ML20072H766

Deposition of Nl Beers on 820708 in New York,Ny.Pp 152-308

ML20072H766
Person / Time
Site:	Crane
Issue date:	07/08/1982
From:	Beers M GENERAL PUBLIC UTILITIES CORP.
To:
References
TASK-*, TASK-08, TASK-10, TASK-8, TASK-GB NUDOCS 8306290728
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p' 152 BK L

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK

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x GENERAL PUBLIC UTILITIES CORPORATION, JERSEY CENTRAL POWER & LIGHT COMPANY, METROPOLITAN EDISON COMPANY and PENNSYLVANIA ELECTRIC COMPANY, Plaintiffs, 80 Civ. 1683 (R.O.)

-against-THE BABCOCK & WILCOX COMPANY and J.

RAY McDERMOTT &

CO.,

INC.

/

Defendants.

)

x NJ Continued deposition.of GENERAL PUBLIC UTILITIES CORPORATION, by MARSHALL L.

BEERS, taken by Defendants, pursuant to adjournment at the offices of Davis Polk &

WARDWELL, ESQS., One Chase Manhattan Plaza, New York, New York, on Thursday, July 8,

1982, at 9:30 a.m.,

before' Robert Cap' z elo,

u a Shorthand Reporter and Notary Public within and for the State of New York.

8306290728 820708 PDR ADOCK 05000289 T

PDR O

V DOYLE REPORTING, INC.

CERTIFIED STENoTYPE REPORTERS 369 LExlNGTON AVENUE WALTER SHAPIRO, C.S.R.

NEw YORK. N.Y.

10017 CHARLES SHAPIRO, C.S.R.

TELEPHONE 212 - 867-8220

1 153 2

APPe arance s:

3 KAYE, SCHOLER, FIERMAN, H Al'S & HANDLER, ESQS.

Attorneys for Plaintiffs 4

425 Park Avenue New York, New York k

5 BY:

STEVEN GLASSMAN, ESQ.,

6 of Counsel 7

8 DAV'.S POLK & WARDWELL, ESQS.

9 Attorneys for Defendants One-Chase Manhattan Plaza 10 New York, New York E

11 BY:

ROBERT W.

FISKE, ESQ.,

12 of Counsel O

13 14 l

l 15 e

16 Also Present:

17 SUSAN HANSON, Paralegal - Davis Polk 18 19 20 21

-000-22 l

l 23 i

l I

24 25 l

1 154

/~N 2

MARSHALL L.

BEERS, having 3

been previously duly sworn by a Notary Public, 4

testified further as follows:

5 CONTINUED EXAMINATION 6

BY MR. FISKE:

7 MR. FISKE:

Mr. Reporter, please mark 8

this exhibit as 893, 9

CDocument consisting of a copy of 10 Supplement 3 was marked as B&W E hibit 893 11 for identification.)

12 Q

Mr. Beers, you realize you continue under 13 oath for the rest of the deposition, do you not?

14 A

Yes, sir.

15 Q

Let me show you a document which we have 16 just marked as B&W Exhibit 893 which is a supplement 17 to the FSAR filed by Met Ed with the NRC.

18 A

When was it filed?

19 Q

Sometime before the Three Mile Island 20 accident.

(

21 I will ask you whether or not you ever 22 read this particular -- withdrawn.

23 I will ask you whether or not you read f~

24 this section of the FSAR.

25 Q

Does this come from one of the l

1 Beers 155 O

2 supplements of the FSAR7 3

Q Yes.

4 MR. GLASSMAN:

Is the question whether 5

Mr. Beers recal3s reading these particular 6

pages or whether he recalls reading a section 7

of the sort?

8 MR. GLASSMAN:

Whether he recalls reading 9

the partic.nlar pages that are in front of him 10 now.

11 A

I have read the FSAR numerous 12

. times, but I don't recall reading these -- this b)

V 13 garticular amendment.

14 Q

The third paragraph under the heading 15

" Response" says,'"Other typical s'ources of documented 16 information include nuclear industry periodicals and 17 newspapers LANS publications, Nucleonics, Week, Atomic 18 Energy Clearinghouse), other plant licensing and 19 operational reporting information submitted to the 20 NRC and nuclear plant abnormal occurrence and 21 experience reports interchanged through informal

(

22 agreements with other utilities.

These documents 1

23 are routed to senior engineering personnel and

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24 engineering management personvel and are informally 25 reviewed by them for applicability to their function.

..m_.. _ _ _ _ _. _

1 Beers 156 (m.

2 or other functions within GPU s At their discretion 3

portions may be routed to others for information and 4

action if judged necessary."

l 5

Were you aware before the Three Mile 6

Island accident Metropolitan Edison had made that 7

commitment to the NRC7 8

A As I said, Mr. Fiske, I don't recall 9

reading this specific document.

Numerous 10 t

publications,as mentioned here in the document, were 11 routed throughout the plant, the operations 12 department and the training department, d

13 Q

Including the publications referred to 14 in this paragraph?

15 A

I remember specifically the Atomic Energy l

16 there is one that Clearinghouse documents and -- well, 17 it in I recall.

It doesn't specifically talk,4 bout ^

18 that paragraph.

19

~

Q What is that?

20 A

The LER summary reports were routed to us.

(

Q When you refer "to us" in that answer, 99 i

~~

Mr. Beers, whom do you mean?

I 23 A

The LEW summary report I recall being 24 sj routed to the training department when I was in the 25 training department. I might also say in the last t

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1 Beers 157 2

paragraph where it talks about nuclear power 3

experience and NUS Licensing Information Service, I 4

recall seeing some of those in our training department

(

5 also.

6 Q

Was a document called "NRC Current Events 7

Power Reactors" circulated through the training 8

department?

9 A

I don't recall the par'ticular title.

10 Perhaps if I looked at the format of one of these, 4

11 I would recall.

i

- 12 Q

I show you a document that was marked as 13 Exhibit 1 6'1.

At the moment, without asking you whether i

14 you ever saw that particular document, let me ask you 15 whether looking at that document refreshes your

+-

i l

16 recollection that the publication called " Current 17 Events-Power Reactors" was reviewed in the training 18 department?

19 A.

I don't recall this one.

As i said, 20 Mr. Fiske, the one that I mentioned in the bottom 21 Paragraph is the one that I recall more than this 22 power reactor.

I 23 Q

Let me show you a document, Mr. Beers,

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24 which has been previously marked B&W Exhibit 74 25 which is action item 31 of the Three Mile Island y

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1 REERS 158 A

2 Unit GORB, dated June 15, 1978;-and the first page 3

of this says under the heading " Items,"

"Other 4

changes which should be made in the process for

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5 acquisition and use of information about incidents 6

at other nuclear plants as one way to forecast and avoid 7

nuclear and radiation safety problems at TMI Units 8

1 and 2."

9 Then it says, "See attached response."

10 Then on the next page there is a statement 11 at the top " Background" which repeats the item I just 12 read and then underneath that there is a statement O

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13 that says, " Current Status.

The following are 14 existing means of reviewing" 15 A

I'm sorry, I'm lost.

16 Q

There's a paragraph that says " Current 17 Status." right on the back.

18 "The following are existing means of 19 reviewing information about nuclear plant ~ incidents.

20 (11 Current Events-Power Reactors from NRC."

21 Then there is a list of three other items L

22 and then you see in the note below, it says, "The 23 training department also reviews these documents D

24 and fo'rmally schedules dissemination and discussion L.j e

25 of other nuclear plant operating experiences as

1 Bears 159

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2 part of the requalification program for all operations 3

department personnel and all licensed personnel."

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Having read that statement which was made 4

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5 to the Three Mile Island Unit GORB, does that refresh 6

your recollection.that Current Events-Power Reactors 7

was reviewed by the training department?

8 A

Well, as the note says

- you see'the 9

haddwritten note on it right there?

-10 Q

Yes.

11 A

Nelson Brown received all of these 12 documents directly.

They were all routed directly to 13 him.

Then he went through this large accumulation of 14 different documents for disseminating information 15 about other plans and about our own plant.

A 16 So, I just don't recall seeing the l

17 particular type of document that you showed me.

18 Q

You are not disagreeing with the statement

)

19 here that Current Events-Power Reactors was reviewed 20 by the training department?

21 A

No.

k'm j

22 Q

What role did you personally have, 23 Mr. Beers, in reviewing documents such as Nucleonics l

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24 Week,' Current Events-Power Reactors, Atomic Energy t

25 Clearinghouse and other documents that were l

1 Bears 160 7-2 circulated to the training department?

during the period of time tha't A

well, as 3

4 I was in the training department, I still had my

(

5 senior reactor operators license, so I sat in on all 6

the classes that were given by Nelson Brown for 7

operating experiences, abnormal occurrences and so on.

'8 From time to time Nelson would come to me, 9

as his supervisor,and we might dis. cuss a particular 10

' event from another plant to determine whether it 11 should be taught or not.

12 You have got to understand, Mr. Fiske, 13 the volume of this type of information that Nelson

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14 was attempting to determine what was not important.

t l-l 15 Q

Well, do you know how often current l

16 Events-Power Reactors was published?

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17 A

Was published?

18 Q

Yes.

19 A

No, I don't recall.

~~

t 20 Q

Do you know how often Atomic Energy ~

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21 Clearinghouse was published?

(

22 A

I believe that comes out weekly.

I 23 Q

Do you know how often Nucleonics Week was

)

24 Published?

25 A

I'm not sure.

I

_.., _., _ _ _ _ _ ~ _ _

i 1

Beers 161

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2 Q

Did Mr. Brown ever tell you during the 3

period of time that you were his supervisor that the 4

volume of this material was too great for him to be

(

5 able to do the job properly?

6 A

No, I wouldn't put it that way, Mr. Fiske, 7

sometimes he complained to me that it was a major part 8

of his workload, but not that he couldn't do the job g

properly.

10 Q

As his supervisor, did you take steps to 11 he sure that Mr. Brown had as much time as he needed 12 to do that job properly?

O

/(-)

13 A

Not specifically.

Mr..

Brown was a very 14 dedicated and responsible individual.

I didn't feel 15 that that type of direct supervision was necessary, 16 Q

No, I didn't mean that.

Maybe you 17 misunderstood my question, 18 MR. FISKE:

Why don't you read it back.

19 (Record read)

~

20 Q

In other words, the question, Mr. Beers, 21 is in terms of the responsibilities that Mr. Brown L

22 had which included, among other things, reviewing 23 these publications, did you as his supervisor in

(

24 the training department, take steps to be sure that 25 Mr. Brown had enough time to be able to do this

1 Beers 162 ts V

2 particular job properly?

3 MR. GLASSMAN:

I think that was just 4

asked and answered, Mr. Fiske.

(

5 MR, FISKE:

Why don't you let Mr. Beers 6

respond, 7

MR. GLASSMAN:

Let's have the answer 8

read back first.

9 MR. FISKE:

Fien.

10 MR. GLASSMAN:

I think it was responsive 11 to both your first question and your second 12 question.

12 MR. FISKE:

If Mr. Beers listens to the 14 answer and tells me he considers that answer 15 responsive, I will accept that.

16 (Record read.1 17 A

Perhaps I can add scmething to that.

The 18 licensing section of the training department was a 19 relatively small section, very close-knit group.

We 20 all had quite a large workload during the period of 21 time that I was there Overtime was available for 22 each individual and we were I recall specifically 23 during the summer of

'79, we were all working 24 overtime to assure we did a competent job in all areas.

25 g

Do you mean the summer of 1978?

My

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1 Beers 163 0

2 questions are obviously related to the period of time bef re the Three Mile Island accident.

3 4

A Yes, I believe 1978 also, I was

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5 specifically thinking of '79 but I believe '78 also.

6 Q

In other words, if you understood my 1

7 question to refer to the period of time before the 8

Three Mile Island accident, you would give the same 9

answer?

10 A

Yes, I would.

t 11 Q

Let me show you a document, Mr. Beers, 12 which has been marked as -- which will be marked as 13 the next 3&W Exhibit which is 894.

14 (Document consisting of a copy of an 15 interoffice memorandum, dated July 3, 1979 16 on the letterhead of Metropolitan Edison i

17 Company was marked B&W Exhibit 894,for 18 identification.)

~

19 Q

Do you have Exhibit 894 in front of you, 20 Mr. Beers?

21 A

Yes, I do.

22 Q

Do you see here you are indicated as a 23 recipient of a copy of this document?

()

24 A

Yes, I do.

25 Q

Did you receive a copy of this document

-1 Beers 164

(/

2 in the summer of 19797 1

3 A

I don't specifically recall.

4 Q

Did you participate in any discussions in

(

5 the, summer of '79 concerning a hole in training with 6

respect to the subject of communications?

7 A

I don't recall any discussions relative 8

to this subject here.

9 Q

Did Mr. Seelinger in the summer of

'79, 10 express any criticism of the way thattthe training 11 department had conducted its review of communications 12 concerning transients at other plants before the b

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13 accident?

14 A

I don't recall any such criticism.

15 Q

what procedures did you have within the 16 training department, Mr. Beers, in the summer of 1978 17 through the Three Mile Island accident for obtaining 18 information about incidents at Metropoliban Edison 19 that might be of benefit to the operators"?

20 A

To the best of my reco21ection, there l

are you speaking formal written procedures?

21 was 22 Is that what you are addressing, Mr. Fiske?

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23 Q

I am not limiting it to written l

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( s) 24 procedures.

Any kind of procedures?

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l 25 MR. GLASSMAN:

I think -- can I have the l

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1 Beers 165 2.

question read back.

I think the question was 3

much more general.

Just -- let me have it read 4

back.

(

5 MR. FISKE:

Okay, M'r. Reporter.

6 (Record read.)

7 MR. GLASSMAN:

As I understand you, you 8

are not limiting this to written procedures?

9 MR. FISKE:

That's correct.

10 A

-As.I said just a few minutes ago, the 11 department and, indeed -- the training department 12 and, indeed, the operations department was relatively j

13 small and we had good lines of communication back and 14 forth.

15 To the best of my recollection, all 16 LER's were routed to the' training department and to 17 the shift supervisors when I was a shift supervisor T

18 for review with their crews.

19 Q

How about other incidents that did not 20 result in LER's that still might be of significance

(

21 to the operators?

22 !

A I'm not sure exactly what you have in I

23 mind, Mr. Fiske.

24 Q

Well, what steps did you take when you 25 were in the training department, supervisor of s

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Beers 166 G

2 licensed training, to be sure that all information 3

that might be helpful to the operators in diagnosing 4

transients was communicate.1 to the training 5

department?

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MR. GLASSMAN:

Are you now talking about 7

Mr. Beers personally or the training department 8

as a whole?

9 MR. FISKE:

I am asking what steps he took 10 or that he was aware that the training department 11 had taken.

12 A.

Well,. I believe that the LER's would have 13 covered any transients, anything of that nature and 14 that type of communication did come to the training 15.

department for review and dissemination as necessary.

16 Q

Were there any procedures in effect for 17 the communication of information to the sraining 10 department other than the review of LER's?

19 A

No written procedures.

20 Q

My question is not limited to written 21 procedures.

Were there any procedures?

22 MR. GLASSMAN:

May I have that read back?

j l

23 Q

Were there any procedures for the 24 communication of information to the training 25 department other than the review of the LER's that

1 Beers 167 O~J 2

you just described?

3 MR. GLASSMAN:

Is this question just 4

related to procedures instituted by the training

(

5 department or procedures which may have come 6

from anywhere else?

7 MR. FISKE:

Anyplace.

8 A

Well, we are still talking about the g

period prior to the accident?

10 Q

Yes.

All my questions deal with that 11 Period unless I say otherwise,

~

12 A

Well, other than all these documents we O.

kI 13 have already talked about include the LER's, I don't 14 know of any procedures, 15 Q

By "the documents that we have already 16 talked about" we are referring to the'se publications 17 such as Current Events-Power Reactors and so forth?

18 A

Yes, sir.

19 Q

Did you ever discuss with Mr.'Zechman 20 the desirability of having direct contact between 21 Met Ed's training department and the training 22 department of any other utilities that had B&W I

23 reactors?

[)

24 A

I recall discussions about this, but.I U

25 don't recall the time frame,

1 Beers 168

('T Q

2 Q

Well, I am talking about before the Three Mile Island accident.

3 4

A I understand that, Mr. Fiske, and sometime

(

5 during my tenure at the training department, a 1

6 mid-Atlantic training conference was established and 7

Nelson Brown was a charter member for that mid-Atlantic 8

training conference.

9 Q

You mean he was in on the ground floor?

10 A

Yes.

11 Q

Was this composed of representatives of 12 different utilities that had B&W reactors?

13 A

It was not specifically B&W reactors.

14 It was all nuclear power plants in the mid-Atlantic 15 area.

16 Q

How often did that group meet?

17 A

I don't recall the frequency.

I think 18 once a quarter or once every six months. I'm not

~

19 sure.

20 Q

When Mr. Brown came back, did he discuss 21 with you and others what had happened at these 22 meetings?

l 23 A

Yes, he did.

We usually had a meeting l

[~,J) 24 of myself, Mr. Zechman and Mr. McCormick.

25 Q

What did you understand was the general

1 Beers 169 OV 2

content of these meetings?

Wha,t types of things were discussed?

3 4

A The charter included a number of things.

(

5 It included trying to standardize radiation protection 6

training among all the utilities so that there could 7

be some reciprocity agreement between the utilities, 8

should it be necessary for people to work at more than.

9 one power plant, 10 For example, construction people, they 11 discussed methods of training.

They also discussed 12 incidents that were of importance to be trained upon, b

13 Q

Did representatives from the various 14 manufacturers attend these meetings?

15 A

From time to time they had different 16 guest speakers at these meetings and I cannot recall l

17 whether it may have been co'mponent vendors or nuclear j

18 steam supply vendors.

19 The NRC was also invited to these 20 meetings.

~

21 Q

Were there minutes prepared?

22 A

Yes, there were minutes prepared.

i 23 Q

Apart from the mid-Atlantic training i

24 conferonce meetings, whenever they started, was there 25 any effort by Met Ed, the training department before

1 Beers 170 0

2 the Three Mile Island accident, to be in touch with s s 3

trainin9 departments at'other utilities to exchange 4

information of mutual interest?

(

5 A

I don't recall so much the training 6

depar tm ent, but I remember one specific incident when 7

I was shift supervisor of talking to a shift 8

supervisor at Crystal River one night about an 9

incident that they had when they sheared a shaft on a 10 decay heat pump.

11 Q

Let's just stick with the training 12 department for a second.

OU 13 Do I understand from your answer that 14 you don't recall any effort by the training department 15 to do that before the Three Mile Island accident?

l 16 A

Well, let me continue, Mr. Fiske.

17 The training supervisor at Arkansas Power 18

& Light which is a B&W plant, is a personal friend of 19 mine, and he and I talk back-and-forth on occacion 20 about training on the B&W plants.

21 Q

Did you have any communication with 23 anyone from any other training department?

23 A

Nothing referring to the simulator.

I

(

24 Q

I say did you have any conversations.with 25 People from the training department at any other B&W

r 1

Beers 171

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Plant besides Arkansas?

A I have talked once or twice with the 3

4 training supervisor at oconee.

5 Q

This is again before the accident.

6 A

I'm not quite sure whether I talked to the training supervisor from oconee before the 7

8 accident or after the accident.

9 Q

Well, did you talk to anyone from any 10 training department before the acciden't other than 11 your friend at Arkansas?

12 A

I'm not positive.

A/

13 Q

Did you have any discussions with anyone 14 else at Met Ed at any time on whether or not that 15 would be a desirable thing to do?

16 A

I don't recall any such discussion.

17 Q

Let me show you, Mr. Beers, again what l

[

18 has been marked as B&W Exhibit 161 which is an 19 issue of Current Events-Power Reactors, published 20 in December of 1977, covering the period the 1st of 21 September through the 31st of October,

'77.

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22 I ask you whether or not you saw that j

23 document before the Three Mile Island accident?

24 A

No, I don't recall this document.

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25 Q

The third paragraph on page 3 of that' v

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.'idocupnt reads es,aQ11owsi "The 3C3' continued to

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blowdown ibr'ourT[th'e pen preswud zRr power relief valve

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',[ f, //~ 4 an.d the ' qufnch tank rupturt; diak ch$ning until C,J /-

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Frimary coo (#(ak s/aturation prassyfrt.was reached about

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formation of 6

, gf,l steam in the ROL, caused,an insur(Js cf water into the

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p r e s, suriz e r..,

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and the high pressure

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witer idjedtion en restored pressurizer level to

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10 [' i about '310' inch'es abouVnine minutes into the J

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',,; g 7.._.r[.Doydusee that paragraph that I just 12 3

• 13 read? i,_ 7

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15

. Q' It is yjsce testimony that you never'saw that j

16 paragraph'..at anytime'bAfore the accident?

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17 A

That's correct.

18

,Q Is it your testim ~ony that you were not 11 i

accident, that

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19

, aware, prior to the'Three Mile Island

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,, ~ 20 such an event had occurred at Toledo Edison's Davis-i si 21 Besse' plant?

1 A

That's correct.

22}

5 i

f Q

.Let me show you a document which is a 1

(m) 24 copy of a January 9, 1978 issue of the Atomic Energy v

v<

f Clearinghoudedl It has been previously marked as 25 "t.

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1 Beers 173 part of B&W Exhibit 247 and I ask you whether you saw 2

3 that document before the Three Mile Island accident.

4 A

No, Mr. Fiske, I don't recall this

(

5 document.

6 Q

Directing your attention to the third 7

page, the fourth paragraph, which reads, I think, 8

identically with the paragraph that I read from the

'g Current Events-Power Reactors, is it your testimony 10 that you did not read that paragraph before the Three 11 Mile Island accident?

12 A

That's correct, I did not.

O 13 Q

And no one brought that to your attention?

14 A

No, sir.

15 Q

Let me show you another document which 1

16 has been previously marked as part of B&W Exhibit 17 247 which is an edition of Nucleonics Week.

18 I ask you, referring to this same 19 transient at Davis-Besse, did you see t h a't document 20 bef' ore the accident?

21 A

No, I did not.

22 Q

Directing your attention to the second l

23 Page of that document, there is a statement in the 24 second paragraph that reads, "RCS pressure continued 25 to decrease until saturation pressure was reached i

I

(

1 Beers 174 2

and steam began to form in the RCSs This caused an 3

insurge of water into the pressurizer and the 4

Pressurizer level went off scale at 330 inches."

l(

5 Is it your testimony that you did not 6

see that statement before the Three Mile Island 7

accident?

8.

A That's correct.

9 Q

And no one brought that to your attention?

10 A

That's correct.

11 Q

I show you a document which has been 12 marked GPU Exhibit 153 which is the LER for the 13 September, 1977 Davis-Besse transient.

14 I ask you whether or not either as a 15 shift supervisor or as a member of the training 16 department, you reviewed that LER at any time before 17 the Three Mile Island accident?

18 A

No, sir, I never saw this prior to the

~.

19 accident.

20 Q

At anytime before the Three Mile Island 21 accident, Mr. Beers, did you become aware of an 22 incident in the fall of 1977 which occurred at Three 23 Mile Island Unit 2 in the course of start-up testing

()

24 in which there was observed an unusual action with 25 respect to pressurizer level?

1 Bears 175

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2 A

In the fall of 1977, did you say?

3 Q

Yes.

4 A

It'was prior to core loading, was it not?

(j 5

Q It was not. functional testing.

6 A

I don't recall any such incident of 7

unusual pressurizer level indication.

8 Q

You don't recall an incident that went on 9

over a period of four days in which there was unusual 10 action with respect to the pressurizer. level?

11 A

No, I don't.

I believe I would like to 12 tell' you how the shift supervisor manning was during 3

s 13 different periods of time.

14 MR. GLASSMAN:

That is not the question.

15 g

Well, if that is relevant to my 16 question --

l 17 A

I believe it is, 18 There were periods of time wh'ereby the 19 shift supervisors ^were split up and three~ shift 20 supervisors would be in Unit 1,

and three shift l

21 supervisors on Unit 2.

22 Q

Your testimony at the moment is, you 23 don't recall any such event during a period of time f~h 24 where you were a shift supervisor on duty at Unit 2, s]

25 is that correct?

1 Beers 176 2

A That's correct.

3 Q

My question is now broader than that; 4

whether it ever came to your attention, whether or

(

5 not you were the shift supervisor on duty at the time, 6

that thcre was such an event in process or after 7

the fact that such an event had occurred?

8 A

It never came to my attention.

9 MR. GLASSMAN:

Can we take a two-minute 10 break?

11 MR. FISKE:

Fine.

12 (Recess taken.1 (s_/)

13 Q

Is it your testimony that it never came 14 to your attention anytime before the Three Mile Island 15 accident that there had been an incident in the course 16 of hot functional testing in which it had been 17 concluded that pressurizer level had been ef fected by 18 the presence of saturation in the reactor coolant 19 system?

~

20 A

I don't recall any such incident.

21 Q

Is it your testimony now that you didn't 3

22 learn about any unusual event in the fall of 1977 23 involving hot functional testing?

~)

24 A

Well, there were reports published about (V

25 the most significant events that occurred in either i

1 Beers 177 O

2 unit and these were routed to the shift supervisors.

3 I don't recall this specific time frame that you are 4

referring to of any significant event.

(

5 We discussed yesterday some particular 6

event at Unit 2, and I have already forgotten the 7

date of that event that we were discussing yesterday.

8 Q

You mean the open PORV7 9

A No, sir.

The overcooling event.

10 Q

We will get to that in a minute.

11 My question -- I think you have answered 12 the question about the hot functional testing.

O(-)

13 When did you figst learn about the 14 overcooling event involving the steam relief valves?

15 A

The evening that it happened.

I was the 16 Unit 1 shift supervisor that evening, and the shift 17 supervisor that was on Unit 2 called me and told me 18 that he had had an incident down there, and we always 19 kept in close communications with each other. That is 20 about all he told me that evening.

21 Q

Were you involved in discussions 22 concerning that transient after it had occurred?

l i

23 A

No, I was not.

(

24

-Q Let me show you a document which has been 25 marked as B&W 186 which is a report prepared by GPUCE

. ~.

g

. B e er s.

. 1.78 O

~

2 Task. Forca concerning the April M, J 978 transient 3

and I ask.you whether at any time hefore the' accident, 4

the Three Mile Island accident in Rarch.of.1979, you

(

5 saw this document.

6 A

No, I don't recall seeing this document.

7 Q

Were-you aware during the period of time 8

that you were supervisor of training for licensed 9

personnel that a report on this transient had been 10 prepared?

11 A

This report?

12 Q

Were you aware that a report had been i

V 13 prepared by either GPU or Met Ed on that April 14 transient?

15 A

Yes.

16 Q

After you became supervisor of training i

17 for licensed personnel, did you review any of those l

l 18 reports to determine what information in there might i

19 be useful in training operators?

~

20 MR. G LA S SMAN :

Are you talking about l

1 j

21 h Mr. Beers personally?

1 j

22 MR. FISKE:

Yes, t

23 r

A I don't recall a review of the April 23, 24

'78 incident for incorporation into training.

25 Q

During the period of time you were in L

1 Bears 179 O

~

2 the trainingdepartment[was'traininggiventothe 3

operators on this transient?

4 A

No, this transient occurred prior to my

(

5 being in the training department.

6 Q

I understand that.

My question is, 7

during the period of time that you were there, 8

beginning on the 1st of July on through the Three 9

Mile Island accident, was trair.ing given to the 10 operators on this transient?

11 A

I don't specifically recall any such 12 training.

13 Q

Do you recall any training that was 14 given to the operators from July 1,

1978 through the 15 time of the accident, on any transient that occurred 16 at Met Ed?

17 A

We trained on transients every year, 18 any transients that occurred at the plant that were of 19 significant importance.

It was a class as part of 20 the requalification program.

21 I don't remember specifics.

22 Q

Well, I am not asking you what the l

23 regular procedure was, Mr Beers.

I am asking you s

24 as you sit here now, can you tell us of any transient 25 that the operators -- any Met Ed transient that the

..n.

.,7 p

1 Beers 180

,O V

2 operators received training on after you became a namber of the training department in July, July 1,

3 4

19767

(

5 A

I thought, Mr. Fiske, I had already 6

answered that.

7 I don't recall any specific transients.

8 Q

Did it come to your attention in the course 9

of discussing the April 23, '78 transient, that there 10 had been a rapid drop in pressure and pressuri=er 11 level?

12 MR. GLASSMAN: In the course of which g(d 13 discussions are you referring to?

14 MR. FISKE:

Any discussions he had about 15 this transient in April.

16 MR. GLASSMAN:

I thought he just testified 17 that he recalled hearing of it on the day of the 18 event, but was not involved in the particular 19 post-event discussions.

20 Q

Did you ever learn at any time before 21 the Three Mile Island accident, during the course of 23 that transient, there had been a sharp drop in the 23 pressure, in the pressurizer level?

C\\

(,/

24

'A I recall reviewing a report on this l

l 25 incident in question that indicated a sharp drop in

(

- ~_

1 Beers 181 0

2 Pressure and pressurizer level which would be expected on an verc ling transient.

3 4

Q Who had prepared that report?

(

5, A

I don't recall.

We had a number of 6

reports routed to us all the time of any incident.

7 It was not always a specific individual that wrote 8

the report.

9 Q

Did you learn that it had been concluded 10 by Met Ed and by GPU that in the course of this transient, a bubble had formed somewhere in the 12 reactor coolant system outside the pressurizer?

I

\\/

13 A

I don't recall that specifically.

14 Q

Were you aware before the Three Mile 15 Island accident, Mr. Beers, that it was possible for 16 a steam bubble to form in the reactor coolant system 17 outside the pressurizer under certain circumstances?

18 A

Well, could you be a little more 19 specific as to the plant conditions when this 20 postulated incident could occur?

21 Q

Were you aware, Mr. Beers, before the 33 Three Mile Island accident, of circumstances under 23 which steam could form in the reactor coolant system

()

24 outside the pressurizer?

25 A

Steam?

l 1

Beers 182 2

Q Yes.

A No, I'm not aware of'that.

3 4

Q I think you have testified, I believe, 5

that you knew that the' units had -- both Unit 1 and

(

6 Unit 2, the reactors were pressurized water reactors?

7 A

Yes.

8 Q

And you understood, did you not, that the 9

temperature.in the reactor coolant system outside the 10 pressurizer was in the vicinity of 550 degrees 11 Fahrenheit in the cold leg and 605 degrees Fahrenheit 12 in the hot leg?

l

's 13 A

That would be the condition at 100 percent i

14 power.

15 Q

What did you understand kept that water 16 from boiling at those temperatures?

l 17 A

The pressurized water reactor.

18 Q

What was it that kept the water from l

1 19 boiling?

l 20 MR. GLASSMAN:

Are you looking for 21 whether Mr. Beers had a particular 22 understanding on all these matters you are i

23 asking about before the accident?

[~T 24 MR. FISKE:

Yes.

During the period of

'%)

25 time he was supervisor of licensed training.

a 1

Beers 183

("}

NI

~2 A

I th i n k I undarstood that a' long tima 3

before thats 4

Q And you undarstood that it was the fact

. (

5 that tha water was under pressure that kept 'it from 0

boiling?

7 A

That's corrects 8

Q And you knau, didatt you, that it was 9

the function of the pressurizer to maintain that 10 pressure?

11 A

That is a function of the pressurizer, 12 yes.

\\.

13 Q

And the pressure under normal operating 14 conditions was approximately 2105 degrees Fahrenheit 15 2105 psig?

16 A

Normal operating pressure is 2155 psig.

Q And you said, Mr. Beers, that you had read the FSAR on several occasions?

l A

Yes, I did.

~

20 Q

Did you read the section in the FSAR that 21 describes the pressurizer?

l l

99

~~

l A

Well, I said that I had ead the FSAR.

23 Q

And you knew that the FSAR stated that 4

the function of the pressurizer was to keep the water 9'5 l

in the reactor coolant system from boiling, didn't

1 Beers 184 sd 2

you?

MR. GLASSMAN:

I think that has been 3

4 asked and answered.

(

3 MR. FISKE: I don't think it has.

6 A

I don't recall that specific statement.

7 Q

But you knew that as a fact, didn't you?

8 A

I think we have already discussed the I

g principle of pressurized water reactor operation.

10 Q

So you understood, didn'ttyou, that if 11 the pressure in the reactor coolant system dropped 12 below a cert'ain point, the water in the reactor 13 coolant system would turn to steam?

that is 14 A

Well, Mr. Fiske, that is not just 15

. aot. art instantaneous occurrence.

This doesn't, like 16 that, occur in the whole reactor coolant system at 17 once.

18 Q

I understand. My question probably wasn't l

19 as clear as it should have been.

I wasn't cuggesting 20 that instantaneously all the water in the reactor i

21 coolant system would suddenly turn to steam.

22 But you knew, didn't you, when the 23 pressure dropped to a certain point, the water in

()

24 the reactor coolant system would start to boil and l

25 would start to produce steam?

1 Beers 185 b

\\-

2 MR. GLASSMAN:

Are you now talking about 3

the water in the entire system or at a 4

Particular point, or what?

(

5 The witness just indicated that the 6

generalitics you are making are not well founded, 7

and we seem to be going into the same morass.

8 MR. FISKZ: Mr. Glassman, I don't think 9

that objection needs to be commented on.

This is l

a fairly ' elementary point, I believe. I don't 10 11 think it is a morass.

12 MR. GLASSMAN:

I don't think I need to 13 comment on what is elementary and what is not. We 14 obviously have our disagreements.

15 You can ask the question, 16 Q

Do you understand the question, Mr. Beers?

17 A

I understand the question, but I'm having 18 difficulty answering you in toto, and correctly.

l 19 The hot and cold leg temperatures that you og pointed out to me at the beginning of this question is I

l 21 an indication of operating conditions at 100 percent 22 power.

And I seem to recall in the FSAR, it also i

l 23 says under some 'ransient, power conditions you will 24 have some steam formation within the re' actor 25 coolant system, nucleate boiling along the fuel pin t

l

1 Beers 186 O

2 channels and these bubbles would collapse prior to 3

exiting the top of the core.

4 So it is difficult for me to answer,

(

5 Mr. Fiske, that -- there is a condition where steam

'6 does form in the reactor coolant system there 7

whereby the pressure as indicated on the control room 8

console will not be lowered to the saturation 9

condition.

10 Q

I understand, This phenomenon called 11 nucleate boiling is something that happens during 12 normal opeations, is that right?

%l 13 A

During transient conditions, there may be 14 a small amount of nucleate boiling. I don't recall 15 exactly what the FSAR says for 100 percent power 16 conditions.

17 Q

I mean ithat is useful in describing 18 one type of boiling that may occur in the system.

19 My question is really broadei than that.

20 It is very, very simple:

You understood just from 21 the basic concept of a pressurized water reactor, 22 did you not, that if the pressure fell below a 23 certain point, that the water in the reactor coolant

()

24 system-would start to boil?

25 A

Yes, I understood that.

1 Beers 187 O

2 Q

And you had steam tables, didn't you, that were used 'from time to time in the training 3

4 Program?

([

5 A

We had steam tables in the training 6

department, we had steam tables in the control room.

7 Q

And..those steam tables listed, among 8

other things, various pressure temperature 9

relationships ct which steam would_ form in the 10 reactor coolant system, isn't that correct?

11 A

That's a ' purpose of the steam tables.

12 Q

Were you aware, Mr. Beers, before the 0'4 13 Three Mile Island accident, that under normal 14 operations, the pressurizer was the hottest part 15 of the system?

16 A

The hottest part of the reactor coolant 17 system we are talking about?

18 Q

Yes.

~

l 19 A

Yes.

~

20 Q

And did you have an understanding that 21 the pressurizer was, in fact, at saturated conditions?

i c

l 22 There were saturated conditions in the pressurizer?

23 A

Do you mean by that that there was a

(

24 two-phase condition in ~he pressurizer, part of the t

25 pressurizer was water and part was steam?

1 Beers 188 O

2 Q

Yes.

3 A

Yes.

4 Q

And the steam was above the water, isn't

('

5 that correct?

6 A

Yes.

7 Q

Isn't it correct that the formation of 8

that steam was what produced the pressure down on the 9

water in the pressurizer and on the water in the 10 reactor coolant system to allow the system to perform 11 its function as a pressurized water reactor?

12 A

I think that is the way the pressurizer O

V 13 performs.

14 Q

And did you have an understanding before 15 the accident that if saturation occurs in the 16 reactor coolant system, that that formation of steam 17 in the reactor coolant system would hav'e, an effect on 18 the level of water in the pressurizer?

^

19 MR. GLASSMAN:

Are you now referring to 20 what you described in your last question or 21 something broader?

b 22 MR. FISKE:

I think the question is l

23 pretty clear.

i (J) 24 MR. GLASSMAN:

I think it is designed to 25 he misleading..

Obviously, you have just I

1 Beers 189

\\"

described a particular situation in the 2

3 Pressurizer itself and it seems now you are 4

trying to ask a broader question.

5 I don't want the witness to be confused

({

6 as to where you are going here.

7 MR. FISKE:

Read the question back.

I 8

don't want Mr. Beers to be confused either.

If 9

there is any question about it, I will restate 10 it.

11 (Record read. )

12 BY MR. FISKE:

\\-)

13 Q

Just so there is no question about it, 14 when I refer to reactor coolant system in that 15 question, I meant reactor coolant system outside the 16 Pressurizer.

i Did you understand that?

17 18 A

No, I didn't understand that'part.

19 Q

Well, that is my question. Let me put it 20 again.

21 Did you have an understanding before the

(_

22 Three Mile Island accident, that if saturation occurs i

23 in the reactor coolant system outside the l

d(~T 24 pressurizer, that the formation of that steam could 25 have an effect on the level of water in the e

1 Beers 190 pd 2

pressurizer?

3

.MR.. GLASSMAN:

I think the witness just 4

answered that.

(

5 MR. FISKE:

No, he didn't, Mr. Glassman.

6 A

I don't recall any specific training in 7

the situation that you are referring to either at 8

Three Mile Island or at the B&W simulator.

9 Q

My question is a little broader than that.

10 It wasn't limited to specific training 11 that you received at either Met Ed or B&W.

My i

12 question is going back to the day one of your b

\\-

13 experience with pressurized water reactors based on 14 whatever you learned from whatever source, class 15 training or whatever your understanding of the 16 system generally.

f 17 Did you have an understanding before the

~

18 accident that if you had saturation forming in the 19 reactor coolant system outside the pressurizer, that 20 that formation of steam could have an effect on the 21 level of water in the pressurizer?

22 A

My training and understanding in that j

l l

23 area prior to the accident was that you should

(

24 maintain a level in the pressurizer commensurate 25 with the established range for whatever particular l

s

.= -.

1 Beers 191 O-2 reactor we are discussing and as long as you maintain 4

that level, you did not need to be concerned about the 3

4 condition.

5 Q

I don't mean to interrupt you, Mr. Beers,

({

6 I don't think you are answering my question.

You can 7

finish your answer and then I will put it again.

8 A

The condition of the rest of the reactor g

coolant system.

10 MR. GLASSMAN:

I think the question was 11 answered.

12 MR. FISKE:

We can debate that later, i

13 Mr. Glassman.

14 Q

In any event, I would like to ask it t

15 again, Mr. Beers.

16 AR. GLASSMAN:

I hope you won't ask the 17 same question again.

18 MR. FISKE:

Yes, I am going t'o ask the 1

19 same question again.

~

20 Q

My question is directed at your i

21 understanding of the way the system worked and 22 operated.

23 Simply, did you understand that in the

()

24 event that steam formed in the reactor coolant 25 system outside the pressurizer, that the formation of

1 Beers 192

/~'s 2

that steam below the pressurizer would have an effect 3

on the level of water in the pressurizer?

4 MR. GLASSMAN:

Objection as to form.

You 5

have a compound question there and you have not

(

6 established that the first half of your question 7

was something that was taught or understood, 8

let alone the combination of events.

9 Q

You can answer, Mr. Beers.

10 A

Somewhere back in my training I was 11 taught that 1 pound of steam takes up more volume than 12 1 pound of water, but I never thought of it in the i\\_/

13 concept that the condition that you described in your 14 question would change pressurizer level.

~

15 Q

Are you saying, just so I understand you, 16 Mr. Beers, that it would be a natural conclusion from 17 the fact that 1 pound of steam -- that steam takes up i

18 a greater volume than water, that if some of the water 19 in the reactor coolant system outside the' pressurizer 20 turned to steam, that would tend to increase the level 21 of the water in the pressurizer, but that you never 22 thought of that specifically before the accident?

I 23 MR. GLASSMAN:

Objection. I think it is i

24 improper to ask him what he was saying. His l

25 testimony was clear, Now you are trying to i

I

1 Beers 193 2

Put words in his mouth by talking about a 3

hyp thetical situation which he just said was 4

not something that he ever thought about before 5

the accident.

(

6 It is highly improper.

His testimony was 7

clear.

You were looking for clearer testimony, 8

and he gave it to you.

I g

MR. FISKE:

I think what I will do is to 10 withdraw the question.

11 BY MR. FISKE:

12 Q

Did anybody bring to your attention, 13 Mr. Beers, the fact that there had been discussions 14 at Met Ed following the April 23rd transient as to 15 whether or not the existence of a bubble or steam in 16 some part of the reactor coolant system had kept the 17 Pressurizer level up above where it would have been 18 otherwise?

19 MR. GLASSMAN:

May I have that read 20 back.

('

21 (Record read) 22 MR. GLASSMAN:

Are we talking about 23 Mr. Beers' knowledge before the accident?

24 MR. FISKE:

Yes.

25 A

I think the only thing I recall relative 1

i

-,_m.-..

1 Beers 194 2

to that area was some discussion in the report or somewhere as to whether the pressurizer em'ptied or 3

4 not.

5 Q

And did you learn from the report or

([ '

6 otherwise that consideration had been given to the 7

possibility that even though the indicated lovel on 8

the instrumentation was zero, that the pressurizer, in fact,'had not emptied because of the existence of 9

10 a bubble or steam somewhere in the reactor coolant 11 system?

12 MR. GLASSMAN:

You are talking about what 13 Mr. Beers learned before the accident?

14 MR. FISKE:

Yes.

15 A

I was aware, from my previous training, 1

l 16 as to whether the level taps come off on the significant, amount o f --

17 Pressurizer, that there is a 18 well, there is some volume b'elow the pres'sure taps --

19 I mean the level taps on the pressurizer.' And my 20 recollection of the report said that the pressurizer 21 did not go empty.

So I did not really think about a

('

22 bubble being elsewhere in the reactor coolant system.

23 Q

Do you have a copy of B&W 186 in front f

~

()

24 of you, Mr. Beers?

25 A

Yes.

1 Beers 195 2

Q Could you look at page 25j I direct your 3

attention to the caption which says, " Pressurizer 4

Performance" on the top of page 25.

(

5 The first sentence says " Pressurizer level 6

was off scale low for about one minute during the 7

transient Ieading to the question of whether any 8

part of the reactor core had been uncovered."

9 Do you see that sentence?

10 A

Yes, sir, e

11 Q

Did you understand before the accident 12 why, having pressurizer level off scale low, might 7-b 13 raise a question as to whether the reactor core was 14 uncovered?

15 A

iss, Mr. Fiske.

I think we have already 16 addressed that a few minutes ago here when we were 17 discussing the principle of pressurized water 18 reactor operation.

19 Q

Well, could you expound on that a little 20 bit 'further?

21 A

In that I mean it was important for the C.

f 22 operator to maintain a water level within the 23 pressurizer.

24 Q

How would the fact that the pressurizer 1

25 level had gone off scale low raise a question as to

1 Beers 196 O'

2 whether the core had been uncoverad?

A Well, if the pressurizer level had gone 3

4 off scale low, that would mean to me that there had

(

5 been sufficient shrinkage in the reactor coolant 6

system whereby the steam volume that was in the 7

Pressurizer, some portion of that steam volume may 8

have shifted elsewhere in the reactor coolant system.

9 Q

How would the shifting of that steam 10 volume to part of the reactor coolant system raise a 11 question of core uncovering?

12 Is your point that concern would be that

(~%

13 the core mkght have been covered only by steam instead 14 of by water?

15 A

You were pointing out to me, Mr. Fiske, I

16 how the pressurizer works.

The steam would always l

17 be above the point where the water is.

Therefore, t

l 18 there is a lot of physical volume in the' reactor 19 coolant system above the core.

For them to make a 20 statement that the reactor core had been uncovered, 21 I don't really follow the basis of their statement l

(_

l 22 there.

l I

l 23 Q

Well, my question, Mr. Beers, is why you l

)

24 understood before the Thr e Mile Island accident, I

25 having pressurizer level v

=cale low might lead to

~

1 Beers 197 OV 2

a question as to whether or not any part of the 3

' react r core had been uncovered?

4 And I thought I understood you to say 1

(

5 that the question would arise because of the fact 6

that loss of level in the pressurizer might indicate i

7 that steam had formed in the reactor coolant system.

8 I am simply asking you whether the question.

9 about core uhcovering would arise from the fact that 10 there might be a cencern that part of the core at 11 that point was covered by steam instead of by water.

12 MR. GLASSMAN: I think you are perhaps O

(_)

i, 13 mischaracterizing Mr. Beer's testimony.

I 14 think the record will show what he has said, but 15 I think he was talking about the need to main-r l

+

16 tain level in the pressurizer.

If it.went off I

17 scale low, that that might indicate that the 18 steam within the pressurizer on top of the

~

19 water level had pushed down further somewhere.

20 I think that is what he said in the series 21 of questions and answers which you have just 22 finished.

23 bR. FISKE:

I am not sure I said anything

)

24 different than that.

25

1 Beers 198 o-g Q

But in any event, Mr. Beers, isn't it c rre t that the question of core uncovery might 3

4 arise from the fact there might be a concern that

(

under those circumstances, part of the core was 5

6 covered by steam and not by water?

7 MR. GLASSMAN:

Are you asking the witness 8

to speculate now.

MR. FISKE:

No.

I am asking for his l

9 10 understanding of the concept as it had been 11 expressed by the GPUCS Task Force before the 12 accident.

(~)

13 A

As I earlier testified, I never saw this g4 particular report.

To further try.and answer your 15 question, Mr. Fiske, it is my training, the operator's 16 training at both Three Mile Island and at the g7 simulator, that it's important to maintain a 18 pressurizer level.

Once you have lost tdat indication i

19 of pressurizer level, you have somewhat of an unknown condition within the reactor coolant system.

20 og Q

Let me just go on, Mr. Beers.

l 22 You said earlier that you had seen a 23 report on the April 23 transient after the accident.--

()

24 I mean after the incident.

25 Are you telling us now that you,

I g

1 Beers 199 2

looking at Exhibit 186, remember that this is not the i

3 report that you saw?

-l 4

A You asked me earlier"on before our break 5

if I had seen this particular report and I said no,

(

6 I had not seen this report.

7 Q

At some point lateryoubaid that you had 8

seen a report on this particular incident and I just.

9 was going back in light of that answer, jus,t.to be 10 sure that it was still your testimony that you can

~*

i n

/;

11 tell us today that you did not see this document, 12 A

I think I have answered that, M r..,F l a k e.

C' i

13 Q

It is your testimony that you did not see \\.

s" i 14 that document?

q

)

15 A

I have already testified to' that.

S

/

16 Q

Let me show you a document which has been on ~the sane 17 marked B&W Exhibit 246 which is a report, 18 transient written by J.L. Seelinger and I ask you 19 whether or not you saw a copy of that report.

20 A

Yes, I believe this report was routed to 21 me as a shift supervisor.

1 22 Q

Is this the report that you were referring 23 l

to earlier when you did recieve a report after the i

f')

24 incident?

J 25 A

It probably is, Mr. Fiske. I can't be

,e

ffi;-

'k i

1 Seers 200 2

positive that this is the actual report.

3 Q

But looking at the first page of this 4

exhibit, there is'a list of distributees, is there

(

5 not?

6 A

Yes.

7 Q

Aren't you listed as the second person 8

on that-list?

9 A

Yes, I am.

10 Q

Directing your attention to page 3 of 11 this report, Mr. Beers, the second paragraph from the 12 bottomt Page 3,

it has the number "3"

at the bottom.

\\/

13 A

It appears to be missing from my cgpy.

14 I go from page 1 to page 4.

15 Q

I show you another copy of this same 16 exhibit that has all the pages and I direct your 17 attention to page number 3 at the bottom, the second 18 paragraph from the bottom reads " Calculations 19 performed immediately after the event and' subsequent 20 chemistry analysis showed that the core remained 21 covered at all times.

22 "Although the bubble left the pressurizer 23 and went into one or both hot legs, the hot leg with l

(~3) 24 the bubble if only one had it, was at least still 8

25 filled with water halfway up the height of the leg,

1 Beers 201 C )\\

~

'w 2

If both hot legs had a bubble, then the legs would 3

have been filled three-quarters of the way up the legs."

4 Do you see that statement?

(

5 A

Yes.

6 Q

Does that refresh your recollection, 7

Mr. Beers, that you were aware before the Three Mile 0

Isla$1d accident that Met Ed had concluded that a 9

bubble -- there had been a bubble in one or both'of 10 the hot legs.

E 11 MR. GLASSMAN:

Does this bring it back to 12 him, is that correct?

AU

'3

^

Is that the question?

14 A

Is that the qu e s tio n?

15 Q

Having looked at this document, is it 16 still your testimony that before the Three Mile Island 17 accident, you did not know that Met Ed had concluded 0

that in the April 23, 1978 transient, a bubble had been formed in either one or both of the5ot legs?

19 20 -

MR. GLASSMAN:

You are asking for his 21 actual recollection and not suppositions from reading the document?

i,

~~

MR. FICKE:

That's corrects 24 A

That's not my recollection of the 25 incident.

1 Bears 202 o

2 Q

.I don't think you understand the; question.

j

)

A It's not my recollection of the incident 3

4 that there was a bubble somewhere other than the

(

5 pressurizer.

6 Q

Did you see any report other than this 7

one, Mr.-Beers?

8 MR. GLASSMAN:

Objection.

The witness

_g has not be~en able to positively identify this 10 document as being the one that he saw.

You 11 are smiling, Mr. Fiske, but the witness said 12 that probably this was the one, but he could 13 not positively identify it.

14 MR. FISKE:

Let's put it this way, just 15 to save a lot of time, 16 Q'

Is it still your testimony, Mr. Beers, 17 having looked at this exhibit, that you did not know 18 before the Three Mile Island accident tha't anyone 19 had concluded that a bubble had existed in either of 20 the hot legs in the cov6.se of the April 23 transient?

21 A

My testimony is, Mr. Fiske, that I don't 22 recollect one way or the other that there was a bubble l

23

'in one or both of the hot legs as a result of this 24 incident.

25 Q

And nobody brought to your attention a

1 Beers 203 1

~#

2 the fact that anyone in GPU or Met Ed may have related the existence of a bubble in the reactor coolant 3

4 system to pressurizer level?

(

5-MR. GLASSMAN:

Objection, lack of 6

foundation.

This report doesn't talk about it 7

in that general term, 8

MR. FISKE:

I think we can survive that 9

objection.

10 Q

You can answer the question.

11 A

I'm sorry, Mr. Fiske, I really don't 12 understand your question.

i 13 MR. FISKE:

Do you want to read it back.

14 (Record read. )

15 A

I don't understand what you are asking me 16 there.

no time before 17 Q

Is.it your testimony that at, 18 the Three Mile Island accident did anyone bring to your 19 attention the fact that anyone in GPU or Met Ed had

~

20 related the existence of' steam h the reactor coolant 21 system to the pressurizer level?

22 MR, GLASSMAN: Objection, lack of I

l i

23 foundation.

It is not a fact as stated by the

[)D 24 questioner.

8-25 MR. FISKE:

It is a fact, Mr. Glassman, 9

,-,w~

,,m---,,,,

-e

, ~,,,,,,,

1 Bears 204

('%.

2 but we can debate that later, 3

Q I will make the question simpler.

4 Did anyone bring to your attention

(

5 anytime before the Three Mile Island accident, the' 6

fact that someone in GPU or Met Ed had related the 7

existence of a bubble or steam in the reactor coolant 8

system to pressurizer level?

9 A

To a change in pressurizer level?

10 Q

Yes.

g 11 MR, GLASSMAN:

Objection, 12' Q

Let me put it again.

O k'

13 Q

Did anyone bring to your attention before 14 the Three Mile Island accident that someone in GPU or 15 Met Ed had concluded that the existence of steam or 16 a bubble in the reactor coolant system had affected 17 the level of water in the pressurizer?',

18 A

No, nobody brought that to my attention.

19 Q

Is that something you would like to have 20 known before the accident?

21 MR. GLASSMAN:

Objection.

Don't answer 22 that.

23 MR. FISKE:

What?

[)

24 MR. GLASSMAN: I said, " Don't answer that."

s,--

25 MR. FISKE:

Are you instructing him not

1 Beers 205 2

to answer?

3 MR. GLASSMAN:

That's correct.

4 Q

Let me show you a document which has been

(

5 previously marked as B&W Exhibit 558 which is 6

captioned, " Nuclear Power Preparatory Training Corps 7

Performance For A Course For Metropolitan Edison 8

Company by Videotape by NUS Corporationi Rockland, 9

Maryland."

10 I ask you a preliminary question,'whether 11 or not you were aware at any time before the accident 12 that Met Ed had contracted with NUS Corporation to have 13 11US Corporation supply to Metropolitan Edison, course 14 materials including materials on core performance.

15 A

I was aware the training department had 16 contracted with NUS, but I don't recall the specific 17 content of the training program.

i 18 Q

Let me ask you whether in the course of 19 your own training at Met Ed when you were' going 20 through the training program as well as the time when 21 you were supervisor of licensed training, did you 22 see this particular -- did you see this exhibit which I

23 is 5587 l

24 A

No, I did'not.

()

25 Q

Let me direct your attention to page 4-20.

I

1 Beers 206

[~h

\\m/

2 Do you have that in front of you?

3 A

Yes.

4 Q

There is a paragraph which reads as

(

5 follows:

"The reactor coolant in the PWR system is 6

kept under pressure to prevent bulk boiling in the 7

core.

In the case of an abnormal transient where 8

this pressure is lost and some steam is generated in 9

the core, how will we know it?

We will see a large 10 increase in level in the pressurizer until pressure 11 is built back up above the saturation value 12 corresponding to the temperature in the core.

Steam

[

13 bubbles will then condense and the level will drop 14 back down close to its normal value."

15 Is it your testimony that you never saw 16 that part of the Met Ed training materials at any 17 time before the Three Mile Island accident?

18 MR. GLASSMAN:

The witness just testified 19 that he hadn't seen the entire volume.

20 MR. FISKE:

I understand. I am asking the 21 question again in response to this particular 22 paragraph.

23 A

That is my te s t'ino ny,

i

/~T

()

24 Q

Is it your testimony that it never came 25 to your attention, Mr. Beers, at any time before the

'i,

1 Beers 207 O

U 3

accident that when steam is generated in the core, 3

you w uld see an increase in level in the pressurizer?

4 A

I have already testified to that.

(

5 Q

I think you mentioned once before, 6

Mr. Beers, the existence of users group meetings 7

at B&W.

8 A

I did?

9 Q

Did you?

Let me withdraw it.

10 Were you aware before the Three Mile 11 Island accident that B&W sponsored something called 12 users group meetings?

13 A

Certainly.

14 Q

And you knew, didn't you, that people 15 from Metropolitan Edison attended those meetings?

16 A

Yes.

17 Q

Mr. Miller was the station superintendent, 18 was he not, for both Unit I and Unit 2 in 1978?

19 A

Yes.

~

20 Q

What.was Mr. O'Hanlon's position in 1978.

21 A

Mr. O'Hanlon held several positions at 33 Three Mile Island.

His last position prior to his l

23 leaving was Unit 1 superintendent, i

24 Q

Did anybody at Met Ed ever tell you at 25 anytime before the Three Mile Island accident that e-

--e-

~, - - - -, -

e,.-,,

.r,-.,

..--.---,,-n-,,,,,a-,,

-m.-,,e-

,..,.-,,.,e,--e e

1 Beers 208 2

Mr. Miller or Mr., O'Hanlon had learned at a users 3

group meeting that in the Davis-Besse transient of 4

September, 1977, that there had been an increase in

(

5 pressurizer level accompanied by saturation in the 6

reactor coolant system?

7 A

No, I don't recall being informed of that.

8 Q

Mr. Beers, the record indicates that 9

in January, 1978, an audit team consisting of 10 Messrs. Troffer, colitz, Tsaggaris and Shurke 11 interviewed approximately 50 supervisory personnel 12 in the course of the audit of TMI.

r^s 13 Were you one of the people that was 14 interviewed?

l l

15 A

Who were the people again, Mr. Fiske?

16 Q

Mr. Troffer, Mr. Colitz, Mr. Tsaggaris 17 and Ms. Shurke..

i l

18 A

This is when?

I Ig Q

January, 1978.

~

l 20 A

I don't recall that specific audit.

21 Q

And you don't recall being interviewed by (m

I l

l 99 any one of those four gentlemen in or about January, 23 1978 to express your views?

t

[)

24 A

I know the people.

One of them is a s-25 woman. I just don't recall.

i l

l 1

Beers 209

/~'

N.)}

2 Q

Is that Ms. Shurke?

3 A

Yes.

4 Q

Let me show you again Exhibit 555.

It's

(

5 a GPU document listing various personnel in various 6

positions in the training department at various points 7

in time.

8 Directing your attention specifically to 9

the last two columns and having that in front of you, 10 can you tell us, Mr. Beers, what was the composition 11 of the training departmen.t in the period of time 12 from July 1,

'78 through the Three Mile Island n

N/

13 accident?

14 MR. GLASSMAN:

Can I have that read 15 back?

l 16 (Record read. )

17 MR. GLASSMAN':

.Do you want Mr. Beers 18 to read what is on the document, or do you want testimony aboui his 19 him to give us some 20 recollection?

21 MR. FISKE:

I want him to give us his 22 best recollection.

If the document is helpful l

23 to him, in that effort, he can use it.

l

(

24 Q

First of all, it's true, isn't it, that 25 during that period of time Mr. Zechman was either l

L

1 Beers 210 s

(G 2

acting supervisor or supervisor?

3 l

A That's correct.

4 Q

And then you were supervisor in charge of 5

licensed training, and Mr. McCormick was group 6

~

supervisor in charge of non-licensen training, is 7

that correct?

8 A

That's correct.

~

9 Q

There are four names listed here under 10 t

March 28, 1979.

Can you read those for us?

11 A

1. 797 12

('S Q

Yes, the last column.

V) 13 A

D.J.

Boltz, E.W.

Orvig, I think C.E.

14

Husted, and K.M.

Tennis, and then D.

Brown.

15 Q

Were Mr. Boltz, Mr. Orwig and Mr. Husted 16 and Mr. Brown instructors in the training department 17 during the period of time between July 1,

'79 and 18 the Three Mile Island accident?

19 A

As you see over here in the March '78 20 column, Mr. Husted's name does not appear.

So, I 21

(

don't know exactly what time Mr. Husted came into 22 f

the department, i

23 But the column as listed is correct, that b

24

\\~2 those four people were instructors at the time of the 25 accident.

1 Beers 211 2

Q As you note, Mr.Husted came into the 3

department sometime after March 1,

'78, is that 4

correct?

([

5 A

Yes, 6

Q Were there any other instructors from 7

the period July 1,

'78 to the date of the accident 8

other than Mr. Boltz, Mr. Orvig, Mr. Brown and 9

Mr. Husted for whatever period of time that he was 10 there?

t 11 A

Well, these people as listed here were 12 the permanent instructors for the training department.

O(>

13 Without a complete review of all the classes that were 14 taught during the period in question, I can't give you l

15 a complete answer because once in a while we would 16 ask someone from the plant to teach a class for us if 17 it was in that area of expertise, 18 Q

I understand that, but putting those 19 people aside, there were no permanent instructors 20 that were part of the training department other than 21 the gentlemen whose names are listed here?

k 22 A

That'r correct.

l 23 Q

Isr.*c it correct, Mr. Beers, that

(

)

24 during this period of tim e from July '78 through x_/

25 the date of the accident, that you felt that you

..g_.--,-.4

1 Beers 212 7sc) 2 should have more people in the training department?

A Well, we'had a rather heavy workload, as 3

4 I testified beforo.

We were putting in some overtime.

(

5 But as I have also testified, we had a group of very 6

dedicated and very responsible peopla, and we were 7

doing the job.

8 Q

Isn't it a fact that you felt that if you had 9

had more people in the training department, you could 10 have expanded the scope of the training?

11 A

Well, I believe that improvements can 12 alwaps be made to any program.

O)

(-

13,

Q Didn't you feel during this period of 14 time that you wanted more people so that you could do 15 a better job of training the operators than you were 16 doing?

i 17 A

No, Mr. Fiske.

That was not,my main 18 concern.

My main concern was to reduce the amount

}9 of hours that the people that were wcrkin'g for me 20 were putting in.

21 Q

Let me show you a document, Mr. Beers, 23 that has been marked as Exhibit 561 and ask you l

23 whether you have ever seen that before.

1

(-

24 MR. GLASSMAN:

Are you excluding, I 25 assume, any viewing with counsel?

1 Beers 213

~%,

(d 2

MR. FISKE:

Yes, I will exclude that.

3 A

No, I never saw this document before.

4 Q

Do you see at the top there it says,

(

5 "TMI-2 Investigative Task Force Interview," and then 6

it says "TMI 10/18/79"?

7 Do you see that?

8 A

Yes, I see that.

9 Q

It says "0930 Training."

10 A

Yes.

t 11 Q

Then it lists:

Zechman, Beers, 12 McCormick on the left and Bob Keaten, Ed Wallace, b'J 13 Bob Long and Ron Williams on the right.

14 A

Yes.

15 Q

Do you remember participating in an d

16 interview with Mr. Zechman and Mr. McCormick that was i

17 conducted by Mr. Keaten and others?

1 18 A

No, I don't racall this interview.

19 Q

Do you'know who Mr. Keaten is"?

20 A

I know him to see him.

21 Q

Were you aware after the Three Mile I sland 22 accident that there was a group of people within the l

l 23 GPU organization who had been asked to conduct a i

l l

24 post-a'ccident investigation on behalf of GPU?

~

25 A

I don't recollect one way or the other.

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

---.,.,,,...~ -~.

n,-, - -, - - - - - -,.,,

1 Beers 214 bl V

2 Q

The,first sentence of this memorandum reads:

" Greatest burden seen by these training 3

4 department managers has been the limit on the size of

(

5 the training department staff."

6 Did you ever make such a statement to 7

Mr. Keaten, Mr. Wallace, Mr. Long or Mr. Williams?

8 A

I don't recall any such statement.

9 Q

Did Mr. Zechman or Mr. McCormick make any 10 statement to that effect in your presence?

11 MR. GLASSMAN:

Are we talking about these 12 people making a statement, Mr. Zechman or

(

\\

13 McCormick making a statement to this group in 14 the presence of Mr. Beers?

15 MR. FISKE:

Yes.

16 MR. GLASSMAN: Ee can't say~ that.'The witness 17 doesnt even recall this interview. I don't know l

18 how he can recall the particular it'em you have l

19 just mentioned.

~

20 MR. FISKE:

He can answer the question.

21 A

I'm sorry, Mr. Fiske, I didn't hear you.

22 Q

Did Mr. Zechman or Mr. McCormick make a 23 statement to that effect in your pre'sence to

[)

24 Mr. Keaten, Wallace, Long or Williams?

\\_/

25 A

I don't recall any such statement, e

1 Beers 215 O

2 Q

I will tell you what I would like to do, 3

Mr. Beers:

There have been four sets of notes 4

Produced by GPU of this interview, all of which have

(

5 been marked as exhibits, and what I would like to do 6

is to show you all four sets of notes together with a 7

typed version of.the notes which translated the 8

handwriting and I will ask you to sit here and you 9

can read the written notes or you can read the typed 10 notes, you can read both.

t 11 Take as much time as you want to read all 12 four.

When you get all through, I am going to ask 13 you whether, after reading all four of those sets 14 o f notes, it is still your testimony that you don't, 15 recall any such interview, 16 Okay?

17 A

Fine.

18 MR. FISKE:

I think the record should 19 indicate that we are handing to Mr.' Beers, COP es of Exhibits B&W 359, B&W 358.

The i

20 21 witness already has B&W561 and the fourth one 22 we are handing over is B&W Exhibit 625.

I 23 Q

I will also give you our own typewritten t

24 versions of those handwritten exhibits in the hopes s_,

25 htat that will make it easier for you to review them.

~

- - +. - -. _, -.,.

y

,,...,,,.-,.y.,e e

y.

,.,..,~,~~,.,.y.y-_

1 Beers 216 2

I will stress th a t the authentic document 3

is the handwritten one.

The typed ones are simply 4

for our use and yours in being better able to read

(

5 the handwritten.

6 MR. GLASSMAN:

I don't know what you mean 7

to imply by the word " authentic "

I don' t know 8

what particular notes you are referring to here 9

or who wrote them or what the background of 10 these might or might not be.

t 11 For whatever they are worth, Mr. Beers 12 does have them in front of him.

O

\\'J 13 MR. FISKE:

I am referring to the notes 14 that were written by the four gentlemen who 15 conducted the interviews.

r 16 MR. GLASSMAN: I am not sure what has or 17 has not been established.

18 MR. FISKE:

You can reserve your position, 19 Mr. Glassman, if you wish.

^

20 Q

Mr. Beers, have you had sufficient time 21 now to review the four handwritten exhibits and the l

22 four typed aid memoirs?

23 A

I have reviewed the exhibits.

(

24

'Q Having reviewed those exhibits, is it 25 still your testimony that you do not recall being

1 Beers 217 4

2 interviewed by Mr. Keaten and others?

3 A

I can't recall the interview.

4 Q

At the time you went into the training

(

5 program from your position as shift supervisor --

6 A

The training department.

7 Q

At the time you went into the training 8

department from your position as shift supervisor, 9

was Unit 2 on a 5-shift basis?

d 10 A

We changed back-and-forth from 6 shift 11 to 5 shift to 6 shift more than once.

Specifically, 12 4

at that time frame, I'm not positive what condition 13 we were in.

14 Q

This is Unit 27

~

15 A

Either unit.

16 Q

You don't remember now with respect to 17 either Unit 1 or Unit 2 whether they were on a.5-shift 18 or 6-shift basis during the summer of 19787 19 A

I just don't recollect one way or the 2

20 o th'e r.

21 Q

You had an attendance problem, did you not, k.

I 22 in the training department during the summer and fall i

U of 19787

(

24 MR. GLASSMAN:

In the entire training 25 department or do you want the department itself?

1 Beers 218 2

Q You had a problem, did you not, in the, 3

training department in attendance by operators that 4

were supposed to be attending classes and did not?

([

5 A

We did not have 100 percent attendance 6

of the licensed operators.

7 Q

Let me show you, Mr. Beers, three 8

documents that have been previously marked as B&W 9

Exhibit 303, B&W Exhibit 304 and B&W Exhibit 776, 10 dated September 1 and November 2, 1978, respectively.

11 Do you have those in front of you?

12 A

Yes, I have the documents in front of me.

[\\/

13 Q.

Now, the first one, Exhibit 303 is a 14 memorandum dated 2/1/1978, which states that "For the 15 first five-week requalification training program 16 cycle which was completed on June 9, 1978, our 17 records show an overall attendance of 44_ percent for 18 licensed personnel during this period "

19 Do you see that?

~

I 20 A

Yes.

21 Q

The September 1,

1978 memorandum which 22 is Exhibit 304 which was written by you says after 23 quoting figures, "The above figures show a very slight

(

24 improvement but overall approximately half the 25 licensed people are not attending requalification

1 Beers 219 bv 2

training."

3 Do you see that?

4 A

Yes, I see that.

(

5 Q

Then the third memo, Exhibit 776 also 6

written by you on November 2,

1978 after quoting some 7

figures says, "The above figures show a decrease in 8

attendance from the last report."

9 Do you see that?

10 A

Yes, I see that.

11 Q

The same memorandum says, "The training 12 records show an overall attendance of 35 pdrcent for O

13 all licensed personnel during this period."

14 Do you see that?

15 A

I believe that number is 36.

4 16 MR. GLASSMAN:

You are now referring to 17 B&W 7767 18 MR. FISKE:

Yes.

19 MR. GLASSMAN:

This i. J the document that 20 says "The decrease in attendance from the last 21 report" and continues "traini.sg math 22 review, reactive balance review as well as 23 other worthwhile training"?

(

24 MR. FISKE:

Yes, I think that is talking j

v 25 about a different cycle.

8 I

1 Beers 220 (h

~

2 A

No, it's talking about that cycle.

3 Q

The part that says, "The present 4

requalification cycle" in other words, the next to 5

the last paragraph in that memo refers to the same

({

6 cycle that is referred to in the first sentence?

7 Is that your testimony?

8 A

I can't be certain.

9 Q

Now, Mr. Beers, these memoranda are 10 directed to, among others, Mr. Miller,.Mr. Floyd, 11 Mr. Seelinger.

12 Do you see that?

Ok-13 A

Yes.

14 MR. GLASSMAN:

Wait a second; are you 15 talking about a particular memo?

Mr. Miller's 16 name doesn't appear on Exhibit 303 unless I'm 17 blind.

18 Q

Your memos, Mr. Beers, were sent to 19 Mr. Miller. Mr. Floyd and Mr. Seelinger,'among others, 20 is that correct?

J 21 A

Yes.

22 MR. GLASSMAN:

We are now talking about the 23 two documents, B&W 304 and 7767

[))

24 MR. FISKE:

Right.

\\.

25 MR. GLASSMAN:

We can all read.

i Beers 221 2

Q Mr Go dman s mem June 21 was sent also to Mr. Seelinger, isn't that correct, among others?

3 4

4 MR. GLASSMAN: *You are'asking whether he

(

5 knows that of his own knowledge or from reading 6

the document?

7 Q

You knew that, didn't you?

8 A

I don't know that, Mr. Fiske. I was not 9

in the training department at the time.

10 Q

You didn't review this memo before you 11 wrote your memo on September 4, indicating that the 12 figures

. withdrawn.

O-'

13 Didn't you read and review Mr. Goodman's 14 memo of June 21, before you wrote your memo of 15 September 17 16 MR. GLASSMAN:

You don't want him to 17 guess now?

18 MR. FISKE:

No, I want his recollection s 19 A

I believe that I reviewed the' body of the 20 memo, but I don't recollect reviewing the addressees, 21 Q

Can you tell us now, Mr. Beers, whether i

22 during this period of time between June '78 and 23 November

'78, there was any different shift cycle for

()

24 Unit 1'than there was for Unit 27 25 A

As I have earlier testifiad, we changed

1 Beers 222 2

from 6 to 5 to 6 and so on. several times. I really 3

don't recall.

4 Q

Do you recall any particular reason in the 5

summer of 1978 why Unit 2 would have been on 5 shifts

(

6 instead of 67 7

A Well, I recall an orientation program 8

whereby we were sending Unit 2 people to Unit 1 for 9

orientation and familiarization in the Unit 1 control 10 room.

They worked right with the Unit 1 control 11 room operators, because that unit was on line at the 12 time.

13 When we were doing this, it nece,ssitated 14 some reduction in the staffing down at Unit 2 15 because we were still staffing that unit also.

That 16 may have been one reason that there,were five shifts 17 at Unit 2.

18 Q

Did you suggest to anybody during the 19 summer or fall of 1978 that Unit 2 ought 'to go on to 20 six shifts?

21 A

You mean me personally?

22 Q

Yes.

23 A

I just don't recollect.

l l

)

24 MR. FISKE: I think this is probably a good 25 time for lunch.

(At 12:30 a luncheon recess was taken.)

l.

1 Beers 223

,0

\\

s

\\'#

2 AFTERNOO N S E S S I ON 3

2:00 p.m.

4 EXAMINATION BY S

MR. FISKE: (Continued)

((

6 Q

Mr. Beers, were you familiar before the 7

accident with the concept known as the pressure 8

temperature envelope?

9 A

Mr. Fiske, are you referring to some 10 figures that are found in the technical specifications?

11 Q

I am talking about a concept that 12 required keeping the relationship between pressure

(/

s_

13 and temperature in a certain boundary.

14 A

Well, we had various cu,rv e s and 15 procedures and tech specs and so on that had 16 temperature as one ordinate and pressure as another 17 ordinate.

18 I'm not sure which one of those types of 19 things you are questioning me about.

~

20 Q

I show you a document which has been 21 marked as B&W 572 which is a copy of the Section 2.0 k

22 of the technical specifications and it is captioned, 23

" Safety Limits and Limiting Safety System Settings,"

r

[~

24 and I direct your attention to page 2-1, right at the b) 25 top, the very first item says, "2.1 Safety Limits"

1 Beerr 224 O

2

" Reactor Core." "The combination of reactor coolant 3

core outlet pressure and outlet temperature shall not 4

exceed the safety limit shown in Figure 2.1-1."

(.

5 Do you see that?

6 A

Are you referring to the figure 2.1-17 7

Q Yes.

8 A

Yes.

9 Q

And that indicates in sort of a graph form, 10 does it not, an area referred to as acceptable 11 Operation?

12 A

There is an' area of the curve defined as 13 acceptable operation, yes.

14 Q

And you understood, didn't you, before 15 the accident that it was necessary to maintain the 16 pressure-temperature relationships within that area 1

17 of this graph marked " acceptable operat' ion"?

18 A

During the time that the pladt was in 19 Mode 3 and 2, yes.

20 Q

For the benefit of the reader, Modes 1 and 21 2 are what?

22 A

Mode 1 was power operation and Mode 2 23 I can't recall the exact name.

But if you were at I

[v) 24 less than 5 percent power, you were in the shutting 25 down.

-. -... -- -.- ~

1 Beers 225 2

Q Do you see the line sort of going on the 3

right-hand side of the page?

4 A

Yes.

You mean the one the diagonal

(

5 11h87 6

Q tea.

7 A

Yes.

8 Q

What did you understand that line g

represented?

10 A

Safety limit.

11 Q

Why did you understand that allowing the 12 Pressure-temperature relationship to go on the wrong

\\-

13 side of that line presented a safety problem?

e 14 MR. GLASSMAN: Objection.

Lack of 15 fo'undation.

He didn't talk about there being a 16 Problem He talked about there being a 17 representation of the curve, the words used on 18 this particuar chart.

l 19 Q

You can answer, Mr. Beers.

~

20 THE WITNESS: I've got to hear the question 21 again.

(,

l 22 (Record read.)

I 23 A

It's my recollection that the basis of j

I~T gg that line was to not allow the reactor coolant system

%-]

l.

(

25 to reach a condition called " departure from nucleate i

s 1

l 1

Beers 226 O

2 boiling "

3 Q

What did you understand was the safety 4

problem that was presented by a departure from

(

5 nucleate boiling?

6 A

The heat transfer characteristics are 7

markedly reduced once you have exceeded this point.

8

'Q And you knew, did you not, that if you 9

allowed the pressure-temperature relationship to -

10 deteriorate to the point where there was a departure 11 from nucleate boiling, that presented a risk of 12 damage to the cere?

O

./

13 MR. GLASSMAN:

Can I have that read back.

14 (Record raad.)

15 A

I believe I answered that in my previous 16 answer here, that when you reach a point of DNB, you 17 have reduced the heat transfer characteristics and 1

i 18 if the core was producing a significant dmount of 19 decay heat, you would possibly not be abl'e to transfer 20 that heat away rapidly enough.

21 Q

And that could, in turn, result in core 22 damage, correct?

23 THE GLASSMAN:

Are you asking the witness l

~

24 to speculate?

25 MR. FISKE:

No, what he understood before l

I

1 Beers 227 IO t

1 2

the accident.

A What do you mean by " core damage,"

3 4

Mr. Fiske?

5 Q

Damage to the cladding.

(

6 A

Are you saying if somehow you got to the 7

right-hand side of this curve?

8 Q

Yes.

9 A

Then there is a' possibility of clad 10 damage.

11 Q

Correct.

Didn't you understand that 12 before the accident?

13 A

Yes, I understood that.

14 Q

And you understood that there was a 15 Possibility of cladding damage which could cause the 16 release of fission products to the reactor coolant?

i 17 A

Depending on the extent of the clad damage,

18 it's conceivable that you could release some fission 19 products to the reactor coolant.

20 Q

Is that what you understood was meant by 21 the reference to the departure from nucleate boiling 23 line on this graph as a safety limit?

23 A

I would like to review the basis of this 24 tech spec to refresh my memory.

25 Q

I think it appears at page B2-1 of this r

l

1 Beers 228 2

same exhibit.

If I can read you the first 3

sentenco --

4 MR. GLASSMAN:

What is the page number?

(

5 MR. FISKE:

B2-1.

6 Q

It says, "The restrictions of this safety 7

limit prevent overheating of the fuel cladding and 8

possible cladding perfor.ation which would result in the 9

release of fission products to the reactor coolant."

10 A

Let's go back and repeat the question for 11 me once more.

12 (Record. read. )

(3 k*

13 A

I think I would just like to reiterate 14 what I said before, that the basis of this line here 15 is to preclude you from reaching the point at which 16 you might have a departure from nucleate boiling 17 condition.

18 The line to the left of this is the formula

~

19 for which a reactor protection system setting is 20 derived and if you should'go to the right of that line, i

21 the reactor would be automatically tripped.

22 Q

Is it fair to call this diagonal line, I

23 for purposes of reference here, a departure from

()

34 nucleate boiling line.

25 MR. GLASSMAN:

We now have two diagonal

-,,.----.,.>v-

.m.,

w

,,.ry

,,,,,..,n-,- - -. -

1 Beers 229 O) s 2

lines we are talking about, Mr. Fiske.,

N/

3 MR. FISKE:

I am talking about the one 4

referred to as the safety limit.

(

5 A

No, I would not like to say that once you 6

reach that line, that you automatically have 7

departure from nucleate boiling.

Departure from 8

nucleate boiling is not a measurable parameter.

There 9

was no meter on the console that indicated departure 10 from nucleate boiling. I'm sure there.are safety 11 fa'ctors built into this line such that when you i

12 reach -- if for some unfathomable condition, you

(~(,,)

13 would reach that line, it's not necessary that you 14 would have departure from nucleate boiling.

15 Q

Did you understand that the reason this 16 line was referred to as a safety limit was that'if 17

-pressure temperature relationship fell to the right 18 of that line, you ran a risk of possible~ clad damage 19 which would result in the release of fission 20 products to the reactor coolant?

21 A

Yes, I understood that.

22 Q

Mr. Beers, you were familiar before the i

4 23 Three Mile Island accident, were you not, with the

/~'-

24 heat-up cool-down curve which was part of a number k

25 of emergency and operating procedures at Unit 27

1 Bears 230 2

A I recall that.

3 Q

Let me show you a copy of this curve which 4

has been taken from the unit heat-up procedure g,

5 2101-1.1 which we will mark as the nex t B&W exhibits 6

(Document consisting of a copy of a 7

report entitled "Three Mile Island Nuclear 8

Station, Unit 2 Operating Procedur'e 2101-1.1,-

9 Unit Heat-Up," was marked B&W Exhibit 895 for 10 identification.)

3 11 Q

Do you have that in front of you, 12 Mr. Beers?

13 A

Yes.

i 14 Q

There are a number of'different lines on 15 this figure, are there not, representing different 16 pressure-temperature relationships?

17 A

There are a number of different lines on 18 the curve.

It's a rather complicated curve.

The 19 different curves are referring to differeht limits.

20 Q

Well, let's look a% for the noment, at 21 Curves 2 and 3.

22 Do you see those?

I 23 A

Yes.

l 24 Q

What did yo'u understand those curves 25 represented?

1 Beers 231

(~)

~#

MR. GLASSMAN: You want the witness to 2

3 read the language or just his understanding in i

4 the abstract?

5 MR. FISKE: I want him to tell us what his

{

6 understanding was before the accident of what 7

those curves represented.

If he wants to look 8

at the language on the right-hand side to answer 9

the question, that is okay.

10 MR. GLASSMAN:

Do you hav,e the page?

11 MR. FISKE:

0812 on the bottom right-hand 12 side.

\\/

13 A

It looks like page 22 or something.

14 These two curves, Curves 2 and 3, were ured on 15 cool-down,and the major difference between the curves 16 depended on whether you had reactor coolant pumps 17 running or not.

18 Q

What was the purpose of those two curves?

19 MR. GLASSMAN:

You mean how were they 20 used or what was the theoretical underpinning?

21 Q

Did you have trouble understanding that 22 question, Mr. Beers?

Before the accident, what did l

23 you understand was the purpose of those curves 2 and O

94 37 N.)

~

25 MR. GLASSMAN: I only make the objection

1 Beers 232

(~%

~

2 because we are having a lot of questions about 3

theory and understanding, not necessarily 4

relating to use and operation.

Now, you have i

(

5 switched from the use of the word " understanding" 6

to the use of the word " purpose."

7 MR. FISKE:

I said what did he understand 8

was the purpose of the curve.

9 MR. GLASSMAN:

Doubly confusing.

Maybe 10 we as lawyers understand the implication of the 11 various words, but we have been sometimes 12 talking about purposes and sometimes we are k-13 talking about operations, 14 BY MR. FISKE:

15 Q

Do you have any trouble understanding i

16 what I am asking you, Mr. Beers ?

17 A

My understanding of the curve is to 18 maintain compression on the fuel clad.

19 Q

Which side of the urves 2 and 3 did you I

20 understand the operators were supposed to stay on?

21 A

I don't know how to describe it to you l

~

99 in words.

On the left-hand side of the curve as you i

l l

23 are looking at the curve.

l ()

24 g

Why did you understand it was important 25 for the operators to stay on the left-hand side of l

1 Beers 233

/'N U'

2 those curves?

A I can answer you, Mr. Fiske, but it will 3

4 not be a short answer.

We have to go into the theory

({

5 of the, fuel pins and everything that is associated 6

with how the fuel pin is constructed and so on.

7 Q

You understood, did you not, that there 8

was pressure on the inside of ths fuel pins?

A Yes.

There was helium.

0, 10 Q

Didn't you understand the reason you had 11 to stay on the left-hand side of the curve,. curves 2 12 and 3, so there would be sufficient pressure on the s) 13 outside of the fuel pins to prevent damage to the pins 14 from occurring as a result of an imbalance of pressure?

i 15 A

No, Mr. Fiske.

That is not my exact i

16 understanding of that.

17 The fuel pins are fabricated down at

~

18 Lynchburg and during their fabrication, even though 19 they are a tube-like assembly, it is concbivable 20 that there may be microscopic cracks in the cladding 21 such that if you did not maintain the proper delta L

22 pressure, if you will, between inside and outside, 23 there might be some gravitation of gases, radioactive l

[~))

24 gases or minute fission products out through these 25 microscopic cracks.

l 1

1 Beers 234 2

I might add th a t the microscopic cracks are there when the fuel pins -- s: hen the fuel assembly 3

4 is brand new.

5 Q

Did you understand staying on the left-hand

((

6 side of these curves had anything to do with 7

preventing possible damage to the fuel pins?

8 A

I believe it was my understanding that if 9

you did not stay on the proper side of these two 10 curves that we are discussing, that you might 11 Propagate some of these microscopic cracks.

12 Q

By " propagate," you mean increase them?

(

13 A

Yes.

14 Q

Now, the curves to the right of Curves 2 15 and 3, there are two curves designated "5"

and "6."

16 Do you see those?

17 A

I can't read the numbers.

'Is that the 18 two numbers down here at the bottom?

19 Q

Yes.

~

20 A

Right above "200" there?

21 Q

Yes.

23 A

Yes, I see those two curves.

23 Q

Are those so-called net-positive

(

24 suctionhead curves?

25 A

Yes.

t

1 Beers 235

Q Did the operators at Three Mile Island 2

receive training as to which side of those curves 3

4 they were supposed to stand on?

.(

5 A

Yes, they did.

6 Q

Which side of the curves were they 7

supposed to stay on?

8 A

To the left and above the curve.

9 Q

Do you recall the line from the figure in 10 the tech specs that was referred to as.the safety 11 limit that we were discussing earlier?

12 A

Yes.

\\'

13 Q

Did you understand that the pressure-14 temperature relationships reflected on that line were 15 such that if you drew that line on this particular l

16 exhibit, that that line would appear to the left of l

l 17 the positive suctionhead curves?

l t

18 A

No.

19 Q

Where did you understand that line would 20 be?

i 21 A

That would be over in here somewhere.

l 22 Q

To the right of the not positive 23 suctionhead curves?

24 A

Yes.

25 Q

Why did you tell the operators it was 4

l b

1 Beers 236

(~h

^

N~

2 important to stay on the left-hand side of the net 3

positive suctionhead curves?

4 MR. GLASSMAN:

You are asking why 5

Mr. Beerd personally told them or what was

{

6 taught in the training program or what?

7 Q

To your knowledge, Mr. Beers, were the 8

operators at Met Ed trained that they should stay on 9

the left side of the net positive suctionhead curves?

10 A

Yes.

11 Q

What was your understanding for the 12 reason why they were told they should stay on the 13 left-hand side of the curve?

14 A

To prevent cavitation of the reactor 15 coolant pumps.

16 Q

Does cavitation involve a process which 17 starts with the formation of steam bubbles at the eye 18 of the impeller to the reactor coolant pumps?

19 A

At the initiation of cavitation, as I 20 understand it, you will produce a two-phase mixture 21 at the eye of the pump with various sized bubbles 22 interspersed with the solid fluid.

23 g

Is it correct that it was the purpose l

f')

24 of the net positive suctionhead curve to maintain v

l 25 pressure e such a level so that those bubbles

- ~

1 Beers 237 O

2 would not form?

3 A

well, it's a combination of absolute 4

pressure and the weight or the height of the water

((

5 that is being imposed on the suction of the pump.

6 Q

There is nothing on this curve, is there, 7

that takes into account the height or weight of the 8

water?

9 A

Not visibly on the curve.

It's built into 10 the way the curve is developed, These things I just 11 addressed are built into the design of the points 12 for the generation of the curve.

13 Q

Did you understand 12efore the accident, 14 Mr. Beers, that if the operators maintained pressure 15 temperature relationship on or to the left of the net 16 positive suctionhead curve, the system would be 17 subcooled?

18 A

I don't think that we discussed 19 subcooling or lack of subcooling.

We discussed it in 20 the vein that if you stayed to the left and above this 21 curve during reactor coolant pump operation, that you k

22 would prevent cavitation to the reactor coolant pumps.

i 23 Q

You knew what the phrase "subcool" meant

[)

24 before'the accident, didn't you?

\\_/

25 A

I don't recall one way or the other k

1 Beers 238 i

s

\\_)

2 whether we ever used that phrase p,rior to the 3

accident.

4 Q

You knew what the phrase " saturation" meant 5

before the accident, right?

(

6 A

Yes.

We discussed we had those conditions 7

in the pressurizer.

8 Q

You knew if the operators maintained the 9

pressure-temperature relationship at or to the left 10 of the net positive suctionhead curve,.the system 11 would not be saturated?

12 A

Are we now making an analogy between net

, 13 positive suctionhead and the term " saturation"?

14 Q

I don't know what you mean by analogy.

15 My question is simply, didn't you understand before 16 the accident that if the pressure-temperature 17 relationships were maintainedion this curve or to 18 the left of it, that the conditions in the reactor 19 coolant system would not be saturated?

a MR. GLASSMAN: He is asking whether you 20 ever considered that before the accident, 21 k

i 22 Mr. Beers.

23 You are not asking him to today, sit 24 and draw some analogy?

25 MR. FISKE:

Exactly as you said, talking

1 Beers 239

your 3

understanding was that you were supposed to proceed 4

to a cold shutdown?

({

5 A

Once again, Mr. Fiske, it would depend on 6

what the reason for the trip was.

If it was something 7

that could be repaired in a short period of time and 8

a determination was made as to what that problem was, i

g and it was possible to perform that maintenance with i

10 the plant in a partially shutdown condition, that 11 would be the plan.

12 Q

It's correct, isn't it, that before the la accident, part of the procedures dealing with various 14 events that could cause a reactor trip were devoted I

15 to cool-down and shutdown o'f the plant?

16 A

I'm sorry, Mr. Fiske, I don't understand i

17 your question.

i 18 Q

It was recognized before the' accident,

~

19 wasn't it, that after a reactor trip, that it might 20 be necessary to take the plant through a cool-down 21 into a cold shutdown?

(_

22 A

Yes.

i 23 Q

And there were procedures designed for

()

24 that purpose, correct?

25 A

That's correct.

I l

• - + -

.,e

-e,

1 Beers 242

/~

(-}

~

2 Q

And one of those procedures was a unit coo 1-down procedure, correct?

3 4

A That's correct.

5 Q

And the operators received training on 6

that procedure at Met Ed?

7 A

Yes,.they did.

8 Q

Another procedure was the unit shutdown i

9 procedure that we referred to a moment ago?

10 A

Yes.

11 Q

Then there was a procedure, was there 12 not, for decay heat removal through the steam l

13 generator?

14 A

I don't recall that specific procedure.

15 Q

Let me show you a document which has been 16 marked previously as B&W Exhibit 573, Unit 2 17 Operating procedure, decay heat removal._

~

18 Do you have that in front of you?

1 of me.

19 A

Yes, I have the procedure in front 20

'Q

. Looking at it now, does that refresh your i

recollection that that is the procedure that you were 21 22 familiar with before the Three Mile Island accident?

i i

23 A

I aon't recall ever having used this

[~)

24 Procedure.

\\~/

25 Q

Whether or not you ever used it, were l

L

1 Beers 243

(- )

t\\#2 2

you familiar with it?

A Allow me a few moments to review it.

3 4

I just don't recall this procedure, 5

Mr. Fiske.

(( T 6

Q Are you familiar with the procedure 7

called decay heat removal system?

8 A

I recall that procedure.

9 Q

And were the operators trained on that 10 Procedure?

t N

11 A

I believe so.

12 Q

Isn't it a fact, Mr. Beers, that all of

'( -

13 the procedures relating to taking the plant through 14 a cool-down into a, shutdown, contained heat-up

(

15 cool-down curve which we have been discussing earlier I

l 16 this afternoon?

17 MR. GLASSMAN:

You want the witness to 18 sit here and examine all of these?

19 MR. FISKE:

No.

20 MR. GLASSMAN: He testified that some he 21 remembers and some he doesn't.

22 MR. FISKE:

They speak for themselves.

23 Q

Isn't it correct that you understood i

[))

24 before the accident, Mr. Beers, that no matter which 25 Particular procedure the operators were using in the

1 Beers-244 i

2 course of taking the plant through a cool-down and a shutdown, they were required to follow the fuel 3

4 pin compression and not positive suctionhead curves i

5 which are contained on the figure that we have been

({

6 discussing earlier today?

A As you stated, Mr. Fiske, when we 7

i I

8 started talking about this curve sometime ago, there g

are a number of different procedures certainly that 10 contain this curve or similar curves.,

\\

11 I'cannot recollect whether all procedures 12 that have the plant in a heat-up or cool-down mode 13 contain that curve.

14 Q

-Well, let's ask you slightly differently.

I 15 As you sit here today, can you tell us of any 16 procedure that was in existence before the Three Mile j

17 Island accident governing the condition ~of the plant 1

I 18 during the heat-up or cool-down mode which did not 19 have these curves as part of the procedure?

20 A

I just can't recollect one way or the I

21 other.

I C.

22 Q

I think we established earlier, i

(

23 Mr. Beers, that before the Three 1111e Island accident,

(

24 the high-pressure injection system had come on 25 automatically at Unit 2 in March of '78 as a result l

i 1

Beers 245 7'T 2

of a depressurization caused by an open pilot F*****d #*1i*f **1***

3 Remember we went through that yesterday?

4 MR. GLASSMAN: I'm not sure that is

{

5 6

er.actly his testimony.

Whatever it is, it is.

7 Q

Let's put it another way, Mr. Beers, g

if there is going to be any question about this --

9 you knew before the Three Mile Island accident, did 10 you not, in March of 1978, high-pressure injection 11 had come on automatically as a result of a 12 depressurization which resulted from an open pilot 13 operated relief valve?

MR. GLASSMAN:

I object. I think this 14 l 15 precise question was asked yesterday and the

~

16 witness spoke of what he knew at the time of 17 the event and his knowledge of HPI at that time; i

18 and he did not s t'a t e it in the fashion that you 19 stated it.

20 MR. FISKE:

Mr. Glassman, if you listened 21 to my question, you would realize that was not 22 what I was asking him.

Maybe we can have it 23 read back so we can move ahead.

24 Read it again.

25 (Record read.)

1 Beers 246

(-m A

I believe I testified yesterday, 2

i Mr. Fiske, that certainly at the time of the 3

4 incident, I did not understand why HPI came on and

(

5 shortly after the incident, during the critique, 6

there was some discussion as to whether it was a real 7

decrease in pressure that started HPI or the fact 8

that we de-energized some pressure sensors which g

caused the HPI initiation.

10 Q

By the time you became head of the training 11

.for licensed personnel, you knew, did you not, that 12 in the March, 1978 transient, pressure had dropped 13 below the setpoint for the actuation of high-pressure 14 injection?

15 A

After power was restorod and we got our

(

l 16 instrumentation back, I knew what the pressure was l

17 which was below the HPI initiation poin't,.

E l

18 Q

You understand, Mr. Beers, I m not asking 19 you now about what you may or may not hav'e known while I

90 these events were occurring while you were on duty 21 as a shift supervisor?

22 I am asking you now what your knowledge 23 was as of July 1,

1978, three gonths or so after this

(

24 event, based upon things that you had learned during 25 the course of the event and based on anything that l

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

1 Beers 247 y u had learned as a result of discussions, as a 2

result f reading the LER, as a result of writing 3

4 y ur wn superintendant's report for that particular 5

transient, from whatever source you may have learned

](

6 it.

I am simply asking you what your knowledge 7

g was in July of 1978.

D y u understand that?

Do you underreand 9

10 that is what I am asking you?

11 A

I didn't when you started to ask me.

12 Q

Then I am glad we clarified it.

As of 4

13 that time, that is July, 1978, you knew, did you not, g4 that in the March '78 transient, there had been an 15 OPen pilot operated relief valve which had caused i

16 depressurization which was sufficient to bring 17 Pressure down below the actuation point'for high 18 Pressure injection?

19 A

Yes.

~

i 20 Q

And y u knew that high-pressure 21 injection had come on automatically in the course

(

U d

n.)

of that transient, right?

23 A

See, that is the part'that we getto the

.()

24 ambiguity there because I really wasn't sure as to i

25 what actually initiated high pressure injection, I

4 1

Beers 248 t\\"l whether it was actual reactor coolant system 2

3 Pressure or a false signal that was sent to the HPI 4

as a result of a loss of power.

5 Q

Well, you knew that if it was a false 6

signal that had actually actuated it, that it would 7

have been actuated in any event by the drop in 8

Pressure if it went below the setpoint, didn't you?

9 MR. GLASSMAN:

Are you asking him to 10 speculate or a hypothetical?

t 11 MR. FISKE:

What he understood about the 12 way an HPI worked.

' O)

\\-

13 MR. GLASSMAN:

Now you talk with some 14 other concept of how HPI was supposed to work 15 generally and I think we have got a source of 16 confusion here, Mr. Fiske.

You ought to clear 17 it up.

18 Q

Are you confused, Mr. Beers?

19 A

I'm not.

~

20 Q

Okay.

Then can you answer my question?

21 I didn't think you were confused.

k_

i 22 MR. GLASSMAN:

The ques tion had a source 23 of confusion, Mr. Fiske.

1 d

U}

[

24 A

It's my complete understanding if the j

t 25 reactor coolant system pressure goes below 1,600 l

l 1

_.r..

1 Beers 249

)

2 pounds or thereabouts, what,ever the switch is tripped 3

at, high-pressure injection will start automatically.

4 Q

And you knew that that was one possible cause for high-pressure injection having come on in

(('

5 6

the course of that transient, right?

A You mean the open PORV?

7 g

Q Yes.

MR. GLASSMAN:

Are you asking whether 9

10 that was considered?

The witness told you 11 several times his. understanding or his knowledge 12 of what happened on that day.

Now it seems

(~))

(.

13 like you are asking him whether he knew about 14 some other possibility that might have occurred 15 even though he said very clearly what he 16 understood.

17 Q

Let me read you the first sentence of the

?8 LER that was filed by Met Ed through Mr. Herbein --

19 withdrawn.

I w?.11 read you the first sentence of this j

20 special report concerning the TMI-2 ECCS actuation of March 29, 1978.

It was filed by Mr. Herbein with 21 l

(_

22 the Nuclear Regulatory Commission in June of 1978, 23 This is the first sentence of this special 24 report concerning ECCS actuation.

l 25 MR. GLASSMAN:

Could I see a copy of i

i I

1 Beers 250 r

O 2

that-document?

MR. FISKE:

Sure.

It 's E::hibit 170.

3 4

Q "At 14:38:51 hours TMI Unit 2 experienced

(.

5 an automatic actuation of safety injection (the 6

emergency core cooling system ECCS),

due to rapid 7

depressurization of the reactor coolant system (RC ). "

l 8

Do you see that?

9 MR. GLASSMAN:

We can show this document 10 to him again, but I believe ycsterday, unless 11 I'm mistaken, Mr. Beers said that he had 12 recalled seeing the LER that is attached here, 13 but he had not recalled seeing the cover 14 material transmitted to Mr. Grier.

15 Q

Is it still your testimony, Mr. Beers, 16 that you don't remember seeing that report by 17 Mr. Herbein to the NRC on the reason for,the 18 initiation of safety injection?

19 A

As I said yesterday, Mr. Fisk'e, I don't 20 recall the first part of this particular report.

21 Q

Let me then turn to the LER itself which 22 I think you said you did see.

Let me direct your 3

4 23 attention to the second page of the LER under the l

(

24 captio'n Event Description," paragraph 5.

25 The second sentence, "The resulting

,e---

r---

3-

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,------------------+ve 7

W-~--'*NNe

• - +

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1 Beers 251

/~T i

i N/

2 depressurization caused safety injection.

Details of this event will be provided in a special report 3

4 pursuant to tech spec 3.5.2."

(

5 Do you see that?

~

6 A

Yes, sir, Mr. Fiske.

You se,e the 7

sentence right preceding that?

8 Q

Yes.

9 A

That's what I was trying to explain to 10 you, that I wasn't really sure whether it was an 11 actual depressurization or a pressure switch failure.

12 MR. GLASSMAN:

Maybe we should read that

\\_/

13 sentence.

14 THE WITNESS:

Let me read it.

Maybe I'm 15 getting things out of conte::t.

Just let me 16 review this.

17 A

I'm sorry, they are talking about the 18 pressure switch for the PORV.

~

l 19 Q

Did you have any reason befor'e the 20 accident, Mr. Beers, to disagree with the conclusion 21 by Met Ed in the special report and in the LER that C

02 the safety injection resulted from the depressurization j

l 23 of the reactor coolant system?

24 A

No.

x-)

25 Q

And the depressurization resulted, did a

.t nears' 252 0

2 it not, from the fact that the pilot operated relief valve had remained open?

3 I

4 A

Yes, I believe I tehtified yesterday

(,

5 that the reactor coolant system was no longer intact 6

when the valve is open.

7 Q

I think you said that you also learned i

8 that in one other event before the Three Mile Island 9

accident, high-pressure injection had come on 10 automatically.

That being the overcooling event in 11 April of 1978.

12 Do you remember that?

13 A

Yes, we discussed-that briefly before.

i 14 Q

Did you understand, Mr. Beers, that the 15 operators were supposed to react differently if high 16 pressure injection came on as a result of a loss of 4

17 coolant accident than they were if high-pressure 18 injection came on as a result of an overcooling 19 transient?

i 20 A

It's my understanding that in practice, 21 should the high-pressure injection system come on for 22 any reason, the operators would maintain a level in k

23 the pressurizer.

But they would take the necessary 24 steps to maintain a level in the pressurizer within 25 a certain band.

--,,,-n

,-g.,--.----,-.m

->m-

-..-.----->e,--,,-------,,--m

1 Beers 253 2

Q You understood, didn't you, there were 3

written procedures which told the operators what 4

action they were suppose'd to take with respect to

({

5 the termination or throttling back of high-pressure 6

injection?

6 7

A Yes.

8 Q

And you understood, did you not, before g

the accident, that the operators were supposed to 10 follow those procedures in determining whether or i

11 not to throttle back or terminate high-pressure 12 injection?

O-13 A

well, if it was established that you were 14 in a particular casualty by the operator, then they i

15 followed the emergency procedure for that casualty.

16 But it's also conceivable that the, may have been

~

17 in more than one emergency procedure at one time and 18 in those conditions, you had to sequentially, 19 perhaps, measure several different emergency 20 procedures together as we were trained at Three Mile 21 Island and at the simulator for this type of multiple (J

i 22 casualty-type situation.

i 23 Q

Was there any event you knew of before i

24 l

the Three Mile Island that would cause depressurization 25 sufficient to cause HPI to come on other than a

_~.

1 Bears 254 O

2 loss of coolant accident or an overcooling?

3 MR. GLASSMAN: I assume you are now 4

talking about any event excluding the loss'of

(

5 power event in 1978 that he ' testified to?

6 MR. FISKE:

That I think meets the 7

definition of a loss of coolant accident.

8 MR. GLASSMAN:

We may dispute those 9

definitions, Mr..Fiske.

There are all different 10 kinds of situations.

11 A

We are not talking about a manual 12 initiation?

O 13 Q

No.

Automatic we are talking about.

14 A

When you say overcooling, that covers a 15 wide range of secondary side initiated casualties.

16 Q

We have not taken the time in this 17 deposition to go through the definition of an 18 overcooling, but if you think you know what it means, 19 I think I know what it means and I am ready to have 20 you answer the question in that context.

21 A

Now that I understand all the extenuating 22 circumstances, please repeat the question to me.

l 23 Q

Maybe it would be helpful, Mr. Beers, so 24 you are not at all uncomfortable with the question, 25 what I mean by an overcooling.

My understanding is

1 Beers 255 O

^

2 that it has been testified to by other witnesses, is a situation in which there is a drop in pressure 3

4 in the primary system resulting from the fact that a

(

5 temperature drop has caused the volume of water in 6

the primary system to shrink and as a result of that 7

shrinking, pressure goes down and the pressurizer g

level goes down.

9 That is a layman's definition of 10 overcooling as it has been used in these depositioins.

11 With that definition in mind, let me ask 12 you again; isn't it true that prior to the Three Mile 13 Island accident, you were not aware of any situation 14 which could cause a depressurization sufficient to i

15 automatically actuate high-pressure injection other 16 than a loss of coolant accident or an overcooling?

17 A

That is true.

18 Q

Now, did you think as head of the training 19 for licensed operators, that it was impor' tant that 20 the operators be able to tell when high-pressure 21 injection came on, whether it was coming on as a 22 result of a loss of coolant accident or an 23 overcooling?

24 A

Yes, I believe that was important and I 25 believe that a number of the emergency procedures

't

[

i Beers 256 7.

t 2

addresced those different symptoms and the operators sere trained n the different symptoms.

3 4

MR. GLASSMAN:

Let's take a short break, 3

please, Mr. Fiske.

g7 6

MR. FISKE:

Okay.

7 (Recess tak6n.)

g Q

Mr. Beers, let me show you a document that has been marked as Exhibit 272 and ask whethe*

9 10 you recognize that as the loss of reactor coolant slash 11 reactor coolant system pressure procedure for' Unit 2.

12 A

Yes.

/3

(,)

13 Q

It's correct, isn't it, that this 14 procedure is in two parts; part A being leak or 15 rupture within capability of system operation, and 16 part B being leak or rupture of significant size such 17 that engineered safety feature systems are 18 automatically initiated?

19 A

Mr. Fiske, allow me --

20 Q

I am reading --

21 A

Let me review the procedure a moment.

('

l 22 Q

I was reading from pages 1 and 6.

l A

You were reading from --

23 24 Q

From pages 1 and 6.

25 A

There is a Section A to the procedure

1 Beers 257 2

that says it's a leak or rupture within the capability 3

of the system; and Section B is leak or rupture of 4

significant size that ESAS would automatically be 5

initiated.

6 Q

Looking at Section B, you see there, do 7

you not, a number of symptoms listed?

8 A

Quite a number.

9 Q

And you understood, did you not, that 10 those were symptoms of a leak or rupture of such a 11 size that HPI had come on automatically?

12 A

That is not completely true, Mr. Fiske.

'N 13 The safeguards actuation system could have come on

~

14 automatically as a result of, as we classified a 15 little while ago, an overcooling event in which some l

16 of the symptoms for the loss of coolant accident and l

17 the overcooling casualty, would be the same such as 18 decrease in pressurizer level with a corresponding l

19 decrease in the reactor coolant system pressure.

l l

l 20 You had to evaluate the -- the operator 21 had to evaluate those symptoms along with some other l

22 symptoms to make a differentiation whether he had a l

23 loss of coolant accident or whether he had an i

(

24 overcooling event.

25 Q

Would looking at the temperature be one I

i

I 1

Beers 258 O

2 way to tell whether you had an overcooling as 3

opposed --

4 A

You have to be a little more specific.

(~ '

5 What temperature are we talking about?

6 Q

The temperature in the reactor coolant 7

system; temperature after the trip, T ave.

8 A

Let me get the sequence of events in my 9

mind.

We got a reactor trip for some reason to 10 initiate this event, is that correct?t 11 Q

We have a reactor trip and we have a 12 drop in pressure down to the point where high i

e 13 pressure injection has come on at 1640.

14 A

And a corresponding decrease in pressurizerinveld*

15 16 Q

Yes.

And the question is let me 17 start all over again.

18 We are talking about a situation in 19 which the operator sees symptoms which he~ recognizes 20 as symptoms o'f a loss of coolant accident and which 21 he also recognizes as symptoms of an overcooling, k.

i 22 some of which, as you have indiccated, are listed 23 here on page 6.

(

24 As you said, in that situation he has 25 to look elsewhere to determine

1 Beers 259 m

2 A

Re has to look at other parameters.

3 Q

Right.

To determine whether this is a 4

loss of coolant accident or whether this is an

(

5 overcooling.

6 My question is really very simple:

7 Included in the parameters that you would expect 8

the operator to look at to determin,e whether he has 9

an overcooling transient would be T ave, to see 10 whether or not there had been a drop in temperature, 11 isn't that right, that is normally associated with an 12 overcooling?

('N 13 MR. GLASSMAN:

You are talking about a 14 situation when there has been a drop in 15 Pressurizer level and drop in pressure, and you 4

16 are trying to distinguish whether that is 17 symptomatic of a LOCA or overcooling event.

18 MR. FISKE:

I am talking of a situation 19 where there are symptoms, whatever 'they are, 20 that are common to both a LOCA and to an 21 overcooling.

As Mr. Beers said, under those

(_

22 circumstances, he would expect the operators 23 to look for other parameters.

()

24 g

Isn't it correct that one of those 25 parameters that you would expect the operator to e--

y w.

,e

1 Beers 260 f'\\.

O 2

look at to determine whether he had an overcooling transient would be.the temperature?

3 4

MR. GLASSMAN:

Wait a minute, Mr. Fiske.

l.

5 It seems like you are trying to create a 6

hypothetical situation before the accident 7

or in terms of this witness' knowledge just 8

before the accident which didn't occur.

9 He has just testified that as far as he 10 understood, both a LOCA and an overcooling 11 event had symptoms in which pressurizer level 12 dropped and pressure dropped; and in that C-s 1

/

13 situation, if he saw those two symptoms, then 14 he would be confronted with the need to look 15 for other parameters.

16 Now, you seem to be talking about some 17 other hypothetical situation.

18 You can ask if he saw that other situation

~

19 before the accident or considered it.

Otherwise 20 we are embarking on a hypothetical that you 21 know is fraught with difficulty.

22 MR. FISKE:

I am simply asking a general 23 question based on Mr. Beers' understanding 24

'of the training that was given to the operators 25 as to how they could tell the difference

Beers 261 g

(~')

between a loss' of coolant accident and an overcooling and we were dealing with the situation where the operator sees symptoms, 4

(

whatever the symptorgs may be, and I'm not 5

6-confining it to any particular symptoms, that the operator recognizes might be attributable 7

f 8

tio a,' LocA or it might be attributable to an overcooling.

So the operator can't tell one 10 j

way r the other just from thosq symptoms which one he has.

~

17 12 Mr.. Beers said under those circumstances,

(~\\

()

he would expect the operator to'look at other 13 34 parameters and I am simply asking at this point in the questioning, whether one of the 15 16 parameters that he would expect the operator to look at would be temperature.-

17 j

18 MR. GLASSMAN:

As long as we'are dealing i

with* situations that he actually considered, gg 1

and n t some hypothetical.

20 Q

Do you understand, Mr. Beers, my question?

gy A

Certainly.

22 23 Q

Is that an answer to my question whether 24 yu understood it?

A-I understand what the question was.

25

1 Beers 262 I"3

\\"

2 Q

And you have answered it?

A No, I have not answered it.

3 4

It's my recollection, Mr. Fiske, of the 5

Procedures and the training that was given to the

((

6 operators, the ability-to differentiate between a 7

loss of coolant accident and an overcooling event 8

did not include evaluating T ave as a means of g

determining an overcooling event.

10 Q

Did you give the operators training, 11 Mr. Beers, on what kind of system parameters are 12 involved in an overcooling transient?

f"'

k-13 A

I have to refresh my memory on 14 what the overcooling procedure says.

I don't I

15 recollect what that says.

16 A more positive means of differentiation-17 between loss of coolant accident and an overcooling 18 event was some symptoms as listed at the ~ bottom of 19 page 6 of this procedure.

20 Q

We will get to that in just a second.

21 Didn't you understand, Mr. Beers, as a

(.

i 22 matter of fundamental knowledge of the system, that 23 an overcooling transient by definition involves a 24 rapid decrease in T ave?

25 A

Well, it depends an awful lot on the

g Beers 263

(

x.

P ant conditions prior to this overcooling event.

l 2

Things such as how much decay heat was in the 3

4 reactor coolant system prior to the event.

What-was the condition of the steam generator levels.

Was it

(

5 an verfeeding, was it a steam line break.

All of 6

those enter into the rate of decrease of the primary 7

8 system temperature.

9 Q

In every one of those cases there is a 10 significant decrease in the temperatur,

isn't that 11 e rrect?

12 MR. GLASSMAN:

Are you asking the witness'

(~)

f

(_/

13 knowledge now or what he recollects back l

then?

14 15 MR. FISKE:

What ne understood about an 16 vercooling transient before the accident.

17 MR. GLASSMAN:

Are you now asking for some 18 theoretical understanding how he ap' plied i

19 procedures?

20 MR. FISKE:

Please, Mr. Glassman, I am 21 asking him as head of the training for licensed 22 personnel as well as based on his experience 23 as a shift supervisor, for his understanding 24 of how the system reacts in an overcooling 25 transient.

i

1 Beers 264 mU 2

MR. GLASSMAN:

As long as we are looking 3

at theoretical understanding.

I'm trying to 4

differentiate

(

5 MR. FISKE:

I'm not talking about 6

theoretical understanding. I am talking about 7

Mr. Beers' understanding of the way the system 8

worked based on actual transients that occurred 9

right there at Met Ed.

10 MR. GLASSMAN: I am trying'to 11 MR. FISKE:

Why don't we shut the plant 12 down for six months?

13 MR. GLASSMAN:

I 'm trying to differentiate

~

.14 the difference between understanding which 15 seems to be a favored word of yours as compared 1

16 to application of procedures which is the kind 17 of a document you have got in front of the 18 witness and particularly training on how to 19 deal with a transient.

There may or may not 20 he differences, but I am entitled to keep them l

21 clear.

22 MR. FISKE:

I think my questions are pretty i

23 clear.

I hope so.

("%

q) 24 BY MR.'FISKE:

25 Q

Isn't it a fact, Mr. Beers, that you

1 Beers 265

(~1

~

\\/

2 understood before the Three Mile Island accident, that an overcooling transient involves a significant 3

4 drop in temperature?

5 A

I may have understood that prior to the

(

6 accident, but I don't recall any training on focusing 7

on a reduction in temperature at Three Mile Is1'and 8

or at the simulator where you had overcooling events 9

initiated to us at the simulator as many other 10 transients,and I don't remember the B&w instructors 11-focusing on the decrease in temperature.

12 Q

You had three overcooling transients at r~w k-13 Met Ed right there at Unit 2 between March of 1978 14 and March of 1979, isn't th'a t a fact?

15 A

I don't recall the number.

i 16 Q

Is it your testimony that you didn't 17 train the operators at Met Ed on those specific 18 overcooling transients, bringing to their attention 19 the changes in the system that had occurr'ed during the 20 course of those overcooling transients at Unit 27 21 MR. GLASSMAN:

That is not his testimony.

22 You are trying to recharacterize his testimony.

l 1

23 MR. FISKE:

I am asking him.

fh 24 MR. GLASSMAN:

You are using the words l

s_/

25 "Is it your testimony" and I object to that I

,-,,-,--.--r c,

v-me

1 Beers 266 2

languaga.

3 A

That is not my testimony, Mr. Fiske.

I 4

said that I don't recollect training on focusing on a

(['

5 decrease in temperature.

6 Q

Based on your understanding, Mr. Beers, 7

of the training.that was given to the operators at 8

Met Ed about the way the system worked, would you 9

expect them to have thought they had an overcooling 10 transient in a situation wh'ere there was no change j

11 in temperature more than five or six degrees?

12 MR. GLASSMAN:

Can I have that read back?

13 e

(Record read.)

14 MR. GLASSMAN: I object to the form of 15 the question.

We are talking about a 16 hypothetical situation about what one vould l

j 17 have expected in a certain situation.

Now we 18 are talking about training to operators at 19 Met Ed and it is unclear to me whe[her you are 20 talking about training given just at Met Ed or 21 training to Met Ed operators including that to C

22 which the witness testified which took place 23 ct the simulator.

)

24 We have got multiple grounds of possible l

25 confusion.

I

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'~w--e w-*-ww-

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~-r-r-'--v-* = ' ' ^ ' * ' ' ' ~ " - ' " '

' ' * ^ '

1 Beers 267 m

\\

2 Q

Based on your understanding of all the 3

training the operators received before the accident, 4

Mr. Beers, did you think they had enough

([

5 understanding of this system to know that they would 6

not have an overcooling transien,t when there was no 7

drop in temperature more than five degrees?

~

g MR. GLASSMAN:

Are you asking this 9

witness to evaluate what he thinks was the 10 mental state of an operator?

11 MR. FISKE:

His knowledge of the training 12 that was given.

13 MR. GLASSMAN:

I object as to form.

I'm 14 not sure where we are going.

15 Q

You can answer, Mr. Beers.

16 A

well, Mr. Fiske, I don't understand the 17 significance of the five degree number, but 18 Q

Make it ten.

19 A

Let me try and describe what happens to 20 T ave after the instant you would have a reactor-21 trip and clear on down.

22 Q

In an overcooling? Is that what you are 23 talking about?

(

24 A

Yes.

25 Q

This is as you understood it before the

1 Beers 268 3,

d 2

accident, right?

A Yes.

Normally T ave would be at 579 3

4 degrees 582 degrees, excuse me, at Unit 2 at 100

(

5 percent power if you had been there prior.

6 Q

This is prior to the trip?

7 A

Prior to the trip.

Immediately following 8

the trip, the T ave would be sloping down toward 9

approximately 545 degrees.

10 From there on, depending on whethar the 11 integrated control system was tuned exactly correctly, i

12 it should have -- assuming there was no overcooling,

(

13 nothing was wrong, everything was a normal reactor 14 trip, the temperature should.have stayed right around 15 545 degrees.

l 16 If the feedwater system was not properly 17 tuned via the integrated control system,,it's l

l 18 conceivable to me that you could have gone below 19 the 545 degree number without having an overcooling 20 event.

21 It's really -- I lost my train of thought.

22 Q

Do you want to hear the answer?

23 A

Yes.

[/

)

24 MR. FISKE:

Read the answer back.

U 25 THE WITNESS:

No, this is all right.

l

. - =

1 Beers 269 2

A It is just really a function of the larger 3

integrated system being tuned correctly to get 4

everything to come out as it is supposed to, and

([

5 during these early days in TMI-2, I seem to recall 6

some malfunctions of the feed system which could have 7

produced the same results as an overcooli'ng event.

3 Q

Would you have expected the operators to

'9 know, from the training they had received before the 10 accident, that if following a reactorttrip, T ave 11 dropped from 582 to a point no lower than 577. that 12 that would not be an overcooling transient?

O%/

13 MR. GLASSMAN:

Are you asking him to 14 reconstruct a hypothetical situation and see 15 whether he would have expected an operator to 16 considor that?

If he ever thought about this, 17 he can answer, but just talking a' bout what he 18 might have expected if something was put in

~

19 his mind, you are putting it in his mind today.

20 Q

Based on your understanding of the.

21 training that had been given the operators before the l

22 accident, would you have expected them to know that I

4 23 in a transient where HPI came on automatically and

()

24 the T ave dropped only from 582 to 577, that that 25 transient was not an evercooling event?

1 Deers 270 2

MR. GLASSMAN:

Can I have that read back.

3 4

LRecord read.)

5 MR. GLASSMAN:

Again, my same objection.

((

6 If you are asking what he would have expected 7

them to know in some particular situation, if g

this thing was something that actually was g

considered during the course of the training 10 program, they were trained on, taught, 11 certainly he can answer.

12 If you are asking him now to speculate 13 on what somebody would have expected in a 14 situation that wasn't dealt with as such in the 15 training progran, it is out of order.

16 MR. FISKE:

This is a basic question going 17 to the fundamentals of the system, what his 18 understanding was as to how the operators had 19 been trained on that.

~

20 A

I'm sorry, Mr. Fiske, I don't think this l

is a basic question. If we are talking about this 21 22 parameter and this parameter alone, the operators l

23 would not have been able to diagnose, based on their

{~))

24 training, what type of casualty this was.

w Q

Let me ask you the question, let me 25 i

l I

1 Beers 271

(~

k")/

2 ask your understanding of the system as it existed 3

before the accident.

4 Would you have expected that a pressure

((

5 drop from 2255, the setpoint for the opening of the 6

pilot operated relief valve, down to 1640, which is 7

the automatic actuation point for the high-pressure 8

' injection, that is a pressure drop of approximately 9

600 pounds per square inch, would have been caused 10 by a drop in temperature of only-5 degrees.

11 MR. GLASSMAN:

Once again, I:~am going to 12 make the same objection, Mr. Fiske.

You are p) 13 talking would he have expected this.

14 If he considered this kind of 15 interrelationship, fine, he can answer it, but 16 I don't want him to sit here now and try to 17 think of what he would have expected in some 18 hypothetical situation given a certain 19 combination of paramaters you are n'o w talking 20 about today unless he actually considered that' 21 before the accident.

(~

22 MR. FISKE: If he wants to sit here in his 23 position as supervisor of training for licensed

[~h 24 i personnel and tell us that he never thought about U

l 25 that kind of a relationship between pressure

1 Beers 272

(~)

\\~l 2

and temperature before the accident, he is free to do so.

3 4

MR. GLASSMAN:

If you want to ask

({

5 questions as to whether he actually considered 6

this, go, ahead and do so.

You seem to be 7

implying if there is something he didn't think g

about, that he should be concerned "Oh, my God, g

what did I not think about."

10 We all know very well there are things 11 which you now characterize as basic which were 12 not at all basic before the accident.

s

's 13 I don't know whether this is one of them 14 or not, but I don't want to have a question 15 phrased in such a way that the record is 16 hopelessly mixed up.

~

17 MR. FISKE: It's very clear,,i t is very 18 simple and I believe it is very basic.

19 Q

Do you want to hear the quest' ion again, 20 Mr. Beers?

I think it probably has been lost in the 21 colloquy.

22 A

Okay.

j 23 (Record read.)

24 MR. GLASSMAN:

Objection to the form of 25 the question.

..o

1 Beers 273 2

A I can only answer, Mr. Fiske, as I 3

answered before, that it depends on a number of other 4

4 things.

One, it's the power history of the plant and 5

the steam generator level conditions.

Those enter

({ _

6 into how rapidly the primary system temperature is 7

going to fall based on an overcooling event.

8 Q

I know, but that is not my question, 9

Mr. Beers.

10 I am talking about a drop n temperature, 11 for whatever the causes are, which is 5 degrees.

i 12 A

I'm with you there.

13 Q

I'm talking about a drop in pressure which 14 is 600 psig.

Okay?

15 A

Yes.

16 Q

Was it your understanding that a drop in 17 600 psig would result in a drop in temperature of 5 18 degrees?

19 A

And the drop of 600 pounds wa~s caused by 20 an overcooling?

l l

21 Q

No.

That is precisely my question.

i 22 MR. GLASSMAN:

I'm completely confused.

23 I think the source of c'onfusion is that l

(

24 obviously there are numerous different 25 parameters that come into play in every f

l.

~.

1 Bears 274 2

transient, and if you ask him what he saw in a parti ular transient, that will further the game.

3 4

If you talk about some hypothetical confluence

(

f tw transients without regard to others or 5

6 two parameters --

7 MR. FISKE:

We are talking about a very g

basic phenomenon understood throughout the g

nuclear industry before the Three Mile Island 10 accident known as an overcooling transient.

11' BY MR. FISKE:

12 Q

It's correct, isn't it, that your 13 understanding of an overcooling transient is that y

there is a drop in tenporature which causes the 15 volume of water in the primary system to shrink and 16 as a result of the water shrinking, the pressure in 17 the system drops and the pressurizer level comes down, 18 correct?

19 A

Yes, that is what the reactor ~ trip 20 Procedure is all about whereby you start the second 21 make-up pump and close the let-down and all that stuff 22 to limit the amou re of shrinkage as a result of the 23 temperature decreasing.

(~h 24 Q

Was it your understanding, Mr. Beers, V

25 before the accident, that a 5 degree drop in

,.-,e

t 1

Beers' 275 I

v 2

temperature would produce a 600 psig drop in pressure.

4 3

A I d'on't recall thinking about a specific 4

relationship, if you had so many degrees drop in

(

5 temperature, you are going to have a corresponding 6

so many pounds drop in pressure.

The only thing I 7

can relate to in that order is what I said yesterday 8

or whenever, that in a solid system, the Navy had a 4

9 rule of thumb of what you could expect.

10 Q

Are you saying to.me, Mr. ' Beers, prior to 11 the Thee Mile Island accident, if an operator in one 12 of your training classes had asked you as his 13 instructor, "Mr.

Beers, as you underst.and this system, 14 if there is a 5 degree drop in temperature, will 15 that produce a 600 psig drop in pressure?

16 You wouldn't have been able to answer 17 that question?

18 MR. GLASSMAN:

Now, we are getting into a 19 hypothetical situation.

If he was ever asked 20 that, fine.

To start talking about some I

21 hypothetical situation asking what he thinks now 22 he might have responded to something that you i

t 23 are posing today for the first time, this is 24 inappropriate.

25 A

I can just reiterate, Mr. Fiske, I never

.n.--,,.

,,----.,----u,

,,-,,,--,,,,+,,,-,g.-,---g y---------y m

l 1

Beers 276 2

thought o f it and I don't recollect ever thinking of it in those terms.

3 4

Q Now, Mr. Beers, you mentioned earlier and I didn't want to come back to it -- that the

((

5 6

LOCA procedure in Section B has some case indicatio,ns at the bottom as to' how the operator can distinguish 7

s 8

between a LOCA and a steam line break, correct?

g A

Yes.

10 Q

And a steam line break would produce an 11 overcooling transient, would it not?

12 A

Yes.

That is one form of an overcooling 7"s

(-)

transient.

13.

14 Q

Item 1 says, " Loss of coolant inside RX I

15 building."

16 A

Yes.

17 Q

" Particulate iodine gas monitor alarm on 18 HP-R-227 reactor building air sample."

19 Do you see that?

20 A

Yes.

21 Q

Did you understand before the accident 22 that that alarm was a symptom by which the operator I

i.

I 23 was supposed to be able to tell the difference i

24 between a LOCA and an overoolant transient?

25 A

That is one of the parameters he would e.

i i

1 Beers 277 O

2 look at to make his evaluation.

3 Q

Did y u have an understanding, Mr. Beers, 4

that in the case of a loss of coolant accident of the l

(

5 size covered by part B of'this procedure, that is 6

loss of coolant accident of significant size that the 7

HPI came on automatically, that that alarm should go 8

off sooner than 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> and 20 minutes into the 4

9 transient?

10 MR. GLASSMAN:

Wait a second, are you 11 talking about in a hypothetical situation if 12 you were -- if you happened to be 'in a situation 13 that you understood was covered by part B of 14 this procedure?

15 MR. FISKE:

Yes.

16 Q

Did you understand, Mr. Beers, in the 17 event you did, in fact, have a loss of coolant 18 accident 19 MR. GLASSMAN:

That he knew a'out it?

b 4

20 MR. FISKE:

Yes.

21 Q

In the event you did, in fact, have a loss 22 of coolant accident of the size covered by part B of i

23 this procedure, did you have an understanding of how

(

24 soon after that loss of coolant accident started, 25 this radiation monitor alarm was supposed to go off?

7 y

,___.,w

f 1

Beers 278 fy k!

2 A

I don't believe, Mr. Fiske, that the 3

response characteristics of that monitor were ever 4

addressed in a particular situation you are

{~

5 describing.

6 Q

You understood,.did you not, that for the 7

Purpose of this particular procedure, this monitor 8

was being used as a diagnostic tool for the operator, 9

correct?

10 A

That's true.

That is notithe only 11 Purpose of that monitor.

12 Q

I understand.

But for the purpose of this 13 P ro ce du re, it was being setup as a diagnostic tool?

14 A

Along with some other parameters.

(

15 Q

Right.

And did you understand that if l

16 there, in fact, was a loss of coolant accident of 17 such a size that HPI had come on automatically, that 18 it was important that the operators be able to 19 disgnose that quickly?

~

l I

20 A

Well, Mr. Fiske, if you look back at 21 Section A of the procedure which is leak or rupture 22 within the capability of the system, the same l

23 diagnostic alarm is listed.

So you use that 24 instrument as a diagnostic tool to make a 25 determination whether it was an overcooling accident

1 Beers 279

~

2 or a loss of coolant accident, no matter what the 3

size of the break was.

1 4

Q Isn't it correct that you understood

(

5 before the event that the plant was experiencing a

6 loss of coolant accident, particularly one of the size 7

covered in part B, that it was important that the O

operators be able to diagnose that quickly?

9 MR. GLASSMAN:

May I h' ave that read back?

10 (Record read.)

11 MR. GLASSMAN:

Are you now talking about diagnosing the LOCA quickly or diagnosing the 13 particular radiation monitor,quickly?

14 MR. FISKE:

Diagnosing that they had a 15 loss of coolant accident in progress quickly.

16 A

It's my understanding that it's important 17 to diagnose any alarm condition that you 'have so that 10 you can take remedial action much quicker.

19 g

Did you take any steps before the 20 j

accident, Mr. Beers, in your capacity as supervisor 21 of licensed training, to satisfy yourself that the 22 setpoints for the radiation monitor were set 03

~

at a level such that they would go off quickly in the, 24 event of a leak or rupture of such a size that HPI i

25 had been automatically initiated?

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

-, _ - -.. _ - - - ~. -. _ _..___ _ _

1 Beers 280 0

2 A

I recall a class being t, aught sometime.

I d n't recall specifically whether it was while I was 3

4 supervisor of training or when it was, but the basis 5

for the alarm setpoints for significant radiation

(

6 monitor alarms at Unit 2, were taught.

7 What the basis of this particular alarm 8

setpoint is, I don't recall.

9 Q

But as supervisor of training, teaching 10 the operators how to diagnose a LOCA as opposed to 11 an overcooling, did you fee'. that it was important 12 that the setpoints be set at a level such that this 13 monitor would go off quickly once there was a LOCA of 14 this size?

15 MR. GLASSMAN: I object.

I don't think 16.

there has been any testimony that Mr. Beers, 17 while he held the position'as supervisor of 18 licensed training, taught this parf.icular 19 Procedure.

~

20 Your question asked about what he thought 21 was important when he taught this procedure 22 and it has an assumption that is just unfounded.

23 MR. FISKE:

If that is the hang-up on the 24 question, I will rephrase it.

25 Q

At the time you were supervisor in charge

1 Beers 281

("

\\-

2 of training licensed personnel, you knew that the 3

training department was training operators on this 4

procedure.

Did you feel it was important that the

({

5 setpoints for this monitor be set low enough so that 6

this monitor would go off quickly in the event that 7

there was, in fact, a LOCA of such a size that HPI 8

had come on automatically?

9 A

Mr. Fiske, I,

as supervisor of licensed 10 operator training, had no input into what this alarm 11 point was set at.

That was the responsibility of 12 the engineering department and the radiation b)

(_

13 protection department in combination.

14 Q

Are you saying, Mr. Beers, that if you 15 had gone to them and said, "I would like to find out 16 what that setpoint is because we are using this as a 17 key diagnostic tool to a loss of coolant, accident, 18 and I want to make sure that it is low enough to l

19 serve that purpose," they would have said "Get lost, 20 Mr. Beers, it's none of your business"?

l 21 MR. GLASSMAN:

Come on.

Now you are I

('

l 22 talking about a complete hypothetical, j

l 23 and asking if he had gone somewhere, does he i

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24

'think they would have' said "Get lost."

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25 g

Was it your understanding that you had no p--

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2 ability to play any role in~the determination of the 3

setpoint for that monitor?

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4 A

I didn't play any role in it.

(

5 Q

Did you understand that you could not have P ayed a role if you had wanted to?

l 6

7 MR. GLASSMAN:

Now you are asking again a 8

hypothetical situation, if he had wanted to play 9

a role in something, could he have played a 10 role.

I think he told you what.his role was.

11 To ask him if he had tried to do something 12 back then, would they have thrown him out of O)

(

sl3 ~

his office or something, we are getting into a 14 n eve r-n eve'rland that is not probative of anything, 15 Mr. Fiske.

16 Mr. Fiske, _if B&W had come to GPU and Met

['17 Ed and told.them crucial things before the 18 accident, nobody would have thrown'them out of 19-their 'of fices either.

I can't allow him to answer.

i 20 '

21 Ql Lei's leave this, Mr. Beers, with this s

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qis u's ti o n :

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' 23 Is it correct that before the accident,

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24 ' \\ you did not 'take any action to determine the setpoint s

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i Beers 283

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2 A

No, that is not correct, Mr. Fiske.

I said that there was training on the setpoints of these 3

radiation monitors and the basis for those setpoints.

4 5-g Based on what you had learned in that 6

training, was it your understanding that those monitors were set at a level where they would go off 7

g quickly in the event of a loss of coolant accident 9

of a size such that HPI was automatically initiated?

10 MR. GLASSMAN:

I think the. witness 11 already testified as to what his understanding 12 was.

Whether you characterize them as quickly

[A/

13 or not, I don't know.

14 MR. FISKE: I don't think he answered this 15 question.

16 A

Yes, Mr. Fiske, I believe I did answer 17 the question.

18 I believe I testified earlier that I don't 19 recall the basis for the setpoints for this 20 Particular monitor.

21 Q

Are you telling us that you didn't know 22 one way or the other before the accident whether that 23 monitor would go off quickly in the event of a LOCA

[')

24 of this size?

v 25 MR. GLASSMAN:

Mr. Fiske, he just told

1.

Beers 284

{~.

4 2

you what his testimony -is.

MR. FISKE:

I don't understand it.

3 4

MR., GLASSMAN:

He told you he doesn't 5

recall.

({

6 MR. FISKE:

He said he didn't recall 7

whether he knew what the basis for the setpoints 8

was. I am not asking him that question. I am 9

asking him simply whether he had an 10 understanding before the Three Mile Island 11 accident one way or the other as to whether this 12 monitor would go off quickly in the event of a b~

\\_/

13 loss of coolant accident of a size such that 14 HPI was automatically initiated.

15 MR. GLASSMAN:

I think he has given you 16 the best answer he can. I will let him try once i

17 more, but I think we should get on with it.

18 MR. FISKE:

I would be happy'to, once I 19 get an answer to this.

~

20 A'

I can only say, Mr. Fiske, that it has 21 been my experience with all the radiation monitors 22 at Three Mile Island, both Unit 1 and Unit 2,

that 23 they were~very rapid response instruments.

24

-Q You learned after the Three Mile Island 25 accident, did you not, that that transient had been

Beers 285 A

~'

2 a loss of coolant accident?

3 A

You mean in reading the reports?

4 Q

Yes, you learned after the accident that

[

5 it was a loss of coolant accident, right?

6 A

yes, 7

Q Did you learn after the accident that 8

thousands of gallons of water had spilled out on the 9

floor in the first hour and fifteen minutes of this 10 accident?

9 11 A

I don't recall the absolute numbers, I 12 know water was on the floor.

13 Q

A lot of water, right?

4 14 A

More than a couple of bucketfuls.

15 Q

Did you learn this particular monitor had 16 not reached its setpoint antil one hour and twenty-17 seven minutes after this loss of coolant. accident 18 started?

19 A

I don't recollect that specifically.

20 Q

Do you know whether the training 21 department at any time after the Three Mile Island 22 accident suggested that there be any change in the i

23 setpoint of that monitor as a result of the l

24 experiences in the Three Mile Island accident?

4 J

l 25 A

You mean if the plant was ever to be

1 Beers 286 A

2 operated again, that a suggestion should be made that

~

that setpoint be lowered?

3 4

Q Yes.

5 A

I don't recall any such suggestion.

[-

6 Q

Do you know whether any suggestion was 7

made that someone should determine what the setpoint 8

w as for the radiation monitor at Unit 3 to determine 9

whether that setpoint should be lowered as a result 10 of what had happened in the Unit 2 accident?

11 A

Well, I don't recall any such suggestion, 12 but I am not positive that the sensitivities of the a

13 two monitors are exactly the same. I d'on't know.

14 Q

Going back to this loss of coolant

~

15 accident procedure, Mr. Beers, it is correct, is it

~

16 not -- I am talking now again about your l

l 17 understanding before the Three Mile Island l

18 accident -- that Section B of this procedure, that is l

19 for leak or rupture of significant size such that 20 HPI is automatically initiated, didn't provide for l

21 any throttling back or te rmination of the high 22 pressure injection that had come on automatically 23 other than what was necessary to prevent pump 24 run-out prior to the timo that the low pressure 25 injection or the core flood tanks started putting l

I

4 1

seers 287 f')

-/

water into t'h e system?

2 A

I d n't recall any throttling in this 3

4 specific procedure, but there were limits and

(

5 precautions and tech specs that the operators were 6

trained on to limit the amount of level in the 7

pressurizer.

g Q

Was there any tech spec that governed the limit of the level in the pressurizer after a g

10 reactor trip?

11 A

Yes, I think that that to my 12 recollection, I believe that th at level still n

s_,)

13 applied, the level te,ch spec limit still applied.

14 Q

Which tech spec limit is that?

15 A

I don't recall.

Are you asking me for 16 the specific step in the tech spec?

17 Q

Yes.

18-A I don't recall the number.

,1 19 Q

Are you suggesting, Mr. B e e r s',

that it 20

' w as your understanding before the accident that if 21 the operators knew they had a LOCA of the sice l

k 22 covered by part B of this procedure, that they could 23 terminate HPI before low-pressure injection or core I

24 flood. tanks were putting water into the system?

25 MR. GLASSMAN:

Mr. Fiske, that is not

_ _ __. _,.._ _._~__....... _._ ____-.._._,___.._...._.. __..

g Beers 288 what he said.

He just didn't say that at all.

2 MR. FISKE:

That is what I am trying to find out.

He made some reference to limits and 4

• F*

5

{

talking about this procedure.

6 MR. GLASSMAN: You were talking in your 7

last question about whether he was saying that g

you shouldn't throttle HPI if you knew there g

was a LOCA in part 3 here.

10 4

MR. FISKE:

That's cor. rect. I am asking 77 12 him about this procedure, Mr. Glassman, which is a procedure for a LOCA of such a si=e that 13 HPI has come on automatically and I am asking 34 him of his understanding of what that 15 16 pr cedure required for that particular accident.

17 i

l 18 I am saying isn't it a fact that under l

that procedure for that accident, an accident 19 inv lying a LOCA of that size, the procedure 20 said that the operator should leave the high 21 k-22 pressure injection on until pressure had gone i

d wn to the point where either the core flood 23 tanks or the low-pressure injection started 34 V

l 25 putting water into the system.

I 1

Bears 289 p

2 MR. GLASSMAN:

He just answered you by 3

saying that he understood the tech specs limits 4

would apply.

5 MR. FISKE:

That is precisely what led to

(

6 my next question which is whether it was his 7

understanding before the accident that in the g

case of a loss of coolant accident of such a size that pressure had dropped to the point 9

10 where HP1 had come on automatically, that the 11 operators were allowed to terminate that HPI 12 during that type of a loss of coolant accident 13 before pressure had dropped to the point where 14 the core flood tanks or low-pressure injection 15 started putting water.

16 MR. GLASSMAN:

Your question' assumes the 17 operator knows there was a loss of coolant 18 accident of the type you are speaking about.

19 MR. FISKE:

Exactly.

20 A

Mr. Fiske, you must understand the 21 importance of the tech specs that was drilled into the 22 licensed operators and the trainees, that the 23 technical specifications were the bible, "Thou shalt

(~)

24 not violate the tech specs."

If they were ina v

25 situation where they saw an imminent condition, that g -

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1 Beers 290 O

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3 they would violate the tech specs, they would 3

probably take action to preclude that violation.

4 Q

Would going on the wrong side of the --

([

5 what we referred to as the departure from nucleate 6

boiling line in the tech specs -- be a violation of 7

the tech specs?

g A

Yes.

You mean to the right-hand side?

9 Q

Yes.

10 A

Yes.

t 11 Q

Was it your understanding, Mr. Beers, 12 that the operators were trained that under no k'

13 possible circumstances, so matter what the emergency 14 was, could they ever violate any provision of the 1

15 tech specs?

If they thought they had to take certain 16 action which was necessary to prevent a major 17 catastrophe at the plant, taking that action might 18 violata a provision in the tech specs, th'at they had 19 to sit there and watch the catastrophe occur rather 20 than violate the tech specs?

21 Is that the training they received?

22 a

A No, Mr. Fiske. I'm sorry if I gave you 23 that impression.

All I was saying was that the tech

[~))

24 Specs were considerd to be a higher-tiered document 25 than the procedure.

1 Beers 291 O) t\\'

2 Q

But if the operators felt that following 3

the procedure was more important than following the 4

tech specs in order to prevent an accident, their 5

training told them they could do that, correct?

{

6 MR. GLASSMAN:

Now, you are talking about 7

a hypothetical situation.

8 MR. FISKE:

IIct at all, Mr. Glassman.

9 Mr. Beers has been telling us now about the 10 emphasis that he said was placed on the tech t

11 specs and I am simply trying to find out 12 whether, in the course of training, the s_/

13 Operators were told that in the event they 4

14 felt that following a procedure was necessary 15 in order to prevent a major accident, that they 16 were allowed to do that even if, in their 17 judgment, following the procedure might 18 violate a provision in the tech spec.

19 MR. GLASSMAN:

There has been~ absolutely 20 no testimony that anyone ever' felt or understood 21 that by violating a tech spec and following the 22 procedure, you would have some situation where 23 you could avoid some accident of the kind you

{'/}

24

.are talking about.

s_

25 The whole scenario you have painted seems l

-.-..,....~ --..

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

1 Beers 292 O

(-

to ba one that is utterly hypothetical.

We 2

9 3

seem to be getting into a lot of these kinds of 4

qsestions, Mr. Fiske.

BY MR. FISKE:

5 6

Q Isn't it correct, Mr. Beers, that the 7

operators understood, as a result of their training, 8

that they could take action which would violate a f -

g tech spec if that action in their judgment was 10 necessary to prevent a serious emergency from i

11 occurring?

. 12 MR. GLASSMAN:

Are you asking whether 13 this man can read an operator's mind as to what 14 he understood in some hypothetical situation?

4 15 MR. FISKE:

No, I am not. I think 16 Mr. Beers can answer that question.

17 MR. GLASSMAN:

Not certainly,the way the

~

18 question is worded, whether the operators 19 understood if this hypothetical situation came 20 up, that they could take the action you described.

oi

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22 MR. FISKE:

Read the question back, l

~

i 23 please.

i 24 MR. GLASSMAN: It doesn't talk about what l

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t 25 the training is.

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1 Beers 293 2

(Record read.)

MR. FISKE:

I will rephrase the 3

4 question to avoid Mr. Glassman's concern.

(

5 Q

Isn't it a fact that the training that 6

was given to the operators told them that they were 7

allowed to take action which was necessary to 8

prevent a serious emergency from occurring if that 9

action might violate a provision of the tech specs?

10 A

I seem to recall somewhere that it said 11 in a document that it was the duty and responsibility 12 of the operator to try and maintain'the plant ina 13 safe condition.

14 Does that answer your question, 15 Mr. Fiske?

16 Q

If that means the answer to my question l

i 17 is "Yes,"

it answers it.

l 18 MR. GLASSMAN:

You asked whether there was i

l 19 a particular training and Mr. Beers-just told l

20 you what he recollected.

That is not the same 21 as a yes or no.

I think he seems to have

(-

i l

22 answered what he recollected.

I don't know I

23 that you are entitled to any more than his

[^))

24 recollection.

25 Q

Does the answer mean that the operators e

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1 Beers 294 2

were trained that they should take action to 3

maintain the plant in a safe condition even if that 4

' action might violate a provision of the tech specs?

({

5 A

I have told you to the best of my 6

recollection, Mr. Fiske, and I don't recall specific 7

training.

8 Q

How about your own understanding before 9

the accident as a shift supervisor as to whether or 10 not you would be allowed to" Lake action which you 11 felt was necessary to maintain a plant in a safe 12 condition even if taking that action may violate a 13 provision in the tech spec?

14 MR. GLASSMAN:

You are asking him to 15 speculate or whether it ever came to his mind?

16 MR. FISKE:

Whether it ever came to l

17 his mind, exactly.

18 A

I don't recall thinking about that type 19 of situation.

The tech specs especially'in Unit 2 20 were pretty well written.

Under normal operating 21 conditions and the casualties that were analyzed as l

22 part of the FSAR, you shouldn't have gotten into a 23 situation whereby you had to make that decision.

()

24 Q

Let me go back, Mr. Beers, to this LOCA 25 procedure, part A.

It says, " Leak or rupture within

{

i Bears 295

\\l 2

capability of the system operation."

3 Did y u understand by system operation,"

that meant a make-up pump?

4

,5 A

One make-up pump?

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f 6

Q What did you understand " system operation" 7

meant?

4 8

A Within' the capability of the HPI system.

4 9

Q operating in the high-pressure injection 10 mode.

(

11 A

Let me review the. procedure here a 12 moment.

Section A of the procedure gives you the 13 flexibility to start the second make-up pump which l

14 when you would be in that condition as far as the HPI 15 systm is concerned, you are in the same condition 16 then as you are in the full HPI mode just for the 1

17 make-up pumps themselves.

18 Q

You would have the same flow as if you 19 had been in the HPI mode, is that your point?

20 A

It should be very close to the same flow.

21 Q

And isn't it a fact, Mr. Beers, that the L

22 designation " Leak or rupture within capability of 1

i 23 system operation" meant the capability of the high

()

24 pressure injection system, if it was operating, to 25 maintain pressurizer level and pressure above the

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1 Beers 296

(

2 1640 psig safety injection actuation setpoint?

3 And I am referring to page 3 if that is 4

helpful.

5 A

No, Mr. Fiske, that is not my understanding 6

of Section A of the procedure.

7 Q

Let's look at page 3.0, paragraph 3.2.5 8

whi'h says, " Caution."

9 Do you see that?

10 A

Look at 2.2.5 first.

11 Q

Let me direct your attention to this, 12 Mr. Beers.

If you want to add anything else, you can.

s) 13 3.2.5 Caution says, " Continued operation 11 depends upon she capability to maintain pressurizer 15 level and RCS pressure above the 1640 psig actuation 16 setpoint."

17 1 says, "If pressurizer level can be 18 maintained above the low level alarm poin't and the 19 ncs proccure above the safety injection astuation 20 point, then proceed to 3.2.6;and 3.2.6 is initiation 21 of plant shutdown and cool-down, is that correct?

22 A

Are you asking me is thac che cool-down 23 procedure?

(~T 24 Q

Yes.

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=

25 A

Yes.

4-

1 Beers 297

('

2 Q

Then the second alternative is "If 3

Pressurizer level cannot be maintained above the low 4

level alarm point and the RCS pressure above the 5

safety injection actuation point, then the plant has

(

6 suffered a major rupture and operation should continue 7

according to part B."

8 Isn't it correct, Mr. Beers, that the 9

s ubs tanc e of that particular section of this procedure 10 tells you that if pressurizer level and pressure can 11 be maintained above the safety injection actuation 12 point, then you, in fact, have a leak or rupture O)

(_

13 within the capability of system operation and you can 14 proceed to plant shutdown and cool-down?

15 But if you cannot do those two things, 16 that'is, maintain pressurizer level above the low 17 level alarm point and maintain pressure above the 18 safety injection actuation point, then yo~u have a 19 leak that is not within the capability of~9ystem 20 operation and you are supposed to go t'o part B of 21 this: procedure?

22 Isn't that in substance what that tells i

23 you?

[~

24 MR. GLASSMAN: I would like to have that V) 4 25 read back.

We can all read the procedure,

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1 Beers 298 fl

\\

2 Mr. Fiske, but your attempt to reword it instead 3

of what it says, may be misleading.

4 MR. FISKE:

I hardly -- I am simply 5

asking Mr. Beers if that is his understanding

({

6 of the relationship between part A and part B 7

of this LOCA procedure.

Putting it precisely, 8

wasn't that his understanding before the Three 9

Mile Island accident?

10 A

Mr. Fiske, are you asking me what is the 11 Purpose of that Caution note?

12 Q

Well, I don't know whether I have 13 necessarily put it in terms of the purpose.

I was 14 asking you as to what your understanding was as to 15 what that meant.

I 16 My question simply was, didn't you 17 understand it to mean that under paragraph 1,

if you 18 could maintain level and pressure above their 19 respective points, then you could s tay within part A i

l 20 and go on to the plant shutdown and cool-down.

If 21 you couldn't maintain pressurizer level at its point 22 and pressure at its point, then you had to go to l

\\

23 Part B.

l

(~)

24 Isn't that the way you understood it?

C#

25 MR. GLASSMAN:

Are you talking about its l

l

1 Beers 299

\\/

2 point, are you talking about pressurizer level 3

ab ve the low level alarm?

4 MR. FISKE:

Right, and the RCS pressure,

(

5 the safety injection a,ctuation point.

6 MR. GLASSMAN: I am slightly confused with 7

the slight rewording, but I think the witness 8

can answer as to his understanding about the 9

particular " Caution," and what it applied to 10 and what his understanding of that Caution was.

11 A

Mr. Fiske, let's go back to 3.2.2.

12 I'm going to answer your question, but I es

(

I x/

13 want you to go back and look at 3.2.2.

We have 14 bypassed the safety injection now per that step, 15 right?

16 Q

Yes.

Which means nothing other than you 17 have assumed manual control.

18 A

That's correct.

That's exactly the point 19 that I wanted to make.

Now you have manuhl control of 20 all the ESAS equipment.

The operator has manual 21 control of all the ESAS equipment.

~

22 It was my understanding that the importance t

23 of that Caution note was that should your pressure l

~

[~)

24 decrease below the 1640 setpoint, now you would have V

25 a reinitiation of the whole HPI system again.

So it

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is important for you to maintain the pressure above 2

that 1640 setpoint.

3 4

Q Did you understand that if you couldn't 5

do that, then you had to.go to part B?

(

6 MR. GLASSMAN:

Are you now talking about 7,

the pressure alone or the pressure and level g

together?

9 MR. FISKE:

I am responding to Mr. Beers' 10 last answer, Mr. Glassman, which,you and I both 11 heard it, was talking about pressure and said 12 nothing about pressurizer level, b

A_)

13 MR. GLASSMAN:

You are rea$ing a portion 14 of a particular paragraph or procedure which you 15 have placed in front of the witness, Mr. Fiske.

16 MR. FISKE:

I am just referring back to 17 Mr. Beersi last answer.

18 A

Well, I believe the two go tosether, 19 pressurizer level and pressure.

~

t 20 MR. FISKE:

Could you read Mr. Beers' 21 last answer back before Mr. Glassman made his 22 interjection.

l 23 (Record read.)

24 Q

Was it your understanding, Mr. Beers, 25 that if pressure dropped below 1640, then you had a i.

1 Beers 301

'N

)

/

2 reinitiation of the hig h-pr.e ss ure injection all over 3

again and at that point you would be in part B, leak 4

or rupture of significant size such that engineered

(

5 safety feature systems are automatically init'iated?

6 MR. GLASSMAN:

The point I was trying to 7

make 8

MR. FISKE:

You don't have to make any more 9

points. Let Mr. Beers answer a few questions 10 without constantly being promp*ed by you.

11 MR. GLASSMAN:

He is not being prompted by 12 me.

I think the problem we have is that you 13 are trying to isolate a particular parameter 14 and the witness testified a few moments ago he 15 considered certain parameters go together.

16 MR. FISKE:

After you told him that is what

~

17 he should say.

18 THE WITNESS:

That is what the procedure 19 says.

20 BY MR. FISKE:

21 Q

That is precisely the point I am trying to 22 make, Mr. Beers, didn' t you understand that in this 23 Caution section, there were two alternatives.

One was

(

24 if pressurizer level could be maintained above its 25 alarm point and pressure could be maintained above the

1 Beers 302 0

2 safety injection actuation point, then you could stay in Section A, leak within the capability of 3

4 the system operation, and go on to the plant shutdown 5

and cool-down, but that in the other alternative, if

(

6 you couldn't do both those things-if you couldn't 7

maintain pressurizer level above the low level alarm 8

point and maintain RCS pressure above the safety 9

injection actuation point, then ycu couldn't stay in 10 part A, but you had to go to part B which was a leak 11 or rupture of significant size such that engineered 12 safety feature systems are automatically initiated?

O)

(b-13 You could either answer yes, you understood 14 it ~ that way or no, you didn't, but that is my 15 question.

16 MR. GLASSMAN:

Mr. Fiske, I think you are 17 trying to get a simple yes or no' answer to a 18 situation where the witness has tried to testify 19 fully and we all know, we have had a lot of 20 testimony about this procedure.

21 We are trying to focus on what it was that l

22 operators in the training understood were i

23 covered or had to be found to make either of 24 these parts applicable.

U 25 He can give you hit understanding.

L

l 1

Beers 303 O

2 MR. GLASSMAN:

That is all I'm asking for.

A To the best of my recollection, Mr. Fiske, 3

4 it was not my understanding that they had to go 5

together, the pressurizer level and pressure.

(

6 Q

Y u understood before the accident that 7

they could go in different directions?

g A

No, that is not what I said. I was 9

thinking of it as an electronic answer, that you had 10 to have both of them to proceed as the procedure 11 directs.

12 Q

Let's put it this way, Mr. Beers.

13 Did you think before the accident about 14 a situation in which pressure and pressurizer level 15 could go in d'ifferent directions?

16 A

No, I did not think about it.

17 Q

so it was your understanding before the 18 accident, wasn't it, Mr. Beers, that in the event that 19 pressure could not be maintained above the 1640 20 setpoint, you had to go to part B7 21 MR. GLASSMAN:

Are you nod asking him L

22 whether interpreting this document before the 23 accident, that Mr. Beers understood that you 24 focused on pressure and that you would not 25 focus on level?

\\

1 Beers 304 r"N 2

MR. FISKE:

I don't know what I can do 3

ther than to try to put the question one more 4

time.

(,

5 g

Isn't it a fact that you understood before 6

the accident that unless you could maintain both 7

Pressurizer level above its alarm and maintain f

8 pressure above its actuation point, then you had to go g

to part B7 10 A

No, that was not my understanding.

11 Q

Were you consulted, Mr. Beers, before Met 12 Ed paid the fine imposed on it by the NRC f'o r

[)

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13 failing to fq11ow this procedure in the course of the 14 accident?

15 A

No, I was not.

16 Q

Did you testify, Mr. Beers, before i

in the proceeding conducted by the 17 the 18 administrative law judge relating to cheating out at 19 Three Mile Island?

~

20 A

No.

21 Q

Were you aware before the Three Mile L

22 Island accident of any operators that had cheated on 23 any examinations?

O) 24 A

Before the Three Mile Island accident?

(s_/

25 g

Yes.

1 Beers 305

(~]

2 A

No, I was not aware of that.

3 Q

Did you become aware after the Three *.ile 4

Island accident of any operators that had cheated on 5

their examinations?

({

6 MR. GLASSMAN:

When?

7 MR. FISKE:

At any time.

8 A

Well, during the summer of

'79, after the 9

accident, it was brought to my attention by one of my 10 instructors, that he thought that there was some 11 impropriety on a make-up p.ackage that was returned 12 to the training department.

\\

13 Q

Who was the person that ha'd committed this J

14 impropriety?

15 A

Mr. Floyd.

16 Q

other than learning that about Mr. Floyd, 17 up to this day have you learned of any ' cheating by any 18 other operator or management person at Me't Ed?

19 A

Are we speaking now exclusive'of the 20 investigation that was done by the administrative i

21 law judge?

22 Q

Yes.

That is a useful limitation.

I'm 23 not asking you just to tell me what you learned by 24 reading that report.

\\-

25 A

I didn't read that report, but we had

1 Beers 306 (O

_)

2 communications.on-the Island'..that talked about that indiscretion.

3 4

Q Well, other than the conduct of Mr. Floyd

(-

5 that you just leferred to, have you learned of any 6

other impropriety committed by operators or management 7

personnel at Met *Ed?

l 8

A No, I did not.

9 MR. FISKE:

That is all I have.

10 Thank you, Mr. Beers.

• i 11 THE WITNESS:

We are done?

12 MR. FISKE:

As far as I am concerned.

O 13 MR. GLASSMAN:

Let me go over my notes to 14 see if I have any questions.

15 (Recess taken.)

16 MR. GLASSMAN: I have no question.

17 (Time noted:

5:05 p.m.)

18

-ooo-i 19 MARSHALL L.

BEERS 20 subscribed and sworn to 21 before me 22 this day of 1982.

l 23 i

24 25

. Beers 307 CERTIFICATE STATE OF NEW YORK

)

3

33,:

COUNTY OF NEW YORK

)

4 t

I, ROBERT CAPUZELo a Notary C.

5 Public of the State of New York, do hereby certify that the continued deposition of MARSHALL L.

BEERS WaS taken Defore me on Thursday, July 8,

1982 consisting of pages 152 through 306 I further certify that the witness had been previously sworn and that the within transcript is a true record of said testimony; 13 l

That I am not connected by blood or t

14 marriage with any of the said parties nor l

interested directly or indirectly.in the matter in controversy, nor am I in the employ of any of the counsel.

18 IN WITNES WHEREOF, I have, hereunto set my 1g

,/k1 hand.this~

day of y/

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7/8/82 308

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WITNESS:

PAGE MARSHALL L.

BEERS 154 E XH I B I T S B&W FOR IDENTIFICATION 893 Copy of Supplement 3.

9 154 I

894 Copy of an interoffice memo, 163 dated July 3, 1979 on'the letterhead of Metropolitan Edison Company.

'895 Copy of a report entitled

.230 i

"Three Mile Island Nuclear Station, Unit 2 Operating Procedure 2101-1.1, Unit Heat-Up."

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4 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK

['

---

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

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

INC.,

Defendants.

3

---

X STATE OF PENNSYLVANIA )

ss.:

[

COUNTY OF DAUPHIN

)

I have read the transcript of my deposition taken on July 7 and 8, 1982 and together with the attached corrections, it is accurate to the best of my knowledge and belief.

a fis ex -

Marshall L. Beers l

l Signed and sworn to before me this

s. 29th day of October, 1982.

(,,

I TgM.%bu

~ Notary Public '

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I' PATRtCIA L COURY Notery fh;Nic. Lebanon Co., Lebanon. Pts A Co timisse Exovee Feb. 8.19P(

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5 CORRECTIONS TO M.L. BEERS DEPOSITION October, 1982 PAGE N LINE CORRECTIONS 4

20'

" Rad Con /and" should read

" Rad. Chemistry" 4

21

" area radioactive" should read

" area and radioactive" 10 5

" cabinet in my desk" should read

" cabinet plus my desk" 15 20 "Mr. Baldson"'should read "JMr..a Roltz "

1 17 20 "when" should read "said" 27 10 "it's to long" should read "it's too long ago."

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~

" unit specific."

39 18

" units, specifically" should. read 51 25

" develop" should read " dwell" 54 22

" warranted" should read " warned" 71 10 "failing to open" should read "failing open" 76 3

" electrical / electric" should read

" electrical / electronic" 91 7

"penelec" should read " panel",

93 3

" reaction" should read

(

L

" recollection" 99 25

" rupture disk" should read '

" rupture disk operation" 105 15

~" March 7" should read " March

'78."

121 4

" automatically block valves." should read " automatically close block valves"

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PAGE' LINE CORRECTIONS 194 16

'"whether" should read "where" 219 22

" reactive" should read " reactivity" 224 25

. "down." should read "down mode" 253 19

" measure" should read " mesh."

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