ML20140D981
| ML20140D981 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 12/14/1984 |
| From: | Atomic Safety and Licensing Board Panel |
| To: | |
| References | |
| CON-#484-747 SP, NUDOCS 8412190265 | |
| Download: ML20140D981 (188) | |
Text
{{#Wiki_filter:nRGNAl U311ED STATES NUCLEAR REGULATORY COMMISSION O IN THE MATTER OF: DOCKET NO: METROPOLITAN EDISON COMPANY 50-289-SP (THREE MILE ISLAND NUCLEAR STATION, UNIT No. 1) i 0 LOCATION: HARRISBURG, PA PAGES: 31,504 to 32,720 DATE: FRIDAY, DECEMBER 14, 1984 $ b', [ldLI674 firsts (s/iv-V37 ace-FEDERAL REPORTERS, INC. OfficialReporters Sok100!bo000$209 I is o r PDR (202)347 3K0 NATICNWIDE COVEi< ACE
31,584 Sin.1 1 UNITED STATES OF AMERICA 2 NUCLEAR REGULATORY COMMISSION i ) ~ 3 BEFORE THE ATOMIC SAFETY AND LICENSING BOARD (3 (_/ 4 -________________x j l 5 In the Matter of: Docket No. 50-289-SP 6 METROPOLITAN EDISON COMPANY (Restart Romand on Management) l 7 (Three Mile Island Nuclear
- Station, Unit No. 1) 8
_______.._________x [ 9 The Library, Richards Hall 10 University Center 2986 North Second Street II Harrisburg, Pennsylvania 17110 l 12 Friday, December 14, 1984 i t' j (_)\\ 13 The hearing in the above-entitled matter resumed, l l Id pursuant to recess, at 9: 33 a.m. l 15 BEFORE: 16 JUDGE IVAN W. SMIT!I, Chairman Atomic Safety and Licensing Board I7 Nuclear Regulhtory Commission Washington, D. C. 20555 I JUDGE WilELDON J. WOLFE, Member II Atomic Safety and Licensing Board Nuclear Regulatory Cominission 20 Washington, D. C. 20555 l 21 JUDGE GUSTAVE A. LINENBERGER, JR., Member i /') Atomic Safety and Licensing Board I / 22 Nuclear Regulatory Commission Washington, D. C. 20555 i l 24 l weseres nopermes,Inc. l 25 l i
31.585 Sim 2 APPEARANCES: 2 On Behalf of the Licensee: 3-ERNEST BLAKE, ESO. DAVID R. LEWIS, ESQ. j 4 Shaw, Pittman, Potts & Trowbridge s 1800 M Street, N. W. 5 Washington, D. C. 20036 6 On Behalf of Three Mile Island Alert: 7 LYNNE BERNABEI, ESO. Government Accountability Project 8 1555 Connecticut Avenue, N. W. Washington, D. C. 20036 9 JOANNE DOROSHOW, ESO. 10 The Christic Institute 1324 North Capitol Street II Washington, D. C. 20036 12 On Behalf of the NRC Staff: 9 I3 JACK R. GOLDBERG, ESO. LOIS R. FINKELSTEIN, ESO. Id Office of the Executive Legal Director U. S. Nuclear Regulatory Commission j 15l' Washington, D. C. 20555 l 16 On Behalf of the Commonwealth of Pennsylvania: ,l i i f I7 THOMAS Y. AU, ESQ. Department of Environmental Resources 18 101 South Second Street 503 Executive House I9 Harrisburg, Pennsylvania 17120 20 21 23 24
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2 WITNESSES-Direct Cross' Redirect Recross Board 3 Richard A. Brill 4 . By ')k. Blake 31,593-By'Ms. Bernabei 31,605; 5 .By Mr. Au 31,651 By Mr. Goldberg 31,652 'O By Judge Smith ~ 31,657. By Judge Linenberger 31,657 17 By Judge Wolfe 31,659 i By tir. Blake 31,660 8 By Ms. Bernabei 31,663: j-9 10 I Identified Received Rejected . 11 TMIA Exhibit Number 41 31,606 12 ). TMIA Exhibit Number 42 31,612 13 h Licensee Exhibit Number 2 31,666 14 Licensee Exhibit Number 3 31,666 ' 15 1 Licensee Exhibit Number 4 31,670 31,686 ~ TMIA Exhibit Number 38 31,695 17 TMIA Exhibit Number 39 31,695 18 TMIA Exhibit Number 32-A I' ~ through 32-K 31,697 31,697 i 20 LA1-1N 21 Prefiled Testimony of Richard A. Brill Following Page .r's 31,610 l 3,,l-22 0 23 t 24 Amfederal nopenses, Inc. 25 i o mm.m m . m m.
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(9:33 a.m.) 3 JUDGE SMITH: Is there any preliminary business g3 V 4 before we hear from Mr. Brill? 5 MR. BLAKE: One matter, to respond to Judge 6 Linenberger's request with regard to TMIA Exhibit 32-C-7 and what that document is. 8 I'm going to let Mr. Lewis describe it. 9 MR. LEWIS: These were the three pages that 10 Ivan Porter was questioned about yesterday. They are not II printed off the computer of the alarm printer. They are 12 pages out of a book that sits next to the alarm printer. (3 A/ 13 There are a number of books that sit next to the printer. Id The books are instruction booklets and other information. 15' This particular book is called the point book. 16 What a point is, is the analog inputs to the computer. 17 The analog inputs come into the computer through an analog 18 input cabinet which is located in the cable spreading room. 19 In order to determine what point represents I ( 20 what input, you have to be able to match the numbers of l 21 the point to some particular instrument measuring a 22 parameter. This point book allows you to do that by giving 23 a point number and then an indication-of what that point p 24 number indicates. That is why this was used when they 1 Ace-Federal Reporters, Inc. 25 went down to -- when they were recording millivolts off
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the points. It was a convenient way to take a point and 2 know what number it is and then be able to write it next 7-3 to the point number and also correlate that with an actual w,) 4 input, in this case a particular thermocouple. 5 There is data at the botton, 01/03/78, Revision 6 1, that is just the date of the book, not a date when any 7 measurements that are handwritten in here were made. It 8 was a revision of the particular point book in question 9 that was sitting next to the computer console. 10 JUDGE LINENBERGER: All right, sir. I don't II want to belabor this. But I'm interested also in the fact 12 that on the left-hand side of these pages there appear to ) 13 be reproductions of what look like sprocket holes in the 14 side of the paper as though at some point in the history 15 of the original of this thing it run through some kind of 16 a device that had a sprocket drive on the paper. 17 Now, how does that square with your information 18 about the date and the point book discussion? 19 MR. LEWIS: It may well have come off a comput-20 er at one point, but it was not off the alat. _rinter. It 21 was not a printout off the alarm printer. I don't know 22 when it was originall printed, what device printed it. 23 But it was not something that was printed on the 28th at 24 the request of an operator. It was an informational book Acs. Federal Reporters, Iric. 25 that was sitting next to the console along with a large
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. number of other' books. 2 JUDGE LINENBERGER:' Okay. Thank you very much. 3 (The Board members are conferring.) 4 JUDGE SMITH: Anything else? .5 MS. BERNABEI: I have two exhibits that I 6 have distributed to the parties and move to be accepted '7 -if they have not been already. 8 One is the portions of the Broughton deposi-9 tion, which is TMIA Exhibit 31. That was accepted yester-10 day. We did not have sufficient copies yesterday. II (Ms. Bernabei is distributing copies to 12 the Board members and-the parties.) 13 And the'second would be portions of the Porter 14 . deposition to which the Licensee and TMIA have agreed, 15 and I believe that is TMIA Exhibit 50 -- excuse me, 40. 16 (Ms. Bernabei is distributing copies to 17 the Board members and the parties.) 18 I think there is still one outstanding matter,. 19 the OIA Report which I believe has been identified as 20 TMIA Exhibit 25. '21 JUDGE SMITH: That's right. What's the status 22 of that? 23 MS. BERNABEI: We move to introduce.it. We 24 think ' that it is relevant to Mr. Gamble 's. testimony, and Ann-7mseres neporters,Inc. 25 what would appear to be the Staff's criticisms of Mr. ll
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Gamble's performance in that investigation. We would 2 move to introduce it. 3 JUDGE SMITH: Are there any objections? b,e s. 4 MR. GOLDBERG: I guess with the same limitation 5 that a number of other documents have come into evidence, 6 namely in the context of what the witness had to say 7 about it, and to the extent that it was used, I don't 8 have an objection but certainly not admitted for all 9 purposes or for the truths of the matters asserted therein. 10 So, with the limitation I don' t have any II obj ec tion. 12 JUDGZ SMITH: Mr. Blake? A(_) 13 MR. BLAKE: Same position, to the extent it 14 was used and discussed. 15 JUDGE SMITH: The Board has an additional 16 reason for wanting to have that document a part o' the 17 record. It should not be cited for the truth of the 18 contents. It has some value I guess for the purposes 19 alluded to by Mr. Goldberg. It also has a value of 20 demonstrating the Board's -- that the Board has reviewed 21 that report and has decided that it does not contain any 22 information which would cause us to pursue the subject 23 matter of that report; that is, whether we are correct 24 or not correct in allowing the record to be closed at Ace-Federd Reporters, Inc. 25 that point should be subject to review and there it is, 1
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they can see what it is we didn't pursue. 2 And so for that purpose we will have it marked 3 as a document but not a~part of the evidentiary record 4 'for that purpose. 5 Anything further? 6 MS. BERNABEI: 'Yes. The Keaten notes, which 7 is TMIA' Exhibit 10, GPU counsel and we have decidied on 8 what perhaps could be called the official stipulated copy. 9 I believe there are only changes to two pages; that is, i 10 essentially an attempt to make the official stipulated Il copy conform, at least to our minds, to the original. I2 What I would propose, the TMIA-10.that I 13 distributed during Mr. Broughton's examination, I would Id propose for us to simply reproduce the two pages and pro-15 vide them to the parties.to substitute for those two pages 16 in the so-called clean copy. i. 17 END fl 18 l -Mary f1ws 19 ^ 20 21 l iu-24 AFaswei n.conws anc. 25 l.
31,592 JUDGE SMITH: That is fine. Sure Sh N 1 MS. BERNABEI: Okay. We will'have that done later 2 this morning. MR. GOLDBERG: Just a couple of minor things. I 4 i have been informed that the Commission meeting, which was scheduled for 2 o' clock on Tuesday has been cancelled. There is not a different meeting scheduled for that. time. I don't know whether the meeting that was scheduled for 2 o' clock on Tuesday concerning the TMI restart proceeding has been 9 r scheduled or just cancelled. But apparently it is not 10 1 nger g ing to take place at 2 o' clock on Tuesday. 11 Als .I have been informed by my office that TMIA 12 has moved to-reopen the steam generator proceeding and maybe g they wish to say something more about that, but I thought g
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We filed, as I undetstand it,-a-g motion to reopen on the grounds of. newly discovered evidence. l JUDGE WOLFE: That is before the Appeal Board? j: MS. BERNABEI: Yes. 39 JUDGE SMITH: Anything further? JUDGE WOLFE: Yes. One other thing. Ms. Bernabei, I have a note on your proposed-g Exhibit 38, or'38 which'has been admitted, I am not'certain. 23 t You had something to add to that? 24 i Am-Federal Reponers, Inc. f In any event,-I' don't have a copy of 38. Would 25 t l ^ ~ m---,. _.,.,,,.m.,. ,,,,, ~ - -, ,,,n-
31,593 Sim 2-2 you check on that? j JUDGE SMITH: That is the Abramovici notes. 2 MS. BERNABEI: Those we are getting copies of 3 's as well as Exhibit 39, which is a portion of Mr. Broughton's 4 n tes. We.should-have copies in a short time. 5 JUDGE WOLFE: All right. 6 MS. BERNABEI: And I would just propose to deal _7 with it at that time. 8 JUDGE SMITH: Are you ready for Mr. Brill? 9 10 Mr. Brill, would you come forward, please. jj I suspect we are going to need some table space. there. 12 ( 13 Whereupon, RICHARD A. BRILL 34 15 was called as a witness on-behalf of the applicant and, having 16 been first duly sworn by Judge Smith, was examined and t testified as follows: 37 JUDGE SMITH: State your name. 18 19 THE WITNESS: Richard A. Brill. DIRECT EXAMINATION 20 INDEX 21 . BY MR. BLAKE: 22 0 Mr. Brill, do you have before you a document 23 entitled " Testimony of Richard A. Brill" dated December 10, 24 .1984? l Am-Fedwei Reporwes, Inc. 25 A Yes, I.-do. L-._
31,594 Sim 2-3 1 Q Mr. Brill, do'you adopt this as your testimony 2 in this proceeding? 3 A Yes, I do. o s kJ 4 MR. BLAKE: Mr. Smith, I ask that the document 5 entitled " Testimony of Richard A. Brill" be'physicalif incor-6 porated into the record as though read. The document consists 7 -of three pages, three and a half pages and an attachment which 8 is a Taylor Instructions Instalations Installation Operation 9 Maintenance Manual by Taylor Instrument Companies. 10 MR. AU: Excuse'me. I don't think I have a copy t 11 of that. 12 MS. BERNABEI: I have two objections, the first (~m (,). 13 being I object to the testimony as a whole because I don't 14 believe that TMIA was given an adequate opportunity.to present 15 evidence on this same point, that is the physical evidence 16 that the pressure chart recorder was cut and perhaps Xeroxed 17 on the evening of March 28th, as some site personnel have 18 tesLJfied. 19 My second objection i1 as to the latter two 20 paragraphs which appear on~page 4. These two parapgraphs are 21 testimony by Mr. Brill as to apparently when the two cuts were s. 1 ) 22 made in the chart and whether or not they had been taped s, 23 .together at a previous time. 24 It is apparent from the testimony that be is not Am-Federal Reporters, Inc. 25 a competent witness to give that testimony. In other words, ~ . ~.
11,595 Sim 2-4 any information he has is from the chart custodian, Karen ~1 Imhoff, and it seems to me that this witness is not. competent, 2 that is his particular expertise and familiarity with. strip 3 (_rw) - charts wouldn't make him a competent witness to testify as 4 to when the or when the chart was not taped together. 5 I would not have the same objection to Karen 6 Imhoff, but she is not here to testify or cross-examine. 7 So, therefore, my second objection is to strike --- 8 or my second proposal would be to strike the last two 9 paragraphs since this witness does not have competence to 10 testify to this. JUDGE SMITH: It seems to me that you have'a big 12 ,f-) problem. - If we sustain your objection, we just adjourn the (,j 13 hearing and go on home and that is the end of it. I don't 14 know if that is what you want, but the Board will. consult 15 and see if that is what we want; 16 MS. BERNABEI: I have two objections, and let me 17 state it very clearly. 1 18 I have an objection to the licensee presenting testimony on this point, the testimony in the entirety, without 20 we be allowed to do so. 21 I think it is a relevant point and I think it is-one the Board should consider. 23 JUDGE WOLFE: What do you mean --- JUDGE SMITH: All right. We will take it under 25 s
31,596 advisement. 1-2 JUDGE WOLFE: What do you mean you being allowed 3 to. I don't unde; stand your point. ,s -( ) N/ 4 MS. BERNABEI: If you remember, at a prehearing 6 5 conference -- well let me start back in August. In August 6 we make a document request of the licensee for copies of 7 relevant document, including the original and copies of the 8 strip recorder. 9 We were not permitted to view the strip recorder 10 until the last day of discovery, October 15th. At that time 11 after we ;eviewed it, we asked the Board for access to the 12 striperecorder such that we could hire an expert to take a () 13 look at it. We were denied that at the prehearing conference. 14 At this time during the hearing we made a second 15 request to the Board that the staff provide someone to talk 15 about it, someone with operating experience that would be l 17 familiar with charts of this nature. l 18 We were not granted that request. We were told t 19 the resident inspector, who we didn't think had the kind of 20 ' expertise and the kind of objectivity to look at it, would 21 be provided and we rejected that offer. n i lis_) =22 We were provided an opportunity within the last l 23 two days to hire our own expert and we did make attempts and ( 24 we couldn't do that. Am-Federal Reporters, Inc. 25 My objection is'to having Mr. Brill testify, or i ~
31,597 Sim 2-6 having the licensee be able to produce testimony from their 3 expert as to physically what the chart shows without TMIA' 2 being accorded what I think was a similar opportunity, and 3 (3 A/ I' don't think granting us the chance to find someone within 4 the last two days is a rimiliar opportunity. 5 6 So that.is my objection overall to the testimony. 7 My specific objection is to the last two 8 paragraphs in that I don't think Mr. Bill has the competence 9 to testify as to that. It is clear that the chart custodian 10 may have information on when the chart was cut and the status 11 of the chart as to taping prior to the microfilming on 12 May 2nd, but Mr. Brill doesn't. ( 13 So my proposal is to let the testimony remain ^ except for the last two paragraphs. 15 L JUDGE SMITH: Oh,-I thought you objected to it. 16 MS. BERNABEI: We would be prejudiced if this-17 were admitted in its entirety. JUDGE SMITH: Well, we don't want to prejudice l l 19 you. So we are inclined to grant your objection to go home. i l 20 l or back to the office. 21 MS. BERNABEI: We are moving to strike the last -- 22 two paragraphs. That is our proposal. 23 JUDGE SMITH So you have no objections to the l l 24 receipt into evidence of his testimony except for the last i Am + w ne n oormn. =. l 25 two paragraphs. I-
31,598 Sim 2-7 ) MS. BERNABEI: That is correct. -2 JUDGE SMITH: Okay. 3 MR. GOLDBERG: I just have one thing to say in g s. k-);: 4 response to Ms. Bernabei's argument, and that is that there 5 is no basis at all for the-suggestion that the staff's 6 resident inspector is not objective and would not be 7 objective in testifying about strip chart records and we have 8 made the offer to have him testify. It was rejected by 9 TMIA, but I-resent the suggestion that he.would not be 10 objective. There is no foundation for such a suggestion. 11 (Board conferring.) JUDGE SMITH: Mr. Blake. (/ 13 MR. BLAKE: I will not go back over the discovery 14 disputes. I think there is a sufficient record to cope with 15 those. Let me just address the last two paragraphs. 16
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3-1-Wal 1 The next to the last paragraph purports Mr. 2 Brill's review of records of micro filming. It certainly 3 seems to me he ought to be able to do that. a. The second sentence in that. paragraph says that 4 5 he spoke with Karen Imhoff. He certainly ought to be'able to 6 say that. It certainly strikes me th$t anyone can be competent 7 to say I spoke with "X". We have heard testimony during this 8 hearing about *:no they spoke with, and who they didn' t. 9 The last paragraph is that he looked at the chart. 10 He looked at the chart and seen whether or not there is evidence. 11 The chart is here for each of us to inspect. It strikes me 12 simply as a matter of confidence and what weight in the end ,a ~ (_) 13 the parties might argue based on the examination of Mr. Brill, 14 but I see no basis on which to strike the last two paragraphs. 15 MS. BERNABEI: Let me-just address these two 16 points. One, we are talking about having people up here who 17 are involved in the central events of the accident. We are not 18 talking about -- and they zre talking about what other people i 19 told them, who are also involved in central events. 20 Here, we are talking about someone third hand i 21 talking about what a chart custodian told him, and I don't f"5-(. / 22 think that is reliable evidence. I think we should have the i 23 chart custodian. l 24 I would also mention the chart custodian was the Ace-Federal Reporters, Inc. - 2.5 person we asked for when we originally asked for witnesses, i 4 n .w-c-
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3-2-Wal 31,600 1 Someone'that could identify, and was in part 2 because we wanted to know about it has been maintained, and 3 when it was cut and taped back together again. We asked for I,,,1 V-4 that person. 5 JUDGE SMITH: Did you request a subpoena? 6 MS. BERNABEI: We asked the Board, and if you 7 remember in the original'1etter when we announced our a witnesses, we said the custodian of the chart. And there 9 was a big controversy over whether anybody would be able to 10 talk about the chart, and that was sort of laid on the?back 11 burner, but we asked for the custodian precisely for this 12 reason.- A I,)- 13 Secondly, Mr. Blake I don't think has quite 14 represented correctly this man's testimony. He said he looked 15 Lat the chart after it has been taped together after micro-16 filming, and he is going to tell us whethe'r it was taped 17 together before microfilming. 18 Now, I think that is a very tenuous. conclusion. 19 It seems to me the person who saw it before it was microfilmed' 20 should be making that determination and brought in here to 21 testify. I don't see any way this man has the basis to state 22 it is taped together now, and I have an opinion as to whether 23 it was taped together before it was taped together now. 24 I mean, that seems to me a very tenuous argument Ace-Federal Reporters, Inc. 25 to be making. And if there is someone who saw it before it was
. ~ G i, ~ ?3-3-Wal. 31,601 1 microfilmed, ' that. person should be brought in. t 72 JUDGE SMITH: My inclination ~is to just close the (eD ~3 record and. forget the whole thing, and let you argue whatever, you want to argue. 4 '5 MS. BERNABEI:-.We would be doubly prejudiced ~ 6 then. -7 JUDGE SMITH: I think the Board has gcae'to 8 extraordinary lengths to provide an opportunity for'you to [ -9 get this document into the hearing room, to let us look at it, 10 to hear what Mr. Brill's observations might be about it, and 4 - 11' now you seem to be quarreling with whether it is acceptable to Ll2 accept Mr. Brill's testimony that he learned, which I infer 'h 13 that he learned-from Karen Imhoff about the pieces being
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14 subsequently taped together. 'That, there is no question about 15 it, that is traditional hearsay problem, and it'is a traditional i i 16 hearsay objection that you are making. 17 I'am inclined.to say that we ought to grant it ~ 18 and go home, and not listen to. evidence on it. But this is 1 19 evidence at your request, and-you just accept the record the. .. 20 way it is. I am willing-to go home right now and forget.this [ 21 whole issue. 1 --- -A' [/d ~22 .-MS.-BERNABEI: What I am saying is it is accepted- ~ 23 except for the.-last two paragraphs. That is what I am saying. l 24 JUDGE SMITH: That is why'he is here, and that Ase-Feded Repo,wes, Inc. l4 . 25 is one of the reasons we are here is to look at that and see u- ..,. - -., _. -.. _ _, _.. - _, - -,,.. - -., ~ ~ -. -.. -
.3-4-Wal 31,602 1 if his observations make sense. 2 If you don't want us to, I don't want to, believe -q 3 me. Y 4 -MS. BERNABEI: Well, my: proposal is to admit the 5 testimony except for~the last two paragraphs. 6 . JUDGE SMITH: The last two paragraphs are important 7 I think-there is other relief that you could probably have. 8 You question whether the hearsay communication between this 9 witness and Karen Imhoff is reliable. I think maybe we could 10 proceed today. I think it is the type of hearsay that is in 11 violation of the hearsay rule, which given the context of' this 12 hearing, this person and everything else, is probably reliable. )() 13 But nevertheless, you have established a 14 traditional hearsay objection. I think we can probably proceed 15 with this guy. You can go out and interview Karen Imhoff if 16 you want to after the hearing. If you have doubts about it, 17 you move to reopen the record or something. 18 We probably won't grant it, you know, because I 19 think you are making a quibble. A quibble -- it is a trivial L!; 20 matter that you are raising, and I think that you are entitled i 21 to it, and go ahead, raise it. ) ~22 To tell you the truth, I would just as soon go 23 home. You know, I think you are putting obstacles in the way l 24 of your own effort to establish the record on the tape. Aas-Federal Reporters, Inc. 25 I would just as soon grant your objection and i k _.
a 5-Wal 31,603 1 go home-myself. 2 MS. BERNABEI: Judge Smith, our objection is to 3 only the last two paragraphs. h-4 JUDGE SMITH: Well, without the last two paragraphs, 5 .I don't think there is any point in being here. 6 MS. BERNABEI: Yes. There is quite a lot in the 7 rest of the testimony. 8 MR. GOLDBERG: This transcript is go ng to show 9 the objection originally was a general objection on how TMIA's 10 case would be prejudiced if the testimony as a whole came:in, 11 and then they went on and backed off that, and now it is the 12 last two paragraphs. .f 13 MS. BERNABEI: Let me -- 14 MR. GOLDBERG: I would appreciate it if you wouldi 15 not interrupt me. I have showed you that courtesy. 16 The transcript of this morning's proceeding will 17 - show exactly what Ms. Bernabei'said about this testimony. 18 MS. BERNABEI: Just so there isn't a problem I-19 on the record, le me state our position. We wanted to hire 20 our own expert to come in here to talk about it. We were 21 not allowed access to the chart, so we could not. Given that-() 22 fact, we are prejudiced by having only available to us a 23 Licensee witness. 24 What we have said is that -- Ace-Feeeral Reporters, Inc. j 25 JUDGE SMITH: This is the third time you have l l E
e3 3-6-Wal' 31,604 1 said tha't.- 2 MS. BERNABEI: Mr. Goldberg just misunderstood. 3 That is why( I stated it: correctly. ~ l,]: JUDGUESMITH:- I believe we can probably strike' 4 5 -the sentence: The pieces were subsequently taped togetherfby 6 Karen Imhoff, the chart custodian with whom I spoke, for 7 easier reference. 8 And leaving: The chart was later microfilmed 9 .in one piece, having been taped together). 10 Does that satisfy your hearsay objection? 11 MS. BERNABEI: Yes, for that paragraph. 12 JUDGE SMITH: And the rest of-it I don't.believe ) 13 you have any valid-objection. 14 He is making more or less a layman's observation, 15 a layman's opinion, that we.can judge the adequacy of ourselves-16 right' here in the hearing room. Neverf mitid. You obviously ~ 17 were not listening to ' what I had. to say. 18 It is not possible for you to engage in an active 19 conversation with you doing'the speaking with Ms. Doroshow 20 and listen to what I am saying. 21 You have the -- unless you have the unique N(,/ '22 capability of doing that, at the very least, the Board is -23 . entitled to the courtesy of a perception that you are listening .24 ito what we are saying. Ase-Fesersi nasumers, Inc. 25 MS. BERNABEI: Judge Smith, I heard what you
3-7-Wal 31,605 1 were sayingh-- 2 JUDGE SMITH: Your objection is overruled. 3 MS. BERNABEI: Let me just state I did hear what 7-V). 4 you said. You said for the other matters,.the Board has the 5 capability, normal human judgment to determine the validity 6 and weight to be given. That was what.I understood you to 7 say. 8 JUDGE SMITH: You got part of it. Let's forget 9 it. Your objection is overrruled, except as stated. We will 10 strike the line which reads: The pieces'were subsequently 'll taped together by Karen Imhoff, the chart custodian with whom 12 I spoke, for easier reference. r _( 13 Remaining is a new sentence: The chart was 14 later microfilmed. 15 You may cross examine. i 16 CROSS EXAMINATION -XXX INDEX 17 BY MS. BERNABEI 18 Q Mr. Brill, there are two strip charts for reactor 19 building pressure, is that correct? 20 A That is correct. 21 Q And in your testimony you speak about both of them, /~T () 22 is that correct? 23 A That is correct. 24 Q And each has, if I am correct, both an A and a B . Aas-Federal Reporters, Inc. 25 channel?
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A That is correct.
2 Q
And I think we were speaking earlier this morning, 3
there is an independent pressure sensor for each channel.
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servici o ise, in-e 1. if additio i i fer- >ia is res ired. se s re te i ci de ine Instrument Serial Number vith your request.
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Ssction IB-13A353 TAYL@R RECORDER Quick-Scan 8 Design H5frI4Cfl0HS 83OJ,93OJ Model D m ?; [5 5 5U b
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- 21
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~ .c s.!C i Fig.1 - One-Pen Recorder, 830J, 930J Model D e Q. l$.; n M G, ( 2. V ";W. t =j ]' 1- -7 - !-l, ); ~~] i.,.. ?- r 4
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v_. j Fig. 2 - Two-Pen Recorder, 830J, 930J Model D Table of Contents INTRODUCTION Installing Terminal Block and Cable. C Description. 2 Electrical Connections. C Serial and Catalog Numbers 2 Power Connections C Specifications 3 Input Connections C Installing Instrument Shde B INSTALLATION Chart Loading. B Mounting Instrument flousing. A Installing ink Capsule. B Mounting on inclined Surface B A-Refer to Housing section il-Refer to General Components section C-Refer to Electrical Connections section IN 5TR U CTI O N 5 F O R TA Y LO R I NSTR UMENTS 7ay/cr[subsmtal OmpanitJ RoCnEKTEll (H. NEW YorsK If.S.A. Prinen ti.iA.
Rccardcr Infr0MCff0H as ;,9sr; mod:i o OPERATION Aligning Pen Carriage D g Pre-Start-Up Check 4 Replacing Amplifier 5fodule D \\ Input Filter. B Replacing Servo Drive Cable D Chart Read-Back. B Checking Amplifier 51odule D ('\\ Two-Speed Chart Drive. B Trouble Shooting.. D V '; Description of Operation. B ( WIRING DIAGRASIS 51AINTENANCE Connection and Schematic Removing Instrument Slide. D Diagrams Back of hianual Calibration. D Periodic Servicing D Adjusting Chart Drive Clutch.. D Supply Spindle . D C-Refer to Electrical Connections section Rewind Spindle D D-Refer to Servicing and Trouble shooting section DESCRIPTION The Taylor Transcope Electronic Recorders, 830J, 930J, Fig. I and 2, are electrically operated instruments for receiving and recording electrical sig-nals on a 4" strip chart. Each recorder is a self-balancing system employing a solid state amplifier, balancing motor, recording pen and feedback element. d ) SERIAL and C ATALOG NUMBERS ( The serial number stamped on the data plate consists of the catalog number and a sequentialidentification number. The catalog number describes the construction of the recorder. An 'X' before the serial number indicates that the instrument has been built to meet a customer's special require-ments. Serial No. 830J _D,,1,,2, ,1, ,1, ,0, (53). 2,,0,,0, _D, - 555 ' Basic Catalog No. Actuation No. of Pens input Catalog Power No. Electrical Code .e Basic Options ,5 6
- Accessories f')
- Alarm Suffix (by Servo Color Code)
V , Alodel(Design Level) Sequential Identification No. Basic Cataleg No. Actuation 830J - Recorder D - D-C Single unit housing for panel mounting 930J - Same as 830J but without housing I N5TR U CTl O N 5 F O R TAY LO R I N 5TR UM E NT5 page 2
Raccrdar IB-13A35'3 83OJ, C3rJ Mod:;l D Introduction No. ofPens
- Accessories 1 - One pen (red)
(53) - Retransmitting potentiometer on 2 - Two pens (red, green) red servo 9 - Special (114)- Connections for extended cable system (149) - Same as (114) but with fuse Input 1 - I to 5 mA d-c
- Alarm Suffix 2 - 4 to 20 mA d-c 0 - No alarms 3 - 10 to 50 mA d-c 1 - One electric, NC 4 - 0.25 to 1.25V d-c 2 - One electric, NO 9 - Special 3 - Two electric,(1) NC,(2) NC" 4 - Two electric,(1) NO,(2) NO" Power 5 - Two electric,(1) NC,(2) NO" 1 - 117V,60 tiz 6 - Two electric,(1) NO,(2) NC" 2 - 117V,50 liz 8 - One, NC and NO 3 - 234V,50 IIz 9 - Two, NC and NO 5 - 110V,50 IIz 6 - 220V,50 IIz
- Omitted if not required 9 - Special
" Servos with two alarms: ElectricalCode (1) Alarm nearer to servo 1 - General Purpose (2) Alarm farther from servo 2 - Class I, Group D, Div 2 9 - Special Ch O Basic Options 0 - None 1 - Two Speed Chart Drive with on-off switch 2 - On-Off switch Example: Serial No. 830JD12110(53)-200D-555 identifies a Recorder (8303) that is actuated by d< (D)and has one red pen (1). The recorder accepts an input of 4 to 20 mA d-c (2),is powered by 117V,60 llz (1) and is designed to operate in areas designated as general purpose by the electrical code (1). It has no basic options (0) but has one accessory: a retransmitting potentiometer on the red servo (53). There is one alarm which is wired for NO (2). The sequential identification number is 555 and the des.gn level is Model D. SPECIFICATIONS n[g,t Input Signal Span input hnpedance u 1 I to 5 mA Adj 3.6 to 5 mA 250 oluns 2 4 to 20 mA Adj 14.5 to 20 mA 62.5 oluns 3 10 to 50 mA Adj 36 to 50 mA 25 ohms ( 4 0.25 to I.25V Adj 0.9 to 1.25V 100K at max unbalance *
- 30 nA max input current at null IN STR UCT I O N 5 F O R TA Y LO R I N5TR UM ENTS page 3
IB-13A353 Rcccrder Q ggg 839J,930J Mod:1 O Zero Limits Power Consumption (,' Adjustable -I to +0.25V 50 114: 22 VA (12W) per servo at balance A 60IIz: 17 VA (15W) per servo at balance Calibration Accuracy (} 10.25% typical Ambient Temperature Limits V 40*F minimum,120 F maximum PowerSupply ll7V 110%,50 liz i17V 110%,60 Ilz 234V 110%,50 llz 110V 110%,50 liz 220V 110%,50 liz OPERATION PRE-START-UP CHECK Before putting the recorder into operation, make sure that it is properly in-stalled and operating. Check the following: 0 1. See that electrical voltage and frequency agree with those on recorder data plate and that hot wire is connected to terminal 1, common wire to terminal 3, and ground wire to terminal 2 7() 2. Make certain that transmitter connections are correct. 3. See that an ink cartridge has been installed, the pen is inking properly and is tracking vertical lines on chart. If not, refer to Gene ral Compo-nents section. 4. Apply power to recorder and make following checks: a. That chart drives smoothly. b. That each pen assumes and holds a position on chart. If input condi-tion is known, check to see that pen reading agrees with this condi-tion. c. If input conditions can be varied, check 0,100% and several other points across range. (O,) 5. Advance chart by turning chart advance wheel until pen is at desired time j line. Recorder is now ready to be put into operation. C I I t r" I IN5YRUCTIO N5 F O R 7AYLO R I N 5TRUME NT5 page 4
' Manual No. A2299 lnstructions C> To the Customer: This manual is for use with the instruments identified below by Instrument Catalog Number. Custome r Mercury Co. of Norwood, Inc. Customer Order No. 52278-PC7604-1 Taylor Order No. 0814-024/72 Instrument Catalog No. X830JD13110D Tagging: HD-TR-1633 ('N WDG-FR-1484-1 (.) WDL-FR-3117 WDL-FR-1636 WDL-FR-1637 SR-FR-1638 BS-PR-1412 HD-PR-330 e f
- Refer to both the AlanualNo. and the Instrument Catalog No. when corresponding about this manual.
h iN57RUCT l O N5 F O R TAYLO R IN 5TR U MEN TS 7a4/[ar[mhumtal Ompdalu ROCitESTER (I). NEW YOR K U.S. A., Priaud io U.S. A.
Section IB-17J100 im.2 Singic-Unit Heusing 3 x 6 and 6 x 6 Panel Mounted Type for Electronic and Pneumatic Instruments InstalIats#on ( Figure 1 Figure 2 Figure 3 3 x 6 Single-Unit flousing 3 x 6 Single-Unit 6 x 6 Single-Unit flousing with Door flousing without with Door Door PART NUMBERS The part number is stamped inside, on the bottom surface, near the front of the housing. 35S457K - 6 x 6 x 24 in. Single-Unit flousing with door for Electronic Instruments 35S458K - 3 x 6 x 24 in. Single-Unit flousing with door for Electronic Instruments 355490 - 3 x 6 x 24 in. Single-Unit flousing without door for Pneumatic Instruments 35S505 - 3 x 6 x 24 in. Single-Unit Housing with door for Pneumatic Instruments 35S610K - 3 x 6 x 24 in. Single-Unit flousing without door for Electronic Instruments 35S637 - 3 x 6 x 18 in. Single-Unit liousing without door for Pneumatic Instruments i L IN5TRUCTI O N 5 FO R TA Y LO R IN5TR UMENT5 [ah[Mlmewd Ocm/uusNJ ROCHESTER (O. NEW YORK U.S.A. Printed in l'.S.A.
IB-17J100 Sincle-Unit Hausing Installation W l o.- L. o g [G 91 (ggjjj '~/N d Locking Stud/ N N ' Pneumatic Electronic Electronic Figure 4-3 x 6 Single Unit Housings, Back View Figure 5-6 x 6 Single Unit flousing, Back View MOUNTING
- 3. Reattach clamps to sides of housing.
h!ount the housing in a location that is free from vibra-tion, dirt and corrosive atmosphere. The ambient tem-
- 4. IIold housing perpendicular to panel surface and put perature should be within the limits specified for the bracket in place under housing. Tighten screws to instrument.
push bracket against bacle of panel and draw bezel tight against front surface; tighten locknuts. For identification purposes, back views of the housings are shown in Figures 4 and 5. Ifousings can be d,*! ( mounted, and conduit can be connected before install-(] ing the instrument. 6: p ; m / v Mounting and panel cut-out dimensions are shown in P6 Figures 7 and 8. Minimum center to-center distance NNh,p between cut-outs allows for use of plastic or rubber fygf grommets in the knockouts. If cable connectors or fi.f/p; rigid conduit is used, more space should be allowed for g.Qh$ ease in wiring. DU~7 ~ G j The housing can be mounted on an inclined surface. jj ] Maximum angles are shown in Figure 6. !f the mount-M c.c s ww ing angle exceeds 5* from horizontal, the instrument g;*g will require moderate rezeroing after installation. Re-Qi;'; fer to the instrument instructions. k?FiO GM s;c e Note f lP If the housing is to be used for an instru-T ment Weh has mercury switches, refer to r n the instrument instructions for allowable () mounting angles. E [,b y 4 Mos. Mount the housing as follows: t - It 3 - 3 s(2)
- 1. Remove mounting bracket and clamps, Figure 7.
(
- 2. Insert housing into cut-out from front of panel.
IN5TRUCTION5 FO R TAYLO R I N5TRUMENT5 Page 2
,m
- Electrical Conn 7/8 Knockout (El Z
(See Totle 1 j, 4 + L U - lf A man O = eerei C Mounting Brocket Clamp 3 O l_E See Note
== 4 a , f f H J ^
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a G O + n, -8 o g Z 7 6 gi ig
- f 8
{4 b' 8 o , ch:8-Fk3 2 -u=( ;4 o C _m _ 8 hU i U a 3{ f MonimumPonel Tickness ~h M 17 E Allow Clearc c. e 3] 25 For Cable Or Terminot 32 Block Cover Required H On Certain Instruments g All dimensions in inches Betel D 32 (, 3-a-c,, ' f _.3 For reference only; 3f M-. } 'z '~'D ll P not for construction a i sy q [~ g N'g s .); 3 l y3 Electrical Conn. Knockouts m -3.' ~ s ia{ Part No. Type Dim. E e . +.-_+- 1 ...6 .8 A B C D L'. -) f a \\ J ,[~, ~'~fa fl Ij I M8K M onk 2W6 X X I I -f 35S490 Pneumatic 24-5/16 X X L l .il -1 =.- I t -. 4 ___, _.% ' % ;j 355505 Pneumatic 24-5/16 X X g k D 355610K Electronic 24-5/16 X X H 5 - f PANEL CUT-OUT 35S637 Pneumatic 18 N c Q Center-to Center Distance F G R ecommended 7 10 Note: Electron 6c housings supplied with flat cover plate as shown. Min 6 mum 5-1/2 6-1/4 3 2 uinimum-aesta Conauit 6 lo w kN g viusn with nack of nousin, or project 5/8 maximum. 5 es M O. o u m Figure 7-Mounting Dimensions for 3 x 6 Single-Unit flousings D O
o o' o ~ V Electrical Connb. aus M $ z 7/8 Knockout 3 ? 1 4A 5 l A + q b t a g 1 I 2 + g 4)8 minum
==mus 3 h it k n W n e es., 'um s i I Mounting Brocket Clamp 6 m j 6 16- ' i-r5 7,$ { i s t 4 6 j,d3 l e e 4;, 8 mmi um = = t__f j 1 3...imum,onel m,nes. - q- \\,or. Cleo,once lio 7 g, jg g4 2 F Cable Or 5 p 16 Terminal Block 4 Cover Required On 3 Certain Instruments l 4 i O --5 A .- r-j--------t e.,ei i a i I / l 6 - -+ -+ 5 8 l center-to-center Distance A B g 6 k- + f$ z = Recommeno.o io so g .l l Minimum 8 8-1/4 I g j l I Minimum-Rigid Conduit 9 lo { l i c.i 5
- c.. I s.
L__ -- -- - J. j g _2 All dimensions in inches h k I g E PANEL CUT-OUT l For reference only; O not for construction C j z 3, -s 3 Figure 8-Mounting Dimensions for 6 x 6 Single-Unit flousing m i i __q n m
IB-13A454 Elactricci Ccnncctions '55"' 4 For Taylor Transcope 4 Recorders 83OJ, 93OJ Models A, B, C and D 870J,970J INStGIIQfl0H A-C A-C Power Power W ^ i I _1. 1 l = = l AC lACClGNDl Power Supply (126S64) I l-24l T l+24l 4 12 5 E TRANSMITTER _6 Y (Two-Wire) 7 15 M 8 16 R 9 17 input -24 10 11 Resistor 7 l 19.3,(Red Pen) 20 E 21 5 g--) 24 25 26 XJ RECORDER E-1304-156 Fig.1 - Taylor Two-Wire Transmitter and a Powe; Supply Connected to Recorder Table of Contents Installing Terminal Block and Cable.................................. I Electrical Connections.......................................... 2 Powe r Co nn ec tio ns.......................................... 6 Transmitter Connections...................................... 6 INSTALLING TERMINAL BLOCK and CABLE If the recorder is an 830J, 870J or a 930J, 970J instrument which is part of a 9160 or 9560 instrument, the terminal block and accordion cable has been installed in the housing at the factory. The following method is used when a 930J or 970J Recorder is installed in a housing by the customer. 1. Unpack recorder-slide. I N5TR UCTIO NS FO R TAYL0 R I N 5YR UME NTS 7a~ij/cr/mbumod CcmpanhJ Print iin t.s.A. HorHESTER m. NEW YOR K. t*.S.A.
IB-13A454 El:ctric l Ccnncct. ions Il15tallatl011 ' *' N3,$7NJ s A-C Power O I 2 3 4 7 5 Y 6 14 7 15 TRANSMITTER 8 _6 1 (Not Two-Wire) 9 17 + Input A-C [ E )'(p,[p,[3 7 9 Power ACC GND 21 23 v 24 25 26 RECORDER E -1304 -is 7 ( ) v Fig. 2 - Non Two-Wire Transmitter Connected to Recorder 2. Push accordion cable into housing from rear. 3. Mount terminal block on rear face of top and bottom brackets with term-inals 1, 2 and 3 at top. Retain terminal block with four #6-32 x 3/8" s c rews. 4. Install recorder-slide in housing as indicated under Installing Instrument Slide in General Components section. ELECTRICAL CONNECTIONS Befo re making any electrical connections check the voltage and frequency stamped on the data plate. The electrical connections are made to the terminal section in the rear of the housing as indicated in the connection diagram. Conduit may be connected to the knockouts in the rear of the housing. IN 5TR UCT I O NS F O R 7A Y LOR IN5YRUMENT5 P09e 2
IB-13A454 Electricci Ccnncctions 832J,C3OJ ode s A, B, C cnd D lg gllgjg A-C Power T I 2 3 4 12 5 13 TRANSMITTER A 6 14 (Two-Wire) 7 15 M 8 16 R 9 17 Signal to Recorder + Input -24 10 18 -) Resistor T la 19.I (Red Pen) 21 23 24 25 26 RECORDER Power 1 2 3 TRANSMITTER B (Two-Wiral M Tl l 12 R S 13 Sign I t Controller -24 T 7 E ) 8 16 9 7 3 18 Note: Terminot 6 on Controller i 19 is used as o Tie Point. ~ 24 25 26 I30**'O' CONTROLLER Fig. 3 - Taylor Two-Wire Transmitter Connected to Recorder { Utilizing the 24v D-C Power Supply in an 840R or 860R Series Controller, When Transmitter Supplying Signal to Controller is also Two-Wire IN 5TRUCTIO N5 F O R TA YL0 R I N5T R UMENT 5 Page 3
IB-13A454 El ctrircl Ccnnections H5fGIIGfl0H 83DJ, C3r J Mod:Is A, B, C cnd D 87oJ,97o; A-C Power 2 A I 2 3 4 12 5 7 _6 5 TRANSMITTER A l 15 (Two-Wire) 8 16 Signot fnput + Recorder d Pe ) T 20 22 21 23 24 25 26 ~ RECORDER Power I I 2 3 12 TRANSMITTER B (Not Two-Wire) Signol 5 13 5 Con roller A-C Power ACC GND [ V 10 18 18 Y 22 20 21 23 Note: Terminot 6 on Controller is used os a Tse Point. 24 25 26 O CONTROLLER t -1304 -859 Fig. 4 - Taylor Two-Wire Transmitter Connected to Recorder Utilizing the 24v D-C Power Supply in an 840R or 860R 4 Series Controller, When Transmitter Supplying Signal A to Controller is Non Two-Wire IN 57R UCT I O N S FO R TAY LO R I N 5TR UMENT5 page 4
IB-13A454 Electric 1 Ccnnections 83DJ,C3CJ ode s A, B, C cnd D lg ggllgg g ( AC Power TRANSMITTER (Not Two-Wire) } F A-C AC Power, 7_ Signal to Green or Blue Pen ACC + g 1 2 3 y 4 2 5 13 6 14 7 15 + 16 input Resistor 8 -(Green or Blue Pen) 10 1 input Resistor il 19 (Red Pen) RECORDER TRANSMITTER (Not Two-Wire) g.e304-72(H A-C f r AC Power Signot to Red Pen _ACC + 5 + ,p GND 'd y Fig. 5 - Two Non Two-Wire Transmitters Connected to 830JD2 or 870JD2 Recorder When making the input connections keep the input cable as far away from the a-c power wires as possible. Run the input cable in a separate conduit from the power wiring. The wire used to connect the instrument to the control system is not critical. Terminals 1,2 and 3 will accept wire as large as #12 and the other terminals will accept wire as large as #14. The power and alarm wiring can be #18. Other wiring can be twisted paire of #20 or #22. Normally it is not necessary to use shielded wire. IN5TRU CT I O N 5 FO R TAY LO R IN 5T R UME NT 5 Page 5
IB-13A454 Electriccl Ccnnections IN5tGIIQLION 83rJ, C3DJ Mod:Is A, B, C and O 870J,970J Power Connections C The power connections to the recorder are made as shown in the connection diag ram. 's' CAUTION: If recorder is an 830JD2, 930JD2 Models lk A, B or C or an 870JD2, 970JD2, do not turn on power to recorde r unless cable from remote amplifie r is connected to re-corder. If power is applied first and then the cable is connected to the recorder, the transistors within the remote amplifie r will be damaged. Note: All housings are wired alike. Do not try to use a recorder-slide designed for use on 117v a-c in a housing which is connected to 234v a-c. Transmitte r Connections These recorders do not have a built-in transmitter power supply. Thus, they cannot supply power to a Taylor two-wire transmitter such as a 740T 1 750T, 800T 4 ~,811T 4 ,860T 4 ~ or any 1300T series. A two- '] wire transmitier h1s only wo wires conne ie~l to it. Transmitters with two ( ~ -~ or three wires for power and two wires for the transmitted signal are not considered tw-wire transmitters. A Taylor two-wire transmitter requires a separate external 24v d-c power supply, such as Taylor Part No.124S64, to operate with the recorder. The transmitter and power supply are connected to the recorder as indicated in the connection diagrams and Fig.1. A Taylor transmitte r powered by 117 or 234v a-c, such as a 718T, 740T 2 75 2 T, 760 T, 800 T_1____, 81 1 T_1 _ o r 860T_1____ has a built-in powe r supply. This is not a two-wire transmitter. This type transmitter is connected to the recorder as shown in the connection diagrams and Fig. 2. A Taylor two-wire transmitter can be connected to the recorder and utilize the transmitter power supply located in an 840R or 860R series controller. This is shown in Figs. 3 and 4. If transmitter B, which supplies a signal to the controller, is also a Taylor two-wire transmitter, transmitter A and the recorder are connected as shown ) in Fig. 3. The power supply in the controller is capable of supplying power (' to two transmitte rs. Here, both transmitters A and B are powered by the power supply in the controller. Both transmitters are turned ON or OFF by the transmitter power switch in the controller. If transmitter B, which supplies a signal to the controller, is not a Taylor two-wire transmitter, transmitter A and the recorder are connected as shown I NSTR UCTIO N 5 FOR TAYLO R I N 5TRUME N T5 Page 6
R r O' ~ A-C Z Power MM ^ 8e m 4 e3 lacIAccicNol g 3. m c Power Supply $'g n (126S64) o l-24l T l+24l
- GO e10 s*g O
O>3 u, z ,, e ~ n n =0 AC Power g TRANSMITTER l' [3 (Two-Wire) }l m D 0 = I R n Signot to Green or Blue Pen Y I 2 3 y T 4 12 5 13 g 6 14 + T 15 ( ) 8 16 1 input Resistor 9 37 3 (Green or Blue Pen) 3 I Z input Resistor "I u TRANSMITTER (Teo-wire) 3 RECORDER g a C Signoi to Red Pen T Note. Tere.inal 15 on Recorder Q [ is used as a Tie Point. r-4304 -7 s(2 ) M W ] z m Fig. 6 - Two Taylor Two-Wire Transmitters and a Power Supply Connected to O g c y y an 830JD2 or 870JD2 Recorder 3 A
Elactriczl Ccnn ctions ^ IH5fGIIQtION 83r;, C3'2J Mod:Is A,8, C cnd O 870J,970J in Fig. 4. The transmitter power switch in the controller will control the f power to transmitter A only. ( If two "non two-wire" transmitters are connected to an 830JD2 or 870JD2 re-corder, each transmitte r is connected as shown in the connection diag rams and Fig. 5. If two two-wire transmitters and a 24v d-c power supply are connected to an 830JD2, 870JD2, 930JDZ or 970JD2 recorder, the connections are made as shown in Fig. 6. In this circu't there is no transmitter power switch to con-trol powe r to the transmitte rs. Note: If the 830JD2, 870JD2, 930JDZ or 970JD2 re-corder has alarms or a retransmitting poten-tiometer, Accessory No. 53, it may not be pos-sible to use terminal 15 as a tie point. Re fe r to the Connection Diagram. l l I O c r-I N 5TRUCT1O N 5 F O R TAYLO R I NSTRUME NTS page 8
S:cti;n IB-13A410 Issu] I General Components for Taylor Recorders 83OJa 93OJ Model D $US$YUC$ 00$ ( Table of Contents INSTALLATION OPERATION Mounting on inclined Surface 1 Input Filter 5 Installing Instrument Slide 1 Chart Read Back. .6 Chart Loading. 2 Two-Speed Chart Drive 6 Installing ink Capsule. 4 Description of Operation 6 MOUNTING ON INCLINED SURFACE is If the recorder is designed to oper- ,u ate in areas designated as Class 1, OT-' / Group D, Div. 2 by the electrical code (Electrical Code No. 2), mer-cury switches are required fo r switching. On 830J, 930J recorders with Basic Option No. 2, the one speed chart drive has one mercury s'[rII on-off switch. On 830J, 930J re-b corders with Basic Option No. 1, ( ) the two speed chart drive has three ^ ~ ' '
- mercury switches.
One switch is an on-cff switch and the other two contro1the fast and slow speed chart Fig. 1 - Mounting Angles and drive motors. Switch Adjustment When the recorder is mounted in a panel that is other than vertical, adjust the switch plate so that the mercury switches will operate. Loosen clamp screw, Fig.1, and rotatc switch plate until mounting angle is opposite index mark; tighten clamp screw. INSTALLING INSTRUMENT SLIDE 1. Pull up on cable lock, Fig. 2, 2. Reach inside housing, pull accordion cable out and plug end of cable into connector at rear of instrument slide. 3. Push down on cable lock. 4. Insert instrument slide into housing, push down on slide stop, Figs. 3 and { 4, and push rest of way into housing until front latch catches. I N5TR U CTI O N5 FO R TAYLO R iN 5TRUM E,N T5 'TcIy/cr /mhumtA/ hmpdAhd Prini.d ie t;.s. A. ROCHERTER m. NEW YOR K (J.8 A.
IB-13A410 Ocncrcl Ccmpancnts IH5fGIIGfl0H sao;, 9so; mod.i o o.'k (
- .TV..,~,~
bli'*-s,,, e 1g.::l ~~ '* e - Cable Lock
"
until chart unit is accessible. O n FA ~ V 2. Insert pencil behind chart; pull i paper to left. ] " - ~~ 3. Rewind chart by turning top of l l ] %siow speed Motor 7 rewind spindle clockwise. . ( D gart Drive TWO-SPEED CHART DRIVE j ~ l g (Basic Option No. 1) 1 mi-m.. -f A two-speed chart drive, Fig. 8, is t.2 3o4-n as an option on the 830J and 930J re-corders. Fig. 8 - Two-Speed Chart Drive The chart drive switch mounted un-der the chart drive motors has three positions "OFF", " SLOW" and " FAST". The OFF position turns off the recorder. The SLOW position turns on the slow speed motor. The fast speed motor runs when the switch lever is in the FAST position. The standard chart speeds are 1" per hour on SLOW and 1" ( \\ per minute on FAST. DESCRIPTION OF OPERATION A blockdiagram of the recorder is shown in Fig. 9 anda simplified schematic diagram in Fig.10. The recorder is actuated by a 0. 25 to 1.25V d-c signal. Any other signal serva uotor Signot Input Recorder
- nee, Amphfie 0
Pen Power l
customer C**"*"',-
i p
^**
O j
c,%"
l cnare ori,e Motor Alorm 1 Alarm
=
Alarm 2 aia,m 2
Fig. 9 - Block Diagram of Recorde r I N5TR UCT1O N5 FO R TAYL0 R I N5TRUME NT5 pnge 6 1
C
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N g
z e
e os 3 ue og PO
=
c O
n owO m3 az o
ll7V A-C 1O c
Power a g Floating 3
(
- Feedback 2
Power Supply o
+
Potentiometer O.65 u F fs C
D-C to A-C Converter
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}
}O
+0
=*
g Ampli ier en
/
G o
62.5.n.
Servo Input
- finput y
Motor
=
Resistor D
XA-1304 - 207 m
o D
e fO E
M Q
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=
i z
ZU O
t Fig.10 - Simplified Schematic of Recorder 3
y o
IB.13A410 Ocncrcl Ccmpon nts 83OJ, 93OJ Model D passes through a precision (0.17o) resistor to provide the necessary 0.25 to
- 1. 25V d-c.
The input signal appears as a one volt signal between A and D in Fig. 10. A q
floating power supply provides a voltage of one volt between A and C.
Point b
B is a sliding contact to pick off a fraction of the voltage between A and C.
The voltage between A and D is compared to the voltage between A and B by the d-c to a-c converter.
If the voltage between A and B does not equal the voltage between A and D, point E will be either positive or negative with re-spect to point A by the amount of the difference.
This difference voltage or error sigaal is amplified by the a-c amplifier and applied to the contro1 winding of the two-phase servo motor.
The reference winding of the servo motor is excited by a 60 Hz sine wave that is shifted in phase 90' from that of the control winding by the 0. 65 F capacitor.
The amplified error signal applied to the control winding causes the servo motor to drive the sliding contact B so as to reduce the error signal to zero and position the pen at the correct point on the recorder chart.
The amplifier is actuated by a positive signal if the pen po-sition is too high and negative if too low.
The direction that the servo motor must turn to obtain balance is determined by the polarity of the signalat point E.
The feedback potentiometer is geared to the se rvo motor through approximately a 20:1 gear reduction. The pulley for driving the pen is mounted on the shaft p of the feedback potentiometer. The shaft extends through the feedback poten-(
tiometer and carries the cams for actuating the alarm switches.
v AV b
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iN5YR UCT1O N5 FO R TAYLOR IN5YR UMENT5 5
P09e 8 L
S:ction IB-13A413 Scrvicina cnd Trcublo Shoctina
~
for Taylor Recorders 83OJ,93OJ Model D Mafntenance Table of Contents Removing Instrument Slide
.1 Aligning Pen Carriage
.5 Calibration.
I Replacing Amplifier Module
... 5 Periodic Servicing
.3 Replacing Servo Drive Cable
.6 Adjusting Chart Drive Clutch 4
Checking Amplifier Module
.7 Supply Spindle
.4 Trouble Shooting
.9 Rewind Spindle
.4 p.
G REMOVING INSTRUMENT SLIDE r.-
5:y ~;_d.o=.r. M iE
.-w.
7 1.
Lift up on slide handle, Fig. 1 M'Q{
and pull instrument slide out to
],~ 7 gfr~ $
E slide stop.
4 Ei9. E81 1,-.
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Push down on slide stop and re-
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Pull up on cable lock, Fig. 2.
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Unplug acco rdion cable from "4
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Handle The recorder was calibrated at the 4
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factory and should not require fur-ther adjustment.
If recalibration is necessary, use the following pro-Fig. 1 - Front of Recorder Slide cedure:
Note: The amplifier is actuated by a 0. 25 to 1.25V d-c signal.
Any other signal passes through appropriate precision (0,1%) resistors in the terminal section to provide the necessary 0.25 to 1. 25V d-c.
1.
Pull instrument out of housing to slide stop.
2.
Rotate se rvo pulley, Fig. 3.
The pen should travel approximately 1% be-low 0% and above 100% on chart.
IN5YR UCTI O N 5 F O R TA YLO R IN5TR UME NT S l
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Potent,ometer Loosen two pulley retaining screws.
Hold pulley shaft a-geinst stop with large gear be-
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y Servo Pulley hind pulley and rotate servo pul-l
/p 1ey untilpen reads approximate-l ly 1% below 0% point on scale.
Servo Pulley Tighten two pulley retaining Motor Retainir.g Screws hi i-79 W
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_m.- f 3" me a Servo idler Gear Assembly D13o4213C Fig. 3 - Servo Motor Assembly l
INSTRUCTIO NS 7OR TAYLO R I NSTRUME NTS P09' 2
IB.13A413 Sarvicing cnd Trcublo Shssting
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lMOIIIf0fIOIICO 83OJ,93OJ Model D Note: If excessive resistance is felt in rotating servo C
pulley to move pen too much friction exists in system.
This may be corrected by cleaning slide rod if it appears dirty or adjusting idler gears on servo assembly to eliminate binding.
The idler gear adjustment must be precise to avoid excessive backlash of servo gear train.
3.
Connect power to instrument terminal section.
Refer to the connection diagra m.
SWn Zero Adjustment Adiu tment 4.
Connect the approp riate input signal (refer to instrument cat-
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Refer to the
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connection diagram.
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5.
Adjustinput signalto 0% of range.
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The recorder pen should be at 0
'A Af on chart.
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Ifit is not, turn zero adjustment, n
Fig. 4 until pen is at 0 on chart.
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Q i e zero.
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6.
Adjust input signal to 100% of Q^
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4 range. The recorder pen should g[I; \\N be at 100 on chart.
- L,J Y h insulator If it is not, turn span adjust-
/
ment untilpen is at 100 on chart.
Counterclockwise adjuatment in-Fig. 4 - Amplifie r Module creases span.
7.
Repeat Steps 5 and 6 for required accuracy.
PERIODIC SERVICING The instrument requires little maintenance.
Under normal operating condi-tions, it is recommended that the following items be checked once a year. If plant conditions dictate, checks should be made more often.
1.
Clean pen slide rods on pen ca triage with solvent such as trichloroethylene.
{
Do not lubricate pen holder or guide rods.
2.
Replace any servo drive cable which may have become frayed or worn.
IN5TRUCTIO N5 FO R TAYLO R I N 5TRUMENT5 page 3
IB.13A413 Ssrvicing and Trcublo Shcsting Mau,ntenance eso.u,,som.d.n o ADJUSTING CHART DRIVE CLUTCH Adjustment of the clutches in the chart drive supply and rewind spindles is made at the factory.
If further adjustment is necessary, use the following procedure:
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Supply Spindle
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1.
Place empty chart core on supply 3
spindle and remcve black snap-in
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plug from top of spindle.
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2.
Suspend 60 grams from supply spin-L
- ~ ~
die, Fig. 5, in a direction which tends to turn spindle clockwise.
Fig. 5 - Supply Spindle Adjustment 3.
Use a 5/16" spin wrench and ro-tate adjusting nut counterclockwise until spindle rotates slowly; then, rotate nut clockwise until spindle just stops rotating.
4.
Replace snap-in plug.
Rewind Spindle
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Follow same procedure as for supply spindle adjustment except in Step 2 Suspend 60 grams from rewind spindle in a direction which tends to tuta spin-die counterclockwise.
Ink Capsule Pen Carriage
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Pen Carriage Pen Carriage
\\ Pen Carriage Mounting Plate P n Lif ter Mounting Screw Adjusting Screw E 1304 213A Fig. 6 - Adjustments on Pen Carriage IN5TRUCTl C NS FO R TAY LO R I NSTR UME NT5 Poge 4
IB-13A413 Sarvicing and Treublo Shocting 83OJ, 930J Model D Mainternatice "w
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Fig. 7 - Replacing Amplifier Module ALIGNING PEN CARRIAGE The pen carriage should be aligned so that the pen will track a chart time line.
This is accomplished by raising or lowering the rear of the mounting plate, Fig. 6.
1.
Pull slide forward so that pen carriage is accessible.
2.
Rotate chart advance wheel until pen is on fine time line.
3.
Looren mounting screw and turn adjusting screws until pen tracks time line when servo pulley is rotated.
4.
Refer to Calibration, page 1.
Zero instrument as described under this procedure.
l REPLACING AMPLIFIER MODULE I
1.
Remove instrument slide from housing.
l 2.
Amplifier module is held onto instrument slide by module retainer, Fig. 7.
I l
IN5TRUCTI O NS FO R TAYLO R I NSTR UME NT5 Page 5
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IB-13A(i Scryicing cnd Troubb Shecting Mas,ntenance
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Length of Cable Instrument (inches) 830JDI, 930JD1 with 1 or 2-speed chart drive 19-1/8" 830JD2, 930JD2 with 1-speed chart drive 19-1/8" (Red) 16-9/16" (G reen) with 2-speed chart drive 19-1/8" (Red) 16-15 /16" (Green)
Fig. 8 - Length of Servo Drive Cables Pull module retainer toward rear of instrument slide and unplug a nplifier module from instrument slide.
3.
Plug new amplifier module into connector on instrument slide. Push module retainer toward front of instrument slide to retain amplifier module in pla c e.
REPLACING SERVO DRIVE CABLE
(
The correct cable for each servo can be identified by its length. Refer to Fig.
8.
1.
Remove old cable and spring from servo pulley and pen holder.
Upper Guice Pulley
/
O Longer Length of Coble Clutch Plate Screws g
Servo Pulley fu$
3 um.
Co.ie uo,ch*Pune,,
j
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i Pen Holder Cable Spring
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o Shorter Length of Cable
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l Lower Guide Pulley Fig. 9 - Diagram of Servo Drive Cable l
l IN5TRUCTIO N5 FOR TAYLO R I N5TRUME NT5 l
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IB-13A413 5:rvicina cnd Trcubla Shcztina
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sao;,,so; moaer o Mam, tenance 2.
Rotate se rvo pulley until its ca-ble notch is at 9 0' clock position, Fig. 4.
1 1
3.
Feed spring loop through lug in end of new cable, i
.. m.
4.
Extend cable and note that one length, measured from knot to Fig. 10 - Cable Spring Attached spring, is longer.
to Pulley 5.
Attach cable spring to pin on pulley and extend cable through notch, Fig. 5.
6.
Wind longer length of cable once around pulley in counterclockwise di-rection; position cable on upp. r guide pulleys at servo and pen slide rod; manually raise pen holder and slip knot into notch on holder, Fig. -i.
7.
Wind shorter length of cable once around pulley in clockwise direction; pass cable back through same notch and hold in place while cable is posi-tioned around lower guide pulley at servo.
8.
Carefully pu11this length of cable so cable spring is extended and position
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cable under lower guide pulley at pen slide rod.
v 9.
Refer to Calibration, page 1.
CHECKING AMPLIFIER MODULE There are test points on the back of the amplifier circuit board.
For access to these test points, remove four screws holding insulator, Fig. 4, to ampli-fier module.
Check the waveforms with an oscilloscope connected betweenthe test point and circuit common (use terminal 4 on the servo motor) as indicated below.
Test Point TP5 This is the output signal from the operational amplifier.
The normal wave-form consists of a small amount of noise (approx 2V p-p) at balanca and a square wave going plus (+) and minus (-) approx 12 to 15V when the recorder
\\
is forced off balance by manually turning the servo pulley.
l l
If the waveform at TP5 is correct, check the waveform at TP11. If the wave-(
form at TP5 is not correct, proceed as follows:
1.
Check +15V and -15V power supplies. Voltage should be 15V AS%.
I N5TRUCTIO N S FO R TAYLOR I NSTRUME NT5 page 7 l
IB-13A413 Scrvicina cnd Treubb Shaeting i
Maintenance 8302,930; modei o 2.
If voltage at TP5 is saturated at +15V or -15V, check C2 and R11. If C2 and R11 are ok, replace operational amplifier A1.
This type af failure
(-
may cause output transistor Q3 or Q4 to burn out.
/
3.
If waveform is a constant square wave or does not change as indicated
\\]/
~-
above when recorder is unbalanced, check waveformat gate of Q1 and Q2.
If Q1 or Q2 is shorted, its gate waveform will be affected. Replace Q1 or Q2.
4.
If waveform shows a high frequency oscillation, check C2, C3, C4, C9, Cll, C17, C18, R9, R10, R11 and R16. Replace defective component.
Note: A quick check for an open capacitor is to short it with a good capacitor and check if symptoms dicappear.
5.
If waveform is smaller than normal, amplifier gain may be too low due to defective A1, Q3, Q4, R10, R11 and R16. Replace defective component.
Test Point TP11 The normal waveform at TP11 should be nearly sinusoidal with a peak to peak value of approximately 300V when the recorder is forced off balance by man-r ually turning the pulley.
(
If the waveform at TP11 is correct, but servo motor does not run, is sluggish or has low torque, check for a bad connection at the servo motor, a defective servo motor or a defective capacitor C10. Replace defective component.
If the waveform at TP11 is not correct, check D17 thru D20, Q3, Q4 and T2.
Replace defective component, f\\
h I~N 5 T R U C T I O NS FO R TAYLOR I N 5TRUME NTS Page 8
IB-13A413 Scrvicina cnd Trcubb Shoctina 83OJ,93OJ Model D Mam, tenance TROUBLE SHOOTING
(
PROBLEM POSSIBLE CAUSE ACTION TO BE TAKEN Pen does not move
- a. No power to instrument
- a. Turn on power. Check luses in when input signal powe r panel, changes
- b. Switch 51 on accordion cable
- b. Check switch St. Replace if is open or defective necessary.
- c. Electrical connections are
- c. Refer to Electrical Connections incorrect Section and Connection Diaeram
- d. Pen holder loose on servo
- d. Check for correct installation.
cable Refer to Replacing Servo Drive Cable.
- e. Defective amplifier
- e. Refer to Checking Amplifier Module
- f. Defective servo motor f.
Replace servo motor
- g. No input signal
- g. Check transmitter and transmission line Pen will not travel
- a. Incorrect input signal
- a. Check input signal over 100% of chart
- b. Instrument out of calibration
- b. Recalibrate. Refer to Calibration.
- c. Servo cable incorrectly
- c. Check for correct installation.
installed Refer to Replacing Servo Drive Cable.
- d. Pen holder stuck on slide rod
- d. Clean rod if dirty; replace if bent
- e. Servo pulley positioned
- e. Correct positioning. Refer to incorrectly Calibration.
- f. Servo pulley retaining screws
- f. Tighten screws. Refer to loose Calibration.
- g. Servo idler gear assembly
- g. Adjust idler gears
- x binding
[
)
s _e When input signal
- a. One-half of secondary
- a. Replace transf armer Tl changes, pen moves winding of transformer Tl in one direction only is open. (winding connected to D17 thru 20)
Pen motion not smooth
- a. Pen hcider or slide rod dirty
- a. Clean rod if dirty; replace if or bent bent Pen motion is sluggish
- a. Defective amplifier
- a. Refer to Checking Amplifier Module Insufficient calibration
- a. Defective component in
- a. Replace defective component adjustment reference voltage power supply Pen chatters or
- a. Noise in input signal
- a. Increase input filtering oscillate s
- b. Defective feedback
- b. Replace feedback potentiometer poter.tiomete r
- c. Excessive backlash in servo
- c. Adjust servo idler gears gear train
- d. Amplifier ga;n too high
- d. Check RIO,11,16 or C2 on on amplifier module. Replace if necessary.
- e. Defective output transforme r
- e. Replace catput transformer T2
- f. Defective input filter capacitor
- f. Replace capacitor Cl2
- g. Defective compor.ent in d-c to
- g. Replace defective component a-c converter
- h. Defective arnplifie r
- h. Refer to Checkinc Amplifier Module Pen position drifts
- a. Defective transistor Q1 or Q2
- a. Replace defective component in d-c to a-c conve rte r d
[NSTRUCTIO NS FO R TAYLOR I N STR UME NTS Po9e 9
l IB-13A413 53rvicing cnd Treubb Shoctina Mam, tenance s a o;,,s o; m oa.i o Pen does not write
- a. Ink capsule empty or no
- a. Install new ink capsule capsule on pen
- b. Pen clogged or installed
- b. Clean pen or install correctly incorrectly
(%
- c. Pen not contacting chart
- c. Check for correct installation.
Replace contact spring or guide rod if reauired.
Pen does not follow
- a. Pen carriage out of alignment
- a. Align pen carriage. Refer to time line Aliening Pen Carriaee.
Chart does not advance
- a. Power off, no power supply or
- a. Check power supply and voltage voltage incorrect
- b. Chart drive belt is off pulley
- b. Replace belt
- c. Chart drive motor defective
- c. Replace motor Chart advances too
- a. Rewind clutch too tight
- a. Adjust clutch. Refer to Adjusting fast Chart Driv s Clutch.
Chart bulges on roll
- a. Rewind and/or supply roll
- a. Check installation of chart roll.
or slips off drive pins installed incorrectly Refer to Chart Loading in General Comoonents section.
- b. Rewind and/or supply clutch
- b. Adjust rewind and/or supply clutch.
too loose Refer to Adjusting Chart Drive Clutch.
Chart perforations
- a. Supply clutch too tight
- a. Adjust clutch. Refer to Adiusting tear Chart Drive Clutch.
Chart does not wind
- a. Rewind clutch too loose
- a. Adjust clutch. Refer to Ad.insting tight on rewind roll Chart Drive Clutch.
Rewind spindle wobbles
- a. Normal condition. This provides self-alignment of cha rt.
i i
l l
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i I N5TRUCTIO N5 FO R TAYLO R I N5TRUME NTS page 10 s
IB-13A413 Ssrvicing and Trcublo Shesting 83OJ,93OJ Mode! D OfeS k
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k I NSTRUCTIO NS FO R TAYLOR INSTRUMENTS page 11 l
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IN5TRUCTIO NS FOR TAYLOR I NSTRUME NT5 5
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N ! a b \\ ~ jV ,iv] l l WARRANTY WATtRANTY Taylor instrument Companies (h'ereafter "Toylor") warrants the equipment manufactured by it to be free from defects in material and workmanship. Upon return, transportation charges prepaid to Taylor's factory, within one year of original shipment, Taylor will rerair or replace, at its option, any equipment which it determines to contain defective n.:+erial or workmanship, and will return said equipment to purchaser, f. o.-b. Taylor's factory. Taylor shall not be oblig-ated, however, to repair or replace equipment which has been repaired by others, obused, improperly installed, altered or otherwise misused or damaged in any way. Taylor will not be responsible for any dismantling, re-assembly or re-installation charges. This warranty is in lieu of all other warranties, express or implied. Taylor shall not be liable for any special, indirect, incidental or consequential damages, including damages claimed in connection with any rescission of this agreement by Purchaser. m -( \\ i q V FACTORY WARRANTY FACTORY SERVICE WARRANTY Taylor warrants the parts, components or instruments manufactured by Taylor and supplied in the performance of factory service (hereafter called " replacement product"), to be free from defects in material and workmanship. Upon return, transportation charges pre-poid to a Taylor factory, within one year of Taylor's shipment of said replacement product to Purchaser, Taylor will repair or replace, at its option, any of said replacement product which it determines to contain defective material or workmanship. Taylor will return said replacement product to Purchaser, F. O. B. Taylor's Factory. Taylor shall not be obligated, however, to renlace or repair any of said replace-ment product which has been repaired by others, abused, improperly instnlled, altered or otherwise misused or damaged in any way. Taylor will not be respon-sible for any dismantling, re-assembly or re-installation charges. Although Taylor will endeavor to restore to operating condition goods to be processed in accordance with a factory service agreement, it cannot warrant the effectiveness of such processing performed by it except as specifically provided for herein with respect to replacement equipment. This warranty is in lieu of all other warranties, express or implied. Taylor p shall not be liable for any special, indirect, incidental or consequential damages including damages claimed in connection with any rescission of a factory service h agreement by Purchaser. /m j t ] . v 0 t
0 [ HOME OFFICE AND MAIN PLANT 4 ./ ROCHESTER, NEW YORK 14601, U. S. A. BRANCH SALES OFFICES AKRON, OHIO CL EVEL AND. OHIO PITT3 BURGH. P A. l
- ATLANTA.GA.
DALLAS, TEXAS RICHMOND, VA. BOSTON, AREA GREENSBORO.N.C. ROCHESTER,N.Y. N EEDH AM, M ASS. HOUSTON TEXAS ST. LOUIS, MO. BUFFALO,N.Y. LOS ANGELES. C ALIF.
- SAN FR ANCISCO AREA CHARLOTTE,N.C.
MINNEAPOLIS AREA SAN LE ANDRO, CALIF.
- CHICAGO AREA HOPKINS. MINN.
SCH EN ECT ADY, N. Y. O AK P ARK, ILL. N EW YORK, N. Y.
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' CHICAGO HEIGHTS, ILL. PARAMUS.N.J. WILMINCTON, DEL. CINCINN ATI, OHIO PHIL ADELPHI A. P A. RESIDENT SALES REPRESENTATIVES AM ARILLO, TEXAS INDI AN APOLIS, IND. ST. PETERSBURG,FLA. BALTIMORE, AREA K AL AM A ZOO. MICH. SALT L AKE CITY, UTAH ELLICOTT CITY, MD. K ANSAS CITY. MO. SAVANNAH,GA. BATON ROUGE, L A. KNOXVILL E, TENN. SEATTLE, WASH. BEAUMONT, TEXAS LOUISVil 1.E, KY. SOUTH CH ARLESTON, W. VA. BIRMINGH AM, AL A. MIDL A,g o, MICH. SPRINGFIELD, MA SS. COLUMBUS, OHIO MIDL AND, TEX AS SYRACUSE. N. Y. CORPUS CHRISTI, TEX. MILW AUK EE, WIS. TOLEDO AREA DEARBORN, MICH. MOBIL E, AL A. PERRYSBURG, OHIO DENVER,COLO. MONROE.LA. TUCSON, ARIZ. = DES MOINES, IOWA NEW ORLEANS L A. WICHITA AREA GREENVILL E, S. C. PORTLAND.OREG. AUGUSTA, K ANSAS SUBSIDIARIES TAYLOR INSTRUMENT COMP ANY ( OHIO) INC.: TAYLOR INSTRUMENT COMP ANIES OF AUSTR ALI A PTY. LIMITED:
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31,611 [,-Suet 1 BY MS. BERNABEI: (Continuing) / \\' ~ ~ ' ' 2 Q Okay. Did you find that, sir? 3 A Yes. 4 Q Okay. Now, there is -- is there a correspond-lh 5 ing dip on the narrow range recorder on Strip Chart B, 6 the one you have before you? 7 And I would refer you slightly after, closer 8 to midnight. 9 A It's not noticeable if there is a dip 10 there. 11 Q Okay. Let me back up for a minute. On Strip 12 Chart B, the upper pin, the narrow range recorder appears ,m 13 to be running somewhat behind the lcwer range one; is 14 that correct? 15 If you look at the pressure spike, perhaps l 16 it would be easier to determine that. 1 17 A Yes, that is correct. 18 Q Okay. So I would presume that something which l 19 appears shortly before midnight may be son.ewhat delayed l 20 on the narrow range and be approximately midnight on the 21 narrow range; is that correct? [~l 22 A Well, it could be approximately midnight. x / 23 Q Okay. And did you note, or can you see, on ) 24 the narrow range on Strip Chart B a slight dip at or AA_2 Reporters, inc. 25 around midnight?
31,612 (73-Suet 1 A Yes. ~ 2 Q Now, I would like to refer you to the Strip 3 Chart A; that is, the other reactor building pressure strip -/T V 4 chart you have before you. W 5 JUDGE SMITH: Which one is -- we have been 6 discussing now -- Exhibit 41 is Strip Chart A? 7 MS. BERNABEI: That's correct. However, the 8 portion that we are referring to is not before you. We 9 are obtaining copies for the Board. I apologize. 10 JUDGE SMITH: I'm sorry. 11 MS. BERNABEI: The portion of the strip chart 12 that Mr. Briti has been testifying about is not before [,, \\ g V 13 you. T 14 JUDGE SMITH: I know. 15 MS. BERNABEI: Okay. That is -- though he 16 has been calling that Strip Chart B. 17 Okay. We do have copies of this. I would I 18 propose this be TMIA Exhibit 42. l 19 (Ms. Doroshaw is distributing copies to 20 the Board members and the parties.) 21 JUDGE SMITH: All right. lT 22 (The document referred to is 9 v 23 marked as TMIA Exhibit Number f EXXXXX 24 42 for Identification.) Ace ~ 3 Reporters, Inc. 25 BY MS. BERNABEI: (Continuing) l
31,613 [~ 3-Suet 1 Q Mr. Brill, if you can, can you refer to 'N~- 2 the approximate time on Strip Chart A and determine if 3 there is a corresponding dip at that time; that is, at /ss 4 or near midnight for the narrow range and wide range h 5 recorders on Strip Chart A? 6 (The witness is looking at the document.) 7 A Looking at Strip Chart A, there doesn' t appear 8 to be. 9 Q There does not? 10 A No. 11 Q Okay. Now, your testimony on Page 3, and I 12 will try to summarize it if I can, is that one would I \\ O (,/ 13 expect a corresponding dip in both recorders on Strip W 14 Chart A and recorders on Strip Chart B if that dip were 15 caused by a pressure event; is that correct? 16 A That is correct. 17 Q Now, if the -- if it were caused by something 18 other than a pressure event, such as the disturbance of 19 the paper one would not see the dip in both Strip Chart A 20 and Strip Chart B; is that correct? 21 Because it wouldn't be caused by a pressure s l _) 22 3ensor, it would be caused by a disturbance of the paper. 23 A That's possible. f) ( ) 24 Q It's possible. Ace ~do Reporters, Inc. 25 JUDGE SMITH: Possible what, that you would not
l 31,614 ( x]-Suet 1 or would? \\.s/ x 2 WITNESS BRILL: Would you repeat the question? 3 BY MS. BERNABEI: (Continuing) g3 (_) g 4 Q Sure. Your testimony is that if a pressure 5 event or a pressure excursion caused a dip in Strip Chart A, 6 it would cause a similar dip in Strip Chart B; is that 7 correct? 8 A That's right. 9 Q Okay. So, following from that reasoning, if 10 there were a dip in one chart but not in the other the 'I conclusion would be that it was not caused by a pressure 12 excursion. 7s s_/ 13 A It's possible that it was not caused by a \\ 14 pressure excursion; that's correct. 15 Q Okay. And -- 1 16 JUDGE SMITH: What does that tell us? 17 MS. BERNABEI: At a minimum -- well -- okay. i 18 BY MS. BERNABEI: (Continuing) 19 Q At a minimum, you would know that two pressure 20 sensors; that is, the two pressure sensors for Strip Chart inthiscase,werenotpickingupthepressureexcursion;f 2I A, /~ (, _T / is that correct? gg 22 23 A I don't think I follow that question. [D 24 i ) Q Okay. You have told us that there are two s Ace +,_id Reporters, Inc. 25 pressure sensors for each --
I l ~ 31,615 [ 'J-Suet 1 A Right. Qj 2 0 -- chart? 3 A Right. sb 4 0 Okay. And each pressure sensor corresponds to W 5 a recorder, either the narrow range or the wide range 6 recorder on each chart. 7 A That is correct. 8 Q So there is four independent pressure sensors; 9 is that correct? 10 A That is correct. 11 Q Now, what I'm talking about is a hypothetical 12 to you based on facts we have. If you were to find one b sm,/ 13 strip chart, Strip Chart B, had certain dips on both the 14 narrow range and the wide range, and the other one did not, 15 one would assume that in fact the dips -- one would have 16 to conclude that the dips were not caused by a real l 17 pressure excursion? 18 A That's not necessarily true, because there is 19 four transmitters in the -- that go along with these 20 strip charts, okay. Two transmitters per each strip chart. 21 If there is a slight variation in pressure () 22 that one transmitter would pick up and these dips, as you ggg 23 note, are very slight, and the other transmitter might not (p) 24 quite see that it is possible that you could have a Ace. al Reporters, Inc. 25 pressure change due to the accuracy of the loop at that l
31,616 [ l-Suet l time or whatever, and a slight dip in one tape and not the x__,/ 2 other tape, and not see that. 3 ,c3 Q Okay. But the most -- if I can term it U g 4 this way, the most probable explanation is that it was 5 not caused by a pressure excursion, the dips in one chart? 6 A I can't really say that. 7 0 Okay. Let me ask you this. 8 JUDGE LINENBERGER: Excuse me. I apologize 9 for the interruption, but one thing that is left dangling IO here is, your mention of transmitters I understand but II it is also my understanding that these transmitters are 12 reacting to something they receive from a transducer placed 7~y ( ) e (j 13 somewhere in the containment building. I4 WITNESS BRILL: Yes, sir. 15 JUDGE LINENBERGER: Each transmitter reacting i 16 to a transducer. Now, without pinning down whether the I7 transducers are located close together, far apart, or 18 whatever, I have difficulty with the previous line of 19 questioning. 20 Are you in a position to explain to us how l 21 the pressure pick up transducers, or where they were locatedrelativetoeachothersothatthislastdiscussiong 22 23 about one chart showing a pulse and another chart not (, ) 24 showing a pulse can be put into some kind of perspective? Ace. ./d Reporters, Inc. 25 WITNESS BRILL: No, I do not know at this time
31,617 l J.0-Suet 1 where those -- <_./ 2 JUDGE LINENBERGER: Where the transducers were 3 located? Okay. U,m. g 4 Let me ask you the following question. If I 5 propose to you that the two transducers were located, let's 6 say, on opposite sides of the reactor building, would you 7 in all cases expect a trace from one transducer to identi-8 cally mimic the trace from the other one? 9 WITNESS BRILL: Normally very close to that 10 trace, possibly slight differences, very slight, if any. II JUDGE LINENBERGER: Thank you, 12 BY MS. BERNABEI: (Continuing) m ) v' I3 Q Okay. Mr. Brill, it is true, is it not, Id that four strip chart -- now I'm talking about gross 15 pressure excursions, the pressure spike was recorded on 16 the -- on both the narrov range and wide range on Strip I7 Chart B, which is TMIA Exhibit 40 and on the wide range 18 for TMIA Exhibit 4 0, which is Strip Chart A. I9 41, which is -- excuse me, 42, which is 20 Strip Chart A. 21 JUDGE SMITH: No. 41 was Strip Chart A. oQ 22 MR. GOLDBERG: I think we ought to have the 23 witness identify which one is which, because it's certainly l l 24 not clear. Am,. 3' Reporters, Inc. s MS. BERNABEI: 41 is Strip Chart B.
31,618 [ ).1-Suet I MR. GOLDBERG: Well, let's ask the witness \\ / %j 2 which one is 41 and which one is 42. 3 MS. BERNABEI: Okay. I can do that, Mr. s N.] 4 Goldberg. Thank you. 5 BY MS. BERNABEI: (Continuing) 6 Q Mr. Brill, the reactor building pressure strip 7 chart that you referred to as Strip Chart B has both the 8 wide range and the narrow range recording of the pressure 9 spike; is that correct? 10 A .That is correct. II Q And that is what was the first chart distribut-12 ed, that was TMIA Exhibit 41; is that correct? ,s 13 A When you say TMIA Exhibit 41, I don't know -- ~- Id Q Okay. 15 A Okay. That is correct. 16 Q Okay. And what you have been referring to 17 as Strip Chart A is the one with only the wide range 18 recording of the pressure spike; is that correct? 19 A Strip Chart A has a wide range recording and 20 a narrow range recording. I 21 Q Of the pressure spike itself? l i r^s (_) 22 A Which pressure spike are you referring to? ggg 23 Q The one that occurred at 1:50 p.m. on March p k ) 24 28th. Ace u Reporters, inc. 25 A 1:50 p.m. Yes, it has a wide range variation,
31,619 [ 12-Suet 1 but the narrow range variation is for some reason not all i / N._/ 2 there. 3 Q Okay. And I can represent that is TMIA Exhibit 7s () 4 42, the second chart that was distributed. 5 A I don't -- 6 JUDGE SMITH: And that being which channel? 7 MS. BERNABEI: There are two channels on both, 8 Channel A and Channel B. 9 JUDGE SMITH: Yes. 10 MS. BERNABEI: It's called Strip Chart A in II his testimony. 12 JUDGE SMITH: Well I think I'm going to have ,~.s 13 to back up and get my terms right, because I understood N~s 14 that there is a Channel A and a channel B. 15 MS. BE RNABEI: Correct. i 16 JUDGE SMITH: And you started talking about l 17 Strip Charts A and B, and I thought you were talking about l 18 the strip chart which was produced respectively by Channel 19 A and Channel B. 20 MS. BERNABEI: No. l 21 JUDGE SMITH: But now you seem to be talking ((~) 22 about somethi ng else. ggg 23 MS. BERNABEI: I'm trying to follow the ,m ) 24 witness' terminology. And he -- Acs%d Reporters, Inc. 25 BY MS. BERNABEI: (Continuing) l
31,620 ~ ~ ' / l 13-Suet,' Q Mr. Brill, you have been using Strip Chart'A ,/ t 2 and Strip Chart B; is that correct? 3 I. That is correct. gsC) g 4 Q Okay. Strip Chart B is the first one we spoke W 5 about which is TMIA Txhibit 41. 6 A Strip Chart B that is identified in my testi-7 many is thn strip chart in qufstion, the one that was J 8 cut and taped back together. V Q The one -- right. And that's TMIA Exhibit 9 10 41, II JUDGE SMITH: Well, wouldn' t it really be 3 A 12 nice if we had consistency between the channels and the 7-~3 I g \\_,/ 13 strip charts produced in each channel? I mean, the way f 3 you have it now you are going to have Chan'el B producing. Id n hannel A producing St2ip Chart B, for 15 Strit ha) ^ 16 no probati at I can,see. I7 tst the record is unclear about that, l~ I8 n I agree, but I'm trying to I9 follow th. st mc wa: not I who made -- I would ? ave done it ditfer. .y. ' But this is not - 'I' did not 20 h 2I compile this. (n_) 22 JUDGE SMkTH: Well, let's take a break and '23 read his testimony. I want to see if I can understand s / k ) what has happened. Right now, hot only am I confused Ahmal Reporters, Inc. 25 about what strip chart -- I think that you misspoke in h N ______-_____--.___-__-_-__-____________A
31,621 l 14-Suet I response to one of my questions about which one it is. 1 / \\___/ 2 And I want to refresh my memory as to his testimony to 7-3 see how your questions seem to be following it. O g 4 MS. BERNABEI: Okay. We have now copies of 5 the full extent of the strip charts. What I would propose 6 is that we distribute those and take a break and try to 7 identify which strip chart goes with his testimony. 8 JUDGE SMITH: Let me ask you, you said in 9 your testimony that you had two channels, A and B? 10 WITNESS BRILL: That's correct. II JUDGE SMITH: And each channel produces its 12 own strip chart? ( ) (Il 13 WITNESS BRILL: That is correct. x-- 14 JUDGE SMITH: And each strip chart has a low 15 and high tracing? 16 WITNESS BRILL: That is correct, I7 JUDGE SMITH: Now, could I ask, just for the o 18' purpose of keeping the testimony consistent that when you a I9 talk about Strip Chart A, it be the strip chart that is 20 produced by Channel A and when you talk about Strip Chart '2fl B -- you are the one that gave them these labels. And ,mk) 22 that when fou talk about Strip Chart B, you know, just ggg '23 for neatness, that be the Channel B chart. (p) MS. BERNABEI: That's fine. And I would then Am J piponen, Im,; 25 h represent that Strip Chart A if TMIA Exhibit 42, and ( I \\ i -~__
31,622 I /
- 5-Suet Strip Chart B is TMIA Exhibit 41.
\\'y.,,' 2 JUDGE SMITH: And that's consistent with what 3 I just said. ,s ) Q,~ 4 MR. BLAKE: Now, I need a break after that 5 last statement. 6 JUDGE SMITH: All right. Just one second. 7 It is -- the strip chart produced by Channel B, is that 8 the one where you can see the pressure spike on both 9 tracings at 1350 approximately? 10 Is that it? Is that the one? II WITNESS BRILL: Okay. The -- yes. I2 JUDGE SMITH: You are 1 coking at the actual ,s N._ / 13 chart. 14 WITNESS BRILL: Yes. I am. And we are refer-15 ring to that as Strip Chart B, that you are referring to. 16 JUDGE SMITH: Right. I7 WITNESS BRILL: Okay. The pressure spike or 18 dip that was indicated in my testimony is identified as I9 occurring at between 12:45 and 1 a.m. on March 29th. 20 MR. BLAKE: Judge Smith, could -- 2I JUDGE SMITH: You want a break? O i, / MR. BLAKE: No, I don't think I need it. Did g 22 23 you just confirm that Exhibit 41 is Channel B, which is eal Reporters, Inc. 24 the one that shows on both tha narrow and wide ranges Am-25 the spike?
j 31,623 6-Suet 1 JUDGE SMITH: Yes. I think that is what we 2 have confirmed. 3 MR. BLAKE: All right. O e END #4 4 Marh flws 5 6 7 8 9 10 11 12 13 14 15 16 17 18 r 19 20 l l 21 0 e. 22 23 24 Acab ml Reporters, Inc. 25 i
31,624 MS. BERNABEI: Judge Smith, we now have copies /~~'yS-1 j / 2 that extend for the time period in question of TMIA Exhibit 3 41. S I w uld just propose that we distribute those at this (3 h
- time, 4
JUDGE SMITH: What is this, a substitution? 5 MS. BERNABEI: That is correct. 6 (Pause while copies are distributed to the Board 7 8 and parties.) JUDGE SMITH: We are just simply making a 9 10 substitution here, and I am going to throw away your first 11 one. That will no longer be of any value. The second one 12 continues on and contains a bold legend " Microfilmed" as compared l ,r 3 ) to the first one which does not. At about 11 p.m. it says h 13 14 microfilmed. 15 MS. BERNABEI: That is TMIA Exhibit 41. TMIA 16 Exhibit 42 is the one which does not.contain such a legend. 17 JUDGE SMITH: Would you repeat that? l ja MS, BERNABEI: Okay. Strip Chart B, or the channel 19 B strip recorder is TMIA Exhibit 41, which bears a large 20 " Microfilmed" legend at approximately 11 p.m. 21 JUDGE SMITH: You may proceed. f') 22 CROSS-EXAMINATION (Resumed) g U 23 BY MS, BERNABEI: 9ed Reporters, Inc. 24 Q Mr. Brill, just to clarify, it is true that Ace-25 assuming the sensors are operating cm rectly, a real pressure
31,625 ,m., ( l5-2 1 excusion would be recorded on the wide and narrow range of \\ / w/ 2 TMIA Exhibit 41 as well as the wide and narrow range of TMIA 3 Exhibit 42? 4 A That is correct. 5 JUDGE SMITH: May I ask that when you refer to 6 these exhibit numbers, because of the confusion we have been 7 having, give both designations. 8 MS. BERNABEI: Strip chart A or B? 9 JUDGE SMITH: Yes. Refer to the exhibit number 10 and the strip chart designation. Il BY MS. BERANBEI: I2 Q And it is your testimony that the dips which (s\\~_)' e 13 you found on the narrow range and wide range strip chart B 14 at approximately 12 p.m. you did not find on the wide and 15 narrow range recording for strip chart A, TMIA Exhibit 42? I A I did find a dip in both. 16 l i 17 0 I am talking now for the.2 p.m., the 12 p.m. l t i 18 time period, the midnight time period on TMIA Exhibit 41 l 19 strip chart B, not the ones you referred to in your testimony, 20 but the ones I pointed you to. 21 A That is correct. l ) 22 Q And for strip chart A, TMIA Exhibit 42, you did h '~' 23 not find corresponding dipe at that time? ,-ss ( ') 24 AS _h Reporters, ane. A The narrow range was not printing at that time 25 and for the wide range there is no dip shown.
31,626 j5-3 1 Q Now you are referring to 12 midnight? TMIA Exhibit V 2 42, strip chart A, at least our copy does indicate that the 3 narrow range is printing at that time, at or around midnight. O, s Youareta'kingaboutstripchartg 4 A Nait a minute. 5 A now? 6 Q Right. 7 A That is correct. I was looking at 12 noon. 8 Q Okay. At 12 midnight there is no corresponding 9 dip at or near that time for either the narrow range or wide 10 range; is that correct? II A On strip chart A? I2 Q That is correct. s xs' 13 A There is no dip on strip chart A either at the 14 wide range or narrow range. l 15 JUDGE LINENBERGER: Ms. Bernabei, one problem the l l 16 Board is having is, at least as I view your two exhibits, 41 I I 17 and 42, I see no dips period corresponding to midnight on 18 either exhibit for either channel of recording. 19 Now should these exhibits show those dips? 20 MS. BERNABEI: It does not chow up on the copy. 21 That is why we are having Mr. Brill identify the dips on the r^s (_) 22 original, and that is his testimony that there was a dip. ggg 23 What I would propose is that perhaps Mr. Brill n ( j 24 mark a copy, or mark the Judge's copy and the record copy Am. __.:: aenorms, inc. 25 of those dips. His testimony is there was a dip on both the
31,627 em5-4 narrow range and wide range of strip chart A, TMIA Exhibit j 41 at or around midnight and shortly before and there were 2 3 none in strip chart A, TMIA Exhibit 42. n MR. GOLDBERG: Ms. Bernabei just misspoke. Exhibi h 4 5 41 is strip chart B. MS. BERNABEI: Okay. There were dips in strip 6 chart B, TMIA Exhibit 41. There were not such dips at that 7 time on strip chart A, TMIA Exhibit 42. 8 JUDGE SMITH: All right. Why don't we look at 9 10 them right now. Let's walk over and look at them. 11 MS. BERNABEI: That is Mr. Brill's testimony, 12 however. , - ~. (The Board and parties walk over to the witness k k~_j 13 14 table and review the charts just referred to.) 15 (Recess.) 16 JUDGE SMITH: I would like to talk about what 17 I see here, point out to other Boad members what I see and 18 just have a roundtable discussion of it. I suppose it should 19 be transcribed. I don't'know how else to approach it. I see things that I don't know if my colleagues see them and 20 21 I don't know if you see them, but I would like to describe f) 22 what I see and let Judge Linenberger describe what he sees g v 23 and Judge Wolfe and just approach it that way. (n) 24 We are not boing to be able to get Xerox copies s Am ~__,.J Reporters, Inc 25 which demonstrate what I believe is your point. I don't think
l 31,628 /'~ N 5-5 1 it is possible. ~J 2 One alternative is to see if we can get a higher -) resolution photograph. I don't even know if that is possible 3 v g 4 or practical under the circumstances. I propose that to W 5 preserve the point that this be a physical exhibit in the 6 proceeding with a proviso that the licensee would keep custody 7 of it and be required to produce it if required when required 8 upon appeal and in any court review if necessary. I think 9 that probably is the most practical way. 10 I really don't think it is going to be practical II or pessible to capture the points that you are making in 12 an exhibit, a duplicating or reproduction type exhibit. !q i 13 MS. BERNABEI: Well, 1 agree, Judge Smith. I w. I4 think the only thing I could suggest would be that perhaps 15 the witness could circle the anomalies or the dips that 16 we have been speaking about on a copy and that could be 17 reproduced for all the parties. 18 JUDGE SMITH: That would be satisfactory as 19 showing the time. 20 MS. BERNABEI: That was my suggestion. But it 21 is not going to show the amplitude. I think we should /~T 'j 22 gather around that strip chart and I would like to say what g 23 I saw there and put it in the record and then you can comment ('s ( ) 24 on it, and the same with my colleagues on the Board. A d.s._la nepon m inc. 25 MS. BERNABEI: Okay.
31,629 "4m 5-6 ') I (The parties and the Members of the Board gather / l 2 around the strip chart.) l (^3 JUDGE SMITH: Now where is the point? I have 3 V 4 lost it. Oh, it is on this one up here. What see at some-5 time priorito 12 midnight, say sometime after 11:30 but prior 6 to 12 midnight, I see a slight dip below the lowest line on 7 the chart at the lower level, the dip being abrupt and 8 approximately the width of the tracing. 9 Somewhat later at the high-level recording I see 10 a dip not quite the breadth of the tracing, about half the II breadth of the tracing. I2 I also, however, see as I look at other places l ,e '3 \\' ' 13 on the chart, I see other dips of that type, and I think that I4 anyone studying the chart could probably select some. I don't 15 know that I am able to see any that have such time coincidence 16 you are looking at the other chart, Mr. Brill, and I am 17 looking at this one -- I haven't identified any that are 18 quite as coincident in time as those that we have, but I 19 haven't looked very much. 20 Here is one I see at 10 a.m., and there may or 21 may not be one coincident in time. I don't know. But I see 7_s l 22 other comparable dips of the same magnitude on the lower h 23 ,-~3 tracing. ( ) 24 Ad.mfa n pon.n, inc. I was looking at strip chart B, which is Exhibit 25 41.
31,630 im 5-7 Does anyone else want to make their observations? j MS. BERNABEI: Judge Smith, I would just note 2 3 that weedid question Mr. Brill on the other strip chart on 7x ( whetherornottherewereanycorrespondingdipsatthattimejlh 4 5 that is approximately at 12 midnight on the other strip chart 6 recorder, and I believe his testimony was there were not. 7 JUDGE SMITH: Yes, I recognize that. Okay. That 8 is what I observed. 9 JUDGE LINENBERGER: I have been looking at this 10 same TMIA Exhibit 41 while Judge Smith was looking at it and 11 I observed the same things he has spoken about. 12 I would at perhaps some perile make the observation. ,,s T ) 13 that in my past experience at viewing things and being involve s_, 14 in trying to use things such as this the very first thing 15 I would want to assure myself of is that calibration factors-16 might not have drifted to make sure that line voltage might 17 notc have drif ted and indeed a standard procedure in something 18 like this is to have a coincident trace from a line voltage I9 recorder and a coincident trace in which intentional line 20 voltage variations are introduced and one looks to see what 21 effect they have on the trace one is trying to adduce informa- ,sV' 22 / g 23 I don't know whether this has been done in this 24 .i n.mn.n, ine, case. I have no feeling for a signal to noise ratios, for 25
31,630 -A S m 5-8 example, but when one gets a trace running at or near the N \\ / 2 zero value line as is the case with the dip we are talking 3 about here on Exhibit 41 for the lower trace, all sorts of ,_s I instrument phenomena creep into play because the machine is llk' 4 5 recording at the very minimum of its capability and may be subject to influences not relevant to any actual change in 6 transducer output. 7 That is all I can comment on it at the moment. 8 JUDGE WOLFE: I agree with Judge Smith's visual 9 10 observations. Obviously I have heard Judge Linenberger and 11 his comments and perhaps we could seek clarification of that, 12 of Judge Linenberger's comments through examination of the f N 13 witness. 14 JUDGE LINENBERGER: I should like to ask, 15 Mr. Brill, if indeed there is available or does he know 16 whether there is available a line voltage recording for that i 17 same time period that could be used to shed some light on 18 whether the kind of thing I have talked about might be at 19 play here? 20 THE WITNESS-I don't know at this time that 21 there is anything available that would be able to give us r> () 22 that information. 23 JUDGE LINENBERGER: Thank you. Gat Reporters, Inc. 24 (Board conferring. ) Aca-25 JUDGE LINENBERGER: As a follow-up question, let { l l
31,631 r- 'm 5-9 me ask, Mr. Brill, are you aware of any information with y respect to these specific recorders that would indicate whether ~^ 2 calibration drifts of the small order of magnitude corres-3 (m ponding to the dips we are talking about on TMIA Exhibit 41 l 4 have been looked for, screened out or in any way taken account 5 f by you or, to your knowledge, anyone else? 6 THE WITNESS: I have not done nothing in that 7 t area and I don't know at this time if anyonebody else has. 8 JUDGE LINENBERGER: Thank you. 9 JUDGE SMITH: I might tell you one of my 10 11 observational concerns concerning your thesis, and that is 12 although the higher level dip and the lower level dip are ,,m 13 maybe within, I don't know, fiveortenminutesofindicatedlh v 14 time, they are visibally apart an indicated time, and it 15 would seem to me that as I have looked at the literature on 16 the machine and as I have seen strip chart recorders that the 17 Pens are exactly lined up. 18 And if you are going to have insult to the machine -ult would be reflected at precisely 19 or to the paper, the 4 the time. For example, if, as you suggest, the paper was 20 21 distrubed, and that is indication of it, it seems to me that (( ') 22 that would be precisely at the time, or if the machine were O 23 bumped, for example, both would be reflected precisely at eal Reporters, Inc. 24 the time, and I don't see that on this. Acm. 25 MS. BERNABEI: If I could just refer you, Judge
y m 5-10 Smith, and I did speak both before the hearing today and i I questioned Mr. Brill somewhat about it during the hearing, 2 if y u w uld notice the one pressure excursion which is 3 obviousonTMIAExhibit41isthepressurespikewhichoccursh 4 at 1:50 p.m. 5 end Sim Joe fols 6 7 8 9 10 11 12 13 14 15 i b 17 1 18 I 19 20 21 0 22 e l 23 C' a_)...._....24 25
31,633 6-1-Wal [^'T 1 If you will notice, ideally the co1ditions you ) / ~' 2 describe should exist, that 13:50, what is marked as 13:50 3 on the lower wide range recorder, is in fact some time before -s 4 the spike which occurs cn the narrow range, and I think that lh '~' 5 is obviously the same pressure that caused both those spikes, 6 but they are somwhat different in terms of the time of the 7 chart. 8 JUDGE SMITH: That is true. 9 MS. BERNABEI: My question to Mr. Brill is to H) presume that same difference in time. 11 JUDGE SMITH: I missed the significance of that. 12 MS. BERNABEI: I think it is a comparable o N. _ j 13 distance between the two spikes on the rarrow and wide range la recorder, and between the two anomalies that appear around 15 twelve midnight on the wide -- narrow r.tnge. 16 JUDGE LINENBERGER: Ms. Bernabei, can we 17 establish for sake of clarity and future considerations of the i 18 record whether it is on either exhibit, whether it is the 19 upper trace that is referred to as the wide range, or the-20 lower trace that is referred to as the wide range? 21 MS. BERNABEI: My understanding the lower trace A(,) 22 is the wide range. 23 WITNESS: That is correct. l A ( i 24 JUDGE SMITH: So, would it be satisfactory with Acd., J Reporters, Inc. 25 you, Mr. Blake, if at this time we constructively receive these i
31,634 6-2-Wal I charts into evidence with custody to be in the Licensee, with s y 2 the understanding they would be produced upon need and demand 3 by any reviewing authority, and that there be no physical V,eq { } 4 changes made of these charts; nothing added, or nothing detracte 5 from them. That they be preserved exactly as they are now. 6 Would that be satisfactory. 7 MR. BLAKE: Let me just check on one thing. 8 (Mr. Blake confers with colleague.) 9 My -- what I was checking on, ordinarily an 10 exhibit in the proceeding lasts literally forever, and II you can go back and read about cases and find exhibits from 12 bygone years. (m) O I, L' JUDGE SMITH: I would expect it to be an exhibit 'd only until the decision in this particular proceeding becomes 15 a final one. i 16 MR. BLAKE: What I suggest we do is before we I7 leave today we put it in the box, the best box we have. Mr. i 18 Brill brought these originals in, and we seal it up today and l l I9 we don't open it again I guess without authority of whoever 20 the presiding officer is at that point in time over the 21 proceedings. /~~(3,/ 22 JUDGE SMITH: That is really more than we asked. h 23 I would not -- don't know if you are going to have any other 24 \\ occasion for other purposes to look at it. Also, there is Ace. J Reporters, Inc. 25 another point too that you could possibly do, and I just didn't
( 3-Wal 31,635 / } } think to capture the whole chart, that it would be practical / 2 to have photographs, but it may very well be. As Judge 3 Linenberger points out, good photographic techniques can ,(.) 4 capture these points, and if it becomes a need to do something T 5 with the chart you could always substitute those. 6 MR. BLAKE: You have no problem with my commitment 7 that we will take every step reasonable so that these are, in 8 fact, preserved, and not monkeyed with. Obviously, I am not 9 going to keep them in my office. They will be provided to 10 somebody presumably at TMI in the records, but with some 11 instructions about an even added degree of cattion and care 12 to be exercised over these particular charts. 7_s' / i t' i 13 I addition, we will attempt to make photographs. s, 14 We will distribute the photographs, and see whether or not 15 they serve the purpose or become a better -- an adequate 16 exhibit, or a substitute exhibit. We will distribute them i 17 and see if the lawyers can agree. i 18 JUDGE SMITH: Any objections to that procedure? l 19 MS. BER" ABEI : No. 20 JUDGE SMITH: Okay. Proceed. 21 BY MS. BERNABEI: (Continuing) /~'s l \\) 22 Q Mr. Brill, one more question along this line. gg i 23 At the point of the wide range or lower recorder on Strip m 7 ( ) 24 Chart B, where there is a dip at or near twelve midnight, Ace' __J Reporters, Inc. 25 from that point thereafter in time, the recording stays below
6-4-Wal 31,636 ( ') I the line of the strip chart, is that correct? The calibrated m-2 line of the strip chart? 3 A That is correct. U 4 Q And before that anomaly it does not, is that fair 5 to say? 6 A It does not. 7 Q On page 4 of your testimony, you speak about -- 8 talking now about the second paragraph -- the first sentence. 9 You speak about records indicating that a portion of strip 10 chart B was microfilmed on May 2, 1979, is that correct? 11 A That is correct. 12 Q Is that the first time, to your knowledge, that -m O ) \\_./ 13 the chart was microfilmed? W 14 A To my knowledge, 15 Q That is the first time the record shows that it 16 was microfilmed? l 17 A To my knowledge. I 18 0 Okay. And my understanding of your testimony is 19 that at the time it was to be microfilmed it was already cut 20 in three pieces, is that correct? 21 A That is correct. i (7) 22 Q Now, do you have any knowledge or information as / 23 to when the chart was cut into three pieces? A ( ) 24 A I do not. Am,m_.) Reporters, Inc. 25 0 And did Ms. Imhoff, to whom you spoke, have any I
6-5-Wal 31,637 /~ '1 i such information? N ] ~' 2 A only that she received the chart in three pieces. 3 Q Now, you said the chart was later microfilmed in 7s \\ l t l LJ A l 4 one piece on December 27, 1983, is that correct? W 5 A That is correct. 6 Q Now, do you know if it was microfilmed at any 7 time between May 2, 1979, and December 27, 1983? 8 A I do not know. 9 Q Okay. So it may have been. You simply have no 10 knowledge of that? 11 A That is correct. 12 Q Now, at any time after December 27, 1983, has the i,,_, ) 'x _ / 13 film been microfilmed or otherwise copied? 14 A I don't have that information. 15 Q Do you have any information as to who cut the I 16 chart originally? That is, prior to May 2, 1979? i 3 17 A I do not. 18 Q The last paragraph of your testimony is that i i 19 -- let me first go to the last sentence. You indicate here 20 that to keep the chart flowing freely in the recorder, one would 21 have to tape up the three pieces in order to continue the chart (3 (-) 22 running through the recorder, is that correct? That is the 23 sense of your sentence there? Gel Reporters, Inc. 24 A That is correct. Am-25 O Now, if I understand correctly from other testimony
6-6-Wal 31,638 in this hearing, I would understand that one could keep the ('" j i paper or the chart flowing freely in the recorder merely if 2 one were to connect the end point of the chart to another 3 ( portion of the chart on the uptake roll. (l) 4 In other words, it really doesn't matter what 5 portion of the chart it is connected to, is that correct? 6 A That would be possible. But af ter examining 7 the chart, it does not look like they were tampered with. 8 0 I am just asking you physically if that would 9 10 be possible. 11 A Yes. 12 O So physically it would be possible to make a 13 cut, presumably after it passes through the plastic bar, ll either before or after it passes through the plastic bar, 14 remove a portion of the strip chart entirely, and then tape 15 { back together the portion which remains on the chart itself, 16 l i and a portion which remains on the takeup roll. l 17 18 A It would be possible after the chart passes the chart roll, approximately an hour to an hour and forty-19 five minutes af ter that time to cut the chart and take a 20 21 piece out, microfilm it, bring it back, and put it back into l rm () 22 the chart. O It is my opinion, though, that due to the 23 Gel Reporters, Inc. 24 straightness of the cuts, the configuration of the panel Ats-25 where the recorder was mounted, that that was not done. I
6-7-Wal 31,639 /~ ' X, 1 Q But it is possible. That is all that I am saying. / x_./ 2 A It is possible. 3 Q Your testimony also states that you believed -s 4 that if -- let me establish this. We know today that Ms. Imhodlh 5 made one taping of this chart. That is, the portions that are 6 cut at 2:00 a.m., and 10:00 p.m., is that correct? 7 A That is correct. 8 Q And what you are trying to determine in your 9 testimony on page 4, what your testimony speaks to is if at 10 any time prior to Ms. Imhoff taping the chart it was taped 11 by someone else? 12 A You are saying that is what I am trying to 13 determine? 14 Q Right. Isn't that what your testimony speaks to 15 on page 4. Any possible taping of the chart prior to Ms. 16 Imhoff taping it. i 1, A Could you restate your question? l 18 Q Sure. Ms. Imhoff taped the chart together after I 19 microfilming the chart on May 2, 1979, is that correct? l 20 A That is correct. i 21 Q And we all know that that occurred. You have A(_) 22 no doubt that that occurred in your mind? 23 A That is correct. O) 24 JUDGE SMITII: I thought we struck that testimony ( Acm. __ J Reporters, Inc. 25 as being unreliable heresay? Now you are establishing that
31,640 6-8-Wal '~' i there is no doubt in anyone's mind that that is the truth. '~ 2 MS. BERNABEI: Well, it says before Ms. Imhoff 3 taped it -- it is referred to in tne last paragraph which s ! \\ ~ 4 remains. I am just trying to establish what he is talking lhh 5 about in the last paragraph; that he is talking about a taping 6 prior in time to any taping Ms. Imhoff should have done, j I am just trying to establish what period of 8 time we are talking about. 9 BY MS. BERNABEI: (Continuing) h) Q Now, Mr. Brill, your testimony in the last ~ .1 paragraph on page 4 speaks to a taping that would be prior in 12 time to any taping Ms. Imhof f did, is that correct? [j g b \\ 13 (Pause) 14 That is prior to May 2, 1979? 15 A Are you asking me do I feel that the strip chart 16 was taped prior to -- 17 Q No. I am asking you in your testimony what period l 18 of time you are talking about. You are talking about -- this 19 is a very simple question. I just want to establish a time i l 20 period you are talking about. 'I have examined the charts 21 to see11f it shows any evidence of having been temporarily ( I () 22 taped together at some time before Mc. Imhoff taped it 23 together.' / N ( ) 24 A That is correct. Am. _.3 n eporters, W. I 25 Q We are talking about now not the taping that we l
6-9-Wal 31,641 j s 1 see before us, but a taping prior to that taping. i 'ss 2 A That is correct. 3 JUDGE SMITH: See -- 'a taping' and the way 7_.s 1 U O 4 the sentence reads it presumes that there was a taping. W 5 MS. BERNABEI: His testimony addresses whether 6 or not he believes there was such a taping. 7 JUDGE SMITH: Okay. So -- 8 MS. BERNABEI: I will try to clarify it. 9 JUDGE SMITH: I think it is clear. The preface 10 of the question that he answered is not that he concedes there 11 was a taping. 12 MS. BERNABEI: Right, right. h (_,- 13 BY MS. BERNABEI: (Continuing) 14 Q Now, we are talking about a time period prior to 15 May 2 of 1979, is that correct? l 16 A In regards to the taping? 17 Q That is correct. 18 A That is correct. 19 Q In order to make the statements you make on page 20 4, you essentially observed or examined the strip chart, is 21 that correct? i I (')h q_ 22 A That is correct. ggg 23 Q And it is fair to say that basically there is l (O) 24 no special expertise required to examine the strip chart in AarmJ Fleporters, Inc. 25 this respect. That is, to determine whether or not it had been
6-10-Wal 31,642 1 previously taped? In'other words, you are not calling on any 2 special experience or knowledge you have about strip charts to 3 do that? 4 A-Well, I have worked with strip charts before. 5 Reviewed strip charts, and in my opinion an examination of the 6 strip chart, I do not see where it was previously disturbed 7 or taped-prior to that taping. 8 Q But I am asking you that doesn't call upon any 9 special expertise. Anyone here that was fairly observant could 10 observe whether or not it had been previously taped? 11 .A A possibility. 12 Q Now, you say that there are no torn edges at the () 13 places where the chart is taped together, is that correct? 14 A That is correct. 15 Q Okay. And that would be the 2:00 a.m. and 10:00 16 p.m. period? 17 A Yes. 18 Q Now it is true, is it not, that there are folded-19 edges where they are folded or non-consistent edges at the point 20 where it is taped. Those two portions. There are certain 21 portions of the strip cl. art that are folded in at the point at . /)N ' (, 22 which the chart is taped, is that correct? 23 A
- yes, 24 Q
And that would be true for both the 2:00 a.m. and Ass-Federal Reporters, Inc. 25 the 10:00;p.m. taping, is that correct? L
c-s 6-ll-Wal ~ 31,643 .) A ItLis correct.for the 2:00 a.m., but not' 2 'necessarily the 10:00 p.m. 3 Q Now,.the 10:00 p.m., it is fair to say the portion
- .},'
4 through which'the' wheel ~ runs on the. recorder is, in fact, .5 disturbed? 6 A Thatiis on the 10:00 p.m. It is disturbed'all '7 'along here. 8 Q Yes. 9 A That is correct. 10 Q In fact,-it is disturbed for the entire portion 11 .of the strip chart between 2:00 a.m. and 10:00 p.m. on 12 March 28th, is that correct? () 13 A Portions of it along the entire strip chart 14 are disturbed, that is correct. 15 0 And it is fair to say they are disturbed in a 16 manner in which that portion of the -strip chart af ter 10:00 17 p.m., on March 28th-is not disturbed? Excuse me. Prior-18 to 2:00 a.m. is not disturbed? 19 A That is correct. 20 Q Now, you state in your testimony that -- or you 21 suggest that there are not pieces of extra tape on the .( ) 22 portions of the strip chart in question, Strip' Chart B, is 23 that correct? 24 'A That is correct. m neporwn, one. 25 Q I would like you to review the backside portion
6-12-Wal 31,644 1 of Strip Chart B, specifically the point between 2:00 a.m. and 2 10:00 p.m. on March 28th. 3 .A Yes. O 4 Q Now, at 2:00 a.m. there is on the back side an - 5 extra piece of tape that is not currently holding together 6 the strip chart, is that correct? A That!is' correct. 7 8 Q And do you know when that piece of tape was 9 placed on the chart? End 6. jo SusT fois. 11 12 CE) is 14 15 16 17 18 19 20 21 22 23 24 Ase-Federal Reportees, Inc. 25
31,645
- 7-1-Suet 1
A No, I do not. 2 Q Now, referring you to the 10 p.m. portion of 3 Strip Chart B, TMIA Exhibit 41, again the back side, g~V) 4 there is a portion of tape there which is not holding to-5 gether the strip chart itself; is that correct? 6 (The witness is looking at the strip chart.) 7 A I don' t see a portion of tape there. 8 There is a paper that is not fast on to the 9 tape if that's what you are concerned about. 10 0 Well, there is a portion of tape on the back 11 side at that time which is not connected to the other side 12 of the strip chart; that is, that portion of the strip -( ) 13 chart after 10 p.m. on March 28th? 14 A You mean this piece right here? 15 0 I'm talking about this piece right here. 16 A Why wouldn' t that piece be part of the other - 17 piece, if it's holding it together. 18 JUDGE SMITH: I think it may be peculiar 39 what is going on the record and what isn' t. That I 20 think was an aside. 21 MS. BERNABEI: Right. Okay. I will ask 22 the question again. 23 JUDGE SMITH: When in doubt, it's on the 24 record. Asefederal Reporters, Inc. 25 BY MS. BERNABEI: (Continuing)
31,646 '#7-2-Suet-I Q There is a portion of the tape, again at or 2 near the 10 p.m. time on March 28th on~ the back side of 3 Strip Chart B, which is not connected to the other side; a 4 that'is, the later than 10 p.m. period of the strip chart; 5 is that correct? 6 A That is correct. 7 Q And it does not appear to be holding the strip 8 chart together at that point? i 9 A At that point in the tape, it does not hold 10 the strip chart together; that is correct. II Q Do you know when that piece of tape was put 12 on the strip chart? 13 A The best I can tell, that piece of tape is Id part of the original taping. I have no idea when that 15 would have been put on the strip chart. 16 0 Okay. And one last point, if you would look 17 at Strip Chart A, which is TMIA Exhibit 42, at the time 4 18 of the pressure spike, at or about 1:50 p.m. on March 39 28th, there is a wide range or lower range recording of 20 the spike at that time; is that correct? 2I A That ic correct. 13 V 22 Q And that is in red on tae chart? 23 A That is correct. 24 Q And there is at tMt time apparently no t.. rFesieres Reporie,s, Inc. 25 recording on the narrow range recording; is that corro::t?
4 L 4 *k*\\h/h IMAGE EVALUATION 6 O Y 82, ////pY 3['f4
- 4 4
g)g,+)!@* %gx,? TEST TARGET (MT-3) s. l.0 lf M Ma lf lf HE !.. '- E I.I l 1.8 1.25 1.4 1.6 4 150mm t*% /$ +<4 A4 w A,- s +#+<p# 7// v o i e s a-
///// ?> k*/ 4 d9 IMAGE EVALUATION 4y,j <>$> /4,, <,(4 4,, e y /9 + l.0 lf 2 E ti 9 NE !E HE l-l em 1.25 1.4 1.6 150mm 6" if 4% Alf 8 Qfi% b 4xzzz//p v / lx m
31,647 17-3-Suet 1 A That is correct. 2 O And it's fair to say that for some period before 3 the time of the spike, there is no narrow range recording-4 of reactor building pressure? 5 A. .That is correct. 6 Q However, a very short time after the spike 7 there appears to-begin.a recording of reactor building. 8 Pressure thereafter? 9 A That is correct. 10 Q Now, if you were to judge from viewing the. 11 chart as it is today, one would assume that in fact the-12 upper recording device or pin was not operating at the time \\j) - 'l 13 of the spike; is that correct? 14 A That is correct. 15 Q And it.would appear that at or near the time 16 of the spike, someone put into operation or attached that 17 upper pin recording; is that correct? 18 A I don't know. -19 Q Well, in any event, it did begin recording a 20 few minutes after the pressure spike and continued there-21 after? () 22 A Yes, it did. 23 Q And that would have to be done manually; is 24 that correct, putting into operation the recorder pin for~ . Ace-Federal Reporters, Inc. 25 the narrow range recorder on Chart A? e
31,648 f.7-4-Suet 1 A I' don't know. It could have been done by the 2 recorder itself. hutomatically? 3 0 4 A If it stopped printing, it could have started 5 ' printing again after the pressure spike. 6 Q Okay. And how would that occur? That is, 4 7 how would it be automatically rather than manually activat-8 ed? 9 A Well, the pressure spike might have activated 10 the recorder pin which in that period of time was not Il printing, and then it started to print. 12 Q It could have also been manually activated; 13 is that correct? 14 A That is correct. 15 Q Just to return to one point, Mr. Brill, 16 Strip Chart B, focusing now on the portion between 2 a.m.- 17 and 10 p.m. on March 28th, okay, the lower portion'of 18 the chart has certain marking or sprocket marking where 19 it runs on the wheel of the recorder; is that correct? 20 A That is correct. 2I Q Okay. Now, those -- at those 2 a.m. and 10 A p.m., those -- well, those at 2 a.m. are disturbed; is V 22 23 that correct? They are folded over, both the sprocket 24 portion and the portion at the top of the chart? Ase-Federst Repo,ters, Inc. 25 A That is correct.
31,649 -#7-5-Suet 1 Q Now, at 10 p.m.-there is also disturbance of' 2 those markings on the bottom'of the Strip Chart B at g 10-p.m.; is that correct? ') 3 u 4 A That is correct. 5 0 And that disturbance-of the sprocket' markings -- l 6 or the wheel markings, continues from 10 p.m. thereafter? 7 Is that correct, Mr. Brill? Or, the hole. 8 A Well, there is disturbances after 10 p.m. 9 Q Okay. And it's fair to say that,one sees 10 no such disturbances in wheel, the holer, or the wheel Il markings which appear before 2 a.m. on March 28th? 12 A That is correct. 13 Q And if you can generalize, one also sees-no-14 such disturbances in the holes or wheel markings which; 15 appear on the other strip chart, Strip, Chart A? I6 A Would you -- 17 Q For that_ period of time. 18 A Prior'to 2 p.m.?- 19 Q Right. Generally talking about the 2 a.m. 20 to 10 p.m. time period, generally there are no such 21 disturbances; is that correct? 22 A That's correct. 23 Q Have you examined this particular recorder as 24 it is located in the TMI-2, TMI Unit 27 Ass-Federal Reporters, Inc, . 25 A Yes. t-
-L ~31,650 '47-6-Suet 1 O' -You have? '2 A' Yes, I have. i: l 3 Q And do-you have any information~ or knowledge-3 as to how paper in the normal course of business at the ~ 5 .-time of the accident was: preserved or. maintained? That ~6 is, paper that-had already.run'through the. strip recorder, 17 the pressure recordur? 8 A I have reviewed seventeen strip. chart accident ~ 9 recorder charts, and I have found that of the seventeen 10 fourteen of those were_ cut in two places to preserve the b 11 accident information. One was not cut. And two were. 12 cut in one place. .[ 13 Q Okay. I think I'm asking you a slightly' 14 different question. 15 Okay. If one-- I assume that the rolls of 16 paper which are used in the. reactor building. pressure f 17 recorders are for a certain period of time. l: II -A That is correct. '19 Q Okay. And, if you know, for these particular-20 recorders, let's take Strip Chart B, how'long a period-21 of. time is that? 22 A I don't know the answer to that. '23 Q Okay..For'whatever period of time it is,'how is the paper changed? In the normal course of operation, 24 Aes-Federal Reporters, Inc. 25 how would the operators come to change the papor in the
31,651
- 7-7-Suet 1 strip recorder?
2 A Okay. After the strip chart recorder flow 3 mechanism for the ' chart starts with the supply reel, goes f- ~/ 4 from the supply reel around to a toothed-wheel reel, from 5 there back to a take-up spindle. And once the take-up 6 spindle is full the take-up spindle chart is taken off and 7 a new chart is put on, on the supply reel. 8 Q And then, if you know, in the normal course 9 of operation the chart would not be cut; is that correct? 10 A That is correct. Il MS. BERNABEI: Okay. I have no other ques-12 tions. () 13 JUDGE SMITH: Mr. Au? 14 MR. AU: A couple of questions. 15 CROSS EXAMINATION 16 BY MR. AU: INDEXX 17 Q The times which are printed on the bottom of 18 these strip charts, are those printed on by the machine 19 or are they preprinted on the roll of paper? l 20 A They are printed, in this case, on the roll I 21 of paper. r . (_)\\ 22 Q Preprinted? i 23 A Yes. 24 0 How does the technician align the time with l Am-Federd Reporters, Inc. 25 the paper? l l'
31,652
- 7-8-Suet 1 A
There is a toothed-wheel n.echanism that he 2 can-adjust the paper to the toothed-wheel take-up reel 3 which will give him the proper time, the actual time that 4 it is. 5 Q He is synchronizing it with his own watch? 6 A Well, with the watch or a clock in the control 7 room. 8 Q So his manual synchronization could be off 9 by a couple of minutes? 10 A It's possible. II MR. AU: Thank you. 12 JUDGE SMITH: Mr. Goldberg. () 13 CROSS EXAMINATION i f Id BY MR. GOLDBERG: .INDEXXX 15 Q Mr. Brill, the recorder that recorded the 16 pressure spike which occurred at 1:50 p.m. on March 28th, 17 1979 and which recorded the charts which you have before 18 you and which are reproduced in part by TMIA. Exhibits 41 19 and 42, that was a Taylor Recorder, 830J or 930J, Model D? 20 A That is correct. 1 2I Q Is it one or the other of those? m (_) 22 A It's one or the other. I don't know right 23 off which one. 24 0 Could you briefly describe the sources of Ace-Federal Reporters, Inc. 25 error associated with the pin recordings on these strip
31,653.
- 7-9-Suet I charts?
2 JUDGE SMITH: Along this line, maybe it might 3 move things along a little better, the Board has been 4 -reading the servicing and troubleshooting part and has 5 it pretty well gathered together there. 0 And if you could answer it in. 'the context of 7 the troubleshooting guide it might be helpful. 8 While he-is looking for that, Mr. Blake, we 9 have received this testimony into evidence together with 10 the attachment which is the Owner's Guide or whatever you II call it, which has accordian fold-ins. I wonder if that's 12 going to cause any trouble? 13 Let's go off the record. Id (An off-the-record discussion ensues.) 15 WITNESS BRILL: Your question was the sources I0 of error?. I7 BY MR. GOLDBERG: (Continuing) IO Q Yes. A Okay. In a strip chart recorder, there is -- 20 that's part of a loop, and the loop has pressure transmit-21 ters connected to it so the pressure transmitter would f' i 22 have a certain error, the strip chart recorder would have 23 a certain error, combined error would be the loop error 24 for that particular loop. 25 0 Okay. There are various components of this
31,654
- 7-10-Suet I recorder such as input filters, amplifier, modules, filters 2
for reducing interferences and smoothing out noi'se signals? 3 A Correct. 4 0 There is a certain amplification error? l 5 A That's correct. There ic ' a servo-drive mechanism 6 that drives the pin which is connected using a wire to the 7 pin mechanism. There is a chart-drive mechanism that 8 -drives tha pin at one inch per hour. 9 All those things would have some inherent 10 error in them. The accuracy of the recorder is identified II in the instruction manual, the overall accuracy. 12 O And can you identify that for us on the O 13 attachment to your testimony? y Id A I would prefer to look it up rather than say 15 something that migi.t not be correct. l 16 0 Yeah, could you do that, please? 17 A Sure. 18 (The witness is looking at a document. ) 19 It identifies the calibration accuracy under 20 the operation instruction as plus or minus point two five 21 percent.- O V 22 Q And tlat's a calibration accuracy? 23 A That is correct 24 0 Would that represent the actual total accuracy Ase-Federd Reporters, Inc. 25 for a particular trace? Or, is that just one of the
31,655
- 7-11-Suet 1
-components? 2 A. No. That would be just one of the components 3 in a loop. 'The other components in a loop would have to-4 be factored in. And normally in loop calibrations the 5 accuracy is determined by the sum of the square, the 6 square root of the sum of the squares for that particular 7 loop, for the components in that loop. 8 Q Now, for the components which comprise this-9 recorder, is it the case that some of them are common to - 10 both pin traces and some of them are not? 11 That is, each pin has associated with it 12 certain components which are associated with that particular - O gin receedine ene net the ether ein recordine2 14 A That is correct, because the inputs on the 15 two-wire system that we use in this particular case is 16 derived from pressure transmitters, and there is two 17 pressure transmitters for each recorder. One drives one 18 pin -- one input from one recorder, or from one pressure 19 transmitter drives one pin and one from the other pressure 20 transmitter drives the other pin. 21 0 So that the total actual error associated with 22 one trace produced by this -- one of these recorders would i 23 not necessarily be the same as the total actual error 24 associated with the other trace printed on the same recorder [ Ace-Feder:3 Reporters, Inc. l 25 at the same time; is that correct? i t
31,656
- 7-12-Suet I A
The error could be different at any given time; 2 that is correct. 3 Q .Now I think you indicated before that you g-q -U .4 examined a total of sevenceen strip charts that were 5 operating at the time of the accident? 6 Did I understand that from your testimony before? 7 A That is correct. 8 Q -Did you look at the sprocket holes of-the 9 strip charts of the ones which you do not have in-front 10 .of you today? II A No, not specifically. 12 Q Do you have any knowledge as to whether .( ) 13 there are disturbances of the sprocket holes on the other 14 charts from the day of the accident? 15 A I do not recall. l 16
- MR.'GOLDBERG
Okay. Thank you, Mr. 17 Brill. END #7' 18 I9 Mary f1ws 20 21 C) 22 23 i 24 An-raises noso,wes, inc. 25
31,657 Sim 8-1 1 (Board conferring.) 2 BOARD EXAMINATION ~s INDEX 3 BY JUDGE SMITH: E,] 4 0 What happens when you bump the machine? It is 5 totally insulated against a jar or somebody bumping into it, 6 into the console? 7 A Well, the consoles are pretty well built. Some 8 somebody bumping in the console would not disturb the recorder. 9 0 It is designed to avoid that? 10 A Yes, sir. 11 0 In fact, the consoles are seismically designed? 12 A Yes, sir. ) 13 (Laughter.) BOARD EXAMINATION 15 BY JUDGE LINENBERGER: 16 i INDEX Q Do you know, sir, wnether there has been any 17 experience with attempting to correlate changes in pen tracing on the chart paper with the functioning of major pieces of equipment around the facility such as, I don't know, heating and ventilation equipment in the control room and r~T certain things turning on and turning off in the reactor (,) 22 bulding and that sort of thing? !! ave those been looked for, do you know? A I don't know if they have been looked for, but Am-Federal Reporters, Inc. 25
i 31,658 Shn 8-2 they could provide an input for noise level, if that is what y u are referring to. 2 0 The calibration and maintenance portion of the 3 ,s ) what I would call the owner's manual that accompanies your 4 testimony for this owner's manual for this equipment indicates 5 that certain calibration and check procedures should be done 6 or performed periodically, and in fact there is a section 7 under the maintenance portion labeled periodic servicing and 8 it indicats certain things should be checked periodically. 9 10 Do you have any knowledge as to what the time II interval prior to the accident was at which point these 12 intruments were serviced? ,- x ) 13 A I do not. 14 0 Also in the maintenance section there is a 15 discussion of the output signal from an operational amplifier associated with these recorders and it indicates that the 17 normal wave form of this operational amplifier signal has a 18 small amount of noise and it defines small as approximately 19 two volts peak to peak at balance. 20 Are you in a position to correlate that normal 21 two volt peak to peak noise out of the operational amplifier p_ I 22 to correlate that in terms of resultant pen movement that ~' 23 it might cause with the amount of pen movement we have 24 Am.r.d.<e n.por,,, ine, seen discussed in the context of the small dips on these 25 two exhibits?
31,659 Sim 8-3 A I am not in a position to tell you exactly how j much pen movement that that would cause. 2 Q All right, sir. 3 7~ Finally, at the very beginning of the operation 4 section of this recorder manual attached to your testimony 5 there is a discussion of an input filter system whose purpose 6 is, and I quote, from the manual, whose purpose is to 7 reduce interference or is supplied for the purpose of reducing 8 interference and smoothing signals from noisy processes. 9 10 And, indeed, it indicates that a particularly 11 designated resistor and a particularly designated condensor might be changed or replaced for the purpose of improving 12 this smoothing, if it is so desired. () 13 Do you know whether any adjustments of this 34 15 input filter network were made by the licensee in setting g up this equipment? A I do not know, sir. j7 JUDGE LINENBERGER: All right. Thank you 18 19 very much, sir. BOARD EXAMINATION 20 BY JUDGE WOLFE: INDEX 21 ,a ( ) 22 0 When did you have occasion first to look at 23 these charts, Mr. Brill? 24 A APProximately two weeks ago. Am Federal Reporters, Inc. 25 0 That was the first timel
t
- 7 y
31,660 Sin 8-4 1 A Yes, sir. 2 C And at all other times these charts have been 3 in the custody of the GPU. custodian, I believe her name is f3 4 Ms. Imhoff; is that correct? ~ 5 A Yes, sir. 6 JUDGE WOLFE: No further questions. 7 JUDGE SMITH: Mr. Blake 8 REDIRECT EXAMINATION INDEX 9 BY MR. BLAKE: 10 0 Mr. Au discussed with you the process of 11 calibrating the time on the chart by adjusting a cog. In 12 the process of doing that, could that result in any effect ( ) 13 on the pen tracing? 14 A Not normally such that there would be a disturbance. 15 that would be that noticeable. 16 Q Could it result in an effect such as we have 17 been discussing here, that is the effect, particularly that le midnight effect? 19 A If the technician were to take the tooth wheel, 20 or if the operator were to take the tooth wheel and, you 21 know, seriously move it radically forward or back, I guess () 22 there could be a slight disturbance in the pen tracing. That 3 is possible that that could happen. 24 0 You have been asked to describe tears or holes w, 25 or disturbances in the cog whool, holes that run along the
31,661 Sic 8-5 edge of the~ tape. If that chart were handled a lot.and i simply viewed a lot and handled by people, could such insults 2 to that piece of the paper occur just naturally from handling 3 O it? 4 A It certainly could. i-5 Q And you were focused on two portions of tape 6 which appear on the back of the original strip chart, one 7 adjoining the two o' clock cut and one adjoining the approximate 8 4 ten o' clock cut. Do those portions of tape which are on, or 9 J 10 which appear at those two places on the chart appear on ij the two o' clock a.m. to ten o' clock p.m. segment of the chart r on the other side of the cuts? 12 Now if you don't understand that question, I () 13 will try it again. 14 L t me do it in two bites, if I can. 15 At the two o' clock cut, does the portion of the 16 tape on the back of the chart appear on the 3 a.m. side or j7 n the 1 a.m. side of that cut? 18 I 19 A It appears on the 3 a.m. side. 20 Q And with regard to now the 10 p.m. cut, does the 21 Portion appear on the 9 p.m. or the 11 p.m.? () 22 A I have not concluded that that portion of tape which was referenced before is an additional portion of 23 24 tape other than that which holds the chart together. AseJoseres neportees, Inc. 25 MS. DERNABEI: Well, I don't mean to interrupt, 4
S m 8-6 i but I think that was his prior-testimony. 2 'MR. BLAKE: No, I think you are wrong. I think 3 tha t is precisely it -- what he has just said now, he 4 previously indicated. 5 MS. BERNABEI: Well, we will let the record show. 6 BY.MR. BLAKE:- 7 Q The segment which Ms. Bernabei referred you to, 8 asyyou look at it now does it appear to be on the 8 p.m. to 9 9 p.m. side or on the other side of the cut, the later' side 10 of the cut? 11 A It appears to be on the 10 p.m. side. l i 12 Q And where is the cut made, in your view, then? ([ ) 13 A The cut is made at about 10:15. Am I understanding 14 right as to what --- 15 Q Yes, sir. 16 And do you see any evidence -- let me focus you 17 on the 2 a.m. cut on the back of the chart. l 18 A Yes, sir. l 19 0 And the segment of tape which appears on the i 20 3 a.m. side of that cut. 21 A Yes, sir. () 22 0 If, assuming that that portion of tape which 23 you see there had been a portion of tape which connected that 24 segment of the chart with the segment of the chart which j Ae-Federal Reporters, Inc. l 25 precedes it in time, which currently is on the roll, would
31,663 Sim 8-7 you expect to see evidence of it on the chart? ) MS. BERNABEI: I am going to object. I don't 2 understand the question. 3 S 1 V JUDGE SMITH: I don't either. I don't understand 4 5 (Board conferring.) 6 MR. BLAKE: No more questions. 7 JUDGE SMITH: Okay. 8 Do you have recross? 9 MS. BERNABEI: Just a couple. 10 RECROSS-EXAMINATION jj INDEX BY MS. BERNABEI 12 0 Viewing whatever portions of tape that appear ) 13 n the back side of the strip chart B today, either the 14 10 p.m. or the 2 a.m. period, do you have any information 15 r vidence as to whether or not there were prior tapings 16 below that tape which appears there today? j7 A I think I indicated in my testimony that I have jg 39 seen no evidence that there was prior tapings. 0 Now if the tape were placed over the same spot 20 there had been prior tape, other than what you have mentioned, 21 73 t J 22 that is that extra pieces of tape may have been 1.:ft or that 23 there may have been torn edges, you could not see evidence, 24 could you, of the prior tape, assuming the tape is exactly Ace Federal Reporters, Inc. 25 the same where the tape is today?
31,664 Sim 8-8 ) A Well, it would be like taping two pieces of 2 paper together. When you try and remove the tape, you tend 3 to fray and destroy the surface of the paper and there are es ( ) 4 no such markings like that on the tape. 5 Q But if it were done carefully, one could not tell; 6 in that correct? If it were taped and untaped carefully and 7 another piece of tape put over it, you could not necessarily 8 detect the prior taping? 9 A No. I think there would be evidence there of 10 frayness and destroying the surface of the paper that you 11 would be able to see. 12 O Even if it were done carefully? (m! 13 JUDGE SMITil: This is a matter of common experience w/ 14 and perception and it doesn't really matter if you get him 15 to agree with you or not. You can make your argument. I0 MS. BERNABEI Okay. n* (Pause.) 1 18 BY MS. BERNABEI: I 19 Q Now the dip on the wide range recorder, or the 20 lower range recorder on strip chart B, I think it was 21 described by Judge Smith as an abrupt change.if I am quoting ,y) 22 him correctly, isn't it true that changes in pressure for 23 the most part, and I am not saying uniformly, but are usually 24 Am FWwe Rnerats,1=. gradual and not abrupt, that is changes that are recorded on 25
31,665 -Sim 8-9 i strip charts of that magnitude? 2 A Would you ask me that question again? 3 Q Yes. Focusing now on the wide range recording, ) 4 the dip that was acknowledged by you and'also characterized 5 by Judge Smith as an abrupt dip or abrupt change, isn!t it 6 true that for the most part small changes in pressure are 7 detected or recorded as gradual changes rather than' abrupt 8 changes on a strip chart of this sort? 9 A That would depend on how the pressure change how 10 actually affected, whether it would be an abrupt pressure 11 change or a gradual pressure change. It could be either way. 12 MS. BERNABEI: Okay. 13 I have no other questions. 14 JUDGE SMITII: Anything further of Mr. Brill? 15 i MR. BLAKE: One moment. 16 (Pause.) 17 MR. BLAKE: No questions. 18 JUDGE SMITH: All right, Mr. Brill, thank you 19 for coming. 20 (Witness Brill excused.) i 21 MS. BERNABEI: I would move TMIA Exhibit 41 and 42 into evidence. 23 JUDGE SMITil: Any objections? 24 Aes Federal Reporters, Inc. (No response.) 25
31,666 ~ JUDGE SMITH: The exhibits are received. 2 (TMIA Exhibits 41 and 42, previously 3 /~T marked for identification, were D 4 received into evidence.) 5 'INDEXXXXXX JUDGE SMITH:' Is there any other business before 6 we go to the proposed findings? ? 7 MR. LEWIS: Yes, there is. I have several exhibits 8 which I would like to identify. 9 JUDGE SMITH: All right. These are Licensee t 10 exhibits?
- i 11 MR. LEWIS:
Yes. If I could identify them, the 12 first, which I would ask to be marked as Licensee Exhibit I) 13 t .v No. 2, is an excerpt from the deposition of Richard Lentz 14 which was taken by TMIA on October 15th, 1984. The portions 15 are page 50, line 25 through page 58, and then page 60, line 12 through page 63, line 7. (The document referred to was marked 18 Licensee Exhibit No. 2 for 19 identification.) 20 INDEX MR. LEWIS: The second which I would ask to be 21 marked as Licensee Exhibit 3 is the answers to two interro- {') i ss gatories which deal with data collected by Richard Lentz. These are answers to Interrogatories 20 and 21 and Licensee's answers to Intervenor, Three Mile Island Alert's fourth set 25
n 31,667 i -Sim 8-11 l 1 of.. interrogatories. l-2 (The document referred.to was-I 3 marked Licensee Exhibit No. 3'for !O j. 4 identification.) I'INDEX 5 e cnd Sim-6 l Joe fois l' y l 8 i l 9 i 10 i j; 11 i i -12 i !O 14 i 15 i j_ 16 i i 17 l-18 19 20 21 0 22 23 24 hFederal Reporters. Inc. 25
9-1-Wal 31,668 1 TMIA and Licensee have discussed these, and I 2 understand they are in agreement. 3 MS. BERNABEI: Substantially that is correct. ,_s ) ~ ' 4 The only -- I would suggest we tear down response 20 -- 5 MR. LEWIS: And admit 217 6 MS. BERNABEI: And admit 21. 7 MR. LEWIS: That is fine with me. Then I would 8 ask that these be admitted into evidence. 9 JUDGE SMITil: You handed two Lentz' depositions. 10 MR. LEWIS: There is a third one. We are in 11 disagreement on the third one. We will get the easy business 12 over first. ) 13 JUDGE SMIT!!: I hadn't appreciated that there 14 were two, so I marked the first one I picked up as Exhibit 2, 15 -- Exhibit 2 is the smaller of the two, right? 16 MR. LEWIS: Yes, it is. l 17 JUDGE SMITII: Exhibit 2 is the smaller of the i 18 two -- 19 MR. LEWIS: The longer. The one that starts 20 on page 50. 21 JUDGE WOLFE: Would you repeat those page numbers, h 22 and line numbers for Licensee Exhibit 2, please? 23 MR. LEWIS: They are already lined out, the ones 24 that are not in evidence. Ace Federal Reporters, Inc. 25 JUDGE WOLFE: I see. All right. r
= 9-2-W21' 31,669 6 1 JUDGE. SMITH: All'right. There are no objections 2 to Exhibits 2 and 3? 3 MS. BERNABEI: Excuse me? JUDGE CMITH: Exhibits 2 and 3 are not objected 4 5 to?. -6 MS. BERNABEI: Three being the answers to ~ 7 Interrogatories?- 8 MR. LEWIS: Yes. 9 MS. BERNABEI: Yes. The only amendment I 10 would make, which I believe Mr. Lewis agrees with, is'I would 11 include in thre'e only the first page and the second page up-12 through tne first two sentences of the interrogatory response - 13 20, and strike the rest of that. 14 MR. LEWIS: In other.words, Interrogatory 21 l'5 and its response should be lined out there. It should not be 16 part of the -- 17 MS. BERNABEI: As well as the rest of response 20, 18 as to the first two: sentences. 19 MR. LEWIS: Ycah, I have no problem with that 20 either. 21 JUDGE SMITH:- What is the additional deletion? 22 MS. BERNABEI: Basically, the deletion would be 23 from page 18, which is the second page, everything after the 24 second sentence of the response. Am reseres noorwes, Inc. c '25 JUDGE SMITH: Of the responsu 20?
m 9-3-Wal 31,670 i MS. BERNABEI: That is correct. 2 JUDGE SMITH: Beginning with, "Mr. Lentz states?" - 3 MS. BERNABEI: That is correct. 4 JUDGE SMITH: Is deleted. 5 MR. GOLDBERG: All of page 19 is gone. 6 JUDGE SMITH:~All of Line 19 then.is gone -- 7 MS. BERNABEI: Page 19, that is right. 8 JUDGE SMITH: That is all gone? 9 MS. BERNABEI: All gone. 10 MR. GOLDBERG: One less piece of paper to carry 11 back.' ,12 JUDGE SMITH: Then we look at -- what is our () 13 next one? 14 Jm. LEWIS: The third piece of paper I handed 15 out, which I ask be marked as Licensee Exhibit 4, is an 16 excerpt from the deposition of Mr. Richard Lentz, taken by 17 TMIA on October 15, 1984. The portions that we ask be admitted 18 begin on page 68, Line 8, and run through page 71, line 19. 19 This excerpt addresses whether Richard Lentz obtained a copy 20 of the strip recorder on the evening of March 28, 1979. XXX 21 (Above referenced document is () 22 marked Licensee Exhibit No. 4 23 for identification.) 24 JUDGE SMITil: And you object? Ase Fedstel Repo,ters, Inc. 115 MS. DERNABEI: Yes, we object. Essentinlly, h.<
j '9-4-W21 31,671 i 1 we don't think this is rebuttal to our direct case. 2 What we presented is testimony from Mr. Broughton 3 essentially as to his knowledge of what was obtained -- what O l 4 information was obtained from the control room, and what 5 information'he would have had available, and apparently what 6 he would have communicated to Mr. Keaten. 7 We did not -- he didn't have any information, s as he testified as to whether or not Mr. Lentz made any copies l 9 of strip recordings. !!is only testimony was that was the i 10 kind of information that they would have wanted to got, but 11 he did not have on the stand any memory of whether or not that 12 information was obtained. () 13 I think given this fact, that is not rebuttal 14 to any direct testimony we have presented, and therefore 15 without Mr. Lentz coming here to testify, we wouldn't agree 16 to that. i l l 17 I would also state that we did agree to portions 18 of Mr. Lentz's deposition on a matter about which Mr. Broughton 19 did testify; the alarm printout. Somewhat reluctantly, given + 20 the fact that Mr. Lentz is not here to testify. l 21 But I think this is not in rebuttal to anything () 22 we have presented. i 23 MR. LEWIS: If I might address that point. 24 I am not sure that -- I don't believe that the fact that it hefene noorwes, W. [ l 25 is not rebuttal to Mr. Broughton's testimony is a factor in t l
9-5-Wal 31,672 1 .its admissibility. It is certainly relevant and probative 2 on a very central point. It has been the point of Mr. Brill's 3 testimony'here today. O 4 I think it is also. rebuttal to TMIA's case in 5 chief, its direct case. TMIA has made the argument, and I 4 would'like to read it to you, this is a portion of Tuesday's 4 - 7 transcript, at page 30,994, TMIA is discussing its theory r E a that the strip chart was removed and cut on March 28th, 9 and they state, and this is Ms. Bernabei: I also say that 10 it fits in with prior testimony of Mr. Illjes. That in fact 11 engineers and there is a suggestion that perhaps it was a 12 GPU Service Corporation engineer, and I think given the () 13 total record, it was probably Mr. Lentz looked and xeroxed 14 the pressure spike and was interested in it. This means 15 there was attention, attention by top technical people on 16 site, GPU Service Corporation people, to the pressure spike 17 on late evening of March 28th. 18 We anticipate that TMIA will make the same 19 proposed findings that testimony by Theodore Illjes indicates 20 that the pressure spike was removed and photocopied at the 21 behest of a GPU engineer, or some finding to that ef fect, () 22 that Richard Lentz was there collecting data, and they will 23 draw the conclusion that Richard Lentz obtained a copy of the [ i 24 strip chart and brought it back to GPU engineers in the A m.peseres mes=< wee,Inc. 25 observation center.
4 a x 9-6-W31 31,673 l t l' We want to show Mr. Lentz's statement, and I r 2 think it is a very key piece of information that is needed 3 to make the record complete. That he doesn't remember -- he b l~ 4 doesn't believe that he wanted or obtained a copy of the strip 5 chart. That is the purpose this excerpt is being introduced. 6 The second point Ms. Bernabei raised that she 7 believes that it would be improper if Mr. Lentz is not here I 8 to testify. It is a point that has been -- well, I _think a 9 large number of deposition excerpts have come in over the 10 last week,coften over Licensee's objection. I think it is l 11 a procedure that TMIA has taken advantage of, and I think l 12 in fairness we should have -- be able to take advantage of the i O ia seme erocedure. l 14 This is TMIA's deposition. Ms. Bernabei cross 15 examined Richard Lentz on it, and I don't think she would be 16 prejudiced. It is a very simple point also. 17 MR. GOLDBERG: The Staff supports Licensco's l - 18 motion. l 19 MS. BERNADEI Can I just respond to a few things l 20 that Mr. Lewis said? We will stipulato that wo intend to make 21 the argument he just laid out. What I am talking about is how i l (~)T (_ 22 this evidenco comes before the Board, and just to touch on tho l 23 second point, we proposed a number of witnessos, and the Board 24 -- and I can understand the Board's considerations -- that wo Ase reewes neporici.Inc. 25 don't want to be hero for the next throo months of our livos, l l
_ ~ 9-7-WOl 31,674 1 If there is some other way of receiving evidence on those 2 witnesses testimony, we will accommodate that if they are not 3 central characters in this drama. 7 s, Q. 4 We agreed, and with Licensee's agreement, that 5 Portions of depositions of these individuals would be entered 6 in lieu of their testimony. That was in. lieu.of testimony that 7 we wanted. And we were the party that were giving up their 8 live testimony in order to enter portions of their deposition. 9 That is number one. In this case what we have 10 is essentially use, as I see it, of Mr. Lentz's testimony -- 11 first of all not as rebuttal. It is not rebutting anything 3 l 12 that Mr. Broughton testified to. It is just information that () 13 happens to support the Licensee's case. 14 If it is true that it supported their case, they 15 should have brought Mr. Lentz here to testify or made some 16 arrangement in their direct case. But as far as I can see, 17 it does not rebut any testimony we have provided in what I 18 will call our direct case. 19 JUDGE SMITil: If it doesn't, then -- and it is 20 -- then it is moot, and we don't have to worry about it. 21 Where will you get the evidence from which you argue that (G.) 22 23 MS. BERNABEI: From the Joint Mailgram exhibits. 24 JUDGE SMITII: What? Ass Fedeed mopoewei, Inc. 25 MS. BERNADEI: From the Joint Mailgram exhibits, i i
9-8-Wal 31,675 1 and from the testimony we have here as to the mission of the 2 GPU. Service Corporation. 3 JUDGE SMITH: This could be argued that it is 7s ( ) -v 4 in rebuttal to portions of the Joint Mailgram Exhibits upon 5 which you rely in your case in chief. 6 MS. BERNABEI: But we did not present testimony 7 on that. 8 JUDGE SMITH: What is the difference? 9 MS. BERNABEI: There has been reliance by all 10 parties on portions of the Joint Mailgram exhibit, and that 11 doesn't mean that somebody in this hearing, any party,can"preser.t 12 rebuttal testimony to that. Everybody has been restricted to 13 doing is providing rebuttal testimony'to the actual witnesses 14 in evidence that has been introduced -- 15 JUDGE SMITH: Nobody has been restricted in 16 rebutting a material fact in dispute. That is a distinction 17 to be made to the means by which it is rebutted. Nobody -- I 18 see no difference in the substance of the case where the 19 testimony was adduced by a live witness sitting there at the 10 witness stand, or by stipulated mailgram exhibit with respect ~ 21 to a person's right to rebut it or supplement it, or whatever. ) 22 If we went back over this case, I don't think we 23 would have seen that pattern at all. If it happened, I 24 ~ certainly wasn't aware of it. ' Ace-Federd Reporters, Inc. 25 MS. BERNABEI: That I assume -- these are u
9-9-Wal 31,676 l 1 stipulated exhibits. These are not part of any party's direct 2 case. 3 What we -- we have proceeeded on the assumption <,,(- 4 k_/ _ i-4 -that Licensee'has presented certain witnesses in its directL 5 case, and also brought attention to the Board a-6 JUDGE SMITH: You mean no part of that volume 7 there.is going to be a' part of your direct case? No part of it? 8 MS. BERNABEI: What I am arguing is the only thing. 9 that_ ve have talked.in this hearing about rebutting is -- or l-10 we considered we had the opportunity to rebut -- was evidence 11 that was presented in this hearing as part of the party's i 12 direct case. ( )- 13 And as you know, when' we had long discussions l-4 'about these exhibits, originally, as-I understood the Board to 15 say, unless it was brought up in examination of witnesses, 16 there would not -- you would not pay. attention to it. 17 You _later clarified that to say no, you wanted l-18 it brought to the attention of the Board in a timely fashion, L= 19 and to the other parties attention.- h-20 None of the parties is going to be able to e-21 rebut the evidence in the-Joint Mailgram exhibits. That ~ q j '(_/ -22 simply has~not been a part of the context in which this hearing
- 23 has appeared.
We could have another whole hearing on that.- L 24 But that'is not what this has been-about. l Ase-Federsi neponen, Inc. l-25 Essen tially, it has been about rebutting testimony i m
31,677 9-10-Wal 1 ~ presented to.this Board for the first time. 2 JUDGE SMITH: I never understood the case to unfold 3 that way. I wish we had a better discussion, but I don't 4 .vodorstand any difference in substance as to whether you 5 rebut the testimony of a live witness or -- 6 MS. BERNABEI: Let me run back to my original '7 objection. If you remember, when the Licensee filed their 8 first notification Lo the Board, we had a long discussion about 9 whether that would be permitted. That is, they would be-l 10 permitted notification to the Board about portions of the record l-11 which were not used in examination of a witness. 1-1 4 12 And the Board said if.it is done.in a timely j (f 13 fashion, even if it is done after the examination of a witness, 14 that is okay. I objected to that at that point, because' I said~ l 15 it will not allow the other parties to. meet that portion _ of the i 16 other party's case. I 17 JUDGE' SMITH: That was the limeliness purpose. 18 MS. BERNABEI: Well, once the witness is off.the' 19 stand, _ there is no chance to rebut that evidence. -What-I am 20 saying is here, essentially, is we are talking.about allowing 21 a party to rebut evidence -- the joint mailgram exhibit, when I 22 the other parties have not been able to do so. 23 JUDGE SMITH; No. I don't agree with you. You l '. 24 have-never been denied an opportunity to rebut evidence simply j A=-Federes Reporwes, anc. J25 because it existed in the form of a joint mailgram exhibit. 1 ^ l
9-l'-Wal 31,678 l 1 That has not been an exclusionary set of evidence. 2 You have failed to appreciate, I believe, the purpose of our 3 requirements that there be-timely notification. The very 73 V, 4 fact -- the very fact that we use the word, ' timely' with 5 respect to announcing the portions of the mailgram exhibits 6 that you intend to rely upon, anticipates that the parties 7 should have an opportunity to rebut. That is obvious. That 8 was the obvious implication of that. So obvious that I would 9 not think it would be necessary to even discuss it now. 10 You are simply wrong that we have had a rule 11 of this case which does not allow a person or party to rebut 12 a mailgram -- stipulated mailgram evidence. O ia xS. esauxes = tet me seet sevr then, thee we-14 would propose to draw up a list of new witnesses. We did not 15 realize that opportunity was available, and I would just say 16 that the witnesses we have called have been put under incredible; 17 scrutiny. 18 First, we went to a prehearing conference in 19 which.that list was distilled. We then went through a long, 20 almost day, this week, on Tuesday, in which other witnesses 21 were allowed. Some were -- we were allowed only through 22 deposition testimony to introduce their testimony. At no 23 point was there any indication from the Board that we would 24 he allowed to produce new witnesses as rebuttal to the notifica< Aos-Fatleral Reporters, Inc. 25 tions that the Licensee had brought up during the hearing.
9-12-Wa1 .31,679 1 We would have taken advantate of that opportunity 2 if we had known it were available. 3 In fact, I remember specific statements from the (Q 4 Board that if you didn't mention the witness before, we are not 5 going to go over that right now. 6 I assume the witness list we originally presented 7 to you, other than to rebut evidence that has come up in this 8 hearing, daat that was the witness list we were stuck with. 9 That is what I understood our directions were. And similarly, 10 I think that would apply to Licensee, except if there is new 11 evidence that comes up during the course of the hearing that 12 they have to rebut, they are limited to the witnesses they ( )- 13 announced at the beginning of the hearing. 14 MR. GOLDBERG: Ms. Bernabei cannot point to any 15 rule that no evidence other than the live testimony.of witnesses 16 can be rebutted in this case, because there has been no such l-17 rule, and with respect to -- l l 18 JUDGE SMITH: And I have never heard in all my 19 years of practicing law, such an approach.- Is that the sole j 20 basis for your_ opposition to the Lentz deposition? I l 21 MS. BERNABEI: Yes. I think without Mr. Lentz ()' 22 being present and an opportunity for cross examination in 23 this hearing -- 24 JUDGE SMITH:. That is another basis, then? l Am-Federal Reporters, Inc. [ 25 MS. BERNABEI: Yes.
9-13-Wnl 31,680 j JUDGE SMITH: Okay. How do you distinguish 2 between Mr. Lentz' testimony and this deposition, and the 3 huge volume of interviews and depositions that we have received. '~' 4 into evidence? 5 MS. BERNABEI: That we propose to call the 6 witnesses. In the alternative, we gave up our right to call 7 witnesses -- 8 JUDGE SMITH: You did not give up any right to 9 call witnesses. 10 MS. BERNABEI: Let me say we agreed to stipulation 11 of their deposition in lieu of their live testimony.
- Thereby, 12 our preference would have been to call them as live witnesses.
(G~h 13 Given the complexity of some of the issues, and the narrowness 14 of what the use would be in terms of the issue before the 15 Board, we agreed to stipulate in portions of their deposition. 16 That was our right to call the person as a witness. And that l'7 was because of Licensee's objection to large portion of our 18 witnesses. 19 In this case, we have not objected to calling Mr. 20 Lentz and having him come here. I think that would be the 21 first step. If there were an objection, and it could be worked im ( 22 out that we would stipulate to this, fine. But I think the 23 first step is to propose Mr. Lentz as a rebuttal witness, at 24 which point we would, if we had an objection raise the objection, Am-Federal Repo,te,s, Inc. 25 and perhaps try to work out something.
F 9-14-Wal! 31,681' l 1 We would rather have Mr. Lentz come testify 2 .about this. 3 JUDGE SMITH: As'a: matter of fact, I think.this-i 4 -examination -- who was the party examining'Mr. Lentz? 5 MS. BERNABEI: Me. 6 JUDGE SMITH: This.is.your own examination of 7 Mr. Lentz on this very issue, and you still don't feel that 8 accepting that deposition is giving you due process, and 9 you represent if you.had Mr. Lentz here as a witness you 10 would have adduced different testimony from him? 11 MS. BERNABEI: Very likely. We did not focus -12 ~ on this particular issue, that is right.'- (). 13 JUDGE SMITH: You didn't focus on this particular 14 issue? Oh, come on. This is an important sub-issue to you. -End-9. 15 LSueT fols. 16 ~17 18 19 20 21 23 24 Ae-Fessed neponen, Inc. 25
31,682
- 10-1-Suet 1 MS. BERNABEI:
Let-me state that we did not 2 have the evidence we now have available at the time we 3 deposed Mr. Lentz. I'm just stating our position for-the oO 4 record. We can be overruled, but I do not -- 5 JUDGE SMITH: Well, no. Don' t just state .6 things for the record. You don't anticipate the Board's 7 ruling. 8 You are not trying to persuade us anymore? 9 MS. BERNABEI: Certainly, I am. But what I'm 10 saying is that I think the proper use of deposition testi-11 mony is either to impeach a witness who is available or 12 if the party that is offering the testimony is willing O i3 to sete1e for the eeseimony rether then the 11ve wieness, 14 okay. And that's all I'm saying. 15 And in this case, we would prefer that Mr. 16 Lentz be brought here for cross-examination. That's our 17 position, and I think legally it's sustainable; that we 18 would object to the introduction of his deposition testi-19 mony in this regard. 20 (The Board members are conferring.) 2I MR. LEWIS: Judge Smith, if I -- 22 JUDGE SMITH: Do you want to be heard? 23 MR. LEWIS: Yes. I would just like to state 24 our position one last time. Regardless of what's in Ace-Federal Repor. ors, Inc. 25 those Joint Mailgram exhibits, there has been questioning
v 31,683
- 10-2-Suet 1 of Mr. Illjes on whether the chart was xeroxed.
There has 2 been testimony that -- on the 28th. TIere has been testi-3 mony that Richard Lentz went to collect data and TMIA ,~ V 4 stated that it was going to draw an inference from that 5 despite the fact that Richard Lentz himself says I didn't -- 6 JUDGE SMITH: Mr. Lewis, I think you have 7 persuaded us as to the subject matter. The question is, 8 Mr. Lentz is available and that being the fact should we, 9 in the circumstances of this case, accept his deposition 10 testimony in lieu of his live testimony over the II objections of counsel. 12 I think you probably have one of the strongest (O 13 arguments that you can make where the deposition was con-(,j Id ducted by the very counsel objecting and with full ap-15 preciation of what the issue was. But nevertheless-16 there is a very strong legal evidentiary precedent that 17 when you have a live witness available and that witness 18 could testify, and there has been no particular agreement l 19 or stipulation or quid pro quo that I can identify, that 20 she is entitled to it. 21 Now, I'm troubled somewhat by the position of (~8 %,) 22 counsel, that she would have us decide an issue with full 23 knowledge that there is evidence to the contrary and 24 foreclose the record to that evidence. I am troubled l Ace-Federal Reporters, tric. 25 by that. I would have preferred to have seen counsel have
31,684
- 10-3-Suet 1 a more flexible approach to it.
I don't know if it's a 2 tactic or if you really need the cross-examination of 3 Mr. Lentz on this point. ,-.U 4 But I do recognize that throughout this pro-5 ceeding you have been prepared to have us decide critical l 6 issues on less than a full and accurate record. And this / 7 is an example of it. 8 MS. BERNABEI: Let me state our position, 9 because I don't think that's correct. 10 We think Mr. Lentz gave very credible testimony 11 to the NRC in 1979. I think when he came to his deposi-12 tion he gave less credible evidence, and it has changed c. (_) 13 considerably from his 1979 testimony to the NRC on parti-14 cular points of interest which he knew at that time would 15 be particular points of interest. 16 I think his prior deposition to the NRC frankly 17 is more credible and more reliable for this Board's -- 18 JUDGE SMITH: Well, you expect us now af ter 19 this exchange to pay any attention to any stipulated mail-20 gram evidence as his previous testimony when you frustrate 21 bringing his deposition testimony in? I don't know. 22 My inclination is, I'm making a judgment, and 23 I know what has transpired this morning and I'm looking at 24 prior interviews that you are offering, I don't know what Am-Federd Reporters, Inc. 25 I'm willing to accept.
m 31,685
- 10-4-Suet 1 MS. BERNABEI:
Okay. Let me state, first, 2 where we started off. We agreed -- and I don't think 3 legally we had an obligation to do so, bbt we did agree G 4 to stipulate in a portion of Mr. Lentz's testimony on 5 the alarm printout. That's the Licensee Exhibit 2 and 3. 6 And which is a much bigger portion than this, specifi-7 cally on the alarm printout. 8 We did so because we felt we had an adequate 9 opportunity to cross-examine him. And we felt that his 10 very answers would indicate that cross-examination and II the various answers he gave at different times would 12 indicate the credibility or lack of credibility of his 13 testimony. 14 When we felt we had an adequate opportunity 15 to cross-examine him at his deposition on our point, on-16 that particular point, we agreed to stipulate into evidence. 17 And I think that shows some flexibility, because legally 18 I don' t think we were obligated to do so. 19 On this particular point, I don't think we 20 took that opportunity, because that was not what we 21 were focusing on. 22 JUDGE SMITH: All right. 2 23 (The Board members are conferring.) 24 JUDGE SMITH: You are going to have to produce Ase-Federal Reporters, Inc. 25 Mr. Lentz if you want this testimony, not today but some
31,686 . #10'-5-Suet I other time I guess. 2 MR. LEWIS: We will advise the Board as soon 3 as possible. %) 4 JUDGE SMITH: I beg your pardon? 5 MR. LEWIS: We will advise the Board as soon 6 as possible as to our decision. We will take a look at-7 it. 8 JUDGE SMITH: All right. We would - we do 9 have an interest in closing this record. I would be 10 inclined to have come of the testimony next week in II Washington if wh want it. Okay. 12 That's our ruling. So, the exhibit is 13 rejected. 14 (The-document previously marked 15 as Licensee Exhibit Number 4 INDEXXX 10 for Identification is rejected.) 17 JUDGE SMITH: That is Licensee Exhibit 4 that 18 is rejected. 19 It really would be very helpful in considera-20 tion of the pt ties who are going to a lot of trouble'next 21 week'to travel and to change their plans and everything 22 else to have an early notification of Mr. Lentz, of your 23 plans for Mr. Lentz. There is' going to be a substantial 24 amount of personal hardship if we -- when we do this. ! waterd noormes. ine. 25 There may be another solution to it. And that i
31,687
- 10-6-Suet 1 is to close the record with everything with respect to all 2
parts of-this issue, begin a schedule for proposed find-3 ings, defer this sub, sub, sub-issue, I guess is what it 7]s - .\\ 4 is, until we return up here on the 2nd of January, and 5 reopen the record, take Lentz's testimony, and close it. 6 But in the meantime allow the record to be 7 closed in all other respects, allow -- this is a very 8 discreet point -- proposed findings to proceed and every-9 thing else proceed. That's what I would recommend. 10 . I don' t want to see next week disrupted. I II don't want to see you-foreclosed from what is obviously 12 relevant and important information with respect to your 13 case. So that is probably what I would propose that you Id do. 15 MR. BLAKE: I suspect that will work out. 16 Mr. Lentz is no longer an employee of the Company, and so 17 it may frankly take us that long to make physical arrange-18 ments. 19 JUDGE SMITH: Well, am I wrong about his 20 availability, then? Who is he, where does he live? 21 MR. BLAKE: He lives in upstate New York. 22 MS. BERNABEI: Syracuse, near Syracuse. 23 JUDGE SMITH: You know, I am distressed, Ms. 24 Bernabei, about your intrasigent attitude on this. I Ase reense nepo,w, inc. 25 simply don' t think it is necessary. I think you have
r 31,688
- 10-7-Suet 1
~' prevailed on a legal technicality. You are putting the 2 parties to a disproportionate amount of inconvenience. l 3 You have accepted, throughout this proceeding, without ] 4 live witnesses, without examination, information of equal 5 importance. And I really don't understand it. I didn't 6 understand that Mr. Lentz was so far away. 7 Let's consult. l 8 MS. BERNABEI: I would just say that we were 1 9 put to the inconvenience and the expense -- l 10 JUDGE SMITH: You are interrupting my consulta-l 11 tion. 12 MS. BERNABEI: I'm sorry. () 13 (The Board members are conferring.) I i 14 JUDGE SMITH: You stated, Ms. Bernabei, that 15 since you took this deposition you have come into pos-i 16 session of additional information which you would use i 17 in cross-examination; is that correct? 18 Is that what you stated? 17. MS.BERNABEI: Yes, that we would -- what I l 20 said, or what I meant to say, is we would be better 21 prepared to cross-examine him today than at the time of l () 22 ,his deposition. 23 JUDGE SMITH: Better prepared? 24 MS. BERNABEI: That's right. Ace-Federal Reporters, Inc. 25 JUDGE SMITH: Just on the question of l l i
31,689
- 10-8-Suet I preparation?
2 MS. BERNABEI: Well, you are talking now about 3 additional information. I think we would have additional () 4 information in terms of the strip chart itself. 5 We did not -- and I will state very frankly, 6 at that point we did not focus physically on the strip 7 chart, including the information Mr. Brill testified to 8 here today. If you will note -- if you read the entire 9 deposition, including the parts we stipulated in with the 10 Licensee, our focus in that was on the alarm printout. II And that is the part we felt we had an ade-12 quate opportunity to cross-examine Mr. Lentz on and we (,) 13 stipulated in with the Licensee. Our focus at that point 14 was not removal of the strip chart. We did question him 15 on that but not on this particular portion. 16 And we would be better prepared today to 17 cross-examine him, given what has happened in this hear-18 ing. I9 JUDGE WOLFE: Well, this part of the deposi-20 tion that the Licensee proposed to offer into evidence 21 does not bear on the techniques of the recording mechanism ,3 V 22 whatever. 23 MS. BERNABEI: I think -- 24 JUDGE WOLFE: It was the rebuttal testimony Am-Federal Reporters, Inc. 25 that the Licensee wishes to offer into evidence, as I
31,690
- 10-9-Suet 1 understand it, is whether Mr. Lentz saw this, these tapes 2
and whether he had any custody or charge over these tapes. 3 Isn't that it? So actually you have no j-, ( 4 right -- 5 MS. BERNABEI: It's -- 6 JUDGE WOLFE: -- to cross-examine'him in ,y 7 extansion of over the purpose for which they are offering 8 this portion of the deposition. 9 Isn't that correct? 10 MS. BERNABEI: I will have to review it. But II I don't think that's quite correct. As I understand it, 12 this has to do -- A .(,JD #10 13 Mary f1wsI4 15 l 16 l 17 l l 18 I l 19 20 21 ( 22 23 24 Am-reseres nemcwri, inc. 25
ll 31,691 Sim 11-1 JUDGE WOLFE: Well, let's get back to Mr. Lewis. j What is the purpose of the offer? 2 4 MR. LEWIS: The purpose of our exhibit will be 3 s to rebut TMIA's findings, which, as we understand and as TMIA 4 has just today stated, will be that the chart was, according 5 to the testimony of Illjes, removed and Xeroxed at the behest 6 of a GPU engineer on the 28th. 7 Richard Lentz was an engineer who was on the 8 island to collect data that evening. Ergo, Richard Lentz 9 jo obtained the copy, and this last point is an inference which 11 we-think is not supported, and in fact it is refuted by 12 Mr. Lentz' own statement. () The inference is that Richard Lentz obtained the 13 ja strip chart and brought it back to the observation center. 15 Richard Lentz was in fact part of the stipulation. The 16 stipulated portion of Richard Lentz' deposition that has j7 already gone in, that has already been received into evidence 18 was a portion where TMIA questioned Mr. Lentz on whether a 19 strip chart could be copied without removing the entire 20 strip chart from the rolls. 21 (Board conferring.) /~ ( 22 MS. BERNABEI: If I can just address, Judge Wolfe, 23 your point and Mr. Lewis' point. 24 4 p.e.rw n n.n, ine. We do have more information today about the 25 specific portion that the licensee wants to address, and that
31,692 S W r rn S P chart was Xerond on dat Sim 11-2 1
- V*"i"9*
2 I w uld also say that we believe there is a 3 O V credibility problem in this regard with Mr. Lentz today, 4 and we will be'very straightforward with that, and that the 5 Board should observe his demeanor on testifying on this 6 particular point. We don't think we focused on it in the 7 deposition adequately to bring that across to the Board. 8 JUDGE WOLFE: Well, see, here you go again. 9 10 We have told you that when you have objections that you are 11 to make your objection and exhaust yourself. Now you are 12 raising a new point, an altogether new point. O is S. 8EnnieE1: den t think se. 1 think it is 14 the same due process --- 15 JUDGE WOLFE: It is an extension of the point 16 that you have a right to have a live witness. 17 (Board conferring.) 18 JUDGE SMITH: We will let the ruling stand. Any 19 time during the week of January 2nd or during the remainder 20 of this first segment of the hearing you can bring Lentz in 21 if you see fit and we will get him on and off, and it will 22 be that very narrow subject matter of this hearing which 23 will remain open. Other than that we are closing the record 24 on the Mailgram issue and we will move to the proposed Ase-Federal Reporters, Inc. 25 findings. l
.31,693 -Sim 11-3 MS. BERNABEI: We have a couple of housekeeping 1 matters. We have made copies of TMIA Exhibit 38 and 39, 2 that is Mr. Abramovici's notes and one copy of Mr. Broughton's 3
- f. sU notes.
4 We have also made copies of TMIA Exhibit 33-F 5 which is the Boyer questionnaire which had a page missing in -6 the original exhibit. 7 JUDGE SMITH: All right. 8 MS. BERNABEI: And we would also propose to 9 10 distribute to the parties those pages of the Keaten notes 11 which have been agreed to as an official stipulated copy 12 between the parties. This would be substituted or put /3 together with TMIA Exhibit 10. j3 g JUDGE SMITH: Why do I have two?
- 4 (Pause.)~)
15 JUDGE SMITH: We have been handed the Keaten note-16 j7 book and what are we supposed to do? We are supposed to 18 substitute pages? 19 MS. BERNABEI: That is correct. 20 JUDGE SMITH: Are there any objections to the 21 substituted pages for Exhibit 107 That has been stipulated O 22 to. v 23 Now, Mr. Boyer, you have the whole questionnaire. 24 MS. BERNABEI: That is the whole questionnaire. Ase-Feuleral Reporters, Inc. 25 JUDGE SMITH: Which we will substitute for the
31,694 'Sim 11-4 entire Exhibit 33-F. y ~ And then we have this. What is this? 2 3 MS. BERNABEI: That is 38 I believe. Those are the Abramovici notes. 4 5 (Pause.) 6 MR. LEWIS: No, Abramovici is 39. MS. BERNABEI: That is correct, Exhibit'38. 7 JUDGE SMITH: All right. What is the other one? 8 MS. BERNABEI: It is one page of Mr. Broughton's 9 10 notes and it is Exhibit 39. 11 JUDGE SMITH: Abramovici is 38 or 39 now? 12 MS. BERNABEI: Abramovici is 38. -( ) 13 MR. GOLDBERG: Is that received into evidence?: 14 MS. BERNABEI: Yes. 15 JUDGE SMITH: Yes. 16 MR. GOLDBERG:. I don't have it in evidence. 17 MS. BERNABEI: Well, I will move it into 18 evidence. 19 JUDGE WOLFE: Well, it is part of another exhibit, 20 but it is smaller; isn't that right? 21 MS. BERNABEI: It is 39. Broughton is 39 and () 22 that is the one that is a portion of another exhibit. 23 JUDGE WOLFE: Oh, all right. 24 JUDGE SMITH: I thought we had received Abramovici's Aes-Fesferal Reporters, Inc. 25 notes into evidence. But if we haven't, is there any l
31,695 .SimRll-5' I objection? 2 (No response.) 3 r~x JUDGE SMITH: All right. It is received. I N-) 14 thinkfit;.has been received twice. 5 (TMIA Exhibit 38, previously 6 marked for identification, was 7 received into evidence.) 8 JUDGE SMITH: And Broughton is 39, and did we 9 receive that? I think we have. 10 In any event, if we haven't, we have now. 11 (TMIA Exhibit No. -39, previously 12 marked for identification, was ~. (s)s received in evidence.) INDEX MS. BERNABEI: There are two remaining issues. 15 One is the joint stipulated exhibit which has been labeled 16 32 with subparts A, etccetera. We just have to know how II the Board wants those received. 18 It is' essentially a big pile of exhibits. 19 JUDGE SMITH: Of 31-A, B and C? O MS. BERNABEI: And there are others which follow. 21 That is the stipulated book of exhibits. (~s \\- JUDGE SMITH: I' thought the stipulated book of 23 exhibits would just continue the item numbers.in the Joint l 24 Exhibit 1, or doesn't that work? 25 MS. BERNABEI: We made it a TMIA exhibit.
.( l 31,695,4 Sim-11-6 JUDGE SMITH: The whole extra. book? 1 MS. BERNABEI: That is right. That was on 2 Licensee's suggestion. We made it a TMIA exhibit. So it is ) now in the record as TMIA Exhibit 32-A, B and C, through K. 4 MS. BERNABEI: It is in the record as 32. It is '5 the collective results of Tuesday's argument about portions 6 of depositions. 7 JUDGE SMITH: Right. I did not understand that 8 process. 9 MR. BLAKE: And we have had occasion since to 10 refer on the record to a couple of those and they have been l identified as 32-A, B and C so far. That doesn't include 12 -all of those which would have been a portion of TMIA Exhibit (_f-~) D 32. 14 JUDGE SMITH: All right. 15 MR. BLAKE: What we should do is identify the 16 other documents that are in that package and give them letters 17 beyond C and then just --- JUDGE SMITH: That would be logical it seems 19 'tomme. 20 MS. BERNABEI: Okay. I can identify them at this 21 /m time. (_) 22 JUDGE SMITH: How long_is that going to take? How many are there? MS. BERNABEI: Through K. A through K. I don't-25 ~ care. I just brought it up so that the Board would understand
. = J 31,696 Sim 11-7 this book of documents. j JUDGE SMITH: I guess we have to get it.in 2 f 3 the transcript. Go ahead and do it quickly, would you please. ,,U 4 MS. BERNABEI: I will not repeat A, B and C. 5 D are portions of Mr. William Yeager's deposition s 6 taken on October 10, 1984. 7 32-E are a portions of Richard Bensen's deposition. 8 32-F is a November 1, 1984 letter from Thomas 9 Crimmins to John Thorp. 10 32-G is portions of Walter Marshall's deposition. Il 32-H are portions of Mr. Abramovici's deposition 12 of October 15, 1984. () 13 32-I are portions of Richard Lentz' deposition 14 of October 15, 1984. 15 32-J are portions of Michael Ross' deposition of 16 September 27, 1984. 32-K.is the. entire. James Moore deposition of" 17 r 18 September 26, 1984. 19 Plus corrections. 20 JUDGE LINENBERGER: Plus corrections to the entire 21 package or just to K? O(_/ 22 MS. BERNABEI: To K. 23 JUDGE SMITH: That is a stipulated exhibit? 24 MS. BERNABEI: Yes. Am-Federal Reponers, Inc. 25 JUDGE SMITH:. All right, it is received. That L
.g 31,697 Sim'11-8 1s received. That is TMIN Exhibit 32 D through K? 2 MS. BERNABEI: It.would be A through K. I don't 3 (~'i think the other --- 4 JUDGE SMITH: A through C had not previously been 5 r ived? 6 MS. BERNABEI: I do not believe so. 7 JUDGE SMITH: All right. That is a correction 8 then, A through K. 9 (TMIA Exhibit 32-A through 32-K, 10 inclusive, were marked for 11 identification and received into 12 evidence.) I X 13 MSf.t BERNABEli The only other remaining exhibit 14 that I think is pending before the Board is TMIA Exhibit 25 ,15 which is the OIA report. 16 JUDGE SMITH: We dealt with that this morning. 37 MS. BERNABEI: You received that? 18 JLDGE SMITH: Yes. j9 MS. BERNABEI: Okay. Thank you. 20 JUDGE SMITH: Are you going to provide copies of 21 those latest exhibits to the Board, the 32 series?- 22 23 MS. BERNABEI: Yes. 24 JUDGE SMITH: Are you going to do it now or are Ase-Federal Reporters, Inc. 25 you going to do it by mail or how? .s 1.
31,698 s Sim.ll-9 ~ j MS. BERNABEI: We can do it right now. 2 Unfortunately, we had some problem biding it. 3 I'- (Board conferring.) V 4 JUDGE SMITH: See, this is what we did not want, 5 loose papers. 6 MS. BERNABEI: I understand that. That is why 7 I was hoping it would just be a continuance. 8 Well, we have no choice. So we will take them 9 the way you have them. 10 MS. BERNABEI: What we could do is provide them to you next week in Washington bound, if you would like that. 12 The parties have the exhibits. .!k) it is not a problem. It s. would be for the Board and for the court reporters. 14 JUDGE SMITH: Well, we certainly can wait _until 15 next week to get them. MS. BERNABEI: Okay. 17 i (Pause.) 18 JUDGE SMITH: Are you ready for the proposed 20 findings? MR. BLAKE: I believe that is the only remaining 21 (') P ece of business. i 22 JUDGE SMITH: What will you do? You will provide 23 24 a bound version of the exhibits to the reporting service? hresores nepenses,Inc. 25 MS. BERNABEI: Yes. L.
r 31,699 P# Sim 11-10 1
- W 11, an we m ve to the proposed findings now.
2 I guess we will begin with licensee's proposal. 3 I have read through it a couple of times and 4 it somewhat surprised me. It is not exactly how I had 5 envisioned it. However, I think that it covers every approach, 6 every issue that we have heard here. 7 I haven't consulted with the other two Board 8 members, but I don't have any problems with it. I am sure 9 10 it will direct us to the proposed findings. 11 Just remember, the purpose of this is not to describe an issue or a sub-issue or anything else. It is 12 to enable us to find the position of the party as to each 13 issue without reading a large part of the proposed findings. 14 We want to know where we can find each proposed 15 16 finding on each issue. 17 MS. BERNABEI: Okay. We have grave problems with 18 this outline. I can just say that essentially the way we 19 have perceived -- the way we have perceived this is as 20 essentially licensee's argument on the issue. 21 What I would propose is that we submit another ) 22 outline for the Board's consideration. Essentially what we 23 tried to do was outline the issues with two ideas in mind, 24 one, to track as closely as possible the Board's language and Ace-Federal Reporters, Inc. 25 the Appeal Board's language and their opinions.
31,700 I Sim 11-11 1 Two, to ensure that the' factual description of ( 2 any of the issues would not have to be repeated with each 3 argument, and I think the licensee's outline suffers from c i 4 both of those infirmities. 5 One, essentially the issues are phrased in terms 6 of the licensee's argument and not in terms of how the Board l 7 itself phrased its issue. 8 And, secondly, that there will be several factual 9 points which will have to be repeated several times in each 10 argument. l II l I could propose to the Board now our alternative 12 structure,'and again what we tried to do was track the Board's ( 13 own language in its opinion, since I think what should be done Id is essentially a rephrasing of the issues in the logical form. 15 JUDGN SMITil: W e l l', 'I sam afraid you want to get 16 into a debate on the substance of issues, and that is not l I7 what we want. We simply want an identifiable place in the 18 proposed finding where an issue is discussed. U I read it through anticipating before I read one 20 word that you were going to argue about it. I just anticipated 21 it. So I read it through to see if it had the defect that l 22 you say it did, and on my own I could not find that defect. 23 I could not find any bias in it. 24 I read these various words and I do not see what As-rese, i nose,w,. inc. 25 you are talking about.
31,701 'Sim-11-12 MS. BERNABEI:.Okay. Can I give you an example', j 2 Judge Smith? ~ 3 JUDGE SMITH: All right. 4 MS. BERNABEI: For instance, first of all, I do 5 n t understand the issue to be what it is stated to be on 6 Item 1, whether Mr. Dieckamp acted in careless disregard for 7 the mailgram's accuracy. JUDGE SMITH: I am going to have a hard time g agreeing with you because I think they have captured almost 9 10 my own language. 11 MR. BLAKE: That came out of a Board memorandum 12 and order. MS. BERNABEI: The Board memorandum that I I 13 14 understand was did Mr. Dieckamp know or should he have known 15 that the mailgram was inaccurate. I believe that --- 16 JUDGE SMITH: Now you-are arguing the issue. 17 MS. BERNABEI: No. I believe that is the issue 18 as phrased by the Board. 19 JUDGE SMITH:- I am not going to argue the issue 20 with you. We have gone over it. And, as a matter of fact, 21 I recall two and maybe three times discussing with you your ( 22 inaccurate concept of the scope of that issue. You can use it or not. I am willing to accept -- 23 24 if this is going to be the basis of your argument, I am willing m noperwe, W. 25 to accept the licensee's proposal and you can be bound-by it.
m. 31,702 Sim 11-13 You can rephrase the issue if you want to in 2 your proposed findings. You certainly are not obliged to 3 accept that as your view of the issue. /s . tg) We will accept this as licensee's burden of 4 E5 Proof... Having the burden:; of: proof, the licensee then is 6 going to have to organize their proposed findings in some 7 way. This is certainly an appropriate way. 8 What we are telling you is if you want us to .9 ' be assured that we will pick up all of your argument on 10 this, you had-better have a comparable organization. Other-i 11 wise, it is physically impossible to every time you address 12 an issue to read all of the pages of proposed findings-that 'I ) 13 you have. \\/. s 14 MS. BERNABEI: Okay. I can assure the Board 15 l we will not make the same arguments that the. licensee has I 16 made in this outline,.specifically whether Mr. Dieckamp.had t 17 a reasonable - -I do not believe that these are issues before 18 the Board. On page 2, Item 4, did Mr. Dieckamp have a reasonable t '20 basis to believe that subsequent evidence on the mailgram was 21 available to mailgram recipients,. supposedly the Commissioners ,.c 22 k-in Uhis case. 23 JUDGE LINENBERGER: Ms. Bernabei, excuse me, but 24
- I' hear you going into the very. things that the Chairman just gw g
-25 said the Board does not want to go into at this time. b . \\l l [q r
p 31,703 j The Chairman further advised.you that if you had Sim 11-14 a different view of the matter, you had every opportunity 2 D E 11
- Y "#'different view.
3 -(% ' We only' indicated our acceptance of what the t ~ 4 liensee has submitted. You have characterized that submittal 5 as an' argument that this Member of the Board does not charac-6 terize it as an argument. But that-is a minor point. 7 Let's just say if you view life differently, you 8 certainly have a right to approach it the way you see it. _p 10 JUDGE SMITH: You.see, it is not up to you to 11 say that the licensee cannot argue this as an issue at this time. 12 () MS. BERNABEI: I agree. 13 JUDGE SMITH: All right. Therefore, your remedy, 34 15 ifyy u don't believe -- is that 4-B you were referring to? g MS._BERNABEI: I am talking about all the items --- JUDGE SMITH: No. The one that you just read. 17 r 18 MS. BERNABEI: 4-A. i l 19 JUDGE SMITH: 4-A. 'All right. If you believe 20 that that is not appropriately an issue, no problem. Just 21 do not address it. But if you believe that that is an issue, . l( ) 22 do not make us look for it someplace else throughout all of 23 your proposed findings. 24 MS. BERNABEI: Okay. So if I understand corectly, i As>Federsi neporiere, Inc. 25 we are free to organize our proposed findings in a way that T -
_ _ _ _ _ _ _ - _ _ _ _ - _ _ - _ = _ _ _ _ _ - _ _ _ _ _ _ _ _ _ _ 31,704-Sim 11-15 1 we think addresses the issues'as outlined by the. Board in
- 2 its prehearing orders and during this hearing?
3 We do not want to. follow this outline becauseL 4 this is the licensee's argument. 5 JUDGE SMITH: Look', if you'do not follow an 6 outline which~ addresses thesenpoints or your version of- .7 ithese points -- you are not ignorant of the issues in this 8 . case. 9 MS. BERNABEI: I understand that. 10 JUDGE SMITH: When they make a statement on one II of~these numbers,.you know full well exactly what they are 12 talking about. You know what it is. If you don't know what . 0-is it 1 tae= wc=1a a ve te ce c1=ae ta t v e c t
- e 14 ancontribution to the record.
There is nothing-here that 15 you sitting there do not know what they are talking about. end Sim 16 Younknow all of it. Joe fols 17 18 19 20 21 22 23 ^ 24 Ase-Federd Reporters, Inc. '25 b ._ j
12-1-Wal-31,705 1 Now, I want you to follow this organization. You 2 are free not to follow.it. If you do not follow it, you have 3 Hno assurance that we will accept your proposed findings on O 4 that particular issue, because we may not even' find it. 5 MS. BERNABEI: What I would say, I would move -- 6 JUDGE SMITH: I am giving you the opportunity to 7 present your proposed findings in a fashion which will assure 8 1 Su the best;.:that,the Board will see your arguments and s J 9 understand them. 10 MS. BERNABEI: Okay. Then I would move-to I 11 certify the Board's acceptance of Licensee's proposed findings, 12 and -- [d 13 JUDGE SMITH: You are free to reject'them. You 14 don't have to do it. 15 MS. BERNABEI: What I am saying is the Board has 16 indicated its predetermination to accept this outline, and 17 reject other parties organization issues. I do not think this 18 fairly states the issues. I think it is their argument. 19 If we are forced to address the issues in this 20 fashion, we are foreclosed from addressing the issues before 21 this Board. ,~ 3,) 22 JUDGEHSMITH: - You do whatever you wish. Anything 23 further? 24 MS. BERNABEI: Yes. I move to certify this to the Ace-Federal Reporters, Inc. 25 Appeal Board. ...,..,_..r. -m
12-2-Wal 31,706 'l JUDGE SMITH: Denied. Anything further? o 2 MR. GOLDBERG: I have just one comment on the 3 Licensee's outline. As a general matter, as far as the V 4 substantive issues before this Board, I think it captures 5 everything, and the parties findings can be proposed in 6 accordance with this outline. 7 There is one-concern that I do have, and that 8 is that over the Staff's objection, there was certain 9 collateral issues introduced into this proceeding which we 10 didn't feel belonged here, were necessary, but nevertheless y 11 were litigated, and now for which I will propose findings. 12 And I am not certain at this time that it can be () 13 done throughout this outline, and I may feel it necessary to 14 add another section which very clearly identifies another 15 sub-issue on which I can propose findings all in one place, 16 for the same purpose the Board wanted an outline to follow. 17 Rather than weave it through this outline, I may want.a separate 18 section on other issues which are related to the Dieckamp 19 mailgram issue which were litigated in this proceeding. 20 JUDGE LINENBERGER: Mr. Goldberg, can you give 21 us a for instance of a collateral issue? () 22 MR. GOLDBERG: Yes. The adequacy of the investi-23 gation into information flow conducted by the NRC Staff. 24 JUDGE LINENBERGER: Okay. - Am-Federal Reporters, Inc. 25 JUDGE SMITH: I am somewhat concerned about what
9. 12-3-Wal 31,707 1 is going to' happen about the proposed findings.- 2 Number one, you will recognize that the rules 3 provide that when ordered to file proposed findings, and .O 4 failure to file' proposed findings on a particular issue would 5 be a default. You recognize that as being a part of the 6 Commission's rules? 7 MS. BERNABEI: Yes, I understand under certain-8 circumstances that is recognized as a default. 9 JUDGE SMITH: And consistent with that regulation, 10 you are directed to file proposed findings on issues that you 11 wish to pursue, and if you fail to do it-you will be in 12 default. ( ) 13 This is an instruction to al.1 parties, not just 14 you, but to all parties. 15 MS. BERNABEI: Perhaps I could suggest -- 16 JUDGE SMITH: I'am just now touching base with the 17 regulation which first requires we instruct you to file 18 proposed findinds, and we are instructing you to file proposed 19 findings, and we are informing you if you fail to file proposed 20 finding;s, you will be in default. 21 MS. BERNABEI: I understand the regulations, 22 Judge Smith. 23 JUDGE SMITH: I know. And you also understand 24 the regulations require me to inform you of this? Ass-Federal Reporters, Inc. 25 MS. BERNABEI: Yes. i.
.4 1
- ,'12-4 WnlH 31,708 4
4 1 JUDGE SMITH: And I'am done doing-that. ~ 2 MS. BERNABEI: So -- 3 JUDGE SMITH: You understand you have received O.
- V
- 4 the1 notice.
5 MS. BERNABEI: Of course. I-read the rules, 6 and have participated in proceedings :such as this. JUDGE SMITH: You are being-inpertinent. t 7 MS. BERNABEI: I am not. I don't see the purpose 8 j 9 of the= Board's admonition. i '10 JUDGE SMITH: The purpose of the admonition-is Lil that the _ rules require that we tell you this. And I am 12 satisfying that portion of the rule. '( ). 13 MS. BERNABEI: If I can state our position.. 14 Our position 11s'this outline does not fairly state the issues. i 15 If we are forced to follow this outline, and the Board has 16 suggested we should, otherwise we may default on certain-17 points. We feel we would not be given a fair opportunity i '18 to present our case. These are not the issues that you 19 outlined in your prehearing order. i 20 These are not the issues that the Appeal Board 21 told you to address, and these are not the issues that have () 22 been litigated in this proceeding. 23 JUDGE SMITH: You may, if you wish, however, 24 redefine the issues as you submit your proposed findings, but Ase-Federsi neporiers, Inc. 25 you should follow this organizational outline. You are not,
12-5-Wal 31,709 1 I repeat, not required to accept this definition of any issue. 2 We are talking only about the physical organization 3 of your proposed findings. Nothing else. The physical 73.) 4 . organization of your proposed findings. How we can look in 5 1 Jur proposed findings, and what you have to say. 6 If you wish you can, for example, take Item 1. 7 Use that and you can say your view of Item 1. Now, you have 8 not come to us and told us any view how the organization, qua 9 organization is unacceptable. Every word you have stated 10 now has been the definition of the issue does not meet your 11 standards, 12 And this is not what we are talking about. And () 13 I am very frustrated that I can't seem to get you to understand 14 the difference between a physical place in proposed findings, 15 as compared to the language and ideas of the scope of the issue. 16 MR. AU: I am trying to understand your instructions 17 in regard to this outline. Suppose we were to file say "X" 18 facts relates to something. We then say that relates to 19 Issue 1-C and 2-B, and 3-D, or whatever? 20 JUDGE SMITH: You can do it that way if you wish. 21 It is very hard to work with that. I have seen very, very O lx_j 22 often proposed findings that will take issue No. 1, for example, 23 whether Mr. Dieckamp acted in carefless disregard, up here 24 in all places throughout all of the proposed findings. Ace Federd Reporters, Inc. 25 Maybe throughout. Another example, and another
12-6-W21 31,710 I example of careless disregard. From page 1 through page 200. 2 When-it comes time to write the decision, it 3 is virtually impossible to carry in your mind all those ~ ~ 4 references, and it is virtually impossible to go back to the 5 proposed finding and see what the parties believe on'that 6 . issue, and I am simply trying to afford Ms. Bernabei and you 7 an opportunity to have the most effective assurances that your 8 arguments will be understood. 9 Now, other than that we can't help you any more. 10 I have viewed this entire thing to be a matter to assist you 11 to have your point raised. We will read the Licensee's proposed ~ 12 findings exactly the way they have them organized, because we 13 must. 14 MS. BERNABEI: Well, can I just -- I don't. 15 understand how we can organize. I don't understand the 16 organization presented here. Let me give you one. example. 17 The first question is whether Dieckamp in sending the mailgram 18 acted in careless disregard for its accuracy. I 19 It seems to me that nowhere in there is there 20 some issue, or sub-issue about whether the mailgram is 21 accurate. I) 22 That' is a necessary component of whether Mr. 23 Dieckamp acted in careless disregard for,the mailgram's accuracy. 24 Whether the mailgram was accurate.
- Ase Federes nepo,sers, Inc.
j 25 JUDGE SMITil: That is exactly right. k
II 12-7-Wel 1 MS. EERNABEI : So where do we put the information 2 about whether or not the mailgram was accurate. 3 JUDGE SMITH: That is in there. I can find it. -[D t %/ 4 If you are saying it is incomplete, that is another matter. 5 MS. BERNABEI: I don't understand the organization. 6 JUDGE. SMITH: Then I can't help you, counsel. 7 As a matter of fact, however, I have watched your wrestling .8 with the issues in the case, and I do believe you have had i 9 trouble understanding the issues, and I can't provide any 10 further guidance for you. You read what we had to say, and 11 this is what we are expecting. 12 MS. PERNABEI: Judge Smith, can I state for the (,c) 13 record what our proposed outline would be, and then maybe you t ~ 14 can see -- 15 JUDGE SMITH: I don't want you to read it. It 16 is late.. 17 MS. BERNABEI: I will only take a few minutes. 18 JUDGE SMITII; All right. 19 MS. BERNABEI: One, is the mailgram accurate? 20 That is -- 21 JUDGE SMITH: That is a good point. '() 22 MS. BERNABEI: Two, assuming that the mailgram 23 is inaccurate, did Mr. Dieckamp know at the time he sent it 24 it was inaccurate. Specifically, what information was Ass-Federal Reporters, Inc. 25 available to him. Given the purpose of the mailgram, did he
a 12-8-W21 31,712 j expect the mailgram to be' relied on in the regulatory process, 2 and did he intentionally misstate the information that was 3 available to him. O .I' ') 4 Third' point, if it was correct that Mr. 5 Dieckamp did not know it was incorrect on May 9th, should 6 he have known that it was incorrect. First you define Mr. 7 Dieckamp's duty regarding the accuracy of the mailgram 8 given its purpose, and secondly, if he had any obligation to do an investigation or inquiry to insure its accuracy, 9 10 and finally whether or not he took those actions to meet 11 up to his duty to ensure its accuracy. 4 12 And the last point being did he have any duty j ()? 13 to correct it. One, if it is inaccurate. If he did not 14 know at the time he sent it it was inaccurate, but he 15 subsequently learned it was inaccurate, did he have a duty 16 to correct it. 17 That would be a sensible outline for thete 18 points. On,e' predicated on the other. 19 JUDGE SMITH: I think you could make all those 20 points with Licensee's outline. It would assist us if you 21 would. However, if you make the points that you wish to make, r' ( ), 22 and you make them within an identifiable organization, and you 23 don't talk about them all throughout your proposed findings 24" we can work with it. Ase-Fadoral Reporters, Inc. 25 I am just simply informing you as my experience
12-9-W21 31,713 i in. writing decisions, if you make arguments intertwined.all 2 through-your proposed findings, you may or may not succeed 3 in getting them cnsidered the way you want to. G 4 All right. Is there anything further? 5 MR. BLAKE: You want to' discuss' schedules? 6 JUDGE SMITH: What do you propose? 7 MR. BLAKE: Although I would like to do better 8.than the regulations, since we are talking about one issue, 9 it is an extended schedule, and we are also facing the 10 traning hearing and, therefore, I would propose that we 11 follow the normal schedule, and not try to do better than 12 that. () 13 That schedule would be for Licensee on January 14th, 14 for TMIA and the Commonwealth, on January 23; for the NRC Staff 15 on February 4; and thenan opportunity for Licensee's reply, 16 after -- finally by the Staff February 14. End 12. 17 Suet fois. 18 19 20 21 ) 22 23 24 - w reseres nepo,mes,Inc. 25
13,714 8
- 13-1-Suet 1 That's what I put on the table, and that 2
essentially tracks the thirty day, forty day, fifty day 3 business accounting for week-ends. .,-s j !} 4 JUDGE SMITH: Mr. Au. 5 MR. AU: Okay. I know I'm going to have a 6 Problem meeting January 23rd. I have scheduled an 7 argument in the Sixth Circuit that preceding week. 8 JUDGE SMITH: You know, you are free-to file 9 earlier if you wish. 10 MR. AU: I understand that. And certainly 11 we will begin working on that. 12 JUDGE SMITH: So, you oppose that schedule? . () 13 MR. AU: I don't have a calendar in front of 14 me. I'm trying to look at the precise dates. 3 15 JUDGE SMITH: Mr. Au, may I expect that your 16 Proposed findings will have some relationship in proportion 17 to your participation in the case? Hg MR. AU: We will not be filing a broad range 19 of Proposed findings. It will be on selected issues, as 20 we see it. 21 If I can be given until January 25th I think () 22 that would be acceptable. 23 JUDGE SMITH: All right.. We have 1/14 for 24 the first filing, 1/23 for -- Asefederal Reso,w,s, Inc. 25 MS. BERNABEI: We have an objection to that.
7 31,715
- 13-2-Suet 1 JUDGE SMITH:
Yes. I want to get these 2 scheduled. 3 MR. BLAKE: 1/23, TMIA/ Pennsylvania. February x 4 4 -- 5 JUDGE SMITH: For TMIA and Commonwealth? 6 MR. BLAKE: Right. And then 2/4, February 4, 7 Staff. And 2/14, the reply. 8 JUDGE SMITil: All right. Would you comment? 9 MS.BERNABEI: Yes. At this point, we are 10 lead Intervenor on several issues on the training issue II and, therefore, we don't know exactly what the division 12 of responsibility on those issues will be at this time () 13 until af ter we have had time to consult with UCS. But 14 it is expected that we will maintain that position on 15 some of the incucc. 16 Given that and given the holiday season at 17 the end of the month, I would propose three additional 18 weeks for our findings, until February 13th. I9 JUDGE SMITII: Mr. Goldberg? 20 MR. GOLDBERG: I don' t have any objection 21 to the Licensco's proposed schedule. 7's' ( 22 JUDGE LINENBERGER: Ms. Bernabei, do I 23 understand your proposal to be to defer the January 23 24 date to February 15th? Ace r d.re n. pori.,i, Inc. 25 MS. BERNABEI I said 13th, which I think is
31,716
- 13-3-Suet 1 three weeks.
2 JUDGE LINENBERGER: All right. The 13th? 3 Excuse me. Thank you. 4 MR. GOLDBERG: Does the Licensee have any 5 position on Ms. Bernabei's request for additional time? 6 MR. BLAKE: No. As I stated earlier, I 7 started by hoping that it was one issue, that we would 8 be able to improve on the phenomenal schedule but recog-9 nizing that we had the training hearing. 10 I thought it was a fair schedule, since we 11 have to go first and we are the closest in time to the 12 holiday period and the training issue. O 13 Te the exeene the Beerd thinks thee seme 14 additional time is in order, I would urge them to extend 4 15 the schedulo right along, keep the same intervals such ~ 16 that if TMIA's schedule is seen by the Board of January 23 17 to be too short on this issue and an additional week is 18 granted to them I, too, would seek the additional week. 19 We will moot the schedulo, and we will meet 20 whatever schedule is put on. But to the extent overall, 21 there is some offect on the bottom line that we would like 22 to got the same advantage that other parties do. 23 (The Board members are conferring.) 24 JUDGE WOLFE: Off the record. l Ase resores neswere,ine. I 25 (An off-tho-record discussion onsues.) 1
r 31,717
- 13-4-SueTI JUDGE SMITH:
We will give some of the relief 2 requested by Three Mile Island Alert but not all of it. 3 f3 Our consideration is, we can't really give too much weight N.] 4 to your perceived responsibilities in the training issue 5 but we are also aware that you have been occupied full 6 time here, and that the rest of the year is the holiday 7 season. 8 We recognize that the Licensee has a right to 9 as prompt as possible disposition in this issue, and that 10 would begin with proposed findings. But at the same time, Il there is no point in pushing everybody to get proposed 12 findings into our desk and have them sit there unread g (,' 13 when we are too busy to read them. 14 So, we are taking into account the fact that 15 we want to give the parties the maximum amount of time i 16 consistent with the utility. And we don' t think that we 17 can, given how the training issue is coming along, and 18 other matters that we have neglected at the office, wo 19 think that probably the earliest we can begin dealing with 20 proposed findings would be the 28th of January. 21 So, that would be adding two weeks. Even then 22 it may be optimistic. I don' t know how that training issue 23 is going to go. 24 But we think that that is a realistic time when A s r w r : n.po,,.. ene. 25 we will have that issue put to bed and be free to turn I
31,718
- 13-5-Suet I our attention to the training issue.
And then we will 2 follow the regulatory intervals af ter that, which we 3 haven' t calculated. 4 That would be the 28th plus ten days. 5 MR. BLAKE: If I can just get agreement now. 6 My suggestion would be for the TMIA/ Pennsylvania then 7 following the Board's advice, rather than January 23rd 8 for the forty day interval it would now be February the 6th. 9 Do we have agreement? 10 MS. BERNABEI: Right. II JUDGE SMITII: Okay. 12 MR. BLAKE: The next date would be NRC Staf f, O 13 rather than February 4 would be February the 18th, although (._y Id I have a red -- it's red on my calendar which suggests to 15 me it may be a birthday of come sort, and so I would state 16 it would have to be the 19th. 17 MR. GOLDBERG That red is also on the Federal 18 calendar as a holiday. I9 MR. BLAKE: All right. So, it's going to be 20 February 19th for the NRC Staff. 2I MR. GOLDBERG: I would rather have it February qkj 22 15th instead of the 19th. 23 JUDGE SMITil: Yes, make it the 15th. We 24 are encouraging you, Mr. Goldberg, to use the method of Aos Federet Reporters, Inc. 25 adopting piggyback findings, adopting those that you agree
31,719
- 13-6-SueTG with by reference and then supplementing only where you 2
disagree or you have to supplement. 3 MR. GOLDBERG: Yes, that's our intention. r- ~j 4 February 15th for the Staff? 5 JUDGE SMITH: Yes, that would be helpful. 6 MR. BLAKE: And that would be the 25th 7 for Licensee. 8 JUDGE SMITil: Okay. That would be satisfactory. 9 And we are going to impose a page limitation of two hundred 10 pages on this, including appendices but not including the Il table of contents. 12 MR. GOLDBERG: And it must be double-spaced. (~h i.,_) 13 JUDGE SMITil: It must be double-spaced and I4 I guess footnotes, a reasonable amount. CHD #13 15 i 16 l Mary flws 17 18 19 20 21 m ,j 22 23 24 As Federal Reporters, Inc. 25
.31,720 Sim' 14-1 MR. GOLDBERG: I had two other matters in I connection with findings that I wanted to raise, and that 2 is that some Licensing Boards have asked the parties to 3 GV submit an opinion separate from and to be followed by findings 4 of fact, and that has not been this Board's practice in the S past in this proceeding, and I just wanted to get clarifica-6 tion that you are not asking the parties to submit a separate 7 opinion to be followed by separate findings of fact? 8 (Board conferring.) 9 JUDGE SMITII: We don't require that. I guess we have somewhat abandoned any hope of having agreed upon background data. MS. BERNABEI: Sure, we could do that. g] (/ MR. BLAKE: Don't abandon it. I am going to make a draft and give it a try. JUDGE SMITH: Okay. That would be helpful if you could do that. MR. BLAKE: We will keep trying. JUDGE SMITil: All right. Anything further? (No response.) 20 JUDGE SMIT!!: All right. With that we are 21 (~ adjourned and the record is closed except as I indicated with (,) 22 respect to Mr. Lontz. (Whereupon, at 1:33 p.m., the hearing adjourned.) Ase-ressem neporwes. inc. 25
CERTIFICATE OF OFFICIAL REPORTER This is to certify that the attached proceedings before the UNITED STATES NUCLEAR REGULATORY COMMISSION in the matter of: NAME OF PROCEEDING: Metropolitan Edison Company, Three Mile Island Nuclear Station, Unit 1 O f DOCKET NO.: 50-289-SP PLACE: Harrisburg, Pennsylvania 'DATE: Friday, December 14, 1984 were held as herein appears, and that this is the original trascript thereof for the file of the United States Nuclear Regulatory Commission. (Sig 47 (NED) GARRETT WALSH, JR. Official Reporter Reporter's Affiliation 4 Ace-Federal Reporters, Inc. W M ~~ MARY SIM6NS ] Official Reporter Ace-Federal Reporters O MJQw Of ficialWoporte r Ace-Federal Reporters, Inc. er-- v- +-+----r .------v-,-----,.-,-y., _}}