ML20072J088

Deposition of Mj Ross on 811118 in Harrisburg,Pa.Pp 202-280

ML20072J088
Person / Time
Site:	Crane
Issue date:	11/18/1981
From:	Ross M METROPOLITAN EDISON CO.
To:
References
TASK-*, TASK-GB NUDOCS 8306290917
Download: ML20072J088 (79)

Text

202 pk UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK

-x GENERAL PUBLIC UTILITIES CORPORATION, JERSEY CENTRAL POWER & LIGHT COMPANY, METROPOLITAN EDISON COMPANY and PENNSYLVANIA ELECTRIC COMPANY, a

Plaintiffs, 80 CIV. 1683 (R.O.)

-against-THE BABCOCK & WILCOX COMPANY and J.

RAY McDERMOTT & CO.,

INC.,

Defendants.

-x Continued deposition of Metropolitan O

Edison Company, by MICHAEL J.

ROSS, taken by Defendants, pursuant to adjournment, at the Host Inn, 4751 Lindle Avenue, Harrisburg, Pennsylvania, on Wednesday, November 18, 1981 at 9:10 o' clock in the forenoon, before Joseph R.

Danyo, a Shorthand Reporter, i

8306290917 811118 PDR ADOCK 05000289 T

PDR 1

f3 i Q DOYLE REPORTING, INC I

CERTIFIED STENOTYP E REPORTER 369 LExlNGToN AVsNUE WALTER SH APIRO, C.S.R.

New Yostsc. N.Y.

10017 CH ARLES SHAPIRO, C.S.R.

TELapwoNE 212 - 867 8220

203 g

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Q 2

Appe a rance s:

3 4

KAYE, SCHOLER, FIERMAN, HAYS & HANDLER, ESQS.

Attorneys for Plaintiffs 5

425 Park Avenue New York, New York 6

BY:

ANDREW MacDONALD, ESQ.,

7 of Counsel 8

9 DAVIS POLK & WARDWELL, ESQS.

10 Attorneys for Defendants One Chase Manhattan Plaza 11 New York, New York I

12 BY:

KAREN E.

WAGNER, ESQ.

-and-s 13 K.

ANN MCDONALD, ESQ.,

14 l

of Counsel i

15 16 Also Present:

17 SUSAN HANSON 1

18

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2 MI CHAE L J.

ROS S,

having s

3 been previously duly sworn, resumed and was 4

examined and testified further as follows:

l O

5 EXAMINATION (continued) 6 BY MS. WAGNER:

7 Q

Are you aware that you are still under I

8 oath?

9 A

Yes.

jl 10 Q

Y u and your counsel came in this morning i

11 with a large box containing approximately six looseleaf ;

s 12 binders.

Are those binders which belong to you?

('N) 13 A

Yes, they are.

l I

i 14 t

Q Can you tell me generally what the contents 1

15 o'f the binders are?

l i

l 16 A

Generally, they are training materials that l

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17 I had in my possession.

I 1

0 18 Q

Can you tell me if those training materials 19 are materials which you had before March 19797 l

20 '.

A To the best of my recollection, without I

21 going through every page, they are long before March of gg 22 1979.

23 MR. MacDONALD:

Basically, as we said 24 yesterday, they are primarily Unit 1 training

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1 Rocs 205 s,

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)

2 A

They are primarily Unit 1.

3 Q

Is there by any chance any Navy 4

training material in there?

5 A

No, there is not.

6 Q

Just one little question about something I 7

asked you about yesterday.

8 I asked you a couple of questions about what 9

you saw in the control room when you arrived on March 1

28, 1979.

One of the things I asked you about was 10 I

11 pressurizer level.

12 Do you recall when you first saw pressurizer

()'i 13 level on that day, when you first knew that the level

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l 14 was off-scale high, whether you knew that because you j

i 15 looked at the pressurizer level indication or that 16 somebody told you that?

17 A

I am not sure.

My recollection is that 18 someone told me it was off-scale high.

i t

19 Q

Were you familiar prior to March of 1979 j

l 20 with thermocouples, what thermocouples were?

lll 21 MR. MacDONALD:

In general?

i 22 MS. WAGNER:

Yes.

23 A

I was familiar with thermocouples in 1

7-24 general.

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25 l

Q What are thermocouples?

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1 Roso 206

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2 A

A device to sense temperature.

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3 Q

similar to a thermometer?

4 A

Similar, except they produce electrical 9

5 output.

6 l Q

were you familiar with in-core 7

thermocouples?

I 8 !

A when you say familiar --

9 Q

Had you ever heard of in-core thermocouples?

10 A

Yes, I had.

It wasn't something that we j

l l

11 used or used daily or even took readings on.

12 Q

Is it correct that you did use in-core j

[)T 13 thermocouples while you were in the Navy with some I

14 greater regularity?

15 A

on occasions, I used in-cores, but it was I

16 more of a mechanical type thing where you had to take 17 a readout with a box and wasn't something that was 18 displayed, and it was under only certain conditions i

19 that you would look at them.

l 1

s l

20 Q

Did you understand when you went to look i

21 at them what it was you were getting from them, what l

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I i

22 information was being transmitted to you?

i 23 A

I understood we were looking for core i

1 I

i i

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temperatures.

Basically, the only time we used them, Y

25 it wasn't during an accident or an on-line situation.

6 I

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1 ROBS 207 7

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It was special conditions when we would look at them.

i 1

3 Q

But you do understand if they told you 4

something, what they were telling you was the S

5 temperature inside the coolant wherever they were 6

located?

7 A

Yes.

You had to knew the location.

8 Q

During the time that you were at TMI, 9

either Unit 1 or Unit 2, were you familiar with an 10 operating procedure which called for the filling of the 11 reactor coolant system full and venting gases out of 12 various parts of it after a maintenance outage or during

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13 a cooldown?

i i

14 A

Yes.

15 Q

During the time when you were using such 16 a procedure, was the reactor coolant system full of i

17 water?

18 A

No, not necessarily.

It may or may not 4

19 have been.

20 Q

The procedure didn't require that you 21 fill it full?

ggg 22 A

The procedure required you to fi31 it, and that was the purpose of the procedure.

23 t

,r'5) 24 Q

Are you making a distinction between what

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the procedure said and what actually happeTed?

When I

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Roos 208

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2 you used such a procedure, was the reactor coolant 3

system filled with water or not filled with water, or 4

was it filled with something else?

5 A

It was normally filled to some level.

It 6

may not have been totally full.

It may not have been l

totally drained down.

Someplace in between.

7 l.

8 Q

Do you recall when you were using that 9

procedure and by "you,"

I mean when that procedure 10 was used by Met Ed -- whether or not you were required I

11 to keep the pressurizer level at or below certain l

12 levels?

'- ()

13 A

No, I don't.

14 l'

Q Had you ever heard of the concept prior to I

15 March 1979 of going solid?

16 A

Yes.

17 Q

What did that mean to you prior to March 18 1979?

19 A

It meant taking the system water solid l

l 20 without a surge volume available in the pressurizer.

l 21 It was something that we were taught at TMI to avoid gg l

i 22 in all cases.

23 Q

Why was it you were taught to avoid it?

A Basically, B&W had given us limits and 24 25 precautions that required us not to ever do that.

Our

i 1

Ross 209 O

procedures reflected that and our training on the 2

simulator and tech specs also reflected that.

3 4

Q Did you have any idea at any time why you 5

weren't supposed to do it?

6-MR. MacDONALD:

Aside from the limits and i

l precautions.

7

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8 Q

Aside from the procedures telling you not 9

to do it, did you have any idea why?

I 10 l A

B&W in one of the training courses they i

i 11 gave us one of the reasons was that they used centrifuga1' high pressure injection pumps and the plant really 12 i

13 didn't have installed equipment or designed to be 14 operated in the solid mode.

15 Q

Do you have any idea what would happen if l

16 it was in the solid mode?

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.A I felt with this particular equipment it I

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18 would be very hard to control pressure.

It was i

l 19 something we ought to avoid.

i 20 Q

Why would it be harder to control pressure l

21 in a solid system than it would if it were not a solid 22 system?

1 23 MR. MacDONALD:

You are talking about his t

i 24 understanding prior.to the accident?

J 25 MS. WAGNER:

Yes.

1

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1 Roca 210

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2 A

During solid system operation, you don't have a surge tank available to you, so any change 3

4 reflects a change in pressure, whether it would be 5

temperature or addition-or reduction of water.

6 Q

I take it even when you do have a surge 7

tank, a change in any parameter will cause some kind of f

I j

a change?

Isn't that correct?

If you have a surge 8 l i

9 tank, and your temperature goes up, something happens, I

10 whether or not you have a surge chamber, is that not l'

11 correct?

l l

1 12 MR. MacDONALD:

Something happens to what?

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13 Q

There is a change in parameters in the I

i i

system.

I am trying to understand.

I would think 14 f

^ 15 no matter what the system is doing,.if the temperature i

16 goes up, something occurs.

So why is it different if 17 you have a solid system from when you don't have a 18 solid system?

19 l

A When you have a solid water tends l

l to expand or contract.

When a system is solid, it 20 i

l 21 tends to expand and will caus,c a pressure increase since' G

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it had no space to expand into the pressurizer or into

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22 -l 23 the surge tank.

24 Q

Was it your belief prior to March 1979 that j

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if the system were_ filled sclid during power operations, b

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that it would break the system?

2 MR. MacDONALD:

What do you mean by break?

3 4

MS. WAG'NE R :

Cause the pipes to fall apart.

s MR. MacDONALD:

Cause a rupture in scke 5

6 primary system piping?

7 MS. WAGNEM:

Yes.

l s

8 A

My understandi'ng was that ih could cause a 9

failure because the design of the high-pressure-10 injection pumps was greater than the design of the j

l 11 system itself.

I l

12 Q.

Just so I understand, are you saying if

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'l 13 high pressure injection was on and the system was i

i 14 solid, there was no method for relieving the increased I

15 pressure at all which would. keep up wi$h the HPI, so you.

16 could have some kind of ruptu.re of the piping?

Is

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• het what you were saying?

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IF A

No.

I think you haie tied my recollection:

8 l

'I 31 why I should stay out of colid to high pressure a

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injection.

20 t

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21 Q

Could you repeat then ag in.what it was Ni ggg 22 you were saying?

I didn't understand.

r 23 A

My understanding of why you didn't want to

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I 24 operate solid was because of the concept that the 25 high-pressure injection pumps' JfsciYasge pressure and

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design pressure was greater than the design pressure

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.3 of the system itself, the reactor coolant system, so it 4

was an undesirable situation to get into.

5 Q

Why?

What does the design of the HFI

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6 pumps -- what happens to them in a solid system?

7 A

Their output pressure, so in a solid t

8 system theoretically you can go to the output 9

pressure of the high-pressure injection pumps which 10 exceeds the design pressure of the reactor coolant 11 system by six or seven hundred pounds.

12 Q

Which means what?

j l

13 A

Which means it is very bad.

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14 Q

You break the HPI pumps?

j 15 A

It means you could overstress the reactor 16 coolant. system.

l 17 Q

Is there no method of relieving the reactor '

18 coolant system other than a bubble if it is in the 19 pressurizer?

I 20 A

No.

The reactor coolant has relief valves, 21 but the relief valves aren't there to get you out of ggg i

22 a situation you got into that you weren't designed to 23 operate at.

Solid operation was not part of the l

34 design of the B&W plants.

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x 25 Q

Did you believe prior to March 1979 that a

1 l

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Roco 213 1

2 the relief valves would not provide sufficient relief hN d

pr tection in such a situation?

3 A

I am really not sure what I believe.

I 4

believe they would open, but I also believe it was very 5

6 undesirable to put water through them.

I just felt it I

i 7

was a bad way of controlling the plant if the design l

l 1

8 point of the relief valves was reached since the i

l relief valves were designed to protect the plant from 9

10 overpressure.

I could never see us getting into that l

l 11 situation.

12 Q

Did you have any understanding just as a l

13 design r.atter whether or not the relief valves, if they

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14 had to be used for some reason, whether it was good l

15 or not or would not provide sufficient relief in such 16 a situation to prevent overpressurizing the system?

17 A

I guess my knowledge prior to 1979 was 18 that it was designed basically to prevent the plant 19 from going solid from a transient, not from a j

20 high-pressure injection pump transient,'a transient 21 being a trip of some kind, an increase of pressure.

I ggg 22 think I would associate code safeties with high pressure 23 injection.

Q You did not have any kind of understanding 3

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prior to the accident as to whether the safeties or i

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1 Ro30 214

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relief valves would provide enough protection even

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with HPI on to prevent overpressurization?

3 4

A No, I never tied the safeties to the 5

high pressure injection pumps itself.

6 Q

Was it your understanding prior to March 7

1979 that the bubble in the top of the pressurizer was 8

intended to prevent the kind of overpressure situation 9

that you just talked about?

I 10 A

Yes.

I think the bubble, my recollection ofi 11 what the bubble was there to do was give you a sur.:e i

12 volume, and a bubble to give you an indication of i

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('S 13 volume so you didn't take the system solid and have

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14 l

the opportunity to take it above its design pressure j

1 1

15 through some malfunction or misoperation.

16 Q

I believe you testified yesterday that you I

17 were aware that it had happened on occasion that a i

18 bubble had formed somewhere other than in the 19 pressurizer in the hottest point in the system, I i

l believe you said, wherever that would be.

20 l

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21 Did you have any understanding that if a 22 bubble did form somewhere else in the system other 23 than the top of the pressurizer, that that bubble would i

24 provide protection against overpressurization as well?

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MR. MacDONALD:

I object.

I am not sure I

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1 Roco 215

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2 that is exactly what his testimony was from 3

yesterday.

I am not sure he testified to that 4

prior to the accident.

5 But regardless of what it was, if you 1

6 just want to use that to bring him back and ask 7

a question based on that, you may.

8 MS. WAGNER:

Whatever I characterized your 9

testimony, whatever you said is certainly what 10 you said.

11 BY MS. WAGNER:

I 12 Q

Do you know what I am asking yot now?

()

13 MR. MacDONALD:

Could you restate the 14 question?

i 15 Q

Did yo'u have any opinion. prior to March 16

'79, if you had a bubble somewhere other than in the 17 pressurizer,that that bubble would provide 18 overpressure protection in the same way that the bubble 19 in the pressurizer would?

20 MR. MacDONALD:

You are asking if, based on I

gg 21 his training, whether he had an understanding?

l 22 MS. WAGNER:

Based on whatever training he I

i 23 had, whether he had any understanding.

24 l

MR. MacDONAlD:

I object to that.

I don't 25 think he testified prior to the' accident he knew I

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1 Roco 216 (mj 2

that the bubble existed in that primary system.

3 My objection just was I don't think he 4

testified prior to the accident that he was 5

aware that there was such a bubble transfer.

I 6

think he testified that it was after that he 7

learned about that.

Your question assumes 8

MS. WAGNER:

Whatever he testified, I am 9

wondering if he can answer the question.

10 MR. MacDONALD:

My objection still stands, l

11 that there is no foundation for that.

l 12 Go ahead.

i

(_)/

I 13 BY MS. WAGNER:

I i

l i

14 Q

Did you have any opinion prior to March l

l 15 1979 that if a bubble formed in some place in the 16 reactor coolant system other than in the top of the i

17 pressurizer, that that bubble would provide the same 18 overpressure protection that the bubble in the j

19 pressurizer provides ?

20 MR. MacDONALD:

I object to his opinion.

6 21 MS. WAGNER:

Understanding.

j ggg 22 A

Based on my trainin:

I really had no I

23 understanding of what a bubble would do someplace else l

24 as far as pressure control.

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25 Q

Were you ever given any training on how to i

i i

i

1 ROD 3 217 fm

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)

2 maintain pressure if for some reason the pressurizer v

3 was not providing pressure control?

4 A

Prior to 1979?

5 Q

Yes.

Prior to March 1979.

6 A

I had received training in solid plant 7

operation as it related to a Navy plant.

j l

I I

8 j

Q What was that training?

9 A

The modes of control, basically of pressure,,

I i

10 keeping in mind that the systems are a lot different t

i i

11 and the components are designed to do that.

l 12 Q

Can you give me some idea what it was you (m)

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13 were trying to do in the Navy?

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14 A

Basically, we would take an alternate i

15 source and float a bottle pressurized source, another l

l 16 surge chamber, on the system.

We would be able to 17 control pressure in a solid mode by the fact that we i

18 had a system of positive displacement pumps which we 19 could regulate the output on and control the pressure 20 increase and regulate the amount of volume removed, so 21 we could set up a stable pressure _ control.

Basically ggg 22 the plant was designed to do that.

g I

23 Q

But you did not have any understanding e

i 7-24 prior to March 1979 how to provide pressure control in Q,)

25 a solid commercial system and not a Navy system if you i

I

1 Ross 218 A(,)>

lost the pressure control provided by the pressurizer?

2 A

Here again, B&W system, my training steered 3

4 me away from that, told me at all costs to avoid that.

5 I had training at other systems that said it was all 6

right to go solid, but those systems were in fact 7

designed and had different control modes than we had l

8 and different pumping arrangements than we had.

9 Q

This is systems other than the Navy?

10 A

Yes.

i l

l l

I 11 Q

Which systems were those?

lo A

Saxton Nuclear.

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(,)

13 Q

What were you taught to do at Saxton?

1 14 l

A Pretty much the same thing as the Navy.

i 15 At Saxton, part of our procedures and our equipment l

16 design was such that during the start-up we would go 17 solid, but here again the plant was specifically 1

18 designed and procedures specifically tailored to do that..

I 19 Q

Had you ever heard of any situation at i

20 i

Three Mile Island or any other B&W nuclear plant prior g

21 to March 1979 in which the pressurizer emptied during 22 normal operation, emptied at a time it wasn't supposed 23 l.

to be emptied?

i l

A Yes.

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24 l

v i

25 i

Q What had you heard about that?

l l

l,

1 Ro0S 219 A

I read event reports that said it happened

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and s me f the places it happened and what action they 3

4 took to restore it.

Be.sically, that it did happen and what they did after to restore it.

5 6

Q Do you recall what they did after to j

7 restore it?

I l

8 A

The major item was a vent of the control 9

rod drive systems.

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10 Q

What did that do for them?

l 11 A

Vent any nitrogen or gas that was trapped 12 in the pressurizer out of the control rod drive systems

(~N 13 themselves, so if you would insert the control rods, you L

14 wouldn't do damage to them.

15 Q

But if the plant was up and running and i

16 the pressurizer emptied for some reason, th at was the i

I 17 first thing they did, was vent the control rod drive l

18 systems?

19 MR. MacDONALD:

His recollection of what he !

20 l

learned?

l 21 MS. WAGNER:

That's right.

lll 22 A

My recollection of what I learned from that i

23 was they took care of whatever their problem was, i

34 restored it to normal, and then vented the control rod

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f drives.

25

1 Ross 220

((,)

2 Q

Prior to March 1979, had you been to any l

3 l training in how to achieve natural circulation in a 4

nuclear power plant?

5 l

A We were trained in how to achieve natural l

6 circulation.

I don't recall us practicing that at the 7

B&W simulator where we actually watched it be t

l

!l established and watched the parameters for any length t

l l

8 l

9.

of time, that being the practical section.

It was 10 !

more of a thing we talked about but didn't stress.

l l

11 Q

And you got no training on that except at I

12 the B&W simulator, is that what you are saying?

m()

13 A

We had a natural circulation procedure on 14 the plant, and of course we trained on all procedures.

15 We had some training.

My point was, the training l

16 wasn't stressed as it is today.

17 Q

Did you understand prior to March of 1979 18 that there was any kind of envelope of pressure and 19 temperature which you had to be in in order to achieve 20 natural circulation?

llg 21 A

I don't recall a curve that said this is l

22 a natural circulation curve or anything like that.

23 Q

So I can make my question perhaps a little i

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24 clearer, did you believe at any time you were not able N-]

25 to use the reactor coolant pumps, for some reason I

1 Ross 221

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2 natural circulation would just occur, or did you 1

believe at that time that there were certain system j

3 4

parameters th at had to be met before natural l

5 circulation could occur?

6 A

My recollection prior to the accident was, 7

the major parameters that you had to meet was raising 8

steam generator levels, and with that being raised, 9

you would achieve natural circulation.

l 10 Q

You didn't have an understanding that i

l 11 there were any primary system parameters that had to be 12 met?

(m an understanding, l l

N/

13 A

When you say I didn't have 14 l

I don't recall that being stressed.

15 Q

Do you recall it being mentioned at all 16 or did you have no understanding of it at all?

17 A

I am sure some primary parameters were i

18 mentioned in our training.

l i

19 Q

You don't recall at the moment what they i

20 were?

l ll) 21 A

No, I do not.

l t

22 Q

I believe you testified yesterday that you l

23 had heard at some point of an event which occurred at i

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24 TMI-2 in March 1978 in which the PORV had remained

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25 open at a time when it should have been shut, is that l

i

1 Rogo 222

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2 correct?

MR. MacDONALD:

Is that correct, what he 3

4 said yesterday?

5 Q

Is it correct that you have heard of that?

6 MR. MacDONALD:

Prior to the accident?

MS. W A G N E R':

Prior to the accident.

7 t

8 A

I believe that is correct.

9 Q

When did you first hear of that event?

10 i A

I am not sure.

I Q

Do you recall how you first heard about it? i 11 l

12 i A

No.

(' )

13 Q

Did you hear about it because you were in x,/

l 14 the control room at the time or did somebody tell you l

15 about it, to the best of your recollection?

16 A

To the best of my recollection, I was not 17 in Unit 2 control room because my duty station in 1978 18 was Unit 1.

My only knowledge would be I heard it i

1 19 someplace.

20 Q

Did you ever see any written report on

)

21 that event?

22 A

I can't recall.

23 Q

Were you aware that Metropolitan Edison g3 34 had filed a licensee event report on that event?

N.]

25 A

I don't recall specific knowledge.

i A

I

1 Ross 223 (g) 2 Q

You don't recall giving any training on that LER?

3 4

A Not specifically.

G S

Q Generally?

6 A

No.

7 Q

What did you hear about the event?

8 A

My recollection is that whatever the I

9 initiating event was, they had a trip that caused the 10 pressurizer level to go off-scale low.

It was a 11 severe transient.

l 12 Q

You did not know what the initiating event fx' ~')

13 was?

i 14 l A

something to do with the feedwater system.

l 15 Q

Did you have any understanding, did you 16 have any knowledge of what had happened to the PORV l

l 17 during that event?

j i

18 A

No.

l 19 Q

I just want to make sure we are talking i

l f

about the correct event.

20 21 You testified yesterday, I believe, that lll 22 you had heard of an event in which for electrical I

23 reasons the PORV had remained open when it should have (A)

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24 been shut.

That is the event I am talking about now.

l I

Is that the event you are talking about now?

25 I

rod 0 224 1

(~'N C!

2 A

No.

3 Q

Which event were you talking about so we 4

can clarify your testimony?

O A

I know there was some transient that 5

6 caused a pressurizer level to go off scale.

I am not 7

sure I relate that to the PORV transient at this time.

8 You are saying what my recollection is of an incident.

l l

I recollect an incident.

That is my recollection of it.

9 Q

Now you are talking about the one with 10 i the PORV remaining open?

11 12 A

Yes.

l l'

)

13 Q

Were you in the control room for that

[d 14 event?

i l

15 A

No.

i 16 Q

So again just to clarify your testimony, 17 do you believe you heard about that event because 18 somebody told you about it?

A The PORV incident?

{

19 l l

l Q

Yes.

20

[

A Yes, I believe someone told me about it.

g) 21 22 Q

Do yvu recall ever reading any report 23 including an LER on that event?

24 A

No, I don't recall.

)

/f_h j

(,/

~

25 l

Q Were you aware that Met Ed had filed an LER l

i I

i I

l 0

1 Roco 225

[ml on that event?

2

\\_/

A No.

3 4

Q You don't recall giving training on that 5

event either?

6 A

No, I do not.

7 Q

But I take it you do recall knowing that j

l 8

for one reason or another, the PORV had remained open 9

at a time when it should have been shut?

10 A

Yes, and I am not sure exactly how I got 11 that information.

I i

12 Q

Do you remember whether or not prior to f) 13 March 1979 you ever considered the failed-open PORV, j

x/

14 for whatever reason, at a time when it should have been 15 shut,to constitute a loss of coolant accident?

16 A

No, I think I just work off my recollection i

l l

17 before the accident.

I would have classified it as i

18 a loss of coolant accident.

l 1

19 Q

We had some testimony yesterday about the i

20 l

pressurizer failure procedure.

I believe you testified l

21 that one of the symptoms of a failed-open PORV is the ggg 99 actuation of HPI, automatic actuation of HPI at 1600 1

l l

i 23 pounds.

i l

,_s 3

Do you recall that that is in fact one of

!i s

/

l

\\

the symptoms of a failed-open PORV in the procedure 25 l

l

1 Roca 226 m

(

)

2 which is B&W Exhibit 304?

%)

A Under the procedure I have in front of me, 3

4 it is not listed as a symptom.

5 Q

Just for the record, does that have a 6

Babcock & Wilcox exhibit number on it?

It is Exhibit 7

305.

Is it listed as an automatic action?

l 8

l l

A Yes.

9 Q

Did you have any understanding prior to 10 !

March of 1979 why that was an automatic action for a l.

gl 11 i failed-open PORV?

I l

l A

Yes, a failed-open PORV would cause a 12 I

f~^l 13 reduction in plant pressure and possibly actuate the

\\_/

14 h high pressure injection system.

b I

15 Q

Do you recall with respect to the March 29, I

i 16 1978 incident,the PORV failed-cpen incident, whether l

l 17 you had any information given to you as to what l

18 happened to pressurizer level during the incident?

19 A

I am confused on the two incidents now.

1 26 The incident I remember is a pressurizer level off-scale 21 low-ggg 22 Q

The incident which you are talking about, i

i 23 was that a cooldown incident which occurred perhaps i

24 in April 1978?

,_s

\\

25 A

I am confused now on the two incidents, i

I

1 Ross 227

(/

i 2

because it has been so long and I haven't been s_

inv lved in the two for quite a period of time.

3 4

Q Did you have any understanding with respect 5

to the incident where the pressurizer level was 6

off-scale low as to whether the pressurizer had in 7

fact emptied?

8 A

No.

I recollect some study being done on 9

it to find out whether or not it had.

I don't recall 10 any details.

11 Q

Do you recall having seen a copy of that 12 study?

p m,

!s_)

13 A

No, I don't believe I ever did see a copy l!

14 i' or recall seeing one.

N i

li Q

Did anyone ever tell you with respect to 15 16 that incident that steam bubbles had been formed in 17 the hot legs of the reactor coolant system?

18 A

No.

19 Q

Do you recall anyone ever telling you that j

20 a bubble had been formed in the upper head of the i

l 21 reactor vessel?

f 22 A

No, not that I ever recall.

l i

23 Q

Do you recall any instruction at or about I

(~N, 24 that time as a result of that incident that all prior

()

l 25 transients were to be reviewed with your operating i

i

1 Roco 228

(~

staff?

)

2

\\~ /

A No.

3 4

Q I believe you testified yesterday, and h

5 correct me if I am wrong, that there was an incident 6

which caused Met Ed to install in the TMI-2 control 7

room an indicating light for the PORV.

t 8

To the best of your recollection now, is l

9 that the transient which resulted in the failed-open l

I I

10 PORV or is it the other one we are talking about?

l l

11 A

To my recollection, when you say " failed 12 open," opening of the PORV.

('N 13 Q

Staying open when it shouldn't have been.

l

(-

l 14 I show you B&W 79, which is a report, 15 one of several reports concerning the April 23, 1978 16 transient, and I will ask you if you have seen it 17 before.

18 A

I believe I have seen it, but I don't have

(

19 any specific recollection of what is inside of it.

l l

20 Q

Do you recall anyone telling you after j

\\

I 21 that incident that the reactor coolant system primary O

i 22 pressure had reached saturation conditions outside f

l I

l 23 of the pressurizer?

j l

l

[

24 A

No, I do not.

(~)

\\

t f

s' 25 i

Q We spoke yesterday I believe also of an I

l l

I I

1 Roso 229

('~h

' 2 event which occurred in September 1977 during which (m) 3 the steam bubbles had been formed in the hot legs of 4

the reactor coolant system of TMI-2, and I believe you 5

testified that you were not familiar with that, is 6

that correct, that you were not familiar with that 7

event?

8 A

That's correct.

9 l

Q Were you at all involved with TMI-2 10 l during the time when it was undergoing hot functional 11 testing?

12 A

It is hard for me to fix the time period.

13 I left there early

'78.

It was around January.

I l

())

\\_

14 believe I may have had the very beginning of it, but i

15 I am not sure.

16 Q

What is the hot functional testing?

17 A

Basically, it is taking the plant to a hot 18 pressurized condition and doing some test functions i

19 to prove that it performs as it is supposed to.

l 20 Q

Is fuel in the reactor at that point?

21 A

In a lot of plants it is not.

I don't j

gg 22 recall in Unit 2 whether it was or not.

l 23 Q

If there is no fuel in the reactor, how is i

24 the system heated up?

i

/~';

25 A

Heated up by use of reactor coolant pumps.

l I

1 Ross 230

[>

2 Q

How is it cooled down?

\\-

A Cooled down by dumping the steam to the 3

4 condenser.

5 Q

And I take it you turn off the reactor 6

coolant pumps?

7 A

You could.

8 Q

You don't have to?

9 A

Right.

i l

10 Q

You do not recall hearing, I take it, of 11 an incident during hot functional testing during which 12 for several days there was a steam bubble in each of

(\\_/

13 the hot legs of TMI-2 which resulted in a very high l

14 j

pressurizer level?

l-A I do not.

I 15 1G Q

Do you recall hearing of an event in 17 December 1978 again occurring at TMI-2 in which the I

18 pressurizer was believed to have emptied and in which I

t 19 it was believed that saturation had formed in the upper 20 l

head of the reactor vessel?

21 A

My recollection is I know of an event j

lg) 22 where the pressurizer was emptied.

I don't recall ever i

23 j having saturation formed anyplace else.

[')

24 Q

And the event about which you are talking x.s 25 is the one we already discussed this morning?

I S

I

Roos 231 1

[/

(

2 A

I am not totally sure, but I know of an event where the pressurizer was 3

4 Q

You are not familiar at this time of 5

knowing of two events in which the pressurizer emptied l

6 prior to the accident?

7 A

No.

They kind of run together for me as 8

one.

9 Q

Were you aware prior to the accident of an I

incident during the start-up of TMI-2 in which damage 10 j I

11 was caused to a makeup pump as a result of faulty 12 alignment of valves?

l

[~)h

\\_

13 A

No.

i 14 Q

Did you learn of such an incident after 15 the accident?

I

{

16 A

Not that I recall.

i 17 Q

Are you aware of any incident, again at l

l 18 TMI-2, in which damage was caused to reactor coolant i

19 pump seals during a test of the reactor coolant pumps?

i 20 A

Not that I recall.

I 21 Q

Do you recall hearing prior to the accident ggg 22 of an event which occurred at the reactor at Rancho 23 Seco,which belongs to the Sacramento Municipal Utility

(]

24 District, in which all indications were lost because

^

\\_,/

l 25 somebody dropped a light bulb in the console and the f

I

1 Roco 232 f

()

PORV opened and depressurization occurred?

2 A

I recall the incident on the light bulb.

3 4

I don't recall the Rancho Seco.

5 Q

Do you recall how you learned about that l

6 incident?

7 A

No, I do not.

8 Q

Do you recall what you learned about it?

A Basically, it was initiated by a loss of 9

10 a light bulb or by a light bulb problem.

11 Q

Do you recall hearing about the failure 12 open of the PORV?

And I mean by the fact that it was I

I) 13 open when it should have been shut, for whatever 14 reason?

15 A

No.

16 Q

Do you recall anything else about that 17 incident?

18 A

I recall the incident.

That is all.

t l

19 Q

Do you recall whether or not any training l

5 l

20 i

was administered on that incident?

A My recollection is some training was done l

ggg 21 l

22

.on that incident.

That is I believe why I recall it.

23 Q

Do you recall that you gave training or that you received training on the incident?

24 25 A

I am not sure.

t

1 Roco 233 I)

Q D

you recall whether or not you saw any 2

\\,j written d umentati n either in the training context 3

or outside of it concerning that event?

4 lll A

No, I do not.

5 6

Q Are you familiar or do you remember being familiar with a valve at Unit 2 called RCV 137?

7 8

A In Unit 27 9

Q Yes.

10 A

No, I do not.

11 Q

Is there such a valve in Unit 17 12 l

A Not to my knowledge.

l

(~h 13 l

Q How about RCV 1557 Does that ring a bell?

\\mj l

{

14 j

A No.

I i

15 Q

How about RCV 3?

16 A

It rings a bell because it is a valve in 17 my unit.

18 Q

Which one is it in your unit, that is, i

19 Unit 17 20 A

A block valve for the spray valve.

21 Q

Of the pressurizer?

22 A

Yes.

l 23 (Recess taken.)

o4 BY MS. WAGNER:

l

()

~

\\

\\~

25 Q

Are you familiar with a term called DNB?

i i

l

o -

1 Rocc 234 e

2 A

Yes, I am.

I i

s,J 3

Q What is DNB?

A DNB is the initials for departure from 4

5 nucleate boiling.

6 Q

What.does that mean?

MR. MacDONALD:

His understanding today?

7 8

MS. WAGNER:

Yes.

9 A

It means that you have reached the point 10 where nucleate boiling is no longer happening, I

11 nucleate boiling being small bubbles, and you are 12 starting to form a larger amount of boiling, big bubblesf l

13 Q

What is DNBR?

l r~s i

)

s

\\/

1]

l A

That is the ratio that expresses this l

l i

15 concept.

16 Q

The ratio between what and what?

I 17 A

The ratio between the flux at the hottest

{

18 channel and the flux at DNB, the point at which DNB 19 l

will take place.

i l

Q What are you referring to when you refer 20 i

21 to the hottest channel?

i G

22 A

When we looked at DK3, we always looked at l

23 the hottest localized channel, and that is what I mean i

at when I say the hottest channel, that mythical channel j

(~'\\

i

/

25 that exists someplace that has all the worst cases i

x-

1 Roco 235 2

Point to it and refers, to localized boiling in that area.

3 4

Q Is that a channel that is theoretically 5

somewhere in the reactor coolant system?

6 A

It is a specific fuel channel, one of the 7

many channels that exist around the fuel rods 8

themselves.

]

9 Q

Is the channel through water?

It is not 10 a channel in the fuel, is that correct?

11 A

It is a channel of water between the fuel 12 rod and another fuel rod.

I

()

13 Q

Where did you first learn about DNB and 14 DNBR, if you can recall?

15 A

I am not sure.

}

l 16 Q

Do you believe it was prior to March 19797 i

17 A

Yes.

I i

18 Q

Did you ever use that concept in the j

l 19 Operation of a commercial nuclear plant?

t 20 A

Yes, we did.

l 21 Q

In what way did you use it?

I ll) 22 A

DNB is something we were taught to avoid, 23 but it also was something you couldn't see.

24 l

Q How could you tell if you had it?

j I

J f

A The training material had you look at four l

25 i

l i

i l

1

1 Roca 236 (y

)

2 parameters, that being power, flow, temperatore, and 3

pressure.

4 Q

And if you had it, what would you do to get lll 5

away from it?

6 A

Really, our training never said if you had 7

DNBR, what you did to get away from it.

It said that 8

your protective system kept you from getting to it.

9 Q

I show you now a document which has not 10 been previously marked, but I prefer not to mark it as 11 an exhibit right now.

It is a document entitled 12

" Nuclear Power Preparatory Training Core Performance 4,

/"N I,

)

13 a Course for Metropolitan Edison Company by a Videotape ;

s._/

i I

i 14 ll by NUS Corporation, Rockville, Maryland," and the l

15 production numbers are 10811243 to 10811473.-

16 My question is, have you ever seen this 17 before?

j i

18 MS. WAGNER:

A similar book was marked in j

19 Craig Faust's examination.

I 20 MR. MacDONALD:

Was this part of a larger I

i 21 exhibit?

G l

22 MS. WAGNER:

I think this was the whole I

i 23 document, but I think that was his personal copy, i

i i

gy 24 which is why this one is different.

j s

i

\\_ /

l l

25 l

A I don't recall seeing this.

l i

I l

i 1

Ross 237 O/

2 Q

Do you ever recall prior to March 1979 receiving any training in " core performance"?

3 MR. MacDONALD:

You mean the subject, the 4

title of a course?

5 6

MS. WAGNER:

Yes.

Not necessarily the 7

title of a course.

In that topic, core 8

performance.

A Yes.

9 10 Q

Do you have any recollection now as to 11 what kinds of things would be taught to you which would 12 be classified under the term " core performance"?

(

13 MR. MacDONALD:

Any recollection of what I

14 kinds of things were taught to him?

15 MS. WAGNER:

That's right, i

i 16 A

My recollection is the type of things were I

17 linear heat rates, how to calculate an actual peak, 1

18 a radial peak.

Those types of items were taught in i

f 19 that course.

20 Q

Did that course include, to the best of 21 your recollection, discussions of,how heat is llg i

22 transferred in a reactor?

l

'MR.

MacDONALD:

You are asking if he recalls 21 l

l 24 whether it did?

f 25 MS. WAGNER:

Yes.

I t

I l

I

1 Ross 238 O,

t/

2 A

I don't recall.

3 Q

I would like to show you now a page and 4

ask you if you have seen this page of the document, O

5 and I will read what paragraph,it is I am referring 6

you to.

7 It says, "The reactor coolant in a PWR 8

system is kept under pressure to prevent bulk boiling 9

in the core.

In the case of an abnormal transient, 10 where this pressure is lost and some steam is generated 11 in the core, how will we know it?

We will see a large 12 I

increase in level in the pressurizer until pressure O

\\

b 13 is built back up above the saturation value 14 l

corresponding to the temperature in the core.

The l

S 15 steam bubbles will then condense and the level will i

16 drop back down close to its normal value."

17 Have you ever seen that particular paragraph 18 before?

I i

• 19 A

No.

j l

ll Q

Is there anything in that paragraph which 20 21 you did not know prior to March 1979?

l lll 22 A

Yes, the concept of an increase in l

23 pressurizer level.

()s i

i 24 j

Q I show you a document previously marked as

(

l t

25 B&W Exhibit 275.

I believe the entire exhibit is the i

l l

l

1 l

1 Ross 239

(_)

2 LER which was filed by Metropolitan Edison o,'

the accident at Three Mile Island on March 28, 1979.

3 4

What I am going to,show you is a part of that exhibit h

5 which is attachment D,

a sequence of events.

6 My question is going to be, havo you ever seen that be(cre?

7 8

A I have seen this.

s 9

Q Did you have any rola in the preparation 10 of that document?

11 A

Not to my recollection.

12 Q

Did you ever review that document?

l i

[s}

13 A

Not to my recollectiNh, l

x/

I 14 [

Q Did you ever review any similar sequence of 15 events concerning the accident, whether or not it was

~

16 in the final form which you see it now in, whether it

\\

17 was a draft,is order to prepare this?

l l

18 A

Not that I can remember.

i 19 Q

When did you see the document?

l A

I remember see.,ing it mainly because of its l

20 s

i 21 bulk size.

j ggg 22 Q

Do you, remember in what context you saw it?

i 23 A

No.

I don't remember.

i i

.tave you ever read it through, just this j

(~y 34 Q

t

)

i v

25 i

part of it?

s t

0 6

3

1 Roca 240

(

)

2 A

I never read it through.

s 3

Q Have you read parts of it?

4 A

I have looked at it.

x i

5 Q

Have you ever seen anything in it with which 6

you disagreed?

7 A

I never studied it that long to draw a i

I l

8 conclusion.

I g

Q I refer you now to a figure, and at the i

10 back of it there is a bunch of graphs.

One of them l

11 is Figure 60.

It is about three pages from the end.

I I

12 My only question about that is, do you

[N have any idea who prepared that document?

(

)

13 i l

[4 A

No, I do not.

t 15 Q

I take it you did not prepare it?

I l

16 A

No.

17 Q

I have a few more questions concerning the l

18 time at which you arrived on the site on the day of 19 the accident.

l I

20 l

When did you first hear about the accident i

21 which began on March 28, 1979?

22 A

My first contract sas a call from a Unit 1 23 shift foreman, and he was concerned about feedwater 7-24 chemistry on Unit 1.

That was early in the morning,

(,j' l

25 4:30, 20 to 5:00.

1 I

d

1 RODO 241 2

Q Did you subsequently go to the site?

A Y

I did*

3 4

Q You first went to TMI Unit 17 5 l A

Yes.

6 Q

You remained there for some short period 7

o f time and then you went to TMI-2, is that correct?

8 A

That's correct.

9 Q

I believe you testified yesterday that one 10 of the things you noticed shortly after you arrived in 11 the Unit 2 control room is an increase on the source 12 range monitor.

13 Do you recall, not your testimony, but

{

()

l 14 that you had seen an increase in the source range 15 monitor sometime shortly after you arrived in the Unit 16 2 control room?

17 A

I remember becoming aware of the source 18 range increase.

19 Q

I would like to refer you to two charts l

20 which are in the back of that.

They are Figures 56 and i

i 21 57.

On these figures, two graphs appear on each one gg 22 of them, and I am referring you primarily to the 23 bottom ones which are called source range channel NI-1.

i 21 Have you seen these graphs before?

j.

~

f)/

I i

A I don't recall seeing these.

25 i

I I

I I

1 ROOD 242

('

)

2 Q

Do you know when you were referring

(~

3 yesterday to the source range monitors whether another 4

way of referring to those is source range channel NI-1?

5 Is that the same instrumentation you were talking 6

about?

'ame instruments.

7 A

Yes, they are the s

8 Q

Looking at the graph, is it possible for you 9

to say, to pick out a point on either one of those 10 graphs which would be about the points when you first 11 noticed the source range indicators at the time you l

l 12 went into the control room?

i

(')

13 A

No, I don't think it would be possible.

I

\\_/

l they were high.

It is not like I saw 14 i

had become i

15 them increasing.

I was aware they were high and it l

16 did bother me.

l 17 Q

What did you mean by "high" at that point?

18 A

They should be decreasing, and at some 19 point they were at a very high level, higher than the 20 level they should have been.

6 21 Q

What was the level at which they should ggg

. 22 have been?

23 A

That period of a trip, they should have 2;

been down in low counts, very low counts.

l

[

)

~

25 Q

Just for a lay person, can you tell me what I

I

1 Roos 243 2

y u c nsider a low count?

A At that point they should have been less i

3 than 30 counts, less than 20 counts.

4 llh 5

Q Is it correct that both of these charts 6

show counts in excess of 30 and they don't show 7 l anything lower than 307 i

8 MR. MacDONALD:

You are asking him to look at the chart?

i g

10 MS. WAGNER:

I want to see if I understand 11 what the chart means.

12 Q

If you don't understand what the chart 13 means, fine.

' O' l

l l

A I don't understand their axis.

l 14 15 Q

On the left-hand side, they say " counts 16 Per minute, log decades."

Does that mean anything to 17 you?

i i

18 A

Yes, that means it was four decades of 19 indication to me.

I don't know what they meant.

20 Q

Four decades means 40, is that correct?

f 21 MR. MacDONALD:

What it means to Mr. Ross?

G 22 MS. WAGNER:

Yes.

I 23 A

It means somewhere around ten to three 24 counts or a thousand to me.

l i

i N-25 Q

So to clarify your earlier testimony, when i

i I

1 Roco 244 (m) 2 you say the count should have been below 30, is that 3

what you said, how did that relate to decades?

4 A

That would be, you would be someplace 5

between one and two decades at that point.

6 Q

That is what would be Lelow this chart, if 7

we could translate it into the language of this chart?

i l

8 A

That is my understanding, having not seen 9

this chart before.

10 Q

But you don't recollect when you arrived l

11 in the control room at what particular point it was?

l l

12 A

No.

Just higher than it ought to be.

j 7s ix_ j 13 Q

Is it correct that somebody called you i

14 l

from the TMI-2 control room when you were in the TMI-1 15 control room to ask you to come over to TMI-2?

i 16 A

Yes, it is, 17 Q

was that Bill Zewe?

18 A

That is my recollection.

19 Q

When he called you on the phone, do you 20 recall whether he made any comment to you at that time 21 as to whether there was any high indication on the g

22 source range monitors?

l 23 A

I don't recall any discussion on source 1

<x 24 range indication at all, or really any specifics at

/

i l

25 all.

l i

i i

l

1 Roca 245 (m

)

2 Q

I now would like to refer you to Figure 4

\\_j 3

in that pile, which is also part of Exhibit B&W 275, 4

and I will hand you a copy of it.

That is a chart, 5

as I understand it, of pressurizer level and pressure 6

in the time period between one hour before and eight l,

7 hours8.101852e-5 days <br />0.00194 hours <br />1.157407e-5 weeks <br />2.6635e-6 months <br /> after the turbine trip on March 28, 1979.

j i

8 I wonder if you could look at this chart I

9 and tell me at which level the pressurizer was, as far I

10 as you can recall,when you first entered the control l

t 11 room or within minutes after you entered the control l

l 3

12 room, whenever you first noticed it.

[~)h 13 A

My recollection on the pressurizer level

(_

I i

14 is that it was very high.

i 15 Q

It would have been, by very high, do you l

16 think close to 400?

l l

17 A

Yes.

I l

18 Q

At that time, I believe you testified that l

19 reactor coolant system pressure was quite low, is that j

l I

f 20 correct?

g 21 A

That is my recollection.

{

22 Q

Is there any point on this graph that you 23 can pick out where the two parameters are the way they i

24 were when you first had information_about them on the 25 day of the accident?

~'

1 i

i k

1 Roco 246 im()

2 MR. MacDONALD:

He didn't have any direct inf rmation in te rms of looking at them.

3 MS. WAGNER:

I am asking him for 4

information based on whatever his information 5

6 source was.

MR. MacDONALD:

I object.

I don't think 7

8 there ir any foundation.

l' l

9 Q

Is it correct that i

I 10 ;

MS. WAGNER:

I think there was a foundation i l

l 8

11 l he knew something about this.

I 12 MR. MacDONALD:

I am not directing him not I

7"N (G

13 l to answer.

My objection stands.

i 14 Q

I am wondering if you can pick out any i

15 point on this chart, looking at pressurizer level and 16 the reactor coolant system pressure lines there, l

I 17 if any space in this chart would be about what you saw i

le or what you had information about, whether you saw it 19 l or not,concerning pressurizer level and pressure at l

20 the same time.

21 A

I could surmise it could be someplace 22 between two and a half and three hours.

(

23 Q

I un just trying to understand how this

,e x

q graph is written.

As I read the graph, at about two N.)

I 25 i

and a half hours, the pressurizer level is about, a

{

i t

I

1 Ross 247 5/

2 little over 300 or around 300.

Is that correct?

3 MR. MacDONALD:

Are you asking him to tell 4

you what he understands?

He didn't write the 1

O

(

5 graph or draw the graph.

He has no inf o rmation 6

of what the author of the graph meant by the 1

7 readings on the graph.

He can take a guess.

8 MS. WAGNER:

I am not asking him to tell l

4 9

me whether this graph is a good graph or bad l

10 graph.

11 Q

My question is based upon your testimony as 12 I understand it.

It looks to me as if the time you

(~~'t l

(_)

13 pointed out we have a pressurizer level about 300 and i

14 j

a pressure at about 700, and I don't think that that 3

15 comports with what you have testified to previously, j

16 so I am wondering if that is in fact what you intended 17 to say.

18 MR. MacDONALD:

That is what my objection l

l 19 is based on.

There is no understanding of what l

20 l

the parameters were when he was in the control 21 room.

He said it was high and pressure was low.

ggg 22 He didn't look at the indicators.

l 23 Having him look at a graph and speculate

[~/')

24 j

on where the parameters might have been when he l

w_

l walked in is not doing anybody any good.

25 i

I J

i

1 Roco 248

/N 2

MS. WAGNER:

He testified he had i

'v' 3

information shortly after as to the level and as 4

to the pressure, and I am asking him to see if I 5

can figure out on this graph where it would put j

6 it on this graph.

I am just asking him to clarify l 7

his testimony.

l 8

MR. MacDONALD:

I object.

I don't think l

9 there is any basis for looking at a graph based 10 on what his prior testimony is to determine 11 when he walked in.

I 12 It is a simple resolution.

Ask him when 13 he came in the control room.

\\/

14 BY MS. WAGNER:

i 15 Q

You previously testified that you arrived 16 in the control room sometime which is shown between 17 two and a half and three hours on this graph.

Do you 18 wish to change any of that testimony based on my 19 reading of this graph? You can certainly agree or l

I 20 disagree with it, 21 A

No.

I don't wish to change any of my ggg 22 t e s t'imo ny.

i 23 Q

I am not suggesting it was wrong.

I just

{

24 wondered if this is still the place on the graph that

(~N i

i K_/

25 you think is closest to what you remember seeing when i

i

1 Roco 249 i

!,,1 2

you walked in.

V MR. MacDONALD:

Objection.

He didn't see 3

4 it when he walked in.

5 MS. WAGNER:

Or hearing about it shortly 6

after he walked in.

7 MR. MacDONALD:

I don't think his testimony l

8 was made on what he heard shortly after he 9

walked in as to both parameters.

10 Q

Do you have anything further to say?

I i

11 think your counsel will let you answer the question.

l 12 A

No.

My previous testimony is what I 13 recollect and what I told you now is what I recollect.

("]

f 14 Q

Is it correct that you recall that the l

l 15 block valve for the PORV was shut at some time after 16 you arrived in the Unit 2 control room?

17 A

My understanding is it was shut prior to me !

18 arriving there or near the same time.

19 (Recess taken.)

1 20 BY MS. WAGNER:

I l

21 Q

Is it correct that you recall that you l

g 22 gave some testimony to the NRC I&E people at or about g

i 23 i

April 25, 1979?

l 21 MR. MacDONALD:

I think he testified to I

/~N.

25 that yesterday.

i l

i

1 Roco 250 2

MS. WAGNER:

Yes, he did, but if I asked (j

3 him that question, you would say --

4 A

Yes.

5 Q

I refer you te page 10 of that testimony G

l and specifically to a question and answer in the middle 7

of the page.

8

" HUNTER:

You did not go behind there. O.K.

9 What about the computer -- did you make a pass at the 10 computer at that time?

I 11 I "ROSS:

One of the shift supervisors at 12 that time was trying to ascertain the position of l

f~/')

13 RC-RV2 it was Ken Bryan.

At that time he reported

's-l 14 back to us that it was 200-something degrees on his j

15 thermocouple, which is a fairly low raading, and 16 about that time we went in and isolated it."

17 Were you asked that question and did you l

18 give that answer?

l 19 A

My recollection is I was there.

I don't l'

'l l

00 remember that answer specifically.

21 Q

Do you believe there is anything wrong with j ggg 22 this transcription?

l 23 A

I have no reason to believe there is I

I 24 anything wrong with that transcription.

I have no l

[ s)

/

25 l reason to believe that what I said today is also,

' ~ '

i,

1 Roso 251

(%./m) 2 anything wrong with that.

3 Q

I am not suggesting there is anything wrong 4

with that.

I was just inquiring as to whether this 9

5 testimony was also correct.

6 Did you have any role at all in any kind 7

o f analyses or evaluations after the accident as to 8

what had happened either to the plant or the equipment 9

or operator action or anything like that?

l A

No.

10 l

I 11 Q

Were you involved at any time in l

12 interviewing any operators of the plant with respect l

[/

13 to their actions on the day of the accident?

s_

14 l

A I don't recall interviewing any of the 15 l

operators.

l 16 i

Q Whether you interviewed them personally or 17 not, do you recall being at all involved in that 18 process?

19 A

No.

I I

l 20 MS. WAGNER:

I would like to mark as B&W i

i I

21 Exhibit 306 a document which consists of a l

lll 22 front page mcmorandum from J.

G.

Herbein to i

23 i

G.

P.

Miller and others, dated June 18, 1979, and

)

24 following that front cover memo are a series of 7\\

t i

i i

'N_/

25 I believe telexes or telecopies from the l

l

1 Roos 252 f~')

I, j

2 Subcommittee on Energy and the Environment, and 3

some questions and some graphs appear to be 4

attached.

5 (Document, the front page a memorandum 6

from J.

G.

Herbein to G.

P.

Miller and others, 7

dated June 18, 1979, wita attachments, was 8

marked B&W Exhibit 306 for identification, as of 9

this date.)

10 Q

Have you seen that document before or any 11 part of it?

12 A

I don't recall seeing the document.

()

13 Q

As you will note, the document refers to 14

" Jim Floyd, Mike Ross, and Bill Zewe are to meet with 15 the operators so that they have a common understanding 16 of the question."

17 Do you have any recollection at this time 18 as to what that is referring to?

19 A

I have a recollection of some questions

[

l 20 l

that had to be answered by the operators for somebody, I

l 21 but I don't recall this document.

G Q

Do you recall what those questions l

22 i

l 23 concerned?

Are they the questions that are appended t

.f s

24 to this document?

t

\\

c Q_J' 25 A

I can't say for certain.

l t

i

1 Roca 253 2

Q Do you recall what you did with respect to

(~')

'u j 3

talking to the operators?

4 A

No, I do not.

I 5

Q Do you recall if you talked to the 6

operators at all?

7 A

No, I do not.

8 Q

Do you recall meeting with Jim Floyd and 9

Bill Zewe to discuss a common understanding of the 10 questions?

11 A

No.

12 Q

Since the accident in March of 1979, have

(~}

13 you spoken with Bill Zewe or Ed Frederick or Fred

\\_)

14 Scheimann or Craig Faust about their actions on the 15 day of the accident?

l' 16 A

Since when?

17 Q

Since March 1979.

18 A

I did.

I 19 Q

For what purpose?

l l

20 A

I don't recall, but I remember talking i

t i

21 about actions.

22 Q

Do you believe you were talking to them 23 just out of personal curiosity or because you had an l

assignment to do something in particular?

24 p p'

' '/

25 A

I am not sure.

i I

i e~

1 Roco 254

[

2 Q

Have yot spoken to anybody other than s

3 counsel about your deposition here?

4 A

No.

5 g

Have you spoken to anybody else who has 6

been deposed in this lawsuit by us about his 7

deposition?

8 A

No.

9 Q

Do you recall if you spoke 10 MR. MacDONALD:

Just a minute.

11 (Discussion off the record between the 12 witness and his counsel.)

(^J) 13 Q

With respect to the documents that have

's-14 l

been produced to us today and yesterday --

15 MR. MacDONALD:

He just has a clarification.

I 16 THE WITNESS:

My clarification is that l

l 17 I have spoken to Ron Toole, not specifically f

i 18 about the deposition, but we have talked about i

19 the subject of the deposition but not any details ^

20 or anything that we have mentioned something about the deposition.

I wanted to clear that up.

21 22 Q

Did he say he enjoyed his deposition?

i 23 A

No, he did not.

i 21 Q

With respect to the documents produced to

(

)

' ~ ~ '

25 I

us by you today and yesterday, can you tell me if any i

I

1 Ross 255 (D

2 documents, if any pages were taken out of those 3

notebooks prior to producing them to us by you or by 4

anybody else?

h 5

A To my knowledge, no material has been 6

removed from those books.

7 Q

Are you involved at all in the cleanup 8

of TMI-27 9

A No, I am not.

10 MS. WAGNER:

No further questions at this 11 time.

12 (Lunch recess taken at 12:00 noon.)

l 13 i

14 i

4 15 16 17 i

18 I'

19 l

t 20 i

21 g

22 2a I

i 2a a

I t

25 l

i i

i I

1 256

(~T ty 2

AF T E RNOO N S E S S I ON 3

1:10 p.m.

4 M I CHA E L J.

ROS S resumed 5

and testified further as follows:

6 EXAMINATION (continued) 7 BY MS. WAGNER:

8 Q

I would like to show you a document which 9

a large binder which you produced to us today, and 10 my only question is the same question I basically asked 11 this morning, whether that binder contains documents 12 which you received before March of 1979.

The first f%.

()

13 page of the document is 8.1 Unit Transient Response.

I 14 There are a number of tabs in the documents, and it is i

15 about four inches thick.

16 A

To the best of my recollection, it is l

17 stuff from before the accident.

I 18 MS. WAGNER:

I have no further questions.

i 19 i

EXAMINATION BY MR. MacDONALD:

l l

,f i

20 t

Q Do you recall testifying previously in 21 this deposition on the subject of your duties ggg 22 I

regarding review of procedures for Unit 1 and Unit 2 I

23 sometime in the early 1970's?

(~T 24 A

Yes, I do.

l

(_)

25 Q

Could you explain to us in a little more i

i l

Roco 257 1

l

^

detail what your responsibilities and duties were

(/')

2

\\_

with regard to that procedure?

3 A

When I talked about my procedure 4

involvement,to be just a little more specific, what 5

6 we were doing was red-lining draft procedures that had been provided to us by either our vendor on the 7

8 NSS system, B&W, or our AE or perhaps component vendors.

We were taking the draft procedures, field walking 9

10 them, making them site specific as to locations, as 11 to ranges of instrumentation, that type of thing.

I 12 Q

Did you yourself ever substantively draft

/'~N 13 or write any of the operating or emergency procedures

\\

L.)

I 14 l

for Unit 2?

l 15 A

No, I did not.

We received our drafts I

16 from either AE's or B&W.

17 Q

Do you recall earlier in your deposition 18 where you were testifying on the subject of training 1

19 you had had prior to the accident on heat transfer, 20 fluid flow?

l I

A Yes, I do.

l ol k

22 Q

Could you explain for us in a little more i

23 detail your understanding of what that training was and 24 the importance you placed on it?

s l

I A

To amplify a little more on what i

\\#

25 l

i i

i

1 Roco 258

[J) 2 importance I placed on it, I placed the importance on it 3

that our vendors placed on it, B&W, and also the NRC 4

placed on it.

lll 5

As of now, the NRC has a separate exam 6

ctction for Feat transfer.

As euch, it will 7et mere 7

emphasis.

It will be a more emphasized subject i

8 everyplace.

9 Q

Did you believe prior to the time of the 10 TMI-2 accident in March of 1979 that your training 11 in reactor theory was something that was important 12 for your knowledge of nuclear steam supply systems?

[~ )

13 l A

Yes, I did.

In fact, it was emphasized

\\_/

l 14 reactor theory training by virtually everybody, -

15 including the NRC.

i.

16 Q

Do you recall earlier in your testimony l

l 17 speaking on the subject of loss of coolant accidents i

18 and your understanding and training prior to the 19 accident of the relationship of LOCA's to core damage?

I t

20 A

Yes, i

21 Q

Would you explain for us in a little more

{

I 22 detail what that understanding was?

i i

23 l

MS. WAGNER:

I object, because I believe it 3

is asked and answered.

g N_)

i 25 l

MR. MacDONALD:

I am asking for a little l

1 Roco 259

~

2 more detail in the course of his testimony on

( '/

'1

\\._

3 this particular subject.

4 A

To amplify my previous words on that, yes, lll 5

I understood a LocA as bad.

I understood that if you 6

drained all of the water out of the cora, you could get 7

fuel damage.

8 What I was trying to say was that prior to 9

the accident, we had no way or we had no training that 10 told us this is how you know core damage is imminent.

I i

11 This is what you should look at.

We had no saturation l

12 indicators.

We had none of the new stuff you have

(^}

13 now nor did we have emphasis that says these five U

14 I

items will tell you that you have core damage instantly 15 as we do now.

16 Q

Do you recall testifying earlier in your 17 deposition on the subject of reactor coolant pumps and i

18 net positive suction head curves?

I 19 A

Yes.

l l

20 l

Q could you explain for us in a little more i

21 detail what your understanding was prior to the time l

l 22 of the accident of the relationship of net positive 23 suction head curves to the reactor coolant pumps and 24 f

reactor coolant system?

I

/~'s i

\\#

25 A

My understanding was the net positive l;'

W

1 Roca 260 r~)

2 suction head curve for the reactor coolant pump was

\\)

3 specific to the reactor coolant pump.

In other words, 4

that curve kept you from having a loss of net positive lh 5

suction head specifically at the eye of the impeller 6

of the pump.

If you formed any lack of pumping due 7

to a loss of net positive suction head, we never 8

associated that curve with anything corewise or the 9

reactor coolant system itself.

10 Q

Did you ever have any training from B&W, 11 Met Ed or any other vendors that would.make that 12 association?

r' 13 A

No.

We never had any training either at

(

l 14 i

the B&W simulator, Met Ed or any architect-engineer 15 that I can recall to make that association.

16 Q

You testified earlier on the subject of 17 departure from nucleate boiling.

Do you recall that?

18 Do you recall testifying on that subject?

19 A

Yes.

20 Q

And you were testifying in relation to s

21 DNB and channels within the reactor coolant system.

22 Do you recall testifying on that subject?

23 A

Yes.

I y

Q Could you explain for us in a little more

('~)

's-)

25 detail where those channels that you were speaking of I

i

1 Roco 261 2

in relation to the subject of DNB were located?

g3 A

MS. WAGNER:

Objection.

3 4

Q In the reactor coolant system.

5 I will break it down.

lll 6

Were they in the hot leg or the cold leg 7

of the reactor coolant system?

8 MS, WAGNER:

Objection.

9 A

When I thought of the DNB concept, I thought 10 of a very local concept, the concept being the hottest 11 single rod in one bundle of rods, localized to 12 one fuel assembly within the core.

13 Q

That is inside the core?

14 A

Inside the core.

i 15 Q

Do you recall testifying earlier on the l

16 subject of the PORV and the light indicator that was 17 installed sometime after March 1978 at TMI-2?

18 A

Yes.

19

' Q Would you explain for us in somewhat more 20 detail what your understanding was or what training I

i 21 you received in relation to that light indicator in the 22 PORV on Unit 2?

l t

l 23 MS. WAGNER:

Objection.

I believe the 21 prior testimony was that he received no training.

s I

/'N

(,)

25 l

MR. MacDONALD:

I am just asking for more

1 Roca 262

^

(V) 2 detail.

You may not have gotten all the detail 3

in your questions.

I think if you look back as 4

to what his answer was, you will see that his lll 5

answer is consistent.

I am asking for any more l

6 details on training he received.

l l

7 Mb. WAGNER:

Is this training about the t

8 light you are asking for?

l 9

MR. MacDONALD:

About the PORV or the light i

10 indication after the time it was installed, 11 anything relating to that subject.

12 MS. WAGNER:

My objection stands.

/~N 13 A

Although I can't recall specific training i

t f

I

\\_/

j 14 on the light, I do recall PORV training, either l

15 emergency procedures or in the course of training I

16 itself.

We never had what I would call a specific 17 item that we trained on and say this is how to diagnose j 1

18 a PORV, but my feeling is the light being installed 19 was a new item in the control room, and that light being l 1.:

20 0 very similar to the devices the operator uses every 21 single day, his whole goal in life as he looks at 22 position indicators, he has a lot of them in the control i

l 23 room, and it would be natural for him to use that as i

I 24 an indicator.

[~h i,

25 3

Q Did you have any understanding prior to the

\\

I e

l l

l

I Roco 263

/ '~ N 2

time of the accident as to, based on your training, b

3 what indications you would rely on primarily for i

indication of valve position in the PORV prior to the h

5 time of the accident?

6 A

POPV pcsition indication, of course, there 7

were items listed that would tell you it was open.

8 Here again, we just had installed a fairly new light 9

in the control room.

It was consistent with the very 10 essence of the operator's training as to light 11 indication or position indication.

I feel he would 12 have used that.

It would be very natural to use that.

13

('N Q

Do you know who in terms of what companies V

14 participated in the recommendation of that light 15 indication to be put in the control room of Unit 2 to 16 indicate position of the PORV?

II MS. WAGNER:

I object.

He indicated before i

i 18 he didn't know who was involved in that.

19 Q

I am just asking the question, regardless 1

f of your recollection.

20 i

i.

l 21 A

My understanding is it was put in in i

9 22 concurrence with our NSS vendor.

i I

23 Q

Do you recall testifying earlier on the

{

)

24 subject of the condensate polisher bypass valve in im 25 Unit 2?

i l

1

l 1

l Rocs 264

,' N 2

A Yes, I did.

Ns]

3 Q

Could you tell us, based on your firsthand 4

knowledge prior to the accident at TMI, whether or not 5

that valve was ever used prior to the accident?

lh 6

MS. MCDONALD:

Objection.

7 MS. WAGNER:

Could I hear the question 8

again?

l 9

(Question read by the reporter) i 10.

MS. MCDONALD:

Objection.

He answered that 11 very question and he already gave an answer.

12 Are you asking him to change an answer?

~s 13 MR. MacDONALD:

I am not asking him to l

I change testimony.

I am asking him to explain 14 15 the basis of the question that I have asked.

i 16 You will see when we go back on the basis of 17 the question you asked, his answer is very 18 i consistent.

I 19 MS. MCDONALD:

The objection stands.

20 A

When I talked about the operation of that i

21 valve, I am speaking for myself.

I know of no use.

l 22 I don't know whether or not Unit 2 used it, because I i

23 was in Unit 1 much of the time.

I l

2; Q

On the day of the accident, March 28, 1979, l

[

\\,

I could you tell us when you, to the best of your

\\_/

25 i

i i

I i

i

1 Roco 265

(,)

2 recollection, entered the control room at Unit 27 l

3 A

To the best of my recollection, I entered 4

the control room about the time or shortly thereafter lll 5

the PORV block valve was closed.

I perceive that 6

timo to be somewhere around 6:30 in the morning, or I 7

recollect that time to be 6:30 in the morning.

8 Q

What was your recollection of your~

9 understanding of what the parameters relating to 10 pressurizer level on the reactor coolant system pressure 11 were when you entered the control room?

12 MS. WAGNER:

I object to the question.

l

[)

13 That has been asked and answered.

Are you

%.)

l 14 asking him for additional testimony or different 15 testimony?

16 MR. MacDONALD:

I never ask for different 17 testimony.

I am asking perhaps for a little more 18 detail than your question alluded to.

19 MS. WAGNER:

My question asked for all 20 available details.

21 A

My understanding of the parameters, it is 9

22 hard for me to tell when I had that knowledge of what 23 the parameters were.

It is hard to tell how I got it, l

l 21 but I know what I thought they were shortly thereafter i

j

\\/

25 or upon entering.

It was no concise time.

I can't l

k

e 1

Roso 266

( ^g 2

relate it with a time.

It was within some time

~

iJ i

3 period it was given to me.

4 Q

Did you learn both pressurizer level and 5

reactor coolant system pressure at the same time?

lll 6

A Not necessarily.

I learned of them.

I am 7

not even sure I got them at the same time.

8 Q

Do you recall testifying earlier in your 9

deposition on the subject of operator input into the 10 layout of the control room at TMI-27 11 l

A Yes.

12 Q

Could you explain for us in a little more

~.

13 detail what e,xactly from your firsthand knowledge you v

14 knew about operator input in the control room at 15 TMI-27 16 MS. WAGNER:

I object to the question.

I 17 asked that precise question and an answer was 18 given to it.

19 A

My knowledge stems from me.

My distinct 20 knowledge.

I don't know of any operator input, but 21 I don't know that there wasn't any operator input.

22 Q

Prior to the time of the TMI-2 accident, j

23

~

could you tell us whether or not you received from B&W, 21 doing simulator training, training on the use of the N

i 1

(~'l l

5-25 computer?

i i

E

(

267 RosG g

,r x (v) 2 MS. WAGNER:

I cbject to the question.

No f undation.

Which computer are ycu referring to 3

4 and was it in the simulator?

MR. MacDONALD:

The computer at the 5

6 simulator.

7 MS. WAGNER:

5:h at computer?

T h'e simulator s

8 is a computer.

9 MR. MacD N$LD:

The compuker tnat was 10 alluded to earlier in the deposition.

1 11 BY MR. MacDONALD:

1

', l 12 Q

You recall tes' ifying earlier about the l

(n.)

13 computer in the control room'at TMI-27

\\.s 1

14 MS. WAGNER:

Again he is welcome to clarify, 15 but i

16 Q

Do you recall testifying on that subject?

17 A

Yes.

r 18 Q

Do you. recall prior to the time o f _ t.h e f

19 TMI-2 accident whether or not when you attended,the i

s a,..

l 20 B&W simulator, you received anv'Vraining from Law at 21 the simulator regarding>the 82se of that computer during h

i

[

22 transients?

l 23 A

We never received any training from B&W

,7 ~ 3 24 at the simulator that tied the computer nor the

[

I t

s C/

monitoring of the computer to any Uransien'ts.

25 u

1 Ross 268 2

Q Do you recall earlier in your deposition 3 d testifying regarding training that you either gave or 4

received in relation to transients that had occurred ll) 5 at TMI Unit 1 or 27 6

A Yes.

7 Q

Would you explain for us in more detail f

8 what your understanding was prior to the time of the 9

accident as to what transient training you either 10 gave or received in relation to transients at either 11 TMI Unit 1 or 2?

I 12 MS. WAGNER:

I object to the question.

./~(Tj 13 Asked and answered several times.

I

?

14 A

Although I don't recall specific instances i

l i

15 of training, I know training was done, and I don't 1

16 recall what made us do it.

Again, I know it was done.

17 I don't know what the document was that says "You 18 must do it," but I know that training was done.

19 Q

Is that on transients that occurred at both l,

.20 Unit 1 and Unit 2 prior to the time of the accident?

21 A

Yes, it is, h

22 Q

Prior to the time of the TMI-2 accident, I

23 did you receive any training from B&W, either at the simulator or otherwise, which related to transients c24 j

25 which had occurred at plants other than Three Mile i

._4 t

t 4

i s

s.'s 4

I

~

1 Roc 0 269 p

2 Island?

y/

3 A

Yes, we did.

In fact, one occurrence I do 4

remember was early on, Duke Power was having trouble lll 5

running feed pumps in parallel, and they were using the 6

unit or having a trip on it due to a feed pump 7

transient, while at the simulator they ran us through I

8 parallel operation, and many times, even though at TMI 9

Unit 1 it wasn't a problem to us.

Q Do you recall anytime prior to the TMI-2 10 l

11 accident whether or not you received training from 12 B&W on simulator or otherwise on a transient that l

gS 13 occurred at Davis-Besse, on any transient that occurred NI 14 at Davis-Besse?

l 15 A

No, we never received any training on that 16 transient.

17 MS. WAGNER:

Which transient are you 18 talking about?

19 MR. MacDONALD:

Any transient occurring 20 at Davis-Besse.

i 21 Q

Do you recall receiving any training?

22 A

We received no training on any transients l

i 23 that occurred at Davis-Besse.

l t

Q You don't recall receiving any transient k,

21

,4 i

(

i N/

25 l

training then prior to the time of the TMI-2 accident I.

1 RoCO 270 28

(

)

2 on a transient that occurred at Davis-Besse in or q_;

3 about September 19777 4

MS. WAGNER:

Objection.

lll 5

A No, I do not.

6 MR. MacDONALD:

I have no further questions.

7 (Recess taken.)

8 BY MS. WAGNER:

9 Q

Did you understand prior to March 1979 10 i who was the operator of TMI-2?

Who was the entity with 11 responsibility for running that plant?

12 A

Yes.

I

(~)

13 Q

Who was that?

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l 14 A

Metropolitan Edison.

i l

15 Q

I take it it was not Babcock & Wilcox?

16 MR. MacDONALD:

For actually hands-on 17 operation of the plant?

18 MS. WAGNER:

That's right.

19 A

No, it wasn't Babcock & Wilcox, although they provided us with much input for operation of the i

20 I

i 21 plant.

l Ill i

99 Q

But ultimately it was Met Ed who ran that l

l 23 plant, isn't that correct?

I i

24 A

That's correct.

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l 25 Q

Based on that, did you feel that Met Ed had,

' ~ '

I l,

1 Ro00 271

(~)

2 any responsibility whatsoever to make sure that its G'

3 procedures were good procedures?

4 MR. MacDONALD:

I object to what you mean llk 5

by " good procedures."

He testified to what 6

review process had been performed.

Q Did you believe that Met Ed had any 8

responsibility for insuring that the procedures were 9 l adequate for keeping the plant protected from damage?

10 MR. MacDONALD:

Objection.

I am not quite l

11 sure what that means, if it has any meaning 12 in terms of licensing documents.

Mr. Ross may l

(~N 13 not be aware.

I

\\._,/

A Yes, Met Ed had a licensing responsibility.

14 I

i I

15 I believe the architect-engineer and also Babcock &

i i

16 Wilcox had a responsibility.

They designed and 17 helped operate the plant in a manner of speaking.

I i

18 Q

Do they have a license to run the plant, j

i i

19 to the best of your knowledge?

l 1

A To the best of my knowledge, they don't 20 21 have a license to run the plant.

However, they 22 designed it.

They had their design approved by l

23 somebody.

I i

24 Q

Are you aware of any review whatsoever l

( ~')

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25 performed by Metropolitan Edison prior to 1979 with l

i

1 Roco 272

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)

2 respect to training?

By that, I mean are you aware of whether Met Ed made any decisions on any training 3

4 that was given to its operators, or did B&W decide 5

the entire content of all the training given to all 6

of the operators?

7 A

I don't know for a fact what percentage 8

was involved in either one of those, but it was a i

9 responsibility that was shared.

We relied on B&W for 10 that input, a lot of it.

l l

11 Q

You did not believe at that time that you 12 personally or Met Ed as an entity had responsibility

( )

f r insuring that your operators were appropriately 13 14 j

trained to run the plant?

15 A

We felt we had a responsibility.

We also IG felt that our best source of input were the people l

17 who designed and built the plant, B&W.

I l

l 18 Q

How did you know that?

l 19 A

B&W designed and built it.

They had a i

20 simulator for it.

We felt that was our best input.

l i'

l 21 Q

Is the simulator an exact replica of the gg) 1

{

22 TMI-2 control room?

23 A

No.

l i

r~N 24 Q

Were there things in the TMI-2 control room

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l 25 l

that were not present at the simulator?

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i l

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i 1

R300 273 p) 2 A

There were.

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Q Was the simulator intended to be an 4

exact duplicate of every function of the TMI-2 plant?

lh MR. MacDONALD:

Objection.

5 6

Q Did you understand it was intended to show 7

you an exact replica of every function in the TMI-2 8

Plant?

9 A

I understood it was not to show you an exact replica, but it was to show you virtually an exact 10 j

11 replica of the NSS supply system.

12 Q

You testified a couple of times about f~')

13 net positive suction head curves.

Was it your u/

14 understanding prior to the accident that the

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15 temperature at the suction of the pump was the same or 16 different as the temperature in the reactor coolant 17 system, the average temperature, let's say?

18 A

Again, when we looked at an NPSH curve, we 19 associated it with the pump.

We made no association l

l 20 with the core or with the core temperature itself.

We 21 looked specifically at that entity, the pump impeller f

9 22 and the pump itself.

23 Q

Did you have any knowledge, regardless of l

24 what the curve had to do with, as to whether or not i

\\/

25 i

the temperature at the pump suction head would be the

?

i Roco 274 1

(

)

2 same or different from the temperature, the average x>

3 temperature of the reactor coolant system?

4 A

If I step back and look at it, again I 5

would know they would be close to the same, but again, lh 6

when we looked at NPSH and we associate a curve, we 7

associate it with a local component.

8 Q

Do you know whether prior to March 1979 i

f 9

you had any understanding as to whether the pressure 10 at the suction of the pump would be the same or 11 different from the pressure of the reactor coolant 12 system?

l' fs

[

)

13 A

I was aware there would be some difference.

w/

14 I was also aware that I never related the pressure at 1

15 the NPSH or at the suction of the pump with the pressure 16 of the core.

We looked at that curve.

That curve 17 told us we were worried about that pump.

18 Q

You mentioned that you knew there would be 19 some difference.

Can you give me any idea of the 20 quantitative amount of the difference?

i' 21 A

Small.

There were pressure drops in the 22 i

loop.

i I

23 Q

W)uld it be a couple of pounds or a l

24 thousand pounds?

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l 25 j

A Twenty-five pounds.

l I

i

1 Roco 275

,, m

(

)

2 Q

At TMI-1 today, is there any direct N_/

3 indication of the water level in the core?

4 A

You have to describe " direct."

lll 5

Q Is there any dial you can look at which 6

tells you there is X feet of water in the core or the l

7 core is covered or the core is uncovered?

Something i

8 that is very direct in telling you the water level in 9

the core.

10 A

No, there is not.

11 Q

Isn't it correct that you testified there 12 is no need for such an indication?

(')I 13 A

That's correct.

G i

14 MS. WAGNER:

I have no further questions.

15 BY MR. MacDONALD:

16 Q

Could you tell us in response to Ms.

17 Wagner's last question why you understand after the 18 accident that there is no need for a level indicator l

19 at TMI-1 in relation to water level in the core?

20 A

'It is true that I testified that no water i

21 level indicator is necessary, but that testimony is l

I 22 based on the additional training we have had now, the I

i 23 additional practice, the installation of thermocouples 21 that read out in the control room, the installation of 7s

(

)

I i

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25 l

the T-sat. meter that displays saturation margin to i

i

Roca 276 1

2 the operator and all the emphasis on procedures and

(]

\\s use of those instruments.

My testimony means it is 3

1 4

not necessary because of all these additions and 5

training, and that includes simulator training.

h 6

MR. MacDONALD:

I have no other questions.

(Time noted: '2:00 p.m.)

7 8

9 MICHAEL J.

ROSS 10 11 Subscribed and sworn to 12 before ce this day of 13

{}/

198 j

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14 l

15 16 17 i

18 19 i

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21 22 23 2

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277 1

1 CERTIFICATE O

2 j

STATE OF NEW YORK

)

j 3

ss..

COUNTY OF NEW YORK

)

l 4

h I,

JOSEPH R.

DANYo a Notary 5

i Public of the State of New York, do hereby certify that the continued deposition of 7

i l

MICHAEL J.

ROSS was taken before I

8 WEDNESDAY, NOVEMBER 18, 1981 me on consisting 9

202 of pages through 276 i

I further certify that the witness had i

11 been previously sworn and that the within transcript is a true record of said testimony; f')

13

~'

i That I am not ' connected by bloed or 14 marriage with any of the said parties nor la, interested directly or indirectly in the matter l

in controversy, nor an I in the employ of any 17 of the counsel.

18 I I

i IN WITNESS WHEREOF, I have hereunto set my 19fl hand this

/

day of.. -

20 i

21 no C14/

ANYD n ;u.

JOSEPH R.

DANYo 24 p.

'wY 2b l

278 CE)

INDEX e

WITNESS PAGE MichaeA J.

Ross (resumed) 204 EXH IB I TS B&W FOR IDENTIFICATION 306 Document, the front page a memorandum from J.

C.

Herbein to G.

P.

Miller and others, dated June 18, 1979, with attachments 252

-oOo-i 9

O l

1

}

l, I

k UNITED STATES DISTRICT COURT (D

SOUTHERN DISTRICT OF NEW YORK

()

l l ________________________________________x GENERAL PUBLIC UTILITIES CORPORATION, JERSEY CENTRAL POWER & LIGHT COMPANY, METROPOLITAN EDISON COMPANY and PENNSYLVANIA ELECTRIC COMPANY, Plaintiffs, 80 Civ. 1683 (RO)

AFFIDAVIT

-against-THE BABCOCK & WILCOX COMPANY and J. RAY McDERMOTT & CO.,

INC.,

Defendants.

l----------------------------------------x l' STATE OF PENNSYLVANIA ):

ss.:

}

l COUNTY OF DAUPHIN

)

i'3 i

I have read the transcript of my deposition taken on V

1981 and together with the attached correc-iNovember 17 and 18, ltions, it is accurate to the best of my knowledge and belief.

g, k

Y l

Michael J.(JM5ss i!

I Signed and sworn to before me this

1. [4 day of October, 1982.

[O i

i W$

("

Notarf Public

[/1HY L BREY Notary PutAc f

Londoncerry Two.. Dauchm County. Pa My Commission Empires Oct. 24,1933 A

4 r-Corrections to M.J. Ross Deposition O

' August, 1982 Page Line Correction 46 8

" wrote" should read " worked" 173 19

" leaving" should read " relieving" 174 4

" leaving" should read " relieving" 213 22 "think" should read " don't think" 235 6

"is" should read "is not" 243 23

" ten to three" should read"

" ten to the third" 264 6

" Mcdonald" should read " Wagner" 264 10

" Mcdonald" should read " Wagner" 264 19

" Mcdonald" should read " Wagner" O

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