ML20072J166
| ML20072J166 | |
| Person / Time | |
|---|---|
| Site: | Three Mile Island  |
| Issue date: | 06/19/1981 |
| From: | Karrasch B BABCOCK & WILCOX CO. |
| To: | |
| References | |
| TASK-*, TASK-01, TASK-02, TASK-03, TASK-06, TASK-07, TASK-1, TASK-10, TASK-11, TASK-2, TASK-3, TASK-6, TASK-7, TASK-GB NUDOCS 8306290987 | |
| Download: ML20072J166 (74) | |
Text
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l sc 325 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK
_ _ -x j GENERAL PUBLIC UTILITIES CORPORATION, *
/' JERSEY CENTRAL POWER & LIGHT COMPANY, METROPOLITAN EDISON COMPANY and :
PENNSYLVANIA ELECTRIC COMPANY, Plaintiffs, 80 CIV. 1683
- (R.O.)
-against-j THE BABCOCK & WILCOX CCMPANY and J. RAY McDERMOTT & CO., INC., :
Defendants. t :
-- - - --- -- . __ _ _ _ _. ._x Continued deposition of THE BABCOCK & ~
WILCOX COMPANY, by BRUCE ADOLPH KARRASCH, l
taken by Plaintiffs, pursuant to Notice, and as adjourned, at the offices of Kaye', Scholer, Fierman, Hays & Handler, Esqs., 425 Park Avenue, New York, New York, on Friday, June 19, 1981, at 9:19 o' clock in the forenoon, before Charles l Shapiro, a Certified Shorthand Reporter and Notary Public within and for the State of New York.
i
'( .
l 8306290987 810619 i PDR ADOCK 05000289 l T PDR i O #
U DOYLE REPORTING. INC.
CERTIFIED STENOTYPE REPORTERE 369 LsxtNGTON AVENUE WAl.TER SH APIRO, C.C.R.
NEW Yo m m:. N.Y. 10017 CHARLES SHAPIRO, C.S.R.
Tat.spwong 212 - 867 8220
t 326 O 2 Appe aran ce s :
3 4 KAYE, SCHOLER, FIERMAN, HAYS & HANDLER, ESQS.
Attorneys for Plaintiffs
( 5 425 Park Avenue New York, New York 6
BY: RICHARD C. SELTZER, ESQ.,
7 of Counsel 8
9 10 DAVIS POLK & WARDWELL, ESQS. (
Attorneys for Defendants 11 One Chase Manhattan Plaza New York, New York 10005 I s BY: ROBERT B. FISKE, JR. -
13 -and-PATRICIA VAUGHAN, ESQ.,
14 O
of Counsel 15
. \
16 17 ,
18 Also Present:
19 DAVID TAYLOR 20 91
(, e *
- 22 23 24 25
327 1
(~)
V' 2 B RUCE AD0LPH KARRAS C H, 3 resumed, having been previously duly sworn by a 4 Notary Public, was examined and tastified further
( 5 as follows:
6 EXAMINATION (cont'd) l 7 BY MR. SELTZER:
8 Q Mr. Karrasch, you said that while you had i
9 not personally initiated preliminary safety concerns 10 your plant integration unit had or members of the unit 11 had, is that right?
, 12 A Yes, sir.
13 on what subjects?
Q ,
I4 A I don't recall any specific ones at this time.
15 Had any of the PSC's initiated by people Q
16 in plant integration resulted in part 21 reports?
17 A I don't recall.
18 Q Did you review the PSC reports prepared by 19 people In plant integration?
20 A Yes, I do recall reviewing reports prepared by i
- 21 people in plant integration.
k 22 Q About how many PSC's were initiated by plant 23 integration?
24 (O)- A I don't recall the exact number but I would say 25 it was on the order of five or ten.
g Karrasch 328
/"s 2 Q You don't romember the subject matter of a 3 single one of them?
4 A I recall one on the subject of equipment errors l 5 used in the safety analysis of the plant, but I can't 6 think of the specific nature of the concern right now.
7 Q What do you maan by " equipment error"?
8 A The safety analysis group assumes certain 9 instrun.entation errors used in the reactor protection 6
10 system. .
11 I vaguely recall a PSC where the actual
_ 12 hardware qualification data was indicating errors which
\_) 13 were larger than those which had been assumed in the 4
14 analysis.
15 g would you take a look at page 2 of GPU e
16 Exhibit 94?
17 (Handing document to witness.)
18 Under the " Definition of significant 19 Deficiency," do you see the items "a., b., c., and d."?
20 A Yes, I do.
21 Q It indicates there that a significant 22 deficiency would exist as a rasult of one or more of i 23 the following d. is "A significant deviation from I 24 performance specifications requiring corrective action 25 involving extensive effort."
i i
_ - _.___ _ _ . _ . . . _ . . . _ _ . ~ _ _ _ _ - . - _ _ _ . - _ - - . _ - . . - - _ _ ._. _ ___ _ _ . ~ . - _ . _
i l
j g Karrasch 329
' 2 What are the performance specifications i
3 referred to there?
4 MR. FISKE: You mean what did he understand f
(, 5 them to be in 1978?
6 MR. SELTZER: Right.
7 A I don't remember trying to understand the specific 8 definition of performance specifications in 1978.
9 Q Were you able to apply part d. without 10 knowing what the performance specificat, ions meant?
J 11 A Yes, sir, I would say so.
i 12 How did you apply it?
Q
!O 13 A As I testified earlier, my under. standing of the 14 procedure is that it requires a safety c neern to be 15 filed if there is a defect or an error in any 'of the I 16 design documentation which is used to show that the 17 plant is safe or to procure hardware for safety-rclated 18 equipment. That includes a very large' hierarchy of 19 documentation all the way from safety: analysis 3-20 calculations to equipment' specs to by hardware to 21 hardware-performance specifications that the vendors 22 give back to us to show that they'have met the'E specs. ='
i
- 23 -
I looked at~ that entire hierarchy of design 24 documentation as-that required to show an adequate-25 design.
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f 1 Karrasch ' 330 0 2 Q Did anyone'ever' explain to you what "a 3 significant deviation < f rom perfornian~ce specifications" 4 meant? - ,-
i
( 5 A I don't recall. ,
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'l 1
6 Q Did you ever have any insiruct. * ' ' '
ion ' that took 7 you step by step through the~B & W procedu j e for o,
8 processing safety 1conceirns?
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~f 9 MR. FISKE. I don't quite,undar.jtand 10 what you mean by stop by step. Is that a ,
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12 MR. SEI'IZE R : Or paragraph by p nragr,aph, ,
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'y 13 heading by heading. '
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' #p 14 A I recall' training sessions which wr/re conducted
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15 for all the employ'ees at NPGD to infor:af9them .t,h at the ,
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-4' 16 procedure was in, place, to give them a generh1 overview
- y , i i 17 of.the intent o f 'the pro ced'ure',And to g'o ,tihrough the i ;!
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' t 18 step-by-step process which 'iP outlined on Exhibit A. .,
e y
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23 A Y e s ,. s'i r , I did., ' '[ , p. h p l . p' 4 Q Did you takepyour l* i respc asibilitiel,s;.
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1 the. preliminary. safety concdrn p'/rocedure dEriously?)-
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1 Karrasch 331 l 2 A Yes, I believe I did.
, 3 "7 Q Why?
. 4 A I was very much involved in the entire process
(- 5 f design and analycis of safety systems for B & W 6 plan's.
t I understood the importance those safety 7 systema' play in the safe operation of a plant.
8 I felt, and I still do, that a mistake made 9 in the.. design process should be corrected.
. 10 Q You said you were very much involved in 11 safety system design.
12 Did that include emergency or cooling
..(~h mi) 13 systems?
14 A Plant integration prepared the system requirements 15 f r the Emergency Core Cooling Systems.
16 Q Were you concerned that the Emergency Core Co ling Systems should function so that't,here was not
~
17 18 core uncovery and fuel melting?
i A
~
19 My understanding is that the system design analysis
- l '
20 which was performed related to Emergency Core Cooling 31 Systems was done to show that they would show results
.d! (.
22 which fell within the limits of the NRC ' design i
23 criteria.
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24 Q Did you understand that there were any
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25 NRC design criteria directed at effective core cooling?
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1 Karrasch 332 O)'
2 A I am not specifically aware of the criteria but 3 I understood that they did exist.
4 Q Did you understand that the NRC had design ,
(( , 5 criteria to insure that there was not substantial 6 melting of the fuel cladding?
7 I am not asking you whether you can recite 8 the regulation, I am just asking you whether you were 9 aware in 1978 that the NRC imposed design criteria 10 that were intended to prevent substantial rupturing 11 of the fuel cladding.
12 A The only thing I recall about the design 13 criteria is that it imposed a cladding temperature 14 limit.
15 Q 2100 degrees Fahrenheit or 2200 degrees 16 Fahrenheit?
17 A I believe the number was 2200 degrees Fahrenheit.
18 Q Is it your understanding that the melting 19 point of zirconium alloy fuel cladding is above 2200 20 degrees?
, 21 A Yes, that is my understanding.
k_ !
22 Q on any of the occasions when you read Don 23 Ha11 man's memo,GPU Exhibit 80, prior to the Three Mile O)
( 24 Island accident, did it ever occur to you that his l
25 raising the possibility of possible uncovering of the l I
l i
l
I 1 Karrasch 333 2 nuclear core raised a safety concern?
3 MR. FISKE: You mean a safety concern in 4 the context as that term is used in the TPSC
({ 5 procedures?
6 MR. SELTZER: Right.
7 MR. FISKE: Do you understand the 8 question, Mr. Karrasch? i 9 MR. FISKE: Off the record.
10 (Discussion off the record ()
11 MR. SELTZER: I will restate the question.
12 BY MR. SELTZER:
13 Q When you got GPU Exhibit 80, Don Hallman's 14 memo and at any time that you read it beEore the 15 Three Mile Island accident, did it ever occur to you 16 that his description of the possibility.of uncovering 17 the nuclear core raised a safety concern '-within the 18 rubric of B & W's preliminary- safety concern procedures?
19 A No, it did not occur to me.
20 Q Did it ever occur to you that the 21 possibility of uncovering the core which Don Hallman 22 described and which Bert Dunn-had described in his 23 February 1978 memoranda raised a safety concern (y
(_,) 24 -within the context of B & W's preliminary safety P,5 concern procedures?
I l
l l
I 1 Karrasch 334 v
2 A No, it did not occur to me. ;
3- Q I would like to show you GPU Exhibit 95 4 which is aB & W policy and procedure relating to the
( 5 reporting of defects and non-compliance concerning 6 safety, (10CFR21).
7 (Handing document to the witness.)
8 Is GPU Exhibit 95 a copy of a document 9 which you received in or about December 1977?
10 A I do not recall receiving or reading this 11 document.
12 Q Do you maintain a binder of B & W policies 13 and procedures?
14 A The policies and procedures are maintained by 15 the Administrative Services Section at B & W.
16 Q Did you have an administrative policy 17 binder in the Plant Integration Section?.
18 A Yes, there was one set of procedures for the 19 entire section.
20 Q When additions were made to that set of 21 procedures,:were copies of the new edition sent to you?
22 A No, they were not.
23 Q Will you turn to the attachment to GPU 24 Exhibit 95 marked for identification, please?
25 Have you seen a copy of 10CFR Part.21
1 Karrasch 335 2 of the type and form attached to GPU Exhibit 957 3 A I have not seen a copy of this type and form 4 of Part 21.
Q In other words, you didn ' t have a copy of
( 5 6 this posted anywhere in or around the Plant Integration 7 section?
8 A That is correct.
9 Q Will you take a look at the last page of 10 GPU Exhibit 95. g 11 Have you seen a copy of that during the 12 time that you were head of the Plant Integration O '
13 Section?
14 A I don't recall.
15 Q I take it then you don't have any 16 recollection that this was posted anywhere in or near 17 the Plant Integration Section, is that ~ right?
18 A I just don't remember one way or th'e other.
19 Q You don't recall anywhere specifically 20 that it was posted, do you?
21 A I do not remember seeing it posted.
22 Q Was there any particular manager at B & W 23 whom you understood had principal responsibility for implementing B & W's obligations under 10CFR Part 21?
.( 24 25 A My understanding was that the Manager of
=t- y ( T
1 Karrasch 336
/3 V 2 Licensing had primary responsibility.
3 Q Who was that?
. 4 A To the best of my knowledge, Jim Taylor was
( 5 Manager of Licensing in 1978.
6 Taylor has been head of Licensing for at
, Q 7 least the last seven or more years, hasn't he?
8 A I don't recall when Mr. Taylor was given that 9 position.
10 Can you recall any other Mknager 'of Q
11 Licensing?
12 A Yes.
d 13 Q Who?
14 A I recall Mr. Ken Shurke was Manager of Licensing 15 sometime ago.
16 Is it your understanding that in 1977 Q
17 and 1978 and 1979 Jim Taylor was the Manager at B & W 18 principally responsible for implementing B & W's 19 preliminary safety concern procedures?
20 A Yes, I think that is correct.
21 Q Are you aware that the-NRC issued a 22 citation against the Babcock & Wilcox for failing, 23 according to the NRC, to' take proper action with f.
A 24 regard to the Dunn recommendation?
25 A- I recall some discussion about such a citation l
l
1 Karrasch 337
<^s -
U 2 over a year ago.
3 I was not involved in the B & W response 4 to that citation.
( 5 Q Among whom was the discussion?
, 6 A I guess it would be more accurate to say I recall 7 hearing about it.
8 I do not recall the specific discussion.
9 Q Other than Dunn, Womack and Kelly, have you 10 had any discussions with anyone else regarding the 11 failure of B & W to send out the guidelines recommended 12 . by Dunn prior to the Three Mile Island accident?
C\ '
13 A I don't recall discussing the failure of B & W 14 to send out the guidelines with Dunn, Womack and Kelly.
15 Q Have you had a discussion with anybody 16 about the fact that B & W never sent'out the Dunn 17 recommendations before the Three Mile Island accident?
18 A The only discussions I recall are the depositions 19 and testimony in front of Rogovin and Kemeny and this 20 deposition which is underway now.
21 Q Is it true that to the best of your 22 knowledge B & W never did send out the guidelines
- 23 proposed by Bert Dunn prior to the Three Mile Island i I\ og accident?
l.
V
- l 25 MR. FISKE: Off the record.
L l
~
1 Karrasch 338 2 (Discussion off the record.)
3 Q If it would help you to take a look at 4 Dunn's recommendat ions as set forth in GPU Exhibit 79, 5 feel free to.
(
. 6 Would you lika to?
I 7 (Handing document to the witness.)
8 A I am only aware of the information I have g gathered during the Kemeny Commission and Rogovin 10 Commission hearings. t 11 I really don' t know for sure whether or not 12 B & W took any action.
s' 13 Q Mr. Karrasch, don't be so anguished. I am 14 not searching for things that are not within your 15 knowledge, so when I ask you do you know whether B & W 16 sent it out, I am just asking whether you have ever seen 17 a memorandum or sight instruction that you know went ,
18 .out before the Three Mile Island accident"containing l
l 19 Dunn's prescription or, did anybody ever t' ell you, "We 1 20 sent that bloody thing out, I don't knew why they didn't 21 . get it"?
L 22' Did you ever hear or see evidence that the 23 Operating guidelines proposed'by Dunn in February 1978 were sent by B & W to the operating utilities prior to
[~)T N_
24 25 the Th re e Mile Island accident?
L _
__ _ _ _ _ _ _ _ _ _ _ - - - --_---__------_--------------------------J
1 Karrasch 339
[)
~
2 A I do not recall seeing an instruction of that 3 nature to our customers before Three Mile Island.
4 Q Has anybody ever told you that such an instruction had been sent out?
( 5 6 A No, sir, I have never been told that such an
,4 s'
7 instruct on had been sent out.
8 Q Is it correct that you have had discussions 3 9 with Dunn, Womack and Kelly regarding your role in the 10 handling of Bert Dunn recommendations (or operation of 11 high pressure injection?
12 A I recall discussions with Womack, Kelly and Dunn A
k-) 13 about the action that I took on Mr. Ha$1 man's g4 memorandum to me. .
15 Q Did you have discussions with anybody else 16 regarding your role in handling anything relating to 17 Bert Dunn's recommendations on how to operate high 18 pressure injection?
19 A Again, the only other discussions I recall were 20 related to inquiries by the Kemeny'and Rogovin Groups.
. 21 Q Did , John MacMillan ever talk to you about l 22 your role in this matter?
23 'A No, sir, he didn't.
() 24 Q Have you ever talked to John MacMillan 25 about anything?
. 1
-l'
1 Karrasch 340
/#'N d 2 A Yes, I have.
3 Q Have you talked to him since the Kemeny 4
Commission hearings?
MR. FISKE: You mean about anything?
( 5 6
MR. SELTZER: Right.
7 A Yes, I have.
g Q Has the subject of the Dunn memorandum and g your role in handling Dunn's recommendations never 10 came up in those conversations? ,,
11 A No, sir, it did not.
12 Q Has anybody at B & W ever expressed 13 criticism to you of your handling of Don Hallman's 14 memo,*GPU Exhibit 807 ;
15 A No, sir, they have not.
16 Q Has anybody ever told you in words or 17 substance that you should have handled Don Hallman's 18 memo quicker?
19 A I recall Dr. Kemeny --
20 MR. FISKE: You mean people at B & W, gg don't you?
L 22 , He means people at B & W.
23 A No.
I 24 Q Has anybody at B G W ever said to you in 25 w rds or substance that'you should have done a more ,
)
l
1 Karrasch 341 Cs N],
2 effective job of following up on your purported 3 assignment to others to work on Don Hallman's memo?
4 A No.
5 Has there ever been an investigation
( Q 6 conducted at B & W other than by lawyers to determine 7 why the Dunn recommendations were not sent out before 8 the Th re e Mile Island accident?
e 9 A I am unaware of any such investigations.
10 Q Where did you meet with Allen Womack when 11 you discussed your role in the Dunn-Hallman matter?
12 A To the best of my recollection it was in his d 13 office.
14 Q Had he called you in as you understood it 15 specifically to discuss your involvement in that matter?
e 16 A I recall that it came up when we were discussing 17 another matter. .
18 There was not a specific meeting for that 19 purpose.
20 Q Who initiated the discussion of the Dunn-21 Hallman matter?
22 A I don't recall.
23 Q How long did you and he discuss the Dunn-(v) 24 Hallman matter?
25 A I don't believe it was any longer than several
y Karrasch 342 0 2 minutes.
Q As best you can recall, what did you say 4
to him and what did he say to you?
( 5
- * ^
yourself in such a hearing.
- "
- 9 "" * * ""I **
g 7 Q What do you mean by "such a hearing"?
A In giving testimony under oath. I had never 8
g done it before and as I best recall Allen's advice to 10 me was " Listen carefully to the questigns and answer g them truthfully."
12 I then briefly related to Allen the action O 1, that I hae tak.n on r. ha11 man.s memoraneum to me.
g4 Q What did you tell Dr. Womack?
A I told him that I recalled receiving Don's letter, 15 16 that I recalled pasaing it on to either McBride or g7 Swanson for action, that I recalled several follow-up 18 conversations with Mr. if allman during the' fall of 1978, gg that I recalled taking action on the letter myself in
- I '
- 20 g I think that was the extent o f 'the nversation. It was very brief.
22 23 Q As r after you related those events to Allen Womack, what did he say to you in words or
[: q Substance?
l l
i Karrasch 343 l O 2 A I don't recall a response from him at all.
3 Q Was he still your boss at the time you had 4 this conversation?
( 5 A Yes, sir, he was.
6 Q Where did you and Bert discuss your role 7 in the Dunn-Hallman affair?
8 A I don't recall for sure.
9 Q Was it a faca-to-face meeting?
10 '
A Yes, it was.
11 Q Had the meeting been arranged in order to 12 have this discussion?
13 A No, sir, it was not.
14 Q Approximately how long did you and he 15 discuss your involvement in the Dunn-Hallman affair?
16 A It was just for several minutes.
17 Q Did Bert say anything to you about what had 18 impelled him to write the memoranda which he had in 19787 19 A No. As I best recall bert asked me what action 20 I had taken on Mr. Hallman's memo and I told him 21 essentially the same thing that.I told Dr. Womack. i 22 That was the extent of my conversation with i
l 23 ' Bert to the best of my recollection. '
b)
(_ 24 Q~ Did_you ask Bert any. questions?
25 ~A I don't recall.
er- e+ + , -- -w --- e
1 Karrasch 344 i
2 Q Have you ever had any other conversation 3 with Bert Dunn regarding the guidelines which he drafted 4 for improving the procedures for operator termination
( 5 of high pressure injection?
6 A No, sir, I don't think I have.
i 7 Q Since the Three Mile Island accident, you I
8 have worked and traveled together with Bob Jones of l
9 the ECCS Analysis Unit, haven't you?
10 A Yes, sir, I have. (
11 Q Do you get along well with Jones?
12 A Yes.
13 Q Have you ever discussed with Bob Jones 14 anything relating to the Dunn-Hallman-Karrasch matter?
15 A I don't recall any discussions with Bob Jones en 16 this matter.
17 Q Where was your conversation with Joe Kelly l
18 on this matter? }
19 A I am pretty sure my conversation with Joe was in 20 his office.
21 Q How long did it last?
22 A Very briefly. No more than several minutes.
23 Q Who initiated the discussion of the Dunn-
)
%/ 24 Hallman-Karrasch affair?
l 25 A I did.
1 Karrasch 345 2 Q Why?
3 A As I best recall Bert had told me that there 4 was a series of memos leading up to Mr. Hallman's memo
( 5 to me. That happened in the conversation that I alluded 6 to earlier with Bert.
7 I then went to Joe who worked for me and 8 asked him for a copy of the five memos so that I could 9 review them. So, I went to see him.
10 Q Did he know what five memos you were 11 -referring to?
12 A Yes, he did.
O 13 Q Did he have copies of them ready to hand 14 to you?
15 A I believe he had one copy and he agreed to get 4
16 me a copy himself.
17 Q How had Joe Kelly, if you kno.w, obtained 18 copies of all five memos?
19 A I do no t know.
20 Q Let me show you GPU Exhibit 76 and ask you 21 if this memo from Kelly to distribution is one of the 22 five memos that you were just referring to?
23 (Handing document to the witness.)
(n) 24 A Yes, it was, to the best of my knowledge.
25 Q After you got this memo from Joe Kelly
- m -w --y
1 Karrasch 346
'o 2 you read it, right?
3 A Yes.
4 Q After reading it did you recall at that time that you had previously received a copy of GPU Exhibit
( 5 6 767 7 Let me be very clear what I am asking you.
8 I am not asking you today whether you recatl getting 9 GPU Exhibit 76 on or about November 1, 1977, I am l
10 asking you whether when you obtained a! copy from Joe l
11 Kelly after the Three Mile Island accident and read l
12 it, did you then recall that you had previously 13 received a copy of GPU Exhibit 76?
14 A No, sir, I did not then recall receiving a copy 15 of GPU Exhibit 76.
16 Q About when in time did Joe Kelly give you i
17 a copy of GPU ?xhibit 76 and the other fo,ur memos that 18 are part of this Kelly-Dunn-Hallman-Karrasch scenario?
19 A I believe I received the five memos'from Joe very 20 shortly after my return from vacation in July of 1979.
. 21 Q When you read GPU Exhibit 76 in July of f' 22 1979, did you understand all of it?
23 A I believe I understood it in a general way, yes.
(A) s_-
24 Q Were you aware that the September 24, 1977 s
25 Toledo event that is referred to was an event at the
"^
1 Karrasch 347 O~ 2 Davis-Besse I nuclear plant designed by B & W?
A The first p tagraph of the letter told me that 3
4 so I was aware of it after reading the letter.
( 5 Q Y u knew that Joe Kelly had been sent from 6 y ur unit out to Toledo Edison to investigate the 7 events relating to the September 24, 1977 transient 8 shortly after that transient occurred, right?
9 A I don't recall connecting up that situation with 10 the incident as described in this memo.
11 Q I wasn't asking for the nexus, I was just 12 asking, you knew, did you not, that Joe Kelly had been 13 sent from your unit out to Davis-Besse to investigate 14 the events relating to the September 24, 1977 transient 15 and that he had been sent shortly after the transient?
16 MR. FISKE: 'I think what Mr. Karrasch 17 said was he didn't connect that wit,h the 18 transient referred to in the memo. ~
19 MR.-SELTZER: I thought he was saying 20 he didn' t make that connection when he read the 21 letter.
23 A When I read this letter I didn't then know thac 24 that was the transient that Joe had gone out to study 25 at the Davis-Besse plant.
Karrasch 348 1
G U 2 You knew that Joe Kelly had been sent out Q
3 in the fall of 1977 to study a transient at Davis-Besse, 4 didn' t you?
(f 5 A Yes. I was involved in sending him.
6 Q What do you mean you were involved?
7 A I was asked permission for him to go and I gave 8 that permission.
9 Q You were asked permission for him to go 10 and do what? t i
11 A Assist Toledo Edison in evaluating a reactor trip 12 which had occurred.
[~
13 Q Did you ever discuss the contents of GPU 14 Exhibit 76 with Joe Kelly?
15 A No, sir, I do not believe that I did.
16 Q will you take a look at the first paragraph.
17 There is a sentence about two thirds of the way down t
18 that begins with the words "As a result." Do you see 19 that?
20 A Yes.
21 Q That sentence reads, "As a result the 22 transient continued on with boiling in the reactor l
23 cooling system," et cetera, et cetera.
() 24 when you read this document, did you 25 understand that boiling in the reactor coolant system 4 - e
1 Karrasch 349 O 2 meant that the water in the reactor coolant system 1
3 had reached its saturation temperature?
4 MR. FISKE: You are talking now about this
( 5 period of time sometime in July of 19797 6 MR. SELTZER: Right.
7 A That is my understanding of the onset of boiling, 8 yes.
9 Q The preceding sentence says "The operator 10 stopped high pressure injection when pressurizer 11 level began to recover, without regard to primary 12 pressure."
13 What did you understand again at the same 14 time in July of 1979 the concept meant of " Pressurizer 15 level began to recover"? What does that mean?
16 MR. FISKE: What did that mean in July 17 of 19797 -
18 A That-meant the pressurizer level began 19 increasing after an initial decrease.
20 Q In other words, the level of water in the 21 presurizer was being restored to its normal operating 22 level?
23 A Yes, _it was increasing back to its normal l
I
(
(~)% 21 operating level.
25 Q Is that the point at which you understood
1 Karrasch 350
(~)'\
\_
2 from GPU Exhibit 76 that the Davis-Besse operators 3 shut of f or terminated the high pressure injection into l
4 the Davis-Besse reactor coolant system?
( 5 A Yes.
6 Q It says in that same sentence that they 7 took that action "without regard to primary pressure. "
8 What did you understand that meant when 9 you read GPU Exhibit 76 in July of 19797 10 A That the operator did not look at primary pressure 11 nor did he look at primary temperature to assure he l 12 had a subcooled reactor coolant system.
13 Q Your man Kelly says in the second paragraph, 14 the first sentence, "Since there are accidents which 15 require the continuous operation of the high pressure 16 injection system, I wonder what guidance, if any, we 17 should be giving to our customers on when. they can 18 safely shut the system down following an accident."
19 At the time you read this in July of 1979 20 did you understand that there are accidents which
, 21 required the continuous operation of the high pressure
(, .
22 injection system?
23 MR. FISKE: You mean did he understand (J
24 in 1979 that there were accidents which would 25 require the continuous operation of HPI?
1 Karrasch 351 l'
N.) 2 MR. SELTZER: I think you have just 3 exactly parroted my question.
4 MR. FISKE: Yes, I know. That's what
(( 5 I hoped I was doing.
6 MR. SELTZER: I don't mind the echo 7 as long as --
8 MR. FISKE: I just --
9 MR. SELTZER: As long as it doesn't confuse 10 the witness to hear two people say the same thing.
11 MR. FISKE: It just confirms that my 12 understanding of the question is correct.
13 A I understood at the time I read this memo that 14 there are accidents which require operation of the high 15 p re s sure injection system to replenish lost reactor 16 coolant fluid during a small break LOCA.
17 Q Did you also understand from.the first 18 sentence of the memo where Kelly says "Perhaps we are 19 not giving our customers enough guidance on the 20 operation of the high pressure injection system," and 21 from the first sentence of the second paragraph where 22 he says "I wonder what guidance, if any, we should be 23 giving to our customers," that Joe Kelly was raising n
' l jl 24 a question in this memo about whether further guidance 25 should be given to Babcock & Wilcox cus,tomers regarding l
.i
I Karrasch 352 O
2 tha operation of the high pressure injection system?
3 MR. FISKE: Do you remember?
4 The question again is:
(' 5 Does he remember what his understanding 6 was in July of 1979?
7 MR. SELTZER: Yes.
8 (Continued on page 353.)
9 10 g 11 12 13 8
, 14 l 15 16
' 17
~
m i 18 i 19 i 20 91
~
l( 22
. 23 24 1
25
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, y-._ ,,e-- _ , - ,---..in.+. ,, -,--%. ,,,,,mm,r _
l g Karrasch 353
(,.J .
2 BY MR. SELTZER:
3 Q Did those sentences impart to you a 4 meaning that Kelly was asking the question whether
( 5 further guidance should be give n to operators on when 6 they can safely shut the high pressure injection system
- 7 down?
8 A Yes. I think the second paragraph states what 9 Joe was asking the distribution list"to think about.
~
g 10 o.K. (
11 What does the last sentence in the memo
.12 say?
O 13 A It says, quote, I would appreciate your thoughts 14 on this subject, close quote.
15 Q Rave you ever given Joe Kelly your 16 thoughts on this subject? .
17 MR. SELTZER: Off the record.
18 (Discussion off the record.)
19 A I do not recall.
20 Q You don' t recall eve r giving him your 21 thoughts on this subject; is that right?
22 A I don' t know whether I did or not.
23 Q All right.
.( )- 24 A I do not recall.
d 25 ,, Q You can't recall a specific conversation
1 Karrasch 354 2 that you had with Kelly in which you gave him your 3 thoughts on this subject, do you?
4 A No, sir, I cannot recall one.
g 5 Q You said that your routine method of 6 reading mail that comes into your office was to look 7 through it and see if it called for any action on your 8 parts is that right?
9 A Yes, I think that is correct.
10 Q When you read GPU Exhibit 7.6 in July of 11 19 79 did you recognize that it called for action on 12 your part?
13 MR. FISKE: Well, I am going to object 14 to that, Mr. Seltzer. I don't think whether 15 he thought in 1979 that had called for action 16 on his part is relevant to this at all.
17 MR. SELTZER: 0.K. ,
18 MR. FISKE: This is two months' af ter the a
19 accident. He was obviously not reading it at that 20 Point for the purpose of deciding whether or not 21 he had to respond to the me mo . He was reading 22 it in terms of being prepared for his Kemeny 23 testimony.
24 So, I didn't object to the other 25 questions in terms of his understanding of what-
,,...m.,- ...
i l
1 Karrasch 355 2 the content of the memo was, but I think in 3 terms of the question relating to the last 4
sentence, the only relevant question is what
( 5 did Mr. Karrasch under' stand when he received 6 the memo in 1977, if he received it.
7 MR. SELTZER: He has already testified 8
that in all probability he did receive it.
9 MR. FISKE: We don't have to go back 10 thro ugh that and rehash the testimony.
11 MR. SELTZER: "All probability," that 12 means it is 100 percent likely, in all bi
\~/ 13 probability he received it." _
14 So let's proceed with his sworn 15 testimony that in all probability he received 16 it.
17 MR. FISKE: Mr. Seltzer, I am not 18 quarreling with you as to what the prior 19 testimony is; it is all in the record.
20
.All I am saying is, the only relevant
'21 time period for the question that you just put 22 is 1977, not 1979. It is totally irrelevant 23 whether he thought in 1977 --
j ) 24 MR. SELTZER: Totally irrelevant?
25 MR. FISKE: Yes, whether he thought in
1 Karrasch 356
(' -
\# 2 1979 Mr. Kelly was then asking him fo r his 3 thoughts. This is two months after the 4 accident.
( 5 MR. SE LT ZE R: I am not concerned with the 6 silly question that you are suggesting that-7 Kelly is asking for his thoughts in July 1979.
8 I am asking him whe ther when he read this in 9 July of 1979 he understood that this Nove mbe r 1, 10 1977 memo was a nemorandum which, sought some i
11 action from Mr. Karrasch.
12 MR. FISKE: Yes, and that is my -- I 4
g-w)
\_ , 13 understand that is what you are asking.
14 MR. SELTZER: Your objection is noted.
j 15 BY MR. SELTZER:
4 16 Q Will you answer the question, please?
i 17 MR. FISKE: If you can.
18 A Joe is asking the people on distribution if they 19 would give him our thoughts on the subject.
20 Q Including your thoughts , right?
i 21 A Yes.
22 Q And giving somebody your though'ts is 2j taking some action; right?
, .fN 24 A Yes, I believe that is right.
'd ,
3.
i
~ 25 Q I would like to show ' you GPU Exhibit 7&
i
' v. (
\1
- 5. :N r.;
+
. _ _ ._. - -~
p._ .
1 Karrasch 357 O
\) 2 for identification, which is Bert Dunn's now famous 3 memo on operator interruption of high pressure 4 injection, February 9, 1978.
( 5 (Document handed to the witness.)
6' If you would like to take an opportunity 7 to rcread it, please do.
8 A Yes.
9 Q. Did you ever delegate to anyone else the 10 responsibility of responding to Joe Kel,1y's 11 November 1 memo, GPU Exhibit 76?
12 A I don' t recall.
(~)' s
\l 13 Q You don't recall anybody to whom you gave 14 that re sponsibility?
15 A I don't recall receiving the memo nor delegating 16 my action on the memo.
17 Q Af ter you got GPU Exhibit 78' Nrom Joe 18-Kelly in July of 1979,,you read it, right?
19 ,
I' A s Yes, I did.
20 , Q Did you read it with the anticipation i
21 ' that you might be questioned on its contents by the i
22; , staff and members of the Kemeny Commission?
' ~
-l
23- A Yes, I did.
.- 24 Q Did you know that your name is on the 25 distribution list?-
,[ '
.. ., IT a
' 8
' vg .
. - = - -- -
1
/
1 .Karrasgh j358
- ' / '
.L.p] '
- ,/
2 A Yes. .
3 Q Did you make any e f forta tejlocate any ,
4 other copies of GPU Exhibit 78 in'your files?
i
({ 5 A Yes.
- 6 What did you de'to look for>it?
Q 7
~
A I have a few number of; flies which are -
8 identified by the high-priority subjects which I am 9 working on.
10 '
Q You didn't find this memo in any of those 11 files? -
12 A No, I did not.
7_ ,
N_ 13 Q Is it fair to conclude that if you got a 14 copy of GPU Exhibit 78, you didn't keep it?
15 A I did not find it in my files; therefore,- I did 16 not have it.
17 Q When you read GPU Exhibit 78 in July of 18 1979 did you unde rstand all of it?
19 A I unde rs tood - it in a general sense, yes.
20 Q In the second paragraph, the sixth line, l
21 the re is a reference to the reactor coolant system L 22 being in, quote, a two-phase state, unquote.
23 What did you understand "two-phase state"
( 24 meant?
25 A "Two phase" to me means that there is a l
u a
19 Karrasch 359
.9m .
) '.. 2 combination of liquid and steam.
3 Q Those are two o the three phases in which 4 water can' exist; is that right?
5 A
({ .;res. -
6 Q Turning to the last sentence of the second 7 paragrapb, Bert says, "Had this event occurred in a 8 reactor,at full power with other than insignificant 9 b urn up,,i t is quite possible, perhaps probable, that h
^
10 core uncovery and possible fuel damage twould have 11 resulted."
l2' Do you see the words, " insignificant O\ 13 -
, , b ur ti up " ?.
~
14 A Yes, I do.
i 15 Q What did that phrase mean to you in July
[ ,
16 of 19797 17 A It meant that the fuel had not be$n. operated 18
, in the reactor for a very long period of time.
s 19 Q What did you understand was the 20 significance of that in the context of this sentence?
21 A That would imply that the decay heat level of
.(. 22 the f uel af ter a reactor trip is at a low value.
- 23 Q Even after a reactor has been completely
(~)-
LJ .
24 scrammed, it continues to generate decay heat, 25 doesn't it?
1 Karrasch 360 2- A Yes, it does.
3 g Is the amount of decay heat generated
, 4 directly proportional to the quantity of radioactive 5 fission products that are available in the core?
(
j 6 A I don' t know if there is a direct relationship 7 between the decay heat level and the quantity of 8 fission products .
9 Q What is it that produces decay heat?
10 MR. FISKE: You are talking about his ,
11 . unde rstanding when?
12 MR. SELTZER: In 1978.
13 . Q Radioisotopes?
- 14 A My understanding is that decay heat is produced 15 as a result of the fissioning process .
16 I don't recall today exactly which part
~
17 of that process causes the decay heat. ,
18 Q Why is decay heat greater in a reactor 19 that has been running for several months than in a 20 reactor that has had insignificant burnup?
21 MR. FISKE: Again you are asking about
(~ 22 his understanding in '787 L 23 MR. SELTSER: Right.
A I')h
\-
2t Q 1978, when you were the top dog in Plant l
25 Integration.
i--
1 Karrasch 361
\_
2 A If the decay heat is a result of the fissioning 3
p roce ss , I would conclude that the longer the 4
tissioning process goes, the greater the decay heat
( 5 level would be.
~
6- Q Bert also said that if the Toldeo event 7 occurred in a reactor at full power, that would have 8 made it quite possible, perhaps probable, that there 0 would be core uncovery and possible fuel damage.
10 What was your understandind,in 1979 when 11 you read this about the effect of lower versus full 12 power on the probability of core uncovery and fuel
(^N k- 13 damage?
14 A At higher power levels -- let me s tr. rt that 15 ove r, please.
16 If the reactor is run at a higher power 17 level, the decay heat following a reactor. trip will 18 be higher. It is a direct relationship.
19 Q So if the power level is ten times 20 greater, the decay heat would be ten times greater?
21 A I don' t know if it is a one-to-one relationship.
22 Q Was there anybody in your Plant 23 Integration Group in 1978 who would have known that?
(O
%d
- 24 A Yes.
-25 Q Who?
.. . ._ - ._ = . __ .- - -..
f
. I KarrASch 362 2 When you said "Yes," whom were you thinking 3 of?
4 A I was thinking of some number of the engineers that worked day in and day out with the analysis in
- ([ 5 6 the fuel and the safety analysis of the core.
7 I don't know for sure that they would know 8 that relationship.
9 Q But there are a lot of people that you 10 could have gone to in your unit in 1978 to find out 11 the answer, right?
12 A I would say that is correct.
O 13 Q When you read the last sentence of the 14 second paragraph of GPU Exhibit 78 in July of 1979, 15 were you aware of any facts which caused you to question J
16 the accuracy of what Bert Dunn had said in that 17 sentence? .
18 A I do not recall questioning the accuracy of 19 what Bert Dunn said in that sentence.
20 MR. SELTZER: Off the record.
21 (Discussion off the record.)
22 (Recess taken.)
23 BY MR. SELTZER:
( 24 Q When you read GPU Exhibit 78 you knew that 25 Bert Dunn was writing about a concern regarding-w w
1 Karrasch 363 3
($) 2 operator interruption of high pressure injection, 3 right?
4 , ME. FISKE: This is in July of '797 5 MR. SELTZER: Right.
((
6 A Yes.
7 Q You understood that Dunn was concerned 8 that the operator interruption of high pressure 9 injection could lead to core uncovery and possible 10 fuel damage, right? L 11 A That is right.
12 Q You knew that Dunn felt that this was a
[~h
\2 13 matter of serious concern?
14 A I believe Bert stated that in the last sentence 15 in the letter, yes.
16 Q He also stated it in the first sentence, 17 righ t? .
18 A That is right.
19 You understood at the time you read this Q
20 in July of.1979 that Bert Dunn believed that this 21 matter deserved prompt attention and correction at j 22 B & W, right?
23 MR. FISKE:. I have the same objection
(~h
-(_j 24 to the question that I had with respect to the 25 .last sentence in the Kelly memorandumsbeing
Karrasch 364 1 1 t
2 totally irrelevant.
l
, 3 MR. SELTZER: Right.
l 4 BY MR. SELTZER:
5 You may answer.
(( Q 6 A The words state that Bert believes this matter 7 deserves prompt attention and correction.
8 I read the words.
9 Q And you knew that he was expressing the 10 thought that it deserved prompt attention and 11 correction by B & W, right?
12 A I would assume that, yes.
13 Q When you got a copy of GPU Exhibit 78 14 from Joe Kelly, did seeing it then refresh your 15 recollection that you had previously received a copy 16 of this memo?
17 A No, sir, it did not. ,
18 Q Can you recall any person to whom you 19 directed GPU Exhibit 78 for attention and'correcticn 20 prior to the Three Mile Island accident?
, 21 MR. FISKE: You mean other than the
\.
22 people who already received copies of it?
23 MR. SELTZER: Oh, I would be thrilled
. v I) 24 if he directed it to those people.
25 MR. FISKE: You mean the second time?
in - . . . - -
m __._____=._m__
1 Karrasch 355 2 MR. SELTZER: I am asking whether 3 Mr. Karrasch personally directed GPU Exhibit
- 4 78 to any person.
l[ 5 A I neither recall receiving the memorandum nor 6 directing it to somebody else for action.
7 Q Swanson and Kelly are both marked for 8 copies of GPU Exhibit 78, do you see that?
9 A Yes, I do.
10 Q They were both in your Plant Integration
. 11 Unit in 1978, weren't they?
12 A Yes.
13 Q Is it your understanding that in 1978 1
14 there was either a spoken or unspoken agreement 15 among people in your unit that you would not discuss 16 the concern over operator interruption of high 17 pressure injection? .
18 MR. FISKE: Wait a second. Can I hear 19 that question again, please?
20 (Record read.)
21 MR. FISKE: Mr. Seltzer, Mr. Karrasch 22 testified that he doesn't recall being aware 23 of a concern about interruption of high A
24 pressure injection in 1978.
(}
25 MR. SELTZER: I don't think he has
~
1 Karrasch 366 O
V 2 testified to that at all. In fact, he claims 3 although there is absolutely no evidence to 4 support it, that when he got Hallman's memo
( 5 in 1978, he sent it to somebody, although 6 nobody will admit he sent it to 7 them to take action on it. I don't think 8 that shows no-concern.
9 MR. FISKE: I am sorry, you are referring 10 to the period of time in August?'
11 MR. SELTZER: I am talking about all 12 1970. The calendar year 1978.
O 13 MR. FISKE: Well, go ahead anyway. I 14 am sure you can answer the question.
15 will you read it cae more time?
16 (Record read.)
17 MR. FISKE: I will object't,o the form 18 of the question.
19 That means you are allowed to answer.
20 A I am quite sure there was neither a spoken 21 or an unspoken agreement of that nature.
22 Q Did people in your unit discuss things
! 23 in 1978 that concerned the design of nuclear plants?
() 24 A Yes, sir, they did.
25 Q Did they discuss among themselves matters l
l 1 Karrasch 367
[)
~
v 2 involving the operation of nuclear plants?
3 A Yes.
4 Q Yet on this subject of operator interrupcion of high pressure injection where you,
( 5 6 Swanson and Kelly r.re all copied on Dunn's two memos 7 and y u claim that you may have asked Art McBride to 8 function on it, nobody has mentioned anything to one 9 another o rally about the subject of operator 10 termination of high pressure injection?
11 MR. FISKE: I object to the form of 12 the question.
O 13 Q Is that your testimony?
g4 A I do not recall any discussions in my unit 15 where I was involved on the subject of operator 16 interruption of high pressure injection in 1978.
17 Q I would like to call your a'ttjention to
~
18 testimony which you gave before the full Kemeny
, 19 Commission, in particular I would like to ~ call your 20 attention to a question asked by Commissioner 21 Peterson on page 257 beginning at line 9.
I 33 l (Handing transcript to the witness.)
23 Q Commissioner Peterson asked you "My.
(f 24 question is could it be that-all of the atomic. energy 25 industry's efforts to tell everyone how safe nuclear
1 Karrasch 368 2 energy is could have provided a mind set so it kind 3 of downgraded any threats to safety and give priority 4 instead to fulfilling some requests of the Nuclear
( 5 Regulatory Commission."
6 Mr. Karrasch answers I 'hink so. My 7 carlier remarks on shifting now our priorities, I 8 think answer that question."
9 BY MR. SELTZER:
10 Q Were you asked that questian and did you 11 give that an swe r?
12 MR. FISKE: Wait a second, Mr. Seltzer.
~h
- (V 13 I think if you are going to read his answer 14 you might as well read the whole thing.
15 Q You continued to say, "We have been 16 studying, for many years, and spending many millions 17 of dollars in analysis and design of those features 18 of a plant which are very, very improbable. And we 19 have been designing -- and these are the major events 20 which are documented in the safety analysis reports.
21 We haven't really thought much about the operator 22 _and his role, because we've been designing the systems 23 to automatically _ keep the plant safe for those very y ,) 24 unlikely events. And when I talk about changing 25 priorities, I believe what I really mean is that
Karrasch 369 2 the emphasis should now be changed to one of first 3 having the analysts, the Bert Dunns, the guys who 4 really know how this plan works, focus more upon
( 5 looking at a sequence of events that can really 6 happen on an operating reactor, and then making sure j 7 that the operators can handle the abnormal." Your 8 answer goes on.
9 MR. FISKE: How about reading the rest 10 of it? E 11 MR. SELTZER: I am getting tired. Do 12 you want to read the rest?
13 MR. FISKE: Sure. Mr. Seltzer has l
14 indicated that he would prefer that I continue 15 to read which I will be delighted te do.
4 16 MR. SELTZER: You could elicit Miss 17 Vaughn to read it. .
18 MR. FISKE: "I don't believe we can 19 design nuclear power plants to handle an 20 infinite number of differont scenarios or 21 different event trees, if you will. There's 22 too many things in that very complex system 23 not only in the NSS, but in the whole plant,
((~)s 24 which you could never guess would happen and 25 try to analyze and then give the operator a
Korrocch 370 1
(~h
~
2 cookbook or a recipe on what to do in the 3 event of. And I believe the lesson to be 4 learned here is that the operators have just 5 got to understand more about the plant."
({
6 That concludes his answer.
7 BY MR. SELTZER:
8 Q Were you asked that question and did you 9 give that long-winded answer?
10 MR. FISKE: I will object to the form 11 of the question.
12 A To the best of my knowledge that is my answer 13 to that question, yes, sir.
14 Q You said at the bottom of page 257 --
when 15 I talk about changing priorities I believe that what 16 I really mean is that the emphasis should now be 17 changed to one of first having the analysts, the, 18 Bert Dunns, the guys who really know how'this plant 19 worhs, focus more upon looking at a sequence of 20 events that can really happen on an operating 21 reactor, and then making sure that the operators
\-
22 can handle the abno rmal . "
23 Were you saying there that you think 24 that Bert Dunn is one of the guys "who really know
(
25 how this plant works"?
Karrasch 371
~
Cl) 2 A The point I was trying to make here was that 3 the engineers who do the safety analysis of the 4 plant have the best understanding of how the plant F
/s 5 responds and how it reacts to a given sequence of 6 events.
7 Bert Dunn is one such analyst.
8 Q You thought he was a good example of 9 the class that you were referring to?
10 A Yes. (
11 Q He is one of the analysts at B & W who 12 really knows how B & W nuclear plants work,to use
,r m 13 your words?
.14 A He knows how the plant responds during a 15 small break LOCA as well as anybody at B & W.
16 Q Now, you thought, as you expressed it 17 here, that the Bert Dunns of B & W should focus more #
18 upon looking at a sequence of events that can really 19 happen on an operating reactor.
20 What did you mean by that? I am asking 21 you to tell me what you meant by events that can i
. I 22 really happen. l 23 were you intending to contrast that with 24 what you had said on the preceding page about B & W
[G^)-
25 in the past having been designing the systems to l i
i l
1 Karrasch 372 2 automatically keep the plant safe for very unlikely 3 events?
4 A I believe the point of my statement here was
( 5 that I thought the emphasis should change from one 6 of studying unlikely events which were mandated to p' 7 us by the NRC to one of looking more at the types 8 of things that can and have really happened on an 9 operating plant.
10 Q When you say "have really happened," do 11 you mean that you thought that B & W should be 12 studying transients that had actually occurred on O( / 13 B & W plants in the past?
~
14 A I don't believe I was referring specifically 15 to B & W.
l ,
16 Q Do yon mean on any nuclear plants?
4 17 A I was referring to a general change,in
~
18 emphasis for the entire industry when I an swe re d
~
10 this question.
20 Q When you said that you thought that the 21 priorities should be shifted to studying events 22 that have happened, did you mean that you thought 23 the designers of nuclear' steam supply systems,
-f) 24 including B & W,should be placing greater emphasis 25 on studying transients that have already taken
- - - - - - - - - - , -- - - -- e --- ,, r -
1 Karrasch 373 0 2 place?
3 A Yes.
4 Q Is that like Allen Womack's suggestion 5 to you in 1978 that study be done on events like l
(
f 6 Rancho Seco's rapid cooldown transient and the 1
7 Davis-Besse transient?
8 MR. FISKE: Well, are you referring 9 to a Davis-Besse blowdown, whatever that was?
10 MR. SELTZER: That's the one.
11 MR. FISKE: I think I will object to 12 the form of the question. You are asking s 13 Mr. Karrasch to make a comparison as to 14 whether one thing is similar to another. I 15 don't think he needs to do that in that form.
16 BY MR. SELTZER:
17 Q Is what you were saying any different 18 from what you understood Allen _Womack had'said to 19 you in 1978 about studying transients that had 20 already occurred on B & W plants?
. 21 A Yes, I think it was. I think Allen was asking L 22 me to focus on improving the design of plants which 23 are currently under construction, I think my N)
J 24 testimony in front of the Kemeny Commission is more 25 to provide a focus on operating plants.
F f
Karrasch 374 1
O U
2 Q Did the idea that you were expressing 3 to the Kemeny commission embrace the notion that 4 B & W should put emphasis now on analyzing prior
( 5 events like the Davis-Besse event?
6 A I think the emphasis I was trying to make in 7 that answe r is that we should study s.cenarios which 8 are more likely to occur versus focusing our 9 attention on improbable events.
10 g All right. Let me see if I, unde rstand 11 what you are saying.
12 Prior to the Three Mile Island accident 13 B & W had performed many analyses on what used to l
14 be called the maximum credible accident; right, or 15 so-called design basis accidents?
16 A The majority of our attention in safety .
17 analysis was focused upon " design basis accidents."
18 Q A design basis accident was intended 10- to be the worst type of accident that-could take 20 place, is that right?
21 A I don't unde rstand what - you mean by "wo rs t. "
L-22 Q The theory under which B & W operated, 23 as you unde rstood it, was if the plant was capable
- (~)
-( j 24 of responding to a design basis accident, then it 25 should be capable of responding safely to accidents
g Karrasch 375 O#
2 that we re less severe than design basis accidents, 3 right?
4 A I am not sure if that was the basis for a philosophy.
( 5 6 I do know it is a fact that we studied 7' design basis accidents.
8 Q You said that large breaks were studied 9 more than small breaks, is that right?
10 A I don't recall saying that. ,,
11 Q I thought you did just a few minutes ago.
12 You talked in your testimony before the
, 13 Kemeny Commission and in your testimony here about .
14 accidents which were very un13daly versus accidents 15 which are more likely.
16 In 1978 did you have any understanding 17 about whether small breaks were more likely to 18 occur than large breaks in the reactor coolant 19 system?
20 A I would say that in 1978 B & W focused'more 21 attention on small breaks.and the analysis of small 22 breaks than they did on large breaks.
23 Q In what year?
I)
\_/
24 A In 1978.
25 Q Is that the year in which the company
.- , ~ ,- -
1 Karrasch 376 2 discovered they hadn't analyzed the pump discharge 3 line break?
4 A I don't know if that was the exact year but
( 5 it was in that time frame.
6 Q You have said that the NRC in its l
7 licensing tended to focus on events that were very 8 unlikely to occur.
9 Did the NRC in any way prohibit B & W 10 from studying more likely events? e 11 A They did not require us to study che more 12 likely events; thev did not prohibit us from O
kl 13 studying the more likely evente.
14 Q To your knowledge was there a tendency 15 at B & W to study those things which the NRC required
. 16 you to suudy,and, conversely, for B & W to tend not 17 to study those things which the NRC did not require 18 you to study?
19 MP. FISKE: Can you answer that 20 question?
21 A I only know about the area in which I focused
, [
s 22 -most of my attention and most of my attention was 23 focused on design and analysis of our plants under I 24 construction to show that they met no w and changing 25 NRC regulations for the-design.
g Karrasch 377 2 Q In the area that you were most familiar 3 with then, you did see a tendency to study those 4 things that the NRC wanted studied and a tendency
( 5 not to study the things that the NRC was not 6 requesting, is that right?
I 7 A The me*ority of the work performed during 8 that time frame by my group was in response to 9 NRC requirements.
10 Q Commissioner Peterson had asked you,
- 11. "could it be that all of the atomic energy industry's 12 efforts to tell people how safe nuclear energy is O
\- 13 could have provided a mind set so that it kind of 14 downgraded any threats to safety and gave priority 15 instead to fulfilling some requests of the Nuclear 16 Regulatory Commission') the first three words of 17 your answer were, "I think so." ,
18 When you said "I think so," were you 19 telling Commissioner Peterson that you agreed that 20 it can be that all of the nuclear industry's efforts 21 to tell everyone how safe nuclear energy is could 22 have provided a mind set sa that it downgraded any 23 threats to safety?
lA) 24 A To the best of my recollection when I said 25 the words "I think so," I was responding to an 1, -
. .. _. - ~, - , .-.
1 i
l 1 Karrasch 37d f'~'
2 implication that priority was given to fulfilling 3 requests by the Nuclear Regulatory Commission.
4 Q Did you answer the first part of the
( 5 Commissioner's question regarding the mind set of 6 downgraded threats to sdfety?
7 A I recall that my initial response was in 8 response to the second part of his question related 9 to the priorities by the Nuclear Regulatory 10 Commission. 8 11 Q Was there any part of your answer that 12 responded to the initial part of Conmissioner 13 Peterson's question?
14 A I just can't remember what my thought process 15 was as I was answering that question.
16 Q Well, look at your answer and tell me, 17 as you see it, if there is anything that you believe 18 was responsive to the first part of Commissioner 19 Peterson's question?
20 MR. FISKE: I don't think, Mr. Seltzer, 21 Mr. Karrasch has to do that.
22 MR. SELTZER: I am just asking him to '
1 23 look at a document which shows the words he n
( ng spcke.
\ )) ~'
25 MR. FISKE: He just told you he can't
- ~ - . -
4 1 Karrasch 379
/~N U. 2 recall what his thought process was.
3 Q Does it refresh your recollection to 4 look at the words you spoke there?
l 5 MR. FISKE: If you want to ask him 6 that question, that's all right.
7 MR. SELTZER: Thank you.
8 MR. FISKE: Does it refresh your 9 recollection to look at your answer as to 10 whether or not your answer was responding to 11 the first part of the question as opposed to 12 the second?
13 A In rereading this response and trying to recall 14 my thought process leading up to that response, I 15 believo I answered the second part of his question 16 on priorities related to requests by the Nuclear 17 Regulatory Commission. That's all I can ..re call .
18 Q Why didn't you answer the first part 19 when he asked you whether there was a mind set so 20 that people downgraded threats to safety?
. 21 A I just don't recall the thought process I
- (.
22 I went through after hearing his question.
23 MR. FISKE: That illustrates one of T
) 24 i the p roblems in putting two questions into 25 one. I l
4 l
I
1 Karrasch 380
/~N -
- h. 2 MR. SELT"ER: Well, I don't think it 3 is a compound question. I thought it was one 4 question and the witness chose not to answer
( 5 the important part of it.
6 MR. FISKE: Well, I think the witness 7 has testified that he responded to the latter 8 part of the question. It happens all the 9 time we people put two questions into one.
10 It's a perfectly natural response.
11 MR. SELTZER: I thought it was studied 12 evasion and a non-natural response.
13 MR. FISKE: I guess what you and I 14 think really doesn't make much difference. .
15 (continued on page 380.)
16 17 18 19 20
- 1 1
22
'J e4
(~)T
\_
~
25 :
l'u' 'A r
1 Karrasch 381 g- -
(m/ 2 BY MR. SELTZER:
3 Q I would like you to look at GPU Exhibit 79.
4 This is a memorandum which you got from 5 Joe Kelly in July of 19 79.
((
6 (Document handed to the witnens.)
7 A Yes. This is one of the five memos which Joe 8 gave me in July of 1979.
9 Q You read it af ter you got it from Joe?
10 A Yes, I did.
t gg Q Did you understand it?
12 A Yes, I understood it when I read it in 1979.
13 Q Did you understand that it'was a follow-up
[4 to GPU Exhibit 78?
15 A Yes, sir.
gg Q Did you recall when Joe Kelly gave this to 17 you in July of 1979 that you had previously received 18 a copy o f it? -
19 A No, I did not recall previously seeing this 2G memo prior to 19 - prior to July of 1979.
21 Q Do you remember from July of 1979 whether 22 the copy of Don Hallman's memo, which Joe gave you, 23 had Bert Dunn's two memoranda attached to it?
y'd 24 T!!E WITN ESS : Would you read that back, C/ -
25 please?
_. - - -= . _ ,
4 g Karrasch 382
(,, .
2 Q Do you remember Don Hallman's memo, GPU 3 Exhi.bi t 80, has an indication that Bert Dunn's two 4
memos are attached?
5
(( A Yes, I recall that.
~
6 Q In July of 1979 your working confrere ,
7 Joe Kelly, gave you a copy o f Don Hallman's memo ,
O
., right?
I 9 l4 A Yes.
10 Q Did the copy of Don's memo,,which Joe 11 gave you, have Bert Dunn's two memos attached to it?
19~
A The two memos were included in the package of s/ 13 five that he gave me.
14 MR. FISKE: He wants to know whether they 15 were the re a second time.
16 A (Continuing) I don't think they were thure a 17 second time. -
l 18 Q You are not sure?
19 A I am quite sure they were not.
20 g were there any markings on the documents
. 21 that you got from Joe Kelly?
k.
22 A I don't recall.
l 23 Q Did you make any marks on them?
l
'( 24 A I don't recall that ei the r.
25 Q . What di d you o- u .. he copies that you
. 1
i 1 Karrasch 383 2
got from Joe. Kelly?
3 A I rcad them. I know I kept them for some time 4
after that, at least until the Kemeny Commission
{ 5 he a ri ng , and then I do not r'ecall what I did with them.
6 Q Did you review them again before you gave 7
testimony be fore the Rogovin group?
8 A I don't recall.
9 Q Did you reread your prior sworn testimony 10 be fore you showed up for your depositio'n this week?
11 A Yes, I did.
12 Q You read all of it?
13 A Yes, I did.
11 Q Did you find any of your sworn testimony 15 which you believed on rereading was not accurate and 16 truthful?
17 A No, I did not. .
18 .
Q What, if anything, was your understanding 19 as to why Bert Dunn had sent you copies of GPU Exhibit 20 78 and 79? .
21 MR. FISKE: At what point.in time are you L 22 talking about?
23 Q The first time you recall reading GPU b).
Qs 24 Exhibit 78 and 79.
25 MR. FISKE: Yo u mean, in 'other words , ,
p e --u. , -
. _. - . _ ~ _ _ . . ... - - _ . _ _ _ _
1 Karrasch 384 i
/~h '
'2
~
July of '797 ,
i
)
3 MR. SELTZER: Maybe after talking about 4 it with us fo r the last two hours, maybe he 5 ramembers he read it earlie r.
(
6 MR. FISKE: I think the time frame 7 should be clear in your question.
8 THE WITNESS: Could you please repeat 9 the question?
[
10 BY MR. SELTZER: t 11 Q At the time you first recall reading 12 GPU Exhibit 78 and 79, what understanding, if any, ,
O 13 did you form as to why Bert Dunn had sent you GPU 14 Exhibit 78 and 797 i
s
+
15 A I don't recall giving that any consideration
, f.
16 when I read the memos in July of 1979. y 17 Q What was your understanding,~ if any, as 18 to why Joe Kelly had sent you a copy of GPU E;Ihibit )
19 76 7 +
J ,
20 MR. ' FISKE: Again, in July of '797
- t. '-r 21 MR. SELTZER: Or at any earlie r' time
(_- 22 that he recalls reading it.
s -
7 I'
y ;
k
':D A Again, I don't recall giving that any -
d r.
h 24'
~[U. consideration at the time I first read.the memos.
25 Q When for the' first' time were you aware t
r;, , - -
_ . ./ - - ,
x
- .c 7 q I
s.
' .s
'g s I s Karrasch 385 n N O. ; C, 2
that B & W's limits and precautions precluded fillingv.
'k. h g 3 the ;iressurizer colid except during hydrostatic
/
4 ' testing?
i \ s
(
3 I $ object to the form of the
]. 5 MR. F ISICE :
t , 6 q ue's ti on .
3'7 3 don't think there has been any evidence
- 3 t} int Mr. Karrasch'has become aware of,that.
,y 9 Q When, if ever?
10 A I' don ' t. recall e\ ver becoming aware o f. that.
t 11 Q You s aid in you(r own description' of the .
12 position of Manager of Pitmt Integration that the
~
O_ 13 Manager of Plant Inteigration should keep himself ,
)
14 abreast of a lot of thi'ngs by reading and' attending
15 me e'ti ngs.'. Do ~ yo u, re c all'1 tha t ?
- s. y .g ,
16 MR. FISKE: Well, let's see that. I u /
' (. c 17 think we'can do a little better than, quote, a l r -
18 lot o f thing ~s , , unquote . h. -
p 19 .MR. SELT2ER: "heeps abr9ast of the
> 't 20 la t e s t ..'d e ve lopments , techniques, and
- 21 ph'los7phies,in NSS design through study, 3-22 rese'erch 'and participation. "
23 - '
-Q ' . Do you remember writing those things?
^N .24 A Yes, sir. \
): *
.. ' ~n -
Y g 25 [L Q 'V,Lven your, role in the Kelly, Dunn,
\ b s
'{% f -q % . j%'y
- . . t 5 -
I3 j h
y 6
1 Karrasch 386 O 2 Hallman, Karrasch matter, did you read the reports of 3 the President's Commission when they came out?
4 A I recall obtaining a copy of the President's
( 5 Commission Report and scanning it very briefly.
6 Q What about a ny o f t he 27 backup reports; 7 did you ever get a copy of any of those?
8 A No, sir, I did not.
9 Q Do you know that there is one that 10 discusses extensively B & W's role? t 11 MR. FISKE: I think it is the role of the 12 managing utility and its supplier.
[\ /~h 13 MR. SELTZER: Right. That is the one.
14 A I do not recall seeing that document.
15 Q Do you recall reading in the Kemeny 4
16 Commission Report that there was something in there about B & W's instructions to utilities on not 17 18 permitting the pressurizer to go solid?
~
19 A No. I do not recall that.
, 20 -Q Did_you read Mitch Rogovin's breezy 21 report prepared for the NRC? l 22 A Ag ai n , I have a copy of that report. I recall 23 glancing' through it. I do not recall reading it n
) 24 thoroughly.
'w ]
25 .Q Have you read anything thoroughly dealiz.g w
1 Karrasch 387 0
2 with the causes of the Three Mile Island accident?
3 A Yes, sir.
4 Q What?
A
( 5 During the time frame that these reports were 6 published and available to me, I was spending the 7 majority of my time preparing for the hearings at 8 Rancho Seco, and I recall reading in great depth many 9 volumes of technical information about the B & W 10 plant design at SMUD in preparation for those 11- hearings.
12 Q What did the B G W technical design for ,,
6
\_ 13 the Sacramento plant have to do with the causes of 14 the Three Mile Island accident, which is what my 15 question dealt with?
16 -Let me be clear, because we will waste a 17 lot of time if you don 't understand my qu,estion.
18 I am not talking about things which related 19 inferentially the way you claimed pressurizer 20 pressure on the secondary side related to temperature 21 on the primary side of a reactor cooling system.
22 I am talking about, did you read 23 anything that directly described and discussed the
/^'T 24- causes of the Three Mile' Island accident?
. N. si 25 A I recall reading a very detailed sequence of
1 Karrasch 388 2 e ve nt s for the Three Mile Island accident within 3 several months af ter it occurred.
4 Q Do you recall reading anything else that 5 described the causes of the Three Mile Icland
{
6 accident, I mean, other than Dunn's two memos and 7 Hallman's memo?
8- A After the Three Mile Island accident I was very 9 much involved in assisting operating plant customers 10 in responding to the new regulations by the NRC in 11 order to keep their plants running. There was a great 12 amo un t of technical information which I had to N/ 13 understand --
14 Q I am talking about the cause of the 15 accident, and I don't mean to cut you off, if you are 16 getting to something that relates to the cause of the 17 Thre e Mile Island accident, but you said you read a 18 detailed sequence of events.
19 Is there anything else that you read that 20 related directly and specifically to the cause of the 21 Three Mile Island ac ci da nt ?
22 A I don't recall.
23 Q Has B & W prepared, to your knowledge,
/m j
\ %,<
l' 24 any study or analysis o f the ca us es of the Three Mile 25 Island accident?
1 i
i Karrasch 389 2 A I cannot remember any specific documents.
k 3 Q Are you aware --
I didn't ask you about 4 specific documents -- are you aware whether B & W has 5 prepared any analysis of the cause of the Three Mile
(
6 Island accident?
4 7 A I am not aware o f any.
8 Are you aware that after the accident Q
9 various managers at B & W prepared what have been 10 called lessons-learned memos? (
11 A No, I do not recall.
12 Q Did you prepare any memo or list of
) 13 lessons learned from or as a result of the Three 14 Mile Island debacle?
15 A I don't believe so.
16 Q Did Allen Womack ever ask you for your 17 contribution to any product that he was' preparing on
~
L8 lessons learned from the Three Mile Island calamity?
19 A I don't recall.
~
20 Q Did you ever ask anybody in Plant
.21 Integration to contribute to or to prepare such a i 22 . list?
23 A- I really don' t remember.-
i
'~N 24 Q You don't remember doing so; is that'what
-( /.
)
25 you mean?
9 9 e -+ -- e v v e
1 Karrasch 390
'^
2 A Yes.
3 Q What was your special assignment for 4 Allen Womack?
( 5 A There were two primary- roles on that special 6 assignments one was to relieve me of the duties of I
7 managing a large group so that I could devote almost 3 full time to the ASLB hearings at Rancho Seco; the 9 othe r was to make myself available to assist Allen in 10 managing the Plant Design Section. E 1
11 Q How long-did that special assignment 12 persist, - from when to when ?
\- 13 A I think it was just for a couple of months in 14 the spring of 1980.
15 Q At the time that you were on special 16 assignment to Allen Womack, was Charlie Parks still 17 working as an assistant to womack?' s 18 A Yes, he was, to the best of my knowledge.
19 Q When Joe Kelly-came back from his-field 20 trip to Davis-Besse to check out the transient that 21 they had had there in the . fall of 1977, did you talk 22- to him about his trip?
23 A .Yes, I.did.
[D
'd 24 Q Did he tell you a little bit 'about it?
- 25. A I think the extent ~ of our conversation was ny
1 Karrasch 391 t
(- -
2 asking him, "Did you complete the e valuatio n, " and I l
3 got a positive response back.
4 Then Joe told me he was very busy preparing 5
({ for a meeting to present the results of that evaluation, 6 and that I should attend that meeting if I wanted to.
7 Q He told you that you should attend his 8 meeting?
9 A Yes.
10 He invited me to the meeting.
11 Q Did Joe Kelly tell you that while he was 12 out at Toledo Edison, Toledo Edison o f ficials had let
\ 13 him know that they wanted to have a better indication 14 of the position of the pilot operated relief valve 15 inctalled in their plant?
16 MR. FISKE: Could I hear that~ question 17 again, please?
18 (Question read. )
19 A I do not recall Joe mentioning that to me at all.
20 Q Do you recall Joe Kelly telling you that
. 21 Toledo Edison officials had told him that they wanted k.
22 to have a device installed in their plant that would 1
23 -automatically close the block. valve if the pilot I I~' 24 (s\' operated relief valve failed.to close when it should?
25 A I do not recall him mentioning that to me, either?
.- = --
1 Karrasch 392 0 2 Q Do you recall Joe Kelly telling you that 3 Toledo Edison had let it be kno'an to Kelly that they 4 wanted to have a feature installed in their plant that l 5 would automatically trip the reactor whenever the G steam and feed water rupture control system had 7 activated?
8 A 1 do not recall that, either.
9 Q Have you ever, from your high school 10 biology course forward to today, heard yf any kind of 11 mechanism being designed for automatically closing a 12 block value when a pilot operated relief valve fails O 13 to close?
14 A We are currently involved in a work task for 15 the Consumers' project to define the requirements and 16 a conceptual design for providing an automatic 17 closure of the PORV block valve. .
18 Q Are you involved in that effort-in any way?
19 A No, I am not, but I am aware of it.
t 20 Q - Who is working on it? !
i 21 A It is a pro.iect that is currently under.way 2p for the Consumers Power Company.
23 -Q So you said.
A)
(
v 24 Who is working on it? Who is in charge?
1 25 A I don't know for'sure.
- 1 Karrasch 293
,es -
-t 2
Q How do you know anybody is working on it?
3 A I am aware that it is an active project within 4 E & W.
5 Who told you that?
( Q 6 A I don't recall.
, 7 Q Has anybody ever told you or let you know 8 that B &W already designed an automatic closure for 9 a block valve on a plant?
, 10 A I am not aware of any such desigd.
11 Q Hearing it from me, is that the first time 12 you have ever heard that?
13 A I know we had been discussing such a design 14 feature possibly with all of our customers.
15 Q No, I mean that'before the Three Mile 16 Island accident B & W had already designed such an 17 automatic closure. -
18 'Did you know that?
~
19 A I did not know that.
20 Q Eave you ever heard of an outfit that goes 21 by the handle Brown Boveri Reaktorat?
(J 22 A Yes, sir.
23 Q Do you know that your company has been for
'b k
' L,'
24 a period of time in a joint venture with'BBR to design 25 a nuclear electric generating plant in-
1 1 Karrasch 394 2
Muelheim-Kaerlich, Germany?
3 A Yes, I am aware of the joint venture.
4 Q Have you ever seen anything in connection 5
{ with the design of that plan't?
6 A Yes.
7 Q But you haven't seen anything that 0
indicated they had designed an automatic closure for 0
the block valve for that plant?
10 A I am unaware of any such design dpature in that 11 plant.
1 Q Have you ever talked to any of the people
'- 13 who worked on any aspect of the design.of that plant?
14 A Yes.
15 Q Who?
16 A Some of the people in Plant Integration were II asked on ' occasion to contribute to the design of 18 that plant.
19 Q Did it ever occur to you before the 20 Three Mile Island plant accident that you might be
- , 21 able to learn something useful by looking at design 22 innovations -that were being planned or ins talled
}
=
23 in the Muelheim-Kaerlich plant?
[ 24- Yes, it did.
U) A.
25 Q Did you ever act upon that?
1 Karrasch 395 O
V 2 A I recall, not personally, but I recall studies 3 being performed to do comparisons between the design 4 of the Muelheim-Kaerlich plant and our 205 fuel
( 5 assembly plants which are under construction.
6 Q When was that undertaken?
7 A My involvement was greater than two or three j 8 years ago.
9 Q aut you never found out that a block valve 10 that would close automatically had been, designed for 11 that plant?
12 A No, sir, I did not know that.
O 13 Q Do you know that B & W has concluded in 14 a written report that if the Muelheim-Kaerlich design 15 for automatic closure of a block valve had been 16 installed at Three Mile Island on March 28th, 1979, S
17 there would not have been a Three Mile Island 18 accident?
19 A I am not aware of any such report.
0 20 Q On March 28th, 1979 B & W set up a f 21 communications control center for obtaining (J
22 information from Three Mile Island, ri ght ?
23 A That is right.
/~T 24 Who first told you that there was a (w) ,
Q
'25 transient.that had taken place or was in progress at
- 'V' = r f
1 Karrasch 396 O"' 2 TMI or March 28th, 1979?
3 A I believe it was Allen Womack.
4 MR. FISKE: Mr. Seltzer, let me just make
"/
( 5 a suggestion. I don't guess that this line of 6 inquiry is one that is going to terminate in 7 the next five minutes. I mean, if it is, fine, x
8 but --
9 MR. SELTZER: Well, maybe 15.
< 10 MR. FISKE: I think I am going to have to 11 leave within five or ten minutes.
12 MR. SELTZER: O.K. What would you like
(~)
V 13 to do?
14 Off the record.
15 (Discussion off the record.)
16 MR. SELTZER: Let me put this on the 17 re co rd . I think that but for some of the 18 perhaps unavoidable interruptions b$cause of
~
19 , other people's schedules , we could have 20 finished Mr. Karrasch's deposition within the 21 four days this week.
22 David Taylor and I particularly tailored 23 --
if that is not too much of a play on words --
,/'T
\,,)
O 13 that we are not attributable to counsel for the 14 plaintiff. So, there is no issue'as to that 15 and we are prepared to have Mr. Karrasch come 16 back on any one of three suggested dates in 17 July. .
18 MR. SELTZER: How about next Monday?
10 MR. FISKE: I simply can't.
20 MR. SELTZER: Or Tuesday or Wednesday or 21 Thursday or Friday?
L 22 MR. FISKE: Let me --
I certainly can't 23 do it -- well, why don't we go.off the record.
o -
, 24 There is no need to put all of this on the 25 record.
i l
1 Karrasch 397-A i l
l 2 (Discussion off the record.) I 7
3 (Time noted: 12 :4 0 o ' clock p .m.)
4 r .
(, 5 6
- Bruce Adolph Karrasch 7
i
, 8 Subscribed and sworn to before me i
9 this day of 1981
, 10 t t
11 I.
4
- 12 Notary Public 13 ;
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1 398 CERTIFICATE l
STATE OF NEW YORK )
3
- ss.:
COUNTY OF NEW YORK )
4 I, CHARLES SHAPIRO, C.S.R. , a Notary
{
l 6
Public of the State of New York, do hereby certify that the continued deposition of 7
BRUCE ADOLPH KARRASCH Was taken before i 8 me on Friday, June 19, 1981 consisting 9
of pages 325 through 397-^ -
I further certify that the witness had 11 been previously sworn and that the within O)
( 1 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 of the counsel.
18 19 IN WITNESS WHEREOF, I have hereunto set my gg hand this S day of ' .3 U kV ' , 1981.
20 21
\..
2" 23 4
CHARLES SHAPIRO, C.S.R.
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December 3, 1982 '"'"*" "'t "
Joel Katcoff, Esq.
Kaye, Scholer, Fierman, Hays & Handler 425 Park Avenue New York, New York 10022 k Re: GPU v. B&W
Dear Mr. Katcoff:
Enclosed is the missing page 398 of Bruce Karrach's original deposition transcript. It has been signed and notarized. .
Please bind it with his June 19, 1981 testimony; it is the last page of that day's transcript. Thank you.
Sincerely, lO14f A' \
Katharine Swett Legal Assistant ,
i Enclosure j
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CERTIFICATE l
STATE OF NEW YORK )
3
- ss.:
COUNTY OF NEW YORK )
g I, CHARLES SHAPIRO, C.S.R.
, a Notary 6 Public of the State of New York, do hereby certify that the continued deposition of 7
BRUCE ADOLPH KARRASCH was taken before me on Friday, June 19, 1981 consisting I
of pages 325 through 39hA ;
g I further certify that theiwitness had 1
been previously sworn and that the within 13 transcript is a true record of said testimony; That I am not connected by. blood or 15 arriage with any of the said parties nor 16 interested directly or indirectly in the matter in controversy, nor am I in the employ of any j g of the counsel. -
g IN WITNESS WHEREOF, I have hereunto set my 4H -
' '98
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Subscribed and Sworn Before CHARLES SHAPIRO, C.S.R.
24 me this 23 day of -/2nM ,1982. j_
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25 Notary Public Comissioned Notary as Danita D. Robertson Comission Expires: /, l 'Jt3
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