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{{#Wiki_filter:bt                                                                                 157
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[x
[x
    \_)                       UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK
\\_)
                              - - - - - - -- - - - -- - -- -        - - -x GENERAL PUBLIC UTILITIES CORPORATION,         a h                   JERSEY CENTRAL POWER & LIGHT COMPANY, METROPOLITAN EDISON COMPANY and               :
UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK
PENNSYLVANIA ELECTRIC COMPANY, a
- - -x GENERAL PUBLIC UTILITIES CORPORATION, a
h JERSEY CENTRAL POWER & LIGHT COMPANY, METROPOLITAN EDISON COMPANY and PENNSYLVANIA ELECTRIC COMPANY, a
Plaintiffs, s
Plaintiffs, s
                                      -against-                               80 Civ. 1683
-against-80 Civ. 1683 (RO)
:      (RO)
THE BABCOCK & WILCOX COMPANY and J.
THE BABCOCK & WILCOX COMPANY and J. RAY McDERMOTT & CO., INC.,
RAY McDERMOTT & CO.,
Defendants.         :
INC.,
                                                          - - - - - - - -x (r'%)                                     Continued deposition of General Public Utilities Corporation by RICHARD W. ZECHMAN, taken by Defendants, pursuant to adjournment, at the offices of Davis Polk & Wardwell, Esqs.,
Defendants.
(                                     One Chase Manhattan Plaza, New York, New York, i
- - - - - - - -x (r'%)
l                                     on Thursday, March 11, 1982, at 9:45 o' clock l
Continued deposition of General Public Utilities Corporation by RICHARD W.
: ZECHMAN, taken by Defendants, pursuant to adjournment, at the offices of Davis Polk & Wardwell, Esqs.,
(
One Chase Manhattan Plaza, New York, New York, i
l on Thursday, March 11, 1982, at 9:45 o' clock l
in the forenoon, before Robert Capuzelo, a Shorthand Reporter and Notary Public within i
in the forenoon, before Robert Capuzelo, a Shorthand Reporter and Notary Public within i
I and for the State of New York.
I and for the State of New York.
5 I
5 I
    /3                                                             DOYLE REPORTING, INC.
/3 DOYLE REPORTING, INC.
CERTIFIED STENOTYPE REPORTERS 369 LExlNGTO N AVENUE WALTER SHAP!RO, C.S.R.                               NEw YomK. N.Y. 10017
CERTIFIED STENOTYPE REPORTERS 369 LExlNGTO N AVENUE WALTER SHAP!RO, C.S.R.
,                  CHARLES SH APIRO, C.S.R.                             TELEPMONE 212 - 867-8220 8306290781 820311
NEw YomK. N.Y.
(     's     gDR ADOCK 0500028
10017 CHARLES SH APIRO, C.S.R.
TELEPMONE 212 - 867-8220 8306290781 820311
(
's gDR ADOCK 0500028


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                                                                                                      )-       ;
1 158 i
158                           i w
w s,_)
s,_)         2   Appeara nc e s:
2 Appeara nc e s:
3 4
3 4
KAYE, SCHOLER, FIERMAN, HAYS & MANDLER, ESQS.
KAYE, SCHOLER, FIERMAN, HAYS & MANDLER, ESQS.
Attorneys for Plaintiffs ggg   5                 425 Park Avenue New York, New York 6
Attorneys for Plaintiffs ggg 5
By:   ANDREW MacDONALD, ESQ.,
425 Park Avenue New York, New York 6
7                       -and-JULIET NEISSER, ESQ.,
By:
ANDREW MacDONALD, ESQ.,
7
-and-JULIET NEISSER, ESQ.,
of Counsel 9
of Counsel 9
10 11 DAVIS POLK & WARDWELL, ESQS.
10 11 DAVIS POLK & WARDWELL, ESQS.
Attorneys for Def3ndants l~o One Chase Mahhattan Plaza
Attorneys for Def3ndants l~o One Chase Mahhattan Plaza New York, New York By:
  ,                            New York, New York                                                     .-
ROBERT B.
By:   ROBERT B. FISKE, ESQ.,
FISKE, ESQ.,
14
14
                                      -and-KAREN E. WAGNER, ESQ.,
-and-KAREN E.
10 o'f-Counsel 16
WAGNER, ESQ.,
                                                                                            -4 g                                                                       i 18                                                                               '
10 o'f-Counsel 16 i
Also Present:                                                   '
-4 g
y       ,
18 Also Present:
19                                                                                       l SUSAN HANSON, Paralegal           -                                      s
y l
                                                                                \
19 SUSAN HANSON, Paralegal
Davis Polk & Wardwell, Esqs.
\\
20 21                                                     .                    I k                                                                                         l 22                                                                                     I I
s Davis Polk & Wardwell, Esqs.
23  '                                                              /'
20 21 I
                ;                                                3       ,                    _,
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                              'r                 ,1 159
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        -( '
159 4
          >            4 2       P. ICHA RD             W.     ZEC HMAN,           resumed, 3             having been previously duly sworn by the 4 y          Notary Public, was examined and testified lll               5             further as follows:
-( '
2 P. ICHA RD W.
ZEC HMAN,
: resumed, 3
having been previously duly sworn by the 4
Notary Public, was examined and testified y
lll 5
further as follows:
6 EXAMINATION (Continued) 1 t
6 EXAMINATION (Continued) 1 t
7I     B$ MR. FISKE:
7I B$ MR. FISKE:
ss 0
s s 0
Q     Mr. Zechman, do you realize you continue d
Q Mr. Zechman, do you realize you continue d
9'         ~
9' to he under octh today?
to he under octh today?
~
i
i 10
                                ,(             10            A a <
,(
I d, o .
A I d, o.
gj                      I .''                 11 MR. MacDONALD:       Regarding a recent t
a <
I.''
11 gj MR. MacDONALD:
Regarding a recent t
12
12
                                        /                     producticn of some documents from the training
/
[ \
producticn of some documents from the training
(u      ,/
[ \\
                        )                     13 d ep a r tmeri t , you asked me to inquire as to 14 where thoss documents came from, and I spoko
(
                                  ,\         15 to Rochelle Hanson who I understand was the
)
                                    /
13 d ep a r tmeri t, you asked me to inquire as to u,/
                                            +
14 where thoss documents came from, and I spoko
16
,\\
                                    ,\
15 to Rochelle Hanson who I understand was the
individual from our firm who sent the letter 17 down, and her understanding is those are i
/
18              general    ~ training department documents, and
+
\o           ,
,\\
19             that is where they came from, culled from the l /
16 individual from our firm who sent the letter 17 down, and her understanding is those are i
      ,        /                             20             training department files as a whole, no particular s
~ training department documents, and 18 general
    '.                                        21             individual's files.
\\o 19 that is where they came from, culled from the l /
                              ~
/
22                     There may be documents in there from many l
20 training department files as a whole, no particular s
23
21 individual's files.
                                                    ,        different individuals, but that is my best 24             understanding of that box of documents.
l
l                                             25   i                 MR. FISKE:     Thank you.
~
22 There may be documents in there from many 23 different individuals, but that is my best 24 understanding of that box of documents.
l 25 i
MR. FISKE:
Thank you.
l
l


I Zechman                     160 m
I Zechman 160 m(,)
(,)         2       Q     Mr. Zechman, when we left off yesterday 3 evening, you were aoing to look at B&W Exhibit 557 4 which has been the subject of the questioning near ll) 5 the end of the afternoon, and let us know, after 6
2 Q
reviewing it, whether you wanted to change any of 7 the answers that you had given concerning whether 8 specific programs described in this exhibit had 9 been given during the period of time while you were 10 in charge of the training department.
Mr. Zechman, when we left off yesterday 3
11             Have you done that?
evening, you were aoing to look at B&W Exhibit 557 4
12       A     I have read the document. One point s
which has been the subject of the questioning near ll) 5 the end of the afternoon, and let us know, after 6
reviewing it, whether you wanted to change any of 7
the answers that you had given concerning whether 8
specific programs described in this exhibit had 9
been given during the period of time while you were 10 in charge of the training department.
11 Have you done that?
12 A
I have read the document.
One point s
13 of clarification --
13 of clarification --
(v) 14             Are there any changes you would like to Q
(v) 14 Q
15 make?
Are there any changes you would like to 15 make?
16             MR. MacDONALD:   I don't think it is 17       necessarily changds. He may want to amplify.
16 MR. MacDONALD:
I0       A     In reviewing these, the setting with which 19 these were given were related to the initial 20 cold license   program and program associated with the 21 initial staffing.
I don't think it is 17 necessarily changds.
22             After the initial staffing, both the 23 magnitude --
He may want to amplify.
the context of the training programs 24 changed from a cold license     program to a hot license
I0 A
  -,e
In reviewing these, the setting with which 19 these were given were related to the initial 20 cold license program and program associated with the 21 initial staffing.
  ,    a
22 After the initial staffing, both the 23 magnitude the context of the training programs 24
  't.
-,e changed from a cold license program to a hot license a
't. '
25 training program and may have not included all the
25 training program and may have not included all the


l l
l 1
1                            zechman                   161
zechman 161
(_,)       2   same kind of programs each of these did for the 3   initial staff.                                         !
(_,)
4               There are certain lectures, programs, jll   5   that are identified in here that we may still 6   conduct in our training, but not in the same framework 7   that these are spelled out.
2 same kind of programs each of these did for the 3
8               One other point of clarification, and 9   that has to do with the period with which I was in 10   charge. I'm assuming it is understood in the 11   period of   9/78 up to the time of the accident that 12   my position was in training, and during that f3
initial staff.
(~j)    13   period of time the supervisor of training or acting 14   supervisor of training, as I should put it, was 15   shared between Mr. Frank   }!cCormack and Marshal 16   Beers during that period with full responsibility 17   and authority.
4 There are certain lectures, programs, jll 5
18         Q     You had a position during that period 19   of supervisor of training, did you not?
that are identified in here that we may still 6
20         A     I had the title, yes.
conduct in our training, but not in the same framework 7
21         Q     Yesterday, Mr. Zechman, we made some 22   references to the portion of the Met Ed FSAR which 23   deals with the training program.
that these are spelled out.
g3      24                 I would like -- this is B&W Exhibit L]
8 One other point of clarification, and 9
25   206 -- to hand you that and refer you to a portion
that has to do with the period with which I was in 10 charge.
I'm assuming it is understood in the 11 period of 9/78 up to the time of the accident that 12 my position was in training, and during that f3 13 period of time the supervisor of training or acting
(~j) 14 supervisor of training, as I should put it, was 15 shared between Mr. Frank
}!cCormack and Marshal 16 Beers during that period with full responsibility 17 and authority.
18 Q
You had a position during that period 19 of supervisor of training, did you not?
20 A
I had the title, yes.
21 Q
Yesterday, Mr. Zechman, we made some 22 references to the portion of the Met Ed FSAR which 23 deals with the training program.
24 I would like -- this is B&W Exhibit g3L]
25 206 -- to hand you that and refer you to a portion


1                               Zechman                     162
1 Zechman 162
[\/   '
[
2     which is captioned " Metropolitan Edison Requalification 3     Program."
\\/
4                   I believe you testified yesterday that lll   5     this program was conducted during the period of time 6     November 1977 through March '79.
2 which is captioned " Metropolitan Edison Requalification 3
7                   MR. MacDONALD:   Are you asking whether 8             that is his testimony or are you --
Program."
9           Q     That is a fact, is it not, that the 10     requalification program was going on during that 11     period of time?
4 I believe you testified yesterday that lll 5
12             A     What were the dates?
this program was conducted during the period of time 6
(~)S s _.      13             Q     November '77 to March '79.
November 1977 through March
14             A     That was the time requalification programs 15     were going on. There were amendments   in that 16     interval.
'79.
17             Q     The Met Ed FSAR states that, "The basis 18 of the requalification program is the need to 19     maintain operator competence and proficiency in the 20     quest for continued safe operation."
7 MR. MacDONALD:
21                   Do you see that?
Are you asking whether 8
22                   MR. MacDONALD:   Section 13.2.2?
that is his testimony or are you --
23                   MR. FISKE:   Yes.
9 Q
That is a fact, is it not, that the 10 requalification program was going on during that 11 period of time?
12 A
What were the dates?
(~)S 13 Q
November '77 to March
'79.
s _.
14 A
That was the time requalification programs 15 were going on.
There were amendments in that 16 interval.
17 Q
The Met Ed FSAR states that, "The basis 18 of the requalification program is the need to 19 maintain operator competence and proficiency in the 20 quest for continued safe operation."
21 Do you see that?
22 MR. MacDONALD:
Section 13.2.2?
23 MR. FISKE:
Yes.
3
3
(~)
(~)
    '\, /
24 I
24   I A     I see that.
A I see that.
23             Q     Was it your understanding that that was
'\\,
/
23 Q
Was it your understanding that that was


1                             Zechman                     163
1 Zechman 163
( ,/
(,/
2   the purpose of the requalification program?
2 the purpose of the requalification program?
3         A       It's my understanding that was the 4   purpose of the requalification program, yes.
3 A
lll 5         Q       Is it correct that some time in 1978, 6   beginning some time in 1978, the control room operators 7   attended requalification training sessions less 8   frequently than they had previously because of a 9   change in the shifts from uix to five?
It's my understanding that was the 4
10         A       That is not necessarily true. They are 11   required to spend a minimum of 60 hours per year 12   in training, minimum. Normally we conducted a (g) u-13
purpose of the requalification program, yes.
                                ~
lll 5
training program that exceeded 60 hours per year.
Q Is it correct that some time in 1978, 6
14         Q       Is it a fact that during that period of 15   time there was a change in the shifts,     the number of 16   shifts?
beginning some time in 1978, the control room operators 7
17         A       I don't recall   the exact time period, but 18 there was a period of time they went to five shifts, 19   that is correct.
attended requalification training sessions less 8
l l             20         g       could you describe just for the record 21   what the difference was between six shifts and five 22   shifts, how that worked?
frequently than they had previously because of a 9
i 23         A     Yes. During six-shift rotation, that g-      24   included three working shifts, a relief shift, a
change in the shifts from uix to five?
    \j 25 l j                  shift that was off and a training shift.
10 A
That is not necessarily true.
They are 11 required to spend a minimum of 60 hours per year 12 in training, minimum.
Normally we conducted a (g) 13 training program that exceeded 60 hours per year.
~
u-14 Q
Is it a fact that during that period of 15 time there was a change in the shifts, the number of 16 shifts?
17 A
I don't recall the exact time period, but 18 there was a period of time they went to five shifts, 19 that is correct.
l l
20 g
could you describe just for the record 21 what the difference was between six shifts and five 22 shifts, how that worked?
i 23 A
Yes.
During six-shift rotation, that 24 included three working shifts, a relief shift, a g-
\\j j
25 l
shift that was off and a training shift.


1                             Zechman                     164
1 Zechman 164
(~
(~
(_)       2                 During five-shift rotation, a relief shift, 3   three operating shifts, and an off shift.
(_)
4         Q     How long was each shift?
2 During five-shift rotation, a relief shift, 3
lll 5         A     The relief shift by the way was used for 6   the training shift.
three operating shifts, and an off shift.
7         Q     How long was each shift?
4 Q
8         A     Eight hours, working hours.
How long was each shift?
9         Q     So just so I understand it, if you 10   took under the six-shift program, six consecutive 11   eight-hour w~orking days, three of those would be 12   devoted to working on duty, one being relief, one r"g
lll 5
( j     13   being off, and one for training, is that correct?
A The relief shift by the way was used for 6
14               MR. MacDONALD:     Are you asking how the 15         program operated, exactly as you describe it?
the training shift.
16               MR. FISKE:   Yes.
7 Q
17         Q     Is that the concep t?
How long was each shift?
10         A     I'm not sure that you have described that 19   correctly.
8 A
20         Q     Why don't you describe it then?
Eight hours, working hours.
21         A     Fine.
9 Q
22               A typical week, there would be a group 23 i that works from 7:00 until 11:00, 11:00 to 7:00 --
So just so I understand it, if you 10 took under the six-shift program, six consecutive 11 eight-hour w~orking days, three of those would be 12 devoted to working on duty, one being relief, one r"g
l 24
( j 13 being off, and one for training, is that correct?
(~)         correct that.
14 MR. MacDONALD:
LI 25                 7:00 to 4:00, 4:00 to 11:00, 11:00 to
Are you asking how the 15 program operated, exactly as you describe it?
16 MR. FISKE:
Yes.
17 Q
Is that the concep t?
10 A
I'm not sure that you have described that 19 correctly.
20 Q
Why don't you describe it then?
21 A
Fine.
22 A typical week, there would be a group 23 i
that works from 7:00 until 11:00, 11:00 to 7:00 --
l 24 correct that.
(~)
LI 25 7:00 to 4:00, 4:00 to 11:00, 11:00 to


1 Zechman                   165 2   7:00. There would be one shift that would be 3   off and there would be one shift that would be 4   working daylight hours from 7:00 to 4:00.     It's that lll   5   shift that would be in training during normal shift 6   rotation.    .
1 Zechman 165 2
7                   So I would see, every five weeks, I would 8
7:00.
There would be one shift that would be 3
off and there would be one shift that would be 4
working daylight hours from 7:00 to 4:00.
It's that lll 5
shift that would be in training during normal shift 6
rotation.
7 So I would see, every five weeks, I would 8
see the relief -- each relief shift.
see the relief -- each relief shift.
9         Q       When you say there are six shifts, then 10 you are referring to two consecutive 24-hour days or 11   six shifts?
9 Q
12           A       si:t shifts means during the daylight hours 5
When you say there are six shifts, then 10 you are referring to two consecutive 24-hour days or 11 six shifts?
      )     13   there would be a relief shift on duty and at the 14 same time there would be a daylight crew called the 15 training crew, training shift.
12 A
16 Q       How was that different when there were 17 five shifts?
si:t shifts means during the daylight hours
l 18 l                        A       The difference is that instead of the l
)
13 there would be a relief shift on duty and at the 5
14 same time there would be a daylight crew called the 15 training crew, training shift.
16 Q
How was that different when there were 17 five shifts?
l l
18 A
The difference is that instead of the l
19 relief shift being down for training, it would be the 1
19 relief shift being down for training, it would be the 1
20 I sixth shift for training.
20 I
21                   I don't think this is coming across very Q
sixth shift for training.
22   clearly.
21 Q
I don't think this is coming across very 22 clearly.
I 22 Could you try again.
I 22 Could you try again.
24           3       yes,
24 3
    \_)
: yes,
25
\\_)
(                                When there are slx shifts, there are six
(
25 When there are slx shifts, there are six


1 Zechman                   166 O
1 Zechman 166 OV 2
V    2 bodies.of individuals as opposed to when there are 3   five shifts, there are five bodies of individuals.
bodies.of individuals as opposed to when there are 3
4 During six-shift rotation, one of the g   5   shifts is a training shift.
five shifts, there are five bodies of individuals.
6 During the five-shift rotation, it's the 7   relief shift that becomes the training shift.
4 During six-shift rotation, one of the g
O We utilized or trained the people who are normally 9   assigned to relief.
5 shifts is a training shift.
10 Q     Is it your testimony then that the 11 change from six shifts to five shifts as you have 12 just described it had no impact on the amount of 13 training that the operators received?
6 During the five-shift rotation, it's the 7
14           A     It is my testimony that we conducted'a 15 requalification program in accordance to the 16 prescribed, required requalification and met the 17 requirement to the best of my recollection for that 18 training program.
relief shift that becomes the training shift.
19 g     I guess my question -- that wasn't my 20   question.
O We utilized or trained the people who are normally 9
assigned to relief.
10 Q
Is it your testimony then that the 11 change from six shifts to five shifts as you have 12 just described it had no impact on the amount of 13 training that the operators received?
14 A
It is my testimony that we conducted'a 15 requalification program in accordance to the 16 prescribed, required requalification and met the 17 requirement to the best of my recollection for that 18 training program.
19 g
I guess my question -- that wasn't my 20 question.
21 My question was, is it your testimony
21 My question was, is it your testimony
    .9 22   that the change from six shifts to five shifts had 23 no impact on the amount of requalification training 24   that a given operator received?
.9 22 that the change from six shifts to five shifts had 23 no impact on the amount of requalification training 24 that a given operator received?
25 !
25 A
A      I have no recollection that I have made
I have no recollection that I have made


1 Zechman                               167 a balance between -- or recall a balance that I 3       personally made between the amount of training for 4
1 Zechman 167 a balance between -- or recall a balance that I 3
six shifts and the amount of training for five h   5     shifts.
personally made between the amount of training for 4
six shifts and the amount of training for five h
5 shifts.
6 I can only state that we certainly 7
6 I can only state that we certainly 7
conducted a minimum of 60 hours requalification 8
conducted a minimum of 60 hours requalification 8
program as required.
program as required.
9                             MR. FISKE:   Could you read that answer 10 back, please.
9 MR. FISKE:
Could you read that answer 10 back, please.
11 (Record read back.)
11 (Record read back.)
12 Q     Did there come to your attention in 13 1978 that there was a problem with attendance in the 14       requalification program?
12 Q
15 A     Yes, I recall a period of time that we 16 had attendance to the live lectures in the 17 requalification program that required us through IO
Did there come to your attention in 13 1978 that there was a problem with attendance in the 14 requalification program?
                'the mode of the requalification program to prepare 19 separate materials, we called them care packages, to 20 the individuals, or make-up packages.
15 A
      -21                       Q     Let me show you a document which was 22 marked as B&W Exhibit 303.
Yes, I recall a period of time that we 16 had attendance to the live lectures in the 17 requalification program that required us through IO
U                               Do you have that in front of you?
'the mode of the requalification program to prepare 19 separate materials, we called them care packages, to 20 the individuals, or make-up packages.
24                       A     Yes, I do.
-21 Q
25 Q     That is a memorandum written by Mr. Goodman.
Let me show you a document which was 22 marked as B&W Exhibit 303.
U Do you have that in front of you?
24 A
Yes, I do.
25 Q
That is a memorandum written by Mr. Goodman.


1                             Zechman                       168 ID
1 Zechman 168 ID
(_)       2         A       It is not.
(_)
3         Q       Pardon me?
2 A
4         A       Not tat one I have in front of me.
It is not.
lll   5         Q       Is this it?
3 Q
6         A       Exhibit 303 is before me at this time, 7   yes.
Pardon me?
8         Q     That is a memorandum dated June 21, 9   1978, correct?
4 A
10         A     That is correct.
Not tat one I have in front of me.
11           Q     That is from Mr. Goodman?
lll 5
* 12           A     Yes.
Q Is this it?
I)
6 A
    \_/
Exhibit 303 is before me at this time, 7
13           Q    
yes.
8 Q
That is a memorandum dated June 21, 9
1978, correct?
10 A
That is correct.
11 Q
That is from Mr. Goodman?
12 A
Yes.
I) 13 Q


==Subject:==
==Subject:==
    " Unit 1, 2, Requalification 14   ~ Program Attendance," right?
" Unit 1,
15           A     Yes, sir.
2, Requalification
16           Q     And you received a copy of that?
\\_/
17                 MR. MacDONALD:     Does he recall receiving 18           a copy?
14
19           Q     You did receive a copy, did you not?
~ Program Attendance," right?
20           A     I can't recall either way at this time 21   whether I received it.       I was aware of the problem 9   22   at that time. I can't recall any more whether I looked 23   at this particular piece of paper.
15 A
Yes, sir.
16 Q
And you received a copy of that?
17 MR. MacDONALD:
Does he recall receiving 18 a copy?
19 Q
You did receive a copy, did you not?
20 A
I can't recall either way at this time 21 whether I received it.
I was aware of the problem 9
22 at that time.
I can't recall any more whether I looked 23 at this particular piece of paper.
24 Q
Do you recall learning in or about June
-)
)
)
    -)
%)
    %)
25 21, 1978 that after the first week of the five-week
24          Q      Do you recall learning in or about June 25   21, 1978 that after the first week of the five-week


1                         Zechman                   169   i I
1 Zechman 169
(~
(~
( )\       2 requalification training program cycle had been 3 completed, that there was an overall attendance of 4 only 44 percent for licensed personnel?
( )\\
5       A     I no longer recollect any numbers of ll 6 that sort.
2 requalification training program cycle had been 3
7       Q     You referred a moment ago to make-up 8 packages.
completed, that there was an overall attendance of 4
9       A     Yes.
only 44 percent for licensed personnel?
10       Q     I guess they have been called care packages, 11 have they not, from time to time?
ll 5
12         A     Yes.
A I no longer recollect any numbers of 6
(m) v 13         Q     I take it, is it correct, what 14 happened if someone missed a classroom lecture, 15 then the instructor made up what is referred to as 16 a care package for that individual then to study in 17 his own time to get the information that he missed l
that sort.
l 18 in class?
7 Q
l 19         A     That is correct.
You referred a moment ago to make-up 8
20         Q     What would one of those care packages 21 typically consist of?
packages.
22         A     Typically it would consist of any hand-out 23 material that was utilized. Sometimes it would include t
9 A
l l    -s      24 a lesson plan, the appropriate lesson material that
Yes.
10 Q
I guess they have been called care packages, 11 have they not, from time to time?
12 A
Yes.
(m) 13 Q
I take it, is it correct, what v
14 happened if someone missed a classroom lecture, 15 then the instructor made up what is referred to as 16 a care package for that individual then to study in 17 his own time to get the information that he missed l
l 18 in class?
l 19 A
That is correct.
20 Q
What would one of those care packages 21 typically consist of?
22 A
Typically it would consist of any hand-out 23 material that was utilized.
Sometimes it would include t
l 24 a lesson plan, the appropriate lesson material that l
-s
[
[
l
l
    \s\ '
\\s\\
25 was taught in that period, and maybe a qui =.
25 was taught in that period, and maybe a qui =.
I 1
I 1


Zachman                         170 1
Zachman 170 1
      \                        And this was to, in effect, substitute Q
['Y
['Y
    %        2 for what the individual had missed by not being at 3
\\
Q And this was to, in effect, substitute 2
for what the individual had missed by not being at 3
the class?
the class?
4 A       This was a way for that individual to 5
4 A
This was a way for that individual to 5
make up what he missed in class.
make up what he missed in class.
6 Q       Mr. Goodman states in this memorandum, 7
6 Q
Mr. Goodman states in this memorandum, 7
Exhibit 303, "Make-up packages are a poor 8
Exhibit 303, "Make-up packages are a poor 8
substitute fo r live Jnstruction. "
substitute fo r live Jnstruction. "
Line 296: Line 473:
10.
10.
Where are you at?
Where are you at?
11 Q       Item No. 2 down at the bottom.
11 Q
12 (g                 A       I see that statement.
Item No. 2 down at the bottom.
(.)     13 Q       At the time you received this memorandum, 14 did you express any disagreement with that concept?
12 (g
15 A       As I told you a few minutes ago, I recollect 16 having an attendance problem in some period of time.
A I see that statement.
(.)
13 Q
At the time you received this memorandum, 14 did you express any disagreement with that concept?
15 A
As I told you a few minutes ago, I recollect 16 having an attendance problem in some period of time.
17 I don't recollect today this piece of paper.
17 I don't recollect today this piece of paper.
18 If I don't recollect this piece of paper 19 at this time, I can't recollect what I said at that 20 time.
18 If I don't recollect this piece of paper 19 at this time, I can't recollect what I said at that 20 time.
h             Q       Did you ever express the view to anybody 22 that you disagreed with the notion that make-up 23 packages are a poor substitute for live instruction?
h Q
24
Did you ever express the view to anybody 22 that you disagreed with the notion that make-up 23 packages are a poor substitute for live instruction?
    .%                          MR. MacDONALD:         He just told you he didn't 25
24 MR. MacDONALD:
He just told you he didn't 25


1                             Zechman                   171
1 Zechman 171
('N,
('N,
(_)             2         necessarily recall whether he ever heard that.
(_)
3         Q     To put it this way, Mr. Zechman, did you 4   agree with the concept it was better to have the lll   5   people in class learning the information directly in 6   class than having to get it from a care package 7   afterwards?
2 necessarily recall whether he ever heard that.
8         A     It is my opinion that I certainly would 9   rather have an individual in class for live 10   instruction, but I also would clarify there has been 11   no evidence that giving the care packages has 12   diluted any of the training we tried to convey during f%                                                     .
3 Q
13 (v)                  our requalification program.
To put it this way, Mr. Zechman, did you 4
14         Q     I think, Mr. Zechman, that is a ques tion 15   tnat the court will have to decide when it hears 16   the facts in this case.
agree with the concept it was better to have the lll 5
17                 MR. MacDONALD:   I think it is part and 18         parcel of his answer.
people in class learning the information directly in 6
l               . 19                 You asked something on this subject 20         matter and he gave you what his answer is.
class than having to get it from a care package 7
21                 MR. FISKE:   It is a major issue in this i                 22         case whether the training program was adequate 23         and whether or not one of the problems with I
afterwards?
g3            24         the training program was that people were i
8 A
l i                 ;
It is my opinion that I certainly would 9
      %.)
rather have an individual in class for live 10 instruction, but I also would clarify there has been 11 no evidence that giving the care packages has 12 diluted any of the training we tried to convey during f%
25         not going to class and, therefore, missing
13 our requalification program.
(v) 14 Q
I think, Mr. Zechman, that is a ques tion 15 tnat the court will have to decide when it hears 16 the facts in this case.
17 MR. MacDONALD:
I think it is part and 18 parcel of his answer.
l 19 You asked something on this subject 20 matter and he gave you what his answer is.
21 MR. FISKE:
It is a major issue in this i
22 case whether the training program was adequate 23 and whether or not one of the problems with I
24 l
the training program was that people were g3 i
i
%.)
25 not going to class and, therefore, missing


1                             Zechman                       172 fm 4     4 iJ           2         the benefits of live classroom instruction.
1 Zechman 172 fm 4
3                 MR. MacDONALD:   You asked for his 4         understanding and his understanding he gave llh 5         you on the record.
4 iJ 2
6                 I think there is a full statement on the 7         record of what his understanding was.
the benefits of live classroom instruction.
8                 MR. FISKE:   I asked whether he simply 9         thought it was better for them to be in the 10         class rather than reading the material, and 11         he answered that question and then added 12         something to it to which I responded.
3 MR. MacDONALD:
C\
You asked for his 4
(_,1     13         Q     Mr. Zechman, let's go to the other 14   exhibit I think that I handed you previously by 15   mistake which is B&W Exhibit 304.
understanding and his understanding he gave llh 5
16                 Do you have that in front of you?
you on the record.
17         A     I have Exhibit 304 in front o f me.
6 I think there is a full statement on the 7
18         Q     That is a memorandum, is it not, from 19   Mr. Beers to a group of people listed at the 20   top of the page, again on the subject of Unit     1,   2, 21   requalification program attendance, this time dated 22   September 3,   1978.
record of what his understanding was.
23         A     It says September 1 on mine'.
8 MR. FISKE:
(~N     24         Q     September 1, 1978, is that correct?
I asked whether he simply 9
()         ;
thought it was better for them to be in the 10 class rather than reading the material, and 11 he answered that question and then added 12 something to it to which I responded.
25 l             MR. MacDONALD:     Are you asking if that
C\\
(_,1 13 Q
Mr. Zechman, let's go to the other 14 exhibit I think that I handed you previously by 15 mistake which is B&W Exhibit 304.
16 Do you have that in front of you?
17 A
I have Exhibit 304 in front o f me.
18 Q
That is a memorandum, is it not, from 19 Mr. Beers to a group of people listed at the 20 top of the page, again on the subject of Unit 1,
2, 21 requalification program attendance, this time dated 22 September 3, 1978.
23 A
It says September 1 on mine'.
(~N 24 Q
September 1,
1978, is that correct?
()
25 l
MR. MacDONALD:
Are you asking if that


1                             Zechman                           173 2           is what the document says?
1 Zechman 173 2
3                 MR. FISKE:       Yes.                               ,
is what the document says?
4           A     That is what the document says.
3 MR. FISKE:
h 5           Q     The document indicates you received a 6 carbon copy, does it not?
Yes.
7           A     The document says the secretary had a carbon 8 copy supposedly       to me.
4 A
9           Q     The copy that you have underline-d, 'in 10 front of you, does it contain underlining?
That is what the document says.
11           A     There are underlinings on the copy that 12 I have, yes, sir.
h 5
13                 Is one of the underlinings under your Q
Q The document indicates you received a 6
14 name?
carbon copy, does it not?
15           A     Yes.
7 A
16 -
The document says the secretary had a carbon 8
Is there also underlining under the Q
copy supposedly to me.
17 sentence that says, "Overall, approximately half the l
9 Q
The copy that you have underline-d, 'in 10 front of you, does it contain underlining?
11 A
There are underlinings on the copy that 12 I have, yes, sir.
13 Q
Is one of the underlinings under your 14 name?
15 A
Yes.
16 Q
Is there also underlining under the 17 sentence that says, "Overall, approximately half the l
18 1.4. censed people are not attending requal. training"?
18 1.4. censed people are not attending requal. training"?
l j          19           A     In the copy that I have, that is underlined.
l 19 A
In the copy that I have, that is underlined.
j
(
(
20           Q     Did you put that underlining on there, 21 Mr. Zechman?
20 Q
22           A     Not to the best of my recollection.
Did you put that underlining on there, 21 Mr. Zechman?
I 23                 Did you put the underlining under your l
22 A
Q 24 name?
Not to the best of my recollection.
l 25           A     Not to the best of my recollection.
I l
23 Q
Did you put the underlining under your 24 name?
l 25 A
Not to the best of my recollection.


1                         zechman                     174 Ch
1 zechman 174 Ch
()_
()
2       Q     Did you understand when you received a 3 copy of this, that somebody had underlined your name 4 beca.;e they wanted you to pay special attention lll 5 to the material that was underlined in the memo?
2 Q
6             MR. MacDONALD:   Objection. You asked 7       whether or not he recalls receiving the document.
Did you understand when you received a 3
8       You asked whether he appears as a cc on the 9       document.
copy of this, that somebody had underlined your name 4
10             MR. FISKE:   I think Mr. Zechman is 11       perfectly capable of telling us if he wants 12       to now he doesn't recall ever receiving this
beca.;e they wanted you to pay special attention lll 5
: 7. \
to the material that was underlined in the memo?
g   )     13       memo. If he wants to tell us he doesn't w/
6 MR. MacDONALD:
14       recall receiving either one of the two memos, 15       saying that less than half the people were 16       attending the requal. program, he can say that.
Objection.
17             MR. MacDONALD:   He may have no recollection 18       one way or the other.
You asked 7
19             MR. FISKE:   Let's find out.
whether or not he recalls receiving the document.
20             MR. MacDONALD:   Why not ask him the i
8 You asked whether he appears as a cc on the 9
21       question instead of making an assumption?
document.
l               22             MR. FISKE:   I did.
10 MR. FISKE:
I think Mr. Zechman is 11 perfectly capable of telling us if he wants 12 to now he doesn't recall ever receiving this
: 7. \\
g
)
13 memo.
If he wants to tell us he doesn't w/
14 recall receiving either one of the two memos, 15 saying that less than half the people were 16 attending the requal. program, he can say that.
17 MR. MacDONALD:
He may have no recollection 18 one way or the other.
19 MR. FISKE:
Let's find out.
20 MR. MacDONALD:
Why not ask him the i
21 question instead of making an assumption?
l 22 MR. FISKE:
I did.
l 1
l 1
!              23             MR. MacDONALD:   You assumed in your 24       question that he recalled receiving it.
23 MR. MacDONALD:
g3 I
You assumed in your 24 g3 question that he recalled receiving it.
N._.A 25             MR. FISKE:   I said when he received it.
N._.A I
25 MR. FISKE:
I said when he received it.
l
l


1                                 zechman                             175 O               2                     I think it's a fair assumption he 3               received it when it is produced by Met Ed and 4             it shows a carbon copy was sent to him.
1 zechman 175 O
lll           5                     MR. MacDONALD:       You can assume anything 6               you want.
2 I think it's a fair assumption he 3
7                       Ask the witness a question.         We are 8             not here to learn about your assumptions.
received it when it is produced by Met Ed and 4
9                     MR. FISKE:   Read the question.
it shows a carbon copy was sent to him.
10                       (Record read back.)
lll 5
11               A       In that question, you assume I got a 12     copy and recollect that copy.
MR. MacDONALD:
13                       I will state that I was aware that there 14     was an attendance problem.           I don't recollect either 15   - way this particular document at this time.
You can assume anything 6
16               Q     So your testimony is that you now say 17     you don't recall receiving either -- you don't 18     recall whether or not you received either Exhibit 19     303 or 304?                       .
you want.
20               A     I'm saying at this point in time, 21     considering that was in 1978, I have seen so many 9           22     documents during that period of time, that I don't 23     recollect one way or the other whether I saw this 24     one at that time.
7 Ask the witness a question.
25               Q     And that answer applies, you say, to both
We are 8
not here to learn about your assumptions.
9 MR. FISKE:
Read the question.
10 (Record read back.)
11 A
In that question, you assume I got a 12 copy and recollect that copy.
13 I will state that I was aware that there 14 was an attendance problem.
I don't recollect either 15
- way this particular document at this time.
16 Q
So your testimony is that you now say 17 you don't recall receiving either -- you don't 18 recall whether or not you received either Exhibit 19 303 or 304?
20 A
I'm saying at this point in time, 21 considering that was in 1978, I have seen so many 9
22 documents during that period of time, that I don't 23 recollect one way or the other whether I saw this 24 one at that time.
25 Q
And that answer applies, you say, to both


1                         Zechman                   176 k./         2 Exhibits 303 and 3047 3       A     Yes, sir.
1 Zechman 176 k./
4         Q     You are not denying, are you, during lll   5 this period of time when you were in charge of the 6 training program at Med Ed that you were aware that 7 less than half the licensed people were attending 8 the requalification classes?
2 Exhibits 303 and 3047 3
9         A     I don't recall the percentage of people 10 who did not attend the' class. I cannot confirm your 11 number at this time.
A Yes, sir.
12               I only can confirm that I was aware there (D
4 Q
q ,j        13 was an attendance program. That I will confirm.
You are not denying, are you, during lll 5
14         Q     Did you do anything about this attendance 15 problem, Mr. Zechman?
this period of time when you were in charge of the 6
16         A     Yes, sir, I did.
training program at Med Ed that you were aware that 7
l              17         Q     Did you bring this question of the l
less than half the licensed people were attending 8
18 poor attendance by the licensed operators at l               19 training programs to the attention of management?
the requalification classes?
9 A
I don't recall the percentage of people 10 who did not attend the' class.
I cannot confirm your 11 number at this time.
12 I only can confirm that I was aware there (D
13 was an attendance program.
That I will confirm.
q,j 14 Q
Did you do anything about this attendance 15 problem, Mr. Zechman?
16 A
Yes, sir, I did.
17 Q
Did you bring this question of the l
l 18 poor attendance by the licensed operators at l
19 training programs to the attention of management?
I l
I l
20         A     I certainly did.
20 A
21         Q     Isn't it a fact that nothing was done 22 about it in terms of improving attendance?
I certainly did.
23         A     That would have to be time qualified.
21 Q
24 There was a period of time that we were aware of the
Isn't it a fact that nothing was done 22 about it in terms of improving attendance?
(%..J
23 A
      -}
That would have to be time qualified.
l              25 attendance problems. There was a period of time
24 There was a period of time that we were aware of the
( -}
%..J l
25 attendance problems.
There was a period of time


1                           Zechman                     177 ,
1 Zechman 177
1 1
(~N
(~N
( ,!       2 in which I made senior management and operations 3 management aware of the attendance problems and 4 there was a period of time it improved.
(,!
lll   5       Q       It certainly hadn't improved by the 6 time you ceased functioning as head of the training e
2 in which I made senior management and operations 3
management aware of the attendance problems and 4
there was a period of time it improved.
lll 5
Q It certainly hadn't improved by the 6
time you ceased functioning as head of the training e
7 department, had it?
7 department, had it?
8       A     I don't recall the period, exact period 9 when it did improve.
8 A
10         g     "There is a memorandum dated September   1, 11 '78.
I don't recall the period, exact period 9
12               Isn't that just about the day you became
when it did improve.
    ,R
10 g
(   )     13 supervisor of the training department and R./
"There is a memorandum dated September 1,
14 began to devote eight hours a day to your own personal 15 study?
11
16         A     That is correct.
'78.
17         Q     As of that time when you ceased to function 18 actively as a supervisor of the training department, 19 the attendance had not improved, had it?
12 Isn't that just about the day you became
20               MR. MacDONALD:     Are you asking for his l
,R
21         recollection?
(
22               MR. FISKE:   Yes.
)
j            23         A     My recollection is not   --
13 supervisor of the training department and R./
14 began to devote eight hours a day to your own personal 15 study?
16 A
That is correct.
17 Q
As of that time when you ceased to function 18 actively as a supervisor of the training department, 19 the attendance had not improved, had it?
20 MR. MacDONALD:
Are you asking for his l
21 recollection?
22 MR. FISKE:
Yes.
23 A
My recollection is not j
I told you i
I told you i
24 before, you are quoting from this letter, and I told 7-I
24 before, you are quoting from this letter, and I told 7-I
(..)     25 you I didn't recollect either way the time period of l
(..)
25 you I didn't recollect either way the time period of l


1 Zechman                                       178 2 this letter and, therefore, I still have not a 3 clear recollection in my mind of the period of time 4 that we had the problem and when the problem h             5 cleared.
1 Zechman 178 2
6           Q             Well, you cannot tell us as you sit here 7
this letter and, therefore, I still have not a 3
clear recollection in my mind of the period of time 4
that we had the problem and when the problem h
5 cleared.
6 Q
Well, you cannot tell us as you sit here 7
today that this attendance had improved in any 8
today that this attendance had improved in any 8
significant way as of the time you assumed the 9 position of supervisor of training, can you?
significant way as of the time you assumed the 9
10           A             Sir, I can only repeat that I'm aware 11 there was an attendance problem and it was in and 12 around that period of time, but I can't nail it down 13 toa fixed time at this time.
position of supervisor of training, can you?
14 Q               Isn't it a fact, Mr. Zechman, that the 15 attendance continued to decline right up to the time 16 of the accident?
10 A
II         A             As I just testified a few minutes ago, 10 I said I was aware of the attendance problem.
Sir, I can only repeat that I'm aware 11 there was an attendance problem and it was in and 12 around that period of time, but I can't nail it down 13 toa fixed time at this time.
14 Q
Isn't it a fact, Mr. Zechman, that the 15 attendance continued to decline right up to the time 16 of the accident?
II A
As I just testified a few minutes ago, 10 I said I was aware of the attendance problem.
19 I was also aware the attendance problem improved at 20 some point in time, but I don' t recall when.
19 I was also aware the attendance problem improved at 20 some point in time, but I don' t recall when.
21                         And you can't tell us now whether that Q
21 Q
22 was before the accident or after the accident, is 23 that correct?
And you can't tell us now whether that 22 was before the accident or after the accident, is 23 that correct?
24         A               It's been too long ago.                       I have no 25 recollection at this time.
24 A
It's been too long ago.
I have no 25 recollection at this time.


1                           zechman                     179
1 zechman 179
(   )
(
    's_/       2         Q   So the answer is you can't say one way 3 or the other as you sit here today?
)
4         A     That is correct.
's_/
llh   5       Q     You were interviewed by Mr. Keaten I 6 think as you told us previously at some point after 7 the accident, is that correct?
2 Q
8         A     That is correct.
So the answer is you can't say one way 3
9       Q     In that same interview, present were 10 Mr. Beers and Mr. McCormack.
or the other as you sit here today?
11               You testified to that before, or a part 12 of the time?
4 A
That is correct.
llh 5
Q You were interviewed by Mr. Keaten I 6
think as you told us previously at some point after 7
the accident, is that correct?
8 A
That is correct.
9 Q
In that same interview, present were 10 Mr. Beers and Mr.
McCormack.
11 You testified to that before, or a part 12 of the time?
fx
fx
()       13         A     Yes, part of the time.
( )
14         Q     Isn't it a fact at that meeting that 15 Mr. Keaten was told that attendance at training           ,
13 A
16 sessions has been very poor and declining?
Yes, part of the time.
17         A     I recall at that meeting that one of the 18 subject areas which was discussed was attendance, i
14 Q
19 but I don't recall with what framework that was 20 discussed, whether it was discussed in past periods, l
Isn't it a fact at that meeting that 15 Mr. Keaten was told that attendance at training 16 sessions has been very poor and declining?
21 present periods. I just don't recall.
17 A
22         Q     Let me show you a document which we will 23 mark as the next exhibit, B&W 561.
I recall at that meeting that one of the 18 subject areas which was discussed was attendance, i
      <w 24               I would just like to read from this k
19 but I don't recall with what framework that was 20 discussed, whether it was discussed in past periods, l
25 document to you, Mr. Zechman, and then ask you a l
21 present periods.
I just don't recall.
22 Q
Let me show you a document which we will 23 mark as the next exhibit, B&W 561.
<w 24 I would just like to read from this k
25 document to you, Mr. Zechman, and then ask you a l
l
l


1                               Zechman                       180
1 Zechman 180
    .0
.0
    \- /       2     question.
\\- /
3                   MR. MacDONALD:   Can he read through it 4           before you ask a question?
2 question.
llI   5                   MR. FISKE:   By all means.
3 MR. MacDONALD:
6                   (Copy of a document entitled "TMI-2 7             Investigation Task Force Interviews, 10/16/79" 8   i        marked B&W Exhibit 561 for identification as 9           of this date.)
Can he read through it 4
10                   Have you finished reading that exhibit?
before you ask a question?
Q 11             A     There were some things I couldn't make out.
llI 5
12             Q     I know, Mr. Zechman, you have been writing n
MR. FISKE:
(,,)     13     some notes on a yellow pad in front of you.
By all means.
14             A     Yes.
6 (Copy of a document entitled "TMI-2 7
I 15                   MR. FISKE:
Investigation Task Force Interviews, 10/16/79" 8
i                                              Could we have that marked as 16             the next B&W exhibit please.
marked B&W Exhibit 561 for identification as i
17                   MR. MacDONALD:   Sure.
9 of this date.)
18                   (Notes made by the witness on a yellow l
10 Q
19             pad marked B&W Exhibit 562 for identification l
Have you finished reading that exhibit?
20             as of this date.)
11 A
l       g  21             Q     Looking at the handwritten memorandum l
There were some things I couldn't make out.
I W
12 Q
22     that you have just been reading, Exhibit 516, after i
I know, Mr. Zechman, you have been writing n(,,)
23     reading that, does that in any way refresh your 24      recollection on any subject that you discussed with
13 some notes on a yellow pad in front of you.
14 A
Yes.
I i
15 MR. FISKE:
Could we have that marked as 16 the next B&W exhibit please.
17 MR. MacDONALD:
Sure.
18 (Notes made by the witness on a yellow l
l 19 pad marked B&W Exhibit 562 for identification 20 as of this date.)
l 21 Q
Looking at the handwritten memorandum g
l W
I 22 that you have just been reading, Exhibit 516, after i
23 reading that, does that in any way refresh your
(~))
(~))
L.         !
24 recollection on any subject that you discussed with L.
I 25     Mr. Keaten back in October of '797       Just yes or no.
I 25 Mr. Keaten back in October of '797 Just yes or no.
l 1
l 1


1                               Zechman                               181 e   h
1 Zechman 181 e
    \m.)       2                 MR. MacDONALD:   Let him answer the 3           question.
h
4                 MR. FISKE:   All I want to find out             --
\\m.)
A llh  5                  There are selected items in there that 6     I recall discussing.
2 MR. MacDONALD:
7           Q     Let me direct your attention, Mr. Zechman, 8     to what I believe is the seventh line on the first 9     page, and I would just like to read a few sentences, 10     and if you, as I read it, think I am reading it 11     incorrectly, you let me know because I recognize it 12     is somebody's handwriting.
Let him answer the 3
n
question.
()       13                 It says, " Attendance at training sessions 14     has been very poor and declining.     For example, in 15     1978, the attendance record was about 30 percent.
4 MR. FISKE:
16     This was attributable to the inability of the OPS
All I want to find out llh 5
;            17     department to release their people for the required 18     training. Off-shift people were the worse in l
A There are selected items in there that 6
l 19     attendance. Shift supervisors were not as bad, but l
I recall discussing.
20     ware ~ worse than that of the control room operators 21     themselves and the auxiliary operators, et cetera.
7 Q
l             22                 "This attendance was brought to t he 23     attention of the plant management on a number of 24     occasions. The response to these letters was not b(~N 25 ! at all apparent as attendance continued to go down."
Let me direct your attention, Mr. Zechman, 8
to what I believe is the seventh line on the first 9
page, and I would just like to read a few sentences, 10 and if you, as I read it, think I am reading it 11 incorrectly, you let me know because I recognize it 12 is somebody's handwriting.
n()
13 It says, " Attendance at training sessions 14 has been very poor and declining.
For example, in 15 1978, the attendance record was about 30 percent.
16 This was attributable to the inability of the OPS 17 department to release their people for the required 18 training.
Off-shift people were the worse in l
19 attendance.
Shift supervisors were not as bad, but l
l 20 ware ~ worse than that of the control room operators 21 themselves and the auxiliary operators, et cetera.
l 22 "This attendance was brought to t he 23 attention of the plant management on a number of b(~N 24 occasions.
The response to these letters was not 25 ! at all apparent as attendance continued to go down."
l l
l l
1 l
1 l
l
l


1 Zechman                     182
1 Zechman 182
    ,    \
\\
( ,)         2               Do you see those portions of the notes 3   that I just read?
,(,)
4         A     Yes.
2 Do you see those portions of the notes 3
lll   5         Q     Did you or Mr. Beers or Mr. McCormack 6
that I just read?
make statements to that effect to Mr. Keaten at the 7   interview that you had with him in October of '797 8         A     I can only testify to what I recall saying 9 to them and I do recall discussing attendance.
4 A
10 I don't recall discussing it specifically as it       is 11 written here.
Yes.
12               I do recall discussing the attendance
lll 5
      /
Q Did you or Mr. Beers or Mr.
(g j)     13   problem.
McCormack 6
14         Q     Is it your position that you told Mr. Keaten 15 in October of 1979 that at some point before the 16 accident, attendance had started to increase?
make statements to that effect to Mr. Keaten at the 7
I 17               MR. MacDONALD:   Are you asking whether he i             18         recalls telling Keaten that?
interview that you had with him in October of '797 8
19               MR. FIS KE : Yes.
A I can only testify to what I recall saying 9
20         A     I don't recall either way.
to them and I do recall discussing attendance.
21         Q     In reading this memorandum, you do not 22   see any statement to that effect in the memorandum, 23   do you?
10 I don't recall discussing it specifically as it is 11 written here.
g-        24               MR. MacDONALD:   You mean o f the portions
12 I do recall discussing the attendance
    '\,s/
/( j) 13 problem.
25         he can make out?
g 14 Q
Is it your position that you told Mr. Keaten 15 in October of 1979 that at some point before the 16 accident, attendance had started to increase?
I 17 MR. MacDONALD:
Are you asking whether he i
18 recalls telling Keaten that?
19 MR. FIS KE :
Yes.
20 A
I don't recall either way.
21 Q
In reading this memorandum, you do not 22 see any statement to that effect in the memorandum, 23 do you?
24 MR. MacDONALD:
You mean o f the portions g-
'\\,s/
25 he can make out?


1 Zechman                     183 O     2 MR. FISKE:   Yes.
1 Zechman 183 O
3                   MR. MacDONALD:   It is not a transcription.
2 MR. FISKE:
4           A       In the notes, it looks like it was h   5   centering around the period 1978.
Yes.
6 Q       I guess we can draw our own conclusions I
3 MR. MacDONALD:
It is not a transcription.
4 A
In the notes, it looks like it was h
5 centering around the period 1978.
6 Q
I guess we can draw our own conclusions I
from what I just read as to whether the reference to O
from what I just read as to whether the reference to O
the fact that attendance continued to go down after 9
the fact that attendance continued to go down after 9
the 30 percent figure was brought to the attention 10 of management in 1978 means that this memorandum 11 refers to a condition existing after 1978.
the 30 percent figure was brought to the attention 10 of management in 1978 means that this memorandum 11 refers to a condition existing after 1978.
MR. MacDONALD:   Draw any conclusion you I
MR. MacDONALD:
Draw any conclusion you I
want.
want.
14 Q       My question specifically, Mr. Zechman, 15 is i .9 it fair to say there is no     statement that 16 you see in this memorandum in front of you to the
14 Q
:      17 effect that at some point, at any point before the 18 accident, attendance improved?
My question specifically, Mr. Zechman, 15 is i.9 it fair to say there is no statement that 16 you see in this memorandum in front of you to the 17 effect that at some point, at any point before the 18 accident, attendance improved?
A       Not in this document.
A Not in this document.
20                     Let me show you a document which has Q
20 Q
21 been marked as     Exhibit 558. It is three pages of 22 handwritten notes which I regret to inform       you are 3
Let me show you a document which has 21 been marked as Exhibit 558.
even more difficult to read than those in 561 because 4
It is three pages of 22 handwritten notes which I regret to inform you are 3
24 l
even more difficult to read than those in 561 because 24 4
of the microfilming, but I would represent to you I
l of the microfilming, but I would represent to you I
25 those have been identified as notes that Mr. Keaten
25 those have been identified as notes that Mr. Keaten
,.,,-n.-----w


l 1                           Zechman                     184 Cs i     i
1 Zechman 184 Cs i
    's /       2 made of the interview that we have just been 3 discussing.
i
4               I will give you this copy, Mr. Zechman, h   5 that I have.
's /
6               Have you seen that document before?
2 made of the interview that we have just been 3
7         A     You have given me three documents.
discussing.
8         Q     Jt is all one document.
4 I will give you this copy, Mr. Zechman, h
9         A     It's   my recollection that   I have not 10 seen this document.
5 that I have.
11         Q     You should probably take a minute to look 12 at it.
6 Have you seen that document before?
7 A
You have given me three documents.
8 Q
Jt is all one document.
9 A
It's my recollection that I have not 10 seen this document.
11 Q
You should probably take a minute to look 12 at it.
in
in
(_,)     -
(_,)
13         A     I read it, but I regret to say that a lot 14 of it I couldn't read.
13 A
15         Q     I will be asking you specific questions
I read it, but I regret to say that a lot 14 of it I couldn't read.
!              16 about specific portions of it. As I do that, you 17 will have another chance to look at the particular 18 section I am asking about.
15 Q
19               Could you look at the last section of 20 the first page.
I will be asking you specific questions 16 about specific portions of it.
21               Do you see the number there?     Could you 22 just read that off the notes?
As I do that, you 17 will have another chance to look at the particular 18 section I am asking about.
23         A     Starting off with "1978"?
19 Could you look at the last section of 20 the first page.
('N       24         Q   Yes. What does it say after that?
21 Do you see the number there?
25         A     "3" --
Could you 22 just read that off the notes?
something. I would be guessing l
23 A
Starting off with "1978"?
('N 24 Q
Yes.
What does it say after that?
25 A
"3" something.
I would be guessing l
l l
l l


s-1 Zechnan                       185 f~s                                                                       '
s-1 Zechnan 185 f~s
                                                                                ~
~
    's               $'''          2 '
's 2
that it is a zero and a percent sign, " attendance."
that it is a zero and a percent sign, " attendance."
s;                                                         '
s; 3
4 3          Q         Did you see any thing in these notes that
Q Did you see any thing in these notes that 4
                                                                                                              \
\\
4   referred to any increase in attendance at any time s
4 referred to any increase in attendance at any time s
s.
s.
5   from 1978 through to the da e of the adcident?
5 from 1978 through to the da e of the adcident?
A 6                     MR. MacDONALD:       He just told you he couldn't 7         read them.         The document speaks for itself.
A 6
8 You may ask him present-sense impression             '
MR. MacDONALD:
9 s
He just told you he couldn't 7
of what is in the document, but the words are
read them.
                      'm           10           what they are.
The document speaks for itself.
e
8 You may ask him present-sense impression s
                        ' ''      11 MR. FISKE:   I am asking him -- do you
9 of what is in the document, but the words are
        \             ''
'm 10 what they are.
s                  12           object to that question?
e 11 MR. FISKE:
I am asking him -- do you
\\
12 object to that question?
s
(^~f
(^~f
(,j
\\.
                  \.
13
13              '
(,j s.
MR. MacDONALD:       I object to the question.
MR. MacDONALD:
s.
I object to the question.
        '~
'~
14                       MR. FISKE:
14 MR. FISKE:
                            ,                      ,                      I think I will agree with you 15           on this particular occasion that the document 16 s              speaks for itself, containing no such reference.
I think I will agree with you 15 on this particular occasion that the document 16 speaks for itself, containing no such reference.
17                       Mr. Zechnan, there is --
s 17 Q
Q 18                       MR. MacDONALD:
Mr. Zechnan, there is --
g                      That is not what I said.
18 MR. MacDONALD:
j                                 19               't . MR. FISKE:   I invite you to disagree with 20           me if you think I am wrong.
That is not what I said.
21                       MR. MacDONALD:       I can't read all the 22           document, either.
g j
2 Q           The next sentence after "1978 - 30 percent
19
('s      '.
't.
s 24   attendance" says, " Missing, requires care packages
MR. FISKE:
    '\_ / \ ' '
I invite you to disagree with 20 me if you think I am wrong.
25   written by instructor."           Then the next line, as I 1                                                                                         .
21 MR. MacDONALD:
i                                                                                 '
I can't read all the 22 document, either.
                                                                                          \
2 Q
The next sentence after "1978 - 30 percent
('s 24 attendance" says, " Missing, requires care packages s
'\\_ / \\
25 written by instructor."
Then the next line, as I 1
i
\\


                                                                        's           ,
's
                                                                          \     ,
\\
                                                                            ,i,           ,              -
,i, 1
1                            Zechman                           13d-             <l i
Zechman 13d-
(~'T
<l i
    ,    1 N'         2 read it, says, " Required 2500 packages / year.''
(~'T 1
3                 Do you see those two?                   L       ,i 4         A       I don't recollect the first word.                   '
N' 2
lll 5   I recollect " Requires care packages VIitten by                       ,
read it, says, " Required 2500 packages / year.''
6  instructor."     I recognize " required"   --
3 Do you see those two?
something,                       i 1
L
7  "2500," and it looks like "packcoes/ year."
,i 4
8         Q     It is a fact, isn't it, that a very                         *
A I don't recollect the first word.
                                                                                                  -l I
lll 5
I recollect " Requires care packages VIitten by 6
instructor."
I recognize " required" something, i
1 7
"2500," and it looks like "packcoes/ year."
8 Q
It is a fact, isn't it, that a very
-l I
t.
t.
9 considerable number of care packages had to be 10 prepared because of the low attendance and the necessity, s
9 considerable number of care packages had to be 10 prepared because of the low attendance and the necessity, s
11 to prepare such packages for the people that were 12 not coming to class?
11 to prepare such packages for the people that were 12 not coming to class?
g
g
(_)       13         A     I recall that there was a number of 14 care packages.     I no longer, recall the magnitude of 15 those.
(_)
16         Q     If these notes were to be construed as i
13 A
I             17 indicating that youEor Mr. Beers ox-?!r.         McCormack i
I recall that there was a number of 14 care packages.
18 had told Mr. Keaten'that that gumber wan as high as l             19 2500 packages per year, we uld you --
I no longer, recall the magnitude of 15 those.
20                 MR. MacDONALD. I object. That is purely g  21         hypothetical.           s l         W 22                 You may ask what he recalls, but you'can't 23         ask if he said'this, vhat would that, main.
16 Q
      ^
If these notes were to be construed as i
I 17 indicating that youEor Mr. Beers ox-?!r.
McCormack i
18 had told Mr. Keaten'that that gumber wan as high as l
19 2500 packages per year, we uld you --
20 MR. MacDONALD.
I object.
That is purely 21 hypothetical.
g s
l W
22 You may ask what he recalls, but you'can't 23 ask if he said'this, vhat would that, main.
(]
(]
24 Q
Isn't it a fact that at the intbeview
^
L!
L!
24          Q      Isn't it a fact that at the intbeview 25 with Mr. Keaten, it was stated by you or Mr. Btera
25 with Mr. Keaten, it was stated by you or Mr. Btera


                                    /
/
s 1                                 zechman                     187 p     a
s 1
          \/                       2   or Mr.     .McCormeck that the number of care packages i             3   was 2500 per year?
zechman 187 p
    /              ji              4           A-       I recall at that meeting indicating that
a
    ,                  h           5   there was a large number of care packages.
\\/
t<               ,
2 or Mr.
.McCormeck that the number of care packages i
3 was 2500 per year?
4 A-I recall at that meeting indicating that ji
/
h 5
there was a large number of care packages.
t<
[
[
6                   If I were to give out t number, if I were 7   to give out a number at that time, it would have c' ,                       8    been pure speculation.
6 If I were to give out t number, if I were 7
                .                                                      7 don't recall that number.
to give out a number at that time, it would have 8
r-9           Q       Based on your present recollection as
c',
                            '. 10   you sit here todayr are you prepared to say that 11   number was wrong?
been pure speculation.
I2           A       I have no recollection --
7 don't recall that number.
(   )                 13                   MR. MacDONALD:     Objection.
r-9 Q
14                   Go ahead.                             -
Based on your present recollection as 10 you sit here todayr are you prepared to say that 11 number was wrong?
                            ~      15                   He told you he doesn't recall the t'                                                           '
I2 A
16           numbers.           .,
I have no recollection --
17                   You are not in a position then to tell Q
(
18   us that the number of care packages that had to be 19   prepared     per year was significantly less than 2500?
)
20                   MR. MacDONALD:     Objection. He told you 21           his recollection.
13 MR. MacDONALD:
22           3L i     Ifdon't recall the specific number.
Objection.
V                                 2U                    You certalnly recall it was well up in Q
14 Go ahead.
[~N,                     24   the hundreds?                   .
15 He told you he doesn't recall the
U 25           A       I don't recall the number any more.
~
t' 16 numbers.
17 Q
You are not in a position then to tell 18 us that the number of care packages that had to be 19 prepared per year was significantly less than 2500?
20 MR. MacDONALD:
Objection.
He told you 21 his recollection.
22 3L i Ifdon't recall the specific number.
2U V
Q You certalnly recall it was well up in
[~N, 24 the hundreds?
U 25 A
I don't recall the number any more.
l a
l a


I                         ,      Zechman                     188
I Zechman 188
(' \
('
(s/     2           Q         You have no recollection at all?
\\
3         A         I recollect that there was a number of 4   them. I don't recollect the magnitude of them any 5   more.
(s/
6         Q         Would ~you agree with Nelson Brown 7   that the preparation of these care packages was a 8   very time-consuming process?
2 Q
9                     MR. MacDONALD:   You are asking him now 10         for his recollection some time in 1978, whether 11         he can recall whether the preparation of those 12         care packages in 1978 was a time-consuming
You have no recollection at all?
( ,l   13         p ro ce s s ?
3 A
* 14                   MR. FISKE:     1978 or '79. Right up to --
I recollect that there was a number of 4
15                   MR. MacDONALD:     I am jus t asking for what 16         your question is intending to do.
them.
17                   MR. FISKE:     I am not talking about the 18         number.
I don't recollect the magnitude of them any 5
19                   What I am asking you now, thinking back
more.
          .            Q 20   to that time period, the number of care packages 21   that had to be prepared and what had to go into each 22   care package as you have previously described that 23   process, would you agree tfith Nelson Brown that the 24    preparation of these care packages was a "very
6 Q
Would ~you agree with Nelson Brown 7
that the preparation of these care packages was a 8
very time-consuming process?
9 MR. MacDONALD:
You are asking him now 10 for his recollection some time in 1978, whether 11 he can recall whether the preparation of those 12 care packages in 1978 was a time-consuming
,(,l 13 p ro ce s s ?
14 MR. FISKE:
1978 or
'79.
Right up to 15 MR. MacDONALD:
I am jus t asking for what 16 your question is intending to do.
17 MR. FISKE:
I am not talking about the 18 number.
19 Q
What I am asking you now, thinking back 20 to that time period, the number of care packages 21 that had to be prepared and what had to go into each 22 care package as you have previously described that 23 process, would you agree tfith Nelson Brown that the
('~')
('~')
      \_/
24 preparation of these care packages was a "very
25   time-consuming p rocess"?
\\_/
25 time-consuming p rocess"?


1 Zechman                   189 2               MR. MacDONALD:   Objection to.the form 3         of the question.
1 Zechman 189 2
4               Do you want to ask what his recollection 5
MR. MacDONALD:
is and wheth r or not it was a time-consuming 6       process?     You may ask that question.
Objection to.the form 3
of the question.
4 Do you want to ask what his recollection 5
is and wheth r or not it was a time-consuming 6
process?
You may ask that question.
7 The form of your question I think is objectionable.
7 The form of your question I think is objectionable.
8 Q     Is it fair to say that the preparation 9 of these care packages, taking into account both 10 the numbers that had to be prepared and what had 11 to go into each package, was a very time-consuming 12 process?
8 Q
13               MR. MacDONALD:   What Mr. Brown may have 14 interpreted as time-consuming, I don't know 15         what   he meant, you don't know   what he meant.
Is it fair to say that the preparation 9
16 Surely Mr. Zechman wasn't there talking to him, 17         so he doesn't know, i   IO If you want to ask apart from that   --
of these care packages, taking into account both 10 the numbers that had to be prepared and what had 11 to go into each package, was a very time-consuming 12 process?
19 j                     MR. FISKE:   At the moment, I am asking i
13 MR. MacDONALD:
!  20         apart from Mr. Brown.
What Mr. Brown may have 14 interpreted as time-consuming, I don't know 15 what he meant, you don't know what he meant.
16 Surely Mr. Zechman wasn't there talking to him, 17 so he doesn't know, i
IO If you want to ask apart from that 19 j
MR. FISKE:
At the moment, I am asking i
20 apart from Mr. Brown.
I am asking it apart l
I am asking it apart l
21         from Mr. Brown.
21 from Mr. Brown.
22               Just your own recollection of that Q
22 Q
23 whole situation, the number of packages ti.a t had to 24 he prepared and what had to go into each package.
Just your own recollection of that 23 whole situation, the number of packages ti.a t had to 24 he prepared and what had to go into each package.
25 Is it fair to say that was a very L
25 Is it fair to say that was a very L


_    . _ _ _          -    _ = _     . -                  .-.    -_      ..-      -    ~~               _.-
_ = _
1 1                                                       Zechman                           190 1                           2           time-consuming process?
~~
3                     A           I testify that the time it takes to prepare 4           a care package is directly related to the subject I               5           matter, the depth of the subject matter, and the 6           amount of material to be covered during that period i
1 1
7           of time.
Zechman 190 1
8                                 Therefore, some care packages would
2 time-consuming process?
  ,                        9          take a lot less time than others.                             It varies from
3 A
,                          10           care package to care package.
I testify that the time it takes to prepare 4
11                       Q         I recognize there might be that variation 12           across the whole number that had to be prepared i3           right up to 2500.
a care package is directly related to the subject I
,                          14                                 I am just saying, taking into account 15           what went into each package, coupled with the total 16           number of packages that had to be prepared, isn't it 17           fair to say that that whole process was very
5 matter, the depth of the subject matter, and the 6
.                          18           time-consuming?
amount of material to be covered during that period i
19                     A           You quoted a number of 2500.                     I don't 20           agree with that number.
7 of time.
21                     Q           I said whatever it was up                     to 2500.
8 Therefore, some care packages would 9
22                                 MR. MacDONALD:                 Whatever your recollection 23                       is, Mr. Zechman.
take a lot less time than others.
()                   24                     A           It is recognizable that the number of 25           care packages we had at the time when attendance was
It varies from 10 care package to care package.
11 Q
I recognize there might be that variation 12 across the whole number that had to be prepared i3 right up to 2500.
14 I am just saying, taking into account 15 what went into each package, coupled with the total 16 number of packages that had to be prepared, isn't it 17 fair to say that that whole process was very 18 time-consuming?
19 A
You quoted a number of 2500.
I don't 20 agree with that number.
21 Q
I said whatever it was up to 2500.
22 MR. MacDONALD:
Whatever your recollection 23 is, Mr. Zechman.
()
24 A
It is recognizable that the number of 25 care packages we had at the time when attendance was


1 Zechman                   191
1 Zechman 191
  ,n
,n
('"' )
2  low, was time-consuming and required us to do 3 extra work.
4        Q      Isn't it also true that in addition to h  5 sending out the material, it was necessary to track 6  it to follow that the individual did, in fact, 7  receive it?
8        A    That was part of the normal job with
.            9 the requalification programs, to track any care 10  packages that were sent out. That was a rather 11  easy task, though, because that was done with    a 12  matrix.
(
(
(s /   13         Q     Just so I understand   it, the burden of 14 preparing these care packages fell on the people 15 who were conducting the classroom sessions, is that 16 correct?
)
17         A     I don't   know that I would call it a 18 burden. It's their responsibility to prepare those 19 care packages.
2 low, was time-consuming and required us to do 3
20         Q     Whatever time was devoted to preparing 21 those care packages was devoted by the people who 22 were conducting the classroom sessions, isn't that 23 correct?
extra work.
[       24       A     That is correct.
4 Q
V; 25       Q     And those were the people that held the
Isn't it also true that in addition to h
5 sending out the material, it was necessary to track 6
it to follow that the individual did, in fact, 7
receive it?
8 A
That was part of the normal job with 9
the requalification programs, to track any care 10 packages that were sent out.
That was a rather 11 easy task, though, because that was done with a
12 matrix.
((s /
13 Q
Just so I understand it, the burden of 14 preparing these care packages fell on the people 15 who were conducting the classroom sessions, is that 16 correct?
17 A
I don't know that I would call it a 18 burden.
It's their responsibility to prepare those 19 care packages.
20 Q
Whatever time was devoted to preparing 21 those care packages was devoted by the people who 22 were conducting the classroom sessions, isn't that 23 correct?
[
24 A
That is correct.
V; 25 Q
And those were the people that held the


1                           Zechman                   192 N
1 Zechman 192 N
s                   2 position of administrator / technical training as it has 3 been described; so-called instructors?
s 2
4         A     Yes, sir. There are times when the G           5 group supervisors may have participated.
position of administrator / technical training as it has 3
6         Q     It would either be the group supervisors 7 or the instructors?
been described; so-called instructors?
8         A     That is correct.           *
4 A
                              ~
Yes, sir.
9              May we take a break?
There are times when the G
10               Sure.
5 group supervisors may have participated.
Q 11 (Recess taken.)
6 Q
12               MR. FIS KE : Read back the last question O(_/               13         and answer, please.
It would either be the group supervisors 7
14               (Record r ead back. )
or the instructors?
15 BY MR. FISKE:
8 A
16         Q     Directing your attention, Mr. Zechman, 17 again to the document that has been marked as B&W 18 358, which are Mr. Keaten's notes of the interview, 19 I am showing you the second page, the third item, 20 which, as I read it, says, "No club to enforce 21 attendance except licensing exam."
That is correct.
22               Do you see that?
9
23         A     I see that.
~
24               Isn't it a fact that before the Three Q
May we take a break?
25  : tile Island accident, you felt that there was no club a
10 Q
Sure.
11 (Recess taken.)
12 MR. FIS KE :
Read back the last question O(_/
13 and answer, please.
14 (Record r ead back. )
15 BY MR. FISKE:
16 Q
Directing your attention, Mr. Zechman, 17 again to the document that has been marked as B&W 18 358, which are Mr. Keaten's notes of the interview, 19 I am showing you the second page, the third item, 20 which, as I read it, says, "No club to enforce 21 attendance except licensing exam."
22 Do you see that?
23 A
I see that.
24 Q
Isn't it a fact that before the Three 25
: tile Island accident, you felt that there was no club a


1                                                 Zechman                             193 O           2     to enforce attendance except the licensing exam?
1 Zechman 193 O
3           A     Are you asking me if that is my quote?
2 to enforce attendance except the licensing exam?
4                 MR. MacDONALD:                     That is basically what 5           he is asking you, whether you recall saying that.
3 A
.                6           Q     That you held that view.
Are you asking me if that is my quote?
7           A     I held a view prior to the accident 8     that it was the responsibility of the line function 9     in this case, line function operations department, 10     to have their people attend training.
4 MR. MacDONALD:
11           Q     As far as the people who were supposed I
That is basically what 5
12     to attend the training were concerned, there was no
he is asking you, whether you recall saying that.
()         13     club to get them to go to the training except the 14     licensing exam?
6 Q
15                 MR. MacDONALD:                     I object to the form of 16           the question.           He gave his answer.
That you held that view.
17                 I also think that you have not attributed 18           that statement to him.                     What somebody may have 19           said or wrote on the pages is their 20           interpretation of what was said --
7 A
21                 MR. FISKE:                     It is a preliminary question.
I held a view prior to the accident 8
22           g     Isn't it a fact that was a view that you 23     held?
that it was the responsibility of the line function 9
A 24           A     That is not a fact.
in this case, line function operations department, 10 to have their people attend training.
25           g     Isn't it a fact that you made a statement
11 Q
As far as the people who were supposed I
12 to attend the training were concerned, there was no
()
13 club to get them to go to the training except the 14 licensing exam?
15 MR. MacDONALD:
I object to the form of 16 the question.
He gave his answer.
17 I also think that you have not attributed 18 that statement to him.
What somebody may have 19 said or wrote on the pages is their 20 interpretation of what was said --
21 MR. FISKE:
It is a preliminary question.
22 g
Isn't it a fact that was a view that you 23 held?
A 24 A
That is not a fact.
25 g
Isn't it a fact that you made a statement


1                           Zechman                     194 7_
1 Zechman 194 7_
    'N' '/
'N' '/
2   to that effect to Mr. Keaten during this interview?
2 to that effect to Mr. Keaten during this interview?
3               MR. MacDONALD:     By "you" you mean Mr.
3 MR. MacDONALD:
4         Zechman?
By "you" you mean Mr.
5               MR. FISKE:   Yes.
4 Zechman?
6         A     I have no recollection of making a 7   statement in that format.
5 MR. FISKE:
8               I do recall making, to the best of my
Yes.
  ,            9  recollection, a statement that it's the responsibility 10   of the line function to get the people there.
6 A
11         Q     The question is, what can they do about 12   it if the people don't go?     You understand what we
I have no recollection of making a 7
(' \
statement in that format.
    \J~      13   are talking about.                                         ,
8 I do recall making, to the best of my 9
14               MR. MacDONALD:     He gave you his recollection 15         twice as to the question that you have asked.
recollection, a statement that it's the responsibility 10 of the line function to get the people there.
16               Do you have another question?
11 Q
l             17               MR. FISKE:   Yes. It is the same question.
The question is, what can they do about 12 it if the people don't go?
l 18         I don't believe it has been answered.
You understand what we
l 19         Q     Did you tell Mr. Keaten during this l
(' \\
l             20   interview that there was no club to enforce the g 21   attendance other than the licensing program?
\\J 13 are talking about.
22               MR. MacDONALD:     Objection. If you 23         would like -- and I know you are not trying l     rx t l   l     ,
~
24 i       to prolong this depositio n -- he just told you
14 MR. MacDONALD:
    \_/         l 25         two questions and answers ago that he didn't
He gave you his recollection 15 twice as to the question that you have asked.
16 Do you have another question?
l 17 MR. FISKE:
Yes.
It is the same question.
l 18 I don't believe it has been answered.
l 19 Q
Did you tell Mr. Keaten during this l
l 20 interview that there was no club to enforce the 21 attendance other than the licensing program?
g 22 MR. MacDONALD:
Objection.
If you 23 would like -- and I know you are not trying l
rx l
l 24 i
to prolong this depositio n -- he just told you t
\\_/
l 25 two questions and answers ago that he didn't


1                                                         Zechman                   195 O             2                               recall ever making that.           What he recalled in 3                               that subject areas           was what he testified to.
1 Zechman 195 O
1 4                               Q     Is that correct, Mr. Zechman, what your 5             counsel just said?
2 recall ever making that.
6                               A     That is correct.
What he recalled in 3
7                               Q     I will read you from a question and 8             answer at Mr. Keaten's deposition.                       I will be happy 9             to come over there since I'm sure you don't have 10           copies over thera.
that subject areas was what he testified to.
i 11                                     Reading from page 705 of Mr. Keaten's 12           deposition, the question is, "Would you look at 13           the next page of your handwritten notes.                         I recognize 14           it is a very poor copy.                         Unfortunately, this is the i
4 Q
15           best we can do working from the microfilm that we
Is that correct, Mr. Zechman, what your 1
,                  16           had.
5 counsel just said?
i 17                                     "Looking at the third comment down i
6 A
i                 18           from the top of the page, the one that begins and 19           reads 'no club to enforce attendance except licensing i                 20           exam,' do you see that?
That is correct.
7 Q
I will read you from a question and 8
answer at Mr. Keaten's deposition.
I will be happy 9
to come over there since I'm sure you don't have 10 copies over thera.
i 11 Reading from page 705 of Mr. Keaten's 12 deposition, the question is, "Would you look at 13 the next page of your handwritten notes.
I recognize 14 it is a very poor copy.
Unfortunately, this is the i
15 best we can do working from the microfilm that we 16 had.
i 17 "Looking at the third comment down i
i 18 from the top of the page, the one that begins and 19 reads 'no club to enforce attendance except licensing i
20 exam,' do you see that?
l f
l f
I                 21                                     "A awer:       I think that is what it says.
I 21 "A awer:
ggg 22                                     " Question:         Did members of the training 23           staff complain that before the accident they had no l
I think that is what it says.
24           way to enforce attendance at training sessions other j                 25 l than the threat of possible failure of the licensing i
ggg 22
" Question:
Did members of the training 23 staff complain that before the accident they had no l
24 way to enforce attendance at training sessions other j
25 l than the threat of possible failure of the licensing i


1 Zechman                     196 C)                           2           exam?
1 Zechman 196 C) 2 exam?
3                                   " Answer:               I believe that I recollect that 4           a comment as to that regard was made.                               I don't 5           remember specifically whether it was a complaint or 4
3
,                                6           simply a comment.
" Answer:
7                                 " Question:                 Do you know who made the 8           comment, Mr. Zechman or Mr. Beers?
I believe that I recollect that 4
  .                              9                                 " Answer:                 I believe, to the best of my         "
a comment as to that regard was made.
10             recollection, it was made by Mr. Zechman."                                 .
I don't 5
11                                   Hearing those questions and those answers 12 from Mr. Keaten's testimony, does that refresh your 13 recollection that you made such a statement to 14             Mr. Keaten?
remember specifically whether it was a complaint or 4
15                                   MR. MacDONALD:                   I object to the form of 16                       the question.                 He wasn't there when Keaten was 17                       deposed and he doesn't know what was meant.
6 simply a comment.
18                       You don't have to look incredulously across the 19                       table.                                                                 -
7
20                                   MR. FISKE:                   I think I am asking an entirely 21                       reasonable question.                         Having heard Mr. Keaten's 22                         testimony that to the best of his recollection 23 Mr. Zechman made the statement that we have
" Question:
()                       24                       been talking about, I am simply asking whether 25 that helps Mr. Zechman remember that, in fact,
Do you know who made the 8
    --~-r,-- -- - , - , ,-y, e,-,.   -r-.-,, - , - -,~-----w,w-re     ,- ,,-r.,-,,r,
comment, Mr. Zechman or Mr. Beers?
9
" Answer:
I believe, to the best of my 10 recollection, it was made by Mr. Zechman."
11 Hearing those questions and those answers 12 from Mr. Keaten's testimony, does that refresh your 13 recollection that you made such a statement to 14 Mr. Keaten?
15 MR. MacDONALD:
I object to the form of 16 the question.
He wasn't there when Keaten was 17 deposed and he doesn't know what was meant.
18 You don't have to look incredulously across the 19 table.
20 MR. FISKE:
I think I am asking an entirely 21 reasonable question.
Having heard Mr. Keaten's 22 testimony that to the best of his recollection 23 Mr. Zechman made the statement that we have
()
24 been talking about, I am simply asking whether 25 that helps Mr. Zechman remember that, in fact,
--~-r,--
-- -, -,,-y, rr e,-,.
-r-.-,,
-,~-----w,w-re
,,-r.,-,,r, r,-
-..w,,,, - - - -,. - -,, - - -,. - - - -, - - -


I 1
I 1
Zec hman                   197
Zec hman 197
  ,n
,n
  ~.       2 he did make that statement.
~.
3         A     I stick to my previous testimony.
2 he did make that statement.
4         Q     Isn't it a fact, Mr. Zechman, that even 5   after the Three Mile Island accident, attendance 6     at training sessions continued to be poor?
3 A
7                 MR. MacDONALD:     I object to the form of 8         the question.
I stick to my previous testimony.
9                 I think he has testified previously that 10 he has some recollection at some point in time 11 and you are using the term " continued" and I 12 don't think that is proper based on what the
4 Q
  /~'T
Isn't it a fact, Mr. Zechman, that even 5
( ,/
after the Three Mile Island accident, attendance 6
13           testimony has been.
at training sessions continued to be poor?
I4                 MR. FISKE:   We have yet to identify that 15 time.
7 MR. MacDONALD:
i 16 Q     Isn't it a fact that as late as 17   December of 1979, more than six months after the 18 Three Mile Island accident, attendance at training 19   sessions continued to be poor at Met Ed?
I object to the form of 8
20                 MR. MacDONALD:     I object to the form of 21           the question.
the question.
g) 22                 You may answer.
9 I think he has testified previously that 10 he has some recollection at some point in time 11 and you are using the term " continued" and I 12 don't think that is proper based on what the
Q 23 THE WITNESS:   Would you repeat that question
/~'T
  / ';   24           for me, please.
(,/
  \J 25 (Record read back.J
13 testimony has been.
I4 MR. FISKE:
We have yet to identify that 15 time.
i 16 Q
Isn't it a fact that as late as 17 December of 1979, more than six months after the 18 Three Mile Island accident, attendance at training 19 sessions continued to be poor at Met Ed?
20 MR. MacDONALD:
I object to the form of 21 the question.
g) 22 Q
You may answer.
23 THE WITNESS:
Would you repeat that question
/ ';
24 for me, please.
\\J 25 (Record read back.J


1 Zechman                   198
1 Zechman 198
    , ,3 fVl 2         A     I'm sorry, I have no recollection of 3 magnitude of attendance at that period of time.
,3 fVl 2
4         Q     You don't have any recollection that 5
A I'm sorry, I have no recollection of 3
classroom attendance in the requalification program 6 reached an all-time low in the period November of 7   '79 through December '79?
magnitude of attendance at that period of time.
8         A     I'm just stating right today I don't 9 recollect the time frames, the attendance time 10 frames. That is all I'm saying.
4 Q
          'll Q     Your answer to my last question is you 12
You don't have any recollection that 5
    / ,'
classroom attendance in the requalification program 6
don't remember?
reached an all-time low in the period November of 7
k-     13         A     I don't remember today.
'79 through December '79?
14 MR. FISKE:   Let's mark the next exhibit 15 B&W Exhibit 563.
8 A
16 (Copy of a memorandum dated 12/20/79 17 from Mr. Zechman to L. L. Lawyer marked 18 B&W Exhibit No. 563 for identification as of 19 this date.)
I'm just stating right today I don't 9
20               Have you had a chance to look at B&W Q
recollect the time frames, the attendance time 10 frames.
21   Exhibit 5637 22         A     I have.
That is all I'm saying.
23 Q     That is dated 12/2G/79, is it not?
'll Q
      /^
Your answer to my last question is you 12 don't remember?
24
/,'
(_)\           A     That is correct.
k-13 A
25 Q    
I don't remember today.
14 MR. FISKE:
Let's mark the next exhibit 15 B&W Exhibit 563.
16 (Copy of a memorandum dated 12/20/79 17 from Mr. Zechman to L.
L.
Lawyer marked 18 B&W Exhibit No. 563 for identification as of 19 this date.)
20 Q
Have you had a chance to look at B&W 21 Exhibit 5637 22 A
I have.
23 Q
That is dated 12/2G/79, is it not?
/^
(_)\\
24 A
That is correct.
25 Q


==Subject:==
==Subject:==
    " Unit 2 Requalification
" Unit 2 Requalification


1                           Zechman                   199 7-~ t K. /       2 Attendance"?
1 Zechman 199 7-~ t K. /
3       A     That is correct.
2 Attendance"?
4         Q     Is that your signature at the bottom, k 5 "R. W. Zechman, Supervisor of Training"?
3 A
6         A     That is not my signature, and he had 7 authority to sign my signature to that letter.
That is correct.
4 Q
Is that your signature at the bottom, k
5 "R.
W.
Zechman, Supervisor of Training"?
6 A
That is not my signature, and he had 7
authority to sign my signature to that letter.
8 I drafted the letter; he signed it.
8 I drafted the letter; he signed it.
9       Q     If I understand you, this document has 10 just been identified as a document that you drafted 11 and Mr. Frederick put your signature to, with your 12 authority?
9 Q
    /^N
If I understand you, this document has 10 just been identified as a document that you drafted 11 and Mr. Frederick put your signature to, with your 12 authority?
(,)       13         A     That is correct.
/^N
14         Q     Was this a memorandum that you wrote in 15 the regular course -- that you prepared in the regular 16 course of business as supervisor of training?
(,)
17         A     Can you repeat that?
13 A
18         Q     Was this written as part of your job?
That is correct.
          . 19 Was this done in the course of your duties?
14 Q
20         A     In accordance with my duties to make 1
Was this a memorandum that you wrote in 15 the regular course -- that you prepared in the regular 16 course of business as supervisor of training?
21 these kinds of things, yes.
17 A
22               MR. FISKE   Mark this as the next exhibit.
Can you repeat that?
23               (Copy of a memorandum from James P.
18 Q
      /~N
Was this written as part of your job?
(
19 Was this done in the course of your duties?
24         o'Hanlon marked B&W Exhibit No. 564 for s.s) 25         identification as of this date.)
20 A
In accordance with my duties to make 1
21 these kinds of things, yes.
22 MR. FISKE Mark this as the next exhibit.
23 (Copy of a memorandum from James P.
/~N 24 o'Hanlon marked B&W Exhibit No. 564 for (s.s) 25 identification as of this date.)


1 I
1 1
1 Zechman                   200   j
Zechman 200 j
    ;    e
e
    \/               2         Q     Do you still have Exhibit 563 in front 3 of you?
\\/
4       A     Yes, I do.
2 Q
lh     5 Q     The first sentence refers, does it not, 6
Do you still have Exhibit 563 in front 3
to a report prepared for you by Mr. Frederick 7 concerning attendance at the Unit 2 requalification 0
of you?
program for the period of November 5, '79 through 9 December 14,     '797 e
4 A
10 A     That is correct.
Yes, I do.
11 Q     The   next sentence says, "The results 12 of this survey indicated an all-time low in       classroom
lh 5
      .e^
Q The first sentence refers, does it not, 6
(_,Nl         13 attendance for this short period of a little over 14 one   month."
to a report prepared for you by Mr. Frederick 7
concerning attendance at the Unit 2 requalification 0
program for the period of November 5,
'79 through 9
December 14,
'797 e
10 A
That is correct.
11 Q
The next sentence says, "The results 12 of this survey indicated an all-time low in classroom
.e^
(_,Nl 13 attendance for this short period of a little over 14 one month."
15 Do you see that?
15 Do you see that?
16 A     I see that.
16 A
1
I see that.
,                              Q      Did you underline the word " low" in that 18 sentence, or did Mr. Frederick?
1 Q
i l                             A     To the best of my recollection, I wrote 1
Did you underline the word " low" in that 18 sentence, or did Mr. Frederick?
20 the letter and I underlined it.
i l
A To the best of my recollection, I wrote 1
20 the letter and I underlined it.
21
21
                )             Q     Two sentences later it says, "Because 22 of the poor attendance, Ed Frederick had to prepare 23 332 ' care packages' to be sent out for make-up and to 4
)
      ;    i           be tracked.';
Q Two sentences later it says, "Because 22 of the poor attendance, Ed Frederick had to prepare 23 332 ' care packages' to be sent out for make-up and to 4
      \_/
i be tracked.';
\\_/
25 Do you see that sentence?
25 Do you see that sentence?


1                           Zechman                     201 0     2         A     I do.
1 Zechman 201 0
3         Q     was_the procedure for preparing care 4   packages after the Three Mile Island accident h   5   essentially as it had been before~in terms of what
2 A
;        6  went into them and how it was done?
I do.
7         A     Yes.
3 Q
8         Q     In the next p.tragraph there is a 9   reference to two gentlemen named Joe chwastyk and 10   Bernie Smith, who, it is stated, did not attend a 11   single lecture out of 20 given.
was_the procedure for preparing care 4
12                 Do you see that reference?
packages after the Three Mile Island accident h
I'3         A     Yes, I do.
5 essentially as it had been before~in terms of what 6
14           Q     Who is Mr. Chwastyk?
went into them and how it was done?
15           A     He was a shift supervisor, Unit 2.
7 A
16           Q     And Mr. Smith?
Yes.
i 17           A     Shift supervisor, Unit 2.
8 Q
18           Q     And the next sentence after that says, 19   "Even though hunting season and vacations may l
In the next p.tragraph there is a 9
20   have interfered, no attempt to make up the lecture 21   during relief week or any other time was made."
reference to two gentlemen named Joe chwastyk and 10 Bernie Smith, who, it is stated, did not attend a 11 single lecture out of 20 given.
22                 Does that sentence refer back to i
12 Do you see that reference?
23   Mr. Chwastyk and Mr. Smith?
I'3 A
l 24           A     To the best of my recollection, it did.
Yes, I do.
25         Q     This memorandum is written to Mr. L. L.
14 Q
Who is Mr. Chwastyk?
15 A
He was a shift supervisor, Unit 2.
16 Q
And Mr. Smith?
i 17 A
Shift supervisor, Unit 2.
18 Q
And the next sentence after that says, 19 "Even though hunting season and vacations may l
20 have interfered, no attempt to make up the lecture 21 during relief week or any other time was made."
22 Does that sentence refer back to i
23 Mr. Chwastyk and Mr. Smith?
l 24 A
To the best of my recollection, it did.
25 Q
This memorandum is written to Mr.
L.
L.


1                           Zechman                     202 2   Lawyer, is that correct?
1 Zechman 202 2
3         A     That is correct.
Lawyer, is that correct?
4         Q     What was his position?
3 A
lh   5         A     Acting manager of training.
That is correct.
6         Q     The last sentence says, or next to last, 7   "I believe we have reached the point where the ' clout' 8   of senior management personnel such as yourself is
4 Q
.          9  required to proclaim the mandatory requirement 10   for operations personnel to attend the requalification 11   lectures and to impress upon them their responsibility 12   to meet the requirements of their license."
What was his position?
lh 5
A Acting manager of training.
6 Q
The last sentence says, or next to last, 7
"I believe we have reached the point where the ' clout' 8
of senior management personnel such as yourself is 9
required to proclaim the mandatory requirement 10 for operations personnel to attend the requalification 11 lectures and to impress upon them their responsibility 12 to meet the requirements of their license."
O
O
  \/       13               Do you see that?
\\/
14         A     Yes, I do.
13 Do you see that?
15         Q     Mr. Lawyer was part of senior management 16   personnel?
14 A
17         A     Yes, he was.
Yes, I do.
18               Did he have the position comparable Q
15 Q
19   to the position that Mr. Tsaggaris held in 19787 20         A     No.
Mr. Lawyer was part of senior management 16 personnel?
21         Q     Was there a position in existence in g
17 A
22   1978 comparable to the position Mr. Lawyer held in 23   December of '797 24
Yes, he was.
(                   A     one position, that was Tsaggaris', was 25   a director. Mr. Lawyer's position was acting manager.
18 Q
Did he have the position comparable 19 to the position that Mr. Tsaggaris held in 19787 20 A
No.
21 Q
Was there a position in existence in g
22 1978 comparable to the position Mr. Lawyer held in 23 December of '797
(
24 A
one position, that was Tsaggaris', was 25 a director.
Mr. Lawyer's position was acting manager.


1                                 Zechman                   203
1 Zechman 203
[']
[']
x>         2                   By title they are not the same.     By 3 authority, I don't know how to compare them, to be 4 ho n e s t .
x>
I   5           Q       Well, trying to compare the two positions 6 as they existed, did you feel in '79 that 7 Mr. Lawyer had more " clout" than Mr. Tsaggaris held 8 in 19787 9                   MR. MacDONALD:     You are asking if he has 10           a recollection of making that       comparison 11           in or around the time he wrote the memorandum?
2 By title they are not the same.
12                   MR. FISKE:     No, I am asking him to make it p!
By 3
authority, I don't know how to compare them, to be 4
ho n e s t.
I 5
Q Well, trying to compare the two positions 6
as they existed, did you feel in '79 that 7
Mr. Lawyer had more " clout" than Mr. Tsaggaris held 8
in 19787 9
MR. MacDONALD:
You are asking if he has 10 a recollection of making that comparison 11 in or around the time he wrote the memorandum?
12 MR. FISKE:
No, I am asking him to make it p!
(_,
(_,
13           now.
13 now.
14                   MR. MacDONALD:     I am going to object to 15           that. Ask him what he recollects at this time.
14 MR. MacDONALD:
16           A       Do I answer?
I am going to object to 15 that.
l 17           Q       Yes.
Ask him what he recollects at this time.
l l           18                   M R' . MacDONALD: I cbject to a present-sense 19           impression sLtting here today as an opinion.
16 A
20           I don't think you allowed your witnesses to 21           answer those types of questions.
Do I answer?
9 l           22                   If you want to ask in or around this l
l 17 Q
23           time period -- as a matter of fact, I think I l
Yes.
    ~
l l
24           will instruct him not to answer.
18 M R'. MacDONALD:
i  ( m.
I cbject to a present-sense 19 impression sLtting here today as an opinion.
LJ l           25           Q       This memo in December of 1979 wasn't the l
20 I don't think you allowed your witnesses to 21 answer those types of questions.
9 l
22 If you want to ask in or around this l
23 time period -- as a matter of fact, I think I l
i
(
m.
24 will instruct him not to answer.
~
LJ l
25 Q
This memo in December of 1979 wasn't the l
l l
l l


1 Zechman                   204 O 2 first time that you had thought of invoking the " clout" 3 of higher authority in order to try to induce people 4 to attend training sessions, was it?
1 Zechman 204 O
5               MR. MacDONALD:         Whether this was the first 6
2 first time that you had thought of invoking the " clout" 3
of higher authority in order to try to induce people 4
to attend training sessions, was it?
5 MR. MacDONALD:
Whether this was the first 6
time he can recall using the term " clout"?
time he can recall using the term " clout"?
7               MR. FISKE:         No, that is a colloquial term.
7 MR. FISKE:
8 You can equate it with any other noun that 9       occurs to you.           In other words, the very simple 10       point is that this time frame in December o'f 11
No, that is a colloquial term.
                '79 was not the first time it had ever occurred 12 to him that he should try to take the problem 13 of poor attendance to higher management to try 14       to get an improvement in the situation.
8 You can equate it with any other noun that 9
15       A       To the best of my recollection, this 16 isn't the only time that I have done that.
occurs to you.
II Q       Is it still your testimony that you 10 don't recall anyone saying to Mr. Keaten in October 19 og e79 that prior to the Three Mile Island accident, 20 the problem of poor attendance was brought to the 21 attention of the plant management on a number of 22 occasions and the response to those letters was not 23 at all apparent as attendance continued to go down?
In other words, the very simple 10 point is that this time frame in December o'f 11
24 MR. MacDONALD:         I think you have asked 25 him that question and he gave you the answer.
'79 was not the first time it had ever occurred 12 to him that he should try to take the problem 13 of poor attendance to higher management to try 14 to get an improvement in the situation.
15 A
To the best of my recollection, this 16 isn't the only time that I have done that.
II Q
Is it still your testimony that you 10 don't recall anyone saying to Mr. Keaten in October 19 og e79 that prior to the Three Mile Island accident, 20 the problem of poor attendance was brought to the 21 attention of the plant management on a number of 22 occasions and the response to those letters was not 23 at all apparent as attendance continued to go down?
24 MR. MacDONALD:
I think you have asked 25 him that question and he gave you the answer.


1 Zechman                     205 I     i
1 Zechman 205 I
    \_/
i
2               MR. FISKE:   I am asking him is that still 3         his recollection, in light of the memorandum 4         that I have just shown him in December of   '79.
\\_/
lI   5               THE WITNESS:   Read it back.
2 MR. FISKE:
6                 (Record read back.)
I am asking him is that still 3
7               MR. MacDONALD:   My objection stands.
his recollection, in light of the memorandum 4
8         A     My only recollection still stands, what
that I have just shown him in December of
  .              9  I have testified to before, that I made him aware 10   of the attendance problem.
'79.
11               The memo that you have in front of you, Q
lI 5
12 B&W Exhibit 563, that you prepared, do you see it?
THE WITNESS:
r
Read it back.
    \
6 (Record read back.)
(-  <
7 MR. MacDONALD:
x/       13   Do you have it in front of you, the December 20, '79 14   memo?
My objection stands.
l 15         A     Yes.
8 A
16               Do you see the reference to the word Q
My only recollection still stands, what 9
II
I have testified to before, that I made him aware 10 of the attendance problem.
                    " clout" in the paragraph I read just a minute ago?
11 Q
18 A     Yes, I do.
The memo that you have in front of you, 12 B&W Exhibit 563, that you prepared, do you see it?
19               That   is in the memo written by you, Q
r (-
20   is that right?
\\
21         A     That is in the memo written by me.
x/
l            gg 22               You have put " clout" in quotes.
13 Do you have it in front of you, the December 20, '79 l
Q 3         A
14 memo?
                  ,              And I put " clout" in quotes.
15 A
()
Yes.
1    /~~
16 Q
24               Let me read from the Exhibit 561 Q
Do you see the reference to the word II
25   which are the handwritten notes of the meeting you
" clout" in the paragraph I read just a minute ago?
18 A
Yes, I do.
19 Q
That is in the memo written by you, 20 is that right?
l gg 21 A
That is in the memo written by me.
22 Q
You have put " clout" in quotes.
3 A
And I put " clout" in quotes.
1
/~~()
24 Q
Let me read from the Exhibit 561 25 which are the handwritten notes of the meeting you


1 Zechman                     206
1 Zechman 206 2
    '-      2 had with Mr. Keaten on October 18, 1979.
had with Mr. Keaten on October 18, 1979.
3 Immediately following -- let me read 4
3 Immediately following -- let me read 4
two sentences in sequence.     "This attendance was 5
two sentences in sequence.
brought   to the attention of the plant management 6
"This attendance was 5
on a number of occasions. The response to those letters was not at all apparent as attendance 8
brought to the attention of the plant management 6
continued to go down. Even with the training 9
on a number of occasions.
The response to those letters was not at all apparent as attendance 8
continued to go down.
Even with the training 9
department reporting back to Redding for separation 10 purposes, et cetera, they did not seem to get any 11 clout to force the OPS department to improve 12 attendance."
department reporting back to Redding for separation 10 purposes, et cetera, they did not seem to get any 11 clout to force the OPS department to improve 12 attendance."
  -    8 i
8 i
  \/ )    13 I will ask you whether or not you made 14 that statement t o Mr. Keaten.
)
15 MR. MacDONALD:     You have asked it three 16 times and he has told you his best recollection.
13
17 MR. FISKE:   I am referring to the sentence 18 that I have read for the first time which I will 19 read now, the one with the word " clout" in it.
\\/
20 It reads, from   the notes of the meeting h           with Mr. Keaten, "Even with the training 22 department reporting     back to Redding for 23
I will ask you whether or not you made 14 that statement t o Mr. Keaten.
              !      separation purposes, et cetera, they did not I
15 MR. MacDONALD:
r^s     24
You have asked it three 16 times and he has told you his best recollection.
('uj)             seem to get any     clout to force the OPS 25 department to improve attendance."
17 MR.
FISKE:
I am referring to the sentence 18 that I have read for the first time which I will 19 read now, the one with the word " clout" in it.
20 It reads, from the notes of the meeting h
with Mr. Keaten, "Even with the training 22 department reporting back to Redding for 23 separation purposes, et cetera, they did not I
r^s 24
'uj) seem to get any clout to force the OPS
(
25 department to improve attendance."


1                                             zechman                                                     207 2         Q         Having             seen your memo where you used 3  the word " clout" in quotes, does that refresh your 4   recollection that you were the source of the lh   5  information in the sentence I just read f rom Exhibit 6   5617 7                   MR. MacDONALD:                           I object.             I don't know 8         whether that was ever even said at the time 9         of an interview.
1 zechman 207 2
10                   MR. FISKE:                   You can object.
Q Having seen your memo where you used the word " clout" in quotes, does that refresh your 3
11                   MR. MacDONALD:                           I have just stated my 12         objection.
4 recollection that you were the source of the lh information in the sentence I just read f rom Exhibit 5
4
6 5617 7
()     13         Q         You may answer.
MR. MacDONALD:
I           14         A         I have no recollection of the choice of i
I object.
l 15 my words at that time.
I don't know 8
16                   MR. FISKE:                   I think I previously marked 17         as Exhibit 564 a document that I have yet 18         shown the witness and I will do that now.
whether that was ever even said at the time 9
of an interview.
10 MR. FISKE:
You can object.
11 MR. MacDONALD:
I have just stated my 12 objection.
4 ()
13 Q
You may answer.
I 14 A
I have no recollection of the choice of i
l 15 my words at that time.
16 MR. FISKE:
I think I previously marked 17 as Exhibit 564 a document that I have yet 18 shown the witness and I will do that now.
l l
l l
l 19                   This is a document, a handwritten note,                                                   .
19 This is a document, a handwritten note, l
20         four pages.
20 four pages.
!        g 21         Q         Do you have that in front of you?
g 21 Q
l         W 22         A         Yes.
Do you have that in front of you?
23         Q         You may want to take a moment to read i
l W
!                that.
22 A
24 25         A         I have read it.
Yes.
23 Q
You may want to take a moment to read i
24 that.
25 A
I have read it.
I t
I t
f
f


1                             Zechman                       208 p.
1 Zechman 208 p.
(
(
    \/ )          2         Q     That contains a memorandum to Mr. O'Hanlon, 3   handwritten memorandum to Mr. O'Hanlon from Mr.       T. L.
)
4   Book, does it not, with a covering memo from Mr. O'Hanlon llk 5   to Mr. G. R. Miller, Mr. Tsaggaris, Mr. Goodman, 6   yourself, and Mr. Kunder, is that correct?
\\/
7         A     Yes.
2 Q
8         Q     can you tell us, looking at the first 9   page, what the date is of Mr. O'Hanlon's memo?
That contains a memorandum to Mr. O'Hanlon, 3
10         A     It looks like   --
handwritten memorandum to Mr. O'Hanlon from Mr.
it's not clear.
T.
11         Q     Some time in 1977 in any event?
L.
12               MR. MacDONALD:     The document says what
4 Book, does it not, with a covering memo from Mr. O'Hanlon llk 5
to Mr.
G.
R.
Miller, Mr. Tsaggaris, Mr. Goodman, 6
yourself, and Mr. Kunder, is that correct?
7 A
Yes.
8 Q
can you tell us, looking at the first 9
page, what the date is of Mr. O'Hanlon's memo?
10 A
It looks like it's not clear.
11 Q
Some time in 1977 in any event?
12 MR. MacDONALD:
The document says what
(~m
(~m
(_)         13         it says. Y,,ou can read as well as he can.
(_)
14               Ask the person who wrote it.
13 it says.
15               MR. FISKE:   I think I can talk to the
Y,,ou can read as well as he can.
;                16         person who received it as well.
14 Ask the person who wrote it.
17         Q     You did get a copy of this, didn't you, 18   Mr. Zechman?
15 MR. FISKE:
l l               19         A     I recall getting a copy of this.
I think I can talk to the 16 person who received it as well.
20         Q     Some time in or about J un e o f 19777 1
17 Q
21         A     That's what the letter says.       I don't 22   recollect, myself, whether it was that period of time.
You did get a copy of this, didn't you, 18 Mr. Zechman?
23         Q     Well, this certainly came to your
l l
        ~
19 A
(L.J')     24   attention some time in 1977, did it not?
I recall getting a copy of this.
25               MR. MacDONALD:     He told you what he I
20 Q
Some time in or about J un e o f 19777 1
21 A
That's what the letter says.
I don't 22 recollect, myself, whether it was that period of time.
23 Q
Well, this certainly came to your
~( ')
24 attention some time in 1977, did it not?
L.J 25 MR. MacDONALD:
He told you what he I


1 Zechman                   209 p,   -
1 Zechman 209
k 2         recalls.
-p, k
3               MR. FISKE:   I am seeing if we can include 4         the entire year 1977 in his recollection.
2 recalls.
h   5         A     I recall receiving this document.
3 MR. FISKE:
6   I don't recall specifically when I got it.
I am seeing if we can include 4
7           Q     In 1977 did you know an individual by the 8   name of T. L. Book?
the entire year 1977 in his recollection.
  ,              9         A     Yes, I did.
h 5
10           Q     What was his position in June of 19777 11           A     I don't recall what his specific position 12   was at that time, mainly because I think he had a r~N k/       13   promotion somewhere in that tine frame.
A I recall receiving this document.
14           Q     What was Mr. O'Hanlon's position at that 15   time in June of '777 16           A     I have no recollection what his specific i
6 I don't recall specifically when I got it.
l             17 title was at that time.
7 Q
18 Q     I would like to direct your attention 19   to the third paragraph of the memo to Mr. O'Hanlon 20   which reads, "Like all else, the S/F and S/G's have 21   become the Godhead of 60 hours required training per 22   year."
In 1977 did you know an individual by the 8
23                 Do you understand what S/F and S/G 's e
name of T.
24  l
L.
[mx ,)       -
Book?
l referred to?
9 A
25                 MR. MacDONALD:   You want to know what he l
Yes, I did.
10 Q
What was his position in June of 19777 11 A
I don't recall what his specific position 12 was at that time, mainly because I think he had a r~N
<k/
13 promotion somewhere in that tine frame.
14 Q
What was Mr. O'Hanlon's position at that 15 time in June of '777 16 A
I have no recollection what his specific i
l 17 title was at that time.
18 Q
I would like to direct your attention 19 to the third paragraph of the memo to Mr. O'Hanlon 20 which reads, "Like all else, the S/F and S/G's have 21 become the Godhead of 60 hours required training per 22 year."
23 Do you understand what S/F and S/G 's l
[mx,)
e 24 referred to?
l 25 MR. MacDONALD:
You want to know what he l
l
l


1 Zechman                     210 2           unders tood when he received the memo?
1 Zechman 210 2
3                 MR. FISKE:   Yes.
unders tood when he received the memo?
4           Q     When you received the memo, did you O 5   understand what an S/F and S/G     was?
3 MR. FISKE:
6           A     I unders tood S/F. I don't know what is 7   S/G.
Yes.
8                 Maybe it is an S/S.
4 Q
Q 9                 Did   you understand this to refer to 10   shift foremen and shift supervisors?
When you received the memo, did you O
11 A     Yes, I did.
5 understand what an S/F and S/G was?
12 Let me correct this. I understand the t
6 A
w        13 S/F was shift foreman.
I unders tood S/F.
14                 I don't know what the second thing is.
I don't know what is 7
15                 If   you are implying -- I don't recall 16   what that was.
S/G.
17 Q     Did you understand it when you received 0
8 Q
Maybe it is an S/S.
9 Did you understand this to refer to 10 shift foremen and shift supervisors?
11 A
Yes, I did.
12 Let me correct this.
I understand the t
13 S/F was shift foreman.
w 14 I don't know what the second thing is.
15 If you are implying -- I don't recall 16 what that was.
17 Q
Did you understand it when you received 0
the memo?
the memo?
19                 MR. MacDONALD:     That is what he is 20           testifying to.
19 MR. MacDONALD:
21                 Are you saying right now you don't know Q
That is what he is 20 testifying to.
22   one way or the other whether you understood what 3
21 Q
Are you saying right now you don't know 22 one way or the other whether you understood what 3
Mr. Book was talking about?
Mr. Book was talking about?
I n       24
I n
(     )                     MR. MacDONALD:     I don't think that was
(
)
24 MR. MacDONALD:
I don't think that was
: i. s '
: i. s '
25         the question. You asked specifically whether
25 the question.
You asked specifically whether


1                             Zechman                     211
1 Zechman 211
    ,r\
,r\\
()       2           he had a recollection of what those two marks 3           were when he received the memo.
()
4           Q     Is it your tes timony , Mr. Zechman, llI   5   that you didn't understand what Mr. Book me nt by a 6   S/S when you received this memo?
2 he had a recollection of what those two marks 3
7           A     I don't know that we clearly identified 8   that as S/S. It's not clear to me at this time 9   looking at that.
were when he received the memo.
10           Q     Is it   your testimony that you didn ' t 11     understand what Mr. Book meant by the initials which 12     appear at the end of that particular line at the time
4 Q
()     13     you received this memo?
Is it your tes timony, Mr. Zechman, llI 5
14           A     Are you asking what my assumption in 15     that period would have been?
that you didn't understand what Mr. Book me nt by a 6
16                 MR. MacDONALD: Not. Your assumption.
S/S when you received this memo?
17           What you recall at that time, what you knew l
7 A
18           about that particular mark.
I don't know that we clearly identified 8
1 19                 You don't want him to speculate on what 1
that as S/S.
20           he assumed he might have thought on that particular i
It's not clear to me at this time 9
21           mark.
looking at that.
l i           22           Q     Any vay you can.
10 Q
l 23                 If you can't, we will go on to the next l
Is it your testimony that you didn ' t 11 understand what Mr. Book meant by the initials which 12 appear at the end of that particular line at the time
l   q       24 l question.
()
O           j 25 '
13 you received this memo?
A      To the best of my recollection, I l
14 A
Are you asking what my assumption in 15 that period would have been?
16 MR. MacDONALD: Not.
Your assumption.
17 What you recall at that time, what you knew l
18 about that particular mark.
1 19 You don't want him to speculate on what 1
20 he assumed he might have thought on that particular i
l 21 mark.
i 22 Q
Any vay you can.
l 23 If you can't, we will go on to the next l
l q
24 l question.
O j
25 A
To the best of my recollection, I l
L
L


1 Zechman                     212
1 Zechman 212
(,)       2 understood what he meant.
, -(,)
3       Q     By that he meant shift supervisors, didn't 4 he?
2 understood what he meant.
5       A     To the best of my recollection.
3 Q
6             Let me read the whole paragraph and Q
By that he meant shift supervisors, didn't 4
7 then ask you whether I am correct in my understanding 8 of the sense of this paragraph, as you unders tood it 9 at the time you received it.
he?
10             "Like all else, the shift foremen and 11 shift supervisors have become the Godhead of 60 hours 12 required training per year. It's time to put training
5 A
(,.,)   I3 back in the training department where it belongs and.
To the best of my recollection.
14 in a responsible fashion. This means more training 15 space, people and expertise. This also means six 16 shifts for CROs, shift foremen and shift supervisors."
6 Q
17 Did you understand when you received this 18 memo that Mr. Book's basic complaint was that too 19 much of the 60 hours required training per year was 20 being done under the shift foremen and shift supervisors 21 who were operations people rather than in the training I           22 department?
Let me read the whole paragraph and 7
23 MR. Mac DONALD:   Are you asking basically 24 l
then ask you whether I am correct in my understanding 8
of the sense of this paragraph, as you unders tood it 9
at the time you received it.
10 "Like all else, the shift foremen and 11 shift supervisors have become the Godhead of 60 hours 12 required training per year.
It's time to put training
(,.,)
I3 back in the training department where it belongs and.
14 in a responsible fashion.
This means more training 15 space, people and expertise.
This also means six 16 shifts for CROs, shift foremen and shift supervisors."
17 Did you understand when you received this 18 memo that Mr. Book's basic complaint was that too 19 much of the 60 hours required training per year was 20 being done under the shift foremen and shift supervisors 21 who were operations people rather than in the training I
22 department?
23 MR. Mac DONALD:
Are you asking basically 24 l
(~x what he understood when he read that paragraph
(~x what he understood when he read that paragraph
\     'x-25       after receiving the memo?
\\
'x-25 after receiving the memo?
l
l


n   -
n
    'a }                                     l Zechman                     213
'a }
    ,~.
l Zechman 213
U 2                                     MR. FIS KE :   I am asking if he had t he s..
,~.
3     ,                      understanding that I just read.
U 2
MR. FIS KE :
I am asking if he had t he s..
3 understanding that I just read.
s
s
                                }4                                               MR. MacDONALD:     What he understood when
}4 MR. MacDONALD:
                        - \-               5                             he read the paragraph.
What he understood when
)                               1
- \\-
                                      '63                                      MR. FISKE:     Read the question back.
5 he read the paragraph.
                                          ,7 s                                   As I see-it, it is simple.
)
S 0}                                   MR. MacDONALD:       I think you are putting i       ,
1
                                .\
'6 MR. FISKE:
                      ~                s 9 ., '                         wordsin Mr. Book's mouth that Mr. Book may or
Read the question back.
                                            ')
3
10 (l                 e may not have intended by writing the paragraph.
,7 s As I see-it, it is simple.
4 11                                       The easy question 'is what he understood a       s 12                  ''
0}
                                                                    '' when he read the paragraph.
S MR. MacDONALD:
                                                                                                                                  ~
I think you are putting i
l_ .
.\\
                                                '                      {
s 9., '
Q '.                             lj3
wordsin Mr. Book's mouth that Mr. Book may or
                                                          -(
~
g                     MR. FISKE:     I will put the question the
10 (l
                          .5
')
                                  ' I4                                   way I want to.       I think I am entitled to ask
may not have intended by writing the paragraph.
                        's.t i l5 3
e 11 The easy question 'is what he understood 4
whether he drew the conclusion from this 4
a s
                                        >16 whole paragraph that I just expressed.
l_.
17                                       MR. MacDONALD:       I am going to object.
'' when he read the paragraph.
18                                       MR. FISKE:     Read the question again, please, i
12
If                                       (Rec,ord   read back.)
~
2(                              A      I pnderstocd'this     as one man's opinion 9
{
21            who was upset at                  khe time, expressing his own opinion.
Q '.
22                               Q       Yes, I understand.       But that he   was i:
-(
1h             expressing the opinion which I                     just aaked you about rm.                         .. . l
lj3 g
(   )                           '2p             -in the last question.
MR. FISKE:
U                                       MR. MacDONALD:     My objection still stands.
I will put the question the
.5
' I4 way I want to.
I think I am entitled to ask
's.t i l5 whether he drew the conclusion from this 3
4
>16 whole paragraph that I just expressed.
17 MR. MacDONALD:
I am going to object.
18 MR. FISKE:
Read the question again, please, i
If (Rec,ord read back.)
I pnderstocd'this 2(
A as one man's opinion khe time, expressing his own opinion.
21 who was upset at 9
22 Q
Yes, I understand.
But that he was i:
1h expressing the opinion which I just aaked you about rm.
... l
(
)
'2p
-in the last question.
U MR. MacDONALD:
My objection still stands.
1
1


l                                                                     s l
l l
1                             Zechnan               ,
s 1
214 fm (s,)     2           Q     He was expressing   the opinion that he 3  felt nore of the 60 hours per year required 4   training should be done in the training department.,
Zechnan 214 fm (s,)
lll 5   isn't that right?                             '
2 Q
6                 MR. MacDONALD:   I object.
He was expressing the opinion that he felt nore of the 60 hours per year required 3
7                 What your recollection     was at the time.
4 training should be done in the training department.,
8         A     My recollection is exactly wh at he wrote                     ,  ,
lll 5
t 9   here. I have no   idea what was in his mind at any 10   time, but whatever he said     here is what he said.                     '
isn't that right?
11         Q     Well, did you understand when he said it 12  l is time to put training back in the training department
6 MR. MacDONALD:
I object.
7 What your recollection was at the time.
8 A
My recollection is exactly wh at he wrote t
9 here.
I have no idea what was in his mind at any 10 time, but whatever he said here is what he said.
11 Q
Well, did you understand when he said it l
is 12 time to put training back in the training department
(~%
(~%
()       13   where it belongs and in a responsible fashion, that 14   he thought that the 60 hours required training should 15   be done by   the training department?
( )
16                 MR. MacDONALD:   Are you asking him to 1           17         interpret   what was in Mr. Book's mind when he 1
13 where it belongs and in a responsible fashion, that 14 he thought that the 60 hours required training should 15 be done by the training department?
1 l            18         wrote the memo?
16 MR. MacDONALD:
l 19                 MR. FISKE:   Conclusions he drew from this 20         memo when he received it, sure.
Are you asking him to 1
21                 MR. MacDONALD:   I object.
17 interpret what was in Mr. Book's mind when he 1
22                 THE WITNESS:   Read the question.
1 18 wrote the memo?
23                 (Record read back.)
l l
(~~T     24                 MR. MacDONALD:   I object.
19 MR. FISKE:
LJ' l           25                 If you recall anything about what was l
Conclusions he drew from this 20 memo when he received it, sure.
21 MR. MacDONALD:
I object.
22 THE WITNESS:
Read the question.
23 (Record read back.)
(~~T 24 MR. MacDONALD:
I object.
LJ' l
25 If you recall anything about what was l
l
l


s -
s -
h                                       .
h
: f. .
: f..
JA                         1                               2e chmars                   215
JA 1
            -                                      I
2e chmars 215 I
't
(~}^
(~}^
(/                   2         said --
't
      .,                          3                   MR. FIS KE : No.
(/
k,     (
2 said --
                            ,    4                  MR. MacDONALD:     You are asking him to lh!           5         ge't[into someone!s mind.
3 MR. FIS KE :
                    #j
No.
!        s      ,                6                  MR. FISKE:     No.
k, 4
  ,-      .s.,                               .
MR. MacDONALD:
g uy .
You are asking him to
  ,                              ,                  MR. MacDONALD:     You are using your
(
                                        ~
lh!
8        words to'say what Mr. Book thought and then
5 ge't[into someone!s mind.
                        ",      9        whether       or not Mr. Zechman recalls those thoughts.       If you want to ask Mr. Zechman what
#j 6
{Q ..
MR. FISKE:
i
No.
,-J           ,                  11         he recalls of his understanding when he read 12         that paragraph, go right ahead.
s
t, 4 13                   MR. FIS KE :   No. 1, Mr. MacDonald, you know,
.s.,
                      /
g uy.
14         I believe by now in a deposition like this I am 15         entitled to ask leading questions.
MR. MacDONALD:
16                   Mr. Zechman was favored by Mr. O'Hanlon 17         with a copy of this memo along with such 18         luminaries as Mr. Miller and Mr. Tsaggaris and 19         Mr. Goodman, and I assume, for the purpose of 20         my question, that he read this memo at the time 21         and tried to deal with it appropriately.
You are using your 8
9           22                   MR. MacDONALD:     You can assume whatever 23         you want.
~
24                   MR. FIS KE :   I am simply asking him 25         whether, when he read this paragraph, he believed
words to'say what Mr. Book thought and then 9
whether or not Mr. Zechman recalls those
{Q..
thoughts.
If you want to ask Mr. Zechman what i
,-J 11 he recalls of his understanding when he read 12 t,
that paragraph, go right ahead.
4 13 MR. FIS KE :
No.
1, Mr. MacDonald, you know,
/
14 I believe by now in a deposition like this I am 15 entitled to ask leading questions.
16 Mr. Zechman was favored by Mr. O'Hanlon 17 with a copy of this memo along with such 18 luminaries as Mr. Miller and Mr. Tsaggaris and 19 Mr. Goodman, and I assume, for the purpose of 20 my question, that he read this memo at the time 21 and tried to deal with it appropriately.
9 22 MR. MacDONALD:
You can assume whatever 23 you want.
24 MR. FIS KE :
I am simply asking him 25 whether, when he read this paragraph, he believed


1                           Zechman                       216
1 Zechman 216
    ,es
,es
(_,/       2         that Mr. Book's concern, among others, was not 3         en ugh of the 60 hours required training per 4         year was being done in the training department.
(_,/
lll. 5       A       I believe that he was very confused at 6 the time and upset and was not very rational in his 7 memo, 8       Q     And you reached that conclusion without 9 knowing what it was Mr. Book was trying to convey to 10 you?
2 that Mr. Book's concern, among others, was not 3
11         A     What Mr. Book conveyed to me is right what 12 is written here. No more, no less.
en ugh of the 60 hours required training per 4
( )s     13               MR. MacDONALD:     He told you that three 14         times, Mr. Fiske.
year was being done in the training department.
15         Q     Mr. Zechman,   we   had some questions 16 earlier about difficulties in the effectiveness of 1
lll.
i 17 the training when there was a six-shift as opposed l             18 to five-shift program.
5 A
l l             19               Do you remember that?
I believe that he was very confused at 6
20         A     Yes, I Co.
the time and upset and was not very rational in his 7
21         Q     Looking at this memo dated June 7,     1977, 22 in light of the last sentence on page       1, does that l
: memo, 8
l             23 refresh your recollection that by the time of this l
Q And you reached that conclusion without 9
f"~]     24 memo, that is, June 1977, the switch had been made V
knowing what it was Mr. Book was trying to convey to 10 you?
25 from six shifts to five?
11 A
What Mr. Book conveyed to me is right what 12 is written here.
No more, no less.
( )s 13 MR. MacDONALD:
He told you that three 14 times, Mr. Fiske.
15 Q
Mr. Zechman, we had some questions 16 earlier about difficulties in the effectiveness of 1
i 17 the training when there was a six-shift as opposed l
18 to five-shift program.
l l
19 Do you remember that?
20 A
Yes, I Co.
21 Q
Looking at this memo dated June 7,
: 1977, 22 in light of the last sentence on page 1,
does that l
l 23 refresh your recollection that by the time of this l
f"~]
24 memo, that is, June 1977, the switch had been made V
25 from six shifts to five?


1                           zechman                   217
1 zechman 217
((_,/\
(
2               THE WITNESS:   Read that question.
\\
3               (Record read back.)
(_,/
4         A     All this reflects in my mind is a statement lh   5 made by Ted Book. I still don't have a time frame 6 when that shift was made, in my mind.
2 THE WITNESS:
7       Q     Did you understand when you received this 8
Read that question.
memo that it was Mr. Book's view that in order to 9 put the required 60 hours required training per year 10 back in the training department, it would require six 11 shifts for the CRO's shift foremen and shift 12 supervisors?
3 (Record read back.)
r))       13 (v                  A     This is not sinking in. I would like 14 to take a break after this.
4 A
15               THE WITNESS:   Read it back, please.
All this reflects in my mind is a statement lh 5
made by Ted Book.
I still don't have a time frame 6
when that shift was made, in my mind.
7 Q
Did you understand when you received this 8
memo that it was Mr. Book's view that in order to 9
put the required 60 hours required training per year 10 back in the training department, it would require six 11 shifts for the CRO's shift foremen and shift 12 supervisors?
r)
(
)
13 A
This is not sinking in.
I would like v
14 to take a break after this.
15 THE WITNESS:
Read it back, please.
16 (Record read back.)
16 (Record read back.)
l             17         A     I had no idea what he had in mind or how 18 he related those two just by th       receipt of this memo.
l 17 A
19 Q     Did you ask him what he meant by it?
I had no idea what he had in mind or how 18 he related those two just by th receipt of this memo.
20         A     I have no recollection.
19 Q
21         Q     You have no recollection of trying to find 22 out what he meant?
Did you ask him what he meant by it?
23         A     I have no recollection either way.
20 A
(y       24         Q     Do you see the word written in handwriting
I have no recollection.
      \_. ]
21 Q
25 on the left-hand side of the page right next to l
You have no recollection of trying to find 22 out what he meant?
23 A
I have no recollection either way.
(y 24 Q
Do you see the word written in handwriting
\\_. ]
25 on the left-hand side of the page right next to l
l L
l L


1 Zechmen                                   218 2 the -- right at the very bottom of page 17 3       A     What is your page 17           Are you talking 4 about the cover sheet?
1 Zechmen 218 2
5       Q     The bottom of page 1 of Mr. Book's 6 memo ,says, "This means more training space, people and 7 expertise. This also means six shifts for CROs, 8                   In the left-hand margin is written a S/Fs and S/Ss."
the -- right at the very bottom of page 17 3
  .      9 word.
A What is your page 17 Are you talking 4
10             Do you see that word?
about the cover sheet?
11       A     I see a word.
5 Q
12             can you read it?
The bottom of page 1 of Mr. Book's 6
,                Q l
memo,says, "This means more training space, people and 7
l  *
expertise.
(  13       A     Not really.
This also means six shifts for CROs, 8
14             Doesn't it say "True"?
S/Fs and S/Ss."
Q 15             MR. MacDONALD:   He just said he can't read 16       it.
In the left-hand margin is written a 9
l
word.
!      17       A     I said it was not clear.
10 Do you see that word?
18             Do you   recognize the handwriting in that Q
11 A
19 marginal notation?
I see a word.
r 20       A     No, I don't.
12 Q
21       Q     It's not your handwriting?
can you read it?
22       A     It's not my handwriting.
l l
23             Is that Mr. O'Hanlon's writing?
*(
Q 24             I just indicated I don't know whose
13 A
(          A 25 writing that is.
Not really.
14 Q
Doesn't it say "True"?
15 MR. MacDONALD:
He just said he can't read 16 it.
l 17 A
I said it was not clear.
18 Q
Do you recognize the handwriting in that 19 marginal notation?
r 20 A
No, I don't.
21 Q
It's not your handwriting?
22 A
It's not my handwriting.
23 Q
Is that Mr. O'Hanlon's writing?
(
24 A
I just indicated I don't know whose 25 writing that is.


1                           Zechman                     219
1 Zechman 219
(~)x
(~)x
(_       2               THE WITNESS:   Can we take a break, 3       please?
(_
4             MR. FISKE:   Sure.
2 THE WITNESS:
lh 5               (Recess taken.)
Can we take a break, 3
6             MR. FISKE:   Could you read the last quastion 7       and answer.
please?
8               (Record read back.)
4 MR. FISKE:
Sure.
lh 5
(Recess taken.)
6 MR. FISKE:
Could you read the last quastion 7
and answer.
8 (Record read back.)
9 BY MR. FISKE:
9 BY MR. FISKE:
10       Q     Directing your attention to the next 11 page, Mr. Zechman, the second paragraph, let me 12 read it into the record so     we can ask you some
10 Q
  ,e m
Directing your attention to the next 11 page, Mr. Zechman, the second paragraph, let me 12 read it into the record so we can ask you some
(_)     13 questions on it.
,e m
14             It reads, "Besides being just plain 15 frustrated over all of this, it is my opinion that 16 it is somewhat erroneous to say we have fulfilled the 17 NRC requirements when they are based on documentation 18 of   subject matter supposedly covered on shift," and 19 it looks to me as though the " supposedly" may be 20 underlined.     "Many times more hours are documented 21 than were actually used for training."
(_)
22             Do you see that paragraph?
13 questions on it.
23       A     I see that paragraph.
14 It reads, "Besides being just plain 15 frustrated over all of this, it is my opinion that 16 it is somewhat erroneous to say we have fulfilled the 17 NRC requirements when they are based on documentation 18 of subject matter supposedly covered on shift," and 19 it looks to me as though the " supposedly" may be 20 underlined.
(~N,   24       Q     Was there a procedure at Met Ed during
"Many times more hours are documented 21 than were actually used for training."
  \al 25 this period of time and continuing on through the time
22 Do you see that paragraph?
23 A
I see that paragraph.
(~N, 24 Q
Was there a procedure at Met Ed during
\\al 25 this period of time and continuing on through the time


1                           Zechman                   220 Q
1 Zechman 220 Q
    \s/         that you were in charge of the training department 2
\\s/
3  to document the amount of time that was spent on 4
2 that you were in charge of the training department 3
to document the amount of time that was spent on 4
training?
training?
llh   5         A     There was an administrative document in t 6 which we recorded the hours of training and the 7 personnel in attendance.
llh 5
g-       Q     For this period, this program that y you described as requiring 60 hours of training per 10 year, was it necessary thatt at the end of the year, 11 the records reflect that each individual had, in 12 fact, had 60 hours?
A There was an administrative document in t
13               THE WITNESS:   Read that back.
6 which we recorded the hours of training and the 7
* 14               (Record read back.)
personnel in attendance.
15         A     It would reflect the amount of time of
g-Q For this period, this program that y
!            16 training they had during that year.
you described as requiring 60 hours of training per 10 year, was it necessary thatt at the end of the year, 11 the records reflect that each individual had, in 12 fact, had 60 hours?
17         Q     If the records didn't reflect 60 hours 18 for an individual, then the records would reflect a 19 deficiency. in the program for that individual?
13 THE WITNESS:
20         A     Yes, it would.
Read that back.
21         Q     Did that documentation requirement 22 apply to subj ect matter that was covered on shift?
14 (Record read back.)
23         A     I just drew a blank on the 60-hour 24 requirement inte rp retatio n.                               ,
15 A
25         Q     Did you understand that the Nuclear
It would reflect the amount of time of 16 training they had during that year.
17 Q
If the records didn't reflect 60 hours 18 for an individual, then the records would reflect a 19 deficiency. in the program for that individual?
20 A
Yes, it would.
21 Q
Did that documentation requirement 22 apply to subj ect matter that was covered on shift?
23 A
I just drew a blank on the 60-hour 24 requirement inte rp retatio n.
25 Q
Did you understand that the Nuclear


1 Zechman                     221 2 Regulatory Commission had regulatory authority over 3 the training that was being conducted at Met     Ed?
1 Zechman 221 2
4       A     Would you like to expand upon that, please.
Regulatory Commission had regulatory authority over 3
h 5       g     What is unclear about it?
the training that was being conducted at Met Ed?
6       A     Your interpretation of regulatory authority 7 over the training program.
4 A
8 Q     Did you understand that in order for Met
Would you like to expand upon that, please.
.          9 Ed to keep its operating license, it had to conduct 10 a training program t hat was satisfactory to the 11 Nuclear Regulatory Commission?
h 5
12 A     I understood that.
g What is unclear about it?
iD'\
6 A
(,/     13 Did you in de rs tand that part of what was Q
Your interpretation of regulatory authority 7
14 necessary to satisfy the Nuclear Regulatory Commission 15 was to conduct a requisite   number of hours of training?
over the training program.
16 A     I understood it, that it was our requirement II to meet the requirements of our requalification program.
8 Q
10 Q     Which includes a specified numbers of 19 hours of training, does it not?
Did you understand that in order for Met 9
20 A     Yes, it does.
Ed to keep its operating license, it had to conduct 10 a training program t hat was satisfactory to the 11 Nuclear Regulatory Commission?
21             Did you understand that the documentation Q
12 A
22 of the training that was given served to demonstrate, 23 if necessary, to the Nuclear Regulatory Commission (n)
I understood that.
L .:
D'\\
24 that the requisite   number of hours of training were, 25 in fact, being conducted?
i
(,/
13 Q
Did you in de rs tand that part of what was 14 necessary to satisfy the Nuclear Regulatory Commission 15 was to conduct a requisite number of hours of training?
16 A
I understood it, that it was our requirement II to meet the requirements of our requalification program.
10 Q
Which includes a specified numbers of 19 hours of training, does it not?
20 A
Yes, it does.
21 Q
Did you understand that the documentation 22 of the training that was given served to demonstrate, 23 if necessary, to the Nuclear Regulatory Commission (n) 24 that the requisite number of hours of training were, L.:
25 in fact, being conducted?


1                           Zechman                     222 2         A     I understood that.
1 Zechman 222 2
;            3         Q     Did you understand that it would be 4 wrong to create documents which showed the training llh   5 had been done when, in fact, the     training had not 6 heen done?
A I
7         'A     I understood that.
understood that.
8         Q     Directing your attention to the last
3 Q
  ,        9  sentence of the second paragraph of Mr. Book's 10 memorandum which reads , "Many times more hours were 11 documented than were actually used for training."
Did you understand that it would be 4
12               Do you see that?
wrong to create documents which showed the training llh 5
4 13         A     I see that.
had been done when, in fact, the training had not 6
14         Q     Did you understand when you received 15 this   memorandum that Mr. Book was stating that 16 documentation had been created which falsely 17 reflected.the amount     of training which had been done?
heen done?
l 10 l                             MR. MacDONALD:   I object to that.
7
19         A     I don't understand what was     in Mr. Book's 20 mind   at that time.
'A I understood that.
I 21         Q     Well, was it important   --  go ahead.
8 Q
l 22         A     When I read this document, including that 23
Directing your attention to the last 9
(               paragraph, it   was very obvious to me there was     a 24 very upset individual making a lot of rash statements 25 and not being very rational about what he was saying.
sentence of the second paragraph of Mr. Book's 10 memorandum which reads, "Many times more hours were 11 documented than were actually used for training."
12 Do you see that?
13 A
I see that.
4 14 Q
Did you understand when you received 15 this memorandum that Mr.
Book was stating that 16 documentation had been created which falsely 17 reflected.the amount of training which had been done?
l 10 l
MR. MacDONALD:
I object to that.
19 A
I don't understand what was in Mr. Book's 20 mind at that time.
I 21 Q
Well, was it important go ahead.
l 22 A
When I read this document, including that
(
23 paragraph, it was very obvious to me there was a
24 very upset individual making a lot of rash statements 25 and not being very rational about what he was saying.
l
l


l l
l 1
1                              Zechman                         223 I
Zechman 223 I
Y/       2           Q     Well, wh'en you read this sentence     in       )
)
i 3    which he said "Many times more hours were documented 4     than were actually used for training," did you llh 5     understand what he meant by that sentence?
Y/
6                   MR. MacDONALD:   He just told you what his 7           understanding was.
2 Q
8                   MR. FISKE:   No, he didn't.
Well, wh'en you read this sentence in i
9                 MR. MacDONALD: You can interpret it any 10           way you want.
which he said "Many times more hours were documented 3
11                   MR. FISKE:   I want an answer to that 12           question.
4 than were actually used for training," did you llh 5
understand what he meant by that sentence?
6 MR. MacDONALD:
He just told you what his 7
understanding was.
8 MR. FISKE:
No, he didn't.
9 MR. MacDONALD: You can interpret it any 10 way you want.
11 MR. FISKE:
I want an answer to that 12 question.
(~N
(~N
()       13                 MR. MacDONALD:     I think the witness   --
()
14                 MR. FISKE:   He can either say he un de rs to o d 15           it or not.
13 MR. MacDONALD:
16                 MR. MacDONALD:     He is going to give an 17           answer to the question if he hasn't already.
I think the witness 14 MR. FISKE:
A     I will repeat the same answer I gave you 18 l 19   a few minutes ago, sir.
He can either say he un de rs to o d 15 it or not.
20                 When reading this letter, it was obvious 21   that we had an upset individual who was not being G
16 MR. MacDONALD:
22   very rational about what he was saying.
He is going to give an 17 answer to the question if he hasn't already.
23           Q     You have just said that you felt he was r-     24   not being rational about what he was saying, correct?
18 l A
I will repeat the same answer I gave you 19 a few minutes ago, sir.
20 When reading this letter, it was obvious 21 that we had an upset individual who was not being G
22 very rational about what he was saying.
23 Q
You have just said that you felt he was r-24 not being rational about what he was saying, correct?
N.N]
N.N]
25   That is what you just said in your last answer?           Isn't
25 That is what you just said in your last answer?
Isn't


1       ,                            Zechman                                     224 O\   2         that right?
1 Zechman 224 O\\
3                     Do you want your last answer read back?
2 that right?
4               A     No.
3 Do you want your last answer read back?
I 5               Q     Your last answer just said you felt that 6         he was not being rational in what he was saying.
4 A
7               A     In many of the things he was saying, he 8         was not being rational.
No.
9               Q     So in order to draw the               conclusion that 10         he was not being rational, you would have to 11         understand what it was that he was saying, isn't that 12         correct?
I 5
13                     MR. MacDONALD:         Understand what he said 14               in the paper?
Q Your last answer just said you felt that 6
15               Q     "Many times more hours were documented 16         than were actually used for training."
he was not being rational in what he was saying.
17                     MR. MacDONALD:         He told you what his 18               understanding was.
7 A
19                     MR. FISKE:       Read the question back 20               if Mr. Zechman is having trouble with it.
In many of the things he was saying, he 8
21                     (Record read back.)
was not being rational.
22                     MR. MacDONALD:         I am going to object.
9 Q
23               Q     You may answer.
So in order to draw the conclusion that 10 he was not being rational, you would have to 11 understand what it was that he was saying, isn't that 12 correct?
24               A     He was saying things that were not u
13 MR. MacDONALD:
25         substantiated by fact.
Understand what he said 14 in the paper?
15 Q
"Many times more hours were documented 16 than were actually used for training."
17 MR. MacDONALD:
He told you what his 18 understanding was.
19 MR. FISKE:
Read the question back 20 if Mr. Zechman is having trouble with it.
21 (Record read back.)
22 MR. MacDONALD:
I am going to object.
23 Q
You may answer.
24 A
He was saying things that were not u
25 substantiated by fact.


1                           Zechman                 225 CN i     !      2         Q     Did you personally conduct an v
1 Zechman 225 CN i
3   investigation to determine whether more hours were 4   being documented than were actually used for llh 5   training?
2 Q
6         A     Sir, in this period of time, if this is 7   indeed the period of time with which this was 8   received, I was group supervisor, to the best of 9   my recollection, I was group supervisor of unlicensed 10   training. That would not have been in my charge.
Did you personally conduct an v
11         Q     So the answer to that is that you did 12   not conduct such an investigation?
3 investigation to determine whether more hours were 4
13         A     Not to the best of my recollection.
being documented than were actually used for llh 5
(~)J L                       ,
training?
14         Q     Did you ask Mr. Book what the basis was 15   for this statement in his letter?
6 A
16         A     Not to the best of my recollection.
Sir, in this period of time, if this is 7
17         Q     Did you find out from Mr. O'Hanlon, 18   Mr. Miller, Mr. Tsaggaris, Mr. Goodman, or Mr. Kunder 19   whether any of them had spoken to Mr. Book in order 20   to determine what the basis was for his allegation?
indeed the period of time with which this was 8
21               THE WITNESS:   Repeat that question.
received, I was group supervisor, to the best of 9
22               (Record read back.)
my recollection, I was group supervisor of unlicensed 10 training.
23         A     Not to the best of my recollection.
That would not have been in my charge.
I
11 Q
      -      24         Q     Do you know as a fact whether Mr. O'Hanlon,
So the answer to that is that you did 12 not conduct such an investigation?
    \a 25   Mr. Miller, Mr. Tsaggaris, Mr. Goodman, or Mr. Kunder
(~)J 13 A
Not to the best of my recollection.
L 14 Q
Did you ask Mr. Book what the basis was 15 for this statement in his letter?
16 A
Not to the best of my recollection.
17 Q
Did you find out from Mr. O'Hanlon, 18 Mr. Miller, Mr. Tsaggaris, Mr. Goodman, or Mr. Kunder 19 whether any of them had spoken to Mr. Book in order 20 to determine what the basis was for his allegation?
21 THE WITNESS:
Repeat that question.
22 (Record read back.)
23 A
Not to the best of my recollection.
I 24 Q
Do you know as a fact whether Mr. O'Hanlon,
\\a 25 Mr. Miller, Mr. Tsaggaris, Mr. Goodman, or Mr. Kunder


l 1
1 Zechman 226 O
Zechman                       226 O             2   conducted an investigation to determine whether more 3   hours were being documented than were actually used 4   for training?
2 conducted an investigation to determine whether more 3
5                 MR. MacDONALD:       What do you mean?
hours were being documented than were actually used 4
6         A full-scale investigation?
for training?
7                 MR. FISKE:     I will let the question stand.
5 MR. MacDONALD:
O Mr. MacDONALD:       Fine. I object.
What do you mean?
  .                9         A     I have no recollection what they did with 10   that information.
6 A full-scale investigation?
11 Q     As you sit here today, Mr. Zechman, you 12 were not aware of any effort that was made to 13 determine factually whether the statement made by 14   Mr. Book that "Many times more hours were documented 15 than were actually used for training" was, in fact, 16   true?
7 MR. FISKE:
17 MR. MacDONALD:       He just told you the answer 18           to the question.       He didn't recall.
I will let the question stand.
19           A     I said I don't recall.
O Mr. MacDONALD:
20                 Then I take it you have no basis as you Q
Fine.
21   sit here for saying this was an irrational statement?
I object.
22           A     You asked me for my opinion when I read 23 i this.
9 A
i 24 MR. MacDONALD:       He gave it to you.
I have no recollection what they did with 10 that information.
I 25 l       A     I said he gave no specifics in his         document.
11 Q
As you sit here today, Mr. Zechman, you 12 were not aware of any effort that was made to 13 determine factually whether the statement made by 14 Mr. Book that "Many times more hours were documented 15 than were actually used for training" was, in fact, 16 true?
17 MR. MacDONALD:
He just told you the answer 18 to the question.
He didn't recall.
19 A
I said I don't recall.
20 Q
Then I take it you have no basis as you 21 sit here for saying this was an irrational statement?
22 A
You asked me for my opinion when I read 23 i this.
i 24 MR. MacDONALD:
He gave it to you.
I 25 l
A I said he gave no specifics in his document.
I
I


1                                     Zechman                                 227 O-       .2   He made an accusation of some sort, no specifics.
1 Zechman 227 O-
3         Q         You did nothing to follow it up and you 4   don't know of anything anybody else did, is that h     5   correct?
.2 He made an accusation of some sort, no specifics.
6                     MR. MacDONALD:       I object.       That is not 7         what he said.
3 Q
8         A         That is not what I said.         I said at 9   that period of time, my recollection, if it is 10   correct, I was a group supervisor in charge of 11   unlicensed training.           That would not have been in 12   my charge at that time.
You did nothing to follow it up and you 4
      )     13         Q         You don't know as you sit here today 14   of anything anybody else did?
don't know of anything anybody else did, is that h
15         A         I already answered that.
5 correct?
16         Q         You said, by the way, Mr. Book was promoted j             17   at or about the time he wrote this memo, is that 18   correct?
6 MR. MacDONALD:
19         A         I said I was uncertain about that.
I object.
20         Q         Does Met Ed promote irrational people?
That is not 7
21                     MR. MacDONALD:       Objection.               There is no 22         basis for that question.
what he said.
23                     MR. F IS KE :     He can answer it?
8 A
    ~
That is not what I said.
24                   MR. MacDONALD:         I will instruct him 25         not to answer.           He is not necessarily involved
I said at 9
that period of time, my recollection, if it is 10 correct, I was a group supervisor in charge of 11 unlicensed training.
That would not have been in 12 my charge at that time.
)
13 Q
You don't know as you sit here today 14 of anything anybody else did?
15 A
I already answered that.
16 Q
You said, by the way, Mr. Book was promoted j
17 at or about the time he wrote this memo, is that 18 correct?
19 A
I said I was uncertain about that.
20 Q
Does Met Ed promote irrational people?
21 MR. MacDONALD:
Objection.
There is no 22 basis for that question.
23 MR. F IS KE :
He can answer it?
24 MR. MacDONALD:
I will instruct him
~
25 not to answer.
He is not necessarily involved


1                           Zechman                     228 k>         2         in whether Book is involved in a promotion, 3         whether he should or shouldn't have gotten 4         a promotion.
1 Zechman 228 k>
llh 5               If you want to ask about his recollection 6         about people that worked for him who were 7       promoted, that is fine.
2 in whether Book is involved in a promotion, 3
8       Q     Are you familiar with the criteria for
whether he should or shouldn't have gotten 4
  ,            9  promotion at Met Ed?
a promotion.
10               MR. MacDONALD:   People within his own 11       department who he may have been involved with?
llh 5
12               MR. FISKE:   Yes, within the training (O
If you want to ask about his recollection 6
    'x_/'     13       department.
about people that worked for him who were 7
14       A     with which I was involved, I certainly 15 have an understanding.
promoted, that is fine.
16       Q     Did you understand there were different 17 criteria as far as rationality was concerned in 18 other parts of tha training department other than 19 the part you were in?
8 Q
20       A     Sir, I would have no part in evaluating 21 the rationality or determining the rationality of an 22 individual.
Are you familiar with the criteria for 9
I l             23               MR. FISKE:   Let me mark as the next 24       exhibit, B&W   Exhibit   565, a memorandum j   sj
promotion at Met Ed?
!            25       dated September 17, 1979 from Mr.     Zechman to 1
10 MR. MacDONALD:
People within his own 11 department who he may have been involved with?
12 MR. FISKE:
Yes, within the training (O
'x_/'
13 department.
14 A
with which I was involved, I certainly 15 have an understanding.
16 Q
Did you understand there were different 17 criteria as far as rationality was concerned in 18 other parts of tha training department other than 19 the part you were in?
20 A
Sir, I would have no part in evaluating 21 the rationality or determining the rationality of an 22 individual.
I l
23 MR. FISKE:
Let me mark as the next 24 exhibit, B&W Exhibit 565, a memorandum j
sj 25 dated September 17, 1979 from Mr.
Zechman to 1


1 Zechman                     229 2
1 Zechman 229 2
Mr. L. L. Lawyer.
Mr.
L.
L.
Lawyer.
3
3
(, Memorandum dated September 17, 1979 4
(, Memorandum dated September 17, 1979 4
from Mr. Zechman to Mr. L. L. Lawyer, marked h   5 B&W Exhibit No. 565 for identification as 0
from Mr. Zechman to Mr.
L.
L.
Lawyer, marked h
5 B&W Exhibit No. 565 for identification as 0
of this date.)
of this date.)
7 Q     I will show it to you and give you an 8
7 Q
I will show it to you and give you an 8
opportunity to read it.
opportunity to read it.
  -    9 Maybe I can save a little time by 10 stating to you that you are obviously welcome to 11 read the entire memorandum, but the only questions 12 I am going to ask you about it are on page       1.
9 Maybe I can save a little time by 10 stating to you that you are obviously welcome to 11 read the entire memorandum, but the only questions 12 I am going to ask you about it are on page 1.
13 MR. MacDONALD:     I think it would be 14 helpful that you not necessarily read every 15 word but that you familiarize yourself with 16 the document.
13 MR. MacDONALD:
i 17 Q     If my suggestion means that you read 18 page 1 a little more carefully, that is perfectly 0
I think it would be 14 helpful that you not necessarily read every 15 word but that you familiarize yourself with 16 the document.
i 17 Q
If my suggestion means that you read 18 page 1 a little more carefully, that is perfectly 0
all right, too.
all right, too.
I l
I l
20 Have you had a chance to read it all now?
20 Have you had a chance to read it all now?
g           A     Yes. I have not read the detail of the 22                                             '
g A
last full pages.
Yes.
20 Q     This is a memorandum that you wrote to 24 Mr. Lawyer in September of 1979?
I have not read the detail of the 22 last full pages.
25 A     It is.
20 Q
This is a memorandum that you wrote to 24 Mr. Lawyer in September of 1979?
25 A
It is.


1 zechman                       230 i
1 zechman 230 i
  /       2         Q     I would like to direct your attention to 3 the second paragraph,.the second sentence, which 4 reads, "It nas always been my contention that the llh 5 only way to have an effective training program"     --
/
sorry.
2 Q
6               "It has always been my contention that 7 the only way an effective training program can be 8
I would like to direct your attention to 3
carried out is to have the sufficient staff and the 9 necessary time to prepare the material."
the second paragraph,.the second sentence, which 4
10               Do you see that?
reads, "It nas always been my contention that the llh 5
11         A     I see that.
only way to have an effective training program" sorry.
12         Q     That is a sentence that you wrote ,
6 "It has always been my contention that 7
()     13 is that correct?
the only way an effective training program can be 8
14         A     I wrote in reference to the time period 15 in which this letter was written.
carried out is to have the sufficient staff and the 9
16         Q     And the word " effective" is underlined.
necessary time to prepare the material."
17               Did you underline it?
10 Do you see that?
18         A     I did.
11 A
19         Q     It was your   view in September 1979, was 20 it not, that the only way an effective training 21 program could be carried out is to have the sufficient 22 staff and the necessary time to prepare the material?
I see that.
23         A     It was my view, putting this letter into 24 perspective at this point in time, that there 25 were a lot of programs going on at this time, new
12 Q
That is a sentence that you wrote,
()
13 is that correct?
14 A
I wrote in reference to the time period 15 in which this letter was written.
16 Q
And the word " effective" is underlined.
17 Did you underline it?
18 A
I did.
19 Q
It was your view in September 1979, was 20 it not, that the only way an effective training 21 program could be carried out is to have the sufficient 22 staff and the necessary time to prepare the material?
23 A
It was my view, putting this letter into 24 perspective at this point in time, that there 25 were a lot of programs going on at this time, new


i l
i l
1                                                                     zechman
1 zechman 231 2
,                                                                                                                        231 2     ones, fo r example , like radiation protection personnel 3     training for the people.who were coming in.
ones, fo r example, like radiation protection personnel 3
4                                                           Since a number of these programs was llh         5     increasing, I was making it clear that additional 6     staff would be needed to do this.
training for the people.who were coming in.
I 7 l                                 Q                     I am really not at the moment going to 8     ask a lot of questions about the details of the 9     September 1979 training program.
4 Since a number of these programs was llh 5
10                                                         I am simply interested in the concept 11     that you expressed in this sentence that the only way 12     an effective training program can be carried out
increasing, I was making it clear that additional 6
()                 13     is to have the sufficient staff and the necessary 4
staff would be needed to do this.
14     time to prepare the material.
I 7
15                                                         Do you understand that is what I am 16     asking about?
l Q
17                                                         MR. MacDONALD:   He told you his 18                                   understanding.
I am really not at the moment going to 8
19                                   Q                     It is fair to say, isn't it, Mr. Zechman, e
ask a lot of questions about the details of the 9
j                       20     that before the accident, as well as after the 21   accident, you felt that you could not have an 22   effective training program unless you had sufficient 23   staff?
September 1979 training program.
g-                24                                                         THE WITNESS:   Repeat that.
10 I am simply interested in the concept 11 that you expressed in this sentence that the only way 12 an effective training program can be carried out
25                                                         (Record read back.1
()
13 is to have the sufficient staff and the necessary 14 time to prepare the material.
4 15 Do you understand that is what I am 16 asking about?
17 MR. MacDONALD:
He told you his 18 understanding.
19 Q
It is fair to say, isn't it, Mr. Zechman, e
j 20 that before the accident, as well as after the 21 accident, you felt that you could not have an 22 effective training program unless you had sufficient 23 staff?
24 THE WITNESS:
Repeat that.
g-25 (Record read back.1


1 zechman                     232 (l
1 zechman 232 (l
    \
\\'v' 2
    'v'         2               MR. MacDONALD:   Effective in the way he 3         used it in the memo and just explained it 4           as to the new program?
MR. MacDONALD:
h   5               MR. FISKE:   Come cin, Mr. MacDonald.
Effective in the way he 3
6           A     His point is well taken, sir.
used it in the memo and just explained it 4
7                 This letter was written at a point in 8   time when the staff -- when the programs were expanding 9   and so was the staff.
as to the new program?
10           Q     Mr. Zechman, did it suddenly occur to you 11   for the first time after the accident that you 12   couldn't run a good training program unless you had n
h 5
k._,,)     13 enough people to do it right?     I simply am askin~g 14 about the basic concept, not about the particular program 15   or the particular numbers. Just the basic concept 16   that in order to run a good program, you have to have l
MR. FISKE:
17   enough people.
Come cin, Mr. MacDonald.
l 18 Is that an idea that first occurred to 19   you after the accident?
6 A
20         A     No. I always felt that way and felt that g 21   we did have that.
His point is well taken, sir.
22                 We will get to that in a minute.
7 This letter was written at a point in 8
l      Q 23                 But this sentence indeed says, doesn't it, 24
time when the staff -- when the programs were expanding 9
(^\
and so was the staff.
10 Q
Mr. Zechman, did it suddenly occur to you 11 for the first time after the accident that you 12 couldn't run a good training program unless you had n
k._,,)
13 enough people to do it right?
I simply am askin~g 14 about the basic concept, not about the particular program 15 or the particular numbers.
Just the basic concept 16 that in order to run a good program, you have to have l
17 enough people.
l 18 Is that an idea that first occurred to 19 you after the accident?
20 A
No.
I always felt that way and felt that 21 we did have that.
g 22 l
Q We will get to that in a minute.
23 But this sentence indeed says, doesn't it, 24 "It always has been my contention that the only way
(^\\;
(,/
(,/
            ;        "It always has been my contention that the only way 25   an effective training program can be carried out is
25 an effective training program can be carried out is


1 Zechman                   233 C)         2
1 Zechman 233 C)
( /           to have the sufficient staff and the necessary time 3   to prepare the material"?     Is that corrects that is 4   what the sentence says, is it not?
( /
h   5               MR. MacDONALD:   The document says what 6         it says. We don't need the witness to confirm 7           the written words.
2 to have the sufficient staff and the necessary time 3
8 A     What I wrote is what I wrote.
to prepare the material"?
9         Q     Have I read it incorrectly?
Is that corrects that is 4
10           A     You have not read it incorrectly.
what the sentence says, is it not?
11 Q     Isn't it a fact, Mr. Zechman, that in the 12 memorandum that Mr. Book wrote to Mr. O'Hanlon in
h 5
[\,/ }   13 1977 he expressed the view that in order to get 14 the 60 hours required training per year back into 15 the training department, it would require more training 16 people, among other   things?
MR. MacDONALD:
II I refer you to Exhibit 564, the bottom 18 of page 1.
The document says what 6
19 MR. MacDONALD:   What is the question.
it says.
20 ,              (Record read back.)
We don't need the witness to confirm 7
21                 MR. MacDONALD:   Are you asking -- I think 22 he told you what his understanding was at the 23 time he read   the document. You are not 24           asking for him to confirm as he sits here now
the written words.
  -\ -
8 A
25 what is written on a page here?   I don't think
What I wrote is what I wrote.
9 Q
Have I read it incorrectly?
10 A
You have not read it incorrectly.
11 Q
Isn't it a fact, Mr. Zechman, that in the 12 memorandum that Mr. Book wrote to Mr. O'Hanlon in
[
}
13 1977 he expressed the view that in order to get
\\,/
14 the 60 hours required training per year back into 15 the training department, it would require more training 16 people, among other things?
II I refer you to Exhibit 564, the bottom 18 of page 1.
19 MR. MacDONALD:
What is the question.
20 (Record read back.)
21 MR. MacDONALD:
Are you asking -- I think 22 he told you what his understanding was at the 23 time he read the document.
You are not 24 asking for him to confirm as he sits here now
-\\ -
25 what is written on a page here?
I don't think


1                           Zechman                   234
1 Zechman 234
(   /
(
  \/         2       it says that.
/
3       Q     You understand that Mr. Book was telling 4 you that he felt there should be     more training lll 5 people in the training department?
\\/
6       A     What is said in the letter is what is 7 said in the letter.
2 it says that.
8       Q     I am asking you what you understood it 9 to mean at that time.
3 Q
10       A     What it says in the letter.
You understand that Mr. Book was telling 4
11       Q     What is that?
you that he felt there should be more training lll 5
12       A     His opinion.
people in the training department?
  /
6 A
13             That you needed more training people in
What is said in the letter is what is 7
  !s_)              Q 14 the training department, isn't that correct?
said in the letter.
15       A     Whatever he said.
8 Q
16             I am asking you, Mr. Zechman, for your Q
I am asking you what you understood it 9
17 understanding of it.
to mean at that time.
10             MR. MacDONALD:   What he recalls his 19       understanding was at the time.
10 A
20             MR. FISKE:   Right.
What it says in the letter.
21       A     I understood that   is what he was saying.
11 Q
22       Q     Directing your attention to the document 23 that is B&W Exhibit 561, a handwritten document which 24 is in front of you, do     you see that?
What is that?
(~3
12 A
    \_/
His opinion.
25       A     Yes.
/
!s_)
13 Q
That you needed more training people in 14 the training department, isn't that correct?
15 A
Whatever he said.
16 Q
I am asking you, Mr. Zechman, for your 17 understanding of it.
10 MR. MacDONALD:
What he recalls his 19 understanding was at the time.
20 MR. FISKE:
Right.
21 A
I understood that is what he was saying.
22 Q
Directing your attention to the document 23 that is B&W Exhibit 561, a handwritten document which
(~3 24 is in front of you, do you see that?
\\_/
25 A
Yes.


1                           Zechman                     235 2       Q       It reads at the top, "TMI-2 Investigative 3 Task   Force Interview, TMI, 10/18/79."
1 Zechman 235 2
4               On the left, "0930, Training, Dick Johnson, llI         5 Marsh Beers, Frank McCormick."
Q It reads at the top, "TMI-2 Investigative 3
6               On the right, " Bob Keaten, Ed Wallace, 7 Bob Long, Rob Williams."
Task Force Interview, TMI, 10/18/79."
8               Do you see the first sentence in the 9 memorandum of that interview, Mr. Zechman?
4 On the left, "0930, Training, Dick Johnson, llI 5
10       A     Ending " Training department staff"?
Marsh Beers, Frank McCormick."
11       Q     Yes.
6 On the right, " Bob Keaten, Ed Wallace, 7
12       A     I see that first sentence.
Bob Long, Rob Williams."
13
8 Do you see the first sentence in the 9
(                        Q      could you read that into the record, 14 please?
memorandum of that interview, Mr. Zechman?
l 15       A       The first sentence reads, " Greatest l
10 A
16 burden seen by the training department"     --
Ending " Training department staff"?
I don't l
11 Q
l                 17 know what that is.
Yes.
18               "MGRS."
12 A
Q 19       A       I don't know.
I see that first sentence.
(
13 Q
could you read that into the record, 14 please?
l l
15 A
The first sentence reads, " Greatest 16 burden seen by the training department" I don't l
l 17 know what that is.
18 Q
"MGRS."
19 A
I don't know.
l l
l l
20               --
20 "has been the limit on the size of 21 the training department" -- and it looks like the 22 word --
                                        "has been the limit on the size of 21 the training department" -- and it looks like the 22 word --   " staff."
" staff."
23 Q       Isn't ita fact that at that interview I           -
23 Q
24 with Mr. Keaten and Mr. Wallace and the other people l
Isn't ita fact that at that interview I
l j                 25 on the task force, you or Mr. Beers or Mr. McCormick
l 24 with Mr. Keaten and Mr. Wallace and the other people l
j 25 on the task force, you or Mr. Beers or Mr. McCormick
(
(
T       v---           w -,e
T v---
v-
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w-m---------Fr wu---e


1 Zechman                     236 O( >         2 made a statement that you have just read into the 3 record?
1 Zechman 236 O( >
4         A     It is true that we discussed the size lll     5 of the staff and requesting additional staff, but 6 it was put into a particular     context, as I recall, 7 that is not expressed here.
2 made a statement that you have just read into the 3
8 Q     You mean you have a specific recollection
record?
            -  9 of putting that statement in the context that was-10 not written down by the people on the task force?
4 A
11               MR. MacDONALD:   I object. He didn't say 12 that he recollected a statement. He said they
It is true that we discussed the size lll 5
(         13         discussed the subject matter. Not that anybody 14         stated that that was so.
of the staff and requesting additional staff, but 6
15         A     In the recollection of what I expressed 16 at that time, it was put in a framework that isn't 17 expressed by somebody's notes here.
it was put into a particular context, as I recall, 7
18 Q     Is it y_our testimony, Mr. Zechman, that 19 at no time up to the Three Mile Island accident, 20 did you ever hold a view that you would like to have l             21 had more people in the training department?
that is not expressed here.
O     22               THE WITNESS:   Read that back, please.
8 Q
23 l                               (Record read back.)
You mean you have a specific recollection 9
l 24 l
of putting that statement in the context that was-10 not written down by the people on the task force?
11 MR. MacDONALD:
I object.
He didn't say 12 that he recollected a statement.
He said they
(
13 discussed the subject matter.
Not that anybody 14 stated that that was so.
15 A
In the recollection of what I expressed 16 at that time, it was put in a framework that isn't 17 expressed by somebody's notes here.
18 Q
Is it y_our testimony, Mr. Zechman, that 19 at no time up to the Three Mile Island accident, 20 did you ever hold a view that you would like to have l
21 had more people in the training department?
O 22 THE WITNESS:
Read that back, please.
23 l
(Record read back.)
l
[]
[]
    '\ J MR. MacDONALD:   I object. I don't think 25 that is what he testified.
24 MR. MacDONALD:
I object.
I don't think l
'\\ J 25 that is what he testified.
l
l


1 Zechman                       237
1 Zechman 237
(^%/
(^%
i 2                 MR. FISKE:   I am asking him.
i
3         A     I have expressed that view in the past.
/
4                 I said my view was that our training lh   5   department has worked very hard.       We had to work 6   overtime hours at times.     It would have been helpful 7   to have additional persons so that we did not have 8
2 MR. FISKE:
I am asking him.
3 A
I have expressed that view in the past.
4 I said my view was that our training lh 5
department has worked very hard.
We had to work 6
overtime hours at times.
It would have been helpful 7
to have additional persons so that we did not have 8
to work additional hours and as hard as we did.
to work additional hours and as hard as we did.
  ,            9         Q     Didn't you or Mr. Beers or Mr. McCormick 10 state to Mr. Keaten and the others in October of 11 1979 that if you had been given more people prior 12   to March 28,   '79, you would have expanded the scope f^)
9 Q
(_       13   of almost all training programs?
Didn't you or Mr. Beers or Mr. McCormick 10 state to Mr. Keaten and the others in October of 11 1979 that if you had been given more people prior 12 to March 28,
14                 MR. MacDONALD:     Are you reading from some l
'79, you would have expanded the scope f^)
15         particular line on the page?
(_
j           16                 MR. FISKE:   Sure.
13 of almost all training programs?
17                 MR. MacDONALD:     Point the witness to it.
14 MR. MacDONALD:
18 MR. FISKE:   Sure. Page --
Are you reading from some l
if that helps 19         him.
15 particular line on the page?
20                 MR. MacDONALD:     I don ' t know if it helps 21         him.
j 16 MR. FISKE:
22                 MR. FISKE:   Page 2. Notes of the Keaten 23 interview.   "If the training staff had been l
Sure.
f~}
17 MR. MacDONALD:
Point the witness to it.
18 MR. FISKE:
Sure.
Page if that helps 19 him.
20 MR. MacDONALD:
I don ' t know if it helps 21 him.
22 MR. FISKE:
Page 2.
Notes of the Keaten 23 interview.
"If the training staff had been f~}
24 given more people (prior to March 28), they l
v.-
v.-
24 t
t f
given more people (prior to March 28), they 25 f      would have expanded the scope of almost all i               I
25 would have expanded the scope of almost all i
I


l 1
1 Zechman 238 rN k_-)
Zechman                     238 rN 2
2 training programs."
k_-)                   training programs."
3 Q
3         Q     Isn't it a fact that a statement to that 4
Isn't it a fact that a statement to that 4
effect was made by you, Mr. Beers and Mr. McCormick?
effect was made by you, Mr. Beers and Mr. McCormick?
lg   5       A     I can only speak for myself. I don't 6 recall making that statement.
lg 5
7 Q     The notes further say, "This specifically 0
A I can only speak for myself.
I don't 6
recall making that statement.
7 Q
The notes further say, "This specifically 0
was directed towards increased and improved 0
was directed towards increased and improved 0
classroom training for the various training programs. "
classroom training for the various training programs. "
10 Is it your testimony that you didn't 11 make that statement?
10 Is it your testimony that you didn't 11 make that statement?
12 A     I don't recognize that statement or
12 A
    /~'x
I don't recognize that statement or
    #          1
/~'x 1
(     )         recollect that statement or having made that statement.
(
14 Q     Is it your testimony that neither Mr. McCormick nor Mr. Beers made that statement?
)
IO A     Sir, I have no idea what statements or 17 recollect what statements Mr. Beers or Mr. McCormick 18 made.
recollect that statement or having made that statement.
l 19 Q     You don't recall one way   or the other, 20   is that it?
14 Q
21 A       I don't recall what they said, period.
Is it your testimony that neither Mr. McCormick nor Mr. Beers made that statement?
22 Q     You were there the whole time they vere 23 there, isn't that correct?
IO A
Sir, I have no idea what statements or 17 recollect what statements Mr. Beers or Mr. McCormick 18 made.
l 19 Q
You don't recall one way or the other, 20 is that it?
21 A
I don't recall what they said, period.
22 Q
You were there the whole time they vere 23 there, isn't that correct?
04
04
              ~
~
,    ,e-'S,               A       I recall being called out of the room or N~)
,e-'S, A
25 going out of the room to make a phone call.     I know I
I recall being called out of the room or N~)
25 going out of the room to make a phone call.
I know I


1 Zechman                   239
1 Zechman 239
  / )
/
  '% )       2   there was some period of time I was not in that room.
)
3         g     now long were you out of the room?
'% )
4 A     I have no recollection.
2 there was some period of time I was not in that room.
h   5.
3 g
Q     Was ':this a telephone call that you lef t 6
now long were you out of the room?
the room to place or was it a call that had come 7 in to you?
4 A
O A     I don't recollect what it was.
I have no recollection.
9
h 5.
,                            I recall leaving the room and going to 10 the telephone, but I don't recollect the reason or 11 whether it was incoming or outgoing.
Q Was ':this a telephone call that you lef t 6
12 Q     Who was the telephone conversation with?
the room to place or was it a call that had come 7
  /m.
in to you?
(.,)     13 A
O A
                                          ~
I don't recollect what it was.
I don't recall.
9 I recall leaving the room and going to 10 the telephone, but I don't recollect the reason or 11 whether it was incoming or outgoing.
14 Q     How long was this interview?
12 Q
15 A     I have no recollection of the length of 16 the   interview any more.
Who was the telephone conversation with?
17 Q     How   long were you out?
/m.
0 A     I have no recollection of that time 19
(.,)
        .        period either.
13
20 Q     The next sentence in this memorandum 21   of   the interview with.you, Mr. Zechman, Mr. Heers, 22 Mr. McCormick, is, "This content has been eroding 23 down through the years."
~
24 Do you see that?
A I don't recall.
14 Q
How long was this interview?
15 A
I have no recollection of the length of 16 the interview any more.
17 Q
How long were you out?
0 A
I have no recollection of that time 19 period either.
20 Q
The next sentence in this memorandum 21 of the interview with.you, Mr. Zechman, Mr. Heers, 22 Mr. McCormick, is, "This content has been eroding 23 down through the years."
24
{]
{]
  's 25 A     No, sir.
Do you see that?
's 25 A
No, sir.


1                               Zechman                                 240 2               Where are you at?
1 Zechman 240 2
3           Q     Immediately following the sentence that 4   says, "This specifically was directed toward lll   5   increased and improved classroom training for the 6   various training programs."
Where are you at?
7                 The next sentence is, "This content 8   has been eroding down through the years."
3 Q
9                 Did you make that statement to Mr. Keaten 10   and the others?
Immediately following the sentence that 4
11           A     Sir, I don't recognize the content                 --
says, "This specifically was directed toward lll 5
I 12   don't recognize or can put into context that
increased and improved classroom training for the 6
()       13   sentence from any conversations that I had there.
various training programs."
14           g     Does that mean you don't remember whether 15   or not you made that statement?
7 The next sentence is, "This content 8
16           A     I don't recall making that statement.
has been eroding down through the years."
l 17           Q     Did Mr. Beers or Mr. McCormick make that 18   statement while you were there?
9 Did you make that statement to Mr. Keaten 10 and the others?
l 19           A     Sir, I answered a while ago.                   I don't l           20   recall what statements either Mr. McCormick or El   Mr. Beers made at that meeting.
11 A
S   22           g     You mean as you sit here now, you can't l
Sir, I don't recognize the content I
l           23 i remember a single thing either one of them said at i
12 don't recognize or can put into context that
I 24   the meeting even with this memorandum in front of you?
()
l   ~s!
13 sentence from any conversations that I had there.
l           25         A     Sir, I'm trying very hard to recall that i
14 g
Does that mean you don't remember whether 15 or not you made that statement?
16 A
I don't recall making that statement.
l 17 Q
Did Mr. Beers or Mr. McCormick make that 18 statement while you were there?
l 19 A
Sir, I answered a while ago.
I don't l
20 recall what statements either Mr. McCormick or El Mr. Beers made at that meeting.
S 22 g
You mean as you sit here now, you can't l
l 23 remember a single thing either one of them said at i
i I
24 the meeting even with this memorandum in front of you?
l
~s!
l 25 A
Sir, I'm trying very hard to recall that i
l
l


1 Zechman                                           241
1 Zechman 241 s
                                                                                                                                          ~
2
s                            2 moment when they were speaking. I just can't recall 3 what they -- what specifically came out from them.
~
moment when they were speaking. I just can't recall 3
what they -- what specifically came out from them.
4 I just can't.
4 I just can't.
I         *5           Q                     Directing your attention to the sentence, 6 the one         further down in the memorandum, "Much of what I
I
was stripped out of the program                                                     (especially 8 auxiliary OP) was the amount of"                                                   --
*5 Q
a couple of things' 9 crossed out                 --
Directing your attention to the sentence, 6
                                                                                  " classroom or personal training (in 10 favor of OJT) and the virtual elimination of formal 11 classroom training in the basics (heat transfer,
the one further down in the memorandum, "Much of what I
.                                      12                                                                                               "
was stripped out of the program (especially 8
reactivity, math, shielding, et cetera)."
auxiliary OP) was the amount of" a couple of things' 9
l       )                     13 Did             you make that statenent to Mr. Keaten 14
crossed out
..                                        and the others at that meeting?
" classroom or personal training (in 10 favor of OJT) and the virtual elimination of formal 11 classroom training in the basics (heat transfer, 12 reactivity, math, shielding, et cetera)."
15       A                     I don't recall making a statement 16 specifically as it is written.                                                   I do recall discussing 17 past and present auxiliary operator training programs j                                       18 and changes that took place relative to them.
l
19                           But do you remember saying to Mr. Keaten Q
)
20 and the others in words or substance that much of what 21 was stripped out of the classroom training -- withdrawn.
13 Did you make that statenent to Mr. Keaten 14 and the others at that meeting?
22                           Do you remember saying to Mr. Keaten in 23 words or substance that much of what was stripped out 24 of the training program was the amount of classroom 25 or personal training, in favor of on-the-job training?
15 A
I don't recall making a statement 16 specifically as it is written.
I do recall discussing 17 past and present auxiliary operator training programs j
18 and changes that took place relative to them.
19 Q
But do you remember saying to Mr. Keaten 20 and the others in words or substance that much of what 21 was stripped out of the classroom training -- withdrawn.
22 Do you remember saying to Mr. Keaten in 23 words or substance that much of what was stripped out 24 of the training program was the amount of classroom 25 or personal training, in favor of on-the-job training?


1                                         Zochman                             242
1 Zochman 242
()         2               MR. MacDONALD:                   He just answered the 3         question a minute ago.
()
4       A     I answered the question to the best I know 5 how. I told you I didn't recognize the framework ll 6 with which -- the way it is stated here, as not my 7   recollection of how I expressed myself at that time.
2 MR. MacDONALD:
8         Q     Did you say to Mr. Keaten in words or 9 substance that prior to the accident, there had been 10 a virtual elimination of formal classroom training 11 in the basics, heat transfer, reactivity, math, 12 shielding?
He just answered the 3
13               MR. MacDONALD:                     Objection. He just 14         told you what his answer was three times now.
question a minute ago.
15         Q     You may answer.
4 A
16         A     I       believe I just answered that question, i             17 sir.
I answered the question to the best I know ll 5
18         Q     Well, if you did, I have not heard the 19 answer.
how.
20         A     I said I don't recall making the statement 21 as is written here.
I told you I didn't recognize the framework 6
9     22         Q     Did Mr. Beers or Mr. McCormick make a 23 statement to that effect?
with which -- the way it is stated here, as not my 7
24         A     I told you I don't recall specifically O) t''       25 what Mr. Marshall Beers or McCormick said at that 1
recollection of how I expressed myself at that time.
                                  -. , - - - . . - - - - - , , .,        --      - - ' ' - ' =   ~ ~ - - ' ' ' ''
8 Q
Did you say to Mr. Keaten in words or 9
substance that prior to the accident, there had been 10 a virtual elimination of formal classroom training 11 in the basics, heat transfer, reactivity, math, 12 shielding?
13 MR. MacDONALD:
Objection.
He just 14 told you what his answer was three times now.
15 Q
You may answer.
16 A
I believe I just answered that question, i
17 sir.
18 Q
Well, if you did, I have not heard the 19 answer.
20 A
I said I don't recall making the statement 21 as is written here.
9 22 Q
Did Mr. Beers or Mr. McCormick make a 23 statement to that effect?
24 A
I told you I don't recall specifically O) t''
25 what Mr. Marshall Beers or McCormick said at that 1
- - ' ' - ' =
~ ~ - - ' ' '


1 Zechman                   243 2 meeting.
1 Zechman 243 2
3         Q       Do you know any reason why the person who 4
meeting.
wrote these notes would have written down at this gg)   5 interview someone had stated that there was,a virtual 6 elimination of formal classroom training in the basics 7 unless it had been said by either you, Mr. Beers, or 8 Mr. McCormick?
3 Q
9               MR. MacDONALD:   Objection. You are 10 asking for his present-sense interpretation 11 of why somebody wrote things on a page that 12 he doesn't even recall seeing, and I instruct 13                                                           "
Do you know any reason why the person who 4
him not to answer.                     '
wrote these notes would have written down at this gg) 5 interview someone had stated that there was,a virtual 6
elimination of formal classroom training in the basics 7
unless it had been said by either you, Mr. Beers, or 8
Mr. McCormick?
9 MR. MacDONALD:
Objection.
You are 10 asking for his present-sense interpretation 11 of why somebody wrote things on a page that 12 he doesn't even recall seeing, and I instruct 13 him not to answer.
14 You are asking him to speculate.
14 You are asking him to speculate.
15 MR. FIS KE : Does he know a reason as 16 to why the person who took the notes of this 17 interview would write down that it had been 18 i
15 MR. FIS KE :
stated that there had been a virtual elimination 19         of formal classroom training in the basics 20 unless Mr. Zechman or Mr. Beers or Mr. McCormick l
Does he know a reason as 16 to why the person who took the notes of this 17 interview would write down that it had been 18 stated that there had been a virtual elimination i
i           21         had said it.
19 of formal classroom training in the basics 20 unless Mr. Zechman or Mr. Beers or Mr. McCormick l
22                 If it is "No," he can say "No."
i 21 had said it.
23 MR. MacDONALD:   It is a present-sense i
22 If it is "No," he can say "No."
24         impression.
23 MR. MacDONALD:
s' 25 A       For all I know, he could have written it L
It is a present-sense i
24 impression.
s' 25 A
For all I know, he could have written it L


1                                                                       Zechman                                     244 O     2       some time after the meeting.                                           It would be pure 3       speculation on my pa'rt.                                           I don't know.
1 Zechman 244 O
4                                                         MR. MacDONALD:   Is this a good time h   5                                 to break for lunch?
2 some time after the meeting.
6                                                         MR. FISKE:   Sure.
It would be pure 3
4 7                                                           (Wh er eupon , at 12:45 o' clock p.m., a 8                                 lunch recess was taken.)
speculation on my pa'rt.
9 10 11 12 13 14 15 3
I don't know.
16 f             17 l
4 MR. MacDONALD:
18                                                                                                                                         l 19 20 i
Is this a good time h
21 22 23 O   '
5 to break for lunch?
25
6 MR. FISKE:
Sure.
4 7
(Wh er eupon, at 12:45 o' clock p.m.,
a 8
lunch recess was taken.)
9 10 11 12 13 14 15 16 3
f 17 l
18 l
19 20 i
21 22 23
' O 25


1                                                           245
1 245 t(,)
(,)
2 AFTERNOON SESSION 3
t 2                           AFTERNOON SESSION 3                               (2 : 3 0 p.m. )
(2 : 3 0 p.m. )
4   R I CHARD           W.       ZECHMAN,           resumed.
4 R I CHARD W.
lll 5                 MR. FISKE:     Could we have the last question 6         and answer.
: ZECHMAN, resumed.
7                 (Record read back.}
lll 5
8                 MR. FIS KE :   I would like to mark as the 9         next exhibit a memorandum to Mr. Zechman dated 10         September 13, 1979 from Mr. McCormick and 11         Mr. Beers.
MR. FISKE:
12                 (Memorandum to     Mr. Zechman dated f;
Could we have the last question 6
x_/
and answer.
13         September 13, 1979 from Mr. McCormick and 14         Mr. Beers marked B&W Exhibit No. 566 for 15         identification as of this date.)
7 (Record read back.}
16   EXAMINATION (Continued) 17   BY MR. FISKE:
8 MR. FIS KE :
18         Q     Are you reading that memorandum, 19   Mr. Zechman?
I would like to mark as the 9
20         A     Yes, I am.     I have not read it entirely.
next exhibit a memorandum to Mr. Zechman dated 10 September 13, 1979 from Mr. McCormick and 11 Mr. Beers.
21         Q     Did you receive       that memorandum from 22   Mr. McCormick and Mr. Beers on or about September 13, 23   19797 24         A     Yes, I did.
12 (Memorandum to Mr. Zechman dated f;
V           '
13 September 13, 1979 from Mr. McCormick and x_/
25         Q     Had you received that memorandum by the
14 Mr. Beers marked B&W Exhibit No. 566 for 15 identification as of this date.)
16 EXAMINATION (Continued) 17 BY MR. FISKE:
18 Q
Are you reading that memorandum, 19 Mr. Zechman?
20 A
Yes, I am.
I have not read it entirely.
21 Q
Did you receive that memorandum from 22 Mr. McCormick and Mr. Beers on or about September 13, 23 19797 24 A
Yes, I did.
V 25 Q
Had you received that memorandum by the


1 Zechman                 246-247
1 Zechman 246-247
      'N
'N
        )       2       time you wrote the memorandum to Mr. Lawyer dated 3       September 17, 1979 which was marked as the previous 4       B&W exhibit?
)
gg)   5             A     Yes,   I did.
2 time you wrote the memorandum to Mr. Lawyer dated 3
6             Q     Referring to again your memorandum of 7     September 17, 1979 which is B&W Exhibit 565, referring 8     again to the first page of that document, do you have 9     that in front of you?     --
September 17, 1979 which was marked as the previous 4
10             A     Yes.
B&W exhibit?
11             Q     --
gg) 5 A
: Yes, I did.
6 Q
Referring to again your memorandum of 7
September 17, 1979 which is B&W Exhibit 565, referring 8
again to the first page of that document, do you have 9
that in front of you?
10 A
Yes.
11 Q
directing your attention to the 12 third paragraph and the sentence that says, "You
directing your attention to the 12 third paragraph and the sentence that says, "You
(~')
(~')
v 13       will   recall in Frank Kelly's audit report of 14       our training efforts in the pas t, his statement:
13 will recall in Frank Kelly's audit report of v
15     'It is our opinion that the subject training 16     organization, like the majority of similar
14 our training efforts in the pas t, his statement:
;              17       organizations at other nuclear power plants, is 18       understaffed and overworked.       Some evidence of l
15
I             19       carelessness     appeared during the review and this j             20       is often the sign of overworked conditions.'"
'It is our opinion that the subject training 16 organization, like the majority of similar 17 organizations at other nuclear power plants, is 18 understaffed and overworked.
Some evidence of l
I 19 carelessness appeared during the review and this j
20 is often the sign of overworked conditions.'"
l l
l l
21                     Do you remember writing that sentence?
21 Do you remember writing that sentence?
22             A     Yes, I do.
22 A
l 23             Q     Did you underline " understaffed and I
Yes, I do.
24   l overworked"?
l 23 Q
O s
Did you underline " understaffed and I
I 25             A     I underlined that.
24 l overworked"?
O I
s'''
25 A
I underlined that.
I
I


1                             Zachman                       248 2         Q     The reference to Frank Kelly's audit 3 report,   is that to the PSQ?
1 Zachman 248 2
4         A     PQS.
Q The reference to Frank Kelly's audit 3
lll   5         Q     The report that you identified earlier 6 in your testimony?
: report, is that to the PSQ?
7         A     Yes.
4 A
8         Q     And that was a review as   your memorandum 9 indicates   of your training efforts in th'e past, 10 was it not?
PQS.
11         A       To the best of my recollection.
lll 5
12                 MR. FIS KE : Let me mark as the next
Q The report that you identified earlier 6
    /     13         exhibit, B&W 567, a document entitled "A 14         Pedagogical Review of Operator Training"       --
in your testimony?
15         withdrawn.
7 A
16                 It was marked as B&W 234.
Yes.
17                 Start again.
8 Q
And that was a review as your memorandum 9
indicates of your training efforts in th'e past, 10 was it not?
11 A
To the best of my recollection.
12 MR. FIS KE :
Let me mark as the next
/
13 exhibit, B&W 567, a document entitled "A
14 Pedagogical Review of Operator Training" 15 withdrawn.
16 It was marked as B&W 234.
17 Start again.
t l
t l
18         Q       I will show you a document which has i
18 Q
19 been marked as B&W Exhibit 234 entitled     "A Pedagogical.
I will show you a document which has i
20 Review of Nuclear Operator Training at Three Mile 21 Island Nuclear Plant."
19 been marked as B&W Exhibit 234 entitled "A Pedagogical.
O   22                 Do you have that in front of you?
20 Review of Nuclear Operator Training at Three Mile 21 Island Nuclear Plant."
23         A     Yes.
O 22 Do you have that in front of you?
l         24         Q     Do you recognize this as the final O     25 report of the college of Engineering from Pennsylvania
23 A
Yes.
l 24 Q
Do you recognize this as the final O
25 report of the college of Engineering from Pennsylvania


~
~
1                                                               Zachman                           249 2   State that you referred to earlier?
1 Zachman 249 2
3         A                         I recognize this as the document --
State that you referred to earlier?
4   pedagogical review of Penn State's -- pedagogical g   5   review of operator training at Three Mile Island.
3 A
6 I have no recollection at this time if 7   this   is the final draft or a final copy of it.
I recognize this as the document --
O Q                         But in any event, you recall that Met Ed 9   did receive this report from the College of 10   Engineering at Penn State?
4 pedagogical review of Penn State's -- pedagogical g
11           A                         I recall they received a report of that 12   title.
5 review of operator training at Three Mile Island.
13 Q                         And I,believe yesterday you answered 14   some questions about the circumstances generally 15   under which that report was prepared.
6 I have no recollection at this time if 7
16           A I
this is the final draft or a final copy of it.
O Q
But in any event, you recall that Met Ed 9
did receive this report from the College of 10 Engineering at Penn State?
11 A
I recall they received a report of that 12 title.
13 Q
And I,believe yesterday you answered 14 some questions about the circumstances generally 15 under which that report was prepared.
16 A
We discussed some things about it.
We discussed some things about it.
17 Q                         In other words, we are not talking, 18 when we talk about Exhibit 234, about some report 19   that hasn't previously been identified in this 20   deposition?
I 17 Q
21                                   MR. MacDONALD:                   Are you asking whether 9 22 or not this report is the same cne he was asked 23           with reference to yesterday?
In other words, we are not talking, 18 when we talk about Exhibit 234, about some report 19 that hasn't previously been identified in this 20 deposition?
24                                   MR. FISKE:                 Yes.
21 MR. MacDONALD:
O. 25           A                       If that is your question, the answer is
Are you asking whether 9
22 or not this report is the same cne he was asked 23 with reference to yesterday?
24 MR. FISKE:
Yes.
O.
25 A
If that is your question, the answer is


1                                   zochman                               250
1 zochman 250
    /'N
/'N 2
    !              2    yes.
yes.
3           Q     Did you receive a draft of this report at 4   some point before it b e came final?
3 Q
ll)       5                 MR. MacDONALD:         I object.           I don't know 6
Did you receive a draft of this report at 4
whether Mr. zechman established that as a final 7           report or whether or not it is a draft of a 8           final report.
some point before it b e came final?
9                 Your question assumes it is.
ll) 5 MR. MacDONALD:
10           Q     So there is no question about it, 11     did you receive a draft of the report by the 12     College of Engineering at Penn State before it became
I object.
    ,          13     final?
I don't know 6
(
whether Mr. zechman established that as a final 7
14           A     To the best of my recollection, we did.
report or whether or not it is a draft of a 8
15 MR. FISKE:         Let me mark as the next 16           exhibit, which is B&W 567, a memorandum from 17           Sandy Lawyer dated January 24, 1980 to J.
final report.
10           Thorpe,       subject:     "Penn State Committee - Initial 19           Draft Report," with an attachment dated January 20           22, 1980.
9 Your question assumes it is.
21                   (Memorandum from Sandy           Lawyer dated 22           January 24, 1980'to           J. Thorpe, subject:
10 Q
23           "Penn State Committee - Initial Draft Report,"
So there is no question about it, 11 did you receive a draft of the report by the 12 College of Engineering at Penn State before it became 13 final?
24           with   attachment dated January 22, 1980, marked 25 l
,(
B&W Exhibit No. 567 for identification as of l
14 A
l
To the best of my recollection, we did.
15 MR. FISKE:
Let me mark as the next 16 exhibit, which is B&W 567, a memorandum from 17 Sandy Lawyer dated January 24, 1980 to J.
10
: Thorpe, subject:
"Penn State Committee - Initial 19 Draft Report," with an attachment dated January 20 22, 1980.
21 (Memorandum from Sandy Lawyer dated 22 January 24, 1980'to J.
Thorpe, subject:
23 "Penn State Committee - Initial Draft Report,"
24 with attachment dated January 22, 1980, marked 25 B&W Exhibit No. 567 for identification as of l
l l


1 Zechman                     251 2
1 Zechman 251 2
this date.)
this date.)
3                       Q       Do you       recognize that?
3 Q
4                       A       I recognize a review document similar lg)     5                 to this.
Do you recognize that?
6 Whether this is the one I reviewed at
4 A
    .              7                  that time, I have no recollection.
I recognize a review document similar lg) 5 to this.
O Q       Looking at Mr.       Lawyer's cover memorandum, 9                 that is directed to Mr. J. Tho rp e , is it not?
6 Whether this is the one I reviewed at 7
10 A       Yes, it is.
that time, I have no recollection.
11 Q       Who is Mr. Thrope?
O Q
12 MR. MacDONALD:       At what time?
Looking at Mr.
13
Lawyer's cover memorandum, 9
(}                                               MR. FIS KE : At that time.
that is directed to Mr.
14                       A       I'm sorry, I don't recollect his title at 15                 this moment.
J.
16 Q       He was with GPU nuclear?
Tho rp e, is it not?
i 17 A       To the bes t       of my recollection.
10 A
I0 Q       You will see the list of         carbon copies at the bottom.
Yes, it is.
20                       A       Yes.
11 Q
21 Q       Mr. Keaten we have talked about before.
Who is Mr. Thrope?
9       22 What was Mr. Broughton's position at 23 that time?
12 MR. MacDONALD:
24                       A       To the best of my recollection, he worked a
At what time?
O              25                 in tech functions, and I believe he worked for
(}
13 MR.
FIS KE :
At that time.
14 A
I'm sorry, I don't recollect his title at 15 this moment.
16 Q
He was with GPU nuclear?
i 17 A
To the bes t of my recollection.
I0 Q
You will see the list of carbon copies at the bottom.
20 A
Yes.
21 Q
Mr. Keaten we have talked about before.
9 22 What was Mr. Broughton's position at 23 that time?
24 A
To the best of my recollection, he worked O
a 25 in tech functions, and I believe he worked for


1 Zschman                     252
1 Zschman 252
()                                                 2                       Mr. Keaten.
()
3                               Q     Who was D. E. Hetrick?
2 Mr. Keaten.
4                                     What was his position at that time?
3 Q
ggg.                                           5                             A     I don't recall his title.
Who was D.
6                                     Mr. R. W. Zechman, what was your position Q
E.
7                      at that time?
Hetrick?
8                             A     Supervisor of training.
4 What was his position at that time?
9                             Q     A. M. Dowbert?
ggg.
10                               A     Anne Dowbert. I believe she was 11                         administrative     assistant. I forget what her title 12 was.
5 A
13                                       Who was O. Smith?
I don't recall his title.
Q 14                                 A     NUS contractor working in our department i
6 Q
15                         at the time.
Mr.
16                                       Who   was G. A. Sullivan?
R.
Q i                                                   17 A     Also a consultant working in our 18                       department at that time.       I forget what company he 19 was from.
W.
20 Q     Do you see the last paragraph of that 21 memorandum from Mr. Lawyer saying, "Please provide 9                                         22 me with comments on the attached document.       By copy 23 of this memo, I am also requesting similar comments 24                         from the cc recipients"?
Zechman, what was your position 7
O                                           25 You were a ce recipient of the attachment
at that time?
8 A
Supervisor of training.
9 Q
A.
M.
Dowbert?
10 A
Anne Dowbert.
I believe she was 11 administrative assistant.
I forget what her title 12 was.
13 Q
Who was O.
Smith?
14 A
NUS contractor working in our department i
15 at the time.
16 Q
Who was G.
A.
Sullivan?
i 17 A
Also a consultant working in our 18 department at that time.
I forget what company he 19 was from.
20 Q
Do you see the last paragraph of that 21 memorandum from Mr. Lawyer saying, "Please provide 9
22 me with comments on the attached document.
By copy 23 of this memo, I am also requesting similar comments 24 from the cc recipients"?
O 25 You were a ce recipient of the attachment


1                               Zochman                     253
1 Zochman 253
(         '2 to Mr. Lawyer's memorandum?
(
3         A       According   to the cover letter I was, yes.
'2 to Mr. Lawyer's memorandum?
4         Q       Did you understand from this memorandum, lll   5 Mr. Zechman, that you and others at         Met Ed were 4             6 being invited, in effect, by the people at Penn State 7 to make whatever comments you wanted to make on the 8 draft that they had prepared and that they would take 9 those comments into account in preparing their final 10 report?
3 A
11                   MR. MacDONALD:   I don't think you have 12 established whether or not he recalled receiving 13
According to the cover letter I was, yes.
;                        a memorandum from Mr. Lawyer.                         ,
4 Q
14                   MR. FIS KE : I think he said he did.
Did you understand from this memorandum, lll 5
15                   MR. MacDONALD:   Your question assumes it.
Mr. Zechman, that you and others at Met Ed were 4
16                   MR. FISKE:   Read the question again.
6 being invited, in effect, by the people at Penn State 7
to make whatever comments you wanted to make on the 8
draft that they had prepared and that they would take 9
those comments into account in preparing their final 10 report?
11 MR. MacDONALD:
I don't think you have 12 established whether or not he recalled receiving 13 a memorandum from Mr. Lawyer.
14 MR. FIS KE :
I think he said he did.
15 MR. MacDONALD:
Your question assumes it.
16 MR. FISKE:
Read the question again.
17 (Record read back.)
17 (Record read back.)
18                 MR. MacDONALD:     My objection stands.
18 MR. MacDONALD:
I 19         Q       You may answer.
My objection stands.
i           20         A         It was my understanding that comments 21   were invited.
I 19 Q
22                 What was to be done with those comments, 23   I don't know that I fully understand -- well, I i
You may answer.
i           24   understand we were asked for comments, but I don't l
i 20 A
[~'\
It was my understanding that comments 21 were invited.
    \/       25   recall what was going to be done with those comments, f
22 What was to be done with those comments, 23 I don't know that I fully understand -- well, I i
i 24 understand we were asked for comments, but I don't
[~'\\
l
\\/
25 recall what was going to be done with those comments, f


E 1
E 1
1 Zechman                                     254 2                                                                                     Did you Q                                                                          understand that the people at 3                       Penn State were going to listen to your comments,                                                                                                                         I 4
Zechman 254 2
consider your comments in determining what final lll                 5                       conclusions they were going to reach in the final 6                       report?
Q Did you understand that the people at 3
M I am not asking you to testify as to whether O
Penn State were going to listen to your comments, 4
you thought they were going to accept them                                                                                                                     all or 9                       reject them all; simply whether you understood as 10 part of the process they were giving you an opportunity 11 to comment and they would cons 5 der those comments
consider your comments in determining what final lll 5
!                                12 before they made their final report.
conclusions they were going to reach in the final 6
13 A                               It was my understanding at that time
report?
'                                I4 that we were asked to prepare comments and that 15 they would review those comments, and what they
M' I am not asking you to testify as to whether O
!                                16 would do with them was unknown to me.
you thought they were going to accept them all or 9
II Q                             I would like to direct your attention 10 to the material beginning on the bottom of page 5 19 of the attachment to                                                                                           Mr. Lawyer's memorandum where 20 it says, "In addition to the above, Penn State has 21 the following specific comments on the GPU training 9               22                       programs" 23
reject them all; simply whether you understood as 10 part of the process they were giving you an opportunity 11 to comment and they would cons 5 der those comments 12 before they made their final report.
!                                                                                                                        Do you see that sentence?
13 A
1 24 A                             Yes, I do.
It was my understanding at that time I4 that we were asked to prepare comments and that 15 they would review those comments, and what they 16 would do with them was unknown to me.
25 Q                             I would like to then direct your i
II Q
    , _ . _ _ _ _ . - . . ,  . _ _ . . , ~ , _ . _ . . - - . _ . - _ _ . _ . , _ _ . - _ . _ . _ _ _ . _ _ . . _ . _ _ - . _ . _ _ , - - - . . _ _ - . _ - - - _ - ~ . - _ . _ _ . . . . . _ _ _ _ _ - - _ . . . . - . _
I would like to direct your attention 10 to the material beginning on the bottom of page 5 19 of the attachment to Mr. Lawyer's memorandum where 20 it says, "In addition to the above, Penn State has 21 the following specific comments on the GPU training 9
22 programs" 23 Do you see that sentence?
1 24 A
Yes, I do.
25 Q
I would like to then direct your i
. _ _.., ~, _. _.. - -. _. - _ _. _., _ _. - _. _. _ _ _. _ _.. _. _ _ -. _. _ _, - - -.. _ _ -. _ - - - _ - ~. - _. _ _..... _ _ _ _ _ - - _.... -. _


1 Zechman                                                           255 (3
1 Zechman 255 (3
(_)                             2          attention to the next page, paragraph C.
2
3                               MR. MacDONALD:                       Mr. Zechman, read A and 4                 B first.
(_)
ggg                   5                 Q             Have you read that?
attention to the next page, paragraph C.
6                 A             Yes.
3 MR. MacDONALD:
7                 Q             The second sentence says, "For example, 8         most of the present CRO training programs (500"                                                                 --
Mr. Zechman, read A and 4
9                A             Where are you at?
B first.
10 Q             Paragraph C.
ggg 5
11 A             I'm sorry.                         I didn't read C yet.                                 My l~a apologies.
Q Have you read that?
()                           13 Now I'm ready.
6 A
14 Q             "For example, most of the present CRO 15 training programs (500 hours compared to the total 16           of 550           hours) involves self-study on the job."
Yes.
17                                 Do you see that?
7 Q
10                 A             I see that statement.
The second sentence says, "For example, 8
19 Q             Did you express any objection to Penn 20         state that that statement was inaccurate?
most of the present CRO training programs (500" 9
21                                 I will withdraw that question and see if G                     22           I can Instate it and move this along a little faster.
A Where are you at?
10 Q
Paragraph C.
11 A
I'm sorry.
I didn't read C yet.
My l~a apologies.
()
Now I'm ready.
13 14 Q
"For example, most of the present CRO 15 training programs (500 hours compared to the total 16 of 550 hours) involves self-study on the job."
17 Do you see that?
10 A
I see that statement.
19 Q
Did you express any objection to Penn 20 state that that statement was inaccurate?
21 I will withdraw that question and see if G
22 I can Instate it and move this along a little faster.
23 I will put the question again.
23 I will put the question again.
I 24 I will read the whole paragraph to you.
I 24 I will read the whole paragraph to you.
25           "A large portion of the                                 training is accomplished e
25 "A large portion of the training is accomplished e
        ,,-.-w- -.-.,---,-.-n,-.     , ---, ~     a   ,.m., - .     .,w,,n.--, n, . - - - ----n.,,w,,     -,,c , _ , - , . , - - - - , , , , ,--,
,,-.-w-
                                                                                                                                                    ,_.-_w_
-.-.,---,-.-n,-.
, ---, ~
a
,.m., -.
.,w,,n.--,
n,. - - -
----n.,,w,,
-,,c
,_.-_w_


l       1                             Zechman                       256
l 1
()       2   through the use of on-the-job training and self-study.
Zechman 256
3 For example, most of the present CRO training _500     (
,;()
4  hours compared to the total of 550 hours) involves lll 5 self-study on the job.       Such a technique is
2 through the use of on-the-job training and self-study.
: 6. s atis f actory for subjects such as piping layout, 7 p ro c edures , system design descriptions and system 8 schematics. It's completely inadequate for reactor 9 theory,   health physics, and other complex technical 10 subjects. Because of this, GPU should revise their 11 training program to include more in-depth classroom 12 instruction in these areas."
3 For example, most of the present CRO training
13                 I have just read you paragraph C on 14 page 6.
(_500 4
15                 Do you recall making a written comment 16 for the benefit of Penn State on that paragraph?
hours compared to the total of 550 hours) involves lll 5
17         A       I recall making comments to Penn State on i
self-study on the job.
18 this report.
Such a technique is 6.
i At this time I have no recollection i
s atis f actory for subjects such as piping layout, 7
19 what portions or what comments         I made at that time.
p ro c edures, system design descriptions and system 8
i             20                 MR. FISKE:     I will mark as the next f
schematics.
21         exhibit, which is     568,   a document entitled 22         " Comments - Penn State Review Committee 23         Report," dated February 6, 1980' to Doc Smith 24         from   Richard W. Zechman, supervisor of training .
It's completely inadequate for reactor 9
O       25                 (Doc umen t entitled " Comments -
: theory, health physics, and other complex technical 10 subjects.
Penn
Because of this, GPU should revise their 11 training program to include more in-depth classroom 12 instruction in these areas."
13 I have just read you paragraph C on 14 page 6.
15 Do you recall making a written comment 16 for the benefit of Penn State on that paragraph?
17 A
I recall making comments to Penn State on i
18 this report.
At this time I have no recollection i
i 19 what portions or what comments I made at that time.
i 20 MR. FISKE:
I will mark as the next f
21 exhibit, which is
: 568, a document entitled 22
" Comments - Penn State Review Committee 23 Report," dated February 6, 1980' to Doc Smith 24 from Richard W.
Zechman, supervisor of training.
O 25 (Doc umen t entitled " Comments Penn


1                           Zechman                         257 2       State Review Committee Report,"
1 Zechman 257 2
3       dated February 6, 1980, to Doc Smith from 4       Richard W. Zechman, supervisor of training, gg  5       marked B&W~ Exhibit No. 568 for identification 6       as of this date.)
State Review Committee Report,"
7       Q     Have you had a chance to look at this 8 three-page document, Mr. Zechman?
3 dated February 6, 1980, to Doc Smith from 4
9             MR. MacDONALD:     I don't think he is 10       finished.
Richard W.
11       Q     I don't think you really need to take 12 the time to compare this     --
Zechman, supervisor of training, 5
()     13       A     It' doesn ' t balance , sir.     That is why 14 I am looking.
marked B&W~ Exhibit No. 568 for identification gg 6
15               MR. MacDONALD:     Give him a few moments, 16       if you will.
as of this date.)
17               MR. FISKE:     I have a couple of specific 18       questions I want to ask.
7 Q
19               MR. MacDONALD:     He wants to take the 20       time to go through it.     Please give him that 21       opportunity.
Have you had a chance to look at this 8
9 22               MR. FISKE:   He can certainly take as 23       long as he wants, but I just have one or two 24       questions.
three-page document, Mr. Zechman?
O       25               MR. MacDONALD:     That is fine.
9 MR. MacDONALD:
I don't think he is 10 finished.
11 Q
I don't think you really need to take 12 the time to compare this
()
13 A
It' doesn ' t balance, sir.
That is why 14 I am looking.
15 MR. MacDONALD:
Give him a few moments, 16 if you will.
17 MR. FISKE:
I have a couple of specific 18 questions I want to ask.
19 MR. MacDONALD:
He wants to take the 20 time to go through it.
Please give him that 21 opportunity.
9 22 MR. FISKE:
He can certainly take as 23 long as he wants, but I just have one or two 24 questions.
O 25 MR. MacDONALD:
That is fine.
l
l


1 Zechman                   258
1 Zechman 258
    )     2         Q     You had had an opportunity to look at 3 B&W Exhibit 568, is that correct?
)
t 4               You have just had an opportunity to g   5 review that?
2 Q
6       A     I was reviewing -- well, yes. I scanned 7 this one and tried to match it against 567.
You had had an opportunity to look at 3
8       Q     Let's take Exhibit 568 and turning to 9 page 3,   at the bottom, is that your signature, 10
B&W Exhibit 568, is that correct?
            " Richard W. Zechman"?
t 4
11         A     That is my signature.
You have just had an opportunity to g
12         Q     And you were a supervisor of training i
5 review that?
i       13 on February 6, 1980?
6 A
14         A     That is correct.
I was reviewing -- well, yes.
15         Q     This memorandum is directed to Doc Smith, 16 is that correct?
I scanned 7
17       A       That is correct.
this one and tried to match it against 567.
18         Q     can you tell us who Doc Smith was 19 on February 6,   '80?
8 Q
20       A       He was a consultant from NUS who 21 worked directly with Sandy Lawyer.
Let's take Exhibit 568 and turning to 9
G 22       Q       Is he the same as the O. Smith that is 23 carbon copied on Mr. Lawyer's memo to Mr. Thorpe?
page 3, at the bottom, is that your signature, 10
24       A       That is correct.
" Richard W.
O   25       Q       I would like to direct your attention
Zechman"?
11 A
That is my signature.
12 Q
And you were a supervisor of training i
i 13 on February 6, 1980?
14 A
That is correct.
15 Q
This memorandum is directed to Doc Smith, 16 is that correct?
17 A
That is correct.
18 Q
can you tell us who Doc Smith was 19 on February 6,
'80?
20 A
He was a consultant from NUS who 21 worked directly with Sandy Lawyer.
G 22 Q
Is he the same as the O.
Smith that is 23 carbon copied on Mr. Lawyer's memo to Mr. Thorpe?
24 A
That is correct.
O 25 Q
I would like to direct your attention


1
1 Zechman 259 2
.,                                                                  Zechman                   259 2   to page 2 of Exhibit 568, item 7.
to page 2 of Exhibit 568, item 7.
3                 Do you see that?
3 Do you see that?
4         A         I see item 7.
4 A
ll)           5         Q         It reads, "PSU. Comment 'C' and 'D',
I see item 7.
6 page 6."
ll) 5 Q
7                   Do you see that?
It reads, "PSU.
8         A         I see that.
Comment
9         Q         Then under " Comments" there is one 10 word, is there not?
'C' and
11         A         There is one word.
'D',
12 Q       What is that one word?
6 page 6."
()                   13 A         " Agree."
7 Do you see that?
14 Q       Mr. Zechman, I would like you to look at
8 A
I see that.
9 Q
Then under " Comments" there is one 10 word, is there not?
11 A
There is one word.
12 Q
What is that one word?
()
13 A
" Agree."
14 Q
Mr. Zechman, I would like you to look at
)
)
:                                  15 the notes of Mr. Keaten which are marked Exhibit 35o.
15 the notes of Mr. Keaten which are marked Exhibit 35o.
16 I believe it's the microfilm which are the notes 17 of Mr. Keaten, of the interview October 1979 with you 18 and Mr. Beers and Mr. McCormick about which we have         .
16 I believe it's the microfilm which are the notes 17 of Mr. Keaten, of the interview October 1979 with you 18 and Mr. Beers and Mr. McCormick about which we have 19 had considerable discussion today.
19   had considerable discussion today.
20 I would like to direct your attention to 21 page 2.
20                   I would like to direct your attention to 21   page 2.     The statement at the bottom of page 2 of 22   Mr. Keaten's notes as I read it is, "Recently have 23 had verbal feedback (mid-7 8-7 91 from shift supervisors 24 that training in basics was lacking."
The statement at the bottom of page 2 of 22 Mr. Keaten's notes as I read it is, "Recently have 23 had verbal feedback (mid-7 8-7 91 from shift supervisors 24
(~)%
(~)%
            \.
that training in basics was lacking."
!                                25                   Do you see that?
\\.
    , - - -     --.w  e---w -- -
25 Do you see that?
--.w e---w w-ei.------m-v---.e+-------ww
.--,yy wre-e.
w w


1                             Zachman                   260
1 Zachman 260
(~}
(~}
    %.J 2               Did you say to Mr. Keaten at the meeting 3 in words or substance that the training department 4 had had verbal feedback in mid-78-79 from shift gg,   5 supervisors that training in the basics was lacking?
2 Did you say to Mr. Keaten at the meeting
6         A     To the best of my recollection, I don't 7 recall making that statement.
%.J 3
8         Q     You don't recall saying anything then to 9 Mr. Keaten?
in words or substance that the training department 4
10               Do you recall saying anything to Mr. Keaten 11 along the lines that people in the training department 12 had received any kinds of complaints or information gg       13 from shift supervisors that they felt that training s   I L./
had had verbal feedback in mid-78-79 from shift gg, 5
14 in the basics was lacking?
supervisors that training in the basics was lacking?
15         A     Not to the best of my recollection.
6 A
16         Q     Did Mr. McCormick or Mr. Beers make 17 any statements to that effect?
To the best of my recollection, I don't 7
18         A     I think I already testified that I don't l             19 recall their statements at that meeting.
recall making that statement.
8 Q
You don't recall saying anything then to 9
Mr. Keaten?
10 Do you recall saying anything to Mr. Keaten 11 along the lines that people in the training department 12 had received any kinds of complaints or information gg 13 from shift supervisors that they felt that training s
I L./
14 in the basics was lacking?
15 A
Not to the best of my recollection.
16 Q
Did Mr. McCormick or Mr. Beers make 17 any statements to that effect?
18 A
I think I already testified that I don't l
19 recall their statements at that meeting.
l l
l l
20         Q     Do you see right above the notes that 21 I just read on that same page, the statement that
20 Q
;            22 says, " Shift in emphasis was from theory to hardware 1
Do you see right above the notes that 21 I just read on that same page, the statement that 22 says, " Shift in emphasis was from theory to hardware 1
23 based on assumption that Navy nukes would have a l             24 basic background"?
23 based on assumption that Navy nukes would have a l
24 basic background"?
(~h
(~h
(/       25         A     I see that.
(/
25 A
I see that.
1
1


1                           Zachman                     261 2         Q   Did you say anything like that?
1 Zachman 261 2
3         A   Not to the best of my recollection.
Q Did you say anything like that?
4         Q   Did Mr. McCormick or Mr. Beers?
3 A
5         A   I have no recollection what Mr. Beers ggg 6   or Mr. McCormick said at that meeting.
Not to the best of my recollection.
7         Q   I would like to go back, Mr. Zechman, 8   to page 6 of the attachment to Mr. Lawyer's 9' memorandum to Mr. Thorpe which is the draft of the 10 Penn State report and direct your attention d
4 Q
11   specifically to paragraph B at the top of page   6.
Did Mr. McCormick or Mr. Beers?
12               It reads, "A review of the topics covered
5 A
,  (~%     13   in the various training programs did not identify-(_)
I have no recollection what Mr. Beers ggg 6
(           14   any material on heat transfer and fluid flow or 15   elementary system dynamics. To understand the 16   technical basis for the design and operation of a 17   reactor plant, one must be familiar with not only 18   reactor theory, but heat transfer and fluid flow.
or Mr. McCormick said at that meeting.
19             ."In addition, it's essential that one be 20   familiar with system dynamics in order to understand l           21   the expected response of a reactor plant under 22   transient conditions.
7 Q
23               "Accordingly, sections covering this 24   material should be added to the CRO and SRO training l
I would like to go back, Mr. Zechman, 8
    '          programs."
to page 6 of the attachment to Mr. Lawyer's 9'
25
memorandum to Mr. Thorpe which is the draft of the 10 Penn State report and direct your attention d
11 specifically to paragraph B at the top of page 6.
12 It reads, "A review of the topics covered
(~%
13 in the various training programs did not identify-(_)
(
14 any material on heat transfer and fluid flow or 15 elementary system dynamics.
To understand the 16 technical basis for the design and operation of a 17 reactor plant, one must be familiar with not only 18 reactor theory, but heat transfer and fluid flow.
19
."In addition, it's essential that one be 20 familiar with system dynamics in order to understand l
21 the expected response of a reactor plant under 22 transient conditions.
23 "Accordingly, sections covering this 24 material should be added to the CRO and SRO training l
25 programs."


1                                                                           zochman                                       262 i
1 zochman 262 i
t 2                                         Do                     you see that paragraph?
t V(~T 2
V(~T 3                       A               I see it.
Do you see that paragraph?
4                       Q               Did you agree with the statement, gg                 5                 Mr. zachman, to                                     understand the technical basis 6                 for the design and operation of a nuclear plant, one 7                 must be familiar with not only reactor theory but                                                                               ,
3 A
8                also heat transfer and fluid flow?
I see it.
Y 9                       A               That was a long statement.
4 Q
10                                       THE WITNESS:                                   Could I have that read 11                       back, please?
Did you agree with the statement, gg 5
12                                         (Record read back.1 13                       Q               I will phrase it a different way.
Mr. zachman, to understand the technical basis 6
      -0 14                                       Did you express any disagreement 15               with the statement that to understand the technical 16               basis for         the design and operation of a reactor 17               plant, one must be familiar with not only reactor 18                 theory but also heat transfer and fluid flow?
for the design and operation of a nuclear plant, one 7
19                                       MR.                         MacDONALD:             Express it to whom?
must be familiar with not only reactor theory but 8
20                                       MR. FISKE:                               To anybody.
also heat transfer and fluid flow?
,                            21                                       THE WITNESS:                                   May I have that read back, 22                       please, and then may I have a break.
Y 9
23                                         (Record read back.)
A That was a long statement.
1 24   i                   A             I don't recollect at this time what 25               comments I specifically expressed, either orally or 4
10 THE WITNESS:
Could I have that read 11 back, please?
12 (Record read back.1 13 Q
I will phrase it a different way.
- 0 14 Did you express any disagreement 15 with the statement that to understand the technical 16 basis for the design and operation of a reactor 17 plant, one must be familiar with not only reactor 18 theory but also heat transfer and fluid flow?
19 MR.
MacDONALD:
Express it to whom?
20 MR. FISKE:
To anybody.
21 THE WITNESS:
May I have that read back, 22 please, and then may I have a break.
23 (Record read back.)
1 24 i
A I don't recollect at this time what 25 comments I specifically expressed, either orally or 4
E
E
              ,,,---. .-- -.-  -_w- ,-.,..--,..,_.r,       , , , , . - - . . , , . . . , , , . . . .        -
-_w-
                                                                                                                ,cm,_.-.     ,-mm .-..-,...,-...-_..,_v.-.   ., . . ,- - - -- ,.-
,-.,..--,..,_.r,
,cm,_.-.
,-mm
.-..-,...,-...-_..,_v.-.
m.


1                                                                 zochnen                                         263 2       in writing, relative to that                                                         --
1 zochnen 263 2
relative to what 3       you just asked.
in writing, relative to that relative to what 3
4               Q             Wouldn't it be a pretty acceptable 5       proposition for someone involved in training nuclear ggg 6       operators that in order to understand the technical 7       basis for the design and operation of a reactor plant, 8       an operator should be familiar with not only the 9       reactor theory, but heat transfer and fluid flow?
you just asked.
10               A               It's my understanding they would have 11       to be familiar with the reactor theory and the 12 heat transfer associated with the characteristics and 13       operation of the reactor at a point in question.
4 Q
14               Q               Similarly, looking at the next sentence
Wouldn't it be a pretty acceptable ggg 5
,                              15       in small "b," wouldn't it be a perfectly acceptable 16       proposition for someone involved in training 17       nuclear operators that an operator should be familiar 18       with system dynamics in order to understand the I
proposition for someone involved in training nuclear 6
19       expected response of a reactor plant under transient 20       conditions?
operators that in order to understand the technical 7
21                               MR. MacDONALD:                                             His recollection at the G                         22               time he read it?
basis for the design and operation of a reactor plant, 8
23                               MR. FIS KE :                         Yes, in that period of time; 24               just a basic concept, that's all.
an operator should be familiar with not only the 9
25               A               I would agree that one would have to be l
reactor theory, but heat transfer and fluid flow?
10 A
It's my understanding they would have 11 to be familiar with the reactor theory and the 12 heat transfer associated with the characteristics and 13 operation of the reactor at a point in question.
14 Q
Similarly, looking at the next sentence 15 in small "b," wouldn't it be a perfectly acceptable 16 proposition for someone involved in training 17 nuclear operators that an operator should be familiar 18 with system dynamics in order to understand the I
19 expected response of a reactor plant under transient 20 conditions?
21 MR. MacDONALD:
His recollection at the G
22 time he read it?
23 MR. FIS KE :
Yes, in that period of time; 24 just a basic concept, that's all.
25 A
I would agree that one would have to be l


1                                     zochman                     264 j )
1 zochman 264 j
2     familiar with the system in the realms of what a 3   reactor operator needs to know, the system dynamics 4     and expected responses as taught by the vendor who ggg       5     designed that reactor.
)
6                 Q       I am perfectly willing to let that 7     answer stand, but I don't think that is what I was 8     asking you.
2 familiar with the system in the realms of what a 3
9                         MR. MacDONALD:   You can let any answer 10                 you want stand.
reactor operator needs to know, the system dynamics 4
11                 Q       The question I was asking is, as a matter 12     of experience and someone who has been involved 13     in training nuclear operators, isn't it a perfectly 14     basic concept that an operator should be familiar 15     with system dynamics in order to be able to understand 16     the expected response of the plant under transient 17     conditions?                       -
and expected responses as taught by the vendor who ggg 5
18                 A         Sir, there are many different types of
designed that reactor.
,                19     reactors and many different types of expected 20     responses with those reactors.             It would have to be 21     those expected responses on a specific plant as 9         22     taught, as far as I'm concerned, as taught from the 23     manufacturers of the plant.
6 Q
24                 Q         What you are saying, he would have to be 25     familiar with system dynamics in order to understand r *
I am perfectly willing to let that 7
            -r--     r-     c-+--+,--,u.- --
answer stand, but I don't think that is what I was 8
asking you.
9 MR. MacDONALD:
You can let any answer 10 you want stand.
11 Q
The question I was asking is, as a matter 12 of experience and someone who has been involved 13 in training nuclear operators, isn't it a perfectly 14 basic concept that an operator should be familiar 15 with system dynamics in order to be able to understand 16 the expected response of the plant under transient 17 conditions?
18 A
Sir, there are many different types of 19 reactors and many different types of expected 20 responses with those reactors.
It would have to be 21 those expected responses on a specific plant as 9
22 taught, as far as I'm concerned, as taught from the 23 manufacturers of the plant.
24 Q
What you are saying, he would have to be 25 familiar with system dynamics in order to understand r
-r--
r-c-+--+,--,u.-
ry--,. _
m m


1 Zochman                     265 O)
1 Zochman 265 O) 2 the very types of expected responses you just
(
(
2        the very types of expected responses you just 3       described?
3 described?
4                         MR. MacDONALD:   His answer is what it g       5                 was.
4 MR. MacDONALD:
6                         MR. FISKE:   I don't believe it's responsive 7                   to the question.
His answer is what it g
8                         MR. MacDONALD:   Whatever your thought, 9                 whether or not his answer is respensive, he 10                   gave you an answer.
5 was.
6 MR. FISKE:
I don't believe it's responsive 7
to the question.
8 MR. MacDONALD:
Whatever your thought, 9
whether or not his answer is respensive, he 10 gave you an answer.
11 You want to rephrase it and put it 12 in your terminology?
11 You want to rephrase it and put it 12 in your terminology?
13                         MR. FISKE:   This is a totally different 14                   question, and you know it and I know it.
13 MR. FISKE:
15                         If you want to take a break because Q
This is a totally different 14 question, and you know it and I know it.
16 you don't understand the question, I am perfectly 17 willing to do that, but you are not answering the 18       question I asked.
15 Q
19 MR. MacDONALD:   He asked for a break 20                   about four minutes ago before you ever asked 21                   that question. It has nothing to do with what O     22                   he understood. Don't imply he asked for a break 23 because you asked that question.
If you want to take a break because 16 you don't understand the question, I am perfectly 17 willing to do that, but you are not answering the 18 question I asked.
24                         MR. FISKE:   Maybe the need for the break O                 25                   continued on to the next question.
19 MR. MacDONALD:
He asked for a break 20 about four minutes ago before you ever asked 21 that question.
It has nothing to do with what O
22 he understood.
Don't imply he asked for a break 23 because you asked that question.
24 MR. FISKE:
Maybe the need for the break O
25 continued on to the next question.


1                               Zochnan                       266
1 Zochnan 266
(           2                   MR. MacDONALD:     He asked for the break 3             five minutes ago.
(
4                   MR. FISKE:   I don't think there is any ggg       5             dispute.
2 MR. MacDONALD:
6             A     I think I answered your question.
He asked for the break 3
7             Q     You have not.     I will ask it again.
five minutes ago.
8     If you want to take a break first, that is perfectly 9     all right with me.
4 MR. FISKE:
10             A     Let's finish the question first.
I don't think there is any ggg 5
11             Q     You have told us in the last two answers 12     that you gave to the question that I put that 4
dispute.
13     different types of reactors could have different 14     types of responses, and you have said that you 15     thought it was important to an operator to 16     understand what those different types of responses 17     could be f ro m   different plants.
6 A
18 Isn't that the substance of what you 19     just said?
I think I answered your question.
20             A     Not exactly, sir, i
7 Q
21             Q     Whether I state it' correctly or not' I O       22     would like to go back for the third time to the 23     sentence in paragraph "b" which says, "It is 24     essential that one be familiar with system dynamics 25     in order to understand the expected response of a
You have not.
I will ask it again.
8 If you want to take a break first, that is perfectly 9
all right with me.
10 A
Let's finish the question first.
11 Q
You have told us in the last two answers 12 that you gave to the question that I put that 13 different types of reactors could have different 4
14 types of responses, and you have said that you 15 thought it was important to an operator to 16 understand what those different types of responses 17 could be f ro m different plants.
18 Isn't that the substance of what you 19 just said?
20 A
Not exactly, sir, i
21 Q
Whether I state it' correctly or not' I O
22 would like to go back for the third time to the 23 sentence in paragraph "b" which says, "It is 24 essential that one be familiar with system dynamics 25 in order to understand the expected response of a


1                             zochaon                   267 2    reactor plant."
1 zochaon 267
(
(
3 o                I am simply asking you whether you didn't 4   agree at the time you received this memorandum with ggg     5   that basic proposition.
2 reactor plant."
6                 MR. MacDONALD:   He answered your question.
3 I am simply asking you whether you didn't o
7                 Do you want to ask it again?
4 agree at the time you received this memorandum with ggg 5
I 8           A     I stand firm in   the way I answered that 9   question just previously, sir.
that basic proposition.
10           Q     The last sentence of this paragraph --
6 MR. MacDONALD:
11           A     May I have a break, please?
He answered your question.
12           Q     Sure. I thought we were going to finish 13   the paragraph.
7 Do you want to ask it again?
14                 MR. MacDONALD:   I thought it was a 15           question.
I 8
16                 MR. FISKE:   I have one last question 17           on this paragraph and then I should be through.
A I stand firm in the way I answered that 9
18                 THE WITNESS:   Go ahead.
question just previously, sir.
19           Q     The last sentence of the paragraph says, i
10 Q
20   "Accordingly, sections covering this material should l
The last sentence of this paragraph --
21   be added to the CRO     and SRO training   programs."
11 A
9     22           A     I see that.
May I have a break, please?
23           Q     I refer you to your comments to 24   Mr. Smith ~ dated February 6, 1980 with respect to
12 Q
      -        25   comment   "b" on   page 6 and ask you if I am correct
Sure.
I thought we were going to finish 13 the paragraph.
14 MR. MacDONALD:
I thought it was a 15 question.
16 MR. FISKE:
I have one last question 17 on this paragraph and then I should be through.
18 THE WITNESS:
Go ahead.
19 Q
The last sentence of the paragraph says, i
20 "Accordingly, sections covering this material should l
21 be added to the CRO and SRO training programs."
9 22 A
I see that.
23 Q
I refer you to your comments to 24 Mr. Smith ~ dated February 6, 1980 with respect to 25 comment "b"
on page 6 and ask you if I am correct


1                             zochman                     268 2   that your written comment with respect to that 3   entire paragraph was " Agree     that heat transfer and 4   fluid flow be added to CRO/SRO training cirriculum."
1 zochman 268 2
lll-         5                 MR. MacDONALD:   I object. You have built 6           in an assumption.
that your written comment with respect to that 3
7                   MR. FISKE:   Read the question again.
entire paragraph was " Agree that heat transfer and 4
8                   LRecord read back.)
fluid flow be added to CRO/SRO training cirriculum."
9         Q       I will ask you, is there any other 10   comment reflected on Exhibit 568 with respect to 11   comment     "b" on page 6 other than what I have just 12   read?
lll-5 MR. MacDONALD:
()           13           A       Sir --
I object.
14           Q       What is the answer?
You have built 6
15           A       There is something wrong with my comments 16   matching up with this document.       They don't match, sir.
in an assumption.
17   I'm not sure that this -- they don't match.       I'm not 18   sure that these comments are reflected against this 19   draft.
7 MR. FISKE:
20           Q       We can go through that some more after I
Read the question again.
21   the break.     I want to be ~sure that we agree on what 9         22   the comments are because Mr. MacDonald expressed some 23   ambiguity about that.
8 LRecord read back.)
l 24           A       Can we do that after the break, sir?
9 Q
O             25           Q       Sure.
I will ask you, is there any other 10 comment reflected on Exhibit 568 with respect to 11 comment "b" on page 6 other than what I have just 12 read?
()
13 A
Sir --
14 Q
What is the answer?
15 A
There is something wrong with my comments 16 matching up with this document.
They don't match, sir.
17 I'm not sure that this -- they don't match.
I'm not 18 sure that these comments are reflected against this 19 draft.
20 Q
We can go through that some more after I
21 the break.
I want to be ~sure that we agree on what 9
22 the comments are because Mr. MacDonald expressed some 23 ambiguity about that.
l 24 A
Can we do that after the break, sir?
O 25 Q
Sure.
i i
i i


1 Zechman                               269
1 Zechman 269
()       2 (Recess taken.)
()
3                             MR. FISKE:       I think the record should 4
2 (Recess taken.)
indicate that we have had a recess of half an ggg   5               hour, and now Mr. MacDonald wants to put 6                 something on the record.
3 MR. FISKE:
7                             MR. MacDONALD:             I am just saying that 8
I think the record should 4
the witness is finished for the day, he informs 9             me, because he has a headache and is tired and 10 is no longer able to physically continue.
indicate that we have had a recess of half an ggg 5
11               I apologize.           There is'nothing else I can say 12               to you.           It has happened before, and I'm sure 13               it will happen again in the course of 14               depositions.
hour, and now Mr. MacDonald wants to put 6
15                             It has happened to me and I understand 16               it happens to witnesses.
something on the record.
17 MR. FISKE:     The testimony ended at 3:35 18                                                                                     '
7 MR. MacDONALD:
when a recess was taken, and it is now 3:55.
I am just saying that 8
19 MR. MacDONALD:             We can reflect I was here 20               for a half hour after lunch.                         I don't want to 21               get into that on the record.
the witness is finished for the day, he informs 9
G   22                             MR. FISKE:     We will resume at 9:30 23 tomorrow morning.
me, because he has a headache and is tired and 10 is no longer able to physically continue.
24                             MR. MacDONALD:
11 I apologize.
    ~                                                                If we can resume at
There is'nothing else I can say 12 to you.
    \-     25                                           (continued on next page.)
It has happened before, and I'm sure 13 it will happen again in the course of 14 depositions.
15 It has happened to me and I understand 16 it happens to witnesses.
17 MR. FISKE:
The testimony ended at 3:35 18 when a recess was taken, and it is now 3:55.
19 MR. MacDONALD:
We can reflect I was here 20 for a half hour after lunch.
I don't want to 21 get into that on the record.
G 22 MR. FISKE:
We will resume at 9:30 23 tomorrow morning.
24 MR. MacDONALD:
If we can resume at
~
\\-
25 (continued on next page.)


i 1                                                               zochann                                 270                 ,
i 1
1 2       9:30 tomorrow morning, that would be fine with us.
zochann 270 1
3                                 (Time noted:                   3:55 p.m)
2 9:30 tomorrow morning, that would be fine with us.
{                                                                   4 RICHARD W. ZECHMAN                                           (
3 (Time noted:
I                                                                   6 subscribed and sworn to                                                                                                     ,
3:55 p.m)
7 before me this                               day                                                                           !
{
1 g of                                     ,    1982, i
4 RICHARD W.
t 9
ZECHMAN
10
(
'                                                                                                                                                                          ~
I 6
11 12 I                                                                 13 4
subscribed and sworn to before me this day 7
1 g
of
: 1982, i
9 t
10 11
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12 I
13 4
i
i
)                                                                 14 e             15 16 I
)
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17                                                                -
15 16 I
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1 271           I CERTIFICATE                                         -
1 271 I
b    STATE OF NEW YORK         )
CERTIFICATE b
3y                                     : ss.:                                                     .
STATE OF NEW YORK
l   COUNTY OF NEW YORK         )
)
4                                                                                               ,'
3y
i I,   ROBERT CAPUZELo                           , a Notary         l 1
: ss.:
6 Public of the State of New York, do hereby l
l COUNTY OF NEW YORK
certify that the continued deposition of                                 i' I
)
l RICHARD w. ZECHMAN                   was taken before               1 8
4 i
me on     March 11: 1982                           consisting of pages     157 through_     271       ;
I, ROBERT CAPUZELo
I further certify that the witness had been previously sworn and that the within transcript is a true record of said testimony;                           ;
, a Notary l
That I am not connected by blood or marriage with any of the said parties nor interested directly or indirectly in the matter I                    in controversy, nor am I in the employ of any                           l' of the counsel.
1 Public of the State of New York, do hereby l
18 IN WITNESS WHEREOF, I have hereunto set my                     !
6 i
handthis''((         day of         / i u a in               , 1982 20 li                                                     i g           21
certify that the continued deposition of I
                                                                        ~
l RICHARD w. ZECHMAN 8
l nn                                                 !          l     ,'            -
was taken before 1
23
me on March 11: 1982 consisting of pages 157 through_
                                                                  / k[ y             h l7 f \ ., /. .N
271 I further certify that the witness had been previously sworn and that the within transcript is a true record of said testimony; That I am not connected by blood or marriage with any of the said parties nor interested directly or indirectly in the matter l'
                                                              '' ROBERT CAPUZELO '                    '
in controversy, nor am I in the employ of any I
C               24 ,l 25                                                                                           i i
of the counsel.
f
18 IN WITNESS WHEREOF, I have hereunto set my handthis''((
day of
/ i u a in
, 1982 20 li i
g l
21 nn l
~
/ k[ y h l7 f \\., /..N 23
'' ROBERT CAPUZELO '
C 24,l 25 i
i f


272
272
    \
\\'~
      '~
INDEX WITNESS PAGE Richard W.
INDEX WITNESS                                             PAGE Richard W. Zechman                                   159 E XHI B IT S B&W                                             FOR IDENT.
Zechman 159 E XHI B IT S B&W FOR IDENT.
561         Copy of a document entitled             180 "TIMI-2 Investigation Task Force Interviews, 10/16/79" 562         Notes made by the witness on a           180 yellow pad 563         Copy of a memorandum dated               198 12/2W 79 from Mr. Zechman to L. L. Lawyer 564         Copy of a memorandum from               199 James P. O'Hanlon 565         Memorandum dated September 17,           229 179 from Mr. Zechman to
561 Copy of a document entitled 180 "TIMI-2 Investigation Task Force Interviews, 10/16/79" 562 Notes made by the witness on a 180 yellow pad 563 Copy of a memorandum dated 198 12/2W 79 from Mr. Zechman to L.
!                          Mr. L. L. Lawyer l
L.
566         Memorandum to Mr. Zechman dated         245 September 13, 1979 from Mr.
Lawyer 564 Copy of a memorandum from 199 James P.
l                         McCormick and Mr. Beers               .
O'Hanlon 565 Memorandum dated September 17, 229 179 from Mr. Zechman to Mr.
I l             567-       Memorandum from Sandy Lawyer             250 dated January 24, 1980 to J.
L.
Thorpe, subject: "Penn State Committee -
L.
Initial Draft Report" with attachment dated January 22, 1980 568         Document entitled " Comments -           256 l
Lawyer l
566 Memorandum to Mr. Zechman dated 245 September 13, 1979 from Mr.
l McCormick and Mr. Beers I
l 567-Memorandum from Sandy Lawyer 250 dated January 24, 1980 to J.
Thorpe, subject:
"Penn State Committee Initial Draft Report" with attachment dated January 22, 1980 568 Document entitled " Comments -
256 l
Penn State Review Committee Report" dated February 6, 1980 to Doc
Penn State Review Committee Report" dated February 6, 1980 to Doc
(     )               Smith from Richard W. Zechman, supervisor of training.
(
                                        . e e i}}
)
Smith from Richard W.
: Zechman, supervisor of training.
e e
i}}

Latest revision as of 05:08, 15 December 2024

Deposition of RW Zechman on 820311 in New York,Ny. Pp 157-272
ML20072H858
Person / Time
Site: Crane Constellation icon.png
Issue date: 03/11/1982
From: Zechman R
GENERAL PUBLIC UTILITIES CORP.
To:
References
TASK-*, TASK-01, TASK-04, TASK-1, TASK-10, TASK-4, TASK-GB NUDOCS 8306290781
Download: ML20072H858 (115)
v • d • e


Text

bt 157

[x

\\_)

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK

- - -x GENERAL PUBLIC UTILITIES CORPORATION, a

h JERSEY CENTRAL POWER & LIGHT COMPANY, METROPOLITAN EDISON COMPANY and PENNSYLVANIA ELECTRIC COMPANY, a

Plaintiffs, s

-against-80 Civ. 1683 (RO)

THE BABCOCK & WILCOX COMPANY and J.

RAY McDERMOTT & CO.,

INC.,

Defendants.

- - - - - - - -x (r'%)

Continued deposition of General Public Utilities Corporation by RICHARD W.

ZECHMAN, taken by Defendants, pursuant to adjournment, at the offices of Davis Polk & Wardwell, Esqs.,

(

One Chase Manhattan Plaza, New York, New York, i

l on Thursday, March 11, 1982, at 9:45 o' clock l

in the forenoon, before Robert Capuzelo, a Shorthand Reporter and Notary Public within i

I and for the State of New York.

5 I

/3 DOYLE REPORTING, INC.

CERTIFIED STENOTYPE REPORTERS 369 LExlNGTO N AVENUE WALTER SHAP!RO, C.S.R.

NEw YomK. N.Y.

10017 CHARLES SH APIRO, C.S.R.

TELEPMONE 212 - 867-8220 8306290781 820311

(

's gDR ADOCK 0500028

l

i.

)-

1 158 i

w s,_)

2 Appeara nc e s:

3 4

KAYE, SCHOLER, FIERMAN, HAYS & MANDLER, ESQS.

Attorneys for Plaintiffs ggg 5

425 Park Avenue New York, New York 6

By:

ANDREW MacDONALD, ESQ.,

7

-and-JULIET NEISSER, ESQ.,

of Counsel 9

10 11 DAVIS POLK & WARDWELL, ESQS.

Attorneys for Def3ndants l~o One Chase Mahhattan Plaza New York, New York By:

ROBERT B.

FISKE, ESQ.,

14

-and-KAREN E.

WAGNER, ESQ.,

10 o'f-Counsel 16 i

-4 g

18 Also Present:

y l

19 SUSAN HANSON, Paralegal

\\

s Davis Polk & Wardwell, Esqs.

20 21 I

k l

22 I

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23 3

24 i

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,1 7

159 4

-( '

2 P. ICHA RD W.

ZEC HMAN,

resumed, 3

having been previously duly sworn by the 4

Notary Public, was examined and testified y

lll 5

further as follows:

6 EXAMINATION (Continued) 1 t

7I B$ MR. FISKE:

s s 0

Q Mr. Zechman, do you realize you continue d

9' to he under octh today?

~

i 10

,(

A I d, o.

a <

I.

11 gj MR. MacDONALD:

Regarding a recent t

12

/

producticn of some documents from the training

[ \\

(

)

13 d ep a r tmeri t, you asked me to inquire as to u,/

14 where thoss documents came from, and I spoko

,\\

15 to Rochelle Hanson who I understand was the

/

+

,\\

16 individual from our firm who sent the letter 17 down, and her understanding is those are i

~ training department documents, and 18 general

\\o 19 that is where they came from, culled from the l /

/

20 training department files as a whole, no particular s

21 individual's files.

l

~

22 There may be documents in there from many 23 different individuals, but that is my best 24 understanding of that box of documents.

l 25 i

MR. FISKE:

Thank you.

l

I Zechman 160 m(,)

2 Q

Mr. Zechman, when we left off yesterday 3

evening, you were aoing to look at B&W Exhibit 557 4

which has been the subject of the questioning near ll) 5 the end of the afternoon, and let us know, after 6

reviewing it, whether you wanted to change any of 7

the answers that you had given concerning whether 8

specific programs described in this exhibit had 9

been given during the period of time while you were 10 in charge of the training department.

11 Have you done that?

12 A

I have read the document.

One point s

13 of clarification --

(v) 14 Q

Are there any changes you would like to 15 make?

16 MR. MacDONALD:

I don't think it is 17 necessarily changds.

He may want to amplify.

I0 A

In reviewing these, the setting with which 19 these were given were related to the initial 20 cold license program and program associated with the 21 initial staffing.

22 After the initial staffing, both the 23 magnitude the context of the training programs 24

-,e changed from a cold license program to a hot license a

't. '

25 training program and may have not included all the

l 1

zechman 161

(_,)

2 same kind of programs each of these did for the 3

initial staff.

4 There are certain lectures, programs, jll 5

that are identified in here that we may still 6

conduct in our training, but not in the same framework 7

that these are spelled out.

8 One other point of clarification, and 9

that has to do with the period with which I was in 10 charge.

I'm assuming it is understood in the 11 period of 9/78 up to the time of the accident that 12 my position was in training, and during that f3 13 period of time the supervisor of training or acting

(~j) 14 supervisor of training, as I should put it, was 15 shared between Mr. Frank

}!cCormack and Marshal 16 Beers during that period with full responsibility 17 and authority.

18 Q

You had a position during that period 19 of supervisor of training, did you not?

20 A

I had the title, yes.

21 Q

Yesterday, Mr. Zechman, we made some 22 references to the portion of the Met Ed FSAR which 23 deals with the training program.

24 I would like -- this is B&W Exhibit g3L]

25 206 -- to hand you that and refer you to a portion

1 Zechman 162

[

\\/

2 which is captioned " Metropolitan Edison Requalification 3

Program."

4 I believe you testified yesterday that lll 5

this program was conducted during the period of time 6

November 1977 through March

'79.

7 MR. MacDONALD:

Are you asking whether 8

that is his testimony or are you --

9 Q

That is a fact, is it not, that the 10 requalification program was going on during that 11 period of time?

12 A

What were the dates?

(~)S 13 Q

November '77 to March

'79.

s _.

14 A

That was the time requalification programs 15 were going on.

There were amendments in that 16 interval.

17 Q

The Met Ed FSAR states that, "The basis 18 of the requalification program is the need to 19 maintain operator competence and proficiency in the 20 quest for continued safe operation."

21 Do you see that?

22 MR. MacDONALD:

Section 13.2.2?

23 MR. FISKE:

Yes.

3

(~)

24 I

A I see that.

'\\,

/

23 Q

Was it your understanding that that was

1 Zechman 163

(,/

2 the purpose of the requalification program?

3 A

It's my understanding that was the 4

purpose of the requalification program, yes.

lll 5

Q Is it correct that some time in 1978, 6

beginning some time in 1978, the control room operators 7

attended requalification training sessions less 8

frequently than they had previously because of a 9

change in the shifts from uix to five?

10 A

That is not necessarily true.

They are 11 required to spend a minimum of 60 hours6.944444e-4 days <br />0.0167 hours <br />9.920635e-5 weeks <br />2.283e-5 months <br /> per year 12 in training, minimum.

Normally we conducted a (g) 13 training program that exceeded 60 hours6.944444e-4 days <br />0.0167 hours <br />9.920635e-5 weeks <br />2.283e-5 months <br /> per year.

~

u-14 Q

Is it a fact that during that period of 15 time there was a change in the shifts, the number of 16 shifts?

17 A

I don't recall the exact time period, but 18 there was a period of time they went to five shifts, 19 that is correct.

l l

20 g

could you describe just for the record 21 what the difference was between six shifts and five 22 shifts, how that worked?

i 23 A

Yes.

During six-shift rotation, that 24 included three working shifts, a relief shift, a g-

\\j j

25 l

shift that was off and a training shift.

1 Zechman 164

(~

(_)

2 During five-shift rotation, a relief shift, 3

three operating shifts, and an off shift.

4 Q

How long was each shift?

lll 5

A The relief shift by the way was used for 6

the training shift.

7 Q

How long was each shift?

8 A

Eight hours, working hours.

9 Q

So just so I understand it, if you 10 took under the six-shift program, six consecutive 11 eight-hour w~orking days, three of those would be 12 devoted to working on duty, one being relief, one r"g

( j 13 being off, and one for training, is that correct?

14 MR. MacDONALD:

Are you asking how the 15 program operated, exactly as you describe it?

16 MR. FISKE:

Yes.

17 Q

Is that the concep t?

10 A

I'm not sure that you have described that 19 correctly.

20 Q

Why don't you describe it then?

21 A

Fine.

22 A typical week, there would be a group 23 i

that works from 7:00 until 11:00, 11:00 to 7:00 --

l 24 correct that.

(~)

LI 25 7:00 to 4:00, 4:00 to 11:00, 11:00 to

1 Zechman 165 2

7:00.

There would be one shift that would be 3

off and there would be one shift that would be 4

working daylight hours from 7:00 to 4:00.

It's that lll 5

shift that would be in training during normal shift 6

rotation.

7 So I would see, every five weeks, I would 8

see the relief -- each relief shift.

9 Q

When you say there are six shifts, then 10 you are referring to two consecutive 24-hour days or 11 six shifts?

12 A

si:t shifts means during the daylight hours

)

13 there would be a relief shift on duty and at the 5

14 same time there would be a daylight crew called the 15 training crew, training shift.

16 Q

How was that different when there were 17 five shifts?

l l

18 A

The difference is that instead of the l

19 relief shift being down for training, it would be the 1

20 I

sixth shift for training.

21 Q

I don't think this is coming across very 22 clearly.

I 22 Could you try again.

24 3

yes,

\\_)

(

25 When there are slx shifts, there are six

1 Zechman 166 OV 2

bodies.of individuals as opposed to when there are 3

five shifts, there are five bodies of individuals.

4 During six-shift rotation, one of the g

5 shifts is a training shift.

6 During the five-shift rotation, it's the 7

relief shift that becomes the training shift.

O We utilized or trained the people who are normally 9

assigned to relief.

10 Q

Is it your testimony then that the 11 change from six shifts to five shifts as you have 12 just described it had no impact on the amount of 13 training that the operators received?

14 A

It is my testimony that we conducted'a 15 requalification program in accordance to the 16 prescribed, required requalification and met the 17 requirement to the best of my recollection for that 18 training program.

19 g

I guess my question -- that wasn't my 20 question.

21 My question was, is it your testimony

.9 22 that the change from six shifts to five shifts had 23 no impact on the amount of requalification training 24 that a given operator received?

25 A

I have no recollection that I have made

1 Zechman 167 a balance between -- or recall a balance that I 3

personally made between the amount of training for 4

six shifts and the amount of training for five h

5 shifts.

6 I can only state that we certainly 7

conducted a minimum of 60 hours6.944444e-4 days <br />0.0167 hours <br />9.920635e-5 weeks <br />2.283e-5 months <br /> requalification 8

program as required.

9 MR. FISKE:

Could you read that answer 10 back, please.

11 (Record read back.)

12 Q

Did there come to your attention in 13 1978 that there was a problem with attendance in the 14 requalification program?

15 A

Yes, I recall a period of time that we 16 had attendance to the live lectures in the 17 requalification program that required us through IO

'the mode of the requalification program to prepare 19 separate materials, we called them care packages, to 20 the individuals, or make-up packages.

-21 Q

Let me show you a document which was 22 marked as B&W Exhibit 303.

U Do you have that in front of you?

24 A

Yes, I do.

25 Q

That is a memorandum written by Mr. Goodman.

1 Zechman 168 ID

(_)

2 A

It is not.

3 Q

Pardon me?

4 A

Not tat one I have in front of me.

lll 5

Q Is this it?

6 A

Exhibit 303 is before me at this time, 7

yes.

8 Q

That is a memorandum dated June 21, 9

1978, correct?

10 A

That is correct.

11 Q

That is from Mr. Goodman?

12 A

Yes.

I) 13 Q

Subject:

" Unit 1,

2, Requalification

\\_/

14

~ Program Attendance," right?

15 A

Yes, sir.

16 Q

And you received a copy of that?

17 MR. MacDONALD:

Does he recall receiving 18 a copy?

19 Q

You did receive a copy, did you not?

20 A

I can't recall either way at this time 21 whether I received it.

I was aware of the problem 9

22 at that time.

I can't recall any more whether I looked 23 at this particular piece of paper.

24 Q

Do you recall learning in or about June

-)

)

%)

25 21, 1978 that after the first week of the five-week

1 Zechman 169

(~

( )\\

2 requalification training program cycle had been 3

completed, that there was an overall attendance of 4

only 44 percent for licensed personnel?

ll 5

A I no longer recollect any numbers of 6

that sort.

7 Q

You referred a moment ago to make-up 8

packages.

9 A

Yes.

10 Q

I guess they have been called care packages, 11 have they not, from time to time?

12 A

Yes.

(m) 13 Q

I take it, is it correct, what v

14 happened if someone missed a classroom lecture, 15 then the instructor made up what is referred to as 16 a care package for that individual then to study in 17 his own time to get the information that he missed l

l 18 in class?

l 19 A

That is correct.

20 Q

What would one of those care packages 21 typically consist of?

22 A

Typically it would consist of any hand-out 23 material that was utilized.

Sometimes it would include t

l 24 a lesson plan, the appropriate lesson material that l

-s

[

l

\\s\\

25 was taught in that period, and maybe a qui =.

I 1

Zachman 170 1

['Y

\\

Q And this was to, in effect, substitute 2

for what the individual had missed by not being at 3

the class?

4 A

This was a way for that individual to 5

make up what he missed in class.

6 Q

Mr. Goodman states in this memorandum, 7

Exhibit 303, "Make-up packages are a poor 8

substitute fo r live Jnstruction. "

9 Do you see that?

10.

Where are you at?

11 Q

Item No. 2 down at the bottom.

12 (g

A I see that statement.

(.)

13 Q

At the time you received this memorandum, 14 did you express any disagreement with that concept?

15 A

As I told you a few minutes ago, I recollect 16 having an attendance problem in some period of time.

17 I don't recollect today this piece of paper.

18 If I don't recollect this piece of paper 19 at this time, I can't recollect what I said at that 20 time.

h Q

Did you ever express the view to anybody 22 that you disagreed with the notion that make-up 23 packages are a poor substitute for live instruction?

24 MR. MacDONALD:

He just told you he didn't 25

1 Zechman 171

('N,

(_)

2 necessarily recall whether he ever heard that.

3 Q

To put it this way, Mr. Zechman, did you 4

agree with the concept it was better to have the lll 5

people in class learning the information directly in 6

class than having to get it from a care package 7

afterwards?

8 A

It is my opinion that I certainly would 9

rather have an individual in class for live 10 instruction, but I also would clarify there has been 11 no evidence that giving the care packages has 12 diluted any of the training we tried to convey during f%

13 our requalification program.

(v) 14 Q

I think, Mr. Zechman, that is a ques tion 15 tnat the court will have to decide when it hears 16 the facts in this case.

17 MR. MacDONALD:

I think it is part and 18 parcel of his answer.

l 19 You asked something on this subject 20 matter and he gave you what his answer is.

21 MR. FISKE:

It is a major issue in this i

22 case whether the training program was adequate 23 and whether or not one of the problems with I

24 l

the training program was that people were g3 i

i

%.)

25 not going to class and, therefore, missing

1 Zechman 172 fm 4

4 iJ 2

the benefits of live classroom instruction.

3 MR. MacDONALD:

You asked for his 4

understanding and his understanding he gave llh 5

you on the record.

6 I think there is a full statement on the 7

record of what his understanding was.

8 MR. FISKE:

I asked whether he simply 9

thought it was better for them to be in the 10 class rather than reading the material, and 11 he answered that question and then added 12 something to it to which I responded.

C\\

(_,1 13 Q

Mr. Zechman, let's go to the other 14 exhibit I think that I handed you previously by 15 mistake which is B&W Exhibit 304.

16 Do you have that in front of you?

17 A

I have Exhibit 304 in front o f me.

18 Q

That is a memorandum, is it not, from 19 Mr. Beers to a group of people listed at the 20 top of the page, again on the subject of Unit 1,

2, 21 requalification program attendance, this time dated 22 September 3, 1978.

23 A

It says September 1 on mine'.

(~N 24 Q

September 1,

1978, is that correct?

()

25 l

MR. MacDONALD:

Are you asking if that

1 Zechman 173 2

is what the document says?

3 MR. FISKE:

Yes.

4 A

That is what the document says.

h 5

Q The document indicates you received a 6

carbon copy, does it not?

7 A

The document says the secretary had a carbon 8

copy supposedly to me.

9 Q

The copy that you have underline-d, 'in 10 front of you, does it contain underlining?

11 A

There are underlinings on the copy that 12 I have, yes, sir.

13 Q

Is one of the underlinings under your 14 name?

15 A

Yes.

16 Q

Is there also underlining under the 17 sentence that says, "Overall, approximately half the l

18 1.4. censed people are not attending requal. training"?

l 19 A

In the copy that I have, that is underlined.

j

(

20 Q

Did you put that underlining on there, 21 Mr. Zechman?

22 A

Not to the best of my recollection.

I l

23 Q

Did you put the underlining under your 24 name?

l 25 A

Not to the best of my recollection.

1 zechman 174 Ch

()

2 Q

Did you understand when you received a 3

copy of this, that somebody had underlined your name 4

beca.;e they wanted you to pay special attention lll 5

to the material that was underlined in the memo?

6 MR. MacDONALD:

Objection.

You asked 7

whether or not he recalls receiving the document.

8 You asked whether he appears as a cc on the 9

document.

10 MR. FISKE:

I think Mr. Zechman is 11 perfectly capable of telling us if he wants 12 to now he doesn't recall ever receiving this

7. \\

g

)

13 memo.

If he wants to tell us he doesn't w/

14 recall receiving either one of the two memos, 15 saying that less than half the people were 16 attending the requal. program, he can say that.

17 MR. MacDONALD:

He may have no recollection 18 one way or the other.

19 MR. FISKE:

Let's find out.

20 MR. MacDONALD:

Why not ask him the i

21 question instead of making an assumption?

l 22 MR. FISKE:

I did.

l 1

23 MR. MacDONALD:

You assumed in your 24 g3 question that he recalled receiving it.

N._.A I

25 MR. FISKE:

I said when he received it.

l

1 zechman 175 O

2 I think it's a fair assumption he 3

received it when it is produced by Met Ed and 4

it shows a carbon copy was sent to him.

lll 5

MR. MacDONALD:

You can assume anything 6

you want.

7 Ask the witness a question.

We are 8

not here to learn about your assumptions.

9 MR. FISKE:

Read the question.

10 (Record read back.)

11 A

In that question, you assume I got a 12 copy and recollect that copy.

13 I will state that I was aware that there 14 was an attendance problem.

I don't recollect either 15

- way this particular document at this time.

16 Q

So your testimony is that you now say 17 you don't recall receiving either -- you don't 18 recall whether or not you received either Exhibit 19 303 or 304?

20 A

I'm saying at this point in time, 21 considering that was in 1978, I have seen so many 9

22 documents during that period of time, that I don't 23 recollect one way or the other whether I saw this 24 one at that time.

25 Q

And that answer applies, you say, to both

1 Zechman 176 k./

2 Exhibits 303 and 3047 3

A Yes, sir.

4 Q

You are not denying, are you, during lll 5

this period of time when you were in charge of the 6

training program at Med Ed that you were aware that 7

less than half the licensed people were attending 8

the requalification classes?

9 A

I don't recall the percentage of people 10 who did not attend the' class.

I cannot confirm your 11 number at this time.

12 I only can confirm that I was aware there (D

13 was an attendance program.

That I will confirm.

q,j 14 Q

Did you do anything about this attendance 15 problem, Mr. Zechman?

16 A

Yes, sir, I did.

17 Q

Did you bring this question of the l

l 18 poor attendance by the licensed operators at l

19 training programs to the attention of management?

I l

20 A

I certainly did.

21 Q

Isn't it a fact that nothing was done 22 about it in terms of improving attendance?

23 A

That would have to be time qualified.

24 There was a period of time that we were aware of the

( -}

%..J l

25 attendance problems.

There was a period of time

1 Zechman 177

(~N

(,!

2 in which I made senior management and operations 3

management aware of the attendance problems and 4

there was a period of time it improved.

lll 5

Q It certainly hadn't improved by the 6

time you ceased functioning as head of the training e

7 department, had it?

8 A

I don't recall the period, exact period 9

when it did improve.

10 g

"There is a memorandum dated September 1,

11

'78.

12 Isn't that just about the day you became

,R

(

)

13 supervisor of the training department and R./

14 began to devote eight hours a day to your own personal 15 study?

16 A

That is correct.

17 Q

As of that time when you ceased to function 18 actively as a supervisor of the training department, 19 the attendance had not improved, had it?

20 MR. MacDONALD:

Are you asking for his l

21 recollection?

22 MR. FISKE:

Yes.

23 A

My recollection is not j

I told you i

24 before, you are quoting from this letter, and I told 7-I

(..)

25 you I didn't recollect either way the time period of l

1 Zechman 178 2

this letter and, therefore, I still have not a 3

clear recollection in my mind of the period of time 4

that we had the problem and when the problem h

5 cleared.

6 Q

Well, you cannot tell us as you sit here 7

today that this attendance had improved in any 8

significant way as of the time you assumed the 9

position of supervisor of training, can you?

10 A

Sir, I can only repeat that I'm aware 11 there was an attendance problem and it was in and 12 around that period of time, but I can't nail it down 13 toa fixed time at this time.

14 Q

Isn't it a fact, Mr. Zechman, that the 15 attendance continued to decline right up to the time 16 of the accident?

II A

As I just testified a few minutes ago, 10 I said I was aware of the attendance problem.

19 I was also aware the attendance problem improved at 20 some point in time, but I don' t recall when.

21 Q

And you can't tell us now whether that 22 was before the accident or after the accident, is 23 that correct?

24 A

It's been too long ago.

I have no 25 recollection at this time.

1 zechman 179

(

)

's_/

2 Q

So the answer is you can't say one way 3

or the other as you sit here today?

4 A

That is correct.

llh 5

Q You were interviewed by Mr. Keaten I 6

think as you told us previously at some point after 7

the accident, is that correct?

8 A

That is correct.

9 Q

In that same interview, present were 10 Mr. Beers and Mr.

McCormack.

11 You testified to that before, or a part 12 of the time?

fx

( )

13 A

Yes, part of the time.

14 Q

Isn't it a fact at that meeting that 15 Mr. Keaten was told that attendance at training 16 sessions has been very poor and declining?

17 A

I recall at that meeting that one of the 18 subject areas which was discussed was attendance, i

19 but I don't recall with what framework that was 20 discussed, whether it was discussed in past periods, l

21 present periods.

I just don't recall.

22 Q

Let me show you a document which we will 23 mark as the next exhibit, B&W 561.

<w 24 I would just like to read from this k

25 document to you, Mr. Zechman, and then ask you a l

l

1 Zechman 180

.0

\\- /

2 question.

3 MR. MacDONALD:

Can he read through it 4

before you ask a question?

llI 5

MR. FISKE:

By all means.

6 (Copy of a document entitled "TMI-2 7

Investigation Task Force Interviews, 10/16/79" 8

marked B&W Exhibit 561 for identification as i

9 of this date.)

10 Q

Have you finished reading that exhibit?

11 A

There were some things I couldn't make out.

12 Q

I know, Mr. Zechman, you have been writing n(,,)

13 some notes on a yellow pad in front of you.

14 A

Yes.

I i

15 MR. FISKE:

Could we have that marked as 16 the next B&W exhibit please.

17 MR. MacDONALD:

Sure.

18 (Notes made by the witness on a yellow l

l 19 pad marked B&W Exhibit 562 for identification 20 as of this date.)

l 21 Q

Looking at the handwritten memorandum g

l W

I 22 that you have just been reading, Exhibit 516, after i

23 reading that, does that in any way refresh your

(~))

24 recollection on any subject that you discussed with L.

I 25 Mr. Keaten back in October of '797 Just yes or no.

l 1

1 Zechman 181 e

h

\\m.)

2 MR. MacDONALD:

Let him answer the 3

question.

4 MR. FISKE:

All I want to find out llh 5

A There are selected items in there that 6

I recall discussing.

7 Q

Let me direct your attention, Mr. Zechman, 8

to what I believe is the seventh line on the first 9

page, and I would just like to read a few sentences, 10 and if you, as I read it, think I am reading it 11 incorrectly, you let me know because I recognize it 12 is somebody's handwriting.

n()

13 It says, " Attendance at training sessions 14 has been very poor and declining.

For example, in 15 1978, the attendance record was about 30 percent.

16 This was attributable to the inability of the OPS 17 department to release their people for the required 18 training.

Off-shift people were the worse in l

19 attendance.

Shift supervisors were not as bad, but l

l 20 ware ~ worse than that of the control room operators 21 themselves and the auxiliary operators, et cetera.

l 22 "This attendance was brought to t he 23 attention of the plant management on a number of b(~N 24 occasions.

The response to these letters was not 25 ! at all apparent as attendance continued to go down."

l l

1 l

l

1 Zechman 182

\\

,(,)

2 Do you see those portions of the notes 3

that I just read?

4 A

Yes.

lll 5

Q Did you or Mr. Beers or Mr.

McCormack 6

make statements to that effect to Mr. Keaten at the 7

interview that you had with him in October of '797 8

A I can only testify to what I recall saying 9

to them and I do recall discussing attendance.

10 I don't recall discussing it specifically as it is 11 written here.

12 I do recall discussing the attendance

/( j) 13 problem.

g 14 Q

Is it your position that you told Mr. Keaten 15 in October of 1979 that at some point before the 16 accident, attendance had started to increase?

I 17 MR. MacDONALD:

Are you asking whether he i

18 recalls telling Keaten that?

19 MR. FIS KE :

Yes.

20 A

I don't recall either way.

21 Q

In reading this memorandum, you do not 22 see any statement to that effect in the memorandum, 23 do you?

24 MR. MacDONALD:

You mean o f the portions g-

'\\,s/

25 he can make out?

1 Zechman 183 O

2 MR. FISKE:

Yes.

3 MR. MacDONALD:

It is not a transcription.

4 A

In the notes, it looks like it was h

5 centering around the period 1978.

6 Q

I guess we can draw our own conclusions I

from what I just read as to whether the reference to O

the fact that attendance continued to go down after 9

the 30 percent figure was brought to the attention 10 of management in 1978 means that this memorandum 11 refers to a condition existing after 1978.

MR. MacDONALD:

Draw any conclusion you I

want.

14 Q

My question specifically, Mr. Zechman, 15 is i.9 it fair to say there is no statement that 16 you see in this memorandum in front of you to the 17 effect that at some point, at any point before the 18 accident, attendance improved?

A Not in this document.

20 Q

Let me show you a document which has 21 been marked as Exhibit 558.

It is three pages of 22 handwritten notes which I regret to inform you are 3

even more difficult to read than those in 561 because 24 4

l of the microfilming, but I would represent to you I

25 those have been identified as notes that Mr. Keaten

,.,,-n.-----w

1 Zechman 184 Cs i

i

's /

2 made of the interview that we have just been 3

discussing.

4 I will give you this copy, Mr. Zechman, h

5 that I have.

6 Have you seen that document before?

7 A

You have given me three documents.

8 Q

Jt is all one document.

9 A

It's my recollection that I have not 10 seen this document.

11 Q

You should probably take a minute to look 12 at it.

in

(_,)

13 A

I read it, but I regret to say that a lot 14 of it I couldn't read.

15 Q

I will be asking you specific questions 16 about specific portions of it.

As I do that, you 17 will have another chance to look at the particular 18 section I am asking about.

19 Could you look at the last section of 20 the first page.

21 Do you see the number there?

Could you 22 just read that off the notes?

23 A

Starting off with "1978"?

('N 24 Q

Yes.

What does it say after that?

25 A

"3" something.

I would be guessing l

l l

s-1 Zechnan 185 f~s

~

's 2

that it is a zero and a percent sign, " attendance."

s; 3

Q Did you see any thing in these notes that 4

\\

4 referred to any increase in attendance at any time s

s.

5 from 1978 through to the da e of the adcident?

A 6

MR. MacDONALD:

He just told you he couldn't 7

read them.

The document speaks for itself.

8 You may ask him present-sense impression s

9 of what is in the document, but the words are

'm 10 what they are.

e 11 MR. FISKE:

I am asking him -- do you

\\

12 object to that question?

s

(^~f

\\.

13

(,j s.

MR. MacDONALD:

I object to the question.

'~

14 MR. FISKE:

I think I will agree with you 15 on this particular occasion that the document 16 speaks for itself, containing no such reference.

s 17 Q

Mr. Zechnan, there is --

18 MR. MacDONALD:

That is not what I said.

g j

19

't.

MR. FISKE:

I invite you to disagree with 20 me if you think I am wrong.

21 MR. MacDONALD:

I can't read all the 22 document, either.

2 Q

The next sentence after "1978 - 30 percent

('s 24 attendance" says, " Missing, requires care packages s

'\\_ / \\

25 written by instructor."

Then the next line, as I 1

i

\\

's

\\

,i, 1

Zechman 13d-

<l i

(~'T 1

N' 2

read it, says, " Required 2500 packages / year.

3 Do you see those two?

L

,i 4

A I don't recollect the first word.

lll 5

I recollect " Requires care packages VIitten by 6

instructor."

I recognize " required" something, i

1 7

"2500," and it looks like "packcoes/ year."

8 Q

It is a fact, isn't it, that a very

-l I

t.

9 considerable number of care packages had to be 10 prepared because of the low attendance and the necessity, s

11 to prepare such packages for the people that were 12 not coming to class?

g

(_)

13 A

I recall that there was a number of 14 care packages.

I no longer, recall the magnitude of 15 those.

16 Q

If these notes were to be construed as i

I 17 indicating that youEor Mr. Beers ox-?!r.

McCormack i

18 had told Mr. Keaten'that that gumber wan as high as l

19 2500 packages per year, we uld you --

20 MR. MacDONALD.

I object.

That is purely 21 hypothetical.

g s

l W

22 You may ask what he recalls, but you'can't 23 ask if he said'this, vhat would that, main.

(]

24 Q

Isn't it a fact that at the intbeview

^

L!

25 with Mr. Keaten, it was stated by you or Mr. Btera

/

s 1

zechman 187 p

a

\\/

2 or Mr.

.McCormeck that the number of care packages i

3 was 2500 per year?

4 A-I recall at that meeting indicating that ji

/

h 5

there was a large number of care packages.

t<

[

6 If I were to give out t number, if I were 7

to give out a number at that time, it would have 8

c',

been pure speculation.

7 don't recall that number.

r-9 Q

Based on your present recollection as 10 you sit here todayr are you prepared to say that 11 number was wrong?

I2 A

I have no recollection --

(

)

13 MR. MacDONALD:

Objection.

14 Go ahead.

15 He told you he doesn't recall the

~

t' 16 numbers.

17 Q

You are not in a position then to tell 18 us that the number of care packages that had to be 19 prepared per year was significantly less than 2500?

20 MR. MacDONALD:

Objection.

He told you 21 his recollection.

22 3L i Ifdon't recall the specific number.

2U V

Q You certalnly recall it was well up in

[~N, 24 the hundreds?

U 25 A

I don't recall the number any more.

l a

I Zechman 188

('

\\

(s/

2 Q

You have no recollection at all?

3 A

I recollect that there was a number of 4

them.

I don't recollect the magnitude of them any 5

more.

6 Q

Would ~you agree with Nelson Brown 7

that the preparation of these care packages was a 8

very time-consuming process?

9 MR. MacDONALD:

You are asking him now 10 for his recollection some time in 1978, whether 11 he can recall whether the preparation of those 12 care packages in 1978 was a time-consuming

,(,l 13 p ro ce s s ?

14 MR. FISKE:

1978 or

'79.

Right up to 15 MR. MacDONALD:

I am jus t asking for what 16 your question is intending to do.

17 MR. FISKE:

I am not talking about the 18 number.

19 Q

What I am asking you now, thinking back 20 to that time period, the number of care packages 21 that had to be prepared and what had to go into each 22 care package as you have previously described that 23 process, would you agree tfith Nelson Brown that the

('~')

24 preparation of these care packages was a "very

\\_/

25 time-consuming p rocess"?

1 Zechman 189 2

MR. MacDONALD:

Objection to.the form 3

of the question.

4 Do you want to ask what his recollection 5

is and wheth r or not it was a time-consuming 6

process?

You may ask that question.

7 The form of your question I think is objectionable.

8 Q

Is it fair to say that the preparation 9

of these care packages, taking into account both 10 the numbers that had to be prepared and what had 11 to go into each package, was a very time-consuming 12 process?

13 MR. MacDONALD:

What Mr. Brown may have 14 interpreted as time-consuming, I don't know 15 what he meant, you don't know what he meant.

16 Surely Mr. Zechman wasn't there talking to him, 17 so he doesn't know, i

IO If you want to ask apart from that 19 j

MR. FISKE:

At the moment, I am asking i

20 apart from Mr. Brown.

I am asking it apart l

21 from Mr. Brown.

22 Q

Just your own recollection of that 23 whole situation, the number of packages ti.a t had to 24 he prepared and what had to go into each package.

25 Is it fair to say that was a very L

_ = _

~~

1 1

Zechman 190 1

2 time-consuming process?

3 A

I testify that the time it takes to prepare 4

a care package is directly related to the subject I

5 matter, the depth of the subject matter, and the 6

amount of material to be covered during that period i

7 of time.

8 Therefore, some care packages would 9

take a lot less time than others.

It varies from 10 care package to care package.

11 Q

I recognize there might be that variation 12 across the whole number that had to be prepared i3 right up to 2500.

14 I am just saying, taking into account 15 what went into each package, coupled with the total 16 number of packages that had to be prepared, isn't it 17 fair to say that that whole process was very 18 time-consuming?

19 A

You quoted a number of 2500.

I don't 20 agree with that number.

21 Q

I said whatever it was up to 2500.

22 MR. MacDONALD:

Whatever your recollection 23 is, Mr. Zechman.

()

24 A

It is recognizable that the number of 25 care packages we had at the time when attendance was

1 Zechman 191

,n

(

)

2 low, was time-consuming and required us to do 3

extra work.

4 Q

Isn't it also true that in addition to h

5 sending out the material, it was necessary to track 6

it to follow that the individual did, in fact, 7

receive it?

8 A

That was part of the normal job with 9

the requalification programs, to track any care 10 packages that were sent out.

That was a rather 11 easy task, though, because that was done with a

12 matrix.

((s /

13 Q

Just so I understand it, the burden of 14 preparing these care packages fell on the people 15 who were conducting the classroom sessions, is that 16 correct?

17 A

I don't know that I would call it a 18 burden.

It's their responsibility to prepare those 19 care packages.

20 Q

Whatever time was devoted to preparing 21 those care packages was devoted by the people who 22 were conducting the classroom sessions, isn't that 23 correct?

[

24 A

That is correct.

V; 25 Q

And those were the people that held the

1 Zechman 192 N

s 2

position of administrator / technical training as it has 3

been described; so-called instructors?

4 A

Yes, sir.

There are times when the G

5 group supervisors may have participated.

6 Q

It would either be the group supervisors 7

or the instructors?

8 A

That is correct.

9

~

May we take a break?

10 Q

Sure.

11 (Recess taken.)

12 MR. FIS KE :

Read back the last question O(_/

13 and answer, please.

14 (Record r ead back. )

15 BY MR. FISKE:

16 Q

Directing your attention, Mr. Zechman, 17 again to the document that has been marked as B&W 18 358, which are Mr. Keaten's notes of the interview, 19 I am showing you the second page, the third item, 20 which, as I read it, says, "No club to enforce 21 attendance except licensing exam."

22 Do you see that?

23 A

I see that.

24 Q

Isn't it a fact that before the Three 25

tile Island accident, you felt that there was no club a

1 Zechman 193 O

2 to enforce attendance except the licensing exam?

3 A

Are you asking me if that is my quote?

4 MR. MacDONALD:

That is basically what 5

he is asking you, whether you recall saying that.

6 Q

That you held that view.

7 A

I held a view prior to the accident 8

that it was the responsibility of the line function 9

in this case, line function operations department, 10 to have their people attend training.

11 Q

As far as the people who were supposed I

12 to attend the training were concerned, there was no

()

13 club to get them to go to the training except the 14 licensing exam?

15 MR. MacDONALD:

I object to the form of 16 the question.

He gave his answer.

17 I also think that you have not attributed 18 that statement to him.

What somebody may have 19 said or wrote on the pages is their 20 interpretation of what was said --

21 MR. FISKE:

It is a preliminary question.

22 g

Isn't it a fact that was a view that you 23 held?

A 24 A

That is not a fact.

25 g

Isn't it a fact that you made a statement

1 Zechman 194 7_

'N' '/

2 to that effect to Mr. Keaten during this interview?

3 MR. MacDONALD:

By "you" you mean Mr.

4 Zechman?

5 MR. FISKE:

Yes.

6 A

I have no recollection of making a 7

statement in that format.

8 I do recall making, to the best of my 9

recollection, a statement that it's the responsibility 10 of the line function to get the people there.

11 Q

The question is, what can they do about 12 it if the people don't go?

You understand what we

(' \\

\\J 13 are talking about.

~

14 MR. MacDONALD:

He gave you his recollection 15 twice as to the question that you have asked.

16 Do you have another question?

l 17 MR. FISKE:

Yes.

It is the same question.

l 18 I don't believe it has been answered.

l 19 Q

Did you tell Mr. Keaten during this l

l 20 interview that there was no club to enforce the 21 attendance other than the licensing program?

g 22 MR. MacDONALD:

Objection.

If you 23 would like -- and I know you are not trying l

rx l

l 24 i

to prolong this depositio n -- he just told you t

\\_/

l 25 two questions and answers ago that he didn't

1 Zechman 195 O

2 recall ever making that.

What he recalled in 3

that subject areas was what he testified to.

4 Q

Is that correct, Mr. Zechman, what your 1

5 counsel just said?

6 A

That is correct.

7 Q

I will read you from a question and 8

answer at Mr. Keaten's deposition.

I will be happy 9

to come over there since I'm sure you don't have 10 copies over thera.

i 11 Reading from page 705 of Mr. Keaten's 12 deposition, the question is, "Would you look at 13 the next page of your handwritten notes.

I recognize 14 it is a very poor copy.

Unfortunately, this is the i

15 best we can do working from the microfilm that we 16 had.

i 17 "Looking at the third comment down i

i 18 from the top of the page, the one that begins and 19 reads 'no club to enforce attendance except licensing i

20 exam,' do you see that?

l f

I 21 "A awer:

I think that is what it says.

ggg 22

" Question:

Did members of the training 23 staff complain that before the accident they had no l

24 way to enforce attendance at training sessions other j

25 l than the threat of possible failure of the licensing i

1 Zechman 196 C) 2 exam?

3

" Answer:

I believe that I recollect that 4

a comment as to that regard was made.

I don't 5

remember specifically whether it was a complaint or 4

6 simply a comment.

7

" Question:

Do you know who made the 8

comment, Mr. Zechman or Mr. Beers?

9

" Answer:

I believe, to the best of my 10 recollection, it was made by Mr. Zechman."

11 Hearing those questions and those answers 12 from Mr. Keaten's testimony, does that refresh your 13 recollection that you made such a statement to 14 Mr. Keaten?

15 MR. MacDONALD:

I object to the form of 16 the question.

He wasn't there when Keaten was 17 deposed and he doesn't know what was meant.

18 You don't have to look incredulously across the 19 table.

20 MR. FISKE:

I think I am asking an entirely 21 reasonable question.

Having heard Mr. Keaten's 22 testimony that to the best of his recollection 23 Mr. Zechman made the statement that we have

()

24 been talking about, I am simply asking whether 25 that helps Mr. Zechman remember that, in fact,

--~-r,--

-- -, -,,-y, rr e,-,.

-r-.-,,

-,~-----w,w-re

,,-r.,-,,r, r,-

-..w,,,, - - - -,. - -,, - - -,. - - - -, - - -

I 1

Zec hman 197

,n

~.

2 he did make that statement.

3 A

I stick to my previous testimony.

4 Q

Isn't it a fact, Mr. Zechman, that even 5

after the Three Mile Island accident, attendance 6

at training sessions continued to be poor?

7 MR. MacDONALD:

I object to the form of 8

the question.

9 I think he has testified previously that 10 he has some recollection at some point in time 11 and you are using the term " continued" and I 12 don't think that is proper based on what the

/~'T

(,/

13 testimony has been.

I4 MR. FISKE:

We have yet to identify that 15 time.

i 16 Q

Isn't it a fact that as late as 17 December of 1979, more than six months after the 18 Three Mile Island accident, attendance at training 19 sessions continued to be poor at Met Ed?

20 MR. MacDONALD:

I object to the form of 21 the question.

g) 22 Q

You may answer.

23 THE WITNESS:

Would you repeat that question

/ ';

24 for me, please.

\\J 25 (Record read back.J

1 Zechman 198

,3 fVl 2

A I'm sorry, I have no recollection of 3

magnitude of attendance at that period of time.

4 Q

You don't have any recollection that 5

classroom attendance in the requalification program 6

reached an all-time low in the period November of 7

'79 through December '79?

8 A

I'm just stating right today I don't 9

recollect the time frames, the attendance time 10 frames.

That is all I'm saying.

'll Q

Your answer to my last question is you 12 don't remember?

/,'

k-13 A

I don't remember today.

14 MR. FISKE:

Let's mark the next exhibit 15 B&W Exhibit 563.

16 (Copy of a memorandum dated 12/20/79 17 from Mr. Zechman to L.

L.

Lawyer marked 18 B&W Exhibit No. 563 for identification as of 19 this date.)

20 Q

Have you had a chance to look at B&W 21 Exhibit 5637 22 A

I have.

23 Q

That is dated 12/2G/79, is it not?

/^

(_)\\

24 A

That is correct.

25 Q

Subject:

" Unit 2 Requalification

1 Zechman 199 7-~ t K. /

2 Attendance"?

3 A

That is correct.

4 Q

Is that your signature at the bottom, k

5 "R.

W.

Zechman, Supervisor of Training"?

6 A

That is not my signature, and he had 7

authority to sign my signature to that letter.

8 I drafted the letter; he signed it.

9 Q

If I understand you, this document has 10 just been identified as a document that you drafted 11 and Mr. Frederick put your signature to, with your 12 authority?

/^N

(,)

13 A

That is correct.

14 Q

Was this a memorandum that you wrote in 15 the regular course -- that you prepared in the regular 16 course of business as supervisor of training?

17 A

Can you repeat that?

18 Q

Was this written as part of your job?

19 Was this done in the course of your duties?

20 A

In accordance with my duties to make 1

21 these kinds of things, yes.

22 MR. FISKE Mark this as the next exhibit.

23 (Copy of a memorandum from James P.

/~N 24 o'Hanlon marked B&W Exhibit No. 564 for (s.s) 25 identification as of this date.)

1 1

Zechman 200 j

e

\\/

2 Q

Do you still have Exhibit 563 in front 3

of you?

4 A

Yes, I do.

lh 5

Q The first sentence refers, does it not, 6

to a report prepared for you by Mr. Frederick 7

concerning attendance at the Unit 2 requalification 0

program for the period of November 5,

'79 through 9

December 14,

'797 e

10 A

That is correct.

11 Q

The next sentence says, "The results 12 of this survey indicated an all-time low in classroom

.e^

(_,Nl 13 attendance for this short period of a little over 14 one month."

15 Do you see that?

16 A

I see that.

1 Q

Did you underline the word " low" in that 18 sentence, or did Mr. Frederick?

i l

A To the best of my recollection, I wrote 1

20 the letter and I underlined it.

21

)

Q Two sentences later it says, "Because 22 of the poor attendance, Ed Frederick had to prepare 23 332 ' care packages' to be sent out for make-up and to 4

i be tracked.';

\\_/

25 Do you see that sentence?

1 Zechman 201 0

2 A

I do.

3 Q

was_the procedure for preparing care 4

packages after the Three Mile Island accident h

5 essentially as it had been before~in terms of what 6

went into them and how it was done?

7 A

Yes.

8 Q

In the next p.tragraph there is a 9

reference to two gentlemen named Joe chwastyk and 10 Bernie Smith, who, it is stated, did not attend a 11 single lecture out of 20 given.

12 Do you see that reference?

I'3 A

Yes, I do.

14 Q

Who is Mr. Chwastyk?

15 A

He was a shift supervisor, Unit 2.

16 Q

And Mr. Smith?

i 17 A

Shift supervisor, Unit 2.

18 Q

And the next sentence after that says, 19 "Even though hunting season and vacations may l

20 have interfered, no attempt to make up the lecture 21 during relief week or any other time was made."

22 Does that sentence refer back to i

23 Mr. Chwastyk and Mr. Smith?

l 24 A

To the best of my recollection, it did.

25 Q

This memorandum is written to Mr.

L.

L.

1 Zechman 202 2

Lawyer, is that correct?

3 A

That is correct.

4 Q

What was his position?

lh 5

A Acting manager of training.

6 Q

The last sentence says, or next to last, 7

"I believe we have reached the point where the ' clout' 8

of senior management personnel such as yourself is 9

required to proclaim the mandatory requirement 10 for operations personnel to attend the requalification 11 lectures and to impress upon them their responsibility 12 to meet the requirements of their license."

O

\\/

13 Do you see that?

14 A

Yes, I do.

15 Q

Mr. Lawyer was part of senior management 16 personnel?

17 A

Yes, he was.

18 Q

Did he have the position comparable 19 to the position that Mr. Tsaggaris held in 19787 20 A

No.

21 Q

Was there a position in existence in g

22 1978 comparable to the position Mr. Lawyer held in 23 December of '797

(

24 A

one position, that was Tsaggaris', was 25 a director.

Mr. Lawyer's position was acting manager.

1 Zechman 203

[']

x>

2 By title they are not the same.

By 3

authority, I don't know how to compare them, to be 4

ho n e s t.

I 5

Q Well, trying to compare the two positions 6

as they existed, did you feel in '79 that 7

Mr. Lawyer had more " clout" than Mr. Tsaggaris held 8

in 19787 9

MR. MacDONALD:

You are asking if he has 10 a recollection of making that comparison 11 in or around the time he wrote the memorandum?

12 MR. FISKE:

No, I am asking him to make it p!

(_,

13 now.

14 MR. MacDONALD:

I am going to object to 15 that.

Ask him what he recollects at this time.

16 A

Do I answer?

l 17 Q

Yes.

l l

18 M R'. MacDONALD:

I cbject to a present-sense 19 impression sLtting here today as an opinion.

20 I don't think you allowed your witnesses to 21 answer those types of questions.

9 l

22 If you want to ask in or around this l

23 time period -- as a matter of fact, I think I l

i

(

m.

24 will instruct him not to answer.

~

LJ l

25 Q

This memo in December of 1979 wasn't the l

l l

1 Zechman 204 O

2 first time that you had thought of invoking the " clout" 3

of higher authority in order to try to induce people 4

to attend training sessions, was it?

5 MR. MacDONALD:

Whether this was the first 6

time he can recall using the term " clout"?

7 MR. FISKE:

No, that is a colloquial term.

8 You can equate it with any other noun that 9

occurs to you.

In other words, the very simple 10 point is that this time frame in December o'f 11

'79 was not the first time it had ever occurred 12 to him that he should try to take the problem 13 of poor attendance to higher management to try 14 to get an improvement in the situation.

15 A

To the best of my recollection, this 16 isn't the only time that I have done that.

II Q

Is it still your testimony that you 10 don't recall anyone saying to Mr. Keaten in October 19 og e79 that prior to the Three Mile Island accident, 20 the problem of poor attendance was brought to the 21 attention of the plant management on a number of 22 occasions and the response to those letters was not 23 at all apparent as attendance continued to go down?

24 MR. MacDONALD:

I think you have asked 25 him that question and he gave you the answer.

1 Zechman 205 I

i

\\_/

2 MR. FISKE:

I am asking him is that still 3

his recollection, in light of the memorandum 4

that I have just shown him in December of

'79.

lI 5

THE WITNESS:

Read it back.

6 (Record read back.)

7 MR. MacDONALD:

My objection stands.

8 A

My only recollection still stands, what 9

I have testified to before, that I made him aware 10 of the attendance problem.

11 Q

The memo that you have in front of you, 12 B&W Exhibit 563, that you prepared, do you see it?

r (-

\\

x/

13 Do you have it in front of you, the December 20, '79 l

14 memo?

15 A

Yes.

16 Q

Do you see the reference to the word II

" clout" in the paragraph I read just a minute ago?

18 A

Yes, I do.

19 Q

That is in the memo written by you, 20 is that right?

l gg 21 A

That is in the memo written by me.

22 Q

You have put " clout" in quotes.

3 A

And I put " clout" in quotes.

1

/~~()

24 Q

Let me read from the Exhibit 561 25 which are the handwritten notes of the meeting you

1 Zechman 206 2

had with Mr. Keaten on October 18, 1979.

3 Immediately following -- let me read 4

two sentences in sequence.

"This attendance was 5

brought to the attention of the plant management 6

on a number of occasions.

The response to those letters was not at all apparent as attendance 8

continued to go down.

Even with the training 9

department reporting back to Redding for separation 10 purposes, et cetera, they did not seem to get any 11 clout to force the OPS department to improve 12 attendance."

8 i

)

13

\\/

I will ask you whether or not you made 14 that statement t o Mr. Keaten.

15 MR. MacDONALD:

You have asked it three 16 times and he has told you his best recollection.

17 MR.

FISKE:

I am referring to the sentence 18 that I have read for the first time which I will 19 read now, the one with the word " clout" in it.

20 It reads, from the notes of the meeting h

with Mr. Keaten, "Even with the training 22 department reporting back to Redding for 23 separation purposes, et cetera, they did not I

r^s 24

'uj) seem to get any clout to force the OPS

(

25 department to improve attendance."

1 zechman 207 2

Q Having seen your memo where you used the word " clout" in quotes, does that refresh your 3

4 recollection that you were the source of the lh information in the sentence I just read f rom Exhibit 5

6 5617 7

MR. MacDONALD:

I object.

I don't know 8

whether that was ever even said at the time 9

of an interview.

10 MR. FISKE:

You can object.

11 MR. MacDONALD:

I have just stated my 12 objection.

4 ()

13 Q

You may answer.

I 14 A

I have no recollection of the choice of i

l 15 my words at that time.

16 MR. FISKE:

I think I previously marked 17 as Exhibit 564 a document that I have yet 18 shown the witness and I will do that now.

l l

19 This is a document, a handwritten note, l

20 four pages.

g 21 Q

Do you have that in front of you?

l W

22 A

Yes.

23 Q

You may want to take a moment to read i

24 that.

25 A

I have read it.

I t

f

1 Zechman 208 p.

(

)

\\/

2 Q

That contains a memorandum to Mr. O'Hanlon, 3

handwritten memorandum to Mr. O'Hanlon from Mr.

T.

L.

4 Book, does it not, with a covering memo from Mr. O'Hanlon llk 5

to Mr.

G.

R.

Miller, Mr. Tsaggaris, Mr. Goodman, 6

yourself, and Mr. Kunder, is that correct?

7 A

Yes.

8 Q

can you tell us, looking at the first 9

page, what the date is of Mr. O'Hanlon's memo?

10 A

It looks like it's not clear.

11 Q

Some time in 1977 in any event?

12 MR. MacDONALD:

The document says what

(~m

(_)

13 it says.

Y,,ou can read as well as he can.

14 Ask the person who wrote it.

15 MR. FISKE:

I think I can talk to the 16 person who received it as well.

17 Q

You did get a copy of this, didn't you, 18 Mr. Zechman?

l l

19 A

I recall getting a copy of this.

20 Q

Some time in or about J un e o f 19777 1

21 A

That's what the letter says.

I don't 22 recollect, myself, whether it was that period of time.

23 Q

Well, this certainly came to your

~( ')

24 attention some time in 1977, did it not?

L.J 25 MR. MacDONALD:

He told you what he I

1 Zechman 209

-p, k

2 recalls.

3 MR. FISKE:

I am seeing if we can include 4

the entire year 1977 in his recollection.

h 5

A I recall receiving this document.

6 I don't recall specifically when I got it.

7 Q

In 1977 did you know an individual by the 8

name of T.

L.

Book?

9 A

Yes, I did.

10 Q

What was his position in June of 19777 11 A

I don't recall what his specific position 12 was at that time, mainly because I think he had a r~N

<k/

13 promotion somewhere in that tine frame.

14 Q

What was Mr. O'Hanlon's position at that 15 time in June of '777 16 A

I have no recollection what his specific i

l 17 title was at that time.

18 Q

I would like to direct your attention 19 to the third paragraph of the memo to Mr. O'Hanlon 20 which reads, "Like all else, the S/F and S/G's have 21 become the Godhead of 60 hours6.944444e-4 days <br />0.0167 hours <br />9.920635e-5 weeks <br />2.283e-5 months <br /> required training per 22 year."

23 Do you understand what S/F and S/G 's l

[mx,)

e 24 referred to?

l 25 MR. MacDONALD:

You want to know what he l

l

1 Zechman 210 2

unders tood when he received the memo?

3 MR. FISKE:

Yes.

4 Q

When you received the memo, did you O

5 understand what an S/F and S/G was?

6 A

I unders tood S/F.

I don't know what is 7

S/G.

8 Q

Maybe it is an S/S.

9 Did you understand this to refer to 10 shift foremen and shift supervisors?

11 A

Yes, I did.

12 Let me correct this.

I understand the t

13 S/F was shift foreman.

w 14 I don't know what the second thing is.

15 If you are implying -- I don't recall 16 what that was.

17 Q

Did you understand it when you received 0

the memo?

19 MR. MacDONALD:

That is what he is 20 testifying to.

21 Q

Are you saying right now you don't know 22 one way or the other whether you understood what 3

Mr. Book was talking about?

I n

(

)

24 MR. MacDONALD:

I don't think that was

i. s '

25 the question.

You asked specifically whether

1 Zechman 211

,r\\

()

2 he had a recollection of what those two marks 3

were when he received the memo.

4 Q

Is it your tes timony, Mr. Zechman, llI 5

that you didn't understand what Mr. Book me nt by a 6

S/S when you received this memo?

7 A

I don't know that we clearly identified 8

that as S/S.

It's not clear to me at this time 9

looking at that.

10 Q

Is it your testimony that you didn ' t 11 understand what Mr. Book meant by the initials which 12 appear at the end of that particular line at the time

()

13 you received this memo?

14 A

Are you asking what my assumption in 15 that period would have been?

16 MR. MacDONALD: Not.

Your assumption.

17 What you recall at that time, what you knew l

18 about that particular mark.

1 19 You don't want him to speculate on what 1

20 he assumed he might have thought on that particular i

l 21 mark.

i 22 Q

Any vay you can.

l 23 If you can't, we will go on to the next l

l q

24 l question.

O j

25 A

To the best of my recollection, I l

L

1 Zechman 212

, -(,)

2 understood what he meant.

3 Q

By that he meant shift supervisors, didn't 4

he?

5 A

To the best of my recollection.

6 Q

Let me read the whole paragraph and 7

then ask you whether I am correct in my understanding 8

of the sense of this paragraph, as you unders tood it 9

at the time you received it.

10 "Like all else, the shift foremen and 11 shift supervisors have become the Godhead of 60 hours6.944444e-4 days <br />0.0167 hours <br />9.920635e-5 weeks <br />2.283e-5 months <br /> 12 required training per year.

It's time to put training

(,.,)

I3 back in the training department where it belongs and.

14 in a responsible fashion.

This means more training 15 space, people and expertise.

This also means six 16 shifts for CROs, shift foremen and shift supervisors."

17 Did you understand when you received this 18 memo that Mr. Book's basic complaint was that too 19 much of the 60 hours6.944444e-4 days <br />0.0167 hours <br />9.920635e-5 weeks <br />2.283e-5 months <br /> required training per year was 20 being done under the shift foremen and shift supervisors 21 who were operations people rather than in the training I

22 department?

23 MR. Mac DONALD:

Are you asking basically 24 l

(~x what he understood when he read that paragraph

\\

'x-25 after receiving the memo?

l

n

'a }

l Zechman 213

,~.

U 2

MR. FIS KE :

I am asking if he had t he s..

3 understanding that I just read.

s

}4 MR. MacDONALD:

What he understood when

- \\-

5 he read the paragraph.

)

1

'6 MR. FISKE:

Read the question back.

3

,7 s As I see-it, it is simple.

0}

S MR. MacDONALD:

I think you are putting i

.\\

s 9., '

wordsin Mr. Book's mouth that Mr. Book may or

~

10 (l

')

may not have intended by writing the paragraph.

e 11 The easy question 'is what he understood 4

a s

l_.

when he read the paragraph.

12

~

{

Q '.

-(

lj3 g

MR. FISKE:

I will put the question the

.5

' I4 way I want to.

I think I am entitled to ask

's.t i l5 whether he drew the conclusion from this 3

4

>16 whole paragraph that I just expressed.

17 MR. MacDONALD:

I am going to object.

18 MR. FISKE:

Read the question again, please, i

If (Rec,ord read back.)

I pnderstocd'this 2(

A as one man's opinion khe time, expressing his own opinion.

21 who was upset at 9

22 Q

Yes, I understand.

But that he was i:

1h expressing the opinion which I just aaked you about rm.

... l

(

)

'2p

-in the last question.

U MR. MacDONALD:

My objection still stands.

1

l l

s 1

Zechnan 214 fm (s,)

2 Q

He was expressing the opinion that he felt nore of the 60 hours6.944444e-4 days <br />0.0167 hours <br />9.920635e-5 weeks <br />2.283e-5 months <br /> per year required 3

4 training should be done in the training department.,

lll 5

isn't that right?

6 MR. MacDONALD:

I object.

7 What your recollection was at the time.

8 A

My recollection is exactly wh at he wrote t

9 here.

I have no idea what was in his mind at any 10 time, but whatever he said here is what he said.

11 Q

Well, did you understand when he said it l

is 12 time to put training back in the training department

(~%

( )

13 where it belongs and in a responsible fashion, that 14 he thought that the 60 hours6.944444e-4 days <br />0.0167 hours <br />9.920635e-5 weeks <br />2.283e-5 months <br /> required training should 15 be done by the training department?

16 MR. MacDONALD:

Are you asking him to 1

17 interpret what was in Mr. Book's mind when he 1

1 18 wrote the memo?

l l

19 MR. FISKE:

Conclusions he drew from this 20 memo when he received it, sure.

21 MR. MacDONALD:

I object.

22 THE WITNESS:

Read the question.

23 (Record read back.)

(~~T 24 MR. MacDONALD:

I object.

LJ' l

25 If you recall anything about what was l

l

s -

h

f..

JA 1

2e chmars 215 I

(~}^

't

(/

2 said --

3 MR. FIS KE :

No.

k, 4

MR. MacDONALD:

You are asking him to

(

lh!

5 ge't[into someone!s mind.

  1. j 6

MR. FISKE:

No.

s

.s.,

g uy.

MR. MacDONALD:

You are using your 8

~

words to'say what Mr. Book thought and then 9

whether or not Mr. Zechman recalls those

{Q..

thoughts.

If you want to ask Mr. Zechman what i

,-J 11 he recalls of his understanding when he read 12 t,

that paragraph, go right ahead.

4 13 MR. FIS KE :

No.

1, Mr. MacDonald, you know,

/

14 I believe by now in a deposition like this I am 15 entitled to ask leading questions.

16 Mr. Zechman was favored by Mr. O'Hanlon 17 with a copy of this memo along with such 18 luminaries as Mr. Miller and Mr. Tsaggaris and 19 Mr. Goodman, and I assume, for the purpose of 20 my question, that he read this memo at the time 21 and tried to deal with it appropriately.

9 22 MR. MacDONALD:

You can assume whatever 23 you want.

24 MR. FIS KE :

I am simply asking him 25 whether, when he read this paragraph, he believed

1 Zechman 216

,es

(_,/

2 that Mr. Book's concern, among others, was not 3

en ugh of the 60 hours6.944444e-4 days <br />0.0167 hours <br />9.920635e-5 weeks <br />2.283e-5 months <br /> required training per 4

year was being done in the training department.

lll.

5 A

I believe that he was very confused at 6

the time and upset and was not very rational in his 7

memo, 8

Q And you reached that conclusion without 9

knowing what it was Mr. Book was trying to convey to 10 you?

11 A

What Mr. Book conveyed to me is right what 12 is written here.

No more, no less.

( )s 13 MR. MacDONALD:

He told you that three 14 times, Mr. Fiske.

15 Q

Mr. Zechman, we had some questions 16 earlier about difficulties in the effectiveness of 1

i 17 the training when there was a six-shift as opposed l

18 to five-shift program.

l l

19 Do you remember that?

20 A

Yes, I Co.

21 Q

Looking at this memo dated June 7,

1977, 22 in light of the last sentence on page 1,

does that l

l 23 refresh your recollection that by the time of this l

f"~]

24 memo, that is, June 1977, the switch had been made V

25 from six shifts to five?

1 zechman 217

(

\\

(_,/

2 THE WITNESS:

Read that question.

3 (Record read back.)

4 A

All this reflects in my mind is a statement lh 5

made by Ted Book.

I still don't have a time frame 6

when that shift was made, in my mind.

7 Q

Did you understand when you received this 8

memo that it was Mr. Book's view that in order to 9

put the required 60 hours6.944444e-4 days <br />0.0167 hours <br />9.920635e-5 weeks <br />2.283e-5 months <br /> required training per year 10 back in the training department, it would require six 11 shifts for the CRO's shift foremen and shift 12 supervisors?

r)

(

)

13 A

This is not sinking in.

I would like v

14 to take a break after this.

15 THE WITNESS:

Read it back, please.

16 (Record read back.)

l 17 A

I had no idea what he had in mind or how 18 he related those two just by th receipt of this memo.

19 Q

Did you ask him what he meant by it?

20 A

I have no recollection.

21 Q

You have no recollection of trying to find 22 out what he meant?

23 A

I have no recollection either way.

(y 24 Q

Do you see the word written in handwriting

\\_. ]

25 on the left-hand side of the page right next to l

l L

1 Zechmen 218 2

the -- right at the very bottom of page 17 3

A What is your page 17 Are you talking 4

about the cover sheet?

5 Q

The bottom of page 1 of Mr. Book's 6

memo,says, "This means more training space, people and 7

expertise.

This also means six shifts for CROs, 8

S/Fs and S/Ss."

In the left-hand margin is written a 9

word.

10 Do you see that word?

11 A

I see a word.

12 Q

can you read it?

l l

  • (

13 A

Not really.

14 Q

Doesn't it say "True"?

15 MR. MacDONALD:

He just said he can't read 16 it.

l 17 A

I said it was not clear.

18 Q

Do you recognize the handwriting in that 19 marginal notation?

r 20 A

No, I don't.

21 Q

It's not your handwriting?

22 A

It's not my handwriting.

23 Q

Is that Mr. O'Hanlon's writing?

(

24 A

I just indicated I don't know whose 25 writing that is.

1 Zechman 219

(~)x

(_

2 THE WITNESS:

Can we take a break, 3

please?

4 MR. FISKE:

Sure.

lh 5

(Recess taken.)

6 MR. FISKE:

Could you read the last quastion 7

and answer.

8 (Record read back.)

9 BY MR. FISKE:

10 Q

Directing your attention to the next 11 page, Mr. Zechman, the second paragraph, let me 12 read it into the record so we can ask you some

,e m

(_)

13 questions on it.

14 It reads, "Besides being just plain 15 frustrated over all of this, it is my opinion that 16 it is somewhat erroneous to say we have fulfilled the 17 NRC requirements when they are based on documentation 18 of subject matter supposedly covered on shift," and 19 it looks to me as though the " supposedly" may be 20 underlined.

"Many times more hours are documented 21 than were actually used for training."

22 Do you see that paragraph?

23 A

I see that paragraph.

(~N, 24 Q

Was there a procedure at Met Ed during

\\al 25 this period of time and continuing on through the time

1 Zechman 220 Q

\\s/

2 that you were in charge of the training department 3

to document the amount of time that was spent on 4

training?

llh 5

A There was an administrative document in t

6 which we recorded the hours of training and the 7

personnel in attendance.

g-Q For this period, this program that y

you described as requiring 60 hours6.944444e-4 days <br />0.0167 hours <br />9.920635e-5 weeks <br />2.283e-5 months <br /> of training per 10 year, was it necessary thatt at the end of the year, 11 the records reflect that each individual had, in 12 fact, had 60 hours6.944444e-4 days <br />0.0167 hours <br />9.920635e-5 weeks <br />2.283e-5 months <br />?

13 THE WITNESS:

Read that back.

14 (Record read back.)

15 A

It would reflect the amount of time of 16 training they had during that year.

17 Q

If the records didn't reflect 60 hours6.944444e-4 days <br />0.0167 hours <br />9.920635e-5 weeks <br />2.283e-5 months <br /> 18 for an individual, then the records would reflect a 19 deficiency. in the program for that individual?

20 A

Yes, it would.

21 Q

Did that documentation requirement 22 apply to subj ect matter that was covered on shift?

23 A

I just drew a blank on the 60-hour 24 requirement inte rp retatio n.

25 Q

Did you understand that the Nuclear

1 Zechman 221 2

Regulatory Commission had regulatory authority over 3

the training that was being conducted at Met Ed?

4 A

Would you like to expand upon that, please.

h 5

g What is unclear about it?

6 A

Your interpretation of regulatory authority 7

over the training program.

8 Q

Did you understand that in order for Met 9

Ed to keep its operating license, it had to conduct 10 a training program t hat was satisfactory to the 11 Nuclear Regulatory Commission?

12 A

I understood that.

D'\\

i

(,/

13 Q

Did you in de rs tand that part of what was 14 necessary to satisfy the Nuclear Regulatory Commission 15 was to conduct a requisite number of hours of training?

16 A

I understood it, that it was our requirement II to meet the requirements of our requalification program.

10 Q

Which includes a specified numbers of 19 hours2.199074e-4 days <br />0.00528 hours <br />3.141534e-5 weeks <br />7.2295e-6 months <br /> of training, does it not?

20 A

Yes, it does.

21 Q

Did you understand that the documentation 22 of the training that was given served to demonstrate, 23 if necessary, to the Nuclear Regulatory Commission (n) 24 that the requisite number of hours of training were, L.:

25 in fact, being conducted?

1 Zechman 222 2

A I

understood that.

3 Q

Did you understand that it would be 4

wrong to create documents which showed the training llh 5

had been done when, in fact, the training had not 6

heen done?

7

'A I understood that.

8 Q

Directing your attention to the last 9

sentence of the second paragraph of Mr. Book's 10 memorandum which reads, "Many times more hours were 11 documented than were actually used for training."

12 Do you see that?

13 A

I see that.

4 14 Q

Did you understand when you received 15 this memorandum that Mr.

Book was stating that 16 documentation had been created which falsely 17 reflected.the amount of training which had been done?

l 10 l

MR. MacDONALD:

I object to that.

19 A

I don't understand what was in Mr. Book's 20 mind at that time.

I 21 Q

Well, was it important go ahead.

l 22 A

When I read this document, including that

(

23 paragraph, it was very obvious to me there was a

24 very upset individual making a lot of rash statements 25 and not being very rational about what he was saying.

l

l 1

Zechman 223 I

)

Y/

2 Q

Well, wh'en you read this sentence in i

which he said "Many times more hours were documented 3

4 than were actually used for training," did you llh 5

understand what he meant by that sentence?

6 MR. MacDONALD:

He just told you what his 7

understanding was.

8 MR. FISKE:

No, he didn't.

9 MR. MacDONALD: You can interpret it any 10 way you want.

11 MR. FISKE:

I want an answer to that 12 question.

(~N

()

13 MR. MacDONALD:

I think the witness 14 MR. FISKE:

He can either say he un de rs to o d 15 it or not.

16 MR. MacDONALD:

He is going to give an 17 answer to the question if he hasn't already.

18 l A

I will repeat the same answer I gave you 19 a few minutes ago, sir.

20 When reading this letter, it was obvious 21 that we had an upset individual who was not being G

22 very rational about what he was saying.

23 Q

You have just said that you felt he was r-24 not being rational about what he was saying, correct?

N.N]

25 That is what you just said in your last answer?

Isn't

1 Zechman 224 O\\

2 that right?

3 Do you want your last answer read back?

4 A

No.

I 5

Q Your last answer just said you felt that 6

he was not being rational in what he was saying.

7 A

In many of the things he was saying, he 8

was not being rational.

9 Q

So in order to draw the conclusion that 10 he was not being rational, you would have to 11 understand what it was that he was saying, isn't that 12 correct?

13 MR. MacDONALD:

Understand what he said 14 in the paper?

15 Q

"Many times more hours were documented 16 than were actually used for training."

17 MR. MacDONALD:

He told you what his 18 understanding was.

19 MR. FISKE:

Read the question back 20 if Mr. Zechman is having trouble with it.

21 (Record read back.)

22 MR. MacDONALD:

I am going to object.

23 Q

You may answer.

24 A

He was saying things that were not u

25 substantiated by fact.

1 Zechman 225 CN i

2 Q

Did you personally conduct an v

3 investigation to determine whether more hours were 4

being documented than were actually used for llh 5

training?

6 A

Sir, in this period of time, if this is 7

indeed the period of time with which this was 8

received, I was group supervisor, to the best of 9

my recollection, I was group supervisor of unlicensed 10 training.

That would not have been in my charge.

11 Q

So the answer to that is that you did 12 not conduct such an investigation?

(~)J 13 A

Not to the best of my recollection.

L 14 Q

Did you ask Mr. Book what the basis was 15 for this statement in his letter?

16 A

Not to the best of my recollection.

17 Q

Did you find out from Mr. O'Hanlon, 18 Mr. Miller, Mr. Tsaggaris, Mr. Goodman, or Mr. Kunder 19 whether any of them had spoken to Mr. Book in order 20 to determine what the basis was for his allegation?

21 THE WITNESS:

Repeat that question.

22 (Record read back.)

23 A

Not to the best of my recollection.

I 24 Q

Do you know as a fact whether Mr. O'Hanlon,

\\a 25 Mr. Miller, Mr. Tsaggaris, Mr. Goodman, or Mr. Kunder

1 Zechman 226 O

2 conducted an investigation to determine whether more 3

hours were being documented than were actually used 4

for training?

5 MR. MacDONALD:

What do you mean?

6 A full-scale investigation?

7 MR. FISKE:

I will let the question stand.

O Mr. MacDONALD:

Fine.

I object.

9 A

I have no recollection what they did with 10 that information.

11 Q

As you sit here today, Mr. Zechman, you 12 were not aware of any effort that was made to 13 determine factually whether the statement made by 14 Mr. Book that "Many times more hours were documented 15 than were actually used for training" was, in fact, 16 true?

17 MR. MacDONALD:

He just told you the answer 18 to the question.

He didn't recall.

19 A

I said I don't recall.

20 Q

Then I take it you have no basis as you 21 sit here for saying this was an irrational statement?

22 A

You asked me for my opinion when I read 23 i this.

i 24 MR. MacDONALD:

He gave it to you.

I 25 l

A I said he gave no specifics in his document.

I

1 Zechman 227 O-

.2 He made an accusation of some sort, no specifics.

3 Q

You did nothing to follow it up and you 4

don't know of anything anybody else did, is that h

5 correct?

6 MR. MacDONALD:

I object.

That is not 7

what he said.

8 A

That is not what I said.

I said at 9

that period of time, my recollection, if it is 10 correct, I was a group supervisor in charge of 11 unlicensed training.

That would not have been in 12 my charge at that time.

)

13 Q

You don't know as you sit here today 14 of anything anybody else did?

15 A

I already answered that.

16 Q

You said, by the way, Mr. Book was promoted j

17 at or about the time he wrote this memo, is that 18 correct?

19 A

I said I was uncertain about that.

20 Q

Does Met Ed promote irrational people?

21 MR. MacDONALD:

Objection.

There is no 22 basis for that question.

23 MR. F IS KE :

He can answer it?

24 MR. MacDONALD:

I will instruct him

~

25 not to answer.

He is not necessarily involved

1 Zechman 228 k>

2 in whether Book is involved in a promotion, 3

whether he should or shouldn't have gotten 4

a promotion.

llh 5

If you want to ask about his recollection 6

about people that worked for him who were 7

promoted, that is fine.

8 Q

Are you familiar with the criteria for 9

promotion at Met Ed?

10 MR. MacDONALD:

People within his own 11 department who he may have been involved with?

12 MR. FISKE:

Yes, within the training (O

'x_/'

13 department.

14 A

with which I was involved, I certainly 15 have an understanding.

16 Q

Did you understand there were different 17 criteria as far as rationality was concerned in 18 other parts of tha training department other than 19 the part you were in?

20 A

Sir, I would have no part in evaluating 21 the rationality or determining the rationality of an 22 individual.

I l

23 MR. FISKE:

Let me mark as the next 24 exhibit, B&W Exhibit 565, a memorandum j

sj 25 dated September 17, 1979 from Mr.

Zechman to 1

1 Zechman 229 2

Mr.

L.

L.

Lawyer.

3

(, Memorandum dated September 17, 1979 4

from Mr. Zechman to Mr.

L.

L.

Lawyer, marked h

5 B&W Exhibit No. 565 for identification as 0

of this date.)

7 Q

I will show it to you and give you an 8

opportunity to read it.

9 Maybe I can save a little time by 10 stating to you that you are obviously welcome to 11 read the entire memorandum, but the only questions 12 I am going to ask you about it are on page 1.

13 MR. MacDONALD:

I think it would be 14 helpful that you not necessarily read every 15 word but that you familiarize yourself with 16 the document.

i 17 Q

If my suggestion means that you read 18 page 1 a little more carefully, that is perfectly 0

all right, too.

I l

20 Have you had a chance to read it all now?

g A

Yes.

I have not read the detail of the 22 last full pages.

20 Q

This is a memorandum that you wrote to 24 Mr. Lawyer in September of 1979?

25 A

It is.

1 zechman 230 i

/

2 Q

I would like to direct your attention to 3

the second paragraph,.the second sentence, which 4

reads, "It nas always been my contention that the llh 5

only way to have an effective training program" sorry.

6 "It has always been my contention that 7

the only way an effective training program can be 8

carried out is to have the sufficient staff and the 9

necessary time to prepare the material."

10 Do you see that?

11 A

I see that.

12 Q

That is a sentence that you wrote,

()

13 is that correct?

14 A

I wrote in reference to the time period 15 in which this letter was written.

16 Q

And the word " effective" is underlined.

17 Did you underline it?

18 A

I did.

19 Q

It was your view in September 1979, was 20 it not, that the only way an effective training 21 program could be carried out is to have the sufficient 22 staff and the necessary time to prepare the material?

23 A

It was my view, putting this letter into 24 perspective at this point in time, that there 25 were a lot of programs going on at this time, new

i l

1 zechman 231 2

ones, fo r example, like radiation protection personnel 3

training for the people.who were coming in.

4 Since a number of these programs was llh 5

increasing, I was making it clear that additional 6

staff would be needed to do this.

I 7

l Q

I am really not at the moment going to 8

ask a lot of questions about the details of the 9

September 1979 training program.

10 I am simply interested in the concept 11 that you expressed in this sentence that the only way 12 an effective training program can be carried out

()

13 is to have the sufficient staff and the necessary 14 time to prepare the material.

4 15 Do you understand that is what I am 16 asking about?

17 MR. MacDONALD:

He told you his 18 understanding.

19 Q

It is fair to say, isn't it, Mr. Zechman, e

j 20 that before the accident, as well as after the 21 accident, you felt that you could not have an 22 effective training program unless you had sufficient 23 staff?

24 THE WITNESS:

Repeat that.

g-25 (Record read back.1

1 zechman 232 (l

\\'v' 2

MR. MacDONALD:

Effective in the way he 3

used it in the memo and just explained it 4

as to the new program?

h 5

MR. FISKE:

Come cin, Mr. MacDonald.

6 A

His point is well taken, sir.

7 This letter was written at a point in 8

time when the staff -- when the programs were expanding 9

and so was the staff.

10 Q

Mr. Zechman, did it suddenly occur to you 11 for the first time after the accident that you 12 couldn't run a good training program unless you had n

k._,,)

13 enough people to do it right?

I simply am askin~g 14 about the basic concept, not about the particular program 15 or the particular numbers.

Just the basic concept 16 that in order to run a good program, you have to have l

17 enough people.

l 18 Is that an idea that first occurred to 19 you after the accident?

20 A

No.

I always felt that way and felt that 21 we did have that.

g 22 l

Q We will get to that in a minute.

23 But this sentence indeed says, doesn't it, 24 "It always has been my contention that the only way

(^\\;

(,/

25 an effective training program can be carried out is

1 Zechman 233 C)

( /

2 to have the sufficient staff and the necessary time 3

to prepare the material"?

Is that corrects that is 4

what the sentence says, is it not?

h 5

MR. MacDONALD:

The document says what 6

it says.

We don't need the witness to confirm 7

the written words.

8 A

What I wrote is what I wrote.

9 Q

Have I read it incorrectly?

10 A

You have not read it incorrectly.

11 Q

Isn't it a fact, Mr. Zechman, that in the 12 memorandum that Mr. Book wrote to Mr. O'Hanlon in

[

}

13 1977 he expressed the view that in order to get

\\,/

14 the 60 hours6.944444e-4 days <br />0.0167 hours <br />9.920635e-5 weeks <br />2.283e-5 months <br /> required training per year back into 15 the training department, it would require more training 16 people, among other things?

II I refer you to Exhibit 564, the bottom 18 of page 1.

19 MR. MacDONALD:

What is the question.

20 (Record read back.)

21 MR. MacDONALD:

Are you asking -- I think 22 he told you what his understanding was at the 23 time he read the document.

You are not 24 asking for him to confirm as he sits here now

-\\ -

25 what is written on a page here?

I don't think

1 Zechman 234

(

/

\\/

2 it says that.

3 Q

You understand that Mr. Book was telling 4

you that he felt there should be more training lll 5

people in the training department?

6 A

What is said in the letter is what is 7

said in the letter.

8 Q

I am asking you what you understood it 9

to mean at that time.

10 A

What it says in the letter.

11 Q

What is that?

12 A

His opinion.

/

!s_)

13 Q

That you needed more training people in 14 the training department, isn't that correct?

15 A

Whatever he said.

16 Q

I am asking you, Mr. Zechman, for your 17 understanding of it.

10 MR. MacDONALD:

What he recalls his 19 understanding was at the time.

20 MR. FISKE:

Right.

21 A

I understood that is what he was saying.

22 Q

Directing your attention to the document 23 that is B&W Exhibit 561, a handwritten document which

(~3 24 is in front of you, do you see that?

\\_/

25 A

Yes.

1 Zechman 235 2

Q It reads at the top, "TMI-2 Investigative 3

Task Force Interview, TMI, 10/18/79."

4 On the left, "0930, Training, Dick Johnson, llI 5

Marsh Beers, Frank McCormick."

6 On the right, " Bob Keaten, Ed Wallace, 7

Bob Long, Rob Williams."

8 Do you see the first sentence in the 9

memorandum of that interview, Mr. Zechman?

10 A

Ending " Training department staff"?

11 Q

Yes.

12 A

I see that first sentence.

(

13 Q

could you read that into the record, 14 please?

l l

15 A

The first sentence reads, " Greatest 16 burden seen by the training department" I don't l

l 17 know what that is.

18 Q

"MGRS."

19 A

I don't know.

l l

20 "has been the limit on the size of 21 the training department" -- and it looks like the 22 word --

" staff."

23 Q

Isn't ita fact that at that interview I

l 24 with Mr. Keaten and Mr. Wallace and the other people l

j 25 on the task force, you or Mr. Beers or Mr. McCormick

(

T v---

v-

--w w

w

-,e

-v-w y-im w-vy--

y w

,.,--gg

=c-m.*-v-

---w, y-

-Ty g

w-m---------Fr wu---e

1 Zechman 236 O( >

2 made a statement that you have just read into the 3

record?

4 A

It is true that we discussed the size lll 5

of the staff and requesting additional staff, but 6

it was put into a particular context, as I recall, 7

that is not expressed here.

8 Q

You mean you have a specific recollection 9

of putting that statement in the context that was-10 not written down by the people on the task force?

11 MR. MacDONALD:

I object.

He didn't say 12 that he recollected a statement.

He said they

(

13 discussed the subject matter.

Not that anybody 14 stated that that was so.

15 A

In the recollection of what I expressed 16 at that time, it was put in a framework that isn't 17 expressed by somebody's notes here.

18 Q

Is it y_our testimony, Mr. Zechman, that 19 at no time up to the Three Mile Island accident, 20 did you ever hold a view that you would like to have l

21 had more people in the training department?

O 22 THE WITNESS:

Read that back, please.

23 l

(Record read back.)

l

[]

24 MR. MacDONALD:

I object.

I don't think l

'\\ J 25 that is what he testified.

l

1 Zechman 237

(^%

i

/

2 MR. FISKE:

I am asking him.

3 A

I have expressed that view in the past.

4 I said my view was that our training lh 5

department has worked very hard.

We had to work 6

overtime hours at times.

It would have been helpful 7

to have additional persons so that we did not have 8

to work additional hours and as hard as we did.

9 Q

Didn't you or Mr. Beers or Mr. McCormick 10 state to Mr. Keaten and the others in October of 11 1979 that if you had been given more people prior 12 to March 28,

'79, you would have expanded the scope f^)

(_

13 of almost all training programs?

14 MR. MacDONALD:

Are you reading from some l

15 particular line on the page?

j 16 MR. FISKE:

Sure.

17 MR. MacDONALD:

Point the witness to it.

18 MR. FISKE:

Sure.

Page if that helps 19 him.

20 MR. MacDONALD:

I don ' t know if it helps 21 him.

22 MR. FISKE:

Page 2.

Notes of the Keaten 23 interview.

"If the training staff had been f~}

24 given more people (prior to March 28), they l

v.-

t f

25 would have expanded the scope of almost all i

I

1 Zechman 238 rN k_-)

2 training programs."

3 Q

Isn't it a fact that a statement to that 4

effect was made by you, Mr. Beers and Mr. McCormick?

lg 5

A I can only speak for myself.

I don't 6

recall making that statement.

7 Q

The notes further say, "This specifically 0

was directed towards increased and improved 0

classroom training for the various training programs. "

10 Is it your testimony that you didn't 11 make that statement?

12 A

I don't recognize that statement or

/~'x 1

(

)

recollect that statement or having made that statement.

14 Q

Is it your testimony that neither Mr. McCormick nor Mr. Beers made that statement?

IO A

Sir, I have no idea what statements or 17 recollect what statements Mr. Beers or Mr. McCormick 18 made.

l 19 Q

You don't recall one way or the other, 20 is that it?

21 A

I don't recall what they said, period.

22 Q

You were there the whole time they vere 23 there, isn't that correct?

04

~

,e-'S, A

I recall being called out of the room or N~)

25 going out of the room to make a phone call.

I know I

1 Zechman 239

/

)

'% )

2 there was some period of time I was not in that room.

3 g

now long were you out of the room?

4 A

I have no recollection.

h 5.

Q Was ':this a telephone call that you lef t 6

the room to place or was it a call that had come 7

in to you?

O A

I don't recollect what it was.

9 I recall leaving the room and going to 10 the telephone, but I don't recollect the reason or 11 whether it was incoming or outgoing.

12 Q

Who was the telephone conversation with?

/m.

(.,)

13

~

A I don't recall.

14 Q

How long was this interview?

15 A

I have no recollection of the length of 16 the interview any more.

17 Q

How long were you out?

0 A

I have no recollection of that time 19 period either.

20 Q

The next sentence in this memorandum 21 of the interview with.you, Mr. Zechman, Mr. Heers, 22 Mr. McCormick, is, "This content has been eroding 23 down through the years."

24

{]

Do you see that?

's 25 A

No, sir.

1 Zechman 240 2

Where are you at?

3 Q

Immediately following the sentence that 4

says, "This specifically was directed toward lll 5

increased and improved classroom training for the 6

various training programs."

7 The next sentence is, "This content 8

has been eroding down through the years."

9 Did you make that statement to Mr. Keaten 10 and the others?

11 A

Sir, I don't recognize the content I

12 don't recognize or can put into context that

()

13 sentence from any conversations that I had there.

14 g

Does that mean you don't remember whether 15 or not you made that statement?

16 A

I don't recall making that statement.

l 17 Q

Did Mr. Beers or Mr. McCormick make that 18 statement while you were there?

l 19 A

Sir, I answered a while ago.

I don't l

20 recall what statements either Mr. McCormick or El Mr. Beers made at that meeting.

S 22 g

You mean as you sit here now, you can't l

l 23 remember a single thing either one of them said at i

i I

24 the meeting even with this memorandum in front of you?

l

~s!

l 25 A

Sir, I'm trying very hard to recall that i

l

1 Zechman 241 s

2

~

moment when they were speaking. I just can't recall 3

what they -- what specifically came out from them.

4 I just can't.

I

  • 5 Q

Directing your attention to the sentence, 6

the one further down in the memorandum, "Much of what I

was stripped out of the program (especially 8

auxiliary OP) was the amount of" a couple of things' 9

crossed out

" classroom or personal training (in 10 favor of OJT) and the virtual elimination of formal 11 classroom training in the basics (heat transfer, 12 reactivity, math, shielding, et cetera)."

l

)

13 Did you make that statenent to Mr. Keaten 14 and the others at that meeting?

15 A

I don't recall making a statement 16 specifically as it is written.

I do recall discussing 17 past and present auxiliary operator training programs j

18 and changes that took place relative to them.

19 Q

But do you remember saying to Mr. Keaten 20 and the others in words or substance that much of what 21 was stripped out of the classroom training -- withdrawn.

22 Do you remember saying to Mr. Keaten in 23 words or substance that much of what was stripped out 24 of the training program was the amount of classroom 25 or personal training, in favor of on-the-job training?

1 Zochman 242

()

2 MR. MacDONALD:

He just answered the 3

question a minute ago.

4 A

I answered the question to the best I know ll 5

how.

I told you I didn't recognize the framework 6

with which -- the way it is stated here, as not my 7

recollection of how I expressed myself at that time.

8 Q

Did you say to Mr. Keaten in words or 9

substance that prior to the accident, there had been 10 a virtual elimination of formal classroom training 11 in the basics, heat transfer, reactivity, math, 12 shielding?

13 MR. MacDONALD:

Objection.

He just 14 told you what his answer was three times now.

15 Q

You may answer.

16 A

I believe I just answered that question, i

17 sir.

18 Q

Well, if you did, I have not heard the 19 answer.

20 A

I said I don't recall making the statement 21 as is written here.

9 22 Q

Did Mr. Beers or Mr. McCormick make a 23 statement to that effect?

24 A

I told you I don't recall specifically O) t

25 what Mr. Marshall Beers or McCormick said at that 1

- - ' ' - ' =

~ ~ - - ' ' '

1 Zechman 243 2

meeting.

3 Q

Do you know any reason why the person who 4

wrote these notes would have written down at this gg) 5 interview someone had stated that there was,a virtual 6

elimination of formal classroom training in the basics 7

unless it had been said by either you, Mr. Beers, or 8

Mr. McCormick?

9 MR. MacDONALD:

Objection.

You are 10 asking for his present-sense interpretation 11 of why somebody wrote things on a page that 12 he doesn't even recall seeing, and I instruct 13 him not to answer.

14 You are asking him to speculate.

15 MR. FIS KE :

Does he know a reason as 16 to why the person who took the notes of this 17 interview would write down that it had been 18 stated that there had been a virtual elimination i

19 of formal classroom training in the basics 20 unless Mr. Zechman or Mr. Beers or Mr. McCormick l

i 21 had said it.

22 If it is "No," he can say "No."

23 MR. MacDONALD:

It is a present-sense i

24 impression.

s' 25 A

For all I know, he could have written it L

1 Zechman 244 O

2 some time after the meeting.

It would be pure 3

speculation on my pa'rt.

I don't know.

4 MR. MacDONALD:

Is this a good time h

5 to break for lunch?

6 MR. FISKE:

Sure.

4 7

(Wh er eupon, at 12:45 o' clock p.m.,

a 8

lunch recess was taken.)

9 10 11 12 13 14 15 16 3

f 17 l

18 l

19 20 i

21 22 23

' O 25

1 245 t(,)

2 AFTERNOON SESSION 3

(2 : 3 0 p.m. )

4 R I CHARD W.

ZECHMAN, resumed.

lll 5

MR. FISKE:

Could we have the last question 6

and answer.

7 (Record read back.}

8 MR. FIS KE :

I would like to mark as the 9

next exhibit a memorandum to Mr. Zechman dated 10 September 13, 1979 from Mr. McCormick and 11 Mr. Beers.

12 (Memorandum to Mr. Zechman dated f;

13 September 13, 1979 from Mr. McCormick and x_/

14 Mr. Beers marked B&W Exhibit No. 566 for 15 identification as of this date.)

16 EXAMINATION (Continued) 17 BY MR. FISKE:

18 Q

Are you reading that memorandum, 19 Mr. Zechman?

20 A

Yes, I am.

I have not read it entirely.

21 Q

Did you receive that memorandum from 22 Mr. McCormick and Mr. Beers on or about September 13, 23 19797 24 A

Yes, I did.

V 25 Q

Had you received that memorandum by the

1 Zechman 246-247

'N

)

2 time you wrote the memorandum to Mr. Lawyer dated 3

September 17, 1979 which was marked as the previous 4

B&W exhibit?

gg) 5 A

Yes, I did.

6 Q

Referring to again your memorandum of 7

September 17, 1979 which is B&W Exhibit 565, referring 8

again to the first page of that document, do you have 9

that in front of you?

10 A

Yes.

11 Q

directing your attention to the 12 third paragraph and the sentence that says, "You

(~')

13 will recall in Frank Kelly's audit report of v

14 our training efforts in the pas t, his statement:

15

'It is our opinion that the subject training 16 organization, like the majority of similar 17 organizations at other nuclear power plants, is 18 understaffed and overworked.

Some evidence of l

I 19 carelessness appeared during the review and this j

20 is often the sign of overworked conditions.'"

l l

21 Do you remember writing that sentence?

22 A

Yes, I do.

l 23 Q

Did you underline " understaffed and I

24 l overworked"?

O I

s

25 A

I underlined that.

I

1 Zachman 248 2

Q The reference to Frank Kelly's audit 3

report, is that to the PSQ?

4 A

PQS.

lll 5

Q The report that you identified earlier 6

in your testimony?

7 A

Yes.

8 Q

And that was a review as your memorandum 9

indicates of your training efforts in th'e past, 10 was it not?

11 A

To the best of my recollection.

12 MR. FIS KE :

Let me mark as the next

/

13 exhibit, B&W 567, a document entitled "A

14 Pedagogical Review of Operator Training" 15 withdrawn.

16 It was marked as B&W 234.

17 Start again.

t l

18 Q

I will show you a document which has i

19 been marked as B&W Exhibit 234 entitled "A Pedagogical.

20 Review of Nuclear Operator Training at Three Mile 21 Island Nuclear Plant."

O 22 Do you have that in front of you?

23 A

Yes.

l 24 Q

Do you recognize this as the final O

25 report of the college of Engineering from Pennsylvania

~

1 Zachman 249 2

State that you referred to earlier?

3 A

I recognize this as the document --

4 pedagogical review of Penn State's -- pedagogical g

5 review of operator training at Three Mile Island.

6 I have no recollection at this time if 7

this is the final draft or a final copy of it.

O Q

But in any event, you recall that Met Ed 9

did receive this report from the College of 10 Engineering at Penn State?

11 A

I recall they received a report of that 12 title.

13 Q

And I,believe yesterday you answered 14 some questions about the circumstances generally 15 under which that report was prepared.

16 A

We discussed some things about it.

I 17 Q

In other words, we are not talking, 18 when we talk about Exhibit 234, about some report 19 that hasn't previously been identified in this 20 deposition?

21 MR. MacDONALD:

Are you asking whether 9

22 or not this report is the same cne he was asked 23 with reference to yesterday?

24 MR. FISKE:

Yes.

O.

25 A

If that is your question, the answer is

1 zochman 250

/'N 2

yes.

3 Q

Did you receive a draft of this report at 4

some point before it b e came final?

ll) 5 MR. MacDONALD:

I object.

I don't know 6

whether Mr. zechman established that as a final 7

report or whether or not it is a draft of a 8

final report.

9 Your question assumes it is.

10 Q

So there is no question about it, 11 did you receive a draft of the report by the 12 College of Engineering at Penn State before it became 13 final?

,(

14 A

To the best of my recollection, we did.

15 MR. FISKE:

Let me mark as the next 16 exhibit, which is B&W 567, a memorandum from 17 Sandy Lawyer dated January 24, 1980 to J.

10

Thorpe, subject:

"Penn State Committee - Initial 19 Draft Report," with an attachment dated January 20 22, 1980.

21 (Memorandum from Sandy Lawyer dated 22 January 24, 1980'to J.

Thorpe, subject:

23 "Penn State Committee - Initial Draft Report,"

24 with attachment dated January 22, 1980, marked 25 B&W Exhibit No. 567 for identification as of l

l l

1 Zechman 251 2

this date.)

3 Q

Do you recognize that?

4 A

I recognize a review document similar lg) 5 to this.

6 Whether this is the one I reviewed at 7

that time, I have no recollection.

O Q

Looking at Mr.

Lawyer's cover memorandum, 9

that is directed to Mr.

J.

Tho rp e, is it not?

10 A

Yes, it is.

11 Q

Who is Mr. Thrope?

12 MR. MacDONALD:

At what time?

(}

13 MR.

FIS KE :

At that time.

14 A

I'm sorry, I don't recollect his title at 15 this moment.

16 Q

He was with GPU nuclear?

i 17 A

To the bes t of my recollection.

I0 Q

You will see the list of carbon copies at the bottom.

20 A

Yes.

21 Q

Mr. Keaten we have talked about before.

9 22 What was Mr. Broughton's position at 23 that time?

24 A

To the best of my recollection, he worked O

a 25 in tech functions, and I believe he worked for

1 Zschman 252

()

2 Mr. Keaten.

3 Q

Who was D.

E.

Hetrick?

4 What was his position at that time?

ggg.

5 A

I don't recall his title.

6 Q

Mr.

R.

W.

Zechman, what was your position 7

at that time?

8 A

Supervisor of training.

9 Q

A.

M.

Dowbert?

10 A

Anne Dowbert.

I believe she was 11 administrative assistant.

I forget what her title 12 was.

13 Q

Who was O.

Smith?

14 A

NUS contractor working in our department i

15 at the time.

16 Q

Who was G.

A.

Sullivan?

i 17 A

Also a consultant working in our 18 department at that time.

I forget what company he 19 was from.

20 Q

Do you see the last paragraph of that 21 memorandum from Mr. Lawyer saying, "Please provide 9

22 me with comments on the attached document.

By copy 23 of this memo, I am also requesting similar comments 24 from the cc recipients"?

O 25 You were a ce recipient of the attachment

1 Zochman 253

(

'2 to Mr. Lawyer's memorandum?

3 A

According to the cover letter I was, yes.

4 Q

Did you understand from this memorandum, lll 5

Mr. Zechman, that you and others at Met Ed were 4

6 being invited, in effect, by the people at Penn State 7

to make whatever comments you wanted to make on the 8

draft that they had prepared and that they would take 9

those comments into account in preparing their final 10 report?

11 MR. MacDONALD:

I don't think you have 12 established whether or not he recalled receiving 13 a memorandum from Mr. Lawyer.

14 MR. FIS KE :

I think he said he did.

15 MR. MacDONALD:

Your question assumes it.

16 MR. FISKE:

Read the question again.

17 (Record read back.)

18 MR. MacDONALD:

My objection stands.

I 19 Q

You may answer.

i 20 A

It was my understanding that comments 21 were invited.

22 What was to be done with those comments, 23 I don't know that I fully understand -- well, I i

i 24 understand we were asked for comments, but I don't

[~'\\

l

\\/

25 recall what was going to be done with those comments, f

E 1

Zechman 254 2

Q Did you understand that the people at 3

Penn State were going to listen to your comments, 4

consider your comments in determining what final lll 5

conclusions they were going to reach in the final 6

report?

M' I am not asking you to testify as to whether O

you thought they were going to accept them all or 9

reject them all; simply whether you understood as 10 part of the process they were giving you an opportunity 11 to comment and they would cons 5 der those comments 12 before they made their final report.

13 A

It was my understanding at that time I4 that we were asked to prepare comments and that 15 they would review those comments, and what they 16 would do with them was unknown to me.

II Q

I would like to direct your attention 10 to the material beginning on the bottom of page 5 19 of the attachment to Mr. Lawyer's memorandum where 20 it says, "In addition to the above, Penn State has 21 the following specific comments on the GPU training 9

22 programs" 23 Do you see that sentence?

1 24 A

Yes, I do.

25 Q

I would like to then direct your i

. _ _.., ~, _. _.. - -. _. - _ _. _., _ _. - _. _. _ _ _. _ _.. _. _ _ -. _. _ _, - - -.. _ _ -. _ - - - _ - ~. - _. _ _..... _ _ _ _ _ - - _.... -. _

1 Zechman 255 (3

2

(_)

attention to the next page, paragraph C.

3 MR. MacDONALD:

Mr. Zechman, read A and 4

B first.

ggg 5

Q Have you read that?

6 A

Yes.

7 Q

The second sentence says, "For example, 8

most of the present CRO training programs (500" 9

A Where are you at?

10 Q

Paragraph C.

11 A

I'm sorry.

I didn't read C yet.

My l~a apologies.

()

Now I'm ready.

13 14 Q

"For example, most of the present CRO 15 training programs (500 hours0.00579 days <br />0.139 hours <br />8.267196e-4 weeks <br />1.9025e-4 months <br /> compared to the total 16 of 550 hours0.00637 days <br />0.153 hours <br />9.093915e-4 weeks <br />2.09275e-4 months <br />) involves self-study on the job."

17 Do you see that?

10 A

I see that statement.

19 Q

Did you express any objection to Penn 20 state that that statement was inaccurate?

21 I will withdraw that question and see if G

22 I can Instate it and move this along a little faster.

23 I will put the question again.

I 24 I will read the whole paragraph to you.

25 "A large portion of the training is accomplished e

,,-.-w-

-.-.,---,-.-n,-.

, ---, ~

a

,.m., -.

.,w,,n.--,

n,. - - -

n.,,w,,

-,,c

,_.-_w_

l 1

Zechman 256

,;()

2 through the use of on-the-job training and self-study.

3 For example, most of the present CRO training

(_500 4

hours compared to the total of 550 hours0.00637 days <br />0.153 hours <br />9.093915e-4 weeks <br />2.09275e-4 months <br />) involves lll 5

self-study on the job.

Such a technique is 6.

s atis f actory for subjects such as piping layout, 7

p ro c edures, system design descriptions and system 8

schematics.

It's completely inadequate for reactor 9

theory, health physics, and other complex technical 10 subjects.

Because of this, GPU should revise their 11 training program to include more in-depth classroom 12 instruction in these areas."

13 I have just read you paragraph C on 14 page 6.

15 Do you recall making a written comment 16 for the benefit of Penn State on that paragraph?

17 A

I recall making comments to Penn State on i

18 this report.

At this time I have no recollection i

i 19 what portions or what comments I made at that time.

i 20 MR. FISKE:

I will mark as the next f

21 exhibit, which is

568, a document entitled 22

" Comments - Penn State Review Committee 23 Report," dated February 6, 1980' to Doc Smith 24 from Richard W.

Zechman, supervisor of training.

O 25 (Doc umen t entitled " Comments Penn

1 Zechman 257 2

State Review Committee Report,"

3 dated February 6, 1980, to Doc Smith from 4

Richard W.

Zechman, supervisor of training, 5

marked B&W~ Exhibit No. 568 for identification gg 6

as of this date.)

7 Q

Have you had a chance to look at this 8

three-page document, Mr. Zechman?

9 MR. MacDONALD:

I don't think he is 10 finished.

11 Q

I don't think you really need to take 12 the time to compare this

()

13 A

It' doesn ' t balance, sir.

That is why 14 I am looking.

15 MR. MacDONALD:

Give him a few moments, 16 if you will.

17 MR. FISKE:

I have a couple of specific 18 questions I want to ask.

19 MR. MacDONALD:

He wants to take the 20 time to go through it.

Please give him that 21 opportunity.

9 22 MR. FISKE:

He can certainly take as 23 long as he wants, but I just have one or two 24 questions.

O 25 MR. MacDONALD:

That is fine.

l

1 Zechman 258

)

2 Q

You had had an opportunity to look at 3

B&W Exhibit 568, is that correct?

t 4

You have just had an opportunity to g

5 review that?

6 A

I was reviewing -- well, yes.

I scanned 7

this one and tried to match it against 567.

8 Q

Let's take Exhibit 568 and turning to 9

page 3, at the bottom, is that your signature, 10

" Richard W.

Zechman"?

11 A

That is my signature.

12 Q

And you were a supervisor of training i

i 13 on February 6, 1980?

14 A

That is correct.

15 Q

This memorandum is directed to Doc Smith, 16 is that correct?

17 A

That is correct.

18 Q

can you tell us who Doc Smith was 19 on February 6,

'80?

20 A

He was a consultant from NUS who 21 worked directly with Sandy Lawyer.

G 22 Q

Is he the same as the O.

Smith that is 23 carbon copied on Mr. Lawyer's memo to Mr. Thorpe?

24 A

That is correct.

O 25 Q

I would like to direct your attention

1 Zechman 259 2

to page 2 of Exhibit 568, item 7.

3 Do you see that?

4 A

I see item 7.

ll) 5 Q

It reads, "PSU.

Comment

'C' and

'D',

6 page 6."

7 Do you see that?

8 A

I see that.

9 Q

Then under " Comments" there is one 10 word, is there not?

11 A

There is one word.

12 Q

What is that one word?

()

13 A

" Agree."

14 Q

Mr. Zechman, I would like you to look at

)

15 the notes of Mr. Keaten which are marked Exhibit 35o.

16 I believe it's the microfilm which are the notes 17 of Mr. Keaten, of the interview October 1979 with you 18 and Mr. Beers and Mr. McCormick about which we have 19 had considerable discussion today.

20 I would like to direct your attention to 21 page 2.

The statement at the bottom of page 2 of 22 Mr. Keaten's notes as I read it is, "Recently have 23 had verbal feedback (mid-7 8-7 91 from shift supervisors 24

(~)%

that training in basics was lacking."

\\.

25 Do you see that?

--.w e---w w-ei.------m-v---.e+-------ww

.--,yy wre-e.

w w

1 Zachman 260

(~}

2 Did you say to Mr. Keaten at the meeting

%.J 3

in words or substance that the training department 4

had had verbal feedback in mid-78-79 from shift gg, 5

supervisors that training in the basics was lacking?

6 A

To the best of my recollection, I don't 7

recall making that statement.

8 Q

You don't recall saying anything then to 9

Mr. Keaten?

10 Do you recall saying anything to Mr. Keaten 11 along the lines that people in the training department 12 had received any kinds of complaints or information gg 13 from shift supervisors that they felt that training s

I L./

14 in the basics was lacking?

15 A

Not to the best of my recollection.

16 Q

Did Mr. McCormick or Mr. Beers make 17 any statements to that effect?

18 A

I think I already testified that I don't l

19 recall their statements at that meeting.

l l

20 Q

Do you see right above the notes that 21 I just read on that same page, the statement that 22 says, " Shift in emphasis was from theory to hardware 1

23 based on assumption that Navy nukes would have a l

24 basic background"?

(~h

(/

25 A

I see that.

1

1 Zachman 261 2

Q Did you say anything like that?

3 A

Not to the best of my recollection.

4 Q

Did Mr. McCormick or Mr. Beers?

5 A

I have no recollection what Mr. Beers ggg 6

or Mr. McCormick said at that meeting.

7 Q

I would like to go back, Mr. Zechman, 8

to page 6 of the attachment to Mr. Lawyer's 9'

memorandum to Mr. Thorpe which is the draft of the 10 Penn State report and direct your attention d

11 specifically to paragraph B at the top of page 6.

12 It reads, "A review of the topics covered

(~%

13 in the various training programs did not identify-(_)

(

14 any material on heat transfer and fluid flow or 15 elementary system dynamics.

To understand the 16 technical basis for the design and operation of a 17 reactor plant, one must be familiar with not only 18 reactor theory, but heat transfer and fluid flow.

19

."In addition, it's essential that one be 20 familiar with system dynamics in order to understand l

21 the expected response of a reactor plant under 22 transient conditions.

23 "Accordingly, sections covering this 24 material should be added to the CRO and SRO training l

25 programs."

1 zochman 262 i

t V(~T 2

Do you see that paragraph?

3 A

I see it.

4 Q

Did you agree with the statement, gg 5

Mr. zachman, to understand the technical basis 6

for the design and operation of a nuclear plant, one 7

must be familiar with not only reactor theory but 8

also heat transfer and fluid flow?

Y 9

A That was a long statement.

10 THE WITNESS:

Could I have that read 11 back, please?

12 (Record read back.1 13 Q

I will phrase it a different way.

- 0 14 Did you express any disagreement 15 with the statement that to understand the technical 16 basis for the design and operation of a reactor 17 plant, one must be familiar with not only reactor 18 theory but also heat transfer and fluid flow?

19 MR.

MacDONALD:

Express it to whom?

20 MR. FISKE:

To anybody.

21 THE WITNESS:

May I have that read back, 22 please, and then may I have a break.

23 (Record read back.)

1 24 i

A I don't recollect at this time what 25 comments I specifically expressed, either orally or 4

E

-_w-

,-.,..--,..,_.r,

,cm,_.-.

,-mm

.-..-,...,-...-_..,_v.-.

m.

1 zochnen 263 2

in writing, relative to that relative to what 3

you just asked.

4 Q

Wouldn't it be a pretty acceptable ggg 5

proposition for someone involved in training nuclear 6

operators that in order to understand the technical 7

basis for the design and operation of a reactor plant, 8

an operator should be familiar with not only the 9

reactor theory, but heat transfer and fluid flow?

10 A

It's my understanding they would have 11 to be familiar with the reactor theory and the 12 heat transfer associated with the characteristics and 13 operation of the reactor at a point in question.

14 Q

Similarly, looking at the next sentence 15 in small "b," wouldn't it be a perfectly acceptable 16 proposition for someone involved in training 17 nuclear operators that an operator should be familiar 18 with system dynamics in order to understand the I

19 expected response of a reactor plant under transient 20 conditions?

21 MR. MacDONALD:

His recollection at the G

22 time he read it?

23 MR. FIS KE :

Yes, in that period of time; 24 just a basic concept, that's all.

25 A

I would agree that one would have to be l

1 zochman 264 j

)

2 familiar with the system in the realms of what a 3

reactor operator needs to know, the system dynamics 4

and expected responses as taught by the vendor who ggg 5

designed that reactor.

6 Q

I am perfectly willing to let that 7

answer stand, but I don't think that is what I was 8

asking you.

9 MR. MacDONALD:

You can let any answer 10 you want stand.

11 Q

The question I was asking is, as a matter 12 of experience and someone who has been involved 13 in training nuclear operators, isn't it a perfectly 14 basic concept that an operator should be familiar 15 with system dynamics in order to be able to understand 16 the expected response of the plant under transient 17 conditions?

18 A

Sir, there are many different types of 19 reactors and many different types of expected 20 responses with those reactors.

It would have to be 21 those expected responses on a specific plant as 9

22 taught, as far as I'm concerned, as taught from the 23 manufacturers of the plant.

24 Q

What you are saying, he would have to be 25 familiar with system dynamics in order to understand r

-r--

r-c-+--+,--,u.-

ry--,. _

m m

1 Zochman 265 O) 2 the very types of expected responses you just

(

3 described?

4 MR. MacDONALD:

His answer is what it g

5 was.

6 MR. FISKE:

I don't believe it's responsive 7

to the question.

8 MR. MacDONALD:

Whatever your thought, 9

whether or not his answer is respensive, he 10 gave you an answer.

11 You want to rephrase it and put it 12 in your terminology?

13 MR. FISKE:

This is a totally different 14 question, and you know it and I know it.

15 Q

If you want to take a break because 16 you don't understand the question, I am perfectly 17 willing to do that, but you are not answering the 18 question I asked.

19 MR. MacDONALD:

He asked for a break 20 about four minutes ago before you ever asked 21 that question.

It has nothing to do with what O

22 he understood.

Don't imply he asked for a break 23 because you asked that question.

24 MR. FISKE:

Maybe the need for the break O

25 continued on to the next question.

1 Zochnan 266

(

2 MR. MacDONALD:

He asked for the break 3

five minutes ago.

4 MR. FISKE:

I don't think there is any ggg 5

dispute.

6 A

I think I answered your question.

7 Q

You have not.

I will ask it again.

8 If you want to take a break first, that is perfectly 9

all right with me.

10 A

Let's finish the question first.

11 Q

You have told us in the last two answers 12 that you gave to the question that I put that 13 different types of reactors could have different 4

14 types of responses, and you have said that you 15 thought it was important to an operator to 16 understand what those different types of responses 17 could be f ro m different plants.

18 Isn't that the substance of what you 19 just said?

20 A

Not exactly, sir, i

21 Q

Whether I state it' correctly or not' I O

22 would like to go back for the third time to the 23 sentence in paragraph "b" which says, "It is 24 essential that one be familiar with system dynamics 25 in order to understand the expected response of a

1 zochaon 267

(

2 reactor plant."

3 I am simply asking you whether you didn't o

4 agree at the time you received this memorandum with ggg 5

that basic proposition.

6 MR. MacDONALD:

He answered your question.

7 Do you want to ask it again?

I 8

A I stand firm in the way I answered that 9

question just previously, sir.

10 Q

The last sentence of this paragraph --

11 A

May I have a break, please?

12 Q

Sure.

I thought we were going to finish 13 the paragraph.

14 MR. MacDONALD:

I thought it was a 15 question.

16 MR. FISKE:

I have one last question 17 on this paragraph and then I should be through.

18 THE WITNESS:

Go ahead.

19 Q

The last sentence of the paragraph says, i

20 "Accordingly, sections covering this material should l

21 be added to the CRO and SRO training programs."

9 22 A

I see that.

23 Q

I refer you to your comments to 24 Mr. Smith ~ dated February 6, 1980 with respect to 25 comment "b"

on page 6 and ask you if I am correct

1 zochman 268 2

that your written comment with respect to that 3

entire paragraph was " Agree that heat transfer and 4

fluid flow be added to CRO/SRO training cirriculum."

lll-5 MR. MacDONALD:

I object.

You have built 6

in an assumption.

7 MR. FISKE:

Read the question again.

8 LRecord read back.)

9 Q

I will ask you, is there any other 10 comment reflected on Exhibit 568 with respect to 11 comment "b" on page 6 other than what I have just 12 read?

()

13 A

Sir --

14 Q

What is the answer?

15 A

There is something wrong with my comments 16 matching up with this document.

They don't match, sir.

17 I'm not sure that this -- they don't match.

I'm not 18 sure that these comments are reflected against this 19 draft.

20 Q

We can go through that some more after I

21 the break.

I want to be ~sure that we agree on what 9

22 the comments are because Mr. MacDonald expressed some 23 ambiguity about that.

l 24 A

Can we do that after the break, sir?

O 25 Q

Sure.

i i

1 Zechman 269

()

2 (Recess taken.)

3 MR. FISKE:

I think the record should 4

indicate that we have had a recess of half an ggg 5

hour, and now Mr. MacDonald wants to put 6

something on the record.

7 MR. MacDONALD:

I am just saying that 8

the witness is finished for the day, he informs 9

me, because he has a headache and is tired and 10 is no longer able to physically continue.

11 I apologize.

There is'nothing else I can say 12 to you.

It has happened before, and I'm sure 13 it will happen again in the course of 14 depositions.

15 It has happened to me and I understand 16 it happens to witnesses.

17 MR. FISKE:

The testimony ended at 3:35 18 when a recess was taken, and it is now 3:55.

19 MR. MacDONALD:

We can reflect I was here 20 for a half hour after lunch.

I don't want to 21 get into that on the record.

G 22 MR. FISKE:

We will resume at 9:30 23 tomorrow morning.

24 MR. MacDONALD:

If we can resume at

~

\\-

25 (continued on next page.)

i 1

zochann 270 1

2 9:30 tomorrow morning, that would be fine with us.

3 (Time noted:

3:55 p.m)

{

4 RICHARD W.

ZECHMAN

(

I 6

subscribed and sworn to before me this day 7

1 g

of

1982, i

9 t

10 11

~

12 I

13 4

i

)

14 e

15 16 I

17

+

18 s

f-19

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'[

20 21 9

22

s 24 25 I

s.

1 271 I

CERTIFICATE b

STATE OF NEW YORK

)

3y

ss.:

l COUNTY OF NEW YORK

)

4 i

I, ROBERT CAPUZELo

, a Notary l

1 Public of the State of New York, do hereby l

6 i

certify that the continued deposition of I

l RICHARD w. ZECHMAN 8

was taken before 1

me on March 11: 1982 consisting of pages 157 through_

271 I further certify that the witness had been previously sworn and that the within transcript is a true record of said testimony; That I am not connected by blood or marriage with any of the said parties nor interested directly or indirectly in the matter l'

in controversy, nor am I in the employ of any I

of the counsel.

18 IN WITNESS WHEREOF, I have hereunto set my handthis((

day of

/ i u a in

, 1982 20 li i

g l

21 nn l

~

/ k[ y h l7 f \\., /..N 23

ROBERT CAPUZELO '

C 24,l 25 i

i f

272

\\'~

INDEX WITNESS PAGE Richard W.

Zechman 159 E XHI B IT S B&W FOR IDENT.

561 Copy of a document entitled 180 "TIMI-2 Investigation Task Force Interviews, 10/16/79" 562 Notes made by the witness on a 180 yellow pad 563 Copy of a memorandum dated 198 12/2W 79 from Mr. Zechman to L.

L.

Lawyer 564 Copy of a memorandum from 199 James P.

O'Hanlon 565 Memorandum dated September 17, 229 179 from Mr. Zechman to Mr.

L.

L.

Lawyer l

566 Memorandum to Mr. Zechman dated 245 September 13, 1979 from Mr.

l McCormick and Mr. Beers I

l 567-Memorandum from Sandy Lawyer 250 dated January 24, 1980 to J.

Thorpe, subject:

"Penn State Committee Initial Draft Report" with attachment dated January 22, 1980 568 Document entitled " Comments -

256 l

Penn State Review Committee Report" dated February 6, 1980 to Doc

(

)

Smith from Richard W.

Zechman, supervisor of training.

e e

i

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