ML20099E688
| ML20099E688 | |
| Person / Time | |
|---|---|
| Site: | Three Mile Island  |
| Issue date: | 11/19/1984 |
| From: | Blake E GENERAL PUBLIC UTILITIES CORP., SHAW, PITTMAN, POTTS & TROWBRIDGE |
| To: | Atomic Safety and Licensing Board Panel |
| Shared Package | |
| ML20099E690 | List: |
| References | |
| CON-#484-270 SP, NUDOCS 8411260021 | |
| Download: ML20099E688 (16) | |
Text
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W'" COB CCj?V0 UNITED STATES OF MERICA
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BEEORE TIE A'ICMIC SAFLTI AND LICENSING BOARD .
In the Matter of )
)
METROPOLITAN IDIFON COMPNPI )
) Docket No. 50-289 SP (hree Mile Island Nuclea'; ) (Re: tart-Managment Rmand) l Ststion, Unit No.1) )
l STIPUIATION OF MAIIGW! EVIDENCE In order to respond to many of 'IMIA's first set of interrogatories, Licensee prepared a thirteen-page questionnaire (attached) which was dis-tributed to 456 individuals. Rese individuals were present and past GPU systs and B&W employees whose name appeared in one or nore of the following categories:
- 1. Specifically named individuals in-Intervenor Three Mile Island Alert's Fjrst Request for Production to General Public Utilities, request nurber 6; I
- 2. Individuals who were issued TIDs by 'Ihree Mile Island on March 28 through 30, 1979, and were engineers or analysts or were in the Operations, Paintenance, a Quality Control, Rad Waste / Rad Chem, Chemistry or Training Department;
- 3. B&W personnel listed in the NBC Special Inquiry G map Report at page 886 or identified in L. Roger's State-ment dated June 12, 1979 or identified by B&W as possibly having knowledge of the 'IMI-2 incident.
Responses were received frun 355 individuals.
, Question 1(a) of the questionnaire read:
On Wednesday, March 28, 1979, (the first day of the accident), were you aware or informed of the con-tainment pressure spike which was recorded at approximately 1:50 P.M. on that date at 'IMI-2? -
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We following individuals answered "yes" to said Question 1(a):
Donald A. Berry Guilford E. Stambaugh, Jr.
1 George T. Steuerwald William H. Zewe Daryl L. Wilt G. M. Olds Mark S. Coleman Michael S. Ricuards Howard C. Crawfoni Beverly A. Good Charles E. Rippon Dale J. Iaudermilch Michael L. Kuhn Walter J. Marshall Brian A. Mehler 7 dam W. Miller M. J. Ross George K. Wandling Question 2(a) of the questionnaire read:
On Wednesday, March 28, D79, did you hear a " thud" or.
" thump" or other noise indicating that hydrogen or sarc other burn, explosio.., or ananaly occurred at or about 1:50 P.M. at ET-2?
One individual, Daniel M. Shovlin, answered "yes" to said Question 2(a) .
Question 4(a) of che questionnaire read:
On Wednesday, March 28, 1979, were you aware or infonned of containment spray actuation at DiI-2 a' approxirtely 1:50 P.M. on that date?
We following individuals answered "yes" to said Question 4(a):
Donald A. Berry William H. Zewe Daryl L. Wilt Mark S. Coleran Howard C. Crawford Tim Hipple i
i r ..,_. . _._ , _. , _ -
... ., . . , Dean R. Kessler
, Michael L. Kuhn Douglas F. Spath, II Walter J. Marshall Brian A.' Mehler-Mam W. Miller M. P. Morrell M. J. Ross George K. Wandling t
Respectfully subnitted SHAW, PITIMAN, POITS & TFOGRIDGE '
I November 19, 1984 GA *-44 Frnest L. Blake, Jr. , P.C.
Counsel' for Licensee 1
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.1(a)- _On Wednesday, March 28, 1979,;(the first day of the accident), were
.you aware or informed of the containment pressure spike which was recorded at approximately 1:50 P.M. on that date at.TIiI-2?
ll _
Yes, I was aware, l_~l . Yes, I was informed,
, l~l No
}]l I do not recerter.
1(b). If your answer-to-1(a) is'yes, at what time did you tocc e aware or
't at what-time were ycu inforced of the spike?
1_l I became aware or was informed of the spike at alcut o' clock.
1 l_~l I do not remember.
1(c). If your answer to 1(a) is yes, hcw were you rade aware or did you become informed of the spike?
l~I_ (State briefly telcw)
T 1
l_~l I do not remember.
l ATTACH ADDITICta SHEE.TS IF NECESSAPY. PID.3E EE SUPE TO IEEh"IPl RT LY KE;T 1
^ ITDI hWEER IS BEIEG PESPCNEED TO CN MTl SUCI ACOITICTAL SI~EETS.
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il(d). 'If your answer. toil (a)'is yes, did you subsequently tell or otherwise cor=unicate with anyone else ateut the pressure spike?. If so, whcm did you tell, when, hcw, and why?-
. l[l Yes,'I told:
- NME DATE AND TIFE FEIECD PURPCSE (e.g., convermition,'-
report, interview, ~
- deposition, test!.-
tony, etc.)
i ll -
No t
((i I do not re:r. ember.
1(e). If your answer to 1(a) is yes, describe your. experience ccncerning any electrical ralfunctions of equiprent that cccurred at I'I-2 .
during the year preceding the accident.
! l_ l-
Description:
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ll_ - I am not aware of any such ralfuncticn.
l~l
_ I do not remember any such ralfunctien.
, 2(a). On Wednesday,ad' rch 28, 1979, did ycu hear a " thud" or " thump" cr other noise indicating that hydrcgen or scte other burn,- explccien, or enemaly occurred at or about 1:50 P.M. at TMI-27 1
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2(a). (Cent'd.)
l~l Yes l-~l
_ No, although I was at or in the vicinity cf 'D1I-2 at that time.
l_~l No, I was not at or in the vicinity of T 'I-2 at that tirm.
l]l I do not rece2er. -
2(b). If ycur answer to 2(a) is yes, what, at the tire, did ycu think caused the noise?
ll_ At the time, I thcught the noise was cauced by:
l]l I did not kr:cw.
l~l I do nct receder.
2(c). If yccr answer to 2(a) is yes, did ycu tell er otherwire ccrmunicate with anybody else about the noise at any time en l' arch 28, 2: arch 29, or March 30? If so, who did you tell and at what tice?
l~l Yes, I told:
MMI CATL
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2(c). (Cent'd.)
l[l No ll_ I do not reneder.
2(d). For any individual identified in yo"r answer to 2(c). state very briefly the substance of your cecmunication:
l-l_ I told the fellcwing:
ll_ I d'o not rererier.
2(c). If ycur answer to ?(a) is yes, did ycu tai:e any acticn in reccense to the ?.oise? What?
l_l Yes, I teck che follcwing acticn:
at atcut o'cicci: en l-l No ll
_ I do not remeder.
2(f). If your answer to 2(a; is yes, were you aware of any acticn taken by anyone else in response to the noise? What?
ll Yes, on at about o eleci: ,
(nare) tcck the folicwing '
actiCn l_-l No Y,
l 1
2(f). (Cont'd.)
l_~l I do not remeder.
2(gi. If your answer to 2(a) is yes, did you cenclude, either at the tire or later, that the noisc had been caused by a hydrogen explcsicn er hydrogen exhustion? If so, en what date and at what time?
l[l Yes, on at atcut o'clcck I concluded that the noise had teen caused cy a hydrc-gen explosion er ced ustion, l_~l No l_~l I do not remeder.
3(a). On Wednesday, March 28, 1979, were you aware er inferred that a hydrcgen explcsien or cc=bustien had cccurred in the DI-2 ccntain-ment building?
l~l Yes, I was aware.
l~l Yes, I irc s informed.
l[i No l~l
_ I do not receder.
3(b). If y.nr answer to 3(a) is yea, at what time did you becere at.are er at what time were you inforecd of the explcsien or cc:iustien?
l]l I became atare er was infcrmed there had teen a hydrc-gen evplosicn er cedustice at ateut o'clv:4.
- l]l I do nct retenber.
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3(c). If.your answer'.to_3(a) is yes, how were you rade aware or did ycu heceme inferred of the hydrogen explosion or e x.bustien?
l]l ' -(State briefly' Nicw) ll _ ' I do not remember.
3(d). If your answer to 3(a) is yes, _did yvu subsequently tell er ctheneise -
cc=runicate to anyone else ateut the explosien er certustien? If so, whcm did you tell, when, and why?
l_-l Yes, I told:
NNIE DATE AND '"T12 - MEniCD Pf]EPOSE (e.g., ccnversation, report, interview, deccsitien, testi-ceny, etc.)
ll No l[l I do not remember.
4(a). On Wednesday, March 28, 1979, were you aware or inferred of contain-rent spny actuation at TMI-2 at cpprcxicately 1:50 P.M. cn that date:
ll_
Yes, I was aware.
ll_
Yes, I was infor cd.
l-l No I
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l_ l I do not rer.crter.
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.4(b). ' If your. answer to 4(a) is yes,' did you s)bsequently tell cr otherwise
'cu anicate with anyone dica about spray actuattan?
l~l.
.Yes, I told:
l1_
No-P l~l
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_ I do not remember.
5(a).- On Wednesday, March 28; Thurh<!ay, March 29, or Friday, March 30, 1979,' were you aware or informed of any instruction not to activate equipment in the .'IMI-2 reacter bitilding because it micht cauce a
. spark and/or hydrocen explosion?
l~l.
Yes, I w:s aware.
l[l Yes, I was inferred.
l~l No
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l~l
_ I do not recerier.
5(b). If your answer to 5(a) a yes, en what date was the instr::ctien' given?
2 l[l Ihe instruction was given on I'. arch , 1979.
l[I I do not remember.
5(c). If your answer to 5(a) is yes, who gave the instructien?
l[I gave the inntruction.
l[l I do not rcre"icr.
- -5(d). If your anrwer to 5(a) is yes, hcw did you learn of the instruction?
,t l[l I heacd , give the instructicn.
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5(d).. (Cent'd.)
.l_~l told re abcut' the~.
instructicn.-
.l_'l .Other (explain) _.
, l~l
_ I do not remember.
5(e). ~
If your answer to 5(a) is yes, did you take any specific acticns in response to the instruction? that acLiens?
l-l
_ Yes, I took the follcwinc acticns:
l l .
l r
l ll_
No 1I_ No specific actica en n:y part recuired.
l-l
_ I do uct renerier.
5(f). Do you knew of anyone else who, en March 28, March 29, er Farch 30, was aware of any instruction not to actitate equipment in the reactor building because it might cause a spark and/cr hydrogen explosien?
l1 Yes, the felicuins rersens were aware of such an instruction:
I_I No h
l_l I do not rcterier.
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If your. answer to' 5(f) is yes, did the perscns identified in ycur .
answer take any specific action in respense to the instructien?-
ll
_ Yes, the follcwing persens took the follcwing actions:
i' l-l No-l[l - I do not remember.
6(a). On f: arch 28, 1979, were you aware at any time of any alar (s) actu-ated by the pressure spike or hydrocen c:cplosien?
1 l-l Yes l l_l No I
I. '
((l I do net rececher.
- 6(b). If your answer to 6(a) is yes, which alarm (M 7 t
ll_
i l[I 'I do not remember.
6(c). If your answer to 6(a) is yes, what at the e ire did ycu think caused i
t the alarm (s)?
l[l I thought the alar =(s) was caused by:
i
6(c). (Cont'd.)
l_~l I did not knew.
l_~l I do not remerter.
6(d). If your answer to 6(a) is yes, did you talk er otherwise corr.:unicate with anyone about the alarm (s), either at that tine or later?
ll_
Yes, I told:
gg PATE AND TIME SUCST.CCE OF THE CCD21LCATIC:'
l~l No 1-'l
_ I do not rererter.
6(e). If your answer to 6(a) is yes, did you take any actica after bcccring aware of the alarm (s)?
l~l
_ Yes, I tcok the follcwing acticns:
l-' l No
( l)) I do not remerter.
! 7(a). With rcspect to the hydrcge:. turn, prescure snike, cr centainment spray actuaticn that cccurt L at 'D'.I-2 at atet.: 1:50 P.'-:. cn " arch 28, 1979, did ycu participate in, overhear, cee, 'r learn of any ccmmunication on these subjects between any CPU ceployee and anyhx!y frcm E&W, NFC, Cctrcnwealth of L' err.sylvania, er any other state agency cr office en I! arch 2S, ' arch 2C, or ."=rch 2C,1979?
7(a). (Cent'c.)
1,]j Yes l.~_.! No l~l
_ I <"o not recember.
7(b).
If your answer to 7(a) is yes, for each such cec: unicaticn anstcer the follcwing : (Utilize correspcndir/J nu: toted lines in iters 7(b)(1) throuch answered.)
7(b)(5) Enlcw to identify the specific instance bcit.g 7(b)(1). Identify the subje-t matter, tire, date, ar:d rathed (e.c., teleph: e, in persen, teletype) in each instance.
ELLTECT TI!E/CATE !TJdCD I
II III IV 7(b)(2). hhat was the substance of each cet=r.icaticn.
I II III IV 7(b)(3). Identify all participants in nach ecer. uni atien.
I II III IV e
7(b)(4). If you were not a participant, did you overhear or see the conmunica-tien in each instance?
I II III IV 7(b)(5). If you did not participate in, overhenr, or see the cocmunication, did you learn about the cor.:.unication from any participant? Str.te frcm when you le arned and the tire, date, nethod, and reascn you were informed.
W1E TIbE/CATE bENCD FT1.' C:!
I II ,,
III IV 8(a). Lo you have documents, including personal rues and liles, t.hich re-late to one or rcre of the follcwing?
- 1. Generation and subsequent ecchustien of hydrcgen en !' arch 2C, 1979 at r:1-2;
- 2. The pressure spike in the 'IMI-2 reacter building at er ahcut 1:50 P.M. cn durch 28, 1979;
- 3. 'Ihe actuatien of the 'D1I-2 reacter building spray at or about 1.2 50 P.ht. On March 28, 1979:
- 4. Any instruction en thrch 28, March 29, or 2: arch 20,1979 not to activate equipment in the ntI-2 reacter building because it mignt cause a spark and/or h 3& ogen explecien 5.
The " thud" cr "thurp" er ct.hcr noise indicating that a hydregen or some other burn, explcsien, or anocal:' cccurred at or alcut 1:50 P.M. en bhrch 28, 1979, at D'.I-2:
- 6. 7.7y alarm (s) actuated by the precsure spike er hydrecen w:.plcsion cn bbrch 28,1979, ac til-2: a ri l
l
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8(a). (Cont'd.)
7 Any ccts:unications or retbcds or lines or cer tmication en 3'. arch 28, 3979, related to generation and subsequent co: ustion of hydrogen, pressure spike, or contain ent spray actuation the.t cccurred that date at '31I-2.
l~l Yes, I do nave documents.
1_l No, I do not t: ave any document's.
8(b). If ycur answer to 8(a) is yes, please cocplete the folicving:
Ycu cay contact me at , (telcpbcne nutter),
en (date) at receiving ccpics of these documcr.ts. _ (tite), to arrarse Date t!ane i
C532u
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