ML20072J169
| ML20072J169 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 09/29/1981 |
| From: | Karrasch B BABCOCK & WILCOX CO. |
| To: | |
| References | |
| TASK-*, TASK-02, TASK-03, TASK-07, TASK-10, TASK-2, TASK-3, TASK-7, TASK-GB NUDOCS 8306290990 | |
| Download: ML20072J169 (104) | |
Text
.
399 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK dg
_ _ _ _ _ __ _ _ _ __ _ _ _ __ _ _ x
(
GENERAL PUBLIC UTILITIES CORPORATION, :
\\
JERSEY CENTRAL POWER & LIGHT COMPANY, METROPOLITAN EDISON COMPANY and PEtiNSYLVANIA ELECTRIC COMPANY, 80 CIV. 1683 (R.O. )
Plaintiffs,
-against-THE BABCOCK & WILCOX COMPANY and J.
RAY McDERMOTT & CO.,
INC.,
s',
Defendants.
____x m
}
}
Continued deposition of Defendant Th'e Babcock & Wilcox Company, by BRUCE ADOLPH KARRASCH, taken by Plaintiffs pursuant to adjournment, at the offices of Kaye, Scholer, Fierman, Hays & Handler, Esqs., 425 Park Avenue, New York, New York, on Tuesday, September 29, 1981, commencing at 10:00 o' clock in the forenoon, before Joseph R.
Danyo, a Shorthand Reporter and Notary Public within and for the. State of New York.
k DOYLE REPORTING, INC.
0 00 289 T
PDR CERTIFIED STENOTYPE REPORTERS 369 LExtNGTON AVENUE WALTER SHAPIRO, C.S.R.
NEw YORK. N.Y.
10017 CHARLES SHAPIRO, C.S.R.
I TELEPHONE 212 - 867-8220
1 400 2
Appea rance s :
3 4
KAYE, SCHOLER, FIERMAN, RAYS & HANDLER, ESQS.
Attorneys for Plaintiffs
(
5 425 Park Avenue New York, New York 6-By:
RICHARD C.
SULTZER, ESQ.,
7 of Counsel 8
9 DAVIS POLK & WARDWELL, ESQS.
10 Attorneys for Defendants One Chase Manhattan Plaza.
PATRICIA VAUGHN, ESQ.
O-
-and-13 ROBERT F.
WISE, ESQ.,
14 of Counsel 15 16 Also Present:
17 DAVID TAYLOR 18
-ooo-19 20 21 22 23
(~h 24 V
25
~,
- (y.
1 401 2
having been previously duly sworn, resumed and 4
testified further as follows:
(
5 EXAMINATION (continued) 6 BY MR. SELTZER:
7 Q
This is a continuation of the depositjan 8
which you began giving in this lawsuit in June 1981.
i.
9 Are you aware of that?
i 10 A
Yes, I am.
11 Q
Are you also aware that just as your 12 testimony then was testimony being given under oath to
/~T CJ 13 tell the truth, your testimony today is simil'arly under 14 oath?
15 A
Yes.
16 ~
Q Within the Plant Integration unit, when you 17 were in charge of it, did you have a group called the 18 NSSS Design Group?
19 A
- Yes, f
20 Q-Am I correct that you prepared a description 21 of the scope of responsibilities of'the NSSS Design 22 Group?
23 A
I don't recall.
(~
(%)
24 MR. SELTZER:
Let me mark for identification t
25 as GPU. Exhibit 377_a document from Mr. Karrasch's
_ -., _.. ~ ~
1 Karrasch 402 2
files entitled "NSSS Design Group."
l 3
(Document above described so marked as 4
Plaintiffs' Exhibit GPU 377 fcr identification, 4
{'
5 as of this date.)
6 Q
Do you recognize GPU Exhibit 377 ac a 7
description of the responsibilities of the NSS Design 8
Group which was prepared by or for you while you were 9
head of Plant Integration?
10 A
I vaguely recall a document'like.this being in 11 place when I was manager of Integration.
I do not recall 12 who prepared it, nor whether or not I even approved it.
13 Q
Was the NSSS Design Grodp responsible for 14 the preparation and issue of overall plant level 15 requirements for the nuclear steam supply system?
16 A
Yes.
17 Q
Was the NCGS Design Group responsible for 18 plant balance of plant criteria and secohdary system 19 requirements?
20 A
Yes.
21 Q
Could you explain what plant balance of 22 plant criteria were in 1978 and 1979?
23 -
A The balance of plant criteria were documents-i'
' (")' -
24 prepared by B & W which informed our utility customers
%/
25 what design requirements they should' comply.with in the
-e
M i
Karrasch 403 f~%
C 2
design of the remainder of the plant.
3 Q
Am I corre ct that B & W had an interest in 4
that because the balance of plant components and systems 5
have a direct interface and operational influence on
('
6 the overall nuclear steam supply system?.Do you see 7
where I am reading from?
8 A
No, I was not following where you were reading.
9 (Record read.)
10 A
Yes, I think that is correct.
11 Q
Is the main feedwater system a balance of 12 plant component as viewed by Babcock & Wilcox?
O
\\-sl 13 A
Yes, it is, to the best of my knowledge.
14 Q
Is the auxiliary feedwater system a balance 15 of plant component?
16 A
Yes, it is.
17 Q
Is the condensate polisher' system a balance 18 of plant component?
~
19 A
Yes, it is.
J 20 Q
Do the main feedwater system, auxiliary 21 feedwater system, and condensate polisher system all L
22 have a direct interface and operational influence on the 23 B & W nuclear steam supply system?
()
24 A
Yes,.I believe that is accurate.
25 Q
Prior to the Three Mile Island accident,
~
.,v.
1 Karrasch 404 2
what, if any review or analysis was done in plant 3
integration to develop requiremorts for the condensate 4
polisher system?
{
5 A
The only requirements that I am aware of that G
could possibly have an effect on the condensace polisher 7
system are those with respect to maintaining proper 8
feedwater chemistry.
9 Q
To what extent, if any, did B & W review 10 the design of the condensate polisher, system in plants 11 that were under design and construction?
I am referring 12 to the period when you were the head of Plant 13 Integration.
14 A
During the time I was manager of Plant Integration, 15 I cannot recall any review of a condensate polisher 16 system being conducted.
17 Q
Do you know whether there was any group 18 outside of Plant Integration that was reviewing the 19 design of condensate polisher systems pri'or to the 20 Three Mile Island accident?
21 MS. VAUGHN:
For the time he was manager.of C
22 Plant Integration?
23 MR. SELTZER:
No, any time prior to the 24 Three' Mile Island accident.
25.
MR. WISE:
Going all the way back to the
[
1 Karrasch 405 i
- O~
2 1960s?
3 MR. SELTZER:
Yes.
As far back as Mr.
4 Karrasch has a recollection.
(
5 A
I am not aware of any such B & W review of the 6
condensate polisher systems on any plant.
7 Q
Is there any one unit or group outside of 8
Plant Integration that would have had any responsibility 9
for review of the condensate polisher system prior to 10 the Three Mile Island accident?
11 MS. VAUGHN:
We are talking of that whole 12 period of time?
13 MR. SELT ZE'R :
Yes.
14 A
The Control Analysis Group did have responsibility 15 for review of plant secondary systems.
I don't know if 16 that review ever included the condensate polishing system 17 Q
Within what larger part of the B & W 18 organization was the Contrcl Analysis Section?
19 A
The Control Analysis Unit was a part of the 20 Plant Design Section.
21.
Q Who was head of Control Analysis at. the time 22 you were head of Integration?
R.
B.
Davis?
23 A
'I recall that Ron Davis was manager of Control
)'
24 Analysis for at least some portion of the time that I 25 was manager of Plant' Integration.
~.
1 Karrasch 406
,V 2
Q Is Davis still at B & W7 3
A No, he is not.
4 Q
Where is he?
l
({
A I don't know.
5 6
Q Do you know where he went after he left 7
B & W7 8
A I vaguely recall that he took a position with 9
another engineering firm in Lynchburg, Virginia.
10 Q
Was it part of the assignment of the NSS 11 Design Group to provide generic policy and coordination 12 for policy resolution affecting the broad aspects of 13 -
the overall plant design?
14 MS. VAUGHN:
You are talking about still 15 when Mr. Karrasch was manager?
16 MR. SELTZER:
Exa'ctly.
17 A
Yes, that was part of the responsibility of the 18 NSS Design Group.
19 Q
The NSS Design Group was headed by Eric 20 Swanson while you were the unit manager. right?
21 A
Yes.
22 Q
And Joe Kelly was one of the engineers 23 within the group?
[/
t 24 A
~Yes.
s._
25 Q
And Lou Cartin was also in that group?
1 Karrasch 407
.n v-2 A
Joe Kelly and Lou Cartin were in that group for 3
some portion of the time that I was manager of Plant 4
Integration.
I don't recall exactly how long.
(
5 Q
What does it mean to provide generic policy 6
and coordination?
You said that was part of the 7
assignment of the NSS Design Group.
8 A
The NSS Design Group had cognizance over the plant 9
level analysis which was performed in the other units 10 in the Plant Design Section.
At times, problems would 11 come up wherein it was discovered that the analysis 12 needed to be changed for some reason or another.
Mr.
O 13 Swancon's group was sometimes asked to take the lead in 14 resolving that problem and assuring that any re-analysis 15 that had to be performed was still consistent with the 4
16 overall design of the plant.
17 Q
When you say that they were,to provide 18 generic policy, does that mean that the policy 19 guidance given by the NSS Design Group would be 20 applicable to more than one plant?
21 A
That is my understanding of the word " generic,"
22 yes.
23 Q
Looking at the second page of GPU Exhibit
/~%.
(,)
'24 377, is it correct that part of the overall responsibility-25' of the NSS Design Group was to conduct interface reviews
i 1
Karrasch 408 U
2 among the NSS and secondary side balance of plant 1
3 systems in order to assure compatibility of interfacing 4 h systen designs and hardware?
l 5
A Yes, that was part of the NSS Design Group's 6
responsibility.
l 7
Q What is your understanding about why B & W 8
felt that a group within B &W should have that 9
responsibility?
10 A
The analysis design work performed by B & W i
11 engineering on a nuclear steam supply system uses 12 i (:)
various parameters which are important in the design 13 of,the secondary systems and balance of plant.
The i
1 14 balance of plant criteria documents and the interface 15 reviews which were performed were conducted to j
16 communicate to our utility customers the fact that
)
f 17 certain aspects of their balance of plant design were i
i 18 impottant to our NSS design, so it was a communication j
19 channel between the NSS vendor and the utility. customer.
20 Q
Was it part of the overall responsibility
)
21 of the NSS Design Group as set forth in item 5 on page 2 22
.of this exhibit to review and approve selected test r
23 specifications and draft operating procedures for systems
(-(,))
24 and equipment in the NSS and secondary side balance of 25 plant?
[. -
.y i
g Karrasch 409 2
MS. VAUGHN:
While Mr. Karrasch was manager?
3 MR. SELTZER:
I think we can avoid even 4
probably having to have that clarification, because
(
5 the unit was created and Mr. Karrasch became its 6
first manager, and the unit was reorganized and f
7 disbanded a. bout the time you ceased being its 8
manager.
9 Q
Isn't that right?
10 A
That's correct.
However, the ddties and 11 responsibilities which are outlined in this document 12 were carried out by another unit which became part of
('T
~.
\\-)
13 Plant Integration when the Plant Integration Unit was 14 organized in 1976.
This function had been part of our 15 responsibility for I would guess seven or eight years.
16 MS. VAUGHN:
Also, he said he didn't know 17 who prepared this or when it was in existence, and 18 I don't want him testifying if it is not within 19 the time he was manager of it, because he didn't 20 prepare it.
21 Q
You said that for six or seven years B & W 22 had been performing this function.
Are you referring 23 to the function that is set forth in item 5 on page 2
(')
24 of GPU 3777
~
25 A
Yes.
-~
1 Karrasch 410
.said six or seven years, was that 2
Q when you 3
for six or seven years prior to the creauion of the 1
4 Plant Integration Unit?
)
(
5 A
No, I meant six or seven years prior to today.
6 Q
what was the procedure by which B & W was, 7
to your knowledge, reviewing draft operating procedures 8
for the six or seven years that you say that was being 9
done?
10 A
During.this time period, I believe the Nuclear 11 Serv' ice Department had the responsibility to prepare 12 selected test specifications and draft operating O
13 procedures.
The Nuclear Service
- Department would at 14 times request various units within the Engineering 15 Department to review those specifications and procedures.
16 The responsibility outlined in item No. 5 of this 17 document identifies that the NSS Design Group might be 18 asked to review and approve test specifications and
~
19 draft operating procedures for systems and equipment in 20 the secondary system and balance of plant.
21 Q
Have you taken any steps to determine I
22 whether the NSS De: sign Group or any predecessor of it 23 reviewed any draft procedures for the Three Mile Island
)
24 Unit 2 plant?
ss I
25 A
No, I have not.
r
1 Karrasch 411 O
2 Q
So you don't know one way or the other 3
whether the NSS Design Group or predecessor of it 4
reviewed any draft procedures for Three Mile Island
(
5 Unit 2; is that right?
6 A
That is correct.
7 Q
Do you know, one way or the other, whether 8
any other group in the Engineering Department reviewed 9
any of the draft procedures prepared by B &W for 10 Three Mile Island Unit 27 L
11 A
No, I am not aware of aB & W review of draft 12-operating procedures for Three Mile Island Unit 2.
'~
13 Q
You see item 8 on page 2 of GPU Exhibit 3777 14 A
Yes, I do.
15 Q
While you were head of Integration, was it b
16 part of the overall responsibility of the NSS Design 17 Group to participate in the solutions for generic risk 18 problems for the nuclear steam system and for the 19 secondary side systems or for systems which have direct 20 interfaces or operational influence on the plant design?
21 A
Yes, that was part of the responsibility of the i
22 NSS Design Group.
23 Q
What are generic risk problems?
()
24 A
Generic risk problems are problems'which were 25 identified on B & W backlog plants under construction
1 Karrasch 412 O\\J 2
which had an effect on more than one plant.
3 9
16 a plant as you have used the term under 4
construction up until the point when an operating
(
5 license is issued or until it goes commercial or when?
6 A
I believe the point in time that I am referring to 7
as under construction is that time prior to the plant 8
going into commercial operation.
9 Q
So the period of construction includes a 10 period of operational testing and gene' ration of power, 11 right?
12 A
Yes, I believe that is correct.
To the best of
)
J 13 my knowledge.
14 Q
You testified in June about a request that 15 you got from Allen Womack shortly after he became the 16 head of the Plant Design Section, and it was a request 17 that you put together a group of people to brainstorm 18 the SMUD light bulb event.
Do you recall that r e q u e s t-19 from Allen Womack?
20 A
Yes.
I 21 Q
Was that a request for analysis and 22 development of a solution for a generic risk problem of 23 the type described in item 8?
O)
(_
24 A
No, I don't believe Allen was asking me to solve 25 the generic risk problem.
1 Karrasch 413 U('%
2 Q
How is what he was asking you to work on 3
different from a generic risk problem?
4 A
The majority of the generic risk problems which I
(
5 am aware of were the result of inconsistencies between 6
the analysis that was performed on the plant and the 7
hardware which B & W had yet to provide on that plant.
8 The problem solution usually required either re-analysis 9
or change to the hardware.
The nature of Allen's 10 request to me on the SMUD light bulb incident was more 11 along the lines of please provide a review of the lesson n
12 we learned at SMUD to determine if there are improvements
(
)
%,s e
13 that could be made to the plants which we were still 14 designing.
I wouldn't include Allen's request in the 15 category of a generic problem to be solved.
16 Q
You said that you understood part of the 17 assignment from Allen Womack was to see if there were 18 improvements that could be made in the plants.
Did you 19 understand that those improvements could include 20 improvements in the hardware?
21 A
Yes.
d 22 Q
And did you understand that those improvement s 23 could also include improvements in recommended operating O
_)
24 procedures or emergency procedures?
25 A
I don't at this time' recall the exact words in
1 Karrasch 414 O
2 Allen's request to me.
I do recall focusing my attention 3
only on the design features of the plant.
4 Q
Are you aware of analysis that was done at
(
5 B & W during the time that you were head of the Plant 6
Integration 'Section concerning a break in the pump 7
discharge line?
Do you know what I am referring to?
8 A
I am not specifically aware of what you ar'e g
referring to.
10 Q
Do you recall that in 1978 B & W notified 11 the NRC that it had previously failed to analyze small 12 break loss of coolant accident occurring in the discharge
(~)
13 line between the reactor coolant pumps and the reactor 14 vessel?
15 A
Yes, I am vaguely aware that there was such a 16 problem.
17 Q
You do recall that there was, work done at 18 B & W on analyzing such a break in the pump discharge 19 line?
20 A
I recall that there was a problem related to pump 21 discharge line break.
I am not at all aware of the 22 analysis that was performed or the details of the way 23 it was resolved.
()
24-Q I show you GPU 378, Mr. Karrasch's monthly 25 report to Don Roy dated May 2,
1978, subject:
April
,w
=-.y e
1 Karrasch 415 f~)
LJ 2
Activities Report.
3 (D c" ment above referred to so marked as 4
Plaintiffs' Exhibit GPU 378 for identification, 5
as of this date.)
(
6 Q
I call your attention to item D on page 3.
7 Is GPU 378 a copy of an activities report 8
which you prepared for April 19787 9
A Yes, it is.
10 Q
Was it the purpose of your activities report 11 to describe to the manager of Plant Design and to the 12 others whom you sent copies what Plant Integration was
~
ig working on and what Integration had accomplished in the
~
14 past month?
15 A
The intent of the activity report was to report 16 significant accomplishments and status of problems which 17 we were working on which were significant.
18 Q
Have you read all of the text for the item 19 which you lettered "D"
on page 3 of GPU 378?
20 A
Yes, I just read it.
21 Q
Does that refresh your recollection as to L
22 some of the details of B & W's work on the pump 23 discharge line break?
[~))
94 A
Yes, it does.
~
25 Q
What was Plant Integration's involvement in
1 Karrasch 416 O
2 the work in 1978 on the pump discharge line break?
What 3
I am really asking is since I assume your monthly report 4
is not meant to be an NPGD newsletter tallina what all 5
of NPGD is working on, I assume there is some part of 6
the work on pump discharge line break which was 7
specifically being performed in Plant Integration and 8
that is wl.at I wanted to ask you to focus on.
9 A
I very vaguely recall that either Lou Cartin or 10 Eric Swanson were asked by Don Roy to coordinate the 11 resolution of this problem.
The majority of the work 12 was performed in Bert Dunn's ECCS Analysis Unit, and Os_
e 13 the only role that I recall Plant Integration played 14 was that of scheduling work and monitoring it to insure 15 that it got completed in a timely manner.
16 Q
Did your group managers submit monthly 17 activities reports to you?
18 A
Yes, they did.
19 Q
Did you as a general rule prepare your 20 monthly report based on, in large part, the monthly 21 reports which your group managers had submitted to you?
22 A
Yes, that's correct.
23 Q
So what appears in item D is something that 24 would have been prepared from a monthly report submitted 25 by Swanson?
l 1
Karrasch 417
, ~b N]
2 A
I don't know for sure who prepared the words in 3
item D.
4 Q
In item D (1), do you see where you have
(
5 described the operator action that has to be taken?
6 A
I see the words in item D (1), yes.
7 Q
Do you recall that part of the solution to 8
the pump discharge line break problem was for B & W to 9
recommend a new procedure for the operation of the high 10 pressure injection system?
11 A
No, I really don't recall the procedure for 12 performance of high pressure injection system.
[
)'
13 Q
Do the words that you wrote in D (1) indicate 14 that part of the solution to the pump discharge line 15 break problem was to change the procedures for operation 16 of high pressure injection?
17 A
I don't recall writing these words.
18 Q
That is your signature at the bottom, isn't 19 it?
20 A
Yes.
21 Q
I am just asking you what your understanding C.
22 is.
If you don't recall writing them but you do have a
23 recollection of what the words mean, I would like that.
rms
(
)
24 If you don't have a recoll'ection from 1978 of what those v
25 words mean, since you wrote this, I would like to ask
1 Karrasch 418 r~s 2
you what you would understand your own words mean as you 3
read them today.
3 4
A I think the words.in front of me speak for
(
5 themselves.
6 Q
You mean you think it is pretty clear what 7
that means?
O A
It means no more to me than the words themselves, 9
if I were to read them back to you.
10 Q
As the author, do you understand that those 11 words that you wrote in D (1) mean in response to B & W's 12 analysis of the pump discharge line break each of the
~'
13
- affected B & W customers, established or adopted a 14 revised procedure for the operation of the high pressure 15 injection system?
16 MS. VAUGHN:
I think I am going to object 17 to the form of that.
I am not sure those words 18 cay that at all.
~
19 MR. SELTZER:
I am asking him.
That is my 20 question.
21 Q
Is that what those words mean?
22 A
I am not familiar enough with the background of i
23 this item D (1) to interpret.any meaning beyond exactly i
' 24 what the words themselves state.
I can read it back to 25 you, if you would like.
i
1 Karrasch 419 bO 2
Q No.
I think I can read also, although I 3
appreciate the offer to read it to me.
4 Are you saying that your words do not convey J
(
5 any meaning to you one way or the other about whether 6
the customers were adopting a new procedure for operation 7
of high pressure injection?
Are you saying you can't
,1 8
tell from reading your own words whether the customers 9
were adopting a new procedure for the operation of HPI?
10 Let me phrase it positively.
Looking at your 11 words, can you tell me whether the customers were 12 establishing a new or a modified procedure for the s_
13 operation of high pressure injection?,
14 A
I don't recall any of the background leading up to 15 item D (1), in this report.
The words do state that each
~
16 of the affected customers has established a procedure 2
17 to perform some action within the first ten minutes 18 following ESFAS actuation.
19 Q
And your words are not sufficiently -- I 20 hear you are saying what the words say explicitly.
I am 21 just asking you, yes or no, can you tell me whether your 22 words tell you today that the operators were adopting a 23 new procedure?
)
24 MS. VAUGHN:-
I think he already answered it.
4 25 MR. SELTZER:
What is the answer?
... ~
e t'm'~
N P'--
F-*
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f-"-**'~*r-'
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1 K'arrasch 420 lv 2
MS. VAUGHN:
He says he doesn't remember.
3 He doesn't remember enough one way or the other.
4 MR. SELTZER:
Now I want present understandin g.
(
5 MS. VAUGHN:
Of what?
6 MR. SELTZER:
Whether those two sentences 7
that he wrote indicate to him that the operators i
8 were adopting a new or revised procedure for HPI 9
operation.
10 MS. VAUGHN:
I think he akswered that the 11 words say just what they say and he can't answer 12 anything beyond that.
V 13 MR. SELTZER:
It is a simple yes or no.
14 Q
Do the words indicate or don't they indicate 15 that the operators were adopting a new or revised 16 HPI procedure?
17 MS. VAUGHN:
Can you answer -that?
18 Q
If you want to say you can't tell, just say 19 that.
20 A
I can't tell from this.
21 Q
That is an answer.
I am not pressing --
[
22 MR. WISE:
Let's not get into that sort of 23 conduct.
O)
(_
24 MR. SELTZER:
Fine, but I don't want him to 25 anguish over it.
I don't want him to think I am
1 Karrasch 421' G
i 2
putting him through a wringer here.
If he can't 3
tell, that is a good answer.
4 Q
I show you GPU Exhibit 92, which is a copy
(
5 of a letter from your manager of Licensing, Jim Taylor, 6
to the NRC dated May 1, 1978, with a blind copy marked 7
to you, Mr. Karrasch.
8 Is GPU 92 a copy of a' letter and a report 9
which you received in or about early May 19787 10 A
I don't recall ever receiving or. reading this.
11 Q
Take a look at the operation action section g
12 on page 5 and continuing onto page 6.
If you could
%Y 13 read that and then tell me whether that refreshes your 14 recollection that you knew in 1978 that part of B & W's 15 solution to the pump discharge line break problem was 16 to recommend a change in the procedure for operation of 17 high pressure injection.
18 MS. VAUGHN:
Do you understand the question?
19 THE WITNESS:
Please read the question back.
20 (Question read.)
21 A
I don't recall reading this in 1978.
22 Q
It does not refresh your recollection?
23 A
Therefore, it does not refresh my* recollection O)
\\m, 24 of what I knew in 1978.
25 Q
I show you GPU Exhibit 90, which is the
1 Karrasch 422 O
l 2
report of the preliminary safety concern for this pump 3
discharge line break problem.
As the manager of Plant 4
Integration, you had a specific role in the preliminary 5
safety concern procedure; is that right?
1 6
A Yes, I did.
7 Q
Part of that role was evaluation of the 8
safety concern, right?
9 A
My understanding of the procedure in 1978 was t
10 that Licensing had the lead responsibility for 11 evaluating the safety concern.
Plant Integration 12 provided a review function of the safety concern to 1r assure that all interfaces amon'g the various analysis 14 and hardware units had been addressed and to review 15 any corrective action to assure that it,was indeed the 16 proper corrective action to take.
17 Q
Was that procedure in effect'in the spring j
18 of 19787 I
19 A
To the best of my knowledge, yes.
20 Q
Did you have a procedure in the spring of 21 1978 for assigning the Plant Integration review functions
(
22 on preliminary safety concerns to anyone within your 23 unit?
24 A
I don't recall a formal procedure.
My practice 25 was normally to delegate the review of the preliminary y
,c
- - -. ~,
9
1 Karrasch 423 V
2 safety concerns to the most capable person in the unit 3
to perform the review.
\\
4 Q
Was there any one particular person whom you 5
were relying upon for that review in the spring of 19787 6
14 S. VAUGHN:
For the review of this or for 7
the review of any PSC7 8
MR. SELTZER:
For the review of any PSC.
9 A
No, there was not one particular person designated 10 for the review of any PSC.
11 Q
Do you recall assigning anyone to perform
(}
12 any review function in connection with the pump discharge 13 line break PSC7 14 A
I don't know exactly who I delegated this 15 preliminary safety co,ncern to.
16 Q
Is there a small group of people among whom 17 you believe the individual is to whom you assigned this?
18 A
I didn't understand the question.,
19 Q
What I am trying to find out is analogous 20 to the situation where you think you sent Hallman's
(,
21 request to either Swanson or McBride, but you are not 22 sure which, is there a similar group of people, one of 23 whom you believe you gave this preliminary safety 3
s
\\_
24 concern to?
25 A
I don't know for sure.
I do note that Lou cartin's
1 Karrasch 424 gg O.
2 name is on the distribution list for the May 1st, 1978 3
letter from Taylor to the NRC.
Lou Cartin did work in 4
Plant Integration.
5 Q
Are you saying that it is possible that Lou t
6 Cartin is the person whom you assigned to work on this 7
PSC?
8 A
That is possible.
9 Q
When B & W developed corrective action to s.
10 respond to a PSC, did you make it a practice to review 11 the proposed corrective action?
12 A
Yes, I believe that we did.
13 Q
If one of your engineers reviewed'the 14 proposed corrective action, was it your practice to take 15 a look at that proposed corrective action before it was 16 communicated to customers?
17 A
Yes, I would say.so.
18 Q
I show you GPU Exhibit 91, which is a letter 19 from Jim Taylor to the NRC dated April 14, 1978 20 concerning the pump discharge line break.
The third
(
21 page from the back is headed " Corrective Action."
Do 22 you see that?
23 A
Yes, I have that page in front of me.
O 24 Q
Before B & W would notify the NRC of 1
25 proposed corrective action, pursuant to Part 21, was it
1 Karrasch 425 2
your practice to review that proposed corrective action?
~
3 A
I recall that Integration was required tc sign the 4
evaluation report prepared by Licensing.
On most 5
occasions, I delegated the review of that evaluation 6
report to appropriate members of my staff.
They would 7
then recommend to me that it be either signed or 8
mcdified.
On the majority of the evaluation reports 9
which I was asked to sign, I did read them.
I do not i
t 10 recall this specific one.
11 Q
The Rancho Seco light bulb event took place
,-w 12 sometime early in 1978, to the best of your recollection; V
1,3 is that right?
i 14 A
Yes, to the best of my knowledge.
15 Q
In January 1979 the Rancho Seco plant had
)
16 a second overcooling incident similar to the one that 17 had taken place in early 1978; is that right?
18 A
Yes, to the best of my knowledge 19 Q
Prior to that second overcooling event at 20 Rancho Seco, had you done anything to put together the 21 team of engineers to evaluate the first Rancho Seco 22 overcooling event as you had been requested to do by 23 Allen womack?
O)
(.
24 A
I don't recall if any-action was taken in response 25 to Dr. Womack's request to form a task force to review
1
(
Karrasch 426 i
e 1
the SMUD light bulb incident.
3 Q
As of January 1979, to your knowledge, had 4
B & W produced any effective recommendations or 5
follow-through on corrective action for the underlying causes 5f the overcooling transient at Rancho Seco?
MS. VAUGHN:
I object to the form of the 8
question.
Q I am just asking for your knowledge.
O A
As a result of the SMUD light b lb incident, I 11 recall preparing a memorandum which I sent to Nuclear h
Service which suggested action that our customers could
=
uJ 13 take as a result of the.inciden't.
I really don't recall 14 today what happened to that memorandum.
15 Q
That was your March 1978 memo.
A Y e,s, I have in front of me GPU Exhibit 306, and 17 that is the memorandum to which I referr'ed.
18 Q
What is the date of it?
A The date is March 29, 1978.
20 Q
Do you know whether any of these
{
21 recommendations were followed through to the point of 22 sending any of them out to custoners?
23 A
I vaguely recall that some follow-up action was Oh o*4 taken to send this to some of our customers.
I don't 25 know the specific time nor the specific customers.
l 1
Karrasch 427
[\\
's./
1 2
Q After the second overcooling transient at J
l 3
Rancho Seco in January 1979, did Dr. Womack speak to you 1
4 about his August 1978 request that more work be done 5
to analyze the Rancho Seco rapid cooldown transient in 6
order to reduce the likelihood of such an event in the 7
future?
8 A
I don't recall.
9 Q
After Rancho Seco's second overcooling 10 transient, did anybody speak to you about the need to 11 do further work on generic problems in order to prevent 12 their recurrence?
~
13 A
Again, I don't recall.
14 (Recess taken.)
15 BY MR. SELTZER:
16 Q
I would like to show you GPU Exhibit 151, 17 which is a memorandum by Joe Kelly dated' October 24, 18 1977, subject:
Report on Depressurization Event, 19 Section 1, a report on the Davis-Besse event.
20 Is GPU Exhibit 151 a copy of a memorandum
(
21 which you received from Joe Kelly in your unit in or 22 about late october 19777 23 A
I don't recall receiving this memorandum.
f\\_
24 Q
You see that you are marked for a copy?
25 A
Yes, I do.
)
l
1 Karrasch 428
[v) 2 Q
Would you read the fourth paragraph on the 3
second page of the exhibit, the page that is headed 4
" Sequence of Events."
5 Before getting this description of the 6
Davis-Besse event, you attended a presentation in 7
Training Room B at which Joe Kelly had described the 8
principal events of the Davis-Besse transient; is that g
right?
10 MS. VAUGHN:
I don't think,he testified 11 that he got this.
12 Q
Before the time that GPU Exhib't 151 was i
~
v 13 written, you attended, I think you already testified, a 14 meeting at which Joe Kelly described to you and to many 15 other B & W managers the basic facts about the 16 Davis-Besse transient; isn't that right?
17 A
I recall attending such a meeting.- I don't know 18 what date in time the meeting was held.
19 Q
Do you recall hearing Kelly describe what he 20 had learned about the Davis-Besse transient at that 21 meeting?
(
22 A
I recall both Joe Kelly and Fred Faist making a 23 Presentation on the event that had occurred at Toledo O
s/
24 Bdison, yes.
4 25 g
I would like to show you GPU Exhibit 133,
1 Karrasch 429 O
2 which is the site problem report for the Davis-Besse 3
cvent *ransmitted on october 11, 1977, with a copy 4
marked to you.
((
5 You regularly received site problem reports, 6
right, during the period that you were head of Plant 7
Integration?
8 A
Yes, that's correct.
9 Q
Is GPU Exhibit 133 a copy of a site problem 10 report which you received?
11 A
I don't recall receiving this site problem report.
12 g
I would like to show you GPU Exhibit 152, I)
\\-
13 which is a site problem report for the Davis-Besse 14 event transmitted on November 9, 1977.
15 Is GPU Exhibit 152 a copy of a site problem 4
16 report which you received?
17 A
I don't recall receiving a copy of.GPU Exhibit 152.
18 Q
The site problem report for the Davis-Besse 19 September 24, 1977 event had several incarnations.
20 Without asking you whether you recall which specific i
l 21 issue of the site problem report you received, is it i
22 your recollection that you did receive one version at 23 least of a site problem report for the Davis-Besse
()
24 September 24, 1977 event?
25 A
I don't recall receiving either one of these site
\\
i
1 Karrasch 430 V
2 problem reports.
3 Q
In other words, even though it was your 4
practice to receive a copy of each site problem report 5
as it was issued during the period you were Plant 6
Integration manager, you have no specific recollection 7
of receiving an SPR for the Davis-Besse transient; is 8
that right?
9 A
I believe that is correct, yes.
t 10 Q
Turning to page 3 of 85 in GPU Exhibit 133, 11
-would you read the second full paragraph?
12 MS. VAUGHN:
The paragraph beginning at 2134?
13 MR. SELTZER:
Right.
14 Q
Would you look at Exhibit 152, please, page 15 23 of'51.
Do you see that the sequence,of events that 16 appears beginning on that page is the same as the 17 sequence of events that was in Kelly's GPU 1517 18 MS. VAUGHN:
Do you want him to go line by 19 line?
20 MR. SELTZER:
No, I think Joe Kelly said
{
21 they are the same.
I am just asking Mr. Karrasch 22 if he notices if they appear to be the same.
23 A
They appear to be the same.
[\\'
24 Q
You already read the fourth paragraph in 25 the sequence of events, right?
1 Karrasch 431 m
2 A
Yes.
3 Q
In the fall of 1978, you knew, did you not, 4
that the Davis-Besse pilot operated relief valve had 5
cycled several times and had failed open during the 6
September 24 transient, correct?
7 A
No, I don't believe I did.
8 Q
You are saying you don't think you learned 9
during the fall of 1978 that the pilot operated relief t
10 valve had failed at the Davis-Besse tr'ansient?
11 MR. WISE:
That is not what he said.
('
12 MR. SELTZER:
I am asking..him that.
%.s 13 Q
If it helps you to have your counsel say 1
14 that, please reconsider.
15 A
Would you please restate the question?
16 Q
The question is:
Did you know in the fall 17 of 1978 that a pilot operated or power operated relief 18 valve in the Davis-Besse plant had failed,to close 19 during a trans ent at that plant, which transient had 20 taken place in September 19777
(
21 Maybe I am getting the years wrong.
I will 22 start over again.
23 Did you know in the fall of 1977 that a k'
24 pilot operated relief valve or electromagnetic relief t
25 valve had failed to close at the Davis-Besse plant
Karrasch 432 2
sometime during September 1977?
3 MS. VAUGHN:
You are fixing on the fall of 4
19777 5
MR. SELTZER:
Yes.
At the time that Kelly 6
gave the presentation to 30 or 50 managers, at 7
the time that Kelly wrote and marked you for a
" he time you were
~
8 copy on GPU Exhibit 151, at t
9 marked for a copy on at least two site problem l.
10 reports of the Davis-Besse transient.
4 i
11 A
The only thing I recall knowing in the fall of
()
12 1977 was that a loss of feed water event had occurred 13 at Davis-Besse, that Joe Kelly was dispatched to go to 14 Davis-Besse to evaluate the transient and that both he 15 and Fred Faist made a presentation to describe the 16 results of that evaluation.
17 I do not recall any details of what had 18 happened during the transient or what the cause of the 19 transient was.
I did attend the meeting where Joe and 20 Fred made the presentation.
That is all I recall.
(_
21 Q
Whatever Joe and Fred said at that meeting 22 you heard them say; is that right?
I 23 A'
I was listening to what they said, yes.
i I
\\m 24 Q
Do any of the documents'that I have placed 25 in front of you relating to the Davis-Besse September 24, h
1 Karrasch 433 s
1 2
1977 transient refresh your recollection that you knew in 3
the fall of 1977 that the pilot operated relief valve 4
had failed to close at the Davis-Besse plant?
5 A
No.
6 Q
Do they refresh your recollection that you 7
were advised in the fall of 1977 that as a result of 8-this transient the pressurizer water level rose?
9 A
No, They do not, t
10 Q
Do they refresh your recollection that you 11 knew in the fall of 1977 that the operators had
(
12 terminated high pressure injection in< response to rising 13 pressurizer water level even tho' ugh the pilot operated 14 relief valve was still open?
15 A
No, they do not.
16 Q
Do you recall that in the. fall of 1977 you 17 knew that boiling or saturation had occurred in the 18 reactor coolant system of the Davis-Besse plant?
19 A
I vaguely recall hearing that fact in the 20 presentation which Joe Kelly and Fred Faist made.
(,
21 Q
Do you recall any other transient at aB & W 22 plant occurring prior to Three Mile Island where 23 saturation occurred in the reactor coolant system?
f-
\\
LJ 24 A
I vaguely recall hearing about such an incident at l
25 Three Mile Island sometime after the Three Mile Island r
=
en
i Karrasch 434 bg 2
accident occurred.
3 Q
Prior to the Three Mile Island accident, were 4
you aware of saturation occurring at a B & W plant 5
during a transient other than during the Davis-Besse 6
transient of September 24, 19777 7
A No.
8 Q
In the fall of 1977, did you learn or do you 9
recall learning that during the Davis-Besse event the t
10 reactor coolant drain tank rupture disk was ruptured?
11 A
I do not specifically recall hearing that in the I) 12 meeting that I attended.
V 13 Q
You say that you do recall hearing that 14 saturation had occurred in the reactor coolant system 15 during the Davis-Besse transient.
What was your 16 understanding as to the mechanism that led to saturation?
17 A
I don't recall the details of the mechanism.
18 Q
What did you understand saturation 19 had occurred meant?
20 MS. VAUGHN:
Back in 1977?
(,
21 MR. SELTZER:
Right.
22 A
That there was some amount offstri.m in the reactor 7-23 coolant system piping.
L)g 24 Q
That is steam outside of the top of the 25 Pressurizer, right?
1 Karrasch 435 Ov 2
A That's correct.
3 Q
Did you have an understanding in the fall 4
of 1977 that for the water in the reactor coolant 5
system to reach saturation, there either had to have 6
been a depressurization or a rise in temperature above E
7 normal?
4 8
A Yes, I think I understood that in 1977.
9 Q
So you understood in the fall of '77 that t
10 during the Davis-Besse transient there 'had either been.
11
'a temperatura-excursion going up or a sudden 12 depressurization, right?
13 A
Yes.
14 Q
Does anything that you have seen this 15 morning or that you have just been testifying to refresh 16 your recollection that you knew that the chain of 17 events leading to saturation at. Davis-Besse included 18 depressuriz.ation through an open pilot operated relief 19 valve?
20 A
No, they do not.
21 Q
Since the Three Mile Island accident, have 22 you ever discussed with Joe Kelly what.it was that he 23 said to the 30 to 50 B & W' managers in,his presentation
]
~
s,)
24 with' Fred Falst-shortly.af ter: the Davis-Besse ' event?
25 A.
No, I don't believe I have discussed that event
1 Karrasch 436 v/
2 with Joe Kelly since the Three Mile Island accident.
3 Q
Since the Three Mile Island accident, have a
4 you discussed with Joe Kelly any of the reasons why he 5
wrote his November 1, 1977 memorandum regarding operator 6
termination of high pressure injection?
7 A
I don't recall any discussions with Joe Kelly on 8
his November 1st, 1977 memorandum.
9 Q
Are you aware of any incident prior to the 10 Three Mile Island accident in which a pilot operated 11 relief valve at aB & W plant failed to close?
12 What I am asking is do you recall knowing i
13 before the Three Mile Island accident.about any B & W 14 plant at which a pilot-operated relief valve failed to 15 close?
10 A
I really cannot remember any at this tine.
17 Q
Before the Three Mile Island case, were you 18 aware of any B
'& W plant at which the reactor coolant 19 drain tank rupture disk had broken?
20 A
I recall such an occurrence-at the Oconee nuclear 21 station a very long time ago, and the thing I recall 22 about it is the fact that insulation had been broken 23 off of the lower part of the steam generator.
I don't x-24 recall when.
25 Q
That was an event that occurred in or about 1
1 Karrasch 437 2
1975, is that right, or around there?
3 A
I don't know.
I am quite sure it was prior to 4
Three Mile Island, too.
(: '
5 Q
What was your understanding before the Three 6
Mile Island accident regarding what had popped the 7
rupture disk at Oconee?
8 I will withdraw that.
9 Did you understand before the Three Mile i
10 Island accident that the reactor coolant drain tank at 11 B & W-designed plants receives steam vented from the 12 pressurizer?
13 A.
Yes, I did know that.
14 Q
Was it your understanding that the cause of 15 the rupture disk blowing at the oconee plant was a 16 release of steam from the Oconee pressurizer?
17 A
To the best of my knowledge, Irech11thatbeing 18 the reason, yes.
19 Q
Did you know which valve on the top 20 of the pressurizer at oconee had released the steam
(
21 which then pushed open the rupture disk?
22 A
No, I did not.
23 Q
Is it your understanding before the Three
\\#
24 Mile Island accident that the Oconee pressurizer had 25 on the top of it'two code safety valves and a.
-l
1 Karrasch 438 O
2 Pilot operated relief valve?
A Yes, to the best of my knowlede.
3 4
Q Was it also your understanding that the 5
Pilot operated relief valve at the Oconee plant was 6
set to open at a lower pressure than the code safety 7
valves?
8 A
Yes, I was aware of that.
e 9
Q Do you recall that at the end o'f 1978 and 10 into 1979 work was done to analyze what is known as the 11 Pumps running case?
12 A
I am afraid you will have to be more specific.
I, O
13 don't know what " pumps ranning case" means.
14 Q
It means leaving the reactor c6ol,ing pum s 15 on during a loss of coolant accident.
4.g 16 A
I recall being aware of such an evaluad on after 17 the Three Mile Island accident.
I don',t reca'11 any 7-
..s s
18 activity-on that prior to Three Mile Island.
S s
19 Q
I take it you haven't looke'd at your sd q % ' N,
.y 20 December'1978 progress report recently.* Let me mark a
21 that as GPU Exhibit 379.-
It is a Karrasch.to Womack
{
I P ece dated Jaisuary.3, 1979.
i i
l 22 N
23 (Document above described so marked as i,ke,a^tDn, 24 Plaintiffs' Exhibit GPU'379 for.ident T*
i l
25 as of this date.)
e<
.s (l
l
']
1 Karrasch 439 p
O 2
Q Do you see the last paragraph on page 37 3
A Yes, I see it.
4 Q
Is that part of a progress report which you 5
prepared and sent to your boss covering the month of 6
December 1978?
7 A
Yes, it is.
8 Q
Does that refresh your recollection that 9
there was work being done in December 1978 to evaluate i
i 10
. primary coolant pumps running during a loss of coolant 11 ac'c'ident?
12 A
Yes, it refreshes my memory that such work was 13 uhder way.
I don't recall being directly involved in 14 that work.
L 15 Q
In other words, it refreshes your
- 4-16 recollection that work was being done on that problem 17 befo're the Three Mile Island accident, right?
~
~\\
. 18 A
's The words in this progress report demonstrate "T:. ;
^
19 that work was under way.
My memory doesn't recall any 20 such work or any direct participation on my part in
{,.
21 such work.
w, 22 Q
I would'like to show you GPU Exhibit 122, s_
x i-23 which is a memo from Lou Cartin in your section, subject:
. (~) '
k l.
24 TECO status report, December 19, 1978, with a copy marked u
25 for you.
~,
M -
A _
,n g -.
n p
y
-4
- -, ~ -
1 Karrasch 440 0
2 Is GPU Exhibit 122.a copy of a memo which 3
Eric Swancon on behalf of Lou Cartin sent 3 you?
4 A
I don't recall seeing or reading this memorandum 5
in December 1978.
6 Q
Do you recall seeing or receiving it ever 7
before today?
8 A
No, I do not recall ever seeing this memorandum 9
before today.
(
10 Q
Cartin was in Swanson's group at the time that 11 this memorandum was written; is that right?
12 A
To the b'est of my knowledge, yeg.
gx e
13 Q
were you aware in late 1978 that Cartin was 14 working on supporting Tcledo Edison Company in its 15 attempts to resolve NRC concerns relating to the 16 Davis-Besse plant?
17 A
I don't recan that that was one of his specific 18 work assignments.
19 Q
Take a look at item 6 on page 2.
20 Have you read that item?
21 A
Yes, I just read it.
22 Q
The second sentence in that item says, "If 23 questioned by the NRC, however, B & W must be in a
\\s}
24 position to state that the small break topicals have 25
' considered the worst possible conditions (i.e.,
loss of
1 Karrasch 441 2
off-site power).
Our inability to respond conclusively to such an inquiry could result in the NaC derating or 3
4 shutting down all of B & W's 177 FA operating plants 5
excePt SMUD until the issue is re s olved.
6 Did Cartin or Swanson ever discuss with you 7
any proposal that the NRC not be responded to g
conclusively because a' response to the NRC could result in derating or shutting down all B & W 177 plants?
9 10 A
I do not recall any such discussions.
11 Q
At any time after mid-December, 1978, did 12 you ever tell Swanson or Cartin that they or B & W 13 should not shrink back from disclosing. things to the NRC 14 because it could result in derating or shutting down of 15 B & W plants?
16 A
I do not believe that I did.
17 Q
Do you recall that prior to December 1978 18 B & W had assumed that pumps off during a loss of 19 coolant accident was a worse case than attempting to 20 leave the pumps running during a loss of coolant accident?
21 22 A
I don't recall ever making such a distinction for 23 B & W small break loss of coolant accident analysis.
't3 24 Q
You knew for small break loss of coolant 25 accidents B & W's analysis had always assumed a loss-of
1 i
1 Karrasch 442 V
2 off-site power, didn't you?
3 MS. VAUGHN:
Prior to December '787 4
MR. SELTZER: Right.
5 A
I do recall that loss of off-site power was an 6
assumption made for the safety analysis work performed 7
in Danny LaBelle's group.
I don't recall being aware 8
that that was always the situation in the ECCS analysis 9
performed in Bert Dunn's group.
6 10 Q.
Does GPU Exhibit 379, which is your December 11 monthly report, refresh your recollection on that subject?
(
12 Take a look at the second sentence in your last paragraph 13 on page 3.
14 A
I still do not recall being aware of or personally 15 involved in this situation in December 1978.
16 Q
Do the words that you have written in your
~
17 December 1978 progress report indicate to you that the 18 assumption being made in B & W's small break LOCA 19 analysis pror to December 1978 was that the reactor 20 coolant pumps would be shut off?
(,
21 A
The words in this exhibit state that small LOCA 22 has been evaluated assuming a loss of off-site power.
23 That assumption would result in a loss of reactor O
24 coolant pumps.
l 25 Q
Do you see the third sentence that you wrote I
1 Karrasch 443 0
2 in that paragraph?
3 A
I don't recall writing these words.
4 Q
I just asked if you see them.
5 MR. WISE:
No, you asked a different 6
question.
7 Q
I said, do you see the words in your third 8
sentence in that last paragraph?
9 A
Yes, I see the words, t
10 Q
You wrote those words, right?
11 MR. WISE:
He just testified that he didn't.
12 MR. SELTZER:
No, he didn,',t testify that.
~
8.
13 Q
You wrote.this report, didn't you, GPU 3797 14 A
I do not recall writing the words in item III A 15 in this report.
16 Q
Do you believe that those words were written 17 by anyone else other than Bruce Karrasch?
18 A
I just don't know who wrote the words.
19 Q
Do you have any reason to believe that 20 somebody other than you wrote those words?
21 A
I really don't know.
22 Q
You don't know of any reason to believe that 23 somebody else wrote those words?
Is that what you are
( T.
U 24 saying?
25 A
My normal process in preparing monthly progress
~
' ~ ' ' ~ ' ~ " "
l l
l l
1 Karrasch 444 I
2 reports was to take input from my staff and use it to 3
put together what I consider significant items to report 4
to Dr. Womack.
I really don't know who wrote those 5
words.
6 Q
You put this report together for Dr. Womack, I
l 7
right, GPU 3797 f
8 A
That was my normal practice.
I don't recall for I
9 sure if I put this specific report together.
t 10 Q
Is that yourhandwriting at-the bottom of l
11 page 37 12 A
Yes, I believe I did initial this report.
13 Q
To the best of your recollection, did you 14 wr'ite or assemble what now appears within GPU Exhibit 15 3797 4
16 A
I don't recall.
17 Q
Looking at the last paragraph above your 18 signature, you have the sentence, the third sentence in 19 that paragraph, "The validity of the assumption to 20 produce the most limiting LOCA consequences (small break)
)
(
21 is now being evaluated."
22 What does the phrase "the most limiting LOCA 23 consequences" mean to you?
p).
\\_
4 MS. VAUGHN:
Mean to him now?
?-
E5 MR. SELTZER:
Yes.
1 Karrasch 445 I\\
V 2
A It would mean to me that it is that the most 3
conservative analysis had been performed in accordance 4
with the regulations and requirements to perform such an 5
analysis.
6 Q
Does the phrase "the most limiting LOCA 7
consequences" refer to consequences which produce a 8
worst case?
9 A
I am not sure I understand what you mean by the t
10 words "a worst case."
My understanding of the LOCA 11 analysis is that certain basic assumptions are used to
[~')
12 prepare an analysis, which then yields results'which V
13 are compared to some established acceptance criteria.
14 The most limiting LOCA consequences implies to me that 15 that analysis is conservative.
16 Q
What do you mean, that it is conservative?
17 Let me try to help.
Whenyohsaythat it 18 is conservative, do you mean that the ana1ysis bounds 19 all other breaks that are possible to occur?
20 A
I am not familiar with the details of the
(_
21 requirements for conducting small break LOCA analysis.
22 I do know that there are a set of rules which we follow 23 which are used to assure that the analysis is conservative 24 and does cover a spectrum of break sizes.
25 I see the words " limiting LOCA consequences."
w->
,-w w
1 1
Karrasch 446 i
2 It implies to me that the analysis is performed in 3
accordance with the conservative assumptions that we 4
must use.
5 Q
Let me switch back to GPU Exhibit 122, which 6
is a copy of Cartin's memo which he indicates he was 7
sending to you.
In item 6, the sentence 2,
Cartin and 8
- Swanson, who signed this, say, "If questioned by the 9
NRC, B & W must be in a position to state that the small 5
10 break topicals have considered the worst possible 11 conditions."
()
12 Was is your understanding that in order to 13 comply with NRC griteria, B & W had to be in a position 14 to state that its analyses had considered the worst 15 possible conditions?
16 A
No.
I don't think that the words " worst possible 17 conditions" reflect the analysis we tried to perform.
18 Q
Do you have to reflect as you understood it.
19 in 1978 the worst possible credible conditions?
20 A
Again, I am not familiar at all with the
(,
21 requirements on what conditions we must consider, but I 22 do believe that there is a well defined set of analysis 23 methods, analysis inputs, and acceptance criteria for l
O 24 results in LOCA analysis which we must use to show an 25 acceptable and safe plant.
l
l I
Karrasch 447 g--
2 Q
Did you know in 1978 that you had to have 3
studied the maximum credible accident?
4 A
Yes.
5 Q
What does that mean, the maximum credible 6
accident?
7 A
Again, I am not exactly sure of the details, but 8
my understanding is that the maximum credible accident 9
has historically been the large break loss of coolant i
10 accident.
11 Q
Did you also understand that for small break L}-
12 loss of coolant accidents B & W had an obligation to 13 study the worst possible conditions that could result 14 from small breaks?
15 A
I really can't attach any meaning to the words 16
" worst possible conditions."
I don't know what they 17 mean.
18 Q
You don't understand what my question means 19 when I said did you know that B & W had to study the 20 worst possible conditions that could result from a small
(,
21 break LOCA?
l 22 A
I don't know what the words " worst possible 23 conditions" mean.
< ~.
24 Q
You testified a moment ago that you understood 25 that B & W had an obligation to analyze the largest
1 Karrasch 448
/,s
()s 2
credible break that could occur in the reactor coolant 3
system.
Did you also understand that B & W had an 4
obligation to examine the consequences of break sizes 5
that were less than the largest possible break in the 6
7 A
Yes.
8 Q
Did you understand that B & W had to determine 9
what were the consequences of breaks that were less than t
10 the largest break that could occur in 'the reactor coolant 11 system?
[d~)
12 A
Yes, to the best of my knowledge, 13 Q
Did you understand that that included 14 determining what were the worst consequences that could 15 happen from a break that was smaller than the maximum 16 break that could occur in the reactor coolant system?
17 A
I am really having trouble with your words " worst 18 conditions."
19 Q
Was it your understanding in 1978 that B & W 20 just had to come up with some of the consequences of a
(
21 small break, but if you missed the worst consequences,:
22 that didn't matter?
23 MR. WISE:
Mr. Seltzer, I really think that 24 you are badgering this witness unnecessarily.
25 MR. SELTZER:
I am trying to use a very
1 Karrasch 449
{a~T 2
docile voice.
I am trying to be very calm about 3
this.
I don't understand, and I think if I 4
approach it differently, maybe the witness.will 5
understand it.
6 Q
I can't conceive how you could do a LOCA 7
analysis of break sizes that would not anticipate the 8
worst consequences and I think that you had told the NRC 9
everything that you should about a certain size break.
t 10 MS. VAUGHN:
Mr. Karrasch has testified 11 that he is not f amiliar with -the details of how
()
12 it was done, but that it was only his understanding.
13 Within the confines of a general understanding, 14 he may not be able to answer your question.
15 MR. SELTZER:
If he can't answer it, that is 16 0.K.,
because if the head of Plant Integration 17 doesn't know that a vendor is supposed to study 18 the worst possible consequences, that is probably 19 not a bad result for us.
20 MR. WISE:
I think part of the problem is
(,
21 the question of assumptions.
If you want him to 22 assume that a utility trains its operators poorly, 23 so they do something they are not supposed to do, 24 the way you phrase the question, the worst 25 possible consequ.ences, I could imagine a number of
-.~
1 Karrasch 450 2
consequences of operator error and utility 3
malfeasance which could result in rather horrible 4
consequences.
5 If you are implying that the NRC required 6
B & W to assume malfeasance by the utility, as an 7
example,#it seems to me that you have added a 8
condition to your question that makes it very 9
difficult for this witness to answer.
't 10 MR. SELTZER:
I certainly wasn't adding 11 that condition which you have suggested.
I 12 MR. WISE: I think the witness testified that
%r 13 there are various* criteria which people in the 14 LOCA analysis field would~be more aware of than 15 he is as to the conditions under which you must 16 analyze a LocA, and there are certain assumptions 17 about what will work, whatwouldn'ywork, what 18 -
you can take credit for, and what you can't take 19 credit for, and he testified he is not familiar 20 with the details on how bad things must get for
(
21 you to assume that analysis.
, 22 MR. SELTZER:
Let's see if I can ask 23 something different then.
\\"
24 BY MR. SELTZER:
i 25 Q
Did you learn sometime after the beginning
i 1
Karrasch 451 m
2 of December 1978 and at any time up to today, that the 3
consequences for a small break loss of coolant accident 4
could be more severe if the reactor coolant pumps were 5
left on following the onset of a transient than if the 6
reactor coolant pumps were shut off at the start of a 7
8 A
I understand the question.
Would you please 9
clarify the time frame again for me?
10 Q
Any time up to today.
4 11 A
Yes, I was aware that such a question came up 12 sometime after the Three Mile Island accident.
I recall 13 such a question coming up.
7 14 Q
And are you. aware that B & W's analysis 15 showed that the consequences were wor'se,,for'certain 16 small break accidents in which the reactor coolant pumps 17 were left on than for the same postalated break size and 3
18 location if the pumps had been shut off at the start of 19 the transient?
20 A
I am vaguely aware that sometime after Three Mile 21 Island 2
that ECCS performed analysis to determine 22 the impact of leaving the reactor coolant pumps running 23 during a small break loss of coolant accident.
Again I 24 am unfamiliar with the details of that analysis.
25 Q
Are you aware of this result of that analysis,
e
~
e,
.,_omn-w-
,,.-,,sr--.
7 w,
1 Karrasch 452 g
km l
2 and I am not asking about any other results of the l
3 analysis.
Are you cuare that the analysis done at 4
B EW showed that there were worse consequences that
(
5 followed leaving reactor coolant pumps on for certain 6
small break LOCA's than would follow from shutting off 7
the reactor coolant pumps at the start of the transient l
8 for those same small break LOCA's?
In other words, 9
did you ever hear there was a class of small breaks for 10 which it was worse to leave the pumpstrunning than it 11 was to shut them off?
12 A
I don't recall ever understanding'that it was O
13 worse to leave the reactor coolant pum,ps running during 14 a small break LOCA.
15 (Luncheon recess taken at 1:00 o' clock p.m.)
16
-coo-17 e
18 19 20 C.
22 23 O
24 25
1 453 2
AFTERNOON SESSION 3
(2:15 p.m.)
4 B R UCE AD0 LP H KARRA S CH having
(
5 been previously duly sworn, resumed and testified 6
further as follows:
7 EXAMINATION (continued)
O BY MR. SELTZER:
9 Q
You are aware, are you not, that your 10 testimony this afternoon continues to be under oath?
11 A
Yes, I am.
12 Q
After the Three Mile Island accident, B & W 13 communicated to the NRC revised instructions for whether 14 te reactor coolant pumps should be on or off after the 15 start of a transient.
Do you recall that?
16 A
Yes, I am aware that that situation was evaluated 17 and that there were communications with the NRC.
18 Q
Do you recall that there was t point in time 19 after the Three Mile Island accident when B & W was 20 recommending that the reactor coolant pumps be left on 21 during a transient?
22 A
Again, I was not intimately involved in the work 23 nor the decision-making that went on in this issue.
I O
A_)
24 do recall that I was aware that there were many 25 discussions within B & W on how to resolve the issue.
I
1 1
1 Karrasch 454-O t
2 am not aware of the details.
3 Q
I show you GPU Exhibit 262, which is a
)
4 preliminary safety concern report for the pumps running 5
problem dated May 31, 1979.
You are marked for a copy 6
on this.
7 In the spring of 1979 at or about the time O
that GPU Exhibit 262 was written, was it still your 9
function as the manager of Plant Integration to review
(
10 all reports of preliminary safety concern?
~
11 A
Yes, it was.
['),
12 Q
Do you recall reviewing or assigning someone U
13 to review the safety concern reflected in GPU Exhibit 14 2627 15 A
No, I do not recall this safety concern in GPU 16 Exhibit 262.
17 Q
Take a look at the last page of the exhibit, 18 which is the second page of a memo written by Bert Dunn 19 to Kane.
Bert is reporting on his conversation with a 20 gentleman of the terrific name of Zoltan Rosztoczy.
(
21 Did you know Dr. Rosztoczy?
22 A
No, I don't know him personally.
23 Q
Have you ever met him?
24 A
I have never met him.
I recall attending an NRC 25 meeting at which he was present.
1
_________________.___________.J
1
~
Karrasch 455 2
Q You shared the same room with him?
3 A
Yes.
4 Q
On the second page of Bert's memo, beginning
(:)
,5 in the first full sentence, do you see where he begins, 6
"As an overriding concern"?
7 A
Yes, I see it.
8 Q
The statement continues, "As an overriding 9
concern, I pointed out that there is no intention within t
10 the operating guidelines to cause a reactor coolant pump 11 trip during the transient and that this is true
[~}
12 regardless of pump performance variables.
In other s_-
13 words, I restated our position that at least one pump 14 per loop will run until it dies.
I confirmed that my 15 experience with reactor coolant pumps running in high 16,
void systems has shown no problems with their performance 17 and that our pump experts indicate no concern in pumping 18 a two-phase fluid."
19 Was it your understanding in 1979 that the 20 phrase "two-phase fluid" refers to a mixture of steam and
(,
21 liquid water?
22 MS. VAUGHN:
You mean his understanding 23 generally, independent of this particular memo or
[)
\\-
24 letter?
25 MR. SELTZER:
Right.
i
i 1
Karrasch 456 O
2 A
Yes, I think that is an accurate description of 3
my understrnding.
4 Q
Were you aware in May of 1979 that there were Cr 5
people at B & W whom you considered pump experts?
6 A
Yes.
7 Q
Were you aware in the spring of 1979 that 8
based on B & W's experience and the knowledge of experts 9
at B & W reactor coolant pumps were able to run in high t
10 void systems with no problems in their performance?
11 A
No, I really was not aware of that.
"i 12 Q
Did you have any knowledge about the ability
-)
"13 of reactor coolant pumps to perform in two-phase fluids 14 or with highly voided systems?
15 A
I was aware in the spring of 1979.that the reactor 16 coolant pumps at TMI-2 had performed and pumped a 17 two-phase fluid at various times during the accident.
18 Q
Do you know how high the void fraction was 19 during the Three Mile Island accident while the reactor 20 coolant pumps were still on?
{
21 A
No, I do not.
22 Q
So you don't know how highly voided the 23 system was with the RC pumps going?
{~w
\\
24 A'
No, I don't recall what the value of the void 25 fraction was at any time during the TMI-2 accident.
J
1 Karrasch 457 O
2 Q
At any time up until today have you learned 3
anytting about the ability of reactor coolant pumps to 4
Perform in a high void system, in other words, a system 5
that has a lot of steam and relatively little liquid 6
water?
7 A
My only exposure to that situation that I can 8
recall is my knowledge of the sequence of events of the 9
Three Mile Island 2 accident.
10 Q
You don't recall anything'else; is that what 11 you are saying?
(~
12 A
'That's correct.
%.))
13 Q
Including you don't recall what Dunn said 14 on the last page of GPU Exhibit 262 for which you are 15 marked for a copy?
16 A
That's correct.
I don't recall ever seeing Bert's 17 letter to Ed Kane of May 29, 1979.
18 Q
Do you recall ever receiving GPU Exhibit 262 19.
from Jim Taylor on which he marks you as the second 20 Person in the distribution list?
21 A-No, I don't think I recall,seeing this exhibit.
{
22 Q
Based on your knowledge of distribution 23 procedures, do you have any reason to believe that Jim O)
(
24 Taylor did not send you a copy of GPU Exhibit 262?
25 A
No, I do not.
b i
Karrasch 458 2
Q Did you know in the spring of 1979 that it 3
was B & W's position that at least one reactor coolant 4
pump per loop should be left on until it dies?
5 MS. VAUGHN:
Are you reading from Bert 6
Dunn's letter now?
7 MR. SELTZER:
That is what I am reading
. 8 from, but I don't think my question depends on 4
9 where I am reading from.
10 MS. VAUGHN:
It might be easier for him 11 to follow the question.
12-
.MR.
SELTZER:
Sure.
I 13 4
No, I was not aware that it was B & W's l
14 position that the reactor coolant pump should be left on 1
i 15 until it dies.
4 j
16 Q
Do you have any recollection of ever hearing
~ 17 that that was B & W's position?
18 A
I don't recall that ever being B & W's position.
19 Q
Did you do any work on the small break 20 operating guidelines that were'sent out after the 21 Three Mile Island accident?
22 A
No, I did not work on the small break cperating 23 guidelines sent out after the accident.
24 Q
Did you ever review them?
l 25 A
I recall reading the guidelines several months r
l l
i 1
Karrasch 459
[ ~t
%.)
2 after they were issued.
3 Q
Do you recall whether those guidelines say 4
that if the reactor coolant pumps are on during a
(
5 transient, they should be left on?
6 A
No, I don't recall that.
7 Q
Was it your understanding in the spring of 8
1979 that if the vibration on reactor coolant pumps 9
exceeded B & W's limits and precautions, that the 10 operators were supposed to shut the pumps off?
11 A
I was aware that there were vibration limits for 12 operation of reactor coolant pumps.
I was not aware of O
13 the, action that B & W fecommended as'a result of high 14 vib ration, that being to trip the reactor coolant pumps.
15 Q
Have you subsequently learned that that was 16 B & W's recommendation to trip the pumps if the 17 vibration exceeded the vibration limits in B & W's 18 limits and precautions?
19 A
I think I am aware of that today, yes.
20 Q
You are aware that that was the B & W 21 instruction that was in effect on the day of the 22 Three Mile Island accident?
23 A
No, I am not aware of that.
()
24 Q
You said you are aware today of that.
- Today, 25 you are aware that B & W had a recommendation that the
l' f
l I
f 1
Karrasch 460 lO 2
pumps should be tripped if vibration exceeded the l
3 vibration limits in tha limits and precautions issued 4
by B & W, and I an asking you during what period of time
(
5 did you understand that B & W had such an instruction?
6 A
Again, my only exposure to the issue of tripping 7
reactor coolant pumps due to high vibration has been 8
through my revi.ew of the actual TMI-2 incident itself.
9 I am not aware of the background or the details or the 10 rationale behind any limits and precautions or 11 recommendations to trip reactor coolant pumps.
12 Q
Are you saying you rev'iewed the procedures 13 in the limits and precautions that appli6d at the' time 14 of the Three Mile Island accident?
15 A
No, I am not saying that at all.
16 MR. SELTZER:
Could you read back the 17 witness's next to last answer?
18 (Record read.)
19 Q
When you reviewed the tripping of the 20
' reactor coolant pumps due to high vibration which 21 occurred during the Three Mile Island accident, did you 22 learn that the vibration at TMI had exceeded the B & W 23 limits and precautions?
l 24 MS. VAUGHN:
I am not sure that is exactly 25 what he testified to.
I will let him answer.
l
-_-_---___-_-___-_-__-_-_____-_-_-__---__-_A
1 Karrasch 461
' o 2
MR. SELTZER:
I hope I am asking something 3
that is a little bit of an extension of what he answered.
4 5
A Could you repeat the question?
6 (Question read.)
7 A
The only thing I recall is reviewing the various 8
write-ups of the sequence of events during the Three 9
Mile Island accident.
Several of those write-ups 10 indicated that the reactor coolant pumps were tripped 11 due to high vibration.
Again, I am unaware of what the i
12 limits are, what their basis is or any of the background 13 beyond the fact that they were tripped due to high 14 vibration.
15 Q
I am not asking you what the limits were.or 16 what the background of the limits was.
You said now 17 for a couple of times that you learned that the reactor 13 coolant pumps were tripped during the Three Mile Island 19 accident in response to high vibration on those pumps.
20 Did you learn that the high vibration which i
21 was observed on the reactor coolant pumps during the
(
22 Three Mile Island accident was. measured to be in excess 23 of the vibration limits in the B &W limits and 24 precautions?
25 A
No, I was not aware of that.
l Karrasch 462
(-)
V 2
Q Were.you aware at the time you were doing 1
3 this study and review that there were vibration limits 4
for reactor coolant pumps in the B & W limits and 5
precautions?
6 A
I really don't know what th e source of the 7
vibration limits was.
8 Q
Were you aware that there were B & W 9
announced vibration limits for the reactor coolant pumps 10 at the time of the Three Mile Island accident?
11 That is a little ambiguous.
I mean, did you 12 subsequent to the accident become aware that at the time gs sJ 13 of the accident there were B & W announced vibration 14 limits for reactor coolant pumps? And please know I am 15 not asking you what the source of those, limits was.
16 I am just asking, did you subsequently become aware 17 that there were B & W vibration limits for reactor 18 coolant pumps?
19 A
My review of the TMI accident indicated to me that 20 there were vibration limits for the reactor coolant pumps i
(
21 I don't know whether they were in the B & W limits and L
22 precautions or not.
I do not know what the source of 23 them was.
O'q,)
24 Q
Irrespective of whether they were in B & W 25 limits and precautions, you say that there were limits i
4 1
Karrasch 463
(~h q-)
2 set on the permissible vibration of the reactor. coolant L
3 pumps at the time of the Three Mile Island accident?
4 A
According to the experts that I read on the
('
5 sequence of events that told me that there were limits.
l 6
Q In what sense did you understand those were 7
limits?
What do you mean, "there were limits"?
8 A
only in the sense that those descriptions of the 9
accident stated that the operators tripped the reactor 4
10 coolant pumps due to high vibration.
-11 Q
What does that have to do with limits?
You 12 said you understood that there were limits.
13 A
Maybe I assume that if the operator tripped them, 14 based on some value, that that value indeed was a limit.
15 Again, I don't know what the source of the limit was.
16 Q
Where were you on the morning of March 28, 17 19797 18 A
I reported to work at B & W at my normal time, 19 which was sometime between 7:30 and 8:00 o' clock.
20 Q
How did you first learn that there was a 21 transient in progress:at Three Mile Island that day?
22 A
To the best of my recollection, I was informed by 23 Dr. Womack that a transient had occurred at TMI-2 early 24 that morning and that I should be aware that I may be 25-asked to assist in evaluating'that transient.
That
1 Karrasch 464
<x
(%s) 2 occurred between 8:00 and 9:00 o' clock that morning.
3 Q
Was Dr. Womack speaking just to you, or 4
4 were there other people in attendance at the same time?
(
5 A
There were other people in attendance at the same 6
time.
7 Q
Was this a meeting at which Allen Womack 8
was speaking to you?
9 A
Yes.
10 MS. VAUGHN:
What /a you mean by a " meeting"?
11 Q
What do you mean by a " meeting" when you 12 said "yes"?
13 A
Yes, it was a gathering of a small number of 14 Allen's staff in his office on the morning of March 28, 15 1979.
16 Q
When you say it was a gathering of Allen 17 Womack's staff, were these people from his Plant Design 18 Section?
19 A
Yes.
20 Q
Were most, if not all, of the managers of 21 the units in the Plant Design Section present in his 22 office for this meeting?
23 A
I don't recall who else was in the meeting.
O
"\\_)
24 Q
Did you take notes at the meeting?
25 A
I don't believe that I did.
~..
y p
1 Karrasch 465
-A 4 b 2
Q Did you have any other meetings with Allen 3
.'4omack that morning?
/
4 A
I really don't know for sore whether I did or not.
(
5 Q
Have you ever seen anyone's notes from the 6
meeting with Allen Womack on the morning of March 28?
4 7
A I don't know for sure, but I don't think so.
8 Q
- Is there someone whose notes you think it 9
is possible,you might have seen based'on your 10 recollection'i 11 A
I don't recall eeing anybody else's notes from 12 that~ meeting.
O-13 Q
What, t[o the best of your. recollection', did
.\\
14 Allen Womack say about tihe Three Mile Island Eransient?/,
./
15 A
As I recall, Allen' told us that Three Mile Island 2
/
18 had experienced a loss of,feedwater at approximately o
17' 4:00 a.m.
that morning, that the reactor.had subs,equently
/
l 18 tripped and I recall him saying that the. reactor coolant i
19 pumps were off.
He had gathered his staff Sogether to 20 alert us that this situation liad occurred and to tell
- 21 us to offer any' support we couldoif T sked'by the Nuclear
~
a
_ ~,
~ '
22
Service Department.
~
'23 That is all I recall about. the brief meeting V(3 '
'~ 24 with Allen that morning.
.~
s t
- w, 25 Q ' _-- Were you asked to do inything_else_/y Allen b
er 4 p
+/ -
g,.
a-.
l c r'-
-,-c
-,: ' c ;.
I 1
Karrasch 466 0
2 Womack that morning with respect to the Three Mile 3
Island accident?
4 A
No, I don't believe that I was.
5 Q
Didn ' t he ask you to set up an incident 6
team?
,3 s
s 7
A I don't remember him asking me to set up an 0
incident team.
s 9
Q Didn't Allen Wom'ack tell you that the 10 pressurizer had gone solid?
11 A
I don't recall hearing that.
12 told you th a't there Q
Do you remember that es 13 was a possible two-phase mixture,in E.he reactor coolant 14 system?
\\
i' s
s.
15
' 1 s
A No, I don't remember that.,
4 16 Q
The presence of a two-phas9; mixture in,the
's' 17 reactor coolant system would mean that it hit saturation, 18 wouldn't it?
q' i
19 A
Yes.
20 Q
Isn't it a fact that AAlen 'WoNack told you
{
21 at the morning meeting or sometime during"Eie morning 22 of March 28, 1979, that there was nereasing 23 radioactivity in the reactor building at ThYee Mile h
[
's 24 Island?
~"
l
.a 25 A
I don't recall hearing that du'r ing the m"orning of
N
~$
s1 Karrasch 467
- t p o
x 2
March 28, 1979.
i 3
Q, Had you ever heard of a release of
.t 4
1 \\\\ radioacti'iity into the reactor building of aB & W 5
plant during any other transient prior to March 28, 19797 6
A No, I don't believe that I had.
7 Q
Prior to March 28, 1979, had you ever heard s
l 8
of a pressurize going solid at any B & W plant?
l 9
A I vag'oely recall that the pressurizer during the 10 SMUD ligh't bulb incident was at a very'high water level.
w v.
11 I don't know if it went solid or not.
12 Q '}
Where do~'you remember that from?
13 A
I. guess I am recalling that during that incident.
14 the pressurizer safety valves were weeping a small amount.
i 15 Q
You know no'w, don't.you, that the pressurizer i
16 went solid at the Davis-Besse plant during the September 17 24, 1977 event,.right?
.t 18
.A I don't recall.
19 Q
Sitting here right.today, you don't recall 20 that the Davis-Besse pressurizer went solid on March 24, (q
21 19777 J
~
22 A'
- I L n'e ve r studied the Davis-Besse transient in 1977.
3 s w
(~ 1.{s 23-no poing',since Q
At 1977 has it ever come to
.n
~
24 your attention and stuck in your mind that the
\\
s 25 pressurizer went solid during that transient?
N t
s g
,\\
c f
1 Karrasch 468 G(~h 2
A That's correct.
3 Q
Are you aware today that the operators at 4
Davis-Besse terminated high pressure injection in 5
response to rising pressurizer level?
6 A
Yes, I am aware of that today.
7 Q
Are you aware that the reactor coolant drain 8
tank rupture disk blew open at Davis-Sesse?
9 MS. VAUGHN:
I thought we went ever this 10 this morning.
i 11 MR. SELTZER:
No, we were talking of what 12 he knew in the fall of 1977, and now I am asking p%_)
13 what he knows right now.
14 A
I am aware that the quench tank rupture disk 15 ruptured at the Davis-Besse incident.
16 Q
Do you know that the pilot operated relief 17 valve failed in its open position at Davis-Besse in the 18 fall of 19777 19 MS. VAUGHN:
Does he know that today?
20 MR. SELTZER:
Yes.
21 A
Yes, I know that today.
22 Q
On March 28, 1979, did you know that the 23 pilot operated relief valve at Davis-Besse had failed s/
24 open in a prior transient?
25 A
No, I was.not aware of it at that' time.
1 Karrasch 469 2
Q At any time during the day on March 28, 1979, 3
did you see any similarities between what you were j
4 hearing had happened at Three Mile Island and what you 5
had heard or read had happened at Davis-Besse in 6
september 19777 7
A No.
8 Q
After the meeting with Allen Womack and his 9
staff, what was your next source of any information t
10 about the pending Three Mile Island calamity?
11 A
To the best of my recollection, my next exposure
/~%
12 to the Three Mile Island accident occurred sometime
(_J.
13 after noon of that day in ancther meeting, whose purpose 14 was to determine if we had any additional data to 15 further make an evaluation of what had happened.
The 16 data we had at the morning meeting was basically againehrly in the 17 nonexistent, and we were to meet 18 afternoon to evaluate any further accumulation of data.
b 19 Q
At or after your morning meeting with Allen 20 Womack, did you ask any questions?
(
21 A
I don't recall.
22 Q
Did anybody consult with you during the 23 morning of March 28 about sending Kelly, Winks, and 24 Twilley, or any one of them, up to Three Mile Island?
i 15 A
I don't recall that either.
~
l l
1 Karrasch 470 2
-Q After the meeting with Al Womack, did you 3
just go back to your unit and conduct business as usual?
4 A
To the best of my knowledge, yes.
5 Q
Have you ever seen a copy of Wandling's 6
notes prepared on the day of the accident?
7 A
Could I see what you are referring to?
8 Q
Sure.
9 A
Yes, I have seen this before.
e.
10 Q
Other than being shown'it by. counsel, under i
11 what circumstances have you seen Wandling's notes from
-t
' N_)N
/~
12 the day of the accident?
13 A
The only time I saw this set of notes from the 14 accident was in the presence of counsel yesterday.
15 Q
Did seeing it today or revie, wing it today, l
16 if you would like to take a chance to, refresh your 17 recollection about the fact that sometime durin,g the 18 morning of March 28, 1979 you were assi,gned to lead or 19 set up a task force or incident team?
20 A
To the best of my recollection, I cannot' recall
(
21 being asked to set up a task force to lead the B & W 22 effort.
23 Q
Do you see where it s a y s '1B. Karrasch to
[ b k/
24 lead," just af ter 'hpproximately 8 :10','?
25 A
Yes, I see that.
1 Karrasch 471 dV 2
Q
'Do you see the entries after 7:45 a.m.?
3 A
on the top of the page?
4 Q
Yes.
5 A
Yes.
6 Q
Do you see the list of plant conditions 7
starting'with loss of feedwater followed by high pressure 8
injection initiate 4 turbine tripped, et cetera?
9 A
Yes, I see those.
t 10 Q
Do any of those refresh your recollection 11 that you heard about those conditions existing at the 12 Three Mile Island plant on the morning of March 287
(,
13 A
The ones I recall hearin'g about on the morning j
14 were the loss of feedwater, the reactor trip on high 15 pressure, the turbine trip, and the fact that the reactor 16 coolant pumps were not running.
17 Q
You said that you heard that.the reactor 18 had tripped.
Was that a pressure trip that you heard 19 about?
20 A
I don't recall if.I heard what caused the trip.
(
21 Q
Did you know in March 1979 that the high 22 pressure trip point for the reactor was above the i
1 23 pilot operated relief valve trip point?
I)
\\/
24 A
Yes, I did know that.
25 Q
Did you know in March 1979 that a solid
1 Karrasch 472' O
N.
2 pressurizer was not the normal operating mode for the 3
pressurizer?
4 A
Yes, I knew that.
5 Q
Did you know in March 1979 that B & W limits 6
and precautions said that the pressurizer must not be 7
filled to solid conditions except under hydrostatic 8
testing?
9 A
No, I did not know that that was explicitly defined 10 in the limits and precautions.
11 Q
Did you know anywhere in anything that B & W 12 had distributed to its customers there was an advisory 13 against filling the pressurizer solid.except under Id hydrostatic test conditions?
l
\\
15 A
No, I do not know of any specific advisory to 16 our customers.
17 Q
I don't know whether you.are~ meaning to 18 change my question in your answer or not.
I am not 19 asking about whether there was a specific advisory.
I 20 am asking,did you have any awareness at all that B & W 21 had advised customers that they should not permit the l
{
22 pressurizer to fill solid except during pre-operational
(
23 testing?
O
'\\-
24 A
I was unaware of any specific advisories.
25 Q
Are you aware today from anything that you
.l
1 Karrasch 473
/9 V
2 have read or heard that on March 28, 1979 Three Mile 3
Island had aB & W limit and precaution that said the 4
Pressurizer must not be filled to solid conditions 5
except under hydrostatic test conditions?
6 A
I, recall in the course of reviewing the TMI-2 7
accident that such instructions existed just through 8
my review of the sequence of events.
Again, I don't 9
know what the specific source was or in what documents 10 they were.
11 Q
Was it your understanding in March 1979 12 that there were many different types of transients 13 which would l'ead to opening of the pilot operated relief 14 valve in the B & W 177 plants?
15 A
Yes, I was aware of that in March 1979.
16 Q
Was it your understanding that those 17 anticipated openings of the pilot operated relief valve 18 would lead to blowing open the rupture disk on the 19 quench tank or the reactor coolant drain tank, as it is 20 sometimes often referred to?
21 A
No, it was not.
(
l 22 Q
Was it your understanding in March 1979 l
l 23 that if the reactor coolant drain tank rupture disk l (~
(._h
)
24 blew open,'that something unexpected had happened?
25 A
Yes.
1 Karrasch
(%
474 2
Q In other words, something more than just a l
3 normal opening of the pilot operated relief valve had 4
happened?
(t 5
A Yes.
The rupture disk on the quench tank was not 6
supposed to rupture except in a very abnormal occurrence.
7 Q
In other words, it would take more than the 8
release of steam from a normal opening of a l
l 9
pilot operated relief valve to blow the rupture disk on i
10 the quench tank?
11 A
That wculd,bc my understanding, yes.
~
12 Q
And that was your understanding in March 13 1979?
14 A
Yes.
15 Q
In March 1979, the~only prior occasion on 16 which you then recall a quench tank rupture disk had 17 blown open was the Oconee incident some years earlier?
18 A
Yes, the one that I alluded to this morning.
19 Q
Have you learned at any time up to today 20 that in addition to the Oconee event, the quench tank
(
21 rupture disk had also been blown open during the 22 Davis-Besse September 1977 transient?
23 A
Yes, I think I recall hearing that the rupture 24 disk had blown at Davis-Besse also.
25 Q
Do you know that the operators at Davis-Besse fi.
1 1
Karrasch 475 r's 2
terminated high pressure injection in response to 3
rising pressurizer water leve17 4
A Yes.
5 g
when did you learn that?
6 Let me ask you more pointedly.
I will 7
withdraw that.
8 At some time between August 3, 1978 and S
March 15, 1979, when you were reading Don Hallman's t
10 memo more than once and co ntemplating 'a response to 11 Ha11 man 's memo, did you ever have the understanding that 12 the operators at Davis-Besse had terminated high s.
13 pressure injection in response to rising pressurizer 14 water level?
15-A No, I don't believe that I did.
16 Q
In March 1979, did you understand that there 17 was something wrong happening in the plant if there 18 were 800 rems of radiation measured in th,e dome of the 19 B & w reactor building?
20 A
Yes, that would indicate an abnormal condition to
(
21 me in March of 1979.
22 Q
Why would that indicate an abnormal condition?
23 A
That level of radiation-is significantly greater n\\'
24-than it should normally be in the dome of the reactor 25 building.
i
1 Karrasch O
476 v
2 Q
Based on your understanding in March.1979, 3
did you have any impression what could create a reading 4
as high as 800 rems?
5 A
No, I really didn't understand what could cause 6
a reading that high.
I just knew that it was much 7
higher than normal.
8 Q
In March 1979, were you aware of anything 9
other than failed fuel rods that could produce a reading 10 as high as 800 rems in the dome of the' reactor building?
11 A.
No.
p 12 Q
At Allen Womack's morning meeting, did Dr.
13 Womack or anybody else at the meeting say in words o r.
14 substance that they believed that there had been a loss 15 of coolant accident at the Three Mile Island plant that i
16 morning?
]
17 A
I don't recall hearing that.
18 Q
At any time during the morning of March 28, 19 1979, did anybody indicate to you that they either-j 20 thought there had been a loss of coolant accident at
{
21 Three Mile Island that day or there was a loss.of 22 coolant accident in progress at Three Mile Island?
23 A
I don't recall any discussions about loss of
'p 24 coolant accident at Three Mile Island on the morning 25 of March 28, 1979.
l 1
Karrasch 477 v
2 Q
After you left Allen Womack's office, did 3
you talk to anybody else about the reported transient 4
at Three Mile Island before lunch?
5 A
I don't recall for sure.
6 Q
Did anybody ever show you Bob Jones' 7
handwritten notes of the meeting in the morning with 8
Allen Womack?
9 MS. VAUGHN:
You mean outside the presance 10 of counsel?
11 MR. SELTZER:
Including yesterday.
(~%
12 l
A I don't recall sceing any handwritten notes frcm (m /
13 that meeting.
14 Q
Let me show you Bob Jones' notes and ask you 15 if it refreshes your recollection about some of the 16 things that you heard that morning.
His notes have 17 been marked as GPU-96.
18 A
Does that say " Notes of R.
C.
Jones on 11:00 a.m.
19 staff meeting for Plant Design"?
20 Q
Right.
You see at the bottom of page 2 21 where it says, " Set up incident team - B.
Karrasch.
l
(
22 various people will be tapped from each team"?
23 A
Yes, I see that.
/~
'kh i
/
24 Q
Does that refresh your recollection that s
25 Allen Womack asked you to set up such a team on the
1 Karrasch 478 b('T I
+
2 morning of March 28, 19797 3
A No, it does not.
For the record, I recall the 4
meeting I attended to have been much earlier than 11:00 5
a.m.
6 Q
Where were you at 11:00 a.m.?
7 A
I don't recall.
I am quite sure I was not in a 8
meeting with Allen Womack on the incident at TMI-2.
9 Q
Why are you so certain your meeting was 10 8:00 a.m.
and not 11:00 a.m.?
11 A
That is just the.best of my recollection.
12 Q
You keep time records?
f
(
13 A
No.
14 Q
Do you have a diary of this day?
15 A
No.
16 Q
Have you discussed with anybody.else what 17 things you did on the morning of March 28, 1979, other 18 than counsel?
19 A
I believe I was asked to explain my activities on 20 that morning by either the President's Commission or the 21 Rogovin Commission.
I don't recall which.
22 Q
Would you turn to.the fourth page of 1
l 23 Wandling's notes.
There is a number 4 at the top of
(~)T
(_
24 the page.
Do'you see the entry for noon?
i 25 A
Yes.
j l
2 1
Karrasch 479 2
Q.
Do you recall that at or about noon on 3
March 28, 1979, the Karrasch task force was asked to 4
determine the recommended course of action for cases i
k 5
with and without the reactor coolant pumps running?
1 j
6 A
No, I do not recall being asked to determine the 7
recommended course of action for cases with and without 8
reactor coolant pumps.
j' 9
Q Phat happened in the afternoca?
Ycu said i
10 that after lunch was.the next time that you got 11 involved in the Three Mile Is3snd fiasco?
12 A
I recall being asked to attend a meeting in a room O-13 called the Project Control Center.
The purpose f the 14 meeting was to make an evaluation of additional data 15 which had been received during,the morning and to 16 determine if there was assistance we could offer 17 Three Mile Island and see if we could find out more 18 about what had happened.
~
19 Q
How early did you show up for that meeting?
20 A
I believe I was there, to the best of my-l 21 recollection, by about 1:00-p.m. in the afternoon.
22 Q
.When you walked into that meeting, there 23 were other people already present in.the room, right?
^
24 A
I believe there~were several people already 25 present, yes..
1 Karrasch 480
)
2 Q
Was there an organized meeting in progress, 3
or were people just
'snding around, sitting around, 4
talking in groups?
('
5 A
I don't recall an organized meeting in progress.
6 Q
Shortly after you arrived at the afternoon 7
meeting or the afternoon gathering, did anyone inform 8
you that a determination had been made that there had 9
been a loss of coolant accident at Three Mile Island or 10 a loss of coolant accident was in progress at Three 11 Mile Island?
12 A
No.
()
13 Q
Did anybody tell yo.u shortly after you.
1 t
14 arrived at the afternoon gathering that the thinking at 15 B & W was that t'here had been a very serious accident 16 at Three Mile Island involving possible core uncovery 17 and fuel melting?
18 A
No.
19 Q
Did anybody advise you that he had personally 20 begun to think that there was a serious possibility of 21 core uncovery or fuel damage at Three Mile Island?
i km 22 A
No, I don't believe so.
23 Q
Did anybody tell you that he had personally rh()
24-begun to think that there had been a loss of coolant 25 accident at Three Mile Island?
1 Karrasch 481 O
2 A
No.
3 Q
When did you first hear anybody at B & W 4
suggest that there may have been or may be a loss of 5
coolant accident at.Three Mile Island?
6 A
To the best of my recollection, I don't believe 7
I heard the words " loss of coolant accident" until 8
either very, very late that afternoon or possibly even' 9
the next zorning.
10 Q
When is the first time thdt you heard lI 11 anybody suggest that there may be or may have been core 12 uncovery or fuel ax1 ting at Three Mile Island?
O.
a 13 A
I recall coming to a belief that there may be 14 possibly core uncovery myself when I heard that there
't 15 were readings indicating the presence of superheated 16 steam in the reactor coolant loops, and I believe that 17 occurred sometime in the mid-afternoon.
Approximately 18 three o' clock.
19 Q.
You say that was mid-afternoon?
20 A
Yes.
21 Q
You said that you don't believe you heard 22 anyone suggest that there had been a loss of coolant 23 accident until either very late in the afternoon or early f3 (ms/ -
24 the next day.
25-What. time period is "very late in the
.,w.
e e
w-
-,-n e
w
1 Karrasch 482 0
2 afternoon" or " late in the afternoon," whichever phrase 3
you used?
4 A
5:00 or 6:00 p.m.
5 Q
Why did superheat in the loops, which I 6
understand to be the same as the hot and cold legs --
7 is that right?
8 A
That's correct.
9 Q
Why did superheat in the hot or cold legs 10 indicate to you that there was possible core uncovery?
11 Can you explain your thinking on that one.
fs 12 7.
When I arrived in the meeting at one o'cloch,
(
1
'i v
13 the first data points that I heard that were signifi. cant 14 to me were the fact that the reactor coolant pressure 15 was less than a thousand pounds and that there were 16 indications of reactor coolant temperature greater than 17 600 degrees.
18 Q
Both of those were measurements in the
^
l 19 loops or the hot and cold legs, as you call th em'?
I 20 A
I don't recall exactly where the measurements 21 were.
I do recall that that was the first poic.t at 22 which I personally became alarmed that something was 23 really wrong at Three Mile Island.
That condition lf}
(./,
24 indicates that there is voiding in the loops.
25 Q
Why does that mean that there is voiding in j
l l
_____.________u
1
/"
Karrasch
~
483 N~))
2 the 1 cops?
You said you didn't know where those 3
temperatures were measured.
4 A
Let me correct myself.
5 Q
Or today you don't recall where they were 6
measured?
7 A
I don't recall where they were measured, but I 8
recall enough about the steam tables to know that 600 l
9 degrees is greater than saturation temperature at 1,000 10 pounds per square inch pressure. It w s at that point 11 in tine'that I becane alarmed that there was a very
("N 12 abnormal condition at Three Mile Island.
\\_
13 sometime later in the afternoon, possibly 14 an hour or so later, I heard that there were temperatures 15 being indicated by the in-core thermal couples that 16 were also in excess of possibly even 700 degrees.
In thohght that that 17 order for that condition to occur, I 18 would have to mean that at least the incore thermal 19 couples were not in an environment of water or even a 20 saturated fluid.
That would indicate to me that they
(
21 were in a steam environment.
That realization occurred 22 sometime in the mid-afternoon.
23 Q-You said that'in the middle of the afternoon
(~)
\\
/
'~'
24 you heard temperature and pressure conditions measured 25 somewhere in the reactor coolant ~ system that indicated
1 Karrasch 484 2
there had been saturation or that there was saturation 3
at the time those readings were taken, right?
4 A
Yes.
(
5 Q
And saturation in the reactor coolant system 6
meant that there had been voiding in the system, as you 7
understood at that day, right?
8 A
That's right.
)
9 Q
And voiding is the same as a two-phase l
10 mixture, right?
1 l
11 A
Right.
r"w 12 Q
And you said that is a very unusual condition?
5.
13 A
Yes.
14 Q
In mid-afternoon on March 28, 1979, did you 15 go from the conclusion that there was voiding in 16 saturation to the conclusion that there was core 17 uncovery?
18 A
I recall hearing that there were very'high-19 readings on the incore thermal couples, readings in 20 excess of saturation temperature, which to me indicates
(
21 that at least the upper part of the fuel where the 22 incore thermal couples are was in a steam environment.
23 That would indicate core uncovery to me.
O
(./
24 Q
Did you get temperature and pressure i
25 readings from the reactor coolant system before you
1 Karrasch 485 a
2 heard what the.incore thermal couple readings were?
3 A
I don't recall where the temperature readings 4
were taken from when I first heard that the temperatures 5
were in excess of the saturation temperature.
They 6
are two-phase.
The RTD's in the upper hot legs and 7
the incore thermal couples.
8 Excuse me.
There is also a third place.
1 l
9 There are RTD's in the cold 'egs also.
t 10 Q
Are there thermal couples in the 11 pre'ssurizer?
12
~
O
=
A Yes, I recall there also is a temperature 13 measurement in the pressurizer.
14 Q
Is it an RTD?
15 A
I don't know if it is an RTD or a, thermal couple.
16 Q
What is an RTD?
17 A
"RTD" stands for resistance temperhture device, 18 a special kind of temperature measuring device.
19 Q
Were you in the room when Bert Dunn-and Lou 20 Cartin recommended that B & W call the Island and tell 21 the Island that they should be charging HPI at 400 GPM?
22 A
Yes, I recall being in the room when a whole 23 series of discussions went on about getting HPI on and
\\
N/
24 water back,into the system.
25 Q
Was the gist of it that the people in the
1 Karrasch 486 2
room who were proposing that HPI should be on perceived 3
that there was a possil.ility of core uncovery due to 4
inadequate water inventory?
5 A
No.
My recollection is that the data we had on 6
reactor coolant temperature and pressure indicated that 7
we were saturated and that we were well below the set 8
point ~ for automatic initiation of high pressure 9
injection and that therefore it should be on.
t 10 g
- What is the maximum flow rate for high i
11 pressure injection on a 177 fuel assembly lowered loop 12 plant?
13 A
I believe on the order of.a thousand gallons per 14 minute.
15 Q
When Bert Dunn and Lou Cartin proposed a.
16 charging rate of only 400 gallons per minute for high 17 pressure injection, did you suggest that it should be 18 on the maximum,-namely, a thousand gallons per minute?
19 A
No, I did not.
20 Q
Did anyone in the room, to your recollection,
(
21 suggest that the recommendation that B & W make should 22 be to turn high pressure injection on full bore instead 23 of just turning it on half-throttle a't about 400 GPM?
(O<-
\\/
24 A
I don't recall.
25 Q
Was this some effort to save water that you
1 Karrasch
- 487 2
were only going to turn it on 400 gallons per minute 3
instead of full-blast?
4 MR. WISE:
I object to that.
There is no 5
need for that sort of thing.
I think you know 6
why 400 gallons was chosen instead of some other 7
figure.
So ask questions instead of making silly, 8
facetious r emark s to the witness.
9 Q
Do you know why 40v gallone was chosen thousandgallonspermindte?
10 instead of a 11 A
No.
I don't recall all the facts that vent into 12 any such decision to recommend a value for high
()g 13 pressure injection.
14 Q
Do you recall anyone recommending any value 15 higher than 400 gallons per minute?
16 A
No, I do not recall that.
17 (Recess taken.)
18 BY MR. SELTZER:
19 Q
Do you remember preparing comments on the 20 operating guidelines for small breaks?
21-A No, I don't recall doing that.
{
22 Q
Do you recall that B & W issued small break 23 operating guidelines following the Three Mile Island 24 accident?
25 A
Yes, I do recall that.
1 Karrasch 488 O
2 Q
Let me show you a document headed " Plant l
3 Integration Comments on ' Operating Guidelines for Small 4
Breaks,'" GPU Exhibit 380.
5 (Document above described so marked as 6
Plaintiffs' Exhibit GPU 380 for identification, 7
as of this date.)
8 Q
This is a document produced from your files.
9 Is that your handwriting on the second page?
t 10 A
Yes.
They are my handwritten comments.
11 Q
Is.that your handwriting on the subsequent 12 typed pages?
Or 13 A
.Yes, it looks like it.
14 Q
Does this. refresh your recollection that 15 you did prepare comments on the operating guidelines 16 for small breaks?
17 A
Yes, it does.
It appears that I did provide 18 comments on this document.
19 Q
To whom were you giving these comments?
i 20 A
I don't recall.
21-Q Do you see where you wrote on the top of
{
22 the second page, " Plant Integration comments are called 23 to your attention to assist in discussing-with NRC and O(_/
24 understanding the complete scope of emergency 25 Procedures"?
t
__-_____----__-_-----------_-------------------------o
1 Karrasch 489
(
%s 2
A Yes, I see that.
l 3
Q And above that, you have written "ECCS 4
Procedure"?
(I 5
A Yes, I see that.
6 Q
Does that refresh your recollection as to 7
whom you were supplying these comments?
8 A
No, it really doesn't.
In fact, I am having a l
very hard. time recalling what the situation was when I 9
10 presumably prepared these comments.
11 Q
Take a look at item 13 on the first page
~
I 12 of GPU Exhibit 380.
You said there, " Add to #7 above--
%J 13 The length of thic implies that our ' simple' approach 14 of the past (start and keep high pressure injection on; 15 keep subcooled) is inadequate - if that is the case, 16 our position on Three Mile Island 2 (operator error) 17 is weakened."
o 18 Did you discuss that with anyone before you 19 wrote that comment?
20 MS. VAUGHN:
I object just because I am not r
21 sure that we have establ-ished that he wrote this.
(
22 We have established that the second page are his 23 handwritten notes and the third page.
/
24 Q
Is what appears on the typed page at the 25 front a typewritten version of comments which you
1 Karrasch 490
/'
(_)}
i 2
prepared?
)
l 3
A No, I am quite sure that it is not.
4 Q
On the second page in the margin, could you
('
5 read what you have written there, please?
6 MS. VAUGHN:
You mean next to point "c"?
7 MR. SELTZER:
Right.
8 A
Next to point "c"
it says, " Weakens 'our position 9
that TMI-2 operotor erred."
10 Q
What weakens B & W's posit, ion that the 11 Three Mile Island 2 operator erred?
1 12 I
A I don"t know.
(~)
V 13 Q
Do you know who preparedhthe..first page of 1
14 GPU Exhibit 380?
15 A
-No, I do not.
16 Q
Do you exclude the possibility that you 17 prepared the first page?
18 A
I doubt that I prepared the first page, but I 19 don't know for sure.
The reason that I doub t that I 20 prepared it is that the level of technical detail goes 21 beyond what my. understanding of these operating 22 guidelines were to include.
1 23 Q
In the spring of 1979, wh'o in your unit had
)
U the technical expertise and the participation in any
-25 work in this area to have drafted this?
4 l
1 Karrasch 491 0
2 A
To the best of my knowledge, Lou Cartin 3
2 Lou used to be in ECCS, didn't he?
was involved in the preparation of the guidelines.
4 A
('
5 Q
Lou used to be in the ECCS Analysis Unit, 6
right?
7 A
Yes, that's correct.
8 Q
Do you recall discussing the guidelines with 9
Lou cartin?
10 A
No, I don't recall discussing the guidelines with 11 Lou.
12 Q
I take it you don't have any recollection 13 of discussing the items on page 1 of GPU Exhibit 380 14 with anyone; is that right?
15 A
I do not recall discussing page 1 of this exhibit f
16 with anyone.
~
17 Q
Do you recall discussing with Lou Cartin 18 (Continued on page 491A.)
19 20
(_
22 23
,-'q) 24 25
.,,, +
. ~..,
.-.e.,
.7 p.
1 Karrasch 491A O
2 or anybody else your comment that something in these 3
guidelines weakens B & W's position that the 4
Three Mile Island 2 operator erred during the Three
(
5 Mile Island accident?
6 A
No, I do not recall discussing that with anybody.
7 (Time noted:
4:20 o' clock p.m.)
c 8
9 BRUCE ADOLPH KARRASCH 10 l
11 Subscribed and sworn to l
12 before me this day i
13 of
- 1981, i
l 14 15 4
{
16 17 18
/
19 i
20 21 22 23
-Q 24 4
f 25 4
e+-
w v
n e v,
,or, w
v-er--
-,,r-
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- ~
+ - - - ~, - -
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1 492 m
e Cf
' l 2
CERTIFICATE j
3 6T.4TE OF NEW YORK
)
) ss. :
4 COUNTY OF NEW YORK )
f
,t
(
5 I,
JOSEPH R.
DANYO, a Notary P.ublic
~.
6 of the State of New York, do hereby certify i
.7 that the continued deposition of BRUCE ADOLPH 8
KARRASCH was taken before me on September 29, 9
1981, consisting of pages 399 through 491A.
10 I further certify that the, witness had 11 been previously duly sworn and that the i
12 within transcript is a true record of said b'
\\b 13 testimony.
14 That I am not connected by blood or 15 marriage with any of the said parties nor 16 interested directly or indirectly in the 17 matter in controversy, nor am I in.the employ
~
18 of any of the counsel.
19 IN WITNESS WHEREOF, I have hereunto W day of October, 20 set my hand this 1981.
L TJ /' Q*7*
21 m
22 OSEPH R.
DANYO 23 b]
24 t
/-
25 w
y q
l i
l l
l
(']
493 i V INDE X WITNESS PAGE BRUCE ADOLPH KARRASCH (resumed)
~
By Mr. Seltzer (continued).
401 E XH IB ITS PLAINTIFFS' FOR IDENTIFICATION GPU 377 Document entitled "NSSS Design Group" 402 GPU 378 Document dated May 2,
- 1978, April Activities Report,
/^')
from B.,A.
Karrasch to
'/
D.
H.
Roy 415 GPU 379 Document dated January'3, 1979, December, 1978 Progress Report, from B.
A.
Karrasch to E.
A.
Womack 438 GPU 380 Document headed " Plant s
Integration Comments on
' Operating Guidelines for_
s Small Breaks'"
488
-oOo-
/
h s
l i
?
U
.