ML20072H848
| ML20072H848 | |
| Person / Time | |
|---|---|
| Site: | Three Mile Island  |
| Issue date: | 03/10/1982 |
| From: | Zechman R GENERAL PUBLIC UTILITIES CORP. |
| To: | |
| References | |
| TASK-*, TASK-01, TASK-04, TASK-1, TASK-4, TASK-GB NUDOCS 8306290775 | |
| Download: ML20072H848 (156) | |
Text
sa gx UNITED STATES DISTRICT COURT
() SOUTHERN DISTRICT OF NEW YORK
x GENERAL PUBLIC UTILITIES CORPORATION, :
JERSEY CENTRAL POWER & LIGHT COMPANY, METROPOLITAN EDISON COMPANY and :
h PENNSYLVANIA ELECTRIC COMPANY,
( Plaintiffs,
( :
-against- 80 CIV 1683
- (R.O.)
THE BABCOCK & WILCOX COMPANY and J. RAY McDERMOTT & CO., INC., :
Defendants. :
x Deposition of RICHARD W. ZECHMAN, 7-e ,
V taken by Defendants, pursuant to notice, at the offices of Davis Polk & Wardwell, Esqs., One Chase Manhattan Plaza, New York, New York, on Wednesday, March 10, 1982 at 9:45 o' clock in the forenoon, before Joseph R. Danyo, a Shorthand Reporter and Notary Public within and for the State of New York.
l-DOYLE REPORTING. INC.
fs b CERTIFIED STENOTYPE REPORTERS 369 LExlNGTON AVENUE WALTER SHAPIRO, C.S.R. New YQng. N.Y. 10017 CHARLES SH APIRo, C.S.R. TELEPHONg 212 - 867 8220 8306290775 820310 PDR T
ADOCK 05000289 PDR -
1 2 2 Appe aranc es :
3 KAYE, SCHOLER, FIERMAN, HAYS & HANDLER, ESQS.
Attorneys for Plaintiffs 4 425 Park Avenue New York, New York BY: ANDREW MacDONALD, ESQ.,
6 -and.
JULIET NEISSER, ESQ.,
7 of Counsel 8
9 DAVIS POLK & WARDWELL, ESQS.
10 Attorneys for Defendants One Chase Manhattan Plaza 11 New York, New York 12 BY: ROBERT B. FISKE, ESQ.,
-and-(~N 13 KAREN E. WAGNER, ESQ.,
14 of Counsel 15 16 Also Present:
17 SUSAN HANSON l
18 00o 19 . IT IS HEREBY STIPULATED AND AGREED by 20 and between the attorneys for the respective 21 parties hereto, that the sealing, filing and O 22 certificat' ion of the within deposition be, 23 and the same hereby are, waived; and that the 24 transcript may be signed before any Notary 25 Public with the same force and effect as if
1 3
(._, 2 signed before the Court.
3 IT IS FURTHER STIPULATED AND AGREED 4 that all objections, except as to the form of lll 5 the question, are reserved to the time of 6 trial.
7 oOo 8 RI CH ARD W. Z E CHMA N , having 9 been first duly sworn by the Notary Public 10 (Joseph R. Danyo), was examined and testified 11 as follows:
12 EXAMINATION BY MR. FISKE:
( f, 13 Q Could you give us your name?
14 A Richard W. Zechman.
15 Q And your residence addrecs?
16 A 458 North Holly Street, Elizabethtown, 17 Pennsylvania, 17022.
18 Q How old are you?
19 A 45, 20 g what is your present position?
21 A My present position is Supervisor of e 22 Technician Training.
23 Q At Met Ed?
l 24 A GPU Nuclear, fg l (x_.-)
25 Q What are your responsibilities in that
1 Zochacn 4 "s 2 position?
3 A My responsibilities in that position is 4 to supervise the following areas, the training in lll 5 the following areas: Maintenance training which 6 includes instrumentation and control, technicians, 7 electrical technicians, utility workers, mechanical.
8 workers, responsible for training of RAD tech--
9 radiation technicians, chemistry technician training, 10 emergency plan training, fire brigade training, and 11 security training.
12 Who do you report to now?
Q 13 A Dr. Ronald Knief.
O 14 Q What is his position?
15 A Manager of Training.
16 Q Could you tell us what the organization 17 looks like beneath you?
18 A Beneath me at this time, in Maintenance 19 Training I have a group supervisor in charge of 20 maintenance training. Reporting to him are five 21 administrators, nuclear technical training. They 22 are instructors. I have a group supervisor. One 23 other thing. There is another group I forgot to 24 mention, and that is general employee and radiation 25 worker training. I have a group supervisor in charge
I
1 Zechman 5
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(,\ j 2 of general employee and radiation worker training.
3 Reporting to him are three administrators in nuclear 4 technical training. I am sorry. Four. I have a llh 5 lead instructor in charge of chemistry training, 6 and I have an administrator nuclear technical 7 training that works with him in chemistry training.
8 I have a lead instructor in charge of RAD tech 9 training and administrator in nuclear technical 10 training that works with him.
11 Q RAD tech is what?
12 A Radiation technician. I have a full time 13 fire brigade administrator in nuclear technical b'"i 14 training. I have a group supervisor in charge of 15 security training and administrator nuclear technical 16 training that reports to him in security training.
17 I have an adiministrator nuclear technical 18 training responsible for emergency plan training.
19 Q Is that it?
20 A I think I got them all.
21 Q If I count this correctly, that would 22 make three group supervisors, two lead instructors, 23 and fourteen administrators technical training?
I 24 A What does that add up to?
O 25 Q 19, 20 including yourself.
- - - - . - -___--__w
1 Zechman 6 2 A That's correct.
'3 Q And this training program that you are 4 now in charge of, that includes training for TMI-1 g 5 and TMI-27 6 A With one exception, and that is RAD tech.
I RAD tech's training for Unit 2, they have a separate 8 training organization.
9 Q For TMI-27 10 A Yes.
11 Does this organization have responsibility Q
12 for training beyond TMI-1 and TMI-2?
13 A No. Our sole responsibility is for the
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's, .)
14 training of those individuals in Unit 1 and Unit 2.
15 where are you located? Where is your Q
16 business office?
17 A I am in the new training building located 10 in the back of the observation center along Route 19 443, .
20 Q What town?
21 A Middletown.
O 22 Q Where is Dr. Knief located?
23 A same location.
24 Who does Mr. Knief report to?
Q
{s 25 A Dr. Long.
1 Zechman 7 2 Q Where is he?
3 A Home base is GPU Parsippany, 4 (Resume of Mr. Zechman marked B&W Exhibit lll 5 554 for identification, as of this date.)
6 Q Showing you an exhibit that has been 7 marked as B&W Exhibit 554, do you recognize this 8 as a copy of a resume that you submitted to the 9 President's Commission back in 19797 10 A I recognize this resume as one I 11 submitted.
12 Q To the President's Commission?
13 A I don't recall that that is the one I J
O 14 submitted to the President's Commission, but I 15 recognize it as one that I prepared.
16 Q In any event, it was accurate as of 17 July 19797 18 A Yes, it is.
19 Q This indicates that you graduated from 20 high school in Reading in 1955.
I I
21 A That's correct.
22 Q Then you went to Penn State?
-23 A That's correct.
24 Q For, I guess, about eight years; is 25 that right?
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1 Zochnen 8
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2 A Part of that was full time. Part was 3 part time. I accummulated those 83 credits during 4 that period of time, ggg 5 Q Just backing up a little bit, I gather 6 after you graduated high school, you went to work 7 for about six years with Western Electric?
8 A That's correct.
9 Q As an electronics technician?
10 A That's correct.
11 Q Did that have anything to do with nuclear 12 engineering?
,S
, 13 A only from the standpoint of having a
(,)
14 good background in electronics and being able to 15 relate to nuclear instrumentation as an example.
16 Q Then you went to Penn State; you started 17 at Penn State in 1961?
l 18 A That's correct.
19 Q Could you explain to us for this period, l
20 '61 to '69, what part of it was full time and what i 21 part of it was part time?
22 A To the best of my recollection, '61 23 through '63 I was full time, and '63, September '63 l
l 24 through September '69, I was employed by the Penn i /~
(h) 25 State University.
1 zechman 9 lh
( j; 2 Q When you started there in 1961, were
~
3 you just starting out in a basic liberal arts degree 4 program?
lll 5 A I started out with an intention for an 6 engineering degree.
7 Q How far did you get on that?
8 A About two years into it.
9 Q What caused you to change courses at that 10 point?
11 A Money.
12 Q What did you decide to do?
13
/~')
NJ A At that time, I decided to look for a 14 job particularly on campus where I could stay there 15 and work and at the same time be able to continue 16 my education.
17 Q Just so I understand it, did you ever 18 get a degree from Penn State?
19 A No, I did not.
20 Q The resume indicates from September '63 1
21 to September '69 you were employed by the Pennsylvania e 22 State University in the Nuclear Engineering Department.
23 A That's correct.
24 Q That is the part time study that you were s
'-) 25 pursuing during that period?
Q:
1 zachnan 10
(} 2 A No, that is not correct. I was employed 3 as an employee by the Nuclear Engineering Department 4 -at that time.
5 So that has nothing to do with any ggg Q 6 further studies?
7 A No, I was pointing out that later on, 8 I went part time to continue picking up credits 9 somewhere in that period.
~
10 Q Is the Nuclear Engineering Department 11 at Penn State part of a graduate study program?
12 A During the time I was there, I had both 13 a graduate and if I recollect an undergraduate 14 program near the latter end toward '69.
15 Q Is it correct that at the time you I
16 started working there in September 1963, you had l
17 had no education or training in any aspect of 18 nuclear engineering?
i 19 A That was my first experience with nuclear.
l 20 Q This resume says that you qualified as i
- 21 an AEC licensed operator -- senior operator at Penn O 22 State University.
23 When did you achieve that qualification?
24 A On the first part of my resume, it
< O 25 indicates that I received an operator's license ir.
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i l
1 Zachmen 11 2 April '65 and an SRO license in May of 1966.
3 Q Was that a license on this trigger Mark 3 4 research reactor?
ggg 5 A That's correct.
6 Q could you describe that reactor for us?
7 A It is a high enriched zirconium hydride 8 fueled reactor, water cooled, swimming pool type 9 reactor.
10 Q Was it what is known as a pressurized 11 water reactor?
12 A No, it was not.
13 Q And the licenses that you received as f~)}
q 14 a licensed operator on that reactor, I take it ,
15 what did that qualify you to do?
16 A That qualified me to operate the research 17 reactor.
18 It was limited to that; is that correct?
Q 19 A That was the purpose of the license, 20 to operate the reactor.
21 Q But the license was limited to operating O 22 that particular reactor?
23 A That's correct.
24 Q You couldn't havo taken that license and p
kl 25 gone out and been authorized to operate a commercial
1 zechman ?2 f3 l.m,) 2 n'uclear reactor?
3 A That's correct. The license is good 4 for only the reactor which you took the exam on glg 5 and were licensed on.
6 Q The resume indicates that you started 7 work at Met Ed in 1969.
8 A That's correct.
9 Q It also indicates that in August 1973 10 you held a position of administrator nuclear 11 technical training?
12 A That's correct.
[)/
x_
13 Q I think you described that position, I I
14 think, a few minutes ago as being equivalent to that 15 of an' instructor.
16 MR. MacDONALD: I think he may have 17 been describing what was in existence today.
1 l 18 Are you asking --
- 19 A No, that was not my title. Would you 1
20 repeat that question again?
I 21 Q In describing the organization of the O 22 Training Department today, you said that there were 23 a total of 14 people in it who hold the title now g- 24 of Administrator-Technical Training, and you at one l
N_)S 25 point said that was equivalent to the title of l
l l
1 Zechman 13 2 Instructor.
3 A That's correct.
4 Q Your resume indicates that from August gg 5 '73 to November '76 you held the position of 6 Administrator-Nuclear Technical Training.
7 I guess I am asking you whether the 8 position of Administrator-Nuclear Technical Training 9 had the same responsibilities and functions then 10 that it does now?
11 MR. MacDONALD: You mean whether or not 12 it was an instructor's position?
13 MR. FISKE: Yes, i 14 A It was an instructor's position but it 15 also had some administrative -- a good portion of 16 my responsibility in that position was administrative.
17 Q There was a category of position in l
18 the Training Department in Met Ed from August '73 19 through March '79 called Administrator-Nuclear 20 Technical Training; was there not?
21 A Yes.
O 22 Q Are you saying that that position was 23 a combination of responsibilities of instructor 24 and also some administrative responsibilities?
O 25 A That position as I recall it had both
1 Zochman 14 2 administrative and instructional responsibilities 3 until the time that a position called Supervisor 4 of Training was created, and that, if I recollect jg 5 correctly, was in 1974.
6 *Q So from '74 to '79, the Administrators 7 Technical Training were in essence instructors?
8 A For the most part, my position still 9 at that time had a lot of administrative 10 responsibilities associated with it. A lot of 11 scheduling, overseeing the training that was being 12 done.
13 3 Q was that also true for some of the people D
14 that held that position, that they also had some 15 administrative responsibilities?
16 A It was probably more limited on their 17 part than it was on mine.
18 But there were some of them that did Q
19 have some administrative responsibilities?
- 20 A Limited.
21 Q Do you remember that sometime after 9 22 the Three Mile Island accident in 1979 you were 23 interviewed by Mr. Keaten who was conducting a 24 post-accident analysis of the training program?
25 A Yes, I do.
1 Zechman 15 b
(,j. 2 Q I would like to show you a document that 3 has been marked as B&W 358. I apologize for the 4 condition of that, but that is the condition in llg 5 which we received it from your company.
6 I would simply ask you for the moment, 7 have you ever seen that document before?
8 MR, MacDONALD: If you are talking about 9 in general aside from any conversations he 10 may have had with counsel.
11 MR. FISKE: Yes, I will exclude any 12 conversations with counsel.
13 A I do not recall seeing that document.
(}
14 Q This document states under the caption 15 " Training Department," it says " Prior to 3/28, one 16 Ad ass't," which I will assume stands for administrative 17 assistant, "two supervisors, four instructors, one i
18 clerk,"
19 Having read that to you from this 20 document, I will ask you whether, prior to March 28, 21 1979, that is an accurate description of the ,
22 composition of the Training Department?
23 A would you repeat that list again?
24 Q one administrative assistant, two O 25 supervisors, four instructors, one clerk.
1 Zechman 16
()
<~s 2 A Give me those again.
3 Q one administrative assistant, two 4 supervisors, four instructors, one clerk. Just to maybe move this along, let me mark another document lll 5 6 which will be B&W 555.
7 (Document marked B&W Exhibit 555 for 8 identification, as of this date.)
9 Q Do you have Exhibit 555 in front of you?
10 A I have Exhibit 555 in front of me.
11 Q Have you ever seen that document before?
12 A I don't recall seeing that document.
['%.J) 13 Q Looking at the column on the far right-hand 14 part of the page where it says March 28, 1979, and 15 running your eye down the names underneath that date, 16 does that indicate that as of that date there were 17 two group supervisors, four administrators nuclear 18 technical training, and one administrative assistant?
19 MR. MacDONALD: I think anybody can 20 read the document and read what it says.
21 Are you asking for his recollection as 22 to whether or not those people were in the 23 Training Department prior to the accident?
24 MR. FISKE: Let's take it one step at
/-s\/
\
25 a time,
1 Zechuan 17 c{ 2 MR. MacDONALD: I don't think what he is
}
3 _ going to'say is going to add any more to what 4 .the document says. '
lp 5 Q The document on its face indicates that i6 as of March 28, 1979, there were two group supervisors, t
7 four adminis?.rators, nuclear technical training, and 8 one administrative assistant in the Met Ed Training I
9 D ep a rtm'e nt , and having shown you that document and t 10 having read to you the notes of Mr. Keaten from
, s 11 the interview of you and others that is reflected 12 in B&W Exhibit 358, does that help you tell us 13 now whether as of March 28, 1979, there were in th'e 14 Training Department two group supervisors, four 15 administrators, nuclear technical training, and one 16 aduinistrative assistant?
f 17. MR. Ma: DONALD: I object to the form.
18 I don't think those are necessarily Mr. Keaten't 19 . notes in Exhibit 358.
20 MR. FISKE: You can reserve that point 21' cf view, e 22 A There was one name that does not to the '
23 best of my knowledge, he was not there at that time, 24 and that is E.W. Orwick.
25 Q You are referring to Exhibit 555?
1 Zochann 18 2
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~,.
A Looking at the names on their only, 3 there is one name on there that was not to the best 4 of my recollection there on March 28, 1979.
ggg 5 Q So if I understand you correctly, from 6 your recollection, Mr. Orwick's name should be 7 deleted from the list?
8 A To the best of my recollection.
9 Q Which would mean according to the list 10 that there were two group supervisors and three 11 administrators, nuclear technical trainings is that 12 correct?
r3
(
13 MR. MacDONALD: Are you asking for his
/
v 14 recollection now prior to the accident?
15 MR. FISKE: Yes. I am asking him how 16 many instructors he had in his Training 17 Department of which he was the supervisor on 18 the day of the accident.
19 MR. MacDONALD: I think that was an 20 easy question. I don't know why we went 21 through the last ten minutes.
O 22 MR. FISKE: If it's so easy, I don't know 23 why Mr. Zechman is taking so long to answer.
24 MR. MacDONALD: Whether he takes long or
(
's- 25 not to answer a question is not your concern.
1 Zochnen 19
[)<
V 2 He can take as long as he wants.
3 If that question was asked ten minutes 4 ago, you would have gotten the answer you ggg 5 wanted.
6 MR. FISKE: You made a comment that it i 7 is such an easy question to answer, and since 8 he is taking so long to answer, I don't understand.
9 MR. MacDONALD: It is an easy question 10 to ask, 11 A What is confusing the issue in my mind 12 and my recollection is the period of time instructors 13 came in post and pre-accident, an'd I do not have a 14 good recollection at this time of when those people 15 came into the department and who was there at that 16 particular time. It has been too long ago.
17 Q Let's put it to you this way: Looking i 18 at the document that is in front of you, Exhibit 555, 19 having deleted the name of Mr. Orwick based on 20 your prior testimony, can you tell us now the name 21 of any other person who you now remember was in O 22 fact an instructor in the Met Ed Training Department l
l 23 whose name is not on that list as of March 28, 1979?
24 A I have no recollection at this time.
l 25 Q This document, Exhibit 555, indicates that
1 Zochacn 20
( ) 2 on the day of the accident you had the position of w/
3 Supervisor Training; is that correct?
4 MR. MacDONALD: Are you asking him is 5 that what the document says or are you asking ggg 6 what his recollection is prior to the accident?
7 They are two different things.
8 Q Is it a fact that on March 28, 1979 9 you held the position of Supervisor-Training in the 10 Met Ed Training Department?
11 A It is correct that was my title and the 12 position I held at that time.
13 Q I believe that fact is also reflected (G~')
14 in your resume which is Exhibit 5547 15 A That's correct.
16 Q You became the Supervisor of Training in 17 September 1978; is that right?
18 A That's correct.
19 Q And from November 1977 to September 1978, 20 you had the position of Acting Supervisor of Training; 21 correct?
O 22 A Thats correct.
23 Q Going back one step before that, from 24 November '76 to November '77, you had the position t
\
'/ 25 of Group Supervisor Technical Training?
1 Zechman 21
,n
( ) 2 A In charge of non-licensed training, 3 that's correct.
4 Q Let's just take the organization of the gg) 5 Training Department at that point in time.
6 A What point in time?
7 Q That point in time, November 1976, for 8 a moment. I think you said earlier that the 9 position of supervisor, Group supervisor,came into 10 existence some time in 1974; is that correct?
11 A No, I don't'believe I said that at all.
12 I said that the position of supervisor of Training
(~'T 13 came into the organization in 1974.
V 14 Q To make it simple, as I understand it, 15 in 1979, at the time of the accident, you held the 16 position of supervisor of Training. There were two 17 Group supervisors, one in charge of the licensed 18 training and one in charge of non-licensed training; 19 is that correct?
20 A That's correct.
21 Q Then there were a number of instructors O 22 under them; is that correct?
23 A That's correct.
7 24 Q Was that instructor of the Training
( h I
~ 25 Department the same in November 1976 as it was in
1 Zochann 22 2 March 1979, forgetting the numbers for a moment?
(U~ ')
3 A To the best of my recollection, the 4 position of Group Supervisor-Non-Licensed Training ggg 5 first existed in the Training Department in November 6 1976. At that time, there was a Supervisor of 7 Training.
8 Q Looking again so we can finish this 9 part of this as quickly as possible, if you look 10 again at Exhibit 555, maybe that will help refresh 11 your recollection.
12 As I look at the top, there are three 13 dates on there; are there not, March 1, 1976, V
14 March 1, 1978 and March 28, 1979? Correct?
15 A That's correct.
16 Q Is it correct that as of March 1, 1976, 17 there was a Supervisor of Training, Mr. Tsaggaris?
18 There were no Group Supervisors, and there were four 19 or there were a number of Administrator Nuclear 20 Technical Training?
21 MR. MacDONALD: Are you asking for 9 22 his recollection, not what the document says?
23 MR. FISKE: Yes. I am asking for his 24 recollection.
(~)N,
's - 25 Q Does this document refresh your t
l l
1 Zoch: tan 23
(^')
%J 2 recollection that the position of Group Supervisor 3 for licensed training and for non-licensed training 4 came into existence some time after March of 1976?
5 A That's correct.
6 Q Prior to that, the instructors reported 7 directly to a supervisor of Training; correct?~
8 A That's correct.
9 Q Is it agreeable to you that for purposes 10 of simplification, absent some different definition 11 for the purpose of a particular question, that we 12 can refer to Administrator-Nuclear Technical Training 13 people as instructors?
(~3 tQ 14 MR. MacDONALD: Are you asking whether 15 or not that is all they did? Or you just 16 want to put a title on it?
17 Q I think you previously said that some 18 of the people including yourself that held the i
19 position of Administrator-Nuclear Technical Training 20 had administrator responsibilities in addition to 21 responsibilities as instructors; correct?
l g 22 A And I said it was on a limited basis.
23 One exception that was my own, I spent a good deal l 24 in administrative.
(~');
\- 25 Q Let me say with that description of what
1 Zachnan 24 gs) 2 an Administrator-Nuclear Training person did, I am 3 simply saying can we for the purpose of this 4 deposition from now on simply refer to them as 5 instructors, or when I refer to instructors, will ggg 6 you understand that I am referring to people that 7 had the official title of Administrator-Nuclear 8 Technical Training?
9 A With the understanding that they did 10 have limited administrative functions and with the 11 understanding that in my role as an Administrator-Nuclear 12 Technical Training, I had quite a bit more administrative 13 responsibility than they did.
(]
\_/
14 Q Maybe we'll continue to call them 15 administrators.
16 I take it your best recollection is 17 November 1976 there came into existence the position 18 of Group Supervisor for Licensed Training and also 19 Group Supervisor for Non-Licensed Training?
20 A Negative. I did not say that. I said 21 in November 1976, the position of Group Supervisor O 22 in charge of non-licensed training came into existence.
23 Q So that as of that time, there was one 24 Group Supervisor?
(/ 25 A That's correct.
1 Zechuan 25 2 Q Looking at Exhibit 555 that is in front
(
3 of you, does that refresh your recollection that 4 as of March 1, 1978, there was still only one Group 5 Supervisor?
6 A I cannot recollect whether there were 7 two Group Supervisors at that time. I do recollect 8 that somewhere in that interval Mr. Don Goodman 9 came in and was designated as Group Supervisor in 10 charge of licensed training.
11 Q You said somewhere in that interval.
12 What interval were you referring to?
e' jg 13 A To the best of my recollection in 11/77, U
14 I moved up as Acting Supervisor of Training. Part 15 of my responsibilities still was to maintain the 16 function of Group Supervisor in charge of non-licensed 17 training. Though I held the title of Acting 18 Supervisor of Training, I was performing another 19 function as well at that time.
20 Q And your resume indicated that as of -- from 21 November '77 to September 1978, you held the position O 22 of Acting Supervisor of Training; correct?
23 A That's correct.
l 24 Q So again looking at this chart, Exhibit 25 555, which I would state does come from the files of
1 Zochnon 26 (N, 2 Metropolitan Edison as an organization chart for QJ 3 these periods, this would indicate that as of 4 March 1, 1978, you were serving as Acting Supervisor ggg 5 of Training with the responsibilities that you just 6 described a moment ago. Mr. Goodman was a Grcup 7 Supervisor for licensed training, and then there 8 were five Administrator-Nuclear Technical Training 9 people under the two of you; is that correct?
10 MR. MacDONALD: You are asking for his 11 recollection now?
12 MR. FISKE: Yes.
13 MR. MacDONALD: Around March 1, 1978?
[k v 14 MR. FISKE: Yes.
15 A It is my recollection that on March 1, 16 1978, I was Acting Supervisor of Training. At some 17 period of time, and I don't recall the time, Don 18 Goodman came in and was Group Supervisor, Licensed 19 Training. I don't recall the status of who were 20 administrators at that time. The names I do not 21 recall that were there at that specific time.
O 22 Q When,you held the position first of 23 Acting Supervisor which was in November 1977, at 24 that time, you were also serving as the Group
(,
,) 25 Supervisor for Non-Licensed Training?
1 Zechman 27 l
(
O) 2 A I was performing that function.
3 Q As well as performing the function of 4 Acting Supervisor?
5- A That's correct.
ggg 6 Q Who was the individual, if any, that was 7 selected to replace you as Group Supervisor for 8 Non-Licensed Training?
9 A That was Frank McCormack.
, 10 Q Do you recall when he first became a 11 Group Supervisor?
12 A No, I don't recall that date.
13 Q At some point, was Mr. B eers selected 14 as Group Supervisor for Licensed Training to 15 replace Mr. Goodman?
16 A At some period of time, he was selected 17 as Group Supervisor in charge of licensed training 18 to replace Mr. Goodman.
19 Q When you were an Administrator-Nuclear l 20 Technical Training, you reported directly to
. 21 Mr. Tsaggaris?
22 A Would you repeat that?
23 (Question read by the reporter.)
24 MR. MacDONALD: At all times, or are you O 25 referring to a specific date such as March 1, q --..g--, = - , , - . - - - w = - - - - - -- -- - ---+ --
P' 1
Zochnen 28 1
2 19767 3 M2. FISKE: Let's take the year 1976.
4 A 1976?
g 5 Q When you were Administrator-Nuclear 6 Technical Training, did you report directly to 7 Mr. Tsaggaris?
8 A That's correct.
9 Q And he was then Supervisor, right?
10 A That's correct.
11 Q What were the circumstances under which 12 you were appointed to become Acting supervisor of 13 Training in Nov4mber of 1977,7 14 A Would you like to clarify what you mean 15 by "the circumstances"?
16 Q Did Mr. Tsaggaris, was he appointed to 17 another position in the organization?
18 A Yes, Mr. Tsaggaris was at some period 19 of time, again I don't recall the date, was promoted 20 to, and again I am not sure of the title -- I believe 21 it was Director of Training for corporate Met Ed.
O 22 Q During the time that he was Supervisor 23 in charge of the Training Department, was he 24 stationed in Pennsylvania at the site at Three Mile 25 Island?
l zechman 29
() 2 A As Supervisor of Training, yes, he was.
3 Q when he received hic new position in 4 1978, did he move to Reading?
ggg 5 A At some period of time, he in his new 6 position, moved to Reading. I don't recall the 7 exact date.
8 Q when he received his new position, that 9 is when you became Acting Supervisor? j i
10 A A g a 3 r. , I don't recall the exact period 11 of that transfer.
12 was there anybody else that served as Q
(g 13 Acting Supervisor other than yourself during the
'd 14 period 1976-19777 15 A To the best of my recollection, no one 16 else held that title.
17- Q During the t-ime that you were Acting 18 Supervisor and then Supervisor of the Training 19 Department, what kind of files did you maintain?
20 A would you like to clarify that. You 21 mean my personal files or the Training Department O 22 files?
23 Q If there are two separate things, let's 24 take them separately. Start with the Training O
-) 25 Department files.
1 Zachaan 30
,a
(_) 2 A The files were maintained by the Training 3 Department and they included the records of training 4 at various times for TMI personnel. It included ggg 5 files on lesson plans. It included computer 6 printouts, resume printouts of the Training personnel.
7 It included resume jackets. Personnel jackets on 8 each individual that worked at the island. The 9 files contained control procedures. I will clarify 10 that, meaning selected control procedures. We did not 11 have every maintenance procedure. There were other 12 procedures outside of the department.
13 when you say files, are you talking (V) 14 about records, or would you include training 15 materials and films?
16 Q We'll get to all of that in a minute.
17 What I am really interested in is under your sort 18 of personal custody and control during this period 19 of time, 1977, November, up to the date of the j 20 accident, what files did you have under your personal 21 custody and control?
O 22 A Since I was either Acting or Supervisor 23 of Training, obviously I was supervising the 24 department, and under me I had people responsible 7_
() 25 for seeing that those files, training materials and
1 Zochuan 31
()
v 2 so forth got filed. In a way those files were under 3 my direction. The maintenance of those files was 4 under my direction even though I had people who did ll) 5 the filing.
6 Q Did you keep any files yourself such 7 as correspondence files or a chronological file?
8 A They maintained a writer's file that I 9 had.
10 Q What is a writer's file?
11 A If I would write a letter, they would 12 maintain the master copy or that copy in the writer's
(' 13 file.
V) 14 Q There was one file that you could go to 15 that would have copies of all the letters you wrote 16 irrespective of the subject matter?
l 17 A I can't say that every letter would be in 18 there, but my letters, copies of my letters were I
19 maintained.
l 20 Q Did you at any time maintain or keep 21 any documents at your home?
22 A The only documents I kept at home in any 23 one time were copies of the original training manuals.
l 24 Consequently since the accident, I have brought all e
n
)
\/ 25 those in to litigation.
1 Zechman 32 O)
(_ 2 Q So in response to the request for the 3 production of documents in this case, you have made 4 available to whoever was collecting those kind of lll 5 documents all of the documents that you had in your 6 home?
7 A That I did.
8 Q You testified previously concerning the 9 Three Mile Island accident before the President's 10 Commission; is that correct?
11 A That's correct.
12 Q Did you also testify before what is known
() -
13 as the Rogovin Commission?
14 A That's correct.
15 Q I believe you also participated in a 16 joint interview with others from Met Ed with employees 17 of the Nuclear Regulatory Commission sometime in 18 1979? Do you recall that?
19 A There was a meeting we had with them, 20 yes, j 21 Q Have you since the time that you testified O 22 before the Kemeny Commission, did you have an 23 opportunity to see the transcript of your testimony?
24 A I saw it shortly after, right after,
. 25 the deposition.
l
1 Zechman 33 2 Q Were you asked t'o review it and 3 determine whether it was accurate?
4 A I was asked to review it and make any ll) 5 notes of corrections.
6 Q Did you do that?
7 A For the Kemeny, I recall, I recollect 8 doing that. I don't recall for the Rogovin.
9 Q Let's take them one at a time. You do 10 recall doing that for the Kemeny Commission?
11 A Yes, I do.
12 Q The next question is do you remember
( 13 doing that for the Rogovin?
14 A I have no recollection at this time.
15 Q Do you remember having seen the testimony, 16 the transcript of the testimony that you gave before 17 the Rogovin Commission or any of its lawyers at 18 any time after you gave it?
i 19 A I did see a copy of the Rogovin testimony l 20 that I gave shortly thereafter giving that testimony.
l l
L 21 Q Have you seen at any time since you 22 participated in it a transcript of the interview 23 that you had with the employees of the Nuclear 24 Regulatory Commission?
25 A I have no recollection of that.
. _ . _ . _ _ .- _ ___ _. _ _ _ . _ _ . . __ .~ . _ __ __ _ _ _ _ _
1 zechman 34 2 Q Do you recall that that particular 3 discussion was tape-recorded?
4 A Yes, it was.
lll 5 Q Did you ever receive a tape?
6 A Yes, I did.
7 Q Did you listen to the tape?
8 A No, I did not.
9 Q To this day, you have not?
10 '
A Not to the best of my recollection did I 11 sit down and ever listen to that again.
12 Q Do you still have the tape?
() 13 A To the best of my recollection, that 14 was one of the things that I brought in and just 15 turned everything over.
16 Q So your best recollection is that 17 you did turn the tape of that interview over to your 18 lawyers for production in this case?
19 A I have no recollection either way on 20 that one.
21 Q At the time you testified before the 22 Kemeny Commission, did you answer the questions 23 truthfully and completely to the best of your 24 recollection at the time?
h a 25 A To the best of my recollection, I answered
1 Zochman 35 2 the questions as honestly and truthfully as I knew 3 it at that time. There were times in which they 4 asked me to speculate and to guess at answers, so ggg 5 there is a good deal of speculation and guesses in 6 that testimony.
7 Q Did you testify truthfully to the 8 questions that you were asked by the Rogovin 9 commission?
10 A I testified truthfully to the best of 11 my knowledge at that time and speculated also at 12 times.
_ 13 Q Do you remember being interviewed by b 14 Mr. Keaten?
15 A Yes, I do recall having meetings with 16 Mr. Keaten.
17 Q Do you remember how many meetings you 18 had with Mr. Keaten?
19 A only one that I recall.
l 20 Q Was that tape-recorded?
i 21 A I have no recollection either wr.y. I k
22 have no idea.
l 23 Q Did you know at the time you were giving i 24 that interview with Mr. Keaten whether he was l
( 25 tape recording it?
1 Zechman 36 i \
2 A I just repeat my answer, I have no 3 recollection either way whether it was or was not 4 recorded.
ll) 5 Q Have you ever seen a tape recording of 6 that interview?
7 A I have never heard or seen a tape 8 recording of any interview that was held with
, 9 Mr. Keaten by me.
10 Q Did you understand that Mr. Keaten 11 was interviewing you for the purpose of getting 12 answers to questions that he was asking about the (s_), 13 Met Ed training program as it existed before the l 14 Three Mile Island accident?
15 A I understood that that was his purpose l 16 of being there.
17 Q Who was at that interview?
l 18 A To the best of my recollection, and I
. 19 will give you the names that I recall being there, 20 Dr. Long, Dr. Robert Long, Bob Keaten. For a l
21 portion of the meeting, Marshall Beers and Frank k
22 McCo rmack. There were others present but I can't l
23 recall at this time who they were.
(\ss 24 (Recess taken.)
l 25 BY MR. FISKE:
1 Zechuan 37 c.
() 2 Q Do you remember a fellow named Ed Wallace 3 being there?
4 A I have no recollection either way.
ggg 5 Q Was Ron Williams there?
6 A No recollection either way.
7 Q What was Mr. Keaten's position at Met Ed 8 at the time of this interview?
9 A I have no recollection what his title 10 was at that time.
11 Q Did you know Mr. Keaten before the day 12 of that interview?
) 13 A That would either have been the first or
(~'J 14 second time I met him, to the best of my recollection.
15 Q Do you have a recollection now of 16 having met him before the date of that interview?
1 17 A No recollection either way.
18 Q Did you know Mr. Keaten before the 19 accident?
i 20 A I have no recollection either way.
21 Q Had you heard of Mr. Keaten before the O. 22 accident?
23 A No recollection either way.
24 Q Had you met,or what was Mr. Long's 7-
~
25 position on the day of this interview?
1 Zachman 38
() 2 A I don't recall what his position was on 3 the day of that interview.
4 Q You had met Mr. Long before that interview?
lll 5 A No recollection either way.
6 Q Had you ever met Mr. Long before the 7 accident?
8 A No recollection either way.
9 Q Had you heard of Mr. Long before the 10 accident?
11 A No recollection either way.
12 Q Is this the same Mr. Long to whom 13
('%J) Mr. Knief, the Manager of Training, reported to, 14 when you first started out in the Training Department?
15 A That is not when I first started out 16 in the Training Department.
17 Q Mr. Long was not involved in the training 18 at all when you first started out in the Training 19 Department?
20 MR. MacDONALD: You mean back in -
21 19 --
22 Q To t'he best of your knowledge, Mr. Long 23 had absolutely nothing to do with Met Ed training 24 at any time up to the date of the accident?
- l. '/
25 MR. MacDONALD: You are asking whether
1 Zechman 39
()
(/ 2 he was at Met Ed prior to the time of the 3 accident?
4 MR. FISKE: No.
ggg 5 Q To the best of your knowledge, did 6 Mr. Long have anything to do with Met Ed training at 7 any time prior to the accident?
8 A To the best of my recollection, he did 9 not.
10 Q Had you heard of Mr. Wallace before the 11 day of this interview?
12 A No recollection either way,
() 13 Q Had you heard of Mr. Williams before 14 this?
15 A No recollection either way. It has been 16 very difficult for me to separate post and pre and 1
17 my recollection of these people.
18 Q Just so you understand it, the question, 19 I am asking you as of the point in time that this
, 20 interview took place which was post accident, and l
l 21 I believe the date is October 18, 1979; the question O 22 is at any time up to that date which includes both 23 pre-accident and post accident time periods, had you p3 24 ever heard of Mr. Williams, Mr. Long or Mr. Wallace?
Nj 25 MR. MacDONALD: Are you asking now as of
1 zechman 40 l
() 2 that specific date or as of the time of the 1
3 interview, because I don't know whether the 4 witness has testified that he has a recollection gg) 5 of the interview.
6 MR. FISKE: As of the time of the 7 interview.
8 A What was the date of the interview?
9 Q' According to Mr. Keaten, October 18, 1979.
10 MR. MacDONALD: I object. I don't 11 know whether Mr. Keaten said it is October 1979 12 or whether what you are looking at are 13 Mr. Keaten's notes.
14 MR. FISKE: According to Mr. Keaten's 15 written record of that interview, it was 16 October 18, 1979.
17 MR. MacDONALD: Is that a question or 18 are you asking the witness if he recalls the 19 interview was October 187 20 MR. FISKE: I was asked a question, what 21 was the date of interview, and Mr. Keaten's 9 22 written record says October 18, 1979.
23 Q Is it your testimony now that you don't
, 24 remember whether you had ever heard of Mr. Wallace, 25 Mr. Long or Mr. Williams before the date of this
--m m ,_ . - - , t , .-r w-, - - - - - -
1 Zochman 41
()
%J 2 interview?
3 A I have no recollection either way, 4 Q How did you find out that this interview ggg 5 was going to take place?
6 A I have no recollection who came to me 7 and told me the interview was going to take place 8 and wanted to talk to me.
9 Q Did you know before the date of that 10 interview that Mr. Keaten was conducting a review 11 of conditions at Met Ed prior to the accident?
12 A To the best of my recollection, I learned
(~3 13 of his committee at the time I was asked to talk
"\j '
14 to them.
15 Q How long before the interview was that?
16 A I have no recollection.
17 Q Did you ask-Mr. Beers and Mr. McCormack 18 to be at that interview?
19 A Yes, I did.
20 Q Did Mr. Keaten ask you to do that?
21 A He said that would be fine.
l 22 Q Was it your idea that they be there?
23 A It was my idea that they be there.
- 24 Q Where did this interview take place?
I f's1
?
I k/ 25 A It took place in a conference room in l
t
1 zechman 42 k_) 2 the security building.
3 Q Is it your testimony that there was only 4 one such meeting?
ggg 5 A To the best of my recollection, there 6 was only one meeting.
7 Q Did you take notes at that meeting?
8 A I did not take notes at that meeting.
9 Q Did Mr. Beers?
10 A I have no idea. I have no recollection 11 whether Mr. Beers did or did not take notes at that 12 meeting.
s q_) 13 Q How about Mr. McCormack?
14 A I have no recollection whether 15 Mr. McCormack did or did not take notes at that 16 meeting.
17 Q Did you know during the meeting that 18 somebody was taking notes?
19 A No recollection either way.
20 Q At any time after the meeting, did you 21 see any written record of that interview?
O 22 A To the best of my recollection, I did 23 not see any results of that interview.
24 Did you understand that Mr. Keaten 7S Q N.] .
20 was going to use what he learned in this interview
1 Zechuan 43 t 2 as part of his overall report?
3 A My understanding at that time was that 4 he was part of the committee that was doing a 5 review. I had no idea or recollection, I should (gg 6 say, of what that was going to be used for, what 7 he was going to do with that information once he 8 had it.
9 Q Did you understand that one of the 10 purposes of that review was to determine what the 11 scope and content was of the training program at 12 Met Ed before the accident during the period of time 13 that you were Supervisor of the Training Department?
(~}
U 14 A I do not recall it being expressed to 15 me in that fashion.
16 Q Did you understand during the course 17 of the interview as questions were asked and you 18 and Mr. Beers and Mr. McCormack answered them that 19 one of the subj ects that was being covered in the 20 interview was the scope and content of the training 21
- program as it existed while you were Supervisor of O 22 Training?
23 MR. MacDONALD: Are you asking for his 24 recollection during the time of the interview?
I -
25 MR. FISKE: Sure.
I
1 Zechman 44 2 A I d o --
3 MR. FISKE: Did he come to learn that 4 during the course of the interview.
lll 5 A I don't recall that it only reflected 6 during the period of time that I was Acting 7 supervisor or supervisor of Training.
8 Q I am asking you whether as this interview
, 9 went on and Mr. Keaten and perhaps others were 10 asking questions and you were answering them you 11 came to learn during the course of the interview 12 that one of the things these gentlemen that were
() 13 conducting the interview were interested in finding 14 out was the scope and content of the training 15 program as it existed before the accident while you 16 were supervisor of Training?
17 A It is that last part that I have a 18 problem with. The last part of your statement 19 says while I was supervisor of Training, and my -
20 recollection is it did not just include that period 21 of time. It included overall training, and it O 22 included past and present.
23 I Q But one of the areas that this interview 24 covered as you came to understand it during the 25 interview was the scope and content of the training -
1 zochann 45
() 2 program before the accident during the period that 3 you were supervisor of Training?
4 MR. MacDONALD: Are you asking whether 5 or not there were specific questions geared ggg 6 at that portion of the training program?
7 MR. FISKE: The question is very simple, 8 If Mr. Zechman doesn't think he understands 9 that question, he is welcome to have it read 10 back. It is the same question I have asked 11 three times.
12 MR. MacDONALD: That is the reason I 13 was trying to,get clarification, because 14 perhaps it is not so clear as you think.
15 g Do you understand it?
i 16 - A I am not sure I understand what you are 1
i 17 totally asking for and in the context that you are I 18 putting it.
19 Q I am asking one question at a time,
', 20 and you are trying to think ahead and answer five 21 others. Just listen to the question I have asked, e 22 and if there are other questions that relate to
, 23 this interview, we'll get to them in a minute. I
- ~
24 will take them step by step.
O 25 MR. FISKE: Could you read back the
'e
- - - - . - , , _ , , ~ , . , , - . - . . - -.
1 Ecch=cn 46 O
V 2 question and type it in. -
3 (Whereupon the reporter read a portion -
4 of the record as follows: 'lQu e s tion i I am g 5 asking you whether as this interview went on 6 and Mr. Keaten and perhaps others were j i 7 asking questions and you were ar.ewering them i
8 you came to learn during the course ofsthe 9 interview that one of the thinhs these 10 gentlemen that were conducting the interview 11 were interested in finding out was the sco'pe 12 and content of the training program as it 13 existed before the accident while you were 14 Supervisor of Training?" '
s .
15 " Answer: It is that last part that I
- 16 have a problem with. The last part of your 17 statement says while I was Supervisor of 18 Training, and my reco11ee:ti'on is it did not 19 just include that period of t i rie .
It included 1 overall training, and it included,past and 21 present.") -
@ 22 Q What I would like you to do is listen 23 to the question ae it is read once more, and focus .
24 on the part of the question that refers to one-of 25 the things.
l , -
. - - _ _ - .- ._ ,_ __ . w . - _ - _ _ _
\
1 Zochann 47 (A) ,
2 MR. FISKE: Would you read it again?
3 (Whereupon the reporter read the previous i
4 question as follows: " Question: I am ggg 5 asking you whether as this interview went on 6 and Mr. Keaten and perhaps others were 7 asking questions and you were answering them 8 you came to learn during the course of the 9 interview that one of the things these
\
10 gentlemen ih'at were conducting the interview 11 were interested in finding out was the scope 12 and content of the training program as it
(~')
v 13 existed before the accident while you were 14 Supervisor of Training?")
15 Q can you answer that?
16 A I can answer that they asked questions 17 that related to t h'a t per'iod of time. I don't know 18 that they explored the full scope or content of the 19 entire training during that period.
20 Q But you did learn during the interview 21 that that was an area that they were interested in?
O 22 MR. MacDONALD: Are you asking whether 23 or not --
,_ s 24 MR. FISKE: It can't be any simpler
\ )
25 than that.
4
1 Zochnnn 48
/~x i
s ) 2 MR. MacDONALD: Did he surmise from the 3 questions that they were interested in the 4 interview?
gg 5 Q Do you understand the question?
6 MR. MacDONALD: What Mr. Keaten thought.
7 A Yes.
8 Q And so you underctood, did you not, at 9 the time of this interview that one area that 10 might be covered by the report that Mr. Keaten was 11 going to prepare was the scope and content of the 12 training program at Met Ed as it existed before the c,
13 accident while you were Supervisor of Training?
( )
<.J 14 MR. MacDONALD: I object. I think he 15 already testified he didn't know whether or 16 not there was going to be a report coming 17 out of anything that was discussed at the 18 interview. There is no basis for the question.
19 Q Is that your answer? Can you answer the 20 question?
21 A I already answered the question, 9 22 Q What is your answer?
23 A I already answered the question.
24 Q Did it occur to you during the course
~'
25 of the interview there might be a written report that
1 Zochman 49 2 might have something to say on the subject of the (V) 3 scope and content of the Met Ed training program 4 as it existed under your supervision prior to the g 5 accident?
6 You don't have to look at Mr.MacDonald 7 You can answer that question.
8 MR. MacDONALD: Don't tell the witness 9 what to do. You ask the questions and he 10 will answer them.
11 MR. FISKE: Hopefully.
12 MR. MacDONALD: You don't have to get 13 nasty with the witness and tell him who to
(~))
L 14 look at. You are there to ask the questions 15 and he is there to give the answers.
16 MR. FISKE: That is the correct 17 definition of what is supposed to happen.
18 MR. MacDONALD: Don't tell him how to 19 sit or what to look at during the deposition.
20 A May I remind you in a previous question 21 indicated I did not have any idea what was going O 22 to be done with the information I was giving. Whether 23 a report was going to be written or otherwise.
24 Q In other words, you are saying that the 1 [\
'/ 25 thought never crossed your mind during the interview 1
1
1 Zachnnn 50
[; 2 that there might be'a written report?
V 3 A I have no idea or recollection what my 4 thoughts were at that time.
5 Q Did you ever ask Mr. Keaten to show you 6 the results of his interview?
7 A To the best of my recollection, I never 8 asked him that.
9 Q Did you ever see any written document 10 emanating from Mr. Keaten's interview?
11 A To the best of my recollection, I have 12 not seen any results, written documents, of that
(~ 13 interview.
N.j$'
14 Q Have you seen at any time since the 15 interview any report prepared by Mr.- Keaten or 16 anyone working for him which in any way comments on 17 the scope or content of the training program at Met 1
l 18 Ed before the accident?
19 A Relative to that interview?
l 20 Q Just answer that question, the one that i
21 I have.
22 MR. MacDONALD: I think he is asking 23 for clarification.
l l 24 MR. FISKE: The only clarification I I I~h
( ./ 25 can give is to have the question read back
1 Zochnen 51
() 2 and ask you to answer as it is asked. Again, 3 if it is helpful, I will ask you to listen 4 carefully to the word "any" in the question.
5 (Question read by the reporter.)
ggg
- 6 A Recognizing the word any that you 7 emphasize, I have no recollection either way. I 8 can only say that I have no recollection of seeing 9 any documentation as a result of that meeting that 10 I had with him.
11 Q But just so we can move on to the next 12 question, my understanding from your answer is that
/-}
NJ 13 you don't remember today one way or the other whether 14 you have seen any written document prepared by 15 Mr. Keaten or anyone else working.for him that 16 comments in any way on the scope or content of the 17 training program?
18 A To the best of my recollection, that is 19 true.
20 MR. FISKE: Can we mark as the next 21 exhibit --
22 Q Before showing you the next exhibit, let l
23 me ask you whether at any time since that interview 24 you have spoken to Mr. Keaten?
25 A I don't recall either way.
I
1 Zachnen 52 2 Q Have you spoken to Mr. Wallace, Mr. Long 3 or Mr. Williams?
4 MR. MacDONALD: You want a specific 5 answer to each one of those?
6 MR. FISKE: If the answer is going to 7 be he doesn't recall, he can lump them all 8 together, 9 A Relative to that interview or just 10 spoken to them?
11 Q Let's start with a broader question.
12 Have you spoken to them at all?
13 A I have spoken to Mr. Wallace since that 14 time.
15 How about Mr. Long or Mr. Williams?
Q 16 A Certainly I have talked to Mr. Long 17 since that time. Not Mr. Williams, to the best of 18 my recollection.
19 Q In any of your conversations with 20 Mr. Wallace or Mr. Long, has there been any 21 conversation between you which relates in any way 22 to the interview that was conducted?
23 A To the best of my recollection, none 24 of our conversations dealt with or talked about 25 that interview,
1 Zech=mn 53 1
(~} 2 Q Did any of them relate in any way to
\m '
3 the investigation that Mr. Kcaten and the others 4 were conducting?
5 A Not to the best of my recollection.
6 Q You have described, just to summarize, 7 the Kemeny Commission deposition, the Rogovin 8 testimony, the interview with the NRC representatives, 9 and this interview with Mr. Keaten, 10 I would like to ask you whether in 11 addition to those four situations you have been 12 interviewed concerning the Metropolitan Edison g- 13 training program as it existed before the accident
\v!
14 by anybody else?
15 A There are two other groups.
16 Q Who were they?
17 A Penn State P-edagogical Review Committee, l 18 and the representative of the PQS Company.
I 19 Q Is that all?
l l
l 20 A To the best of my recollection at this
! 21 time.
- 22 Q what was the full name of the first 23 group you gave us?
24 A You are referring to the Penn State?
/O
(_,/ 25 Q Yes.
1 Zechnen 54
(} 2 A The full name of that committee?
3 Q Right.
4 A The report was the Pedagogical Review, 5 and I forget the rest of that title. Something 6 like Pedagogical Review of Training. I don't 7 recall the specific title.
8 Q Would it be A Pedagogical Review of 9 Reactor Operator Training at the Three Mile Island 10 Plant issued by the Nuclear Engineering Department 11 of the College of Engineering of Penn State?
12 A To the best of my recollection, that is 13 what the title was, 14 Q Just so we understand, is the Nuclear 15 Engineering Department of the College of Engineering 16 at Penn State the place where you worked for six 17 years or so?
18 A That's correct.
19 Q Does the present president of the 20 Nuclear Regulatory Commission have any past 21 connection with that Penn State?
O 22 A would you repeat that?
23 Q Does the present chairman of the 24 Nuclear Regulatory Commission have any past t
L/ 25 connection with Penn State University?
1 Zochman 55
(~) 2 A Yes, he does. If you are referring to C/
3 Nunzio Paladino?
4 Q Yes, 5 A Yes, he does.
6 Q Was he at Penn State while you were 7 working there?
8 A Yes, he was.
9 Q What was his position?
10 A To the best of my recollection, he was 11 Dean of Nuclear Engineering at that time.
12 Q So basically he comes out of the same
,f- 13 organization that was commissioned to conduct the (S )
14 review that you just described?
15 MR. MacDONALD: You mean he worked 16 for the same department that was doing the 17 review?
18 MR. FISKE: Worked for the College of 19 Engineering. He was a dean of the College of .
20 Engineering, 21 A I don't know what his position was at 22 the time they did the review.
23 Q I understand that, but the review was 24 done by the College of Engineering at Penn State?
b')
i/ 25 A Nuclear Engineering, right.
1 Zochnan 56 2 Q And at one point Mr. Paladino was dean 3 of that college; isn't that what you just said?
4 A That's correct.
5' Q Do you know how it came about that the 6 college of Nuclear Engineering at Penn State was 7 selected to do this review?
8 A No, I wasn't a part of those discussions 9 or the decision that decided upon them to do that 10 review.
11 Q Do you know who made that decision within 12 GPU?
- 13 A No, I do not.
14 Q When is the first time you learned that 15 such a review was going to take place?
16 A I have no recollection at this time when 17 it was.
18 Q I take it there did come a time when you 19 learned that?
20 A There did come a time I learned that 21 there was going t,o be a Review Committee from Penn O 22 State looking at our training.
23 Q How did you learn that? Did someone 24 at Met Ed tell you that?
25 A Yes, someone from Met Ed told me that,
1 Zsch2an 57
[]
\s 2 That's correct.
3 g were you personally interviewed by 4 someone from the College of Nuclear Engineering in ggg 5 connection with that review?
6 A Yes, I was.
7 Q Do you know whether Mr. McCormack was 8 interviewed?
9 A I have no recollection either way.
10 g were you interviewed on more than one 11 occasion?
12 A By the Penr. State?
g- x 13 g Yes.
O 14 A Yes, I was.
15 g were you asked to make written 16 documentation relating to the training program as 17 it existed before the accident available to the 18 Penn State reviewers?
19 A To the best of my recollection, right
! 20 prior to the Kemeny Commission investigation, Frank 21 McCormack wrote a summary of licensed training, G 23 Unit 1 and Unit 2, and to the best of my recollection, 23 that was also not only presented to the Kemeny 24 Commission but also presented to the Penn State
/~%
U 25 committee.
1 Zachman 58
('s 2 Q Did you see the report of the Penn State Nl 3 committee when it came out?
4 A Yes, I did.
5 Q Had you seen a draft report before it G
6 came out?
7 A To the best of my recollection, I did.
8 Q And you were given an opportunity to 9 comment on the draft report as it existed?
10 A I do recall orally making comments about 11 the draft report.
12 Q To people at Penn State?
gg 13 A To people at Penn State.
N~,.!
14 Q You said you were also interviewed by 15 the PQS people.
16 A PQS Corporation, yes.
17 Q What does that stand for?
j 18 A To the best of my recollection, it stands 19 for' Personal Qualifications Services.
20 Q Was that an organization that was also 21 retained to conduct a review of the' training l 22 program as it existed before the accident?
23 A They are charged to look at our past 24 training.
(h
(,) 25 Q And you were interviewed by them, you l
l
1 zechuan 59 2 said?
3 A I was interviewed by Mr. Frank Kelly.
4 Q Who was it that interviewed you from g 5 Penn State?
6 A Dr. Gordon Robertson was one individual, 7 and I can't recollect the other individual's name.
8 Q Was Gordon Robertson someone you knew 9 while you were at Penn State?
10 A Yes, he was.
11 Q Did you ever see any notes or summary 12 of the interview, any of the interviews, that you 13 had with any of the people at Penn State?
14 A I don't recall seeing any notes :r 15 reviewing any notes of any sort.
16 Q Or summaries of any kind?
17 A or s umm a ri e s', to the best of my 18 recollection.
19 Q Did you ever see any notes or summaries 20 of the interview that Mr. Kelly conducted?
21 A May I get a clarification what you e 22 mean summary, would you include a summary as a 23 final report?
24 Q No, I was not.
(~,
25 A would you repeat your question?
1 Zechman 60
.(
2 Q Did you see any notes or summary of the 3 interview that Mr. Kelly conducted?
4 4 A No.
ggg 5 Q Did you see a draft of the report 6 prepared by PQS before it became final?
7 A I have no recollection either way on that 8 one.
9 Q During the years 1976 through 1979, was 10 there a budget for the Training Department at Met Ed?
11 A I don't recall either way during that 12 period.
( 13 Q I guess my question is during this ,
14 period of time while you were Supervisor of Met 15 Ed Training Department, did you know one way or the 16 other whether there was an annual budget for that 17 department?
18 A Let me go back to your original question.
i 19 You said since 1976. In November 1976 I was a 20 group supervisor and not the Supervisor of Training.
i 21 During my time as Supervisor of Training, I remember i
22 being involved in the budget to a certain extent.
23 Q What was your role in the preparation of l
24 the budget?
O 25 A The reason I say limited is that the
1 zachnen 61 rn 2 functions I was performing during that time varied (v) 3 at different points of time, and I recall that Frank 4 McCormack was doing a lot of the ground work on the 5 budget in that time for me at that time, if I recall ggg 6 correctly.
7 Q Can you tell us what the budget was 8 for the Training Department?
9 A I no longer recollect that information.
10 Q You can't even give us an approximation?
11 A That has been so long ago, I have no 12 recollection of even the magnitude any longer.
13 You understand I am asking now about v
-} Q 14 the year 1979?
15 A I understand that you are asking about 16 the year 1979.
17 Q When you came to Met Ed, you were not 18 a licensed control room operator; is that correct?
l 19 MR. MacDONALD: Licensed on what?
20 MR. FISKE: Licensed control room l
l l 21 operator.
22 Q When you came to Met Ed, you had no 23 other license other than the license that you 24 previously described that you had while you were at (3
l kJ 25 Penn State; is that correct?
l 1
(
1 Zschann 62 r N.
( j
) 2 A Relating to nuclear reactors, that's 3 correct.
4 Q In other words, you did not have a ggg 5 license that would have allowed you to be an operator 6 on either TMI-1 or TMI-27 7 A That's correct.
8 Q And is it correct that at the time you 9 became Acting Supervisor of the Training Department 10 in November 1977, you did not have a license on 11 either unit?
12 A That's correct.
(')
L ,1 13 Q And you had no nuclear license other 14 than the one you had at Penn State?
15 A That's correct.
16 Q Is it correct that when you became 17 Supervisor of the Training Department in September 18 1978, you did not have a license which would have 19 enabled you to be an operator on either TMI-1 or 20 TMI-27 21 A I did not have a license that would 9 22 legally let me o'perate the controls of that reactor.
23 That's correct.
_ 24 Q Isn't it a fact that beginning in
\
'~'
/
25 September 1978 when you assumed the position of
1 zschann 63
/\
(v) 2 Supervisor of the Training Department that from 3 that point on right up to the date of the accident 4 you were spending eight hours a day studying to ggg 5 become a licensed control room operator?
6 A It is true that I was assigned on a 7 full-time basis to study for a license. That is not 8 to say that all eight hours was devoted to that.
9 There were times I was in my department and had 10 conversations and may have written a memo or two on 11 behalf of the Training Department, but my primary 12 role was studying for a license.
(^]
'wJ 13 g would it be fair to say that other than 14 studying for the license, your responsibilities 15 during that period of time while you were Supervisor 16 of the Training Department from September 1978 right 17 through the day of the accident were limited to i
18 consultation with your people and your staff if 19 they had questions?
20 A on a limited basis.
21 (Portion of the record read by the 22 reporter.)
23 A It was on a very limited basis. That is
, 24 true, i
25 Q Isn' t it also true that beginning in or
1 Zech=an 64 2 about November 1977 when you became Acting Supervisor, 3 you began this period of study designed,to enable 4 you to become a licensed control room operator?
g 5 A Not on a full-time basis. It was on a
.6 limited basis at that time. It was more of an 7 orientation and reorientation with the physical 8 hardware at that time.
9 Q But this program of study to become a 10 licensed operator began at the same time that you 11 assumed the position of Acting Supervisor of the 12 Training Department; isn't that correct?
13 A on a* limited basis. That was not my 14 only function at that time. That is what I am trying 15 to clarify.
16 Q But isn't it a fact that during this 17 period November 1977 through September 1978 while 18 you were Acting Supervisor of the Training i
19 Department, you were devoting a considerable amount l
20 of time to study as opposed to running the department?
21 A I guess I would argue on the point of 9 22 what would be considered considerable time, I was 23 spending time. It was limited. It was spotty. By 24 spotty, I mean I may spend a half day one day on G
~ 25 studying and another two days totally in my office
1 Zechusn 65 l
rs
( ) 2 on work-related subjects.
A/
3 Q Isn't it a fact that the amount of time 4 you were spending on study interfered with your 5 training responsibilities to the point where the ggg 6 decision was made basically to take the training 7 responsibilities away from you and allow you to 8 devote eight full hours a day to study?
9 (Question read by the reporter.)
10 A I have got to put this in a kind of 11 context. During that period of time, it was in my 12 opinion difficult to concentrate on the studying r"N 13 with the amount of work load I had in the Training k._
14 Department. It was decided in September of '78 15 when I was promoted to Supervisor of Trainin g that 16 I made it clear that, one, I wanted to get that 17 license, that I felt I n'eeded specific full time 18 available to continue my study based on the 19 scheduling of the NRC exam in the following three 20 months, 21 Q You said earlier that you testified O 22 before the President's Commission. By that, I 23 take it you mean that you gave a deposition before 24 lawyers on the staff of the President's Commission; k' - 25 correct?
r 1 Zschnen 66
(^]
\ _/
s 2 A That's correct, 3 Q And that was given under oath; is that 4 correct?
5 A That's correct.
O 6 Q I would like to read you a series of 7 questions from page 183 and 184 of the transcript.
8 I will start with line 8, and I am going to read you 9 a series of questions and answers and ask you 10 whether you were asked those questions and gave 11 those answers to lawyers from the President's 12 commission in July 1979.
13 " Question: Did anyone approve of your ti 14 spending time training during the period November 15 '77 to September '78?"
16 " Answer: Yes, this was both understood 17 by Alexis Tsaggaris and George Troffer, and it was 18 at their suggestion."
19 " Question: They suggested to you 20 that you become licensed on Unit 1?"
21 " Answer: No, they had discussed it with 6 22 me and I made the decision. They had asked me 23 whether I would be interested in obtaining a 24 license, and I did and I made the desire known in
/^N
(_,) 25 November '77."
1 zochman 67 2 " Question: Mr. Tsaggaris and Mr. Troffer
(~')T 3 discussed it with you and you became licensed?"
4 " Answer: First Mr. Tsaggaris,and I ggg 5 beli ev e I had further discussions with Mr. Troffer."
6 " Question: And they understood that 7 beginning in November '77 to September '78 you were 8 going to spend time training?"
9 " Answer: They understood that."
10 " Question: Did you indicate to them 11 how much time you would spend?"
12 " Answer: They knew I was spending a rN 13 considerable time trying to do both jobs."
( /
\J 14 " Question: And in September '78, when 15 you devoted full time to training for the SRO 16 license exam, did somebody approve that?"
17 " Answer: Yes, at the time I was 18 promoted to Supervisor of Training, that was l
19 discussed with me by Alex Tsaggaris. Apparently 20 he and Mr. Troffer had discussed it and felt that l
21 the ability to train and run a department at the O 22 same time was not working out very well and they 23 would allow me full time to seek a license."
i l
24 " Question: You indicated that they l
l'~h;
' ./ 25 indicated to you that the ability to train and run
?
1 zochann 68
('
'V
) 2 the Training Department at the same time was not 3 working out?"
4 " Answer: I indicated to them."
ggg 5 " Question: And on what basis did you 6 indicate to them?"
7 " Answer: Well, that training was 8 totally interrupted. I would sit in a lecture and 9 sit there two minutes and the phone would ring and 10 I would have to go to a meeting or questions were 11 asked by people in the department and things of that 12 sort. The training was just not effective."
(g 13 Were you asked those questions and did
%,)
14 you give those answers under oath to the President's 15 Commission?
16 MR. MacDONALD: You are asking whether l
17 he can recall these questions and answers?
18 MR. FISKE: I will put my question 19 exactly as I put it.
20 A There is also a correction made to that 21 deposition, 9 22 Q The first question before we get to 23 the subject of possible corrections is, whether you 24 were asked those questioc.s and gave those answers?
p
\J 25 A With excepting the fact that I made
1 zcchsan 69
() 2 corrections to that document and that I don't see 3 them here, those questions were answered to the best 4 of my recollection, 5 Q Let me see if I understand what you are g
6 saying.
7 To the best of your recollection the 8 questions and answers that I just read were the 9 questions that were asked and the answers that you 10 gave at the deposition, and you say you think at 11 some time after that you made corrections to them; 12 is that correct?
'T 13 A That's correct.
J 14 Q Did you make those corrections before 15 you signed th~e deposition?
16 A To the best of my recollection, I made 17 those corrections prior to signing the deposition.
18 So that whatever corrections you made Q
19 would be contained in the final copy of the deposition l 20 as it is signed?
21 A I have no idea what they did with that 22 or where it is or what is or is not with the final 23 one, 24 Q Did you keep a copy of the deposition O
V 25 with the corrections that you made on it?
l
1 ZGehmsn 70 3
(v ) 2 A To the best of my recollection, I did, 3 Q Do you still have that?
4 A I am not sure. I may or may not still g 5 have that.
6 Q Going back again to this period November 7 1977 through the date of the accident when you were 8 either Acting Supervisor of Training or Supervisor 9 of Training, as part of the training program, were 10 the people who were being trained given written 11 material, handout material, to read during the 12 training?
(~h 13 A You have to be more specific. I can
( ,/
14 only answer that in generalities as the question is 15 posed to me. There are times when written material 16 in their training program would have been given to 17 them, and I can think of oral exams as an example 18 which wouldn't have been.
19 Q The question is very general. It is 20 simply whether during that period as part of the 21 training program there were written materials that 9 22 from time to time were handed out to the people 23 who were being trained?
24 A That's correct.
)
\s' 25 Q Who was responsible for selecting the
l I
1 Zochmen 71 ;
l em l
( ,) 2 written material that was given out to the people 1
3 being trained? I 4 A Since the material was developed over ggg 5 a period of years, it would have been different 6 people at different times.
7 Q During the period of time that you were 8 Acting Supervisor of Training and then Supervisor 9 of Training, were you personally satisfied that the 10 written material that was being given out to the 11 people that were being trained was adequate for 12 the purpose for which it was being used?
(; 13 A Realizing there were times during the U
14 period that I was Acting and Supervisor of Training, 15 I did not see all the material that was handed out, 16 because of either my own personal training or 17 particularly during the' period '78 to the accident 18 when I was in training full time, I may not have 19 seen all of it.
20 Q So you are saying that there may have 21 been material added to the training program that O 22 you were not familiar with?
23 A I have no recollection either way.
~
,, 24 Q Who in the Training Department during
( )
25 that period of time had the responsibility to make
~
1 Zochman 72
() 2 that determination?
3 A During that period of time both 4 Mr. Frank McCormack and Marshall Beers, and during ggg 5 the period when I was Acting, I believe Don Goodman 6 was there at that time, and he had that responsibility 7 in my absence.
8 Q Directing your attention again to 9 Exhibit 555 and to the column on the right-hand side ,
10 listing Administrators-Nuclear Technical Training, 11 could you read the names for me from the top?
12 A Are you talking for the period March 28,
(^3 13 19797 N) 14 Q Yes. You may be more familiar than I.
15 A Myself, Richard Zechman. Frank McCormack, 16 Marshall Be e r s , Denis Bolts, Eric Orwick who I 17 don't believe was there at that time, Chuck Husted, 18 Nelson Brown, Karen Tennis.
19 Q Apart from the written material that I 20 just asked you about during this period of time, 21 again 1977 November to the date of the accident, 9 22 were there other materials that were used in the 23 training program such as video tapes or films?
24 A I have no recollection either way.
O's 25 (Recess taken.)
~
1 Zochnon 73
, fN 2 BY MR. FISKE:
b/ .1 3 Q Going again back to this period of 4l November 1977 through the date of the accident, I I'
e 5 6
take it during that entire time period while you were Acting Supervisor of Training and then 7 Supervisor of Training you reported to Alexis
, 8 Tsaggaris?
9 A No, that is not necessarily true. There 10 was a period of tim'e I reported to Alexis Tsaggaris 11 and then a later time that I reported directly to 12 George Troffer. I don't recall the exact date.
f3 13 Q What was the position held by Mr. Tsaggaris
( i w/
14 while you were reporting to him?
15 A .As I mentioned earlier, I am not quite
. 16 sure of the title. Direc' tor of Training comes to 17 mind.
18 Q Ion't it a fact that during that period, 19 let's say November 1977 on, the Director of Training 20- was located in Reading?
21 A I forget the exact date that he took e 22 permanent location there, but somewhere in that 23 ' time he maintained an office in the Reading area.
24 Q- If I just told you to save time you
- ((j; 25 testified before the President's Commission that
s
\
1 200hnnn 74 l9 -
2 during the period November '77 'o November '78 t
'w) 3 Alexis Tsaggaris was the, Director of Training in 4 Reading, would that refresh your recollection? That ggg 5 is at page 185. '
I 6 A I don't recall either way at the moment.
7 Q There was a period of time in any event 8 which we can identify separately later that 9 Mr. Tsaggaris was physically located in Reading?
10 A That's correct.
11 And is it correct that during that Q
12 period of time his visits.to the island were 13 infrequent?
C')
V 14 A I have no recollection at this time what 15 the frequency of those v'isits were.
16 Let me raad you some questions and Q
17 answers that you were asked and gave at the 18 President's Commission deposition.
19 Reading now from page 185 and 186, and l
20 this I think you will see from the preceding question l
l l 21 and answer refers to Mr. Tsaggaris:
h l
22 " Qu e's ti on : Was he closely involved 23 with the day-to-day activities?"
24 " Answer: I kept him abreast as much N -) 25 as possible of what took place. He pretty well
. s l
1 zochsen 75
()~ 2' lef t me on my own. If I had questions, I would 3 call him and discuss it with him."
3 f
4 " Question: Did you have day-to-day s
^
ggg 5 contact with him?"
6 " Answer: No."
( 7 " Question: How frequently did he come 8 to the island?"
s .
9 " Answer: Infrequently."
. i w-10 " Question: When you say infrequently, 11 once a month?"
12 " Answer: I can't remember."
13 " Question: would you see him here once 14 a week?"
s
'15 " Answer: I don't believe so."
16 " Question: Once a month is probably 17 more accurate?"
s 18 " Answer: It is hard to say. It was l
19 infrequent. It wasn't on any periodic basis. I l s ;G vouldn't say once a month or once every two weeks."
21 " Question: when he came here, was that O 22 at your request?"
23 " Answer No."
24 " Question: What was the purpose of O s 25 s
his visits?"
e i
y .-m,- r -.--9 --. , , , . - - - - - ------..--% --.,,_...--.,._r,. -
, - - , , y c ,. -
1 Zochnan 76
,m (v ) 2 " Answer Business that he had with 3 station management. That is all."
4 Were you asked those questions and did ggg 5 you give those answers to.the President's Commission?
6 A I recollect speaking in that area, but 7 I don't recall any longer whether that is specifically 8 what I said at that time.
9 Q As you listened to the questions and 10 answers being read to you just a moment ago, do you 11 have any basis as you sit here today for saying that 12 the questions and answers that I read do not accurately 13 reflect what you were asked and what you said on
{^)')
n.
14 that occasion?
15 A This is one of the areas in which I 16 was asked to speculate. Under those circumstances 17 at that time I am not sure that that wasn't just 18 that, speculation. The only thing I can tell you 19 right now with respect to his visits to the island 20 is that they were periodic.
21 MR. FISKE: I move to strike that 22 answer as non-responsive.
l 23 MR. MacDONALD: You can make any motion 24 you want. I think he answered your question.
I L~ 25 MR. FIS KE : No, he did not.
4 1 Zechman 77
\ ,) 2 Q Do you have any basis sitting 3 here today for saying that the questions that I 4 read and the answers that I read do not accurately ggg 5 reflect what you said, what you were asked and what 6 you said on that occasion?
7 MR. MacDONALD: I object. I think he 8 answered the question.
9 MR. FISKE: I am not asking whether 10 he was speculating or not speculating. I 11 asked if he was asked those questions and he 12 answered those questions. If he wants to say
(/)
s-13 because of some preprogrammed preparation that 14 he was speculating, you can bring that up on 15 your questioning later. I would like him to 16 answer the questions responsively and fairly.
j 17 MR. MacDONALD: I think that is what he l
18 is doing. I am not here to judge his answers.
19 MR. FISKE: Somebody is going to judge 20 these answers, and you --
21 MR. MacDONALD: I am sure that is not k
22 going to be you.
23 MR. FISKE: I want to make it very l
- g. 24 clear when that time comes that this answer i :
'w/
25 that I --
that question I just asked him clearly
1 Zochncn 78
(/
(_
- 2 on it's face did not call for Mr. Zechman to 3 say whether he was or was not speculating 4 when he gave those answers. The question was, 5 which I will repeat again, does he have any 6 basis as he sits here today for saying that 7 those questions and answers that I read do 8 not accurately reflect what he said.
9 Q Do you understand that?
10 MR. MacDONALD: I think he understood 11 that the first time. If you want to ask the 12 question again, go ahead.
g3 13 MR. FISKE: If he says he understood it
()
14 and volunteers this preprogrammed speech about 15 speculation, that makes it even worse.
16 MR. MacDONALD: I don't think anything 17 is preprogrammed. Unfortunately, I think he is 18 testifying to the best of his recollection 19 truthfully and honestly. You can form any 20 opinion you so choose, but don't intimidate 21 the witness by telling him what you think he 9 22 should say and what you think his answer should 23 be. You can ask the question and he can 24 give the answer.
(/
w_. 25 MR. FISKE: Do you seriously believe that
1 Zechman 79
()
2 the answer he gave was responsive to the 3 question I asked?
4 MR. MacDONALD: I am not here to give ggg 5 testimony. Neither are you, 6 MR. FISKE: You can take the fifth on 7 that if you want.
8 MR. MacDONALD: I am not taking the fifth.
9 I am not here to clutter up the record with 10 speeches and testimony like you are. Just ask 11 the questions and he will give you an answer.
12 MR. FISKE: I am trying to get an
/ \
( 13 answer which I haven't gotten.
%,)
14 BY MR. FISKE:
15 Q Are you going to answer my question?
16 A All that has gone on, I have forgotten 17 the question. What is the question?
18 I have asked you three times. The Q
19 question is Do you remember now the questions that 20 I read from the President's Commission deposition 21 and the answers you gave under oath?
O 22 A I don't recall either way at this time 23 those specific questions and answers.
,- 24 Q My question is as you sit here today,
(')
25 do you have any basis for saying that the transcript
1 Zechman 80
(.
(,j 2 which is in front of you from pages 185 and 186 and 3 the questions and answers that I read from that 4 transcript do not accurately reflect the questions gg) 5 that you were asked and the answers that you gave on 6 that occasion?
7 A The only basis of addressing that area 8 has to do with the frequency. I just don't recall 9 the frequency.
10 Q You misunderstood my question, I believe.
11 MR. MacDONALD: I think he is trying to 12 do the best he can.
A) ixj 13 Q I am simply asking and let's try one 14 more time, whether as you sit here today you have 15 any basis for telling us that the written transcript 16 which you have before you of the questions and the 17 answers at this deposition that you gave in July 18 1979 do not accurately reflect what you said back 19 there in that day in July?
20 A As I mentioned just a while ago, I have 21 no recollection either way whether what I have on 9 22 here is what I said at that time. This is a piece 03 of paper that somebody else transcribed. I don't g 24 recall.
%) 25 Q You have no basis for saying that it is
1 Zechman 81
~
2 ina curate?
G MR. MacDONALD: He just told you he had 3
4 n rec llection, 5
A I have no basis either way.
ggg 6 Q During this time that we have been talking 7
about while Mr. Tsaggaris was in Reading, did he g review the written materials that were given out 9 to the students in the class in the training program?
10 A Not to the best of my recollection.
11 Q Did he come to the island and audit 12 the classroom sessions?
,w 13 MR. MacDONALD: You mean by audit, sit (v) in on the classrooms?
14 15 MR. FISKE: Yes.
16 A It is too long ago. I have no 17 recollection either way.
18 Q Did he review the video tapes that were ig being used in the curriculum at that time?
l 20 A I d n't know that'there were video 1
l l 21 tapes -- I don't recall whether there were video l
22 tapes being used.
23 Q Were there written lesson plans that i 24 were being used by the instructors?
l f}
U 25 A Yes.
1
1 Zochann 82 2 Q Did Mr. Tsaggaris come to the island
[GD 3 and review those lesson plans during that period of, 4 time?
5 A I have no recollection either way.
ggg 6 Q Do you have any better recollection 7 of whether Mr. Troffer did those things when he 8 took over for Mr. Tsaggaris?
9 A To the best of my recollection, he did 10 not.
11 Q During this period and let's go back a 12 little bit, from the time you first started in the
("]
v 13 Training Department at Met Ed right up to the date 14 of the accident, was it part of the training program 15 to have classroom lectures?
16 A Can I ask you for a time frame? Are 17 you talking about from day one on the island when 18 training first started for the first CRO's?
i 19 Q Let's take this period '76 to the date of 20 the accident.
21 A Training of operators and CRO's and O 22 auxiliary op e ra'to rs included not only classroom -- it 23 certainly included classroom lectures, but that was 24 not the total mode or type of training they received.
l /~
! \ >h 25 Q But there were classroom lectures?
l
1 zochnen 83 2 A Yes, there were.
l 3 Q Where were they held?
4 A over the history of the island, many ggg 5 different places.
6 Q Let's take the period during the time 7 you were either Acting Supervisor or Supervisor.
8 A They were held in what was known as the 9 training building, training trailer complex, if 10 you will.
11 Q Where was that? On the island?
12 A on the island, gS 13 Q When you say the training trailer
'V 14 complex, does that mean there were more than one 15 trailer?
16 ,
A Yes, there was more than one trailer in 17 a miniature trailer city.
18 What type of trailers were these?
Q 19 A They were trailers that --
I don't recall 20 the length or size of them, but they were converted 21 into classrooms.
O 22 Q Converted from what?
23 A We got them that way. They were empty 24 shells, and then we put classroom settings in them,
['/
)
25 chairs and blackboards and all the training materials.
1 Zochnen 84
( 2 Q How many were there?
3 MR. MacDONALD: This is November 1977?
4 MR. FISKE: Yes, ggg 5 A To the best of my recollection, there 6 were three,and the reason I am hesitating is that 7 part of the trailers were attached to a wooden 8 building and became an integral part of that building.
9 Q Was there a special trailer during that 10 period of time that was used for video tape 11 presentations?
12 A If any video tapes would be shown, they 13 could be shown in any one of those areas.
14 Q Was there a formal library with reference 15 material?
. 16 A There was a small library of reference 17 material in storatg e a rea.
18 Was that located in one of the trailers?
Q 19 A Yes, it was.
20 Q Was there a librarian?
21 A Let me clarify. You said in one of the O 22 trailers. To the best of my recollection, it was 23 stored in one of the --
one or more of the rooms of 24 the wooden complex.
25 Q Was there a librarian?
1 Zochnan 85
[\
gj 2 A There was a girl who took care of that 3 along with other duties. She did not have the title 4 librarian as such.
lll 5 Q Was there a card catalog indicating 6 what material was available in the library?
7 A To the best of my recollection, she 8 had a three-ring binder that listed the materials 9 that were available.
10 Is that binder still available?
Q 11 A I have no recollection either way.
12 Was there a procedure for taking material Q
~
~T 13 out of the library?
(U 14 A When you say procedure, you mean a 15 formal written document?
16 If someone wanted to take something out Q
i '
17 of the library to read it, was there a procedure 18 where they would do that, sign out?
19 .
A I don't think there was any formal 20 mechanization. I think it was just common courtesy 21 to go tell her what material you were taking.
22 Q Then there was a formal procedure to be 23 sure one knew who had what publication?
24 A No, I said, to the best of my b
o 25 recollection, there was not a formal procedure.
1 Zechann 86 2 Q What was the name of this person who 3 was in charge of the library?
4 A Karen Tennis. If you look on this g 5 list --
6 Q Exhibit 5557 7 A Yes. Under March 28, 1979, the last 8 name you see, Karen Tennis, if you go to the middle 9 column March 1st, you see Karen Ritchey. Karen 10 Ritchey was her maiden name.
I 11 Q So some time between March 1, 1978, and 1
l 12 March 28, 1979, in addition to the library, she 13 assumed the responsibilities of a husband?
14 A I believe that is correct.
15 (Luncheon recess taken at 12:30 P.M.)
l 16 17 18 l 19 l
20 l 21 h
22 23 24 O 25
i 1 zechman 87
() 2 AF TE RHOON S ES S I ON 3 (1:30 o' clock P.M.)
4 RI CHA RD W. Z ECHM AN , having been previously duly sworn, resumed and ll) 5 6 continued to testify as follows:
7 EXAMINATION (continued) 8 BY MR. FISKE:
9 Q You realize you continue under oath?
10 A Yes.
11 Q Are you a member of any union?
12 A No, I am not a member of any union.
() 13 Q Were you at any time since you have been 14 employed by Met Ed?
15 A No, I have not been a member of any 16 union since employed by Met Ed.
17 Q Am I correct that none of the people who 18 served as Supervisor-Training, Group Supervisor, 19 or Administrator-Nuclear Technical Training were 20 members of the union?
21 MR. MacDONALD: By their title or 22 individually any people who served in that 23 capacity? I don't know whether you are trying 7s 24 to focus on the titles or the people.
( I G'
25 MR. FISKE: If it makes a difference.
1 Zochacn 88 2 A It does.
(v) 3 Q To the best of your recollection, during 4 the period of time November '77 to the date of the 5 accident, while you were either Acting Supervisor 6 or Supervisor of Training, were there any people 7 serving with you or under you as Group Supervisors 8 or Administrator-Nuclear Technical Training who 9 were members of the union?
10 A No, there was not.
11 Q Is it correct that during this same 12 period of time the Training Department did not
(~} 13 assign homework to the students in the training
%)
14 program because of union regulations that would 15 have required overtime to be paid if homework had 16 been assigned?
17 MR. MacDONALD: You are talking of 18 homework, out of class work?
19 MR. FISKE: Yes.
20 A It is true on an official basis we did 21 not assign students on their off duty hours at the e 22 station. That fs not to imply that they were not 23 given assignments while on company time or does 24 it imply that they did not do work on their own hl
\/ 25 after hours.
1 Zochann 89
( ) 2 Q To the extent they did work outside 3 class, it was either work that was done during 4 the regular union work week or it was work that gg) 5 was done on their own time for which they were not 6 paid?
7 MR. MacDONALD: Are you implying there 8 was a specific union work week by that 9 question?
10 Q Was it one of the terms of the contract 11 that you had with the union that members 12 of the union would have to be paid overtime if in fv ') 13 a given week they worked more than a specified 14 number of hours?
15 A It is understood that if I were to 16 assign work to a union worker, and I would require 17 him to do that work in excess of his normal working 18 day, I would have to pay him overtime.
19 Q And for that reason, that type of 20 hcmework was not assigned; isn't that correct?
21 A Normally we allowed time in class for O 22 them to do it in class and did not assign it out of 23 class under normal conditions.
,s 24 Q Let me show you a document that we'll
\_/ 25 mark as B&W Exhibit 556.
1 zachman 90
() 2 (Document dated August 1, 1973 marked 3 B&W Exhibit 556 for identification, as of this 4 date.)
Do you recognize this document?
gg 5 Q 6 A I recognize this document.
7 Q Is that a document that you prepared?
8 A That is a document that I prepared.
9 Q Does this reflect the various types of 10 training programs which have been conducted by 11 the TMI staff since the date of this document 12 which is August 1, 19737 13 A To the best of my recollection, it was
(
14 a summary of training that I put together at that 15 time. I don't know the scope any longer of all the 16 documentation searches that I performed to get all 17 this, but there was a summary that I put together l
18 for Mr. Herbein.
19 Q What was his position at that time?
i l 20 A I don't recall the specific title that 21 he had at that time.
O 22 Q Let me ask you this question. Were 23 training programs of the type listed on this document 24 conducted by the Training Department during the O 25 period of time that you were either Acting Supervisor I
1 Zechman 91
( 2 or supervisor, that is, November '77 through the 3 date of the accident? By that, I don't mean -- just 4 to clarify that question. I am not asking you to lll 5 tell me every single item on pages 2 through the 6 end were the same but basically I am asking you 7 whether the type of programs outlined on page 1 8 of the document were also conducted during the 9 period of time when you were in charge of the 10 Training Department.
11 A Excuse me for some confusion. You 12 referenced back to page 1.
(~ 13 Let me go at it a little bit differently V} Q 14 if there is any confusion about this because what 15 I am asking I think is'relatively simple.
16 During the period of time that you 17 were in charge of the Training Department, that is, 18 either Acting Supervisor or Supervisor, did the Training l
19 Department conduct training programs for the 20 operations staff as that phrase is used on page 1 21 of the document in front of you?
O 22 A If you are asking have we conducted I
23 training programs for supervisory staff which 24 included shift foremen and shift supervisors and for O
V 25 non-supervisory staff includes control room operators y - _ - ----,.m.,,,c ..- -. .-
1 Zochman 92
[)
U 2 and auxiliary operators, yes, we did conduct 3 training programs for those classificationse 4 Q During this same period of time, did lll 5 you conduct training programs for the technical 6 staff, radiation protection and chemistry personnel, 7 both supervisory staff and non-supervisory staff?
8 A To the best of my recollection, we did 9 not during that period.
10 Q was any training program conducted for 11 the supervisory and non-supervisory staff in radiation 12 protection and chemistry during that period of T' 13 approximately a year and a half?
(-)T 14 MR. MacDONALD: Are you talking now 15 about the supervisory staff under number 2 16 which is staff chemists, radiation protection 17 supervisory and analysts and radiation 18 protection technicians non-supervisory staff?
19 MR. FISKE: Yes.
20 MR. MacDONALD: For those people?
21 MR. FISKE: Yes.
22 Q was any training program conducted for 23 the staff chemists and radiation protection 24 supervisory staff and the analysts and radiation
(~h
'~ 25 protection non-supervisory technicians during that
1 zochman 93 1
2 period of time?
3 A I have no recollection of what training 4 they had during that time. A lot of the training lll 5 was conducted by the line function itself or people 6 being sent off to offsite schools.
7 Q Do I understand you correctly that if 8 any training was given to them, it wasn't given by
, 9 the Training Department of which you were the 10 supervisor?
11 A There is one area, general employee 12 training, to the best of my recollection, they
() 13 appeared in that training program which we conducted,
- f. 14 to the best of my recollection.
l t
l 15 Q Was there any kind of an organizational 16 structure for the administration of training at i
17 Met Ed so that whereby some training was done 18 outside of the Training Department of which you were 19 Supervisor?
l l 20 A Each line function that is, whether it 21 be the Maintenance Department, Chemistry Department, 22 Radiation Protection Department, had the liberty,and 23 often did to, send their people to offsite schools, 24 outside the initiation by us. We would receive 25 the final documentation of their attending those
\. _
1 Zechman 94 (m
(_) 2 schools.
3 Q That was not done for a shift foreman and 4 shift supervisors and control room operators and llh 5 auxiliary operators?
6 MR. MacDONALD': You mean for any of 7 those --
8 MR. FISKE: Sending them to offsite
, 9 schools.
10 A- No, the line function had that same 11 liberty.
12 Q I guess what I am trying to get at is
() 13 just as a matter of conceptual organiz,ation, did 14 the Training Department of which you were Supervisor 15 or Acting Supervisor, have the same type of 16 responsibility for training the technical staff, 17 the maintenance staff, and the engineering staff 18 as those terms are used in Exhibit 556 as you did 19 for training the operations staff?
20 A I am sorry. I just am not getting the 21 full understanding of the way you are asking the 22 question.
23 Q Let's go through this document 556.
24 Maybe that is the easiest way to get at it. This 73
(.
25 talks as of August 1, 1973. Let's turn to page 2
1 Zochnen 95
( ,) 2 wh'ere it says " Operations Staff Training Programs."
3 A Yes.
4 Q Then you see a whole lis t of things lll 5 under " Supervisory Staff" and then a whole other 6 list of things under "Non-Supervisory Staff;" is that 7 correct?
8 A That's correct.
9 Q And am I correct that the responsibility 10 for the training program outlined on pages 2 and 3 11 for the operations staff was within the Training 12 Department at Met Ed?
(m 13 l ) A Not necessarily true. Let me give you L./
14 an example, on page 2 under " Supervisory Staff,"
15 item 2, observation experience and observation 16 training, six months at Saxton. There was not a 17 Training Department at that time. The people were 18 sent to Saxton under the direction of the appointed 19 site superintendant at that time.
20 Q Putting it another way, there are 21 references on pages 2 and 3 to various courses 22 that were conducted either at Babcock & Wilcox or 23 General Electric or other places other than at the 24 island; isn't that correct?
[_s v) 25 A That's correct.
1 Zochman 96 e
2 Q What I am asking I guess is was it the 3 Training Department at Met Ed that had the 4 responsibility for determining the extent to which lll 5 as part of the training program for operations staff 6 they would participate in programs off the island 7 o'f the type that are outlined on pages 2 and 37 8 A It wasn't totally at our direction that 9 all these programs, that is, it was not to' tally 10 at the direction of the Training Department that 11 people were sent to all of these programs, and l 12 sometimes it was a coordinated effort between the 13 Operations Department and ourselves, i
14 Q But to the extent that items are l
15 listed on pages 2 and 3 for the operations staff
- 16 training program as being conducted at Three Mile l
17 Island, those were conducted by the Training 18 Department?
19 A I have to go down every --
20 MR. MacDONALD: If you are going to ask I
l 21 him to answer that in a general way, he has 22 to go down every one because there may be 23 some on there that were conducted on the i
24 island by people who were in the Training 25 Department, because that is why I don't know l
l
1 Zechman 97 r)\
(_ 2 if you want him to answer it generally.
3 Q To the extent there were training 4 programs for the operations staff at Three Mile ggg 5 Island conducted by Met Ed, were those all conducted 6 by the Training Department?
7 A They were not all conducted by the 8 Training Department.
9 Q so do I understand you to tell us then 10 that some part of the training for the operations 11 staff that was done by Met Ed at Three Mile Island 12 was done by personnel outside the Training Department?
{ ( 13 A Let me give you an example and see if 14 this example fits the scheme. For example, item 15 4 on page 2, General Electric turbine course 16 conducted at TMI by G.E. personnel. That was a 17 program that I don't recall if we initiated them 18 coming there or whether it was operations, but if 19 it were a program that operations staff were trained 20 in, it was done by personnel outside the Training 21 Department.
O 22 Q By General Electric?
23 A Yes.
-w 24 Q I was trying to exclude that kind of
(.
25 situation from my question. To the extent that the
1 Zechman 98
! )
's / 2 particular program that was administered was a 3 Met Ed program as opposed to bringing in someone 4 from the outside to conduct a program at Met Ed, lll 5 were those one hundred percent Met Ed programs for 6 the operations staff all conducted by the Training 7 Department?
8 A Not necessarily true. I consider for 9 example when B&W would bring their training programs 10 to our island, it was their program that they were 11 presenting.
12 Q I am excluding that type of thing from r
(_,\1 13 the question. The type of question is simply 14 confining it now to the programs that were conducted 15 at Met Ed solely by Met Ed people without any l 16 involvement from anybody from the outside, were 17 those for the operations staff all conducted by 18 the Training Department?
l j 19 MR. MacDONALD: We are dealing now with 20 the time period up to '73?
21 MR. FISKE: Yes, for the moment. I am 22 just talking of the ones that are in this 23 exhibit, 556.
(~} 24 A I would have to put into context the
'u
)
25 period of '69 to '73 the term Training Department.
l
1 zechman 99
(.
(_) 2 During that period of time '69 to '73, we relied 3 on a lot of the training was conducted by foremen 4 who had gone through previous training that were lll 5 Part of the Operations Department in that time 6 frame. We relied on some engineers and we also had.
7 some college professor I know of there in that time 8 frame.
9 Q Let's go back then, now that we at 10 least identified the scope of the question, to the 11 period of time when you were in charge of the 12 Training Department.
(v) 13 A '77 through the time of the accident?
14 Q Yes.
15 The question is: During that period 16 of time to the extent that training programs were 17 conducted at the island, solely by Met Ed personnel 18 for the operations staff, were those programs
'19 conducted by the Training Department?
20 A For the most part, those training 21 programs for operations personnel were conducted 22 by the Training Department, not to exclude guest 23 lecturers.
f- 24 Q Did the Training Department during
'q)S 25 this same period of time conduct programs for the
1 Zechman 100 tO
(_) 2 technical staff?
3 MR. MacDONALD: You are talking of 4 November '77 through the accident?
h 5 MR. FISKE: Yes, that is, the radiation 6 protection and chemistry personnel.
7 A To the best of my recollection, I don't 8 recall any formal programs that we conducted for 9 those people during that time. That is not to 10 say that they did not sit in on any of the lectures 11 at times.
- 12 During this same period of time while Q
13 you were in charge of the Training Department, did 14 the Training Department conduct programs for the 15 maintenance staff as that term is used in Exhibit 16 556 including instrument foremen, electrical 17 foremen, mechanical foremen, instrument technician, 18 mechanical and electrical personnel?
19 A For the most part, any training that 20 was given to those personnel would have been 21 performed by the line function or as they have done 9 22 in the past, send them offsite to specialized 23 schools as needed. That is not to say that they 24 haven't sat in on the lectures at one time or v
25 another.
. !l 1 - Zochman 101 2 Q Is it fair to say that you had no special 3 Il programs designed for them alone that did not also 4 ine'lude the operations staff?
lll 5 1
A 'd e ' r e talking of the period '777 6 Q Yes.
l 7 A Repeat the question.
2 (Question read by the reporter.)
9 A I --
10 Q Let me put it this way: You said with 11 respect to both the technical staff and the 12 maintenance staff that they would attend lectures 13 that were being given for the benefit of the
(
14 operations staff.
15 A I said it is conceivable they may have 16 attended one or two lectures, not that the training 17 program or those lectures were specifically for 18 them at their request.
19 Q That is what I am getting at. In other 20 words, they may have participated in programs that 21 were designed for the operations staff?
22 A on a limited basis. Normally whatever 23 training -- the majority of their training was 24 conducted from the line function itself or O 25 specialized training.
l
1 Zechman 102 Ds
(,,) 2 Q So the question is did you during this 3 period of time have any programs in the Training 4 Department that wer'e specifically designed for s
either the technical staff or the maintenance staff?
ll) 5 6 A Not to the best of my recollection.
4 7 Q Finally on this exhibit, we come to the 8 engineering staff which is defined as including 9 both mechanical and electrical engineers.
10 Did the Training Department when you 11 were in charge of it conduct programs for the 12 engineering staff?
i r) 13 A There were engineers who went for
_j 14 licensing programs, certain engineers who went for 15 licensing programs and therefore had gone through 16 some of our operator SRO training program, and if l 17 my memory serves me well, it was during that 18 period. I know the Engineering Department had a 19 training program of their own going at that time 20 somewhere in that time frame.
l Is it correct that again the Training 21 Q 22 Department while you were in charge'of it did not 1
23 have any programs that were specifically designed' i
l ,- 24 for the engineering staff?
i ,y) 25 A Not other than the engineers who attandea' k
s N
1 Zechman 103 I
i 2 the operator train'ing program. That is the best of n,
3 my recollection. '
\ f 4 MR. FISKE: Would you mark the next llh' 5 exhibit which is B&W 557.
6 (summary document written by Frank 7 McCormack marked B&W Exhibit 557 for 8 identification, as of this date.)
1
.9 Q Do you have that document in front of 10 you?
t 11 A Exhibit 557, yes.
!j 12 Would you like to take a minute to look Q
I~ 13 at it?
%h) 14 A Yes, please.
i
[ 15 Q Have you had a chance to look at it?
16 A I had a chance to scan it.
1 '
17 Q Have you ever seen that document before?
18 A Yes, I have.
19, Q Can you tell us what it is?
20 A To the best of my recollection, that is 21 a summary documer.t 'that Mr. Frank McCormack wrote 22 prior to the Kemeny Commission investigation, and 2S _ it was put together as a summary for them, if I 24 } recall.
25 Q Did you see this summary before it was
l 1 Zechman 104 2 submitted to the President's Commission?
3 A I saw it only on a cursory -- I scanned 4 it. I did not check it. If you are asking if I lll 5 checked it for specific accuracy, since it has a 6 date and times and numbers, I did not.
7 Q At the time it went into the President's 8 Commission, was there anything in it that you
. 9 recognized at that time as being inaccurate?
10 A Realizing that I only gave it a cursory 11 review, in that short brief time that I had to do 12 that, I did not see anything during that period.
) 13 That is not to say there are not inaccuracies in it.
14 Q Did you make as extensive a review of 15 this document before it went to the President's 16 Commission as you thought you needed to make?
17 A I don't think I even thought about that 18 at that time. During that period of time, things 19 were very hectic. A lot of things were happening.
20 There was very little time to do much of anything 21 except get materials ready for people who were 22 requesting it, and I don't think that entered my 23 mind at the time.
24 Q In other words, you had sufficient 25 confidence in Mr. McCormack that you did not feel
I l Zechman 105
[)
V 2 you had to give this any more than a cursory review 3 that you gave?
4 A I had a great deal of confidence in gg) 5 Mr. McCormack and felt comfortable with it.
6 Q I believe you said earlier that a 7 document summarizing the training program was 8 prepared by Mr. McCormack and given both to the 9 Kemeny Commission and also to the group from Penn 10 state that was conducting the after the accident 11 review. Do you remember that?
12 A Yes, I remember that.
13 Q Is this the document you wpre referring 14 to?
15 A To the best of my recollection, this is 16 one of the documents we turned over to them.
17 Q To the Penn State people?
18 A Yes.
19 Q Let me show you a document that has been 20 previously marked as Exhibit 260 which is an 21 excerpt from the FSAR which Met Ed filed with the 9 22 Nuclear Regulatory Commission. The portion that I 23 am showing you which is marked B&W Exhibit 260 is 24 captioned " Training Program."
25 Do you have that in front of you?
1 Zochran 106 l
/~h; '
( 2 A Yes.
N/ )
3 Q I take it that you have seen this document )
4 before you came here today?
lll 5 A Assuming this is from the FSAR for !
6 Unit 2, I recall seeing this document some time ago, 7 yes.
8 Q It is correct that by law Metropolitan 9 Edison was required to state in the FSAR what their 10 training program for Unit 2 would consist of?
11 MR. MacDONALD: I object. I don't know 12 what necessarily Mr. Zechman's familiarity
/) 13 with it is by law.
' u s' 14 A Since I did not write this particular 15 section, I can't answer that question.
16 Q Did you understand that in this document, 17 the FSAR, Met Ed was describing to the Nuclear 18 Regulatory Commission in some detail the type of 19 training program that Met Ed would conduct?
l 20 A Yes.
l 21 Q Did you understand Met Ed was making 22 that description ~ to the NRC in order to be able to j
23 obtain an operating license for TMI Unit 27 l
24 A I had that understanding.
l 25 Q Did you understand Met Ed had to comply
\ -
l l
l
1 zechman 107
- 1 (3
) 2 with the description of the training program in 3 this FSAR in order to get that license?
4 A I understood this reflected the training lll 5 that we accomplished for the operations people as 6 stated.
7 Q And this was intended to state both 8 the training that had been given to the Unit 2 9 people up to that point in time and the training 10 that would continue to be given to them in the future; 11 isn't that correct?
12 A I understood up to that time, this would
[)
w/
13 be the training that would be given. I also 14 understand that does not negate our ability to 15 modify our programs accordingly.
16 Q When you became Acting Supervisor of 17 the Training Department, did you review the FSAR 18 that was on file with the NRC to be sure that the 19 Met Ed training program was complying with the 20 description that had been given to the NRC?
21 A I don't recall that I specifically sat 22 down with the FSAR and measured our training programs 23 against everything that was in there because at the 24 time I took over the Training Department, pretty V
25 much of the training programs were in auto, and I
1 ZochMEn 108 (m) 2 there was not much difference from what we were 3 doing in the past.
4 Q Were any amendments filed to the FSAR describing the training program during the period lll 5 6 of time you were in charge of the Training Department?
7 A I have no recollection at this time one 8 way or the other.
9 Q Why don't you turn to page 13.2-6 and 10 13.2-6A and the pages that follow that which 11 describe the Metropolitan Edison operator 12 requalification program. I am referring to pages 13.2-6 through 13.2-10.
f~)
w-13 14 Dc you see those pages?
15 A Yes.
16 Q Am I correct that those pages all 17 purport to describe the Metropolitan Edison operator 18 requalificatien program?
19 A 13.2-6 through 13.2-10 --
20 Q Let's make it 13.2-14.
21 MR. MacDONALD: You are talking about O 22 the point in time this FSAR was filed?
23 , Q In other words, do pages 13.2-6 through
- 24 13.2-14 of the document that is in front of you (s) xs 25 refer to the Metropolitan Edison operator requalification
1 Zechman 109
[ ); 2 program?
v 3 A Yes.
4 Q And you see down in the bottom of each 5 page it says AM or AN 64 -- AM 64 and then in 9
6 parenthesis a date 4-7/78?
7 A I see it.
8 Q Does that indicate that these pages 9 that we have just been referring to were prepared 10 and filed with the NRC in 1978?
11 A Yes, it does.
12 Q And that was a period of time during l 13 *which you were in charge of the Training Department?
> (~)N,
\.
14 A That's correct.
l 15 Q so let me ask you specifically with l 16 respect to this part of the FSAR, did you prepare 17 this? -
18 A To the best of my recollection, at 19 this time, I recall the program being modified l
20 and submitted. I honestly can't remember who l
21 did the final draft.
22 Q Did you at that time, whoever prepared i
23 the final draft, did you review it to be satisfactory 24 as the Actina Supervisor in charge of the Training
,O
\/ 25 Department that this revision accurately described l
l l
1 Zechman 110 2- the requalification program that your department 3 was running?
4 A I remember reviewing it at some period ll) '5 of time in this time frame prior to ' the submittal; 6~ I don't recall the end point. I don't recall I whether I saw the final product.
8 Were you satisfied at the time this Q
9 document was filed with the NRC that Metropolitan 10 Edison in fact was conducting the training that 11 this amendment to the FSAR describes?
12 A We normally without question follow i
(} 13 the training that we submit in the FSAR. My l 14 difficulty in answering your question today is I 15 don't recall reviewing the end product.
16 Let's go back to Exhibit 557 which is Q
17 captioned " Training and Certification of Metropolitan 18 Edison Company Three Mile Island Unit 2 Licensed 19 Personnel;" correct? That is the title, is it not?
l 20 A That is the title.
21 Q I direct your attention to page 3 to O 22 the caption 1-A, Auxiliary operator Training.
23 A Yes. I am looking at it.
24 That describes, does it not, the Q
O 25 auxiliary operator training given by the Training i--__ , . - . . . - - - - . _ . . . - . . - _
1 Zechman 111 2 Department to operations personnel?
3 A It describes what is typically included.
4 Q Does this document that we have just been talking about, Exhibit 557, refer to the time ll) 5 6 period when you were in charge of the Training 7 Department?
8 MR. MacDONALD: This entire document?
9 I have a problem with that only in the sense 10 that it seems to be a general question designed 11 to get Mr. Zechman to answer without going 12 through the document and looking and seeing 13 whether his recollection is such that it 14 conforms to that question and the assumptions 15 in that.
16 MR. FISKE: Let's try to take it one step 17 at a time.
18 Q we're talking of page 3, auxiliary I
19 operator training.
20 Does this document describe the auxiliary 21 operator training that we.s conducted by Met Ed O 22 during the period of time that you were in charge 23 of the training?
24 A 'Just looking at it this moment, it shows 25 typical subject matter but is not all inclusive.
1 Zechman 112 g This first sentence of this document
( 2 3 says, "With but one exception, all of the initial 4 control room operator staff at TMI-2 were graduates ggg 5 of the U.S. Navy Nuclear Training Program with 6- several years of operating experience on naval nuclear 7 propulsion plants."
8 Do you see that?
9 A Yes.
10 Q It goes on to say "All were initially 11 employed as auxiliary operators -A - nuclear. In 12 this classification they participated in a training Ov 13 program which typically included the following."
14 And then there is a description of nine items.
15 A I see that. -
16 g Did you understand that the description 17 th a.t followed is intended to describe the training j 18 program that in fact was received by the initial 19 control room operator staff at TMI-27 l 20 MR. MacDONALD: Are you asking for his l
21 recollection at the time he reviewed the 9 22 document i not today?
23 MR. FISKE: Yes.
24 g Is this a description of the auxiliary r
25 operator training program which the initial control
1 Zochman 113 C.s,) 2 room operators received?
3 A This is a typical generic training 4 program but not all inclusive. It does not mean ggg 5 that every auxiliary operator would have received 6 everything that is here.
7 Q I understand that. This is the so-called 8 basic training program; right?
9 A This is a selected list of topics, of 10 some of the major topics that would have been 11 included. Not all inclusive.
12 Am I correct that these nine topics that Q
/~ 13 are listed on this page were taught *by the Met Ed N~])
14 Training Department?
15 MR. MacDONALD: Exclusively? At all 16 times?
17 MR. FISKE: That is the question.
i 18 A I have no recollection one way or the
- IQ other on that, it is all inclusive.
l 20 Q As part of this sort of basic auxiliary i
l 21 operator training program on these nine subjects l
22 that are listed here, was it part of that program l
[ 23 that on a regular basis people other than the Met Ed 24 instructors would do the training?
l
,l'h
\> 25 A Normally Met Ed instructors would do the l
l
1 Zechman 114 lD
(_) 2 training. That is not to say there are not guest 3 lecturers. This is initial control room operator 4 staff we're talking about. There are additional ggg 5 staff, additional personnel, auxiliary operators that 6 came in after initial staffing that had programs 7 that were of similar subject matter.
8 Q At the bottom it says, "This training 9 was conducted using the nuclear power preparatory 10 training program developed by NUS Corporation of 11 Rockville, Maryland."
12 Do you see that?
/m'
( i 13 A Yes.
b/
14 Q Is it fair to say at some point in 15 time while you were yourself an instructor in the 16 training program, you participated in teaching this 17 particular course?
l 18 MR. MacDONALD: By course, you are 19 referring to the NUS Corporation mentioned 20 at the bottom?
I
(
i 21 MR. FISKE: Yes.
l 22 A You are talking about for this initial 23 group?
i
- 24 Q All right, let's start with that.
\j 25 When was the initial group, when did they 1
s
1 Zechnen 115 (j 2 go through this particular training program?
3 A I have no recollection any longer of 4 the time frame of that program or who conducted 5 it at that time.
ggg 6 Q was it before you became Acting supervisor 7 of Training in November 1977?
8 A To the best of my recollection, that 9 would be true.
10 Q And from August 1973 to November 1977, 11 you held the position of Administrator-Nuclear 12 Technical Training or Group Supervisor-Technical
("')
%d 13 Training for non-licensed peoples correct?
14 MR. MacDONALD: I think you established 15 that.
16 MR. FISKE: It is a preliminary question.
17 A would you give me those dates again?
18 (Question read by the reporter.)
19 A During that period, I held either one 20 of those two positions.
l 21 Q In either one of those two positions,
- 22 did you ever pazticipate in this training program l
23 which is described in page 3 of Exhibit 557?
l l 24 A I just don't recall.
(_s) 25 Q Do you ever remember teaching a course 1
1 Zochann 116 2 or conducting a training program at Three Mile
['w)l 3 Island that utilized the nuclear power preparatory 4 training program developed by NUS Corporation?
5 A I recall that we utilized portions of ggg 6 it at different times. That is the best of my 7 recollection. I can't pinpoint how much of it we 8 used or periods of times.
9 Q When you say we used it --
10 A The training program.
11 Q --
are you including both situations 12 in which you personally used it as an instructor 13 and situations in which other people used it while
']
uj 14 you were in a supervisory capacity?
15 A I know other people have utilized portions 16 of it at one time or another. I h' ave difficulty 17 recalling if and when I did personally.
18 j (Recess taken.)
19 BY MR. FISKE:
20 Q I think before the recess, we were 21 talking about this nuclear power preparatory training 22 program developed by NUS Corporation of Rockville, 23 Maryland.
24 A Yes.
' '/ )
25 Q Is it correct that that was prepared
1 Zochnen 117
(~N
\ !
2 by NUS for Met Ed?
x/
3 A I don't know that it was apecifically 4 prepared just for Met Ed. It was a generic program.
ggg 5 To the bes t of my recollection, it was a generic 6 PWR program. There were portions of it that were 7 specific.
8 Q Let me show you a document that we'll 9 mark as the next exhibit which is B&W 558 which is 10 a black looseleaf notebook containing a number of 11 pages, the first page of which is captioned " Nuclear 12 Power Preparatory Training Core Performance, a s 13 Course for Metropolitan Edison via Video Tape by
(/)
w I4 NUS Corporation."
15 A It was a course prepared for Met Ed but 16 it was a generic course that they sold to other 17 utilities as well.
18 Q Was it your understanding that l 19 Metropolitan Edison had purchased these materials l
20 from NUS Corporation?
21 A Yes.
9 22 (Black looseleaf notebook containing a 23 number of pages marked B&W Exhibit 558 for 24 identification, as of this date.)
{~~)).
(_ 25 Q And that there was written material on l
1 zechman 118
(~}
%J 2 a variety of subjects as well as video tape?
3 A That's correct.
4 Q Did you have any participation in the 5 decision to purchase this program?
g 6 A Yes, I did.
7 Q When was that decision made?
8 A To specifically pinpoint it to a time 9 frame, I no longer remember the timing when we 10 purchased those. It was --
the best estimate would 11 be in the late '60s, '73 period, somewhere in there.
12 That is not true either. It may have been earlier
,13 than that. No, that's right. I stand by what I 14 said.
15 Q Do you know what Met Ed paid for those 16 materials?
17 A I don't recall what it was.
18 Q Was it in the thousands of dollars?
l 19 A It was in the thousands of dollars.
20 Q I take it you made a sufficient review 21 of the course material before the-decision was e 22 made to buy it to satisfy yourself that this was 23 a worthwhile investment of Met Ed's money?
l 24 A That is certainly not true.
25 Q You did not?
1 Zschman 119
(,,) 2 A I did not review the entire material 3 prior to purchasing it.
4 Did you make enough of a review of it to Q
5 satisfy yourself that this was a good thing for gg 6 Met Ed to do?
A The review that was made was the O
demonstration that was given to Mr. Don Hettrik 9 and myself. NUS had come to the island one day 10 and given us a demonstration. They showed us a few 11 excerpts of the tapes and showed us a few volumes I2 of the material. We scanned them that day at that 13
(")
(_.-
time. Don Hettrik was there with the idea if we 14 were to purchase them, they wanted to purchase the 15 PWR ones for TMI and the BWR ones for Oyster Creek.
16 It was based on that cursory review of the materials 17 at that time that the purchases were made.
IO Q I take it to your knowledge nobody at 10 Met Ed made any more thorough review of these 20 materials than you did and Mr. Hettrik did before 21 this decision was made?
O 22 A I can't recollect either way.
23 Q Is it correct that this course material 24 1 /
from NUS came in a series of separate chapters?
('- 25 A volumes, chapters.
l l
1 Zschann 120 And the one we have just shown you as
(~]
%s 2 Q 3 Exhibit 558 for example is captioned " Core Performance" 4 with the number 4 under it; is that correct?
5 A Yes.
6 Q These materials were used, I take it, 7 during the period of time that you were in charge 8 of the Training Department, the NUS material?
9 MR. MacDONALD: You are talking now the 10 end of '77 to the time of the accident?
11 MR. FISKE: Yes.
12 A I don't recall what, if any, of these 13 materials were used during that period. It was (V-)
14 somewhere in that period that these were phased 15 and a new series called NET, Nuclear Energy Training, 16 was purchased from NUS.
17 Q During the period of time that those 18 materials, that is, the NUS materials, were in the 19 possession, let's put it that way, were in use 20 by the Met Ed Training Department, was there a 21 procedure whereby the instructors that were teaching 22 the course knew which portions of that they were 23 supposed to use in the program?
24 A over the years that we had them, whenever f'/
\-
T 25 they were used and the frequency they were used, it
1 Zachman 121 O(_j 2 was at different points of time in history, they 3 were used in all kinds of modes. We may have just 4 shown one or a portion of a tape. It is hard to 5 put in that kind of a box.
ggg 6 Q Going back to the page 3 of this 7 Exhibit 557 which refers to the training program 8 that was given to the initial group of control 9 room operators and the nine topics that are identified 10 on page 3, it says "This training was conducted 11 using the Nuclear Power Preparatory Training Program 12 developed by NUS Corporation of Rockville, Maryland."
(~ 13 Do you see that?
V)-
14 A Yes.
15 Q Do you see any reference on page 3 ,
16 to sny other type of materials that were used 17 during the training prog' ram on the subjects that 18 are listed on page 3?
19 A I have no recollection of the specifics 20 any longer of the training program and what was and 21 was not used and how much of this material, if any, 9 22 was used at this time. I have no recollection 23 of that at this moment.
24 Q Let's take this training program that 25 is described on page 3 of Exhibit 557 on these nine
1 Zechman 122 t'%
.: ) 2 subjects.
%.J 3 Were there classroom lectures on each 4 of those nine subjects?
5 A I have no recollection of that period g
6 of time any longer in my memory bank that tells me 7 anything of the specifics.
8 Q Let's take the period in time --
9 A This is one man's writeup. I haven't 10 verified the dates or the times or the number of 11 hours1.273148e-4 days <br />0.00306 hours <br />1.818783e-5 weeks <br />4.1855e-6 months <br /> or what specifically was used.
12 Q Let's take the period of time when you 13 were in charge of the Training Department.
("]
\_/
14 were there classroom lectures on each 15 of these nine subjects, the nine listed on page 3?
16 A Realizing that they are generic topics, l
17 they are topics that are generally the kind of 18 topics we cover in our training program.
l 19 Q Do you know where Mr. McCormack got 20 the number of hours that are listed on page 3 after i
[
l l 21 each one of these topics?
22 A No, I have no recollection at this l
l l 23 point where he pulled those numbers off of.
24 Q Did you have a program when you were in
! /~T
\
l t
'i 25 charge of the Training Department whereby there would i
l l
1 Zechmnn 123 73 2 be specifically 160 hours0.00185 days <br />0.0444 hours <br />2.645503e-4 weeks <br />6.088e-5 months <br /> of training in mathematics
\_)
3 as part of this program, 80 hours9.259259e-4 days <br />0.0222 hours <br />1.322751e-4 weeks <br />3.044e-5 months <br /> of general 4 science, 240 hours0.00278 days <br />0.0667 hours <br />3.968254e-4 weeks <br />9.132e-5 months <br /> of atomic energy physics?
5 A It is highly unlikely in the time I 6 was in charge of the Training Department that we 7 would have had 160 hours0.00185 days <br />0.0444 hours <br />2.645503e-4 weeks <br />6.088e-5 months <br /> of mathematics. The 8 program he is defining here, the best I can 9 understand, referred to the initial training program, 10 what we referred to as the cold license training 11 program.
12 Q Was there a cold license training program 13 going on while you were in charge of the training bs) 14 program?
15 A A cold licensing training program has 16 to do with a plant that hasn't been operated yet.
17 There was no cold licensing program going on during 18 the time I was in charge.
19 Q This program that is listed on page 3 20 was,in effect,not in operation during the period 21 of time you were in charge of the Training Department; 22 is that correct?
23 MR. MacDONALD: Are you saying these 24 subjects weren't taught or the program I r~
(_)) 25 generically described as a cold licensing
1 zechman 124
(
-N/ 2 program?
3 MR. FISKE: This program described on 4 page 3.
llg 5 A I lost the context.
6 Q This portion of the so-called cold 7 licensing program was not being given at any time 8 while you were in charge of the training program?
. 9 A The topical areas are covered in our 10 training program for control room operators.
11 Q But not as part of the cold license 12 training?
(O
_) 13 A But not part of what is defined as cold 14 license training program.
15 Q Directing your attention to the exhibit 16 that you have in front of you which is 558, did 17 you ever use that part of the NUS program in any 18 instruction that you did?
19 A I have no recollection either way.
20 Q when you were an instructor in the 21 program, I'take it that the NUS set of materia ~1s 22 was available to you as an instructor; is that 23 correct?
24 MR. MacDONALD: What program are you J
25 talking about?
-.r_ + , , _ , _ . - - _ - - _ , , . - ,. .- _ _ _ _ _ _ -
1 Zochman 125 (O,) 2 MR. FISKE: The one that is described 1
3 as the nuclear power preparatory training 4 program developed by NUS Corporation of
$ 5 Rockville, Maryland in Exhibit 557.
6 MR. MacDONALD: When that material was 7 being used?
8 MR. FISKE: Yes, during the period of 9 time that Mr. Zechman was acting as an 10 Administrator-Nuclear Technical Training, 11 were the NUS materials available to you as an 12 instructor.
13 A Those materials from the time they were 14 purchased to the time they were phased out were 15 available to us to be used.
h 16 Q You yourself participated as an 17 instructor in conducting courses, did you not, during 18 this period of time?
19 A To the best of my recollection, my 20 participation as an instructor really centered, 21 focused, mainly in the area of reactor theory.
22 That is not to say that there weren't times that 23 I trained on some of the other subj ects , but in 24 those periods of time that was my area.
O 25 Q Again going back to this period of time, l
___ __-_-__-___________-____-_____-____-____-_J
1 Zechman 126 2 '73 to '76, with reference to the nine topics 3 that are on page 3 of Exhibit 557, are you saying 4 that there were different instructors who specialized lll 5 in these different topics?
6 A There were different instructors in 7 the Training Department at various times in the course 8 instruction for the various groups that went through 9 this training.
10 Q Did you at any time ever give any 11 instruction to anyone at Three Mile Island on the 12 subj ect of core performance?
() -
13 A could you further break that down into 14 subj ect matter?
a 15 Q Any aspect of core performance.
16 A I recollect giving a program one time 17 on material I received from B&W on core performance 18 and some areas of core performance.
19 Q Did you ever give any instruction on 20 reactor physics?
21 A I certainly did.
22 Q on plant chemistry?
23 A Not to the best of my recollection.
24 Q Atomic and nuclear physics?
s /
25 A Yes, I have.
I Zechman 127 n/
%_ 2 Q General science?
3 A Basic concepts many years ago.
4 Q In deciding what materials you were lll 5 going to use to give instruction on any of these 6 subjects that you just described, did you review 7 the NUS material to make a determination for 8 yourself as to whether you wanted to use any part 9 of that material in giving your instruction?
10 A If I used any of that material at 11 some point in time,'my recollection I just don't 12 recall any longer my utilization of that. If I
() 13 utilized it, it would be normal practice to have 14 reviewed it prior to use, particularly the video 15 tapes.
16 I understand if you used certain Q
17 portions of it, you reviewed those portions before 18 you used it. I am asking a broader question than 19 that.
20 Whether in order to determine whether 21 you would or would not use certain portions of it, 22 you read the NUS material to be able to make that 23 determination?
24 A Recalling the size of those volumes, I
{JS 25 suspect that you are asking about the text?
1 Zechman 128 f) 2 Q Yes, or the video tape.
3 A I don't ever recall taking a specific 4 volume and reading it entirely.
lll 5 Q But you did go through it sufficiently 6 to satisfy yourself as to whether you should use it 7 or not use it?
8 A It would be normal practice to review
. 9 the material that I was going to utilize prior to 10 its use. That being the normal mode.
11 Q Would it also be normal practice to 12 review it in order to determine whether or not you n,_,
s 13 wanted to utilize it?
14 MR. MacDONALD: Was it normal practice?
15 MR. FISKE: Yes.
16 A That would be normal practice. There
( 17 could have been circumstances where they may have l
18 shown a tape before reviewing it. I can't recollect 19 either way but I could concede that that would be 20 possible.
! 21 Q was the decision as to what portion of 22 the NUS material was used a decision that was 23 left up to the individual instructor, or did you 24 have someone tell you what portions of it you 25 should use?
- . . _ _ _ ~. .. _ . _ - . _ _ _ . - . _ _ _ - , _ . - . - . . , _ . _ _ __ __
1 Zechman 129
(~
't/ 2 A I think it is fair to say for the most 3 part it was a resource document and video tapes to 4 use at our discretion if we felt it was appropriate.
g 5 Q So by "we," you mean the individual 6 instructors?
7 A Yes.
O Q So one instructor could teach core '
9 performance using the NUS materials and another 1 1
10 instructor could teach core performance without, 11 using them, and that was all perfectly all r i g'h t.. { \
12 with the Training Department? '
\
() .\
13 A It depended on what ~ the purpose of, , s I
14 using those materials were. All of these materiala 15 that we get in that are resource materials also '
s
\
16 have to be related.to plant specifics, so they would 17 not entirely stand by themselves.
18 Q I understand that. But taking into 19 account what you just said, it is correct, is it not, 20 that there was no program at Met Ed which would say 21 for example that if you were giving a lecture on 22 core performance you either do have to use the 23 NUS material or you don't use it? That was left p, 24 up to each individual instructor?
k._)
25 A I don't ever recollect someone saying
1 Zochann 13?
4
[)
v 2 you had to une that material.
3 Q During the period of time that you were 4 serving as an instructor, was there an organized lll 5 program for the instructors by the Training 6 Department which specified for them 9 hat materials 7 they had to use in conducting the courses?
8 A I don't know that I can put it in that 9 context. Over the years a bank of resource material 10 and lesson plans were accummulated by the Training 11 Department and updated at specific times. The 12 resource materials that we got in we used in 13 dif f eren t ways , sometimes to support the training
(}
V 14 we had, and sometimes to bring out a concept.
15 Q My question very simply is was whatever 16 you did something that was part of a coherent 17 program that was given to you by the Training 18 Department, or was it something you decided for 19 yourself was the best thing to do on a lecture 20 by lecture basis?
21 MR. MacDONALD: I think he tried to 22 give you t'he answer to that qu es ti on .
23 A I don't know how else to answer other 24 than the way I just did.
(n
\>
i 25 Q Going back to the program that is listed
y,.
- r' 1 j Zechman 131 s
(D g) 2 on page 3 of Exhibit 557, did that consist of both 0 classroom lectures and self-study?
Er <
4 A I have no recollection, I believe I 6
llh . testified to that, of this point in time when this 6 was u s'ed to be~able to tell you that.
7 Q so you wouldn't be able to tell us s
8 for example of the 1120 hours0.013 days <br />0.311 hours <br />0.00185 weeks <br />4.2616e-4 months <br /> listed on page 3, 9 how much of that was in class and how much was 10 self-study?
11 A I have no recollection at this time.
12 Going on to page 4 of Exhibit 557, Q
() 13 you see the heading "1B Cold License Training"?
14 A yes.
15 Q Number one is Unit 2 CRO training 16 program and there are dour items listed under 17 that, math review, reactor theory, TMI-2 systems, 18 TMI-1 control room observation.
19 Do you see that?
20 A yes.
21 Q Did you participate yourself in any 22 p part'of that program?.
23 A I have no recollection at this time.
24 Q Item 4 on that same page, TMI-2 A
25 on-the-job training for CRO candidates, it says
1 Zechman 132
(_) 2 " guided self-study on TMI-2 systems," and their 3 respective sections of A, Burns & Roe systems 4 descriptions; B, TMI-2 FSAR; C, TMI-2 standard llh 5 technical specifications.
6 Do you see that?
7 A Yes.
8 Q Were you an instructor in the Training 9 Department during the period of time that that part 10 of the training was going on?
11 A I was in the Training Department at 12 the time that all the training except that which
,\
(J x
i 13 was conducted prior to '69. I was in the Training 14 Department.
15 Q And the TMI-2 staff cold RO license 16 training program referred to in paragraph 1B of 17 page 4 was conducted, was it not, sometime between 18 September 1969 and November 19767 19 A It is conceivable it was covered in 20 that time frame, yes.
21 MR. MacDONALD: Testify to your 22 recollection.
23 , THE WITNESS: Read the question.
<x 24 (Question read by the reporter.)
{ i q.)
25 A To the best of my recollection, that is
I 1 Zechman 133 l' ;
w ,/ 2 true.
3 Q Item 4B on page 4 refers to guided 4 self-study on TMI-2 systems and their respective llh 5 sections of TMI-2 FSAR.
6 Do you see that?
7 A Yes.
8 Q As a member of the Training Department 9 at Met Ed, did you yourself review the sections 10 of the TMI-2 FSAR having to do with the TMI-2 11 systems?
12 A I do recall having a Unit 2 FSAR and ex looking at systems' portions. I can't recall if (J)
~
13 14 I ever read them word by word, page by page.
15 Q Did you feel that if it was part of 16 the on-the-job training for CRO candidates to 17 engage in self-study on the sections of the TMI-2 l 18 FSAR dealing with TMI-2 systems that you as an 19 instructor should read those same sections?
20 A May I ask how you are tieing together 21 the FSAR and systems for their trafning?
22 Q I am reading from the description of 23 this program on the bottom of page 4 which says
(~3 24 that it was part of TMI-2 on-the-job training for l %-]
l 25 CRO candidates to engage in self-study on TMI-2 l
1 Zechman 134
(~N
(_) 2 systems and their respective sections of the TMI-2 3 FSAR, and having explained that, maybe I should 4 have the question read again, gg) 5 (Question read by the reporter.)
6 MR. MacDONALD: Are you asking if he 7 recalls that is the reason why he reviewed 8 those sections?
9 MR. FISKE: I am asking him the question 10 that Mr. Danyo just read.
11 (Question read by the reporter.)
12 A That is to imply, from your question,
() 13 that I taught systems. To the best of my 14 recollection, there are very few systems that I 15 personally taught.
16 MR. FISKE: Let me mark as Exhibit 559 17 a document which is a table of contents for 18 the FSAR for TMI-2.
19 (Table of c,ontents for FSAR for TMI-2 20 marked B&W Exhibit 559 for identification, 21 as of this date.)
9 22 Q What I would like to ask you now is 23 directing your attention to certain portions of
,y 24 the table of contents of the FSAR, whether you
'\~.
25 rend those portions of the FSAR for Unit 2 at any
1 Zechman 135 m
, '\
\j 2 time up through and including the period of time 3 that you were in charge of the Training Department 4 at Metropolitan Edison?
lh 5 MR. MacDONALD: If you are going to ask 6 him questions on this, let him look at the 7 whole thing before you ask him questions on it.
8 MR. FISKE: Sure. You may take as long
. 9 as you want.
10 Q I would like to now show you Exhibit 559 11 and ask you whether at any time while you were at 12 Met Ed up to and including the period of time when 7-~.
() ,
13 you were in charge of the training program at Met Ed 14 you read the section of the Met Ed FSAR captioned 15 " Engineered Safety Features"?
16 MR. MacDONALD: You want him to answer 17 the question just by showing him the caption 18 " Engineered Safety Features"?
19 MR. FISKE: Yos.
I l
20 MR. MacDONALD: I object. What is your i
i 21 recollection?
22 A I recollect being in that chapter at 23 one time or another. I don't recall any longer what l
,r^) 24 I read in there or how much of that I read.
'\_)
25 Q The question is now whether you made it
1 Zechman 136 2 a point when you were at any time in the Training 3 D*Partment including the period of time when you 4 were in charge of it to sit down with the Met Ed lll 5 FSAR and read the entire section entitled " Engineered 6 Safety Features"?
7 MR. MacDONALD: I object. I'think he 8 just told you the answer to that, what his 9 recollection of what he recollected being in 10 it and what he could recall.
11 You can ask the question again.
12 MR. FISKE: I am.
() 13 A The answer is I recall reading in the 14 FSAR at one time or another the section or chapter 15 " Engineered Safety Features." I no longer recall 16 what it is I read in there or the depth with which
! 17 I read it.
18 Q My question is: Did you make it a point l
. 19 at any time you were in the Training Department I
l 20 including when you were in charge of it, to say
! 21 to yourself I think it is important that I know 22 everything that is in the Met Ed FSAR having to i
23 do with engineered safety features, and so I am i
24 going to sit down and read it to be sure I know C.) 25 what is in there?
E 1 Zechman 137 O 2 MR. MacDONALD: I object to the form of 3 the question. I think he answered the question.
4 A I don't know how I can answer the question lh 5 any differently than I did just a while ago.
6 Q That is your answer?
7 MR. MacDONALD: He gave you his best 8 recollection three times now.
. 9 MR. FISKE: He said from time to time 10 he may have read portions of it. I am asking 11 him whether he ever made it a point to sit 12 down with the Met Ed FSAR and learn what
() 13 Met Ed had represented to the Nuclear 14 Regulatory Commission about the engineered 15 safety features of the TMI-2.
16 MR. MacDONALD: Your interpretation 17 of what he said is your interpretation. The 18 record is going to reflect his testimony.
j 19 He gave you his recollection twice, and if 20 you want to harass the witness and ask the 21 witness three or four times, I will let 22 you ask it once more, but I don't think it is 23 proper to badger the witness.
24 MR. FISKE: I am simply trying to get 25 an answer to the question.
1 Zechman 138
('h (m) 2 MR. MacDONALD: I think he gave you the 3 answer to the question four times.
4 Q What is the answer?
llh 5 A The same as I just said a while ago.
6 Q Did you make it a point to sit down 7 with the Met Ed FSAR and read the section of the 8 FSAR captioned " Reactor Coolant System," section 57 9 MR. MacDONALD: I object unless you 10 show him the whole section, but I won't 11 instruct him not to answer the question.
12 A The same answer that I referred to in h
(~j 13 the past to the question you asked me about would
(_
14 apply to that as well.
15 Q Suppose you give us what the answer is, 16 because it is a new question.
17 A The answer is that I have looked at 18 the FSAR several time periods including the chapter i
i 19 you just referred to. I no longer recall the -
l 20 specifics of what is in there or the detail with
(
21 which I read it.
22 Q Can you tell us now whether you 23 ever, right up to the time of the accident, read I
(~g 24 the portion of FSAR in the section on the reactor V
25 coolant system that refers to pressurizer?
1 zechman 139 2 MR. MacDONALD: I think he just told 3 you what his recollection was.
4 MR. FISKE: I am asking specifically h 5 if he read this section.
6 A I don't recall either way at this point 7 in time.
8 Can you tell us whether you read the Q
9 section that refers to safety and relief valves?
10 A I don't recall either way at this time.
11 Q Do you recall whether you read the section 12 dealing with reactor coolant pumps?
im fd I3 A I don't r,ecall either way at this time.
14 Q Do you recall whether you read the 15 section dealing with the decay heat removal system?
16 A I don't recall either way at this time.
17 Q can you tell us now referring l
18 specifically to the engineered safety features 19 whether at any time before the accident you read 20 the section of the FSAR dealing with the emergency 21 core cooling systems?
22 MR. MacDONALD: I object. You have 23 asked him time and time again. He said he 24 recollects reading through the sections and 25 he doesn't recollect specifically any more l
l
1 Zechman 140 pm
(_ 2 about it.
3 MR. FISKE: He can answer that question.
4 A My same answer as I answered in the lll 5 previous questions applies.
6 Q Just so I understand the terminology, 7 when this document, page 4 of the Exhibit 557, refers 8 to sections of TMI-2 FSAR referring to the TMI-2 9 systems, does the TMI-2 systems include the 10 engineered safety features?
11 MR. MacDONALD: Are you asking for his 12 recollection at the time he saw the document?
r~s 13 Do you have an understanding as to what (v) Q 14 TMI-2 systems are?
15 MR. MacDONALD: Aside from the document?
16 MR. FISKE: Yes.
17 Q Do you have an understanding of what the 18 TMI-2 systems are?
19 A I have an understanding of what TMI-2 20 systems are.
21 Q And the engineered safety features, are 22 they part of the TMI-2 system?
23 A Yes.
,- 24 Q And is the reactor coolant system part s
25 of the TMI-2 system?
1 Zschman 141
( 2 A The terminology reactor coolant system?
3 Q Yes.
4 A I understand that terminology.
lll 5 Q To be part of the TMI-2 system?
6 A Yes.
7 Q Is the reactor part of the TMI-2 system?
8 A Yes.
9 Q Just so there is no question about it, 10 is the pressurizer part of the TMI-2 system?
11 A Yes, it is.
12 Q So the program that is described at the
~
13 bottom of page 4 of the guided self-study on the 14 sections of the TMI-2 FSAR on the TMI-2 systems 15 would include the engineered safety features as 16 well as the reactor coolant system?
17 MR. MacDONALD: You are asking what his 18 recollection is at the time he read the 19 document, not to speculate today what it may 20 have meant?
21 MR. FISKE: Sure.
22 A I am unclear in your cuestion.
23 MR. FISKE: I will withdraw it. I 24 think the document speaks for itself.
<x U 25 MR. MacDONALD: Fine. I have heard
1 Zechman 142
( 1
\/ 2 that phrase before.
3 Q This morning we were asking you or 4 reading you some questions and answers from page llh 5 183 and 184 of the Kemeny Commission testimony.
6 Do you recall that?
7 MR. MacDONALD: You are just asking if 8 he recalls you reading'the questions and
. 9 answers?
10 MR. FISKE: Yes.
11 A I understand we discussed some of those 12 questions.
(-
(_) 13 Q Just to bring this back to your mind, 14 the last sentence in the last answer that I read 15 was your statement that, "The training was just 16 not effective."
17 Do you recall when I read those questions 18 and answers to you this morning?
19 A I remember that.
20 Q I read you a series of questions --
I am 21 just asking you, I read you this morning a series 22 of questions and answers, the last answer of which 23 ended with the sentence "The training was just not
(~} 24 effective" on page 184, V
25 A I understand that, but I must say I
1 Zochaan 143 O
( ,1 2 disagree with that statement.
3 MR. FISKE: I move to strike that 4 gratuitous statement.
lll I am simply asking you whether you read 5 Q 6 those questions and answers this morning, but I will 7 proceed.
8 You testified this morning that those 9 answers that you gave at the time were accurate but 10 that you recalled after the deposition that you had 11 made some corrections?
12 A That's correct.
/~ 13 Q Let me show you a document which we'll
\_))
- 14 mark as Exhibit 560 consisting of three pages and 15 ask you if you recognize that document as three 16 pages of corrections which you made to the Kemeny 17 Commission testimony on August 8, 1979.
18 (Three pages of corrections made to the 19 Kemeny Commission testimony on August 8, 1979 20 marked B&W Exhibit 560 inr identification, as 21 of this date.)
22 Q Do you recognize it?
23 A I 'ze it.
- 24 Q I. rect that before you made those I '"
25 corrections, you over your testimony in order
1 Zechman 144
/ 'N t n
(_) 2 to be able to determine whether or not you wanted 3 to make corrections; is that right?
4 A It is correct that I read over the lll 5 testimony. It was very painful to do that. I 6 did not want to go through it again. It is 7 conceivable in my mind I could have missed some.
8 Q Let me show you again the document and 9 ask you to read into the record from the left-hand 10 side of the three documents the page numbers upon 11 which you made corrections. Just start with the 12 first one and read the page numbers.
) 13 A 83, 104, 115, 134, 148, 174, 181, 193, 14 211, 233, 268. I can't read the next one. 269, 15 page 10, 19, 20, 25, 27, 28, 30, 32, 35, 36, 41, 43, 16 47, 57.
17 Q It is correct, is it not, that there is 18 no correction to any statement on page 183 or page 19 1847 20 A That is a correct statement.
21 Q Could you tell us over what period of 22 time the initial group of control room operators 23 training continued at Met Ed before they received gx 24 control room operator licenses on Unit 2?
)
'J 25 A I no longer have a recollection of those l
1 Zechman 145
( 8
'N_/ 2 time frames.
3 Q Is it a year, is it two years?
4 A It is difficult because the training lll 5 would never have stopped from the time it started 6 to the time they got a license. They would always 7 be in some kind of training review, and I don't 8 have a good hold of that time frame.
9 Q So you just can't answer that question 10 one way or the other?
11 A That's correct.
12 Q Would you look at Exhibit 557. I direct
( ~.
i s_j 13 your attention to the index on page 1.
14 Do you see that?
15 A Yes, I see that.
16 Q Listing different types of training 17 for people in five different job classifications; is 18 that correct?
19 A Yes.
20 Q What I would like you to do is go 21 through this document and tell us which of those 22 programs was conducted during the period of time 23 1977 through the time of the accident when you were 24 in charge of the Training Department? You.are
,-];
\_
25 obviously not confined to the index in answering
1 Zechman 146 7
e !
\m/ 2 that ques tion. Maybe it would be easier if I took 3 them one at a time and asked you.
4 A It would be easier if I told you it lll 5 has been too long -- it has been three years since 6 the accident. The last two years I haven't been 7 involved in the operator training. I have a very 8
difficult time putting time frames of training 9 programs because there are so many. All you are 10 going to get if you go through there is I don't 11 recall.
12 Q I would like to ask you these questions, q_,) 13 and bear in mind that I am confining them now to the 14 period when you were in charge of the department.
15 MR. MacDONALD: You are asking him 16 at the time he saw and conducted a review of 17 this document?
18 MR. FISKE: No, I am not necessarily 19 asking you to verify this as of the time you 20 saw this document cursorily before it went to 21 the President's Commission. I am asking you 22 to use this document as a reference point for 23 the questions that I am now about to ask which p 24 is:
U 25 Q Starting with page 3, that during the
1 Zechman 147
_) 2 period of time that you were in charge of the 3 Training Department, was a training program of the 4 type described on page 3 conducted?
lll 5 A When you say was a type program like 6 shown on page 3 conducted during my tenure --
7 MR. MacDONALD: I think he went through 8 this one. He said generically some of these
, 9 were covered.
10 A But not this particular program.
11 Turning to the next one which is at the Q
12 top of page 4, item 1B called cold license training
!, j 13 program with a des *crfytion that follows underneath, 14 was any part of that program --
15 A The term cold license refers to a 16 special type of licenae program prior to commercial 17 operations.
i 18 MR. MacDONALD: I want to make it 19 clear that you are not attempting to get the 20 witness to verify that this particular material l
21 was all inclusive of any cold license training 22 p . gram that was conducted on the island at l
23 any time?
fy 24 MR. FIS KE : No.
N 25 A The cold license training program, my
1 Zechman 148 (x/ !
2 recollection, Unit 2 went commercial in '78. I 3 don't recall what period of time they went for their 4 license. It is conceivable that some of the
$ 5 training -- the tail end of the cold license 6 training program, a review or something of this 7 sort could have been covered at that time.
O Q So that answer refers to the material
. 9 on pages 4, 5, 6 and 7; is that correct?
10 A It is conceivable that some portions of 11 that could have been covered at that time. I don't 12 recall.
[\/) 13 Q Now, the next one is 1C on page 8. The 14
" Hot License (Replacement Operator) Training."
15 Was that program conducted during the 16 period of time you were in charge of the Training 17 Department?
l 18 A To the best of my recollection, that 19 type of program was conducted during my period.
20 Q Item 1-E --
let me cover 1-D, which 21 says control room operator certification, page 12.
22 I take it that is simply a reference l
23 to the process by which a certificate is issued; 24 correct?
s-25 A l A license.
l l
1
1 Zschman 149
( ,) 2 Q That doesn't describe a training 3 program; right? Item 1-D on page 12 simply describes 4 the process by which a license is issued. It does lll 5 not describe the content of a training program?
6 A That's correct.
7 Q Item 1-E on page 13, reactor operator 8 requalification with reference to the FS%R chapter 13, sectic 9 13.2.2, Metropolitan Edison operator requalification 10 program, was that program conducted during the 11 period of time that you were in charge of the 12 Training Department?
(v~) 13 A Yes.
14 Q Going to 2-A on page 14, that describes 15 a program for previous TMI-1-SRO licensees.
16 Do you see that?
17 MR. MacDONALD: Page 157 18 MR. FISKE: Yes, pages 15 and 16 and 19 17.
20 Q was that program going on while you 21 were in charge of the Training Department?
22 MR. MacDONALD: The type of program?
23 MR. FISKE: Yes.
24 A You are referring to a cross license s
i s V 25 type program?
1 Zochnan 150
(_) 2 Q I guess I am referring to the program 3 that is described on pages 15, 16 and 17.
4 A This one has to be clarified because it still refers to cold license programs.
lll 5 Once 6 the plant was commercial, and license is obtained 7 for the first time, there is no longer a cold 8 license program.
9 Q So I guess then the answer would be 10 that kind of program was not going on during the 11 period of time after --
12 A Let me make sure. There are portions
[v ') 13 that are listed here that were conducted during 14 that time. It is hard to segregate everything 15 that is on here.
16 Q But some portion of this was given 17 during that time?
l 18 A Yes.
19 Q Item 2-B, page 18, SRO licensees from l
20 other reactor facilities, any part of that program l
l l 21 being given during the time you were in charge of l
22 the department?
l l 23 A Again, this refers to a cold license l
g- 24 program, and in the description of some of the i t% )
i u/
25 line items, some of the line items are still 1
l l
l
1 Zechman 151 2 conducted -- some of the line item training was 3 still conducted during my period.
4 Q Item 2-C, page 21, selectees from h 5 initial TMI-2 CRO staff. Was any part of that 6 program going on during the time you were in charge 7 of the department?
8 A This again refers to selected initial
. 9 staff. There are subject areas in here which we 10 still cover in training programs, but not in the 11 format that is dictated here, the exact format that 12 is here.
~
13 Again, some part of this was going on Q
14 in 19777 l
15 A There are some subject areas that are 16 covered.
i 17 I guess the last one is item 3, shift Q
18 supervisor training and certification, pages 23 to l
19 25. Was that program being conducted during the time 20 you were in charge of the department?
21 A The same thing would apply here. There l 22 are certain portions of this that would still have 23 been conducted during my period.
24 Then there are three references to Q
25 specific individuals in items l 4, 5 and 6. I am sorry.
I
1 Zcchran 152
( ) 2 4, 5-A and 5-D.
%./
3 can you look at those?
4 A You are referring to page 26 now?
lll 5 Q Page 26, 27 and 28.
6 were any part of those programs conducted 7 while you were in charge of the department?
8 A On page 26, item 4, there would be one 9 program that is still going on. It would have been 10 going on during my period.
11 Did you say item Roman 5, page 277 12 Q Yes.
(~x 13 A I need clarification. When you say b
14 programs, are you referring -- you are not tieing 15 together the programs in the classifications, are 16 you, or are you?
17 Q What is the difference?
18 A When I say for example I will look at 19 a line item that says 80R program at the simulator, 20 yes, there are 80R programs at the simulator that 21 were conducted during my period of time.
22 Q I meant in connection with the training 23 of that particular individual or group of individuals.
24 A Then I have to reanswer your question.
\
i,
'x / 25 Why don't we do this since it is late Q
1 Zechnan 153
(_) 2 in the day. It probably would save time all around.
3 If you want to look through that overnight 4 and just come in the morning and tell us what, if I 5 any, adjustments you want to make to your prior 6 testimony, that will be fine.
7 A Okay.
8 MR. FISKE: The last thing that I would
, 9 want to cover today is during the luncheon 10 recess, Mr. MacDonald, we received a box of 11 documents from your firm with a cover letter 12 that described the documents as newly rs
( j) 13 discovered documents from the Training files.
14 It is a fairly large box with a fairly 15 large number of documents. I was wondering 16 if you could tell us the circumstances under 17 which those documents were discovered?
18 MR. MacDONALD: I have not engaged in 19 the document production in the case. There 20 are people who have worked on the document 21 production. I don't know the specifics of 22 what may or may not be in that box or when 23 it was culled together or what the fruits of 24 it are. I was told there were documents that
(~3 V
25 were gathered together at some point of time
i 1 Zechman 154 g
() 2 recently. There were additional training 3 material that was uncovered, and I said as 4 soon as that material was turned over, it lll 5 should --
6 MR. FISKE: Do you know whether that 7 material comes from Mr. Zechman's files 8 personally as opposed to the Training 9 Department files?
10 MR. MacDONALD: I don't know how that 11 breaks out.
12 MR. FISKE: Would you be in a position f)
LJ 13 after an appropriate consultation with a 14 knowledgeable individual to 1,et us know the 15 answer to that?
16 MR. MacDONALD: I will try to find out 17 if we have delineated it that way, which 18 ones, if any, are specifically Mr. Zechman's 19 and which ones are generally Training 20 Department files.
21 MR. FISKE: I assume you have that 22 information, and if so, we would like to have it.
23 MR. MacDONALD: I would hope so.
I 24 (Time noted: 4:30 o' clock P.M.)
7-
!' )
~'
25 RICHARD W. ZECHMAN Subscribed and sworn to before me thic aav nr sono
1 155 2
g/~'s _C _E _R _T _I _F _I _C _A _T _E 3 STATE OF NEW YORK )
- ss.'
4 COUNTY OF NEW YORK )
5
@ I, JOSEPH R. DANYO , a 7
Notary Public within and for the State of New York, 8
do hereby certify that the foregoing deposition 9 of RICHARD W. ZECHMAN Was taken before 10 me o Wednesday, March 10, 1982 ;
11 That the said witness was duly sworn 12 before the commencement of his testimony and 13
()' that the within transcript is a true record of said x.s 14 testimony; 15 That I am not connected by blood or 16 marriage with any of the parties herein nor 17 interested directly or indirectly in the matter in 18 controversy, nor am I in the employ of any of the 19 counsel.
20 IN WITNESS WHEREOF, I have hereunto set 21 my hand this M day of AA CN ,, 1982 22 23 , s ,
24
@f5 -
a' ! .n
[ JOSEPH R. DANYO
\._) '
25
March 10, 1982 156
( I N DEX g
WITNESS PAGE Richard W. Zechman 3 EXH I B I TS B&W EXHIBITS FOR IDENT.
554 Resume of Mr. Zechman 7 555 Document 16 556 Document dated August 1, 1973 90 557 Summary document written by 103 Frank McCormack 558 Black looseleaf notebook 117 containing a number of pages 559 Table of contents for FSAR 134 for TMI-2 j 560 Three pages of corrections 143 made to the Kemeny Commission testimony on August 8, 1979 t
l l t *
- 1 l '8 l ('d 1
l l
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