ML20072H802
| ML20072H802 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 03/26/1982 |
| From: | Zechman R GENERAL PUBLIC UTILITIES CORP. |
| To: | |
| References | |
| TASK-*, TASK-01, TASK-02, TASK-04, TASK-1, TASK-10, TASK-2, TASK-4, TASK-GB NUDOCS 8306290749 | |
| Download: ML20072H802 (86) | |
Text
.
642 UNITED STATES DISTRICT COURT f^.
SOUTHERN DISTRICT OF NEW YORK V
_ _ _x GENERAL PUBLIC UTILITIES CORPORATION,
. ~1 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 Continued deposition of RICHARD W.
ZECHMAN, taken by De fendants, pursuant to adjournment, at the offices of Davis, Polk
(
& Wardwell, Esgs., One Chase Manhattan Plaza, New York, New York, on Friday, March 26, 1982, at 9:45 a.m.,
before Catherine Cook,a Shorthand Reporter and Notary Public of the State of New York.
C d_
/
B306290749 gg DOYLE REPORTING. INC.
PDR ADOCK 0 PDR CERTIFIED STENOTYPE REPORTERS 369 LExlNGTCN AVENUE WALTER SHAPIRO, C.S.R.
NEW Yon x, N.Y.
10o17 CHARLES SHAPIRO, C.S.R.
TELEPMoNE 212 - 867 0220
g 643 2
Appe arance s :
3 4
KAYE, SCHOL ER FIERMAN, HAYS & HANDLER, ESQS.,
5 Attorneys for Plaintiffs, G
425 Park Avenue, 6
BY:
ANDREW MacDONALD, ESQ.,
of Counsel 8
9 10 DAVIS POLK & WARDWELL, ESQS.,
Attorneys for Defendants, 11 One Chase Manhattan Plaza, New York, New York 12 BY:
ROBERT B.
FISKE, ESQ.
and 13 Os KAREN E.
WAGNER, ESQ.,
14 of counsel 15 16 ALSO PRESENT:
17 18 SUSAN HANSON 19 20 o0o 21 0
22 23 24 25
644 1
/ a.
(
)
2 RI CHARD W
Z ECH M A N h'aving A'
3 been previously duly sworn, resumed and testified 4
further as follows:
5 EXAMINATION (Continued) ggg 6
BY MR. FISKE:
7 Q
Mr. Zechman, you realize that you continue 8
under oath?
9 A
I do.
10 Q
Near the end of your testimony yesterday, 11 you mentioned something that you referred to as a 12 pressure / temperature envelope.
(~'S 13 A
Yes, sir, I did.
V 14 Q
Could you tell us what the pressure /
15 temperature envelope is?
16 A
A pressure / temperature envelope is an 17 operating envelope which defines the boundaries of 18 operations of the reactor during operations.
l 19 Q
You say " defines the boundaries"?
l 20 A
Pressure / temperature boundaries.
21 Q
Was your understanding of that envelope O
22 that there is a fixed pressure and a fixed temperature 23 or is it a floating, movable pressure / temperature 24 relationship?
,r m 5
)
\\d 25 A
It 's a movable temperature relationship.
1 Zochman 645
('))
2 You have to stay within the boundaries of those s-3 different points of operations.
4 Q
What did you understand would happen if 5
you did not stay within the boundaries?
gg 6
A To the.best of my recollection, that 7
pressure / temperature envelope was always based on a 8
DNBR ratic.
You maintain a DNBR ratio no greater than 9
1.3.
10 Q
What is DNBR ratio?
11 A
Heat flux which would cause departure from 12 nuclear boiling divided by the actual heat flux.
('N 13 Q
What is a departure from nuclear boiling?
14 A
Departure from nuclear boiling is a heat 15 transfer transition from nuclear boiling into what 16 could eventually lead to film boiling.
17 Q
So is it correct that if one function of 18 the pressure / temperature envelope was to prevent either 19 temperature increasing or pressure decreasing to the 20 point where boiling would occur?
21 A
As I said, the DNBR ratio was again in O
22 relationship to a surface phenomenon.
It was always 23 related to the heat transfer characteristics or modes 54 of heat transfer from fuel assemblies.
25 Q
This is the type of surface boiling that
1 ZochEnn 646 2
you described yesterday that could cause fuel damage?
A Yes, sir, I did.
3 4
Q So is it fair to say that one purpose of 5
staying within the pressure / temperature envelope was g
6 to prevent fuel damage?
7 A
Yes, I think that's fair.
Yes, sir.
8 Q
Also the phrase has been used in this 9
deposition " bulk boiling."
10 A
Yes, sir.
r 11 Q
And what is bulk boiling?
12 A
Bulk boiling, as I understand it 13 Q
I am asking your understanding before the 14 accident.
15 A
Before the accident?
16 Q
Yes.
17 A
To the best of my recollection, I don't 18 recall the use of the term prior to the accident.
19 I do recall the term after the accident.
There was a 20 lot of discussion about RCS bulk boiling.
21 Q
what is bulk boiling as you understood 22 the meaning of that term after the accident?
23 A
Well, as I understand it after the 24 accident, it was referred to a saturated RCS system 25 which you had bulk boiling in the RCS system.
1 Zochman 647
(
2 Q
What is bulk boiling?
3 A
I don't recall how the term was exactly 4
defined after the accident.
ggg 5
Q As you have used it in the deposition, 6
what did you mean by bulk boiling?
7 A
As I believe I understand it post-accident 8
in that terminology, it referred to -- my terminology 9
or understanding was bulk boiling referred to a 10 saturated RCS system, where you had a lot of boiling 11 occurring -- rapid boiling occurring in the RCS system.
12 Q
Just going back to basics for a moment, (U~}
13 Mr. Zechman.
You have described earlier in the 14 deposition the temperatures of the water in the primary 15 system as you understood them before the accident.
16 A
Yes.
17 Q
What were those temperatures again?
18 A
Full power operation?
19 Q
Yes.
20 A
About 600 degrees TH, about 550, about 575 21 in there, average.
22 Q
What atmospheric at what temperature 23 does water boil at atmospheric pressure?
24 A
212 degrees, i
l 25 Q
What was your understanding of what kept 1
i l
1 Zochnan 648
(
2 the water in the primary system that was either at 3
550 degrees or higher from boiling?
4 A
What was it that kept that from boiling?
5 Q
Yes.
g 6
A I understand we have a pressurized water 1
7 reactor.
That the reactor.was at very high pressures 8
to prevent thats 9
Q At what pressure was this water in the 10 primary system kept during normal operations?
11 A
About 2000 psig.
12 Q
Going back to basics again, I think you
~
13 testified that you understood that if that pressure 14 dropped far enough, you could have boiling in the 15 primary system?
16 A
I said from a theoretical standpoing, I
(
17 understood that.
18 Q
Was that theoretical concept explained 19 in your basic training that you gave the operators?
l 20 A
To the best of my recollection, that i
I 21 theoretical understanding was known.
O 22 Q
Were the operators trained that they should l
23 not operate the reactor in conditions that you have l
24 described as bulk boiling?
(~\\
G 25 A
As I testified earlier, that never occurred l
l
1 zochman 649 2
to us and, to the best of my recollection, that subject 3
wasn't approached.
4 Q
You mean you never at any time in any of ggg 5
the. training that you gave your operators explained 6
to them that it was important not to let the water 7
in the primary system start to boil?
8 A
As I testified earlier, it just didn't 9
occur -- that didn't occur.
That didn't occur to me.
10 Q
Going back to the description that you 11 gave earlier,of the way the whole reactor system 12 operates, it is correct, is it not, that there is a hot 13 leg and a cold leg in the primary system?
14 A
Yes.
15 Q
When the water is in pipes which go through l
16 the core, correct?
17 A
Yes.
18 Q
When they go through the core, they are 19 heated up, the water is heated up to approximately 600
'20 degrees Fahrenheit?
21 A
That's right.
22 Q
Now it's in the so-called hot leg?
l l
23 A
Yes.
l 24 Q
The water goes in these same pipes through N
25 water in the steam generator, correct?
l h
1 Zochman 650 2
A Yes.
3 Q
In that process, heat is transferred from 4
the primary system water to the secondary system, 5
correct?
6 A
Yes, tha t 's correct.
7 Q
As a result of that, when the water comes 8
out of the steam generator --
9 A
on the secondary side.
10 Q
-- on the secondary side, it has now been 11 cooled to 550 degrees, correct?
12 A
We are back to the primary now.
13 Q
I am talking a bout the primary all along.
14 A
We were jumping back and forth.
You are 15 talking about heat being transferred to the secondary?
16 Q
Maybe I didn't make myself clear.
The 17 water comes out of the core at 600 degrees in the hot 18 leg, correct?
I l
19 A
Yes, sir.
l l
20 Q
It stays in those same pipes and goes l
l 21 through the steam generator, is that correct?
22 A
Th at 's correct.
23 Q
In that process, heat is transferred from l
24 the primary system water to the water in the steam 25 generator, correct?
I i
i.
1 Sochann 651 "D
2 A
To the secondary side, yes.
(G 3
Q After the water in the primary system 4
goes through the steam generator, as a result of the 5
heat transfer process that you have just described ggg 6
the water in the primary syster which is still in the 7
same pipes is cooled down to about 550 degrees, correct?
8 A
500-something degrees, yes.
9 Q
Now, it's in the so-called cold leg, 10 correct?
11 A
Yes, sir.
12 Q
Then it goes through the cold leg and 13 reenters the core?
14 A
That's correct.
15 Q
In that process the water is heated up 16 again to 600 degrees, is that correct?
17 A
That's correct.
18 Q
In that same process, that is going 19 through the core, the water performs a function 20 of cooling the core, does it not?
21 A
That's correct.
It serves more than just O
22 that function.
23 Q
one of the functions it serves is keeping 24 the core cool?
O
\\r/
25 A
Yes.
l
_=
1 Zochman 652 2
Q Did you understand that it was important 3
from a safety point of view to keep the core cool?
4 A
I understood that as long as I maintained 5
adequate RCS inventory, that the core stayed cool.
ggg 6
Q And that it was very important for safety 7
reasons to keep the core cool, is that correct?
8 A
It was one of the functions -- I understand 9
it was one of the functions of the coolant yes, sir.
10 Q
By "yes, sir," you mean you did understand 11 that cooling the core was important for safety reasons?
12 A
Yes, I understood that.
13 Q
You understood that if the core was not 3
O 14 adequately cooled, that could lead to fuel damage, 15 correct?
16 A
I understood there were conditions in 17 which you could have localized flux such that you 18 could have fuel damage.
l 19 Q
For the moment I am not asking you by what l
20 particular mechanisms the core would be failed to be l
21 cooled.
I am simply asking you didn't you understand 22 as a basic concept of running a nuclear reactor that if l
23 the core was not cooled, that could lead to core damage?
24 A
I already testified that it never occurred S_/
25 to me that conditions were such that the core wouldn't
653 2
1 Zochacn 2
he covered, because we were focusing on maintaining 3
the pressure --
4 Q
Why did you understand that it was 5
important to keep the core covered?
gg 6
A For several reasons.
One, as you mentioned, 7
the coolant kept the core cool.
8 Second of all, it was a moderator for the 9
neutron reaction.
10 Q
Why was it important to keep the core 11 cool?
12 A
Because if you didn't have the core cooled, 13 you could have core damage, fuel damage.
14 Q
And as you just said a minute ago that one 15 function of having the water in the primary system 16 circul ate through the core was to perform a core
, 17 cooling -- was to keep the core cooling, is that 18 correct?
19 A
That was one og its functions.
20 Q
You also knew, did you not, before the 21 Three Mile Island accident, that if the water in the 22 reactor or coolant system boiled into steam, that it 23 would not be able to effectively keep the core cooled?
24 A
I told you that that never occurred to me 25 prior to the accident.
__,7
654 1
Zochman
(}
2 Q
You mean it never occurred to you that 3
MR. FISKE:
Withdrawn.
4 Q
It never occurred to you that if pressure 5
dropped far enough, that could cause boiling in the ggg 6
primary system?
7 A
I told you from a theoretical point, 8
I understood that.
9 Q
Let's keep it on a theoretical point of 10 view.
11 Did you also consider as a theoretical point 12 of view that if the water in the primary system did i
13 boil as a result of a drop in pressure that that could 1
14 impede its effectiveness to keep the core cooled?
15 A
Repeat the question, please.
16 (Question read.)
17 A
And you are talking about prior to the i
i 18 accident?
l 19 Q
Yes.
20 A
I don't recall that occurring to me at that l
21 time.
h
(
22 MR. FISKE:
Let me show you a document 23 which we will mark as B&W Exhibit 571.
This is r
24 a collection of pages captioned " Nuclear Energy l
l
\\-
25 Training Instructor's Guide Plant Performance."
1 zochacn 655
()
2 Q
I will show you this document and ask you 3
whethe r this was part of the training materials used 4
at Met Ed?
5 A
Yes, we got this somewhere around 1978 or ggg 6
so.
7 Q
Let me show :'ou two pages, Mr. Zechman, 8
from this document.
First is page Q-1 which has the 9
number 1083-0123, question No. 4 reads, "Is boiling 10 in the PWR core expected?
If so, what are the 11 limitations on the amount?"
12 And the next p.g o is QS-1, 1083-0125,
(~S 13 captioned " Quiz solutions."
No. 4 reads, "Yes.
There
\\_)
14 is some boiling in the hot channels, but it must be 15 limited so that there will be no steam in the upper 16 plenum."
17 Do you see that?
18 A
Yes.
19 Q
What is the upper plenum?
20 MR. MacDONALD:
His understanding before 21 the accident?
O 22 Q
Did you understand before the accident 23 what the upper plenum was?
l 24 A
Top of the reactor vessel above the core.
f
25 Q
Part of the primary system outside the I
i l
l 1
zochman 656 t'
(
2 pressurizer, right?
s 3
A
'No.
What I am talking about,is the top par [of it, above 4
of the vessel, above that that f
gg) 5 the core, i
6 Q
In other words, not part of the primary
?
7 syste'n through which the water circulates in the manner 8
you have just described?
t 9
A' For example,-t'he steam generator or the'
'{
10 pressurizer, you are referring to, sir.
11 Q
Yes.
12 A
No.
[~}
13 Q
In other words, it is not?
(>
14 A
It is not.
15 Q
Why did you understand it'was important 16 that there be no steam in the upper plenum?
17 A
I. dont r ecall seelig those questio5s or 18 even using those.
19 Q
Did you understanding that it was important 20 that there not be steam in the upper plenum?
21 A
I never considered that, sir.
9 22 Q
Let me show you another set of questions
.e 23 and answ'ers from the same exhibit.
The question is 24 on page E.2-6, 1083-0148, question 17.
V(~s
\\
25 "While reading an analysis of a x
1 Zochnan 657
()
2 hypothetical accident you find this statement, 'Then 3
there is a rapid drop in reactor pressure and the 4
DNBR drops to less than 1,' what would you expect ggg 5
the consequences of this to be?"
6 And then on page ES2.B, 1083-0151, the 7
answer is, " Expect film boiling to occur and probable 8
fuel damage."
9 Do you see the question and the suggested i
10 solution?
11 A
I dc.
I 12
.i Q
Gn it is correct, is it not, that you il r.
pl underst ood f'h M
l that a rsnid drop 1.n reactor prassytre c4uld s/
I i
14 produce film boiling which could cause fuel daraqs?
15 A
That is not correct.
I already told you 16 that that never occurred to me.
17 Q
Did you ever look at this material?
18 A
We haven't scanned every bit of material 19 because we had gotten in, to the best of my recollection, 20 the early part of
'78.
We used part of it.
I(don't 21 recall which parts were used and which weren't.
I 22 don't know that we used the whole thing.
23 Q
Is it your testimony that you didn't train 24 ycur operators on the concept that is reflected in that i
25 question and answer that I just read?
m m-g e
-.--.m
--v
,-e
, - + -
'y
-w a
y
s 1
Zochman' 658 s
(
2 A
Could you define the concept again?
3 Q
Yes.
If there is a rapid drop in reactor 4
pressure and the DNBR drops to less than 1.you would ggg 5
expect film boiling to occur and probable fuel damage.
6 A
I don't recall, to the best of my 1
j recollection, that it was put in those terms.
7 8
Q Wheth(r it was put in those terms l
I I
9 4 A
Because it didn't occur,to me, so I don't f
10 racall the time that it was taught.
11 Q
so I understanc your answer, whether or l?-
not it war put ist the precise terms that were used 15
in that guestion and answpr, is it ycur testircny that 14
. that basic concept war act part of the training that i
s i
15 you gave the operators?
16 A
To the best of my recollection, that was 17 not.
~
18 Q
I think you have testified before that it 19 was part of the training at Met Ed to train the 20 operators on technical specifications, operating 21 procedures and emergency procedures.
(Il l
-22 A
Yes, sir.
23' Q
waan't it a fundamental concept in the 24 training on thoseSprochdures that pressure and 25 temperature shouldbe maintained vithin the so-called 1
1
1 zochcon 659
[ )T 2
pressure / temperature envelope?
3 A
Yes, we were trained that we would try 4
to operate the reactor within the pressure / temperature 5
envelope.
gg 6
Q And that this was true whether you were 7
talking about a start-up or whether you are talking i
B l
about normal cperations cr whether you are talking
[
about cooldown er after a transient, is that correct?
5 i
%0 A
This is during normal operations, the 11 operating envelope.
r 12 Q
Did you understand that after a transient
'5 13 i it was all right to depart from the preesure/temparature 1
'{&
1 14 envelopo?
15 I
A That's why we had a pressure / temperature 16 envelop in the RCS system that would give us trips 17 should we reach points of those envelopes, 18 Q
You have already said earlier that one of 19 the purposes of staying within the pressure / temperature 20 envelope was to keep from creating a condition in 21 which fuel damage would occur, do you remember that?
O 22 A
I said it was related to not exceeding 23 to maintaining a DNBR ratio greater than 1.3.
24 Q
In order to avoid fuel damage?
25 A
DNBR was always related to heat transfer
-L, i
1 zochman 660 2
from fuel and if that heat yes.
If that heat could you repeat the question.
3 4
Q I will repeat it so we can save time.
I am 5
repeating a question that I asked in the same way and g
it's a predicate to the question I want to next ask.
6 7
Isn't it a fact that you understood that 8
it was impcrtant to stay within the pressure / temperature t
gl envelope in order to avoid creating a condition where 4
10 jl fuel danage could occur?
A I believe I already testified to thst.
11 l l
lag Q
Wasn't it your understanding that it was I
i
{~}
13 juat as importanc to keep fuel damage fron occurring
%s l
after a transient had occurred, as it was during i
14 15 normal operatiens?
16 A
Yes.
l 17 Q
So isn't it a fact that the concept of 18 maintaining pressure and temperature within the 19 pressure / temperature envelope was reflected in 20 procedures that applied after a transient had occurred j
21 as well as procedures that related to normal operations?
l 22 A
Repeat the question, please.
l 23 (Question read.)
l 24 A
I don't know that the procedures covered O
\\-
25 every possible circumstance that one could perceive.
1 Zschman 661 2
Emergency procedures were based on expected response, 3
expected symptoms and responses to certain plant 4
transients, 5
g I am not asking you now to tell us about ggg 6
every single procedure that applied after a transient 7
had occurred.
I am simp'ly asking you on a broader 8
basis, isn't that correct that the same concept, that 9
is, staying within the pressure / temperature envelope c
10 in-order to prevent possible fuel damage apply just as 11 much during a situation in which a transient had 12 occurred at it did during normal operatiens?
13 A
I ' don't recall.
14 Q
Mr. Zecharn, I wouId like to read you 15 from some te stimony that Mr. Scheimann gave before 16 the President's Commission.
17 You know who Mr. Scheimann is, I take it?
18 A
Fred Scheimann.
19 Q
Yes.
One of the operators of Three Mile 20 Island who was present in the control room on the day 21 of the accident.
O 22 A
I understand who he is, yes.
l 23 Q
He was a shift foreman, was he not?
l l
24 A
I forget what his position was at that i
25 time.
1 Zschman 662
(^]
2 Q
I am reading from page 154, and I will v
3 come around so you can follow.
4 A
I forget what his title was at that time.
5 Q
Let me start at page 154.
G 6
" Question:
On Frederick Deposition Exhibit 7
3 they indicate limiting conditions for operation.
f Do you know where these limiting conditions came from?
8 I
9
" Answer:
It would probably come from 10 B&W specifications for the plant operaticn.
11
" Question:
In designing the plant they 12 would set out limits to operate the plant?
(}
13
" Answer:
I would believe ao, yes.
'uj 14
" Question:
And pursuant to that tech 15 specs were drafted?
16
" Answer:
Yes.
17
" Question:
In your B&W training course, 18 was it explained to you why these limits were set?
19
" Answer:
Some limits I would say yes, it 20 was.
21
" Question:
Do you remember which limits O
22 were explained?
23
" Answer:
Not totally.
24
" Question:
Do you remember generally?
g)
Ik/
25
" Answer:
We had talked some pressure and
1 Zachman 663
(~)
2 temperature limits and things of that nature.
'w) 3
" Question:
Do you remember anything else?
4
" Answer:
Not really.
5
" Question:
Do you remembe r what they e 6
explained to you as to pressure and temperature?
7
" Answer:
They explained to us what our 8
pressure bands were and what our temperature bands were 9
and they did give us basic ideas of why they were I
10 trying to maintain in that area.
11
" Question:
Do you remember what they said?
12
" Answer:
You had a certain cinimum
(-]
13 pressurization temperature to keep from increasing
'v' 14 pressere toc high before your temperature was up to keep ycu from having cladding trouble and rupture 15 16 trouble.
And you had maximum temperature limitations 17 to prevent boiling in the core and things of that nature.
18 You had minimum tenperature limits, minimum pressure 19 limits to keep you from boiling in the reactor coolant 20 system basically things of that nature."
21 Did you at Met Ed train the operators that O
22 you had a pressure / temperature relationship which was 23 important to keep you from boiling in the reactor 24 coolant system.
\\>
25 MR. MacDONALD:
He can answer.
I object to
e 3
1 Zochasn 664 2
the form.
3 A
I already testified that I do not -- it 4
did not occur to me the condition of having boiling ggg 5
in the core, that the pressure / temperature envelope 6
was based on a DNBR ratio which had to do with fuel 7
cladding and fuel damage' considerations.
8 Q
Did you ever learn during any of the time l
prior to the accident that you were receiving reports.
9 10 as to what was going on in the B&W training program that I
11 B&W was giving training of that nature?
12 A
1 don't recall B&W giving us training in 13 which those areas were discussed, i
14 Q
You mean nobcady rever brought to your i
15 attention that they were giving that training, is that i
16 correct?
17 A
I am saying I don't recall seeing it in 18 my training or recall it in their training, to the 19 best of my recollection at this time.
20 Q
So apparently Mr. Scheimann never told you 21 that they were doing that?
O 22 A
No,-I don't recall discussing it with Mr.
23 Scheimann.
24 MR. FISKE:
Let me mark as the next exhibit, O
25 as B&W Exhibit 572, Section 2.0 of the Technical
1 Zechman 665 4
()
2 Specification for the TMI Unit 2.
3 (collection of pages captioned " Nuclear 4
Energy Training Instructor's Guide Plant ggg 5
Performance " marked B&W Exhibit 571 for 6
identification, as of this date.)
7 (Section 2.0 of the Technical Specifications 6
for TMI Unit 2 marked B&W Exhibit 572 for 1
9 identification, as of this date.)
I 10 BY MR. FISKE:
11 Q
Is it correct, Mr. Zeehman, that during i
12 the period of time befora the Three Mile Island accident ll 13 when you were in charge of the training department, 14 you were familiar with-the technical specifications for 15 Unit 27 16 A
At the time I was either acting or was in 17 charge, and the times that I went through the technical 18 specifications.
I don't know that I memorized all of i
l 19 them.
20 Q
Let's look at page 2.1, the very first 21 item, which says, "2.1 Safety Limits."
22 Do you see where it says " Reactor Core,"
23 it says "The combination of the reactor coolant core 24 outlet pressure and outlet temperature shall not O
25 exceed the safety limit shown in Figure 2.1-1."
L
4
- l Zechman 666
()
2 Do you see that?
3 A
Yes, I do.
4 Q
Turning to Figure 2.1-1, does that reflect gg a pressure / temperature envelope?
5 6
MR. MacDONALD:
What he understood prior 7-to the accident?
f 8
MR. FISKE:
Yes.
j 9-A I realize prior to the eccident we had a 10 pressure / temperature envelope.
I just don't recall 11 if this was the -- I just don't recall this, at this 12 time.
(
13 Q
You do reca'll that there was a pressure /
14 temperature envelope which had to be complied with as l
15 part of the safety limits relating to the core?
I 16 A
Yes, I understood that.
17 Q
I would like you to turn to page B2-1.
18 If it helps, it is numbered 0922 at the bottom.
19 Do you have that in front of you?
20 A
Yes.
21 Q
Do you see at the top " Safety Limits?
O 22 A
Yes.
23 Q
And the next word is " Bases"?
24 A
Yes, sir.
O 25 Q
And the first paragraph reads, with respect
1 Zschnan 667
(
)
2 to 2.1.1 that we read just a moment ago, "The 3
restrictions of this safety limit prevent overheating 4
of the fuel cladding and possible cladding performation (gg 5
which would result in the release of fission products 6
in the reactor coolant.
Overheating of the fuel 7
cladding is prevented by restricting fuel operation 6
to within the nucleate boiling regime where the heat 9
transfer coefficient is large and the cladding surface 10 tanperature is slightly above the coolant saturation 11 temperature."
12 Do you see that?
13 A
I see that.
14 Q
Did you understand that the pressure /
15 temperature envelope pictured in Figure 2.1.1 was 16 designed to accomplish the result described in the 17 section I just read?
18 A
Yes, I did.
19 Q
You understood that that technical 20 specification applied during both normal operations 21 and during the course of a transient?
O 22 A
I said I didn't recall.
23 MR. FISKE:
Let me mark as B&W Exhibit 573 24 at the risk of re-marking an exhibit that has O
25 already been introduced at a prior deposition.
ll 1
zachman 668 2
(Document marked B&W Exhibit 573 for 3
identification, as of this date.)
4 BY MR. FISKE:
I 5
Q This is Unit 2, operating Procedure ggg 6
2102-3.3, Decay Heat Removal Via OTSG."
7 Do_you recognize this, Mr. Zechman, as 8
an operating procedure for Unit 27 9
A I recognize this as a procedure that i-
^
10 has all the markings of a Unit 2 procedure, yes, sir.
11 Q
Looking at the bottom of the front page, 12 do you see two blocks reflecting the fact that Unit 2 13' PORC had recommended approval with the signature for 14 the chairman of the PORC and that the Unit 2 15 superintendent had approved with a signature of the 16 Unit 2 superintendent?
17 A
I see that.
18 Q
Both reflecting dates in April of 19777 19 A
Negative.
It looks like '78 to me.
l 20 Q
I think you read it better than I do.
21 It's'78, right?
22 A
I believe so.
23 Q
What did you understand the purpose of this 24 procedure was?
CE) 25 A
I don't recall using this procedure
1 zechnen 669
~ '
2 personally.
3 Q
Were you aware that there was a procedure 4
applicable to decay heat removal via the steam ggg 5
generator?
6 A
I can only say that the title looks familiar,
+
7 but I don't recall using it.
8 Q
Let's go back a couple of steps.
9 Are you familiar with a concept in the 10 operation of a nuclear reactor called decay heat 11 removal?
12 A
Yes, sir.
13 Q
What is decay heat removal?
14 A
Decay heat removal Ls removal of residual 15 heat from reactor core after a period of shutdown.
16 Q
Am I correct that in a situation where 17 there has been a transient resulting in a reactor 18 trip, there continues to be heat generated from the 19 core even though the unit is not operating?
l 20 A
Even through the rods have been inserted 21 and the reactor is essentially shut down, there is a O
22 residual heat flux of the core of fission products.
23 Q
That is colloquially called decay heat?
24 A
That 's correct.
25 Q
It is important to accomplish a safe and
1 Zochaan 670
[)/
2 effective shutdown that that decay heat be removed?
~-
3 A
cooldown.
4 Q
It's important that it be done, that the ggg 5
decay heat be removed?
6 A
It is important to remove the decay heat.
7 Q
one way to do that is via the steam 8
generator, is that correct?
9
'A The decay heat removal system?
10 Q
Yes.
Is that correct?
Put it another way, 11 more simply.
12 Is there a process ;?o r removing the decay 13 heat which involves the steam generator?
14 A
There is enti process -- there is a process 15 that I am aware of, yes.
l 16 Q
can you tell us whether the document you 17 have in front of-you is the operating procedure for 18 that process?
19 A
As I said, I have not used and I am not 20 familiar with this procedure and I would be speculating 21 at this point.
O 22 Q
Let me direct your attention to page 3.0 23 of this document, the top of the page under " Limits 24 and Precautions."
O
\\-
25 A
Yes, sir.
1 Zochasn 671 2
Q "2.1.1.
Reactor coolant temperature /
3 pressure and cooldown rates shall be maintained within 4
the limits specified in Figure 3.4.2 of Ts 3.4.9.1 5
(refer to Figure 1.5.2 attached)."
g 6
Do you see that reference?
7 A
I see that reference.
8 Q
Turning tc Figure 1.5.2, do you have tha; 9~
in front of you?
t -
10 x
y,3, i
11 Q
" Heat Up/Cooldown Curve."
12 A
That's correct.
13 Q
Eave you ever teen that curve ~before?
14 A
I have seen heat up and cooldown curves, but I
I 6
15 1 don't know that I saw this specific curve.
I don't i
16 recall that I specifically saw this specific curve.
17 Q
what did you understand the purpose of a 18 heat up/cooldown curve was?
i 19 A
It's been a very long time since I worked 20 with them.
I only have a generic remembrance of the 21 heat up and cooldown curves.
Two areas, one had to do 22 with the operation of the pumps and some of the l
23 limitations had to do with the metallurgical considera-24 tions of the piping.
(:)
25 Q
Isn't the heat up -- doesn't the l
l l
I _ _ _ _.
~ - _, _. _., _ _, _.. _,
1 Zochman 672
)
2 heat up/cooldown curve appear in a large number of s-3 procedures for Unit 2, both emergency and operating 4
procedures?
5 A
I can't put a quantity on it.
I know that g
6 it appears in several procedures.
7 p
Isn't it a fundamental concept that these 8
curves have to be conformed vith during al3 phases 9
of the start-er operation and cocidown of the 10 reactor?
}
11 A
I don't recall all the limitations and use 12 of thosa curves any more.
It 's been long time ago.
It 13 Q
Mr. Zechman, we ars taikt.ns about a pretty 14 fundamental question relating to a period cf time from 4
15 whenever it was that you first started with the 16 training dep&rtment at Met Ed back in the early
'70's 17 right through. the period of. time ending in F. arch of '79 18 when you were in charge of the training department.
19 So I am asking you simply, thinking back over that 20 entire period of time in which you were involved in 21 or in charge of the training at Met Ed, didn't you O
22 understand that at all times during start-up operation 23 or cooldown, shutdown, you had to comply with these 24 curves?
O 25 A
I had an understanding years ago when I was
1 Zachman 673 g_,)
2 working with these and in the training department, I 3
had an understanding of the heat up and cooldown curves 4
and the basis for them.
I don't rghall the basis (l) 5 for them today.
It's been too long since I worked with S
them.
7 Q
Did you know cf any situation from start-up 6
right through cooldven when it wasn't recessary to l
i 9
conform to these curveu?
10 P.
As I said, I don't recali all the 11 rauifications and usos of those curves et this time.
12 I would be speculating at this point with my memory.
(
13 Q
Let's see, Mr. Zechm&4.
Why did you 14 l
understand it was impartant tc comply with these curves?
15 A
Because they were limitations that were put 16 in procedures to operate with.
17 Q
Did you have' an understanding beyond the 10 fact that they were attached to a procedure as to the j
19 reason why it was important to do it?
1 20 A
I certainly understand that they were l
21 important, that we follow those heat up and cooldown 22 curves.
That's why they were in our procedures and l
23 there were a good number of reasons for parts of those 24 curves.
I don't recall today all those ramifications.
25 Q
I am simply asking you in the broadest l
1 Zschman 674 2
terms possible, why did you understand that it was 3
important to filow the curves?
I assume you had some 4
understanding beyond simply the fact that they appeared 5
in the procedure?
ggg 6
A I told you a while ago, they had to do 7
with the operetion of our C pumps, they had limitatior_s 4
i with the metallurgical consideratione of the piping.
9, I understocd that.
b l
M l Q
What did you understa.ud eculd happen if i
those curves were not followed?
11 tj y
12 r A
I don ~t recall those details a.sy more, g
g-13 air.
D 14 i Q
Can you give tu any sing 1r thing that i
l 15 you recall now could have cecurred that would be bad 16 for the plant if those curves were not followed?
17 A
With respect to the metallurgical con-18 siderations, you could exceed some of the stress j
19 limits of some of the piping, 20 Q
Why would that be bad?
21 A
For the integrity of the RCS system.
22 Q
Why was it important to maintain the l
23 integrity of the RCS system?
24 A
So you won't have ruptures or damage to 25 the piping within the RCS system.
1 Zechman 675
(
2 Q
Was it important that you not have damage 3
to the* integrity of the RCS system during start-up?
4 A
Certainly.
ggg 5
Q Was it important that you not have damage 6
to the integrity of the TOS system during normal 7
ope rations ?
f E
h Yes, sir, 9
Q Wed Lt important that you did not have 10 i 4ccage to thw intes.~ity of ti:e RCS system during h
h cooldowa?
11 f
12 A
Yes.
13 (Peress.)
Li -l!
hY MR. FIFEF:
?#
15 Q
You have that heat up/cooldown curve in 16 front of you, Mr. Zechman.
17 A
1.5.27 18 Q
Yes.
19 A
Yes, sir.
20 Q
There are some numbers down the left-hand 21 side of the page, are there not?
O 22 A
You mean B&W numbers or -- I am sorry.
23 Starts with the J 24 Q
No, not the numbers that reflect the O
25 s tamping of the documents.
1 Zechacn 676
['} '
2 A
On the curve itself?
'a 3
Q Yes, top number is 2300 and the bottom is 4
100.
ggg 5
Do you see that?
6 A
Yes.
7 Q
What do those numbers represent?
I 8 j MR. MacDONALD:
You are asking for h i.s s
t i
S recollection now?
I l
~
30 MR. FISKE:
Yes, and he can loo % at the 11*
c u rv e..
12 A
The numbers repreaant temperature.
13 Q
what do the numbers across the b;tton --
' O 14 A
I t ho ug~a t you said -- which huhcred are 15 you talking about?
16 Q
The top number is 2300 and the bottom 17 number 100.
18 A
That's RC pressure.
19 Q
The numbers acrosc the bottom are 20 temperature?
21 A
Correct.
O 22
-Q What did you understand the curves, the 23 various curves that are on this graph supposed to 24 represent?
's /
25 A
sir, it's been too long since I worked
1 Zschman 677 2
with these curves.
I would be speculating on the 3
interpretation of these curves.
I don't remember any 4
more.
ggg 5
Q Just starting with the basics, isn't it 6
correct that these curves reflect varacur pressure /
l 7
temperaturo relationships as you stove along the curve?
6 A
Yes, they do.
O Q
And is it also correct that it was in-
}
I 10 )
portant to asintain those pressure /tempereture j
11 relationships?
i i
12 A
In the utilization of this curve and the 13 procedure that utilizes this curve.
i 14 Q
Se that at any time this heat up/cooldown 15 curve appears in a procedure, the purpose of it is 16 to be sure that in implementing that particular 17 procedure, the operators are sure that the 18 pressure / temperature relationships conform with what
(
19 they are expected to do in light of these curves?
l 20 A
Under the guidance of what the procedure 21 states.
O 22 Q
Right.
But let's just take one curve, 23 for example.
Let 's take the curve that's marked No.
2.
24 Do you see that curve on this chart?
O 25 z
A Yes, I do,
t
1 Zochnan 678 2
Q Then there is a description of that on the right-hand side, is there not?
3 4
A Yes, there is, 5_
Q How is it described?
ggg 6
A
" Minimum RC pressure to maintain compres-7 sion force on clad (natural circulation)" -- and then 1
6 a letter I can 't read, and then -- " inst. erspr pint 50 psia minus 12 degrees Fahrenheit."
9 l
l' 10 Q
so did you understand before the accident 11 thut the purpose of this curve was to be sure that a l
12 certain minimum pressure was unir.tained in rela tion to h
s 13 the temperature that existed at that part.icular point
)
14 in time?
15 A
I already said I have not worked with these.
16 I don't recall the basis for these or have a recall 17 of the basis for these at this time. I would be 18 speculating on --I can read to you what it says, but I 19 would be speculating on the interpretation of all of 20 this.
21 Q
Let's j u s.t look at the various curves.
l 22 Let's take them one at a time, l
23 The first one is No.
1.
Do you see No. 17 i
24 A
Yes, sir.
1.
'\\-
25 Q
Do you know whether the operators were l
l l
i
1 Zochman 679 2
supposed to maintain a pre,sure/ temperature 3
relationship that stayed on the left side of the 4
curve or the right side of the curve?
ggg 5
A I don't recall.
6 Q
How about curve No.
2, can you tell us t
7 whether the operators were supposed to maintain a 6
pressure / temperature relationship cn the lef t side 9
of the carve or on the right side of the curve?
l.
t 20 !
A I don't recall.
k' 11 Q
Can yce tell us looking at any one of
!j the six curves on that chart whether the operators l
12
.I la were supposed to maintain pressure on the left side I
14 or the -- pressure / temperature relationship on the l
15 left side of the curve or the right side?
I 16 A
I don't recall.
17 Q
And you are'giving those answers after 18 having an opportunity to look at the curves and look 19 at the description of each one, is that correct?
20 A
That's correct.
l 21 Q
As you sit there today, Mr. Zechman, just l
22 by looking at the description of these curves, can you 23 tell us which side of the curves the operators should 24 be on?
)
25 MR. MacDONALD:
I am going to object to l
i
1 Zochann 680 2
that.
You are talking about his present 3
recollection of the document and not prior to 4
the accident.
I object to that.
His recollection ggg 5
is fine.
I have no problem with that.
6 MR. FISKE:
I will give Mr. Zechman an 7 l opportunity to answer if he wants to.
8 A
Would you restate the question, please, j
l l
)
9 (Questi>n read.)
l
\\
4 c
t 10 g
1ust ec you understand, Mr. MacDonald 11 (I stated an cLjaction that had been stated in previcus IE deponitient on both sides and witnesses up to this 13 point havo nct been required to answer his questions l
)
1 14 like the one --
15 MR. MacDOMALD:
Do you want to know if 16 he wants to answer over my objection?
17 MR. FISKE:
Yes.
18 A
I do not.
19 Q
Were you familiar with a procedure called 20 the unit heat up operating procedure that was in effect 21 before the accident 2202-1.17 22 A
I don't recall that procedure at this i
l l
23 time.
(
24 Q
Was there a heat up/cooldown curve that was l
l 25 part of that procedure?
l l.,. -. -.
- - - ~ ~ - - - - - ~, - - - - -, - -
- ' - ~ ' - ~ ~ - - ~
1 Zochman 681 (Av) 2 A
I don't recall.
3 Q
Do you recall a procedure called unit 4
startup operating procedure that was in effect before (g) 5 the accident?
6 A
You are talking about Unit 27 7
2 Y o r..
8 A
As I think I me r.t io ned 9
{
Q Or Unit 12 10 i A
Okay, for Urti t i trers waJ A startup
[I 11 procedure, I recall that.
12 Q
Was there a heat up/cocidown curve as part
['l 13 of that procedure?
'u/
l l
14 A
I don't recali.
j 15 Q
Was there a procedure in effect before i
l 16 the accident for Unit 2 or Unit 1 called pressurizer 17 operating operating procedure?
'8 A
For Unit 1,
to the best of my recollection, 19 there was.
20 Q
How about Unit 2?
21 A
I don't recall.
O 22 Q
Was there a heat up/cooldown curve that 23 was part of that procedure?
24 A
I don't recall.
I don't remember.
I
)
~
25 Q
Was there a procedure in effect prior to
I 1
Zachmen 682
(
2 the Three Mile Island accident called reactor coolant 3
pump operating procedure?
4 A
I don't recall either way.
ggg 5
Q For either unit?
6 A
Either unit.
7 -
Q I take it you don't recall whether there I
i 1
8 was a-heat up/cooldown curve ac part of that procedure?
l 9 il A
I don't recall.
l1 10 I Q
Nas there c procedure in e2fect befote the 11 Three Mile Islan6 accident known as power operations?
I 12 A
To the best of my recollectioat there was j
i l
/
13 for Unit 1.
j k
14 Q
How ahottt for Unit 27 15 A
There was one that was similar to it.
I 16 don't recall the exact title.
17 Q
Whatever the title of it wac, the substance 18 was comparable?
19 A
I can't say because I don't recall what 20 the substance of the Unit 2 one was.
21 Q
Was there a heat up/cooldown curve as part O
22 of that procedure?
23 A
I don't recall.
24 Q
Was there a procedure in effect prior to 25 the Three Mile Island accident called unit shutdown?
I
,_m
Zochitan 683 1
A There was a shutdown procedure for Unit 1.
(3 i
l 2
I don't recall the exact title.
I don't recall the 3
title if there was one for Unit 2.
4 Q
Was there a heat up/cooldown curve as part of that procedure?
C A
I don't recall.
7 Q
We icoked at the decay heat removal via 8
l OTSG, 6.nd we have all seen that there is a beet up/
9 I
I cooldown curv6 for that one.
10 i i
i
(;l A
Yes.
11 ft Q
Was there a procedure in effect befcre the 4
Il f
12
,Il Three Mile Xstand accident called unit cooldown?
j f
$3 7 t
i'
J A
I don't recall either way.
14 Q
For either unit?
15 A
For either unit.
16 Q
So I take it you don't recall whether there 17 l
was a heat up/cooldown curve for any such procedure?
18 l
A I don't recall.
19 Q
Was there a procedure called decay heat l
20 l
removal system?
21 lll A
There was a procedure called decay heat removal for Unit 1.
I don 't recall if there was a 23 corresponding specific title for Unit 2 on procedure.
l 24 r%
(
)
Q Was there any heat up/cooldown curve as l
25 i
{
1 Zschmen 684
/
(~m
(% -)
2 part of that procedure?
3 A
I don't recall.
4 Q
Was there a procedure called reactor trip ggg 5
emergency procedure?
6 A
For Unit 1 there was a reactor trip 7
procedore, to.the best of my recollection.
I don 't 8
rscall if there was a corresponding title for Unit 2.
9 0
has there a haat up/cooldown curve as part 10 t of that; procedure?
I 11 l A
2 don't recall.
I h
.Q Was there a procedure in effect before the l
12 I
("S is a c c a d e r.t called station blackout?
\\~]
14 A
'To the best of my recollection, there was '
15 a procedure with that title for Unit 1.
I don't 16 recall if there was a corresponding procedure for 17 Unit 2 or its title.
l l
18 Q
Was there a heat up/cooldown curve as part l
19 of that procedure?
l c
20 A
I don't recall.
21 Q
Regardless of the specific titles of the l
h
(
22 variods procedures, having read you the titles that I l
l 23 just did, do you recall whether or not there were in 24 fact procedures designed to deal with the types of
, ~h. '
[
! \\ I 25 conditions or circumstances reflected in the titles
/
I i
l l
1 Zechman 685
()
2 that I just read?
3 A
I have forgotten the titles you went 4
through.
l ggg 5
Q Unit heat up operating procedure, unit 6
startup operating procedure, pressurizer operation, 7
reactor coolant pump operation, power operations, unit 8
shutdown, decay heat removal system, unit cooldown, 9
reactor trip, station blackout.
10 A
Repeat your initial question.
11 (Question read.)
12 A
Can I ask for a clarification?
You are f~)T 13 saying, for example, if there is a procedure called i
u.
14 reactor trip procedure, that it dealt with a reactor 15 trip?
16 Q
Yes.
In other words --
17 A
It could have. dealt with some other things i
18 but would it have dealt with what the title said?
l 19 Q
I wanted to be sure when you were 20 answering my questions that you were not limiting your 21 answer to a procedure with a specific wording of 22 the one that I read to you.
I wanted to be sure that j
23 your answers are given in the context that I was asking 24
'whether there were procedures not only with that O
i 25 specific title but also procedures that governed the s
I
._,__.,__..,m_,,_
s s
1 Zechm'an 686 2
type of situation that was describe in the title, 3
whether or not you remembered the exact title of the i
4 procedure.
lll 5
A To the best of my recollection, the ones 6
that you have named were procedures that dealt with 7
at least what the title implied.
Sometimes some of 8
those titles were tied together into a single procedure, 9
that's what is confusing the issue in my mind right 10 now, whether they were separate procedures or titles 11 or sometimes combined titles.
12 Q
I want to make cure I understand your
()
13 answers when you were saying you didn't recall one way 14 or.the other if there were certain procedures in effect 15 at Unit 2, but you.did remember such a procedure for 16 Unit 1, youweregiving[that answer in the context not 17 simply of a procedure with that specific title but a l
18 procedure dealing with the subject matter reflected l
19 in the title, do you follow me?
20 A
I understand.
To the best of my recollection I
e 21 I was.
22 Q
I would like to show you, Mr. Zechman, 23 a document previously marked as B&W Exhibit 540, which l
L.
24 is Unit 2 Os operating procedure 2102-3.2 called Unit 25 Cooldown.
Tr '
i,
.k l
1 Zechman 687
()
2 Do you have that in front of you?
3 A
I have that in front of me.
4 Q
What is cooldown?
lll 5
MR. MacDONALD:
Apart from the procedure?
6 MR. FISKE:
Yes.
7 Q
Just generally, in the same sense I asked 8
you before what is decay heat removal, I would like 9
to know basically what is cooldown.
10 A
When you are shutting down the plant, you are 11 cooling down the system, the RC system.
12 Q
Would this be a procedure that is a cooldown
()
13 procedure that would be in effect at some point in time 14 after there had been a reactor trip as a result of a 15 transient?
16 A
I have not used this procedure.
I can only 17 say that this says that it's a Unit 2 procedure, 18 cooldown.
19 Q
yithout reference to this specific procedure, 20 is it correct that the process of cooldown as you have 21 described it a moment ago would follow a reactor trip 22 as a result of a transient?
23 A
To the best of my recollection, yes, sir.
24 Q
In other words, after a transient occurs, 73 V
25 one of the things you try to do is get the plant back
1 zechman 688
(_j 2
to normal conditions as part of a cooldown process, 3
correct?
4 A
Following a trip, if you are shutting lll 5
the plant down, you are going to cool it down, it's 6
a cooldown procedure.
9 7
Q It's a procedure on the way to shut down 8
after a trip, correct?
9 A
Yes, sir.
I was referring to the general 10 title cooldown, not this particular procedure.
11 12 I understand.
Now, I would like you to 4
12 look at the specific procedure.
Particularly page 3.0
()
13 paragraph 2.1.1, which reads under the heading " Limits 14 and Precautions," " Reactor coolant temperature / pressure 15 and cooldown rates shall be maintained within the 16 limits specified in Figures 3.4-2 and 3.4-3 of 17 TS 3.4.9.1.
Refer to Figures 1 and 2 attached."
l 18 Just a preliminary question.
Does TS 19 refer to technical specifications?
l j
20 MR. MacDONALD:
You are asking for his 21 recollection?
O 22 MR.'FISKE:
His understanding of l
l 23 A
To the best of my recollection, it is.
24 Q
Would you look at Figures 1 and 2 that
(~g l
\\_)
l 25 are part of this.
l
1 Zechman 689 2
A 1 and 2?
3 Q
Let's start with Figure 1.
4 Do you have Figure 1 in front of you?
h 5
A Yes.
g 6
Q That is a heat up/cooldown curve?
7 A
That's its title.
8 Q
Isn't that the same curve that we were just 9
looking at a moment ago which was part of the decay 10 heat removal procedure?
11 A
I haven't compared them.
12 Q
Do you want to take a minute and do that.
13 Before you do that, Mr. Zechman, was it your under-14 standing before the accident that there were different 15 heat up/cooldown curves appliable to different 16 procedures?
17 A
Not to the best of my recollection.
18 Q
I would like to turn to page 6.0 and i
i 19 paragraph 2.2.9, which reads, "If any safety equipment 20 defined in technical specification 2.1 and 2.2 is 21 exceeded, the shift supervisor shall notify the 22 station unit superintendent.
The reactor shall be t
23 placed in hot standby within one hour.
The licensee 24 shall notify the Commission, review the matter and I
l 25 record the results of the review including the cause r
l l
1 Zechman 690 2
of the condition and the basis for corrective action 3
taken to preclude reoccurrence.
Operation shall not 4
be resumed until authorized by the Commission."
lll 5
The safety limit defined in technical specification 6
2.1 refers to the same technical specification that I 7
read to yoh earlier, does it not, concerning safety 8
limits for the reactor core?
9 A
I don't recall the numbers -- I don't recall 10 whether 2.1 11 Q
Would you look at it so there is no question.
12 It's B&W 572.
()
13 MR. MacDONALD: You are' asking now his 14 recollection of these things prior to the 15 accident.
Not just comparing these documents?
16 MR. FISKE:
Sure.
His understanding prior 17 to the accident when this refers to technical 18 specification 2.1, was he aware prior to the 19 accident of any technical specification 2.1 20 other than the one that has been previously 21 shown which he now has in front of him.
22 A
Assuming that I have the current tech spec 23 that was associated at the time this procedure was in 24 effect, these two correspond.
25 Q
It says in this paragraph, "The licensee
1 Zachman 691
)
2 shall notify the Commission."
3 What commission was that referring to?
4 A
The NRC, Nuclear Regulatory Commission.
lll 5
Q Were you f amiliar with this requirement 6
of the unit cooldoen procedure prior to the Three Mile 7
Island accident?
8 A
As I said, I don't recall this procedure.
9 Q
Do you recall any part of any procedure 10 which required you to notify the Commission if safety 11 limits were exceeded?
12 A
I certainly recognize and understand
()
13 that when safety limits were exceeded we notified 14 the commission.
15 Q
Wasn't it your understanding, Mr. Zechman, 16 that not following a heat up/cooldown curve could 17 result in a violation of a safety limit which would 18 require reporting to the NRC7 19 A
I don't recall.
20 Q
Going back, Mr. Zechman, to the decay heat l
21 removal procedure, do you have that in front of you?
22 A
2102-3.37 23 Q
Yes.
24 A
Yes, sir, I do.
i
(
25 Q
I would like to direct your attention
1 Zechman 692 2
to page 4.0, paragraph at the top of the page, 2.1.7, 3
which reads, "During decay heat removal by natural 4
circulation maintain TH" that's temperature in the lll 5
hot leg?
6 A
Normally TH refers to temperature in the 7
hot leg.
8 Q
"30 degrees Fahrenheit below the 9
saturation temperature corresponding to pressurizer 10 pressure in order to prevent boiling in the hot legs."
11 Do you see that?
12 A
I see that.
(
13 Q
What was your understanding of the purpose 14 of that re quiremen t?
15 A
I don't recall using this procedure, so I 16 have no recollection of what that means.
17 Q
Do you know what boiling in the hot legs 18 refers to in that procedure?
19 A
No, sir, I do not.
I have no recollection l
20 what that means.
21 Q
What do you understand the saturation 22 temperature corresponding to the pressurizer pressure 23 to mean?
24 A
You are asking me to interpret that 25 sentence, the saturation temperature l
1 Zechman 693 O
\\ _)\\
2 MR. MacDONALD:
Recollection again prior s
3 to the accident as to what those words meant.
4 THE WITNESS:
In relationship to this lll-5 procedure?
6 Q
Generally.
7 MR. MacDONALD:
Just a second.
Can we 8
have the question so we can have an understanding 9
of what you are talking about.
The witness is 10 confused.
He was asked quesitons about this 11 paragraph relating to what he understood the 12 words meant.
(
13 Q
Before the accident, Mr. Zechman, did 14 you understand what boiling in the hot legs was?
15 A
No recollection of what the terminology 16 referred to.
17 Q
You mean if somebody had come to you 18 in the course of a transient and said, "Mr.
- Zechman, 19 I thinn we have got a problem," and said, "We have 20 got boiling in the hot legs," you wouldn't know what 21 he was talking about?
l 22 A
I could interpret what he is saying.
I am l
23 not going to interpret what the meaning of this was.
24 Q
what was the concept, boiling in the hot gS V
25 legs, as you understood it?
1 Zechman 694 1
()
2 A
I didn't understand before the accident.
3 I said I would -- I said the only thing I would do if 4
you asked me was to speculate what that means, and lll 5
that's pure speculation.
6 Q
Go back to the question I just asked and 7
if someone came up to you and said "We have got a 8
problem, we have got boiling in the hot legs," would 9
you have understood what he was talking about?
10 MR. MacDONALD:
I object to the form.
11 You can answer.
12 A
I am afraid I would have to ask him to
()
13 define what he is talking about.
14 Q
Were you familiar with the concept of 15 saturation temperature corresponding to pressurizer 16 pressure?
17 A
As it refers to the pressurizer?
I 18 Q
Yes.
19 A
Whatever the saturation pressure is for l
l l
20 that -- whatever the saturation temperature is for that 21 pressure.
22 Q
Did'you have any understanding before the 23 accident as to why during decay heat removal by natural
~ 24 circulation, it would have been important to have 25 maintained temperature in the hot leg 30 degrees
1 zechman 695
(
2 Fahrenheit below tea saturation temperature corresponding 3
to pressurizer pressure?
4 A
I don't recall seeing this procedure or lll 5
that statement and, therefore, it would be speculation 6
in interpreting what that means, sir.
7 Q
I am not asking you to interpret a 8
procedure.
I am just asking yo. whether by reference 9
to the procedure or not, did you understand that 10 during decay heat removal by natural circulation, it 11 was important to maintain temperature in the hot leg, 12 30 degrees Fahrenheit below the saturation temperature
()
13 corresponding to pressurizer pressure?
14 A
I have no recollection of that concept.
15 Q
Did you understand it was important to 16 maintain temperature in the hot leg at any degrees 17 Fahrenheit below the saturation temperature cor-
)
18 responding to the pressurizer pressure?
19 A
As it applies to this procedure?
20 Q
No.
21 A
I never used that terminology so -- the 22 answer is I have no recollection.
23 Q
Did you understand that during decay heat 24 removal by natural circulation that it was important 25 to maintain any pressure / temperature relationship?
I
1 Zechman 696 c
p(,)
2 A
There were temperature and pressure 3
relationships but I just don't recall what they were.
4 Q
I am not asking you to give me the specific lll 5
degrees or pounds per square inch, but do you recall 6
that it was important to maintaining certain pressure /
7 temperature relationship?
8 MR. MacDONALD:
Specifically now with 9
natural circulation?
10 MR. FISKE:
During decay heat removal.
11 A
I can only recall that there were 12 temperature considerations that we looked at and O
(_j 13 pressure, but that is as far as I can answer, sir.
14 Q
You did know, did you not, that the 15 pressure / temperature envelope concept that you have 16 described earlier applied to decay heat removal?
17 A
I don't recall.
18 Q
Do you understand that question?
Maybe 19 you would like to have it read again.
20 A
Read it again.
21 (Question read.)
22 A
I don't recall.
23 Q
Earlier, Mr. Zechman, in this deposition (7b) 24 we showed you volume 5 of the final safety analysis LJ 25 report prepared by Metropolitan Edison Company and
1 Zechman 697 rh
(_)
2 submitted to the Nuclear Regulatory Commission in order 3
to obtain an operating license for Unit 2.
4 I would like to show you a section from lll 5
that 5.5.10, pressurizer.
Right under that 5.5.10.1, 6
design basis and it reads, "The pressurizer is 7
designed to provide a capability of maintaining the 8
reactor coolant system at saturation pressure to 9
prevent boiling of the coolant."
10 Do you see that?
11 A
I see that.
12 Q
Were you familiar with that concept before
()
13 the accident?
14 A
I don't recall this one.
15 Q
I am not -- for the moment I am not asking 16 you whether you read this particular part of the FSAL.
17 First I am simply asking you whether you were aware 18 prior to the accident of the concept that is expressed 19 in the sentence that I just read.
20 A
I told you that from a theoretical 21 standpoint I understood that pressure / temperature 22 relationship, that it did not occur to me prior to did not occu'r to me prior to the 23 the accident 24 accident having a saturated or boiling condition in
{)g
\\-
25 the coolant.
1 Zechman 698
\\m) 2 Q
You didn't know before the accident that 3
the pressurizer was designed to provide a capability 4
of maintaining the pressure at a level sufficient to lll 5
prevent boiling in the coolant?
6 MR. MacDONALD:
Are you asking him now 7
to interpret the concept supposed as stated 8
in this FSAL or his recollection of it?
9 MR. FISKE:
Read the question back.
10 (Question read.)
11 A
I understand from a theoretical standpoint 12 that it maintaine.d pressure and'. elevated pressures in a (3
V 13 PWR.
14 Q
That that was done in order to prevent 15 boiling in a coolant, is that correct?
16 A
I told you I never considered boiling of 17 the coolant in the RC system.
18 Q
Did you train your operator in the 19 training program that in accordance with this statement 20 from the Met Ed FSAL to the Nuclear Regulatory 21 Commission describing the design basis of the 22 pressurizer that the pressurizer was designed to 23 provide a capability of maintaining the reactor
(~}
24 coolant system at a pressure high enough to prevent
\\m /
25 boiling in the coolant 7
M 1
Zechman 699 1
2 A
Are you asking me if I trained on this 3
paragraph?
4 Q
On the concept of that paragraph.
llh 5
A I don't recall.
l 6
Q Any of your training programs at Met Ed, did you ever try to describe to the operators what 7
8 the purpose of the pressurizer was?
9 A
Yes, we did.
10 Q
Did you tell them that the purpose of 11 the pressurizer was to keep pressure up above saturation 12 temperature?
13 A
we told them the purpose of pressurizer 14 had several functions.
One as a surge tank, one to 15 maintain system pressure.
4 16 Q
At a certain prescribed level, correct?
17 A
What do you mean by "certain prescribed 18 level"?
19 Q
Didn't you explain to the operators at 20 any point in the training that they received at Met 21 Ed that a purpose of the pressurizer to be sure that 22 pressure was kept up above the saturation point?
23 A
we never discussed, to the best of my 24 recollection, the saturation of the RC system.
25 Q
So you never told the operators that it was
1 Zechman 700
(,)
2 important that pressure be kept up above the saturation 3
point?
4 A
We taught then that the pressure the lll 5
only recollection I have at this point that we taught 6
them that the purpose of the pressurizer was to 7
maintain system pressure and that it accommodated 8
acted as a surge tank to accommodate incoming and 9
outgoing surges and to main'tain system pressure.
10 Q
My question, which I don't believe you have 11 answered yet, did you ever tell them at any point 12 in the training program that by maintaining system
,-(,)
13 pressure that meant that pressure should be maintained 14 above the saturation point?
15 A
I don't recall.
16 Q
Does that meant that your testimony is as 17 you sit here today that you don't have.any recollection 18 of ever teaching them that concept?
19 A
I just don't recall.
20 Q
Do you recall at any time at any part of 21 the training program that you conducted or that you 22 participated in at Met Ed when there was a discussion 23 of maintaining system pressure, any one of the students
(~}
24 asking a question, "Well, gee, what happens if pressure
'<J 25 drops and we can't maintain system pressure?"
1 Zechman 701
( '
2 A
The concept has always been on maintaining 3
pressure and level.
I don't recall considering that, 4
sir.
lll 5
Q So it's your testimony, and I think this 6
is the last question I have on this, that at no time 7
in the training program, to the best of your 8
recollection, as you sit here today, where the 9
operators taught what would happen if system pressure 10 was not maintained?
11 A
other than the relationship of the 12 pressure / temperature envelope relative to DNBR.
()
13 Q
They were never told what would happen 14 if the pressure dropped even lower than the 15 pressure / temperature relationship that would affect 16 the DNBR, is that correct?
17 A
Read that back.
18 (Question read.)
19 A
I don't recall it.
20 Q
was training given'to the operators at 21 Met Ed during any period of --
22 MR. FISKE:
Withdrawn.
23 Q
Did you believe during the period of time 24 while you were in charge of the training program at 25 Met Ed that it would be important for the operators
1 Zechman 702 2
to be able to determine during the course of a 3
transient whether or not saturation had occurred?
4 A
I already testified that prior to the lll 5
accident saturated RC system just didn't occur to me, 6
sir.
7 Q
So the answer to my question is no.
If 8
you would like to hear it again.
9 A
Please.
10 (Question read.)
11 A
It did not occur to me prior to the 12 accident, I am sorry.
()
13 Q
Let me show you a document which has 14 already been marked as B&W Exhibit 419 and which is a 15 copy of a letter from Mr.
E.
G.
Ward, senior project l
16 manager at B&W to Mr.
L.
C.
Lanese, GPU Service 17 Corporation, Parsippany, New Jersey.
Subject Three 18 Mile Island Nuclear Station Unit No.
2, ECCS small 19 break analysis.
20 Do you have that document in front of you?
21 A
Yes, sir.
22 Q
Did you ever see this document prior to 23 the Three Mile Island accident?
(~s 24 A
I don't recall seeing this document.
(_)
25 Q
Did anyone within the training department
-,r.
---g m._
1 zechman 703 2
receive from Mr. Lanese or anyone el'se at GPU Service 3
Corporation the ECCS small break analysis which was 4
sent by B&W to Mr. Lanese, with this letter?
lll 5
A I can't speak for other people in my 6
department, whether they personally have seen this or 7
not.
I don't recall seeing i t.'
8 Q
Look at the second paragraph of the 9,
letter from Mr. Taylor to Mr. varga, do you see that?
10 A
Yes, sir.
on the cover page, July 16, 19787 11 Q
Yes, which is one of the pages in this 12 exhibit.
This is a letter by which Mr. Taylor, manager 13 of licensing at B&W, forwarded to the Nuclear 14 Regulatory Commission the same ECCS small break 15 analysis that they sent to Mr. Lanese at CPU Service 16 Corporation.
17 MR MacDONALD:
I object if you are 18 asking him to --
19 MR. FISKE:
I am just stating that.
Trying 20 to save a little time.
21 Q
The second paragraph of this letter says, 22
" Break sizes of
.04,
.055,
.07,
.085,
.10 and.15 23 feet are examined.
These attached analyses, along
'^s 24 with the break analysis in 'ECCS analysis of B&W's
]
25 177FA lowered loop NSS,' constitute a complete t
t 1
zechman 704 2
spectrum of small break analyses which we believe 3
to be wholly in accordance with 10 CFR 50.46 and 4
10 CFR 50 Appendix
'K.'"
llh 5
There is attached to the NSS analysis 6
a Figure B-3 which is a graph reflecting pressure f
7 versus time for each of the break sizes referred to 8
in the paragraph that I just read.
9 I would ask you whether or not, Mr.
- 10 zechman, you were ever made aware by anyone at GPU 11 Service Corporation or anyone else within the Met Ed 12 organization that analyses had been conducted of various
()
13 break sizes and that a calculation will be made of 14 the expected pressure versus time resulting from 15 these of those break sizes?
16 A
You are talking about what my recollection 17 was prior to the accident?
18 Q
Yes.
19 A
My only recollection at this time prior 20 to the accident that there was an analysis done.
That's 21 my only recollection.
22 Q
And theunderstanding that you had back 23 before the accident as acting supervisor or as 24 supervisor of training, is this the kind of informa-25 tion you had expected that GPU was to send to your y-n,,,-
,,v,
,,w--
,n-,,r-r------n.-
-,-a
-.-----,,r
.r,-
,,,_ man-----m-,..
-n
~
1 Zechman 705
(_)
2 training department if they received it?
3 MR. MacDONALD:
You are talking about in 4
the form itself here?
lll 5
MR. FISKE:
The substance.
I don't know 6
if it was the precise language.
7 A
Sir, I would have to evaluate all of the 8
information that's given here and make some rational 9
determination.
In speculation -- it would be 10 speculation at this time.
11 Q
Was it important to you during the period 12 of time you were in charge of the training department "N
q_)
13 that you have as much information as possible to 14 communicate to your operators about the expected 15 consequences which would flow from a variety of break 16 sizes which could produce a loss of coolant accident?
l 17 A
It was important for me to have information l
18 on small break operating philosophy that an operator need 19 to know'how to recognize it and the results of those 20 different things.
21 Q
As you understood it prior to the accident, 22 would and which showed the changes in pressure over 23 a time that would be reflected in small breaks of
(~)
24 various sizes, be.useful to the operators in V
25 diagnosing a transient?
1 zechman 706 O'
2 MR. MacDONALD:
You are asking if he 3
thought of that prior to the accident?
4 MR. FISKE:
Yes, with that kind of lll 5
information.
6 A
I didn't consider it at the time so 7
Q You didn't?
You said you don't remember 8
seeing this report.
I understand that.
I am simply 9
asking you whether in your function as supervisor of 10 training or acting supervisor, did you understand 11 that there could be different changes in pressure over 12 time resulting from small breaks of different sizes?
13 A
To the best of my recollection, I had 14 that kind of an understanding.
15 C
And did you believe it would be useful q
16 for the operators to know in diagnosing a transient 17 what the expected changes in pressure over time would 18 be for different sizes of small breaks?
19 A
Since I didn't have that information at 20 hand at that time, I don't know that I considered that 21 at that time.
22 Q
You mean it never occurred to you as head 23 of training that there might be different changes in 25 breaks?
k
1 Zechman 707
/~T
'\\ //
2 A
I don't recall what my considerations were 3
at that time.
4 Q
Did you understand that every break in the llh 5
primary system boundary, no matter what size, would 6
Produce exactly the same change in pressure over time?
7 A
I don't know what I considered at that 8
time.
I don't recollect what my thinking was at that 9
time.
10 Q
were the operators in the training 11 department trained on the fact that there could be 12 different changes in pressure over time resulting
[~}
(_/
13 from different break sizes?
14 A
I don't recall.
15 Q
To your knowledge, today as you sit here, 16 do you have any recollection that such training was 17 in fact given?
18 A
I recall there was small break training 19 given, but I don't recall today all the details of that 20 training.
21 Q
Did you also receive -- you also received 22 training, did you not, in the course of getting your 23 license on Unit 17
,CT 24 A
Yes, sir.
V 25 Q
In the training that you received as a
1 Zechman 708 O-2 student at the same time you were head of the training 3
department, did you get training on the fact that 4
different break sizes would produce different changes llh 5
in pressure over time?
6 A
I just don't recall.
7 (Recess.)
8 BY MR. FISKE:
9 Q
Mr. Zechman, prior to the Three Mile Island 10 accident, were you aware of any provisions in any 11 operating procedure or technical specifications regarding 12 the pressurizer level?
13 A
I was aware that they existed, that they 14 existed in tech specs and limits and precautions.
15 Q
What did you understand those ground rules 16 were?
17 A
I can only recall one of them today.
That 18 was limit and precautions, there was a statement that 19 says one should not exceed a certain level in the 20 pressurizer under any circumstances except under 21 hydrostatic testing, i
22 Q
What was that level?
l i
23 A
I don't recall the exact number any more.
l
~
24 Q
What was the capacity of the pressurizer?
l 25 A
I don't recall those numbers, sir.
l l
l
1 Zochnen 709
(
2 Q
what was the level prescribed in the 3
limits and precautions in relation to the capacity of 4
the pressurizer?
5 A
I don't understand your question.
O 6
Q You have said you don't remember the level 7
and it was referred to in the technical specifications.
8 You said you also don!t remember the capacity of 9
the pressurizer.
I am not asking you for a specific i
10 number, I am asking what was, without reference to 11 any specific numbers, the relationship between the level 12 that was referred to in the tech specs and the capacity 13 of the pressurizer?
14 A
As I have just mentioned -- the statement 15 I just mentioned relative to the pressurizer had to do 16 with limits and precautions.
17 Q
Not tech specs?
18 A
I don't recall if it's also listed there.
i 19 I just don't recall.
So I was referring to limits 20 and precautions and there was a limit and precaution 21 not to exceed a certain level in that pressurizer, if l
22 I remember correctly, under no conditions except under l
23 hydrostatic testing.
24 Q
What I am asking you in simple terms, was 25 that level halfway up the pressurizer, was it three
1 Zoehnon 710
(
2 quarters of the way up, was it full or was it a 3
quarter?
What was it?
4 A
It was above the halfway point.
I just 5
don't remember the number.
gg 6
Q Did you train your operators with respect-7 7
to that particular section of the limits and 8
precautions?
i 9
A Yes, to the best of my recollection.
10 Q
What did you tell them was the purpose of 11 that particular portion of the limits and precautions?
12 A
What the statement said.
13 Q
The statement simply said do not allow the 14 pressurizar level to go above a certain level other 15 than in hydrostatic testing?
16 A
I believe it says under any conditions 17 except for hydrostatic testing.
18 Q
You remember that specific language?
19 A
That's -- because it became an issue 20 after the accident it is still in my mind.
21 Q
None of these other things that we have 22 been talking about that you don't remember were issues 23 after the accident?
I' 24 A
Certainly they were.
O 25 Q
Just before we took a break, I showed you a j
1 Zochacn 711
^h
[d 2
number of specific procedures and you said you didn't
\\
3 recall whether there was such a procedure.
After the 4
break I started asking you about this one particular 5
subject and without having any document in front of ggg 6
you, you are now quoting specific language of that limit 7
and precaution.
8 A
I can't account for why memory remembered 9
that.
I can't account for it.
10 Q
Let me go back to my earlier question, that 11 you now demonstrated that you remember the specific 12 language of this one particular paragraph, and as you
(~'T 13 have described it -- I would say parenthetically, if
\\_)
14 you want to look at it now, I will be happy to show it 15 to you.
I don't mean to restrict you to oral memory 16 word for word for that whole section.
As you have 17 described it, it prescribed -- you described it that 18 pressurizer level should not exceed a certain level 19 under any circumstances except hydrostatic testing.
20 A
To the best of my recollection, that's what 21 the limits and precautions say.
22 Q
so we don't have any question about it, 23 I would like to show you -- I believe this has already 24 been marked.
I am sure it's been marked already and
/~(xl 25 instead of taking the time to look for the specific
1 Zachman 712 n
(%j) 2 exhibit number, why don't I just if this is agreeable 3
to Mr. MacDonald -- to refer to the fact that this has 4
been previously marked as a GPU exhibit and leave it 5
blank until we find out what it is and fill it in ggg 6
later.
7 MR. 1:acDON ALD :
That's fine.
8 Let's refer to it as to its title.
9 MR. PISKE:
A fairly large document 10 entitled "Three Mile Island Nuclear Station 11 Unit No. 2 Operating Procedure 2101-1.1 Nuclear 12 Plant Limits and Precautions," and this is a
^
13 document that contains 137 pages.
(' ))
14 Q
The page I would like to refer you to is 15 number 17 which says 16 A
Are you on page 17?
17 Q
Yes.
At the bottom,.this all refers to I
I 18 the pressurizer.
Down at the bottom it says, " Limits l
19 and Precautions 1.2-01 Absolute Maximum pressurizer l
l l
20 level at any time the reactor is critical is blank i
21 inches," and then on the right-hand side it is filled 1
22 in 385.
Then I will go on to the next page where 23 item.c4 says, "The pressurizer must not be filled j
24 with water to indicate its solid conditions blank l
l 1
'~#
25 inches ati y time eheept when required for systeratic l
l
1 zochsan 713 i
I~
( )/
2 hydrostatic test."
Number on the side is 400 inches.
3 Is that what you were referring to, the 4
limits and precautions?
5 A
I believe so.
O 6
Q Rather than the one on the previous page 7
which says " absolute maximum pressurizer level at any 8
time the reactor is critical is 385 inches"?
g A
I recall both of those.
The one I was 10 referring to was item 4.
11 Q
Did you understand in four separate 12 paragraphs of this particular section two different
(}
13 maximum pressurizer levels were prescribed?
14 A
The one I think has a note on page 17 15 that defined the reasoning behind the 385 inches.
The 16 other one the only recollection that I have that was 17 900 that was quoted when it was described when the 18 answer to the question, "Why don't yce want to maintain 19 pressurizer level in the pressurizer and not go solid?"
20 Because we had a maximum limit and precaution.
s 21 Q
Maybe this will help you answer the 22 question I asked be fore, what did you tell the j
23 operators was the reason for not allowing the press
~'
24 pressurizer level not to exceed either 385 inches or 25 400 inches?
b
,,,e
--,--.--,e--
+ - - -
---a---m.
1 Zochaon 714
[)
2 A
The reason for the 385, to the best of my 3
recollection, we did.~ quote the note that's here.
The 4
other one I don't believe a reason was given on the 5
fact that it says do not exceed under any condition 9
6 except hydrostatic testing.
7 Q
What did you understand the reason for 8
havind that 400-inch limitation?
a I don't recall.
9 f6 10 i
Q Did it have anything to do with the t
^'
11 concern about going solid?
p' 12 A
'As I said, in our training at the simulator 3
~)!
when we were discussing that, that was a number which 13 14.
was usually quoted as a reason why you didn't want to i
15 go solid.
16 Q
You understood, did you not, Mr. Zechman, 17 before the accident-that the system would not be 18 considered solid if there was saturation in the reactor t
19 coolant system?
20 A'
Repeat that question.
21 (Record read.)
l 22 A
I told you before that I never considered 23 prior to the accident that saturated RC system.
24 Q
Let me read you from the testimony of Mr.
25
'Toole, the same Mr..Toole whose testimony we read
1 Zochman 715 2
to you yesterday.
This is his testimony in this 3
case.
4
" Question:
What is your understanding 5
of the term ' solid condition' with reference to a ggg 6
7
" Answer:
Solid system is what we used to 8
have when we hydroed the system.
We will open all 9
vents and the coolant system would be solid.
Sometime 10 the condition of having the pressurizer instrument 11 off scale above 400 inches to be off scale high would 12 be referred to as being solid.
~
13
" Question:
Does your definition of solid 14 system include the possibility of voids in the 15 reactor coolant system?
16
" Answer: No.
None other than what would 17 be in the top of the pressurizer."
18 That's from page 1060 of Mr. Toole's 19 deposition and I would also like to read to you from 20 page 287 of Mr. Floyd's deposition.
21
" Question:
Was it your understanding 9
22 prior to the accident that if the reactor coolant 23 system had a bubble, not in the pressurizer, but
~
24 someplace else, that it could be described as a solid O
25 system?"
---,--,-n-,
.--r.,c.
-n
1 Zachman 716
(
2 Mr. Seltzer, attorney for Mr. Floyd, "In 3
other words, the pressurizer is full to the roof and 4
there is a bubble someplace else?
ggg 5
"Ms. Wagner:
Right.
6
" Answer:
Would I before the accident 7
have described that as a solid system, is that the 8
question?
9
" Question:
Yes.
10
" Answer No, I would not have described 11 that as a solid system."
12 Having heard the testimony of both Mr.
13 Floyd and Mr. Toole, does that in any way help you 14 recall whether you had the same view before the accident 15 that they did?
16 A
I guess I can't speak for them, but I 17 certainly did not have that understanding prior to I
18 the accident.
i 19 Q
Did you believe before the accident that l
20 the system would be solid even though there was 21 saturation in the reactor coolant system?
22 A
I never considered saturation in the 1G reactor coolant system.
24 Q
Do you know where, from what source, Mr.
25 Toole and Mr. Floyd would both have received l
l l
1 Zechman 717
(
2 information or training which led them to the con-3 clusion that the system would not be solid if there 4
were voids in the reactor coolant system?
5 A
I didn't discuss it with either of them.
ggg 6
I am not knowledgeable of other than what you quoted 7
to me or the reasoning for them saying that.
8 Q
Did you understand that the 400-inch 9
limitation or the 385-inch limitation would apply even 1.
10 if the operators knew that the system was not solid?
11 A
I don't know that in our discussions prior 12 to the accident that that ever became a point of
()
13 consideration.
14 Q
what did you understand going solid meant 15 before the accident?
16 A
As the terminology used in the training 17 on simulator and our ownsit meant continuing rising 18 level in the pressurizer from going out the top.
19 Q
You mean if the pressurizer was full of I
20 w a t e r ', that meant 21 A
With a full RC system including up through O
22 the pressurizer.
23 Q
what do you mean by a full RC system?
l l
24 A
A completely solid system.
25 Q
I asked what a solid system was and you i
l l
1
l zechman 718
('
\\-s' 2
said a system which is full.
And then I asked you what a full system and you said solid.
3 4
MR. MacDONALD:
Full of what?
5 A
Full of water.
6 Q
If the system in fact was not full of 7
water but was full of part water and part steam, it 8
would not be solid, is that correct?
9 A
As long as we put it in the reference that 10 not solid and not steam, we are talking about the 11 pressurizer.
12 Q
What I am talking about is the part of the
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13 system outside the pressurizer for the moment.
14 A-Never considered that.
15 Q
But your definition of solid was a condition 16 in which the system was full of water, correct?
17 A
Yes.
18 Q
If it is not full of water, then it is not 19 solid, right?
i 20 A
Yes, but I am saying, I am putting 21 boundary conditions on where it is not solid, I am saying 9
22 not solid by virtue that there is a steam space in 23 the pressurizer.
l f~')
l 24 Q
Just to go back to basics.
If the reactor
- x. /
25 coolant system itself was full of water, but the l
l l
m mb
1 Zechman 719 f~)
~/
2 pressurizer is only partly full of water and part 3
steam, that is not a solid system, correct?
4 A
In the light that that term was used.
lll 5
Q Yes.
That's the way it's supposed to be 6
during normal operations?
7 A
Yes.
8 Q
so your testimony, I believe, a moment 9
ago that a solid system is a system where not only 10 the reactor coolant system itself is full of water 11 but also the pressurizer is full of water, correct?
t 12 A
That's my recollection.
Yes, that's correct.
)
13 Q
If the reactor if the pressurizer is 14 full of water but the reactor coolant system is not, 15 the system is not solid, isn't that correct?
16 A
I never considered that.
17 Q
Whether you considered it or not, if your 18 definition of solid is a situation where both the 19 reactor coolant rystem and the pressurizer is full of 20 water, if either one of them is not full of water then 21 it is not solid?
22 A
But in the definition of the terminology 23 that we used it in our training, not being solid was n
24 always -- was in reference to then only and only to J
25 the pressurizer.
It did not consider not being solid
1 Zechman 720 2
below the pressurizer or in the RC system.
3 Q
That is because you believed that 4
pressurizer level was an accurate measure of cyctem llh 5
inventory?
6 A
I think I already testified that our 7
training focused and B&W's training focused on if you 8
maintained pressurizer level you were assured 9
satisfactory inventory.
10 Q
What was the problem with being solid?
11 A
I just don't recall.
I know there was a real 12 important reason but I j u st can't recall it right now.
13 MR. FISKE:
I think what I suggest is 14 we break for lunch.
I will go back through 15 my notes and maybe we can shorten this.
I think 16 we can finish.
17 (Whereupon, at 12:45 p.m.,
a luncheon 18 recess was taken.)
19 20 Ig>
I 22 23 C) 25 l
1 721 2
AFTERNOON SESSION 3
2:40 p.m.
4 o0o lh 5
RI CH ARD W
Z E CHMAN having 6
been previously duly sworn, resumed and testified 7
as follows:
8 EXAMINATION (Continued) 9 BY MR. FISKE:
10 g
Mr. Zechman, are you aware of the fact 11 that within the last year two operators at Met Ed were 12 found to have cheated on certain examinations they took 13 during the course of the Met Ed training program?
(
14 A
I was aware of that.
15 g
Which particular examinations?
16 A
Pardon?
l I
17 g
which particular examinations?
18 A
To the best of my recollection, it was 19 the relicensing examination.
20 g
During the period of time that you were 21 head of the training department, did you have specific 22 procedures in effect to prevent that kind of cheating?
23 MR. MacDONALD:
What kind of cheating.
24 MR. FISKE:
The kind of cheating that s.-
25 went on by those two operators.
c
1 Zechman 722 2
A I haven't been in conversation with the 3
investigating committee nor am I aware of all the 4
facts surrounding that cheating other than the fact ll 5
that it existed.
6 Q
You were aware that cheating existed, 7
correct?
i 8
A Yes.
9 Q
The cheating related to examinations that 10 were taken in the course of the Met Ed training 11 program?
12 MR. MacDONALD:
Before or after?
(
13 MR. FISKE:
After.
14 A
That was the NRC exam to the best of my 15 recollection, after the accident.
16 Q
Did you have procedures in effect at i
17 the training ' department when you were in charge of 18 it to prevent cheating on NRC exams?
19 A
During the administration of either 20 exams for requalification or entry exams, there 21' was a separation of students and a proctor.
22 Q
Did it ever come to your attention at 23 any time while you were running the training depart-24 ment that any operator was suspected of having 25 cheated?
i i
1 zechman 723 (D
k/
2 A
on any exam?
3 Q
Yes.
4 A
In one case.
llh 5
g was there an investigation made?
6 A
Yes, there was.
7 Q
What was the result of that?
8 A
The result of that, I can only speak from 9
the end I observed, I was not in again total 10 conference with the individual and senior management.
11 I know one of the results of that particular cheating 12 incident, the individual was relieved from duty, sent
(%
(_,)
13 to the training department for a concentrated training 14 effort.
15 Q
That is the only time that you now 16 recall where anyone was suspected of having cheated 17 on an examination?
18 A
To the best of my recollection, sir.
19 MR. FISKE:
That's all I have.
20 MR. MacDONALD:
Due to the length of time 21 he has testified, we are not going to get done 22 cross this af ternoon so let's knock off here until 23 some mutually convenient time to reconvene here 24 for this examination of Mr. zechman.
25 MR. FISKE:
If you choose not to start
1 Zechman 724 O
2 this afternoon, I am not in a position to 3
require you to do it.
I want to make it clear 4
that we don't consent to this, k
5 MR. MacDONALD:
Whether or not you consent, 6
I am saying that Mr. Zechman has testified for 7
many days and is tired and exhausted at the end 8
of the day, on the basis of that it's not in the 9
best interest of anybody and not fair to anyone 10 if we start cross-exa-ination at this time a
11 and to the extent that he is leaving today, I
, 12 don't think it would be concluded anyway and since n
(/
13 we have scheduled and rescheduled direct and 14 cross-examinations during the case, I think 15 that that's a practice we will continue.
16 MR. FISKE:
I say there is no way we can require you to proceed this afternoon.
I want l
17 18 to make it clear that we are not in agreement 19 with what you have just said.
20 MR. MacDONALD:
That's fine.
I can't make l
21 you agree to anything, Mr. Fiske.
22 MR. FISKE:
We also would like to finish 23 this up as quickly as possible and we would be 24 happy to do it any day next week.
25 MR. MacDONAL:
As we have done in i
1 zechman 725
(-
2 scheduling and rescheduling direct examinations, 3
as soon as we can with everybody's schedules, 4
mine and the witness' get back together again lh 5
to finish this as expeditiously as we can, and 6
that's what we will try to do and we will try on 7
every deposition.
It doesn't serve the purpose 8
this afternoon, not being able to complete it 9
MR. FISKE:
I want to make it clear.
We are 10 ready to go now, we are ready to go Monday, we are
'll ready to go Tuesday, we are ready to go Wednesday, 12 and if you want to defer it beyond that.
13 MR. MacDONALD:
Let me say there are 14 many different times in the scheduling of 15 depositions and rescheduling direct testimony 16 when we are ready to go ahead and you are not l
17 and you can't and we try to work this out to 18 mutually convenient times, and I think we will l
19 continue to do that throughout the case.
20 That's one of the reasons that we talk 21 on the telephone and try.to get the dates 22 convenient for everyone.
l 23 There have been various times when we are i
24 ready to go on with direct and you have not l
25 and vice versa.
I appreciate your telling me i
l
1 Zechman 726 O
2 that you are available Monday, Tuesday and 3
Wednesday and I will take that into consideration.
4 MR. FISKE:
We are available on those dates llh 5
and we are available at the earliest opportunity 6
five minutes from now to what you think is an 7
appropriate date if you don't agree to those.
8 MR. MacDONALD:
Okay.
9 MR. FISKE:
Thank you, Mr. Zechman.
10 (Time noted:
1:45 p.m.)
11 12 13 14 15 16 17 18 19 20 til 22 23 25
l 1
7 2 7.
(v)
CERTIFICATE 2 ;,
3li STATE OF NEW YORK
)
- ss.:
COUNTY OF NEW YORK
)
4 4
I, CATHERINE COOK l
, a Notary Public of the State of New York, do hereby certify that the continued deposition of 7
i RICHARD W.
ZECHMAN was taken before 8
me on March 26, 1982 consisting of pages 642 through 726 I further certify that the witness had been previously sworn and that the within
/V) transcript is a true record of said testimony; t
13 That I am not connected oy blood or marriage with any of the said parties no" lo, I
interested directly or indirectly in the matter l
in controversy, nor am I in the employ of any of the counsel.
18 IN WITNESS WHEREOF, I have hereunto set my 19 hand this le;Y day of GM 1982.
20 t
21 22
,g l
9 23
-rL T uva, hrt CATHERINE COOK i
n
,,/
l 25 l
.I l
March 26, 1982 728 I NDEX Witness Page Richard W.
Zechman 644 o0o EX H I B IT S B&W FOR IDENTIFICATION PAGE 571 Collection of pages captioned 665
" Nuclear Energy Training Instructor's Guide Plant Performance."
572 Section 2.0 of the Technical 665 Specifications for TMI Unit 2, 573 Unit 2, Operating Procedure 668 2102-3.3, Decay Heat Removal Via OTSG."
I o0o l
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