ML20100A468

Notification of Intended Joint Mailgram Exhibit Refs & Deposition Stipulations Re Pressure Spike Indication. Related Correspondence

ML20100A468
Person / Time
Site:	Three Mile Island
Issue date:	11/27/1984
From:	Blake E GENERAL PUBLIC UTILITIES CORP., SHAW, PITTMAN, POTTS & TROWBRIDGE
To:	Atomic Safety and Licensing Board Panel
Shared Package
ML20100A472	List: ML20100A468 ML20100A486
References
CON-#484-413 SP, NUDOCS 8412030609
Download: ML20100A468 (4)

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RELATED coGRESPONDENCE

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November 27, 1984 C[sa RED

<;L UNITED STATES OF AMERICA '04 lid -3 ['M :4" 3' NUCLEAR REGULATORY COMMISSION t f ri ' .- ..

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l BEFORE THE ATOMIC SAFETY AND LICENSING BOARD

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j In the Matter of ) I METROPOLITAN EDISON COMPANY ) Docket No. 50-289$2

) (Restart Remand (Three Mile Island Nuclear ) on Management)

Station, Unit No. 1) )

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NOTIFICATION BY LICENSEE OF INTENDED JOINT MAILGHRAM EXHIBIT REFERENCES  ;

AND DEPOSITION STIPULATIONS t l

l During TMIA's cross-examination of Mr. Dieckamp, TMIA re-ferred to an April 6, 1979 interview of Craig Faust and a March '

E 29, 1979 interview of Hugh McGovern. Tr. at 28,672 to 28,602.

TMIA represented that Mr. Faust believed or indicated he be- l l

11eved that the pressure spike indicated a real increase in  !

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pressure at the time it occurred. Tr. at 28,673.  !

TMIA also  !

represented that Mr. McGovern did not question that the pres-sure spike indicated a real increase in prennuro. Tr. at 28,682.

Licensco accepto neither TMIA's charactorizations of tho i

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statarents of those two individuals nor StIA's failure to mention other statments by those individuals which put their reactions to the pressure spike in context. Accordingly, Licensee intends to refer in proposed findings to the folicwing portiens of the joint railgram exhibits.

Licensee intends to refer to item 28 of the Joint Mailcram t

Dchibit, page 145, lines 13-17, where Mr. Faust testified tilat both he and F&ard Frederick suggestod at the time of the spike an instru-nunt ralfuncticn as the cause. Licensco also intends to refer to pages 6 and 7 of item 133 of the Joint Failgram Stipulation.

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Licensco also intends to refer to the Pay 4,1979 interview of

!! ugh McGwcrn, itan 21 of the Joint Pailgram Dd11 bit, Engo 8, in which fir. McGwcrn indicates that they thought the spika was an electrical spike, not an actual pressure spiko. For the satu reason, Licenseo intends to refer to the Septerrbor 3,1980 interview of !!r. l'cCovern, item 111 of the Joint l'ailgram Dchibit, caces 3-7.

Licensco has alco proposed to ttIA that it agrecs to stipulato into evidenco pago 32, lines 8 thrcugh 23, of ttIA's deposition of Mr. McCovern in which fir. PcCovern explains the meaning of his thrch 29,1979 statement. In his t' arch 29, 1979 interview, Mr. McGovern dictated:

"1400 Itad a (loss) of 2-32A and 2-42A(,1 Lous of radiation arca stonitors and an It< building pressuro opiko that went off cealo on narrow rango trutor -- definito epiko otraight up, straicht back down . . . had full Rx buildirvy (upray pumps and DG-VPS, DII-V8's) isolation and coolityt. Scmmno cecured npray pumps, chut DS-VI's and D!!-V8'u (Itugh did) and unicolated atuit ment for building."

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TMIA's representation in its questioning of Mr. Dieckamp that this statement indicates that McGovern did not question that the pressure spike indicated a real increase in pressure is re-futed by Mr. McGovern's explanation in his deposition.

Q. Okay. Now there's no statement -- again, I'm looking on the 2 p.m. entry, the 1400 entry on this page, no indication as to believing the spike was due to an

{ electrical malfunction, is that correct?

A. That is incorrect.

Q. The electrical malfunction?

A.

The loss of 2-32A and 2-42A are motor control con-

tors, electrical buses on the 328 level of the auxil-iary building.

The loss of radiation area and (sic) monitors and the reactor building spike I attributed to either the electrical malfunction of the equipment on the 328 level of the auxiliary building or some sort (sic),of a catastrophic event on the 328 building l

a fire or something else along those lines.

Q. I understand that, and I understand your hypothesis.

But what I'm asking now is does it state in this paragraph other than by inference, by this hypotne-sis, that the spike was due to an electrical malfunction?

A. No, it does not.

I ask you also to recall that this was taken about 3:00 in the morning following a very long day before.

TMIA Deposition of H. McGovern (Sept. 26, 1984) at 32.

During TMIA's cross-examination of Mr. Dieckamp, TMIA nino misrepresented the deposition testimony of Messrs. Lontz and Creitz.

TMIA stated that Mr. Lent: had testified that the strip chart could be removed without disrupting the recordira .

t Tr. at 28,868 . As page 105, line 7, to page 109, line 1, of Mr. Lentz's deposition reveal, Lenta did not so testify. TMIA i

4 has agreed to stipulate this portion of the Lentz deposition j into evidence. With respect to the deposition testimony of Mr.

Creitz, TMIA has already explained its misstatement. Tr.

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at 29,067 TMIA has agreed to stipulate into evidence the por-tion of the Creitz deposition beginning on page 20, line 15, and ending on page 30, line 7.

) Respectfully submitted,

! S !!A W , PITTMAN, POTTS & TROWBRIDGE i W '.b / W la Ernest L Blake, Jr., P.C.

David R. Lewis  ;

j Counsel for Licensee i

i j Dated: November 27, 1984 j

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