ML20072H957

Deposition of Jf Walters on 810413 in New York,Ny.Pp 1-163

ML20072H957
Person / Time
Site:	Crane
Issue date:	04/13/1981
From:	Walters J BABCOCK & WILCOX CO.
To:
References
TASK-*, TASK-GB NUDOCS 8306290835
Download: ML20072H957 (163)

Text

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w UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK

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GENERAL PUBLIC UTILITIES CORPORATION, JERSEY CENTRAL POWER & LIGHT COMPANY, METROPOLITAN EDISON COMPANY and

(

PENNSYLVANIA ELECTRIC COMPANY, a

Plaintiffs, CIVIL ACTIOI NO. 80 CIV.

-against-1683 (R.O.)

THE BABCOCK & WILCOX COMPANY and J.

RAY McDERMOTT &

CO.,

INC.,

Defendants.

(

- - - - - -x Deposition of the Defendant, THE O

V BABCOCK & WILCOX COMPANY, by' JAMES FRANKLIN WALTERS, taken by Plaintiffs, pursuant to notice, at the offices of Kaye, Scholer, Fiernan, Hays & Handler, Esgs., 425 Park Avenue, New York, New York, on April 13, 1981, at 10:00 a.m.,

before Charles shapiro, a Certified Shorthand Reporter and Notary Public of the State of New York, p

V DOYLE REPORTING. INC.

CERTIFIED STENOTYPE REPORTERS jo 5g%

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369 LtxtNoToN AVENUE P

PDR Nsw Yomst. N.Y.

10017 Tas.rpNoNe 212 - 867 8220

1 2

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Appe arance s :

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

4 4

Attorneys for Plaintiffs, 425 Park Avenue,

(

5 New York, New York 6

BY:

RICHARD C.

SELTZER, ESQ.

and 7

ANDREW MacDONALD, ESQ.,

of Counsel 8

9 DAVIS POLK & WARDWELL, ESQS.,

Attorneys for Defendants, 10 One Chase Manhattan Plaza, New York, New York 10005 11 BY:

DANIEL F.

KOLB, ESQ.

12 and

[)

LINDA E.

CHATMAN, ESQ.,-

13 of Counsel 14 ALSO PRESENT:

15 DAVID TAYLOR o0o 16 IT IS HEREBY STIPULATED AND AGREED by and 17 among the artorneys for the re'spective parties 18 hereto that the sealing, filing and certifica-i 19 tion of the within deposition be,'

and the same 20 hereby are, waived; and that the transcript may 21 be signed before any Notary Public with the same 22 force and effect as if signed before the Court.

13 IT IS FURTHER STIPULATED AND AGREED that l

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24 all objections, except as to form, shall be l

L 25 reserved to the time of trial.

L i

1 3

4 2

JAMES F RANK L I N WALT ERS 3

having been first duly sworn, was examined 4

and testified as follows:

I 5

EXAMINATION BY 6

MR. MacDONALD:

7 Q

Will you state your full name, please, 8

Mr. Walters?

9 A

James Franklin Walters.

10 Q

Your address?

(

11 A

402 Lakewood Street, Lynchburg, Virginia.

12 Q

Who is your current employer, Mr.

l

\\m) 13 Walters?

14 A

Babcock & Wilcox.

15 Q-How long have you been employed by 16 B&W7 17 A

Since February of

'69.

18 Q

Who was your employer before B&W7 19 A

Brown Engineering Company.

20 Q

For how long did you work for Brown 21 Engineering?

w 22 A

Four and a half years.

23 MR. MacDONALD:

I would like to mark I

, j 24 as GPU Exhibit 126 a copy of the resume 25 of James Franklin-Walters that was used in Mr.

1 Walters 4

2 Walters' Rogovin deposition.

3 (Resume of James Franklin Walters 4

marked GPU Exhibit 126 for identification,

(

5 as of this date.)

6 BY MR. MacDONALD:

7 Q

Mr. Walters, is this an accurate 8

representation of your educational and work 9

related experience?

10 MR. KOLB:

Could I ask whether you mean 11 accurate as of the date it was used?

12 MR. MacDONALD:

Accurate as of the 13 date it was prepared.

14 A

Yes, it is.

15 Q

What is your current position at B&W?

16 A

I am a Project Engineer in a Project 17 Engineering Unit.

18 Q

That is in the Engineering Department?

19 A

Yes.

20 Q

So you are no longer in the Nuclear 21 Service Department?

22 A

That's correct.

23 Q

Have you ever had occasion from the

-(

)l 24 time you have been at B&W to produce copies of 25 i

'your resume for use other than'the one we see L

1 1

Walters 5

2 here by the company?

3 A

Yes, I believe my resumes have been i

4 used for -- by the company.

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5 Q

Is the resume a copy of what we see 1

6 here or was it in a different form?

I' j

7 A

It was in a different form.

8 Q

Who was that resume produced for?

9 A

I have no knowledge of the specific people 10 it was prepared for.

11 Q

When was it made up?

12 A

I am not aware of that.

O 13 Q

Did it contain more detail than we see

/

4 14 on GPU Exhibit 1267 4

15 A

Yes, I believe it did.

j 16 Q

What additional information was con-17 tained on that resume that you prepared that is 18 not in GPU Exhibit 1267 i

19 A

I don't remember in detail.

20 Q

In substance, if you can recall.

21 A

I think mainly it was for a slightly dif-l l

22 ferent purpose, it was to be used as i

23 MR. KOLB:

.The question is only what

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24 was in it, not what it was used for.

25 A

Well, it covers' essentially the--same t

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I Walters 6

2 information, a little more detail on the start-ups, 3

specific job identification at oconee, at Arkansas, 4

a little more specific on some of the detail 5

problems I had been involved with.

6 Q

What was the specific purpose this 7

resume was produced for?

8 A

From time to time, B&W offers people to our 9

customers for assisting their engineers, on-site e

10 engineers, for work and that's what'it was used 11 for.

12 Q

In other words, it was used to give 13 to customers to judge the qualifications of the 14 personnel who were to be assisting them?

15 A

Yes.

16 Q

Did other individuals Within your 17 section at B&W at the time you prepared this'also 18 prepare a resume?

e4 19 A

I don't remember specifically.

20 Q

Were you requested by your superior

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21 at the time to prepare this resume?

22 A

As I remember, yes.

23 Q

And others in your unit were also?

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24 A

Yes.

25 Q

Were these. resumes then put together

1 Walters 7

s 2

in a package, do you know, to be shown to the 3

customers or were they shown to the customer 4

individually?

5 A

I have no knowledge of exactly how they were 6

shown to the customer.

7 Q

Have you seen a copy of anybody else's 8

resume that was prepared as a result of the 9

request?

t 10 MR. KOLB:

Meaning the same type of A

11 request we were just discussing?

~T 12 MR. MacDONALD:

Correct.

{V 13 A

I believe I have seen some of the engineers 14 that worked for me.

15 Q

Was a description prepared of the 16 unit or the section responsibilities or expertise 17 aside from individual resumes?

~

18 A

I have no knowledge of that.

19 Q

You did not work on anything like 20 that?

21 A

No.

22 Q

You only prepared your own resume?

23 A

Yes.

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24 Q

Was a copy of that resume turned over 25 in the course of this lawsuit, do you know?

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1 Walters 8

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2 A

I have no knowledge of whether it was or 3

not.

4 Q

Do you have a regular document 5

retention policy at B&W presently?

6 A

Yes.

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7 Q

Could you tell me what that policy 8

entails?

9 A

What documents are we talking about?

10 Q

Documents that are prephred in the 11 regular course of business.

12 MR. KOLB:

He is talking about a company 13 policy now, something that would be the i

14 general practice of the company as you 15 understand it.

16 THE WITNESS:

Yes.

17 A

Yes, we have a policy and procedures manual 18 for. production of related documents in-the areas 19 I was working in.

20 Q

What do those policies call for in 91 terms of retention of documents?

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22 A

It varies from document to document.

Generally, I remember that there are criteria 23

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for filing in the Central Files specific documents l

25 and mainly in the job I was in we -- most of my

4 1

Walters 9

2 stuff was filed in the service Library, itself.

3 Q

Have,there been any specific 4

directives after the TMI-2 accident of March (1

5 28th, 1979 regarding retention of documents at B&W7 6

MR. KOLB:

To the extent you know.

7 MR. MacDONALD:

Always to the extent 8

that he knows.

9 MR. KOLB:

Yes.

It's a very broad 10 question.

That's why I made

'he statement t

11 I did.

12 A

I don't remember.

DG 13 Q

Have you received any memo or directive 14 or have been told verbally of any retention policy 15 on documents that you either write or receive in 16 your normal course of business at B&W since the 17 TMI-2 accident?

18 MR. KOLB:

Would you read the question 19 back.

20 (Record read.)

21' A

_I don't recall of any.

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i 22 Q

Do you personally have a document

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j 23 retention policy of your own that you have de-rw l

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21 l

veloped as to which documents you retain in your 25 files and which-you may discard?

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1 Walters 10 2

A No, I have not.

3 Q

Are the guidelines that you use in 4

document retention generally the ones that are in

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5 the B&W policies and procedures directive?

6 A

Generally.

7 Q

And in the policy and' procedures 8

directive is there any guidance on what documents 9

to retain andJwhich to discard?

10 A

Not that I recall.

11 Q

So the policies and procedures directive 12 deals with where documents should be sent, i.e.,

. f-.U 13 if to Central Files or maintained by the 14 individual?

15 MR. KOLB:

You are asking for the 1G state of his recollection as to the 17 procedures.

18 MR. MacDONALD: Yes.

19 MR. KOLL:

Just the'best you know now.

20 A

Yes, that's to the best of my knowledge.

21 What is v policy in-terms of which 22 documents ye tin in your files since the 23 TMI-2 acciden 24 MR. KvbB:

Just to be clear, are you 25 talking about all documents or are'you L

1 Walters 11

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2 talking about documents with respect to 3

TMI-2 or some specific subject?

4 MR. MacDONALD:

All documents.

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5 MR. KOLB:

O.K.

6 A

I don't believe I have ever developed a 7

specific policy for specific documents.

8 Q

Do you have any general policy in terms 9

of what you maintain in your files as a matter 10 of regular course of business?

L 11 A

Yes, I retain copies of memos that I have 12 written to other people within the company on

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13 general subjects and information or memos I have 14 received from people within the company usually 15 listed by subject matter.

116 Q

Are the memos that you retain which 17 you yourself authored kept in a chronological 18 file?

t-19 A

Yes.

20 Q

For how long have you maintained the i

oi chronological ~ file?

l 22 A

I believe it was either '77 or

'78.

I l

23 forget the exact year.

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24 Q

Have you received any specific directives since the TMI-2. accident regarding maintenance 25

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Walters 12 Od 2

of TMI related material?

3 A

What do you mean by maintenance?

4 Q

Retention.

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5 A

Yes.

6 Q

What was that directive?

7 MR. KOLB:

If I may.

8 (Witness confers with counsel.)

9 MR. KOLB:

I just inquired of Walters 10 to be.certain, I thought and k believe I am 11 correct, the material he is referring to came 12 from counsel and that as far as we are o

a 13 concerned is privileged.

14 MR. MacDONALD:

The fact that he has 15 received such a directive would be all I am 16 looking for.

17 MR. KOLB:

I think you asked that and 18 he has given you an answer.

19 I understand if there is a 20 communication you are entitled to know 21 there was such a communication but it 22 is as to the content I raise my objection.

23 BY MR. MacDOLAND:

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Q.

So it is your testimony you have 1,j-24 l

25 seen some directive after TMI that relates to

I 1

Walters 13 2

maintenance of TMI related files?

3 A

Yes.

4 Q

So before when you testified about

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5 ten minutes ago that you hadn't received any 6

directive after the TMI-2 accident regarding 7

retention of your files, that statement was not 8

correct?

9 MR. KOLB Now, first of all, whatever t

10 his prior statement was the record speaks 11 for itself on that.

12 O

Secondly, you will recall that I V

13 asked earlier a clarifying question as to 14 whether you were asking about specific 15 retention directives as to TMI or whether 16 you were asking generally.

17 You indicated you were asking 18 generally.

19 MR. MacDONALD:

That's correct.

20 MR. KOLB:

I think, therefore, the 21 implication of your remark is uncalled for 22 because of the way you phrased.your prior 23

. questions and because of the way you

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24 responded to-my inquiry.

25 Let me say again, though, whatever d

1 Walters 14 2

his prior testimony is, it speaks for 3

itself, and if you want to go back to 4

question him about it, I will ask to have

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5 the record read back.

6 MR. MacDONALD:

I think we will 7

glean from his prior testimony and my 8

questions it was a general question before 9

you even inserted whether or not it was 10 generally or specifically and'his answer 11 was, I think the record will correctly 12 reflect he received no directive after the 13 accident regarding the maintenance of 14 files at B&W and now he said he has 15 received a directive relating to TMI 16 related files.

17 Indeed, one is a subset of the other 18 and if in fact the answer to the first 19 question should have been yes, all I am 20

. attempting to do is to go back and establish

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21 that 'here had been directive related to 22 TMI.related documents and indeed'his 23 prior answer as to generally should have

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been yes.

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05' MR. KOLB:

I think that you will have

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2 to go back and deal with the prior record 4

3 however you please.

I don't agree with 4

your characterization of his prior l

5 testimony.

We have been sitting here-6 listening to the testimony and there is no 7

purpose-debating it beyond that.

8 I think the record is a good one on 9

the subject and you had your answers on both 10 questions, both'in general and in specifics.

11 DY MR. MacDONALD:

12 Q

Have you maintained since the TMI-2 13 accident all TMI related files?

j i

14 A

Yes.

15 Q

Did you turn those files over to 16 counsel at some time after the accident?

17 A

Yes.

18 Q

.Did you turn any other material over 19 to counsel after the TMI-2 accident?

20 MR. KOLB These would now be documents og other than documents relating to the TMI-2 22 accident, is that what you are asking about?

23 MR. MacDONALD:

.Other than documents L( )_

34 relating to TMI as a TMI-1 or TMI-2, not 25 -

specifically. relating to the accident on

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i 1

Walters 16 2

March 28th, 1979, as it related to the day 3

of the accident.

4 MR. KOLB:

You are asking about something

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5 that didn't relate to TMI, did he turn over J

6 anything else besides things related to 7

TMI.

8 MR. MacDONALD:

My question dealt i

9 with whether he turned over all TMI related

'T 10 material and the answer I thibk was yes.

11 I want to find out if he turned over any 12 g-other material aside from his TMI related C

13 material.

14 MR. KOLB:

0.K.

You can answer that.

15 A

Yes, I think there are other materials that 16 were turned over that were not specifically related 17 to TMI.

18 Q

Do you produce on any regular basis 19 activity reports?

20 A

Yes.

21 Q

For how long have you done that?

22 A

Three, four years.

23 Q

Since the time you were in Plant

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Performance Services?

25 A

Yes.

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Walters 17

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2 Q

And before that time?

3 A

Not on a regularly scheduled manner, or 4

any that I retained.

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5 Q

So it's been since 2/77 that you 6

generated these particular monthly act'ivity i

7 reports?

8 A

I believe that's correct, yes.

9 Q

Who are those reports sent to?

10 A

My immediate supervisor, Don kallman.

1 11 Q

Has he been your supervisor since 12 the time you became Supervisory Engineer for CE) 13 Plant Performance Services?

14 A

Yes, until January of this year.

15 Q

Which is when you changed to Project 16 Engineer?

i 17 A

That is correct.

18 Q

Who do you report to now?

19 A

Bob Baker.

20 Q

Is Project Engineering ~a unit in the 21 Engineering Department?

22

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A Yes, it is.

23 Q

What section is it in?

(A,).

24 l

A It's in the Project Engineering Section.

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25.

.There is two groups'under Project Engineering,

a 1

Walters 18

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2 start-up plants excuse me, operating plants 3

and units that haven't been started up yet.

4 Q

Were your monthly activity reports, 5

while you were a member of Plant Performance 6

Section Services Section, produced in the course 7

of the lawsuit turned over to counsel? Excuse me.

8 MR. KOLB:

Which do you mean?

9 MR. MacDONALD:

I will say turned over 10 to counsel because I don't know whet'ser Mr.

11 Walters will know whether they are produced O.

12 or not.

V 13 MR. KOLB:

Let me say beyond the very 4

14 general questions you inquired about, you 15 put to the witness earlier, I think it is 16 inappropriate for you to be asking specific 17 questions as to which particular documents 18 he may or may not have turned over to 19 counsel as that gets into the whole question 20 of how we have and have not dealt with

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21 particular witnesses and particular documents.

22 This particular question is simply 23 1

the point where I am going to draw the line FN i

24 and I think that if you just keep to_the 25 general and ask questions where we are not L

I walters 19

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2 talking about attorney-client privilege 3

that I will have no problem.

4 MR. MacDONALD:

I don't want to deal 5

in the specifics of what was discussed 6

between the attorney and the client.

What I 7

want to find out is if there are any relevant 8

documents pertaining to this particular 9

lawsuit especially monthly activity reports 10 which we have gotten as of lake before 11 depositions or after depositions, but what I 12 want to find out is whether or not he retains 13 such documents which he testified to and 14 whether he turned them over to counsel because 15 if he did not we sure would lixe to see those 16 particular monthly activity reports regardless 17 of communications that have gone on between 18 counsel.

l 19 I don't want to deal in specifics into I

I 20 each year, but this is general and I want to I

l 21 find out if he indeed turned over these 22 documents.

l 23 MR. KOLB:

.I want you.to understand g

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my objection is not directed at whether you 25' should or should not have access to these v

1 Walters 20 d('N 2

reports, my complaint is only with the 3

phrasing of the question because it calls 4

for the transmittal of the materials, what the

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5 content of the transmittal was between the 6

client and the lawyer.

You can ask the 7

questions in ways that will permit you to 8

obtain the information you are looking for 9

without getting into communications with 10 counsel, I am sure, and I will ask you to 11 do it that way.

12 MR. MacDONALD:

Well --

13 MR. KOLB:

Or in those ways.

14 MR. MacDONALD:

Let's proceed and see 15 where we go.

16 BY MR. MacDONALD:

17 Q

Do you still matain a file of monthly 18 activity reports, Mr. Walters?

19 A

Yes, I do.

20 Q

Have you ever parted with that file f

-21 at any point in time during the last year and a

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22 half?

23 A

Yes.

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q 24 l

Q

.And when was that?

I 25 MR. KOLB:

Just the time..

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1 Walters 21 2

MR. MacDONALD:

Just the time.

3 A

The first day of each year.

4 Q

What happened on che firs t day of each 5

year?

6 A

well, I had a policy of throwing away the 7

previous year's progress reports.

8 Q

In January of 1980, did you discard 9

the monthly activity reports for 19797

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10 A

Yes.

11 Q

Did you maintain any copies of those in rg 12 your files aside from -- you said you discarded a

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13 copy of the '79 progress reports in January 1980.

14 Are there any copies maintained 15 elsewhere in B&W, did you send a copy.of those 16 to the central files?

17 MR. KOLB:

You have asked ~three 18 questions and I would.ask you to break that 19 down.

20 MR. MacDONALD:

Let's start this way:

21' Q

Did you maintain or were there H

4 22 maintained after January 1,

1980 any other copies g

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23 of your 1979 monthly activity reports?

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. *1 MR.'KOLB:

Are you asking about copies 25 within the company or. copies within his own L

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personal file?

3 MR. MacDONALD:

Within his own personal 4

files.

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5 MR. KOLB:

Within his own personal G

files.

7 A

No, I do not have any of the copies of those 8

in my own personal file.

9 Q

Within B&W?

i 10 A

There may ce.

I am not aware.that they are t

11 still retained.

12 Q

By individuals you may have sent the 1

13 monthly activity reports to?

14 A

Yes.

4 15 Q

You did not at the same time you 16 discarded a copy of the monthly activity reports 17 simultaneously or any time thereafter send a copy r

18 to central files for filing purposes?

19 A

No, I don't believe I have ever Aent a copy 20 of my progress reports to central files.

21 Q

In January of 1981, did you discard 22 copies of your 1980 monthly activity reports?

i,

23 A

Yes, I did.

f-24 Q'

Were any copies maintained in your 25 files?

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Walters 23 1

2 A

No.

3 Q

Any sent to central files?

4 A

No.

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5 Q

The only ones that might exist would 6

be ones that other people who received copies of 7

those reports have retained?

8 A

That is correct.

9 Q

The only activity reports that you 10 currently have within your files a r'e the copies 11 of the reports since January 1,

19817 12 A

That's true.

13 Q

If you wanted to find copies of your 14 prior monthly activity reports, previous. years, 15 where would you go?

16 MR. KOLB:

I will object as to form, 17 but he can try to answer the question.

18 A

I would go to the person-that I sent a copy 19 of those progress reports t o'.

20 Q

Would that be Mr. Hallman?

21 A

Yes.

1 22 Q

Would there be anyone else who you

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23 sent copies of those progress reports'to?

g 24 A

No.

25 Q

Were these monthly activity reports,

L I-1 Walters 24 i -

2 1979 monthly activity reports, you discarded in.

3 January of 1980 after you received a directive 4

to maintain TMI related documents?

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5 A

I don't remember specifically.

6 Q

Do you have any general recollection?

'7 Ai No..

8 Q

In January 1981, when you discarded 9

1980 monthly activity reports, do you know whether this was after you received.any directive regarding 10 a

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- mainton'ance of TMI related files?

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12 A

Yes.

Ow 13 Q' '.

Had you aiready received before January 14 1981 tNe directive to maintain TMI related files?

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t l5 A

Yet.

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16 Q

But aft'er January 1,

1980?

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17 Ai I don't recall exactly when I received the M

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.,. document R,to re tain the' files.

1

,1 10 Q,

But youdid receive it before January 1,

1981?'

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91 A

~Yes.

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lO activitiy reports for 1980-that related to TMI

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Iy there any material _in your monthly

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24 or.i'ssubs that would affect TMI?

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MR. KOLB: TMI generally or the TMI-2 l

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2 accident?

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MR. MacDONALD:

No, TMI-2 generally.

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.i MR. KOLB:

So that would include the C.

5 accident?

6 MR. MacDONALD:

It would include-the 1

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w o u l'd a f f e c t the 177 fuel assembly plant.

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Q l >When you said "possibly," what 13 a

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generically to 177 FA plants?

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Well, I only meant that since I worked on the

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.23 Q

Does your section, your prior section, qh]i

)

i I

i g

eJ.

" f C/

r44

.r excuse me, Plant Performance Services maintain any s

, _" 4 hk.

^$

.i. 'y' 1-

,.+

25 common files or shelf files of any sort in your

>g a

i~

lQ

^

m Q}ry) f '\\, d -

\\

't 1

Walters 26

[-R J.

2 work area?

3 A

Yes, we do.

4 Q

What do those files contain?

5 A

Well, the most files of the group's work 6

is contained in the Nuclear Service Library.

7 Documents produced by us.

8 Q

Is that all documents produced by 9

individuals within the Plant Performance Section?

t 10 A

Major documents, not memos, that type of 11 references.

g-12 Q

Will you make the distinction what C]/

13 you mean by major documents as opposed to memos?

14 A

Well, major documents is the responsibility 15 of the group of writing specific test procedures, 16 test specifications,-that's what I am talking 17 about as major documents.

18 Q

Draft operating procedures, tech 19 specs, documents like that?

20 A

Yes.

(

21 Q

What else aside from the things that i

i 22-you and I have.just mentioned are maintained in

'i l

23.

these shelf files?

I k-24-A Well, I have subject files in my own desk 25 and I have my own file cabinet that had subject-i 4

r n.

<~

n

1 Walters 27

• O

\\_J.

2 files in them.

3 Q

At the time that you turned over i

4 documents to counsel, did you go through your 5

files yourself and look for material to turn 6

over to counsel?

7 A

Yes, I believe I did.

8 Q

Did you look at all your files during l

9 the course of that review?

10 MR. KoLB:

I will object as to form.

11 A

I don't recall whether I went through all 12-ny files.

I am sure I looked through the files and s

s 13 responded with the ones that were that I thought 14 were TMI related.

l 15 Q

Did you review all your subject 16 files?

17 A

I don't recall.

~

18 Q

Do you maintain any subject files 19 that-are generically applicable to all 177 FA 20 plants?

21 A

Yes.

22 Q

Did you review those files?

23 j

MR. KOLB:

Are you referring to all of

(

24 them?

l 25 MR. MacDONALD:

All the ones that he

1 Walters 28 f~%

N_ -

2 maintained that are generically applicable 3

to 177 FA plants.

4 A

I don't remember if I looked at all of them.

(~

5 Q

Did you look at some of them?

6 A

Yes.

7 Q

~ Which ones in particular, can you 8

recall, that you looked at?

9 A

Files of information of data, memos, that 10 related to the TMI-2 accident that g had in my 11 possession.

12 a

Q So when you reviewed your files, you 13 specifically looked for documents that related to 14 the TMI-2 accident?

15 A

Yes.

16 Q

Did you look for any other material 17 that related to TMI-1 or 2 that did not relate 18 specifically to the accident on March 28th, 19797 19 A

I believe I have.

I don't recal1 specific 20 documents.

21 Q

Did you indeed turn over documents to 22 counsel other than documents that related just i

23 specifically to the TMI-2 accident?

(

)

24 A

I have.

v.

25 Q

Did you receive ~any monthly activity L

l 1

Walters 29

,y NJ

^

2 reports from anybody in the GP Section during 3

the time you were a supervisory engineer?

4 A

Yes, I received reports on the engineers

(

5 that worked for me.

6 Q

How many engineers worked for you 7

during the course of time that you were a 8

supervisory engineer in GPS?

9 A

Six to eight.

10 Q

At any given time there were six to 11 eight?

12 A

Yes.

- ("%

(_)

13 Q

Did each one submit to you monthly a 1

14 monthly activity report?

15 A

Yes, they did.

16 Q

These were in writing?

17 A

Yes.

~

18 Q

Did you then review these monthly 19 activity reports and incorporate some "of their 20 subject matter into your monthly activity report 21 that.you sent on'to Mr.'Hallman?

(

22 A

.That is true.

23 Q

Did you maintain copies of the monthly e

(

24 activity. reports that yere sent to you by the m

.25 engineers who. worked for you?

a,

p p

1 Walters' 30

-f 2

A No, I did not.

3 Q

Did you maintain copies of those 4

reports for any length of time after you received

{)

5 them from the engineers?

6 A

Generally it may be a month, until the next 7

progress report was due.

8 Q

And then you discarded that former or 9

. prior progress report?

10 A

That's correct.

11 Q

As of January 1981, did you, when 12 you moved from Supervisory Engineer in PPS to b) i-13 Project' Engineer in the Project Engineering 14 Section, at that point in time maintain or have 15 any activity reports from the engineers who 6

16 reported to you in PPS?

17 MR. KOLB:

Would you read,the question

~

18 back, please.

19 (Record read.)

~

20 MR. KOLB:

I will object to the 21 question because I think it is unclear what i

22 point in time specifically you are referring l

I 23 to.

-s

[J')

24 MR. MacDONALD:

I will try to rephrase 25 it.

r

++y 7

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-y 9

m--

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F 1

Walters 31

'AU 2

BY MR. MacDONALD:

3 Q

As of January 1981, did you maintain 4

or have in'your possession any activity reports (4

5 from any of the engineers who reported to you in 6

the PPS Section?

7 A

I don't recall that I did.

8 Q

Do you maintain a daily diary or any 9

sort of daily log of your activities at B&W?

10 A

Not specifically daily diary.

11 Q

Do you maintain a diary or a log of 12 your activities at B&W?

O.

13 A

Yes.

14 Q

How long have you maintained such a 15 diary?

16 A

About three years,

'78 to

'80.

'17 Q

During the time that you were a 18 Supervisory Engineer in the Plant Performance 19 Services section?

20 A

That's correct.

21 Q

Do you maintain copies of this diary 22 after year's end?-

23.

A Yes.

t.

~~

' g(v) s 24 Q

Do you currently have copies of your 25 diary for time periods since you became a men 6er i

l

1 Walters 32 2

of the Plant Performance Services Section at 3

B&W7 4

MR. KOLB:

Would you repeat the

(

5 question, please.

6' (Record read. )

7 A

Yes, I do.

8 Q

What kind of entries, as a general 9

matter, do you make in this diary?

10 A

Usually things that I wanted'to keep 11 for my own future reference for specific meetings 12

-that might occur throughout the building on 13 specific subjects or problems-that occur during 14 the year.

15 Q

Do you keep notes in your diary of 16 what occurred at meetings?

17 A

on a case-by-case basis.

18 Q

Do you keep.a record of who attended 19 meetings that you were.present at?

20 A

That's correct.

21 Q

Time.and place of those meetings?

22 A

Yes.

23 Q

The subject matter?

j y/

24 A

Yes.

25 Q

Did you review this diary during-the

I walters 33 gs l

2 course of your review of documents in relation

'3 to this lawsuit?

4 MR. KOLB:

I object as to form

(

5 again and let me state the objection so you 6

understand this time.

You are assuming 7

there is one review.

8 MR. MacDONALD:

0.K.

9 MR. KOLB:

I take it that some of 10 the questioning and the answers earlier b-11 pertained to Mr. Walters' review on a prior i

12 occasion.

That's-my objection.

He can 0

13 try to answer the question a stated, but 14 I will have to object to it as to form.

15 You might read it back so he has it 4,

l 16 in mind.

17 MR. MacDONALD:

I will rephrase it.

18 BY MR. MacDONALD:

i 19 Q

'At any point in time since'the TMI-2 20 accident, have you reviewed your daily diary

'21 to glean whether or not there are TMI related 22 activities that you were involved.in that you 23 recorded in your diary?.

.~ 24 A

Yes, I have.

-kf 25 Q'

Did you turn that material over to e

+,

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=or-

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I 1

Walters 34

^.

G}'.

2 counsel?

3 MR. KOLB:

Again, I object because 4

that goes into the specifics of what

(

5 materials were turned over to counsel and I 6

would simply ask you to find another way 7

to get the information you are searching 8

for.

9 MR. MacDONALD:

I think that what we 10 are dealing with here is documents that 11 should have been or were produced, you 12 know, in the course of this litigation.

O 13 I think that I am perfectly within my 14 rights to ask what documents he turned 15 over.

16 I am not getting into the substance

~

17 of any conversations that may'have occurred

/

18 between counsel and Mr. Walters,' just 19 whether'or not he turned over an'y documents 20 that related to a specific subject.

.21 MR. KOLB:

Your good intentions are 22 not in question.

You have to make your 23 inquiry about matters which are not

( j),.

24 confidential and not a matter of 25 communication between.the attorney and L

.i

1 Walters 35 s

v 2

client and I am sure you can get this 3

information that you are looking for 4

without getting into the communications

(

5 between the attorney and client.

6 so that you are not being obstructed 7

in any way from getting what you want, you 8

are simply being asked to keep away from 9

communications between counsel and client.

10 MR. MacDONALD:

Well, I am asking 11 only to the extent that there were documents 12 that Mr. Walters produced or turned over

[\\

\\/

13 in the course of his review for production

'14 in a lawsuit.

15 I don't see many other ways I can 16 get to Mr. Walters to find out whether he 17 turned over material and documents.that 18 may or may not be relevant in tbis particular 19 lawsuit.

I 20 MR. KOLB:

Of course, you can ask 21 him questions as to what he did, up to the 22 point where you get to counsel's 23 communication, and then you can inquire of

-( }

24 us, I suppose.

25 MR. MacDONALD:

I just

1 Walters 36 2

MR. KOLB:

That's ~ a different 3

question.

4 MR. MacDONALD:

Yes, I can do that

(

5 obviously, but you are not sitting in the-6 chair right now being deposed.

7 MR. KOLB:

Yes, I am simply pointing 8

out there are other ways in getting the 9

information.

10 MR. MacDONALD:

Not fro,m Mr. Walters.

11 MR. KOLB:

You don't have to get 12 everything from Mr. Walters.

/~h 13 MR. MacDONALD:

Well, et me just 14 ask you then if in fact material that i

15 related to the day of the accident or l

I 16 any other TMI related material that was 17 in Mr. Walters' diary was in' fact produced 18 in the course of the lawsuit?

19 MR. KOLB:

I would at this point like 20 to just have a moment with Miss Chatman 21 and Mr. Walters.

Maybe we can just step 22 out a second.

I think we can help you 23 shorten this.

A) t, 24 MR. MacDONALD:

Fine.

v-25 (Witness and counsel leave the

F r

1 Walters 37

't L.-

2 examination room.)

3 MR. KOLB:

I wanted to take a moment 4

to inquire to be certain that my statement

(

5 was going to be correct for the record.

3 6

First of all, the files of Mr. Wciters 7

have been examined either by counsel or by 8

Mr. Walters on more than one occasion 9

which was the reason I interjected my 10 objection earlier.

11 We have been trying both with Mr.

12 Walters and with other witnesses as counsel m

)

/

13 to try to be certain that full compliance 14 with your document production was had.

15 In connection with the book, the 16 diary, as it has been described Mr. Walters 17 testified about a moment ago, that we additional documenbs with us 18 brought some 19 today because we found such documents, 20 they are not voluminous and we would like 21 to have them stamped in the fashion that's 22 become acceptable in the case and turn them 23 over to you,'that would be done, I think, no

. [~')

24 later than tomorrow morning and certainly

's./

'25 well before you have to conclude your

(

1 Walters 38 2

examination of Mr. Walters.

The material 3

is not voluminous.

That, as far as we 1

4 know, based on our own review and Mr.

(

5 waiters' review, gives you averything you 6

have asked for.

7 If there is anything that turns up a

8 that you should have gotten by virtue of 9

any further questions assuming it's 10-appropriate that we do so in gelation to t

11 your request, we will go back and look for 12 it again but we have made a significant

("'

13 effort here to try to be certain that for I

14 this deposition as soon as we could you 15 had all the necessary materials.

16 MR. SELTZER:

Can we just go off 17 the record for a second?

18 MR. KOLB:

Yes.

l

~

l 19 MR. SELTZER:

Off the record.

I 20 (Discussion off the record.)

L 21 BY MR. MacDONALD:

(.

22' Q

Mr. Walters, did you ever write a-f-

23 memo to Mr. Hallman after the TMI-2 accident-that I)

'24~

recounted your lessons learned from TMI?

l-,A s i.

I 25 A

I don't -believe I did.

1 Walters

~39 w(

2 Q

Were you ever asked to write a memo 3

recounting any e valuation of yours of the TMI-2 e

i -

4-accident?.

l 5

A No, I wasn't.

t 6

Q Did you ever write any memo relating 7

to that. subject matter?-

8 MR. KOLB:

Relating to the acci' dent?

9 MR. MacDONALD:

An evaluation of the 10 accident.

l 11 ~-

A' Yes, I wrote a memo evaluating the 12 accident.

' O' 13 Q

When was that written?

14 A

In

'79.

Somewhere around May, I believe, a

15 of

'79.

16 Q

What was the substance of that 1

17 evaluation or memo?

1 18 MR. KOLB:

Are you-asking him to 2

19 characterize the memo?

20 MR. MacDONALD:

No, what it contained 21 substantially.

23 MR. KOLB:

Subjects treated, that kind 23 of thing?

...p)

(

. 24 MR. MacDONALD:

And any more detail

'25 he can recall'about it.

l

0 1

Walters 40 2

MR. KOLB:

I think as to detail the 3

memo will speak for itself.

4 MR. MacDONALD:

Let's deal with the

(-

5 subject first and then we will go on from 6

there.

7 A

I wrote a memo that was eventually a 8

scenario of events that occurred during the TMI-2 g

accident.

10 Q

Were you asked to write.,such a 11 scenario by anyone?

12 A

No, I wasn't.

O

\\s/

13 Q

Who did you send this scenario to, 14 if anyone?

15 A

I don't remember the specific names on the 16 memo.

It was addressed to Mr. Hallman.

17 Q

Do you know whether that evaluation 18 or scenario was included in a report o'r any draft 19 reports by a committee of B&W called the Technical 20 Review Committee?

21 A

I do not have knowledge. that it was.

22 Q

Have you ever heard of the Technical 23 Review Committee?

[^/)'

24 A

Yes.

25 Q

Do you know who was on that Committee?

1

o 1

Walters 41 2-A No, I don't.

3 Q

Have you ever' read any of the reports 4

that were generated by that committee?

l 5

A I don't recall that I have.

6 Q

Have you ever produced any documents 7-for that committee or for any member of the 8

committee?

9 A

I am not sure since I don't remember the 10 specific people'or recall the specific people that 11 were on that committee.

12 Q

You don't know of anybody that you

\\/

13 can recall today who was on that committee?

14 A

The only person that pops in my head 15 was Russ Ball.

.16 Q

Who was Mr. Ball?

17 A-He was the Manager of R&D related activities 18 or something of that nature.

19

'Q Did you ever meet with Mr[ Eall or 20 any'other members of the TRC at any~ point in

- 91 time?

22 A

I may have, but I don't recall.

23

'Q Did-you ever generate any other memos 24 ~

.or documents after the TMI-2 accident which

. 25 -

discussed '-the accident or the -cause of the s

L

1 Walters 42 t'~#

2 accident?

3 A

Yes.

4 Q

What are those documents?

(

party to the development of 5

A I was part 6

B&W's sequence of events document o r of the 7

accident.

I. wrote some chapters in there, I 8

believe.

9 Q

was that sequence of events document 10 prepared under your direction?

t 11 A

The latter one?

12 Q

The one you are speaking about.

.g 13 A

No.

14 Q

Was the first one that you spoke of, 15 the scenario, prepared under your direction?

16 A

Yes.

17 Q

A moment ago you said y6u,may have 18 met with Mr. Ball, but you don't recall.

19 Why did you answer "I may have"?

20 A

I remember meeting with Mr. Ball at some 21 time, but I don't recall when.

It was sometime 22 after the accident.

i' l

23 Q

What do you recall of the subject

('~%

24 matter of that meeting?

- Ns)

- 25

'A He was asking about the data acquisition

=-

. =.

I waiters 43 2

system that was running at the time of the 3

accident, the-B&W react, so-called reactimeter 4

system, and was wanting some general and specific

(

5 information about that data acquisition system.

6 Q

And what was your response during 7

that discussion?

8 A

The best I recall I related what the equipment g

was, how it performed, that it was a highspeed 10 data acquisition system and something generally a

11 to that nature.

12 Q

Did you do anything after the O

T's 13 discussion in relation to the subject matter that was discussed?

14 15

<A I don't recall.

16 Q

In relation.to the second sequence 17 of events that you have discussed, who was in 18 charge of preparing that?

~

19 MR. KOLB:

I am not sure I' understand 4

20 what that question means.

21 would you read it back, please.

C.

22 (Record read.)

23 MR. KOLB:

Can you be more precise

(')'\\

34' when you say sequence of events?- I am not 25 sure what you mean.

1 Walters 44 2

MR. MacDONALD:

I think Mr. Walters 3

has stated that there was a document that 4

he was involved in producing that involved

(

5 a sequence of events of the TMI-2 accident.

6 I want to know if he can tell me who was in 7.

charge of producing.that particular document.

8 MR. KOLB:

So it's the document you are 9

referring to?

10 MR. MacDONALD:

Yes, t

11 A

The person that I know, that I reported to, 12 was a Mr. Ken Schroeder, I believe his name is.

\\ ')

13 Q

What is his position at B&W?

14 A

I don't know.

15 Q

What was his position then?

16 A

I don't know that.

17 Q

Who else was involved in,this effort 18 for the production of this document?

19 A

There were various people withid B&W.

I 20 don't recall their names at this time.

21 Q

Do you recall anyone else who was 22 involved?

23 A

I believe there was a Mr. Sun from our

(

n L (a) 24 Alliance Research Division, 25 Q

What did you understand that h

1 Walters 45

(

2 Schroeder was responsible for at that time, at 3

the time of the production of this document?

4 A

To try to piece together from available

(

5 information what was or what had been the 6

scenario of events or the sequence of events 7

during the TMI-2 transient.

8 Q

When this document was produced, do 9

you know whether or not it was included in any 10 report that was generated by the Technical Review 11 Committee?

12 A

I do not know specifically how the 13 information was used or reported.

14 Q

Do you know generally whether or 15 not this sequence of events was used in any of 16 the drafts or final versions of the Technical 17 Review Committee report?

18 A

I do not know what the final Technical 19 Review document or report was.

It may'have been, 20 but I do not know what they produced.

21 Q

In your resume marked GPU Exhibit 22 126 for identification your education has BSNE.

23 Is that a bachelor of science in

'. p]

24 nuclear engineering?

.g.

25 A

That is correct.

l t

,+

1 Walters 46 i

'f~h 1' (_)'

2 Q

What areas of concentration did you 3

study or have in North Carolina State College 4

regarding your BSNE?

.(

5 A

Specific background in nuclear reactor 6

physics, some additional work in nuclear 7

instrumentation and general physics and 8

thermodynamics as most colleges, engineering 9

degrees offer.

10 Q

That pertained specifically to 11 nuclear reactors?

12 A

Yes.

't O

\\

- 13 Q

Courses that might have included.

14 or did include subject matter on core cooling and 15 heat transfer and -- those two specifically?

d 16 MR. KOLB:

Is the question whether-17 they did include those subjects, not might 18 have?

19 MR. MacDONALD:

They did. ^

20 A

To the best of my recollection, they did.

21 Q

Have you ever taken any other post 22 graduate courses or attended seminars or lectures i

l 23 since your graduation from North Carolina State l

[)

24 College?

(./

i L

25 MR. KOLB:

Could we have that

_ =

4 1

Walters' 47

- (. U/.

2 question read back so we can have that list 3

of items in mind.

4 (Record read.)

(

5 A

Yes.

6 Q

What specifically were those courses 7

or seminars or lectures?

8 A

The seminar was on nuclear rocket 9

propulsion.

10 Q

Was this during the time you were

~11 at Brown Engineering?

12 A

That's correct.

OV 13 Q

Were there any other courses or 14 lectures or seminars that you participated in or 15 attended since your graduation from North 16 Carolina state College?

17 A

I haven't attended any others..

18 Q

None since you were employed by 19

- B&W?

20 A

That is correct.

21 (Continued on following page.)

-22 23

[w')

24

. 25 L

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f.: '

L 1

Walters 48 Q

You came to B&W in 1969 and in 2

]s 3

February of 1969 until September 1971, you were 4

Performance Engineer in the Steam Generator

(

5-Group of Component Engineering; is that correct?-

6 A

Yes, it is.

7-Q How did you receive your assignment 8-to that section?

9 A.

That was the initial hiring location within 10 B&W when I came.to work for them, t

111 Q

Why:-did you leave Brown Engineering?

12 A-Because the aerospace industry funding and N'

~

13 all was running out and I was looking for future

-14 w rk.

15 Q

How did you come to be employed by 16 B&W7 17 A

As best I remember, I received ~an employment

~1g application from a recruiter, local r[cruiter.in-19 Huntisville, Alabama that a B&W. repre s e'ntative w uld.be in touch and he wanted to talk to me.

20 21 Q

On the basis of that, did you go and

. speak to the representative and then you1were 22<

23

. hired by-B&W7

~

A I did.

24 25.

Q What-were the duties:that you performed

1 Walters 49 O

2 as Performance Engineer in the Steam Generator 3

Group?

4 A

Initially, it was familiarization with the

(

5 B&W steam generator as a Test Engineer.or an 6

Assistant Test Engineer on tests that were run 7

at the Alliance Research Division on performance 8

of the steam generator and compilation, reduction 9

of that data into a couple of documents within 10 B&W Company.

11 Q

Did you ever do any analysis or have 12 occasion to study other manufacturers' steam 13 generators in the course of your work with the

[4 B&W Steam Generator Group?

15 A

I don't recall that I had any detailed 16 information on other vendors' s te am gene rators.

17 Q

Was there anybody within t.he group that or studies?.

18 did perform such analysis 19 A

I believe there was, yes.

~

l' 20 Q

Do you know who that was?

A I don't recall his name at this time.

og

~

(J on Q

Was he an engineer?

A Yes.

23 I

('~)}

24 Q

Did you report to him?

]'

't.

A No.

25 w

~

1 Walters 50 (J~).

l 2

Q Did he report to you?

3 A

No.

4 Q

Was it part of the responsibility of

(

5 the Steam Generator Group to review site problem 6

reports that were associated with steam generators?

~

7 A

I don't recall.

8 Q

Did you do any such review?

9 A

Not at that time.

10 Q

Did you have any occasion at all 11 during the course of time when you were a 12 Performance Engineer in the Steam Generator Group

(\\

13 to review or read site problem reports?

14 A

I don't recall.

15 Q

You don't recall having reviewed any?

16 A

That's correct.

17 Q

what were the two documents that you 18 just referred to that you helped compile during 19 the course and time when you were a Performance 20 Engineer in the Steam Generator Group?

A I don't recall-the exact names of the 21 22 documents or the numbers of them.

One of them had 23 to do with the performance testing of the integral

[s) 24 economizer generator.

)

s.

25 The other one had to do with the accelerated

V 1

Walters 51

-[ )

s

\\_/.

2 fouling test run on the 90 tube blue model of 3

3 ARC.

4 Q

Are you aware of any differences in 5

the B&W once through steam generator from other 6

steam generators employed by other manufacturers?

7 A

Yes.

8 Q

Is it a fact that the water capacity 9

of the B&W once through steam generator is less 10 than Westinghouse's steam generator'?

11 A

Yes, I believe that's correct.

12 Q

From September of 1971 until December 13 of 1972 your resume reflects that you were an 14 engineer assigned to write test specifications 15 and train operators in various aspects of startup 16 physics testing.

17 were you at that point in time also 18 still a member of the Component Engineering 19 Department?-

r 20 A

No, I wasn't.

21 Q

What section or unit or department were 23 you'in at that point in time?

23 A

I transferred to the Nuclear Service r

A j\\

34 Department.

25

.Q Was there a section within Nuclear i:

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Walters 52

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m

'2

. service that you were ' assigned to at this point

.in time?-

a 3

oc 4

A Yes.

I am trying to recall the name of it.

(

5 something like Operating Reactors Section 6_

or something like that.

i What were yo3K-duties and 7

Q

.s; IS responsibilities in that'section aside from what u

(9 is reflected on your resurte?

1 3 4

tk:

io A

I believe the only' additional activity was 11 that I was assigned to the B&W data acquisition q

s

.. c tYE 12 system that wes'were or would employ in the startup

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13

.of the power plants once we started them up

-N 14 and I was.becoming familiar with this system so

.i 15 when we were able to use,it',- u would have s

'16 knowledge of it.

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17 Q

What did tpeysystem entail?

5-s, s

Sp Ige A '.

It was a high data. acquisition computer l

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3 jg.J drjven system and also-calculated reactivity i~n wt s

4 q.

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st.e g re that we would.use.during physics s tartilp m,

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~g testing.

o 2o Q

Wys it'only. designed for use during.

. o,3 physics s $:' art up testing?.

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-A That's correct.

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Has it been utilized since that time-x i

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for any other_ purpose aside from physics startup

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' )(.ys s te 57 Q.

'And what is that?

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' Essentially, as a plant transient monitor Ii

.,6-If 77 {-

i. to catch data during unforeseen trips or transients.

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^

Q What was your involvenient with this 8

i

.l/'hroject?

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r /.y it

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,1 01

'A The data acquisition system?

'It was built

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. ( ;j it llby our Research Division and I had taken the g,

1 i'

12

. system, become familiar with it, understood what i

13 it did and how we would interface it with the 14 utilities information system to be used during a 15 normal startup testing of that particule.r unit.

16

-Q Did you write any procedures or any 17 other documentation to be used by utilities 18 relating to this data acquisition system?

~

19 A

I believe I did prepare an operating r

20 procedure for that piece of equipment.

21 Q

In y ur resume it has the phrase " train C

22-operators."

23 What specifically were your tasks

,. x (a) 24

. relating to training operators during the time 25 that-you were an engineer 1in the operator Reactor m

1 Walters 54 O

2 Section?

3 MR. KOLB:

Just so the record is 4

elear, it says " train operators in various

(

5 aspects of startup physics testing."

It 6

doesn't just say " train operators."

7 The witness can answer the question.

8 A

I had occasions to instruct the operators 9

in what the normal reactor core physics testing 10 consists of and how we would operate the plant 11 during these physics testing once we started up 12 that unit and to present them to specific

(~)T

~ \\_

13 operating methods that they would be called on to 14 do throughout the operation of the core.

15 Q

Was that training done at the utility 16 or at B&W7 17 A

It was done at B&W.

18 Q

How many such training sessions were 19 you involved in?

20.

A Probably more than 10, 10 to 20.

21 Q

Did you engage in a training session 22 for each startup that you were involved in?

23 MR. KOLB:

Is the question whether

^/ );

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24

'there was a single training session for 25 each startup?.

y w

--,-e.,,

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1 Walters 55 2

MR. MacDONALD:

Was he involved in 3

training sessions for each startup that 4

he was involved in.

(

5 A

I don't understand the question.

6 g

Let me back up.

7 When you said you trained operators 8

in various aspects of physics testing and it i

9 tras done at B&W, startup physics testing, did you 10 perform the training each time a uti11ty was l

11 starting up a nuclear power plant, a B&W nuclear 12 power plant?

C)

\\d 13 MR. KOLB:

I want to be sure we've 14 got the question clearly in mind.

15 Are you asking whether he personally 16 engaged in this activity in every single 17 instance that there was a B&W plant started 18 up?

19 MR. MacDONALD:

Since the dime that 1

20 he was involved as an engineer.

21 Q

How many reactor startups were you 22 involved in at B&W in the time since you have 23 been employed at B&W7 f~}'

Are you talking about L initial startups 24 A

x_/-

25 or initial startups plus restarts?-

1 Walters 56

(~~

\\

2 Q

Let's deal with initial startups.

3 A

Two.

4 Q

What plants were those?

l 5

A Oconee I and Arkansas Power & Light Unit 1.

6 Q

What time period was each?

7 A

The Oconee unit was in early 1973 and 8

the Arkansas unit was a period of two years, 9

abo ut, in 1973 to

'75.

10 Q

Did you perform training of operators 11 in the aspects of startup physics testing 12 for each one of these initial startups?

13 A

I don't recall that I did for either.

I 14 did for some of the Arkansas operators.

15 Q

But not for the Oconee?

t 16 A

I don't recall.

17 Q

Did you provide any training for any 18

'other utility personnel on start up physics 19 testing?

20 A

Yes.

21 Q

For which?

22 A

Florida Power & Light.

I 23 Q

Was that in connection with a specific A

(

l 24 sta'rtup or restart?

x_./

25 A

No.

It was essentially initial prototype 9

Y

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y 4

-<m-w g

1 Walters 57 2

training.

3 Q

Which restarts have you been involved 4

with?

(

5 A

Well, I have been involved in all restarts, 6

in the period of time I was in the Plant 4

7 Performance Service Section, in one capacity or 8

the other.

9 Q

Since February of 1977, that is 10 A

Yes, e

until January 19817 11 Q

12 A

Yes.

("%

(-)

13 Q

Prior to February 1977, were you 14 involved in any plant restarts?

15 A

Not in plant restarts.

16 Q

Will you describe your duties other 17 than training of operators in the aspects of 18 startup physics testing on each of the two initial

~

19 startups that you were involved in?

20 A

My training of operators consisted wholly og o f startup physics testing of the operators in-(.

~

22 the particular sections.

I had no other 23 instructions to carry out at that time.

'(']

24

-Q You had no other duties in relation

%j 25 to those-startups, just' training the operators?

I waiters 58 2

A Yes, in the startup physics testing area.

3 Q

Did you have any other duties regarding 4

the initial startups of these plants other than 5

training of operators?

6 A

Yes.

7 Q

What were those duties?

8 A

The other duties consisted of writing 9

specifications, test specifications, operating i

10 draft procedures that B&W supplied 'as part of the 11 contract to the individual utilities.

12 Q

Did you ever perform any on-site work 13 during any of these startups?

The initial 14 startups I am speaking about.

15 A

Yes, I did.

16 Q

What did that entail?

17 A

I believe it entailed review of the utility 18 procedures at Oconee I,

sometime during the six 4

r 19 or eight months I was there, and writing of and 3

20

. review of specific procedures before the startup 21 at Arkansas.

22 Q

And this was done at the site?

23 A

Yes.

)

24 Q

The draf t procedures that you spoke 25 of a moment ago, how were they prepared?

t

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l 1

Walters 59 l

2 A

I don't recall the specific details of the 3,

draft procedures.

Most of,mine covered the 4

startup testing specifications or test

(

5 specifications.

6 Q

What was the-basis for the test 7

specifications or draft procedures, was there 8

input from Enginnering that underlined the 9

procedure or tes t specification?

10 MR. KOLB:

I know you mean that to 11 be one question but it is really two.

l 12 MR. MacDONALD:

I will break it down.

Og I

f 13 Q

Was there any input from the Engineering 14 Department that you used in drafting the test

~15 specifications or the draft procedures used for 16 startup physics. testing?

17 A

Yes.

18 Q

And what was.that input?

l 19 A

Well, it varied from procedure to procedure 20 but generally consisted of equipment specifications, 91 design specifications for equipment, converaations

'33 with specific Engineering personnel, the PSAR, i

23 preliminary safety analysis reports, plant specific

(

)

'24 drawings, fluid hydraulic drawings known as FHD's

% /

25 the.NRG reg guide on initial startup testing,

1 Walters 60 3

generally that nature of information.

3 Q

Was there anybody else that provided 4

input?

(

5 A

various more senior people within the g

Service Group than I.

7 Q

And what did their input consist of,

'l 8

generally?

9 A

Usually it consisted of reviewing the 10 procedure that I had prepared, making comments on 11 it for my resolution to them or to find out if 12 that in particular was a misunderstanding or was A

k.-)

13 it a corre ct evaluation of what I had written.

14 Q

In the course of your training of 15 operators in startup physics testing, did you 16 work at all with any people in B&W's Training 17 Department?

18 A

Yes.

19 Q

What was your contact with'the Training 20 Department in-the course of the training of those og operators?

33

'A My contacts mainly consisted of questions 23 from'these experienced on how specific portions of the plant operated, for they understood more

.( [

24 about the plant than I did from an operation 25 1

l

. _ - - - =.

1 Walters 61 i

2 standpoint and I was trying to glean information 3

from them that would be bearing on my factual 4

instruction of the operators in the physics

(

5 testing area, since we had to interface closely 6

with the operators to accomplish this physics b

7 testing.

8 Q

Who in the Training Department did 9

you speak with?

10 A

well, it varies over a period of time.

Four 11 names come to mind, and they are a Mr. Goslow, 12 Mr. Herb Smith, Mr. Bill Street and Mr. Phil O

13 Griffin.

14 Q

These were all B&W training 15 instructors?

16 A

Yes.

17 Q

Did you provide any simulation work 18 during the course of your training of operators 19 in startup physics testing?-

20 A

Yes, I believe_we did.

31 Q

Wh at type of simulation work?

22 A

We simulated on the simulator as best we 23

.could, using the data acquisition system that I

[

(em).

23 previously talked about in. interface with the N_/

I-25 simulator for the operator to make the h

..m

I walters 62 OG 2

corresponding manipulations that we as engineers 3

needed to get the data for later analysis.

4 Q

Was the simulation performed in all

(

5 instances for each group that you trained in 6

startup physics testing?

I 7

A I believe it was but I don't recall 8

specifically that it was.

9~

Q Were.you involved in any way in 10 draf ting operating or abnormal emer'gency procedures 11 for Arkansas or oconee I?

12 MR. KOLB:

Would you read the question

, O 13 back, please.

14 (The reporter read back the last 15 question.)

1 16 MR. KOLB:

I will object as to form.

17 I am not sure what you mean by " abnormal 18 operating procedures. "

19 Q

Mr. Walters, do you know what I mean 20 when I refer to ' abnormal operating procedures,"

21_

procedures for abnormal operation?

22 A.

Yes,-I have my opinion on what abnormal 23 procedures we are talking about.

n.

i) 24 Q.

Were you involved-in any way in 25 drafting any operating procedures regarding 4

+

1 Walters 63 f\\

V 2

abnormal operation at ANO-1 or Oconee I?

3 A

I believe I was.

4 Q

What did those procedures entail?

(

5 A

The only ones that come to mind to me right 6

now were at Arkansas, and those were the loss of 7

off-site power and reactor trip, turbine trip 8

procedure.

There may have been others but that's 9

the only two I recall right now.

10 Q

And you drafted those p'ro ce du re s ?

11 A

I don't recall that I drafted the entire 12 document.

I either added to or embellished 13 or took the previous B&W procedure or some outline 14 from Arkansas and produced the document from it.

15 Q

Did you use the Lynchburg simulator 16 at all?

By "you" I mean did you personally 17 operate the Lynchburg simulator during any of 18 these training sessions on startup physics 19 testing.

20 A

Not during startup physics testing, no.

21 Q

At any other time?

22 A

Yes.

23 Q

When was that?

-nI) 24 A

_ Initially, when I came into Service, I had 25 a 10-day training course on the simulator, plant I

a.

... - ~,.

1 Walters 64 S.

(_)

2 2

operations course, that.was, and portions were on 3

the simulator.

4 Q

What did that course entail?

{

5 A

General operation and understanding of how 6

the B&W NSS unit operated under various transient 7

conditions.

8 Q

During the training of the operators 9

on startup physics testing, did the members of 1

10 the Training Department provide the(instruction on 11 the simulator for the utility students?

12 A

Yes.

O

\\/

13 Q

What was your role in relation to 3

14 that?

15 A

Mainly as we would function later on as 16 overall or shift test coordinator to tell the 17 operators what we needed to do when and to offer any 18 advice that was needed for accomplishing of the 19 physics testing.

20 Q

What specifically did you do on the 21 simulator durir.; the course of your training at 23.

the timeLyou came into the Plant Performance i

23.

Service s Section at B&W7 i

-l'j'h e 24 A-s It' consisted of manipulating the. control H

25 rods, drive system, the plant equipment to take i

k.

I walters 65

~

\\f 2

the plant from a cold iron condition to 100 3

percent power and then shutting the plant down 4

to a normal shutdown of the transient.

l 5

Q Did you perform any simulations of 6

any transients at the time you were taking this 7

course on the simulator?

8 MR. KOLBt Would you read the g

question back, please.

10 (The reporter read back(the last 11 question.)

12 A

I believe so.

I don't recall the specifics 13 but I believe so.

14 Q

You don't recall specifically what 15 transients may have been involved?

16 A

Not specifically.

I am sure there were 17 various ones but I don't recall the specific ones.

18 Q

Did you receive anyinstr$ctionon

)

19 the simulator regarding what procedures you 20 should perform during transients in order to be og able to shut the plant down on a normal cold

(_

~

22 shutdown?

23 A

our training, or at the time ~ I was on the

' (%.

( jf 34 simulator, there were normal shutdown procedures 25 there.

I don't remember. exactly how we used them

1 Walters 66 2

or specifics about them.

3 Q

Were you using, during the course of 4

your simulator training, the simulator procedures

(

5 that were developed for the simulator, the j

6 Old Forest Road procedures?

7 A

During this training course, yes.

8 Q

Did you at any point in time ever have 9

any involvement in developing those Old Forest i

10 Road similator procedures as a member of the 11 Plant Performance Services Section at B&W or at any 12 other time in your employment at B&W7 13 A

I believe so.

14 Q

What was your involvement?

15 A

The one that sticks out in my mind was, I 16 believe, I either was party to or reviewed the 17 Present in-place procedure on one called 18

" Reactivity Balance Procedure."

19 Q

What did that procedure entail?

6 20 A

It offers instructions to the operators on 21 how to determine the factors concerning critical I

33 ro ds in the core position, position of the

.33 estimated critical rods for a startup, how to

.af'T 34 -

change Boron concentrations during power L

i 25 operations if it was necessary to do so, and at

1 Walters 67 2

all times I would track the reactivity conditions 3

of the core.

4 Q

Do you know whether or not anybody

(

5 else in the Plant performance Services Section 6

reviewed simulator procedures, the Old Forest l

7 Road procedures?

8 A

I don't recall.

9 Q

You don't recall anybody doing so?

10 A

I don't recall any specifics, procedures 11 and people doing that..

12 Q

Do you recall generally whether anyone 13 in plant Performance Services reviewed or helped

{

14 to write any of the procedures used by B&W on 15 the simulator to train operators?

16 MP. KOLB:

Would you read the question 17 back, please.

18 (The reporter read back the last 10 question.)

20 MR. KOLB:

At what point in time?

31 MR. MacDONALD:

At any point in time 22 that he knows.

23 A

I don't remember when I was Supervisory

[

34 Engineer in the Plant Performance Services Section, u

25 There may have been.

i l

L Walters 68

<~x U

2 Q

At any time before that, during the 3

course of your employment at B&W, where you knew 4

of anybody reviewing or contributing to the Old

(

5 Forest Road simulator procedures.

6 MR. KOLB:

Are you now asking about 7

anyone at all as opposed to confining it 8

to a particular section or group?

9 MR. MacDONALD:

That's right.

10 A

As I remember, when I was initially in 11 the Operating Reactors Group, we did review or 12 people in, that were set around me, reviewed the i

13 procedures.

14 Q

The simulator?

15 A

The simulator procedures.

I mainly think 16 these were in the area of physics testing or 17 startup, shutdown, the reactivity bala,nce 18 procedure.

19 Q

Is there still a section in B&W today 20 that deals with the Operator Reactor Section or 21 is there a section such as that?

22 A

There is still a Plant Performance Services 23 Section, if th at ' s the question.

f 24 Q

The section that you were involved in l

v 25 in 1971 to '72 had the name. Operation Reactor

1 Walters 69

.O, 2

Section?

3 A

Operating Reactors Group or something like 4

that, Section.

(

5 Q

And that is the one that had input 6

in the simulator procedure?

7 A

I think mainly we reviewed the procedures 8

that were written by the B&W training instructors 9

and offered comments of that nature.

As I stated 10 previously, reactivity balance procedure may have 11 be,en written by us.

12 Q

Is that a group that then later O

13 became known as the Plant Performance Services 14 Section?

15 A

Yes.

16 Q

In 1973 to

'75, you were Test 17 Coordinator for initial startup testing on 18 AP&L ANO-1.

19 Were you at that time still in the 20 Operating Reactors Section?

21 A

Administrative 1y, yes.

L 33 Q

And also before that in 1972 and '73 23 when you were First-of-a-Kind Test Engineer,

-[ )

f

-y Assistant Shift Engineer and Shift Engineer for the v

l

^

25 B&w' Advice and consultation Team for oconee I?

}

'l f

l 1

Walters 70 2

A Yes.

3 Q

Then in 1975 to

'77, you became Senior l

4 Engineer in the Mechanical Equipment Section for

(,

5 Nuclear Service, which is a different section from 6

the Operating Reactor Section?

7 A

That is correct.

8 Q

In your instruction on the simulator 9

when you became Supervisory Engineer in the early 10 Part of 1977 in PPS, did it include any training 11 or instruction on going solid?

12 A

Did my training?

?)

2

.13 Q

Yes.

14 MR. KOLB:

Will you please repeat 15 the question.

16 (The reporter read back the last 17 question.)

~

18 A

I don't recall having received any 19 instruction or training during this period of 20 time.

21 Q

You said you took a course at a point 22 in time that you, unless I am mistaken, that you 23 became Supervisory Engineer in PPS and part of

(-

24 that course was simulator training.

That is 25 what I am referring to.

1 Walters 71 2

A I'm sorry if I misled you.

It was the initial time when I came into the 3

Service Group in 1971.

4

(

5 Q

1971-727 A

Right.

6 7

Q Back at that point in time and 8

that was the only training that you had on the B&W simulator?

9 10 A

That's the only formal training I have 11 had, yes.

12 Q

During the course of that training, 13 did you have any instruction on taking the plant solid?

g4 A

I don't recall whether I did or I didn't.

15 16 Q

Were there any occasions during the course of that simulator training when you indeed 17 18 did take the plant colid under simulat'ed conditions?

A I don't recall that either.

19 20 Q

What, if anything, did you understand from that training you had on the simulator

,, g

-(

~

regarding the. advisability of taking a plant solid?

33

[Q :

T' A_

I_ don't recall anything from that specific

.,4 D#*1"1"9 F# 9#8"*

- 25

I 1

Walters 72

[ }

\\_/

2 Q

Prior to the TMI-2 accident, when 3

did you learn, if you did, anything regarding the 4

advisability of taking a plant solid?

('

5 A

Would you repeat the question?

6 MR. MacDONALD:

Please repeat the 1

7 question.

8 (The reporter read back the question 9

as requested.)

10 A

In general terms, it was my o' pinion or --

11 MR. KOLB:

The question is when, 12 if at all, not what your opinion was.

13 MR. MacDONALD:

Is that stated in the 14 form of an objection?

15 MR. KOLB:

I th.'nk he was clearly 16 going over and answering something you 17 hadn't asked.

18 A

I don't remember when I became specifically 19 aware of that particular action.

20 Q

What do you understand regarding 31 the advisability of taking a plant solid?

33 MR. KOLB:

I will object as to form.

23 Q

Prior to TMI, what was your

/~.

(}

24 understanding of the advisability of taking the

- 25 plant solid?

r y

i r

4 -

1 Walters 73 2

MR. KOLB:

I will object as to form j

1 3

again.

4 A

I understood that it was something that 5

I understood myself that it was something that 6

should not be done unnecessarily.

7 Q

What do you mean when you say t

8 "unnecesaarily"?

1 r

9 A

That action is, operator action is, or I

t 10 what I had understood that this was not something 1

11 that you wanted to normally do with a power 12 plant.

, O 13 (Continued on page 74.).

14 15 16 I

17 1

18 19 l

20 22 T

23 A

..V 24 25 t

I

i~

1 Walters 74

(~

(

2 Q

Why was that not advisable?

3 A

simply, basically because you lose pressure 4

control over the system when you do that, in the

(

5 normal manner.

6 Q

what happens as a result of losing 7

pressure control?

8 A

It depends on the specific transient 9

or the specific scenario as to what would 10 actually happen.

-11 Q

From what did you develop your i

12 understanding that it was not advisable to take

('~\\

13 the plant solid?

i 14 MR. KOLB:

I didn't hear him testify 1

15 that way.

I think his testimony was more 16 specific than that and as to his 17 understanding the record speaks,for 4

18 -

itself.

19 If you would like to sk him how he 20 formed that understanding, that's a fair 21 question, but let's not recharacterize L

22 his testimony.

23 MR. MacDONALD:

The record does I

>s

~

speak for itself, but I am. going to ask him.

l

(

)

24 t

N/

25 g'

What_did you develop from your F

I T

t T

m

1 Walters 75

\\~

2 understanding on the advisability of taking a 3

plant solid?

4 A

Other than the loss of pressure control

(

5 I had, over the years, a great deal of 6

conversation between general people, general 7

persons that I come in contact with, some 8

probably being operators, and over a period of 9

time I had also I thought were realizations 10 that there was very certain that operators or that 11 I understood this is something you were not 12 doing indiscriminate 1y and for various reasons.

(~',

(_)

13 Q

Did you gain this understanding 14 through conversations with people in B&W's 15 Training Department?

16 A

It may have been.

I am sure I discussed --

17 had discussions with them in the early portion l

18 of time.

19 Q

Was there anybody else you had 20 conversations with regarding taking the plant 21 solid?

(m 22 A

None that I can recall specifically.

23 Q

Can you recall anybody that you had 24 discussions with in a general manner?

25 A

No.

1 Walters 76

(~ / '

\\-

2 Q

Prior to THI did you have any 3

understanding taking the plant solid could 4

create problems with vessel mechanics?

(

5 A

I remember having making -- having made 6

such a statement, yes.

7 Q

And when was that?

8 A

In the latter part of

'77.

9 Q

What was the basis for that statement?

10 A

It was a memo drafted by me to a Mr. Joe 11 Kelly.

12 Q

What was the basis for the proposition

[ ')

\\_-

13 that it might create problems with vessel 14 mechanics to take a plant solid?

15 A

It was based on my concern of whether or 16 not if we took the plant solid that we would ever 17 pressurize it, cause ensuing stresses in the 18 vessel or piping or steam generators,'and, 19 therefore, cause a loss of generation'~or down 20 time for the specific utility involved.

21 Q

How long had you held that belief (L.

22 with regard to the vessel mechanics regarding 23 taking the plant solid?

' f ')-

24 MR. KOLB How long before he made v

^

'25 the statement to Mr. Kelly?

1 Walters 77

/~N t

)

2 MR. MacDONALD:

That's right.

3 A

I don't recall.

4 Q

Would there be any other problems

(

5 associated with taking the plant solid?

6 A

sure, in certain instances, I have stated 7

a loss of pressure control as a' possibility, 8

also I thought at the time that there was a 9

possibility we could cause unnecessary LOCA's 10 by going solid in the system.

e 11 Q

What knowledge or training did you 12 have that created that concern in your mind 13 N/

13 regarding vessel mechanics in late '77?

14 A

I have no specific training in the area 15 of brittle fracture or vessel mechanics or stress 16 analysis.

17 Q

Did you have any concerns that led 18 you to believe that there was a problem with 19 vessel mechanics if you took the plant ~ solid?

20 A

Not specifically, no.

21 Q

Had you asked anybody within B&W 22 to do any analyses or had any analyses been 23 performed that led to your opinion that there 1

f w) 24 could be a problem with vessel mechanics if

(\\_)

25 indeed a plant w taken solid?

.~

a 1

Walters 78

-]

2 A

I was not aware of any if they existed.

3 Q

You hadn't seen any?

4 A

No, I hadn't.

(

5 MR. KOLB:

Off the record.

,6 (Discussion off the record.)

7 BY MR. MacDONALD:

8 Q

Was there anything in particular that 9

triggered this belief that you had regarding a 10 problem in vessel mechanics if indeed a plant was 11 taken solid?

12 A

No.

I used those terms, vessel mechanics,

(._/'

13 purely in relation to an overpressurization of 14 the system and in what the ensuing problems would 15 be if that had occurred.

16 My first impression was as far as 17 paperwork in getting that utility's reactor

~

18 back into operation if that indeed occurred.

19 Q

But you had no personal kn'owledge or 20 concerns gleaned from discussions or anything 21 that you had read at B&W that would have led you 22 to form that understanding?

23 MR. KOLS:

Read the question back,

[

24 please.

25 (Record read.)

1 Walters 79

/~N

\\~#'

2 A

I had read nothing that said that there 3

would be a vessel problem, vessel mechanics 4

problem, from an overpressurization.

(

5 Q

Had anybody informed you that there 6

would be such a problem?

7 A

Not that I recall.

8 Q

Or could be such a problem?

9 A

No, no one had informed me of that.

p 10 MR. MacDONALD:

Off the record.

11 (Discussion off the record.)

12 (Recess.)

?

13 BY MR. MacDONALD:

14 Q

Will you describe your duties as 15 First-of-a-Kind Test' Engineer between 1972 16 and 19737 17 A

On the Duke Oconee I unit.was B,&W's

^

18 -

first prototype unit to go in operati$n.

As a 19 part of the initial startup testing th'ere was 20 various first-of-a-kind tests for that unit 21 that had to be performed and I had the 22 responsibility for seeing that'the instrumentation 23 was installed and the data was taken, analyzed

[;.

24 and sent back to B&W Lynchburg in this particular NJ 25 case.

t

s -,

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'A I

Halters 80

'.'N p

~

2

-p As an Assistant Shift Engineer in the

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I f

$s same startup project, what were your duties?

4 F

,7;

_.4 A

cI was assisting the Shift Engineer which x,

.(j 5

'we were there as advising and consultation to e

1.

s.

1',

6 the D t... e Power Shift Engineer, Shift Tes t people 7

for'an'[a'osistance that th'ey might need during 1

r i

8 startup.

r 9

Q You w'ere on site, in other words?

i 10 A

Yes.

t i

i-11

J Q

Did you spend time in the control

{

12 i room?

- O i

13 A

Yes.

I 14 Q

During startup?

15 A

Yes.

16 Q

What types of duties did you perform 17 in that role-in the control room?

18

'A.

As a Shift Test Engineer?

19 Q

-As an Assistant. Shift Engineer.

20

.A I--

this was during the startup testing, 21 physi'es startup testing, zero power physics testing.

As I said, to offer any advice and 23

. consultation to the Duke engineers or to the

. 24 Duke operators.if~ questions were. asked, my

- 25

- main. function.was to be aware of what data was

~

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1 Walters 81 2

being-taken, how it was being taken and as soon 3

as we got to a stopping point to analyze such 4

data along with the Duke engineers for comparison 1

l 5

to prediction data.

6 Q

And as shift Engineer for the advice i

7 and consultation team, what were your dut._es?

8 A

Then I took over a particular shift and had 9

an assistant working for me and e s s e n ti ally * *.le 10 same type of work, but now it is from the Lead 11 Engineer on the shift.

i

. 12.

Q Was the B&W Advice and Consultation i

N 13 Team utilized in any other startups aside from

- 14 Oconee I?

15 A

B&W engineers were utilized in other 16 startups.

17 Q

Was it part of an Advice and 18

~ Consultation Team?

19 A

No.

. 20 '

Q, Was-this the only time that an Advice 21 and Consultation Team for an initial startup

- (..

22' was put together by B&W?

23 -

A'

'No.

)l

' 24 g

What other instances?

~

25 A

-A11 initial startups had a: B&W Advice and 4

4 y

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,,y

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I Walters 82 n

2 Consultation engineer at the site.

3 Q

Were you involved in that Advice 4

and Consultation effort in any other instances

(

5 other than Oconee I?

A' No.

6 i

7 Q

As Test Coordinator for initial 8

startup testing at AP&L ANO-1, you didn't perform 9

that same function as you did at Oconee I?

'10 A

No.

t 11 Q

What were your duties as Test 2

12 Coordinator at AP&L?

A s-13 A

well, the main difference is that at Duke 4

-14 the initial startup activity was advice and 15 consultation in the NSS contract.

16

.At Arkansas I provided many of the 17 same duties with other leadership roles, but

~

18

.this was.on a master service contract to the 19 particular-utility.

, 20 Q

And what-did your duties as Test 21.

Coordinator entail?

22 A

.I had around five to six engineers, B&W 23 engineers, that reported to.me that would be-Ii 24, Shift Engineers and Data Analysis Engineers,.once.

5/

25-we started the unit.up, and'had overall s

y-

I walters 83 A

r i

G 2

responsibility reporting to their Plant Nuclear 3

Engineer for the collection of the test data, 4

running the tests, seeing that the analysis,

(

5 on-site analysis, was done and any problems that 6

were -- that came up were reported along the chain 7

quickly or to be aware where problems could occur 8

and advise management that certain tests were 9

going to be performed at different times, just a 10 general coordination of the test program.

11 Q

Did you have any on-site 12 responsibilities as Test Coordinator?

(~%

\\-

13 A

I was on site.

14 Q

You were on site.

As a Senior 15 Engineer in the Mechanical Equipment Section of 16 Nuclear Service, what were your duties?

17 A

Generally to find solutions to any problems 18 that were coming in from the units at startup, 19 -

talk with the Enpineering Department, find the 20 resolution to the'particular problems that were 21 either coming in by phone or by our site problem 22 report, if a solution had to be had very quickly 23 to try.to turn it around and get that back to the p).

24 site operations manager at each of the sites.

3x_/-

25 Q

Did you review as part of your job as-

1 Walters 84

/"T V

-2 Senior Engineer site problem reports relating to 3

the units that you were involved in startup on?

4 A

I may have.

I don't recall specific ones.

(

5 Q

In general, did you make it part of 6

your routine to review those site problem reports?

7 A

Not in general, no.

8 Q

Only when they came to your attention?

9 A

That's correct.

10 Q

Who would send them totyour attention?

11 A

Usually one of two sources, either the 12 very small section that handled SPR's, logging, 13 categorizing, and then sending them out or 14 for my immediate supervisor, Mr. Ken Ellison at 15 that time.

16 Q

What section or unit or department 17 was responsible for categorizing or~ 1.ogging 18 those SPR's?

19 A-It was part of the Operating Plant 20 Section of Nuclear Service.

21 Q

That Operating Reactor Section that 22 you had been in?

i 23 A

No, rs

(

)

24 Q

This was an Operating Plant?

-25 A

An Operating Plant Service Section I believe i

i

I walters 85

()

e 2

is what it is called.

3 Q

How often did you receive site 4

problem reports from the Operating Plant

(

5 Service Section when you were a Senior Engineer 6

in the Mechanical Equipment Section?

7 A

I don't. recall any specific time period or 8

the amount that came in per day or per week or 9

per month.

10 Q

Did they come immediate1y to your 11 attention or were they routed to you by someone 12.

else in the department?

ss 13 A.

They were routed-to me usually by Mr.

14 Ellison.

15 Q

Mr. Ellison, did he also route'the o

IG SPR's to anyone else within the Mechanical 17 Equipment Section?

18 A

very possibly, yes.

19 Q

would it depend on what th'e SPR was 20 related to?

21 A

That's correct.

'22 Q

Did you receive the SPR's that dealt 23 with startup?

[N 24 A

Yes.

h..

25 Q

Did you receive any other SPR's?

1 Walters 86 2

A I believe they all dealt with startups.

3 Q

what other SPR's were reviewed by people 4

in the Mechanical Equipment Section?

-((

5 A

well, just generally SPR's that had to do 6

with our supply equipment, hardware, and any 7

problems with that.

8 Q

Did you review any SPR's relating to 9

any reactor trips?

10 A

I don't recall of any during'.the time I was 11 in this specific section.

12 Q

Had you reviewed any prior to the m) 13 time that you were in this specific section?

\\

14 A

Yes, I had reviewed the trips when I was 15 at oconee I and also at Arkansas when I was on 4

16 site.

17 Q

Did you review all of the,SPR's 18 relating-to reactor trips when you were on site 19 at Oconee?

20 A

I don't believe I reviewed all of them, no.

21 Q

was it part of your-job function to 22 review the SPR's.when you were on site at Oconee?

23 A

onlysin.the aspect of understanding what

'(')

24

-had happened and to be aware, if there was

~.s 25 something that came out of that particular report

{

i

1 Walters 87

'"I 2

that we didn't already know or was not expected 3

or some specific piece of information like that.

4 I did not have responsibility, if that's what T

(.

5 you are inferring, for reading every SPR and 6

communicating that along to somebody.

7 Q

But you had responsibility for 8

reviewing that'to determine if there was t

9 something that may have related to the startup 10 of Oconee I?

(

11 A

only in the function that would help me do 12 my job better as a startup Test Engineer.

13 Q

Would all the information relating 14 to reactor trips have been relevant to your job as

.15 a startup Test Engineer?

16 MR. KOLB:

Relevant'in what sense?

~

17 MR. MacDONALD:

In the sense that 18 he referred to it as part of his job 19 performance to know what went on'at Oconee 20 I.

.21' A

Not specifically to the startup physics 22.

testing, only in that it would make me more 23 informed, a startup Test Engineer.

[)k; 24 Q

At Arkansas Power & Light did you

\\

25

. review'SPR's as a general' matter?-

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Walters 88

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A Yes.

3 Q

What types of SPR's did you review?

4 A

well, usually I reviewed them as a function

(

5 so that the Master Service Team would know that 6

the B&W team was sending an SPR back to Lynchburg,

-7 the general information that was in it.

8 Q

Did you review all SPR's that related 9

to Arkansas Power & Light?

4 10 A

I don't know that I reviewed 1.it each and 11 every one.

12 Q

Was it part of your job function to 13 review those SPR's?

14 A

only in that again that I would -- was aware I'

15 if I had not been on shift or not on site the day 16 it happened or something, that I was aware of a 17 trip, what the nature.of it was and did it impact 18' my test program or was-it as a result of it or 19 that type of information.

~

. 20 Q

Were you on the routing of any of 21 the SPR's that might have been generated at 22 Arkansas Power & Light that were not on your-shift?

' 23 A

I would usually see a copy of them, yes,

['

'24 at'some time,'right.

%)

25 Q

Is the same true'for Oconee?

.a.

1 Walters 89 2

A If I took it upon myself to look for them, 3

I would see copies of most of them.

4 4

Q When you became Senior Engineer in

(

5 the Plant Performance Services Section of the 6

Nuclear Service, ws.o was in charge of the Nuclear 7

Service Section?

8 MR. KOLB:

Is that a precise i

9 description?

10 THE WITNESS:

No.

(

11 MR. KOLB:

I don't think you 12 precisely describe'd'his role. I wish you 13 would restate the question.

14 MR. MacDONALD:

0.K.

15 BY MR. MacDONALD:

16 Q

When you bece,me Supervisory Engineer in 17 the Plant Performance Services Section, Nuclear 18 Service

~

19 MR.-KOLB:

0.K.

i t

20 MR. MacDONALD:

That's what I thought 21 I said.

Excuse me.

who was in charge of the Nuclear-22 Q

L 23 Service Department?

t

- -(( ]\\

24 A

I'believe it's Mr. Andy Olds.

x 25 Q

Wha'.fis Mr. Olds' position-today?

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3

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1 Walters 90 2

A I believe he is Manager of Field Engineering 3

and Services of the Customer Service Department 4

today.

(

5 Q'

Is that a section of Customer 6

Service?

'7 A

Yes.

8 Q

Is Plant Performance Services a 9

section?

10 A

No, it.would be a unit.

It consists of 11 several sections.

i.

12 Q

So you would call that a unit.

In 13 the hierarchy at B&W, I had thought that it went 14 unit to section to department.

Am I correct?

15 A

That section, his section consists of d

16 various units.

17 Q

Who replaced Mr. Olds as Manager of 18 Nuclear Service?

~

19 A

Mr. Dick Kosiba is presently thi Manager 20 of Customer Service.

21

.Q It is now called Customer Service?

k[

22 A

Yes.

I M.

Q_

Is Field Service another.name for

.[')

24.

Nuclear. Service?

~~../

25 A

Yes.

1 Walters 91

'~'

2 Q

When did Mr. Kosiba take charge as 3

the manager of nuclear or Customer Service?

4 A

To the best of my recollection, it was in

(

5 1979.

6 Q

Do you recall whether it was before 7

or after the TMI-2 accident?

8 A

I believe it was slightly before.

9 Q

What was Mr. Kosiba's position before 10 he took over as the Manager of Nuclear Service?

11 A

I don't recall.

12 MR. KOLB:

Would this be a good time 13 to break for lunch?

14 MR. MacDONALD:

Sure.

15 (whereupon, at 12:35 p.m.,

a lunch 16 recess was taken.)

4 17 18 19 i

20 e

22 23 i

. p;.

(d.

l 25

1 92 2

AFTERNOON SESSION 3

2:05 p.m.

4 00o

](

5 JAME S FRAN K L I N WA L TE R S 6

having been previously duly sworn, was 7

examined and testified as follows:

8 EXAMINATION (Continued)

J 9

BY MR. MacDONALD:

10 Q

You are aware, Mr. Walters, that your 11 testimony continues under oath this afternoon?

12 A

Yes, sir.

13 Q

As Supervisor Engineer in the Plant 14

_ Performance Services Section of the Nuclear Service 15 Department, what were your specific duties?

16 A

I was responsible for seeing that the 17 contract documentation for each of the reload 18 cores from B&W to the utilities was cEmpleted 19 and sent to project management who del'ivered it 20 to the particular utility involved.

This 21 consisted of mainly the physics test data and 22 any changes to tests, methods in the core testing 23 that would occur on that particular reload.

(

24 Q

Are you responsible for anything Aj} -

25 else within Plant Performance Services aside

f 1

Walters 93

/~h~

V 2

from this reload function?

3 A

Yec.

The group as a whole is responsible 4

for any changes to operating procedures, draft

(

5 operating proceduren that were supplied by B&W 6

to utilities.

I think generally that's the two 7

basic functions of the group.

8 Q

When you say "of the group, " you 9

mean of the Plant Performance Services Section?

10 A

Right.

t 11 Q

Did you also prepare plant limits and 12 precautions?

\\-

13 A

No.

14 Q

Plant set points?

15 A

No.

16 Q

Technical specifications?

17 A

We would review some suggested, tech specs 18 every once in a while th at Engineerinh trould 19 send around for' review and comment onf but we did l

20 not actually prepare them.

31 Q

Who did you send your comments to l

22 after you reviewed them?

23 A

I.believe the Licensing Department acted i

L 24 as a focal point to get all the comments.back 28./

25 and then redistribute-them to the Engineering r-L-

1

'l 1

Walters 94 2

Department or who had ever written them to 3

begin with.

4 Q

Did you review any of the limits

(

5 and precautions?

6 A

Yes, I have reviewed the limits and 7

precautions documents.

8 Q

Was that a part of the function of' 9

the Plant Pe r fo rnianc e Services Section?

i-10 MR. KOLB:

Do you meantwas it part of 11 the function to read the document?

12 MR. MacDONALD:

To review the

(~

\\

13 document.

~-

14 Q

Limits and precautions.

15 A

Let's say we would review it for our 16 particular area, that being the core operation 17 if there was anything in there on that, but not 18 as a general rule, the whole document, no.

~

19 Q

You testified that you yourself have 20 reviewed limits and precautions?

ol A

I have reviewed the document at some k.

22 time in the past.

23 Q

Do you recall when?

[ ll 24 A

Well, probably early on before I went or

~_./.

25 while I was at either'one'of the two sites.

g

- + - -

+p-9-M-T

'M-

1 Waltors 95 t)

2 Q

And the two sites would be Oconee 3

or Arkansas Power & Light?

4 A

Correct.

(

5 Q

Were the limits and precuations 6

generic to all 177 B&W plants?

7 A

The document was, yes.

4 8

Q So your review would have been 9

applicable to any B&W 177 plants?

10 A

In general.

11 Q

After your review of the limits 12 and precuations, was there anything that you O

.i\\

)

s/

13 did as a result of that review?

Did you pass 14 comments on to anybody or have discussions with 15 anyone?

16 A-If that had been warranted.

I don't 17

.romember any specific times that may have occurred.

18 Q

You stated that Plant ~ Performance 19 Services was responsible for preparation of draft 20 procedures.

21 Have you been involved in the l

22 preparation of draft operating procedures?

23 A

We are talking about the pre-TMI-2

/ 8

( ;

24 accident?

25 g

Yes, prior to TMI-2.

1 Walters 96 t

<~

2 A

Yes, early on, very early.

/

3 Q

when was that?

4 A

When I went into Service.

I think I was

(

5 involved in like the normal operating procedure 6

for heatup and cooldown and plant operation, 7

those three specific documents.

i 8

Q When was that?

9 A

Sometime in

'71,

'72,

'73, that time frame.

10 Q

Did you participate in drafting 11 procedures in your position as Supervisory 12 Engineer in PPS?

/"'S)

(m.

13 A

Yes, if the if we had the ch'ance to 14 do so, to perform this function.

I don't remember 15 us having -- I mean I don't remember a specific 16 procedure we had written in the last couple of 17 years.

.18 Q

Have you had occasion to review l

19 procedures, draft operating procedures ^ prepared 20_

.by others in the Plant Performances Services.

l L

21 Section?

l 22 MR. KOLB:

Could I hear the question l-E 23 again, please?.

i

(f g:

24 (Record read.)

(

r I

25; A

What time period are we ~ talking about?

__. -.,... ~ -, _..

1 Walters 97

\\~'

2 Q

Let's start pre-TMI.

3 A

I don't recall any specific ones, but I am 4

sure somewhere along the line I did.

(

5 Q

Who within B&W is responsible for 6

preparing draft operating procedures to be sent 7

out to operating utilities?

8 A

I believe the Plant Performance Service 9

Section would have that responsibility.

10 Q

Is there anyone withintPPS, 11 specifically, who has that responsibility?

12 A

Not a specific individual, I don't believe, 13 no.

14 Q

Is there anyone who was in charge 15 of preparing the draft operating procedures?

16 MR. KOLB: In the same organisationi 17 MR. MacDONALD:

Within PP,S.

18 A

Yes, as far as administrative cbntrol there 19 is.

20 Q

Who would that be?

21 A

well, it would depend whether or not it 22 was a startup-plant or an operating plant.

If it 23 was an operating plant, I would have the

("D 24 responsibility-for seeing that the work was-x1 25 finalized and sent out.

Early on there was a

1 Walters 98 2

startup group that would have the responsibility 3

fo r the initial procedures.

I would have 4

essentially revisions to the initial document

([

5 if they were to be sent out.

6 Q

who was in charge of the startup 7

unit in PPS prior to TMI?

8 A

Ron Finnin, I believe.

9 Q

So prior to the TMI-2 accident your 10 unit within PPS was in charge of dr.afting 11 operating procedures for B&W7 12 A

Yes.

13 Q

What was the process by which draft 14 operating procedures were prepared within your 15 unit of PPS?

16 MR. KOLB:

During what time period?

17 MR. MacDONALD:

During the time 18 period prior to the TMI accident.

19 MR. KOLB:

At any time while he was 20 in the unit?

21 MR. MacDONALD:

While he was Supervisory

.k 22 Engineer.

23 MR. KOLB:

All right.

- (

24 A

Well, during that period of time it probably

')

LJ 25 would' apply to the revision.

I don't recall any 1

1 Walters 99 n],

N_ -

2 new procedures that came along.

3 There is B&W policies and procedures 4

that outline the format of the documents, what

(

5 type of information might be researched te go 6

into these documents, a hierarchy of signoffs, 7

the writer, the reviewer, reviewed by Engineering 8

and then distribution to the Project Managers.

9-Q Who were, from the time you were 10 Supervisory Engineer up to the time of the TMI-2 11 accident, the people who had to sign off on the 12 draft operating procedures?

O\\--

13 A

well, the reviewer -- the preparer within 14 the Service Group, a reviewer in the Service 15 Section which might be an engineer, that reported i

16 to me or myself, and then a parallel review by the 17 cognizant engineering group on that~ p, articular 18 system or procedure or operating procedure.

19 Q

Was there a special sectiAn within 20 the Engineering Group that dealt with signing 21 off on the draft operating procedures?

22' A

At one time there was.

I don't remember 23 specifically when it was formed.

i

)

24 Q

What do you think now?

xs 25 A

The. Plant Integration Group of Engineering.

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1 Walters 100

\\~

2 Q

They were the ones who signed off 3

for the Engineering Department?

4 A

Yes.

(

5 Q

on the draft operating procedures?

6 A

Yes.

7 Q

Who was in charge of Plant Integration 8

prior to the TMI-2 accident?

9 A

I believe Mr. Bruce Karrasch was.

10 Q

Is he still in charge of that section 11 today, do you know?

12 A

No.

13 Q

Does such a section ex st?

14 A

By name, no.

15 Q

Is there still today a group in 16 Engineering that normally signs off on draft 17 -

operating procedures?

18 A

Yes.

19 -

Q

'What group is that?

~

i 20 A

It's called Plant Performance Engineering.

21 Q

Who heads that group?

22-A Mr. Ed Kane.

23 Q

Was there anybody.else who is required

()

24 to sign off on draft operating procedures prior

- \\J 25 to TMI-2 before they were issued to the v

e g

sm, e g

~ - <

1 Walters 100-A

[\\

2 utility?

3 A

I don't recall that there was.

4 (Continued on following page.)

6 7

8 9

10 11 12

/')

(j 13 14 15 16 17 18 19 20 L

21 l

C 22 23 f) 24 v

25

4 1

Walters 101 l'

k_ -

2 Q

What revisions and operating procedures 3

did you participate in as Supervisory Engineer 4

prior to the TMI-2 accident?

k 5

A The only one I recall is a power operation 6

procedure.

7 Q

What was the substance of the change in 8

that procedure?

9 A

It dealt with the mode of operation of a 10 B &W core essentially.

We have two modes of 11 Operation, a' boron chem shim mode of operation 12 and a rodded mode of operation.

Some of the O

\\l 13 units sold _were of one mode and some were of the 14 other mode of operation.

As time went on, most 15 of the plants that were operating rodded changed 16 to the all-rods-out mode of operation.

When that 17 happened, we revised the procedure that had been 18 sent to them initially to include the other mode

-19 of operation in it.

20 Q

During the course of your employment 21 at Supervisory Engineer in PPS, was it also part of 22 your job function to review SPR's?

23 A

Not a primary function but I have reviewed

[,') ~

24 the'SPR's-from time to time.

~

25 Q

Did you review SPR's on a regular 4

. - + -, -

--m3 3

1 Walters 102 2

basis?

3 A

No.

4 Q

Was there anyone within PPS who was

-(

5 charged with the review of SPR's?

6 A

I don't recall that there was.

7 Q

Was there anybody in PPS who reviewed 8

SPR's on any regular basis to determine if 9

they were applicable or should be adopted into 10 draft operating procedures?

11 A

I don't recall.

12 Q

You don't recall that there were any?

I x>

13 A

I don't recall any specific instances.

14 Q

Do you recall generally whether or not 15 there was anybody within PPS who regularly reviewed 16 the SPR's to see whether or not the operating 17 plant experience which they contained.was 18 applicable to the draft operating procedures that e

19 were prepared by PPS?

i 20 A

I don't recall that anybody other than 21 specifically on my group would have had that 22 responsibility but I don't recall.any specific 23 people doing that or person doing that.

l'

(

24 MR. MacDONALD:

Please read the answer 25 back.

1 Walters 103 A

'N 2

(The reporter read back the answer.)

3 Q

Are you saying there was nobody 4

apecifically assigned within PPS to review

(

5 SPR's to see whether they were applicable to any 6

draft operating procedures that were sent out 7

from PPS to the utilities?

8 A

There was nobody assigned on a regular 9

basis as a matter of everyday job to do that 10 that I'm aware of.

t 11 Q

Did SPR's get reviewed on occasion 12 by people within the Plant Performance Service 13 Section?

14 A

Yes, from time to time they were reviewed.

15 Q

Were those reviews performed as a 16 result of an SPR being routed to PPS by some 17 other'section or unit or department'within B&W?

18 A

Generally, yes.

19 Q

Did anyone from the Plant' Performance 20 Services Section receive SPR's on a regular basis?

21 A

I am not aware that anyone did.

23 Q

When they were routed to PPS, was there.

23 any unitsor department within B&W that generally

./#~}

34 was-the. initiator of the routing?

L

(_/

25' A

. What specific group did the routing?

1 Walters 104 Lk f~

1 r

2 Q

That's correct.

3 A

Yes, there was a small group of people in 4

Operating Plant Services that received them,

(

5 catalogued them and then routed them to a defined 6

list of people.

7 Q

Was there a set of SPR's kept in the 8

Plant Performance Service Section files?

9 A

Not in the Plant Performance Service Section.

10 Q

Was there a set kept by.any individual 11 in PPS of the SPR's?

12 A

I'm not aware of any individual having a set O

13 of them.

14 Q

Did the Operating Plant Service Section 15 have the responsibility to review the SPR's or 16 just to catalogue them and then route them along?

17 A

I think they did both.

18 Q

Prior to the TMI accident who was in 19 charge of the Operating Plant Service Section?

20 A

I believe it was a Mr. Jim Phinney.

~

21 Q

When you received, when anyone within 22 Plant Performance Services received a copy of an 23 SPR, what was the responsibility of PPS in terms

(,)k :

t

24 of analyzing or acting upon the SPR?

25:

A

_If we.did receive ~such an SPR, our major t-m y

t3r 1

m-t--t-3 T

9-

-9

I Walters 105

-A-

.'d 2

responsibility was to see if what had happened or 3

the particular problem, how it impacted plant 4

operation or control of the plant.

If it did,

(

5 then we would try to get with the particular 6

engineering organization that was most aware of 7

this particular problem or the piece of equipmen't 8

or whatever it was and see if indeed there was 9

some problem that needed correcting.

10 Q

I thin't you have testified that you 11 had personally reviewed SPR's while you were a 12 Supervisory Engineer at PPS; is that correct?

bl

\\-)

13 -

MR. KOLB:

I don't want you to ask 14 him what his prior testimony was.

That 15 speaks for itself.

If you want to ask him-16 the question,just for context, that is all 17 right but let's not put it in~ terms of what 18' the prior testimony was.

19 MR. MacDONALD:

I am asking him if.

~

20 that's correct,-as'to the question.

'21-MR. KOLB:

As I say, I don't object

.22 to your asking in this instance, even though 23 it may be different from the prior question,

- [')

24 but I don't want you asking hi.a in terms x_A

25_

of prior testimony.

1 Walters

-106

(~N 1

,A/

2 BY MR. MacDONALD:

3 Q

You have indeed reviewed SPR's as a 4

Supervisory Engineer in the Plant Performance

(

5 Services section; correct?

6 A

I have reviewed SPR's from time to time.

4 7

Q In the course of reviewing an SPR, 8

do you have a normal procedure that you follow?

9 MR. KOLB:

Are you asking whether he 10 followed a normal procedure at the time 2

11 when he did this?

12 MR. MacDONALD:

When he reviewed the (m /

13 SPR, did he have a normal procedure that 14 he went about in terms of the review.

15 A

I don't recall if I followed or if I had 16 a specific procedure in mind when I revi,ewed those 17 documents or not.

18 Q

What did you generally do ' hen you w

19 received an SPR?

~

20 A

I read the problem, tried to understand what 21-the problem was, either myself or if I assigned 22 it to one of the engineers working for me would 23 go down and talk with Engineering or go to

{a~'}

34 Engineering.and talk with them, see if they had 25 already received a copy of it and were working on

E 1

Walters 107 f^%

2 it and was there a reason to effect a change or 3

some document operating procedure in our case the problem still under investigation.

4 or was

(

5 Q

The Plant Performance Services 6

Section, was that located in the same physical 7

building as the Engineering Department?

8 A

Yes.

9 Q

Were they on the same floor as members 4 -

10 of the Engineering Department?

11 A

No.

There are two floors in the building 12 and Engineering is on both floors.

So there is

[h k/

13 more than one floor.

14 Q

So Plant Performance Services, the 15 personnel who made up Plant Performance Services i

1 l

16 we re on the same floor as some members of the i

17 Engineering Department?

18 A

As some members of the Engineering Department.

{

19 Q

Generally, if you have a problem 20 understanding an SPR, would you seek out someone 21 fr m the appropriate Engineering Section whom you 22 thought had the expertise in that field to discuss 23 -

the problem with?

m.

,,)

24 A

Yes.

25 g

If the information in the SPR related

1 Walters 108 O

2 to an operating procedure, were there others 3

within Neclear Service that you_also talked to 4

regarding the issue as a general matter?

{:

~5 A

In the general context of doing my job, I 6

probably would consult other people within the 7

service organization, yes.

l 8

Q Anybody specifically?

9 A

Well, the only people that I have in mind 10 are ex-Training. people that I would contact from 11 time to time to supplement my understanding.

t 12 Q

Who were those ex-Training people?

N 13 A

I don't remember all of their names.

14 Q

Who would be some that'you.can recall?

15 A

I think the ones I have related to in the 16 past, Mr. Goslow, Mr. Smith, Mr. Street.

17 Q

Any others that you can recall?

l 18 A

Those are the-only three I remember.

r

~

19 Q-Why would you speak to these gentlemen 20 in particular, because they had some experience 21 in the Training Department?

+

22

'A That was the primary. reason, yes.

23 Q

What would that add to your i

l (.

2p understanding of the problem?

25 A

Well, I.was. seeking information to' reinforce-t k'

1 Walters 109 f\\

\\, /

i 2

my own thinking or to see that I was correct or 3

incorrect in'my present thinking.

Another avenue 4

of information.

i(

5 Q

You would go to these three 6

individuals to provide you with input on what 7

the Training Department would indeed have g

experience on regarding the issue that had arisen 9

in the SPR?

10 A

I don't-know that it ever occurred to me It that they were giving me information that the B&W t

12 Training Department was passing along.

It was 13 more like I knew they were ex-Training people and g4 I knew their quality of understanding and I went 15 to them to see that what I understood was what 16 they understood.

17 Q

But the reason you sought.them out 18 was because of their background in training of 19 operators?

A Yes.

20 ng Q

Are there any instances that you can 22 recall when you spoke to the ex-Training people 23 regarding an issue that had arisen in an SPR?

4

(

24 MR. KOLB:

Are you asking whether he 25 can recall an instance that'he read an

r 1

l 1

Walters 110 2

SPR and then went and talked to them?

3 MR. MacDONALD:

That he spoke to these p

4 three individuals concerning an issue that

(

5 had arisen out of an SPR.

6 A

I don't recall at this time any specific 7

instance.

8 Q

Did you speak to anybody in the g

Training Department itself at any point in time 10 regarding issues that may have arisen as a result 11 of your reviewing an SPR?

12 MR. KOLB:

When you say "at any point O

13 in time" 14 MR. MacDONALD:

Prior to TMI.

15 A

I may have.

16 Q

Can you give me the instances that 17 you can recall?

18 A

I don't recall any specific instances but 19-it would not be unlikely that I did not talk to 20 them.

21 MR. KOLB:

Will you read the answer 22 back.

23 (The reporter read back the an swe r. )

A

()

24 Q

Are you saying that you have spoken 25 to Training Department personnel regarding issues

1 Walters

.j j j

- /~N t

)

%/

2 that had arisen out of the SPR review?

4 4

3 A

That is certainly possible, yes.

4 Q

Who in the Training Department would

(

5 you speak to on this subject?

6 MR. KOLB:

Are you asking if he has 7

an actual recollection of conversations 8

with people?

9 MR. MacDONALD:

A general recollection 10 of doing it, who he spoke to.

11 A

I don't recall any specific people at 12 specific times.

I mean, certainly it would change O

13 over a period from 1971 to

'77.

14 Q

In the time from 1977 to the TMI 15 accident, we re there people whom you would speak 16 to in the Training Department regarding issues 17 that arose out of a rr iew of an SPR?

18 A.

If I did during this time, I think the 19 person's name is John Lind, I believe.

l 20 Q

L-i-n-d?

21 Was he the lead instructor for the l

f 22 Training Department at this point in time?

)

l i

i 21 A.

I don't remember.

He was at some point in j

(~N l~

t, )

24 time in there.

j j

25 Q

We re there any other people within the i

r 1

Walters

.112

.O 2

Training Department whom you spoke to regarding 3

any issues on a regular basis?

4 A

Possibly but I certainly don't remember any

(

5 specific cases or individuals' names.

6 Q

Did you ever have discussions with 7

Norman Elliott, J

8 MR. KOLB:

Is this now confin'e d to the 9

same period or at any time?

10 MR. MacDONALD:

Generall,y.

11 MR. KOLB:

Do you understand?

The 12 question is whether you ever spoke to 13 Mr. Elliott.

14 A

I'm sure I spoke to him at some time, yes, 15 Q

Did you have occasion to speak to him 16 in relation to re' view of SPR's or issues that arose 17 out of SPR's?

18 A

I certainly don't recall any issues or times.

19 Q

Is the Training Department also 20 located within the same building as Plant f

og Performance Services?

22 A

Yes.

23 Q

The whole Nuclear Service Department-

[ ')

24 is located within that building?

25

.A Yes.

'l 1

Walters

.113

' O

\\d' 2

Q And the whole Engineering is located 3

in that building?

4 A

In two buildings.

Two buildings that are

(

5 adjacent to each other.

6 Q

Just to back up and run something by, 7

I thought you said before there were two floors 8

and Engineering was on both. floors.

9 Is that all confined within one 10 building?

t 11 MR. KOLB:

Is your question whether 3

12 when he was speaking of two floors before

. (N

(,)

13 what he was speaking of was all in one 14 building or is your question whether or 15 not Engineering is all in one building?

16 MR. MacDONALD:

I had thought, perhaps 17 I was wrong, I had spoken of it.as one 18 location.

19 Q

You said two floors.

All k am trying 20 to find out is whether or not it is one building i

21 that Engineering occupies two floors in, and where 22 the Nuclear Service Department is also located, or 23 whether it is two b uildin gs ?

(~

24 A

I think we there refer to the old and the

(_;}

25 new building.

1 Walters 114

' (u~')

2 Q

Are they conne cted?

3 A

Yes.

4 Q

What are your present duties as

(

5 Projects Engineer in the Projects Engineering 6

Unit?

7 A

They are twofold, part of my duties are the 8

licensing aspect of each reload for, in my case, 9

SMUD and TECO, Toledo Edison for reloads, any 10 problem or any dealings with the NRC that come 11 up in a licensing connection; the other aspect is 12 I am assigned specific projects from time to time o

13 that usually have been asked for by the' owners '

14 group or a specific utility for engineering 15 support or work to be done by the B&W Engineering 16 Department, an d I coordinate scheduling, manpower, 17 resources to get Engineering or engineers to work 18 on certafn projects to effect a solution and pass-

~

-19 the solution on as a memo or report or whatever 20 to the Project Managers who then send it to the

-21 utilities, i

22 Q

What specific or special projects have 23 you been involved in since January 19817

[

24 MR. KOLB:

Just in general?

l

%/

25 MR. MacDONALD:

Subject category areas.

?

l 1

t

1 Walters-115 f~)

\\g 2

A Steam generator tube rupture transient 3

is one area that we have offered a proposal to the 4

utilities to do some work; the other area is a

('

5 matter of brittle fracture or thermal shock of 6

the reactor coolant system.

l 7

Q In your pr esent position, do you have 8

engineers that report to you directly?

9

.A No.

10 Q

Whom do you report to directly?

11 A

I report to the Senior Project Engineer,

,i 12 Mr. Bob Baker.

f') -

%)

1 13 Q

Who is the Manager of the Project 14 Engineering Unit?

15 A

Mr. Ken Suhrke.

16 Q

And Mr. Baker reports to Mr. Suhrke?

17 A

That's correct.

18 Q

Have there been any changes since 19 the TMI-2 accident in the Plant Performance 20 Services section in regard to.the procedure for 21 drafting instructions to be sent to the sites?

22 MR. KOLB:

Would you read the question 23 back, please, Mr. Reporter.

(

24 (The reporter read back the last 25 question.)

1 Walters 116 2

A I don't recall any.

3 Q

So up until the time that you left 4

the Plant Performance Services Section in January

(

5 of 1981, the procedure remained much the same 6

as it had been prior to the TMI-2 accident?

7 A

That's what I recall, yes, sir.

8 Q

Were the sign-offs basically the same 9

after the TMI-2 accident in terms of who was 10 required to sign off on the draft operating 11 Procedures as before?

12 A

Essentially.

The group changed from C%

13 Integration to Plant Performance Engineering but 14 essentially the same.

15 MR. MacDONALD:

I would like to mark 16 as GPU Exhibit 127 for identification, a 17 memo from Don Hallman to PPSS personnel, 18 dated July 30, 1979.

~

19 (Memo from Don Hallman to PPSS 20 Personnel dated July 30, 1979 was marked 21 as GPU Exhibit No. 127 for identification, 22 as of this date.)

23 Q

Is this a copy of a memo that you 24 sent out for Don Hallman in or about July 30, 1979 25 in the regular course of business?

1 Walters 117 b-

\\)

2 A

Yes, sir.

3 Q

Is that your signature, "i.

3.

L 4

Walters for D.

F.

Hallman" at the bottom of the

(

5 page ?

6 A

Yes.

7 Q

Did you author this document, GPU 1277 8

A No, I did not.

9 Q

Was Mr. Hallman unavailable to sign 10 the document and you signed it for"him and sent 11 it out?

12 A

That must have been it, yes.

13 Q

In the first sentence,.the document 14 reads, "All future instructions to operating 15 plants concerning how the plants should be operated 16 during normal or abnormal conditions must be 17 reviewed by Training prior to customer transmittal. "

18 was this a new procedure that was 19 being implemented in regard to the instructions 20 to be sent to utilities after the TMI-2 accident?

21 A

Yes, or at least it is a formalization of 22 intended practice.

23 Q

It says "All future instructions."

b~j 24 Does'it mean instructions after the date of

%./.

25 July 30,:19797 i

1 Walters 118 OV 2

A That's the way I would read it, yes.

3 Q

Prior to July 30, 1979 the Training 4

Department had not reviewed draft operating

(-

5

--procedures for either normal or abnormal conditions 6

prior to their transmittal to utility customers; i

7 is that correct?

i 8

MR. KOLB:

Would you read the g

question back, please.

10 (The reporter read back',the last 11 question.)

12 MR. KOLB:

Is that question intended

.(~)

\\'

13 to determine whether it was a practice of 14 having them review them or not, or do you t

15 mean had the Training Department ever in i

16 any instance reviewed something that had 17 '

gone out?

18 MR. MacDONALD:

I think we are talking 19 here in terms of a procedure for review by 20 the Training Department and the question is 21 geared towards all future instructions 22 which I am seeking to elicit whether it is 23 a change in procedure from what happened as to

[)

24 both before July 30, 1979.

And the question

s. /

25 is simply, prior to July 30, 1979 did the u

1 Walters 119 jf'{

2 Training Department review draft operating 4

i' 3

procedures during the normal or abnormal 4

conditions prior to the transmittal to the 4

(

5s customer.

6 MR. KOLB:

The problem is the same, i

7 though.

The way the question is phrased 1

1 8

you could be asking whether it ever, but 1

9 it seems you want to find out whether there 10 was a regular procedure.

4 I

11 MR. MacDONALD:

Let's deal with a 12 i

regular procedure and then we will deal N

13 with that.

i 14 BY MR. MacDONALD:

1 i

15 Q

As a matter of general practice prior 16 to July 30, 1979, did the Training Department

~

17 review draft operating procedures prior to 18 submission to operating utility customers of B&W7 19 A

I am familiar early on that the Eraining i

20 Department did indeed review the procedures, the 4

21

' operating procedures that were sent out later, or 22 the group at that time, the Operating Reactors l

23 Group at that time.

I do not'know that they

)

i

'T

' [Q

~4 reviewed allcrevisions to them or I'm not aware o

t 25

.cf any specific cases along that line but I do 1

1 Walters-120 2

know that they did review them when I was in the ffice back in the 1971,

'72,

'73 area.

3 4

Q Were those procedures that related to j

5 startup physics testing?

6 MR. KOLB:

Is your question whether 7

all the procedures he is' referring to were-8 of that type or whether some of them were 9

of that type?

10 MR. MacDONALD:

Let's see whether 11 some of them were.

12 A

Yes, they reviewed the physics testing.

~

13 Q

Did they review any other type of 14 draft operating procedure?

15 A

Yes, mainly their review was of'the draft-16 operating procedure.

17 Q

Now, this particular memo. states that 18 "All future instructions to operating plants 19 concerning how the plants should be o[erated 20 during normal or abnormal conditions must be 21 reviewed by Training prior to customer transmittal."

22 Is that a change from the practice 23 that existed prior to July 30, 1979?

f MR. KOLB:

If we may, I think it 24 25 would be useful to read the next sentence, a

7

1 Walters 121

. R t

(ms i

2 which says, "This verfies verbal instructions 3

already transmitted to many of you."

4 MR. MacDONALD:

I have no problem 4

5 reading that sentence if it helps the s

6 witness.

7 MR. KOLB:

I think it helps give the 8

context to the question and for the purpose 9

of understanding the record.

I 10 A

well, as I stated befo re, I think the memo 11 gives a formal administrative guideline to follow t

12 from this point on but at no time, at least to L d 13 my own opinion, that we excluded Training from 14 review of procedures.

[

15 Q

so it is your belief that Training was 16 involved in review of procedures at all times 17 prior to July 30, 19797 18 A-No, I wouldn't say "all times."

But they 19 did review procedures.

4.

20 Q

In the normal course of sending draft 21 procedures to the utility site prior to this, 22 the date of this memo, Training was involved in 23 that review?

/~

(,%

)

24 A

As best I can recollect, they were.

25 Q

Did Training or anyone from the

e-1 Walters 122

('~%.

\\

)

2 Training Department sign off or were they required 3

' to sign off by the Policy and Procedures Manual f

4 on the draft operating procedures?

(

5 A

I don't recall.

6 Q

In the second paragraph of the meno 7

it states, "By copy of this memo, N.

S.

Elliott is 8

requested to provide a list of names authorized-9 by him to provide required signatures for Training, 10 and to instruct such designees thatt expedited 11 reviews are often required for these documents."

12 Was that list of names subsequently

()

\\/

13 provided to PPSS by Mr. Elliott?

14 A

I believe it was or at least a name was 15 provided.

16 Q

And these were the individuals who 17 would then be required to sign off.from the i.

18 Training Department in the future on the draft 19 operating procedures before they were sent out to 4

20 the utility sites?

21 A

That's correct.

22 Q

Is it your understanding that that 23 sign-off signature was a change in procedure as

[~}

24 of approximately the date of this memo?

s-25 A

I view it as a change in the formal aspect

4

'l Walters 123

"/N

(' 'l 2

of the procedure.

3 Q

Could you explain for me the difference 4

between an operating guideline and a site

{

5 instruction, if there is any?

6 A

An operating guideline is a specific piece 7

of information that would talk about things, 8

various controls or how to operate the plant under 9

certain conditions.

It is an instruction.

10 The site instruction is a formal procedure 11 by which the Service Department could deliver any 12 information to the Service Manager or Project

)

's/

13 Manager which would be relayed directly to the 14 utility on a very quick turnaround basis, which 15 would then be followed up by some formal memo, 16 document, something as we could furnish the paper 17 work.

18 Q

Was there any requirement' prior to 19 the TMI-2 accident that site instructi'ns be o

20 signed off by any other people within B&W other 21 than PPS?

(i 22.

A I don't recall at this time.

23 Q

Was the re any sign-off within the

/']

24 Plant Performance Services Section required before

%.J 25 the site instruction was sent out?

1 Walters 124

.,m

(

)

i-

~

2 A

On matters that involved plant operation, I 3

believe there was, yes.

4 Q

Who would have to sign off?

(

5 A

Don Hallman or his designee.

6 Q

Were you his designee at times?

7 A

I was one of them, yes.

8 Q

Were there others?

9 A

Yes.

10 Q

Who were they?

t 11 A

Well, the two Supervisory Engineers, one 12 of the Startup Group and one of the Operating 7

i 13 Reactors Group.

I was one, the other was 14 the individuals' names were Ron Finnin and Jim 15 veenstra.

I believe those were the only two 16 during the time I was there.

17 Q

Finnin preceded Veenstra?.

t 18 A

Yes.

~

19 Q

In the context of operating guidelines 20

.and site instructions, how do draft operating 21 procedures fit in?

Are they classified as 23 operating guidelines?

23 MR. KOLB:

Would you read the question I

(-

24 again, please.

. l 25 MR. MacDONALD:

Let me break that up.

i

^

,,~--,n.,-+,,,--,,,,,,-wr

. -, -,=

m.

1 1

Walters 125

}

2 It is a littic convoluted.

3 Q

In the context of operating guidelines i

4 and site instructions, how do draft operating i.

i 5

procedures fit in?

6 A

Draft operating guidelines is B&W's document that we would send the utility for its 4

8 incorporation into operating procedures, plant 9

specific operating procedures.

10 Q

so it is not the same a'nimal as an i

11 operating guideline?

I 12 MR. KOLB:

I would have to ask you

.O

~

13 what you mean by "same animal."

I am not 14 sure how far to take that.

1 15 Q

It is not --

16 MR. KOLB:

My question is, do you want 17 the genus and species or what? -

s 18 Q

It is not the same as an operating 19 guideline, a draf t procedure?

20 MR. KOLB:

We are talking about a 21 draft operating procedure 4.

22 MR. MacDONALD:

,Yes.

23 MR. KOLB:

-- and I think he has

(}-

txj'

. 24 explained to you how the two relate to each y

25 other and~I am unclear as to what additional u -...

1 Walters 126 b) 2 information you want.

.c 3

MR. MacDONALD:

I was a little confused, 4

and mybe it is just my fault, but in his

]

5 answer before he used the term " draft j

6 operating guideline" in the first sentence of h

7 his answer and that is what confused me.

I 8

did not know whether he was referring to 9

operating guidelines as is, as we see in the 10 July 30, 1979 GPU Exhibit 127, memo or not.

i 11 MR. KOLD:

Let me make this suggestion.

12 His answer just a couple of answers back, 13 why don't we have that read back, because I x

14 do thin % it is clear, and if it is not, it 15 would be easier to see what isn't clear 16 about it if we have it read back.

17 MR. MacDONALD:

That's hine, 18 Will you please repeat the answer.

4 19 (The reporter read back the answer 20 as requested.)

21 MR. KOLB:

That is very clear.

22 BY MR. MacDONALD:

23 Q

wh'at confuses me is the term " draft

()-

24 operating guidelines" when my question dealt with

~

1 25 draft operating procedures.

What I am trying to

1 Walters 127

(~T L) 2 glean is whether or not the draft operating i

3 procedure is the same as an operator guideline 4

MR. KOLB:

But

(

5 Q

if you can answer that question.

6 MR. KOLB:

But as the answer read 7

indicated, he referred in his testimony to 8

both operating procedures and operating 9

guidelines and explained their relationship.

i 10 Now, I don't have any problem.with either 11 having him repeat that relationship er 12 repeating the answer again, but it seems to 13 me that he has given you the answer and I 14 don't understand what additional information 15 you are looking for.

16 MR. MacDONALD:

Well, let's just go 17 back to it for a minute because -I didn't 18 quite understand his answer and I would like 19 to make it clear in my own mind.

20 (Continued on page 128.)

• 1 k.

22 23 24 25

,,i

[

I

[

1 Walters 128 1

S#

2 Q_

An operating guideline is different 3

from a draft operating procedure, as I understand 4

it, is that correct?

(

5 MR. KOLB:

Do you mean different in 6

words or do you mean different in some other 7

respect?

i 8

MR. MacDONALD:

Different in any 9

respect at this point in time and then I 10 will find out how it is different.

9 11 MR. KOLB:

Do you understand the 12 question or do you not understand?

(~)

(/

13 THE WITNESS:

Yes, I understand the 14 question.

15 MR. KOLB:

O.K.,

why don't you go 16 ahead and try to answer it.

17 A

Previous to the TMI-2 transient, we 18 prepared, B&W prepared, draft operating 19 procedures.

Those were then embellished by the 20 utility as they saw fit for various title 21 documents.

22 After the TMI-2 transient there 23 was a new procedure or new document name that

[>

'!4 came into existence called an Operating Guideline s-25-or could be Abnormal Operating Guideline.

1 Walters 129 O

~ '

2 9.

Did the Operating Guideline that l

3 came into existence after the TMI-2 accident 4

substantially parallel the draft operating

{

5 procedure that was used by B&W prior to the TMI-2 6

accident?

7 A

Yes.

8 Q

During the time you were involved as 9

a Supervisory Engineer in the Plant Performance 10 section, did you have any occasion,to deal with 11 licensing at all or the licensing basis for 12 plants?

l' k-13 MR. KOLB:

That's possibly going to be-14 two questions depending on how the response 15 comes.

16 Could you break it down?

17 Q

Let's take the first one first.

18 Did you have any involvement in 19 licensing?

~

' 20 A

No.

21 Q

Did you have occasion to work with C

22 the licensing basis required to license nuclear 23 power plants?

[}

24-A I had occasions.to either.be questioned x_-

25 by someone from licensing or offer my comments i

t tg r,w g

em

+e-

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1 Walters 130 O

(

I 2

on certain licensing aspects.

3 Q

Can you recall specifically in what 4

instances you were asked to comment on licensing

(

5 aspects for a certain issue?

6 A

The only thing that jumps to mind is a 7

branch technical position from the NRC on reload 8

startup testing.

9 Q

Were you familiar at the time you 10 were a member of the Plant Performknce Services 11 Section as a supervisory Engineer with the 12 requirements or guidelines of 10 CFR?

~/

13 A

I generally know what the document is.

14 Q

You have read it, reviewed it?

15 A

Not in any great detall no.

y

.16 Q

Did you have occasion to work with 17 the document at all during the time you were a 18 Supervisory Engineer at PPS?

19 A

I don't recall ever having any occasion 20 to except for the previous, I just mentioned 21 there was, I believe, a licensing -- a Xerox page 22 from that document that I looked at when we were 23 talking.about the restart physics testing.

[

24 Q

In drafting or revising 25 operating draf t procedures prior to the 1

1 Walters 131 t

2 TMI-2 accident, did you perform this function 3

with the guidelines of 10 CFR in mind?

4 A

I don't believe I ever recall addressing

_ (

5 that issue.

6 Q

During the time you were a Supervisory 7

Engineer in P.PS, did you have any regular meetings 8

of the Plant Performance Services Section that 9

you attended?

10 A

I don't believe we had any regular scheduled 11 meetings of the Section.

12 Q

You had no monthly, Mr. Hallman did (s"s]

13 not call any monthly meetings or any other regular 14 meetings for the Plant Performance Section?

15 A

No.

16 Q

Did you have any,other regular meetings 17 during the time you were a Supervisory Engineer 18 for PPS at which only some members of'PPS would 19 be involved?

~

20 A

I.had meetings from time to time with two 21 or three of the engineers that worked.for me from 22 time to time on particular issues.

23 Q

Did you have any regular meetings

[').

24 among yourself and Mr. Hallman and Mr. Finnin s._,./

25 at any time while you were a Supervisory

1 Walters 132 (h

\\/

2 Engineer?

3 A

Not regularly scheduled meetings.

4 Q

You did have meetings?

I 5

A From time to time, yes.

6 Q

Would the same hold true for meetings 7

with Mr. Veenstra and Mr. Hallman and yourself?

8 A

Yes.

9 Q

At those meetings that were not 10 regularly scheduled, was there anyt agenda prepared 11 or anything else that would give you guidance 12 as to what the meeting would discuss?

O)

(_

13 A

There wasn't any regular agenda.

14 Q

Were there at times agendas prepared 15 for such meetings?

16 A

I don' t believe so, no.

17 Q

What were the purposes for such 18 meetings?

19 A

Administrative to begin with, passing along 20 to us Supervisory Engineers the workload in respect 21 to manpower resources-that we had to do work was km 22 the biggest reason for the meetings.

l 23 Q

Discussing the workload and the issues

("]

24 that were to be resolved by the section within'a 25 period of time?

1 Walters 133 i

( /~

\\-

2 A

Yes, and a prioritizing of the workload.

3 Q

Were there any meetings among PPS 4

personnel other than the ones you have just

(

5 mentioned which were not regular meetings, but 6

which were held from time to time in the Plant 7

Performance Services Section of Nuclear Service?

8 A

There were no regularly scheduled meetings 9

other than the ones we have talked about.

There 10 possibly was a meeting from time to time on 11 specific subjects and I may or may not have been 12 in attendance.

O

(_)\\

13 Q

Can you recall-the substance of any 14 of those specific meetings?

15 A

What time period are we talking about?

16 Q

At the time you were a Supervisory 17 Engineer.

18 A

Yes.

19 Q

What were those?

20 A

Well, a particular issue of the -- o f a 21 big workload that came into the section in 1979, k

22 I believe it.was, later referred to as the ATOG 23 work, abnormal transient operating guideline

'T 24 work, where I and several of my engineers met

'>-/

25 quite often and quite frequently to-develop a

. ~

__m 1

1 Walters 134 I

J 2

philosophy for this new operating guideline.

3 Q

The abnormal transient operating 4

guidelines were prepared by people within PPS?

(

5 A

Yes.

6 Q

Was there any involvement from others 7

outside of PPS?

8 A

Yes.

9 Q

Who were they?

10 A

Well, varicus engineering pedple were involved 11 in the project.

12 Q

This was a project that was begun as

'O N-13 a result of the TMI-2 accident?

14 A

That is true.

15 Q

Can you name any of the specific 16 people who were involved outside of the personnel 17 from PPS?

18 A

Yes.

Mr. Lou Cartin, Mr. Eric.Swanson, 19 Mr. Joe Kelly, Mr. Tally and others that I don't 20 remember their names right at the moment.

21 Q

Mr. Cartin and Mr. Swanson were j

22 members of the Plant Integration Unit?-

l l

23 A

Yes.

i

).

24 Q

Was Mr. Kelly also?

-./

25 A.

Yes, I think so.

f' g

g 9

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g

-l' Walters 135 2

Q What unit or section was Mr. Tally 3

in?

4 A

Control System Analysis or Controls Analysis,

(

5 I believe.

6 Q

Was that in the Engineering 7

Department?

8 A

Yes.

9 Q

was he a Unit Manager?

10 A

No.

I think he was a Lead Engineer.

11 Q

Who aside from yourself within PPS was 12 involved in ATOG?

?g 4

13 A

Mr. Bob Twilley, Mr. Ted Book.

They are 14 the major ones..

15 Q

What was Mr. Twilley's position at the 16 time?

17 A

He was an engineer that reported to me.

18 Q

Is he still an engineer w thin PPS?

19 A

Yes.

]

20 Q

And Mr. Book's position?

21 A

He was an engineer reporting also to me.

22 Q

Did Mr. Book also used to be a training 23 instructor?

'l

.( );

24 A

Yes, he was in the Training Department, w

25 Q

Was he an instructor in t he Training

.~

1 Walters 136 j

O 2

Department?

3 7.

Yes.

4 Q

What time period was he an instructor

('

5 in the Training Department, to the best of your i

6 knowledge?

7 A

A year or two years preceding when he came 8

to work for me which was prior to '79 I reckon.

i 9

Q Who was in overall charge of the 10 ATOG Program?

t 11 A

From a technical or administrative?

12 Q

Let's try administrative.

(~l h

'~-

13

. A Denny Napir.

14 Q

The same for the technical?

15 A

No, Mr. Joe Kelly was.

l 16 Q

What portions of the ATOG Program 17 were you involved in?

18 A

I was involved with the conceptlon 19 to the final production of the specific procedure 20,

that was sent to Arkansas.

21 Q'

Were you involved in the drafting of 22 the procedures?

23 A

Yes.

. [/I 24 Q

Were you involved in providing the 25 technical backup for the drafting procedures?

t

,m

--..~v

,c

,..m-

,~v

1 Walters 137

'~

2 A

I was involved in obtaining or relating to 3

Engineering and then in ensuing discussion with 4

Engineering about the needed work or needed

(

5 technical backup for the procedure.

6 Q

Who was the person or persons in 7

engineering who you discussed the need for backup 8

for ATOG with?

9 A

Mr. Swanson, Mr. Cartin, Mr. Kelly.

10 Q

They provided the technical backup 11 to support the new draft operating procedures 12 that were produced by ATOG7 s'

13 A

That's true.

14 MR. MacDONALD:

Off the record.

15 (Discussion off the record.)

16 (Recess.)

17 MR. MacDONALD: I would like to mark for 18 identification as GPU Exhibit 128 a memorandum 19 from Frank Walters to Don Hallman dated 20 12/22/1978.

21 (Memorandum from Frank Walters to 22 Don Hallman dated 12/22/1978 marked GPU 23 Exhibit 128 for identification, as of this i

24 date.)

/

25 Q

Mr. Walters, is this a memo that you 1,

1 Walters 138 O

2 authored and sent to Mr. Don Hallman on or about 3

December 22nd, 19787 4

A It is.

(

5 Q

Under " subject" on the fourth line 6

from the top it says "PPS Workload problem. areas."

7 What did you mean when you said 8

" problem areas"?

9 A

Areas of work or items of awareness that 10 I wanted to specifically highlightr.to Don as 11 mixed in with all of the other workload in the 12 group for his consideration in the workload 13 that the group had to do.

s-14 Q

Are these items that you thought 15 needed additional investigation or correction?

16 A

I think these were items that I thought 17 to be doing better than an average job in our 18 area that we should be addressing on some 19 future schedule or priority.

20 Q

Were these arranged in any priority 21 order by you?

k.

22 A

I don't believe so.

23 Q

In the first sentence it says the (m) 24 following:

25 "The following is a summary of

1 Walters 139 O

2 the various problem areas or ares that need 3

additional investigation to assure our standing in 4

the service field as competent and aware f(

5 engineers available for master service work as 6

well as accomplishing our contractual" can you 7

read that?

8 A

" Work."

" work in a competent and efficient 9

Q i

~

10 manner."

e 11 Did these areas that you brought to 12 Mr. Hallman's attention in December of 1978 13 receive additional investigation?

14 A

I don't recall whether all items did or 15 not.

16 Q

Did some of the items?

4 17 A

Yes.

18 Q-would you identify which 'tems i

19 received additional investigation?

.R.

KOLB:

To the extent he is aware.

M 20 21 MR. MacDONALD:

That is always to the 22 extent he is aware.

23 A

well,-most of these are areas of work that

( )

24 I wanted to to assure that Don understood 25

.that we were working on along with other

... ~. _

=

4 1

Walters 140 O

2 information for work that was coming up.

~

3 Item No. 4 addressed from time to 4

time and addressed in the last year or so with

(

5 the individual utilities.

6 Item 5 I think resulted in a -- what 7

I am sure in additional work by both us and the 8

Engineering Department.

9 Item 6 I responded with a memo, I 10 believe, to Engineering on that par icular subject 11 and I believe I received one back from them.

12 Item 7 actually resulted in a piece f'

t 13 of equipment to do that item.

14 Item 11 I did indeed generate a 15 generic nuclear engineer training program for 16 Plant nuclear engineers.

- 17 Item 15 has been addressed in the 18 company in various manners since that' time as T

19 well as within the Service Department for 20 scheduling simulator trainning for engineers in 21 the Plant Performance Service Section.

22 Item 17 resulted in a new test 23 method that was sent to Arkansas.

[~}

24 Those are the items I remember recalling t_-

' 25 at least some work or additional evaluation happening

1 Walters 141 2

on.

3 Q

When was the work on item No. 4 4

prepared?

(

5 A

I don't recall the ' exact date that we 6

started work on it.

7 Q

Approximately when was it?

Was it 8

sometime in 19797 g

A I.really don't remember.

10 Q

was it after the TMI-2'. accident?

11 A

I believe it was before.

12 Q

No. 4 says, " Evaluate our position C1

?

13 on NRC's recommendation that we assist utilities 14 in development of dual acceptance criterias."

15 A

Yes, sir.

16 Q

Could you describe for me what 17 dual acceptance criterias are?

18 A

The NRC passed along a memo from Paul 19 Check drafted by one of their. people Ehat asked i-20 that testing that was done in the future should 21-have a review criteria and an acceptance 22 criteria for the particular test data when it was 23 performed.

(

(

)

24 Our procedures in the past only v

25

' contained an acceptance criteria, and I was asking

1 Walters 142 (1) 2 her whether or not it was B&W's or his opinion i

3 that we should take some time to talk with the 4

utilities and see which way they wanted to go l

5 as far as complying with this recommendation or 6

continuing the practice that we had been going 7

with for several years.

8 Q

on the basis of that you developed a 9

review and acceptance criperia?

10 A

on the basis of that I looked into certain 11 of our test and certain of the acceptance 12 criteria and tried to determine how much O

k-13 resources would be needed if indeed the utilities 14 want to comply with this dual acceptance criteria.

15 Q

And what did you determine in terms 16 of resources that would be needed to comply?

17 A

I determined that there was i$d,eed a couple of 18 cases in point that were not, the information was 19 not readily available, indeed it bounded on 20 philosophical interpretation of tech spec 21 numbers, or already accepted, acceptance criteria 22 and that any deviation from that would require 23 an in-depth evaluation by Engineering to determine

[)

24 a new review criteria and certainly this would

%);

25 have to be talked to with the utilities about

1 Walters 143 4

f'N()

2 how they wanted to approach this.

3 Q

No. 5 says, "Re-evaluate present 4

PIDC acceptance criteria with new information

(

5 available."

6 What does PIDC stand for?

7 A

Power Imbalance Detector Correlation test.

8 Q

And what does that, in substance, 9

entail?

10 A

It is a correlation between the out-of-11 core detectors and the in-core detectors that 12 allows the out-of-core system, which is an input 13 to the reactor protection system, to be

/

14 calibrated to a certain criteria so that in under 15 any transient RPS or reactor protection system 16 would be conservative during this transient when 17 an

. established power imbalance in ~the core i

18 occurred.

19 Q

Now, this reevaluation you' passed on pp for additional work by the Engineering Department?

21 A

Yes, it was passed on to the Engineering 22 Department.

23 Q

Do you know what the outcome was in l

I' 24 the Engineering Department?

V 25 A

The Engineering Department ran some

1 Walters 144

[)

~

v 2

analysis to try to duplicate some of the 3

information that we had received from sites or 4

at least to evaluate as best they could a l

5 from an input paramter how that_would affect 6

the in-core to out-of-core correlation.

7 Q

Who in the Engineering Department did 8

you pass this on to?

9 A

I think it was a Mr. Marv Gudorf.

10 Q

What section or unit wds he involved 11 in?

s 12 A

He was the head of the Nuclear Operation 13 Analysis Unit of Fuels Engineering.

14 Q

Did you get an answer back from this 15 gentleman regarding the issue?

16 A

Yes, I received a correspondence on that 17 sometime later.

I don't remember the.date.

18 Q

Do you recall when the work was done?

19 A

Not at this time, i

f 20 Q

or when you passed along the concern?

21

'A No, I don't even' remember when I passed it 22 along.

l

. M Q

No. 6 says, " Evaluate impact of" em

-(4b 24 you will have to tell me what that symbol means.

25 A

Westinghouse.

Super'bar W.

T t-

-y,- - '

w yr g

ye-wt-

+y

+

yw Ty wr--

we w

r-7

1 Walters 145 (N

(_)-

2 Q

" Westinghouse rod" 3

A

" Swap."

" swap technique on plant 4

Q

(

5 availability and customer demands."

6 Will you explain what Westinghouse 7

rod swap technique is or was?

8 A

I became aware in review of certain 9

information that is routinely passed along to us 10 from our Washington correspondence (from the NRC, 11 from public documents, that Westinghouse at l

l 12 certain units was experimenting with a new

(' )'

13 technique measuring rod worths, as a result of s'

j 14 this information I evaluated that particular 15 technique versus the boron swap technique that 16 we had been using in our startups, and came to 17 the conclusion that it looked like we could save

~

18 a few hours in the zero power physics testing by 19 employing this rod swap technique and 'was asking 20 Don his thoughts on the process and whether I 21 should go any further with Engineering on the 22 subject.

23 Q

Did Mr. Hallman give his O.K.

to go

(/)

24 further with Engineering on the subject?

s._

25 A

.Yes, indeed.

1 Walters 146 2

Q Did you then pass this concern along 3

to Engineering?

4 A

Yes.

(

5 Q

Who in. Engineering?

6 A

The same Mr. Marv Gudorf.

7' Q

Did you get an answer back from 8

Engineering?

9 A

Yes, I think so.

10 g

were there any other i$ stances that 11 you can recall obtaining information from public 12 documents regarding the NSS systems of other Oi V

13 manufacturers, Westinghouse, GE, Combustion 14 Engineering?

15 MR. KOLB:

Which systems?

16 MR. MacDONALD:

Westinghouse, GE.

2 17 MR. KOLB:

Which sys tems ?-

18 MR. MacDONALD:

NSS.

19 MR. KOLB:

NSS.

O.K.

20 A

I don't recall in specific.

There are always 21 public documents that are available for review 22 or to look at.'

23 Q

Was there'anybody within B&W who

(

24 regularly took part in such a review of those 25

-public documents?

1 Walters 147

?\\

r%.)

2 A

I am not sure whether there was or not.

3 Q

No. 7 says, " Complete development of 4

RAMP generator and new reactivity calculator.

(

5 Ensure complete closeout" --

6 A

" Checkout."

7 Q

" Checkout," excuse me.

8 "and field' tested."

9 Will you explain to me that this 10 concern was about?

t 4

A 11 MR. KOLB:

Just a second.

12 Go ahead.

i

[)

\\/

13 MR. MacDONALD:

Will you please repeat 14 the question.

15 (Record read.)

16 A

Yes, for some time I had been'in Fuels l

17 Engineering and I had discussed the's,ubject of 18 the individual utilities using their own 19 '

reactimeter in measuring the physics s'tartup 20 parameters and since we were responsible, B&W 21 was responsible, for the safety analysis of'those 22 units, how-could we back equipment that was not 23 B&W supplied.

rs

.(

f 24 As a result of that.I asked some

>ws

\\

25 the C&I Group of B&W could we build a RAMP

1 Walters 148

\\

2 generator that we could go to the utility site 3

and input to their reactivity calculator and 4

check the output with the same RAMP generator

(

5 to our reactivity calculator and see how far 6

different they were.

If it indeed was the same 7

as ours, there would be no problem with using 8

their measured data in our safety analysis 9

evaluations.

That was the RAMP generator.

10 The new reactivity calculator, the 11 old data reactivity calculator was of

'69,

'70 12 vintage electronics and to remain competent and

/~s 13 with the latest equipment in the field we needed 14 to use some capital money and build a new up to 15 the state of the art with an electronic system 16 reactivity calculator.

17 Q

Did you pass along this concern to 18 anyone at another department within B&W?

19 A

I think Safety Analysis themselves were 20 aware of it, at least Mr. Vosberg in safety 21 Analysis.

I believe I remember discussing it 22 with*him.

23 Q

In addition --

24 A

I N.,/ -

25 Q

Excuse me.

1 Walters 149

~

D 2

A I don't remember other people.

There may 3

have been other discussions.

i 4

Q In addition to writing this memo to

(

5 Mr. Hallman, do you remember at some point in 6

time discussing it with Mr. Vosberg?

7 A

Yes, I think I probably discussed it with 8

him at some point in time.

9 Q

Is Mr. Vosberg the Manager of 10 Safety Analysis?

t 11 A

I do not believe he was Manager.

He was 12 probably a Supervisory Engineer in Safety 13 Analysis.

14 Q

Was Mr. LaBelle the Manager?

15 A

I believe that's correct.

16 Q

Was there any resolution of this concern 17 in No. 7 as to either the RAMP generator or the 18 new reactivity calculator?

19 A

Well, we were successful in getting 20 both products built and indeed have used both of 21 them'today.

22 Q

Do you recall whether either items 9

23 5,

6 or 7, the work performed, was performed

. A.

},)

24 prior to the TMI-2 accident or after the TMI-2 25 accident?

., _... ~

1 Walters 150 bv 2

A To the best of my recollection, it was 3

probably an ongoing subject that was touched on 4

before and it continues afterward.

(

5 Q

Did you have discussions with people 6

in the Engineering Department on items No. 5 and 7

67 8

A Yes, I did.

9 Q

On item 5, how many discussions 1

10-can you recall having with people in Engineering?

11 A

I don't remember the exact number.

12 Q

More than one?

O l

13 A

sure.

• 14 Q

Was it several?

15 A

Yes.

16 Q

Item No.

6, can you recall having 17 more than one discussion with people.in the 18 Engineering Department regarding this concern?

19 A

At least several times.

20 Q

Item No.

7, can you recall having 21 discussions with people in the Engineering 22 Department regarding this concern, more than 23 one?

You' stated one with Mr. Vosberg.

(

24 A

I had at least two discussions with'Mr.

25 Gudorf on the subject.

1.

Walters 151 s

2 Q

In addition to the conversation with 3

Mr. vosberg?

4 A

Yes.

(

5 Q

Can you recall any other conversations?

6 A

I am sure at some time or another I talked 7'

to Mr. Hallnan about it.

8 Q

Did you specifically talk to Mr.

9 Hallman about all the items that are in Exhibit 10 GPU 1287 t

i 11 A

I don't believe I ever met him and we went 12 down it on an item item basis, no.

s

^

13 Q

But do you believe you have discussed 14 the items on GPU Exhibit 128 marked for 15 identification with Mr. Hallman?

16 A

At some time or another, I think we have 17 touched on each of them.

18 Q

No. 8 says, "Obtain new d'ata 19 acquisition system to replace obsolete' hardware 20 now being-used."

21 What was the new data acquisition 22 system that you were referring to in No. 8?

23-A Essentially the same piece of equipment I

[}

24 was referring to in No.

7, reactivity calculator /

A,/

~

j 25 data acquisition system, a new 1978-79 vintage

.___m i

4 t

k, ~

l 1

Walters 151-A 4

l 2

electronics compared with the 69 vintage 3

electronics that we had that we used on startup 4'

4

testing, i

j

(

5 (Continued on following'page.)

6~

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8 a

i i

9 10 t

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11 i

12 e

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14 i

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1 Walters 152

[~')

U 2

Q Did you have any discussions on Item 3

No. 8 with anybody in Engineering aside from 4-the ones you have already recounted in relation 4

(

5 to No. 77 6

A I don't recall any conversations about the 7

data acquisition system.

8 Q

No. 9 says, " Develop new data handling 9

tools once new data acquisition is bought."

10 Will you explain to me what the 11 "new data handling tools" were that you were 12 referring to in Item No. 97

~)

(d 13 A

It would be new computer software, plotting 14 software that would be used on the new hardware, 15 if it were bought, in Item 8.

16 Q

Was that new data acquisition system 17 put in place since the time of your writing of 18 12/22/787 19 A

We do have one unit in hand, yes.

20 Q

When was that obtained?

2'1 A

It must have been early

'80.

22 Q

And.the software has also been 23 obtained for that hardware unit?

/~N

' _)

24 A

I'm not aware it has been produced yet.

(

25 Q

Did you have conversations with

~_

L 1

Walters 153

. f~'u 2

Engineering regarding, concerning No.

9, about 3

the software?

4 A

No, I have not.

(

5 Q

Have you had any discussions with 6

anyone else at B&W regarding Item No. 97 7

A Yes, I have had discussions with some of 8

the C&I people in service that are responsible for 9

maintaining the system.

10 Q

Have you had more than one discussion?

11 A

Yes.

12 Q

Have you had several discussions?

Os 13 A

At least two.

14 Q

With which individuals in C&I?

15 A

Mr. Norbert Seeling and Bill Nielson.

16 Q

Have you sent them any memos on the 17 subject?

18 A-I don't recall any at this time.

10 Q

Item No. 10 says, " Develop and Q/A t-20 data reduction codes for small mini-computer."

21 Does this relate to plant data?

22 A

It relates to reduction of plant startup 23 test data during the startup physics testing.

/~%

.()

24-Q Did you discuss this concern with 25 anybody at B&W?

_~

1 Walters 154 Q('x 2

A With Mr. Hallman and engineers within my 3

group.

4 Q

Anyone from outside of your group?

(

5 A

I don't recall any.

6 Q

Has the current concern that you 7

express here been resolved?

8 A

Item No. 107 9

Q Yes.

10 A

Yes.

t 11 Q

When did that occur?

12 A

Well, it was on an ongoing basis.

We

\\2 13 developed a small LOCA computer calculation and I believe we used an Engineering or B&W 14 we 15 procedure by which we Q/A'd that little program 16 and filed it in the files on an as-needed basis.

17 Q

No. 11 says, " Develop nuclear engineer 18' training program for generic plant." -

19 This was performed by you 'when?

20 A

I don't remember specific dates.

There 21 were times when I completed that.

22 Q-When did you begin?

23 A

I don't remember that either.

.,m

(

)

24 Q

Do you recall approximately when it v

25'

'was completed?

.~

?

1 Walters 155 2

A Sometime between a request from Florida 4

3 3

Power & Light for such a training course and 4

their acceptance of it, whenever that was.

I

(

5 don't remember,

'79,

'78.

6 Q

This was a training program for 7

Florida Power & Light personnel?

8 A

The first one was.

9 Q

No. 13 says, "Does PPS's work scope 10 ever intend to have an objective of,some type 11 of data analysis on problem areas or coordination 12 of these problems?"

O.

13 The " problem areas" that you referred 14 to there, are they plant problem areas or 15 did you have something else in mind?

16 A

I believe I had other problem areas in mind.

17 Q

What were those other problem areas?

18 A

well, I asked that question in the context 19 of the first paragraph of this memo.

5t was my 20 belief that if we were to remain an outstanding og group in what we were doing, that we should offer 22 a question concerning, to the utilities, concerning i

j 23 how much analysis or how much. involvement should

().

24 we have in analysis of or looking at each x..-

25 specific transient or trip that the plant might get

1 Walters 156

.O v

2 into.

3 Q

What prompted your concern or your 4

statement to Mr. Hallman in No. 137

(

5 A

I don't recall.

6 Q

No. 14 says, Study and evaluate our 7

competition test programs so we are not in 8

dark as to where our program stands."

9 Did you ever discuss this with 10 anybody outside of relaying the information to j

11 Mr. Hallman, regarding No. 14?

12 A

Yes, I'm sure I have.

[)

\\/

13 Q

Can you recall with whom?

14 A

Well, it was certainly with engineers 15 that worked for me, we discussed.it, yes.

16 Q

Was there anyone outside of PPS?

17 A

I think I may have had a passing comment 18 with Mr. Jim Phinney, Manager of Operating Plant 19 Services, about availability of plants and from 20 that could we minimize the startup testing time 21 in the relay physics testing, k.

22 Q

Was there any. resolution of the 23 concern?

. ()

24 A

Well,- I didn't state it_as a concern.

I N. /

25

' don't know what you mean by that.

Is it possible j

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1 Walters 157 (y

2 that we can evaluate the different test programs 3

and indeed improve the one that is already in 4

exiatence.

(

5 Q

was anything done as a result of your 6

comment to Mr. Hallman?

7 A

I do not believe we made any changes.

8 Q

No. 15 says, " Ensure our engineers g

received a training course from Engineering and 10 on the simulator."

(

11 By "our engineers" you mean the 12 engineers within the Nuclear Service Section?

(~%

(l 13 A

No.

B&W engineers in the Engineering 14 Department oh, excuse me.

"Our engineers,"

15

. yes, Plant Performance Service engineers.

16 Q

And by " received a training course 17 from Engineering," you maan the personnel within 18 the Engineering Department?

19 A

.That is correct.

20 Q

And "on the simulator," by that you 21 mean on the B&W training simulator?

/

22 A

That's correct.

23 Q

Has that program been put into place

[~)

since the time you write this memo?

24 L).

25 A

I did result in establishing a training

1 Walters 158 2

course for my engineers from the Safety Analysis 3

Department which I mainly had back in my mind 4

4 here.

(

5 Q

When did that program begin?

6 A

I don't remember the exact dates that that 7

training program was accomplished.

8 Q

Why did you consider it important that t

9 such a program be instituted?

10 A

It is always important to havj engineers 11 that are involved in testing, in operation of a 12 nuclear power plant, to understand the basic input l

/~N 13 from the Safety Analysis Department, how the 14 limits are set, what goes into setting the limits 15 and an understanding of those limits so that when 16 you are out testing, you can evaluate any abnormal' 17 or condition that you are in where it.is a serious 18 problem, where it is something that should go back 19 to B&W or at least how to evaluate the problem 20 that you are in.

21 Q

This was a new program that was 22 instituted, correct?

23 A

I wouldn't say it was a new program that was i

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24 instituted.

j,

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25 I was successful in getting the training that

1 Walters 159 O

2 I thought necessary for the engineers that were 3

in the section at the time.

4 Q

And that was the training from the

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5 Engineering Department and the training on the 6

simulator?

7 A

Yes.

8 Q

No. 16 says, "Have someone become 9

aware that the 205 PMIS software and the plant 10 computer area in general as of now we have zero 11 expertise in this area."

12 Q

What does the "205 PMIS software" that 13 you were referring to in there refer to?

14 A

I was referring to the on-line computer 15 software for the 205 plant, which is Plant 16 Performance Information System, I believe is what 17 that stands for.

It is essentially an on-line 18 computer for the 205 plants.

i 19 Q

And you were saying that t5ere was 20 nobody within PPS that had expertise in this 21 area as of that time?

22 A

That's correct.

23 Q

Has there been any resolution of that f

s.

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24 Particular concern that you expressed in Item f

25 No. 167.

.. = -

1 Walters 160 h

2 A

I am not aware that any solution to that 3

has been effected.

4 Q

Did you talk to anybody within PPS

(

5 aside from Mr. Hallman regarding the substance 6

of Item 16?

7 A

None other than one or two engineers that 8

worked for me.

9 Q

Did you speak with anyone outside of 10 PPS?

(

i 11 A

I don't believe so.

f 12 Q

No. 20 says, "Present RPRINT data

(

f 13 reduction tool is an embarrassment at best."

14 Can you explain what "RPRINgdata 15 reduction tool" is?

16 A

That's the name given to an in-house code 17 for data reduction from the data acquisition 18 system that we previously referred to.'

19 Q

Did you discuss this parti'cular 20 concern with anybody oth'er than Mr. Hallman?

21 A

Yes, I believe I did.

22 Q

Can you recall with whom?

23 A

I believe with Mr. Kelly -- not the same f) 24 Kelly we talked about before.

%d 25 Q

Not Joe Kelly?

d _.

1 Walters 161 l

2 A

Not Joe Kelly, Mr. Bill Kelly at sometime 3

about it, and also a programmer from the 4

Computer Group.

f 5

Q What section is Mr. Bill Kelly in?

6 A

At that time, when I talked to him, he was 7

in the Plant Performance Service Section.

8 Q

Can you recall when it was that you 9

spoke to him?

10 A

It was in 1978.

I believe in',the middle of i

11 the year or something.

12 Q

Before the time you wrote this memo O

F 13 to Mr. Hallman?

14 A

Yes, I'm sure.

15 Q

was there any resolution of the 16 concern you expressed in Item No. 107 17 A

Not that I am aware of.

18 MR. MacDONALD:

This is a good place 19 to call a halt for today.

20 MR. KOLB:

O.

K.

21 (Time noted:

4:33 p.m.)

22 James-Franklin Walters 23 Subscribed and sworn to before me 24 v

this day of

.1981.

25

)

i

,- s jb/1 1

162 s

%_,_,/

[EHIlZIgAlg 3

STATE OF NEW YORK

)

ss.:

4 COUNTY OF NEW YORK )

5 6

CHARLES SHAPIRO, C '. S. R.

I,

,a 7

Notary Public within and for the State of New York, 8

do hereby certify that the foregoing deposition 9

of. TAMES FRANKLIN WALTERS was.taken before 10 April 13, 1981 me on 11 That the said witness was duly sworn

)(n) 12 before the comnencement of his testimony and 13 that,the within transcript ic'a true record of said j

.)

14 testimony; 15 That I am not connected by blood or 16 marriage with any of the parties herein.nor 17

~

interested directly or indirectly in the matter in 18 controversy, ncr am I in the employ of any of the 19 counsel.

s 20 IN WITNESS EEREOF, ' I' have hereunto set

(*

21 my hand this 13 day of AfAll 1981.

22

~3 0) 9 s 24Qw, CHARLES SHAPIRo, C.S R.

25

April 13, 1981 163 I ND E X Witness Page James Franklin Walters 3

i 00o E X H I B I T S GPU FOR l

IDENTIFICATION PAGE

~

126 Resume of James Franklin 4

j

Walters, t

127 Memo from Don Hallman to 116 PPSS personnel dated July 30, 1979, 128 Memorandum from Frank 137 Walters to Don Hallman dated 12/22/1979.

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