ML20136B201
| ML20136B201 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 08/09/1979 |
| From: | Rockwell W, Robert Williams METROPOLITAN EDISON CO., PRESIDENT'S COMMISSION ON THE ACCIDENT AT THREE MILE |
| To: | |
| References | |
| TASK-TF, TASK-TMR NUDOCS 7908280836 | |
| Download: ML20136B201 (97) | |
Text
1
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3 PRESIDDC'S COMMISSION ON THE ACCIDENT AT ',*BE"E fCCLE ISLAND 4
5
~
6 7
Deposition of Metropolitan Edison Cbmpany by 8
n0NALD L. WILLIAMS, held at the Three Mile Island Nuclear Generating Station, IIarrisburg, Pennsylvania on the 9th of August, 1979, con:noncing at 1:20 o' clock p.m., before
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e,c 9
Ray E. Sveigart, Registered Professional Reporter and Notary
' ~J 10 Public in and for the State of Pennsylvania.
11
--oOo-12 APPEARANCES:
13 I )
MATIAS F. TRAVIESO-DIAE, ESQUIRE 14 Shaw, Pittman, Potts & Trowbridge 1800 !! Street, N.W.
15 washington, D. C. 20035 For - Metropolitan Edison Conpany 16 WINTHROP A. ROCKWELL, ESOUIRE 17 For - President's Commission 18 19
]
20 21 22 Pages 1 to 98 23 f
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RONALD L. WILLIAMS _, having been first duly sworn l
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2 by Winthrop A. Rockwell, Esquire, was examined and testified p-3 as follows:
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5 DIRECT EXAMINATION _
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6 sy MR. E rwzLL:
7 0
would you state your full namo, please?
8 A
. My name is Ronald L. Williams.
9 0*
Your current employiar?
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10 A
GPU Service Corporation.
11 Q
Your current position with the GPU Service 12 Corporation?
13 A'
A senior consultant in the Generation Division.
14 Q
And your current business address and telephone 15 number?
16 A
260 Cherry Hill Road, Parsippany, New Jerley, 17 07054; Area Code 212-263-4900, Extension 300.
18 0
As a senior consultant in the Generation Division
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u 19 for GPU Service. Corporation, what are your responsibilities,
'4 20 Mr. Williams?
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A I am generally assisting Bob Arnold.
I report 21 directly to Bob, Vice President of the Generation Division.
22 And fundamentally, I assist him in technical matters at 23
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his 211scretion and as he needs support. - '
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And in addition, I have been involved in other
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on-going activities not related to Three Mile Island, however,
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2 for the GPU Sarvice Corporation.
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3 Q-Would ygu trace for 'ne briefly your employment -
4 history with GPU7 When did you first join GPU?
5 A
April'Ist, 1968.
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O And what position did you assume at that ti3ne?.
6 7
A I started with the company as a technical 8
specialist.
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Okay."In what area?
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Primarily at that time I was hired into what wo 11 l call the Nuclear Power Activities Group.
We were concerned
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12 with the design of Three Mile Island, the initial operation ~
13 of Oyster Creek and eventually got into starting to develop j
14 the design for the Forked River Nuclear Station.
15 4 Q How long did you remain a technical specialist,,?.
I was in that position for about a year and h"N" 16 A
17 half.
18 0
so, that would be until late 19697 e.
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19 A
That is correct.'
20 0
And then what position did you take?
A At that titne I became project sannager for design.
21 O
For a particular project? c:j{gWKNA sp$p f.;tw+.
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Primarily related to Three Mile Island Unit No. 2.
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Q And that would have been late '69 to when?
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Until'1971.
I don't remember the sonths.very well.-
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But in '71 I became manager of mechanical engineering.
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And how did you -
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That was in 1970 I became manager
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until 1971, at which time I became manager of engineering.
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Q Okay.
And how long did you remain manager of 7
engineering?
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Until October, 1978, at which time I became D
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Okay.
Did you move directly from project
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Yes, I did.
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riow, as a technical specialist in the Nuclear j
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Power Activities Group, what specifically were your duties?
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I was principally involved in the design of 15 the NSSS system for Three Mile Island 2 and also some activities' 16 associated with the balance of plant for that unit as well.
37 Q
Now ---
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It was pretty much a broad across-the-board 19 technical review of the plant design. w e",
20 Q
During this period of the review of the design g
of the NSSS system, had you settled on Babcock a Wilcox from 22
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the beginning as the WSSS supplier or were you involved in a 23 l
revisiw of Bt.H as compared to other suppliers? S
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' 'A That' selection had been made back in 1967.-
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l That was before I joined the company.
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0 Okay.
Now, what kind of involvement did you have 3
in the design of,the NSSS system?
What kinds of questions
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5 A
It was a review function more than anything else.
6 In other words, BW would submit us information about their 7
design, and then we would review it and comment, generally 8
looking at any way we could improve either the equipment or 9
the plant design and to inject some of the utility viewpointo
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'into the design as they woul6 affect operation or maintenance l
11 joraccessibilityoftheplant.
12 Q
You say in regard to operation, maintenance and 13 accessibility?
l 14 A
That is correct.
A O Do you rersember any of the specific issues?
You 15 16 defined, now, areas of concern.
i 17 A
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18 0
within those areas of concern, can you recall 19 specifie questions that you, as a technical specialist, became 20 involved with during that period from the spring of 1968 until latter 19697 21 A.
Just to give you a scattering of things, we got 22 involved, for example, in canless fuel.
The original fuel 23 design had a can around the fuel elements themselves, and 24 (o,
So, we did get
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Was that anopen issue at that t'
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. No.
The size had been selected.
We reviewed the
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Now, in reviewing the size of the OTSG for f
17 adequacy, what kind of analysis would you have done?
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Fundamentally heat transfer analy.is, trying to 1
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No._ At that time we were not doing much of the
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component oriented rather than systems oriented.
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Jim Moore was our system specialist at that tims.
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Did you ki the course of your work' look at the 12 design of the pressurizer?
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pressurizer was over addressed during that period of review?
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At any time up to the accident on March 28,dids
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okay.
Are you aware that there has been some 12 discussion?
Were you aware up to the time of the' accident
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I recall there were discussions of loss of load capability of the D&W plant, and we questioned Bsw on their 3
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By loss of load capability, do you mean the A7 transient response?
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Yes.
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And with respect to the pressuriser, what jg 20
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A Whether it was an adequate volume for expansion.
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In other words, whether the level of fluctuation 4
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is a aufficient volume there to ride through the transient.
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it would be whether the level of fluctuation is greater in.
5 magnitude as a function of pressurizar volume?
What you are 6
concerned about in the fluctuation and levels is that correct?
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No.. You are more concerned with preneure 8
variation than you are with level per so.
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counts.
You want to make sure you don't got the over-pressure
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avoid high or low pressure excursions during a transient, 11 12 following a transient.
13 0
You mean increasing the size of the pressurizer would allow you to increase the size of the steam space?
14 15
- A of course, 16 Q
I sea.
And that sirnply gives you essentially a spring or a storage chamber which has greater limits?
17 A
Yes, that is correct.
18 19 0
Is that the fundamental concern?
A Yes, it is.
20 Q
You indicated that you had become aware of 21 discussion about the appropriateness of the size _of the,
22 Pressurizer.
23 Do you ever recall having talked about that with y
hv anybody froin B&W7-
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I didn't personally cover that croc.
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Do you know who from GPU might have been
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I think at that timr 517. Schmauss was the W
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Yes.
And we also involved MPR Amrociates in 17
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Q Is schmauss still with GPU?
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A Yes, he is.
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Be is manager of instrumentation and control....
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Have they been a a
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available to us for almost anything we wnnt to bring thtm f.W in on.
They are a very strong technical organization, and 2
3 ve utilize thern wherever we feel we need some expertise r
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beyond that which we have within our own ' company.
i brought their people in on a number of' occasions to review l
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6 technical-related matters.
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Q Ubat does 17R stand for?
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A Mandell, Panoff and Rockwell Associates.
Those 9
,are the three people who formed the company.
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Where are they baded?'
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Washington, D. C.
12 Q
They are all ex-nuclear Navy peoplar is that f
13 right?
14 A
They started out that way.
I don't think they f
15 are all ex-nuclears now.
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16 Q
I mean the three, Hande11, Panoff and Rockwell?
17 A
Yes.
They were Naval reactor personnel.. _.
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18 Q
How far back has the relationship with MPR gone?
l 19 Back in the late '60's?.
20 A
Oh, yes.
'68,
'69, somewhere in there.
And we t
have used them consistently since that time.
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UP through today?
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Yes.
We still use their services.
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. We reviewed the control rod drive mechanism f.,
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design that'B&W had offered us.
I'can't lesnember the exact p
8 definition of the original one, but it was one that involved
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1 all of.their applications.
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okay.-
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A And we were successful in doing that.
We did
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convince B6W that they should use the roller nut design.
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Were there other areas that you can recall having L
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looked at during that era?.
A We' discussed insulation design for the NSEE
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system.,The reactor coolant pumps, we were very heavily --
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Q Any other areas that you can' recall?.
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I am sure there were many others, but they don't f
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,0 Okay... Now,_ when you becam pro ect manager for j
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the" design'of THI-2 in late 1PG9, can you doacribe to me 5
' '2e re..ponsibilitica of that job?
6 A'
'I was responsible there for the USSS design by j
7 B&W for both Unit 1 and Un t 2 and also for the balance of i
8 plant design by Burns & Roe for_the Unit 2.
And by " responsible," 1 9
I ruoan in the sonne of a project' engineer in a project
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mana' gar's' function,'which"was lens involved technically and 10 m re inv lved from the standpoint of their scheduling, their 11 i
timing, their ability to 'roduce the design as we needed it j
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to match the construction needs.
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0 You don't recall when in the fall of '69 you 14 t
k.that positiont o you?
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I can got d e a sume, and
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0 That is all right.
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Who' was your primary consultant, if you had one, 39 ysym to the balance of plant for Unit 20 q
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A' I dealt with P. O. Hardone, who was the Burns &
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And~ did you deal with"them equally and r.
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simultaneously on issues or was there some breakdown?
Did 2
you deal with Mr. Hardone on certain issues and Mr. DeRienzo g
3 en others?
4 A
If it was schedule or personnel oriented, we 5
probnbly would deal more with P. O. and if it were more 6
technical oriented, how was the design coming, what was 7
your approach to this or that, then we would deal with a
Paul DeRienzo.
It was a management design kind of a split 9
between the two of them.
10 O
Did you also have contact with engineers working 11 for these two men, Hardone and DeRienzo ---
12 A
Yes.
13
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--- with regard to specific issues?
14
'^
15 Q'
We dep sed a Mr. Gottilla about a week ago at 16 Durns & Roe.
Do you remember Mr. Gottilla?
g A
Yes, I do.
3g Q
He appears to have had responsibility for 39 control room design instrumentation during that period; is t
20 that correct?
A Yes.
22
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Q Is that accurate to your understanding?
i 23
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'A It is.
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During his deposition, we marked as Gottilla
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1 Deposition Exhibit 18 a r:nmorandum which I will show you.
2 It is dated March 14, 1969, to Mr. Dioram and Mr. Moely n
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3 from youroolf, I believe.
t 4i A
Yes.
5 0
Is that correct as to the date and the author 6
and the rocipient of this n:cmorandum, March 14, 19697 f
7 A
Yes.
8 0
"And this me=orandum was written by yourself7 L
9 A
Yes.
10 0
Do you recall the mnorandun?
If you want to 11 take some time to read it, please do.
t 12 A
(Witnoss perusing document.)
Yes.
This is the 13 rooting that we held to discuss the control room design after ve had decided to cove the unit from Oyster Crech to Three 14
~-
Itile Island, yes.
15 16 0
okay.
seeing tLhat document refreshes your recollection.
Do you remember the document itself?
17 A
Not in all its detail.
18 g.
19 0
okay.
Why don't you take a moment ' to read it so I
you have it fresh in your mind?
t 20 e
A (Perusing document.)
All right.
l;.
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MR.. ROCKifELL Off the record.
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O Actually, before we got to that document, let 3
ns.nsk you what you understood to be the reasons for the
[
4 cite change fro:n Oyster Creek to Three Milo Island.
5 A
I really wasn't involved in that.
It was a 6
management decision that was made at that time based on
-l 7
need for power, location of load, trying to match the 8
generation point with the load requirements and things of that 9
Sort.
t i
I really was not involved in making the decision i
l'O i
whethEr to move the unit or not.
11 I
12 O
Are you aware of any other considerations that 13 were or nay have been taken into account in making the site
~
change?
34 sA It was a lab r e nsid rati n at that tina having 15 to do with the availability of labor and difficulty with the 16 labor situation.
In How Jersey, it was very difficult.
37 1
0 Difficult in what sense?
18 A
In the sense of more of an aggressive labor 39 "I
i 20 i
plant, we were concerned that we would maybe run into some r
serious labor problems.
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Q When you say " aggressive," again, I don't know lI 23 whinEybumean'.
Were we having strikes?
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A Yes, we had strikes and we had labor difficulties.
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You arc roc 11y out of ny field now i'.i t, hic eron.
2 Q
I understand.
I just wanted to know what your
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general understanding is.
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A That is my gonoral understanding.
5 Q
Once the decision was nade to change the site,
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6 were you, as the project r2anager for TMI-2 design ---
1 7
A I was'not the project manager at that time.
The
'J 8
decision was trade in December of '68 to mye the unit, very 1
i 9
late December of '68.
- ~
10 O
Excune'me.
3 11 A
At the time of this nemo, for instance, I was 12 still a technical specialist.
13 Q
Right.
Okay.
14 In your role as technical specialist, do you reca11Jif there was any kind of a request for the then 15 I
existing design for Oyster Creek 2 which was being moved to 16 i
M --
17 A
Yes.
18 si 19 Q
--- to be reviewed in light of the fact that the location was being moved?
20
)
A Yes.
When we moved the unit, we changed the p;
21 Perating company from Jersey Central to Met-Ed.
And at that
{i 22 time Mot-Ed was responsible for the design of Unit 1 and 23 had been working on that for quite some time.'
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room design for Unit 2 and make en asconoment of whethor it 2
could be made to be iderntical to the Unit I design, the 3
thought being that it would facilitate, operations and make 4
for e Intter design from the standpoint' of having the same
~
5 basic control room design in both units.
6 O
Defore we get into that, was there any request 7
from GPU itself for any kind of a system review geared to 8
whatever difficulties night be present as a result of the i
9 alte ' change or whether new factors night be introduced as i
a result of the site chhnge?
10 11 A
I am not aware of any.
But I don't think that 12 rroving the unit would have imposed any changes, basic changes l
13 to the control room other than in the electrical area because i
[-}
14 of the connections to the grid would bo different.
So, there would' definitely be some changes in that area that would 15 follow from the move from Oyster Creek to Three Mile Island.
16 17 Q
For instanoo, one implication of the move fron oyster Creek to Three Mile Island would be that you already 18
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f 19 had on-going at Three Mile Island a power plant under~
construction that had been engineered by Gilbert Associates; 20 correct?
21
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A Yes.4
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4 22 Q
And now the question was snoving the power plant, 23
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.~-essentially similar power' plant ~,' same NSSS design but having 24 g\\
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Q Was a consideration given to dropping Durns & Roe f
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nn'd having Gilbert'Associatos take over the architect j
i rnglece.: function"so that you would 51 ave a match?
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5 I don't know whether that was considered or not.
A 6
Dut there was a determination made that we would not do that, 7
we would continue to have Burns & Roe proccod with the design 8
of Unit'2'.
9 "O
Do you know who 'would have made that decision 10 which you just'describod?
11 A
I suspect it would have beon Lou Roddis, who was 12 the director of the Nuclear Power Activitics Group at'that' l
13
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I 14 Q
Mr., Roddis is no longer with GPU7
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15 A
That is correct.
l 16 Q
Do you know where he is now?
n 17 A
ne has his own consulting business in charleston, q
18 South Carolina.
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You don't know the nana of that consulting firia f
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I 21 A
I think he goes by his own name, Lou Roddis,
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In any event, I take it you were not involved in the question of whether or not to change architect
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A That is right, I was not.
4 2
O or the decision in fact to rotain, continuo to 3
retain Durns & Roo af ter the site chango?
4 A
That is correct.' I was not involved in that.
t 5
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'And I take it this memorandun which I have 6
referred you to, which has boon marked as Cottilla Deposition 7
Exhibit 18, was done in your capacity as a technical
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Is that the right word?
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I don't undorstand your question.
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This memorandum dated !! arch 14, 1969, was done
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while you were still a technical specialists correct?
11 12 A
Yes.
13 O
And that npparently was one of the areas of your e
responsibility as a technical specialist, was the control 14 15 room?4 16 A
Not really.
17 0
Iraving had a chance to review this, how did you happen to write this memorandum?
37 18 y.,
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We had a vary small organization at that time ~, ~
'6 and we had raade a rather major determination to nove a 20 nuclear plant from one location to another.
And so, everyone 21 was pressed to serve ini trying to coordinate that move, and y,x.
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22 that is what I was really doing in this function, was 23
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And this vno one of the questiono that came up
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And so, what I did was
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control unit desiyn.
8 O
So,'you handled this particular issue on sort
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That is correct.'"'
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Rather than as part of the on-going responsibiliti es t
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night.
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16 (The testimony is continued on page 22.)
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Doferring now to the memorandum --
3 nnd I should noto for the record that I can't find the nark 4
by tihich this uns barked ao Gott111a Exhibit 18, but I assure 5
you it is Gott111a Exhibit 18.
6 A
I will tako your word for it.
7 4
Docause it is in my log, and I know we cirked 8
this exhibit.
9 Now, there is a reference in the fourth r
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10 para 6raph of this uccorandum, let ma read:
" Based on a 11
, comparison of the basic control room designs for Unit 1 and 2, 12 it was apparent that there is a basic difference in the desigt 13 philosophies pursued by the two designers."
14 And then it goes on:
"The Burns & noe design 15 for bnit 2 has a much more distinct grouping of control 16 functions than does the OAI design."-
~
17 Can you elaborate on what you meant there by 18 the distinct grouping of control functions?
Do you recall 19 what that difference in philosophy of control room design was1 e
20 A
I really can t.
Apparently I was able to j
a 21 distinguish that at the time, but thinking back on that, I 22 guess ten years have dulled say memories a bit as far as the : #,ll e.
23 specifics of the differences between the two control room
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24 designs.
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Do you remember the meeting itself 25 Q
Okay.
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that occurred apparently -- I think it occurred on tho day
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before you wrote thin letter, namely, March 13, 1969 3
A I recall being there.
I don't recall vividly 4
each step of the r/ecting or anything.
But I do recall the 5
uooting itself.
6 Q
Okay.
Then you go on in the fifth paragraph 7
on page one, " Hot-Ed explained their concern cycr not having 8
oncentially identical control roca desi5n.
They considered 9
that a high degree of conformity between the two control rooms 10 is casential"for a number of reasons."
11 I
And then you So on, as I am sure you recall 12 free having just rend it a a:cment ago, to point out that 13 other people at the meetin6 indicated that having control
)
14 room decigns which were very similar but not identical could J.
15 be dicadvantaged because of the potential for operator con-16 fusion in not rcmemberin6 which control room they are in.
17 A.
That is correct.
18 Q
Whereas, if you have distinctly di.fferent 19 control rooms, operators are less likely to forget which 20 plant they are working in.
21 A
Those were the two extremos we were lo'oking
' ' f.R ed
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22 at at this meeting, yes.
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23 4
And I am wondering, do you recall who
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24 basically was expressing or articulating two extremes in 4
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viewpoints, the two sides of the spectrum which yoii have "@.
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outlined in your nemorandumt 2
A The Mot-Ed personnel trere the ones who were
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i/tQcc*q cnd advocating the like design.
They thoucht that 4. th va~*cn, if identical or clor.a to identienl, would be t
} batter for them from the standpoint of operator training, 5
6 from the standpoint of licensing their people and frca the 7
ctandpoint of using their people.
They felt they could use people on both units =uch more interchangeably than they 8
9 could if the'decigns were quite different.
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2 :_
..I?ow, I don't recall who specificelly raised
~
10 h
h t cense.
Having
,the issue of di rerencca may be helpful in t a 11 two similar but not identical den 1 Ens could be worse than 12 13 having two very different designs.
I know that Jim Neely, for one, felt that 14 15 uny, because his feeling was even at Oyster Creek,"we were 16 Going to paint the two -- between Oyster Creek 1 and the then j
i 17 proposed Cyster Creek 2, which was now Three :411e 2, that wo 18 rould actually paint the centrol rocas different colora so
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19 that there would be no confusion as to which room the operator 20 was in, and it would' help him think that unit rather than Perhaps being confused as to which unit he might be in.
21
~4 Did you follow the cours'e"of that discussion
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22 or debate beyond this particular meeting that is being 23 7
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And how did that discussion f. low and what aas h,
2 the ultimate resolution of itt 3
A If I recall, we didn't reach a decision in 4
this tieeting.
We nort of recognized the issue.
We had 5
discussed both sidea of the coin, if you will, as to the 6
merita of one and the merits of the other.
7 And at that time, if I recall, we ended this 8
necting by asking Burns & Roc to acnd the drawings of their 9
control room to Met-Ed so that they could look at'it more 10 carefully.
And it in my recollection that they did ot t.
11 And the resolution finally turned out that we 12 agreed to retain the Unit 2 control room design as Burns &
I3
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Roe had prepared it rather than changing it around to make it 14 conform to the Unit 1 design.-
15 Q
The Burns tc Roe design as it was then came 16 closer to which of the extremes, the similarity or the 17 differenes?
18 A
There were larEe differences,between the two 19 control rooms.
e 20 Q
So, the ultimate consensus came down on the 21 side of obtaining differences or at least not changing what
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y 22 was then in existence?
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23 A
That is right.
And it wasn't just to have
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To make the chan6e would have involved quite yv 25 a bit of redesign effort and cost and' schedule impact as'well.
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Q Vould that decision ha.e been mada by b
2 representatives of Mot-Ed or of OPU, or would that be a joint 3
position?
4 A
If I recall, Met-Ed finally came around to the 5
viewpoint that it was not worth the chan6e to modify the design.
6 They felt that having separate designs was an acceptable 7
aituation, and we didn't end up having to wrestle before top 8
canagement to make the determination on this thing.
9 My recollection is they came around and agreed
'~
10 that we would retain the design as it was.
So that it was an 11 acquiescence on their part rather than a decision or a determina-12 tion made on anyone's part.
13 Q
Your memorandum is addressed to Mr. Bierman 14 and Mr. Neely.
They were both with OPU at that time; is that 15 corre t7 16 A
It's a little hard to figure out who was with 17 whom at that time.
We did not have a service corporation at 18 that time.
And we worked for the Nuclear Power Activities I9 Oroup,' but each person in the Nuclear Power Activities Group
_a: r.
20 was actually on the payroll of one of the operating companies.
21 Jim Neely was the project manager for Three a,
22 Mile 2.
George Bierman was project manager for Three Mile 1.
23 George was really a Met-Ed employee and y rked for Net-Ed.
24 Jim Neely was a Nuclear Pcwer Activities Group employee, and
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25 he really worked for the Nuclear Power Activities Group.
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That was et thic cp;cific tinne.
Lator on us W
2 brought the group together, and everyono werked for the Nucicar 3
Pcaer Activition Group.
4 4
And then that Nuclear Power Activitica Group 5
ultimately became CPU Service Corporatient 6
A Yes, we became the generation division of 7
CPU Service Corporation.
8 Q
And the service corporatien was formed about 9
1972; is that correct?
10 A~
I think that'is I
es.~ It must'haie beco '72 y
4 0 ing back to your dcocription of your duties 11 as a technical specialist, you indicated that' insofar as you 12 13 exercised a review function, it was, in part, to inject
(.
)
14 utility perspective --
l 15 A
- Yes, 16 Q
-- in connection with the ope ration, raintenance 17 c.nd accessibi.lity?
18
.A Yes.
19 4
To what extent, vis-a-vis' Burn & Roe, did you 20 find system design which did not adequately reflect a utility.
21 CF CPerating perspective?
In other words, did you find Burns
& Roe's approach' reflected a good deal of understanding of the
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22 23 point,of view of the utility or that there were a fair number of things which require re-thinking in light of utility
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A There ucre certainly a number of items that
[gj 2
didn't have what you would call utility perspectivo in it, 3
becauco many of the designers did not have operating orporienc e 4
or utility experience.
But I wouldn't characterizo Burns &
5 goe,s effort as being any different th,n any other architect engineer or any other IL3SS designers.
It is sort of a back-6 7
Ground that they all characteristically lack in their approach 0
to the job.
9 4
Can you give me examples of the kinds of things 4
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10 that you could be able.to inject into. the design that architect; 11 engineers typically would not, representing a utility's b
12 perspective?
13 A
Basically it would be in the location of the
(
14 equipment, the crientation of it, ability to gs.in access to
]
A 15 the equipnent.
At that time I think we had a little sharper 16 perspective on radiation control than perhaps some of their i
17 people did.
We try to make sure that designs were compatible 1
18 with minimum exposure to people.' We wanted to insure.that 19 we had adequate lay-down space so that when we were performing 20 maintenance or repair operations, that we had adequate space, 21 adequate handling equipment.
We had power outlets where a y
,y 773
,7 22 man might need one so we could. get a welding set into where 23 the man might be working, just sort of looking ahead beyond
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The characteristic of a designer is more 7
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3.
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g baro to thera cnd doea moet tho requiremonta and cafety, mest G-8 1
2 the requirements of flow, items like that, much more function-(h 3
ally oriented.
4 L'o try to make our perepoctivo a little 5
broader than that, look at the poor Euy who was going to have 6
to vork and live with that plant downstream rather than the 7
designer who would be comewhere else when the unit went into 8
operation.
9 Q
Baced on your werk as a technical specialist and as project manager, did you develop eny comparative view 10
,cf the experience cophistication of Burns & Roe as compared to 11 Gilbert Associates in an architect engineer's function with 12 13 respect to nuclear powert
(.)
14 A
Not really.
I think they were both qualified and they both did a very good job.
They both had problems 15 and they both had their share of shortages in experienced 16 17 Personnel, as did everyone back in these early days.,
I couldn't characterize one of them as being 18 19 superior to the other.
20 4
Do you know who at OPU would have been instrumental in the decision to select Babcock and Wilcox as 21 5
3 the MSSS supplier?
22 A
I would say that decision was made before I 23 r,
.r, got there, and that was probably a 1966 or '67 decision.
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Jorsey Control 1
9
- ?cuor and Light made the determination as far as I know to
?
2 select B&W.
3 4 !
Q You don't know who particularly rey have been 5
involved in that decisient 6
A I don't know.
i 7
4 Would GPU have been involved in that decision 8
aince it tras the holding company at that time?
9
.. A I tracn't there.
So, I don't know the extent to which they might have been involved.
In fact, I don't know 10 pho uss there from GPU at that time.
11 12 4
As the stanager of mechanical engineering from 13 1970-71 and as the mana6er of engineering on throu6h 1970s 0s what was the scope of your responsibility?
Did it include 14 i
Three# Mile Island Unit 27 15 I
A Yes, it did..
16 4
How such beyond Unit 2 did it got 17 A
Early on we were involved with Forked River,'
l 18 and for some period of time we were involved in a unit called 19 Portland 5, which was a projected nuclear plant that we took 20 bids On but never really placed an order for.
21 4
Portimad'57 T: 9:
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22 23 A
Portland 5, yes.
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Later on we'got involved in Oyster Creek,.
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support of the Cystor Crcok plant.
2 Q
You ccan nunbcr onu?
3 A'
Yes, the operating unit.
4 For cumple, as manger of enginacring, I uns recponsible for nuclear fuel, and our peoplo eorked with fuel 5
6 cunagement for the Oyster Creek station as well as the Three 7
Milo Isinnd.
And later we got involved in foncil units as uc1L.
8 4
Uhen did you becomo involved in fossil units?
9 A
IIcmcrCity 3 una our firatfossil unit, and we 10 ci,arted to got involved in.that around 1972, I suspect.
That 11 la a cuens, but it is in that area of 1972, started developing 12 the design of Homer City 3 13 4
How much of a portion of your time was TMI-2 e(>)
'14 taking during the time you ucro manager of acchanical engineer ingaNdmanag,crofen61neers?
Would it be pcosible to give an 15 16 averaget 17 A
I would say that when we were working on --
18 when I was mechanical engineering manager, probably 60 per
- p 19 cent of my time, more than half of my time was involved with 20 Three Mile.
But when I became engineering' manager, then my 21 time was split quite a bit more among the other units.
. 3-py.g;.-
22 I still probably continue to put 25 per cent 23 of my time on Three Mile Island.
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As I understand the initial target for
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A I can't vouch for that.
2 4
I any event, you understand that it tras 3
cubatantially earlier than the ultite.ato coutpletion dato?
4 A
Yes.
l Q
tihat are the reasons to the bout of your 5
6 ! un"3cratanding for the delay in ccmpletion of TMI-27 7
A I era really not equipped to talk about that, nd I cay that because :::y involvement was very technically 8
9
.criented in tha engineering departcent.
.I did not have involvetent in the project management, and I think you would 10 d
got a tauch stronger and better answer from our project oriente 11 12 pscple in that respect.
13 4
Okay.
And who would they bot
(;
s 14 A
I think Howard was project saanager for Three A
15 l'.ile Isisnd.
16 Q
And who cine would be familiar with that?
17 A
Bill Hirst was the manager of projects.
18 Q
The last name again?
19 A
H-I-R-S-T, Hirst.
20 Q
In your work as manager of engineering, did ye a become aware of any factors which may have related to a delay 21 22 in completion?
23 A
Certainly.
s 24 Q
Understanding that you didn't know all of them,
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67 25 were you aware of any of the factors?
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33 A
Wall, naturally.
You dcn't work in o vacuun.
12 1
Tou are bound to be aware of problems that are happenins.
[9 2
4 Could you tell me uhat you ucre crare off 3
A Funda=cntally ve were aware of delays in 4
5 delivery of equipment.
We were awars of the fact that it 6
just took a lot longer to build a big plant like this than we 7
thought ori inally.
I think a lot of our delay was based on 5
a ecce fairly optimistic schedules that we set fcr ourselves 9
at the beginning, and recognising that this is one of the cacly nucicar plank.s, Three Mile 1, at losst, and then Three 10 Jnle 2, we were in the learning stagen of trying to really 11 understand how long 11c took to build one of these units.
12 Productivity was always a question, whether 13
-.)
There were we were cetting adequ tc labor and productivity.
14 delays in design developmanb.
That impacted construction.
15
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Q Were there any other factors that you became 16 17 aware of in your role 4s manager of engineeringt,, --
A I don't think so.
Those are generally the
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20 4
You indicated that'your ' review function as a
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23 acces,sibility.
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other verds, what kinds of utility pernpoetives could you bring 2
to that croa that prhr,po was not presented aircady in the
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A I don't imow that we effected their 1sy-cut 4
becauce that ims pectty well fixed at the tfrn that I cace to 5
6 GW cad started to work in this area.
Ue did effect conc of ri.c activitics that they 7
a w:s ucridng en uith regard to handlir.g of equip:: cat end no f= th.
Ilmr a pernen could get into th0 bottaa of the ottana 9
i Ler.2rator, for c::c:.plo, uith crevded cond?tions that cristed 10 pinra, re:::ove the men-nay cnd then sain access to the botto:n 11 heed.
12 hco are thanklacs kinds of teoks.
You don't 13
(."
Isow whether you really accomplished anything in doing this
)
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Idud of work or not.
It is really hard to come up with a list 15 f things that they actually did that we would say were 16 definite improvecents to the B&W design.
We like to pride 37 ourselws in thinking that we did that, but it is, very:g, 13 difficult to put your finger on tangible imprcnements thet se 19 "8re **8Ponsible for.
^
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Renuwing tim characterir.ation of changes as 21
~
improvements,'do you recall any other chanaes' thaE you sede to l
22 confor#
d88192 t8 one 70n 8e #88 m Pracdcol 23
.s.,
7-or more useful fram a utility perspective?
i 24 Q
A
'the change in the control rod desige msneumi==
25 9
50 Mas 4LM e W A#$H AL. ON C.
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wo feol was clearly in an crea that wao much better to design v14 i
tocau5e it clininated ceals and potential Icatage paths and 2
clininated the need for an operator to get in and have to 3
repcir the.:o kinds of equiptent.
We worked very extensively with M W on colect-5 6
ing the neals for the reactor coolant pu=ps.
17e wanted to 7
- ahe cure that their desicn would be a long-lived design so i
8 that un vouldn't have to have shut-downs and would not have 9
to h::vc personnel co into a high radiation c.rca and have to 10 replace s'cals' en any kind of a frequent basia.
WeworkedonsomeoftheirotNerequipment, 11 12 pucps, not just the reactor ecolant system, some of their 13 other supply equipment, uith the same thoughts in mind, trying
()
to minimize maintenance or to make maintenance a little canier 14 to peri"orm and putting equipment in locations, although, again a 15 16 th*3 was more working with Burns 14 Roe than BW, but put 17 equipment in locations where the operators would not have 18 to be exposed to high radiation levels to do maintenance work, d
u 19 to take re.sdings or to calibrate a gauge and things of that
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Anything else that comes to mindt
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No.
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Okay.
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Q Are you nufficiently familiar with th9 design s,15 2
of a balanced pirnt in Units 1 and 2 to be able to cc= pare y
- the design with roepect to maintenanco access --
3 I
A Ho, I an not.
4 as between Units 1 and 27 5
4 6
A I have not perennally made such a comparison, 7
re2.11y.
8 Q
A couple of people havo indicated that they 9
f$cucht there was.a nignificant difference between Unit 1 cnd 10 2 in terms of naintenanco access, that Unit I was cubstantiall;r 11 cuperior in terr:us of case of access for maintenance purposes.
12 Vould you have any hacia for acrecing or din-13 acrosing with that characterisation?
)
14 A
I would not.
15 Q
When you moved on in your job to become cenior 16 censultant, how did your responsibilities change and what are 1
17 they now?
i 18 A
I basically moved out of the line management f
19 function and into a technical consulting capacity.
I became 3
4 20 involved in broader issues -
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21 4
Such as?
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22 A'
-- for the company.
23 Steam generator integrity was one issue.
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Any others?
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25 A
Safety, adequacy of our fossil units was one g
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. 16 iscue tint I did got involved in.
W 2
4 You caid the ::ord "carcty," and then you 3
c21d "adoquacy of fossil units."
Were you connecting the I
4 two or were you --
5 A
ITo.
I meant one nubject, cafety adequacy of 6
cur fcenil units.
7 Q
Okay.
Have there been any other focusca of 8
four uork as senior consultant?
9 A
Yes.
I have been involved in foccil-related l
10 cctivities to a largo degroo and primarily related to improved 11
, perfore:.nce of our largefossil units.
12 Q
Your reference to aton:n concrator integrity 13 cuts across both nuclear and fossil units?
14 A
Yes, it does.
15 Q
Have you looked at any exclusivo1y nuc1 car 16 issues in your role as cenior censultant?
17 A
Steam generator integrity is one of the items 18 that I have as a responsibility, I mean nuclear plant steam I9 generator integrity.
20 Q
The question was any exclusively nuclear 21 issues as a senior consultant, one which involves only nuclear
- p ec 3,4.; x
+
22 ' units and not a combination of fossil and nuclear.
23
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,I can't think of any..,,
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And you indicate that as senior consultant C
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25 you do report to Mr. Arnold?
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A Yes, I do.
h 2
Q Did you become involved at all in the TNI-2 3
recovery effort starting on the 20th and centinuing up to 4
today1 5
A Tos, I did.
6 Q
Could you describe what role you took?
7 A
I was anoigned to come down here on the 29th 8
of Ihrch basically to head up a team of people to recover the 9 l unit.
10 Q
I can infer frcm that that you were the top 11
, nan in charge?
12 A
Well, at that time we formed a small group 13 of people to -- ue forr.ed two groups of people, one to access
(_.)
14 the accident and another to make an assessment of the recovery 15 of the plant.
This lasted about three days, or two days.
16 Q
All right.
Thon you realized how --
17 A
Until we realized how big a job it was, and 18 then everybody worried about securing the plant and becoming e
19 involved in the accident itself, and I quickly got into that
'20 phase of it..
21 Q
I was just wondering if you were in charge 2
t' 3
c gf 22 of all of the thousands of people who descended.
23 A
Not at all.
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okay.
So, after the three days in which L&
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.w of the problem, what duties did you acouns in the recovery 48 i
2 procesa?
A The very early part of that I was in the 3
control ocu with a number of our other poopis trying to 4
assist in the securing of the reactor.
And then I became 5
involved in come of the health physics oriented functions on 6
the island, again not in the lino capacity but working with 7
them, overseeing their activitics to make sure that things 8
ucro being dona properly, that they had the right kind of 9
cupport, that they were trorried about the right kind of inauca 10 Q
thybe you can break this down.
You were head 33 of the team to recover the unit for about --
12 A
A day and a half.
13 Q
Then you were in the control roc:af 14
^
A Again this was only a matter of a few more 15 16 days in the control room area.
Q Okay.
And then you moved into the health 17 P ysics area a week or ten days after the accident?
h 18 19 A
Yes.
Trobably six to seven days after the 20 accident.
And I'only stayed there a short time working with those people.
21
. About that time the' waste management group 22 started to become formed, and I was assigned to work with the 23
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And did you stay with the waste management,,
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2 A
I stayed with the waste management group until 3
necewhere around near. the end of June.
4 4
So, the bulk of your personal effort during 5
the recovery period would have bocn with the wanto canaccr.cnt 6
group?
7 A
Yes.
8 4
' And did you have a particular position or 9, role in that group?
10
'A ' '
I was a general flunkie at the beginning as 11 pveryone was, really storrying about water inventory in the plant and trying to Eet some of the water off th's floor and 12 13 in the tanks, trying to generally gain control over the water e,.
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15 16
. (Testimony continued'on next page.)
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BY liR. ROCK'.TELL :
2 Q
And then what happened?
3 A
I then got involved in what wo call the 4
Technical Functiono Group.
5 0
In this within the Wasto 7tanagonent?
0 A
Within the Maste Management Group, yes.
7 o
And what was the Technical runctions Group 8
doing?
9 A
Prir.nrily looking ahead as to how to clean up 10 tho auxiliary building, how to procens the liquid waste, t,rying to establish the fundamentals of the decontanination 11 12 program, concerned with replacoraent of the filters and the 13 necuring of releases to the environn:ent from the plant.
.)
s-14 Q
Did you have a particular rolo or position with 4.
15 the Technical Functions coup?
)
16 A
I was, I guess you would call the managorj h
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I 18 0,
Group leador?
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Yea.
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20 Q
11 ave you stayed in touch with the Waste.-
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Fo
' As only casually.
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Are you familiar with the current status of the 1 44
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Q Let no skip ahoad e little bit in tim from what 2
wa have been talking about.
j Can you give to your current understanding of 3
4 the status of the work of the tracto Manar;ctant Group, and 5
perhaps we can taka it with respect, for instance, to the 1
6 auxiliary building, whero the vator is, is there still water 7
on the floor?
8 A
No, no, no._ Tho water has boon cleaned up from the floor, and all of the water is in tanks in secure holding 9
10 patterns, if you will.
Q What is your current water inventory?
7y A
The current inventory in Unit 2 is fairly well 12 13 fillco.
The normal tanks are fairly well filled.
d,..
Q When you say the "nornal tanks," what do you naan g
by that?
15 A
What I meant was the tanks that were part of the 16 original plant equipment, excluding tanks that we have added 37 e system since the time I got don he m and started 18
+
j; developing new storage facilities, new processing facilities. 1~
39 Q
In terns of water volume, how much contaminated.
'i 20
+
water do you have in these tanks?
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'A Something like 240,000 gallons of water in the -
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reactor coolant bleed tankn.
Q-Are those tanks in',the auxiliary room?." S M" W.".' M?TT.
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ther tanks, nornal complement of tanks in the auxiliary J
2 building.
And the other water is in the reactor building 3
4 munp.
0 Okay.
And how rauch do you have in the reactor 5
6 nunp?
A About 500,000 gallons thorn.
7 And are you getting radiation lovel readings from Q
g the ronctor buf.lding su::p?
Can you measure the level of 9
radiation in tho wator?
10 A
There has been no cuanureraent nado yet.
They 11 are vorhing on trying to get a camplo of the coolant from g
the containrent building, but that sample hasn't been taken 73 yet.
4Q Okay.
What are the problama associated with 1
getting that sample at present?
17 Accessibility is the biggest problem.
A As I understand, there are some satnpling lines O
18 ni that come out of the reactor building into other places in the
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19 plant.
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A They are not sampling lines.
They are process" 21 lines, really, and they are fairly largo, lines.,
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activity levol.
3 Q
IIove you put people in the auxiliary building 4
yot?
j t
5 A
ch, yon.
6 Q
You have?
7 A
- Yes, j
8 0
11 ave you been doing that onnentially from the 9'
.beginning?
10 g
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Do you have radioactivity readings from the i
12 reactor coolant blood tanks or from the other tanks in the i
13 auxiliary building?
14 A
Yes.
+
15 O
What are thoso?
16 A
I can't roca11 offhand.
Thero have been samples
. 17 taken of those tanks $tho water in those tanks.
The activity 18 levels and the isotopic composition is well defined there.
l 19 Q
And you are able to take samples regularly?
,u, 20 A-Yes.
21 Q
Is there any expectation as to when you will get
, 3, o.
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.r 22 a' readirig ~on the watir 'in the ' reactor building' sump?w b-23 A
There is, but I don't know what it is.
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24 Q
Do you know what kind of time frame they are
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7ty hopo is that it would bo loss than c matter 3-5 2
of months.
It would be vecks before we could actually take y
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" ""UP **
4 0
You have contracted with one or two companics, j
as I recall, to help in the wanto management effort?
i 5
6 A
YO8*
7 Q
It was announced two or three weeks ago, I g
believe; in that correct?
A Yes, that is correct.
9 Q
t --- -
10 A
13ut why are you pursuing that with me?
I menn, I am willing to talk about it.
12 0
Y u indi ated you were involved with the waste 13
", )
management.
14 (A
I was up until June.
These decisions were made after I left waste management.
o I am willing to talk about it, but if you really i
17 v
want specific up-to-date detail, you are probably better off t
18 talking to some of the people who are now in vaste management.
19 Q
I understand.
It is just that you are here..,
p~w 1
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I am not getting this in order to give anybody a report
[
on the current eff. ort.
I am trying to understand the process r
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<W-you have been going through.
And the fact that you are here, 23 l
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A Okay.
As long as you don't feel that I an' a "J'.
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leading authority on vasto management, becauco that I am not.
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0 I ' understand you are not.
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' A okay.'
5 0
This is not with an eye to try to give anybody 6
a status report on the curront of forta.
It is to try and 7
help no understand the acopo of the offort so that when we
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8 go ahead and talk to peoplo who are currently doing it, I
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vill hava a better understanding of what they are doing.
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i 10 A~
Fair enough.
11 O
What vero the names of those two companics that 12 have recently been obtained; do you recall?
13 A
Chem Nuclear Systems.
They are responsible j
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f 16 reactor building sump.
17 0,
tfasn't there another one named recently as
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18 a participant in the clean-up?
Maybe I am wrong.
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Therewas a contract awarded to Chem Huclear also for. the ' decontamination work in the auxiliary building.
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An outfit called VIKEM, who are subcontractors l
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Are you familiar with what the longer rango I
2 plan is for ono dealing with the contaminated trator in 3
nuuhor tuo, generally the approach to docontamination of 4
the " plant equipr. ant onco the water is rocoved?
Aro you ablo 5
to givo es any kind of an overviou?
6 A
When you nay the plant, you raean the reactor 7
huilding?
If you are talking about the reactor building, 8
I havo had no involvanont in the work that has boon going 9
on in recovery of the reactor building.
That has been dona 10 by Dochtel and'under the direction of different poopic in yy the GPU other than nyself.
12 0
Uho are they?
13 A
Dick Iteward has boon currently responsible for J
the Dochtel effort.
14
's Q
II vard s responsibilition then involves the 15 16 very f the roactor building?
r A
Yes.
17 0
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reactor building, a(Cre you also referring to the handling of
'TA 39 the contaminated water presently in the~ reactor building?
20 A
That is a function of the Maste Managenent group.
21 The processing of. that~ water would"be by the Waste Ma'nagement 22 we a.
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bocause it nado'moro conne to havo one group rosponsibio for 2
cleaning up all of the contaminated liquid on the oito.
3 Q
I na trying to got so:no cort of feel for this, 4
and you are the first ono I have talkod to.
I hopo you vill 5 ' givo rm a little data in torns of explainirrJ what the process 6
18-7 A
Cure.
Hall, the plan la to go in and process the 3
liquid water in the auxiliary building.
And there has been a 9
aynton not up for that called EPICOR-2.
That la a
'dc=inoralizati n systen.
You take the water and put it 10 through a pro-filter and removo any activity, any particulata a'etivity that is in the vator and also colectively remove g
i dino from tho water, and then you pass it through resin for 13 ion exchange to rarove the other activitios, the dissolved l
14 I
activitics in tho water.
15 And when you got the icvel down to that level 16 that is pormissible for discharge frota the plant, then the water would be discharged.
..Q Does that involve cycling and' recycling; and" 20 p.
a.
A It snay involve recycling until the affluent j
21 level of activity is such that it can be discharged.
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Q Okay.
And are you working in' that area with l
23 i
.l EPA standards for the discharge?
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lit:L'.ts on uhat can be dincharged from the plant, and that 2
really governs our ability to discharge.
3 Q
Okay.
In tho equipment for the filtering for 4
p rticulato activity, iodino through the resin beds all being 5
installed as new or added cIuipment just to handlo this 6
task?
7 A
Yes.
The IPIcon-2 facility is new.
It has been 3
added sinco the accident.
l 9
O And the EPIcon-2 refers to a rnanufacturer of a particular kind of equipment? -
10 A
EPICOR is a corTany, EPICOR, Incorporated.
J y7 So, it is their system.
So, we call it that.
12 Q
Is that system presently in place and roady to 13
)
operato?
g 15
. A Yes, as far as I know it is.
Q And how long has it been finished and ready to go?
16 I take it it took some time to build it?,
17 A
When I left it was fairly complete.
There was 18 still some work to be done on the system.
There'was more 39 software: to be done, training of people, troubleshooting 20 the system, running it through its test program.
But the actual installation was fairly well*
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completed by the time I left.
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Where is ' that ' system set up?
Physically where
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It is on tho cast side of the island opposito 4
(L; 2
Unit 2, and it is located in what was called the chotnical 3
cleaning building.
That building was actually built here 4
prior to the accident as a syston for chenically cleaning 5
the steam generator, and it uno never used for that purposo.
6 Q
IInvo you begun to proccas water through the 7
nPIcon-2 synten yet?
8 A
I don't think so.
9 0
Uhat are the things rornining to bo done before 10 that process can'atart?
Do you have any knowledge of that?
11,Again, generally ---
12 A
I don't know whether there are any technical 13 litr.itations or any physical limitations as far as it boing b-14 cocpleted or whether the testing is done and so forth.
- But, 15 of courso, we have been prevented from discharging or from 16 proconsing any liquid by the Cout:rd.osion until they complete 17 their environmental assessrent of processing liquid from 18 Three Mile Island.
19 Q
Are thor <s any facilitics so that you can begin
~
~ processing and simply place processed liquid into holding 20 21 tanks so that you can get going with the processing?
A We could do'that.
We'have storage facilities O
22 23 associated with EPICOR-2 so that we could process and then u.3:
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store the liquid, but we'h' ave not been permitted to do any
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processing.
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Q now, I havo heard referencoe, and I think they 2
aro primarily reforences from the news, to trucking liquid vant away fr m Three Mile Island, and I wanted to know 3
whethor that is accurato.
4 A
The only liquid waste va are trucking is from 5
6 the Johns over there.
Q Okay.
7 A
We have not trucked any radioactive vante from g
this aito, nor vill we do that in the future.
9 Q
Okay.
That is not part of the recovery effort?
O A
No.
O I am r latively --- this is an area that I 12 9
EY
(--
13
)
to anybody in this aroa before.
I hope you will excuse me for not being as knowledgeable as I should be, but it is 15 part of the Icarning process for me.
A Okay.
O So, the overall general' plan, as best you AU understand it, is to process the liquid waste through the EPICOR-2' system which basically cleans it up in a variety of s
ways, assuning you get permission and approval from the 21 NRC; is that correct?
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The intent is to process what we call the 23 intermediate level waste through the EPICOR system.'
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EPICOR system will not be used to clean up the high activity 25
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wastes that are in the reactor building basocont, for 2
example.
3 0
You nean the sump, by that?
4 A
Yes, the cump, reactor building sung.
i 5
The new syntem that Chom Nuclear is designing i
6 is intended to bo used for cleaning up tho traste in the i
L 7
reactor building bacin.
L 8
Q Okay.
Now, the intorpediato vaste which you 9
jur,t referred to vould bo the 240,000 gallons in the reactor 10 coolant biced tanks?
A It v uld be that plus the --- let's start with 11 the water in the rad vasto tanks,.and that is about the 12 13 150,000 gallon level that I talked about.
That is the first f
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14 thing that the EPICOR system is going to process.
It is the lo~ west level -- lowest activity level water that we are 15 going to be processing.
16 The intent was to start on that and then process
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nut in your use of de term Mntemdiate 14uid
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waste, you are referring basically, then, to the reactor f
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coolant bleed tank waste 'nd to the rad mate tanks in the 7
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auxiliary building?
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intormodiato waste?
(,
2 A
That is right.
3 Q
Kov, if there is a category of intermediate 4
wasto, do you hava a category of low level wanto?
5 A
Yen, ve do.
6 0
Uhat vaa that --
7 A
Conorally va have beon calling anything icas than 8
one nicrocurio por millilitar water low activity water.
9 O
Lot no got that.
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=
10 A
Leas than"one microcurio per n111111ter, that is
, hat we call low level activity. This is an arbitrary w
11 12 definition.
13 O
And do you have liquid waste in that range?
14 A
Some of the water in come of the tanks is in that 15 range'.
e 16 0
okay.
And would you treat that water in any 17 different fashion than the intermediate level wasta that you gg were just referring to?
1 19 A
No.
We would process that the'same way.
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20
. Q Through the EPICOR-2 ---
5, _
A Through the EPICOR-2 system.
21
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Q fAnd then the system boing set up by ches' Nuclear, ((
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m 22 will that also be essentially a filtering systers?
23
.,.?,,..~,a.x e r x' filtration systom domineralization.* #. ~ m" m,.w y e
.e g:. s e,n~- m....
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It is a 24 u,.
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cort, or is it fundanontally different in design than tho 2
3 A
It in different in design only that in the v
4 phyuical arrangement of the thing, the dominerali: era are 5
located or will bo located under water in the fuel pool, 6
and the reason for that is to provida shielding from the 7
radioactivity that will be built up in the filtors or in the 8
de: inoralizers as the water is being processed.
And then they
'j
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will bo handled under water.
Pilters will be put into casks 10 and then shipped off sito as dowatered resin.
11 O
The resin, then, is ultimately reducod to a 12 solid dry form?
13 A
Yes.
It is devaterod, and it la ennentially dry.
14 There is a littic moisture on it,but it is like dry.
15
.Q And then it is put into casks?-
A Shipping cask is a shielded, specially designed j
16 cask so that you can put the activity into it and shield 17 i
the public against it.
It keeps the radiation level down ll 18 to meet the requirements for transportation and burial.
l\\
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It is also designed to provide"a'very safe,
20 en 1 sure f r the activity while it is being transported.
21 Q.
So that the activity"that is removed from the 22
..~o...
wa er uly mateiy gets.-duced to dese relatively dry -
23
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A' You take it from the' water and you deposit it.
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on the resin, really is what you do.
It 1s called ion.
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exchange.
You tako it from the wator and put it on the
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2 Q
And then the rocin is ultimately takon and 3
reduced to a chunk?
4 A
no.
It is not nolidified.
j 5
i 6
Q It romains in liquid forn?
i l A
It romains in a --- ronin is liko little heads.
7 g
And what you do is you tako it and you run uator through it, and then you draw all of the water off of it.
And then that 9
is all d donatcred ronin, and it just stays in that form 10 1
as a loose resin within the domineralizor vessel itself.
11 Q
Okay.
And does it remain in tho'domineralizor g
13
.)
A Yos.
,, Q Porcanently?
A Yes.
It is shipped in the domineralizer vessel and then it is buried.
Q To the extent it is permanently disposed of, it g
is disposed of within -
A Within the same vessel, that is correct. ' -
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0 Then you can substitute a new dsmineralizer 21 vessel into your line --
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A That is right.
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-- if one is exhausted?
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and put it into a shipping cask and ship it and bring a new
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2 one in and put it into the process stream in place of the 3
exhaunted ono.
l 4
Q And is the dominoralizar vasoci uith the rocin l
5 incido like any other filter, has a certain capacity, and j
6 onco you hav,3 used it up, you have to replace it?
7 A
Yes.
It has either a chonical limit when you 8
exhaust it chemically co that it can no longar exchange 9
iona, or it' gets to an activity lovel, radioactivity level 10 of cuch a nagnitudo that you havo to ntop procoscing.
11 There is a limit on the amount you can chip.
12 So, you can only load it up to either a certain activ'ity 13 lovel or to its limit of ion exchange, whichever comes first.
14 Q
Is this procons of domineralization and ion 15 exchange one that has been in uso for some years in terms i
16 of decontaminating water?
17 A
Sure.n j
tu p r.
4 Our' normal rad waste systems une denineralizers 18 1
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Now, we have never handled water here with the t
21 i
activity lovel we are talking about.. That is the major- }{.
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vater through the derainora11: ors in ordor to reduce it to 2
acceptablo levels?
Is that the primary quantion, simply 3
how long, how runy tiros you havo to run it through the 4
flitor?
5 A
Yes.
There in no concern about whethor it will 6
vork or not.
It is a rattor of fine-tuning the system, 7
really.
And what it involves is trying to pick the right 8
renins, the right nix of resins or other lon exchango media 9
to do the job cost efficiently, really, so that you --- you
~~
10 like to got a ningle' pass system so you can run the nter through, remove a sufficient amount of activity so you can 11 12 just dischargo that water.
That would be the ultimate goal 13 of such a system.
)
3
.O The water would be discharged ultimately into the 34 rivers,is that correct?
15 A
16 So, to the extent you can achieve that, you 17 pr bably are going to reach som balance where you will have 18 to proccan and then maybe"rocycle tlirough the' system another 5
19 20
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But I think there is some development work going on by Chen Nuclear, and it is. fundamentally trying to fine-
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It is not trying to invent the system or
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determine whether it will work or not.
It is a matter of
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O Uhy does it make a difference that you chould be 2
abic to run water through tho ayatom onco inntoad of simply cycling it or recycling It until you are at whatover levol 3
4 you want?
5
. It's just a natter of economico, procacaing A
6 tirn, orcrator tino, peoplo being onployod to run water 7
nround a loop.
It doesn't pay of f if you can do it in one 3
cingle pans.
The best way to do it would bo to navo the enco-through ayatom.
9
~
0 What are the ostinates as to t1io volume of unter 10 that can be proceanod on a daily basis once the system 11 e
c: a n lin ?
I csu thero is a range of ostinates.
12 A
syn em s
a ng a
ne pr cens about 13
)
20 gallons por ninute.
Now, whether you can achieve 20 gallons per minute or whethor you have to slow this systors down a little bit to get an effective ion exchange on each pass remains to be seen.
That is part of the development 17 work that is going on now.
18
<u.
But' if you 'could" process at 20 ' gallons' per
~
19 minute, you can pump qitite a number of thousands of gallons 20 4,
through the. course of a day.
3:
Q, I was just calculating that.
About 24,000.
It-4
- &,'%n O;.;wnm%c-y
'..g"^
'. r u.: ;,;n r rl0 n', - ?
< ~
22 y
is a little more than that.
25,000.
23 I h a% n '.t!w......run the number out lately.,'so, I t W,. _'f *. -
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24 f x.2
. 7
~.
7! Q:
don't know... But you can process quite a bit of water that way 7
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y
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3-19 1
O Once the radioactivo unter has been --- annuming 2
the ayatem can be not up and tuned proparly and can be 3
procenced, dinchargod, and the radioactiva wasto retnoved 4
for dinpoani noncuhoro, I tako it the next ntop la than to 5
try to begin decontamination of tho insiden of whatever 6
buildings are contaninated; in that correct?
l 7
A That would bo the next stop, surely.
l 8
Nov, there is nomo decontanination going on in f
9 the auxiliary building now.
10 Q
Dee m e people are able to get in there?
l A
Suro.
Y u can got in and you can do sone 11 12 docontanination, cleaning up of' tho floorn, for oxar.ple, 33 where the water did come up on the floora and has left somo i
activity bohind, cleaning up the overhead structures, cable 34 i
. I tray and everything else where thoro has boon sono, activity 15
)
dop sited. '
16 Q ~ What is'tfie p'r'ocess that you usis for
~~~
~ ~
~
~ ~
~
y7 decontaduating pu11 ding structures and equipment itself?
3g r,, g:
~
A Somotimes it is no more than vacuuming.^
39 Sometines it is vacuuming followed by a wet wash of sorm u
)
20
~ '
a.
~
sort, just a ha'nd-on kind of a decontamination activity.
This isn't really.high loval activity.m. w......P'It is Q~
.1...
- oh 4.
w.
m 22 m
an a
- mi,e.4 - - o a mu "--
sort of low level contamination.
Q
.Tnd l'as this begun on 'a ' systematic basis now? ~ ~c,-
.. n a n.:,
~,. ~ n.w, s.. n. ~. ~. w.v w e. m.
o..
. au-mm mm. a,,
+ m.n.
u 24 4
It has been going' on, starting [with cleaning the
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floors and then in selectiva areas, going in and cleaning 2
up sono of the rost of the building.
3 It doesn't make sonno to go in and clean the 4
uholo building if you hava high activity water in the tanks 5
ascociated with that and the pipon and so forth.
You are 6
better off not putting peoplo into thone aroan on a routine 7
basis until you'liavo oliminated the activity sources, the g
water, the pipos, the gases and things liko that in the 9
building. You get rid of that first and then go in and ^
a job of cicaning up the auxiliary building itself.
10 S
there is a plan being developed to try to 11 integrate and organizo the entire auxilinry building clean-up 12 13 activity, including water prococcing and decontamination.
(.)
Q with respect to the reactor building, you g
15 "7 "
16 A
It's being addressed by a different group of-17 people than the Waste Management Group...
18
_ _ ;*p; jy..
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Waste Management has been largely involved in~ "
~ '
g the auxiliary building clean-up, plus processing liquid from
.0 c,._
. _ ~.. -
the reactor building.
The reactor building recovery effort has been focused in the Dechtel effortiS::A'i
.n..n. m ya m c. m ; m.;ica,yyy, h;sym]m T4 w "1)% C.!' +Pl pgcknyh ;;;cmx 22
.q. a y
O And under Mr. Heward's direction so far as 23 mp; apg j,*gojfegrnedh W D 55 # M f M'b M D D @ ** C D D # N 24
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A' That"is correct.--
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61 3-1 BY MR. ROCK' FELL:
2 Q
Who in the Mot-Ed person involved in the 3
reactor building >:. lean-up?
4 A
I cn not airaro of a Met-I'd percen por se.
5 4
It is primarily a GPU function?
6 A
Yes.
7 4
Is the process in the cican-up of the reactor building oecentially the caire, namely, that you uant to get i
9 the water cut and that ycu will got the trater out at coca 10 point, deconteninato it, and then you have to ctart trith some 11
' process of cleaning the insido of the building? _
12 A
Right.
That is 6enerally the approach.
You 13
-()
remove the liquid first and then get in and start -- when I 14
~
cay "get 1n,' I don't coan necescarily physically ~got in
~6
~
15
~
cither, because at 'this point we are just not really sure 16 what some of the activity levels are in the reactor building.
17 4
That was the question I was going to cocte to.
18 'l
~
l' Vbat"are your readings in ths.. reactor, p.,.
i 19
~
1 tuildingt. 9 2
t, m
.m A
I am not current on that.
I really don't' l
21 know what the activity level reading,e are and what some of
- F.
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V C
the current projections are.
23 l
c,..
7.,,5y ty.
To the extent that you,can begin some 7,l 3,
24 process of clean-up of the reactor building without actually
^
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~
25
%DAYbEMM
/I'F " % N M D ' '" M '
- M' sending pecple in, wha.t.as..re some cf the~ mechanisms t. hat y.ou.
f,.x..
a
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monesaca a maesnat, sac.
. at n. tocswntow ave.,
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I know of that are available?
.?
2 A
Probably the firnt thing you vould tant to 3
do would bo to do cono kind of recato c1 caning, perhaps uaing l
4 the building opray cyctem na a way of epraying in dotergent, 5
untor or water with decontamination colutions in it, so that saybo ycu could do =cca gross clean-up of e.xposed surfaces in 6
7 th3 reactor building.
And then perhaps with that kind of approach, then you might coloctively start naking penotrations 8
9 into the building with peopic in local creaa or maybo uith rn$te handling equipent of sena sort into cortnin areas and 10 11
,then start c1 caning, a6ain maybe using core or leas remote 12 equipment to that people -- it would not be a hands-on
)
c1 caning the first time through.
It would have to involve 13 14 acme kind of remote equipment to got in and at least c:ake a A
15 rough first-cut c1 caning of the building to get the activity 16 levels down.
~
17 4
That is essentially a wash-down kind of 18 processt f
75 y
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4 m
n 1
19 A
Generally.
You would like to do more than
..y y. --.
r
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20 washing.
You would like to get some decon solution in there.,
21 and you would like to get it so that you can spray it with r
;.L
- ca :tnc= % ys.,x
- m v
^'~
e-22 "some velocity rather than just a wetting of the'_ surface.
You 23 would actually like to try to blast or a laseir jet kind of a
- c :, a w. x w 5 y z a d w.m :.9 ; y g q, m.:. y ; y y ; p. ;,,
24 thing is more appropr. tate because it really moves the
' activity off the surface F N..,,yWRM ^
@ w.. ',N X m...s..,,
s.,,
a 25
,' f.f W p.
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63
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Como activity can be very tonaciours, tu:d even 2
with chemicals you can't novo it unicas you really give it a 3
good chot.
4 4
',That is a decon nolution?
'Jhat deca it 5
involve?
'Jhy is it different than water, for example?
6 A
Generally it tenda to disco 1vo and put into 7
solution all of your activity, so that it actually makes --
8 instead of just waching, it actually puts it into colution, 9
and then you can got it off the surface a lot better that way.
10 Q
Ucw, to tho extent thht you are uning fluids 11
,to either put activity into nolution or just simply wash it 12 off the surfaces inside the reactor, will you then have to 13 process that liquid through your liquid waste management L) 14 cyatem?
^
15 A
That is correct.
16 You said %yctems" and that is important 17 because we are really 1 coking not only at the demineralization 18 system but also looking at an evaporator system.. And there 7-;
v.
r 19 is a design of a process evaporator being performed by the 20 Waste Management' Group so that if you find later on that
~
21 demineralization saay not be economic to work on decon solution:s, s.
~
m g
we may want to use the evaporators as the primary way of A 22 23 cleaning up the decontamination solutions.
- 4.
+
sm-~s Q
I see.
The principle in the evaporator would ]_
24 ro bethatyoucouldevaporateoffcertainfluids,ankthat, y
25
- y,7
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27 N. LOC E wlLLow Art..
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- = - -
um
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I proccas leaves behind the radioactivity?
7j.
2 A
Yes.
r 3
4 And you can --
4 A
In a concentrated form.
5 Q
Concentrated and then co:tchett 6
A You solidify it.
You would solidify that.
7 Q
!!aw do you colidify something thut isn't 8
nocociated with the kind of nolid reninn that no ucre talking 9
about beforat 10
'A
' Thora are three or four ways of doin6 it.
11 Ana is to solidify it in concrete.
Another in to solidify 12 it in w!nt is called urea-fornaldchyde, a UF syatem, urca-13 formaldehyde.
And the third is to unc what is called a 14 Dow system from Dow Chemieni.
They have developed a binder 4
15 that tends to immobilize the liquid and then it hardens and 16 sets up so that it becomes an immobile mass, actually, as 17 coment sets up the same way..
18 4
Would'f,he use.of. cement -- you don't mean l
1 19 you are enclosing a liquid mass in cement?
q.w 2.
o,
20 A
It.is homogeneously dispersed through it 21 whether you are using UF,.Dow Chemical or concrete.
It is v
.~
+.
'y' ~
x 3%g::;n;3g;;g;u:mc34;;y : y ;
.y; 22 not just building a shell around a liquid core.
It is, t'
1
~
'23 actually dispersed homogenerously through the matrix.
. p. g7. g,. ;yy.v; 7,v.
- y y3 7 n.
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3 24 Q
Obviously we are building assumption upon g
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a,,n v. w..nw
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a 25 assuipption here, but I am interested in tracking through some
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1 hind of concral underntanding of how the process of recovery 2
in the icncer run might work.
j 3
Onco you have developed como sort of a systect 4
for liquid uasto manacement and once you htve becun a process 5
of building cican-up and accuming thcae proceed in somo 6
manageablo uay no that you can ultimately put people into 7
the Unit 2 reactor building, what kind of metallurgical or 8
structural or engineering analysis is going to have to be 9
done of all of the equipment in the Unit 2 building to see 10 to what extent they have been affected by all of the things 11 that happened cince March 28th?
12 A
I can't define apocifically what would be 13 done, but it in going to be a pretty extenoive program.
14 Soue of.the equipment has been under water 15 for a couple of months now.
Some of it has been exposed to 16 very high radiation leveI.s for some period of time.
There is 17 always a question of whether there han been acmo thermal 18 shock to some of the reactor plant components, and you
~
?
probably have to make some analysis of that to insure that 19 20 the equipment hasn't been damaged.
21 Insulation must be shot by now, and you g-g.
m7
,.y 22 probably have to replace that because it is water-lo6ged ori 23 because it is perhaps damaged in some other wa'y.
.o o_;r u.
eg; ;
24 Q
I understand that insulation, particularly
~~
%?
25 electrical insulation is highly susceptible to damage from -
A
[-
......c......m...c.
. n......,u.. m..
...., m......,,,,,
I y
t
66
-5 1
radleactivity.
j 2
A That la correct.
Certainly notora and 3
instruments and equipment in centainment would havo to ho 4
checked rather carefully to neo in fact whethor it has been 5
dataced by the radiation expecuro or not.
6 Q
Dcos radiatien exposure have a nctallur61 cal 7
effect?
8 A
It deca, but only at real high levoln of 9,very high energy neutrons.
10 For examplo, neutrons will cauce damace in 11 ptcol, in carbon stocl.
It will brittle carbon oteol.
Dut i
12 you havo to get up to very high levels, like maybe ten to 13 the cichteenth NVT, which is a very high activity IcVel.
1 t
14 And really, the only thing that is a mattor of concern there j
15 is the. reactor vencel itacif.
And that in not because of i
16 an accident.
That is because of just normal operation with 1
17 high neutron levels in the vicinity of the reactor vossel 18 itself.
n
)
19 So, I don't think there is any reni concern
, g m n 20 about radiation damage to metals in the building itself.
21 Thera.has nou been neutron activity, and it takes neutron,
\\
a.
yv.
22 high level neutron activity to actually cause' damage to metals.
23 But gammma, beta activity will affect 4.; w,,
p m m,; r g a n:
24 insulating materials, plastics and things of that sort.
L:j
~
a.
~
25 So, there undoubtedly has been some radiation
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7 damage to nemo of the equipment in the plant, and that is all 1
Coins to have to be asconced.
It is a thermal aneceanent, 2
radiation anscuoment, certainly Just a chemical physical 3
4 acnonement of equipsont that han boon expecod to ths liquid 5
in the reactor building bacecont.
6 Q
Obviounly wo are talking in highly Generalized 7
torns.
But cro there other major componanta of coing back in 8
and straightening out, cleaning up the kouan we. stoa in the 9
reactor building, auxiliary building other than what we have 10 discuscod generally?
A I don't think so.
It in generally an ij 12 activity clean-up and an equipment assoasment and refurbich-13 ment, is what you nre rea'11y coing to have to go through.
<.( )
4 Let me take you back now away from the 14 recovsry effort to the time when the GPU Service Corporation 15 was fomd.
16 MR.'TRAVIESO-DIAZ:
Let's take a five-i7 minute break.
18 s
19 (Shortrecens.)
~
20 21 (Testimony continued on next page.)
,A.
22 23 n-
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64 5-1 1
(Ronald L. Willian:s ranunca.)
2
..*F 3
DY MR. ROCmfELL: -
4 Q
At the tino of the formation of CPUSC, were 5
you abcorbed into that' organization ir.modiately?
6 A
Yan, I was.
7 Q
Do I correctly undcratand that Mr. Roddia uns 8
tho initial organitor and head of the Service Corporation?
9 A
no.
10 Q
Vao was?
11 A
I havo to think back on this.
Lou Roddis was 12 head of tha Nucioar Power Activitics Group.
That is the 13 organi stion I joined in 1900.
Lou actually left us in b.
14 April of '69, and a fellow named Goorge Rittor took ovar the 15 nuclear Power Activities Group then.
i 16 I an a little nebulous in my own nind as to who 17 was on board when we formed the Service Corporation.
18 Mhen we did form the Service Corporation, Bill 4, r,
19 Verrochi came over from Penelec and becana a Vice President 20 in charge of the CPU Service Corporation, Generationi -
y,.
.m.
Division at that tiina.
21 22 3
. Q There was m' Gene l ration" Division of the GPUSC7];f;.'
?'
A That is correct.
23 t'
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- u-A GPUSC was a lot bigger than the Nuclear, Power y,.
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5-2 1
Activities Group.
It involved como of the financial, como of the accounting, como of the auditing, a lot of other 2
3 functions than just uhnt no woro working on.
Wo vore a 4
cnall part of what beenna the Servico Corporation.
5 0
Did the nucicar Power Activitics Group encontially 6
becoco the Ganeration Division of GPUSC7 7
A That in cractly what happened to us.
8 0
Okay.
And nost of the engincoring functions 9
of CPUSC as they applied to TMI-2 would havo fallen within 10 the Generation )
inion?
A Yes.
17 I
12 Q
Okay.
Then the rent of the divisions were more 13 administrative as you have just describs.x17 3)
A No.
We had other technical groups, but they 14 were m ro inv Ivod with transmission distribution, involved 15 1
with our interchange with the Pennsylvania /Nes Jersey / Maryland
~
7 16 interchange.
They were involved with hydroactivities of 37 a
- l the company, things of that nature.
a; 18
- . j
~w 6.
As'far as power plants were concerned, we'were i
39 5
a the key technical group' responsible for power plant 20 developnant.
7,
' Now, within the Generation Division.at roughly?~
JA i
Q.
7 Y
+
.:- w
?_..C.
s 0,
22 the time of the formation of the CPUSC, are you able to give i,
23 LI me an overview of' the ~ structure of' that 'd51sion in terms db.
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of organizational structure?I
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5-3 1
A I think wo had a number of project managers 2
rather than a project group par ne, and each project managor 3
was renponsible for a specific project, Three M.ile Island 1, 4
Three Milo Island 2, !!or.or City, Forked River, Portland and 5
any other projects that we were working on at that tina.
6 0
Gonething city't 7
A Ilo m r city.
That was a fossil unit we vore 8
working on.
9 ifo alno had an engineering dapartmnt, and there 10 the responsibility van for nost of the technical functions 11 that went on.
I 12 The engineering department served each of the 13 projects.
In other worda, we were not project oriented.
We
(..)
14 wara a resource group for each of the projects, and our people 15 in engineering vorhed on all of the different projects.
I 16 O
Within the Generation Division, was there any 17 other departnent such as the engineering departent which was 18
".t ---
e.
A We had an environmental department who was-19 responsible for all of our environmental activities as well as i
20
,~
nuclear safety and licensing.
[
21 L
Q You say nuclear safety and licensing came under
.. et 22
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23
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e A
That is'sorrect.'
~y,
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24 We ials5 had a quality assurance department which
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25
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I staa coparato from ongincoring and environmontal projects.
5-4 2
O Do you renombor any other indopondent departirenta 3
besidea ongincaring, and environr. ental, GA7 4
A Projects ---
5 O
That ucro other than projects.
6 A
I think that was the banic structure.
Thoro 7
my havo boon an administrativo group or comothing like that, 8
but it would be a nnall function.
9 0
Then going back to your job responsibilition, 10 you ucro manager of this' enginnering department that you have jluatdescribedanprovidingcupportfunctionsacrosseachof 11 12 the project arean?
13 A
That is correct.
J 14 Q
And you reported as manager of engineering from 15
'71 through 1978 to what people?
Could you givo me the 16 namos of one person or hovover nany there were?
17 A
It was basically Bill Verrochi who was our f.
Vice Presiden't.
18 E
19 Q
Is he still Vice President?
20 A~
Ho.
He had Bob Arnold's job.
Bob Arnold moved
'P over in 1977 and replaced Bill Verrochi.
21 Q;
And Verrochi vent where in 19777, Jyge 22
.x.
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A Ife went back to Penalec as President of Penelec.
23 m.
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And Mr. Arnold care from what' job to' Vice '
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7 P u sident for the Generation Division of the CPUSC7 3
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A Dob was a Vice Pronident at Mot-Ed.
I think 2
they called it the production departreont.
It was basically 3
their generation depart. cont, also.
4 Q
As a technical specialist and than project canagor 5
and finally the engineering department as nenager of 6
ongincuring, do you have an understanding of how the GPU 7
organi=stion and the Met-Ed organization has intorfaced 8
from the tino the plant, TMI-2, was initially conceived up 9
to the time it went into operation?
10 A
Yes, I have a fair underctanding of that.
11 O
Could you trace for ne how that interface 12 occurred in its broad perspectiva?
tty understanding is the 13 shift occurred at some point from primary responsibility k.I 14 residing in GPU to primary responsibility residing in Met-Ed.
A I an intorested in how that shift occurred.
15 16 Q
I am going to be a little less than accurate on specific dates and so forth, but the hrine responsibility 17 18 for Three Mile 1 rested with Met-Ed.
They started before 19 the Nuclear Power Activities Group was formed.
So, they 20 had the responsibility for Three Mile 1.
And I have to say "prirm responsibility" because 21 we were also involved in supporting Het-Ed on Three Mile 1.
22 George Bierman was the project manager for 23 Met-No.
George reported to Met-Ed management, but George 4
also rap rted to Lou Roddis in the Nuclear Power Activities 25 0M8SACM $ M & B SM AL, $NC.
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2 So, if you look for a sharp line of demarcation, 3
it doesn't really exist.
4 Jira tieely was the ptoject w?. nager for Throo Mile 2.
5 Jim worked in the Ituelear Power Activities Group and reported 6
to Lou Roddis.
So, thoro was no ambiguity whatever about his 7
position.
8 Q
And he reported only to Roddis?
9 A
That is correct.
10 Q
And did not also report to Mot-Ed managernent?
A Well, he reported to some extent to Jersey yy Central management, but it was a lot sharper definition of 12 the fact that he worked directly for L'u Roddis in the o
13
-(>
Nuclesar Power Activities Group.
74
^*
15 focused in the Service Corporation more than the Nuclest power Activities Group.
Q Definition of what?
18 A
The definition of responsibility for Three Mile 1 9
and Three Mile 2 became much more sharply focused in the 20 Service Corporation or the Nuclear Power Activities Group.
I am quite sure that George Bierman, for example, was transferred to the Nuclear Power Activities Group.
You have to recall that Met-Ed had the 24 s
responsibility to operate the plant.
No question about that.
- MOMRRACM 4 MARSMAL. INC.
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And wo had tho recponsibility for designing and constructing 2
the plant.
So, there aro many interfaces betwoon tho two l
l 3
groups.
l 4
So, when I say responsibility for the plant, it l
5 is renponsibility in the specific areas designated.
So that 6
Met-Ed really always had the responsibility for Three Mile 7
Island, and va always had the responsibility for Three Hile 8
Island.
What became recre sharply focused was the fact that
/
9 the design and construction 'offorts became score and more a 10 part of the Service Corporation as timo vont on, and Met-Ed becano less involved in that and concentrated their activities 3y
'z.
12 much more on the operation of the plant.
13 Q
And with respect to THI-2, when would Met-Ed 's
<.,.?
14 responsibility for operation have ripened into an active role 15 in terms of having something to operate?
A Their involvoment goes way back in Three Mile 2 16 37 because they have a staff to train, they have procedures to write and a lot of things to do.
So, they didn't 18 39 suddenly become involved when we turned the plant over to them.
They had been very actively involved for, I would say, the 20 entire tenure, that wholo period of time, that while they were looking at Unit 1, they, nevertheless, had to make their staffing plans to cover both units, and they had to be 23 prepar d for operating the second unit as well as the first l
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2 In addition, the function that wo ucro trying 3
to perforn from the smallor group of giving the utility 4
pornpoetive, the operation flavor, if you will, looking at 5
design with thoso eyes and in that vein, bocare a Met-Ed 6
responsibility.
They were the operator, and they started to 7
review drawings and review plans and so forth to insure that 8
it raot the operator's requiror.cnts.
9 So, they had that kind of a function in the 10 design activity.
They woron't responsible for the donign, b,ut they wero given the role of reviewing the design ficom the 11 12 operator's standpoint.
And as they got more involved in 13 Unit'1, they became much more profic!ent in reviewing things
..J 14 for Unit 2.
15
^Q Was the contralizing of design and construction 16 responsibility in the Nuclear Power Activities Group or 17 subsequently in GPUSC, was any consideration given as to 18 whether either the Nuclear Power Activities Group or GPUSC should go all the way $ wn the road and become not only the 19
~
i 20 designer and overseer of construction but also en operator 21 of paar plants so that the whole spectrum of work on nuclear i
'J Powerplantswascentralised'to[oneorganization?.,
j 22 23, A
I can't answer that.
I was not at the level
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considered.
It probably was considered from time to time.
2 I was not part of any activo consideration of that kind of an 3
itos.
4 Q
That would include your ti:co as manager of j
5 ongineering?
6 A
That is right.
7 It was not a raging question at any timo as 8
to whether any one group should be totally responsible for 9
the whole thing or not.
l 10 He had a very broad balance betwoon the Service 13
, Corporation and the operating company.
In other words, it 12 was not just the Coneration Division.
We were a small part 13 of the whole GPU Service Corporation operating company O,
i 14 P cture, and there was a definite role for the Service 15 e magemt pad developed and a dennite
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x r le f r the Operating Company.
16 How, there raay have been consideration of one 77 D
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18 pretty clear, at least to me at that time, all through.this 39 tht g, that our responsthi11,ies were for design and 20 construction and the operating company's responsibilities 22
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f 1 Q
I understand.
I am not asking where the 23
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operating responsibilities lay. 'I think I understand that.
2 24
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The question'is whether a different organizational..[
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structuro was conaidered during that tium period, and I gather 2
you have no knowledge that it vas?
A I do not.
3 4
Q Do you know whethor there has bocn any 5
discussion since the accident focusing on organisational 6
structure in that conse?
7 A
I have no direct knowledge of any thinking along 8
those 11nos.
9 O
Do you have any indirect knowledge?
10 A
There"are all kinds of storios and rumors, of 11 e urne, floating around about the possibility of forming 12 a generation company per se.
That would involve both 13 design and construction as well as operation of the plants,
)
n but that is pure hearsay.
14 8
There has been no formal acknowledgement of that 15 by thi company as far as I know, and I am not aware of any 16 formalized thinking along that line.
17 o
okay.
In the GPU or the Muclear Power Activities 18
~
Group design review, for example, of Burns & Roe or 39 B&W proposed designs, would that, the acceptance of proposed 20 p
designs coming from those two organizations or from other 21 organizations for that matter, be done by an acceptance on y
22 1
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23 it be 'done by selective reje etion?
What is the process?
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It~vas an evolving process.
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As we grow and got raore peoplo, we developed 2
4 much woro formalized review process, and wo got into a 3
review of component-by-corsponent and system-by-system review 4
-of what was going on by both B&tt and Durns & noe.
5 In the early anys it was alt:ost by exception.
6 There were so few people.
We had no few people that we 7
delved into specific areas, and we treated things noro by 8
exception.
If we liked it, we didn't say anything.
If we 9
didn't like it, we left them know about it.
Dut as timo wont on, we'did develop'a much more 10 formalized review procedure, and eventually we ended up, 11 12 receiving, I think, most drawings, we selected which ones 13 we really wanted to review, we received most drawings, most 14 system descriptions, most procedures and things like that, and vs. reviewed them in a very structured fashion, so that 15 they knew whether we liked it or not.
It wasn't a matter 16 of just hearing what we didn't like.
We forna11y approved 17 r commented on or agreed with the design that was being 18 developed.
19 0
In your contact with the usss system, during the 20 time that its design was being reviewed, did you have any 21 l
familiarity with.the NSSS system's. design by D&W's three c
22 competitors, Westinghouse, General Electric and Western
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Y look at the B&W design?L." :
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A ifa did in a very formi censo becauno uo voro 2
reviewing and dovoloping the Forked River design with respect
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to engincoring.
So, un had a very direct comparison we were 4
making there.
5 The timo frano was auch, though, that we wore, 1
1 6
sooro or lass, looking at combustion engineering in light of J
7 n m rather than the other way around because Forked River 8
followed Three Mile Island by quite a few years.
- IIowever, 9
there were certainly things that casce out of our review of 10 combustion ongineering designs that we turned around and j
guestioned or fed back into the Throo Mile Island design as f
11
,i 12 well.
!)
13 In addition, a number of our people, just by i
O-o 14 virtue of prior employrnent, had experience with Westinghouse i
15 systenis, and, of course, we had Oyster Creek operating, and ll 11 16 while there aren't too many similarities between a boiling c1 17 water reactor and a pressurized water reactor, there were l1 f
18 soma.
And we learned mone lessons fron Oyster Creek that II 19 we tried to feed back into Three Mile Island as well.
.j r-20 Q
Dased on the degree of coruparative understanding l
ji that you have just described, is the D&W system as a whole j
21 L
a a re responsive system in the sense that it can be moved j
22 through power ranges more easily, can be retained on line 23 4
more easily?
Is that a characterization that has any basis 34 t
a-
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in Y ur 8xPerience?
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I don't think there would be any great difforence 2
betwoon any of the three PWR doolgns.
I think they all have 3
fairly much tho osmo limitation on their maneuverabillty, 4
if you vill, or their flo.sibility as far as operations are 5
concerned.
6 Now, there is a difference between a DNR, boiling 7
water reactor, and a PWR.
8 Q
I am not talking about that.
9 A
I know.
There l's a great difference there.
10 But I think the differences betwoan the three PWR designs 11 would be degrees rather than magnitudes of difference.
12 I am just'not aware of any flexibility that one 13 of those would have that the other wouldn't also have.
14 0
Are you aware of any comparison in terms of 15 design > margins between, say, D&W's systom, Westinghouse and i
o 16 Western Engineering?
j 17 Let me give you some examples.
He talked a r
18 moment ago, or actually it was a while ago now, about the
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19 size of the pressurizer and the rate at which the pressuriser level or the steam bubble in the pressuriser would fluctuate
!l 20 i,t based on the size of the pressure level.
p 21
-l Do y u know whether, for instance, there was less 22 of a design margin in the BtM pressurizer than in the r
23 N
24 Western Engineering or Westinghouse pressurizer?
}- -
A I don't know from a first-hand standpoint.be'cause,
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1 as I caid before, I was not really involved in the 2
transient analycos at all.
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nut again, I don't think Dr.W nuffers too much f
r 4
in that sonne.
I don't think that the Uostinghouso design 5
has very much grentor capability to roopond to transients 6
than the D&1f donign does.
It tuy, but I am not familiar 7
enough to nay that it doos or dooan't.
8 Q
What about the same question with respect to the 9
number of timos the pilot operated relief valve would be 10 challenged?
11 A
I can't answer that.
I really don't know the i
12 pressure swing that you would get on a comparable turbine 13 trip on a Westinghouse unit compared to a B&W unit.
14 I don't think that the pilot operated relief t
15 valve p'robicms are exclusive to B&W, though.
There are other j
I 16 plants that have pilot operated relief valve problems.
'17 O
The question is the number of times in which i
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19 A
It's hard to say because there are many more 20 Weistinghouse plants than there are B&W plants.
If you have r
twice as rr.any events that may be on a per plant year basis, 21 you would have to normalize it some way, and I have never f
22 l
~
seen a ch a norr.alization.
I don't know what it is.
23 Q
What about the same general question with respect l-l 24 u
r.
25 to the once-through steam generator?
My understanding is that p
n
\\e i (Q
I the boil-out dry time in the event of a totalions, both nain 2
and auxiliary food, in a onco-through is substantially loss 3
than you would hava in a U-2.
4
'A It is.
It has less invcntory of water.
5 Q
What advantages does the once-through steam 6
generator give that would lead to its usa - do you know -
7 as compared to.a U-27 8
A
'I don't think there are great differences really 9
in performance between the two.
10 I would'say'that naybe the onco-through steam 11 generator is core conducive to evaluation analysis than a 12 recirculating steam generator.
13 Q
I don 't understand what you are ---
14 A
I am talking about a performanco standpoint.
I' 15 If you' take a look at the operation of a once-through stoam 16 generator, it is fairly simple.
The water comes in, the water 17 goes out. ' Water comes in, and it is evaporated, and the I
18 water goes out, and you can trace where the water is going, s
19 you can understand the performance of that unit a little 20 battar than you can a recirculating unit where ' there is always 21 a mass of water in motion inside the unit at any one time.
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22 I think from a standpoint' of being a piece of
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23 equipment, a once-through steam generator is a good piece f.;. uq ' _;
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Tor example, thora havo boon far fostor problems 2
with once-through steam generators with corrosion, chemical 3
attack or a tube. failure standpoint' than there have been 4
with recirculating steau generators.
So, 'in that sonne f t is 5
not really a bad piece of equiprent.
It is a pretty good 6
piece of equipment.
7 You do got a little bit of super heat out of the 8
unit which isn't worth a whole lot in efficiency of the plant 9
or anything like that,.but again, you are very wall assured i
10 of good dry steam ' going into the turbines.
11 l
There were some broad advantages to the onoc-
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t 12 through steam generator that I believe led B&W into adopting 13 it instead of a rocirculating unit.
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14 From a performance standpoint, because it has s
15 less infantory, it clearly la more susceptible to feed water 16 failure.
It has less time, less for giving in that sense.
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17 It does boil dry faster, and you have to get feed in there 18 quickly.
But then the systems were designed with that
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20 So, it wasn't a deficiency in that standpoint.
21 You may have gained a little bit of time in Three Mile if m.,
22 we had not had such.a dependency on emergency feed water into
,a 23 the unit, but I really don't think history will show that the m.Q., k 24 blocked feed water valves made a very big difference in what m
25 really happened here at Three Mile Island.
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So, in that nenco, I don't think that the onco-2 through staan generator failed where another unit night havo 3*
made the grado or corothing of that sort.
4 0
My goontion doesn't intend to suggont that.
It 5
is a question directed to the overall look at the donign in 6
torna of whether it has any distinguishing featuren fron your 7
experience from competitivo dealgna along the lines of being 8
more ronponsive, more manipulative, if I can uso that example.
9 A
I junt don't have enough first-hand experience with the system dynamics or the tranniont responso work to 10 "ay that it does or doesn't.
11 Hy impression is that it is not much different 12 than the others.
13 Q
There is one thing I want to show you.
34 Hr. Williams, I 'am showing you what has been
(
15 previously marked as Dunn Deposition Exhibit 38.
I identify 16 that as a memorandum from a Mr. Tom Novak of the NRC dated 77 January 10, 1968.
jg Looking at it quickly, do you recognize the l
39 1
20 "*" ("" "
n 4
A No, I do not.
Q.
Could you review it briefly at this tima?
l 22 A
(Perusing docusaant.)
n-
^
Q Did_ you ' eve'r hecome aware of the issues, the
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kinds' of issues raised in that memorandum from Mr. Novak
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dated January,1970(nic) at any tirco before tho accident 2
of Threo 11tle Island 27 i.
1 3
A I do not.
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(The tantinony is continued on pacJo 85.)
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-1 DY MR. ROCKWELL i
Q Do you knew of anyone in GPU who was aware 2
iI f the kindo of issues being addreased by Mr. Novah there?
3 A
I do not.
?
4 5
Q Referring you to what has previously been 6
marked no Womach Deposition Exhibit 23, which I identify as i
i a February 9,1978, nemorandum from a Mr. nert Dunn, Babcock
^
7 8
and Wilcox, to Mr. Jim Taylor, also of B&W.
Would you take a moment to read that, please, il 9
all the way thecuch?
10 13 A
(Perusing document.)
f Q
Havo you'had a chance to read that memorandum 12 13 through?
A Yea, I have.
j 14 i
Q Were you aware of any of the issues, kind of j
15 16 inaues boing rained in that memorandum before the accident i
of Three Mile Island 27 17 A
I was not personally.
p 18
)
19 Q
Do you know of anyone in the OPU organization i
F who was aware of any of' th'e genera 1 issuealbeing addressed by g.
20 i
Mr. Dunn in that memorandum before the accident?
21 A'
I can't ady that I -- I knew of no -- I have fi 22 n t diacussed it with anyone or heard anyone discussing that f.
23
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g specific issue.
t 24 L'
Q Obviously I am talking about your knowledge.
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A Yes.
I was not aware of it, no.
2 Q
And you were not awaro that anybody else was?
3 A
That la correct.
4 Q
Do you know whether anybody at Metropolitan 5
Edison was aware of either the issues raised by Mr. Dunn or 6
the issues raised by Mr. Taylor.in the memorandum you read a 7
moment ago before the accident?
8 A
I am not aware of it.
No one discussed'it with me or anything of that nort.
10 Q
Had a report by Mr. Michelson, an engineer 11 with TVA, addressing in part questions of pressurizer icvel 12 high and RC pressure low ever ccme to your attention before
}
the accidenti 14 A
No, sir.
A 15 Q
As manager of engineering or as a technical specialist or any of the jobs you held in between, were you l
16 t
17 involved at all in the selection of the reactor building isolation signal of'four psi?
U 18 19 i
A Not personally.
L 20 That signal was developed primarily'by Burns
[a 21 l
& Roe or by B&W, with input from both of them, and would have
't 22 been reviewed by our engineering people and' cur licensing
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peoplei
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24 I was personally not involved in the selection
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2g of either the level or the choice of the signals to be used.
p Ip j.
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67 H
~3 Q
Do you kncv whether tho CPU review on that 1
question enconpucced other poccible signalo in addition to i
2 proscure in the containment, in other wordo, n:ultiple signal 3
thresholds?
4 A
I an sure the multiple signal threshold was 5
6 diccucced, but I can't tell you trabasis upon which we made the selection or the determination to pick simply the building 7
8 pres m e.
Q During the time you were manager of en61neer-9 ing, the NRC issue, what is known as the standard review plan, 10 11 appr ximately 1975, in that standard review plan, there is a
' tandard which suggests the use of multiple signals for
~
s 12 13 containment isolation.
Were you aware of that, of the standard i
14 review plan and of the contento of,the review plan with respect to isolation signals at about tho time it was published in 15 16 19757 A
Not specifically.
I did not Eet directly l
17 involved in that issue.
[
18 t.,
19 Was the standard review p'lan reviewed by the I
20 GPUSC engineering department at the time it was published?
[
l l
21
.I can't verify that it was, but I can be A
very sure that it was.
[
22
.4 Okay.
If it had been, where would it have v
23 been reviewed within the organization?
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A Basically the standard review plan was first
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revicued by our licensing people who made a de%craination as y
2 to whether the standard review plan would affect our ongoing 3
projecto or not.
And then where there woro differences between 4
the standard review plan and current projects, they were 5
bringing them to the attentien of the engineering people if 6
they felt they were significant encuch to warrant.
And if 7
they did bring it to the attention of the engineering people, 8
there would be a review made and a determination as to whether 9
vc should modify our then existing plant or not to meet the t.
10 standard review plan requirements.
11 Q
Would you have had engineers in the engineerin4; 12 department who would have had particular expertise with respect 13 to reactor buildin8 icolation, so that they would have been
.J 14 the ones to whom the standard review plan would have been i'
t' 15 brought?
L 16 A
I would say that that is a safety-related 17 issue that probably would have been determined by our
- j. l 18 7.icensing people directly.
From a safety standpoint, safety i
r 19 signal, it was more within the purview of the licensing L
20 department at that time.
L i
21 4
The reason I ask the question is because you
- i 22 indicated a moment ago in your answer'that the licensing.
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(1 23 department would have identified differences between the
- i D
24 standard review plan and ongoing projects and then would m
25 have brought those differences to the attention of the h
k MOMdeaCH & M ARdM AL. IN C.
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1 eng$ncering department.
2 A
That is rfcht, where they involved engineering 3
modifications.
Where they involved licensing points or items 4
of a border-line safety,analysin er safety casessment, then 5
the licensing people would be more likely to resolve those 6
within their cwn shop.
7 4
With engineers that were in the licensing 8
department?
9 A
Ch, yes.
There were engineering people in 10 the licensing apartment.
Q I see.
Do you know who was head of licensing 11 12 at GPU in the '75 to '77 time periodt 13 A
Jack Thorpe was the manager of environmental
'14 affairs for the environmental department, which included 4
15 the safety and licensin6 group.
}
16 The safety and licensing manager in 1975 was 17 probably Tom Crimmins.
18 Q
And your title there was safety and licensing 19 manager?
i 20 A
That is correct, manager of safety and 21 licensing.
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22 4
Would you, from the time'you,$oined GPU until 23 you became manager of engineering have reviewed at all the J
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. I would not have done thet personally.-
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3 A
Yes, it would have bcon.
4 It was fundamentally a Burns a Roe design 5
effort, and to the extent that' cur peoplo did Set involved 6
with that, we would have revioned their approach to poliching, 7
- yes, 8
Q That would be part of the ongoing review 9
function that you describad that GPU Servico Corp. oration was 10 having?
11 A
That is right.
12 Again, though, you have to recall size and 13 time vary.
The ability of our organization to review things 14 varied with tine.
And in the early days with a sinaller group, 15 we had to be very sel'ective in what we reviewed.
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3 I can't accuro you that we looked at that 4
very carefully back in Itf/2 or whenever the bacia for the 5
polishing system was established.
I suspect it was earlier 6
than '72.
In fact, I incv it was earlier than '72 7
4 I am sure it was.
8 A
That mir,ht have been at a time when we had 9,very limited resourcen available to us.
10 Q
Are you familiar with a man Toolc frorn the 11 f,PU organization?
12 A
Ron Toolet 13 4
Yes.
R. J. Toole.
'.)
14 A
Yes, I am.
- ^
Q Is he still theref l
15 16 A
' dell, Ron is now working for Penelec.
He is l
5 17 no longer with GPU Service Corpcration.
18 Q
Where would be be based?
1 19 A
Ron is at Homer City generatin6 station.
p 20 Q
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I 21 A
In Pennsylvania, yes.
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Did he" work in your engineering department' 23 for a. time?
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Yes.
Ron was in the start-up test group.
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being tout r.nnager.
I think his last pociticn wac start-up 4
and test manacer.
5 6
I' 7
(Testimony continued on next page.)
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DY MR. ROCKWELL:
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Baand on your experienco for sort.a ton plus 3
years with GPU and GPU Scrvice Corporation, is thcre one 4
ontity in the mix of co=panies and groups that aro involved 5
in building of a power plant that takes a single integrated 6
overview of the design and oporation of the power plant, 7
used as a whole, nees that one part makes nonse in light of 8
all of the ottier parts?
9 A.
I would say the Servico Corporation performs 10 that function.. Wo dopond on a lot of input from the '
11 pperating company to do that, And in some cases wo becorae
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12 a reforce in trying to balance design, construction, 13 schodule, cost and operator interest and operator desires and 14 no forth.
15 In cases where wo do have conflicting interest, 16 if you will, betwoon what the operator feels he wants or 17 needs in a plant and what we feel is appropriate for a plant, i
18 it generally winds up with Dob Arnold or 11erman Dieckamp to
.c 19 resolve.
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21 They don't go away very easily.
If they really feal they.
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22 23 try to reach a higher level of management.
I It is not that we have had an ability to just",
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But I take it your viou, though, is that that 2
overview integrating function ultimately does resido with 3
GPU as opposed to, for instance, !bt-Ed or any of the other 4
individutti participanta?
5 A
I fool it doon, yen.
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And would that be true from the beginning of ths L
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desig'n process, selection of vendors, up through the final l
8 certification in the start-up process of the plant, is as 9
it should bo?
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10 A
Yes, with a lot of input from the oporating i
In other words, it is not a unilateralt (
,ompany, though.
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12 assessment of things.
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13 opportunity we can to participate in the review and in the O
14 selection process.
i 15 s, Q I am not trying to suggest it is a unilateral 16 process.
I guess what I are curious about is whether the t
l responsibility ultimately resides in one place.
17 s
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I think that is right, and I think that is the
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Mr. Williams, have you made any statements from
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to friting or tapo or menorialized in any other way banod I
2 on what you anid, for instanco, an interview with a tapa 3
recorder.
4 A
fio, I havo not.
5 0
For instance, a written ntatomont in which you 6
put down your inpressions or put down noms analynin.
A 11 0, I havo not.
7 g
Q lio statomants as I havo defined then ao far as 9
you know?
A That is correct.
10 0
Okay.
13 A
I have r op nded to sorn3 interrogatories and things 12 13 f that nort on very select --- they are narrow innues.
('.l O
okay.
Who poned thoso intorrogatorien?
14 A
I responded to interrogatorios posed by the 7
flRC THI special inquiry group, and I renponded to some interrogatories submitted by the Susquehanna valley Alliance.
O can you tell me the general subject matter 18 4
I i
areas addressed in those interrogtcorios?
A In the Eusquehanna Valloy Alliance, they were i
basically associated with the wasta management activities, l
21 1
and in the special inquiry, those are basically in the waste 22 management activity areas, also.
23
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. I'm sorry.
No.
In the response to the special I
24 inquiry group, one question was related to the control room l
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2 0
11ov long is the net of interrogatorios and 3
your ancvoro posod by tho unc special inquiry group?
4 A
Fairly short.
5
!!R. P.OCKWELL :
Could wo have a copy of that, 6
pic33e7 7
HR. TRAVIEso-DIAz:
okay.
8 What do you want?
9 MR. ROCKNELL:
These would be the intorrogatorics 10 posed by the NRC opecial inquiry.
Is that the term you used?
11 TITE WITNESS:
I think that is the torn.
l 12 MR. ROCKWELL:
I think'probably it is the 13 URC's INE.
14 14R. TRAVIECO-DIAZ :
No, it is not INE It is the 15 on-gol'ng URC TMI inquiry.
16 MR. ROCKWELL:
And we would need not only the answorn but.' tho' questions in order to r:,aka nonse out of the 17 18 answors.
19 MR. TRAVIESO-DIAS:
Are you asking for the ones thint he prepared' or, the ones dose rhsponse he collected?
20 MR. ROCKWELL:
Both.
21 THE WITNESSt,"knainejill appear' onlh[on one [
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nY MR. ROCKuELLs 2
O Thoro woro throe interrogatories, one of which 3
you prepared and tuo of which you coordinated?
4 MR. TRAVIP.SO-DIA2 :
Just to clarify, thoy are 5
not interrogatorios.
They are requests for information of 6
doc uir.an ts.
They are not gouged in the languaga of boing 7
interrogatories.
I 8
1:n. ROCKWELL:
I neo.
l 1
9 TIIE WITNESS:
Excuse :m, ny Icgal --
10 14R. ROCKWELL:
That in all right.
11 TIIE WITHESS:
My background in lacking in that 12 nenne.
13 MR. ROCKWELL:
So long as wo are clear.
-)
14 Then some of the responces are simply in the 15 form o'f documents produced, sinco you indicated that sono 16 of the inquiries are for documents?
17 MR. TRINIESO-DIAt t The responsos are in the i
18 form of rmmoranda or docuncnts where portinent.
19 MR. ROCKWELL Off tho record.
20 21 (Off record dinoussion.)
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e, 22 23 T11E WITNESS:
I did also rr.ake a statement before
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BY MR. ROCKWELL (i
2 0
Was that in connection with the sories of 1
otatomonts nado by Mot-Ed personnol?
3 A
Yes.
4 5
0 Any other staterants that como to raind?
6 A
tro.
7 Q
1o 0 and A intervious?
8 A
Nothing pornonal like that.
I!o one on one or 9
anything of that sort.
MR. ROCmfELLs Okay.
I am going to recons 10 your deposition at this time, Mr. Williams.
By rocossing it, g
I leave you subject to recall for addit onal testimony should g
that be needed.
I don't know that it will be,but we will let 13 you know through the office here if it is necessary.
14 I appreciate your having nada yourself available A
on what was relatively short notice.
Thank you very snuch.
TIIE WITNESS:
You are welcome.
18 19 (Whereupon, at 4:15 o' clock p.m., the l
deposition was recessed.)
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WONRDACH 8 MAR $NAL. INC.
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2 I horchy cortify that the foregoing is a trum 3
and correct tranocript of t:y ntonotypo notes taken by no 4
during the deposition on the above cause, at tho herein 5
indicated tino and place.
6 I further cortify that I am neither attorney nor counsol for, nor reinted to or employed by any of the parties 7
8 to the action in which this deposition is taken, and further that I am not a relative or employee of any attorney or 9
counsol cop 1 yed by the' parties hereto or' financially 10 interested in the action.
y3 In witness whereof, I havo hereunto set my hand 12 and affixed ray n tarial seal this
@Nday of August, 1979.
13 14 15 tty commission Expires:
April 18, 1983 17 18
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