ML20207S595

Forwards Four Transcripts of Interviews by House Committee on Interior & Insular Affairs Re Mystery Man Issue, Including:Jh Chwastyk 830510,WA Marshall 830512,CC Faust 830401 & G Kunder 830516 Interviews.Related Correspondence

ML20207S595
Person / Time
Site:	Crane
Issue date:	03/17/1987
From:	Doris Lewis GENERAL PUBLIC UTILITIES CORP., SHAW, PITTMAN, POTTS & TROWBRIDGE
To:	Johnson G NRC OFFICE OF THE GENERAL COUNSEL (OGC)
References
CON-#187-2825 CIV-PEN, EA-84-137, NUDOCS 8703200077
Download: ML20207S595 (200)

Text

2225 RELATED CORHt.bPW"'bcr~ 7 "- - n &3 26 Q v /E s

Pan' a h.,,h.........n.~.n DOLMETED SHAW, PITTMAN, PoTTs & TROWBM6GE

.v~....i...e m o...or...

.. co.

87 MAR 18 A10:44 23eo ~ sr. cr. ~..

TELEm/CA.LE WASHINGTON. D. C. 20037 vinoimia orrie, C9-ae93 (.MawkAw w.w) isos ramme catDat ontva tr*Eoat o E7'o o (acc'ess e47' OFFICr se a urt[fJ y 00CKEib4Gi SEFvicf.

1, c.co.,,,

8 RANCH (zoa aza.27eo a aza.37ei QAVID R. LEWIS

(*

n h D, 19 U George Johnson, Esquire Office of the General Counsel U.

S. Nuclear Regulatory Commission Washington, D.C.

20555 In the Matter of GPU Nuclear Corporation (Three Mile Island Nuclear Station, Unit No. 2)

Docket No. 50-320 -- EA 84-137

Dear George:

q Enclosed are copies of four transcripts, which GPUN recently obtained, of interviews conducted by Henry Myers and the Staff of the House Committee on Interior and Insular Affairs, relating primarily to the " mystery man" issue addressed by Mr. Parks.

They are: an Interview of Joseph H. Chwastyk (May 10, 1983); an Interview of Walter A. Marshall, Jr. (May 12, 1983); an Interview of Craig C. Faust (April 1, 1983); and an Interview of George Kunder (May 16, 1983).

GPUN is producing these documents pur-suant to Interrogatory 11 of the NRC Staff's First Set of Inter-rogatories to GPU Nuclear Corporation (Oct. 9, 1986) and Document Request 7 of the NRC Staff's First Request for the Production of Documents from GPU Nuclear Corporation (Oct. 9, 1986).

Sincerely, 8703200077 870317

'f l

PDR ADOCK 05000320 PDR David R. Lewis I

G Counsel for GPUN Enclosure cc: Service List DRL:pr cc:

SPPT ELB / JPH / DRL / CBA GPU Clark, Liberman, Thorpe Standerfer, Arnold, Stier BECHTEL:

B.

Kanga, R. Garb THELEN, MARRIN:

Hock, Richardson (mailed

)

L

1 e

I CXMETED U3NRC UNITED STATES OF AMERICA

'87 MAR 18 A10 :44 NUCLEAR REGULATORY COMMISSION Before the Administrative Law Judge f0CM kg h^h*'

BRANCH In the Matter of

)

GPU Nuclear Corporation Docket No. 50-320 dl

)

License No. DPR-73

)

EA-84-137 (Three Mile Island Nuclear

)

Station, Unit No. 2)

)

SERVICE LIST Ivan Smith, Esquire Administrative Law Judge Atomic Safety and Licensing Board Panel U.S. Nuclear Regulatory Commission Washington, D.C.

20555 Docketing and Service Branch Office of the Secretary U.S. Nuclear Regulatory Commission Washington, D.C.

20555 George E.

Johnson, Esquire Office of the General Counsel 9604 MNBB U.S. Nuclear Regulatory Commission Washington, D.C.

20555 Dated:

March 17, 1987 l

2 Wsehington, D. C.

3 Tuesday, May 10, 1983 4

5 INTERVIEW OF:

6 JOSEPH J. CHWASTYK, 7

a witness, called for examination, at the Longworth House 8

Office Building, Room 1322-A, Washington, D.C.

20515 9

beginning at approximately 2:05 o' clock, p.m.,

before 10 WILLIAM J. ALLEN, a Notary Public in and for the District of 11 Columbia, when were present on behalf of the respective 12 parties:

13 APPEARANCES:

14 For the Committee Staff:

15 DR. HENRY MYERS, SCIENCE ADVISOR TOM WIMER, NUCLEAR SCIENCE ADVISOR 16 EILEEN HOLLOWELL, STAFF COUNSEL COMMITTEE ON INTERIOR AND INSULAR AFFAIRS 17 1324 Longworth House Office Building Washington, D.C.

20515 18 For the witness, Joseph J. Chwastyk:

19 LeBOEUF, LAMB, LEIBY & MacRAE 20 BY:

MICHAEL F.

McBRIDE, ESQUIRE WILLIAM C. MARCOUX, ESQUIRE 21 1333 New Hampshire Avenue, Northwest Washington, D.C.

20036 6TEWART, FOE & OGLE 5BY, INC. - REPORTING SERVICES

,,n s

,ce_,o,,

2 m

1 APPEARANCES: (Continued) t 2

For the witness, Joseph J.

Chwastyk:

3 KILLIAN & GEPHART BY:

STEVEN D.

SNYDER, ESQUIRE 4

218 Pine Street Box 885 5

Harrisburg, Pennsylvanic 17108 6 7 8 -

I-N D E X 9

10 THE WITNESS:

EXAMINATION BY:

11 JOSEPH J. CHWASTYK DR. MYERS 3

12 13 14 15 DEFENDANTS' EXHIBITS IDENTIFIED 16 No. 1 38 17 No. 2 42 18 19 20 21 STEWART, POE & OGLESBY, INC. - REPORTING SERVICES

3 4

~

l PROCEEDI NGS

(.

2 Whereupon, 3

JOSEPH J. CHWASTYK, 4

was called as a witness and was examined and testified as 5

follows:

6 DR. MYERS:

I should say th,is interview is being 7

conducted as a part of our inquiry into the TMI accident and 8

clean-up.

Our primary function is to fully investigate the 9

accident and to insure the clean-up is carried out in 10 accordance with the Commissions's regulations.

Our purpose 11 in this inquiry, Mr. Chwastyk, is to invite questions about 12 ongoing and past events, and our inviting you here does not 13 mean you acted improperly or inappropriately.

14 EXAMINATION BY COUNSEL FOR THE COMMITTEE STAFF 15 BY DR. MYERS:

16 Q.

Could you tell us what your current position is?

17 A.

Yes.

I am the Manager of Plant Operations.

As l

l 18 such, I am in charge of the Plant Operations, RAD Waste Stop 19 Operations, Chemistry Department, and Shipping and Disposal l

20 Group.

1 21 Q.

And to whom do you report?

22~

A.

Pres'ently, ~I report to Mr. John Barton, who is bTEWARTn FUE & QULE5BY, ING. - REPORTING SERVICES

4

~

l acting as Site Operations Director.

(

2 Q.

And what are your basic responsibilities?

3 A.

Basic responsibilities are the plant operations 4

and the stability and the safe operations of the system, and 5

the access to the auxiliary treatment, processing of RAD 6

waste system and gasses, chemistry that goes along with the 7

operations and both RAD waste and plant operations; and the j

8 shipping and disposal of RAD waste active material from 9

Three Mile Island to whatever points so designated.

10 Q.

When Mr. King was Director of Site Operations, you 11 were reporting to him?

12 A.

Yes.

13 Q.

Would you tell us what you believe to be the 14 substance of Larry King's concerns --

15 A.

You mean specifically?

16 Q.

Well, generally.

What is it that he seemed to be 17 saying that -- well, he was saying that various activities 18 were carried out in a way not in accord with the 19 Commission's regulations.

20 A.

The only way I can answer that is in terms of 21 definition, if you will, of a split between what we termed I think the things Mr.

22" safety issue a'nd'a sa'fety problem.

j STEWART, POE & OGLESBY, INC. - REPORTING SERVICES

6 1

procedures defined, the type of work that could be done, 1

2 what kind of approval was needed to accomplish that work, 3

what kind of testing you need after it was refurbished to 4

put it back in service.

The intent of the procedure was not 5

in fact followed through.

I am not sure I made myself clear 6

there.

7 Let me say that those things defined in the two 8

procedures, AP-1043 and AP-1047, were not followed through 9

as required by those procedures, which is not to say that 10 the concerns which the procedures were designed to mitigate 11 were not.

12 Q.

But because of the failure to follow those 13 procedures or to adhere to those procedures, is there, or 14 could there have been uncertainty as to whether or not 15 unsafe conditions existed?

16 A.

I would have to say yes.

Not following prescribed 17 procedures, no matter what they may be, you know, generally 18 would or could lead to a possible problem.

19 Q.

So not following procedures would lead to 20 uncertainty, is that it?

21 A.

Yes, basically.

l 22" Q.'

The' materia'l s'ubmitted for the record of our April 1

f STEWART, POE & OGLESBY, INC. - REPORTING SERVICES

,_m_.__

,m

7 g

~

l 26 hearing, GPU said they have documents saying, "All 2

procedures important to safety are approved by the Site 3

operations Director as required by the station operating 4

license."

5 Do you know of instances in the last year where 6

procedures, apart from safety, were not approved by the 7

Operations Safety?

8 A.

No, I don' t.

9 Q.

So you would say in the last year all procedures 10 important to safety were approved by Site operations, the 11 Site Operations Director, prior to those procedures being 12 put into effect?

13 A.

I would say all procedures that'were classified as 14 "important to safety" were approved by a Site Operations 15 Director, that is true.

16 Q.

Prior to being put into effect?

17 A.

Prior to being put into effect.

18 Q.

Do you believe any administrative procedures were 19 bypassed in order to meet schedules?

20 A.

I don't believe that would be the reason the 21 administrative procedures were bypassed.

~

0.

Do you know why they might have been bypassed?

22 REPORTING SERVICES sIEWART, PUE & OGLE 5BY, INC.

8

~

l A.

I don't know for a fact.

My impressions are that 2

it was due to a lack of knowledge of the fact that those 3

procedures were not there.

And second of all, how to carry 4

through on those procedures.

5 MS. HOLLOWELL:

You said before that procedures 6

are classified as important to safety.

Now, I guess one 7

question is, were there other procedures that weren't 8

classified being important to safety, but might have been 9

important to safety that you are aware of in the last year, 10 that did not go through the process.

11 MR.'McBRIDE:

?.s approval by the Site Operations 1

I-12 manager?

I 13 THE WITNESS:

I will have to think about that for 14 a moment.

15 There was an area of concern we were trying to 16 watch very closely.

17 MS. HOLLOWELL:

Who determines, who does the l

l 18 specifications.

19 THE WITNESS:

The classification is done presently 20 by what we call the Cognizant Engineer Concept, which is and 21 designated engineers who are responsible for the system,

~

22 therefore responsible for whatever changes that go along O

STEWART, POE & OGLESBY, INC. - REPORTING SERVICES

9 1

with the system, be they changes from an engineering i

2 standpoint or procedures, or changes in the way we operate, 3

which can be the same as changes in the procedures.

4 Now, he does that evaluation to determine whether 5

it is important for safety or not.

6 MS. HOLLOWELL:

And if he determines it is 7

important to safety, it goes through this procedure we 8

talked about.

9 THE WITNESS:

Yes, defined procedure, the 10 appropriate process.

e 11 MS. HOLLOWELL:

And things he does not classify 12 important to safety are not approved in this way and are 13 just made?

How will those decisions be made?

14 THE WITNESS:

It still follows in a proven 15 procedure, but the review and procedure problem is different.

16 In most cases on not important safety items or procedures, 17 the only approval you would need on it would be the Cog 18 engineer, the department head, and any other departments 19 that may be affected by that procedure.

20 BY DR. MYERS:

21 Q.

So you would say to the extent administrative 22" procedure's we're' bypassed, that there was as a result of 31swax1, evt & vuttdex, 1NC. - REPORTING SERVICES

10 1

certain people being involved in these matters, not

(

2 understanding what was required, rather than bypassing them 3

in order to meet schedules?

4 A.

Yes.

5 Q.

Similarly, do you know :f instances where 6

engineering reviews that would h4ve, in your view, been 7

required by procedures, were such reviews not conducted in 8

certain instances?

9 A.

I think you will have to be a little more specific.

10 Q.

Say with a crane.

Were there engineering reviews 11 related to safety reviews about the crane?

12 A.

There were concerns brought up as a part of the 13 review on the crane procedures or safety evaluations.

I am 14 not sure I can answer you on that.

15 Q.

I guess one example might have been where an 16 analysis of dropping a load was or was not done, it is not 17 clear to me.

And the crane test procedure was going to be 18 accepted with the possibility that the analysis of the l

19 consequences of dropping the load had not been adequate?

20 A.

That type of engineering review does not fall into l

l 21 the purview of us at.the site.

That is usually the design

~

~

22 engineering gr'oup that does the calculations and has them F

l ST EWART, POE & OGLESBY, INC. - REPORTING SERVICES

[_

11 1

done, et cetera.

(

2 For instance, on the polar crane, the calculations

~

3 used to determine load-drop analysis are not part of the 4

safety evaluation report, although they may reference those 5

calculations, they are not part of that.

6 Q.

But' thos.e calculations were supposed to have been 7

done prior to the completion of that report, or in 8

conjunction with that report?

9 A.

I don't know that I am qualified to answer that.

10 That would have to be looked at.

e 11 Q.

Are you aware of significant discrepancies between 12 drawings and "as built" conditions at TMI 2?

13 A.

I am aware we have a problem with the drawing.

It 14 is still a problem, but not as bad as it was, say four years l

15 ago.

And I hope it will not be as bad next year.

16 Q.

Could you give us an example of what a discrepancy l

l 17 might be, or one you consider significant?

(

18 A.

You mean in specifics?

l l

19 Q.

Yes.

Where you have a drawing and you go and the f

20 drawing indicates that valves might be in some position.

l l

21 And you go there and they are not there, and pipes are in l

22-'

di f f ere'nt' loc'at i'ons? -

I bTEWART, FUE & VULEbbX, ANC. - REFORTING SERVICES

12

~

l A.

Well, one comes to mind, and only because I read 2

it in an affidavit, that acid spill we had a year or so ago, 3

where changes were made in the plant and not reflected in

~

4 the drawing, and the operator went down to complete an 5

evolution.

And because there were not correct drawings, he 6

spilled a couple hundred gallons of acid on to the gr6und.

7 I can't think of anything more specific than that, 8

and only because that is documented as an evolutional i

9 problem.

10 Q.

Mr. Gischel said that equipment component had been 11 reclassified from " safety related" to "not important to 12 safety," without following procedures in making such changes.

13 Do you know any cases where such classification 14 has occurred without these procedures being followed?

15 A.

You are really out of my field of expertise, to be 16 quite frank with you.

I am not quite familiar with the 17 procedures used in the engineering groups.

18 Q.

Is it a fact as of January of this year, the lines 19 of responsibility were unclear for control of significant 20 repairs or equipment changes?

21 A.

Can you rephrase that somewhat.

22" Q.'

Well, if a cha'nge were to be made on a piece of

~

~

MWMdARTn_POE & OGLESBY, INC. - REPORTING SERVICOS

13 1

equipment, was it clear to you who was in charge of

\\

2 certifying that the proposed change was indeed something 3

that could be done, or would be allowed to be done?

4 A.

I think you are referring to the review process, 5

in which each group is required to review a document to 6

ensure that it meets the requirements of whatever 7

responsibility that group has.

I guess my answer would have 8

to be, there was a time period, especially around the end of 9

last year or first part of this year, where the 10 responsibility became a little bit hazy because of the e

11 reorganization we had begun there.

12 Q.

But is that clarified now?

13 A.

I would say there have been attempts to clarify it.

14 Whether or not all issues are clarified, I don't really know, 15 because I have not had a chance to go through.

16 MR. WIMER:

You say that there were some problems.

17 Was this the interrogation of the Bechtol management with 18 the GPU management?

Is that what you are referring to?

4 19 THE WITNESS:

Yes.

20 MR. WIMER:

And you are still uncertain as to 21 whether the transients from.that management have died out.

~

22' THE WITNESS:

No.

I am just uncertain if all the dILWAMI, PUL & UOLLddX, ANG. - REFORTING SERVICES

14 1

problems that we experienced during that transition are in 2

fact all straightened out.

'#~

3 BY DR. MYERS:

4 Q.

But in the course of your going about you; 5

business every day, you know what must be brought to you to 6

be approved, and what you must bring to someone else for 7

their approval?

+

8 A.

In that sense, yes.

9 Q.

In January of this year, who was legally the 10 designated plant manager?

11 A.

That was one of the titles that became unclear as 12 a result of the reorganization.

Up until that time, it was 13 pretty clear that Larry King had held that responsibility.

14 After the reorganization, it became unclear, because of some 15 changes that were requested by way of letter with the NRC 16 asking for approval by GPU nuclear on a reorganization at 17 Three Mile Island.

18 There was a memo written sometime afterwards to 19 clarify that position, and I think it mentioned Mr. Kenga 20 and Mr. Barton, or Mr. Kenga alone as the plant manager.

21 But it also designated Larry King responsible for Operations 22' and Mai~nt'enance.

I t'hin'k that was designed to meet the

~~

STEWART, POE & OGLESBY, INC. - REPORTING SERVICES

15 4

1 requirements for plant manager under BCA 16.7.

It was ANSI.

2 MR. McBRIDE:

You used the phrase ANSI.

3 THE WITNESS:

Yes, I think it stands for American 4

Nuclear Standards.

5 DR. MYERS:

For the recurd, it is American 6

National Standards. Institute.

7 BY DR. MYERS:

8 Q.

Do you know what experience is necessary to 9

satisfy the ANSI standard if one is to be designated plant 10 manager?

e 11 A.

I would just be guessing.

I would say eight or 12 ten years of plant operation experience, plus, if not at 13 least the holding of a license, at least going through the 14 training to take that.

15 Q.

Did Mr. Kenga have that experience?

16 A.

Not that I am aware of.

But again that is 17 something I am not qualified to answer.

10 Q.

Did Mr. Barton have that experience, to the best 19 of your knowledge?

20 A.

To the best of my knowledge, he did not.

But 21 again, that is only to the best of my knowledge.

22" Q.

Could'you tell' us what the Safety Review Group was, S

STEWART, PGE & OGLESBY, INC. - REPORTING SERVICES

16 1

or is?

2 A.

Well, that is very touchy, because the Safety 3

Review Group was part of that reorganization I mentioned a 4

little earlier that we, GPU Nuclear, had tried to institute, 5

by way of identifying it to the NRC on the docket by way of s

6 memo.

7 It is basically a group assigned responsibility 8

for review of activities, documents at Three Mile and Unit 2, 9

to ensure the safety of those documents and the evolution at 10 the controls is maintained.

11 Q.

And to whom did it report?

12 A.

The safety review.

Now *emember, the Safety 13 Review Group is not an approved organization right now.

It 14 is still pending approval'of the NRC.

But the SRG reported 15 to the Licensing and Nuclear Safety Director.

16 Q.

Did you have some concern as to whether this group 17 was fulfilling its role as you perceived what its role was?

18 A.

I did; yes, sir.

And I think I documented those some of which were answered in terms of revising 19

concerns, 20 the organizational plan from what it was originally put out 21 to our present position, where we have not instituted SP.G

~

~

~

functions.

22 STEWART, POE & OGLESBY, INC. - REPORTING SERVICES i

)

17 w

1 Q.

And were those concerns brought to the attention 2

of the NRC?

3 A.

Yes, sir.

4 Q.

By you?

5 A.

Yes, sir.

6 Q.

And then what happened then?

7 A.

The reason I am hesitating, this brought this to 8

the attention of the NRC a number of ways.

9 Q.

How did you bring it to their attention?

10 A.

I think by copies of some of the memos I sent to e

11 the licensing group, and I had at least one phone 12 conversation that I remember.

So I am not sure how to 13 answer you.

f 14 Q.

Did they seem to be responsive to your concerns in i

15 the sense that they seemed to take them seriously, or did 1

l l

16 they --

17 A.

Well, the first time I talked to someone in t.he 18 NRC -- it was more in the order, you know, of looking for 19 some advise.

I read the organization, I read the ANSI

\\

20 standards, and I just could not get the two to match.

So I 21 brought that point up to some NRC people, and they looked at 22" it, and t' hey 'got back' t5 me and said -- well, I don't know 5T.EW A RT, POE & OGLESBY, INC. - REPORTING SERVICES

i 18 1

if they got back to me, but I didn't get any advice.

(

2 MS. HOLLOWELL:

That is what you call important, 3

some advice about this?

~

4 THE WITNESS:

The first time.

I returned that 5

call later on when -- by way of, you know, a transmittal 6

letter.

We were asked to review a revised edition of'the original, or whichever revision it was, and I noticed a lot 7

8 of the same problems were in the revised plan.

9 So I did call again, and ask if I could get some 10 response back to my initial questions.

And I think I was 11 told basically, "We have got nothing to do with,the 12 organization of the unit."

So they could not help me.

I 13 guess I wrote another memo.

14 BY DR. MYERS:

15 Q.

Are your concerns now addressed, or do they still 16 exist?

17 A.

Again, I don' t know if I can answer that, because 18 I would have to go back and see what the concerns were, what 19 has been proposed now and what the differences are now, if 20 anything.

21 Q.

Are you aware of something called the Unit Work 22-'

Cons t ruc't'i o n?

~

~

STEWART, POE & OGLESBY, INC. - REPORTING SERVICES

~ & o 1aae_ osse _9_e_9_L_____.___

19 1

A.

Yes, I am.

f 2

Q.

And are you aware whether a commitment was made in 3

'82 to implement a Unit Work Instruction System?

4 A.

I was aware there was a commitment made to 5

implement -- I am not sure just the Unit work Instruction 6

systems, but a new. control system.

7 Q.

Do you believe these systems have been properly 8

implemented?

9 A.

I believe that those systems, and specifically the 10 UWI system, because it is a new administrative document in 11 control, has some holes in it that have to be patched up --

12 and they had, since the start.

13 Q.

Do you perceive any organizational units 14 circumventing the intent of the Unit Work Instruction?

15 A.

I am not sure saying " circumventing the intent of 16 it" is absolutely correct.

There were circumstances where 17 certain groups decided not to use the UWI, or added on 18 additions.

A good example is the work permit mode of 19 controlling work.

20 Q.

So which units then would have not done this?

21 A.

Which specific units?

22~

Q.

Yes.

I mean,'do you perceive that everyone should

~

~

STEWART, POE & OGL' Y,

INC. - REPORTING SERVICES

20 l

have perceived by -- or should have carried out their

~

2 activities in accordance with the requirements of the unit 3

work construction?

4 A.

Yes, I do.

5 Q.

You perceived that some organizational units were o

6 not doing this?

7 A.

Yes.

At that time, yes.

8 Q.

Which time?

9 A.

At that time the UWI system was instituted, and 10 for some period of time thereafter, until people could be 11 properly indoctrinated.

12 Q.

Are they properly indoctrinated now?

13 A.

I think in terms of the UWI system, yes.

14 Q.

Do you believe there exists an adequate quality 15 classification list at TMI 2?

16 A.

Again, that is out of my realm of responsibility, 17 but I don't think there is.

If there is one, it is outdated.

18 Again, that is not in my realm of expertise.

19 Q.

But your perception then would be that it is not 20 kept current?

21 A.

Yes, sir.

22--

Q.

Were~the po~lar crane procedures prepared without

~

CT " ART, 20

OCLEC0Y,

SC. - ECTORT:NG 0:2V:C 0 m m _ e u m _a_f

p 21 1

adequate data?

2 A.

By that, you mean the polar crane test procedures?

3 Q.

Yes?

4 A.

Without adequate data?

5 Fithout adequate data to properly perform the 6

procedure?

7 Q.

Well, to prepare the procedures.

8 MR. McBRIDE:

Are you asking for his present 9

opinion or his opinion before all this --

10 DR. MYERS:

No, before.

When the procedures came 11 forth in the middle of February.

12 MR. McBRIDE:

Do you understand the question?

13 THE WITNESS:

Well, I understand the question, and 14 it goes back to February.

But what data we are talking 15 about in -- is it data used to prepare the procedures, or 16 data prepared in which the procedure is used to collect?

17 BY DR. MYERS:

18 Q.

No.

The information used as a basis for these 19 procedures, whether there was in hand, sufficient 20 information to be such that procedures could be prepared on 21 the basis of that inf ormation?

22--

Ac You are asking did we have sufficient data

~

bTLWAKT, FUL & UVLLbdX, 1NC. - REFURTING bbHVICEb 6

f a

l l

22 l

available to go ahead and write a procedure?

~

2 Q.

Yes.

3 A.

An operating procedure?

4 Q.

Test procedures?

^

' ~

5 A.

A test procedure?

6 I would have to say I don't think we did.

The 7

only available source would be Safety Evaluation Reports, 8

and back again to answer this in terms of the middle of 9

February, back around that time, the Safety Evaluation 10 Report was not a very good document to use, to be able to 11 use to accomplish that.

That is my perception.

12 Q.

I will now ask you these questions about Mr. King.

13 Mr. King made statements to the effect that 14

" contamination had been flown through auxiliary air vents."

15 Were you aware of what had happened there?

16 A.

I was involved with that problem.

Right now I 17 don't remember all the details of it.

18 Q.

What are we talking about here?

19 A.

Well, what we are talking about here is -- and 20 again I don't remember the source of the leakage, but it was 21 what is called the AUX building filters.

So it was in 22-~

effect these filters were being bypassed that way.

Well,

~

OT:L' ART, 200 ; 00L:002, INC. - R PCRT WG SERVICE 5 KR@XL_R@ @- 3 @ 27

23 1

they were being bypassed in that they had drains that came

(

2 off the bottom and drained to a collection tank.

3 And the purpose which, of course, these filters 4

have, is in case of fire, for water to get to them, because 5

they originally designed them with charcoal filters, which 6

were flammabl'e.

And if for some reason you had a fire or 7

inadvertent actuation of a fire system, you have a means of e

8 draining the water out.

And that drain system was used to 9

accomplish that.

10 The filters at each compartment of the filters had 11 a drain that drained to this drain tank here, and if I 12 remember correctly, they were -- the drains in the filters 13 themselves were supposed to be plugged, and they were not.

14 They were just taped over.

15 Q.

So as a result of that, gasses went down into 16 those drains somewhere?

17 A.

Yes.

If I may show you here --

18 Q.

Surely.

19 A.

If I can make a drawing.

If we just take -- this 20 here would be a filter here -- and this would be a filter --

21 MR. McBRIDE:

Try to verbalize this for the record.

22 THE OITNESS:

This is the drain here, and this

~

STEWART, POE & OGLESBY, INC. - REPORTING SERVICES i

e

24

~

~

l would be a compartment.

And this is another filter.

This 2

is looking at it -- I want to look at this as a side-view 3

drawing.

But the drains were such that -- well, there were 4

four of these.

5 These drains were such that they were fully in the 6

bottom of these cavities, in between the filters.

And they 7

ran a pipe down to a tank, which was a water collection tank 8

maintaining the level.

9 The plugs were designed to be put here at the 10 cavity.

They were not, such that air flow coming in, could in through this one filter, down the drain pipe, by 11 come 12 passing that filter, or coming in this way and bypassing two 13 filters.

14 Q.

But it was not such that air could enter those 15 filters and go straight -- I mean come in here, and get to 16 the outside without having gone through two of the four 17 filters.

18 MR. McBRIDE:

You say that it was not?

19 DR. MYERS:

Any air passing through here, would go 20 through at least two of the four filters?

21 THE WITNESS:

By this drawing I am showing, I am 22 not sure this is exactly what was in the plan.

I know it STEWART, POE & OGLESBY, INC. - REPORTING SERVICES J

25

~

l had to go through at least one filter.

Whether it would or

~

(

2 not, I would have to look at it.

3 MR. WIMER:

How was air forced through these 4

filters?

5 THE WITNESS:

There are fans down here and the air 6

is sucked thr'ough.,

7 MR. WIMER:

What is the diameter of these drain 8

pip,es?

9 THE WITNESS:

I don' t really recall.

10 BY DR. MYERS:

11 Q.

Then there was tape -- somebody found tape over 12 those vents?

13 A.

Yes.

14 Q.

Were there ever plugs in those vents as far as you 15 know?

16 A.

As far as I know, there were not.

17 Q.

Was the tape in place at the time of the accident?

18 A.

I really don't know that.

19 Q.

Would this have had any effect on how much 20 radioactivity was released during the accident?

21 A.

Only if you make a couple of assumptions, in that

~

2 2' '

there was no tape on'there, which I don't think is a valid STEWART, POE & OGLESBY, INC. - REPORTING SERVICES

~

26 M

1 assumption.

8 2

Q.

But in any case, for air to get out of the 3

building, it would be an auxiliary building if it went down 4

that pipe and into that tank?

a 5

A.

Yes.

6 Q.

So if it got out of the building, it would nave 7

had to pass through this filter and that filter to get out 8

.! the building?

9 A.

Yes.

Again, that is assuming this drawing is 10 correct, and I am not sure of this, 11 Q.

We have Mr. Freemerman's February 17th memo saying 12 there was no technical validity about Mr. Gischel's concerns 13 about the crane.

14 MR. McBRIDE:

Is that a question?

15 BY DR. MYERS:

16 Q.

There is a February 17th memo saying that.

Are 17 you aware of that?

18 A.

I may have read it.

I don't recall.

19 Q.

Do you have any dealings with Mr. Freemerman?

l 20 A.

Yes, I do.

i l

21 Q.

Do you think you would have seen that memorandum?

22' A.

It is very'pos'sible that I did.

~

INC. - REPORTING SERVICES

_ STEWART, _POE rn_OGLESBY,_

27 l

Q.

Were you aware that Mr. Freemerman, in talking to

~

(

2 him or whatever, that he believed that there was no 3

technical validity to Mr. Gischel's concerns?

~

4 A.

I don't think I ever discussed specifically Mr.

5 Gischel's concerns with Mr. Freemerman.

6 Q.

Did'you hear that there was disparity between --

7 or discrepancy between the views Mr. Freemerman expressed 8

and in discussions, and those he expressed in his memorandum?

9 A.

Not first hand.

I heard rumors to those effects.

10 Q.

You did hear rumors?

11 A.

Yes.

12 Q.

Did Mr. King tell you this?

13 A.

I don't recall who told me.-

14 Q.

You heard someb.,0y say that?

15 A.

Yes.

16 Q.

Were you aware that the initial drafts of 17 procedures for the crane test provided for a test, a load 18 test of the crane?

19 A.

Can you repeat that question.

20 Q.

Was there a provision for a load test of the crane 21 in the initial draft of the procedures for use of the crane?

I anot su're'I understand your question still.

22" A.

m STEWART, POE & OGLESBY, INC. _- REPORTING SERVICES

28 M

1 Q.

Was it planned at one time to test the crane with 2

something like a 40-ton load before recovering the missile 3

shield?

4 A.

Not that I am aware of.

5 Q.

Mr. Parks said in his affidavit that in the first 6

week of January, Site Operations was refused entry into the 7

reactor building.

8 Do you recall any such event?

9 A.

I recall an event that I am not sure he was 10

" refused entry into the reactor building" is a proper term.

11 We were required to do some additional administrative work 12 in order to get into the reactor room.

13 Q.

Who controlled entry into the reactor building?

14 A.

Recovery Programs Group -- more specifically I 15 think it is Recovery Operations.

16 Q.

So it is like there were people at the door saying 17 "Okay, why are you here and what do you want to do"?

18 A.

No.

It is not that.

The door is kept locked and i

19 can only be opened when some administrative controls are put 20 in place.

You have got to properly plan it, schedule it, 21 ensure that you get the right reviews, and that your people 22" are properly trained."

Ence you meet all those commitments, STEWARTp_POE & OGLESBY, INC. - REPORTING SERVICES

29 1

then you can go inside the building.

f

('

2 Q.

And in this case, Recovery Operations felt that 3

had not been done?

g 4

A.

In this case, recovery operations felt it had not 5

been done; that is right.

6 Q.

And what was it that had not been done?

7 A.

What had not been done was even though a UWI 8

defining those things were written and approved in 9

accordance with the administrative procedures, Recovery 10 Operations, or Recovery Programs, whichever, felt they still 11 needed a work permit approved before they would allow us to 12 go into the building, and that is what prevented it.

13 Q.

There were times that you would-have tasks in the 14 building that needed to be carried out, that you might have 15 to go in to check valves or change something from time to 16 time?

17 A.

Yes, sir.

18 Q.

These are the last questions about the crane.

19 Mr. Parks said that as of February 22nd of this 20 year, "The crane load test program, as presently constituted, 21 could have, if implemented, could have resulted in 22" substant'iai v'iofation's df NRC requirements," and by this I STEWART, POE & OGLESBY, INC. - REPORTING SERVICES

30 1

think he means AP 1043 and 1047.

2 Do you agree with that?

3 A.

AP 1043 and 1047 are not NRC requirements, though 4

they may incorporate some NRC requirements in them.

5 Q.

But adherence to 1043 and 1047 is something NRC 6

requires as a licensing condition at this point?

7 A.

Not specifically, no.

Not that I am aware of.

8 Q.

This is something that, say 1043 and 1047 were 9

abolished, that you would have to have something to replace 10 it in order to meet the NRC requirements?

11 A.

That is very hard to answer, because AP 1043 and 12 1047 are procedures -- in other words, they define a lot of 13 requirements, some of which are NRC required, some of which 14 are GPU nuclear requirements.

15 Q.

Suppose Mr. Parks said that as of February 22nd of l

16 this year the crane load test program, as presently 17 constituted, could have resulted in a substantial 18 noncompliance with AP 1043 and AP 10477 19 A.

.That is true.

2'O Q.

I may have gotten Mr. Parks wrong there, but -- I 21 can read that to you later.

~

Did'you and Mr. Parks inform Messrs. Kitler and 22 I

STEWART, POE & OGLESBY, INC. - REPORTING SERVICES

31 W

l Lake that you, in Site Operations, did not agree with

(

2 Kitler's and Lake's proposed resolution of the deficiencies

~~.

in the crane load test procedures?

3 4

A.

We reviewed the suggested corrections and we wrote 5

a memo to the interested. parties, delineating our agreement 6

or disagreement with the resolution.

~

7 Q.

And in some respects, did you agree, and in others 8

did you not agree?

9 A.

That is true, yes.

10 Q.

I don' t know if this is significant, but there are 11 some memos I think that you wrote, having to do -- or 12 referring to where radiac wash was dumped into a floor drain

~

i 13 in violation.

i 14 My question is, what is radiac wash?

15 A.

That is a type of detergent in nuclear power 16 plants, because of its chloric-free content -- this is not 17 in violation of any regulations.

We had to control the l

18 chemical content of the water so we can properly clean it up.

19 And just allowing anybody to go dumping anything in there 20 that they wanted, that is not desirable.

21 0.

Dumping this radiac wash into the drain did what?

22

A.'

It b'asicall'y r'equired us to separate that water INC.

REPORTING SERVICES

_STEWARTp_POE &_OGLESBY,_

32

~

l and determine a different methodology to clean it up other 2

than what we had in place in terms of our SDS.

And 3

basically it meant before we could clean that specific water 4

up, because of the different chemical water concentrations, 5

we had to change the types of resins we were using in that 6

system 7

MR. MARCOUX:

Should we make this an exhibit?

8 MR. McBRIDE:

Did you propose.to ask any more 9

questions about that?

10 DR. MYERS:

No.

Unless you have something to say 11 about it.

12 THE WITNESS:

I don't have anything to say.

13 DR. MYERS:

These questions now have to do with 14 the accident.

15 BY DR. MYERS:

16 Q.

Are you aware of an entry in GPU Sequence of 17 Events, stating that " Operators manually initiated high 18 pressure injection of the engineer safety features starting 19 at the bottom"?

20 MR. McBRIDE:

What is the time period?

21 DR. MYERS:

At 5:41 a.m.

' nd this is the day of the accident?

22" MR. Mc' BRIDE:

A STEWART,POE & OGLESBY, INC. - REPORTING SERVICES 7

f:-

33 H

1 DR. MYERS:

Yes.

(..

2 MR. McBRIDE:

May we go off the record?

~..

3 DR. MYERS:

Yes.

Off the record.

4 (Discussion off the record).

5 DR. MYERS:

Back on the record.

6 THE' WITNESS:

What was the question now?

7 BY DR. MYERS:

8-Q.

Are you aware of an entry in GPU Sequence of 9

Events --

10 A.

I am reading it.

11 Q.

But were you aware of it prior to your reading it, 12 that there was such an entry?

13 A.

I don't know that I can answer that.

There are a 14 lot of entries.

i 15 Q.

When did you first become aware some operators l

16 recalled that HPI had been initiated approximately the time 17 of the last reactor coolant pumps were turned off?

18 A.

I don't know that I ever became aware.

19 Q.

-There are various interviews with Faust, Frederick 20 and Zewe, where, in one way or another, they seemed to have l

21 recalled that this happened.

And Zews stated this in a 22 meeting' w'ith the ACR5 at" one point, and I believe he stated

~

4.'

t ST EWART, POE & OGLESBY, INC. - REPORTING SERVICES

34 1

it at the meeting of GPU employees.

's 2

A.

I guess I don't understand the question.

It is 3

logged here.

4 Q.

The question is, when did you become aware of this?

5 A.

Well, I don't know.

When I first read these 6

documerts, whenever that was.

7 Q.

Were you ever party to discussions concerning 8

h.igh-pressure injection at approximately 5:41 a.m.?

9 A.

No.

Not that I am aware of.

10 Q.

Do you believe high-pressure injection was 11 initiated approximately at 5:41 a.ra. on the day of the 12 accident?

13 A.

Do I believe it?

It says it was here.

I was not 14 there at 5:41 on the day of the accident, so I am not sure 15 what the question is asking.

16 Q.

Well, did anyone tell you it was initiated at 5:41 17 a.m. on the day of the accident?

18 A.

They may have, I just don't recall.

I just don' t 19 see any situation of that specific evolution.

20 Q.

Well, as you know, it was a big thing in the trial.

21 A.

It was big in the trial, but I still don't know 22 why it was.

O STLelMWMO_E & OGLESBY, INC. - REPORTING SERVICES

35 0

1 Q.

B&W claimed if injection had been left on at'that 2

point, there would be no damage to the core.

3 A.

I will not comment on that.

I would have to look 4

at the whole sequence.

5 Q.

But do you recall anyone telling you that this 6

happened; the'high-pressure injection happened?

7 A.

No.

8 Q.

And you have no reason to believe that, one way or 9

the other, that this happened?

I mean, other than the fact 10 it is in the Sequence of Events saying it happened.

But 11 other than the Sequence of Events, do.you have any reason to 12 believe whether that happened or didn't happen?

13 i

A.

I really can't.

We have talked somewhat about the 14 accident throughout the last four years, and someone may 15 have mentioned it at some time or other, but I never put any 16 significance on it myself.

So I am not sure I can answer 17 the question honestly, except that I don't recall.

18 Q.

On March 31 of this year you told Mr. Stiers that 19 Mr. Kunder was involved in shutting down the reactor coolant 20 pumps.

21 A.

Yes.

~

~

22" Q.

Did'Mr. Kunder shut down the reactor coolant pumps?

STEWART, POE & OGLESBY, INC. - REPORTING SERVICES

36-1 A.

Yes.

2 Q.

Did Mr. Kunder --

3 A.

He was involved in shutting them down.

4 Q.

Do you think he actually shut them down himself?

5 A.

I doubt it.

He probably ordered them shut down.

6 I think that is part of the public record, anybody who wants 7

to know.

8 MS. HOLLOWELL:

You don't know it for a fact 9

because you were not there?

10 THE WITNESS:

That is correct.

11 BY DR. MYERS:

12 Q.

But you think it is part of the public record that 13 Mr. Kunder was involved in some way in shutting down the 14 pumps?

15 A.

The reactor coolant --

16 MR. McBRIDE:

Are we talking about 5:41 now?

4 17 DR. MYERS:

Yes.

18 THE WITNESS:

Because there seems to be some mix-up 19 on high-pressure injection --

20 DR. MYERS:

This has to do with the reactor 21 coolant pumps, but the previous question had to do if 22~

somebody ' turned on the h'igh-pressure injection.

~

But I did O

_bTEWARTg_POE & OGLESBY, INC. _- REPORTING SERVICES

37

~

l not ask the question whether you thought Mr. Kunder was

(

2 involved in the high-pressure injection, which I gathered 3

you told Mr. Stiers -- well, your answer appears there.

4 BY DR. MYERS:

5 Q.

Did you see either of these articles?

This is 6

from the Wall' Street Journal soon after the trial started.

7 Do you recall that?

That talks about the mystery man for 8

the first time.

9 MR. McBRIDE:

The question is, did you see this 10 article.

11 THE WITNESS:

I think I did.

I am pretty sure I 12 did, but that is all I can say 13 MR. MARCOUX:

This is an article dated what?

14 MR. McBRIDE:

No date appears.

15 DR. MYERS:

It is approximately November 7.

16 MR. McBRIDE:

Of '82?

17 DR. MYERS:

Of 1962.

18 THE WITNESS:

Yes, I think I did read this article.

19 BY DR. MYERS:

20 Q.

Did that cause, as you recall, much discussion as 21 to whether or not high-pressure injection had been turned on 22..

5:41 a.m.?

at O

%wnvwt r-atA rcawInsm - TRRF#25LM @RfW8@@@

38 w

1 A.

Not that I am aware of.

a 2

MR. MARCOUX:

May I suggest that we make that part 3

of the record and label it as an exhibit?

4 MR. McBRIDE:

Can we make this Exhibit Number 1 to S

the deposition?

6 DR. MYERS:

Sure.

7 MR. McBRIDE:

The article undated from The Wall 8

Street Journal, entitled " Babcock and Wilcox Blames Mystery 9

Man for Extent of Damage at Three Mile Island."

10 (Whereupon, the above-mentioned document was marked 11 Defendants' Exhibit No. 1 for Identification, and 12 is attached hereto).

13 DR. MYERS:

And here is another one from The 14 Washington Post.

This one was approximately February 20, I 15 believe.

16 MR. McBRIDE:

And the question is --

17 BY DR. MYERS:

18 Q.

Did you see that prior to this meeting?

19 A.

Yes.

20 Q.

Do you remember, did that cause any discussion?

21 A.

Yet, sir; it did.

~

I 22" Q.

Again, it raises a question of the mystery man and e

REPORTING SERVICES TEWART M E 1 0GLESB M NC.

39 1

what people -- you might have thought about that, whether or

(

2 not the high-pressure injection was turned on and then 3

turned off?

4 A.

No.

I don' t recall any discussion from that 5

aspect.

I think the discussion was in terms of the quality 6

of the articl'e.

7 MS. HOLLOWELL:

Which was?

8 THE WITNESS:

It seemed to be damaging in terms of 9

what it looks like to the public, in terms of Three Mile 10 Island and the accident, and GPU and B&W involvement.

11 MS. HOLLOWELL:

These were discussions with people 12 that you work with.

13 THE WITNESS:

Yes 14 DR. MYERS:

15 Q.

Tell me if this is correct.

I believe in your 16 interview with Mr. Stiers, I think you said that there might 17 have been discussion as to whether it was appropriate to 18 turn off the reactor coolant pumps, as opposed to whether or 19 not it would be appropriate to turn off the high-pressure 20 injection pumps, if they in fact had been turned off.

21 But was there discussion as to whether or not the

~

~

22

reactor coolant pumps should have been turned off at O

STMMARTo POE & OGLESBY, INC. - REPORTING SERVICES

40 w

1 approximately 5:41 a.m.?

2 A.

I discussed with Mr. Stiers the allegation in Mr.

~..

Parks' affidavit about the mystery man concept.

3 4

Q.

But that aside, other than what you discussed --

5 other than whether you discussed it with Mr. Stiers or not, 6

but was there a discussion you participated in having'to do 7

with the wisdom of turning off the reactor coolant pumps at 8

that time?

9 A.

At what time?

10 Q.

At 5:41 a.m.?

11 A.

I have discussed the wisdom of shutting off the 12 reactor coolant pumps.

13 Q.

If you had been there and were in charge, would 14 you have turned off the reactor coolant pumps at that time?

15 A.

Oh, boy!

I would prefer not to answer that 16 question.

I am sure the people over there had enough on 17 Monday morning.

18 Q.

Did Mr. Dieckamp ever discuss with you, your 19 recollecti.ons that on the day of the accident you knew that 20 some sort of explosion had occurred in the reactor building 21 MR. McBRIDE:

Off the record please.

22

(Discu'ssion' of'f the record).

STEWART, POE & OGLESBY, INC. - REPORTING SERVICES

41 l'

DR. MYERS:

Back on the record.

(

2 THE WITNESS:

Do you want me to answer that?

3 MR. McBRIDE:

While off the record, we agreed that 4

the question that would be posed to Mr. Chwastyk, and the 5

only question in this area, was whether at any time 6

subsequent to' the date of the accident at TMI 2, he and Mr.

7 Dieckamp had a discussion about --

8 DR. MYERS:

Mr. Chwastyk's recollection on the day 9

of the accident that some type of explosion happened in the 10 reactor building.

11 MR. McBRIDE:

Do you recall such a discussion with 12 Mr. Dieckamp?

13 THE WITNESS:

I don' t recall a discussion on it.

14 I do recall at one time subsequent -- this is quite a while 15 afterwards, and I had occasion to meet Mr. Dieckamp on some 16 other purpose.

There was some joke about hydrogen explosion, 17 but there was never any discussion.

18 MR. MARCOUX:

Can we mark this second newspaper 19 article as Exhibit 2.

20 MR. McBRIDE:

The article entitled "The Real Three 21 Mile Island Story Leaks out," will be Exhibit Number 2.

22

~

l STEWART, POE & OGLESBY, INC. - REPORTING SERVICES i

42 1

(Whereupon, the above-mentioned w

document was marked Defendants' Exhibit No. 2 2

for Identification, and is attached hereto).

3 4

DR. MYERS:

I guess if we follow up on that last 5

answer, we will get into the question that you don't want us 6

to get into.

And I agree, that issue is closed, so that is 7

it.

8 (The reupon, at 3:15 p.m.,

the taking of the 9

deposition was concluded).

10 11 12 13 14 15 16 17 18 19 20 21 22'

~

~

STEWARTo POE & OGLESBY, INC. - REPORTING SERVICES

o 43

~

l CEF.2IFICATE OF REPORTER I..

2 I, William J. Allen, shorthand reporter, do hereby 3

certify that the testimony which appears in the foregoing 4

Pages 3 through 42 were taken by me stenographically and 5

thereafter reduced to typewriting under my supervision; that 6

said deposition is.a true record of the proceedings; that I 7

am neither counsel for, related to, nor employed by any of 8

the parties to the action in which this deposition was taken 9

and further that I am not a relative or employee of any 10 attorney or counsel employed by the parties thereto, or 11 finacially or otherwise interested in the outcome of the 12 action.

13 14 Court Reporter 15 16 17 18 19 20 21 22 EiRFGN2h PX4F4 & OGLESBYo INC. - REPORTING SERVICES

e o

Me Real Three, TMI, From Page C1 l

b p

g But,what emerged from the trial amounted

%~

to an tnyttation to a House Interior subcom-mittee - scheduled to hold hearings Tuesday on the Nuclear Regulatory Commission's Sto' Mi 6"d ' '" <*z e

- ' d t' '">'s it

really wants to.

I N

The subcommittee has asked the NRC to l By Susan Q. Stronohon

.d; note any significant information on TMI that -

HE REAL STORY behind the four year.old acii-surfaced during the trial as well as the status Tdent at the Three Mile Island nuclear plant finaD of the NRC position on a separate $4-billion 3

suit GPU has filed against the government.

seemed to start spilling out at the end oflast year...p

. It's unclear, however, how much NRC offi-

'The press missed a lot of the storv. and quite a story it was: evidence that operators at TMI falsitied earlier e als will find it in their interest to volunteer l on Tuesday. That second $4 billion GPU suit reports on coo! ant leaks to the Nuclear Regulardy l

1 Commission: a study - done by GPU itself more than charges the NRC with negligence, claiming -

m a novel twist for the corporate world -

I a year before the accident - which found that "the that the regulators didn't regulate firmly quality of operator personnel is on a continuous dow.

enough. that if the commission "had acted i

i tard trend due to lack of traininr."a suggestion o! con, with due care... the TMI accident would tradictory statements under oath by a key TM1 em.

i not have occurred."

! ploye: evidence of an operator cheating on a qualihing As one government official who has fol-i examination and much else.

^

lowed the TMI case says. " A lot of serious ac-The setting for these revelations was not one of ihe cusations have been made about the NRC's

~.ot:Icialinvestigations held on the worst commere'aj own competence in this case. Testimony in

. lear accident in the nation's history. Those inquiries that [New York) trial showed that GPU ta!>i-i - by two cons:recional committees, two special inves.

fied important data to the NRC Althouxh i tigative panels and the Nuclear Regulatory Commis.

the [NRCl staff had plenty of opportunity to i

vion - did not concentrate on drawing out such details call the utility on that and other infractions.

and did not fully develop the hits and pieces of evi it didn't take the mattet seriously. When the dence thev had uncovered.

(NRCl case comes to court. logically some-But now, in a federal courtroom in Manhattan, heaps of money were at stake so no holds were barred. Gen, body is gomg to want to know why."

. But whether or not the NRC is interested l eral Public Utilities. owner of TMI. was suing Babcock

& Wilcox. maker of the TMl reactor. seeking M billibn m pursuing the leads that came out of the {

i in damages. charging that B&W had caused "unthink.

GPU.B&W litigation. that trial did produce some fascinating information. As Henry

able risks to human life." Not standing still for inat,

' Babcock & Wilens retaliated with charges of " willful Myers, science adviser to the House Interior Committee, remarks of that aborted court and wanton misconduct" by GPU at Three Mile Islan'd.

battle:"For the first time there were people and the evidence about who was at fault began to flod.

it did not tiow tor long. In late January,just as Ba}s who were interested in the unvarnished tr.th, cock & Wilcox was gettmg into its own attack during and they were determined to not it out."

the trial. GPU announced that it was settimg out or E

E court for $37 million and this in the form of rebates on eqtupment and services it would continue to.huv oser GPU may not have been eager to file suit the next decade trom Babcock & Wilcox, a:ainst B&W or the NitC. But lawsmts were needed to sati3fy two goups that hold great See TMI, Page C power over the utility: stockhoiders and state public utility commissions.

Susan t/. Ntranahan, an editorial teriter for Both must be convmeed the utility did all The Phiindolphia Inquirer. han follouced the \\

it could to seek outside tunds to ' pay the TMI case sunce the March 1979 accident. She n \\

nmu tm lenov ns an Alicia Patter ~ ort fello.r f

h e

The Rea' T1ree Mile Island Tale Leaks Out

\\

which... their training program left them

' nearfy'51 billion in TMI cleanup costs and totally ill equipped... "

the $3-billion expense of replacement electri-It was during cross-examination of GPU's l calpower while TMIis out of service.

own witnesses that Fiske built much of his Despite dogged GPU efforts to obtain fed.

case. The cross-examination of William Zewe, eral funds and contributions from other nu.,

shift supervisor in TMI Unit 2 at the time of cigar uses,.there appear to be only twn :

the accident,was an example.

I scurces of money - GPU's investors and :

At issue was the temperature of steam -

customers. Investors aren't standing in line to :

buy the company's stock. That leaves GPU's.

surging out of a stuck open valve on the reac-ratepayers in central Pennsylvania and New tor's pressurizer tank. TMI operators didn't know for two hours and 20 minutes that the Jersey, who will continue to be assessed for a valve was stuck open, allowing much of the substantial share of the cleanup costs. If GPU reactor cooling water to pour out. They com-hopes to win more rate increases, it must pounded the problem by shutting off emer-demonstrate to the utility commissions that it made good. faith efforts to obtain funds from gency rr.ake up water.

GPU contended that faulty B&W instruc-other sources.

So GPU found itself in the courtroom of tions caused operators to misread the prob-Federal DistrictJudge Richard Owen on Nov.

lem. But B&W argued that any competent

1. David Klingsber::, a noted New York law-operator should have been tipped off by the yer retained by GPU, opened the trial by abnormally high temperatures, caused by the promising to relate "a frightening episode of escaping steam, that the valve was stuck corporate misconduct" by Babcock & Wilcox.

open. To prove it was incompetence - not B&W's instructions - at fault, Fiske had to The keystnnes of GPU's negligence claim were two memos written in February 1979 by show that Zewe knew of the high tempera-S B&W engineer describing a September tures for a long time and did not respond.

177 incident at an Ohio nuclear plant. Thel To begin with, Zewe told Fiske that he hadn't followed GPU's booklet of operating Ohio problem, also involving a loss of coolant, procedures for abnormal situations as the ac-to a B&W built reactor, was indentified and cident unfolded. He also said that he hadi corrected in 20 minutes. The memo advised been told by a control room colleague that!

B&W management to warn other B&W reacq temperatures had dropped from a high of 280 tot owners to revise emergency instructions to degrees Fahrenheit to 230 degrees, indicating prevent a recurrence. (The warning finally-to him the valve had closed.

was sent out after the TMI accident.) The That version, Fiske said, was different from -

~

memos, Klingsberg declared,"are the smok previous sworn testimony by Zewe hefore ing guns of this case."

B&W's attorney was Robert B. Fiske Jr...

other investigatory bodies. On one occasion, Fisk said Zewe had testified that he had former U.S. attorney for the Southern Dis.

heard the temperature incorrectly. Fiske also trict of New York,who responded forcefully.

recited earlier Zewe testimony before a Sen-

"We expect to prove that GPU was guilty :

not merely of ordinary negligence, but of '

ate committee probing TMI. When asked what he considered the " major contributor to reck'essness and in fact engaged in certain re-this accident," Fiske said. Zewe had re-spects in deliberate, willful and wantun mis-sponded then:" Failure of the operator, my-mnduct," he declared. When problems began self, to adequately determine the electro-in the reactor, he said, operators had emer -

magnetic relief valve was still open."

gency instructions available but ignored them Fiske accused Zewe of altermg his testi.

in favor of their own "on the spot, off the cuff, ad hoc analysis n( system conditions, for many now to otiset any infer 7nce of inenmpe.

0

5. ~

l 4

- e i

~

1 1

ance at operator training classes, to prepare :.

~ ~

for NRC. required mams, dropped as low an. ;.

j 33 percent. The TMI supervisor of training.

was devotmg half his time to studying for his.

tence on his part. zewe oenna tne charge, own operator's beense, the GPU audit'..

~~'

saying that his testimony on this occasion was showed, and when he failed the test, he spent to the bestof his recollection, all his time properms for a m.mamination.

?

" g g

• A control room supervoor, who had to bei I'

recertdled to the NRC following the accident. -

The linliest evidence about conditions at was found to have cheated on the nam. &

• TMI came during the crossmamination of submitted his test with answers in someone '*

Robert C. Arnold, president of GPU Nuclear else's handwriting and a different color ink.

Corp. and, as such, TMI's chief ourseer. In Ing% aR this, Armid ddended h tuin.'

• Arnold's www, mamtenance of the TMI reac.-

progen mid a gtim m Fish's ~-

t wm " adequate. Operator training w" l

= acceptable. Employee responsible for run.

statement that TMI rnanagement " failed to '

i; ning the reactor were reliable and capable.

instiH a seu d reput for h tuining" d '.

But for every positive assessment by Ar.

g,,,,,,,

l noid, Fiske countered with other evidence -

This last assertion by Arnold elicited some -

l all drawn from GPU's own files, from its em.

sharp remarka from Judge Owen, who said he.

i ployes' nworn statements during revious in, had gotten the impression from Arnold's di..

i votisations or h trialitself, from NRC rat testunony that "ewrything [at TMll was documenta.This evidenceincluded:

hunky-dory." In fact, said the judge, "the.

4

= The TMI station manager advised his su.

operator training here was pretty stro.

periors before h accident that poor mainte, cious.... That bears on the quality of.

nance at the plant was.a serious problem. At operator skill, which bears upon the question.

the time of the accident 800 to 1.000 repair of whether or not they shmid have recop.

5 tanks wem pending. Arnold estimated under nised certain symptoms and closed the relief i

crnas-namination that TMI's maintenance valve early on in the same."

budget for 1979 had been cut "several hun.

On Ju. 21, with the defenu still in h >

i dred thousand, and [it could easily have ap.

early stage of calling its own witnesws GPU i

proached a million (< ollarsl," but he con.

suddenly agreed to settle. The full text of the

)

tended that ructor maintenance was still suf.

settlement agreement has not been made.

i ficient.

public, but one portion that was reluned

• The TMl reactor was fraught with prob.

states that "neither party has established j

lemn from the beginning. Starting in 1979, that the other was the cause of the TMI.2 ac.

j Unit 2's coolant system leaked at rata that cident."

frequently acceded allowable NRC limits.

By most assessments b uttlement was NRC rules required that the reactor be shut forced upon a beleasured GPU management e j

down to determine the cause of such leaks.

by its increasingly worried colleagues in the -

But Fiske cited NRC findings that TMI nuclar industry. "This had the potential for s opera

• ors, to avoid the npense of shutdowns, dressing down an entire industry that's al.

manipulated the leak rates, falsely certifying ready on its knees." commented a govern.

j to h NRC that there was no major problem.

ment lawver following the case. "Nobody in When the NRC luened of the falsitied all the TMI investigations had brought out i

records after the TMl accident. Fiske said, it such damaging information."

fined GPU for the infraction.

The question now is whether anybody in

• A GPU audit conducted more than a year Congrenn or elsewhere really has an interest i

before the accident noted ht "the quality of in pursuing the rest of the story,in brinting l

operating personnel is on a continuous down.

out that full "unverished truth" about what ward trend due to lack of training." Attend.

really happened at Three Mile Island.

i j

i l

e j

-m-,-m._---

_,_-me

--,-,mw-.-

,m,y,-

merw e---

Wd 562d End D

5 Babcock & Wilcox Blames ' Mystery Man'

~~ ~

For Extent af Damage at Three MileIsland

• w;*@"":en'",,":n*";

,e Stile Island look proper actions earty enough O

tu the accident to avert damage. Babcock &

By JottN R. E.s sHW1 llc 2 Wilegg hopes to show that any absence of siatinae.mret Tm w.u. sinuv humu.

s.annrgs didn't have a senous impact.

NEW YORK-A "mysterv man may To 'iend off that effort. GPU's attorneys,

have played a. ital and previously unreece are already cht!!enging Mr. Mske's version lnistti rule m the 193 accident at the Three of the events. David Khngsberg. GPU's lead Shle Islasal nuclear power plant.

- itterney, told the court, the water pumping FLibcock & Wilcox Co. which supplied

incident didn't have any major effect on the the reactgr. contends that relatively earty in the accident an unidentified person turned

!.cculent. "They IBabcock & Wilcox) make

. t,ig thing out of that. but it doesn't get to off a coonne pump at the plant that could ite heart of what happened." Mr. Klmgs-have saved the reactor from the senous.

1. I ***d damaec it later sustamed. General Pubhc The argument over this pomt raises new '

Utahties Corp., the plant's owner, challenges the Habcock & Wilenx claim.

questioits about the accuracy and thorough-ness of previous inquines into wat has been The assertion came m opening argu.

ments of a tnal that began in federal court one of the most investigated even.3 of recent.

times. Major investigations have been done i here this week involvmg the two compa.

by a special commission appointed by Presi-I nies.

As previously reported. GPU has filed a -

dent Carter; the Nuclear Regulatory Com-34 bilhon damage claim against Babcock &

mission:.a special outside inquiry commis-Wticox, a urut of McDermott Inc. The utility sicned by the NRC: Congress, and the nu-contends the reactor maker s failure to pro, clear mdustry, Mr. Rske's contentions areft't the Drst vide adequate instructions and equipment fur running the plant led to the March 23.

challence to the adequacy of those mvestira-193. accident. generally considered to be tions. For instanea. Rep. Morns Udall (D.,

the worst mishap id the history of commer.

Ans.t. chairman of the House Committee on rial nuclear power.

Intenor and Insalar Affairs, has charged the NRC failed to adequately mvestigate evi-

. Explanations Challenged dence that the utthty ort the first day of the Fisxe Jr., Babcocx & Wilcox, Robert In his opening statement B.

acuuent withheld imponant ininrmanon q

s lead attor-frnm state and federal officials about the se-ney, ratsed some surpnsing assertions that v,.etty of the per.,blem.

seemed to challenge the official explana-a on tions of what happened in the early hours of i

The accident began as the result of a rei-the accident that began at 4 a.m. on Maren 23, 19 3.

auvely minor plant malfunction. It rapidly Mr. Fiske said that evidence ga:hcred

">cantted because of an imciag7tosed water over the past il% years mdicated that plant i

cak from a stuck open safety valve. as well as misleading indicators in the control room operators began to diagnose and preperly that caused operators to incorrectly diag-

&al with the accident far earlier than pre-nose the problem.

viously believed and earty enourn to have Under the generally accepted view of averted senous damage to the plant.

what happened that misdiagnosts went en Specifically. operators began sending for several hours. As a result, operators large amounts of emergency cochng water failed to keep enough water m the reac-mio the reactor. Mr. Fiske said. But within

tor, a few minutes someone turned that water i But Babcock & Wilcox contends that by supply off, he said. !! the supply had been 5:40 a.m. operators apparently began to ree-kept on. most of the damare to the plant ognise they didn't have enough water in the would have been averted. Mr. FLske ad-core. As a result, they turned on an emer-ded.

gency pump full blast to send in more wa-As reported. the lokt of cooling water and ter. Mr. Fiske said. Records snow the the failure to replace it led to severt over, pumps were on for five mmutes before the heaunt and damage to the reactor's nuclear umdentified persoft turned them off. he fuel as well as the release of radiation to the added.

environmenti In response to questions by The Wall Mr. Fiske said he and h's colleagues had Street Journal. Mr. Fiske said he wasn i at looxed hard to identify who turned off the Ilberty to provide the evicence the cmten-cater, but without success. "We don't know ttoris are based on urttil he presents it at the cho he is today. He is the mystery man m (nal, which is expected to last about two this case." Mr. Fiske told the court.

months.

Prior Incident Therefore. some of the questions raised by P..tbcocn & Wilcos s content nns can t im-The contentions by Babcock & Wilcox medtately be answmd.

e was M W nresidir g Judge Richard Owen dunne the fre.urned at urtdermining the maut thrust i

uf CP'.' a case. Babcock & Wilcox knew of a opening arguinents. H the pump was tum 19M incicent at an Ohio nuclear plant that m uff, the ludte asted. "didn t somebody toct many ways foresnadowed the accident at amund and say, 'Who the hell turned it Three Mlle 191and. Despite urgtnr3 from "8 I -

some of its own safety experts. Bartork &

Wilcox didn't send out warnings to otter Mr. Fiske responded that ofte operator utthly sustomers. The company asserts that had said he thought the pump had stayed on.

t!rh warnf ars weren t necessary C f't

• mm.

Sgt the attorney sdded. "It is_g_pqgjg."

b s

1 1

51203

(

2 COMMITTEE ON INTERIOR AND INSULAR AFFAIRS 3

4 Washington, D. C.

5 Thursday, May 12, 1983 6

INTERVIEW OF:'

7 WALTER A. MARSHALL, JR.,

8 a witness, called for examination, at the Longworth House 9

Office Building, Room 1322-A, Washington, D.C.

20515 10 beginning at approximately 2:00 o' clock, p.m.,

before 11 WILLIAM J. ALLEN, a Notary Public in and for the District of 12 Columbia, when were present on behalf of the respective 13 parties:

14 15 APPEARANCES:

16 For the Committee Staff:

17 DR. HENRY MYERS, SCIENCE ADVISOR COMMITTEE ON INTERIOR AND INSULAR AFFAIRS 18 TOM WIMER, NUCLEAR SCIENCE ADVISOR PAUL PARSHLEY, CONSULTANT 19 1324 Longworth House Office Building Washington, D.C.

20515 20 21 STEWART, POE & OGLESBY, INC. - REPORTING SERVICES Washington, O.C.

(202) 265-3827

s 2

1 APPEARANCES (Continued:)

2 For the witness, Walter A. Marshall, Jr.:

3 LeBOEUF, LAMB, LEIBY & MacRAE BY:

WILLIAM C. MARCOUX, ESQUIRE 4

MARILYN TEBOR SHAW, ESQUIRE 1333 New Hampshire Avenue, Northwest 5

Washington, D.C.

20036 6

For the witness, Walter A. Marshall, Jr.:

7 KILLIAN & GEPHART BY: SMITH B.

GEPHART, ESQUIRE 8

218 Pine Street Box 886 9

Harrisburg, Pennsylvania 17108 10 0-11 12 INDEX 13 14 THE WITNESS:

EXAMINATION BY:

15 WALTER A. MARSHALL, JR.

DR. MYERS 3

16 17 18 19 20 21 dTLWAET, FUL 6 VULL5BY, ING. - REPORTING SERVICES 2126 Bancroft. Place, N.W.,

Washington, D.C.

(202) 265-3827

o 3

1 PROCEEDINGS I

2 whereupon, 3

WALTER A. MARSHALL, JR.,

4 was called as a witness and was examined and testified as 5

follows:

6 DR. MYERS:

Mr. Marshall, this interview is being 7

conducted as a part of the Commissions ongoing inquiry into 8

the TMI accident and clean-up.

Our primary concern is 9

whether the NRC fulfilled its responsibilities to fully 10 investigate the accident and make sure the cleanup is 11 carried out.

12 our purpose in inviting you here is to ask 13 questions about ongoing and past events. 'In doing so we 14 don't, by any means, mean to imply we believe you acted 15 improperly or inappropriately.

Our primary. purpose is to 16 collect information on events of concern to the Committee.

17 BY DR. MYERS:

18 Q.

Could you tell us what your position is at TMI?

19 A.

I am Operations Engineer in Unit 2.

20 Q.

What are your responsibilities?

21 A.

In the last six or eight months I have been 22' working on Head Lift Procedures for RCS, basically.

i STEWART, POE & OGLESBY, INC. - REPORTING SERVICES

____ ___________8186_Ranernft place.

N.W.. Wa sih i ne e nn. n r'. t707) 76 b1A?7

a 4

1 Q.

And to whom do you report?

l 2

A.

Right now I report to Joe Chwastyk.

3 Q.

And prior to Larry King's leaving?

4 A.

I reported to Larry King.

5 Q.

How long have you been employed by GPU7 6

A.

Since 1977, February of '77.

7 Q.

And what were your responsibilities about the time 8

of the accident?

4 9

A.

I was Operations Engineer then.

10 Q..

And what were your duties at that time?

11 A.

I had AUX Surveillance Programs, various 12 responsibilities for training operators, some system 13 operations, coolant towers.

I reviewed the AUX operator's 14 logs, shift foreman's logs.

I had responsibility for 15 writing some procedures and reviewing other proceedings.

I 16 was alternate man on PORC.

I guess that is basically it.

17 Q.

What was your experience prior to going to GPU7 18 A.

I worked for Newport News Shipbuilding and Dry 19 Docks for five and a half years.

20 Q.

On what?

21 A.

Nuclear cruises.

22' O.

And what did you do, roughly, at Newport News?

siswART, vut 6 vv6Lsex, INc. - EEPORTING SERVICES

---

- - __ _ _888090neRoft Place __,

N.W.,

Washincton, D.C.

(202) 265-3827

5 1

A.

I was a Shift Test Engineer.

t 2

Q.

For a nuclear system?

?-

3 A.

Yes.

4 Q.

Could you tell us what your understanding is of 5

Larry King's concerns about the manner in which clean-up 6

operations were being conducted?

7 A.

In respect to --

8 Q.

Well, he seemed to be concerned -- or he was 9

concerned that certain procedures were not being adhered to, 10 basically that.

11 A.

I believe basically, in respect to the polar crane 12 and some of the work that was done on the polar crane, was 13 not done per the prescribed procedures.

It is my impression 14 that sometime ago the polar crane was turned over for 15 Bechtel to work on and fix, and get up to speed, and turn 16 back over to the utility.

17 Some of the work they did in the timef rame the 18 crane was turned over to them, I was under the impression it 19 may not have been in accordance with the procedures for 20 doing work on the island.

Certain pieces or components that 21 they replaced would normally have been done by ECM, were

~

~

22 done under the auspices of Bechtel doing the work, and REPORTING SERVICES STEWART, POE & OGLESBY, INC.

2126 Rancroft Place.

N.W.. Washincton. D.C.

(202) 265-3827.

o 6

1 consequently may or may not have been reviewed properly.

2 Q.

When you say that ECM you mean an interchange 3

memorandum?

4 A.

Yes.

5 Q.

And there is a procedure implicit in such, in an i

6 ECM7 7

A.

Yes.

8 Q.

It may or may not have been followed by Bechtel?

9 A.

Yes, sir.

That is my impression of it.

10 0..

In submitting material for the record of our April 11 26 hearing, GPU said, and this is a quote, "All procedures 12 important to safety are approved by the Site Operations 13 Director as required by the Site Operating License."

l l

14 Do you know of procedures important to safety that i

15 were not approved by the Site Operations Director?

16 A.

Not specifically.

17 Q.

Are you generally aware of any procedures of that 18 kind?

19 A.

No, sir.

20 Wait now, there may have been -- yes, there are a I

21 couple of procedures that here recently had to do with the 22' head lift task that was' written by RD&D.

I i

diswAx1, rus 6 vossaux, inv. - useuxiino ssxvicsd l

2126 Bancroft place, N.W.,

Washincton, D.C.

(202) 265-3827

7 1

Q.

And what is RD&D?

f 2

A.

Reactor Disassembly and Defueling.

3 They were issued and placed on the street, and 4

they didn't receive the proper approval.

There were two or 5

three, something like that.

6 Q.

Two or three procedures?

7 A.

Yes.

8 Q.

And proper approvals by the Site Operations 9

Director?

10 A.

Yes, sir.

11 They were never used.

They were written for work 12 to be done downstream, but they did get issued without being 13 approved by the Site operations Director.' Subsequently, 14 they were found and brought back, and I believe they have 15 been properly approved now.

16 Q.

And what did those procedures refer to?

17 A.

I am not sure specifically.

I think one had to do 18 with disconnecting the intermediate cooling water lines from 19 the head.

That rings a bell.

But there were two or three 20 of them.

5 21 Q.

Now, you may have answered this with regard to 22' your discussion about the crane.

STEWART, POE & OGLESBY, INC. - REPORTING SERVICES A AM DOae7@ f t 3SOGa N. W..

Wa n h i ne t on. D.C. (202) 26%- % 27

8 1

Was Administrative Procedure 1043 and 1047 adhered 2

to in developing procedures for testing of the crane prior 3

to its use?

4 A.

The crane has not been used yet.

The test 5

procedure submitted to site ops for review was not written 6

in accordance with 1047.

7 Q.

And when you said it was possible that certain 8

procedures weren't adhered to in refurbishing the crane --

9 A.

That was 1043.

10 0..

And Mr. Gischel has said, " Equipment and 11 components have been replaced from safety related to not 12 important-to-Jafety, without following procedures for making 13 such changes."

14 Does that procedure have a number there, or is 15 there a specific procedure that would apply to that?

16 A.

That may come under 1043.

Generally it is the 17 engineering group who is the one that determines important-18 to-safety or not important-to-safety.

19 Q.

Do you know where such reclassification might have 20 occurred without procedures not being followed?

21 A.

Not specifically, no, sir.

22' O.'

Who does PORC' report to these days?

STLWART, POL 6 QGLL5BY, ING. - REPORTING SERVICL5 2126 Bancroft Place, N.W.,

Washincton, D.C.

(202) 265-3827

9 1

A.

PORC7 2

Q.

Yes, sir?

3 A.

These days they rep 6rt to Jim Larsen, who is 4

Manager of Licensing in Nuclear Safety.

5 Q.

Has that always been the case?

6 A.

No, sir..

PORC normally reported to, and advised 7

the Manager, the Plant Manager.

8 Q.

And that would be --

9 A.

Larry King's position.

10 In the latest reorganization, that duty was given 11 to Licensing and Nuclear Safety, and the PORC was supposed 12 to change to the Safety Review Group.

13 Q.

So PORC has now become Safety Review Group?

14 A.

The function PORC used do do is now being done by 15 them.

16 C.

But there is something called the Safety Review 17 Group?

18 A.

There is a PORC now.

Right now it is an interim 19 where there is a PORC, and the people that are going to be 20 in the Safety Review Group are sitting in PORC.

And the Safety Review Group then reports to Larseni 21 Q.

22' A.

Yes, sir. 'And PORC would still basically report i

l STEWART, POE & OGLESBY, INC. - REPORTING SERVICES L -_____ _______ ____ _ _ _ M M _ na agg e t t _ Dlo co o _ N o W o o Washinoton.D.C. (202) 265-3827

_ - - - _ =

10 l

1, to King's position.

2 Q.

Is this consistent with ANSI standards?

3 A.

I am not sure.

I would have to go back up through 4

the ANSI standards pretty close.

t l

5 Q.

Are you familiar with ANSI standards 18.7 and 18.17 6

A.

Not by number.

l 7

Q.

But these are purportedly the standards that 8

require LARs to be approved by Site Operations Director?

9 A.

Yes, sir.

10 Q..

But there is something that requires LAR to be l

11 approved by Site operations?

12 A.

Yes.

l l

13 Q.

Do you know of LARs that were not approved by the 14 Site operations Director?

15 A.

LAR, meaning Licensing and Reports?

16 Q.

Yes, sir.

17 A.

Not specifically.

18 Q.

Are you generally aware of any?

l 19 A.

I see a lot of them come across my desk.

It seems e

20 like generally they have Larry's or chwastyk's signature on 21 them, one or the other.

22' Q.

But then th"e Plant Manager or the Director of Site REPORTING SLEVIGL5 STLWART, POL 6 QGLL5DY, ING.

________ _ _________2126_Danereft_ Place, N.W.,

Washington, D.C.

(202) 265-3827

11 1

Operations is the person that is responsible for ccmpliance 2

with all licensing conditions?

3 A.

Yes, sir.

4 Q.

And that person now is who?

5 A.

John Barton, I believe, is Acting Director of Site 6

Operations.

7 Q.

And prior to that?

8 A.

Prior to that, it was Larry King.

9 Q.

Do you believe that Mr. Parks' concern about the 10 polar crane was based on sound analysis, or as a result of 11 his having had an emotional commitment to -- or let me say 12 where that question comes from.

13 I think some people feel that it was his concerns, 14 they did relate to his having an emotional commitment to, 15 say, certain ways of doing the job.

And he of course feels 16 that his concerns were based on real objections to the way 17 analyses had been done?

18 A.

It was my impression his safety concerns related 19 to the methods that they were using, or that they were 20 trying to get their procedures approved by -- and it was not 21 in compliance with the test program that had been

~

22' established by 1047.'

S T EW A RT, POE & OGLESBY, INC. - REPORTING SERVICES

.AARG Doaegeft__Ploeog_N.W., Washington, D.C.

(202) 265-3827

12 1

Q.

Are you familiar with something called 2

Construction Department Services Project Instruction, or 3

CDSPI, which is a Bechtel document?

4 A.

No, sir.

5 Q.

So then you would not know about modifications 6

made to the polar crane were made more on the basis of work 7

packages prepared with the CDSPI?

8 A.

No, sir.

9 Q.

But in any case, that work should have been done 10 on the basis of an ECM7 11 A.

Probably some of it.

And some could have been 12 done under the work permit system.

13 Q.

Mr. Parks said that as of February 22 of this year, 14 "The crane load test program as then constituted, and if 15 implemented, could have resulted in substantial violation of 16 NRC requirements."

17 Do you agree with that?

That is 1043 and 1047.

18 A.

The procedure had not been approved or implemented 19 yet.

20 Q.

But as it was written?

21 A.

As it was written, I don't know about NRC 22' requirements, but it was not in compliance with 1047 and STEWART, POL 6 OGLL5DY, ING. - REPORTING SERVIGL5 2126 Rancroft place.

N.W..

Washinnenn. n.r.

(707) 7A% 1R77

13 1

1043.

I 1

2 Q.

It was or was not?

.r 3

A.

It was not.

That is the reason it was going 4

through the review cycle.

5 Q.

Do you know if consideration was given to use of a 6

string gauge'in lo.ad testing of the cranc?

7 A.

I believe somebody said something about that, I am I

8 not real familiar with it though.

9 Q.

Testing the crane was not something you were 10 intimately connected with?

11 A.

No, sir.

I was not following that, particularly.

12 Q.

Have the low pressure safety injection, or the 13 high-pressure safety injection pumps been tested since the 14 accident?

I 15 A.

I don't know for sure.

I don't believe so.

The 16 make-up pumps were run for a specific amount of time after 17 the accident, and there was a program an effort to get the 18 low-pressure injection pumps to the point where they could i

19 be run.

I don't know if they were ever actually started or 20 ran, though -- the low-pressure pumps.

l 21 C.

But the high-pressure pumps?

22' A.

They ran for 5 specific time after the accident, l

ST EWA RT, POE & OGLESBY, INC. - REPORTING SERVICES 2126 Bancroft Place, N.W., Washington, D.C.

(202) 265-3827

14 e

1 yes.

2 Q.

Since May of '79, say?

3 A.

I can't really say for sure.

4 Q.

If they were not tested, do you know why they 5

might not have been tested?

6 A.

Basically because of the RAD levels in the fooms.

7 Q.

Is it credible that breaking of a piping entoring 8

through the bottom of the pressure vessel would lead to 9

draining of the pressure vessel, or namely, is it credible 10 there could be a break in the piping leading to the bottom 11 of the pressure vessel?

12 A.

Credible?

13 Q.

By credible, I mean --

14 A.

A high probability?

15 Q.

Well, is it possible that -- if someone said, "Maybe 16 there is a large amount of uranium in the basement of the 17 reactors building that might go critical," you might say, 18 "We don't have to worry about it."

But the breaking of a 19 pipe that entered through the bottom of a pressure vessel 20 might or might not fall into that.

In the context, is this 21 something that should be planned for?

22' A.

I would think'if you were going to get a look in REPORTING SERVIGL5 STLWART, FUL 6 OyLL55Y, ING.

---

-----_------- -- RAR& Bn ERR @ R R M o @o n %%o MooMaegeao DoCo (202) 265-3827

15 1

the RCS, that probably would be one of the higher 2

probability areas, yes.

3 Q.

If this were to occur, would it be necessary to 4

inject water into the core?

5 A.

By the procedures that are on the street right now, 6

yes.

7 Q.

Do you think anything terrible would happen if 8

water were not injected into the core?

9 A.

I don't know.

That would have to be a decision as 10 you come along.

11 Q.

What kind of thing might happen if water --

12 A.

Eventually you would drain the vessel down.

13 Q.

But is there any particular safety hazard that 14 would occur if water were to suddenly be removed from the 15 core?

16 A.

It depends a lot on core configuration, and nobody 17 is certain of core configurations.

18 Q.

But if the core is -- if it is something like 200 19 kilowatts now, is that it?

20 A.

It is way down.

21 Q.

But is 200 kilowatts --

22' A.

I think it'is'less than that.

STEWART, POE & OGLESBY, INC. - REPORTING SERVICES Washington, D.C.

(202) 265-3827

_______2126_Bancroft Place,-- -N.W.,. _ _ _ _. _

16 1

Q.

Is there concern that is enough heat to cause 2

melting?

3 A.

No, sir; I don' t believe so.

4 Q.

So why then --

5 A.

The concern would be that you could have an 6

inadvertent crisis in event of some of the water turning to 7

steam.

Here you are getting into some --

8 Q.

Somehow if water were put back in the core that 9

was not borated?

10 A..

That could give you a problem.

11 Q.

But the core just sitting there without any water, 12 is there anything --

e 13 A.

Theoretically, this should be no problem.

But 14 seeing they don't know the core configuration, people will --

15 Q.

Would the radiation levels in the reactor building 16 go up if water should run out of the core, in the sense that 17 there would be less shielding, between the inside and the 18 outside if the water were to --

19 A.

I doubt very seriously the water in the vessel is 20 providing much more shielding than the head itself.

Now, if 21 you were to take the head off and drain water out, you would 22~

probably see a considerable increase in RAD level.

bTLWAhT, PUL 6 UULLbBX, I ts. - REPOETING SERVICE 5 2126 Bancroft Place.

N.W.,

Washinoton, D.C.

(202) 265-3827

17 1

Q.

If the head were off and the water was to run out,

(

2 then the radiation --

3 A.

Yes, you would probably see an increase.

4 Q.

There is, some people feel, potentially flammable 5

material brought out in the vessel head in the upper 6

internals?

7 A.

Yes, sir.

8 Q.

Have you had anything like that?

9 A.

Yes, sir.

10 Q.

So, if the water level were to drop, then is there 11 some concern that that flammable material, that something 12 would happen to it?

13 A.

Yes, sir.

It is Unit 2 Tag.

14 Q.

What are these materials?

What are the elements?

15 A.

I believe it is zirconium high-drive they were 16 worried about.

17 Q.

Zirconium high-drive came about from --

18 A.

From the fuel pins during the accident.

13 Q.

But that made zirconium oxide?

20 A.

Yes, sir.

21 Q.

But if this were to happen and there were enough 22' there, at least some peo'ple have a concern that is flammable

~

STEWART, POE & OGLESBY, INC. - REPORTING SERVICES RA84 Rnn@ Reft Place, N.W.,

Washincton, D.C.

(202) 265-3827

18 1

if it were exposed?

2 A.

Yes, sir.

Some people have a concern that it 3

might burn.,

4 Q.

Do you have any sense of whether more stringent 5

adherence of licensing were given to Site Operations 6

Proposals than for Recovery Operations Proposals?

7 A.

Sometimes it may have appeared that way.

8 Q.

That is because people thought the other people 9

were being required to adhere to more stringent standards?

10 A.-

Yes, sir, 11 Q.

Could you describe the difference between what 12 Site Operations was requested to do in installing water 13 level instrument anticipation and what Recovery Operations 14 was required to do?

15 A.

I am trying to think.

Is this in the steam 16 generator level?

17 Q.

I believe that was in the pressure vessel.

18 A.

Read that again, please.

l l

19 Q.

Could you describe the difference between what 20 Site Operations was requested to do in installing water-21 level instrument anticipation, and what Recovery Operations

~

i 22 was required to do?

\\

k

)

b1LWAMA, PUL 6 UULLbbX, ING. - REPORTING SERVICES (202) 265-3827

= - - - - - -

-. 2126 Bancroft Place. N...W., Washincton. D.C.

19 1

A.

I am not sure in what respect we are talking about.

I 2

Q.

I guess the question this relates to is to whether 3

Site Operations was being required to adhere to a more 4

stringent standard for the work than was Recovery Operations?

5 A.

And I am not'sure how that question fits into the

' ~

6 two.

7 Q.

And what in installing --

8 A.

We basically had one level indication, and we-9 decided to try to establish another, because basically two 10 is better than one.

11 The second one was merely a stand-pipe off of two 12 valves, one, a collate piping, the valves were there 13 specifically for the normal level indication that was used 14 during normal refueling.

You just put Tag-2 tubing and make 15 a stand pipe.out of it.

16 The other level indication was a pressure 17 transmitter and pressure gauge installed off the DK heat-18 drop line, put on the design engineering for the quick-lock 19 test.

We modified it so that after we were drained down, it 20 would be compensated for reactor building pressure along 21 with water level.

And we did that by coming off a pressure 4

J

'22' tap on'the building sprdy line and running -- it went STEWART, POE & OGLESBY, INC. - REPORTING SERVICES 2126 Bancroft Place, N.W.,

Washington, D.C.

(202) 265-3827

20 1

directly into the building, and running it down to the low 2

side of the gauge.

3 We had a little more trouble doing that, 4

procedurally, than we did putting the stand-pipe on, but I 5

am not sure --

6 0

But the stand-pipe, where the stand pipe was, down 7

with a tag-2 beam?

8 A.

That is a pretty simple solution.

9 O.

It did not create any particular hazards, as far 10 as you know?

11 A.

Not as far as I was concerned.

12 Q.

Could you tell us what quick-scan was intended to 13 do?

14 A.

We have quick-scan -- I am not real sure.

15 O.

My sense of quick-scan had something to do with 16 determining radiation level under the head?

17 A.

The whole data acquisition package was -- that was 18 the intent of it.

Quick-scan-2 was -- I believe it was the 19 first part of it, where we dropped a RAD-CON instrument in 20 and took a reading under the head, with the water drained 21 out.

~

22~

Q.

And was this agreement that the Safety Review REPORTING SERVICES STEWART, POE & OGLE 5BY, INC.

2126 Bancroft Place.

N.W.,

Washincton.

D.C.

(202) 265-3827

21 1

Group or PORC, would not review procedures for quick-scan 2

until it had been reviewed and approved by the NRC, namely 3

were procedures being sent to the NRC for review prior to 4

their having been approved by the Safety Review Group?

5 A.

Yes, sir.

Some draft procedures were sent to the 6

NRC.

7 Q.

Was that normal?

Is that a normal way of doing 8

things?

9 A.

No, sir.

10 Q.

So, NRC did review draf ts of quick-scan procedures 11 prior to approval of the SER from which the procedures were 12 derived?

13 A.

They had them to review; yes, sir.

14 Q.

And it was true the NRC was examining procedures 15 while a new SER was being prepared?

16 A.

Yes, that is true.

17 Q.

And did NRC issue a letter, to your knowledge, 18 somewhere around 9 or 10 March, saying there was a problem 19 with these procedures?

20 A.

I believe they did; yes, sir.

21 Q.

Did they say anything, to your recollection, about 22' issuing a citati~on at that time?

STEWART, POE & OGLESBY, INC. - REPORTING SERVICES 2126..Bancroft Place, N.W.,

Washington, D.C.

(202) 265-3827

22 1

A.

I don't remember at that time.

2 Q.

Do you know what it is that requires PORC to 3

approve SER and procedures prior to being given to the NRC7 4

Is that Tek Pak 8.6.2 --

5 A.

Yes, sir; I believe it is.

6 Q.

In the course of draining the steam generator, was 7

there an unmonitored release of krypton?

8 A.

I can't answer that for sure.

9 Q.

Were you involved in it?

10 A..

There was a release of krypton from the B 11 generator back for quick-look, yes, sir.

12 Q.

But that was not related to the draining?

13 A.

Well, it was related to draining the B generator 14 down for quick-look, not forehead lift.

15 Q.

Is there evidence of cesium being released as a 16 result of a break-through in the four by four liner used to 17 drain steam generator B?

18 A.

I don't believe so, I don't know that.

19 Q.

You are saying you don't know?

20 A.

I don't recall.

21 Q.

Were deficiencies discovered, or problem areas 22' disclosed to the head lift task force during weekly meetings STEWART, POE & OGLESBY, INC. - REPORTING SERVICES 2126 Bancroft Place, N.W..

Washincton, D.C.

(202) 265-3827

23 1

that you attended?

(

2 A.

Read that again, please.

3 0.

What kinds of deficiencies or problem areas were 4

discussed at head lift task force meetings?

There were problem areas and deficiencies 5

A.

6 discussed at'the weekly meetings; yes, sir.

Some of them 7

had to do with how we were going to drain down the B-steam 8

generator, and the fact the SER had not been completed per 9

the schedule for the head lift, and things like that.

10 0

Has the SER been completed now?

11 A.

At this point, I don't believe so.

12 0.

What kind of problems were being encountered?

13 A.

We had a problem trying to figure out how to drain 14 the B generator, because the valve coming out of the I

15 building that we were going to use to drain the generator 16 with is stuck shut.

So we could not drain the B generator 17 like we did the A generator.

18 0

The valve coming out of which building?

19 A.

The reactor building, for draining the B generator.

20 0

And has that problem been resolved?

21 A.

Yes, sir; we have since drained it.

22' O.

Did ld'21 or' 1043 require issuance of an ECM prior STEWART, POE & OGLESBY, INC. - REPORTING SERVICES 2126 Bancroft Place, N.W.,

Washincton, D.C.

(202) 265-3827

x 24 1

to draining steam generators?

2 A.

I don't believe ECM was issued to drain the The B-steam generator, there were two or 3

A-steam generator.

4 three ECMs issued.

As it turned out, we managed to get a 5

piece of Tag-2 tubing on a valve we didn't think we had 6

access to, and we drained through the Tag-2 tubing.

So I 7

don't believe any ECMs were implemented, but I think there 8

were a couple of ECMs on draining the B generator.

9 Q.

Did 1021 and 1043 require any ECM prior to 10 draining?

11 A.

No, sir.

I don' t believe so.

12 0

So was there anything that required an ECM prior 13 to draining?

14 A.

The B generator -- first of all, one of the 15 options was to cut the line upstream of the valve that was 16 stuck shut, and just let it drain.

And that would have 17 taken an ECM; yes, sir.

And I believe one in fact was 18 issued to do that, but it was not implemented.

19 Q.

Because yoJ found that --

20 A.

We found a7other path; yes, sir.

21 0

Are you aware of any significant discrepancies 22' between drawings and '"as built" conditions at TMI-2?

STEWART, POE 6 OGLE 5BX, INC. - REPORTING SERVICE 5 2126 Bancroft Place, N.W.,

Washington, D.C.

(202) 265-3827

25 1

A.

With the "as built," the drawings don't 2

necessarily reflect the "as built."

3 Q.

Could you give us an example of a case you might 4

consider that significant?

5 A.

One that just came up, there is a self 6

strengthening valve on the SDS header going to the monitor 7

tanks.

That does not show up on the composite drawing for 8

SDS.

I don't know if that is signiCicant.

9 Q.

Has anyone ever made a list of drawings which did 10 not reflect the "as built" conditions?

Is that something 11 that has to be reported to the NRC?

12 A.

I am not sure.

I don't think so.

We did come up 13 with a list of drawings we felt were necessary to be updated, 14 and I believe some money was committed to it when Burns and 15 Rose started.

16 Q.

Is there something like a Nonconformance Report, 17 something called that?

18 A.

Yes, sir; I think so.

19 Q.

And if you find a situation in which a drawing 20 does not conform to the "as built" conditions, is that 21 something that would call for a Nonconformance Report?

~

22-That would be one method for pointing it out; yes, A.

STEWART, POE & OGLESBY, INC. - REPORTING SERVICES 2126 Bancroft Place.

N.W.,

Washinoton, D.C.

(202) 265-3827

26 1

sir.

2 0.

But quality assurance procedures at the plant, do 3

they require this?

4 A.

I am not sure.

Do you have any idea why it was Recovery 5

O.

6 Operations rater than Site Operations Control that controls 7

access to the reactor building?

8 A.

No, sir.

Other than that is the way it was 9

decided.

10 0..

As far as you know, were these entries done in a 11 manner to comply with applicable licensing conditions?

12 A.

Yes, sir; to the best of my knowledge.

13 0

Are you aware of work performed in a continuing 14 building that was not approved by a Senior Reactor Operator?

15 A.

No, sir; not specifically.

16 0.

Are there contingency plans for removing bolts 17 from the reactor pressure heads, if it turned out these 18 bolts are warped or jammed in some way?

4 19 A.

Yes, sir; I believe there is.

There is, or they 20 are working on it, one or the other.

21 0

These questions now relate to the day of the 22' accident.

~

~

biLWART, FUL & UGLL55Y, INC. - REPORTING SERVICES 2126 Bancroft Place, N.W., Washington, D.C.

(202) 265-3827

27 1

Do you recall what time you arrived at control

/

2 room on that day?

3 A.

I initially got to the control room somewhere in 4

the timeframe, probably 5:35 to 5:45, something like that.

5 Q.

But they called you in?

6 A.

Yes, sir.

I think I got the phone call at five 7

o' clock.

8 Q.

Do you recall what you did when you got there?

9 A.

I went up to the control room, went into the 10 control room, there was an AUX operator there, and I asked 11 him what tripped us, and he said, "The consoles."

I went 12 downstairs to the consoles.

13 Q.

And so you were not then in the' control room when 14 the first reactor coolant pumps were turned off?

15 A.

No, sir.

16 0..

Were you there when the second two were turned off?

17 A.

No, sir; I was not.

l 18 Q.

Did you participate in any discussion leading to 19 the decision to shut down reactor coolant pumps?

20 A.

No, sir, I wasn't.

21 Q.

So you were down looking at the polishers?

~

22' A.

I think about a hour or an hour and 15 minutes.

STEWART, POE & OGLESBY, INC. - REPORTING SERVICES

'2126 Bancrof t Place.

N.W..

Washincron.

D.C.

(707) 76; 1R77 L

28 1

When I came back up, they were talking about starting 1-B 2

coolant pump.

That is when I realized the coolant pumps 3

were secure.

4 0

Were you aware of any plan to go into the reactor 5

building at approximately 4:30 a.m.?

6 A.

I heard somebody in the background say get RWP 7

ready.

8 0.

You were going to go in, or this is just something 9

you heard in the background?

10 A..

This is something I heard in the background while 11 I was doing something else.

12 Q.

That someone was going to tell you to go in?

13 A.

Somebody said, " Bob and I will go in and vent the 14 legs."

15 0.

If you were going to go in to vent the hot legs, 16 is that something anyone ever did before?

17 MR. MARCOUX:

Are these still around the reactor 18 coolant pumps, or the accident sequence 19 DR. MYERS:

This is accident sequence.

20 MR. MARCOUX:

I thought we were only going to talk 21 about reactor coolant pumps.

~

22' DR. MfERS: ~ Let's go off the record.

l l

i d i LW A Ki,. FU L h UVLtdbl, 1NL. - REPORTING 5ERVICE5 2126 Bancroft Place, N.W.,

Washington, D.C.

(202) 265-3827

29 1

(Discussion off the record).

(

2 DR. MYERS:

Back on the record.

3 BY DR. MYERS:

4 Q.

Were you aware on March 28, 1979 that safety 5

injection was or was not initiated at approximately 5:41 6

a.m.,

approxi'mately coincident with the turning off of the 7

last reactor coolant pumps?

8 A.

I don' t know.

9 Q.

You don't recall?

10 A.

I have no knowledge; no, sir, 11 Q.

"Are you aware that the GPU sequence of events 12 indicates that safety injection was initiated at about 5:41 13 a.m.?

14 A.

Not particularly.

15 Q.

Have you read the GPU sequence of events?

16 A.

I may have in the past, but I don' t remember 17 reading it.

18 Q.

So it is possible you have just never read the 19 sequence of events?

20 A.

It is possible I have, yes.

21 Q.

But do you recall any discussion of whether HPI

~

22' was initiated at approximately 5:41 a.m. prior to the GPU?

STEWART, POE & OGLESBY, INC. - REPORTING SERVICES D.C.

(202) 265-3827 212 6_ B a ncr_o f t,. Pl a ce.

.N. W.. Wa s h i n c t o n.

30 1

A.

No, sir.

2 Q.

So you don't recall any discussion of 3

high-pressure injection initiated about that time?

4 A.

No, sir.

5 O.

When did you first become aware of some operators 6

having recalled that HPI had been initiated at approximately 7

the time the last reactor coolant pumps were turned off?

8 A.

Just now, I guess.

9 Q.

Just since it came up?

10 A.,

Just since you said it.

I was not aware that HPI 11 was secure.

12 Q.

Or that it was initiated?

13 A.

That it was initiated?

14 0.

Yes, sir.

15 A.

I figured that it was initiated at the time of the 16 reactor trip.

17 0.

And then was secured shortly thereafter?

18 A.

I was not aware of it.

19 Q.

You were not aware?

20 A.

That it was secured and started back up; no, sir.

21 0.

You were not aware that it was throttled back 22' several minutesafter it was turned on, or it came on in the b1bWART, POL & OGLE 55Y, ING. - REPORTING SERVICES 2126 Bancroft Place, N.W., Washington, D.C.

(202) 265-3827

31 1

first place?

/

2 A.

I would imagine that it was throttled back.

3 Normally it was.

You were supposed to throttle it back.

4 0.

Initially?

5 A.

Yes.

6 0.

But you were not aware that some operators 7

recalled that they took action to initiate something like 8

full flow at approximately the time the last reactor coolant 9

pump was turned off?

10 A.

No, sir.

11 0.

And you never heard discussion of that until Parks 12 said that?

13 A.

I don't remember discussing that with anybody.

14 0

Do you remember discussing it with anyone?

15 A.

No, sir.

16 0

Do you recall when you became aware this was a big 17 issue at the trial?

18 A.

I wasn't aware it was a big issue at the trial.

19 0,

You were not aware it was a big issue at the trial?

20 A.

No, sir.

I 21 0.

That is all I have on that area.

22 Now, were you aware of problems prior to the STEWART, POE & OGLESBY, INC. - REPORTING SERVICES 7126 Ranern*e place.

N.W..

Wachinernn. n.c.

(707) 769 1R77

32 1

accident relating to design deficiencies of the make-up 2

demineralizer systen, or with the condensating polisher 3

system?

4 A.

Could you repeat that question?

5 Q.

Were you aware of problems prior to the accident 6

as problems existing prior to the accident, relating to the 7

design deficiencies of the make-up demineralizer system, or 8

with the condensating polishing system?

9 A.

The condensating polishing system had some design 10 problems; yes, sir, 11 0.

Do you know how these deficiencies had been 12 documented?

13 A.

It seems they were documented by field questioners, 14 and there was a memo put together by, I believe, myself and l

15 Joe Ogden and.Carey Hart, that talked about problems that we 16 had with the condensating polishers that should be corrected 17 in the early stages of Forked River.

18 Q.

The early stages of --

19 A.

Of Forked River.

That was the other plant that 20 was under construction.

21 0.

How were these tracked at Three Mile Island to 22' make sure they were coriected?

SILWART, FOE & OGLESBY, INC. - REPORTING SERVICES 2126 Bancroft Place, N.W.,

Washinaton, D.C.

(202) 265-3827

e 33 l

o 1

A.

I can think of two in particular where ve

~

2 submitted work requests to modify some of the pecple going 3

to the air regulators for the control valves, and we wanted 4

to pipe the domineralized water directly into the line.

5 Q.

Was there some document that was placed somewhere 6

which would allow everyone to know, or those in charge to 7

know that these deficiencies were being taken care of?

8 A.

No, sir.

Not to my knowledge.

9 Q.

What is a punch list?

10 A.

A punch list?

11 Q.

Yes, sir.

12 A.

This goes back to the system turn-off.

When the 13 contract or and start-up company were completed, 14 construction of the system, and were ready to turn it over 15 to the utility, the individual departments in the utility 16 went out and walked the system down, and listed any 17 discrepancies that they had with the system.

And that was 18 put into a punch list.

That was part of the turnover 19 package.

20 Q.

So this is a list of items relating to --

21 A.

Each individual system.

22 Q.

-- where corrective action of some sort might be

~

STEWART, POE & OGLESBY, INC. - REPORTING SERVICES 2126 Bancroft Place.

N.W..

Washincron.

D.C.

(202) 265-1R77

n 34 6

1 necessary?

2 A.

Yes, sir.

3 Q.

Is the punch list available now as it existed?

I 4

mean, does this punch list exist from -- I mean, what 5

happens to the punch list after the systems are turned off?

6 A.

I believe it was maintained.

7 Q.

It is maintained?

8 A.

Yes, sir.

9 Q.

So at some time thet punch list exists somewhere?

10 A..

Yes, sir; it should.

11 Q.

Is the punch list as it existed on March 28, 1979 12 now available?

13 A.

I can't answer that.

14 Q.

Who would know whether it was available?

15 A.

It should be available.

16 Q.

Have you ever seen it?

17 A.

I saw it about the time of system turn-off, or 18 plant start-up.

19 Q.

Have you seen it since the accident?

20 A.

No, sir.

I have not looked for it.

21 Q.

But if we were interested in looking at that list, 22' who would we ask for'it?

STEWART, POL & OGLESSY, INC. - REPORTING SERVICES 91.on n.nc,n't Dirca._N.W.. Washineron. D.C.

(202) 265-3827

i 35 D

1 A.

I would imagine it is in the Document Control, f

2 they should have it somewhere.

Each individual MTX had its 3

own punch list, and there was a master punch list that was 4

maintained.

5 Q.

Do you think that punch list should have been 6

turned over to the.NRC at some point?

7 A.

I believe NRC reviewed it before they gave us our 8

operating license.

9 Q.

But since the accident, with all these 10 investigations, did anyone ever ask, to your knowledge, 11 "Where is the punch list"?

12 A.

No, sir.

13 Q.

Do you have any idea how many items might have 14 been on that master punch list prior to operation?

15 A.

I would think probably around 5,000.

16 Q.

You say 5,000?

17 A.

Yes, sir.

18 DR. MYERS:

Those are all the questions I have.

19 MR. MARCOUX:

I have no questions.

20 (Thereupon, at 2:50 p.m.,

the taking of the 21 deposition was concluded).

STEWART, POE & OGLESBY, INC. - REPORTING SERVICES 2126 Bancroft Place.

N.W..

Washincton.

D.C.

(202) 265-3827

I 36 0

1 CERTIFICATE OF REPORTER 2

I, William J. Allen, shorthand reporter, do hereby 3

certify that the statement which appears in the foregoing 4

Pages 3 through 35 were taken by me stenographically and 5

thereafter reduced to typewriting under my supervision; that 6

said statement is a true record of the proceedings; that I 7

am neither counsel for, related to, nor employed by any of 8

the parties to the action in which this statement was taken 9

and further that I am not a relative or employee of any 10 attorney or counsel employed by the parties thereto, or 11 finacially or otherwise interested in the outcome of the 12 action.

13 14 Court Reporter 15 16 17 18 19 20 21

~

22 biLWANT, PUL 6 UULL55Y, INC. - REPORTING SERVICES 2126 Bancroft Place, N.W.,

Washington, D.C.

(202) 265-3827

c--

'o 3

b 1

40103 2

COMMITTEE ON INTERIOR AND INSULAR AFFAIRS 3

4 5

Washington, D.C.

6 Friday, April 1, 1983 7

INTERVIEW OP:

8 CRAIG C.

FAUST, 9

a witness, called for an interview pursuant to agreement of 10 the parties, in the Longworth House Of fice Building, Room 11 1324, Washington, D.C.

2'0515.

Beginning at approximately 12 10:00 o' clock, a.m.,

before WILLIAM J.

ALLEN, a Notary 13 Public in and for the District of Columbia, when were 14 present on behalf of the respective parties:

15 16 APPEARANCES:

17 On Behalf of Craig C.

Faust:

18 lee 0EUF, LAMB, LEIBY & MacRAE BY:

HARRY H. VOIGT, ESQUIRE 19 1333 New Hampshire Avenue, Northwest Washington, D.C.

20036 20 21 JL'il 3 1933 u.

(i' 22 STEWART, POE & OGLESBY, INC. - REPORTING SERVICES

s 2

1 APPEARANCES (Continued:)

I 2

On Behalf of The Committee Staff:

3 DR. HENRY MYERS, SCIENCE ADVISOR Committee on Interior & Insular Affairs 4

1324 Longworth House Office Building Washington, D.C.

20515 5

6 Also Present:

7 STANLEY SCOVILLE, STAFF DIRECTOR AND COUNSEL PAUL PARSHLEY, CONSULTANT 8

EILEEN HOLLOWELL, STAFF COUNSEL 9 10 l

11 INDEX 12 13 THE WITNESS:

EXAMINATION BY:

14 CRAIG C.

FAUST DR. MYERS 4/65 15 MR. VOIGT 64 16 MR. SCOVILLE 17 MR. HOLLOWELL 18 MR. PARSHLEY 19 20 No Exhibits 21 I;Y 22 c

2 bTEWAMT, PUE 6 UULLb5Y, INC. - REFUMTING 5ERVICE5 l-u

~~

m m,. o _

..o o o o p.. o pp. c> o o p. _ _ _ _ _ _ _ _

b i

3 1

PROCEEDINGS 2

DR. MYERS:

This interview is being conducted as a 3

part of our inquiry into the TMI accident and clean up, and 4

as part of this we expect to interview additional employees 5

and request depositions taken in conjunction with the trial 6

which were not submitted at the trial.

7 I would like to say that early on in this inquiry, 8

we came to believe during the early hours of the accident, 9

the operators did act in reasonable accord with their 10 training, and it is our' understanding that the NRC -- that 11 is the official position of the NRC at this point.

The fi 12 purpose of this is not to somehow fix blame on operators 13 doing the right or wrong thing during those early hours.

14 So the question that we really want to address is 15 whether, Mr. Faust, to the best of your recollection, was 16 the high-pressure injection turned on about 5:40 a.m. on 17 March 28 coincident with the turning off of the reactor 18 coolant pumps?

19 THE WITNESS:

To the best of my recollection -- I 20 can't actually state it, what has happened in the past, but 21 I would go back to this and look at the previous thing and 22 it indicates that we tended to agree that it was turned on, STEWART, POE & OGLESBY, INC. - REPORTING SERVICES

s

~

4 1

but I would like to clarify that.

If I gave a i,,.

2 misinterpretation on this when I say turned on, I meant 3

reinitiated from the state at which it was on, and all we 4

were doing was just a measure -- this is purely -- I am 5

speculating now in telling the truth.

6 EXAMINATION 7

BY DR. MYERS:

8 Q.

Was there a countdown so that the flow which had 9

been approximately 25 gallons per minute, up to that point, 10 and it is our understanding that water was being taken out 11 of the make-up tank and the letdown system was in operation

(

12 during this first 100 minutes, and that the average flow 13 during this period was like 25 gallons per minute or less.

14 Was the flow through these makeup pumps and high-pressure 15 injection pumps substantially increased at approximately 16 5:40 a.m.,

coincident with the turning off of the reactor 17 coolant pumps, to the best of your recollection?

18 A.

From where I was at, I could not say whether it 19 was or not.

I can just say what I believe happened at that l

l 20

point, i

21 0

Could you tell us what you believe happened?

n.

vf 22 A.

Before we took off the last set of reactor coolant bTEWART, FUL & UULLb5Y, INC. - REPORTING SERVICE 5 L

w m n naman aco aaaa

S

(

5 1

pumps, we reinitiated the high-pressure injection, and once 2

again I am not saying it was turned of f, that is about all I 3

can state on that.

4 Q.

But to the best of your recollection, was that 5

high-pressure injection reinstated at full flow?

6 A.

I can't verify that, simply from the point that I 7

was not over at that ctation, and when I talked about some 8

of this later on, I talked -- I had already been in talking 9

with Bill and Fred on the previous interviews, and it sort 10 of became established, when I was in some of these 11 interviews, I told the whole story from my own point of view,

(

12 not only from my own behalf, but from theirs, and it is not 13 actually factual, as I am the one doing it.

14 Q.

But as a result of those discussions, did you 15 sometime in the months after the accident agree, when you 16 tal.ked about what you had done, did you agree that you had 17 turned on the high-pressure injection or reinstated it at 18 nearly full flow or full flow at that time, or just prior to 19 turning off the reactor coolant pumps?

20 A.

It became known as that.

The reason I say that is 21 that I was one of the ones who first said when we were going j g.

Os 22 over sequences of events trying to relate it, I said didn't STEWART, POE & OGLESBY, INC. - REPORTING SERVICES

,S o

g I

we do this, I feel like we reinitiated high-pressure 2

injection just before we took the pumps off, and they sort 3

of agreed with me, and that is all.

From what I recall of 4

it, they were not even sure at that point, they just said 5

since they felt what --

6 MR. SCOVILLE:

Could you identify who "they" are?

7 THE WITNESS:

Bill Zewe and Fred Schiemann.

8 MR. SCOVILLE:

Several times you have touched 9

pieces of paper.

Could you identify those?

10 DR. MYERS:

Those are' documents we have given him.

11 MR. SCOVILLE:

You have referred to them.

(.

12 THE WITNESS:

These are the sequence of events, I 13 am not touching them, I am just saying the sequence of 14 events we had gone over earlier, there was only one I 15 remember when I was in a room with them, and the statement I 16 am making is from an early interview we were in on, if you 17 want to call it a suggestion, or I put it in the sequence of 18 events in our minds at that point; I feel like it happened 19 at that point, but I can't say it as a fact any more.

20 MR. SCOVILLE:

Thank you.

21 BY DR. MYERS:

k.,2 22 Q.

Would it have been reasonable that it happened?

i STEWART, POE & OGLE 55Y, ING. - REPORTING SERVICE 5

~'~*:

.= e.

. ~ '

. *...- e *.

=

~ ~

~ ~ ~.

~** ~~~~

7 1

Our reading of the record is that you were turning off the 2

reactor coolant pumps, that you recognized at that time 3

there was saturation conditions in the primary, and you were 4

seeking to initiate natural circulation, and that you 5

thought that it was important to have the system full of 6

water for purposes of doing natural circulation.

So would 7

it have been reasonable that you would have turned on the 8

high-pressure injection of full flow at that time?

9 A.

Well, one thing I did not realize, we were at 10 saturation at that point.

I'm not sure how I got -- well, I 11 have a feeling how I got it in there.

A lot of my 12 depositions and interviews that you are looking at were sort 13 of -- you can see where I was getting out of step in reading 14 things.

One thing I did do, I don't remember talking about 15 or thinking about steam in the system until we were trying 16 to recover -- we knew that we had the bubble in the loops 17 later on in the day, and it became common to talk about i

18 voids and steam throughout the whole system shortly after i

19 that, and I started using those terms in my depositions.

I 20 don't really remember exactly what I was thinking of when we 21 were taking the pumps off.

I can go back through this, and l

l (? '.

i (.,.

22 a lot of this I could see that I was talking from prior

{

l STEWART, POE & OGLESBY, INC. - REPORTING SERVICES

8 1

testimony and using terms that I had used since the accident.

/

2 Q.

What is it that you thought was causing the pumps 3

to vibrate?

4 A.

I don't know to be honest with you.

5 Q.

But it was clear they were vibrating?

6 A.

Yes.

/

7 Q.

And there were instruments indicating that the 8

pumps were vibrating?

9 A.

Yes.

I pointed that point out to Bill, and I 10 pointed it out in a general sense, not just to Bill.

11 MR. VOIGT:

When you refer to pumps, you are

(

12 referring to reactor coolant pumps?

13 DR. MYERS:

Right.

14 BY DR. MYERS:

15 Q.

Do you recall then the turning off of the I

16 high-pressure injection after it was called on at 5:40 a.m.,.

17 since the group decided -- or the group decided in the I

18 months following the accident that high-pressure injection i

19 was reinstated at something like full flow at approximately 8

20 5:40 a.m.; is that correct?

21 A.

Yes, that is what we came to believe.

i d *4,

/

' (S 22 Q.

Did the group reach any consensus as to when it STEWART, POE

6. OGLE 5BY, INC. - REPORTING SERVICES

~

9 1

was turned off after that?

2 A.

Not that I know of.

3 Q.

Did you discuss who turned it off ever?

4 A.

You mean later on in the day?

5 Q.

Either later on in the day or since the accident, 6

have you discussed amongst yourselves what it was or what 7

was the situation leading to turning off the high-pressure 8

injection?

9 A.

I don't remember discussing it -- you mean just 10 Bill Zewe, Fred and myself.

11 Q.

Did you discuss that with anyone?

12 A.

Yes, I have been asked the sequence of the pumps, 13 because later on -- well, I will put it this way, I believe 14 it was right around seven to eight in the morning I shifted 15 my station on the secondary side of the feed water system, 16 and I became the primary system pump operator for the 17 high-pressure injection and makeup pumps, and I made several 18 manipulations on the pumps during that period of time, of 19 which I was not throttling back on high-pressure injection.

20 Q.

But we know if it was turned on at full flow at 21 5:40 a.m.,

it could not have been left on very long because hE 22 of data indicating what the level of water was in the STEWART, POE & OGLESBY, INC. - REPORTING SERVICES

10 1

storage tank, so we know at most there could have been 5,000 2

gallons injected at that time, and that would mean only five 3

minutes or so?

4 A.

Yes.

5 Q.

Now, did you ever speculate amongst yourselves 6

having decided to the best of your recollection in the 7

months following the accident that the high-pressure 8

injection had been reinitiated at approximately full flow 9

while it was that that led to its being reduced 10 approximately to zero, or to a very low level?

11 A.

Not with me, not f rom that point of view.

(

12 Q.

Well --

13 A.

You are putting in a specific timeframe there.

14 Q.

But you did turn it on, I mean the group did agree 15 that it had been turned on at full flow or nearly full flow 16 at approximately the time that the main reactor coolant 17 pumps were turned off.

18 MR. VOIGT:

Just a minute, there are two questions 19 there.

One said they did turn it on, and the other said 20 they later agreed.

21 Now, he testified he does not know --

()

22 DR. MYERS:

But somehow this group of operators STEWART, POE & OGLESBY, INC. - REPORTING SERVICES

11 agreed to the extent they did put that into the chronology.

1 s

2 MR. VOIGT:

That is right.

3 DR. MYERS:

None of them disagreed.

4 MR. VOIGT:

At that time.

5 DR. MYERS:

But they in fact, in one of these 6

places you can see someone wrote in that they insisted that 7

it be included there.

8 So for whatever reason it appears that Zewe at 9

least seemed to have been responsible for putting that in 10 there, he did that, according to Zewe on the basis of his 11 having discussed that with Mr. Faust and Mr. Frederick, and

(-

12 at least it appears that in May 1979, up t'o at least a few 13 months ago, that was their position?

14 THE WITNESS:

Nobody ever started asking us 15 specifically why.

16 BY DR. MEYER:

17 Q.

But this appears to have been something they l

l 18 believed otherwise they would not have gone out of their way 19 to have it inserted in the sequence of events?

20 A.

That is why I was trying to say, when this was 21 done, I feel I am the one that initially said -- because I

. Om

' (s) 22 ' was

'- I can' t even clarif y this, because I think it was in l

l STEWART, POE & OGLESBY, INC. - REPORTING SERVICES

_ o g o m._ o, -

e. 29 9..

12

'1 1

with one of the first interviews with the NRC.

2 Q.

I think it is one I gave you there?

7 3

A.

Where I said didn't we do that at this time, or 4

something to that ef f ect.

5 Q.

But if Mr. Frederick had actually done it, then he 6

would have said -- he did not disagree?

7

~

A.

He didn't really remember.

8 Q.

At that time?

9 A.

Yes, because he more or less said after I sort of 10 insisted on it -- I just still feel that -- I am trying to 11 clear up that I put the idea out at that point, and sort of

(.

12 insisted on it at that point that I thought we had initiated 13 high-pressure injection, and once again I didn't believe it 14 to be turned off totally.'

15 Q.

But knowing what the level in the storage tank was --

16 A.

I did not know that at that time.

r 17 Q.

So it,was not your -- at that time you did not 18 know what the circumstances were as to turning off the 19 high-pressure injector.

20 Sir, do you know who turned off the high-pressure 21 injection --

($-

22 A.

I don't know anybody did, that is what I am trying STEWART, POE & OGLESBY, INC. - REPORTING SERVICE 5 no an nom ms a m m m m m_

m a o coo n s noe

nnn,

13 1

to say.

I 2

Q.

Well, the data does indicate that, because if it 3

were turned on at full flow, then the water level in the 4

water storage tank by 7:10 would have been substantially 5

lower than it was, so there is data indicating that, namely 6

at most, it could have been on for five minutes at full flow.

7 MR. VOIGT:

Are you asking him whether he knows, 8

or are you saying you know that?

9 DR. MYERS:

I am asking him if he knows?

10 THE WITNESS:

The question you are asking me I 11 don't know.

( -

12 BY DR. MYERS:

13 Q.

Did you and your co-workers discuss that in the 14 months following the accident.

15 MR. VOIGT:

Discuss what?

16 DR. MYERS:

Discuss the turning off of the 17 high-pressure injection at that time?

18 THE WITNESS:

We didn't discuss it that somebody 19 turned it off, no.

20 BY DR. MYERS:

21 Q.

You did not discuss it?

d o

Nd" 22 A.

It was discussed as we went along, and from the STEWART, POE & OGLESBY, INC. - REPORTING SERVICES

n 14 point of view of what the condition of the pumps were during 1

2 the day, we tried to figure cut what the flow was, and this 3

was not always together in a group.

I had been asked what 4

the flow rates on the pump were, what I thought they were 5

during the day, and the only numbers I could remember were 6

when I was -- the stagger flow in the loops, and a specific 7

number was given for 100 GPM on each pump.

8 Q.

Now, to the best of --

9 MR. VOIGT:

Just a minute.

When you say each pump, 10 what do you mean?

11 THE WITNESS:

Each high-pressure injector pump,

( ~

N 12 and that would have been when I moved over on to the primary l

13 system, sometime between seven and eight, in that time.

14 BY DR. MYERS:

15 Q.

Now, if the high-pressure injection pumps were 16 turned off, would it be known, do you believe --

17 A.

I don't think they were turned off, I think they 18 were throttled back.

19 Q.

Do you know who throttled them back?

20 A.

I can't actually say, I can say who I believe was 21 there, but I was not actually watching.

QU.I 22 Q.

Who was there?

i STEWART, POE & DGLE5BY, INC. - REPORTING SERVICES

15 1

A.

Who I believe was there?

s; '

2 Q.

Yes?

3 A.

I believe Ed was operating the high-pressure 4

injection pumps, controlling those at that time.

5 Q.

Is it the case that if they were throttled back 6

that he is the one that would have done that?

7 A.

That would be my impression, yes, I was not always 8

facing Ed.

9 Q.

This is at approximately 5:45 a.m.,

if they were 10 throttled.

This initiation, which you came to agree 11 probably occurred at 5:40 a.m.,

that the pumps were -- if

(-

12 that happened, the pumps were probably throttled back within 13 five minutes or so.

That is a fact, and that is the time --

14 A.

If I knew who did it?

15 Q.

No, that is the time we are talking about.

16 A.

I cannot say who actually was doing it, I can only 17 say who I believe was doing it, because I can't actually 18 remember someone putting their hands on the 16 valves; I can 19 say who I believe did it.

20 Q.

Well, what other people were around besides Mr.

21 Frederick that might have been close enough to do that?

.e-Ed:

22 A.

At that point?

STEWART, POE & OGLESBY, INC. - REPORTING SERVICES

16 1

Q.

Yes.

2 A.

I don't know who all was around.

I know Bill Zewe 3

was there, George Kunder, and Fred Schiemann was in that 4

area, and Ed Frederick was in that area, and Ken Brian --

5 well, I don't know if he was specifically in that area or 6

not.

There were some other people in the room at that time 7

too, and I believe they were people from the INC shop, but I 8

don't think -- I don't know what their positions in the room 9

were at that time.

10 Q.

Would a person other than a licensed operator be 11 allowed to touch those controls?

12 A.

I would say no.,

13 Q.

A person other than the licensed operator -- well, 14 could a person other than a licensed operator direct a 15 licensed operator to manipulate the controls?

16 A.

Depends on who the person is.

What the operator 17 would do is see if

.t was reasonable in his mind, a 18 suggestion made before he made a move on whatever he was 19 doing.

20 Q.

But say a person such as Mr. Kunder or Mr. -- well, 21 I don't know to what extent -- but suppose there were a

(..e 22 person, say Mr. X, who was a superintendent of Unit 1 but

f. -

l i

bTEWAMT, PUE 6 UULEbpY, ING. - MEFUMTINU bEMVICEb

. i t

Q9 o p.m.

...e,sq

,...._._9

17 1

did not have a license to operate Unit 1.

Could such a 2

person direct somebody to do something, and would that 3

operator be obligated to do it?

4 A.

Not if he felt it was not right, he could tell him 5

no, he would not do it.

6 Q.

So to the best -- so to your knowledge, then, you 7

have no direct knowledge of who might have done this?

8 A.

Throttle back?

I can't point out anybody that 9

would have throttled it back, no.

10 Q.

Do you think it was throttled back7 11 A.

What we believe at the time?

'(

l 12 Q.

No, what you believe now?

13 A.

Yes.

14 Q.

You believe it was throttled back at approximately 1

15 5:45 a.m.?

i 16 A.

I don't think -- I think it was a gradual thing if 17 it was throttled back.

1 18 Q.

But say between 5:45 a.m. and 6:00 a.m.,

it was l

19 throttled f rom nearly full flow to something relatively low 20 flow?

21 A.

You are setting the timeframe?

l kh 22 Q.

But say in that timeframe, between 5:40 a.m. and STEWART, POE & OGLESBY, INC. - REPORTING SERVICES

18 1

6:00 a.m.,

was it throttled from say something like one 2

thousand gallons per minute to something like 100 gallons a 3

minute?

4 A.

My opinion was that it was.

I don't know if it 5

was factually done from what you are saying about the data 6

and from what I know about it, I would assume it was 7

throttled back, but what time period, I can't answer that, 8

it would speak from what you are saying, the records that 9

you have, the records gathered.

10 Q.

But did you discuss that among yourselves in the 11 months following the accident, the extent to which it was 12 throttled back after this time when it was your 13 consensus --

14 A.

In our interviews?

15 0

No, just discuss it among yourselves when you were 16 talking about all of this?

17 A.

We never really got together by ourselves like 18 that, it was only one time we did it, and that did not 19 border on a high-pressure injection.

That was just -- we 20 were trying to, early in the accident, we tried to get 21 together and just, in our own minds, say what happened, what

!kh 22 was the sequence that happened, and we got lost on that.

5TEWART, POE & OULE55Y, ING. - REPURTING 5ERVICE5

19 1

Q.

But in doing that, it became your consensus that l'

2 full high-pressure injection had been initiated at 3

approximately 5:40 a.m.,

approximately coincident with 4

turning off the main reactor coolant pumps?

5 A.

In my opinion, yes.

6 Q.

And the group --

7 A.

I won't speak for the group.

8 Q.

But they seemed to have accepted that, because 9

they agreed, or at least Mr. Zewe did, because he put this 10 in the official sequence of events?

11 A.

I am still stating that that is because what I

(

12 said earlier.

13 Q.

But he seemed to -- is there any reason to think 14 he disagreed wit'h you?

15 A.

At the time he didn't, but it was not a specific l

16 question directed toward him to try to find who did 17 specifically what, it was -- he believed this happened at 18 this point.

19 Q.

Well, you know that Mr. 2 ewe at the trial in New 20 York, he was asked about his recollection of some of these 21 things, and Mr. Fisk said, "It clearly was your position in

.p:

w, 22 July of 1979 - " he says July -

"it was your position that STEWART, POE & OGLESBY, INC. - REPORTING SERVICES mn nm m m.

mn m m

.m_m.

m..__....

(.

20 1

the sequence of events should state HPI was manually

,..a, 2

2 initiated full at the time of the second set of pumps were 3

turned off at 5:40, right," and Mr. Zewe says, "Yes."

4 Then Mr. Fisk said, "That was Mr. Frederick's 5

position, and Mr. Fausts' position as well, right."

And he 6

said, "I recall we did, the three of us agreed to that, yes, 7

and now we are in July, and Mr. Zewe says yes.

8 Mr. Fisk said, "There came a time when manual 9

interjection of HPI at 5:40 was in fact inserted into the 10 draft sequence of events," and Mr. Zewe said, "As I recall 11 it was, yes."

'~

12 Then Mr. Fisk went on and said, "It is correct, is 13 it not, Mr. Zewe, that in July of '79, you and Mr. Faust and 14 Frederick were insisting high-pressure injection was put off 15 at 5:40 at the time the two reactor coolant pumps were 16 turned off?"

And Mr. Zewe said, "That is right"?

17 A.

Put off?

18 Q.

Turned off.

19 A.

Or had been turned off?

20 Q.

Let me read -- this is f rom the transcript.

21 A.

It is?

22 Q.

"It is correct, is it not, that in July '79 you STEWART, PUE & OGLESBY, INC. - REPORTING SERVICE 5 2126 Bancroft Place, N.W., Washing ton, D.C.

(202) 265-3827

rs

.v.~

n) 21 1

and Mr. Fau'st and Mr. Frederick were insisting high-pressure

( ?,,

2 injection had been put on at 5:40 at the time the two 3

reactor coolant pumps were turned off?"

4 Mr. Zewe said "That is 'co r rect. "

5 MR. VOIGT:

Are you asking him whether he knows 6

what Mr. Zewe said?

7 DR. MYERS:

I am telling him that was Mr. Zewe's 8

feelings, and he was telling Mr. Fisk that at the trial.

9 THE WITNESS:

I have no problem with what Bill is 10 saying with him.

I am saying I initiated the idea; that 11 initially nobody came up with it until I stated it.

(-

12 BY' DR. MEYER:

13 Q.

But Mr. Fisk said, "Your best recollection at that 14 time in May 1982" -- this is in a deposition now -

"three 15 years after the accident, was that high-pressure injection 16 was reinitiated at 5:40, isn't that correct?"

And Mr. Zewe 17

said, "I stated that there," and Fisk said, "That is the 18 truth," and Mr. Zewe said at the time, "Certainly."

19 So it is Mr. Zewe still believing that it was 20 initiated at 5:40.

I mean he is not saying I got all that 21 from Craig Faust, he is saying --

(..)

22 A.

That is fine with me.

STEWART, POE & OGLESBY, INC. - itEPORTING SERVICES

_2126 Bancroft Place, N.W.,

Washington, D.C.

(202) 265-3827

22 1

Q.

But then if it was initiated at 5:40, the question 2

is what were the circumstances leading to its being 3

throttled back?

4 A.

I could not answer that.

5 Q.

Do you have -- I mean you have never discussed 6

that with anyone?

I mean did they say --

7 A.

It has been asked of me, but I could not answer 8

the specific question you are asking me, I was not over 9

there, and I don't remember it being stated or somebody 10

saying, "I am throttling back."

11 Q.

But did you ever think to ask anyone what led to

(-

12 the throttling back of the high-pressure injection?

13 A.

No.

I didn't know there was a problem with it in 14 that sense.

I figured everybody had the information; I 15 thought the accident was known.

16 Q.

But do you believe if it had been left on at 17 approximately full flow, there would have been damage or no 18 damage to the fuel?

19 A.

I don't know, the pumps are designed to inject 20 high-pressure or inject water into the core.

21 Q.

So certainly enough capacity in those pumps to

.n k5f 22 keep the core, to cool the core?

5TEWART, FOE 6 OGLE 5BY, ING. - REPORTING SERVICES

i 23 1

A.

If it is believed it is getting into the core.

E; 2

Q.

But at that time was there no reason to think --

3 A.

That is later on.

4 Q.

This is before there was any fuel damage?

5 A.

We didn't know that at that time.

6 Q.

But there was no reason to believe there was fuel 7

damage?

8 A.

At that time, no, we didn't believe the core was 9

uncovered at that time.

10 Q.

But now in retrospect, do you think that if those 11 pumps had been left on at full flow, starting at

[

12 approximately 5:40, there would have been no damage to the 13 core or damage to the --

14 A.

I would say I am not qualified to answer it, but 15 in my own personal opinion, I imagine you could look back at 16 it and say it could.

17 Q.

That there would be --

18 A.

There would be no damage to the core as long as 19 the core was covered.

20 Q.

Are you saying that if full flow from 21 high-pressure injection had been left on at approximately --

(N.

22 beginning approximately 5:40 a.m.,

that in your opinion, the STEWART, POE & OGLESSY, INC. - REPORTING SERVICES e

..m

.. nm

.00m

24

~

1 core would not have been damaged?

2 A.

As a reactor operator, you are asking me that?

1 3

Q.

Yes.

4 A.

I am not sure I understand why you are asking that.

5 Q.

As a reactor operator, as a person who has a fair 6

amount of knowledge of what the pumps are supposed to do?

7 A.

I would have felt there would have been no cote 8

damage.

9 Q.

That is your opinion, I mean that may be wrong?

10 A.

The opinion at that time was that this system was 11 full of water.

12 Q.

Right, we understand that.

13 A.

And there would not have been any core damage from 14 that point.

15 Q.

But knowing what you know now, do you believe that 16 there would have been no damage to the core if high-pressure 17 injection had been at full flow beginning at approximately 18 5:40 a.m.?

19 A.

I don't know.

From the simple point of view, I 20 would say no, it would not have been, but I am not sure, 21 there would not have been any flow damage.

But that is

<7

..w 22 based assuming the flow is going to maintain the system fuel.

STEWART, POL & DGLE55Y, INC. - REPORTING SERVICES

__ cop..o

.s. - -..

25 1

Q.

Is there any reason for thinking the flow path s

2 would not be --

3 A.

This came later on.

4 Q.

But given that the core was intact, is there any 5

reason to believe the flow path would have been other than 6

of a nature that it would have been able to cool the core?

7 A.

This is from what I know now.

8 Q.

This is starting at 5:40 a.m.,

where the core as 9

far as we know was virtually intact, assuming for the 10 purpose of this question that it was intact, that none of 11 the fuel rods had failed?

(..

12 A.

As far as I know, it did not at that time.,

13 Q.

The data seems to indicate there was no damage to 14 the core at that point, but for purposes of this question, 15 assume there was no damage to the core at that point, would 16 full flow f rom high-pressure injection beginning at 17 approximately 5:40 a.m. have made it such that there was no 18 significant damage to the core?

19 A.

I still can't answer that.

20 Q.

What is your opinion as knowing what high-pressure 21 injection is supposed to do?

(,b 22 A.

What I know now about the accident, assuming that STEWART, POE & OGLES 8Y, INC. - REPOPTING SERVICES e

h u.

?

i 26 I

high-pressure injection pumps were on full at that time, we 2

had taken off the reactor coolant pumps, all right, the 3

system was already down in volume, which we did not realize 4

at the time.

Once we turned the pumps off*, I don't know if 5

the core would have flashed to the point that there would 6

have been damage to the core just from uncovering the core 7

from that point, because we were down to -- I should not say 8

that -- a third of the volume was left in the core, the 9

water.

10 Q.

But suppose -- let me say, suppose the time the 11 reactor coolant pumps were turned off, that the core was C-12 still covered?

13 A.

That is what I am saying.

14 Q.

No, sir, for purposes of this question, assume 15 that the water level in the core is above the level of the 16 fuel?

17 A.

All right.

18 Q.

If that were the case, and you turn off the main 19 reactor coolant pumps a'nd at the same time you turn on 20 high-pressure injection at full flow, and leave that on at 21 full flow, do you believe that there would have been core

(

22 damage?

STEWART, POE 6 DGLE55Y, ING. - REPORTING SERVICES

27 1

A.

Assuming the system volume was there, I would say 2

no.

3 Q.

Meaning assuming that the core, that the water 4

level was above the level of the core when you turned --

5 A.

And throughout the system.

See, what I am looking 6

at, the core became the hottest point, the pressurizer had 7

cooled itself down, and the core became the hottest point, 8

and I am saying once you turn off the reactor coolant pumps, 9

it would totally depend on what the volume of the system was, 10 because once you turn those off, you get separation, and 11 also you would get flashing in the core area to a point that 12 it might force the water out of the core region up into the 13 loops.

That is what I am going on.

If the system is full, 14 I would say no.

15 Q.

But suppose the system was such that there was two 16 feet of water above the core when you turn off the pumps?

17 A.

You would have to have an engineer to do that for 18 you.

19 Q.

Did you discuss this question later with your 20 associates as to whether or not, " Boy,, if the thing had been 21 left on at 5:40 a.m. at full flow, beginning at 5:40 a.m.,

(. )

22 whether core damage might not have occurred"?

STEWART, POE & OGLESBY, INC. - REPORTING SERVICES

28 1

A.

I don't believe so.

2 Q.

You don't recall any discussions as to whether or 3

not that might --

4 A.

Not individually, and I believe that is what you 5

are asking me.

6 Q.

You in groups, or individually or whatever?

7 A.

No, it was -- we were not asked if core damage 8

could have been prevented.

9 Q.

But did you ever sit down and talk about with 10 people or hear people talking about how the core damage 11 might have been avoided had the high-pressure injection been

(

12 left on at full flow at approximately 5:407 13 A.

Not in discussions that I know of.

14 Q.

You were never sitting around a table like this 15 where people were discussing this, I mean say in the months 16 f ollowing the accident, say prior to October '79?

17 A.

Not that I remember.

I am aiming this -- that we 18 specifically sat down and talking about it, "we" being Bill 19 2 ewe and myself, and Fred Schiemann.

20 Q.

But did you ever hear anybody else --

21 A.

I have heard comments from people that said m

SS:

22 high-pressure injection would have prevented it.

I have STEWART, POE 6 OGLE 5BY, INC. - REPORTING SERVICE 5

29 1

heard comments from myself that had reactor coolant pumps t

2 been left on it might have been prevented.

3 Q.

You felt that possibly that at 5:40 a.m.,

that it 4

might have prevented core damage if it was left on?

5 A.

The reactor coolant pumps?

6 Q.

No, the high-pressure injection pumps.

7 I mean, did you think to yourselves in the months 8

following the accident, that well, maybe if high-pressure 9

injection had been left on at full flow at that time, 10 beginning at that time, that maybe damage to the core might 11 have been avoided?

12 A.'

Yes, along those lines.

13 Q.

You thought that?

14 A.

To myself, I thought a lot of things that might 15 have prevented it.

16 Q.

But that particular thing, high-pressure injection, 17 having been initiated at 5:40, which you believe to have be 18 the case, at least in the summer of 1979?

19 A.

Why do you want me to say it as if it was the only 20 thing.

21 Q.

Well, it is my understanding that you did think (h'

22 that that had happened, and that Bill Zewe and Ed Frederick STEWART, POE & OGLESBY, INC. - REPORTING SERVICES e.,,

....._s,_

..._ f,, _ _ _,,nes,,,e.,ne,_

30 1

agreed with you, and that is why it was put in the sequence s.

2 of events?

3 A.

Yes.

4 Q.

Given that you did think this was the case, did 5

you then think ' hat, well, we might have ' avoided core damage 6

if the high-pressure injection had been left on at full flow?

7 A.

I can't honestly say I thought of that alone.

8 Q.

But as you thought back over this thing, this 9

accident, did you think, well, at various times if we had i

10 done different various things, maybe we would have avoided 11 damage, recognizing that the procedures followed -- in our i

\\

12 view you did more or less what your procedures told you to 13 do, but at this particular time, at 5:40 when you were 14 thinking more or less coincident with turning off of the 15 reactor coolant pumps, did you think that, well, maybe it 16 should have been left on at that time, or if it had been 17 left on there would have been no damage to the core?

18 A.

I can't say that.

I am referencing to the 19 accident.

20 Q.

But did people talk about that.

Did you ever talk 21 to anybody alone, with groups, or to hear people saying, you

(!%3 22 know, "If high-pressure injection had been left on at full STEWART, POE & OGLESBY, INC. - REPORTING SERVICES

_ og o, s...

c.

31 1

flow we might have avoided damage"?

i 2

A.

I know I have heard it.

I know I have talked 3

about different aspects of the accident with -- I could not 4

come close to the numbers, just people in the control rooms, s

5 things as they went on.

6 Q.

Did anybody have strong feelings to the effect 7

high-pressure injection was not initiated at full flow at 8

approximately 5:40 a.m.,

prior to October 1979?

9 A.

Specifically?

10 Q.

Yes, did someone try to argue with you saying this 11 did not happen, why are you putting this into the sequence

(.

12 of events?

13 A.

The only place I came up with this, was requested, 14 that was during the B&W litigation.

15 Q.

But that was later?

16 A.

Before that.

17 Q.

It was not in '797 18 A.

No.

19 Q.

But no one in the year 1979 disputed that fact?

20-A.

Because it was not thought of as far as I know.

21 There was nothing directed at it to direct attention.

t::,

0.2?

22 Q.

But it was something that Bill Zewe requested be STEWART, POE & OGLESBY, INC. - REPORTING SERVICES m

m

...n.

32 1

added to the sequence of events.

There are these notes i.

2 saying that --

3 A.

But I think I am the one who did that, I keep 4

saying.

5 Q.

But Zewe and Frederick seemed to agree with you?

6 A.

That is because they don't remember, more than 7

likely.

I would be willing to bet if you asked them 8

factually --

9 Q.

Well, I think maybe they don't remember -- I mean 10 at the time they didn't remember, are you saying they didn't 11 remember that?

12 A.

Until I brought it up in one of our interviews, I 13 said, "We did this then," and they started agreeing with me.

14 Q.

Would Kunder have known whether it was known or 15 not?

16 A.

I have no way of knowing.

17 Q.

He was there?

18 A.

Yes.

And you could ask him.

That would be my 19 best guess -- I am not supposed to guess.

20 Q.

If high-pressure injection were initiated at 21 approximately full flow at that time, would people other cb (9,i 22 than you and Ed Frederick have been aware of it?

5TEWART, FDL & UULL55Y, ING. - REPURTINU 55RVIGL5

33 1

A.

Anybody paying attention to us at that time I

(

2 would say would have been aware of it.

3 Q.

Is that something Ed Frederick would have done on 4

his own, I mean would he have consulted with you saying, "Okay, 5

we are turning of f the main pumps and turning on the 6

high-pressure injection.

Somebody here said there was a 7

countdown" -- you said that?

8 A.

I put that in there.

9 Q.

But Ed Frederick, and Bill Zewe and Schiemann did 10 not remember any countdown, is that what you are saying?

11 A.

Not until after I said it.

All I am trying to 12 point out is that I remember in one interview saying, "Didn't 13 we put high-pressure injection on it?

Didn't we have like a 14 countdown to it?"

I don't know why I remember that.

15 Q.

My reading of the record and going back over the 16 early interviews is that you were not the only one.

I mean, 17 there is no unambiguous statement in the record as far as I 18 have seen, but there are other people who also recall this, 19 and so you are not the only one.

20 A.

Okay.

Then based on that, it is already known.

21 Q.

That this happened?

,.p:.'

V,-

22 A.

Yes.

From the records that state that, and nobody STEWART, POE & OGLESBY, INC. - REPORTING SERVICES

34 I

disputes it.

\\

2 Q.

Well, no one in the early days disputed it, and 3

now -- but the question is, if this happened, did -- to the 4

best of your recollection, no one has -- or to the best of 5

your knowledge, no one has an idea of who it was that 6

throttled it?

7 A.

An idea?

8 Q.

Well, somebody must know who throttled it.

If it 9

happened, someone must have throttled it, and that person 10 may or may not now recall doing that?

11 A.

I am giving you what I was stating that it was 12 just from an assumption based on where I thought Ed was at 13 that time, or I believe he was at the time.

14 Q.

And at least at the time you remember the 15 countdown?

16 A.

Yes, I feel like there was a countdown just to get 17 everything going at the same time.

18 Q.

And did you ever discuss with Ed who -- I mean 19 then what happened, when you were talking about this, then 20 you and Ed and Bill 2 ewe never discussed about who throttled 21 it or why it was throttled, after 5:40 a.m.?

n',9 22 A.

At the time we started talking about it that would 5TEWAMT, PUL 6 UULLupT, ING. - MLrvMTANU 5LMVIGLb v v v u.__tv r t cv v c

35 I

have been the B&W litigation.

2 Q.

But Bill Zewe says that is how it got added to the 3

sequence of events, because he, and you and Ed were talking 4

about this, and you decided that is what happened?

5 A.

Yes.

6 Q.

In any of those discussions, did you ever decide 7

or talk about who it was that might have throttled this?

8 A.

No, I don't think we believed anybody -- I don't 9

believe we thought about throttling back the pumps, who 10 would have throttled it back, because I didn't even think 11 about it until later on.

12 Q.

You mean you never thought about the fact the 13 high-pressure injector had not been throttled back?

14 A.

I just didn't think about throttling back the 15 high-pressure injection pumps, the idea I didn't think about f

16 it.

17 Q.

But did you think after the accident whether or 18 not the high-pressure injection had been throttled back 19 after being initiated full at approximately 5:40 a.m.?

20 A.

I knew it was being throttled -- oh, brother!

i 21 I can't actually say I knew it was being throttled back at

.N!

147 22 that time.

i i

STEWART, POE & OGLE 8BY, INC. - REPORTING SERVICES w

n

~

n.

_n

36 1

Q.

But at some later time, at sometime since 5:40 2

a.m. on March 28, 1979, did you think about who it was that 3

might have throttled it back?

4 A.

Since the accident?

5 Q.

Since 5:40 a.m. on March 28, 1979, any time up to --

6 A.

At any time up to turning off the pumps, or the 7

whole day?

8 Q.

No.

Who throttled it back, say, prior to 6:00 9

a.m.

Have you thought --

10 A.

The first name that would have come to my mind 11 would have been Ed's, because I was under the impression

(

12 that Ed was at the pumps and doing the operations on the 13 pump.

But I can't factually say it was Ed.

14 Q.

But if Ed had done that, would Ed have done this 15 without having been directed to do it by someone?

16 A.

You would be better off asking him.

17 Q.

B u t --

18 A.

I know of situations where he would have done it 19 on his own; from then on I don't know.

20 Q.

Do you know why since it was your recollection 21 that the high-pressure injection had been initiated at h, '

22 approximately 5:40, do you know why it was decided to do UTEWART, PUE E UULE5eIs ANU.

MEFUMTANU BEMVAGE5 ann. n ne n.

ie n n

i' 37 j

I that at that time?

e (-

l '

2 A.

The best I can remember is just taking off the l

3 reactor coolant pun.ps, assuring that full flow of l

4 high-pressure injection at that time when we were going to l

l 5

try to go to natural circulation, it might be a good idea to 6

have high-pressure injection going into the loops.

7 Q.

So you are saying the purpose -- that you were 8

about to turn off the main reactor coolant pumps, you were l

l 9

wanting to go to natural circulation?

10 A.

That is right.

11 Q.

And that you thought in order -- that you thought c'

12 that an action that would help get you to natural l

13 circulation, help natural circulation --

l 14 A.

No.

Not necessarily help natural circulation, it 15 was just an added, why not put them on at this time -- let 16 me correct that, why not reinitiate it at this time, at full 17 flow, depending on when it was throttled.

18 Q.

So did you talk among yourselves, as you recall, 19 about whether you should do this?

20 A.

Just the way I recollect, just from the point of 21 we are going to try to go for natural circulation, some of

(![.I 22 the things we would do.

I was put in charge of feeding up STEWART, Pot & OGLCSBY, INC. - REPORTING SERVICES

3a the steam generators, one of the suggestions was to put --

1

~

2 this is totally from the way I feel it happened -- was to 3

reinitiate fully high-pressure injection -- and what was the 4

other thing?

5 Q.

Turn off the pumps.

P 6

A.

Yes, turn off the pumps.

7 Q.

And so did you, and Ed and Bill Zewe discuss this, 8

or --

9 A.

The group of us there, I just remember George, 10 Bill Zewe, myself, and Fre'd was in the corner, there were 11 other people.

i' 12 Q.

George, meaning George Kunder?

13 A.

Yes.

And I don't know who else was listening to 14 that conversation.

15 Q.

But this was the discussion among some of you at 16 least?

17 A.

I always wonder if this is a true discussion or 18 not, it was a direction we were going.

19 Q.

But people knew, at least those people knew what 20 was about to happen?

21 A.

Yes, that is my opinion.

r* 't.

vd 22 Q.

And then it happened, or at least you thought it e

STEWART, POE & OGLE 5LY, INC. - REf M Td2S w

,mm mm o. ___,_._ # n mnm

~ m a n.

N

.i,,P g,

[..

't 39

,/

1 j

1 happe:yeh 'in ~19797

~

2 A.

Yes.

o e

3 MR. IlOLLOWELL:

What was your task?

s 4

THE WITNESS:

My back would have been to most of y

'5 them because I was in charge of the steam generators.

They 7

C

'were holding -- they were sort of central in the room right 7

there, and if anything -- me looking to the side of the 8

thing, while I was still maintaining steam generators, which 9

I was still having prob 3 ems uith them, so I was not -- this g

8 b

^

\\

10 is why I am saying, I was not fully concentrating on what 11 was being said totally in the room..

A lot of this, I i-12 believe so.no of the actions that happened, maybe not all of 13 it, but what I thought happened because it seemed reasonable j

14 to happen that way.

15 BY DR. MYERS:

16 Q.

So there was this -- I mean at least you believed 17 in the summer of 1979 that there had been this decision to s

i 18 do this, namely turn'off the main pumps, turn off the high-19 pressure injection pumps at full flow and try to get natural 20 circulation?

21 A.

Yes.

hj

, 22 l Q.

Then the data indicates that high-pressure UTEWART, POE & OGLCSDY, IllC. - REPORTING SERVICES e

~e

...... a -....

.---. --- ~~~~

v i

40 I

injection was not left on at full flow for the next hour.

2 The' data indicates that.it was throttled and substantially 3

throttled following its initiation at full flow.

4 Now, would that have be the subject of some 5

discussion among people before it was throttled?

6 A.

At that time I was feeding the generators.

7 Q.

So you did not participate in any such discussion?

8 A.

Tnat is right.

9 Q.

Later on did you ever hear anybody say why it was 10 throttled or how it came to be throttled after this 11 initiation of full flow?

d

(

12 A.

I was asked those questions in interviews, and l.

13 also if I knew anything about them, and I usually tried to 14 be helpful and say things thet I didn't see.

15 Q.

What did you say in these other interviews?

16 A.

When they asked who might have been the one who 17 did that, I think I came out and said Ed Frederick at those 18 times, and you should ask him.

I felt he was the one over 19 there.

20 Q.

But Ed Frederick had done this, having just been 21 the person who turned it on, would he have turned it off

('.

22 unless directed to by someone else in your view?

A STEWART, POE & OGLESBY, INC. - REPORTING SERVICES

41 1

A.

I could not answer that.

It depends on what his l

2 mind -- what he thought was going on.

3 Q.

Did Ed Frederick tell you that he had been 4

directed to turn it off, the throttle?

5 A.

No, he did not say it that way.

6 Q.

What did he say?

7 A.

The three of us, or four of us had -- you are s

8 asking me this from the point of view prior to the reactor 9

coolant pumps, right, going off, being taken of f?

10 Q.

No, I am asking you if -- I mean, if you didn't 11 know anything about it, you would have assumed it was Ed i

12 Frederick who throttled the high-pressure injector after it 13 was turned on at approximately 5:40 a.m.?

14 A.

I sti]l believe he would have been the one.

15 Q.

He would have been the one to actually manipulate 16 the controls.

Did he ever tell you or indicate to you in 17 one way or another whether he had been directed to throttle 18 the high-pressure injection?

19 A.

No, not at that time.

20 Q.

No, but since 5:40 a.m. on March 28, 1979, has he i

21 ever said to you anything about the circumstances leading to

,:n E66 22 throttling of the high-pressure injection?

STEWART, POE & OGLESBY, INC. - REPORTING SERVICES

~

s 42 1

A.

Ed and I, believe it or not, have not discussed

/~;,

2 the accident when we are together.

3 Q.

Have you ever discussed that with anyone else 4

about the circumstances leading to the throttling of the 5

high-pressure injection after or approximately 5:40 a.m.?

6 A.

The best I can answer that is when I was asked 7

what I thought happened.

8 Q.

What do you think happened?

9 A.

I think that the high-pressure injection was 10 reinitiated and throttled at some point in time.

What point 11 in time, I don't know.

12 I didn't think there was a mystery as to it being 13 throttled.

14 Q.

Well --

15 A.

Or why it might have been throttled back.

I would 16 have based the pressurizing levels -- the indications itself, 17 because we still believed we had a full system.

18 Q.

Right, but it may not have been a great mystery as 19 to why it was throttled, but it seems to be a mystery as to 20 who throttled it or who directed that it be throttled?

21 A.

Not to me.

eq

'thi 22 Q.

You think since it was Ed Frederick who stood STEWART, POE & OGLESBY, INC. - REPORTING SERVICES

43 1

there, if it was throttled, that it was more likely that he 2

did it?

3 A.

That is my impression, yes.

4 Q.

But --

5 A.

I'have no factual -- I did not physically hear 6

anybody say throttle this back.

7 Q.

But since you were --

8 A.

Since he might have heard this, or somebody might 9

have told him to do this, or he might have done this on his 10 own.

That is all we know.

11 Q.

Do you know or do you have any reason to believe

('

12 that somebody told him to do that?

13 A.

I don't even have an answer for that.

14 MR. PARSHLEY:

Do you think it is the kind of --

i 15 THE WITNESS:

Sir, I don't know.

The supervisors i

16 in the corner might have said it.

I know the ones I believe 17 in the room, I don't know if they would have told them to do 18 it or not or he would have done it on his own, or if 19 Schiemann might have given him directions to back off, 20 because he was watching pressurizing levels, and that is a f

21 possibility.

h f' 22 BY DR. MYERS:

STEWART, POE & OGLESBY, INC. - REPORTING SERVICES I

.m og a o

00-w 09

___n-,.o....

--.-a-,

i 44 1

Q.

But the pressurizer was already full at that time?

4 2

A.

Yes.

3 Q.

And it was full at the time the high-pressure 4

injection was initiated?

5 A.

Yes, from the readouts I have seen.

6 MR. PARSHLEY:

Do you think it is the kind of 7

action that somebody could take and then not recall having 8

taken it?

9 THE WITNESS:

That day, yes.

I asked Ed about 10 something -- I told him something that he did that he didn't 11 remember definitely that day, and he just does not remember 12 doing it, and he actually walked around the pan while I was 13 over there and he didn't quite get them, the option, he was 14 going to shut the five valves -- or open the five valves, on 15 the borated water storage tanks, and he didn't remember 16 doing that.

17 It can happen, there are things that I don't 18 remember from the day of the accident.

It seems liks it 19 would have been me that done it, and my feeling is the 20 diesel generators themselves -- we defeated them, I know I 21 would have been the one who gave the order, because I was Z:

gj) 22 talking to Terry Doughterty, to take the diesels off, I STEWART, POE & DGLE55Y, INC. - REPORTING SERVICES o--o oooo.

e-o 0000 a 0-co.

ce.co-29 9 -

45 1

think you are aware you can't shut them down f rom up in the 2

control room, but I don't remember telling Terry to go down 3

there, because they came on a second time, and I didn't feel 4

we needed that with the problems we had in the past, I 5

figured we could put them on when we needed them.

But 6

apparently I told him to go down and leave them in that 7

position down there.

8 Now this is to me thinking logically what I wanted 9

to do is have him reset it, and I would go over in the 10 control room -- there is a switch there you can put it in an 11 exercise program, which defeats the ES start position, but 12 that is just an area that I can't remember talking to Lynn 13 Wright, who relieved me that day, except -- I can't even 14 remember most of the stuff I was telling him.

He said I was 15 back and forth between the high-pressure injection area and 16 the pan itself.

17 BY DR. MYERS:

18 Q.

But this countdown, that is something that you did 19 recall at least in the summer?

20 A.

I recall parts of things throughout the day, but 21 what I am having problems with is what I put in there as to c?.

ET 22 what I assume should have happened that way, because one of STEWART, POE & OGLESBY, INC. - REPORTING SERVICES 2

46 1

the very first things I did during the early part of the 2

accident which I feel I should have remembered right down to 3

the letter of what happened, was the actual sequence of 4

operations I performed on the emergency feed valves, the 11 5

valves, and I got that totally -- I got two stories 6

describing that, and they are different.

I don't know which 7

one is right now, or if either of them are right to tell you 8

the truth.

9 Q.

So in summarizing then, to the best of your 10 recollection, at least in the summer of -- the spring and 11 summer of 1979, the high-pressure injection was -- to the 12 best of your recollection, in the spring or summer of 1979, 13 that there was an initiation of the high-pressure injection 14 at approximately full flow at approximately 5:40 a.m.; is 15 that correct?

16 A.

I am agreeing from the point of view that, yes, I 17 believe we initiated high-pressure injection prior to 18 turning reactor coolant pumps off, or at the same time.

19 Q.

But you have no direct -- is it correct you have 20 no direct recollection or that you don't recollect the 21 circumstances that led to the throttling of this m.

(-$

22 high-pressure injection after it was initiated at full flow l

5TEWART, POE & OGLE 5BY, INC. - REPORTING SERVICE 5 i

m no-m w cs e o aa m e_

am woo

47 1

at approximately 5:40 a.m.?

~

2 A.

Not direct, no.

3 Q.

Do you have any indirect -- maybe if you could 4

summarize your understanding of what you think happened with 5

regard to throttling of the high-pressure injection after it 6

was initiated at 5:40?

7 A.

What my belief is?

8 Q.

Yes, sir, what your belief is?

9 A.

There is just my belief, and I have already stated 10 that, that I am pointing a finger at Ed right now, and I am 11 saying I believe he was the one who would have throttled it 12 back, and I would base that -- base the throttling back on 13 his belief the system was full at the pressurized level 14 Now, if somebody gave him directions -- I am 15 making an assumption, since Fred was watching the level 16 indicator, that he might have directed Ed to throttle back 17 on it.

18 Q.

We assume that if it was throttled back, it was 19 throttled back because people thought it should be throttled 20 back, not for purposes of causing damage.

That is our 21 assumption on all of this, that people were doing what they

/ ':.

'ep 22 thought should be done.

STEWART, POE & OGLESBY, INC. - REPORTING SERVICES

I l

48 1

A.

Yes.

)

f' 2

MR. PARSHLEY:

And your recollection is that you 3

had discussions with Zewe and Frederick about putting there 4

into the sequence, the fact that your best --

5 THE WITNESS:

What I am trying to state straighten 6

out is that I remember myself being the one who brought it 7

up, I even said didn't we have a countdown on it.

I think I 8

re enforced that believe with them.

9 Now if I would have done that at that time, 10 whether it would have been thought of, I don't know.

11 MR. PARSHLEY:

Do you think when you Were having

(-

\\

12 those kinds of talks, that Frederick believed that you 13 thought he was perhaps the only one that could have done 14 this?

15 THE WITNESS:

I get the feeling like I was 16 pointing a finger at him saying you did this, why did you do 17 it.

18 MR. PARSHLEY:

No, that is not it.

19 If the three of you were talking about what had 20 happened at that time, reconstructing the sequence of events, 21 was the discussion such that he would have -- I mean, were m

%d 22 you all in agreement he would have been the only one that i

l STEWART, POE E OGLESBY, INC. - REPORTING SERVICES a.-

m

_..p.

49 1

could have done that had it happened?

2 THE WITNESS:

No, not from that point of view, 3

there was not a general agreement that Fred did this.

I 4

could not tell how we felt in that direction.

All I am 5

saying is, is that at that time I tended to put it out as 6

being that point in time and they started agreeing with me.

7 MR. PARSHLEY:

Would you have expected him to say 8

no, I would have been the one who had done that and I didn't 9

do it?

10 THE WITNESS:

If he felt he didn't, for sure.

But 11 Ed once again was having a hard time remembering things that 12 occurred.

That is why we -- one of the things we started, 13 we started off with individual interviews, and we felt that --

14 or I felt especially, because I was getting a lot of things 15 out of sequence and saying things that I was not sure of, 16 that we would have been better to try to do them together so i

17 we can help each other out on where this stuff falls in.

18 That is why we started saying we are going to do it as a 19 group.

20 BY DR. MYERS:

21 Q.

This is related to this, in the first four hours (iY 22 following the reactor trip, the data indicates that make up STEWART, POE & OGLESBY, INC. - REPORTING SERVICES

50 1

pump 1-A was in operation rather than 1-B.

Is that pump --

.s,.

2 was that pump drawing from the make-up tank during that 3

period, or the borated water storage?

4 A.

During the initial point?

5 Q.

Initially it was throttled, but the data shows 6

pump 1-A was on at that time?

7 A.

Yes.

8 Q.

For make up purposes?

9 A.

Yes, we put it on.

10 Q.

But there was let down going on and make up going 11 on in that period, say the first two hours and twenty 12 minutes.

I mean that is what --

13 A.

The best thing I can say there, my fact on that is 14 that I shut off the letdown, I attempted to start the A pump.

15 I moved off to the secondary side; anything I said after 16 that was purely from what I believed happened took place and 17 what I heard in our interviews.

18 Q.

Okay, the data indicates that pump 1-A was the one 19 on during this period, that 1-B comes off at the time 20 high-pressure injection was activated around 4:00 a.m.,

and 21 then 1-A is in operation?

(,b 22 A.

Right.

bTEWART, POE & UGLE55X, INC. - REPORTING SERVICES

---o

.0 o

e - ----

51 1

Q.

Now, if 1-A and the sequence of events indicates 2

there was let down occurring during that period and there 3

was make up --

4 A.

There should have been 1-C on too.

5 Q.

1-C was off according to the data -- just let me 6

ask you this --

7 A.

There should have been a start on 1-C.

8 Q.

Well, it was started but it was turned off?

9 A.

That came as pressurized level.

10 Q.

But my question here has to do with whether 1-A in 11 this period was drawing from the water storage tank or the

(*

12 make-up tank?

13 A.

Both, the operator would have had to manually 14 isolate the make-up tank, and if that was not done, which I 15 don't know --

16 Q.

Because during this time if let down did occur, 17 the let down goes into the make-up tank, or does it go 18 somewhere else?

19 A.

I can tell you what you got to watch out for here.

20 Q.

I am just asking where can let down go to?

21 A.

It can go to the bleed tanks or make-up tanks, or 6<..

'qf 22 it can be shut off, period.

STEWART, POE & OGLESBY, INC. - REPORTING SERVICES

____.,m_...___

_...__s,__m.__

o.

,,e one, _ _ _

C 52 1

Q.

But if it were on during this period, is it known 2

if it were going to the make-up tanks or bleed tanks or shut l

3 off?

There is no good records as far as you know as to --

4 A.

I was not watching it, I didn't do the 5

manipulations there, it could have been either.

6 Q.

And the make up, and if pump 1-A was operating in 7

this period, it could have been drawing from either the 8

make-up tank or the borated water storage tank?

9 A.

That is what I was going to try to tell you 10 something else here.

11 The thing -- it went back to the feedback tank if C-12 there was a concern, you know.

In Ed's mind, he may have re 13 opened those valves, which would have been a source of value 14 from the BWST to the make up stand.

15 Now that is just one point of view on it, I don't 16 know if he also did operations in the 12 valves which takes 17 the suction off that.

There were a couple of combinations 18 that could have been done there that would have left --

19 Q.

You are just saying a lot of things could have 20 happened?

21 A.

Yes, I don't know.

,C4

%1?

22 Q.

And if they were just using control flow in and STEWART, POE h UULE55Y, INC. - REPORTING SERVICES

53 o

1 out of the reactors during this first two-hour-twenty-minute s

2 period, other than times when the high-pressure injection 3

might have been activated full, would it have been customary 4

to draw from one tank or the other?

5 A.

During this period, it would have been customary 6

to draw from the BWST.

7 Q.

During that whole period?

8 A.

Well, I feel like you would almost have to state 9

something here.

This was not a normal situation.

It 10 started drawing out, so I am not sure how to answer that.

11 Normally I would say on a regular reactor trip you are t'

12 going -- it is a short term, say, it would have been off the 13 BWST, and we would have had a tendency to want to stop 14 drawing from the BWST.

15 Q.

Why is that?

16 A.

Because of the sodium concentration, and we wanted 17 to shift the source back over to the make-up tank, and as 18 soon as possible, if that were capable of being done, and 19 the whole thing -- the whole theory is that it might have 20 been a consideration, and then it got thrown out as time 21 went on, I don't know.

A S, ?-

22 Initially we had a tendency to try to limit the STEWART, POE & OGLESBY, INC. - REPORTING SERVICES

54 amount of water being initiated from BWST if the situation 1

?i 2

was stabilized.

3 Q.

And that is because of the chemicals that are in 4

the BWST water, the make up water is basically pure water?

5 A.

It does not have sodium in it, it takes time to 6

get that cleaned out.

7 Q.

So, this is something that would have been in the 8

back of peoples minds to give off the BWST as soon as 9

possible and get to the make-up tank, I mean if there were 10 not other intervening considerations?

11 A.

It is a possible thought.

12 Q.

You are saying that there is a reason for doing 13 that, there may be a reason for not doing it, but --

14 A.

Once again it depends on the situation you are in.

15 Q.

Normally though, does manual initiation of 16 high-pressure injection automatically isolate the make-up 17 tanks?

18 Let me say why I am asking that.

It appears at 19 7:30 a.m.

the make-up tank level seemed to be going down at 20 that time.

Now that implied the make-up tank was not 21 isolated, is that just my wrong reading of the data?

-n

($.'

22 A.

It does not manually isolate the tank, no.

STEWART, PUE & UULE55Y, ING. - MEPUMTINU 5EMVIGEb mnmn m

om mn

- mm em o.

n m cocco non nono

55 1

Reinitiating it, it is a manual function, the operator has

/

2 to do it.

3 Q.

So if there was manual initiation of high-pressure 4

injection, that would not automatically isolate the --

5 A.

Neither would automatic, that would not isolate 6

suction from the make-up.

7 Q.

So nothing automatically isolates?

8 A.

No, it is a manual function.

9 Q.

Did you have a procedure for dealing with a 10 situation where the bubble had transferred either to the 11 pressure vessel or to the hot leg?

12 A.

I don't think so; I don't remember the procedure.

13 Q.

And did you have a procedure for going to -- or 14 did your procedure, written procedure for going to natural 15 circulation involve initiation of high-pressure injection?

16 A.

I don't believe it did.

17 Q.

Had you been aware of this event in 1977 where 18 steam or saturation conditions developed in the hot leg --

19 A.

I don't remember.

20 Q.

Since then you have heard of this?

21 A.

I have heard of it, but I don't remember now.

(S.

22 Q.

Were you aware on, say, March 28, 1979 that if STEWART, POE & OGLESBY, INC. - REPORTING SERVICES

1

~

56 1

steam or saturation conditions did exist in the candy' cane, 2

that you would not be able to remove or compress the steam 3

by -- it was more than -- in order to re-establish water in 4

the top of the candy cane, it would take more than jacking 5

up the pressure?

6 A.

I can't honestly say what I knew at that point, I 7

can tell you --

8 Q.

What do you think now?

9 A.

The main thing I would have talked about would 10 have been to increase the temperatures of the pressurizer, 11 make it the hottest point again in the system, as well as f

12 driving the high-pressure injection -- that is one of the 13 things you would do is try to pressurize the hottest source 14 again.

15 Q.

Okay.

Do you recall talking about going in to 16 vent a loop?

17 A.

I don't remember if it was during the accident or 18 after, but there was talk of venting the loops.

19 Q.

During the accident?

20 A.

Yes.

21 Q.

Well, that is in the record.

4-D$

22 A.

I just don't remember.

STEWART, POE & DGLE55Y, INC. - REPORTING SERVICES onao m_..

__om mo___

nn mn o n _ a n _ _3

.o a_

oaaac 200 omao

57 1

Q.

Some people were prepared to go into the reactor 2

building for venting the loops at approximately 6:30 a.m..

3 Were you aware of that on March 28th?

j l

4 A.

I knew there was talk of going to vent off the 5

loops, but what I am saying, I don't know if it was on the 6

day of the accident, no, or what time of the accident.

7 Q.

But did you know that people talked on the day of 8

the accident about going in to vent the loops?

9 A.

That is what I don't remember.

10 Q.

I mean, you don't remember hearing it yourselves 11 on the day of the accident?

12 A.

Yes.

13 Q.

But do you know now or do you believe now there 14 was talk on the day of the accident about going into the 15 reactor building for purposes of venting the loops?

16 A.

I vaguely remember hearing something along those 17 lines as being part of it, so I am sure along the line I 18 heard it.

19 Q.

And this thing you heard was that people were 20 talking on the day of the accident about going into the 21 reactor building for purposes of venting the loops?

iiG-

'cf 22 A.

I am not sure, I am really not sure.

I can't STEWART, POE & OGLESBY, INC. - REPORTING SERVICES

~

58 I

answer that just from memory right now, I can't place it.

I 2

have heard something about venting off the loops, but I 3

don't know if if it was at that time.

4 Q.

Well, when else was there steam in the loops other 5

than March 28th?

6 A.

There was gas in there.

7 Q.

But they were not in the loops, were they?

8 A.

I would imagine.

9 Q.

But I mean, after March 28th they weren't?

10 A.

Pardon me.

11 Q.

I mean after March 28th there was no -- was there 12 gas in the loops after March 28th?

13 A.

Yes, there would have been gas in the loops at 14 that time.

15 Q.

After the reactor coolant pumps started?

16 A.

Yes, at least the B loop.

17 Q.

Because of the B steam generator was blocked off?

18 A.

When they started the A pump it was run for awhile, 19 or I should say the longest.

20 Q.

When during the accident did you realize that the 21 bubble had transferred either to the pressure vessel or the

.rt.

V6 22 steam generator hot leg?

STEWART, POE & OGLESBY, INC. - REPORTING SERVICES

59 1

A.

We were talking about trying to press it up.

That 2

would have been somewhere I guess around ten o' clock, say, 3

we were trying to regain the pressurizer as the hottest 4

source.

5 Q.

And by pressing it up, you meant by heating up the 6

pressurizer and seeking to establish a bubble in the 7

pressurizer that you would hopefully collapse whatever steam 8

bubbles there were in the loops?

9 A.

In the leg.

10 Q.

Was there a procedure for doing this?

11 A.

I don't believe so.

12 Q.

Did you on March 28th, did you recognize the hot 13 leg temperatures in excess of 700 degrees were indicative of 14 a core being uncovered --

15 A.

I can't honestly say what I thought.

16 Q.

You mean now -- well, it is a long time ago, but 17 would you have known, did your training lead you to believe i

18 that the temperatures in excess of 700 degrees were 19 indicative of the core being uncovered?

20 A.

I can't remember thinking about my training -- you 21 are saying would my training lead me to believe --

, ?.>

(c r, 22 Q.

No, did your training tell you prior to March 28, l

STEWART, POE & OGLESBY, INC. - REPORTING SERVICES

60 1

1979 that if you saw temperatures in excess of 700 degrees 2

that that meant that the core was uncovered?

3 A.

I didn't remember feeling that way about it.

4 Q.

Pardon?

5 A.

I don't remember feeling that way about it.

6 Q.

But I mean, would your training have told you if 7

you saw 700 degrees that meant there is superheated steam in 8

the system?

9 A.

If I sat down and thought about it, I would have 10 figured out tha t --

11 Q.

You knew what superheated steam was prior to March 12 28th?

13 A.

Yes.

34 Q.

And superheated steam being in this case steam 15 that had been heated by virtue of coming in contact with hot 16 fuel rods or something else?

17 A.

Just that steam gets above its saturation point, 18 you no longer have moisturation content in it.

We have a 19 theory in steam generators.

20 Q.

That it is superheated steam in the steam 21 generators is normal operation?

=;.

%.,e 22 A.

Yes.

bTEWART, POL & QULE55Y, INC. - REPORTING SERVICES m.

.o....... __.....__....

us__m._.

_ = -

, e n e s _. ere

,ne,

~

61 1

Q.

But if you had been -- this may not have be your 2

job on March 28th, but if you -- this was part of peoples 3

training to tell them that, to give them some idea that --

4 well, if this temperature, the steam temperatures are in 5

excess of 700 degrees, that may mean the core was uncovered?

6 A.

No.

7 Q.

Training never said that?

8 A.

No.

The only reason was that I don't remember us 9

talking along the lines that we are going to see that this 10 condition exists.

11 Q.

But if you had seen -- you don't know now, but if 12 you had seen temperatures of 700 degrees in the hot legs, 13 what would you have thought of those, or you don't remember 14 what?

15 A.

I don't know any more.

For part of it I was not 16 in the right position for it.

Later on in the day I knew we 17 had put the pressurizer --

18 Q.

You said you knew that by --

19 A.

I mainly remember trying to -- we had concern for 20 getting or assuring all the heaters were on in the 21 pressurizer, because we had operators sent out to check for v?

22 that specific reason to regain the pressurizer as the hot a

STEWART, POE & OGLESBY, INC. - REPORTING SERVICES

62 1

point in the system.

2 Q.

And you were trying to do that prior to noon on 3

March 28th?

4 A.

The transcript should indicate that.

5 Q.

Do you have the April sixth interview I gave you?

6 A.

Yes, sir.

7 Q.

Let me review that.

8 A.

This was --

9 MR. VOIGT:

He has not asked you a question.

10 BY DR. MYERS:

11 Q.

That statement is, "we got flashing and went rigt t 12 out the tank probably into the building and we saw 27 psi 13 spike; building pressure came immediately back down."

And 14 then it goes on and says, " Building pumps picked up.

We 15 took them off.

My reason is that we didn't have a building 16 pressure any more, and there was sodium hydroxyzine.

Up to 17 that point that is where I got relieved."

l 18 Now, do you recall whether you believed on March 19 28th that this pressure spike indicated that there will be a 20 real spike in building pressure?

21 A.

I didn't know if it was a real one or not.

9-

'85 22 Q.

Well, what did you mean then when you said this to STEWART, POE & OGLESBY, INC. - REPORTING SERVICES

63 I

the interviewers?

2 A.

We were trying to figure out why we got it, if it 3

was actual or not; all I was saying was it might have been, 4

because I was trying to associate it with something we might 5

have done at that time.

It was definitely off the wall 6

because I was just trying to give -- sometimes you give an 7

irrational answer just to try to give a direction to look 8

for.

9 Q.

Then if you got to the next to the last paragraph 10 where it says they asked you about the reactor building.

11 This now is from an interview on April 6, 1979.

12 A.

This was me talking after I heard what everybody 13 else thought.

14 Q.

Well, you say --

15 A.

It was, the hydrogen explosion -- maybe I was 16 trying to make myself look good, I don't know.

17 Q.

You say it looked like shock waves. "It probably 18 had an explosion because that is what it looked like, shock 19 waves"?

20 A.

I don't know why I made that statement except that 21 it was influenced by what happened in the media, and I was

!. r 22 just trying to give a reason.

Who was I talking to here?

STEWART, POE & OGLESBY, INC. - REPORTING SERVICES

...e

1 64 1

Q.

The team.

2 I think that is a GPU team.

3 DR. MYERS:

Those are all the questions I have.

4 Do you have anything you would like to add?

5 EXAMINATION 6

BY MR. VOIGT:

7 Q.

I just want to clarify where you were on the 8

morning of March 28th.

9 Can you tell me approximately how many minutes 10 into the accident or at what hour you went to the secondary 11 side?

12 A.

That was within seconds.

It was in the first 13 minute that I was -- my dealings on the primary side left me 14 over on the secondary side.

I was only -- I did two 15 manipulations on the primary side, and then immediately went 16 over to the secondary side.

17 Up until the time it would have been after, there 18 would have been a period of time after we isolated, tried to 19 isolate the steam generator, maybe three hours, three to 20 four hours into it, because I was involved in that, before I 21 started moving back over to the primary side.

'$ ff 22 5TEWART, POE & DULEb5Y, ING.

REFURTING SERVICE 5 uwu.u_sym__suuc

65 1

EXAMINATION (Resumed) l 2

BY DR. MYERS:

3 Q.

I think you tried to isolate that earlier, prior 4

to turning off the pumps?

5 A.

I don't know.

6 Q.

I have one other question.

7 Did you believe or come to believe prior to 8

turning off the pumps that you had possibly transferred the 9

steam bubble either to the pressure vessel or to the loops?

10 A.

Prior to turning them off?

l 11 Q.

Yes.

12 kR. VOIGT:

Which pumps?

13 DR. MYERS:

The reactor coolant pumps.

14 THE WITNESS:

I don't know if I thought that or 15 not.

I might have thought of that, I might not have.

I 16 don't know any more, I know what I was possibly trying to 17 base that on.

18 BY DR. MEYER:

19 Q.

What do you think of the theory that during that l

l 20 first 100 minutes that there had come this idea to you and 21 Frederick and Zewe that this is possibly what had happened, 1

i II 22 and that is what you were really trying to do during that l

I STEWART, POE & OGLESBY, INC. - REPORTING SERVICES I

.y

~

66 7

1 period, namely transfer the bubble, get the bubble back into 2

the pressurizer?

3 A.

When did that come to me?

4 Q.

No, that that is a theory that was going on for 5

the first 100 minutes.

6 MR. VOIGT:

I don't understand your question.

7 BY DR. MYERS:

8 Q.

Well, some people tried to understand ihat was 4

9 going on here for 100 minutes, what were ttey thinking or f

10 what were they trying to do.

11 There is a theory now, because th9ee are those who 12 will say they should have recognized the full pressurizer 13 meant that the PORV was open, and water vad running out of 14 the system and they should have closed the block valve.

15 Another theory is thst. they $ame to believe not 16 that that -- or they didn't think that the PORV was open, 17 because if they thought that was openeld, they would have 18 closed the block valve.

But instead -- but what they really 19 thought is that somehow the bubble had been loss-from the 20 pressurizer and it had appeared either -in the pressure 21 valves or the hot legs, and the problem was to get the hf) 22 bubbles back into the pressurizer, and there were no STEWART, FQE E QULE55Y, INC. - MEPUMTING 5EMVICE5

7

.m.

j'-

s

.l 67

( :.-

y 1

procidures for tha't, that that is something no one had ever i

-d' 2

told the'm how to do, or I don't know if they know how to do 3

that now.

But that is a theory of going on -- one theory 4

was that everybody.was milling around this period.

Another

/

'5 theory was that there'wds a recognition or a belief at least s

6

,that the bubble had been lost in the pressurizer and 7

appeared in either the hot leg or pressure vessel and the 8

problem is how do we get back to where we should be.

9 Now, I am asking you how you respond to that n

c.

13 theory of what is going;on for the first 100 minutes.

j 11 MR. VOIGT:

How he responds to the theory based on 12' his present knowledge?

13 DR. MYERS:

I mean, I have never heard anyone say 14 if that is what in fact they did think during this time, and 15 they were trying to get the bubble back in the pressurizer.

6 l-l'

.,UE

~That is very convincing '.to some people at least, but I don't l

- 17 know what you think of that theory, or if you consider that

'18 an off-th'e-wall theory?

I 19 A.

I can tell you basically what I was doing.

20 BY DR. MYERS:

21 Q.

All.right.

l 3

0, 22 A.

I was 'trying to regain the steam generator for the s

STEWART, POE & OGLESBY, INC. - REPORTING SERVICES m

s t

,s,,

68 s

1 most part.

There was a milling around as you said.

2 Q.

Because --

3 A.

Some of that was going on to look at different n

4 data.

5 Q.

Some people would say there was milling around 6

going on, without any idea of what the problem was or what 7

needed to be done?

8 A.

There was another theory.

9 Q.

There was another theory there was some sense of 10 what had happened, namely that the bubble had been lost in 11 the pressurizer, it was necessary to get it back.

There was

(-

12 no written. procedure for doing this, and I am just asking 13 whetner you or your associates perceived that is what 14 happened, and now you are trying to figure out how to get l

15 the bubble back into the pressurizer.

16 MR. VOIGT:

You are asking him what he thought at j

17 that time?

18 DR. MYERS:

No, I am asking whether that theory is 19 a better description or describes better what was going on 20 rather than this wandering around the control room.

21 MR. VOIGT:

I still don't understand what you are 22 asking.

Are you asking him for what he thought or believed SfERKRT, POE & OGLESBY, INC. - REPORTING SERVICES

69 1

on March 28th.

2 DR. MYERS:

No, I am asking -- well, I will ask 3

directly.

4 BY DR. MYERS:

5 Q.

Did you and your colleagues on that morning, in 6

the first 100 minutes, believe that the problem was that the 7

bubble had been lost in the pressurizer and had appeared in 8

either the pressure vessels or the hot legs, and the problem 9

was to get it back into the pressurizer?

10 A.

I don't know.

11 BY MR. VOIGT:

12 Q.

Do you know someone named Richard D.

Parks?

13 A.

Yes.

14 Q.

Did there come a time recently where you received 15 a telephone call from Mr. Parks?

16 A.

Yes.

17 Q.

Can you tell us the time and date of that 18 telephone call?

19 A.

The time was about eight o' clock at night.

20 Q.

And the date?

21 A.

I think it was the 21st of this month, or last on 6) 22 month.

STEWART, POE & OGLESBY, INC. - REPORTING SERVICES

70 e

1 Q.

It is now last month.

2 Did Mr. ' Parks say anything to you about this 3

interview?

4 A.

He related -- he was talking about his problem on 5

the island in regard to -- he f elt he was being abused as 6

far as harassment as he called it, and he felt -- he was 7

trying to uncover information to the extent that testing he 8

thought should have been done on the polar frame that was

/

9 not being done for one reason or another --

10 Q.

But my question is, did he say anything to you 11 about this interview today?

12 A.

Well, he said they want to talk to me.

13 Q.

Who is "they"?

14 A.

Mr. Myers.

15 Q.

He indicated to you that Mr. Myers wanted to get 16 in touch with you?

17 A.

Yes.

18 MR. VOIGT:

I have nothing further.

19 DR. MYERS:

I was trying to get in touch with him.

20 (The reupon, at 11:40 a.m.,

the interview was 21 concluded).

@i$r 22 STEWART, POE & QULE55Y, ING. - REFORTING SERVICE 5

._,n,s e e c__ __, n e -, __

.a ar..

.e.

,..._..,...,__....s.4.,.

o v

71 4

1 CERTIFICATE OF REPORTER 2

I, William J. Allen, shorthand reporter, do hereby 3

certify that the testimony which appears in the foregoing 4

Pages 3 through 70 were taken by me stenographically and 5

thereaf ter reduced to typewriting under my supervision; that 6

said deposition is a true record of the proceedings; that I 7

am neither counsel for, related to, nor employed by any of 8

the parties to the action in which this deposition was taken 9

and further that I am not a relative or employee of any 10 attorney or counsel employed by the parties thereto, or 11.

finacially or otherwise interested in the outcome of the

(

12 action.

13 14 (2nn.,

e AL Court Reporter 15 16 17 18 19 20 21 FM vis 22 STEWART, POE & OGLESBY, INC. - REPORTING SERVICES

m 1

0 1

51605 COMMITTEE ON INTERIOR AND INSULAR AFFAIRS 1

3 Washington, D. C.

4 Monday, May 16, 1983 5

INTERVIEW OF:

6 GEORGE KUNDER, 7

a witness, called for examination, at the Longworth House 8

Office Building, Room 1322-A, Washington, D.C.

20515 9

beginning at approximately 2:00 o' clock, p.m.,

before 10 WILLIAM J.

ALLEN, a Notary Public in and for the District of 11 Columbia, when were present on behalf of the respective l

12 parties:

-a 13 14 APPEARANCES:

15 For the Committee Staff:

16 DR. HENRY MYERS, SCIENCE ADVISOR TOM WIMER, NUCLEAR SCIENCE ADVISOR 17 PAUL PARSHLEY, CONSULTANT COMMITTEE ON INTERIOR AND INSULAR AFFAIRS 18 1324 Longworth House Office Building Washington, D.C.

20515 19 For the witness, George Kunder:

20 LeBOEUF, LAMB, LEIBY & MacRAE 21 BY:

MARILYN TEBOR SHAW, ESQUIRE 1333 New Hampshire Avenue, Northwest r,

l 22 Washington, D.C.

20036 STEWART, POE & OGLESBY, INC. - REPORTING SERVICES

~

2126 Bancroft Place, N.W., Washington, D.C.

(202) 265-3827

m 4

2 s

1 APPEARANCES: (Continued) 2 For the witness, George Kunder:

3 KILLIAN & GEPHART 4

BY:

STEVEN D.

SNYDER, ESQUIRE 218 Pine Street 5

Box 886 Harrisburg, Pennsylvania 17108 6

7 8 9

INDEX 10 11 THE WITNESS:

EXAMINATION BY:

12 GEORGE KUNDER DR. MYERS 3

13 14 15 16 17 18 19 20 21 22 STEWART, POE & OGLESBY, INC. - REPORTING SERVICES 2126 Bancroft Place, N.W., Washington, D.C.

(202) 265-3827

e 3

i 1

PROCEED I NGS I

^ ~

2 Whereupon, 3

GEORGE KUNDER, 4

was called as a witness and was examined and testified as 5

follows:

6 DR. MYERS:

This interview is part of the 7

Commission's ongoing inquiry of the TMI accident and 8

clean-up.

Our primary concern is whether the NRC fulfilled 9

its responsibility in fully investigating the accident and 10 seeing the clean-up is carried out in accord with the 11 Commission's investigation.

Our purpose in inviting you is 12 to ask questions about ongoing events, and our inviting you 13 here is not to imply that you acted, during the accident, 14 inappropriately.

15 EXAMINATION BY COUNSEL FOR THE COMMITTEE STAFF 16 BY DR. MYERS:

17 Q.

Could you tell us what your position was at TMI on 18 March 28, 1979?

19 A.

Yes.

My position was Unit 2 Superintendent, 20 Technical Support.

21 Q.

Can you tell us what your primary responsibilities r-22 were?

STEWART, POE & OGLESBY, INC. - REPORTING SERVICES 2126 Bancroft Place, N.W.,

Washington, D.C.

(202) 265-3827

=

4 a

1 A..

Yes.-

My primary responsibility was to supervise

2 the Plant Engineering Group in Unit'2.

Collateral duties 3

involved also PORC Chairmanship.. That is the Plant 4

Operation Review Committee, Unit 2; and also responsible for:

5 coordinating the planning for refueling' outages.

6 Q..

What kinds of matters did the PORC review?

7 A.

In accordance with the technical specifications in -

8 existence at the time, the PORC was responsible to review 9

procedures, and procedure changes, design changes, events

-10 take that occur at the plant to determine reportability; and 11 investigate them with the aim toward recommending corrective 12 actions.

And in general, Overview Unit Operations and 13 advise the Superintendent on matters important to safety.

14 Q.

In the event there was a transient, such as the 15 one that occurred on April 23,

'78, would the PORC review 16 that and make recommendations as to how procedures might be 17 changed?

18 A.

I was not in Unit 2 at that time.

19 Q.

Recognizing that.

But is that the sort of thing 20 if a report had been prepared, is that the kind of thing 21 that PORC would review?

22 A.

In general, that is the kind of thing that PORC STEWART, POE & OGLESBY, INC. - REPORTING SERVICES 2126 Bancroft Place, N.W.,

Washington, D.C.

(202) 265-3827

._n-

4 5

I would review.

1-

~ -

2 Q.

And if there were any suggestion in that procedure, 3

.or any. inference from such'a report that procedures might be 4

chang ed, it would be wise to change procedures, the PORC i

5 would recommend changes be studied or changes be made?

6 A.

Well, in general.

Whenever there was a I

7 recognition of problems, they would be identified.for action, 8

and to the extent procedures were determined through that 9

investigation, or through the review, to be inadequate or in 10 need of any changes, that was something PORC would point out 11 and recommend.

4 12 Q.

Could you tell us what a punch list is?

i 13 A.

Not specifically.

The term is used in the context 14 of a list of items typically that needs to be either --

15 either turn-over items, in the context of start-up and test 7

16 activities.

It may be used for, as a listing of, you know, 17 problem areas, or something like that.

It could be used in 18 a number of activities without being more specific.

i 19 Q.

Let me tell you what our understanding is.

This 20 was a list of items which indicate the need for some kind of 4

21 changes or modifications with regard to various systems or i

[

22 equipment.

Some of those things possibly relating to safety, l

STEWART, POE & OGLESBY, INC. - REPORTING SERVICES 2126 Bancroft Place, N.W.,

Washington, D.C. (202) 265-3827

6 4

1 others perhaps not.

2 Is that more or less correct?

3 A.

If that is your understanding.

4 Q.

Was that any different from your understanding?

5 A.

Well, is your understanding in the context of --

6 Q.

Say as a pump --

7 A.

What was the program the thing was associated with?

8 Q.

There is a list of equipment, say, which might not 9

comply with the specifications in the contract, and that 10 somebody had to do something to bring that equipment up to 11 conformance with the terms of the contract.

12 A.

I am afraid it is still too general.

13 Do you have a copy of something?

14 Q.

No, I don't.

15 A.

Punch lists are referred to, as I indicated, 16 generally used in association with start-up, with other 17 activities or other programs that the term can be used.

And 18 without getting into specifics here --

19 Q.

The punch list I am talking about is something 20 that purportedly existed on the day the operating license 21 was issued, and that list indicated equipment that might 22 need some kind of modification or additional work.

STEWART, POE & OGLESBY, INC. - REPOPTING SERVICES 2126 Bancroft Place, N.W.,

Washington, D.C.

(202) 265-3827 a

o 7

1 A.

Then I guess I am not familiar with it, because I

~

2 was in Unit 1 at the time.

3 Q.

But would you assume there was a punch list?

4 Would it be typical there would be such a list at a plant 5

that is about to begin operation?

6 A.

I can only assume it is possible.

7 Q.

But you don't know that there was such a list at 8

TMI-2 on the day the OL was issued?

9 A.

Not for a fact; I am afraid not.

10 I would not doubt that something like that can 11 exist as part of the turn-over or start-up, but I don't have w_J 12 specific knowledge of that.

13 Q.

Well, do you have any knowledge of such a list 14 existing as of the day of the accident, such that this list 15 was modified between the day of issuance of the operating 16 license and March 28th, as revisions and changes were made?

17 A.

I am aware that there were lists of items that 18 needed to be addressed.

They were probably called punch 19 lists, but they would have a specific name to them, I would 20 expect.

And these would have been items that were, as you 21 indicated, items that involved industrial safety, things

[

22 that needed to be resolved but did not impede or was not l

STEWART, POE & OGLESBY, INC. - REPORTING SERVICES 2126 Bancroft Place, N.W.,

Washington, D.C.

(202) 265-3827

8 1

considered a major item that would impact safety or continue 2

the safety operation of the plant, something in that context 3

that that list existed.

4 Q.

Would the PORC have been the keeper of that list?

5 A.

No.

PORC would not, to the best of my knowledge.

6 Q.

But PORC would have access to those lists?

7 A.

Yes.

PORC would have access to them.

8 Q.

So would you know where to go if you had a 9

question about something?

10 A.

Well, I think there was the capability for the 11 PORC to, if it had any questions or needed to know 12 information, it had the authority and the capability of 13 getting that information in that sense.

PORC did have 14 access to that kind of information.

15 Q.

Do you have any idea of how many items were on 16 these lists as of the day of the accident?

17 A.

Well, without knowing the specific list, I would 18 be just guessing.

I don't know specifically how many items.

19 Q.

Well, could you tell us what those lists, what 20 might be the title of those lists, what you would ask for if 21 you were going to ask for such a list?

22 MR. PARSHLEY:

And who would you ask?

STEWART, POE & OGLESBY, INC. - REFORTING SERVICES 2126 Bancroft Place, N.W., Washington, D.C.

(202) 265-3827

9 1

MS. SHAW:

This all seems very general.

You are i

2 asking him for specific questions about generalized lists, 3

and I am a little confused.

4 DR. MYERS:

Well, these are lists that are 5

supposed to represent lists of equipment which needed some 6

kind of modification, which at that time of turn-over did 7

not comply to the contract specifications.

So that these 8

lists specified what deficiencies existed, and they may have 9

specified what additional work was required to bring that 10 equipment into line with the contracts.

11 MS. SHAW:

I just raised it before.

You were 12 looking for a specific name of a list.

13 THE WITNESS:

Like I said, I am aware of lists, 14 but not quite the same context as you indicated.

15 There are punch lists of outstanding turn-over 16 items, and those lists, to the best of my knowledge, my 17 engineering group is in receipt of.

But I recall a number 18 of different lists, but they are general left-over items 19 that were being worked of f by -- well, I am not exactly sure, 20 other than our group -- but at least the architect-engineer.

21 But I don't remember those lists as being deviations from

[

22 contreet specifications, per se.

STEWART, POE & OGLESBY, INC. - REPORTING SERVICES 2126 Bancroft Place, N.W.,

Washington, D.C.

(202) 265-3827

10 1

BY DR. MYERS:

2 Q.

It would say there is a list of outstanding turn-over 3

items?

Would that mean something if somebody were to ask 4

for such a list?

5 A.

Generally, yes.

That would mean something, but 6

without being more specific, it is difficult to say what 7

list you are referring to.

8 Q.

Would these items be listed on the computer?

9 A.

I don't recall them being listed on a computer, 10 although they may have been.

But some list may have been 11 computerized.

12 Q.

If there is a list of outstanding turn-over items, 13 where would such a list have been on, say, the day of the 14 accident?

15 A.

Well, I expect you could find some listings in 16 correspondence that I had in my department, some of which 17 was simply turned over from my predecessor, and wherever i

18 else those copies would have gone to, I would expect the GPU 19 office was a recipient; the test and start-up group that 20 remained on site, in their files.

21 These were the kind of things that would have 22 received relatively wide distribution, that which I am STEWART, POE & OGLESBY, INC. - REPORTING SERVICES 2126 Bancroft Place, N.W., Washington, D.C.

(202) 265-3827

11 1

thinkingaof.

r i

~ ~

2 Q.

But was there a master list then of outstanding Y

3 turn-over items?

4 A.

I don't know specifically whether there was or not.

5 It is likely -- it is the kind of thing that someone would 6

have been responsible for the list to issue them.

Maybe one 7

list was kept by one group and another listing was kept by 8

another group.

9 Q.

But with the Plant Superintend, would he have, or 10 the Plant Manager, would he maintain such a list, a master i

4

{

11 list?

12 A.

I don't really know whether he did or not.

i 13 Q.

So you are saying at the bottom, you don't know i

i 14 whether there was or was not a master list of outstanding-L 15 turn-ever items?

16 A.

Not specifically, no.

I don't know whether or not i

17 there was one.

18 Q.

Generally, do you know if there was one?

l 19 A.

I am not really generally even sure we are talking i

i 20 about the same things.

I j

21 Q.

But the list calling a list of outstanding turn-over 1

22 items --

i t

STEWART, POE & OGLESBY, INC. - REPORTING SERVICES 2126 Bancroft Place, N.W.,

Washington, D.C.

(202) 265-3827

12 1

A.

That was a general reference I made.

I still 2

don't know if that was the title or the name of the list, 3

but it was in connection with turn-over that I recall these 4

kinds of things.

5 Q.

And then in conjunction with turnover, there would 6

be some kind of list, saying, "Here are the things we need 7

to do, the paint in various rooms is not the right color, 8

some of the valves may not be up to par, we may want to fix 9

it at some future time.

We may want to have different kinds 10 of instrumentation in various places."

That is the kind of 11 thing I imagine would be on such a list.

12 A.

That is my general recollection, yes.

13 Q.

But was there a master list of such items?

14 A.

I would only expect there would be a master.

But 15 I don't specifically know for sure.

16 Q.

And do you know where the list, if there were such 17 a list, existed on the day of the accident, where one might 18 find that list now?

19 A.

Without looking at files, I can' t say for sure, 20 but it is the kind of thing, as I indicated before, that 21 received reasonably wide distribution.

And I would expect 22 that they would be found in files, departmental files, key STEWART, POE & OGLESBY, INC. - REPORTING SERVICES 2126 Bancrof t Place, N.W., Washington, D.C. (202) 265-3827

13 1

departments in Unit 2.

r

" ~

2 Q.

But if there-were a master list, then presumably 3

that would be in the Superintendent's office, the 4

Superintendent of Unit 27 5

A.

I could not say.-

6 Q.

But then you are saying if there were a master 7

list, it is not clear to you where such a list would have 8

been kept?

9 A.

That is correct.

And again, you say " master list,"

10 almost as if it is in the singular.

There may be a variety 11 of lists.

I don't recall any more.

12 Q.

But if there were a set of lists, do,you have any 13 idea where such lists would have been maintained?

14 A.

It is pretty much the same, you know, files, 15 similar files as I indicated before, where they might be 16 found.

17 Q.

Then are you saying the term " punch list" is not 18 sufficiently precise to convey a sense of what this list is 19 that we are talking about, as punch list of turn-over items?

20 A.

No.

I am simply saying, when you mention the term 21

" punch list," I recall lists that were associated with the l

22 turn-over process, and I can't say whether or not that is ST EWART, POE & OGLESBY, INC. - REPORTING SERVICES 2126 Bancrof t Place, N.W., Washington, D.C. (202) 265-3827

t 14 1

the same kind of thing that you are referring to or not 2

without seeing something more specific.

3 Q.

If there were such a list, what would a list of 4

valves that needed to be changed at some future date, even 5

though these valves did comply with the NRC requirement, 6

would there be a list of valves or a list of pumps?

Or 7

would valves and pumps be on the same list?

8 A.

I don't remember.

9 MS. SHAW:

You would not be involved in the 10 generation of such a list, would you?

11 THE WITNESS:

My department, when I came into Unit l.

12 2, was such that as an engineering group, they were the kind i

13 of people, among other groups in the organization, that 14 could generate questions or items that could uJtimately find 3

i 15 its way on the start-up type punch lists.

16 So to that extent, my group could have been i

17 involved in the generation of trings, usually through other 18 processes, questionnaires, memos, or what-not.

But I don' t l

19 recall ever maintaining the list.

20 BY DR. MYERS:

21 Q.

And " turn-over" means when the equipment is turned 22 over to the utility, if there is a contractor there working STEWART, POE & OGLESBY, INC. - REPORTING SERVICES 2126 Bancroft Place, N.W., Washington, D.C.

(202) 265-3827 a

15 1

on some system, or some piece of a system, the contractor at i

2 some point turns over that system or piece of system to GPU.

~~

3 Is that how that works?

4 A.

When you say " contractor," what specifically are 5

you talking about?

6 Q.

Well, suppose the catalytic is there doing 7

something.

Do they say, "We have welded these pipes 8

together, and we have done this in accordance with our 9

contract, and we are certifying this, okay."

10 Is that what turn-over means?

And GPU accepts 11 responsibilities for it?

12 A.

In a broad scale, yes.

That is the kind of thing 13 we are talking about.

The maintenance or the instructor 14 contractor constructs the equipment, then it is tested and 15 turned over with some formal process that exists.

16 Q.

And this process goes on for a number of years 17 prior to the issuance of the operating license?

18 A.

Yes, generally.

19 Q.

On March 28, 1979, did the alarm in the utility 20 computer print-out accurately represent the status of make-up 21 points A, B and C7 l

22 Let me say where this report comes from.

We have STEWART, POE & OGLESBY, INC. - REPORTING SERVICES 2126 Bancroft Place, N.W., Washington, D.C.

(202) 265-3827

16 1

seen a report, and we have this report which talks about the 2

status of the make-up pumps, and suggests that the computer 3

printouts did not accurately reflect the status of these 4

pumps.

But it is not clear from their report the extent to 5

which that was the case.

6 Are you familiar with this?

It is TD-ll8.

7 A.

I am afraid I am not familiar with it specifically.

8 I may have seen it.

9 0

Are you familiar with any suggestion after the 10 accident to the effect that, "Well, the alarm print out did 11 not exactly say what was going on," that is whether the 12 alarm printer was printing, like some of these print out did 13 not print reflect what was accurately going on with these 14 pumps?

15 A.

Well, my understanding from the various 16 investigations that have occurred was that the alarm printer 17 was behind in terms of printing out the intelligence that 18 was besieging the computer, so to speak, in the early hours 19 of the accident.

20 I can't verify through personal observations that 21 that was the case.

I don't have that understanding.

22 0

But say when the alarm printer was actually i

STEWART, POE & OGLESBY, INC. - REPORTING SERVICES 2126 Bancroft Place, N.W.,

Washington, D.C.

(202) 265-3827 i

17 1

printing out data, and it said, "Make-up Pump 1-A was normal

"~

2 or tripped."

Was that necessarily an indication that Pump 3

1-A was in that status?

4 I mean, are you aware of any discussions as to 5

whether or not that the computer printout accurately 6

reflected the status of those pumps?

7 A.

I don't remember any specific discussions.

I do 8

remember during the course of the post accident 9

investigation, that the question of the computer 10 backlogging; and also the question in general of the 11 computer out put rereflecting what really occurred with the L_-}

12 make-up pumps, was discussed.

I think that was the basis 13 for probably this kind of a report here.

14 But I just know that as being the concern of the 15 various investigative groups that were trying to understand 16 early what the scenario was.

But I don't recall any 17 specific conversations, or any specific ability on my part 18 to verify or add to the technical input of that.

19 Q.

Based on what you now know, can you say whether or 20 not the computer print-outs are an accurate reflection of 21 the status of these pumps?

l 22 A.

Based on what I heard in general, the computer STEWART, POE & OGLESBY, INC. - REPORTING SERVICES 2126 Bancroft Place, N.W.,

Washington, D.C.

(202) 265-3827

18 l'

printouts are not an accurate reflection of the status of 2

the pumps.

3 Q.

Then, in addition to that, which this has to do 4

with the question of how the pumps were connected to the 5

computer, whether the computer was accurately measuring 6

status or giving --

7 A.

I should add, that is not my finding.

I am 8

reading that from the various reports.

9 Q.

I understand that.

10 But I think that this is a report, this is the 11 only thing that I have seen that says that the pumps were 12 connected to the computer in a manner such that the computer 13 might not accurately show the status of the pumps.

I am not 14 sure I have seen it through now.

15 Other than that, other than whether or not the 16 computer was accurately indicating the status of the pumps, 17 the fact was that at some point, the computer got behind and 18 was not printing out, and then the data was dumped from 19 sometime after 5:00 a.m. to sometime after 6:00 a.m.,

or 20 whatever.

Anyhow, the data collected at 5:41 a.m. appears 21 to be dumped, or at least part of that data appears to be 22 dumped.

STEWART, POE & OGLESBY, INC. - REPORTING SERVICES 2126 Bancroft Place, N.W.,

Washington, D.C.

(202) 265-3827 t

19 1

Do you have any insight as to whether or not the r

- ~

2 computer data, indicating what happened at 5:41 a.m.,

since 3

there still seems to be some of that data around, whether 4

that data was an accurate indication of whether or not HPI 5

was initiated at that time?

6 A.

No, I don't.

7 Q.

Do you believe that make-up tank data in itself 8

provides an accurate indication of whether a significant 9

change in HPI flow occurred at some time?

Namely, if you 10 look at make-up tank level data, does that, in itself, 11 indicate a significant change in HPI flow?

12 A.

Are you saying if one ignored all other 13 indications in a plant and just looked at the level 14 indication for the make-up tank?

15 Q.

Right.

16 A.

No.

I don' t think by looking at that in itself 17 allows one to confer the status of HPI in itself.

18 Q.

So if the flow, if the injection flow suddenly 19 went from 70 gallons per minute to 800 gallons per minute, 20 and the only data you had was make-up tank level, would that 21 indicate, in your view, that that kind of change had l

22 happened, an injection flow?

STEWART, POE & OGLESBY, INC. - REPORTING SERVICES 2126 Bancroft Place, N.W., Washington, D.C.

(202) 265-3827

20 1

A.

I am not sure I understand the conditions that you 2

are posing to me.

3 Q.

Suppose you are doing normal make-up and let down, 4

and the flow might be 50 gallons per minute.

5 A.

Yes, sir.

6 Q.

And suddenly high-pressure injection is turned on 7

at nearly full flow.

And the only data you have is make-up 8

tank level data.

9 Can you infer from that data that there was this 10 change in flow from 50 gallons per minute to 1,000 gallons 11 per minute?

12 A.

I am not really sure I could.

Because one would 13 have to know, in order to confirm it, I would think one 14 would have to know some other parameters and the general 15 timeframe, and could not just completely ignore other 16 indications.

17 It may not mean he needs a lot of other 18 indications, but hypothetically, I really don't see how one 19 could conclude anything from just make-up tank level 20 information.

There is information that that can provide 21 that could be useful in conjunction with another event and 22 testimony, and other plant indications thro.gh other STEWART, POE & OGLESBY, INC. - REPORTING SERVICES 2126 Bancroft Place, N.W., Washington, D.C.

(202) 265-3827

i 21 L

1 indicators, for example.

But by itself, I don't think it is i

2 necessarily something that you can use to conclude the 3

status of HPI injection flow rate.

4 MR. PARSHLEY:

You would expect though, that if

)

5 the conditions that were just postulated in the last l

6 question existed, that there would be a significant change i

7 in the level of the make-up tank.

i 8

THE WITNESS:

It depends on the plant status with l

j 9

respect to the injection system.

The hypothetical situation i

10 you are talking about, you don't know whether or not your i

11 suction is from the tank to begin with.

I 12 If you start to research any situation, you need i

i 13 to know line-ups, you need to know expected line-ups, and i

1 l

14 other parameters that relate to the understanding of the j

15 entire big picture.

You may not necessarily have all the 1

l 16 data you would like to have, but I would expect you would i

I 17 need to know more than just what a recorder chart or a level i

18 indicator is telling you in order to assess other effects in 19 the plant.

20 BY DR. MYERS:

i 21 Q.

What you are saying is that you would really have 4

r-22 to know the position of various valves and whatever, in i

STEWART, POE & OGLESBY, INC. - REPORTING SERVICES i

2126 Bancrof t Place, N.W., Washington, D.C.

(202) 265-3827

22 1

order to know how various valves were lined up.

I think 2

that is what I heard you say.

3 A.

No.

I simply said that I don't think, based on my 4

engineering judgment, that knowing make-up tank level, by 5

itself, is enough information to conclude what is happening 6

with the injection status.

The reverse of that, you know, 7

in your question, asking about having to know positions.

8 Q.

But there is information, in addition to that tank 9

level, that you would need to know in order to determine 10 whether or not there had been a significant increase?

11 A.

Yes.

That is possible.

12 Q.

Is that possible?

I think I heard you say that 13 you needed to know information, in addition to tank level, 14 to determine whether or not there had been a significant 15 change in injection flow.

i 16 A.

No.

I said that make-up tank level is not always 17 sufficient information in order to determine the status of 18 HPI, that you may need other information.

You have turned 19 that around and said that means I will always need to know 20 other information.

21 That might not be true.

It depends on the 22 hypothetical scenario you are talking about.

STEWART, POE & OGLESBY, INC. - REPORTING SERVICES 2126 Bancroft Place, N.W.,

Washington, D.C.

(202) 265-3827

s.

_ _4 _

a

< ~,:

'23 s

1 Q.

Well, how do you know if the tank level is i

2 sufficient information then, to determine whether or not a

^~

3 significant change occurred?

~

4 A.

Well, one would have to look, I think, at the 5

plant's initial conditions that you ar,e postulating, and the 6

expected operation of the system.

It maybe important to 7

know the valve positions and line-ups and other,intormation.

8 But you would have to get the specific case.

9 Q.

But the specific case is postulating other 10 information, or the specific case is postulating fther 11 conditions?

I mean in effect, you are saying if the e 12 valves are in a certain state, then make-up tank level J.s a 13 sufficient indicator.

But in order to get 'there, you nave

~

14 to say, "Make certain assumptions about the status of 15 various valves"?

16 A.

I am afraid I am not clearly understanding your 17 question.

i 18 Q.

You said that make-up tank level'in itself may not 19 be sufficient information to allow you t.o infer whether 20 there was a significant change in high-pressure injection 4

21 flow.

s.

i l

22 Then you say, "It may," which implies at somotime t

STEWART, POE & OGLESBY, INC. - REFORTING SERVICES 2126 Bancrof t Place, N.W., Washing ton, D.C.

(202) 265-3827

7 7

I b '

y-

'.- p 3

I 1

it OL11 be, and other' rimes it won't be sufficient.

~

2 i

But in order to determine whether or not it is 3

sufficient 4 do y6u need to know the status of various valves?

v 4

A.

I expect there would be some conditions where that 5

information.is necessary.

6 Q.

If this data may be adequate, or it may not be

' adequate, what else do you need to know, to determine 7

g t

8 whether that information is adequate?

9 A.

Do you have a specific scenario?

10 Q.

W411, we can look at the make-up tank during the s,

11 accident.

e 12

-ICould you tell me from that whether or not there e-13 was a; sudden change in high-pressure injection, without 14 know ng the stetus of various valves?

15 A.

I don't~know whether I could or not, it would

16 depend on the timeframe you are talking about, and other 17 info,ry.stion that would be available to help substantiate the 1

i J

'18 status.

19 Q.

This is a new subject now.

20 On April 21, 1979, Craig Faust informed the NRC, 21 "The operators reinitiated the LPI just prior to stopping 22 the pumps."

STEWART,~POE & OGLESBY, INC. - REPORTING SERVICES 2126*Bancroft Place, N.W., Washington, D.C.

(202) 265-3827 A,

.A

25 1

You should know that where this line is drawn r-2 across here, that there is a half-page gap in the transcript.

" ~

3 But Craig Faust said that -- well, you can read p

4 what he said in the upper part.

(

5 MR. PARSHLEY:

Why don't you read it?

6 DR. MYERS:

"Something else I would like to just t

7 emphasize is that just prior to stopping those pumps, we did 8

reinitiate, we hit high-pressure injection just prior to 9

stopping the pumps.

I don't know if that was brought up 10 before, it should be though.

We got the decision, in other t

11 words, we made the decision and I am not sure how you can p

u-]

12 look at that" --

13 BY DR. MYERS:

14 Q.

Do you recall when you became aware of Mr. Faust

,I, 15 having said that to the NRC1 l-16 MS. SHAW:

Let me ask here, What was deleted?

17 You said a page and a half?

18 DR. MYERS:

This is how the exhibit was.

That is 19 just how they did it.

I have the full thing, but this is 20 how it came to'the trial.

)

21 MS. SHAW:

I see.

l 22 BY DR. MYERS:

REPORTING SERVICES ST EWART, POE & OGLESBY, INC.

2126 Bancroft Place, N.W.,

Washington, D.C.

(202) 265-3827

26 1

Q.

When did you become aware of Mr. Faust having said 2

this to the NRC?

Do you recall when you became aware of 3

that?

4 A.

I don' t recall ever being aware of it, to begin 5

with, specifically.

6 Q.

Then the next one is several pages down.

It says 7

"May 25, 1979, GPU Group Discussion."

8 Is it all right if we put this in the record so we 9

won't have to read it.

10 MS. SHAW:

May we go off the record, please.

11 (Discussion off the record),

12 DR. MYERS:

Back on the record.e.

13 BY DR. MYERS:

14 Q.

Have you seen this transcript prior to today?

15 A.

I don't remember having seen it, so I don't 16 remember whether or not I did.

17 Q.

When did you become aware that Mr. Zewe had 18 recalled initiation of high-pressure injection at about the 19 time the last reactor coolant pumps were turned off?

20 A.

Could you read that again?

21 Q.

When did you become aware Mr. Zewe had recalled 22 that full high-pressure injection had been initiated at STEWART, POE & OGLESBY, INC. - REPORTING SERVICES 2126 Bancroft Place, N.W.,

Washington, D.C. (202) 265-3827

_A

27 1

about the time the last reactor coolant pumps were turned

~~

2 off?

3 A.

I don't ever recall having that understanding at 4

all.

5 Q.

That Mr. Zewe had recalled this?

Not your 6

understanding, but when did you become aware Mr. Zewe had 7

that understanding?

8 A.

Again, I don' t recall having that understanding.

9 Q.

The next one is the ACRS meeting, where Mr. Zewe 10 said in response to a question of Mr. Moeller at the ACRS --

11 A.

By the way, on these, I have read a lot of various 12 transcripts now.

Is there anything -- when you give me 13 these things, excerpts, I find it rather hard to identify 14 anything.

15 Q.

Well, this one is from the Friday June 15, 1979 16 meeting of the ACRS, where Mr. Zewe is talking about the 17 accident.

And at one point he says, "At the same time that 18 we secured the last two reactor coolant pumps, which were 19 the A side pumps, we initiated full high-pressure injection 20 at the same time, which was approximately 5:40, if I 21 remember right."

Were you ever aware that Mr. Zewe had made a l

22 STEWART, POE & OGLESBY, INC. - REPORTING SERVICES 2126 Banctoft Place, N.W.,

Washington, D.C.

(202) 265-3827

28 1

statement like this to the ACRS?

2 A.

No.

I don't recall anything like that.

3 Q.

When did you first become aware that some 4

operators believed that safety injection had been initiated 5

at approximately maximum flow, at about 5:41 a.m. on the day 6

of the accident?

7 A.

I don't especially recall being aware that the 8

operators recalled the initiation of the HPI the way you 9

suggested.

10 But I do recall being aware of some confusion of 11 testimony presented during the course of the B&W trial.

I 12 became aware of that after the Parks' allegation was out.

13 But I don't recall anything else.

14 Q.

During the trial, for some reason, Mr. Fisk had 15 said that he believed that high-pressure injection had been 16 initiated manually about the time the last reactor coolant 17 pumps were turned off, and Mr. Fisk said this on 18 approximately November 1.

19 So that is where, I guess, I heard it, that this 20 was an issue.

21 But then they came forth with these various drafts 22 of the sequence of events, where I think a couple of pages --

STEWART, POE & OGLESBY, INC. - REPORTING SERVICES 2126 Bancroft Place, N.W.,

Washington, D.C.

(202) 265-3827

29 1

MR. PARSHLEY:

Who is "they"?

Y 2

DR. MYERS:

B&W; which were exhibits to the trial.

~ ~

3 BY DR. MYERS:

4 Q.

If you ge a couple of pages in, it says, 5

" Operators's manual fully initiated high pressure prior to 6

tripping pumps."

7 Do you recall seeing this prior to the B&W trial?

8 A.

Seeing this?

9 Q.

With this handwritten insertion?

10 A.

No.

I don't.

11 Q.

This purportedly was distributed to many people, L-12 including you, but it is not -- there is a cover memo from 13 Jerry Miller to various people saying -- that is the cover 14 page draft, and it says, "The attached, marked-up copy of 15 the annotated sequence of events, is the result of TMI-2 16 PORC meetings held on May 14, 16, 17, and July 9 and 13, 17 1979.

This memo is to formally transmit these comments to 18 the..."

something, and I can't make it out --

SOE 19 formulation group.

It appears that this has not occurred in 20 the recent revisions, and it is requested that the Data 21 Reduction Group, as a minimum, meet with the TMI-2 Group and l

22 discuss or resolve the commments.

Finally, I would like to STEWART, POE & OGLESBY, INC. - REPORTING SERVICES 2126 Bancroft Place, N.W., Washington, D.C.

(202) 265-3827

F 9

30 1

stress that the comments addressed on Page B of the May 21 2

submittal be received and appropriately considered when 3

preparing future versions of the Annotated Sequence of 4

Events."

5 Now, do you recall ever seeing this insertion here 6

where someone wrote in " Operator, manually"?

7 A.

No, I don' t.

8 Q.

The next item is the July 16, 1979 Sequence of 9

Events, Revision 1.

10 Then on Page 27, there it says at 5:41:37, "The 11 operator manually initiated high-pressure injection to 12 supply additional cooling water to the reactor cores.

13 Make-up Pump 1-C started.

Make-up Pumps 1-A and 1-C are 14 operating" 15 Then it says "Zewe, Faust and Frederick," and I 16 think it says, " insist this is the case" 17 Were you aware of this entry in the Sequence of 18 Events ever?

19 A.

No.

I don't recall that.

20 Q.

Is this something that you would have reviewed 21 prior to -- as it was being revised?

22 A.

I remember being in receipt of copies of the STEWART, POE & OGLESBY, INC. - REPORTING SERVICES 2126 Bancroft Place, N.W.,

Washington, D.C.

(202) 265-3827

9' 31 1

L equence of Events.

I think that is indicated here.

1 S

1

" ~

2 The work that I was doing in the post-accident 3

period, which was mainly supervising the recovery efforts in 4

the control room, was such that I did not always review 5

these in detail.

6 As a matter of fact, as you read from the one 7

transmittal memo, I remember it now, there was a group 8

f o rmed in order to try to pull together all of the data from r

9 transcripts, plant records, and logs, analysis from off-10 site agencies, and groups that were performing studies and 11 so forth, to try to correlate all that information into a 12 report that, in general, was perceived as the most accurate 13 reflection of the Sequence of Events.

14 So since I was not directly responsible for I

15 anauring that this task was done, I did not review each and 16 every one of these in great detail.

I would expect, back at 17 that period of time, I would have gone through it on some 18 occasion.

But it was not specifically germane to the 19 recovery of the plant at that point, and I did have a number 20 of people on my staff who were participating much more 21 heavily in the formulation of this.

And then, of course, it r--

22 was as transferred to this other group to coordinate.

STEWART, POE & OGLESBY, INC. - REPORTING SERVICES I

2126 Bancroft Place, N.W., Washington, D.C.

(202) 265-3827

I 32 1

Q.

Do you believe this entry at 5:41:37 is accurate?

2 A.

I have no personal basis to really indicate 3

whether it is accurate or inaccurate, since I didn't have a 4

direct role that I can recall in that.

5 Q.

Do you recall, or recall recalling whether HPI was 6

initiated at that time?

7 A.

No, I don' t.

8 Q.

Could that have happened without your having been 9

aware of it?

10 A.

I am not sure that it could.

It is speculation, I 11 think, to answer that for sure, anyway.

It is possible, but 12 I would not expect it to be likely.

13 Q.

Where were you when the reactor coolant Pumps 1-A 14 and 2-A were turned off?

15 A.

Are you making specific reference to the pumps?

16 Are you talking about the first --

17 Q.

No.

This is the second set that happened at 18 approximately 5:41 a.m.?

19 A.

At the time of securing the second set of reactor 20 coolant pumps, I recall being in the control room.

21 Q.

Who actually turned them off?

22 A.

I don't know for sure, precisely who.

To the best i

STEWART, POE & OGLESBY, INC. - REPORTING SERVICES 2126 Bancroft Place, N.W.,

Washington, D.C.

(202) 265-3827 i

p

~~

33 1

of my recollection it was likely one of the operators.

2 Q.

Do you remember which one?

3 A.

Not specifically, no.

4 Q.

Did you participate in the decision-making that 5

led to turning off the last of the pumps?

6 A.

In a sense, I did participate in the context of --

7 I was made aware that the pumps needed to be secure, because 8

the reactor-coolant system pressure-temperature conditions 9

were such that you would violate the MPSH requirements for 10 pump operation.

11 I recall looking at the curve; B&W, which is the 12 B&W limitations and precautions, to verify that we were at 13 that point on the operating curve, and to continue to 14 operate that way would violate the limits and precautions 15 for the safe operation of the pump.

16 I don't recall whether I verbally acknowledged 17 that was okay, or whether or not I concurred by not telling 18 them to keep the pumps running.

But in that sense, I had 19 some involvement.

20 Q.

Who at that time would be responsible for saying, 21 "Okay, secure them"?

22 A.

Well, in general, the licensed operators in Unit 2 I

STEWART, POE & OGLESBY, INC. - REPORTING SERVICES 2126 Bancroft Place, N.W.,

Washington, D.C.

(202) 265-3827

r-34 I

were responsible for following their procedures and 2

operating the equipment in accordance with what they 3

understood the procedures to be.

4 Q.

Do you recall whether Mr. Zewe was in the control 5

room when that happened?

6 A.

To the best of my recollection, he was 7

MR. SNYDER:

Off the record.

8 (Brief recess taken).

9 DR. MYERS:

Back on the record.

10 BY DR. MYERS:

11 Q.

If you had reviewed this Sequence of Events, would 12 you have agreed or disagreed with this entry at 5:41 a.m.?

13 So that we are all talking about the same one, the one on 14 July 16th, which is a couple of pages down the road.

It is 15 the one where Frederick, Zewe and Faust are mentioned.

16 A.

I don't really have any recollection or basis to 17 agree or disagree with this, because the information, at 18 least in this area and many others, was developed by others 19 from information that I am not personally aware of.

20 Q.

But you would say that if this thing did happen, 21 that to the best of your recollection, you were not aware of 22 it, and that you did not have anything to do with it?

STEWART, POE & OGLESBY, INC. - REPORTING SERVICES 2126 Bancroft Place, N.W.,

Washington, D.C.

(202) 265-3827 i

F,-

35 1

A.

Aware of what?

r--

2 Q.

If high-pressure injection was manually initiated

~~

3 to supply additional cooling water throughout the core at 4

about 5:41 a.m.,

that you, to the best of your recollection, 5

were not aware of it?

6 A.

Are you postulating that --

7 Q.

I am postulating that if this thing happened, 8

which it states here that you do not recall it happening --

9 A.

Well, whether or not it says that here, or whether 10 or not it was, I don't recall high-pressure injection being 11 initiated at that time.

12 Q.

Have you thought about this to the extent that you 13 have any ideas as to how this sentence got here, if it did 14 not happen?

15 A.

No.

Not specifically. I can only speculate that 16 it could have been, you know, a result of time factors or 17 just lack of memory or something like that.

I really 18 dona.'t have a basis to know one way or the other.

19 DR. MYERS:

That is all I have.

20 MS. SHAW:

I have no questions.

21 (Wh er eupo n, at 3:10 p.m.,

the taking of the l

22 deposition was concluded.)

STEWART, POE & OGLESBY, INC. - REPORTING SERVICES 2126 Bancroft Place, N.W., Washington, D.C.

(202) 265-3827

o 36 1

CERTIFICATE OF REPORTER 2

I, William J. Allen, shorthand reporter, do hereby 3

certify that the testimony which appears in the foregoing 4

Pages 3 through 35 were taken by me stenographically and 5

thereafter reduced to typewriting under my supervision; that 6

said deposition is a true record of the proceedings; that I 7

am neither counsel for, related to, nor employed by any of 8

the parties to the action in which this deposition was taken 9

and further that I am not a relative or employee of any 10 attorney or counsel employed by the parties thereto, or 11 finacially or otherwise interested in the outcome of the 12 action.

13 (k buA [

14 Court Reporter 15 16 17 18 19 20 21 22 STEWART, POE & OGLESBY, INC. - REPORTING SERVICES 2126 Bancroft Place, N.W.,

Washington, D.C.

(202) 265-3827