ML20072H872
| ML20072H872 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 03/12/1982 |
| From: | Zechman R GENERAL PUBLIC UTILITIES CORP. |
| To: | |
| References | |
| TASK-*, TASK-01, TASK-03, TASK-04, TASK-1, TASK-3, TASK-4, TASK-GB NUDOCS 8306290788 | |
| Download: ML20072H872 (103) | |
Text
. - - _ _ _ _
273
.b t h
UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK
_ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _x GENERAL PUBLIC UTILITIES CORPORATION, s
("
JERSEY CENTRAL POWER & LIGHT COMPANY, METROPOLITAN EDISON COMPANY and PENNSYLVANIA ELECTRIC COMPANY, Plaintiffs,
-against-80 Civ. 1683 (RO)
THE BABCOCK & WILCOX COMPANY and J.
RAY McDERMOTT & CO.,
INC.,
a Defendants.
_ _ _ _ _ _ _ _ _ _ _x Continued deposit; ion of General Public b
Utilities Corporation by RICHARD W.
- ZECHMAN, taken by Defendants, pursuant to adjournment, at the offices of Davis Polk & Wardwell, Esqs.,
,One Chase Manhattan Plaza, New York, New York, on Friday, March 12, 1982, at 10:00 o' clock in the forenoon, before Robert Capuzelo, a
Shorthand Reporter and Notary Public within and for the State of New York.
l l
(
f%
DOYLE REPORTING. INC.
(,)
8306290788 B20312 O
CERTIFIED STENOTYPE REPORTERS 369 Lgx1NGToM AVENUE WALTER SHAPIRO. C.S.R.
Nrw Yong. N.Y.
10o17 CHARLES SHAPIRO, C.S.R.
TELEPNoNE 212 - 867-8220
1 274 2
Appea ran ce s:
3 4
KAYE, SCHOLER, FIERMAN, HAYS & HANDLER, ESQS.
Attorneys for Plaintiffs 5
425 Park Avenue G
By:
ANDREW MacDONALD, ESQ.,
7
-and-JULIET NEISSER, ESQ.,
8 of Counsel 9
10 11 DAVIS POLK & WARDWELL, ESQS.
Attorneys for Defendants 12 One Chase Manhattan Plaza New York, New York 13 By:
ROBERT B.
FISKE, ESQ,
14
-and-KAREN E.
WAGNER, ESQ.,
15 of counsel l
16 l
17 18 Also Present:
19 SUSAN HANSON, Paralegal Davis Polk & Wardwell, Esqs.
20 21 9
22 M
24 O
25 l
/
P
1 275 2
RICHARD C.
- ZECHMAN, resumed, 3
having been previously duly sworn by the 4
Notary Public, was examined and testified ggg 5
further as follows:
6 EXAMINATION (Continued) 7 BY MR. FISKE:
8 Q
Mr.
Zechman, you realize you are still 9
under oath, do you not?
10 A
Yes, sir.
l 11 Q
We Dft off yesterday afternoon around 12 3:30.
There was a pending question with respect to
()
13 Exhibit 568.
14 MR. MacDONALD:
I believe he answered that 15 question.
i 16 Q
I will put the question again.
17 Directing yo'ur attention to page 2 18 of Exhibit
~568, looking at the left-hand side 19 of the page there is a number 6 and then it says, 20 "PSU, Comment
'b," page 6."
(
21 Do you see that?
O 22 A
I sea,that.
23 Q
Next to that is a comment, is that 24 correct?
There is a comment that has to be put in 25 A
1
1 Zechman 276 t
2 context.
s 3
Q Is it correct, Mr. Zechman, that this 4
document states under " Comment," " Agree that heat 5
transfer and fluid flow be added to CRO/SRO training ggg 6
curriculum"?
7 MR. MacDONALD:
The document says what 8
it says.
If you want to ask him as to what 9
his recollection is or what he. wrote there, 10 that is fine.
That is the way you proceeded so 11 far, and I expect that is the way you are going 12 to proceed.
(
13 MR. FISKE:
That is the only comment 14 reflected on the exhibit for that particular 15 item.
(
16 Q
Mr. Zechman, when we broke at 3:30 yesterday, 17 did you take with you Exhibits'567 and 5687 567 is 10 the memorandum from Mr. Lawyer to Mr. Thorpe with 19 the attached draft of the Penn State report.
20 MR. MacDONALD:
We picked up all the 21 copies of the exhibits when we left yesterday, 22 Mr. Fiske.
Not the original copies.
23 MR. FISKE:
Maybe Mr. Zechman can answer i
24 the question.
25 g
When we recessed at approximately 3:30 l
l
1 zachman 277 b) 2 yesterday, did you stay here in this building at v
3 Davis Polk for a period of time before you lef t?
4 A
Yes, I did.
5 Q
What time did you leave Davis Polk?
6 A
I don't recall the exact time.
7 Q
Was it at least a half an hour later, 8
some time after 4:00 o' clock?
9 MR. MacDONALD:
You mean by the time we 10 got a cab out of here?
11 Q
From the time you walked out of the 43rd 12 floor of this building, which is the floor on 13 which the deposition is being taken.
14 A
It could have been 15, 20 minutes.
I 15 didn't keep track of the exact time.
16 Q
The record reflects Mr. MacDonald came l
17 into the deposition room at five minutes to four and 18 said there would be no further testimony yesterday.
19 So I take it, did you leave with 20 Mr. MacDonald when you left?
21 A
Yes, I left with Mr. MacDonald when I i
l 22 left.
23 Q
During the period of time between 3 :30 24 and five minutes of four yesterday, did you review O
25 your comments as they are reflected --
1 Zschman 278 j
2 MR. MacDO!!ALD:
I instruct him not to 3
answer.
4
.Since I was sitting next to him, 5
Mr. Fiske, whatever he looked at was looked gg 6
at in the context of -- let me state my 7
objection so that you know it.
8 MR. FISKE:
I wanted to finish the 9
question.
10 MR. MacDONALD:
I'm sorry.
I thought you 11 had.
12 Q
Did you review Exhibit 568 in comparison
(}
13 with Exhibit 4677 14 MR. Mac DONALD:
I will inctruct him 15 not to answer on the basis of privilege.
16 The basis is whatever review he did, 17 it was done in the context of being in my 18 presence and at my direction.
19 MR. FISKE:
Then we will proceed, 20 perhaps, a little more slowly and carefully.
21 could you give Mr. Zechman a copy of 9
22 Exhibit 567.
23 Q
Mr. Zechman, what I would like to do is 24 to take Exhibit 567 which consists of the memorandum i
25 by Mr. Lawyer and then the attached document, the
~
1 zochman 279
(
2 attached draft of the Penn State report, and go 3
through the Penn State draft report in comparison 4
with the comments that appear on your Exhibit 568.
5 Let me start with -- I am just looking at 6
the left-hand side of the page.
Let's start with 7
Exhibit 568.
8 Do you see item 1, paragraph 4, line 3?
9 We are on page 3.
10 Let's start again.
The first page 11 reflected in your comment sheet is page 3, is that 12 correct?
The top of page 1 of your comment sheet.
~
13 In other words -- I will withdraw that.
14 The first comment reflected on Exhibit 15 568 is a comment with respect to an item on page 3,
16 is that correct?
17 A
That is correct.
18 g
And that is item 1, which says, 19
" Paragraph 4, line 3, little emphasis given to 20 provlem solving."
21 Do you see that?
22 A
Yes.
That was taken out of the context 23 of the draft report.
o 24 Q
Looking at Exhibit 567, page 3, do you
! ()
25 see the fourth paragraph that begins with the words l
l
1 Zachman 280 2
"Penn State"?
3 A
Yes, I do.
4 Q
Do you see beginning in line 3 of that 5
paragraph the words "Little emphasis is given to gg 6
problem solving"?
7 A
You are talking about paragraph A, the 8
second sentence?
9 Q
Yes.
The end of line 3 of that 10 paragraph, it says, "Little emphasis is given to 11 problem solving," correct?
12 A
It says, "That is little emphasis is f ()
13 given to problem solving."
That was their opinion 14 and not necessarily mine.
l 15 MR. FIS KE :
I move to strike the 16 gratuitous remark.
I 17 MR. MacDONALD:
Move to strike whatever s
18 you want.
19 Q
I want to make it clear so you understand 20 the questions as I am asking them.
I am not asking 21 for any of your comments at this point on either the O
22 draft report or your comment sheet.
You made the 23 statement yesterday that you thought that the 568 was not directed at the 24 comment sheet was not 25 document which is 567.
,ys L
4
-.m, m-J
__4 1
2:a+-
1 Zechman 281 2
MR. MacDONALD:
I don't think that is i
3 exactly what he said.
i 4
What he said is on the record.
5 MR. FIS KE :
I just want to go through it g
6 to make a comparison simply between the comments 7
on 568 and what is in 567, and th'at is the 1
8 only purpose of my questions.
9 I'am not at this point in the deposition 10 asking for any comments'on the s ub stanc e of i
11 any of this.
12 Q
Do you understand what I am asking?
()
13 Do you understand that is what I am going to ask you?
14 Is there any question about that in your 15 mind, any confusion on the scope of the questions 16 that I am about to ask?
17 A
Are you saying as I make -- as you make 18 this comparison, I'm not going to h av e an opportunity 19 to explain the rationale behind my comments?
l 20 Q
what I am saying is that there is a 21 procedure for conducting examinations in court and O
22 in depositions under which the witnesses are required 23 to answer the questions as they are asked.
24 If your lawyer wants to bring out 25 anything that you feel or he feels should be h
1 Zochman 282 2
brought out that I have not brought out, there is 3
an ample procedure for that at the conclusion of 4
the deposition, but you are -- so, believe me, 5
Mr. Zachman, so there is no confusion about this, ggg 6
I am not trying to foreclose you from ever making 7
any comments on the substance of the Penn State 8
report.
You will have ample opportunity to do that 9
if you wish.
10 All I am trying to do at tais stage of 11 the deposition is to go through a comparison between 12 567 and 568, and I am not at this point in the
()
13 deposition asking you for those comments.
I think 14 Mr. MacDonald will agree that I am entitled to 15 organize this deposition in any way that I want 16 long as my questions are clear and fair.
as 17 MR. MacDONALD:
I have no problems with 18 you organizing your deposition in any way you 19 want.
I think to. compare one document to 20 another -- the words are written -- to take it 21 and say, "As you sit here today, is that what O
22 is written on the page," doesn't really advance 23 this case anywhere.
You can do that as well as 24 I can, or anybody else sitting in the room.
25 To have Mr. Zachman go through that
1 Zochman 283 f~
2 for ten minutes, 15 minutes, a half hour, I 3
don't think advances things.
4 I just object to that line.
5 You may go ahead and do it.
ggg 6
MR. FISKE:
Lawyers can disagree with 7
what advances a case or what doesn't.
I am 8
taking the risk to do it the way I want to do 9
it.
If you think that doesn't advance the 10 case, you can hold that opinion.
11 Q
So that we can move quickly and not 12 engage in a lot of colloquy and discussions that is
' ()
13 simply going to slow things down, I would like to 14 proceed in the way that I described, recognizing, 15 as I said before, I am not in any way attempting 16 to foreclose you from making comments at the l
17 appropriate time which will come during this deposition 18 about the content of the reports and your comments 19 on the substance; O.K.?
20 A
I understand.
l l
21 Q
Let's look at the second comment that 22 you have on page 3 of Exhibit 568 and that is 23 directed to paragraph 4, line 4.
24 Do you see the words in your comment, "No 25 attempt to develop math skills beyond high school t
. -. - _,, ~ _ _
l 1
Zechman 284 O
2 1.y.1=7 3
A I do.
4 Q
Do you see on page 3 of Exhibit 567, 5
paragraph "b,"
"No attempt is made to develop the ggg 6
mathematical skills of a candidate beyond those 7
normally expected of a technically oriented high 0
school student"?
9 A
I see that.
10 Q
The next comment appears on page 5 11 and that is directed at page 5, paragraph 1, line 1,
12 On Exhibit 568 it says, "SRO must be a graduate of
)
13 an accredited bachelor degree program in engineering."
14 Do you see that?
15 A
I see that.
16 Q
Then looking at page 5, paragraph 1, 17 line 1 of Exhibit 567, do you see, "The candidates 18 for SRO must be graduates of an accredited bachelor 19 degree program in engineering"?
20 A
I see that part of the sentence.
21 Q~
Turning to the next page of your Exhibit O
is item 4 now on your Exhibit 568, 22 568, page 5, this 23 and it refers to page 5, paragraph 3, line 4, and it says, "An Aux
'A' can progress to a CRO after the 24 25 completion of a nuclear technology."
1 zochman 285 2
Do you see that?
3 A
Yes.
4 Q
Looking at 567, paragraph 3, line 4, 5
do you see, "An Aux. A can progress to CR0 after.
6 completion of a nuclear technology"?
7 A
I see that part of the sentence.
8 Q
The next comment on Exhibit 568 is 9
page 5, paragraph 3, lines 6,
78, 8,
"RO not i.
l 10 eligible for RO license until 40 credits towards I
11 BS degree obtained."
12 A
I see that.
13 Q
Do you see beginning in line 6 of i
14 paragraph 4 on page 5 of Exhibit 567 the words, 15 "He would be eligible for RO licensing but would not i
16 he eligible for further advancement until completion i
17 of 40 additional credits towards a BS degree"?
18 Do you see those words on lines 6, 7 and 8 on 19 Exhibit 5677 20 A
I see that.
21 Q
Now, your next comment on Exhibit 568 O
22 is with respect to page 6,
"PSU, Comment
'b.'"
23 Turning to page 6 of Exhibit 567, is 24 there a-comment "b"
on that page?
25 A
There is a comment "b" on that page.
i
_ _ _ _ _ _ _.,,. - -.. _. _,.. _ _, _, _ _ ~ _ -, _, - - - - - - - -,, _ _, -..
l l
1 Zechman 286 2
Q The next comment on your Exhibit 568 3
is with respect to PSU comment "c" and "d" on page 6.
4 Do you see that on Exhibit 5687 5
A I see "c"
and "d" with "d" continuing on gg 6
page 7.
7 Q
Do you see on 568 your comment 8
memorandum, a comment with respect to PSU comments "c" 9
and "d" on page 6?
10 A
Yes, sir, I do.
11 Q
Then on page 6 and continuing on to page 12 7 of Exhibit 567 -- withdrawn.
(G_)
13 On page 6 of Eghibit 567, is there a 14 comment
'c"?
15 A
There is a comment " c.' "
16 Q
Is there a comment "d"
in Exhibit 567 17 which starts on page 6 and continues over to page 77 18 A
There is.
19 Q
And your next comment does not 20 identify a page number but it refers to PSU comment i
21 "e" with the words " Point progression degrees should be O
22 clearly identified."
23 Do you see that on 5687 24 A
I see that.
Q Turning to page 7 of Exhibit 567, is 25
1 Zachman 287 O\\
2 there a PSU comment "a" on that page?
3 A
There is a comment "e" on that page.
4 Q
Is there a sentence on that comment 5
that says, "The point progression should be gg 6
clearly identified"?
7 A
There is.
0 Q
Your next comment on Exhibit 568 is 9
with respect to PSU comment "f" on page 7.
10 Do you see that?
11 A
I see that.
12 Q
Is there a comment "f" on page 7 of
()
13 Exhibit 5677 14 A
There is.
15 Q
Your next comment on Exhibit 568 is 16 with respect to PSU comment "g" with the words 17
" Training department h'ead reports to the QA 18 manager,"
referring to page 7.
19 Do you see that?
20 A
There is a comment that says that.
21 Q
Referring to page 7, is that right?
O 22 A
Referring to page 7.
23 Q
Looking at Exhibit
- 567, page 7,
is 24 there a paragraph entitled "g" on that page?
25 A
There is.
I 4
1 zachman 288 O
2 Q
Does the first sentence of that 3
paragraph contain the words "The training 4
department head reports to the quality assurance
{lg 5
(QA) manager"?
6 A
That is part of the first sentence.
7 Q
Again directing your attention back to 8
568, the next comment is with respect to a PSU 9
comment "h"
with the words " Assign homework,"
10 again referring to page 7.
i 11 A
I see that.
12 Q
Directing your attention to page 7
()
13 of Exhibit 567, is there a comment "h" on that page?
14 A
There is a comment "h" on that page 7.
15 Q
Does the first sentence of that co mment 16 say, "nowhere in the program is it evident that f
17 homework is assigned"?
18 A
There is that sentence.
19 Q
Now, your next comment in Exhibit 568 20 is PSU comment "i."
21 Looking at Exhibit 567, is there a is there a paragraph "i" on page 87 22 comment "i" 23 A
There is.
24 Q
Now turning to the final page of your 25 comment sheet, Exhibit 568, the first item refers
1 zachman 289 2
to PSU comment "j" on page 8.
3 Directing your attention to Exhibit 567, 4
is there a paragraph "j" on page 87 ggg 5
A There is.
6 Q
The next comment on your comment sheet 7
is with respect to PSU comment "k" on page 8.
8 Directing your attention to Exhibit 567, 9
is there a paragraph "k" on page 87 10 A
There is.
11 Q
The next comment on your comment sheet is 12 with respect to PSU comment "1" on page 8 with
()
13 reference to the words "Some materials used for AOs 14 and CROs questionable."
15 Is there a paragraph "1" on page 8 of 16 Exhibit 5677 17 A
There is a paragraph "1."
18 Q
Do the first two sentences c7 that 19 paragraph read, "It appears that the same material 20 is used for AOs and CROs.
Such an approach is 21 questionable"?
O 22 Do the first two sentences contain 23 those words"?
24 A
The first two sentences contain those
\\
25 words, yes.
1 Zechman 290 2
Q The next comment on Exhibit 568 is i
3 with respect to PSU comment "m" on page 8.
Is there a paragraph "m" on Exhibit 5677 4
5 A
There is a paragraph "m" on Exhibit 567.
ggg 6
Q The next comment on 568 is with respect 7
to PSU comment "n" on page 8.
8 Turning your attention to Exhibit 567, 9
is there a paragraph "n" on page 8 of that document?
l 10 A
You didn't read the entire item.
]
11 Q
I am about to.
The first question is, 12 is there a paragraph "n" on page 87 l
)
13 A
There is a paragraph "n" on page 8 of 14 567.
15 Q
Your comment sheet, under PSU comment "n"
16 are the words " Union representative should be 17 licensed CRO."
18 Do you see that on Exhibit 5687 19 A
I do.
20 Q
Now looking at Exhibit 567, paragraph l
21 "n," does that cont'ain the sentence "To censure 9
22 adequate technical competence, the union representative 23 should be at least a licensed CRO"?
24 A
Yes, I have that sentence.
25 Q
The final page to which comments are l
l
- l. -
1 zachman 291 2
directed, your comment shpet on Exhibit 568
{
l 3
contains a comment with respect to PSU comment "o"
4 on page 9.
5 Looking at Exhibit 567, is thore a ggg 6
paragraph "o" on page 97 7
A There is a paragraph "o" on page 9 of 8
567.
9 Q
Looking at the next comment, page
'j 10 9 -- withdrawn.
11 Looking at the next comment *on your 12 comment sheet, that refers to PSU comment "p" on page 0
13 e.
t 14 I ask you whether there is a paragraph "p" 15 on page 9 of Exhibit 567.
16 A
There is.
17 Q
And your comment on Exhibit 568 has i
18 the words "small utility training information" under i
l 19 the phrase "PSU Comment p."
20 Do you see that?
21 A
I see that.
l 9
22 Q
Looking at the first sentence of I
l 23 paragraph "p" on p' age 9, does that state, "A comparison 24 review of the GPU training program to the selected 25 small utility was also performed"?
I
1 Zechman 292 0
2 A
It does.
3 Q
Your next comment on your comment 4
sheet is with resp e ct to PSU comment "q" on page 9.
5 I would ask you whether there is a ggg is there a paragraph "q" on page 9 of 6
comment 7
Exhibit 5677 8
A There is a paragraph "q" on 567.
d 9
Q And finally, the last comment on your 10 comment sheet is with respect to PSU comment "r"
on 11 page 9.
12 I would ask you whether there is a 13 paragraph "r" on page 9 of Exhibit 567.
14 A
There is a paragraph "r" on page 9 of 15 567.
l 16 Q
I think I asked you some questions, 17 Mr. Zechman, either the first or second day of this 18 deposition, about your participation in the 19 development of the budget for the training department.
20 Do you remember that?
21 A
Yes, sir, I do.
O 22 Q
And I think you testified that, if 23 I remember correctly, that at least at one point in 24 time you delegated considerable responsibility for 25 that to Mr.
McCormick.
1
1 Zechman 293 2
MR. MacDONALD:
I object.
Whatever he 3
testified to, he did.
I don't know that those 4
are the exact words.
g If you are trying to refresh his 5
6 recollection, start from somewhere.
7 Q
Did you, Mr. Zechman, at any point during 8
the time that you were in charge of the training 9
department, delegate any part of the responsibility 10 for the development of the budget for the training 11 department to Mr. McCormick?
12 A
To the best of my recollection, 13 Mr. McCormick had worked o n the budget and, to the 14 best of my recollection at this time, I believe it 15 was I who directed him to work on it at that time.
16 Q
What was that time?
17 A
Sir, all I r'ecall, there was a period 18 of time in which that was done.
19 Q
Well, was there a period of time 20 during which you were either acting supervisor or 21 supervisor of the training department when you 9
22 assumed responsibility for participating in the 23 development of the budget for your department?
24 A
By " participation," sir, with respect 25 to the budget, there are times when I participated in i
zoch=an 294 1
A)
(-
either commenting on the budget or reviewing it j
2 in 8 me apacity of that sort.
3 Q
And you were aware of the amount of 4
money that had been -- or that was proposed to be 5
allocated to the training department in the budget, 6
were you not?
7 8
A At the time of ty involvement, I would have been aware of those numbers.
I don't have 9
those numbers in my head at this time.
10 33 Q
Was the budget put together on an annual 12 basis?
MR.
MacDONALD:
Are you still dealing 13 with a certain time period or any time prior to 14 the accident?
15 16 MR. FISKE:
Fair enough.
l 17 Q
Let's take the period of time from the 18 beginning of 1976 through the accident.
i A
What is your question, sir?
19 l
Q Was the budget prepared on an annual 20 21 basis?
k A
To the best of my recollection, the budget 22 was prepared at some time and it included projected 23 allocations to the best of my recollection.
24 25 Q
so, for example, some time in the year
=
1 zachman 295 O
2 1977 a budgot would be put together for the year 3
1978, that kind of thing?
4 A
I don't know what time frame they were 5
put together.
I don't know whether it was in 1976.
gg) 6 I have no recollection of that.
7 Q
I am not asking now for any specific 8
years.
I am just trying to get the process down.
9 Is it correct that the process involved 10 making a decision during one year as to what the 11 projected budget would be "or the next year?
12 MR. MacDONALD:
Are you asking if that
()
13 was the normal process for the budget?
14 MR. FISKE:
Yes.
15 A
Because I have such a poor recollection 16 at this time, I can't say either way, sir.
17 g
Do you remember any time during the 18 period when you had positions of acting supervisor 19 or supervisor of the training department when you 20 were dissatisfied with the amount of money that 21 was allocated to the training department in the 9
22 budget?
23 A
I have no recollection at this time 24 of not being satisfied with the amount of money 25 allocated to the training budget.
l --
1 Zechcan 296
)
2 Q
Did you, Mr. Zechman, yourself on more 3
than one occasion go to the facilities of Babcock 4
& Wilcox at Lynchburg, Virginia and participate 5
in their simulator program?
ggg 6
MR. MacDONALD:
prior to the accident?
7 MR. FISKE:
Yes.
8 A
You mean as a student?
9 Q
Yes.
10 A
Yes, sir.
11 Q
Do you recall going to B&W for training 12 on the simulator in 1969, 1973 and 1978?
()
13' MR.
MacDONALD:
Whether he recalla going 14 each of those years or any of those years?
15 MR. FISKE:
Let's see if he remembers 16 all three, for openers.
17 A
The only date that I recollect with 18 certainty that I went to the simulator was in 1978.
'19 Q
You do remember that you had been 20 there at some time before that?
That wasn't your U2I first time?
/
qil l
A That wasn't my first time.
22 },
23 Q
- There was a period', of time, was there not, l.,
24 in 1976, when the operators,in the Met Ed training
,g-
~
25 program went to the B&W simulator on cn annual basis?
1 zechman 297 1
(_
2 MR. MacDONALD:
M'ay I hear that question 3
again?
4 MR. FISKE :
I will rephrase it.
5 Q '.
There was a period of time, was there not, ggg 6
when the procedure at Met Ed was to have the 7
operators go to B&W for simulator training once a 8
year?
9 A
There was a time when we went -- when the 10 operators went to requalification training on an 11 annual basis.
12 Q
Licensed operators doing requalification
()
13 training?
14 A
Yes.
That is not to say we couldn't 15 send students along to observe.
16 Q
Sure.
I'm not excluding anybody else 17 for the moment.
18 But talking about licensed operators 19 doing requalification training, there was a period 20 of time when it was the policy at Met Ed to have 21 those licensed operators go to the B&W simulator 9
22 once a year?
That is correct, right?
23 A
It was a policy to have our licensed x
24 operators at some period of time go to the 25 simulator on an annual basis.
m l
1 Zechman 298 s
O 2
Q Did you personally feel that was a 3
worthwhile thing for them to do?
4 MR. MacDONALD:
You are talking about 5
the time when --
ggg 6
MR. FISKE:
Back in those years when 7
this was going on.
We are' talking before the 8
accident.
9 A
May I ask for a clarification?
10 Q
sure.
11 A
Are you saying not only was it 12 worthwhile -- are you tying two things together,
)
13 the annual time frame together with whether it was 14 worthwhile to go to the simulator?
15 Q
Well, those are clearly two separate 16 questions, so let's take them one at a time if that 17 is easier.
18 We are talking now, as I said, all these 19 questions are directed at the period of time before 20 the accident, including the period of time even before 21 you became suporvisor or acting supervisor of training.
O 22 Do you understand that time period I am 23 talking about?
24 I am not limiting these questions to the 25 time period when you were in charge of the training 4
1 Zechman 299 2
department.
I am extending it back before then, O.K.?
3 A
I believe I understand.
4 Q
And the question is 5
During that period of time did you ggg 6
consider that it was worthwhile for the licensed 7
operators to have training on the B&W simulator?
8 A
I believe the simulator provided a very 9
useful tool for the operators.
We relied extremely 5
10 on the training we received from B&W and the 11 operation of the B&W system.
We relied heavily on 12 the operation of that simulator.
13 Q
Relying heavily on it, did you feel it 14 was desirable to have the operators get that kind 15 of valuable training once a year?
16 A
I believe it was valuable sending people 17 to the simulator indepen' dent of a time frame.
18 Q
I understand that, but we covered that.
19 Now I am asking you as to your opinion 20 during th'at period of time as to the frequency with 21 which you felt it was desirable to have the O
22 operators go to the simulator.
23 There was a period of time when, as you 24 have said, they were going to the simulator every 25 year, isn't that correct?
1 zachman 300 2
A There was a period they went to the
~,
3 simulator every year, yes.
4 Q
Did you feel it was worthwhile, valuable S
to the operators to go to the simulator every year?
gg 6
A I guess my answer still is it's valuable 7
to go to the simulator -- it was valuable to go to 8
t he simulator at any time, whether it was once a 9
year or otherwise.
10 Q
I understand that.
But somebody had 11 to make a decision, I assume, within the Met Ed 12 training department, as to whether the operators were
()
13 going to go once a year, once every two years, once 14 every three years, once every four years, or once 15 every ten years.
16 All I am getting at, there is a i
l 17 question tha t I am asking, Mr. Zechman, that deals 18 not simply with the concept of having them go 19 there, but how often they should go there.
20 Do you understand that?
21 MR. MacDONALD:
Wait a minute.
22 There are a lot of assumptions.
That is more 23 a statement than a question.
24 If you want to ask a question, put a 25 question.
~.
1 Zechman 301 O
2 MR. FISKE:
Let's go back to basics.
3 Q
Did you understand that somebody in the 4
training department was making a decision as to 5
how often the operators should go to the B&W g
6 simulator?
7 A
The decision on the frequency of how 0
often they go to the simulator was not just
-- was I
9 not just the decision made by the training department.
t 10 It had other -- there were other people involved 11 in the decision-making process as to the frequency.
12 Q
But there was a person or a group of 13 persons within the Met Ed organization that made that 14 decision, correct?
15 A
That is correct.
Q That is what I am getting at, that type 16 17 of decision; in fact, that specific decision as to IO how frequently the operators should go to the 19 simulator.
I am asking you for your opinion during 20 the period of time that you were involved in this 21 traiiting pre-accident as to whether you felt that O
22 it was desirable to have the operators go to the 23 simulator every year.
24 A
I would need a lot more information to 25 make that kind of decision on the frequency.
I would
1 Zechman 302 0
2 have to know at the time whether, if for any 3
reason, sending them on a less frequent time 4
affected their operating ability.
5 Q
There was a time, Mr. Zechman, was.rhere ggg 6
not, before the accident when a decision was made by 7
someone within Met Ed that the operators would not 8
go every year but rather would go every two years?
~
9 A
There was a point in time in which a 10 decision was made to send the operators -- a group i
11 of operators every other year.
12 Q
And at the time the decision was made,
()
13 you understood what the decision was, did you not?
j 14 You understood that now the operators were going 15 to be going every other year instead of every ye,ar?
l 16 A
I understood that.
l 17 Q
Did you have an opinion at that time when 18 you learned that decision, as to whether that was 19 a good thing for the training program, a bad thing l
l 20 for the training program, or it didn't make any 21 difference?
O 22 A
sir,' I already indicated that I thought l
l 23 going to the simulator was a good thing.
I indicated
(
24 that whether it was -- to make a determination s]
j 25 whether it would be -- to make a determination whether f
, - _ ~... _
v-1 zachman 303 i
2 every two years as opposed to every year was
\\
3 g
d r bad, I w uld need a re inf rmation.
4 Q
Look, Mr. Zechman, in 1978 is when 5
this happened, wasn't it?
gg) 6 A
I forget the exact time frame.
7 Q
Let's look at page 85 of your 8
Kemeny Commission testimony.
9 Directing your attention to the question 10 and answer in line 11, "In 1978 they made the 11 decision to alternate years?
12
" Answer:
Yes," do you see that?
13 A
Yes, I do.
14 Q
Does that refresh your recollection 15 that 1978 was the year that the decision was made?
16 A
All this tells me is that at the time 17 I was having this deposition taken, that was my 18 best recollection, but I also stated that I was 19 asked to speculate.
20 Q
When you testified before the 21 President's Commission, that was in July of 1978, 9
22 is that right?
23 A
That is what I have a copy of before me.
24 MR. MacDONALD:
You are asking if he recalls 25 it was July of '797
1 zochman 304 2
MR. FISKE:
Yes.
3 Q
Don't you recall that you testified 4
before the President's Commission in July 19797 5
A I recall I testified before the ggg 6
President's Commission.
On the copy of the 7
deposition here, it says the 27th day of July.
8 Q
I am not asking you to remember the 9
specific day, but you do have a present recollection 10 of test.ifying and giving a deposition to the 11*
President's Commission in the summer of 1979, isn't 12 that correct?
()
13 A
That is correct.
14 Q
In the summer of '79 you were asked 15 the following question and gave the following 16 answer:
17 "In 1978 they made the decision to 18 alternate years?
19
" Answer Yes.
20
" Question:
So that 1978 was Unit 1's 21 year?
O 22
" Answer:
Yes."
23 Do you see that in the testimony?
24 A
Yes.
25 Q
In 1978, Mr. Zechman, you were supervisor
=
1 zechman 305 t
2 of training, correct?
MR. MacDONALD:0 For the whole entire 3
4 period?
5 Q
Until September 1, 1978 you were acting 6
supervisor of training, and from September 1,
1978 7
to December 31, 1978 you were supervisor of 3
training, correct?
9 A
That is correct.
i 10 Q
So that for the entire year 1978 you 11 were either acting supervisor or supervisor of 12 training, correct?
)
13 A
That is correct.
14 Q
When this decision was made in 1978 to 15 stop sending the operators to the simulator every 16 year, but instead o nly send them every other year, 17 did anyone consult you as supervisor of training to
~
i 18 get your opinion before that was done?
19 A
To the best of my recollection, I
was i
20 asked, I was consulted.
21 Q
Did you have an opinion?
l 22 A
Yes, I did.
23 Q
Did you express that opinion?
24 A
Yes, I did.
25 Q
What was that opinion?
4
1 Zechman 306
\\-
2 A
My opinion was that I was disappointed.
3 Q
Now, the fact of the matter is,
4 Mr. Zechman, isn't it, that the decision was made 5
by the management based on a cost evaluation?
gg 6
A That is the best of my recollection, 7
that decision was made by them on that basis.
8 Q
Do you remember who in management made r
9 that decision?
10 A
I no longer recollect who the final 11 authority on that was.
12 Q
I will read you some questions and
()
13 answers from the Kemeny Committee deposition, 14 page 85 and continuing to page 86.
15 "And you indicated it was a management 16 decision based on a cost evaluation?
17
" Answer:
That is my understanding.
18
" Question:
And who in management 19 would have made that decision?
20
" Answer:
It would have been made at 21 least at the vice president level.
O 22
" Question:
Which would have been whom? -
23
" Answer:
Jack Herbein.
24
" Question:
Is he the individual that 25 instructed you as to his policy?
Zochman 307 1
" Answer:
I don't know who instructed 2
Alexis Tsaggaris to that policy.
3
" Question:
And Mr. Tsaggaris told you 4
of that policy?
5 ggg
" Answer:
Yes.
6
" Question:
What was your opinion of the 7
8 simulator training at B&W from your experience on that simulator?
9
" Answer:
I felt that was the nos 10 11 worthwhile training I have seen in a long time.
12 I felt the instructors wer? very well qualified.
13 I thought what you saw and what you did on the
()
simulator was worth its weight in gold."
14 were you asked those questions and 15 16 did you give those answers before the President's 17 commission?
18 A
What you have read and my testimony is 19 what I recall saying to the President's Commission 20 at that time.
21 Q
D es that ref resh your recollection, 9
22 having heard that, that it was Mr. Herbein at the 23 vice president level who made the decision to have 24 the operators go to the simulator only every other O
25 year?
1 Zechman 308 2
A I stil1~ don' t recollect either way.
3 Q
I w uld like to go back to the notes 4
of the interview, Mr. Zechman, that you had with 5
Mr. Keaten in October of 1979.
I believe we marked gg) 6 this as B&W Exhibit 561.
I would like to direct your attention 7
8 to the bottom of page 2 of these notes where the 9
notes state, "There is a perceptive from this 10 discussica of a constantly eroding training program, 11 especially for aux. operators with time as well ac 12 a continually reduced interest in the need and 13 value of the training itself."
14 Do you see the statement in the memorandum 15 of that interview?
16 A
I see the comment.
17 Q
Did you make a statement to Mr. Keaten 18 in words or substance that there was a constantly 19 eroding training program, that the training program 20 was eroding?
21 MR. Mac DONALD:
I object.
I think that 9
22 was asked and answered yesterday, but you may I
23 ask it again specifically as to that paragraph.
24 MR. FIS KE :
I will put it very simply 25 then.
If that is true, then all of this l
l i
1
l 1
zochnan 309 2
becomes duplicative, but to avoid the chance 3
it wasn't a sked yesterday, I will put it once 4
4 more.
5 Q
Did you say to Mr. Keaten in words or ggg 6
substance that prior to the accident there had been 7
an erosion in ths' training program?
8 l
A I don't recall saying to Mr. Keaten the L
9 phraseolo9y that you just used or implying that l
10 statement.
11 Q
15 it your testimony that you didn't 12 say anything in that meeting that would create the
()
13 i
impression in someone's mind that there was an 14 eroding training program?
15 MR. MacDONALD:
I object to that.
That 16 is pure speculation.
Anything can create an 17 impression in someone's mind.
Who knows what 18 somebody is going to think and write down on a 19 piece of paper based on what someone else said?
20 That is the most hypothetical question 21 I have ever heard.
l 22 Q
Let me ask you again, Mr. Zechman, 23 what was Mr. Keaten's position at the time of this 24 interview?
25 A
I believe I have already testified that
1 Zechman 310 0
2 I don't recall his specific title at that time.
3 Q
Do you know how long he had been with 4
the GPU organization?
5 A
I have no recollection of that.
(gg I
6 Q
One of the people that was at this 7
interview vas Mr. Long?
8 !
A That it ccrrect.
l 1
Q Ar.d what is Mr. Long's pcsition at GPU 9
fl i
10 '
today?
I 11 MR. MacDONALD:
We went through this i
12 the other way, Mr. Fiske.
O(_)
13 MR. FISKE:
I know.
I have one or two 14 questions.
l A
Dr. Long is Mr. Knief's supervisor.
16 He is director of training Dr. Long is director of 17 training.
Q Did you ever express the view to anybody 18 19 that Mr. Keaten, Mr. Wallace, Mr. Long, and 20 Mr. Williams weren't qualified to conduct the kind 21 of investigation into t'he training program that O
22 was reflected in this interview they had with you?
23 THE WITNESS:
Repeat that.
24 (Record read back.)
25 A
That question never even arose in
. _ _ _ - - ~
h l
Zechman 311 f
n 2
my mind at the time.
I 4
3 Q
Is your recollection as to what i
l 4
Mr. McCormick and Mr. Beers said at this meeting 5
any better today than it was yesterday?
ggg 6
A Sir, I still have no recollection of 7
what they asid.
t 8
Q In t me read crother sta temen t frob the memorsndum of this laterview again.
Referring to 9 l i
y 10l page 3 now.
t 11 I Tne statement from the interview reada, I
12 "In sone senses the training depart 7.ent secms to 13 have been an orphan organisation.
It had the 14 responsibility for establishing a program (within 15 restraints and limits available), but virtually no 16 authority or clout to ensure that the overall 17 program" -- the sentence ends there.
18 Do you see that sentence?
19 A
I see that sentence.
20 Q
Did you make statements to Mr. Keaten 21 in words or substance that the training department 9
22 had the responsibility for establishing a program, 23 but no authority or clout to ensure that it was carried l
l 24 out?
25 A
I believe I testified yesterday as to
Zochman 312 1
C\\
V 2
the best of my recollection that I did indicate to that group that the line function -- I don't know 3
if these are the exact words, but the operations 4
department was not being responsive to the letters ggg 5
6 of attendance in that -- just to let them know that that was one of my comrents.
7 l
3 Q
Lo you remember saying anything else t
9 apa rt from the inattention of the cparating j
l
[
department to the attendance problem, to the d.I 10 i
p 3
11 effect that the training department had no I
12 authority or clout to ensurc that the overall I
i I ')
13 l program was carried out?
\\~J 14 A
I have no recollection making that 15 statement because I felt we had the authority 16 to carry out the training program.
My concern was 17 with the attendance to the training program.
18 Q
Did you feel that you had the clout 19 to enforce attendance?
20 A
I felt that I had the responsibility 21 to make it known about the attendance, but it was G
22 the responsibility of the line function or the 23 operations departnant to see their people were there.
24 Q
I heard your answer.
Now I would like 25 to ask my question again specifically, f
l 1
Za char.n
313 O
2 Did you feel that the training department 3
itself did not have the clout to e nforce attendance?
4 MR. MacDONALD:
Are you talking about 5
his understanding prior to the accident?
ggg 6
MR. FISKE:
Yes.
7 MR, MaccoNALc:
His recollection of that 1
6 understandin1?
?
9i MR. FISKE:
- tes, i
t 10 [
MA.
MacrCNALD:
I just wanted tc clarify 11 the tine y eriod.
I2 A
I i'ei t we had the responsibility to 13 make the attendance known.
I did not have the 14 responsibility to order, under my command, the 15 operations department individuals to the training 16 department.
17 Q
The memorandum, Exhibit 561, again on I0 the bottom of page 3 and the top of page 4,
this 19 is the memorandum of the interview that you had l
l 20 with Mr. Keaten and others.
21 The memorandum says, "In response 22 to a question on differences between units, there was a general feeling that there was a noticeable 23 l
24 difference between attitude and performance
()
i 25 between the unit operators with the Unit 1 people l
e
- r.,.,,.. -.- - -
1 Zechman 314 O)
\\_
2 being decidedly on top.
No specific reasons could 3
he given other than background, approach, pride, 4
et cetera, in Unit 1 people that they never seemed to ggg 5
get in Unit 2 people."
6 Do you see those statements in this 7
memoranduu?
l 0 1 a
- see t3csa seatements, 1
~
0 !
O Do you remexber which one of the four I
10 yentlemen, Mr. Keaten, Mr. Wallace, Mr. Long, or 1,
I 2
]
Mr. Williams asked the question about the difference 11 12 between units?
()
13 A
I don't even recall the qlestion being 14 asked, sir, if it was even asked.
15 Q
Do you remember anybody at the meeting 16 discussing any aspect of any difference between 17 units?
18 A
I have no recollection of that at this 19 time, sir.
I 20 MR. FIS KE :
Let's take a break.
21 (Recess taken.)
O 22 BY MR. FIS KE :
l 23 Q
Mr. Zechman, who'at Met Ed made the l
24 decision as to which people would be selected as 25 operators for Three Mile Island Units 1 and 27 l
l t
1
1 Zochman 315 (h
MR. MacDONALD:
At any particular time?
(-)
2 MR. FISKE:
I am talking before the 3
accident.
4 5
Q what was the procedure?
ggg 6
A can you narrow that down to a 7
classification 7 Are you talki.ag about ecocrol rcom i
l operators?
8 i 9 !
Q Iet's stare with them, yes, I
f 4
10 A
The normai celectrote prccess for c:htecl l
11 rao.n operators is as follevs:
l l
When a control room operator position 12
)
13 is opon, it is a union position and by such, the 14 position is posted.
By " posted," I mean an 15 open position is put on a bulletin board for the 16 union personnel to see.
17 People interested in that position, l
l 18 mainly the control room operators, because they 19 have two years' experience, the auxiliary operators 20 bid in on the position.
The supervisor of operations, whether it I
21 O
22 be Unit 1 or Unit 2, has the ultimate responsibility 23 for picking the most senior qualified auxiliary 24 operator for that position.
25 In the selection of that operator, he
1 Zechman 316 A(-
2 sometimes consults with us on the individual's 3
training background to that point.
That is not to 4
say that he has to -- in the normal practice, it was 5
to look at his background, discuss the individual gg 6
with us.
But the ultibate selection was made b
7 fI by that individual.
i
(
8 Q
Are thers specifica criteria for persons t
9 -
to enter that orocesr?
10 A
Just a clariticatLon, vnen you say to 11 enter the procesa, la thect a union con tr.ict ea st 12 tells abcut the bidding processt
()
13 Q
What the qualifications of the persen 14 has to be in order to be considered a control roon 15 operator at Met Ed.
16 A
There is a job specification for a 17 control room operator position.
18 Q
That is a written document, I take it?
1 19 a
re is, 20 Q
Anyone that wanted to apply would have 21 to meet those qualifications, is that correct?
O 22 A
They would have to meet those 23 qualifications or the supervisor of operations would
("N 24 have to justify any waivers, should there be any.
I b 25 Q
What is the dividing line between the
1 Zechman 317 O
2 union and management in the organizational 3
structure of the operations department at Three Mile 4
Island?
g 5
MR. MacDONALD:
You mean in terms of E
I personnel by position?
I
}i I
MR. FISKE Yes.
j 8
A The control rocra operator po s ir.io n
[:
9 is the last union pcsition.
M2o-se the control roon.
10 cperator is a shift f o r e m e.n, a management posit.;Lon, j
11 and shift supervisor is a management position, il
}
12 l supervisor of operations is a mar.cgement posi tic,n.
l Q
Is there sort of a basic group of four 13 14 people that are supposed to be on the shift at any 15 time in the control room?
one 16 MR. MacDONALD:
Prior to the accident?
17 MR. FISKE:
Yes, prior to the accident.
I 18 there was a complement of CRO, A
There is 19 shift foreman and shift supervisor and auxiliary 20 operators on a shift prior to the accident.
21 Q
Was it required procedure that there be 9
22 a shift foreman and a shift supervisor on each shift?
23 A
I don't recall the complement, the specific 24 complement.
I don't recall.
25 Q
Is it correct that in orde r -- again,
1 Zechman 318 P
2 prior to the accident -- to become a control room 3
perator, it was not necessary for a person to have attained a degree beyond graduating from high school?
4 A
It is correct that one of the ll 5
6 requirementa for a CRO was to be a high school I
graduat.3.
The position did not require s higher 8 [
degree or a college dagree.
]
9 I
Q L' ave there been any changer in che I
1 10 educational requiresents to becone a control roca
}
+
i cporator since the accident?
- )
i:
12 HR. Ma cEGI1ALD s In terms of degrees now?
)
13 MR.
FIsns:
Any chang e.
14 A
Not being in the operator training 15 department for the last approximately two 16
- years, I don't recall.
17 Q
You don't know, in other words?
18 As you sit here today --
19 L
As I sit here today, since I'm not 20 involved in operator training, I don't know.
i l
21 Q
Prior to the accident, did Met Ed 22 have any formal procedures by which persons working 23 at either Unit 1 or Unit 2 could initiate a safety 24 concern?
25 THE WITNES S :
Read that back, please.
m
1 gechman 319 2
(Record read back.)
3 A
I don't recall.
4 Q
Were you familiar with the provisions (lg 5
of 10 CFR 21 prior to the accident?
I 6 I A
Yes, I an.
7 3
Q You were?
I 8 g'l A
I was, l
h l
9 Q
Did yoa.st any time prior to the
{
- l l
10 f chree Mile Island acciden t>
ever een eny report t
i 1'
l II filed by Met 2d under 1G CFR ?.1 Wi'.h respect to U2
[
either Unit 1 or Unit 27 I) 13 A
1 don't recall, 14 Q
Did the traising department during the 15 period of time that you were either acting 16 supervisor or supervisor include training on the 17 requirements of 10 CFR 217 18 A
To the best of my knowledge, it did.
19 Q
Was there written material used by t he 20 training department in connection with that program?
21 A
I don't recall.
O 22 Q
In what part of the training program was 23 that taught?
24 A
To the best of my r ecolle ct io n, it was 25 taught in operating training and requalification and
1 Zechman 320 tx-2 in the general employee training program.
3 Q
was there a
specific instre ; tor that 4
was responsible for that part of the training?
S A
Are you.asking was there a specific 6
instructor assigned tc just train on that subject?
7 Q
I am not as king you whether there was I
}
l 8
a person who did that and nothing else.
I)
I an asking you4 wac that subject 9
10 tatight by ant pezs9n, I:
l 11 lt A
- 7. t could have been taught by several instructors at different times.
] dj.fferent 12 13 9
I would like to show you vbat was I
14 marked on =e befor e as Exhibit 557 which, just to f
15 make the record clear, was identified as a summary i
16 of the training and certification relating to 17 Three Mile Island Unit 2 operators prepared by 18 Mr. McCormick after the accident.
19 I
ask you if y.ou can just look 20 through that and point out for me where in there l
21 it contains a reference to a program which covered 22 the requirements'of 10 CFR 21.
1 23 MR.
MacDONALD:
You want him to look j
24 in there and see if there is a specific l
25 reference to that in there?
l l
i- -
._+
v
i 1
zechman 321 2
MR.'FISKE:
Yes, I would like to know 3
where in the document is the reference to the 4
section or the part of the training program 5
which covers 10 CFR 21.
ggg 6
A May I sea a copy of the requalification
)
7 prograr, Chapter 13, that thiri makes reference to?
~
j 8
Q Is it attached to chat document.?
i j
4 9
A No, it isn't.
It is nada refc3 ence 70 1
I 10 J here.
l 11 MS.. ~MAGNF.R t I do0'P. recall ever receivin) 12 it.
13 THE WITNESS:
It's the cporator t
14 requalification program.
15 MS. WAGNER:
Chapter 13 of what?
16 THE WITNESS:
The FSAR.
17 Q
You would like to see the description of 18 the requalification training program from the FSAR?
19 A
Yes.
I 20 Q
You are testifying that was attached to 21 the memorandum?
O 22 A
No, I'm saying he made reference to that.
23 Q
So the record can be clear, Mr. zechman, 24 what page of the exhibit are you now looking at?
25 A
I am looking at page 13 of Exhibit 557.
I Zechman 322 2
Q Could you just read into the record 3
what is contained on page 13 of Exhibit 557?
4 A
Paragraph 1.e,
" Reactor operator f
g requalification.
The philosophy, conduct" 5
back.
6 "The philosophy, content and conduct 7 I; of the trainir.g prograu designed to maintain license N] cperator qualification and proficiency is de. scribed O
l I
9 by the TiiI-2 FSAR chapter 13, section 13 2,2, il 10 f
'Heercpolitan Edison operator requalf fication progias.
lfThis il is provided as attachment 1."
l
{
12 Q
Then we navn. Just provided to you the (L'3 j
execrpt fron P.he 'FSAR referred to os page 13 't j
l l.;
i 14 A
Yes, sir.
15 Now, on page 13.2-7 of chapter 13, which 16 describes the Met Ed operator requalification program, 17 paragraph 13.2.2.2.1,
" Operational Review (O R) 18 Lecture Series," on page 13.2-7, there is a section 19 that reads as follows:
20 "The following topics shall be covered 21 as a minimum during the OR lecture series each 9
22 year.
Item H is applicable portions of the title 10 23 chapter 1 code of Federal regulations."
l l
O 24 Q
Have you finished reviewing that document?
l U
25 A
I have reviewed the document.
I
1 zechman 323 N/
2 As I mentioned earlier, this document 3
was a summary review prepared by Frank McCormick as 4
the best of his recollection or what he could put 5
together at that time to give an overview of.our ggg 6
p rogr am.
Just because it doesn't specifically say i
7 10 CFR 21 doesn't imply our training programs did nct 8 } cover that.
b i
I 9
'I Q
I would like to refer you back to the i
i 10 description of the requalification program " rom
)
j; 11 l
the FSAF. Exhibit 200, 1
12 You referred earlier te section 13.2.2.2.1, 13 the operational review lecture series, is that correct 7 1
14 A
That is correct.
3 I
i 15 Q
And the reference to the code of Federal 16 regulations is in subparagraph H of that section, is 17 it not?
18 A
That is correct.
19 Q
so that whatever was caught on the code 20 of Federal regulations under the description in 21 the FSAR would be as part of the operational review O
22 lecture series?
23 A
What was covered in the OR lecture 24 series, one line ite.m was applicable portions title 25 10 of Federal regulations.
What that was there 1
\\1 1
Zechman 324 n\\/
to do was to allow us to review appropriate codes 2
f Federal regulations or any new ones coming along 3
4 or changes we felt applicable for the operators to 5
have knowledge of.
ll) 6 Q
This training program was a training pt not?
7 program for licensed cperators, was 8!
A This particular the enc --
4-t
- b Q
The operational resiew Isciure earles t
that we have just been talking ab6ut wan part of 10 }
)
il [
the !!at Ed opsratar r91nelificaticn program, was it I
(
13 g noe.F
/
13 a
That is correct.
i 14 Q
Which, by definition, 'was for licensed l
15 operators, isn't than correct?'
16 A
That is correct.
17 Q
Was there any place in the training
/-
18 program where instructions on_the ' applicable portions
,/
1 i / '~
19' of 10 CFR 21 were given to peisons~who were not
'r 20 licensed operators?
i 21 A
To the best of my recollection, that was O
22 covered in the general employee training program.
l t
23 Q
I am not sure I understand that.
I i
24 A
There is a general employee training 25 program we had for all Met Ed personnel.
They went l'
zechman 325 1
OV through the program on an annual basis and 2
security regulations, applicable codes and 3
regulations, basic health physics, introduction to 4
5 QA, that is what I recall off the top of my head.
lll 6
Q Let me show you a document that we have 7
marked before as B&W Exhibit 556 which is a 8
memorandum ?that you' wrote to Mr. Herbein on August 1,
1973 which tr'ansmits to Mr. Herbein what is referred 9
10 to as an outline of the various training programs 11 conducted for the TMI staff to date.
12 Do you have that in front of you?
O s
13 A
Yes.
14 Q
Could
- you, just for my guidance, 15 show-me where in this summary -,
where in this 18 outline of the training programs conducted for the 17 TMI staff to date, where the employee training 18 program which you have just referred to is describe 67 19 A
I don't see --
l 20 Q
First of
- all, is it described in the 21 document you have in front of you, B&W Exhibit 556?
22 A
I don't see it listed as such in this i
23 document.
That does not infer that that program, 24 although I think it was under a dif ferent title at 25 that time, was not given.
i M
e e..
r g
23chaan 326 I
point out that the code, the 2
Federal regulations, aome of them we conducted --
3 when new ones came out, we conducted special 4
programs just for those to bring them up to date.
9 Q
Were there written materials given to 6
the people in the e mploy.e e training program 7
e nearning-the requirements of 10 CFR 217 8
MR. MacDONALD:
You are talking g
specifically about 21 or the entire chapter 107 10 MR.
FISKE:I Let's make it the whole gy i
chapter.
12 1
Q Amend my q uestion to include the whole 13 T
h chapter.
g
(
A To the best of my recollection, they 15 were given copies of t hat section of the code 16 s
of Federal regulations.
g7 18 Q
' Were they given any written material t hat explained what that section o f the code of Federal gg
- '"1**'
20 A
I d n't recall.
21 O
E "Y
"*h** ** *1 ""
Y"
""d*#***"d ""
22 23 are talking about 10 CFR 217
~~*
A es, I understand we were talking about 24 O
,0 c,.
2,.
\\,,
1
1 Zechman 327 2
g Would the fact that no such written 3
material has been produced to us in this 4
litigation by Met Ed help you recall whether or not lll 5
any such written material existed?
6 MR. MacDONALD:
I object.
I don't 7
know whether that is factually accurate or not.
8 Ask him your question.
9 THE WITNESS:
Repeat the question.
10 (Record read back.)
11 A
Would you be kind enough to rephrase the 12 question?
()
13 g
You don't understand i t?
14 A
I'm not sure I understand the phraseology.
15 g
I will try to make it as clear as 16 I can.
l 17 would the fact that r.o written material 18 explaining the meaning of 10 CFR 21 and its 19 requirements has been produced by Met Ed to us l
l 20 in t his litigation help you remember whether or not 21 any such written material existed prior to the l
22 accident?
23 MR. MacDONALD:
I will object, the same S
24 reason.
1 25 A
To the best of my recollection, the
I 1
Zochman 328 2
material existed.
3 To go beyond that would be speculation 4
on my part.
g 5
MR. FISKE:
Could I hear the answer, 6
please?
7 (Record read back.)
8 Q
Is it your testimony now that there was 9
such written material in existence before the 10 accident?
11 A
To the best of my recollection, copies of 12 10 CFR 21 were given to individuals in our program 13 at different times and they were made aware of 14 dif ferent programs.
That is the best of my 15 recollection.
16 Q
I think you have already told us 17 that from time to time copies of the text of the l
18 10 CFR 21 may have been prepared and may have been 19 given to certain people.
I understand that.
20 What I am asking you is whether any written 21 material was prepared which explained for the O
22 benefit of those for whom 10 CFR 21 is not 23 self-explanatory what the meaning of that section 24 was and what its requirements were?
O 25 MR. MacDONALD:
You are speaking of in
1 ZGchacn 329
,a t )
2 a hand-out fashion rather than to explain 3
in the classroom?
As opposed to handed to the 4
people in the class?
llg 5
MR. FISKE:
Either one.
6 A
I don't recall supplemental hand-out 7
material.
I don't recall either way whether 8
supplemental material was provided.
It would have 9
definitely been explained as part of the program 10 by an instructor.
11 Q
orally?
12 A
orally.
(),
13 Q
For those who happened to be at the 14 l'ecture that day?
15 A
For those who would be at the lecture 16 that day.
17 Q
When the care packages were made up for 18 those who weren't at the lecture that day, what 19 went into the care package to convey to the person 20 who had missed the lecture the oral explanation 21 of the meaning of 10 CFR 21?
O 22 A
I don't recall at this time if that was t
23 one of the modes utilized, nor do I recall either way 24 how that was-transferred, if indeed it was put in 7-.V 25 that fashion.
I don't recall specifically it being
1 zechann 330
/~h 2
put in a care package.
D 3
Q But you can't tell us now, based on your 4
testimony, that during this period of time when lll 5
you were supervisor of training, that if a 6
lecture was given on 10 CFR 21 and the meaning of it 7
and the requirements of it, that there was any 8
procedure to give people who had missed the lecture 9
the benefit of the oral explanation?
10 MR. MacDONALD:
Are you confining the 11 time period to when he was supervisor of training 12 and not when we were dealing with some of the 13 other questions on the whole period?
l s
14 MR. FISKE:
The period of time when 15 presumably he would have the most knowledge on 16 this subject.
17 THE WITNESS:
Repeat that question, 18 please.
19 (Record read back.)
20 A
I don't recall a procedure other than 21 10 CFR 21 itself.
And the transfer of that 9
22 information orally could have come from several 23 directions, in classroom, a foreman could have 24 directed it.
O 25 Q
When you say " foreman,"
whom do you mean?
1 zochaan 331 2
You mean a shift foreman?
Is that who you meant DY "f
- "*""?
3 4
A I don't recall all of the circumstances (ll 5
of how that was transferred orally.
6 Q
Looking again at the FSAR in the 7
description of the operational review lecture 8
series, one of the topics, indeed, the first topic 9
listed in the FSAR as a topic that would be 10 covered --
i 11 A
I'm sorry, can we take a break?
I'm 12 not able to concentrate.
13 Q
Sure.
We might as well break for lunch.
14 (Whereupon, at 12:45 o' clock p.m.,
a 15 lunch recess was taken.)
16 17 18 19 20 22 23 24 25
1 332
(
2 AFTERNOON SESSION 3
(2:00 p.m.)
4 R
ICHAR D
W.
ZECH M
A N, ggg 5
resumed.
6 EXAMINATION (Continued) 7 BY MR.
FISKE:
8 Q
Mr. Zechman, before lunch we were 9
looking at the section of the FSAR dealing 10 with the qualification program, specifically the 11 operational review lecture series, item A.
It 12 says, " Reportable Occurrences."
13 Do you see that?
14 A
Yes.
15 You are' talking about under the 16 sentence, "The following topics shall be covered 17 as a minimum"?
18 Q
Yes.
19 A
Yes.
20 Q
Was the term " Reportable Occurrences" 21 a term of art at Met Ed before the accident?
O 22 In other words, did it have a universally understood 23 meaning?
24 MR. MacDONALD:
Apart from its English 25 meaning?
1 zochann 333
(
2 A
I' guess I still don't quite unders tand.
3 Q
What did you understand " Reportable 4
Occurrences" to be.
ggg 5
A Those were, as my understanding, they were 6
events that occurred at TMI that were reportable.
7 Q
Reportable to whom?
8 A
The NRC.
9 Q
Is that under 10 CFR 21 or is it 10 broader than that?
11 A
It's broader than that.
12 Q
Were t here written criteria at Met Ed (O"T 13 before the accident for 14 A
May I
explain?
15 What I am saying, we have technical i
16 specifications, we have 10 CFR 21, and we have l
17 safety limits.
18 Q
Were there written criteria for 19 determining what types of o ccurrences were l
20 reportable under any one of those three different 21 situstions?
O 22 A
Yes, there was.
23 Q
What written criteria were t here for 24 determining whether an occurrence was reportable O
25 under 10 CFR 217
1 Zochman 334
(}
2 A
- sir, I don't have 10 CFR 21 memorized.
3 Q
That isn't what I asked you.
4 I asked you were there written ggg 5
criteria at Met Ed before the accident for 6
determining which occurrences were reportable under 7
8 A
I believe 10 CFR 21 speaks well for itself.
9 Q
so your answer is there were no written 10 criteria other than the language of the regulation 11 itself?
12 A
I don't recall either way.
13 Q
Were there written criteria for
}
14 determining which occurrences were reportable under 15 the tech. specs?
t.
16 A
Yes, there was.
17 Q
What were they?
l l
18 A
At the time of the accident, sir, i
19 I had those memorized.
I no longer recall them.
20 Q
I am not asking you to recite them from 21 memory.
I am just simply asking you to describe l
22 the general nature of those written criteria.
23 A
violation of a safety limit would be 24 one.
l 25 Q
Just s topping you there, when you
1 Zochman 335 (h
2 referred to safety limit, do you mean safety limit
(,/
3 as prescribed in a technical specification?
4 A
Yes, sir.
Exceeding a
tech. spec.
(g) 5 limit.
That is all I recall at t his time, sir.
6 Q
So have you now described all of t he 7
circumstances under which an occurrence would be 8
reportable?
9 A
I don't know that I described all of 10 them.
I have described those that I recall at this 11 time.
12 Q
Who at Met Ed made the decision as to
( )')
13 whether a
particular occurrence would be reported?
14 A
I don't recall.
15 Q
In what part of the Met Ed organization 16 was the decision made?
17 A
I don't recall, sir.
I must point out j
that I
was not in that decision-making body or 19 group.
20 Q
And you are telling us you don't know 21 now what part of the Met Ed organization had the O
22 responsibility for making that decision?
23 A
I ce rtainly recognize that the 24 operations department would make violations, 7x
)
(/
25 any violations or exceeding limits that were l
l l
1 Zochman 336 C)
(_j 2
reportable, 'known to the supervisor of operations 3
and to the plant superintendent.
4 Q
But you don't know who made the gg) 5 decision?
6 A
Not being a
part of that decision-7 making
- process, I
don't recall.
8 Q
Were these reports written?
9 A
To the best of my recollection, they 10 were.
11 Q
Were they filed somewhere?
12 A
Would you expand upon what you mean
(,a) 13 by "Were they filed somewhere?"
Did someone 14 maintain a
file on them?
15 Q
Yes.
16 A
Having not been the generator of those 17 or writing
- those, I
have no recollection either 18 way.
l 19 Q
Let's talk about the period of time 20 when you were in charge of the training 1
21 department.
22 Part' of the requalification training 23 was training on reportable occurrences, was it l
l p
24 not?
V 25 A
That is correct.
1 Zechman 337 2
Q Was it important to you as head of 3
the training department to know whether there was 4
one place an operator could go if he wanted g
5 to sit down and review reportable occurrences 6
at Unit 1
or Unit 27 7
A certainly I felt it was important for 8
me to know.
9 Q
And did you know?
10 A
Up to the time of the accident, to 11 the best of my recollection, I
knew.
12 Q
Was there or wasn't there such a
place?
13 A
There was such a place.
14 Q
Where was it?
15 A
I said I don't recall.
I recalled it 16 at the time of the accident, but I no longer have 17 that recollection.
0 Q
In addition to reportable occurrences, 19 what other written information was there at Unit 1 20 or Unit 2 that would contain information about 2I transients at the plant?
22 A
There would have been reactor trip 23 reports, LERs, other reports deemed appropriate 24 by the plant superintendent.
25 Q
Well, do they have a name?
1 Zochman 338
(
2 A
I don't recall a specific name.
3 Q
Is that all of the different types 4
of written material that were available before the (lh 5
accident on transients at the plant?
6 A
There were GORB reports that sometimes 7
reflected review of transients.
8 There may be others that I don't 9
recall at this time.
10 Q
Are you familiar with the initials TDR?
11 A
I'm familiar with the initials.
I can't 12 place the wording that go along with them.
(
13 Q
Did you ever hear of a
type of written 14 report concerning transients at the plant called a
15 TDR?
16 A
Yes.
17 Q
Was that called a technical data 18 report?
19 A
To the best of my recollection, th at is 20 the wording for the letters.
21 Q
Did you ever hear of a type of 9
22 document called a
topical report?
23 A
- Yes, I did.
24 Q
Did that also have in formation about O
25 transients at the plant?
I
_ -___,.i..
,,_y.,
_., -,. _ ~.
1 Zochacn 339
[^)
2 A
- Yes, it did.
\\'
3 Q
Was there such a document as an 4
unusual occurrence report?
lll 5
A To the best of my recollection there
.6 was.
7 Q
Did that have information about transients 8
at the plant?
9 A
To the best of my recollection it did.
10 Q
Was there any one place where documents 11 of all of these types that we have just 12 described were kept together?
N 13 A
I don't recall.
(d 14 Q
On what basis did the training 15 department make it its business to learn 16 information about prior transients from the 17 reportable occurrence reports, the reactor trip 18
- reports, the
- LERs, these other reports by the 19 superintendent, the GORB reports, TDRs, topical 20 reports,'
and the unusual occurrence reports?
21 A
They came from different directions.
22 Certain documents came from different directions.
23 They didn't all necessarily come from the same 24 direction.
,a 25 Q
During the period o f time that you were
1 Zochann 340 2
in charge of the training, what procedures did 3
y u have to be sure that t he instructors that 4
were doing the instructing had reviewed all of l
5 the d cuments of the type that I have just 6
described?
7 A
We were on distribution from 8
various sources for those different documents.
9 I'm not claiming that ce saw every document 10 and that we received every
- one, but we were 11 on dis tributio n; the training department was on 12 distribution from those various sources.
13 Q
Did everybody in the training 14 department receive a
copy of each one of 15 these?
16 A
No, not everybody in the department 17 would receive a copy of those.
18 Q
Was there one person that was assigned 19 the responsibility to review all of the documents 20 of this type?
21 A
The responsibility was shared within O
22 the training depkrtment to review the documents.
23
- Again, not saying that we saw all of 24 them.
25 Q
Who made the determination as to
1 1
Zochson 341 2
what information in these various documents would 3
become part of the training program c ur ric ulum?
4 A
There were times in our ggg 5
organization as I
- said, it was a
shared 6
responsibility.
There were times I had the 7
responsibility.
There were times when Nelson 8
Brown had that responsibility.
There were times 9
when Marshall
- Beers, the group supervisor, had 10 that responsibility.
11 Q
In other
- words, the responsibility 12 for this was sort of passed around from one 13 person to another?
14 MR.
MacDONALD:
Objection to the 15 form of the q ues tion.
16 Q
You may answer.
17 A
No, that is not
- true, sir.
I 18 It was for
- example, I will give you an 19 example.
20 Normally they would be directed 21' to the supervisor of training.
In the absence 4
22 of the supervisor-of training, it would have been 23 a
delegated responsibility.
Therefore, there were
' 24 times when a
delegation of responsibility fell rm k) 25 on Nelson Brown.
There were some times that T
- * =
1 Zochann 342
()
2 Marshall Beers had that responsibility.
3 Q
When you say in the absence of the 4
supervisor of
- training, by that you mean jgg 5
physical absence from the Island?
6 A
or in training.
7 What I am trying to point out is 8
'that normally they would have come to the 9
supervisor of training.
As such, I delegated 10 those to be read by and reviewed by either
)
11 review t hem myself or I
may have delegated 12 them to Marshall Beers or Nelson Brovn to 13 review those for appropriate determination 14 whether training would be required.
15 g
- Well, during the period of time 16 from September
'78 to the date of the accident 17 when you were studying eight hours a
- day, i
18 I
take it you did not do the review of l
I 19 these documents at that time.
20 A
To the best of my recollection, m ost 21 of those reviews at that time were done by 9
22 Nelson Brown.
That is not to say that I may 23 have not come into my office and picked them 24 off the
- tray, looked at
- them, and passed them 5'
25 on to him.
1 Zachann 343 2
Q Was information about transients at 3
the plant contained in the control room logs?
4 A
The control room logs reflected the (ll 5
operation.
Those transients were reflected in those 6
logs to the best of my recollection.
7 Q
Was in' formation as to transients at 8
the plant reflected in the shift supervisor's log?
9 A
I don't recall the scope of that 10 responsibility with that log.
11 Q
Are you saying you don't know or you 12 don't recall whether there was information in the
()
13 shif t supervisor's log about plant transients"?
14 A
I don't recall.
15 Q
Was there information about plant 16 transients in the shift test engineer's log?
17 A
Sir, since I don't maintain those logs, 18 I recognize that the logs were kept.
- However, 19 I don'.t recall what the scope or content of 20' those logs were.
21 Q
At any time when you were head of the 22 training department, did you make an effort to find 23 out what was in those logs to determine whether there 24 was information in them that might be useful to O
25 the training department?
1 Zochmen 344
()
2 A
To the best of my recollection, there 3
were times that our instructors have gone to the 4
control room to look at the logs to get information jll 5
from them relative to some operating condition or 6
7 Q
I am not sure you have completely 8
answered the question I just asked, Mr. Zechman.
9 Maybe the reporter can read it back to you.
10 (Record read back.)
11 A
There are times that I had been in the 12 control room and had looked at the logs at times
(^)
13 when a certain event was occurring, not v
14 necessarily a plant transient, but events were 15 occurring to -- for the purpose of ascertaining 16 whether it was feasible to collect that information 17 and take it back to training.
18 Q
Were those situations in which you 19 already knew about the event and you were going to l
l 20 the log to get some details concerning it?
21 A
To the best of my recollection, I have 22 done both.
23 Q
What is the other?
24 A
The other is while one was going on, f3 I
i
\\_J 25 while some evolution was going on, to observe, to
~
1 zochman 345 2
watch what was going on and follow it up.
I may have 3
not stayed in the control room all the time.
I may have 4
left and came back and followed up an evolution that lll 5
was occurring.
6 There were times when there was a 7
transient that had occurred in the past or 8
some time in the past and I have gone up and reviewed 9
that.
2.
10 Q
After you learned about the transient?
11 A
Yes.
12 Q
Was there any regular procedure in the
(
13 training department to have the control room logs 14 reviewed to determine whether there was information 15 in there that would be useful to you?
16 A
To the best of my recollection, there 17 was no such procedure.
18 Q
Was there any such procedure with 19 respect to shift test engineer's logs?
20 A
Not to the best of my recollection.
21 Q
Was there any such procedure with 22 respect to the shift supervisor's logs?
23 A
Not to the best of my recollection.
f 24 Q
Were there procedures at Met Ed during C) 25 the period that you were in charge of the training
1 Zochman 346
(
)
2 department to find out information about events w/
3 at other plants?
4 A
Clarification of your term " procedure;"
(l) 5 you mean a formal procedure?
Can you elicit 6
Q I guess what I am asking simply is, 7
during the period of time that you were in charge 8
of the training department, did you have any 9
procedures, methods by which you would go out and 10 try to find out what transients had occurred at 11 other plants that might have been of interest to Met 12 Ed?
l
- ()
I 13 A
Thank you for that clarification.
v 14 We were on distribution for several l
15 publications, such as LERs, clearing house reports, 16 clearing house summation printouts, Power Events.
17 Q
Power Events, is that the name of a 18 publication?
l l
19 A
To the best of my recollection, it is.
l 20 I&E Bulletins.
l l
21 That is all I can recollect.
22 Q
Is there a publication called " Current 1
23 Events, Power Reactors"?
l 24 A
Yes.
We were on distribution.
I'm not l' s't
\\
i
\\/
25 saying we received every one.
I l
1 Zachmen 347
()
2 Q
Pardon me?
3 A
I said I was clarifying to make it a 4
point we were on distribution, but there are times Jll 5
that we did not receive every one of those.
6 Q
You were on distribution for all of the 7
publications that you have just described?
0 A
To the best of my recollection.
9 Q
Who made the distribution?
10 A
I don't specifically recall where each 11 one came from.
I know that a number of them were 12 coming from distribution from the plant superintendent.
r.
(
)
13 Some were coming from licensing.
U 14 Q
That means there is a procedure within 15 the training department for one person to review 16 those publications to determine whether there was 17 anything in them of interest to the training IO department?
19 A
The same review process that I mentioned 20 l
for the previous reports applies here as well.
21 Q
In other words, you or, in your absence, 22 either Mr. Brown or Mr. Beers?
23 A
or by my direction, yes.
24 Q
Were you aware of the existence of other
(')
25 publications which contained information about l
t
1 Zachann 348
(~'s 2
transients at other plants?
V 3
A could you be more specific?
4 Q
Well, were you aware that, in addition ggg 5
to the documents, the publications that you have 6
just told us about, there were in existence or 7
there were being published publications, other 8
publications which reported on transients at other 9
plants?
10 A
I think I told you a few minutes ago that 11 list I gave you was what I recalled at this time.
12 I can't -- I don't recall either way at this moment.
(~N 13 Q
Did you receive a publication called
'u]
14
" Nuclear Power Experience"?
l 15 A
Yes, we did.
l 16 Q
I guess then my question is, in 17 addition to all of those, during the period of time 18 that you were head of the training department, 19 were you aware that there were out there somewhere 20 other publications containing information about 21 transients at plants that were not bein,g distributed O
22 to the training. department?
23 THE WITNESS:
Please read that back.
24 (Record read back.)
,A i
\\._)
25 A
I simply don't understand the generality l
1 Zochman 349 v) 2 of your question.
1 3
Q I subscribe to Time.
I know there is a 4
publication called Newsweek.
I choose not to ggg 5
subscribe to Newsweek.
6 Have you got.it?
7 A
I'm with you.
8 Q
Were there publications out there that 9
had information in them about transients at other 10 plants that you knew of but knew that you were not 11 receiving?
12 A
I don't recall.
(~')
13 Q
During the period of time that you were V
14 in charge of the training department, did either you 15 or, at your direction, Mr. Beers or Mr. Brown try 16 to make a comprehensive review of all publications 17 that might have information about transients at 18 other plants and take steps to be sure that you 19 received all of those publications?
20 A
Let me just see if I understand what 21 you are saying.
9 22 Did any one of us make, if you would, 23 a comparison list between all those that were l
24 published versus those we received?
l
(~'T Nj
\\
l 25 Q
.Let's put it this way:
l l
l l
1 Zochuan 350
[')
2 Did you ever say to Mr. Brown or
\\_,i 3
Mr. Beers, "Look, let's go out and find out all 4
of the publications that there are that have
{lg 5
information about transients at other plants.
Let's 6
take a look at that list and let's then make a 7
decision as to which ones we want to take or whether 8
we weint to take them all"?
9.
A There was a period of time when we were 10 aware of other publications, and that is how we 11 got on distribution for some of these.
I know 12 there was a period of time we discussed those that gS 13 we were aware of in making some of those selections.
O 14 That is the best of my recollection relative to your 15 question.
16 Q
You are not aware now as you sit there 17 of any situation where you consciously decided not 18 to obtain copies of a particular publication that 19 contained information about transients at other 20 plants?
l 21 A
Not to the best of my recollection.
9 22 Can we take a break?
23 Q
All right.
24 (Recess taken.)
I~\\
(/
25
1 Zachann 351
(
2 BY MR. FISKE:
3 Q
Mr. zachman, was there a procedure 4
within the training department to document the ggg 5
fact that the publications that we were discussing 6
before the break had been reviewed?
7 A
There is not a procedura as such.
8 However, if it was on a distribution 9
list, the signature of the person receiving it would 10 be there.
11 Q
In other words, if it was distributed 12 to someone, was it distributed with a list of people 13 so that someone crossed his name off and then it 14 went to the next person kind of thing?
15 A
You usually signed your initial and 16 then passed it on, yes.
17 Q
Was the initial to indicate that the IO person had actualJy read the document, or was 19 it simply a question of crossing his name off so 20 it could go on to the next person?
21 A
It was simply that the person received O
22 it.
It didn't necessarily imply that he read it.
l l
23 Q
I guess what I am asking, did you have 24 a procedure within the training department to document 25 the fact that these various publications that came
{'
a l
r l
1 Zochann 352 t
a f*
('
2 Anto tha training department containing information 3
about transients at other plants had,,in fact, been i +
4 reviewed?
/
gg
- 5 A
To the best of my recollection, we
' 6 di_dn't have a procedure.that formalized,that review, 7
if that is what you ard;asking.
8 Q
Yes.
9 A
That is not to say we didn't review 10 them.
s
/
11 Q
In addd: ion to receivin'g' these 12 publications, did you' reach out to other utilities 13 directly to make' contact with them to try to find out 14 information about transients at their plants?
15 A,
There were times that not just necessarily l
16 myself but in'dividuals' in our training department 17 did ca11'other plants to discuss transients that i
18 happened at their plant.
19 Q
This' would be again after you had 20 1 earned of that transient fron some other source?
21 A
That'would have been the normal case.
O
'22 Q
Did you have any procedure whereby people 23
' in the training department at Met Ed would, on a 21 periodic basis, contact other utilities to find out 25 whether or not the're had been transients at those
/
.,r.
- ~ - - - - -
- ~ ' '
' - ~ ~
s s
s.
1 Zachman 353 i'
L
()
2 utilities that might be of interest to Met Ed?
3 THE WITNESS:
Please repeat that.
4 (Record read back.)
ggg 5
A There was not a procedure that dictated 6
that.
Not saying that we didn't do that on a 7
periodic basis.
8 Q
I guess I don't understand the answer.
9 Are you saying you did do it or didn't?
10 A
There wcs no procedure.
That'is no,t to 11 may we didn't on occasion call other plants about 12 transients at their plants.
13 Q
Do you understand the thrust of my r
14 question?
I am not asking you whether, if you i
l 15 read a report' abbut' a transient at some other plant, 1
^
16 somebody in the training department might call 17 up somebody at the' utility to get more- :
18 information about the transients beyond what was 19 in the document that you had read.
I understand i
l 20 you have said that you did that from time to time.
l 21 I am asking whether there was, on a h
22 periodic basis, people from the training department
-t 23 would call other utilities simply to find out
~ '
24 whether there were transients that had occurred O
25 at that plant that might be of interest to Met Ed.
4
1 Zechmsn 354
/$
2 A
To the best of my recollection, there s
~
3 was not a procedure which, if I understand your
~
4 question correctly, it was not a procedure 5
such that on a frequent basis or on an infrequent g
6 basis, that individuals would consciously call 7
another plant to constantly keep in contact with what 8
they were doing or what transients they may have 9
had, if that is the understanding of your question.
10 Q
Are you familiar with the owners group 11 and the users group meetings held at Babcock & Wilcox?
3 12 A
I'm familiar with the terms and the 13 understanding that there are those groups.
14 Q
Were you aware of the existence of those 15 groups before the accident?
16 A
Yes, I was.
17 Q
Did you understand that these were 18 meetings under the auspices of B&W of representatives 19 from various utilities that had B&W reactors?
20 A
What were the names of the two groups
,} O 21 again?
22 Q
The-owners group and the users group.
23 A
Yes, I was aware of that.
n l
l 24 Q
Did you yourself ever attend any of l
[\\
25 those meetings?
i i
(
1 Zochamn 355 2
A To the best of my recollection, I did 3
not.
4 Q
Let's take the owners group first.
g 5
Did the same group of people from 6
Met Ed go to the owners group meetings as 7
went to the users group meetings?
0 A
I have no recollection who the members 9
of those groups were any longer.
10 Q
Did you know at the time that they were 11 different people that attended the two different types 19
~
of meetings?
l 13 A
What time frame are we talking about?
I4 Q
'77,
'78,
'79.
15 A
I don't recall.
16 Q
Did anyone from training ever attend 17 any of those meetings?
O A
Not to the best of my recollection.
19 Q
Did you understand, prior to the accident, 20 that one purpose of these meetings was to discuss 21 operating experiences at the various plants that 22 had D&W reactors?
A I had that general understanding.
l 24 Q
Did you have an understanding prior to 25 the accident that at least one part of these meetings
1 Zachnen 356
/~)
2 was that
.there was a procedure whereby x_/
3 representatives of utilities would speak directly 4
to the other utility representatives about the ggg 5
operating experiences at their plants?
6 THE WITNESS:
Please repeat the 7
question.
8 (Record read back.)
9 Q
Did you understand that one part of 10 these meetings was to give representatives that 11 were there from the various utilities an 12 opportunity to hear on a first-hand basis from 13 repre s ent ative s o f other u,tilities about a
14 transients and other incidents at their plants?
15 A
To the best of my recollection, that 16 was my understanding.
17 g
Did you consider at the time that it 18 would be valuable to the training department to 19 have the benefit of the information that was 20 communicated to the Hot Ed representatives at those 21 meetings?
O 22 A
I believe that our representatives were 23 at that meeting and would be responsible to provide l
24 the training department with material that they
(~)'N
\\-
25 deemed important for the training department to use
1 Zachann 357 in training.
3 Q
Did you have any procedure whereby 4
the people that went to these meetings would report ggg back to the training department on the information 5
0 that they had learned from the other utility 7
representatives?
8 A
Are you asking did the training department 0
have a procedure?
10 Q
Or did Met Ed have a procedure.
II A
Not to the best of my recollection.
12 To the best of my recollection, there was no
/~N procedure.
That doesn't negate the fact that N.
14 they would still distribute that information to us if they deemed appropriate.
l Q
From the point of view of the training I
department, it all depdnded on whether or not the 18 people that went there decided to tell you about I0 l
it or not, is that correct?
l A
To the best o f my recollection, that is 21 correct.
O 22 Q
From any of the sources that we have 23 just been discussing, Mr. Zechman, at any time prior 24 to March 28, 1979, were you aware that there had O)
(_
25 been a transient involving a stuck open or failed l
l l
1 Zschman 358
("}
2 open pilot relief valve at the Davis-Besse plant of
%.J 3
Toledo Edison in the fall of '77?
4 A
You are asking me personally?
ggg 5
Q Yes.
6 A
I have no recollection of that.
7 Q
I would like to go back to the FSAR 8
section 13.2.2 9
A Wait, can I go back?
Can I have that 10 question again?
I may have not concentrated.
11 THE WITNESS:
Mr. Reporter, what was 12 that previous question?
13 (Record read back.)
v 14 A
The only time I had knowledge of that 15 was post after the accident when Mr. Brown 16 informed me of an LER printout that had that on it.
17 I wanted to make sure I answered that to the best 18 of my recollection.
19 Q
In other words, some time after the 20 Three Mile Island accident, Mr. Brown came to you 21 with an LER printout of the Davis-Besse accident?
O 22 A
Yes.
It was probably under discussion 23 at that time and he made me aware of the printout.
24 Q
Did you ask Mr. Brown whether he had n\\ /
25 had that printout before the accident?
1 Zachman 359
[)
2 A
I don't recall either way.
%)
3 Q
Was it of any interest to you at 4
that point as to whether Mr. Brown had reviewed ggg 5
that LER before the accident?
6 A
I don't recollect what my thoughts 7
were at that time.
8 Q
I think when you were going through the 9
list of different types of documents that the 10 training department received concerning transients 11 at other plants, one of the types of documents that 12 you said you were on distribution for was LERs, is 13 that correct?
14 A
That is correct.
We were on distribution.
15 Q
Do I understand correctly that the LER 16 that Mr. Brown showed you after the accide nt 17 was the type of LER that you were on distribution for?
18 A
No, sir.
Mr. Brown received direct 19 to him from the NRC an LER printout which is a l
20 summation, transient summation.
That's what he 21 showed me.
O 22 g
After the accident?
23 A
After the accident.
24 Q
How was that different from the 25 LER that you received in the regular course of the 1
1 Z3chann 360 (j)
(
2 training department's business in distribution?
3 A
To the best of my recollection, they 4
are a little bit more definitive in scope.
g 5
Q Which?
6 A
The LER that we were on distribution 7
for.
Again, repeating that, we didn't receive 8
them all.
~
9 Q
When you say you didn't receive them 10 all, were you aware of the fact that prior to the 11 accident, that you-were not receiving them all?
12 A
What period of time are we talking about (d
~
13 now?
14 Q
Any t ime.
15 Did it ever come to your attention 16 at any time before-the accident as head of the 17 training department that you were not receiving all 18 the LERs?
19 A
I don't recollect either way.
20 Q
Well, you just said a moment ago sort 1
21 of as an add-on to your last answer; you said you O
22 didn't receive 'all.
23 I am asking you whether, at any time 24 before the accident, you became aware of the fact 25 l
that you were not receiving all the LERs.
I i
1 Zachnen 361 s
/
)
2 A
There were times when we would be
\\_/
3 missing one and we would -- if we were reading an 4
LER printout and saw one and went and tried to ggg 5
find the LER, there are times we would have made 6
that kind of discovery.
7 Q
Have you finished your answer?
8 A
What I am saying, I don't recall us 9
making a check and balance at all times to see 10 we got every one.
11 Q
But on those occasions when you were 12 reviewing the printout and you found that you were
(~N 13 missing an LER, did you then take steps to get it L.)
14 or did you just say, "Oh, well, we will skip that 15 one"?
16 THE WITNESS:
Repeat the question.
17 (Re cord read back. )
18 A
To the best of my recollection, 19 there was a conscious e'f f o rt to find out if we had 20 known it was missing.
21 Q
Is it fair to say that either as a O
22 result of the direct regular procedure where these 23 LERs came to you through distribution or in the 24 followup procedure when you noticed that maybe you O)
\\'-
25 hadn't gotten one, that by and large you got the LERs
1 Zschmen 362 fN 2
on a regular basis?
U 3
MR. MacDONALD:
What do you mean by 4
"by and large"?
gg) 5 Q
In all but a very few cases you 6
eventually did receive the LERs?
7 A
Yes.
8 Q
To put it another way, can you 9
today quantify the frequency with which you 10 didn't get LERs either as a result of the 11 regular distribution or as a result of the 12 followup process if you noticed a particular one 13 was missing?
)
'~#
14 A
I don't know that I can put a quantity 15 on that frequency.
16 Q
Did you ever conclude at the time you 17 were running the training department that that 18 frequency was high enough to be a matter of any 19 conce rn to you?
20 A
To the best of my recollection, that 21 wasn't a major problem.
O 22 Q
I guess we can go back to the FSAR.
23 I think we were looking again -- I was about to look 24 at the description of the Met Ed operator 25 requalification program.
1 Zachacn 363 (J) 2 Do you see that item D -- I'm sorry, item E 3
4 MR. MacDONALD:
What page is this?
)
5 MR. FISKE:
13.2.7.
13.2.2.2.1, the 6
topics to be covered, item E is " Abnormal 7
and Emergency P.rocedure Review."
8 Q
Do you see that?
9 A
Yes.
10 Q
It is a fact, isn't it, part of the 11 requalification training program was training on 12 emergency and abnormal procedures?
O 13 A
That is correct.
\\J 14 Q
And this training was classroom 15 training, was it not?
16 A
well, there is a reference on the bottom 17 it can be given by shift foremen or shift supervisors.
18 Q
Where does it say that?
19 A
Right here, and down here.
20 Q
You mean the footnote?
21 A
Yes.
O 22 Q
Was it part of the procedure at Met 23 Ed before the Three Mile Island accident to have the 24 training department review draft emergency and
(, )
25 operating procedures before final procedures were
1 Zachann 364
/^)
2 adopted?
V' 3
A Not to the best of my recollection.
4 Q
Did it ever occur to you while you were ggg 5
head of the training department at Met Ed that it 6
might be useful to have the training department 7
perform that function?
8 A
I don't recall having thought of that 9
either way.
10 Q
As head of the training department, 11 did you think it was important that the procedures 12 be understandable to the operators?
x 13 A
Certainly as head of the training
(-^A 14 department, I would feel that the procedures should 15 be understandable.
16 Q
Did you feel it important that they 17 not be confusing?
l 18 A
well, that's kind of an ambiguous term.
j 19 What is confusing to some people may not
(
20 be confusing to others.
I would say they would have i
21 to be written as well as they can be.
O 22 Q
In order to be an instructor on the 23 p ro ce du re s, I assume you, talking about you personally 24 now, Mr. Zechman, during the time that you did that (D
\\/
25 MR. MacDONALD[
Maybe --
1 Zechman 365 2
MR. FISKE:
I will back up and ask the 3
question.
4 Q
Did you personally conduct training ggg 5
on procedures?
6 A
To the best of my recollection, I did not 7
personally train on procedures.
8 Q
As part of your own training to become 9
a licensed operator, did you study the procedures?
10 A
Yes, I did.
11 Q
In embarking on the study of the 12 procedures with a view t.o potentially have an
's 13 operator's license, did you believe it was 14 important to you that you understand the procedures?
15 THE WITNESS:
Please repeat the 16 question.
17 (Record read back.)
18 A
Certainly as one that is going for a l
l 19 license and is going to utilize the procedures, 20 I would want to understand the procedures.
l 21 Q
Focusing on the situation right up 22 to the time of the accident, based on the training i
23 that you had done up to that time, did you believe 24 that you understood the procedures then?
1 25 A
The fact that I was still studying
1 Zachmen 366 2
indicated that I was still in a mode of training.
3 certainly I didn't have memorized every procedure.
4 Q
I am not asking you whether you memorized 5
it, but can you tell us today whether there was 6
any procedure when you went through it as part of 7
your training that when you went through it, you 8
said to yourself, "I don't understand this"?
9 A
Oh, I think in the course of studying 10 procedures or any subject matter of complexity, 11 there are times when you have a question that you 12 need to ask for interpretation.
(~N 13 Q
Were these questions satisfactorily
(_)
14 answered?
15 A
To the best of my recollection, they were.
16 Q
Again switching to your supervisor -- put 17 on your supervisor of training hat for a moment 18 as opposed to your student hat, and I would ask you 19 in te rms of the approach of the training department 20 in 1978 and 1979 with respect to the training 21 on procedures, was there, in the classrooms when O
22 training was -
when the procedures were being 23 taught, was there give and take back and forth 24 between the instructors and the students, questions O) i\\/
25 asked and answers given?
l 1
Zachnen 367 l
(-}s 2
A To the best of my recollection, there 3
was.
4 Q
Was that give and take between the ll) 5 students and the instructors an important part of 6
the training on these procedures?
7 A
That was one -- in the classroom 8
situation, that certainly was an important part 9
of their training.
That wasn't -- well, I have 10 answe re d.
11 Q
And this give and take in the classroom, 12 I take it was oral back and forth?
r~x.
13 A
That is not to say we didn't
- 7. s k
(
%/
14 questions on written tests relating to the 15 procedures.
16 Q
Apart from that, apart from whatever 17 was done on written tests, the questions that 18 students would have during class about what is 19 this particular procedure or what do they do in a 20 particular situation, the answers that the 21 instructors would give, that would all be in oral O
22 dialogue, is that correct?
23 A
For the most part.
24 Q
The students didn't submit written
(
u-25 questions to the instructors, did they?
1 Zo chnen 368
[)
2 A
No.
The instructors are teaching, s.-
3 give and take would be in an oral mode.
4 Q
What steps were taken to communicate ggg 5
the benefits of that oral dialogue back and 6
forth, the questions and the answers, to the 7
people that were not at that particular lecture?
8 A
As I recollect, there were different 9
modes to handle that situation.
There were 10 times when in the course of requalification, 11 if a care package was sent out involving 12 procedures, there may have been a handout that
(~';
13 went along with it or a copy of a lesson plan.
'w) 14 There were various modes, the way that was handled.
l i
15 Q
I am asking you not about a handout or 16 a lesson plan.
17 I am asking about the situation where, l
l 18 during class, a particular emergency procedure is 19 being discussed; it's the subject of that l
20 particular day's lecture.
21 During the course of the lecture or 9
22 during the course of the class, several students 23 in the class have questions for the instructor about 24 various aspects of the procedure, what would a (s) 25 x
particular section mean, what would you do in a
1 Zachnen 369 f~}
2 particular situation, questions of that type; and v
3 the instructor then gives oral answers to each of 4
those questions.
The class is over, and everyone lll 5
leaves, and there is a group of people that were 6
supposed to be in attendance at that lecture who 7
for one reason or another were not.
8 I am asking you what procedure was 9
there to give those people who missed the class 10 the information that was contained in the oral 11 dialogue back and forth between the students and 12 the instructors that occurred during that class r3 13 session.
NY 14 MR. MacDONALD:
You are asking whether 15 there was a formal written procedure where 16 the instructor had to do something or 17 whether there was a method?
You are asking a 18 hypothetical question.
19 MR. FISKE:
I hardly think it is 20 hypothetical.
21 MR. MacDONALD:
He didn't teach l
22 procedures.
1 23 MR. FISKE:
He was in charge of the 24 training.
If he wants to say he doesn't i
T
'J 25 know, that is fine.
1 ZochmEn 370 f~T 2
MR. MacDONALD:
I am sure he is going d
to give you the answer to the best of his 3
4 recollection, 5
MR. FISKE:
That is all I am asking ggg 6
him to do.
7 A
I don't recall.
8 Q
As part of the training that was done 9
on eme rgency procedures, were the s tu'de n t s told what 10 to do if they, in the course of a transient, ran 11 into a situation that wasn't covered by any 12 procedure?
r~
13 MR. MacDONALD:
May I hear that question.
- !'v 14 (Record read back.)
15 A
I don't recall.
16 Q
You mean is it your answer, Mr. Zechman, 17 you can't tell us today whether in the training 18 program the operators were taught to deal with 19 situations that do not fall within a specific 20 emergency procedure?
21 MR. MacDONALD:
In the course of abnormal O
22 emergency procedures review we are talking 23 about?
. 24 MR. FISKE:
I will expand it to any h
s/
25 place.
1 Zachann 371
[j'N 2
THE WITNESS:
Please repeat the question.
\\,
3 (Record read back.)
4 A
There are times in our training programs g
would take hypothetical things happening and 5
we 6
then work through utilizing the procedures that 7
would apply to our -- in other words, we t
8 would -- there were times they would take a 9
hypothetical situation and propose it to the 10 class and then discuss what they think would happen 11 and what systems would apply, what procedures they 12 would use.
($
13 There are times that kind of a
(__/
14 discussion has taken place.
15 Q
Were these hypothetical situations 16 that were discussed in the class situations as to 17 which a particular procedure was, in fact, applicable?
18 A
I don't recall specific situations, so 19 I can't answer your question directly.
20 Q
I guess what I am getting at and 21 maybe you can't answer it any better than you 9
22 already have, but I will give it one more shot I
23 am really talking about a situation where, in the 24 course of a lecture on a procedure or maybe more 25 than one procedure, somebody in the class puts up his
1 Zechman 372 p)
(
2 hand and says, "Well, that is all well and good.
3 I understand if this procedure applies, I do this.
4 I understand if that procedure applies, I do that, lll 5
but what am I supposed to do if I'm in the middle 6
of a transient and I can't figure out which 7
procedure to use?
What am I supposed to do then?"
O A
Certainly there is guidance for that.
9 They are to call their immediate foremen.
10 Q
An d le t him decide it?
11 A
Well, no.
He would look at the situation 12 and have to make a determination, evaluate the (s) situation.
If he needed additional help, he would 13 14 call for additional help to evaluate the situation 15 on how to proceed.
16 Q
Let me read you a question and answer l
1 that comes out of the testimony that you gave be fo re l
10 the so-called Rogovin Commission.
I am referring 19 to question and answer at page 75 of that transcript.
20 Have you got page 75 in front of you?
21 A
Yes, I do.
O more question here on 22 g
ny have one 23 diagnosis o f of f-normal behavior of the reactor.
24 "Is there some portion in the licensed i,_)
V 25 operator's training as well as the requalifications l
l
1 Zachacn 373
()
2 in which he is exposed to lectures or work in the 3
area of diagnoses of off-normal conditions, or is 4
it ggg 5
" Answer:
No, sir."
6 were you asked that question and did you 7
give that answer?
8 A
I don't recollect that question at this 9
time.
10 Q
Do you have any reason to believe that 11 this transcript that you have in front of you 12 doesn't accurately reflect the question that you
(~]
13 were asked and the answer that you gave?
\\_/
14 A
This is a transcript that was taken at 15 a deposition I gave.
You are showing me a piece of 16 paper of that deposition, and I'm just saying I have 17 no recollection at this time of that question being 18 asked.
19 Q
That is the question I asked you a moment 20 ago and you answered.
I am asking a different 21 question, which is, as you sit here today, do you 9
22 have any basis for telling us that the transcript 23 does not accurately reflect the question that you 24 were asked and the answer that you gave?
\\'
25 A
I believe I just answered your question,
1 Zachacn 374
('}
2 a similar type question, my recollection as of
'\\_J 3
today.
4 Q
That isn't what I am asking you, either.
ggg 5
I am just simply asking you whether, 6
as you sit here today, you have any basis for telling 7
us that the transcript that you have in front of you 8
of the deposition you gave on September 14, 1979, 9
does not accurately reflect the question you were 10 asked and the answer you gave on that day back in 11 1979.
12 A
y m saying I don't recollect this question 13 being proposed any longer.
%. ]
14 What I have here is a transcript of my 15 deposition.
It's a piece of paper that supposedly 16 says what I said at that time.
17 Q
That is as far as you are prepared to go?
18 A
I don't know if I can go any further.
l l
19 Q
Would you consider that off-normal 20 conditions would include a condition that was not l
l 21 covered by any specific procedure?
22 A
I suppose the term "off-normal" could 23 be interpreted many ways, sir.
24 Q
How did you interpret it when you O
l
(,,,
25 answered the question "No"?
l l
1 Zachacn 375
(~)
2 A
I don't recollect the ques tion today,
V' 3
so how could I recollect what my thought was at 4
that time?
llg 5
Q Well, in terms of your experience as head 6
of the training department at Met Ed, is a situation 7
in which no procedure applies a normal condition?
8 A
I would think not.
9 MR. FISKE:
Well, I will be going into 10 a new topic, so I think we might as well stop 11 at this point.
12 (Time noted:
3:50 o' clock p.m.)
13 k(m/~}
RICHARD W.
ZECHMAN 14 15 Subscribed and sworn to 16 before me this day i
i 17 of 1982.
18 I
(
19 20 21 22 l
23 24
((s 25
1 376 i
(s)
CERTIFICATE 2
STATE OF NEW YORK
)
3
- ss.:
COUNTY OF NEW YORK
)
4 I,
ROBERT CAPUZELo
, a Notary 5
l Public of the State of New York, do hereby I
certify that the continued deposition of 4
RICHARD W.
ZECHMAN was taken before l
l me on March 12, 1982 consisting of pages 273 through 376 I further certify that the witness had i
11 i
been previously sworn and that the within
. /]
transcript is a true record of said testimony; G
13 a
am not connected by blood or 14 marriage with any of the said parties nor i
la, i
interested directly or indirectly in the matter 1G i
in controversy, nor am I in the employ of any 17 i
of the counsel.
t 18 IN WITNESS WHEREOF, I have h eunto set my 19 hand this day of
//, "LA t
,1982.
20 i
i
(
21 O rd bad ROBERT CAPUZELo /
- \\
g
/
L) 24 25 l l
i I
..