ML20072H810
| ML20072H810 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 04/29/1982 |
| From: | Zechman R GENERAL PUBLIC UTILITIES CORP. |
| To: | |
| References | |
| TASK-*, TASK-01, TASK-04, TASK-1, TASK-11, TASK-4, TASK-GB NUDOCS 8306290753 | |
| Download: ML20072H810 (187) | |
Text
. -_.
729 r's (v)
UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK
x GENERAL PUBLIC UTILITIES CORPORATION, JERSEY CENTRAL POWER & LIGHT COMPANY, METROPOLITAN EDISON COMPANY and cb PENNSYLVANIA ELECTRIC COMPANY, H
Plaintiffs, 80 Civ. 1683 (R.O.)
-against-THE BABCOCK & WILCOX COMPANY and J.
RAY McDERMOTT &
CO.,
INC.,
Defendants.
x O
continued deposition of Plaintiff
(
GENERAL PUBLIC UTILITIES CORPORATION, by RICHARD W.
ZECHMAN, taken by Defendants pursuant to adjournment, at the offices of Davis Polk & Wardwell, Esqs., One Chase Manhattan Pla:a, New York, New York, on Thursday, April 29, 1982, at 9:00 o' clock in the forenoon, before Nancy Rudolph, a Notary Public within and for the State of 9
l B306290753 820429 DOYLE REPORTING. I N C.
PDR ADOCK 05000 CERTIFIED STENoTYPE REPCRTERS 369 LexlNGToN AVENUE WALTER SH APIRQ. C.S.R.
New YomK. N.Y.
10017 CHARLES SH APIRO, C.S.R.
TatspwoNe 212 - 867 8220
1 730 l
\\s' 2
APPe aran ce s:
3 KAYE, SCHOLER, FIERMAN, HAYS & HANDLER, ESQS.
Attorneys for Plaintiffs 4
425 Park Avenue New York, New York 5
By:
STEVEN GLASSMAN, ESQ.,
6 of Counsel 7
8 DAVIS POLK & WARDWELL, ESQS.
9 Attorneys for Defendants One Chase Manhattan Plaza 10 New York, New York 11 By:
ROBERT B.
FISKE, ESQ.,
of Counsel
.12
~
13 14 Also Present:
15 SUSAN HANSON 16 A.
JULIET NEISSER 17 18
.19 l
20 g
21 22 t
23 25 l
1 731 m
(_)
2 RI CHARD W.
ZE CHMAN, having 3
been previously duly sworn, was examined and 4
testified further as follows:
th 5
EXAMINATION (continued) 6 BY MR. GLASSMAN:
7 Q
Mr. Zechman, in his direct examination 8
of you, Mr. Fiske asked you a number of questions 9
regarding your responsibilities during the period 10 when you held the title Acting Supervisor of Training 11 an d then Supervisor of Training.
I am going t'o ask you 12 a number of questions on cross-examination about that
()
13 period, but before we go into that period, I would like 14 to ask you some questions about the earlier positions 15 and responsibilities you had with Metropolitan Edison 16 in order to have a clearer picture of your 17 responsibilities as they evolved.
Mr. Fiske asked a 18 number of questions regarding the period when you were 19 supervisor of training,and regarding earlier periods 20 as well; sometimes the time periods went back and forth 21 and it was somewhat unclear.
I am going to try to be (gg 22 chronological.
I would like you to keep in mind the l
23 precise time period so the testimony will be very clear.
l 24 MR. FISKE:
My only objection to that is h
\\v 25 the part where you said at times my questions
1 Zechman 732 O
\\/
2 were unclear as to the time period.
I think my 3
questions were very clear as to the time period 4
covered by each question.
5 Q
I would like you to first take a look once 6
more at what was previously marked as B&W 554, which 7
is your resume.
I would like you to take a look at 8
page 2, please, and in particular the section entitled September 1969 to October 1973."
In that 9
" Met-Ed 10 section there appears the statement, " Responsible for 11 organizing the Training Department and the 12 administration of the Unit I training programs under I\\m) 13 the direction of the Station Superintendent."
14 Could you describe for us just exactly what 15 your responsibilities were in that time frame?
16 A
Yes, at that time I reported to Three Mile l
17 Island nuclear station and reported to Jack Wise, the 18 station superintendent.
At that particular time, the 19 training program for the first cadre of reactor 20 operators, auxiliary operators and rad techs for Unit 1 21 was in progress.
My responsibilities at that time were qg 22 to supervise the continuation of the training program, 23 to maintain the records of all the training that was f')
24 being accomplished, including the progress of each v
25 student, to keep the station superintendent informed l
1 Zechman 733
(~)
j
\\/
2 of the progress of the program, to coordinate and 3
organize the flow of the training program, that is, 4
including the assignment of instructors and to 5
interface between the students.and the union for any 6
problems that may arise in that area.
7 Q
Can you identify for us what precise 8
programs were in effect during that time frame, 9
September 1969 to October 19737 10 A
That was what was referred to as the 11 cold licensing training program for the Unit 1
.12 operators, auxiliary operators and rad techs.
(3
\\_)
13 Q
What are they, cold license programs?
14 A
I should clarify that.
The rad techs were 15 sitting in in a portion of that program on the basic 16 fundamentals and some of the systems that were 17 related to their needs.
This was not to imply that 18 they were getting a license nor did the auxiliary 19 operators intend that they get a license, but they 20
- sre getting the same in-depth training as the 21 operators at that time.
[g 22 Q
what is a cold license program?
23 A
That is a training program that is given 24 to operators who are going to be operating a station 25 which is not yet finished in construction or operating.
1 Zechman 734 (7
(_),
2 Q
I believe you just testified that AO's w uld sit in on the cold license program.
By AO's 3
4 are you referring to auxiliary operators?
5 A
That's correct.
6 Q
In this time frame, September 1969 to 7
October 1973, was there a separate program for 8
training AO's?
9 A
No, at that time they received the same 10 in-depth training as the operators did.
11 Q
Your resume, B&W 554, says that you were 1
12 responsible for organizing the training department.
()
13 What did you mean by organizing?
14 A
By organizing I meant that I had to 15 insure that instructors were available to teach the 16 various subjects that were taught during that time, 17 to insure that the flow of the schedule continued, 18 to iron out any scheduling problems or availability 19 of ins'tructors on a particular day.
20 Q
Your resume also says that you were 21 involved in administration of Unit 1 training programs qgg 22 during that period.
23 What did you have in mind by the word 7-24
" administration"?
(_)3 25 A
By administration I was overseeing the
1 Zechman 735
,m
()
2 conduct of the training program, maintaining the 3
rec rds.
At times I would audit the classroom 4
instruction and report back to the superintendent on 5
the progress.
6 Q
In your last answer, you just said that 7
you were involved in overseeing the conduct of the g
program.
What did you mean by the word " overseeing"?
9 A
Overseeing means that the program was 10 continuing, insuring that instruction continued as was 11 scheduled, as I just mentioned, maintain the records.
12 If students were having problems such as if they had O) 13 failed on the exams, I would interface with them and (s_-
14 make sure that the superintendent was aware of any of 15 those kinds of problems.
16 Q
You also stated in your testimony a few 17 moments ago that you audited the classes.
What did you 18 mean by " audit"?
t 19 A
By audit, I would sit in and listen to the l
20 lecture that was being presented.
I would look at 21 the material that was being presented and listen to l
22 the interface between the students and the instructor 23 and insure that it was continuing in a smooth manner.
24 Q
You said there was a cold licensing v
i 25 program in that period; is that correct?
A That's correct.
1 Zechman 736
(~)/
x--
2 Q
Was there a hot licensing program?
3 A
No, sir'.
4 Q
Could you tell us why not?
5 A
Well, hot licensing training program 6
refers to training program for personnel for operators 7
or SRO's who are going to be operating a plant that 8
is already in operation.
9 Q
In this time period, was there a plant 10 already in operation?
11 A
No, sir.
,12 Q
was there a requalification program, a (Q,j 13 requalification training program during this period?
14 A
No, sir.
15 Q
Why was there no requalification program?
16 A
A requalification program is a program 17 that was later defined by the NRC after the 18 construction and operation of the TMI Unit 1 facility.
I l
l 19 The requalification program was for refresher training 20 and continuation of training of individuals that qg 21 are licensed on a year-after-year basis.
22 Q
During the period September 1969 to October 23 1973, there was no requalification training program;
(~N 24 is that correct?
%Y 25 A
That's correct.
1 zechman 737
(/
i q.
2 Q
Was there any simulator training during 3
this period?
4 A
Somewhere in that period the control room k
5 operators were sent to the simulator for cold license 6
training on the simulator.
7 Q
Was there a Unit 2 training program during 8
this period?
9 A
There was somewhere near the end of 1973, 10 1974, to the best of my recollection, some training 11 for the Unit 2 personnel started.
I don't exactly 12 know when.
n(,)
13 Q
Were there any Unit 2 training programs 14 before the end of 19737 15 A
I don't recall.
16 Q
Was there any Unit 2 training program in l
(
17 1969, 1970, '71 and '727 18 A
Not to the best of my recollection.
19 Q
why not?
20 A
well, because Unit 2 was still under 1
g 21 construction and the emphasis at that time was on 22 Unit 1 and the training for Unit 2 would start closer 23 to the 1974' period.
f'}
24 Q
During the period September 1969 to s_/
25 October 1973, did you personally teach any courses for
1 Zechman 738 b)
\\/
2 Metropolitan Edison?
3 A
During that period there were times I 4
taught lectures on reactor theory.
5 Q
Did you teach any other courses in that 6
period?
7 A
Not to the best of my recollection.
8 Oh wait.
I take that back.
I may have 9
taught a lecture on shielding and I may have taught 10 instrumentation theory.
11 A
What did you mean by the words " reactor
. 12 theory" as you just used it?
f'N
\\_)
13 A
Reactor theory encompasses a gamut of 14 material starting with the basic fundamentals of what 15 an atom is, suberitical multiplication, reactivity 16 coefficients.
17 Q
What did you mean by the term " shielding" 18 as you just used it?
19 A
Shielding had to do with shielding of --
20 materials that are used to shield against radiation, gg 21 beta gamma and neutron.
" instrumentation l 22 Q
I think you also referred to l
23 theory" in your previous answer.
/)
24 What did you mean by that?
\\J 25 A
I meant the theory associated with how a
1 zechman 739
~h (b
2 compensated ionization chamber works, an ionization 3
chamber boron tri fluoride detectors and how they 4
worked.
5 Q
what is the compensation ionization 6
chamber?
7 A
That is the power range detectors used in 8
the plant.
9 Q
what is a boron tri fluoride detector?
10 A
That is the detector used for the start-up 11 range.
12 Q
During the period September 1969 to r'
k_)}
13 October 1973, were operating emergency procedures 14 taught by Metropolitan Edison?
l 15 A
Yes, they were.
16 Q
Did you teach any operating procedures 17 or emergency procedures in that time period?
18 A
No, sir, I did not.
19 Q
Do you know who did?
j 20 A
Yes, the people most conversant with those 21 were the foremen who were teaching the programs at 22 that time.
23 Q
Did there come a time when you ceased
(~)
24 to have responsibility for overall administration of
\\/
25 the Met Ed training programs?
1 1
Zechman 740 2
A Yes, sir.
3 Q
When was that?
4 A
That was approximately in June of 197(.
5 Q
Do you know who took over those 6
responsibilities?
7 A
Yes, sir, Mr. Jim Seelinger.
8 Q
Do you know approximately when he took 9
over those responsibilities?
10 A
My best estimate is around June of
'74.
11 Q
What position did you then assume?
.12 A
Administrator of nuclear technical f'
(_
13 training.
That was in about August of 1973, if my 14 memory serves me well.
15 Q
IIow long did you hold that position?
16 A
Until November of
'76.
17 Q
tihat were Mr. Seelinger's responsibilities 18 in that period?
19 A
In that period, Mr. Jim Seelinger had the 20 responsibility for overseeing the training of Unit 1 21 and Unit 2 operations, training including the ggg 22 auxiliary operating training on Unit 1 and Unit 2 and 23 overseeing the other training that was going on, f~Jj 24 which was general employee type training.
x.
25 Q
You just referred to auxiliary training
1 2echman 741
(~(_))
2 for Unit 1 and Unit 2.
Are you referring to separate 3
training for auxiliary operators?
4 A
Yes, sir, I am.
5 Q
Do you know when suen training was first 6
instituted?
7 A
Somewhere around the 1974 period, I 8
believe.
9 Q
What other training programs were,being 10 administered by Metropolitan Edison in the 1974 to 11 1976 time frame?
.12 A
somewhere in there is when the cold O(_)
13 license training program for the Unit 2 operators was 14 under way.
15 Q
was there any program in that time frame 16 for Unit 1 operators?
I
(
17 A
Yes, sir, in that time frame -- what time 18 frame are we talking about here?
19 Q
I am talking about the time frame 1974 to 20 1976.
l 1
ggg 21 A
During that time, there was a 22 requalification program for Unit 1 operators.
There 23 was initial replacement operator -- or not initial, I
(~}
24 there were replacement operator training programs
'J 25 in effect for new operators for Unit 1.
There were l
l l
1 Zechman 742
(~N t
)
2 auxiliary operator training programs for auxiliary 3
operators in Unit l'
an'd there was general employee 4
training.
O 5
Q You referred to requalification training 6
program for Unit 1 in ti.e perio'd 1974 to 1976.
You 7
had 'not made" reference to such a program in the period 8
1969 to 1973) is that correct?
9 A
That's correct.
s 10 0
It is correct, then, that the 11 requalification training for Unit I w,3s begun in the 12 h
1974 to 1976 time frame?
(~)h
(
13 1
A Sometime in that time frame the NRC came M
14 out with what they called and identified as a 15 requalification program and.had requested each 16 utility to write their own requalific'ation program I
l 17 under the guidance which they had put out and then
~ hat to the NRC for approval'.
That was done 18 submit t
19 and that is the program that we were discussing a l
l 20 minute ago.
1 ll 21 Q-was there a' hot license program during 1
l 22 the period 1974 to 19767 23 A
Yes, there was for any replacement CRO i
,l f~'J l
24 for Unit 1.
\\~
25 O.
You referred a bit earlier in your
1, Zechman 743 m
~
2 testimony to a replacement program.
Can you tell us 3
the difference between the replacement program that 4
you described and the hot license program, if any?
5 A
Well, they are the same.
I think I 6
testified earlier it was known as the Category IV 7
training program.
8 Q
You also referred a few moments ago to 9
the general employee training program; is that 10 correct?
11 A
That is correct.
12 Q
Could you describe that for us?
13 A
Yes, the general employee training program 14 was a program which was conducted for the general 15 employee.
It was a program that included -- it was 16 an annual requirement for each employee to go through 1
~
17 it.
It included the security procedures, emergency 18 procedures for the general employee; that is, if they 19 heard the alarms, where did they go, what did they l
20 do.
It included what quality assurance, QA, is.
It l
(l) 21 included certain reg guides, use of reg guides.
22 It included some industrial safety information and 23 review of basic radiological protection.
(J
)
24 Q
Now, during the period 1974 to 1976, again l
25 you said that Mr. Seelinger had administrative i
1
1 Zechman 744
\\~/
2 responsibility for training programs?
A That is correct.
3 4
Q What were your responsibilities during 5
that time frame?
6 A
During that time, I spent a great deal of 7
time with Jim Seelinger doing administrative type 8
work.
That is, continuing with scheduling and 9
setting up schedules for instructors, interfacing 10 with the NRC on schedules for exams, maintaining 11 records and in some cases teaching reactor theory.
.12 Q
When you said " maintaining records," what 13 kind of records are you referring to?
14 A
What I was referring to was if the 15 training program would be given, I would fill out the 16 administrative documentation associated with that and 17 put it in the proper format for permanent filing.
18 Q
When you say " teaching reactor theory,"
1 19 is that the same reactor theory type of teaching 20 which you testified to doing in the 1969 to 1973 time g
21 frame?
l 22 A
Yes, and it would include any additional 23 information in that area that came along.
24 Q
Did your teaching of reactor theory
}
25 include heat transfer?
1 Zechman 745 2
A No, sir.
3 Q
During the 1974 to 1976 time frame, can 4
you tell us approximately what portion of your time 5
was spent on administrative responsibilities?
6 A
This would be an estimate on my part.
7 It would be approximately 90 percent administrative 8
and maybe 10 parcent instructional.
9 Q
During the 1974 to 1976 time frame, did 10 you teach operating procedures or emergency procedures?
11 A
No, sir, I did not.
- 12 Q
During the 1974 to 1976 time frame, did you (3
13 teach plant transients?
14 A
No, sir, I did not.
15 Q
Do you know who did?
16 A
That -- the training of -- on plant 17 transients would have been taught, for Unit 1 and 18 Unit 2 -- would have been taught by the licensed 19 instructors.
j 20 Q
Do you know who taught operating procedures g) 21 and emergency procedures in that time frame?
22 A
Again, that would have been the instructors.
23 Q
Did you personally supervise training on
/~N
()
24 procedures or plant transients during that time frame?
25 A
No, that responsibility fell under Jim
1 Zechman 746
[~)
(_/
2 Seelinger.
3 Q
You said that you did teach reactor theory 4
in the 1974 --
5 A
Let me back up a second.
That fell under 6
Jim Seelinger.
Sometime in that time period -- what 7
period are we talking about?
8 Q
1974 to 1976.
9 A
O.
K., my statement was correct, then.
10 Q
You stated a while earlier that you did 11 teach reactor theory during this period, 1974 to 1976.
.12 To whom did you teach it?
(-(_)
13 A
I taught it to, at times to both Unit 1 14 operations personnel as well as Unit 2 operations 15 personnel.
16 Q
When you say " operations personnel," what 17 kind of operations personnel are you referring to?
18 A
I am referring to CRO's and SRO's.
19 Q
Did you teach reactor theory to any i'
20 auxiliary operators?
lll 21 A
During the early period of 1974 to
'76, 22 somewhere in there, I believe I did.
And as I already 23 mentioned, back earlier than that in Unit 1.
(~T 24 Q
What was your understanding of the function V
a 25 of an auxiliary operator?
1 Zechman 747 (A
'N
\\~
2 A
The auxiliary operator by job spec was 3
responsible for the secondary side of the plant 4
and certain primary systems.
5 Q
When you say "certain primary systems,"
6 to what are you referring?
7 A
I don't recall what they are right now but 8
they had some systems which they would be out in the 9
plant and be responsible for operating in the. plant 10 as opposed to in the control room.
11 Q
I believe you testified a few moments ago
.12 that you taught reactor theory to CRO's and SRO's 13 during this time period; is that correct?
14 A
That's correct.
15 Q
Can you give us an example of how a CRO 16 was expected to apply reactor theory?
17 A
Well, reactor theory, a great deal of it 18 had to do with multiplication in the reactor.
19 That i,s when you pull control rods, neutron 20 multiplication takes place in the reactor.
As
{lg 21 multiplication increases, more fission events take 22 place, mere heat is generated.
The amount of 23 multiplication is measured in units of reactivity.
(~j\\
24 4fe talked about reactivity effects of control rod t
25 movement.
We talked about the fission product I
1 1
Zechman 748
('M
'\\~/)
2 poisons that you build up in the core, such as xenon 3
and samarium, and its effect on core operation.
4 Q
Referring once again to B&W 554, under 5
the heading 1976 to 1977 it indicates that in 6
that time period you assumed the position of group 7
supervisor of technical training; is that correct?
8 A
That's correct.
9 Q
Further on in that section of your resume, 10 the words appear " Supervisor of Training - TMI"; is 11 that correct?
12 A
I see that.
/-
' _)N
\\
13 Q
Who does that refer to?
14 A
That refers to Alexis Tsaggaris.
15 Q
How did your responsibilities change in 16 November 19767 17 A
In November 1976, as group supervisor, l
18 technical training, I was responsible for the 19 auxiliary operator training programs on both Unit 1 l
20 and Unit 2 and the general employee radiation wor:er l
1
)
21 training for the general employee.
22 Q
When you say you were responsible for 23 those programs, could you describe your responsibilities
~T 24 in a bit more detail?
(b i
25 A
Yes, by responsibilities I meant that I was i
1
1 Zechman 749
('N
(_)
2 responsible for insuring that the training programs 3
for auxiliary operators were conducted, supervising 4
the instructors who taught in that program, maintaining 5
the records associated with that program, keeping 6
Alexis Tsaggaris informed of those programs and the 7
conduct of those programs and the progress of those 8
programs.
9 Q
When you say you were responsible for 10 insuring that the programs were conducted, which 11 programs are you referring to?
12 A
Auxiliary operator training r~( j\\
13 programs Unit 1 and Unit 2 and the general employee 14 radiation protection programs for the general employee, 15 or general employee worker, I should say.
16 Q
The resume, B&W 554, says that you were I
17 responsible for the administration of the " assigned 18 TMI non-license training programs."
l 19 What did you mean by the term "non-license 20 training programs"?
g 21 A
Nonlicensed referred to the auxiliary 22 operator programs referring to -- that the auxiliary 23 operators do not get NRC licensed and the general 1
gS 24 employee programs.
That is what that referred to.
GI 25 Q
Are the employee programs you referred to l
1 zechman 750
( >)
2 the same employee programs you described a bit earlier 3
regarding the 1974 to 1976 time frame?
4 A
Yes, sir.
5 Q
You testified a few moments ago that you 6
were responsible for insuring that these programs were 7
conducted.
In what manner did you carry out this 8
responsibility?
9 A
If there were a new group of auxiliary 10 operators hired and training programs had to be 11 conducted for them, which was the case many times
. 12 during those years, I would insure that the schedules A(_)
13 would be made up, that the instructors were assigned 14 to those programs and the programs were conducted in 15 accordance with those.
16 MR. GLASSMAN:
Can I have the answer 17 read back.
18 (Record read.)
19 Q
In accordance with what?
20 A
With those responsibilities.
lll 21 Q
You also testified a few moments ago that 22 you supervised instructors during this time period.
23 Could you tell us more specifically what I'T 24 you did in this respect?
\\_)
25 A
Yes, the instructors reported to me.
I
1 Zechman 751 l')
(_/
2 would assign them to the training program.
Under 3
those assignments, the instructors would prepare the 4
lessons for the program and teach the program.
I 5
would insure that they were available for that 6
program when assigned and interface with them on a 7
supervisory level to iron out any problems should 8
there be any problems.
9 Q
You have described a number of 10 administrative duties in supervision here.
Did you 11 substantively review their license?
.12 A
I audited at times the training programs.
(_/
13 I would sit in some of the programs to listen to 14 the interface between the students and the instructor 15 and review his material.
16 Q
Your resume, under the heading of 1
17 November 1976 to November 1977, refers at the end of 18 that paragraph to " supervision of the assigned 19 Administrators of Nuclear Technical Training."
20 What was intended by the word " assigned"?
ll) 21 A
Assigned means that those instructors 22 assigned to teach the auxiliary operator training l
23 programs or the general employee radiation worker 24 training programs.
25 Q
Did you personally have any teaching
1 Zechman 752
(%(-)
2 responsibilities in this time frame, November 1976 to 3
November 19777 4
A There may have been -- there were times 5
there may have been times that I taught reactor 6
theory during that time.
7 Q
Did you regularly teach reactor theory 8
during that time frame?
9 A
I don't know that I regularly taught it 10 during that ti e.
Somewhere in that time frame, 11 Mr. Dennis Bolts began to teach reactor theory on a
.12 regular basis.
And we relied on him at that time.
(~)s 13 Q
Were q_
14 A
I might also point out in that time frame 15 we also had a nuclear engineer that was teaching some 16 of the programs.
l 17 Q
What programs are you referring to?
18 A
Reactor theory.
19 Q
Did the nuclear engineer teach any other 20 programs?
g 21 A
He taught in some of the CRO programs, 22 company license programs, if my memory serves me well.
23 Q
Do you recall what courses he taught?
i I
24 A
I think he taught reactor physics, O( N 25 reactor kinetics.
That's all I can recall.
There is
l 1
Zechman 753
/~^s
(_)
2 more but I can't recall what else.
3 Q
What was your understanding of the term i
4
" reactor physics"?
5 A
Reactor physics, again, has to do with 6
the study of the atom, the study of' radiation, the 7
study of neutron multiplication production.
8 Q
What was your understanding of the term 9
" reactor kinetics"?
10 A
Reactor kinetics had to do with the effect 11 of reactivity on the operation of the core.
12 Q
During this period you were group 13 supervisor of technical training for nonlicensed 14 training -- is that correct?
i 15 A
As I have described my training more or I
16 less a minute ago.
l l
l 17 Q
--was there a group supervisor of license 18 training during that period?
l 19 A
Shortly thereafter there was appointed a 20 group supervisor of license training, yes, sir.
I g) 21 don't exactly remember the exact time but somewhere 22 in that interval.
23 Q
Do you know if there was any instruction l
l w
24 given on operating procedures and emergency procedures 25 during that time frame?
l l
j 1
zechman 754
((_8) 2 A
Yes, sir, there was.
3 Q
Did that come under the nonlicense area 4
or the license area?
5 A
I guess you have to clarify what procedures 6
you are talking about.
7 Q
Operating and emergency procedures.
8 A
Operating and emergency procedures was 9
taught certainly under the licensing training group 10 and there were some secondary plant procedures taught 11 to the auxiliary operators.
12 Q
Did you personally teach operating or 7s()
13 emergency procedures in that time frame?
14 A
No, I did not.
15 Q
Were plant transients taught during that 16 time frame?
17 A
Yes, sic, they were.
18 Q
Did you personally teach plant transients 19 during that time frame?
20 A
No, sir.
lll 21 Q
I am now going to move on to the period 22 in which your resume indicates you were acting
~
23 supervisor of training and then supervisor of training,
_lM the period that I indicated in the beginning that you 25 were asked a goodly number of questions by Mr. Fiske.
i Zechman 755
(
\\
\\"
2 B&W Exhibit 554 indicates that from November 1977 to September 1978 you assumed the 3
4 position of acting supervisor of training; is that 9
5 correct?
6 A
That's correct.
7 Q
How did you get that position?
8 A
I was called to the home office in Reading 9
by Alexis Tsaggaris and at that time he discussed with 10 me the -- that he would like me to take on the position
., _ 11 of acting supervisor, training.
He explained that my
,12 administrative abilities demonstrated during Unit 1
(_)T 13 and up to this period were excellent and he felt that I 14 could do a good job in that position and asked if I 15 would assume that role.
16 Q
What did you say to him?
17 A
I said that we would talk about it a little 18 bit and we talked about it and we discussed one other 19 item and that was getting a license, an NRC license, 20 and going through a licensing program myself.
He ll 21 thought that that would be a good idea.
I thought that 22 I would like to do that very much and I thought that i
23 would be appropriate at this time, so we discussed that 1
24 possibility.
25 Q
Was that in a face-to-face meeting?
1 Zechman 756 ex 2
A Yes, sir, it was.
3 Q
Where did that take place?
4 A
In the home office in Reading.
O 5
Q You described part of a discussion 6
regarding getting a license or going into a licensing 7
Program yourself; is that correct?
8 A
That is correct.
9 Q
What was the purpose of going into such 10 a program, of your going into such a program?
11 A
We talked about my responsibilities during c12 this time and I told him since I had been working 13 with auxiliary operator training programs for some time 14 that getting a license would -- and taking some time 15 to get out in the plant and rememorize some of the 16 very specific features in the plant,rememorizing all 17 the alarms and set points that one needs to do in 18 order to get a license program, that I felt that it 19 was necessary to do so at that time and that I wanted 20 to take that time to review and also get a license.
lll 21 Q
Did you tell him why you wanted to get a 22 license?
23 A
Yes, as I just explained.
I I}
24 Q
Did you discuss with Mr. Tsaggaris your
%j 25 other responsibilities as acting supervisor of training?
1 Zechman 757
\\-
2 A
Yes, we had a long discussion on the 3
responsibilities.
We talked about that if I was to 4
do this, it meant that I would be away from the 5
department on many occasions, being out in the plant 6
and doing some research and going through, starting 7
to go through a license program, and that to do so 8
would mean that the burden of responsibility for the 9
auxiliary operator programs and the license program 10 would fall heavily on the individuals involved.
By 11 that, I meant that the group supervisor of operator
.12 training would, as his responsibility required, n) 13 continue the administration and supervision and 14 direction of the licensing training programs, that I 15 would be only interacting with him on in an 16 indirect basis in a kind of an auditing function.
I
(
17 still would maintain du'ing that period of time my r
18 responsibilities as group supervisor of nonlicense l
l l
19 training; however, I would rely on one of those 20 instructors to continue with a lot of the administrative l
g) 21 work that would have to be continued in my absence.
22 Q
And you discussed this with Mr. Tsaggaris?
23 A
Yes, sir, I did, f~)
24 Q
What did he say about that?
V 25 A
That was very much agreeable to him.
He I
1 Zechman 758
('m r
)
2 thought that was a good idea.
He then met with --
3 at a later date met with the individuals in the 4
department and notified them of my acting position O
^
5 and made it clear what thd role would be of those 6
individuals in my absence.
7 Q
What individuals are you now talking about?
8 A
I am referring to the group supervisor of 9
license training at that time and I discussed -- if my 10 memory serves me well, I believe Alexis had discussed 11 with one of the instructors in the auxiliary operator 12 training program that he would play a big role in some
('
\\-))
13 of the administrative duties.
14 Q
Who was the group supervisor of licensing 15 during that period we are talking about now, November 16 1977 to September 19787 17 A
Mr. Don Goodman.
18 Q
Was he group supervisor of licensing 19 for the entire period?
20 A
Somewhere in that interval, if my memory lll 21 serves me well, he had left and transferred to 22 PENELEC, which is a sister company of the GPU system, 23 and Mr. Marshall Beers had replaced him as group
[)h 24 supervisor of license training.
25 Q
Did Mr. Beers take over the same
1 Zechman 759 t's 2
responsibilities as Mr. Goodman had?
's 3
A Yes, sir, he did.
4 Q
You said there was an individual who had 5
responsibility in the area of auxiliary training that 6
you relied on.
Who was' that?
7 A
That was Mr. Frank McCormick.
8 Q
What were his responsibilities as you 9
understood them during this period?
10 A
He continued with his responsibilities as 11 administrator of nuclear technical training and 12 instructor's role in the auxiliary operator
^
k s\\
/
l 13 training programs and took on some of the administrative m
14 duties in my absence, such as record-keeping, scheduling 15 and so forth.
16 Q
You did not obtain a license during this i
f 17 period; is that correct?
18 A
That's correct.
19 Q
Did Mr. Goodman have a license?
20 A
Not on the the TMI plants, no sir.
lll 21 Q
Do you know on what plants he had a 22 license?
23 A
If my memory serves me well, he did have a l
{J')
24 license on the Saxton PWR reactor at one time.
It
~
25 wasn't current at that time, to the best of my l
1 zechman 760 3(G 2
recollection.
3 Q
Did Mr. Baers have a license?
4 A
Yes, he had a dual license, an SRO 5
license on both Unit 1 and Unit 2.
6 Q
During the period November 1977 to 7
September 1978, did you teach any licensed operators, 8
you personally?
9 A
Not to the best of my recollection.
10 Q
Were operating procedures and emergency 11 procedures taught during this period by the training 12 department?
O)
\\_
13 A
Were they taught by the training 14 department?
l 15 Q
Yes.
l 16 A
Yes, sir.
17 Q
Did you personally teach operating or l
18 emergency procedures during this time frame?
l 19 A
No, sir.
l 20 Q
Were plant transients taught by the l
(
ll) 21 training department during this time frame?
22 A
Yes, sir.
23 Q
Did you personally teach any plant
(~N 24 transients during this time frame?
l
%)
25 A
No, sir.
1 Zechman 761
/m
\\m 2
Q Did you teach reactor theory during this 3
time frame?
4 A
Not to the best of my recollection.
5 Q
Did you teach anything during this time 6
frame?
7 A
Not to the best of my recollection.
8 Q
could you briefly list for us the training 9
programs that were in existence at that time?
10 A
At that time for Unit 1 there was a Unit 1 11 requalification training program.
There was a 12 category 4 replacement operator training program in
()
13 place.
There was a Unit 2 company license program 14 still in effect.
There was a Unit 1 and Unit 2 15 auxiliary operator training program and there was a 1
16 general employee training program.
17 Q
Did you, as acting supervisor of training, 18 audit any of these programs?
19 A
During what period?
20 Q
During the period November 1977 to g) 21 September 1978.
22 A
Yes, sir, I did.
I recalled coming back 23 to my office and on several occasions meeting with
(~N 24 Don Goodman and picking out at random various names
\\)
25 of personnel in the requalification programs and having
1 Zechman 762
(~')
N/
2 him go to the files and verify the status of their 3
training in accordance with the requalification 4
program.
5 Q
Were you aware during this period 6
November 1977 to September 1978 that there were written 7
materials used in the training program?
8 A
Yes, sir.
9 Q
What materials do you recall being used?
10 A
Well, I will list the materials that were 11 available as sources for the various training 12 programs.
b
\\
13 We had a file of Unit 1 and Unit 2 lesson 14 plans.
We had system descriptions for Unit 1 and 15 Unit 2.
16 We had the B&W PWR technology manuals.
17 We had control copies of procedures.
18 We had P&I prints which were electrical l
19 prints.
20 We had vendor manuals and we had available i
lll 21 control copies of piping diagrams.
22 Q
Do you recall any other materials at this 23 time?
/~
N_)T 24 A
Somewhere in that period we had received 25 some video tapes, I believe in that period, from B&W
1 zechman 763 (D
kJ 2
on the integrated control system.
l 3
'Q Is this a comprehensive list you have 4
just given us?
5 A
It is by no means comprehensive.
It is 6
what comes to mind at this time.
7 Q
You referred to a file of Unit 1 and Unit 2 8
lesson plans a few moments ago.
9 could you describe what that is?
10 A
Yes.
It was a file drawer in which lesson 11 plans were maintained for both Unit 1 and Unit 2.
12 Q
What training programs are you referring m
13 to?
14 A
Well, those lesson plans would be utilized 15 where appropriate in either of the programs associated 16 with either the auxiliary operators or control room 17 operators, where appropriate.
18 Q
Was there a lesson plan for each 19 particular course?
20 A
There were lesson plans for -- in the lll 21 different lectures that we gave in each of the courses.
22 That is about as far as I can describe it.
23 Q
Do you know how lesson plans were
}
24 generally prepared?
J 25 A
Yes.
Generally, the lesson plans were
1 Zechman 764 I'^l h
k-2 prepared by the instructor on the particular system 3
or the piece of equipment that they were going to 4
give a lecture on.
O 5
Q were lesson plans used only by particular 6
instructors?
7 A
Do you want to clarify that?
8 Q
I believe you just testified that the 9
lesson plans were prepared by an instructor on a
10 particular course.
Were those lesson plans available 11 only to that particular instructor?
12 A
No, the lesson plans were available to any i
[
}
l
\\_/
13 of the instructors that were going to teach that 14 particular subject.
15 Q
How would other instructors obtain copies 16 of that lesson plan?
17 A
They would simply ask the girl in charge 18 cf record-keeping for a copy of the lesson plan or 19 for utilization of that lesson plan in the file.
20 (continued on the following page.)
lll 21 22 23
(}
24 25
hd1 1
Zechman 765
(-
(_/
2 Q
In your testimony a few moments ago, you 3
referred to control copy of procedures, is that correct?
4 A
Yes, sir.
O 5
Q What did you mean by that?
6 A
By the control copy, I meant that through 7
the distribution system there are what was called 8
control copies.
Those copies are the most up-to-date 9
copies and are used, the only copies that are used, in 10 the actual operation of the plant as opposed to a Xerox 11 copy of a procedure that isn't marked.
12 Q
what procedures were you referring to?
(m) 13 A
I was referring to the operating emergency, 14 normal operating, and administrative procedures.
15 Q
You also referred to vendor manuals.
16 What did you have in mind by that?
17 A
By vendor manuals, we had available to us 18 the vendor manuals on diesel generators, various pumps 19 and motors, and things of that sort.
20 Q
I believe you testified just before that lll 21 there was a relatively brief period of time when Don 22 Goodman was group supervisor of technical training for 23 license programs, is that correct?
24 A
That is correct.
25 Q
During that period, did b.r.
Goodman have
2 1
Zechman 766 r
\\l 2
regular teaching responsibilities?
3 A
Not regular teaching responsibilities, no, 4
sir.
O 5
Q In response to questioning by Mr. Fiske, 6
you testified that the training program had been "in 7
auto" when you became acting supervisor of training, 8
is that correct?
9 MR. FISKE:
Where is that testimony?
10 Q
Do you recall testimony to that effect, 11 Mr. Zechman?
12 A
Yes, sir, I do.
f~)N
(._
13 Q
Page 107 starting at line 16, Mr. Zechman, 14 I am reading from a transcript of your testimony in 15 this action. Starting at page 107, line 16, and reading 16 through page 108, line 3, there is the following l
17 question and answer, you can read with me.
l l
18
" Question:
When you became acting 1
19 supervisor of the Training Department, did you 20 review the FSAR that was on file with the NRC jll 21 to be sure that the Met Ed training program was 22 complying with the description that had been l
l l
23 given to the NRC7" 24
" Answer:
I don't recall that I specifically
(~h]
l 25 sat down with the FSAR and measured our training
3 1
Zechman 767 x-2 programs against everything that was in there, 3
because at the time I took over the Training 4
Department, pretty much of the training programs 5
were i,n auto, and.there was not much difference 6
from what we were doing in the past."
7 Do you recall that question and that 8
answer, Mr. Zechman?
9 A
Yes, I do.
10 Q
What did you mean by "in auto"?
11 A
I meant that there was established, for
, 12 example, in Unit 1 a category for replacement operator (D
x_)
13 training program.
There was established a 14 requalification program.
There were auxiliary operator 15 programs in place.
There was a general employee
- \\
16 training program in place and being conducted.
17 Q
B&W Exhibit 554 on page 1,
you note that 18 "From September 1978 to present - promoted to 19 supervisor of training, September 1,
1978."
20 Did you assume the position of supervisor 21 of training on or about September 1,
1978?
ll 22 A
I was promoted to that position in that 23 time, yes, sir.
~T 24 Q
How did you get that position?
[O 25 A
Again, I was called to the home office in l
l
4 I
Zechman 768
[#
\\'
2 Reading and again reminded of what they thought was 3
exhibited as very good performance and felt that, based 4
on my past performance, that I was offered the position O
5 of supervisor of training.
6 Q
Did you meet with anyone in Reading?
7 A
I met with Alexis Tsaggaris, and I believe 8
I met with one of the managers.
I believe it was L.
9 Lawyer at the time.
10 Q
Do you recall what Mr. Tsaggaris said to 11 you and what you said to him at that meeting?
.12 A
Yes, I did.
Again, we discussed A
'\\_/)
13 responsibilities and the direction towards.getting a 14 license.
I discussed that during the period of acting 15 supervisor of training that my ability to oversee the 16 department on a periodic basis and try to train--and t
17 self-training the program mycolf, was not working very 18
,,11, 1
19 Traditionally, my training programs would t
l 20 be interrrupted.
That is, I would be out in the plant (l) 21 or sitting in a class, and I would be interrupted due i
22 l to phone calls or meetings that I had to attend.
And 23 that since the exam had already been scheduled, I felt i
24 that I needed to get out full-time in the plant a:id l
25 essentially not be -- have my training program
i 5
1 Zechman 769 A)
\\/
2 interrupted.
3
'We discussed that, and he understood, and
\\
4 it was decided at that time that although I would x
9 5
have the title, the responsibilities would be delegited s
6 at different periods to Mr. Frank McCormick and Mr.
7 Marshall Beers.
That was agreed upon and that is what 8
happened.
9 Q
In your last answer, you talked about 10 certain things not working very well.
11 During the time you had your position as
.12 acting supervisor of training and were training 13 yourself, what did you mean by that?
14 A
What I meant by that was that there was 15 a constant there appeared to be constant 16 interruptions.
l l
i 17 Q
What was being interrupted?
l 18 A
My personal training.
It seemed a good v
d nny of the times I would get aid of sitting in a id class, reviewing a lecture series,or out in the plant, 21 I would be interrupted by phone calls or administrative (g
22 duties that I had to come back to my ofice to take 23 care of, or meetings to attend; those kinds of things.
24 g
I would like you to refer for a moment 25 to questions and answers asked by Mr. Fiske during the 1
l
6 1
Zechman 770 13 s
i s
N^
2 first session of your deposition in this case and, in 3
particular,' to pages 66 through 69 of the transcript.
s 4
would youtplease just read through those pages, Mr.
)
5 Zechm.a.
6
'I would like to focus your attention in on the' question and answer'beginning on line 24 of
- 7.,
e s.
8 page 67 and continuing through line 13 of page 68.
1 9
A Would you repeat what specifically I
\\
10 should look at?
11 Q'
Particularly, I would like you to refer 12 to the questions an'd ' answers which Mr. Fiske was 4
(_)
13 rea' ding from your prior testimony before the Kemeny 14 Commission.
The questions and answers are quoted by 15 Mr. Fiske from pages 183 to 184 of the Kemeny y
16 commission transcript of your testimony, and they are 17 requoted at the bott$m of page 67 and the top of page l
18 68 of your testisony in this case.
19 The particular question which I am 20 focusing on reeds as follows:
s
(
21 "You in'icated that they indicated to you d
22 that the ability to train and run the Training 23 Department at the same time was not working out?"
~h 24
" Answer:
I indicated to them."
l, ('\\-]
[
25
" Question:
And on what basis did you m<
7 1
Zechman' 771 Ot
(_)
2 indicate to them?"
3
" Answer:
Well, that training was totally 4
interrupted.
I would sit in a lecture and sit 9
5 there two minutes.and the phone would ring and 6
I would have to go to a meeting or questions 7
were asked by people in the department and 8
things of that sort.
The training was just not 9
effective."
10 Do you recall those questions and answers?
11 A
Yes, sir.
12 Q
What training were you referring to that (O
_./
13 was totally interrupted?
14 A
I was referring to my personal training 15 program.
16 Q
Which personal training program was that 17 again?
18 A
My training program.
19 Q
Was that your training program for a 20 license?
(l) 21 A
Yes, sir.
22 Q
Further on in that answer, which appears 23 on line 12 of page 68 of your testimony, the words
/'T 24 appear, "The training was just not effective."
%A 25 Do you see that?
8 1
Zechman 772 c'~,'
2 A
Yes, sir, I do.
3 Q
what training were you referring to?
i 4
A My personal training program.
O 5
Q Why was that not effective?
6 A
Because of all the interruptions I was 7
experiencing during that period.
8 Q
Returning once again to the conversation 9
you had with Mr. Tsaggaris when you took the position 10 of supervisor of training, you testified a bit earlier
~
11 that in that conversation you made reference to a :ams
.12 that alreadly had been scheduled.
Now, in reference
((,)
13 to your own personal training, what exams were you 14 referring to?
15 A
I was referring to the NRC exams that 16 were scheduled for those individuals that were going 17 to be taking the licensing exams, I believe, in November 18 of
'78.
l l
19 Q
Approximately when did you have this l
20 conversation with Mr. Tsaggaris?
(ll 21 A
That was approximately around September j
22 of
'78.
23 Q
What did Mr. Tsaggaris say to you during
(/]
24 that conversation?
l l
I 25 A
As far as the promotion was concerned, he l
9 1
Zechman 773 O'-
2 was giving me background on their decision why I was 3
selected for that and we discussed my licensing program, 4
and we discussed the fact that I -- we discussed the 9
that I made to be temporarily relieved of that 5
request 6
position to go full-time into a study program for my 7
preparation for a license, and that during that period 8
the responsibilities would be delegated at different 9
times between Frank McCormick and Marshall Beers, and 10 that Marshall Beers, the supervisor of license training, 11 would continue to supervise as his responsibilities
.12 dictate the license programs for Unit 1 and Unit 2 and
( ~))
13 the supervision of the instructors that provide those 14 programs.
15 Q
What were Mr. McCormick's responsibilities?
16 A
I believe somewhere in that period, Mr.
17 McCormick was promoted to group supervisor of 18 nonlicense training.
19 Q
Did you suggest to Mr. Tsaggaris, that you 20 be temporarily relieved of the position full-time?
21 A
Yes, sir, I did.
l 22 Q
What did he say in response to that?
23 A
Again, they agreed and understood and had
(
24 no problem with that decision.
25 Q
When you say "they agreed," to whom are
10 1
Zechman 774
(~%
\\_)
2 you referring?
3 A
By that, I meant Mr. Tsaggaris, and I have 4
a little difficulty remembering whether it was Sandy 5
Lawyer or George Troffer.at that time that also agreed.
6 Q
During the period September 1978 up until 7
the day of the accident, did you actually perform the 8
functions of supervisor of training, you personally?
9 THE WITNESS:
Would you repeat that, 10 please?
11 (Question read)
.12 A
only to the extent let's see, from (A_)
13 September to November, not at all, except for maybe 14 writing a memo or two.
From November to the time of 15 the accident, on a very limited basis, because I was 16 still continuing with my training program during that 17 period.
18 Q
When you say "on a limited basis," can 19 you give us your best recollection of what your 20 involvement was?
llg 21 A
The involvement during that period is, I 22 may have been back in my office or occasions in that 23 period, touched base with each of those individuals.--
(-}
24 by " individuals," I mean Frank McCormick and Marshall
\\.s 25 Beers to see how things were going and to answer any
1 Zechman 775
/~%
(_)
2 questions they may have had and may have written a memo 3
r two.
4 Q
Did you understand that Mr. Beers and 9
5 Mr. McCormick had responsibility for training, 6
fundamental responsibility for training during that 7
time period?
8 MR. FISKE:
I object as to the question.
9 Q
You can answer.
10 A
It was understood that they still 11 maintained the responsibility in their area and were
. 12 shaing the responsibilities of supervisor, training.
()
13 Q.
What was the basis of your understanding?
14 A
Again, the basis of my understanding was 15 that I was continuing my training program during that 16 period and that they would share those responsibilities.
17 Q
Did there come a time when any individual 18 other than yourself became acting supervisor of 19 training or assume that title?
20 THE WITNESS:
Repeat that?
l 21 (Record read.)
22 A
Yes, I think I mentioned that as of 23 September 1978 that responsibility was delegated at
~g 24 different periods between Marshall Beers and Frank O
25 McCormick.
1 zechman 776
/\\
(_)
2 Q
Mr. Zechman, I am gcing to show you what has previ usly been marked as B&W Exhibit 260.
3 4
Do you remember that one?
A Yes, sir, I do.
5 6
Q In his direct examintion, Mr. Fiske asked 7
you some questions regarding the requalification 8
program which is described starting at page 13.2-6 of 9
this document.
I will get to that in a moment,but 10 first I would like if you could please describe for us 11 generally your understanding of this document, what
.12 it is.
[)
13 A
This document is a document out of the N_;
14 Chapter 13, out of the 13.2, FSAR, which described 15 the training programs, the initial training programs 16 that are conducted for Unit 2.
17 Q
What initial training programs are you 18 referring to?
~
19 A
well, as they are outlined here, the 20 initial supervisory SRO training programs, the control lll 21 room operator licensing training programs, statements 22 about previous nuclear training experience, training 23 programs for nonlicensed individuals, referring to the 24 auxiliary operators, and outlining training programs for C
25 rad chem techs, maintenance office personnel and
l 1
Zechman 777 2
general employee training programs.
3 Q
So the requalification program is only 4
one program that is discussed in this document; is 5
that correct?
6 A
It is only one section of chapter 13.2, 7
yes, sir.
8 Q
Were all of the programs discussed in B&W 9
260 taught by Met Ed at one time or another before 10 the accident?
11 A
Well, since this is comprehensive, some
_12 of the programs were conducted not only by Met Ed
)
13 but by B&W and outside consultants as well as vendors, 14 vendor training programs for mechanical and electrical 15 and I&C maintenance.
16 Q
Were all of the programs that are l
17 discussed in B&W 260 taught by somebody at one time l
18 or another before the accident?
19 A
To the best of my recollection.
20 Q
Is that answer to the best of your lll 21 recollection, yes or no?
22 A
Yes.
23 Q
I would like you to refer for a moment now f-]
24 to the requalification program section of B&W 260, LJ 25 which is identified as section 13.2.2 starting at
1 zechman 778 10 2
page 13.2-6.
3 Do you see that?
4 7.
Yes, sir.
9 5
Q I would like you to focus for a moment 6
under the heading 13.2.2.1,
" Program Schedule."
7 The third paragraph ends with the following sentence, 8
"OR lectures,are scheduled for a minimum of 60 hours6.944444e-4 days <br />0.0167 hours <br />9.920635e-5 weeks <br />2.283e-5 months <br /> 9
per year for all single and dual license holders."
10 Prior to the accident, did you have any 11 understanding of what that meant?
- 12 A
Yes, sir, I do.
x' 13 Q
And what was that understanding?
14 A
My recollection at this time is that 60 15 hour1.736111e-4 days <br />0.00417 hours <br />2.480159e-5 weeks <br />5.7075e-6 months <br /> requirement was placed on the onus of the training 16 department.
We were required to have and conduct 17 60 hours6.944444e-4 days <br />0.0167 hours <br />9.920635e-5 weeks <br />2.283e-5 months <br /> of classroom instruction, minimum, per year.
18 I think, as I testified earlier, many times if not 19 all, we exceeded that.
l 20 Q
Did that mean that each individual had to 21 attend 60 hours6.944444e-4 days <br />0.0167 hours <br />9.920635e-5 weeks <br />2.283e-5 months <br />, as you understood it?
lll 22 A
No, sir, it did not.
It meant that we had 23 to conduct instruction, live instructions at a minimum 24 of 60 hours6.944444e-4 days <br />0.0167 hours <br />9.920635e-5 weeks <br />2.283e-5 months <br /> per year, and if the individuals did not 25 get to the live instruction programs, they were sent
1 zechman 779 2
what we refer to as " care packages" or makeup 3
packages" to make up that material.
4 Q
Mr. Zechman, I would like you to read for a m ment from page 219 to.220 of.your transcript of 5
6 your deposition in this case.
7 Mr. Fiske asked you the following questions 8
and you gave the following answers, from which I will read.
Starting on line 24 of page 219 and continuing 9
10 through line 20 of page 220, the following questions 11 and answers appear:
12
" Question:
Was there a procedure at Met Ed 13 during this period of time and continuing on 14 through the time that you were in charge of the 15 training department to document the amount of time 16 that was spent on training?
1 17
" Answer:
There was an administrative 18 document in which we recorded the hours of 19 training and the personnel in attendance.
20
" Question:
For this period, this program lll 21 that you described as requiring 60 hours6.944444e-4 days <br />0.0167 hours <br />9.920635e-5 weeks <br />2.283e-5 months <br /> of 22 training per year, was it necessary that at the 23 end of the year, the records reflect that each
(~Y N
24 individual had, in fact, had 60 hours6.944444e-4 days <br />0.0167 hours <br />9.920635e-5 weeks <br />2.283e-5 months <br />?
l l
25
" Answer:
It would reflect the amount of l
l 1
1 Zech 780 2
time of training they had during that year.
3
" Question:
If the records didn't reflect 4
60 hours6.944444e-4 days <br />0.0167 hours <br />9.920635e-5 weeks <br />2.283e-5 months <br /> for an individual, then the records 5
w uld reflect a deficiency in the program for 6
that individual?
7
" Answer:
Yes, it would."
8 Do you recall those questions and answers?
9 A
Yes, I do.
10 Q
Are you now changing your testimony?
11 A
Yes, sir, I am.
,12 Q
Why are you changing your testimony?
b V
13 A
Because I have since read the requal 14 document again and recalled that the basis for that 15 60 hours6.944444e-4 days <br />0.0167 hours <br />9.920635e-5 weeks <br />2.283e-5 months <br /> and the onus for that 60 hours6.944444e-4 days <br />0.0167 hours <br />9.920635e-5 weeks <br />2.283e-5 months <br /> was on the l
16 training department, not on the individual.
It was to 17 insure that we conducted a minimum of 60 hours6.944444e-4 days <br />0.0167 hours <br />9.920635e-5 weeks <br />2.283e-5 months <br /> per 18 year of live instruction, actual classroom 19 instruction.
20 Q
You just referred to a requal document.
g 21 What document are you referring to?
22 A
I am referring to a requalification I
l 23 program which is also spelled out in administrative 24 procedure AP 1 through 6.
25 Q
Referring just for a few more moments to l
1 Zechman 781 Ok-2 B&W 260, page 13.2-8, in particular there is a 3
heading that say s 13.2.2.2.2, " Fundamentals and 4
System Review (FSR) Program."
5 Just describe briefly for us your 6
understanding of the nature of that program.
7 A
Yes, sir.
This was referred to, as it 8
says in the parantheses, the FSR portion of the 9
requalfication program.
This program -- this part of 10 the requalification program outlines the specific 11 lectures that must be given based on any deficiencies c12 that were based on certain deficiencies that were 13 noted in the annual requalification exam.
By that 14 I mean at the end of each requal year, the licensed 15 individuals were required to take within the NRC what 16 we call as our requalification written and oral exam.
l 17 On page 13.2-11a, it indicates that if an individual 18 in taking this exam scores 80 percent in any section i
I 19 of the annual written exam, he will be required to 20 participate in an FSR program or subject training ll) 21 related to that deficiency, so what this is saying, 22 as an example, is if he got less than 80 percent in 23 the exam which was entitled " Principles of Operation,"
f)')
24 he would during the next requal cycle have to sit in x
25 on a lecture covering in that case " Principles of
1 Zechman 782
(~'
\\
2 Operation" to make up those deficiencies.
3 So what this program allowed us to do is 4
that if any deficiencies -- and, really, what they 5
were saying is less than 80 percent, if they got 6
less than 80 percent -- he got extra training in those 7
areas by having to participate in those subjects.
8 Q
Was it the practice of the training 9
department to give that extra training?
10 A
Yes, sir.
11 Q
Did that training include lectures?
.12 A
That training included lectures.
m k_)
13 Q
Is there a reference in B&W 260 to a 14 hot licensing program?
I wonder if you could tell me 15 whether that exists.
16 A
Yes, on page 13.2-15 and section 13.2.3, 17 it talks about replacement personnel training.
18 Q
What is the relationship of that to a hot 19 licensing program?
20 A
What this is referring to is now that you (l) 21 have an operating plant, you have the initial cadre 22 of licensed individuals who are operating that plant I
23 and now as additional CRO's are needed due to attrition 24 or for whatever reason, the new trainees or new CRO's 25 or SRO's will go through what is referred to as a
1 Zechman 783 bi
\\._/
2 replacement operator training program.
That became known for CRO's as our Category IV training program.
3 4
Q I don't see the words " hot license" 5
anywhere here, unless you can help me.
Are you using 6
hot license and replacement training program 7
interchangeably?
8 A
Yes, sir.
9 Q
Bsw 260 is a portion of the FSAR relating 10 to training programs; is that correct?
11 A
That's correct.
.12 Q
Is that all that is in the FSAR?
O)
(_
13 A
No, that is just one section of the FSAR.
14 Q
In his direct examination, Mr. Fiske 15 asked you some brief questions regarding FSAR system 16 descriptions.
17 Do you recall that?
18 A
I recall some discussion of that, yes, sir.
19 Q
Were the FSAR system sections used for 20 any training program while you were acting supervisor lll 21 of training or supervisor of training?
22 A
There may have been drawings taken out of j
l 23 it or some references made to it but we also had
(~h 24 system descriptions that were written by the vendors V
25 that were used in training, in Unit 2.
l 1
Zechman 784
[^')
Y/
2 Q
Why did you use system descriptions 3
provided by the vendors?
4 A
They were more detailed than what appeared 5
in the FSAR.
6 Q
What, then, was your understanding of 7
the use to which the FSAR system sections would be 8
put?
9 A
The FSAR was a document that was required 10 to be put together that described those requirements 11 for obtaining an operating, a plant operating license.
c12 Q
I would like to show you a copy of what O(_s' 13 has previously been marked as B&W 557 entitled 14
" Training and Certification of Metropolitan Edison 15 Company, Three Mile Island Unit 2, Licensed Personnel."
16 I believe you testified in response to direct questions 17 on that, that it had been prepared by Mr. McCormick; 18 is that correct?
19 A
That is correct.
20 Q
Do you know why this document was prepared?
g) 21 A
Yes, I had requested him to prepare it at f
22 some period post-accident to give his -- to write his l
l 23 best compilation of training programs at that time, f) 24 in a very short period of time that he had, to the V
l 25 best of his ability.
It was to give an overview of 1
t
1 zechman 785 m
(\\-)
2 the various training programs.
3 Q
When you say "best compilation," what do you 4
mean by those terms?
9 5
A By that I meant there was not very much 6
time for him to put all this together, so he had to 7
collect as much. historical data as possible to write 8
this and prepare it so that one looking at this 9
could get an overview of the programs.
It was by no 10 means totally comprehensive of what all the training 11 that was accomplished.
.12 Q
Looking now at both B&W Exhibit 260 and O( /
13 B&W Exhibit 557, B&W 260 being the description of the 14 FSAR training program and 557 being Mr. McCormick's 15 memorandum which you just described, how, if at all, 16 do these two documents relate to each other?
17 MR.*FISKE:
I am not sure I understand the 18 question, Mr. Glassman.
19 A
They overlap in some respects in the 20 initial training area.
The one that Frank McCormick 21 wrote in some respects details some of the inforniation l
22 that is found in the FSAR on the initial training.
23 Q
You referred a little while earlier to 24
" care packages."
Were care packages prepared for f')
v 25 any particular training program?
1 Zechman 786 2
A They were prepared for and in line with 3
the requalification program for those individuals who 4
missed the live lecture.
O 5
Q In response to direct examination by Mr.
6 Fiske, you gave some testimony regarding an attendance 7
issue at Metropolitan Edison; is that correct?
8 A
That is correct.
9 Q
What program did that relate to?
10 A
That related to the requalification program.
11 Q
Did it relate to any other training program?
12 A
No, it was strictly related to the
)
13 requalification program.
14 MR. FISKE:
I object to this, Mr. Glassman, 15 unless you make Mr. Zechman specify which part 16 of his testimony relating to attendance problems 17 he is talking about.
Unless you are suggesting 18 or Mr. _ Zechman is suggesting that nothing in 19 his testimony on direct concerning attendance 20 related at any point to any program other than gg) 21 requalification?
22 MR. GLASSMAN:
That is exactly what the 23 nature of my question is.
24 Q
Mr. Zechman, did your testimony with regard
(~x)
Am/
25 to an attendance problem relate in any respect to any
1 Zechman 787 l
/~N k-
)
2 program other than the requalification program?
3 A
Not to the best of my recollection.
4 Q
Mr. Zechman, referring again to the care 5
packages used in the requalification program, was 6
that authorized, to the best of your knowledge, 7
anywhere in the FSAR?
8 A
Yes, in the FSAR which describes the 9
requalification program, the requalification program 10 which has been approved by the NRC states that if an 11 individual misses a lecture that he may make up that 12 lecture by several means, one of which is being sent (O
_)
13 a makeup package being referred to as a " care package."
14 Q
I'would like you for a moment to look 15 at B&W 260 and see if you can point out to us any 16 particular portion of that which relates to care 17 packages, so-called care packages.
18 A
I am on page 13.2.2.2.1 entitled 19
" Operational Review (OR) Lecture Series."
20 Q
Which paragraph are you referring to?
ll 21 A
Approximately the sixth paragraph.
It 22 starts out " Attendance of all licensed personnel will 23 be recorded.
Absences will be made up by reviewing
/~N 24 lecture material and/or discussions with on-shift
()
25 supervisory personnel or the technical staff."
1 zechman 788
/
(s_)
2 Q
During the period that you were acting 3
supervisor of training and supervisor of training, l
4 what, if any, kinds of materials were included in 5
so-called " care packages"?
6 A
Well, it varied in accordance with the 7
subject matt (.e and if it was on a piece of equipment, 8
it would hata included perhaps some excerpts from the 9
vendor manual.
At times it could include lesson 10 plan, a handout that was given out by the instructor.
11 Again, it varied with the lecture that was given.
.12 Q
Did you review any of these care packages?
13 A
Yes, sir, I have.
14 Q
Why would you review them?
15 A
Well, I recalled during the time that I 16 was acting supervisor, as an example, I met with Don 17 Goodman and asked to pick out a series of names at 18 random and asked to verify the attendance of the 19 program and the material.
20 Q
While you were acting supervisor of lll 21 training or supervisor of training, you held those 22 titles, did you ever sit in any classes?
23 A
Yes, I did.
As part of my training, I did
'N 24 sit in a number of lessons,
{d 25 Q
For what purpose did you sit in on lessons?
1 Ze chman 789
(' j\\
2 A
Again, for review and part of my training 3
towards a license.
4 MR. FISKE:
I am not clear what you are 5
asking Mr. Zechman hbout, Mr. Glassman.
Are 6
you asking him now about lectures or lessons as 7
part of this operation and review lecture series 8
which is part of the requalification program?
9 MR. GLASSMAN:
I was asking about lessons 10 in general.
You will have an opportunity to 11 ask any further questions you like.
12 MR. FISKE:
But I think we can save a lot
()
13 of time if the questions are a little more focused.
14 You had been asking about care packages 15 MR. GLASSMAN:
We are off care packages.
16 I will save time and ask the questions.
17 Q
What kinds of classes did you actually sit 18 in on, Mr. Zechman, during the time that you were 19 supervisor of training?
20 A
I sat in on some of the requalification qg 21 lectures that were being conducted by the licensing 22 section of the training department.
23 Q
Is that all you recall at this point in 24 time?
25 A
And I believe I also -- in fact, I know
1 Zechman 790 2
I also sat in on some of the auxiliary operator 3
leccures.
4 Q
I believe a bit earlier you testified 5
about requalification exams given by Met Ed.
Is 6
that correct?
7 A
Yes, sir.
8 Q
How often were such examinations given?
9 A
On an annual basis.
10 Q
was there any action to be taken by Met 11 Ed if someone failed that exam?
12 A
Yes, sir.
It was pretty well described in O) g 13 the requalification procedure.
14 Q
What action was that?
15 A
That action is described on page 13.2-11a 16 of B&W Exhibit 260.
17 Q
Can you just generally describe what it is?
18 A
I will read it.
19 "If an individual receives a grade of less 20 than 70 percent overall on the annual examination l
gg 21 it will be mandatory that (1) he be. relieved of his 22 licensed duties and (2) enter an accelerated 23 requalification program.
Upon (1) successfully passing 24 a second written and oral examination and (2) 25 certification of satisfactory rating being sent to the
1 zechman 791 i
\\
( )
2 NRC, the individual will be returned to his licensed duties."
3 4
Q Did you have an understanding of what was meant by the term " accelerated requalification 5
6 program"?
7 A
Yes.
8 Q
What was that?
9 A
What that referred to, if that individual 10 failed that exam, he would have to go into a 11 remedial training program covering the areas of 12 deficiency under the direction of the training (G_)
13 department.
14 Q
Was there a written requalification exam?
15 A
Yes, sir.
16 Q
Do you recall approximately when before 17 the accident was the last time such a written exam was 18 given?
19 A
I believe it was February of 1979.
20 Q
Did anyone fail that exam?
21 A
Not to the best of my recollection.
ggg 22 MR. GLASSMAN:
I would like to have 23 identified as GPU Exhibit 508 for identification
,f-}
24 a series of seven sheets of paper.
NJ 25 (Cover sheets of requalification exams
1 zechman 792 2
were marked as GPU Exhibit 508 for identification, 3
as of this date.)
4 Q
Mr. Zechman, I show you what has been 5
marked as GPU Exhibit 508.for identification.
6 Can you tell us what this is?
7 A
This is the cover sheet of the exams, 8
the annual requalification written exams.
9 Q
Which exams are you talking about now?
10 A
I am talking would you clarify your 11 question?
.12 Q
Are you talking about an exam given at a
()
13
- p. articular time?
14 A
This was the cover sheet of the people 15 who participated and took the requalification exam 16 which was for the cycle 5 1978-1979 period.
17 Q
Are thesa documents maintained in the
{
l 18 training department?
l 19 A
Yes, sir.
20 Q
Do you know if this document, GPU Exhibit l
)
21 508, includes the cover sheets for all persons who 22 took the exam in that period?
23 A
I don't believe so.
24 Q
What is contained on these cover sheets?
v 25 A
It is the point value for each section of 1
I
1 Zechman 793 i
(_/
2 the exam, the applicant's score and percent of the 3
category value, his final grade, the applicant's 4
name and who approved the exam.
5 Q
There is a line that says " Approved by" 6
at the bottom of each of the sheets on GPU Exhibit 508.
7 It appears to have the same signature on each line.
8 Can you read that?
9 A
Yes, that is Marshall Beers.
10 Q
Who is that?
11 A
Marshall Beers was the group supervisor
.12 in charge of license training.
13 Q
Mr. Zechman, during Mr. Fiske's direct 14 examination, you were asked a number of questions 15 regarding specific operating procedures and emergency 16 procedures for TMI Unit 2.
17 Did you teach any operating procedures 18 or emergency procedures at any time prior to the Three 19 Mile Island accident?
20 A
No, sir.
ggg 21 Q
I would like you to refer for a moment to 22 pages 91 to 93 of the transcript of your testimony 23 taken by Mr. Fiske, and particularly note the testimony
(~}
24 at the top of page 93, the first answer, in which as V
25 part of the answer, you said, "A lot of the training
1 Zechman 794
(_-
2 was conducted by the line function itself or people 3
being sent off to offsite schools."
4 MR. FISKE:
Why don't you read the 5
whole answer, Mr. Glassman.
6 MR. GLASSMAN:
You are entitled to read 7
the whole answer.
There is no secret here, 8
Mr. Fiske.
9 Q
The first part of the answer says, "I
have 10 no recollection of what training they had during that 11 time.
A lot of the training was conducted by the
.12 line function itself or people being sent off to 13 offsite schools."
14 Perhaps we should, to clarify this 15 further, read the question and answer.
16 MR. FISKE:
Why don't you do that.
17 Q
The question, which starts on page 92, 18 says:
19 "Was any training program conducted for l
20 the staff chemists and radiation protection gg 21 supervisory staff and the analysts and 22 radiation protection non-supervisory technicians l
23 during that period of time?
24
" Answer:
I have no recollection of what 25 training they had during that time.
A lot of l
1 Zechman 795
('%
Y-2 the training was conducted by the line function 3
itself or people being sent off to offsite 4
schools."
5 Further down the page, the following 6
question and answer appear 7
" Question:
Was there any kind of an 8
organizational structure for the administration 9
of training at Met Ed so that whereby some 10 training was done outside of the Training 11 Department of which you were Supervisor?
12
" Answer:
Each line function that is, 13 whether it t the Maintenance Department, 14 Chemistry Department, Radiation Protection 15 Department, had the liberty, and often did to, 16 send their people to offsite schools, outside 17 the initiation by us.
We would receive the l
18 final documentation of their attending those 19 schools.
20
" Question:
That was not done for a i
ggg 21 shift foreman and shift supervisors and control 22 room operators and auxiliary room operators?
23
" Answer:
No, the line function had the
(^)T 24 same liberty."
\\_
25 Do you recall those questions and those
1 2echman 796 (O
2 answers?
A Yes, sir.
3 4
Q During the time that you were acting "5
supervisor and then supervisor of training, what type 6
f training was perf rmed by the line function for y
operators?
E A
For operators?
9 Q
Yes.
l 10 A
There are occasions when the shift foreman i
11 or the shift supervisor or the supervisor of c12 operations conducted on-the-job training programs or LJ 13 special lectures while on shift, and when they did so, 14 if they wanted that documentation to appear in the 15 resume file of the individuals, they would submit the 16 documentation in attendance forms to the training i
17 department for permanent filing.
18 Q
Did the training department keep track of 19 on-the-job training for the operators?
A Are you re ferring to that conducted by 20 21 the on-shift personnel?
g 22 Q
Yes, I am.
23 A
If it was their desire to have that y
documented, they would send it to us and we would file 25 it and make it a part of the record.
l
1 Zechman 797
\\'
2 Q
In what situations would that be documented?
3 A
well, as an example, I believe they 4
conducted, if my memory serves me well, somewhere 5
prior to the accident they conducted an on-shift 6
training program on standard tech specs and that would 7
have been documented and sent to us.
8 Q
By "on-shift training program on standard 9
tech specs" are you referring to a program that 10 includes lectures?
11 MR. FISKE:
I didn't hear that question.
.12 (Question read.)
(')s
\\-
13 A
It -- I don't recall at this time exactly 14 the mode.
It was either lecture series or in a 15 seminar-type mode.
16 Q
Were these part of the regular Met Ed 17 training programs?
18 MR. FISKE:
I don't understand what you mean 19 by the question, Mr. Glassman, by the " regular 20 Met Ed training program."
21 Q
Were these part of any normal Met Ed g
1 22 training program, Mr. Zechman?
23 A
It was above and beyond.
In that particular
/ T 24 case, I believe it was above and beyond what was V
25 required.
They certainly took credit for it and it J-
1 Zechman 798 O(_)
2 became part of the record.
And by "above and beyond" s
3' I mean it was their program that they set up in 4
addition to what other material was taught in their 5
programs.
6 Q
You referred to on-the-job training.
Is 7
that referred to anywhere in the FSAR training 8
section?
9 A
Yes, sir.
10 Q
Could you tell us where that is?
You may 11 refer again to B&W 260.
,12-A Yes, that is referred to on page 13.2-9, i
13 section ~13.2.2.3 entitled "on-The-Job Training."
14 Q
Did the training department keep track of 15 on-the-job training?
16 A
Yes, sir, they did.
l l
17 Q
In what manner was that, during the period
(
18 that you were acting supervisor?
19 A
During that period, Mr. Nelson Brown had l
2G the responsibility of auditing the on-the-job training i
gg 21 program.
22 Q
Do you know the manner in which that 23 function was carried out?
24 A
Yes, sir, there were two modes of it.
x_/
25 One was the simulator training which people received
1 Zechman 799
,/
2 at the simulator.
That was one part of it.
The 3
second part of it was that each licensed operator 4
maintained a booklet in the control room in which he 5
kept a log of the evolutions, maj or evolutions that 6
he performed to show diversification of experience, 7
and on a quarterly basis Mr. Brown would audit those 8
and make sure that the individuals underlying function g
was aware of any delinquencies or makeup that had to 10 be taken care of.
11 Q
Mr. Zechman, I would like you to refer 12 to page 299 of the transcript of your direct
()
13 examination in this case.
And with regard to a 14 period before the accident, there is a question and 15 answer which begins on line 4 of page 299 which 16 reads as follows:
l I
17
" Question:
During that period of time, did 18 you consider that it was worthwhile for the 19 licensed operators to have training on the B&W l
20 simulator?
l 21
" Answer:
I believe the simulator provided ggg 22 a very useful tool for the operators.
We relied i
23 extremely on the training we received from B&W l
l l
24 and the operation of the B&W system.
We relied s
1
\\~
25 heavily on the operation of that simulator."
l
1 Zechman 800
.s()
2 Do you recall that question and that 3
answer?
4 A
Yes, sir.
5 Q
Did you in fact rely on training you 6
received from B&W and the operation of the B&W 7
system, did you rely heavily on the operation of the 8
simulator during the period you were acting g
supervisor or then supervisor of training for Met Ed?
10 MR. FISKE:
Who is "you"?
11 MR. GLASSMAN:
Met Ed.
12 A
Yes, Met Ed did.
(O 13 Q
Why?
%J 14 A
Because it allowed the operators and the 15 shift supervisors and shift foreman an opportunity 16 to practice plant transients, abnormal and emergency 17 t ran sients that normally you would not practice on 18 an operating plant.
19 Q
Why would you not practice that on a 20 normal operating plant?
21 A
Because you don't want to put an operating g
22 plant purposely through emergency-type transients or 23 abnormal conditions.
24 Q
Did this simulator training at the B&W 7-U 25 simulator provide training that could not be adequately
1 Zechman 801
)
2 provided for by lectures?
3 A
Lectures certainly could be given on plant 4
transients, but the difference between discussing 5
them and actually having hands-on training is 6
certainly different.
The ability to use the simulator 7
to practice those transients with hands-on experience 8
is what I was referring to as valuable.
9 Q
When you refer to " plant transients,"
10 what do you mean by that term?
11 A
What I am saying is abnormal conditions, 12 non-normal emergency-type conditions, m
13 Q
Before the accident, were operators for 14 Met Ed sent to the B&W simulator in conjunction with 15 any particular Met Ed training programs?
16 A
Yes, sir, they were.
17 Q
What programs?
18 A
They were sent to -- are you referring to 19 Unit 2 or Unit 1 or both?
i 20 Q
Let's try both, 21 A
All right.
For both, at various times they ggg 22 were sent to the simulator.
The CRO's -- the initial t
l 23 CRO's and shift supervisors for Unit 1 and Unit 2 gy 24 had participated in initial simulator training programs U
25 which were called license programs.
We sent
1 zechman 802
^
\\
2 individuals to the simulator as part of the 3
requalification program and a requirement for a 4
start-up certification, that is, for -- after the plant 5
was commencial and we were certifying new CRO's getting 6
them prepared for the NRC exam -- they would have to 7
be certified, what was referred to as a start-up 8
certification -- and we relied on B&W simulator 9
personnel to provide that certification training for 9
10 the exam.
11 Q
In your last answer you referred to an
.12
" initial simulator program."
(~h
(,)
13 Could you briefly describe what you mean 14 by that?
15 A
By that I meant there was initial training 16 programs.
For example, the Unit 2 operators, to the 17 best of'my recollection, attended an eight-week 18 initial program at B&W which included both classroom 19 instruction and hands-on training on the simulator 20 as part of their cold licensing program.
21 Q
When you refer to simulator training with g
22 regard to the requalification program, is that separate 23 from the initial simulator program?
24 A
Yes, sir.
C( s 25 Q
when you refer to start-up certification,
1 zechman 803
(~
i 2
is that separate from the initial simulator program 3
and the requalification program simulator training?
4 A
Yes, sir.
5 Q
Did you ever go to the simulator 6
personally?
I am talking about the B&W simulator.
7 A
Yes, sir.
8 Q
Did you have contact there with B&W 9
personnel?
10 A
Yes, sir.
11 Q
With what B&W personnel did you have
.12 contact at the simulator?
f3
(,
13 A
Well, over the years, starting in the 14 pre-commercial days for Unit 1,
I interfaced with the 15 I don't recall whether he was manager of training or 16 director of training -- Mr. George Stall, whom I 17 interfaced with in the initial phases setting up 18 schedules and training that they would provide, and l
19 in later years I interfaced with Norm Elliott and some 20 of the lead instructors like Walt Perks and Mr. Lynn.
21 Q
When you say "later years," roughly what l
22 years are you speaking of?
23 A
Well, I am talking about the '78-79 period.
(~~JN, 24 There were times throughout from the early days of
\\~
25 Unit 1 through Unit 2 that I at various times talked
1 Zechman 804 2
to them.
3 Q
By "them," whom are you now referring to?
4 A
I am referring to sither the lead 5
instructors or personnel who were in charge of the 6
simulator training group.
7 Q
You mentioned Norm Elliott.
Do you know 8
what position he held at B&W7 9
A Manager of training.
10 Q
What, to your best recollection, is the 11 period of time you dealt with him?
.12 A
I don't recall the year that he took 13 over the manager position with B&W but I know that 14 when he first took over and various periods from that l
15 time on, I interfaced with Mr. Elliott at different 16 times.
17 Q
Could you describe the nature of your 18 interface with Mr. Elliott?
i 19 A
Y e s..
Most of the time it had to do with a i
20 scheduling of requalification personnel or initial 1
21 training programs at the simulator or special programs g
l 22 that they conducted on site for us over the years, and l
23 I also interfaced with him on the day that I was 24 certified, received my start-up certification he was 25 my examiner.
1 zechman 805 (cmi
\\/
2 Q
You said that you dealt with him in 3
scheduling of requalification personnel at the B&W 4
simulators is that correct?
5 A
That is correct.
6 Q
Could you describe what you mean by that?
7 A
Well, yes.
Normally, a year, almost a 8
year in advance, we would schedule various blocks 9
of time in which we could send our, both Unit 1 and 10 Unit 2, licensed personnel to the simulator for 11 requalification training.
During those times, I would 12 at times interface with him, at times I would 13 interface with the lead instructor.
Also in any 14 special programs that they may have conducted during 15 that time or initial training programs.
I also --
16 there were other occasions, too; I believe, if my 17 recollection is correct, that the rad chem techs 18 were sent to B&W programs on radiochemistry and I 19 believe I interfaced with Mr. Elliott on the scheduling l
20 of that also.
9 21 Q
Did you interface with Mr. Elliott, B&W's 22 manager of training, during the period that you were 23 supervisor of training, either acting supervisor of 24 training or supervisor of training?
25 A
To the best of my recollection, I did, J
1 Zechman 806 2
and was again in the scheduling of personnel that 3
were going down either for requalification or for 4
start-up certification.
I believe I had discussions 5
with him at that time.
6 Q
I believe that you also testified a few 7
moments ago that you had some interface with Mr.
8 Elliott with regard to a start-up certification exam; 9
is that correct?
10 A
That is correct.
11 Q
When was that?
12 A
That was in 1978.
I don't remember the
(~'T
(_)
13 exact month.
14 Q
Was this a face-to-face interface?
15 A
It was the day of the exam.
He was the 16 examiner that essentially put me through the paces on 17 the simulator and was giving me the examination.
18 Q
At Lynchburg, Virginia?
19 A
It was on the B&W simulator at Lynchburg, 20 Virginia.
gg 21 Q
Could you briefly describe to us what 22 happened that day in terms of your interface with 23 Mr. Elliott?
24 A
Well, it was the day on which I was taking 25 the start-up certification, which involved taking
1 Zechman 807 (3
(_/
2 the reactor from a suberitical state to critical 3
and up to the point of low power and following the 4
procedures to do so, and it was during that time 5
that Mr. Elliott would co$tinually ask questions on 6
what you are observing and if there are any alarms 7
what they would be, and what the importance of the 8
alarms was.
It was a typical start-up certification 9
program to insure that one was capable of going 10 through those evolutions.
11 Q
Was this during the period that you were 12 studying to obtain your license?
()
13 A
Yes, sir, it was.
14 Q
At any time before the TMI accident, did 15 anyone from B&W ever tell you of a transient at 16 Davis-Besse in or about September or October of 19777 17 A
No, sir.
18 Q
At any time before the TMI-2 accident, 19 did Mr. Elliott, B&W's manager of training, ever tell you 20 of a transient at Davis-Besse in or about September 21 or October of 19777 l
22 A
No, sir.
23 Q
Before the TMI-2 accident, did anyone 24 from B&W ever tell you of an event at Davis-Besse where J
25 operators were confused by a rise in pressurizer level?
i Zechman 808 ry 2
A No, sir.
3 Q
Did Mr. Elliott, B&W's manager of training, 4
ever tell you before the accident that there had been 5
an event at Davis-Besse where operators were confused 6
by a rise in pressurizer level?
7 A
No, sir.
8 Q
Before the TMI-2 accident, did anyone 9
from B&W ever tell you that operators at Davis-Besse 10 had prematurely terminated high pressure injection?
11 A
No, sir.
712 Q
Mr. Elliott, B&W's manager of training, 13 never told you that?
14 A
No, sir.
15 Q
Before the TMI-2 accident, did anybody 16 from B&W ever tell you that operators at Davis-Besse 17 had taken inappropriate action in terminating high 18 pressure injection?
19 A
No, sir.
20 Q
Before the TMI-2 accident, did Mr. Elliott, gg 21 B&W's manager of training, ever tell you that 22 operators at Davis-Besse had taken inappropriate 23 action in terminating high pressure injection?
24 A
No, sir.
25 Q
Before the TMI-2 accident, did anyone from
1 Zechman 809 I
(~h
(-)
2 B&W ever warn you of a danger of inappropriate 3
operator accion if pressurizer level had gone up and 4
pressure was down ?
5 A
No, sir.
6 Q
Before the TMI-2 accident, did Mr. Elliott, 7
B&W's manager of training, ever warn you of a danger 8
of inappropriate operator action if pressurizer level 9
was up and if pressure was down?
10 A
No, sir.
11
-Q Mr. Zechman, I am going to read to you
.12 for a moment from a document which has previously 13 been marked as GPU Exhibit 76, which is a November 1,
14 1977 memorandum from J.
J.
Kelly of plant integration 15 of Babcock & Wilcox Company to distribution, subject, 16
" Customer Guidance On High Pressure Injection Operation,"
17 customer, generic, and with a distribution list which 18 includes some seven people, including N.
S.
Elliott.
19 The first paragraph of the document reads 20 as follows:
"Two recent events at the Toledo site (gg 21 have pointed out that perhaps we are not giving our 22 customers enough guidance on the operation of the high 23 pressure injection system.
On September 24, 1977,
/'~T 24 after depressurizing due to a stuck open electromatic V
25
- relief valve, high pressure injection was automatically
1 Zechman 810
\\_-
2 initiated.
The operator stopped HPI when pressurizer 3
level began to recover, without regard to primary 4
pressure.
As a result, the transient continued on 5
with boiling in the RCS, etc.
In a similar occurrence 6
on October 23, 1977, the operator bypassed high 7
pressure injection to prevent initiation, even though 8
reactor coolant system pressure went below the 9
actuation point."
10 Prior to the TMI-2 accident, did anyone 11 at B&W ever tell you in words or substance the
.12 information which I just read to you from GPU Exhibit (D
(_j 13 76, a copy of which was distributed to N.
S.
Elliott?
14 A
No, sir.
15 Q
Prior to the TMI-2 accident, did Mr.
l 16 Elliott, B&W's manager of training, ever tell you in 17 words or substance the information which I just read 18 to you from GPU Exhibit 767 19 A
No, sir.
20 Q
Mr. Zechman, I am going to read very
)
21 briefly from another memorandum which has been 22 previously marked as GPU Exhibit 78, which is a 23 February 9, 1978 memorandum from Bert M.
- Dunn,
(~N 24 manager of ECCS analysis, Babcock & Wilcox Company,
\\~]
25 to Jim Taylor, manager, licensing.
Subject:
" operator
1 Zechman 811
/~N k-2 Interruption of High Pressure Injection."
It begins 3
with the statement, "This memo addresses a serious 4
concern within ECCS Analysis about the potential for 5
operator action to terminate high pressure injection 6
following the initial stage of a LOCA."
It continues 7
and the following paragraph begins with the following 8
sentences: "The direct concern here rose out of the o
recent incident at Toledo.
During the accident 10 the operator terminated high pressure injection due to 11 an apparent system recovery indicated by high level 12 within the pressurizer.
It continues.
13 Mr. Fiske is, of course, free to refer to 14 any portion he wishes, but at the end of that same 15 paragraph, it says, "I believe it fortunate that t
I 16 Toledo was at an extremely low power and extremely low 17 burnup.
Had this event occurred in a reactor at full 18 power with other than insignificant burnup it is quite 19 possible, perhaps probable, that core uncovery and 20 possible fuel damage would have resulted."
ggg 21 At any time prior to the Three Mile Island 22 accident, did anyone from B&W tell you in words or 23 substance the information which I just read to you
/~}
24 from GPU 787 N) 25 A
No, sir.
1 Zechman 812 O)
(_,
2 Q
Did Mr. Elliott, B&W's manager of 3
training, ever tell you that information in words 4
or substance?
5 A
No, sir.
6 Q
I will read one more sentence in the last 7
paragraph, page 1,
of GPU Exhibit 78, which reads as 8
follows:
"The incident points out that we have not 9
supplied sufficient information to reactor operators 10 in the area of recovery from LOCA."
11 Prior to the TMI-2 accident, did anyone 12 from B&W tell you that, in words or substance, an
()
13 incident at another plant had pointed out that "we 14 have not supplied sufficient information to reactor 15 operators in the area of recovery from LOCA"?
16 A
No, sir.
17 Q
Prior to the TMI-2 accident, did Mr.
l 18 Elliott ever tell you that there was an incident at 19 another plant which pointed out that "we,"
B&W, "have 20 not supplied sufficient information to reactor gg 21 operators in the area of recovery from LOCA"?
22 A
No, sir.
23 Q
I am going to read very briefly from one 24 further memorandum, which was previously marked as 25 GPU Exhibit 79 for identification.
This is a
1 Zechman 813 O(-)
2 February 16, 1978 memorandum from Bert M.
- Dunn, 3
manager of ECCS analysis, Babcock & Wilcox, to Jim 4
Taylor, manager, receiving, subject, " Operator 5
Interruption of High Pressure Injection."
The memo 6
refers to a " recommended" procedure for terminating 7
high pfessure injection following a LOCA and under 8
paragraph 2 of the memorandum it states the following:
9 "At X minutes following the initiation of high 10 pressure injection, termination is allowed provided 11 the hot leg temperature indication plus appropriate
.12 instrument error is more than 50 degrees below the i
13 saturation temperature corresponding to the reactor 14 coolant system pressure less instrument error."
15 At any time prior to the TMI-2 accident, 16 did anyone at B&W ever conveyoto you that information?
17 A
No, sir.
18 Q
Did Mr. Elliott, B&W's manager of training, I
19 ever convey to you,that information prior to the TMI-2 20 accident?
l ggg 21 A
No, sir.
22 (Recess taken.)
l l
23 Q
Mr. Zechman, during the period that you 1
("N 24 were acting supervisor and then supervisor of training,
\\_)
25 an d I am particularly focusing on the period from l
l
1 Zechman 814
/~s
(
)
s/
2 November '77 through the day of the accident, did 3
any Met Ed employees from outside the Met Ed training 4
program audit the Met Ed training program?
5 A
You mean outside the training department?
6 Q
Yes.
7 A
Yes.
We had audits from the QA department; 8
quality assurance.
9 MR. GLASSMAN:
I would like to have t
10 marked as GPU Exhibit 509 for identification 11 a Metropolitan Edison Company memorandum dated
.12 June 9,
1978.
l
(~
l
(
13 (Metropolitan Edison Company memorandum l
14 dated June 9,
1978 was marked as GPU Exhibit l
15 509 for identification, as of this date.)
16 Q
Mr. Zechman, I show you what has been 17 marked as GPU Exhibit 509 for identification.
l 18 Can you tell us what this document is?
l 19 A
Yes, this was a follow-up audit summary 20 document prepared by the quality assurance department.
21 Q
Have you seen this document before?
g 22 A
Yes, sir.
23 Q
When did you see it?
(~
24 A
I saw it at some period of time when it 25 was carbon copied and sent to me in the June '78 1
1 Zechman 815 Od period.
2 MR. GLASSMAN:
Would you read back the 3
last two questions and answers.
h (Record read.1 Q
Mr. Zechman, I would like you to refer to page 3 of GPU Exhibit 509.
It has been marked for identification at the bottom page, 12440412 for purposes of litigation.
Under the heading VI,
" Personnel Present at the Post Audit Review Held on 3/31/78 at TMI," an R.
W.
Zechman appears.
Does that refer to you?
("
l A
Yes, sir, it does.
Q Were you present at a post audit review?
i A
To the best of my recollection.
l 15 l
Q Were you present at a post audit review held on or about March 31, 1978?
A I don't recall what the date was but I g
l recall being at this particular one.
I 19 Q
I will read from page 3 several paragraphs j
under the heading, "AP 1006, Rev. 2 - Requalification e
21 1
Program."
But before I do that, I would just like to 22 ask you, before the accident did you have an l
understanding of what was meant by AP 1006, Rev. 27 A
Yes, that was the requalification l
1 Zechman 816 OV 2
procedure.
3 Q
What does AP stand for?
4 A
That is " administrative procedure."
5 Q
Can you describe for us generally what 6
was contained in that procedure?
7 A
Yes, it was the complete description and 8
requirements of the requalification program for 9
licensed operators.
10 MR. FISKE:
Mr. Glassman, for purposes 11 of this deposition, if you want to read portions
.12 of this exhibit to Mr. Zechman, I am sure you
(
)
\\/
13 are free to do it at this point.
I think it 14 should be understood, of course, that this 15 document has not been qualified in any way 16 and I don't think Mr. Zechman is in a position l
17 to do that.
At this point it is simply hearsay.
18 MR. GLASSMAN:
Well, Mr. Fiske, as you 19 know, I have not yet asked him a particular l
20 follow-up question about the document.
I will lll 21 ask him certain questions and obviously there 22 are other things that may or may not be subject i
23 to connection.
(JD 24 MR. FISKE:
I take it this document is 25 referring to an audit that Mr. Zechman did not
1 Zechman 817 2
conduct?
3 MR. GLASSMAN:
I think Mr. Zechman has 4
testified as to who conducted the audit and 5
I don't think we have any secrets here, Mr.
6 Fiske.
The precise nature of the questions 7
were with regard to audits of the training 8
program conducted by persons within Met Ed who g
were outside of the training department.
10 Q
Mr. Zechman, at the bottom of the page 11 under the list of carbon copies, there is an R.
W.
- 12 Zechman listed there.
Is that you?
kg) 13 A
Yes, sir.
14 Q
Is it your testimony that you did receive 15 a copy of this document at some time prior to the 16 TMI accident?
j 17 A
Yes, sir.
18 Q
was that received in the ordinary course 19 of business?
20 A
Yes, sir.
(gg 21 Q
I would like to now read from paragraphs 22 under the heading, "AP 1006, Rev. 2 Requalification 23 Program," contained on page 3 of GPU Exhibit 509.
(
24 It reads as follows:
"The portion of the audit 25 pertaining to operator Requalification was conducted
1 zechman 818 (D
()
2 on March 2 and 3, 1978 at TMI.
The adequacy of and 3
compliance with AP 1006 was probed and determined to 4
be satisfactory.
The training records and training 5
lessons of fifteen (15) randomly chosen employees for 6
the 1977 Training Cycle (March 1,
1977 through March 1,
7 1978) were reviewed.
With the exception of three (3) 8 persons, all personnel either attended the training 9
lesson or made up the required training in a timely 10 manner.
11 "Two (2) of the three (3) persons 12 subsequent to the audit made up the required lessons
()
13 and the third person is allowing his license to lapse.
14 "Those Personnel licensed late in the 15 Cycle, were phrased into the remaining lessons of the 16 Cycle.
They will be matriculated into the 1978 Cycle, 17 beginning March 1,
1978."
18 Mr. Zechman, do you have any information 19 that would contradict any of the conclusions in the 20 paragraphs that I have just read to you?
l gg 21 MR. FISKE:
You mean apart from 22 everything that he testified to on his direct 23 examination?
24 MR. GLASSMAN:
I don't think there was C>s 25 anything that he testified to that was I
1 Zechman 819
(/
~
)
N.
2 contradictory, Mr. Fiske.
That is purely 3
gratuitous.
If you have anything else you 4
would like to pursue that you think is relevant, 5
you have a chance to do that, as you know.
I 6
don't think it is appropriate for you to 7
interrupt the cross, as we have tried not to 8
interrupt the direct.
9 MR. FISKE:
I want to make sure I know 10 what the scope of your question is.
11 MR. GLASSMAN:
The scope of my question is 12 very clear and broad.
~n
)
13 THE WITNESS:
What was the question?
14 MR. GLASSMAN:
Will the reporter please 15 retype the question into the transcript.
16 MR. FISKE:
I would like to hear it again 17 myself.
18 (Question read.)
19 MR. FISKE:
Is that singular or plural?
20 MR. GLASSMAN:
Singular.
)
21 MR. FISKE:
Are you talking about the 22 three paragraphs under "AP 1006, Rev. 2 23 Requalification Program"?
(')
24 MR. GLASSMAN:
Yes.
V 25 THE WITNESS:
Could I hear the question
1 Zechman 820 (m
'~
2 again, please?
3 (The reporter read back the question as 4
follows:
"Mr.
Zechman, do you have any 9
5 information that would contradicc any of the 6
conclusions in the paragraphs that I have just 7
read to you?")
8 A
No.
9 Q
Mr. Zechman, during the period that you 10 were acting supervisor of training and as supervisor 11 of training, was the Met Ed training program ever
- 12 inspected or audited by a person outside of GPU?
(~)
'\\_/
13 A
Yes, sir, they were audited by the NRC, 14 the Nuclear Regulatory Commission.
15 A
Do you recall when such audits took place?
16 A
I believe there were two.
I think they 17 were '77 or '78 or both were in
'78.
I don't recall i
18 exactly.
19 Q
Do you recall the purpose of those audits?
20 A
Yes, sir, the purpose of the audits was l
21 to -- I believe one of them was to verify the 22 initial training programs and I believe one of them l
23 was to -- was an' audit of the requalification program.
1
(
24 Q
Did you participate in any fashion in 25 those audits?
l 1
zechman 821
(
}
2 A
Yes, sir, I did.
~-
3 Q
Can you describe for us what your 4
participation was?
5 A
My participation was to meet with the 6
NRC inspector and insure that whatever he wanted to 7
see or documentation that he wanted to ese was 8
available to him.
9 Q
Did you in fact supply information to 10 the NRC personnel?
11 A
Our department supplied it t7 them, yes, 12 sir.
13 Q
Do you know if the NRC personnel ever 14 actually went into the plant during the course of the 15 audits?
16 A
Yes, in some of the audits, I don't recall l
i 17 which ones, they actually went into the plant and 18 verified with individuals that the training that they 19 verified on records was also verified by the individuals 20 that the records showed having the training.
21 MR. FISKE:
Just for the record at this 22 point, I know all the objections are reserved 23 to the trial, but I am going to note an objection, 24 just if it will help you in your questioning, 25 to Mr. Zechman's description of what the NRC did.
1 Ze chman 822 1
r8 2
I don't think he is competent to describe that 3
unless he was with them personally and went 4
around and did it.
5 Q
what is the basis of your testimony that 6
the NRC personnel actually went into the plant?
7 A
From recollection of the follow-up report 8
that was written, 9
Q Did you actually receive copies of 10 follow-up reports written by the NRC?
11 A
Yes, sir.
.12 Q
To your knowledge, did the NRC ever find h) x_
13 deficiencies in the Met Ed training program in the 14 course of these audits?
15 A
No, sir.
16 MR. GLASSMAN:
I would like to have a 17 document marked as GPU 510, dated March 4, 18 1977.
19 (Document dated March 4, 1977 from the 1
i l
20 Nuclear Regulatory Commission to Metropolitan lll 21 Edison Company was marked as GPU Exhibit 510 22 for identification, as of this date.)
23 Q
Mr. Zechman, I show you what has been
()
24 marked as GPU Exhibit 510 for identification.
Can 25 you tell us what that document is?
1 Zechman 823
(
~
2 A
Yes, this was an NRC inspection report, 3
follow-up report of their inspection.
4 Q
Have you ever seen this document before?
O 5
A Yes, sir, I had.
6 Q
Had you seen it before the accident?
7 A
Yes, sir.
8 Q
How did you obtain a copy of it?
9 A
A copy was sent to me.
10 Q
I would like you to refer for a moment to 11 page 8 of this document under the heading No.
4,
.12
" Operator Staff Training (Unit 2)."
N/
13 MR. FISKE:
I just note, Mr. Glassman, that 14 I would have the same objection to use of this 15 exhibit that I did to the prior one.
This is 16 obviously a report prepared not by Mr.
17 Zechman but by the Nuclear Regulatory Commission.
18 MR. GLASSMAN:
We are not contending 19 that Mr. Zechman prepared the report.
20 MR. FISKE:
I understand that but, go ahead, lll 21 you can ask, whatever questions you want.
22 BY MR. GLASSMAN:
23 Q
Reading from page 8,
paragraph 4, under (i
24 the heading " Operator Staff Training (Unit 2),"
the 25 document says, "The inspector verified that training
1 Zechman 024 2
commitments in the FSAR, Section 13.2 had been 3
established and conducted commensurate with the time 4
prior to licensing.
Responsibilities for 5
administration / evaluation had been assigned in this 6
area."
7 Do you have any information which would 8
contradict that finding?
9 A
No, sir.
10 Q
Referring to the next page of this il document, page 9,
under the heading, "On-The-Job 12 Training," it says, "The FSAR commitments for
(
13 on-the-job training had been established and carried 14 out for personnel in the following classifications:
15 control room operators; auxiliary operators; 16 mechanical maintenance personnel; electrical l
17 maintenance personnels technicians; QA/QC personnel; 18 and other members of the technical staff.
l l
l 19 MR. FISKE:
What page is this?
20 MR. GLASSMAN:
This is page 9.
gg 21 MR. FIS KE :
Small b.
l 22 Q
And after the material I just read, the 23 report continues, "The inspector identified no 24 discrepancies."
p l
\\_J l
25 Do you have any information which would
na 1
zechman 825 2
contradict that conclusion?
3 A
No, sir.
4 MR. FISKE:
You mean information that 5
would contradict whether the inspector 6
identified any discrepancies?
i 7
MR. GLASSMAN:
That's correct.
8 MR. FISKE:
I have no objection to that 9
other than the basic objection to the use of 10 this document.
11 MR. GLASSMAN:
I would like to have 12 identified as GPU Exhibit 511 for identification
()
13 a document dated 25/May/1978.
14 (Document dated May 25, 1978, from_the 15 Nuclear Regulatory Commission to* Metropolitan 16 Edison Company was marked as GPU Exhibit 511 17 for identification, as of this date.)
18 Q
Mr. Zechman, I show you what has been 19 marked as GPU Exhibit 511 for identification.
20 Can you tell us what that is?
qg 21 A
Yes, this is another NRC -- I believe this 22 was an unannounced inspection and this is a follow-up l
23 this is the follow-up report of that inspection.
24 Q
What do you mean by " unannounced inspection"?'
-)
x/
25 A
well, the NRC reserves the right to come in
1 Zechman 826 (D
5/
2 at any time they ddsire and inspect the conduct of 3
the operations at the facility, including training.
4 Q
Did you receive a copy of this document 5
at any time before the accident?
6 A
Yes, sir, I did.
7 Q
on the front page at the top of the 8
document, there is in handwriting a "CC" with a number 9
of initials including RWZ.
10 Are those your initials?
11 A
Those are my initials.
.12 Q
'Did you in fact receive a copy of this I
(,
13 document.at some time before the accident?
g 14 A
Yes, sir, I did.
15 i
Q Mr. Zechman, did you participate in any l
16-fashion in this audit?
j 17 A
Yes, sir,fI did.
l 18 Q
What did you do?
19 A
I interfaced with the NRC inspector and 20 provided him with whatever information he was lll 21 pursuing at that' time.
22 Q
'C7.n you tell us generally what kind of 23 information you prov3ded?
l l
l
(~h 24 A
?e vas looking at requalification records G'
25 and the requalification training program in both 1
1
+
1 Zechman 827 (D
\\J 2
Units 1 and 2.
3 Q
I would like you to refer for a moment 4
to the page that is marked at the bottom, for purposes 5
of this litigation, 11630997.
6 Do you have that page in front of you?
7 A
Yes.
8 Q
Under the heading, " Persons Contacted,"
9 at the very bottom of that list there is a reference 10 to an R.
Zechman, Supervisor Training.
11 Does that refer to you?
.12 A
Yes, sir.
/~
(N_)
13 Q
There is an asterisk there that says, l
14
"* denotes those present at the exit interview."
15 were you present at an exit interview?
16 A
Yes, sir.
17 Q
Can you describe for us the nature of 18 the exit interview?
l 19 A
Yes, the nature of the exit interview was 20 to summarize the results of their inspection and to
)
21 outline any findings and to have an interface to make 22 sure there are no misunderstandings and that everybody l
23 understood what they were looking for and the results
(~}
24 of what they found.
%./
25 Q
I would like you to refer now to the page l
l
1 zechman 828
('h
(_)
2 marked, for purposes of this litigation, 11630996.
It 3
is the page just before the one we were looking at.
4 On that page under the heading " Inspection 5
Summary" there appears the following paragraph:
6
" Inspection on May 9-12, 1978 (Combined Report Nos.
7 5 0-2 89/78-0 9 and 5 0-32 0/78-18) Areas Inspected:
8 Routine, unannounced inspection of licensed operator 9
requalification training, general employee training, 10 craft personnel training, quality assurance for the 11 Startup Test Program, startup test records, and licensee 12 action on previous inspection findings.
The inspection
()
13
. involved 33.5 inspector-hours onsite by one NRC 14 inspector."
15 Do you see that?
16 A
Yes, sir.
17 Q
Under that there appears a heading, 18 "Results," underlined, and after that a colon, and it 19 reads, "No $tems of noncompliance were identified."
20 Do you see that?
21 A
Yes, sir.
22 Q
Do you have any information which 23 contradicts the results of this inspection?
~
24 MR. FISKE:
I just note the same point 25 I made be fore, Mr. Glassman.
l
1 Zechman 828-A 2
A No, sir.
3 (At this time, 12:15 p.m.,
a luncheon 4
recess was taken.)
5 6
7 8
9 10 11 12 13 14 15 16 17 18 19 20 g
21 22 23 24 25
1 829
(%
()
2 AFTERNOON SESSION 3
2iOO p.m.
4 RI CHA RD W.
- ZECHMAN, resumed.
5 EXAMINATION (continued) 6 BY MR. GLASSMAN:
7 Q
Mr. Zechman, I show you a copy of what 8
has previously been marked as B&W 5 6 7 ', which is a 9
memo from Sandy Lawyer to J.
Thorpe, subject, "Penn 10 State committee -- Initial Draft Report," dated 11 January 24, 1980, with an attachment, multipage 12 attachment entitled "Penn State Pedogogical Review of
(%x -)
13 Operator Training," dated January 22, 1980.
/
14 Do you have this in front of you?
15 A
Yes, I do.
16 Q
I also show you a copy of what has 17 previously been marked as B&W 568 for identification, 18 which is a February 6, 1980 memorandum from Richard 19 W.
Zechman to Doc Smith, subject, " Comments Penn 20 State review Committee Report."
21 Do you have this in front of you?
9 22 A
Yes, I do.
23 Q
Will you take just a few moments to review 24 that.
I would like to ask you whether you now recall b)
\\,_
25 whether or not B&W 568 represented your written
1 Zochacn 830 en
(
)
2 comments with regard to the document which has been N_/
marked B&W 567.
3 4
MR. FISKE:
Could I hear the question dk 5
8981"*
I 6
(Question read.)
7 A
To the best of my recollection, it does.
8 Q
In his direct examination, Mr. Fiske asked 9
you some questions with regard to these documents.
10 I would like to ask you a few more now.
11 B&W 568 contains a number of items 12 followed by page numbers and comments under separate
/ "N 13 columns.
The first item refers to paragraph 4, line3 N.)
14 of page 3.
I would like you to refer to B&W 567, 15 page 3, paragraph 4, line 3,
and tell us if you could 16 to what item in B&W 567 you were referring.
17 A
That was a sentence in subparagraph a),
18 which starts out with "the program is largely 19 descriptive in nature.
That is, little emphasis is 20 given to problem solving."
I was referring to the 21 sentence "That is, little emphasis is given to problem 22 solving."
23 Q
What'was your written comment on that?
24 A
My written comment is, "In actual practice 7-(
)
25 and past experience the need for CRO's/SRO's to solve
1 Zechman 831
\\p/
2 math problems associated with plant operation is estimated to be less than 0.5 percent of their time."
3 4
Q Could you tell us what you intended by 5
that comment?
6 A
Yes.
In their training programs they did 7
problem solving and then at the simulator they did g
problem solving on reactivity problems and so forth, 9
but in actual practice on the job there was very 10 little math associated with those positions on the 11 job, and that is what I was referring to.
12 Q
Did you discuss your comment with anyone
(<\\)
13 from Penn State?
\\_/
14 A
Yes, sir, I did.
15 Q
With whom?
16 A
With Mr. Gordon Robinson.
17 Q
Did you discuss this particular comment 18 under item 17 19 A
Yes, I did.
20 Q
Do you recall what you said to Mr. Robinson I
21 and what he said to you?
22 MR. FISKE:
Mr. Glassman, this is l
23 discovery.
I am happy to have it on the record.
/~s 24 It is o3viously not competent testimony at trial.
.b 25 Go ahead.
l
1 Zachmen 832
'N
[O 2
MR. GLASSMAN:
I am not sure what the 3
nature of your objection is, Mr. Fiske.
4 MR. FISKE:
Go ahead, Mr. Zechman, lllh 5
THE WITNESS: ' Repeat the question.
6 (Question read.)
7 A
To my recollection, I repeated pretty 8
much what I had here in that particular sentence and 9
I think, as I recall, his comment was that he felt 10 differently.
It was his opinion that what he said 11 stood.
12 Q
Do you recall anything else that he said
(~}
13 in that regard?
%.)
14 A
I know we were discussing training programs 15 and talking about math and problem solving and I 16 know we were in the discussion of training and the 17 problem solving we did was consistent with typical 1
18 training programs, operator training programs both 19 here and at the simulator.
20 MR. GLASSMAN:
Could I have that read back.
21 (Answer read.)
22 Q
Did you say that to Mr. Robinson or did 23 he say that to you?
24 A
I said this to Mr. Robinson.
/
('-
25 Q
Did he respond to that?
1 Zachman 833
(~)
2 A
I don't recall his response to that.
Q.)
3 Q
I would like you to look at item 2 on 4
B&W 568, which refers to page 3,
paragraph 4, line 4.
dll 5
I would like you to tell us what portion 6
of B&W 567 you were referring to.
7 A
I was referring to item b), which states, 8
"No attempt is made to develop the mathematical 9
skills of a candidate beyond those normally expected 10 of a technically oriented high school student."
11 Q
Your comment (a) with regard to that item 12 says, "NRC requires only a High School Education."
(~~3 13 Is that correct?
(_/
14 A
That's correct.
15 Q
At the time you made that comment, was it t
16 your understanding that a high school education was t
17 adequate?
l 18 MR. FISKE:
I object to that question, l
l 19 Mr. Glassman.
That is clearly leading.
l l
20 A
Yes, I thought that was adequate provided 21 that individuals involved go through the appropriate 22 training programs.
23 Q
What was the basis of your comment that 24 the "NRC requires only a High School Education"?
O
\\~ /
25 A
The NRC endorsed a NANSI Standard 18.1, i
I
1 Zachaan 834
(~')
2 I believe it was, in which it had a matrix that V
3 indicated the educational requirements for CRO's.
4 Q
There is a further comment (b) with regard ljll 5
to this item.
Would you read that for us, please?
6 A
" Previous experience has shown no need 7
to provide CRO and SRO's with Math backgrounds of a 8
level greater than High School Alge.5ra/ Trig. along 9
with a generic understanding and meaning of summation 10 symbols, integral sign, differential symbols and the 11 meaning of ' integrating the area under a curve.'"
12 Q
To what previous experience were you
(~'N 13 referring in that comment?
U 14 A
Well, we certainly had operated the Unit 1 15 reactor since its commercial operation and gained a 16 great deal of experience both there and at the 17 simulator and by that time it was pretty evident of 18 the math people were using that progressed over that 19 period and what was needed for that position.
20 Q
On B&W Exhibit 568 your comments jump
{
l 21 from several items on page 3 to an item on page 5; l
22 is that correct?
l l
23 A
That's correct.
i I
24 Q
I would like you to look for a moment
[2
\\
\\-
25 at page 4 of B&W Exhibit 567.
Take a moment to read l
l I
l
1 zochman 835 2
that, and I would like to ask you whether at the time 3
that you reviewed B&W 567 you agreed or disagreed 4
with all of the material on page 4.
lll 5
A Are you asking me do I agree with 6
everything that's on page 47 7
Q I am asking you at the time that you 8
reviewed B&W 567 and at the time you prepared g
B&W 568, did you agree with all the material on page 47 10 A
No, sir, I did not.
11 Q
Was there any particular reason that you 12 did not include any comments on page 4 in your 13 preparation of B&W 5687 14 A
I had, as I mentioned earlier, conversations 15 with Mr. Gordon Robinson and this was one of the areas 16 that we had discussed on the phone.
17 Q
You said that you did not agree with i
18 everything on page 4 of B&W 567.
Can you tell us the 19 areas in which you did not agree?
20 A
Well, he talks about, on page 4,
21 "Specifically, because of the largely descriptive 22 nature of the material and the lack of mathematics in 23 the program, we cannot understand how the program 24 educates the individual in the problem solving skills 25 necessary to handle the unusual or casualty condition."
1 Zschacn 836
[
2 At the beginning of that page there is A.-
3 an ther sentence that says, "It appears to Penn State 4
that the training program discussed above lacks those lll 5
elements necessary to attain the objectives outlined 6
earlier."
And then I just read the second sentence.
7 Q
Do you disagree with, that?
8 A
Yes.
9 Q
Why do you disagree with that?
10 A
Well, in this whole paragraph there was 11 no foundation that was put in there by Penn State of 12 specifics.
It was someone's opinion but it did not C(~N 13 have specifics or backing that one could put teeth 14 in and believe in.
If it lacked mathematics, my 15 question would be, well, what mathematics did it 16 lack that they felt needed to be there?
Was there a 17 task analysis or training analysis that showed that 18 operators needed more math than they were presently 19 getting within the industry or in our training program?
20 I felt that it was not clear at all in what he was 21 trying to say here.
22 Q
Did you say that to Mr. Robinson?
23 A
Yes, I did.
24 Q
You read from a certain portion of the
[)
t
\\w/
25 first paragraph on page 4.
Was there anything else l
1 Zachman 837
/,,T 2
in that paragraph with which you disagreed?
Q.)
3 A
Yes, he had here, "In addition, it appears 4
that all control room personnel receive essentially lll 5
the same training regardless of what level, CRO or 6
SRO, one is concerned with."
And I disagreed with 7
that.
The SRO's needed a lot more memorization of 8
material and training than the CRO's.
There are times 9
that we gave the CRO's SRO material so they were 10 knowledgeable in that but the SRO's certainly --
11 they both didn't get the same.
12 Q
Is there anything else in this paragraph,
("]
13 the first paragraph of page 4,
that you disagreed Lj l
14 with?
l 15 A
"Since the individuals in the control room 16 are the last defense in an accident, it is absolutely 17 essential that they be able to analyze and diagnose 18 complex situations and take appropriate corrective l
l 19 action."
I don't disagree with the fact that they 20 analyze all the procedures and take appropriate 21 corrective action, but he made a generic statement 22 there.
It says, "To do just that requires," and here 23 is the part I disagreed with, "To do just that requires i
24 a high degree of abstract reasoning and problem 1
25 solving ability."
And I guess my objection there is
1 Zochnen 838
(")T 2
what degree of high -- what degree of abstract
's 3
reasoning is he referring to, what degree of problem 4
solving ability is he referring to that wasn't jl}
5 incorporated.
It is simply giving statements without 6
foundation that I disagreed with.
7 Q
Did you discuss that with Mr. Robinson?
8 A
Yes, sir, I did.
9 Q
What did he say to you?
10 A
He said that was his opinion.
11 Q
Did he tell you what the basis of his 12 opinion was?
13 A
Something referring to, "Well, that's the
^
- %J 14 way the world is now," or something of that sort.
l 15 Q
Did you have an understanding of what he l
{
16 meant when he used words to the effect of "That's l
l l
17 the way the world is now"?
l 18 MR. FISKE:
I object to the form of that 19 question.
20 A
I believe he was referring to the post 21 accident as a result of the accident and the post S
22 accident situation.
23 The following sentence says "The 24 identification and cultivation of such ability is p)
'N-25 completely lacking from the GPU program."
Again, it
1 Zachmen 839
(S 2
is a statement without foundation and that is what I w
3 bjected to.
4 Q
Did you tell Mr. Robinson that?
(l) 5 A
Yes, sir, I did.
6 Q
one of the comments which you just read 7
said that, "Since the individuals in the control 8
room are the last defense in an accident, it is 9
absolutely essential that they be able to analyze and 10 diagnose complex situations and take appropriate 11 corrective action."
12 Do you see that sentence?
fs 13 A
Yes, sir, I do.
(
4
\\.J 14 A
Is it your understanding that before the 15 TMI-2 accident there were training programs in effect 16 to enable operators to analyze and diagnose complex 17 situations and take appropriate action?
18 MR. FISKE:
I object to that as, No.
1, i
19 leading, and No.
2, hopelessly self-serving.
20 A
Obviously, the training programs included 21 abnormal and emergency procedures, and the training 22 at the simulator was on some abnormal and emergency 23 procedures that required one to analyze and use 24 procedures accordingly.
b)
\\_J 25 Q
What simulator are you referring to?
1 Zechman 840 (m%j)
/
2 A
The B&W simulator at Lynchburg, Virginia.
3 Q
I would like to refer once again to B&W 4
568, in particular item 3, which refers to paragraph 1,
I 5
line 1 on page 5.
6 I would like you to review paragraph 1,
7 line 1,
on page 5 of B&W 567 and tell us what you 8
were referring to.
9 A
The Penn State report was referring to, 10 "The candidates for SRO must be graduates of an 11 accredited bachelor degree program in engineering 12 (preferably, electrical, mechanical or nuclear (sv) 13 engineering)."
And then what I was saying here was 14 that this was I will quote what I said, " Total 25 over reaction by the Penn State Committee.
The events 16 in Unit II probably would not have changed even if 1
17 operators /SRO's had a degree.
Remember, there were 18 approximately 7 personnel in the Cont
'l Room with 19 engineering degrees."
l 20 What I was stating there was that the l
21 industry did not require graduate SRO's and CRO's.
22 Not that they don't have them, not that they would i
23 discourage anybody from having them, but that it was 24 not a requi rement, and suddenly Penn State seems to g3
(%j) 25 be placing that requirement in the report, and I
1 Zechman 841 2
questioned where they were coming from.
3 Q
I refer to page 2 of B&W 568, in 4
particular item 5, which refers to paragraph 3, line 6,
lll 5
7 and 8 of page 5.
6 could you tell us what you were referring 7
to?
8 MR. FISKE:
Which one is this?
9 MR. GLASSMAN:
Item 5 on page 2 of 10 B&W 568.
11 A
O.
K.,
I was referring to the following:
12 "At that time, he would be eligible for RO licensing
(
13 but would not be eligible for further advancement 14 until completion of forty additional credits towards 15 a B.S.
degree."
And my comment was, "Over reaction 16 by Penn State" and " Disagree with 40 credit i
17 requirement."
18 MR. FISKE:
Your comments were what?
i 19 THE WITNESS:
Two comments, "Over reaction 20 by Penn State," and " Disagree with 40 credit l
21 requirement."
9 22 Q
What"was the basis of those comments which 23 you made?
24 A
The basis, again, was pretty much what 25 I expressed earlier about the previous section we 1
1 zochann 842
()
2 were discussing, that there was no foundation.
They 3
came out and made a statement that RO's should have 4
40 additional credits.
Forty additional credits in ll 5
what?
Why was it necessary to have 40 credits of 6
college education?
What was the importance of it?
7 Why was that necessary?
It was those kinds of 8
questions that elicited my comments.
There was just 9
no foundation for what they were requesting.
10 Q
Did you discuss that with Mr. Robinson?
11 A
I don't recall.
12 Q
Did you discuss it with anyone at Penn 13 State?
l 14 A
I don't recall.
i 15 Q
I would like you to refer now to item 7 16 on B&W 568.
It refers to "PSU Comment
'c' and
'd.'"
17 The written comment in B&W 568 says " Agree"; correct?
l 18 A
Yes, that's correct.
19 Q
Can you first tell us what you were 20 referring to in terms of comment c?
I 21 A
Yes, Penn State gave a lot of --
22 MR. FISKE:
Well, you mean other than what l
23 is referred to under c on page 6 of Exhibit 24 MR. GLASSMAN:
Let me rephrase that.
(~h
?
\\-
25 Q
Comment c on page 6 reads as follows:
1 1
Zschman 843
(']
2 "A large portion of the training is accomplished
'8_J 3
through the use of on the job training and self study.
4 For example, most of the present CRO training ll 5
programs (500 hrs compared.to the total of 550 hrs) 6 involves self study on the job.
Such a technique is 7
satisfactory for subjects such as piping layout, 8
procedures, system design description ~s, and system 9
schematics.
It is completely inadequate for reactor 10 theory, health physics, and other complex technical 11 subjects.
Because of this, GPU should revise their 12 training program to include more in-depth classroom
(~N 13 instruction in these areas."
d 14 Did you agree with everything in that 15 paragraph?
16 A
No, sir, I did not.
17 Q
What, then, was your comment " Agree" 18 referring to?
19 A
I was agreeing with the generic statement 20 they made, and that was that "GPU should revise their 21 training program to include more in-depth classroom 22 instruction in those areas."
What I was saying was 23 I didn't have an objection if we had more classroom l
24 instruction, there was nothing wrong with that
,O
\\I 25 statement.
All I was saying was " Fine."
I didn't l
1 Zachman 844 I~)
2 agree that it was necessary.
I just said that I have V
3 no problem with their suggestion.
4 Q
Paragraph d on page 6 of B&W 567, to which dll 5
you refer in B&W 568, reads as follows:
"With regards 6
to on the job training (OJT) conducted by the 7
operations department, we note no audits of this 8
effort by the training department are evident.
To 9
provide for a check on the satisfactory progress of 10 an individual, periodic testing of trainees during 11 the OJT portion of training program must be conducted 12 and the results audited."
(~T 13 By your comment " Agree" on B&W 568, were O
14 you agreeing with the entire paragraph d on B&W 5677 15 MR. FISKE:
I am going to object to the 16 form of that question.
17 A
No, I was no't agreeing.
l 18 Q
What were you referring to when you i
19 commented " Agree" with regard to PSU comment d ?,
20 A
It was in a generic way agreeing with 21 providing maybe a more formal means of checking the 22 OJ -- the progress of each student in his OJT program.
23 Informally, I meant perhaps matrices or something of 24 this sort.
I certainly wasn't agreeing that we did r~w.
25 not audit that, because we certainly did.
1 zochnan 845
(')
2 Q
When you say "we" did audit the
%./
3 training, wh m are y u referring to?
4 A
The Met Ed training department.
f]ll 5
Q I w uld like you to refer next to item 9 6
on B&W 568, which refers to PSU comment f.
The 7
written comment on B&W 568 says, " Agree."
g What did you mean by the comment " Agree"?
A In reference to that paragraph?
9 10 Q
Yes.
11 A
That I had no problem with additional 12 direct audits of classroom instruction by anybody.
3 13 His comment here the last sentence was, "To ensure L.,I 14 high quality, comprehensive, in-depth instruction, 15 frequent audits of classroom instruction must be 1
16 provided for."
l 17 He was suggesting there may be more 18 frequent ones and all I was agreeing to was I had no 19 problem with that, and that was not to imply that 20 we didn't do that or it wasn't done.
21 Q
Were there audits of classroom 9
22 instructions performed before the TMI-2 accident?
23 A
Yes, sir, there was.
24 Q
Who performed those audits?
A
(' ') -
25 A
By the very nature that senior management, l
1 Zochnen 846
(~h 2
who had licenses, being in the various training L-]
3 programs and lectures during requal, that was a form 4
of audit.
The fact that, to the best of my jll 5
recollection, 1 believe QA had audited those sometimes.
6 I know I personally sat in some of the programs during 7
the time I was acting or had the title of acting 8
supervisor of training.
9 Q
I would like you to refer next to page 3 10 of B&W Exhibit 568, and in particular to item 16 11 which refers to PSU comment m on page 8.
12 What were you referring to on B&W 567, 13 what paragraph were you referring to?
Could you O(~T 14 read that for us?
15 A
Paragraph m states, " Examinations are 16 important - oral as well as written.
Sample written 17 AO exams should be provided for review."
18 Q
You have the comment " Agree" on B&W 568.
1 19 What did you mean by that comment?
l 20 A
I had " Agree - Can supply if requested."
l 21 What I was simply saying is apparently they didn't 22 request them because we certainly would have supplied l
l 23 them if they asked us for them.
24 Q
I would like you to refer next to item 19
(~'s
\\-
25 which appears on page 3 of B&W Exhibit 568.
Item 19 i
1 zochman 847
[')
2 relates to page 9,
PSU comment p, "Small Utility x/
3 Training."
4 Can you read for us what portion of B&W lll 5
567 you were referring to?
6 A
Do you want me to read the paragraph?
7 g
Whatever you want.
8 A
Paragraph p reads as follows:
"A 9
comparative review of the GPU training program to 10 the selected small utility was also performed.
11 Because of the sketchy information provided by the 12 small utility, little if any conclusions could be
(}
13 drawn.
One aspect is worth noting, however, that is v
14 that records of AO training and record entries are 15 computerized.
Such a system allows quick and easy 16 evaluation of an individual's performance.
GPU should 17 consider adoption of such a technique."
18 Q
What was your comment on that paragraph?
19 A
My comment was, "The conclusion is that 20 they did a lot less than we were doing in operator 21 training," referring to the small utility.
22 Q
What'did you mean by that comment?
23 A
well, as I understood this report and 24 their charge, they were to compare our training program 25 with another utility of approximately the same size,
1 Zochmen 848 T'}
2 and what I was saying is if the information they v
3 received was that sketchy, my comment was the 4
conclusion is that they did a lot less than we were lll 5
doing in operator training.
6 Q
I would like you to refer next to item 21 7
on page 3 of B&W 568, which relates to PSU comment r 8
on page 9 of B&W 567.
Comment r in B&W 567 reads as 9
follows:
"It appears from discussions with various 10 training personnel at GPU that some decline in the 11 overall quality of the training program may have 12 occurred prior to the accident.
To avoid this in the
(~g 13 future, the Quality Assurance Division should be V
14 required.to develop a QA plan for periodically 15 measuring the quality of the program.
As a minimum 16.
this QA plan should require yearly audits of the 17 training program."
18 Your comment with regard to that paragraph i
19 is written on B&W 568 as " Agree."
Is t' hat correct?
20 A
That's correct.
21 Q
What did you mean by your comment " Agree"?
22 A
Again, the situation at the end of the 23 paragraph says, "As a minimum this QA plan should I
24 require yearly audits of the training program."
I had
(~')
ks' 25 no objection with that suggestion.
I did not imply
1 Zochman 849
)
2 that I agreed with anything else in that paragraph.
3 Q
The first sentence of that paragraph reads, 4
"It appears from discussions with various training jll 5
personnel at GPU that some decline in the overall 6
quality of the training program may have occurred prior 7
to the accident."
8 At the time that you reviewed B&W 567 and 9
provided your comments as set forth in B&W 568, did 10 you agree that there had been a decline in the overall 11 quality of the training program prior to the accident?
12 A
No, sir.
13 Q
At the time that you prepared B&W 568, did 14 you have in your mind an overall assessment of the 15 Penn State Committee's initial draft report?
16 MR. FISKE:
Can I hear that question, 17 please.
18 (Question read.)
19 A
Yes.
20 Q
Did you express that assessment to 21 anybody?
22 A
Yes, I did.
23 Q
To whom did you express it?
24 A
I expressed it to Doc Smith and I expressed O
25 it to my boss at the time, L.
Lawyer.
1 zochman 850 2
Q Who is Doc Smith?
3 A
Doc Smith was a consultant from NUS that 4
worked as a consultant, jll 5
Q What did you say to Doc Smith?
6 A
I told both Doc Smith and L.
Lawyer 7
that there were some suggestions in here that I had 8
no problem with the overall flavor of, the Pedogogical 9
Review report appeared to be a selling brochure for 10 Penn State.
It looks like they were pushing degrees 11 and degree programs and it just appeared that this had 12 no foundation; at least they were not expressing any 13 foundation in the report that would support that 14 requirement.
15 Q
And you expressed that to Mr. Lawyer?
16 A
Yes, I did.
17 Q
What did he say to you?
18 A
They agreed.
19 Q
When you say "they" agreed, to whom are you 20 referring?
21 A
I am saying Doc Smith and L.
Lawyer had O
22 the same opinion.
23 Q
And they expressed that L
to you?
l 24 A
Yes, they did.
I s-25 MR. GLASSMAN:
I have no further questions.
l
1 Zechman 851 2
BY MR. FISKE:
3 Q
Mr. Zechman, when you were speaking to 4
Doc Smith and Mr. Lawyer about the Penn State report, 9-5 did you tell Doc Smith or.Mr. Lawyer that to the 6
extent the Penn State report was critical of your 7
training program, it expressed many of the same 8
criticisms that you yourself and Mr. McCormick and 9
Mr. Beers had expressed to Mr. Keaten and others in 10 the interview that you had had with him after the 11 accident?
12 MR. GLASSMAN:
Objection.
There has been
("%
i _/
13 a goodly amount of questioning on this, Mr.
d s
14 Fiske, and you know fully well that Mr. Zechman 15 testified that that was not what he said to 16 Mr. Keaten.
I 17 MR. FISKE:
He did not say that, Mr.
l l
18 Glassman.
He said we have produced the notes i
i 19 of Mr. Williams which were taken in the course l
20 of that interview.
We are asking Mr. Zechman g) 21 about statements that were written down by 22 Mr. Williams that were made obviously by himself, 23 Mr. Zechman, Mr. Beers or Mr. McCormick, and I
~
24 am going to prodeed with this line of examination.
%./
25 MR. GLASSMAN:
I will allow you to examine
1 Zechman 852 i
)
As' 2
Mr. Zechman but you should note there has been 3
much questioning on that document and the 4
document was not one that was prepared by 9
5 Mr. Zechman, nor has it been established that 6
those comments were comments of Mr. Zechman.
7 Q
The question is, Mr. Zechman, when you 8
spoke to Mr. Lawyer and Doc Smith about the Penn 9
State report, did you tell them that many of the 10 criticisms that the Penn State report made about the 11 Me t Ed training program were similar to r atements
.12 that either you, Mr. Beers or Mr. McCormick had made p
(_)
13 about the Met Ed training program to Mr. Keaten in 14 your post-accident interview?
15 A
I don't see how I could, sir, because if I 16 recall my testimony, that the only comment I could 3
l 17 recall in my conversations with those people was l
18 the need for additional support people, that we were 19 overloaded with work.
20 Q
And as far as you know, then, these lll 21 statements that are contained in Mr. Williams' notes 22 were just made up by him out of the air?
23 A
Sir, I have no idea of the total foundacion
(^j 24 for those notes.
I can only addresa thet which I
\\_J 25 recall and what I testified to.
1 Zeche.an 853
,m.
l
)
3.,J '
2 Q
And is it your testimony, Mr. Zechman, that you disagreed with a statement in the small r 3
4 paragraph in the Penn Stace draft report that "It 5
appe ars from discussions with various training 6
personnel at GPU that some decline in the overall 7
quality of the training program may have occurred 8
prior to the accident"?
9 A
There was no foundation in my mind that
, 10 ahowed there was a -- that the quality of the tj h
training program had.dec' lined.
- 3
,12 I Q
Did you disagree with that conclusion?
I
()
13 A
I don't know that I made any basis any 14 evaluation of that conclusion that they had in there.
Q Well, their conclusion states that "It 15.,
16 app e a'r s from discussions with various training i
17 personnel at GPU."
s l/
18' A
I was with Net EG-
,19 Q
I understand.
Did yau try to find out i
l f
20 l
who these training personnel at GPU were who had had
)
21 these discussions with the people at Penn State?
22 A
No, sir.
23 Q
Didn't you or Mr. McCormick or Mr. Beers
/~')
24 in your. presence state to Mr. Keaten that the contents q,s 25 of the classroom training at Met Ed has been eroding
'i l
1 Zechman 854 7-(_/
2 down through the years, in words or substance?
3 A
sir, I have already testified to that 4
same line of questioning and I said I only recall 5
but I said I did not recall any longer what Mr.
6 McCormick or Mr. Beers had to say at that meeting.
7 Q
So is it your testimony today that you 8
still don't recall either you or Mr. McCormick or 9
Mr. Beers making a statement to that effect?
10 A
I do not recall that, sir.
11 Q
Is it your testimony today, Mr. Zechman, 12 that neither you nor Mr. McCornick nor Mr. Beers
()N
(_
13 made any statemente to Mr. Keaten that were in any 14 way critical of the Met Ed training program?
15 A
Sir, I just said I didn't recall what 16 Mr. Beers or Mr. McCormick said at that meeting.
17 Q
There was a long delay, was there not, 18 Mr. Zechman, between the time we finished your last 19 day of direct examination and the day that this 20 cross-examination occurred by Mr. Glassman?
h 21 A
There was a delay, sir.
22 Q
Several weeks went by, did they not?
23 A
I haven't counted the days.
(~')
24 Q
In the meantime, a transcript was prepared v
25 of the entire direct examination?
1 Zechman 855
/
\\/
2 MR. GLASSMAN:
Mr. Fiske, you know very 3
well that you even ordered daily copy of the 4
transcript.
9 5
MR. FISKE:
Ekactly, I am trying to have 6
Mr. Zechman establish that.
7 Q
There was a transcript prepared, was there 8
not?
9 MR. GLASSMAN:
How is he supposed to know 10 that?
11 Q
Did you look at a transcript of your 12 testimony that you gave on direct examination in this g~s
(_)
13 deposition several weeks ago?
14 A
No, sir, I did not.
15 Q
You have never seen a transcript?
16 A
I saw a transcript in discussions with 17 my lawyers.
18 Q
Right, they 1.ad a transcript?
(
19 A
Yes, sir.
l 20 Q
And they read to you various questions and lll 21 answers from that transcript?
l l
22 A
Yes, sir.
l 23 Q
And so you have had a lot of time since 1
l
'~';
24 you were first asked in the direct examination 25 several weeks ago about that interview with Mr. Keaten l
1 Zechman 856 f~'( ))
2 to think about it some more, haven't you?
3 MR. GLASSMAN:
Objection.
Obviously, he 4
has had whatever time he has had.
If you want 5
to ask him if he has had a further recollection, 6
you can.
I think he has given you the answer.
7 A
I did not think about, during that 8
interval -- I shouldn't say "any," but that didn't 9
focus in my mind during that time.
10 Q
Just so we understand, Mr. Zechman, as 11 you sit here today now, several weeks after you gave 12 the testimony earlier, as you sit here you cannot O) 13 recall one single statement made by you, Mr. Beers or ix_e 14 Mr. McCormick in that interview that was critical of 15 the Met Ed training program?
16 MR. GLASSMAN:
Mr. Fiske, I have to say 17 I really object to this.
Not only did you 18 harp on this in your prior examination, but 19 Mr. Zechman has answered this two or three times l
20 now.
You have gotten the answer to the question.
i ll) 21 I will let him answer it once more l
l 22 but this is carrying it a bit too far.
It has 23 become harassing 'for the witness.
~]
24 Q
Go ahead, Mr. Zechman.
N.--)
25 A
I already testified that my only
1 Zechman 857
,,s
'w_,/
2 recollection of that meeting was my conversation about 3
the work load and the need for additional people 4
because of the work load that was placed upon them.
5 Q
So is the answer to my question "no"?
6 THE WITNESS:
Read the question?
7 (Question read. )
8 A
I only recall that which I just stated.
9 Q
Now, Mr. Zechman, in this document that 10 is Exhibit 368 which Mr. Glassman has led you 11 through in your examination here today --
12 MR. GLASSMAN:
I object to the inference
,o j
13 in the comment.
ty 14 Q
you made written comments with respect 15 to various items in the draft Penn State report, 16 did you not?
17 A
Yes, sir, I did.
18 Q
And on several occasions in the course of 19 those written comments, you expressly disagr2ed with 20 certain statements that were contained in the draft
)
21 report, did you not?
22 A
Yes, I did.
23 Q
Now, you understood, did you not, Mr.
(~'s 24 Zechman, when you received this draft report which is
)
c 25 Exhibit 567 that in fact it was a draft report?
1 Zechman 858 O
\\_/
2 A
Yes, sir, I did.
3 Q
And y u understood that it was being given 4
to you in order that you might make written comments 5
with respect to the accuracy or inaccuracy of the 6
statements in it, did you not?
7 MR. GLASSMAN:
We have been over this 8
before, but I will let him answer.
9 MR. FISKE:
I think it is highly relevant 10 in light of the testimony he has given a few 11 minutes ago.
12 A
It was given to me and said " Review that t'h
'( _)
13 and make comments."
14 Q
And you received this cover memorandum, 15 did you not, dated January 24, 1980, written by 16 Mr. Lawyer to J.
Thorpe, a carbon copy to R.
W.
17 Zechman?
18 A
Yes, I did.
19 Q
Do you see the sentence in the second 20 paragraph that says, "It is Dr. Witzig's intention to ll 21 substantially modify that document as a result of our 22 discussions on 1/22/80, and comments which I will 23 provide him on or about 2/13/80"?
/~~N 24 A
I see that.
O 25 Q
And did you understand by this the written
1 sechman 859 m(sl 2
comments that you were given an opportunity to make 3
on this document would be provided to the people at 4
Penn State and that your written comments would be 9
5 taken into account by them in deciding whether or not 6
to modify some of the statements that they had made 7
in that draft report?
8 A
I realize that this was one source of my 9
comments to be incorporated, it wasn't all-inclusive.
10 Q
Was it important to you that this report 11 once it came out by Penn State not be unfairly critical 12 in any respect of the Met Ed training program?
(~(_)
13 A
It was my understanding that it was their 14 job to make a review of our training program and 15 say whatever they wanted to say.
16 Q
That is not answering my question.
17 MR. FISKE:
Would you read it back, i
18 please.
1 19 (Question read.)
20 MR. GLASSMAN:
Are you asking whether l
21 that was in Mr. Zechman's mind at the time?
22 MR. GLASSMAN:
Yes, you bet I am asking 23 that.
b("N 24 A
can you reclarify your statement?
I am 25 not quite sure I understand the context of your
, ~.
1 Zechman 860 s
2 statement?
3 Q
It is very easy, Mr. Zechman.
You were 4
given a draft report written by Penn State that was 5
very critical in a number *of respects about the Met 6
Ed training department, of which you had been acting 7
supervisor and supervisor immediately before the 8
Three Mile Island accident.
9 MR. GLASSMAN:
Objection to the 10 characterization.
The report deals with 11 post-accident matters for the most part and 12 it is an unfair characterization.
13 MR. FISKE:
Mr. Glassman, you are just 14 diverting this examination.
That is a 15 completely inaccurate characterization of the 16 document and all you are doing is slowing down 17 this examination, which I am doing my best to 18 finish this afternoon but which I am clearly 19 not going to be allowed to finish unless I can 20 proceed.
ll 21 Will you read the question back again, 22 please, the beginning of the question.
23 (Record read.)
24 Q
Is ti.at correct?
25 A
It is correct that I received that report.
]
1 zechman 861
/
2 Q
And you knew, did you not, that you were 3
being given an opportunity to make comments with 4
respect to that draft report?
5 A
This was one of the means by which I
~
6 could make comments.
It wasn't the only one.
7 Q
You were given an opportunity to make 8
written comments about that report; isn't that 9
correct?
10 A
Yes, sir.
11 Q
And you knew that whatever comments that l
.12 you made about the report would be taken into
()
13 consideration by Penn State in deciding whether or 14 not to make some of the adverse comments they made?
15 MR. GLASSMAN:
Are you now referring to 16 written comments, oral comments or both?
17 MR. FISKE:
I am talking about the comments 18 that he made in Exhibit 568 19 A
My comme..rs 20 Q
-- in response to the request that went ll 21 out to all of the individuals on that list.
22 A
I understood that my comments along with 23 the other comments by other individuals would be 24 received by Mr. Lawyer and that he would make the final 25 report to Penn State on what he thought appropriate.
1 Zechman 862 O)
(m 2
Q And I direct your attention now to page 2 3
of Exhibit 568 which refers to "PSU Comment
'c' and 4
'd,'" which appear on page 6 of the draft report.
5 Let's take paragraph c, small c.
- Reading, 6
this is what the draft report says.
Mr. Glassman 7
read it once before but I will read it again.
It 8
says, "A large portion of the training is accomplished 9
through the use of on the job training and self study.
10 For example, most of the present CRO training programs 11 (500 hrs compared to the total of 550 hrs) involves 12 self study on the job.
Such a technique is
()
13 satisfactory for subjects such as piping layout, 14 procedures, system design descriptions, and system 15 schematics.
It is completely inadequate for reactor 16 theory, health physics, and other complex technical l
17 subjects.
Because of this, GPU should revise their 18 training program to include more in-depth classroom 19 instruction in these areas."
20 Do you see that?
(
21 A
Yes, sir, I do.
22 Q
Now, knowing that that was the draft 23 comment that was being made by Penn State, knowing 24 that you had an opportunity to express a written 1
l 25 agreement or disagreement with anything in that l
1 Zechman 863
()
\\_)
2 paragraph that was critical of your training program, 3
isn't it a fact that the only thing that you put 4
in your written comment with respect to that entire 5
paragraph was the word " Agree"?
6 A
It is a fact that in the written comments 7
I have here one word " Agree."
8 Q
And isn't it a fact that what went to Penn 9
State as your written comment contained no written 10 disagreement?
11 A
I don't know that that is correct, sir,
.12 because I don't know that this report that I wrote i--
(_/
13 here'went to Penn State.
My comments, along with my 14 written comments here, along with my verbal comments 15 were expressed to Mr. Lawyer, and to the best 16 of my recollection, it is a compilation of all the l
17 thoughts that he got and that went to Penn State.
18 Q
But at the time you wrote this document, 19 and you said it to Mr. Smith, you know that there 20 was going to be no written comment going from you to 21 Penn State on this paragraph e other than the one 9
22 word " Agree"; isn't that correct?
23 A
I didn't know that any written paragraph
{~)}
24 or statement I made was going to go directly to Penn N-25 State.
1 Zechman 864 m
'J 2
Q By the way, did you ever see the final 3
Penn State report?
4 A
Yes, sir, I did.
l 5
Q Were you curious to see whether after 6
having received your written comment on that 7
paragraph, they made any changes?
8 A
I recall reviewing it.
I don't recall 9
that I took that report and word for word went down 10 this list and made a comparison.
11 (Recess taken.)
.12 BY MR. FISKE:
13 Q
Let me show you, Mr. Zechman, Exhibit 234, 14 which is the final report of the Penn State group, and 15 I direct your attention to page 18, paragraph c.
16 Isn't it a fact that the final report 17 contains precisely the same language that the draft 18 report contains in the paragraph with respect to which 19 your only written comment is the word " Agree"?
20 MR. GLASSMAN:
Mr. Fiske, if you want the 21 witness to sit here and read word for word 22 and do a proofreading job for us -- we can all 23 read that.
N, 24 MR. FISKE:
Will you stipulate, Mr.
j 25 Glassman --
l l
1 Zechman 865 s
[/
I
\\-
2 MR. GLASSMAN:
We can all read the 3
document.
I don't think we are accomplishing 4
anything here.
If you would like to call 5
Penn State's witness to testify whether 6
anything else was changed or why, you can do so.
7 MR. FISKE:
-- nothing was changed?
8 MR. GLASSMAN:
Whatever it is, it is.
9 If this witness had any role in writing that, 10 you can ask him.
11 MR. FISKE:
I would like Mr. Zechman 12 to confirm that the final report which he r'~N x_)
13 reviewed contains exactly the same language in i
14 paragraph c that the draft report contained in 15 the paragraph with respect to which his only 16 written comment was the word " Agree."
17 MR. GLASSMAU:
It is inappropriate to have 18 a witness do a proofreading job on it.
We l
l l
19 car read it and see that they seem to be 20 similar.
I am not going to have the witness do 1
l 21 a proofreading job for you here.
QIl l
22 BY MR. FISKE:
1 23 Q
N Zechman, let's look again here
(^
24 at paragraph r draft report.
();
25 Do you.ee that first sentence that refers
1 Zechman 866 I
2 to the fact that "some decline in the overall quality 3
of the training program may have occurred prior to 4
the accident"?
dh 5
A I see that sentence.
6 Q
Yes, and'you see in your written comment 7
with respect to that paragraph r, again the only 8
word in your written comment is the word " Agree"?
Is 9
that correct?
10 A
Yes, we just discussed that a while ago, 11 Yes.
12 Q
So the fact is that at the time you
'k-13 reviewed that draft, paragraph r, the only written 14 comment that you made and the only written comment 15 that you had any reason to believe might go to Penn 16 State with respect to that paragraph, was your word 17
" Agree"?
18 MR. GLASSMAN:
That has been asked and 1
19 answered several times.
20 MR. FISKE:
No, I haven't asked him 21 about this paragraph.
9 22 A
I told you that word " Agree" referred to i
23 the last sentence, that I had no problem with yearly
[d 24 audits.
Their final suggestion.
25 Q
I know that is what you just told us a few
1 Zechman 867 2
minutes ago, Mr. zechman, but the written document 3
that you sent to Doc Smith of NUS contained only 4
the written word " Agree" with respect to that I
5 paragraph; isn't that correct?
6 A
That's correct.
7 Q
So when Doc Smith got this memorandum, 8
as far as you knew, he would read it and the only 9
comment he would see that you had with respect to that 10 paragraph was that you agreed?
11 A
He also had my verbal comments that I
. 12 discussed with him and Mr. Lawyer.
()
13 Q
Did you call up Mr. Smith and Mr. Lawyer 14 and tell them that you disagreed with part of 15 paragraph r, did you tell them that in an oral 16 conversation that you didn't put in this memo?
17 A
We discussed the report and various l
18 aspects of the report.
I remember trying to go from l
19 this one to this one.
We discussed some of the things l
l 20 I just mentioned earlier in this report orally.
21 Q
Did you tell Mr. Smith, "Oh, by the way, 22 Mr. Smith, when you get my memorandum that says I l
23 agree with paragraph r, I just want you to know that
(~)
24 I am not talking about agreeing with that sentence LJ 25 that talks about a decline in the quality of our
1 Zechman 868 O
2 training"?
3 MR. GLASSMAN:
Are you asking whether 4
he made that precise comment?
I 5
MR. FISKE:
I*am asking whether he made 6
a comment to that effect.
7 A
I' don't recall.
8 Q
The fact of the matter is, you didn't, 9
isn't it, Mr. Zechman?
10 A
I don't recall either way.
11 Q
And the fact is you yourself believed that 12 the re had been a decline in the quality of the O
O 13 training program, as you, Mr. McCormick or Mr. Beers 14 said to Mr. Keaten?
15 A
I did not say that and I can't account 16 for what Mr. Beers or Mr,.
McCormick said.
You are 17 putting words in my mouth, sir.
18 Q
I take it, your testimony now, Mr. Zechman, 19 is you can't recall any conversation that you had 20 with Mr. Smith or Mr. Lawyer about that paragraph r?
21 A
About paragraph r, yes, we did discuss 22 that.
23 Q
You now remember such a conversation?
ID 24 A
No, I am saying we discussed this report
%)
25 and various aspects of the report.
1 Zechman 869
/'
(m)N 2
Q I am asking you about the small r 3
paragraph.
4 A
Oh, paragraph r in particular, I just I
5 don't recall the specifics of those comments.
6 Q
So that at the time you communicated your 7
thoughts to Mr. Smith in this memorandum with respect 8
to paragraph r, you had no basis for believing that 9
he would have any view from you with respect to the 10 accuracy of that, other than your written comment that 11 you agreed with it?
12 A
Where it talks about the quality of
(')h q
13 the training program, I know that he knew my feelings 14 and so did Mr. Lawyer, that I did not agree as to the 15 decline of the overall quality of the training.
16 Whether it was in reference to this paragraph r or not, 17 they knew that was my opinion.
1 18 Q
There is no question that in a number of l
l 19 different subparagraphs of this Exhibit 568, you 1
1 i
20 didn't express specific disagreement with conclusions l
21 drawn by Penn State, did you?
1 22 MR. GLASSMAN:
I think you just asked 23 that a few moments ago.
1 I
l
(~]
24 Q
That is a fact?
U 25 A
Yes.
1 Zechman 870
\\_)
2 Q
And yet, you made no written disagreement 3
with probably the most impo'rt an t statement of all, 4
that there had been an overall decline in the quality I
5 of your training program?-
6 MR. GLASSMAN:
I object.
That is a 7
statement without foundation and it is clearly an 8
objectionable, inappropriate question.
9 Q
Now, Mr. Zechman, you said that starting 10 at, I believe, sometime in 1977 -- and correct me if 11 I am wrong -- you began studies looking towards 12 obtaining a license as a control room operator?
,ry
)
13 A
Yes, sir.
Nm/
14 Q
When was that in 19777 15 A
It was at the time that I was appointed 16 acting supervisor of training.
l 17 Q
I neglected to ask you one other questica, 18 Mr. Zechman, before we go any further with that last j
19 line of questioning.
Let me just go.back for a moment 20 to this Penn State report.
I have one other question 21 I wanted to ask you with respect to paragraph r, the 9
1 22 one in which the draft report referred to an overall 23 decline in the quality of the training program and l
fw 24 your written comment was the word " Agree," and I would 25 like to have you look at the final report, which is l
l
1 Zechman 871 O
\\,)
2 B&W Exhibit 234, and see whether or not after you s
3 submitted your written comment to Doc Smith, the 4
final report issued by Penn Sta*.e contained any change 5
in the language with respect to the decline in 6
quality of the Met Ed training program?
7 MR. GLASSMAN:
Objection.
First, the 8
witness has already testified as to what 9
portion of paragraph r he agreed with and 10 specifically stated it did not include the 11 portion that counsel just read into the record.
,12 Furthermore, as I stated before, it is totally
{)x inappropriate to have a witness here sit down 13 14 and try to read one paragraph in a report he 15 didn't write and try to compare that to another l
16 document or an earlier draft and tell us now l
17 whether the words are the same or not.
j 18 MR. FISKE:
Well, then, let's save a little 19 time.
I will read the draft report, which is 20 Exhibit 367.
21 "It appears from discussions with various 22 training personnel at GPU that some decline in 23 the overall quality of the training program rN 24 may have occurred prior to the accident."
b 25 That is one of three sentences in a
1 Zechman 872
[)
2 paragraph as to which Mr. Zechman's only
%)
3 written comment is the word " Agree."
4 Exhibit 234, the final report of Penn I
5 State, in its paragraph r reads, in the first
^
6 s e n te n ce',
as follows:
"It appears from 7
discussions with various training personnel 8
at GPU that some decline in the overall quality 9
in the training program may have occurred prior 10 to the TMI-2 accident."
11 Q
Now, Jet's go back, Mr. Zechman, to your 12 efforts to obtain a license.
(y"T, 13 MR. GLASSMAN:
Was there a question x,
14 pending or were you testifying, Mr. Fiske?
15 MR. FISKE:
No, I am reading evidence 16 into the record.
It is a perfectly appropriate 17 procedure, since you didn't want to have the 18 witness acknowledge that.
19 MR. GLASSMAN:
I just wanted to know what 20 you were doing or find out what foundation is 21 laid for this, but you ere able to read what you G
22 want to read.
23 Q
I think we have gotten as far as your 24 studies in September 1977.
And that was looking
/
\\
25 towards becoming a licensed control room operator?
1 Zechman 873 O
\\' /
2 A
It was towards getting and taking an SRO 3
license examination.
4 Q
And an SRO is something different from 5
a CRO?
6 A
That's right.
7 Q
Can you explain what the distinction is?
8 A
A CRO refers to a control room operator 9
examination for an individual who is going to 10 operate the controls of the reactor; an SRO license 11 refers to a senior reactor operator, one who will 12 direct and supervise the control of the operating 13 reactor.
i 14 Q
But in order to get an SRO license, you 15 first have to have a CRO license?
16 A
That's correct.
Well, you could take 17 both exams at the same time.
18 Q
But you can't have an SRO license without 19 a CRO license?
20 A
Well, not quite in those terms.
You can 21 take both exams and end up with an SRO license.
In 22 other words, you wouldn't have one license before 23 the other.
You can take both exams at the same time ID 24 and end up with your SRO license.
?
\\_)
25 Q
Which would include both?
1 zachman 874 2
A Yes.
3 Q
Now, I think you s' aid before that at the 4
time you became supervisor of the training department h
5 in the fall of 1978, that that examination had already 6
been scheduled?
7 A
scheduled several moaths in advance with 8
the NRC.
9 Q
And it was scheduled for you at what time?
10 A
November of
'78.
11 Q
And you did in fact take it in November of 12 19787 13 A
Yes, sir, I did.
14 Q
Was the exam that you took an exam that 15 would have allowed you to become an SRO?
16 A
It would -- to become an E30.
17 Q
What was the exam you took?
18 A
The exam I took was both the CRO and SRO 19' examination.
I would have ended up with,an SRO license 20 if I had successfully passed that test.
21 Q
Is it correct, Mr. Zechman, that in order 22 to take the CRO exam you had to have completed those 23 portions of the Met Ed training program which are a 24 prerequisite to obtaining a CRO license?
25 A
No, I would have had to take a tailored
-v u-
1 Zechman 875
(~)
2 program based upon my background and experience, and 3
that's what I did.
4 Q
To the extent that your background and lll experience was a substitute for some of the material 5
6 in the training program, you wouldn't have to go 7
through that particular part of the training program?
8 A
That's correct.
9 Q
But to the extent that your training and 10 background had not covered certain areas of the 11 training program that were required for a CRO license, 12 then you would have to take those portions of the
(_3) 13 training program?
Is that correct?
f 14 A
To -- yes, to an extent it depends on 15 what you are referring, but, yes, I would take those 16 theories that I needed additional training on.
17 Q
Have you a copy of the FSAR in front of 18 you?
19 MR. GLASSMAN:
Are you referring to a 20 particular document, B&W 260?
21 MR. FISKE:
It is the part of the FSAR 22 that deals with the training program.
n A
Yes, sir.
('N 24 Q
What I am asking you is if you will look at
(_J 25 a portion of this that is on page 13.2-2, which is
1 Zechman 876 p
()
2 captioned " Initial Non-Supervisory Staff (RO 3
License)."
4 A
Yes, sir.
(l l Q
,Then there i s.
a list of small paragraphs 6
that go down a through g; is that correct?
7 A
Yes, sir.
8 Q
Am I correct, Mr. Zechman, in your g
understanding that in order to obtain a CRO license 10 a person has to have completed the training that is 11 described in that portion of the FSAR?
12 A
No, sir, this portion of the FSAR
/~h 13 referred to the training that the initial cold t
G 14 licensed people had gone through.
That's all this 15 document says.
16 Q
But is it fair to say that in order for 17 you to have obtained a CRO license, you would have 18 had to have had and completed training comparable to 19 what would be given in the cold license training 20 program?
21 A
I take objection to what you say being 22 comparable because neither the number of hours 23 required in training nor the amount of practical f s, 24 obse rva tion training here, the program that I would A
25 have gone through would not have been entirely the
l 1
Zechman 877 2
same program that is here.
It would be modified.
3 Q
Is there anything in the FSAR that 4
describes the kind of training program that you went 5
through?
6 A
No, the only reference to a training 7
program is on page 13.2-15, which didn't apply to 8
my particular situation.
It applied to personnel who 9
were going to be licensed control room operators that 10 come up from the ranks of AO's.
Traditionally, the 11 way that my category would have been defined is that
-12 a training program, tailored training program would 13 be made according to my background.
We would tell 14 the NRC, "Here is the training he had received," and 15 if they deemed that satisfactory, they would 1
16 administer the exam.
17 Q
But generally speaking, is it fair to say 18 that the kind of training overall that the NRC 19 would expect someone that was doing what you were 20 doing to have was comparable to the kind of training, 21 in its overall content, to the kind of training that 22 people would have if they just started from scratch?
23 MR, GLASSMAN:
Objection.
Insofar as it
()
24 seeks to elicit information as to what the NRC 25 might have thought or something of that sort.
1 Zechman 878 fy,)
2 Objection as to form.
3 Q
Let's put it this way.
Just in terms of 4
your understanding of the way this worked both as a h
5 student and as someone who held the position of 6
acting supervisor or supervisor of training, isn't 7
it fair to say that you understood that you had to 8
be as "well trained" in order to obtain an SRO 9
license as anybody else who obtained an SRO license?
10 A
It meant that I had to have the training 11 comparable for an SRO license and would be examined 12 accordingly.
O)
(
13 Q
And if you obtained this SRO license, 14 then you would be qualified to go out and operate a 15 nuclear reactor?
16 A
A specific reactor which the license was 17 being --
18 Q
Yes, specifically the 2ne at THI Unit 2?
19 A
No, Unit 1.
20 Q
But assuming you obtained this license, 21 you would then be qualified to go out and operate 22 the reactor?
23 A
The license would allow me to do that.
(g 24 That wasn't my intention.
\\_)
25 Q
But that is what you had to be qualified
~
'l 1
Zechman 879
(_)
2 to do?
A Yes, sir.
3 4
Q Now, in the FSAR, page 13.2-3, one jll of the programs that is described in the cold licensing 5
6 training program is something called " Advanced Systems, 7
Procedure, and Nuclear Theory Training."
Do you see 8
this under small f7 9
A Yes.
10 Q
Which includes training on a number of 11 topics which are listed in that paragraph?
12 A
Yes, sir.
g3 t,,)
13 Q
And did you receive training on those topics?
14 A
O.K.,
these topics are generic in nature, 15 so if I am referring to 1 through 8, I had training in 16 those generic topics.
17 Q
Well, let's take topic No.
1, emergency 18 procedures.
19 You had training on' emergency procedures?
20 A
Yes, sir.
21 Q
And you had the amount of training on 22 emergency procedures that Met Ed felt was necessary 23 for you to have in order to be able to go out and
(^3 24 operate a reactor at TMI-1; is that correct?
uj 25 MR. GLASSMAN:
Objection.
The witness
1 Zachman 800.
(3
()
2 testified he wasn't going to operate a reactor, 3
he was trying to take an examinatien.
t u 4
MR. FISKE:
Sure, but the eximin'ation 5
qualified you to be*able to operate a reactor.
6 MR. GLASSMAN:
If you passed the' 7
examination.
8 MR. FISKE:
Yes.
9 A
Yes.
10 Q
And so you received in the course of your l
d 11 training up to the point where y'ou took that' 12 examination, the amount of training'on emergency i
(~%
13 procedures that Met Ed felt.wrs necessary in order to
)
- J j
v i
N 14 enable someone to go out and operate a reactor?
^
15 A
I received craining on emergency i
16 procedures towards my license, yes, sir.
1 training department, 17 Q
And as head of the for d' moment, you yourself felt, 18 putting that hat on 19 did you not, that Met Ed;sheuld have a training of whi,ch someone who obtained 20 program in the course 21 an SRO license learned enoagh;about the emergency g
22 procedures so that you would be perfectly happy to have
/
23 that person running a reactor at either Unit 1 or l
l l
24 Unit 27 f.-k/
25 MR. GLAESMANr Can I have that read back?
t l
l
-v _ -
~
,1
-Zechman 881 i
()
2 (Question re ad. )
3 MR. GLASEMAN:
Are you asking whether this 4
witness had that feeling at a particular point 5
in tima?
6-MR. PISKE:
Sure, the whole time he was i
7 running the training department.
.n 8'
A 6 Certainly I felt the purpose of the 9
training prograo..was to provide one the training 10 to prepare and train them adequate'y to operate that 11 reactor.
~
12.
Q And you yourself at,the time you took that (s
' 13 exam in December 1973 felt that you had received x
14 such training?
- 15 A
I had received training during that time 16 on those items.
17 Q'
And were yoh yourself satisfied that that s
Ui was training that was sufficient to-allow you to go l
l 19 out and operete a reactor?"
20 jf A
Was-the training sufficient?
21 Q
Yes.
l 22 A
The training that I received was 4
' 23 sufficient, yes, sir.
t
~
24 Q
And the testimony' that you gave, then, s
25
- Mr.
Zechman, in your exanination several weeks ago I
y s
1 Zechman 882 iO
(_)
2 about your familiarity with various of the operating 3
and emergency procedures that were discussed with 4
you was given after you had received the kind of h
5 training that you have just described?
6 A
It was received almost three years prior 7
to that testimony.
8 Q
And when you were asked, Mr. Zechman, 9
whether or not you learned during the period of time 10 that you were acting supervisor or supervisor of 11 the training department about various transients that 12 had occurred right there at Met Ed and you answered
/~
( j}
13 that you were not aware of them, I take it that your 14 testimony would be that you did not learn of those 15 transients in the course of the training that you 16 received?
17 MR. GLASSMAN:
Objection.
The witness l
18 testified that he didn't recall those transients.
19 There may be a' slight difference or nuance in l
20 the way counsel stated it.
21 A
I still don't recall.
22 Q
Just so we understand your testimony, 1
23 when you say today that you don't recall those r~s 24 transients, you don't recall learning about them
\\s) 25 either in your capacity as acting supervisor of the 1
l l
i
i 1
Zechman 883
()
2 training program or in your capacity as someone who 3
went through the training program as a student?
4 MR. GLASSMAN:
Is the question whether I
5 he doesn't recall them or he doesn't recall 6
whether or not he ever learned about this?
It 7
is a bit unclear.
8 A
I simply don't recall them, period.
9 Q
Now, going back to this time in September 10 of -- I believe it was September of 1978 I believe 11 you said you were given a position of supervisor 12 of the training department?
()
13 A
Yes, sir.
14 Q
Was there a job description for that 15 position?
16 A
I just don't recall.
17 Q
When someone asked you to be supervisor 18 of the training department, did you understand what 19 that job was going to involve?
20 A
In past experience, certainly having 21 two past supervisors of training, I understood what 22 that position entailed.
23 Q
What did you understand it entailed?
gS 24 A
That the supervisor of training had the
()
25 responsibility for the conduct and administration of
1 zochann 884
()
2 the training department.
3 Q
With both licensed and nonlicensed 4
training?
I 5
A When referring to nonlicensed training, 6
you are referring to' auxiliary operator training 7
and general training that I mentioned earlier, yes.
8 Q
Would it be fair to say that you 9
understood that the supervisor of training had the 10 overall responsibility for the contents as well as 11 the administration of the training program?
12 A
Well, I guess I better clear whoever
(
13 was responsible for the content, but the content 14 contained a lot of things and materials like procedures 15 that we utilized that somebody else prepared.
16 Q
I understand that you didn't go sit down 17 and write personally as supervisor every single piece 18 of literature that was used in the training program, 19 but in determining what the overall -- one of the 20 functions of the supervisor of training was to 21 determine what the overall content of the training 22 program should be; isn't that correct?
23 A
That pretty much developed over the years 24 into standard training packages that were approved by O
25 the NRC.
1 Zechman 885 i
i
(
2 Q
And you used the phrase, I think, that 3
when you became acting supervisor, that the training 4
department was "in auto," I think is the phrase khk 5
that Mr. Glassman picked up from your earlier 6
testimony.
7 Do you remember that?
8 A
Yes, in context of the definition of 9
" auto" that I described.
10 Q
And that is the way it was when you took 11 over as acting supervisor in 19777 12 A
By virtue of the fact that training
(' )
. 13 programs were in place and that I had a group LJ 14 supervisor in charge of licensed training and he was 15 conducting and administering those programs.
16 Q
How many years had you been involved with 17 training at Met Ed before you became acting supervisor?
18 MR. GLASSMAN:
Are you talking about 19 training of any sort?
20 MR. FISKE:
Yes.
21 A
Since I joined Met Ed in September of
'69.
22 Q
So that is about eight years that you had 23 been in the training department?
24 A
Eight years; more than that, sir.
I
\\
'~
25 Q
Well, from '69 to '777
1 Zechman 886 t' h
(_)
2 A
ch, you.are talking
'77.
I'm sorry, I 3
didn't understand your' time frame.
Yes, sir.
4 Q
So you essentially spent eight years I
~
5 in the training department?
6 A
Yes, sir.
7 Q
During part of which you had been 8
an instructor yourself?
9 A
Instructor in certain areas, yes, sir.
10 Q
And during that period of time from 1969 11 to 1977, how many instructors were there all told?
12 A
It varied at different times, sir.
r x.
13 v)
Q Somewhere around three, four, five, six, 14 something like that?
15 A
It varied because in 1969 we had foremen 16 who were instructors, engineers that provided 17 instruction, then the training department got full-I8 time instructors and those numbers varied over the 19 years.
20 Q
And all of this training that you 21 instructors were doing was all done in one central 22 location, was it not, at Met Ed in the trailers?
23 A
Not to exclude training that was done 24 off-site by the vendors.
-s (a) 25 Q
I said the training that you instructors l
l
1 zechman 887 O(_),
2 did was all done at Met Ed in those trailers; isn't 3
that correct?
4 A
It wasn't only trailers.
We were in I
5 different places at different times.
There were other 6
buildings on the Island where we had conducted 7
training.
8 Q
And you knew all the other instructors 9
personally during this period 1969 to 1977, you knew 10 who they were, didn't you?
11 A
Yes, sir.
12 Q
And did you meet with them from time to (s
(,)
13 time?
14 A
Yes, sir.
15 Q
Did you have meetings of the training 16 department in which training concepts were discussed?
17 A
We had meetings.
18 Q
And there was a general exchange of 19 infor,mation to the extent that people felt that was 20 important in determining the overall scope of the 21 training program?
22 MR. GLASSMAN:
Could I have that read 23 back?
('s 24 MR. FISKE:
I will withdraw it and put
\\_
25 another question.
1 Zechman 888
(}f
/
2 Q
As part of the overall administration of 3
the training program during'those eight years, 1969 4
to 1977, weren't there occasions where the training 5
department would get together and there would be 6
discussions on various topics relating to the overall 7
operation of the training program?
8 A
It's hard to put in that context because 9
our training programs grew over time and yet we did 10 have meetings, we did discuss training problems, and 11 so forth.
I don't know how else to answer your 12 question, sir.
()
13 Q
When you became acting supervisor of 14 training in September 1977, was it basically assumed, 15 in an acting responsibility, the responsibility of 16 the supervisor as you described them earlier?
17 A
Realizing there were times I wasn't 18 there and, as I mentioned, they were in auto and 19 sometimes had to conduct business without me.
20 Q
At that period of time, recognizing that 21 the training program was "in auto," as you put it, 22 I take it there were procedures that you were l
23 familiar with within the training department to be sure 24 that the training department was kept up-to-date with L) 25 developments as they occurred that might be important
1 Zechman 889
.O
(_)
2 in terms of making any modifications that might be 3
necessary to the training program?
4 MR. GLASSMAN:
Arc you talking about a h
5 former document?
^
6 Q
When you came in September 1977, you said 7
the training program was in auto.
Looking ahead to 8
whatever period of time you were going to be in 9
charge of it, you didn't expect to sit there and 10 stay in auto for some indefinite period into the future 11 without making changes to adapt to whatever new 12 information was developed?
(~~x x_-)
13 A
I did not at all imply that additional s
14 information sent down to the training department wasn't 15 being acted upon and incorporated into training.
16 Q
And you assumed that part of the 17 responsibility of the training department was to be 18 sensitive to whatever new information might be out 19 there that could make your training more effective?
l 20 MR. GLASSMAN:
Could I have that read 21 back?
l 22 (Question read.)
1 1
23 A
I was sensitive to the fact that material j
g-'
24 was sent to the training department for review and at i
V 25 times incorporation into the requal program, as an i
l
1 Zechman 890 f%
(,),
2 example.
3 Q
Y u understood that was part of the 4
responsibility of the training department, to try ll 5
and get that information and to incorporate it into 6
the training whenever appropriate?
7 MR. GLASSMAN:
It is unclear what 8
information we are now talking about.
9 Q
New information that might make your 10 training more relevant and more effective.
11 MR. GLASSMAN:
I will let the witness 12 answer it if he can, p) t 13 A
I certainly was aware that material was y
14 sent to us for our review and sometimes requested to 15 update our people on certain training aspects.
l 16 Q
And do I understand -- one last question 17 with respect to this time period -- do I understand 18 that you were spending some of your time while you 19 were acting supervisor studying to obtain your 90 license?
21 A
Yes, sir, that's correct.
22 Q
Now, with respect to the rest of the time 23 when you were not studying, do we understand correctly 24 that during that time you were performing the
(~)h 25 functions of an acting supervisor and performing the
1 Zechman 891 2
functions of supervisor as you described it earlier?
3 MR. GLASSMAN:
Are you talking about all 4
the functions of acting supervisor or is it 5
directed at something specific?
6 MR. FISKE:
I am trying to make this 7
simple.
8 Q
You described earlier what the job of 9
supervisor was, right?
10 A
'Yes.
11 Q
Now, there was no supervisor in September 12 1977, that is, no one with the title of supervisor?
13 A
Well, there was someone with the title of 14 acting supervisor.
15 Q
And that was you?
16 A
Yes.
I 17 Q
And you understood you were to act as 18 the supervisor?
19 A
Under the auspices a,n d agreements, as I 20 mentioned earlier in my testimony today.
I 21 Q
Subject to the fact that you were going 22 to be spending some of your time studying?
23 A
That's correct.
l (g
24 Q
But to the extent that you were not V
25 spending your time studying, then you would be
1 Zochaan 892 s
(
)
2 performing your responsibilities of supervisor, as
%./
3 you described them earlier?
4 A
I would be providing those responsibilities 1h 5
at the time I was there, yes, for what action had to 6
be taken at the time I was there, yes.
7 Q
You said that in September of 1978, you 8
we re promoted to supervisor and you were told that one 9
reason you were being promoted to supervisor was 10 because of your good performance?
11 A
over the years, yes, sir.
12 Q
Did you understand that included your
(~}
13 good performance during the time that you were acting V
14 supervisor?
15 A
ch, I understood that it included the whole 16 compass, of all the years that I had been there.
They 17 covered my administrative ability.
18 Q
You were not being promoted to supervisor 19 because of the excellent job you had done in the l
20 preceding years studying to become a licensed operator?
21 A
The only way that would have been tied 9
22 together was the fact that I they thought it was l
23 I would assume they gave me credit for wanting to do 24 that and to make sure I had that review and that I
~'
25 training.
i
1 Zechman 893
[)
(_/
2 Q
But to the extent that they were talking 3
about your work at Met Ed for the preceding years 4
when they complimented you on your good performance, h
5 they were talking about your good performance as 6
acting supervisor?
7 MR. GLASSMAN:
Are you asking him to 8
speculate now?
9 MR. FISKE:
What he understood.
From 10 this conversation.
11 A
The discussion I had with Mr. Tsaggaris 12 was that he was talking about over the years and b) 13 including that period that he was satisfied with my L./
14 performance.
15 Q
Including your performance as acting 16 supervisor, that is all I am trying to include?
17 A
It included that year.
We had several 18 audits that I participated in that year and they were l
19 happy with those audits and the results and so forth.
20 Q
Now, I think you said, Mr. Zechman, that 21 you found during the ccurse of this year when you were 22 acting supervisor that you were having difficulty 23 with your training because you became interrupted from 24 time to time?
(s\\
%./
r l
25 A
Yes, sir.
l 1
1 Zechman 894
/'N
(,)
2 Q
And do I understand that when you became 3
interrupted, you were interrupted by having to perform 4
some acting supervisor function?
k 5
A Well, realizing that that function 6
included at times going to meetings; it included 7
assisting if a problem developed in the training 8
department, somebody needed my advice or I got a phone 9
call from somewhere or whatever.
10 Q
Well, putting it simply, doing the job of 11 acting supervisor was getting in the way of your 12 personal study; isn't that correct?
[)
13 A
It was a combination, studies were getting
%J 14 in the way of the supervision and the supervision 15 was getting in the way of the study.
16 Q
So, in other words, you were having 17 trouble doing both?
18 A
That's correct.
1 19 Q
And the solution to that was to make you l
20 supervisor and allow you to study full-time?
21 A
No.
22 MR. GLASSMAN:
Objection.
What solution 23 are we talking about?
7-24 MR. FISKE4 The Met Ed solution.
)
l v
l 25 A
No, the solution to that was that I was l
l 1
l l
1 Zechman 895 m)
(_
2 promoted, relieved of my duties to enter full-time 3
into a training program and that other individuals 4
would be made acting supervisor of training and I l 5
perform that function.
6 Q
Well, at the time you were promoted to 7
supervisor, did you receive a pay increase?
8 A
I honestly don't recall.
9 Q
How long did you expect at the time you 10 were promoted to the position of supervisor that 11 you would be devoting full-time to your studies?
.12 THE WITNESS:
Repeat that question?
f())
13 (Question read.)
14 A
At that period of time that it was 15 discussed with Mr. Tsaggaris, it was for the period 16 of September through November.
17 Q
In other words, you contemplated that it 18 would only be up to the time that you took the 19 examination?
20 A
Took the exam, that's correct.
21 Q
And then what happened when you took the 9
22 exam?
23 A
I didn't pass it, rN 24 Q
And so what happened after that with N
25 respect to the position of supervisor?
1 Zechman 896
/~N
()
2 A
We met again and they realized in the 3
short time frame, and understood, the NRC, the 4
feedb. :k we got from the NRC, it was obvious they I
5 were short of additional time that was needed 6
and that I should continue on and retake the exam, 7
continue on in my training and retake the exam.
8 Q
And when did you expect to take the 9
exam again, when was the next scheduled exam?
10 A
I forget the target date.
It was 11 scheduled and I just honestly don't remember when it 12
- was, (m) 13 Q
How many months from November 1978?
14 A
It was 10 CFR 55.
15 Q
Was it more than six months?
16 A
I said I honestly don't recall the time 17 frame.
18 Q
Well, you hadn't taken the exam as of the 19 date of the accident, had you?
20 A
No, I never took it again.
21 Q
So you continued on full-time in study 22 from November of 1978 until at least after the 23 accident?
24 A
No, until the time of the accident, and x,)
25 that's when everything stopped.
1 Zechman 897 O
2 Q
And so September 1978 through the end of 3
March 1979,then, there was no one performing the 4
function of supervisor other than the people who 5
had been design.ated as acting supervisor?
6 A
There were times when I came back into the 7
department and did write memos, did interface with 8
my people for whatever purposes that was for.
9 Q
Now, Mr. Zechman, you testified that Mr.
10 Norman Elliott of B&W did not tell you about a 11 transient that had occurred at Toledo Edison's
'12 Davis-Besse plant?
O 13 A
Yes, sir; this is prior to the accident.
14 Q
Did Gary Miller or Mr. O'Hanlon ever tell 15 you about the transient that occurred at Davis-Besse?
16 A
I think we discussed this before in prior 17 testimony and I testified that they did not.
18 Q
They didn't tell you that they had a 19 description of that accident directly,from the 20 station superintendent at Davis-Besse?
21 A
Not to the best of my recollection.
22 Q
Did Mr. Miller or Mr. O'Hanlon tell you 23 that the operators at Davis-Besse had diagnosed an
()
24 open pilot-operated relief valve within 20 minutes?
25 A
No, sir, they did not.
1 Zechman 898 2
Q Did Mr. Miller or Mr. O'Hanlon tell you 3
that in the course of that accident sequence 4
pressurizer level went up at the same time that 5
pressure was decreasing?
6 A
Not to the best of my recollection.
7 Q
Did Mr. Miller or Mr. O'Hanlon tell you 8
that that accident showed that pressurizer level g
could not be relied upon as an accurate measure of 10 system inventory?
11 A
They did not, to the best of my 12 recollection.
()
13 Q
Did Mr. Miller or Mr. O'Hanlon tell you 14 that it would be inappropriate for an operator to 15 terminate high pressure injection based on pressurizer 16 level in that situation?
17 A
Not to the best of my recollection.
18 Q
And to your knowledge, did they give any 19 of that information to anyone in the training 20 department?
21 A
I can't speak for everybody in my training 22 department.
I can only speak for myself.
23 Q
But you have no knowledge as you sit here 1
l (2) 24 today, that they gave any of that information to l
25 anybody in the training department?
l
i Zechman 899 p\\
\\-)
2 A
I have no knowledge either way that 3
they did or they didn't.
4 Q
Now, Mr. Glassman read you a question 5
and answer from your prior testimony at page 220 6
and asked you whether you wanted to change that 7
testimony and you said that you did.
8 I would like to read the question and 9
answer again.
10 This is by way of preface.
This is with 11 respect to the part of the requalification training 12 program that required 60 hours6.944444e-4 days <br />0.0167 hours <br />9.920635e-5 weeks <br />2.283e-5 months <br />, right?
/m IU) 13 A
O.
K.
14 Q
" Question:
If the records didn't reflect 15 60 hours6.944444e-4 days <br />0.0167 hours <br />9.920635e-5 weeks <br />2.283e-5 months <br /> for an individual, then the records would 16 reflect a deficiency in the program for that 17 individual?
I 18
" Answer:
Yes, it would."
19 That was the answer that you gave on' i
20 March 11, 1982.
And I just would like to have you l
21
. state again how it is that you would change that qg 22 testimony today.
23 A
Because shortly after that testimony, I
'T 24 read again the requalification program and at that (d
25 time I recalled that the onus for that 60 hours6.944444e-4 days <br />0.0167 hours <br />9.920635e-5 weeks <br />2.283e-5 months <br /> was l
l 1
i
1 Zechman 900 2
on the training department as opposed to on the 3
1"diVid"*i-4 Q
That is the part of the answer that I 5
don't think I understood.- What is the difference?
6 A
oh, the difference was that the 60 hours6.944444e-4 days <br />0.0167 hours <br />9.920635e-5 weeks <br />2.283e-5 months <br /> 7
required the training department to -- during 8
requalification training to provide a minimum of 60 9
hours of classroom instruction as opposed to saying 10 60 hours6.944444e-4 days <br />0.0167 hours <br />9.920635e-5 weeks <br />2.283e-5 months <br /> of care packages or homework assignments 11 or whatever other items you want.
It was required 12 that we continually conducted as a minimum a year,
(~%
()
13 60 hours6.944444e-4 days <br />0.0167 hours <br />9.920635e-5 weeks <br />2.283e-5 months <br /> of classroom instruction.
14 Q
Is it your testimony that it wasn't 15 necessary for an individual to document that he had i
16 been to 60 hours6.944444e-4 days <br />0.0167 hours <br />9.920635e-5 weeks <br />2.283e-5 months <br /> of classroom instruction?
17 A
It is my testimony that they had to 18 document the time that they spent either in classroom 19 instruction or on assignments, makeup packages for 20 not being in the classroom.
21 Q
Is it your testimony that that requirement g
22 of the FSAR would have been discharged if an individual 23 never went to class at all and simply read care 24 packages for the full 60 hours6.944444e-4 days <br />0.0167 hours <br />9.920635e-5 weeks <br />2.283e-5 months <br />?
25 A
The onus was on the training department
1 Zechman 901 (D
(_,/
2 providing classroom instruction, and that is why it 3
also states that if someone doesn't get to those 4
classrooms, they may receive that information I) h 5
through a care package.
6 Q
Was it your understanding that the 7
requirements of the FSAR sould have been satisfied 8
if you held these 60 hours6.944444e-4 days <br />0.0167 hours <br />9.920635e-5 weeks <br />2.283e-5 months <br /> of classroom lectures 9
and nobody had come but everybody had simply read 10 care packages?
11 MR. GLASSMAN:
Are you asking whether 12 Mr. Zechman actually thought of that
/~s( )
13 secnario?
N 14 MR. FISKE:
Yes, when he went back and 15 read this part of the FSAR that led him to 16 change the testimony that he gave earlier.
I
{
17 MR. GLASSMAN:
Your question is not 18 directed to whether that actually occurred but 19 simply whether that would fall within his 20 understanding of the requirement?
21 MR. FISKE:
Yes.
I9 22 A
Well, that never happened and to the best 23 of my recollection, and I suppose it is conceivable rx 24 that I don't know.
That never occurred to me, I k._.
25 guess.
l
(
1 Zechman 902 0
2 THE WITNESS:
Can I talk off the record 3
for a second about taxicabs?
4 (Discussion off the record.)
5 BY MR. FISKE:
~
6 Q
I'would like to show you again a document 7
marked B&W Exhibit 303, which is a copy of a f
8 memorandum written by Mr. Goodman, whom you have' 9
referred to earlier today, to a number of individual?
10 including yourself on June 21, 1978.
11 I direct your attention to the sentence 12 that says, "Make-up packages are a poor sdbstitute 13 for live instruction."
14 Do you see that?
15 A
I see that sentence.
16 Q
.And that sentence is in the memorandum 17 written by Mr. Goodman; isn't that correct?
18 A
That document that I have here was written 19 by Don Goodman and that sentence does appear here, 20 yes.
21 Q
And did you understand when you received 9
22 that, that "make-up packages" was referring to care 23 packages?
They are the same things, right?
24 A
Yes.
25 Q
And when you testified that you felt that
1 zechman 903 2
the requirements of the FSAR could be met simply by 3
providing 60 hours6.944444e-4 days <br />0.0167 hours <br />9.920635e-5 weeks <br />2.283e-5 months <br /> of classroom instruction 4
irrespective of the number of hours that the h
5 operators actually_ spent in class, were you taking 6
into account the fact that makeup packages are a poor 7
substitute for live instruction?
8 A
That was Don Goodman's comment, not my 9
comment.
10 Q
so you were not taking that into account?
11 A
I think as a matter of opinion, that 12 opinion certainly needs to be justified.
13 Q
Mr. Goodman was a group supervisor, was 14 he not?
15 A
He was a group supervisor in charge of f
16 license training, yes.
17 Q
And it was the licensed operators that 18 were participating in the requalification training 19 program?
20 A'
That is correct but there were others l
21 sitting in on the training.
i 22 Q
But it was designed for them?
23 A
Yes.
()
24 Q
And this.60-hour lecture series that 25 we were talking about was part of that requalification
1 Zechman 904 A(,)
2 program, right?
3 A
Yes.
4 Q
Now, Mr. Zechman, Mr. Glassman showed 5
you some documents and asked you some questions about 6
audits that were conducted by people at Met Ed and 7
a couple of documents that purport to be audits 8
by the Nuclear Regulatory Commission.
9 I would like to direct your attention to 10 the document which is marked 509, which reflects an 11 audit by two individuals named Heysek and Barbagallo, 12 who are described as audit team leaders for n
(_)
13 Metropolitan Edison, and I would like to direct your 14 attention specifically to paragraph (C) on page 3,
15 which is the paragraph Mr. Glassman referred to you 16 before.
And that refers, does it not, to an audit 17 that was conducted on two days in March of 1978, 18 March 2nd and 3rd?
19 A
Yes, sir.
20 Q
And he also showed you audits that were 21 conducted by the NRC on February 2nd, 3rd and 4th, 1977 22 and May 9th through 12th, 1978.
23 A
Yes, sir.
ps 24 Q
Three days in 1977 and four days in May t
)
\\_/
25 1970.
1 Zechman 905 V) f 2
I would like to ask you, Mr. Zechman, did 3
you show to either of the people from Met Ed or 4
the peopla from the NRC this document that has been 5
marked B&W Exhibit 303 thdt is a memorandum from 6
Mr. Goodman that I showed you before?
7 A
Did I show them th'is document?
8 Q
Yes, any of the people that were doing 9
those audits, did you show them that internal 10 memorandum?
11 A
I don't recall.
' 12 Q
Did you show them the sentence in this tT
(-)
13 memorandum that refers to a poor showing on the part 14 of Met Ed operators in attending the requalification 15 programs?
16 A
I just sa'd I don't recall if I showed 17 them that letter.
18 Q
Did you tell them that for the period of 19 time covered by this memorandum, the overall 20 attendance was 44 percent?
Do you know whether 21 anybody that conducted any of those audits knew that?
g 22 A
I don't recall.
23 Q
Do you know whether anybody that conducted 1
f')N 24 those audits saw B&W Exhibit 304, which is a second
(
25 memorandum, this time written by Mr. Beers on
1 Zechman 906 I
r8
?
)
\\/
2 September 1,
1978, again complaining about attendance 3
at the requalification program?
4 A
No, I don't recall that.
All that was 5
saying was they had to do it by care packages.
6 Q
Which are a poor substitute for live 7
instruction?
8 A
That was one man's opinion and I have no 9
idea what the foundation was for that opinion.
10 Q
Well, I think we went through this once 11 before, Mr. Zechman, but I think the answer to that 12 is contained in your direct examination so we won't r
(,)
13 waste any more time on that.
14 Did you, Mr. Zechman, or did Mr. Beers 15 or Mr. McCormick tell either Mr. Heysek or Mr.
16 Barbagallo from Met Ed or anybody that was conducting 17 an audit for the NRC that attendance at training 18 sessions had been very peor and declining?
19 A
I don't recall.
20 Q
Did any one of the three of you, you, 21 Mr. McCormick or Mr. Beers, tell any of the people g
22 that were conducting those audits that that poor 23 attendance was attributed to the inability of the l
(~~A N
24 operations department to release their people for the
'w 25 required training?
l
1 Zechman 907
(
2 A
I don't recall.
3 Q
Did any one of the three of you tell i
4 anyone that was conducting those audits that this i
dh 5
-Poor attendance was brought to the attention of 6
the plant management on a number of occasions and the s
7 response to this was not at all apparent, as i
g attendance continued to go down?s g
A First of all, you are reading and saying j
10 a lot of things.
I don $t know what you are referring x
e 5.I 4
L p' s
~11 thers to but if you are saying did those specific i
^12 things that you mentioned, were they relayed, I don't s
(
13 recall.
14 Q,
I am simply asking whether ap.ybody that
't 15 conducted those audit,s was tolb by you, M
McCormick tl '
i i', '
d.
16' or Mr. Beers or, indeed, anyone at Met Ed that.the IN 17 Problem of poor attendance had been brought to the 18 attention of the plant management on a number of 19 occasions and that nothing was.done and attendance t
20 continued to go down?
i 3
w
' '21 MR. GLASSMAN:
You are asking whether th'e
-)
k 4
22 substance o'f those words was conveyed, you are 4.
J'
'p3 not asking whether that is absolutely true or s
24 not?
O 25 MR. FISKE:
I am asking whether that fact s
F s
-M
i 1
Zechman 908
(,
(_)
2 was told to the people that were conducting 3
A I don't recall.
4 MR. GLASSMAN:, Objection insofar as k
5 there is a fact asstmed that la not in 6
evidence.
7 Q
Was anyone that conducted any of these 8
audits told that the instructors had to prepare and 9
pursue as many as 2500 caro packeges in a year and 10 that that was a real burden?
11 A
I haven't verified that number.
I don't 12 know if that is a typo on there or what.
e^x()
13 What was the question again?
14 (Question read. )
15 A
You are referring to the NRC audit people 16 or the QA audit people?
17 Q
Yes.
18 A
I don't recall either way.
l 19 Q
I will break it into two parts.
i 20 Were they told that the instructors had to l
21 prepare so many care packages, whatever the number 9
l 22 was, that it was a real burden on them?
23 A
I don't recall either way.
l
'"3 24 Q
And do you recall whether they were told w) 25 that there were 2500 care packages in a year that had t
~
1
.Zechman 909
^
2 to be prepared?
ii 3'
A As I said, that numbar I haven't verified in my own recollection, and in answ3r to your question, 4
5 other than that number, I* don't recall either way.
6 Q
Do.you know whether anyone who conducted 7'
these audids, either the two-day audit by Met Ed 3
or
>he" audits of two or three days each by the NRC, f
~
9 wac told by anyone, including you, Mr. McCormick 10 or Mr. B 6 e r s,. that the contents of classroom training 11 had been eroding down through the years?
' 12 MR. GLASSMAN:
You are asking a number g
i
)
k/
13 questions.
Are you asking as to Mr. 2echman 14 first and then as well as anybody else?
15 Q
I will break it down.
16 -
Did you tell that to anybody that was l
l 17 cc n du ctir.g any of these audits?
l l
18 A
Not to the best of my recollection.
i 19 Q
And do you know wheth,er anyone told them l
l 20 that?
1 21 A
I have no idea I don't recall them 9
22 saying anything to that effect that I am aware of, 23 anyway.
[~ )
24 Q
Did you tell snyone that was conducting
%J 25 any of these audits that this eroding of the contents l
l
1 Zechman 910 0
2 of classroom training had led to the virtual 3
elimination of formal classroom training in the 4
basics, heat cransfer, reactivity math, the I
5 shielding, et cetera?
6 MR. GLASSMAN:
Objection.
I don't know 7
what this eroding is.
You are reading from 8
some document out of context.
If you are 9
asking whether Mr. Zechman used those words, 10 you can.
11 Q
Did you tell anybody that was conducting 12 any of these audits that there had been a virtual
(
13 elimination of formal classroom training in the 14 basics?
15 A
I recall making no such statement.
16 Q
Do you know whether anybody told that to 17 any of the people that were conducting these audits?
18 A
I have no idea what they said to them or 19 recall whether they made that statement.
20 Q
Do you know whether anybody that 21 conducted any of these audits was told that there g
22 had been a reduced interest in the need and value of 23 the training?
24 A
I don't recall making that statement nor 25 do I recall anybody else making that statement.
1 zechman 911
(
2 Q
Do you know whether anyone who conducted 3
any of these audits was told that training was a 4
hand-me-down organization as far as getting analyses, 5
procedure revisions, drawing revisions, system 6
descriptions and so forth?
7 A
I don't recall anyone making those 8
statements to these people.
9 Q
Do you know whether anyone told the 10 people that were conducting these audits that the 11 training department was an orphan organization?
12 A
I don't recall making or my people making
()
13 that statement to the NRC or the QA audit people 14 that you are referring to.
15 Q
Would it be fair to say, Mr. zechman, l
16 that you, Mr. Beers and Mr. McCormick individually 17 and collectively knew a lot more about the Met Ed 18 training program than Mr. Heysek and Mr. Barbagallo l
I 19 learned in a two-day review of written material on 20 March 2nd and 3rd, 19787 ol MR. GLASSMAN:
Objection.
I don't l
22 know what you are referring to.
You are l
23 asking him to make a judgment now as to 24 what he knew?
O 25 MR. FISKE:
Yes, sure.
l 1
e i
_.-a_a
...-.a.___-J "W
.w.
J 1
zechman 912 2
MR. GLASSMAN:
That is absolutely 3
inappropriate to have him answer that question.
4 A
I can't.
lll 5
Q I think you can answer that, Mr. Zechman.
6 A
I have never sat down and judged what 7
Mr. Heysek or the other gentleman mentioned, what 8
their total comprehension of the training program 9
was.
10 Q
Do you think in reviewing the 11 requalification program for two days in 1978 they 12 learned more about the entire Met Ed training program b
13 than the collective knowledge of you, Mr. Beers and 14 Mr. McCormick?
15 MR. GLASSMAN:
Come on, that is 16 objectionable, Mr. Fiske.
You are asking him 17 for his opinion about what somebody else 18 knew, when he said he didn't even know what 19 the totality of their knowledge was.
It is 20 pretty obvious that the question contains 21 objectionable and prejudicial assumptions 22 regarding two days' knowledge, whereas the 23 witness already testified he doesn't know the
('S 24 totality of the knowledge.
25 MR. FISKE:
I am referring to the audit
1 Zechman 913 (A) 2 which they made, which, by their own 3
description, was conducted on March 2nd and 4
3rd, 1978.
That is what the questions have
!llI 5
been about.
6 Q
And isn't it fair to say -- if you don't 7
think you can answer this, you tell me -- but I am 8
asking you whether it isn't a fact that you as 9
acting supervisor of training, Mr. Beers as head of 10 licensed training, and Mr. McCormick as head of 11 nonlicensed training, collectively knew a lot more 12 about the entire scope and operation and quality of 7s ')
13 the training program at Met Ed than these two audit t%J 14 team leaders did based on a two-day review?
15 A
How can I speculate on the background and 16 the experience those people had in the reviewing 17 programs and their knowledge of the programs and 18 compare that to what my people knew when I never made 19 that comparison.
20 Q
Would you give the same answer if I asked 21 you to compare your knowledge about your own training 9
22 program with that of the people that came in from the 23 NRC for two days?
g-24 A
How -- what I would say would be O) 25 speculation because I don't know what their total
I 1
Zechman 914 Ob 2
knowledge is of all our programs.
3 Q
In other words, you are not prepared to 4
say that an assessment of your own training program
'h 5
made by you, Mr. Beers and Mr. McCormick to Mr.
6 Keaten and others.would'be more meaningful than a 7
two-day review by these two audit team leaders?
8 MR. GLASSMAN:
Objection.
I direct the 9
witness not to answer.
Your asking him 10 to speculate on some assessment that might 11 be made now is totally inappropriate.
l
.12 MR. FISKE:
O.
K.,
that is all I have,
(
13 Mr. Zechman.
14 (Time noted:
4:20 p.m.)
15 16 17 Richard W.
Zechman 18 Subscribed and sworn to before me 19 this day of 1982.
20 13 22 23 24 25
1 l
915 l
CERTIFICATE O
2 Itl STATE OF NEW YORK
)
3l
- ss.:
I COUNTY OF NEW YORK
)
4 l
I, NANCY RUDoLPH
, a Notary O
Public of the State of New York, do hereby certify that the continued deposition of e
RICHARD W.
ZECHMAN was taken before j
l me on Thursday, April 29, 1982 consisting O
of pages 729 through 914 I further certify that the witness had been previously sworn and that the within transcript is a true record of said testimony; That I am not connected by blood or marriage with any of the said parties nor lo, interested directly or indirectly in the matter in controversy, nor am I in the employ of any of the counsel.
18 IN WITNESS WHEREOF, I rave hereunto set my 19 CL hand this / 3 day of 4I -
,1982.
n 20 i.'
}/ A.. o,
/ i
/r(,'s-
~
o Nan'dy Rudolph
~
I l
24 1
25 I
916 I NDEX WITNESS PAGE
~
Richard W. Zechman (resumed) 731 4
EXHIB I TS GPU FOR IDENTIFICATION 508 Cover sheets of requalification exams 791 509 Metropolitan Edison Company memorandum dated June 9, 1978 814 510 Document dated March 4, 1977 from the Nuclear Regulatory Commission to Metropolitan Edison Company 822 l
511 Document dated May 25, 1978, from the Nuclear Regulatory Commission to Metropolitan Edison Company 825 1
l 9 9
,9 l
l l
1 c
l O
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