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642 UNITED STATES DISTRICT COURT f^.                   SOUTHERN DISTRICT OF NEW YORK V                     _ _ _ __________ _ _ _ _ _                              _ _ _x GENERAL PUBLIC UTILITIES CORPORATION,
642 UNITED STATES DISTRICT COURT f^.
          . ~1           JERSEY CENTRAL POWER & LIGHT COMPANY, METROPOLITAN EDISON COMPANY and                                 :
SOUTHERN DISTRICT OF NEW YORK V
PENNSYLVANIA ELECTRIC COMPANY, Plaintiffs,                   80 CIV. 1683
_ _ _x GENERAL PUBLIC UTILITIES CORPORATION,
:      (R.O.)
. ~1 JERSEY CENTRAL POWER & LIGHT COMPANY, METROPOLITAN EDISON COMPANY and PENNSYLVANIA ELECTRIC COMPANY, Plaintiffs, 80 CIV. 1683 (R.O.)
                                                        -against-THE BABCOCK & WILCOX COMPANY and J. RAY McDERMOTT & CO.,               INC.,                 :
-against-THE BABCOCK & WILCOX COMPANY and J.
Defendants.               :
RAY McDERMOTT & CO.,
INC.,
Defendants.
_ _ _ _x Continued deposition of RICHARD W.
_ _ _ _x Continued deposition of RICHARD W.
ZECHMAN, taken by De fendants , pursuant to adjournment, at the offices of Davis, Polk
ZECHMAN, taken by De fendants, pursuant to adjournment, at the offices of Davis, Polk
(
(
                                          & Wardwell, Esgs., One Chase Manhattan Plaza, New York, New York, on Friday, March 26, 1982, at 9:45         a.m.,   before Catherine Cook,a Shorthand Reporter and Notary Public of the State of New York.
& Wardwell, Esgs., One Chase Manhattan Plaza, New York, New York, on Friday, March 26, 1982, at 9:45 a.m.,
C d_                                                                                   . -
before Catherine Cook,a Shorthand Reporter and Notary Public of the State of New York.
                                                                                              /
C d_
B306290749             gg                                         DOYLE REPORTING. INC.
/
PDR ADOCK 0           PDR                                         CERTIFIED STENOTYPE REPORTERS 369 LExlNGTCN AVENUE WALTER SHAPIRO, C.S.R.                                               NEW Yon x, N.Y. 10o17 CHARLES SHAPIRO, C.S.R.                                           TELEPMoNE 212 - 867 0220
B306290749 gg DOYLE REPORTING. INC.
PDR ADOCK 0 PDR CERTIFIED STENOTYPE REPORTERS 369 LExlNGTCN AVENUE WALTER SHAPIRO, C.S.R.
NEW Yon x, N.Y.
10o17 CHARLES SHAPIRO, C.S.R.
TELEPMoNE 212 - 867 0220


g                                                         643 2 Appe arance s :
g 643 2
Appe arance s :
3 4
3 4
KAYE, SCHOL ER     FIERMAN, HAYS & HANDLER, ESQS.,
KAYE, SCHOL ER FIERMAN, HAYS & HANDLER, ESQS.,
Attorneys for Plaintiffs, G   5 425 Park Avenue, 6               New York, New York 7       BY:     ANDREW MacDONALD, ESQ.,
5 Attorneys for Plaintiffs, G
425 Park Avenue, 6
New York, New York 7
BY:
ANDREW MacDONALD, ESQ.,
of Counsel 8
of Counsel 8
9 10       DAVIS POLK & WARDWELL, ESQS.,
9 10 DAVIS POLK & WARDWELL, ESQS.,
Attorneys for Defendants, 11                 One Chase Manhattan Plaza, New York, New York 12 BY:     ROBERT B. FISKE, ESQ.
Attorneys for Defendants, 11 One Chase Manhattan Plaza, New York, New York 12 BY:
13               -
ROBERT B.
and Os                       KAREN E. WAGNER, ESQ.,
FISKE, ESQ.
14                                               of counsel 15 16 ALSO PRESENT:
and 13 Os KAREN E.
17                               -
WAGNER, ESQ.,
18                 SUSAN HANSON 19 20 o0o 21 0 22 23 24 25
14 of counsel 15 16 ALSO PRESENT:
17 18 SUSAN HANSON 19 20 o0o 21 0
22 23 24 25


1 644
644 1
    / a.
/ a.
(     )       2 RI CHARD             W .      Z ECH M A N     ,      h'aving A'
(
3         been previously duly sworn, resumed and testified 4         further as follows:
)
ggg  5 EXAMINATION (Continued) 6 BY MR. FISKE:
2 RI CHARD W
7         Q     Mr. Zechman, you realize that you continue 8 under oath?
Z ECH M A N h'aving A'
9         A     I do.
3 been previously duly sworn, resumed and testified 4
10         Q     Near the end of your testimony yesterday, 11 you mentioned something that you referred to as a 12 pressure / temperature envelope.
further as follows:
(~'S         13         A     Yes, sir, I did.
5 EXAMINATION (Continued) ggg 6
V 14         Q     Could you tell us what the pressure /
BY MR. FISKE:
15 temperature envelope is?
7 Q
16         A     A pressure / temperature envelope is an 17 operating envelope which defines the boundaries of 18 operations of the reactor during operations.
Mr. Zechman, you realize that you continue 8
l 19               You say " defines the boundaries"?
under oath?
Q l
9 A
20         A     Pressure / temperature boundaries.
I do.
21         Q     Was your understanding of that envelope O   22 that there is a fixed pressure and a fixed temperature 23 or is it a floating, movable pressure / temperature 24 relationship?
10 Q
      ,r m 5     )
Near the end of your testimony yesterday, 11 you mentioned something that you referred to as a 12 pressure / temperature envelope.
      \d         25         A     It 's a movable temperature relationship.
(~'S 13 A
Yes, sir, I did.
V 14 Q
Could you tell us what the pressure /
15 temperature envelope is?
16 A
A pressure / temperature envelope is an 17 operating envelope which defines the boundaries of 18 operations of the reactor during operations.
l 19 Q
You say " defines the boundaries"?
l 20 A
Pressure / temperature boundaries.
21 Q
Was your understanding of that envelope O
22 that there is a fixed pressure and a fixed temperature 23 or is it a floating, movable pressure / temperature 24 relationship?
,r m 5
)
\\d 25 A
It 's a movable temperature relationship.


1                         Zochman                     645 You have to stay within the boundaries of those
1 Zochman 645
('))
('))
s-2 3 different points of operations.
2 You have to stay within the boundaries of those s-3 different points of operations.
4         Q     What did you understand would happen if gg      5 you did not stay within the boundaries?
4 Q
6         A     To the.best of my recollection, that 7 pressure / temperature envelope was always based on a 8 DNBR ratic. You maintain a DNBR ratio no greater than 9 1.3.
What did you understand would happen if 5
10         Q     What is DNBR ratio?
you did not stay within the boundaries?
11         A     Heat flux which would cause departure from 12 nuclear boiling divided by the actual heat flux.
gg 6
('N       13         Q     What is a departure from nuclear boiling?
A To the.best of my recollection, that 7
14         A     Departure from nuclear boiling is a heat 15 transfer transition from nuclear boiling into what 16 could eventually lead to film boiling.
pressure / temperature envelope was always based on a 8
17         Q     So is it correct that if one function of 18 the pressure / temperature envelope was to prevent either 19 temperature increasing or pressure decreasing to the 20 point where boiling would occur?
DNBR ratic.
21         A     As I said, the DNBR ratio was again in O     22 relationship to a surface phenomenon. It was always 23 related to the heat transfer characteristics or modes 54 of heat transfer from fuel assemblies.
You maintain a DNBR ratio no greater than 9
25         Q     This is the type of surface boiling that
1.3.
10 Q
What is DNBR ratio?
11 A
Heat flux which would cause departure from 12 nuclear boiling divided by the actual heat flux.
('N 13 Q
What is a departure from nuclear boiling?
14 A
Departure from nuclear boiling is a heat 15 transfer transition from nuclear boiling into what 16 could eventually lead to film boiling.
17 Q
So is it correct that if one function of 18 the pressure / temperature envelope was to prevent either 19 temperature increasing or pressure decreasing to the 20 point where boiling would occur?
21 A
As I said, the DNBR ratio was again in O
22 relationship to a surface phenomenon.
It was always 23 related to the heat transfer characteristics or modes 54 of heat transfer from fuel assemblies.
25 Q
This is the type of surface boiling that


1                         ZochEnn                     646 2 you described yesterday that could cause fuel damage?
1 ZochEnn 646 2
3 A     Yes, sir, I did.
you described yesterday that could cause fuel damage?
4       Q     So is it fair to say that one purpose of 5 staying within the pressure / temperature envelope was g
A Yes, sir, I did.
6 to prevent fuel   damage?
3 4
7       A     Yes, I think that's fair. Yes, sir.
Q So is it fair to say that one purpose of 5
8       Q     Also the phrase has been used in this 9 deposition " bulk boiling."
staying within the pressure / temperature envelope was g
r 10       A     Yes, sir.
6 to prevent fuel damage?
11       Q     And what is bulk boiling?
7 A
12       A     Bulk boiling, as I understand it   --
Yes, I think that's fair.
13       Q     I am asking your understanding before the 14 accident.
Yes, sir.
15       A     Before the accident?
8 Q
16       Q     Yes.
Also the phrase has been used in this 9
17       A     To the best of my recollection, I don't 18 recall the use of the term prior to the accident.
deposition " bulk boiling."
19 I do recall the term after the accident. There was a 20 lot of discussion about RCS bulk boiling.
10 A
21       Q     what is bulk boiling as you understood
Yes, sir.
,    22 the meaning of that term after the accident?
r 11 Q
23       A     Well, as I understand it after the 24 accident, it was referred to a saturated RCS system 25 which you had bulk boiling in the RCS system.
And what is bulk boiling?
12 A
Bulk boiling, as I understand it 13 Q
I am asking your understanding before the 14 accident.
15 A
Before the accident?
16 Q
Yes.
17 A
To the best of my recollection, I don't 18 recall the use of the term prior to the accident.
19 I do recall the term after the accident.
There was a 20 lot of discussion about RCS bulk boiling.
21 Q
what is bulk boiling as you understood 22 the meaning of that term after the accident?
23 A
Well, as I understand it after the 24 accident, it was referred to a saturated RCS system 25 which you had bulk boiling in the RCS system.


1                           Zochman                                 647 2             What is bulk boiling?
1 Zochman 647
(                          Q 3           A I don't recall how the term was exactly 4 defined after the accident.
(
ggg       5           Q As you have used it in the deposition, 6 what did you mean by bulk boiling?
2 Q
7           A As I believe I understand it post-accident 8 in that terminology, it referred to -- my terminology 9 or understanding was bulk boiling referred to a 10 saturated RCS system, where you had a lot of boiling 11 occurring -- rapid boiling occurring in the RCS system.
What is bulk boiling?
12           Q Just going back to basics for a moment, 13 Mr. Zechman. You have described earlier in the (U~}
3 A
14 deposition the temperatures of the water in the primary 15 system as you understood them before the accident.
I don't recall how the term was exactly 4
16           A Yes.
defined after the accident.
17               What were those temperatures again?
ggg 5
Q 18           A Full power operation?
Q As you have used it in the deposition, 6
19               Yes.
what did you mean by bulk boiling?
Q 20           A About 600 degrees TH, about 550, about 575 21 in there, average.
7 A
22           Q What atmospheric   --
As I believe I understand it post-accident 8
at what temperature 23 does water boil at atmospheric pressure?
in that terminology, it referred to -- my terminology 9
24           A 212 degrees, i
or understanding was bulk boiling referred to a 10 saturated RCS system, where you had a lot of boiling 11 occurring -- rapid boiling occurring in the RCS system.
l 25           Q What was your understanding of what kept 1
12 Q
Just going back to basics for a moment, (U~}
13 Mr. Zechman.
You have described earlier in the 14 deposition the temperatures of the water in the primary 15 system as you understood them before the accident.
16 A
Yes.
17 Q
What were those temperatures again?
18 A
Full power operation?
19 Q
Yes.
20 A
About 600 degrees TH, about 550, about 575 21 in there, average.
22 Q
What atmospheric at what temperature 23 does water boil at atmospheric pressure?
24 A
212 degrees, i
l 25 Q
What was your understanding of what kept 1
i l
i l


1                       Zochnan                     648 the water in the primary system that was either at
1 Zochnan 648
(      2 3  550 degrees or higher from boiling?
(
4         A   What was it that kept that from boiling?
2 the water in the primary system that was either at 3
g  5         Q   Yes.
550 degrees or higher from boiling?
6         A   I understand we have a pressurized water 1
4 A
7 reactor. That the reactor.was at very high pressures 8 to prevent thats 9         Q   At what pressure was this water in the 10 primary system kept during normal operations?
What was it that kept that from boiling?
11         A   About 2000 psig.
5 Q
12         Q   Going back to basics again, I think you
Yes.
        ~
g 6
13 testified that you understood that if that pressure 14 dropped far enough, you could have boiling in the 15 primary system?
A I understand we have a pressurized water 1
16         A   I said from a theoretical standpoing, I
7 reactor.
(           17 understood that.
That the reactor.was at very high pressures 8
18         Q   Was that theoretical concept explained 19 in your basic training that you gave the operators?
to prevent thats 9
l           20         A   To the best of my recollection, that i
Q At what pressure was this water in the 10 primary system kept during normal operations?
I 21 theoretical understanding was known.
11 A
O 22         Q   Were the operators trained that they should l
About 2000 psig.
23 not operate the reactor in conditions that you have l
12 Q
24 described as bulk boiling?
Going back to basics again, I think you
(~\
~
G     25         A   As I testified earlier, that never occurred l
13 testified that you understood that if that pressure 14 dropped far enough, you could have boiling in the 15 primary system?
16 A
I said from a theoretical standpoing, I
(
17 understood that.
18 Q
Was that theoretical concept explained 19 in your basic training that you gave the operators?
l 20 A
To the best of my recollection, that i
I 21 theoretical understanding was known.
O 22 Q
Were the operators trained that they should l
23 not operate the reactor in conditions that you have l
24 described as bulk boiling?
(~\\
G 25 A
As I testified earlier, that never occurred l
l
l


1                           zochman                   649 2   to us and, to the best of my recollection, that subject 3   wasn't approached.
1 zochman 649 2
4           Q     You mean you never at any time in any of ggg     5   the. training that you gave your operators explained 6   to them that it was important not to let the water 7   in the primary system start to boil?
to us and, to the best of my recollection, that subject 3
8         A     As I testified earlier, it just didn't 9   occur -- that didn't occur. That didn't occur to me.
wasn't approached.
10         Q     Going back to the description that you 11   gave earlier,of the way the whole reactor system 12     operates, it is correct, is it not, that there is a hot 13     leg and a cold leg in the primary system?
4 Q
14           A     Yes.
You mean you never at any time in any of ggg 5
15         Q     When the water is in pipes which go through l
the. training that you gave your operators explained 6
16   the core, correct?
to them that it was important not to let the water 7
17         A     Yes.       -
in the primary system start to boil?
18           Q     When they go through the core, they are 19     heated up, the water is heated up to approximately 600
8 A
              '20     degrees Fahrenheit?
As I testified earlier, it just didn't 9
21           A     That's right.
occur -- that didn't occur.
l              22           Q     Now it's in the so-called hot leg?
That didn't occur to me.
l 23           A     Yes.
10 Q
l 24           Q     The water goes in these same pipes through N         25     water in the steam generator, correct?
Going back to the description that you 11 gave earlier,of the way the whole reactor system 12 operates, it is correct, is it not, that there is a hot 13 leg and a cold leg in the primary system?
14 A
Yes.
15 Q
When the water is in pipes which go through l
16 the core, correct?
17 A
Yes.
18 Q
When they go through the core, they are 19 heated up, the water is heated up to approximately 600
'20 degrees Fahrenheit?
21 A
That's right.
22 Q
Now it's in the so-called hot leg?
l l
23 A
Yes.
l 24 Q
The water goes in these same pipes through N
25 water in the steam generator, correct?
l h
l h


1                           Zochman                       650 2       A     Yes.
1 Zochman 650 2
3       Q     In that process, heat is transferred from 4 the primary system water to the secondary system, 5 correct?
A Yes.
6       A     Yes, tha t 's correct.
3 Q
7       Q     As a result of that, when the water comes 8 out of the steam generator --
In that process, heat is transferred from 4
9       A     on the secondary side.
the primary system water to the secondary system, 5
10       Q     -- on the secondary side, it has now been 11 cooled to 550 degrees, correct?
correct?
12         A     We are back to the primary now.
6 A
13         Q     I am talking a bout the primary all along.
Yes, tha t 's correct.
14         A     We were jumping back and forth.       You are 15 talking about heat being transferred to the secondary?
7 Q
16         Q     Maybe I didn't make myself clear.       The 17 water comes out of the core at 600 degrees in the hot 18 leg, correct?
As a result of that, when the water comes 8
I l           19         A     Yes, sir.
out of the steam generator --
l l           20         Q     It stays in those same pipes and goes l
9 A
l           21 through the steam generator, is that correct?
on the secondary side.
22         A     Th at 's correct.
10 Q
23         Q     In that process, heat is transferred from l
-- on the secondary side, it has now been 11 cooled to 550 degrees, correct?
24 the primary system water to the water in the steam
12 A
;          25 generator, correct?
We are back to the primary now.
13 Q
I am talking a bout the primary all along.
14 A
We were jumping back and forth.
You are 15 talking about heat being transferred to the secondary?
16 Q
Maybe I didn't make myself clear.
The 17 water comes out of the core at 600 degrees in the hot 18 leg, correct?
I l
19 A
Yes, sir.
l l
20 Q
It stays in those same pipes and goes l
l 21 through the steam generator, is that correct?
22 A
Th at 's correct.
23 Q
In that process, heat is transferred from l
24 the primary system water to the water in the steam 25 generator, correct?
I i
I i
i . - _ _ _    -            - _ - . _      - _. - _.    - _ -. . _
i.


1                         Sochann                   651 "D       2       A     To the secondary side, yes.
1 Sochann 651 "D
(G 3       Q     After the water in the primary system 4 goes through the steam generator, as a result of the 5 heat transfer process that you have just described ggg 6 the water in the primary syster which is still in the 7 same pipes is cooled down to about 550 degrees, correct?
2 A
8       A     500-something degrees, yes.
To the secondary side, yes.
9       Q   Now, it's in the so-called cold leg, 10 correct?
(G 3
11       A   Yes, sir.
Q After the water in the primary system 4
12         Q   Then it goes through the cold leg and 13 reenters the core?
goes through the steam generator, as a result of the 5
14         A   That's correct.
heat transfer process that you have just described ggg 6
15         Q   In that process the water is heated up 16 again to 600 degrees, is that correct?
the water in the primary syster which is still in the 7
17         A   That's correct.
same pipes is cooled down to about 550 degrees, correct?
18         Q   In that same process, that is going 19 through the core, the water performs a function 20 of cooling the core, does it not?
8 A
21         A   That's correct. It serves more than just O   22 that function.
500-something degrees, yes.
23         Q   one of the functions it serves is keeping 24 the core cool?
9 Q
Now, it's in the so-called cold leg, 10 correct?
11 A
Yes, sir.
12 Q
Then it goes through the cold leg and 13 reenters the core?
14 A
That's correct.
15 Q
In that process the water is heated up 16 again to 600 degrees, is that correct?
17 A
That's correct.
18 Q
In that same process, that is going 19 through the core, the water performs a function 20 of cooling the core, does it not?
21 A
That's correct.
It serves more than just O
22 that function.
23 Q
one of the functions it serves is keeping 24 the core cool?
O
O
    \r/     25         A   Yes.
\\r/
25 A
Yes.
l
l


                                        -_                              _=   _ _ - -    ___ __  -
_=
1                               Zochman                       652 2             Q       Did you understand that it was important 3   from a safety point of view to keep the core cool?
1 Zochman 652 2
4             A       I understood that as long as I maintained 5     adequate RCS inventory, that the core stayed cool.
Q Did you understand that it was important 3
ggg 6             Q       And that it was very important for safety 7     reasons to keep the core cool, is that correct?
from a safety point of view to keep the core cool?
8             A       It was one of the functions -- I understand 9     it was one of the functions of the coolant         --
4 A
yes, sir.
I understood that as long as I maintained 5
10               Q       By "yes, sir," you mean you did understand 11       that cooling the core was important for safety reasons?
adequate RCS inventory, that the core stayed cool.
12               A       Yes, I understood that.
ggg 6
3                  13               Q       You understood that if the core was not O
Q And that it was very important for safety 7
14       adequately cooled, that could lead to fuel damage, 15       correct?
reasons to keep the core cool, is that correct?
16               A       I understood there were conditions in 17       which you could have localized flux such that you 18       could have fuel damage.
8 A
l                       19               Q       For the moment I am not asking you by what l                       20       particular mechanisms the core would be failed to be l                       21       cooled. I am simply asking you didn't you understand 22       as a basic concept of running a nuclear reactor that if l
It was one of the functions -- I understand 9
23       the core was not cooled, that could lead to core damage?
it was one of the functions of the coolant yes, sir.
24                 A       I already testified that it never occurred S_/                 25       to me that conditions were such that the core wouldn't
10 Q
By "yes, sir," you mean you did understand 11 that cooling the core was important for safety reasons?
12 A
Yes, I understood that.
13 Q
You understood that if the core was not 3
O 14 adequately cooled, that could lead to fuel damage, 15 correct?
16 A
I understood there were conditions in 17 which you could have localized flux such that you 18 could have fuel damage.
l 19 Q
For the moment I am not asking you by what l
20 particular mechanisms the core would be failed to be l
21 cooled.
I am simply asking you didn't you understand 22 as a basic concept of running a nuclear reactor that if l
23 the core was not cooled, that could lead to core damage?
24 A
I already testified that it never occurred S_/
25 to me that conditions were such that the core wouldn't


2               1                                                   Zochacn                   653 2             he covered, because we were focusing on maintaining 3             the pressure --
653 2
4                         Q           Why did you understand that it was 5             important to keep the core covered?
1 Zochacn 2
gg 6                         A           For several reasons. One, as you mentioned, 7             the coolant kept the core cool.
he covered, because we were focusing on maintaining 3
8                                     Second of all, it was a moderator for the 9             neutron reaction.
the pressure --
10                           Q           Why was it important to keep the core 11             cool?
4 Q
12                           A           Because if you didn't have the core cooled, 13             you could have core damage, fuel damage.
Why did you understand that it was 5
14                           Q           And as you just said a minute ago that one 15             function of having the water in the primary system 16             circul ate through the core was to perform a core
important to keep the core covered?
                , 17               cooling -- was to keep the core cooling, is that 18             correct?
gg 6
19                           A           That was one og its functions.
A For several reasons.
20                           Q           You also knew, did you not, before the
One, as you mentioned, 7
!                  21             Three Mile Island accident, that if the water in the 22             reactor or coolant system boiled into steam, that it 23             would not be able to effectively keep the core cooled?
the coolant kept the core cool.
24                           A           I told you that that never occurred to me 25             prior to the accident.
8 Second of all, it was a moderator for the 9
__,7         _ _ , . , ,      _ . - .  . - _ . _  _ . . _ _ _ _.
neutron reaction.
10 Q
Why was it important to keep the core 11 cool?
12 A
Because if you didn't have the core cooled, 13 you could have core damage, fuel damage.
14 Q
And as you just said a minute ago that one 15 function of having the water in the primary system 16 circul ate through the core was to perform a core
, 17 cooling -- was to keep the core cooling, is that 18 correct?
19 A
That was one og its functions.
20 Q
You also knew, did you not, before the 21 Three Mile Island accident, that if the water in the 22 reactor or coolant system boiled into steam, that it 23 would not be able to effectively keep the core cooled?
24 A
I told you that that never occurred to me 25 prior to the accident.
__,7


1                                                   Zochman                                               654
654 1
(}                 2             Q                 You mean it never occurred to you that                                   --
Zochman
3                                MR. FISKE:         Withdrawn.
(}
4             Q                 It never occurred to you that if pressure 5     dropped far enough, that could cause boiling in the ggg 6     primary system?
2 Q
7             A                 I told you from a theoretical point, 8     I understood that.
You mean it never occurred to you that 3
9             Q                 Let's keep it on a theoretical point of 10     view.
MR. FISKE:
11                                 Did you also consider as a theoretical point 12     of view that if the water in the primary system did i
Withdrawn.
13     boil as a result of a drop in pressure that that could 1
4 Q
14     impede its effectiveness to keep the core cooled?
It never occurred to you that if pressure 5
15             A                 Repeat the question, please.
dropped far enough, that could cause boiling in the ggg 6
16                                 (Question read.)
primary system?
17             A                 And you are talking about prior to the i
7 A
i                         18     accident?
I told you from a theoretical point, 8
l 19             Q                 Yes.
I understood that.
20             A                 I don't recall that occurring to me at that l                         21     time.
9 Q
h         22                                MR. FISKE:          Let me show you a document
Let's keep it on a theoretical point of 10 view.
11 Did you also consider as a theoretical point 12 of view that if the water in the primary system did i
13 boil as a result of a drop in pressure that that could 1
14 impede its effectiveness to keep the core cooled?
15 A
Repeat the question, please.
16 (Question read.)
17 A
And you are talking about prior to the i
i 18 accident?
l 19 Q
Yes.
20 A
I don't recall that occurring to me at that l
21 time.
h
(
(
23             which we will mark as B&W Exhibit 571.                                       This is r
22 MR. FISKE:
24               a collection of pages captioned " Nuclear Energy l
Let me show you a document 23 which we will mark as B&W Exhibit 571.
This is r
24 a collection of pages captioned " Nuclear Energy l
l
l
      \-
\\-
25             Training Instructor's Guide Plant Performance."
25 Training Instructor's Guide Plant Performance."


1                                         zochacn                                                 655
1 zochacn 655
()           2       Q           I will show you this document and ask you 3 whethe r this was part of the training materials used 4 at Met Ed?
()
5       A           Yes, we got this somewhere around 1978 or ggg 6 so.
2 Q
7       Q           Let me show :'ou two pages, Mr. Zechman, 8 from this document.                   First is page Q-1 which has the 9 number 1083-0123, question No. 4 reads, "Is boiling 10 in the PWR core expected?                                     If so, what are the 11 limitations on the amount?"
I will show you this document and ask you 3
12                     And the next p .g o is QS-1, 1083-0125,
whethe r this was part of the training materials used 4
(~S         13 captioned " Quiz solutions."                                     No. 4 reads, "Yes.         There
at Met Ed?
    \_)
5 A
14 is some boiling in the hot channels, but it must be 15 limited so that there will be no steam in the upper 16 plenum."
Yes, we got this somewhere around 1978 or ggg 6
17                     Do you see that?
so.
18       A           Yes.
7 Q
19       Q           What is the upper plenum?
Let me show :'ou two pages, Mr. Zechman, 8
20                     MR. MacDONALD:                               His understanding before 21         the accident?
from this document.
O     22       Q           Did you understand before the accident 23 what the upper plenum was?
First is page Q-1 which has the 9
l               24       A           Top of the reactor vessel above the core.
number 1083-0123, question No. 4 reads, "Is boiling 10 in the PWR core expected?
f'''       25                     Part of the primary system outside the Q
If so, what are the 11 limitations on the amount?"
I i
12 And the next p.g o is QS-1, 1083-0125,
l
(~S 13 captioned " Quiz solutions."
No. 4 reads, "Yes.
There
\\_)
14 is some boiling in the hot channels, but it must be 15 limited so that there will be no steam in the upper 16 plenum."
17 Do you see that?
18 A
Yes.
19 Q
What is the upper plenum?
20 MR. MacDONALD:
His understanding before 21 the accident?
O 22 Q
Did you understand before the accident 23 what the upper plenum was?
l 24 A
Top of the reactor vessel above the core.
f'''
25 Q
Part of the primary system outside the I
i l


l 1                             zochman                         656 t'                                                      '
l 1
(s            2 pressurizer, right?
zochman 656 t'
3         A     'No . What I am talking about,is the top 4 of the vessel, above that       --
(
that par [of it, above              f the core,                                                              ''
2 pressurizer, right?
gg)   5                                                                       i 6         Q     In other words, not part of the primary
s 3
                                                                                ?
A
7 syste'n through which the water circulates in the manner 8 you have just described?                       ,'      '                  '
'No.
t 9         A'     For example,-t'he steam generator or the'             '{
What I am talking about,is the top par [of it, above 4
10                                                           '
of the vessel, above that that f
pressurizer, you are referring to, sir.
gg) 5 the core, i
11         Q     Yes.
6 Q
12         A     No.
In other words, not part of the primary
?
7 syste'n through which the water circulates in the manner 8
you have just described?
t 9
A' For example,-t'he steam generator or the'
'{
10 pressurizer, you are referring to, sir.
11 Q
Yes.
12 A
No.
[~}
[~}
13 Q
In other words, it is not?
(>
(>
13          Q      In other words, it is not?
14 A
14         A     It is not.
It is not.
15         Q     Why did you understand it'was important 16   that there be no steam in the upper plenum?
15 Q
17         A     I. don''t r ecall seelig those questio5s or 18   even using those.             '
Why did you understand it'was important 16 that there be no steam in the upper plenum?
19         Q     Did you understanding that it was important 20   that there not be steam in the upper plenum?
17 A
21         A     I never considered that, sir.
I. don''t r ecall seelig those questio5s or 18 even using those.
9   22         Q     Let me show you another set of questions
19 Q
                                                                                    .e 23   and answ'ers from the same exhibit.       The question is 24   on page E.2-6,     1083-0148, question 17.
Did you understanding that it was important 20 that there not be steam in the upper plenum?
      \
21 A
V(~s 25                 "While reading an analysis of a
I never considered that, sir.
9 22 Q
Let me show you another set of questions
.e 23 and answ'ers from the same exhibit.
The question is 24 on page E.2-6, 1083-0148, question 17.
V(~s
\\
25 "While reading an analysis of a x


1                               Zochnan                                                 657
1 Zochnan 657
()       2     hypothetical accident you find this statement, 'Then 3     there is a rapid drop in reactor pressure and the 4     DNBR drops to less than   1,' what would you expect ggg 5     the consequences of this to be?"
()
6                   And then on page ES2.B, 1083-0151, the 7     answer is, " Expect film boiling to occur and probable 8     fuel damage."                                                                               ,
2 hypothetical accident you find this statement, 'Then 3
9                   Do you see the question and the suggested
there is a rapid drop in reactor pressure and the 4
  .                                                                                                            i 10     solution?                                                   ,
DNBR drops to less than 1,' what would you expect ggg 5
11   _
the consequences of this to be?"
A    I dc.                                                                                 ;
6 And then on page ES2.B, 1083-0151, the 7
I 12 .i         Q   Gn it is correct, is it not, that you r.
answer is, " Expect film boiling to occur and probable 8
il                                                                                                    .
fuel damage."
f'h s/
9 Do you see the question and the suggested i
M  pl l
10 solution?
I underst ood that a rsnid drop 1.n reactor prassytre c4uld i           14     produce film boiling which could cause fuel daraqs?
11 A
15             A   That is not correct.                   I already told you                             <
I dc.
16     that that never occurred to me.
I 12
17             Q   Did you ever look at this material?
.i Q
18             A   We haven't scanned every bit of material 19     because we had gotten in, to the best of my recollection, 20     the early part of   '78. We used part of it.                       I(don't 21     recall which parts were used and which weren't.                               I 22     don't know that we used the whole thing.
Gn it is correct, is it not, that you il r.
23             Q   Is it your testimony that you didn't train 24   i  ycur operators on the concept that is reflected in that 25     question and answer that I just read?                             -
pl underst ood f'h M
g --     - - -               , - + -                       -w       - - ,  a
l that a rsnid drop 1.n reactor prassytre c4uld s/
I i
14 produce film boiling which could cause fuel daraqs?
15 A
That is not correct.
I already told you 16 that that never occurred to me.
17 Q
Did you ever look at this material?
18 A
We haven't scanned every bit of material 19 because we had gotten in, to the best of my recollection, 20 the early part of
'78.
We used part of it.
I(don't 21 recall which parts were used and which weren't.
I 22 don't know that we used the whole thing.
23 Q
Is it your testimony that you didn't train 24 ycur operators on the concept that is reflected in that i
25 question and answer that I just read?
m m-g e
-.--.m
--v
,-e
, - + -
'y
-w a
y


s     '
s 1
1                                    Zochman'   s 658 2                A      Could you define the concept again?
Zochman' 658 s
(
(
3               Q     Yes. If there is a rapid drop in reactor 4         pressure and the DNBR drops to less than 1.you would 5         expect film boiling to occur and probable fuel damage.
2 A
ggg 6               A     I don't recall, to the best of my 1
Could you define the concept again?
7  j     recollection, that it was put in those terms.
3 Q
8               Q     Wheth(r it was put in those terms   --
Yes.
l I                                                                 I
If there is a rapid drop in reactor 4
'                  ,.      94              A     Because it didn't occur,to me, so I don't
pressure and the DNBR drops to less than 1.you would ggg 5
  .                            f 10         racall the time that it was taught.
expect film boiling to occur and probable fuel damage.
11                 Q     so I understanc your answer, whether or l?-         not it war put ist the precise terms that were used 15''       in that guestion and answpr, is it ycur testircny that     .
6 A
i      s 14        . that basic concept war act part of the training that     ,
I don't recall, to the best of my 1
i                               ,
j recollection, that it was put in those terms.
15         you gave the operators?
7 8
16                 A     To the best of my recollection, that was 17         not.                           ~
Q Wheth(r it was put in those terms l
18                       I think you have testified before that it Q
I I
19         was part of the training at Met Ed to train the 20         operators on technical specifications, operating 21         procedures and emergency procedures.
9 4 A
l (Il       '
Because it didn't occur,to me, so I don't f
                        -22                 A     Yes, sir.
10 racall the time that it was taught.
23'               Q     waan't it a fundamental concept in the 24         training on thoseSprochdures that pressure and 25         temperature shouldbe maintained vithin the so-called 1
11 Q
so I understanc your answer, whether or l?-
not it war put ist the precise terms that were used 15''
in that guestion and answpr, is it ycur testircny that 14
. that basic concept war act part of the training that i
s i
15 you gave the operators?
16 A
To the best of my recollection, that was 17 not.
~
18 Q
I think you have testified before that it 19 was part of the training at Met Ed to train the 20 operators on technical specifications, operating 21 procedures and emergency procedures.
(Il l
-22 A
Yes, sir.
23' Q
waan't it a fundamental concept in the 24 training on thoseSprochdures that pressure and 25 temperature shouldbe maintained vithin the so-called 1
1
1


1                                 zochcon                   659 2     pressure / temperature envelope?
1 zochcon 659
[%.)T 3                 A Yes, we were trained that we would try 4     to operate the reactor within the pressure / temperature envelope.
[ )T 2
gg 5 6                 Q And that this was true whether you were 7     talking about a start-up or whether you are talking i
pressure / temperature envelope?
B   l about normal cperations cr whether you are talking 5      about cooldown er after a transient, is that correct?
3 A
[                                                              i
Yes, we were trained that we would try 4
              %0                 A This is during normal operations, the 11     operating envelope.                                       .!
to operate the reactor within the pressure / temperature 5
r                                                                                   ,
envelope.
,            12                 Q Did you understand that after a transient
gg 6
        '5   13 i   it was all right to depart from the preesure/temparature 1
Q And that this was true whether you were 7
    '{&           1 14     envelopo?
talking about a start-up or whether you are talking i
15   I A That's why we had a pressure / temperature 16     envelop in the RCS system that would give us trips 17     should we reach points of those envelopes, 18                 Q You have already said earlier that one of 19     the purposes of staying within the pressure / temperature 20     envelope was to keep from creating a condition in 21     which fuel damage would occur, do you remember that?
B l
O 22                 A I said it was related to not exceeding   --
about normal cperations cr whether you are talking
23     to maintaining a DNBR ratio greater than 1.3.
[
24                 Q In order to avoid fuel damage?
about cooldown er after a transient, is that correct?
25                 A DNBR was always related to heat transfer
5 i
%0 A
This is during normal operations, the 11 operating envelope.
r 12 Q
Did you understand that after a transient
'5 13 i it was all right to depart from the preesure/temparature 1
'{&
1 14 envelopo?
15 I
A That's why we had a pressure / temperature 16 envelop in the RCS system that would give us trips 17 should we reach points of those envelopes, 18 Q
You have already said earlier that one of 19 the purposes of staying within the pressure / temperature 20 envelope was to keep from creating a condition in 21 which fuel damage would occur, do you remember that?
O 22 A
I said it was related to not exceeding 23 to maintaining a DNBR ratio greater than 1.3.
24 Q
In order to avoid fuel damage?
25 A
DNBR was always related to heat transfer


                                                                  -L, i     1                             zochman                       660 2     from fuel and if that heat   --
-L, i
yes. If that heat --
1 zochman 660 2
could you repeat the question.
from fuel and if that heat yes.
3 4             Q   I will repeat it so we can save time.     I am 5     repeating a question that I asked in the same way and g
If that heat could you repeat the question.
6    it's a predicate to the question I want to next ask.
3 4
7                 Isn't it a fact that you understood that 8     it was impcrtant to stay within the pressure / temperature t
Q I will repeat it so we can save time.
gl   envelope in order to avoid creating a condition where 4
I am 5
repeating a question that I asked in the same way and g
it's a predicate to the question I want to next ask.
6 7
Isn't it a fact that you understood that 8
it was impcrtant to stay within the pressure / temperature t
gl envelope in order to avoid creating a condition where 4
10 jl fuel danage could occur?
10 jl fuel danage could occur?
A   I believe I already testified to thst.         -
A I believe I already testified to thst.
11 l l           lag             Q   Wasn't it your understanding that it was I
11 l l
i 13      juat as importanc to keep fuel damage fron occurring
lag Q
Wasn't it your understanding that it was I
i
{~}
{~}
    %s                                                                           ,
13 juat as importanc to keep fuel damage fron occurring
i          14  l  after a transient had occurred, as it was during 15     normal operatiens?
%s l
16             A   Yes.
after a transient had occurred, as it was during i
l 17               Q   So isn't it a fact that the concept of 18     maintaining pressure and temperature within the 19     pressure / temperature envelope was reflected in 20     procedures that applied after a transient had occurred j           21 as well as procedures that related to normal operations?
14 15 normal operatiens?
22               A   Repeat the question, please.
16 A
l l
Yes.
23                   (Question read.)
l 17 Q
l 24               A   I don't know that the procedures covered O
So isn't it a fact that the concept of 18 maintaining pressure and temperature within the 19 pressure / temperature envelope was reflected in 20 procedures that applied after a transient had occurred j
    \-     25     every possible circumstance that one could perceive.
21 as well as procedures that related to normal operations?
l 22 A
Repeat the question, please.
l 23 (Question read.)
l 24 A
I don't know that the procedures covered O
\\-
25 every possible circumstance that one could perceive.


1                           Zschman                                       661 2 Emergency procedures were based on expected response, 3 expected symptoms and responses to certain plant 4 transients, 5         g   I am not asking you now to tell us about ggg 6 every single procedure that applied after a transient 7 had occurred. I am simp'ly asking you on a broader 8 basis, isn't that correct that the same concept, that 9 is, staying within the pressure / temperature envelope c       .
1 Zschman 661 2
10 in-order to prevent possible fuel damage apply just as 11 much during a situation in which a transient had 12 occurred at it did during normal operatiens?
Emergency procedures were based on expected response, 3
13         A   I ' don't recall.
expected symptoms and responses to certain plant 4
14         Q   Mr. Zecharn, I wouId like to read you 15 from some te stimony that Mr. Scheimann gave before 16 the President's Commission.
transients, 5
17             You know who Mr. Scheimann is, I take it?
g I am not asking you now to tell us about ggg 6
18         A   Fred Scheimann.
every single procedure that applied after a transient 7
19         Q   Yes.     One of the operators of Three Mile
had occurred.
!        20 Island who was present in the control room on the day 21 of the accident.
I am simp'ly asking you on a broader 8
O     22         A   I understand who he is, yes.
basis, isn't that correct that the same concept, that 9
23         Q   He was a shift foreman, was he not?
is, staying within the pressure / temperature envelope c
10 in-order to prevent possible fuel damage apply just as 11 much during a situation in which a transient had 12 occurred at it did during normal operatiens?
13 A
I ' don't recall.
14 Q
Mr. Zecharn, I wouId like to read you 15 from some te stimony that Mr. Scheimann gave before 16 the President's Commission.
17 You know who Mr. Scheimann is, I take it?
18 A
Fred Scheimann.
19 Q
Yes.
One of the operators of Three Mile 20 Island who was present in the control room on the day 21 of the accident.
O 22 A
I understand who he is, yes.
l 23 Q
He was a shift foreman, was he not?
l l
l l
l        24         A   I forget what his position was at that i
24 A
25 time.
I forget what his position was at that i
25 time.


1                             Zschman                   662
1 Zschman 662
(^]
(^]
v 2         Q     I am reading from page 154, and I will 3   come around so you can follow.
2 Q
4         A     I forget what his title was at that time.
I am reading from page 154, and I will v
5         Q     Let me start at page 154.
3 come around so you can follow.
G 6               " Question:   On Frederick Deposition Exhibit 7   3 they indicate limiting conditions for operation.
4 A
8  Do you know where these limiting conditions came from?
I forget what his title was at that time.
f I
5 Q
9               " Answer:   It would probably come from 10   B&W specifications for the plant operaticn.
Let me start at page 154.
11               " Question:   In designing the plant they 12   would set out limits to operate the plant?
G 6
" Question:
On Frederick Deposition Exhibit 7
3 they indicate limiting conditions for operation.
f Do you know where these limiting conditions came from?
8 I
9
" Answer:
It would probably come from 10 B&W specifications for the plant operaticn.
11
" Question:
In designing the plant they 12 would set out limits to operate the plant?
(''}
(''}
  'uj 13               " Answer:   I would believe ao, yes.
13
14               " Question:   And pursuant to that tech 15   specs were drafted?                                         ,
" Answer:
16               " Answer:   Yes.
I would believe ao, yes.
17               " Question:   In your B&W training course, 18   was it explained to you why these limits were set?
'uj 14
19               " Answer:   Some limits I would say yes, it 20   was.
" Question:
21               " Question:   Do you remember which limits O 22   were explained?
And pursuant to that tech 15 specs were drafted?
23               " Answer:   Not totally.
16
24               " Question:   Do you remember generally?
" Answer:
Ig) k/     25               " Answer:   We had talked some pressure and
Yes.
17
" Question:
In your B&W training course, 18 was it explained to you why these limits were set?
19
" Answer:
Some limits I would say yes, it 20 was.
21
" Question:
Do you remember which limits O
22 were explained?
23
" Answer:
Not totally.
24
" Question:
Do you remember generally?
g)
Ik/
25
" Answer:
We had talked some pressure and


1                               Zachman                     663
1 Zachman 663
(~)     2     temperature limits and things of that nature.
(~)
  'w) 3                 " Question:   Do you remember anything else?
2 temperature limits and things of that nature.
4                 " Answer:   Not really.
'w) 3
5                 " Question:   Do you remembe r what they e 6     explained to you as to pressure and temperature?
" Question:
7                 " Answer:   They explained to us what our 8     pressure bands were and what our temperature bands were 9     and they did give us basic ideas of why they were I
Do you remember anything else?
10     trying to maintain in that area.
4
11                 " Question:   Do you remember what they said?
" Answer:
12                 " Answer:   You had a certain cinimum 13    pressurization temperature to keep from increasing
Not really.
5
" Question:
Do you remembe r what they e 6
explained to you as to pressure and temperature?
7
" Answer:
They explained to us what our 8
pressure bands were and what our temperature bands were 9
and they did give us basic ideas of why they were I
10 trying to maintain in that area.
11
" Question:
Do you remember what they said?
12
" Answer:
You had a certain cinimum
(-]
(-]
  'v' 14     pressere toc high before your temperature was up to 15 -
13 pressurization temperature to keep from increasing
keep ycu from having cladding trouble and rupture 16     trouble. And you had maximum temperature limitations 17     to prevent boiling in the core and things of that nature.
'v' 14 pressere toc high before your temperature was up to keep ycu from having cladding trouble and rupture 15 16 trouble.
18     You had minimum tenperature limits, minimum pressure 19     limits to keep you from boiling in the reactor coolant 20     system basically things of that nature."
And you had maximum temperature limitations 17 to prevent boiling in the core and things of that nature.
21                 Did you at Met Ed train the operators that O 22     you had a pressure / temperature relationship which was 23     important to keep you from boiling in the reactor 24     coolant system.
18 You had minimum tenperature limits, minimum pressure 19 limits to keep you from boiling in the reactor coolant 20 system basically things of that nature."
    \>-
21 Did you at Met Ed train the operators that O
25                 MR. MacDONALD:     He can answer. I object to
22 you had a pressure / temperature relationship which was 23 important to keep you from boiling in the reactor 24 coolant system.
\\>
25 MR. MacDONALD:
He can answer.
I object to


e 3     1                               Zochasn                     664
e 3
  '                    the form.
1 Zochasn 664 2
2 3           A     I already testified that I do not -- it 4   did not occur to me the condition of having boiling 5   in the core, that the pressure / temperature envelope ggg 6   was based on a DNBR ratio which had to do with fuel 7   cladding and fuel damage' considerations.                   ,
the form.
8           Q     Did you ever learn during any of the time 9    prior to the accident that you were receiving reports.
3 A
l 10   as to what was going on in the B&W training program that I
I already testified that I do not -- it 4
11   B&W was giving training of that nature?
did not occur to me the condition of having boiling ggg 5
12           A     1 don't recall B&W giving us training in 13   which those areas were discussed, i
in the core, that the pressure / temperature envelope 6
14           Q     You mean nobcady rever brought to your i
was based on a DNBR ratio which had to do with fuel 7
15   attention that they were giving that training, is that i
cladding and fuel damage' considerations.
16   correct?
8 Q
17           A     I am saying I don't recall seeing it in 18   my training or recall it in their training, to the 19   best of my recollection at this time.
Did you ever learn during any of the time l
20           Q     So apparently Mr. Scheimann never told you 21   that they were doing that?
prior to the accident that you were receiving reports.
O   22           A     No,-I don't recall discussing it with Mr.
9 10 as to what was going on in the B&W training program that I
23   Scheimann.
11 B&W was giving training of that nature?
24                 MR. FISKE:   Let me mark as the next exhibit, O     25           as B&W Exhibit 572, Section 2.0 of the Technical
12 A
1 don't recall B&W giving us training in 13 which those areas were discussed, i
14 Q
You mean nobcady rever brought to your i
15 attention that they were giving that training, is that i
16 correct?
17 A
I am saying I don't recall seeing it in 18 my training or recall it in their training, to the 19 best of my recollection at this time.
20 Q
So apparently Mr. Scheimann never told you 21 that they were doing that?
O 22 A
No,-I don't recall discussing it with Mr.
23 Scheimann.
24 MR. FISKE:
Let me mark as the next exhibit, O
25 as B&W Exhibit 572, Section 2.0 of the Technical


4 1                                                             Zechman                             665
1 Zechman 665 4
()                                 2                                         Specification for the TMI Unit 2.
()
3                                                 (collection of pages captioned " Nuclear 4                                         Energy Training Instructor's Guide Plant 5                                         Performance " marked B&W Exhibit 571 for ggg 6                                         identification, as of this date.)
2 Specification for the TMI Unit 2.
7                                                 (Section 2.0 of the Technical Specifications 6                                         for TMI Unit 2 marked B&W Exhibit 572 for 1
3 (collection of pages captioned " Nuclear 4
9                                         identification, as of this date.)
Energy Training Instructor's Guide Plant ggg 5
I                                     10                 BY MR. FISKE:
Performance " marked B&W Exhibit 571 for 6
11                                         Q       Is it correct, Mr. Zeehman, that during i
identification, as of this date.)
'                                    12                 the period of time befora the Three Mile Island accident ll 13                 when you were in charge of the training department, 14                   you were familiar with-the technical specifications for 15                 Unit 27 16                                         A       At the time I was either acting or was in 17                 charge, and the times that I went through the technical 18                 specifications.                     I don't know that I memorized all of i
7 (Section 2.0 of the Technical Specifications 6
l                                     19                 them.
for TMI Unit 2 marked B&W Exhibit 572 for 1
20                                           Q       Let's look at page 2.1, the very first 21                     item, which says, "2.1 Safety Limits."
9 identification, as of this date.)
22                                                   Do you see where it says " Reactor Core,"
I 10 BY MR. FISKE:
23                   it says "The combination of the reactor coolant core 24                   outlet pressure and outlet temperature shall not O                                 25                   exceed the safety limit shown in Figure 2.1-1."
11 Q
L   ._ _. _ . _._ __ _.._ _ ... _ __ __ ,,_ _ ._ _ _ ,_ _._ _ _ _ _ ____. _ _ .______                                      _ _ __ ..___ __ _ _
Is it correct, Mr. Zeehman, that during i
12 the period of time befora the Three Mile Island accident ll 13 when you were in charge of the training department, 14 you were familiar with-the technical specifications for 15 Unit 27 16 A
At the time I was either acting or was in 17 charge, and the times that I went through the technical 18 specifications.
I don't know that I memorized all of i
l 19 them.
20 Q
Let's look at page 2.1, the very first 21 item, which says, "2.1 Safety Limits."
22 Do you see where it says " Reactor Core,"
23 it says "The combination of the reactor coolant core 24 outlet pressure and outlet temperature shall not O
25 exceed the safety limit shown in Figure 2.1-1."
L


4                                           -l                                                             Zechman                       666
4
()                                     2                                                 Do you see that?
- l Zechman 666
3                                           A     Yes, I do.
()
4                                           Q     Turning to Figure 2.1-1, does that reflect 5                  a pressure / temperature envelope?
2 Do you see that?
gg 6                                                 MR. MacDONALD:   What he understood prior 7-                                         to the accident?
3 A
f 8                                                 MR. FISKE:   Yes.
Yes, I do.
j                                             9-                                         A     I realize prior to the eccident we had a       ;
4 Q
10                 pressure / temperature envelope.                     I just don't recall 11                   if this was the -- I just don't recall this, at this 12                 time.
Turning to Figure 2.1-1, does that reflect gg a pressure / temperature envelope?
(                                     13                                           Q     You do reca'll that there was a pressure /
5 6
14                 temperature envelope which had to be complied with as l                                           15                 part of the safety limits                       relating to the core?
MR. MacDONALD:
I 16                                           A     Yes, I understood that.
What he understood prior 7-to the accident?
17                                                 I would like you to turn to page B2-1.
f 8
Q 18                 If it helps, it is numbered 0922 at the bottom.
MR. FISKE:
            .                              19                                                 Do you have that in front of you?
Yes.
20                                           A     Yes.
j 9-A I realize prior to the eccident we had a 10 pressure / temperature envelope.
21                                           Q     Do you see at the top " Safety Limits?
I just don't recall 11 if this was the -- I just don't recall this, at this 12 time.
O                         22                                           A     Yes.
(
23                                           Q     And the next word is " Bases"?
13 Q
24                                           A     Yes, sir.
You do reca'll that there was a pressure /
O                                     25                                           Q     And the first paragraph reads, with respect
14 temperature envelope which had to be complied with as l
15 part of the safety limits relating to the core?
I 16 A
Yes, I understood that.
17 Q
I would like you to turn to page B2-1.
18 If it helps, it is numbered 0922 at the bottom.
19 Do you have that in front of you?
20 A
Yes.
21 Q
Do you see at the top " Safety Limits?
O 22 A
Yes.
23 Q
And the next word is " Bases"?
24 A
Yes, sir.
O 25 Q
And the first paragraph reads, with respect


1                                     Zschnan                                                 667
1 Zschnan 667
( )     2     to 2.1.1 that we read just a moment ago, "The 3   restrictions of this safety limit prevent overheating 4     of the fuel cladding and possible cladding performation (gg 5   which would result in the release of fission products 6     in the reactor coolant.                     Overheating of the fuel 7     cladding is prevented by restricting fuel operation 6     to within the nucleate boiling regime where the heat 9     transfer coefficient is large and the cladding surface 10     tanperature is slightly above the coolant saturation 11     temperature."
(
12                       Do you see that?
)
13           A           I see that.
2 to 2.1.1 that we read just a moment ago, "The 3
14           Q         Did you understand that the pressure /
restrictions of this safety limit prevent overheating 4
15     temperature envelope pictured in Figure 2.1.1 was 16   designed to accomplish the result described in the 17     section I just read?
of the fuel cladding and possible cladding performation (gg 5
18           A         Yes, I did.
which would result in the release of fission products 6
19           Q         You understood that that technical 20     specification applied during both normal operations 21     and during the course of a transient?
in the reactor coolant.
O   22           A           I said I didn't recall.
Overheating of the fuel 7
23                       MR. FISKE:           Let me mark as B&W Exhibit 573 24           at the risk of re-marking an exhibit that has O     25           already been introduced at a prior deposition.
cladding is prevented by restricting fuel operation 6
to within the nucleate boiling regime where the heat 9
transfer coefficient is large and the cladding surface 10 tanperature is slightly above the coolant saturation 11 temperature."
12 Do you see that?
13 A
I see that.
14 Q
Did you understand that the pressure /
15 temperature envelope pictured in Figure 2.1.1 was 16 designed to accomplish the result described in the 17 section I just read?
18 A
Yes, I did.
19 Q
You understood that that technical 20 specification applied during both normal operations 21 and during the course of a transient?
O 22 A
I said I didn't recall.
23 MR. FISKE:
Let me mark as B&W Exhibit 573 24 at the risk of re-marking an exhibit that has O
25 already been introduced at a prior deposition.


ll 1                                                                   zachman                                       668 2                                   (Document marked B&W Exhibit 573 for 3                 identification, as of this date.)
ll 1
zachman 668 2
(Document marked B&W Exhibit 573 for 3
identification, as of this date.)
4 BY MR. FISKE:
4 BY MR. FISKE:
I 5                 Q                 This is Unit 2, operating Procedure ggg 6 2102-3.3, Decay Heat Removal Via OTSG."
I 5
7                                   Do_you recognize this, Mr. Zechman, as 8 an operating procedure for Unit 27
Q This is Unit 2, operating Procedure ggg 6
;                                        9                A                 I recognize this as a procedure that i-
2102-3.3, Decay Heat Removal Via OTSG."
^
7 Do_you recognize this, Mr. Zechman, as 8
an operating procedure for Unit 27 9
A I recognize this as a procedure that i-
^
10 has all the markings of a Unit 2 procedure, yes, sir.
10 has all the markings of a Unit 2 procedure, yes, sir.
11                 Q                 Looking at the bottom of the front page, 12 do you see two blocks reflecting the fact that Unit 2 13' PORC had recommended approval with the signature for 14 the chairman of the PORC and that the Unit 2 15 superintendent had approved with a signature of the 16 Unit 2 superintendent?
11 Q
17                 A                 I see that.
Looking at the bottom of the front page, 12 do you see two blocks reflecting the fact that Unit 2 13' PORC had recommended approval with the signature for 14 the chairman of the PORC and that the Unit 2 15 superintendent had approved with a signature of the 16 Unit 2 superintendent?
18                 Q                 Both reflecting dates in April of 19777 19                 A                 Negative.                     It looks like '78 to me.
17 A
l                                       20                 Q                 I think you read it better than I do.
I see that.
21 It's'78, right?
18 Q
22                 A                 I believe so.
Both reflecting dates in April of 19777 19 A
23                 Q                 What did you understand the purpose of this 24 procedure was?
Negative.
CE)                               25                 A                 I don't recall using this procedure
It looks like '78 to me.
l 20 Q
I think you read it better than I do.
21 It's'78, right?
22 A
I believe so.
23 Q
What did you understand the purpose of this 24 procedure was?
CE) 25 A
I don't recall using this procedure


1                         zechnen                     669
1 zechnen 669
  ~ '
~ '
2 personally.
2 personally.
3       Q   Were you aware that there was a procedure 4 applicable to decay heat removal via the steam 5 generator?
3 Q
ggg 6         A   I can only say that the title looks familiar,
Were you aware that there was a procedure 4
                                              +
applicable to decay heat removal via the steam ggg 5
7 but I don't recall using it.
generator?
8         Q   Let's go back a couple of steps.
6 A
9             Are you familiar with a concept in the 10 operation of a nuclear reactor called decay heat 11 removal?
I can only say that the title looks familiar,
12         A   Yes, sir.
+
13         Q   What is decay heat removal?
7 but I don't recall using it.
14         A   Decay heat removal Ls removal of residual 15 heat from reactor core after a period of shutdown.
8 Q
16         Q   Am I correct that in a situation where 17 there has been a transient resulting in a reactor 18 trip, there continues to be heat generated from the 19 core even though the unit is not operating?
Let's go back a couple of steps.
l
9 Are you familiar with a concept in the 10 operation of a nuclear reactor called decay heat 11 removal?
;          20         A   Even through the   rods have been inserted 21 and the reactor is essentially shut down, there is a O   22 residual heat flux of the core of fission products.
12 A
23         Q   That is colloquially called decay heat?
Yes, sir.
24         A   That 's correct.
13 Q
25         Q   It is important to accomplish a safe and
What is decay heat removal?
14 A
Decay heat removal Ls removal of residual 15 heat from reactor core after a period of shutdown.
16 Q
Am I correct that in a situation where 17 there has been a transient resulting in a reactor 18 trip, there continues to be heat generated from the 19 core even though the unit is not operating?
l 20 A
Even through the rods have been inserted 21 and the reactor is essentially shut down, there is a O
22 residual heat flux of the core of fission products.
23 Q
That is colloquially called decay heat?
24 A
That 's correct.
25 Q
It is important to accomplish a safe and


1                             Zochaan                     670
1 Zochaan 670
[)/
[)/
  ~-
2 effective shutdown that that decay heat be removed?
2   effective shutdown that that decay heat be removed?
~-
3         A     cooldown.
3 A
4         Q     It's important that it be done, that the ggg   5   decay heat be removed?
cooldown.
6         A     It is important to remove the decay heat.
4 Q
7         Q     one way to do that is via the steam 8   generator, is that correct?
It's important that it be done, that the ggg 5
9         'A     The decay heat removal system?
decay heat be removed?
10         Q     Yes. Is that correct?   Put it another way, 11   more simply.
6 A
12                 Is there a process ;?o r removing the decay 13   heat which involves the steam generator?
It is important to remove the decay heat.
14           A     There is enti process -- there is a process 15   that I am aware of, yes.                                   !
7 Q
l 16           Q     can you tell us whether the document you 17   have in front of- you is the operating procedure for 18   that process?
one way to do that is via the steam 8
19           A     As I said, I have not used and I am not 20   familiar with this procedure and I would be speculating 21   at this point.
generator, is that correct?
O   22           Q     Let me direct your attention to page 3.0 23   of this document, the top of the page under " Limits 24   and Precautions."
9
O\-     25           A     Yes, sir.
'A The decay heat removal system?
10 Q
Yes.
Is that correct?
Put it another way, 11 more simply.
12 Is there a process ;?o r removing the decay 13 heat which involves the steam generator?
14 A
There is enti process -- there is a process 15 that I am aware of, yes.
l 16 Q
can you tell us whether the document you 17 have in front of-you is the operating procedure for 18 that process?
19 A
As I said, I have not used and I am not 20 familiar with this procedure and I would be speculating 21 at this point.
O 22 Q
Let me direct your attention to page 3.0 23 of this document, the top of the page under " Limits 24 and Precautions."
O
\\-
25 A
Yes, sir.


1 Zochasn                                                         671
1 Zochasn 671 2
    ,                                              2                  Q                           "2.1.1.               Reactor coolant temperature /
Q "2.1.1.
3         pressure and cooldown rates shall be maintained within 4         the limits specified in Figure 3.4.2 of Ts 3.4.9.1 5           (refer to Figure 1.5.2 attached) ."
Reactor coolant temperature /
g 6                                             Do you see that reference?
3 pressure and cooldown rates shall be maintained within 4
7                 A                           I see that reference.
the limits specified in Figure 3.4.2 of Ts 3.4.9.1 5
8                 Q                           Turning tc Figure 1.5.2, do you have tha;                                                                       ,
(refer to Figure 1.5.2 attached)."
9~         in front of you?
g 6
Do you see that reference?
7 A
I see that reference.
8 Q
Turning tc Figure 1.5.2, do you have tha; 9~
in front of you?
t -
t -
10                   x                           y,3,                                                                                                           ,
10 x
i 11                     Q                           " Heat Up/Cooldown Curve."
y,3, i
12                     A                           That's correct.
11 Q
13                                                 Eave you ever teen that curve ~before?
" Heat Up/Cooldown Curve."
Q 14                     A                           I have seen heat up and cooldown curves, but                                                               I
12 A
.                                                                                                                                                                                                          I   <
That's correct.
6 15             1 don't know that I saw this specific curve.                                                                                                       '
13 Q
i I don't 16 recall that I specifically saw this specific curve.
Eave you ever teen that curve ~before?
17                                               what did you understand the purpose of a Q
14 A
18             heat up/cooldown curve was?
I have seen heat up and cooldown curves, but I
i 19                     A                         It's been a very long time since I worked 20               with them.                       I only have a generic remembrance of the 21               heat up and cooldown curves.                                                   Two areas, one had to do 22               with the operation of the pumps and some of the l
I 6
23               limitations had to do with the metallurgical considera-24               tions of the piping.
15 1 don't know that I saw this specific curve.
(:)                                   25 Q                         Isn't the heat up -- doesn't the l
I don't i
16 recall that I specifically saw this specific curve.
17 Q
what did you understand the purpose of a 18 heat up/cooldown curve was?
i 19 A
It's been a very long time since I worked 20 with them.
I only have a generic remembrance of the 21 heat up and cooldown curves.
Two areas, one had to do 22 with the operation of the pumps and some of the l
23 limitations had to do with the metallurgical considera-24 tions of the piping.
(:)
25 Q
Isn't the heat up -- doesn't the l
l l
l l
I____.    . . _ - - _ _ . ~ - _ , _ . _ . , _ _ , _ . . _ ,           , _ _ _ _ _ . , . _ _ _ _ .      . . _ _ _ , _ , _ . _ _ _ _ _          _
I _ _ _ _.
~ - _, _. _., _ _, _.. _,


1                                           Zochman                           672
1 Zochman 672
      )         2     heat up/cooldown curve appear in a large number of s-3     procedures for Unit 2, both emergency and operating 4     procedures?
)
g      5             A                 I can't put a quantity on it.         I know that 6     it appears in several procedures.
2 heat up/cooldown curve appear in a large number of s-3 procedures for Unit 2, both emergency and operating 4
7             p                 Isn't it a fundamental concept that these 8     curves have to be conformed vith during al3 phases                         ,
procedures?
9      of the start-er operation and cocidown of the 10     reactor?
5 A
}             11             A                 I don't recall all the limitations and use 12       of thosa curves any more.                     It 's been long time ago.
I can't put a quantity on it.
It 13             Q                 Mr. Zechman, we ars taikt.ns about a pretty 4              14       fundamental question relating to a period cf time from 15       whenever it was that you first started with the 16       training dep&rtment at Met Ed back in the early                     '70's 17       right through. the period of . time ending in F. arch of '79 18       when you were in charge of the training department.
I know that g
19       So I am asking you simply, thinking back over that 20       entire period of time in which you were involved in 21       or in charge of the training at Met Ed, didn't you O     22       understand that at all times during start-up operation 23       or cooldown, shutdown, you had to comply with these 24       curves?
6 it appears in several procedures.
O         25             A                 I had an understanding years ago when I was
7 p
Isn't it a fundamental concept that these 8
curves have to be conformed vith during al3 phases 9
of the start-er operation and cocidown of the 10 reactor?
}
11 A
I don't recall all the limitations and use 12 of thosa curves any more.
It 's been long time ago.
It 13 Q
Mr. Zechman, we ars taikt.ns about a pretty 14 fundamental question relating to a period cf time from 4
15 whenever it was that you first started with the 16 training dep&rtment at Met Ed back in the early
'70's 17 right through. the period of. time ending in F. arch of '79 18 when you were in charge of the training department.
19 So I am asking you simply, thinking back over that 20 entire period of time in which you were involved in 21 or in charge of the training at Met Ed, didn't you O
22 understand that at all times during start-up operation 23 or cooldown, shutdown, you had to comply with these 24 curves?
O 25 A
I had an understanding years ago when I was


1                                     Zachman                     673 g_,)       2         working with these and in the training department, I 3         had an understanding of the heat up and cooldown curves 4         and the basis for them.       I don't rghall the basis (l)   5         for them today.       It's been too long since I worked with S         them.
1 Zachman 673 g_,)
7               Q         Did you know cf any situation from start-up 6         right through cooldven when it wasn't recessary to l                                                                   i 9         conform to these curveu?
2 working with these and in the training department, I 3
10               P.       As I said, I don't recali all the             !
had an understanding of the heat up and cooldown curves 4
11         rauifications and usos of those curves et this time.           ;
and the basis for them.
12         I would be speculating at this point with my memory.
I don't rghall the basis (l) 5 for them today.
13                         Let's see, Mr. Zechm&4.     Why did you
It's been too long since I worked with S
(                          Q 14          understand it was impartant tc comply with these curves?
them.
l 15               A         Because they were limitations that were put 16         in procedures to operate with.
7 Q
17               Q         Did you have' an understanding beyond the
Did you know cf any situation from start-up 6
'            10         fact that they were attached to a procedure as to the j           19         reason why it was important to do it?
right through cooldven when it wasn't recessary to l
1 20               A         I certainly understand that they were l           21         important, that we follow those heat up and cooldown 22         curves. That's why they were in our procedures and l
i 9
23         there were a good number of reasons for parts of those 24         curves. I don't recall today all those ramifications.
conform to these curveu?
25               Q         I am simply asking you in the broadest l
10 P.
As I said, I don't recali all the 11 rauifications and usos of those curves et this time.
12 I would be speculating at this point with my memory.
(
13 Q
Let's see, Mr. Zechm&4.
Why did you 14 l
understand it was impartant tc comply with these curves?
15 A
Because they were limitations that were put 16 in procedures to operate with.
17 Q
Did you have' an understanding beyond the 10 fact that they were attached to a procedure as to the j
19 reason why it was important to do it?
1 20 A
I certainly understand that they were l
21 important, that we follow those heat up and cooldown 22 curves.
That's why they were in our procedures and l
23 there were a good number of reasons for parts of those 24 curves.
I don't recall today all those ramifications.
25 Q
I am simply asking you in the broadest l


1                               Zschman                     674 2     terms possible, why did you understand that it was 3     important to filow the curves?     I assume you had some 4     understanding beyond simply the fact that they appeared 5     in the procedure?             '
1 Zschman 674 2
ggg 6             A     I told you a while ago, they had to do 7     with the operetion of our C pumps, they had limitatior_s 4   i with the metallurgical consideratione of the piping.
terms possible, why did you understand that it was 3
9,     I understocd that.
important to filow the curves?
b                                                               l Ml            Q     What did you understa.ud eculd happen if       i 11 tj  those curves were not followed?
I assume you had some 4
y                                                                 ,
understanding beyond simply the fact that they appeared 5
12 rg          A     I don ~t recall those details a.sy more, g-     13       air.
in the procedure?
D 14 i           Q     Can you give tu any sing 1r thing that i
ggg 6
l 15     you recall now could have cecurred that would be bad 16 ,
A I told you a while ago, they had to do 7
for the plant if those curves were not followed?
with the operetion of our C pumps, they had limitatior_s 4
17             A     With respect to the metallurgical con-18       siderations, you could exceed some of the stress j         19       limits of some of the piping,                         ,
i with the metallurgical consideratione of the piping.
!          20             Q     Why would that be bad?
9, I understocd that.
21             A     For the integrity of the RCS system.
b l
22             Q     Why was it important to maintain the l
M l Q
23       integrity of the RCS system?
What did you understa.ud eculd happen if i
24             A     So you won't have ruptures or damage to 25       the piping within the RCS system.
those curves were not followed?
11 tj y
12 r A
I don ~t recall those details a.sy more, g
g-13 air.
D 14 i Q
Can you give tu any sing 1r thing that i
l 15 you recall now could have cecurred that would be bad 16 for the plant if those curves were not followed?
17 A
With respect to the metallurgical con-18 siderations, you could exceed some of the stress j
19 limits of some of the piping, 20 Q
Why would that be bad?
21 A
For the integrity of the RCS system.
22 Q
Why was it important to maintain the l
23 integrity of the RCS system?
24 A
So you won't have ruptures or damage to 25 the piping within the RCS system.


1                                 Zechman                   675
1 Zechman 675
(       2               Q     Was it important that you not have damage 3       to the* integrity of the RCS system during start-up?
(
4               A     Certainly.
2 Q
ggg   5             Q     Was it important that you not have damage 6       to the integrity of the TOS system during normal 7       ope rations ?
Was it important that you not have damage 3
E             h     Yes, sir, f
to the* integrity of the RCS system during start-up?
9              Q     Wed Lt important that you did not have 10 i     4ccage to thw intes.~ity of ti:e RCS system during h
4 A
11  h cooldowa?
Certainly.
12             A     Yes.                                       f  '
ggg 5
13                       (Peress.)
Q Was it important that you not have damage 6
to the integrity of the TOS system during normal 7
ope rations ?
f E
h Yes, sir, 9
Q Wed Lt important that you did not have 10 i 4ccage to thw intes.~ity of ti:e RCS system during h
h cooldowa?
11 f
12 A
Yes.
13 (Peress.)
Li -l!
hY MR. FIFEF:
hY MR. FIFEF:
Li -l!
?#
                  ?
15 Q
15             Q     You have that heat up/cooldown curve in 16       front of you, Mr. Zechman.
You have that heat up/cooldown curve in 16 front of you, Mr. Zechman.
17             A     1.5.27 18               Q     Yes.
17 A
19               A     Yes, sir.
1.5.27 18 Q
20               Q     There are some numbers down the left-hand 21       side of the page, are there not?
Yes.
O   22               A     You mean B&W numbers or -- I am sorry.
19 A
23       Starts with the J   --
Yes, sir.
24               Q     No, not the numbers that reflect the O     25       s tamping of the documents.
20 Q
There are some numbers down the left-hand 21 side of the page, are there not?
O 22 A
You mean B&W numbers or -- I am sorry.
23 Starts with the J 24 Q
No, not the numbers that reflect the O
25 s tamping of the documents.


1                                         Zechacn                       676
1 Zechacn 676
['}
['} '
    'a
2 A
        '            2                 A           On the curve itself?
On the curve itself?
3                 Q         Yes, top number is 2300 and the bottom is 4     100.
'a 3
ggg         5                             Do you see that?
Q Yes, top number is 2300 and the bottom is 4
6                 A           Yes.
100.
7                 Q           What do those numbers represent?
ggg 5
I 8js MR. MacDONALD:     You are asking for h i.s i                                                                                                   t S                 recollection now?                                           I
Do you see that?
                                                                                                    ~
6 A
l 30                               MR. FISKE:   Yes, and he can loo % at the       !
Yes.
11*                 c u rv e. .
7 Q
12                 A           The numbers repreaant temperature.               -
What do those numbers represent?
13                   Q           what do the numbers across the b;tton --
I 8 j MR. MacDONALD:
, 'O 14                   A           I t ho ug~a t you said -- which huhcred are 15       you talking about?
You are asking for h i.s s
16                   Q           The top number is 2300 and the bottom 17       number 100.
t i
18                   A           That's RC pressure.
S recollection now?
19                 Q             The numbers acrosc the bottom are 20         temperature?
I l
21                   A             Correct.
~
O     22               -Q               What did you understand the curves, the 23         various curves that are on this graph supposed to 24         represent?
30 MR. FISKE:
    's /         25                 A             sir, it's been too long since I worked
Yes, and he can loo % at the 11*
c u rv e..
12 A
The numbers repreaant temperature.
13 Q
what do the numbers across the b;tton --
' O 14 A
I t ho ug~a t you said -- which huhcred are 15 you talking about?
16 Q
The top number is 2300 and the bottom 17 number 100.
18 A
That's RC pressure.
19 Q
The numbers acrosc the bottom are 20 temperature?
21 A
Correct.
O 22
-Q What did you understand the curves, the 23 various curves that are on this graph supposed to 24 represent?
's /
25 A
sir, it's been too long since I worked


1 Zschman                                     677 2   with these curves.     I would be speculating on the 3   interpretation of these curves.           I don't remember any 4   more.
1 Zschman 677 2
ggg     5           Q     Just starting with the basics, isn't it 6                                                                                                 '
with these curves.
I would be speculating on the 3
interpretation of these curves.
I don't remember any 4
more.
ggg 5
Q Just starting with the basics, isn't it 6
correct that these curves reflect varacur pressure /
correct that these curves reflect varacur pressure /
l 7     temperaturo relationships as you stove along the curve?
l 7
6           A     Yes, they do.
temperaturo relationships as you stove along the curve?
O Q     And is it also correct that it was in-
6 A
}               I
Yes, they do.
!          10 ) portant to asintain those pressure /tempereture                                       j     ,
O Q
                                                                                                        !    i 11     relationships?                                                                       '
And is it also correct that it was in-
i 12             A     In the utilization of this curve and the                                       .
}
13     procedure that utilizes this curve.
I 10 )
i         14           Q     Se that at any time this heat up/cooldown                                       .
portant to asintain those pressure /tempereture j
15 curve appears in a procedure, the purpose of it is 16     to be sure that in implementing that particular 17     procedure, the operators are sure that the 18 pressure / temperature relationships conform with what 19
11 relationships?
(                 they are expected to do in light of these curves?
i i
l 20             A     Under the guidance of what the procedure 21     states.
12 A
O   22             Q     Right. But let's just take one curve, 23     for example. Let 's take the curve that's marked No. 2.
In the utilization of this curve and the 13 procedure that utilizes this curve.
24                   Do you see that curve on this chart?
i 14 Q
z  O     25             A     Yes, I do ,
Se that at any time this heat up/cooldown 15 curve appears in a procedure, the purpose of it is 16 to be sure that in implementing that particular 17 procedure, the operators are sure that the 18 pressure / temperature relationships conform with what
(
19 they are expected to do in light of these curves?
l 20 A
Under the guidance of what the procedure 21 states.
O 22 Q
Right.
But let's just take one curve, 23 for example.
Let 's take the curve that's marked No.
2.
24 Do you see that curve on this chart?
O 25 z
A Yes, I do,
t
t


1                               Zochnan                     678 2             Q     Then there is a description of that on 3      the right-hand side, is there not?
1 Zochnan 678 2
4             A     Yes, there is, 5_           Q     How is it described?
Q Then there is a description of that on the right-hand side, is there not?
ggg 6             A     " Minimum RC pressure to maintain compres-7       sion force on clad (natural circulation)" -- and then 1
3 4
6       a letter I can 't read, and then -- " inst. erspr pint 9      50 psia minus 12 degrees Fahrenheit."
A Yes, there is, 5_
l l'           10             Q     so did you understand before the accident 11       thut the purpose of this curve was to be sure that a l
Q How is it described?
12       certain minimum pressure was unir.tained in rela tion to h
ggg 6
s       13       the temperature that existed at that part.icular point     !
A
      )
" Minimum RC pressure to maintain compres-7 sion force on clad (natural circulation)" -- and then 1
14       in time?
6 a letter I can 't read, and then -- " inst. erspr pint 50 psia minus 12 degrees Fahrenheit."
15             A     I already said I have not worked with these.
9 l
16       I don't recall the basis for these or have a recall 17       of the basis for these at this time. I would be 18       speculating on --I can read to you what it says, but I 19       would be speculating on the interpretation of all of 20       this.
l' 10 Q
21               Q     Let's j u s.t look at the various curves.
so did you understand before the accident 11 thut the purpose of this curve was to be sure that a l
l
12 certain minimum pressure was unir.tained in rela tion to h
!            22       Let's take them one at a time, l
s 13 the temperature that existed at that part.icular point
23                     The first one is No. 1. Do you see No. 17 i           24             A     Yes, sir.
)
14 in time?
15 A
I already said I have not worked with these.
16 I don't recall the basis for these or have a recall 17 of the basis for these at this time. I would be 18 speculating on --I can read to you what it says, but I 19 would be speculating on the interpretation of all of 20 this.
21 Q
Let's j u s.t look at the various curves.
l 22 Let's take them one at a time, l
23 The first one is No.
1.
Do you see No. 17 i
24 A
Yes, sir.
1.
1.
  '\-       25             Q     Do you know whether the operators were l
'\\-
25 Q
Do you know whether the operators were l
l l
l l
i
i


1                             Zochman                     679 2     supposed to maintain a pre,sure/ temperature 3     relationship that stayed on the left side of the 4     curve or the right side of the curve?
1 Zochman 679 2
ggg     5           A     I don't recall.
supposed to maintain a pre,sure/ temperature 3
6             Q     How about curve No. 2, can you tell us           ,
relationship that stayed on the left side of the 4
t 7     whether the operators were supposed to maintain a
curve or the right side of the curve?
!            6      pressure / temperature relationship cn the lef t side 9 ,. of the carve or on the right side of the curve?               '
ggg 5
t l.
A I don't recall.
20 !         A     I don't recall.
6 Q
k 11             Q     Can yce tell us looking at any one of 12  !j the six curves on that chart whether the operators           l
How about curve No.
                                                                                .I la     were supposed to maintain pressure on the left side         I 14     or the -- pressure / temperature relationship on the l
2, can you tell us t
15     left side of the curve or the right side?
7 whether the operators were supposed to maintain a 6
I 16             A     I don't recall.
pressure / temperature relationship cn the lef t side 9
17             Q     And you are'giving those answers after 18     having an opportunity to look at the curves and look 19     at the description of each one, is that correct?
of the carve or on the right side of the curve?
20             A     That's correct.
l.
l         21             Q     As you sit there today, Mr. Zechman, just l         22       by looking at the description of these curves, can you 23       tell us which side of the curves the operators should 24       be on?
t 20 !
    )
A I don't recall.
25                   MR. MacDONALD:   I am going to object to l
k' 11 Q
Can yce tell us looking at any one of
!j the six curves on that chart whether the operators l
12
.I la were supposed to maintain pressure on the left side I
14 or the -- pressure / temperature relationship on the l
15 left side of the curve or the right side?
I 16 A
I don't recall.
17 Q
And you are'giving those answers after 18 having an opportunity to look at the curves and look 19 at the description of each one, is that correct?
20 A
That's correct.
l 21 Q
As you sit there today, Mr. Zechman, just l
22 by looking at the description of these curves, can you 23 tell us which side of the curves the operators should 24 be on?
)
25 MR. MacDONALD:
I am going to object to l
i
i


1                                                                             Zochann                                       680 2                                       that.           You are talking about his present 3                                       recollection of the document and not prior to 4                                       the accident.             I object to that.                               His recollection ggg                       5                                       is fine.           I have no problem with that.
1 Zochann 680 2
6                                                 MR. FISKE:                     I will give Mr. Zechman an opportunity to answer if he wants to.
that.
7l                                                                                                                                    ;
You are talking about his present 3
8                                       A         Would you restate the question, please,                                           j l
recollection of the document and not prior to 4
                                          )
the accident.
l 9                                                   (Questi>n read.)                                                               l 4
I object to that.
  *                                                                                                                                                                        \
His recollection ggg 5
c t
is fine.
10                                        g          1ust ec you understand, Mr. MacDonald 11 (I                  stated an cLjaction that had been stated in previcus IE                    deponitient on both sides and witnesses up to this 13                    point havo nct been required to answer his questions                                                            l  )
I have no problem with that.
      %.                                                                                                                                                                        1 14                    like the one --
6 MR. FISKE:
15                                                  MR. MacDOMALD:                                    Do you want to know if 16                                      he wants to answer over my objection?
I will give Mr. Zechman an 7 l opportunity to answer if he wants to.
17                                                MR. FISKE:                    Yes.
8 A
18                                      A          I do not.
Would you restate the question, please, j
19                                      Q        Were you familiar with a procedure called 20                    the unit heat up operating procedure that was in effect 21                  before the accident 2202-1.17 i
l l
22                                      A          I don't recall that procedure at this l
)
9 (Questi>n read.)
l
l
,                                     23                   time.
\\
4 c
t 10 g
1ust ec you understand, Mr. MacDonald 11 (I stated an cLjaction that had been stated in previcus IE deponitient on both sides and witnesses up to this 13 point havo nct been required to answer his questions l
)
1 14 like the one --
15 MR. MacDOMALD:
Do you want to know if 16 he wants to answer over my objection?
17 MR. FISKE:
Yes.
18 A
I do not.
19 Q
Were you familiar with a procedure called 20 the unit heat up operating procedure that was in effect 21 before the accident 2202-1.17 22 A
I don't recall that procedure at this i
l l
23 time.
(
(
24                                       Q         Was there a heat up/cooldown curve that was l
24 Q
l     %-                            25                 part of that procedure?
Was there a heat up/cooldown curve that was l
l                                                                             -
l 25 part of that procedure?
l . , . - . -.   . _ . . - . . , , .        , - - , , , - - - - - - . - - - -         - - - - - , ,    - - - ~ ~ - - - - - ~ , - - - - - , - -
l l.,. -. -.
- - - ~ ~ - - - - - ~, - - - - -, - -
- ' - ~ ' - ~ ~ - - ~


1                               Zochman                     681 2           A     I don't recall.
1 Zochman 681 (Av) 2 A
(Av) 3           Q     Do you recall a procedure called unit 4   startup operating procedure that was in effect before (g)   5   the accident?
I don't recall.
6           A     You are talking about Unit 27 7           2     Y o r. .
3 Q
8           A     As I think I me r.t io ned --
Do you recall a procedure called unit 4
9           Q    Or Unit 12
startup operating procedure that was in effect before (g) 5 the accident?
6 A
You are talking about Unit 27 7
2 Y o r..
8 A
As I think I me r.t io ned 9
{
{
10 i         A     Okay, for Urti t i trers waJ A startup
Q Or Unit 12 10 i A
[I 11     procedure, I recall that.
Okay, for Urti t i trers waJ A startup
12           Q     Was there a heat up/cocidown curve as part
[I 11 procedure, I recall that.
['l         13     of that procedure?
12 Q
  'u/
Was there a heat up/cocidown curve as part
l l             14             A     I don't recali.
['l 13 of that procedure?
j             15           Q     Was there a procedure in effect before i
'u/
l             16     the accident for Unit 2 or Unit 1 called pressurizer 17     operating operating procedure?
l l
              '8
14 A
              .            A    For Unit   1, to the best of my recollection, 19     there was.
I don't recali.
20             Q     How about Unit 2?
j 15 Q
21             A     I don't recall.
Was there a procedure in effect before i
O   22             Q     Was there a heat up/cooldown curve that 23     was part of that procedure?
l 16 the accident for Unit 2 or Unit 1 called pressurizer 17 operating operating procedure?
  ,_        24             A     I don't recall. I don't remember.
'8 A
I     )
For Unit 1,
    ~
to the best of my recollection, 19 there was.
25             Q     Was there a procedure in effect prior to
20 Q
How about Unit 2?
21 A
I don't recall.
O 22 Q
Was there a heat up/cooldown curve that 23 was part of that procedure?
24 A
I don't recall.
I don't remember.
I
)
~
25 Q
Was there a procedure in effect prior to


I 1                                           Zachmen                                 682
I 1
(             2                   the Three Mile Island accident called reactor coolant 3                   pump operating procedure?
Zachmen 682
4                           A     I don't recall either way.
(
ggg   5                           Q   For either unit?
2 the Three Mile Island accident called reactor coolant 3
6                           A   Either unit.
pump operating procedure?
7 -                         Q   I take it you don't recall whether there                         '
4 A
i'                                                                                  I 1
I don't recall either way.
8                   was a-heat up/cooldown curve ac part of that procedure?
ggg 5
l A     I don't recall.
Q For either unit?
9 il                                                                                            '
6 A
l1                                                                                   ,
Either unit.
10 I                       Q     Nas there c procedure in e2fect befote the                     '
7 -
11                   Three Mile Islan6 accident known as power operations?
Q I take it you don't recall whether there I
I
i 1
,                12                         A     To the best of my recollectioat there was               j i                                                                                     l
8 was a-heat up/cooldown curve ac part of that procedure?
    /           13                     for Unit 1.                                                         j k
l 9 il A
14                           Q     How ahottt for Unit 27 15                         A     There was one that was similar to it.               I 16                   don't recall the exact title.
I don't recall.
17                         Q     Whatever the title of it wac, the substance 18                   was comparable?
l1 10 I Q
19                           A     I can't say because I don't recall what 20                   the substance of the Unit 2 one was.
Nas there c procedure in e2fect befote the 11 Three Mile Islan6 accident known as power operations?
21                           Q     Was there a heat up/cooldown curve as part O   22                   of that procedure?
I 12 A
23                           A     I don't recall.
To the best of my recollectioat there was j
24                           Q     Was there a procedure in effect prior to 25                   the Three Mile Island accident called unit shutdown?
i l
/
13 for Unit 1.
j k
14 Q
How ahottt for Unit 27 15 A
There was one that was similar to it.
I 16 don't recall the exact title.
17 Q
Whatever the title of it wac, the substance 18 was comparable?
19 A
I can't say because I don't recall what 20 the substance of the Unit 2 one was.
21 Q
Was there a heat up/cooldown curve as part O
22 of that procedure?
23 A
I don't recall.
24 Q
Was there a procedure in effect prior to 25 the Three Mile Island accident called unit shutdown?
I
I
_ _ _ _ . _ _.        ,      ,        ,    ,_m -- _  __  - - - - - - - -          --
,_m


Zochitan                   683 1
Zochitan 683 1
A     There was a shutdown procedure for Unit   1.
A There was a shutdown procedure for Unit 1.
(3 i     l         2 I don't recall the exact title. I don't recall the 3
(3 i
l 2
I don't recall the exact title.
I don't recall the 3
title if there was one for Unit 2.
title if there was one for Unit 2.
4 Q     Was there a heat up/cooldown curve as part of that procedure?
4 Q
C A     I don't recall.                               '
Was there a heat up/cooldown curve as part of that procedure?
7 Q     We icoked at the decay heat removal via 8     l
C A
                          ,! OTSG, 6.nd we have all seen that there is a beet up/
I don't recall.
9     I I cooldown curv6 for that one.
7 Q
10 i                                                                   i
We icoked at the decay heat removal via 8
                      !                                                                i A     Yes.
l OTSG, 6.nd we have all seen that there is a beet up/
11   (;l                                                              ;
9 I
ft           Q     Was there a procedure in effect befcre the   4 12  Il                                                               f
I cooldown curv6 for that one.
                      ,Il   Three Mile Xstand accident called unit cooldown?           '
10 i i
i
(;l A
Yes.
11 ft Q
Was there a procedure in effect befcre the 4
Il f
12
,Il Three Mile Xstand accident called unit cooldown?
j f
j f
t      *
$3 7 t
                  $3 7' i
i'
      '' J A     I don't recall either way.
'' J A
14 Q     For either unit?
I don't recall either way.
15 A     For either unit.
14 Q
16 Q     So I take it you don't recall whether there 17 l                           was a heat up/cooldown curve for any such procedure?
For either unit?
18 l                                   A     I don't recall.
15 A
19 Q     Was there a procedure called decay heat l               20 l                           removal system?
For either unit.
21 lll                   A     There was a procedure called decay heat removal for Unit   1. I don 't recall if there was a 23 corresponding specific title for Unit 2 on procedure.
16 Q
l               24 r%
So I take it you don't recall whether there 17 l
(                                   Was there any heat up/cooldown curve as l
was a heat up/cooldown curve for any such procedure?
          )                        Q 25 i
18 l
A I don't recall.
19 Q
Was there a procedure called decay heat l
20 l
removal system?
21 lll A
There was a procedure called decay heat removal for Unit 1.
I don 't recall if there was a 23 corresponding specific title for Unit 2 on procedure.
l 24 r%
(
)
Q Was there any heat up/cooldown curve as l
25 i
{
{


1                                 Zschmen                       684
1 Zschmen 684
                                      /
/
(~m                   part of that procedure?
(~m
2
(% -)
(% -)
3           A       I don't recall.
2 part of that procedure?
4           Q       Was there a procedure called reactor trip ggg   5     emergency procedure?
3 A
6           A       For Unit 1 there was a reactor trip 7     procedore, to.the best of my recollection.           I don 't 8   rscall if there was a corresponding title for Unit 2.           -
I don't recall.
9           0       has there a haat up/cooldown curve as part 10 t of that; procedure?                                                 ,
4 Q
I                                                                   '
Was there a procedure called reactor trip ggg 5
11 l           A       2 don't recall.                                   -
emergency procedure?
I                                                                           '
6 A
l                  12  h        .Q       Was there a procedure in effect before the
For Unit 1 there was a reactor trip 7
("S I                  is     a c c a d e r.t called station blackout?
procedore, to.the best of my recollection.
    \~]
I don 't 8
14             A       'To the best of my recollection, there was '
rscall if there was a corresponding title for Unit 2.
15     a procedure with that title for Unit       1.     I don't 16     recall if there was a corresponding procedure for 17     Unit 2 or its title.
9 0
l l                 18           Q       Was there a heat up/cooldown curve as part l                 19     of that procedure?
has there a haat up/cooldown curve as part 10 t of that; procedure?
I 11 l A
2 don't recall.
I h
.Q Was there a procedure in effect before the l
12 I
("S is a c c a d e r.t called station blackout?
\\~]
14 A
'To the best of my recollection, there was '
15 a procedure with that title for Unit 1.
I don't 16 recall if there was a corresponding procedure for 17 Unit 2 or its title.
l l
18 Q
Was there a heat up/cooldown curve as part l
19 of that procedure?
l c
l c
20             A       I don't recall.
20 A
21             Q       Regardless of the specific titles of the l             h
I don't recall.
(                 22     variods procedures, having read you the titles that I l
21 Q
l                 23     just did, do you recall whether or not there were in
Regardless of the specific titles of the l
    ,'~h. '
h
24     fact procedures designed to deal with the types of
(
22 variods procedures, having read you the titles that I l
l 23 just did, do you recall whether or not there were in 24 fact procedures designed to deal with the types of
, ~h. '
[
[
    \'' I 25     conditions or circumstances reflected in the titles
! \\'' I 25 conditions or circumstances reflected in the titles
                                                                            /
/
I i
I i
l l                                                                       -._.
l l


1                                                           Zechman                                                                                 685
1 Zechman 685
()                                 2   that I just read?
()
3         A           I have forgotten the titles you went 4   through.
2 that I just read?
l ggg                       5         Q           Unit heat up operating procedure, unit 6   startup operating procedure, pressurizer operation, 7   reactor coolant pump operation, power operations, unit 8 shutdown, decay heat removal system, unit cooldown, 9 reactor trip, station blackout.
3 A
10             A           Repeat your initial question.
I have forgotten the titles you went 4
11                         (Question read.)
through.
12               A           Can I ask for a clarification?                                                                         You are 13       saying, for example, if there is a procedure called                                                                                                               i f~)T u.
l ggg 5
14       reactor trip procedure, that it dealt with a reactor 15       trip?
Q Unit heat up operating procedure, unit 6
16             Q           Yes. In other words --
startup operating procedure, pressurizer operation, 7
17               A           It could have. dealt with some other things i
reactor coolant pump operation, power operations, unit 8
18       but would it have dealt with what the title said?
shutdown, decay heat removal system, unit cooldown, 9
l                                   19               Q           I wanted to be sure when you were 20       answering my questions that you were not limiting your 21       answer to a procedure with a specific wording of j                                  22       the one that I read to you.                                               I wanted to be sure that 23       your answers are given in the context that I was asking 24     'whether there were procedures                                                   not only with that i
reactor trip, station blackout.
O                            25       specific title but also procedures that governed the                                                                                   s I
10 A
      , -_            . _ - . _ . _            _      _.-        . , . - , _ , _ . . _ , . - _                    ._,__.,__..,m_,,_  _ . _ _ , . . _ . _ _ _ ,              , . , _        . . _ _ . _
Repeat your initial question.
11 (Question read.)
12 A
Can I ask for a clarification?
You are f~)T 13 saying, for example, if there is a procedure called i
u.
14 reactor trip procedure, that it dealt with a reactor 15 trip?
16 Q
Yes.
In other words --
17 A
It could have. dealt with some other things i
18 but would it have dealt with what the title said?
l 19 Q
I wanted to be sure when you were 20 answering my questions that you were not limiting your 21 answer to a procedure with a specific wording of 22 the one that I read to you.
I wanted to be sure that j
23 your answers are given in the context that I was asking 24
'whether there were procedures not only with that O
i 25 specific title but also procedures that governed the s
I
._,__.,__..,m_,,_


s s 1                               Zechm'an                     686 2       type of situation that was describe in the title, i
s s
3      whether or not you remembered the exact title of the 4       procedure.
1 Zechm'an 686 2
lll               5             A   To the best of my recollection, the ones 6       that you have named were procedures that dealt with 7       at least what the title implied. Sometimes some of 8       those titles were tied together into a single procedure, 9       that's what is confusing the issue in my mind right 10       now, whether they were separate procedures or titles 11       or sometimes combined titles.
type of situation that was describe in the title, 3
12               Q   I want to make cure I understand your
whether or not you remembered the exact title of the i
()                   13       answers when you were saying you didn't recall one way 14       or.the other if there were certain procedures in effect 15       at Unit 2, but you.did remember such a procedure for 16       Unit 1, youweregiving[that answer in the context not 17       simply of a procedure with that specific title but a l                           18       procedure dealing with the subject matter reflected l
4 procedure.
19       in the title, do you follow me?
lll 5
20   '
A To the best of my recollection, the ones 6
A    I understand. To the best of my recollection I
that you have named were procedures that dealt with 7
e     21 '
at least what the title implied.
I was.
Sometimes some of 8
22               Q   I would like to show you, Mr. Zechman, l               ',
those titles were tied together into a single procedure, 9
that's what is confusing the issue in my mind right 10 now, whether they were separate procedures or titles 11 or sometimes combined titles.
12 Q
I want to make cure I understand your
()
13 answers when you were saying you didn't recall one way 14 or.the other if there were certain procedures in effect 15 at Unit 2, but you.did remember such a procedure for 16 Unit 1, youweregiving[that answer in the context not 17 simply of a procedure with that specific title but a l
18 procedure dealing with the subject matter reflected l
19 in the title, do you follow me?
20 A
I understand.
To the best of my recollection I
e 21 I was.
22 Q
I would like to show you, Mr. Zechman, 23 a document previously marked as B&W Exhibit 540, which l
L.
L.
23        a document previously marked as B&W Exhibit 540, which 24       is Unit 2 operating procedure 2102-3.2 called Unit Os 25       Cooldown.
24 is Unit 2 Os operating procedure 2102-3.2 called Unit 25 Cooldown.
  ,    Tr '
Tr '
i,               .k l
i,
.k l


1                                               Zechman                     687
1 Zechman 687
()           2                                     Do you have that in front of you?
()
3             A                       I have that in front of me.
2 Do you have that in front of you?
4           Q                       What is cooldown?
3 A
lll       5                                     MR. MacDONALD:   Apart from the procedure?
I have that in front of me.
6                                     MR. FISKE:   Yes.
4 Q
7           Q                       Just generally, in the same sense I asked 8     you before what is decay heat removal, I would like 9     to know basically what is cooldown.
What is cooldown?
10           A                       When you are shutting down the plant, you are 11     cooling down the system, the RC system.
lll 5
12           Q                       Would this be a procedure that is a cooldown
MR. MacDONALD:
()         13       procedure that would be in effect at some point in time 14       after there had been a reactor trip as a result of a 15     transient?
Apart from the procedure?
16           A                       I have not used this procedure. I can only 17     say that this says that it's a Unit 2 procedure, 18       cooldown.
6 MR. FISKE:
19             Q                     yithout reference to this specific procedure, 20       is it correct that the process of cooldown as you have 21       described it a moment ago would follow a reactor trip 22       as a result of a transient?
Yes.
23             A                     To the best of my recollection, yes, sir.
7 Q
24             Q                       In other words, after a transient occurs, 73 V
Just generally, in the same sense I asked 8
25       one of the things you try to do is get the plant back
you before what is decay heat removal, I would like 9
to know basically what is cooldown.
10 A
When you are shutting down the plant, you are 11 cooling down the system, the RC system.
12 Q
Would this be a procedure that is a cooldown
()
13 procedure that would be in effect at some point in time 14 after there had been a reactor trip as a result of a 15 transient?
16 A
I have not used this procedure.
I can only 17 say that this says that it's a Unit 2 procedure, 18 cooldown.
19 Q
yithout reference to this specific procedure, 20 is it correct that the process of cooldown as you have 21 described it a moment ago would follow a reactor trip 22 as a result of a transient?
23 A
To the best of my recollection, yes, sir.
24 Q
In other words, after a transient occurs, 73 V
25 one of the things you try to do is get the plant back


1                                                 zechman                         688
1 zechman 688
(_j         2 to normal conditions as part of a cooldown process, 3 correct?
(_j 2
4               A     Following a trip, if you are shutting lll     5 the plant down, you are going to cool it down, it's 6 a cooldown procedure.
to normal conditions as part of a cooldown process, 3
9 7               Q     It's a procedure on the way to shut down 8 after a trip, correct?
correct?
9               A     Yes, sir.                   I was referring to the general 10 title cooldown, not this particular procedure.
4 A
4            11               12     I understand.                     Now, I would like you to 12 look at the specific procedure.                               Particularly page 3.0
Following a trip, if you are shutting lll 5
()       13 paragraph 2.1.1, which reads under the heading " Limits 14 and Precautions," " Reactor coolant temperature / pressure 15 and cooldown rates shall be maintained within the 16 limits specified in Figures 3.4-2 and 3.4-3 of 17 TS 3.4.9.1.           Refer to Figures 1 and 2 attached."
the plant down, you are going to cool it down, it's 6
l 18                       Just a preliminary question.                       Does TS 19 refer to technical specifications?
a cooldown procedure.
l j             20                       MR. MacDONALD:                     You are asking for his 21                 recollection?
9 7
O     22                       MR.'FISKE:                   His understanding of       --
Q It's a procedure on the way to shut down 8
l l            23               A     To the best of my recollection, it is.
after a trip, correct?
(~g      24               Q     Would you look at Figures 1 and 2 that l   \_)
9 A
l             25 are part of this.
Yes, sir.
I was referring to the general 10 title cooldown, not this particular procedure.
11 12 I understand.
Now, I would like you to 4
12 look at the specific procedure.
Particularly page 3.0
()
13 paragraph 2.1.1, which reads under the heading " Limits 14 and Precautions," " Reactor coolant temperature / pressure 15 and cooldown rates shall be maintained within the 16 limits specified in Figures 3.4-2 and 3.4-3 of 17 TS 3.4.9.1.
Refer to Figures 1 and 2 attached."
l 18 Just a preliminary question.
Does TS 19 refer to technical specifications?
l j
20 MR. MacDONALD:
You are asking for his 21 recollection?
O 22 MR.'FISKE:
His understanding of l
l 23 A
To the best of my recollection, it is.
24 Q
Would you look at Figures 1 and 2 that
(~g l
\\_)
l 25 are part of this.
l
l


1                                                                       Zechman                                       689 2                       A                   1 and 2?
1 Zechman 689 2
3                       Q                   Let's start with Figure                                     1.
A 1 and 2?
4                                           Do you have Figure 1 in front of you?                                         ,
3 Q
g                  5 h
Let's start with Figure 1.
A                   Yes.
4 Do you have Figure 1 in front of you?
6                     Q                   That is a heat up/cooldown curve?
h 5
7                     A                   That's its title.
A Yes.
8                     Q                   Isn't that the same curve that we were just 9   looking at a moment ago which was part of the decay 10       heat removal procedure?
g 6
11                       A                     I haven't compared them.
Q That is a heat up/cooldown curve?
12                         Q                     Do you want to take a minute and do that.
7 A
!                            13       Before you do that, Mr. Zechman, was it your under-14         standing before the accident that there were different 15       heat up/cooldown curves appliable to different 16       procedures?
That's its title.
17                       A                     Not to the best of my recollection.
8 Q
18                         Q                     I would like to turn to page 6.0 and i
Isn't that the same curve that we were just 9
i 19         paragraph 2.2.9, which reads, "If any safety equipment 20         defined in technical specification 2.1 and 2.2 is
looking at a moment ago which was part of the decay 10 heat removal procedure?
!                        21           exceeded, the shift supervisor shall notify the t
11 A
22           station unit superintendent.                                                         The reactor shall be 23           placed in hot standby within one hour.                                                                 The licensee 24           shall notify the Commission, review the matter and I
I haven't compared them.
l                         25           record the results of the review including the cause r
12 Q
Do you want to take a minute and do that.
13 Before you do that, Mr. Zechman, was it your under-14 standing before the accident that there were different 15 heat up/cooldown curves appliable to different 16 procedures?
17 A
Not to the best of my recollection.
18 Q
I would like to turn to page 6.0 and i
i 19 paragraph 2.2.9, which reads, "If any safety equipment 20 defined in technical specification 2.1 and 2.2 is 21 exceeded, the shift supervisor shall notify the 22 station unit superintendent.
The reactor shall be t
23 placed in hot standby within one hour.
The licensee 24 shall notify the Commission, review the matter and I
l 25 record the results of the review including the cause r
l l
l l


1                         Zechman                     690 2 of the condition and the basis for corrective action 3 taken to preclude reoccurrence. Operation shall not 4 be resumed until authorized by the Commission."
1 Zechman 690 2
lll   5 The safety limit defined in technical specification 6 2.1 refers to the same technical specification that I 7 read to yoh earlier, does it not, concerning safety 8 limits for the reactor core?
of the condition and the basis for corrective action 3
9       A     I don't recall the numbers -- I don't recall 10 whether 2.1 --
taken to preclude reoccurrence.
11         Q     Would you look at it so there is no question.
Operation shall not 4
12 It's B&W 572.
be resumed until authorized by the Commission."
()     13               MR. MacDONALD: You are' asking now his 14         recollection of these things prior to the 15         accident. Not just comparing these documents?
lll 5
16               MR. FISKE:   Sure. His understanding prior 17         to the accident when this refers to technical 18         specification 2.1, was he aware prior to the 19         accident of any technical specification 2.1 20         other than the one that has been previously 21         shown which he now has in front of him.
The safety limit defined in technical specification 6
22         A     Assuming that I have the current tech spec 23   that was associated at the time this procedure was in 24   effect, these two correspond.
2.1 refers to the same technical specification that I 7
25         Q     It says in this paragraph, "The licensee
read to yoh earlier, does it not, concerning safety 8
limits for the reactor core?
9 A
I don't recall the numbers -- I don't recall 10 whether 2.1 11 Q
Would you look at it so there is no question.
12 It's B&W 572.
()
13 MR. MacDONALD: You are' asking now his 14 recollection of these things prior to the 15 accident.
Not just comparing these documents?
16 MR. FISKE:
Sure.
His understanding prior 17 to the accident when this refers to technical 18 specification 2.1, was he aware prior to the 19 accident of any technical specification 2.1 20 other than the one that has been previously 21 shown which he now has in front of him.
22 A
Assuming that I have the current tech spec 23 that was associated at the time this procedure was in 24 effect, these two correspond.
25 Q
It says in this paragraph, "The licensee


1                                 Zachman                                   691
1 Zachman 691
        )           2   shall notify the Commission."
)
3                 What commission was that referring to?
2 shall notify the Commission."
4               A The NRC, Nuclear Regulatory Commission.
3 What commission was that referring to?
lll       5               Q Were you f amiliar with this requirement 6   of the unit cooldoen procedure prior to the Three Mile 7   Island accident?
4 A
8               A As I said, I don't recall this procedure.
The NRC, Nuclear Regulatory Commission.
9               Q Do you recall any part of any procedure 10   which required you to notify the Commission if safety 11   limits were exceeded?
lll 5
12                 A I certainly recognize and understand
Q Were you f amiliar with this requirement 6
()           13     that when safety limits were exceeded we notified 14     the commission.
of the unit cooldoen procedure prior to the Three Mile 7
15                 Q Wasn't it your understanding, Mr. Zechman, 16     that not following a heat up/cooldown curve could 17     result in a violation of a safety limit which would 18     require reporting to the NRC7 19               A I don't recall.
Island accident?
20               Q Going back, Mr. Zechman, to the decay heat l                 21     removal procedure, do you have that in front of you?
8 A
22               A 2102-3.37 23                 Q Yes.
As I said, I don't recall this procedure.
24               A Yes, sir, I do.
9 Q
Do you recall any part of any procedure 10 which required you to notify the Commission if safety 11 limits were exceeded?
12 A
I certainly recognize and understand
()
13 that when safety limits were exceeded we notified 14 the commission.
15 Q
Wasn't it your understanding, Mr. Zechman, 16 that not following a heat up/cooldown curve could 17 result in a violation of a safety limit which would 18 require reporting to the NRC7 19 A
I don't recall.
20 Q
Going back, Mr. Zechman, to the decay heat l
21 removal procedure, do you have that in front of you?
22 A
2102-3.37 23 Q
Yes.
24 A
Yes, sir, I do.
i
i
(
(
25               Q I would like to direct your attention
25 Q
I would like to direct your attention


1                             Zechman                     692 2   to page 4.0, paragraph at the top of the page, 2.1.7, 3   which reads, "During decay heat removal by natural 4   circulation maintain TH"     --
1 Zechman 692 2
that's temperature in the lll       5   hot leg?
to page 4.0, paragraph at the top of the page, 2.1.7, 3
6         A     Normally TH refers to temperature in the 7   hot leg.
which reads, "During decay heat removal by natural 4
8         Q     --
circulation maintain TH" that's temperature in the lll 5
                                      "30 degrees Fahrenheit below the 9   saturation temperature corresponding to pressurizer 10   pressure in order to prevent boiling in the hot legs."
hot leg?
11                 Do you see that?
6 A
12           A     I see that.
Normally TH refers to temperature in the 7
hot leg.
8 Q
"30 degrees Fahrenheit below the 9
saturation temperature corresponding to pressurizer 10 pressure in order to prevent boiling in the hot legs."
11 Do you see that?
12 A
I see that.
(
(
13           Q -
13 Q
What was your understanding of the purpose 14   of that re quiremen t?
What was your understanding of the purpose 14 of that re quiremen t?
15           A     I don't recall using this procedure, so I 16   have no recollection of what that means.
15 A
17           Q     Do you know what boiling in the hot legs 18   refers to in that procedure?
I don't recall using this procedure, so I 16 have no recollection of what that means.
19           A     No, sir, I do not. I have no recollection l             20   what that means.
17 Q
21           Q     What do you understand the saturation 22   temperature corresponding to the pressurizer pressure 23   to mean?
Do you know what boiling in the hot legs 18 refers to in that procedure?
24           A     You are asking me to interpret that 25   sentence, the saturation temperature   --
19 A
l
No, sir, I do not.
I have no recollection l
20 what that means.
21 Q
What do you understand the saturation 22 temperature corresponding to the pressurizer pressure 23 to mean?
24 A
You are asking me to interpret that 25 sentence, the saturation temperature l


1                                           Zechman                                                                       693 O
1 Zechman 693 O
  \s_)\                         2                 MR. MacDONALD:                 Recollection again prior 3           to the accident as to what those words meant.
\\ _)\\
4                 THE WITNESS:                 In relationship to this lll-                 5         procedure?
2 MR. MacDONALD:
6         Q     Generally.
Recollection again prior s
7                 MR. MacDONALD:                 Just a second.                                                     Can we 8         have the question so we can have an understanding 9         of what you are talking about.                                                                 The witness is 10         confused. He was asked quesitons about this 11         paragraph relating to what he understood the 12           words meant.
3 to the accident as to what those words meant.
Before the accident, Mr. Zechman, did
4 THE WITNESS:
(                          13          Q 14     you understand what boiling in the hot legs was?
In relationship to this lll-5 procedure?
15           A     No recollection of what the terminology 16     referred to.
6 Q
17           Q     You mean if somebody had come to you 18     in the course of a transient and said,                                                                   "Mr. Zechman, 19     I thinn we have got a problem," and said, "We have 20     got boiling in the hot legs," you wouldn't know what 21     he was talking about?
Generally.
l                             22           A     I could interpret what he is saying.                                                                     I am l
7 MR. MacDONALD:
23     not going to interpret what the meaning of this was.
Just a second.
gS                          24           Q     what was the concept, boiling in the hot V
Can we 8
25     legs, as you understood it?
have the question so we can have an understanding 9
of what you are talking about.
The witness is 10 confused.
He was asked quesitons about this 11 paragraph relating to what he understood the 12 words meant.
(
13 Q
Before the accident, Mr. Zechman, did 14 you understand what boiling in the hot legs was?
15 A
No recollection of what the terminology 16 referred to.
17 Q
You mean if somebody had come to you 18 in the course of a transient and said, "Mr.
: Zechman, 19 I thinn we have got a problem," and said, "We have 20 got boiling in the hot legs," you wouldn't know what 21 he was talking about?
l 22 A
I could interpret what he is saying.
I am l
23 not going to interpret what the meaning of this was.
24 Q
what was the concept, boiling in the hot gS V
25 legs, as you understood it?


1                                         Zechman                                           694       .
1 Zechman 694 1
l 1
()
()               2               A         I didn't understand before the accident.
2 A
3 I said I would -- I said the only thing I would do if 4 you asked me was to speculate what that means, and lll         5 that's pure speculation.
I didn't understand before the accident.
6               Q       Go back to the question I just asked and 7 if someone came up to you and said "We have got a 8 problem, we have got boiling in the hot legs," would 9 you have understood what he was talking about?
3 I said I would -- I said the only thing I would do if 4
10                         MR. MacDONALD:         I object to the form.
you asked me was to speculate what that means, and lll 5
11                         You can answer.
that's pure speculation.
12                 A         I am afraid I would have to ask him to
6 Q
()             13 define what he is talking about.
Go back to the question I just asked and 7
14                 Q       Were you familiar with the concept of 15 saturation temperature corresponding to pressurizer 16 pressure?
if someone came up to you and said "We have got a 8
17                 A       As it refers to the pressurizer?
problem, we have got boiling in the hot legs," would 9
I 18                 Q       Yes.
you have understood what he was talking about?
19                 A       Whatever the saturation pressure is for l
10 MR. MacDONALD:
l 20   that -- whatever the saturation temperature is for that l
I object to the form.
21   pressure.
11 You can answer.
22                 Q       Did'you have any understanding before the 23 accident as to why during decay heat removal by natural
12 A
                ~ 24   circulation, it would have been important to have 25 maintained temperature in the hot leg 30 degrees
I am afraid I would have to ask him to
()
13 define what he is talking about.
14 Q
Were you familiar with the concept of 15 saturation temperature corresponding to pressurizer 16 pressure?
17 A
As it refers to the pressurizer?
I 18 Q
Yes.
19 A
Whatever the saturation pressure is for l
l l
20 that -- whatever the saturation temperature is for that 21 pressure.
22 Q
Did'you have any understanding before the 23 accident as to why during decay heat removal by natural
~ 24 circulation, it would have been important to have 25 maintained temperature in the hot leg 30 degrees


1                         zechman                     695
1 zechman 695
(         2 Fahrenheit below tea saturation temperature corresponding 3 to pressurizer pressure?
(
4         A     I don't recall seeing this procedure or lll   5 that statement and, therefore, it would be speculation 6 in interpreting what that means, sir.
2 Fahrenheit below tea saturation temperature corresponding 3
7       Q     I am not asking you to interpret a 8 procedure. I am just asking yo. whether by reference 9 to the procedure or not, did you understand that 10 during decay heat removal by natural circulation, it 11 was important to maintain temperature in the hot leg, 12 30 degrees Fahrenheit below the saturation temperature
to pressurizer pressure?
()     13 corresponding to pressurizer pressure?
4 A
14         A     I have no recollection of that concept.
I don't recall seeing this procedure or lll 5
15         Q     Did you understand it was important to 16 maintain temperature in the hot leg at any degrees
that statement and, therefore, it would be speculation 6
;          17 Fahrenheit below the saturation temperature cor-
in interpreting what that means, sir.
)           18 responding to the pressurizer pressure?
7 Q
19         A     As it applies to this procedure?
I am not asking you to interpret a 8
20         Q     No.
procedure.
21         A     I never used that terminology so -- the 22   answer is I have no recollection.
I am just asking yo. whether by reference 9
23         Q     Did you understand that during decay heat 24   removal by natural circulation that it was important 25   to maintain any pressure / temperature relationship?
to the procedure or not, did you understand that 10 during decay heat removal by natural circulation, it 11 was important to maintain temperature in the hot leg, 12 30 degrees Fahrenheit below the saturation temperature
()
13 corresponding to pressurizer pressure?
14 A
I have no recollection of that concept.
15 Q
Did you understand it was important to 16 maintain temperature in the hot leg at any degrees 17 Fahrenheit below the saturation temperature cor-
)
18 responding to the pressurizer pressure?
19 A
As it applies to this procedure?
20 Q
No.
21 A
I never used that terminology so -- the 22 answer is I have no recollection.
23 Q
Did you understand that during decay heat 24 removal by natural circulation that it was important 25 to maintain any pressure / temperature relationship?
I
I


1                         Zechman                         696 c
1 Zechman 696 c
p
p(,)
(,)       2       A     There were temperature and pressure 3 relationships but I just don't recall what they were.
2 A
4       Q     I am not asking you to give me the specific lll   5 degrees or pounds per square inch, but do you recall 6 that it was important to maintaining certain pressure /
There were temperature and pressure 3
relationships but I just don't recall what they were.
4 Q
I am not asking you to give me the specific lll 5
degrees or pounds per square inch, but do you recall 6
that it was important to maintaining certain pressure /
7 temperature relationship?
7 temperature relationship?
8             MR. MacDONALD:   Specifically now with 9       natural circulation?
8 MR. MacDONALD:
10             MR. FISKE:   During decay heat removal.
Specifically now with 9
11       A     I can only recall that there were 12 temperature considerations that we looked at and O                                                           *
natural circulation?
(_j     13 pressure, but that is as far as I can answer, sir.
10 MR. FISKE:
14       Q     You did know, did you not, that the 15 pressure / temperature envelope concept that you have 16 described earlier applied to decay heat removal?
During decay heat removal.
17       A     I don't recall.
11 A
18       Q     Do you understand that question?   Maybe 19 you would like to have it read again.
I can only recall that there were 12 temperature considerations that we looked at and O
20       A     Read it again.
(_j 13 pressure, but that is as far as I can answer, sir.
21               (Question read.)
14 Q
22       A     I don't recall.
You did know, did you not, that the 15 pressure / temperature envelope concept that you have 16 described earlier applied to decay heat removal?
23       Q     Earlier, Mr. Zechman, in this deposition (7b) 24 we showed you volume 5 of the final safety analysis LJ 25 report prepared by Metropolitan Edison Company and
17 A
I don't recall.
18 Q
Do you understand that question?
Maybe 19 you would like to have it read again.
20 A
Read it again.
21 (Question read.)
22 A
I don't recall.
23 Q
Earlier, Mr. Zechman, in this deposition (7b) 24 we showed you volume 5 of the final safety analysis LJ 25 report prepared by Metropolitan Edison Company and


1                         Zechman                     697 rh
1 Zechman 697 rh
(_)     2 submitted to the Nuclear Regulatory Commission in order 3 to obtain an operating license for Unit 2.
(_)
4               I would like to show you a section from lll   5 that 5.5.10, pressurizer. Right under that 5.5.10.1, 6 design basis and it reads, "The pressurizer is 7 designed to provide a capability of maintaining the 8 reactor coolant system at saturation pressure to 9 prevent boiling of the coolant."
2 submitted to the Nuclear Regulatory Commission in order 3
10               Do you see that?
to obtain an operating license for Unit 2.
11       A     I see that.
4 I would like to show you a section from lll 5
12       Q     Were you familiar with that concept before
that 5.5.10, pressurizer.
()     13 the accident?
Right under that 5.5.10.1, 6
14       A     I don't recall this one.
design basis and it reads, "The pressurizer is 7
15       Q     I am not -- for the moment I am not asking 16 you whether you read this particular part of the FSAL.
designed to provide a capability of maintaining the 8
17 First I am simply asking you whether you were aware 18 prior to the accident of the concept that is expressed 19 in the sentence that I just read.
reactor coolant system at saturation pressure to 9
20       A     I told you that from a theoretical 21 standpoint I understood that pressure / temperature 22 relationship, that it did not occur to me prior to 23  the accident  --
prevent boiling of the coolant."
did not occu'r to me prior to the 24 accident having a saturated or boiling condition in
10 Do you see that?
11 A
I see that.
12 Q
Were you familiar with that concept before
()
13 the accident?
14 A
I don't recall this one.
15 Q
I am not -- for the moment I am not asking 16 you whether you read this particular part of the FSAL.
17 First I am simply asking you whether you were aware 18 prior to the accident of the concept that is expressed 19 in the sentence that I just read.
20 A
I told you that from a theoretical 21 standpoint I understood that pressure / temperature 22 relationship, that it did not occur to me prior to did not occu'r to me prior to the 23 the accident 24 accident having a saturated or boiling condition in
{)g
{)g
    \-
\\-
25 the coolant.
25 the coolant.


1                         Zechman                     698
1 Zechman 698
  \m)       2       Q     You didn't know before the accident that 3 the pressurizer was designed to provide a capability 4 of maintaining the pressure at a level sufficient to lll 5 prevent boiling in the coolant?
\\m) 2 Q
6             MR. MacDONALD:   Are you asking him now 7       to interpret the concept supposed as stated 8       in this FSAL or his recollection of it?
You didn't know before the accident that 3
9             MR. FISKE:   Read the question back.
the pressurizer was designed to provide a capability 4
10               (Question read.)
of maintaining the pressure at a level sufficient to lll 5
11       A     I understand from a theoretical standpoint 12 that it maintaine.d pressure and'. elevated pressures in a (3
prevent boiling in the coolant?
V       13 PWR.
6 MR. MacDONALD:
14       Q     That that was done in order to prevent 15 boiling in a coolant, is that correct?
Are you asking him now 7
16       A     I told you I never considered boiling of 17 the coolant in the RC system.
to interpret the concept supposed as stated 8
18       Q     Did you train your operator in the 19 training program that in accordance with this statement 20 from the Met Ed FSAL to the Nuclear Regulatory 21 Commission describing the design basis of the 22 pressurizer that the pressurizer was designed to 23 provide a capability of maintaining the reactor coolant system       a pressure high enough to prevent
in this FSAL or his recollection of it?
(~}      24                  at
9 MR. FISKE:
  \m /
Read the question back.
10 (Question read.)
11 A
I understand from a theoretical standpoint 12 that it maintaine.d pressure and'. elevated pressures in a (3
V 13 PWR.
14 Q
That that was done in order to prevent 15 boiling in a coolant, is that correct?
16 A
I told you I never considered boiling of 17 the coolant in the RC system.
18 Q
Did you train your operator in the 19 training program that in accordance with this statement 20 from the Met Ed FSAL to the Nuclear Regulatory 21 Commission describing the design basis of the 22 pressurizer that the pressurizer was designed to 23 provide a capability of maintaining the reactor
(~}
24 coolant system at a pressure high enough to prevent
\\m /
25 boiling in the coolant 7
25 boiling in the coolant 7


M 1                                                                         Zechman                                           699 1
M 1
2                               A                             Are you asking me if I trained on this 3 paragraph?
Zechman 699 1
4                               Q                             On the concept of that paragraph.
2 A
A                             I don't recall.
Are you asking me if I trained on this 3
llh      5 l                             6                             Q                             Any of your training programs at Met Ed, 7  did you ever try to describe to the operators what 8 the purpose of the pressurizer was?
paragraph?
9                             A                             Yes, we did.
4 Q
10                               Q                             Did you tell them that the purpose of 11   the pressurizer was to keep pressure up above saturation 12   temperature?
On the concept of that paragraph.
13                               A                             we told them the purpose of pressurizer 14   had several functions.                                                 One as a surge tank, one to 15   maintain system pressure.
llh 5
4 16                               Q                             At a certain prescribed level, correct?
A I don't recall.
17                               A                             What do you mean by "certain prescribed 18   level"?
l 6
19                               Q                             Didn't you explain to the operators at 20   any point in the training that they received at Met 21   Ed that a purpose of the pressurizer to be sure that 22   pressure was kept up above the saturation point?
Q Any of your training programs at Met Ed, did you ever try to describe to the operators what 7
23                               A                             we never discussed, to the best of my 24   recollection, the saturation of the RC system.
8 the purpose of the pressurizer was?
25                               Q                             So you never told the operators that it was
9 A
Yes, we did.
10 Q
Did you tell them that the purpose of 11 the pressurizer was to keep pressure up above saturation 12 temperature?
13 A
we told them the purpose of pressurizer 14 had several functions.
One as a surge tank, one to 15 maintain system pressure.
4 16 Q
At a certain prescribed level, correct?
17 A
What do you mean by "certain prescribed 18 level"?
19 Q
Didn't you explain to the operators at 20 any point in the training that they received at Met 21 Ed that a purpose of the pressurizer to be sure that 22 pressure was kept up above the saturation point?
23 A
we never discussed, to the best of my 24 recollection, the saturation of the RC system.
25 Q
So you never told the operators that it was


1                         Zechman                     700
1 Zechman 700
(,)       2 important that pressure be kept up above the saturation 3 point?
(,)
4       A     We taught then that the pressure --
2 important that pressure be kept up above the saturation 3
the lll   5 only recollection I have at this point that we taught 6 them that the purpose of the pressurizer was to 7 maintain system pressure and that it accommodated   --
point?
8 acted as a surge tank to accommodate incoming and 9 outgoing surges and to main'tain system pressure.
4 A
10       Q     My question, which I don't believe you have 11 answered yet, did you ever tell them at any point 12 in the training program that by maintaining system
We taught then that the pressure the lll 5
( ,)     13 pressure that meant that pressure should be maintained 14 above the saturation point?
only recollection I have at this point that we taught 6
15         A     I don't recall.
them that the purpose of the pressurizer was to 7
16         Q     Does that meant that your testimony is as 17 you sit here today that you don't have.any recollection 18 of ever teaching them that concept?
maintain system pressure and that it accommodated 8
19         A     I just don't recall.          .
acted as a surge tank to accommodate incoming and 9
20         Q     Do you recall at any time at any part of 21 the training program that you conducted or that you 22 participated in at Met Ed when there was a discussion 23 of maintaining system pressure, any one of the students
outgoing surges and to main'tain system pressure.
10 Q
My question, which I don't believe you have 11 answered yet, did you ever tell them at any point 12 in the training program that by maintaining system
,-(,)
13 pressure that meant that pressure should be maintained 14 above the saturation point?
15 A
I don't recall.
16 Q
Does that meant that your testimony is as 17 you sit here today that you don't have.any recollection 18 of ever teaching them that concept?
19 A
I just don't recall.
20 Q
Do you recall at any time at any part of 21 the training program that you conducted or that you 22 participated in at Met Ed when there was a discussion 23 of maintaining system pressure, any one of the students
(~}
(~}
24 asking a question, "Well, gee, what happens if pressure
24 asking a question, "Well, gee, what happens if pressure
  <J 25 drops and we can't maintain system pressure?"
'<J 25 drops and we can't maintain system pressure?"


1                               Zechman                     701
1 Zechman 701
( '
( '
2             A     The concept has always been on maintaining 3     pressure and level. I don't recall considering that, 4       sir.
2 A
lll 5             Q     So it's your testimony, and I think this 6       is the last question I have on this, that at no time 7       in the training program, to the best of your 8       recollection, as you sit here today, where the 9     operators taught what would happen if system pressure 10     was not maintained?
The concept has always been on maintaining 3
11             A     other than the relationship of the 12     pressure / temperature envelope relative to DNBR.
pressure and level.
()             13             Q     They were never told what would happen 14       if the pressure dropped even lower than the 15     pressure / temperature relationship that would affect 16       the DNBR, is that correct?
I don't recall considering that, 4
17             A     Read that back.
sir.
18                   (Question read.)
lll 5
19             A     I don't recall it.
Q So it's your testimony, and I think this 6
20             Q     was training given'to the operators at 21     Met Ed during any period of --
is the last question I have on this, that at no time 7
22                   MR. FISKE:   Withdrawn.
in the training program, to the best of your 8
23             Q     Did you believe during the period of time 24       while you were in charge of the training program at 25       Met Ed that it would be important for the operators
recollection, as you sit here today, where the 9
operators taught what would happen if system pressure 10 was not maintained?
11 A
other than the relationship of the 12 pressure / temperature envelope relative to DNBR.
()
13 Q
They were never told what would happen 14 if the pressure dropped even lower than the 15 pressure / temperature relationship that would affect 16 the DNBR, is that correct?
17 A
Read that back.
18 (Question read.)
19 A
I don't recall it.
20 Q
was training given'to the operators at 21 Met Ed during any period of --
22 MR. FISKE:
Withdrawn.
23 Q
Did you believe during the period of time 24 while you were in charge of the training program at 25 Met Ed that it would be important for the operators


1                                 Zechman                   702 2       to be able to determine during the course of a 3       transient whether or not saturation had occurred?
1 Zechman 702 2
4             A     I already testified that prior to the lll             5       accident saturated RC system just didn't occur to me, 6       sir.
to be able to determine during the course of a 3
7               Q     So the answer to my question is no. If 8       you would like to hear it again.
transient whether or not saturation had occurred?
9             A     Please.
4 A
10                     (Question read.)
I already testified that prior to the lll 5
11               A     It did not occur to me prior to the 12       accident, I am sorry.
accident saturated RC system just didn't occur to me, 6
()                   13               Q     Let me show you a document which has 14       already been marked as B&W Exhibit 419 and which is a 15       copy of a letter from Mr. E. G. Ward, senior project l
sir.
16       manager at B&W to Mr. L. C. Lanese, GPU Service 17       Corporation, Parsippany, New Jersey. Subject Three 18       Mile Island Nuclear Station Unit No. 2, ECCS small 19       break analysis.
7 Q
20                   Do you have that document in front of you?
So the answer to my question is no.
21               A     Yes, sir.
If 8
22               Q     Did you ever see this document prior to 23       the Three Mile Island accident?
you would like to hear it again.
(~s                 24               A     I don't recall seeing this document.
9 A
Please.
10 (Question read.)
11 A
It did not occur to me prior to the 12 accident, I am sorry.
()
13 Q
Let me show you a document which has 14 already been marked as B&W Exhibit 419 and which is a 15 copy of a letter from Mr.
E.
G.
Ward, senior project l
16 manager at B&W to Mr.
L.
C.
Lanese, GPU Service 17 Corporation, Parsippany, New Jersey.
Subject Three 18 Mile Island Nuclear Station Unit No.
2, ECCS small 19 break analysis.
20 Do you have that document in front of you?
21 A
Yes, sir.
22 Q
Did you ever see this document prior to 23 the Three Mile Island accident?
(~s 24 A
I don't recall seeing this document.
(_)
(_)
25               Q     Did anyone within the training department
25 Q
        -,r. ---g ---
Did anyone within the training department
-,r.
---g m._


1                                             zechman                           703 2 receive from Mr. Lanese or anyone el'se at GPU Service 3 Corporation the ECCS small break analysis which was 4 sent by B&W to Mr. Lanese, with this letter?
1 zechman 703 2
lll               5         A             I can't speak for other people in my 6 department, whether they personally have seen this or 7 not. I don't recall seeing i t .'
receive from Mr. Lanese or anyone el'se at GPU Service 3
8         Q             Look at the second paragraph of the 9, letter from Mr. Taylor to Mr. varga, do you see that?
Corporation the ECCS small break analysis which was 4
10             A             Yes, sir.             on the cover page, July 16, 19787 11             Q             Yes, which is one of the pages in this 12     exhibit.           This is a letter by which Mr. Taylor, manager 13     of licensing at B&W, forwarded to the Nuclear 14       Regulatory Commission the same ECCS small break 15     analysis that they sent to Mr. Lanese at CPU Service 16     Corporation.
sent by B&W to Mr. Lanese, with this letter?
17                           MR   MacDONALD:           I object if you are 18             asking him to --
lll 5
19                           MR. FISKE:             I am just stating that. Trying 20               to save a little time.
A I can't speak for other people in my 6
21               Q             The second paragraph of this letter says, 22       " Break sizes of .04,                   .055, .07, .085, .10 and .15 23       feet are examined.                 These attached analyses, along
department, whether they personally have seen this or 7
    '^s                     24       with the break analysis in 'ECCS analysis of B&W's
not.
        ]
I don't recall seeing i t.'
25       177FA lowered loop NSS,' constitute a complete t
8 Q
Look at the second paragraph of the 9,
letter from Mr. Taylor to Mr. varga, do you see that?
10 A
Yes, sir.
on the cover page, July 16, 19787 11 Q
Yes, which is one of the pages in this 12 exhibit.
This is a letter by which Mr. Taylor, manager 13 of licensing at B&W, forwarded to the Nuclear 14 Regulatory Commission the same ECCS small break 15 analysis that they sent to Mr. Lanese at CPU Service 16 Corporation.
17 MR MacDONALD:
I object if you are 18 asking him to --
19 MR. FISKE:
I am just stating that.
Trying 20 to save a little time.
21 Q
The second paragraph of this letter says, 22
" Break sizes of
.04,
.055,
.07,
.085,
.10 and.15 23 feet are examined.
These attached analyses, along
'^s 24 with the break analysis in 'ECCS analysis of B&W's
]
25 177FA lowered loop NSS,' constitute a complete t


t 1                               zechman                     704 2       spectrum of small break analyses which we believe 3       to be wholly in accordance with 10 CFR 50.46 and 4       10 CFR 50 Appendix 'K.'"
t 1
llh                       5                   There is attached to the NSS analysis 6       a Figure B-3 which is a graph reflecting pressure f
zechman 704 2
7       versus time for each of the break sizes referred to         ,
spectrum of small break analyses which we believe 3
8      in the paragraph that I just read.
to be wholly in accordance with 10 CFR 50.46 and 4
9                   I would ask you whether or not, Mr.
10 CFR 50 Appendix
                                          - 10       zechman, you were ever made aware by anyone at GPU 11       Service Corporation or anyone else within the Met Ed 12       organization that analyses had been conducted of various
'K.'"
;        ()                               13       break sizes and that a calculation will be made of 14       the expected pressure versus time resulting from 15       these of those break sizes?
llh 5
16               A   You are talking about what my recollection 17       was prior to the accident?
There is attached to the NSS analysis 6
18               Q   Yes.
a Figure B-3 which is a graph reflecting pressure f
19               A   My only recollection at this time prior 20       to the accident that there was an analysis done.     That's 21       my only recollection.
7 versus time for each of the break sizes referred to 8
22               Q   And theunderstanding that you had back 23       before the accident as acting supervisor or as 24       supervisor of training, is this the kind of informa-25       tion you had expected that GPU was to send to your y-     n,,,- ---------, ,
in the paragraph that I just read.
9 I would ask you whether or not, Mr.
- 10 zechman, you were ever made aware by anyone at GPU 11 Service Corporation or anyone else within the Met Ed 12 organization that analyses had been conducted of various
()
13 break sizes and that a calculation will be made of 14 the expected pressure versus time resulting from 15 these of those break sizes?
16 A
You are talking about what my recollection 17 was prior to the accident?
18 Q
Yes.
19 A
My only recollection at this time prior 20 to the accident that there was an analysis done.
That's 21 my only recollection.
22 Q
And theunderstanding that you had back 23 before the accident as acting supervisor or as 24 supervisor of training, is this the kind of informa-25 tion you had expected that GPU was to send to your y-n,,,-
,,v,
,,w--
,n-,,r-r------n.-
-,-a
-.-----,,r
.r,-
,,,_ man-----m-,..
-n
~


1                         Zechman                     705
1 Zechman 705
(_)         2 training department if they received it?
(_)
3             MR. MacDONALD:   You are talking about in 4       the form itself here?
2 training department if they received it?
lll   5             MR. FISKE:   The substance. I don't know 6       if it was the precise language.
3 MR. MacDONALD:
7       A     Sir, I would have to evaluate all of the 8 information that's given here and make some rational 9 determination. In speculation -- it would be 10 speculation at this time.
You are talking about in 4
11       Q     Was it important to you during the period 12 of time you were in charge of the training department "N
the form itself here?
q_)       13 that you have as much information as possible to 14 communicate to your operators about the expected 15 consequences which would flow from a variety of break
lll 5
;            16 sizes which could produce a loss of coolant accident?
MR. FISKE:
l 17       A     It was important for me to have information l
The substance.
18 on small break operating philosophy that an operator need 19   to know'how to recognize it and the results of those 20 different things.
I don't know 6
21       Q     As you understood it prior to the accident, 22 would and which showed the changes in pressure over 23 a time that would be reflected in small breaks of
if it was the precise language.
(~)       24 various sizes, be.useful to the operators in V
7 A
25 diagnosing a transient?
Sir, I would have to evaluate all of the 8
information that's given here and make some rational 9
determination.
In speculation -- it would be 10 speculation at this time.
11 Q
Was it important to you during the period 12 of time you were in charge of the training department "N
q_)
13 that you have as much information as possible to 14 communicate to your operators about the expected 15 consequences which would flow from a variety of break 16 sizes which could produce a loss of coolant accident?
l 17 A
It was important for me to have information l
18 on small break operating philosophy that an operator need 19 to know'how to recognize it and the results of those 20 different things.
21 Q
As you understood it prior to the accident, 22 would and which showed the changes in pressure over 23 a time that would be reflected in small breaks of
(~)
24 various sizes, be.useful to the operators in V
25 diagnosing a transient?


1                         zechman                     706 O'       2             MR. MacDONALD:   You are asking if he 3       thought of that prior to the accident?
1 zechman 706 O'
4             MR. FISKE:   Yes, with that kind of lll   5       information.
2 MR. MacDONALD:
6       A     I didn't consider it at the time so   --
You are asking if he 3
7        Q     You didn't?   You said you don't remember 8 seeing this report. I understand that. I am simply 9 asking you whether in your function as supervisor of 10 training or acting supervisor, did you understand 11 that there could be different changes in pressure over 12 time resulting from small breaks of different sizes?
thought of that prior to the accident?
13       A     To the best of my recollection, I had 14 that kind of an understanding.
4 MR. FISKE:
q            15       C     And did you believe it would be useful 16 for the operators to know in diagnosing a transient 17 what the expected changes in pressure over time would 18 be for different sizes of small breaks?
Yes, with that kind of lll 5
19       A     Since I didn't have that information at 20 hand at that time, I don't know that I considered that 21 at that time.
information.
22       Q     You mean it never occurred to you as head 23 of training that there might be different changes in 25 breaks?
6 A
k                                                               __
I didn't consider it at the time so 7
Q You didn't?
You said you don't remember 8
seeing this report.
I understand that.
I am simply 9
asking you whether in your function as supervisor of 10 training or acting supervisor, did you understand 11 that there could be different changes in pressure over 12 time resulting from small breaks of different sizes?
13 A
To the best of my recollection, I had 14 that kind of an understanding.
15 C
And did you believe it would be useful q
16 for the operators to know in diagnosing a transient 17 what the expected changes in pressure over time would 18 be for different sizes of small breaks?
19 A
Since I didn't have that information at 20 hand at that time, I don't know that I considered that 21 at that time.
22 Q
You mean it never occurred to you as head 23 of training that there might be different changes in 25 breaks?
k


1                           Zechman                     707
1 Zechman 707
  /~T
/~T
  '\ //       2         A     I don't recall what my considerations were 3 at that time.
'\\ //
4         Q     Did you understand that every break in the llh   5 primary system boundary, no matter what size, would 6 Produce exactly the same change in pressure over time?
2 A
7         A     I don't know what I considered at that 8 time. I don't recollect what my thinking was at that
I don't recall what my considerations were 3
        ,      9 time.
at that time.
10         Q     were the operators in the training 11 department trained on the fact that there could be 12 different changes in pressure over time resulting
4 Q
Did you understand that every break in the llh 5
primary system boundary, no matter what size, would 6
Produce exactly the same change in pressure over time?
7 A
I don't know what I considered at that 8
time.
I don't recollect what my thinking was at that 9
time.
10 Q
were the operators in the training 11 department trained on the fact that there could be 12 different changes in pressure over time resulting
[~}
[~}
(_/         13 from different break sizes?
(_/
14         A     I don't recall.
13 from different break sizes?
15         Q     To your knowledge, today as you sit here, 16 do you have any recollection that such training was 17 in fact given?
14 A
18         A     I recall there was small break training 19 given, but I don't recall today all the details of that 20 training.
I don't recall.
21         Q     Did you also receive -- you also received 22 training, did you not, in the course of getting your 23 license on Unit 17
15 Q
  ,CT         24         A     Yes, sir.
To your knowledge, today as you sit here, 16 do you have any recollection that such training was 17 in fact given?
V 25         Q     In the training that you received as a
18 A
I recall there was small break training 19 given, but I don't recall today all the details of that 20 training.
21 Q
Did you also receive -- you also received 22 training, did you not, in the course of getting your 23 license on Unit 17
,CT 24 A
Yes, sir.
V 25 Q
In the training that you received as a


1                             Zechman                 708 O-       2 student at the same time you were head of the training 3 department, did you get training on the fact that 4 different break sizes would produce different changes llh   5 in pressure over time?
1 Zechman 708 O-2 student at the same time you were head of the training 3
6         A     I just don't recall.
department, did you get training on the fact that 4
7               (Recess.)
different break sizes would produce different changes llh 5
in pressure over time?
6 A
I just don't recall.
7 (Recess.)
8 BY MR. FISKE:
8 BY MR. FISKE:
9         Q   Mr. Zechman, prior to the Three Mile Island 10 accident, were you aware of any provisions in any 11 operating procedure or technical specifications regarding 12 the pressurizer level?
9 Q
13         A   I was aware that they existed, that they 14 existed in tech specs and limits and precautions.
Mr. Zechman, prior to the Three Mile Island 10 accident, were you aware of any provisions in any 11 operating procedure or technical specifications regarding 12 the pressurizer level?
15         Q   What did you understand those ground rules 16 were?
13 A
17         A   I can only recall one of them today. That 18 was limit and precautions, there was a statement that 19 says one should not exceed a certain level in the 20 pressurizer under any circumstances except under 21 hydrostatic testing, i         22       Q     What was that level?
I was aware that they existed, that they 14 existed in tech specs and limits and precautions.
15 Q
What did you understand those ground rules 16 were?
17 A
I can only recall one of them today.
That 18 was limit and precautions, there was a statement that 19 says one should not exceed a certain level in the 20 pressurizer under any circumstances except under 21 hydrostatic testing, i
22 Q
What was that level?
l i
l i
23       A     I don't recall the exact number any more.
23 A
l   ~
I don't recall the exact number any more.
l          24         Q     What was the capacity of the pressurizer?
l
25       A     I don't recall those numbers, sir.
~
24 Q
What was the capacity of the pressurizer?
l 25 A
I don't recall those numbers, sir.
l l
l l
l                                       __      __ . _ . , .        . _ _ _
l


1                                                                 Zochnen                                               709 what was the level prescribed in the
1 Zochnen 709
(                2                      Q 3              limits and precautions in relation to the capacity of 4               the pressurizer?
(
5                     A           I don't understand your question.
2 Q
O 6                     Q         You have said you don't remember the level
what was the level prescribed in the 3
,                    7              and it was referred to in the technical specifications.                                                     '
limits and precautions in relation to the capacity of 4
8               You said you also don!t remember the capacity of 9               the pressurizer.                             I am not asking you for a specific i
the pressurizer?
10               number, I am asking what was, without reference to 11               any specific numbers, the relationship between the level 12                 that was referred to in the tech specs and the capacity 13                 of the pressurizer?
5 A
14                       A         As I have just mentioned -- the statement 15                 I just mentioned relative to the pressurizer had to do 16                 with limits and precautions.
I don't understand your question.
17                       Q         Not tech specs?
O 6
18                       A         I don't recall if it's also listed there.
Q You have said you don't remember the level 7
i
and it was referred to in the technical specifications.
;                19                 I just don't recall.                             So I was referring to limits 20                 and precautions and there was a limit and precaution 21                 not to exceed a certain level in that pressurizer, if l
8 You said you also don!t remember the capacity of 9
22                 I remember correctly, under no conditions except under l
the pressurizer.
23               hydrostatic testing.                                   ,
I am not asking you for a specific i
24                       Q         What I am asking you in simple terms, was 25                 that level halfway up the pressurizer, was it three
10 number, I am asking what was, without reference to 11 any specific numbers, the relationship between the level 12 that was referred to in the tech specs and the capacity 13 of the pressurizer?
14 A
As I have just mentioned -- the statement 15 I just mentioned relative to the pressurizer had to do 16 with limits and precautions.
17 Q
Not tech specs?
18 A
I don't recall if it's also listed there.
i 19 I just don't recall.
So I was referring to limits 20 and precautions and there was a limit and precaution 21 not to exceed a certain level in that pressurizer, if l
22 I remember correctly, under no conditions except under l
23 hydrostatic testing.
24 Q
What I am asking you in simple terms, was 25 that level halfway up the pressurizer, was it three


1                                                               Zoehnon                                     710 quarters of the way up, was it full or was it a
1 Zoehnon 710
(                    2 3            quarter?                 What was it?
(
4                       A                 It was above the halfway point.                               I just 5             don't remember the number.
2 quarters of the way up, was it full or was it a 3
gg 6                       Q                 Did you train your operators with respect-                                   7 7             to that particular section of the limits and 8             precautions?
quarter?
i 9                       A                 Yes, to the best of my recollection.
What was it?
10                         Q                 What did you tell them was the purpose of 11               that particular portion of the limits and precautions?
4 A
12                         A                 What the statement said.
It was above the halfway point.
13                         Q                 The statement simply said do not allow the 14               pressurizar level to go above a certain level other 15               than in hydrostatic testing?
I just 5
16                         A                 I believe it says under any conditions 17               except for hydrostatic testing.
don't remember the number.
18                         Q                 You remember that specific language?
gg 6
19                         A                 That's -- because it became an issue 20               after the accident it is still in my mind.
Q Did you train your operators with respect-7 7
21                         Q                 None of these other things that we have 22               been talking about that you don't remember were issues 23               after the accident?
to that particular section of the limits and 8
I' 24                         A                 Certainly they were.
precautions?
O                 25                         Q                 Just before we took a break, I showed you a j
i 9
A Yes, to the best of my recollection.
10 Q
What did you tell them was the purpose of 11 that particular portion of the limits and precautions?
12 A
What the statement said.
13 Q
The statement simply said do not allow the 14 pressurizar level to go above a certain level other 15 than in hydrostatic testing?
16 A
I believe it says under any conditions 17 except for hydrostatic testing.
18 Q
You remember that specific language?
19 A
That's -- because it became an issue 20 after the accident it is still in my mind.
21 Q
None of these other things that we have 22 been talking about that you don't remember were issues 23 after the accident?
I' 24 A
Certainly they were.
O 25 Q
Just before we took a break, I showed you a j


1                           Zochacn                     711
1 Zochacn 711
    ^h
^h
[d
[d 2
  \
number of specific procedures and you said you didn't
2 number of specific procedures and you said you didn't 3 recall whether there was such a procedure. After the 4 break I started asking you about this one particular 5 subject and without having any document in front of ggg 6 you, you are now quoting specific language of that limit 7 and precaution.
\\
8         A     I can't account for why memory remembered 9 that. I can't account for it.
3 recall whether there was such a procedure.
10         Q   ,
After the 4
Let me go back to my earlier question, that 11 you now demonstrated that you remember the specific 12 language of this one particular paragraph, and as you
break I started asking you about this one particular 5
(~'T     13 have described it -- I would say parenthetically, if
subject and without having any document in front of ggg 6
  \_)
you, you are now quoting specific language of that limit 7
14 you want to look at it now, I will be happy to show it 15 to you. I don't mean to restrict you to oral memory 16 word for word for that whole section. As you have 17 described it, it prescribed -- you described it that 18 pressurizer level should not exceed a certain level 19 under any circumstances except hydrostatic testing.
and precaution.
20         A     To the best of my recollection, that's what 21 the limits and precautions say.
8 A
22         Q     so we don't have any question about it, 23 I would like to show you -- I believe this has already 24 been marked. I am sure it's been marked already and
I can't account for why memory remembered 9
  /~
that.
(xl 25 instead of taking the time to look for the specific
I can't account for it.
10 Q
Let me go back to my earlier question, that 11 you now demonstrated that you remember the specific 12 language of this one particular paragraph, and as you
(~'T 13 have described it -- I would say parenthetically, if
\\_)
14 you want to look at it now, I will be happy to show it 15 to you.
I don't mean to restrict you to oral memory 16 word for word for that whole section.
As you have 17 described it, it prescribed -- you described it that 18 pressurizer level should not exceed a certain level 19 under any circumstances except hydrostatic testing.
20 A
To the best of my recollection, that's what 21 the limits and precautions say.
22 Q
so we don't have any question about it, 23 I would like to show you -- I believe this has already 24 been marked.
I am sure it's been marked already and
/~(xl 25 instead of taking the time to look for the specific


1                             Zachman                     712 n
1 Zachman 712 n
(%j)       2   exhibit number, why don't I just     --
(%j) 2 exhibit number, why don't I just if this is agreeable 3
if this is agreeable 3   to Mr. MacDonald -- to refer to the fact that this has 4   been previously marked as a GPU exhibit and leave it ggg  5   blank until we find out what it is and fill it in 6   later.
to Mr. MacDonald -- to refer to the fact that this has 4
7               MR. 1:acDON ALD : That's fine.
been previously marked as a GPU exhibit and leave it 5
8               Let's refer to it as to its title.
blank until we find out what it is and fill it in ggg 6
9               MR. PISKE:     A fairly large document 10         entitled "Three Mile Island Nuclear Station 11         Unit No. 2 Operating Procedure 2101-1.1 Nuclear 12           Plant Limits and Precautions," and this is a
later.
      ^
7 MR. 1:acDON ALD :
13           document that contains 137 pages.
That's fine.
8 Let's refer to it as to its title.
9 MR. PISKE:
A fairly large document 10 entitled "Three Mile Island Nuclear Station 11 Unit No. 2 Operating Procedure 2101-1.1 Nuclear 12 Plant Limits and Precautions," and this is a
^
13 document that contains 137 pages.
(' ))
(' ))
14           Q     The page I would like to refer you to is 15   number 17 which says   --
14 Q
16           A     Are you on page 17?
The page I would like to refer you to is 15 number 17 which says 16 A
17           Q     Yes. At the bottom,.this all refers to I
Are you on page 17?
I 18   the pressurizer. Down at the bottom it says, " Limits l
17 Q
19   and Precautions 1.2-01 Absolute Maximum pressurizer l
Yes.
l l             20   level at any time the reactor is critical is blank i
At the bottom,.this all refers to I
!              21   inches," and then on the right-hand side it is filled 1
I 18 the pressurizer.
!              22   in 385. Then I will go on to the next page where 23   item .c4 says, "The pressurizer must not be filled j
Down at the bottom it says, " Limits l
    ,_        24   with water to indicate its solid conditions blank l   l   1
19 and Precautions 1.2-01 Absolute Maximum pressurizer l
      '~#
l l
25   inches ati y time eheept when required for systeratic l
20 level at any time the reactor is critical is blank i
21 inches," and then on the right-hand side it is filled 1
22 in 385.
Then I will go on to the next page where 23 item.c4 says, "The pressurizer must not be filled j
24 with water to indicate its solid conditions blank l
l 1
'~#
25 inches ati y time eheept when required for systeratic l
l
l


1                                                       zochsan                                 713 i
1 zochsan 713 i
I~                         hydrostatic test."                            Number on the side is 400 inches.
I~
2
( )/
( )/
3                               Is that what you were referring to, the 4     limits and precautions?
2 hydrostatic test."
5               A               I believe so.
Number on the side is 400 inches.
O 6               Q               Rather than the one on the previous page 7     which says " absolute maximum pressurizer level at any 8     time the reactor is critical is 385 inches"?
3 Is that what you were referring to, the 4
g             A                 I recall both of those.                   The one I was 10       referring to was item 4.                                                                       '
limits and precautions?
11                 Q                 Did you understand in four separate 12         paragraphs of this particular section two different
5 A
(}             13         maximum pressurizer levels were prescribed?
I believe so.
A 14                                    The one I think has a note on page 17 15         that defined the reasoning behind the 385 inches.                                           The
O 6
,                  16         other one               --
Q Rather than the one on the previous page 7
the only recollection that I have that was 17         900 that was quoted when it was described when the 18         answer to the question, "Why don't yce want to maintain 19       , pressurizer level in the pressurizer and not go solid?"
which says " absolute maximum pressurizer level at any 8
20         Because we had a maximum limit and precaution.
time the reactor is critical is 385 inches"?
s 21                 Q                 Maybe this will help you answer the 22         question I asked be fore , what did you tell the                                             ,
g A
j 23         operators was the reason for not allowing the press                                                     ~'
I recall both of those.
24         pressurizer level not to exceed either 385 inches or 25         400 inches?
The one I was 10 referring to was item 4.
11 Q
Did you understand in four separate 12 paragraphs of this particular section two different
(}
13 maximum pressurizer levels were prescribed?
14 A
The one I think has a note on page 17 15 that defined the reasoning behind the 385 inches.
The 16 other one the only recollection that I have that was 17 900 that was quoted when it was described when the 18 answer to the question, "Why don't yce want to maintain 19 pressurizer level in the pressurizer and not go solid?"
20 Because we had a maximum limit and precaution.
s 21 Q
Maybe this will help you answer the 22 question I asked be fore, what did you tell the j
23 operators was the reason for not allowing the press
~'
24 pressurizer level not to exceed either 385 inches or 25 400 inches?
b
b
        ,,,e   ,          ,  ,      . , . . . - ,            --,--.--,e--       + - - - ---a---m.   . -
,,,e
--,--.--,e--
+ - - -
---a---m.


1                                       Zochaon                     714
1 Zochaon 714
[)                           2                 A         The reason for the 385, to the best of my 3         recollection, we did.~ quote the note that's here.         The 4         other one   --
[)
I don't believe a reason was given on the 5         fact that it says do not exceed under any condition 9
2 A
6         except hydrostatic testing.
The reason for the 385, to the best of my 3
7                 Q       What did you understand the reason for 8         havind that 400-inch limitation?
recollection, we did.~ quote the note that's here.
                          >  a 9                            I don't recall.
The 4
f6
other one I don't believe a reason was given on the 5
        .                          10         i         Q         Did it have anything to do with the t                                 ,
fact that it says do not exceed under any condition 9
          ^'
6 except hydrostatic testing.
11           concern about going solid?
7 Q
p'                   12                   A 3    'As I said, in our training at the simulator
What did you understand the reason for 8
        ~)!       '    ,        13            when we were discussing that, that was a number which 14 .         was usually quoted as a reason why you didn't want to i
havind that 400-inch limitation?
15           go solid.
a I don't recall.
16                   Q       You understood, did you not, Mr. Zechman, 17           before the accident-that the system would not be 18           considered solid if there was saturation in the reactor t
9 f6 10 i
19           coolant system?
Q Did it have anything to do with the t
20                   A'       Repeat that question.
^'
21                             (Record read.)
11 concern about going solid?
l 22                   A         I told you before that I never considered 23           prior to the accident that saturated RC system.
p' 12 A
24                   Q       Let me read you from the testimony of Mr.
'As I said, in our training at the simulator 3
25           'Toole, the same Mr..Toole whose testimony we read
~)!
when we were discussing that, that was a number which 13 14.
was usually quoted as a reason why you didn't want to i
15 go solid.
16 Q
You understood, did you not, Mr. Zechman, 17 before the accident-that the system would not be 18 considered solid if there was saturation in the reactor t
19 coolant system?
20 A'
Repeat that question.
21 (Record read.)
l 22 A
I told you before that I never considered 23 prior to the accident that saturated RC system.
24 Q
Let me read you from the testimony of Mr.
25
'Toole, the same Mr..Toole whose testimony we read


1                           Zochman                                                             715 2 to you yesterday. This is his testimony in this 3 case.
1 Zochman 715 2
4               " Question:   What is your understanding 5 of the term ' solid condition' with reference to a ggg 6 reactor coolant system?
to you yesterday.
7               " Answer:   Solid system is what we used to 8 have when we hydroed the system.                           We will open all 9 vents and the coolant system would be solid.                                               Sometime 10 the condition of having the pressurizer instrument 11 off scale above 400 inches to be off scale high would 12 be referred to as being solid.
This is his testimony in this 3
    ~
case.
13               " Question:   Does your definition of solid 14 system include the possibility of voids in the 15 reactor coolant system?
4
16               " Answer: No.               None other than what would 17 be in the top of the pressurizer."
" Question:
18               That's from page 1060 of Mr. Toole's 19 deposition and I would also like to read to you from 20 page 287 of Mr. Floyd's deposition.
What is your understanding 5
21               " Question:   Was it your understanding 9   22 prior to the accident that if the reactor coolant 23 system had a bubble, not in the pressurizer, but
of the term ' solid condition' with reference to a ggg 6
                                    ~
reactor coolant system?
24 someplace else, that it could be described as a solid O     25 system?"
7
" Answer:
Solid system is what we used to 8
have when we hydroed the system.
We will open all 9
vents and the coolant system would be solid.
Sometime 10 the condition of having the pressurizer instrument 11 off scale above 400 inches to be off scale high would 12 be referred to as being solid.
~
13
" Question:
Does your definition of solid 14 system include the possibility of voids in the 15 reactor coolant system?
16
" Answer: No.
None other than what would 17 be in the top of the pressurizer."
18 That's from page 1060 of Mr. Toole's 19 deposition and I would also like to read to you from 20 page 287 of Mr. Floyd's deposition.
21
" Question:
Was it your understanding 9
22 prior to the accident that if the reactor coolant 23 system had a bubble, not in the pressurizer, but
~
24 someplace else, that it could be described as a solid O
25 system?"
---,--,-n-,
.--r.,c.
-n


1                                 Zachman                       716
1 Zachman 716
(         2                 Mr. Seltzer, attorney for Mr. Floyd, "In 3   other words, the pressurizer is full to the roof and 4   there is a bubble someplace else?
(
ggg   5                 "Ms. Wagner:       Right.
2 Mr. Seltzer, attorney for Mr. Floyd, "In 3
6                 " Answer:     Would I before the accident 7   have described that as a solid system, is that the 8   question?
other words, the pressurizer is full to the roof and 4
9                 " Question:     Yes.
there is a bubble someplace else?
10                 " Answer       No, I would not have described 11   that as a solid system."
ggg 5
12                   Having heard the testimony of both Mr.
"Ms. Wagner:
13   Floyd and Mr. Toole, does that in any way help you 14   recall whether you had the same view before the accident 15   that they did?
Right.
16               A   I guess I can't speak for them, but I
6
,            17   certainly did not have that understanding prior to I
" Answer:
18   the accident.
Would I before the accident 7
i 19               Q   Did you believe before the accident that l
have described that as a solid system, is that the 8
20   the system would be solid even though there was 21   saturation in the reactor coolant system?
question?
22               A   I never considered saturation in the 1G     reactor coolant system.
9
,            24               Q   Do you know where, from what source, Mr.
" Question:
25   Toole and Mr. Floyd would both have received l
Yes.
10
" Answer No, I would not have described 11 that as a solid system."
12 Having heard the testimony of both Mr.
13 Floyd and Mr. Toole, does that in any way help you 14 recall whether you had the same view before the accident 15 that they did?
16 A
I guess I can't speak for them, but I 17 certainly did not have that understanding prior to I
18 the accident.
i 19 Q
Did you believe before the accident that l
20 the system would be solid even though there was 21 saturation in the reactor coolant system?
22 A
I never considered saturation in the 1G reactor coolant system.
24 Q
Do you know where, from what source, Mr.
25 Toole and Mr. Floyd would both have received l
l l
l l


1                             Zechman                     717
1 Zechman 717
(               2   information or training which led them to the con-3   clusion that the system would not be solid if there 4 were voids in the reactor coolant system?
(
5             A   I didn't discuss it with either of them.
2 information or training which led them to the con-3 clusion that the system would not be solid if there 4
ggg 6 I am not knowledgeable of other than what you quoted 7   to me or the reasoning for them saying that.
were voids in the reactor coolant system?
8             Q     Did you understand that the 400-inch 9 limitation or the 385-inch limitation would apply even 1.
5 A
10 if the operators knew that the system was not solid?
I didn't discuss it with either of them.
11             A     I don't know that in our discussions prior 12 to the accident that that ever became a point of
ggg 6
()             13   consideration.
I am not knowledgeable of other than what you quoted 7
14             Q     what did you understand going solid meant 15   before the accident?
to me or the reasoning for them saying that.
16             A     As the terminology used in the training 17   on simulator and our ownsit meant continuing rising 18   level in the pressurizer from going out the top.
8 Q
19             Q     You mean if the pressurizer was full of I
Did you understand that the 400-inch 9
20   w a t e r ', that meant --
limitation or the 385-inch limitation would apply even 1.
21           A     With a full RC system including up through O           22   the pressurizer.
10 if the operators knew that the system was not solid?
23           Q     what do you mean by a full RC system?
11 A
l l               24             A     A completely solid system.
I don't know that in our discussions prior 12 to the accident that that ever became a point of
i                25           Q     I asked what a solid system was and you l
()
l 1
13 consideration.
14 Q
what did you understand going solid meant 15 before the accident?
16 A
As the terminology used in the training 17 on simulator and our ownsit meant continuing rising 18 level in the pressurizer from going out the top.
19 Q
You mean if the pressurizer was full of I
20 w a t e r ', that meant 21 A
With a full RC system including up through O
22 the pressurizer.
23 Q
what do you mean by a full RC system?
l l
24 A
A completely solid system.
25 Q
I asked what a solid system was and you i
l l
1


l                           zechman                           718
l zechman 718
('
('
    \-s'       said a system which is full.     And then I asked you 2
\\-s' 2
3 what a full system and you said solid.
said a system which is full.
4             MR. MacDONALD:   Full of what?
And then I asked you what a full system and you said solid.
5       A     Full of water.
3 4
6       Q     If the system in fact was not full of 7 water but was full of part water and part steam, it 8 would not be solid, is that correct?
MR. MacDONALD:
  ,          9       A     As long as we put it in the reference that 10 not solid and not steam, we are talking about the 11 pressurizer.
Full of what?
12       Q     What I am talking about is the part of the
5 A
    /~3 k./     13 system outside the pressurizer for the moment.
Full of water.
14       A-     Never considered that.
6 Q
15       Q     But your definition of solid was a condition 16 in which the system was full of water, correct?
If the system in fact was not full of 7
17       A     Yes.
water but was full of part water and part steam, it 8
18       Q     If it is not full of water, then it is not 19 solid, right?
would not be solid, is that correct?
i           20       A     Yes, but I am saying, I am putting 21 boundary conditions on where it is not solid , I am saying 9
9 A
22 not solid by virtue that there is a steam space in 23 the pressurizer.
As long as we put it in the reference that 10 not solid and not steam, we are talking about the 11 pressurizer.
l l
12 Q
f~')   24       Q     Just to go back to basics. If the reactor
What I am talking about is the part of the
/~3 k./
13 system outside the pressurizer for the moment.
14 A-Never considered that.
15 Q
But your definition of solid was a condition 16 in which the system was full of water, correct?
17 A
Yes.
18 Q
If it is not full of water, then it is not 19 solid, right?
i 20 A
Yes, but I am saying, I am putting 21 boundary conditions on where it is not solid, I am saying 9
22 not solid by virtue that there is a steam space in 23 the pressurizer.
l f~')
l 24 Q
Just to go back to basics.
If the reactor
: x. /
: x. /
;          25 coolant system itself was full of water, but the l
25 coolant system itself was full of water, but the l
l l
l l
________m mb - - - .__ - --
m mb


1                           Zechman                       719 f~)
1 Zechman 719 f~)
  ~/
~/
2 pressurizer is only partly full of water and part 3 steam, that is not a solid system, correct?                     !
2 pressurizer is only partly full of water and part 3
4           A   In the light that that term was used.
steam, that is not a solid system, correct?
lll     5           Q   Yes. That's the way it's supposed to be 6 during normal operations?
4 A
7           A   Yes.
In the light that that term was used.
8           Q   so your testimony, I believe, a moment 9 ago that a solid system is a system where not only 10 the reactor coolant system itself is full of water 11 but also the pressurizer is full of water, correct?             t 12             A   That's my recollection. Yes, that's correct.
lll 5
      )
Q Yes.
13             Q   If the reactor --
That's the way it's supposed to be 6
if the pressurizer is 14   full of water but the reactor coolant system is not, 15 the system is not solid, isn't that correct?
during normal operations?
16           A   I never considered that.
7 A
17           Q   Whether you considered it or not, if your 18   definition of solid is a situation where both the 19   reactor coolant rystem and the pressurizer is full of 20   water, if either one of them is not full of water then 21   it is not solid?
Yes.
22             A   But in the definition of the terminology 23   that we used it in our training, not being solid was n
8 Q
J 24   always -- was in reference to then only and only to 25   the pressurizer. It did not consider not being solid
so your testimony, I believe, a moment 9
ago that a solid system is a system where not only 10 the reactor coolant system itself is full of water 11 but also the pressurizer is full of water, correct?
t 12 A
That's my recollection.
Yes, that's correct.
)
13 Q
If the reactor if the pressurizer is 14 full of water but the reactor coolant system is not, 15 the system is not solid, isn't that correct?
16 A
I never considered that.
17 Q
Whether you considered it or not, if your 18 definition of solid is a situation where both the 19 reactor coolant rystem and the pressurizer is full of 20 water, if either one of them is not full of water then 21 it is not solid?
22 A
But in the definition of the terminology 23 that we used it in our training, not being solid was n
24 always -- was in reference to then only and only to J
25 the pressurizer.
It did not consider not being solid


1                                                 Zechman                               720 2 below the pressurizer or in the RC system.
1 Zechman 720 2
3               Q             That is because you believed that 4 pressurizer level was an accurate measure of cyctem llh                     5 inventory?
below the pressurizer or in the RC system.
6                 A             I think I already testified that our 7 training focused and B&W's training focused on if you 8 maintained pressurizer level you were assured 9 satisfactory inventory.
3 Q
10                 Q             What was the problem with being solid?
That is because you believed that 4
11                 A             I just don't recall.                   I know there was a real 12 important reason but I j u st can't recall it right now.
pressurizer level was an accurate measure of cyctem llh 5
13                               MR. FISKE:         I think what I suggest is 14               we break for lunch.                           I will go back through 15               my notes and maybe we can shorten this.                               I think 16               we can finish.
inventory?
17                               (Whereupon, at 12:45                   p.m., a luncheon 18                 recess was taken.)
6 A
I think I already testified that our 7
training focused and B&W's training focused on if you 8
maintained pressurizer level you were assured 9
satisfactory inventory.
10 Q
What was the problem with being solid?
11 A
I just don't recall.
I know there was a real 12 important reason but I j u st can't recall it right now.
13 MR. FISKE:
I think what I suggest is 14 we break for lunch.
I will go back through 15 my notes and maybe we can shorten this.
I think 16 we can finish.
17 (Whereupon, at 12:45 p.m.,
a luncheon 18 recess was taken.)
19 20 Ig>
19 20 Ig>
I 22 23 C) 25 l
I 22 23 C) 25 l


l 1                                                                                           721 2                                   AFTERNOON SESSION 3                                             2:40 p.m.
1 721 2
4                                                 o0o lh           5   RI CH ARD                   W .              Z E CHMAN                   ,            having 6           been previously duly sworn, resumed and testified 7           as follows:
AFTERNOON SESSION 3
8     EXAMINATION (Continued) 9     BY MR. FISKE:
2:40 p.m.
10           g         Mr. Zechman, are you aware of the fact 11     that within the last year two operators at Met Ed were 12     found to have cheated on certain examinations they took 13     during the course of the Met Ed training program?
4 o0o lh 5
(                     14           A         I was aware of that.
RI CH ARD W
15           g         Which particular examinations?
Z E CHMAN having 6
16           A         Pardon?
been previously duly sworn, resumed and testified 7
l                                                                   .
as follows:
I 17           g         which particular examinations?
8 EXAMINATION (Continued) 9 BY MR. FISKE:
18           A         To the best of my recollection , it was 19     the relicensing examination.
10 g
20           g         During the period of time that you were 21     head of the training department, did you have specific 22     procedures in effect to prevent that kind of cheating?
Mr. Zechman, are you aware of the fact 11 that within the last year two operators at Met Ed were 12 found to have cheated on certain examinations they took 13 during the course of the Met Ed training program?
23                     MR. MacDONALD:               What kind of cheating.
(
24                     MR. FISKE:             The kind of cheating that s .-
14 A
25           went on by those two operators.
I was aware of that.
_  . . _ . _    _. _c___      _ _ _ . _ . . _      . _ _ . _ . _ - - - - _ _ _ , . . --  _ _ _ _ __      . _ _ _ _ .
15 g
Which particular examinations?
16 A
Pardon?
l I
17 g
which particular examinations?
18 A
To the best of my recollection, it was 19 the relicensing examination.
20 g
During the period of time that you were 21 head of the training department, did you have specific 22 procedures in effect to prevent that kind of cheating?
23 MR. MacDONALD:
What kind of cheating.
24 MR. FISKE:
The kind of cheating that s.-
25 went on by those two operators.
c


1                                                                         Zechman                     722 2                               A   I haven't been in conversation with the 3
1 Zechman 722 2
investigating committee nor am I aware of all the 4               facts surrounding that cheating other than the fact ll   5             that it existed.
A I haven't been in conversation with the 3
6                               Q   You were aware that cheating existed, 7             correct?
investigating committee nor am I aware of all the 4
i 8                               A   Yes.
facts surrounding that cheating other than the fact ll 5
9                               Q   The cheating related to examinations that 10               were taken in the course of the Met Ed training 11               program?
that it existed.
12                                     MR. MacDONALD:                               Before or after?
6 Q
(   13                                     MR. FISKE:                               After.
You were aware that cheating existed, 7
14                               A     That was the NRC exam to the best of my 15               recollection, after the accident.
correct?
;        16                               Q     Did you have procedures in effect at i         17               the training ' department when you were in charge of 18               it to prevent cheating on NRC exams?
i 8
19                               A     During the administration of either 20               exams for requalification or entry exams, there 21'             was a separation of students and a proctor.
A Yes.
22                               Q     Did it ever come to your attention at 23               any time while you were running the training depart-24               ment that any operator                                         was suspected of having i
9 Q
25               cheated?
The cheating related to examinations that 10 were taken in the course of the Met Ed training 11 program?
i
12 MR. MacDONALD:
Before or after?
(
13 MR. FISKE:
After.
14 A
That was the NRC exam to the best of my 15 recollection, after the accident.
16 Q
Did you have procedures in effect at i
17 the training ' department when you were in charge of 18 it to prevent cheating on NRC exams?
19 A
During the administration of either 20 exams for requalification or entry exams, there 21' was a separation of students and a proctor.
22 Q
Did it ever come to your attention at 23 any time while you were running the training depart-24 ment that any operator was suspected of having 25 cheated?
i i


1                           zechman                     723 (D
1 zechman 723 (D
k/         2       A     on any exam?
k/
3       Q     Yes.
2 A
4       A     In one case.
on any exam?
llh   5       g     was there an investigation made?
3 Q
6       A     Yes, there was.
Yes.
7         Q     What was the result of that?
4 A
8       A     The result of that, I can only speak from 9 the end I observed, I was not in again total 10 conference with the individual and senior management.
In one case.
11 I know one of the results of that particular cheating 12 incident, the individual was relieved from duty, sent
llh 5
g was there an investigation made?
6 A
Yes, there was.
7 Q
What was the result of that?
8 A
The result of that, I can only speak from 9
the end I observed, I was not in again total 10 conference with the individual and senior management.
11 I know one of the results of that particular cheating 12 incident, the individual was relieved from duty, sent
(%
(%
(_,)     13 to the training department for a concentrated training 14 effort.
(_,)
15       Q     That is the only time that you now 16 recall where anyone was suspected of having cheated 17 on an examination?
13 to the training department for a concentrated training 14 effort.
18       A     To the best of my recollection, sir.
15 Q
19               MR. FISKE:   That's all I have.
That is the only time that you now 16 recall where anyone was suspected of having cheated 17 on an examination?
20               MR. MacDONALD:   Due to the length of time 21       he has testified, we are not going to get done 22       cross this af ternoon so let's knock off here until 23         some mutually convenient time to reconvene here 24         for this examination of Mr. zechman.
18 A
25               MR. FISKE:   If you choose not to start
To the best of my recollection, sir.
19 MR. FISKE:
That's all I have.
20 MR. MacDONALD:
Due to the length of time 21 he has testified, we are not going to get done 22 cross this af ternoon so let's knock off here until 23 some mutually convenient time to reconvene here 24 for this examination of Mr. zechman.
25 MR. FISKE:
If you choose not to start


1                     Zechman                     724 O         2 this afternoon, I am not in a position to 3 require you to do it. I want to make it clear 4 that we don't consent to this, k     5       MR. MacDONALD:   Whether or not you consent, 6 I am saying that Mr. Zechman has testified for 7 many days and is tired and exhausted at the end 8 of the day, on the basis of that it's not in the
1 Zechman 724 O
  ,            9 best interest of anybody and not fair to anyone 10 if we start cross-exa-a ination at this time 11 and to the extent that he is leaving today, I
2 this afternoon, I am not in a position to 3
          , 12 don't think it would be concluded anyway and since n
require you to do it.
(/       13 we have scheduled and rescheduled direct and 14 cross-examinations during the case, I think 15 that that's a practice we will continue.
I want to make it clear 4
16         MR. FISKE:   I say there is no way we can l            17  require you to proceed this afternoon. I want 18 to make it clear that we are not in agreement 19 with what you have just said.
that we don't consent to this, k
!            20       MR. MacDONALD:     That's fine. I can't make l           21 you agree to anything, Mr. Fiske.
5 MR. MacDONALD:
22         MR. FISKE:   We also would like to finish 23 this up as quickly as possible and we would be 24 happy to do it any day next week.
Whether or not you consent, 6
25       MR. MacDONAL:     As we have done in i
I am saying that Mr. Zechman has testified for 7
many days and is tired and exhausted at the end 8
of the day, on the basis of that it's not in the 9
best interest of anybody and not fair to anyone 10 if we start cross-exa-ination at this time a
11 and to the extent that he is leaving today, I
, 12 don't think it would be concluded anyway and since n
(/
13 we have scheduled and rescheduled direct and 14 cross-examinations during the case, I think 15 that that's a practice we will continue.
16 MR. FISKE:
I say there is no way we can require you to proceed this afternoon.
I want l
17 18 to make it clear that we are not in agreement 19 with what you have just said.
20 MR. MacDONALD:
That's fine.
I can't make l
21 you agree to anything, Mr. Fiske.
22 MR. FISKE:
We also would like to finish 23 this up as quickly as possible and we would be 24 happy to do it any day next week.
25 MR. MacDONAL:
As we have done in i


1                                         zechman                                 725
1 zechman 725
(-           2               scheduling and rescheduling direct examinations, 3               as soon as we can with everybody's schedules, 4               mine and the witness' get back together again lh     5               to finish this as expeditiously as we can, and 6               that's what we will try to do and we will try on 7               every deposition.             It doesn't serve the purpose 8               this afternoon, not being able to complete it                       --
(-
9                              MR. FISKE:   I want to make it clear.             We are 10               ready to go now, we are ready to go Monday, we are
2 scheduling and rescheduling direct examinations, 3
              'll               ready to go Tuesday, we are ready to go Wednesday, 12               and if you want to defer it beyond that.
as soon as we can with everybody's schedules, 4
13                               MR. MacDONALD:   Let me say --
mine and the witness' get back together again lh 5
there are 14               many different times in the scheduling of 15               depositions and rescheduling direct testimony 16               when we are ready to go ahead and you are not l
to finish this as expeditiously as we can, and 6
17               and you can't and we try to work this out to 18               mutually convenient times, and I think we will 19               continue to do that throughout the case.
that's what we will try to do and we will try on 7
l 20                               That's one of the reasons that we talk 21               on the telephone and try.to get the dates 22               convenient for everyone.
every deposition.
l             23                               There have been various times when we are i
It doesn't serve the purpose 8
24               ready to go on with direct and you have not l             25               and vice versa.           I appreciate your telling me i
this afternoon, not being able to complete it 9
MR. FISKE:
I want to make it clear.
We are 10 ready to go now, we are ready to go Monday, we are
'll ready to go Tuesday, we are ready to go Wednesday, 12 and if you want to defer it beyond that.
13 MR. MacDONALD:
Let me say there are 14 many different times in the scheduling of 15 depositions and rescheduling direct testimony 16 when we are ready to go ahead and you are not l
17 and you can't and we try to work this out to 18 mutually convenient times, and I think we will l
19 continue to do that throughout the case.
20 That's one of the reasons that we talk 21 on the telephone and try.to get the dates 22 convenient for everyone.
l 23 There have been various times when we are i
24 ready to go on with direct and you have not l
25 and vice versa.
I appreciate your telling me i
l
l


1                   Zechman                   726 O     2 that you are available Monday, Tuesday and 3 Wednesday and I will take that into consideration.
1 Zechman 726 O
4       MR. FISKE:   We are available on those dates llh 5 and we are available at the earliest opportunity 6 five minutes from now to what you think is an 7 appropriate date if you don't agree to those.
2 that you are available Monday, Tuesday and 3
8       MR. MacDONALD:   Okay.
Wednesday and I will take that into consideration.
9       MR. FISKE:   Thank you, Mr. Zechman.
4 MR. FISKE:
10       (Time noted:   1:45 p.m.)
We are available on those dates llh 5
and we are available at the earliest opportunity 6
five minutes from now to what you think is an 7
appropriate date if you don't agree to those.
8 MR. MacDONALD:
Okay.
9 MR. FISKE:
Thank you, Mr. Zechman.
10 (Time noted:
1:45 p.m.)
11 12 13 14 15 16 17 18 19 20 til 22 23 25
11 12 13 14 15 16 17 18 19 20 til 22 23 25


l 1
l 1
7 2 7.
7 2 7.
(v)   2 ;, ,
(v)
CERTIFICATE                              '
CERTIFICATE 2 ;,
STATE OF NEW YORK     )
3li STATE OF NEW YORK
3li                          : ss.:
)
COUNTY OF NEW YORK     )
: ss.:
4                                                                             4 I,     CATHERINE COOK                   , a Notary       l Public of the State of New York, do hereby certify that the continued deposition of                         !
COUNTY OF NEW YORK
7                                                                              i RICHARD W. ZECHMAN               was taken before 8
)
me on       March 26, 1982                 consisting of pages 642       through     726   ;
4 4
I further certify that the witness had been previously sworn and that the within
I, CATHERINE COOK l
/
, a Notary Public of the State of New York, do hereby certify that the continued deposition of 7
V) t 13 transcript is a true record of said testimony; That I am not connected oy blood or lo, marriage with any of the said parties no" I
i RICHARD W.
interested directly or indirectly in the matter                 l in controversy, nor am I in the employ of any                   '
ZECHMAN was taken before 8
of the counsel.
me on March 26, 1982 consisting of pages 642 through 726 I further certify that the witness had been previously sworn and that the within
18 19 IN WITNESS WHEREOF, I have hereunto set my             '
/V) transcript is a true record of said testimony; t
hand this le;Y     day of       GM               ,  1982.
13 That I am not connected oy blood or marriage with any of the said parties no" lo, I
20                                             t 21 22
interested directly or indirectly in the matter l
                                              ,g       -
in controversy, nor am I in the employ of any of the counsel.
l  9 23                                 -rL T       uva , hrt CATHERINE COOK                     i n
18 IN WITNESS WHEREOF, I have hereunto set my 19 hand this le;Y day of GM 1982.
  ,,/
20 t
21 22
,g l
9 23
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March 26, 1982                               728 I NDEX Witness                                     Page Richard W. Zechman                             644 o0o EX H I B IT S B&W FOR IDENTIFICATION                               PAGE
March 26, 1982 728 I NDEX Witness Page Richard W.
  ,                          571   Collection of pages captioned   665
Zechman 644 o0o EX H I B IT S B&W FOR IDENTIFICATION PAGE 571 Collection of pages captioned 665
                                    " Nuclear Energy Training Instructor's Guide Plant Performance."
" Nuclear Energy Training Instructor's Guide Plant Performance."
572   Section 2.0 of the Technical   665 Specifications for TMI Unit 2, 573     Unit 2, Operating Procedure     668 2102-3.3, Decay Heat Removal Via OTSG."
572 Section 2.0 of the Technical 665 Specifications for TMI Unit 2, 573 Unit 2, Operating Procedure 668 2102-3.3, Decay Heat Removal Via OTSG."
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Latest revision as of 06:09, 15 December 2024

Deposition of RW Zechman on 820326 in New York,Ny.Pp 642-728
ML20072H802
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Site: Crane 
Issue date: 03/26/1982
From: Zechman R
GENERAL PUBLIC UTILITIES CORP.
To:
References
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.

642 UNITED STATES DISTRICT COURT f^.

SOUTHERN DISTRICT OF NEW YORK V

_ _ _x GENERAL PUBLIC UTILITIES CORPORATION,

. ~1 JERSEY CENTRAL POWER & LIGHT COMPANY, METROPOLITAN EDISON COMPANY and PENNSYLVANIA ELECTRIC COMPANY, Plaintiffs, 80 CIV. 1683 (R.O.)

-against-THE BABCOCK & WILCOX COMPANY and J.

RAY McDERMOTT & CO.,

INC.,

Defendants.

_ _ _ _x Continued deposition of RICHARD W.

ZECHMAN, taken by De fendants, pursuant to adjournment, at the offices of Davis, Polk

(

& Wardwell, Esgs., One Chase Manhattan Plaza, New York, New York, on Friday, March 26, 1982, at 9:45 a.m.,

before Catherine Cook,a Shorthand Reporter and Notary Public of the State of New York.

C d_

/

B306290749 gg DOYLE REPORTING. INC.

PDR ADOCK 0 PDR CERTIFIED STENOTYPE REPORTERS 369 LExlNGTCN AVENUE WALTER SHAPIRO, C.S.R.

NEW Yon x, N.Y.

10o17 CHARLES SHAPIRO, C.S.R.

TELEPMoNE 212 - 867 0220

g 643 2

Appe arance s :

3 4

KAYE, SCHOL ER FIERMAN, HAYS & HANDLER, ESQS.,

5 Attorneys for Plaintiffs, G

425 Park Avenue, 6

New York, New York 7

BY:

ANDREW MacDONALD, ESQ.,

of Counsel 8

9 10 DAVIS POLK & WARDWELL, ESQS.,

Attorneys for Defendants, 11 One Chase Manhattan Plaza, New York, New York 12 BY:

ROBERT B.

FISKE, ESQ.

and 13 Os KAREN E.

WAGNER, ESQ.,

14 of counsel 15 16 ALSO PRESENT:

17 18 SUSAN HANSON 19 20 o0o 21 0

22 23 24 25

644 1

/ a.

(

)

2 RI CHARD W

Z ECH M A N h'aving A'

3 been previously duly sworn, resumed and testified 4

further as follows:

5 EXAMINATION (Continued) ggg 6

BY MR. FISKE:

7 Q

Mr. Zechman, you realize that you continue 8

under oath?

9 A

I do.

10 Q

Near the end of your testimony yesterday, 11 you mentioned something that you referred to as a 12 pressure / temperature envelope.

(~'S 13 A

Yes, sir, I did.

V 14 Q

Could you tell us what the pressure /

15 temperature envelope is?

16 A

A pressure / temperature envelope is an 17 operating envelope which defines the boundaries of 18 operations of the reactor during operations.

l 19 Q

You say " defines the boundaries"?

l 20 A

Pressure / temperature boundaries.

21 Q

Was your understanding of that envelope O

22 that there is a fixed pressure and a fixed temperature 23 or is it a floating, movable pressure / temperature 24 relationship?

,r m 5

)

\\d 25 A

It 's a movable temperature relationship.

1 Zochman 645

('))

2 You have to stay within the boundaries of those s-3 different points of operations.

4 Q

What did you understand would happen if 5

you did not stay within the boundaries?

gg 6

A To the.best of my recollection, that 7

pressure / temperature envelope was always based on a 8

DNBR ratic.

You maintain a DNBR ratio no greater than 9

1.3.

10 Q

What is DNBR ratio?

11 A

Heat flux which would cause departure from 12 nuclear boiling divided by the actual heat flux.

('N 13 Q

What is a departure from nuclear boiling?

14 A

Departure from nuclear boiling is a heat 15 transfer transition from nuclear boiling into what 16 could eventually lead to film boiling.

17 Q

So is it correct that if one function of 18 the pressure / temperature envelope was to prevent either 19 temperature increasing or pressure decreasing to the 20 point where boiling would occur?

21 A

As I said, the DNBR ratio was again in O

22 relationship to a surface phenomenon.

It was always 23 related to the heat transfer characteristics or modes 54 of heat transfer from fuel assemblies.

25 Q

This is the type of surface boiling that

1 ZochEnn 646 2

you described yesterday that could cause fuel damage?

A Yes, sir, I did.

3 4

Q So is it fair to say that one purpose of 5

staying within the pressure / temperature envelope was g

6 to prevent fuel damage?

7 A

Yes, I think that's fair.

Yes, sir.

8 Q

Also the phrase has been used in this 9

deposition " bulk boiling."

10 A

Yes, sir.

r 11 Q

And what is bulk boiling?

12 A

Bulk boiling, as I understand it 13 Q

I am asking your understanding before the 14 accident.

15 A

Before the accident?

16 Q

Yes.

17 A

To the best of my recollection, I don't 18 recall the use of the term prior to the accident.

19 I do recall the term after the accident.

There was a 20 lot of discussion about RCS bulk boiling.

21 Q

what is bulk boiling as you understood 22 the meaning of that term after the accident?

23 A

Well, as I understand it after the 24 accident, it was referred to a saturated RCS system 25 which you had bulk boiling in the RCS system.

1 Zochman 647

(

2 Q

What is bulk boiling?

3 A

I don't recall how the term was exactly 4

defined after the accident.

ggg 5

Q As you have used it in the deposition, 6

what did you mean by bulk boiling?

7 A

As I believe I understand it post-accident 8

in that terminology, it referred to -- my terminology 9

or understanding was bulk boiling referred to a 10 saturated RCS system, where you had a lot of boiling 11 occurring -- rapid boiling occurring in the RCS system.

12 Q

Just going back to basics for a moment, (U~}

13 Mr. Zechman.

You have described earlier in the 14 deposition the temperatures of the water in the primary 15 system as you understood them before the accident.

16 A

Yes.

17 Q

What were those temperatures again?

18 A

Full power operation?

19 Q

Yes.

20 A

About 600 degrees TH, about 550, about 575 21 in there, average.

22 Q

What atmospheric at what temperature 23 does water boil at atmospheric pressure?

24 A

212 degrees, i

l 25 Q

What was your understanding of what kept 1

i l

1 Zochnan 648

(

2 the water in the primary system that was either at 3

550 degrees or higher from boiling?

4 A

What was it that kept that from boiling?

5 Q

Yes.

g 6

A I understand we have a pressurized water 1

7 reactor.

That the reactor.was at very high pressures 8

to prevent thats 9

Q At what pressure was this water in the 10 primary system kept during normal operations?

11 A

About 2000 psig.

12 Q

Going back to basics again, I think you

~

13 testified that you understood that if that pressure 14 dropped far enough, you could have boiling in the 15 primary system?

16 A

I said from a theoretical standpoing, I

(

17 understood that.

18 Q

Was that theoretical concept explained 19 in your basic training that you gave the operators?

l 20 A

To the best of my recollection, that i

I 21 theoretical understanding was known.

O 22 Q

Were the operators trained that they should l

23 not operate the reactor in conditions that you have l

24 described as bulk boiling?

(~\\

G 25 A

As I testified earlier, that never occurred l

l

1 zochman 649 2

to us and, to the best of my recollection, that subject 3

wasn't approached.

4 Q

You mean you never at any time in any of ggg 5

the. training that you gave your operators explained 6

to them that it was important not to let the water 7

in the primary system start to boil?

8 A

As I testified earlier, it just didn't 9

occur -- that didn't occur.

That didn't occur to me.

10 Q

Going back to the description that you 11 gave earlier,of the way the whole reactor system 12 operates, it is correct, is it not, that there is a hot 13 leg and a cold leg in the primary system?

14 A

Yes.

15 Q

When the water is in pipes which go through l

16 the core, correct?

17 A

Yes.

18 Q

When they go through the core, they are 19 heated up, the water is heated up to approximately 600

'20 degrees Fahrenheit?

21 A

That's right.

22 Q

Now it's in the so-called hot leg?

l l

23 A

Yes.

l 24 Q

The water goes in these same pipes through N

25 water in the steam generator, correct?

l h

1 Zochman 650 2

A Yes.

3 Q

In that process, heat is transferred from 4

the primary system water to the secondary system, 5

correct?

6 A

Yes, tha t 's correct.

7 Q

As a result of that, when the water comes 8

out of the steam generator --

9 A

on the secondary side.

10 Q

-- on the secondary side, it has now been 11 cooled to 550 degrees, correct?

12 A

We are back to the primary now.

13 Q

I am talking a bout the primary all along.

14 A

We were jumping back and forth.

You are 15 talking about heat being transferred to the secondary?

16 Q

Maybe I didn't make myself clear.

The 17 water comes out of the core at 600 degrees in the hot 18 leg, correct?

I l

19 A

Yes, sir.

l l

20 Q

It stays in those same pipes and goes l

l 21 through the steam generator, is that correct?

22 A

Th at 's correct.

23 Q

In that process, heat is transferred from l

24 the primary system water to the water in the steam 25 generator, correct?

I i

i.

1 Sochann 651 "D

2 A

To the secondary side, yes.

(G 3

Q After the water in the primary system 4

goes through the steam generator, as a result of the 5

heat transfer process that you have just described ggg 6

the water in the primary syster which is still in the 7

same pipes is cooled down to about 550 degrees, correct?

8 A

500-something degrees, yes.

9 Q

Now, it's in the so-called cold leg, 10 correct?

11 A

Yes, sir.

12 Q

Then it goes through the cold leg and 13 reenters the core?

14 A

That's correct.

15 Q

In that process the water is heated up 16 again to 600 degrees, is that correct?

17 A

That's correct.

18 Q

In that same process, that is going 19 through the core, the water performs a function 20 of cooling the core, does it not?

21 A

That's correct.

It serves more than just O

22 that function.

23 Q

one of the functions it serves is keeping 24 the core cool?

O

\\r/

25 A

Yes.

l

_=

1 Zochman 652 2

Q Did you understand that it was important 3

from a safety point of view to keep the core cool?

4 A

I understood that as long as I maintained 5

adequate RCS inventory, that the core stayed cool.

ggg 6

Q And that it was very important for safety 7

reasons to keep the core cool, is that correct?

8 A

It was one of the functions -- I understand 9

it was one of the functions of the coolant yes, sir.

10 Q

By "yes, sir," you mean you did understand 11 that cooling the core was important for safety reasons?

12 A

Yes, I understood that.

13 Q

You understood that if the core was not 3

O 14 adequately cooled, that could lead to fuel damage, 15 correct?

16 A

I understood there were conditions in 17 which you could have localized flux such that you 18 could have fuel damage.

l 19 Q

For the moment I am not asking you by what l

20 particular mechanisms the core would be failed to be l

21 cooled.

I am simply asking you didn't you understand 22 as a basic concept of running a nuclear reactor that if l

23 the core was not cooled, that could lead to core damage?

24 A

I already testified that it never occurred S_/

25 to me that conditions were such that the core wouldn't

653 2

1 Zochacn 2

he covered, because we were focusing on maintaining 3

the pressure --

4 Q

Why did you understand that it was 5

important to keep the core covered?

gg 6

A For several reasons.

One, as you mentioned, 7

the coolant kept the core cool.

8 Second of all, it was a moderator for the 9

neutron reaction.

10 Q

Why was it important to keep the core 11 cool?

12 A

Because if you didn't have the core cooled, 13 you could have core damage, fuel damage.

14 Q

And as you just said a minute ago that one 15 function of having the water in the primary system 16 circul ate through the core was to perform a core

, 17 cooling -- was to keep the core cooling, is that 18 correct?

19 A

That was one og its functions.

20 Q

You also knew, did you not, before the 21 Three Mile Island accident, that if the water in the 22 reactor or coolant system boiled into steam, that it 23 would not be able to effectively keep the core cooled?

24 A

I told you that that never occurred to me 25 prior to the accident.

__,7

654 1

Zochman

(}

2 Q

You mean it never occurred to you that 3

MR. FISKE:

Withdrawn.

4 Q

It never occurred to you that if pressure 5

dropped far enough, that could cause boiling in the ggg 6

primary system?

7 A

I told you from a theoretical point, 8

I understood that.

9 Q

Let's keep it on a theoretical point of 10 view.

11 Did you also consider as a theoretical point 12 of view that if the water in the primary system did i

13 boil as a result of a drop in pressure that that could 1

14 impede its effectiveness to keep the core cooled?

15 A

Repeat the question, please.

16 (Question read.)

17 A

And you are talking about prior to the i

i 18 accident?

l 19 Q

Yes.

20 A

I don't recall that occurring to me at that l

21 time.

h

(

22 MR. FISKE:

Let me show you a document 23 which we will mark as B&W Exhibit 571.

This is r

24 a collection of pages captioned " Nuclear Energy l

l

\\-

25 Training Instructor's Guide Plant Performance."

1 zochacn 655

()

2 Q

I will show you this document and ask you 3

whethe r this was part of the training materials used 4

at Met Ed?

5 A

Yes, we got this somewhere around 1978 or ggg 6

so.

7 Q

Let me show :'ou two pages, Mr. Zechman, 8

from this document.

First is page Q-1 which has the 9

number 1083-0123, question No. 4 reads, "Is boiling 10 in the PWR core expected?

If so, what are the 11 limitations on the amount?"

12 And the next p.g o is QS-1, 1083-0125,

(~S 13 captioned " Quiz solutions."

No. 4 reads, "Yes.

There

\\_)

14 is some boiling in the hot channels, but it must be 15 limited so that there will be no steam in the upper 16 plenum."

17 Do you see that?

18 A

Yes.

19 Q

What is the upper plenum?

20 MR. MacDONALD:

His understanding before 21 the accident?

O 22 Q

Did you understand before the accident 23 what the upper plenum was?

l 24 A

Top of the reactor vessel above the core.

f

25 Q

Part of the primary system outside the I

i l

l 1

zochman 656 t'

(

2 pressurizer, right?

s 3

A

'No.

What I am talking about,is the top par [of it, above 4

of the vessel, above that that f

gg) 5 the core, i

6 Q

In other words, not part of the primary

?

7 syste'n through which the water circulates in the manner 8

you have just described?

t 9

A' For example,-t'he steam generator or the'

'{

10 pressurizer, you are referring to, sir.

11 Q

Yes.

12 A

No.

[~}

13 Q

In other words, it is not?

(>

14 A

It is not.

15 Q

Why did you understand it'was important 16 that there be no steam in the upper plenum?

17 A

I. dont r ecall seelig those questio5s or 18 even using those.

19 Q

Did you understanding that it was important 20 that there not be steam in the upper plenum?

21 A

I never considered that, sir.

9 22 Q

Let me show you another set of questions

.e 23 and answ'ers from the same exhibit.

The question is 24 on page E.2-6, 1083-0148, question 17.

V(~s

\\

25 "While reading an analysis of a x

1 Zochnan 657

()

2 hypothetical accident you find this statement, 'Then 3

there is a rapid drop in reactor pressure and the 4

DNBR drops to less than 1,' what would you expect ggg 5

the consequences of this to be?"

6 And then on page ES2.B, 1083-0151, the 7

answer is, " Expect film boiling to occur and probable 8

fuel damage."

9 Do you see the question and the suggested i

10 solution?

11 A

I dc.

I 12

.i Q

Gn it is correct, is it not, that you il r.

pl underst ood f'h M

l that a rsnid drop 1.n reactor prassytre c4uld s/

I i

14 produce film boiling which could cause fuel daraqs?

15 A

That is not correct.

I already told you 16 that that never occurred to me.

17 Q

Did you ever look at this material?

18 A

We haven't scanned every bit of material 19 because we had gotten in, to the best of my recollection, 20 the early part of

'78.

We used part of it.

I(don't 21 recall which parts were used and which weren't.

I 22 don't know that we used the whole thing.

23 Q

Is it your testimony that you didn't train 24 ycur operators on the concept that is reflected in that i

25 question and answer that I just read?

m m-g e

-.--.m

--v

,-e

, - + -

'y

-w a

y

s 1

Zochman' 658 s

(

2 A

Could you define the concept again?

3 Q

Yes.

If there is a rapid drop in reactor 4

pressure and the DNBR drops to less than 1.you would ggg 5

expect film boiling to occur and probable fuel damage.

6 A

I don't recall, to the best of my 1

j recollection, that it was put in those terms.

7 8

Q Wheth(r it was put in those terms l

I I

9 4 A

Because it didn't occur,to me, so I don't f

10 racall the time that it was taught.

11 Q

so I understanc your answer, whether or l?-

not it war put ist the precise terms that were used 15

in that guestion and answpr, is it ycur testircny that 14

. that basic concept war act part of the training that i

s i

15 you gave the operators?

16 A

To the best of my recollection, that was 17 not.

~

18 Q

I think you have testified before that it 19 was part of the training at Met Ed to train the 20 operators on technical specifications, operating 21 procedures and emergency procedures.

(Il l

-22 A

Yes, sir.

23' Q

waan't it a fundamental concept in the 24 training on thoseSprochdures that pressure and 25 temperature shouldbe maintained vithin the so-called 1

1

1 zochcon 659

[ )T 2

pressure / temperature envelope?

3 A

Yes, we were trained that we would try 4

to operate the reactor within the pressure / temperature 5

envelope.

gg 6

Q And that this was true whether you were 7

talking about a start-up or whether you are talking i

B l

about normal cperations cr whether you are talking

[

about cooldown er after a transient, is that correct?

5 i

%0 A

This is during normal operations, the 11 operating envelope.

r 12 Q

Did you understand that after a transient

'5 13 i it was all right to depart from the preesure/temparature 1

'{&

1 14 envelopo?

15 I

A That's why we had a pressure / temperature 16 envelop in the RCS system that would give us trips 17 should we reach points of those envelopes, 18 Q

You have already said earlier that one of 19 the purposes of staying within the pressure / temperature 20 envelope was to keep from creating a condition in 21 which fuel damage would occur, do you remember that?

O 22 A

I said it was related to not exceeding 23 to maintaining a DNBR ratio greater than 1.3.

24 Q

In order to avoid fuel damage?

25 A

DNBR was always related to heat transfer

-L, i

1 zochman 660 2

from fuel and if that heat yes.

If that heat could you repeat the question.

3 4

Q I will repeat it so we can save time.

I am 5

repeating a question that I asked in the same way and g

it's a predicate to the question I want to next ask.

6 7

Isn't it a fact that you understood that 8

it was impcrtant to stay within the pressure / temperature t

gl envelope in order to avoid creating a condition where 4

10 jl fuel danage could occur?

A I believe I already testified to thst.

11 l l

lag Q

Wasn't it your understanding that it was I

i

{~}

13 juat as importanc to keep fuel damage fron occurring

%s l

after a transient had occurred, as it was during i

14 15 normal operatiens?

16 A

Yes.

l 17 Q

So isn't it a fact that the concept of 18 maintaining pressure and temperature within the 19 pressure / temperature envelope was reflected in 20 procedures that applied after a transient had occurred j

21 as well as procedures that related to normal operations?

l 22 A

Repeat the question, please.

l 23 (Question read.)

l 24 A

I don't know that the procedures covered O

\\-

25 every possible circumstance that one could perceive.

1 Zschman 661 2

Emergency procedures were based on expected response, 3

expected symptoms and responses to certain plant 4

transients, 5

g I am not asking you now to tell us about ggg 6

every single procedure that applied after a transient 7

had occurred.

I am simp'ly asking you on a broader 8

basis, isn't that correct that the same concept, that 9

is, staying within the pressure / temperature envelope c

10 in-order to prevent possible fuel damage apply just as 11 much during a situation in which a transient had 12 occurred at it did during normal operatiens?

13 A

I ' don't recall.

14 Q

Mr. Zecharn, I wouId like to read you 15 from some te stimony that Mr. Scheimann gave before 16 the President's Commission.

17 You know who Mr. Scheimann is, I take it?

18 A

Fred Scheimann.

19 Q

Yes.

One of the operators of Three Mile 20 Island who was present in the control room on the day 21 of the accident.

O 22 A

I understand who he is, yes.

l 23 Q

He was a shift foreman, was he not?

l l

24 A

I forget what his position was at that i

25 time.

1 Zschman 662

(^]

2 Q

I am reading from page 154, and I will v

3 come around so you can follow.

4 A

I forget what his title was at that time.

5 Q

Let me start at page 154.

G 6

" Question:

On Frederick Deposition Exhibit 7

3 they indicate limiting conditions for operation.

f Do you know where these limiting conditions came from?

8 I

9

" Answer:

It would probably come from 10 B&W specifications for the plant operaticn.

11

" Question:

In designing the plant they 12 would set out limits to operate the plant?

(}

13

" Answer:

I would believe ao, yes.

'uj 14

" Question:

And pursuant to that tech 15 specs were drafted?

16

" Answer:

Yes.

17

" Question:

In your B&W training course, 18 was it explained to you why these limits were set?

19

" Answer:

Some limits I would say yes, it 20 was.

21

" Question:

Do you remember which limits O

22 were explained?

23

" Answer:

Not totally.

24

" Question:

Do you remember generally?

g)

Ik/

25

" Answer:

We had talked some pressure and

1 Zachman 663

(~)

2 temperature limits and things of that nature.

'w) 3

" Question:

Do you remember anything else?

4

" Answer:

Not really.

5

" Question:

Do you remembe r what they e 6

explained to you as to pressure and temperature?

7

" Answer:

They explained to us what our 8

pressure bands were and what our temperature bands were 9

and they did give us basic ideas of why they were I

10 trying to maintain in that area.

11

" Question:

Do you remember what they said?

12

" Answer:

You had a certain cinimum

(-]

13 pressurization temperature to keep from increasing

'v' 14 pressere toc high before your temperature was up to keep ycu from having cladding trouble and rupture 15 16 trouble.

And you had maximum temperature limitations 17 to prevent boiling in the core and things of that nature.

18 You had minimum tenperature limits, minimum pressure 19 limits to keep you from boiling in the reactor coolant 20 system basically things of that nature."

21 Did you at Met Ed train the operators that O

22 you had a pressure / temperature relationship which was 23 important to keep you from boiling in the reactor 24 coolant system.

\\>

25 MR. MacDONALD:

He can answer.

I object to

e 3

1 Zochasn 664 2

the form.

3 A

I already testified that I do not -- it 4

did not occur to me the condition of having boiling ggg 5

in the core, that the pressure / temperature envelope 6

was based on a DNBR ratio which had to do with fuel 7

cladding and fuel damage' considerations.

8 Q

Did you ever learn during any of the time l

prior to the accident that you were receiving reports.

9 10 as to what was going on in the B&W training program that I

11 B&W was giving training of that nature?

12 A

1 don't recall B&W giving us training in 13 which those areas were discussed, i

14 Q

You mean nobcady rever brought to your i

15 attention that they were giving that training, is that i

16 correct?

17 A

I am saying I don't recall seeing it in 18 my training or recall it in their training, to the 19 best of my recollection at this time.

20 Q

So apparently Mr. Scheimann never told you 21 that they were doing that?

O 22 A

No,-I don't recall discussing it with Mr.

23 Scheimann.

24 MR. FISKE:

Let me mark as the next exhibit, O

25 as B&W Exhibit 572, Section 2.0 of the Technical

1 Zechman 665 4

()

2 Specification for the TMI Unit 2.

3 (collection of pages captioned " Nuclear 4

Energy Training Instructor's Guide Plant ggg 5

Performance " marked B&W Exhibit 571 for 6

identification, as of this date.)

7 (Section 2.0 of the Technical Specifications 6

for TMI Unit 2 marked B&W Exhibit 572 for 1

9 identification, as of this date.)

I 10 BY MR. FISKE:

11 Q

Is it correct, Mr. Zeehman, that during i

12 the period of time befora the Three Mile Island accident ll 13 when you were in charge of the training department, 14 you were familiar with-the technical specifications for 15 Unit 27 16 A

At the time I was either acting or was in 17 charge, and the times that I went through the technical 18 specifications.

I don't know that I memorized all of i

l 19 them.

20 Q

Let's look at page 2.1, the very first 21 item, which says, "2.1 Safety Limits."

22 Do you see where it says " Reactor Core,"

23 it says "The combination of the reactor coolant core 24 outlet pressure and outlet temperature shall not O

25 exceed the safety limit shown in Figure 2.1-1."

L

4

- l Zechman 666

()

2 Do you see that?

3 A

Yes, I do.

4 Q

Turning to Figure 2.1-1, does that reflect gg a pressure / temperature envelope?

5 6

MR. MacDONALD:

What he understood prior 7-to the accident?

f 8

MR. FISKE:

Yes.

j 9-A I realize prior to the eccident we had a 10 pressure / temperature envelope.

I just don't recall 11 if this was the -- I just don't recall this, at this 12 time.

(

13 Q

You do reca'll that there was a pressure /

14 temperature envelope which had to be complied with as l

15 part of the safety limits relating to the core?

I 16 A

Yes, I understood that.

17 Q

I would like you to turn to page B2-1.

18 If it helps, it is numbered 0922 at the bottom.

19 Do you have that in front of you?

20 A

Yes.

21 Q

Do you see at the top " Safety Limits?

O 22 A

Yes.

23 Q

And the next word is " Bases"?

24 A

Yes, sir.

O 25 Q

And the first paragraph reads, with respect

1 Zschnan 667

(

)

2 to 2.1.1 that we read just a moment ago, "The 3

restrictions of this safety limit prevent overheating 4

of the fuel cladding and possible cladding performation (gg 5

which would result in the release of fission products 6

in the reactor coolant.

Overheating of the fuel 7

cladding is prevented by restricting fuel operation 6

to within the nucleate boiling regime where the heat 9

transfer coefficient is large and the cladding surface 10 tanperature is slightly above the coolant saturation 11 temperature."

12 Do you see that?

13 A

I see that.

14 Q

Did you understand that the pressure /

15 temperature envelope pictured in Figure 2.1.1 was 16 designed to accomplish the result described in the 17 section I just read?

18 A

Yes, I did.

19 Q

You understood that that technical 20 specification applied during both normal operations 21 and during the course of a transient?

O 22 A

I said I didn't recall.

23 MR. FISKE:

Let me mark as B&W Exhibit 573 24 at the risk of re-marking an exhibit that has O

25 already been introduced at a prior deposition.

ll 1

zachman 668 2

(Document marked B&W Exhibit 573 for 3

identification, as of this date.)

4 BY MR. FISKE:

I 5

Q This is Unit 2, operating Procedure ggg 6

2102-3.3, Decay Heat Removal Via OTSG."

7 Do_you recognize this, Mr. Zechman, as 8

an operating procedure for Unit 27 9

A I recognize this as a procedure that i-

^

10 has all the markings of a Unit 2 procedure, yes, sir.

11 Q

Looking at the bottom of the front page, 12 do you see two blocks reflecting the fact that Unit 2 13' PORC had recommended approval with the signature for 14 the chairman of the PORC and that the Unit 2 15 superintendent had approved with a signature of the 16 Unit 2 superintendent?

17 A

I see that.

18 Q

Both reflecting dates in April of 19777 19 A

Negative.

It looks like '78 to me.

l 20 Q

I think you read it better than I do.

21 It's'78, right?

22 A

I believe so.

23 Q

What did you understand the purpose of this 24 procedure was?

CE) 25 A

I don't recall using this procedure

1 zechnen 669

~ '

2 personally.

3 Q

Were you aware that there was a procedure 4

applicable to decay heat removal via the steam ggg 5

generator?

6 A

I can only say that the title looks familiar,

+

7 but I don't recall using it.

8 Q

Let's go back a couple of steps.

9 Are you familiar with a concept in the 10 operation of a nuclear reactor called decay heat 11 removal?

12 A

Yes, sir.

13 Q

What is decay heat removal?

14 A

Decay heat removal Ls removal of residual 15 heat from reactor core after a period of shutdown.

16 Q

Am I correct that in a situation where 17 there has been a transient resulting in a reactor 18 trip, there continues to be heat generated from the 19 core even though the unit is not operating?

l 20 A

Even through the rods have been inserted 21 and the reactor is essentially shut down, there is a O

22 residual heat flux of the core of fission products.

23 Q

That is colloquially called decay heat?

24 A

That 's correct.

25 Q

It is important to accomplish a safe and

1 Zochaan 670

[)/

2 effective shutdown that that decay heat be removed?

~-

3 A

cooldown.

4 Q

It's important that it be done, that the ggg 5

decay heat be removed?

6 A

It is important to remove the decay heat.

7 Q

one way to do that is via the steam 8

generator, is that correct?

9

'A The decay heat removal system?

10 Q

Yes.

Is that correct?

Put it another way, 11 more simply.

12 Is there a process ;?o r removing the decay 13 heat which involves the steam generator?

14 A

There is enti process -- there is a process 15 that I am aware of, yes.

l 16 Q

can you tell us whether the document you 17 have in front of-you is the operating procedure for 18 that process?

19 A

As I said, I have not used and I am not 20 familiar with this procedure and I would be speculating 21 at this point.

O 22 Q

Let me direct your attention to page 3.0 23 of this document, the top of the page under " Limits 24 and Precautions."

O

\\-

25 A

Yes, sir.

1 Zochasn 671 2

Q "2.1.1.

Reactor coolant temperature /

3 pressure and cooldown rates shall be maintained within 4

the limits specified in Figure 3.4.2 of Ts 3.4.9.1 5

(refer to Figure 1.5.2 attached)."

g 6

Do you see that reference?

7 A

I see that reference.

8 Q

Turning tc Figure 1.5.2, do you have tha; 9~

in front of you?

t -

10 x

y,3, i

11 Q

" Heat Up/Cooldown Curve."

12 A

That's correct.

13 Q

Eave you ever teen that curve ~before?

14 A

I have seen heat up and cooldown curves, but I

I 6

15 1 don't know that I saw this specific curve.

I don't i

16 recall that I specifically saw this specific curve.

17 Q

what did you understand the purpose of a 18 heat up/cooldown curve was?

i 19 A

It's been a very long time since I worked 20 with them.

I only have a generic remembrance of the 21 heat up and cooldown curves.

Two areas, one had to do 22 with the operation of the pumps and some of the l

23 limitations had to do with the metallurgical considera-24 tions of the piping.

(:)

25 Q

Isn't the heat up -- doesn't the l

l l

I _ _ _ _.

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

1 Zochman 672

)

2 heat up/cooldown curve appear in a large number of s-3 procedures for Unit 2, both emergency and operating 4

procedures?

5 A

I can't put a quantity on it.

I know that g

6 it appears in several procedures.

7 p

Isn't it a fundamental concept that these 8

curves have to be conformed vith during al3 phases 9

of the start-er operation and cocidown of the 10 reactor?

}

11 A

I don't recall all the limitations and use 12 of thosa curves any more.

It 's been long time ago.

It 13 Q

Mr. Zechman, we ars taikt.ns about a pretty 14 fundamental question relating to a period cf time from 4

15 whenever it was that you first started with the 16 training dep&rtment at Met Ed back in the early

'70's 17 right through. the period of. time ending in F. arch of '79 18 when you were in charge of the training department.

19 So I am asking you simply, thinking back over that 20 entire period of time in which you were involved in 21 or in charge of the training at Met Ed, didn't you O

22 understand that at all times during start-up operation 23 or cooldown, shutdown, you had to comply with these 24 curves?

O 25 A

I had an understanding years ago when I was

1 Zachman 673 g_,)

2 working with these and in the training department, I 3

had an understanding of the heat up and cooldown curves 4

and the basis for them.

I don't rghall the basis (l) 5 for them today.

It's been too long since I worked with S

them.

7 Q

Did you know cf any situation from start-up 6

right through cooldven when it wasn't recessary to l

i 9

conform to these curveu?

10 P.

As I said, I don't recali all the 11 rauifications and usos of those curves et this time.

12 I would be speculating at this point with my memory.

(

13 Q

Let's see, Mr. Zechm&4.

Why did you 14 l

understand it was impartant tc comply with these curves?

15 A

Because they were limitations that were put 16 in procedures to operate with.

17 Q

Did you have' an understanding beyond the 10 fact that they were attached to a procedure as to the j

19 reason why it was important to do it?

1 20 A

I certainly understand that they were l

21 important, that we follow those heat up and cooldown 22 curves.

That's why they were in our procedures and l

23 there were a good number of reasons for parts of those 24 curves.

I don't recall today all those ramifications.

25 Q

I am simply asking you in the broadest l

1 Zschman 674 2

terms possible, why did you understand that it was 3

important to filow the curves?

I assume you had some 4

understanding beyond simply the fact that they appeared 5

in the procedure?

ggg 6

A I told you a while ago, they had to do 7

with the operetion of our C pumps, they had limitatior_s 4

i with the metallurgical consideratione of the piping.

9, I understocd that.

b l

M l Q

What did you understa.ud eculd happen if i

those curves were not followed?

11 tj y

12 r A

I don ~t recall those details a.sy more, g

g-13 air.

D 14 i Q

Can you give tu any sing 1r thing that i

l 15 you recall now could have cecurred that would be bad 16 for the plant if those curves were not followed?

17 A

With respect to the metallurgical con-18 siderations, you could exceed some of the stress j

19 limits of some of the piping, 20 Q

Why would that be bad?

21 A

For the integrity of the RCS system.

22 Q

Why was it important to maintain the l

23 integrity of the RCS system?

24 A

So you won't have ruptures or damage to 25 the piping within the RCS system.

1 Zechman 675

(

2 Q

Was it important that you not have damage 3

to the* integrity of the RCS system during start-up?

4 A

Certainly.

ggg 5

Q Was it important that you not have damage 6

to the integrity of the TOS system during normal 7

ope rations ?

f E

h Yes, sir, 9

Q Wed Lt important that you did not have 10 i 4ccage to thw intes.~ity of ti:e RCS system during h

h cooldowa?

11 f

12 A

Yes.

13 (Peress.)

Li -l!

hY MR. FIFEF:

?#

15 Q

You have that heat up/cooldown curve in 16 front of you, Mr. Zechman.

17 A

1.5.27 18 Q

Yes.

19 A

Yes, sir.

20 Q

There are some numbers down the left-hand 21 side of the page, are there not?

O 22 A

You mean B&W numbers or -- I am sorry.

23 Starts with the J 24 Q

No, not the numbers that reflect the O

25 s tamping of the documents.

1 Zechacn 676

['} '

2 A

On the curve itself?

'a 3

Q Yes, top number is 2300 and the bottom is 4

100.

ggg 5

Do you see that?

6 A

Yes.

7 Q

What do those numbers represent?

I 8 j MR. MacDONALD:

You are asking for h i.s s

t i

S recollection now?

I l

~

30 MR. FISKE:

Yes, and he can loo % at the 11*

c u rv e..

12 A

The numbers repreaant temperature.

13 Q

what do the numbers across the b;tton --

' O 14 A

I t ho ug~a t you said -- which huhcred are 15 you talking about?

16 Q

The top number is 2300 and the bottom 17 number 100.

18 A

That's RC pressure.

19 Q

The numbers acrosc the bottom are 20 temperature?

21 A

Correct.

O 22

-Q What did you understand the curves, the 23 various curves that are on this graph supposed to 24 represent?

's /

25 A

sir, it's been too long since I worked

1 Zschman 677 2

with these curves.

I would be speculating on the 3

interpretation of these curves.

I don't remember any 4

more.

ggg 5

Q Just starting with the basics, isn't it 6

correct that these curves reflect varacur pressure /

l 7

temperaturo relationships as you stove along the curve?

6 A

Yes, they do.

O Q

And is it also correct that it was in-

}

I 10 )

portant to asintain those pressure /tempereture j

11 relationships?

i i

12 A

In the utilization of this curve and the 13 procedure that utilizes this curve.

i 14 Q

Se that at any time this heat up/cooldown 15 curve appears in a procedure, the purpose of it is 16 to be sure that in implementing that particular 17 procedure, the operators are sure that the 18 pressure / temperature relationships conform with what

(

19 they are expected to do in light of these curves?

l 20 A

Under the guidance of what the procedure 21 states.

O 22 Q

Right.

But let's just take one curve, 23 for example.

Let 's take the curve that's marked No.

2.

24 Do you see that curve on this chart?

O 25 z

A Yes, I do,

t

1 Zochnan 678 2

Q Then there is a description of that on the right-hand side, is there not?

3 4

A Yes, there is, 5_

Q How is it described?

ggg 6

A

" Minimum RC pressure to maintain compres-7 sion force on clad (natural circulation)" -- and then 1

6 a letter I can 't read, and then -- " inst. erspr pint 50 psia minus 12 degrees Fahrenheit."

9 l

l' 10 Q

so did you understand before the accident 11 thut the purpose of this curve was to be sure that a l

12 certain minimum pressure was unir.tained in rela tion to h

s 13 the temperature that existed at that part.icular point

)

14 in time?

15 A

I already said I have not worked with these.

16 I don't recall the basis for these or have a recall 17 of the basis for these at this time. I would be 18 speculating on --I can read to you what it says, but I 19 would be speculating on the interpretation of all of 20 this.

21 Q

Let's j u s.t look at the various curves.

l 22 Let's take them one at a time, l

23 The first one is No.

1.

Do you see No. 17 i

24 A

Yes, sir.

1.

'\\-

25 Q

Do you know whether the operators were l

l l

i

1 Zochman 679 2

supposed to maintain a pre,sure/ temperature 3

relationship that stayed on the left side of the 4

curve or the right side of the curve?

ggg 5

A I don't recall.

6 Q

How about curve No.

2, can you tell us t

7 whether the operators were supposed to maintain a 6

pressure / temperature relationship cn the lef t side 9

of the carve or on the right side of the curve?

l.

t 20 !

A I don't recall.

k' 11 Q

Can yce tell us looking at any one of

!j the six curves on that chart whether the operators l

12

.I la were supposed to maintain pressure on the left side I

14 or the -- pressure / temperature relationship on the l

15 left side of the curve or the right side?

I 16 A

I don't recall.

17 Q

And you are'giving those answers after 18 having an opportunity to look at the curves and look 19 at the description of each one, is that correct?

20 A

That's correct.

l 21 Q

As you sit there today, Mr. Zechman, just l

22 by looking at the description of these curves, can you 23 tell us which side of the curves the operators should 24 be on?

)

25 MR. MacDONALD:

I am going to object to l

i

1 Zochann 680 2

that.

You are talking about his present 3

recollection of the document and not prior to 4

the accident.

I object to that.

His recollection ggg 5

is fine.

I have no problem with that.

6 MR. FISKE:

I will give Mr. Zechman an 7 l opportunity to answer if he wants to.

8 A

Would you restate the question, please, j

l l

)

9 (Questi>n read.)

l

\\

4 c

t 10 g

1ust ec you understand, Mr. MacDonald 11 (I stated an cLjaction that had been stated in previcus IE deponitient on both sides and witnesses up to this 13 point havo nct been required to answer his questions l

)

1 14 like the one --

15 MR. MacDOMALD:

Do you want to know if 16 he wants to answer over my objection?

17 MR. FISKE:

Yes.

18 A

I do not.

19 Q

Were you familiar with a procedure called 20 the unit heat up operating procedure that was in effect 21 before the accident 2202-1.17 22 A

I don't recall that procedure at this i

l l

23 time.

(

24 Q

Was there a heat up/cooldown curve that was l

l 25 part of that procedure?

l l.,. -. -.

- - - ~ ~ - - - - - ~, - - - - -, - -

- ' - ~ ' - ~ ~ - - ~

1 Zochman 681 (Av) 2 A

I don't recall.

3 Q

Do you recall a procedure called unit 4

startup operating procedure that was in effect before (g) 5 the accident?

6 A

You are talking about Unit 27 7

2 Y o r..

8 A

As I think I me r.t io ned 9

{

Q Or Unit 12 10 i A

Okay, for Urti t i trers waJ A startup

[I 11 procedure, I recall that.

12 Q

Was there a heat up/cocidown curve as part

['l 13 of that procedure?

'u/

l l

14 A

I don't recali.

j 15 Q

Was there a procedure in effect before i

l 16 the accident for Unit 2 or Unit 1 called pressurizer 17 operating operating procedure?

'8 A

For Unit 1,

to the best of my recollection, 19 there was.

20 Q

How about Unit 2?

21 A

I don't recall.

O 22 Q

Was there a heat up/cooldown curve that 23 was part of that procedure?

24 A

I don't recall.

I don't remember.

I

)

~

25 Q

Was there a procedure in effect prior to

I 1

Zachmen 682

(

2 the Three Mile Island accident called reactor coolant 3

pump operating procedure?

4 A

I don't recall either way.

ggg 5

Q For either unit?

6 A

Either unit.

7 -

Q I take it you don't recall whether there I

i 1

8 was a-heat up/cooldown curve ac part of that procedure?

l 9 il A

I don't recall.

l1 10 I Q

Nas there c procedure in e2fect befote the 11 Three Mile Islan6 accident known as power operations?

I 12 A

To the best of my recollectioat there was j

i l

/

13 for Unit 1.

j k

14 Q

How ahottt for Unit 27 15 A

There was one that was similar to it.

I 16 don't recall the exact title.

17 Q

Whatever the title of it wac, the substance 18 was comparable?

19 A

I can't say because I don't recall what 20 the substance of the Unit 2 one was.

21 Q

Was there a heat up/cooldown curve as part O

22 of that procedure?

23 A

I don't recall.

24 Q

Was there a procedure in effect prior to 25 the Three Mile Island accident called unit shutdown?

I

,_m

Zochitan 683 1

A There was a shutdown procedure for Unit 1.

(3 i

l 2

I don't recall the exact title.

I don't recall the 3

title if there was one for Unit 2.

4 Q

Was there a heat up/cooldown curve as part of that procedure?

C A

I don't recall.

7 Q

We icoked at the decay heat removal via 8

l OTSG, 6.nd we have all seen that there is a beet up/

9 I

I cooldown curv6 for that one.

10 i i

i

(;l A

Yes.

11 ft Q

Was there a procedure in effect befcre the 4

Il f

12

,Il Three Mile Xstand accident called unit cooldown?

j f

$3 7 t

i'

J A

I don't recall either way.

14 Q

For either unit?

15 A

For either unit.

16 Q

So I take it you don't recall whether there 17 l

was a heat up/cooldown curve for any such procedure?

18 l

A I don't recall.

19 Q

Was there a procedure called decay heat l

20 l

removal system?

21 lll A

There was a procedure called decay heat removal for Unit 1.

I don 't recall if there was a 23 corresponding specific title for Unit 2 on procedure.

l 24 r%

(

)

Q Was there any heat up/cooldown curve as l

25 i

{

1 Zschmen 684

/

(~m

(% -)

2 part of that procedure?

3 A

I don't recall.

4 Q

Was there a procedure called reactor trip ggg 5

emergency procedure?

6 A

For Unit 1 there was a reactor trip 7

procedore, to.the best of my recollection.

I don 't 8

rscall if there was a corresponding title for Unit 2.

9 0

has there a haat up/cooldown curve as part 10 t of that; procedure?

I 11 l A

2 don't recall.

I h

.Q Was there a procedure in effect before the l

12 I

("S is a c c a d e r.t called station blackout?

\\~]

14 A

'To the best of my recollection, there was '

15 a procedure with that title for Unit 1.

I don't 16 recall if there was a corresponding procedure for 17 Unit 2 or its title.

l l

18 Q

Was there a heat up/cooldown curve as part l

19 of that procedure?

l c

20 A

I don't recall.

21 Q

Regardless of the specific titles of the l

h

(

22 variods procedures, having read you the titles that I l

l 23 just did, do you recall whether or not there were in 24 fact procedures designed to deal with the types of

, ~h. '

[

! \\ I 25 conditions or circumstances reflected in the titles

/

I i

l l

1 Zechman 685

()

2 that I just read?

3 A

I have forgotten the titles you went 4

through.

l ggg 5

Q Unit heat up operating procedure, unit 6

startup operating procedure, pressurizer operation, 7

reactor coolant pump operation, power operations, unit 8

shutdown, decay heat removal system, unit cooldown, 9

reactor trip, station blackout.

10 A

Repeat your initial question.

11 (Question read.)

12 A

Can I ask for a clarification?

You are f~)T 13 saying, for example, if there is a procedure called i

u.

14 reactor trip procedure, that it dealt with a reactor 15 trip?

16 Q

Yes.

In other words --

17 A

It could have. dealt with some other things i

18 but would it have dealt with what the title said?

l 19 Q

I wanted to be sure when you were 20 answering my questions that you were not limiting your 21 answer to a procedure with a specific wording of 22 the one that I read to you.

I wanted to be sure that j

23 your answers are given in the context that I was asking 24

'whether there were procedures not only with that O

i 25 specific title but also procedures that governed the s

I

._,__.,__..,m_,,_

s s

1 Zechm'an 686 2

type of situation that was describe in the title, 3

whether or not you remembered the exact title of the i

4 procedure.

lll 5

A To the best of my recollection, the ones 6

that you have named were procedures that dealt with 7

at least what the title implied.

Sometimes some of 8

those titles were tied together into a single procedure, 9

that's what is confusing the issue in my mind right 10 now, whether they were separate procedures or titles 11 or sometimes combined titles.

12 Q

I want to make cure I understand your

()

13 answers when you were saying you didn't recall one way 14 or.the other if there were certain procedures in effect 15 at Unit 2, but you.did remember such a procedure for 16 Unit 1, youweregiving[that answer in the context not 17 simply of a procedure with that specific title but a l

18 procedure dealing with the subject matter reflected l

19 in the title, do you follow me?

20 A

I understand.

To the best of my recollection I

e 21 I was.

22 Q

I would like to show you, Mr. Zechman, 23 a document previously marked as B&W Exhibit 540, which l

L.

24 is Unit 2 Os operating procedure 2102-3.2 called Unit 25 Cooldown.

Tr '

i,

.k l

1 Zechman 687

()

2 Do you have that in front of you?

3 A

I have that in front of me.

4 Q

What is cooldown?

lll 5

MR. MacDONALD:

Apart from the procedure?

6 MR. FISKE:

Yes.

7 Q

Just generally, in the same sense I asked 8

you before what is decay heat removal, I would like 9

to know basically what is cooldown.

10 A

When you are shutting down the plant, you are 11 cooling down the system, the RC system.

12 Q

Would this be a procedure that is a cooldown

()

13 procedure that would be in effect at some point in time 14 after there had been a reactor trip as a result of a 15 transient?

16 A

I have not used this procedure.

I can only 17 say that this says that it's a Unit 2 procedure, 18 cooldown.

19 Q

yithout reference to this specific procedure, 20 is it correct that the process of cooldown as you have 21 described it a moment ago would follow a reactor trip 22 as a result of a transient?

23 A

To the best of my recollection, yes, sir.

24 Q

In other words, after a transient occurs, 73 V

25 one of the things you try to do is get the plant back

1 zechman 688

(_j 2

to normal conditions as part of a cooldown process, 3

correct?

4 A

Following a trip, if you are shutting lll 5

the plant down, you are going to cool it down, it's 6

a cooldown procedure.

9 7

Q It's a procedure on the way to shut down 8

after a trip, correct?

9 A

Yes, sir.

I was referring to the general 10 title cooldown, not this particular procedure.

11 12 I understand.

Now, I would like you to 4

12 look at the specific procedure.

Particularly page 3.0

()

13 paragraph 2.1.1, which reads under the heading " Limits 14 and Precautions," " Reactor coolant temperature / pressure 15 and cooldown rates shall be maintained within the 16 limits specified in Figures 3.4-2 and 3.4-3 of 17 TS 3.4.9.1.

Refer to Figures 1 and 2 attached."

l 18 Just a preliminary question.

Does TS 19 refer to technical specifications?

l j

20 MR. MacDONALD:

You are asking for his 21 recollection?

O 22 MR.'FISKE:

His understanding of l

l 23 A

To the best of my recollection, it is.

24 Q

Would you look at Figures 1 and 2 that

(~g l

\\_)

l 25 are part of this.

l

1 Zechman 689 2

A 1 and 2?

3 Q

Let's start with Figure 1.

4 Do you have Figure 1 in front of you?

h 5

A Yes.

g 6

Q That is a heat up/cooldown curve?

7 A

That's its title.

8 Q

Isn't that the same curve that we were just 9

looking at a moment ago which was part of the decay 10 heat removal procedure?

11 A

I haven't compared them.

12 Q

Do you want to take a minute and do that.

13 Before you do that, Mr. Zechman, was it your under-14 standing before the accident that there were different 15 heat up/cooldown curves appliable to different 16 procedures?

17 A

Not to the best of my recollection.

18 Q

I would like to turn to page 6.0 and i

i 19 paragraph 2.2.9, which reads, "If any safety equipment 20 defined in technical specification 2.1 and 2.2 is 21 exceeded, the shift supervisor shall notify the 22 station unit superintendent.

The reactor shall be t

23 placed in hot standby within one hour.

The licensee 24 shall notify the Commission, review the matter and I

l 25 record the results of the review including the cause r

l l

1 Zechman 690 2

of the condition and the basis for corrective action 3

taken to preclude reoccurrence.

Operation shall not 4

be resumed until authorized by the Commission."

lll 5

The safety limit defined in technical specification 6

2.1 refers to the same technical specification that I 7

read to yoh earlier, does it not, concerning safety 8

limits for the reactor core?

9 A

I don't recall the numbers -- I don't recall 10 whether 2.1 11 Q

Would you look at it so there is no question.

12 It's B&W 572.

()

13 MR. MacDONALD: You are' asking now his 14 recollection of these things prior to the 15 accident.

Not just comparing these documents?

16 MR. FISKE:

Sure.

His understanding prior 17 to the accident when this refers to technical 18 specification 2.1, was he aware prior to the 19 accident of any technical specification 2.1 20 other than the one that has been previously 21 shown which he now has in front of him.

22 A

Assuming that I have the current tech spec 23 that was associated at the time this procedure was in 24 effect, these two correspond.

25 Q

It says in this paragraph, "The licensee

1 Zachman 691

)

2 shall notify the Commission."

3 What commission was that referring to?

4 A

The NRC, Nuclear Regulatory Commission.

lll 5

Q Were you f amiliar with this requirement 6

of the unit cooldoen procedure prior to the Three Mile 7

Island accident?

8 A

As I said, I don't recall this procedure.

9 Q

Do you recall any part of any procedure 10 which required you to notify the Commission if safety 11 limits were exceeded?

12 A

I certainly recognize and understand

()

13 that when safety limits were exceeded we notified 14 the commission.

15 Q

Wasn't it your understanding, Mr. Zechman, 16 that not following a heat up/cooldown curve could 17 result in a violation of a safety limit which would 18 require reporting to the NRC7 19 A

I don't recall.

20 Q

Going back, Mr. Zechman, to the decay heat l

21 removal procedure, do you have that in front of you?

22 A

2102-3.37 23 Q

Yes.

24 A

Yes, sir, I do.

i

(

25 Q

I would like to direct your attention

1 Zechman 692 2

to page 4.0, paragraph at the top of the page, 2.1.7, 3

which reads, "During decay heat removal by natural 4

circulation maintain TH" that's temperature in the lll 5

hot leg?

6 A

Normally TH refers to temperature in the 7

hot leg.

8 Q

"30 degrees Fahrenheit below the 9

saturation temperature corresponding to pressurizer 10 pressure in order to prevent boiling in the hot legs."

11 Do you see that?

12 A

I see that.

(

13 Q

What was your understanding of the purpose 14 of that re quiremen t?

15 A

I don't recall using this procedure, so I 16 have no recollection of what that means.

17 Q

Do you know what boiling in the hot legs 18 refers to in that procedure?

19 A

No, sir, I do not.

I have no recollection l

20 what that means.

21 Q

What do you understand the saturation 22 temperature corresponding to the pressurizer pressure 23 to mean?

24 A

You are asking me to interpret that 25 sentence, the saturation temperature l

1 Zechman 693 O

\\ _)\\

2 MR. MacDONALD:

Recollection again prior s

3 to the accident as to what those words meant.

4 THE WITNESS:

In relationship to this lll-5 procedure?

6 Q

Generally.

7 MR. MacDONALD:

Just a second.

Can we 8

have the question so we can have an understanding 9

of what you are talking about.

The witness is 10 confused.

He was asked quesitons about this 11 paragraph relating to what he understood the 12 words meant.

(

13 Q

Before the accident, Mr. Zechman, did 14 you understand what boiling in the hot legs was?

15 A

No recollection of what the terminology 16 referred to.

17 Q

You mean if somebody had come to you 18 in the course of a transient and said, "Mr.

Zechman, 19 I thinn we have got a problem," and said, "We have 20 got boiling in the hot legs," you wouldn't know what 21 he was talking about?

l 22 A

I could interpret what he is saying.

I am l

23 not going to interpret what the meaning of this was.

24 Q

what was the concept, boiling in the hot gS V

25 legs, as you understood it?

1 Zechman 694 1

()

2 A

I didn't understand before the accident.

3 I said I would -- I said the only thing I would do if 4

you asked me was to speculate what that means, and lll 5

that's pure speculation.

6 Q

Go back to the question I just asked and 7

if someone came up to you and said "We have got a 8

problem, we have got boiling in the hot legs," would 9

you have understood what he was talking about?

10 MR. MacDONALD:

I object to the form.

11 You can answer.

12 A

I am afraid I would have to ask him to

()

13 define what he is talking about.

14 Q

Were you familiar with the concept of 15 saturation temperature corresponding to pressurizer 16 pressure?

17 A

As it refers to the pressurizer?

I 18 Q

Yes.

19 A

Whatever the saturation pressure is for l

l l

20 that -- whatever the saturation temperature is for that 21 pressure.

22 Q

Did'you have any understanding before the 23 accident as to why during decay heat removal by natural

~ 24 circulation, it would have been important to have 25 maintained temperature in the hot leg 30 degrees

1 zechman 695

(

2 Fahrenheit below tea saturation temperature corresponding 3

to pressurizer pressure?

4 A

I don't recall seeing this procedure or lll 5

that statement and, therefore, it would be speculation 6

in interpreting what that means, sir.

7 Q

I am not asking you to interpret a 8

procedure.

I am just asking yo. whether by reference 9

to the procedure or not, did you understand that 10 during decay heat removal by natural circulation, it 11 was important to maintain temperature in the hot leg, 12 30 degrees Fahrenheit below the saturation temperature

()

13 corresponding to pressurizer pressure?

14 A

I have no recollection of that concept.

15 Q

Did you understand it was important to 16 maintain temperature in the hot leg at any degrees 17 Fahrenheit below the saturation temperature cor-

)

18 responding to the pressurizer pressure?

19 A

As it applies to this procedure?

20 Q

No.

21 A

I never used that terminology so -- the 22 answer is I have no recollection.

23 Q

Did you understand that during decay heat 24 removal by natural circulation that it was important 25 to maintain any pressure / temperature relationship?

I

1 Zechman 696 c

p(,)

2 A

There were temperature and pressure 3

relationships but I just don't recall what they were.

4 Q

I am not asking you to give me the specific lll 5

degrees or pounds per square inch, but do you recall 6

that it was important to maintaining certain pressure /

7 temperature relationship?

8 MR. MacDONALD:

Specifically now with 9

natural circulation?

10 MR. FISKE:

During decay heat removal.

11 A

I can only recall that there were 12 temperature considerations that we looked at and O

(_j 13 pressure, but that is as far as I can answer, sir.

14 Q

You did know, did you not, that the 15 pressure / temperature envelope concept that you have 16 described earlier applied to decay heat removal?

17 A

I don't recall.

18 Q

Do you understand that question?

Maybe 19 you would like to have it read again.

20 A

Read it again.

21 (Question read.)

22 A

I don't recall.

23 Q

Earlier, Mr. Zechman, in this deposition (7b) 24 we showed you volume 5 of the final safety analysis LJ 25 report prepared by Metropolitan Edison Company and

1 Zechman 697 rh

(_)

2 submitted to the Nuclear Regulatory Commission in order 3

to obtain an operating license for Unit 2.

4 I would like to show you a section from lll 5

that 5.5.10, pressurizer.

Right under that 5.5.10.1, 6

design basis and it reads, "The pressurizer is 7

designed to provide a capability of maintaining the 8

reactor coolant system at saturation pressure to 9

prevent boiling of the coolant."

10 Do you see that?

11 A

I see that.

12 Q

Were you familiar with that concept before

()

13 the accident?

14 A

I don't recall this one.

15 Q

I am not -- for the moment I am not asking 16 you whether you read this particular part of the FSAL.

17 First I am simply asking you whether you were aware 18 prior to the accident of the concept that is expressed 19 in the sentence that I just read.

20 A

I told you that from a theoretical 21 standpoint I understood that pressure / temperature 22 relationship, that it did not occur to me prior to did not occu'r to me prior to the 23 the accident 24 accident having a saturated or boiling condition in

{)g

\\-

25 the coolant.

1 Zechman 698

\\m) 2 Q

You didn't know before the accident that 3

the pressurizer was designed to provide a capability 4

of maintaining the pressure at a level sufficient to lll 5

prevent boiling in the coolant?

6 MR. MacDONALD:

Are you asking him now 7

to interpret the concept supposed as stated 8

in this FSAL or his recollection of it?

9 MR. FISKE:

Read the question back.

10 (Question read.)

11 A

I understand from a theoretical standpoint 12 that it maintaine.d pressure and'. elevated pressures in a (3

V 13 PWR.

14 Q

That that was done in order to prevent 15 boiling in a coolant, is that correct?

16 A

I told you I never considered boiling of 17 the coolant in the RC system.

18 Q

Did you train your operator in the 19 training program that in accordance with this statement 20 from the Met Ed FSAL to the Nuclear Regulatory 21 Commission describing the design basis of the 22 pressurizer that the pressurizer was designed to 23 provide a capability of maintaining the reactor

(~}

24 coolant system at a pressure high enough to prevent

\\m /

25 boiling in the coolant 7

M 1

Zechman 699 1

2 A

Are you asking me if I trained on this 3

paragraph?

4 Q

On the concept of that paragraph.

llh 5

A I don't recall.

l 6

Q Any of your training programs at Met Ed, did you ever try to describe to the operators what 7

8 the purpose of the pressurizer was?

9 A

Yes, we did.

10 Q

Did you tell them that the purpose of 11 the pressurizer was to keep pressure up above saturation 12 temperature?

13 A

we told them the purpose of pressurizer 14 had several functions.

One as a surge tank, one to 15 maintain system pressure.

4 16 Q

At a certain prescribed level, correct?

17 A

What do you mean by "certain prescribed 18 level"?

19 Q

Didn't you explain to the operators at 20 any point in the training that they received at Met 21 Ed that a purpose of the pressurizer to be sure that 22 pressure was kept up above the saturation point?

23 A

we never discussed, to the best of my 24 recollection, the saturation of the RC system.

25 Q

So you never told the operators that it was

1 Zechman 700

(,)

2 important that pressure be kept up above the saturation 3

point?

4 A

We taught then that the pressure the lll 5

only recollection I have at this point that we taught 6

them that the purpose of the pressurizer was to 7

maintain system pressure and that it accommodated 8

acted as a surge tank to accommodate incoming and 9

outgoing surges and to main'tain system pressure.

10 Q

My question, which I don't believe you have 11 answered yet, did you ever tell them at any point 12 in the training program that by maintaining system

,-(,)

13 pressure that meant that pressure should be maintained 14 above the saturation point?

15 A

I don't recall.

16 Q

Does that meant that your testimony is as 17 you sit here today that you don't have.any recollection 18 of ever teaching them that concept?

19 A

I just don't recall.

20 Q

Do you recall at any time at any part of 21 the training program that you conducted or that you 22 participated in at Met Ed when there was a discussion 23 of maintaining system pressure, any one of the students

(~}

24 asking a question, "Well, gee, what happens if pressure

'<J 25 drops and we can't maintain system pressure?"

1 Zechman 701

( '

2 A

The concept has always been on maintaining 3

pressure and level.

I don't recall considering that, 4

sir.

lll 5

Q So it's your testimony, and I think this 6

is the last question I have on this, that at no time 7

in the training program, to the best of your 8

recollection, as you sit here today, where the 9

operators taught what would happen if system pressure 10 was not maintained?

11 A

other than the relationship of the 12 pressure / temperature envelope relative to DNBR.

()

13 Q

They were never told what would happen 14 if the pressure dropped even lower than the 15 pressure / temperature relationship that would affect 16 the DNBR, is that correct?

17 A

Read that back.

18 (Question read.)

19 A

I don't recall it.

20 Q

was training given'to the operators at 21 Met Ed during any period of --

22 MR. FISKE:

Withdrawn.

23 Q

Did you believe during the period of time 24 while you were in charge of the training program at 25 Met Ed that it would be important for the operators

1 Zechman 702 2

to be able to determine during the course of a 3

transient whether or not saturation had occurred?

4 A

I already testified that prior to the lll 5

accident saturated RC system just didn't occur to me, 6

sir.

7 Q

So the answer to my question is no.

If 8

you would like to hear it again.

9 A

Please.

10 (Question read.)

11 A

It did not occur to me prior to the 12 accident, I am sorry.

()

13 Q

Let me show you a document which has 14 already been marked as B&W Exhibit 419 and which is a 15 copy of a letter from Mr.

E.

G.

Ward, senior project l

16 manager at B&W to Mr.

L.

C.

Lanese, GPU Service 17 Corporation, Parsippany, New Jersey.

Subject Three 18 Mile Island Nuclear Station Unit No.

2, ECCS small 19 break analysis.

20 Do you have that document in front of you?

21 A

Yes, sir.

22 Q

Did you ever see this document prior to 23 the Three Mile Island accident?

(~s 24 A

I don't recall seeing this document.

(_)

25 Q

Did anyone within the training department

-,r.

---g m._

1 zechman 703 2

receive from Mr. Lanese or anyone el'se at GPU Service 3

Corporation the ECCS small break analysis which was 4

sent by B&W to Mr. Lanese, with this letter?

lll 5

A I can't speak for other people in my 6

department, whether they personally have seen this or 7

not.

I don't recall seeing i t.'

8 Q

Look at the second paragraph of the 9,

letter from Mr. Taylor to Mr. varga, do you see that?

10 A

Yes, sir.

on the cover page, July 16, 19787 11 Q

Yes, which is one of the pages in this 12 exhibit.

This is a letter by which Mr. Taylor, manager 13 of licensing at B&W, forwarded to the Nuclear 14 Regulatory Commission the same ECCS small break 15 analysis that they sent to Mr. Lanese at CPU Service 16 Corporation.

17 MR MacDONALD:

I object if you are 18 asking him to --

19 MR. FISKE:

I am just stating that.

Trying 20 to save a little time.

21 Q

The second paragraph of this letter says, 22

" Break sizes of

.04,

.055,

.07,

.085,

.10 and.15 23 feet are examined.

These attached analyses, along

'^s 24 with the break analysis in 'ECCS analysis of B&W's

]

25 177FA lowered loop NSS,' constitute a complete t

t 1

zechman 704 2

spectrum of small break analyses which we believe 3

to be wholly in accordance with 10 CFR 50.46 and 4

10 CFR 50 Appendix

'K.'"

llh 5

There is attached to the NSS analysis 6

a Figure B-3 which is a graph reflecting pressure f

7 versus time for each of the break sizes referred to 8

in the paragraph that I just read.

9 I would ask you whether or not, Mr.

- 10 zechman, you were ever made aware by anyone at GPU 11 Service Corporation or anyone else within the Met Ed 12 organization that analyses had been conducted of various

()

13 break sizes and that a calculation will be made of 14 the expected pressure versus time resulting from 15 these of those break sizes?

16 A

You are talking about what my recollection 17 was prior to the accident?

18 Q

Yes.

19 A

My only recollection at this time prior 20 to the accident that there was an analysis done.

That's 21 my only recollection.

22 Q

And theunderstanding that you had back 23 before the accident as acting supervisor or as 24 supervisor of training, is this the kind of informa-25 tion you had expected that GPU was to send to your y-n,,,-

,,v,

,,w--

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

-,-a

-.-----,,r

.r,-

,,,_ man-----m-,..

-n

~

1 Zechman 705

(_)

2 training department if they received it?

3 MR. MacDONALD:

You are talking about in 4

the form itself here?

lll 5

MR. FISKE:

The substance.

I don't know 6

if it was the precise language.

7 A

Sir, I would have to evaluate all of the 8

information that's given here and make some rational 9

determination.

In speculation -- it would be 10 speculation at this time.

11 Q

Was it important to you during the period 12 of time you were in charge of the training department "N

q_)

13 that you have as much information as possible to 14 communicate to your operators about the expected 15 consequences which would flow from a variety of break 16 sizes which could produce a loss of coolant accident?

l 17 A

It was important for me to have information l

18 on small break operating philosophy that an operator need 19 to know'how to recognize it and the results of those 20 different things.

21 Q

As you understood it prior to the accident, 22 would and which showed the changes in pressure over 23 a time that would be reflected in small breaks of

(~)

24 various sizes, be.useful to the operators in V

25 diagnosing a transient?

1 zechman 706 O'

2 MR. MacDONALD:

You are asking if he 3

thought of that prior to the accident?

4 MR. FISKE:

Yes, with that kind of lll 5

information.

6 A

I didn't consider it at the time so 7

Q You didn't?

You said you don't remember 8

seeing this report.

I understand that.

I am simply 9

asking you whether in your function as supervisor of 10 training or acting supervisor, did you understand 11 that there could be different changes in pressure over 12 time resulting from small breaks of different sizes?

13 A

To the best of my recollection, I had 14 that kind of an understanding.

15 C

And did you believe it would be useful q

16 for the operators to know in diagnosing a transient 17 what the expected changes in pressure over time would 18 be for different sizes of small breaks?

19 A

Since I didn't have that information at 20 hand at that time, I don't know that I considered that 21 at that time.

22 Q

You mean it never occurred to you as head 23 of training that there might be different changes in 25 breaks?

k

1 Zechman 707

/~T

'\\ //

2 A

I don't recall what my considerations were 3

at that time.

4 Q

Did you understand that every break in the llh 5

primary system boundary, no matter what size, would 6

Produce exactly the same change in pressure over time?

7 A

I don't know what I considered at that 8

time.

I don't recollect what my thinking was at that 9

time.

10 Q

were the operators in the training 11 department trained on the fact that there could be 12 different changes in pressure over time resulting

[~}

(_/

13 from different break sizes?

14 A

I don't recall.

15 Q

To your knowledge, today as you sit here, 16 do you have any recollection that such training was 17 in fact given?

18 A

I recall there was small break training 19 given, but I don't recall today all the details of that 20 training.

21 Q

Did you also receive -- you also received 22 training, did you not, in the course of getting your 23 license on Unit 17

,CT 24 A

Yes, sir.

V 25 Q

In the training that you received as a

1 Zechman 708 O-2 student at the same time you were head of the training 3

department, did you get training on the fact that 4

different break sizes would produce different changes llh 5

in pressure over time?

6 A

I just don't recall.

7 (Recess.)

8 BY MR. FISKE:

9 Q

Mr. Zechman, prior to the Three Mile Island 10 accident, were you aware of any provisions in any 11 operating procedure or technical specifications regarding 12 the pressurizer level?

13 A

I was aware that they existed, that they 14 existed in tech specs and limits and precautions.

15 Q

What did you understand those ground rules 16 were?

17 A

I can only recall one of them today.

That 18 was limit and precautions, there was a statement that 19 says one should not exceed a certain level in the 20 pressurizer under any circumstances except under 21 hydrostatic testing, i

22 Q

What was that level?

l i

23 A

I don't recall the exact number any more.

l

~

24 Q

What was the capacity of the pressurizer?

l 25 A

I don't recall those numbers, sir.

l l

l

1 Zochnen 709

(

2 Q

what was the level prescribed in the 3

limits and precautions in relation to the capacity of 4

the pressurizer?

5 A

I don't understand your question.

O 6

Q You have said you don't remember the level 7

and it was referred to in the technical specifications.

8 You said you also don!t remember the capacity of 9

the pressurizer.

I am not asking you for a specific i

10 number, I am asking what was, without reference to 11 any specific numbers, the relationship between the level 12 that was referred to in the tech specs and the capacity 13 of the pressurizer?

14 A

As I have just mentioned -- the statement 15 I just mentioned relative to the pressurizer had to do 16 with limits and precautions.

17 Q

Not tech specs?

18 A

I don't recall if it's also listed there.

i 19 I just don't recall.

So I was referring to limits 20 and precautions and there was a limit and precaution 21 not to exceed a certain level in that pressurizer, if l

22 I remember correctly, under no conditions except under l

23 hydrostatic testing.

24 Q

What I am asking you in simple terms, was 25 that level halfway up the pressurizer, was it three

1 Zoehnon 710

(

2 quarters of the way up, was it full or was it a 3

quarter?

What was it?

4 A

It was above the halfway point.

I just 5

don't remember the number.

gg 6

Q Did you train your operators with respect-7 7

to that particular section of the limits and 8

precautions?

i 9

A Yes, to the best of my recollection.

10 Q

What did you tell them was the purpose of 11 that particular portion of the limits and precautions?

12 A

What the statement said.

13 Q

The statement simply said do not allow the 14 pressurizar level to go above a certain level other 15 than in hydrostatic testing?

16 A

I believe it says under any conditions 17 except for hydrostatic testing.

18 Q

You remember that specific language?

19 A

That's -- because it became an issue 20 after the accident it is still in my mind.

21 Q

None of these other things that we have 22 been talking about that you don't remember were issues 23 after the accident?

I' 24 A

Certainly they were.

O 25 Q

Just before we took a break, I showed you a j

1 Zochacn 711

^h

[d 2

number of specific procedures and you said you didn't

\\

3 recall whether there was such a procedure.

After the 4

break I started asking you about this one particular 5

subject and without having any document in front of ggg 6

you, you are now quoting specific language of that limit 7

and precaution.

8 A

I can't account for why memory remembered 9

that.

I can't account for it.

10 Q

Let me go back to my earlier question, that 11 you now demonstrated that you remember the specific 12 language of this one particular paragraph, and as you

(~'T 13 have described it -- I would say parenthetically, if

\\_)

14 you want to look at it now, I will be happy to show it 15 to you.

I don't mean to restrict you to oral memory 16 word for word for that whole section.

As you have 17 described it, it prescribed -- you described it that 18 pressurizer level should not exceed a certain level 19 under any circumstances except hydrostatic testing.

20 A

To the best of my recollection, that's what 21 the limits and precautions say.

22 Q

so we don't have any question about it, 23 I would like to show you -- I believe this has already 24 been marked.

I am sure it's been marked already and

/~(xl 25 instead of taking the time to look for the specific

1 Zachman 712 n

(%j) 2 exhibit number, why don't I just if this is agreeable 3

to Mr. MacDonald -- to refer to the fact that this has 4

been previously marked as a GPU exhibit and leave it 5

blank until we find out what it is and fill it in ggg 6

later.

7 MR. 1:acDON ALD :

That's fine.

8 Let's refer to it as to its title.

9 MR. PISKE:

A fairly large document 10 entitled "Three Mile Island Nuclear Station 11 Unit No. 2 Operating Procedure 2101-1.1 Nuclear 12 Plant Limits and Precautions," and this is a

^

13 document that contains 137 pages.

(' ))

14 Q

The page I would like to refer you to is 15 number 17 which says 16 A

Are you on page 17?

17 Q

Yes.

At the bottom,.this all refers to I

I 18 the pressurizer.

Down at the bottom it says, " Limits l

19 and Precautions 1.2-01 Absolute Maximum pressurizer l

l l

20 level at any time the reactor is critical is blank i

21 inches," and then on the right-hand side it is filled 1

22 in 385.

Then I will go on to the next page where 23 item.c4 says, "The pressurizer must not be filled j

24 with water to indicate its solid conditions blank l

l 1

'~#

25 inches ati y time eheept when required for systeratic l

l

1 zochsan 713 i

I~

( )/

2 hydrostatic test."

Number on the side is 400 inches.

3 Is that what you were referring to, the 4

limits and precautions?

5 A

I believe so.

O 6

Q Rather than the one on the previous page 7

which says " absolute maximum pressurizer level at any 8

time the reactor is critical is 385 inches"?

g A

I recall both of those.

The one I was 10 referring to was item 4.

11 Q

Did you understand in four separate 12 paragraphs of this particular section two different

(}

13 maximum pressurizer levels were prescribed?

14 A

The one I think has a note on page 17 15 that defined the reasoning behind the 385 inches.

The 16 other one the only recollection that I have that was 17 900 that was quoted when it was described when the 18 answer to the question, "Why don't yce want to maintain 19 pressurizer level in the pressurizer and not go solid?"

20 Because we had a maximum limit and precaution.

s 21 Q

Maybe this will help you answer the 22 question I asked be fore, what did you tell the j

23 operators was the reason for not allowing the press

~'

24 pressurizer level not to exceed either 385 inches or 25 400 inches?

b

,,,e

--,--.--,e--

+ - - -

---a---m.

1 Zochaon 714

[)

2 A

The reason for the 385, to the best of my 3

recollection, we did.~ quote the note that's here.

The 4

other one I don't believe a reason was given on the 5

fact that it says do not exceed under any condition 9

6 except hydrostatic testing.

7 Q

What did you understand the reason for 8

havind that 400-inch limitation?

a I don't recall.

9 f6 10 i

Q Did it have anything to do with the t

^'

11 concern about going solid?

p' 12 A

'As I said, in our training at the simulator 3

~)!

when we were discussing that, that was a number which 13 14.

was usually quoted as a reason why you didn't want to i

15 go solid.

16 Q

You understood, did you not, Mr. Zechman, 17 before the accident-that the system would not be 18 considered solid if there was saturation in the reactor t

19 coolant system?

20 A'

Repeat that question.

21 (Record read.)

l 22 A

I told you before that I never considered 23 prior to the accident that saturated RC system.

24 Q

Let me read you from the testimony of Mr.

25

'Toole, the same Mr..Toole whose testimony we read

1 Zochman 715 2

to you yesterday.

This is his testimony in this 3

case.

4

" Question:

What is your understanding 5

of the term ' solid condition' with reference to a ggg 6

reactor coolant system?

7

" Answer:

Solid system is what we used to 8

have when we hydroed the system.

We will open all 9

vents and the coolant system would be solid.

Sometime 10 the condition of having the pressurizer instrument 11 off scale above 400 inches to be off scale high would 12 be referred to as being solid.

~

13

" Question:

Does your definition of solid 14 system include the possibility of voids in the 15 reactor coolant system?

16

" Answer: No.

None other than what would 17 be in the top of the pressurizer."

18 That's from page 1060 of Mr. Toole's 19 deposition and I would also like to read to you from 20 page 287 of Mr. Floyd's deposition.

21

" Question:

Was it your understanding 9

22 prior to the accident that if the reactor coolant 23 system had a bubble, not in the pressurizer, but

~

24 someplace else, that it could be described as a solid O

25 system?"

---,--,-n-,

.--r.,c.

-n

1 Zachman 716

(

2 Mr. Seltzer, attorney for Mr. Floyd, "In 3

other words, the pressurizer is full to the roof and 4

there is a bubble someplace else?

ggg 5

"Ms. Wagner:

Right.

6

" Answer:

Would I before the accident 7

have described that as a solid system, is that the 8

question?

9

" Question:

Yes.

10

" Answer No, I would not have described 11 that as a solid system."

12 Having heard the testimony of both Mr.

13 Floyd and Mr. Toole, does that in any way help you 14 recall whether you had the same view before the accident 15 that they did?

16 A

I guess I can't speak for them, but I 17 certainly did not have that understanding prior to I

18 the accident.

i 19 Q

Did you believe before the accident that l

20 the system would be solid even though there was 21 saturation in the reactor coolant system?

22 A

I never considered saturation in the 1G reactor coolant system.

24 Q

Do you know where, from what source, Mr.

25 Toole and Mr. Floyd would both have received l

l l

1 Zechman 717

(

2 information or training which led them to the con-3 clusion that the system would not be solid if there 4

were voids in the reactor coolant system?

5 A

I didn't discuss it with either of them.

ggg 6

I am not knowledgeable of other than what you quoted 7

to me or the reasoning for them saying that.

8 Q

Did you understand that the 400-inch 9

limitation or the 385-inch limitation would apply even 1.

10 if the operators knew that the system was not solid?

11 A

I don't know that in our discussions prior 12 to the accident that that ever became a point of

()

13 consideration.

14 Q

what did you understand going solid meant 15 before the accident?

16 A

As the terminology used in the training 17 on simulator and our ownsit meant continuing rising 18 level in the pressurizer from going out the top.

19 Q

You mean if the pressurizer was full of I

20 w a t e r ', that meant 21 A

With a full RC system including up through O

22 the pressurizer.

23 Q

what do you mean by a full RC system?

l l

24 A

A completely solid system.

25 Q

I asked what a solid system was and you i

l l

1

l zechman 718

('

\\-s' 2

said a system which is full.

And then I asked you what a full system and you said solid.

3 4

MR. MacDONALD:

Full of what?

5 A

Full of water.

6 Q

If the system in fact was not full of 7

water but was full of part water and part steam, it 8

would not be solid, is that correct?

9 A

As long as we put it in the reference that 10 not solid and not steam, we are talking about the 11 pressurizer.

12 Q

What I am talking about is the part of the

/~3 k./

13 system outside the pressurizer for the moment.

14 A-Never considered that.

15 Q

But your definition of solid was a condition 16 in which the system was full of water, correct?

17 A

Yes.

18 Q

If it is not full of water, then it is not 19 solid, right?

i 20 A

Yes, but I am saying, I am putting 21 boundary conditions on where it is not solid, I am saying 9

22 not solid by virtue that there is a steam space in 23 the pressurizer.

l f~')

l 24 Q

Just to go back to basics.

If the reactor

x. /

25 coolant system itself was full of water, but the l

l l

m mb

1 Zechman 719 f~)

~/

2 pressurizer is only partly full of water and part 3

steam, that is not a solid system, correct?

4 A

In the light that that term was used.

lll 5

Q Yes.

That's the way it's supposed to be 6

during normal operations?

7 A

Yes.

8 Q

so your testimony, I believe, a moment 9

ago that a solid system is a system where not only 10 the reactor coolant system itself is full of water 11 but also the pressurizer is full of water, correct?

t 12 A

That's my recollection.

Yes, that's correct.

)

13 Q

If the reactor if the pressurizer is 14 full of water but the reactor coolant system is not, 15 the system is not solid, isn't that correct?

16 A

I never considered that.

17 Q

Whether you considered it or not, if your 18 definition of solid is a situation where both the 19 reactor coolant rystem and the pressurizer is full of 20 water, if either one of them is not full of water then 21 it is not solid?

22 A

But in the definition of the terminology 23 that we used it in our training, not being solid was n

24 always -- was in reference to then only and only to J

25 the pressurizer.

It did not consider not being solid

1 Zechman 720 2

below the pressurizer or in the RC system.

3 Q

That is because you believed that 4

pressurizer level was an accurate measure of cyctem llh 5

inventory?

6 A

I think I already testified that our 7

training focused and B&W's training focused on if you 8

maintained pressurizer level you were assured 9

satisfactory inventory.

10 Q

What was the problem with being solid?

11 A

I just don't recall.

I know there was a real 12 important reason but I j u st can't recall it right now.

13 MR. FISKE:

I think what I suggest is 14 we break for lunch.

I will go back through 15 my notes and maybe we can shorten this.

I think 16 we can finish.

17 (Whereupon, at 12:45 p.m.,

a luncheon 18 recess was taken.)

19 20 Ig>

I 22 23 C) 25 l

1 721 2

AFTERNOON SESSION 3

2:40 p.m.

4 o0o lh 5

RI CH ARD W

Z E CHMAN having 6

been previously duly sworn, resumed and testified 7

as follows:

8 EXAMINATION (Continued) 9 BY MR. FISKE:

10 g

Mr. Zechman, are you aware of the fact 11 that within the last year two operators at Met Ed were 12 found to have cheated on certain examinations they took 13 during the course of the Met Ed training program?

(

14 A

I was aware of that.

15 g

Which particular examinations?

16 A

Pardon?

l I

17 g

which particular examinations?

18 A

To the best of my recollection, it was 19 the relicensing examination.

20 g

During the period of time that you were 21 head of the training department, did you have specific 22 procedures in effect to prevent that kind of cheating?

23 MR. MacDONALD:

What kind of cheating.

24 MR. FISKE:

The kind of cheating that s.-

25 went on by those two operators.

c

1 Zechman 722 2

A I haven't been in conversation with the 3

investigating committee nor am I aware of all the 4

facts surrounding that cheating other than the fact ll 5

that it existed.

6 Q

You were aware that cheating existed, 7

correct?

i 8

A Yes.

9 Q

The cheating related to examinations that 10 were taken in the course of the Met Ed training 11 program?

12 MR. MacDONALD:

Before or after?

(

13 MR. FISKE:

After.

14 A

That was the NRC exam to the best of my 15 recollection, after the accident.

16 Q

Did you have procedures in effect at i

17 the training ' department when you were in charge of 18 it to prevent cheating on NRC exams?

19 A

During the administration of either 20 exams for requalification or entry exams, there 21' was a separation of students and a proctor.

22 Q

Did it ever come to your attention at 23 any time while you were running the training depart-24 ment that any operator was suspected of having 25 cheated?

i i

1 zechman 723 (D

k/

2 A

on any exam?

3 Q

Yes.

4 A

In one case.

llh 5

g was there an investigation made?

6 A

Yes, there was.

7 Q

What was the result of that?

8 A

The result of that, I can only speak from 9

the end I observed, I was not in again total 10 conference with the individual and senior management.

11 I know one of the results of that particular cheating 12 incident, the individual was relieved from duty, sent

(%

(_,)

13 to the training department for a concentrated training 14 effort.

15 Q

That is the only time that you now 16 recall where anyone was suspected of having cheated 17 on an examination?

18 A

To the best of my recollection, sir.

19 MR. FISKE:

That's all I have.

20 MR. MacDONALD:

Due to the length of time 21 he has testified, we are not going to get done 22 cross this af ternoon so let's knock off here until 23 some mutually convenient time to reconvene here 24 for this examination of Mr. zechman.

25 MR. FISKE:

If you choose not to start

1 Zechman 724 O

2 this afternoon, I am not in a position to 3

require you to do it.

I want to make it clear 4

that we don't consent to this, k

5 MR. MacDONALD:

Whether or not you consent, 6

I am saying that Mr. Zechman has testified for 7

many days and is tired and exhausted at the end 8

of the day, on the basis of that it's not in the 9

best interest of anybody and not fair to anyone 10 if we start cross-exa-ination at this time a

11 and to the extent that he is leaving today, I

, 12 don't think it would be concluded anyway and since n

(/

13 we have scheduled and rescheduled direct and 14 cross-examinations during the case, I think 15 that that's a practice we will continue.

16 MR. FISKE:

I say there is no way we can require you to proceed this afternoon.

I want l

17 18 to make it clear that we are not in agreement 19 with what you have just said.

20 MR. MacDONALD:

That's fine.

I can't make l

21 you agree to anything, Mr. Fiske.

22 MR. FISKE:

We also would like to finish 23 this up as quickly as possible and we would be 24 happy to do it any day next week.

25 MR. MacDONAL:

As we have done in i

1 zechman 725

(-

2 scheduling and rescheduling direct examinations, 3

as soon as we can with everybody's schedules, 4

mine and the witness' get back together again lh 5

to finish this as expeditiously as we can, and 6

that's what we will try to do and we will try on 7

every deposition.

It doesn't serve the purpose 8

this afternoon, not being able to complete it 9

MR. FISKE:

I want to make it clear.

We are 10 ready to go now, we are ready to go Monday, we are

'll ready to go Tuesday, we are ready to go Wednesday, 12 and if you want to defer it beyond that.

13 MR. MacDONALD:

Let me say there are 14 many different times in the scheduling of 15 depositions and rescheduling direct testimony 16 when we are ready to go ahead and you are not l

17 and you can't and we try to work this out to 18 mutually convenient times, and I think we will l

19 continue to do that throughout the case.

20 That's one of the reasons that we talk 21 on the telephone and try.to get the dates 22 convenient for everyone.

l 23 There have been various times when we are i

24 ready to go on with direct and you have not l

25 and vice versa.

I appreciate your telling me i

l

1 Zechman 726 O

2 that you are available Monday, Tuesday and 3

Wednesday and I will take that into consideration.

4 MR. FISKE:

We are available on those dates llh 5

and we are available at the earliest opportunity 6

five minutes from now to what you think is an 7

appropriate date if you don't agree to those.

8 MR. MacDONALD:

Okay.

9 MR. FISKE:

Thank you, Mr. Zechman.

10 (Time noted:

1:45 p.m.)

11 12 13 14 15 16 17 18 19 20 til 22 23 25

l 1

7 2 7.

(v)

CERTIFICATE 2 ;,

3li STATE OF NEW YORK

)

ss.:

COUNTY OF NEW YORK

)

4 4

I, CATHERINE COOK l

, a Notary Public of the State of New York, do hereby certify that the continued deposition of 7

i RICHARD W.

ZECHMAN was taken before 8

me on March 26, 1982 consisting of pages 642 through 726 I further certify that the witness had been previously sworn and that the within

/V) transcript is a true record of said testimony; t

13 That I am not connected oy blood or marriage with any of the said parties no" lo, I

interested directly or indirectly in the matter l

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

18 IN WITNESS WHEREOF, I have hereunto set my 19 hand this le;Y day of GM 1982.

20 t

21 22

,g l

9 23

-rL T uva, hrt CATHERINE COOK i

n

,,/

l 25 l

.I l

March 26, 1982 728 I NDEX Witness Page Richard W.

Zechman 644 o0o EX H I B IT S B&W FOR IDENTIFICATION PAGE 571 Collection of pages captioned 665

" Nuclear Energy Training Instructor's Guide Plant Performance."

572 Section 2.0 of the Technical 665 Specifications for TMI Unit 2, 573 Unit 2, Operating Procedure 668 2102-3.3, Decay Heat Removal Via OTSG."

I o0o l

l l

O L

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