ML20136G882

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Applicant Exhibit A-2,consisting of Partial marked-up Transcript of R Lentz 841015 Deposition in Harrisburg,Pa Re Reactor Trip Review Rept
ML20136G882
Person / Time
Site: Three Mile Island Constellation icon.png
Issue date: 01/03/1985
From: Lentz R
AFFILIATION NOT ASSIGNED
To:
References
SP-A-002, SP-A-2, NUDOCS 8508200053
Download: ML20136G882 (14)


Text

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\ l UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION {_

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3 IN THE MATTER OF:  :

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g 4 METROPOLITAN EDISON COMPANY  : DOCKET NUM3ER 50-289 (THREE MILE ISLAND NUCLEAR  :

5 STATION, UNIT 1) -  :

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8 DEPOSITION OF: RICIIARD LENTZ --

9 TAKEN BY: TilREE MILE ISLAND ALERT 10 BEFORE: VIRTINIA T. BENGEL, CSR NOTARY PUBLIC 11 DATE: OCTOBER 15, 1984, 1:00 P.!1.

12 PLACE: FRIENDS MEETING HOUSE 13 6TH AND HERR STREETS

'( 14 HARRISBURG, PENNSYLVANIA 15 16 17 APPEARANCES: " ' " " ' '

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GOVERNMENT BY: LYNNE BERNABEI, ACCOUNTABILITY ESQUIRE **** PRO N 7 ""

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asJastas BISIIOP , LIBERMAN AND COOK ' #"""'

s 21 BY: JOIIN F. WILSON, ESQUIRE 8"E8

  • sentreeter m&Ts/'7 22 FOR - LICENSEE s** **

23 OFFICE OF EXECUTIVE LEGAL DIRc.-uan -_-

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BY: LOIS FINKELSTEIN, ESQUIRE 21 FOR - NUCLEAR REGULATORY COMMISSION 25 ".

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2 A -- had some of the data.that I needed. From whom I 3 foun it out, I don't know.

4 N

Q~ What kind of data was that?

l 5 A he data that I wanted to gather, something of the l 6 first list, pgu know, like the sequence of events or the reactor 7 trip review -- mean, post trip review and so on was not there, 8 that it had been p t together in the reactor trip review report -

i 9 that they put togeth whenever they have a reactor trip.

10 0 I'm asking- yo specifically what data was it that you 11 understood Mr. Benson had ut together?

i U A I don't know what i was.

  • 13 Q Did it have anything do with the alarm printouts?

14 A I don't know. I know he ad some of the stuff that f 15 was missing.

16 Q Now, did you speak to Mr. Mel that evening?

17 A I don' t know the name .

E Q How about Mr. Kidd?

j E A I don't know the name.

E O Mr. Iljes? .. .

21 A The name sounds familiar, but I don't know v 'io he is.

22 Q So you don't know whether you talked to him or t

%) that evening?

Si n "o e

i 25 0 Now, you spent -- well, let me ask you this. You

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l 1 gathered together cer_tain data that was available; is that ,

2 correct?

3 A Yes.

4 Q And that data included alarm summary reviews, alarm 5 printouts? -

6 A It may have. I at this time can't recall exactly 7 what it was.

8 There is some previous testimony to the NRC in which - -

  • O 9 you say you did gather and make xarox copies of alarm summary 10 reviews. Does that jog your memory?

I 11 A Yes, I may have made that statement to the NRC.

12 0 okay. And you have no information to indicate that T 13 that is incorrect at this time?

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14 A Well, I do and I don't in that I also said that I took 15 twelve hours worth of stuf f.. And to collect twelve hours worth 16 of stuff with that xerox copier would have taken another twelve 17 hours, and I wasn't in there that long. $;

18 Q .Let me just stop you for a moment. Let's just talk 19 about the kinds of data that you took. 4 20 Now, you said you took alarm summary reviews in your-- d.

21 NRC interview. Do you have any information today that indicates 22 you did not take those alarm summary reviews?

23 A No.

24- 0- The other thing that you talked about is taking.infor-l 25 mation from a storage area behind the computer printer?

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i 2 Q And you have no information to indicate that that '

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! 3 testimony is incorrect?

I 4 A Right. .

,. , 5 0 Again, I'm talking about the type of data.

6 A Other than like I said, that all of that stuff would t

7 have taken much more than twelve hours to copy.

8 Q Now, what kind of data was this in the storage area - -

7 4

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9 behind the computer printer?

10 A The alarm typer printout.

l That's the one that has 1

11 l the red and the black alternating -- you know, depending on 12 whether it comes in the alarm or CAIRS type alarm printer.

13

'f Q So basically the alarm summary review is the same

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l 14 thing as the data behind the storage area of the computer,'or 15 are those tuo different things?

16 A I don't recall anymore if they are or not the same.

I 17 O Mow, did you get the sequence of events recording? $

18 A That's one of the things that I was after was the '

19 - sequence of events and the post trip review.

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20 0 Did you get either one of those things? --

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1 21 A I should have got one of those. Those were the things 22 that we wanted to use, and we needed something like that to

! 23 make the graphs .that we made later on that evening.

24 0 So your nemory is that you got one of those two things?

l 25 A yes.

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Q And you don' t knoTe which one right now? .

2 A Yes.

l 3 .O How about the ICS?

4 A No.

l l

5 0 You did mot get that?

6 A That was down in the Relay Room, and they did not want 7- us walking through that area. The same with the reactimeter 8 ' tapes. ,

9 0 What is it that Mr. Benson got that you weren't able  ;

10 to get? -

11 A I don't know. I know I got it the next day.

12 Q Okay. Now --

T 13 A I think it was some of the stuff that goes into the 14 normal reactor' trip review report that they write up as-per the  !

15 procedures for the reactor trip review.

16 O So it might have been part'of the post trip monitor?

17 A yes, 18 Q In your prior testimony, you have indicated that therc 19 were gaps or holes in the information you obtained on March 28, 20 specifically a gap or hole for 5:00 to 5:30 a.m. --

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21 A We did not notice'the gap,until several days later.

22 O But there was a gap?

23 A There was a gap, yes. But I -- the gap uasn't noticec,  ;

21 until we started pouring over the data and we got the complete i 25 printout:off of the alarm typer.

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1 10 IJow , in previous stimony, you indicated you asked ,

j 2 for xerox copies on-March 29 because you determined a portion j 3 of the data was micsing from the alarm summary review typer, (

4 specifically the period from 5:00 to 5:30 a.m. Do you remenber 5 anything like that-?

6 A I know a portion was missing. I don't know what time-7 wise was missing.

l l l

8 okay.

Q. Your prior testimony was that you determined -

9 that on March 29 and asked for that information on March 29?

10 - A Yes. Sometime on the 29th, I guess, in xeroxing all 11 that data I discovered that a portion was missing. Sometime 12 on that day I may have started asking for it.

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V 13 0 Your prior testimony is that you revieued what you had 14 gotten on March 28 and discovered gaps which you had, specifi-15 cally --

16 A tio, that's not correct.

17 Q So your memory is now that you discovered the gap ~

'18 when? On March 29th?

19 A March 29th or maybe the 30th, whenever we started -

20 going over the alarm printer. di e 21 Q So your pricr' testimony may be in error?

22 .A- Yes.

23 0 llow --

3+ A I did not Xerox the stuff that was in the back of that i

. 25 alarm printer, to my knowledge, until at least the 29th.

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55 1 Q Nou, that's_ not what -- your prior testimony -- ,

2 A I know, but it was just too much stuff. I nay have 3 said that, but I did not do it. It was too much stuff there to 4 xerox.

5 Q Let's g& back for a moment. You said in your prior 6 testimony that you xeroxed the alarm printout and described it 7 as a three-fourth inch high stack of printout computer program 8 that was fan-folded. Now, is that incorrect? You're telling mc -

O now that that is incorrect?

10 A It must be- incorrect.

l 11 Q You also stated that you got twelve hours of data, E and it took you approximately two hours at the xerox machine to

  • 13 get that data.

l That is incorrect as well?

l l 14 A I think so, because I don't think I was on the site 15 two hours total, and about an hour of the time I spent waiting 1

16 to be able to copy stuff.

17 Q What timo did you return to the Observation Center?

18 A Sometime around ten o' clock or so.

19 Q Let me just go through your prior testimony because m it's very different than uhat you're saying here today, !!r. -

t 21 Lentz.

Z! First of all, you said that you --

23  !!R. UILSON : Objection.

21 BY !!S . DER mDEI:

l B Q -- xeroxed a volume of documents -- I s.

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1. MR. tILSON
_ Objec ion. The uitness should be allowec, 1

2 to review his prior testimony.

4 3 IIS. BERNABEI: Allow me to ask the question. If he 4 wishes to, he can. You're not his attorney. If the witness

! 5 wants to, he is al-lowed to.

6 BY MS. BERNABEI

7 Q Now, you testified at the previous time that the i

8 volume of documents you xeroxed on March 28 was a three-fourth -

i 9 inch high stack of computer printout.

I j 10 A I do not believe I copied that much that night.

11 Q. So you're saying that your prior testinony is incorrec t?

12 A yes, j

13 Q You also stated that you spent two hours standing at i

14 the xerox machine copying one page at a time. You're-saying j 15 that you did not spend that amount of time?

16 A Yes. I don'.t believe I spent that much time.

J i ~

17 Q That testimony is incorrect as well?

M A Yes.

t 19 j lQ You also stated you got twelve hours of data. You're i

20 saying that testimony is incorrect as well? --

5

' 21 A yes, 22 -Q

] You also said that you returned to the Observation 23 Center around 11:00 or 11:30. That is incorrect? Is that right?

l 24 A .I don't know what time I got back. .

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25 Q So that may be correct, the 11:00 or 11:30?

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~It may be correcET- I do remember coming back to the 1 A i

2 motel sometime around midnight, l

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! 3 .Q Mr. Lontz, let me just ask you this. Ilow is it that t

l 4 much. closer in time to the event, specifically June 1st of 1979,

5 you could make four mistakes about your gathering of information f

j 6 in the Unit-2 on the first day of the accident when that was i-

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7 your primary duty? Can you explain how you can make four mis-8 takes in your testimony to the NRC? - -

9 A All of that time just runs all together.

I

! 10 Q Did you see your testimony and'have a chance to correct 11 it?

U A Yes.

1 5 13 O And you didn't make these corrections at or near the i

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14 time of the. interview? Did you make these corrections and say 15 this is faulty testimony?

l- 16 A As I recall, when I read it, that's what I had said.

j 17 Q No, I'm asking you, didn't you correct it and tell the ~.

] 18 NRC much nearer to the time of the event in 1977, gee, that i

i 19 wasn't really the way it happened?

i 20 A Those three days down there just all run together. --

d 21 Q Mr. Lentz, I'm asking.you a very simple question.

l 22 You had a chance to review and correct your testimony. You did Z3 not do that, is that correct, in 1979 when you reviewed your Si testimony?  ;

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25 A Yes.

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i 1 0 You're also_tell me that if you said in your prior I

2 testimony, as I read it, that there were holes in the alarm

. 3 summary revieu that you obtained on March 28, that is, for the 4 period of 5:00 to 5:30 a.m., that is incorrect as well? Is 5- -that correct? -

! 6 A I did not discover it that night.

i 7 Q So that testimony, if it reads as I have stated it, 3

1 8 is incorrect? -t

! 9 A Yes, because I did not discover it that night.

10 0 It is fair to say that you did bring back some por-

! 11 tion of the alarm printout, is that correct, to the observation 5

12 Center?

I would hate to have to swear to the fact that yes, 13 A 14 I did bring back some portion of that. I honestly do not recall 15 if I brought back any portion at all of the alarm printer.

16 Q Mr. Broughton has testified that in fact the graphs 17 that you made or the plots-that he made on the evening of March 18 28 did include data from the alarm printout. .

l 19 A There is essentially no data worthwhile on the alarm 20 printer to make plots out of. - -t I

21

0 I'm not asking you that. His testimony is that you 22 did in fact use the alarm printout in part to make those two 23 plots. Do you have any information that contradicts that?  !

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24 A Yes, that the alarm printer has no data worthuhile to 25 make plots-of the nature that we made.

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  • nArn ren- ebn ,13-- n 4n+n- Tu nnmne 2 eith from the sequence of events or the post trip revicu, l 3 which gives a matrix type plot of pressures and temperatures.

l 4 Q So you estimony is that you did not bring back any l

l 5 alarm printout materia -

6 A No, I'm not making t statement either. I don't 7 recall bringing back alarm printers. I do remember looking in l

8 the box behind the computer, that the comp er alarm conter was - ,

9 just sitting there clicking away continuously, t there was a 10 large stack of paper back there, and that it vould have aken 11 cc: t-g te c 77 2ny of t', t in e---,- --

U Q My question to you is, do you today know of any alarm

] 13 printout data that you took on the evening of March 28 back to i

14 the observation Center? "

15 A Uo, I don't.

16 You have no memory?

Q 17 A I may have, but I may not have.

. 18 O Did you have any mem ry prior to today? I'm talking 19 about at any time, say from th time of your URC interview of 20 June of 1979 to the present. -- -

! 21 A Do I __

22 Q Did you have any better memory of whether or not you l

l 23 made alarm printout copics prior to today?

21 A I don't understand the question.

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15 Q You don' t have any mencry today whether or not you did

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I that; is that your te,stimoii9? Is that correct? ,

2 A Yes.

3 Q I'm asking you, at any time prior to today did you 4 have a better memory?

5 A Yes. Back earlier I would have remembered better.

6 Q Okay. How about a month ago?

7 A No.

8 O Let me ask you this. Did GPU or GPU attorneys request -

l 9 of you cortain information to respond to discovery?

10 A Yes. -

11 0 Did you tell them at that time that you recall making 12 copies of the pages from the alarm printer?

N 13 A Yes, I may have.

I 14 0 But you can't remember today whether or not you did?

l l 15 A I may have made just several pages of copics from the 16 alarm printer.

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17 0 That wasn't my question. My question is, did you tel}

18 them that about a month ago when they responded to discovery in 19 this proceeding?

3) A Yes, I may have. --

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21 Q Okay. But today you can't remember? Do you under-22 stand the question? You said you can't renember uhether or not l 23 you did it, but a month ago you told them you did?

21 A That was one of the things that I probably would have 25 copied if I had a chance to copy it.

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1 Q No. 11y question ~Is, you have stated tei.ar that you ,

2 have no memory of uhether you made copics of the alarn printout.

3 11 hat I'n asking you is, did you tell the GPU attorneys that you 4 did in fact make copics of the alarm printout on Itarch 28 a 5 month ago? -

6 Q Yes, I may have and because of the fact that I'm 7 confusing the alarm printer and the post trip ncnory revieu and 8 all these other things -- -

9 O Let's just talk about the alarm printer. You say --

10 and correct me if I'm urong. You say today you have no memory, 11 right? You have no memory of uhother you nado copics of the 12 alarm printer on tiarch 28. I'm asking you, didn't you tell the T 13 GPU attorneys about a month ago, maybe a shorter while ago, 11 that you in fact did make copics?

15 A Yes. I ansucred that question that yes, I nade copict:

16 of stuff.

17 Q So you had a better memory back then than you do today ?

13 A No. It's --

19 0 ifas your testimony then incorrect uhen you ansucred 20 yes back then? e 21 A It's the fact that --

22 O Mr. Lentz, I'm talhing about the alarm printout. I'm 23 not talking about the rest of the data. I'm talhing about the 21 alarm printout. You ans'.icred a month ago that in foct you had 25 mado copics of that data; is that right? '

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.. .. i 1 .A Ycn. And I, was Eliinking -- I guess I uns thinking ,

2 anyway of the post trip roviou and the sequence of ovents reviot 3 and so on.

4 Q But you don't know for sure, right? You don' t knou 5 for sure? You did say the alarm printout? That's what you 6 told the GPU attorneys a month ago?  !

l 7 A Yes, I may have told them the alarm printor.

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11 A gathered up all the notas I had and put them in a 12 file, and B t. took it, uhich is the same filo I pulled out

  • 13 of my drauer and nt on the request for data hora.

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11 Q Did you in i ato to anyone with regard to that pro-  !

15 cooding what data you had collectod?

16 A  !!o . I 17 Q That question uns novo asked ~of you?

16 A t;o , i If you remember, you and !!r.

19 0 oughton loft the sito 2D around midnight? . -

21 A I renombor gotting.back to the motel . motino around 22 midnight.

23 Q I think you said !1r. Broughton lof t before yo did?

28 A I don' t_ hnou how I got to the rnotol . I do romo. r 25 7 n *

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