ML20132E897
| ML20132E897 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 01/30/1985 |
| From: | NRC COMMISSION (OCM) |
| To: | |
| Shared Package | |
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| References | |
| NUDOCS 8507180191 | |
| Download: ML20132E897 (73) | |
Text
4 i
e -,.~,- 2 ORIGINf_
5 UN11EU STATES NUCLEAR REGULATORY COMMISSION IN THE MATTER OF:
DOCKET NO:
INVESTIGATIVE INTERVIEW
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LOCATION: HARRISBURG, PENNSYLVANIA PAGES:
1 - 72 DATE:
WEDNESDAY, JANUARY 30, 1985 i
fDOCM05000289 91 850620 D
T PDR ACE-FEDERAt. REPORTERS, INC.
officai>*rs 444 North CapitolStreet Washington, D.C. 20001 (27.; N-3700 NATIONhCE CCh*ERACE
.*e 1
1 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION 2
3 INVESTIGATIVE INTERVIEW 4
OF 5
EDWARD RUSSELL FREDERICK 6
7 Killian & Gephart 216-218 Pine Street 8
Harrisburg, Pennsylva nia 9
Wednesday, January 30, 1985 10 The Investigative Interview of EDWARD RUSSELL II FREDERICK commenced, pursuant to notice, at 5:28 p.m.
12 BEFORE:
13 William T. Russe 11, Deputy Director Division of Human Factors Safety 14 Office of Nuclear Reactor Regulation U. S. Nuclear Regulatory Commission 15 Washington, D.
C,. 20555 16 Robert A. Capra, Senior Program Manager Staff of Executive Director for Operations 17 Office of Nuclear Reactor Regulation U. S. Nuclear Regulatory Commission 18 Washington, D. C. 20555 l
19 Smith B. Gephart, Esquire l
216-218. Pine Street i
20 Harrisburg, Pennsylvania 17108 1
21 i
I 22 23 l
24
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MR. RUSSELL:
The date is January 30th.
The 3
time is 5:28.
We are reconvening the interview of Mr.
4 Frederick to cover a new subject.
5 Ry way of background, I would like to read into 6
the record the information contained in NUREG 0680, 7
Supplement 5, Chapter 11, entitled " Change of Operator 4
8 Testimony" at Page 11.8:
The OI investigation identified 9
conflicting testimony and statements by Frederick concern-10 ing his involvement in the inclusion of HPI actuation at 11 0541 in the licensee's sequence of events.
Whether Frederick j 1
12 was silent and never challenged the inclusion of HPI actua-l 4
13 tion at 05,41, as he testified during the OI investigation I
14 and trial, or whether he insisted on including HPI actua-4 15 tion at 0541 as circumstantial evidence and testimony of t
16 others indicates cannot be resolved on the basis. of evidence i
17 developed by OI to date.
I 18 The purpose of this portion of the interview will i 19 be to discuss that circumstantial evidence, some of the j
1 20 statements by others to give you an opportunity to provide 21 your views as to how HPI actuation came to be included and 22 what your individual involvement was.
23 We have a series of exhibits and then testimony
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f g
24 of others.
By way of background, we will be establishing ass. a neemm, inc.
l 25 on the record what those exhibits are and give you an j
f.
3 1
opportunity to review them.
If you have any questions on 2
them, we will take time to discuss those.
Then, we will 3
go into some of the testimony.
4 If at any time, however, you feel you want to add 5
information that is not covered in either the OI investiga-6 tion or in any of the earlier testimony, please feel free 7
to do so.
8 Bob, do you want to go ahead?
9 MR. CAPRA:
I am sure that you have seen before 10 all of the documents that we are going to talk about today, 11 but I would like to go through and refresh your memory on 12
' some of them.
All of the documents, by the way, are contain-13 ed in a' two-volume report.
This is one here, and this is 14 the other volume which is the 01 Report on Operator Change i
15 in Testimony.
l 16 I'm not sure if you have seen the entire report 17 itself or just certain exhibits.
But this was put together i
18 here -- and I will let you take a look at this.
This is 19 a chronological listing of exhibits that are in the report.
s' 20 By chronological, I mean the actual dates of the documents j
21 themselves, including statements by other individuals who I
22 were interviewed on this particular subject.
j 23 There is another sheet here.
These are also l
l 24 exhibits in the report itself which is a chronological list-l g
=
.c mooners. anc.
25 ing of statements made by either yourself or Mr. Faust or
4 1
Mr. Zewe on the subject.
They range from early interviews 2
right after the accident up through the depositions and the 3
trial testimony for the GPU versus B&W lawsuit.
4 And I will give you three other documents here 5
which we may go through today or else you can include them 6
in the file.
Basically, it's a capsulized synopsis of what 7
I believe the statements made by yourself, Mr. Zewe and Mr.
8 Faust contain in these various exhibits on this particular 9
issue.
All three of them are here, but this is yours.
10 MR. GEPHART:
Just a question.
Is that this 11 one, 597 12 MR. CAPRA:
What exhibit number is it?
13 MR. GEPHART:
Number 21.
14 MR. CAPRA:
On the front, does it say --
15 MR. GEPHART:
It doesn't say anything.
i 16 MR. CAPRA:
That's Exhibit 20.
Whose is that?
17 MR. GEPHART:
That is --
18 MR. CAPRA:
That's this one.
See, this is 19 Frederick's right here; this is Faust's here.
l 20 MR. RUSSELL:
And we will be going through the 21 docurents you have in your hand to show you the actual state- ;
i 22 ments.
They have been highlighted in the report.
We have 23 summarized them.
Mr. Capra and I have been through all of 24 the documents.
We feel comfortable that those summaries I
4.
..on wen. w:.
25 represent the chronology of the exhibits and an accurate l
l
e; 5
I summary of the testimony.
2 That summary raises some questions that we would 3
like to discuss with you.
So there will be a period of time 4
now that we will be developing background before we go into 5
that.
We will start now with the earliest exhibit which I 6
believe, Bob, was Exhibit 13.
7 Whereupon, e
EDWARD RUSSELL FREDERICK 9
was called as a witness, examined and testified as follows:
i l
10 EXAMINATION j
l 11 BY MR. CAPRA.
f 12 Q
Okay.- Exhibit 13 -- and most of these exhibits 13 are extracts of documents.
They are not the entire document. {
14 This is an extract from the annotated sequence of events, 15 Revision 0, in other words, the first sequence of events 16 Utat was put together by Mr. VanWitbeck and his team back i
i*
17 on May 10th, 1979.
18 This particular copy has some handwritten notes j
19 on it.
It was determined during the OI investigation that 20 these handwritten notes are, in fact, Mr. Faust's notes.
i 21 Okay.
i 22 If you take a look at it, you will see that at j
23 approximately 0554 they are giving a plant status at the 24 time and there are some handwritten notes up at the top 42 anowwn. =.
25 that says:
Fully initiated HPI.
And that was inserted in i
+
O 4
6 1
by Mr. Faust when he was reviewing this particular document.
2 Again, this is in the May time frame.
3 A
Okay.
(The witness is looking at the documents.)
4 5
Q There are five of these that I want to show you.
6 It takes a minute or two to go through them.
7 The second document is a -- it's OI Exhibit 17, 8
which is a memorandum from Gary Miller, the Station Manager at the time, to Data Reduction, care of' Mr. Tom VanWitbeck, 9
I 10 dated May 21st, 1979.
The memo says:
The attached marked up; 11 copy of the annotated sequence of events is a result of the l
12 TMI-2 FORC meetings held on May 14th,16th and 17th,1979.
+
,I 13 This memo is to formally transmit these comments to the
' i 14 Data Reduction Group.
I 15 l Again, this is an extract from the entire docu-l 16 ment.
But on the back in handwriting is our -- are notations; 17 which indicate who were the attendees at the PORC meeting.
l 18 Included among the attendees were yourself, Mr. Faust and I
t' 19 Mr. Zewe.
20 The handwritten notes which are from Mr. Bezilla l 21 indicate that these notes are also based on operator inter-22 views.
The PORC secretary indicated that this is his hand-l 23 writing here; however, the handwriting was a consolidation j
i 24 of comments that were received on the whole annotated l
g An e noorwn. w.
25 sequence of events as a result of these three days of going s.
.w...
7 I
through the sequence.
2 You will see an entry at 0541.
It says:
Manually 3
initiated full HPI.
There is 'also a handwritten notation 4
out to the side that says:
What does this mean, with a 5
question mark.
I'm not sure whose_ handwriting that was.
~
6 I don't think throughout the OI investigation they deter-7 mined exactly who wrote that.
8 A
All right.
9 (The witness is also looking at these documents.)
10 Q
The next document is also a copy of a one-p' age i
11 extract from the sequence of events.
This one happens to j
l 12 be Revision 1 which is dated July 14th,1979.
i 13 At this particular time, the revision to the l
14 sequence of events did show a typewritten entry now at i
15 0541 that said:
The operator manually initiated high 16 pressure injection to supply additional cooling water to I
t 17 the reactor core.
Out to the side are some handwritten 18 remarks which says:
Zewe, Faust and Frederick insist this l
19 is the case.
20 This particular handwriting is that of Dr. Long, 21 Robert Long.
22 The next document is again a memorandum from l
23 Gary Miller to Tom VanWitbeck of the Data Reduction Group, 3
24 dated July 13th, 1979.
And it provides additional comments
,i d
en wwn.w.
25 on the annotated sequence of events.
i
, _ +,
y n
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8 1
This particular document, the manual operation 2
of HPI at that particular time was not typewritten in, and 3
someone has inserted in here:
Operator manually initiated 4
' full HPI prior to tripping pumps.
Previous comment per 5
W. Bewe.
6 MR. RUSSELL:
That was subsequently confirmed to 7
be Mr. Zewe's handwritting.
8 THE WITNESS:
So this would have been the copy 9
that he was reviewing?
10 MR. RUSSELL:
That's correct.
11 BY MR. CAPRA:
12 Q
Again, this is a copy of Revision 1, dated "13 July 1979.
The PORC me'eting that they are referring to 14
- where this was initially discussed -- we will get into a 15 little more detail -- was in the May time frame.
So this 16 is subsequent to the PORC, meeting.
f I
17 A
Okay.
18 (The witness is looking at the document.)
l 19 Q
The last one of these exhibits is an extract l-i 20 from a Technical Data Report prepared by GPU Nuclear, and 21 the date this TDR was released was February 6th,1981.
22 And it provides the final version of the annotated 23 sequence of events.
It was provided to the NRC.
24 The first few pages of this on -- the first few A2 e n wn. w.
l 25 pages of this document include references.
The references 9
M
%9
a 9
I are all numbered.
The references are also inserted by each 2
of the entries, so that when you go through you can see what 3
the source of the data was, or the input that was used, to 4
provide that particular sequence.
5 If you notice, on Page 41 it is an entry for 0541, 6
which states:
The operator manually initiated safety injec-7 tion portion of the engineer safety features trains A and B g
to supply additional cooling water to the reactor core.
And 9
it goes on to describe the operation of the makeup system and 10 plant status at that time.
11 The references that are utilised for that particu-12 lar entry are Reference 7, 8.D and 9.D.
Re feren ce 7 -- I ' ve 13 got 1.he reference sheet itself.
Reference.7 is a memorandum
\\
14 written by Mr. VanWitbeck as a result of the PORC Committee 15 meeting.
Unfortunately, we have not been able to find a l
16 copy of that particular document.
Mr. VanWitbeck doesn't i
i 17 have it.
It's not included in the OI report.
l 18 The only other references I believe are Reference I.
19 8.D.
8.D is a reference which indicates it was an interview, t
20 two interviews, of you dated March 30th,1979 and April 6th, 1
21 1979.
l I
t 22 The other reference that is utilised there is 23 Reference 9.D.
Is that correct?
I 24 A
Yes.
An e newwn. m.
l 25 o
which is an interview of Mr. Frederick, dated i
l
I 10 1
April 23rd, 1979.
2 A
Okay.
3 (The witness is looking at the document.)
4 BY MR. RUSSELL:
5 Q
That constitutes what we believe is the existing 6
written record concerning the inclusion of HPI actuation at 7
that time.
There are a number of statements that are tape 8
recordings.
There are interviews conducted by NRC.
There 9
are depositions.
They all focus around that small amount of 10 written record.
l l
11 We will be going into some of those now.
And it l
l 12 was significant from the standpoint of the chronology of 13 both those documents and the chronology of how discussions l
l 14 occurred which led to the situation where GPU identified i
15 you as the principle source for inclusion of HPI actuation
{
16 at 0541.
I 17 They did not identify Mr. Zewe, did not identify i
18 Mr. Faust, rather cited you as the particular individual as 19 the source of information for that particular actuation.
20 What we will do is go through those now so that 21 you are able -- so that you can understand what that trend, l
what that sequence of events, was.
22 l
23 A
We are going to go to those reference documents?
I 24 Q
Yes.
We will be doing that.
4A en r.n.w.
25 A
That will be interesting.
t i
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s 11 1
.BY MR. CAPRA:
2 Q
We will take a look at that first.
The first 3
- reference document which is the memo from Mr. VanWitbeck 4
that I said we don't have -- it certainly would be very 5
helpful if we had that particular document.
6 Were you ever shown a copy of that document?
7 A
This interview?
8 Q
No, not that interview.
That's the second re -
9 farence.
Reference Number 7, the memo that Mr. VanWitbeck 10 wrote regarding the PORC Committee meeting, the minutes.
11 A
I don't recall it.
And I didn't keep any of I
12 those interviews.
I have a few copies of these,-but I don't j
', '13 have any of that correspondence.'
14 Q
When you were going through this, either maybe for 15 the-deposition or in the trial preparation, whatever, there 16 is nothing that would indicate in your trial testimony it-17 self or in your written deposition -- I'm sorry, in the 18 transcript of the deposition for the lawsuit, that anyone l
19 ever showed you that document on the re, cord.
Okay.
i 20 So I'm wondering if somewhere along the line in 21 the trial preparation or in preparation for the deposition i
22
. if you had ever seen that?
23 A
No, I don't recall seeing this.
l 24 Q
You don't recall that?
=)
e newwn.im.
25 A
No.
12 1
O okay.
The second reference that was used as a 2
source for' including this particular item in the sequence of 3
events is your interview with Mr. Long and Mr. Ruppert on 4
March 30th,1979, very shortly after the accident, at 5
approximately one or 1:30 in the morning.
4 I've gone through this particular transcript.
I
.7 do not see any mention in here about actuation of HPI at any g
8 particular time.
There is a discussion about tripping the 9
- last two pumps, but I don't recall seeing anything in there 10 which discusses HPI actuation.
11 So I'm not sure if that was included as a reference
- 12 by mistake.
It was lumped together.
That reference had two I
~
interviews as one source of reference.
.But reading throug.k,
13 14 there myself, I couldn't find where that could be used as a 15 basis for including that in the sequence of events.
16 That is the whole interview.
It's not --
i 17 A
That was going to be my next question.
Are you i
18 sure you have it all.
I guess you do.
i 19 MR. RUSSELL:
We have it from Page 1 to the last 20 page, with your signature on the laat page.
l I
21 THE WITNESS:
So the ques?. ion is, why was this l
l 22 cited as a reference?
l 23 MR. RUSSELL:
No.
We are just identifying, as 24 part of the background, that in this particular instance this 42 e nowwn.s=.
25 document cited as a basis for including it, in our review of
13 1
it it does not show that that would provide a basis for i
2 concluding that you were the individual that stated HPI was 3
actuated shortly af ter the pumps were tripped.
It discusses 4
tripping two pumps, but it does not discuss actuation of 5
HPI.
6 THE WITNESS:
So this -reference could have been 7
lost just in a numbering error or something like that.
8 BY MR. CAPRA:
9 Q
Like I said, it was lumped together with the next to interview, okay, as a one-line entry.
Okay.
If you go back 11 through the entire sequence of events, they may have lumped l
those together because somewhere else there is a -- this may l
12 13 have served as a basis for -- you know, those two interviews 14 may have served as a basis for some other entries in the e
15 sequence of events.
16 A
Probably so.
17 Q
Okay.
If you go to the next exhibit there which
{
18 was the other interview which was used as a reference in the 19 sequence of events, it is an interview conducted by Mr.
i 20 VanWitbeck, et al as part of the GPU Service Corporation l
21 investigation that was conducted on April 6th,1979.
l 22 And if you look at Page 2, there is a discussion 23 between yourself and it says the " team."
I'm not sure who j
24 the individual or individuals at the time were who were 4.
,w m oorwei,inc.
25 asking the questions.
Do you want to take a look through that?
w w
14
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MR. RUSSELL:
It's the section which is highlighted!
1 2
in yellow.
3 (The witness is looking at the document.)
4 BY MR. CAPRA:
5 Q
For the record -- I'm not going to do this in all 6
cases but it might be worth it to go through, for the record, 7
and indicate what was said here between yourself and the 8
te am.
The part I'm talking about is where it starts -- this t
9 is Mr. Frederick speaking now:
Later on, it may have been 10 when the pumps were off, we did a manual high pressure in-t i
11 je ction.
This was after the other guys arrived so it was 12 pretty f ar into it.
13 Te am:
When do you think that was Oith relation t
i ja to when reactor coolant pumps were taken off?
l 15 Frederick:
We didn't have a good indication on i
16 the pumps.
We didn't have any Delta-T indication.
It was I
17 about that time we talked ourselves into going into high l
18 Pressure injection.
We felt that we were generating steam 19 in the loops.
I believe it was right in there that we did 20 manually initiate high pressure injection.
I believe 21 throughout the entire evolution we were injecting water, 22 even though it may have only been five or six hundred gallons 23 per minute.
l 24 Team:
Was that before the attempt to restart the C,
s n
.. w.
25 reactor coolant pump?
4
15 1
Frederick:
Yes.
I think it was in between there.
2 We sat for a long time with no flow indication.
3 Frederick, a little bit later on --
4 MR. RUSSELL:
That's Page 4.
5 BY MR. CAPRA:
l l
6 Q
I'm sorry.
Page 4 of the interview goes on to 7
state:
And I don't think it was until the pumps were off 8
that we considered going solid.
That's when we talked our-9 selves into manually initiating high pressure injection.
10 A little bit later on, also on Page 4, you are i
i 11 saying -- this is the point where you were not quite sure, i
12 you are talking about a leakage from the PORV or the code g
13 safety valves.
It's not parti,cular'ly relevant, I'm sorry, 14 to this portion.
Okay.
15 But you can see there that at least this does 3
16 provide some statements that tend to support there was a i
17 manual actuation of HPI some time after the last set of l
18 reactor coolant pumps was tripped and before the restart of 19 reactor coolant pump 2B, which took place I believe around
~ 20 0654 and ran for approximately nineteen minutes.
3, t
21 About at that point in time you believed.
Okay.
j i
22 A
It seems to me I had two times confused.
But l
23 some time between when the pumps went off, and we are saying d
i 24 6:50.
% aj That would be a pretty good span.
And probably it e ame, wen. inc.
h.
2S was 4:20 when the pumps went off, 4 :19.
k
I 16 1
Q Ye ah.
0541 is when the second set of reactor 2
coolant pumps was tripped.
3 A
So what we are saying is a two and a. half hour 4
time period when we might have had high pressure injection?
5 Q
Right.
And again I'm not sure if we mentioned 6
this at the beginning of your interview, we are not trying 7
to revisit whether there was or was not high pressure in-8 jection at 0541.
I think we have concluded, the NRC, that 9
there was a very small probability, if.at all, that there e
10 was a manual actuation at that time.
And if there was, it
!1 did not run for very long.
We are not revisiting that issue.
.12 We are setting some groundwork for statements 13 that you made and other operators made that later were 14 changed.
15 A
Okay.
16 Q
If you will turn to the.next exhibit, that was the i 17 third reference that was used for including manual HPI in 18 the annotated sequence of events.
It was an interview that 19 was conducted a short time af ter that, a couple of weeks, l
20 on April 23rd, 1979.
21 It was an interview with Mr. Hunter, Mr. Yuhas,
~
I 22 and Mr. Marsh of the NRC.
And if you will turn to Pages 48 j
i 23 through 50, I believe that is the excerpt that I have here, j
24 you were asked if you made any changes to HPI when the d
e n orwn. im.
25 reactor coolant pumps were secured.
And you said that:
17
)
1 Somewhere along that line we actually initiated high pres-2 sure injection manually.
3 You made a statement to the effect that that 4
may have been at the time that you secured decay heat pumps.
5 And I'm not sure exactly in that statement what you are 6
referring to by decay heat pumps.
7 Do you mean the reactor coolant pumps, removing 8
decay heat?
I don' t think at this point in time you are 9
talking about RER pumps.
10 (The witness is looking at the document.)
i 11 A
I don't know what I'm talking about there.
That I
i 12 is talking about an initiation of ES and securing decay heat 13 Pungs, when actually when you initiate ES you get the decay 14 heat pumps.
I don't understand why I would be turning them l
15 off at the same time I'm turning them on.
16 Q
Okay.
I'm not sure what you mean.
What pumps 17 are you talking about when you say decay heat pumps?
18 A'
The RHR pumps are the decay heat pumps.
In our l
19 plant, you call them decay heat removal pumps.
Do you i
20 call them residual heat removal pumps?
21 O
RHR and decay heat removal are --
22 A
The same thing.
23 Q
-- the same.
But I didn't think you were at a 24 j
-point in time when you had the RHR pumps operating.
You 4.
e memornes, anc.
25 never did go on RHR.
18 1
A We had injection at the time of the pressure 2
spike started.
I mean, it didn't actually flow in but the 3
pumps were running.
4 BY MR. RUSSELL:
5 Q
Which pressure spike are you talking about?
6 A
The pressure spike in the building in the after-7 noon.
We had to go in isolation.
8 Q
I understand.
That would have been an automatic initiation due to the pressure spike in the building which 9
10 would have started these pumps.
11 A
Right.
Then --
12 Q
But we are now talkirig about the time frame in the 13 morning ---
14 A
Well, see the automatic ES had gone off right at l
15 the time of the accident at 4:03 or whatever it was.
16 Q
Yes.
I 17 A
There was one there.
But this is not either one of !
18 those, because this is --
19 Q
A different time in the morning.
i 20 A
This --
21 Q
This would be a manual which would not result in 22 those pumps operating.
23 A
Yeah, it would.
f 24 Q
Manual -- full manual actuation?
f J
n _. ~.
25 A
Yeah.
Yeah, it would.
What I'm talking about here --
19 I'm not remembering this, I'm telling you what it says here.
1 2
If you go to the high pressure injection panel and push the 3
four red buttons, you get high pressure injection, low 4
pressure injection, building isolation, e~verything except 5
building spray.
6 Q
I understand that.
7 A
Okay.
8 Q
The earlier testimony indicated that this could have been done by simply opening up the high pressure in-9 10 3ection valves to each of the loops to provide the flow",
11 that that may have been interpreted as being the manual 12 initiation of high pressure injection.
13 A
Right.
That's --
?
14 Q
Right.
There was testimony to that effect.
15 There was also testimony that this could have been done by 16 starting an additional makeup pump and opening those valves, 17 which would have been different than going over to the panel e
18 and manually initiating the equivalent of an automatic I
I 19 actuation.
20 A
Right.
I would interpret all those as a manual 21 initiation of high pressure injection, in different forms i
22 but the same effect.
l 23 Q
Do you recall any time during the event that there was one manual initiation that you would have used l
24 Am A Rowwn. im.
l 25 the buttons on the panel which would have also resulted in 4
20 I
1 decay heat pumps starting?
2 A
That's the way I did it around the time of the 3
site emergency; when we decided to initiate high pressure 4
injection, that's how I did it.
I pushed the buttons.
5 Q
And then you subsequently secured the decay heat 6
pumps, the low pressure injection portion?
7 A
I don't know.
I don't recall doing that.
8 Q
Do you recall --
9 A
It would be the prudent thing to do.
By pro-10 cedure that would be the thing to do.
But I don't reca'll 11 doing that, j
12 Q
So you feel that this particular time frame may 13 be associated with the time of the site emergency?
14 A
(No reply.)
15 BY MR. CAPRA:
1 16 O
The data from the alarm printer was regained at i
17 064 8 that morning.
It was lost for a period of time, the I
18 data was lost for a period of time.
But it was initialized.
19 It was a manual actuation at 0720 that morning, and that was consistent, or in the time frame of the general emergency,i 20 a
21 that was declared at 7:24.
I 22 A
You are talking about that actuation?
l 23 BY MR. RUSSELL:
24 Q
Yes.
We are now talking about one earlier between g
4.
e n.poren, inc.
25 the time the four pumps were turned off and you attempted to l
F 21
- 6 P.M.*** I restart the 2B pump.
2 A
I did not do it in that manner.
I only did that 3
once in my life, and that was at the time of the site emergency.
4 It's something that I remember doing.
5 This seems kind of sketchy.
But if I'm talking 6
about initiating with those red buttons, I'm talking about 7
the time of the site general emergency.
8 MR. GEPHART:
That would be at 1:50?
9 MR CAPRA:
No, that's 0720.
10 THE WITNESS:
Between 7:10.
II MR. RUSSELL:
Not the 0541.
12 BY MR. CAPRA:
13 Q
I think the actuation thtt occurred in the after-1 Id noon at 1:50 or 1350 in the afternoon was the automatic --
l 15 A
The automatic.
16 Q
-- actuation, i
17 A
Initiated by the --
I 18 Q
Building pressure.
Okay.
The next exhibit is an l
l' exhibit where you were interviewed by Mr. Keaten, part of 20 l
the Keaten Task Force, on September 19th, 1979.
i 21 In there, on Page 60, you were asked if you took 22 any action with respect to high pressure injection flow at l
23 about the time the last reactor coolant pumps were taken off, 24 t
and your answer to that was, no, that you did not recall tha,t.
Am J Reponers, Inc.
25 It's on Page 60.
)
22 1
A 607
)
2 Q
Six zero.
Do you have the right exhibit number?
3 It was a taped interview.
4 A
Yes.
5 (The witness is looking at the document.)
6 I guess I forgot the question.
7 Q
Okay.
The question was, in this particular inter-8 view, which is now the September 1979 time frame, you were 9
asked by Mr. Keaten -- is he the one that was doing the 10 questioning there?
II A
Yes.
12 Q
If you remembered actuating high pressure injection f
13 at the time the last set of' reactor coolant pumps was taken Id off, and I believe your answer was, no, you did not recall 15 that, that you took no action like that.
16 Is that correct?
I II A
That's correct.
18 Q
Okay.
Now, that's essentially all of your state-I' ments on this particular issue up until you get to the B&W/
{
20 GPU lawsuit and begin your deposition.
i 21 We can leave that for now and go to some other l
statements.
These exhibits also are in here.
But I just l
22 23 wanted to summarize for you -- as a matter of fact, if you 24 have the summary I gave you of Mr. Zewe 's testimony on this i
4.
.m noorwn ene.
25 particular issue, he was also interviewed March 30th, 1979 by
_~
23 1
Mr. Long and Ruppert of GPU Service Corporation.
On Pages 2
19 and 20 of that particular transcript, he says:
So, I 3
went and secured all coolant pumps and then we kept on feeding 4
HPI at this point.
5 So the earliest interview we have of Mr. Bewe is 6
his recollection at the time of this interview, and is that at 7
the time reactor coolant pumps were secured you at least had 8
BPI on at that particular time.
9 The next interview that Mr. zowe had on this subject 10 was on 4/6/79.
It's at this point he was interviewed by "GPU l
11 Service Corporation investigation team, and there is no l
12 distinct statements in there regarding the actual actuation of i
13 HP'I, whether it was or it was not initiated at this particular 14 time.
I think one of the clear things that you realize by 15 this' time was he was very unsure of times that certain events 16 took place.
17 As he began to look at data -- I think he testified :
i I
18 later to that effect -- times became very fuzzy, things that 19 he thought took a very long time to happen actually happened 20 in a very short period of time and vice-versa.
21 Again, this is before the PORC meetings in May.
l 22 I think Mr. Zewe's next interview with IEE, Mr. Marsh, Hunter, i 23 Kirkpatrick and Criswell was on April 23rd,1979.
2' 4.(
On Page 56 he said that both you and Mr. Scheimann e n
,wes. inc.
25 were on the makeup system most of the time the morning of the l
24 1
morning of the accident.
And then he continues on on Page 56 2
and 57 and says basically that HPI was discussed before 3
securing the reactor coolant pumps, and that HPI was increased 4
about this time.
5 Now, it's not clear to me from reading that parti-6 cular transcript if he's referring to the time that you had 7
two reactor coolant pumps still running or not.
So, again 8
there is n'o clear-cut distinction, nothing to help us sort 9
this particular issue out.
10 One of the exhibits that you looked at earlier l
i 11 when we first started in going through the background was the t
i 12 PORC Committee Minutes, May 14th through 17 of 1979, where I
13 yourself, Mr.. Faust and Mr. Zewe were in attendance. And 14 inserted the words, " Operator manually initiated full high 15 pressure injection."
16 So it was after the PORC meeting by approximately I
I 17 a week or ten days that there was a group interview conducted 18 by Met Ed, May 25th, 1979, in which Mr. Zewe, Mr. Miller, l
19 Mr. Seelinger, Mr. Porter and Mr. Ross were there.
And this i
20 following excerpt on Pages 5 and 6 took place I'
21 Zewe:
I think right here is where we went back to 22 full HPI.
l 23 Mr. Miller:
Right, at the point where you turned l
24 j
off the last pump?
l As e noorwn, sm.
j 25 Zewe:
Just before or just after we did that, I
i 1
,----w e
-+-- --
+
25 1
because they took a countdown and Craig hit HPI just'as Ed 2
secured the last two pumps.
3 I think he was referring to you as Ed and Craig 4
as Craig Faust.
5 Bewe I don't know if that was the case or not, 6
but it was just before we tripped the last pumps that we put 7
on HPI.
4 3
Mr. Miller:
Bill, are you pretty sure we had full 9
HPI around that time?
10 3 ewes I was not as sure as the operator who 11 actuated it was.
He is sure, Craig Faust.
I 12 Mr. Zewe:.We talked about that yesterday after i
13, we" reviewed the tape.
And I went,over the complete scenario
~
14 for training and everybody as an aid for future training I
15 classes, and Craig and Ed thought it began -- that's a l
4 I
16 typographical error.
Thought again it was either just.before i
l 17 or -- just before the last two pumps or just after the last i
18 two pumps.
19 okay.
So the gist of his interview at this parti-20 cular time is that this is the first time that he brings up 21 the fact that it was some type of countdown and Mr. Faust 22 initiated HPI and you tripped the last two reactor coolant i
l 23 pumps, and that you had discussed the scenario the day before l
l 24 l
and provided some additional details at that particular time.
l 4.
e nes - w s,inc.
j 25 The point of this being, at least at this point in a
+
4 4
,,---..-,--.,---n
<...n,----,,..-,,,--,---,,,--,-,,n
.-c-----,_,.w,~,----
26 4
1 1
time, one would be led to believe from reading this that Mr.
i 2
Zewe had an understanding that all three of you thought that 3
this occurred, that he had your support, or you had discussed 4
it with him as well as Mr. Faust and himself.
5 Now, Mr. Zewe went on in June of 1979 and discussed 6
the fact that he thought there was a manual actuation at that 7
time before the ACRS.
And that's basically his testimony on a
the subject, again up to the point of the GPU/B&W lawsuit 9
review.
10 And in that particular -- in his deposition ori l
11 May 28th, 1982 around Pages 815 to 120, again he recalls that 12 both Frederick and Faust told him that it was their recollection i
13 that HPI was actuated full when the second set of pumps'were 14 turned off.
15 On Page 824, he says that he learned details from i
16 both Faust and Frederick that made him ramamher it happening.
17 On 826, in discussing the countdown which was that 18 exhibit we looked at earlier, B&W 761, he said he recalled 19 that after discussion with both yourself and Mr. Faust some l
20 time later.
21 At the trial under cross-examination by Mr. Fisk, j
i 22 Zewe said that he recalled all three agreed at the PORC meetingi 23 however, Mr. Faust was the one that was very sure at the time 24 that it happened.
And Zewe recalled that Faust remembered A
el Reporters, Inc.
25 more details than Frederick, but they both relayed information
~
27 y
concerning the event.
2 And the last document where this was discussed with 3
Mr. Zewe, where essentially all of this stuff was gone over 4
again, was the OI interview the day after you were interviewed 5
by OI on this subject.
And on Pages 14-18 of the transcript, 6
he said that Faust advised him at the PORC meeting that he 7
had actuated EPI at the time the last two reactor coolant a
pumps were shut down.
9 He said there were charts at the meeting that 10 showed that it could not have been left on at that particular 11 time.
He believed there was some controversy at the PORC 12 meeting when it was brought up whether or not HPI did actuate i
13 at that particular time.
14 And I think Mr. VanWitbeck was the individua.' who 15 showed some data at that meeting that would lead one to 16 believe that there was no technical support for that argument i
17 at that time.
But at this time, Mr. Bewe said that he had la insisted upon it being included in the sequence of events be-19 cause the sequence of events should also reflect what operators 20 remembered.
21 On Page 24, Mr. Eewe did not recall if all three 22 operators insisted the events were true.
But he did not re-l 23 call anyone disagreeing.
l 24 On Page 43, he discussed the fact that he had talked 4..
a ne.orers inc.
25 to you subsequent and that you informed him that you did not
28 1
agree at the time that EPI had taken place at 0541.
2 Now this -- the time frame we are talking about 3
when he said he had those discussions was after the litigation, 4
after the trial was over.
3 And, again in closing his interview, on Pages 64 6
and 65, he describes a conversation that he had spoken with 7
both Mr. Faust and yourself since the trial and discussed the a
fact that you both thought that Faust was wrong.
9 That's a bird's-eye view of Mr. Sewe's testimony 10 on this particular issue.
11 MR. RUSSELL:
I think it would be useful to similarly 12
, go through Mr. Faust's.
~
l
^
13 MR. CAPRA:
Okay.
f 14 BY MR. CAPRA:
15 Q
Mr. Faust's first interview that covered this 16 particular item was -- again we are back at the beginning 17 again on 4/21/79.
It was an IEE interview conducted with Mr.
f 18 Marsh, Hunter and Jackson.
19 And on Pages 48 through 49 of that transcript, I
20 Faust says:
Something else that I would like to emphasize l
21 is that just prior to stopping those pumps we did reinitiate, 22 we hit high pressure injection just prior to stopping the j
l 23 pumps.
I don't know if that was brought up before.
It j
24 r
should be, though.
4.
e neueren, sac.
25 Mr. Faust went on to say during this interview that e am
29 1
the reason for initiating high pressure injection at that 2
time was that they had voids in the loop and you were trying 3
to establish natural circulation.
4 And he said that you initiated high pressure in-5 jection while he tripped the pumps.
6 BY MR. RUSSELL:
7 Q
Would you like to see that interview?
8 A
No, no.
I'm just -- I thought it came out back-2 9
wards.
C 10 BY MR. CAPRA:
~
11 Q
That's backwards from what Mr. Zewe said.
12 A
Okay.
i 13 BY.MR. RUSSELL:
14 Q
It is.
There is a conflict between Mr. Faust's i
15 statement and Mr. Bewe's statement.
16 A
Okay.
17 BY MR. CAPRA:
18 Q
You are going to find there is also a conflict IP later in what Mr. Faust said his role in this was.
You are i
20 going to find Mr. Faust said that he tripped two sets of 21 reactor coolant pumps and he believes you tripped the other l
22 two.
And he believes he tripped the first two sets, a.nd at 23 the time of the tripping of the second two reactor coolant 24 pumps and initiation of HPI, which was alleged to have A.
2 nanomri, W.
25 occurred at that particular time, he was feeding the steam
.e.,
.,y
,m,
._s..m,,,
,_.,,-__._..,.__v,_c 7.,_,
..--_.-,_.___,...,mmy,.9
30 1
generators.
He was on the feed station.
And he thinks Mr.
2 Scheimann was the individual that tripped the pumps.
3 A
Okay.
4 Q
In the next interview of Mr. Faust, which was the 5
Keaten Task Force interview, 9/19/79, Faust was describing 6
whether or not there was this countdown that was alluded to 7
earlier.
And he said that he wasn't sure whether it was a 8
countdown, all he remembered was some sort of sequence was 9
discussed so that all the operators were coordinated to turn 10 off the last two pumps after HPI was initiated.
11 And Mr. Faust was not questioned again on this 12 particular point until his deposition for the GPU versus B&W 13 lawsuit.
And at that particular time, he recalled HPI was 14 actuated before the pumps were taken off.
He said he.didn't i
15 do it physically.
It's something that he remembers hearing 16 as being done or going to be done.
He doesn't know if it was 17 or wasn't actually done.
He just remembers that before the 18 pumps were turned off, something about HPI being initiated.
19 Later on he was question about, but was it his 20 recall that HPI was initiated and he said that was his recall, 21 that HPI was initiated at that particular time.
22 And he was questioned then about whether he believes 23 that his earlier statements on this particular subject could 24 4
possibly have been influenced by things he was hearing after Ac w nowwn. w.
25 the accident, and he at that point said it was quite possible.
31 1
He said that he knew there were terms that he used 2
such as voiding in the core that were not terms that were part 3
of his routine everyday operating vocabulary until after the 4
accident.
5 Now, he was not called as a witness during the 6
trial, at least to the point where the trial was settled.
And 7
the next discussion with him was on May 9th, 1984, the same day a
that you were interviewed by OI.
9 During this particular interview, on Pages 13 and 10 14, he thinks that you would have been the one to initiate 11 HPI, because that's where you were during that particular 12 time.
And his function at the time was on the feed gtation, j
13 feeding up the once through steam generators.
He stated that 14 he did not physically shut off the last two reactor coolant 15 pumps, he believes it was Mr. Scheinann.
16 HegoesontostatethatbothyouandMr.Zewewerel 17 present at the time that he had brought it up, meaning the l
i 18 initiation of the HPI, and he is now referring to the PORC i
19 Committee meeting.
He said at this particular point in time, 20 May 1984, he could not recall your reaction, or their reaction, j 21 at the meeting.
Again, it was his recollection that he thought 22 everyone agreed.
l 23 He was questioned on Pages 21 through 23 of the 24 4(
transcript about the meeting where yourself and Mr. Scheimann e noorwei, inc.
25 and Mr. Faust all got together at Bill Zewe's house shortly L
32 1
after the accident.
I believe you testified that it was after 2
'you had -- it would have been about a week or so after the 3
accident, a week and a half, after you had received some data, 4
reactimeter data, when you got.together.
The meeting didn't 5
actually last that long.
It was the first time you had 6
actually seen some of the data put together..
7 He was asked if it was at this point in time that 8
you realized that it may have been the prudent thing to do, 9
to initiate HPI and whether that was discussed amongst your-10 selves, and he said that was not discussed.
II BY MR. RUSSELL:
12 C
Do you recall that meeting?
i 13 A
Uh-huh.
Id Q
Was it your recollection that HPI actuation was 15 or was not discussed at. that meeting?
i 16 A
I don't think it was.
We got to the eight minute I
l 17 point where feedwater came back and most of us, I think all 18 of us, felt it was a much shorter time than eight minutes, I'
that it was only a few seconds.
And we attributed much of f
20 the problems we had to that eight minute time frame.
We 21 didn't go much beyond that.
22 And we thought we had solved the whole puzzle 23 by then.
I guess we didn't.
J 2d BY MR. CAPRA:
an,
,a neswers, Inc.
25 Q
And the last two things, if you turn the page, there l
l
I 33 1
is a discussion on Page 43 through 47 essentially where again 2
he is going by recall where he says that he believes there 3
were three actions going on at once, 'and that's why he 4
remembered some type of countdown, or are we all ready now.
3 Something to that effect.
And the acti'ons that he recalled 6
were himself feeding up the steam generators, you initiating 7
HPI and Mr. Scheimann tripping the pumps and Mr. Zewe giving 8
the direction.
9 Again, that wa s his recall.
And then he was 10 questioned on Pages 46 and 47 again about whether he ever thought there was any dissension on the part of any of the 12 operators with regard to the manual actuation being inserted t
13 in the sequence of events.
And he said he didn't remember U
any dissension but nobody ever focused on it really until the 15 trial, it was never.a particular issue.
16 BY MR. RUSSELL:
I II Q
Let me highlight some of the things we have just II gone through.
First, Mr. Bewe appears to be the first one, I'
in an interview that was recorded, to discuss HPI actuation l
l 20 at the time of securing the reactor coolant pumps.
This is l
21 on his April 30th interview with Long and Ruppert, Pages 19 l
22 and 20.
23 I
That was also affirmed by him then a few days j
j later, April 6th, with the GPU investigation team.
These were all well before the PORC meeting and may have been before l
=.
34' l
the meeting at Mr. Zewe's house.
1 2
Mr. Faust first discusses the HPI actuation on 3
April 21st, 1979 in an NRC interview, where he interjects i
4 that discussion essentially in the middle of the discussion 3
on another subject, he brings it up and adds it in at that 6
point.
7 Other than the testimony that you had --
0 BY-MR. CAPRA:
l 9
0 If you recall, we left off with your statements J
10 before the B&W/GPU litigation.
We went through all the test 11 of the information.
)
12 A
Yes.
13 BY MR. R'USSELL:
14 Q
The only testimony or discussion happened to have 15 been with the April 6th, '79 investigation team, it was 16 talking about starting high pressure injection some time 17 between the pumps were secured and your attempting to restart 18 the 2B pump.
]
19 That would be between 5:41 in the morning and i
20 approximately 6:547 j
21 MR. CAPRA:
I believe that's the ball park.
22 BY MR. RUSSELL:
23 Q
Okay.
Approximately a one hour time frame.
It I
24 4.(
would appear from those very early statements that all three e noww, w.
25 operators were of the opinion that high pressure injection i
a f
1
__---.-_--_-__,--,.__.--._,...-.._m._.
,___,..._.m..__...-__.m.,_.-,_,
.._,--..-._,_.-,...m.._,_,.,_._
r--
l 35 I
actuation did occur and that some of the other statements that 2
were written into records, recollections from PORC meetings, 3
would indicate there is a basis for a conclusion that all 4
three operators insisted this was the, case, which was Mr.
5 Long's notation.
6 Yet later when we get to the deposition and the 7
trial, your testimony is substantially different from that.
8
.' ' this point, I would like Bob to go through a 9
summary of wl at your testimony was and then we will cover 10 some questions on it.
11 A
.Okay.
12 BY MR. CAPRA:
13 O
Now, on P' age 2 of this summary of your testimony 14 this is during the deposition which in attendance were Mr.
15 Fisk, who was deposing you, and Mr. Seltzer, your attorney 16 at the time.
17 And the date was May 4th and May 17th, 1982.
These 18 are extracts from those two days.
Okay.
19 On Page 18 and Page 20 of the deposition, you make 20 some statements to the effect that, one, you did not see 21 any drafts of the LER before it was filed.
The LER that we 22 are talking about is the sequence of events.
That you did 23 not recall having seen any of the drafts of the sequence of 24 events of the accident, which you understood were being pre-Ad at mm,em, inc.
25 pared by GPU for the purpose of filing with the NRC.
And the
36 1
only discussion that you had of the sequence of events was 2
with an I&E interview at the Skyway Motel in Harrisburg.
3 By the way, when we walked through the testimony 4
earlier, the I&E interview where you discuss this with Mr.
5 Hunter, Mr. Yuhas and Mr. Marsh -- Mr. Marsh was not conducted 6
at the Skyway Motel.
It was conducted at one of the trailers y
at the site.
Okay.
So, you may have been referring here to
' ut e
another interview, which I'm not f amiliar with.
Okay.
B 9
it was not included in this package.
10 And you did not recall attending any PORC meetings 11 to discuss draft sequence of events.
12 On Page 955, you said that Frederick and Faust f
13 both -- you said that both yourself and Mr. Faust turned off 14 one set of pumps each, but you didn't remember which set was 15 turned off by whom.
16 On Page 960, you state that you recall some HPI 17 manipulations during the day but you didn't know what times r
18 they were, and you did not associate HPI with the 0541 time 19 frame.
20 On Page 967, you said that you do not recall any 21 meetings that you participated in where this subject of 22 actuating HPI at the time reactor coolant pumps were turned 23 off.
2d Those statements, or some of these statements seem A'
. noorwei anc.
25
- to be in conflict with events that occurred.
Okay.
The fact l
l l
1 l
._.. _. _. _ _ _ _. _ _, _ _ _ _ _ _ -. _ _. -.. ~... _ _ _ _.. _,.. - -.. _ _. _. _... _
37 1
that you did attend PORC meetings, that you had discussed the i
2 sequence of events at the time.
3 BY MR. RUSSELL:
4 Q
Can you give us any information that would help 3
us with this particular deposition?
6 It would certainly appear that when you were being 7
deposed that the statements you were making were not consistent a
with other documents and other statements and some of the 9
things we just walked through in the last hour.
10 A
There is a -- the only thing --
11 Q
What happened during that period of time?
12 A
I don't know what question I was asked when I 13 answered this, did..not Jee_any_ddafts.of_.the.LER before it 14 was filed.
I know that I was working with vanWitbeck on a 15 couple of times a week basis answering questions about the 16 sequence of events.
17 There were times he would call me into his office, 18 they had -- it was not the sequence of events that you have 19 there.
It was their worksheets.
They were trying to piece 1
20 together when things happened. And I would look at those 21 and give my comments and then I would leave.
22 And occasionally he would send me a few pages in 23 the mail to read and I made comments pretty much like those 24 documents we saw Bill and Craig had initialed.
If I had d
a no.mn, inc.
25 anything substantial I was supposed to call him or send him l
---.3-
..--,-,-.,------y
,.,---,-,.e-----
9-
+--.-,, _.,, -
I 38 1
back some comments.
2 I think what this statement means is that I 3
didn't see the LER before it went to the NRC the way we 4
were sending it to the NRC.
3 Q
You mean the final document that had the references 6
to your particular testimony --
7 A
Right.
8 Q
-- supporting that inclusion?
9 A
Right.
Yes, the sequence of events or if I refer 10 to it as the LER, what I'm talking about is when VanWitbeck 11 got started wrapping it all up and started putting it all 12 together, he didn't talk to' me much anymore.
And I didn't 13
_ review the thing before it left.
14 I don't believe -- and I don't remember seeing it.
15 I don't believe that I saw it before -- af ter it was wrapped i
16 up and ready to go.
I saw bits and pieces of it, but that's 17 about it.
18 Q
Do you know what caused the long delay with respect l'
to that particular document being completed?
20 For example, the PORC meetings, the comments, the 21 other documents that we see were in the July 1979 time frame.
22 A
Right.
I remember --
23 Q
The final document was not transmitted to the NRC 24 A.g until February 6th, 1981.
That's twenty months after the e n=mri, eac.
25 last revision and discussions for which we have the annotated
39 1
records, Mr. Zewe's handwriting, Mr. Long's, the PORC Committee 2
meeting.
3 What was going on in that year and a half?
4 A
I don't know.
I remember quite a bit of activity, 5
like you say, in March, April, May and June.
That's the time a
when I'm talking about that VanWi deck typically would be 7
calling me and asking me questions and things like that, 3
July, maybe in the Sunumer.
9 But af ter that, I don't remember -- I mean, it 10 tailed off.
It kind of slowed down and I wasn't involved 11 in that anymore, although I was involved in a lot of other 12 meetings and testimony and stuff.
But that seemed to stop.
r 13 So I don't know why the sequence of events wasn't 14 submitted.
I think that -- I don't know when the EPRI 15 sequence of events came out.
I believe that was in 1980.
16 When I saw that, I thought that was a pretty neat 17 document because it layed everything out chronologically.
I i
18 remember thinking as I read through it that it was an interest-19 ing way to lay things out.
It's pretty similar to the way 20 GPU did it, but I hadn't seen a complete sequence like that 21 before the EPRI document came out.
22 That's why I remember, and I've got a feel to 23 myself, that I didn't see that LER document before it went 24 out.
That's the way I remember it.
An a no rwes, Inc.
25 Number two, it says:
Do not recall having seen any
+
40 I
drafts of the SOE being prepared by GPU.
What I mean there 2
again is the full document.
I wasn't one of the reviewers, 3
or didn't read the whole thing before it went out.
But I 4
did see bits and pieces of it as vanWitbect would ask 5
questions about it.
6 so if that was interpreted in the testimony as 7
never saw any of this information before, that's not really 8
right.
Whenever they asked me a question about it, I saw the 9
page that they were talking about, or the three or four 10 events that they were trying to piece together.
II This Number 3 confuses me a%little bit.
Here we 12 are talking about sequence of events.
If I remember the 13 testimony correctly, this was in reply to a question, you Id know, did you ever discuss the SOE with anybody, sequence of 15 events with anybody.
16 0
If you like, we can actually go to this particula.
17 exhibit and read it in context.
18 A
We could but what I'm saying here is the sequence l'
of events, meaning the sequence of events document.
Here 20 I'm just talking about the sequence of events, not actually 21 any document.
22 But, when did you discuss the sequence of events.
23 Well, one of the times I discussed it was in this first I&E 24 4.i interview which was a taped interview at this motel.
e neww. w.
25 And I guess we should look at it, because I don't i
41 1
really think that I said that that's the only time I ever 2
discussed what happened during the accident.
3 Q
Page 18 through 20-A.
4 MR. GEPHART:
Of what exhibit?
5 BY MR. CAPRA:
6 Q
Before we go to that, this is where I'm talking 7
about your interview on April 23rd, 1979 with IEE before Mr.
8 Hunter, Mr. Yuhas and Mr. Marsh, took place in Trailer 203 9
at the site.
10 I don't think you were referring to this particular II interview.
12 A
No.
a 13 Q
On Page 19 --
Id MR. RUSSELL:
Why don't you just let him read it 15 so h'e can read in context the pages around that and then when 16 you get to the section --
17 THE WITNESS:
Okay.
18 (The witness is looking at a document.)
I' Okay.
Again, I think the distinction is that these 20 questions are asking whether we had meetings where we dis-21 cussed the sequence of events document.
Okay.
Not the 22 trend of events that occurred.
We discussed that many times.
23 And I answered these questions.
The question is 24 quite specific:
Did you ever discuss any written draft of
,u wn nmsac.
25 the sequence of events of the accident in a group which
42 1
contained, in addition to yourself, other control room 2
operators who had been on duty?
-3 Yes, the answer.
4 Was there more than one such discussion?
I said 5
I only remember one at this time.
That was a session led 6
by the NRC I&E group at the Skyway Motel in Harrisburg.
7 Putting that aside -- this is the question -- I'm 8
asking you now whether you had a discussion about a written --
9 I'm asking you whether you had a discussion concerning a written sequence of events in draft form which discussion was 10 11 participated'in by not only yourself but other operators that 12 were on duty the day of the accident?
13 And I say:
No, I don't recall any specific times 14 where a review of that nature took place.
Meaning here is 15 the sequence of events, three or four of us are around it 16 and we are discussing it.
17 But I think this statement here where it says the 18 only discussion of the sequence of events was with the I&E 19 interview at the Skyway Motel in Barrisburg, I don't think i
20 that's an accurate summary of this testimony.
21 BY MR. CAPRA:
22 Q
Was that the only time you could remember --
23 A
Discussing --
{
24 0
-- discussing --
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25 A
- the document.
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43 1
Q Isn't the question a written sequence of events?
I
/
2 A
Yes, that would be the written sequence of events 3
document, right.
4 Obviously we discussed the sequence of events five 3
or -- on five or six other occasions but sometimes I was alone, 6
in the Dr. Long interview, or with the NRC IEE interviews down y
at the trailer where they were all taped.
Those are all
>r a
sequence of events discussions but we didn't have the sequence 0'
9 of events document.
10 We weren't trying to improve upon or add informa-11 tion to the sequence of events.
They were just asking me 12 questions about the sequence of events.
l 13 Q
The PORC Committee meeting in May of 1979, you 14 did sit down with a draft sequence of events with the other l
15 individuals and discuss it and make casunents on it with the 16 other control room operators.
17 A
Well, at that time and now I don't recall attending 18 that meeting and having the documents around and discussing 19 it.
20 Q
You did not recall it during the deposition; is 21 that what you are saying?
22 A
No.
23 MR. GEPHART:
He said he doesn't recall it now 2d either.
d e mesorers, lac.
25 BY MR. CAPRA:
6
j 44 1
Q You don't recall it now?
2 A
The only meeting of this nature that I recall 3
was in the auditorium, it was on TMI.
There were very few 4
people there.
I don't remember it being identified as a 5
PORC meeting or like there were minutes being taken or any-6 thing like that.
It may very well have been with some PORC 7
members but r.s f ar as I knew, it was a, just come on in here 8
and talk with these guys type meeting.
9 That may be the meeting that everybody is talking 10 about.
But again that -- I don't recall that as being a' Il notch-by-notch description of the SOE.
12 I've been to other PORC meetings.
I've been to 13 PORC meetings where you review procedures and discuss their Id safety and all that sort of thing.
And I have not been to 15 any meetings like that to discuss the actions.
I mean, i
16 people that you recognize are sitting around the table, I
17 someone is taking miraltas, and we are dissecting the procedure.
6 18 That's what I call a PORC meeting, okay.
l' Now, all I'm saying is the possibility is that 20 some of these PORC members had a meeting, okay, which I i
i 21 attended and the SOE was one of the topics of discussion, 22 and I just wasn't aware that that was an official PORC 23 meeting.
That may be the case.
24 i
Q That was the principle purpose of that PORC h
J RSIIDriers, irit.
25 meeting May 14th and May 17th, was to discuss the draft
45 1
sequence of events, go through it with Mr. VanWitbeck and*
2 other members of the PORC Committee and yourself.
3 BY MR. RUSSELL:
4 Q
But you are saying based upon the way the meeting 5
was conducted, wherever it was conducted, that you did not 6
understand that this was a formal PORC meeting, that it was 7
different from other meetings that you had observed where J
8 procedures or other documents were reviewed?
9 A
Right.
So when people asked me, have you been to 10 a PORC meeting about this, I said I don't remember being'at II a PORC meeting about that simply because I didn't think they 12 were the same thing.
1' 13 BY MR. CAPRA:
Id Q
These excerpts were taken from your trial testi-15 mony, December 6th and December 7th, 1982.
This was part of 16 your direct testimony where you were being questioned by Mr.
17 Seltzer.
I8 On Page 3493, you did state that you manually I'
initiated HPI only once.
20 However, back in your 9/19/79 intervi'ew with Mr.
21 Keaten you said that you did remember initiating HPI at 22 least twice.
You said:
One time we did it and we were told 23 to stop.
Another time an order came down to do it.
24 Now, when you were asked about this in your OI d
e noorwri. ene.
25 interview later, you said that when you went back and looked m. w, w.emme *** * - e
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46 1
at this you were confused because it appeared that the second 2
statement an order came down to do it, you weren't sure 3
whether the "do it" referred to securing or starting or 4
initiating HPI.
5 Does that ring a bell?
6 A
No, it doesn't.
7 BY MR. RUSSELL:
8 Q
Would you like to look at Page 60 of your inter-9 view and see the context to see if you recall that discussion?
10 A
Is that in here?
11 BY MR. CAPRA:.
12 Q
Yeah, they are all in chronological order, okay, i
13 s'o if you look at -- there is a tab there that shows where 14 your testimony begins in your notebook there.
4 15 A
Which page?
16 Q
Let me show you.
17 A
Right. I've got it.
18 MR. GEPHART:
That's the wrong page.
19 MR. CAPRA:
Okay.
Let me show you how this is 20 organized.
There is a tab here for each of you. All the 21 documents we are talking about are laid out chronologically.
22 I show the September interview right here, 23 September 19th, 1979.
Page 60.
24
(
(The witness is looking at the document.)
A.
e noso,ws, inc.
25 THE WITNESS:
There is another one on 3493 where I
--. ~-.-.
l 47 i
I said I did it once, right?
2 BY MR. CAPRA:
3 Q
Right.
4 A
That's in here?
5 Q
Yes.
Again, chronologically.
We are now into 6
the trial testimony.
okay, 3493.
i 7
A Okay.
8 (The witness is looking at the document.)
9 BY MR. RUSSELL:
10 Q
You have seen the two statements.
The two 11 statements are apparently in conflict with each other.
12 What I would like you to do is to try to attempt t
13. to explain what caused the conflict, or if in your mind Id there was something that occurred in between which would 15
,cause you to change your testimony?
16 A
This question is different from this question.
17 Q
Would you like to expand upon -- you are looking 18 at Page 60 of the --
II A
Page 60 here.
It says I -- well, it's an answer.
t 20 Mr. Keaten says:
You don't specifically remember hearing an 21 instruction that, all right, we are just going to leave two 22 of the pumps running full blast until further notice?
23 l
Now, I can remember trying to initiate high pres-l 24 6
sure injection manually at least twice.
Okay.
aa e neww,, w.
25 Now, this other question is a little bit different,
48 1
because it says:
Was there any point during the time that 2
you were still on duty -- that's between eleven o' clock at 3
night and four o' clock the next day, right.
But it says:
4 While you were still on duty the morning of the accident 5
where you manually initiated full high pressure injection?
6 I said:
Yes.
7 How many times did you initiate a full manual 8
actuation of the high pressure injection?
9 To me, that means how many times did you push the 10 red button.
Once.
Okay.
11 Now, back here where we are talking about initiat-12 ing high pressure injection, he wasn't that specific.
And 13 I'm talking about times after the initial accident where I I
Id manually started high pressure injection without pushing 15 the red buttons.
That was right about ten seconds into the 16 accident.
Right.
17 Disregarding that one, there were at least two 18 more.
One where I pushed the red buttons and one later on 19 in the afternoon after the -- we were like one or two o' clock l
20 in the afternoon I guess, there was another one in there.
21 Right.
22 O
so you weren't differentiating between starting 23 the makeup pumps and opening the 16 valves from hitting the 24 4{
red buttons to start high pressure injection?
e n.s==ri, inc.
25 A
In these two questions, I am, yeah, because when t
I l
49 1
he says a full manual actuation of high pressure injection 2
that, to me, means pushing the manual buttons for the entire 3
system and --
4 Q
Full, to you, means then in addition to high 5
Pressure injection, also low pressure injection, the manual 6
initiation of safety injection?
7 A
That's right.
8 Q
As compared to full high pressure injection which 9
could be a thousand gallons per minute from the two makeup 10 pumps going into the four -- through the four sixteen valves 11 into the four cold legs?
12 A
Right.
I'm pretty clear on this, one time manual 13 actuation, full manual actuation, because 'as far as I know 14 I'm the only operator that ever did that at TMI.
I remember 15 doing that once.
Okay.
16 0
You are now referring to your testimony at the 17 trial?
18 A
On Page 3493, yeah.
The other manipulations where 19 I say at least twice, I'm trying to differentiate there be-20 cause there was -- right near the accident there was one, 21 that was high pressure injection even though the system was, 22 you know, I did it by opening the valves and turning on the 23 pumps.
It's the same thing.
24 And later on at the time of the site emergency was J
am.
25 another high pressure injection, and that's the one where I
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50 1
pushed the red buttons.
And later on there was an automatic 2
initiation and another manual actuation where we increased 3
flow, either just before or just after that pressure spike.
4 And I think that was in with the depressurization 5
that we were trying to go through.to try and get core flood f
6 on.
We were doing all kinds of manipulations with high 7
pressure injection.
8 Those -- that at least twice terminology can be 9
differentiated I think from this one full manual actuation 10 by my interpretation of what full manual means.
II MR. RUSSELL: 'All right.
The next section in the 12 trial testimony, Bob.
i 13 BY MR. CAPRA:
Id O
I think you have cleared up the next couple of 15 points here with your explanation of that one.
16 Let's go to Page 3513 and 3514 of your direct 17 i
trial testimony.
It appears that you now recall. attending 18 PORC meetings with Mr. Zewe and Mr. Faust and that at that particular point Faust stated that RPI was initiated at 0541 20 when the pumps were tripped.
i 21 And you stated that you did not agree or disagree 22 with Mr. Faust at the. time beca'use you could not recall.
Also 23 no data was available at the meeting in which to confirm or i
24 refute what Mr. Faust said at the meeting, aa' e noorm, inc.
25 Is that a correct recollection of your testimony?
e
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51 1
It's right here if you want to look at it.
2 A
Again, the meeting I am referring to as a PORC 3
meeting is the one --
4 BY MR. RUSSELL:
5 Q
You mean in the auditorium?
6 A
I began to label it as a PORC meeting because that's 7
the one I thought everyone was talking about.
8 Q
You are now talking about the meeting in the 9
auditorium on the site?
10 A
Yeah, this was in the auditorium.
II BY MR. CAPRA:
12 Q
At the time of your deposition you weren't calling 13 it a PORC meeting, but at the time of your trial testimony Id you are now calling it a PORC meeting; is that correct?
15 A
I think so.
16 Q
Okay.
17 A
Somewhere along the line I began labeling that as 18 the PORC meeting, and I remembered those discussions where I9 Zewe and Faust were insisting on this and they kept asking 20 me if I agreed or disagreed.
And I said I don't think I did 21 either one.
22 And that's what this says.
23 BY MR. RUSSELL:
24 ad g-Now, before that meeting your testimony back in a nenorms, Inc.
25 April of 1979 on the 6th of April with VanWitbeck where you l
l
52 1
discussed a manual initiation of high pressure injection, 2
some time between securing the pumps and attempting to start 3
the 2B pump, that would indicate'that you believed that that 4
event had occurred.
5 That does not appear to be consistent with the 6
statement in the trial that you neither agreed nor disagreed, 7
unless the trial is specifically only referring to that PORC g
meeting.
9 A
Well, again in this statement where I'm talking 10 about, it may have been when the pumps were off we did a' 11 manual high pressure injection.
That's where it seems that 12 I believe we did a high pressure injection.
I 13 And since there was so much confusion on it back 14 in the May thing I kept reading it over and all I can see 15 is that I had compressed the time between when we turned the 16 pumps off and when we did the site emergency.
Because it was 17 only a few minutes after the other guys -- you know, this was 18 after the other guys arrived.
The other guys I'm talking i
l 19 about are the Gary Millers and the engineers and people 20 that were making a decision about the site emergency.
21 Now I say that's when we did -- later on, it may 22 have been when the pumps were off we did a manual high 23 pressure injection.
This was after the other guys arrived.
24
(
We didn't turn the pumps off and do a high pres-A.
.i nosomei, Inc.
25 sure injection.
In my mind, I guess we did.
But those two
53 1
events were very close together.
But actually there is 2
quite a bit of time between them.
3 BY MR. CAPRA:
4 Q
Okay.
But --
5 A
See what I'm trying to say?
6 Q
Yes.
7 A
I have labeled the high pressure injection, it's a
true.
In this sentence I say the high pressure injection, 9
the pumps going off, it happened pretty close together.
10 But I throw in a third thing that says this was 11 after the other guys arrived.
And now I'm talking about the 12 honchos arriving just before the site emergency was declared.
13 And those --
14 Q
Do you know now that that is what you were talking 15 about?
I mean, people began to arrive quite early in the 16 event.
17 A
That's right.
That's true.
13 Q
For example, Ken Brian was there very early because 19 he was over in Unit 1.
Brian Mahler arrived quite early 20 I believe.
George Kunder was called at home; he arrived 21 quite early.
22 A
Right.
23
_Q The 'other thing, back in this previous testimony 24 you were specifically narrowing it down to a period before
(
4.
m m.pmm inc.
25 you started the second reactor coolant pump.
Okay.. The 2B
54 1
pump.
2 A
Before we started?
3 Q
Right.
4 A
Yes.
5 BY MR. RUSSELL:
6 Q
Which was prior to 6:54 in the morning and would 7
have been some time prior to getting the data recorder back, e
approximately that time frame, one hour.
Approximately a 9
one hour time frame between 5:41 and 6:54.
10 BY MR. CAPRA:
11 Q
Again, don't lose sight of what we are trying to
'12 do here, okay.
We are not trying to get you now to agree t
13 that there was or was not an HPI actuation,at that --
14 A
Right.
I understand.
15 Q
-- particular time.
Okay.
We are trying to 16 determine whether at that time you really did believe that-17 there was an actuation based on the statements of yourself,.
18 other individuals, the fact that you did not disagree with it, l
l 19 yet you took exactly the opposite stand at the trial and duringi 20 your deposition,'but particularly at the trial that it did
(
21 not occur, not only didn't it occur but that you never said 22 it did occur.
23 A
I know why I took such a firm stand in the trial, l
24 because it's the first time I ever examined the data.
Prior i
an e n
,ws. inc.
25
'to that this confusion I think is, either I had heard Bill and i
q 55 1
Craig talking about the initiation and assumed that it was i
2 in there.
I don't know.
I don't know why there is so much 3
confusion about the time in that particular testimony, be-4 cause as far as I know, while I haven't reviewed my other 5
discussions about the sequence of events, I don't think I 6
mentioned it any other time.
7 I don't know why --
8 BY MR. RUSSELL:
9 Q
That is the only time that we have been able to 10 find in looking through this record where you mentioned a 11 high pressure injection actuation.
12 A
I may have talked to Bill or Craig about it.and
- 13 just stuck it in there.
I don't know.
14 BY MR. CAPRA:
15 Q
The other thing, Page 3513 and 3514, where you now recall attending the PORC meeting-because you now 16 17 label it a PORC meeting, where you said you did not agree or I
18 disagree with Mr. Faust at the time because there was -- one i
19 of the things was, you did not recall HPI being actuated at i
20 that time so it was better to remain silent than challenge 21 something when you had no recollection of whether it did or 22 did not occur, but you also said there was no. data available i
(
23 at the meeting to confirm or refute it.
- Okay, i
24 d
Whereas, Mr. Zewe in his OI interview, when he i
e n
. inc.
l 25
-recalled the PORC meeting, the OI interview now and I'm talking I
1
.=
56 1
about May of '84, when he was questioned about why he had 2
insisted that it be put in the sequence of events he said 3
that Faust had advised him at the PORC meeting that he had 4
actuated HPI at the time when those last two reactor coolant 5
pumps were shut down.
6 And then he, being Mr. Zewe, said that they had 7
charts at the meeting which indicated that it couldn't have 8
been left on, couldn't have happened.
But Zewe insisted that 9
it be put in the sequence of events because he wanted that 10 to reflect what operators recalled or r==amhered.
dkay.
11 So, apparently at the meeting it was somewhat of 12 an issue, granted not as much of an issue as it has become 1
13 since.
But there was some data apparently, according to Id Mr. Zewe's recollection, that led -- at least, Mr. VanWitbeck 15 and whoever else was there, to at least discuss the fact 16 that it did not appear from the data available at the meeting 17 that that was the case.
18 Mr. Zewe remembered charts, he said.
Okay.
As l'
you said,. one of the reasons you did not agree or disagree 20 at the meeting was that there was no such data there.
Okay.
21 Let's go on to your cross-examination during the 22 trial.
23 MR. GEPHART:
Getting tired?
.(
24 THE WITNESS:
No more tired than I usually am.
4.
4 nomen. anc.
25 MR. GEPHART:
Can we take a break?
i
)
57
'g.
I MR. CAPRA:
Sure.
2 MR. GEPHART:
How much longer are you going to 3
goy 4
MR. RUSSELL:
We've only got a couple of other 5
areas left.
But I think it's important to get on the record 6
his statements concerning what appear to be conflicts in 7
testimony.
And I will need to review all of this and make 8
a recommendation.
9 MR. GEPHART:
What do you think?
10 MR. CAPRA:
We don't want to have to do it i
[
11 again.
12 MR. GEPHART:
Well, it's getting on 7 o' clock, l
13 MR. RUSSELL:
I would think we should be able to Id finish in another fifteen minutes to a half an hour.
15 MR. GEPHART:
Let's not take a break.
Let's I6 go.
Go ahead.
l 17 BY MR. CAPRA:
18 Q
I want to go through your cross-examination.
This l'
cross-examination at the trial took place on December 9th, 20 1982.
At Page 3879 of the transcript, they showed you -- you l
l 21 will see as we go through here, they show you many of the 22 documents that we have already discussed this morning.
l 23 They discuss with you Mr. Zewe's deposition at l
24 l
A(
Page 820 where Mr. Zewe said that all three operators agreed.
i e mesorem. anc.
25 At your trial testimony, you stated that you did not agree or
.r
-, _, - -. _. -.. -. - ~ _,.. _ _. _.
58 1
disagree and that they probably construed your silence as 2
agreement.
3 Later on, at Page 3881 through Page 3885 they asked 4
you to respond to Mr. Zewe's testimony regarding the count-5 down.
You recall that we looked at an exhibit where Mr.
6 Zewe presented some testimony during his interview on May 25th, 7
1979 where he described the countdown sequence.
3 You stated that you did not recall any such discus-n 9
sion.
Yoti did remember manual actuation but you did not 10 recall the time frame.
11 Again they brought out Mr. Zewe's testimony regard-12 ing the PORC Committee meeting.
Now this is his testimony at 13 the trial we are referring to. *I,t becomes difficult when you j
14 look at some of these documents because you have got quotes 15 within quotes within quotes.
16 But at the-trial they showed you his testimony 17 where again it was his position that all three of the indivi-18 duals agreed and again you stated that the agreement must 19 have been assumed on Mr. Zewe's part because you didn't 20 disagree.
And you said that -- and At that point you said 21 that you never made an affirmative statement that it did in 22 fact happen.
23 Later on in the trial at Pages 3338 through 3390, 2d you were shown a copy of Mr. Long's comments on the sequence As e mesorwei, Inc.
25 of events where it states that Zewe, Faust, Frederick insist l
l
. - - - -..~.-
59 1
this is the case.
Again, you reiterate that you had never 2
insisted on this.
This is the same document we showed you 3
earlier today.
4 This is another quote within quotes here, but on 5
Pages 3890 and 3891 of the transcript you were shown Mr.
6 Zewe's testimony.
Mr. Zewe was shown Mr. Long's comments, 7
and Mr. Eewe's response to Mr. Long's comments were, yes, 8
that all three had insisted that HPI had been put on at 5:40 9
when the reactor coolant pumps were secured.
10 Your response again to that was that you denied 11 that you ever said that.
12 Then, you were questioned by Mr. Fisk I believe 13 on Page'3893 and Page 3894 that even though you recalled only 14 one manual actuation of EPI, the sequence of events filed 15 with'the NRC showed two, the 0541 and the 0720.
16 And'again you stated that even though you knew 17 these two existed and your testimony at the trial was that 18 only one actuation occurred, the sequence of events went 19 forward showing two.
I 20 I believe you may have cleared that up from our 21 discussions that we had earlier now, that you were referring 22 to as one manual actuation was hitting the red buttons.
23 A
And so that point here where it says the SOE 24 A.(
filed with the NRC showed two, I never told anyone that should e neoerwes inc.
25 be taken out.
I don't recall seeing the entire document where
i o
60 1
I could have seen that they were still included in that, 2
if I had any strong feeling about it I was given the opportunity 3
to take it out.
Because I draw the -- this seems to imply 4
that even though I had strong feelings about it, I didn't do 5
anything about it.
I don't think that was the case.
6 Q
And your reasca for.that is, one, you didn't see 7
the entire document put together and even had you seen the 8
document you didn't have strong feelings about it one way or 9
the other at that time; is that what you are saying?
10 A
Right.
So the question says:
Didn't you ever 11 tell anyone to take that out?
12 And it seems rather irresponsible that I didn't i
13 do that.
But I - '
14 Q
That's the way -- that was the way the question 15 was phrased.
16 A
Okay.
I don't agree with that interpretation of 17 it.but I suppose it's there.
I 18 MR. RUSSELL:
I think we have covered most of the I
i 19 information in that.
20 MR. CAPRA:
I would like to cover this.
21 MR. RUSSELL:
Okay.
Go ahead.
22 BY MR. CAPRA:
23 Q
Almost everything we have talked about today is 24 covered in your OI interview with Mr. Letts and Mr. Norton
.- Ar{
w nes core, inc.
25 on May 9th, 1984.
So I don't think we need to go through
.
i 61
'l l
1 that.
The only thing I would like to ask you about is if 2
you look at the discussion beginning on Page 10 where we 3
were referring back to your interview with Mr. VanWitbeck, 4
4/6/79, you are questioned about the meaning of the statement 5
there that said:
It was about that time we talked ourselves 6
into going 'into high pressure injection.
We felt that we 7
were generating steam in the loops.
I believe it was right 8
in there that we did manually initiate high pressure injection.
9 In discussing what that statement meant, on Page 15 10 you said that you were trying to establish natural circulation.
II You said that natural circulation -- you are trying to explain 12 a time frame 'that you are tailk'ing about.
There was an extended i
perf.od o'f time between the time you tripped the pumps and 13 Id you actually initiated high pressure injection *.
15 You are saying now it was around -- you are talking 16 about the 7:20 actuation, and one of the things you say, I I7 must have been referring to a time when that was more.than two 18 hours2.083333e-4 days <br />0.005 hours <br />2.97619e-5 weeks <br />6.849e-6 months <br /> into the accident, because it says in there that other i
people had arrived and it was later in the event.
i 20 The other thing you say there that seemed peculiar f
21 to me, you said that natural circulation takes twenty to 22 forty minutes to an hour to establish.
I 23 Is that your understanding today?
24 Am{.
A Twenty to forty minutes, yeah.
Not an hour I e menerws.Inc.
25 don't think.
That's too long.
The guideline I think is I
i s
62 1
twenty minutes.
It wasn't then.
It is now.
2 BY MR. RUSSELL:
3 Q
et me understand the difference between time to 4
establish natural circulation and when one would expect 5
natural circulation to be in effect following the tripped 6
pumps.
7 Once pumps are tripped, the pumps coast down.
If 8
you have thermal differences you will get natural circula-9 tion and it almost coincides with tripping the pumps.
10 It may take time to verify that, and there is a 11 difference between the time it takes to establish natural 12 circulation, how much time is assumed in a safety analysis i
13
.cn for other reasons, where you have until you need to have Id natural circulation in effect.
15 A
How long it takes to verify that, and not coast 16 down or some other transient?
17 Q
How long --
18 A
That's twenty to forty minutes.
Now, what you l'
said about natural circulation being available immediately 20 after the pump trip is probably true but not verifiable, not 21 being able to establish the three or four criteria that we 22 have for natural circulation.
j 23 And this is all post-accident.
24 A.t Q
This is your understanding now, in the situation e now=m. w.
1 25 where you have sub-cooling where you are attempting to establish
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64 1
of the operators, they participate in the meetings, and they I
write down their recollections of those events as they occur.
2 3
Bill Long writes down, Faust, Frederick, Zewe insist this is 4
the case.
Others have similar' perceptions at the time, that 5
the operators felt high pressure injection actuation occurred.
6 This is what we are referring to when we say there 7
is circumstantial evidence in testimony of others which would 8
appear to support i conclusion that in the days shortly after 9
the accident and during the development of the sequence of 10 events you were in agreement with incorporation of HPI actua-11 tion.
Some time later, in preparation for the trial or during 12 the -- actually after the start of the trial and the prepara-13 tion of witnesses, the issue of the mystery man becomes a 14 significant issue.
And your testimony changes to one of, 15 I was silent on that issue.
I didn't argue for it one way 16 or the other.
17 And now you appear as an expert witness supporting 18 a conclusion that the HPI actuation did not occur.
19 A
Uh-huh.
20 Q
That appears to not only be a stark difference p
21 from what your testimony was but appears to be motivated by 22 a desire to refute the arguments of counsel for B&W during 23 the trial.
j Is there anything that you have to add at this 24 An-e noonm,inc.
25 point in time based upon what we have gone through today that l
4 63 1
natural circulation?
~
2 A
Right.
And you have to verify it, the steam 3
generator, Delta-T and all that kind of stuff.
4 Q
It's really an apple and orange type argument, 5
because in the circumstances you had at the time you were 6
concerned about voiding, you did not have a situation where 7
you had normal flow with your pumps, you were having pump 8
vibration, lower amperage on the pumps.
9 A
Yes.
10 Q
Other problems.
And really the situation does' not 11 appear to me to be relevant to the circumstances we are talk-12 ing about in the time frame.
13 So it appeared to be a fact that you had learned 14 after the event that you were superimposing back on the 15 event.
16 A
I think so.
17 0
Is that the case?
18 A
Yes. These numbers and these concepts about 19 natural circulation are all things that we learned after the 20 accident.
21 Q
Let me go back to the difficulty, we have a 22 situation where we have meetings that involve three operators, 23 two of those operators argue for inclusion of HPI actuation 24 in the sequence of events, Bill Zewe and Craig Faust.
Other
=
a n oorwn. ene.
25 people are there that are present.
They observe the interaction
=
t 65 I
would help to rationalize or resolve that conflict?
2 A
I think the two situations that you have developed, 3
that you have drawn from the record, are -- there is a little 4
bit o'f an element missing.
5 When Bill and Craig insist that the mention of 6
the HPI be inserted.in the record, the SOE, it was my 7
interpretation -- and I think Bill stated outright -- that 8
we've got to put this down in the record or else it will be 9
forgotten, it won 't show up anywhere.
Here is a valid operator 10 memory of something, even if it's misplaced, it's not at'0541, II maybe it's at 0620 or something, it ought to be put in and 12 discussed and. thought about and checked out rather than just 13 say, well, we will discard it and not count.
Id His insistence, I felt and I feel today, was based I3 on making the record complete and then checking the data later 16 and we will resolve this conflict later.
But don't just dis-I7 regard this Craig-Faust insistence and his insistence that I8 this HPI did occur.
I remained silent thinking that -- not that I 20 agreed with the HPI or disagreed with the HPI initiation, 21 but I agreed that it should be written down somewhere and 22 analyzed and figured out in the weeks and months to come.
23 So I think we can draw the conclusion that I agreed that it I,
j should be inserted in the SOE for that purpose, so that it 25 would be preserved and analyzed, just to figure out if it
66 1
actually did happen.
2 I mean, I felt there was nothing to be lost by 3
looking at it closer.
So I didn't disagree that it should d
4 be put in the record.
That's how I think that came down.
3 During the trial everyone started hearing about 6
the mystery man, and it became a rather large point of e
7 contention that if this HPI actuation actually did occur then 8
this pyramided into some kind of big event and changed the 9
whole outlook on the accident and makes it look intentional 10 and all that sort of thing.
And I was asked by the counsel 11 whether or not I thought HPI occurred at that time, and I 12 said, no, I don't think it did.
I don't remember it happen-13 ing.
14 And he asked me if I would examine the data, or 15 if I had ever examined the data I was having to support my 16 memory from, and I said, no, I never looked at it.
So they 17 gave me the stuff to look at and I came to the conclusion 18 that HPI didn't occur.
- l 19 And they thought it was significant that I now 20 was pretty firm on the fact that I didn't believe it occurred, 21 I not only didn't remember it but here I could look at the 22 data and prove to myself that it (11dn't happen.
23 They said they would request the Judge that I be
(
24 allowed to say that at the trial, and asked -- he asked me 4.,..* no.,ws.
25 if I would say that at the trial, and I said sure.
l h
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67 1
So then they laid this stuff out at the trial and 2
asked me all the same questions again, and the final question 3
I think was, did it occur, and I said no.
And that was the A
conclusion based on, one, I didn't remember it occurring; 5
and, two, I have looked at all these pieces of paper and it t
6 proves to me that it didn't happen.
7 And that, of course, is regarded as expert testimony 8
because it was -- I don't know, some kind of rule they made 9
up.
10 Then, I didn't know this was going to happen.' Fisk-11 gets up and starts cross-examining me on it, or maybe it was 12 the other order.
And'as a matter of fact, I think he did go i
13 first., He showed me some data and said, this is where HPI 14 occurred, and I said, no, it couldn't happen there because 15 the level should not decrease when you have HPI going on.
16 And so he kept showing me the same curves saying 17 this is where it happened, and I said I can't agree with that.
18 And he pushed me and pushed me to say either change my mind 19 or prove it further. And I tried to explain it to him, and 20 I went through a lengthy explanation to the Judge and how 21 this diagram shows if the pump is moving water it can't be 22 changing makeup tank-level.
23 The only thing I had -- that was what I based my 24 Ac$
conclusion on, whether it was right or wrong.
I guess three ei neomsen, sac.
25 or four other Committees decided whether that was right or i
68 I
wrong.
But at the time, with the data I had, I firmly believe 2
that there could not have been an HPI at that -- within that 3
five or ten minute frame.
4 And so I think I came across rather hard line, one, 5
because I was getting rather badgered by Mr. Fisk and I just 6
felt that I had to, you know, insist that I change any of 7
the answer that I just made.
In fact, I really did believe 8
that there wasn't any HPI based on that one set of data and 9
charts that they showed me.
10 So, although it appears that I firmly believeci at II one point in time that there is no reason to speak up and 12 no disagreement that'there was an HPI and then later on saying.
13' that there was not an HPI, I don't think they are linked Id because they are two different circumstances.
One, where I 15 was specifically asked to analyze it and in the other case I 16 was just listening to a conversation and saw no reason to 17 disagree with it and destroy the record as-sowe wanted to 18 construct it.
I think that's a complete picture.
20 Q
Was there ever an occasion where you got together 21 with Mr. Zewe and Mr. Faust after the accident, a few days 22 to weeks after the accident, recognizing what had been 1
23 reconstructed from the standpoint of voiding in the core and 24 j
core damage, recognizing that you were losing inventory and 25 should have been initiating high pressure injection actuation i
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s 69 1
in order to prevent core damage and didn't?
2 As a result of feeling some responsibility for 3
the event developed amongst the three of you a scenario that 4
HPI was actuated at the time core cooling was stopped, when 5
the reactor coolant pumps were turned off?
6 A
No.
We never met with that intent.
What you 7
are saying is that we analyzed the data and found out we a
8 made a mistake and then get together and make a story and 9
say we really did make a mistake?
10 No, no.
We never did that.
11 Q
There was no collusion amongst the operators then 12 to fabricate a story which would make it look as if they 13 understood more about what was happening?
14 A
No.
In fact, one of the things that Mr. Zewe was, l
15 at that time building some resentment and kind of anger about, 16 that we were not allowed to very often be interviewed as a 17 group or be questioned as a group.
This PORC meeting was an r
l 18 exception.
19 Usually we were -- especially when it was an NRC 20 interview, they were running almost daily down there in the 21 trailers on the south and of the Island.
We had to go 22 individually.
And after about a month of that, Zewe began 23 to feel that, you know, they had the information they needed 24 and our memories were starting to fail and we were probably a
e n
,wn. Inc.
25 starting to contradict each other.
And there was no way to i
l
A 70 1
take advantage of supporting each other in a group panel like 2
the PORC did.
We never were able to discuss our testimony 3
or how the sequence of events was appearing to people who 4
were putting the big picture together.
5 And that caused him some great amount of concern.
6 And he voiced that several times, that at some point in time 7
after we have gotten our initial impressions of the accident 8
down as individuals we ought to be put together as the 1
9 operating group as we were, as a crew, and try to piece to-10 gether how this thing came'down.
11 The first time we actually did that I think with any success was at the Essex derporation mockup.
I don't 12 13 know if you know about that.
Waere we tried to construct 14 the sequence of events using a raodel of the control room.
15 And I think some new information came out of that that went 4
16 into the EPRI document.
That was a good exercise.
17 But that's the kind of thing that Bill wanted us 18 to do, get together as a group and do that.
I think that is 19 in contradiction to the assumption that we got together and l
20 planned this testimony, because we didn't have that opportunity /
21 We didn't do it.
22 BY MR. CAPRA:
23 Q
You testified to I believe it was OI when you 24 were initially interviewed on this subject back in May of m{
v noon.cs. inc.
25 last year that the only time you really did recall ever getting l
O' I
71 a
1 together outside without anybody else around, other than the 2
four operators, including Mr. Scheimann, without other people 3
around interviewing you, whatever, was when you got together 4
at Mr. Zewe's house.
5 And other than that, if you were interviewed as 6
a group such as the Keaten interview or whatever, there was 7
always somebody else there.
And by that time you had been 8
interviewed enough on the accident, that if you ever did get 9
together it wasn't to discuss the accident.
10 A
We didn't get together, socially or anything like 11 that.
12 Q
I think you also brought out' that at this period 13 of time everybody started switching jobs and there 'esn't w
14 the occasion.
You didn't operate as a shift together anymore.
15 A
Yes.
Fairly quickly after the accident.
I was 16 I
scheduled to be transferred to training on April 1st after 17
- my selection as an instructor in December.
That was post-18 poned because of the accident, but some time in April I did I
19 go to training.
20 Soon after that, Fred Scheimann went to being one 21 of the senior people.
They selected him for rad waste.
22 Bill stayed on the shift for awhile, so'did Craig.
23 But I think Bill soon shifted to Unit 1 almost full time.
24 Ar.{s.
They broke us up within a month or two.
e neswwes. inc.
25 BY MR. RUSSELL:
I
72 Q
Do you have anything else you would like to add i
t-.'
arning the HPI actuation scenario?
ire tne A
No.
I t
I RD R.
FREDERICK MR. RUSSELL:
Bob, is there anything you would like to add?
MR. CAPRA:
No.
iginal MR. RUSSELL:
The time is 7:29 and we will complete
-the interview.
Thank you.
(Whereupon, the interview is concluded at 7:29 p m
- Typed Wednesday, January 30, 1985.)
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- - Signature' 1
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