ML20072J173
| ML20072J173 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 09/30/1981 |
| From: | Karrasch B BABCOCK & WILCOX CO. |
| To: | |
| References | |
| TASK-02, TASK-03, TASK-06, TASK-07, TASK-2, TASK-3, TASK-6, TASK-7, TASK-GB NUDOCS 8306290993 | |
| Download: ML20072J173 (101) | |
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1 vg UNITED STATES DISTRICT COURT j
. SOUTHERN DISTRICT OF NEW YORK s
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_x GENERAL PUBLIC UTILITIES CORPORATION, a JERSEY CENTRAL POWER & LIGHT COMPANY, METROPOLITAN EDISON COMPANY and PENNSYLVANIA ELECTRIC COMPANY, m
80 CIV. 1683 Plaintiffs, (R.O.)
1
-against-THE BABCOCK & WILCOX COMPANY and J.
R7Y McDERMOTT & CO.,
INC.,
Defendants.'.
_a--
.____x Continued deposition of Defendant The v
Batcock & Wil cox Company, by BRUCE ADOLPH KARRASCH, taken by Plaintiffs pursuant to adjournment, at the offices of Ka,ye, Scholer, Fierman, Hays & Handler, Esgs., 425 Park i
Avenue, New York, New York, on Wednesday, S,eptember 30, 1981, commencing at 10:05 o' clock in the forenoon, before Joseph R.
Danyo, a Sh,orthand Reporter and Notary Public within and for the State of New York, e
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DOYLE REPORTING. INC.
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Nsw Yom s, N. Y.
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Appea rance s :
3 i
4 KAYE, SCHOLER, FIERMAN, HAYS & HANDLER, ESQS.
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Attorneys for Plaintiffs S
425 Park Avenue New York, New York l
'6 i
By:
RICHARD C.
SELTZER, ESQ.,
l 7
of Counsel i
8 I
9 DAVIS POLK & WARDWELL, ESQS.
t 10 Attorneys for Defendants One Chase Manhattan Plaza 11 New York, New York i
i 12 By:
PATRICIA VAUGHN, ESQ.
-and-13 ROBERT B.
- FISKE, JR.,
ESQ.i 14 of Counsel 1
15 l
16 Also Present:
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1 17 DAVID TAYLOR 1
i 18 19
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496 pb 2
BRUCE AD0LP H KARRAS CH 3
having been previously duly sworn, resumed and 4
testified further as follows:
5 EXAMINATION (continued) 6 BY MR. SELTZER:
7 Q
You are aware, aren't you, that your 8
testimony today is under oath the way it has been 9
every previous day of your testimony in this case?
t 10 A
Yes, I am.
11 MR. SELTZER:
I would like to mark as GPU 12 381 a document produced from your personal files, 13 according to the identification tihat was given 14
-to us.
It is headed " Implications of TMI-2 15 Incident."
16 (Document above described so marked as 17 Plaintiffs' Exhibit GPU 381 for identification, 18 as of this date.)
19 Q
Is that your printing on the last page?
20 A
The printing on the last page does look like my 21 printing.
22 Q
Could you please identify-GPU Exhibit 3817 i
23 A
I cannot identify GPU Exhibit 381.
I don't recall m
24 either preparing it or over seeing it.
25 Q
What were the circumstances under which you
I Karrasch 497 7x 2
wrote the chart or graph that is the last page of this 3
exhibit?
4 MS. VAUGHN:
I am not sure he said he wrote 5
it.
He said it looks like his handwriting.
l 6
MR. SELTZER:
I will take that as he wrote 7
it.
8 Q
Do you know anybody else who has a 9
handwriting style that looks like that on the last page t
10 of GPU Exhibit 3817 11 MS. VAUGHN:
If.you know.
12 MR. SELTZER:
I just asked him, "Do you know. "
13 A
No, I do not.
14 Q
What were the circumstances under which you 15 wrote the chart or graph which appears as,the last page 16 of this exhibit?
17 A
I really do not recall preparing this chart, nor 18 do I recall the circumstances leading up to its 19 preparation.
20
- Q Do you think it would help refresh your
(
21 recollection about the circumstances under which you 22 prepared it if I showed you the box of your personal 23 files in which this was produced to us?
\\
N2 21 A
Th3t may help.
25 Q
Did Allen Womack ever ask you for anything i
1 Karrasch 498 2
along the lines reflected in GPU Exhibit 3817 3
A I really do not recall.
4 Q
Does it refresh your recollection if I tell 5
you that we found another copy of all three pages of I
i 1
6 GPU Exhibit 381 in another file that was identified as l
7 having come from Dr. Womack?
l 8
A No, that does not help refresh my memory.
9 Q
Have you had a chance to read through the t
10 text of GPU 381 line by line?
11 A
No, I just scanned it a few moments ago.
12 Q
Why don't you take a chance.to read it more 13 throughly and see if that refreshes your recollection 14 about having authored this.
15 A
I have read it.
16 Q
Is it beginning to come back to you now that 17 this is something that you prepared?
18 A
No, it is not.
19 Q
Do you have any reason to believe anyone 20 else prepared this?
(
21 A
I don't recall at all preparing the outline which 22 is typed on the first two pages.
I do believe that the 23 graph is my printing, and therefore I believe I did
' ~ '
24 prepare it.
I still don't recall preparing either the 25 outline or the chart.
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1 Karrasch 499 f.
N/
2 Q
In 1979, did the phrase "PORV qualification" 3
have any meaning to you, and if so, what?
4 A
The phrase "PORV qualification" did have meaning 5
to me in 1979.
I believe that meaning was that the 6
PORV in its original design was not qualified to safety 7
grade standards.
It was a non-safety grade piece of 8
hardware.
The word "PORV qualification" implied to 9
me that -- let me start that sentence over.
t 10 Qualification of the PORV would mean to 11 me to upgrade it to safety grade standards.
12 Q
What is the significance of a component such 13 as the pilot operated relief valve being safety grade?
14 MS. VAUGHN:
You are talking about today?
15 MR. SELTZER:
No, in 1979.
16 Q
What would be the advantages, to state it 17 differently, of upgrading the PORV to safety grade?
18 A
There are several requirements outlined in various 19 standards which define what safety grade means.
Such 20 things as qualification to seismic levels, assuring
(
21 that the valve would work under a seismic event, 22 assuring-that-the valve would work in an adverse 23 environment caused by an accident, assuring that power
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24 supplies to the valve were redundant,'such.that if there 25
'were a single failure, you would still have power i
.~.-
1 Karrasch 500 b
2 supplies that would allow the valve to operate, and 3
possibly some amount of qualification testing to 4
assure that the valve would operate as designed.
5 Q
In other words, testing to assure that 6
the valve as built conformed with the designs for the 7
valve?
8 A
Yes.
9 Q
Is that sometimes called as-built 10 verification?
11 A
I don't know if it is. referred to as as-built 12 verification.
I refer to it as qualification testing.
x 13 Q
We will get to a document in a minute in 14 which you talked about verification as built.
15 Prior to the Three Mile Island acciden,t, 16 are you aware that the pilot operated relief valves for qualified}forpassage 17 the type 177 plant had not been 18 of water?
19 A
Yes, I am aware of that.
20 Q
What does that mean, not qualified for
(
21 passage of water?
22 A
It would mean to me that the service conditions 23 specified for the valve would have included steam as 21 the liquid that the valve would relieve.
25 Q
You mean the liquid or the fluid?
1 Karrasch 501 2
A Excuse me.
I meant the fluid that the valve 3
would relieve and that water would not have been 4
specified as the fluid for the valve to relieve.
5 Q
You say that water would not have been 6
specified.
You mean water in its liquid phase?
7 A
Yes.
I mean water in its liquid phase.
8 Q
Subsequent to the Three Mile Island 9
accident, has B & W, to your knowledge,. considered s.
10 changing the qualifications for the pilot operated 11 relief valve to include qualification for passing 12 liquid water?
13 A
I don't know.
14 Q
IIave you ever considered what qualification 15 of the valve for liquid water service should be 16 undertaken?
17 MR. FISKE:
Could I ask a clar,ifying 18 question.
When you are asking Mr. Karrasch 19 whether B & W considered qualifying the valve to 20
-Pasi liquid water, are you asking him whether he
(
21 considered whether the valve would allow water 22 to pass through it.
Is that what you mean by 23
" qualification"?
I _ f~h.
.>.g MR. SELTZER:
No, I don't mean just could l
'l' I
25 water escape through it, but whether the valve l
i
1 Karrasch 502 2
would still function as designed and pass liquid 3
water through it.
4 Q
Did you ever consider after the accident 5
the issue of whether the pilot operated relief valve 6
should be qualified for releasing liquid water?
7 A
I don't believe I ever personally made that 8
consideration.
9 Q
Now that we have clarified exactly what I t
10 meant by " qualified for passing liquid water," do you 11 know since the Three Mile Island accident whether
()
12 anybody at B & W has ever considered the desirability 13 of qualifying the pilot operated relief valve for 14 permitting the escape of liquid water?
l 15 A
No, I really don't know.
16 Q
In 1979, did the phrase " auxiliary feedwater
~
17 requirements" have meaning for you?
18 A
Yes, they did.
19 Q
What was the meaning?
20' A
In order to adequately remove core decay heat
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21 following a loss of main feedwater with a subsequent 22 reactor trip, the auxiliary feedwater must come on 23 within a certain time and provide water to the steam
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generators.
The minimum flow rate and minimum i
25 requirement for starting emergency feedwater are what
1 Karrasch 503 J
2 I consider requirements for emergency feedwater system.
3 Q
In addition to minimum flow, what was the 4
other thing that you said?
5 A
In addition to minimum flow rato, I also consider 6
the delay time between the loss of main feedwater and 7
the start of emergency feedwater as an important 8
variable.
9 Q
And that was something that.would be t
10 included within the auxiliary feedwater' requirements?
11 A
Yes, to the best of my knowledge.
12 Q
Are auxiliary feedwater requirements a 13 document prepared at B &W or a series of documents?
14 A
For the backlog plants under construction, 15 Integration prepared balance of plant criteria which 16 communicated the requirements for auxiliary feedwater 17 to our utility customers.
Those are the only 18 requirements for auxiliary feedwater that I am aware of.
19 Q
It is a fact, is it not, that prior to the 20 Three Mile Island accident, the auxiliary feedwater
(
21 system was not a safety grade system on the lowered loop 22 plants?
23 A
I really don't know the answer to that question.
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24 Q
Do you know whether the integrated control 25.
system for auxiliary feedwater was safety grade or not i
1 Karrasch 504 2
safety grade?
3 A
It is my understanding that the integrated control 4
system is not a safety grade system.
5 Q
After the Three Mile Island accident, are 6
you aware of any consideration at B &W to require 7
that the control and actuation mechanism for the 8
auxiliary feedwater be upgraded to safety grade?
9 A
Yes, I do recall that.
t 10 Q
What, if anything, were the' advantages of 11 upgrading the actuation and. control systems for 12 auxiliary feedwater from non-safety grade to safety 13 grade?
14 A
It is my understanding that the advantages of 15 upgrading the control system for emergency feedwater 16 to safety grade were that it would increase the gkeater 17 reliability of the system and provide a 18 assurance that emergency feedwater would be supplied to 19 the steam generators in the event of a loss of main 20 feedwater.
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21 Q
In what way would'it increase the 22 reliability?
23 A
As I mentioned earlier, the safety grade r's
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I 24 requirements address such things as seismic qualification 25 assurance of performance in an adverse environment
t 1
Karrasch 505 2
caused by an accident, redundancy in the power supplies 3
and the number of pumps and the number of valves such 4
that a single failure would not preclude getting water 5
to the steam generators.
6 Q
Was the fact that the auxiliary feedwater 7
was valved out in the control room at Three Mile Island 8
on March 28, 1979 a single failure?
9 A
No, not in the context of designing a system to t
10 safety grade requirements.
11 Q
Would designing a system to safety grade
(
12 requirements in any way affect whether the system could 13 be operated with all of the auxiliary feedwater valves 14 blocked?
15 A
My understanding of safety grade in this context 16 is that the system is designed to still perform in the 17 event of a single failure of one of the de, sign features 18 of the safety grade system.
It is not des,igned to 19 perform adequately for any and all occurrences, such 20 as operator error or operator closing valves or turning
(
21 off pumps.
22 Q
In 1979, did B & W have something which you 23
-knew by the phrase " containment isolation requirements"?
I O
.-Q l
21 First let me ask you, did you have an 25 understanding in 1979 of what the phrase " containment l'
t Karrasch 506
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2 isolation requirements" meant?
3 A
Yes, I did have an understanding of what that 4
phrase meant.
5 Q
What did it mean?
6 A
My understanding of " containment isolation 7
requirements" is that the plant is designed such that 8
the containment can be totally isolated from the outside 9
world in the event of certain conditions which could t
10 possibly release radioactivity from the' fuel.
11 Q
You have referred to the containment.
In m) 12 the sense that you have used it in your answer, is that 13 the same as the reactor building?
14 A
Yas.
15 Q
In the aftermath of the Three Mile Island 13 accident, was there any consideration given at B &W 17 to changing containment isolation requirements?
18
- A I am really not familiar with-the containment 19 isolation requirements.
I vaguely recall B & W 20 suggesting requirements to the utility customers, but
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21 I believe the containment isolation requirements are 22 the responsibility of the utility, and I really have not 93 been-involved in setting them.
24 0
In 1979, did you undurstand that " reactor 25 coolant system high point venting" was a phrase that
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507 1
Karrasch J
2 referred to possible devices for venting gas out of 3
the top of the loops and out of the top of the reactor 4
vessel?
5 A
Yes, that was my understandir.g in 1979.
6 Q
What, if any, consideration was given 7
at B & W to modifying the design of its plants to 8
include high point venting in the aftermath of the 9
Three Mile Island accident?
5 10 Let me ask you first, was there consideration 11 given to modifying the design of B & W plants after the ID 12 Three Mile Island accident to include high point V
13 venting?
14 A
Yes, to the best of my knowledge.
15 Q
It is a fact, is it not, that.you recognized 16 after the Three Mile Island accident that the inability 1
17 to achieve high point venting could interfere with 18 achieving natural circulation?
19 MS. VAUGHN:
By "you," do you mean Mr.
20 Karrasch himself?
(
21 MR. SELTZER:
Yes.
22 A
Again, I was not directly involved in the issue 23 of high point venting, but it is my understanding that 1
+
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28.
the requirements for high point vents were mandated 25 by the NRC to the utility customers, and B & W's role
I Karrasch 508 2
in the issue of high point venting was that of responding 3
to the needs of the utility customers.
^
4 Q
That is not unhelpful, what you have said.
5 I just don't think it responds directly to what my 6
question was.
Would you like to have the question 7
reread?
8 A
Yes.
9 (Record read.)
E 10 MS. VAUGHN:
I think that is a responsive 11 answer.
()
12 MR. SELTZER:
I don't think.he said a thing 13 about the ability to achieve natural circulation.
14 MS. VAUGHN:
He said he wasn't involved 15 with it. It was just his understanding of what 16 was going on.
17 MR. SELTZER:
I said it wasn't unhelpful.
18 I don't think it responds directly.
19 MS. VAUGHN:
Do'you have another question?
20 MR. SELTZER:
No, I want to find out 5
(
21 whether after the Three Mile Island accident he 22 gained an understanding that if you can't get the 23 gas out of the t c '> of the candy canes, that it O
i 21 can interfere'with natural -circulation. Diminishes 25 the-capability for reactor coolant system natural w
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Karrasch 509 2
circulation.
Karrasch to Fahland June 13, 1979.
3 MS. VAUGHN:
Is that an exhibit already 4
marked?
5 MR. SELTZER:
No.
6 MS. VAUGHN:
Will you mark it?
7 MR. SELTZER:
I will in a minute.
8 THE WITNESS:
Would you please reread the 9
original question?
(
10 (Record read.)
11 A
I vaguely recall that B & W did not believe the
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/
12 high point vents were necessary to achieve natural 13 circulation in the event of a small break LOCA.
I do 14 recall that the NRC mandated that high point vents be 15 installed and that our utility customers then asked 16 B &W for assistance in setting the design requirements 17 for a high point venting system.
18 That is the best of my recollection.
19 Q
Do you agree or disagree with this 20 statement?:
"During a small break transient, the top of
(
21 the hot leg and the head of the reactor vessel will fill 22 with a steam / water mixture which diminishes the f~
- 23 capability for reactor coolant' system natural
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l s/
i 24 l
circulation."
25 I would like you to respond based on your
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l Karrasch 510 2
understanding as of June 1979.
3 MS. VAUGHN:
If you are reading from a 4
document, it might be very helpful for him to
-5 see it, because it might be in the context of the 6
document he can answer your question much better 7
than pulling it out of nowhere.
It seems to me 8
any answer he gives now is not necessarily a good 9
one without having the document in front of him.
t 10 MR. SELTZER:
If I had written this on a 11 separate sheet of paper and just asked the 12 question, since I used no funny words, it is all 13 straight English, you wouldn't ask me to show 14 him the document.
15 MS. VAUGHN:
It seems you are asking him 1G reading from a document.
17 MR. SELTZER:
It is.
~
18 MS. VAUGHN:
I think he should have that 19 document in front of him.
20 MR. SELTZER:
He will get it.
Just not now.
f 21 It is a perfectly proper way to proceed, to ask 22 the witness a question, and then if he can't 23 answer it, I will refresh his recollection by i
21 l
showing it to him.
25 A
You want to try die original question again?
l t
I Karrasch 511 r~s 2
Q The question is based on what you knew in 3
1979.
Do you agree or disagree with the following 4
statement?:
"During a small break transient, the top 5
of the hot leg and the head of the reactor vessel will 6
fill with a steam / water mixture which diminishes the 7
capability for reactor coolant system natural l
8 circulation."
l 9
MS. VAUGHN:
I still think if you are j
l t.
10 trying to get his understanding of what that 11 means or what he would have understood that to
(~}
12 mean, it is better to have a document in front of V
13 him.
You can go on with the deposition that way.
14 Q
You can answer the question.
15 A
I am having trouble interpreting your question 16 because there are different meanings to the words refertonhtural 17
" natural circulation."
When I 18 circulation, I think of solid water natural circulation 19 where the loops are completely filled with water.
20 Q
Let me suggest a different definition and
(
21 see if you can answer the question using that.
I mean I
22 effective cooling of the core without the reactor 23 coolant pumps operating.
b) 4 21 r
A Again, there are different meanings to the words k
25
" natural circulation."
______________________d
1 Karrasch 512 7-s 2
Q I just gave you the meaning that I would 3
like you to apply.
4 A
I can achieve effective cooling of the core without 5
the reactor coolant pumps running if I have either solid 6
water natural circulation in the loops or if I have a 7
condition where there is voiding in a steam / water 8
mixture in the loops.
Natural circulation will be 9
achieved in both of those conditions and effective core i
10 cooling will occur if I have water on the secondary side 11 of the steam generators to remove the heat being 12 generated.
13 Q
Are you saying that based on the knowledge 14 that you had in 1979, it is not your understanding that 15 an air block or steam block would rise to the top of 16 the candy canes and impede the further passage of 17 coolant?
18 MR. FISKE:
By "1979," you mean June?
19 MR. SELTZER:
Right.
20 A
It was my understanding in June 1979 and it is
(
21 my understanding today that the core can be effectively 22 cooled by natural circulation during a small break 23 LOCA if there is a steam / water mixture present in the t)
1 21 l
l I
25 Q
Are you envisioning as you say that a l
l n.,,
e- - -,
1 1
Karrasch 513
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N./
2 homogeneous steam / water mixture?
Do you understand 3
what the word " homogeneous" means?
That the proportion 4
of steam and water is everywhere the same throughout the 5
entire reactor coolant system.
Are you envisioning 6
that the proportion of steam and water is going to 7
be the same at the top of the candy cane as it is at 8
the bottom of the core region or the reactor vessel?
9 A
No, I am not envisioning that.
The situation I t
10 am alluding to is a condition where the' bottom of the 11 loops and the reactor vessel is solid water, and the
(
12 top of the loops is a homogeneous mixture of steam and 13 water.
It is my understanding that in'that condition 14 adequate core cooling can be maintained by natural 15 circulation, 16 Q
Do you know what a loop seal is?
j 17 MS. VAUGHN:
Are you still talking about 18 his knowledge in June.19797 19 MR. SELTZER:
Yes.
I want to know if the 20 head of Plant Integration at B & W knew at the
(
21 time of the Three Mile Island accident what a 22 loop seal is.
23 MS. VAUGHN:
That is different from June 1
21 1979.
25 MR. SELTZER:
I will take either period.
f 1
Karrasch 514 rw (v) 2 A
I believe I know what a loop seal is, yes.
3 Q
What is it?
n a piping system 4
A A loop seal is a situation i 5
where the piping contains trapped gas which will not 6
allow the passage of fluid through the piping.
7 Q
Is it a "U" bend?
8 A
That is my understanding, yes.
9 Q
The tops of the hot and cold legs form "U"
t 10 bends, don't they?
11 A
The top of the hot leg is a "U" bend.
(
12 Q
During the Three Mile Island accident, have
\\ _.)
13 you come to know that the "U" bends at'the top of 14 the hot legs became filled with steam?
15 A
It is my understanding that the "U" bend at the 16 top of the hot legs became filled with steam.
17 Q
You said that it wasyourundhrstanding of 18 a loop seal that it was a device which could, by 19 trapping gas, prevent the passage of fluid.
20 Was it your understanding in June 1979
(
21 that the "U"
bend at the top of the hot leg could 22 become filled with a gas known as steam and thereby 23 impede the flow of a fluid known as liquid water?
1 i.
24 j
A No, that was not my understanding in 1979, nor is
~'
l 25 it my understanding today.
i 1
Karrasch 515
, ~x 2
Q What is the mechanism by which the liquid 3
water could pass through the hot legs if they were 4
containing trapped gas at the top?
5 A
It is my understanding that the steam / water 6
mixture at the top of the loops will be condensed in 7
the upper portion of the steam generator and return to 8
the fluid state and thereby continually add liquid 9
water to the reactor vessel which can then be boiled k.
10 off to remove the heat in the core.
11 Q
You said that steam would be condensed in 12 the top of the candy canes; is that right?
(
13 A
I think I said steam would be condensed in the 14 steam generator.
15 MR. SELTZER:
Let me mark as GPU 382 your 16 memo to Fahland on June 13, 1979, subject:
17 Responding to TMI-2 Concerns - Verification of 18 As-Built Data and High Point Venting.
19 (Doc ume n t above described so marked as 20 Plaintiffs' Exhibit CPU 382 for identification,
(
21 as of this date.)
22 Q
Is GPU Exhibit 382 a copy of a memorandum, 23 together with attachments, that you sent to Mr. Fahland
_s I
21 on or about June 13, 1979?
25 A
Yes.
1 Karrasch 516 2
Q Do you see the attachment dealing with high 3
Point vent?
4 A
Yes, I do.
5 Q
At the time that you sent GPU Exhibit 382 to 6
Mr. Fahland, did you indicate to him in any way that 7
you disagreed with the statement that appears at the 8
start of the page on high point vent?
~
A No, I did not indicate to him that I disagreed 9
1 10 with that statement.
11 Q
Have you ever told him that you disagreed 12 with that statement?
13 A
To the best of my knowledge, no.-
14 Q
Do you know what the basis for that statement 15 was at.the time that you sent it to Mr. F,ahland?
16 A
I do not recall preparing this paper on high point 17 vent.
However, I believe that the basis {orthe 18 statement would have been that a comparison was being 19 made between solid water natural circulation in the 20 reactor coolant system and natural circulation with a
(
21 steam / water mixture.
I believe the statement is 22 implying that solid water natural circulation is 23 somewhat better than a condition where you have steam O-4
/
s 21-and water natural circulation.
However, I believe they 25 are both adequate for adequate core decay heat removal.
.~ _ -. - -., - -
1 Karrasch 517
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U 2
Q Let me show you a diagram that I just i
3 sketched depicting the top of the hot legs in a B &W 4
177 plant.
Can you picture where that is in the hot 5
legs, where there is that "U" bend configuration?
'6 MS. VAUGHN:
If you can.
7 A
Yes, I can.
8 MS. VAUGHN:
Can we mark this?
I don't 9
know that it is going to be much t
10 MR. SELTZER:
Fine.
We will mark it 383.
11 (Sketch above referred to so marked as r
12 Plaintiffs' Exhibit GPU 383 for identification,
('m 13 as of this date.)
14 Q
One side of that "U"
bend is the reactor, 15 and on the other side is the steam generator, right?
16 A
Yes, that's correct.
17 Q
Did you understand in 1979 that there could 18 be a situation in which steam would be formed in the 19 reactor coolant system such that steam would fill up 20 that area at the top of the hot legs that is depicted
(
21 in GPU Exhibit 3837 22 A
Yes.
23 Q
Don't you recall that Carlyle Michelson and 0(_
24 Bert Dunn had both concluded that if you.had a steam l
25 formation occupying that much of the bend at the top i
1
1 Karrasch 518 s
2 of the hot leg, that it would interfere with natural 3
circulation under either of the definitions that you 4
have suggested?
5 MS. VAUGHN: "That much" is a funny term,
'6 and this is just your drawing.
Do you want to 7
qualify it?
8 MR. SELTZER:
It means below the bottom of 9
the bend.
t 10 A
I am really unaware of any information from either 11 Mr. Michelson or Bert Dunn on this subject.
12 Q
Let me probe --
13 A
I haven't read anything.
14 Q
Let me probe your understanding, then.
15 Focusing on this configuration where the 16 steam fills the top of the "U" bend to points that 17 are below this point.
What would you call this point 18 that I am pointing to?
David Taylor suggested it could 19 be called the incide of the bend.
20 A
That is 0.K.
(
21 Q
Let me label this.
22 Was it your understanding as of' June 1979 23 that effective core cooling by natural circulation could f*'
24 be achieved when the area above the inside of the bend 25 was filled with steam and in fact it was filled with i-
t I
Karrasch 519
-~s 4
2 steam to a little bit below that point and then there 3
was water on both sides of the hot leg?
I 4
A Yes, that was my understanding.
5 Q
What is the heat transport mechanism that
'6 you understood could give effective core cooling?
l 7
A As long as the core is covered with water, 8
adequate core cooling will continue by a natural i
9 circulation process which occurs within the core itself s
10 where the water is merely heated up.
As that water 11 heats, it rises and eventually will form more of a V(
i 12 steam / water mixture in the top of the hot leg as you i
13 have depicted here.
As more and more of a steam / water 14 mixture is formed in the top of the hot leg, eventually j
15 that steam / water mixture will reach the t.op of the l
16 steam generator.
During this entire process, there is i
17 still adequate decay heat removal in the core by 18 natural circulation.
19 Q
Is that because the core is covered with 20 water?
(
21 A
Yes.
It is my understanding that when the 22 steam / water mixture reaches the top of the steam i
i l
23 generator, that it will be condensed in the steam l Q I
\\/
21 generator and return to the solid water. state in the l
25 steam generator.
At that time, a positive pressure i
1 Karrasch 520 (q
t j
),
2 differential will be established in the loop such that 3
natural circulation will occur and more water will be 4
admitted to the reactor vessel to continue the process 5
of heating water in the core.
It is my underetanding
'6 that that natural circulation will continue as long as 7
you remove the decay heat in the steam generators.
8 Q
What will remove the decay heat in the steam 9
generator?
t 10 A
It is my understanding that maintaining a high' 9
11 water level on the secondary side of the steam generator
(
12 will condense the steam and remove the energy from the 13 primary water through the condensation'procens.
14 Q
So your analysis and understanding was that 15 eventually the water level in the hot legs gets icwer 16 and lower until eventually the water level drops into the 17 steam generator; is that right?
~
18 A
Yes.
19 Q
And when the water level drops into the 1
20 steam generator, then the steam generator begins to see 21 steam from the primary side, rkght?
(
22 A
I believe it is a steam / water mixture.
23 Q
Your understanding that the steam gene'rator
[_)
' ~ ',
l 21 would contribute effective core cooling is linked to i.
25 your understanding that at the time that the water 1
~
s
\\..
s 1
Karrasch 521
)
\\_/
1-2 level has dropped down to within the steam generator, 3
the core is still completely covered with water; is'that 4
right?.
5 A
Yes, I believe that is my understanding.
'6 Q
After the Three Mile Island accident, are 7
you aware of considerations at B & W that there ought 8
to be increased attention to realistic analysis of 9
expected moderate frequency events?
That is i t e'$s II-A-1 i
10 of GPU Exhibit 381.
11 A
Yes, I am generally aware of that.
12 Q
Was that a shift in focus compared to
(%s) y 13 prior to the accident?
14 A
Yes, I believe that was a shift in focus throughout 15 the entire industry.
16 Q
What had the analyses been focused on before 17 the Three Mile Island accident?
18 A
It is my understanding that the analysis prior
'19 to the Three Mile Island accident focused on bounding 20 safety analysis, accidents and transients.
(
21 Q
Were the bounding events events that were 22 not likely to occur or expected to occur with a very low 23 frequency?
O 21 A
I would say that the bounding events I referred to
)
i 25 were expected to occur with a very low frequency.
+i
-y
'g
,_ )-
" i k
3 0-522 1
Karrasch 2.
Q What, if anything, was the perceived 3
desirability at B & W for shifting the focus to analysis 4
of events that were expected to occur with moderate 5
frequency?
'6 A
Please repeat that question.
7 (Que s tion read.)
8 Q
In other words, what is your unde'rstanding 5
9 ofswhat benefits, if any, would flow from shifting the t
10 focus in analysis from events which were highly unlikely 11 tot happen to events which were expected with a moderate 12 fr'eq oney?
13 -
A I need it read back again.
14 (Record read.)
t 15 Q8 In other words, what was your understanding 16 of the benefits, if any, from focusing transient analysis 17 on events of moderate frequency instead of on events 1,.
18 that were highly unlikely to occur?
\\-
19 A
I think the focus -- excuse me.
I believe the i
y T
20 change in fbcus was primarily due to the operating.
4
(,
21 experience that we had obtained since the start-up of the 23 177. fuel assembly plants.
The change in focus in no way
's 23 lessened the need to do the bounding safety analysis
)
4y,
\\ }l i
21
,a n'd ah ow that the plant would be safe and that the
,,[g :h\\
l}
s W
' \\ ' L '- -
23 ' I
- safety'syst'sms would perform the ir intended function.
s
+e ~
t
- 3 w.
- k r
- \\,, ' -i,,
.,,,c,--
a
1 7s 523 i
1 Karrasch t
i 2
Once that was done, and once many years of operating 3
experience on the plants was obtained, B & W and the 4
whole industry thought it would now be prudent to begin 5
to focus our attention on the kinds of events that
.6 really happened on a nuclear power plant.
7 Q
Why was that something that was seen as 8
prudent?
Why did you think that was prudent?
9 A
I think our experience had shown that things i
10 happened at these plants which we were unable to predict 11 and that by now taking that experience, we could improve
["}
12 both the operation and design of the plants to prevent V
13 recurrence of abnormal events.
14 Q
Since the Three Mile Island accident, has 15 B & W begun doing more transient analysis.on events 16 of expected moderate frequency?
17 A
Yes, we have.
18 Q
You are not saying, are you, that prior to 19 the Three Mile Island accident B &W was unable to 20 predict that a' valve such as a pilot operated relief
(
21 valve would fail to,close, are you?
22 A
No, I don't believe I am saying that we were 23 unable to predict that.
\\-
24 Q
Let me show you the file that was produced 25 for us from your personal files'in which-GPU Exhibit l381
?
I Karrasch 524
{Q^3 2
appears, and I ask you if seeing it in the context of 3
your files refreshes your recollection about the 4
circumstances under which it was prepared.
It was 5
produced among these files.
It was the file between
'6 6567, 6569.
It is TMI-2 natural circulation, TMI-2 7
owners, TMI sequence of events, and the one you have 8
is B & W TMI-2 concerns.
9 Is that your handwriting on the file label?
t 10 A
Yes, I believe it is.
I recall starting a series i
11 of files shortly after the TMI-2 accident to accumulate
( )J 12 correspondence which had crossed my desk.
4 13 Q
Do you see GPU Exhibit 381-in the file that 14 is in front of you?
1 15 A
Yes I see it.
)
l 16 Q
Does it all come back to you now,~the i
17 circumstances under which that was prepared?
1 4
^
18 A
No.
I 19 Q
Does any of it come back to you?
20 A
I still do not recall preparing GPU Exhibit 381.
(
21 I only recall starting the files and accumulating the 22 documentation which is in them.
l 23 Q
Is that one of your personal files?
21 MS. VAUGHN:
What do you mean by " personal"?
l-25 MR. SELTZER:
That this is Mr. Karrasch's I
h
i Karrasch 525 gg
\\
f
%J 2
files, and to the best of his knowledge, if 3
something is in there, he put in in or his 4
secretary put it in at his direction.
5 A
To the best of my knowledge, that is true.
It
.6 was a long time ago, and I don't recall reading or 7
filing a lot of this documentation.
8 MR. SELTZER:
I would like to mark as 9
GPU Exhibit 384 a memorandum that begins with v
10 the same first two pages on " Implications of TMI-2 11 Incident," but contains something fetchingly
()
12 listed as "The TMI-2 Message" and concluding 13 with the same chart that you had'at the back of 14 GPU 381.
15 (Document above described so marked as 16 Plaintiffs' Exhibit GPU 384 for identification, 17 as of this date.)
18 Q
This copy was produced from Allen Womack's 19 file.
If this doesn't refresh your recollection, I am 20 going to bring Dr. Womack-in a second to tell you all
(,
21 about it.
22 Just for openers, that is your handwriting 23 on the side of the first page of GPU Exhibit 384, isn't O
24 it?
25 A
Yus, it does look l ike my handwriting.
1 Karrasch 526 s
2 Q
Did you read the TMI-2 Message?
3 MR. FISKE:
You mean just now?
4 MR. SELTZER:
Right.
5 A
Yes, I just finished reading it.
.6 Q
Within the TMI-2 Message, there is a 7
reference at the beginning of the second paragraph to L
0 "the attached figure," and it says, "The attached figure 9
depicts the necessary elements which must be strengthened 10 to assure proper operator training and an optimum plant 11 design / operator interface."
/~
12 (hj You prepared the attached figure, right?
13 A
To the best of my knowledge, yes.
14 Q
And you headed the attached figure in your 15 handwriting "The TMI-2 Message," right?
16 A
Yes, to the best of my knowledge.
17 Q
And do you recall that you wrote the 18 preceding three pages,which are also entitled "The TMI-2 19 Message"?
20 A
I honestly cannot recall preparing any of the
(
21 pages in this e x h ib i t.
22 Q
Do any of these pages bring back even a 23 faint blush of recognition that you have seen them before ?
O
21 A
I~ recall very vaguely during the s'ummer of 1979 25 that I was involved in the initial definition of the
I l
1 Karrasch 527 (N
e>
2 ATOG program.
I worked with Dr. Womack and people 3
like Joe Kelly to try and define a program which we 4
could then offer to our utility customers called 5
abnormal transient operating guidelines.
The work that
'6 I did here, if indeed I even did it, may have been 7
tied to the initial definition of the ATOG program.
8 Q
When you said, "the work that I did here,"
9 you were referring to GPU Exhibit 384; is that right?
r.
10 MS. VAUGHN:
I think he said may have 11 done it.
(
12 Q
When you said "here," you were looking down
^
13 at something in front of you.
You were looking at 14 GPU Exhibit 384, weren't you?
15 A
Yes, I was looking at Exhibit 384.
16 Q
Did you have a p.
re?'
acretary in June 17 and July of 19797 18 A
There was a secretary for the entire Plant 19 Integration Unit.
20 Q
What was her name?
(,
21 A
she reported to me.
I don't remember her name.
22 Q
Is she still with the company?
23 A
I had three or four differet.t secretaries in b<
4 s
21 Plant Integration during the time from 1978 to 1980 25 and I don't recall which one was in place during the
~
~,
1 Karrasch 528
_ U 2
summer of 1979.
3 Q
Is Art McBride still with B & W7 4
A No, he is not.
5 Q
Where is he now?
'6 A
I don't know.
7 Q
Where did he go after B & W?
8 A
I don't remember for sure, but I believe he went 9
to a consulting firm called S.A.I.
t 10 Q
Is Eric Swanson-still with'B & W7 11.
,A Yes, he is.
D 12 Q
When you wrote on the. side of GPU Exhibit
[f 13 384, page 1, "See Attachment 'TMI-2 Message,'" which 14 were you referring to, the diagram that you wrote or 15 the narrative "TMI-2 Message"?
16 A
I don't recall.
17 MR. SELTZER:
I would like to' mark as GPU 18 Exhibit 385 a memo from Mr. Karrasch to Mr.
19 Fortune, subject:
Proposed TMI-2 Impact Study, 20 June 21, 1979.
(
21 (Document above described so marked as 22 Plaintiffs' Exhibit GPU 385 for identification, 23 as of this date.)
0]
21 MR. SELTZER:
I would like to mark as GPU 25 Exhibit 386 a memorandum from C.
W.
Litchford to
1 Karrasch 529 s
2 Distribution, subject:
TMI-2 Related Work Tasks, 3
June 6,
1979.
4 (Document above described so marked as Plaintiffs' Exhibit GPU 386 for identification, 5
'6 as of this date.)
7 Q
Is GPU 385 a copy of a memo which you sent
.8 to Mr. Fortune in or about June 21, 1979?
9 A
Yes, it is.
e 10 Q
You outline a series of projects, and you 11 give the names of people and dates.
Was work done on 12 those projects?
()
13 A
Yes, I recall the work was'done on those projects.
14 Q
Was it done in the Plant Integration Unit?
15 A
It was done by several units at B & W, including 16 Plant Integration.
17 Q
Was any centralized file set}up for 18 organizing materials done on these tasks?
19 A
I don't recall.
20 Q
Am I correct that GPU Exhibit 386 contains
(
the owners group list of TMI-2 concerns that you 2t 22 referred to in GPU Exhibit 3857 3
A I don't recall for sure what I was referring to 2
[
the first page under item 1 as.the owners group list
\\-
on 2.g 25 o f TMI-2 concerns.
l 1
Karrasch 530 I
2 Q
Do you recall receiving GPU Exhibit 3867 3
A-Yes, I do recall seeing regular publications of 4
TMI-2 related work tasks.
5 Q
In June 1979, were Fairbrother, Brooks, and
.6 Brazill' members of Plant Integration?
7 A
Yes.
8 Q
Is Fairbrother still with B & W?'
9 A
Yes, he is, t
10 Q
Is Brooks?
11 A
Yes, he is.
(
12 Q
Is Brazill?
13 A
Yes, he is.
14 Q
Is Brockman?
15 A
I believe Mr. Brockman took a leave of absence 16 to return to school several years ago.
I don't know 17 where he is today.
18 Q
Is Mr. Leinhart still with B & W?
19 A
No, he is not.
20 Q
Where did he go?
(
21 A
I don't remember.
22 Q
How long ago did he leave?
23 l
A To the best of my recollection, it was sometime b>
l x~
21 shortly after the summer of 1979.
I 25 8
Q Turn to item 46 in GPU Exhibit 386, please.
v 9
1 Karrasch 1
531 2
Do you see where it says, " Evaluation of 3
interrupted natural circulation as an 4
acceptable cooling mode"?
5 A
Yes, I see that.
'6 Q
Are you aware whether work was done to 7
study that item after the Three Mile Island accident?
8
~A No, I am not.
9 I Q
If someone wanted to find the results of 10 f studies on any one of these subjects, is there any 11 index or source that someone could go to i
12 for the papers that were generated as a result of work on these i
13 i subjects?
14 A
I really don't know if there is a file that 15 contains the work related to these tasks..
16 l
Q Was Litchford coordinating the work on these 17 tasks?
18 A
To the best of my knowledge, Mr.
i 19 Litchford was a i
scheduler who prepared this list.
I would not t
say 20 i that he was 6
coordinating the work.
k 21 Q
Is there anyone who was coordinating the 22 work?
O 23 A
The people listed under the headings " Task Leader,*
i 24
" Integrator,"
and " Product Manager" would all have some I
2.3 I
responsibility with respect to preparing and issuing
/l
I Karrasch
~
532 fs) v 2
the results of the work.
3 MR. SELTZER:
I would like to mark as 4
GPU Exhibit 387 a memo which you sent to Mr.
5 Pryor, subject:
Impact of TMI-2 Related Changes 6
on Hardware Design Evaluation, November 9, 1979.
7 (Document above described so marked as 8
Plaintiffs' Exhibit GPU 387 for identification, 9
as of this date.)
10 Q
You wrote this in early November, 1979, 11 right?
f~))
12 A
Yes.
i 13 Q
You told Pryor that Plant Integration has 14 made an evaluation of studies being conducted in Plant 15 Design which had the potential to change.the operating 16 plant or backlog contract reactor coolant system design 17 basis.
18 Who worked on that evaluation?
19 A
I believe I personally did that evaluation.
20 Q
Did you do it in your head or did you write
(,
21 something down?
22 A
I believe that the evaluation that I performed 23 was a review of those work tasks under way in Plant
,3
( ))
l t
i I
21 l
Design to determine which ones would have an effect on l
1 25 work which was being performed in Dr. Pryor's Component
I Karrasch 533
~'(J
- 3
\\
2 Engineering Section.
My review indicated that there 3
was a potential impact, and as I best recall, the 4
purpose of this letter was to just make members of the 5
Plant Design Section aware that they should be
'6 communicating such changes to the people in Charlie 7
Pryor's Component Engineering Section.
8 Q
You say that the purpose of this memo is 9
to let people in Plant Design know that they should I
1 t
10 be communicating with Charlie Pryor?
11 MS. VAUGHN:
Are you reading or are you
[V")
12 just asking the question?
13 Q
Is that what you just said to me?
14 A
Yes, I believe that was the intent of the 15 memorandum.
16 Q
Did you write down anything as part of your 17 evaluation of the studies that you say you conducted?
18 A
I don't recall for sure, but I don't think I did.
19 I was performing a review of paper which already 20 existed.
(
21 Q
Do you recall that in the spring of 1979 22 after the Three Mile Island accident Allen Womack 23 or Carlton or somebody asked you to review the history 3)
gg of failures on pilot-operated relief valves and 23 establish a B & W position on what should be the failure
l 1:
l l'
Karrasch 534 O-2 mode for the electrical circuitry associated with the 3
pilot operated relief valve?
4 A
I don't recall a request like that.
5 Q
I.e t me show you the request and see if it
'6 refreshes your recollection.
I show you GPU 33, which 7
is a womack to Carlton, c.c.
to Karrasch, memo, May 15, 8
1979.
9 Does that refresh your recollection that you 1
10 were asked to develop or establish a po'ition for the s
11 Plant Design Section on what should be the failure mode I~h 12 for the pilot operated relief valve circuitry?
b 13 A
I do not recall seeing this request, nor do I 14 recall discussing it with Ray Carlton.
15 Q
You see where Womack says at the bottom of 16 his memo, " Prompt Action is Needed," capitalizing
~
17 Prompt Action Needed?
18 A
Yes, I see that.
19 Q
He also underlined it. Do you see that, too?
j 20 A
Yes.
(
l Q
Do you remember taking any action?
21-22 A
No, I do not.
23 MR. SELTZER:
I would like to mark as GPU 2f l
Exhibit 388 a Preliminary Report of Sa f e ty Concernu 23 from Mr. Brockman, PSC 35-79,-dated August 10,
i i
I 1
Karrasch 535 2
1979.
3 (Document above described so marked as 4
Plaintiffs' Exhibit GPU 388 for identification, 5
as of this date.)
6 Q
Have you had a chance to look at GPU i
7 Exhibit 388?
8 A
Yes, I have just reviewed it.
9 Q
Plant Integration is supposed to be the t
10 iead unit on this PSC and the manager of Plant 11 Integration is supposed to review all PSC's.
O 5
1 12 Is GPU Exhibit 388 a copy of a page which V
13 you have seen and previously reviewed?
14 A
Yes, I recall seeing this PSC when it was issued.
15 Q
Do you recall the concern that is being 16 described here, namely, the relatively high probability 17 that the steam generators will be flooded during a 18 number of transients?
19 A
Yes, I do recall the concern.
20 Q
Do you recall that sometime in November
(,
21 1978 or earlier B & W management directed the Plant 22 Integration Unit to spearhead the job of resolving this 23 problem?
3 A
I 21 A
I recall that there was an effort under way in 25 Integration prior to TMI-2 to resolve a concern'on the
- -. - ~ _. - _ - ~ _..
i
{:
i I
Karrasch 536
' f).
(_/
2 BSAR-205 plant with respect to the potential for steam i
i' 3
generator overfill.
4 Q
In the nine months between November 1978 5
and August 1979, when GPU Exhibit 388 was written, had
.6 Plant Integration made any progress on providing a
7 fix for this problem?
8 A
To the bestlif my knowledge, some amount of work 9
went on between November of 1978 and the Three Mile t
i 10 Island accident.
11.
Q Who was doing that work?
- ()
12 A
I believe that it was being led by Eric-Swanson, i
13 I don't recall exactly, but I don't believe we finished 14 our evaluation prior to the TMI-2 accident, and I do 15 recall that the overfill concern was of a lower
~
16 priority than addressing the new concerns that had 17-arisen from the TMI-2 accident.
)
18 Q
Let me switch to another subject.
i 19 On the 177 plants other than Davis-Besse, 20 what is'the maximum head on the-HPI pumps, give or take i
j
. (,
21 a pound or two?
22 A
I don't know for sure.
I believe that it is 23 several hundred pounds greater than the design pressure 4
\\
21 of the reactor coolant system..That design pressure is-s 25 2500' pounds por square inch.
s 1
Karrasch 537
)
2 Q
So something in or around 3000 pounds per 3
square inch would be your best recollection of what the maximum discharge pressure for the high pressure
{
5 injection system was?
'6 A
All I really know for sure is that it is greater' 7
than 2500 pounds.
8 Q
And you say a few hundred greater, right?
Is that what you just said?
10 MS. VAUGHN:
I think he said he just doesn't 11 really know.
He just knows it is greater.
[
12
\\-
MR. SELTZER:
That is great' for you to say 13 that.
All I am trying to do is capture his 14 recollection.
I think he said just a moment ago 15 that his best recollection was that' it was a few 4
16 hundred pounds greater.
17 Why don't you read it back?
18 (Record read.)
19 Q
At the time you were head of Plant Integratic n, 20 would it have-been extremely easy for you to find out
(,
91 exactly what the maximum discharge pressure was on the
~
high pressure injection pumps on B & W plants?
1 MS. VAUGHN:
Extremely easy?
What do you 21 mean?
25 MR. SELTZER:
Liku.as easy as picking up a
I Karrasch 538
~N 2
telephone and dialing any of five or six people 3
who were in the Pumps Section.
4 A
I would say that I could have obtained that 5
information via a phone call or by obtaining a document
'6 like a safety analysis report to look it up.
i 7
Q Did you keep SAR's in your office?
8 A
No, I did not.
9 Q
Were they available in the Plant Integration v
10 Section?
11 A
some of them were, not all of them.
(
12 Q
How many people were working on the ATWS 13 questions in Plant Integration in 19787 14 A
To the best of my recollection, there were between 15 three and five people in Plant Integration who had work 16 assignments related to the ATWS concern.
~
17 Q
Was it a full-time assignment,for those 18 people or were they working on other things 19 concurrently?
20 A
They were working on other things in addition to
(.
21 the ATWS assignment.
22 Q
Was there one person who was supervising 23 all of the ATWS assignments?
g-)
U 24 A
Yes, Art McBride was that person.
-25 Q
Are the files on the ATWS work located
i
\\
539
,-q t
Karrasch O
2 pretty much in one place?
3 A
I believe that Mr. McBride kept a central file of 4
ATWS documentation in 1978.
That is to the best of 5-my recollection.
'6 Q
In the course of the ATWS work, was a 7
question raised as to whether continued operation of 8
high pressure injection could result in a pressure 9
spike that would damage the reactor internals?
t 10 A
I don't recall any such questions'.
11 Q
In the course of the ATWS work, was there 12 any question raised about the possibility of a pressure U
13 spike created by the operation of high' pressure 14 injection?
15 A
I recall that analysis was performed to determine 16 what the transient pressure response of the entire 17 reactor coolant system was during an ATWS event.
If a 18 pressure spike were to have occurred, it would have been 19 part of the analysis to determine pressure versus time.
30 Q
Based on the understanding that you had in
(
3t 1978 of the reactor coolant system, was it your 33 understanding that the high pressure injection pumps 23 could create a pressure in the reactor coolant system f'%}
e\\/
gg greater than the maximum discharge pressure of the high 25 pressure injuction pumps?
In other words, without any
1 Karrasch 540 p
2 preamble, can an HPI pump create a pressure in the 3
reactor coolant system that exceeds the head of the 4
HPI pumps?
()
5 MS. VAUGHN:
As far as he understood in
'78.
6 A
I don't believe I knew the answer to that question 7
in 1978.
8 Q
Do you know the answer today?
9 A
I need to understand more about the specific t
10 conditions you are referring to before 'I can answer 11 such a question.
]v) 12 Q
Like what?
What conditions would you need 13 to know?
14 MS. VAUGHN:
I don't think Mr. Karrasch is 15 here as an expert to answer on that.
16 MR. SELTZER:
I will tie this back.
It 17 relates to his knowledge before the. accident.
18 Q
What are the conditions that you would need 19 to know?
20 A
What kind of a trandent are you imposing on the 21 reactor coolant system?
What assumptions are you 22 making about the performance of relief valves?
What 23 is the initial condition of the temperature and pressure
,3
(
\\
L.)
21 in the pressurizer?
I think there are many variables 25 that would have a direct' influence on the answer to i
1 Karrasch 541
'<x
)
,1 2
that question.
And it would require some analysis to 3
answer it.
4 Q
Have you ever done that analysis or had it 5
performed for you?
'6 A
What analysis?
You have to be specific.
7 Q
Whether a high pressure injection pump can 8
create a pressure in the reactor coolant system that 9
exceeds the maximum discharge pressure of the pump, t
10 A
I don't recall such an analysis being performed.
11 Q
Before you responded casually in the hallway
(
)
12 to Don Hallman regarding his August 3 memo, what C/
13 analysis had you seen about the response of pressure in 14 the reactor coolant system to high pressure injection 15 pumps staying on?
16 MS. VAUGHN:
I object to the form of the 17 question.
18 A
The analysis that I had seen, which could be l
helpful in answering that question, was the analysis 19 i
I 20 that had been performed for ATWS.
21 Q
I am trying to find out what particular l
22 part of that analysis you are referring to.
Who did l
23 it, what did he do, what was concluded, what did he 21 study.
Any of those.
25 A
The ATWS analysis includes a very rapid heat-up
i Karrasch 542 s
j 2
of the reactor coolant system, which causes a very 3
rapid expansion of the fluid in the reactor coolant system.
That expansion causes the pressurizer level 4
5 to increase, the pressurizer to go solid, and
.6 subsequently end up in water relief out the pressurizer I
safety valves.
8 A similar transient in the pressurizer 9
would occur if one were to leave the high pressure t
injection pumps running long enough for'the system to 10 11 go solid.
}
12 It is my understanding that the transient 13 would not be nearly as severe or as rapid as the ATWS 14 transient.
15 Q
With your last sentence, you. answered what 16 I was_ going to ask you.
Why would the transient not 17 be as rapid or severe as an ATWS transient?
What is 18 the crucial difference?
I9 '
A The ATWS transient causes the reactor coolant 20 to expand due to a rapid increase in temperature.
That 2I expansion, to the best of my knowledge, is at a greater 22 rate than the expansion that would result if the high i
pressure injection pumps merely injected fluid into the 23 I
\\/
.i g i
system.
25 Q
Hallman's question hadn't included this
(
5 1
Karrasch 543 p/
k 2
part of its hypothesized state of facts that the 1 -
reactor remained critical without scram, did it?
3 4
A I don't think Don Hallman's question.said one 5
way or the other.
'6 Q
When you said that the HPI situation 7
wouldn't progress as rapidly as the ATWS situation, 8
weren't you assuming that in the high pressure injection 9
situation posited by Hallman that there was a scram of t
10 the reactor?
11 A
No, I don't believe that the scram of the reactor
[\\
12 was an important distinction in the questions that Don R) 13 Hallman was asking me.
Maybe if I could see the 14 memorandum, it would help.
15 Q
Let me take you back a step.
You said you 16 didn't believe that an HPI situation would progress as 17 rapidly as an ATWS situation.
Whenyous}aidthat, I
18 asked you what did you mean, and you'said the heat-up 19 that causes the transient to progress rapidly, an ATNS, 20 wouldn't be there in a high pressure injection situation 1
21 Isn't it a fact that the heat-up is caused 22 by the fact that the reactor has not been scrammed in 23 an ATWS situation?
i g3 21 A
Yus.
The reason the reactor coolant fluid 25 expands so rapidly in an ATWS situation is that the l
544 1
Karracch
- q.
D 2
reactor is still producing power.
(Luncheon recess taken at 1:00 o' clock p.m.)
3 5
I
'6
-oCo-1 4
7 4
8 AFTERNOON SESSION 9
t 10 (2:15 p.m.)
i 11 B RUCE ADOL PH KARRASCH 12 having been previously duly sworn,, resumed and=
(
13 testified further as follows:
14 EXAMINATION (continued) i 15 BY MR. SELTZER:
16 Q
You understand that you are still under 4
17 oath to tell the truth?
i 18 A
Yes.
19 Q
Did you rely on analysis that was generated 20 as part of the ATWS project in answering Don Hallman's 21 first question as set forth by Hallman-in GPU Exhibit
)
22 80?
23 A
Yes, I did.
O V
24 Q
Did you rely on ar.y ATWS analysis to answer 25 Don Ha11 man's second question, what damage would the
,.,. -, _ _. ~. _
a f'%
1 Karrasch 545 2
water surge through the relief valve discharge piping 3
and quench tank cause?
4 A
I think with regard to the second question, I don't 5
recall looking at any specific analysis.
I do recall 6
that water surge through the relief valve discharge 7
piping was an issue that had been addressed in ATWS 8
and that it had been concluded that the valve's were 9
capable of handling a water discharge.
1 10 Q
But you don't recall relying upon that 11 information or analysis when you responded to Don n
12 Hallman; is that right?
(_)
13 A
No, I had that information when I did respond to 14 Don.
15 Q
what did you mean when you said you don't 16 recall relying on any specific information?
17 A
I think I am distinguishing between the use of 18 actual analysis, which is what I used in formulating an 19 answer to question No.
1, versus what I would consider 20 just general information that I had received during the 21 course of the ATWS analysis in the fall of 1978.
22 Q
If one were to look at all of the ATWS 23 analysis material that was generated in the fall of
'78, 21 are you say ing that someone would be able to find 25 information in there relating to whether water surge
546 1
Karrasch V
2 through the-relief valve discharge piping and' quench 3
tank would cause damage?
4 A
I don't know that.
5 Q
If somebody looked through the ATWS material 6
that was generated during the fall of 1978, would 7
someone be able to find information on the surge of l
8 Hallman's first question?
9 A
Yes.
t 10 Q
Do you know what form that information is 11 in?
()
12' A
To the best of my recollection, that information 13 l is in the form of transient pressure traces of the l
l 1
14 reactor coolant system during the entire ATWS event.
15 Q
Had work been done on transient pressure 16 responses for the ATWS program before the fall of 1978?
17 A
I don't knew for sure.
I know that work had been 18 ongr ing earlier than the fall of 1978.
I don't recall i
19 the specific nature of it.
20 Q
How do the transient analysis pressure 21 tracings that you referred to give any indication that 22 would respond to Hallman's first question?
23 MS. VAUGHN:
I will let him answer, but I
\\/
24 thought we went over this essentially before 25 lunch.
l,
I Karrasch 547 "T
(U 2
MR. SELTZER:
If you want to tell me what 3
the answer is, please do.
4 MS. VAUGHN:
No, I don't want to.
5 Q
Hallman's first question was if the
'6 pressurizer goes solid with one or more high pressure 7
injection pumps continuing to operate, would there be 8
a pressure spike before the reliefs open which could 9
cause damage to the reactor coolant system.
(
10 A
would you please now repeat the qdestion?
11 Q
The question is, how did the transient I )
12 analysis pressure tracings which you say were
(_/
13 generated in the ATWS work during the fall of 1978, s
14 lead you to an answer to Don Hallman's first question?
15 A
Those pressure traces, again to the.best of my 16 knowledge, show that there is no pressure spike before 17 the relief valves open.
18 Q
Do you recall that there are one or more 19 pressure traces that describe a transient during which 20 the high pressure injection pumps continue to operate?
21 And I mean pressure trace done in the fall of 1978.
m 22 A
I don't recall looking at any pressure traces 23-where the conditions were such that one or more HPI s
i
)
v 21 pumps were operating.
i 25 Q
Then how did the pressure traces help you
_--y-g---
r ys w-
1 Karrasch 548 gg
]
2 answer his question, if they didn't show one or more 3
high pressure injection pumps continuing to operate?
4 A
It was my understanding at-that time that the 5
pressure transient that is imposed upon the reactor 6
coolant system during an ATWS event is more severe than 7
the pressure trancient that would occur when one or 4
8 more HPI pumps continue to operate.
9 Q
How can it be more severe?
How do you know 10 it would be more severe?
In the fall o'f 1978 and the 11 beginning of 1979, did you know that an ATWS transient
[V) 12 would be more severe than an event in which one or more high pressure injection pumps continue'to operate?
13 14 A
That was the basis which I used to answer Don 15 Hallman's question.
16 Q
Why did you assume that basis?
17 A
I don't recall exactly how I came to that 18 conclusion.
I may have discussed it with someone in 19 Engineering, but the general phenomenon which is 20-occuring here is that the ATWS event causes the 21 reactor coolant pressure an'd pressurizer level tot 22 increase from the normal value up to the set' point of 23 the safety valves within seconds..
It is very rapid.
7-(
)
24 My underfatan' ding of the capability of the
= 25 '
high pressure injection system is that it would cause
- y. ' i..
y-
.f.,
f 1
Karrasch f.,
549
(~N, N-)
2 the pressurizer level and reactor coolant pressure to 3
increase up to the safety valve set points on the 4
order of minutes.
5 Q
That was your understanding in" the fall of.
-s
'6 1978 and early 19797 s
7 A
That was the basis upon which I could answer N
8 Don's first question.
s 9
Q That is the basis on which you answered it?
t 10 A
To the best of my recollection, yes.
y
.s 11 Q
So you assumed when you answered Don 12 Hallman's first question that whatever.the pressure
()
13 effects were that were created in'the situation he was 14 describing in his first question, that was a pressure 15 situation that would develop over a matter of minutes,e
't 16 not seconds is that right?
g
,7 17 A
Yes, to the best of my recollection.
18 Q
So you were assuming thaD he high pressure 19 injection pumps continuing to operate was a sit'u'ation f.
e-20 that was existing without a simultaneous trans'ient i s'A.,
((
21 without scram, right?
j 3
N 22 A
I don't understand that question.
ge y
.p
[
I i
~
4 'g 23 Q
If you had a simultaneoes transient with,outt g3 i
)
{
(,
to you said you would progred.slto high pressure 21
- scram, II
' \\ '.
25 the rolief valve set point in a matter of seconds, s
a t
j
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v
?
.- -.-._= _ __
1 Karrasch 550 g-
~'
2 right?
MS. VAUGHN:
What do you mean by 3
4
" simultaneous"?
()
MA. SELTZER:
Concurrent.
Happening at the 5
6 same time.
7 MR. FISKE:
What happening at the same time?
8
')
MR. SELTZER:
High pressure injection pumps g
running and the reactor not scrammed.
t MR. FISKE:
I think maybe we need some 4
10 11 clarificition.
I think what Mr. Karrasch was 13 testifying before, he was not testifying about 13 a situation in which there was.an ATWS and HPI w
s 14 at the sIme time.
N s,+
15 Q
Do Y.ou agree with your counse.l?
s.
16 A
Yes, he is exactly right.
17 MR. SELTZER:
That is all'I w'as trying to 18
/
clear up.
s s
-Q And you understood that Don Hallman in his 1si i
i
\\. '
gij first question was just asking you about HPI pumps A
s k
operatib withost.their being ATWS at the same times 3
I f
isn't that r ig h.t ?
5 33 4
- i.,
~g3 A
That was my un'derstanding.
[
}
21-Q So if you undurstood that Hallman's first s
33 question was just a sk ing you ab~ouc'HPI pumps. continuing s
i
- g
^ '.,
i
\\
44 &
i 1
Karrasch 551 I
1 Il' 2
to operate without ATWS going on at the same time, that 3
means that the reactor was scrammed at the time that the i
4 HPI pumps were continuing to operate, right?
5 A
Even though Don's memo states that the reactor
'6 was scrammed, I believe that was his intent.
7 Q
That is what you understood at the time, 8
that you were responding?
9 A
To the best of my knowledge, yes.
t 10 Q
If the reactor is scrammed at the time that 11 the high pressure injection pumps are continuing to
()
12 operate, you said that it would take several minutes 13 for the pressure to rise to the relief' valve set point; E
14 is that right?
15 A
That is my understanding, yes.
16 Q
And that was your understanding at the time 17 you were considering responding to Don Hallman's memo, 18 right?
19 A
Yes, that's correct.
20 Q
The cause of the rise in pressure over 21 several minutes is the water being added to the system 22 by the high pressure injection pumps; is that right?
23 A
The cause of the pressure excursion is the water 7_
(G) i l
being added to the system by the pumps, which causes 21 1
2.5 the steam space in the pressurizer to contract, and that 1
l 1
Karrasch 552 C
2 is what causes the pressure to increase.
3 Q
The high pressure idection pumps can only 4
4 cause the pressure to increase up to the maximum 5
discharge pressure of the pumps themselves; isn't that 6
right?
7 A
As I testified this morning, I haven't done that 8
analysis, but my guess would be that the pressure 9
could not go above the shutoff head of the pumps.
I 10 Q
Is that what your understanding would have 11 been, as best you can reconstruct it, in the fall of
()
12 1978 and early 19737 13 MR. FISKE:
I don't think he has to 14 reconstruct it.
It is a question of what he 15 remembers.
16 Q
From what you remember, do you recall 17 anything inconsistent with that from late
'78, early '797 18 A
I guess I don't really recall asking myself that 19 question in late 1978 or early 1979.
20 Q
With a reactor scrammed and high pressure 21 injection pumps continuing to operat'e, are you aware of 22 anything that you knew in(late 1978, early
'79, that 23 would cause' reactor coolant system pressure to rise
_ 7-s D
24 above the head of the high pressure inje~ction pumps?
25 A
No,'I was_not aware of anything.
v.
~
l l
[
l 1
Karrasch 553 lO t
2 MR. SELTZER:
I have no further questions.
3 EXAMINATION BY MR. FISKE:
4 Q
You have in front of you Mr. Hallman's 5
memorandum, which is Exhibit GPU 80; is that correct?
6 3
y,g, I
Q What is the date of that memorandum?
MR. SELTZER:
I think the document speaks 9
for itself.
I think it would be useful 11 I will read it into the record.
The date of this 12 memorandum is August 3,
1978.
13 Q
Is that correct?
I4 A
Yes, that is the date of the memorandum.
15 Q
Can you tell us what was going on in the 16 Plant Integration Unit in August 19787 17 A
To the best of my recollection, in early August of IO 1978, I had just returned from a one-and-a-half-week 19 vacation and was in the process of spending some amount 20 of extra time working with Allen Womack, who at that 2I time had just been named the new manager of the Plant 22 Design Section.
I l
U Q
When you refer to " extra time," what do you I
s'~
i 2I l
mean by that?
l 25 A
As the new manager, Allen was looking to me to
i Karrasch 554 ym k
2 assist him in learning about the duties and 3
responsibilities of both the Plant Integration Unit and 4
the Plant Design Section, and I found myself spending 5
considerable time with Allen in addition to my normal
.6 duties and responsibilities during the f irs t two or 7
three months of his tenure as the new manager.
8 Q
I think you said that after you received 9
Mr. Hallman's memo, you sent it to either Mr. Swanson 10 or Mr. McBride with a note asking them to look into the 11 questions raised.
Do you remember that?
12 A
Yes, that's correct.
13 Q
Did you take that action shortly after you 14 received Mr. Hallman's memorandum?
15 MR. SELTZER:
Objection.
Leading.
16 Q
Can you tell us how soon after you received 17 Mr. Hallman's memorandum you sent it to either Mr.
18 Swanson or Mr. McBride?
19 MR. SELTZER:
Objection.
No foundation this 20 witness has a recollection.
21 MR. FISKE:
I am asking the question.
22 A
I don't recall the exact time that I sent the 23 memorandum to Mr. McBride or Mr. Swanson.
I do recall
('-)
I 21 upon returning from my vacation that I was reviewing a j
25 very larqu backlog of mail which I had received while on
=
i 1
Karrasch 555 2
vacation, and I believe at that time that I quickly 3
scanned this particular memorandum, GPU Exhibit 80, 4
noted the two questions which were being asked of the 5
Plant Integration Unit and delegated a response to the
'6 questions to either Mr. McBride or Mr. Swanson by 7
writing a note at the top of the memorandum and sending 8
it to one of them.
9 Q
Were there any projects that were under way t
10 in the Plant Integration Unit in the late summer or 11 early fall of 19787 12 A
Yes.
13 Q
can you describe some of the more 14 significant projects?
15 A
There were quite a number of what I considered 16 very high priority projects under way in the Plant 17 Integration Unit.
18 Q
Would you describe some of the projects I
19 that you considered to be.high priority?
4 20 A
The anticipated transient without scram analysis (m
' 21 which was under.way was one of the most high priority 22 efforts.
referred M,
Q
.That is the program that.has been
-(
l
\\-d 21 to from time to. time in your deposition. earlier; is 25' that correct?
w
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y y
y9
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.-.7y 9
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.w gr
1 Karrasch 556 rw (w
2 A
Yes, that's correct.
3 I recall a major effort to re-evaluate 4
the small break analysis which had been performed on 5
our 205 fuel assembly plants.
~6 I recall spending a considerable amount of 7
personal time working on what was then called the 8
asymmetric loading problem.
9 There were several NRC issues which were 10 taking a considerable amount of time.
Some of these 11 that come to mind are a fission gas release program, a
(
12 program to requalify safety grade control room 13 instrumentation equipment, a program to respond to a 14 regulation guide which required the plants to be taken 15 to a cold shutdown condition entirely through the use 16 of safety grade equipment. And there was one other major 17 project which was under way throughout th}e entire the entire Nuclear Power 18 B & W -- excuse me 19 Generation Division at Lynchburg, and that was a 20 product standardization program, in which we were
(,
21 updating all of our documentation on the 205 fuel i
22 assembly plants to assure that the analysis and the 23 system requirements and the equipment specifications for i\\ '
{
I i
i
\\
/
21 l
hardware were all consistent and accurate and up to 25 date.
-j
. te whw
1 Karrasch 557 p
O 2
Q Do those describe some of the projects that 3
you considered to be high priorky in the late summer 4
and fall of 19787 5
A Yes, those are a representative sample of some 6
of the high priority projects.
I Q
You referred earlier to what we have been 8
't.
calling the ATWS analysis.
I don't think yet in this 9
deposition you have been asked exactly what you were e
analyzing in that program.
What was th'e ATWS analysis?
10 11 -
A Anticipated transient without scram was a 12 transient which was postulated by the NRC in which there was a loss of main feedwater and a sub' sequent increase 13 14 in reactor coolant pressure to the trip set point 15 which was supposed to. trip the reactor.
16 The concern in ATWS and the. postulated 17 condition was that the reactor did not trip when the 18 reactor protection system received the high pressure 19 signal.
This led then to a situation where there was 20 no feedwater provided to the steam generators to 21 remove the heat generated in the core, and the core 22 was still producing essentially full reactor power.
i 23 This is a very severe condition in which the reactor
'w./
24 coolant system temperature and pressure' increases to 25 values much greater than those previously analyzed.
m-w ~
w,,.r
-p,
I s.
Karrasch 558 l
2 The cor7ern is that the high reactor 3
coolant system pressures which are well in excess of 4
3,000 p.s.i.
could compromise the structural integrity 5
of the components and welds in the reactor coolant
'6 system and possibly result in severe damage to the 7
8 Q
You said that this ATWS project had been i
9 postulated by the NRC.
What did you mean by that?
t 10 A
To the best of my knowledge, the NRC reviewers 11 had some time ago begun asking questions about the 12 reliability of the reactor protection system to scram 13 the reactor when a demand signal occurred.
i 14 Q
In other words, the work that you were 15 doing on this ATWs project was being done in response i
16 to questions raised by the NRC7 II-A That's correct.
18 Q
I think the next project you mentioned was 19 the work on the small break analysis on 205 plants?
20 A
Yes.
'21 Q
Can you describe'that briefly?
22 A
.Sometime during the spring and' summer of 1978, it 23 was discovered that the small break analysis for the
.O.
V l
21 1
205 fuel assembly plants had assumed that'there was a 25 very high water level on the secondary side of_the steam
... -. ~
i Karrasch 559 g
l (G
2 generators to enhance condensation heat transfer on 3
the primary side and subsequently core cooling during 4
the small break LOCA.
5 we also determined sometime during that
~6 time frame that there was no instrumentation installed 7
on that 205 fuel assembly plant to measure such a high 8
level in the steam generator, nor was there a system 9
installed to automatically bring the water level to that t
10 point.
11 Integration was in the lead to resolve
(~)
12 that generic problem and determine what the best V
13 solution would be.
This was one of those situations 14 where our role as an integrator resulted in us being 15 asked to resolve an inconsistency between the analysis 16 which had been performed on the plant and the hardware 17 which had been designed and procured.
18 Q
When you refer to the 205 plants in 19 connection with this analysis, were those plants that go were then still under construction?
(,
31 A
Yes.
None of the 205 plants were operating at 32 that time, nor are they yet operating today.
33 Q
You referred earlier to an asymmetric
)
/
loading problem that you were working on in the late 33 25 summer and fall of 1978.
Can you tell us what that was?
560 1
Karrasch Q
2 A
Yes.
The asymmetric loading problem was another 3
NRC concern in which they had discovered that for 4
operating 177 fuel assembly plants that we had never 5
taken into account the loads imposed on the reactor
'6 vessel due to a pipe rupture inside the reactor vessel 7
cavity.
As a result of this discovery, the NRC told 8
our operating plant utilities to do an entire 9
re-analysis of the supports and restraints and the e
10 loads on the reactor vessel for a postulated 11 double-ended rupture of the hot or cold leg pipe where 12 it is attached to the reactor vessel.
13 One of the people in my unit was asked to 14 take the lead in resolving this problem and getting J
15 the analysis performed to the satisfaction of the NRC.
j 16 Q
You referred -- and that work was also 17 going on in the summer and fall of 19787}
18 A
Yes.
That work had been ongoing since 1977.
It l9 was a very big project.
20 Q
You referred to a couple of other projects
(,
3t which you described as NRC issues, one of which was the 23 fission gas release program?
33 A
Yes.
~%
i
]
h gg Q
Can you tell us about that?
I I
25 A
One of the people in my unit was asked to direct
i f
i Karrasch 561 f fs N.J 2
a program to determine exactly what the proper values 3
were for the amount of fission gas which is released 4
from the fuel during operation.
The NRC has asked a 5
question about our models and techniques for predicting
'6 the fission gas which is released from the fuel, and 7
they questioned whether or not we were conservative.
8 The concern is that if you underpredict 9
the amount of gas which is released, you would 10 consequently underpredict the internal pressure which 11 is generated inside the fuel rods.
(
12 As you remember my testifying earlier, the 13 first barrier to the release of radicactivity is the 14 fuel rod cladding, which therefore it is very important 15 that you accurately predict how much fission gas is 16 released from the fuel and how much pressure build-up 17 there is inside the rods.
18 During the fall of
'78, we had embarked on 19 a program to re-analyse and recalculate the amount of 20 fission gas released inside the fuel rod, 21 Q
Then I think you referred to another project m
22 that you were working on involving requalifying 23 instrumentation?
4 g%,}
\\
21 A
Yes.
25 Q
Could you describe that project?
b
1 Karrasch 562 o
2 A
Prior to the summer of 1978, the NRC had issued 3
a new regulatory guide.
I believe the number is 4
Regulation Guide 1.89, which stipulates that all control 5
and instrumentation hardware which is inside the
'6 reactor building must be able to withstand the 7
environment which is imposed upon it during its service I
8 in the plant.
They impose such stringent requirements as 9
making sure that we addressed aging of the equipment, 10 making sure that we addressed operability of the 11 equipment in the environment caused by a LOCA or steam
()
12 line break, and making sure that procedures were in place 13 to check the calibration of this hardware so that it 14 maintained its accuracy over the entire 40-year life 15 of the plant during both accident and norma 1' conditions.
16 This was a major project which is still it 17 under way today, and to the best of my recollection, 18 required a significant amount of time by several people 19 within the Plant Integration Unit.
20 Q
I believe you also referred to work that
(,
21 you were doing in response to a reg. guide having F
22 to do with being able to proceed to a cold shutdown 23 condition?
..I 21 A
Yes.
This was another rey. quide which the 25 NRC had recently issued which required that the plants
a
,- c-1 Karrasch 563
/
)
NJ 2-install safety grade equipment to allow the operator 3
to cool the plant down to a stable condition on the 4
decay heat removal system.
The previous requirements f.
5 had stated that the plant could be maintained in a
'6 stable hot shutdown condition by the use of safety 7
grade equipment.
This new requirement stated that in 8
addition to maintaining the plant safe during hot 9
conditions, that equipment be installed and qualified i
10 to cool the plant down and maintain it in a safe 11 condition at cold conditions.
12 Here again, this is an issue which requires i
13 the utilities to re-analyze and redesign and reprocure a 14 considerable amount of hardware to be back-fit to 15 their plants which are currently under construction.
16 Q
This again was going on in the late summer
}
17 and fall of 19787 18 A
Yes, it was.
19 Q
Then you referred also to a project 20 spreading across the entiro Nuclear Power Generation
(
21 Division involving product standardization?
33 A
- Yes, g
Q-Could you describe that briefly?
f~%
21 A
S mutime in the spring and summer.of'1978, we 33 discovered that the documentation which defir.es our 205
1 Karrasch 564 2
fuel assembly product had a good number of 3
inconsistencies and inaccuracies in it which really 4
did not meet our quality standards for having good, 5
sound documentation to back up our product.
'6 As a result of such a situation, B 4 W 7
could be very open to audit by either customers or the 8
NRC and could find ourselves in the situation where 9
the equipment which we had purchased for a 205 fuel t
10 assembly plant would not be good equipment, so a very 11 high priority effort was undertaken in the fall of '78 12 to make sure that all of the analysis and the system 13 requirement specs prepared by Integration and the 14 equipment specifications which were used to buy hardware 15 were all consistent and right and up to date to the l
16 latest standards.
That was a major effort which took
~
17 up to 10 or 12 people out of the Plant Integration Unit 18 on almost a full-time basis during the fall of 1978.
19 Q
Again, was the project that you just 20 described being conducted with respect to the 205 plants 21 that were then under construction?
22 A
Yes.
23 Q
You testified in response to one of Mr.
I (O
i
+
24 Seltzer's questions earlier that during.this period of 25 time in the~1 ate summer and fall of '78 you and others
1 Karrasch 565
^w(V
\\
2 in the Plant Integration Unit were working nights and 3
weekends.
Do you recall that testimony?
4 A
Yes.
5 Q
Were you working nights and weekends on the
'6 projects you just described?
t 7
A Many of the projects which I just described were 8
projects which came in which were in addition to our 9
normal duties and responsibilities.
It was an overload i
10 of work, so to speak.
As a result, rather than staff 11 up the unit with more people for what we perceived to be 12 a short-term extra amount of work, a good number of the 13 people in Integration were asked to work overtime to 14 handle not only their normal duties and responsibilities, 15 but also these additional work projects..To the best 16 of my recollection, a good number of people did work 17 nights and weekends, including myself.
18 Q
Do I understand from your testimony that 19.
during this period of time in the summer and fall of f
20 1978 there were many other projects going on in the 21 Plant Integration Unit, other than the ones you have 22 described?
23 A
Yes.
27_
t s
\\j i
Q Without tak ing the time here to go through 21 l
25 every single one of thusu projects separately, do I
I Karrasch 566
~s
)
I 2
understand from what you just said that the projects 1
3 that you did describe in some detail a few minutes ago 4
were projects that were putting this extra workload 5
pressure on your unit during this period of time?
~6 MR. SELTZER:
Objection.
Leading.
7 A
Yes, those projects are the key ones that I can 8
recall that were causing the extra workload in the 9
Plant Integration.
t 10 Q
Now, I think you told Mr. Seltzer in 11 response to his questions that on two occasions, possibly 12 three occasions, in the fall of 1978, early 1979, Mr.
13 Hallman asked you in effect how you were coming on the 14 questions that he had put in his memorandum and that you 15 told him that someone was working on that.and would be 16 getting back to him with an answer.
testimonk?
17 Do you remember that 18 A
Yes, I do.
19 Q
When you told him that someone was working 20 on it, whom were you referring to?
21 A
I was referring to either Art McBride or Eric 22 Swanson.
23 Q
At page 45 of your deposition earlier in this p_
(
)
24 case, Mr. Seltzer asked you the following question and
'~'
25 you gave the following answer:
1 Karrasch 567 l
w 2
" Question:
It is a fact, isn't it, Mr.
3 Karrasch, that you know of no work that was done by 4
anybody in the Plant Integration Section to resolve Don 5
Hallman's questions between August 3, 1978 and New
'6 Year's 1979; isn't that right?
3 7
" Answer:
There was work under way in the 8
Plant Integration group on other subjects which are g
related to the questions which Don Hallman was asking.
(
10 As a result of being aware of that work; I was able 11 sometime after the first of the year, to the best of
(}
12 my recollection, to respond to Don Hallman's questions."
13 Do you remember being asked that question 14 by Mr. Seltzer and giving that answer?
15 A
Yes, I do.
16 Q
What work were you referring to in that 17 answer that was under way in the fall of ~
in your 1978 18 unit which was related to the questions which Mr.
19 Hallman had asked you?
20 A
The work that I was referring to was the
(,
gt anticipated transient without scram evaluation, which I 33 described earlier.
23 Q
Was there a particular person in your unit gg who had primary responsibility for that work?
3,5 A
Yes.
I-- -..
-i
_____m
.1 Karrasch 568 m
2 Q
Who was that?
3 A
It was Art McBride.
4 Q
I think you told Mr. Seltzer in response k
5 to his question that sometime after the first of the
'6 year you yourself reviewed Mr. Hallman's memorandum in 7
order to try to come to a determination with respect 8
to the questions that he had asked.
Do you remember 9
that?
I 10 A
Yes.
11 Q
I take it you did that at that time after 12 work had proceeded during the summer and fall on the 13 ATWs project?
[4 A
Yes, that's correct.
15 Q
could you tell us, to the best of your 16 recollection now, what your thought process was in 17 analyzing that memorandum of Mr. Hallmana,. attempting 18 to answer his questions?
[9 MR. SELTZER:
Are you asking him what was 20 his thought process sometime in 19797 21 MR. FISKE:
Yes, at the time he already 33 testified he sat down with the memorandum, 33 reviewed it in order to be able to answer Mr.
~
.f^%-
(_)
33 Hallman's questions.
23 A
To the best of my --
i
,+-
e.
a 1
Karrasch 569 d(~S 2
MR. FISKE:
What I am asking Mr. Karrasch r
3 is at the time he sat down with that memorandum, 4
reviewed it in order to come to an answer with 5
respect to Mr. Hallman's questions, what thought
'6 process did he go through in the course of 7
answering those questions.
8 MR. SELTZER:
You are focusing on his thought 1
9 processes in 1979 sometime between January 1 and t
10 March 15, which is the period in which he says 11 to the best of his recollection he responded to I
12 Don Hallman; is that right?
()
13 MR. FIS KE :
I am asking Mr. Karrasch about 14 that point in time in early 1979, as he has 15 previously testified, when he reviewed Mr.
IG Hallman's memorandum for the purpose of analyzing 17 the questions and responding to th e'm.
18 A
To the best of my recollection, I recall reading 19 Don's memorandum sometime after the first of the year 30 and recognizing that the real concern that_was being
(,
31 addressed here was that of uncovering the core if there 22 were an operator interruption of high pressure injection 23 I recall thinking that that should be an 4
[
1 v
gg unlikely event because the operator should not interrupt 25 high pressure injection, and in fact, my perceived
1 Karrasch 570 3
G 2
understanding of the procedures and my very good 3
understanding of the way the plant was designed told 4
me that once high pressure injection comes on at 1600 5
p.s.i.,
that both the design and the procedure
'6 state that it should be left on until the pressure 7
recovers above 1600 p.s.i.
So it was --
8 Q
What conclusion did you come to with respect 9
to the questions that Mr. Hallman had raised in that t
10 memorandum?
11 A
In addition to understanding the real concern as
[v) 12 I just discussed, I also had obtained the benefit 13 several months previous to January 1979 of the analysis 14 that had been under way on ATWS, and as I testified to 15 Mr. Seltzer earlier, that analysis of ATWS was useful the presence 16 in answering Don's first question about _
17 of a pressure spike before the reliefs op'n.
e 18 Q
And you have already explained your thought 19 process with respect to that in response to Mr. Seltzer's 20 questions; is that correct?
21 A
Yes.
22 Q
What conclusion did you come to with respect 23 to the second question raised by Mr. Hallman in light 7
i j
~'
23 l
of the concern expressed by Mr. Dunn?
25 A
The ATWS analysis had addressed the issue of water
}
i 571 1
Karrasch
/-s\\
\\
l v
4 2
surge through the relief valve and the relief valve J
3 discharge piping and had concluded that the valves would pass water.
In addition, I determined that any damage 4
I 5
that coulu occur to the surge line excuse me -- any
.6 damage that could occur to the relief valve discharge I
piping would really be insignificant to the concern 0
that was expressed here, that being the potential for 9
uncovering the core.
i.
10 I was able then to conclude that there would 11 be no pressure spike and that the concern that was
()
12 being expressed, th a t being potential for uncovering i
13 -
the core, was a much more significant concern than any 14 potential damage to the relief valve discharge piping, a
15 and I could then, with that analysis, answer Don's two 16 questions.
l II Q
So to conclude your thought process at that 1
18 time, what was the conclusion that you reached with D
~
respect to'the questions raised by Mr. Hallman in 20 relation to Mr. Dunn's concern?
2I
.A I believe as_a result of that analysis, I-22 concluded that the potential for uncovering.the core 23 due to operator interruption of high pressure injection 2I
- wasfa concern which was much more significant than the 2*I ~
two concerns that Don had addressed in his two questions i
cn. '
r
,,t-ee+
+wr-t T
= +
/ ~s -
1 Karrasch 572 2
to me, and I thought that if Bert thought additional 3
clarification to the operators on when to terminate 4
HPI was a prudent thing to do, then I agreed that indeed 5
we should go ahead and communicate that to the utilities.
"6 Q
Did you, after reaching that conclusion, 7
communicate that conclusion to Mr. Hallman?
8 MR. SELTZER:
Which conclusion?
'He has 9
enunciated several now.
He has his answer to j
e 10 Question 1, his answer to Question 2,
and his 11 thoughts on Bert Dunn's recommendation that 12 additional advice should be given to the operators.
13 MR. FISKE:
I will rephrase the question.
14 Q
You testified, I believe, in response to 15 questions by Mr. Seltzer that you had a conversation 16 with Mr. Hallman on the subject cf Mr. Hallman's 17 memorandum sometime in early 1979; is thahcorrect?
18 A
Yes, that's correct.
To the best of my 19 recollection.
20 Q
To the best of your recollection, how soon 21 after you had reached the conclusions that you just 22 described did you have that conversation with Mr.
23 i
Hallman?
3
)
I 21 MR. SELTZER:
If you can recall.
2.5 A
I think, as I testified earlier,.I don't know for
1 Karrasch 573 (N,
(_./
2 sure, but I believe it was within a week or two after 3
I went through this thought process following my 4
reading of Don's memorandum.
5 Q
And did you communicate to Mr. Hallman your
'6 conclusion that the additional clarification could be 7
sent to the customers?
8 A
I don't recall the exact nature of the 9
conversation with Don except to say that I told him 10 that I had the answers to his questions', and I believe 4
11 I told him what those answers were and that I thought
'N 12 that in light of the fact that potential uncovering of
[d 13 the core is a valid concern, that I thought that was more 14 significant than the concerns raised in the two questions.
15_
Q After you had that conversation with Mr.
16 Hallman, did you believe that you had answered the 17 questions that he had. raised in his memorandum to you?
18 A
Yes, I believe I was satisfied that I had 19 responded to Don's-memorandum.
20 MR. FISKE:
That is all I have.
21 FURTHER EXAMINATION 22 BY MR. SELTZER:
22 Q
You said after you reached you conclusions
(~)
\\)
21 about Don ~Hallman's questions, it was a week or two-25
~before you bumped into Don Hallman'in the hall and gave
1 Karrasch 574 fx 2
him any response.
Before coincidentally bumping into Don 3
4 Hallman in the hall and giving him a response, had you 5
developed any thought about how you were going to
~6 respond to him?
7 MR. FISKE:
I think you already asked that 8
question in your direct examination.
I will 9
object.
(
10 Q
You can answer.
11 MR. FISKE:
You may put an answer on the 12 record that will be subject to a, ruling thereon.
13 A
Again, to the best of my recollection, I do recall a
I 14 reading the memo, formulating in my mind the answer to 15 Don's two questions just because I had been involved 16 with the ATWS issue and could now answer those questions, theurgencyofth}e potential 17 but still I didn't feel 18 possibility that was expressed of uncovering the core 19 due to operator interruption of high pressure injection.
j 20 So once I answered the two questions in my m.ind, I merely
(,
31 told myself that I would get to Don Hallman as soon as 22 I could and answer his two questions.
23 Q
Did you have any intention after you had
!q.
\\!
formulated an answer to dictate a memo to Don Hallman?
31 e
.g3
'MR.
FISKE:
Same objection, o
l l
l 1
Karrasch 575 2
A I don't recall that.
3 Q
Did you formulate any intention to set up a 4
meeting with Don Hallman or with Don Hallman and others 5
to discuss your answer to his questions?
6 MR. FISKE:
Same objection.
7 A
No, I did not.
8 Q
Did you plan to call Don Hallman'up at a l
9 convenient time and tell him over the telephone what 5
10 the answers were?
11 A
I may have.
I don't recall.
(
12 Q
Do you have any recollection of at any point 13 setting out to look for Don Hallman to'give him the 14 answers to these questions?
15 A
Again, I may have.
16 Q
The question is, do you have a recollection 17 of doing so, not "I may have."
He is answering the question, 19 l and I believe on numerous other occasions you l
20.
would have welcomed that kind of a responses any 21 response,you have said many times, in whatever 22 the words the witness wishes to put it, may be 23 useful in constructing a glimmer of a
~
recollection, fs
- 1\\_/
I 21
'is something you have always solicited.
I don't 25 see how you can object to his answer until you t-E-
d"'
1 Karrasch 576 O..
t 2
have heard it.
3 MR. SELTZER:
It seems strange out of your 4
mouth.
You are usually saying, through a clenched 5
fist, "How can you ask a witness that?"
'6 Q
Do you remember what the question is?
7 MR. FISKE:
Read the question and answer 8
as far as it got.
9 (Record read.)
10 A
I may have. I don't recall.
I do' recall 11 formulating the answer to those two questions in my 4 ()
12 mind, and my normal practice would be to do something 13 when I had the time to do it.
14 Q
Do what?
What would it have been your 15 normal practice to do in responding to questions in 16 written form from Don Hallman such as GPU Exhibit 80?
17 A
To communicate back to Don the answ'ers to his 18 questions, either verbally or in writing, possibly in 19 a meeting.
I make a judgment many times on what the 20 best, most efficient means of making a communication is
(,
21 at B &
W.
On this particular instance, I did not elect 22 to follow up with a written memorandum.
O Q
If you had not run into Don Hallman quite 23 i
21 i
by chance in the hall and given him an answer on the 25 fly, as it was, do you know when thereafter you would 1
7 2
i<
- 3,
+
~
+\\
Karrasch "t
'577 s
i 2
have responded to him?
\\
3 MR. FISKE:
I object to that question-4 because of the form and also bechse it is s
5 hypothetical and also because it was already N
'6 asked and answered.
P 7
Q What is the answer?
8 MR. FISKE:
I think he said by definition 9
his response to Mr. Hallman would be to some 10 degree later than it was by having met him in t' h e s
r 11 hall and communicating with hit,..but'he couldK't h
12 say how much later it would-have been.
I think V
13 that is almost a verbatim paraphrase of the T,\\
1
(
3 3,,
Ns 14 answer he gave.
{
s,'
..s 15 If that saves time,.I an happy to make'that 16 contribution.
s A 'i _
[ ',
17 Q
Is what Mr. Fiske said consistent.1rith your 18 reco'3ec ton and would that be your testimony'if you
~'n 19 I c ar 9 taday?
1 20 A
Yes, it would.
21 Q
During the fall of 1978 and early 1979,
',j s
22 how many people were wvrking iri'your Plant Integration
}
% ^a g
>H 23 Unit?.
O; 1
s u
,1
- /
21 A
Somewhere betwuen 20 and 24. people.
.l 25
~Q-Did the staffing 1 increase during that time s
~
y "u,
,1
\\
~
1 Karrasch 578
,s 3
i, i
2 period?
A I don't recall exactly.
I do recall that the
.3,
'g 4' g
ctaff level of Plant Integration stayed pretty constant s'
p, 5
during.my entire tenure as manager of that group.
m.
'6 Somewhere between 20 and 24 people.
7 Q
To t,he best of your recollection, did you 8
ask for any increase in staffing during the fall of '78 7
g 9
and early 1979?
5 10 A
I recall going through the budgeting process for 3
11 the next, year, which would be 1979, and putting in for
~
s
'\\
1 something greater than 25 people.
13 MR. FISKE:
Total?
s I
-3 E
14 THE WITNESS:
Total.
3 15 A
I don't r call if that-was ever approved or not.
,s 16 Q
In response to questions by Mr. Fiske about
\\
'\\ w s
,g 17 cpera' tor interruption of high pressure injection, you.
4 k'
' 3 s
18 said'from your understanding of procedures and from your i
l
>s 6
\\
r j-19 u.1qerstanding about how the plant was intended to be 1
r l
20 operated,'the high pressure injection should be left s
(,
31 on untir.a certain pressure level was reached.
~
. v
/
As of the spring of 1979, had you ever made 22 s'
i d1 l
a detailed study of the procedures that were in effect
{
93
(~N l
l i
i t
l,,56 at3y.B I
& W plants?
gg If 25
- A Toqthe best of my knowledge, no.
1 w
7..
t 1
Karrasch by 579 f
2 Q
Were you specifically familiar with the 3
B & W draft procedures communicated to any B & W 4
plant relating to pressurizer operation?
5 A
Again, to the best of my knowledge, no.
^6 Q
Were you familiar in the spring of 1979 with
(
7 the B & W limit and precaution relating to the level to 8
which the pressurizer could be filled except'under 9
hydrostatic test conditions?
t 10 A
No, I don't believe I was familiar with that limit 11 and precaution.
(G')
12 Q
Were you familiar with the.B & W draft 13 procedure sent to any operating utility relating i,
14 specifically to loss of reactor coolant, loss of 15 pressure?
16 A
To the best of my knowledge, no.
~
17 MR. SELTZER:
.I would like to mark as GPU 18 389-Bruce Karrasch's October Activities Report, 19 dated October 31, 1978.
)
20 (Document above described so marked as
(,
21 Plaintiffs' Exhibit GPU 389 for identification, 22 as of this date.)
23 Q
You testified on cross-examination by Mr.
I 21 l
Fiske about certain proiucts which were-high priority 25 during the summer of 1978 and the fall of 1978.
Do'you
l I
i Karrasch 580 gg ih s
2 recall that?
3 A
Yes, I do.
4 Q
Was the ATWS project a high priority project" 5
A Yes, it was.
'6 Q
Was it one of the projects that was 7
consuming a substantial amount of time in the Plant 8
Integration Unit during the summer of 1978 and the fall 9
of 19787 e
10 A
I wculd.ay that it was taking something around 11 half of Art McBride's time, plus up to half the time 12 of two or three other people in the Plant Integration 13 Unit.
I would consider that a big project for our group.
14 Q
You have described how busy you and your 15 unit were during the latter half of 1978 and into early 16 1979.
17 How long did it take you, whe'n you sat 18 down and thought about it, to come up with the answers 19 to Don Hallman's questions?
20 A
No more than a couple of hours.
I think the
(
2t important point-is that I couldn't do it until I had 22 gathered and understood the evaluations that were going M
on in ATWS.
O
/
23 Q
Take a look at your October. Activities Report, N'
25 GPU Exhibit 389, and tell me.if you find any reference
l i
l l
I-O 581 1
Karrasch v
2 in there to ATWS work.
3 MR. FISKE:
You are just showing him the 4
October report?
5 MR. SELTZER:
Right.
I l
i l
.6 A
No, I don't see any reference at all to the ATWS 7
issue in my October Activities Report to Allen Womack.
8 Q
We didn't get all of your activities 9
reports, and we looked through the production.
We 10 don't have all of them.
11 I am going to show you your August 1978
[~ )
12 Activities Report also and ask you if you can find any w
13 reference in it to the high priorty ATWS program.
14 (Recess taken.)
15 BY MR. SELTZER:
16 Q
You said in order to answer Don Hallman's 17 first question, you looked at pressure traces 18 generated in the ATWS program, right, or you recalled 19 information from pressure traces done for the ATWS 20 program, right?
k, 21 A
Yes, I think it is more accurate to state that I l
22 recall the.results of the analysis which showed pressure l
l l
23 traces from the ATWS event.
7 s.
\\
\\-)
24 Q
Was it your understanding that the increase 25 in p re s sure - cau:4 ud by the anticipated transient without i-L a
i
~
l Karrasch 582
(
2 scram was a more rapid increase in presssure than would 3
occur with a continuous HPI injection with scram?
4 A
Yes, that was my understanding.
5 Q
Did you therefore conclude that if the
'6 reactor coolant system could safely survive the pressure 7
increase of a transient without scram, that the reactor 8
coolant system could therefore safely survive the i
9 pressure increase from a high pressure injection with t
10 -
11 MR. FIS KE :
Would it help to hear the 12 preceding question and answer again?
(
13 A
I would like to hear the last question one more 14 time.
15 (Record read.)
16 A
In order to look at the potential for damage to 17 the reactor coolant system, you have to look at more 18 than just-the pressure trace itself.
The additional 19 thing that has to be studied is the stresses which are 20 induced in the reactor coolant system due to the
(, -
21 pressure.
22 The ATWS analysis involved a transient 23 whure the pressure and pressurizer level were increasing I
21 very rapidly _to thu sut point of the safety valves.
i 25 When they got there, the safuty valves opened and
_~
1 Karrasch 583 2
discharged a mixture of water and steam.
That analysis showed that there was no pressure spike in the reactor j
3 4
coolant system before the relief valves opened.
In the C
ATWS transient, after the relief valves opened, the 5
'6 pressure continues to go very, very high, up above 7
3,000 pounds, and therefore a stress analysis must be 8
performed to evaluate the structural integrity of the reactor coolant system, 9
t 10 In the situation where the high-pressure 11 injection pumps are on and the reactor is tripped, once
(~h 12 the relief valves open, they can relieve the full amount
\\_)
4 13 of flow rate being injected by the pumps, and therefore g4 the pressure does not go above 2500 p.s.i.,
so the real the important question for the 15 question -- excuse me 4
16 high pressure injection scenario is will there be a 17 spike before the valves open, which is the question that 18 Don asked.
19 The important question for.ATWS is how high does the pressure go and will the reactor _ coolant system 20
(
31 maintain its integrity.
33 Q
It didn't take the ATWS analysis for you 33 to know that the set point for the relief valves was
- 0
(.)
3g l
2500 p.s.i.,
did it?
3,5 A
No, it did not.
1 1
Karrasch 584 2
Q And it didn't take the ATWS program for you 3
to know that the relief capacity of the safety valves 4
exceeded the pumping capacity of the high pressure 5
injection pumps, did it?
'6 A
No, I don't believe it did.
7 Q
What did the ATWS program add, then, to your 8
ability to answer Question l?
9 MR. FISKE:
He just told you two minutes ago.
10 MR. SELTZER:
I don't think'he answered it.
3 11 I think as we have developed it now, he knows
()
12 that the pressure is going to be relieved at 2500 13 and he knows it-can handle the full capacity of 14 the high pressure injection pumps.
15 Q
What else do you need to know,to answer 16 Don Hallman's question?
17 MR. FISKE:
He told you.
18 MR. SELTZER:
Don't 19 MR. FISKE:
Let's have it read back.
20 (Record read. )
21 (Re c e s s taken.)
f 22 BY MR. SELTZER:
23 Q
Now you can answer the question with Mr.
24 Fisku's objection stated.
The question is, what did the 25 ATWS program add to your ability to answer Question I?
I
1 Karrasch 585 2
A Don was asking if there would be a pressure spike 3
in the reactor coolant system before the relief valves 4
opened.
Until the ATWS' analysis was completed, I did 5
not know whether or not there would be a spike during
'6 the time that the valves were going from a closed 7
position to an open position.
The analysis confirmed 8
that there would be no spike.
9 Q
In what form is that information?
In other i
10 words, if somebody looked back through the ATWS material, 11 what form would you see that information in?
I N
i 12 A
To the best of my recollection, the results of the
~)
13 analysis are presented as curves or graphs of reactor 14 coolant system pressure versus time.
Those curves 15 demonstrate that there is no pressure spike at the point 16 where the pressure reaches 2500 p.s.i.
17 Q
Are the tracings based on emp'irical data?
18 A
To the best of my knowledge, they are based on 19 computer calculations.
20 Q
So it is a computer simulation of operation, j
(,
21 not actual experience?
22 A
Yes, to the best of my knowledge.
23 MR. SELTZER:
I would like to mark your v
/
l August Activitius Report, dated September 1,
- 1978, 28 i
25 as GPU Exhibit 390.
}
1 Karrasch 586
,,f-2 (D ocume n t above described so marked as 3-Plaintiffs' Exhibit GPU 390 for identification, 4
as of this date.)
5 Q
Do you recognize that as a copy of your
'6 August Activities Report sent to Al Womack on 7
September 1, 1978?
8 A
Yes, I do.
9 Q
Do you see anything in there about the t
10 ATWS projects?
11 A
No, I do not see anything in the August Activities
)
12 Report to Al Womack on ATWS.
%J 13 Q
Do you see anything in there, including 14 under "New Commitments," which is on the last page, that 15 refers to Don Hallman's request that Plant Integration 16 lend assistance on the questions that Hallman raised in 17 GPU Exhibit 807 18 A
No, I do not.
19 MR. SELTZER:
I have no further questions.
20 FURTHER EXAMINATION
~
21 BY MR. FISKE:
22 Q
You testified earlier, I believe, that the 23 work on the ATWS project was under way before August of 24
-1978; is that correct?
l 25 A
Yus,_to the bust of my knowledge, it was under way
=
c 9
y
1 Karrasch 587
%/
2 before August of 1978.
3 Q
Yesterday, there was marked as an exhibit 4
the monthly progress report for December 1978, and that 5
was marked as GPU Exhibit 379, and I will show you that
'6 and ask you if you see the reference to the ATWS matter 7
in that document.
8 A
Yes, there is a reference to the ATWS evaluation 9
in item "C"
under " Accomplishments."
t 10 Q
You testified in response t'o Mr. Seltzer's' 11 questions that in coming to the conclusion that
/"'
12 existing procedures should require that HPI be left on
\\_
13 until pressure has come back up to at least 1640_ pounds 14 per square inch, you had not reviewed any of the 15 procedures that in fact had been issued to the 16 operating utilities.
Do you remember that answer you 17 gave him?
18 A
Yes, I remember that answer.
19 Q
What, then, was the basis for your conclusiod 20 in January 1979 that existing procedures should require
(,
21 that HPI should be left on until pressure came back to 22 at least 1640 pounds per square inch?
23 MR. SELTZER:
I don't think that is what
\\-
24 l
he said in his prior testimony.
1 I
25 MR. FISKE:
I believe he testified --
I Karrasch 588
<w f
I
.O 2
MR. SELTZER:
I think he said 1600 p.s.i.
3 I think you are just showing it is really counsel 4
that is giving testimony here and not the witness 5
and supplying greater precision than the witness
'6 was capable of supplying.
7 MR. FISKE:
Do you care to leave that comment 8
on the record?
9 MR. SELTZER:
I am really objecting more to s.
10 leading and mischaracterizing of'the testimony.
11 Q
My question is simply what was the basis (a~')
12 for your belief in January 1979 that the existing 13 procedures should prevent the interruption of HPI when 14 pressure was below the actuation point?
15 A
During my tenure as manager of Plant Integration, 16 I became quite knowledgeable in the design and operation 17 of the plant safety systems.
That knowledge included 18 an understanding that the set point for high pressure 19 injection was a very important variable in the plant.
20 For instance, the design included a key
(,
21 lock bypass.that required the operator to actually take 22 an action by turning a key before he could take the 23 pressure intentionally below 1600 p.s.i.
without high 24 prussure in jection automatically com ing. on.
l 2,3 I also knew that all of the analysis that l
i Karrasch 589 gg
)
gi 2
had been done using the high pressure injection system assumed that the high pressure injection system stayed 3
4 on until pressure had recovered to above 1600 p.s.i.
5 To me, it was inconceivable that anybody would be
'6 in s t ru c t e d to terminate high pressure injection below 7
that set point.
8 Q
You had not, I take it, reviewed the specific 9
procedures that were in effect at TMI-2 as of January L
10 1979; is that correct?
11 A
I had not reviewed the procedures.
I assumed that I~h 12 the procedures would not allow the operator to terminate 4
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13 high pressure injection below the set point based upon 14 my knowledge of the analysis and the design.
15 Q
But you did not know in January 1979 that 16 in fact the procedures in effect did require the 17 operators to leave HPI on until pressure had risen back n
18 above 16007 19 MR. SELTZER:
Objection, no foundation, 20 l leading.
(,
3t Q
Apart from the assumption that you made, not 22 having actually read the procedures,'you did not know for 93 a fact that the procedures in fact did require that HPI
~
[~).
^
gg be left on until p'ressure came back above 1600 p.s.i.?
l 3;p MR. SELTZER:
Objection.
I wouldn't object 9
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y
--e qmm y
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4 1
Karrasch 590 7-v 2
if you say, "You didn't know whether the proceduren f
3 specified," but I think if you leave it where 4
you have, there is no foundation that that is 5
what the procedure provides.
'6,
MR. FISKE:
The foundation is the procedure 7
itself.
8 MR. SELTZER:
I object because you include 9
a statement that is contrary to fact, i
10 THE WITNESS:
Would you read back the 11 question?
12 (Question read.)
13 MR. FIS KE :
The foundation-for my question 14 is the procedure which GPU was fined for not 15 following on the day of the accident.
16 (Record read.)
17 A
I did not know for a fact what the ' requirements 18 in the procedure were.
I 19 MR. FISKE:
That is all I have.
20 FURTHER EXAMINATION (f
_21 BY MR. SELTZER:
22' Q
At the-time you reached the conclusion which ZI you did about operator interruption of high pressure C\\
injection and what you thought the procedures provided, 21-25 is it correct that you had either forgotten about.or O
i 1
Karrasch 591
'\\s' 2
were ignorant of the fact that the Davis-Besse operators f
3 had terminated high pressure injection during a transient.
4 at their B & W plant prior to pressure being restored
(: '
5 to the high pressure injection actuation set point?
'6 MR. FISKE:
For how long?
7 MR. SELTZER:
They did it. That is my point.
8 (Record read.)
9 A
Yes, it is correct.
2 10 MR. SELTZER:
I have no further questions.
11 FURTHER EXAMINATION 12 BY MR. FISKE:
(%)
13 Q
Is it also correct that you were not aware j
14 at that time that the operators at Davis-Besse within 4
15 20 minutes had correctly diagnosed the situation and 16 restored high pressure injection until pressure came back II up above the set point?
18 A
That is also correct.
19 MR. SELTZER:
Thank you, Mr. Karrasch.
20 (T ime noted:
4:25 o' clock p.m.)
h
^
21 BRUCE ADOLPH KARRASCH 33 Subscribed and sworn to before 23 me this day of 1981.
y-
.j g
.25
592 I
f"N 2
CERTIFICATE 3
STATE OF NEW YORK
)) ss.:
4 COUNTY OF NEW YORK )
5 I,
JOSEPH R.
DANYO, a Notary Public 6
of the State of New York, do hereby certify 7
that the continued deposition of BRUCE ADOLPH 8
KARRASCH was taken before me on September 30, 9
1981, consisting of pages 494 thr o ug h.5 91.
t 0
I further certify that the wit, ness had I
11 been previously duly sworn and that the O
lo within transcript is a true record of said g
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 IO of any of the counsel.
19 IN WITNESS WHEREOF, I have hereunto set my hand this /
day of October, 1981.
20
~
- { f>
JOSEPH R.
DANYO 23 O) l
\\v 24 25 l
l
i 1
593 v
IN D EX WITNESS PAGE (s
Bruce Adolph Karrasch (resumed)
By Mr. Seltzer 496 By Mr. Fiske 553 By Mr. Seltzer 574 By Mr. Fiske 586 By Mr. Seltzer 590 By Mr. Fiske 591 O
E XH I B IT S PLAINTIFFS'
^
FOR IDENTIFICATION GPU 381 Document headed " Implications of TMI-2 Incident" 496 GPU 382 Memorandum dated June 13, 1979, from B.
A.
Karrasch to F.
R.
Fahland, subject: Responding to TMI-2 Concerns - Verification of As-Built Data.and liigh Point Venting 515 GPU 383 Sketch prepared by Mr. Seltzer 517 i
GPU 384 Document headed " Implications of TMI-2 Incident," with three-page attachment headed O
"The TMI-2 Message" 525 i
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-, ~
U 594 y~)
~
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INDEX OF EXHTBITS (continued)
PLAINTIFFS' f
FOR IDENTIFICATION PAGE GPU 385 Memorandum dated June 21, I,
1979, from B.
A.
Karrasch to R.
J.
Fortune, subject:
Proposed TMI-2 Impact Study 528 GPU 386 Memorandum dated June 6,
- 1979, from C.
W.
Litchford to Distribution, subject:
TMI-2 Related Work Tasks 529 GPU 387 Memorandum dated November 9, 1979, from B.
A.
Karrasch to C.
W.
Pryor, subject:
Impact of TMI-2 Related Changes on Hardware Design Evaluation 532
[/
GPU 388 Preliminary Report of Safety N,
Concerns, PSC 35-79, dated August 10, 1979,_from R.
J.
~
Brockman 535 GPU 389 October Activities Report, dated October 31, 1978, from B.
A.
Karrasch to E.
A.
Womack 579 GPU 390 August Activities Report,-
dated September 1,
- 1978, from B.
A.
Karrasch to E.
A.
Womack 586
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