as it existed before the 24 April 23 incident. Just.to make sure, it is not your r
\
25 recollection now that this comment refers to the i
t' d
- I 1 Keaton 162 2 l position of the steam relief valves? By "this comment,"
> b 3 il'l I mean the one about the operator seeing the signals 4 to the valves but not whether the valves were actually lll 5 opened or shut. ,
6 A No, it is not my recollection that this ,
l '
7 refers to the steam safety valves. ,
8 Q Do you recall during your work on the task '
i 9 force becoming aware with respect to any valves, 10 whether or not it is the feedwater control and block l
11 1
valves or some other, valves, c f a problem concerning 12 the operator seeing only a signal to the valve rather 13 than an actual position indicator for that valve?
O }4 l A No, I don't recall becoming aware of any i
15 problem associated with that, and it is gratuitous
, 16 information, but I suspect that is why I don't remember 17 this, l
18 d 1 note that you put an exclamation mark Q
i 19 d after your comment and then drew two vertical lines I;
i 20 il immediately to the left of it. Was it your normal I
1 p ractice to do that for all comments?
22 l A No.
23 Q In fact, there is none other on that page
- 23 ; that is so marked, is there?
O(_/ 2.5 l- A That's correct.
ij e
..~
l Keaten 163
() 2 .:
Q Was it your practice to make these 3 !i notations only with respect to those things that you ll 4 thought were more significant than others?
lh 5 A I have used that notation to I believe mean '
6 more than one thing, always in the direction of 7 highlighting it in some fashion.
8 Q Do you know whether the task force ever 9 investigated the instrumentation on any valves with 10 respect to the question of operator ability to have a 11 direct indication of the position of the valves?
12 A I don't recall any such investigation.
() 13 Q Are you able to say today what the 14 instrumentation was for the feedwater control and block s
15 valves at the time of the April 23, 1978 incident?
16 A No, I am not.
17 ; Q Would you look now at page 3816 of your 16 i notes which relate to, according to the heading, the 19 I task force meeting on May 3rd, 1978. You see there 20 immediately underneath the heading indicating the date i,
I 21 the notation " Action Items" and then following that a 22 list of items, numbered items?
23 A Excuse me just a minute.
f-s 21 Q Is there something you would like to u 25 clarify?
li h
1 Koston 164 i
4 2 A No, I was just puzzled by something I saw.
3! I don't mind telling you what it is that puzzled me. I
?
4 ! was surprised I did not see Gary Broughton's name in t
l lll 5 j the list of people that were at the meeting.
6 Q We're back to page 3816 and the action items' 7 listed there. What was the purpose of your making i 8 this listing as best you can recall it now?
9 A I believe that these notes were made in 10 conjunction with the process that I described earlier 11 i n which various considerations associated with the 12 transient were assigned to one or more members of the 13 task force to investigate. ,
14 Q There are numerous notations here, some of 15 them for Ed, and I take it that would be Mr. Wallace?
l i
16 . A Yes.
l 17 i Q And Rich would be Mr. Lentz?
18 A Yes.
[9 i Q Bob, who would that be? You had more than 4
i; J one Bob on this team?
20 -
og l A I believe that would be Bob Cutler.
33 f Q Jim would be Mr. Seelinger?
23 A' I believe that is correct.
I 2; Q And there are several notations for RWK.
25 I'take it that would be yourself?
Y q
1 KGatan 165 I
l D-5 o
~
A Yes.
s 3 l Q There is also a notation at one point for 0l1 4 Sandy. I take it that would be Mr. Levin?
lll 5 A I believe that is correct.
6 Q The second action item is gas bubble. Would 4
7 it be correct that that referred to the formation of i
8 a bubble in the primary system outside the pressurizer? .
9 A Yes, I believe that is correct. ,
10 Q And the two people assigned to that were 11 l Mr. Wallace and Mr. Seelinger, according to this note?
12 A According to this note, that's. correct.
I 13 Q Do you recall whether they were in fact j
14 the people who were asked to look into that?
d 15 E A I do recall that Mr. Wallace in fact did
?
16 I! review the transient, including the thermohydraulics,
. I.
17 which would include this item. I do recall that Mr.
II 18 l Seelinger had independently done that, I believe in i
19 l{ ,
fact in advance of formation of this task force.
h 20 My earlier puzzlement was associated with 21 ! the fact that I did not also see Mr. Broughton's name 33 l on this item.
i 23 Q Do you believe Mr. Broughton worked on this 3; problem, that is, the gas bubble?
I~) i I kl 25 [ A To the best of my memory, he did I i t
.I
r i
1 t
h 1 Konten 166 l
2 participate in the evaluation of the thermohydraulics 34 of the transient. I do not remember specifically 4 whether he performed an evaluation of the gas bubble h 5 per se.
f 6 Let me go forward for a moment to the next !
Q l
I page, 3817, item 22, which reads, " Logic for operator 8 action - need to develop simplified version -
9 recommend," and the word " recommend" has been '
10 underscored. What did you mean by that comment?
11 A I don't remember.
12 Q Was there any concern at the time regarding I 1
13 1 the ability of the operators to find and carry out 14 l the correct procedure during the course of a transient?
15 IlI MR. GLASSMAN: Objection insofar as you l
16
[ are asking for internal thought processes of
\
1 8 somebody else.
18 Q Isn't it true that you in writing this note 19 ! were in fact pointing out a concern that the task 20 force had developed about the ability of operators to i-21 find and follow the appropriate procedure during the l
22 course of a transient?
I 23 A I don't specifically recall what this was l
21 referring to except that I have a very vague memory O 25 that this may refer to either the writeup or the I(:
b it o
l l
l 1 Kosten 167 i
[/)
\_ -
3 p
.j information we received verbally from the plant staff 3 with respect to what the operators had done and why l I!
l 46 they had taken the actions that they did, and I am not '
l lll 5 l certain, but I think that what the note was referring 6 to was the need to be able to present a simpler version i
7 of that story to the GPU and Met Ed management that !
I 8 we were going to be meeting with in a few days in i
9 i explaining the operator response. I don't interpret 10 that and I don't recall that it referred to a concern 11 that the operators were not able to find the right '
12 j procedure.
The following item is No. 23 and reads,
[~)
N-13 ,
Q
}4 " Logic for ESF injection de fe ating. " Do you recall d
to what that item referred?
15 f
16 A I don't recall what it referred to. I note I
17 j in that one and the previous one that those don't U
18
] appear to have been assigned to anyone. Again, the i
19 j best I can do is to give you what vague recollection I 20 ,
do have, which is that in drawing up this list of l 91 l action items, we were pointing toward what was for the l
22 ! task force a very near-term meeting with management in 23 which we needed to give them our initial conclusions
~
y and recommendations, and I vaguely remember that some
- 'b l
l 23 of the things that wcre in this list were directed 1'
l
~
1 Kosten 168
, i I
l! toward being able to describe to management what had
(~}
s_-
g J
3 lj happened rather than necessarily pointing to something b
4 i that we had identified as a problem area. ,
lll 5 Q You had headed this list " Action Items,"
6 and do I take your last answer to be that some of 7 these were items that you did not think required any 8 action but were simply descriptive?
9 A To the.best of my memory, the action item 10 that was referred to there was to get the information 11 l into a form where we could present it in a 12 l comprehensible fashion to_the management that was going 13 to be reviewing this the following week.
14 Q Do you recall whether you ever received i
15 !: information concerning the logic behind defeating 16 I the ESF injection?
1 17 A I frankly don't recall, and a major problem i
18 here is my being able-to separate out what I knew'as f
l 19 { a result of this transient versus " hat I later learned 20 tj as a result of the 1979 TMI accident.
l 21 { Q Do I understand your testimony to 1me that l
22 ; while you have difficulty separating out in your mind 33 between what you now know and what you have learned I
3; since-the accident and what you may have learned since
, s/ 25 the investigation, you are testifying that you did I
1 Keaten 169 3 receive some information with respect to the logic 3 ] behind defeating ESF injection as a result of this 0
4 g investigation?
A I am testifying that I can't remember lll 5 No.
6 whether I did or not, and my attempt to remember it is l
7 complicated by what happened later. ;
l
< 1 8 Q So at this point you are not able to say 9 one way or the other whether you ever got any further 10 , information with respect to item 23 on your list?
11 MR. GLASSMAN: Asked and answered.
12 l MR. WISE: It was not.
ll 13 A I cannot specifically remember whether I 14 did or not.
l 15 lj MR. GLASSMAN: That is about the third time Ic 1 it has been answered.
17 Q Would you look at item 27, which reads, i
h; 18 "New scheme for safety injection - Lou." Do I take I
i 19 j it Lou would be Mr. Lanese?
t go h A I believe that is correct.
21 Q What was meant by item 27?
O 22 ; A I am not certain, but'I believe that that 23 refers to the possible change in the logic for 3; injecting sodium hydroxide.
G 25 ,
Q That is the problem we discussed briefly i
i i Konton 170 2 this morning concerning the consequence of injecting 3
I sodium hydroxide into the primary system with the 1
4 high-pressure injection flow?
llI 5 A I think a more accurate statement of what
^
6 was intended here was that it was a consideration of ,
l 7 whether there might not be a different set of initiating; 8 signals for that injection that would be preferable.
9 Q Did you make any attempt to find out what 10 system was employed at TMI-1 for sodium hydroxide i S 11 injection or the lack thereof in connection with 1
12 high-pressure injection?
i l
13 A I don't remember whether we discussed the
, C 14 l Unit 1 system in this regard or not.
I 15 Q Did it ever come to your attention that the i
16 j system at TMI-1 was very different with respect to the i
17 !o injection of sodium hydroxide?
. il i 18 y A In what time frame?
< q l
19 l4 Q Before the Three Mile Island accident on h
20 '
March 28, 1979.
I.
I- 21 h A I am just not sure. I have the continuing I l 22 ! problem of trying to figure what I learned when.
I l' 23 Q Would you look now at page 3819 of your l
t 2 notes. About a quarter of the way down the page, there A- 1
\-) 25 I is a wavy line and then a heading "TTF - 5/4/78- Action l
I~
h
I l I 1 Kenten 171 i
2 Items." Do I take it that TTF referred to your task 3
f ree?
4 1 A I believe that is correct.
l h 5 Q Would you look at the first item that you 6 have got noted there. "1. Transient Review. A, We ;
1 i
7 are having problems with feedwater control prior to j 8 trip - high pressurizer level, popped pressurizer t
9 relief, et cetera - level dropped significantly - where I
10 did the water go. Apparently out of normal SS i
- l 11 operation - see temperature Av."
12 I have attempted to fill out what I believe '
13 to be abbreviations on your part. You are not bound 14 by my reading. If I have mischaracterized anything 15 j that you wrote there, please let me know.
16 l A I believe I agree with your characterization I
17 j of the abbreviations, i
18 l Q Your comment indicates that you had learned
~
19 ,
that the plant was having problems. prior to the April i
20 23 incident, as you note here. Isn't that correct?
21' MR. GLASSMAN: Are you asking whether the 1
22 : comment indicates that or whether he now 23 recollects that?
34 f MR. . WISE: Whether he now recollects'it.
' l 25 A I recollect that there were some problems.
l.
L _- - __-_-___-________-_-________--___---_2_. _ _ - _ _ _ _
I l
1 Konten 172 2 in feedwater control prior to the trip.
Q Were those problems in fact resulting in 3 l 4 high pressure level and relief through the pressurizer relief valve?
lll 5 6 A I frankly don't remember that.
7 Q Do you recall with whom you had 8 conversations concerning this topic? i 9 MR. GLASSMAN: Objection. Lack of 10 foundation. He didn't say he had any 11 conversation. !
12 Q You didn't make this up out of thin air, 13 did you?
14 MR. GLASSMAN: He didn't say he recalled.
15 A To answer your question, I do not believe l
16 I made it up out of thin air.
17 j Q I only asked that because your counsel was
! uncertain as to whether or not we needed a foundation 18 19- or I should say your counsel believed we needed a 20 f foundation for whether or not you learned this from t
i 91 i someone else.
i 22 l MR. GLASSMAN: It still hasn't been 23 established whether Mr. Keaten recollected any l
21 conversations related to this.
\_,) 25 MR. WISE: That it what I asked. I' presume-I
'l il 1
l
l 1 .l Keaten 173 1
2 he had conversation with someone. Who he learned 3
?
this information from.
4 A I do not remember who I learned it from.
I lll 5 Q Would you.look briefly at the following 6 page, 3820, and see item 1 listed as gas bubble. About :
7 midway down the page, chere is item 1, gas bubble, I
8 and immediately below that, it says " Pressurizer relief i I 9 l had blown about 50 times in last 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> due to 10 I sluggish" and I am afraid I can't read the next word.
11 A I believe the next word is " heater."
12 Q --
" heater control -
operators had 13 improved things somewhat (blowing once per hour)."
14 Do you recall to what that comment had 4
15 j reference?
'i
- 16 l A I believe that it referred to problems that i
17 ,
the operators were having with th3 contrciler for the I
18 ! pressurizer heaters.
I i
19 l Q Had that resulted in challenges to the 1 - l 20 l pressurizer relief valve'about 50 times in the previous 1
24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />?
l 22 i' MR. GLASSMAN: You are asking for Mr.
i 23 Keaten's recollection?
1 23 j_ MR.-WISE: Yes, all of my questions are l- -
i s A 95i directed to Mr. Keaten's. recollection.
L.
Il I; ,
i! l
\
o
1 Keaton 174 l
g A I do not recall any specific numbers such
}
li as the ones that you used, but I also should comment 3 il 40 that the concept of this type of an operation being a tj lll 5 challenge to the pressurizer relief valve is 6 something that postdates this event, and my recollection i
7 is that the attitude at this time was that this was a j 6 normal function of the pressurizer relief valve or .
9 PORV. l l
10 Q Just so it is clear, the numbers that I used' I i l i 11 in c.y question had come from your notebook.
12 A Yes, that appears to be correct.
13 l Q Did the task force give any consideration s) ! '
14 to this particular item and the consequences it might 15 d have for the reliability of the pressurizer relief I!
16 l valve?
i 17 l A The only thing which I recollect associated l
18 .
with this item was a general opinion on the part of 19 . the task force that the heater controls should be made d
20 to function correctly.
21 Q Did anyone consider the possibility that G repeated lifting of the pressuriser relief valve as 22 f i
23 many times as indicated in your notebook may have had 4;
- an. adverse effect on the reliability of that valve?
l
\" A I don't recall one way or another.
25 I
i- , l l
1 Koston 175 i
2 Q Did anyone look into the number of openings a
and closings and the conditions under which that valve 3 {
4 was designed to operate?
MR. GLASSMAN: You are talking about during lll 5 6 the course of this task force work? ,
7 MR. WISE: Yes. l 8 A Again, I don't specifically recall one way ,
9 or another. As part of the activities that were going ,
10 on in evaluating the transient and the consequences 11 of the transient, there were discussions between GPU/
12 Met Ed personnel and B&W personnel about some aspects 13 of this transient. Whether the question of the PORV g4 was raised, I don't know.
15 Q Let me go back to page 3819, the preceding i
g(; ; page. We've discussed item A under your action items i
1; l for May 4, 1978. Before we leave that, let me ask j
18 l one or two other questions.
19 i; The notation at the end of that first 20 comment reads, "Apparently out of normal SS operations _-
i og see T av." What was meant by that comment?
33 A I frankly don't remember what it meant. SS l
23 - is not'an abbreviation as far as I can recall that I y normally use.
l
\/ 33 ,
Q Have you used SS to stand for steady state?
L i
. - + - - + -
, e
l 1 Keaton 176 3 A That is possible.
a 3 ;j Q Y u are n t able to recall now whether h
4y that is what you meant here or not?
J-lk 5 l A I really do not.
6 Q Do you recall any significance of T-av 7 with respect to this comment? i 8 Perhaps I can clarify my question. You l I
g have noted "See T-av" following your comment. Would j 10 looking at the T-av tell you something about the items ,
I i 11 that you have mentioned in this comment, namely, high l
1 12 pressurizer level, popping of pressure relief valve, 13 a significant drop in the level, and out of normal .
14 operations?
l l
I:
13 r MR. GLASSMAN: You arc asking for Mr.
16 Keaten's interpretation of this particular item l 17 i now rather than his recollection of whether it i
18 meant anything to him?
19 l
MR. WISE: No, I am trying to refresh his 20 - recollection and test his recollection about this i I 21 item. I am not asking-him to interpret it today, 22 except insofar as he is interpreting it, he is 23 recalling what he meant then..
34 A I don't recall what I meant then.
(9
\/ 25 I Q Let me now move on to the next item in your t
i
.... .., , _ 2_______________________
l 1 Koaton 177 l l
2 list, which is preceded by a B, " Operator doesn't really have good knowledge of what is happening -
3]
li 4
'I seems to react too quickly according to procedure ,
rather than thinking."
lll 5 l 4
6 What specific operator actions did you have 7 in mind when you wrote this comment? j t
8 A To the best cf my recollection, this was i I
9 generally referring to actions associated with control l I 10 of the feedwater and/or energency feedwater system, f
11 but I don't remember the specifics.
12 Q Did you believe at the time that 13 improvement was needed in operator understanding of 14 the basic concepts governing the operation of the 15 system during a transient?
I
'l 16 ' MR. GLASSMAN: You are asking for his 17 current recollection of what he believed back 18 then?
19 ,
MR. WISE: Yes.
.i f A I don't recall that I personally.had a 20 p i' I 21 1 strong viewpoint with respect to that one way or 22 l another. I don't recall that I personally did any real i
23< evaluation of the type of operator actions that are y re ferred to here, and my recollection, albeit a vague 25 one,.is that I was reflecting what others who were t
l l
l-
, .- -- ,--- - -,. , , , , . . - , , - e+ ,e ., --v -
1 Kotton 178 I
, 2 doing that evaluation were telling me.
3 Q Y u have this comment listed as an action 4 item. What action was taken acout this item?
lh 5 A I don't recall that this task fcree per se f
6 took any specific action with respect to this. ;
7 Q would you look at item D listed on that l
3 page, which reads, " sequence of events was inferred --
1 i !
9 some alarms which should have been expected are not ;
10 shown."
i Is it true that there were alarms that 12 one would have expected in a transient of the type that r 13 occurred on April 23, 1978 that in fact had not gone Ci 14 off? I 15 A I am sorry. I don't remember that y li; i particular item. 17 Q Do you remember whether any action was l{! 18 'l taken on this action item? l 19 A I am not sure that I agree that this is an i. 20 action item. What you said earlier about this having 21 l a heading of " Action Items" is true, but in reviewing 22 i these notes here and on the following page, I notice 23 that where there really was an action item, that it 3; specifically is called out as such, and I believe what w- 33 happened here is that'although I he adell these notes i I
I 1 KontGn 170 I l ('s \._/
; 2 , " Action Items," I in fact included things that were
{ 3q just interesting information and not action items. 1
^
4 *Q Did you consider at the time that the j l 5 failure of expected alarms to go off was only an l i ! 6 I interesting item rather than something that required 7 action? 8 l A I don't specifically recollect this item, , I i' 9 l! so I don't remember what I might have had as an l l 10 :!a attitude toward it. 11 ll Q Would you go back to page 3817 for a 12 moment and look at item 24, which reads, "Look at (~N 13 discharge pipe plugging rumor." After that the N.J' i 14 notation is " Jim (check" something which I h 15 cant read and " design," and again I can't read the 16 remainder of that comment, and the parentheses is 1- h closed. ll 18 ! Do you have any recollection of that item? l 19 A First I want to correct something I said 20 earlier. You asked me if the entry " Jim" on these i lists would refer to Jim Seelinger. At that time I 1 l 23 , said yes. Now I am not sure that that is true. I 23 think that it might have referred to Jim Moore. 34 Q 3efore we return to your recollection of th s i I l 25 l this specific item, let me follow up on that for a li, I I e
1 Keaton 180 t 4 2 , moment. In the operations of the task force, did you \ I. give assignments both to Mr. Moore and Mr. Seelinger, 3 ll I I 4 4 ! or did you give out assignments only to those people i l l 5 who were employees of the service corporation serving 1 6 on the task force? l t 7 A In general, I believe that there were some t 8 of the items which needed to be done that Jim l. 9 Seelinger agreed to do or to participate in, but the , 10 lj best of my memory is that the meeting on May 2nd which 11 was the first meeting was the only meeting that was 12 l held at Three Mile Island and that the other meetings 13 were held in Parsippany, and further, that Jim
\_
14 j Seelinger remained at the Island. 15 Q If we could go back to item 24, which was a I 16 , the comment, "Look at discharge pipe plugging rumoe r , " 17 do you have any recollection as to what that comment 18 referred to? 19 A At this relatively early stage in'the task 20 force's activities, I have a general recollection that i 1 l a lot of our attention was directed toward the issue l 23 l of the bellows and bellows liners and what had caused 23 the failures there. I have a very vague memory that 3; l someone--had thought that some of the discharge piping g-. - k 25 downstream of the bellows and liners had been either i
i i 1 Keaton 181 i i 2 plugged or that with the steam safety valves open, s 3 that a critical flow regime might exist in that piping. h il 4 1 Q This is piping on the secondary side of the lll 5 system? 6 A It is really -- it is the piping between I the steam safety valves which were on the secondary 7 8 side of the system and the atmosphere. I f i 9 Q What if anything came of this item? { 10 A I don't remember that anything came of it. l1 1 11 ! Q Was it ever determined whether in fact those l 12 pipes had been plugged? 13 A Let me clarify my previous answer, which' 14 . wasn't very explicit. 15 To the best of my recollection, the 16 l evaluations which were done indicated that this item 17 was not significant in being a contributor to any of 18
!y the transient or the damage.
19 lli l l Q That helps clarify your previous answer, 1 20 j! but I would still like an answer to my last question, t 21 which was, was it ever determined whether or not those 22 pipes had in fact been plugged? 23 } A To the best of my memory, there was never
>4 any evidence that indicated that they were plugged.
%/ 25 .
Q Turning back to page 3820, at the - top half i h F l[ l il t
l 1 Keaten 182 2 of the page in large capital letters, you had written 3 jj " Action" underscored, and then the following comment, F if 4
" List all added and missing items for Met Ed writeup lll 5 and review with Seelinger - Wallace," and then beneath i
6 that, " Review Wednesday trip - Lanese," and beneath ! 7 , that, "Get TMI-1 transient-Lanese compare with TMI-2." l 8 Had there been a transient at or about this , l 9 time at THI-1? I 10 ; A I don't recall what that refers to. ' l : 11 Q Do you recall whether the task force ever i 12 made a comparison between the April 23 incident at 13 TMI-2 and some other incident at TMI-1? (~T 14 l A No, I don'.t recall. 15 Q Did you ever perform any work with respect 16 to any transients at TMI-1 before the date of the . 17 g accident on March 28, 19797 l' 18 A As I indicated yesterday, as a part of b c 19 ll attempting to bench mark the RETRAN model for TMI, we 20 i have looked at certain transients that occurred in l 21 TMI-1, and I frankly don't remember the. exact time l ' l 22 ! frame, and the extent to which that was done before 23 versus after the accident. i 24 I Q Have you ever reviewed or seen a transient
%/ 25 report or analysis concerning any events at TMI-1 L
c
1 Keaten 183 l 2 involving the pilot-ope rated relief valve 3 malfunctioning in any respect? fi 41 A I do not recall any TMI-1 transients lll . 5 associated with a mal f unctioning PORV. , 6 Q Are you aware of any transients at TMI-1 7 before the accident at TMI-2 which resulted in 8 saturation in the primary system outside the 9 pressurizer? [
\
I 10 MR. GLASSMAN: You are asking for Mr. ' 11 Keaten's current knowledge? . 4 12 j MR. WISE: Yes. 13 A I do not recollect any such. I 14 Q 'Are you aware of any transients that 15 occurred at TMI-1 before the TMI-2 accident-which 16 resulted in initiation of high pressure injection? 17 A I don't recall one way or another. j l 18 'l Q Did you ever receive any information back i 19 . from Mr. Lanese concerning any comparisons that he 1
' * ~
20 may have made between the April 23, 1978 incident and t 21 any other transients, whether at TMI-2, TMI-1 or'some 2,9 l other plant? 23 A I don't recall. 24 g- Q At some point during the April 23, 1978 ("% 1
\ ) */
25 transient, the operators did reduce HPI flow, isn't t
. _ ___ _ . _ _ _ ____________._ ___ m_____.
l l 1 Kenten 184 3 that correct? 3 }o A Yes, I believe that is correct. ; 4 Q Was it ever of concern to you during your i I jh 5' work on the task force that the operators had done so? 6 A I do not recall that the task force found
- i I
7 that the reduction in HPI flow was inappropriate. ' 8 Therefore, I don't recall that there was any concern l i 9 about it. 10 Q You may have misunderstood my question. 11 3 Regardless of whether in this particular accident the 12 reduction in HPI flow was appropriate, was there any I i
+
13 I concern on the task force that you were aware of.about
\ '
- 14 i whether the operators had correctly understood the -
I! 15 l situation at the time they terminated HPI or reduced i 16 its flow? 17 MR. GLASSMAN: Objection. I am not sure a 18 I it is clear to me from the question what situation 19 you are talking about. 30 MR. WISE: The transient. 21 MR. GLASSMAN: I am not sure what you mean S 22_ l by "whether the operators understood the 23 transient." What aspect, what initiating event? 24 I am not sure what you-have in. mind. This is j (~ .
\- 25 clearly a different question from the earlier.one.-
[ 4 H
,-e- , ,c- , - ,,-,.,-en-y ,-y + ,v.-- - , - , - . , , . , - y % * - , . . ~ , -
1 Ketten 185 t 2 Maybe the witness can answer, if he 3 y understands what it is, but I am not sure I do. 4 A I don't totally understand the question l 1 lll 5 either, but perhaps I can answer a more restricted 6 question that will get to your --
.i MR. GLASSMAN: Let Mr. Wise rephrase it.
I I 8 MR. WISE: I can perhaps rephrase it. 9 Q I understand from your testimony that the , s 10 task force concluded that the operator action during I 11 .l the April 23, 1978 event in terminating or reducing the 1 . l 12 j HPI flow had been appropriate. ; I 13 My question now is a different one. That 14 ; is, whether the task force was concerned, to your II 15 j, knowledge, whether the operators at the time they I! 16 Il
, terminated or reduced HPI did so for the right reasons.
t- A I do not recall any concern expressed by
.I 18 ] the task force on that subject.
I 1 19 (Recess taken) f l 20 'L BY MR. WISE: 21 Q Were you at any time conce rne d during your 22 work on the task force with whether the operators had 23 been able to correctly distinguish between a steam og line break and a loss of coolant accident? (
\'-
({ 25 A I don't recall such a concern. l l !
, , - - - , , , - - , n , ,.,-r, , , n + - - - - - , .---n
1 K3& ten 186 l l 3 ! Q Would you look at page 3826 as it has been Os,- !! 3 I marked for this litigation, which is a further page of u 4
!l your notebook in Exhibit 337, and look at the comment about halfway down the page.
lll 5 It says, " Talk to John 6 i Barton-request Ron Toole be present." Underneath that, t 7 "How did operator know no LOCA." l l 8 were you in the practice of referring to , i N ' 9 , a loss of coolant accident by the abbreviation LOCA? l 2 A Yes. 10 l 11 l Q Do you recall the comment as it appears on l 12 page 3826 that I just read to you? 1 13 A I see on that same page that there is 0 g4 i
! another related entry up at the top where it says
) 15 ,
" Recommendation short-term operator training on 16 simulator - steam line break versus LOCA."
17 Q Does any of this refresh your recollection le ! as to whether or not you were concerned about the 19 Y operator's ability to identify and correctly 20 distinguish between a steam line break and a loss of b. 91
~
I coolant accident? t 9 22
- A I don't recall that, and I also note that.
23 does not appear, as far as I can tell, in any of the l 21 j recommendations in the task force report. 25 Q Did you ever get an answer to the question t t i y
I 1 Kanton 187 i noted in your notebook, "How did operator know no O' 2 i LOCA?" 3 ll 4 1 A I frankly don't remember that at all. 5 Q Do you remember any conversations with Mr. 6 Barton or Mr. Toole concerning this matter? I f
\
7 A No. ' s Q What areas was Mr. Barton working on for ; I g the task force, if any? l 1
'I A 10 ;l To the best of my recollection, he was not )
I 11 working on anything for the task force. I 12 Q Do you have any information today as to 13 why the notation suggests that you talk to John 14 Barton with Mr. Toole present concerning this item? l 15 ,, A I don't have any recollection at all of S 16 h that, and I further note that the way that this is
'i 17 arranged in this notebook and the way I normally keep i
18 ! notes, I do not necessarily assume that these two items i
, 19 j are related.
I 20 ii. Q With respect to your short-term 4 21 i recommendation which you noted in answer to one of my 22 previous questions, do you know whether anything was. 23 ever done to follow up on thot? That short-term 23 recommendation was " operator training on the simulator O (_) 25 , steam line break versus a LOCA." 4
1 KGaton 188 t . .
<* 3 MR. GLASSMAN: You are talking of the entry l l
at the top of this page? 3l li 4 ['l MR. WISE: Yes, page 3826.
- ' i
! A Again, I don't remeuber that. I don't ll) 5 ,
i 6 remember making it as a recommendation, and I don't : 7 r emember, if it was made as a recommendation, what if I i I g anything was done. 9 Q Did the . task force, to your knowledge, ever i 10 determine whether the operators knew they had no loss l 2 I 11 of coolant accident at the time they terminated 12 high-pressure injection during the April 23, 1978 i 13 incident? ; 1 ,
- 14 ,
A I don't recall. t
- I I
i i 13 4 Q I would like you now'to look at B&W Exhibit i I 1d : 186, which is your task force report, and we're going 17 to be looking at the attachment or appendix to your 18 report prepared by Met Ed. If you look at page A-2-16 i , 19 l of your report, which is marked for purposes of this
- i. 20 l litigation as 1247-0600, that page is titled 21 " Recommendations / Action Items." Following it through ,
22 page A-2-19 are a series of recommendations contained 1 . 23 in the Met Ed report. Do'you see that?' 21 . A Yes. This particular copy appears to have 25 a page missing.
. _ _ _.-- - ~, , . - - , ..,. ,,. _ - . . . . . . . . - , . . . - . . , , , _ ,
- . . = - . -- - - - -
l 1 KGcten 189 f i g MR. WISE: Unfortunately, for whatever b 3 reasons, in the microfilming, B&W Exhibit 186, 4 !f i apparently page 17 of the Met Ed staff report lll 5 which was re-marked page A-2-17 in the task force 8 6 report, was missing. We have another copy of i 7 the Met Ed report which was also marked in this j t litigation as B&W Exhibit 246. I 8 . 1 9 While we took a short break, we obtained i i 10 : from Exhib t 246 a copy of page 15 of the Met Ed 11 . report and counsel for plaintiffs has had an 12 opportunity to compare it as it existed in the
, [ ) 13 original Met Ed report, and the witness now has '
l 14 l that page before him. I don't think it is i i 13 f necessary to insert it into the actual exhibit. 16 y For whatever reasons, the exhibit was marked i 1- ! without that page, but so the record is clear, 6 I 18 that page should have been part of the Met Ed t 19 , report and was part of the Met Ed report marked i i
- 20 as 246, l
21 ' I also note that Exhibit 246, which was 22 ; marked earlier, has a cover memorandum signed by i 23 Mr. Seelinger and dated May 4,'1978, which - is indicates that the finalized report is being i forwarded under cover of the memorandum. i 25 There f i t
- - . ~ _ . . _ . . . _ . _ , _. .
1 Kantsn 190 3 is a lengthy list of individuals listed as 3 l receiving a carbon copy. Among them is Mr. Keaten. lll f 4 g With that out of the way, we can go back b l 5 j to the questioning. I 6 BY MR. WISE: i 7 Q Again let me turn your attention to the g recommendations and action items in the Met Ed report. 9 g Would you look at the action items for equipment 10 changes. Item 10 says, " Computer problems with the 11 l sequence of events and memory trip review need to be 12 l!l resolved -- Fels -- prior to startup." (~] 13 Do you know what the notation " Fels" means? U 14 g A Yes. It refers to Mr. Bill Fels, who was U 15 d a member of the computer group. i 16 , Q Did the task force at any time learn that 17 the computer problems with the sequence of events and 18 memory trip review had been resolved? 19 l A I don't recall that the task force was e 3 20 informed that the computer problems had been solved. 91 I don't recall in the sense of one way or another. 23 Q Item 12 indicates as follows: " Provide i 23 some indication for main steam relief valve position. 3; j A temporary microphone from the vicinity of the valves [^N !
'I 33 to the control room has been suggested. In this way, i
1 Keaten 191 2 the operator could at least detect independent of 3 ; analyzing console indication that the relief valves il 4 are open. GPUSC -- Toole -- prior to startup." i 5 was this recommendation followed up on by ll i 6 j your task force? ,
; i 7 l A The recommendation from the task force that i
8 I was a part of was to provide some means of knowing 9l whether the valves were open, and eventually, if , i . I ! 10 i practical, some method of knowing when they reclose. 1 11 , In our task force report, this item as ! I 12 l listed is complete, and I believe that in fact it was l , i 13 l listed as complete, based upon the action that was l 14 i indicated in the Met Ed report. , 15 9 In discussing that item, I notice this time, 16 ; and also once before when you mentioned it, that you 17 added the qualifying phrase "if practical" with 1 ] 18 respect to installing some form of instrumentation to 19 give the operator direct indication of whether the valve
.f .
4 !! 20 lj had reclosed. I 21 What do you mean by "if practical"? 22 A To the best of my recollection, the item 23 was worded that way to indicate the task force's 1 23 l perception of a difference in priority between the need
\_/ !
23 for a signal to show when the valve had opened and a 1
1 Kosten 192 , l 2 signal th at would let the operator know when it had 3 reel sed, and so the wording was to indicate that we h 4 i felt it was of higher priority to get a signal that l 5 w uld let the operator know when the valves were opened. ll 6 j Q Would the provision of a signal to let the i 7 operator know when the valve had opened in some way ; I g make it less practical to provide him also with a 1 9 signal for when it closed? , t 10 A Not necessarily. 11 l Q I am still having difficulty with the 12 qualification "if practical." What was it about the l 4 13 provision of a signal to indicate closure of the , s' g4 l valve that required the qualification that it be done i I I
- 15
; only "if practical"?
j! ' I 10 ; A My recollection is that the task force was i l 17 ! led to believe that it might be in fact very difficult i f 18 to accomplish the detection of the valve closure i 19 f because of the way that the valves were designed. c I 20 'i Q What would make it difficult? ot ! A I don't remember the details, but I believe i 22 it was our understanding that, given the design of 23 the safety valves, there was no obvious way to put the i 34 type of mechanical indicator that is frequently used 1 (~~)
\d 1
43 to detect valve motion in other types of valves, and i I
i 1 , Koston 193
-r% o~ , whereas,as I indicated in the Met Ed recommendation,
[! 3 there appeared to be a reasonably straightforward method l 4 j of providing to the operator some indication _that the l' valves had opened, we. had not identified any comparable lll 5 6 method of doing it for valve closure. ! e 7 In addition, the recommendation was based , g upon the perception that from the standpoint of value 9 to the operator in operating the plant during a 10 , transient involving the steam safety valves, that it , i i 11 was more important for him to know that the valves had , 12 opened.
% 13 Q The microphone device would tell him that e
14 the valve had opened, is that correct? ! l f 15 A One or more valves had opened.
- ?
16 ! Q Is it true that device would, however, not 17 t be a reliable indicator of closure of the valve? h 18 1 A If more than one valve were opened, I don't 19 l believe the microphone would give reliable information 20 l1: about when and if individual valves closed. It might 21 Il be used as an indication that all valves had' closed 22 l once that were true.
.t 23 Q It is true, is it not, that such a 24 microphone would not be a reliable indicator if the O(_) 23 valve had only partially closed? In other words, there i
j l
- l i.
. 1 Keaten 194
, 2 is a possibility that the valve could be entirely ^ 3 !! opened, entirely closed, or somewhere in between, and ' ' 1
- I 4 ; the microphone would not help very much with respect >
$ 5 to a situation where the valve was neither entirely I
6 closed or entirely opened? j 7 MR. GLASSMAN: Are you asking for Mr. ! , i ' Keaten's opinion or whether this was discussed 8 l
; 9 in the task force?
10 MR. WISE: Whether this was considered in I 11 the task force in connection with these i 12 recommendations. 1 ^ I 13 A To the best of my recollection, there was
! 14 some discussion about partial closure and the fact i
i i 15 l that microphones would not be particularly useful in 1
- IG ! indicating that.
l 17 I Let me also clarify the reason for the l' .! p 18 , task' force's recommendations in this regard. It bears l 19 upon the difference in priority. i , 20 To the best of my recollection, the task 21 force generally felt that something like a microphone i-e 22 l which would tell the operator, yes,-he had one or 23 more steam safety. valves open, and then eventually, yes, i 2; j they are all now closed, probably would fulfill the i
~
25 ,
. needs o f the operator, and the desire, to the best of i
l t
1 Keaten 195 g my recollection, for having more specific information i on when valves opened and closed individually was 3[ 1 4 'j really for the basis of a later reconstruction of a transient as contrasted to what the operator needed
) 5 t
6 during the transient, and so we would and, to the best of my memory, we did perceive that although that would t 8 be in some sense desirable, it was a lower priority ; 9 than providing the information to the operator that he I ' 10 ' could really use. 11 l Q Was there any consideration given as to 12 k, whether there was some device or form of instrumentation I 13 which would give a direct indication of the position
~) ,
14 of the valve, not just whether it was entirely open l 15 [ or entirely closed, but a direct indication of exactly i 16 what the position of the valve was? 1- , A To the best of my recollection, we were
'I 18 l told that no one had come up with a good scheme for 3
19 doing that. 20 nl Q Who told you that? I t A I don't remember. III 22 Q . Was it someone within the GPU system or 23 an outside group? 2; ; A I don't know. O- 25 , Q Let me ask you generally with respect to I 8 j
I 1 Keaton 196 ('g 3 l the recommendations and actions contained in the Met V 'i 3 Ed staff report. Did the task force consider those i: 4 recommendations and actions as items that the task force l 5 needed to examine and resolve itself? l 6 Let me withdraw that. That is probably a i 7 confusing way to put the question. i i 8 What use, if any, did the task force make , i 9 f the recommendations and actions proposed in the Met 10 Ed staff report? I ! 11 MR. GLASSMAN: The question is directed 12 to recommendations generally of a Met Ed report, 13 not to specific items? (N 1 14 l MR. WISE: That's correct. i 15 A I don't recall that the task force 16 directly used these recommendations per se in its j 17 , activities. I certainly believe that we were aware of 18 j them, and furthermore, with Jim Seelinger participating l 19 j in our task force as well as in the Met Ed activities, 20 it provided some consistency between them, but the 21 best of my recollection is that the task force tended O 22 to develop its recommendations on its own and then 23 look to see where there was overlap between the two, 3; and clearly there was everlap between the 23 reconmendations, but there was not, for example, an 9 i
1 Keaton 197 4 3 f attempt to integrate the two sets of recommendations i! a into one joint set of recommendations. 3 lls 4 i Q Was that because there was disagreement i l 5 within the task force with some of the recommended 6 items in the Met Ed plant staff report? ! i 7 A Not that I recall. I think it was more f l 8 a reflection of the fact that the two sets of ; i 9
. recommendations were developed to some extent i
10 independent of each other, and furthermore, that the ; 11 recommendations as they appear in this report were t 12 really documented for historical reasons in the sense 13 that many of the recommendations shown here as J 14 indicated in the report had already been completed by 15 the time that the report was issued. 16 Q In your last answer, you referred to this i 17 i report in here. I take it you were referring to the I! 18 j! task force report which is B&W 186.
'l .
~
19 l A That's correct. 20 Q You were contrasting it with the-Met Ed
- i; l t I staff report which has been marked separately as 246
&. 22 l
and also is included as an appendix to the task force l bl 23 report? 3: A That's correct. 25 Q Would you look at page A-2-18 in the task c l _ . _ . .
l 1 KGaton 198 3 force report. It is page 16 of the Met Ed staff 3 report. You will see at the bottom the heading
!i 4
" Training." Underneath that there are two items. Do I
l 5 l you know whether, or did the task force make any review G to determine whether or not the training items listed i I 7 on page 16 and carried over onto the following page were ; I g actually followed? 9 ; A Not to the best of my recollection. 10 ; Q would you look at the recommendations listed i 11 under "Other," particularly the first item, which calls i 12 for " Precalculate the exact volumes of critical piping 13 runs and tanks from various taps and capture'in a g4 procedure. Such a procedure would have helped in i 15 l quickly analyzing the pressurizer situation and'in IG l determining the core remained covered." I 1; I That is the way it reads. Apparently a 18 word is missing. To your knowledge, was such a 1 19 procedure ever written? I! h 20 2 A I don't know. I 21 Q Did the task force take a look at that O 22 recommendation? 23 o A I don't recall the task force specifically 24 , considering this recommendation.
/~' l 25 Q Would you look at the second recommandation i
t b
1 l 1 Kocten 199 f 1 and the third, both of which discuss the alarms, and ( 2 l li 3 in the second recommendation, the statement is made
!l i
4 " Escalate the alarm window correction program in lll 5 priority. This will eliminate an excessive lighted G n-mber of panel alarms at the base line condition I i 7 and give the operator a better chance to focus on what I i 8 to respond to." l 9 Do you know whether anybody ever did , i 10 , anything about that? 11 A To my knowledge, the task-force made no , l 12 attempt to track that recommendation, and I don't know what happened. ( 13 14 Q Finally, item 3, which reads " Add ' i 15 l additional alarm acknowledgement capability in the 16 control room. Currently, the operator at the controls i 17- i has to go across the control" -- and I believe the ' 18 word " room" has been omitted -- "to read an alarm and 19 . then back to the center console to acknowledge it. 20 GPUSC -- Toole -- determine GPU position." ot ! Did the task force look into that h 22 l recommendation? 23 A To the best of my knowledge, no. l 34 (Continued on next page) l ($) 25
-~ _ _ - - . . _ . ._. ._ _ -. . _
- r. .... . ... .. . .-_ - --.-.. . _. .-. . .- .- - . .. . . -
a. 1 1 Keaten 199-A . 2 .Q Do you know whether anyone at GFUSC did? I 3 ! A I don't know. I hl l 4 l. (Time noted: 4:55 p.m.) { i h' 5 , i I 6 I 7 ROBERT W. KEATEN i i
- f. 8 ;
4 i f~ * ] 9 Subscribed and sworn to i I 10 before me this day of i i 11- 1982. i 1 i 12 ! t f l i 14 i-I i 15 !i i ! i 4 i 16, , 4 I I i 17 i i i 18 i
- i
- 19 ll i,
4 !. 20 , 9{
)
i 22 j 23 l l 24 e , 25 f I
,e- . --*,,--,.---r--Ew--e #+ +w-mw---w-~~e 2 i-=,-w-inew---.-<, .~,---<v----~b+,*,---,4..-,---ve-,-----ev,,vv.w.,%=,<--,-----,w--+.w...e-,e=-+
1 200
- CERTIFICATE O -
STATE OF NEW YORK ) 3 i
- 33,:
COUNTY OF NEW YORK ) 4 e.
,, I, JOSEPH R. DANYo , a Notary Public of the State of New York, do hereby certify that the continued deposition of 7
ROBERT W. KEATEN 8 was taken Defore me on Tui:S D AY , JANUARY 5, 1982 consisting of pages 92 199-^ through ; I further certify that the witness had been previously sworn and that the within transcript is a true record of said testimony; That I am not connected by blood or marriage with any of the said parties nor interested directly or indirectly in the matter in controversy, nor am I in the employ of any i of the counsel. t IN WITNESS WHEREOF, I have hereunto set my
~
20 hand this [7' day of Awver / 9&;;L , ($ 21 l , 22 W A. Ow bSE H R. DANYO /# 24 2s
i 201 'l 1 a !O l \ i I NDEX ,i 9 . WITNESS PAGE i Robert W. Keaten (resumed) 94 i EXHI B ITS
}
i ) B&W FOR IDENTIFICATION I-
< 337 Portion of a spiral notebook 151 1 -oOo-1 l
i J i 4 i i I h l +, _ i ,y. 4 4
a# - i If J ( UNITED STATES DISTRICT COURT I
; SOUTHERN DISTRICT OF NEW YORK i
; ----------------------------------------x fGENERALPUBLICUTILITIESCORPORATION, :
JERSEY CENTRAL POWER & LIGHT COMPANY,
,j METROPOLITAN EDISON COMPANY and :
; PENNSYLVANIA ELECTRIC COMPANY, l :
j Plaintiffs, 80 Civ. 1683 (RO) , l
. -against- AFFIDAVIT I :
} THE BABCOCK & WILCOX COMPANY and j J. RAY McDERMOTT & CO., INC., :
De fe nd ants. : I ________________________________________x 5 6 STATE OF NEW JERSEY ) /G. : ss.: V [ COUNTY OF MORRIS t
)
f. I have read the transcript of my deposition taken on jjJanuary 4, 5, 6, 7, 8, 19, 20 and 22, 1982 and together with the i;
' attached corrections, it is accurate to the best of my knowledge and belief.
_' N. Robert W.'Keaten
~.
Signed and sworn to before me this J7 I day of October, 1982. P Notarf Public C AUCE 3. HOUSE P3TARY FU200 0F K!W JEFS!Y F*, ::rt:nissien Expires 'tarch 7. leS5 __-_____-___---__-__----_____-___-t.___a
. l CORRECTIONS OF ROBERT W. KEATEN September 1982
~
Page Line Correction 36 13 "Seward-7" should read "and Seward-7" 81 16 "Mr. Broughton" should read "Mr. Schmauss" 121 7 " time phase" sh6uld read " time phased" 133 16 " recede" should read " reseat" 243 6 " Jim Seeinger" should read " Jim Seelinger" 333 16 " pumps were turned" should read " pumps turned" 354 20 " communication" should read " coordination" 354 21 " center. Although" should read " center, although" 408 18 "on" should read "a" 420 3 "believe" should read " believed"
' ~
460 12 " sentences in" should read " sentences and" 461 9 "can shoot out," should read "can shoot at it." 463 11 "I am" should read "I am not." 465 16 " regard as things of undesirable" should read
" regard as undesirable" 467 9 "eminet" should read " imminent" 470 25 "could" should read."would" 482 8 "value." should read " valve,"
490 20 "How did you reach" should read "Had you reached" 494 19 "already" should read " satisfactory" 506 9 "effect, indicating" should read "effect, indicates" 510 11 "If I had known it was the other valve, I" should read "If they had known it was the other valve, they" l (
\- Page Line Correction 525 5 "0" should read "A."
j 525 23 "that it would" should read "that would" 529 5 " pressurized" should read " pressurizer" 539 21 "that. My" should read "that, my" 543 19 " reactant" should read " reactor" 544 3 "the" should read "this" 551 14 "is" should read "or" 560 9 " steam leak" should read " steam line." 561 25 " steam leak" should read " steam line." 580 15 "about" should read "against" 589 3 "in" should read "and" () 608 638 18 16
" uncertain" should read " referring to" "0" should bead "A."
640 18 " task force intended" should read " task force had not intended," 641 8 "ever time" should read "every time." 652 20 "sponse rs" should read " assistants" 679 8 "I recommend"should read "I recommended"
?
684 14 "JRT-GARB" should read "JRT-ORB." 693 5 "of" should read "by" 693 7 "Mr. Lanese's" should read "Mr. Lucien's" 719 18 "Q" should Read "A." 742 23 "second" should read "section" 743 24 " alternative is" should read " alternatives." 744 18 "in" should read "and" 2
O Page Line Correction 755 18 " extent" should read " accident" 768 7 "an independent view" should read " interview" 781 17 "do take actions. on" should read "do take actions which" 781 18 " turns" should read " turn" 792 16 "his" should read "the" 801 4 "I do recollect that" should read "I do recollect this." 812 13 " instruction" should read " instrumentation 825 5 "their" should read "the" 825 6 " current" should read " occurrence" 829 3 "in" should read "of" 847 13 "A" should' read "Q." 866 23 " accusations" should read " actions" 868 6 "to a degree" should read "to agree" 868 14 " opinion" should read "importance" 867 7 "a waiver'should read " aware" 872 23 "on" should read "from" 876 16 "from" should read "to" 882 6 " differentiation" should read " differential" 883 24 " differentiation" should read " differential." 894 8 "doesn't" should read " accident" 895 24 " discussing" should read " discussing," 895 25 "it as part" should read "as part"
- 900 19 "only" should read "any"
(} 3 l
/
i l Page Line . Correction 900 20 '
"by one person" should read "by only one person" 918 10 "made" should read "may" 942 15 " steam" should read " sneak" ,
954 17 " system." should read " system," 964 3 "A" should read "Q." 1 974 11 "Q" should read "A." 983 12 "and" should read "in" 999 18 "Mr. Keaten" should read "Mr. Glassman." 1009 19 "O" should read "A." 1015 8 "0" should read "A."
/~' 1023 " culled" should read " called" V) 3 1024 3 "their qual'ifications." should read "their environmental qualification."
1033 22 " arrive a" should read " arrive at " 1036 5 "O" should read "A." 1039 21 "I believe aware" should read "I believe I was - aware" 1043 9 " suction tank," should read " storage tank" 1048 3 " contingent" should read " contentions" 1048 7 " remember exact words" should read " remember the exact words." 1050 23 " hand" should read "and." O LJ 4
-w7-i + g .. - - - - - - e-. -}}