ML20072H846
| ML20072H846 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 05/18/1982 |
| From: | Long R GENERAL PUBLIC UTILITIES CORP. |
| To: | |
| References | |
| TASK-*, TASK-04, TASK-07, TASK-10, TASK-4, TASK-7, TASK-GB NUDOCS 8306290773 | |
| Download: ML20072H846 (176) | |
Text
. _ _ - _
pkL UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK
-- - -- - - _ _ - - - - - - - - - - -x GENERAL PUBLIC UTILITIES CORPORATION, :
,O, 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 Deposition of GPU Nuclear Corporation, by ROBERT L. LONG, taken by Defendants, pursuant to notice, at the offices of Davis Polk &
t Wardwell, Esqs.,_One Chase Manhattan Plaza, New York, New York on Tuesday, May 18, 1982 at 9:50 o' clock in the forenoon, before Joseph R. Danyo, a Shorthand Reporter and Notary Public within and for the State of New York.
8306290773 820518 PDRADOCK05000g T.
t O 1
- V DOYLE REPORTING, INC.
CERTIFIED STENOTYPE REPORTERS 369 Lex NGTON AVENUE WALTER SHAPIRO, C.S.R.
NEW YOnx.~ N.Y. foo17
- CHARLES SHAPIRO, C.S.R.
TELEPHONs 212 - 867 822o
1
- '> [
l-l' 2 l
. l.
/
C/ Appe a rance s:
2 ,
3 4 KAYE, SCHOLER, FIERMAN, HAYS & HANDLER, ESQS.
Attorneys for Plaintiffs I
5 425 Park Avenue
BY: STEVEN J. GLASSMAN, ESQ.,
7 of counsel 8
9 DAVIS POLK & WARDWELL, ESQS.
10 Attorneys for Defendants t One Chase Manhattan Plaza 11 New York, New York I
12 BY: RODMAN W. BENEDICT, ESQ.,
j 13 of counsel 14 i
15 Also Present:
.16 DEBORAH JACOBS 17 ,.
18 -ooo_
~
- 19 20 k.
22 23 fx
,\ ) - 24 n.j -
25 'I l
j
I 1 -
3
- im.
. 2 IT IS HEREBY STIPULATED AND AGREED by 3 nd between the attorneys for the respective 4 parties hereto that the sealing, filing and
( 5 certification of the within deposition be, 6 and the same hereby are, waived; that the 7 transcript may be signed before any Notary 8 Public with the same force and effect as if 9 signed before the Court.
10' IT IS FURTHER STIPULATED AN,D AGREED 11 that all objections, except as to the form 12 of the question, are reserved to the time of n
13 trial.
14 15 -ooo-16 .
17 RdB E RT L. L0NG, .having 18 been first duly sworn by the Notary Public 19 (Joseph R. Danyo),'was examined and testif,ied 20 -as follows: -
21 EXAMINATION BY MR.-BENEDICT:
22 Q Would-you state your name for the record?
(' 23 A Robert Long.
l ([*\
~_:
j 24' Q .Could you tell me;your business address?
A 25 GPU_ Nuclear Corporation,: 100 Interspace l
e j
I 1 Long 4 LO 2 Parkway, Parsippany, New Jersey. .
-3 Q And your home address?
4 A 104 Brooklawn Drive, Morris Plains, New 5 Jersey.
~6 MR. BENEDICT: I would like to mark as 7 B&W Exhibit 668 a res'ume provided to me by 8 counsel for Dr. Robert L. Long.
9 (Resume of Robert L. Long marked B&W 10 Exhibit 668 for identification, A,s of this 11 date) 12 Q .Does B&W 668 accurately represent your O 13 education'al and work experience to date?
14 A Yes, it does.
15 Q It indicates that you received a 16 Bachelor of, Science degree in electrical. engineering 17 .- from Bucknell University in 1958. -
18 .Did you at the time you were at Bucknell 19 take any. courses in nuclear engineering.or in 20 Physics?
21 'A 'Yes, IJ.took one' introductory-course in 22 nuclear engineering, and.I took the normal physics 23 .. ' courses. required of~ engineering students..
L24 -Q. For your. Bachelor-of1 Science. degree, l
- -25
- ' did-lyou study fluid flow, heat transfer?
- e
.v l
~
l 1
1 1 -
Long 5
- fw 2 A Only to a very limited extent.
]
l 3 Q Did you have a course of study, among 4 the courses you took for your BS, in thermal
'( 5 dynamics?
6 A No, I did not.
7 Q Up to and including receiving your i
8 Ph.D., did you take any academic courses in thermal 9 dynamics?
10 A No, I did not.
11 Q What was the subject of your Master's 12 dissertation or thesis, if you had one?
13 A I didn't have a thesis for the Master's 14 degree.
15 Q Did you have a Master's project that 16 you did. independent research for?
17 A No, it was all courae work. .
18 Q What was the thesis for your Ph.D.?-
19 A The Ph.D. dissertation, I don't remember 20 the exact topic, but it was on resonance integral 21 cross-section measurements.
22 Q Is that something related to nuclear 23 physics?'
- (mI 24 A More related to reactor physics.
- %J 25 :Q LIn a very-general 25 words or less, if
i 1
1 -
Long 6 0 2 you can, what.does that entail or encompass?
3 A It is naasurements of the neutron 4 reaction rates at energies between thermal energies
( 5 and fast energies.
6 Q You indicated that only to a limited 7' degree'did you ctudy heat transfer and fluid flow 8 for your Bachelor's degree. Did you in the course 9 of any of your postgraduate education study heat 10 transfer and fluid flow? ?
11 A In a limited extent, in varous nuclear 12 engineering courses, yes.
O 13 Q It indicates here that during the time 14 you were getting your Ph.D. at Purdue, you worked 15 as a student research associate at the Argonne 16 National Laboratory. What did you do at Argonne?
17 A That is where I performed my .
18 dissertation. I made the measurements on the 19 Argonne thermal source reactor. It is a small 20 research reactor.
21 Q From .1962 to 1965, you indicated that 22 you were a reactor specialist at the White Sands 23- Missile Range in New Mexico. Were you in the
- 24 military service at the time?
25 A .Two years I was in the military and one
'1-' '- ' . i: _ _ . _ . _ . _ _ _ . ___-_-_____._--___.___.__-__1________m__
1 1 Long 7 O 2 year in the Civil Service.
3 Q What branch of the service were you in?
l 4 A The Army Ordnance Corps.
( 5 Q Whet did you do as a reactor specialist?
! 6 A I was supervisor of the White Sands 7 fast-burst reactor facility.
8 Q Earlier you described the reactor at the 9 Argonne National Laboratory. Did you say it was a 10 thermal reactor? '.
11 A Yes, it was called the thermal source 12 reactor.
O 13 Q Was this a pressurized water reactor?
14 A No.
15 Q Was it a light water reactor?
16 A. Yes.
17 Q Was it a pool reactor? .
18 A Yes.
19 Q Is that the kind of reactor you had at 20 the University of'New Mexico when you were on the 21 faculty there, a pool reactor?
22 A No, the reactor at the University of 23 New Mexico was called the aerojet general nuclear f 24 model 201. It essentially is a solid reactor 25 core made of a polyethylene and uranium
1 .
Long 8
/ \
2 homogeneous mixture operated at a maximum power 3 level of five watts.
.4 Q How is criticality controlled at the
( <5- reactor at the University of New Mexico?
6 A The use of control rods which are made 7 of fuel material, so it is insertion and withdrawal 8 of fuel.
9 Q You said you worked on a fast-burst n 10 reactor at White Sands. What is a fast-burst
.11 reactor?
12 A Fast-burst reactors are a rather unique O)
\~ 13 reactor type that is used to produce very intense 14 short-duration pulses of radiation. It is made of 15 again a homogeneous metal core, approximately eight 16 inches in diameter, eight inches high. The power 17 level goes from zero to 30,000 megawatts and back 18, to zero in a pulse with a width of half maximum 19 pulse of about 45 microseconds.
, 20 -Q What-is - the fast-burst reactor used for?
. 21 A Primarily as a radiation source for 22 weapons effects testing.
1 23' ~Q How is the f ast-pulse reactor
-[ }
\_j '
-'24 . criticality-controlled?
l 25 - JA- Insertion'and withdrawal of fuel.
+
1 Long 9
(~
L )/_
2 Q You next list on your resume a 13-year 3 stint as a faculty member of the nuclear engineering 4 department at the University of New Mexico. What were the various titles, if they changed, that you
( 5 6 held at UNM7 7 A I began as an assistant professor in 8 1965 and was promoted to associate professor in 9 1968. Full professor in 1973. I was assistant 10 dean of the College of Engineering frok '72 to 11 '74. I was acting department chairman of-the 12 chemical & nuclear engineering department in '74-75, A
('# l 13 and chairman from '75 to '78.
14 Q Did you teach courses while you were 15 a faculty member?
16 A. Yes.
17 Q Did you also participate in university-18 sponsored research?
19 A Yes, but more outside-sponsored than 20 uhiversity-sponsored.
21 Q Were you acting as an independent
- 22. consultant working for outside-sponsored.research, 23 orlwere you working as'a member of the faculty at 0)
, 24- the University of New Mexico?
25 A :I did some of both.
.1 Long 10 O-
\_/
4 2 Q Did you teach courses while you were 3 in the University of New Mexico in thermal dynamics?
4 A No.
Did you teach any courses that related
( 5 Q 6 to the dynamics, whether nuclear or hydraulic, of 7 pressurized water reactors?
8 A Yes. I taught courses in nuclear power 9 reactor controls and talked about the dynamics a l 10 great deal, principally the nuclear kid,etics and 11 reactor kinetics.
i 12 Q so these were nuclear physics issues 13 as opposed to mechanical-type issues?
14 A Primarily, yes.
15 Q When you served as the chairman of the
.16 department of chemical and nuclear engineering,
- 17 were.you still acting as a teacher? .
18 A Yes, I was.
19 Q Did you prepare certain written 20 testimony for submission to the Atomic Safety and
~
21' Licensing Board'that is considering.the restart o f' 22 TMI Unit-17 t-23 A 'Yes. I participated- in .the - preparation ,
. ( ); 24 yes. ,
25- Q -Did you include'inJtha't written material-
><re rre +- w sw s- w - n -e s- m, m s- pm -w-
s -
1 Long 11 0 2 a description of your past experience to date?
3 A Yes, I think so.
4 Q In the written testimony that was dated December 22, 1980 and introduced before the Atomic
.( 5 6 Safety and Licensing Board considering the TMI-1
'7 restart on February 11, 1981, at pages 7 through 9, 8 there is a discussion of Dr. Long's past experience.
9 As Mr. Glassman knows, it hasn't been 10 our practice in the past to mark testim,ony which 11 has been sworn in this case as an exhibit. I 12 mention that because this is the source of the
~
13 following questions Icam going to ask you. If you 14 . need to look at it, just ask, and I will be happy 15 to show it to you.
'16 . I would just like to understand some of 17 the outside jobs you did while you were at the 18 University of New Mexico. One of the thi gs that 19 this' testimony indicates is that you served as a e
, 20 project engineer for the design of.the Sandia 21 .-Laboratory SPR-2 fast-burst reactor.
22 Is this fast-burst. reactor similar to J
23 .the one.you told me about at White Sands? - !
.fs 1
) 24 A Yes. l K' .J . !
1 25 .Q 'could'you tell mefwhat your; tasks or.
a L l
A .E_J 4 m- 4 t
1 .
Long 12
. -m 2 your. job responsibilities were as the project 3 engineer on that matter?
4 A Yes, I was on a half-time research
( 5 contract the university had with Sandia, and I was 6 the leader of a team of people designing a new 7 pulse reactor for Sandia Labs.
8 Q Who was on this team of designers? Were 9 these other people from the University of New 10 Mexico? i 11 A No, they were primarily from Sandia 12 Labs.
13 Q It indicates you were " project-14 engineer." Does that mean you were the supervisor 15 of this project?
16- A. In the technical sense, yes, but there 17 was a Sandia supervisor who was the administrative 18 . man and corporate supervisor of,those people.
, 19 Q Was it principally your - experience -at- ,
20 White Sands which.provided you with the necessary
~
.. 21 background to - participate in this project?
22 A Yes.
23 Q When 'in your career ~did this occur 7
[l 24 .A 1965-1966.
.% J
' ~
- 25. Q The next' task or job that you had
,-y
.. . _ _ _ ~
\
.\
N ..
13 Long ,
1 O\ f
_j indicated by this ,
2 during this time, at least as - ut fM 3
resume, is that you are listed as the " principal '
- h. .
l 4
investigator for.a contract with Consolidated ,
h.
5 Edison Company of New York to' analyze axial xenon ,
' is 6
redistribution and power shaping in large ,
7 pressurized water reactors." >\
What was your role as the principal 8 \L .-
9 investigator? s F i
The work ,
10 A I had a' contract with Con Eds. -
g
- N, N
s primarily perfcrmed by one of my doctoral w as ',
11 .
(^}
12 candidates who was located here in New York with Con '
J N
\ ) i 13 Ed to do thati work. .
14 Q Were you principally supervising work 15 being done by this student? 'g *
's t A -
Yes, s 16 1
's Do you know what if~any application Con.
A'
~
17 Q Ed intended to put this work to?
18 .
i 19 A Yes. They were looking for a t'e'c h n i q u e g,
20 of doing rapid calculations on the effect of xenon 21' after reducing pcwer, particularly on weekends.
('
22 Q This was with respect to power reactors?
23 A Yes.
- (~'N - (,
k '-
)
24 Q At.what time were you.doing this job.
.or doing this review work?
I-
.25
, a ,
.3 . , . ,
\
\*
\~ '
. 14
- Long 1
f3
- U n '
A I don't remember the exact-starting b-2 \' t.-
),
time.
It was 1971-1972, and the work was completed ..
3 V.:
I b' in 1974-1975.
4 .-
~
what if any formal training had you had " L C 5 Q
.( initiating this work as principal .
p'.
~
6 prior to -
s a , 4 the design, 7
investigator which related to s '
- 3. . .
a
's , -g '
' 8 construction,'or operation of large pressurized [ .'
'n N .
water power rAactors?
(
9 7 . ,;
10 .A My course work at',rurdue covegd the .
(;.
y , ,-
J' as d'es*st of pressurized water reactors aslwell 7 6 N 11 i f(w g
K s i
ss s I worke'd for. Con' Edison 12 boiling water reactors. ;'
~
D s for'a year in 1970 and 1971 at Indian Po[nt W 3.,,
1.
'hk . ~ ~ 13 -
14 I taug t courses in' designing reactors.
N ) ,.s N
You indicated earlier that you did not' 15 -Q M_ s a
16 in the cott rs e of your formal education take h' s N
- '- 17 course in thermal dynamics.' 14h at was'the nature of 18 the course you took which included the subfect of
..- w ' *
' ~
d esign of pressurir.ed water geactors?
~19 tL7 \
'% ' s -
You a're going back a lon's time.
t 20
, ~\ % s
.- % ,5 1 s . 1 \.
e y w t Idhapreciate that.
, s, t ,
' k 21
- dh 3 ; ( l'
~ ,a.,. .Ns J(
'\
3 '
j' - !
I am tr/ing to
-*' ' Y', ' A'- We -had a design '*course.
2h(
?t S. W .
I think it was probably 23 'h r L'fresdarber q% %
the textbook.
? t < , 1
- Glas s tone'-S i=on ski , which has 'the s title ' quc'le ,- ar
! t ~~, '
V ~24 . s e _g ' .%
f o Sizonski'was one of my .
3-25 ' Reactor Engineering.
.,}y h 8[
x j --
---___.___.x__
'\ti
_m.._____,_
1 Long 15 2 professors at Purdue. We also had a project design 3 course where we worked through the design of a l
4 portable nuclear power plant which was strictly a Project design. No one ever built one, at least l
(' 5 6 not like the one we designed.
7 Q What course or courses did you teach l
8 while you wera at the University of New Mexico which I l
9 related to pressurized water design?
10 A We had a similar project dd, sign course 11 where the students worked on a team. I taught it 12 several times. Sometimes the students would do an
/' ;
L' 13 original design. Other times they would study or 14 m ayb e do a comparison study between two different 15 manufacturers' designs.
16 Q. Do you recall ever considering the 17 design of a B&W plant in the course of teaching these 18 courses?
19 A Not specifical-ly B&W plants, no.
20 Q What textbooks or textbook did you use 21 for your design course?
22 MR. GLASSMAN: When?
23 MR. BENEDICT: When he was at the 24 University of New Mexico.
25 A Seems like we followed a text that was
1 Long 16 1
O 2 published by Professor Sizonski which was kind of a 3 follow-up to the Sizonski and Glasstone text. ,
4 Q Is that a publication that was publicly ,
5 available or was it privately printed?- ,
6 A No, it was a published text. ,
t 7 Q Do you recall the names of the authors?
8 A Siskonski was I think the sole author 9 of that particular one.
10 g Did you also use the textbook that you 11 recall using when you were at Purdue?
12 A Yes, Glasstone and Sizonski is kind of 13 a good reference text that we have used all through 14 the years.
15 Q What if any training or education had e
16 you had prior to this project'for-Con Ed on the 17 operational aspects of a pressurized water, power 18 reactor?.
19 A Nothing more than what we already 20 discussed. The reason for going to Con Ed was to 21 get more experience with commercial power reactors.
{ You indicated that 'you had spent some 22' Q 23 time prior to this_ project at Con Ed's Indian Point
- x. 24 Unit.1, I think you said a year, starting-in 1970, 25 is-that right?
!- l
1 Long 17
,s 2 A, Yes, 1970-1971.
3 Q What was your job responsibility or 4 project or reason for being at Indian Point 17
( 5 A I went there under a program sponsored 6 by the Ame rican Society for Engineering Education 7 to provide university faculty members with industry 8 experience. I think my title at Con Ed was 9 associate reactor engineer.
10 When I got there, they hadtjust 11 recently discovered problems with a thermal sleeve 12 in their primary coolant system, agd they asked me 13 whether I would keep track of all of the quality 14 assurance, nondestruc.ive activities associated 15 with repair of that problem.
16 Q. What kind of reactor is Indian Point 17 17 A Indian Point 1, which is no longer -
18 operating, is a pressurized water reactor.
19 Q Do you recall who designed the nuclear
-20 steam supply system?
21 A I.am pretty sure B&W did the nuclear 22 steam supply system. At the time'I was there, they 23 h'ad change'd.the core from the B&W core-to the
. ,7
( ). 24 Westinghouse. core.
25- Q -- Do you know whether the heat exchanger
Long 18 1
> r~s 1 (_)
2 or steam generator was a once-through steam 3 generator?
4 A No, they were U-tube generators located in a horizontal position. They were rather unique.
(
5 6 Q What was the approximate thermal output 7 of the Indian Point 1 reactor?
8 A As I remember, it was about 280 9 megawatts. Something close to half of that came 10 from an oil-fired super heater which is>.also 11 unique.
- 12 Q So at least with the addition of the
~
13 oil-fired heat input, Indian Point 1 operated with 14 -a super heat component in its secondary side?
4 15 A That's right.
- l 4 16 Q. Was Unit 1 being used to generate 17 electricity at the time you were there? ,
18 A Yes, we got it started up before I left.
19 The repair job took about six months and then it 20 ran for a while'during the time I was still there.
21 Q What was the nature of the repair work.
22 that you were involved in?
23 A We~-had to remove the nozzle that was a
-[-s') 24 connection for adding makeup water into the primary A._ f 25- system. _ we also had to cut out a portion of the V
1 Long 19
~
2 primary hot leg, the major piping, and replace it 3
with another nozzle and with a new thermal sleeve, 4 and then we closed the line.
( 5 Q That was work that you did prior to the 6 work we were talking about earlier with respect to 7 xenon redistribution, I take it?
8 A That's right.
9 Q The next task that is indicated or 10 listed in your written testimony is that you were 11 the " supervisor in charge of the design, 12 development and installation of a fossil power 1
N 13 plant simulator at.the University of New Mexico 14 under the sponsorship of the New Mexico nergy 15 Resources Board and the Public Service Company of 16 New Mexico."
17 What was your role or responsibility-18 with respect to the installation of the simulator?
~
19 A Again, as principal inve s t ig a to'r , I i
i 20 directed the activity of a Ph.D.' student, and there 21 'were a-couple of other' student research' associates.
working on the same project.
22 l
23 -Q Prior to this work,.what'if'any-L l >- -
-( sj 24- experience had you had with respect to power plant.
- s. /
25 . simulators?
~ .1 . . _ _ ,_ . . . . .
~. .. ._ __ __.
Long 20 1
,m w
2 A Prior to that work, none.
Q was the simulator at the University of 3
4 New Mexico a full-function simulator? .
(. 5 A No, it was a limited-scope simulator 6 designed to demonstrate principles of operation of 7 fossil plants.
8 Q Did it purport to replicate a typical 9 control room for a fossil plant?
10 A No, it did not. t 11 Q How long and when did you work on this s 12 project? ,
2 13 A I think we began work on it about the 14 1973 time period. This funding began in the fall
! 15' of 1974, and the student completed the work 16 somewhere in the 1976-1977 time period.
17 Q Do you know whether this simulator is 18 still being used at the University of New Mexico?
19 A No, I don't know.
20 Q The next task listed is " consultant for 21 General Physics' Corporation, with the task of 22 revising the reactor engineering volume of General 23 Physics' ' Academic Program for-Nuclear Plant i
\_/- 24 . Personnel.'"
25; What . was your job as .a consultant . to-
+
1 Long 21 (s -
2 General Physics? ,
3 A General Physics had I think a whole set 4 of volumes of textbooks that they marketed for use by the industry in training reactor operators and
( ,
5 6 other power plant technicians, and they asked me to 1
7 help revise and update a copy of the Nuclear 8 Reactor -- whatever that title is.
9 Q " Academic Program for Nuclear Plant 10 Personnel." t 11 A Yes.
12 Q With whom did you work or did you work
(~)
\/
13 with a number of people in doing 'his consultation?
14 A I worked with several people. The 15 only names I remember is Bob Deutch, who was and 16 still is I think president of General Physics ,
17 and another engineer named Dick Burdette..
18 Q Is General Physics a vendor of training 19 services to utilities?
20 A Yes.
21 Q They. sell.more than just textbooks?
..L 22 They also sell the services of trainers or 23 consultants?
i j i 24 A Yes,.they do provide instructors for.
w/
25 use at theLutilities.
[ . . . , . - .
3 1 Long 22 2 Q Was it your understanding that the ;
3 textbook that you were revising was going to be used 4 by licensed operators or by people who were in training to be licensed operators for nuclear power
( 5 6 plants?
7 A I don't remember whether that was 8 specifically for operators or whether it was a more 9 general text for various kinds of technicians.
10 Q Did the textbook, as you recall, have 11 specific discussions of the operation of pressurized 12 water reactors?
13 A Yes.
14 Q Did it have specific' discussions of the 15 operation of boiling water reactors?
16 A. Yes.
1 17 Q Since your arrival as an employee of 18 GPU or a GPU subsidiary, have you ever Tecommended 19 to GPU or Met Ed the use of General Physic's'for 20 training operators or other plant personnel?
21 A No, I haven't recommended that.
k 22 Q Have you ever recommended the use of 23 this textbook?
I 24 A No.
25 Q Do you know whether the textbook is =
l
Long 23 1
. p 2 still being used?
A No, I do not.
3 4 Q Do you know whether GPU or Met Ed or 5 any other part of the GPU system used the textbook I
6 or General Physics?
~
7 A I don't know whether they used the i'
8 textbook. We have used materials from General 4 9 Physics, and we have used staff members from 10 General Physics to assist us in our instruction of 11 programs.
12 Q Do you know whether GPU has used General 13 Physics prior to the Three Mile Island accident on 14 March 28, 19797 15 A No, I don't know.
16 Q - You do, however, know that at some time 17 since your arrival they have used General Physics' 18 services?
19 A Following the accident time period, I am 20 aware of them using General Physics, yes.
21 Q Did you have any role in administering 22' or supervising the General Physics program or 23 ' presentation at GPU or Met _Ed?
.A
(_,/ 24
-A only very indirectly, once I became 25
' director of training and education.
1T - -- ' - --
i l
l-I Long 24 1
d Q Do you know what subjects General Physics 2 D 3
were requested to train on? Et t.
r.
MR. GLASSMAN: What time frame?
4 f3 MR. BENEDICT: Whenever he remembers.
C:. 5 b 6 A No, I don't recall the specific :
7 subjects. i 8 Q Do you recall that they were training .
9 licensed personnel? i.s g
10 A I don't know. .
11 Q When you were at Argonne, did you have 12 an operating license for the thermal source .
- O,*- ,
13 reactor? -
14 A No, I didn ' t- have an operating' license, 15 because that is a Government reactor, and they don't actually issue licenses. I was a certified 16 17 operator, however. .
18 Q What was your'first reactor op5 rating experience? Was it at Argonne or was it prior to
-19 20 that in an'academ - setting? i 21 A No, the first reactor operating j
22 experience was'on the Argonne, thermal source 23 . reactor as a trainee, and then I became certified so I'could do:my dissertation work
, ls / 24 as an operator.
25 on the reactor.
i
- - " ~
, , , . . . , . . . . . , l
I l
25
- Long What if any operating experience have 2 Q [Nf; you had on light water reactors? E.,
3 A
I have not had any direct operating %s 4 . ~
5 experience on 1,ight water reactors. ki Wasn't the Argonne reactor a pool 6 Q ?
7 reactor? O.
A Yes. I was thinking light water power I.;
8 #
b-reactors.
Yes, the Argonne reactor was a pool l; 9
10 reactor.
.Q You had no operating experience at the 11 :
' / 12 Indian Point Unit 1 reactor? ,
~ (.
A Nothing other than observing operations. 4 13 Q
You say you were certified as an operator 14 for the Argonne facility. Have you ever held an 15 ' ,
16 AIC or NRC-issued license?
A Yes.
17 For what facilities-were you licensed?
18 Q 19 A I was licensed as a senior reactor 20 operator on the university's training reactor.
Q That is the reactor you were telling
( 21 23 me about that has a solid core?
A. That's right.
23 r~'N 3 still valid?
(). 1 I Q Is your reactor' license 24 No, not~once I' terminated employment A
.25
26 Long i
O V
2 with the university. U c:,
C#
the United Kingdom Q
What was your work at ,
3 f slf' 4
pulsed experimental reactor? Ik?
6'
( 5 A I went there in 1966-1967 on leave from %; '
6 the university to assist them in the starting up of i
' i and I functioned as, I guess i 7
that pulsed reactor, 3.c f I don't 8 you would call it, a reactor supervisor. .
9 remember the exact title. i-Q Senior reactor physicist? ,
s 10 .
A Yes.
11 What was your job as a senior reactor I 12 Q 13 physicist? '
A That meant that I could be in charge of 14 decisions with respect to the 15 q a shift and make the
- i 16 operations of that reactor. .
Q
.What was the general design of this 17 18 reactor?
A First off, it is a fast-pulse reactor, 19 20 but its design is somewhat different than the It.uses pin-type White Sands or Sandia reactors.
( -21 They are in a solid matrix of 22 fuel elements.
and the whole system is 23 copper and epoxy rer.n,
~.
(V 24
' reflected by. copper.
Q What is the purpose of this reactor?
25
1 Lon9 27 O 2 A It is also used to produce pulses of radiation for radiation effects testing.
3 1
4 Q Your writter testimony indicates that
( 5 you " spent one year with the Electric Power Research 6 Institute as project engineer with responsibility 7 for managing projects in availability engineering i
8 and development of utility power system data bases."
9 First, when did you spend this year at 10 EPRI? t 11 A I was on sabbatical leave in 1976-1977 12 from the university.
O 13 Q What was your job as project engineer 14 with responsibility for availability engineering?
15 A EPRI staff members essentially managed 4
16 the works, from EPRI's viewpoint,.that is being 17 - done by contractors. You have prime contr, actors
! 18 who assign the projects. The EPRI staff member i 19 negotiates their contract in' terms of its technical 20= content, monitors the work, reviews the reports.
21 Q What is availability engineering?-
22 A In general, availability engineering 23 'is a term used to describe the activities used to
,. . f~ . . .
i
( 1 24 - find wayc of improving the. reliability of power f
- 25 plants. l l
u __
1 Long 28
- 3 f
Q)1 2 Q What if any specific projects can you 3' recall working on during your year at EPRI?
4 A One project was developing essentially
( 5 literature shirts and a base for describing what 6 availability engineering was, how it was being 7 applied in the industry. Another was developing a 8 review and some recommendations for reliability 9 data bases for the power industry.
10 A third was a survey of thd, performance 11 of steam generators across the nuclear industry.
,, 12 Q What was the issue with respect to the tj 13 performance of steam generators?
. 14 A At that time, the steam generators 15 were just starting to experience what the industry 16 calls denting problems .
17 Q What is denting? .
18 A A phenomenon where you get crud buildup 19 in the cracks on the secondary side of the steam 20 generators, which tends to squeeze or dent the 21 tubes and can lead to cracking of the tubes and 22 thus to tube leaks in the steam generator.
23 Q Did this project' include consideration 78 1 v j- 24 of both U-tube and once-through steam. generators?
I 25 A Primarily it is associated with U-tube l
_ _ . _ _ _ _ _ _ . _ . _ _ . _ _a
1 Long 29 2 steam generators, since at that time the OTSG's 3 almost had no problems with tube leaks.
4 Q According to B&W 668, in June 1978 you came to GPU Service Corporation as the manager of
_( 5 i 6 generation productivity. Was there any relation 7 between your job function in your new job at GPU 8 and what you had been doing at EPRI?
9 A A very direct relation, yes.
10 Q What is the relationship? (
f 11 A GPU had decided to form a new department 12 in the Service Corp. that would focus attention
'n 13 on improvement of the performance of their power 14 pl. ants throughout the system.
15 Q Were you brought in to manage a group 16 o r unit that was set up for the first time upon 17 your arrival? .
18 A Yes, that's. right. I was brought in to
! 19 up basically, to-recruit the staff, and initiate.
l 20 the work.
21 Q How wasyour job responsibility described 22 to you when you arrived at GPU?
- 23 A. . Basically, I was. asked to work.witn the
( .s y l( ) 24 . operating companies, to guide'their development of
-25 pe rformance ' improvement. p rograms , .primarily p
t -
t m e-- 4
i
.i l
Long 30 1
p V focusing on the large coal plants in western r 2 ?
3 f'.~
Q Your work included both nuclear and ~
4 ,
{ fossil?
A Yes.
i 6
In the approximately nine months between Q
7 your arrival in June 1978 and the accident at Three g
Mile Island in March 1979, approximately, what 9-r percentage of your time was spent dealing with g 10 .
issues related to nuclear facilities in the GPU 11 sy tem?
12
\- MR. GLASSMAN: 'You don't want him to 13 guess, I assume?
14 MR. BENEDICT: No, what he has as an 15 "pproximation. I am not going to hold him 6 -
to the decimal points.
17 A I don't know percentage, but I.would 18 a
s ay. perhaps a week or two weeks out of those nine I was months might have been focused on nuclear.
20 primarily concerned with the fossil plants.
'L
( Q Was it your understanding that that-was 22 to be the emphasis in your job when you arrived?
23 f3 - MR. BENEDICT: I am trying to
( ) 24 k'
differentiate between happenstance or 25 f
i i
l 1
1 . Long 31
)
2 circumstance during those nine months which 3
led him to spend most of his time on fossil 4 as opposed to his understanding at the time
( 5 he arrived as to where his emphasis would be 6 for the first year that he was at work.
7 A No, that was consistent with my 8 understanding.
9 Q When did the generation product-10 ivity -- is it a division or group?t 11 A Department.
12 Q When did the generation product-13 ivity department jell into something that was 14 actually doing work corresponding to its mandate?
15 A We were beginning to feel we had a 16 fairly w. ell-defined program in place just about at 17 the time of the TMI accident. ,
18 Q Prior to the accident in Marcb 1979, had
-19 you had any responsibility with respect to'the 20 training of.any GPU or Met Ed personnel?
. 21 A No,LI.did not.
.22 Q You didn't'have'any responsibility with 23 respect to reviewing operator' training or any other
.fs.
,( 1
,24 . training?
- R.)
25 '- ' A '- No.
y g- -v-- (-
1 -
Long 32
. ;/~)
~
2 Q Do you recall whether prior to the Three 3 Mile Island accident you knew who was the head of 4 the training department for Three Mile Island?
5 A No, I don't think I did.
(
6 MR. BENEDICT: I would like to have 7 marked-as B&W Exhibit 669 a document provided 8 to us by counsel for GPU, which is headed 9~ "GPU Service Corporation, Generation Division, i
10 Division. 30," and it bears the dA,te in the 11 lower right corner of April 1st, 1979.
12 -(Document headed "GPU Service Corporation, N ,
'- 13 Generation Division, Division 30," dated J
14 April 1, 1979, marked B&W Exhibit 6'69 for 15 identification, as of this date) 16 Q. Does B&W 669 accurately reflect the 17 generation productivity department that you set 18 up prior to the Three Mile Island accidenk in March 4
19 1979?
20 MR. GLASSMAN: You want the witness to
. 2'1 review each title and each name?
b 22 MR.. BENEDICT: I am more interested in 23 the titles than the names'for the moment. It
. f^%' is the lower quarter of'the document that I am l 5 124 '
s 25 interested in.
1
+
~
1 Long 33 MR. GLASSMAN: Are you then, so we're 2
3 clear, are you then referring to the titles 4 appearing beneath the titic " Manager of
([ 5 Generation Productivit?"?
6 MR. BENEDICT: That's right.
7 .A Yes.
8 Q For approximately how long had this 9 organization been set up and these people listed 10 here filled these jobs prior to the Apfil 1st date 11 of B&W 669?
12 MR. GLASSMAN: You are referring to 13 the individuals beneath the title " Manager, 14 Generation Productivity"?
15 MR. BENEDICT: That's right, beneath 16 Dr. Long's name.
17 A The organizational structure was set up 18 within a few months after my arrival at GPU. Some .
~
19 of the people, namely, Mr. Locke and Mr. Weiser, 20 were already employed _by GPU when I arrived, and 21 'then they were assigned to me. Ms. Niebo began 22 work.for us I believe in late.1978. Mr.
23 Billingsley began work for us in early 1979. I
( 24 don't remember the exact month.
1 25 Q Had Mr. Billingsley worked at GPU' prior us
1 Long 34 0 2 , to that?
3 A No.
4 Q Did you interview and hire Mr.
Billingsley?
( 5 6 A Yes.
7 Mr. Christy was a co-op student from 8 the University of Cincinnati who joined us in 9 March 1979 about a week before the TMI-2 accident.
10 Q Beginning when you were hir.ed in June 11 1978 through until the day of the accident in March 12 1979, did you report to Mr. Bachofer?
13 A Yes.
14 Q Did you at any time prior to the Three 15 Mile Island accident report to anyone other than 16 Mr. Bachofer directly?
17 A No. ,
18 Q Did you know Bob Keaten prior to the 19 Three Mile Island accident?
20 A Yes.
21 Q In the GPUSC hierarchy, what were your 22 relative levels, if you know?
23 A He was a manager, reporting to a director, as was I.
( 24 25 Q So as you understood it, he was
1 Long 35
(_/ 2 essentially the same corporate level?
3 A Yes.
4 Q According to your written testimony before the Atomic Safety and Licensing Board, you
( 5 6 were "a member of the TMI-2 recovery team from 7 March through July of 1979."
8 During this time period, did you do any 9 work or have any responsibility with respect to the-10 generation productivity department? (
11 A very limited.
12 Q Your time was principally taken up with
(~) -
\~>' 13 your responsibilities with respect to the recovery 14 team?
15 A That's right.
16 Q. Your testimony then indicates that you 17 " served as director of the TMI_ generation, group's 18 reliability engineering division." That is also 19 noted on B&W 668.
20 What was the nature of your job 21 responsibilities aus the director of_ reliability 22 engineering?
-23 A' We were setting up a new division.under
,~m
( )- 24' 'the TMI. generation group, which was headed by Mr.
w./
25 ' Arnold. The' division included'the systems f
l i
- Long 36 1
O 2 laboratory.
1 3 Q When you say " systems," that is the GPU l
4 systems?
5 A Yes.
6 Q It included the laboratory?
7 A Yes. The quality assurance department.
8 Q The information management department?
A Yes. And I think to begin setting up 9
10 the nuclear saf ety asse ssment departmenti 11 Q Was this a new group within the 12 generation division?
f-s MR. GLASSMAN: Which group re you now 13 14 referring to?
Q Reliability engineering? Is that a 15 16 new group within the generation division?
17 A I can't answer that directly. ,
18 It was still part of GPUSC. This was Q
19 prior to the creation of-GPU Nuclear?
- 20 A -Yes,-it was prior to the creati'on of 21 GPU. Nuclear, but th'e TMI genera' tion-group combined
. 22 people from the Service Corp. generation division 23 and Met Ed, so;that we had all the' personnel at TMI,
. ,r$ .
()_
24 some'. people from Med Ed,. Reading, and'then large 25= numbers ofistaff people from the.Parsippany Service m
-
- v
Long 37 1
[v) 2 Corporation group reporting to the head of the TMI .~
3 generation group. I 4 Q Was Mr. Arnold the head of TMI ;
k 5 generation group? 4 6 A Yes.
7 Q And your division was part of the TMI 8 generation group?
9 A Yes.
10 Q So as of the summer of 1979,tI take it 11 what we have marked as B&W 669 was no longer an s 12 accurate representation of the setup?
s 13 A That's right.
14 Q At GPU?
15 A Right.
16 Q - .You said one of your responsibilities !
17 was the-setting up of the nuclear safety a,ssessment
~~
18 department. What was the nuclear safety ' assessment 1
19 department?
20 A It was intended to be a small group 21- that would provide an overview of all activities
'22 in GPU cn: in this case, the generation group,.which 23- might impact on nuclear safety.
r~s I i- Were you the head of this department?.
is/f 24 Q 25 A No,-I was the director over that
_a
i
- Long 38 1
3 (a
2 department, and I was in the process of recruiting .
1 3
who the staff should be and even defining what the !
4 functions of the department should be. :
Q Who was ultimately recruited for this 5 .
6 department? Who was the first full staff? .
7 A The first full staff was a contractor .
8 from Burns & Roe, and the man's name was Don 9
McCormick, and then eventually we recruited a GPU i 10 person whose name was Robert Whitesel. t 11 Q Mr. McCormick didn' t work for the GPU J
N 12 system? .
13 A No. .
14 Q He was 15 A We contracted with Burns & Roe for his e
16 nearly full time, I think . about 80 percent at that time.
17 18 Q Who if Lanybody did Mr. McCormick
~
19 have working with or for him?
20 A When he began, he had I believe two
'other Burns & Roe engineers. I don't remember their j' 21 22 names.
23 Q Does the nuclear safety assessment.
t^\
.kj :24 ._ department continue to exist in some form at'GPU?
25- A. Yes.
L
- - ~ - - .. .
Long 39 1
f 2 Q Who is-the current head?
3 A The current head is Robe rt"Whitesol.
4 Q Does Mr. Whitesel have anybody working 1 I
5 for him?
6 A Yes, he has at the present time, he has 7
a secretary and he has some people at TMI reporting 8 to him. He is recruiting again for his Parsippany 9 staff.
10 Q Does Mr. Whitesel report to you? ,
11 A Yes, in my current position.
- l. _ 12 Q What is the current name of Mr.
13 Whitesel's department or group?
J 14 A It has tha sa'me name, nuclear safety 15 assessment department.
16 Q- However, it is now part of GPU Nuclear?
17 A That's right.. .
18 Q You indicated in your earlier testimony 19 that one of your responsibilities or tasks'during 20 thisl period was to define the_. responsibilities of the nuclear. safety assessment-department. How did 21 22 you define thoce responsibilities?
23 MR. GLASSMAN: What. point in time?
.A MR. BENEDICT: 'In the initial creation A( -- . ' 24 ,
-l . ._ .
~ 25 ' of'the..departmer ._
, -- "9
. - p- = ,- p-
c.
1 Long 40 0 2 A Would you clarify what you mean by 3 "how"?
4 Q I don't mean the mental processes. What 5 were the responsibilities as you defined them?
(
6 A One major responsibility was to support 7 the activities of the GPU general office review 8 boards, known as the GORB's. Another is to manage 9 the activities of the independent on-site review 10 groups. There is one of those functioning now at
-11 TMI-1. There will be one at Oyster Creek 12 eventually, and perhaps there will be one at TMI-2 1
(~)
k/ 13 in the more distant future.
14 Then the corporate group, in addition 15 to supporting the GORB activities, has, as I 16 mentioned l earlier, kind of an oversight 17 responsibility for looking at any and all, activities
~
18 that might impact on nuclear safety. They also
- 19. perform the function of a nuclear safety o'mbudsman
,c l
20 for the GPU Nuclear Corporation.
21- Q ~ These were"the-roles.or ~ responsibilities 22' as you defined.them in.the summer of-1979/
23 A They were certainly. considered in the fy n ;c
~(v ). 24 late summer and fall of 1979, and I more fairly have 25 described them asi they have evolved at thisipoint'in
,N.
a h
1 Long 41 2 time.
3 Q Are you aware of any description or
.4 documentation of the responsibilities of the nuclear )
5 safety assessment department?
({
6 A Yes. 1 7 Q What are you aware of?
8 A There is a GPU nuclear organization book l 9 which describes their responsibilities.
10 Q Did you draft the contentshof that book 11 with respect to this department?
12 A The'very earlier drafts sere prepared b\/ 13 by Mr. McCormick and I reviewed them.
14 Q Are. you aware of~any people or groups 15 - or departments within the GPU system who he'id the responsibilities you have' defined for the nuclear
~
-16 17 safety' assessment department prior to its. creation 18 in the summer of 1979?
19 MR. GLASSMAN: Are you talking about 20_ ~romeone who had all'of these responsibilities'
. 21 or particular ones?
h 22 MR. BENEDICT: .Let's hear it back.
23 =(Record rea,d) rx ~
jx ,;; 24 Q By that, I mean:any of_the
' 25 responsibilities,.not.necessarily.all of.the
..c7 <v,: -
- s. ,
1.
~
s
%.~ % f ( ; g' g
%g-4 W s
'k .
jp 1 u I \ f m
- *4 e ,, S u
3 42 1 % ,s %1.ong.
. - ~
,5 , -- s. j
, )
~
t N
(f re s p o n s i5il i.uiet .s. .?,
't'
,y 2 A i, '. s
- ~
i N l,s% ;
3'
"~
A The 'G' ORB groups were functioning for N
- > \
4't. I' some period of time. I don't know when they
- u.
- , ~ '%
and they were supported by some
(- J
'5 s ta rte d. ptNIP U
's s '
1 i t, ij staff from the Service Corporati$a. '
is'
'" N TN 7- Q Aro you a member of either of the '
GORBs?
,(; . . rt j\. _.
'" V. 8- A No, I am not. \
{ n Werc you ever?
9 Q ,
A No. e 10
%. ~
11' Q 'Are you"a member of anysoi the other A- A k.?l2 ,
groups or committee's, review groups,<Dithin GPU?
' i'- s .
13 A No, not..ah the presento time.
14 Q Have you ever been a member of any such review groupp -other sthan the accident review-group 15 ,
s 16 we .. dis ettssed e arlier?f's f
17 A No. .
'18 Q Who, if anyone to your knowledge, had.
.19- responsibility for, .as you have put it, ov'ersight
. 20 responsibilities with respect to safety-related 21 matters prior to the -Three Mile Island accident?
22 -MR. GLAS SM AN : During.what-period are
~ 23, y'ou talking'about? Mr.-Long was only with-the-lf^;)
. ~
company a very short period'of time,
~( 24 . _
Any-time he..is aware of 125 -- MR. ' BENEDICT :
> ~
ws-
43 Long 1
(')'
w 2
prior to the Three Mile Island accident. W A certainly that oversight responsibility 3 b 4
is one of the responsibilities of the GORBs. ,
Q Other than the GORBs, are you aware of 5 G 6 any group or unit or person or organization within ,
7 GPU who had that responsibility prior to the 8 sccident? ,
A I am not aw are of who those might be, 9
10 but I am not f amiliar with the Met Ed organization.
11 Q Does the nuclear safety assessment 12 department have any review or oversight g- .
13 responsibilities with respect to the training of 14 licensed personnel at Met Ed or JCP&L?
A At the present time?
15 16 Q . Yes.
17 A First off, Met Ed and JCP&L don't have 18 control --
You are right. Let me fix the -
19 Q 20- question.
21 Today, does the nuclear assessment 22 . department have any responsibil'ities with respect 23 to NRC-licensed employees 1 of GPU?
Insofar as'that group might think they-k) 24 .A
. have. an impact on nuclear safety, they could 25 F o,
s
- Long 44
.1 u
k .-
.2 certainly look at them. ,
i Q You are n t aware of any ongoing .
3
.4 responsibilities that that group has or department
( 5 has? .
A- Not a specific assignment, no.
6 7 Q Does the nuclear safety assessment ,
8 department have any responsibilities with respect g to-assuring compliance with 10 CFR, Part 217
. 10 A No; again, not directly in terms of 11 assuring compliance.
' 12 Q What do you understand the general O 13 requirements to be of 10 CFR, Part 21 t day, just very generally? I am not looking for specifics, 14-i A I think I would want to go back and 15
' 16 read 10 CFR, Part 21 to answer that. .
i 17 Q Do you understand'that 10 CFR,,Part 21 18 imposes certain requirements on you ~ as an ' employee I
19 of GPU. to report to the NRC or take steps to'see to 20 it.-that the NRC is notified of certain. safety-21 related issues?
-A- Yes.
22 23 12 When-did you'first-become aware of' "N .
. x,l ' 24 .your having_any responsibilities _ personally with 25 respect to 10 CFR, Part.21?
,w-- --+,,g.
v.,e w y~,,,,b- <-m ,,-- - ~ - - - . 3.,- - , -.
1 - Long 45 1
2 A When it was issued, but I don't remember 3 the date of issue.
4, Q HI f I told you it was January 1978 that it became effective, would that help you place it
( 5 6 in time?
7 A That sounds about right. I would have 8 been notified as a licensed operator and responsible 9 lab director at the University of New Mexico.
10 Q At any time following your>.-arrival at 11 GP U., but prior to the Three Mile Island accident, 12 did you receive any training or education or written
~t
\/ 13 material with respect to your responsibilities 14 under 10 CFR, Part 217 15 A None that I recall, but remember, I 16 was primarily associated with the fossil plants ~.
17 Q Since the Three Mile Island a.ccident, 18 have you received any training or written material
- 19. or education with resr9ct to your responsibilities i-210 under 10 CFR, Part 21?
21 A Yes. That -isL dis cussed in the general 22 employee training that is provided to all personnel 23 who have access badges to"either site.
- /~T -
l, ) :24 .Q ;And has.that training been provided to s s-251 you?. l
- Long 46 1
ws-.
2 A Yes.
3- Q And that was since the Three Mile Island.
4 accident?
5 A Yes.
k 6 Q what are the independent on-site revi.ew 7 groups that you spoke of earlier?
8 A I can't tell you very many details, 9 because it is just starting to function, and I am 10 just starting to get familiar with them s. ag ain . I 11 was not directly associated with them for some 12 period of time until my recent new position. We
%j' have reorganized the safety review process at the 13 14 site, and eventually the plant operating review 15 committees will no longer be functioning, and the 16 IOSRG'are part of the review process that replaces 17 that older PORC process. ,
18 Q Is.the concept of the independent 19 on-site review' group something that has be'en 20 developed since the'Three Mile Island accident, to
~ 21- !your. knowledge?
22 A Yes.
23' Q What is the expected composition in
. f3 terms of position.or title of.the independent (pI-24-25- -- on-site review group?
- i
' k te
- Long 47 1
l)
V MR. GLASSMAN: Expected by whom?
2 MR. BENEDICT: Expected by Dr. Long.
3 4 A Primarily it would be engineering l 5 graduates with some minimum number of years of 6 experience.
7 Q Employees of the General Public 8 Utilities system?
9 A They will be employees of GPU Nuclear.
10 Q will it include any licensed. personnel, 11 to your knowledge, or requ!re the inclusion of any 12 licensed personnel?
O 13 A It does not require personnel to be 14 licensed.
15 Q. What did you mean when you said that x 16 one of the responsibilities of the nuclear safety 17 assessment department was to act as an' ombudsman?
18' A The ombudsman function I think is one 19 that you are familiar with in general term's. It 20 is someone you can gb to in confidence and express
. 21 a concern and be assured that that concern-has been.
22 I
addressed. That is basically th e function of the 23 nuclear safety ombudsman.
p).
4 24 Q' To-your knowledge, did such a person 25 .or organization, or did that person or organization m
- e n a n e- me r
1 - Long 48 V. 2 exist at GPU or Met Ed with that responsibility 3 prior to the Three Mile Island accident?
4 A No, it did not.
( 5 Q You were, as you say, involved in the 6 establishment of this department in the summer of 7 1979. Whose idea was this department?
8 A The concept I believe evolved from 9 discussions between Mr. Arnold and Mr. Dieckamp.
10 Q Do you know whether any of t these 11 discussions had occurred prior to the Three Mile 12 Island accident?
\- 13 A I think they had discussed them some i
14 before the Three Mile Island accident, yes.
15 Q Are you aware today of any efforts made 16 prior to the Three Mile Island accident to organize 17 or establish something that became or waa to become 18 the nuclear saf ety assessment department?
19 A since I wasn't associated'with that, 20 I don't know what was done prior to the accident.
21 ~ Q ' Earlier, you had difficulty _ answering
( .
22- one of my questions because I was unclear-about the 23 current role that the Metropolitan Edison and
~ [;~;} -
. L/
' ~. 24 JCP&L sub'sidiaries play with respect to the 25_ operation asf. Unit 1 Eat TMI and the' Oyster Creek 4
J
, ,e- y w --- w --
1 Long 49
. ,a '.
T")
2 plant.
3 Could you briefly describe for me what 4 the current status is of the licensing of those 5 facilities?
(}
6 A GPU Nuclear Corporation became official 7 in January 1982. We formed the administrative 8 structure for GPU Nuclear in early 1980 and began 9 all the requests to the various agencies to 10 transfer licenses and get approvals oftthe utility 11 commissions and the Federal Regulatory Commission 12 and the Securities and Erchange Commis sion and
\
13 eventually the Nuclear Regulatory Commission to 14 where GPU Nuclear is now the operator of the TMI 15 and Oyster Creek stations. The owners of those 16 's tatio ns are still the operating companies. Met 17 Ed,-Jersey. Central and Penn Electric. .
18 Q We discussed earlier the fort $or the 19 structure of the reliability engineering Separtment 20 which you became the director of in August 1979, 21 and stayed at until January 1980.
~
22 Could you describe the roles or 1
z23 responsibilities of this department?
. ,m
(
) 24 A The systems laboratory provides
~~
25 chemistry and'metallurgica1Llaboratory services to
1 Long 50 0 2 all the operating companies in the GPU system. The 3 QA department provides, in the fall.of 1979 when it 4 was the TMI generation group, provides quality 5 assurance, quality control, support of TMI. That
({
6 would include both the operational kind of quality 7 assurance, quality control activities and the 8 activities associated with engineering modifications, 9 design, purchase, all the typical QA functions. The 10 informational management group was set up to really 11 effectively organize the very complex recordc 12 keeping that is required by regulatory and corporate 13 activities, and the nuclear safety assessment 14 department I think we already discussed.
15 Q During your stint as the director of the 16 reliability engineering department or unit, did the 17 department have any responsibility with rqspect to-18 training of licensed personnel or people seeking 19 their licenses?
20 A No.
21 Q Prior to your appointment as director of L 22 training and education to the GPU Nuclear Corporation 23 in February 1980, did you have any responsibility 24 at GPU with respect to the training of licensed 25 personnel or. people seeking licenses?
1 Long 51 O . 2 A No, other than the fact that the QA 3 department does review training as it reviews just 4 about everything that goes on.
Do you recall having any direct
( 5 Q 6 involvement in quality assurance or quality control 7 with respect to training prior to your receiving the 8 title of director of training and education?
9 A No.
10 Q Prior tc your arrival at G#U, 11 encompassing your whole professional career, did you 12 have any responsibility with respect to the training O 13 of licensed personnel or people seeking their 14 licenses?
15 A Training of students and faculty members 16 at the University of New Mexico to be licensed on 17 the University of New Mexico reactor, yes.
18 Q Did you have any responsibility with 19 respect to the training of any people with respect 20 to light water reactors?
21 A I gave a few lectures to operator 22 candidates when I was at Con Ed.
23 Q on what subjects, if you can recall, did
_ 24 you lecture?
25 A Health physics and nuclear reactor
1 Long 52
/ -
r-2 instrumentation.
3 Q Do you mean nuclear instrumentation or 4 the instrumentation of the nuclear reactor?
5 A Nuclear instrumentation.
.( .
6 Q You indicated earlier that GPU Nuclear 7 was set up in early '80. Did you take the job of 8 director of training and education at the time th at 9 GPU Nuclear was first established?
10 A Yes. t 11 Q. What were the responsibilities of the 12 section or unit that you directed?
O~ 13 A At the time we began, it was to provide 14 the management direction of the training at TMI, to 15 set up a corporate training group, and eventually to 16 bring in the oyster Creek training group, but that 17 was a phased operation. ,
18 Q Is-it fair to say that your work as the 19 . director of the reliability engineering unit was 20 similar in kind to the work that you did-as manager
~
21 of the generation productivity unit, although
( 22 broader, as you have a position higher in the 23 corporate. hierarchy?
- u,,
{ x[ 24 A No , I wouldn't characterize it as having 25 any similarity..
w i .' . .-
.] . . _. _ - ii.i -
1 Long 53 O
V 2 Q Did the reliability engineering 3 department have any responsibility with respect to 4 the issues of generation productivity and
^
reliability that you discussed as being the
( 5 6 responsibility of that unit?
7 A 'Only indirectly in the sense that the t.
8 QA program is designed to assure that the plant is 9 properly operated and maintained, which leads 10 hopefully to good performance and good Teliability.
11 Q But it was not a matter of your being 12 promoted within a section of the organization that
' / ,
13 also at the same time had.a name change? It was 14 definitely a different job, I take it. .
15 A That's right.
i 16 Q. I take it also it was a different job 17 to become the director of training a.'d education?
18 A Yes.
19 Q Did you take sith you any of the' people 20 -you had-had in the reliability engineering 21 ' department when you moved to your new job?
(_ 22 A .Yes, the systems laboratory. continued 23 to report to.me as director of training and-
'r^3 .
t
): 24 ' education, and I had a special projects director 25- who moved.with me.to the new job.
y
~ s - , , , 4 ,r - , - . , . . . - - , , , -
1 ,
Long 54
(~ . '
L ); .. -
2 Q Who was that?
3 A Mr. Hetrick.
4 Q Is it accurate that you were the 5 director of an organization or unit called training
({
6 and education?
7- A Yes.
8 Q What was the responsibility of the 9 training and education group or unit?
10 A I thought I de scribed that '-earlie r .
, 11 Q You said that administratively at least 12 you incorporated the' Met E.d training, is that
' (~\ s
\l 13 correct, and that you intended to incorporate the 14 JCP&L ~ training?
15 A No, I wouldn't say it that way. I was 16 responsible for direction of the training at the 17 TMI site with a manager of training the re . repo'rting 18 to me.
19 Q Who was the manager reporting to you?
20 A In February 1980, it was Mr. Lauer.
21 Q L. L. Lauer?
A 22 Yes.
23 Q Did that position, manager of training
(, ,) .
24' at TMI, change in the course of your tenure as.the ,
25~ head offtraining and e'ducation?
sim-, t mf ,_ g we g- y ,w i
- 1 '-
1 Long 55 1
D t' V
2 A Yes. .
3 Q Who did it become?
.4 A The man who replaced Mr. Lauer is Dr.
Ron Knief.
({ ' 5 6 Q Do you know whether Mr. Lauer held that 7 po'sition prior to the Three Mile Island accident?
8 A No, he did not.
9 Q Do you.know who held the position prior E
10 to the Three Mile Island accident? ,
11 A There was not anything equivalent to 12 that position prior to the accident.
13 Q Following the Three Mile Island 14 accident, was a new -- was the training at TMI 15 reorganized with Mr. Lauer as its head?
16 A. The training was reorganized. I am not
-17 sure exactly when Mr. .Lauer was made head., whether~
18 that was right~at the time-of-the reorgankzation or 19 whether.it happened a little later.
20 .Q What was the nature of'the 21- reorganization, as you understood it?
C 22 .A The. program was expanded to include ~
23 personnel in addition tolthe licensed reactor
( ,j 24- operating. training. programs. I'would say thatswas 25 the major, change.
i . .
?;
~1 Long. 56 2- Q Do you know who was the head of 3 licensed training at . TMI prior to the Three Mil'e 4 Island accident?
Are you talking about a
( ~5 MR. GLASSMAN:
6- title?
7 MR. BENEDICT: Yes.
8 MR. GLASSMAN: The witness was not there 9 during that period.
10 MR.. BENEDICT: I understandt. Dr. Long 11 also spent a lot of time reviewing the 12' accident. This-fact may have come to him. 1 A-13 At the time of the accident, Mr.
14 Zechman I believe was supervisor of operating 15 training.
16 'O. .What did-your responsibilities encompass 17 during the.25-month period that you1 served as -
18' director of training and education?. What I am
'19 interested in-is to what extent were you an 20 administrator and to what extent were you
~
. 21_ , participating in the review or preparation of 22 . training' material? To what extent were you
- 23 = 'in'volved in'the hiring or. firing of training-24 personnel?
- v. :-
725 ;MR. GLASSMAN: .Would.you.like the a
g- ]_, . . . . . . . . .. g -
..y , .. - , , , i. .
_ , , , , , _ _ , , _ _ , , , , _ _ _ ,,.,,_,_a, , , _ _ _ , , , _ , _ , _ . _ _ _ _ , _ _ _ _ _ _ _ _ _ - _ . - _ _ _ _ _ a___..._
l' Long 57
-* tN .
- q,) .
. 2 witness to answer each of those questions 3 separately?
4 4 MR. BENEDICT: I think it is a very 5 general question. I will pursue anything Jh 6 that comes up. I just want --
Dr. Long looked e
7 -a little puzzled at my first question. I 8 wanted to give an idea of where I was going.
9 A Certainly one of the major activities 10 was to assure that the programs were ofganized 11- effectively, that their technical content was 12 consistent with the requirements that had evolved 13 after the accident. I interviewed and hired three 14 managers, Dr. Knief for TMI, the corporate training
- 15. manager, and the Oyster Creek training manager. I 16 - also interviewed some of the key section head 17 candidates at both of the sites. I interacted 18 extensively'with the sites in discussions of.both i- 19 simulator training and the developing plans for i >
20 purchase of simulators, and in addition, continued 21 my responsibility for the systems laboratory, which (1
22 'really doesn't have anything to . do with training ,-
23 ~ but alsoLthat took some portion of my time.
,m.
.( )- 24 Q 'How did youl-determine the' appropriateness 25 of-the technical content.of the training?
1 Long 58
,-s -
-Q. A Certainly I reviewed the program 2
3 descriptions -that we re being developed. I asked 4 other people to look at technical areas where I had concerns. I read documents that had come out of
( 5 6 investigation as well as the documents which began 7 -to come out of the Institute of Nuclear Power 8 Operations once it was functioning.
9 Q Did you attend lectures?
10- A occasionally, t 11 Q Did you review quiz answers?
12 A Not directly. <
f
/ 13 Q Did you review prior training outlines 1.4 or practices ?
15 A No, I did very little of that. Just t
16 things were changing so dramatically, I didn't feel 17 it was appropriate to go back and look at.the old 18 . stuff.
19 Q Did you attempt to institute a new 20 training' program from the ground up?
- , 21 A No, I would not characterize'it that way.-
22' Q ~Did.you or:your trainers rely on the 23 content o f training material prepared prior to the e j.O) 24 - Three Mile Island accident.at least as a basis for =
.x 25 . 'the program?.
? .
1 Long 59 D' ~
Certainly as a base for licensed 2 .A
-3 operator training, that's correct.
4 Q What was your role with respect to the simulator or the consideration of the acquisition of
( 5 ,
6 a simulator by GPU?
- 7 A You want the latter part answered?
8 ~Q Yes.
9 A I participated in the discussions among 10 the TMI and the. technical functions pe ople and the 11 corporate training people on what kind of i
12 simulators we ought to consider, what the time frame
. /'
'k -
13 .should be, who the possible vendors were, how to 14 evaluate those vendors in terms of getting started 15 on such a project.
1 16 Q. Has the determination been made, to 17 your knowledge, at GPU to acquire a full-function
- 18 simulator for the TMI-1 fac'lity?
19 A Yes, we do plan and we have told the 20 licensing board that we are going to get a, replica l
=21 simulator for TMI-1.
-22: Q. 'Are you aware of any' consideration 23 'within GPU prior to the Three_ Mile-Island accident
~
e x. .
i ) ' 24 related to the acquisition.of.the replic'a simulator, 25 _as.you call-it?
I'
[
In _
l 1 Long 60 I
Yes, there'was some consideration.
2 A I am 3 not sure of the time frame. I don't know any of the 4 details.
5 Do you know who was involved in those
{ Q 6 -considerations?
7 A Mr. Hetrick had something to do with it 8- because he provided to mc a file box full of '
9 material that was gathered at the time they were 10 considering it. t 11 Q Do you know where that file box full of 12 material is today?
(')M
\- 13 A Some of it may still be in the file box 14 in storage. Pieces of it may be spread around to 15 the various people. We didn't use it very much.
i .
16 We.just. looked at it to see what they had done
.17 before and then began to gather new information. -
18 Q where would you look-if you wanted to- '
19 find the material that was contained in that box 20 Mr. Hetrick gave to you?
21 A -- I have to ask my secretary to look at
([' 22
.the list of boxes:that we have'in storage.
23; Q 'You believe.that the first place you' 24 would-look would be.Lin storage which:you have some a1 25' . control ' over ,. .:.is that right?.
~
1
1 Long 61
- 9. 2 A I don't control storage, but the storage 3 we send things to.
4 Q Is this GPU central file storage?
( 5 A I wouldn't call it the GPU central file.
6 It is a storage area where you can send old 7 materials that are no longer active.
8 Q Do you know what the name of this 9 outfit is?
10 A No.
(
11 (Recess taken) 12 BY MR. BENEDICT:
O 13 Q Referring to your title as director of 14 training and education, do you know whether such 15 a position or job description existed prior to the 16 accident in March 1979?
17 A No, it did not. .
18 Q Did such a position exist prior to the 19 creation of GPU Nuclear?
20 A 'N o , it did not.
. 21 Q Do you know whether anyone or any' group L 22 of people held the same responsibilities that you 23 held as the director of training within the GPU 24 or GPUSC organization prior to the creation of 25 GPU Nuclear?
1 Long 62 0 2 A No, I don't know that.
3 MR. BENEDICT: I would like to have marked 4 as B&W 670 what appears to be an organization 5 chart for at lear' part of the nuclear
({
6 assurance division for GPU Nuclear dated 7 November 10, 1980.
8 (Organization chart for part of GPU 9 Nuclear, dated November 10, 1980, marked 10 B&W Exhibit 670 for identification, as of 11 this date) 12 Q Does this exhibit accurately reflect O 13 the organization of your group, particularly on the 14 second page of the exhibit at the date of'the 15 document?
16 MR. GLASSMAN: Is the question then 17 directed to the entire exhibit or solely to 18 the second page?
19 MR. BENEDICT: Just the second page 20 to begin with.
21 MR. GLASSMAN: What point in time?
22 MR. BENEDICT: The date of the document.
23 A Yes, it does.
24 Q Going back to the first page, is it 25 correct at this time you reported to Mr. Herbein?
\
.~ . . ~ - - -
l 1
1 l
l l' -
Long 63 0(N Yes.
2 A l
3 Q Did you through the time that you held 4 'this position or at all times that you held this 5 Position report to Mr. Herbein?
(
6 A No.
7 Q To whom else did you report?
8 A From February 1980 through early 9 _ September of 1980, I was the acting division 10 d. rector in addition to director of trdining and 11 education.
12 Q Did you continue to report to Mr.
.\/f') .
13 Herbein until you changed jobs or job positions in 14 April 1982? '
15 A. Yes. ,
4 16 Q. Did you take ove r Mr. Herbein's job in 17 April 1982? .
18 A Yes..
19 Q _As the director and vice president of
. 20 nuclear assurance-division of GPU Nuclear 21 ' Corporation, as noted on B&W 668, did you serve the
'(- 22 same': function that Mr..Herbein was serving during 23 the time that you reported to him?
pv l.
( 24 A ' Basically, yes.
e
-25 Q~ Does'the. organization of the training W
(. *
.pY
-l I
l 1 -
Long 64 l
- \_/
\
2 and education group continue today to be what is 3 represented on page 2 of B&W 670 with the exception 4 of you ,no longer being the director?
( 5 A You mean the current date?
6 Q' Yes..
7 No, there is some slight changes.
8 Q Who is the current director?
9 A Mr. Ross is the acting director, and 10 according to the memo announcing my appointment, I 11 am still the director until the new director is 12 recruited or obtained from within the organization. ,
ksw 13 Q what changes from this organizational ,
14 chart dated November 10, 1980 would have to be made 15 in order.to make it currently accurate?
16 .A. Manager.of the systens lab no longer 17 reports to the director of training and education.
18 Q To whom does he report?
19 A He now . reports to a materials and 20 chemistry director in the technical functions 21 division..
L~
22 Q Any other changes that would have to be 23 -made to m'a'ke this. currently accarate?
/~~. .
-! 't 24 A- Yes,.the TMI-2 training manager.is now
%/
-25 shown asa manager ~of TMI-2' training,. reporting to
.a '.' s T
- 1 .
Long 65 9 2 Dr. Knief, who is training manager for TMI rather 3 than exclusively TMI-1.
4 Q Who is the current training manager or manager for training at TMI-2?
( 5 6 A That position is not filled. Knief is 7 essentially still acting.
8 Q What is your current job description, 9 the one you have held since just April of 19827 10 A I now have overall responsibilities for 11 training and education, for quality assurance, for 12 nuclear safety assessment, and for emergency 9 13 planning.
14 Q Does page 1 of B&W 670 continue to be 15 an accurate description of the groups and 16 individuals reporting to you as the director of 17 nuclear assurance? .
18 A Not, it is not.
19 Q What would have to be changed to make 20 it accurate today? You are acting director of 21 training and education as well as being the director 22 of nuclear assurance, is that correct?
23 A No.
24 Q Didn't you say --
25 A There is an acting director of training
1 Long 66 2 and education who is Mr. Don Ross. I am now the 3 director and'vice president of nuclear assurance.
4 Met Ed would not appear there anymore. I am a vice 5 president of GPU Nuclear. Mr. Herbein was a vice L({
6 president of Met Ed at the time of the date on this 7 chart. Mr. Bacho fe r - is no longer in that position.
'8 The re is nobody in that position, manager of 9 special projects, nuclear. Mr. Kacanas has the 10 title of director of quality assurance /,rather than 11 manager. The NSAD position is described as NSAD 12 director, and the name is R. M. Whitesel. Emergency s/ 13 planning is the same as shown here with Rogan.
14 Q NSAD is nuclear safety as s e s s' men t 15 department, right?
16 A. Yes.
17 Q- Who do you report to today? .
18 A office of the president-GPU Nbclear, 19 which has Mr. Clark as executive vice pres'ident and' 20 .Mr. Arnold as president.
21 Q What is Mr. Herbein's current job, if 22' you know?
23 1A . M r. Herbein-is now vice president of
'[ ,i.. 24 operations ~for-Pennsylvania Electric. I N /- )
25 12- necis not a part of GPU. Nuclear anymore?
4 J
I 1- Long 67
-O ss ,/ . I 2 A That's right. I 3 Q Do you hold any additional 4 responsibilities currently that we haven't talked 5 about other than as the director of nuclear
- ((
6 assurance?
7 A Yes. I have one special assignment as
-8 the group leader of the failure analysis task force 9 for the TMI-1 steam generator problem.
10 Q Have you held any other such special 11 assignments since the Three Mile Island accident?
12 A Yes.
- ["}/
%- 13 Q What other assignments can you recall?
14 A One was a member-of the Keaten t.ask 15 force, and then I had a variety of special e
16 . assignments in the period just following the 17 accident, the initiation of.the accident.,
18 Q Rel'ating to review or investigation 19 into the-accident?
20 A- Yes. Some of them were.
21 Q Are you a member of any industry 22 o rg aniz ation s ? -
23 ' A' I_am not sure.what you mean by industry I'Ni 24' _ organizations.
LJ L 25- Q Maybe,' organizations that'are N . - - .- . .-
1 . Long 68
/"N '
1 !
~!' engineering organizations or nuclear-related industry 2
3 groups.
4 MR. GLASSMAN: Professional society?
5 MR. BENEDICT: Yes.
((
6 A .Yes. The American Nuclear Society.
7 Q Other than that?
8 A Atomic Industrial Forum.
9 Q Are you a member of any of the committees 10 for the Atomic Industrial Forum? t
. 11 A No.
12 Q Have you ever served'as a committee 13 member for the AIF?
14 A No.
15 Q ,
What if any publications or recorded 16 speeches or presentations have you made with respect 17_ to the accident at Three Mile Island on M. arch 28, 18 1979?
19 A I made a number of talks to g r'oup s at
'20' .many different locations following the accident.
21~ Q. Are you aware of whether any of those 22 were recorded or did you prepare a synopsis or 23 summaries or written memoranda with respect to the L[)
O 24 contents of those presentations?
- 25 A~ Most of them-Ildid not. ..I speak from-i t .J b , . m-
a - .a . .r- a + . ~ . - - -- --. .----..~ . - . - - . -
anma- .~. . - ~ ..
\
J t' i 1
Long 69
~s p-notes and slides., There is one paper that is
~
2 i 3 published in the journal called Nuclear Technology 4 which I gave as a presentation to several different i
groups.
l ( 5 6 Q Do you preserve or have you preserved '
' 7 any of the notes or slides that you used in any of
- 8 these presentations with respect to the accident?
9 A Yes, not organized according to an 1
10 individual talk. I 11 Q Have your counsel approached you with 4
12 recpect to the Three Mile Island accident'and asked 4 '\
l
^- . 13 you to either review or make available files.that
[ 14 you have control' of produc ti,on in this I
- 15' . litigation?
- i. -
16 A. Yes.
17 Q Have you done so?- .
- s. t 3
18 A Yes.
l 19. Q .Did!you produce or make available-to F
20 ' your attorneys these notes-and slides with. respect-i-
l 21 oto your presentations?
22 A ~I don't;know.
' ~
. 23 MR.' BENEDICT:. We have reviewed the
- -m -
) : files that h' ave-.been given to,us as' having .Jas
' ~
l- - 24, their source'Dr.-Long,:and I, haven't seen any_
- 25
---..,_,_~. . s . - . . - . - . . . - _ _ , - - . . . ,-...,-r-.-.-...,-- -.. .-, ~ , .--
l.
L l Long 70 1
v I would appreciate it 2 such notes or slides.
3 if you would look over those things and we 4
will leave that as an open item so that later
(
5 in the week or sometime hereafter-- l MR. GLASSMAN: We can certianly look for 6
them. Obviously I can't sit here and 7
8 identify what they are nor whether they are responsive in time or substance. We don't 9
10 know exactly what they are, but welli be 11 pleased to look for them.
12 BY MR. BENEDICT:
13 Q Since the Three Mile Island accident, 14 have you provided any lectures or presentations or 15 prepared any written material that you know is 16 going to be used by licensed people at GPU?
17 MR. GLASSMAN: Are you talking,about 18 used in any sense or used in a training 19 program?
MR. BENEDICT: Provided.to them, yes,-
20 21-for information purposes.
{ .I assume anything by Dr.
22 MR. GLASSMAN:
23 Long would be hopefully read by someone.
. ,I 1 ' No , I mean that he knew-MR. BEMEDICT:
(/ '24 25 there was some connection between whatihe said
_ _ . . _ _ - - _ - _ - _ . _ _ _ _ - . _ - . _ _ - . - - . _ . - . . - . _ - _ - - - _ ^ _ -
l 1 Long 71 0 2 and information that was going to be 3 communicated to the operators. I don't think 4 the question is that hard to understand.
A In terms of information provided to the
( 5 6 operators, no.
7 BY MR. BENEDICT:
8 Q When did you first hear about the 9 occurrence at Unit 2 of Three Mile Island, the 10 occurrence that happened on March 28, 19797 11 A Probably around nine o' clock in the 12 morning on March 28.
13 Q What did you hear at that time?
14 A Very sketchy information that the plant 15 had been shut down and that there was some problem.
16 Q. What was the source of this information?
17 MR. GLASSMAN: You mean who tpid it to 18 Dr. Long?
19 MR. BENEDICT: Yes, the immediate sourec.
20 A I don't remember who it was.
21 Q It was someone within GPU?
L 22 A Yes, it was somebody within the GPU 23 companies.
( 24 Q You hadn't heard it on a news report or 25 read it in the paper or something like that?
1 1
i 1 - Long 72
- ] -
J 2 A Not that I recall.
3 Q You say the only thing you can remember 4 hearing'about it was sketchy information and that
( 5 the plant was shut down. Do you remember hearing 6 anything about the current condition of the plant in 7 this first time that you were preserted with 8 information about it?
,9 A No.
10 Q What was the next bit of information 11 that you learned about the Three Mile Island 12 accident?
O 13 A Sometime during the day I learned that 14 there was some radiation releases. '
15 Q Did you participate or were you in any 4
4 16 meetings.or' conversations that you can recall 17 related to the Three Mile Island accident,during 18 'that first. day, March 287 19 A No.
20 Q Were you given any job' responsibility 21 during;the first day?
22 A 'No.
23 Q Did you discuss with anyone,who.was a
/s supervisor of yours'that you can recall,.the (v) 24 25 incident or work that was -being - done or going to be
1 Long 73
- y y t
Q)1 .
2 done with respect to it? ,
3 A No.
4 Q Approximately when did you leave the office on Wednesday, the 28th of March?
( 5 6 A- I wasn't in the office.
7 Q Where were you on~the 28th?
8 A I was at Oyster Creek on the 28th of 9 March. I left Oyster Creek at the end of the work 10 day. , (
11 Q Did you make any effort to communicate 12 with people in Parsippany with respect to the 2 13 accident on the 28th?
14 A No.
15 Q Did you continue with whatever business e
16 which had you at Oyster Creek that day after you 17 - heard about it? ,
18 A Yes.
19 Q Did you conduct or carry on no'r' mal I-20 business that day? .
21 A Yes.
i ~ -
L 22 Q When did you return to Parsippany?
r 23 when did you return to your office in Parsippany?
r r'y
[ ( 24 A To my office, about 7:30 the next
- N_x!
25 morning.-
r .___s . . _ _ _ _ _ _ . _ . _ _ . _ _ _ _ . . _ _ _ _ _ . _. . _ _ _ _ _ _ _
1 Long 74
~
(:) 2 Q Is that your normal time to arrive?
3 A Yes.
4 Q As of your arrival at 7:30 on the 5 morning of the 29th, what if any information did
{
6 you have about the accident other than what we have 7 already talked about? There has been a radiation 8 release and that the plant had been shut down?
9 A I am sure it was on the news by then.
10 I don't remember what the news said. e 11 Q You didn't speak with anyone following 12 your return home that evening on the 28th?
13 A No.
14 MR. BENEDICT: I would like to'have 15 marked as B&W Exhibit 671 a collection of 16 h an dw rit ten notes we received as having come 17 from Dr. Long's files with microfilm numbers 18 1312-9789 through 9799. The notes are dated 19 at various times on March 28, 1979, "except 20 for the last page, which is dated May 10, 1979.
21 (Collection of handwritten notes, with 22 microfilm numbers 1312-9789 through 9799, 23 dated March 28, 1979 and May 10, 1979, marked 24 B&W Exhibit 671 for identification, as of 25 this date)
i 1 Long 75
)
?~s
-L-) 2 Q When if ever did you first see what has 1 1
3 been marked as B&W Exhibit 6717 4 MR. GLASSMAN: You are assuming this 5 was an entire exhibit?
{
6 MR. BENEDICT: It was provided to us as 7 a single file. If Dr. Long has to separate 8 pages out, he can.
9 A The dates when I received it is written 10 at the top except- it is not legible. "tReceived 11 noon" --
12 Q If you look at my microfilm copy,.I
~k-b) 13 think it says " Originals (Moore notes received 1800 14 hours, 5/10/79) . " Is that a fair reading of that 15 writing?
16 A. Yes, it is 5/10/79, 1800 --
I think that 17 is an 8.
18 Q Is that your handwriting, just that
~
19 portion where it says --
20 A Yes.
21 Q Do you~ recognize any of the handwriting 22 on any of the pages as being your own other than 23 that?
() 24 A The last page is my writing. <
25 Q Do.you recall having seen these notes
76
- Long 1
G -
L-). not the last page, but the pages dated ;
2 prior to --
$:; I 3
March 28, 1979, do you recall seeing these pages 4
prior to your receipt as noted here on May 10, 19797 b
A No, I don't recall.
5 E t-6 Q How did these notes come into your 7 possession?
8 A I believe that I requested them as part 9 of the accident assessment activities that I was .
g 10 involved in. .
11 Q Of whom did you request them?
12 A Mr. Moore.
s_
13 Q Is it your understanding that these are 14 Mr. Moore's notes?
A Yes, it is.
15 16 Q - Is it your understanding that these are 17 notes-that were made at approximately the times on 18 the date noted on the pages?
19 A That's right. .
20 Q Who is Mr. Moore?
21- A He is an engineer with the technical 22 functions division of GPU Nuclear.
23 Q What was his position on the 28th of
(~^/ 24 March, if you recall?
x-25 A He was an engineer in the technical
, -_ _, , , ~ , - - . . _ . _ . - - . _ . _ , _
= - -_ ._ _ -
4 i
Long 77 I
s'~s .
\
' '/
2 functions group of the GPU Service Corporation. t 3 Q Is that a group that was under your i
4 charge?
(- 5 A No.
6 Q How did you come to.know that Mr. Moore 7
had notes related to the first day of the accident?
8 A I don't recall.
9 Q I recogni=e that we seem to be pushing 10 the clarity of these fairly far, but I yas 11 wondering if you can look at the first page of B&W ,
12 671 and I will show you the best copy I have, O'l which is directly from the microfilm pr1nter, and 13 14 ask you whether or not you can identify writing 15 in the right margin which appears to say either 16 "could" or "would blow quench tank ruptur disk."
17 Can you recognize that as your own 18 handwriting?
7 19 A No, I don' t believe that is my' 20 handwriting at all.
e 21 Q Do you know whether that notation was 22- on'the notes when you received them from Mr. Moore?
s L 23 A No, I do not.
i .
L (sJ- 24 Q Did you discuss with Mr. Moore his notes l v'
- 25 around the time you received them?
Y f
1- . Long 78
('s
"]'
t 2 A Yes, I believe we had some discussions-s 3 about them.
~4 Q Did he tell you what the source of the
[ information contained in his notes was? Focusing 6 specifically on pages 9791 and'9792, which are the 7 second and third pages of the exhibit, they are 8 headed at the top 3/28/79, 10:05 a.m. There is 9 then a series of people's names, Keaten, Cronberger, 10 Broughton, Capodanno, Lentz, Moore, Lehman. Do 11 you know -- did Mr. Moore tell you that these notes 12 were his notes taken at or of a meeting among those C.>) 13 people at about the time noted?
14 MR.' GLASSMAN: The question is whether 15 Mr. Moore told Dr. Long that?
16 . MR. BENEDICT: Right.
17 A I don't remember. ,
18 Q Did you understand that these notes 19 were taken contemporaneous with the times'noted 20 oon them?
21 A Yes, I'did understand-that.
22 Q Did you know whether on the day of the 23 accident.or do you know whether on the day of the
)
- . . sd 24 accident a meeting of these people occurred in the 25 morning?
___. _ _ _ _ _ ._m _ . _ . _ _ . _ _ _ _ - - - - - - - - - _ - - - _ - _
---U
_ ~ . . . . . - . . . - -
r 1 Long 79 b.~
i 2 A No, I don't know that.
3 Q You were not, as I understand your 4 testimony, in'Parsippany-on that day,-is that
(. 5 correct?
6 A That's correct.
7 Q Do you know whether any ef fort was made 8 to get in touch with you on March 28?
I 9 A None that I am aware of.
10 Q Turning to the three pages(in the 11 exhibit which are marked for this litigation as
. 12 9796 through 9798, did Mr. Moore tell you or did 13 you come to understand by some other means that the
] 14 information contained on these pages was provided to
! 15 . Mr. Moore by Mr. Kunder at or about 6:00 p.m. on 4
16 March 28, 19797 17 MR. GLASSMAN: What do you mean by.
18 provided?
~
l 19 MR. BENEDICT: The source of the ,
i 20 information-to Mr. Moore was Mr. Kunder.
21 MR. GLASSMAN: You are talking about
( 22 the source of all the information on.this or 23 whether . this was Mr. Kunder's words? The
[~).
LJ 24 question is fraught with ambiguities.
25 MR. BENEDICT: It is a discovery question.
" ~
. Long 80 1
b)
. Q,! .
2 I will take a chance with it. .
MR. GLASSMAN: Objection to the form.
3 4 A I don't recall the details of the
( 5 conversation I had with Mr. Moore.
6 BY MR. BENEDICT:
7 Q Did you have any understanding about 8 the time you received and reviewed this material as 9 to what the source of the information was that is 10 contained on pages 9796 through 97987 11 MR. GL AS SM AN : When you talk of 12 understanding, are you talking about'whether O 13 the witness might have guessed or' thought?
14 . MR. BENEDICT: I think the word 15 " understanding" has a clear definition in 16 current parlance and I will take a chance on 17 the question. .
18 MR. GLASSMAN: In this context'I am not 19 so sure it is clear. Therefore, I object to 20 it. But the witness can answer if he 21 understands it.
22 MR. BENEDICT: If you can use it, so 23 can -I.
t'h
-(% j) 24 A. I understood at the time that these were l
25 notes that Jim Moore had made and were in some E_ _
. Long 81 1
. (v respect from Mr. Kunder.
2 3 Q Looking at page 9796, about a third of 4 the way down the page, there is a statement that l 5 reads, " suspect steam bubble in dome forced water 6 up into pressurizer."
7 when if ever did you become aware of 8 such a suspicion that such a thing might have 9 occurred in the course of the Three Mile Island 10 accident? 9 11 A I can't recall when that particular 12 thing might have first como to my mind.
'O 13 Q As of March 28, 1979, what [f anything 14 did you know about an incident which occurred at 15 Three Mile Island Unit 2 on April 23rd, 1978 in 16 which main steam relief valves stuck open and the 17 system experienced an overcooling transient?,
18 A I didn't know anything about that.
19 Q Did you come to learn for the first 20 time after the Three Mile Island accident about 21 such an incident?
22 A That's right.
23 Q Turning to the last page of the exhibit
/\_j 24 which you said were your notes or which were your 25 handwriting, the first portion of the written t ,
Long 82
.1 -
,u.[
C) 2 paragraph reads, "At 5:00 p.m., 28, March '79 -
Moore on site." Does that represent your 3
4 understanding that Jim Moore.was on the Three Mile Island site or at least nearby by at least 5:00
( 5 6 p.m. on the day of the accident?
7 MR. GLASSMAN: My copy is somewhat 8 illegible there, and you might well say what
,9 you say.
10 MR. BENEDICT: Maybe Dr. Long can look 11 at the microfilm copy and tell me whether that 12 is a fair reading of his handwriting.
O 13 A Yes.
14 Q Did you know or had you learned at the 15 time you wrote that that Moore had arrived at Unit 2 16 or at le.a s t at the TMI site by 5:00 p.m. that day?
17 A Yes, he-was there by 5:00 p.m. I don't 18 know when he arrived.
19 MR. GLASSMAN: We are now _refe'rring to 20 a note of Dr. Long's dated 10 May 19797 21 MR. . BENEDICT: Right.
22 Q You indicated - earlie r that you requested 23 Mr. Moore's notes of Mr. Moore because you were
! r's working on some review work following the Three (v) 24 25 Mile Island accident of the accident. What if any i:
1 - Long 83
)
. s _/ -
2 specific' reasons do you recall having for wanting
'3 to-see his notes?
4 A As best I can recall, these are notes 5 that might have been helpful in looking at the
((
6 sequence of events.
7 Q Were you interested at the time you 8 requested these notes in the information flow from 9 the site?
I 10 MR. GLASSMAN: Objection. !][ am not 11 sure what you mean by "information flow from 4
12 the site."
(' 13 The witness can answer if he understands 14 it.
15 A I don't recall whether that was #
16 something that would have prompted my interest or 17 not at that particular time. ,
18 Q The only recollection you have as to i.
- 19 why you n.ight have wanted these notes or w'hy you 20 did want these notes was for information that might 21 .have been useful in preparing a sequence of events C 22 related to occurrences at the plant?
23 A 'Yes, from what I can remember, yes.
iv) 24 Q' At the time you reviewed Mr. Moore's 25 notes, do you recall considering this statement I l
E l
1 Long 84
' ~
2 quoted earlier, " suspect steam bubble in dome forced 3' water up into pressurizer"?
4 A No, I do not.
[
5 (Discussion off the record) 6 MR. BENEDICT: You make a good point 7 off the record. These are illegible, and I 8 suspect there will come a time not in th.e too 9 distant future that we have to go back and 10 ask to see the originals. They age hard to 11 read. It.is a consequence of copying and 12 microfilming and a lot of other things. If
~
3~ 13 we can get the originals --
14 MR. GLASSMAN: I am not sure what your 15 point is or what your intended 16 ch,aracterization of my comment is, but in 17 terms -- .
18 MR.' BENEDICT: 'My recollection'of your 19 comment is that.you said that'this was another
. 20 set of illegible notes. I'am perfectly 21 (willing=to agree with you. I am also 22 perfectly willing to make-it' clear to you s
. 23 , that you have in your possession'the originals
] I 24
of these, and there may come a time when we-
\f 25 may want them. That is all,I am saying.
9 A 4 g, .g.,,- ,. ...n -
, , , . .. ,,...,m,_
85 Long 1
- . g~s
- \v) = If you are saying that, MR. GLASSMAN: _9?}
2 " " -
of saying that you know you are' fully capable .x 3 ..
to me at any time, and we are very f,9f.
4
( 5 cooperative in this litigation, making As far as the particular N" #
6 documents available. '
if you would document, and I would appreciate 7 '
a review of this 8 let me finish the statement, t; there may be a 9
copy will reveal that while t;.
?.r front 10 word or two that are blotched on the 5 11 page, they are capable of being read, and 12 the additional pages of the document appear '
) to be very legible.
I am not sure what your ..
13 ,
14 problem is. _
If that is the case, MR. BENEDICT: r 15 ~
16 then I will hold you to it. b 17 BY MR. BENEDICT:
'Q I would like to show you what has been 18 It marked as B&W Exhibit 672 for identification.
19 20 is a collection of handwritten notes dated at various times on March 29, 1979, which were (j 21 as having come from your files, Dr.
22 .
produced to us 23 Long.
i ) First, can you identify the handwriting
'24 25 on these pages.as being your own?
llu
.- ~ - - -
~
i
+
1 Long' 86 ,
\
2 , (collection of handwritten notes dated 3- at various times on March 29, 1979 marked 4 B&W Exhibit 672 for identification, as of 5 this date) <
J{-
6 A Yes, it is my handwriting.
7- Q Do you see in your review any spaces
-8 that appear not to be your handwriting?
, 9 A No.
t 10 Q You indicated you arrived at the office 11- in Parsippany about 7:30. That is your normal
. 12 . time of arrival on March 29, 1979. What if anything 75 . .,
k- 13 did you learn about the Three Mile Island accident 14 after your arrival on that day?
15 nut. GLASSMAN: You are talking about at-16 the very beginning of the day?
17 Q Yes, what is the very first t.hing you
~
18 remember learning about the Three Mile Is1and 19 accident?
20 A Essentially the first 'hing t I did that 21 . morning was to call Mr. A rnold and'tell him that I
.(. 22 was aware of the TMI-2 problems from the meeting in 23 Oyster Creek and from the news, was there something I
I could do to help.
i
- j. [ )/
s 24 .
25 Q What was Mr. Arnold's response to your
.+. _ _ _ . . , , _ _ , . _ . , _ , , . . - _ . . . , , , _ , , _ . . , _ _ . , , . . . _ _ -._. _ . . _ . .
.~ . . . _ _
l
,- 1 Long 87 wO
~
~#- 2 proffer of assistance?
.3 A His response was, "Yes, I would like you 4
4 to be on one of the groups that we are sending to 5 -
5 Three Mile Island. Go pack your bags and get to 6 my office as soon as you can."
7- Q When did you return to Mr. Arnold's 8 office with your bags packed?
9 A Somewhere around 8:30 or 9:00 o' clock.
10 Q What then transpired?' t 11 A We had a brief meeting and, to the a
12 best of my recollection, we were told there was 13 going to be two groups, one under Ron Williams that 14 'was to look at what needed to be done to recover 15 the plant, and .one under Mr. Richard Wilson which 16 was to determine essentially the sequence of events
) . 17 or what had happened in the incident. ,
18 Q Who was in this meeting in Mr'. Arnold's 19 office?
20 A I guess with certainty the only ones .
21 I can be sure of were Mr. Arnold and myself.
22 Q Were there other people?
i 1
23 .A Yes. '
24 Q- More than five?
l')Y
\_
25 A .I can't remember that specific meeting.
l
1 Long 88
(~h ~
d 2 Q What-if any new information did you 3
learn about what had happened at Three Mile Island 4- since 4:00 a.m. on March 28 in that meeting with 5 Mr. Arnold?
{
6 A I don't recall any specific new 7 information.
8 Q Was any written material provided to you?
9 A I think we were shown drafts of the two 10 brief memos appointing the two committe,es.
11- Q Were those typewritten memos?
12 A I don't remember at the time whether O
\/ 13 they were typed yet or not.
~
14 Q Who were these memos from?
15 A I think they were --
I don't remember.
t 16 Q. What --
17 A The subject of the memos was setting up
~
18 the two committees.
19 Q The Wilson commi ttee and the Williams 20 committee?
21 A Yes.
C 22 Q What next happened after the meeting 23 in Mr. Arnold's office on that day? ,
1 A In my case, I went to the car pool and j
[}
^-
24 25 got a company car and drove to Three Mile Island. i l
l l
. , , ~ , . . , _ . _ . - , _ . _ .
Long 89 1 ,
("%;
'2. Q Did you drive alone?
3 A Yes.
- 4. Q About when did you arrive at Three Mile Island?
( 5 6 A Approximately 1:30 in the afternoon.
4 7 Q If I can turn your attention to B&W 672 8 and specifically to the second and third pages 9 marked for this litigation as pages 9815 and 9816, 10 which are noted in--the upper right margin, page 1 11 of 2 and page 2 of 2, approximately 1415 hours0.0164 days <br />0.393 hours <br />0.00234 weeks <br />5.384075e-4 months <br />, 29 4
12 March 1979, 1 take it 1415 hours0.0164 days <br />0.393 hours <br />0.00234 weeks <br />5.384075e-4 months <br /> is about 2:15 p.m.,
13 is that right?
14 A Exactly 2: 15 p.m.
-15 Q Do you recall Mr. Herbein provided you
.16 with some information about that time and you took 17 these notes? ..
18 A He was not providing this to de 19 directly, but yes, he was providing the information.
J' 20- Q He was giving a briefing?
, 21 A Yes.
22 Q To whom was he giving this briefing-23 other than'to you?.
'D i
Senator. Hart and.other members of-the j., ,) - 24 A. J 25' committee that were'there.
I think there may(have i
J 1 Long 90
- s O 1-
' ' ' ~
- 1. 2 been some press people there, but I am not s u,re .
3 Q Where did this meeting take place?
4 A In the TMI visitors center.
5 Q Were there other people from Parsippany 6 .there that you can remember?
7' A Yes, I think most of the people on 8 these two committees were there at about that same 9 time.
10 Q Were you there'for the beginning of Mr.
11 Herbein's briefing to Senator Hart, et al.?
4 i
12 A I don't think so. I think I arrived a
.f'N -
13 little bit after it started.
14 Q Are these notes that you took during 15 the presentation by Mr. Herbein?
I 16 A, Yes.
! _ 17 Q About how long did Mr. Herbein's 18 briefing last, if you can recall?
19 A From my notes, I indicate that'hhe NRC 20 rep began speaking at 1500 hours0.0174 days <br />0.417 hours <br />0.00248 weeks <br />5.7075e-4 months <br />, so that would
' 21 : indicate!about 45 minutes.
22 Q The NRC representative immediately 23 followed Mr. Herbein?
I~think so.
24 A
, _s..-
25 Q In the middle.of the first of~these two e --
+y -- 4ng~y>.m.- m m- ?
1 Long 91 Ite
'" pages, there is a passage that appears to read "5 2
3 assemblies seem to have temperature approximately 4 500 degrees Fahrenheit." Is that a fair expansion 5 of your abbreviations?
6 A , Yes.
7 Q And then below that, there is a series 8 of ditto marks, but correct me if I am wrong, Other 9 - as s e mb lies seem to have temperature approximately 300 10 degrees Fahrenheit," and then there is a 11 parenthetical next to that which reads "177 12 assemblies."
s . 13 Did you understand the source of this 14 information to be in-core thermocouples?
i 15 A Not at that time.
16 Q. Have you since learned that that was 17 the source of this information?' ,
18 A No, I don't know what the source of
~*
19 . that information is.
, 20 (Discussion off the record between the 21 witness and his counsel)
- -~
22 (Recess taken) 23 BY MR. BENEDICT:
[) 24 Q Turning to:the second page of your-v 25 two-page collection of notes on Mr. Herbein's
, m ~g p- e , . +-
g.-y .,8 -7 y y er y -
q'
1 Long 92
.s
- (
2 Presentation and looking at the top of th,e second p a g e', it appears to read "Electromatic relief valve 3
4 on pressurizer apparently stuck open -
discharge 5 into drain tank."
-(
6 Do you recall whether Mr. Herbein 4
7 mentioned that the rupture disk on the drain tank 8 had burst?
9 A No, I don't recall.
10 Q Do you recall whether Mr. Herbein said 1
11 that there had been a flow from the drain tank into 1
12 the reactor building sump?
N- 13 A No, I don't recall.
14 Q Do you recall Mr. Herbein described in i
15 any manner the pathway of fission products from the 16 reacter. coolant system to the containment or
! 17 environment? ,
^
18 A only what it says.in my notes. I don't 19 recall that.
20 Q In other words, you don't recall -- you 21 don't have a specific recollectionLof him saying
{. 22' this?-
4 A
23 fo-j'~') 24 Q. But you don't have any reason to~
q A_/. R
, 25 believe that he didn't say that?
.y - . -
c -- _- g - . , y * , - . , ,~ ,
\
)
i 93 Long 1
-~g-
- ' L) . Didn't say the thing that is in my 2' A (0
3 notes. b Right, or words to that e-ffect?
t.
4 Q r.:
,( 5 A Yes. IE What is indicated by your notation o'
6 Q 7
"NRC rep" on that second page? <
8 A There was a speaker who was an NRC ,
9 employee. 1, Was he asked by Mr. Herbein, o your 10 Q
- 11 knowledge, to make a presentation?
12 A I don't know.
13 Q Are these notes immediately following or 14 under the statement "NRC rep," are these y5ur notes 15 that you took of his. presentation?
16 A' - Yes, they are.
17 Q Did you stay until the end of his 18 presentation?
f 19 A 'Yes.
Q Was there any other speaker or speakers 20 21 following the NRC representative?
{
22 A I don't recall.
4 23 Q You testified that you arrived at the
) 24 site ~approximately 1:301on March 29 and these notes
. .s '
.Do you 25 .
,are time dated as being-approximately 2:15.
Long 94 1-
\
recall what if anything you did in the interim i
2 f.
3 between your approximate time of arrival'and this .
Y.
4 presentation by Mr. Herbein? }s 5
A very vaguely, I was trying to locate w and 6 other members of the team.and determine where '
7 when we were going to meet.
Do you recall whether prior to your 8 Q .
Herbein and after your departure 9
meeting with Mr.
any 10 from Parsippany that morning, you receive 11 information with respect to the condition of the
- 12 plant or the occurrences of the day before?
sd 13 A I heard some brief news clips on the radio driving over there. I don't remember what they 14 t
15 were.
other than that, you don't recall any W
, 16 Q k
17 inf o rmation? .
18 A No.
19 Q What did you do after the NRC -
20 representative stopped talking?
We made. arrangements to --
I don't 21 A 22 remember whether we got badged or what, but I know so we.could go on site.
23 we picked up dosemeters
) What then did you do once you got on.
\/ 24 .
Q 25 ' site?.
t
_ _ _ _ _ _ _ _ . _ _ . . _ _ _ - _ _ . . _ _ . _ _ . . _ _ . _ _ _ _ _ _ . _ _ _ _ . _ _ . . - _ _ . - _ - _ _ . _ . . _ _ _ . . _ _ _ . _- .m _ _ _ _ _ _ . _ ..m__.___.
1 Long 95
\
je y -
~ 2 A We had what my notes here describe as 3
the initial team meetings.
4 Q There is a three-page set of notes 5 starting at 9817 and going through 9819 which are g
6 noted in the upper right-hand corner on the first to 7 be page 1 of 3 and to be time dated 1540 hours0.0178 days <br />0.428 hours <br />0.00255 weeks <br />5.8597e-4 months <br />, 29 8 March '79. That is 3:40 in the afternoon. I take 9 it you don't recall doing anything prior to 3:40 10 and after the end of the NRC rep's presentation 11 other than doing the necessary work to get onto the 12 site?
(')-
- s. 13 A Thac's right.
14 Q Do these three pages of notes represent 15 notes that you took during what is characterized 16 here as ,the initial team meetings ofthehilson 17 group and Williams group? .
~
18- A Yes.
19 Q what did you understand the charge to be 20 of the Wilson group which according to this f21, document you'are not listed as a-member of?
22 MR. GLASSMAN: I think that has been 23 asked and answered.
L ~ [~) 24. MR. BENEDICT: I willEstrike that L ,1 25- question.
.L
-1 Long 96
- /~h .
V~ 2 Q In the upper right-hand corner,of page 3 9817 there are two columns. One says " Wilson" and 4 the word " Wilson" is underscored. Immediately under j' 5 that are the names Broughton, G. Kunder, J. Moore, 6 D. Reppert, Lee Rogers, and Ed Wallace.
1 7 Was it your understanding that those
-8 were the people who made up the Wilson group?
9 A I don't recall what my understanding 10 was at the time, e 11 Q You don't have any reason to believe that 12 that is not what it represents?
4 %
-s 13 A No.
14 Q Do you recall the constituency of the
- 15 Williams group as being the people who are listed l 16 under the underscored name " Williams"?
17 A Yes. .
18 Q Were you a member of the Wilson group?
19 A' No, I was not a member of the 'W'ilson 20 group.
21 Q, What did you understand the charge of 22 the Wilson group to be?
l 23 MR.' GLASSMAN: I thought that had been I [ 24 asked.and answered.
!- a, j-l- 25. A- I think basically, as my notes;here say, F \
y-y ,- , --.g, , - ww.. - . , _ . ~ . - y - ,, . ,.g r 3 , ,,
1 Long 97 2 gather info, establish facts, describe the sequence 3 of events, and they were not charged with 1
4 identifying blame.
5 Q The quotation you read is " gather info,
(
6 establish facts to describe sequence of events,"
7 and then a new line, "--not charged with identifying 8 ' blame.'"
9 Isn't it correct that subsequent to this 10 meeting you did have responsibility with respect to 11 preparation of sequences of. events pertaining to the 12 Three Mile Island accident?
, s. 13 A Yes, that's right.
, 14 Q Was that responsibility carried out 15 under a charge that was different from.the charge 16 given here to the Wilson group?
17 A Yes. .,
18 Q Under chose direction was your work 19 .with respect to sequences of events done?'
20 A I think during.that effort I was 21 reporting directly to Mr. Arnold.
22 Q: Do.you know whether the Wilson group
. 23 was working in parallel to you at the time you.were
- - .[ );.
s 24 working on sequences of events?
25 - -A No.
O %
1 Long 98 2 Q- Had the Wilson group been disbanded, to 3 your knowledge, at that time?
4 A Not officially.
( 5 Q Was it doing any work with respect to sig'uences of events during the time that you were 6
s t i'
,, s ,, ts 7 workingonsequences-ofevents{
s 8 A No. m
, s ,
s ,
, .: c u 9 Q You testified you were a member of the
?. . s.
10 -Williams group. What was your understanding of the ,
s 4
.. . L.
11 ch'arge of the Williams group?
\
? 12 'A The Williams group -- 'I-guess it is not vs. '
i 13 talked about here in these notes -- it is, 1-B,'
Q 14 1
responsibility of.the Williams group, clean up plant 15 and restarting to normal service.
That was my 16 understanding when we were in Parsippany, and i was 17 still our. understanding that afternoon, that,wo,were 18 to be' concerned with'the, clean-up and restoration of 1 s -
'. 3, -
. 19 the service of the. unit. ,
(
t 20 Q For how long did you pursue gthat charge
,, 4 o l}1 - as.a memN r.of the Williams group? L" b s.
1 22 ' .A .Almost not at all. I think in.this v, s <
xN, 23 ). , particulhr meeting the team members recognized'that
, , ss -
L er% (N - t, N '
(w) .) _. 24. 4the plant was'still not in a satisfactory,' stable
-- t !
-25 configuration.that'we understood and that.we needed v x
~
s
,7
~' ',
W _
1 l
1 Long 99 s
- ~
2 to prob ably use our resources differently than had 3 been originally allocated by Mr. Arnold in 4 Parsippany.
5 Q Was the Williams group as formulated at
((
6 this time effectively disbanded without doing any 7 work soon after March 29?
8 MR, GLASSMAN: Objection as to form.
9 The witness can answer.
10 A Other than the one meeting, ghat evening,of 11 the Williams group later that evening, I don't think 12 it ever met again.
(~%
l
\- 13 Q You indicated that the group understood 14 at that time that the plant was not in a position to 15 be prepared for reinstitution of' normal service.
e 16 What was the basis at the time that you wrote this, 17 3:00 or 4:00 in-the afternoon on the 29th, to say 18 that?_ .What information did you have?
19 A Basically we had high radiatio'n' levels 20 . in many locations'in the plant. The reactor coolant 21_ system was not-_ behaving properly.- I think at that 22 time they may not have had RC: pumps operating. I 23- don't remembe r the idetails , but just those-kinds of n
f F -24 ' things.
L/
25 -Q- Turning'to the second page of your
i 1 . Long 100 t
.(~y
-V. 2 notes which is marked for this litigation as 9818, 3
there is a passage starting a couple of inches from 4 the top of the page which reads, " Wilson reading of Dieckamp letter March 28, 1979, assume -"
( 5 6 MR. GLASSMAN: I am not clear on my copy 7
as to the date there, whether that is March 29.
! 8 MR. BENEDICT: I agree. It is hard to 9 tell. I accept that'as a question.
" Assume - one yeartoutage -
10 Q It says, 11 $30 million core cost may have to be replaced."
12 Is that an accurate reading? Is the s~
l .
13 second word " cost" in that line?
14 A I think so, yes.
15 Q Then another dash, another line, another 16 dash "$20-30 million.may be cost of. cleanup."
17 Do you recall whether at the t,ime of this meeting there was any-disagreement, either'you held 18 19 .any disagreement or anyone else-voiced any' 20 disagreement,.with respect to Mr. Dieckamp's
~
, 21. assumptions?
22 MR. GLASSMAN: Objection, lack of 23~ foundation ~. There'has been no discussion of
/5 whether'these were assumptions of Mr.
l l :24 a_
- 25l Dieckamp-ors estimates or guesses or anything
~. , . p -. w
1 Long 101 fm-
-(j.)
2 else.
MR. BENEDICT: Your objection is' on the 3'
4 ' record.
5 (Record read)
{
6 MR. GLASSMAN: You have to establish 7 first whether they were assumptions and then 8 you have to ask whether the witness recalls 9 any discussion of disagreement.
10 MR. BENEDICT: Is this an objection to
~
11 the form?
12 MR. GLASSMAN: And, otherwise, as stated.
e - (~'t
- 13 MR. BENEDICT: I think you Nnow we 14 preserved objections e,x c ep t as to the form.
15 A I don't know if these'are Mr. Dieckamp's 16 assumptipns, and I don't recall any discussion of 17 them. .
18 Q Do you recall-a reading of a fetter from
^
19 Mr. Dieckamp during.this meeting?
20 A No.
21 Q ' Returning back to the first page of
~
22 these. notes,._there is a heading labeled "B."
It is 23 the page marked for litigation as 9817, which reads, f-
" Primary Importance - Timewise'- operating: staff (3 24 25 interviews - Wilson approach - first talk into tape l'
I i-,
(;
L T- > \
l l
l 1 Long 102 2 recorder - transcribe and review - interactive mode 3 with groups of ' people . "
4 First, is that a fair reading of what is 5 written there?
(
6 A Yes.
7 Q Isn't it true that either during March 8 29 or immediately thereafter you participated in 3
9 interviews of operators at the TMI site?
10 A Yes. That's correct. t 11 Q Were you participating in a program laid 12 out in this meeting?
~
13 A Yes.
14 Q Was it your intention at the time to 15 follow the approach set forth here?
16 A. Basically, yes.
17 Q Isn't it true that you did talk to the 18 operators and report the conversations by tape 19 recorder?
- 20 A Yes.
21 Q And that-subsequently those interviews ,
22 Twere transcribed?
23 A Yes.
24 Q And. reviewed by you?
-25 ~A' -.Yes,-and by others.
5 4 1 , e r a y c- -
a
J 1 Long 103 7 y. -
'( # )
2 , Q Were they reviewed by the person who was 3 being interviewed?
4 A Yes.
5 Was there then an interactive meeting of
{ Q 6- a group of the operators?
7 A Yes. I think there may have been ,
8 several of those.
9 Q Did you participate in those?
10 MR. GLASSMAN: Which ones are we talking 11- about?
12 MR. BENEDICT: Whatever ones he recalls.
gs . a
! ) "
\/ 13 There were several of those, is what he said.
14 MR. GLASSMAN: Are you asking whether 15 Dr. Long participated in all such interviews?
e 16 . MR. BENEDICT: If he recalls-17 participating in any of them. ,
18 MR. GLASSMAN: Objection to the form.
19 A I may have participated in onewhich'took 20 place a fairly long . time after the accident. I did 21 - not participate-in the ones that took place in the 22- immediate postaccident period.
23 Q Did you participate in group discussions
' [ ). 24' as part of your: responsibilities as a member of the
/
.25l Keaten task force?
~ '
_ _ _. , y e, -
l 1 ~Long 104 2 A I think that is the one I recall, yes.
3 Q Turning to the page marked for 4 litigation purposes as 9818, which is the second page 1
- 5. of your notes of these meetings, there is a heading
{
6 numbered 4, followed by the word " Data,"
7 underscored, and it reads, "Wants to set up data 8 base accessible to SC"--which would stand for 9 Service Company?
10 A I believe that is right.
11 Q --
"ME" -- would stand for Metropolitan 12 Edison?
13 A Yes.
14 Q --
"and plant," and then a paragraph, 15 " Data box in control room office has originals --
-16 G.' Miller and Joe Logan" --
and then an insert --
17 "G..Kunder, Wallace, Kunder," Rodrigue z? ,
18 _A No, Rodgers.
19 Q -
"will set up . data managemen't".
1 20 Broughton and" -- M-u-r-i-1-1.
J21 A Murill Shaffer.
L 22 Q ---"to arrange space, badging, clerical 23 : help."
ap) 24 What was in fact done, to your
- m/
. 25 recollection, with respect to the creating of a data L-
1 Long 105
. ,.n:
I I GJ 2 base that was accessible to people working on the 3 accident review?
4 A .Went through several steps. As 5 represented here in these notes, I think it is J{
6 really kind of a first discussion of where data was 7 from the early part of that transient. Someone 8 other than myself had responsibility for kind of 9 collecting what was there in those first few days.
10 In discussions with someone, I can't 11 remember who, I volunteered to bring Jerry Weiser 12 to the site, who worked for me at the time, and he (s
\- 13 and perhaps one or two others who might have come 14 with him started to catalogue things and identify 15 the strip charts, computer printouts, log sheets, 16 those kinds of things, within probably the first.five 17 days, I would guess. .
18 Do you remember what if any system there Q
~
19 was for storing and making accessible data ' prior to 20 the arrival'of Mr. Weiser?.
21 A- No, I don't know whether you could call 22 there being any system in place at.that point.
- 23 g- Was ~ there'any central location where you,
-x . .
24 .during those early-days, could obtain access to g x.{ s) 25 _ data related.to the transient, written data or hard l
a ,
i
l l
~
1 Long 106 7- -
2 data?
3 A on the first couple of days, there was 4 not. I suppose the first major assignment I had was F 5 to set up the data reduction and management group.
6 I don't remember exactly what day that was, whether 7 that was the fifth or sixth day, but somewhere in 8 that time frame, we felt very much and very strongly-9 the need to make sure that all the data was being 10 captured, that it was being identified nd 11 catalogued, and that it could be made available to
~
12 whoever wanted it.
s 13 Q Are you aware of whatever happened to 14 the data that Mr. Weiser organized and that you
~51 accumulated in the data reduction and management 16 group? ,
17 A Yes. Initially, the' group was set up
! 18 in a trailer. I think the first trailer was off s
' 19 -' 'the island near the observation center. I' brought 20 in a consultant to' help us with-just organizing-21 the procedure, someone experienced in records 22 management. We began.to set up a sign-out process, 23 and in fact, we stopped people from taking things-
/"^)
V 24 out the trailer. We~ started microfilming. We did 25" all the things necessary~to try to make sure-that
- 't
- .A5 ""b
Long 107 1
-~s b 2 none of the information got lost. .
3 Q Who was permitted access t'o t h e 4 information contained in that trailer?
A I don't know as we had hard-and-fast
( 5 6 rules at the start, but generally the people who 7 would have been using it were the commission, the
.8 technical staff, and people from the industrial 9 advisory group that had been set up.
10 Q Are you aware of any limitagions imposed 11 on access to information with respect to the NRC7 12 A None at all.
13 Q It was your understanding tNat the NRC 14 had access to any information contained or that was 15 in the possession of the data reduction and 16 management group?
17 A' Yes. .
18 Q Was that a firm policy that so'meone else 19 had established?
20 A Yes.
21 Q Do you know today where the information-22 is that was ac c'umula te d in those early weeks?
23 A No, I don't know the' specific location.
[N, 24 today.
()r 25 Q Is it your understanding that it has 4
_ _ m___________________.____ ______ _ . . _ _ _ _ _ _ _ _ _ _ . _ _ _ . _ _ . _ _ _ _ _ _ _ _ _ _ _ _ _ . _
I l
Long 108 )
1
/'S 5,,/
l 2- been preserved? ,
A Yes.
3 4 Q Was it your understanding or did there come-a time following the Three Mile Island accident
( 5 6 where you understood that GPU was under an obligation 7
to preserve information related to the accident, an 8 obligation imposed by the Nuclear Regulatory 9 Commission?
10 A Yes. I don't remember exactly when that 4 11 happened, but it happened fairly early on.
12 _ Q What was your understanding of your g("% obligations?
13 A We were to preserve our notes'and any 14
, 15 records that we had of the work we were doing.
16 Q . Has there come a time since the Three 17 Mile Island. accident where you understood that that
^
18 obligation no longer applied?
19 A It seems to me, yes, there was some 20 memo that.came eventually that said that that 21- . original memorandum, which is the way it came to us, 22 in a memorandum from Mr. Arnold, no longer applied.
23 Q Do you recall an approximate time frame
, ( ). 24. Hof.that? Was it since.the formation of GPU-Nuclear?
25 - A I don't remember.
' . ya .- -
1 Long 109
/~ ~'N .
t 2 Q Do you recall whether it was before or 3 after the institution of this litigation, which for 4 your information was instituted on March 25, 1980?
5 A No, I don't remember.
(
6 Q Did you at the time or at any time since 7 receiving the second memo you discussed make an 8 effort to clean out your files of old material?
9 A Not that I can remember, cleaning out 10 files associated with TMI-2 things. (
11 Q Have you made an effort, despite the 12 receipt of the second memorandum, to preserve
.(.
13 material related to your work on the Three Mile 14 Island accident?
15 A No, I have not made a special effort.
16 . (Lunch recess taken at 1:10 p.m.)
17
~
18
~'
19 20 21~
- 22
- 23
.( '24 x) -
25 E
I 110 f%
i )
i \/ 2 A' F T E RN O O N- S E S S I O N 3 (2:45 p.m.)
4 , ROBE R T L. L0 NG resumed and
,g 5 testified further as follows:
6 EXAMINATION (continued) 7 BY MR. BENEDICT:
8 Q Returning to what has been marked as i 9 B&W Exhibit 672 for identification and turning to a
10 the page that has been marked for litigation as 9819, 11 there is a numeral 7 at the top, and it reads after 12 that, " Report by Kunder." *
{ \
As/ -13 Do you recall receiving a report from 14 Mr. Kunder on March 29, 1979 after your arrival at 15 Three Mile Island?
16 A. Yes, Mr. Kunder talked to the group 17 during our meeting at Three Mile Island. ,
18 Q So this was part of the meeting that we 19 were talking about earlier, the initial team i -
20 meetings, as you said?
21' A Yes.
22 Q There is an entry immediately below what 23 I just-read,'"still has bubble in RV dome."
24 A This is a "P."
r l[V').
' 25 Q Wha't is the PV7
Long 111 1
L) 2 A Pressure vessel.
Q I thought it might have been reactor 31 4 vessel. Is the reactor vessel and pressure vessel 5 the same thing?
{'
6 A Yes.
7 Q What is the earliest time you can 8 remember hearing that there was a bubble in the 9 pressure vessel or reactor vessel dome? .
10 A I d'on't remember. I can't r.emembe r the 11 details of this particular meeting either.
I 12 Q Can you recall whether you understood
[O)~
13 at the time that Mr. Kunder was giving this 14 presentation what the bubble at the top of the 15 ' pressurizer was composed of?
16 A . I don't even remembe r him saying that .
17 Q At this point you have no independent ,
18 recollection of what he was talking about'when he i .
19 said that?
20 A No.
s 21 Q Going to the first page of the exhibit, 22 there is a single-page. note, headed at the top 23 "2130 hours0.0247 days <br />0.592 hours <br />0.00352 weeks <br />8.10465e-4 months <br />, 29 March 1979." 2130-hours is-9:30, is i.
(Gj- 24 .that correct?
25 A 2130 hours0.0247 days <br />0.592 hours <br />0.00352 weeks <br />8.10465e-4 months <br />, yes.
_ _ _ _ . _ . . ~ _ - _ . - -
_ ._ _ .. . . . .. ...rr -.,,i - - -
i""Ir" i'tI " 4 'Jl lN' W 1 Long 112 0 2 Q The notes are headed " Meeting of 3 williams Committee." It lists as present williams, 4 Lowe, Long, Lauer and Crimmins. Is this the meeting 5 you were referring to earlier when you said therr;
{
6 was one meeting of the Williams committee later in 7 the evening?
8 A Yes.
9 Q Did you ever do any work on any of these 10 assignments following this meeting in the context of 11 a committee composed of some or all of the people 12 listed above?
13 A Not in the context of the committee, no.
14 (Group of handwritten documents, first 15 page dated June 15, 1979, marked B&W Exhibit 16 673 for identification, as of this date) 17 Q I show you a document that has been 18 marked as B&W Exhibit 673 for identification. It 19 has the date at the top right margin of 15 ' June 20 1979, and it appears to be some form of chronology.
21 Is this document composed of your 22 handwriting?
23 A Yes, it is.
( 24 Q Is this document a comparison prepared 25 by you on or about the date noted of the NRC, EPRI, i
1 Long 113
\
f~%
d u,)
2 and GPU chronologies?
3 A It appears to be that over a fairly 4 limited period of time.
5 Q By " limited period of time," you mean the
(
6 period covered by the chronology?
7 A Elapsed time, yes.
8 Q ~ What caused you to prepare this?
, 9 MR. GLASSMAN: You mean was there a 10 particular reason in his mind? t 11- MR. BENEDICT: Was he~ asked to prepare 12 it or did he have a purpose that he intended 3 A s- 13 to put to this document.
14 MR. GLASSMAN: _ Objection to the form.
15 Are you asking whether anyone --
16 . MR. BENEDICT: I will stand on my 17 question. Let's not have a colloquy. Your 18 objection is noted. That all has to be in the 19 . Southern District, as your partner k'e'eps 20 telling me.
.21 MR. GLASSMAN: It is not clear whether 22 .you are asking the procedural question as to 23' how it was prapared or whether someone
( ) 2 24 ' directed Dr. Long to prepare-it.
'x..,/ :
- 25. .(Continued on next page)
k 1 Long 114
.f^) ~
2 BY MR. BENEDICT:
3 Q I will limit my question. My question is 4 not focused on the method by which you prepared this.
5 Rather, the purpose for.which you prepared this.
((
6 A I can't recall.
7 Q Do you recall whether you were asked by 8 anyone to prepare this?
9 A No. I don't recall.
10 Q Can you tell me what the significance
' 11 of the three right-hand columns is, some of which 4
12 contain X's?
O Is 13 A Not based on recollection, but based on
. 14 what I am looking at now, they are indications of
, 15 whether or not those particular times and event 16 descriptions were in any of those three sequences 17 of events. ,
18 Q Do you recall whether you useb for this
! 19 purpose the chronology which appears in nu'ieg.
7 20 06007 l
. 21 A No, I don't recall.
22 Q- Do you recall what the source was of the.
I 23 NRC chronology that you used in this comparison?
f
[A._/h~ 24 A No.
25 - Q Do you. recall what'the source.was of the-A.'*~.
l' Long 115
+
'~'
2 EPRI chronology used?
! A No.
3
, 4 Q What, if you recall, or which GPU chronology or sequence of events did you use? Do
{ 5 6 you recall?
. 7 A I don't know.
8 Q Do you recall whether you used a 9 preliminary sequence of events or annotated sequence 10 of events prepared within GPU? t 11 A I don't know. There were so many 12 sequences of'-events prepared by all three groups that
(<
- s. / 13 I have no way of knowing which one it was or which 14 ones.
15 Q Was this document prepared about June 16 15, 19797 17 A Yes. .
18 Q What,did you mean when you wrbte in the 19 .second and third lines on the first page,'"GPU '
20 should address-'-- particularly availability of info 21 to operator"?
! 22_ A Generally -- specifically, that specific
- . ~ 23 . statement " pressure began increasing in-the reactor
~
, (
A-}; 24 coolant drainLtank".standingiby:itself may.or may
. 25 not have been known to=the operator.
e- ~^- --r - , - - - e ev, * ,e + ,v--- - , . , - y e-' ,%
-+ -
m **-r
1 Long 116 x -
- I*
2 Q So it is your recollection that when you 3 said " availability of info to operator," you were 4 referring to reactor coolant drain' tank parameter 5 information?
J 6 A That particularly, yes.
7 Q If you could look for the moment at the 8 second page of the' document marked for litigation 9 as page 1877, and there is an entry which is under
-10 the " Elapsed Time" column marked as approximately 11 15 minutes, and the entry reads " Reactor coolant 12 pump-related alarms began coming in (verify these t' .
(
( 13 were being -- or not being seen in real time)."
14 Did there come a time after you prepared 15 this document that you verified whether or not that e
, 16 information was being seen in real time?
17 A I don't recall. ,
18 Q Do you today know whether or not 19 information relating to the reactor'coolan't pumps was*
20 being seen by the operators in real time?
21 'A Not without looking at-another final kind 22 of report.
23' Q Turning to the last page of the exhibit
/ 'i M marked 1880, there is an entry.which is' timed
%.l 25 approximately 20 minutes and onward, and the entry
, . . ~ . . , - .
I 1 Long 117
(~
'y)/
2 reads, Both NRC and EPRI particularly give 3 attention to condensate pumps / hot well problems.
4 Is it important, should it be included in GPU
't 5 sequence?"
' ((
6 What if anything did you conclude with 7 respect to the question you have written there?
8 MR. GLASSMAN: What time frame? At or 9 about the time this document was written?
10 MR. BENEDICT: We can stard there.
11 A I don't recall.
S 12 Q Did there ever come a time that you
("T -
\l 13 concluded whether or not attention should be paid
( 14 in GPU sequences of events to condensate pump and 15 hot w' ell problems?
16 A. I don't remember.
17 (Group of documents marked B&W. Exhibit
, 18 674 for identification, as of this date) 19 Q I would like to.show you a d o c u'm e n t .
20 marked as B&W 674, which was provided to us-by your 21 counsel. The source given by your counsel was your i files.
22 23 ' . Exhibit 674 represents an entire' file.as q
24 we-have received f.t . an d the file' jacket.is headed-
%.) .
s- -
25 " Conclusions / Recommendations', Report Draft 7 April ,
q y y 9ma- 7 ,. .,,. m.-
I 1 + Long 118 ;
( )~ .
2 '79."
3 Is that your handwriting on the file 4 jacket label on the first page?
5 A Yes.
'({
6 Q Could you page through what has been 7 marked as B&W Exhibit 674 and tell me whether you 8 recognize any of the other handwriting that appears 9 on the documents as yours?
10 A I see three pages which have notations 11 that I recognize as my writing.
12 Q What pages are those?
/~')
13 A 8704, 8706 and 8707.
14 Q Focusing first on the first two pages J
15 after the cover page, which are marked for litigation 16 as 8701.and 8702, is it correct that the handwriting 17 that appears on 8701, you do not recogniz.e it as 18 your handwriting?
19 A I-do not.
20 Q Again focusing on the second and third 21- ~ pages.of the e xh ibit ', did you have any role in 22 preparing either of theseftwo pages?
23 A. No, I did not.
,e~.,.
';( J- 24 Q When did you receive these two pages?
s.-
25 .A I don't remember.
p 4 m + e ~ omr m e--
s .
1 -
Long 119 fx )-
.i
%)
2 Q Do you recall from whom you received 3 these pages?
4 A Not a specific person, no.
~
5 Q Do you recall whether you received these 6 pages sometime in early-April of'19797 i 7 A Yes.
8 Q Is it your recollection that you did?
9 A Yes.
10 Q Did you receive them about',the date
- 11. noted here, April 77 12 A It was around that date, when I was 13 assigned the responsibility for the sequence of 14 events team. I don't know the exact date.
15 Q Do you know who prepared these two pages, 16 the typewritten portions?
17 A No. .
18 Q The page labeled 8701 has the numeral 19 9 at the top, and it-starts with a subheading or a 20 heading numbered 5. Do you know from what these two
. 21 pages were removed?
22 MR.. GLASSMAN: . Objection. No. foundation.
23 .MR.. BENEDICT: If they are removed'from s
-l ) 24 anything. l a/. i 1
25 A As I remember, these were part of'one of l l
a <
l 1
l I
1 -
Long 120
('"'l 2 the earliest sequence-of-events documents that I saw.
3 Q Who was preparing the sequence-of-events 4 ~ documents during this early time period, as you 5 recall?
(
6 A There was a small team of people, maybe 7 as many as five or six people involved. Tom Van 8 Witbeck, John Flynn, Bill Behrle, and I think Ed 9 O'Connor. I am not sure.
10 Q Was Mr. Van Witbeck in cha8ge of this 11 project?
12 MR. GLASSMAN: What point in time?
13 MR. BENEDICT: This early stage.
14 A Not at the time that I re ceiv'ed this 15 document.
4 16 Q. Did Mr. Van Witbeck report to you on 17 these projects? .
18 A Not at the time I received this. He 19 did when I assumed the responsibility for this 20' project.
- 21. Q Who did you understand was in charge of 22 -the project at the time you received these~two pages?'
23 A I-am not.sure.
24 .Q Do you know to whom Mr. Van Witbeck
]As)) .
i 25 . reported, whether or not that person.was in charge i
c ,
4 , , v--
1 Long 121 g-2 of it?
3 A No, I don't know.
4 Q Mr. Van Witbeck at this time worked for 5 Energy, Incorporated, is that right?
J{
6 A Yes.
- 7. Q Who was John Flynn at that time? Who 8 did he work for? What did he do?
9 A John Flynn was a B&W engineer. He 10 worked on site. I don't know what his unction was.
.11 Q What did Mr. Behrle do at that time?
12 A He is an engineer and he was working for
>g
\__/ 13 MetHEd. I don't know what his particular assignment 14 was.
15 Q Mr. O'Connor was from JCP&L, is that 16 right? ,
17 A Yes.
18 Q Was he working full time on Three Mile 19_ Island accident-related matters at this time?
20 A I don't know.
21 Q Looking at the-second of the two- pages (c 22 we were talking about, marked for litigation as n '8702,:there is a passage after this numeral-(5) 24 - which' reads,.."The. design of the pressurizer J (/~'t .
p.
25 electro-pneumatic relief valve should be 4 ;
lN .
. :na'as.
l' . Long 122
_ (-
! )
"' investigated and replacement with a different type 2
3 valve should be considered. Positive valve position 4 indication,should be installed that is initiated
]{ 5 from valve stem movement."
6 were you aware of this recommendation at 7 or'about the time that you received this document?
8 MR. GLASSMAN: Is the question directed 9 to something other than having read the 10 document? t 11 MR.. BENEDICT: Yes, it is broader than
- 12. that. If the source of his information was
(")
.% / 13 reading the document that is fine. If he is
. 14 aware of it from some other reason,'I am 15 interested in that as well.
~
-16 A. To the best of my recollection, this 17 list of recommendations was the first-I spw those 18 kinds of things, and they were very, very 19 preliminary.
20 -Q Did you know-at the time that you 21 received and reviewed these two pages that prior to
(-- 22 the Three Mile Island accident, there had been -
i 23 consideration within the GPU organization-to' change If~} j!4 the type of indication of-PORV position-that existed 0, ;
25 at the Three Mile-Island Unit 2 site?
_ +;
4
+ y f g.- y- - rae-h-, y
1 1
Long 123
[v\ A No, I didn't.
2 3 Q Have you since the time you received 4 this document become aware of that fact?
MR. GLASSMAN: Which fact?
l( 5 6 MR. BENEDICT: The fact that within GPU 7 prior to the Three Mile Island accident and 8 after the installation of the light which 4
.9 indicated solenoid power on the PORV sometime 10 after March of 1978 that GPU or people withir 11 GPU considered changing that to a different 12 type of indication.
7._
1.
13 MR. GLASSMAN: Objection. Lack of
. 14 foundation.
15 The_ witness can answer.
4 16 A. I don't recall having known that.
- 17. Q Were you aware prior to your receipt of 18 this document that the pilot-operated relief valve 19 at Three Mile Island didn't have a valve stem that 20 .was directly connected to'the valve disk in the 21 valve'itself?
( -
A No, and I.am not sure that that is what-
-22 -
23 this says.
- en
'Did you understand'at:.the time you read l
,-) 24 _Q '
4
- 25. this: that the reference here to valve _ stem movement
Long 124 1
O 2 was referring to the movement of the pilot valve 3 stem? ,
4 A I don't recall what I remembered when I read this.
( 5 6 Q Moving down the page, following numeral 7 (7) there is an entry which reads, " Consideration 8 should be given to more frequent opera' tor tr'aining 9 on reactor plant simulators. Emphasis'sh'ould be e'
10 placed on unusual incidents (e.g. the sqall break .c l 11 LOCA)."
12 Were you aware at the time that you r
^
O 13 received this that prior to the Three Mile Island 14 accident the frequency,of license ( TMI operators' l
- t. ,i ,
15 visits to the B&W simulator'das riddced from once 16 ayeartoonceevery'twoyear[3? /
> I !'
17 A No, I w a s not. /
, s' 18 Q Are you today aware of the f ac't' . th at 19 there was a period prior to the Three Mile" Island 20 accident when Metropolitan Edis%n or GP6 reduce {
$r -
/ s -
21 the frequency of operator visits.t'a the Lynchburg C simulator?
22 23 A Yes, I am.
Is it your ur.derstanding that that
) 24 Q 25 frequency was reduced from once a year to once every J f ,
A- - - - _ -_ - _
l 125
., 1 . Long 1 l
'~T !
2 two years?
' ~
-3 A Yes.
4 Q When do you recall first becoming aware
( 5 of that fact?
6 A I see no way I could name a time.
7 Q You can't pin it down? ,
8 A No.
9 Q- Do you recall whether you became aware 10 of it during the summer that you worked on accident-11 related studies in the summer of 19797 12 A I don't recall.
\- 13 Q Turning now to the pages mkrked as pages 14' 8703 through 8712, which compose the remainder of 15 this' document, Exhibit 674, looking first a 870 3, 16 are'the.words " Appendix A" as written on his page, 17 is that your handwriting? ,
18 A No.
19 Q Do you know whose handwriting'that is 20 -written in?
21: A No.
~k[ Did you have any role in the preparation.
22 Q -
l i
23 of the typed portion of'the pages following .the
-l
.( }- - 24. page saying " Appendix A"? i N_/ R 25 .A -No,LI did not. "Y,1 l
m I
, r . - . , -
-,y . . . _ . _ . . _ .
'M ._
- c ,. ,
l yg T.
[' , r
- w. s s ' <
i%. i i
O \, 126 3 '. - Long.
1 J ,
'~\
O w- ,
?)
x]- 2 1 0 When do you recall first receiving this? :.'
4 .
At the same time as I received the other 3
A' . ts
' 4 pages. g ?
j'
.n E 5- Q 'Did you receive them from the same s sss +w
\6\
person?"
t !-
A s' I don't know.
',, 7 When did you put the handwriting on it i8 Q
- " m y9 , -
that you noted. on tihe three pages as being yours? '
10 A At about the time I received the g li ' documents.
t.
12 Q What if anything-was this an-appendix ;
p '
N
'13 to or ' this to be an appendix to?,
.s N N ~T a: ,
,_,4 -
14 ,
A To the best of my xecollection, as I r s ,; , ' 4
' i- 15 . ) , a l r e a d y m e n t'i o n e y., d , thid>Uas attached to either the-
, , g.
.-i, y - .i s .
'earliestibr one of the n. earliest sequence-of-events 1
16 -
t
~
17 documents I saw.'
, .g .
18 'Q. Do you know who prepared these'pages?
\L s.
N '
s r ' >- .
+ 19 ,; A 'b' No . - .
\'
, \ ;l
~ ;
Q 'The typed portion?
20 .
.r )\ . =;
. gu ,-
21 A No. y f
N
- 22. Q Do'you-know wheth,er r.
the same person or-23.
the same group of, people
- prepared the first<two
} i*
p ,,
[j 24' pagesof'B&W 674 and these last_pages,.the pages h
- following Appendix A?
y .,% s ,
l25 .,
A a y ey e
'h -
..*I-.
[ D p Q'N ,
' .. h , _ $ .
I
- , . 7,, :. ' , ,. , _ , ~ ' " ~ " ' * * ***w . , , . . .
l Long 127 l 1 l l(~)
No, I don't.
2' A
! 3 Q There is a recommendation which follows 4.
the. numeral (7) on page marked 8704, carrying over 5
to 8705, which reads, "Make HPI logic impossible to l( '
6 bypass below 1600 to 1700 psig unless T hot is less than 500 degrees Fahrenheit. You could use 7-8 other appropriate" -- it appears to read " values" 9 with a correction in hand from " valves" -- "of 10 temperature and pressure that would prev,ent you .
11 from bypassing HPI at anywhere near saturation 12 conditions near normally expected values of reactor h\" 13 coolant T hot following a transient."
14 Prior to the time that you read this, 15 were you aware that high-pressure-injection should 16 not be terminated at Unit 2, T M I, when the reactor 17 coolant system is at saturation, at least assuming ,
18 low-pressure injection is not operating?
~
~
19 A No, I was not.
20_ Q Prior-to the Three Mile Island accident 21 on March 28, 1979, bere you aware that high-pressure (d .
22 injection or'was it your understanding that high-23 pressure injection, if automatically actuated,
': em .
(xs ) 24 .should not be terminated at Three Mile Island Unit 2 25 'if saturated conditions' exist within the reactor
1_ .
Long 128
.(\-
'k- '
2 coolant system outside of the pressurizer?
3 A Prior to the accident, I wouldn't have 4 thought about or talked about high pressure injection 5 at Three_ Mile Island.
6 Q Did Indian Point Unit 1 have an 7 emergency core cooling system?
8 A No, it did not.
g g other than its normal makeup and
, 10 letdown system, assuming it had one of those, did it 11 have any system for the emergency provision of 12 cooling water?
N L/
,)~ 13 A I don't think so. I think'th'at is why 14 it is now shut down. .'
15 Q _ was it your understanding that the 16 reactor,at Indian Point 1 was under normal operating 17 conditions to be kept at subcooled conditions within 18 the reactor coolant system and outside of'the 19 pressurizer? -
20 MR. GLASSMAN: What point in time?
21 MR.. BENEDICT: At the time he was working 22 there.
23 A. I don't remember ever even talking about f("y 24 those kinds of topics.
N_.] '
25- Q During_the time you worked for Con Ed g.
' 0
1 Long 129 O 2 and were involved with the Indian Point reactor, did 3 you have any involvement in considering the 4 installation of an emergency core cooling system at g
, 5 Unit 1?
6 A No, I did not.
7 Q Looking at the bottom of the page marked 8 8705 and reading the entry after the numeral (11),
9 " Require each site to have its own simulator and,"
10 underscored, "a six-shift schedule, such that one 11 shift is always in training. Keep the training,"
12 underscored, " shift in training," underscored, "and 13 do not use them on other jobs. Make each individual 14 sign a statement each training period that he has 15 received simulated transients of the following 16 nature.".
17 There is then a list of five simulated
~
18 transient types.
19 Prior to your reading this som'etime in 20 early or mid-April of 1979, what was your 21 understanding as to the number of shifts of operators C 22 at Unit 27 23 A I had no idea. I never talked to anybody 24 about it.
25 Q During the course of your work related
1 Long 130
~
-[)
\~/ 2 to the Three Mile Island accident that summer 3 following the accident, did you become aware of the 4 fact that Unit 2 had a five-shift operator schedule?
( 5 6
A I was aware that at some point in time they had a five-shift schedule, yes.
7 Q Did you understand that the result of 8 'having a five-shift schedule was to reduce the 9 number of training weeks available 'o members of 10 each shift vis-a-vis having a six-shif schedule?
11 A No, I don't think I would characterize 12 that change from six to five the way you have.
W)
(_ 13 Q Is the difference between $aving a 14 five-shift schedule or was the difference'between 15 having a five-shift schedule at Unit 2 prior to the 16 Three Mile Island accident and'the time when it had 17 a six-shift s;chedule, was.the effect of that
. 18 difference to reduce-the amount-of training _ weeks 19 -available to the individual operators in e~ach shift?
20 A I don't:know.
21 Q One of J the sentences in the passage I 22 just read said, " Keep the training shift'in training 23- and do not use them on other jobs."
f[~'[
\ ,
'24' Prior to your. reading this, were you
- 25 aware of any practice or.use of operators-during
I i
1 . Long 131 '
m.,
i 1
\/ their training week for other jobs at Unit 27 l 2
3 MR. GLASSMAN: Are you asking whether the
~
4 witness was aware of your statement prior to 5 reading this document?
(
6 MR. BENEDICT: I will restate the 7 question.
8 Q Prior to the time that you read this, 9 were you aware that there were times at Unit 2 at 10 Three Mile Island where the training. shift was being 11 used for other jobs and not being given training 12 duri'ng their training week?
m u,} 13 A No, I was not, and reading this, I don't 14 - remember that I agreed with any of the things that-
.15 are in this. document when I read them. I don't 16 ' remember. -
17 Q Did there come a time during ,the course 18 of your re'iew v of the Three Mile. Island accident- .
~
19 that' you learned that such indeed had occurred?
20 MR. GLNSSMAN: What had indeed occurred?-
21 .MR. BENEDICT: The training weeks had 22 .been spent doing other things than' training.
23 MR. GLASSMAN: Are you talking about-J'l - '24 any training weeks, any operator?
NJ 25 MR.~ BENEDICT:- hit depends on what Dr.
Long 132 1 .
^b
-U 2 Long remembers. .
MR. GLASSMAN: Objection to the form.
3 4 The witness can answer if he understands 5 the question.
({ .
6 It is a little bit obscure to me.
7 A I guess I can't answer that question. I 8 don't know how to answer that question the way it is 9 phrased.
10 Q Subsequent to the Three Mil Island 11 accident, did it ever come to your attention that 12 operators were not spending their training week or 13 there were instances in which operators'did not 14 spend their training week at Three Mile Is' land 15 prior to the accident in training, but rather spent g 16 them doing other jobs?
17 A Yes. .
18 Q It.came to your attention that' that 19 occurred?
20 A That individuals didn't always get their i
21 training if they were having to serve on a relief 22 shift, for example.
23 Q Did you make any recommendations with
('12
~
24 . respect-to eliminating that situation?-
25 A Me personally?-
'-"-t
Long 133 1
2 Q Yes.
D '
Not myself Not on an individual basis.
3 A
4 alone, no. :
r:
Are you aware of any such recommendations
- l 5 Q I 6' ever being made following the Three Mile Island t
'7 a c r; .'.d e n t , that is to say, recommendations to prevent '.
8 operators'from doing other jobs during their f1- 9 training weeks?
10 A- They may have been in something like t 11 the'Keaten task force report, but I don't remember 12 the details.
O' 13 g You don't remember any such 14 recommendation one way or che other?
15 A No . -
16 Q: - Turning to the next page, there is a l 17 long passage beginning in the middle of the page L
18 which reads, "Many' symptoms of LOCA were present:
19 "1). Rapidly falling reactor coolant L20 -pressure.
"2). Pressurizerclevel increasing more 21
~
. rapidly 3 than normal.
22' 23 "3). Reactor: coolant drain! tank-l
/
24 temperature'and pressure increasing rapidly ~.
'( ,1; "4). : Reactor Building pressure 25 t
l I
l 1 .
Long 134
/^i k-). 2 , increasing after five minutes when the reactor
^
3 coolant drain tank safety valve lifted and much more 4 rapidly at 15 minutes when the rupture disk blew. -
i ,e 5 "5). Reactor Building sump level 6 increasing rapidly and both," underscored, "re a c to r 7 Building sump pumps starting and still not having 8 enough capacity to pump the sumps down.
- _ 9 "6). Auxiliary Building sump overflowing 10 and water coming out,of.the floor drains.
11 "7). Reactor Building temperature 12 increasing.
(' _j - 13 "8). Gradual degradation of reactor 14 coolant pump flow caused by voiding." I 15 Numeral 12 in the left margin, "None 16 of these, symptoms separately or together were 17 assimilated by the operators to be consistent with 18 a LOCA."
1 19 Immediately to the left of the' indented
- 20. subparagraphs,.you have written, "These.probably 21 all true -- but bombshells!"
22 MR. GLASSMAN: You are talking of the 23 indented paragraphs 1 through 87 7'S 24 MR. BENEDICT: Yes.
]
L25 Q In-the course of your work on the 5
1 Long 135 O 2 postaccident investigations that you did following 3 the Three Mile Island accident, did you ever discover 4 that any of the symptoms listed in numerals 1 through 8 were not true or had not occurred on the
( 5 6 day of the accident?
7 A I don't remember, without looking in 8 detail at a final sequence of events.
9 Q Working from your recollection at this 10 time, today, do you have any reason to(believe that 11 in fact all eight of those symptoms did not occur 12 or any of those eight symptoms did not o'ccur on the 13 day of the accident?
14 MR. GLASSMAN: Objection. It has not 15 been established th'at Dr. Long Looked into 16 these issues at all.
17 MR. BENEDICT: I will stand on my 18 question.
19 A Would you repeat the question /
20 (Record read) 21 MR. GLASSMAN: I object both on grounds L 22 of lack of foundation as to whether the witness 23 ever looked into the particular items, and 24
( secondly, as to the ambiguity in form in the 25 meaning of the word " occur" in the sense of
4
.1 Long 136 2- whether something after the fact was found to 3
have occurred or whether it was seen on the day 4 of the accident or by whom or how.
5 The question is very vague and unclear.
}(
'6 MR.. BENEDICT: I will take my chances.
7 A I don't know. The reason for my comment 8 is.that I was concerned that certainly all this 9 information simply wasn't available to the operators.
10 Q Do you know todav which or f any of 11 this information was in fact not available to the 12 operators on the day of the incident?
- s. 13 'A Item No. 3, for example, was not 14 available to them,.I don't believe. -
15 Q By."available," I take it you mean was 16 not seen.by them? Th'ere are in fact real time 17 meters recording reactor coolant drain tank 18 temperature and pressure within the ' contr$1 room, _
19 -isn't that correct?
20 -A I don't=know if'that ~is correct.or not.
~
- 21. QL Areithere~any others_of these eight 22 -things that you know.the operators were_not aware of '
- 23 on'the, day of.the accident?
. D~ /24 A" -
Not.without looking-.at the details of QJ 25' ithe accident.
, d 4_ . .
1 Long 137 0 2 Q Still on page 9706, is the writing on 3 the top third of the page where there is a change 4 .in the text, the typed text, is that your handwriting 5 as well?
{
6 A I am not sure whether that is mine or 1
7 not.
8 Q The pascage I read marked in the margin 9 is in your handwriting, is that correct?
i 10 A Yes. g 11 Q Looking again at what has been marked as 12 B&W 674, what if anything do you recall doing with 13 this material after you received it otNer than 14 reviewing it and making the marginal notes that we 15 have discussed and the others that are on the 16 document.?
17 A I put it in the file folder and I am 18 not sure that I ever looked at it again. "
19 Q Excluding for the moment any r'eviews of 20 this material you may have had with counsel, when 21 was the last time you can recall seeing any of the L 22 pages that are included or even the file jacket 23 that are part of B&W 674?
24 A P rob ab ly in the summer when we got the 25 request for documents associated with the accident.
1' . Long 138
(
k/ 2 I kind of took a quick look at my-files.
3 Q Would that have been the summer of 1980?
4 Can you recall?
5 A I think so.
g 6 Q' Was there any material other than the 7 pages we have talked about included in the file 8 j acket with the heading, a copy of which is shown as 9 the first page of Exhibit 6747 10 A I don't recall. (
11 Q You don't recall taking any pages out 12 before providing them to your counsel?
bj.
(m,- 13 A I am sure I did'not do that.
14 Q And you can't tell by reviewing it 15- whether or not this constitutes the entire file as 16 you. produced it?
- 17. A No, I can't. .,
18 -(sequence of - events. report, TkI-2, 19 3/28/79 incident, marked B&W Exhibit' 675 for 20 identification, as o f ;.this 'date')
-21 -Q. I show you a document marked as B&W 22 Exhibit 675 for identification. It appears to be a
. 23 : sequence ' of ievents related to'the accident at Three
[ 24 Mile Island on~ March 28, 1979. There 'is a
- 25 handwritten' entry on the last pageLof the exhibit
. Long 139 1
' j"')c
\-
i 2 which states, "This was sent to NRC approximately 8:00 p.m. Tuesday, April 3rd, 1979."
3 4' "
4 When did you first see this document, if ever?
l (_ 5 6 A I remember seeing it, but I have no idea l
7- when was the first time.
8 Q Do you recall whether it was about the I 9 date that is on the document, early. April, soon after 10 the accident?
11 A- Yes,-it would have been not 12 necessarily -- I would be surprised if it was as
- '[
l ' '- - 13 early as the 3rd, but a few' days or a week later.
1 14 Q The textual ~ material at the top of the f
15- first page of B&W Exhibit 675 reads, "The following 1
-16 sequence.of-events for the TMI-2 incident of 4
17 3/28/79 has been formulated by B&W-engineers using ,
~
18 available plant data."
19 Do~you_know who this_is referring to 20 when it says "B&W engineers"?
21_ A 'No, I'do not.
- k. '
'22-
.Q Were you. aware in the early weeks i
i' .MJ immediately following the Three Mile Island accident
~
ev -that B&W people were preparing some sequences of-
, , ( ) :-
- .24' 125- events with respect toLthe incident? ,
II r
l Li
' ~
l
1 Long 140 0 2 A I was aware there were some B&W people 3 on the team working at TMI. I don't know whether 4 there were other B&W people who were doing something.
5 Q Do you know whether the B&W engineers
(
6 referred to here as the people who prepared Exhibit.
7 675 were the same engineers from B&W that you had 8 working on the team creating sequences of events?
9 A No, I don't know.
10 Q Do you know who the Larry is who is 11 referred to on the last page as the signator of the 12 note?
13 MR. GLASSMAN: You don't want a guess?
14 MR. BENEDICT: No. '
15 A No, I do not.
16 Q Do you recognize any of the handwriting 17 on this document --and let me show you my., microfilm 18 copies of the middle two pages --
as being 19 handwriting of yours?
20 A No, I don't believe that is my 21 handwriting.
L 22 Q Are you aware of any sequences of events I .23 prepared within or by or for GPU that precede ,
24 April 4th, 1979?
25 A I don't know when the first one would
141
. Long 1
.('
b have been prepared. It was right around that time, 2 G"r I don't but whether it -was before or after April 4, 3 f'N know, 4
time when you were given 5 Q Did there come a f4 to assisting 6
certain responsibilities with respect .
7 in the preparation of a sequence of events relating j.:
8 to the accident on March 287 \
A Yes.
9 k 0
When did you get that responsibility ( or .
10 ,
-11
' those responsibilites?
Mr.
'< 12 A I'can't remember the exact date.
f-N
( assessment' 13 Arnold established an accident documentation team. He made me head of that team.
14 You probably have 15 - There is a memo that is dated.
It had, as I remember, 16 something that tells you.
13 tasks, one of which was ' a" sequence of events. ,
17 18 Q If I told you that your counsel- had 19 told us that the document or the' accident assessment f6rmed on April 15, would 20 documentation team was 21 that. comport with your general recollection?
/
MR. GLASSMAN: Objection as to form.
(:
22' A ..T h a t is ' about , the right date, but I. don't 23
,O
't i/
24 know whether that is the exact'date or not.
to the Q 'Did you do any work.with. respect 25
"- - ^
./
l Long 142 1-LO creation of a sequence of events prior to receipt ,
2 b of the formal memorandum from Mr. Arnold that you 3 $
4 mentioned setting forth the tasks for the accident b' assessment documentation team?
( 5 i 6 A Nothing other than help provide :
7 information from the data reduction and management 8 trailer. I think I was aware of the group because
, 9 they came to us for information.
10 Q How many tasks did you say My. Arnold's 11 memorandum set forth?
12 'A I think there were 13 tasks.
, .[sM) 13 Q Were you responsible for assuring the 14 completion of each of those tasks?
A Yes. Basically, many of them had 15 16 individua1s assigned, and I was just to see that 17 they put-the stuff together. .
18 Q You were the supervisor?
__19 A Yes.
20 Q Did you have any hands-on responsibility 21 as to any of the-13 tasks?
22 A- I think in-every case I had somebody 23 s ubo rdinate to me who had the' lead responsibility
. ,~c for the task.-
d )' , 24' Q With whom did you work or'who was on 25
- d. j
Long 143 1
2- your team or task force?
3 A I can't remember-all the names or even 4 all the tasks. At that point certainly Tom Van Witbeck was head of the sequence of events team.
( 5 6 Q Do you recall who Mr. Van Witbeck had 7 working with him on the sequence of events team, 8 as you call it?
9 A Not on that date, because that team 10 kept changing. t 11 Q Who-all, not limiting it to any.given 12 .. time, but focusing on the subgroup of the accident
,.O 13 assessment documentation team headed by Mr. Van 14 Witbeck, that.had the. responsibility for preparing 15 the sequences of events, who do you recall working e
16 -with ~ him on those matters?
17 A I think I gave you some names.; earlier.
18 Bill Behrle, Ed O'Connor, John Flynn, and there-was 19 another John'from B&W. I:can't remember his last 20 name.
- 21. Q Do you know someone named Putnam from 22 Energy, Inc., J._Putnam?
- 23 A JohnJPutnam I think was B&W, You do remembe r Mr. Putnam and he was
' s('%
/ ' 24 Q u./
involved with Mr. Van-Witbeck in drafting?
~
- 25' I
Long 144 1
n
~
~# A Yes, I think that is the name.
2 There were others from EIF. There were 3
4 others from Met Ed. I don't remember names.
Q I take it Mr. van Witbeck's group was
-( 5 6 not composed solely of Energy, Incorporated people?
7 A Not at all.
8 Q Other than the possibility that Mr.
9 Putnam was also from Energy, Incorporated, do you 10 know of any other people who worked on the accident 11 assessment documentation team and worked on the i 12 sequence of events who was from Energy, Incorporated?
D t t
\ 13 - MR. GLASSMAN: Objection. There appears to be some confusion here as to Mr. Putnam's j
14 15 employment. If I recall, the witness thought 16 that he might have been with,B&W. bounsel 17 seems to think he was with Energy, .
18- Incorporated. We may be proceeding'on 19 assumptions.
20 Q .Other than Mr. Putnam, who may or may 21 not have worked with Energy, Incorporated, are you h . 22 aware of any other people other than Mr. Van.Witbeck 23 from Energy, Incorporated who worked on the1 sequence 1,6i 24 of events?.
- \_f 25 A. Yes, but I don't recall names.
l
-l
=
e , ,
- ~ _
1 Long 145 I
h2~ ,2 Q Was-the accident assessment documentation 3 team budgeted? Did it have a separate budget that 4 you were responsible for administering?
,5 A No. There wasn't any budget as such.
(
6 Q Again, I am just asking for a ball park 7 figure. What percentage of time did you spend on 8 work with respect to the accident assessment 9 documentation team during the three months 10 immediately following the accident, the. summer, 11 b,asic ally ?
12 A I don't think I can give you an estimate
_ (_,)
13 in terms of the percentage of time. M job changed, 14 and I wasn't associated with it for a while, and -
15 then I came back to it.
16 Q. How long did your association with the 17 team continue uninterrupted from its initiation or.
~
f18 establishment sometime in April of 19797 19 A ~ About two weeks.
20 ;Q~ What did.you do following the two weeks?
21 A The last'two weeks-I was at the island 22 during.that. crisis period which was the first two.
23 weeks of May. 'I was group leader of the planning
(~Y L \._,1 24 and contingency. task force or some such title.
. 25 I; don't rememberlthe exact title.
s--*- -.
-ny ,.,
9 -
l
~1 Long 146 frN k ' 2 Q What was the function of this task force?
3 A It w'as a group that had been in 4 existence for about a month under Mr. Crimmins. He 5 had to return to Jersey central. Mr. Arnold asked
((
6 me to take that task on, and they were really in 7 a windup phase of a lot of contingency studies that 8_ _ had been done during the crisis period.
9 Q Is it a fair characterization for me to 10 say that by " contingency" you mean to consider 11 possible things that could happen to TMI-2 at that 12 time and how to deal with them if they were to lose 7-)
\/ 13 the reactor coolant pump ,. f or example , or if they 14 were to lose pressurizer level indication?
15 A Yes.
16 Q. And you worked on that for about how 17 long? ,
~
.18 A About two weeks.
19 Q Did you work on it until the p'lant was 20 taken into natural circulation?
21 A It_was taken to natural circulction h 22- around April, I think, so I. got into_it just about 23 the-time that was happening.
[)
'J
=,
24 Q During the two weeks that you spent on 25 _this task force,'did.you do any work or any 1
l l
Long 147 1 !
n v
2 significant amount of work that related to viewing .
3 how the accident had occurred or the early sequence f
of events, say the first day of the accident?
4 N-Not during that period. I was focused ,
5 A p 6
more on the immediate problems that were being faced.
7 Q Following your two-week stint at that, ;
8 did you then return to work on the accident 9 9 assessment documentation team? '
10 . A I don't think I.ever did offi,cially. I 11 went back to Parsippany and kind of worked on 12 .whatever assignment Mr. Arnold gave to me.
gg ,
'% sI 13 Q Was part of that work, though, 14 administering the accident assessment documentation 15 team work?
A -
Yes. There was some responsibklity for 16 17 at least some of the tasks. .
18 Q' Did there come a time when your 19 responsibilities with respect to the accident assessment documentation team work ~ dropped off 20 21-sharply or was it a gradua'l reduction in the amount
.22 of time you spent on it?
.23 A It was a gradual reduction and ended
_ ,e~
c 24
' fairly abruptly when'we create'd the relikbility
(_/
25 engineuring position, and then I assumed a whole new
Long 148 1
/ .
\ >)
2 role. .
-3 Q When you took over your new job in August ,
4 of 1979, you terminated effectively your oversight .
( 5 of the accident assessment documentation team work?
6 A Basically, yes.
7 (Multip age document entitled " sequence 8 of Events, Draft," marked B&W Exhibit 676 for 9
identification, as of this date) 10 Q I show you a document that hps been marked B&W 676 for identification. It bears the 11 12 typewritten heading " Sequence of Events" and in the O 13 upper right margin is written in hand " Draft 14 approximately 0700 13' April '79." .
15 First, is it your handwriting that wrote e
16 the time and the date?
A Yes. t 17 ,
18 Q Do you recognize any of the other 19 handwriting that appears throughout B&W 6767 20 A There are very few limited comments n
- 21 which I recognize as my handwriting,~ mixed in.with 22 an awful lot of other people's handwriting.
23 Q Focusing first on the handwriting that' N
-!. r~j 24 appears on the first page, marked for litigation as 25' 2416,.is any~.of.that your. handwriting other than 1 l
$ - c - - +
. . . , _. . ~ . . c .
~ '
Long 149
, 1:
2- the-upper _right corner?
i
- 3 A- I don't think so.
T '
'4 Q. Turning to the last page of the exhibit, i marked for litigation as 2433, are the other entries
~
l 5
?
. 6: -
enumerated.1 and 2 in your handwriting?
7 A Yes, the two entries that are the'last 8 on the page..
~
o '
29 _ Q Is'there any other writing or marking on
, ^
' 10 ' ..this page_that is yours? (
11 J A< I don't know whether-the circle and F . .. > 12 : question mark are~mine orinot.
Il[2?
f :131 Q- ~The remainder --
4 f:
I 14 A None of the others is mine.
7 i .15 Q -- ; you identify not.-as being yours?
+-
e 16 - A.. That's.right.
i 17 Q Did you receive the typewritten portion ,
?
l 18- of this' document on or about April 13 at about 7:00.
~19. fin ~the morning?
20 MR.-GLASSMAN:' You . are _~ re ferring ;tol .a L l'
._ 21
. typewritten, document without;the hand markings oncthem?
~
4
- 22_
7 , 23. MR. . BEN EDICT,: Yes, I;am removing,-forLth'e.
moment consideration of:the. handwriting..
);.p). - ; ' 24 l K 25 A. I don't know. ,,
4
~
).
9'
. ;a >
I m y ,
A I
l Long 150 l 1
13 D 2 Q Do you remember whether the first time .
3 you saw this document it had the handwriting on it i' 4 'other than, of course, your own?
I A No, I don't remember.
h 5 !!
6 Q You don't remember one way or the other?
4 7 A Right.
8 Q Do you remember that you received this 9
document sometime around 7:00 in the morning on the 10 13th of April 19797 t 11 A No.
12 Q Do you remember ever having seen this 13 document before?
14 A In terms'of actually remembering 15 receiving it, no.
16 Q . Who prepared the typewritten ortion of 17 this? ~Who drafted the typewritten portion of this ,
18- document?
19 A I don't know.
20 Q Is this an early draft of a sequence of events being prepared under the aegis of the
(; 21 22 accident assessment-documentation team?
l :23 A. Yes.
,n, l (, , 24 -Q. Does your answer'with respect to who l 25 prepared it.or --
1
l l
Long 151 f l'
p v
2 A If you mean specifically who, I don't 5 3 know. I 4 Q Who was assigned the responsibility at r 5 that time for preparing drafts of sequences of ,
E' 6 events-for the accident assessment documentation 7 team?
- f. .
8 A' On the 13th of April, I am not sure. <
9 Q Do you recall that during April Mr. I 10 Van Witbeck.was responsible for doing that?
4 11 A At some point I. recall clearly assigning
- 12 him the responsibility for the lead, but I don't s
- %_)
13 know when that date was. .
14 Q Do you recall during the latter weeks 15 of April 1979' reviewing drafts of sequences of 16 events? -
'17 A Yes, many of them. ,
a 18 Q Do you recall that the sequenc$s'of.
19 events.you reviewed took a form like the on'e' in 20 front of you?
MR. GLASSMAN: Objection. I don't know 21 22 what you mean[by "a form:like."- They'were. ,
23- typed. 1They had notes.
- D 24" =MR. BENEDICT: I recognize.the question
(._)
problems, but'I will stick byiit.
~
i 25 .
-has some
- r
~ ' ' * ' ' " " * * , _ _ _ , . _ . __
/
' 152 I ' Long 0 2 MR. GLASSMAN: I don't see --
3 MR. BENEDICT: I will withdraw it and I 4 will make it a' negative.
BY MR. BENEDICT:
( 5 6 Q Do you recognize that this document is 7
not in the format of the sequences of events drafts 8 that you reviewed during that time period?
MR. GLASSMAN: That is the same question.
9 10 MR. BENEDICT: No, I disagre .
11 MR. GLASSMAN: Either question is going 12 to be totally undecipherable. Perhaps I can 0 13 help you out. Maybe you want to ask the 14 witness whether he saw any documents that had 15 time periods requentially listed or something 16 that you can tell us you are looking for.
17 MR. BENEDICT: I will stand by the 18 question. It is not going to be the'last 19 question I will ask on the sequences : - Let's 20 put it this way.
21 A I guess I don't know what you mean by 22 "the form." Did I see them typed with handwritten 23 marks on them?
Do you recognize this document as being
( 24 Q 25 different in form, for whatever reason different in I
l,
. - - =. . -__-.
- Long 153 1
e~s form from the documents that you recall reviewing 2 #
3 that were sequences of events? }
4 A Yes. 9
( 5 Q This is different in form? ,
f 6 A Yes.
7 Q What differences do you recognize or 8 can you recall?
9 A There were some sequences which had at 10 least three different columns, and perhaps four. .
Q Were these sequences arranged 11
(~g 12 horizontally on the paper so that you had to turn U the paper so that its long side was horizontal in 13 14 order to read the typing?
15 A They may have been.
16 Q -
I amlimitingmyquestionnowbo the 17 early period in April. Does that-continuejto be
~.
18 your testimony? .
19 A In the early period in April -- by 20 "early," you mean --
Q. I mean early in.the preparation of 21 22 eequences of events, not early in the calendar month.
23 A' Somewhere the form changed from that in k- J 24 B&W 676 to a different. format.
s 25 Q Do you have any reason to believe-today i 7
_ .i
y
, \,s .\ I[
' ~
%, g 3.
(
_, q f
~y
'1 Long L 154 i
d
. s
, s
.z' y ,. 2 that what has been marked as B&W 676 is not a copy,
.o
, '3 So'vever marked up in hand, do you have any reason
.O s 4 to_believe that it is not a copy of an early draft s ,
A ., 5 g of the sequence of events that was being prepared
6- under the aegis of the accident assessment Y , .,
, J 7 documentation team? E s s
\
8 ' -
MR. GLASSMAN: Objection as'to form.
5 9 A The date you told mesabout the. accident
+
10- assessment documentation. *team is the 15th o.f April.
g s t 11 , If that date is accurate, then this was not done i,
-s y ,
12 under the aegis of the accident assessment p -
\j 13 documentation team. N T , 14 .
Q That is one'of the reasons why I asked i
s, %
, '15 you whether or not'you rqcalled whether'any work
% s
\
M, '
i ,
o 16 had been done prior to the date of the memorandum j
y s.
17- tli'at you re ceived from Mr. Arnold. ,
18 m Do you now recall whether or i$ot you did-
, y
~
19 'any-work with respect to preparation of-seq'uences,
- A'- o s, ,? ',,
N.20 , of events, whether or not.it was under the' specific x 3 ,=
~
~L, -
i 21 .
titile of the accident assessment documentation team, 1 22 duYing this. period?' ^ ^
- 4 .
3 A .'No,.I' don't recall..
x = 23
[ .i 7
f')
.v,-
y ;. w, .
24 T Looking.at page 2422 for purposes of
'25 this. litigation and focusing on---a seAtence that has
- <-+-
,. s 3
' Is -
U
,, . m - s,
~ * . as- . .-. ,_ _ , , ,
1 Long 155 rm
('/ I 2 been struck out'which appears after the entry of 24 3 minutes and 58 seconds, the lined-out' sentence 4 reads, "This temperature monitored by a 5 thermocouple strapped to the pipe never gets above
{
6 290 degrees Fahrenheit due to heat losses."
7 MR. GLASSMAN: There is some earlier 8 material that is also crossed out.
9 MR. BENEDICT: That's right. I have no 10 reason to put it in the record, tIf you want, 11 you can.
12 Q I want to ask you whether at the time
(~'s
(_) 13 that this draft is dated, around the middle of 14 April, did you have'any information with respect to-15 the maximum expected temperature reading you would 16 get on the thermocouple connected to the PORV
- 17 discharge line on Unit.27 ,
18 A I don't remember having any sbeh i
19 information.
l 20 -Q Has there come a time.since the Three 21: Mile Island accident up.until today when you have i.
{ 22 learned or obtained information with respect to the-i
.23 maximum-expected' temperature _that the thermocouple
! /~'t 24 would indicate on the' discharge line for the PORV?
G) 25 A I.am sure'the question has been looked
f 1 . Long 156
.. q 2 at, but I don't remember the results.
3 Q Again looking at the entry on page 2424, 4 after two hours, part of the passage following that 5 entry that has been crossed over is a sentence which
-{
6 reads, "At this point, T hot A appears to be 7 superheated; therefore, superheated steam exists in 8 high point of the A loop from this point on in the 9 transient for at least the next hour."
10 At the time that this draft. is dated, 11 were you aware of the fact that the Three Mile 12 Island Unit 2 reactor coolant system had contained
. k_w) 13 superheated steam at some time during the accident 14 on March 28, 19797 -
15 A Yes, at the time this draft was prepared, a
16 I was aware that --
no, excuse me. I am not aware 17 that there was superheated steam. Certainly I was 18 aware that there was steam in.the primary' system.
19 Q You don't recall.having any kn'owledge 20 specifically related to the steam being_superheated 21 as opposed to-being saturated during.this time?
.22 A No.
23 Q . Prior to the accident at Three Mile I'\1 24 IIsland,.did you understand that superheat could-be
( )
25 -:added.to steam only:by expcsing 100 percent quality i
1 . Long 157 i l-:
2 steam to a heat source?
3 A No, I don't think prior to the accident 4 I understood that. I am not sure that is a correct 5 statement.
J{
6 Q Prior to the Three Mile Island accident, 7 did you understand that if~a heat source was 8 totally submerged in saturated liquid water, that 9 superheated steam could not be created in any 10 significant quantities? t
- 11. A I don't think I ever thought about that 12 question.
1 13 Q Did you understand that prior to the 14 Three Mile Island accident, that the secondary side 15 of Unit 2 operated with a superheat component in the 16 steam created for purposes of turning the turbine?
17 A Yes, I knew that the B&W once,-through
~18 steam generators produced superheated ste$m.
19 Q Did you'know'that U-tube steam' 20 generators of the type used by Combustion Engineering 21 and WestinghouseLdid not produce superheated_ steam?
- (' 22 A .Yes.
23 Q Did'you understand that theLU-tubes in 24 the steam generator of the: Westinghouse and CE
- 25 ; (designs were, totally: immer~ sed in secondary side y.
- +
___1w _w - _.-- -u - ---_--x-----,--__---a- . - - - - - - - . - - - - -- a
1 Long 158 2 water?
l 3 A- I don't know whether that is correct or 4 -not.
5 Q My question is really, did you understand 6 prior to the Three Mile Island accident? Do you 7 have any recollection of knowing that fact prior 8 to the Three tiile Island accident.
9 A First off, I don't know that that is a 10 fact. t 11 Q You don't recall knowing that fact, true 12 or false, prior to the Three Mile Island accident?
km 13 A No.
14 Q Were you aware prior to the Three Mile 15 Island accident that the once-through steam
'16 generato.r tubes in the B&W steam generator were only J
17 partially covered with liquid secondary side water?
~
18 A Yes.
19 Q Did you understand that steam produced 20' from the boiling secondary side water in the B&W 1 '
21 steam generator pas' sed by. heated steam generator 41 22- tubes on its way.out of the secondary side of the PJ ' steam generator vessel?
24 A' What point in' time?
['f '
x 25 Q Prior to the Three Mile Island accident.
A ," _
+--g w e
1 Long 159 f
- A Yes-2 3 Q Did you understand that it was by that i
4 method of passing steam across the heated steam j generator tubes that the superheat component was
{- 5 6 added to the secondary side steam at Unit 27 Did you 7 have this understanding prior to the Three Mile 8 Island accident?
9 A When you specify Unit 2, you give me ,
10 problems answering the question. If Itdidn't think 11 about Unit 2 --
12 Q If I expand the question to your
/~
k_%) 13 knowledge of B&W once-through steam generator design 14 prior to'the Three Mile Island accident, would that 15 change your answer?
16 A. My very limited knowledge of B&W a-17 once-through steam generator design, yes,,I 18 understood.that the superheat occurred in the tube
~
19 portion of the generator.
20 Q Above the surface of the saturated
'21 secondary side water?
C 22 A I don't think that is an accurate 23 statement. I won't agree to that.
L f' ( 24 Q !Is it your understanding that superheated
- J-25 steam can be created _when a heat source -- assuming
~
a
- c -
.1 -
Long 160 s
)
2 the pressure remains constant, that superheated steam 3 can be created where the heat source is immersed 4 completely in saturated water?
(- 5 MR. GLASSMAN: Now you seem to be 6 shifting your question to present understanding 7 where before the question seemed to be 8 directed to preaccident.
9' MR. BENEDICT: I am interested.now in 10 what Dr. Long knows today. I wil,1 go back to 11 try to put it in time. I may be asking the 12 question wrong, and if that is true, I would y- .
i,..)n - 13 like to know, because I don't think we're 14 communicating.
15 (Record read)
?
16 A. Since I do very little thinking, if any, 17 about superheated steam, I can't really answer.
18 Q You don't know whether that s atement 19 is wrong or right?
20 A I don't know whether that statement is 21 wrong or right.
22' Q Did you understand prior to the Three
' 23
. Mile Island' accident that it'was.an abnormal
[)
.\_)
24 occurrence for there to be steam generated within
~
25 the' reactor coolant. system of Unit 2.outside of the I
l
M 1 -
Long 161 2 pressurizer? ;
l 3 A Prior to the accident, again, I just 4 didn't have ~ any contact with Unit 2.
4 A pressurized water reactor?
4
( 5 Q 6 A A pressurized water reactor, I would 7 think it would be unusual to have steam outside the 8 pressurizer, yes.
9 Q Did you understand prior to the Three 10- Mile Island accident that steam could exist outside u.
11 of the pressurizer in a pressurized water reactor
. 12 coolant system as a result of an accident
(~% .
13 situation? .
14 A Yes.
15 Q Did you recognize prior to the Three Mile 16 Island accident that the Unit 2 reactor was a 17 pressurized water reactor? ,
'18 A' Yes.
~
19 Q If I-understand your testimony,-at the 20 time in April of 1979,-you don't recall knowing that 21' .superheated steam-conditions existed within'the RCS
! (i 22 'at-Unit'2 during the accident?
23 A: I-am not able to recall that at the r
t ,
wg .
- 24. present time.
V; L 25; (Q .You'do recall'at that time.that steam
-- y -u--g e p--~e g
1 . Long 162
.[~N t $
N/ . existed within the reactor coolant system outside the
., 2 3 pressurizer?
4 A Yes.
5 (Recess taken) 6 (Documents marked as B&W Exhibits 677 7 through 681 for identification, as of this 8 date)
- 9 BY MR. . BENEDICT
10 Q I would'like to show y'ou atseries of 11 documents which I will describe for the record and 12 which have been marked as B&W Exhibits 677 through a
L/ 13 681.
14 Turning first to B&W 677, it is headed 15 in typewritten words " Preliminary Sequence of Events ,"
16 and then in what appears to be'your handwriting in 17 the upper right corner, " Draft, Midday, 1,3 April
~
i 18 '79."
19 Is it correct'that the handwritten 20 notation in the upper right is yours?
21 A _Yes.
l j
i22 .Q I turn your attention for the moment to I.
L 23' B&W'678, which again.is' headed in typewriting, N' 24 ' " Preliminary Sequence of Events," and has the
! . .l' ~ .'
25' . notation-in.the upper right margin of " Draft 2215-
1 -
Long 163 (m 4 2 hours," which is 10:15 p.m., is that correct?
3 A Yes.
4 'Q Or 13 April 1979. Is that notation in 5 your hand?
J{
6 A Yes.
7 Q I ask you to look at B&W 679, again 8 headed " Preliminary Sequence of Events." It has a 9 handwritten notation in the upper right corner which
~ 10 has been crossed over, which appears t6 read "0930-11 hours, 13 April '79." There is then something 12 written after it which I can't read. Can you make
(
- (. 13 - out what that says, something three letters or copy?
14 A Your copy may be better than'mine.
15 Q I am afraid not in this case.
16 . Do you read that it says " April 14" 17 on it? .
~18 A It says "ELB copy April 14." There are 19 some other things which I can't read.
20 .Q Does'ELB mean anything to you in this 21 . context?
22' A Yes. Those are the initials of Ernie-23 Blake.
't' #~D - 24- Q Are you aware of whether Mr. Blake had-
' QJ 25 any responsibility.with respect to preparation of
'p,-
1 . Long 164 0'. 2 sequences of events around about April 14, 19797 3 .A No, he did not have responsibility for 4 Preparation of sequence of events, g 5 Q Did he have any responsibility with 6 respect to review or consultation on such sequences?
7 A Yes, he reviewed them.
8 Q Is the inscription, both the one that 9 has been crossed out and the portion of the lower 10 one that we can read, do you recognizetthat as being 11 in your hand?
12 A The words "ELB copy" do not look like 13 my handwriting. The " April 14" does. The "0930 14 hours, 13 April '79" are my handwriting. .
15 Q Now looking at B&W 680, which in headed 16 " Prelim % nary Sequence of Events," and written in 17 the upper right margin is what appears to, read
- 18 "Last Draft --4/15/79," is that a fair reading of 19 what you see?
20 A I think so, but it is not entirely clear.
21 Q Is it'sufficiently clear for you to
.22 identify whether it is or is not your. handwriting?
.23 A Yes, it is'my handwriting.
24 0 . Finally, I would like you to look at 25 what.has been marked for identification as B&W ~681,
_ __-__-__.-m__ - - - - - - -
1 -
Long 165 2 the first page of which is a letter on letterhead of l 1
1 3 the GPU Service Corporation from R. L. Long to R. C.
4 Arnold, and it is headed " Preliminary Sequence of 5 Events, TMI 2 Accident.of March 28, 1979." The
..((
6 letter is dated April 16, 1979. And the second page l 7 of B&W Exhibit 681 is headed " Preliminary Sequence I 8 of Events, TMI 2 Accident of March 28, 1979, Issued 9 April 16, 1979."
10 First focusing on the document marked 11 as B&W 681, do you recognize 681 as a preliminary 12 sequence of events that was prepared under your
/~N ,
- 13 supervision at the request of Mr. Arnold sometime 14 prior to April 16, 19797 '
15 A Yes.
16 Q. Is this the sequence of events which you I
17 had been asked by Mr. Arnold to prepare as part of 18 your job as the director of the accident assessment 19 task force?
20 MR. GLASSMAN: Objection as to form.
21 obviously Mr. Arnold didn't ask him to produce 22 a particular document in its final form. If
-23 you are'asking the witness if this was produced
)( 24 .in response to Mr. Arnold's request , that would v
25 make some. sense.
o_ -
i l
1- Long 166 jq 2 MR. BENEDICT: I think the question, the 3 import of the question is the same, ,
- 4. You can answer your counsel's question.
5 A I did prepare it at the request of Mr.
6 Arnold.
7 Q Do you remember whether it was part of 8 'the accident assessment task force responsibility to
. g see to it that this document was prepared? Is that 10 part of your job as the director of that team?
'11 A Yes, but, Counsel, you have introduced 12 some confusion in my mind as to when the task force
.(
(_/- 13 was formed.
14 Q No, I didn't. I only asked you -- I
! 15 am only telling you what your counsel has confused 16 me with, and that is a date of April 15.
17 101. GLASSMAN: I don't know which counsel 18 you are referring to.
~
19 MR. BENEDICT: In answer to an "
20 interrogatory posed in this litigation. It 21 was'certifi'd e by an officer of GPU k;
22 Corporation as being accurate to the best of 23 his knowledge.
<['}
l~.)
24 _MR. GLASSMAN: We can mark it as an
~25. exhibit. I would - .like to know what counsel l
l
- - j
1: Long 167
.g Ns 2' is referring to.
3 MR. BENEDICT: There is your answer. )
4 Q Do you recognize the documents that have 5 been marked as B&W Exhibits 676 through 680 as 6 prior drafts of what has been marked as B&W 6817 7 A I didn't look at each one to see if that
-8 is all they are.
9 Yes, they are all drafts of the sequence 10 of events, the preliminary sequence o f s. eve nts .
11 Q Which has been marked as B&W 681, is 12 that correct?
. N_
f~/\, , 13 A Yes.
14 Q Is.it your. understanding that the drafts 15 that have been marked as B&W 676 through 680 are 16 marked in-chronological order from earliest to 17 latest? ,
18 MR. GLASSMAN: You are referrkng to 19 chronological order of drafting, as' opposed 20 to chronological order of receipt by-Dr.=Long?'
21 . M R. . BENEDICT: If Dr. Long can testify
^
22 'as to their. timing of the preparation, I will 23 ~ take that. If he has to limit himself as to e 24 the order-in which he~ received them, I,will k)\ ' "
25 accept that.
3 . , , ,
1 Long 168 i' '!' A The notations indicate the order in which
. 2
-3 I received them, although I am not sure about B&W 4 679.
5 Q You have no reason at this point to
((
6 .believe that these are not marked in the order of 7 their preparation?
8 A I don't think you can tell from the 9 notations when B&W 679 was received by me or who
$10 marked on-it. t 11 Q I don't disagree with your statement, 12 but I press for an answer to my question, which is,
(')/
(- 13 and it is a focused one, do you have any reason 14 . today to believe that the order in which I marked 15 them does not represent a chronologeal progression 16 from earlier to later? I am not asking you to i
17 review each page of the documents. I want to know.
18 whether you today have any knowledge whic$ would 19 suggest that I made,a mistake in my order.
20 A No.
21 Q Are you-aware today of any other drafts
-(I 22 of B&W 681 other than the ones that have been
- 23 marked as B&W'676 through 680?
/D
/ i 24 A I am not aware of any.
2%/ '
25 'Q Turning to 677, could you look through T M 7 # - w y y 4 y -p % < 9
1 Long 169
(,, ,) -
2 677 and tell me whether there is any of your 3 handwriting on this document other thin the notation l 4 in the uppdr right corner of the first page?
l 5 A A very few of the notations appear to be
((
6 my handwriting.
7 Q Could you direct me to those that you 8 believe are your writing?
9 A Page 2402, the entry at 0400:37. The re 10 is a handwritten word " automatic." t 11 Page 2403, there are a couple of notes 12 associated with the entry at 0401:16.
) '
N./ 13 Page 2404, an entry at 0402:03. l 14 Page 2405, some notations associated'with 15 the entry at 0408:06.
16 Q. All of those entries in that area?
17 A I don't know about the circle.,with the.
'18 line through it, and there are some strik$ overs, 19 and I don' t know whether they are mine.
20 Q All the writing is yours?
21 A The writing,-yes.
L 22 Q Anyplace.else?
23 A Page 2408, the entry at 0645:37, " Makeup ff'}
's_/ .
24 pump C was stopped." -The parens that;are out to 25 the right of.that entry that says " Inference could
- g e
___ m__ _mm-- - _ - _ _ _ _ _ _ _ - - _ . - - _ . _
l l
- 1. Long 170 2 be deleted," close parens. Only that part. Those ,
3 are all that I can recognize with certainty.
- 4 Q Did you look over B&W 677 and make those entries.at about the time and date noted on the
'{ 5 6 front in your handwriting?
7 A I don't recall at this point in time.
8 Q Do you have any reason to believe that
'9 th00e notations were made at some --
at any time 10 after the preparation of what has been(marked as 11 B&W'681?
12- A No.
-O
. (_/ 13 Q Is it your recollection th t you 14 reviewed B&W 677 prior to the completion of B&W 6817 15 A I certainly can't say that with any 16 certainty.
17 Q Do you have any reason to believe that- '
18 you didn't review B&W 677. prior to the completion
-19 of'6817 20 A Since I can't recall, I don't --
- 21. .Q .There is a difference, and I am sure.
'22 -your counsel can explain this to you better than I, 23- but there is,a difference:between having a i
[ '%)
If'N g 24 recollection of something1 and the question of whether 25 'or'not you haveLany. reason to believe that something 1
=
y g- -
- Na yr7 t-W '
m'i'M9M t'N -7 '
'T
$ WW - "--
l 1 Long 171
{~}-'
~
2 is or ir not true, and that is, do you possess 3 other information other than a recollection of this 4 document that tells you that in fact you didn't do 5 what I am suggesting? That is the difference
(
~6 between the first question and the second question.
7- MR. GLASSMAN: Frankly, I think your 8 rewording of it is probably helpful and avoids 9 'any negative inferences that might otherwise 10 be drawn from the record. t 11 MR. BENEDICT: I am only interested in 12 whether he has any reason to believe that he 13 did not read it and review it prior to the 14 preparation of 681.
15 A I don't possess any information at this 16 point in time that tells me that I did it other 17 than at that time. ,
18 Q' Do you have any information ab to who 19 else's handwriting this is on B&W 677?
20 A No, I do not.
'21 : Q Turning to B&W 678, why don't you page j
~
22 .through and tell us if you come to any handwriting 23 that'.is yours other than the entry in the upper.
1
[)-
24 right margin of the first page.
25 A Page 2387, the two circles.in'the left
. ~ ,* ,
1 Long 172
. ,r~x 5
2 margin of page 2387 3 On page 2388, the entry at 0400:45, the 4 word " pressurizer."
5 Page 2390, the entry at 0402:38, the
{
6 words " reactor coolant." I don't know whether the 7 "B" associated with that is mine or not.
8 Page 2391, an entry at 0405:43, the
+
- 9. insert of the word " inches."
10 0405:52, the changing of the tense of 11 the' word " trip" to " tripped."
12 Page 2393, the entry at 0542:37, the
-~.
m ) 13 word " operator," and the entry at 0554:37 underneath that notation, the word " '
14 approximate."
15 Page 2394, all of the word entries on 16 that page, handwritten' word entries, are mine. I 17 don't know about the kind of editorial remarks.
18 Page 2395, again all of the hbndwritten
~
19 word entries. I can't be sure of the edito' rial 20 remarks.
21 Page 2396, all of the handwritten word h.' ~
22 entries.
23 Page 2397, all of the handwritten word J f~~]; L 24 entries. I can't.tell about a singleLletter.
. X_./ -
25 Page 2398, the two word entries, the
~
s q -
w ~ e m w my
~. .. --. - -
1 Long 173
, 2 word."were" 'and the word " decreased."
3 Page 2399, all of the handwritten word 4' entries and the handwritten time entires at 1524:37.
5 Q Do you qualify "O.K" as a word in the 6 right margin?
7 A~ That is my notation.
8' Page 2399, the word "were."
9 You have to help me, what you want to I
10 call the next page number. t 11 Q The last page of the exhibit.
12 A The-last page of the exhibit, I wrote in
-s .
. 13 the word," temperature," a-typed sentence, and then l 14 there is an asterisk footnote that is in my-writing.
15 MR. GLASSMAN: Just a moment.
l 16 (Discussion off the record between the 17 witness and his counsel) ,
18 (Time noted: 5:00 p.m.)
19 20 ROBERT L. LONG i 21
- S ub's c rib e d and sworn to-( 1 before me this day of;
-23 1982.
e-f 24 t-o) l- 25 1
t 5 , . , . - .- ~ , ,. . .-,-ry-
1 .
374 1"' .
k b b $ 1 b 1 b b. $ k 3 STATE OF NEW YORK )
- ss.:
4 COUNTY OF NEW YORK )
m, 5
'.~
6 JOSEPH R. DANYo I, , a 7
Notary Public within and for the State of New York, 8
do hereby certify that the foregoing deposition 9 of ROBERT L. LONG was taken before 10 TUESDAY, MAY 18, 1982 j me on I 11.
That the said witness was duly sworn 12 his before the commencement of testimony and that the'within transcript is a true. record 'of said 4
13
- 14 '
testimony; 15 '
That I am not connected by blood or 16 marriage with any of the parties herein nor 17 interested directly or indirectly in th5 matter in 18 controversy, nor.am I in the employ of ny of the 19 counsel.
20 IN WITNESS WHEREOF, I'have hereunto set 21 my hand this b[ day'of' Ay /9/d 22 s f
\./ S H R. DANY[
-25 e
D
, ,, y y -.- w. - - , . , - - r y -,-.c
175
- I
, I N D EX ;
WITNESS PAGE Robert L. Long 3 4-y;,
9 7
- 1 16 ~9' EX H. I B I T S' 4 B&W FOR IDENTIFICATION t
668 Resume of Robert L. Long 4 669 Document headed "GPU Service Corporation, Generation Division, Division 30," dated" April 1,
(-
1979 32 670 -Organization chart for part of -
GPU Nuclear, dated November 10, 1980 62 e
67.1 Collection-of handwritten notes, with microfilm numbers 1312-9789 through 9799, dated March 28,_ ,
1979 and May 10, 1979 , 74 672
- - Collection of handwritten notep dated at vario~us times on March 29, 1979 86 673 Group of handwritten' documents, first p' age dated June 15, 1979 112
.s
, .5 -
674 Group of documents 117 t
, < %i -
$a 'd ,_h, I - "
( r - ', ,, 5'
, j%' :. 4 I - f
. a. mag;*;.u
e-J
% . - ' .. .. . . =;n . . . t W aQu-vrM u G,C;;i n k dai M;n z u "us%LWC:;LLM&buw,:4
, .a 7.u ,
, ,. t i t ' '
~ .- ,
u%w' :x ::?:<%:.n Gu :du;%y'T_
a ;
aOc-n&!,'ani#1df5AMA'a h
t,
- 176 4
1 i
,\ -
)
INDEX OF EXHIBITS -
i (continued)
.o i
4 B&W
~
.. FOR IDENTIFICATION PAGE 675 ' Sequence of events report, TMI-2, 3/28/79 incident 138 a ;Wp , -i , . -
iQv-
'ocument' entitled 676 'Multipage d =
" Sequence of Events, Draft" 148 '
677 Documents 162 ,
through 4
681 u' .
4 I -oOo-e
, ,se 4
O-M l
i O*
+
j
- i t
- I
} l
- . i s
t e
e 9
i
- 9 3 4 t-k f
_ 4 1
. c. .
e '
- q i.,
,~. , . . . , , . - , . ,s; - s r ^4
. 43 h e,o
~
,__,.,#~ _._1 +>'} ,,.
- _g~n
~h L" / [4 ' .A 'C.
.,,,# y ay q y W N ,
W $$.$
- - $N 5
s $r u.
- -l-,; $$iS4 N!' -
- - 151 _ $*_ _ . - ...-..-.Y" t $ IA E t'