ML20096D686

Response to TMI Alert First Set of Interrogatories & First Request for Production.Certificate of Svc Encl.Related Correspondence

ML20096D686
Person / Time
Site:	Three Mile Island
Issue date:	09/04/1984
From:	Blake E METROPOLITAN EDISON CO., SHAW, PITTMAN, POTTS & TROWBRIDGE
To:	THREE MILE ISLAND ALERT
Shared Package
ML20096D677	List: ML20096D673 ML20096D686
References
SP, NUDOCS 8409060243
Download: ML20096D686 (59)

Text

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""lDEnc;5 September 4, 1984

. UNITED STATES OF AMERICA -

NUCLEAR REGULATORY COMMISSION.

p-Before the Atomic Safety and Licensing Board 00CKETED USWC In1the Matter.of! ) '84 SEP -5 N154

. . )

METROPOLITAN EDISON COMPANY ) Docket No. 50-289 SP ,,. re-

. . ) (Restart-Remand on Management), e, i < >

(Three' Mile Island Nuclear ) ~ J,' .

Station, Unit No. 1) )

H LICENSEE'S RESPONSE TO THREE MILE ISLAND  ;: .

-ALERT'S FIRST SET OF INTERROGATORIES AND FIRST REQUEST FOR PRODUCTION I. INTRODUCTION On: July _31,L1984, Intervenor Three Mile Island Alert

-(TMIA) filedLits First-Set of Interrogatories to CPU Nuclear Corporation and its First Requent for Production. Shortly.

'thereafter, Licensee informed TMIA that it intended to request

^

a protective order with respect to a number of;the' discovery Erequests as exceeding the~ scope of the Restart proceeding. To facilitate discussion of Licensee's objections,-Licensee pro-vided TMIA with a. draft of the protective order it intended to request. On-August 13, 1984, Licensee and.TMIA met to discuss Licensee's objections, but were unable to reconcile their posi-

.tions'as to scope. However, Licensee and TMIA did agree to

-several clarifications to the mutual benefit of both parties.1/

1/ In fact, Licensee withdrew an intended scope objection to

. Interrogatory No. 9 in~ light of the agreed upon changes.

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B409060243 840904 PDR ADOCK 05000289 g .

PDR .

On August 15,L1984,-Licensee filed a Motion for Protective

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, ' Order [in;which,itobjectedto-TMIADocument-RequestNos. 1-6, and 9, and1to TMIA Interrogatory'Nos. 2-7, 14-22,.37-31, 34, 37-41, 48-51, and158. Licensee' moved that many of these re-

. quests be' limited.to documents or'information relating ~.to.the ,

~ generation'and subsequent combustion of hydrogen, the pressure

. spike, and the initiation of_ containment spray, all of which occurred,at TMI-2'at'approximately 1:50 p.m. on March 28, 1979.

Licensee also requested an extension of time.until September 4, 1984, in which to respond to TMIAs interrogato-Dries. 'In order to respond to many of TMIA's interrogatories, L

' Licensee had to canvass a.large number of-GPU and B&W employees. Although Licensee believes that it has no obliga-tion to obtainfinformation from former employees no" longer under Licensee's control, Licensee included such former employees in its inquiry and made a good ~ faith effort to ascer-Ltain their knowledge.

These' inquiries entailed a~ considerable effort. It took-

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Licensee about two weeks to digest'TMIA's interrogatories and to-prepare a_ thirteen-page questionnaire to be sent to present and- former employees. - Licensee also compiled a list of the names ~and addresses of individuals who might have pertinent -

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information.2/ The list included over 400 individuals and also j2/

s The list [ includes present and past GPU system and B&W employees whose name appeared in one or more of the following (Continued Next Page) 1

m

• - took/over two weeks to prepare.

Licensee's. document search and preparation of answers to interrogatories not dependent on the survey of employees pro-

ceeded concurrently with.the preparation of the questionnaire.

LSix employees have worked exclusively on the discovery requests for the past month, and a number of attorneys and members of GPU management have devoted considerable portions of their time to the requests.

On August 27, 1984, the Licensing Board informed Licensee by--telephone that Licensee's request.for an extension of time would.be granted. On August 29, 1984, TMIA notified Licensee that it was repudiating the clarifications to which TMIA-and Licensee had agreed. On August 30, 1984, the Licensing board (Continued)

-categories:

1. Specifically named individuals in Intervenor Three Mile Island Alert's First Request for Production to General m.Slic Utilities, request number 6;

2. Individuals who were issued TLDs by Three Mile Island on March'28.through 30, 1979, and were engineers or analysts or were in the Operations, Maintenance,

, 0 Quality Control, Rad Waste / Rad Chem, Chemistry or Training department;

3. Personnel identified to the President's Commission.as Principal People Sent to the Site March 28 through 30, 1979, and GPUSC, Mtn. Lakes technical support; and

4. B&W personnel listed.in the NRC Special. Inquiry Group Report at page 886 or identified in L. Roger's State-ment dated June 12, 1979.

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T held alconference telephone call to discuss Licensee's motion 1

for protective crder, and the' Board provided advance notifica-

+. . . .

' tion of its intended rulings.

This' Response?contains Licensee's= answers to TMIA's dis-lcovery requests as modified!by the changes to which Licensee-and'TMIA agreed and as limited by Licensee's previous objec-

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tions'and motion for protectiveLorder. Licensee is presently-

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' preparing a supplemental response necessitated by the Board's rulingst onl Licensee's' motion for protective order. Licensee (will file this~ supplemental response a?s soon as possible. With

~ respect to TMIA's effort'to reinstate contentions previously.

modified by mutual agreement, Licensee objects to_those-conten-tions as-unreasonably burdensome _and irrelevant to the-extent

- they call for-information different from the information called

'forLin the modified contentions.

II. TMIA's Document Requests' With respect to the documents requested by TMIA, as limit-

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• ed by Licensee's motion for protective order, Licensee has made-such documents 3/ available for inspection and copying in a

.;b/ TMIA has agreed that Licensee need not provide copies'of

- the:following documents:

~1) NUREG 0600 r

2). Report _of the President's Commission on the Accident at Three Mile Island; 'and staff reports listed therein.

3) Reporting of'Information Concerning the Accident at Three (Continued Next Page) 4

e

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DiscoveryLRoom located at:

Room 418 Center City Holiday Inn, 2350 2nd Street

-Harrisburg, Pennsylvania

' For-access, contact John Wilson, Esq., at (201) 263-6136. ,

The'following documents prepared by Shaw, Pittman, Potts &

Trowbridge are attorney work product, are privileged,-and will not-be included.in the Discovery Room.

Memorandum from Paul A. Kaplan to J.. Patrick Hickey.

re Dieckamp Mailgram of May 9, 1979 (April 22, 1981).

Memorandum from Paul A. Kaplan to J. Patrick Hickey reLAnalysis of and Response to Udall Subcommittee Ma-jority Staff Report, Section III-J (" Hydrogen Combus-tion") (April 22, 1981).

s Briefing Memorandum prepared by J. Patrick Hickey for Robert C. Arnold (May 1, 1981).

. Draft Digest of Documents Pertaining to the Dieckamp

^

Mailgram.-(August 24, 1984).

Counsel for Licensee.has knowledge of the factual basis on

- which th'e privilege lies.

b. .

p (Continued)

Mile-Island - Committee on Interior and Insular Affairs (Udall).

4) - NUREG 0760.

5). Three Mile Island,.a Report to the Commissioner and the Public (Rogovin).

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6) Memorandum from Mitchell Rogovin et al. to Chairman Ahearne . z;;.

./ . (March 4, 1980)~(Supplemental Rogovin). *;;,

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7) Restart Proceeding Pleadings and Transcripts. .s;D~'

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i III. TMIA's Interrogatories

- Interrogatory l' Regarding any document responsive to Intervenor TMIA's

-First' Request for. Production of Documents of whose exis-tence-GPU is aware, or which GPU knew existed in the past, and which is not now within GPU's custody or. con. trol, state the'following:

_(a) ~ the current location of the document; l(b) the custodian of the document; (c) the title and substance of the document; (d) the doc ment request to which the document is respon-sive; a id (e) if the document no longer exists, the last known lo-cation of the document and the circumstances under which the document ceased to exist.

- Response (1)

Licensee is aware of no documents responsive to TMIA's First Request for Production of Documents, as limited by Licensee's Motion for Protection Order, that are not now within

- GPU's custody or control. This response will be supplemented to the extent required by the ASLB Order ruling on Licensee's Motion for Protective Order.

Interrogatory 2 Describe all-lines and methods of communication and/or re-porting between the NRC and GPU which existed on March 28, 1979. State the following for each such line or method of communication and/or repc -ting identified above:

(a) the method or line of communication, whether by tele-phone, in person,.by teletype or by some other meth-

. Od; k!

(b) each person participating in each such method or line of' communication; I

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• ~(c); the'preciseitime each suchzmethod-or line.of.communi-

-cation was first-utilized on March 28, 1979;-

L(d):ithe' precise'Llength of time on March 28, 29,'or-30,- .

1979 such. method or'line of communication'was main-

. tained;

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~. ~(e) c oach' person, who1although not. participating, had.the

-opportunity to_ overhear and/orolearn of-the informa-ition_ transmitted by means of,such method or-line of communication :on March: 28, 21979;

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(f) _Lall persons named in. Document-Request-number.6_who overheard, or saw,. learned from any, individual in-

volved'inlthe communication about,.the communica-tions, and the time, date and/or reason for that per-son being informed of

such communications; J(g) 'the person wh'o_on March' 28,'1979, initiated, sug-gested or recommended setting up each new method.or line of communication and/or reporting listed above;

.and

(h) identify.any documents which-refer to, mention, memo-rialize~or1otherwise. concern the' availability or use Lany such' method or line'of communication on March'28,

, 1979. ,

-Response-(2) 1(a) Lines _and methods.of: communications between GPU and.

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the-NRC'as they existed on March'28,..1979--included telephonic andLin-person-communications'.

- 4(b) With1 respect to specific { communications that Laddressed hydrogen,-the. spike,.or initiation of containment-spray,: Licensee . is aware ofionly two' communications that were

reported as having.been made with thetNRC on March 28, 1979.

EBrian'Mehler has stated-that he discussed the spray pump actuation.with an NRC-inspector, but could not identify the individual. ' Joseph Chwastyk stated that about the time the

.  : spray,pumpsLwere shut off he communicated with Donald Neely, an

. NRC inspector.

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.(c),'(d),-(g) The initiation and maintenance of-the meth-ods or lines of communication between Licensee and the NRC are idescribed in NUREG/CR-1250, "Three Mile Island: A Report to

.the Commissioners and to the Public," Vol II, Pt. 3, pp.

943-952:(Jan.~1980)l;"StaffReportto'thePresident'sCommis-s ionJon'the Accident.at Three Mile Island, Report of the Office

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of' Chief Counsel on the Nuclear Regulatory Commission," pp. ,

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132-137'(Aug. 1979);-NUREG-0600, " Investigation into the March j 28,-l1979 Three. Mile Island Accident by Office of Inspection and Enforcement," pp. I-3-39 to I-3-43 (Aug. 1979); and Subcommit-tee on. Nuclear Regulation, " Report to the United States Senate, Nuclear Accident 1and Recovery at Three Mile Island," pp.

, 118-120, 127-128, 130-132, 137-138, 147-151-(June 1980).

(e) Anybody in-the control room at the time had the op-

-portunity to overhear any communications between Chwastyk or Mehler and the NRC.

(f) Brian Mehler told the Senate Subcommi ttee on Nuclear Regulation about.his communication-in an interview on August 22, 1979. Mehler also told the NRC in a deposition on October 30, 1979. Joseph Chwastyk told the NRC about his com--

munication in a deposition on October 30, 1979, and in an NRC

-interview on September 4, 1980.

(h) Specific communications referred to in the response 2(b) are discussed in:

Deposition of Joseph ~Chwastyk by NRC Spe-cial Inquiry Group (Oct. 30, 1979), at 18, 21-23.

-Interview of Joseph Chwastyk by I&E (Sept. 4, 1980), at 13-14, 104-112.

Interview'of Brian'A. Mehler by the Senate-Subcommittee.on Nuclear Regulation (Aug. 22, 1979) at 9-10.

s Deposition of Brian A. Mehler by the NRC SpecialEInquiry Group-(Oct. 30, 1979) at 7-10,-18-22, 25-26.

Deposition of James Higgins by the NRC Spe- '

.cial. Inquiry Group (Sept. 9, 1979), at 6. 3 Deposition of Donald R.-Neely by the NRC Special Inquiry Group (Oct. 12, 1979),

_at 16.

Interview of Donald Neely by NRC (Oct. 7, 1980) at 13.

NUREG-0760, " Investigation of Information

.- Flow During the Accident at Three Mile Is-land" (Jan. 1981) at 24-25.

Subcommittee on Nuclear Regulation, " Report to the' United States Senatei. Nuclear Acci -

dent Recovery at Three Mile Island" (June 1980)'at 140.

Majority Staff of the House Committee on

-Interior and Insular Affairs, 97th Cong.

1st Sess., " Reporting of Information Con-

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cerning the Accident at Three Mile Island"

-(March 1981)Lat 73.

NRC Office of Inspection and Enforcement,1 Memorandum (May 18, 1979), reprinted in Accident at The Three Mile Island Nuclear Power Plant, Oversight Hearings before a Task Force of the Subcommittee on Energy and the Environment of the House Committee on Interior and Insular Affairs, 96th' Cong., 1st Sess. 192 (1979).

Methods.-and lines of communications are discussed in the docu-ments-identified in response 2(c).

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Interrogatory:3

, , - ' Identify!all personsLassigned to.the emergency organiza- '

' tion or command team.and all. persons who-participated-in Lthe7think: tank meetings in the shifte supervisor's_ office-

-from March.28:through March- 30,.1979 at the TMI-2 site.

' Describe each'such person's duties and responsibilities ~

?during this three-day period..

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For!Jeach person. identified above,. state thefexact time he

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= was -in! Unit 2, his access' to or location in the Control

^ Room,Ennd all activities or tasks he performed during this

'three-day period. ,

L Response-(3) ,

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The emergency command team individuals assembled by G. P.

t MillerLon March 28, 1979 and their responsibilities were:

Individual Responsibilities

.G. Miller _ Emergency Director

'M.-Ross -Supervise TMI-2f operator actions R. Dubiel. Supervise--radiation-protection

, . . activities

'O i[. Logan

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Assure procedures and plans

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were reviewed and'followed s

G. Kunder. _ Supervise technical support and. communications.

.v D.-Shovlin_ Supervise emergency maintenance-J. Seelinger Supervise emergency control center in TMI-l

-djf L.LRogers B&W Employee - Technical assistance'and liaison with B&W The activities of..these individuals are discussed in their prior. testimony, interviews,'and depositions,fwhich Licensee Lhas_made.available'in the Discovery Room. Licensee is present-

?: 'ly endeavoring to obtain further information from these individuals.-

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lInterrogatory'4

" h Identify all lines or methods of communication and re-porting between the NRC and B&W.which existed on March 28.

Identify.the following concerning all such lines of commu-nication and/or reporting identified above:

('a); 'the' method or line of communication, whether by tele-phone, in person, by teletype or' by some other meth-od; (b) the persons participating in each such method or line of communication or reporting, and the substance of his/her participation; (c)- the persons who heard or saw any communications de-scribed above; (d) the precise time each such method or line of communi-cation was first utilized on March 28, 1979, and the length of time on March 28, 29, or 30, 1979, it was maintained; (e) . persons who overheard, or saw, or learned from any

~ individual involved in the communications about, the communications described above, and the time, date, reason and method by* which these persons were so in-formed; (f) persons who initiated, suggested, or recommended initiation of each new method or line of communica-tion and/or reporting described above; and (g)- all documents which refer to, mention, memorialize or otherwise concern the availability or use of any such method or line of communication and/or reporting de-scribed above.

Response (4)

The' lines and methods of communications between the NRC and B&W as they existed on March 28, 1979 included telephonic communications and in-person communications. These lines and methods of communications generally continued through March 30, 1979. The lines and methods of communications are generally f

I L.

' described;.in Nuclear Regulatory Commission's Special Inquiry Group-Report, Volume II, Part 3, Section B.

Licensee is unaware of any communication between the NRC

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and B&W on March 28, 1979 concerning the hydrogen burn, pres-sure spike or containment building spray actuation that oc-curred in the TMI-2 containment building at approximately

'1:50 p.m.lon March 28, 1979. See completed questionnaires addressed to B&W personnel, which are available in the Discov-ery Room.

Interrogatory 5 Identify all lines or methods of communication and/or re-porting between GPU and the State of Pennsylvania, or any state agency or office, on March 28, 1979. For each such line of. method of communication and/or reporting listed above, identify-the following:

( a )- the method or line of communication, whether by tele-phone, in person,-by teletype or by some other meth-od; (b) all persons participating in each such method or line of communication or reporting, and the substance of his/her participation; (c) all-persons who heard or saw any communications de-scribed above; (d) the. precise time each such method or line of communi-cation and/or reporting was first utilized on March 28, 1979, and the-length of time on March 28, 29, or 30, 1979 each was maintained; (e) all persons who overheard, or saw, or learned from any individual involved in the communications about,

.the communications described above, and the time, date, reason and method by which these persons were so informed; (f) persons who initiated, suggested, or recommended

. initiation of each new method or line of communica-tion and/or reporting described above; and y

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(g) all documents which refer to, mention, memorialize or otherwise concern the availability or use of any such 1 method or line of communication and/or reporting de-  !

scribed above.

Response'(5)'

The lines and methods of communication between GPU and the State of Pennsylvania or any state agency or office as they ex-

isted on: March 28, 1979 included telephone communications and in-person' communications. These lines and methods of communi-cations generally continued through March 30, 1979. The lines and methods of communications are generally described in Presi-dent's' Commission, Report of the Public's Right to Information Task Force; Nuclear Regulatory Commission's'Special Inquiry Group' Report, Volume II, Part 3, Section C and Appendices III.7 and III.8; NUREG-0760 at'39.

-To the best of~ Licensee's knowledge, no communications be-tween GPU and-the State of Pennsylvania concerning the hydrogen burn, pressure spike,.or containment building spray actuation took place on March 28, 1979.

Interrogatory 6 Identify all lines or methods of communication between GPU and B&W for the period of March 28, 1979 through March 30, 1979.- For each such line or. method of communication listed above, identify the following:

(a) the method or line of communication, whether by tele-phone) in person, by teletype or by some other meth-od; ,

(b) all persons participating in each such method or line of communication and/or reporting, and the substance of his/her participation;

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C 4*he - i(c); Tall persons _who heard or saw any communications de--

scribedEabove; (d)'1the preciseTtime each such method or.line of communi-

. cation was~first utilized on' March 28, 1979,,and the n -

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length of timeton March-28, 29, or 30, 1979, eachswas imaintained;;.

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.x x (e) -all< persons;who' overheard,-'saw, or learned ~from any s -individual involved in the communications-about, the:

' communications: described above, and the time, date,.

m.' ' reason /land method 1by-which.such persons were'so in-

' formed of the communications; (f)~:all persons who' initiated, or suggested or recom-mended;the1 initiation of, each method or line of com -

.manication,.and/or'. reporting described above; and-

(g) -all documents 7which refer to, mention,. memorialize or

'otherwise concern'the availability or use of any~such method or-line of communication and/or reporting-de-

, scribed above.

'Res6onse (6) 1. ,

lThe--~ lines-and methods of.codmunication between GPU and B&W m

r uforfthe-period of March 28,-1979 through-March 30,:1979 includ-

'ed telephonic' communications and in-person communications.- .

.Thesejlines"and methods.of. communications-generally. continued 1through. March 30,L1979. iAs to exact or. precise times of such s-

<n ' communications,[LicenseeLhasnoknowledgeof~timesotherthan

.as maylbe reflected in documents provided in the Discovery Room'

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.- or what has beenLprovided in investigative reports by others.

(See. Nuclear-Regulatory Commission's Special Inquiry Group Re- ,

1

- port, Volume II,.Part 3, Section A.4.e)

'In-the-late evening of March:29,11979 or.early morning of ec- - Marchl30,o1979, William Lowe, a GPU consultant, informed Don Nitti'of B&W'by telephone-of the hydrogen burn, pressure spike, n .

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.and containment building spray actuation which occurred in'the TMI-2Econtainment building at approximately 1:50 p.m. on March 28,fl979. Don Roy or Jim Taylor of B&W may have been with Don Nitti'at the time. See notes of William Lowe, avail-able.in the Discovery _ Room. See also the completed question-

-naires, available in the. Discovery Room; Memorandum from Mitchell:Rogovin et al.-to Chairman Ahearne (March 4, 1980) at 54-55, and documents cited therein.

-Interrogatory 7 Identify all lines or methods of communication between B&W and the State of_ Pennsylvania and its agencies, offices or officials for the period of March 28, 1979 through March 30, 1979, and answer the questions posed in subparts (a) through (g) above for each such method iden-tified.

Response (7) .

Licensee is unaware of any lines or methods of communica-

' tion or any specific communication between B&W and the State of Pennsylvania.and its agencies, offices, or officials for the period of March 28, 1979 through March 30, 1979.

Interrogatory 8 At what time and date.did Mr. Miller give an order not to turn on~the oil pumps and/or any other equipment in the reactor building so as not to cause a spark which might ignite hydrogen in the reactor. Please state the answer of each of the following persons to this question:

.(a) Gary Miller; (b) Brian Mehler; (c) Joseph Chwastyk; (d) Michael Ross;

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1. ^  :(e)f Charles Mell; L(f)[ITheodore Illjes.

Response 4(8)

' (a)'lGa'ry Miller's. response is~ contained in a question-naire.which he.-completed at Licensee's request. This. question-naire 1s'available in the Discovery Room.

4 See also NRC Deposi-tion-of Gary Miller (Oct. 29, 1979)'at 22-23.

4'

.(b) ' Brian Mehler's response is contained in a completed fquestionnaire,oavailable in the. Discovery Room. See.also NRC

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Deposition of

Brian Mehler (Oct. 11, 1979) at 15-16, 23-25, and 129-30; NRC Deposition of"Bri'an Mehler (Oct. 30, 1979) at 11-15;

~and NRC-Interview-of Brian Mehler-(Sep. 3, 1980) at 17-32.

, (c) Joseph Chwastyk's response to' Licensee's question-

'naire.has not yet been received. However, see NRC Deposition of. Joseph Chwastyk-(Oct. 30, 1979) at 15; and NRC Interview-of s Joseph Chwastyk (Sep. 4, 1980) at'16-21, 36-40.

(d); Michael Ross' responselis contained in a completed

-questionnaire'available in the Discovery Room. See also NRC Interview of Michael Ross-(Sep. 24,'1980) at-66-67.

'(e) Charles Mhil's response to Licensee's questionnaire

-has not'yet-been received and. Licensee does not know Mr. Mell's response.

(f) Theodore Illjes' response is contained in a completed questionnaire available in the Discovery Room. See also NRC Interview-of Theodore Illjes (Sep. 24, 1980) a t 10 '.2 .,

. Interrogatory 9-

' Identify:the precise day and time for the three-day period n from March 28 through March 30, 1979 t hat any member of the Command Team and/or think tank had any concern regard-ing the presence of hydrogen in the containment or reactor coolant system and for each such incident, identify all persons who held such a concern. Identify any'conversa-

-tions, discussions, meetings or communications regarding such' concerns and all indicators of the condition of the plant which' led that person'or persons to hold such a con-

~cern. Identify any action taken in response to such con-cerns.

' Response (9)

Licensee is unaware of'any member of the Command Team and/or.think tank having expressed concern regarding the pres-ence of hydrogen in the containment or RCS prior to late even-ing.on March 29, 1979 or early morning on March 30, 1979. To the: knowledge of Gary Miller, no such concern was expressed prior to that period of tine. By the morning of March 30, 1979, it was general knowledge that there had been a hydrogen

-burn in the TMI-2. containment building and that a bubble partly composed of hydrogen was in the RCS. There was a general con-cern by-everyone involved on March 30, 1979 of the presence of hydrogen in-the containment building and RCS of TMI-2. Licens-eehasnoknowledgeofanyexpreshedconcernsbyanyCommand Team and/or think tank member _regarding the presence of hydro-Cen in the containment or RCS other than what has been provided in' investigative reports by others.

Interrogatory 10 Describe all incidents.and/or experience of any GPU or B&W personnel at TMI concerning electrical malfunctions of equipment during the year preceding the accident.

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Response-(10)-

Licensee asked those GPU and B&W personnel identified as discussed in-the introduction, supra, to describe their experi-Lence with electrical malfunctions of equipment. Their re-sponses-are' contained in completed questionnaires available:in

.the~ Discovery Room.

Interrogatory 11'

. Describe the length of time it would take for an ascension and descension of an electrical' spark or signal due to an electrical malfunction.

Response (11)

Interrogatory 11 is incomprehensible and unanswerable.

TMIA identifies neither the piece of equipment of concern nor the' source of the spark or signal. Nor does TMIA explain what it means by the " ascension and descension" of a- spark or sig-

. nal . - Licensee therefore objects to this interrogatory.

' Interrogatory 12

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Describe all alarms which were actuated'by the pressure spike which occurred at approximately 1:50 p.m. on

. March 28, 1979. ' Identify all documents'which recorded, referred to', mentioned, or concerned such alarms.

Response (12)

All alarms which were actuated by the pressure cpike which' occurred at approximately 1:50 p.m. on March 28, 1979 are de-scribed on the alarm printout which has been produced in re-sponse to this interrogatory and is available in the Discovery Room.

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e' 1 Interrogatory 13

-Identify.'any photographs, drawings, charts or any other

. graphic representatica of the pressure spike and/or the teffecta-of.the hydrogen explosion occurring at about 1:50 p.m. on March 28, 1979.

Response (13)

This interrogatory has been responded to as a request for

_ production of. documents (see Intervenor Three Mile Island Alert's First Request for Production to General Public

. Utilities, No. 11) and responsive documents have been placed in the_ Discovery Room.

Interrogatory 14 Identify all investigations, inquiries, or reports which were conducted by GPU,- B&W or any GPU or B&W consultant or I- contractor'concerning the TMI accident or the-events oc-curring on March 28 to March 30, 1979 concerning the TMI accident. For each such investigation; inquiry or report,

,, state the following:

'(a) the person who commissioned, authorized or directed it; (b) 'the person who conducted the investigation or inquiry or who authored the report; (c) the date of any report; (d) the title of. any report; and (e) the current _ location and/or custodian of the report, investigation, inquiry or investigative findings.

. Describe the manner or method by which the investigation or inquiry was conducted or the report written, and any persons, documents, or data consulted during the investi-gation, inquiry or writing of each such report.

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y - LResponse'(14) s The'first-l inquiry-oriinvestigation of the pressure spike-

and'the generation and' existence'of; hydrogen occurred during March'29=and 30,11979, as reported;in investigations done!by F

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g[others,'suchias Memorandum from Mitchell Rogovin et al. to.

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_ Chairman Ahearne.(March _4,.1980) at 52-62. LInterviews of GPU ve .

- and B&W. personnel were-subsequently' conducted. The spike was

,? ,

2 (mentioned in'several-of,these interviews. See Metropolitan

' Edison Co. Interview of Craig Faust (April _6, 1979); Metropoli-A] . tan Ediion Co. Interview of-Brian Mehler (April 25,'1979);; Met -

ropolitan Edison Co. Inter, view of John Flint _(April 29,.1979);

and. Metropolitan-Edison Co. Interview of Hugh McGovern (May.4, L

1979). 'In. addition, numerous technical inquiries, investiga-

't, ions, and. reports cnt hydrogen were _ subsequently conducted by.

^

I '

.GPU,tB&W, and ;their' consultants :cnr contractors. See Documents-in the Discovery Room.

Interrogatory 15

, s.

33  ; Identify all communications, discussions, conversations or briefings'between CPU and B&W on one hand, and any member.

~

~

of the Committee on the Interior and. Insular Affairs or a Lthe Subcommittee on Energy and the Environment or the istaff of.the. committee, on the other hand, occurring on May 7,:1979, during the Committee / Subcommittee's tour of.

e

. dte TMI-2 facility, including but not limited to identifi -

L cation of all communications between Jim Floyd-and members

'and$ staff of the Interior Committee or Energy and Environ '

-mentLSubcommittee.

Response (15) '

j, Mr.~5Dieckamp has provided the following statement: "I was

-present during the briefings and plant tour for members and ll r

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Tataff of the Committee on Interior and Insular Affairs and its p

Subcommittee on Energy and.the Environment on May 7, 1979.

k During the. briefings and tour'I communicated with a number of 4

the visitors but.cannot recall specific interactions or their content.

4 "I.had previously been in contact with the. committee staff to make arrangements for the tour and to establish the agenda.

+

~I have been unable to recover any record of the agenda or iden-

<tification of the GPU participants. I am of_the impression that the agenda included a_ description of the accident, a dis-cussion irf the' plant status, and a' plant tour. I am uncertain about the identification of all participants but believe, on

'the basis of key personnel, that other participants included R.-

. lC. Arnold and J. Herbein and representatives from the communi-cations, security, and health physics functions.

"I do recall the_ control room tour being guided by

-J. Floyd.and I do' generally recall his identification of the containment building pressure recorder (s), and the containment spray controls;.his comments on the pressure spike to the ef-fact that it had to be real~because of the coincidence require-ment for spray initiation; and his reference to the operator response.being in direct view of an NRC inspector."

' Interrogatory 16 Identify all communications from or to Herman Dieckamp from March 28, 1979 through May 30, 1979, concerning the TMI accident, or any conditions of the reactor or events occurring during the accident.

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h3 "j " . 4 2For.allisuchicommunications.identifiedi in addition to

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providing theinformation. required'according to Initruc-

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. tion ~C':above,._ state the following:

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l(a) -the: exact-date and time of the communication; I

, . J E(N); the person Sho' initiated the_ communication;

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c and a M(c)})thepurposeiof.thecommunication;

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_[ 1 s ( d)' iany actionfMr. Dieckamp took as'a result of the com-

~

munication, including but not_ limited to anyl action ~

'he.took to report the information he learned to any E . _ .) .other GPUiofficial, the NRC or the Commonwealth.of G

yi Pennsylvania.

~ ' ~

,[In partihular, identify any information either to or from.

~

FMr.'Dieckamp concerning the following: t

-(a) :The-pressure' spike ~which occurred at approximately- 4

.1:50 p.m.;;

.'(b) The:PORV had been open.from approximately 4:00 a.m.

3n:. ' '

' ,to<approximately 6:00 a.m.;.

[(c) 'The HPI'(high pressure injection) had been throttled ,

y . during the~ time the'PORV had been leaking.during.the -4 4

-p early-morning of March 28, 3379; x u. . : >

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-(d) Hot' leg temperatures;in excess ofL700-degrees F'had existed during the morning.of March:28,: 1979; -

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1 O(e) Temperatures in excess of the.' saturation. temperature ~

, 1 indicated the coreiwas or'had been-inLa' condition to

,f .-bei cooled by steam rather than water; * ' >

(

(f) '

On March:28, 1979, the TMI-2 reactor was in a condi-t . _ ,

tion not covered by emergency procedures;

.(g) Certain GPU and/or B&W' personnel on site on March 28,. .

.e e 1979,Twere uncertain prior ~to' noon on March 28,' 1979, 7 as to whether the TMI-2 core.was being adequatelyf cooled;

'(h)- The in-core thermocouple : temperature readings for any 14 . ipart of the day of March 28, 1979; j

n s(i)? The2 neutron. detectors mounted inside and outside the j

reactor pressure vessel indicated increased' neutron K- ,

levels on March 28, 1979; t

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d.E '( j )! The high radiation levels detected by the radiation '

monitor mountedLat the' top of the containment build-

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J:; o s ing during thelmorning of March-28, 1979;

' . t (k) .. TheLhydrogen

. explosion and/or combustion which oc- i curred during the early afternoon on March 28,- 1979- -

i

.(1) 4

-( The actuation of-,the: containment sprays associated-3 .with :the pressure spike; and  :

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. (m)- Any. instructions by Mr. Miller or.other GPU_ personnel '

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J / /i ]^: 'not to activate any_ equipment.in the. reactor building-because it might cause-a spark and/or a hydrogen ex- ,

'q plosion;.

g w, ,j For any such information flowing ~to'or from Mr. Dieckamp 2

r . .<M  : described.above, please identify.the follow 1ng for such 7,&X information:

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'(a); The perron who supplied the'information to Mr.

Go 'j Dieckamp-or obtained the information from Mr. i i ,

.Dieckamp;. i m .. w Sh[.j j , [(b)4 The method'by which this information'was transferred;

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' ' c' ,(c) Whether the information.was transferred in a--

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' person-to-person' conversation and/or discussion in G ,6 > % -

-written form,_over the telephone.or telex,:.or by some- -

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J (j, ~ -other means;

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' ( d ) .: The exact tilme, - date and pl Ace (s) at which 'the infor-s; MW :mation.was transferred;'

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( *, i(e)' -The. reason or purpose for the' communication; l(f) . 'The person.who= initiated any'such communication;

^

$, -(g) ;;Any' document referring to, mentioning, documenting or-memorializing lany such. communication;

(h)L The current location or custodian _of any such docu-mentridentified in subpart (g).above:

-(i) lIfJany such-. document identified'in (g)'above no

longerfexists,3the; circumstances-under which it-ceased to. exist;and/or was destroyed; and k '

1(j):$The person.or persons to wh'om the.information was-transferred subsequent to the time Mr Dieckamp.com-

.municated the-information, and the date, time, and place'of:any such-; subsequent transfer of information.

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.[ . ' Response (16)

Mr. Dieckamp has provided the following statement: "On

- March 28, 1979 I was in Harrisburg, Pa. for the purpose of meeting with the Pennsylvania Public_ Utilities Commission-(PaPUC) to review the status of Pennsylvania Electric Co.

(Penelec). I'was in the company of W.1A. Verrochi and a number of other Penelec personnel. Prior to the start of.the meeting with'the PhPUC,.someone tol'd me to call Walter Creitz, the '

- president of Metropolitan Edison Co. Sometime just before 9:00'a.m. I reached Mr. Creitz. He told me that there was a problem'at TMI-2. I immediately spoke by phone with R.C.

.- Arnold in Parsippany, N.J. About mid morning I became aware of

' a press conference with.Lt.-Gov. Scranton. I attended that:

L . conference at about;10:30 to 11:30 in the Pennsylvania State

- Capitol-building. At the-beginning and'at the end of the Fenelec meeting with the PaPUC I made brief statements about TM'I-2. Sometime in the late morning I'became-aware'of a meet-ing between Lt.. Gov. Scranton and member of the TMI-2 plant staff that was. planned for 2:00 p.m. . None of theae activities or communications involved the pressure spike, hydrogen explo-3 ision,1 spray _~ initiation,2cr limitations on the operation of .

equipment in' containment.- .

~

"In discussions with members offthe Lt. Governor's staff

. in his. outer office around'2:OO p.m. .there was no mention of the pressure spike, hydrogen explosion, spray initiation, or climitations1on!the: operation of electrical equipment in 4

N ' ' - -

l e.

containment. -The only specific individuals I can recall

- conversing.with are Ray Holz and T. Geruski.

"I left the Lt. Governor's office sometime between 2:00 and 2:30 p.m. and in the course of leaving the State Capitol building encountered J. Herbein, G. Miller, and G. Kunder getting out of a car at about 2:30 p.m. on their way to the meeting with the Lt. Governor. Since they were late,-our con-versation was very brief and there was no mention of a pressure spike,' hydrogen explosion, spray initiation, or limitations on equipment operation.in containment.

"I returned from Harrisburg to my home in New Jersey dur-ing the afternoon of March 28, 1979. I spoke by telephone with R. C. Arnold.' The conversation centered around repressuriza-tion of the system and starting of a primary pump. There was no discussion or mention of a pressure spike, hydrogen explo-

- sion, spray initiation or limitations on the operation of elec-trical equipment in containment.

"Early Thursday morning, March 29, 1979, I-met with R. C.

Arnold in order,to sign a memorandum which established a task force to. develop an analysis of what we understood at that time to have been a significant transient but did not yet understand to include a loss of coolant accident and significant core dam-

~ ~

age. Later, I learned that Lt. Gov. Scranton was going to' tour ,

the plant-at a'out b noon and that a group of congressmen would

-be at the site in the afternoon. I spoke with a number of peo-

ple, whom I cannot specifically identify, to ensure that 1

c Scranton was aware of the congressional visit and to arrange to

-brief the-congressional visitors. I traveled to TMI later Thursday morning and arrived some time after noon. At the TMI visitors center-I encountered Richard Vollmer of NRC, whom I had known for.a number of years, and we chatted about the situ-ation.' There:was no mention of a pressure spike, hydrogen ex-plos' ion, spray initiation, or limitations on the operation of electrical ~ equipment'in containment.

For the-congressional visitore, I made some brief intro-ductory remarks and J. Herbein gave the briefing on the then current state of knowledge. G. Miller was present and answered

' some questions. J. Benesh of the State of Pennsylvania was also present. At no time was there any mention of a pressure spike, hydrogen explosion,': spray initiation, or limitation'on electrical equipment operation in containment.

- "A number of the people that we'had dispatched to the site to'_begin an investigation into what was.then considered an-in-cident listened in on the Herbein briefing in order to get an

~

overview before proceeding into the plant.. ' I spoke >briefly with some of.those individuals. I think I remember speaking'to' R. Wilson and:Wm. Lowe; however, at that time they had. limited-awareness of the details-of the March 28 events or the status of.the plant. There'was no mention of or discussion with thesa people concerning the pressure spike, hydrogen explosion, spray

. initiation, or limitations on electrical equipment operation e

within containment.

A y * ,,g-,,-w --wm,- -c- y w- --v, - - -

"After the congressional visit (s) I returned home to New Jersey during-the late afternoon and evening hours. Sometime during the evenin,g of Thursday, March 29, I spoke by phone with R. C. Arnold. We discussed his thinking about the need for ad-ditional support of the activities at TMI-2 and I instructed him to. proceed to the site on Friday morning, March 30, 1979.

During the Thursday evening phone conversation there was no mention of or discussion of a pressure spike, hydrogen explo-sion, spray initiation, or limitation on equipment operation in containment.

"On Friday morning, March 30, 1979, I went into the Parsippany office of the GPU Service Co. I was discussing the status of TMI-2 with W. G. Kuhns when we learned of the radia-tion release that focused new attention on the site. My notes indicate that I spoke with.R. C. Arnold at about 12:30 p.m. and he relayed general information about'the radioactive 1 releases and radiation levels. As a result of'the ominous nature of~the Friday morning information I began to-seek assistance from nu-

-merous organizations around the country. My notes contain the first mention of hydrogen in a phone conversation with R. C.

Arnold at 2:05 p.m. on Friday March.30. Subsequent phone con-

~versations with Keaten at 2:30 p.m. and 8:20 p.m. and with

- M. Levinson at 6:20 contain hydrogen related references in the notes.

"The notes from the afternoon and evening of Friday, March 30 indicate that-much of the telephone discussion related

e F ,.

't'o-the presence of,-the removal of, and the operational prob-lems of non-condensible hydrogen. My notes provide no explicit

-reference but I think'I first learned of the pressure spike sometime on Friday, March 30, 1979. During the Friday / Saturday night I stayed =in the-office and was in contact with the site

~

and remember' speaking on several occasions with Wm. Lowe con-cerning hydrogen with particular reference to the radiolytic decomposition of water.

"My' activities in the period out through April, 1979 are summarized in hhe response to Interrogatory Nos. 54, 55, 56 and

-58. During April and May my activities and communications were too numerous to recount-and my memory would not suppert such

~ detail. 'Beyond the Mailgram of May 9, 1979, the next record of communications relative to the pressure spike are contained in 1my letter dated' June 14, 1979, Congressman Udall in: response to his. inquiry.of?May 29, 1979."~

Mr. Dieckamp's statement will be~ supplemented to the ex-

tent required by the ASLB Order ruling'on Licensee's Motion for-

~ Protective Order.

Interrogatory 17~

Identify all persons who knew at or around BiOO a.m. on March 28, 1979,.that the PORV,had been open from about

'4:00.a.m. to'about.6:20'a.m., including'a statement about-

the'atatus of the knowledge of the-following. persons

-(a) Iden Bryan; (b) Mike Ross; (c). Bill Zewe; y., A h

h*

(d) Brian Mehler; (e) ' George Kunder; (f) Gary Miller;

- (g) Jim Floyd;-

(h) Robert Arnold;

'(i) Herman ~Dieckamp; and (j)..J. G. Herbein.

If'any-of the above-listed persons had any such knowledge, identify all persons to whom they communicated such knowl-edge,.and the_ time,,date, location'and' purpose of each such communication.

Response (17)

Licensee's response will be provided by supplement to the extent required by the ASLB Order ruling on Licensee's Motion for Protective Order.

Interrogatory 18 Identify-all persons who had knowledge.or information around 8:00 a.m. on March 28, 1979, that the HPI had been throttled during the time the PORV had been leaking. In-clude in your answer the following persons: Ken Bryan; Mike Ross; Bill-Zewe;1 Brian Mehler; George Kunder; Gary' Miller; Herman Dieckamp'; J. G. Herbein; Robert Arnold; Jim Floyd; Edward Frederick; and Craig Faust; For any person identified above, identify all persons to

-whom he subsequently. communicated such information and the time, date, purpose and location of any such communica-tion.

s Response (18)

Licensee's response.will be provided by supplement to the extent required by the'ASLB Order ruling on Licensee's Motion for Protective Order.

t n

Interrogatory 19

~

Identify all persons who had knowledge of information

.around 8:00 a.m. on' March 28, 1979 that hot leg tempera-tures in excess of 700 degrees had existed on that day.

Include in'your response.the answers of the following per-sons to'this. question: Mike' Ross; Bill Zewe; Brian Mehler; George Kunder; Gary ~ Miller;' John. Flint; James Seelinger;: Jim'Floyd; Robert Arnold; J. G. Herbein; Craig c Faust; and Edward Frederick.

For any person-identified'above, identify all persons to whom he. subsequently communicated such information, and the time, date, purpose and location'of any such communi-cations. Answer the same question with respect to the same persons,and their knowledge or information of hot leg temperatures at 9:'00 a.m.;; noon; and 2:00 p.m. on March 28,.1979.

Response (19)

Licensee's-response will be provided by-supplement to the extent. required by the ASLB Order. ruling on Licensee's Motion for Protective Order.

s Interrogatory 20 Identify all persons who had knowledge or information on March 28, 1979 that temperatures in excess of the satura-tion temperature indicated-that the-core was or had been in a condition where it.had been cooled by steam rather:

. than water.. Include-in your response the a'nswers of the following persons: Ken Bryan; Mike Ross; Bill Zewe; Brian Mehler; George Kunder; Gary Miller; John Flint; James Seelinger; Jim Floyd;~RobertDArnold; J. G. Herbein; Edward Frederick; Craig' Faust; Joseph Chwastyk; and Robert Long.

g For any~ person identified above, identify all persons to whom-he subsequently communicated such information, and the time, date, purpose and location of any such communi-

. cation.

Further, .for each person identified above, state whether he knew or had knowledge on March 28, 1979 that tempera-tures-in excess-of 700 degrees F. .were temperatures in ex-cess of the saturation temperatures.

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. ' Response (20)-

Licensee's' response will be provided by supplement to the

. extent required by the ASLB Order ruling on Licensee's Motion for Protective-Order.

. Interrogatory 21 Identify all persons who believed, had information or had uncertainty prior to noon on March 28,s 1979 as to whether

.the'TMI-2zcore was being adequately cooled. Include in your response the answers for the following persons: Ken

-Bryan; Mike Ross; Bill:Zewe; Brian Mehler; George Kunder;

- Gary. Miller; John' Flint; James Seelinger; Jim Floyd;

~

~

Robert; Arnold; Edward: Frederick; Craig Faust; Joseph Chwastyk; and. Robert 1Long.

~

i ~For any person. identified above, identify all other per-sons to whom he> subsequently l communicated such informa-tion, belief or uncertainty,.and the time, purpose and lo-

' cation _of any;such communication.

LResponse '('21)

Licensee'sfresponse'will.be provided by supplement to the

. extent required.by the ASLB. Order ruling on Licensee's Motion for ProtectiveLOrder.

' Interrogatory 22-

'5 Identify allipersons who had knowledge or information on-March'28, 1979_that the TMI-2 reactor was in a condition

..E fnot covered by~ emergency procedures,-and for.each such'-

person state the time, or times during'which.he first held:

or was informed of such information and/orLbelief. In-

~

-.clude in your response the answers of the following per-t sons: JKen. Bryan; Mike Ross; Bill'Zewe; Brian Mehler;

. . George Kunder; Gary Miller; John Flint;; James Seelinger;

. . , _~ ..

Jim Floyd; Robert Arnold;-Edward Frederick; Craig Faust; t" Joseph Chwastyk;*~and. Robert Long.

~

' Response (22)

Licensee's' response will;be'provided by supplement to the s-Y

l

-extent required by the ASLB Order ruling on Licensee's Motion forl Protective Order.

Interrogatory 23 Identify all-persons with information or knowledge on March 28, 1979 of the pressure spike which occurred at ap-proximately 1:50 p.m., and for each such person identi!ied

.above, identify the time or times at which he learned or was informed of the pressure spike.

For.any person' identified above, identify all persons to whom he subsequently communicated such information, and

'the time, date, purpose and means of any such communica-tion.

Responsen(23)

The information requested is contained in completed i- questionnaires, available in the Discovery Room.

Interrogatory 24 Identify all persons with information or knowledge on March 28, 1979 that a hydrogen explosion and/or combustion had occurred during the afternoon on March 28, 1979, and identify _the time or times at which he learned or was in-formed of the explosion and/or combustion. For'any per-sons identified above, identify all persons to whom he subsequently communicated such information, and the time, date, purpose and means of any such communication.

Response (24)

The information requested is contained in_ completed questionnaires, available in the Discovery Room.

' Interrogatory 25-Identify all persons with information or knowledge on March 28, 1979 of the actuation of_the containment sprays at approximately 1:50 p.m. on March 28, 1979, and for_*ach e

.such person identified above, identify all other persons

.to whom he subsequently communica'ted such-information and/or knowledge.

tz

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J

(, je-y .

Response (25)

The information requested is contained in completed questionnaires, available in the Discovery Room.

Interrogatory 26 Identify all persons with information and/or knowledge on March 28, March 29, or March 30, 1979 of any instruction by Mr. Miller or any other GPU peraannel not to activate equipment in the reactor building ?ecause it might cause a spark and/or a hydrogen explosion. For any such person identified above, in addition, identify the following with respect to his information and/or knowledge:

(a) Any other persons with similar information, and the means by which he/she acquired that information; (b) The means by which that person learned or was in-formed of the instructions; (c) The person who gave such instructions and the rea-son (s) for giving such instructions; (d) All persons who responded to or acted upon such in-structions, and the specific actions he/she took in.

response to such instructions; and (e) Any documents which refer to, mention, memoralize or otherwise concern such instructions.

Response (26)

The information requested is contained in completed questionnaires, available in the Discovery Room.

Interrogatory 27 At what time (s) on March 28, 1979 did Command Team or Emergency Team personnel decide to employ and begin to im-plement a repressurization strategy? At what time on that date did the Command Team or Emergency Team personnel cease the depressurization strategy?

If either answer given above is other than the closing of the block valve at 3:08 p.m., explain the discrepancy be-tween your answer and Mr. Chwastyk's testimony that a chango was made from a depressurization to a re-pressurization strategy at the time of closing the block valve.

Response (27)

Licensee's response will be provided by supplement to the L extent < required by the'ASLB Order ruling on Licensee's Motion for Protective Order.

Interrogatory'28 Identify _all persons who instructed Emergency Team person-nel to cease the_depressurization strategy and begin a re-pressurization strategy, the precise time such directions were given to all persons identified above, and the per-

. sons to whom such directions were given.

Response (28)

Licensee's response will be provided by supplement to the extent required by the ASLB Order ruling on Licensee's Motion for Protective Order.

Interrogatory 29 What were the reason or reasons-for changing strategy to bring the reactor under control? Include in your answer, any indicators of the reactor's condition which led Emer-gency Team personnel tx> change the strategy.

. Response (29)

Licensee's response will be provided by supplement to the extent required by the ASLB Order ruling on Licensee's Motion for Protective Order.

' Interrogatory 30 If Mr. Miller is not' identified above as the person who gave the order to change to a repressurization strategy, explain how emergency Team personnel acted without his direction.

~

r.1 k

Response-(30)

Licensee's response will be provided by supplement to the extent required by the ASLB Order ruling on Licensee's Motion for Protective; Order.

Interrogatory'31 What role, if any, did Robert Arnold play in changing from a depressurization to a repressurization strategy?

Response (31)-

- Licensee's response will be provided by supplement'to the exten'tfrequired by the ASLB Order-ruling.on Licensee's Motion for Protective Order.

Interrogatory 32 5

. Identify all persons who heard a " thud," " thump" or other noise indicating .that hydrogen or some other explosion or-

anomaly had occurred around.1:50 p.m. on. March 28, 1979.

- For'each person ~ identified above, state the following:

(a) His belief at thht time of the cause or reason for the~ noise; (b) .Any communication he had with any other-person about

- the noise at any. time on March 28, March 29 or-March 30, 1979; the substance of those communica-

.tions, and the exact time of the communications; (c)- The first time-he believed the no'ise was caused by a hydrogen explosion or hydrogen combustion,.whether or

not he so understood it'at 1:50 p.m..on March-28, 1979;

- (d) Any action he or anyone else'took after hearing the r

~*

noise in response to the noise. Include an identifi-cation of the person taking such action, and the-exact time of anycsuch action; and (e)Any document recording, memorializing, referring to,'

mentioning,'or'concerning'in any way the noise.

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Response (32)

The information requested is contained in completed questionnaires, available in the Discovery Room.

. Interrogatory 33

. Identify.allopersons who became aware at any time of any

alarm actuated by the pressure spike and/or_ hydrogen ex-plosion occurring around 1:50 p.m. on March 28, 1979.

For each such person identified above, state the-follow-

- ing:

(a). His belief at,the-time he became aware of the alarm or the'cause or reason for the alarm; (b)' Any communications of this person with any oth'er per-son concerning.the alarm and the time, date and sub-

. stance of those communications, and the persons =with whom he communicated; (c)' Any action he or any other person took after becoming

-aware of.the alarm; and

_(d) Any document recording, memorializing, mentioning, referring _to, or concerning in_any way any such-alarm.

Response (33)' .

The information. requested is contained in completed-

~

questionnaires, available in the Discovery-Room.

Interrogatory 34 1

Identify and' state in as precise'words as-possible, the substance of the conversation and/or_ discussions between cor among Mr. Miller,~Mr. Dieckamp and Mr. Herbein on March 28,- 1979, including but limited to the conversations

.which occurred between.them from approximately 2:00 p.m.

when Mr. Miller left the site-to meet with the-Pennsylvania.Lt. Governor and'apptoximately 5:30 p.m.,

when~Mr. Miller return'ed to the site.

Respon'se '(34) u Mr. Dieckamp.has provided the following statement: "At s ', -

about 2:30 p.m. on Wednesday, March 28', 1979, I encountered and spoke with Messrs. Herbein, Miller, and Kunder on the steps of 1the Pennsylvania State Capitol Building. The conversation was.

very brief because they were late for what was to have been a 2:00 p.m.-appointment with the Lt. Governor. I expressed con-cern that those three individuals could be absent from the

plant'if.there was a problem. From the exchange I received the impression-that the plant was stable. There was no mention of

a pressure spike, containment spray actuation, or hydrogen.

"In a.recent conference call with J. Herbein and G. Mill-Jer, I was informed that they had no discussion between them'on March 28,' 1979 concerning a pressure spike, containment spray actuation, or hydrogen. This position is consistent with their statements in a letter to Congressman.Udall dated June 12, 1979, which states that they-first became aware of the pressure-spike, containment spray actuation, and hydrogen on Friday,

- March 30, 1979."

Mr. Dieckamp's statement will be: supplemented to the ex-tent required by the ASLB Order ruling on Licensee's Motion for Protective Order.

Interrogatory 35 Identify'all investigations, inquiries or probes GPU or

.the NRC has made to determine why the operators' logs de-scribe the pressure pulse which-occurred at-approximately 1:5 0 p.m. on March 28, 1979 as 4 psi and 5 psi when the magnitudecof the pulse was in fact 28 psi.

-Explain the reason or reasons the operators logs errone-ously recorded the magnitude of the pressure spike.

.) -

6 1

^ _Responsei(35)

~

Licensee has not undertaken any investigation, inquiry, or

. probe to determine why.the operator's logs describe the pres-sure spike which occurred in the.TMI-2 containment building at 3 .

'lapproximately'1:50 p.m. on March 28,- 1979 as 4 psi and 5 psi when the magnitude.of the pulse was approximately 28 psi.

Licensee is unaware of any specific NRC investigation, inquiry, f or: probe concerning this matter,. although the NRC questioned at

-least Donald A.'l Berry an'd Control Room operators Zewe, LScheimann,- Frederick,. Faust on this matter in connection with I

_the;NRC'~s investigation _of_the March 28, 1979 accident at

' TMI-2. :These interviews, which have been placed in the Discov-ery Room, provide the individuals' explanation of the entries

.'in the operator's logs.

Intehrogatory-36

.At what time or. times on March 28 through March 30, 1979

did the : hydrogen- recombiner become actuated? For each

- ' time. identified above, identify lthe-following:

-(a) The manner in which the actuation was recorded; (b). The documents which record, memorialize,. mention'or otherwise concern the actuation,-and their current location;

- i (c)

All persons _ who had knowledge or were. informed of the

, actuation of the hydrogen recombiner_at~or near the time of: actuation;-

1(d) The persons to whom-each person identified in subpart:(c) above communicated the fact of the

' actuation of the-hydrogen.recombiner;:and.

q; (e) The mode ofcactuating the hydrogen rccombiner,

including whether it was. actuated automatically or

manually.

~

k T

A

/

. Response 1(36) l To'the~best of Licensee's knowledge, the hydrogen I recomb'iner was not actuated any. time between March 28, 1979

- througi. March 30, 1979.

. Interrogatory 137 Explain the location-'o'f the~in-core thermocouple data recorded with a_ digital voltmeter for the period from March 28 through May 7, 1979. .

-Response-(37)-

Licensee's response will be provided by supplement to the extent required by the ASLB Order ruling on Licensee's Motion for Protective Order.

Interrogatory 38 Explain'the meaning of Mr. Miller's recorded comments to Mr. Troffer at Met-Ed at approximately 9:30 a'.m.:on March 28 which are recorded in a transcript-of1 that date:

~". . . to be honest with you, we've been assessing the-plant. . . . We don'tLknow where.the hell the plant was going. The situation we're in is a' delicate one because we-actually have plant integrity. . . . If we had a leak.

we'd be all.right."

Response (38)

Licensee's response'will be provided by supplement to the extent required by_the ASLB' Order. ruling on Licensee's Motion

-for Protective Order.

Interrogatory 39 Explain the meaning of Mr. Miller's additional recorded comments to Mr. Troffer as recorded in a transcript of March 28, 1979: ". . . in addition to this, the plant ob-viously experienced a pressure and temperature change f airly - f ast.' I didn't say this to them -- I'm just saying it to the group." - What details did he not communicate to 2-

- - - , , -- , , - - , - -r-- - ,w,m , m . , -- -. , - + - ,e-+

- r E

.c

- g '

r ', e

~the Commonwealth'of Pennsylvania authorities with whom he:

communicated earlier that morning?-

What were'the reason (s) for Miller not telling and/or withholding these-details!from the Commonwealth of-1 Pennsylvania authorities? -Did he at or about 9:30 a.m.

communicate the details identified above to the NRC?c If so,.to whom did.he communicate the information~and at what:

. time'or times?

-Response'(39)

Licensee's response will be provided by supplement to the Lextentl required by the ASLB Order ruling on Licensee's Motion-

for' Protective Order.

Interrogatory 40 Did GPU inform the NRC of the following on March 28, 1979, and if.so,'who communicated the information; to whom at

'the NRC~did he" communicate the:information; and at what>

. precise hour did he communicate the information?

-(a)' It appeared;the PORV.had been' opened and/or. leaking.

from approximately 4:00 a.m. to.about 6:20 a.m.;

(b) - The HPI had been' throttled during the time the PORV ha'd been open'and/or leaking; '

(c) ' Temperatures in excess of 700 degrees F. had been measured 4in the hot' legs; (d) Temperatures lin excess of 700 degrees F. had been-measured-on the in-core thermocouples; (e) . Temperatures in excess of-2000 degrees.F. had been measured'on the'in-core.thermocouples;

~(f), The plant wasin a condition not provided for in emergency' procedures;

" *~

~(g)- Some GPU personnel'were uncertain as'to whether the core was in-a condition where it was being adequately

+_ . cooled on March 28, 1979; (h) ' Radioactivity measurements on a reactor coolant sam-ple indicated failure of a substantial portion of the fuel rods; and-

~

s

r -

s.+ \

s'

~

-a:

s

. j; ,

~

,,1 1(i).'Aipressure pulse h'ad'been recorded on reactor build-

ing. pressure measuring instrumentation.

m r ' ?If GPU did not inform th'e!NRC~on March-28 of any-of the y7 matters stated in subparts.(a) through (i) above, sta_te

'rthe~date, time, and means by which that.information was:

communicated totthe NRC at-any later time; the person-who

.communicatedTsuch..information; and:the reason (s) for com-imunicating such information to the NRC at that time.

J'e < If LGPU did not ' communicate any' matters stated in

~ subparts (a) through'(i) above to the'NRC.at any' time,

-explain why.not.

Response (40)

, _-(i) Late Thursday evening March 29,11979 or~early~ Friday

morning,~ March 30, 1979, Metropolitan Edison Company verbally

- 0 ;i -. .

N ' inotified-the NRC of the, pressure > pulse which had-occurred in ttheiTMI-2: containment building at approximately 1:50 p.m. on

[ Ma$ch:28, 1979. ' Licensee is-unaware-of who specifically;

~

Ladvised~the NRC of-.the. pressure pulse. ' Metropolitan Edison

.a Company's: notification to the NRC.followed its. appreciation of'

+4 the. significance of=the pressure pulse during.this time-frame.

1. f" !There is testimony that NRC personnel in the TMI-2 control:

room at'approximately,liSO p.m..on March 28,;1979 may.:havelseen lthe1 indication of1the pressure. pulse or'were. told of it by Met-

~

ropolitan Edison, Company personnel. 'See Response 2(b).

. Interrogatory- 41 N < Answer:the question posedcin. Interrogatory No. 40: above,.

^'

sa fincluding.all subparts'therein with~ respect-to the Common-

wealth of

Pennsylvania -instead of the NRC.

-Response 1(41)

, t 1(i')L Metropolitan-Edison Company.did not inform the

~ , , -

3

'.4'

r 1

-l

+-

Commonwealth of Pennsylvania on March 28, 1979 of the pressure i pulse. ' Licensee does-not know when or how any communication about the_ pressure pulse was made to the Commonwealth of Pennsylvania.

Interrocatory 42 Describe all checks which were made of plant. conditions and/or containment within four hours after the occurrence of the pressure spike and/or the activation of the reactor-building spray pumps. For each such check described above, state the following:

(a) The person or persons who made such check; (b) Any document referring to, recording, memorializing or otherwise concerning any such check; (c) Any action taken as a result of or in response to any such check; and (d) All persons who were informed on March 28, 1979 of the results of such checks and any action he took as-a result of or in response to that information.

Response-(42)

A number of individuals have acknowledged awareness of the

' occurrence of the pressure spike or-containment spray actuation and to observing plant conditions through instrumentation at

'the time of such occurrence. At least two individuals,

.L. Rogers and J. Chwastyk, have intimated in prior statements that a c5.sck of containment was made. Mr. Rogers is a former B&W employee, and Mr. Chwastyk is a.former GPU Nuclear.

employee. Neither individual is' currently employed within the GPU System. Licensee is not aware of the bases for their prior comments. Licensee is unable to confirm that any such check of

~

E

't containment was performed in response to the pressure spike or actuation of the reactor' building spray. Licensee is unaware of'any specific plant-parameters subsequently being monitored in response to_the pressure spike or containment. spray

- actuation.

See Statement of Leland Rogers (June'12, 1979) at 22; NRC Interview of Brian Mehler (Sept. 3, 1980) at 15; NRC Interview of~ Joseph Chwastyk-(Sept. 4, 1980) at 11-12; NRC Interview of William Zewe (Sept. 4, 1980) at 44; NRC Interview of Gary Mill-er (Sept. 5, 1980) at 123; NRC Interview of Michael J. Ross (Sept. 24, 1980) at 48-49; NRC Deposition of Edward Frederick (Oct. 9, 1980) at 6; NRC Deposition of Craig Faust (Oct. 9, 1980) at 8-9; NRC Deposition of Joseph Scheimann (Oct. 9, 1980) at 5; NRC Deposition _of Joseph Logan-(Oct. 16, 1980) at 55; NRC

. - Deposition of Adam Miller (Oct. 28, 1980) at 9-11;-NUREG-0760

. at 27-28; and Majority Staff of the Committee on Interior and-Insular Affairs, " Reports of Information Concerning the Acci-dent at Three Mile Island" (March-1981) at 73-75, 97.

Int,errogatory 43

[~

Answer the following with respect to Leland Rogers' Memo-randumnor Statement of 3/28/79 Unit II Transient, dated

-June 12, 1979, at page 22:

(a) Describe all checks made of plant conditions.and/or i1 the containment in response to the pressure spike and/or activation of the, reactor building spray pumps; (b)- Identify all persons who made any such checks and all persons to whom the results of such checks were com-municated;

i2 (c)- Identify all documents'which recorded, memorialized, mentioned; referred.to or otherwise concerned such checks, and their_ current location;

~

(d) Identify _the operator cited:in-the sixth sentence of the second paragraph'on page 22;

.(e) . Identify-all members of the monitoring _ teams men-

-tioned in the seventh sentence of the-second para-

. graphi on page 22; and

^

. (f) . Explain'the' basis for the conclusion noted in the fifth sentence of the second paragraph on page 22 L

thatj "The; transient conditions were a result of a rapid reaction between the H r0 in the.

2 2 containment and~ occurred: coincident with a continued long period.of system venting to the containment."

Response (43)

< For the' response to (a)', (b), and (c), see the. response to-Interrogatory 42.

(d)lL. O. Wright (e) Licensee has a record of results of site. radiological

-monitoring'which reflect atI1405 on March 28,'1979, that_a mea-surement was made "around Unit-2 Rx bldg," but no record was

- made as to the individuals that performed:the measurement and reported same. ,

(f)LLicensee is unable toistate:what'Mr. Rogers. intended

. .to. convey in'that-sentence:with respect to his awareness at any particular. point'in' time. :Mr.: Rogers'-Statementcappears to be an overview of the events at TMI-2 prepared for purposes'other 4than:to-identify his contemporaneous knowledge of events.

Interrogatory 44 State GPU's position as to whether any misstatements, in-accurate statements or. false statements were_made in the Dieckamp mailgram to Congressman Morris Udall. Identify ~

e M k -

m. . .

. s s

'all'such misstatements, inaccurate statements and/or false statements.

Interroge. tory 45 State the time.at which GPU first learned of such mis-statements, inaccurate statements or' false statements identified in responso'to Interrogatory 5No. 44 above.

Identify all persons who learned of such misstatements, ,

false statements cr 'iriaccurate statements, and identify all persons to whom they: communicated such information;

-the.date, time ~and reasons for which they communicated such information;'and the action which'GPU took in re-sponse to such information.

Interrogatory 46 Identify any discussions, conversations, communications or contactsEconcerning the false statements, inaccurate statements or misstatements identified in response to

-Interrogatory No. 44 above.

Interrogatory 47

. Identify any. action taken by GPU, including but not limit-

- ed to any. actions taken by Mr. Dieckamp after learning Lof

.the false' statements, inaccurate statements or mis-statements identified above,-including but not limited to any action taken-by GPU to correct the false statements, inaccurate statements ~or misstatements.

~

State the reason for failing to take any such action if your_ answer is that no action _was taken-by GPU to correct the false statements, inaccurate statements or mis-statements. identified above, cResponse (44),(45),(46),(47)

Mr. Dieckamp has provided the_following statement: "I am

' unaware of.any misstatements,. inaccurate; statements, or false s statements in the Mailgram.

"To the extent that some would construe the 'no evidence'

' statement to be-contradicted by the testimony of Chwastyk,

~

Meh,ler, and!Illjes, thatJ' evidence' was adduced. subsequent to the"Mailgram statement.- The testimony of Chwastyk,. Mehler, and

-45 .

Illjes which is sometimes cited as evidence does not ' interpret the pressure spike and spray initiation in terms of reactor core damage.'

" Subsequent independent investigators have examined the state'of understanding-on the day of the accident and con-

'cluded:

The investigators conclude that hydrogen was not discussed as a~cause for the pressure ,

spike on March 28, 1979. .There was no acknowledged cause for the spike on that date. It is concluded that the order not to restart electrical equipment was given on some~ day subsequent to March 28, 1979.

NUREGLO760, p. 28.

"The. statement, '. . . . nor that anyone witheld any information' relates to the pressure spike and its interpreta-tion. The pressure spike or some manifestation thereof was known to a number of people on'the day of the accident and its occurrence was not officially. conveyed to all potentially in-terested parties on that day. I do not believe that informa-tion about"the pressure'-spike and its- interpretation was con-sciously witheld. The NRC's Special. Inquiry Group and NUREG 0760 reach a similar conclusion."

Interrogatory 48 When did GPU first become aware of the substance of the interviews conducted by the NRC in preparation of the I&E Report?. When did GPU first become aware of and/or review L -

the I&E interviews of Brian Mehler and Joseph Chwastyk?-

Identify all persons to whom the substance of such inter-views was communicated at.any time prior to January, 1981.

When did Mr. Dieckamp first become aware of the substance of the interviews of Brian Mehler and Joseph Chwastyk.

4 s

.i

~

• A.,'

• ' '4 Identify.all persons.who informed Mr. Dieckamp of'the.sub-

. stance of these-interviews and identify all communications "3'

between.such persons and Mr. Dieckamp concerning the two

interviews.

~

' Response (48)~

^

iMr.-Dieckamp has'providedithe following statement: "The -

- Ma'ilgram was.sent'to Congressman'.Udall on May.'9, 1979.

An I&E Linterview t of Brian Mehler was conducted on-May^17, 1979, and.an I&E interview of Joseph Chwastyk was conducted on May-21,:1979.

The transcript of the Mehler;inverview-indicates that it was

a. Ltyped on: JulyJ2; 1979,Jand the transcript of the Chwastyk in-

' I terview: indicates that it was typed on July 10, 1979. I do not

. know:when I-first became aware.of the Chwastyk May 21, 1979 and

=Mehler May-17, 1979 interviews. I became. aware of continuing

.intere'st,by-the Udall committee-in the pressure spike by way of

~

'a letter:from Udall-to me' dated May 29, 1979,'which asked for answers to a number of-questions including ones relating to.the

pressure. spik'e.

~

-I next became aware of continuing committee

.interestiby way of questions from the Udall-committee to;the NRC dated January; 21,.1980- and February 4, 1980. My first real Jawareness'of the contents of the Chwastyk.May 21, 1979 and

-Mehler May 17, 1979 interviews may have'been by;way.of the ,

. March'4, 1980lRogovin/Frampton Memorandum'to the'NRC Re Ques-

tionsLSubmitted by Congressman Udall.

"I have a record of having received a copy of:the Chwastyk: -

s n May-21, 1979 interview from John Wilson on January: 29, 1981, fand'at;about the'same-time I received a copy of a April 25,

~

._47_

y

, Q h" I.. ; .. _ g . _

p ,s 1979 GPU' interview of Mehler from E. Blake, of Shaw, Pittman,

, 'Potts'&'Trowbridge.

~

~

"I most 1ikely became aware of the content of the' inter-

views conducted by the NRC in preparation of the I&E Report

'when NUREG 076C was published.

"Asnu' m ber of people within GPU ha'd access'to the I&E in-

~terviewsiof-Chwastyk and Mehler, but I have no recollection of being~ informed by anyone of the substance of these interviews.

I think myfawareness derived-from published documents."

~

Interrogatory 49

. Identify all persons within GPU who held any responsibili-

.ty to; keep informed about'and track the interviews con-ducted'by the NRC concerning the TMI-2 accident.

Response-(49)

~

W. Behrle arranged and tracked the interviews which were

~

conducted by~I&E in connection with its investigation in prepa-

~

_ ration of NUREG 0600. Licen~see will supplement this response

, .to.the-extent required by the ASLB Order ruling on Licensee's Motion-for Protective Order.

1. Interrogatory  ; Identify all persons within GPU who held any responsibili-ty 'to ' stay informed about f or : track interviews conducted in the icourse of preparation of the'Rogovin Report.

Response (50)

J. F. Wilson and J. Guerin~ arranged a,nd tracked'the inter-views which were conducted by the NRC Special Inquiry Group in

. connection with its investigation in preparation of the

y -

7[, 2 YA l

, _ (

"Rogovin" Report. Licensee.will supplement this' response to itheLextent required by the ASLB Order ruling on: Licensee's.Mo-

' tion'for Pro'tective. Order.

Interrogatord 51" Ide'ntify!all GPU'personnelland/or' attorneys.who attended Lany.part of any I&E interviews and/or Rogovin Report in-iterviews.

!For allipersons. identified above,[ identify all. notes, memoranda;; minutes or other documents.they maintained con-

.cerning.such; interviews and all: persons to whom such

. notes', memoranda,: minutes _or other documents were distri-

'buted.

. _ Response-(51) >

The.following individuals representing GPU attended inter-

. views conducted byzthe.NRC in conjunction with'its investiga -

~

tion ~which~1ed to NUREG 0760 and'/or the NRC Special Inquiry

~ Group:

E. .L. Blake, Jr., Esq.

D. E.-Davidson,:Esq. '

~

'J. B. Liberman,-Esq.

W..B. Reynolds, Esq.

D. A.'Ridgeway, Esq.

M. F. Travieso-Diaz,-Esq'.

N J. F.' Wilson, Esq.

A. R. Yuspeh,'Esq.

'The:last paragraph of this_interrogatoryfhas been1re-2

~

M Lsponded to'as a; request 1for production of documents'(see Inter .

.venor1Three. Mile Island Alert's First Request fo'r Production to Genera'l. Publ'ic. Utilities, ' No. 11) and-documents maintained by-Ltheselindividuals have been placed'in the Discovery Room.

-LicenseeLwill_ supplement this response to the extent required 1

by;the ASLB Order ruling on Licensee's Motion for Protective Order.-

i: ~

s .% .

P

.s .

ck .

~

YInterrogatory-52

.I

' ~

For what purpose did Mr. Dieckamp'cend a mailgram to Con-

, 'gressman Udall.on May 9, 1979. Identify all persops whom Mr. Dieckamp consulted prior to, sending the telegram, and

-the substanceLof anyfcommunications with such persons.

Identify;all communications between Mr. Dieckamp,andLMr.

-Floyd concerning the subjects discussed in the mailgram.

Response:52

- LMr. Dieckamp has provided the fo'llowing statement: "The a(

i, 3 -

-[( purpose of-the May 9, 1979 Mailgram to Congressman Udall was to

. >jf .,c take exception to the. newspaper commentary on the Congressman's'

(( visit ~to TMI on:May 7, 1979 that appeared on May 8, 1979 in the New York Times. I do not today recall the specific individ-uals, if.any, that may have been consulted in the course of drafting.the Mailgram. I did not consult with J. Floyd. My Ereference to him in the Mailgram is a-direct. reflection of what 1'

E -I heard him.say to.the congressional visitors during the con-f'  ; trol room tour on May 7, 1979."

n Interrogatory 53

-g

( .

t 2What is the basis for Mr. Dieckamp's statement in the

^

.mailgram that Mr.~Floyd's--statement7 that certain activity

.was in view.of the HRC inspectors in the control. room at

, the time =of the accident referred to' activation of'the

'%L .: containment building spray-and not-to the pressure spike?

.(

( c

,7R'esponse 153 "Q Li i, ..

('

IT :l\ :- Mr. Dieckamp has provided the - following statement: "The

. s

'k . basis'forLthe subject comment was my recollection of Mr.

Floyd's's'atements t that I'haard in the course of the briefing j

yr ~

of; congressional-visitors in the TMI-2 control room on MayL7,.

an fk'"'

%= ,

1979. The Mailgram attempted to convey that the turning.off of 1

a .

I b, 9Ni l 3.,

t i fu: '

w;-

..+j,' ' ^~. , , .-~ , .- ..-.,,e . . , , - , . . - , , . -,

.,-.,..w-,,.- -,i..,,,,',,,-n -, . - - .

' '~ ' ~^

7,

,jpi

>4n a/

/th'e/containmen't: spray wasEin. view of the NRC inspectors.'The

-, 9y; '

. 'Mailgram.makes'no statement about'the-pressure'spikelin.this

, Econtext."-

ps 1 -- F 1 , 7 /-_ - ) '.

iInterrogatory 54-t Ni . .

d: -

R What'1wasc the basis;for':Mr. Dieckamp's statement in.the

' y" '

jmailgram'that,'"ThereLis no evidence that anyone inter-

, {preted'the:' pressure spike' and the spray' initiation in

. terms of reactor core damage at the-time of the spike'nor 1' .

that anyone withheld'any information."

&^

.I .

Describe 2 the'information'to which Mr. Dieckamp_was refer-

tring;in the=latter portion-of_this statement.

^ '

' Interrogatory 55-

~ fWhat;was the basis for Mr. Dieckamp's statement in the qg , ;i t ~f . . g. ;fifth; paragraph lof the mailgram which suggests that the eg , evening _of; Thursday, MarchL~29, was.the first time GPU i

Ak<p = ?s ' learned ~'of the pressure-spike and postulated it to be the t

results-of'a_ hydrogen oxygen explosion within the-contain-

~

dha.L 5

s ment building?'

, ,' cc $- . Interrogatory 56'

'E k

~

_W hat was the basis for Mr. Dieckamp's statement _in-the

~

_fifthi paragraphicf the mailgram which suggests-that the-

~

first time ~GPU took measurements' intended'to determine the

. extent of'aLhydrogen bubble within the primary reactor-cooling;1oop;wasusome time after the' technical staff-first

. < reviewed:the %pikeLonLthe~ evening of' Thursday, March 29.-

Describelthe measurements'to which Mr. Dieckamp referred

in the fourth sentence ~of the fifth paragraph'of the mailgram, and identify.allidocuments which record, memori-

_ 1alize,. mention,crefer to, or otherwise concern such mea-

- surements.

-Interrogatory 58- *-

JI'dentify alb-information and/or knowledge Mr. Dieckamp.

00  ; held on May.8, 1979 and May 9.-1979 regarding the inter-

. views : and investigation' b.eing.- conductedby GPU-'concerning J . the TMI-Accident;-events which occurred on March 28, Marchl29'and March 30, 1979;3the: conditions of the TMI-2 h$$h Y creactor:on~ March 28,-March 29 and March 30, 1979; and re-portingfof^anyfsuchievents or conditions to the NRC'and/or F the'Commonwealthiof~ Pennsylvania.

p a

t ..

Identify all documents which mention, refer to, record, memorialize or otherwise concern any information and/or knowledge identified above.

Response (54), (55), (56), (58)

Mr. Dieckamp has provided the following statement: "An incident investigation task force had entered the plant during the-late afternoon of Thursday, March 29. I became aware of the reactor building pressure spike sometime on Friday, March 30, 19791 In telephone conversations with personnel at the site, most likely Mr. R. C. Arnold, I was told of the pres-sure spike recording being brought to the attention of the task force during the night of March 29. The task force postulated a zirconium water reaction as the source of the hydrogen. The presence of hydrogen was recognized as being consistent with the off-normal pressure volume behavior of the primary system.

' The postulate also caused the plant staff to take steps to take a containment building gas sample and to take steps to permit operation of the hydrogen recombiner. The first containment building gas sample was taken at about 4:00 a.m. on March 31.

" Records indicate that the initial measurements of the non-condensible gas in the primary system were completed at about 0300 on March 30, 1979. The volume of the non-condensible gas in the primary system was measured by observing the system pressurd change associated with a change

-in the water volume in the primary system. Documenta relating to such measurements are contained in the Discovery Room.

i l

L

• '"After moving to the site on the afternoon of Saturday, March.31, I was in routine conversation with key members of the l

plant. staff, the task force, the NRC, . and the' industry advisory 4 1

group that had been formed. In these interactions I became aware of the confirmation of hydrogen through the. analysis of Lthe' containment building gas sample (s) which contained hydrogen Land showed a depletion in the normal atmospheric oxygen concen- ,

l tration. ~This depletion afforded the first indication of the j amount of reacted-zirconium and thus the first ' quantitative' indicator of.the degree of zirconium reaction and thus core

' damage. I was also directly involved in the concern about the potential explosivity of the hydrogen bubble, the primary cool-

~

ing system vulnerability to high concentrations of non-condensable~and/or dissolved gas, and the strategies employed to remove the hydrogen from the reactor primary system.

"During.the first few weeks of April I remained at the site. I availed myself of the early GPU~ operators' interviews, satiin on preliminary 1 reviews of the sequence of. events, par-

.ticipated in status reviews with the onsite NRC staff, coordi-nated the activities of the industry advisory group and gener-ally' participated in the management of the accident.

"During the third week in Aprid I drew upon this awareness and the. developing learnings, including an investigation of the closed emergency feed valves and the G. Miller. report based on a taped conversation and reconstruction of the day of the acci-dent, to assemble-testimony for presentation to the Nuclear F

L-[

l I

1 Regulation Subcommittee of the Senate Committee on Environment j and Public Works.

~" Prior,to May 9, 1979,-I did not conduct any exhaustive investigation'of the pressure-spike and its interpretation but I hadLgiven the subject considerable attention in-the course of preparing the testimony because the spike, its identification with~the Zr/H O reaction, the verification and quan-2

' tification'of the hydrogen, and the subsequent analysis of the degree of. fuel cladding reaction was a meaningful way to iden--

tify the difficulty in recognizing the scale of the accident and the time necessary to derive enough information for some quantification of the core damage.

"From the considerable information available to me prior to May.9, 1979, I had a very clear understanding of-the delayed recognition and interpretation of the pressure spike. I also heard or saw no indication that the pressure spike had been.

properly diagnosed orEthat it caused the plant staff on March 28 to change or adopt a strategy for bringin; the plant to cold shutdown that recognized the presence of hydrogen or non-condensible gas. Prior to May 9,-1979, I knew that a pres-sure spike had been observed on the day of the accident but my overall awareness caused me to conclude that no one recognized *

'theLsignificince of the spike in terms of core damage on

. March 28.

"The latter portion of the Mailgram statement refers to the_ pressure spike and its interpretation. It was my o

v, a

~

l ' s

- conclusion:that no one could have made a conscious decision to iwithhold'information about the spike."

With respect.to Interrogatory No.-58, Mr. Dieckamp's re- i sponse will be supplemented to the extent required by the ASLB

' Order l ruling on Licensee's Motion.for Protective Order- .

s ' Interrogatory:57 '

^Ident.'.'fy?all' investigations,. inquiries,- studies or reports

~

authored by GPU or anyJconsultant hired'by GPU~regarding Ethe Dieckamp mailgram-to Congressman Udall and/or whether Mri Dieckamp.made-any material false statement in that-mailgram.

-For all such investigations, inquiries,' studies or reports

. identified above, indentify the.following:

4-  : (Ia) lThe person (s) who conducted, wrote, or. participated in the investigation, investigative report, inquiry, study, cur report;

~(b). The. purpose for the investigation,-inquiry, stddy,'or' s ~ report;

-(c) 'Any documents,. including any reports or studies which

-resulted from the investigation, inquiry or' study;

.(d) The currentT1ocation of any documents identified ini w subpart (c) above; _ and-

.(e). 'Any. disclosure made of such investigations,-inqui-ries, studies or reports to the NRC,_and the date of-

- any such disclosure; t

C

~

O

~ Response'57-Licensee has conducted no investigations, inquiries ,

studies, or reports nor'has it hired ~any consultants regarding

. the- May 9, 1979' mailgram':to Congressman Udall.

Respectfully submitted,

_ SHAW, PITTMAN, POTTS & TROWBRIDGE kW Y rho Ernest L. Blake, Jr., P.C.

. David R. Lewis Counsel for Licensee-Dated: September 4, 1984 4

9

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.- R E Q t

,. .gf;c -:

g September 4, 1984

-UNITED-STATES OF AMERICA

, NUCLEAR. REGULATORY COMMISSION

. DOCKETED d5MC BEFORE THE ATOMIC SAFETY AND LICENSING' BOARD 84 SEP -5 All :54

-.In"the Matter of-

).

~) aff.<.:. OF ;! On .

METROPOLITAN-EDISON. COMPANY- ) Docket' No00'50_ 1.28p SEi'V

). (Restart-Management .'$ddkId).

(Three-Mile. Island Nuclear

)

Station, Unit No.'1) )

CERTIFICATE OF SERVICE I hereby certify that copies of " Licensee s Response to

-Three Mile Island Alert's First Set of Interrogatories and First Request for Production," dated September 4,-1984, were served-.this-4th-day'of September, 1984 by deposit in the

' U.S.: mail,.first. class,' postage-prepaid, to the parties on the.attachedcService List.

l-l'

( ,

M N Ernest L. Blake, Jr., P.C.

l .

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}

UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE' ATOMIC' SAFETY AND LICENSING BOARD

[In'the Matter )

)

METROPOLITAN EDISON COMPANY ) . Docket No. 50-289 SP

) (Restart Remand cn Management)

'(Three Mile ' Island Nuclear )

Station,-Unit No. 1) -)

SERVICE LI'ST

'Nunzio-J. Palladino, Chairman Administrative Judge U.S. Nuclear Regulatory Commission John H. Buck Washington, D.C. 20555 Atomic Safety & Licensing Appeal' Board Thomas M.; Roberts, Commissioner- U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Washington, D.C. 20555 Administrative Judge James K. Asselstine, Commissioner Christine N. Kohl-U.S. Nuclear Regulatory Commission Atomic Safety & Licensing Appeal-Washington , D. C. 20555 Board U.S. Nuclear Regulatory Commission ~

Frederick 1Bernthal, Commissioner Washington, D.C. 20555

'U.S. Nuclear Regulatory Commission Washington,-D.C. l20555 -

Administrative Judge

. Ivan W. Smith, Chairman Lando W..Zeck, Jr., Commissioner Atemic Safety & Licensing Board U.S.. Nuclear Regulatory Commission U.S. Nuclear Regulatory Commission Washington, D.C. '20555 Washington, D.C. 20555

^

Administrative Judge Administrative Judge.

Gary J. Edles, Chairman . Sheldon J. Wolfe Atomic Safety-& Licensing Appeal Atomic Safety & Licensing Board Board U.S. Nuclear Regulatory Commission.

L U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Washington, D.C. 20555 r

o

'w

- SNt- ,

LAdministrative Judge- Mr. Henry D. Hukill

.Gustave A. Linenberger, Jr. .

Vice-President

_ Atomic Safety & Licensing Board GPU Nuclear Corporation

_U.S.-Nuclear Regulatory Commission P.O. Box 480

. Washington,10.C. 20555 Middletown, PA 17057-

Docketing and Service Section.(3) Mr.-and Mrs. Norman Aamodt i Office of the Secretary. R.D. 5 l U.S. ~ Nuclear. Regulatory Commission ~ Coatesville, PA 19320 Washington, D.C. 20555 Ms. Louise Bradford Atomic Safety & Licensing' Board TMI ALERT Panel .

1011-Green Street- ,

U.S. Nuclear Regulatory Commission Harrisburg, PA~-17102 l Washington, D.C. ~20555 Joanne Doroshow, Esquire

, Atomic Safety & Licensing Appeal The Cnristic Institute Board Panel .

1324 North Capitol Street-U.S. Nuclear Regulatory Commission Washington, D.C. 20002 Washington, D.C. 20555 Lynne Bernabei, Esq.

• ^

Jack R. Goldberg, Esq. . (4) Pr c Office of the Executive Legal 1555 Connecticut Avenue Washington, D.C. 20009 U.S Nuc ear Regulatory Commission Washington, D.C. 2,0555 'Ellyn R. Weiss, Esq.-

Harmon, Weiss & Jordan

~

Thomas Y. Au, Esq.- 2001~S Street, N.W., Suite 430

-Office of Chief Counsel Washington, D.C. 20009 Department of Environmental

-Resources Michael ~F. McBride, Esq.-

-505 Executive House 'LeBoeuf, Lamb, Leibyf& MacRae P.O. Box 2357 1333 New Hampshire Avenue, N.W.

LHarrisburg, PA 17120 Suite 1100 Washington, D.C. 20036 Michael W. Maupin, Esq.

Hunton & Williams 707 East-Main Street P.O. Box 1535 Richmond, VA 23212

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