ML20106D608
| ML20106D608 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 10/24/1984 |
| From: | Bernabei L GOVERNMENT ACCOUNTABILITY PROJECT |
| To: | Blake E SHAW, PITTMAN, POTTS & TROWBRIDGE |
| References | |
| CON-#484-739 SP, NUDOCS 8410260071 | |
| Download: ML20106D608 (24) | |
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GOVERNMENT ACCOUNTABlu1Y PRogg 1555 Connecticut Awmue, N.W., Suite 202 uwRC Washington, D.C. 20036 (202)232-8550
'84 00125 All:29 HAND-DELIVERED H.Qg!y October 24, 1984 renC: %,",g BCCh0 q S i)
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sh Ernest L. Blake, Esquire Shaw, Pittman, Potts & Trowbridge
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1800 M Street, N.W.
Washington, D.C.
20036 j.,39
Dear Ernie:
I am writing to respond to your two letters of October 22, 1984 which were delivered to me on Tuesday morning, October 23.
I would like to address both your and Mr. Wilson's comments in your first lette'r about specific documents wnich I believed were not properly disclosed to TMIA in discovery.
Secondly, I wish to address the current document production system which I believe has caused some problems and aggravated other problems of document production in this case.
First, after review of the document requests I have made recently in this case I agree that I did not make a request to review or have produced a copy,of Mr. Abramovici's interview given to the NRC.
Therefore, I apologize for my statement that the Abramovici interview was deliberately withheld.
I would like to explain, however why I believed I had ordered the inter-view and the general confusion regarding GPU's production of documents in this case.
s I would like to add some background to my complaints in my October 16, 1984 letter to you which you have omitted.
In fact I did make a request following the last deposition in Harrisburg on Friday afternoon, October 5, 1984, to gain access to the Shaw, Pittman Document Room the following Monday, October 8.
l As you know, at the time we then had depositions scheduled in
.Harrisburg for the following Wednesday and Thursday, October 10 and 11.
Because of the rules of the Document Room it is not l
j possible to have documents copied unless one allows 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> for copying.
Given that restriction, I wished to review the documents on Monday, October 8, in order to have the documents r
available for the October 10 and 11 dopositions.
At that time l
I told you that I would come into Shaw, Pittman between 12:00 l
and 2 p.m. on October 8 to review the documents.
The intent of that statement was that I would enter Shaw, Pittman's offices at some time on October 8 between those times and stay some l
additional time to review the documents.
l 8410260071 e41024 i
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.I returned to my office Saturday' morning to find a telephone message from someone in my office who had received.a call-from
-Shaw, Pittman which stated as follows:
Dave Rubinton - (an Antioch p
student-who works in our clinic), Joanne Doroshow and you are
' cleared with security at Shaw, Pittman on Monday, October 8.
I g~
assumed from the~ telephone message that all three of us were
' cleared to, review documents at any time during the day.
On Monday I called Shaw, Pittman at about 2:15 to indicate b
that I would be coming.to the finn to review documents within a short1ti.me. 'JU; that time the receptionist stated that she had 4
spoken'to a paralegal and that apparently there would be no problem with my coming over1to the firm to review the documents.
At the, time I arrived a paralegal, who I had not met before, said she was working on another case and could not help me.
0The firm appeared to be quite busy, even though-it was a federal holiday.)
+
-I informed the paralegal that I was familiar with the organization of documents and that.if_she would simply bring the requested docu-i
.ments to the-discovery room I would have no problem in reviewing tluun and requesting - the necessary copies without her assistance.
She said that she could not do that.
4 Subsequently I spoke to Ms. DeBow who was at home.
I informed her that given our_ deposition schedule _for Wednesday, and the requirement of 24Lhours to copy documents, we would not be prepared for_the depositions if we could not be provided access to review the documents that day.
After unsuccessful attempts on'both our parts to reach you at your home, Ms. DeBow agreed toLcome to the office to assist me in reviewing the docu-ments.. At'the time she arrived at the office, around 4:30 p.m.
I_had returned to my office for a copy of TMIA's discovery requests and was in the process of making a list of the documents I. wished to review or copy.
As you know, GPU has not provided an index of the documents which it has produced in response to our discovery requests.
Therefore, in essence, TMIA has to know that a particular inter-view or deposition exists in order to request it, or make a general sweeping request for all interviews of a particular individual.
Further, GPU has made additions to its responses to specific interrogatories and document requests without specifically informing TMIA of'this supplementation.
Therefore, it has been necessary to do a complete re-review of the documents GPU has produced in response to TMIA discovery requests in order to pick l
up any additional documents which have been added since the last review.
(This is contrast to your prior practice in which you
a 3-placed the documents which supplemented prior responses in separate folders with the date on which the documents were placed in the Document Room.)
As you know, this led to our late review of the notes of Mike Morrell, on which was based in part TMIA's recent motion to extend the discovery period.
L In any case, after ordering the depositions and interviews which I wanted, I began a review of the~ entire set of documents produced in response to TMIA's First Set.of Interrogatories and
~
First Request for Production.
-I completed my review in about 45 minutes, and ordered a number of documents in accordance with the instructions I had received from a paralegal with whom I had spoken prior to speaking to Ms. DeBow and in accordance with the written instructions in the Document Room.
When Ms. DeBow returned I gave her my order'of documents to be xeroxed.
She then told me'that one had to use a different system to order documents, different than the prior system in which I had been instructed and the one which was in written form in the Document Room.
She and I then~ spent 30 minutes re-writing my request for documents in accordance with these new instructions,.
As I have told you on prior occasions, I do not believe this system allows TMIA or-its counsel adequate'acces's to the documents GPU has produced in the course of discover'y in this case.
In addition, as I have explained to you at a prior time in September, Mr. Rubinton, a student who has spent several days reviewing interviews and depositions in your Document Room has had similar problems.
For example, on'one day in September, he made four separate requests for particular documents.
He gave me the four separate request forms he filled out on that day.
Ms. DeBow was unabla to produce the requested documents in response.to those four requests.
Only after I made the very same request of you, and you made the request of Ms. DeBow in the exact same form as Mr. Rubinton's fourth request were the U
documents produced for TMIA. - This particular request consumed at least two hours of Mr. Rubinton's time and about one-half hour respectively of my time and your time.
Moreover, on October 18, 1984, you informed me for the first time in the course of discovery in this case that GPU would not make available documents produced in this case past the discovery cutoff date of October 15, 1984.
At that time GPU was still supplementing responses to TMIA's prior discovery requests and TMIA had not had an opportunity to review these supplemental responses.
At that time I informed you that it was my experience i
that documents produced in the course of discovery were to be 1
- made available from the time they were produced up until the time i
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of the hearing.
.I also stated that it was my understanding that this had.been the practice in the course of discovery in these proceedings.- Since Ms..Doroshow wished to review certain documents in preparation for Mr. Lowe's deposition, scheduled for 11:00 a.m.
on Friday,gOctober,19, 1984, I told you that I would seek the intervention of the Licensing Board if we.were' denied access to the documents to prepare'for that deposition.
You acce to my request and-in reconsidering later stated that you would make the documents available until November 7, 1984.
In your second. letter of October 22, you placed the additional condition on TMIA that it inform you one day before any review of i-documents in1the Document Room of its desire to review documents.
Although I believe that this condition creates a burdensome process and unduly restricts TMIA's access to the' documents I have agreed i.
to attempt to comply with this new rule.
As I have' stated toiyou at prior times, I would prefer to work out a document production system which provides TMIA adequate
- access to the docuemnts on a regular basis.
That has not been worked out so that we have' encountered the problems we have today; Second, I still believe that GPU should have produced and did not in fact produce the Abramovici notes' and Lentz' notes' identified in the course of the Abramovici'and Lentz'dep'ositions held on October 15, 1984.
In_the case'of theseLtwo sets of notes, they are notes which fall within TMIA's discovery requests, are similar to notes of other individuals which have been produced in discovery in this litigation, and are clearly relevant to the issue at hand.
L j
I stated in my letter of October 16 that it appeared that
'E Mr. Abramovici notes may contain references to the incore thermo-
- couple temperatures and actuation of containment sprays.
I have drawn this conclusion from-the following testimony of Mr. Abramovici.
(I have attached the relevant pages of his deposition.)
1)- Mr. Abramovici testified that he believed he took notes of the briefings by Kunder and Bensel on March 28.
He stated that
- if he-still maintained notes taken during one presentation he would have maintained notes taken during the other.
Transcript at 28 2)
Mr. Abramovici testified that he believed either Mr. Bensel or Mr. Kunder told him and others that " core thermocouples were peaked high, which would have been probably in excess of 2500."
Upon showing him Mr. Moore's notes for a 5:00 p.m. briefing in which it is indicated that the' individual giving the briefing stated that incore thermocouple ~ temperatures read in excess of
~
' 2500 degrees F, Mr. Abramovici testified that he believed he had heard that briefing, although he ~did not recall whether Mr. Bensel or some other individual had given~it.
Tr. at 22
4<
3)
In. addition, Mr. Abramovici testified that he had answer ~ed
~in his questionnaire to GPU tha't he.had learned of actuation of the containmentLsprays on' March 28 bec'ause'that was his best memory at that time.
Tr. at.36 4):
In_ response'to questions about who informed him of the actuation'of the' containment sprays Mr. Abramovici stated "I think one'of the' individuals--again, I don't'ev'en rem ~ ember if it was Bensel, I can't ev'en remember'--I hea'rd ther'e was an' actuation.
.I couldn't even~tell wher'e'I hsa~rd it from~."'
Tr. at.35 (Note 'tha~t the transcript is incorrec't in attributing this statem'ent'to Mr. Wilson.
Mr. Wilson made 'an objec'tior. as to form, and then Mr. Abramovici went on to answer' ths' ques' tion posed.)
I believe'that given Mr. Abramovici's testimony on~ October 15,
.it is reasonable to conclude the'following:
1
^
1)
Given that Mr. Abramovici had taken notes' of ths'Bensel presentation and given' that"Mr. Moore's notes indic~ ate.that some-one possibly Mr. Bensel, informed him.of 2500 degress' temperatures, 1-Mr. Abramovici's notes'of the'Bensel' pre's'entation, if hs still had them, may indicate'a briefing of such temperatures'.
2)
Given that Mr. Abramovici had stated that hs' learned of the actuation of the' containment sprays on March 28 or perhaps the early morning of March 29, and given that he took notes of briefings by Kunder and Bensel, and perhaps othsr' notes, it is possible to l
-infer that his notes of March 28 might mention containment spray
-actuation.
L 3)
Mr. Abramovici's notes of March 28 and 29 are relevant to his knowledge of hydrogen, the pres'sure spike, core damage'and
.incore thermocouple temperatures on March 28 and ths'early' morning of March 29.
I have not yet.had the opportunity to review Mr. Abramovici's notes, now produced in the Document Room.
However given the fact that there is a mention of "H2 concentration unknown" on the top of one page, it appears that it was clear from the' start that l
Mr. Abramovici's notes were.within the~ scope of permissible i
discovery.
l l
Moreover, it appears from Mr. Wilson's statement about these I
-notes, which appears on page 4 of your October 22 letter, that he l
did review Mr. Abramovici's March 28 notes prior to his deposition.
In addition, GPU was previously aware of these' notes' since Mr. Abramovici produced them in response to a request from the NRC in the course'of its original investigation into the Accident.
d
- .- 1 Therefore I believe that GPU was under an obligation to
. produce the Abramovici notes prior to his deposition.
It was only after.Mr. Abramovici himself identified the notes that they were made available.
Third, I believe Mr.ELentz'~ notes of March 28 should have
~
been made'available.
As you know TMIA believes that the lines of reporting between the GPUSC enginee~rs sent to the site on March 28 and GPUSC top management in Parsippany is information relevant to the' issue before the Board.
Mr. Lentz's notes from a morning Lmeeting:in.Parsippany establishes' the' tasks given to the five GPUSC engineers who were'sent to the' site'on the first day of the Accident.
Mr. Lentz'was one of.those'five enginee'rs.
In order
['
Parsippany on March 28 and March'29 one needs to understand the to determine what information was transmitted from the site to reporting relationships established'for the GPUSC engineers sent to the' site.
This is especially important when none of the five GPUSC engineers now remembers the time he reported back to Parsippany.
Further, Mr. Moore's notes'of this same morning meeting in i
Parsippany have bee'n produced in the course'of discovery in this
- proceeding.
Mr. Lentz apparen'tly produced these documents to Mr. Wilson'a'nd Mr. Wilson, in return, produced them to me'in the course of the deposition.
It appea' red as though Mr. Len'tz'consi-dered them relevant to his actions on March 28, at least to the 1
' extent of providing them to Mr. Wilson for production in this pro-ceeding.
(Mr.'Lantz' stated that he had produced the same packet of documents in the course.of the' GPU v. B&W litigation as well.)
My review of the two-pages of Lentz' notes indicates that in fact the notes lay out an assignment of tasks for various GPUSC personnel, both the engineers sent to-the' site'and top GPUSC management who. remained in Parsippany.
Therefore, the notes themselves bear out the relevance which TMIA places on them--that is they: help establish the line of reporting within GPUSC estab-L lished on March 28 between the site and Parsippany.
Further, I do not understand what Mr. Wilson's statement means that I misrepresented Mr. Wilson " indicated that [Ee7 would produce the Lentz notes from March 28, 1979 during the deposition..."
He did in fact produce the notes during the deposition.
After
- Mr. LenH hacT provided me with copies of his original notes,
- Mr. Wilson pulled from his briefcase a copy of these same'noten.
The point I made in the letter was that Mr. Wilson provided me with a copy of the notes only after Mr. Lentz provided them to me.
I also would like to correct your statement in your letter which states that " Licensee's lone request for a copy of TMIA docu-monts was made on October 2 and still is not fulfilled although it involved only six documents."
TMIA, in response'to your document
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_j 7-s 9; requests on the Dieckamp Mailgram-Issue has identified all docu.
ments within its possession and control.
I produced one document, which you did not previously'possea's,in the course'of our putting together the Mailgram Stipulation.
.I also indicated that I had i
' copied and would make: available to you certain memoranda which you
-might not otherwise have availaole.
In response to a specific
-request from Mr. Lewis for six documents I made them available.
In one case I have not been able to find a copy of particular
)
l notes, but indicated that at such time as I do find them I will make them available., As Mr. Lewis knows, these notes are quoted verbatim in.the Raymond Interview,1which I have produced for you.
Further,1these documents are all interviews which were conducted in the course of the NRC, Kemany..or Senate' investigations into the Accident.
Once I understood Mr.-Lewis' specific request I attempted in an expeditious manner'_to copy and send you the docu-ments.
Other than the Raymond notes I believe I have made all the interviews which you requested available to you.
- In conclusion, I did not lightly state that I believed cer-tain' documents have been deliberately withheld from TMIA in the 3'
' course of document production in this case.
As I stated earlier ~
in the letter I was wrong with regard to the Abramovici NRC inter-
. view.
However, I continue to believe'that GPU was not forthright
/
in its production of the Lentz' notes and the'Abramovici notes.
~Pinally, I wish to set up a time to discuss Licensee's
' Response to TMIA's Fifth Set of Interrogatories.
By my calcula-tions TMIA must file a motion to compel ~by October 29.
Therefore I.suggest-that we' meet to' discuss licensees response on Thursday,
-October 25.,Please contact me as to whether or not you will be available on that date.
4 Sincerely yours,
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g, Ly Bernabei cc:. Service List l
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A Previously, no.
2 MR. WILSONi May we go off the record for a second?
'3 (Discussion held off the record.)
4 A
Like I say, I'm still not sure if it was Benson or
~
5 Bensel, but it was Dick, I remember.
6 BY MS. BERNABEI:
7 Q
It was. Richard, okay, Dick.
8 A
And he was an electrical engineer.
9 Q
If I represent to you that person who was an electrical 10 engineer at that time with the first name of Richard was 11 Bensel, that would sound right to you?
12 A
If I see his face or picture, I could recognize him.
{
13 Q
But he was an electrical engineer with the first name 14 of Richard?
15 A
Right.
16 Q
How did it come about that you were briefed by Mr.
=
17 Bensel?
18 A
Like I said before, he just came there.
I don't know 19 who called him or....
20 Q
You took certain notes of the briefing?
21 A
That's correct.
22 Q
Did anyone else, to your knowledge, take notes of 23 that briefing?
24 A
I think so.
25 Q
Who was that?
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A-Like I say, I don't remember who was.there with me, but 2
I know that whoever was there, I remember I was writing because 3'
they were writing.
I was still in my learning stages of 4
engineering, co....
5 Q
Do you remember Mr. Bensel mentioning to yoa that in-6 core thermalcouple temperatures in excess of 2500 had been 7
read?
8 A
I can't say for sure whether he told me or the person 9
subsequent to him who we' interviewed, but I do recall that the 10 core thermalcouples were peaked high, which would have been 11 probably in excess of 2500.
u Q
I'd like to show you what has previously been marked 13 as Moore _ Exhibit 1; specifically, certain notes or handwritten
}[]
14 notes which Mr. Moore has identified as notes he took at the 15 5:00 p.m. briefing on March 28th.
16 I'd like you to review the two pages which appear 17 under 5:00 p.m., March 28th, and see if that's the substance g
of the briefing that you remember Mr. Bensel gave you at that 19 time or on that date.
A Yes, they are.
The facts seem reasonable.
I just 20 don't recall whether it was Bensel or somebody else.
21.
Q But the substance of what appears in that two pages, 22 does that accord with your recollection of what was told you 23 Lhat day at the Observation Center?
g A
To the best of my recollection, yes.
25
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. as-there any discussion at the time t' hat you
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-Q-W 2
learned of the in-core'thermalcouple temperatures in excess 3
of 2500 degrees of what significance that had in terms of 4-core damage?
5 A
Again, to the best of my' recollection, somebody'did 6
say -,and again, I can't say.if it was Dick Bensel or some-7 body in the group or George Kunder who interviewed afterwards-8; but there was an indication of core damage.
9 Q
Did t, hey link it into these high temperature readings ?
10 That is, did anybody ind'icate that being over 2500 degrees 11
. indicated core damage?
12 A
I don't remember that.
'j{y 13 Q
.But someone did speak about the fact that there had 14 been core damage suffered?
15 A
That there.was potential for core damage.
16 Q-Was there any discussion at the time again when you
~ 17 -
heard about the thermal couple readings that that is infor-18 mation that should be reported to the NRC7 s
A I do not recall.
20 Q
It may have been discussed, you just can't remember?
21 A
I do not remember.
l 22 Q
Did Mr. Moore or yourself or anyone else talk'about 23 reporting this back to your home office, to Parsipprny?
24 A
I do not recall.
25 Q
Do you know if this information was reported back
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1 to your home office?-
2 A1 As I previously stated, JimMoore indicated that he
,3 did call back to Parsippany.
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-4
-Q Did he indicate that he had-informed them of what
~
5 he had learned the first day, March-28th?
6 A -
I don't know what he informed-them or who he talked 7
- to.
8-Q But he did indicate he called at some time after he
.9 received this 1nformation?
10 A
I don't remember.
It would be just purely specu-11-lation on my part to say yes.
12 Q-Now, after Mr. Bensel briefed you, Mr. Kunder
]
13 briefed you, is that correct?.
- 14
'A That's' correct.
15 Q
How did it come about that Mr. Kunder briefed you?
16 A
He came in from the control room.
Who called him 17
' or how he got there,- I really don't know.
m Q
Was this a briefing primarily of your group of five
[-
19 from the Service Corporation?
20 A
That's what I remember, yes.
21 Q
So --
22 A
Well,.by saying five, again, I don't know if there 23 were'three or five or two.
24 Q
However many were there?
.:s A
Yes.
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Q It's fair to say that whoever was in the Observation 2-Center was probably included in these briefings; that is, 3
whether --
4 A-
'No.
~
5 Q
Not necessarily?'
6 A -
No.
There were many more people in the Obersvation 7
Center.
8'
'Q I'm talking about just Service Corporation people.
9 There's five in your group.
What I'm saying is it's fair to 10 say that whenever they arrived, they became part of these 11 briefings?-
u MR. WILSON:
Objection as to form.
{
13 BY MS. BARNABEI:
14 Q
Do you understand my question?
15 A
I guess not.
16 Q
There were five of you that came down from Parsippany,
17 is that correct?
18 A
The five that I know of, yes.
1.
ur Q
The five that you know of.
And people arrived at 20 different times?
l L
21-A That's true.
L 22 Q
What I'm asking you is in terms of these two briefings, 1
l 23
_ starting off with the five o' clock one, is it fair to say i
a that as many of the five of you as had arrived participated 25 in that briefing, listened to the briefing?
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MR. WILSON:
Objection as to form.
2 A-I'm_not sure again what you're asking.
I think 3
there was -- that some of us were present.
If there were 4
other people from the Service Corporation....
5 BY MS. BARKABEI:
6-Q No, let me ask the question again.
I'm not phrasing 7
it properly.
'8 You arrived at somewhat staggered times, you and 9
the five.
Now,.I'm not talking about anybody else, but the 10 five of you in your group.
11 What I'm saying is, is it likely that whoever had E2 arrived at.5:00 p.m. listened to Mr. Bensel, participated or
))f 13 listened to the briefing?
14 MR. WILSON:
I still have to object as to form; is 15 it likely that.
16 MS. BENSEL:
I'll ask the question a different way.
17 Is -- Well, I'll leave the question.
E A
As I say, I know at least one more other than me B
was there.
Whether there were five or four or three, I don't 20 remember.-
21 BY MS. BARNABEI:
22 Q
But whoever had arrived at the Observation Center, 23 did they come to the briefing?
24 A
I couldn't say.
25 Q
You don't know, okay.
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27 1-Now, what did you learn from Mr. Kunder?
2 A
Again, I would have te go back to my -- I just II don't recall at this point.
Ycu know, stil1 more information,
~
4 a lot of the same thing that we had already learned previously 5
from Dick Bensel.
6 Q
Did Mr. Kunder have with him a sequence of event 7
recorder, any hard data from that recorder?
8 A
I don't recall.
9 Q
Do you remember him referring to the sequence of 10 events recorder?
11 A
Again,.I remember one of the two mentioning computer E
alarm events recorder, computer alarm recorder that could not
]([)
13 keep up with the alarms,that whenever they were printed, were 14 actually printed minutes after the actual alarm took place,
' 15 but whether it was Bensel or Kunder, I do not recall.
16 Q
But one of those two --
17 A
One of those two, yes.
18 Q
Did they mention any other data or forms of data B
about the accident?
20 A
I recall mentioning of the so-called reactimeter 21 data, which as soon as it became available, B&W would have 2
the first crack-at it because from what I recall, it belonged 23 to them.
Then subsequent to that, we could get a dump for 24 us.
That's a computer dump, computer printout.
25 Q
Do you remember Mr. Kunder mentioning anything about
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I the status of.the reactor at that time; that is, at or about 2
6:00 p.m.?
.3 A-I don't remember.
't 4
Q
.Did you take notes of this briefing or did Mr.
5 Kunder?
6 A-Yes.
7 Q
Do you maintain those in your file?
8 A
LIf I have Bensel, I'll have Kunder.
-Q Whatever notes, if you maintained them, you would 9
M.
have them both?
11 A
That's correct.
Q To your-knowledge, you produced them for the company n
13 in the course-of this litigation?
{y A'
Not for the company.
I know I had them with me at 34 15 that interview with NRC and they asked me if-they can make 16-copies of those notes.
Q And they did make copies, to your knowledge?
17 A
I produced them.
I'd also like to mention, there 18 was a divisional representative from the company.
I think g
F-his name was Brown, and for all I know, he may have made a 20 copy for the company, but I'm not -- I couldn't say.
21 Q
What did you do after the briefing by Mr. Kunder?
22 A
.Again, from what I remember, we stayed around the 23 observation center until sometime that night.
I don't recall c
24 when.
I think it probably went into the night.
25
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29 I
l Q.
. When you say we, who else?
2 A~
M:e and George Lehmann for sure, and I'm pretty sure
- 3 Jim Moore, but again, I just -- The~ reason.I'm pretty sure of Geo"rge Lehmann is because we came back in this same car _and.
~
4 5
'we stayed as a pair.
I do recall that Rich Lentz and Gary 6
.Broughton went back to the hotel and told us when the reactimeter 7
data gets back,.give them a call and they would be back.
8 Q
What time did they leave?
.9-A I don't remember.
10' Q
Mr. Lentz went into Unit-2, did he not, to collect 11 some data?
u A
He'did go into the unit to the control room, yes.}} l13 Q What time was that? 14 A It was sometime later on the 28th or early on the 15 29th, I don't recall the exact time. , 16 Q What data did he collect when he was in the control -17 room? m A He brought back some data, I don't recall what form 19' they were in. 20 Q It was computer data? 21 A I don't recall. i-22 Q It didn't include the reactimeter data, is that fair Sg to say? i g A I don't remember. 25 Q Did it include any of the alarm printouts? t - GEIGER & LORIA REPORTING SERVICE. INC., 1000 MARKET ST.. HUG. PA 17101 HBG. 234 2109 PA 1000-222-GLRS - I t b' ~ ~
30 f: .1 A I don't remember. -I know we had some pressure and 2 temperatures, but that's all I remember. However they came 3 through, I don't know. I remember it was in tabular form. 4-Q When you say in tabular form, what do you mean; as ~ 5-though in a log or on a computer? 6 A I remember a form that had pressure and temperatures 7 versus time and other data. 8 Q Do you remember seeing any strip charta or strip .9 charts of pressure temperature or copies of those? 10 A' No, I do not. 11 Q~ You can't remember any alarm printouts? n A I just don't remember. They may have been there, I 13 just don't remember. 14 Q Do you remember for what time period he collected 15 data? Again, we're talking about this March 28th period. 16 A I do not. 17 Q Did you review this data at the time he brought it 18 back to the Observation Center? ' 19 A We -- again, we is me and others; again, I don't 20 recall who the others were -- we started to plot the pressure 21 versus temperature. 22 Q Did this include Mr. Broughton? 23 A I don't remember. Probably, but I don't remember. 24 It would just be speculation. 25 Q Did you plot or did you use this data in any other j( way? - GEIGER & LORIA REPORTING SERVICE. INC 1000 MARKET ST..H8G. PA 17101 HBG. 234 2109 P41800 222 CLRS -
31 1 'A. 'I'm sorry?. 2 . Q 'Did you use or plot this ' data any other way? 3 .A-We plotted,-yes. 4-Q. Wh'at other kind of plots other than'the one you've ' 5 describ'ed did you make? 6 -A-That's all I remember, just the pressure versus g 7. . temperature to_ determine whether we reached saturated 8 conditions or not in the reactor. _g -Q And you in fact determined you had reached saturated .10 - ' conditions, is that' correct? A That's correct. 1
- n Q
I'll show you what's been previously marked as Lentz 13 Exhibit 3. I can tell you it's a number of pages: of notes of { 14 Mr. Broughton, which he took on March 28th. 15 Specifically, I'd like to refer you to the two plots 16 that he stated that he and others made on March 28th and ask 17 you if you can identify those two plots. s A I know we plotted something, but whether it was this ig or not, I just don't remember, m Q Can you review both? There's two plots there, one 21 on page seven and page eight. 3 A Both,,yes, Q Do either one of those look familiar to you? m A No. y Q-Now, reviewing this for a moment, what kind of data g N.. - - GEIGER & LORIA REPORTING SERVICE. INC 1000 MARKET ST HSG. PA 17101 H5G. 234 2109 PA 1500 222 GLRS - ~
32 g. 1 is necessary to make those two plots? 2 A This one appears to be steam generator pressure, 3 steam generator level. I would say B, feed water flow. 4 Pressure, steam generator pressure is here. I don't know if 5 they mention or not. On the second graph, it's pressurizer -6 level, primary pressure, saturation pressure, primary temper-7 ature, and obviously time. In looking here, I think also B 8 is temperature was his primary -- or steam generator -- looked 9 like primary temperature. -10 Q Do you know what form one could obtain that data 11 from TMI? In other words, what form would that data come in?. D A From my recollection of what the reactimeter data ][. 13 looked like, I would say this would be easily obtainable from 14 the reactimeter data. 15 Q Assuming that the reactimeter data was not available 16 at that time, where would that information likely come from 17 or where cculd it be obtained? E A I think it would just be purely speculation on my 19 part. 20 Q In your prior interview you stated -- I'm sorry, 21 your interview with the NRC on June 11th,1979 -- on page 10 22 you state that Mr. Lentz went into the control room when he 23 brought the sequence of events and he also brought some pre-24 liminary data. 25 What sequence of events were you talking about at f that time? - GEIGER a LORIA REPORTING SERVICE. INC.. 1000 MARKET ST HBG. PA 17101 HDG. 234 2109 PA 1800 222 GLRS -
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[ 1 MR. WILSON: Objection. May the witness see his 2 testimony? .3 BY MS. BERNABEI: e 4 Q Sure, would you like to? 5 A I don't know if it's going to refresh my memory or 6 not. 7 Q Top of the page on page 10. 8 A .I don't recall. It probably was the alarm sequence 9 of events, but,I just don't recall. 10 Q After Mr. Lentz brought back the data -- and there's 11 been testimony that at this time there were some plots made, - 12 and Mr. Broughton has identified the two I've just shown to 13 you as those plots that were made on March 28th -- during this .{ 14 Period of time, do you remember any discussions about core 15 damage? 16 A No,'I do not. 17 Q Do you remember any discussions about the pressure 18 Spike which had occurred previously at 1:50 p.m.? A Pressure spike? ig Q Yes. 20 A You're talking of the Reactor Building pressure spike ? 21 Q That's right. 22 A No. 23 Q Do you recall any discussion with production of g 25 hydrogen? - GElGER & LORIA REPORTING SERVICE. INC.,1000 MARKET ST H8G. PA 17101 HOG. 234 2109 PA 1000 222 GLRS - _.n-n-e,ea-n.---v- -e,
~.. 3h 1 1 A No, I do not. 2 Q Let me ask you this. On March 28th, 1979, did you 3 know that at temperatures greater than 2200 degrees there would 4 be 'a failure of the fuel cladding so as to produce zirconium - 5 steam reaction in hydrogen? 6 A Greater than 22007 The reactor is designed for 7 2500, so I can't see where 2200 would cause -- 8 Q I'm talking about core temperatures now. g A Core te:nperatures? 10 Q Core temperatures. You don't know that now? 11 A Like I say, I know the reactor is designed for 2500 a pounds, 2500 PSI. 13 Q No, no, temperature, not pressure. ][. 14 A I'm sorry. 15 Q We're talking about temperature now. Did you know 16 that at greater than 2200 degrees Fahrenheit -- 17 A I knew that at some temperature significantly higher than the design temperature, there would be a water reaction, g 19 you know, giving off hydrogen, yes. Q Did you know that at greater than 2200 degrees 20 Fahrenheit -- 21 A No, I.did not. 22 0 -- that would produce significant quantities of 23 24 hydrogen? A No. 25 L - GEIGER & LORfA REPORTING SERVICE. INC.,1000 MARKET ST..HBG. PA 17101 HBG. 234 2109 PA 1800 222 GLRS -
r 35 [ 11 -Q Did you-know that at greater than 2500 degrees, that 2 reaction would produce significant amounts of hydrogen? 3 A I'm sorry, I.. confused it before with pressure. 4 Q I understand. Do you know today at what temperatursa 5 -significant amounts of hydrogen are produced? 6 A I do not. It is not my area of expertise. 7 Q. .Do you:know of any discussion, again in your group, ~ 8 '- in the Observation Center.in the evening of March 28th about 9 the.possible production of hydrogen? 10 A On the 28th? I do not-recall. 11 Q Do you know of any discussion, regardless of whether 12 you currently remember it? .{ 13 A On.the 28th? . 14 Q Yes. 15 A No,-I don't.- 16 -Q You became aware at sometime on March 28th of the 17 actuation of the containment sprays, is that correct? 18 - MR. WILSON: Objection. Objection as to form. I 19 think one of the individuals -- again, I don't even remember 20 if it was Bensel, I can't even remember -- I heard there was 21 an actuation. I couldn't even tell where I heard it from. 22 Q But someone had informed you then on March 28th? m A I don't know if it was -- well, somebody informed 24 me that it was on March 28th, but I don't know if I found out l 25 on March 28th or.... I - GElGER & LORIA REPORTING SERVICE. INC 1000 Mall 8(ET ST-MSG. PA I7801 HSG. 234 2109 PA 1000 222 GLRS - f l ~
36- [ 1 Q-Well, you answered a question there for GPU, did you 2 not, in which you stated _on March 28th you learned about 3 _ actuation of containment: sprays on that date? 4 A' If.that's what.I' stated, that was my memory at that 5 time. 6 Q How did you learn about that? '7 A Somebody must have said it, I just don't know who. 8 Q That would have been one of the engineers or someone 9 from the contro,1 room? - M A It would be speculation, I just don't remember. 11 Q Before you said maybe it was Bensel, maybe it was U-someone -- ,]((. 13 A Yes. like.I say, I just don't want to pin it on some-14 body that I really don't know for a fact, I just know that I 15 heard of the actuation. 16 Q When you learned of it, what did you learn? What 17 did you hear? 18 A I just don't recall, just the sprays came on. m Q Did you know at that time -- assuming you heard it 20 on March 28th, as you stated on your questionnaire -- that it 21 took two out of three independent pressure sensors to detect 22 pressure over 28 PSI to actuate the containment sprays? It 23 - had a two out of three logic essentially. 24' A I don't know. It's probably true. I'm asking you now if you can think back when you 25 Q - GEIGER & LORIA REPORTING SERVICE. INC.. 1000 MARKET ST HeG. PA 17101 HBG. 234 2109 PA 1800 222 GLRS d
m - - - - - - ~ - ~ 3 i-t,' l z. 37 I" 1 heard this, did you know of the logic? 2 A Two out of three logic? At that time I doubt very 3 much. -- 4 Q Did you maintain notes when you learned-this? 5 A. I don't recall.- Like I say, whatever notes I have -- 4 '6 Like I say, I don't : remember anything about the actuation. 7 Q-But your best memory is, at the time you filled out a the questionnaire, that you learned about it'on the 28th, is e that correct? That isn't in fact how you filled out the m questionnaire. 11 A -Like I say, the 28th, at one point I made clear, n 'you know, I came there whatever time,.two or three o' clock in . the afternoon, and diir.'u go back to the hotel until sometime 14 the next morning, so considered that time to be one day, ~ m March 28th. If it was at three o' clock in the morning of the 16 29th,.I still-think it was the 28th. 17 Q So, essentially you knew it was sometime in the m evening of March 28th or early morning of March 29th prior to s your return to the hotel? 30 A Right. 21 Q You don't quite remember now who told you? 22-A I do n.ot. 23 Q Is it fair to say that whoever it was that told you, se you considered him a reliable source; that is, someone.... 25 A Like I say, I don't recall the individual, I can't - GEIGER 4 LORIA REPORTING SERVICE. INC 1000 MARKET ST..MOG. PA 17101 HOG. 234 2109 PA 1000 222 GLR $ -}}