ML20073T222
| ML20073T222 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 12/07/1982 |
| From: | Frederick E GENERAL PUBLIC UTILITIES CORP. |
| To: | |
| References | |
| TASK-*, TASK-01, TASK-02, TASK-03, TASK-05, TASK-06, TASK-07, TASK-1, TASK-10, TASK-2, TASK-3, TASK-5, TASK-6, TASK-7, TASK-GB NUDOCS 8306290502 | |
| Download: ML20073T222 (181) | |
Text
^
1
~
jbp t1 Frederick-direct 3378 7~'s 1
UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK
('
2
x 3
GENERAL PUBLIC UTILITIES CORPORATION, 4
JERSEY CENTRAL POWER & LIGHT COMPANY, METROPOLITAN EDISON COMPANY and 5
PENNSYLVANIA ELECTRIC COMPANY, 6
Plaintiffs, 80 Civil 1683 (RO) 7 v.
C THE BABCOCK & WILCOX COMPANY and J.
RAY McDERMOTT & CO.,
INC.,
9 Defendants.
10
______________________________________x 11 December 7, 1982 12 10:15 e.m.
13 N-Before:
14 HON. RICHARD OWEN, 15 District Judge.
16 17 l?
(Open court)
I 19 EDWARD RUSSELL FREDER I C K resumed.
20 DIRECT EXAMINATION (Cont'd) 21 BY MR. SELTZER:
i 22 THE COURT:
Good morning.
j i
l 23 Q.
Mr. Frederick, you testified that during the
!l
2h 24 first 10 or-15 minutes of the transient about four or five it
~ /
25' hundred enunciator alarms in the windows above the panels
' 1 07 B306290502 82 289 s uTHERN oisTaicT REponTEns.u.s. coutruousE I
PDR ADOCK PDR FoLEY SQUARE. NEW YPRK. N.Y. - 79i.1020 T
i._ -.
_s 7
jbp t1 Frederick-direct 3379 1
appeared.
2 On the morning of the accident, what, if I
x 3
anything, did you do regarding all those alarm indications?
t 4
A.
Well, after they had given us the information I j
5 discussed yesterday, groups of alarms came in for the 6
turbine, for the condensate and for the various primary 7
systems.
Once that group of information was acquired, they 8
weren't doing much for us but they could be analyzed 9
individually.
S/ we decided not to acknowledge -- not to 10 push the acknowledge button.
11 Q.
What difference does that make, pushing the 12 acknowledge button?
How does that ef fect what you see or
/%
(
13 hear in the control room?
14 A.
Well, if an alarm comes in, it sounds the 15 enunciator alarm, electronic beeper, and then you look up 16 and you see the card flashing and you push the acknowledge 17 button and it turns off the beeper and it makes the alarm 18 card stop flashing.
19 When that alarm clears, it sounds the beeper 20 again, it begins to flash again and when you push the 21 acknowledge button, it goes out, that light, if that 22 condition is fixed, cleared.
23 So in this case where we had all those alarms e
{ ![]
24 coming in and going out --
)
25 Q.
Let me clarify something.
sm, SOUTHERN DISTRICT REPORTERS.U.S. COURTHOUSE FOLEY SQUARE. NEW YORK. N.Y. - 191 1020 i
.. ~.
s.
m_.
^
e e
jbp t1 Frederick-direct 3380 If an alarm condition has appeared in the plant, l
l 1
1~~s 2
youve said the card flashes and the beeper comes on.
If 3
you push the acknowledge button, what happens to the status 4
of the card?
i 5
A.
When the alarm is coming in?
6 Q.
Yes.
1 7
A.
When you push the button, the card remains 8
lighted solid, like you see in there.
Then when it is 9
clearing, it flashes dimly, there are two voltages which 10 could be applied to i t and it flashes dimly when it is 11 cleared.
12 Q.
What do you mean when it is cleared?
13 A.
Whatever condition is and the condition is --
14 THE COURT:
Being remedied.
15 THE WITNESS:
Is being remedied.
That's a good 16 word.
If i t happens again, you push the button and the 17 light goes out.
With all the alarms coming in and going 18 out, we decided not to push the acknowledge button because 19 it would erase some of the acknowledge conditions and we 20 decided to see what it would be.
Later on we thought when 21 it settled down, we could go through the individual alarm 22 cards and see if there was any more information we could i
23 draw from the alarms.
l
)
24 Q.
To resume with the point in the transient where
/
25 I believe we were yesterday, reactor coolant system SOUTHERN DISTRICT REPORTERS.U.S. COURTHOUSE FOLEY SQUARE. NEW YORK. N.Y. - 191.1020 h
9 v-e-T
'a-me'%
,--ew-4
,,_,7_.,
jbp t1 Frederick-direct 3381 1
pressure and pressurizer level were falling.
-,\\.
i s/
2 At that point, did you observe what was m
3 happening to the temperature in the reactor coolant system?
4 A.
It was trending down with the other -- pressure 5
level and temperature were trending down.
6 Q.
Did you take note of the specific level to which 7
or at which reactor coolant system temperature was at any 8
point when pressure and pressurizer level were coming down?
9 A.
Not that I recall, no.
I was just looking at 10 the trending information on the graph.
11 Q.
Did there come a time early in the transient 12 when you checked the temperature and pressure on the
[
13 reactor coolant drain tank?
14 A.
I really don't recall that, going back there now, 15 but I had testified much earlier just after the accident 16 that I did.
So I don't really remember it now though.
17 Q.
Do you mean in one of the times that you were 18 being questioned af ter the accident you gave testimony 19 about-that?
20 A.
Yes.
Soon after the ace' dent we were i
21 interviewed by a lot of dif ferent groups and back in there 22 somewhere I said I,went back there.
I just don't remember 23 it now.
"7
(
24 Q.
Were you interviewed by personnel from the NRC's 25 I& E division in April 19797 SOUTHERN DISTRICT REPORTERS. U.S. COURTHOUSE FoLEY SQUARE. NEW YORK. N.Y. - 7911020 i
~...
jbp tl Frederick-direct 3382 1
A.
Yes.
They interviewed us for several weeks in,
(s 2
I think, April of 79.
3 MR. SELTZER:
Your Honor, I would like to read 4
from Mr. Frederick's I & E testimony, his recorded 5
recollection under Rule of Evidence 803 sub.5.
6 MR. FISKE:
We have no objection, your Honor.
7 MR. SELTZ ER:
This is at page 64.
8 Q.
Is Mr. Hunter somebody who was interviewing you 9
from I & E?
10 A.
His name was Darwin Hunter, one of the 11 investigators.
12 Q.
Mr. Hunter said to you:
13 "Okay.
Let's spend a couple of minutes on a
~J 14 reactor coolant drain tank.
I know that we have been here 15 awhile but I am going to try to get this.
16 Let me get talk about the reactor coolant drain 17 tank.
The initial conversation we talked about the reactor 18 coolant drain tank, we touched on the reactor drain tank 19 and the fact that you went around behind the panel and 20 noted that pressure was zero, high temperature, that the 21 pressure was down, low pressure.
You turned the reactor 22 coolant pump off.
And you turned the coolant pump off.
23 "Mr.
Frederick:
The level was down, the We have three 24 pressure was up and the temperature was up.
\\-
25 gauges, level, temperature and pressure."
(
SOUTHERN DISTRICT REPORTERS.U.S. COURTHOUSE i
FOt.EY SQUARE. NEW YORK. N.Y. - 791 1020 l
l. - -.
33
jbp t1 Frederick-dirset 3383 1
What did you understand, conceptually, from your 1
2 prior training and experience could cause reactor ' coolant
)
3-drain tank temperature and pressure to be elevated as you 4
described in this prior testimony?
5 A.
Well, the condition, a specific condition would 6
be a blast from one of the relief valves that would cause 7
an exhaust of a lot of steam from the pressurizer and it i
8 would go into the drain tank and heat it up.
Tha t steam 9
would hit the water and the drain tank heated up and would 10 raise the pressure.
11 Then it would exhaust for awhile and it would i
12 shut.
Pressure and temperature would remain high for 13 awhile and then later on it would go back to normal.
14 Q.
Where was the panel on which reactor coolant i
15 drain tank information was shown?
16 A.
Panel 8-A is located around the left-hand corner 17 of the rear panels shown here in the control room.
It 18 faces the outer wall of the control room.
19 Q.
Did you have any understanding why the reactor 20 coolant drain tank information was on a back panel?
21 A.
Well, we had a number of rear facing panels like 22 that for systems that we don't use very of ten.
And since 23 this'was not a panel that we used very often, that's why I
""1 24 would classify it as a back panel.
J
,)
25 Q.
Could you just very succinctly indicate what l
SOUTHERN DISTRICT REPORTERS. U.S. COURTHOUSE l
FOLEY SQUARE. NEW YORK. N1 - 791-1020 l
.~.
.-3, m.
... + ~ -
,--%.n.,,
w-I
.V..
,-..--+-,-a
,.n
,..c...._.
.,n--,-..
jbp tl Frederick-direct 3384 1
other kinds of information is displayed on back panels?
e 2
A.
There are -- around this side of the control 3
room, around the right-hand side of the panel --
4 MR. FISKE:
I will object to this as irrelevant, 5
where the panels are.
He went and looked at it.
6 THE COURT:
I sustain that objection.
7 Q.
Mr. Frederick, you indicated that it was your 8
understanding that a blast of steam from a relief valve 9
could elevate temperature and pressure.
10 What did you mean by "a blast"?
11 A.
Well, you had very hot steam and high pressure 12 and the valve springs open and the steam rushes through the 13 steam pipe to the drain tank and the effect is to rush all 14 that energy into the drain tank and I just used the term 15 blast.
It opens, blasts the steam out and reshuts and you 16 get an excursion in the drain tank.
17 Q.
On the day of the accident, would it have helped 18 you if the drain tank information had been displayed on a 19 front panel?
20 MR. FISKE:
I will object to that, your Honor.
21 THE COURT:
Yes.
I will sustain that.
22 I don't gather that anybody contends that they 23 didn't look at it or didn't know about it, correct?
You 24 don't contend that?
25 MR. SELTZER:
No.
This wi* ness says SOUTHERN DISTRICT REPORTERS. U.S. COURTHOUSE FoLEY SQUARE. NEW YORK. N.Y. - 791 1020
,n..
.n.
u
-+~-'"~J es 1pr zu
,p.,,.,_,
n g
J e
---a jbp tl Frederick-direct 3385 1
THE COURT:
Then I'll sustain that objection.
t 2
Q.
On March 28, 1979, was elevated temperature and 3
pressure on the reactor coolant drain tank expected or 4
unexpected?
5 MR. FISKE:
Your Honor, I will object to this 6
unless the witness describes how high the temperature was 7
when he saw it, how high the temperature and pressure were.
8 THE COURT:
Well, it seems to me, in addition to 9
that we have got to have some prior act such as pressure 10 reaching a point where a valve would open to make that 11 expected and you haven' t laid that foundation at all.
12 So I will sustain that objection.
1 13 Q.
Mr. Frederick, you said that you heard Mr. Zewe, J
14 the shift supervisor, announce that there had been a 15 reactor trip.
You say that af ter he announced that you 16 checked panel indications.
17 From your looking at panel indications, were you 18 able to tell what had triggered the reactor trip?
19 A.
Yes.
I knew that the reactor trip was due to a 20 turbine trip which resulte6.in high pressure in the reactor 21 coolant system and high pressure reactor trip.
22 Q.
At what pressure does a high pressure reactor 23 trip get actuated?
"~
24 A.
2255 pounds.
So wha t I understood had happened, s_,I 25 the turbine trip rejected all that energy back into the 1
SOUTHERN DISTRICT REPORTERS U.S. COURTHOUSE FoLEY $QUARE. NEW YORK. N.Y. - 791 1020
m4 -_
u a
jbp tl Frederick-direct 3386 reactor coolant system and caused the high pressure
' 2 condition which caused the PORV to open at 2255, trip at i
i 3
2355 and then when the pressure started coming back down 4
again, the PORV reset at 2205 and then we go into the 5
reactor trip immediate actions.
6 (Continued on next page) 7 8
9 10 11 12 13 1
14 15 16 17 18 19 20 21 22 23 1
24 25 SOUTHERN DISTRICT REPORTERS.U.S. COURTHOUSE FOLEY SQUARE. NEW YORK. N.Y. - 791 1020
+ -.,
,~,,,_.,,,_.m._-,.-.~._,,_,,m_~
,__._,....-__-._.,.-,y-y,,%-
,w..~,,.,._,___
lh t2 Frederick - direct 3387 (A) 1 Q.
How soon after the start of the transient did i
/
2 you understand the pressure moved up to the PORV set point, 3
up to the reactor trip set point and then down through the 4
PORV closing set po in t, as you just described it?
5 A.
That happened in only a few seconds.
From Ehe 6
time that I had moved from my original position to panel 6 7
and was returning to panel 4 to look at the ICS when Mr.
8 Zewe announced the reactor trip, and then I verified the 9
reactor trip, all that had already happened.
10 Q.
With that as foundation, knowing that there had 11 been a high pressure reactor trip and that the plant had 12 moved through the open set point and the close set po int
\\_-
13 for the PORV and had, as you described it, ej ected a blast 14 of steam --
15 THE COURT:
Mr. Seltzer, don't sum up.
Just put 16 the next question.
G,ive the background.
17 What did you expect to find in the way of 18 elevated temperature?
All right.
Let's keep moving 19 forward, please.
What did you expect to find, given that?
20 THE WITNESS:
I expected to see the pressure and 21 temperature elevated in the drain tank due to that 22 excursion from the --
23 THE COURT:
And how much?
w?
24 THE WITNESS:
I just knew it would be well above 25 normal.
Again, I was just looking for that as a trend SOUTHERN DISTRICT REPORTERS. U.S. COURTHOUSE FOLEY SQUARE. NEW YORK. N.Y. - 79t 1020 X L :~~ -.
..-"L~~T~~~,_~~~~~~-
. ;~
,: ^
lh t2 Frederick - direct 3388 1
information.
2 THE COURT:
You had no specific figures in 3
expectation, is that what you are telling me?
4 THE WITNESS:
Tha t's right.
There is no way to 5
anticipate what those numbers might be.
6 THE COURT:
Because the PORV has only been open 7
for, what, maybe 5 or 10 seconds?
8 THE WITNESS:
Not very long.
I don't know how 9
many seconds.
10 Q.
What if any expectation did you have of what 11 level pressure would be in the reactor coolant drain tank?
I 12 A.
Just that it would be well above normal.
13 0
You testified yesterday that' in scanning the 14 panel indications shortly after the start of the transient 15 what you observed was normal following a reactor trip and 16 turbine trip.
17 "Let me ask you now, when you got back to panel 4, 18 do you know what the status of the indicator light for the j
19 pilot operated relief valve was?
20 A.
It was off.
21 THE COURT:
Do you remember seeing it lit?
22 THE WITNESS:
It was not lit.
23 THE COURT:
No.
Do you remember at any time
{ ')}
24 seeing it lit?
L 25 THE WITNESS:
No.
The --
SOUTHERN DISTRICT REPORTERS. U.S. COURTHOUSE FOLEY SQUARE. NEW YORK. N.Y. - 191 1070
~
~ ~
. J.:
, ^ :: ~
~
^ ^ ~ ~
- X~ ^
7~~L :.
7 '~ : '
4-Ih t2 Frederick - direct 3389 tg
(
l THE COURT:
The answer is no?
s 2
THE WITNESS:
No.
I had my back to the panel.
3 Q.
You indicated at what point in time the PORV 4
would have lifted.
Where were you at that po in t in time?
5 A.
I was over here between panel 5 and 6 at the 6
turbine control.
I was verifying the turbine trip.
7 Q.
When you got back to the panel 4 position and 8
the PORV light was off, what if any understanding did you 9
have then about whether the PORV light being off would be a 10 normal or an abnormal indication?
11 A.
That would be a normal indication because we 12 have already had the high pressure excursion in the reactor
\\s_/'
13 coolant system and we were into the post reactor trip where 14 I am going to have to take manual control of the makeup 15 system now.
So we are a few seconds into the transient, 4
16 the pressure is down below that and the valve should be 17 shut.
18 Q.
The pressure is down below what?
19 A.
The pressure has gone below the reset point.
20 Q.
For --
21 A.
For the PORV, for the relief valve.
22 Q.
You testified yesterday that one of the first 23 actions that you performed af ter you got back into the area h
24 on the lef thand side of the panel was that you started a d[
25 second makeup pump.
On that morning did anything happen as SOUTHERN DISTRICT REPORTERS, U.$. COURTHOUSE FOLEY SQUARE NEW YORK, N.Y. - 191 1020
Ih t2 Frederick - direct 3390-1
-a result of your starting 'the second makeup pump and 2
putting whatever additional flow it does into the reactor 3
coolant system?
4 A.
After starting the second makeup pump and 5
increasing the makeup flow I soon saw that the pressurizer 6
level turned and began coming back up.
7 Q.
Did there come a point in time early in t.he 8
transient when high pressure injection and other emergency 9
safety features automatically actuated?
10 A.
Yes.
11 Q.
When was that?
12 A.
I don' t have a time in mind, but it was after 13 this time when the pressurizer level was beginning to rise 14 back up when I had control of pressurizer level.
15 Q.
What systems start on an emergency safety 16 features actuation?
17 A.
The systems that are directly affected by the 18 high pressure signal are the makeup system and the decay 19 heat removal system.
These pumps of the makeup. system 20 shif t automatically so the A and C pump are running and the 21 B pump is off whereas on manual control I had the A and the l
22 B pumps running.
Then these four injection valves, 16-A, B,
23 C and D, opened to their full injection set points.
- - i 24 The decay heat removal. pumps that are controlled 25 from over here start, but they have no function at this SOUTHERN DISTRICT REPORTERS. U.S. COURTHOUSE FOLEY $QUARE. NEW YORK. N.Y. - 7911020
.-...-.,~._.#
m,.,...
.,u.+.___.-...
-,_ _ _~ _,.,.._,
_.-s,...,_.
Ih t2 Frederick - direct 3391 I
time uatil the pressure is reduced around 700 pounds.
Then
(/)
x_
2 they would begin injecting water.
They are the low 3
pressure injection pumps.
4 All the support systems that supply cooling 5
water for the makeup system and for the decay heat removal 6
system are also automatically started and the valves and 7
the coolers for the. electrical lineup necessary to support 8
that is indicated back here on panel 13, the white lights.
9 Also the backup electrical power source, these diesel 10 generators, would start to supply standby electrical power 11 in case of some problem with'the normal electrical sources 12 here on the front panel.
\\s_/
13 Q.
Is there any independent indication of when the 14 diesels have started?
15 A.
Yes.
For one thing there is a large bell, like 16 a fire alarm bell, on the top of the diesel, each one.
17 There is also a blue and an amber running light for each 18 diesel that comes on.
i 19 Q.
Is that a soft bell?
20 A.
No, it is a large, like a fire alarm bell.
21 Q.
Did you take any steps to verify whether there 22 had been emergency safety features actuation?
23 A.
Yes.
After I realized that we had had the l
.- 3
! '~ \\
24 automatic initiation, I began to check each of the 25 components I just outlined and their subsystem to make sure
$OUTHERN Di$TRICT REPORTERS. U.S. COURTHOUSE I
FOLEY SQUARE, NEW YORK. N.Y. - 791 1020
.,u m._
, + =
,-m-g-,
,y_.-
l p
l L
l i
lh t2 Frederick - direct 3392 l O 1
that everything moved to its automatic initiation status, V
2 both on this panel 3, panel 8, and then the individual l
3 status on panel 13.
Each component has a white light that 4
indicates that it is in its ES status.
You have to wait 5
for all those components to move to their white light
,6 status.
7 Q.
Once the diesels have been actuated by an 8
emergency safety features signal, how are they shut off?
9 A.
They can't be stopped from the control room as 10 long as the ES signal is still in.
You have to send an 11
. operator to the diesel, which is a separate building from 12 the control building, and they would have to shut it down 13 manually.
14 Q.
Is that some times called a fuel rack?
13 A.
Well, when you get to the diesel there is a 16 large red button that controls the fuel feed to the diesel 17 generators, and when you disengage or push that button in, 18 it disengages the fuel supply from the diesel and it shuts 19 down.
20 Q.
If the diesels are shut off at the fuel rack, 21 what if any effect does that have on the bell alarm that 22 you said goes of f on the diesel panel when there is an 23 automatic safety features actuation?
(
24 A.
The bell sounds because you have applied a 25 signal to the diesel to start.
It will tell you, one, that SOUTHERN DISTRICT REPORTERS. U.S. COURTHOUSE FOLEY SQUARE. NEW YORK. N.Y. - 191 1020
~. _ _
+
Ih t2 Frederick - direct 3393 m
)
I the diesel is attempting to start, that it has started or 2
that it has failed to start, whatever -- all these alarms 3
are separate enunciators.
Just like these enunciator 4
alarms will give you a beeper, these alarms will give you a 5
bell.
Anything that affects the diesel generator will 6
cause the bell to ring.
7 If you push the start button or give it an 8
automatic signal to start and it doesn't go, then you will 9
get the alarm to tell you why it doesn' t start.
If it does 10 start, then you will get the alarm that says diesel running.
11 Q.
You described that when the emergency safety
/N, 12 features signal came in the A and C pumps started or the A 13 and C pumps were functioning instead of the A and B pumps 14 which you had on manual.
15 A.
I am referring to the makeup pumps, the high 16 pressure injection pumps.
17 Q.
Does the source of water for the HPI mode differ 18 from the source of water for the makeup mode?
19 A.
Yes.
The source of water I was using was the 20 makeup tank, the tank that's connected to the suction pumps i
21 in the auxiliary building.
When HPI is fully initiated, 22 then it takes -- suction is shi f ted to the borated water 23 storage tank which is a large tank outside on the grounds (V
24 of the site there.
It is outside the building.
25 Q.
When you got the indier tions on the panel that SOUTHERN DISTRICT REPORTE's, U.S. COURTHOUSE FOLEY SQUARE. NEW YORK. N.Y. - 791.1020 i
i lh t2 Frederick - direct 3394 1
high pressure injection had automatically actuated, what if 2
any thoughts did you have about what had caused that 3
automatic initiation of HPI?
4 A.
-I saw the ES actuation or I knew that the ES 5
actuation occurred, and I figured it was due to low 6
pressure, the 1600 or 1640 pound low pressure signal on the 7
RCS.
8 Q.
What if any prior experience did you have at the 1
9 plant or the simulator with initiations of high pressure 10 injection, automatic initiations?
11 A.
Well, I had seen it before and I knew that there 12 had been several ES actuations, so I knew that it could
{
13 happen.
I knew that it was a likelihood.
]
14 Q.
Did you expect an automatic actuation of high 15 pressure injection on every reactor trip?
i 16 A.
I wouldn't expect it on after trip because the i
17 reaction that the operator takes -- the reactor trip
+
18 procedure is actually high pressure injection.
It is just i
19 being done manually.
If you do it quick enough and if you 20 do it with enough flow, you will avoid the automatic 21 initiation because you are quick.
l 22 O.
Let me ask you, if it is not expected on every 23 reactor trip, what did you think explained the automatic
/
l 24 actuation of HPI on this trip?
25 THE COURT:
I thought he told us.
He said it SOUTHERN DISTRICT REPORTERS U.S. COURTHOUSE FOLEY SQUARE. NEW YORK. N.Y. - 791 1020 l
~~ ~
~
~~
~~
~~
~ ~ ~
~ ~ ~
~~
11 Z Z ~ ~
e w ~ ~....
Ih t2 Frederick - direct 3395 1
went below 1650, right?
That's what you said you Delieved --
2 THE WITNESS:
That was the actuation signal, yes.
3 THE COURT:
That's what you believed.
4 Q.
What did you think had led the plant on this i
5-excursion to drop pressure to the 1640 actuation point?
6 A.
Well, the reason we got it on this trip was 7
because I was somewhat delayed in returning to the makeup 8
system to begin the manual initiation because I was over on 9
panel 6 to begin with, so, a few second delay, I didn' t get 10 it in as quickly as I might have if I did it right away.
11 Q.
What if any effect does the level of load at 12 which the plant is operating have on the amount of cooldown?
6 13 A.
Well, in relation to how it affects the 14 saturation, if you start at a very high power level in a 15 transient like this, you are likely~to have a very severe 16 cooldown.
If you are at a lower level, the cooldown would i
17 be less severe because it is just a smaller transient.
The 18 other trips that we had had that initiated ES were all from 19 lower power levels, 30's and -- 20, 30, 40 percent, in that a
20 range.
This was from nearly a hundred percent, and I 21 expected it to be a bigger transient.
22 Q.
Before March 28 had you been trained to 'use high injection actuation as a diagdostic tool to figure 23 pressure 24
'out what casualty occurrad?
25 A.
No.
You really can't use it to diagnose what SOUTHERN D157RICT REPORTERS. U.S. COURTHOUSE FOLEY SQUARE, NEW YORK, N.Y, - 191 1020
~
u________
0 w:
~
lh t2 Frederick - direct 3396
['
1 the problem is.
You know why i.t started, it is the k
2 automatic initiation signal, but it doesn' t help you 3
diagnose what the initiating problem was or identify the 4
name of the transient that you are going through.
5 Diagnostically it really doesn't help you very much.
6 Q.
Had you had any training or experience before 7
March 28 which informed you how much of a temperature drop 8
would be needed in order to decrease reactor coolant system 9
pressure suf ficiently to actuate high pressure injection?
10 A.
I don' t think I had a specific range of 11 temperatures in mind.
I expected that it could occur on 12 any large transient like this.
It just depended on, not
\\s,f 13 how quickly the pressure dropped, but just the fact that it 14 was going to because you had a trip.
It is all a matter of 15 quick recponse in a manual response to the reactor trip.
16 Q.
You said that you observed that pressurizer 17 level had started to recover.
What if any thoughts did you 18 have as you watched pressurizer level beginning to recover?
19 A.
Once I had control and was raising pressurizer 20 level, then I knew that the reactor trip transient was just 21 about over, we could start wrapping up the excess makeup 22 that I had applied and that we could return to normal 23 makeup lineup in a few minutes af ter I got the level a 24 little higher.
b 25 Q.
Did you have any understanding why pr'essurizer soumEnn oisnici nEronnas,u.s. counmousE q
FoLEY sQuAnE. NEW YOnK. N.Y. - 191.1020 4
n:
~
-lh t2 Frederick - direct 3397 1
level was increasing?
v 2
A.
Because I was -- this is after the automatic 3
initiation or before?
4 Q.
After.
5 A.
It was a combination of my manual makeup and the 6
automatic initiation dumping in a thousand to 1200 gallons 7
per minute. you are going to get a large increase in the 8
volume in the system.
So that's indicated by the l
9 pressurizer level going up.
10 Q.
Did there come a time when the shift foreman, 11 Mr. Scheimann, entered the control room?
12 A.
Yes.
He had been in the turbine building and he 13 came into the control room.
14 Q.
Do you know whether Fred Scheimann was back at 15 the control room by the tine the automatic safety features 15 actuation came in?
17 A.
He was in right around that time.
That's when 18 he arrived.
19 Q.
What if anything did you observe Mr. Scheimann i
20 doing shortly af ter he arrived?
21 A.
Initially he was looking through procedures and 22 then he came to the corner between panel 3 and 4 where I 23 was, I was at the makeup station, and he began to observe 7
24 the primary parameters while I manipulated the equipment on hp v
25 panel 3.
SOUTHERN DISTRICT REPORTERS. U.S. COURTHOUSE FOLEY SQUAhE. NEW YORK. N.Y. - 791-1020
.~
g
-Wer's v
.,--or,,,
7
Ih t2 Frederick - direct 3398
\\
l Q.
At about the time that the emergency safety
[G 2
features actuated, what was Craig Faust doing?
3 A.-
He was still over at the secondary station 4
between panels 4 and 5.
He was monitoring the --
5 establishing steam generator level at the post trip set 6
points.
7 Q.
What is the level at which the steam generator 8
normally maintains water when the plant is generating power?
9 A.
It is in the operating range 80 or 100 percent, 10 something like that.
About 250 to 300 inches.
11 Q.
What is the level which you understood it was 12 appropriate to adjust steam generator water level once i
,_,)
13 there has been a trip of the turbine?
14 A.
Thirty inches.
15 Q.
Based on your experience before March 28 how 16 long did you expect it would take for Mr. Faust to bring 17 steam generator water level down from its pretrip level to 18 the 30-inch level?
19 A.
A couple of minutes, two or three minutes.
I 20 Q.
Did you know from the start of this transient 21 that main feedwater was unavailable?
22 A.
No, I did not.
l 23 Q.
Based on your prior training and experience, if 24 main feedwater were unavailable, was there a particular
('~'s 25 level in the steam generators where cuxiliary feedwater or
$O0THERN DISTRICT REPORTERS, U.S. COURTHOUSE FOLEY SQUARE. NEW YORK. N.Y. - 791-1020 a
g.J,
,. _, Z.. J ~~'
~
. :1Z.
fl..
Ih t2 Frederick - direct 3399 O
s i
1 emergency feedwater would be actuated?
I 2
A.
At the same level.
It would try to maintain the 3
same post trip condition, 30 inches.
4 Q.
How many minutes after the start of a transient 5
such as the one you had would emergency feedwater or 6
auxiliary feedwater, as it is alternately called, come on?
7 MR. FISKE:
You mean assuming there was no main 8
9 MR. SELTZER:
Exactly.
10 A.
It would come on the same way the main feedwater 11 would have come on, a couple of minutes into the transient.
12 When the level boiled down to 30 inches, it would start to
(
maintain the 30-inch level, to at or around 30 inches, just N,/
13 s
14 before you got there.
15 Q.
You say that would be about 2 minutes into the 16 transient.
17 A.
Yes.
18 Q.
At 2 minutes into the transient on March 28, 19 1979 had the pressure already risen to the actuation point l
l 20 for the pilot operated relief valve?
l 21 A.
Yes, the pilot operated relief valve had already 22 cycled within the first few seconds of the transient.
23 THE COURT:
Can I stop you a moment?
I have
/
7 24 been following with this GPU chronology and I just was
- (Sy V
25 curious because there they indicate you get to the
~,
l SOUTHERN DISTRICT REPORTERS. U.S. COURTHOUSE FOLEY SQUARE, NEW YORK. N.Y. - 791-1020
~. -
.,. __ _ j
~
'lh t2 Frederick - direct 3400 1
emergency feedwater actuation at 35 seconds.
He just said 2
it was 2 minutes.
I wonder whether there was some 3
discrepancy there.
4 THE WITNESS:
May I explain?
5 THE COURT:
Sure.
6 THE WITNESS:
The actuation of the emergency l
7 feedwater system is the actual turning on of the pumps.
8 Steam driven and motor driven pumps get a signal to start 9
as soon as the main feed pump tripped, which was I guess 35 10 seconds.
When the pumps come on they go into a recirculation 11 mode until the level of the control valve on the discharge 12 of the pumps gets a signal to maintain steam generator
~
x,j 13 level.
14 So the pumps actually started but were not 15 discharging to the steam generators until the level 16 ap,proached down near 30 inches.
That's when the automatic 17 valve would have opened and began to maintain,the level in 18 the steam generator.
19 THE COURT:
Tha t's wha t I read here happened at 20 35 seconds.," Steam generator B level reached the 21 integrated control system set point of 30 inches at which 22 the emergency feedwater valve opens.
Feedwater was r.ot 23 admitted into the steam generator B beca'use emergency
/
24
-feedwater block valve was shut.
EF-V 128 is normally open."
G 25 THE WITNESS:
That should be 12-C.
SOUTHERN DISTRICT RETORTERS. U.S. COURTHOUSE FOLEY SQUARE, NEW YORK. N.Y, - 191 1020
1 lh t2
-Frederick - direct 3401 1
THE COURT:
12-B, excuse me, you are right.
['
\\,s 2
THE WITNESS:
The boildown of the steam 3
generators was extremely fast in this condition.
Tha t' s 4
not what I expect.
He is asking me --
5 THE COURT:
You said it was 2 minutes and I read 6
here 35 seconds.
Are you just a little bit off?
Is it 35 7
seconds or is it 2 minutes?
8 THE WITNESS:
No.
What we are seeing here is 9
because it was a hundred percent trip, it happened much 10 faster than I thought.
11 THE COURT:
So it is 35 seconds?
12 THE WITNESS:
It must be.
They probably got t'
t 4
13 that off --
14 THE COURT:
Off the computer?
15 THE WITNESS:
Off the B & W reactimeter i
16 downstairs.
17 THE COURT:
Go ahead, Mr. Seltzer.
18 BY MR. SELTZER:
19 Q.
Based on your understanding of how systems were 20 actuated, did the point at which auxiliary feedwater pumps 21 were actuated have any effect or could it have had any 22 ef fect on whether the pressure rose to the PORV set point?
23 A.
That pressure excursion was independent of the
? ~s j
It was due to the turbine trip.
All 25 these things going on at the auxiliary feedwater happened
'a SOUTHERN DISTRICT REPORTERS.U.S. CCURTHOUSE FOL'IY SQUARE. NEW YORK, N.Y. - 1911020 i
l
. _.1
~
~
- 1 Ih t2 Frederick - direct 3402 1
after the fact that the PORV cycled.
It opened and shut
[
' Q 2
because the turbine stopped demanding steam from the system 3
and rejected all that energy into the RCS, reactor coolant 4
system.
At that point the PORV cycled, the reactor tripped, 5
and then these feedwater things were happening later.
6 Q.
Let me put this question, because I think it 7
ties directly into something that came up yesterday.
8 If the 12 valves which we will come to in a 9
minute had not been shut, if they had been open so that the 10 auxiliary feedwater could come on at the earliest time that i
11 it was called upon to come in and inj ect water into the 12 steam generators, what if any effect would that have had on 13 the primary system, the PORV actuation and reactor trip?
l 14 A.
It wouldn' t have had any ef fect because all 15 those things had already occurred.
As a result of the 16 turbine trip, you get the pressure excursion in the reactor 17 coolant system which actuates the PORV and causes the l
18 reactor trip, and the establishing of steam generator level 19 through main or auxiliary feed is a subsequent action, it 20 happens later on.
21 Q.
So would the ~ PORV have opened or not if the 12 22 valves had not been shut?
i 23 A.
Yes, it would have.
They would have opened and 24 shut.
\\
25 Q.
Would there have been a reactor trip if the 12' SOUTHERN DISTRICT REPORTERS.U.S. COURTHOUSE FOLEY SQUARE. NEW YORK. N.Y. - 7913020 l
=. -.. - -
lh t2 Frederick - direct 3403 1
valves had been open instead of shut?
i 2
A.
Yes, the reactor trip was a direct result of the 3
turbine trip and not af fected by the status of the 4
feedwater systems.
i L
i 5
(Continued on next page.)
5 7
8 9
10 i
11 12 V
13 14 I
I 15 i
16 17 18 19 20 21
~
22 i
23 i
l 24 25 SOUTHERN DISTRICT REPORTERS, U.S. COURTHOUSE FOLEY SQUARE. NEW YORK. N.Y. - 791.1020
_y
- ~, _ - _ _ _, -,....-.._ _ _ _ _ _.. - _ _. _ _, _ _,,,, _. _.. -....
jbp t3 Froderick-direct 3404 1
MR. SELTZER:
Your Honor, you'll note in the GPU
,m
(
)
2 chronology it indicates that at 15 seconds the 3
electromagnetic relief valve should have shut at this time.
4 THE COURT:
I saw that.
It was open for 11 5
seconds and it should have shut at 15 seconds.
6 MR. SELTZER:
That precedes by a discreet amount 7
as to when the emergency feedwater should have come on.
8 THE COURT:
Given what we are now focusing on I 9
wonder how much of this testimony is necessary?
10 MR. SELTZER:
What I was bringing it out for, 11 your Honor, was to clarify something that came up in 12 colloquy.
13 THE COURT:
What I am getting at is your asking s
's--
14 this gentleman, who is there in an emergency situation, to 15 give us times about things and sequences about things from 16 his recollection now three years old at a time when there 17 was obviously a certain amount of emergency in the air and 1R he's not a clock and we, in fact, have the clock.
19 I just wonder how much we need to do this with 20 this witness in terms of establishing times because.he's 21 obviously not the best source of that definitive i'
22 information.
r I
{
No question about it.
In fact, i
l 24 Mr. Frederick has testified to the compression of time, the
' fiq the difficulty of keeping track of time.
l t
i 25 expansion of time,
}U
$0UTHERN DISTRICT REPORTERS.U.S. COURTHOUSE j
FOLEY SQUARE. NEW YORK. N.Y. - 791.1020 4
i
,.__m A
jbp t3 Frederick-direct 3405 1
THE COURT:
I understand.
I observe that to you i
2 in terms of --
3 MR. SELTZER:
The only point of the last few that the questions was to establish sequence and the fact 4
PORV opens and shuts before auxiliary feedwater would have 5
6 even been called upon.
7 THE COURT:
I have gone through this chronology 8
and observed that prior to your asking the question.
9 Because, as I remember, in the Davis-Besse incident we had 10 the PORV open for, what, a matter of perhaps 10 seconds on 11 the flutter -- there was a flutter on the chart and then it 12 came straight down.
13 MR. SELTZER:
The pressure came down.
y M
14 THE COURT:
But the flutter was the PORV opened 15 and then apparently it stuck, but it was only open because 14 of the pressure for, what, 9 or 10 or 12 seconds at 17 Davis-Besse.
18 MR. SELTZER:
I think it would have stayed open 19 for about 10 seconds.
20 THE COURT:
Here was 11.
21 MR. KLINGSBERG:
We wanted to clarify, your 22 Honor, because yesterday at 3265 your Honor seemed to be 23 under the impression that the reason why the PORV opened j
24 was because the emergency feedwater valves were closed and L-.4 25 it happened in a different time sequence.
)
d SOUTHERN DISTRICT REPORTERS.U.S. COURTHOUSE FOLEY SQUARE. NEW YORK. N.Y. - 191 1020 k
a-
.. ~, - +
.,%~
y
-+
+- -,
V jbp t3 Frederick-direct 3406 1
THE COURT:
I see what you are saying.
I
,m 2
understand.
The PORV opened because the water stopped 3
going through the secondary side for whatever reason, 4
mainly because the condensate polisher valve stuck, right?
5 Q.
Mr. Frederick, why don't you state -- was the 6
reactor tripping and the PORV opening related to the 7
feedwater interruption?
8 A.
No.
9 Q.
What is your understanding as the operator at 10 the panel what event caused the PORV opening and closing in 11 the, reactor trip?
12 A.
The event that caused the eventual opening of ey 13 the PORV was independent of the feedwater, loss of
\\'
14 f eedwater, condensate polisher. isolation.
All that 15 happened was that the turbine steam valves closed, stopped 16 demanding steam from the steam generator.
The reactor is 17 still producing 100 percent power, so many BTUs of energy 18 per second and there is no place for it to go.
And this is 19 an instantaneous reaction.
20 THE COURT:
Could I hear the question back?
21 THE WITNESS:
I am trying to say it is 22 completely independent of the feedwater condensate 23 isolation.
l 24 THE COURT:
It was the closing of the condensate f5 l
1 25 polisher valves that turned off the circulation on the t
SOUTHERN DISTRICT REPORTERS.U.S. COURTHOUSE FOLEY SQUARE, NEW YORK. N.Y. - 791.1020
jbp t3 Frederick-dirset 3407 I
secondary side, right?
2 It stopped the circulation on the secondary side?
3 THE WITNESS:
Yes, sir.
4 THE COURT:
Now, that termination on the 5
secondary side meant that there was no water on the 6
secondary side to take the heat out of the water on the i
7 primary side?
8 THE WITNESS:
But there was.
There was nearly 9
300 inches of water in the steam generator, which still 10 could remove heat from the primary side.
11 THE COURT:
But not enough?
12 THE WITNESS:
It could remove it for the next i
13 minute or two.
J j
14 THE COURT:
Well, then, I don't follow you.
I 15 really don't follow you.
16 MR. SELTZER:
Maybe, your Honor, if I could help.
17 THE COURT:
No.
Let the witness tell me, please.
18 All right.
19 What are you saying caused this reactor trip?
20 THE WITNESS:
The reactor tripped following the 21 turbine trip.
22 THE COURT:
Forget the turbine trip.
What 23 caused the reactor trip?
l 24 THE WITNESS:
High pressure in the reactor,
" 7 OJ 25 coolant system.
' U SOUTHERN DISTRICT REPORTERS. U.S. COURTHOUSE FoLEY SQUARE. NEW YORK. N.Y. - 791 1020
(
w a.,,u-
, m m w m-e,-
,,. +,
~.mr.
w-m-
-mn-w..
e.wp.s-~
~
-s
+,..+e.
.,?.m
"~-
~ +
. _ ~ ~
jbp t3 Frcderick-dirset 3408 1
THE COURT:
Why was their pressure in the 2
3 THE WITNESS:
Because of the sudden energy 4
Storage in the reactor coolant system.
5 THE COURT:
And what caused that?
6 THE WITNESS:
Steam valves on the secondary side 7
closing.
8 THE COURT:
Aren't we back to where we were 9
before?
The secondary side wasn't taking the heat out of
.i 10 the primary side?
11 THE WITNESS:
Only for the time it takes for the 12 steam pressure to rise to where the steam safety valves 13 open.
All this happened in like three seconds.
('_s\\
(,)
14 THE COURT:
That's what I understand.
15 THE WITNESS:
But it is not because we 16st 16 feedwater.
There is no water going into the steam 17 generators because there is no steam leaving.
18 THE COURT:
But the system is no longer 19 circulating, tha t 's what the problem is, right?
20 THE WITNESS:
Yes.
f 21 We could easily have caused the same transient 22 just by pushing the turbine trip button and let the 23 feedwater keep running, the same transient would have 24 occurred.
Even if you still had feed pumps and loss of
}
25 condensate and dumping lots of water in the steam generator, o
j SOUTHERN DISTRICT REPORTERS,U.S. COURTHOUSE i
FOLEY SQUARE, NEW YORK. N.Y. - 791-1020 3
jbp t3 Frsdorick-dirset 3409 1
the same transient would have occurred.
)
2 THE COURT:
Because you are not taking the heat V
3 out of the secondary side?
4 THE WITNESS:
Right.
You don't take heat out by 5
putting water in as much as you do by taking the steam out.
6 THE COURT:
Since you are not drawing it out, 7
what you and I are talking about, Mr. Frederick, as I 8
understand it, as the secondary side water is going up 9
through here, the primary side water is going down through 10 there?
11 THE WITNESS:
Yes.
12 THE COURT:
You are saying to me that the i
13 secondary side water going up through here and turning to ^
w\\1 fV 14 steam is not happening at that point because it has no 15 where to go?
16 THE WITNESS:
That's right.
17 What you are doing is accumulating a lot of 18 steam in here.
19 THE COURT:
And it has no where to go and 20 nothing new coming in to continue to take out heat and, 21 therefore, this comes in with the expectation of getting 22 rid of its heat and it doesn't do it.
23 THE WITNESS:
It doesn't do it.
24 THE COURT:
We're on the same wavelength.
It 7
~
p-25 is just a question of how you describe it.
d SOUTHERN DISTRICT REPORTERS.U.S. COURTHOUSE FoLEY SQUARE. NEW YORK, N.Y. - 791-1020
. ~.
-Q-
jbp t3 Frederick-direct 3410 1
THE WITNESS:
All right.
t/
2 THE COURT:
You say that can happen in a matter
\\
3 of just several seconds?
4 THE WITNESS:
Yes.
5 Q.
If you had a. full load turbine trip without a 6
feedwater trip, what was your understanding what that would 7
do to the primary side?
8 A.
The same transient would occur.
due to high pressure.
10 Q.
Did Mr. Faust who was over monitoring the 11 secondary side inforn you what the status was of the 12 secondary side indications?
13 A.
Yes, he did.
He said the steam generator ovens 14 were decreasing and he was unsure that feedwater was 15 replacing -- was now going to start controlling the level.
16 He couldn't tell from the instrumentation whether water was 17 actually being admitted to the steam generators.
l 18 Q.
Did Mr. Faust tell you what, if anything, he was I
19 doing to try to control the secondary side?
20 A.
He had taken manual control of the ICS stations 21 for emergency feedwater and was increasing the manual 22 signal to try to see a response in the steam generator 23 level to either hold it up or make it increase slightly so 24 he could be sure he was inserting water.
He was having
/
e 25 some difficulty with that.
'5 SOUTHERN DISTRICT REPORTERS.U.S. COURTHOUSE -
FOLEY SQUARE. NEW YORK. N.Y. - 791 1020 n
\\
jbp t3 Frsderick-dirset 3411 1
He was beginning to realize that the indication f'%
V),
2 he was looking for wasn't showing up and he couldn't verify I
==
3 that he had flow and so he began to investigate what could 4
cause the loss of flow through the emergency feedwater 5
system.
And a few seconds later he discovered that the 6
block valves for the emergency feed system was shut.
7 Q.
Prior to his -- withdrawn.
8 Was there some way that you knew when he had 9
discovered that the block valves for the emergency 10 feedwater system were shut?
11 A.
Is there some way?
12 Q.
How were you informed, i f you were?
13 A.
He shouted 'that he had found them shut.
3
\\s /
14 Q.
Before he announced that, what was happening to l'S' the pressurizer level which was on the panel in front of 16 you?
17 A.
As I said before, pressurizer level was coming 18 quickly because of the high pressure injection, so I cut it 19 back.
20 We were at about -- we were up in the 300 range, 21 300 inches or more, and I still had a steady increase in 22 pressurizer level so I decided to make a drastic cut in the i
23 HPI flow.
I cut it back/ I think, to about half and l
i 24 initiated some letdown and I saw -- then I gained control
[t"7h l
25 of the pressurizer as it dipped over.
As the increase N.)
souTurnN orsTaict neronTuns.u.s. counruouss j
4 FOLEY sQUAnE. NEW YonK. N.Y. - 791-1020 y
q.--g".-a y-w.
q.,s s,
>-q y
p $
-r~g
jbp ta Frederick-direct 3412 1
stopped, I started to see the decrease.
2 Q.
You say that you cut back the HPI flow into the 3
reactor coolant system by about half.
4 What was the level in the pressurizer at about 5
the time when you did that?
6 A.
It was 360, 380, in that range.
7 Q.
Were you cutting back the HPI flow pursuant to 8
any specific procedures or guidelines that you had been 9
trained on?
10 A.
Yes.
11 I was trying to avoid the high level limit in
{
12 the pressurizer of 385 to ultimately the 400 in limit which 13 says you can't exceed 400 inches at any time.
I didn't 14 want to go solid.
15 Q.
400-inch limit is what we reviewed yesterday?
16 A.
Yes.
17 Q.
When you were at the simulator for training in 18 Lynchburg, were you working from your plant procedures and l
19 tech specs which had limitations on going solid?
20 A.
Yes.
We had all those limits imposed in both 21 places.
22 MR. FISKE:
I think he.said it was during the 23 one week in 1977.
24 THE WITNESS:
That's incorrect.
25 MR. FISKE:
In 1976 he said he was using the B r.
SOUTHERN DISTRICT REPORTERS,U.S. COURTHOUSE FOLEY SQUARE. NEW YORK. N.Y. - 791 1020 L____ __ __ __z___ ____ r _ _ ____ __ ;_ ;; L 7.
-~r
jbp t3 Frederick-direct 3413 1
W simulator procedures.
'N 2
THE WITNESS:
We were using the TMI-2 tech specs.
3 Q.
So you are saying that during both the 3
4 eight-week training course at the simulator and during the 5
one-week follow-up course you were using the TMI-2 tech 6
specs?
7 A.
Yes.
8 The standard technical specifications was what 9
we were learning in our code license training program.
10 They were our TMI-2 technical specifications.
We were 11 using the B & W procedures because the TMI technical 12 specifications had not been revised.
i i
13 Q.
The only point I was trying to clarify to Mr.
'i N a 14 Fiske's inquiry was were you using your own plants' 15 technical specifications at all times you were trained at 16 the simulator?
17 A.
Yes.
18 Q.
Did any B & W instructor tell you there -might be 19 a time when the provisions in the technical specifications 20 relating to maximum level in the pressurizer would not be 21 applicable?
l 22 A.
They are always applicable.' Maximum level in 23 the pressurizer cannot be exceeded under any circumstances.
24 MR. FISKE:
I will object to that answer.
l
J 25 THE COURT:
It is not responsive.
\\
SOUTHERN DISTRICT REPORTERS. U.S. COURTHOUSE i
FOLEY SQUARE NEW YORK. N.Y. - 791-1020
[
- - - -. ~
jbp t3 Frederick-direct 3414 1
MR. FISKE:
It is either yes or no.
l(
/
2 MR. SELTZER:
Can I ask the reporter to read the 3
question back?
4 THE COURT:
Put it again.
5 Did any B & W instructor ever tell you there 6
would come a time when the pressurizer level was not 7
applicable?
Just yes or no.
8 THE WITNESS:
No.
9 Q.
What was your understanding about whether there 10 was any indication on which it would be appropriate to 11 exceed the tech spec limit on. pressurizer level?
12 A.
Once the pressurizer level is normal or slightly
~
13 above, you have got plenty of water, there is no reason to 14 go above any more water, no reason to exceed that limit.
15
-0 At the point in time where we are now that the 3
16 pressurizer level is up above 300 inches, you are cutting 17
'back on high pressure injection, did you have any belief 18 that the plant was experiencing loss of coolant accident?
19 A.
No.
20 Q.
Did the pressurizer level respond to your 21 cutting back on high pressure injection?
l 22 A.
Yes, it did.
23 The graph turned over and began to go down.
24 04 What did you understand as to why pressurizer b'
level was decreasing when you cut back on HPI flow?
25 4
/
SOUTHERN DISTRICT REPORTERS.U.S. COURTHOUSE FOLEY SQUARE, NEW YORK, N.Y. - 791 1020
,___7_._.
~__
~
~.. - -
m
jbp t3 Frederick-direct 3415 1
A.
I had decreased the amount of water going in and
[,.m}
2 I had begun to letdown on drain water through the letdown (d
3 system, so.I was beginning to have the control of the 4
pressurizer level and was going to be able to bring it back 5
down to normal.
6 Q.
After you saw pressurizer level begin to dip 7
down, what happened next?
8 A.
I guess a minute or so later it started to go 9
back up again.
It turned and began to increase again.
10 Q.
What did you do when you saw pressurizer level 11 begin to go up again?
12 A.
I think I throttled back more on high pressure 13 injection but I began to wonder what caused this second j
14 level experience, since I had corrected the first one, what 15 was causing the second one.
16 Q.
What was your thinking about why pressurizer 17 level was now resuming its upward rise?
18 A.
For the first few seconds I was thinking about 19 it and I was wondering what could have caused it and then 20 Mr. Faust shouted that he had found emergency feed isolated.
21 So I thought that -- if there was no feedwater at all we 22 had experienced a swell when the steam generators boiled 23 dry.
That is, the reactor coolant system expanded and i
24 caused that push up in the pressurizer.
I
h 25 THE COURT:
What's the chronology, as you recall J
SOUTHERN DISTRICT REPORTERS. U.S. COURTHOUSE FOLEY SQUARE. NEW YORK. N.Y. - 791.1020 i,
\\
i
-<--~~..w,-.
.~..__
,m_
^
- 1 jbp t3 Frederick-direct 3416 1
it, between your throttling back on HPI?
I gather you l'
2 manually instituted it, right, sort of at half speed?
(_/
3 THE WITNESS:
Yes, sir.
4 THE COURT:
You throttled back on it, right?
5 THE WITNESS:
Yes.
6 THE COURT:
There comes a time where you say 7
Faust says to you he's discovered the emergency feedwater 8
block valve is closed, "the 12's",
I think he yelled out as 9
I have heard the testimony, the 12's are closed, right?
10 THE WITNESS:
Yes.
11 THE COURT:
What's the relationship of that in s
12 terms of time, how much later?
13 THE WITNESS:
Very short time, few seconds..
b\\
14 But what had happened then, the increase and k,)
s 15 then the dip and then the increase in level and not very 16 much later he announced it.
17 I don't really have the times.
18 THE COURT:
Now, there was an automatic 1
19 actuation of high pressure injection prior to Faust 20 discovering this, wasn't there?
21-THE WITNESS:
That was prior to my manual 22 control of th'e high pressure injection.
23 When I throttled back, what I was throttling was 24-the automatic initiation.
It happened while the
(#~
25 pressurizer level was still increased the first. time.
s- >
a SOUTHERN DISTRICT REPORTERS U1 COURTHOUSE I
FOLEY SQUARE, NEW YORK. N.Y. - 791 1020
.-7.
~,
..m...
_.,..-u
jbp t3 Frederick-direct 3417 1
THE COURT:
Okay, go ahead.
b\\
2 Q.
You said that when pressurizer level resumed Q
3 rising, that was the point where Mr. Faust called out that 4
the 12's were shut.
5 For how long a time did you attribute the rise 6
in pressurizer level to the loss of emergency feedwater l
J 7
that Faust had just announced?
l 8
A.
While he was trying to gain manual control over 9
the feedwater system, I was waiting for him to stabilize 10 his emergency feedwater flow rate, then I could -- erasing 11 that variable, I would be able to determine what the steady 12 stay condition of the reactor coolant system was.
13 It was several minutes until -- he was having l
xi l
14 trouble with the manual controls.
So all during that time
)
f, 15
-and then for a few minutes later, I attributed it to the i
16 emergency feedwater loss which was the cause of the swell.
17 Q.
There came a point in time when emergency 18 feedwater was put into the steam generators; is that right?
19 A.
Yes.
20 Q.
After you learned that there was emergency i
21 feedwater going into the steam generators, what was t
22 happening to pressurizer level?
t 23 A.
Initially when he opened the 12's with the i
24 emergency feedwater control valves full open, there was a 1
a 25 large in-rush of water to the steam generators and we heard
(
)
-iV i
'l SOUTHERN DISTRICT REPORTERS.U S. COURTHOUSE f
FOLEY SQUARE. NEW YORK. N.Y. - 791 1020
}
_s_.__
~'
)
jbp t3 Frederick-direct 3418 1
it on'the noise monitor from the control building area and 2
I saw a dip in pressurizer level.
It showed me that we
(
j 3
were shrinking some of the water in the RCS.
4 So until he could stabilize that in-rush of 5
water, I wouldn't be able to get much sense out of the 6
pressurizer level until he stabilized his flow rate.
7 Q.
Did there come a time when he did stabilize the 8
flow rate into the steam generators?
9 A.
Like I said, it was several minutes.
It took 10 him awhile to do that.
11 Q.
After he had done that, was pressurizer level 12 still high?
13 A.
Yes.
-~
14 Q.
What did you attribute the high pressurizer 15 level to after you had learned that the feedwater into the 16 steam generators had been stabilized?
17 What were your thoughts about the high B
18 pressurizer level then?
19 A.
Well, then having stopped the variable of 20 increasing and decreasing of emergency feedwater flow, the 21 next thing to do was to drain out water from the reactor 22 coolant system to get the amount of water, then putting in, 23 to less than what I am taking out.
I'm sorry, the other 24 way.
Taking more out than I am putting in' so the level l
!l
)'
25 would go down.
i
~J l
SOUTHERN DISTRICT REPORTERS.U.S. COURTHOUSE Fo!.EY SQUARE. NEW YORK. N.Y. - 791.1020 l
l
. ~., -
jbp t3 Frederick-direct 3419 1
I began to take the make-up flow rate down to a i
2 minute and get the maximum letdown.
M 3
Q.
What significance, if any, did you attach to the 4
fact that you had a rapidly rising pressurizer level above 5
300 inches?
l 6
A.
It was very significant.
7 If I couldn't get control of it we would gu 8
solid in the pressurizer and that probably would cause 9
damage to the plant.
10 Q.
Do you know what level pressurizer water level 11 had descended to before it started to turn around?
s.
12 What was the lowest po int that you were aware 13 that pressurizer level went to?
O\\
i 14 A.
I don't remember being aware of the numerical 15 value of the level.
I was just watching the direction of 16 the slope on the graph.
17 Q.
Were you aware that it went below -- withdrawn.
18 Before the transient started, did you have 19 normal level in the pressurizer?
20 A.
Yes.
21 Q.
When the transient started and you got back to 22 the panel that indicates pressurizer level, where was 23 pressurizer level relative to the normal level at which you 24 had started the event?
i 25 A.
I'm sorry.
When was this?
[ \\;d O
l souraEaN oisraicr mEroarEas.u.s. couarnousE FOLEY SQuAaE. NEW YOaK N.Y. - 791.1020 l
~'
- _ L _-. __________ _._~~~_ ~
- ~
jbp t3 Frederick-dirset 3420 1
Q.
The turbine trip has been announced, you walked
.(N) 2 over to see it on panel 17.
Then you got back to the panel
(
3 4 station where the pressurizer level gauges are.
4 Was pressurizer level above no.rmal, below normal?
5 You said you started at normal before the transient?
6 A.
Yes.
It was below normal.
7 Q.
What was your understanding about what was 8
between the below normal water level and the top of the 9
pressurizer?
10 A.
About 300 inches or so.
11 Q.
And what was filling that space?
12 A.
Well, as the pressurizer level came down, that 13 was filled with steam.
As that, as I started to refill it 14 with my manual make-up and with my subsequent automatic HPI, 15 we refilled that whole region with cold water.
16 Q.
What, if anything, do you think happened to most l
17 of the steam that had been in the several hundred inches of 18 space as you were filling the space up with water?
l f
19 A.
It was condensing.
20 Q.
Could you explain what process you understood 21 condensed the steam?
22 A.
As you push water into the pressurizer, the 23 steam space is going to be reduced and the reduction of 24 that space is going to cause the steam to transfer from the
'Ni 25 vapor state to the liquid state and just in order to
/
4 SOUTHERN DISTRICT REPORTERS.U.S. COURTHOUSE f
FOLEY SQUARE. NEW YORK. N.Y. - 791-1020 sI.
__. _. _ _ _ -.. _.. ~. _,
j.
jbp t3 Frederick-direct 3421 I
l 1
maintain the saturation state.
It just occurs as a natural 2
phenomenon.
w l
3 Q.
What, if any, training or experience had you had 4
before the accident as to how quickly steam could be 5
condensed in the steam space at the top of the pressurizer?
6 A.
It could happen very quickly.
In the transients 7
that I have seen, it was a very quick response to the 8
pressurizer.
9 Q.
When you got back to the panel 4 station, were 10 there gauges in front of you that recorded and reflected 11 reactor coolant system pressure?
12 A.
Yes.
13 Q.
Is there also a gauge that recorded pressure in' (j,i
(,,,
14 the pressurizer?
15 A.
No.
The gauge only shows reactor coolant system 16' total pressure.
17 Q.
Is the pressure that is maintained in the 18 reactor coolant system -- withdrawn.
19 Is the pressure that exists within the reactor 20 coolant system the same throughout the entire reactor 21 coolant system?
22 A.
No.
23 Q.
Why is that?
Why isn't it the same?
24 A.
It is not the same because there is a flow in
/ "NJ 25 the system and because we have pumps-operating to move the
\\.-)
w SOUTHERN DISTRICT REPORTERS. U.S. COURTHOUSE FOLEY SQUARE. NEW YORK. N.Y. - 192.1020
3422 jbp t3 Frederick-direct The pressure at the discharge of the pump is high 1
water.
(\\
l 3
2 as it pushes the water into the reactor vessels.
V 3
Q.
What pump?
4 A.
The reactor coolant pump.
5 As you push water into the reactor vessel itself 6
you lose about 35 pounds of pressure as it moves through 7
the fuel assemblage.
is 8
So the pressure at the outlet of the vessel 9
lower than at the inlet and, as you move further on the j
loop, the pressure continues to drop until you come back to 10 J
In 11 the lowest point which is the suction of the pump.
12 other words, there is a continuous decrease of pressure as m
13 you go around the loop.
14 Q.
You said that when you got back to panel 4 the 15 indicator-light for the pilot-operated relief valve was off.
16 Did you take any steps at that point in the 17 transient to verify that the pilot-operated relief valve 18 had closed?
19 A.
No.
20 The indication that it was off and'the response 21 of the instruments was enough to show that there was 22 nothing abnormal going on in that respect.
23 Q.
Response of what instruments?
24 A.
I didn't see any indications that would say that 25 the PORV was open.
V SOUTHERN DISTRICT REPORTERS.U.S. COURTHOUSE j'
FoLEY SQUARE, NEW YORK. N.Y. - 791 1020
.---==L- -
r
" " ' ~ - -
.-n-.-.,,,
jbp t3 Frederick-direct 3423 1
Q.
Did you have any reason to suspect that the y-m f
}
2 light indicating pilot-operated relief valve position was V
3 giving you a wrong signal?
4 A.
No.
5 I would be no more suspicious of that light than 6
any other 50 or 100 lights that I told you about yesterday
~
7 when what I was examining them during the beginning of the 8
sequence.
They are all the same type of lights and giving 9
me the same status type information.
It is not a 10 particularly suspicious light.
11 MR. SELTZER:
Your Honor, I'm about to switch to 12 something else.
13 THE COURT:
All right, we'll take our recess.
i i
14 (Recess) y 15 (Open court) 16 DIRECT EXAMINATION (Cont'd) 17 BY MR. SELTZER:
18 Q.
Mr. Frederick, with the pressurizer filled up to 19 a point where you were concerned about going solid, did 20 there come a time when you thought that there might be a 21 pressure spike in the reactor coolant system?
22 A.
Yes.
23 I thought that if it was that solid we would see
[
24 a pressure spike.
i l
~'*3 25 Q.
Did you ever see a pressure spike in the first
)
SOUTHERN DISTRICT REPORTERS. U.S. COURTHOUSE FOLEY SQUARE. NEW YORK. N.Y. - 791 1020 7~-
7_ _
_L
jbp t3 Frederick-direct 3424 1
couple of hours of the transient?
)
2 A.
No.
3 Q.
.When you failed to see a pressure spike, what, 4
if anything, did that indicate to you?
5 A.
It indicated te me that the pressurizer -- it 6
indicated 400 inches, but there was still some space in the 7
pressurizer at the dome of the tank.
8 THE COURT:
When you say a pressurizer spike, 9
what are you talking about?
10 THE WITNESS:
Pressure spike?
11 THE COURT:
Yes.
What are you talking about?
12 THE WITNESS:
Sudden increase of pressure.
It T
13 looks like -- if you are looking at a pressure gauge, you 14 see a little pointed increase in pressure.
15 THE COURT:
Because you see that the pressurizer 16 level, as I understand it, in five minutes or less went 17 from about 160 something to off the map, right?
18 THE WITNESS:
Yes.
19 THE COURT:
What do you call that?
20 THE WITNESS:
That's not 21 THE COURT:
That's not a spike?
22 THE WITNESS:
That's pressurizer level.
23 I was talking about reactor coolant system 24 pressure.
The other graph is indicating pressure.
[
/
25 THE COURT:
I see.
Okay.
O SOUTHERN DISTRICT REPORTERS U.S. COURTHOUSE FO!.EY SQUARE. NEW YORK. N.Y. - 791 1020
.__g
- '?w-F.-
T yy
jbp t3 Frederick-direct 3425 1
Q.
Just to recap.
2 THE COURT:
Let me hear this.
3 Q.
When the pressurizer water level was at solid, 4
did there come a time -- with the pressurizer water level 5
solid, you would expect that the pressurizer water system 6
would spike up?
7 A.
Yes.
8 Q.
And you never saw that?
9 A.
That's right.
10 Q.
And could you just briefly recap it?
f 11 What ran through your mind as to why the system 12 was not seeing the pressure spike that you thought might
-I 13 occur?
\\m l 14 A.
Because, as the level indicator was showing me, 15 the pressurizer level was at or around 400 inches but there 16 is more space above the indicated range, the straight 17 portion of the tank.
There is a dome on top of the tank 18 that isn't indicated and I figured that there was still 19 space up there that I couldn't see on the indicator.
20 Q.
What would be the effect, as you understood it, 21 of having that space above the water level in the 22 pressurizer?
23 A.
It would indicate that we didn't have the 24 pressurizer just absolutely full of water.
It would still l2 N
25 act as a cushion for pressure transients.
)
%r SOUTHERN DISTRICT REPORTERS.U.S. COURTHOUSE 3
FOLEY SQUARE. NEW YORK. N.Y. - 791-1020
~
jbp t3 Frederick-direct 3426 1
Q.
Had you had any training before the accident on 2
solid conditions in the reactor coolant system?
The whole 3
reactor coolant system including the pressurizer?
4 A.
There is no training on how to operate in any 5
kind of solid conditions, no.
6 Q.
Had you had any training on how long it would 7
take for the -- withdrawn.
8 THE COURT:
As I understand it, you testified 9
that your training consisted of " don't let the pressurizer 10 go solid except for hydrostatic test", right?
11 THE WITNESS:
Yes.
12 THE COURT:
That's essentially it.
13 We don't really need to go around that subject a 14 third or fourth time.
All right.
15 O.
When the pressurizer went to the top of its 15 readable scale, where was reactor coolant system pressure?
17 A.
The pressure was at about 1300 pounds or so.
18 0..
Did you have any understanding why the reactor 19 coolant system pressure was at that level?
20 A.
Well, the pressurizer normally maintains reactor 21 coolant system pressure.
What I had done was just flood in 22 300 inches of cool water.
It would take sometime for the 23 heaters to regain ability to maintain reactor coolant 24 system pressure.
,[A So, while the large amount of cold water was 25 SOUTHERN DISTRICT REPORTERS, U.S. COURTHOUSE FoLEY SQUARE. NEW YORK. N.Y. - 798 1020 r:r
-.r 7
cnn
~
l - --
T
-~-
jbp t3 Frederick-direct 3427 1
injected, we would have the suppression of pressure.
. 'N, Had you had any experience before the accident 2
Q.
3 with a slow recovery of pressure or pressure suppression as 4
you called it?
5 A.
Yes.
6 We had other transients where the pressurizer 7
heaters just didn't seem to have the capacity necessary for 8
a quick return of the reactor coolant system pressure and 9
we had had some heater controller failures also.
10 Q.
Now, after you had injected about, as you said, 11 300 inches of cold water intc the pressurizer, did you 12 eventually see the pressure start to come up?
13 MR. FISKE:
Your Honor, I think there is a 14 misstatement here that no cold water is injected into the 15 pressurizer.
16 The testimony has been that what happens is --
17 MR. SELTZER:
I will rephrase it.
18 MR. FISKE:
Hot water at about 580 degrees is 19 going into the pressurizer.
20 (Continued on next page) 21 22 23 24 25 V
SOUTHERN DISTRICT REPORTERS. U.S. COURTHOUSE FOLEY SQUARE. NEW YORK. N.Y. - 791-1020 l
1 e
l '['
~ ~ ~ ~
" ~ ~ "
~~
~~ '~
1 lh t4 Fr6derick - direct 3420 l
1 Q.
Mr. Frederick, what did you mean in a prior
(
gm answer when you referred to cold water going into the i
2 l r&
l 3
pressurizer?
4 A.
Just using in a relative sense cold as compared 5
to 647.
550 to 560 degree water, 570 degree water, is 6
colder than 647 degree water.
It is cold water.
It may be what you are accustomed to as tap water, or anything, 7
not 8
but cocipa red to the 647, we are about a hundred degrees 9
colder..
10 Q.
Where does the number 647 come fron?
Where is 11 there a temperature of 647 degrees?
12 A.
Normal temperature in the pressurizer is 647 13 degrees fahrenheit.
That's the temperature that is
/
14 maintained under the steady state condition that we had 15 just before this transient began.
16 Q.
And the colder water that was coming into the 17 pressurizer was at what temperature?
18 A.
Whatever the TH was.
Say 550 to 580 degrees.
19 Q.
After the initial filling of the pressurizer 20 with the colder water that was coming in, did you 21 eventually see reactor coolant system pressure recover?
22 A.
No.
23 Q.
You said that initially you thought that it was I
24 taking awhile for the heaters to heat up the colder water
>m:
25 that you had just injected into the pressurizer.
Later on
(
N)
SOUTHERN DISTRICT REPORTERS.U.S. COURTHOUSE FoLEY SQUARE. NEW YORK. N.Y. - 791 1020 f
- _ ~. _
_ _._ J1
lh t4 Frederick - direct 3429 1
as pressure continued to stay low, what if any thoughts did O
n 2
you have as to why pressure was staying down?
(d 3
A.
I began'to think that the capacity of the 4
heaters was just insufficient to raise that much -- to get 5
the temperature of the water up or that I think even later 6
on we checked for heater failures, heaters that were not 7
operating for some reason.
That we would check out in the 8
turbine building.
You would have to go out and look at the 9
breakers for the heaters.
10 Q.
While pressure was staying down low, where was 11 pressurizer level?
12 A.
It was high.
It was in the approximately 400-13 inch range.
('4 i
14 Q.
What did you think was causing the pressurizer 15 level to remain up very high?
16 A.
For a long time, I already explained, I thought 17 it was due to the emergency feedwater instability.
As time
)
18 went by, I began to suspect that -- we went through several 19 analyses trying to figure out why the pressurizer level was 20 high.
We thought that the instrument had failed or for 21 some reason was reading high and another time, whether it 22 was before that or not I don't know, we suspected that our 23 letdown or our drain line that I had opened up was not --
l 24 was blocked for some reason, that the water was not flowing i
'l 25 from the reactor coolant. system to the letdown system.
So s
SOUTHERN DISTRICT REPORTERS.U.S. COURTHOUSE i
i-FOLEY SQUARE. NEW YORK. N.Y. - 791.1020
. ~ ~. -
lh t4 Fredorick - dirset 3430 we tried to verify our valve lineup both locally and here 1
x We
)
on the control panel, sending an auxiliary operator.
2 wanted to have the drain from the system and we weren't 3
4 sure that we had'it.
5 THE COURT:
Let me hear that answer.
6 (Record read.)
7*
Q.
You referred to sending an auxiliary operator.
8 Why was an auxiliary operator sent?
9 A.
I believe we sent one of the operators to check 10 the local indications on some of the valves in the letdown 11 line to see if it was open.
12 Q.
Did the high pressurizer level ever lead you to 13 suspect that saturation had occurred in the reactor coolant N
14 system outside the pressurizer?
15 A.
No.
16 Q.
Had you had any training on the effects of 17 saturation in the reactor coolant system on pressurizer 13 level?
19 A.
No, there was never any training that showed how a saturation condition in the system would affect the 20 21 instruments on the panel.
22 Q.
Had you ever seen saturation in the reactor 23' coolant system modeled at the B & W simulator?
24 A.
No.
25 Q.
You have already testified to the fact that
\\
, \\.j; i
i SOUTHERN DISTRICT REPORTERS.U.S. COURTHOUSE FOLEY SQUARE. NEW YORK. N.Y - 791.1020 t
T' g
g=
,9
.4 g
gi
Ih t4 Frederick - direct 3431 1
Craig Faust called out in the control room that the 12 (D
2 valves were shut.
What if any effect did the problems with
\\a) 3 emergency feedwater have on your ability to control the 4
primary side?
5 A.
I would listen if Mr. Faust had something to say 6
about what he was doing.
It was our practice to keep each 7
other informed about what we were doing.
I wasn't involved 8
in his analysis or his problem, other than that he was 9
keeping me posted with what he was doing.
10 0
Did it interfere with what you were doing in any 11 way?
12 A.
No.
'~5 13 Q.
After the emergency feedwater flow was restored, 14 and you described that Faust stabilized flow into the steam 15 generators, what did you do next?
f 16 A.
I already said that the feedwater stabilized, 17 pressurizer level was still high.
We went through those 19 analyses trying to figure out what was happening with the
{
19 pressurizer level, why was it so high, did we have letdown, 20 is there something wrong with the instrument.
I don't 21 recall a specific incident that occurred next.
i l
22 0
Did you have an alarm printer attached to the l
23 computer in the control room?
24 A.
Yes.
CCj#
What if any function did you understand that
{
i 25 Q.
u,/
J SOUTHERN DISTRICT REPORTERS. U.S. COURTHOUSE FoLEY SQUARE. NEW YORK. N.Y. - 791 1020
^
^
Ih t4 Frederick - direct 3432 1
computer alarm printer had during a plant transient?
f' 2
A.
It was our practice not to use the alarm printer v
3 during any kind of a transient because it had a rather slow 4
typewriter on it.
You couldn't get information out of it 5
as quickly as it was occurring in the plant.
6 Q.
When you attended simulator training at B&W
- 7 did they have a control room computer in the simulator room?
8 A.
Yes.
9 Q.
During the transients that were simulated at B&
10 W was the computer printer used?
11 A.
No.
12 Q.
Did there come a time when you checked the 13 pressurizer level instrumentation to see if it was giving 14 you accurate readings?
15 A.
Yes.
We asked an instrumentation technician to 16 examine the instrument and determine if the reading we were 17 getting was valid.
18 Q.
What was the result of his investigation?
19 A.
He was surc that the instrument was giving valid 20 information, that the pressurizer level was high.
21 Q.
Did you do anything at the panel to attempt to 22 determine whether you were getting accurate pressurizer 23 level indication?
24 A.
Yes.
All I could do was -- there is a switch
]/ 'Nf 25 and two meters that show pressurizer level.
This switch SOUTHERN DISTRICT REPORTERS. U.S. COURTHOUSE FOLEY SQUARE NEW YORK. N.Y. - 791-1020 l
I l
-...._.._A_
L:-~~^
'~
^
~
lh t4 Frederick - direct 3433 1
here selects one of the three pressurizer level instruments N
2 that you can read on this graph, and there are two 3
pressurizer level gauges here that indicate an alternate 4
signal for pressurizer levels not compensated for by 5
temperature, and there are -- you compare them to see if it is the 6
they are reading the same and they tell you that 7
same thing, that it is a good instrumentation.
8 Q.
Did you compare the various readings of 9
pressurizer level that you could obtain in the control room?
10 A.
Yes.
That's what I did.
You just have to look 11 at the gauges on the panel.
12 Q.
I am just asking, did you do that on the morning n
13 of the accident?
I; 14 A.
Yes, yes.
15 Q.
Did there come a time after 4 a.m. when you 16 rece1ved information about the operation of the reactor 17 building sump pumps?
4 18 A.
Yes.
19 Q.
How did you get information about the sump pumps?
20 A.
One-of the phone calls I received was from an 21 auxiliary operator in the auxiliary building, and he told 22 me that 23 Q.
Could you fix a point in time, as best you can?
24 A.
Around a half an hour, or so, after the
(
25 beginning of the transient.
j - ;
SOUTHERN DISTRICT REPORTERS.U.S. COURTHOUSE FOLEY SQUARE NEW YORK. N.Y. - 791 1020 I
__y
.-.~.;. _
7.
lh t4 Frsderick - dirset 3434 1
Q.
What did the auxiliary operator calling from the
['"'l) 2 auxiliary building tell you?
Q.
3 A.
He told me that the reactor building sump pumps 4
were running and the sump level was high.
5 Q.
Did he tell you how much water had been pumped i
6 out of the sump?
7 A.
No.
8 Q.
Did you know how much water had been pumped out 9
of the sump?
10 A.
No.
11 Q.
How many pumps are there that withdraw water 12 from the sump?
13 A.
Two.
I 14 Q.
Did the auxiliary operator indicate whether one 15 or both punps were on?
16 A.
I believe he said both were running.
17 Q.
Did the auxiliary operator indicate anything 18 about what the water level was in the sumps?
19 A.
He said it was high.
20 Q.
Did you do anything to check whether what he was 21 telling you about the condition of the sump was accurate?
22 A.
Yes.
I used the digital computer display to 23 find out what the level was in the sump on,the i
24 instrumentation that I had.
~'y 25 Q.
What did your check reveal as compared to what v
SOUTHERN DISTRICT REPORTERS.U.S. COURTHOUSE FOLEY SQUARE. NEW YORK. N.Y. - 191-1020
. _ ~. - _ _
e*
1h t4 Frederick - direct 3435 1
the auxiliary operator told you?
(h
(
)
2 A.
Mine showed that the sump was full also.
u_,7 3
Q.
You said that the auxiliary operator didn't tell Did the auxiliary 4
you how much water had been pumped out.
operator tell you how long the ' sump pumps had been on?
5 6
A.
No, he didn't.
7 Q.
At the panel that is in the auxiliary building, 8
was there anything from which the auxiliary operator would 9
have been able to read how long the pumps had been on?
10 A.
No.
All he has down there are the sump level 11 gauge similar to the ones that you see here on the control 12 panel and a red and green status light for the pumps.
m 13 Q.
Is there a normal water l'evel that is maintained 14 in the sump?
15 A.
There is usually a couple of feet in there.
16 Q.
Is there a point at which the sump pump 17 automatically turns itself on?
1R A.
Yes.
I really don't know what that is, but it 19 is a little above that normal level.
I 20 Q.
Something above the two-foot level?
21 A.
Yes.
22 Q.
When you were told that the sump level was high 23 and you confirmed it in the control room, what was your 24 understanding as to how big the reactor building sump was?
("AgJ 25 How large a holding space are we talking about.
(
g x_s' SOUTHERN DISTRICT REPORTERS.U.S. COURTHOUSE FoLEY SQUARE. NEW YORK. N.Y. - 791 1020
- ~ -
lh t4 Frederick - dirset 3436 1
A.
It is a box about the size of the Judge's desk O
2 here, this indent where he is sitting.
About 6 by 4 or 5, '
3 and then it is about 6 feet deep.
There is some piping and 4
things in the sump and t.he pumps themselves.
5 Q.
What was your understanding when you got the 6
report that the sumps were full as to how much extra water 7
had flowed into the sumps above the level that otherwise 8
would have been in the sump?
9 A.
We had gained -- in terms of gallons, I didn't 10 figure that out, but it.was a few tubsful of water that 11 raised the level from what was normally in there to above 12 the actuation set point for the pumps.
13 MR. FISKE:
Excuse me, your Honor, I didn't hear 14 the answer.
15 THE COURT:
You may have it read back, 16 (Record read.)
17 Q.
When you heard that the sump level was high and 18 the pumps were on, did that tell you that something was 19 very wrong?
20 A.
It showed that we had a problem, that something 21 was wrong with the pumps, that either they weren't running 22 or they weren't pumping enough water to keep the sump level 23 down.
24 Q.
Was having all that water in the sump a big 25 concern to you?
s SOUTHERN DISTRICT REPORTERS.U.S. COURTHOUSE FoLEY SQUARE. NEW YORK. N.Y. - 791.1020 I
^-
Frederick - direct 3437 1h t4 1
A.
No, it is not 'O that much water.
It is just
.f 2
an area about this large that's the basement of a very A
3 large building.
You'are going to get a lot of water in a 4
little sump like that.
5 THE COURT:
Did you know at this time that the 6
drain tank rupture disc had blown?
7 THE WITNESS:
No.
8 THE COURT:
I think you placed this information 9
about the sump as being a phone call from the auxiliary 10 operator about a half an hour into the transient, right?
11 THE WITNESS:
Yes.
12 THE COURT:
The chronology places the drain tank emp 13 rupture disc as blowing at 14 minutes 51 seconds.
\\s_
14 THE WITNESS:
There are no indications of the.
15 disc status.
There are no control room indicators or other 16 indicators that tell you what the status of the disc is, 17 whether it-i's blown or not blown.
la THE COURT:
Are there indicators that tell you 19 that the pressure in the drain tank has gone I gather to 20 zero, which is what happens when the disc blows?
21 THE WITNESS:
We have a pressure gauge in the 22 tank that would indicate whatever pressure is present, yes.
23 THE COURT:
If the disc blows, it blows because 24 the pressure is too great for the tank and on blowing, the
/
25 pressure goes approximately to zero, correct?
(/
~
SOUTHERN DISTRICT REPORTERS.U.S. COURTHOUSE FoLEY SQUARE. NEW YORK. N.Y. - 791-1020 m
1h t4 Frederick - dirsct 3438 1
THE WITNESS:
Yes, but the normal pressure in
-[ mT 2
the tank is zero, so it wouldn't really tell you if it were t
)
%J 3
zero that the disc is blown.
4 THE COURT:
Did you have any awareness that the 5
tank had had a higher pressure prior to it going to zero?
6 THE WITNESS:
Mr. Seltzer asked me if I 7
remembered that sort of thing.
I don't actually remember 8
the trip back to look at.the gauges, but I testified that I 9
did go back and saw the pressure was up and the tenperature 10 was up.
Tha t was within, according to the testimony, a few Il minutes after the transient began.
12 THE COURT:
Did you at the time that the 13 auxiliary operator told you about the sumps, which is, you b)
(
14 say, a half hour deep, did you have an awareness at that 15 point that the pressure in the drain tank was now zero?
19 THE WITNESS:
Again, not having a specific 17 recollection of it, there is testimony that says that we 18 are aware that the pressure was now zero.
19 THE COURT:
No.
As you sit here today, do you 20 have any recollection of at that time having in your mind 21 that the pressure in the drain tank was zero?
22 THE WITNESS:
No, I don't remember it at all.
23 THE COURT:
Where did you think the water came 24 from in the sump?
i'
N 25 THE WITNESS:
At the time I knew that we had SOUTHERN DISTRICT REPORTERS, U.S. COURTHOUSE FOLEY SQUARE. NEW YORK. N.Y. - 191-1020
. [
[
lh t4 Frederick - direct 3439 1
been continuously been putting water in the sump during the
,0 2
shift.
It pumps out a couple of times a shift anyway.
We
{/
3 had water in there for -- normally there was water dumping 4
in there, so there wasn't any abnormality.
It just showed 5
that the source of water either was putting water in faster k
than the pumps could pump it out now or that the pumps 7
weren't actually even pumping.
I didn't know what the 8
source of the water was.
9 THE COURT:
I see.
Okay.
Go ahead, Mr. Seltzer.
10 BY MR. SELTZER:
11 Q.
Mr. Frederick, do you recall testifying before 12 the House Committee, Congressman Udall's committee, in May 13 1979?
b 14 A.
Yes.
15 MR. FISKE:
Your Honor, I certainly have no 15 objection at some point to Mr. Frederick being questioned 17 on this testimony because I certainly intend to ask him a 18 lot of questions about what he said on this occasion, but I 19 would just like to inquire what Mr. Seltzer's purpose is 20 for doing this now.
Is he trying to impeach Mr. Frederick?
21 MR. SELTZER:
No.
This is, again, recorded 22 recollection.
23 THE COURT:
I don't know that he said he has a 24 failure of recollection. 'What's the area in which he b
U 25 doesn't recall something?
g%)
SOUTHERN DI5TRICT REPORTERS.U.S. CoURTHOU5E FOLEY SQUARE. NEW YORK. N.Y. - 791 1020
~ ~:~~
~ ~ ~ ^
^
J.-.
- ~". ::^.-.
1h to Frederick - direct 3440 1
He was asked "where did you think 2
this water was coming from," and he said "the drain tank, 3
the reactor coolant draining tank" 4
THE COURT:
I know, but when I asked him now I 5
think he said he didn't know.
6 MR. SELTZER:
If he doesn't recall now, then 7
this is recorded recollection --
8 THE COURT:
His answer was "I don't know."
It 9
wasn't "I don't recall."
His answer was "I don't know."
10 THE WITNESS:
I thought I said "I didn't recall 11 going back there."
12 THE COURT:
Le t 's se e wha t the answer is.
13 (Record read.)
14 THE COURT:
I will sustain the objection.
15 MR. SELTZER:
Your Honor, may I read this for 16 the purpose of refreshing 17 THE COURT:
No.
He doesn't indicate he has any 18 memory to be refreshed.
He hasn't indicated he doesn't 19 recall or he needs his memory refreshed.
20 BY MR. SELTZ ER:
21 Q.
Mr. Frederick, you testified many times about 22 the Three Mile Island accident.
Was --
23 THE COURT:
Would you*please go through that 24 door?
25 (The witness lef t the courtroom.)
SOUTHERN D!$TRICT REPORTERS.U.S. COURTHOUSE FOLEY SQUARE. NEW YORK. N.Y. - 791 1020
lh t4 Frederick - dirset 3441 l
1 THE COURT:
It is one thing to sort of try to i
2 massage an answer into the witness' consciousness, but he
)
3 has given me an answer and what has happened is you want 4
the answer to be something other than what was said to me.
5 MR. SELTZER:
Not at all.
1 A
THE COURT:
Yes, at all.
It is at all.
He has 7
given me an answer and you believe the answer should be 8
something else.
That's your sincere belief.
You think the i
9 answer should be something else.
10 MR. SELTZER:
Your Honor, I don't really think 11 the answer should be anything.
The answer is whatever this 12 man has previously said, it is wha t he says today --
/ mg 13 THE COURT:
That's what he tells me here now is 14 his recollection.
15 MR. SELTZER:
That's his recollection today.
16 THE COURT:
So we will live with his 17 recollection today.
18 MR. SELTZER:
I think it is just going to be a 19 pointless exercise to delay for a day getting him to 20 discuss the fact that one month after the accident --
21 THE COURT:
One of the issues that the Court has 22 to deal with with all of these witnesses who frankly are 23 giving cue rather detailed evidence about things that were 24 happening at breakneck pace under very pressing l
I f
25 circumstances -- one of the things I am going to have to do SOUTHERN DISTRICT REPORTERS. U.S. COURTHOUSE FOLEY SQUARE. NEW YORK. N.Y. - 791-1020
,.--n-
---.,,.--e
---a.
r
. _ Ell ~
- ~
lh t4 Frederick - direct 3442 1
is to determine how I assess this testimony, so it is not a 2
pointless exercise.
It goes to how you assess the weight
['
L 3
to be given what a witness says about a particular subject.
4 You had him here a minute or two ago saying he 5
remembers something as happening in two minutes and in fact 6
it happened in 35 seconds.
7 MR. KLINGSBERG:
Your Honor, could I just jump 8
in a second?
9 THE COURT:
I'd rather you didn't.
I'd rather 10 deal with one lawyer on one side at a time, if you don't 11 mind.
Yes, Mr. Fiske?
12 MR. FISKE:
Maybe I don't have to say anything 13 if you sustain the objection, but this witness testified at
(,)
14 his deposition twice.
I asked him the question "did you 15 think the water was coming into the sump from the drain 16 tank," and he said "no, I didn't learn that until three 17 days after the accident."
18 I said "I tell you what, I will give you another 19 chance to answer that question and I will remind you you 20 are under oath."
21 Mr. Seltzer objected to that, but the witness 22 said "my answer is the same.
Clearly I didn't know that 23 the water in the sump was coming from the drain tank until 1
24 three days after the accident."
25 Then I read him three different answers he gave v
SOUTHERN DISTRICT REPORTERS. U.S. COURTHOUSE FOLEY SQUARE. NEW YORK. N.Y. - 791.1020
~
~
^~~
i Ih t4 Frederick - direct 3443 to that congressional committee where he said the water is 1
I read him the coming from the drain tank and every time
(
/
2 3
question he said, "Well, I was just telling them something 4
I learned after the accident."
5 His position right through the deposition was 6
that during the accident he didn't know the water was t
7 coming from the drain tank, and that's the answer he just 9
gave to your Honor.
think Mr. Seltzer can now try to sort of 9
I don't anticipate the cross examination by reading him this and 10 11 saying "what did you mean then," and so forth.
He has 12 taken his position.
He said the same thing under oath here 13 that he said in the deposition, that he didn't think the 14 water was coming from the drain tank.
15 I think he has to live with that answer in the 16 face of what he said to the congressional committee and in 17 the face of the fact that Mr. Zewe testified himself that 18 he told Mr. Frederick while they were standing at the panel 19 that the water was coming from the drain tank.
Mr.
Frederick has taken his position here the same way he did 20 21 in the deposition.
I think he has made his choice, and i
let's just get on with this in the way --
22 23 THE COURT:
I think as a matter of trial 24 procedure, I am going to sustain the objection for the l[M' reasons I stated before Mr. Fiske made his observations to f/
25 SOUTHERN DISTRICT REPORTERS.U.S. COURTHOUSE FOLEY SQUARE. NEW YORK. N.Y.
79L 1020 1-
.- v e,
)
i lh t4 Frsderick - dir6ct 3444 1
me.
But what he does say to me as a matter of the 2
procedural history of arriving at this point frankly kj 3
confirms the view that I have.
4 MR. SELTZER:
Your Hono r, I'd only like to say 5
that this is one event out of hundreds of events that 6
transpired during that day, and I think he has given 7
testimony previously that was shortly after the accident 8
when his recollection was probably fresher.
All that I was 9
seeking to do was show him this and see if it refreshed his 10 recollection.
I am as aware as Mr. Fiske that he what he 11 told your Honor --
12 THE COURT:
He doesn't need to have his
,e 13 recollection refreshed.
That's the problem.
We are 14 dealing with the timing of things and admissibility.
He is 15 dealing with an answer that doesn't need recolle2 tion 16 refreshed.
He is saying he doesn't know where it was 17 coming from.
That's his short answer at the very end.
I 18 will sustain the objection.
19 (The witness entered the courtroom.)
20 BY MR. SELTZER:
21 Q.
Mr. Frederick, was it unusual for the sump pump i
~
22 to be on?
23 A.
No.
24 Q.
Before the accident started what had caused the 25 sump pump to run when it did run?
.v 1
$OUTHERN DISTRICT REPORTERS. U.S. COURTHOUSE FoLEY SQUARE. NEW YORK. N.Y. - 1911020 0
~ * * * ~ '
-~
-w=
~ - -
,s,,,,
Ih t4 Frcdorick - dirset 3445 1
A.
It ran a couple of times a shift due to water
~ (q) 2 accumulation in the sump just due to normal operation.
We w j' 3
had -- everything in the whole reactor building that has a 4
leakoff or a drain of some sort goes to the sump or --
5 THE COURT:
This is identified leakage we were i
6 talking about, right?
7 THE WITNESS:
No, no, this is mostly 8
condensation because the building is so hot and full of 9
humidity.
10 Q.
Could you just explain in a sentence or two what 11 the source of -- how that water gets into the sump?
12 THE COURT:
I think I understand that.
13 Q.
In addition to the condensation of humidity,
.\\
's) 14 were there any other sources-that contributed water to the 15 sump that had to be pumped out?
l 16 A.
There were some valve leakoffs and pump seal 1
17 leakoffs.
Water that runs out of the pumps normally is l
I 18 collected in that sump and stored and then sent over to the 19 auxiliary building for radioactive waste processing.
20 Q.
What i f anything did you do after you got the 21 report that the sump was full and the pumps were running?
22 A.
I checked the level on the computer digital 23 readout and then --
24 Q.
Did you take any action?
25 A.
I told Mr. Daugherty, the auxiliary operator I SOUTHERN DISTRICT REPORTERt U.S. COURTHOUSE FOLEY SQUARE. NEW YORK. N.Y. - 791 1020
---n.
s--
-.-n
1h t4 Frederick - direct 3446 I
was talking to, to. turn off the pumps.
.p) 2 Q.-
Had you conferred with anybody in the control
,V 3
room before giving Mr. Daugherty that instruction?
4 A.
Yes.
I explained the report that Mr. Daugherty 5
had given to me to Bill Zewe, and then I told Daugherty to 6
turn off the pumps?
7 Q.
When you went to the simulator for training did R
you get any instruction on how you could tell if a rupture 9
disc had burst on a reactor coolant drain tank?
10 A.
No, the simulator doesn't have a drain tank 11 rupture disc.
They didn't show you that.
12 Q.
How extensive was B & W's instruction on the 13 drain. tank?
14 MR. FISKE:
I am going to object to that 15 question, your Honor.
It is very general.
I 16 THE COURT:
Yes.
17 MR. SELTZER:
I will rephrase it.
Withdrawn.
18 MR. FISKE:
Are all these questions on the 19 training on the drain tank being limited to B & W?
20 MR. SELTZER:
Yes.
21 Q.
When you were at the simulator being trained by 22 B&W, what.was the extent of the instruction that you got 23 from B & W, if any, on the reactor coolant drain tank?
i i
24 A.
Other than that event I described yesterday, I N
25 don't really recall any, any training on the reactor SOUTHERN DISTRICT REPORTERS. U.S. COURTHOUSE FoLEY SQUARE. NEW YORK. N.Y. - 1911020
~#'
'-***~
~
ae=
,.g g
-M
-*""*-Y
..-.7-g w
Ih t4 Frederick - direct 3447
/~'
1 coolant drain tank or its function or status during 2
transients, or anything like that.
3 Q.
Did the simulator have a panel of readings that 4
was_ analogous 'to your reactor coolant drain tank gauges 5
that are on panel 8-A?
6 A.
No, they don't have a panel that models anything 7
about the drain tank.
8 Q.
Did the simulator have anything that 9
continuously recorded what the parameters were in the drain 10 tank?
11 A.
No, they don't display or record any reactor 12 coolant drain tank parar.eters.
)
13 Q.
Was there a mockup of what the panel would look
,14 like in a control room that had gauges for a reactor 15 coolant drain tank?
16 A.
No, there is no representation of it at all.
17 Q.
Was there a period of time during the transient 18 when Mr. Zewe, the shift supervisor, left the control room?
19 A.
Yes.
I 20 Q.
Did there come a point in time when you noticed 21 that there was an increase in reactor building pressure?
22 A.
'Yes, there was.
23 Q.
Do you recall when that was relative to Zewe's j
24 leaving the control room and returning?
}
s 25 A.
It was after he left and then he came back and
~-
SOUTHERN DISTRICT REPORTERS. U.S. COURTHOUSE j
FOLEY SQUARE. NEW YORK. N.Y. - 7911020
..m.
Ih t4 Frederick - direct 3448 N
1 then we got into a discussion abou', reactor building 2
pressure.
3 Q.
With whom did you discuss the increase in 4
reactor building pressure?
5 A.
Mr. Zewe was there and Mr. Faust, Mr. Scheimann.
6 I think that's it.
~
7 Q.
What was the substance of that discussion?
8 A.
It was a discussion to determine the reason for 9
increasing reactor building pressure and we --
{
\\
10 Q.
Did you reach any conclusions in that discussion?
j l
11 A.
We concluded that there was a steam leak in the 12 r,eactor building that was causing an increase in
(
,J 13 temperature and pressure.
%J 14 Q.
Where did you think the steam was leaking from?
15 A.
The steam piping from the steam generator that's 16 inside the reactor building.
17 Q.
This is piping that would normally carry steam 18 from the steam generators to where?
19 A.
The steam generators in the reactor building to 20 the steam turbine in the turbine building.
21 Q.
What was your basis for concluding that you had 22 a break in that steam line?
23 A.
We saw indicators on the steam generators that 24 showed that the feed and steaming rates were uneven in the V{
\\
25 generators and that's an indication of a steam leak, and we SOUTHERN DISTRICT REPORTER $.U1 COURTHOUSE FOLEY SQUARE. NEW YORK N.Y. - 1911020
~
_au.
____x________
~
-+
.n Ih t4 Frederick - direct 3449 1
saw the raising pressure in the reactor building, and so 3
(j
\\
2 between those indications, those panel indications and-3 symptoms, we decided that there was probably a steam leak 4
in th'e B steam generator.
5 MR. FISKE:
Can we just have the time fixed fo r 6
this determination?
7 THE COURT:
This is when Mr. Zewe came back from 8
his --
9 MR. SELTZER:
His trip to the turbine building.
10 THE COURT:
His trip to the turbine building.
11 Q.
Did you consider any possibilities other than a 12 steam line break as causing the building pressure rise?
13 A.
I don' t recall that I considered anything else, D
14 no.
15 Q.
In the conversation that you participated in 16 with the people you have identified, was there any 17 discussion of other possibilities or any other possibility 18 giving rise to the pressure increase in the reactor 19 building?
20 A.
I think the conversation addressed the 21 possibility of loss of coolant, but it was discounted 22 because *.here was no presence of radiation.
23 Q.
Did you reach any conclusion in this 24 conversation as to the size of the steam line break?
(
C/
25 A.
It was not very large because we weren't seeing SOUTHERN DISTRICT REPORTERS U.S. COURTHOUSE FOLEY SQUARE. NEW YORK. N.Y. - 791 1020
~
1h t4 Frederick - direct 3450 1
much of a pressure decrease or a feed rate change in the
-y
/
\\
so we classified k,/
2 generator that we suspected was leaking, s
3 it as a small to medium steam leak.
4 Q.
Did you take out any procedure that told you 5
what you should do for a steam leak?
6 A.
I didn' t personally, but the procedure was taken 7
out.
8 Q.
Somebody else took it out?
9 A.
Yes.
10 Q.
You referred to not seeing a radiation alarm.
11 What was the significance, as you understood it, of the 12 absence of a reactor building radiation alarm?
13 A.
The procedures for a loss of coolant and steam
%J 14 line break indicate'that they can be so similar that there 15 may be only a few ways to differentiate between one 16 casualty or the other, so that one way you can determine 17 between a steam leak and a loss of coolant accident i s the 18 presence or absence of the reactor building radiation alarm 19 when the primary coolant, the reactor coolant system water, 20 is exhausted due to a loss of coolant accident in the 21 reactor building.
It causes an increase in radiation 22 products because that water is carrying radiation products 23 whereas the steam which is on the secondary side is not 24 radioactive.
~~~
O-(
25 Q.
Did you take any action based on the conclusion SOUTHERN DISTRICT REPORTERS.U.S. COURTHOUSE TOLEY SQUARE. NEW YORK. N.Y. - 791 1020 m---
p
,ve-a-
e
-p
==
-e-F vt-
--+=*t---e W
_~
1h t4 Frederick - direct 3451 1
that there was a steam line break?
p 2'
A.
Yes.
We isolated the generator which we 3
suspected was leaking, that is we shut the feed lines going 4
into the generator and the steam lines coming out, to 5
eliminate it as a source of leakage.
So eventually if it 6
did have a leak it would empty out and there would be no 7
more steam leak.
8 Q.
Did isolating the B steam generator have any 9
effect on reactor building pressure?
10 A.
Yes, the pressure began to go down.
11 Q.
Did there come any point in time when you 4
12 believed you might have a primary side to secondary side i
13 leak?
~
14 MR. FISKE:
Your Honor, I think these questions 15 are just a little bit leading.
16 THE COURT:
Yes, I do too.
I sustain that.
17 Q.
'/ hat was happening to the indications of reactor le coolant pump function as the transient progressed?
19 A.
At some point in the transient we began to see 20 reactor coolant system flow degraded, starting to get less 21 and less flow indicated on the graphs on panel 4.
That 22 drew us to examine the other reactor coolant pump operating 23 parameters, and we saw high vibration on the vibration 24 indicators over there by the clock and then we saw the V
25 current indicators, that is the electrical current SOUTHERN DISTRICT REPORTERS.U.S. COURTHOUSE FoLEY SQUARE. NEW YORK. N.Y. - 791.1020
3452 Frederick - direct Ih t4 for the pumps were showing lower than normal
.1 indicators, t
s 2
current flow to the pumps, and I think those were all the
,/
3 indications that we were starting to have a problem with 4
the reactor coolant pumps.
to do if 5
Q.
Had you received any training on what you were getting high vibration on the reactor coolant 6
7 pumps?
8 A.
Yes.
The reactor coolant pump operating in 9
emergencies procedures required that you manually trip the 10 reactor coolant pumps i f you exceed the vibration limits.
11 Q.
Af ter you noted the high vibration on the pumps 12 did you take part in any discussions regarding the 13 condition of the pumps?
U As I remember there were several discussions 14 A.
15 about what action to take as a result of the degraded 16 condition of the pu. ps, and we decided to turn off two 17 pumps to see i f it mtde any difference in the operating characteristics of the pumps that we lef t on.
18 19 Q.
Who was involved in the discussions about what 20 to do with the pumps?
21 A.
Myself and Craig Faust and I think Mr. Zewe and 22 George Kunder.
23 Q.
I'd like to show you what's previously been F-24 marked as B & W Exhibit 261 in evidence as the reactor A-(
25 coolant pump operation procedure.
Was this a procedure SOUTHERN DISTRICT REPORTERS. U.S. COURTHOUSE FOLEY SQUARE. NEW YORK. N.Y. - 7911020
~'
4
.e,w,
. ~ -
lh t4 Frsderick - direct
-3453 1
that was in effect at the time of the accident?
h.
it is.
2 A.
.Yes, _
-3 Q.
When you were having the discussion with others 4
about the status of the reactor coolant pumps, was~any part 5
of this procedure being referred to?
S-A.
The point of concern were the limits that I 7
. described in the section of the procedure called limits and 8
precautions that begin on page 3, and in particular the 9
limits of most concern are listed under -- on page 9 where 10 the limits and precautions are continuing, it says -- 2.4 11 says " reactor coolant pumps must be tripped if," and then 12 it lists the conditions under which you must trip your i
13 reactor coolant pumps.
\\
14 So we were examining what would make us have to 1
I -
15 trip the reactor coolant pumps and see 2.2.4.5 and 2.2.4.8
' ~
16 and 2.2.4.7 are the vibration limits for operation of the 17 pumps.
That's what we were seeing in the meters over by 18 the clock, i
19 Q.
In the training at Babcock & Wilcox had-you 20 gotten any instruction on the reasons why the pumps should 21 be tripped if these vibration limits were exceeded?
22 A.
Excessive vibration of this magnitude causes i
23 damage to the mechanical seals along the shaf t of the pump, f
24 and if you damage those seals you can create a leakage up
-25' along the sha f t of the pump f rom the reactor coolant system.
SOUTHERN DISTRICT REPORTER $.U.S. COURTHOUSE FoLEY $QUARE, NEW YORK. N.Y. - 7911020
(
= a-e e <
.*.a
.u_,,
. ~,.
. ~.
Ih t4 Frederick - direct 3454 1
You also have --
'2 Q.
What happens if that occurs?
3 A.
That's a leak that you can't stop.
It will just 4
leak, even when you cool down, it will still come out, 5
because it is a low point in the system.
Another situation 6
is close tolerances in the motor and the pump shaft 7
themselves.
If you vibrate it excessive you are actually 8
going to damage the bearings in the support of the pump and 9
you could cause pretty good damage to the impeller that way.
10 Q.
What did you understand from your training you 11 should do if any of these vibration limits were exceeded?
12 A.
If you exceed the limits on vibration, you have
{
13 to manually trip the pump.
G' 14 Q.
Would you turn to the chart that is three pages 15 from the back?
16 A.
Yes.
17 Q.
At the time you were discussing the status of 18 the pumps did anybody have out this curve, this set of 19 curves?
20 A.
As I remember it, Mr. Kunder asked me for a copy 21 of this curve so that he could see it while we were 22 discussing the status of the pumps.
23 Q.
Did you give it to Mr. Kunder,7 "1
24 A.
Yes.
'l s) 25 Q.
Did you give anything else to Mr. Kunder?
' SOUTHERN DISTRICT REPORTER $. U.S. COURTHOUSE FoLEY SQUARE. NEW YORK. N.Y. - 7911020
a.
^
--w..
3455 Frederick - direct f
1h t4 r
I think.he also asked me if we had any steam 1
A.
\\vl tables in the. control room, and we didn't actua.lly have a 2
I had the xerox copy of a page or two 3
steam table book, but 4
in the operators' drawer, so I gave him that.
if any understanding did you have as to the 5
Q.
What purpose for which these curves were being consulted?
6 These curves represent an operational limit on 7
A.
-Depending what combination of 8
the reactor coolant pumps.
it gives a net positive suction head 9
pumps you are running for continued operation of the pumps, and Mr. Kunder 10 limit reviewing the 11 was just reviewing -- I assume he was just if we were near that.
12 limit to see 13 THE COURT:
Which was the printout that was 50 (V
degrees high according to certain testimony of Mr. Zewe?
14 think your Honor may be referring 15 MR. FISKE:
I 16 to what is tab 4 in our book which has those --
You remember in the course of THE COURT:
No.
17 18 some examination about Mr. Zewe's handwritten chart Your Honor, there was testimony MR. KLINGSBERG:
-19 recorder before the 20 that if you look at the pressure 21 accident on the strip chart, it looks like it is 50 degrees So at the outset the chart 22 below what would be normal.
23
'might have been --
THE COURT:
High?
24
's-25 MR. KLINGSBERG:
Yes.
I don't remember if it is SOUTHERN DISTRICT REPORTERS.U.S. COURTHOUSE FoLEY SQUARE NEW YORK. N.Y. - 791 1020
- - - - - ~ -
~- _ _ _.. ~,
~~~
~
~ ~ - ~
~,
1h t4 Frederick - direct 3456 1
high or low.
/
2 THE COURT:
High.
As I remember, Mr. Zewe said 3
he was using figures that were 50 degrees higher than they 4
ought to be.
5 MR. KLINGSBERG:
No.
He said that at the 6
beginning of the accident -- before the accident the 7
pressure on the chart was 50 PSIG higher than the normal 8
pressure in the reactor coolant system.
9 THE COURT:
No.
I think the question --
10 MR. KLINGSBERG:
I don' t know that you can infer 11 from that that that continued throughout or not.
It 12 depended on what happened --
l 13 THE COURT:
I understood him to say in response i
14 to some question by Mr. Fiske that the control room 15 operators were aware that this thing was running 50 pounds 16 higher than it actually was.
Isn't that --
17 MR. KLINGSBERG:
I don't think he did, but I'd J
18 have to check.
19 THE COURT:
For a couple of days.
20 MR. KLINGSBERG:
No.
I am not sure of that.
21 MR. FISKE:
Your Honor, there was a question as 22 to whether Mr. Zewe was aware that the day before the l
23 accident it had been determined that the wide range l
l
.l 24 pressure chart was 50 PSIG higher.
^
l
[
(
25 THE COURT:
And he said he was aware of that.
SOUTHERN DISTRICT REPORTERS. U.S. COURTHOUSE FOLEY SQUARE, NEW YORK. N.T. - 791 1020 l
I l
t
'M
1h t4 Frederick - direct 3457 1
MR. SELTZER:
No, he said --
{A.\\
2 MR. FISKE:
He said he didn't know that that had 3
happened.
I believe that was the testimony.
He did know 4
that the wide range pressure chart itself starts on the day 5
of the accident 50 PSIG above what the pressure was.
6 MR. KLINGSBERG:
He said he knows that today, 7
looking at it.
8 BY MR. SELTZER:
9 Q.
After Mr. Kunder had looked at the net po si tive 10 suction head curves for the reactor coolant pumps, did he 11 tell you anything about what he concluded?
12 A.
As best I recall, he just said that we were near 13 the net positive suction head limits for the pumps.
a Whenyoulearnedtpattheplantconditionswere 14 Q.
15 near the net positive suction head curve, did you have any 16 thoughts about whether to turn HPI on or turn it on more?
17 MR. FISKE:
Could I hear that question again?
18 THE COURT:
Before you get to that question, 19 what did you understand was meant by near the net positive 20 suction head limits?
What did that mean to you?
1 21 THE WITNESS:
Referring to this curve, these two 22 lines, number 5 and number 6, represent net positive 23 suction head or operating limits for the reactor coolant 24 pumps, and he said that we were near --
MD',
25 THE COURT:
If you exceeded those, what did you SOUTHERN DISTRICT REPORTER $ U.S. COURTHOUSE FOLEY SQUARE NEW YORK. N.Y. - 7911020 1
3
- - - - ~+.: -
~~ -
--~--
~ ~ ~ ~ -
l 1h t4 Frederick - dirset 3458 1
. understand would happen?
_/
}
( _,/
2 THE WITNESS:
That's when you would start having 3
cavitation of the pump.
Should I explain cavitation?
l 4
THE COURT:
No.
Mr. Zewe explained cavitation.
i 5
THE WITNESS:
Then if you are at or.near this 6
limit, you can expect that cavitation is going to occur or 7
is occurring, depending on the other indications that you 8
have on the panel.
If you are at or near this net po si tive 9
suction head curve and you saw no cavitation and no flow 10 degradation and no amperage change, then you can assume you 11 are not cavitating yet.
If you continue to go beyond the 12 limit, then you eventually will.
~
THE COURT:
Mr. Frederick, did you attribute 13 14 your pump vibration to these factors or what did you 15 attribute them to?
16 THE WITNESS:
Exceeding the net positive suction 17 head?
18 THE COURT:
No.
Being the low pressure, etc.,
i 19
_etc., that you were aware existed, low pressure and lower 20 temperature.
1-i 21 THE WITNESS:
Yes, that's what this limit shows, 22 low pressure.
23 THE COURT:
Is that what you people attributed 24 the pump vibration to?
In other words, you didn't assume 7
\\
/
25 the pumps had decided to pick this moment to become f a ul ty.
v SOUTHERN DISTRICT REPORTERS.U.S. COURTHOUSE FOLEY SQUARE. NEW YORK. N.Y.
J111020
- w-=**
v---w-
,,w
Ih t4 Frederick - direct 3459 You attributed their problem to something else, did you not?
1 2
THE WITNESS:
Tha t's right.
(_,
3 THE COURT:
What did you attribute their problem 4
to?
5 THE WITNESS:
Being at or near this net po si tive 6
suction head limit, that is the pressure limit at the 7
suction of the pump.
8 THE COURT:
Then did you have any discussion as 9
to why you were at that limit?
10 THE WITNESS:
The question of pressure control 11 had been something we were discussing all along.
This was 12 just the result of the the low pressure.
N 13 THE COURT:
I understand, but if you are at --
14 this is, what, about an hour and 15 minutes, 13 minutes, 15 because you shortly stopped the pumps, right?
16 MR. SELTZER:
Two of the p' umps.
17 THE CO'URT:
Two of them?
We are talking an hour 18 or an hour and 15 minutes, right?
19 THE WITNESS:- Yes.
20 THE COURT:
At that point the pressure in the 21 system is about 1100 and the temperature is about 545.
22 Were you saying to yourself, "Why have we got those 23 pressures and why have we got those temperatures?"
24 THE WITNESS:
Yes.
s Y
25 THE COURT:
What kind of answers were you coming
- q,/
$OUTHERN DISTRICT REPORTER $.U.S. COUR HOUSE FOLEY $QUARE. NEW YORK. N.Y. - 791 1020
Jh t4 Froderick - direct 3460 1
up with, if any?
77-~
2 THE WITNESS:
We had attributed our lack of
)
- s__,
As we were trying 3
pressure control to several conditions.
to analyze what that problem was, the pressurizer heaters, 4
5 perhaps -- originally it was the insurge of water, cold water to the pressurizer, and we had the consideration of 6
7 insufficient heater capacity or failed heaters, which was 8
one of the things that Mr. Zewe investigated.
9 THE COURT:
He found they hadn't failed, right?
10 THE WITNESS:
As I recall now, I think the Il testimony shows what he found when he went out there.
So we had attributed lack of pressure control to things like 1.
13 that.
There we were with low pressure and it was beginning
~J 14 to have an ef fect on the components, that is the reactor So now we did have low pressure up to this 15 coolant pumps.
16 time and now we are beginning to see that low pressure is 17 af fecting these components, the reactor coolant pumps.
18 THE COURT:
You say you attributed the low fact that the pressure to the adding of the water and the 19 20 pressurizer heaters weren't working, is that what you are 21 telling me?
22 THE WITNESS:
At first we thoughtsit was the 23 water.
Il 24 THE COURT:
Then you decided it wasn't?
'pg We decided it was probably --
25 THE WITNESS:
(,,) -
SOUTHERN DISTRICT REPORTERS.U.S. COURTHOUSE FoLEY SQUARE. NEW YORK. N.Y. - 791-1020
- - ~ - - - - - -
lh t4 Frsdorick - direct 3461 9
1 since it was taking so long to get the pressure back, it
("'h 2
might be the capacity of the heaters was insufficient or (s,,)
3 that some of them wasn't working, so that was investigated.
4 THE COURT:
What did you learn from that 5
investigation.
6 THE WITNESS:
Eventually we learned that the 7
pressurizer heaters were working -- pressurizer heaters 8
were working properly, that I can recall.
9 THE COURT:
Was that before the time you are now 10 sitting around discussing the fact that you are near the 11 point of minimum net positive suction head limits on the 12 pumps?, Was it before that time?
13 THE WITNESS:
No, I don't think so.
14 THE COURT:
You think i t was af ter that time?
15 THE WITNESS:
The determination about whether 16 the pressurizer --
17 THE COURT:
About the heat, yes.
/
18 TH,E WITNESS:
I know that determination wasn't 19 made -- when Mr. Zewe came back to the control room we 20 still hadn't figured that out.
It was sometime later that 21 that decision was made, that the heaters were working right.
22 I don't know how that ties in to this time frame, whether 23 that was at this time or later.
24 THE COURT:
What I am trying to get at is, you 25 are sitting here at roughly 5 o' clock or 5:15, you have got SOUTHERN DISTRICT REPORTERS.U.S. COURTHOUSE FOLEY SQUARE. NEW YORK. N.Y. - 791 1020 f
b_.%_-.-p w
4 g
y p
9 9
.. ~.
Ih t4 Frederick - direct 3462 1
pressure at 3100, you have got temperature at 545, you have
-y 2
got a pressurizer that's up at 375, 80, 90 inches, and you s_-
3 have pumps that are starting to malfunction because they 4
aren't pumping, they don't have enough product to pump; 5
right?
6 THE WITNESS:
No, there is plenty of product, 7
there is plenty of water in the system.
The pressurizer is e
full.
9 THE COURT:
I understand, but they are down to 4
10 this point where you are starting to have the risk of 11 cavitation, which I gather, without getting into too much 12 detail, is that steam bubbles are going to start forming in
[
13 the pumps, right?
\\
14 THE WITNESS:
Yes.
It is a long term corrosion 15 type problem.
You don't want it to exist for very long.
16 THE COURT:
The flow through the pumps is slowed 17 way down.
18 THE WITNESS:
The flow was degraded.
I don't 19 remember to what degree.
20 THE COURT:
So what are you people saying to 21 yourself is causi,ng this, because you added water, as I 22 recall it
.I 23 THE WITNESS:
There is plenty of water.
.r1 24 THE COURT:
You had the manual HPI, you have the l
l l
\\s_,/
25 automatic HPI, you have added water and presumably _you
[
soumERN DISWCT REPORTERS.U.S. COURTHOUSE j_l FoLEY SQUARE. NEW YORK. N.Y. - 791 1020
~
~
.---,-,.4
1e-,
lh t4 Frederick - direct 3463 1
haven't lost any water, and yet these pumps all of a sudden
\\/
2 are starting to shake themselves off their bearings to the 3
point where you have got to close them down or you are 4
risking cracking the pipes and having major leaks at the 5
bottom of the system that you can' t do anything about.
6 What are you saying to yourself about how come 7
with this system full of water, no leaks, sound system, no 9
LOCA's, what are you saying to yourself explains all of 9
this?
10 THE WITNESS:
The inventory of water in the 11 system is completely independent from the cavitation 12 process.
You wouldn't have to lose inventory in order to 13 have cavitation.
So that the fact that the system is full, d
14 the only problem you have is that the pressure is low and 15 you are approaching the cavitation limit on the pump.
16 THE COURT:
Why should pressure be low if you 17 have a sound system?
18 THE WITNESS:
We were trying to analyze that.
19 We were trying to figure out why pressure was low.
We just 20 hadn't determined that --
21 THE COURT:
Theoretically if you had a sound 22 system you wouldn't have low pressure, would you?
23 THE WITNESS:
A sound system meaning no leaks?
-/~
24 THE COURT:
Yes, meaning no leaks.
i 7
l-
)
25 THE WITNESS:
Leaks or no leaks does not
,G SOUTHERN DISTRICT REPORTERS. UJ5. COURTHOUSE FoLEY SQUARE. NEW YORK. N.Y. - 791-1020 k
$h.
y wm-w
.y y,
r--w--r e
p-g a.-
- + - - -
y-p-e-we ----
w-
1h t4 Frederick - direct 3464 1
determine the system pressure.
System pressure is normally y-.,
s_ /
2 determined by the pressurizer status.
That is the heaters --
3 you can have a full system, 220 inches in the pressurizer, 4
with heaters on and have a very low pressure or you can 5
have a very high pressure, depending on what the set po in t 6
of the heaters is.
You can control pressure at any level, i
7 whether the system is full or at normal level or a littic 8
bit higher, or whatever.
9 THE COURT:
I take it you had your heaters I
10 running to the maximum allowed by the system, did you not, given the fact that you were concerned with all of this 11 12 cold water?
i 13 THE WITNESS:
Yes.
We had the heaters turned on s
14 and we were investigating whether or not they were working.
15 THE COURT:
So it wasn't a question of not putting -- or was it a question that you felt you weren' t 16 17 adding enough heat?
18 THE WITNESS:
That was one of the considerations, 19 the capacity of the heaters as a heating capacity was 20 probably insufficient.
21 THE COURT:
What were the other considerations 22 THE WITNESS:
If if it is not capacity, then it 23 is the number of heaters that were operating.
El 24 THE COURT:
What were other considerations that
'V) 25 would account for this rather unusual accumulation of
- s SOUTHERN DISTRICT REPORTERS.U.S. COURTHOUSE i
FOLEY SQUARE. NEW YORK. N.Y. - 791-1020 I
l
.,____,j i
4 1h t4 Frederick - direct 3465 1
circumstances, if I can call it that?
/
\\
(,)
2 THE WITNESS:
That was, indeed, the crux of the 3
problem.
We had no conditions in the plant a f ter our final 4
investigation that would cause low pressure, but in fact we 1
5 had low pressure.
How do you remedy a situa t '.on for which 6
there is no reason?
That was our problem.
Low pressure 7
with no apparent reason.
8 THE COURT:
So when you have no apparent reason, l
9 what do you start thinking might be the reason?
What are l
10 the things that you would tick off on your finger that 11 would cause low pfessure?
12 THE WITNESS:
We had examined the steam leak and 13 found that there was a steam leak.
That is a source of low 14 pressure.
15 THE COURT:
That would account for the water in 16 the sump, but that was not a loss from the reactor coolant 17 system, right?
That was a loss from the secondary system.
19 THE WITNESS:
Yes, but one of the symptoms of a 19 steam leak is low pressure in the reactor coolant system.
20 Remember I said that the symptoms of a steam leak and a 21 LOCA are just about the same, low pressure, low level, that 22 sort of thing.
So we were examining steam leak as a 23 possibility for a large number of th'e symptoms that we were 24 seeing.
We had eliminated that and waited to see if it
,r
/(
25 affected all of those parameters.
SOUTHERN DISTRICT REPORTERS U.S. COURTHOUSE FO!.EY SQUARE, NEW YORK. N.Y. - 7911020
^
~ ~^
~ Z Tii__ __ __ _________ ___. ____ _~_ _ 1- -
~~
- - - ~
~ '~
^
m
I 1h t4 Frederick - direct 3466 l
In the course of waiting for these things that 1
2 we tried, that is pressurizer heaters we were investigating, 3
we were trying to see what ef fect the steam generator change had on it and then these problems with the pumps 4
5 develops, so that not knowing the cause for the low 6
pressure does not tell you that you shouldn't take the 7
action based on the indications of the pump.
8 We had low pressure.
The pumps were starting to 9
shake badly.
You have to turn them off whether you know 10 what is causing the low pressure or not because the 11 condition --
12 THE COURT:
I appreciate all of that.
What I am y
13 trying to ascertain, Mr. Frederick, is, what was the
}
individual and collective thinking of you men as you looked 14 15 at this array of disorganization, if I can put it that way?
16 What were you saying to yourself?
I can just imagine some 17 of the language that was flying around in that control room 10 at 5:10 in the morning, if I put my mind to it.
19 THE WITNESS:
Actually, the state of the
~
at that time.
It 20 operators was rather calm and analytical 21 wasn' t a state of panic.
What we had was a relatively 22 stable situation with low pressure.
The instability occurs 23 or the concern starts to occur when we have to secure the l
.24 reactor coolant pumps and lose our flow and move to a s,/.
25 situation --
m SOUTHERN DISTRICT REPORTERS.U.S. COURTHOUSE FOLEY SQUARE. NEW YORK. N.Y. - 791 1020
'Y~~'
W-t-.-
I h t'4 Frederick - direct 3467 1
THE COURT:
And that's what you were looking at 1(
2 right at that moment?
3 THE WITNESS:
Yes, that's right.
4 THE COURT:
You were faced with the problem of 5
shutting down the pumps with a sump full of water and a 6
pressurizer level that was up at the top.
7 THE WITNESS:
Way at the top, yes.
8 THE COURT:
And 1 assume some awareness of 9
possible saturation?
10 THE WITNESS:
No, sir.
11 THE COURT:
No?
No awareness of possible 12 saturation?
13 THE WITNESS:
Saturation has no significance.
{"
V 14 THE COURT:
I mean somebody had asked for the 15 steam tables, right?
16 THE WITNESS:
In an effort to examine net 17 positive suction head of the pumps.
18 THE COURT:
But if you are going to have that in 19 the pumps, you are not far away from saturation in the 20 system, are you?
21 THE WITNESS:
It is a long way from cavitation 22 to saturation of the system, if'there is no consideration i
23 that saturation in the system can occur.
The situation of 24 cavitation in'the reactor coolant pumps is not a logical
-.%(v 25 premise to saturation in the reactor coolant system.
It is SOUTHERN DISTRICT REPORTERS.U.S. COURTHOUSE FOL2Y SQUARE NEW YORK. N.Y. - 791-1020
~, _ _ _ -
.. _ _ _ ~..
--d w-
i-I 1h't4 Frederick - direct 3468 1
neither a point in training nor mentioned in any of the r-s 2
procedures as being a signi'ficant event.
Therefore, why s_s 3
conclude that that is occurring or it is even a significant 4
possibility?
5 THE COURT:
Let me ask you this.
Were you ever 5
given any instruction on what saturation in a reactor 7
coolant system is or means?
8 THE WITNESS:
As a control room operator?
9 THE COURT:
Yes.
10 THE WITNESS:
What does it mean to me?
11 THE COURT:
No.
Were you ever given any 12 training?
In the course of any training, Met Ed, B& W, CG 13 Navy, were you ever told that you were not to permit the 14 system itself to get boiling?
15 THE WITNESS:
No, sir.
That's a function of the 16 design of the system and not an operator action.
There is 17 no procedure or step that says prevent saturation.
It IS doesn't tell you to do that.
19 THE COURT:
I know there isn't, there doesn't 20 appear.to be, but didn't you at some point somewhere along 21 the way learn that there is a certain point where if the temperature is high and the pressure drops low enough, you 22 23 will have boiling in your reactor coolant system?
You had rl 24 an awareness that that could occur at some relationship of l'%.*
j 25 the temperature to the pressure, correct?
\\,,)
SOUTHERN DISTRICT REPORTERS.U.S. COURTHOUSE FOLEY SQUARE. NEW YORK. N.Y. - 191 1020 I
lh t4 Frederick - direct 3469 1
THE WITNESS:
The only context of boiling that
(~~')
\\s -
2 we had was the latter stages of an MHA type LOCA where the system is' evacuated of inventory and begins to overheat the 3
4 core, where you have' steam production which leaves the 5
system through the leak.
6 THE COURT:
Did you never learn of a relationship of -- does the word saturation mean something 7
8 to you?
9 THE WITNESS:
Yes, sir.
I know the precise 10 definition of the term.
11 THE COURT:
What does it mean?
12 THE WITNESS:
Saturation is the pressure and 13 temperature relationship at which a fluid can exist as a 14 liquid or a vapor.
15 THE COURT:
Did you ever get any instruction on 16 that in relation to the inventory of the reactor coolant 17 system?
18 THE WITNESS:
No, sir.
19 THE COURT:
And you are saying that at roughly 5 o' clock t'o 5:15 with the pumps now f acing the necessity of 20 21 shutdown, your thought was this was -- you tell me again so 22 I have got your actual thinking.
What were you visualizing 23 as the cause of the situation in which you found yourself 5 i
24 o' clock to 5:15 with the pumps malfunctioning.
~
\\_,)
25 THE WITNESS:
The situa tion we were in was a soumERN DISTRICT REPORTERS,U.S. CoURWoUSE FoLEY SQUARE. NEW YORK. N.Y. - 791 1020
.. _ ~
lh t4 Frederick - direct 34'70 1
condition which low pressure existed in the reactor coolant
[/}
y 2
system and we were beginning to encroach on the net 3
positive suction head of the pumps and we had to shut them 4
down due to high vibration.
5 THE COURT:
But did you have any answers to the G
"why"?
7 THE WITNESS:
Only the several avenues that we 9
were examining, pressurizer heater failure or ste9m leak 9
that we were piling up somewhere --
10 THE COURT:
Steam leaks from pipes on the 11 secondary side?
12 THE WITNESS:
Yes, a steam leak in the secondary 13 system, actually from the steam generator, inside the 14 reactor building.
15 THE COURT:
Counsel, it is 2 minutes of 1.
16 Let's recess until a quarter past 2.
17 (Luncheon recess.)
18 19 20 21 22 23 r1 24 d
i 25 SOUTHERN DISTRICT REPORTERS, U.S. COURTHOUSE FoLEY SQUARE. NEW YORK. N.Y. - 791-1020
jbp t5 Frederick-direct 3471 1
P.
M.
SESSION 2
(2:15 p.m.)
[]
3 (Open court) 4 DIRECT EXAMINATION (Cont'd) 5 BY MR. SELTZER:.
6 Q.
Mr. Frederick, Mr. Zewe and possibly others have 7
already explained what is cavitation, so I don't want you 8
to give a long description of it.
9 Can you give a very specific description of what 10 you understood constituted cavitation prior to the accident?
I 11 A.
Cavitation is the formation of vapor bubbles in 12 the suction of the pump and the subsequent collapse of l
13 those pumps in the~ water and the discharge of vapor in the
}
14 impeller veins.
,j 15 Q.
What did you understand before the accident was 16 the condition of the water outside the pump if cavitation 17 was going on inside the pump?
18 A.
If cavitation is occurring, then the process 19 itself assumes that the suction of the pump and the 20 discharge of the pump are both filled with fluid, that'is a 21 liquid, water.
If'you have vapor bubbles forming in the 22 water and then subsequently collapsing in the water, that's 23 what causes the vibration and the erosion of the impeller 24 blades.
25
~
Q.
Why did you understand that there had to be t]
\\
SOUTHERN DISTRICT REPORTERS, U.S. COURTHOUSE FoLEY SQUARE NEW YORK. N.Y. - 791 1020 C
m___ _ _ _ _. _.
_._m
jbp tS Frederick-direct 3472 1
liquid water both on the suction side and the discharge p
if there was cavitation going on in the pump?
(v) 2 side 3
A.
I guess the basic process of cavitation says to the that you have the liqu.id being drawn in and exposed 4
5 low pressure at the eye of the pump and that causes 6
formation of bubbles in the liquid.
Bubbles travel along 7
the veins to the discharge of the pump and then they 8
collapse in the water and that shock wave causes erosion 9
and vibration in the pump impeller.
10 0
What, if anything, did you understand caused the 11 bubbles to collapse?
32 A.
They collapsed at the discharge of the pump 13 because that is the highest pressure that is developed by
= s i i
'V) 14 the pump at the tips of the impeller blades.
When that is forced on the vapor bubbles, they collapse on 15 pressure 16 the liquid and cause a small implosion.
17 THE COURT:
What do you understand permits 18 cavitation in the first place?
19 THE WITNESS:
Inadequate net positive suction 20 head.
21 THE COURT:
What does that mean?
22 THE WITNESS:
It means that the static pre'ssure 23 applied to the suction of the pump is insufficient to 24 prevent the formation of the vapor bubbles when the pump is a
/
3 25 running.
k SOUTHERN DISTRICT REPORTERS.U.S. COURTHOUSE FoLEY SQUARE, NEW' YORK. N.Y. - 791 1020 I-
~...- _, _
Js
jbp t5 Frsderick-direct 3473 1
THE COURT:
So, in other words, low pressure.
^')
2 Is it the combination of pressure and x, /
3 temperature or just low pressure?
4 THE WITNESS:
It is static pressure or head 5
measured in feet.
G THE COURT:
Well, is there a relationship 7
between temperature and pressure that permits this, that's 8
really what I am asking you?
9 THE WITNESS:
The primary way to prevent it is 10 pressure.
The mechanism that is occurring is a combination 11 of low pressure and the same pressure it was before it 12 entered the pump.
The pressure is decreased below the g;
13 saturation point for the water at the eye of the pump.
I(,)\\
14 THE COURT:
Well, as I understand, this can 15 occur at differing temperatures depending upon the pressure, 16 is that correct?
17 THE WITNESS:
If you understand it from this 18 curve, it means that it can occur depending upon the number 19 of pumps that are running, the combination of whether they 20 are both in the same loop or in different loops and as a 21 result of pressure at the eye 22 THE COURT:
And temperature?
23 THE WITNESS:
Yes.
It can occur at different 24 temperatures.
But this doesn't follow through that way for
/
,("'}
25 the entire curve.
You see it flattens out at the bottom.
V SOUTHERN DISTRICT REPORTERS. U.S. COURTHOUSE FOLEY SQUARE. NEW YORK. N.Y. - 791.1020 e
-M>
f 1r
--tgy-e er eimg e.-,
>P
,e
~.
jbp t5 Frsderick-direct 3474 That's the different consideration for the pump operation.
1
/
h 2
It is not a direct pressure / temperature relationship.
It m
3 has to do with the elevation in the pipes as well because 4
just the difference of the height of the water creates 5
pressure in itself.
6 THE COURT:
Just a minute now.
7 THE WITNESS:
You see in other systems, we have 8
the same problem, cavitation and the way we prevent the cavitation is by elevating the source of water above 9
10 pump, that applies a certain amount of pressure in the 11 suction.
You could have a very cold water refrigeration 12 system, it could cavitate.
It is due to the suction 13 pressure applied to the pump.
g3
\\s_s/
14 It is a situation which can occur in a very cold 15 system or a very hot system.
It is mostly dependent upon 16 the head that you supply to the pump.
17 THE COURT:
If you take --
18 THE WITNESS:
Any centrifugal pump can cavitate.
I 19 THE COURT:
If you would take your chart.
20 If you are running 545 say at 1100, you are 21 right up here, right?
22 THE WITNESS:
Yes.
23 THE COURT:
Now, you are on the wrong side of 24 what would be an extension of this dotted line; is that
![ Yl 25 right?
V SOUTHERN DISTRICT REPORTERS. U.S. COURTHOUSE f'
FOLEY SQUARE. NEW YORK. N.Y. - 791-1020 1
^
jbp t5 Frederick-direct 3475 1
The dotted line is for single pump and this fine
,/ m 2
is for two pumps, as I understand it?
3 THE WITNESS:
This is 4
THE COURT:
This is the two pumps?
5 THE WITNESS:
This is one pump in each loop and 6
this is two pumps in one loop.
7 THE COURT:
So if you are running a 545 or 550 8
at 1100, you are then on the wrong side of either of those, 9
are you not?
10 THE WITNESS:
Yes.
11 THE COURT:
And you should be on the other side s
12 of them to avoid that problem?
13 THE WITNESS:
To avoid the cavitation?
(,,, '
(
14 THE COURT:
Right.
_j 15 THE WITNESS:
Yes.
16 Q.
What relationship, if any, did you understand 17 the net positive suction head curve had to the occurrence 18 of saturation in'the reactor coolant system outside the 19 pumps?
20 A.
There is no relationship involved between the 21 net positive suction head curve which was a graphic j
22 representation of a localized occurrence inside the reactor 23 coolant pump.
There is no relationship between that and 24 the entir'e system as a whole.
r
'Sf 25 Q.
Did you.get any instruction from B & W, the navy s/
m
{
SOUTHERN DISTRICT REPORTERS.U.S. COURTHOUSE FOLEY SQUARE. NEW YORK. N.Y. - 791 1020
,. ~
~. -
- - ~ ~ - -
~~~~
~ ~ -. - - -
- -- ~
.. L
~
~
jbp t5 Frsderick-direct 3476
- 1 or Metropolitan Edison or anybody else about whether
(-
2 detecting -- withdrawn.
3 Did you get any instruction from anyone, B&W, 4
- the navy, Met Ed that by looking at the net positive 5
suction head curve and seeing where the plant was in 6-relation to the NPSH curve you could detect saturation in 7
8 A.
No.
9 Q.
After you turned off the first set of reactor 10 coolant pumps, what happened to the remaining two pumps?
4 11 A.
We left them running for awhile and monitored 12 their condition to see if it improved as a result of T
13 turning off the first two pumps; to see if the vibration x-14 was reduced or the flow had better characteristics.
15 Q.
Did there come a time when you -- withdrawn.
16 Were you monitoring boron concentration in the 17 reactor coolant system during the transient?
18 A.
We did draw some boron samples during the 19 morning.
20 Q.
What, if anything, did you observe happening 21 with boron concentration?
22 A.
The analysis that the chemist brought back showed that the boron concentration had been drastically 23 24 reduced.
L i
s 25 Q.
What action did you take in response to the low h
a SOUTHERN DISTRICT REPORTERS,U.S. COURTHOUSE FoLEY SQUARE. NEW YORK. N.Y. - 791 1020
- ++en-a-e-..
s
-. - % we,
.,,,,2,.
...g._
. L. -.
jbp t5 Frederick-direct 3477 1
levels of boron concentration?
2 A.
After the second sample, I believe we began a
3 emergency boration, that is, addition of highly 4
concentrated boric acid to the reactor coolant system to 5
raise the total concentration back to where it should have 6
been.
7 Q.
Where did you get the boric acid from?
8 A.
The boric acid is added from the boric acid mix 9
tank which is a special tank in the auxiliary building and we used two pumps which are specifically identified for the 10 11 purpose of adding highly concentrated boric acid.
So all 12 we had to do was start the pumps in automatic.
m 13 Q.
Is this boric acid mix tank the same tank as the 14 borated water storage tank from which you said HPI is 15 pulled when you have a full actuation of HPI?
15 A.
No.
17 The borated water storage tank is a different 18 tank located outside the building.
This tank I am 19 referring to now, the boric acid mix tank, is a much 20 smaller tank located inside the storage building where we 21
' store highly concentrated boric acid.
22 Q.
When you were adding boron to increase the level 23 of concentration, what was the rate of flow?
24 MR. FISKE:
Excuse me.
Could I have that 25 question clarified?
SOUTHERN DISTRICT REPORTERS.U.S. COURTHOUSE FOLEY SQUARE, NEW YORK. N.Y. - 791-1020 W
.y-g..
y
jbp t5 Frsderick-direct 3478 1
Flow of what?
2 MR. SELTZER:
The flow from the boric acid mix M
3' tank, the flow of the fluid you were withdrawing from that 4
tank?
5 MR. FISKE:
The flow into the systen?
6 MR. SELTZER:
Into the reactor coolant system.
~
7 A.
The boric acid pumps put the water into the 8
system at the rate of about 10 or 20 gallons per minute, I 9
think.
10 Q.
Why were you concerned about the level of 11 boration?
s 12 A.
When the reactor is shutdown, that is, the 13 control rods ar.e inserted after the reactor trip, the boric (A:b l
v/
14 acid concentration in the reactor coolant system is the I
15 only variable then in how to add more shutdown capability 16 to the reactor, keep it in a shutdown state.
17 The depletion or the reduction in the boron or 18 boric acid concentration indicates that positive reactivity 19 or startup potential is being added to the reactor core.
l 20 So it is going to restart to get a sufficient amount of 21 positive reactivity added.
So that decrease in boric acid 22 is moving as closer to a startup state with the reactor.
23 It is going to be starting nuclear heat again.
24 Q.
You mean it is going to go critical?
I
[N 25 A.
Yes.
SOUTHERN DISTRICT REPORTERS. U.S. COURTHOUSE FOLEY SQUARE. NEW YORK. N.Y. - 791.1020
^
~* -
m
____________OQ_
3479 jbp t5 Frsderick-direct 1
Q.
What is the source range monitor?
m The source range monitor is a neutron count 2
A.
indicator that monitors the level of operation of the 3
4 nuclear core.
5 Q.
Did there come a time when you observed the 6
source range monitor?
7 A.
Yes.
8 At about the same time that we received the low 9
boron concentration reports we examined the source range 10 indicators and saw an increase in count rate, which 11 indicates a startup of the reactor.
12 Q.
What did you think was happening when you saw 13 the level going up on the source range monitor?
{s)
\\_ /
14 A.
Well, the source range indicator was increasing 15 because the boric acid had been removed and we were 16 observing a spontaneous or inadvertent restart of the 17 reactor.
18 Q.
Did you have procedures that covered such an 19 unanticipated approach to startup of the reactor or 20 recriticality?
21 A.
Yes, we did.
22 There is an emergency procedure which you use 23 when you identify that a restart is occurring.
It is 24 called unanticipated criticality.
And the manual action is
[
/
25 to do what I did.
I started adding boric acid to the s- -
SOUTHERN DISTRICT REPORTER $.U.S. COURTHOUSE FoLEY SQUARE. NEW YoKK. N.Y. - 7911020
--y 7
y
,r_g
jbp t5 Frederick-direct 3480 1
system in a highly concentrated form.
,7 2
Q.
You described a moment ago the process that led
(}
3 to tripping two of the four reactor coolant pumps.
4 At some point were the other two tripped?
5 A.
Yes.
6 Sometime later the vibration, flow degradation 7
and amperage condition was still suf ficiently bad that we 8
had to secure the last two reactor coolant pumps as well.
9 Q.
Up until the time when you secured or shut off 10 the last two reactor coolant pumps, you had a forced flow 11 of coolant water around the core.
12 What, if any, flow did you understand would be l
m 13 maintained after you shut off the last two reactor coolant C' -
14 pumps?
15 A.
The flow would initially go to zero"."
There 16 would be no flow.
Then if we could establish natural 17 circulation flow, I really didn't know what the rate would 18 be but it would be some slower rate than normal.
19 Q.
Can you succinctly state what your understanding 20 was of natural circulation?
Just what is it?
21 A.
That the circulation is movement of the water 22 through the reactor coolant system which is motivated only 23 by the conductive flow of water from the less dense high 24 elevations or where warm water would exist, and when you
_)
[
'u 25 have colder water in the lower elevations or in the steam
\\vl SOUTHERN DISTRICT REPORTERS. U.S. COURTHOUSE FOLEY SQUARE. NEW YORK. N.Y. - 791 1020 l
'jbp t5 Frederick-direct 3481 1
generator, that colder water would move down into the core
(- y) 2 and displace water out of the core and into the steam g%)
3 generators where it would be cool.
4 So this conductive flow would exist just due to 5
a change in temperature across the steam generator with no I
6 pumps running.
i 7
Q.
After you shut off the last two reactor coolant 8
pumps, what indications did you expect to see, if any, that 9
natural circulation flow to have been established?
j 10 A.
Well, there really weren't any guidelines on i
11 what you would see or how long it would take to you see the 12 change in parameters due to natural circulation.
But I 13 knew there should be a difference in temperature between ps 14 the hot region of the piping and the cold region and there s_s j
15 is -- that's called the delta T or the dif ferential 16 temperature.
4 17 There is a procedure that we had for natural i
18 circulation after blackout which gave a limit to that l
19 differential temperature and that's what we had to go by.
I 20 We were supposed to develop that maximum f
21 differential temperature and hold the steam generator 22 levels at a high level so we could have heat removed by the 1
23 water -- through the water that is adjacent to those steam t
24 generator tubes and that would initiate and sustain the 25 natural circulation state.
SOUTHERN DISTRICT REPORTERS.U.S. COURTHOUSE l
FOLEY SQUARE, NEW YORK. N.Y. - 791 1020
... - ~...,
jbp t5 Frsdorick-direct 3482 1
Q.
Did you know how long it would take before the
(Ti 2
temperature dif ferential between the hot legs and the cold
- d 3
legs had increased to the level that would be sustained 4
during natural circulation?
5 A.
Did I know the time how long it would take?
6 Q.
Yes.
7 A.
I didn't know how long it would take.
8 Q.
Was there -- withdrawn.
9 What was the next action that was taken with 10 respect to the reactor coolant pumps?
11 A.
Some. long while later when we decided that 12 natural circulation had not occurred we started or tried to i
13 restart the reactor coolant pumps.in an effort to start 14 forced circulation because we didn't have any circulation.
~-
15 at all.
16 Q.
Were you able to restart one or more of the 17 reactor coolant pumps?
18 A.
We couldn't get any of the reactor coolant pumps 19 to indicate that they were running when we turned the 20 switches.
21 I know that post-accident data shows that one of 22 them did start but we had no indication that it was 23 operating, other than that the red light changed position, 24 but there was no flow or anything like that.
I O[
sY 25 Q.
Did you form any understanding as to why the SOUTUERN DISTRICT REPORTERS. U.S. COURTHOUSE FOLEY SQUARE. NEW YORK. N.Y. - 791-1020
- n*
w ep.,eue e
jbp t5 Fredericx-direct 3483 1
pumps were apparently not restarting?
2 A.
There are a lot of interlocks or special (m
\\
3 conditions that must be met before you could start a 4
reactor coolant pump, about 13 or 15 of chem, and it was my 5
understanding that we weren't meeting all of the 6
prerequisites for a manual startup reactor coolant pump.
7 We had to go through each interlock separately and clear it 8
and set up the prerequisites for the startup before they 9
would start successfully.
10 Q.
Did there come a time when the pilot-operated 11 relief valve block valve was closed?
12 A.
Yes.
13 Q.
What, if anything, was your understanding as to
(,
14 the circumstances that led to that?
15 A.
There was a suggestion by the supervisors to 16 shut 17 MR. FISKE:
I have no problem with any of this 18 as long as Mr. Frederick 19 THE COURT:
It is direct evidence.
20 MR. FISKE:
If we're letting in something that 21 he knew was happening at the time.
22 THE COURT:
Would you phrase your question in 23 the kind of way that would elicit that kind of 24 understanding?
- /" 'N 25 Q.
What did you see and what did you personally V
SOUTHERN DISTRICT REPORTERS. U1 COURTHOUSE FOLEY SQUARE, NEW YORK. N.Y. - 791 1020
,,f_
jbp t5 Frederick-direct 3404 1
hear regarding the closing of the block valve?
- ['"~Q 2
Just your personal experience that day.
V 3
A.
Okay.
4 While we were stationed at the panel, Mr. Mehler, 5
Brian Mehler who is a shift supervisor, approached the 6
panel and began conversation with Mr. Scheiman and myself.
7 He said.that it was suggested that we try closing the PORV 8
block valve to see if it has any result or any change of 9
indications in the reactor coolant system parameters and 10 Mr. Schelman closed the block valve.
11 0
What, if any, consequences did you see as a N
12 result of the block valve being shut?
i i
.13 A.
After the PORV block valve was shut, the system J
. ( _,/
14 pressure began to increase, the reactor coolant systen 15 pressure began to increase.
16 Q.
When you saw that, did you have any thoughts 17 about whether the pilot-operated relief valve had been 18 opened prior to the block valve being shut?
19 A.
Whether it was at that moment or not, I don't 20 know.
But I began to think about the consequences of, 21 perhaps, it being partially opened or. fully opened for that 22 entire time since the trip began and I tried to add that 23 information into our analysis of the transient so far and 24 figure out how-it had influenced the parameters' I
J
( N 25 indications.
SOUTHERN DISTRIC1 REPORTERS.U.S. COURTHOUSE j
FoLEY SQUARE. NEW YORK. N Y. - 791-1020
.- -,+
.,,,,,,n-
-.9,
n_.
jbp t5 FrGderick-direct 3485 1
Q.
What, if any, indications did you have at that 2
point in time as to the inventory in the reactor coolant 3
system?
4 A.
As I remember, the inventory was still
~
indicating that the system was full, overfull, actually.
5 6
Q.
How were you interpreting that?
7 A.
By pressurizer level.
withdrawn.
8 Q.
At or about 9
Were you still the operator who was in charge of 10 the controls on the primary side of the panel?
11 A.
Yes, I was.
Mr. Scheiman was assisting me in 12 monitoring some of the primary, keeping me informed of 13 trends.
\\
- 14 Q.
At the point where the block valve was closed, 15 did you consider ~st that time turning on high pressure 16 injection?
17 A.
I don't recall considering it.
18 Q.
You mentioned this morning the absence of
-19 radiation alarms when you had high reactor building 20 pressure.
21 Were you continuing throughout the transient to 22 look for radiation alarms?
23 A.
Yes.
24 We were checking the the whole panel for 25 additional information that could help us analyze the v'
li SOUTHERN DISTRICT REPORTERS.U.S. COURTHOUSE FoLEY SQUARE. NEW YORK. N.Y. - 791 1020 Wus m '
- =ge empm(m ee4a.eweeag=--
--_gamew 4
P=
- emm>W+
9-
-4 g= y
_-e=w
-m - hwe-.
b O+__
jbp t5 Frederick-direct 3486 1
situation, additional alarms, exhibited on panel 12 right O
2 in the center of the room, and that we looked at quite g
3 often.
4 Q.
Did there come a point in time during the 5
accident when you did receive radiation alarms?
6 A.
Yes.
7 Q.
When did you first notice radiation alarms?
8 A.
It was right around the time when we declared a 9
site emergency shortly af ter attempting to start the 10 reactor coolant pumps.
Somewhere around there.
11 Q.
You say it was shortly before a site emergency 12 was declared?
i 13 A.
Yes, as I reme[nber.
3 b
d 14 Q.
So --
15 MR. SELTZER:
If your Honor please, I think the 16 record showed that that was at about 7: 30 in the morning.
17 I won't ask this witness for his recollection as to 18 precisely what was that emergency.
19 Q.
Prior to receiving those radiation indications, 20 did you have any thoughts about whether there had been 21 radiation released into the containment building?
22 A.
I remember scanning the panel looking for 23-indications of radiation,and not seeing them.
24 So what I was looking for was indications of
/]7 25 just that nature.
I didn't see any.
G SOUTHERN DISTRICT REPORTERS.U.S. COURTHOUSE FOLEY SQUARE. NEW YORK. N.Y. - 791-1020
_ +,
e
-w-=*e-
-%we
. +.
p
-.~#.
- - - + < -
w W
g 7
w-
-g,
,-.w m--
wy gy--
--w y
-u-
- = m
3487 jbp t5 Frcderick-direct 1
0 Before you got those indications, just before 2
the site emergency was declared, had you received any kind
(%
3 of radiation alarm, whether in the reactor building or 4
elsewhere?
5 A.
I don't recall the inception of the alarm but we 5
had indicated intermediate closed cooling system radiation 7
alarm sometime in the transierit before all of these other i
8 alarms came in.
9 (Continued on next page) 10 11 12 13 O
14 15 16 17 18 19 20 21 22 23 1
24 25 v
$OUTHERN DISTRICT REPORTERS.U.S. COURTHOUSE FOLEY $QUARE. NEW YORK. N.Y. - 791-1020
-~ -..-,.
Ih tG Frederick.- direct 3488
~s 1
Q.
Based on your experience before the day of the b
d 2
accident did you have any experience about what caused an 3
intermediate closed cooling monitor alarm?
4 MR. FISKE:
Just before Mr. Frederick answers 5
this question, I am not really sure I understand the,last 6
answer.
7 THE COURT:
You may have it read back.
8 (Record read.)
9 A.
Yes.
Receiving that particular alarm was an 10 expected event after a reactor trip.
11 MR. FISKE:
Excuse me, your Honor.
That's what 12 I don't understand.
I thought he said he didn't receive
'm
)
13 the alarm.
Maybe I am.out of order, but I just don't
/
f 14 understand what's going on.
15 THE COURT:
Read back the answer.
16 (Record read.)
17 THE COURT:
Mr. Fiske, do you need the rest of 18 that?
19 MR. FISKE:
No, I think I have it now.
I am 20 sorry.
21 0
I believe you just said that an intermediate closed cooling monit'r radiation alarn could be caused by a 22 o
23 reactor trip.
Could you explain that?
24 A.
A reactor trip is a transient which causes both
\\s_/
25 mechanical and thermal shock to the reactor coolant system.
SOUTHERN DISTRICT REPORTERS.U.S. COURTHOUSE FoLEY SQUARE, NEW YORK. N.Y. - 791 1020 b -
FP W
l I1
~
.,y,
-h-m y-y 4-u
1h t6 Frederick - direct 3489 l
That is, change in temperature and a mechanical shock of
[ ~}
'Q' rods causes the release of corrosion products 2
the control 3
from the walls of the piping, just microscopic type 4
particles, wear products from valve operations, that sort 5
of thing.
6 These products are highly radioactive.
That's 7
why the general radiation level in a reactor coolant system 8
greatly increases following a reactor trip.
That radiation, 9
even though the coolant is not coming out of the piping, or 10 anything, can be detected outside the piping because it 11 penetrates the pipes, just like x-rays, and this particular 12 monitor located where it is is sensitive to this increase
)
13 in x-ray type radiation and it will make an alarm after a g
14 reactor trip.
15 It is not really sensing more radiation in the 16 system than it is monitoring, but the radiation around the 17 sensor itself is causing it to go into an alarm state.
18 Q.
Just so I understand, is the radiation that the 19 alarm is detecting from the particles being discharged 20 radiation that is within the reactor coolant system or has 21 it escaped from the reactor coolant system?
22 A.
Again, these little particles floating in the 23
' reactor coolant system water are emitting x-ray or gamma t-i 24 type radiation, and it can penetrate the pipe walls and
}
N 25 then be detected by an exterior detector like this.
SOUTHERN DISTRICT REPORTERS.U.S. COURTHOUSE FoLEY SQUARE, NEW YORK. N.Y. - 791-1020 j
P e
.sy
-4 7en
,y
Ih t6 Frederick - direct 3490
[##%g 1
Q.
Is the detector detecting a loss of coolant
\\j i
2 accident?
That's what I am driving at.
3 A.
No.
All it is seeing is an increase in 4
background radiation inside the reactor building due to the 5
t r i p.'
9 Q.
Is there a name or a phrase that's sometimes 7
used to describe the release of thest radioactive particles?
8 A.
Again -- oh, the par ticles in the water?
9 Q.
Yes.
10 A.
That's called a crud burst because the corrosion 11 products and wear products on the walls of the piping are 12 referred to as crud.
b (G
)
13 Q.
Is there any action that you understood was 14 dictated by the reseat of a radiation alarm coming from the 15 intermediate closed cooling alarm?
15 A.
Well, under different circumstances, that is 17 when we don't have a reactor trip, the actuation of the 18 intermediate closed cooling water alarm tells you that the 19 intermediate closed cooling water system, that i s the 20 system that cools the control rod drive motors and other 21 portions of the reactor system, i s for some reason having in 'he water of that cooling 22 an increase in radiation level t
23 water system.
--4 24 But in the context of this reactor trip it is 25 telling us that the gamma radiation coming from the entire s.
SOUTHERN DISTRICT REPORTERS, U.S. COURTHOUSE FoLEY SQUARE. NEW YORK. N.Y. - 791-1020
=
w m
T-w--
g v-
+-**W
Ih t6 Frederick - direct 3491 1
system is causing this alarm to go off.
So in this
,/'"'
V 2
situation it doesn't require any action.
3 Q.
When you came on shift'at 11 p.m. on March 27 4
you were in charge of panel manipulation, did you say?
5 A.
Yes.
6-Q.
Did you check the status of,the indicators on 7
the panel when you took over the panel?
8 A.
Yes, I did.
As I explained before, I examined 9
the key parameters that indicate the ' current operating 10 condition of the plant and I looked over important things 11 that the person I was relieving told me were important to 12 look at and reviewed the logs and paperwork that they were
((%)
13 using.to do whatever work was in progress.
14 Q.
Are there indications on the panel that show the 15 open or closed status of the 12 valves which are the block 16 valves on'the auxiliary feedwater system?
17 A.
Yes.
18 Q.
What kind of indicator is on the panel for that?
19 A.
It is a red and green light above the switch 20 that controls the position of the valve.
21 Q.
How is it that you did not initially notice that j
22 those panel indications showed the valves were shut?
23 A.
My observ-rion of the panel at that time was to
(
l
-['N i
?
24 observe, like I said, the key parameters for the operating 25 systems, and not having seen any disorder in those l
SOUTHERN DISTRICT REPORTERS. U.S. COURTHOUSE FOLEY SQUARE. NEW YORK N.Y. - 791.1020 l
r
.,.+s,
lh t4 Frederick - direct 3492 es 1
parameters, I didn' t get into specific valve locations
\\~ '
2 because I wasn't looking for a problem at that time.
I was 3
looking for any abnormalities in the normal maintenance of 4
those key' parameters.
5 Q.
After the 12's were discovered shut, did you
~
9 ever state that the discovery of the closed feedwater block 7
valves --
8 THE COURT:
Wait, wait, wait.
Why don't you go 9
through the door.
10 MR. SELTZER:
I will withdraw it, your Honor.
11 THE COURT:
All right, sit down.
12 MR. FISKE:
I will withdraw my anticipatory 7
13 objection.
14 Q.
What does the phrase feed and bleed mean to you?
15 THE COURT:
Do we need to get into all of this?
16 I thought Mr. Zewe went into this at quite some length.
17 MR. SELTZER:
Let me just go through these 18 questions myself --
19 THE COURT:
Will he do anything more than tell i
l 20 me about it or is he going to bring it in to some new 21 context?
r 22 MR. SELTZER:
In light of that, your Honor, I 23 can skip this.
l 24 THE COURT:
I don' t want to cut you off from l
i A,/
25 anything that's new, but if it is just a further m
SOUTHERN DISTRICT REPORTERS.U.S. COURTHOUSE FOLEY SQUARE. NEW YORK. N.Y. - 791-1020
e
= - - - - - - - _---.
Ih t6 Frederick - direct 3493 1
description of the same thing we have already had by J
2 another witness, we don't really need that, as we discussed.
3 Q.
You said that you were in charge of the primary 4
side of the panel throughout the accident.
You have 5
described the automatic actuation of emergency safety 6
features that occurred very soon after the 4 a.m. start of 7
the transient.
8 was there any point during the time that you 9
were still on duty the morning of the accident where you 10 manually initiated a full HPI injection?
11 A.
Yes.
12 Q.
How many times did you '.nitiate a full manual i
>)
13 actuation of high pressure injection?
14 A.
Once.
15 Q.
When relative to any other events that would fix 16 it in point of time do you recall the one full manual 17 actuation of high pressure-injection?
18 A.
It was around the time of the site emergency.
19 Q.
When you say site emergency, as I understand it, 20 there was a site emergency and then there was a subsequent 21 general emergency.
Do you distinguish in your mind between 22 those two terms?
23 A.
Yes, 1 know the difference.
'm
[
24 Q.
What was the site emergency and what was the
\\')
25 general emergency?
SOUTHERN DISTRICT REPORTERS. U.S. COURTHOUSE FoLEY SQUARE, NEW YORK. N.Y. - 791.1020 7
O co
..~.
lh tS Frederick - direct 3494 (3
1 A.
There are three grades in-the emergency e
i 2
escalation when you declare a radiation type emergency or a
~-
3 problem at the plant.
There is local emergency and then 4
site and then general.
The declaration of the general 5
emergency really isn't clear to me.
I know that once you in the site emergency state we were beginning to take a 6
are 7
lot of the actions in the emergency plan, and I don't 8
clearly remember the declaration of a general emergency.
9 MR. SELTZER:
I may have misspoken earlier, your 10 Honor.
The general emergency was declared 7:24 and a site 11 emergency was declared at 6:50.
I didn't want to mislead-12 the Court or the witness by my having confused those two 13 events.
I think the general emergency was declared af ter V
i 14 Gary Miller, the station manager, arrived in the control 15 room.
16 I am not offering that as testimony, but I think 17 tha t's what the record reflects.
18 Q.
Let me show you the computer alarm printer and 19 ask you if on that you can identify the point at which 20 there was the manual actuation of the full high pressure i
21 injection?
22 A.
The pages in mine are numbered.
Manual 23 initiation is indicated on page 31.
.i 24 Q.
What is the time that's shown for the point at k
25 which there was manual actuation of full HPI?
SOUTHERN DISTRICT REPORTERS.U.S. COURTHOUSE FOLEY SQUARE. NEW YORK. N.Y. - 791 1020
~ _. _.. _ _. _ _ _
Ih t6 Frederick - direct 3495
(' N 1
A.
It would be at 07:20:22.
\\'
/
2 Q.
So that would be approximately 20 minutes after 3
7 in the morning?
4 A.
Yes.
5 Q.
Do you remember anyone else during the first 6
four hours of the accident operating the controls that 7
would initiate a full HPI actuation?
9 A.
No.
9 Q.
Based on the routine and the procedures that you 10 were following that morning in the control room, is it 11 possible that someone else stepped up to the panel and took 12 control of HPI?
~
/
13 THE COURT:
Sustained.
Q/
14 Q.
What routine and procedures were you following 15 for manning the panel that controls HPI?
15 A.
During the morning I was, as I said before, in 17 charge of control of the primary system, with Mr.
19 Scheimann's assistance.
I was stationed at panel 3.
When 19 I wasn't at panel 3 and was going to move to panel 4, for a 20 minute, or so, I would info rn Mr. Scheimann I whs leaving.
21 If he was going to shift his position, he would tell me, 22 Conversation was constant in that when you are 23 asking someone to take over your duties on a panel, you do 3
k 24 a turnover, you say "this is what I am doing right now,"
g)
'(\\-
25-then you leave.
After that he says "okay, I have got it."
l SOUTHERN DISTRICT REPORTERS, U.S. COURTHOUSE f
FOLEY SQUARE. NEW YORK. N.Y. - 191 1020 I
~
~ ~ ~..
_..,... ~....
. s 4.
- ,.Q.
lh t6 Frederick - direct 3496 in each case when you shift your position on the p[j 1
So that V
2 panel, the person that you are leaving in charge of that
~
3 panel has some knowledge of what you are trying to 4
accomplish before you turn it over to him.
5 Q.
Based on what you were doing, if you turned over 6
the panel to someone else and had started HPI, is that a piece of information that you would communicate?
7 8
A.
Yes.
9 Q.
Based on your understanding of how the routine 10 was being followed in the control room, if you reassumed 11 control of a panel that had the HPI controls after having 12 stepped away for some interval, would the person from whom 13 you were assumin'g control tell you whether he had initiated 14 HPI?
15 A.
Yes.
16 Q.
Are the high pressure injection pump and the 17 makeup pump the same pumps or different pumps?
18 A.
They are the same pumps, just a different name 19 for the same piece of equipment.
I L
20 Q.
I think you probably gave the answer to the 21 Court this morning.
If it is operating in its makeup mode o
22 from what water source does it draw?
23 A.
It draws from the makeup tank.
24 Q.
If the pumps are operating in their high l
25 pressure injection mode, where i.s. the water be ing drawn SOUTHERN DISTRICT REPORTERS. U.S. COURTHOUSE FoLEY SQUARE. NEW YORK. N.Y. - 1911020 4
. ~,. -...
Ih t6 Frederick - direct 3497
/s' 1
from?
l i
2
- A.
The borated water storage tank.
3 Q.
If the pumps are drawing from the borated water 4
storage tank, are there any other pumps that could be 5
simultaneously withdrawing water from the makeup tank?
6 A.
No.
7 Q.
Are there any valves that could be letting water 8
out of the makeup tank while the HPI pumps are pulling 9
water from the borated water storage tank?
10 A.
No.
When HPI is drawing from the borated water 11 storage tank, the outlet of the makeup tank, the pipe that 12 comes out of the bottom, is isolated.
f 13 MR. SELTZER:
Would you get the chart, please?
%./
14 THE COURT:
I can see it.
It is right here.
15 Mr. Seltzer, you don't need to get that chart.
I have got 15 it right here.
valve 12, right?
Right there?
17 THE WITNESS:
No, sir, that would be 137 that 19 does the isolation.
19 THE COURT:
MUV 137, right above it?
20 THE WITNESS:
Yes, sir.
That's the swing check --
o 21 THE C0yRT:
How come you have it marked down to 22 here?
That's the valve that doesn't let it go back?
You 23 are. talking about this one which is the one that isolates h
24 it, that's the valve that doesn' t let it go back, right?
('
}
\\
U/
25 THE WITNESS:
Yes, sir.
This shows automatic SOUTHERN DISTRICT REPORTERS. U.S. COURTHOUSE FOLEY SQUARE. NEW YORK. N.Y. - 791 1020
.m_
1h t6 Frederick - direct 3498 l
/
1 injection mode assuming operator action in accordance with N]l 2
the --
3 THE COURT:
When you isolate the makeup tank, r
4 you close this one here, right?
5 THE WITNESS:
That's the operator's action.
The 6
automatic action is that this valve closes.
7 THE COURT:
I understood that from Mr. Zewe to 8
be a one-way valve that would let stuff through but not let 9
it back.
10 THE WITNESS:
That's correct.-
11 THE COURT:
Anyway, we are all together now.
12 Q.
What happens to that valve if water is being 13 drawn from the borated water storage tank?
14 A.
The valve we are talking about, MUV 137, upon i
15 initiation of flow from the BWST closes and does not allow 16 water to exit the makeup tank.
17 Q.
Have you reviewed charts that show what was 18 happening to makeup level during the morning of the 19 accident?
20 A.
Yes.
21 Q.
Do you know what that chart shows was happening 22 to make up tank level at 5:4,1 a.m.?
23 A.
Yes, I do.
,.. )
24 Q.
What was happening?
V 25 A.
Makeup tank level was decreasing, going down.
SOUTHERN DISTRICT REPORTERS. U.S. COURTHOUSE FOLEY SQUARE. NEW YORK. N.Y. - 791 1020
__-.7-%.
-,---r x.m
-w.-
1 l
1 lh t6 Frederick - direct 3499 1
Q.
Based on your, understanding as you have 2
testified today as to how the systems work, what does the 3
data that you have reviewed on makeup tank level indicate 4
about whether HPI could have been on full manual actuation 5
at 5:41?
5 A.
It could not.
7 MR. FISKE:
I am going to object to that, your 8
Honor.
I don't think that Mr. Frederick is being called 9
here as an expert witness on whether this could or could 10 not have happened.
He is supposed to tell us what his I
11 recollection is of the events, and apparently he has done 1.2 that. 'Now they are trying to go beyond that to show that 13 based on these charts, or whatever, it didn't happen or 14 couldn't have happened.
I am not sure that is appropriate 15 for Mr. Frederick.
16 MR. SELTZER:
May I be heard, your Honor?
~~
17 T51E COURT:
Yes.
I think this objection is 18 going to cause a witness trip.
19 (The witness left the courtroom.')
20 MR. SELTZER:
Your Honor, I can explain our 21 position from this chart very quickly, and then your Honor 22 can rule.
The witness has just indicated that when the 23 makeup pumps are operating in a makeup mode, they draw down rqj 24 water from the makeup tank, and we have reproduced here 25 from B & W reactimeter data, this is their machine, this SOUTHERN DISTRICT REPORTERS. U.S. COURTHOUSE FOLEY SQUARE NEW YORK. N.Y. - 791-1020
?
- - - _.., ~ ~
.....m...
o i
_ _ = _
lh t6 Frederick - direct 3500 1
shows what was happening to makeup tank level' during one 2
part of the accident.
We have drawn a line at 5:41, which 3
is the point where the last reactor coolant pumps were l
4' turned of f and where there were entries describing what was 5
happening.
I
'S Mr._ Frederick has just testified from his i
7 understanding --
8 THE COURT:
Let me ask you this.
I see what you l
9 are saying over there.
On the other hand, if you look at 10 this valve diagram, is there any reason that they couldn't 11 have hit the HPI and gotten to turn of f valve number 12 and 12 had drawn off all sources?
~
13 MR. SELTZER:
I think Mr. Frederick would say 14 that is impossible.
15 THE COURT:
Why is he prepared to say it is 16 impossible?
17 MR. SELTZER:
He will describe the system's 18 operation.
As an operator and now an instructor he is 19 extremely familiar with how these systems function.
20 THE COURT:
Is he prepared to say that if you I
21 open up valves 5-A and 5-B that there is an automatic 22 closure of valve 12?
If you open up these, does that mean 23 that that one is automatically closed?
24 MR. SELTZER:
I think it is 137 that shuts.
25 THE COURT:
I am not sure that I agree with you SOUTHERN DISTRICT REPORTERS. U.S. COURTHOUSE FOLEY SQUARE, NEW YORK. N.Y. - 191.1020 t
. ~. _
O
..__e--
~
~~
1h t6 Frederick - direct 3501 1
about 137 because Zewe testified to something quite f
v 2
different about 137 than this witness has testified to.
l 3
MR. KLINGSBERG:
No, it is exactly the the same.
4 THE COURT:
If this witness testifies that 137 5
is the manual one, then it would appear that there is no 6
reason to have valve-number 12 at all.
7 MR. SELTZER:
137 is not manual.
It is an 8
automatic check valve and when it sees backpressure from 9
the borated water storage tank --
10 THE COURT:
That's exactly what Zewe told me, 11 you are right.
That's what Zewe told me.
When the thing 12 starts to back up, it closes.
You are a hundred percent
(
13 correct.
14 This witness, however, said that you could 4
15 ~
manually operate 137 to close.
I am not sure, that he may 4
16 not have made a mistake about that.
If he is right about 17 that, then there is no reason to have valve number 12, 18 because then you would have two valves serving the same 19 function right next to each other ir. the line and --
l 20 MR. SELTZER:
I am sure this wouldn' t be the 21 first time that this plant has had two valves performing 22 the same function.
23 THE COURT:
You have this here.
I suppose you l-
.1 24 can make an argument from that chart, which is Exhibit 3022, v/
\\
25 you can make the argument from that, i f you want to, but it SOUTHERN DISTRICT REPORTERS.U.S. COURTHOUSE FOLEY $QUARE. NEW YORK. N.Y. - 791.1020 i
i
-w,.
siw,-
+
p.,.-mr.-,---v--e--
-ve y-ye
- vyy.,-,.wv.
--p.em--,---m---r--p*e-wr y-p-
.w--y w
sm
-y-W wri-,-w,-ey.-
,n 9.-
,em.,p q
w w---,-
,,wS
,y-,
v--
e
lh t6 Frederick - direct 3502
N 1
does seem to me that unless a witness is prepared to say 2
that this system is going to close of f 12 at the same time 3
as it opens up 5-A and 5-B automatically, that then it 4
doesn't necessarily follow that you aren't drawing down 5
from both borated water and the makeup tank at the same 5
time.
7 MR. SELTZER:
Yout Honor, I think one of us has 8
to ask Mr. Frederick whether it must follow that either 9
valve 137 or valve 12 shuts whenever there is full 10 actuation of HPI.
If that were so, then the makeup tank 11 level could not be drawn down when there is full HPI 12 initiation, and this decline on 3022 would show that there
(
j 13 could not have been a full HPI actuation at 5:41.
14 THE COURT:
I don't know that it necessarily 15 shows that at all.
Unless this witness tells me that, I 15 haven't heard that from any source except from you.
17 MR. FISKE:
There is one other problem here, 18 your Honor.
There is in effect the same problem that was 19 outlined previously with respect to Mr. Zewe.
- 7. 0 You heard Mr. Zewe's testimony how in the week 21 or two or a couple of months after the accident --
22 MR. SELTZER:
Wait, we don't have to get into 23 that.
('"N 24 MR. FISKE:
We certainly do.
Mr. Frederick p
\\
25 repeatedly told. everybody at GPU, and it is right in their SOUTHERN D!$TRICT REPORTERS,U.S. COURTHOUSE FoLEY SQUARE. NEW YORK. N.Y. - 791-1020
..n.-
Ih t6 Frederick - direct 3503
(' '$
1 own chronology based on what Mr. Frederick insisted on, in 2
the words of one of the GPU people, that.HPI went on full
'~'
3 at 5:40.
So Mr. Frederick, side by side with Mr. Zewe and 4
Mr. Faust, was telling people at GPU in the preparation of 5
this official chronology that HPI was in fact turned on on 6
full at 5:40.
The people at GPU who recognized that he was 7
insisting on that put that in the chronology a year and a 8
half later after there had been exhaustive investigation of 9
this and filed it with the Nuclear Regulatory Commission as 10 GPU's official statement of what had happened at 5:40.
m 11 I don't think it is appropriate for Mr.
12 Frederick, who is so deeply involved in the credibility
( )%
/
13 questions, at the very least, that go into this, to now be 14 coming in and acting as some kind of an expert witness to 15 undermine his own credibility in terms of what he was 16 telling people in the spring of 1979.
17 If this is really going to be the subj ect now of 18 expert testimony that somehow it was absolutely impossible, 19 it couldn't possibly have happened that HPI went on i: 5:40 20 and this is something that GPU now has suddenly dit '
- ered, 21 which they obviously didn't know in September of 19L3, a 22 year and a half after the accident when they filed it with 23 the Nuclear Regulatory Commission -- and I might say that
)~s ~ i 2a was six months after this lawsuit had been brought, they i
\\\\~/
25 still were saying that HPI had gone on at full at 5:40 SOUTHERN DISTRICT REPORTERS. U.S. COURTHOUSE FOLEY SQUARE. NEW YORK. N.Y. - 791 1020
.f c.
-3e
..pm es 3-
..ww=r-
+-a--
--w.-m e-
y i
..,,y 7 g
'1h t6 Frederick - direct 3504
[N 1
based on the statements of Frederick, Zewe and Faust -- I
\\ ',)
2 don't think that it is up to Mr. Frederick to come in here 3
now and act as'some sort of o,n-the-spot expert witness to
'4 say that this couldn't have happened.
5 MR. SELTZER:
Let me respond --
S THE COURT:
Let me ask you this.
I suppose it-7 is conceivable that in the tensions of that morning 8
Frederick believed that something had happened at a 9
particular time and after the event --
10 MR. SELTZER:
I think it is Zewe, your Honor.
' ll Frederick has never testified --
12 THE COURT:
Frederick.
)
13 MR. SELTZER:
Zewe is the one who said there was 14 a 5:41.
Frederick never --
15 THE COURT:
Mr. Fiske says that Frederick said 16 that it happened.
17 MR. SELTZER:
I think he misspoke.
Frederick 19 haa never on the record with any testimony said that he 19 thought there was a 5:41 --
20 MR. FISKE:
Mr. Zewe testified here just three 21 or four days ago that they had a meeting with the PORC, 22 that Mr. Zewe as at, Mr. Frederick was at and Mr. Faust was 23 at, and all three of them, Zewe, Frederick and Faust, all
- ')
24 told the PORC that HPI had come on at 5:40.
25 You may remember further that Mr. Zewe testified SOUTHERN DISTRICT REPORTERS. U.S. COURTHOUSE FOLEY SQUARE. NEW YORK. N.Y. - 791 1020 m
s
,. +
+ -.
a--
,,, - +. - - -
e 4s w,
,o ww
-y-r,,e
-m o,,,ox,-
-e--m y-ey,-,-
.z..
lh t6 Frederick - direct 3505 1
that according to both Mr. Frederick and Mr. Faust there
>'wj#-
2 had been a countdown at 5:40 at which when one of them hit J
3 the reactor coolant pumps, the other one hit high pressure 4
injection.
That's the detail that they were going into.
5 THE COURT:
You are getting, though, into 6
questions of credibility of the witness on which you are 7
obviously going "to cross examine and which you are entitled 8
to urge upon the Court.
But it seems to me it is open to 9
this witness, subject to your cross examination on 10 credibility, to say to me, for argument's sake, Zewe is 11 wrong when he says 5:41.
It is open to the witness to say 12 "I
thought I had at 5:41, but in looking back at it, in 13 looking at these records, I realize that I must have been C
14 mistaken."
15 How that leaves the issue of weight of the 16 testimony is perhaps then another matter, but as far as the 17 admissibility of the man saying "from looking at these 18 records I conclude that it was another way," that's a 19 different matter at this particular point which only has to 20 do with whether the witness shall be permitted to be asked 21 the question.
22 I think I will let him be asked the question, 23 although I must confess that it is an unusual, wrinkle that I.
I A.:
24 the person is, if he has at some time in the past, and you
/
i' k
,)
25 haven't asked him this, Mr. Seltzer, whether or not he did i
SOUTHERN DISTRICT REPORTERS. U.S. COURTHOUSE l
FOLEY SQUARE. NEW YORK. N.Y. - 7911020 e
n
,,,,p.
,n, a
-,7 oo q,-
lh t6 Frederick - direct 3505 1
1 1
1 not in fact tell the PORC that i t wa s 5 : 41 -- I g ue ss
[]
V 2
somebody is going to ask him that before the witness 3
finally leaves the stand -- but if he says he did tell them, 4
if he says "yes, I did tell them it was turned on at 5:41,"
5 it is unusual for him to then be permitted as a quasi 6
expert to say "I am contradicting that statement bas.ed upon 7
my review of the records," but I am going to let him do it.
8 Bring the witness in.
9 MR. SELTZER:
Your Honor, I might add that Mr.
I 10 Zewe testified in no uncertain terms that you could not be s
11 drawing down makeup pumps while HPI --
12 THE COURT:
I will be interested to see what he
)
13 says about these valves.
14 (The witness entered the courtroom.)
15 BY MR. SELTZER:
f 16 Q.
Mr. Frederick, could you take a look at the
)
17 diagram of the valves that connect to the makeup tank and 18 explain what happens to those valves when there is full HPI 19 actuation?
20 A.
All the valves on the --
21 Q.
The valves that connect directly to the makeup 22 tank, the 137 and the 12?
23 A.
The 12 is an electrically operated valve that 24 has a motor on it to open and close it, but it is only 25 actuated by a manual signal.
I would have to go to the SOUTHERN DISTRICT REPORTERS,U.$. COURTHOUSE FOLEY SQUARE. NEW YORK. N.Y. - 7911020 m._
~ _..,...
' 6'L '
~
Ih t6-Frederick - direct 3507
.(%
1 panel and turn the switch to make the valve move.
'J 2
THE COURT:
When you close 12 -- excuse me.
How 4
3 do you turn on 5-A and 5-B?
How do you open 5-A and 5-B7 4
THE WITNESS:
Several ways.
When ES is t
5 automatically initiated, they open automatically.
6 THE COURT:
If you manually initiated HPI, do 7
-you push a button to open 5-A and 5-B?
8 THE WITNESS:
No.
What you do to get--- maybe 9
the term I am using is wrong -- manual initiation, that is 10 full manual initiation of the high pressure injection, 11
. occurs when you push these red buttons right here.
12 THE COURT:
Wha t does that --
p
(
13 THE WITNESS:
It is just a matter of pushing two 14 buttons.
15 THE COURT:
What does that do, that opens up 5-A 16 and B and energizes the pumps?
17 THE WITNESS:
It actuates several dozen 18 components, not just the pumps and those valves.
19 THE COURT:
That's all I am asking-about so far.
20 It opens up 5-A and 5-B and opens up makeup pumps 1-A and 21 1-C, turns them on, right?
22 THE WITNESS:
Yes.
23 THE COURT:
Does it do anything else?
What else
'I i
j J
24 does it do when you hit those buttons?
i i
\\._
25 THE WITNESS:
It takes automatic control of the j
SOUTHERN DISTRICT REPORTERS.U.S. COURTHOUSE FoLEY SQUARE. NEW YORK. N.Y. - 791 1020 I
~
..n-----w-r w
rvi-,-
w--
w-
+.-3,y y
-*<,-,w--+,ey--
4 y
-vew-.-e
= * *
-A
,p--.a.
..m yr,.e+>
e.-
."y-e4---wu+
w
+-
e d
Ih t6 Frederick - direct 3508 1
discharge valves in the makeup pumps and sets them at their j'~')N T
2 prethrottle automatic set po in ts.
It opens into a prethrottle 3
position, 250 GPM's, approximately.
Then it also controls 4
the recirculation valves in the makeup pumps that are shown 5
there as 36 and 37 about in the center of the diagram, it 5
closes those valves.
7 THE COURT:
Okay.
8 THE WITNESS:
On this picture I believe that's 9
all is going to happen right now.
There are other systems 10 that are affected by pushing those buttons.
All we are 11 doing is lining up the makeup pumps A and C so that they 12 trace back there through 139-A and 5-A, borated water 13 storage tank, that flow path is open and it is opened on
(
14 the C pump through the B valve.
Then you have the presence 15 o f -- that pressure from the borated water storage tank is 16 felt through 5-A, through 139 and 40 and it pushes up 4
17 against 137 and it closes it.
18 Do you see 139 and 40 there, the suction head 19 pumps?
Here.
Once this 5-A opens the pressure from this 20 tank is felt all the way bac'k through there and closes it, 21 closes the check valve.
It seems that all they are showing 22 on this diagram is where the water is coming from to get 23 into the system, but these other systems are not shown --
'#Ck) 24 it does not show the effect on that.
25 All we are seeing is this pressure, that's about SOUTHERN DISTRICT REPORTERS,U.S. COURTHOUSE FOLEY SQUARE, NEW YORK. N.Y. - 1911020
,-.b,-
8
~ ' '
- e
-=w,-
..,. - ~
lh t6 Frederick - direct 3509 p-l 60 feet of water, which is roughly 30 pounds, or.so,
(
pushing down on all this piping here and back up against 2
3 that check valve, back around that loop.
As long as 12 is 4
open you will have a force against the check valve.
5 THE COURT:
I don't understand this one respect.
6 Why is it that if makeup pump 1-A is pumping full blast, it 7
doesn't pull water from any pipe that puts water into i t?
8 Pump 1-A is pushing water on this chart to the right, 9
co r r ec t?
10 THE WITNESS:
Yes.
11 THE COURT:
It is drawing from the left, correct?
12 THE WITNESS:
Yes.
~
k,,/
13 THE COURT:
Why is it putting backpressure on m
14 the makeup tank when it is pulling water from that 15 direction?
16 THE WITNESS:
The assumption cannot be made that 17 pressure in this line will be zero or a vacuum just because 18 it is pumping.
The pressure in this line will be a 19 function of the elevation of water in this tank and this 20 tank combined.
If the elevation of water in this tank is 21 much superior to this elevation, then this will be the 22 controlling pressure.
If this pressure is 30 pounds and 23 the pressure on this. tank is less, then that pressure will 24 overrule this check valve back here and shut.
f t \\_/
THE COURT:
Are you prepared to say that that's 25 SOUTHERN DISTRICT REPORTERS.U.S. COURTHOUSE FOLEY SQUARE. NEW YORK. N.Y. - 198 1020 I
3
-y.
.m...-~
,a-.
n
,,n
,w-w o-
,~,,, -
g w-eo<+-
.-,-,-.,--w v.
-m.
4-g
1h t6 Frederick - direct 3510
}
1 what in fact happened at 5:41 a.m. on March 28, 1979?
(U 2
THE WITNESS:
I wasn't aware that I had said 3
that.
4 MR. SELTZER:
Wait a second, your Honor.
5 THE COURT:
Please, please.
i 6
(Record read.)
7 THE COURT:
I am saying, are you prepared to say 8
that that is what indeed-happened at 5:41 on the morning of 9
March 29, 1979?
10 THE WITNESS:
No.
In reviewing these_ charts, 11 what I am prepared to say is that that in fact did not 12 happen, that whatever condition existed at 5:41, it was O
(
13 such that we were still able to pull water through the 14 makeup tank.
If HPI were initiated, that would be 15 impossible because this check valve would be backseated.
16 THE COURT:
You don' t know that the pressure on 17 that check valve would have been 30 pounds backwards, do l
18 you?
I 19 THE WITNESS:
It is how the system is designed 20 to function.
That is how we were set up on that day.
21 THE COURT:
I know, but do you know from your 22 own experience or knowledge or engineering background that i
23 that is is fact what happened?
I
~s 24 THE WITNESS:
Yes.
I have seen it happen many 25 times.
s-SOUTHERN DISTRICT REPORTERS.U.S. COURTHOUSE FoLEY SQUARE. NEW YORK, N.Y. - 191-1020 i
i i
Ih t6 Frederick - direct 3511 j
1 THE COURT:
What?
i 2
THE WITNESS:
That when HPI is initiated, the 3
makeup tank level stops decreasing.
It happens that way 4
every time.
It is just a function of the elevation of the 5
two tanks.
One is lower than the other one and is 6
therefore overruled.
7 THE COURT:
Okay.
Thanks very much.
8 BY MR. SELTZER:
9 Q.
Would you take a look at GPU Exhibit 3022 --
10 THE COURT:
Let me just stop you.
Does this 11 happen with -- I take it HPI involves two pumps, correct?
12 THE WITNESS:
Automatic initiation would involve 13 two pumps, yes.
14 THE COURT:
Suppose you only had one pump.
15 THE WITNESS:
Which one, sir?
16 THE COURT:
For example, here, you have got 1-A 17 and 1-B going and you have got that connecting line between 18 them.
I take it 1-B is doing the pulling from the makeup 19 tank while the 1-A is doing the pulling from the storage 20 tank, right?
We are talking about Exhibit 3020, for the 21 record.
22 THE WITNESS:
No, sir.
In this condition we 23 would be drawing water out of the borated water storage i.ij 24 tank.
/
v' 25 THE COURT:
This indicates that you are drawing SOUTHERN DISTRICT REPORTERS. U.S. COURTHOUSE I
FoLEY SQUARE, NEW YORK. N.Y. - 791.1020 y
,,._y__.
4,
lh t6 Frederick - direct 3512 I
water out of the makeup tank as well.
[N)
Nl 2
THE WITNESS:
I don' t know wny it shows that.
3 THE COURT:
Go ahead.
I gather I will~ await 4
hereafter on this.
5 THE WITNESS:
It might help if it was laid out i
6 just a little differently and you could see the dif ference.
7 Should I redraw it for you?
8 THE COURT:
I will let Mr. Seltzer put questions 9
to yo u.
This is an exhibit that's already in evidence, but 10 I can't let you redraw it for me.
They will have to do 11 that.
12 BY MR. SELTZER:
fN'
(
)
13 Q.
Based on the understanding that you have 14 explained of when makeup tank level can decrease and when 15 it cannot decrease, what does the data from the B & W 16 reactimeter shown on GPU Exhibit 3022 indicate as to 17 whether high pressure injection could have been on a full 19 actuation at 5:41 5.m.?
19 THE COURT:
He answered that already several l
20 times, Mr. Seltzer.
He said it was impossible.
Tha t ' s 21 what he told me in an earlier answer.
Let's go on.
22 Q.
Did there come a time when you attended a 23 meeting of the PORC with Mr. Zewe and Mr. Faust after the k s) 24 accident to discuss what had happened during the accident?
} kl) i 25 A.
- Yes, i
SOUTHERN DISTRICT REPORTERS. U.S. COURTHOUSE FOLEY SQUARE. NEW YORK. N.Y. - 7911020
[
y.
2 :..
Ih t6 Frederick - direct 3513
}
l MR. FISKE:
You'r Honor, I am going to put that
\\v/
2 question in the same category as two or three others that 3
we have objected to.
I think we are entitled to develop 4
that on cross examination.
5 THE COURT:
No, let's see.
Apparently he has 6
not been specifically asked that as to himself, and I will 7
let him answer this one.
Go ahead.
I will. overrule that 8
objection under these circumstances.
Go ahead.
9 A.
Yes.
10 THE COURT:
Were you at such a PORC meeting?
11 THE WITNESS:
Yes, sir.
12 Q.
At that PORC meeting was there a discussion of
/
13 full manual actuation of high pressure injection?
14 A.
It was one of the topics that we discussed, yes, 15 Q.
Did any of the control room operators who had 16 been in the control room on the morning of the accident say 17 anything at that meeting about when high pressure injection 18 had been put <: a full manual actuation?
19 A.
Yes.
Mr. Faust, Craig Faust, said that he felt 20 there was a high pressure injection actuation at about the 21 time that we closed off the -- at the time when we turned 22 off the reactor coolant pumps.
23 Q.
The first two pumps or.the last two pumps?
j Id 24 A.
The last, the final pumps, the last two pumps.
Y 25 O.
So that would be at about 5:41 a.m.?
SOUTHERN DISTRICT REPORTERS. U.S. COURTHOUSE FOt.EY SQUARE. NEW YORK. N.Y. - 791.1020
_.y9 m.,e-g g-$-
m
.aw
~
q w
w
2
. :. ~
Ih t6 Frederick - direct 3514 l'
A.' -
Yes.
~
2 THE COURT:
That's about this time we are 3
talking about, right?
4 THE WITNESS:
Yes.'
The chronology shows it at 5
-exactly this time, yes.
G Q.
What is your best recollection about what i f.
7 anything you said when Mr. Fa ust said he believed there had 9
been a full manual actuation of HPI at or about 5:41?
9 A.
I didn't say anything.
I didn't agree or 10 disagree.
11 Q.
What was the state'of your knowledge at that i
12 time about whether there had been a full manual actuation 13 of HPI at 5:41?
%J 14 A.
We were working strictly from memory at that 15 meeting trying to come up with fresh information, and I 16 didn' t have a memory that coincided with his, but I 17 couldn't remember clearly enough what time I did the manual 18 actuation to tell that it wasn't at that time.
I needed 19 more information to precisely figure out when I did the 20 manual actuation.
21 Q.
So what did you say about it when the topic was 22 raised?
23 A.
Since there was no data available, I didn't say k) 24 anything.
I didn' t of fer a dissenting opinion.
25 THE. COURT:
Mr. Frederick, this caption on GPU SOUTHERN DISTRICT REPORTERS.U.S. COURTHOUSE FOLEY SQUARE. NEW YORK. N.Y. - 791 1020
.,,.e-
Ih t6 Frederick - direct 3515 1
3020 reads, " Manual injection mode following reactor trip."
,2 What does that caption mean?
3 THE WITNESS:
If you recall, I described 1
4 starting an additional makeup pump and closing the letdown 5
isolation valve immediately after the reactor trip when I 6
arrived back at panel 3.
I had gone over to the other 7
panels and --
8 THE COURT:
That's what you are talking about, 9
the manual injection of HPI, right?
10 THE WITNESS:
That's manual injection.
I guess 11 the terminology --
12 THE COURT:
Is this a good time for a recess?
13 MR. SELTZER:
Yes, your Honor.
14 THE COURT:
Very good.
We will take a ten-minute I
15 recess.
1G (Recess.)
17 (Continued on next page.)
18 19 20 21 22 23 1
24 25 SOUTHERN DISTRICT REPORTERS.U.S. COURTHOUSE FoLEY SQUARE. NEW YORK. N.Y. - 7911020 A
.ww.-.
v we.a mq+-v.**
3 eww.
--www-
.w.
==e..e-
-ww-
--.,.-4
- - _. = _ - - _..
jbp t7 Frcdcrick-dircct 3516 1
(Open court).
[,\\
C/
2 Q.
Mr. Frederick, looking at GPU Exhibit 3020, 3
which is the diagram of the make-up pumps and HPI pumps 4
drawing from pumps A and B, when the pumps are lined up so 5
that A and B are drawing HPI flow, full HPI flow, where 6
does that water come from?
7 A.
It comes from the borated water storage tank.
8 Q.
Can you explain from diagram 3020 how the water 9
effects the make-up tank?
10 A.
When you start flow through the 5, ES-35 A valve, 11 just by opening the va1ve, you take the pressure that's in 12 the borated water storage tank, a very large tank, about 60
[D 13 feet high, outside the building, and elevate it about 20 14 feet above the make-up tank, all that pressure is exerted 15 on the check valve which is at the discharge of the make-up 16 tank and it closes that check valve.
17 Q.
What number is the check valve?
18 A.
137.
That's the small tank at a low elevation 19 and this pressure backseats the check valve and prevents 20 water from coming out of the make-up tank.
21 In this particular diagram, what you are going 22 to see, all these colored and dashed lines show that the 23 water in the makeA'a tank, the levels are going to be 24 increasing slightly due to the sealed return and the 25 resurge in the pump.
The resurge going through 36 and 37 I
SOUTHERN ' DISTRICT REPORTERS. U.S. COURTHOUSE FOLEY SQUARE FEW YORK. N.Y. - 791 1020 i
jbp t7 Fredorick-dircet 3517 1
and the resurge --
(
(,/
2 Q.
Which tank?
i 3
A.
The make-up tank.
l 4
Q.
I think you made a remark that there was 5
something you would change o,n this chart.
6 What were you referring to?
7 A.
When I was speaking to his Honor I didn't mean 8
to change this chart or redraw this chart.
I wanted to 9
draw a picture that shows the difference in size of the 10 tanks and difference in elevation so it would be a little 11 more obvious why the check valve can't be opened.
I didn't 12 mean to change the exhibit.
I didn't want to do that.
I
-/N 13 Q.
How would you change the size of the tanks to k
14 illustrate what you wanted to illustrate?
15 A.
Well, as I have said, the borated water storage 16 tank is about 60 feet high.
The make-up tank is about, 17 what did we say, 100 inches or 120 inches.
It is a very 18 small tank in comparison to the borated water storage tank.
19 It is a significant low elevation.
The reaction of that 20 check water is going to backseat it every time.
21 Q.
Let me turn to another subject.
22 Before March 28, 1979, was there a method by 23 which operators were informed if control room procedures 24 were being changed?
Y 25 A.
Yes.
$0UTHERN DISTRIC' REPORTERS.U.S. COURTHOUSE FoLEY SQUARE. NEW YORK. N.Y. - 791-1020 w
-w g
e -
.g-w-
..,,, 9
1 jbp t7 Frcdorick-dirset 3518 f
1 There were several ways that we were informed of
~
2 procedure changes.
We had a required reading book in the s_s 3
control room which -- into which all procedure changes were 4
entered and we were to review them and initial a sheet that I
l 5
showed that we had reviewed them.
We had -- well, there was a procedure review, 6
7 kind of like a surveillance on a regular basis, that you 8
"had to go through and read all the procedures whether they f
9 were changed or not.
Of course, we had the requalification 10 training where they would point out the significant changes 11 in the procedures that had happened over the last period of 12 time since you had training on procedures.
i 13 So in those three ways we would learn about all 14 kinds of procedure changes.
15 Q.
In learning about procedure changes, did you 16 know before the accident whether any procedure changes for 17 your unit had originated with Babcock & Wilcox?
18 A.
Yes.
That was one source of information that 19 caused procedure changes.
20 Q.
Prior to the day of the accident, what training 21 did you get at Metropolitan Edison on other events that had 22 occurred at Three Mile Island?
t 23 A.
Well, that type of information was relayed to us 24 in a similar manner.
(,/
25 We had required reading book which would include soumERN oisn!CT REPORRR$.U.S. COUREOUSE FOLEY SQUARE. NEW YORK. N.Y. - 791.1020
,q
jbp t7 Frederick-diroct 3519 i
1 bulletins or information from any source that supervision
(',s l
2 thought it was appropriate for us to be aware of.
We also I
i 3
had the supervisor's menos, in which if he was apprised of 4
some situation that had occurred that was relevant to our 5
plant, then he could let us know through one of those memos.
6 We also had LER, that is Licensee Event Report 7
reviews in training and they were part of our reading and 8
study cycle in the requalification.
9 Q.
Before the accident, did you receive any 10 training on events that occurred at other company's nuclear 11 plants?
12 A.
Yes.
In the same way.
They would be included m
13 with the information about local LER's.
14 Q.
In 1978, did you learn that a change had been 15 made in the small break loss of coolant accident procedure?
16 A.
Yes.
17 Q.
What was the nature of that change?
18 A.
It was an insertion of a special section of the i
19 loss of coolant accident procedure which addressed a f
20 response which was necessary to a small break LOCA when it 21 was in conjunction with other indications.
That is, a 22 failure of a diesel operator or failure of a make-up pump 23 to start during a LOCA.
i 24 Q.
Did you receive training on that change of loss 25 of coolant accident procedure?
s SOUTHERN DISTRICT REPORTERS.U.S. COURTHOUSE FOLEY SQUARE. NEW YORK. N.Y. - 791 1020 l
,. ~,,
..a.._,_-._-,.,
w, e>
..=
jbp t7, Frederick-direct 3520 1
A.
Yes, we did.
I received it through all the 2
avenues I just discussed.
The review on-shift, the 3
required reading, the requalification training and specific 4
drills that we had to run on that procedure.
They gave us 5
a drill scenario that we had to act out and be able to I l 6
. accomplish the tasks outlined in the drill within a 7
specified time period.
i 8
THE COURT:
I hate to come back to this.
But my 9
memory about this chart 3020 -- do you still have that 10 there?
11 THE WITNESS:
Yes, sir.
12 THE COURT:
You know, this chart indicates that 13 coming from the make-up tank at this point is up to 160 s
14 gallons a minute through this line and up here 95 gallons a 15 minute through this line.
16 That's what that chart tells me, does it not?
17 THE WITNESS:
These are right but it is not 18 coming from the make-up tank.
The blue indicates water --
19 THE COURT:
No.
This says normal make-up.
20 THE WITNESS:
Because that's not a high pressure 21 injection line.
That's the normal make-up line.
That's 22 the pipe.
That's the reactor coolant system inventory 23 control valve and this is the normal make-up -- this is the i
24 line we normally control pressurizer level and the system i
N-25 inventory through.
We don' t usually use these 16 A, B,
C l
SOUTHERN DISTRICT REPORTERS.U.S. COURTHOUSE FoLEY SQUARE. NEW YORK. N.Y. - 791 1020 y
).c%
y
~
^
4 jbp t7 Frodorick-direct 3521 i
1 and D lines.
We use these lines.
This is the normal flow l
2 path or make-up so we call it the normal make-up line.
3 We're labeling the pipes.
4 THE COURT:
You see, when you had the make-up
!i l{
5 pump going all alone, Mr. Frederick, and I'm now looking at i.-
6 3018, when you had the make-up tank going all by itself, it i
It is l,
7 is pumping the 95 gallons per minute up to the top.
a f
8 pumping up to 160 gallons per minute on this line that goes
!.{'
9 straight across through valve 17, et cetera.
4 10 THE WITNESS:
Yes.
I i
THE COURT:
Now, you have the same thing 11 i
l 12 happening here in 3020, you have the same flow, the same t
13 pipes and this diagram has the line identically open.
It N
i 14 is now shaded in blue but whereas heretofore it was shaded i'
15 in red.
4 16 THE WITNESS:
Well, the shaded I
17 THE COURT:
Are you saying to me that the flow
~
s d
18 that is listed here that is going through these lines now i
19 comes from a different source?
t i
THE WITNESS:
Yes, sir, that's exactly what 20 21 THE COURT:
Coming from a dif ferent source?
22 THE WITNESS:
Yes.
It can't comet out of here 23 any more.
24 This red and green mixtu're is the water that's c
\\d 25 being added from resurge and is trapped in the tank and SOUTHERN DISTRICT REPORTERS.U.S. COURTHOUSE FoLEY SQUARE. NEW YORK. N.Y. - 7911020
.~.
,=y
-y4, ye g
.-,p-,.r-p
-e--.,-e.
+w-h.
a-
,,,e.eg gr.p
-m-- - - - -
- =..
jbp t7 Frederick-direct 3522 1
water that is still coming from the system to the return 2
is y
t 3
THE COURT:
That doesn't show that it is trapped i
4 in the tank.
This valve is opened here, 137.
I would i
5 think a diagrammer if the valve was closed, would have had 6
the little thing which is obviously hinged at the upper 7
right, correct?
8 THE WITNESS:
Yes.
l 9
THE COURT:
It is hinged right there.
If that 10 were diagramed as closed, it would be hinged up against the 11 bottom of the make-up tank, right?
Right.
Showing that it 12 had in fact closed instead of being a 45 degree angle down.
13 THE WITNESS:
No, sir.
The check valve position 14 change is not indicated on the standard schematic.
It has 15 to be understood.
16 THE COURT:
But you are saying to me then there i
17 should be some way on this chart of showing me that this 18 valve was in fact closed.
19 You see, closed valves here are marked like the 20 big ones, are marked in black when they are closed and they I
21 are not marked in black when they are open.
22 THE WITNESS:
That's a standard schematic.
j Are you telling me that a check 23 THE COURT:
]
24 valve is left in the same position on a chart whether it is l
25 closed or open?
SOUTHERN DISTRICT REPORTERS.U.S. COURTHOUSE FoLEY SQUARE, NEW YORK. N.Y. - 791.1020 e-e - w.
% -* <* w var e,em pe.- e-.*e.%s r
ww
+-.,y.-
..%s,t...,m....
,m.
,% 9 %
,s
.,,,a
. ~., ~ - _.,
jbp t7 Frederick-dircct 3523 1
THE WITNESS:
That's correct.
2 THE COURT:
So that one reading the chart can't 3
tell whether it is closed or open, that's what you are 4
telling me?
5 THE WITNESS:
One can tell if he understands how i
6 the system operates.
7 THE COURT:
But the chartist has not gone to the 8
trouble to tell you that, is that what you are telling me?
t 9
THE WITNESS:
That's correct.
i 10 THE COURT:
You saying that notwithstanding that 11 the same amounts go through the same lines, apparently 12 coming from the same pumps, that, in fact, those lines are c--
13 no longer being furnished water from the make-up tank?
[v 14 That's what you are telling me.
They are getting it from 15 some other source?
16 THE WITNESS:
That's correct.
That's the design 17 of*the system.
18 THE COURT:
Oka y.
I'm sorry to get back to this.
19 I just want to understand these charts.
20 MR. SELTZER:
I'm pleased, your Honor.
I can 21 see that you were looking at that and I would rather clear 22 1.t up if we can.
23 MR. KLINGSBERG:
In case your Honor wants to 24 look at it, at 1913 and 1917 Zewe, who talked about these lg 25 charts, initially explained the same thing.
j.
soumERN DISTRICT REPORTERS.U.$. C071 MOUSE FoLEY SQUARE. NEW YORK, N.Y. - 191 1020 l ;:
t l
..~ _
jbp t7 Frsderick-dircct 3524 1
THE COURT:
Thank you.
N,/
2 MR. KLINGSBERG:
1912 but I think it starts on 3
1911.
4 Q.
You said, Mr. Frederick, that you did receive
{.
5 training on a change that was made in the procedure for 6
handling a small break loss of coolant accident in 1978.
7 Did you have any understanding as to where, in 8
what company that change of loss of coolant accident l
9 procedure originated?
10 A.
Yes.
It came from B & W.
11 Q.
I would like to show you what has.been 12 previously marked as GPU Exhibit 2074.
13 Can you identify this document?
14 A.
Yes.
15 This is a letter which is from Mr. Floyd who was 16 the operation supervisor or supervisor of operations 17 explaining that Unit 2 operation department personnel had 18 reviewed the change that you just described and the fact 19 that everybody understood it and that the equipment had l
20 been physically located.
That the people had signed here 21 understood it.
l 22 Q.
It indicated what, I'm sorry?
23 A.
It indicates that the change, the 22021.3 had e's 24 been reviewed and that the equipment involved in the change
'./\\)
)
25 had been located by the people who initialed the sheet.
SOUTHERN DISTRICT REPORTERS.U.S. COURTHOUSE FOLEY SQUARE. NEW YORK. N.Y. - 791-1020 n
jbp t7 Frcdsrick-dircet 3525 (s..
1 Q.
What is the change referred to here?
2 A.
That's the small break LOCA change that B & W 3
recommended to our loss of coolant accident in 1978.
I 4
Q.
And is the second page of the document a signoff 5
sheet?
6 A.
Yes, it is.
7 Q.
Are your initials on it?
8 A.
Yes, they are, the right-hand column near the 9
center.
10 Q.
What do your initials indicate?
11 A.
It indicates that I reviewed and understood the 12 change and I had located the equipment and understood the I, -
13 terms, dedicated CRO and that sort of thing, that applied 14 to the procedure.
15 Q.
Was this a procedurc change that had any effect 16 on the connection of high pressure injection during a loss 17 of coolant accident?
18 A.
nsd any change in the connection of it?
19 Q.
In how HPI was connected or cross connected?
20 A.
Oh, yes.
21 The procedure change mandated a change to the 22 standard or the standard operating valve lineup that closed 23 the discharge cross connects on make-up pump between B and TE[
24 C pumps.
)
,/
25 Q.
Apart from this information on HPI during loss l
s SOUTHERN DISTRICT REPORTERS.U.S. COURTHOUSE FOLEY SQUARE, NEW YORK. N.Y. - 791 1020
.l
. J l
~~
~-
jbp t7 Frcderick-direct 3526 1
of coolant accidents, did you receive any other suggested Ok,j 2
changes from Babcock-& Wilcox in 1978 or 1979 before the s
3 accident affecting the operation of HPI?
4 A.
I don't specifically recall any now, other than 5
this recommendation here.
6 Q.
I'd like to turn now to an event that took place 7
on December 2, 1978.
8 Do you recall that there was a reactor trip on 9
December 2, 1978?
10 A.
I knew there were transients in that timeframe 11 but the date doesn't really signify any particular event.
s 12 Q.
Let me show you the licensee report for that i
13 transient, marked GPU 2059 for identification.
d 14 Do you recognize this report?
15 A.
Yes.
16 This is just a description of the transient and 17 the initiating events for the December 2 trip.
18 Q.
Did you see this report in the regular course of 19 business?
20 A.
Yes.
This was part of our required reading.
21 Q.
Can you tell -- withdrawn.
22 Did you learn whether high pressure injection 23 had automatically initiated during this reactor trip?
24 A.
It did occur during this transient after the 25 reactor trip, yes.
SOUTHERN DISTRICT REPORTEAS. U.S. COURTHOUSE FOLEY SQUARE, NEW YORK. N.Y. - 791.1020 l
.x jbp t7 Frsderick-dirset 3527 1
Q.
What did you understand had caused high pressure
.(.
2 injection to actuate?
x-l 3
A.
This was an overfeed transient due to blocked I
4 open, I mean, feed regulating valve and the overfeed of the l
5 steam generators is what initiated the transient that 6
caused the ES to actuate after the reactor trip.
7 Q.
Do you recall a reactor trip that took place on 8
November 7, 19787 Again, the dates aren't that -- aren' t part of 9
A.
10 my recollection.
I just usually recall what occurred 11 during the transient and not necessarily the date that it 12 occurred on.
13 Q.
Let me show you what has been marked as GPU
(
14 Exhibit 2060 for identification and ask you if you 15 recognize this -- excuse me, 2160.
16 A..
Yes.
I remember this was a reactor trip and 17 ECCS actuation caused by the initiating event was the 18 heater drain pump trip.
19 Q.
Did you review this Licensee Event Report GPU 20 2160 at or about the time that it was issued?
f 21 A.
Yes, I did.
22 Q.
And did you say that HPI had automatically 23 actuated during this event?
1 24 A.
'Yes.
l T,-
/
25 Q.
Did you receive training on this event?
s,,
l SOUTHERN DISTRICT REPORTERS.U.S. COURTHOUSE-l FOLEY SQUARE. NEW YORK. N.Y. - 791 1020 e
'..,4 1y 9
@+
v
jbp t7 Frsderick-direct 3528 1
A.
Yes, along with the review, we were trained on 2
transients like this to review the panel indications and 3
see how the transient progressed, review something like 4
this on.the panel.
5 Q.
What was the point of that review?
6 A.
Just to insure that I understood both the i
7 automatic and the operator response to a transient like 8
this.
f 9
Q.
You said that there was an automatic actuation 10 of high pressure injection.
4 11 Was there also a reactor trip?
12 A.
Yes.
~
13 Q.
Did you ever learn in connection with this event 14 on November 7, 1978, that the reactor coolant system may 15 have had some limited saturation at a time when pressurizer 16 level was below the bottom of the readable scale?
17 A.
I don't remember any reference to saturation in 18 the training that I ever received.
19 Q.
If you had been told that there had been such 20 limited saturation at a time when pressurizer level was 21 below the bottom of the readable scale, would that have 22 been useful information for you on the day of the accident?
23 MR. FISKE:
I object to that, your Honor.
t.
24 THE COURT:
Yes.
Sustained.
J 25 Q.
Do you recall an event that took place on April SOUTHERN DISTRICT REPORTERS.U.S. COURTHOUSE FOLEY SQUARE. NEW YORK. N.Y. - 7911020 l
.-.a s
.-~-,$_.
~
jbp t7 Frederick-dirset 3529 l
1 23rd, 1978?
O 2
A.
That particular day I do remember, yes.
l i
3 MR. SELTZER:
I would like to mark for 4
identification GPU Exhibit 2061, the Licensee Event Report i
5 for the April 23rd, 1978, event.
6 Q.
Can you identify GPU Exhibit 20617 7
A.
This is the same type of report about the 8
transient that occurred on April 23rd in which there was a 9
reactor ' trip due to an NI failure and then a subsequent j
10 ECCS actuation.
11 s
Q.
Did this event involve the steam safety valves 12 in any way?
13 A.
Yes.
14 What happened af ter 'the reactor trip, subsequent 15 to the turbine trip, it caused a rise in the steam pressure 16 and the steam safety valves opened and some of them failed 1
17 to reset.
And that caused an overcooling and an ECCS 18 actuation.
19 Q.
Was a review of this Licensee Event Report 20 included in any of your training?
21 A.
Yes.
22 This was a report that I was familiar with and 23 the same type of training that I had on the other incidents 24 plus there were reports issued about this one that I 25 reviewed.
SOUTHERN DISTRICT REPORTERS.U.S. COURTHOUSE FOLEY SQUARE. NEW YORK, N.Y. - 791.1020
.=________________"________m___
->r't
=
- ete
~
^ * = = -
-%*-3
~=
wv_*r.m-4em**
N ma w = - wg-w gw - mo e--=Ww e =
-essi==
oo
jbp t7 Frederick-direct 3530 Is this the event that you were describing in J
1 Q.
yesterday's testimony where you were the panel operator who 2
3 initiated second make-up pump and then throttled back on l
a 4
high pressure injection?
5 A.
Yes.
6 Q.
Will you turn to the fourth page of Exhibit 2061 7
where there is a narrative of the event and I would like to 8
call your attention to the fourth paragraph beginning with 9
the words "the operator", do you see that?
10 A.
Yes.
11 Q.
It says there:
"The operator took the proper 12 immediate action in manually cutting back feedwater demand 13 shutting the letdown isolation valve, starting a second 14 make-up pump and opening the high pressure injection valves 15 on the side of the operating make-up pumps".
16 Were you aware that there was that appraisal of 17 the operator's conduct in the Licensee Event Report?
18 A.
Yes.
19 Q.
And who was the operator that's being referred 20 to there?
21 A.
Myself.
22 Q.
Yesterday you testified that you were aware that 23 there was a B & W appraisal of your conduct during this 24 transient.
25 I'd like to show you GPU Exhibit 2048 for i
x SOUTHERN DISTRICT REPORTERS, U.S. COURTHOUSE FoLEY SQUARE. NEW YORK. N.Y. - 791 1020
' 7' ' "
~'J
~~ ~
~ ~~n
~ ~ - - ~
~ ---
~ ~
~ "
' ~ ' ~
~ ~ ~
~
_...,_m.
jbp t7 FrGdorick-diroct 3531 1
identification -- excuse me, it is in evidence.
2 A.
Yes.
3 Q.
At the top of page three of a letter from L.C.
j
]
4 Rogers, the B & W site operations manager, to Gary Miller, 5
the station's superintendent at Three Mile Island, and it 6
states:
" Based on the arguments and observations outlined 7
above, B & W's conclusion is that the pressurizer was never 8
emptied.
It appears that only the operator's timely i
9 initiation of HPI prevented this from occurring, but the 10 data seems.to support our contention that the pressurizer 11 was never entirely drained".
12
, Is this the report from B & W that you were 1.
s 13 referring to yesterday?
14 A.
Yes.
15 Q.
And who was the operator whose timely initiation 16 of HPI was being commented upon as you understood this 17 document?
18 A.
That was me.
19 Q.
From the comments -- withdrawn.
20 Do you recognize the chart that is the fourth 21 page of GPU Exhibit 2048 as the same chart that we were 22 discussing yesterday?
23 A.
Yes.
F 24 Q.
From the comments that you received from Babcock 25
& Wilcox and Metropolitan Edison, did you believe that you SOUTHERN DISTRICT REPORTERS.U.S. COURTHOUSE FoLEY SQUARE NEW YORK. N.Y. - 791-1020 t
.r.
~
m.
m.
jbp t7 Frcdorick-dirset 3532 l
had handled the high pressure injection and pressurizer 7-~
2 level correctly on April 23rd?
s, 3
A.
Yes, I did, both the evaluations had stated that 4
I had taken the proper actions, 5
Q.
From the comments by B & W and the chart that B j
l 6
& W attached to GPU Exhibit 2048, what, if any, i
7 understanding did you have about whether your throttling of 8
HPI had been consistent with what should have been done?
i 9
MR. FISKE:
Can I hear the question again?
10 (Record read) 11 THE COURT:
You may answer.
12 A.
I understood that my actions were consistent x
13 with what was expected and what was considered the proper 14 response for the indications that were present on the panel.
l'5 Q.
What's the role, if anything, of previous 16 successful handling of a transient situation in an 17 operator's mind?
18 MR. FISKE:
I will object to that, your Honor.
19 The April 23 transient was a totally different transient.
20 It was an overcoolant.
21 THE COURT:
I will sustain that objection.
22 Q.
What was the event that led you to start a I
23 second make-up pump as shown on the last page of B & W's 24 letter, GPU Exhibit 2048?
(
25 A.
In response to the reactor trip, I was taking SOUTHERN D!$TRICT REPORTERS.U.S. COURTHOUSE FoLEY SQUARE. NEW YORK. N.Y. - 791-1020
jbp t7 Frodorick-dirset 3533 1
actions dictated in the reactor trip procedure which
(
'N 2
dictate that I should attempt' to control the pressurizer 3
level using the make-up system and so, in response to the 4
drop of pressure, I was controlling high pressure injection.
5 Q.
What was motivating your action when you 6
throttled high pressure injection at the point at which it 7
is indicated on the last page of B & W's report and j
8 throttled high pressure injection?
9 MR. FISKE:
I think the record should reflect 10 that the throttling reduced the flow from 1000 down to 500 11 pounds per minute.
12 Q.
Can you indicate what was the throttling that
's 13 you did?
%Y 14 THE COURT:
And what was your motivation to do 15 it?
16 A.
The motivation was that the pressurizer level 17 was recovering and the continuing full' flow was not 18 necessary and if I reduced flow to 500 or so to start 19 tapering back on high pressure injection, then I could move 20 smoothly into a control mode, that is, a smooth transition 21 back into normal control of the pressurizer level by 22 steadily decreasing the high pressure injection flow as we 23 approached the 100 pound set point.
~
'"P 24 Q.
What happened to the reactor coolant system k,)
25 pressure at the time you throttled high pressure injection SOUTHERN DISTRICT REPORTERS.U.S. COURTHOUSE FOI.EY SQUARE NEW YORK. N.Y. - 791-1020 1
-.-~,.n g-+..,
- n -- -. -..
_ ~.
jbp t7 Frederick-dirGet 3534 l
1 en April 23rd?
N 2
A.
The chart shows that it was decreasing.
3 Q.
Did you understand from this document that B&W 4
had reviewed your conduct in handling HPI as depicted on B 5
& W's chart?
l f
f 6
THE COURT:
Please, Mr. Seltzer, he's already 7
told us that he understood that referred to him.
All right.
8 Let's not go into that again.
i s.
9 MR. FISKE:
This is a 30-second time period in I
i 10 any event, your Honor, that we're talking about when it was 11 going down.
12 THE COURT:
Put another question.
13 Q.
Did the reports which you received on your 14 handling of high pressure injection on April 23rd effect 15 your understanding of how you should control high pressure 16 injection following subsequent reactor trips?
I 17 A.
Yes.
18 It indicated to me that the actions that I was 19 taking were proper and I should continue them in the future.
20 If I saw the same situation, I would do the same thing.
21 Q.
Do you recall that there was an event at Three 22 Mile Island Unit 2 on March 29, 1978?
23 A.
Yes.
~
24 Q.
Did you receive training on that event?
25 A.
Yes, we did.
,j/
SOUTHERN DISTRICT REPORTERS U.S. COURTHOUSE FOLEY SQUARE. NEW YORK. N.Y. - 791-1020 v
..=
--m w
e
-w
-ww w
w w- - - =
ww'---etww-te-=
~v-=AP w-v + + v e gr--evy-~e--
t-e-"wwevs-*TH' t
"*We
's
l jbp t7 Frsdorick-dirset 3535
)
1 Q.
What was the event?
y_
,f 2
A.
The event on March 29, 1978, was a loss of power 3
to vital power supply and that caused -- also loss of bus 4
on quite a few of the indicators on the panel, and the 5
I guess I remember the significant event is 6
the loss of vital power.
I can't recall the entire 7
scenario right now.
8 Q.
Do you know if the indication on the pressurizer 9
level gauge was effected by the loss of power?
10 A.
I don't think it was.
11 Q.
In your training, what, if any, significance did 12 you attribute to the March 29 event?
i,..
13 MR. FISKE:
I don't think Mr. Frederick has yet 14 described what it was other than a failure of some bus.
I 15 think we ought to learn a little bit more about it.
16 THE COURT:
It is premature.
17 Q.
From your training, what did you learn were the 18 most significant features of the March 29, 1978, event?
19 A.
The most significant feature was the training 20 and -- what we learned from it was on loss of the vital bus, 21 some of the indicators would fail in different directions i
22 and we.had to be able to identify through the loss of a 23 vital bus which instruments would be ef fected.
.r-24 We were instructed to identify the power supply (W) 25 for each indicator so that if a vital bus failed in the SOUTHERN DISTRICT RESCRTERS.U.S. COURTHOUSE FOLEY SQUARE. NEW YORK. N.Y. - 791 1020 i
-.- ~
I l-
___.._________m_m__
O
1 jbp t7 Frederick-direct 3536 1
future, we could identify the common failure on instruments 2
which come from the same power supply.
We also had I
j 3
additional panel instruments' installed to indicate the
(
l i
4 position of the equipment that had failed as a result of S
the transient.
6 Q.
In the March 29, 1978, event, was there any 7
ef fect on the operation of the pilot-operated relief valve?
8 A.
Yes.
As a result of the power loss, the 6
9 pilot-operated relief valve opened.
10 Q.
Could you explain just succinctly how that 11 happened, how you, understood that happened?
12 A.
The signal that feeds the control for the 13 pilot-operated relief valve was fed f rom a vital ' power 14 supply, that is a normally uninterruptable power supply.
15 When it lost power, it gave a f alse signal to the 16 pilot-operated relief valve to open which is not as a 17 result of pressure but as a result of the control signal 18 failure.
It told the valve'to open and it opened.
19 Q.
Is that the same as saying that its fail safe 20 position was a failed open position?
21 A.
That's one way of saying it, yes.
22 Q.
Do you know whether there was any change in the 23 electrical logic to the pilot-operated relief valve after 24 the March 29, 1978, event?
A 25 A.
I know that there were some wiring changes but 50UnHRN DISTRICT REPORTERS.U.S. COURTHOUSE FOLEY SQUARE. NEW YORK. N.Y. - 791.1020
- i.
____________.___L.
jbp t7 Frsderick-direct 3537 1
I'm not really familiar with the details.
2 Q.
After the March 29, 1978, event, what, if any, 3
additional instrumentation was installed in the control i
I 4
room with respect to the pilot-operated relief valve?
l t,
]
5 MR. FISKE:
I think we went through that 6
yesterday.
It was the' light.
We'll stipulate to that.
7 MR. SELTZER:
I'm not sure that we had done that, 8
but fine.
9 Q.
Turning to a dif ferent point.
Before the accident did you have any knowledge f
10 i
11 whether any of the valves on the top of the pressurizer 12 were leaking?
13 A.
Yes.
14 The reason that I was doing the manual operation 15 with the pressurizer system as I described yesterday were 16 because it had been determined that one of the valves on 17 top of the pressurizer was leaking.
18 Q.
Was it part of your responsibility to determine 19 which of the valves on top of the pressurizer was leaking?
r 20 A.
No, that determination was made by the 21 engineering department, based on the data that was supplied 22 them from the control room.
23 Q.
Did you have any understanding as to whether the engineering department was receiving any data from the 24
/
\\/
25 control room?
$ouTHERN DISTRICT REPORTERS.U.S. COURTHOUSE
-j _
FoLEY SQUARE. NEW YORK. N.Y. - 791 1020 3
w
,----c..
-4.---,.-,...w--
,y-ww,,a-e J. e -g-w.
.w-e,-
jbp t7 Frederick-dirset 3538 1
A.
Yes, they were.
We would package information 2
for them every night and give it to them in the morning.
3 Q.
Among the data that you were packaging for the
)
4 engineering department, what pieces of data contained 5
information that would be applicable to determining leakage
'6 from the top of the pressurizer?
l 7
A.
Well, besides this specific package that we sent l
8 them, they were reviewing leakage data by itself.
i 9
We sent them chart recorders and -- those on I
10 panel 10 over by the clock.
Of course, the information we l
l l
11 accumulated on the morning reports was available for them.
12 Q.
What information was on the morning reports that 13 would be useful in reviewing leakage at the top of the
- 14 pressurizer?
15 A.
We took daily readings on the relief valve 16 discharge temperatures and posted them on the morning 17 report.
18 The temperature report I'm referring to is one 19 that also prints out that data and it can be reviewed.
20 Q.
What type of temperature recorder are you 21 referring to?
22 A.
The analogue recorder on panel 10 that monitors 23 those continuously.
Strip chart report.
24 Q.
You say it was an analogue recorder on panel 10.
g 25 What were the data points that were reflected on SOUTHERN DISTRICT REPORTERS.U.S. COURTHOUSE FoLEY SQUARE. NEW YORK. N.Y. - 191-1020
_.,, ~ _ _ _ _ _ _ _ _ ~ _ _. _.,
r
____.___1.____O..___
e jbp t7 Frgdorick-direct 3539 1
that analogue recorder?
2 A.
It is a -- there are many, many points on the 3
recorder, 50 or 60 or so.
And it records all kinds of 4
leakage data from specific points in the waste disposal l
systems, most of the stuf f or if not all the stuf f that i
5 goes into the reactor coolant drain tank and other leakage 6
w 7
collection drain points.
8 Q.
Were you informed before March 28, 1979, as to which of the valves on top of the pressurizer was leaking?
9 i
10 A.
Well, as I said, it was engineering who was 11 making that determination.
It is my understanding that s
12 some of the supervision and engineering thought it was code it was "s{
13 safety, one of the code safeties and some thought 14 the PORV.
The determination had been made that it was or 15 16 at least it appeared that the determination they made was 17 because they got a code safety in the warehouse.
18 Q.
When you say there was a determination, what do 19 you base that understanding on?
20 MR. FISKE:
That's what I was going to ask and 21 not Mr. Frederick to sum up the evidence but simply what he 22 was told and by whom.
23 MR. SELTZER:
That's all I want to elicit.
24 Q.
What do you base your understanding that v
25 somebody had identified it as a code safety valve that was SOUTHERN DISTRICT REPORTERS U.S. COURTHOUSE FOLEY SQUARE. NEW YORK. N.Y. - 1911020 f
-~...,_..._.
jbp t7 Frsderick-dirGct 3540 1
leaking?
f 'N 2
MR. FISKE:
In all due respect, I think the s~-)
3 question is who told him and what did he tell him.
j 4
MR. SELTZER:
Exactly.
5 THE COURT:
No, your question was more general.
6 Who told you it was a code safety?
i 7
THE WITNESS:
I knew just from my discussions in 8
the Operations Department that the code safety had been 9
identified in the warehouses as available for the upcoming 10 outage.
It was an outage item that had been selected.
I 11 was aware of work that was being planned for the outage.
12 Q.
Do you know whether any replacement valve for
/
13 any of the valves on top of the pressurizer had been
)
14 located?
y 15 A.
Yes.
The A code safety valve had been located 16 in the on site warehouse, spare parts warehouse.
17 Q.
Did you have any understanding what that spare 18 code safety valve had been located for?
What they were 19 going to do for it?
20 MR. FISKE:
It seems to me the question is who 21 did he have these conversations with and what did they say?
22 THE COURT:
I will sustain that objection.
23 Q.
How did you know that there had been a search in 24 the warehouse for a replacement pressurizer code safety 25 valve?
l SOUTHERN DISTRICT REPORTERS.U1 COURTHOUSE FOLEY SQUARE. NEW YORK. N.Y. - 791-1020
jbp t7 Frederick-dirset 3541 1
THE COURT:
No.
Who told you?
Who told you and 2
what were you told?
3 THE WITNESS:
I'm fairly sure that I remember 4
receiving information through a watch turnover but I don' t 5
knew who I was relieving at the time.
In other words, as 6
we come in on-shift, we get information concerning jobs 1
L 7
that are done and the jobs that are planned, from the 8
person that we relieve and you get a list of information.
9 That's where I got information of that kind and I just 10 don't know who it would have been, what individual person 11 would have been that I was talking to because I relieved a 12 different person every few days.
i.
13 Q.
Did you ever see a letter from Lee Rogers to T
14 Gary Miller which said on March 23, 1979 --
15 MR. FISKE:
Did he ever see the letter, Mr.
16 Seltzer?
17 Q.
That a spare code --
18 MR. FISKE:
Wait a moment.
Did he see the 19 letter?
20 THE COURT:
Yes.
21 Did you see the letter?
22 THE WITNESS:
I have seen letters and lists like l
23 this, but specifically to say I have seen this list would 24 not be part of my recollection.
I have seen ones like this.
Lf 25 Q.
You' referred to morning reports.
5 sotm!ERN DISTRICT REPORTERS.U.S. COURmOUSE FoLEY SQUARE. NEW YORK. N.Y. - 791 1020 l
.-._...-., m.. - _. -.
jbp t7-Frcdorick-dircet 3542 1
Did you ever participate in filling out the 2
information in the morning report?
3 A.
Yes.
4 Q.
Were you familiar with the tailpipe temperatures l
5 that were being reported in morning reports prior to the 6
accident?
7 A.
Yes.
If I didn't make the recording on the
~
8 report, I at least gave the data to Mr. Scheiman so he 9
could record it.
I was aware that it had to be withdrawn i
10 from the panel every day.
11 Q.
What was your understanding, if any, as to what 12 temperature you would see in the tailpipe or discharge pipe 13
.beyond the pilot-operated relief valve if it were leaking?
/
I 14 A.
It would be elevated above its normal 15 temperature by some amount, depending upon the size of the 16 loop.
17 Q.
What did you understand -- withdrawn.
18 From your review of data in the control room and 19 from filling out morning reports or seeing morning reports, 20 what had you observed was the temperatuee being recorded 21 for the pilot-operated relief valve discharge pipe before
{
j 22 the accident?
i 23 MR. FISKE:
For how far back, Mr. Seltzer?
'24 Q.
Going as far back as you remember the plant was
.b 25 in service?
U SOUTHERN DISTRICT REPORTERS, U.S. COURTHOUSE FOLEY SQUARE, NEW YORK. N.Y. - 7911020
,. - ~
i s_
m
jbp t7 Frcdorick-ditGet 3543 1
A.
It was in the 170 to 190 range.
2 Q.
You testified a moment ago that from information 3
you received on-shift'changeoffs from possible documents 8
4 that you had seen, you knew that a code safety valve had l
f 5
been located to replace a leaking code safety valve on Unic 6
2.
7 Did you have any personal knowledge one way or 8
the other as to whether or not it was a code safety valve 9
or a pilot-operated relief valve that was leaking on the 10 top of the Unit 2 pressurizer?
I l
l 11 A.
Well, I knew that it was one or the other.
It 12 was just not part of my job to figure out which one it 13 would be.
I knew that the engineering department was
- T y) 14 making a determination.
15 (Continued on next page) 16 17 18 19 20 1
21 22 23 24 r- -
O' SOUTHERN DISTRICT REPORTERS,U1 COURTHOUSE FOLEY SQUARE, NEW YORK. N.Y. - 791-1020
Ih t8 Frsderick - dircct 3544 1
Q.
Did you have any opinion before the accident as i
/~~
/
2 to how it could be determined which valve was leaking?
\\
3 A.
I think so.
By cycling the pilot operated 4
relief valve block valve, you could take a leakage 5
determination and see if it made any difference while the 1
6 valve was shut.
8 i i 7
Q.
Were you aware of any discussions at the plant 8
about whether to cycle the, block valve?
9 A.
Yes, there are some that felt that if you close s
10 a block valve, it would stick, stick shut.
i I
11 Q.
Did you have any training before the accident as i
12 to what action should be taken if it was suspected that a 13 pilot operated relief valve was leaking?
14 A.
Well, it would be very similar to what I just 15 told you.
If you have suspicion that that valve is leaking, i
16 contributing to your leakage in the system, then you could l
17 cycle the valve to get a leakage determination and then i
i 18 that would tell you whether there was a real problem or not i,
{
19 as far as leakage goes.
Just shut it, take the leakage I
I 20 reading.
I 21 Q.
Where did you receive that training?
f 22 A.
I picked it up first at B & W.
23 Q.
Let me show you what's previously been marked as I
24 GPU Exhibit 2165, which is the OFR procedure for 25 pressurizer abnormal operations.
You testified yesterday SOUTHERN DISTRICT REPORTERS.U.S. COURTHOUSE FOLEY SQUARE. NEW YORK. N.Y. - 791 1020 p... +...,, -.
v.
.. + - ~ ~
.~.
- .........,m.,
s-lh t8 Frsdorick - direct 3545 1
that this was the procedure that you used when you were at 2
the simulator for the two-month training program.
[\\
1 3
Let me show you a copy that I have which is 2165.
4 marked for identification yesterday.
Do you see the 5
section that deals with a leaking pilot operated relief 6
valve?
7 A.
Yes.
8 Q.
What does that B & W Old Forest Road procedure 9
say about when, i f ever, you have to close a block valve if 10 the PORV is leaking?
11 A.
It gives as an action after you determine that
-12 there is a leaking valve in there.
It says "close the 13 relief valve block valve if leakage is g'reater than that v
i
~14 allowed by technical specifications."
15 Q.
Is that the procedure on which you were trained 16 during the two-month training course that you had at B & W7 17 A.
Yes, these are the ones that we had to memorize 18 for the initial test.
19 Q..
It refers to leakage in excess of that allowed 20 under the technical specifications.
Were you familiar at 21 the time that you were at the two-month B & W training 22 course with Met Ed's technical specifications on E11owable
(
23 leakage?
24 A.
Yes.
We were using the Metropolitan Edison 25 TMI-2 technical specifications.
=
SOUTHERN DISTRICT REPORTERS.U.S. COURTHOUSE FoLEY SQUARE, NEW YORK. N.Y. - 791.1020 i
~..... -. - -,.., - _..
4
_ _. ~
~<
w n
.g m,
s.
+e-
_,_.-*e--,.w--v._a.
+ - - - -
,p p,
wy -. y
,-h-
1h t8 Frodorick - dirset 3546 1
Q.
At the time that you were being trained on this 2
procedure which says close the block valve if the leakage 3
through the PORV exceeds text specs, what was the allowable 4
text speck leakage?
This would be leakage coming from a 5
valve at the top of the pressurizer.
6 A.
Yes.
I think it was 10 GPM.
I could review the 7
text spec to refresh my memory a little bit.
It's been 8
awhile since I had to use them.
I think it is 10 GPM.
9 Q.
If the leakage were less than 10 GPM, subject to 10 correction on whether the amount is right, what did you 11 understand from the OFR procedure was required with respect 12 to the block valve?
13 A.
If your PORV is not exhibiting a leakage problem O
14 which is in excess of that which is allowed by the 15 technical specifications, you can leave the block valve 16 open.
If you start exceeding that limit, then you are 17 going to have to leave it shut.
18 Q.
When I was asking you a minute ago about what 19 your opinion was of what should be done at TMI-2 just 20 before the accident, you said you thought they should cycle 21 the block valve to see if there was leakage from the PORV.
22 If the block valve had been shut and there was 23 the same amount of leakage, do you have an opinion as to 24 what should be done with the block valve then?
\\
25 A.
Yes, that would indicate that the PORV was not SOUTHERN DISTRICT REPORTERS.U.S. COURTHOUSE FOLEY SQUARE NEW YORK. N.Y. - 791 1020 6
.1
.,-n J
Ih t8 Frsderick - direct 3547 1
contributing to the leakage and you could leave it open.
b 2
Q.
Ta king it on the other hand, if the block valve 3
were shut and from readings that were taken it was l
4 determined that in fact the PORV had been leaking, did you 5
have an opinion on what should then be done with the block 6
valve?
7 A.
Yes.
Then as long as the leakage is not in 8
excess of the technical specifications, then you can leave 9
the block valve back open and reopen it.
10 Q.
What's your understanding, if any, as to whether 11 the allowable leakage limits in the text specs for TMI Unit 12 2 were the same in 1979 as they had been somewhat earlier 13 when you took the two-month B & W training course?
14 THE COURT:
Mr. Seltzer, can I ask how this is 15 relevant to our issues?
16
-MR.
SELTZ ER:
Yes, your Honor.
Counsel for B &
17 W have taken the position that under the procedures, if 18 there is detected leakage from the PORV, the block valve 19 should have been shut and left shut.
20 We are establishing that under B & W's own 21 drafted procedures under which this operator was trained 22 and all of our operators were trained, the instruction was 23 if the leakage is not in excess of text spec limits, then 24 the block valve does not have to be shut and certainly
\\
25 doesn't have to remain shut.
$OUTHERN DISTRICT REPORTERS.U.S. COURTHOUSE FoLEY SQUARE. NEW YORK. N.Y. - 791-1020
\\
t I
l 1h t8 Frsderick - dircct 3548 1
THE COURT:
But you went through a lot of 1
2 business about testing here before.
This does not have to kJ 3
do with this man's knowledge, but general principles.
Mr.
4 Zewe has given a lot of testimony about this.
On this last i
I 5
one, what are you getting into that for, whether there has 6
been a change for since '78 to '797
~
7 MR. SELTZER:
I will withdraw that.
8 MR. FISKE:
The other point, your Honor, this is 9
typical of what's gone on.
Mr. Seltzer hasn't asked Mr.
10 Frederick one question about the procedure that in fact was 11 in effect on the day of the accident.
Mr. Frederick has 12 testified that he went back to B & W in 1977 and then was 13 trained on the TMI-2 procedures as they were on the day of h
v/
14 the accident and Met Ed eliminated this language in the B &
15 W simulator procedures which B & W used for people that 16 didn't have any, Met Ed rejected that and adopted their own 17 procedure which specifically unequivocally says without any 18 talk of text spec limits if the PORV is leaking, close the 19 block valve.
20 Mr. Seltzer isn't even asking him about that.
21 He takes him back to some draft procedure at an earlier 22 stage in the simulato'r.
I think the crucial thing, the 23 important thing, is what was the procedure on the day of 24 the accident and how did Mr. Frederick understand that 25 procedure.
v SOUTHERN DISTRICT REPORTERS.U.S. COURTHOUSE FOLEY SQUARE. NEW YORK. N.Y. - 191-1020
1h t8 Frederick - dircet 3549 1
THE COURT:
How much more do you have of this
~s 2
witness?
Are you almost through?
h
,ss-3 MR. SELTZER:
We are almost finished.
4 "THE COURT:
Why don't you finish up with this 5
witness.
6 MR. SELTZER:
I think it is going to take -- it 7
might take half an hour to finish, but I could finish this 8
point that Mr. Fiske raises?
9 THE COURT:
What more do you have, because this 10 last little bit, we didn't need to spend time on this.
11 Let's go for a little bit or finish with this witness.
12 BY MR. SELTZER:
13 Q.
Could you open up your compendium of TMI-2
(
)
14 procedures to tab 5' which is pressurizer system failure 15 procedure.
16 A.
Yes.
17 Q.
Is this the procedure that would cover leaking 18 pilot operated relief valve that was in effect on the day 19 of the accident?
20 A.
Yes, it is, i
21 Q.
Which is the section that deals with a leaking 22 PORV?
23 THE COURT:
Mr. Seltzer, it is only going to 'be 24 of. value if you tie it in with.some action that he did or
'}
25 shou 1d have done or some thought that he had.
But just to SOUTHERN DISTRICT REPORYERS.U.S. COURTHOUSE FOLEY SQUARE. NEW YORK. N.Y. - 791-1020
lh t8 Frederick - dircct 3550 1
tell me what's in here is not needed.
i P"7 2
MR. SELTZER:
That's exactly what I am coming to.
(
3 THE COURT:
Let's go quickly.
j 4
Q.
Looking at section A, leaking pilot operated 5
. relief valve, what did you understand from section A, 6-leaking pilot operated relief valve, should be done if the I
7 operators operating pursuant to this procedure thought 8
there was a leak coming from the pilot operated relief 9
' valve within the 10 GPM text spec limit?
i i
10 A.
If you are not exceeding the limit, you can open 11 the valve, open the block valve.
12 Q.
The manual action says close the electromatic 13 relief valve.
7._
m 14 THE COURT:
Isolation valve.
)
15 A.
Yes.
16 Q.
How -do you construe that manual action if the 17 operators are closing it'because they believe there is a i
18 leaking PORV7 19 MR. FISKE:
Your Honor, it seems to me that the 20 procedure speaks for itself.
21 THE COURT:
I sustain that.
22 MR. SELTZER:
I don't see how it speaks for 23 itself.
24 THE COURT:
I assume the Court can read it as 25 well as anyone in this room.
.J l
souruman oismer msroarras.u.s. coummouse g
FoLEY SQUARE, NEW YORK. N.Y. - 791-1020 i
1-LM
-w..
ver e w
-e
-,y,==g m.
~***W=e**mapew+'m.m-wwow=e=4+ - v= e wr - we
..e- = e r=w e==4.-amp-
--__..-,..,,_,_,,.m-,,-,...-
lh t8 Frsderick - direct 3551 1
MR. SELTZER:
This is a technical document.
- 2 THE' COURT:
No.
He has added a condition, and 3
you are saying you want him to add this condition as he 4
sits here on the witness stand and urge upon me that that 1
5 is something that's in the writing.
You are saying how i
6 does he construe it.
There is nothing, it seems to me, to 7
construe, there is nothing to construe.
8 MR. SELTZER:
Your Honor, these are procedures 9
drafted for oper ators, operators who were trained on the i
10 operation of these systems principally by the vendor on how 11 to handle emergencies, and this is an emergency procedure.
12 Q.
Let me ask, what was the basis of your 13 understanding that you testified to on how this manual d.
14 action B-1 was interpreted?
i 15 MR. FISKE:
I object to that, your Honor.
We 16 are right back where we were before.
The procedure is very 17 simple.
If you have a leaking PORV, it says close the 18 block valve, period.
19 THE COURT:
Can I put two questions?
20 MR. SELTZER:
Certainly.
21 THE COURT:
Do you find anywhere under sections 22 A-1 or A-2 anything that permits you to not close this when 23 there is some leakage?
Is there any language that gives I
24 you that leave?
Do you find any such language?
25 THE WITNESS:
That says you should not close it
-g d
SOUTHERN DISTRICT REPORTERS,U.S. COURTHOUSE FoLEY $QUARE NEW YORK. N.Y. - 791-1:20 3
m-.
w-
.r ere-r--w-
,w-v--w wi,w-w
-ggwy---
w
---r
,-----g w--ee w
y w
e
--9--,t 9+g-~
t Ih t8 Frcderick - direct 3552 1
if you have --
2 THE COURT:
Yes, that says you don' t have to'
\\
l v'
3 close it, even if you have leakage.
Do you find any 4
language that says that, that under certain circumstances i
j 5
it can leak and you den't have to close it?
Do you find 6
any language that says that?
In here.
It is either on the I
7 page or it isn't on the page.
8 THE WITNESS:
It doesn' t say that you don' t have
~
9 to close it, but it doesn't say it must remain closed.
10 That's what I thought the point here was.
11 THE COUNT:
Okay.
12 THE WITNE'SS:
Maybe I --
13 THE COURT:
Put another question.
At least we 14 don't have any language to construe.
What's your next 15 question?
16 Q.
Was there anything else in the pressurizer 17 system failure procedure, in addition to the training you 18 received from Babcock & Wilcox, that led you to believe 19 that the block valve did not have to remain shut if it had 20 been closed to diagnose a leaking PORV?
21 A.
Other sections that refer to relief valve 22 leakage tell you that once you have made the leakage 23 determination, you can reopen.
Other sections which 24 require manual actions don't require that the manual r-- -
l 25 actions have no termination point.
O SOUTHERN DISTRICT REPORTERS.U.S. COURTHOUSE FoLEY SQUARE. NEW YORK. N.Y. - 191 1020
lh t8 Frsdorick - dirsct 3553 1
They say take the manual action and then it is
~'
2 just intrinsically implied that at some point you are going
\\'
3 to evaluate the length for which that manual action has to 4
be continued.
5 Q.
Can you give me an example of that?
6 A.
Sure.
Let's look at some of these other manual 7
actions here.
Look over here on inoperative pilot operated 8
relief valve page 2.
If you have a failed closed RC R-2 it 9
says " shift spray valve to manual and open.
Open further i
10 for additional spray flow."
11 MR. FISKE:
Your Honor, we are not talking about 12 spray flow.
There is a very simple one section, one page, 13 that tells you --
h 14 THE COURT:
I will sustain that.
Strike that j
v 15 out.
16 MR. SELTZER:
Your Honor, if I may be heard, the 17 witness is pointing out that there are other instructions 18 here, for example, "open further for additional" --
19 THE COURT:
Wait.
20 (The witness left the courtroom.)
21 MR. SELTZER:
"Open further for additional spray D. '
22 flow."
I take it he is suggesting that that is not a 23 command to leave the spray flow on indefinitely.
24 THE COURT:
No.
What you are doing is you are 25 trying to say that some practice had crept up that y
N.,Y SOUTHERN DISTRICT REPORTER $.U.S. COURTHOUSE FOLEY SQUARE NEW YORK. N.Y. - 191 1020
lh t8 Frederick - direct 3554 1
permitted this, and we all concede that this language 2
doesn't say that.
He said it doesn't say that.
He agreed.
Ur"'7 3
He said it doesn't say that.
He says it doesn't say how 4
long you have to keep it closed, but it doesn't say you can i
5 leave i t open if you have a leaking PORV.
If you have a I
6 leaking PORV, it says close.
He agrees that that is what i
7 he says.
8 MR. SELTZER:
But the jugular, if you will 9
permit me, your Honor, is that whether the PORV is leaking i
10 or not leaking, if they follow the immediate manual action 11 and close it, no matter whether it is leaking or not 12 leaking, they are going to reopen it.
Therefore, on March 13 28, 1979, the day of the accident, whether that was a 14 leaking PORV --
g 15 THE COURT:
Why would they open it?
The 16 followup action says repair it during the next shutdown.
17 MR. SELTZ ER:
They will do that, your Honor, but --
18 THE COURT:
Then until you have had a shutdown 19 where it is repaired, then I suppose the block valve should 1
20 be closed.
21 MR. SELTZER:
No, your Honor --
22 MR. FISKE:
It is meaningless if it says close 23 it and then open it 20 seconds later again.
What's the 24 po in t in opening it in the first place?
25 MR. SELTZER:
I will tell you what the purpose d
SOUTHERN DISTRICT REftRTERS.U.S. COURTHOUSE FOLEY SQUARE. NEW YORK. N.Y. - 1981020 e
n
.-m,--s mme s e -
p.,
.e
1h t8 Frsderick - direct 3555
-1 is.
It is a diagnostic step.
It helps diagnose whether 2
there is a PORV leak and then you can put in a repair 3'
ticket for it.
But if the leakage is within text spec 4-limits, why defeat the operation of a valve that was l
5 intended to protect the code safety valves?
6 The leakage is within all allowable limits, they 7
have diagnosed whether it is leaking.
Now open it and get 8
the advantage of having a pilot operated relief valve --
i 9
THE COURT:
Where is the text spec?
10 MR. FISKE:
The text spec doesn' t say anything 11 about the block valve, your Honor.
12 MR. SELTZER:
Here it is, page 3/4 4-15 under D, 13 it says --
14 THE COURT:
That doesn't say you can have 10 15 gallons leakage from the PORV notwithstanding pressurizer 16 system failure procedure 2205-1.5.
j 17 MR. SELTZER:
The technical specifications are 18 the paramount instruction on how the plant can be operated.
19 TLE COURT:
But 10 GPM I assume, Mr. Seltzer, 20 has to do with leaks from flanges, leaks from code safeties.
21 MR. SELTZER:
That's right.
It is the totality.
22 THE COURT:
When you get down to this specific 23 valve, this specific valve, they say if you have a leak, I
24 isolate the valve and fix it on your next shutdown.
That's 25 what it says.
~
SOUTHERN DISTRICT REPORTERS U.S. COURTHOUSE FOLEY SQUARE, NEW YORK. N.Y. - 791 1020 I
. -. ~
l
..--._._...n.. i.,.._ _ -,,.
.,..__...__t__,,_______._,___.____,,.._,.____,_,._,_..i n
lh t8 Frcderick - dircct 3556 1
MR. SELTZER:
Yes.
But --
2 THE COURT:
It doesn't say you can let it leak.
3 It says you close the block valve.
4 MR. SELTZ ER:
If there is a block valve there, 5
you might as we will see if the valve is leaking, but there 6
is no reason to defeat the operation of that valve if the
[
7 leakage is within operational limits.
?
8 THE COURT:
It might occur to somebody that one 9
of the reasons to do that is that -- Mr. gewe said if you t
10 leave these things leaking, after. awhile they become 11 damaged and then they don't function properly.
12 MR. SELTZ ER:
Apparently Babcock & Wilcox who 13 supplied the valve trained people that you didn't have to (Jl' 14 close the block valve at all.
15 THE COURT:
No, no.
The instructions that were 16 in the control room the night of the acci6ent were that the 17 leaking pilot operated relief valve, if it leaked, you 18 should have the block valve closed.
The instructions that 19 were in that room that night said that.
We all concede 20 that.
That's what this page says.
21 MR. SELTZER:
I absolutely concede that's what 22 the words say.
But the point that Mr. Frederick was making, 23 with all deference, your Honor, is that an instruction that 24 says do something doesn' t always in the context of the way r--
l fc g; 25 procedures are written have to tell you when it is time to i
t f
\\d SOUTHERN DISTRICT REPORTERS.U.S. COURTHOUSE Fot.EY SQUARE. NEW YORK. N.Y. - 791 1020
.~..
1h t8 Frcderick - dircet 3557 1
stop doing it.
Just as it says initiate spray, it didn't e
2 say when to suspend spray.
You don't have to leave the g'
\\
3 spray on until the room is flooded, pres umably.
f 4
THE COURT:
No, it does.
It does.
It says in 5
A-3, " Repair during next shutdown."
It does tell you when 6
is the termination point.
Close the valve, repair during 7
next shutdown.
8 MR. SELTZER: It doesn't say that you have to 9
leave it closed until the next shutdown, though.
You could 10 diagnose it, then open it and repair it during the next 11 shutdown.
We would be happy to submit that if B & W, the 12 vendor, had thought that this procedure mandated keeping 13 the valve shut, then I suggest that their simulator 14 procedure certainly would have said and they would have 15 been training.the operators that you must close it and keep 16 it closed.
17 Instead they don't even require as a diagnostic 18 step closing the block valve.
They don't even suggest that 19 it would be a prudent thing to do to close it just to check i
20 whether it is open.
They say don't even touch the block 21 valve unless the leakage exceeds text specs.
22 MR. FISKE:
Your Honor, that's incorrect.
That 23 was what was in that simulator procedure in 1976.
This 24 specific procedure was revised to eliminate that, an'd your 25 Honor was absolutely correct, that on the night of the j
SOUTHERN DISTRICT REPORTERS.U.S. COURTHOUSE FoLEY SQUARE. NEW YORK. N.Y. - 791 1020 L.
~*T
~~~
~
~
~
~
~
lh t8 Frederick - dirset 3558 1
accident in the control room they were told if you have a O
2 leaking PORV, close the block valve.
3 I might say, your Honor, that the NRC agreed
.l 4
completely with your Honor's recent analysis of this and 1
Ed for not having the block valve closed for l
5 they fined Met 6
precisely the argument that we are making here.
The procedure says if you have a leaking PORV, close the block 7
8 valve.
"This is your procedure, Met Ed, you adopted it, 9
you had it in the control room that night, and you didn't 10 follow it and therefore you are fined."
That's precisely 11 our argument here, your Honor.
12 THE COURT:
The evidence point that we had before us, which is this fellow is going to construe this 13 14 language, it doesn't seem to me that there is anything I am going to sustain the objection 15 there to construe, so 16 to any claimed instruction of that language, and we will be 17 in recess until 10:15 tomorrow morning.
18 (Court adjourned.)
19 20 21 22 23 I -
24 25 5
SOUTHERN DISTRICT REPORTERS.U.S. COURTHOUSE FOLEY SQUARE. NEW YORK. N.Y. - 791.1020
. w
l l
l 3559 1
l WITNESS INDEX l-2 Name Direct Cross Redirect Recross 3
Edward Russell Frederick 4
(Resumedi 3378-5 EXHIBIT INDEX 6
1 7
8
.9 10 11 12 13 14 J
4 15 i
16 i
17 1
18 19 j
20 -
21 22 23 i
1 i
I 24 j-n.
25
)
4 i
l SOUTHERN DISTRICT REPORTERS. U.S. COURTHOUSE FOLEY SQUARE. NEW YORK. N.Y. - 7911020 i
}
Q
--