ML20072H895
| ML20072H895 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 03/25/1982 |
| From: | Zechman R GENERAL PUBLIC UTILITIES CORP. |
| To: | |
| References | |
| TASK-*, TASK-01, TASK-03, TASK-04, TASK-1, TASK-11, TASK-3, TASK-4, TASK-GB NUDOCS 8306290801 | |
| Download: ML20072H895 (116) | |
Text
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524 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK O
............. _... _.. -x GEEERAL PUBLIC UTILITIES CORPORATION, a
{
JERSEY CENTRAL POWER & LIGHT COMPANY, METROPOLITAN EDISON COMPANY and a
PENNSYLVANIA ELECTRIC COMPANY, y,
Plaintiffs, 80 CIV. 1683 (R.O.)
-against-THE BABCOCK & WILCOE COMPANY and J. RAY McDERMOTT & CO.,
INC.,
a Defendants.
...... _ _ _x Continued deposition of Richard W.
- Zechman, O
taken by Defendants, pursuant to adjournment, at the offices of Davis, Polk & Wardwell, Esqs.,
One Chase Manhattan Plaza, New York, New York, on March 25, 1982 at 10:00 o' clock a.m.,
before Catherine Cook, a Shorthand Reporter and Notary Public within and for the State of New York.
[
y m.
l DOYLE REPORTING. INC.
B306290801 820325 PDR ADOCK 05000289 CERTirito sTENoTYPE REPORTERS l
[
T PDR 3,,g,,,,,,,,
,y,,,,
WALTER SHAPIRO. C.S.R.
New Yong. N.Y.
10017 CHARLES SHAPlRO, C.S.M.
YeksPMons 212 - 867 8220
1 525
/O 2
Appe a rance s :
Q,]
3 KAYE, SCHOLER, FIERMAN, HAYS & HANDLER, ESQS.
Attorneys for Plaintiffs 4
425 Park Avenue New York, New York O
BY:
ANDREW MacDONALD, ESQ.,
6 of Counsel 7
8 DAVID POLK & WARDWELL, ESQS.
9 Attorneys for Defendants One Chase Manhattan Plaza 10 New York, New York 11 BY:
KAREN E. WAGNER, ESQ.,
-and-12 ROBERT B.
FISKE, ESQ.,
of Counsel m
13 f
Present:
14 SUS 7.N HANSON 15 16 17 l
1 oOo 18 19 l
20 l
l 21 RI CH ARD W.
Z ECHMAN, having been O
22 previously duly sworn, was examined and continued 23 to testify further as follows:
24 EXAMINATION BY
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'~
25 MR. FISKE:
526 Zochann G
1 Q
Mr. Zechman, you realize that you continue
()
under oath this morning?
3 A
Yes, I do all day today, certainly.
4 Q
In some testimony that you gave at the end of the day yesterday, you said that operators had been 6
trained to look at, among other things, pressurizer 7
level in order to terminate high pressure injection.
8 MR. MacDONALD:
Are you asking what he g
tes tified?
10 MR. FISKE:
It is a preliminary question.
11 A
That wasn't all inclusive.
That was one of 12 the things, we maintained pressure and level of high pressure injection.
That's not all inclusive.
14 g
I don't think you lis tened to the question.
15 question was,didn't you testify yesterday that The 16 in determining whether to terminate high pressure 17 the injection after it had come on in the course of 18 transient, one of the things the operators would do 19 would be to look at pressurizer level?
20 A
One of the things we did was look at pressurizer level but what I am saying is that that is 22 not the point of termination of high pressure injection.
23 Q
The question was wasn't it one of the Os 24 things that the operators looked at?
25 t
527 l
Zschaan 4
1
/~h A
To try to maintain level.
2 Q
Right.
Didn't you testify yesterday that 3
you believed that the pressurizer level would be an 4
indication of the inventory in the system?
A That's correct.
6 Q
In the training that you did in the 7
Training Department at Met Ed, did you tell the 8
operators that they could assume that pressurizer 9
level was, in fact, an accurate indication of system 10 inventory?
11 MR. MacDONALD:
You are talking prior to 12 the accident?
r-(]/
13 MR. FISKE:
Yes.
14 Prior to the accident our training program A
15 reflected the fact that to maintain pressurizer level 16 insured inventory in the RC, proper inventory in the 17 right RC, yes.
18 And that looking at pressurizer level would Q
19 te11the operators accurately what the system inventory 20 was?
21 O
That is what our training at both B&W and A
22 our Met Ed program indicated.
23 Q
Did you feel that as head of the Training 24 Department that it would have been important for the Q(._ /
25 i
4
I 528 Z3chnon 5
1 b
\\/
2 operators to know in the training that you gave them at Met Ed if there were circumstances under which in 3
of the transient pressurizer level was not 4
the course G
an accurate indication of system inventory?
5 6
A That did not occur to me based on our 7
training.
8 Q
I think you have testified several times not aware prior to the accident 9
yes te rday that you were level of any circumstances under which pressurizer 10 11 would not be an accurate indication of system inventory.
MR. MacDONALD:
I object.
I have no problem--
12 if you think you have to clarify something but j
13 going back and having him trying to remember what 14 tes tified yesterday is very dif ficult.
he 15 MR. FISKE:
I will rephrase it.
16 17 Q
Is it correct that in the training you gave told the operators that pressurizer 18 at Met Ed, you level was an important indication of system inventory?
1 19 A
In the training of our operators both at 20 21 Met Ed and at the simulator, level in the pressurizer ggg told them 22 was focused on as long as we maintained -- we an indication long as we maintained level that was 23 as of satisfactory inventory.
(~
24 I
I think you said yesterday that you were not Q
25 I
529 Zachnon 1
O 2
aware prior to the accident of any situation in which Pressurizer level had increased while pressure was 3
decreasing.
4 MR. MacDONALD:
Are you asking that again?
G 5
MR. FISKE:
I am stating that as a 6
Preliminary statement and I will ask you today 7
8 as a fresh question, doesn't that, in fact,raflect your testimony?
9 10 A
Prior to the accident?
11 Q
Yes.
12 A
I said I could not recollect at this time in our training that I observed pressurizer 13 any time decreasing during normal 14 level increasing or pressure 15 operations.
to the 16 Q
Is it your testimony that prior there could be 17 accident that you didn' t understand that circumstances under which pressure dropped creating 18 saturation or boiling and in that situation pressurizer 19 level would increase?
2C A
Never occurred to me prior to the accident.
f lll 21 22 Q
To your knowledge, did anyone in the the accident?
Training Department know that before 23 not that I To the best of my recollection, A
(~'h 24 l
V 25 was aware of.
f
530 l
Zochman 7
1
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Q Let me read you from the testimony given 2
in this case by Ronald J. Toole, an employee of GPU, 3
and let me ask you preliminarily, did you know Ronald J.
4 Toole before the accident?
ggg 5
A Yes.
6 What was his position at Med Ed?
Q 7
A Prior to the accident?
8 MR. MacDONALD:
You are talking about 9
immediately prior?
10 n7, FISKE:
Let's say a year or two before 11 the accident, 1978,
'79.
12 A
I don't recall what his exact position is m(,)
13 before he became superintendent, I just don't recall at 14 this time.
I recall that he worked in Engineering.
15 don' t. recall what his position was.
I 16 At some point he became superintendent?
Q 17 A
Yes.
(
18 Q
On which unit?
19 A
Unit 1.
20 Q
What are the responsibilities as you 1
understand them of the superintendent of either Unit h
2 22 or Unit 27 23 the They have the total responsibility for A
(g
()
24 operation and administration of their unit.
- conduct, 25 a
Z3chann 531 8
1 O
t 1
include any supervision or 2
Q Would that
'~
training that was supervisory responsibility for the 3
4 given to the operators?
O He had overall responsibility for everything 5
A 6
for that unit, including the training.
Toole was examined in this case back 7
Q Mr.
8 in July of 1981 and I would like to read just several from his deposition.
If you want 9
questions and answers I am reading from 10 to look at them, you are welcome.
11 page 803 and 804.
" Question:
Was it your belief in 13 I
(~)
September of 1977 that a rise in pressurizer level
(/
13 accompanied by a simultaneous drop in reactor coolant 14 could not occur when reactor coolant pumps 15 pressure fuel in the core of were in operation and there was 16 17 the plant?
"Mr.
Glassman:
If you recall.
18 l
" Answer:
I don' t remember.
I 19
" Question:
Was it your understanding in 20 September of 1977 that the formation of voids in the 21 j
(l) system in the reactor coolant system would displace
~
22 inventory which would then migrate to the pressurizer?
23
" Answer:
I believe I testified yesterday
['N 24
\\_)
that if voids were to occur in one place in the vessel 25 o
I 532 Zechman 1
O other than the pressurizer you would force liquid into 2
3 the pre-surizer level.
4
" Question:
This was an understanding that O
you had in September of 19777 5
don't remember if I did or didn't.
6
" Answer:
I 7
" Question:
Is this an understanding you 8
had before the accident at Three Mile Island in March 9
19797 don' t know that I ever addressed 10
" Answer:
I 11 it that way, but I assume that I knew if I put a s team that it 12 bubble in one place and raised the pressure, 13 would go on someplace else because th a t is, in fact, 14 what you did with the pressurizer.
l Did Mr. Toole ever communicate to you, or 15 Q
his in the Training Department, 16 to your knowledge anyone 17 understanding of the effect of voids in the system on 18 level in the pressurizer as he described it in the 19 testimony that I just read to you?
T personally do not recall ever discussing 20 A
21 that subject with Mr. Toole.
ll) testified previously, Mr. Zechman, 22 Q
You have 23 and this is a preliminary question, that you understood that if pressure dropped in the course of a transient
()
24 reactor coolant that could produce boiling in the l
25 that 3
,r--
~
l Z3chann 533 10 1
[)
system.
\\_e 2
testified that I understood theoretically A
I 3
that if pressure dropped, that could happen.
4 the familiar with the concept --
Q You are
)
as it is used with term " saturation,"are you not, 6
l respect to nuclear reactors?
7 A
I understand the term " saturation" in terms 8
trained, whether it was the pressurizer of what we were 9
or the steam generator.
10 isn't saturation what Q
In layman's terms, 11 occurs when the water in the reactor coolant system 12 to steam?
()
or in the pressurizer turns 13 refers Saturation -- the term " saturation" A
14 at which water to the point -- at a given temperature 15 will turn to steam.
16 Q
That is the same concept, is it not, to 17 have the water boil?
18 A
That is the same concept as the water 19 changes phases.and boils.
20 You testified yesterday that Mr. Floyd was Q
lll the superintendent of -- he was 21 in charge of operations 22 at Unit 2.
23 recollection was that he A
To the best of my O
24 supervisor of operations.
was 25 i
,,--c
534 Zechman 1
O What were his responsibilities as supervisor 2
Q of operations?
3 He had the responsibility for supervising 4
A and directing the operations of -- and directing the i
5 6
operators and shift foremen and shift supervisors of i
7 Unit 2.
8 Q
It is a fact, is it not, during the period training.of operators was being 9
'77,
'78 and '79 some themselves?
done by the operations people 10 11 A
It certainly is true that they also had training. It is true even on 12 a responsibility for some they were provided training among their own shifts.
\\
13 shift 2,
Mr.
As supervisor of operations of Unit 14 Q
for Floyd would have had an overall responsibility 15 whatever amount of that kind of training went on?
16 MR. MacDONALD:
Are you asking if he did, 17 18 what Mr. Zechman's recollection is?
MR. FISKE:
Yes.
19 As you understood what his position involved?
20 Q
A Could you repeat tha t?
21 qgg (Question read) 22 for training He would have responsibility 23 A
24 that he directed.
That's not to say while the shift foreman, while on shift may have conducted training on 25
535 Zechman 1
(*
of.
2 his own that Jim wouldn't have been aware s
I am not saying that Mr. Floyd did personally 3
Q 4
all the training.
I am asking isn't it a fact his O
position as supervisor of operations included among 5
for other things overall supervisory responsibility 6
whatever training was going on at Unit 2 by the operation s
.7 8
people?
Each of the supervision personnel had a 9
A responsibility as a supervisor -- had the responsibility 10 responsibility of training their 11 and shared in the That's part of their responsibility.
12 personnel.
G 13 Q
Mr. Floyd has also given deposition testimony I
case within the last month and I would like to 14 in this 166 and 167 of Mr. Floyd's testimony 15 read you from pages Do you have that in front of you?
16 166 in front of me.
17 A
I have page line 4, Starting at the top of the page, 18 Q
it your understanding that a pressurized 19
" Question:
Was water reactor was not intended to operate at saturation 20 in a primary system outside of the 21 temperature lll 22 pressurizer?
All my questions relate to your understanding prior to the answer.
23 Do you mean all temperatures of
" Answer:
()
24 the water in the reactor coolant system should be below 25 H
I Zochsan 536 13 1
saturation temperature?
f')
V I mean that water should not be
" Question:
3 in a bulk boiling mode.
4 Yes, I knew that before the
" Answer:
g accident.
" Question:
Do you know where you learned 6
7 that?
8
" Answer:
No.
" Question:
Do you have any understanding 9
10 of what would happen in the primary system of a pressurized water reactor if the water had reached a 11 12 in the primary system oatside of bulk boiling stage V
13 the pressurizer?
l 14
" Answer:
Yes.
15 What was your understanding would'
" Question:
16 1
be the results?
17
" Answer:
Net steam formation, i
" Question:
Did you have any understanding 18 19 steam formation would have as to what ef fect that net 20 onthe reactor coolant system,if any?
O 21
" Answer:
Yes.
that understanding?
22
" Question:
What was 23 As the size of the new steam
" Answer:
O 24 the pressurizer level would increase.
(...)
bubble grew, 25 I
I 537 Zochann 14 1
O
" Question:
Did Mr. Floyd ever communicate 2
to you or to your knowledge anyone else in the Training 3
fact that in a case Department his knowledge of the 4
where you had saturation in the primary system that 1
5 6
that would cause the pressurizer level to increase?
MR. MacDONALD:
I am going to object to 7
8 the f orm.
You can ask him if he ever communicated Your interpretation what was set out in the pages.
9 10 of what it means --
Would you repeat the question?
11 A
did Mr.
To avoid any technical objection, 12 Q
l in 13 Floyd every communicate to you or to anyone else that in a case where a drop 14 the Training Department in pressure had caused saturation in the primary 15 l
that would cause the pressurizer level l
16 system that I
17 to increase?
to the best of my recollection.
18 A
Not l
19 Q
Can you tell us today, Mr. Zechman, whether as to why 20 there is any explanation that you know of neither the superintendent of Unit 1 nor the supervisor lll 21 each of whom had responsibility of operations' of Unit 2, 22 l
communicated -- did not for training of operators, i
23 the Training Department their knowledge 24 communicate to fact that a drop in pressure causing saturation 25 of the f
I i
538 Zoch2cn 1
an increase in pressurizer level.
/kj could itself cause 2
MR. MacDONALD:
I object to the form.
3 He can answer the question based on his 4
recollection.
I have no way of knowing -- repeat your A
6 question -- well, I can't speak for them.
I have no 7
idea what -- they never relayed that to me, to the 8
best of my recollection, or anyone in my department.
9 Why they didn ' t, only they can speak for that.
10 function Based on your understanding of the Q
11 that the Training Department was supposed to perform 12
[/)
during the period of time you were in charge of it in L_
13 training the" operators on how to deal with transient I
14 conditions, is this the kind of information you would 15 like to have had?
16 MR. MacDONALD:
Objection. Purely 17 speculation.
18 MR. FISKE:
It is something he has no 19 recollection of ever receiving and you are 20 asking questions based on that.
21 9
If it hadn't occurred to me prior to the A
22 accident, it would be pure speculation at this point.
23 Q
Was it important to you at the time that f3 24
(
)
you conducted training of the operators that they 25 I
te
I 539 Zochman 16 1
0\\
information as to whether or not
(.,/
2 be given accurate 3
the pressurizer level could be relied upon as an indication of system inventory?
4 accurate O
5 A
Certainly it was important to me that we 6
were,and we were assured that it was.
That was our 7
understanding.
8 Q
Neither Mr. Floyd nor Mr. Toole ever told 9
you anything that changed that understanding?
10 A
Not to the best of my recollection.
11 Q
Earlier in this deposition, Mr. Zechman, we showed you a document which has been marked as 12 13' B&W 558, which is a chapter called " Core Performance"
()
14 from the publication
- Nuclear Power Preparatory Training, l
from the l
which was purchased by Metropolitan Edison 15 16 NUS Corporation.
17 Let me just show you that again.
Do you 18 have that in front of you?
19 A
Yes, I do.
4-20.
l 20 Q
I would like you to turn to page 21 Do you have that in front of you?
gg 22 A
I have that page in front of me.
i 23 Q
I would like to read you a paragraph about two-thirds of the way down the page from this document.
24 O-under 25 "The reactor coolant in a PWR system is kept l
l I
1 u
540 Zachmen 1
In the to prevent bulk boiling in the core.
2 pressure
~
this pressure is case of an abnormal transient where 3
how steam is generated in the core, lost and some 4
G will we know it?
We will see a large increase in level 5
is built back up in the pressurizer until pressure 6
above th e saturation value corresponding to the 7
8 temperature in the core."
Do you see those three sentences from that g
portion of the Met Ed training materials?
10 A
I see that sentence.
11 it still your testimony that you were 12 Q
Is t
i not aware of this concept prior to the Three Mile A
\\/
13 Island accident?
14 I was not A
It is still my contention that 15 accident.
of that phenomena prior to the aware 16 Is it still your testimony that nobody Q
17 familiar with Training Department at Met Ed was 18 in the this concept prior to the accident?
19 recall seeing this paragraph prior A
I don't 20 to the accident.
lll to your knowledge 21 Q
Is it your testimony that, 22 responsible for training in the nobody else that was 23 that paragraph from Met Ed Training Department ever saw
['
24 in course book which Met Ed had purchased for use u
this 25 i
o
Zochmen 18 541 1
the training program?
()
2 I can't speak for other people in my A
3 depar tment.
I can say that I don't personally recall 4
ever seeing that paragraph in the manual or being used.
g Are you familiar with something called Q
6 hot functional testing at a nuclear power plant?
7 A
Yes, I am.
8 Q
Could you explain in as few words as you 9
doing it accurately, what hot functional testing
- can, 10 is?
11 A
Hot functional testing is simply heating 12 up the system and running the system and doing testing
(~}
13 v
under those conditions.
14 Were you aware in September of 1977 that Q
15 to functional testing was going on with respect hot 16 Unit 27 17 recall we went.through a period of hot A
I 18 functional testing.
I don't recall th e exact timing.
19 Q
Did it come to your attention that in the 20 course of that hot functional testing a situation had 21 11, been experienced where steam had been generated in the 22 hot legs and pressurizer level increased?
23 I have no recollection of that.
A 24 n-Q To make it more complete, did it come to x-25
542 h
Zochcon 1
~}
your attention that during the course of hot functional 2
testing a situation had developed where pressure 3
decreased, saturation was caused in the hot legs, and 4
pressurizer level increased resulting in a situation 9
5 where pressurizer level rose while pressure was down 6
as a result of saturation?
7 A
I have no personal recollection of that.
8 Q
Let me show you a document which has 9
previously been marked as B&W 175 which are pages from 10 the GPU start-up test log book.
11
.Do you have that in front of you?
12 A
Yes.
13
()
Q Is it correct that the GPU start-up test 14 that log book was designed to record in a log events 15 occurred during hot functional testing?
16 A
I never personally used the log book or 17 was any part of those tests.
So looking at this is new 18 to me.
19 Q
Let me just show you -- ask you to tura 20 to what is the fourth page of this document which hhs at the top of the page, " John C. Ulrich 9/8/77."
22 Do you have that in front of you?
23 A
Yes, I do.
24 (p
,)
Q I direct your attention to two-thirds down 25 H
Zechcan 543 20 1
O
" Pressurizer level unexpectedly increased 2
the page,
from when venting the pressurizer and decreased pressure 3
4 500 psig to 460 psig.
Pressurizer level increased O
approximately 150 inches during this evolution."
5 6
Do you see those two sentences?
7 A
Yes, I do.
Is it your testimony that no one brought 8
Q Three information to your attention prior to the 9
this 10 Mile Island accident?
Not to the best of my recollection.
11 A
12 Q
Is it also your testimony that to your 13 knowledge nobody brought this information to the attention of anyone else in th e Training Department 14 15 prior to the Three Mile Island accident?
to the best of my recollection.
16 A
Not that Am I correct that your testimony is 17 Q
18 you never saw the pages from this log book?
19 A
To the best of my recollection, I have not 20 seen the pages from that log book.
Was it part of the procedure at Met Ed at 21 Q
(l) the course that' information developed during 22 the time functional testing which might be important 23 of hot to the Training Department would be communicated to 24 j (}
25 the Training Department?
6 i
l
Zochman 544 21 1
/%
A Repeat the question.
()
2 (Question read) 3 as I mentioned earlier, channels A
There were, 4
to the Training Department.
where information was sent recall during this period of time what I don't 6
information was transmitted to us.
7 show you a document which Q
I would like to 8
153 which is a covering letter has been marked as GPU together with copies of the license -- inventory for 9
10 1977.
a transient at David-Besse on September 24, 11 Do you have that in front of you?
12 A
I do.
I would like to direct your attention to Q
14 page 3, caption " Event Description."
l 15 A
I see it.
Q I would like to have you look at a paragraph 16 17 which is part of the event on the second -- on page 4, am referring to the second paragraph l
18 description.
I on page 4.
The sentence reads starting about halfway 19 continued to f
20
" Reactor coolant system pressure
- down, 21 reached and 9
decrease until saturation pressure was 22 form in the reactor coolant system.
steam began to 23 This caused an insurge Approximately T=8 minutes.
( ')
of water in the pressurizer and the pressurizer level rh 24 25 i
L Zechman 545 2
1 went off scale at 320 inches."
2 before it your testimony that at no time Is 3
4 the Three Mile Island accident did you personally know 9
5 that in the course of the Davis-Besse transient a situation had occurred where because of a drop in 6
Pressurization had occurred in the reactor coolant 7
caused an insurge -- and that that 8
system and that th at in the pressurizer level?
caused a significant increase 9
10 A
I believe I already testified that,I was -
11 not aware of the Davis-Besse incident.until post.
12 accident.
Is it your testimony that you never read N-)
13 Q
I I
the accident?
in the Davis-Besse LER before 14 this sen tence l
this Davis-Besse LER prior A
I did not see 15 s.
16 to the accident.
asked you some questions near the syprt 17 Q
We l'
18 of the deposition about varlous publications that were I
received by the Training Department.
19 s
A Yes.
20 21 Q
Referring back to that general subject for lll 22 a moment.
I would like to show you an excerpt from which a publication called " Nuclear Power Experience" 23 is part of a document which has already been marked
["*
24 l
\\~
as B&W Exhibit 208.
25 H
I w
Zachsan 546 23 1
Do you have that in front of you, Mr.
Zechman?
3 A
I have a document.
I don't know how you 4
associate that with '20 8.
lll Q
You don't have to worry about that.
Do you 6
have the document in f ront of you that I just handed
.7 you?
8 A
I have a document in front of me.
9 Q
It consists of three pages, does it not?
10 A
It consists of three pages.
11 Q
I would like to read you a portion of 12 referring to a paragraph from this exhibit which is
()
the same Davis-Besse transient which was described 14 in the LER that I just showed you a minute ago.
The 15 I am showing you says -- which I am sentence that 16 second paragraph on going to read to you is in the 17 pressure continued to decrease" page 4.
It says, "RCS A
Wait a minute.
19 Q
Page 2 of the exhibit reads, "RCS pressure 20 continued to decrease until saturation pressure was 21 g
reached and steam began to form in the RCS." Skipping 22 "This caused an insurge what is in the parentheses, pressurizer and the pressurizer level of water into'the 24 went off scale at 320 inches."
25 c
.t i
~
~>
e 5
i Zechman 547 24 1
that I just.
2 Co ' you sein those two sentances
~
3 i.iread?
{
o 1
j '
(
4
,A Y e s'.,
'(
l
[
Is it year testinony thdt you did not see 5
g this publication with this 1.nformation in it prior to 6
s 7
the Three Mile Island accident?
4 8
A To the best of my recolloction, I did not I
.I Mile 9
see this document prior to the accident at Three 10 Island.
u 11 Q
No one in the Training Department, to yo,r obtained this information from this document?
12 knowledge, O
13' A
I cannot speak for everycne in my Training 14 Departmant because I wasn't at th i s -- I can't speak 15 for the rest of the people in the Tr'aining Department.
16 Q
Do you have any knowledge as you sit 17 here today that anyone else responsible for training 18 at Met Ed read this doconent?
I have no knewledge of anybody that I know 19 A
20 of that would have read that.
There was also some testimony earlier about 21 Q
ggg 22 a publication called "The Atomic Energy" put out by I would like to show 23 the Atomic Energy Clearing House.
from that same Exhibit 208 which
()
24 you some more pages 25 have a caption on the first'page, " Atomic Energy H
~~
I Zachcan 548 g
("N 2
Clearing House Volume 24, January 9, 1978."
I would to direct your attention tothe second page of this 3
like 4
excerpt where there starts a description of the O
September 24, 1977 David-Besse transient which is 5
Primary described under a heading " Valve Malfunctions 6
System Depressurization."
I would ask you to look at 7
8 the next page and the fourth paragraph on that page RCS continued to blow down through which reads, "The 9
and the quench the open pressurizer power relief valve 10 tank rupture disk opening until primary coolant 11 six minutes into saturation pressure was reached about 12 i
\\- /
13 the transient.
The formation of steam in the RCS
(~\\
This l
caused an insurge of water into the pressurizer, 14 injection then 15 insurge and the high pressure inches after" restored pressurizer level to about 310 16 17 something " minutes into the transient.
read Is it your testimony that you didn't 18 the Davis-Besse transient prior to the 19 this portion of 20 Three Mile Island accident?
see this prior A
To my recollection I did not 21 (l) to the accident.
5 23 g
Is it also your testimony that, to your 24 knowledge, that no one else responsible for training at f')
the Met Ed read this paragraph or this desciption of a
25 I
H
zochsen 549 26 1
transient before March 18, 19797 q
Davis-Besse l
)
NJ g
A Since I have not talked to each person 3
relative to that, I cannot speak for everyone in my 4
Training Department.
g Q
Nothing has come to your attention at any 6
to indicate to you that time up until today, has it, 7
in fact, any person in your Training Department did, 8
read this?
9 A
This particular document?
10 Q
Yes.
11 A
No.
12 Can we take a break?
OV 13 (Recess taken) 14 BY MR. FISKE:
15 In another publication that you testified Q
16 about earlier in this deposition, something called a
17 f
events power reactor.
I would like to show current f
18 you a document which has been marked previously as B&W Exhibit 161, which is a four-page document entitled 20 date is l
Events Power Reactors," and the
" Current 1977.
g 21 1 September-31 October, 1977 publiched December 22 there is a Directing your attention to page 2, 23 description under the caption " Valve Malfunctions
('s 24 Primary System Depressurization of the Davis-Besse s
i V
25 is i
20choon 550 27 1
transient on September 24, 1977."
2 I would direct your attention to the third 3
page of this exhibit, the middle of the page where 4
there is a paragraph that reads, "The RCS continued to ggg blow down through the open pressurizer power relief 6
valve and the quench tank rupture disk opening until 7
saturation was reached about six minutes primary coolant 8
into the transient.
The formation of steam in the 9
into the pressurizer.
RCS caused an insurge of water 10 and the high pressure water injection then This insurge 11 inches after restored pressurizer level to about 310 12
[T nine minutes in the transient."
13 Is it your testimony that you never read 14 transient prior that description of the Davis-Besse 15 to the Three Mile Island accident?
16 A
To the best of my recollection, I haven't.
17 Q
Is it also your testimony that no one, to 18 your knowledge, responsible for training at Met Ed 19 of the Davis-Besse read that description of the accident 20 f
(g To the best of my recollection.
21 A
22 You are saying, to the best of your g
U recollection, you have no knowledge that anybody read l
rx I
)
24
~
it?
l l
l l
1 u
551 Zechcon 23 1
l 2
A To the best of my recollection at this time, I have no knowledge of anybody else reading it.
3 think you testified previously that you 4
Q I
were familiar with Users Group and Owners Group 5
meetinga held by BsW'.
6 7
A I was aware that there were those groups, 8
yes.
I believe you testified that you understood 9
Q those meetings were held under the auspicies of 10 that B&W for the benefit of representatives of the various 11 that were operating reactors built by B&W.
12 utilities l
13 A
That's correct.
In November 1977, did you know an employee 14 Q
of Met Ed by the name of Gary Miller?
15 16 A
Yes, I did, t
17 Q
What was his title?
18 A
1977.
I don't recall what his title was.
I don't 19 20 recall what his title was at that time.
as of Can you tell us what his title was 21 Q
lll the date of the Three Mile Island accident?
22 I am drawing a blank on his specific title.
23 A
can you tell us any position that you remembe'r 24 Q
him holding at Met Ed or GPU during the period from l
25 I
a
_. = _ -
I 552 Zachoon 29 1
Island 1977 through the date of the Three Mile September l
I accident?
3 time he was Unit 2 superintendent.
A At one 4
Did you know an employee of Met Ed or 1
Q ggg of James O'Hanlon in November 19777 GPU by the name 6
A I knew a James O'Hanlon.
I don't recall 7
when he came with the company.
8 Q
Can you tell us any positions that Mr.
9 O'Hanlon held with Met Ed or GPU during the period 10 the accident?
September of 1977 to the date of 11 A.
Yes, he was superintendent.
12 Q
Of which unit?
O 13 A
I am just drawing blanks.
14 Q
Is it correct that both Mr. Miller and Mr.
15
'77 O'Hanlon at some point in time between November 16 and the date of the Three Mlle Island accident held 17 of either Unit 1 or the position of superintendent 18 Unit 27 19 To the best of my recollection, they did.
A 20 a person by the name of Q
Have you ever met 21 (I,
Terry D. Murray employed by Toledo Edison?
22 A
No, I don' t recognize that name.
23 Q
I would like to read you, Mr. Zechman, Murray in a depositio n portions of testimony given by Mr.
25 s.
I
~~ --
553 Zochman 30 1
IO Reading from page 49, I would like, Mr.
5/
2 in this case.
3 zechman, in the interest of saving time,to read you and those that particular paragraphs from pages 49 4
O and you are perfectly entitled to read the 5
- follow, 6
entire pages to see if there is anything there that I 7
haven't read that you think is important.
It starts 8
on page 49.
9
" Question:
Mr. Murray, can you tell uu, 10 if you can recognize the phrase Users Group" 11
" Answer:
Yes.
12
" Question:
Can you tell us what the Users b
13 Group is?
V 14
" Answer:
That is a term that usually refers 15 to an organization, an informal organization that year made up of the plant managers 16 meets twice a
of the various B&W-designed nuclear power plants.
17 Are 18
" Question:
You say plant managers.
1 19 those t~ t e station superintendents?
20
" Answer:
Yes.
21
" Question:
When you became station (gg did you begin superintendent as you described earlier, 22 23 attending these meetings?
24
" Answer:
Yes.
25
" Question:
Can you tell us what the purpose i
554 Zechman 1
31 is of having station superintendents meet?
2 The purpose is to exchange
" Answer:
3 the operation,particularly the 4
information about O
of ordinary occurrences that each of us 5
unusual or out 6
have seen to exchange that information."
7 Skip to page 51.
8
" Question:
Do you remember where the first 9
Users Group meeting was that you attended as station 10 superintendent?
Twin Bridge Marriott in Washington 11
" Answer:
12 D.C.
13
" Question:
Are you able to tell us about 14 when that meeting took place?
15
" Answer:
I think it was the 15 and 16, or 16 14 and 15 of November, 1977.
Let me show you a document which 17
" Question:
18 has been marked B&W 1001 in this litigation.
19
" Answer:
Yes.
20
" Question:
Are you able to recognize that 21 document generally?
f g
It was a document that is 1
22
" Answer:
the minutes of the meeting that was held 23 distributed as 24 on the 15 and 16 of November 1977."
)
skipping to page 52, " Question:
Are you 25
Zochoon 555 32 1
K-)
2 able to find in those minutes a list of 3
attendees?
" Answer Yes.
4
" Question:
Are you one of the persons 5
6 listed?
" Answer:
Yes, I am.
7 8
" Que s tion :
Are you able to find on the of attendees any personnel of Met Ed?
9 list
" Answer:
Yes.
10
" Question:
Could you tell us who they are?
11 12
" Answer:
Garry Miller, Mr. Jim O'Hanlon.
"Que s ti on :
Do you remember whether Mr.
()
13 14 Miller and Mr. O'Hanlon were, in fact, in attendance 15 at that ueeting?
I do remember them being in
" Answer:
16 17 attendance."
18 Going to page 54, "Now you reported on a Is one of the events you report on 19 number of events.
20 that of September 24, 1977 that we have discussed about during this deposition?
21 (gg "Aaswer:
Yes, it is.
22
" Question:
Would it be fair to say that it 23 24 is the spirit of the meetings of the station g-]
V information is exchanged fully and 25 superintendents that 3
H
.~
556 Zochoon 33 1
0 2
freely?
" Answer:
Most definitely.
3
" Question:
I take it in your report on 4
the September 24, 1977 incident as well as your report 5
listed in the minutes was consistent on the other events 6
with that concept?
7
" Answer:
Yes.
8
" Question:
Are you able to recall that you 9
10 made the report on that event?
" Answer:
Yes."
11 12 on page 58, skipping a lot of colloquy, can you tell me what your best 13
" Question:
Mr. Murray, i
recollection is that during that report on the 14 15 September 24, 1977 incident you reported on the failure of the steam and feed rupture control system?
16
" Answer:
I believe that I did, 17
" Question:
Do you recall whether during 18 that report you indicated that there had also been a 19 problem with the auxiliary feedwater system?
20 "Anso I am positive that I reported 21 f
ggg on that auxiliary feedwater governor probl,em.
22
" Question:
What is your best recollection 23 as to whether you reported on the f act that the PORV 24 stuck open?
25 i
1 zachman 557 4
1 O
" Answer:
I am positive I reported on that.
2
" Question:
What is your best recollection 3
that the of whether you reported that during the event 4
G pressure level went to saturated conditions?
5
" Answer:
That I am fairly sure was reported 6
7 also.
" Question:
What is your best recollection 8
the to whether you reported that during the event as 9
Pressurizar indicator read full?
10
" Answer:
I believe I stated that also.
11
" Question:
What is your best recollection 12 as to whether you reported that the quench tank rupture 13 j
I disk had broken?
14
" Answer:
I am sure I mentioned that.
15
" Question:
Is it your best recollection 16 summarized those things that in reporting the event you 17 l
18 which you thought were most important?
" Answer; Yes."
19 I
i I would like to ask you at any time before 20 the Three Mile Island accident in March of ' 79, did 21 jg either Mr. Miller of Mr. O'Hanlon advise the Training I
22 at the Davis-Besse-Department that they had learned that 23 in the Davis-Besse transient pressure decreased while f
24 Pressurizer level was increasing?
I 25 d
I
.... _ _.. -.. ~, _
Zachaan 558 1
MR. MacDONALD:
I will let him answer.
I
[}
just want to object to the form of the question.
3 I have no recollection of that kind of a A
4 discussion at this time.
g Q
You have no recollection of either Mr.
6 is that Miller or Mr. O'Hanlon telling you that; 7
correct?
8 A
That's correct.
9 Q
Have you learned at any time up until today 10 information that Mr. Miller or Mr. O'Hanlon reported that 11 to anybody else in the Training Department?
12 A
No, I do not.
O-13 Q
Have you learned at any time up until today 14 that Mr. Miller or Mr. O'Hanlon gave the Training 15 Dopartment any of the information that they had 16 received from Mr. Murray at that Users Group meeting?
17 I have no recollection of that information A
18 at this time.
19 Q
Did it ever come to your attention, Mr.
20 Zechman, prior to the Three Mile Island accident that 21 (Ik there had been a transient at Unit 2 in March 1978 22 involving a failed open PORV in which during the course 23 of the transient pressure decreased and pressurizer level increased?
25 H
t
559 Zsch=an 1
0 You are asking my personal recollection?
A 2
3 Q
Yes.
4 A
Not that I recall.
that you have no knowledge O
5 Q
Is it correct in pressurizer information concerning an increase 6
that level and a decrease in pressure during the course of 7
8 the March 29, 1978 transient was brought to the attention in the Training Department?
9 of anyone 10 A
Not to my knowledge.
Let me show you a document which has 11 Q
previously been marked as Bsw 176, which are on 12 2 and these I
test engineers' log for Unit 13 from the shift 14 relate to March 29, 1978, and I would direct your The third line s ay s,
l attention to the second page.
l 15 pressurizer level was increasad to approximately 16 "The RCS pressure decreased to approximately 17 200 inches.
psig before recovery started."
18 1200 take it your testimony is that nobody, I
19 in the Training Department was made 20 to your knowledge, aware of that f act?
llh 21 am not aware of anybody 22 A
I am saying that I in the Training Department being aware of that.
23 Is it your testimony that you did not 1
24 Q
()
I that is, the shift review this particular document, 25 i
560 Zochtsn 1
()
test engineers' log, before the Three Mile Island 2
accident?
3 I did not review that prior to the Three A
4 Mile Island accident.
ggg Q
Do you know, to your knowledge, if anyone 6
anyone in the Training Department ever saw those
- else, 7
pages from the test engineers' logs?
8 A
I cannot speak for those in my department, 9
ever aware of anyone in my department but I am not 10 reading that.
11 Island Were you aware before the Three Mile Q
12 2
that there was another transient at Unit accident
()
in April 1978 with respect to an analysis of Met Ed I
14 after the transient concluded that because of steam i
f 15 formation in the reactor coolant system, bubble 16 pressurizer level had been held up?
17 I have no recollection of that.
A 18 Q
Is it your testimony also with respect to 19 this transient at Unit 2 that 20 "this," this one here?
A When you say 21 Just so we understand cach l
g Q
The April 23.
I
[
22 my questions a few moments ago were directed.at
- other, 23 a transient at Unit 2 in March of 1978 in which, according to the shift test engineers' log, pressurizer 24 25 l
r
' - ~
561 Zochaan 1
and I think we 1evel went up and pressure went down,
(}
have covered that transient.
3 am asking you about another transient Now I 2 with respect to which 4
less than a month later at Unit g
there was an analysis after the event by Met Ed which 6.'
a result of steam bubble formation concluded that as sys tem resulting f rom a drop in 7
in the reactor coolant And I think 8
pressurizer level was held up.
- pressure, you have testified that you were not personally aware 9
10 of that transient.
11 am now asking you whether you have any I
12 else in the Training Department knowledge that anyone l
)
at Met Ed of this Met Ed was made aware by anyone at second transient at Unit 2 in which because of the 14 15 system formation of steam in the reactor coolant 16 pressurizer level resulting from a drop in pressure, i
17 was held up?
18 A
I can only say that I cannot speak for I can say everybody else in the Traning Department.
20 of anybody else being aware of that.
that I wasn't aware 2t of a transient which occurred qq)
Q Were you aware at TMI-2 on November 7 of 1978 in which there had been 22 an actuation of high pressure injection because of the i
23 24 f}/
drop in pressure?
\\_
25 N
562 Zechman 1
O Do you want to tell me a little bit more?
2 A
MR. MacDONALD:
Based on that.
3 MR. FISKE:
Listen to the question again.
4 O
(Question read) 5 I have no recollection at this time.
6 A
7 Q
I take it it would also be your testimony that you have no recollection of learning any 8
of information from that transient about the effect 9
saturation on pressurizer level?
10 11 A
Since I cannot recollect that one, certainly I can't associate it with level.
12 13 g
Is it your tes timony, Mr. Zechman, that notwithstanding all of the information which has been 14 to your attention in the last hour of this 15 brought or known deposition concerning information available 16 to various people within the Met Ed organization 17 18 concerning the fact that a decrease in pressure'can an increase saturation which in turn can cause 19 cause 20 in pressurizer level resulting in a situation where 21 Pressurizer level is increasing while pressure is lll 22 decreasing, that at no time did that concept get communicated or known to the Training Department?
23 MR. MacDONALD: I' object to the form of
()
24 25 the question.
I think there are assumptions f
'h
563 Zechman 1
0 built into the question and lacks foundation, 2
can answer to the best of his understanding.
but he 3
4 A
Again, I will speak for myself.
I have no 9
recollection of that being relayed to us.
I cannot 5
6 speak for everyone in my Training Department.
7 Q
Am I correct in understanding that notwithstanding the existence of the information in 8
that it has been presented in the the various forms 9
last hour of this deposition, the Training Department 10 Island continued right up to the day of the Three Mile 11 to train operators that pressurizer level was 12 accident indication of under all circumstances an accurate i
13 inventory level in the system?
14 MR. MacDONALD:
I object to the form, but 15 16 he can answer.
17 A
Would you repeat it?
(Question read) 18 19 A
To the best of my recollection, the Training at Met Ed and at the simulator informed 20 Department the pressurizer the operators that maintaining level in lll 21 assured inventory in the RCS system.
22 procedure at Met Ed under 23 g
was there a Toole or Mr. Miller or Mr.
f which Mr. Floyd or Mr.
24
(
O'Hanlon would communicate to B&W to understand that 25 l
{
H
564 20choon 1
O they had information with respect to the f act that 2
an accurate indication of pressurizer level was not 3
system inventory in a situation where a drop in 4
G Pressure had caused saturation?
5 Anything I would say about what their A
6 communications were would be speculation on my part.
7 You don't know of any regular procedure 8
Q at Met Ed that would have led them to communicate that 9
communicate it to kind of information to B&W and not 10 their Training Department in their own organization?
11 Let me see if I understand that question 12 A
correctly.
13 saying is was there a procedure What you are 14 they would relay any information they knew such that 15 that to someone else but not the Training 16 about 17 Department?
18 Q
Yes.
of any such procedure.
A I am not aware 19 Q
Was there a procedure at Met Ed whereby 20 3
log books relating to hot functiona information from the 21 ll testing would be related to B&W but not to the Training 22 23 Department at Met Ed?
Again, you are asking me what somebody else A
24 it is hard for me to speak would do and I don't know --
25 i
1
-,r-,--.,.n.-
I 565 Zachsen 1
Oiv 2
for what they would do.
3 Q
Your understanding, I take it, at the time that if you were head of the Training Department was 4
6 in the Met Ed organization received information 5
anyone which would be useful to the operators in preventing 6
7 a major transient, that that information would be at Met Ed; is communicated to the Training Department 8
9 that right?
10 A
I am saying that it was normal policy that 11 things the plant superintendent, licensing or vice it was normal policy to 12 president wanted us to know, 13 send us that information.
There certainly was not a policy that you 14 Q
were aware of as head of the Training Department where 15 that information would be communicated to B&W but not 16 to your own Training Department?
17 of.
18 A
Not that I am personally' aware 19 Q
Was there any procedure at Met Ed where transient on March 28, information concerning either the 20 21 1979 involving the open PORV, the transient in April lll involving a cooldown resulting from failed 22 of 1978 or the transient in November 23 open steam relief valves, not to Me t 1978 would be communicated to B&W but 24 of
( )
Ed's own Training Department?
25
1 zechman 566
(~
k_
2 A
I am not aware of them supplying B&W 3
information that they felt that we should know and 4
not supply us with.
I am not implying by that, lll I saw it.
5 6
Q Just one last question.
Is it fair to 7
say, Mr. Zechman, that you have no basis as you sit 8
here today f or telling us that B&W was aware of what 9
Mr. Floyd new, what Mr. O'Hanlon knew what Mr. Miller 10 knew and what Mr. Toole knew concerning the impact of --
11 concerning a divergence between pressurizer level and 12 pressure?
By that ques tion, I mean you have no basis g
(
13 for testifying, do you, that ainy of those four 14 individuals communicated that fact to B&W7 15 MR. MacDONALD:
Are you asking whether he 16 knew if any of those four individuals communicated 17 any f acts relating to saturation and its effect 18 on level to B&W7 19 MR. FISKE:
Yes.
20 Q
I take it, Mr. Zedsman, you do not have 21 any basis for testifying that either of those four 22 individuals communicated to B&W that they knew in a 23 transient where pressure decreases you can have pressurizer level increasing when saturation is reached?
<^T 24 b
25 MR. MacDONALD:
I am going to object to the 1
l 1
zachman 567 O
2 form of the question.
No proper foundation.
You can answer.
l 3
4 A
I am not aware of the communication in 5
those areas that they transferred, if any, to B&W.
6 Q
You have no knowledge that they did transfer 7
such information; is that correct?
8 A
I personally have no knowledge, yes.
i 9
Q Is it correct that you also have no basis I
10 for telling us that the information concernits the 11 hot functional testing incident in September of 1977 12 was communicated to B&W7 i
)
13 A
I have no personal knowledge of that.
14 Q
Is it correct that you have no basis for 15 telling us that the information concerning a divergence 16 between pressure and pressurizer level in March 1978
~
17 open PORV transient was communicated to B&W7 18 A
By that group, you mean?
19 Q
By anybody at Met Ed.
20 A
I have no recollection at this time of that
~
l 21 being transmitted.
22 Q
we were discussing at the end of the day l
l 23 yesterday questions relating to high pressure injection.
l l
24 A
Yes, sir.
25 g
You did understa'nd, did you not, before l
I 1
Zechman 568 2
the Three Mile Island accident, that the actuation of hi h pressure injection was itself a symptom of a loss 3
9 4
of coolant accident?
O 5
A I understood was one symptom provided that 6
the pressure got down to 1600 before it was activated.
7 Q
I think we have established yesterday that 8
HPI would come on automatically when pressure dropped 9
to around 1600.
10 A
What I am implying is that the leak may be 11 small enough that pressure may not drop -- if it is a 12 small break it may not drop to activate high pressure.
13 Q
You may have a loss of coolant accident in 14 which it was not low enough to actuate H PI in the first 15 place?
16 A'
Yes.
f 17 Q
If in the course of a transient pressure 18 dropped below 1600 and HPI at that point did come on l
1 19 automatically, that that fact itself, that is the very 20 fact that HPI had come on would be a symptom of a loss 21 of coolant accident?
22 A
could be a symptom of a loss of coolant 23 accident.
(~h 24 Q
Did you understand before the Three Mile V
25 Island accident that there was any other event or
1 ZOchnon 569
<- s()
2 type of transient that could actuate HPI based upon a 3
drop in pressure other than the loss of coolant accident?
4 A
Yes.
I understand that there were other 5
circumstances that could have activated the high pressure 6
system.
7 Q
Which in those circumstances --
8 A
Was not considered a LOCA.
9 Q
-- would cause a drop in pressure, right.
10 A
Yes.
11 Q
You were familiar, I assume, with the phrase 12
" overcooling"?
()
13 A
Yes, sir.
14 Q
Is an overcooling transient one which could 15 cause a drop in pressure and the actuation of HPI?
16 A'
Drop of pressure and level.
17 Q
And actuation of HPI?
18 A
Yes.
19 Q
You understood before the Three Mile Island 1
accident that if you had an overcooling transien t --
20 21 A
Assuming,by the way, we have reached that g
22 activation point.
23 Q
Yes.
24 MR. FISKE:
Would you read what I started?
-s s
25 (Record read)
I 1
Zechman 570 2
Q If you had an overcooling transient, you 3
would expect to see a drop in pressure and a drop in 4
pressurizer levels is that correct?
5 A
Yes.
6 Q
You were not aware of any opposite trending 7
phenomenon associated with an overcooling transient:
8 is that correct?
9 I was trying to shortcut by using a phrase 10 used in other depositions.
11 MR. MacDONALD:
Just add the parameters you 12 are talking about.
13 Q
You were not aware prior to the Three Mile
()
14 Island accident of any circumstances under which an 15 overcooling transient as opposed to a loss of coolant let me -- pressure would decrease while 16 accident i
l 17 pressurizer level was ' increasing?
18 A
During an overcooling situation?
19 Q
Yes.
20 A
Not to my recollection at this point.
21 Q
I think you told us before that H comes 22 on automatically as part of the safety system whenever 23 pressure reaches or goes below approximately the 1800 24 pound set points is that correct?
O 1
A That's correct.
25 l
1 1
Z0chuan 571 4
()
2 Q
In a loss of coolant accident, what is it 3
that causes pressure to go down?
4 A
The fact that we are losing inventory.
If 5
we have a breach of the RC system and therefore losing 6
pressure.
7 Q
What is it in an overcooling transient that 8
causes pressure to go down?
pressure to go down?
9 A
The fact that 10 Q
Yes.
11 A
The fact that temperature is going down, you 12 are dragging heat away and temperature is dropping and
()
13 pressure is dropping.
14 Q
was it important to you in running the 15 Training Department at Met Ed that you be advised in 16 the Training Department of situations during the 17 operation of either unit in which a transient had 18 occurred which activated HPI?
In other words, to put 19 it simply, was it important to you in the Training 20 Department that you learn about any transient that 21 occurred at either plant where HPI had come on?
22 A
During operations of the plant?
23 Q
Yes.
A Not testing or anything of this sort?
24 25 Q
Well, let's talk about during operations.
1 zechman 572 O)
(_
2 A
Realizing that's a broad, generic question, 3
I think based on the circumstances and I am sitting 4
here trying to think of all the kinds of circumstances 5
which could occur and whether there be any tnat were 6
not significant that would not be important to the 7
Training Department.
8 Q
Could there be a transient 9
MR. MacDONALD:
Was he finished with his 10 answer?
11 MR. FISKE:
I was trying to explain.
12 A
I wasn't finished yet.
I was trying to get
()
13 my thoughts together.
14 Q
Maybe I can make it clearer.
Based on your 15 understanding before the accident, would there be a 16 transient during normal operations in which there was such a decrease in pressure that HPI came on requiring 17 of emergency procedures to restore the plant to 18 the use normal condition that you would consider insigificant?
19 MR. MacDONALD:
Are you asking if anything 20 that occurred he considered insignificant?
You 21 have to deal with his recollection.
22 MR. FISKE:
I will ask if he remembers any 23 such actuation of HPI which.he then analyzed and 24
\\'"
decided was insignifcant.
I will ask him that.
We 25
T i
.I i
1 Zochacn 573 s
[)\\
(_
2 will start with that.
3 A
Can you repeat the question?
4 (Ques ion read) 5 A
I don't. recall analyiing an'HPI ~ actuation 6
in which I deemed' insignificant.
s 7
Q Let me ask the next question.
Making it 8
clear, I am asking for your understanding before the 9
Three Mile Island accident.
10 Did you have an understanding then that 11 there could be transients during operations in which 12 there was a drop in pressure large enough to actuate 1
13 automatically a safety system requiring the application l ()
l 14 of emergency procedures to bring the plant back to a 1
15 normal condition which could be termed insignificant?
16 A
Not that I could think of in the phraseology, 17 that you used.
18 Can we break?
s 19 (Recess taken)
BY MR. FI Sr.E 20 21 Q
Prior to the Three Mile Island accident, 22 were you aware-of any transient at Unit 1 or Unit 2',
23 where in the course of operations the high pressure injection system had been automatically actuated?
24 rN
- t. #)
A I cannot recall any at this time.
25 l
s
.I l
)
Zechman 574 1
i, 2
Q Speaking of Unit 2, I take it that it is 3
correct that you were not aware before the accident of 4
the ECCS actuation in the open PORV transient in March 5
'787 6
)
.A Not to the best of my recollection.
'7 Q
You were not aware of the ECCS high pressure 8
injection actuation in the course of the April 23, 1978 9
cooldown transient?
l 5,_
10 A
Not to the best of my recollection.
11 Q
You were'inot aware of high pressure injection
\\
12 having come on automatically in a transient in November l'
13
'787
[
j I
A To my ' recollection at this time, no.
14 s
N-15 Q
You were not aware of high pressure 16 injection having come on in the course of another 1m transient near the end of 19787 17 18 A
Not to my recollection at this time.
Q\\.
s ~
l 19
(
Q Could you, for'our benefit, go through the l
in mechanics or dynamics of hoy it is that p drop 20 temperature produced a drop in pressure in the primary N
21 tit 22 system?
\\
L
\\
MR. MacDONALD:
His recollection prior _to l
23 the accident?
24 MR. FISKE:
Yes.
I assume he understood 25 l
s i
?1
~*%
I 1
Zechman 575 O
\\_)
2 before the accident how that worked or why that 3
happened.
4 A
A drop in temperature?
5 Q
Yes.
We are talking about a cooldown 6
We are backing up a little bit.
Before 7
the break we were talking about two different types of 8
situations which could cause a drop in pressure 9
sufficient to actuate high pressure injection 10 automatically.
One was a loss of coolant accident 11 and one was an overcooling transient.
I think you 12 described how it was that a loss of coolant accident O(_)
13 could cause a drop in pressure simply because there was 14 a loss of coolant through a break in the system, and I 15 think that is clear.
You also said that in the case 16 of an overcooling transient, what would cause the drop 17 in pressure was a drop in temperature.
18 I think it would be useful in this deposition 19 how in an overcooling transient that a drop in temperature 20 produced a drop in pressure.
l A
A decrease in temperature, the RCS liquid 21 22 results in the shrinkage of the system resulting in a 23 decreasing level and pressure.
7T 24 Q
Is there during normal operations a O
relationship between the temperature in the primary 25
I 1
Zechman 576 O
2 system and the temperature in the secondary system?
3 A
Is there a relationship, did you say?
4 Q
Yes.
G 5
A You are dragging from a hot to a colder 6
system.
7 Q
It is correct, is it not, that in the so-8 called primary system there is a hot leg and a cold 9
leg?
10 A
Yes.
11 Q
And the hot leg describes that part of the 12 system through which the water flows after it has gone 13 through the core on its way to the steam generator; 14 is that correct?
15 A
That's correct.
16 Q
As the water passes through the steam 17 generator in the primary system pipes, it transfers 18 heat from those pipes to the water in the steam 19 generators is that correct?
20 A
correct.
21 Q
Which then heats the water in the steam 22 generator up to a certain temperature?
23 A
secondary side, yes.
(~}
24 Q
Isn't it correct that under normal conditions
(/
25 the temperature in the hot leg is around 605 degrees
1 Zechman 577 O
2 Fahrenheit?
3 A
That's correct.
Somewhere around 605 degrees.
4 Q
After it passes through the steam generator 5
and becomes part of the so-called cold leg, it has 6
dropped in temperature to approximately 550 degrees?
7 A
somewhere in there.
8 Q
And it stays at that temperature until it 9
goes back through the core again and re-enters the 10 hot leg, correct?
11 A
Are we back on the primary side or secondary 12 side?
(~)
i
\\_/
13 Q
We are in the primary side.
Just going 14 through it one more time.
We have talked about the hot leg 15 which is the part of the system between the core and the 16 steam generator.
17 A
I understand that.
Ig Q
And that part of the circle was about 600 l
19 degrees.
l 20 A
0 K-21 Q
It then passes through the steam generator 22 and transfers some of its heat to the water in the 23 steam generator and the result when it comes out of the steam generator and enters the cold leg it is down 24 25 to about 550 degrees.
578 Z0chacn 1
(
A Yes.
Q And it stays at that temperature until it 3
reaches the core and goes back through the core and 4
gets heated up again to approximately 605 degrees; is ggg that correct?
6 A
That's correct.
7 Q
To what temperature is the water in the 8
steam generator heated by the water that goes through 9
it from the primary system?
10 A
Using what the temperature of the steam is 11 that comes out of the secondary side?
12 Q
Yes.
p V
13 A
I don't recall the exact values.
l
(
14 l
Q There is water in the steam generator, is 15 there not?
16 A
Sure.
On the secondary side?
17 Q
Yes.
18 A
On the secondary side goes in the bottom 19 and goes up through the steam generator and heat is 20 transferred and goes through different boiling regions lll 21 sup**-heated steam and goes and transferred to steam, 22 out the secondary side to the turbine.
23 Q
You are familiar with the abbreviation "TH"?
24
)
A T Hot.
~/
25
1 1
zechman 579 O
2 Q
TC?
3 A
T Cold.
4 Q
That is the temperature of the cold leg?
O 5
A Yes.
6 Q
T Av 7
A Yes.
8 Q
What is that?
9 A
That's the average temperature of the 10 RC system.
Av 11 Q
Is there any relationship between T 12 or TC in the temperature in the secondary system?
C' 13 A
Yes, there is.
14 Q
What is that relationship?
15 A
Relationship between T Av and Tsat 16 Q
Are they the same?
17 A
No.
18 Q
If the T Av is halfway between 550 and 19 605,approximately 575, and TC is 550, what is the 20 temperature in the secondary side?
A I need to know what T sat is on-the llh 21 22 secondary side.
23 Q
Isn't there a regular temparetuare for 24 Tsat in the secondary system during normal operations; isn't it supposed to be at a certain temperature?
25
I 1
zechman 580 0
2 A
It is and I cannot recall that number.
3 I am drawing blanks.
4 Q
I guess what I am also asking you is what O
relationship between that number and whatever 5
is the 6
it is and either T Av or TC or TH.
7 A
Q=UA Delta T.
8 Q
Would you mind putting that in English?
9 A
Yes.
The heat on the secondary side is 10 equal to the U, which is the coefficient of heat 11 transfer times the area times the quantity Delta T, 12 change in temperature.
13 Q
What I am asking you is in the course of normal operations where you have TC 550, TH approximately 14 15 600, what would you expect in normal operations the 16 temperature on the secondary side to be?
17 A
I told you I just can't recall that number.
18 Q
Is it correct the way the system works 19 that a decrease in temperature on the secondary side would produce a decrease in temperature on the primary 20 side?
lll 21 A
It means we are dragging heat away, yes.
22 Q
other than a loss of coolant accident and 23 an overcooling as you have described it in your testimony
()
24 of was there any other circumstance that you were aware 25
+-,-s-4
.,-2 J
w.
..m_
581 1
Zechman 0
2 before the Three Mile Island accident that could cause 3
a drop in pressure sufficient to actuate high pressure
-1 injection?
5 A
Please repeat the question.
4 6
(Question read) 7 A
Yes, there was.
8 Q
What?
to 9
A Stuck open PORV would reduce pressure 10 that point.
11 Q
I guess by my question I had been including 4
12 a stuck open PORV within the definition of a loss of 13 coolant accident based on some testimony you gave loss of earlier in a deposition that you considered a i
14 l
through an open PORV to be a " loss of coolant 15 coolant 16 accident"?
17 A
No, sir, I did not.
Not to the best of my indicated that a stuck open PORV would 18 recollection.
I 19 allow pressure to drop but I,didn't con, sider that l
never considered a loss of coolant accident via a we 20 PORV.
llh 21
-22 Q
Let's pause on that for a minute.
You understood that when the PORV, if the PORV failed open 23 that mass in the form of steam or whatever would flow
(
24 out of the PORV through the pipe into the drain tanks I
25 l
l
582 1
zochman
/~
I
(_)h 2
is that correct?
3 A
small amount of mass, yes.
l 4
Q Isn't it correct to censider that a loss 5
of coolant?
l' 6
A But not in the phraseology as a loss of l
7 coolant accident.
8 Q
Without pausing a great deal longer at 9
this moment, is it correct then that prior to the Three aware of any event 10 Mile Island accident you were not 11 which could cause a drop in pressure to actuate high 12 pressure injection other than a loss of coolant accident, l
an open PORV or an overcooling?
13 14 A
There may be others, I just can't think of 15 any other at this moment.
Did you give your operators any training at 16 Q
had come on Met Ed as to how they could tell once HPI 17 18 whether it had come on because of a loss of coolant as opposed to an overcooling transient?
19 accident A
In our training we tried to explain to them 20 the distinguishing features.
llh 21 Did you explain to them that one of the 22 Q
features of an overcooling transient distinguishing 23 was a drop in temperature?
()
24 We explained that one of them was a drop in A
2;-
~.
583 zechman 1
O in level.
We are 2
pressure,also a corresponding drop talking about overcooling?
3 i
4 Q
Yes.
O Did you tell them they would not expect 5
an overcooling transient without a drop in 6
to see 7
temperature?
Putting it another way to make it more 8
simple, Mr. ~ Ze chman, did you explain to the operators 9
in the training program that if high pressure injection 10 came on in the course of a transient accompanied by an 11 increase in temperature, that that would be an indication 12 that they were not in the middle of an overcooling O'
13 transient?
A Repeat the question.
14 (Question read) 15 16 A
I cannot put it in the terms you put it, 17 in the terms you put it.
I can only put it in the terms of the ways of distinguishing between the 18 of how -- some 19 two.
20 Q
You have already told us and I think explained caused very clearly how an overcooling transient would be ll) 21 resulting from a drop in temperature.
I think you have 22 already told us that.
23 A
And level 7 24 w
Q Right.
25
I 584 1
Zechman
/
b/
the accident 2
Did you understand prior to that you could have an overcooling transient when there 3
4 was an increase in temperature?
O Never considered that prior to the accident.
5 A
6 No.
The answer is no, I never considered that.
7 Q
Having just told us that what produced an 8
overcooling transient is a drop in temperature, are you 9
saying that you never considered that an increase in 10 temperature would produce an overcooling transient?
11 A
No.
I am saying an overcooling is and level decrease.
12 characteristic of temperature Ch 13 Q
So you would not expect to have an overcooling
(
l 14 transient if there was an increase in temperature; is tha<
15 correct?
16 A
To the best of my recollection.
17 Q
In training the operators on how they could
- accident, difference between a loss of coolant 18 tell the 19 open PORV transient and an overcooling, wasn't it part that 20 of the training process to tell the operators what causes an overcooling transient is a drop in lll 21 22 temperature?
A You can't put it just in those terms.
You 23 have got to know the situation at the time, what all
[ ')
24
%./
25 the other parameters are and make that evaluation.
1 1
Zechman 585 ON]
2 Certainly one of the things they are looking for in 3
overcooling is a decrease in temperature and pressure 4
together.
That is one of the symptoms but that is not O
5 the only thing we are looking for in making those between those situations you have hypothesized that we 6
7 looked for.
8 Q
I am not saying this is the only thing they 9
should look to.
Indeed, we went through a procedure 10 yesterday which listed a number of separate specific 11 things that should be looked to which might be uniquely a steamline 12 characteristic of a LOCA as opposed to
'\\
13 break and as opposed to a tube rupture.
We have already 14 covered all that.
I am simply focusing on the moment for this additional consideration.
I think you have 15 16 told us that it was your understanding before the 17 accident that you could not have an overcooling transient 18 where there was an increase in temperature as opposed 19 to a decrease, and I am asking wasn't that part of the 20 training program?
I am not saying the only thing.
I am saying was that part of the training given to the lll 21 22 operators that trying to determine in the course of a transient whether or not there was an overcooling 23 involved, that one of the things they should look at
[-))
24
\\_
was the temperature?
25
586 1
Zechman l
2 A
That's only one of the things they should 3
look at.
They should also look at level.
about 4
Q I am only asking you at the moment O
5 temperature as one of the things they should look at is causing in the process of trying to diagnose what 6
7 this drop in pressure that they are looking at.
8 Am I correct that that was one of the 9
things that they were told to look at?
10 A
But not all.
One of the things but not all.
11 MR. FISKE:
Let's stop for lunch.
12 (Luncheon recess taken at 12:30 p.m.)
O 13 l
14
(
15 16 17 18 19 20 22 l0 24
I 587 1
a AFTERNOON SESSION 2
2:12 o' clock p.m.
3 4
O 5
RICHARD W.
ZECHMAN, resumed:
6 BY MR. FISKE:
7 Q
Mr. Zechman, before lunch we were talking 8
about the training that was given to the operators at 9
Met Ed on how to differentiate between a LOCA and an 10 overcooling transient when they saw a decrease in 11 pressure which was sufficient to actuate high pressure 12 injection.
O What I would like to ask you now is what 13 the Three Mile was your understanding at the time of 14 to what would happen if in the course 15 Island accident as 16 of an overcooling transient the operators left HPI on 17 longer than they should have.
18 A
Assuming now that the HPI is on and that 19 there is an overcooling and temperatures are continuing to decrease because of that overcooling?
20 Q
Correct.
lh 21 A
Levels are increasing.
Pressure and 22 23 temperature are decreasing and levels decreasing.
One was to of the concerns the operators were told about
()
24 maintain level in the pressurizer.
Don't let it go out 25
1, 588 1
Zechman O
2 the bottom.
Don't let the level go out the top of 3
the pressurizer.
They were trained to operate high injection in such a way to control the 4
pressure O
5 overcooling event.
I 6
Q Let's put it in a slightly different way 7
in light of the answer you just gave.
You said it was your understanding and your Training Department's 8
9 position, right up to the time of the accident, that 10 pressurizer level was an accurate measure of inventory 11 of the system, correct?
12 A
That's correct.
O-What was your understanding of a situation 13 Q
14 in which the system was full and the pressurizer level 15 was full, what would happen if under those conditions the operators continued to leave HPI on?
16 17 A
I don't recall.
18 Q
I think you testified yesterday that~you did understand that if the operators terminated HPI 19 had during a loss of coolant :ccident when the pressure 20 there was not come back up to the actuation point that lh 21 a risk that the pressure could continue to_ decrease to 22 23 the point where saturation would occur.
I think we end of the day.
spent about a half hour on that at the
(
24 What MR. MacDONALD:
'I am going to object.
25
I 1
Zachman 589 bv 2
he said was said.
If you want to go back over the 3
ground, fine.
I don't think necessarily your 4
characterization is right.
That's all, Mr. Fiske.
O 5
Q Let me read you the last two questions and 6
answers from yesterday's deposition.
I 7
" Question:
My question is did it occur 8
to you before the accident that if the operators had is been given training and instruction on when it 9
proper to termknate HPI either didn't understand those 10 11 instructions or failed to follow them or made a mistake 12 or for whatever reason terminated HPI when, in fact, the O
13 HPI should have stayed on,that,one consequence of their 14 doing that, that is improperly terminating HPI would 15 be to allow a continuing drop in pressure?
"Mr. MacDonald:
Did that ever occur to you?
16
" Answer:
Yes.
17 18
" Question:
And that a continuing drop in 19 pressure if it went far enough to cause boiling?
" Answer:
And this is where I think we have 20 our differences.
As a theoretical point, I understand lll 21 that that will occur."
22 That is from the end of yesterday's session.
23 24 I would like to proceed from those answers.
Did you
()
25 understand that if a transient had been diagnosed as a
1 590 i
zechman 0
2 loss of coolant accident and that a loss of coolant 3
accident was in progress, that the operators should 4
not terminate HPI until at least pressure had returned O
5 to the actuation point?
6 A
The focus on HPI has always been to maintain 7
level and their focus was on level.
Everything we 8
observed in the past maintaining HPI for a LOCA, pressure 9
and level stay together.
10 Q
And as you said, that was also true for an 11 overcooling; is that correct?
12 A
Would you like to state that question again?
13 I said what for overcooling?
14 MR. FISKE:
Read Mr. Zechman's last answer j
15 back.
(Answer read) 16 17 Q
First of all, let me put a preliminary 18 question.
When you use the word "we" in that last I
19 answer, you weren't referring to Met Ed as a whole, 20 you were referring to you personally, were you not?
l Met Ed and at the simulator training.
A
()
21 MR. FISKE:
Read the last sentence back.
22 (Answer read) 23 Who were you referring to when you used the
()
24 Q
25 word "we" in that sentence?
l l
591 I
Zechman (O) 2 A
I repeat what I said.
When I said "we,"
\\_J 3
I referred to our operators at the simulator and our 4
own in-house training.
O 5
Q The "we" is confined to your operators?
To the training of the operators.
6 A
7 Q
It is not intended to speak more broadly else in the Met Ed organization, 8
and include anyone 9
other than just the operators; is that correct?
attended 10 A
well, it depends whether the others 11 the operator training program.
12 Q
were you intending to include Mr. Floyd, Mr.
(m.
O'Hanlon in the use of "we" 13 Toole, Mr. Miller and Mr.
14 in that sentence?
-- what I 15 A
What I was referring to in that
~
16 was referring to was that in the training, whether it 17 was Mr. Floyd or Mr. O'Hanlon who went through the referring to them who went through the 18 training, I am 19 training at the simulator and in-house.
That's what I was referring to.
20 21 Q
I would like to go back to the question that lll 22 I started with and I think it is probably easier to put 23 it again.
Did you understand that if it was diagnosed
[ )J 24 that the loss of
~. -
during the course of a transient 25
l l
1 Zechman 592 0
and the HPI had 2
coolant accident was in progress, that 3
come on, that the HPI should not be terminated until 4
at least the pressure had been restored back to the O
it had been automatically activated 5
set point at which 6
for safety reasons?
so you understand, I am not asking i
7 you to get into the question of how that diagnosis would i
f 8
take place.
I am asking you whether after the diagnosis 9
had been made, on whatever basis, it was determined that 10 you, in fact, had a loss of coolant accident in progress 11 resulting in a drop of pressure sufficient to 12 automatically activate HPI, did you understand that it 13 would be wrong to terminate the HPI until the pressure 14 had been restored at least back to the actuation point?
15 A
In the operation of the HPI it was always 16 focused on maintaining level in the pressurizer and 17 pressure would follow that.
It was the level that 18 was the major concern in past training.
19 Q
Are you saying that if there was a loss --
20 knew a - loss of coolant accident was going on and 21 as you were looking at the instrumentation you were lll that told you that 22 seeing on whatever basis symptoms 23 there was a LOCA in progress, that you would turn off 24 the HPI, if the pressurizer level was high?
(
taught that as maintaining level and 25 A
We were
593 Zechman 1
O we were always taught 2
pressure by operation of the HPI, RCS if we maintained level that we had a sufficient 3
4 coolant and the focus was on the level.
O We have been all thrcugh that this morning 5
Q testified that you personally and apparently 6
and you have aware of 7
nobody else in the Training Department was 8
the fact that there could be circumstances when not an accurate indication of 9
pressurizer level was 10 system inventory.
I am not particularly anxious to 11 go through that all over again.
I would like to finish 12 this deposition.
I am simply asking you once again i
13 that if it were diagnozed that there was a loss of i
coolant accident in progress because of a lot of other i
14 symptoms besides pressurizer level or including 15 16 pressurizer level, that there was a diagnosis that you had a loss of coolant accident in progress, didn't 17 l
18 you understand that the HPI should not be terminated actuation point?
until pressure had come back to the 19 You are talking prior to the accident?
A 20 Q
Yes.
h 21 Prior to the accident our training was to A
22 We The other situation didn't occur.
maintain level.
23 never saw in our past training level going up and
(
24 25 pressure going down.
It was always together.
w vo--
.o v-.m
-.nv m,-
.---r----e,
,n-
1 Zechman 594 2
Q Didn't your own training at Met Ed,even 3
without knowledge,as you have testified of the fact that 4
there could be a difference between level and pressure O
5 when saturation was occurring in the system, even 6
without that knowledge for the moment, wasn't your 7
training to the operators that they should look at 8
level and pressure before determining to terminate HPI?
9 A
I think I answered that question by saying 10 that the training we had focused on level and in the 11 past the pressure always.
12 Q
In other words, it didn't make any 13 difference what the pressure was, you just looked at 14 the pressurizer level?
15 A
It never occurred -- in the pastit was never 16 separated.
They were together.
17 Q
Isn't it a fact, Mr.Zechman, that your 18 training taught them that they should look at level and 19 pressure, both, before terminating HPI?
A The training we received from the simulator 20 and in-house focused on maintaining level to insure lll 21 22 adequate RCS coolant.
By virtue of that in the past and everything we observed, pressure stayed with it.
23
/~N 24 Q
In other words, you were told that both 25 pressure and level were important, were you not?
Didn't
595 1
Zechman t'
l 2
you tell that to your operators?
x 3
MR. MacDONALD:
In normal operation of 4
the plant?
O 5
MR. FISKE:
In deciding whether to terminate 6
HPI after it had come on in the phase of a drop -
7 in pressure.
8 A
Maintaining level that pressure would also 9
be controlled, we told them.
10 Q
So that pressure was important?
In other 11 words, what you are saying, is it not, that you told level as an 12 the operators that they could look at
(
13 indication of what the pressure was?
14 A
We trained them that by maintaining level t
l inventory would be maintained and 15 sufficient core l
16 pressure would follow it because that is the way we were 17 taught at the simulator and in-house.
18 Q
If pressure followed it,then they could terminate HPI when they got back up above the actuation 19 l
20 point?
down Termination of HPI is..when we get l
A lll 21 22 when we can go on to low pressure injection.
23 Q
So you were supposed to leave it until 24 you got down to low pressure injection?
(
A We were always taught to maintain level with 25 l
1 596 1
Zechman p) the focus was on.
2 HPI in the pressurizer,and that's what i
3 p
When you say "we were," that is what you 4
were taught at Met Ed?
O 5
A We were taught at the simulator too.
6 Q
How many hours were involved inthe two-year 7
requalification program thht was taught by Met Ed?
8 KR. MacDONALD:
What time?
9 MR. FISKE:
While he was head of the 10 Training Department.
11 A
A minimum of 60 hours6.944444e-4 days <br />0.0167 hours <br />9.920635e-5 weeks <br />2.283e-5 months <br /> scheduled training a 12 year and sometimes it went up as high as 200-some hours.
O
(_/
13 Q
Wasn't it as high as 5007 14 A
You may be right. I don't recall the exact 15 facts on numbers that we had.
I know there were times 16 there was a significant number of hours.
17 Q
And the training on the B&W simulator 18 during the period of time that you were head of the 19 Training Department was one week every two years, is 20 that correct, about 40 hours4.62963e-4 days <br />0.0111 hours <br />6.613757e-5 weeks <br />1.522e-5 months <br />?
A At times I was either acting or in charge ll) 21 22 of.
There was a period of which was 40 hours4.62963e-4 days <br />0.0111 hours <br />6.613757e-5 weeks <br />1.522e-5 months <br /> every two 23 years and 40 hours4.62963e-4 days <br />0.0111 hours <br />6.613757e-5 weeks <br />1.522e-5 months <br /> ever year.
That's my recollection.
'~
24 Q
Beginning in '78 it was 40 hours4.62963e-4 days <br />0.0111 hours <br />6.613757e-5 weeks <br />1.522e-5 months <br /> every two 25 years, correct?
l 597 1
Zechman i
O 2
A I think I told you before I didn't remember 3
the exact dates. I know there was a period of time that it was 40 hours4.62963e-4 days <br />0.0111 hours <br />6.613757e-5 weeks <br />1.522e-5 months <br /> and that was consistent with our 4
O 5
requalification program.
B&W 6
Q Forty hours every two years on the simulator as compared with hundreds of hours of 7
8 training at Met Ed; is that correct?
9 A
If you want to do a time comparison, that's 10 correct, sure.
By the way, not counting, of course, 11 the initial training program that operators spent at 12 the simulator.
O 13 Q
These also had an initial training program 40 hours4.62963e-4 days <br />0.0111 hours <br />6.613757e-5 weeks <br />1.522e-5 months <br /> Ed that was many hours multiple of the 14 at Met 15 they would get 16 A
It was more than 40 hours4.62963e-4 days <br />0.0111 hours <br />6.613757e-5 weeks <br />1.522e-5 months <br /> on the simulator?
17 Q
18 A
Eight weeks at the simulator.
Combination 19 classroom and simulator.
20 Q
In any event, would you debate any further the quantitative differences between the training at ll) 21 22 Met Ed and that at B&W7 sounds to me that an extraordinarily It 23 at high reliance was put by the Training Department 24 Met Ed on the situation of level in the pressurizer.
25
598 Zechman 1
2 MR. MacDONALD:
Object to the form.
What 3
do you mean by " extraordinarily high reliance?
4 Q
Do you think that is an unfair characteri-0 5
zation, Mr. Zechman?
6 A
If you are referring to the number of hours 7
spent on that issue, yes, I think that's unfair.
8 Q
I an not talking now about the number of 9
hours that that subject was covered.
I am talking 10 quantitatively, or rather substantively, qualitatively 11 about the situation that was given in your training an accurate 12 program to pressurizer level as being 13 reflection of inventory in the system and just from 14 the numbers of times that you referred to it in the 15 response to questions that I asked, whether they are 16 related to that or something else, I will draw the 17 conclusion, which I invite you to correct if you think 18 it is wrong, that the Met Ed Training D'epartment'put 19 heavy reliance on that in the training of its operators.
A You have got to put it in the framework 20 in which our discussions took place.
We were talking jll 21
-- where we 22 about transient conditions and we went learned to operate under transient conditions was at 23 24 the simulator.
That was the main focus of the simulator 25 to look at transients and do different things on the
I 1
zechman 599 A
2' simulator.
That's where we learned that concept.
3 Q
You didn't confine your information about 4
how to deal with transients to the B&W simulator program, O
5 did you?
Putting it another way, wasn't it important 6
for you to get what information you could about 7
transients from whatever source?
8 A
I am not saying the only source of 9
transient information came from B&W.
10 Q
Accepting that and taking whatever you know 11 about transients or didn't know about transients in the 12 Met Ed Training Department, from whatever source, isn't F 's
\\_/
13 it a fair characterization of your training program i
i that you placed heavy reliance on the pressurizer level 14 15 as being an accurate indicator of system inventory 16 during the training that you gave your operators?
17 A
I guess I take issue with " heavy emphasis."
18 It was characteristic of what we learned in operating 19 RCS system and how we performed at the simulator and what we have learned in the operation of that system 20 over the years.
21
)
Q Again, when you use "we" in that sentence, 22 who are you referring to?
23 learned A
People going through.the training who
[^)
24
%-)
how to operate the plant.
25
L 600 Zochman 1
O-Q And you did not mean to include in "we" 2
Mr. O'Hanlon, Mr. Miller, Mr. Floyd and Mr. Toole?
3 A
I certainly did imply to include anyone 4
who went through our program and got licensed.
Went llh through the same training, went to the same kind of I
6 simulator training, went through our training program.
J 7
MR. FISKE:
Could you read the last answer 8
back?
9 (Answer read) i 10 Q
Was Mr. Floyd licensad?
11 A
He was.
12 Q
Presumably Mr. Floyd was taught during your
()
an accurate training program that pressurizer level was 14 msasure of inventory in the system?
15 A.
To the best of my recollection, he went 16 through that same training, both at Met Ed and at the 17 simulator and had that reliance.
18 Q
He knew then, did he not, that your training 4
19 program at Met Ed was teaching the operators that they 20 could rely on pressurizer level as being an accurate II, 21 reflection of system inventory?
22 A
I can't speak for what Mr. Floyd thought.
23 I can only say what training he went through.
24 Q
The training that he went through told him, 25
'i
,.r-.;r.,..
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.--.y
.~..
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.,,____,.,_.-_..m x,,~...r...--,_,._.,._,_-_.m
--._.m
r 601 1
Zechman 0
2 as you have just said, that he could, he and anyone 3
else -- any operator could rely on pressurizer level as being an accurate measure of system inventory?
4 O
5 A
That is what we were taught in the simulator and carried through on our training.
6 7
Q Do you know if Mr. Floyd knew this was 8
being taught in the training program and he knew that 9
was incorrect, that he wouldn't tell you in the Training Department that you were giving out misleading 10 11 information?
MR. MacDONALD:
Objection to the form.
12 13 A
I can't speculate what was in Mr. Floyd's l
14 mind.
15 Q
Would you give the same answer with respect 16 to Toole?
MR. MacDONALD:
To clarify, go through the 17 18 training program.
l 19 Q
Did Mr. Toole, to your knowledge, go through l
i the Met Ed training program?
f 20 A
To the best of my recollection, Mr. Toole 21 He did not go through all of our training program.
22 went through some of it.
f l
23 Did he go through the part where operators Q
24 were taught that they should look to pressurizer level 25 l
r-m.
7w --
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1 1
Zechman 602 0
as an accurate measure 2
during the course of a transient 3
of inventory in the system?
4 A
I have no way of recalling that.
I don't O
5 recall that at this time.
6 Q
Did Mr. Miller go through the Met Ed training 7
program?
8 A
Yes, he did.
9 Q
Did Mr. O'Hanlon go through the Met Ed 10 training program?
11 A
Yes, he did.
12 Q
Let me ask you the same question with respect O
13 to those two gentlemen, Mr. Miller and Mr. O'Hanlon.
have told the 14 Do you have any reason why they would not 15 Training Department that you were giving misleading informa' tion to the operators when you were telling them 16 17 that they could rely on pressurizer level as an accurate 18 level of system inventory?
MR. MacDONALD:
Objection to form.
19 A
You keep saying "giving us" -- why they didn' t 20 tell us about misleading information.
I can't speculate ll) 21 22 on what their thoughts were.
I can only tell you what l
our training was and what training they went through.
23 24 Q
I understand.
They went through your trainin g
()
which told them and others that you should look during 25
J 1
603 Zechman 1
to pressurizer level as an course of a transient 2
the accurate measure of inventory in the system, correct?
3 That's correct.
4 A
do you know of any reason 5
Q I am asking you, training program and then through that 6
why having gone the Users Group meeting about which Mr.
7 learning at transient in there had been e 8
Murray testified that an accurate which pressurizer level was clearly not 9
that they didn't tell measure of system inventory, 10 to the Training Department?
11 that MR. MacDONALD:
I object again.
12
(
going to speculate on their A
Sir, I am not 13 I know nothing thoughts or their communications that 14 15 about.
We were discussing at one point earlier Q
16 considered today the question of whether an open PORV was 17 accidents do you remember 18 by you to be a loss of coolant 19 that?
A Yes.
20 if I am Q
I think you said, and correct me 21 that you considered an open PORV to involve
- wrong, 22 that you didn't consider it loss of coolant but some 23 I
l accident."
to fall within the phrase " loss of coolant 24 Is that correct?
25
l 1
604 1
zochman O
2 A
Yes.
I never considered as it was the day 3
of the accident the loss of coolant through the PORV.
4 Never considered it in that mode.
O In training --
5 Q
6 A
That is prior to the accident, I never 7
considered it.
Ed In the training that was given at Met 8
Q 9
with respect to dealing with an open PORV, we went through earlier in the deposition procedures that were 10 11 designed to diagnose an open PORV and prescribe the 12 treatment for an open PORV once it has been diagnosed.
13 I think we went through that a day or so ago; do you 14 recall that?
15 A
Yes.
16 Q
You recognized, did you not, that it was 17 important not to allow a condition to continue where a PORV opened and remained open?
18 A
If it was recognized that that was the case.
19 20 Q
I will accept that for the moment.
In considering what the consequences --
i lll 21 A
By the way, this is assuming we are in 22 23 operating -- the plant is operating and we had an open PORV?
24 25 Q
Sure.
That's what the procedures were
,y
I 605 Zechman 1
2' designed to deal with; is that correct?
The pressurizer that we went through was system failure procedure 3
designed to deal with that very situation and the 4
O failed open or stuck open PORV duruing the course of 5
6 operations; is that correct?
7 A
The procedure dealt with, if it was it was open, they recognized through some symptoms that 8
told you some of the things to do.
9 10 Q
In order to close it?
A In order to close it.
11 Or to block off the opening?
12 Q
A If it was recognized that it was open, yes.
13
[
What understanding did you have as to what 14 Q
system if the PORV remained open for t
would happen to the 15 l
a sustained period of time?
16 A
My understanding was that the pressure would 17 HPI would come on.
18 drop until a point where So we understand each other, an open PORV 19 Q
creates, in effect, a hole at the top of the system, does 20 it not, above the pressurizer?
lll 21 P
It's a relief valve.
A 22 It's an opening in the system?
Q 23 A
Yes, it's an opening, 24
)
Beneath that opening is the pressurizer, Q
25
606 Zechman 1
O 2
correct?
A Yes.
3 4
Q Which has at least at the time the PORV O
5 first opens steam on the top and water underneath; is 6
that correct?
7 A
Correct.
8 Q
That water and that steam is under very 9
high pressure, is it not?
10 A
Yes.
11 Q
And did it occur to you at any time right 12 up to the accident that if there was a hole in the top remained open for any period of time
\\-
13 of the system that and you had right beneath the hole water under high 14 15 pressure, that a normal consequence of that would be l
16 for the water to go out the hole?
A It never occurred to me.
We never 17 18 experienced that in our training.
It never occurred to me before the accident that that would happen, 19 Q
What did you think the reactor coolant drain 20 tank was for?
l 21 Vent A
I told you there are several uses.
22 headers going into that, the PORV empties into that.
23 Q
What empties into that from the PORV as Ov 24 you understood?
25 l
.... - _ -. ~,.
I 607 Zechman 1
O 2
A The tailpipe.
- 3 Q
I know the pipe connects the PORV and the 4
drain tank.
I am saying what goes into the drain tank O
5 through that pipe through an open PORV.
6 A
Just s te am and it condenses and forms water 7 _
during normal operations.
t 8
Q Did it occur to you that if the PORV 9
remains open for an extended period of time, something 10 more than the steam that is at the top of the pressurizer 11 will go through that hole?
i Never occurred to me prior to the accident.
12 A
13 Q
In other words, it never occurred to you l
consequence of having a 14 before the accident that one 15 PORV that remained open for a period of time is that towards water under high pressure would tend to go 16 i
17 that hole, thereby, among other things, filling up the 18 pressurizer?
19 A
Our training always in the operation of the pressurizer say don't go solid and don't go out 20 Try to maintain level in the pressurizer.
21 the b ottom.
lll 22 With that in mind,it never occurred that that would 23 happen.
24 Q
In other words, you never tried to sit down
- ()
a matter'of basic dynamics of the 25 and figure out as i
s M
_r_
____..,__.y.,_,_._.,r...,,.
.,w,-,_...-,..-
,.._.____.__.-._.m.........
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I 608 zechman 1
O 2
plant what would happen to the water in the system or 3
what would happen to the water in the pressurizer if 4
there was a hole at the top of the system that remained O
open for a period of time?
5 6
MR. MacDONALD:
I am going to object to 7
the form.
He may answer.
8 A
Certainly I think that would be something 9
on the simulator.
We never observed it on the simulator.
I don't recall It was never called to our attention.
10 11 having -- thinking about that prior to the accident.
12 Q
Mr. Zechman, did you ever do any thinking O
\\l 13 during the entire time you were head of the Trai~ning 14 Department to form some independent opinion of your 15 own as to what you thought the operators should be 16 taught?
17 A
Sure I did.
I am saying that that particular accident.
situation never occurred to me prior to the 18 19 Q
You didn't think that you were limited in what you taught the operators by what you had learned 20 21 at B&W, did you?
ll)
A certainly not.
22 23 Q
Didn't you understand that Metropolitan Edison had the legal responsibility with the NRC as a
24 their license for running particular condition of keeping 25
--,,n.,,..=.,
I 609
'Zechman 1
a training that was satisfactory to the Nuclear 2
4 3
Regulatory Commission?
(
~4 MR. MacDONALD:
I object to the form of O
5 that.
You may ask him what his understanding is.
6 when you coach it in legal responsibility, I think 7
it is out of bounds for this witness.
i 8
MR. FISKE:
They maybe told him that when he was hired as head of the Training Department 9
10 that Met Ed had a legal responsibility.
If he doesn't know, he may say so.
11 had a training program consistent 12 A
I know we 13 with the requirements o.'
10CFR 5 5 and the appendices.
i 14 Q
And the responsibility for that training Program ultimately was with Met Ed although you could l
15 16 subcontract certain parts of it out to other l
17 organizations; is that correct?
1 18 A
Please repeat.
(Question read) 19 A
we are getting into legal questions that I 20
\\
am in a position to totally answer.
don't feel I l) 21 what did you understand would happen to 22 Q
i Met Ed's operating license if the NRC determined that I
23 24 any part -- if the NRC determined that the training
(
program was insufficient?
25
~ - -,- -,,--.
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n-,-
.---r----
.. ~
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a----
l 610 Zechman 1
2 A
I certainly understood that I have a training program consistent with 3
commitment to provide a 4
10CFR55 and appendices.
O Did you understand that if you did not do 5
Q 6
that, that Met Ed could lose its license?
7 A
I suppose depending on the circumstances 8
that would be the case.
9 Q
We are talking about a license from the Ed is required to Nuclear Regulatory Commission that Met 10 11 have in order to run its reactors is that correct?
12 A
I don't pretend to know all the legal ramifications of the operating license.
I know I can 13 a training categorically that we had to have 14 state l
15 program consistent with 10CFR55.
I 16 Q
Let me put the question again.
You 17 understood, did you no't, that in order for Met Ed to 18 be able to operate TMI-2, they had to have an operating 19 license from the Nuclear Regulatory Commission?
A I understood that.
20 k
21 Q
You understood, did you not, that Babcock &
Wilcox did not have to have a license from,the Nuclear 22 Regulatory Commission?
23 MR. MacDONALD:
To operate plants?
(
g4 MR. FISKE:
To engage in the business that 25
l 611 1
zechman 2
they were engaging in.
3 A
I don't know all the business that B&W 4
engages in.
How can I say that?
They have a fuel O
5 facility.
I don't know what the --
6 Q
Did they have to have a license from the NRC to conduct a simulator training program?
7 8
MR. MacDONALD:
I am not quite understanding.
A license in what sense,the same sense as operating 9
i 10 a nuclear plant?
In other MR. FISKE:
Any kind of a license.
11 12 words, did B&W have to have approval in the form of any kind of a license from the Nuclear 13 l
Regulatory Commission in order to conduct a 14 training program in Lynchburg?
15 They have an approved program for the 16 A
r 17 start-up
- a. certification program.
18 Q
Was that part of the training you sent your 19 operators to?
A Yes, it was.
20 Q
Did they have to have a license in order llh 21 22 to operate the simulator training, conduct the simulator training that you have been referring to so frequently 23 throughout your deposition?
24 you referring to an A
When you say license, are 25 l
1 zachman 612 O
2 operator license, RO or SRO license?
3 Q
Any kind of a license?
4 MR. MacDONALD:
I object.
I don't know what O
5 you mean.
6 MR. FISKE:
I couldn't make it any more 7
simple.
8 Q
You understood, Mr. Zechman, that when Met 9
Ed operated Unit 2 they were doing that under a license from the Nuclear Regulatory. Commission and that they 10 11 couldn't operate the plant without that licenser is 12 that correct?
v 13 A
I understand that.
14 Q
Now I am asking you with respect to the 15 B&W simulator program that we have been discussing 16 here, did you understand that B&W was running that from the simulator program under any form of license 17 18 NRC and that they couldn't conduct it without approval 19 from the NRC?
A To the best of my recollection, they did not 20 have-- the simulator did not have an operating license 21 similar to an operating license at a commercial plant.
22 The simulator did have to have an approved start-up 23 certification program.
24 25 Q
Did you understand that if the NRC found
1 613 Zechman 1
O training was being given to operators 2
that inadequate 3
at Met Ed with respect to dealing with emergency 4
transient situations, that that would be a basis upon 6
which they could find the training program insufficient 5
6 and take away the license?
7 A
I recognize that they provided audits of insure we were in compliance 8
our training program to 9
with the program.
And that if there were problems in identified at that time the training program they were 10 and evaluation of the situation of those was made by 11 12 the INE.
O So you understood they were doing audits?
13 Q
f A
Yes, sir.
14 15 Q
Did you understand that if the NRC concluded 16 that the training given to Met Ed operators with respect i
in a transient were to handling emergency conditions 17 18 inadequate, that that could put Met Ed's operating 19 license in jeopardy?
A You are asking me this prior to the accident?
20 Q
Yes.
lll 21 A
Prior to the accident I guess I never 22 vein because our programs and our considered it in that 23 audits always had that program and never thought our
()
24 Program being insufficient enough to warrant anything 25
_ - - -.,, ~... _,. _ _, - - -,., _, -, -,., _ _ _...
G14 1
Zechman 2
like that.
3 Q
You mean the thought never crossed your 4
mind at any time when you were head of the Training O
5 Department as to what might happen if the NRC concluded 6
that your training was inadequate?
7 A
No.
8 Q
That was my question.
9 A
Certainly I knew we had commitments for 10 our training programs.
I knew we were audited against 11 those.
12 Q
And you knew if the NRC concluded that 13 the training being given to your operators handling 14 emergency conditions in the course of a transient 15 were inadequate that that could put your license in 16 jeopardy?
17 A
I certainly understood that if our -- if 18 they determined our training was inadequate for whatever 19 reason, that some resolution would have to be made and some determination of what the penalty for that 20 l
l 21 would be.
Whether it is a follow-up, whether it is 22 a fine, whatever.
23 Q
You understood that part of the training 1
that was given to Met Ed operators on dealing with l
f 24 l
emergency conditions in the course of a transient 25 l
l o
n
.-------w
--,w,n,---
, - -,,- --,,,<--- m.-
,----.--,--,n-...,n-e.,
,,~---,--w-,-
--,--.n,-
i 615 Zechman 1
O was done under contract with Met Ed by B&W; is that 2
3 correct?
I understand that we had a contract with 4
A O
for B&W to provide training for us.
5 B&W 6
Q That training was part of the training that you relied upon to be sure that your overall 7
the requirements of the code of 8
training program met federal regulations that you just referred to; is that 9
10 correct?
B&W program supplemented our ongoing A
The 11 We relied on B&W to provide that 12 traning program.
's-13 training and the start-up certification programs.
t 14 Q
In the last analysis if training on emergency 15 procedures was not sufficient, then Met Ed could lose 16 its license whether that deficiency occurred in the i
17 Met Ed training or in the training that was contracted 18 to B&W is that correct?
A You are getting into a legal question and 19 in a position to answer legal I don't feel that I am 20 questions like that.
lll 21 Q
Mr. Zechman, I didn't refer to a legal 22 question.
I am simply asking you.
You are head of 23 You are responsible for this the Training Department.
/~S 24 U
the NRC and the FSAR, Program that has been described to 25
616 1
Zechman O
ever occur to you while you were running 2
and did it 3
the Training Department that you better be sure in your 4
own mind that you are satisfied that the training that 9
the operators on dealing with emergency 5
is being given to 6
conditions in a transient is sufficient?
7 A
Please read that question back.
8 (Question read)
I As head of the Training Department, 9
A 10 relied on the procedures that were given us in the in the training and guidance 11 operation of our plant, 12 that we received and the training we received at the O
13 simulator.
What is adequate and sufficient is 14 everybody's responsibility, not just the head of the 15 Training Department.
That includes the training we 16 got from the simulator as well.
It is everybody's 17 responsibility to insure that we have procedures and that we receive training accordingly.
18 19 Q
If the training was adequate, including 20 the trairing at B&W, Met Ed was the one who was going to i948e the license; is that correct?
21 A
If the NRC made that determination?
22 23 Q
Right.
So it was important to you, was it l
as head of the Training Department to make your
[~')
24
- not,
%/
25 own jud9 ment as to whether including the information
-,r
~
I 617 I
Zachman O
2 that was being taught at B&W and all the other in fo rma tio, 3
that you had at Met Ed, the training program met the 4
requirements of the code of federal regulations?
O 5
A As I said, it was a cooperative effort 6
on what was adequate.
Certainly we relied a great deal 7
on the vendor of the plant to be able to tell us how 8
to operate that plant.
9 Q
'I think you have said that on numerous 10 occasions, and I think we understand that.
11 A
O.K.
Therefore we relied on them giving 12 the correct information on the operation on that plant.
13 You can't separate that.
14 Q
What I am getting at, Mr. Zechman, you 15 didn't put a blindfold over your eyes insofar as 16 emergency training procedures are concerned.
"I wouldn't 17 worry about that, that's being done at B&W.
I don't 18 have to look what they are doing or whether I think l
19 that's sufficient.
I will let them do that and I won't 20 pay any attention to it"?
21 A
I didn't imply that at all.
l ggg 22 Q
You made your own independent review to 23 satisfy yourself that sufficient training was being 24 done on emergency procedures, correct, including a
()
25 review, in fact, of what was being taught in your
~~~
I 618 1
Zechman O
and including what was being taught 2
Training Department 3
at B&W?
4 A
If that is to imply that I thought of every 0
5 possible situation that could happen in the plant and 6
the operation of that plant, I don't believe I am a 7
superman of that type.
8 Q
Do you think there are supermen of that 9
type at B&W?
think the people who manufactured the unit 10 A
I 11 certainly should be expert on that unit.
12 Q
And shouldn't the people that are operating O
13 it.also be expert on the operation of that unit?
They should be expert on the operation based 14 A
15 on what they were told how to operate that.
as well By you in your Training Department 16 Q
17 as by B&Ws is that correct?
f from both 18 A
Input to the training program _came 19 directions.
MR. MacDONALD:
Let's take a break.
20 (Recess taken) lll 21 22 BY MR. FISKE:
Are you familiar with a publication put out 23 Q
State by the Nuclear Reactor Facility of Pennsylvania
()
24 in Nuclear Power University entitled "A Lecture Series 25
,-e
,w-
,--------g-
---v-w
l l
1 1
Zechman 6J 9 O
2 Plant Operations Training"?
3 A
Yes, I am.
4 Q
Were you a contributor to that publication?
O 5
A Yes, I was.
6 Q
was that publication provided to the Met 7
Ed Training Department for use in the training of your 8
operators?
9 A
Yes, it was.
Not in all training programs.
10 It was provided to Met Ed to be used where they felt 11 necessary to use it.
12 Q
In other words, to the extent that there I
13 was material in here that you or whoever else was 14 making decisions felt would be useful in your training 15 program, you would use it; is that correct?
16 A
That's generally the way it was, yes.
17 MR. FISKE:
I would like to mark as the 18 next exhibit, a collection of pages which we 19 will formally bind together at some appropriate 20 point.
Mark this as B&W 570.
at bottom (Collection of pages with numbers lll
' from 0565 to 0956 were marked B&W Exhibit 21 22 running 23 570 for identification, as of this date.)
~
24 MR. FISKE:
For the record, I would like to indicate that the collection of pages that are 25
--r r
p
-m.--
L 620 Zechman 1
0 2
being marked as B&W Exhibit 570 have numbers at the bottom running from 0565 to 0956.
3 4
Q Let me show you this exhibit, Mr. Zechman, O
and ask you whether you recognize from the cover the 5
referred to.
6 pamphlet or brochure you have just 7
A I recognize the cover but there were 8
several different editions of this.
I don't know 9
which edition this is.
10 Q
All right.
Let me direct you to the page which has 11 12 the number 0576 through numbers 0584 and ask you if
\\-
13 you recognize those as the table of contents for 14 this publication?
MR. MacDONALD:
Would you give him a minute 15 16 to leaf through this?
17 Q
Have you had an opportunity, Mr. Zechman, 18 to look through that exhibit?
have scanned through the exhibit.
19 A
I from this exhibit 20 Q
Let me show you a page 21 marked No. 0574 entitled "A Lecture Series in Nuclear llh Power Plant Operators Training," and it-list 22 contributors and a list of individuals.
Do you see 23 l
that?
24
\\e A
Yes, I do.
25 O
._.,,e
_ - ~,,. -,.,. - -. - -.
621 1
Zechman 0
2 Q
Are you listed as a contributor?
3 A
Yes.
4 Q
For what subject matters?
O 5
A Basic physics, atomic physics, basic 6
nuclear physics and fission shielding.
Back to the table of contents that we 7
Q 8
looked at a moment ago, can you tell which chapters 9
deal with those topics?
10 A
Chapter 2, Chapter 3, Chapter 4, Chapter 10.
11 Q
How many chapters are there altogether?
assuming I have 12 A
In this issue there are 13 the full set of table of contents here, there are ten l
14 chapters.
15 Q
This also lists as contributors a man 16 named John L. -- maybe you can read that for me.
17 A
Penkala.
18 Q
Did you know Mr. Penkala during the period this you were writing your section of I
19 of time that 20 publication?
A I did.
lll 21 22 Q
Who is Mr.
Penkala?
23 A
Mr.
Penkala was in charge of the training the Penn State Nuclear Reactor Facility.
section of 24 25 Q
The next individual listed is Donald A.
Ross
622 1
~Zechman 0
2 Did you know Donald A.
Ross during this period of time?
3 A
Yes.
4 Q
Who is he?
O I forget his 5
A In that period of time 6
exact title.
7 Q
Was he also located at Penn State?
8 A
Yes, and physically located at the nuclear 9
reactor facility.
10 Q
To save a little time, page 0575 contains a 11 notice which says " original notes compiled March 1969 12 and revised April 1969."
O 13 Do you see that?
A I see that.
14 15 Q
During that period of time, were all the 16 individuals that are listed as contributors to this Publication affiliated with Penn State?
17 18 A
To the best of my recollection they were.
l i
was George Geissler's position at that 19 Q
What 20 time?
A Geissler had -- if my recollection is lll 21 I
22 correct, had the same faculty title as Don,Ross.
23 can't recall what that was.
Q What was your position at that time?
(
24 A
At that time I was a training supervisor.
25 l
\\
4%
\\
1 Zechman 623 O
there was such a thing, where did Mr.
2 Q
If 3
Geissler range in the hierarchy as compared to you?
4 A
Above me.
O 5
Q Would it be fair to say that this 6
publication was a joint effort by several individuals
-- affiliated with Penn State University?
7 on the 8
A That's correct.
Did you ask any of the other individuals 9
Q 10 that were contributing to the publication to review 11 the sections that you wrote?
12 A
To the best of my recollection, John 13 PSnkala reviewed those.
14 Q
Did you review sections that the other 15 authors wrote?
i l
16 A
I did not.
I 17 Q
I would like to refer to page 9-71 which is part of the chapter en instrumentation and control 18 Geissler end this bears the number 0899 19 written by Mr.
20 at the bottom.
I will read a section of this'9.14.2.5.
Accurate assessment "Importance of pressure measurement.
l 21 22 of pressure and the resulting control actions are of 23 paramount importance in a PWR if the pressure increases 24 beyond a certain point, certain irreversible relief devices are provided such as safety valves and rupture 25 j
l 624 Zechman 1
C) disks, which while protecting the primary piping, produce 2
3 an inevitable shutdown of the reactor.
If pressure 4
decreases the possibility exists that boiling will O
5 begin, which may produce a sufficient change in the 6
heat transfer from the core to cause damage to fuel."
Did you review that paragraph at any time 7
in connection with your training responsibilities at 8
9 Met Ed?
that You pick one paragraph out of there 10 A
11 I simply don't recall at this time.
It's been too 12 long a period of time.
A I think you testified that this book was 13 14 made available to Met Ed for use in your training 15 program.
16 A
That's correct.
any time while you had any responsibilities 17 Q
At including the period of time 18 in the Training Department, in charge of it, did you review this l
19 that you were you felt publication to determine which portions of it 20 would be useful in training operators at Met Ed?
lll 21 A
I guess I have to give you some historical 22 background on use of those books.
The books initially 23 were used for tho, initial cadre of operations personnel
("%
24
\\j for Unit 1.
The books then were used on the Island for 25 i
1 625 1
Zechman 2
the training of operators most of which was -- I can't 3
say -- some of which was aircady completed by the time 4
I joined Metropolitan Edison.
After that period of O
5 time, they were used, different sections were used and 6
not entirely the entire book.
I can't recollect right 7
now at this point in time which sections we used when 8
and which sections I reviewed at that time.
9 Q
I guess my question was, did you make an 10 effort to review the entire publication apart from the that you obviously had written yourself to determine 11 part sections whether there was anything in any of those 12 I
in the Met Ed training program?
l which would be useful k
13 14 A
I recall reviewing the book.
I don't 15 recall any longer what sections or if I reviewed the recall making a r'eview at times.
16 entire book.
I do 17 g
I would like to read again one sentence 18 from the paragraph I read a moment ago where it says, decreases the possibility exists that 19 "If pressure sufficient l
boiling will begin which may produce a l
20 I
21 change in the heat transfer from the core to cause i
)
damage to fue'1."
22 I would like to ask you, based on your I
23 l
knowledge and understanding of the system prior to the
/
24 Island accident,'did you have any understandin g
Three Mile 25 a.,--
l 626 Zechman 1
O 2
that that statement is inaccurate in any way?
3 A
I believe I a'iready testified relative to 4
the question of if pressure decreases, did I have an O
5 understanding from a theoretical point that if pressure 6
decreased that the boiling could have occurred.
I 7
already stated from a theoretical standpoint I understood 8
that.
You referred several times during this 9
Q 10 deposition to the fact that you knew that from a 11 theoretical standpoint.
I take it that once, in fact, 12 the pressure reaches that point and boiling starts, it s/
13 is not theoretical anymore?
4 A
I am talking about an understanding, a 14 theoretical understanding as opposed to a practical 15 applied to our plant.
16 situation, as 17 Q
You mean you knew of no situation in which saturation had decreased to the point where 18 pressure 19 had occurred?
MR. MacDONALD:
Prior to the accident?
20 I
MR. FISKE:
Yes.
l 21 from I told you from a theoretical point l
A 22 f
it never occurred to practical application to our plant 23 24
((}
Q In other words, it never occurred to you 25 i
I 627 Zechman 1
O 2 a drop in pressure would produce boiling?
2 that at Unit The We never observed it on the simulator.
3 A
4 focus wasn't on that in our training at the simulator O
5 or in the operation of the simulator.
MR. FISKE:
I will move to strike that.
6 7
Q That is not my question, and I believe you 8
know that, M r.
Zechman.
I am asking you MR. FISKE:
Read the question back again.
9 (Question read) 10 to the accident It never occurredto me prior 11 A
12 that decreasing pressuring as applied to our plant O
going to cause boiling because our emphasis wasn't 13 was i
on that.
14 Did you think there was something different l
15 Q
from other prassurized water reactors 16 about your plant 17 so that a drop in pressure wouldn't cause boiling at 18 your plant?
A The focus was on maintaining level such 19 that inventory -- I am trying to tell you that our 20 training was such that our focus was not on that and lll 21 therefore not considered.
22 23 Q
In other words, that was the focus, you say, training that you gave your operators in the Met of the
)
24 Ed training program?
25
628 Zechman 1
O 2
A I am saying the focus of our training both 3
from B&W and in-house was on maintaining level and as 4
long as we did that, the core'was sufficiently O
5 inventoried.
6 Q
I guess you are telling us that for whatever 7
reason, nobody ever brought to your attention or 8
anybody else's in the Training Department the fact 9
that incidents had occurred at TMI-2 in which there 10 had been saturation as a result of drop in pressure?
11 A
I think I already testified to that, sir.
12 Q
So nobody told you that this theoretical 13 concept that you described had, in fact, occurred in 14 real life on more than one occasion, right there at 15 Unit 27 16 MR. MacDONALD:
Are you asking whether or
' old him saturation occurred at t
17 not anyone ever 18 Unit 2 prior to the accident?
MR. FISKE:
Could you read the question back?
19 (Question read) 20 A
Prior to the accident?
f lll 21 22 Q
Yes.
A I already testified to that.
23 l q 24 0
l Going back to this sentence one more time, it
~'
25 8
=
l 629 Zechman 1
2 reads, "If pressure decreases, the possibility exists that boiling will begin which may produce a sufficient 3
4 change from the heat traasfer from the core to cause O
damage to fuel."
5 How did you understand that boiling in 6
fuel?
reactor system could cause damage to the 7
the 8
A As related to our training.
How did you understand it?
9 Q
MR. MacDONALD:
Prior to the accident?
10 11 Q
I am not limiting it. Mr. Zechman, which I believe I made clear on numerous occasions on what you
.12 the operators' may have trained your operators on or what 13 I am simply may have learned from any other source.
14 accident how did you understand as 15 asking prior to the head of the Training Department boiling in the core t
16 17 could cause damage to the fuel?
f I
18 A
The training I had with respect to the core
(
always had to do with --
19 l
i Q
Pressurizer level.
We are not asking about i
20 I
that, Mr. Zechman. I am not asking what your training l
lll 21 just made clear in my last question.
22 was, as I believe I i
f is Maybe we could read it back one more time so there i
23 i
no possible mistake about it.
24 O
(guestion read) 25 i
e
1 Zechman 630 0
My prior knowledge and own training relative 2
A 3
to fuel damage had to do with transfer of heat from 4
the elements relative to DNBR.
It did not have anything 9
5 to do, it did not -- well, that's what my prior 6
experience has been.
7 Q
You did understand, did you not, that 8
boiling in the reactor coolant system could cause 9
damage to the fuel?
10 A
Again, I put it in the light that we are 11 talking about damage to the fuel-in relationship to the 12 fuel-being able to transfer heat to the coolant.
Not 13 as the RCS, as a collectivs body.
For whatever the mechanics.of it were,you
'. 4 Q
15 did understand that if boiling occurred in the core that 16 could cause fuel damage?
MR. MacDONALD:
You mean the core itself?
l l
17 I
18 MR. FISKE:
The core is part of the reactor 19 coolant system, isn't it?
A Yes, but when we are limiting the effects 20 of fuel and the transfer of heat from fuel, that is a 21 ggg surface effect.
22 f
23' -
Q I am talking, Mr. Zechman,about the type of I
hoiling that results from a drop in pressure.The same 24 in the 25 type boiling
.that Mr.Ceissler is talking about
.i L
^-*
l 631 1
Zechman 2
publication that was part of your materials in your 3
training program.
Do you understand that?
4 A
I can't speak for Mr. Geissler.
I can only 0
5 speak for myself.
6 Q
I just want to make it clear what I am asking 7
you.
I am asking it in reference to the sentence in Mr. Geissler's part of this publication which reads, 8
"If pressure decreases, the possibility exists that 9
10 boiling will begin."
That is the type of boiling I 11 am asking you, the type of boiling that results from a 12 decrease in pressure and goes on to say, "which may 13 produce a sufficient change in the heat transfer from the core to cause damage to the fuel."
14 I am simply asking you, didn't you understand 15 16 before the accident that if boiling occurs as a result 17 of drop in pressure that that boiling by whatever means 18 can cause damage to the fuel?
I A
I am going to repeat my testimony that 19 already said, I theoretically understood that if pressure 20 I will repeat that dropped that boiling could occur.
ll 21 the core my limitation -- my understanding relative to 22 fuel or had to do with surface effects on the and DNBR 23 in channels of the fuel.
24 25 Q
Taking that answer as you gave it, am I e
n r..-
I 632 Zec hman 1
0 in understanding that you did know before the 2
correct 3
accident that if boiling occurred in the reactor coolant 4
system as a result of drop in pressure that boiling 5
could cause damage to the fuel?
It was referred to localized boiling in 6
A 7
the core.
Never in reference to bulk boiling in the 8
RC system.
9 Q
What produced this localized boiling that 10 you are referring to?
11 A
You have -- assuming the worst case where 12 you are going to get localized effects on the field.
Broad configuration could localize the heat in a 13 Particular part ti the core.
Localizing it to a 14 i
15 Particular fue1 assembly.
I 16 Q
So in other words, if there was localized boiling as you have just described it that could cause 17 18 damage to the fuel at the point where that boiling occurred, is that your testimony?
19 A
Our training was such that we realized the 20 difference of nuclear boiling to film boiling. If the 7g heat transfer was through one of those modes that that is 22 the surface effect you would get.
23 And that boiling could be produced by a Q
24 drop in pressure?
25
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.-~-e,
_,a.,,.
,-----n
--,-,e-
,,w--
-v
,----,,,,-,--,er
+-------a
,-,-----e-,---.-4
l 633 1
zachman 2
A No, that's where we differ.
3 Q
You are talking about some type of boiling 4
that occurs without a change in the basic pressure 9
temperature relationship?
5 6
A Due to the localized flux distribution.
7 Q
That is one case, the localized flux 8
distribution.
Didn't you understand that if that same 9
type of boiling was caused by a drop in pressure that 10 the same would occur?
That never occurred to me prior to the 11 A
12
- accident, You certainly had no reason prior to the 13 Q
14 accident to exclude that type of boiling as a cause for 15 a type of fuel damage?
16 A
I repeat that that never occurred to me 17 prior to the accident.
18 Q
Let's get a couple of basic things here 19 straight.
Didn't you understand before the accident that what keeps the water in the reactor coolant system 20 from boiling is maintaining the proper pressure lll 21 22 temperature relationship?
I A
I told you from a theoretical point 23 understand that a PWR operates at elevated pressures 24 s
25 to prevent boiling.
- - ~
634 1
Zechman O
2 Q
And if the pressure drops below what you 3
referred to before as the Tsat temperature, then 4
you will have boiling; is that correct?
O 5
A Repeat that question.
6 (Question read) 7 A
From a theoretical standpoint, I understand 8
that when the pressure drops from that point you would 9
have boiling.
10 Q
Let's look at the steam generator for a 11 second.
All right?
12 A
o x, 13 Q
What types of fluid are in the steam
(
i 14 generator?
15 A
We have liquid, we have steam, and we have 16 superheated steam.
17 Q
What did you understand caused the change 18 in the steam generator from water into steam?
19 A
Transfer of heat from the primary to the l
the water passed through the tubes, passed 20 secondary as 21 by the tubes, the water would heat up as it traveled lll l
22 up to a point where it flashed to steam and then went by a section that was not wetted and picked up more 23, 24 heat and became superheatcu.
25 Q
What turned the water in the steam generator i
l a
a
635 1
Zechman O
2 into steam was a change in the pressure temperature 3
relationship; is that correct?
4 A
I understand that.
That's the way the G
5 training was.
6 Q
Nothing theoretical about that?
7 A
That's correct.
8 Q
You certainly understood if that same type 9
of change occurred in the primary side you would have j-10 steam in the primary side?
never occurred to me prior to the 11 A
That 12 accident.
We didn' t discuss that.
You mean it never occurred to you once 13 Q
14 before the accident as head of the Training Department 15 at Met Ed that if in the primary system the pressure relationship changed entirely that you --
16 temperature Is that 17 the water in that system could turn to steam.
18 seriously your testimony?
It never occurred to me prior to the accident k
19 A
s of having a saturated RC system.
20 21 Q
Any saturation in the system outside the ggg 22 pressurizer?
From a theoretical standpoint I A
Yes.
23 understand that.
From a practical application to our 24 25 reactor, I did not consider that.
I 1
l l
1 636 Zechman 1
2 Q
It never occurred to you at any time that to for keeping pressure up was 3
one of the reasons 4
prevent the water in the reactor coolant system from O
5 turning it into steam?
said from a theoretical standpoint I
6 A
I 7
understood that.
to the fuel Did you understand that damage 8
Q the possibility of radiation being 9
could increase 10 released into the atmosphere?
11 A
I certainly understood if the fuel damage 12 was significant enough, the f is sion products were released to the RC system, that there are sets of O
13 radioactivity under certain conditions in which that 14 conditions could be released to the atmosphere.
You 15 16 have to have a whole set of conditions, different 17 Paths that would have to take for that to happen.
18 Q
Is it correct that if the damage to the --
that you understood prior to the 19 isn't it correct accident that if the damage to the fuel resulted in 20 into the reactor the release of radioactive material lll 21 at that that there was only one barrier left
- building, 22 point between release of radiation into the atmosphere?
23 First your assumption is that we have had A
24 were released to the fuel damage and fission products 25 J
~ _ - - _ -
637 Zechman 1
O RC system and by some means the fission products got 2
into the reactor building.
3 4
Q Yes.
S Somehow got there.
That the reactor 5
A containment of building was the last' barrier for the 6
7 that radiation.
as a barrier 8
Q I am asking you what was left 9
to release the radiation to the atmosphere after that a
10 point?
should that 11 A
Assuming that it was not 12 occur and should there be inventory that was not t
l transferred somewhere else, suppose the activity got 13 Transferred from the sump to the waste 14 in the sump.
it.is you assuming that 15 facilities. Assuming that -- are else?
I don't understand in there and not going anywhere 16 17 your boundary conditions.
18 Q
Let's put it this way You had as part of ther training on radiation, did you 19 requalification program l
not?
20 A
sure.
21 lll it was W'hy did you tell your operator,s that 22 Q
23 important not to allow damage to occur to the fuel?
of reasons.
One certainly there are a lot A
24 One, release of was the integrity of the core itself.
25 D
~ ~ ~ -
~ ' ^ - - -
- '*W
'i w'-
- + - - - -,. _ _
1
^
i 638 zechman 1
those being able fission products, the possibility of 2
That you wanted to 3
to be released to the atmosphere.
4 make sure -- well, so we talked about integrity of the S
5 core, we talked about fuel damage, assuming it is 6
significant enough that f ission product's would be 7
released, those are the two main ones that I recall at 8
this time.
it never occurred 9
Q Is it your testimony that 10 to you before the accident that one of the reasons it was important to maintain pressure was to prevent 11 i
from occuring under which, by 12 certain circumstances i
boiling could occur which reason of a drop in pressure, 13 damage which could increase the i
could cause fuel 14 atmosphere?
likelihood of radiation being released to the 15 A
Pressure temperature relationships in that 16 focused on the operating reactor 17 light were always 18 within the pressure temperature envelope which was exceeding the BNBR ratio.
associated with not 19 would l
I have understood what you said and I 20 Q
like you to listen to the question one more time and see lll 21 if you can answer it.
22 (Question read) 23 I already testified to the fact that prior A
24 to fuel damage to the accident my knowledge relative 25 i
641 O
INDEX i
Witness Page Richard W.
Zechman 525 EIBIB ITS B&W For Ident, 570 Collection of pages with numbers at bottom running from 0565 to 0956 619 oOo l
l l
O
1 Zechuan 639 2
had to do with surface effects of fuel elements and 3
related to the transfer of heat from those elements.
4 It was not related to a. decrease in pressure of the 5
RC system.
6 Q
So that it never occurred to you that 7
boiling which resulted from a drop in pressure could 8
cause fuel damage which could increase the dangers 9
of releasing radiation; is that your last answer of the 10 day?
11 A
Repeat the question.
12 (Question read) 13 A
I already testified to that in my previous 14 answer.
15 Q
Do I understand that the answer is no?
16 A
The answer is prior to the accident it did 17 not occur to me of that relationship.
18 MR. FISKE:
This is a good time to stop.
19 (Time noted:
4:15 p.m.)
20 000 21 Richard W.
Zechman 22 Subscribed and sworn to 23 before me this 24 day of 1982.
7
i 1
640 CERTIFICATE 2
3 lvJ ii STATE OF NEW YORK
)
3 l i
- ss.:
7 COUNTY OF NEW YORK
)
4
()
I, Catherine cook
, a Notary
[
Public of the State of New York, do hereby 6
(
i certify that the continued deposition of l
7 Richard W.
Zechman was taken before 8
1 me on March 25, 1982 consisting i
9 i
i of pages 524 through 641 10 l
I further certify that the witness had l
11 I
been previously sworn and that the within l
t transcript is a true record of said testimony; l
13 That I am not connected by blood or 14 I
I marriage with any of the said parties nor r
1 i
i interested directly or indirectly in the matter i
l 16 I
in controversy, nor am I in the employ of any j
1 i
of the counsel.
l 18 l.
IN WITNESS WHERE3F, I have hereunto set my hand this c)N day of kfCh
, }98L j
20 l
3 i
21 l
22 r,
LM ip e AC12 l
{
catherine Cook I
24 25 l
s 1
l l
-