ML20072H858

Deposition of RW Zechman on 820311 in New York,Ny. Pp 157-272

ML20072H858
Person / Time
Site:	Crane
Issue date:	03/11/1982
From:	Zechman R GENERAL PUBLIC UTILITIES CORP.
To:
References
TASK-*, TASK-01, TASK-04, TASK-1, TASK-10, TASK-4, TASK-GB NUDOCS 8306290781
Download: ML20072H858 (115)

Text

bt 157

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UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK

- - -x GENERAL PUBLIC UTILITIES CORPORATION, a

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

Plaintiffs, s

-against-80 Civ. 1683 (RO)

THE BABCOCK & WILCOX COMPANY and J.

RAY McDERMOTT & CO.,

INC.,

Defendants.

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

Continued deposition of General Public Utilities Corporation by RICHARD W.

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

(

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

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

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

I and for the State of New York.

5 I

/3 DOYLE REPORTING, INC.

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

NEw YomK. N.Y.

10017 CHARLES SH APIRO, C.S.R.

TELEPMONE 212 - 867-8220 8306290781 820311

(

's gDR ADOCK 0500028

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1 158 i

w s,_)

2 Appeara nc e s:

3 4

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

Attorneys for Plaintiffs ggg 5

425 Park Avenue New York, New York 6

By:

ANDREW MacDONALD, ESQ.,

7

-and-JULIET NEISSER, ESQ.,

of Counsel 9

10 11 DAVIS POLK & WARDWELL, ESQS.

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

ROBERT B.

FISKE, ESQ.,

14

-and-KAREN E.

WAGNER, ESQ.,

10 o'f-Counsel 16 i

-4 g

18 Also Present:

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19 SUSAN HANSON, Paralegal

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s Davis Polk & Wardwell, Esqs.

20 21 I

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159 4

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2 P. ICHA RD W.

ZEC HMAN,

resumed, 3

having been previously duly sworn by the 4

Notary Public, was examined and testified y

lll 5

further as follows:

6 EXAMINATION (Continued) 1 t

7I B$ MR. FISKE:

s s 0

Q Mr. Zechman, do you realize you continue d

9' to he under octh today?

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i 10

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A I d, o.

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11 gj MR. MacDONALD:

Regarding a recent t

12

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producticn of some documents from the training

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

14 where thoss documents came from, and I spoko

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15 to Rochelle Hanson who I understand was the

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

~ training department documents, and 18 general

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

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20 training department files as a whole, no particular s

21 individual's files.

l

~

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

l 25 i

MR. FISKE:

Thank you.

l

I Zechman 160 m(,)

2 Q

Mr. Zechman, when we left off yesterday 3

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

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

reviewing it, whether you wanted to change any of 7

the answers that you had given concerning whether 8

specific programs described in this exhibit had 9

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

11 Have you done that?

12 A

I have read the document.

One point s

13 of clarification --

(v) 14 Q

Are there any changes you would like to 15 make?

16 MR. MacDONALD:

I don't think it is 17 necessarily changds.

He may want to amplify.

I0 A

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

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

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

't. '

25 training program and may have not included all the

l 1

zechman 161

(_,)

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

initial staff.

4 There are certain lectures, programs, jll 5

that are identified in here that we may still 6

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

that these are spelled out.

8 One other point of clarification, and 9

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

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

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

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

18 Q

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

20 A

I had the title, yes.

21 Q

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

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

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

1 Zechman 162

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2 which is captioned " Metropolitan Edison Requalification 3

Program."

4 I believe you testified yesterday that lll 5

this program was conducted during the period of time 6

November 1977 through March

'79.

7 MR. MacDONALD:

Are you asking whether 8

that is his testimony or are you --

9 Q

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

12 A

What were the dates?

(~)S 13 Q

November '77 to March

'79.

s _.

14 A

That was the time requalification programs 15 were going on.

There were amendments in that 16 interval.

17 Q

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

21 Do you see that?

22 MR. MacDONALD:

Section 13.2.2?

23 MR. FISKE:

Yes.

3

(~)

24 I

A I see that.

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23 Q

Was it your understanding that that was

1 Zechman 163

(,/

2 the purpose of the requalification program?

3 A

It's my understanding that was the 4

purpose of the requalification program, yes.

lll 5

Q Is it correct that some time in 1978, 6

beginning some time in 1978, the control room operators 7

attended requalification training sessions less 8

frequently than they had previously because of a 9

change in the shifts from uix to five?

10 A

That is not necessarily true.

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

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

~

u-14 Q

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

17 A

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

l l

20 g

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

i 23 A

Yes.

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

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25 l

shift that was off and a training shift.

1 Zechman 164

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(_)

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

three operating shifts, and an off shift.

4 Q

How long was each shift?

lll 5

A The relief shift by the way was used for 6

the training shift.

7 Q

How long was each shift?

8 A

Eight hours, working hours.

9 Q

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

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

14 MR. MacDONALD:

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

16 MR. FISKE:

Yes.

17 Q

Is that the concep t?

10 A

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

20 Q

Why don't you describe it then?

21 A

Fine.

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

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

l 24 correct that.

(~)

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

1 Zechman 165 2

7:00.

There would be one shift that would be 3

off and there would be one shift that would be 4

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

It's that lll 5

shift that would be in training during normal shift 6

rotation.

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

see the relief -- each relief shift.

9 Q

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

12 A

si:t shifts means during the daylight hours

)

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

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

16 Q

How was that different when there were 17 five shifts?

l l

18 A

The difference is that instead of the l

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

20 I

sixth shift for training.

21 Q

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

I 22 Could you try again.

24 3

yes,

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25 When there are slx shifts, there are six

1 Zechman 166 OV 2

bodies.of individuals as opposed to when there are 3

five shifts, there are five bodies of individuals.

4 During six-shift rotation, one of the g

5 shifts is a training shift.

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

relief shift that becomes the training shift.

O We utilized or trained the people who are normally 9

assigned to relief.

10 Q

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

14 A

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

19 g

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

21 My question was, is it your testimony

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

25 A

I have no recollection that I have made

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

personally made between the amount of training for 4

six shifts and the amount of training for five h

5 shifts.

6 I can only state that we certainly 7

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

program as required.

9 MR. FISKE:

Could you read that answer 10 back, please.

11 (Record read back.)

12 Q

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

15 A

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

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

-21 Q

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

U Do you have that in front of you?

24 A

Yes, I do.

25 Q

That is a memorandum written by Mr. Goodman.

1 Zechman 168 ID

(_)

2 A

It is not.

3 Q

Pardon me?

4 A

Not tat one I have in front of me.

lll 5

Q Is this it?

6 A

Exhibit 303 is before me at this time, 7

yes.

8 Q

That is a memorandum dated June 21, 9

1978, correct?

10 A

That is correct.

11 Q

That is from Mr. Goodman?

12 A

Yes.

I) 13 Q

Subject:

" Unit 1,

2, Requalification

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14

~ Program Attendance," right?

15 A

Yes, sir.

16 Q

And you received a copy of that?

17 MR. MacDONALD:

Does he recall receiving 18 a copy?

19 Q

You did receive a copy, did you not?

20 A

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

I was aware of the problem 9

22 at that time.

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

24 Q

Do you recall learning in or about June

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

1 Zechman 169

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2 requalification training program cycle had been 3

completed, that there was an overall attendance of 4

only 44 percent for licensed personnel?

ll 5

A I no longer recollect any numbers of 6

that sort.

7 Q

You referred a moment ago to make-up 8

packages.

9 A

Yes.

10 Q

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

12 A

Yes.

(m) 13 Q

I take it, is it correct, what v

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

l 18 in class?

l 19 A

That is correct.

20 Q

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

22 A

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

Sometimes it would include t

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

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

I 1

Zachman 170 1

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Q And this was to, in effect, substitute 2

for what the individual had missed by not being at 3

the class?

4 A

This was a way for that individual to 5

make up what he missed in class.

6 Q

Mr. Goodman states in this memorandum, 7

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

substitute fo r live Jnstruction. "

9 Do you see that?

10.

Where are you at?

11 Q

Item No. 2 down at the bottom.

12 (g

A I see that statement.

(.)

13 Q

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

15 A

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

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

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

h Q

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

24 MR. MacDONALD:

He just told you he didn't 25

1 Zechman 171

('N,

(_)

2 necessarily recall whether he ever heard that.

3 Q

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

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

people in class learning the information directly in 6

class than having to get it from a care package 7

afterwards?

8 A

It is my opinion that I certainly would 9

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

13 our requalification program.

(v) 14 Q

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

17 MR. MacDONALD:

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

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

21 MR. FISKE:

It is a major issue in this i

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

24 l

the training program was that people were g3 i

i

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25 not going to class and, therefore, missing

1 Zechman 172 fm 4

4 iJ 2

the benefits of live classroom instruction.

3 MR. MacDONALD:

You asked for his 4

understanding and his understanding he gave llh 5

you on the record.

6 I think there is a full statement on the 7

record of what his understanding was.

8 MR. FISKE:

I asked whether he simply 9

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

C\\

(_,1 13 Q

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

16 Do you have that in front of you?

17 A

I have Exhibit 304 in front o f me.

18 Q

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

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

23 A

It says September 1 on mine'.

(~N 24 Q

September 1,

1978, is that correct?

()

25 l

MR. MacDONALD:

Are you asking if that

1 Zechman 173 2

is what the document says?

3 MR. FISKE:

Yes.

4 A

That is what the document says.

h 5

Q The document indicates you received a 6

carbon copy, does it not?

7 A

The document says the secretary had a carbon 8

copy supposedly to me.

9 Q

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

11 A

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

13 Q

Is one of the underlinings under your 14 name?

15 A

Yes.

16 Q

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

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

l 19 A

In the copy that I have, that is underlined.

j

(

20 Q

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

22 A

Not to the best of my recollection.

I l

23 Q

Did you put the underlining under your 24 name?

l 25 A

Not to the best of my recollection.

1 zechman 174 Ch

()

2 Q

Did you understand when you received a 3

copy of this, that somebody had underlined your name 4

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

to the material that was underlined in the memo?

6 MR. MacDONALD:

Objection.

You asked 7

whether or not he recalls receiving the document.

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

document.

10 MR. FISKE:

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

7. \\

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)

13 memo.

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

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

17 MR. MacDONALD:

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

19 MR. FISKE:

Let's find out.

20 MR. MacDONALD:

Why not ask him the i

21 question instead of making an assumption?

l 22 MR. FISKE:

I did.

l 1

23 MR. MacDONALD:

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

N._.A I

25 MR. FISKE:

I said when he received it.

l

1 zechman 175 O

2 I think it's a fair assumption he 3

received it when it is produced by Met Ed and 4

it shows a carbon copy was sent to him.

lll 5

MR. MacDONALD:

You can assume anything 6

you want.

7 Ask the witness a question.

We are 8

not here to learn about your assumptions.

9 MR. FISKE:

Read the question.

10 (Record read back.)

11 A

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

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

I don't recollect either 15

- way this particular document at this time.

16 Q

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

20 A

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

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

25 Q

And that answer applies, you say, to both

1 Zechman 176 k./

2 Exhibits 303 and 3047 3

A Yes, sir.

4 Q

You are not denying, are you, during lll 5

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

training program at Med Ed that you were aware that 7

less than half the licensed people were attending 8

the requalification classes?

9 A

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

I cannot confirm your 11 number at this time.

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

13 was an attendance program.

That I will confirm.

q,j 14 Q

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

16 A

Yes, sir, I did.

17 Q

Did you bring this question of the l

l 18 poor attendance by the licensed operators at l

19 training programs to the attention of management?

I l

20 A

I certainly did.

21 Q

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

23 A

That would have to be time qualified.

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

( -}

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25 attendance problems.

There was a period of time

1 Zechman 177

(~N

(,!

2 in which I made senior management and operations 3

management aware of the attendance problems and 4

there was a period of time it improved.

lll 5

Q It certainly hadn't improved by the 6

time you ceased functioning as head of the training e

7 department, had it?

8 A

I don't recall the period, exact period 9

when it did improve.

10 g

"There is a memorandum dated September 1,

11

'78.

12 Isn't that just about the day you became

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(

)

13 supervisor of the training department and R./

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

16 A

That is correct.

17 Q

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

20 MR. MacDONALD:

Are you asking for his l

21 recollection?

22 MR. FISKE:

Yes.

23 A

My recollection is not j

I told you i

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

(..)

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

1 Zechman 178 2

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

clear recollection in my mind of the period of time 4

that we had the problem and when the problem h

5 cleared.

6 Q

Well, you cannot tell us as you sit here 7

today that this attendance had improved in any 8

significant way as of the time you assumed the 9

position of supervisor of training, can you?

10 A

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

14 Q

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

II A

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

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

21 Q

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

24 A

It's been too long ago.

I have no 25 recollection at this time.

1 zechman 179

(

)

's_/

2 Q

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

or the other as you sit here today?

4 A

That is correct.

llh 5

Q You were interviewed by Mr. Keaten I 6

think as you told us previously at some point after 7

the accident, is that correct?

8 A

That is correct.

9 Q

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

McCormack.

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

fx

( )

13 A

Yes, part of the time.

14 Q

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

17 A

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

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

21 present periods.

I just don't recall.

22 Q

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

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

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

l

1 Zechman 180

.0

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2 question.

3 MR. MacDONALD:

Can he read through it 4

before you ask a question?

llI 5

MR. FISKE:

By all means.

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

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

marked B&W Exhibit 561 for identification as i

9 of this date.)

10 Q

Have you finished reading that exhibit?

11 A

There were some things I couldn't make out.

12 Q

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

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

14 A

Yes.

I i

15 MR. FISKE:

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

17 MR. MacDONALD:

Sure.

18 (Notes made by the witness on a yellow l

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

l 21 Q

Looking at the handwritten memorandum g

l W

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

23 reading that, does that in any way refresh your

(~))

24 recollection on any subject that you discussed with L.

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

l 1

1 Zechman 181 e

h

\\m.)

2 MR. MacDONALD:

Let him answer the 3

question.

4 MR. FISKE:

All I want to find out llh 5

A There are selected items in there that 6

I recall discussing.

7 Q

Let me direct your attention, Mr. Zechman, 8

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

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

n()

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

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

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

Off-shift people were the worse in l

19 attendance.

Shift supervisors were not as bad, but l

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

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

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

l l

1 l

l

1 Zechman 182

\\

,(,)

2 Do you see those portions of the notes 3

that I just read?

4 A

Yes.

lll 5

Q Did you or Mr. Beers or Mr.

McCormack 6

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

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

A I can only testify to what I recall saying 9

to them and I do recall discussing attendance.

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

12 I do recall discussing the attendance

/( j) 13 problem.

g 14 Q

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

I 17 MR. MacDONALD:

Are you asking whether he i

18 recalls telling Keaten that?

19 MR. FIS KE :

Yes.

20 A

I don't recall either way.

21 Q

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

24 MR. MacDONALD:

You mean o f the portions g-

'\\,s/

25 he can make out?

1 Zechman 183 O

2 MR. FISKE:

Yes.

3 MR. MacDONALD:

It is not a transcription.

4 A

In the notes, it looks like it was h

5 centering around the period 1978.

6 Q

I guess we can draw our own conclusions I

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

the fact that attendance continued to go down after 9

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

MR. MacDONALD:

Draw any conclusion you I

want.

14 Q

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

A Not in this document.

20 Q

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

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

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

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

25 those have been identified as notes that Mr. Keaten

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

1 Zechman 184 Cs i

i

's /

2 made of the interview that we have just been 3

discussing.

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

5 that I have.

6 Have you seen that document before?

7 A

You have given me three documents.

8 Q

Jt is all one document.

9 A

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

11 Q

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

in

(_,)

13 A

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

15 Q

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

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

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

21 Do you see the number there?

Could you 22 just read that off the notes?

23 A

Starting off with "1978"?

('N 24 Q

Yes.

What does it say after that?

25 A

"3" something.

I would be guessing l

l l

s-1 Zechnan 185 f~s

~

's 2

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

s; 3

Q Did you see any thing in these notes that 4

\\

4 referred to any increase in attendance at any time s

s.

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

A 6

MR. MacDONALD:

He just told you he couldn't 7

read them.

The document speaks for itself.

8 You may ask him present-sense impression s

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

'm 10 what they are.

e 11 MR. FISKE:

I am asking him -- do you

\\

12 object to that question?

s

(^~f

\\.

13

(,j s.

MR. MacDONALD:

I object to the question.

'~

14 MR. FISKE:

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

s 17 Q

Mr. Zechnan, there is --

18 MR. MacDONALD:

That is not what I said.

g j

19

't.

MR. FISKE:

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

21 MR. MacDONALD:

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

2 Q

The next sentence after "1978 - 30 percent

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

'\\_ / \\

25 written by instructor."

Then the next line, as I 1

i

\\

's

\\

,i, 1

Zechman 13d-

<l i

(~'T 1

N' 2

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

3 Do you see those two?

L

,i 4

A I don't recollect the first word.

lll 5

I recollect " Requires care packages VIitten by 6

instructor."

I recognize " required" something, i

1 7

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

8 Q

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

-l I

t.

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

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

g

(_)

13 A

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

I no longer, recall the magnitude of 15 those.

16 Q

If these notes were to be construed as i

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

McCormack i

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

19 2500 packages per year, we uld you --

20 MR. MacDONALD.

I object.

That is purely 21 hypothetical.

g s

l W

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

(]

24 Q

Isn't it a fact that at the intbeview

^

L!

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

/

s 1

zechman 187 p

a

\\/

2 or Mr.

.McCormeck that the number of care packages i

3 was 2500 per year?

4 A-I recall at that meeting indicating that ji

/

h 5

there was a large number of care packages.

t<

[

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

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

c',

been pure speculation.

7 don't recall that number.

r-9 Q

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

I2 A

I have no recollection --

(

)

13 MR. MacDONALD:

Objection.

14 Go ahead.

15 He told you he doesn't recall the

~

t' 16 numbers.

17 Q

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

20 MR. MacDONALD:

Objection.

He told you 21 his recollection.

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

2U V

Q You certalnly recall it was well up in

[~N, 24 the hundreds?

U 25 A

I don't recall the number any more.

l a

I Zechman 188

('

\\

(s/

2 Q

You have no recollection at all?

3 A

I recollect that there was a number of 4

them.

I don't recollect the magnitude of them any 5

more.

6 Q

Would ~you agree with Nelson Brown 7

that the preparation of these care packages was a 8

very time-consuming process?

9 MR. MacDONALD:

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

,(,l 13 p ro ce s s ?

14 MR. FISKE:

1978 or

'79.

Right up to 15 MR. MacDONALD:

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

17 MR. FISKE:

I am not talking about the 18 number.

19 Q

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

('~')

24 preparation of these care packages was a "very

\\_/

25 time-consuming p rocess"?

1 Zechman 189 2

MR. MacDONALD:

Objection to.the form 3

of the question.

4 Do you want to ask what his recollection 5

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

process?

You may ask that question.

7 The form of your question I think is objectionable.

8 Q

Is it fair to say that the preparation 9

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

13 MR. MacDONALD:

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

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

IO If you want to ask apart from that 19 j

MR. FISKE:

At the moment, I am asking i

20 apart from Mr. Brown.

I am asking it apart l

21 from Mr. Brown.

22 Q

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

25 Is it fair to say that was a very L

_ = _

~~

1 1

Zechman 190 1

2 time-consuming process?

3 A

I testify that the time it takes to prepare 4

a care package is directly related to the subject I

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

amount of material to be covered during that period i

7 of time.

8 Therefore, some care packages would 9

take a lot less time than others.

It varies from 10 care package to care package.

11 Q

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

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

19 A

You quoted a number of 2500.

I don't 20 agree with that number.

21 Q

I said whatever it was up to 2500.

22 MR. MacDONALD:

Whatever your recollection 23 is, Mr. Zechman.

()

24 A

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

1 Zechman 191

,n

(

)

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

extra work.

4 Q

Isn't it also true that in addition to h

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

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

receive it?

8 A

That was part of the normal job with 9

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

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

12 matrix.

((s /

13 Q

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

17 A

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

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

20 Q

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

[

24 A

That is correct.

V; 25 Q

And those were the people that held the

1 Zechman 192 N

s 2

position of administrator / technical training as it has 3

been described; so-called instructors?

4 A

Yes, sir.

There are times when the G

5 group supervisors may have participated.

6 Q

It would either be the group supervisors 7

or the instructors?

8 A

That is correct.

9

~

May we take a break?

10 Q

Sure.

11 (Recess taken.)

12 MR. FIS KE :

Read back the last question O(_/

13 and answer, please.

14 (Record r ead back. )

15 BY MR. FISKE:

16 Q

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

22 Do you see that?

23 A

I see that.

24 Q

Isn't it a fact that before the Three 25

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

1 Zechman 193 O

2 to enforce attendance except the licensing exam?

3 A

Are you asking me if that is my quote?

4 MR. MacDONALD:

That is basically what 5

he is asking you, whether you recall saying that.

6 Q

That you held that view.

7 A

I held a view prior to the accident 8

that it was the responsibility of the line function 9

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

11 Q

As far as the people who were supposed I

12 to attend the training were concerned, there was no

()

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

15 MR. MacDONALD:

I object to the form of 16 the question.

He gave his answer.

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

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

21 MR. FISKE:

It is a preliminary question.

22 g

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

A 24 A

That is not a fact.

25 g

Isn't it a fact that you made a statement

1 Zechman 194 7_

'N' '/

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

3 MR. MacDONALD:

By "you" you mean Mr.

4 Zechman?

5 MR. FISKE:

Yes.

6 A

I have no recollection of making a 7

statement in that format.

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

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

11 Q

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

You understand what we

(' \\

\\J 13 are talking about.

~

14 MR. MacDONALD:

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

16 Do you have another question?

l 17 MR. FISKE:

Yes.

It is the same question.

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

l 19 Q

Did you tell Mr. Keaten during this l

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

g 22 MR. MacDONALD:

Objection.

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

rx l

l 24 i

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

\\_/

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

1 Zechman 195 O

2 recall ever making that.

What he recalled in 3

that subject areas was what he testified to.

4 Q

Is that correct, Mr. Zechman, what your 1

5 counsel just said?

6 A

That is correct.

7 Q

I will read you from a question and 8

answer at Mr. Keaten's deposition.

I will be happy 9

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

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

I recognize 14 it is a very poor copy.

Unfortunately, this is the i

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

i 17 "Looking at the third comment down i

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

20 exam,' do you see that?

l f

I 21 "A awer:

I think that is what it says.

ggg 22

" Question:

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

24 way to enforce attendance at training sessions other j

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

1 Zechman 196 C) 2 exam?

3

" Answer:

I believe that I recollect that 4

a comment as to that regard was made.

I don't 5

remember specifically whether it was a complaint or 4

6 simply a comment.

7

" Question:

Do you know who made the 8

comment, Mr. Zechman or Mr. Beers?

9

" Answer:

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

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

15 MR. MacDONALD:

I object to the form of 16 the question.

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

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

20 MR. FISKE:

I think I am asking an entirely 21 reasonable question.

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

()

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

--~-r,--

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

-r-.-,,

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

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

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

I 1

Zec hman 197

,n

~.

2 he did make that statement.

3 A

I stick to my previous testimony.

4 Q

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

after the Three Mile Island accident, attendance 6

at training sessions continued to be poor?

7 MR. MacDONALD:

I object to the form of 8

the question.

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

/~'T

(,/

13 testimony has been.

I4 MR. FISKE:

We have yet to identify that 15 time.

i 16 Q

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

20 MR. MacDONALD:

I object to the form of 21 the question.

g) 22 Q

You may answer.

23 THE WITNESS:

Would you repeat that question

/ ';

24 for me, please.

\\J 25 (Record read back.J

1 Zechman 198

,3 fVl 2

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

magnitude of attendance at that period of time.

4 Q

You don't have any recollection that 5

classroom attendance in the requalification program 6

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

'79 through December '79?

8 A

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

recollect the time frames, the attendance time 10 frames.

That is all I'm saying.

'll Q

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

/,'

k-13 A

I don't remember today.

14 MR. FISKE:

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

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

L.

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

20 Q

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

I have.

23 Q

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

/^

(_)\\

24 A

That is correct.

25 Q

Subject:

" Unit 2 Requalification

1 Zechman 199 7-~ t K. /

2 Attendance"?

3 A

That is correct.

4 Q

Is that your signature at the bottom, k

5 "R.

W.

Zechman, Supervisor of Training"?

6 A

That is not my signature, and he had 7

authority to sign my signature to that letter.

8 I drafted the letter; he signed it.

9 Q

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

/^N

(,)

13 A

That is correct.

14 Q

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

17 A

Can you repeat that?

18 Q

Was this written as part of your job?

19 Was this done in the course of your duties?

20 A

In accordance with my duties to make 1

21 these kinds of things, yes.

22 MR. FISKE Mark this as the next exhibit.

23 (Copy of a memorandum from James P.

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

1 1

Zechman 200 j

e

\\/

2 Q

Do you still have Exhibit 563 in front 3

of you?

4 A

Yes, I do.

lh 5

Q The first sentence refers, does it not, 6

to a report prepared for you by Mr. Frederick 7

concerning attendance at the Unit 2 requalification 0

program for the period of November 5,

'79 through 9

December 14,

'797 e

10 A

That is correct.

11 Q

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

.e^

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

15 Do you see that?

16 A

I see that.

1 Q

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

i l

A To the best of my recollection, I wrote 1

20 the letter and I underlined it.

21

)

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

i be tracked.';

\\_/

25 Do you see that sentence?

1 Zechman 201 0

2 A

I do.

3 Q

was_the procedure for preparing care 4

packages after the Three Mile Island accident h

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

went into them and how it was done?

7 A

Yes.

8 Q

In the next p.tragraph there is a 9

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

12 Do you see that reference?

I'3 A

Yes, I do.

14 Q

Who is Mr. Chwastyk?

15 A

He was a shift supervisor, Unit 2.

16 Q

And Mr. Smith?

i 17 A

Shift supervisor, Unit 2.

18 Q

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

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

22 Does that sentence refer back to i

23 Mr. Chwastyk and Mr. Smith?

l 24 A

To the best of my recollection, it did.

25 Q

This memorandum is written to Mr.

L.

L.

1 Zechman 202 2

Lawyer, is that correct?

3 A

That is correct.

4 Q

What was his position?

lh 5

A Acting manager of training.

6 Q

The last sentence says, or next to last, 7

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

of senior management personnel such as yourself is 9

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

O

\\/

13 Do you see that?

14 A

Yes, I do.

15 Q

Mr. Lawyer was part of senior management 16 personnel?

17 A

Yes, he was.

18 Q

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

No.

21 Q

Was there a position in existence in g

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

(

24 A

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

Mr. Lawyer's position was acting manager.

1 Zechman 203

[']

x>

2 By title they are not the same.

By 3

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

ho n e s t.

I 5

Q Well, trying to compare the two positions 6

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

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

in 19787 9

MR. MacDONALD:

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

12 MR. FISKE:

No, I am asking him to make it p!

(_,

13 now.

14 MR. MacDONALD:

I am going to object to 15 that.

Ask him what he recollects at this time.

16 A

Do I answer?

l 17 Q

Yes.

l l

18 M R'. MacDONALD:

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

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

9 l

22 If you want to ask in or around this l

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

i

(

m.

24 will instruct him not to answer.

~

LJ l

25 Q

This memo in December of 1979 wasn't the l

l l

1 Zechman 204 O

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

of higher authority in order to try to induce people 4

to attend training sessions, was it?

5 MR. MacDONALD:

Whether this was the first 6

time he can recall using the term " clout"?

7 MR. FISKE:

No, that is a colloquial term.

8 You can equate it with any other noun that 9

occurs to you.

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

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

15 A

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

II Q

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

24 MR. MacDONALD:

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

1 Zechman 205 I

i

\\_/

2 MR. FISKE:

I am asking him is that still 3

his recollection, in light of the memorandum 4

that I have just shown him in December of

'79.

lI 5

THE WITNESS:

Read it back.

6 (Record read back.)

7 MR. MacDONALD:

My objection stands.

8 A

My only recollection still stands, what 9

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

11 Q

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

r (-

\\

x/

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

14 memo?

15 A

Yes.

16 Q

Do you see the reference to the word II

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

18 A

Yes, I do.

19 Q

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

l gg 21 A

That is in the memo written by me.

22 Q

You have put " clout" in quotes.

3 A

And I put " clout" in quotes.

1

/~~()

24 Q

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

1 Zechman 206 2

had with Mr. Keaten on October 18, 1979.

3 Immediately following -- let me read 4

two sentences in sequence.

"This attendance was 5

brought to the attention of the plant management 6

on a number of occasions.

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

continued to go down.

Even with the training 9

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

8 i

)

13

\\/

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

15 MR. MacDONALD:

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

17 MR.

FISKE:

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

20 It reads, from the notes of the meeting h

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

r^s 24

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

(

25 department to improve attendance."

1 zechman 207 2

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

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

6 5617 7

MR. MacDONALD:

I object.

I don't know 8

whether that was ever even said at the time 9

of an interview.

10 MR. FISKE:

You can object.

11 MR. MacDONALD:

I have just stated my 12 objection.

4 ()

13 Q

You may answer.

I 14 A

I have no recollection of the choice of i

l 15 my words at that time.

16 MR. FISKE:

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

l l

19 This is a document, a handwritten note, l

20 four pages.

g 21 Q

Do you have that in front of you?

l W

22 A

Yes.

23 Q

You may want to take a moment to read i

24 that.

25 A

I have read it.

I t

f

1 Zechman 208 p.

(

)

\\/

2 Q

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

handwritten memorandum to Mr. O'Hanlon from Mr.

T.

L.

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

to Mr.

G.

R.

Miller, Mr. Tsaggaris, Mr. Goodman, 6

yourself, and Mr. Kunder, is that correct?

7 A

Yes.

8 Q

can you tell us, looking at the first 9

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

10 A

It looks like it's not clear.

11 Q

Some time in 1977 in any event?

12 MR. MacDONALD:

The document says what

(~m

(_)

13 it says.

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

14 Ask the person who wrote it.

15 MR. FISKE:

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

17 Q

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

l l

19 A

I recall getting a copy of this.

20 Q

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

21 A

That's what the letter says.

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

23 Q

Well, this certainly came to your

~( ')

24 attention some time in 1977, did it not?

L.J 25 MR. MacDONALD:

He told you what he I

1 Zechman 209

-p, k

2 recalls.

3 MR. FISKE:

I am seeing if we can include 4

the entire year 1977 in his recollection.

h 5

A I recall receiving this document.

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

7 Q

In 1977 did you know an individual by the 8

name of T.

L.

Book?

9 A

Yes, I did.

10 Q

What was his position in June of 19777 11 A

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

<k/

13 promotion somewhere in that tine frame.

14 Q

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

I have no recollection what his specific i

l 17 title was at that time.

18 Q

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

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

[mx,)

e 24 referred to?

l 25 MR. MacDONALD:

You want to know what he l

l

1 Zechman 210 2

unders tood when he received the memo?

3 MR. FISKE:

Yes.

4 Q

When you received the memo, did you O

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

6 A

I unders tood S/F.

I don't know what is 7

S/G.

8 Q

Maybe it is an S/S.

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

11 A

Yes, I did.

12 Let me correct this.

I understand the t

13 S/F was shift foreman.

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

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

17 Q

Did you understand it when you received 0

the memo?

19 MR. MacDONALD:

That is what he is 20 testifying to.

21 Q

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

Mr. Book was talking about?

I n

(

)

24 MR. MacDONALD:

I don't think that was

i. s '

25 the question.

You asked specifically whether

1 Zechman 211

,r\\

()

2 he had a recollection of what those two marks 3

were when he received the memo.

4 Q

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

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

S/S when you received this memo?

7 A

I don't know that we clearly identified 8

that as S/S.

It's not clear to me at this time 9

looking at that.

10 Q

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

()

13 you received this memo?

14 A

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

16 MR. MacDONALD: Not.

Your assumption.

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

18 about that particular mark.

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

20 he assumed he might have thought on that particular i

l 21 mark.

i 22 Q

Any vay you can.

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

l q

24 l question.

O j

25 A

To the best of my recollection, I l

L

1 Zechman 212

, -(,)

2 understood what he meant.

3 Q

By that he meant shift supervisors, didn't 4

he?

5 A

To the best of my recollection.

6 Q

Let me read the whole paragraph and 7

then ask you whether I am correct in my understanding 8

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

at the time you received it.

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

It's time to put training

(,.,)

I3 back in the training department where it belongs and.

14 in a responsible fashion.

This means more training 15 space, people and expertise.

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

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

22 department?

23 MR. Mac DONALD:

Are you asking basically 24 l

(~x what he understood when he read that paragraph

\\

'x-25 after receiving the memo?

l

n

'a }

l Zechman 213

,~.

U 2

MR. FIS KE :

I am asking if he had t he s..

3 understanding that I just read.

s

}4 MR. MacDONALD:

What he understood when

- \\-

5 he read the paragraph.

)

1

'6 MR. FISKE:

Read the question back.

3

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

0}

S MR. MacDONALD:

I think you are putting i

.\\

s 9., '

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

~

10 (l

')

may not have intended by writing the paragraph.

e 11 The easy question 'is what he understood 4

a s

l_.

when he read the paragraph.

12

~

{

Q '.

-(

lj3 g

MR. FISKE:

I will put the question the

.5

' I4 way I want to.

I think I am entitled to ask

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

4

>16 whole paragraph that I just expressed.

17 MR. MacDONALD:

I am going to object.

18 MR. FISKE:

Read the question again, please, i

If (Rec,ord read back.)

I pnderstocd'this 2(

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

21 who was upset at 9

22 Q

Yes, I understand.

But that he was i:

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

... l

(

)

'2p

-in the last question.

U MR. MacDONALD:

My objection still stands.

1

l l

s 1

Zechnan 214 fm (s,)

2 Q

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

4 training should be done in the training department.,

lll 5

isn't that right?

6 MR. MacDONALD:

I object.

7 What your recollection was at the time.

8 A

My recollection is exactly wh at he wrote t

9 here.

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

11 Q

Well, did you understand when he said it l

is 12 time to put training back in the training department

(~%

( )

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

16 MR. MacDONALD:

Are you asking him to 1

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

1 18 wrote the memo?

l l

19 MR. FISKE:

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

21 MR. MacDONALD:

I object.

22 THE WITNESS:

Read the question.

23 (Record read back.)

(~~T 24 MR. MacDONALD:

I object.

LJ' l

25 If you recall anything about what was l

l

s -

h

f..

JA 1

2e chmars 215 I

(~}^

't

(/

2 said --

3 MR. FIS KE :

No.

k, 4

MR. MacDONALD:

You are asking him to

(

lh!

5 ge't[into someone!s mind.

1. j 6

MR. FISKE:

No.

s

.s.,

g uy.

MR. MacDONALD:

You are using your 8

~

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

whether or not Mr. Zechman recalls those

{Q..

thoughts.

If you want to ask Mr. Zechman what i

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

that paragraph, go right ahead.

4 13 MR. FIS KE :

No.

1, Mr. MacDonald, you know,

/

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

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

9 22 MR. MacDONALD:

You can assume whatever 23 you want.

24 MR. FIS KE :

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

1 Zechman 216

,es

(_,/

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

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

year was being done in the training department.

lll.

5 A

I believe that he was very confused at 6

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

memo, 8

Q And you reached that conclusion without 9

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

11 A

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

No more, no less.

( )s 13 MR. MacDONALD:

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

15 Q

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

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

18 to five-shift program.

l l

19 Do you remember that?

20 A

Yes, I Co.

21 Q

Looking at this memo dated June 7,

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

does that l

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

f"~]

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

25 from six shifts to five?

1 zechman 217

(

\\

(_,/

2 THE WITNESS:

Read that question.

3 (Record read back.)

4 A

All this reflects in my mind is a statement lh 5

made by Ted Book.

I still don't have a time frame 6

when that shift was made, in my mind.

7 Q

Did you understand when you received this 8

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

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

r)

(

)

13 A

This is not sinking in.

I would like v

14 to take a break after this.

15 THE WITNESS:

Read it back, please.

16 (Record read back.)

l 17 A

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

19 Q

Did you ask him what he meant by it?

20 A

I have no recollection.

21 Q

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

23 A

I have no recollection either way.

(y 24 Q

Do you see the word written in handwriting

\\_. ]

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

l L

1 Zechmen 218 2

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

A What is your page 17 Are you talking 4

about the cover sheet?

5 Q

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

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

expertise.

This also means six shifts for CROs, 8

S/Fs and S/Ss."

In the left-hand margin is written a 9

word.

10 Do you see that word?

11 A

I see a word.

12 Q

can you read it?

l l

• (

13 A

Not really.

14 Q

Doesn't it say "True"?

15 MR. MacDONALD:

He just said he can't read 16 it.

l 17 A

I said it was not clear.

18 Q

Do you recognize the handwriting in that 19 marginal notation?

r 20 A

No, I don't.

21 Q

It's not your handwriting?

22 A

It's not my handwriting.

23 Q

Is that Mr. O'Hanlon's writing?

(

24 A

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

1 Zechman 219

(~)x

(_

2 THE WITNESS:

Can we take a break, 3

please?

4 MR. FISKE:

Sure.

lh 5

(Recess taken.)

6 MR. FISKE:

Could you read the last quastion 7

and answer.

8 (Record read back.)

9 BY MR. FISKE:

10 Q

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

,e m

(_)

13 questions on it.

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

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

22 Do you see that paragraph?

23 A

I see that paragraph.

(~N, 24 Q

Was there a procedure at Met Ed during

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

1 Zechman 220 Q

\\s/

2 that you were in charge of the training department 3

to document the amount of time that was spent on 4

training?

llh 5

A There was an administrative document in t

6 which we recorded the hours of training and the 7

personnel in attendance.

g-Q For this period, this program that y

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

13 THE WITNESS:

Read that back.

14 (Record read back.)

15 A

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

17 Q

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

20 A

Yes, it would.

21 Q

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

23 A

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

25 Q

Did you understand that the Nuclear

1 Zechman 221 2

Regulatory Commission had regulatory authority over 3

the training that was being conducted at Met Ed?

4 A

Would you like to expand upon that, please.

h 5

g What is unclear about it?

6 A

Your interpretation of regulatory authority 7

over the training program.

8 Q

Did you understand that in order for Met 9

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

12 A

I understood that.

D'\\

i

(,/

13 Q

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

16 A

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

10 Q

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

20 A

Yes, it does.

21 Q

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

25 in fact, being conducted?

1 Zechman 222 2

A I

understood that.

3 Q

Did you understand that it would be 4

wrong to create documents which showed the training llh 5

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

heen done?

7

'A I understood that.

8 Q

Directing your attention to the last 9

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

12 Do you see that?

13 A

I see that.

4 14 Q

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

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

l 10 l

MR. MacDONALD:

I object to that.

19 A

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

I 21 Q

Well, was it important go ahead.

l 22 A

When I read this document, including that

(

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

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

l

l 1

Zechman 223 I

)

Y/

2 Q

Well, wh'en you read this sentence in i

which he said "Many times more hours were documented 3

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

understand what he meant by that sentence?

6 MR. MacDONALD:

He just told you what his 7

understanding was.

8 MR. FISKE:

No, he didn't.

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

11 MR. FISKE:

I want an answer to that 12 question.

(~N

()

13 MR. MacDONALD:

I think the witness 14 MR. FISKE:

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

16 MR. MacDONALD:

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

18 l A

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

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

22 very rational about what he was saying.

23 Q

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

N.N]

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

Isn't

1 Zechman 224 O\\

2 that right?

3 Do you want your last answer read back?

4 A

No.

I 5

Q Your last answer just said you felt that 6

he was not being rational in what he was saying.

7 A

In many of the things he was saying, he 8

was not being rational.

9 Q

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

13 MR. MacDONALD:

Understand what he said 14 in the paper?

15 Q

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

17 MR. MacDONALD:

He told you what his 18 understanding was.

19 MR. FISKE:

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

21 (Record read back.)

22 MR. MacDONALD:

I am going to object.

23 Q

You may answer.

24 A

He was saying things that were not u

25 substantiated by fact.

1 Zechman 225 CN i

2 Q

Did you personally conduct an v

3 investigation to determine whether more hours were 4

being documented than were actually used for llh 5

training?

6 A

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

indeed the period of time with which this was 8

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

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

That would not have been in my charge.

11 Q

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

(~)J 13 A

Not to the best of my recollection.

L 14 Q

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

16 A

Not to the best of my recollection.

17 Q

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

21 THE WITNESS:

Repeat that question.

22 (Record read back.)

23 A

Not to the best of my recollection.

I 24 Q

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

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

1 Zechman 226 O

2 conducted an investigation to determine whether more 3

hours were being documented than were actually used 4

for training?

5 MR. MacDONALD:

What do you mean?

6 A full-scale investigation?

7 MR. FISKE:

I will let the question stand.

O Mr. MacDONALD:

Fine.

I object.

9 A

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

11 Q

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

17 MR. MacDONALD:

He just told you the answer 18 to the question.

He didn't recall.

19 A

I said I don't recall.

20 Q

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

22 A

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

i 24 MR. MacDONALD:

He gave it to you.

I 25 l

A I said he gave no specifics in his document.

I

1 Zechman 227 O-

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

3 Q

You did nothing to follow it up and you 4

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

5 correct?

6 MR. MacDONALD:

I object.

That is not 7

what he said.

8 A

That is not what I said.

I said at 9

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

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

)

13 Q

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

15 A

I already answered that.

16 Q

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

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

19 A

I said I was uncertain about that.

20 Q

Does Met Ed promote irrational people?

21 MR. MacDONALD:

Objection.

There is no 22 basis for that question.

23 MR. F IS KE :

He can answer it?

24 MR. MacDONALD:

I will instruct him

~

25 not to answer.

He is not necessarily involved

1 Zechman 228 k>

2 in whether Book is involved in a promotion, 3

whether he should or shouldn't have gotten 4

a promotion.

llh 5

If you want to ask about his recollection 6

about people that worked for him who were 7

promoted, that is fine.

8 Q

Are you familiar with the criteria for 9

promotion at Met Ed?

10 MR. MacDONALD:

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

12 MR. FISKE:

Yes, within the training (O

'x_/'

13 department.

14 A

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

16 Q

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

20 A

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

I l

23 MR. FISKE:

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

sj 25 dated September 17, 1979 from Mr.

Zechman to 1

1 Zechman 229 2

Mr.

L.

L.

Lawyer.

3

(, Memorandum dated September 17, 1979 4

from Mr. Zechman to Mr.

L.

L.

Lawyer, marked h

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

of this date.)

7 Q

I will show it to you and give you an 8

opportunity to read it.

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

13 MR. MacDONALD:

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

i 17 Q

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

all right, too.

I l

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

g A

Yes.

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

20 Q

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

25 A

It is.

1 zechman 230 i

/

2 Q

I would like to direct your attention to 3

the second paragraph,.the second sentence, which 4

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

only way to have an effective training program" sorry.

6 "It has always been my contention that 7

the only way an effective training program can be 8

carried out is to have the sufficient staff and the 9

necessary time to prepare the material."

10 Do you see that?

11 A

I see that.

12 Q

That is a sentence that you wrote,

()

13 is that correct?

14 A

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

16 Q

And the word " effective" is underlined.

17 Did you underline it?

18 A

I did.

19 Q

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

23 A

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

i l

1 zechman 231 2

ones, fo r example, like radiation protection personnel 3

training for the people.who were coming in.

4 Since a number of these programs was llh 5

increasing, I was making it clear that additional 6

staff would be needed to do this.

I 7

l Q

I am really not at the moment going to 8

ask a lot of questions about the details of the 9

September 1979 training program.

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

()

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

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

17 MR. MacDONALD:

He told you his 18 understanding.

19 Q

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

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

24 THE WITNESS:

Repeat that.

g-25 (Record read back.1

1 zechman 232 (l

\\'v' 2

MR. MacDONALD:

Effective in the way he 3

used it in the memo and just explained it 4

as to the new program?

h 5

MR. FISKE:

Come cin, Mr. MacDonald.

6 A

His point is well taken, sir.

7 This letter was written at a point in 8

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

and so was the staff.

10 Q

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

k._,,)

13 enough people to do it right?

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

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

17 enough people.

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

20 A

No.

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

g 22 l

Q We will get to that in a minute.

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

(^\\;

(,/

25 an effective training program can be carried out is

1 Zechman 233 C)

( /

2 to have the sufficient staff and the necessary time 3

to prepare the material"?

Is that corrects that is 4

what the sentence says, is it not?

h 5

MR. MacDONALD:

The document says what 6

it says.

We don't need the witness to confirm 7

the written words.

8 A

What I wrote is what I wrote.

9 Q

Have I read it incorrectly?

10 A

You have not read it incorrectly.

11 Q

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

[

}

13 1977 he expressed the view that in order to get

\\,/

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

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

19 MR. MacDONALD:

What is the question.

20 (Record read back.)

21 MR. MacDONALD:

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

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

-\\ -

25 what is written on a page here?

I don't think

1 Zechman 234

(

/

\\/

2 it says that.

3 Q

You understand that Mr. Book was telling 4

you that he felt there should be more training lll 5

people in the training department?

6 A

What is said in the letter is what is 7

said in the letter.

8 Q

I am asking you what you understood it 9

to mean at that time.

10 A

What it says in the letter.

11 Q

What is that?

12 A

His opinion.

/

!s_)

13 Q

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

15 A

Whatever he said.

16 Q

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

10 MR. MacDONALD:

What he recalls his 19 understanding was at the time.

20 MR. FISKE:

Right.

21 A

I understood that is what he was saying.

22 Q

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

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

\\_/

25 A

Yes.

1 Zechman 235 2

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

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

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

Marsh Beers, Frank McCormick."

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

Bob Long, Rob Williams."

8 Do you see the first sentence in the 9

memorandum of that interview, Mr. Zechman?

10 A

Ending " Training department staff"?

11 Q

Yes.

12 A

I see that first sentence.

(

13 Q

could you read that into the record, 14 please?

l l

15 A

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

l 17 know what that is.

18 Q

"MGRS."

19 A

I don't know.

l l

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

" staff."

23 Q

Isn't ita fact that at that interview I

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

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

(

T v---

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

y w

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=c-m.*-v-

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

1 Zechman 236 O( >

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

record?

4 A

It is true that we discussed the size lll 5

of the staff and requesting additional staff, but 6

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

that is not expressed here.

8 Q

You mean you have a specific recollection 9

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

11 MR. MacDONALD:

I object.

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

He said they

(

13 discussed the subject matter.

Not that anybody 14 stated that that was so.

15 A

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

18 Q

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

21 had more people in the training department?

O 22 THE WITNESS:

Read that back, please.

23 l

(Record read back.)

l

[]

24 MR. MacDONALD:

I object.

I don't think l

'\\ J 25 that is what he testified.

l

1 Zechman 237

(^%

i

/

2 MR. FISKE:

I am asking him.

3 A

I have expressed that view in the past.

4 I said my view was that our training lh 5

department has worked very hard.

We had to work 6

overtime hours at times.

It would have been helpful 7

to have additional persons so that we did not have 8

to work additional hours and as hard as we did.

9 Q

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

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

(_

13 of almost all training programs?

14 MR. MacDONALD:

Are you reading from some l

15 particular line on the page?

j 16 MR. FISKE:

Sure.

17 MR. MacDONALD:

Point the witness to it.

18 MR. FISKE:

Sure.

Page if that helps 19 him.

20 MR. MacDONALD:

I don ' t know if it helps 21 him.

22 MR. FISKE:

Page 2.

Notes of the Keaten 23 interview.

"If the training staff had been f~}

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

v.-

t f

25 would have expanded the scope of almost all i

I

1 Zechman 238 rN k_-)

2 training programs."

3 Q

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

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

lg 5

A I can only speak for myself.

I don't 6

recall making that statement.

7 Q

The notes further say, "This specifically 0

was directed towards increased and improved 0

classroom training for the various training programs. "

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

12 A

I don't recognize that statement or

/~'x 1

(

)

recollect that statement or having made that statement.

14 Q

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

IO A

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

l 19 Q

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

21 A

I don't recall what they said, period.

22 Q

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

04

~

,e-'S, A

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

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

I know I

1 Zechman 239

/

)

'% )

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

3 g

now long were you out of the room?

4 A

I have no recollection.

h 5.

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

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

in to you?

O A

I don't recollect what it was.

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

12 Q

Who was the telephone conversation with?

/m.

(.,)

13

~

A I don't recall.

14 Q

How long was this interview?

15 A

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

17 Q

How long were you out?

0 A

I have no recollection of that time 19 period either.

20 Q

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

24

{]

Do you see that?

's 25 A

No, sir.

1 Zechman 240 2

Where are you at?

3 Q

Immediately following the sentence that 4

says, "This specifically was directed toward lll 5

increased and improved classroom training for the 6

various training programs."

7 The next sentence is, "This content 8

has been eroding down through the years."

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

11 A

Sir, I don't recognize the content I

12 don't recognize or can put into context that

()

13 sentence from any conversations that I had there.

14 g

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

16 A

I don't recall making that statement.

l 17 Q

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

l 19 A

Sir, I answered a while ago.

I don't l

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

S 22 g

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

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

i I

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

l

~s!

l 25 A

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

l

1 Zechman 241 s

2

~

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

what they -- what specifically came out from them.

4 I just can't.

I

• 5 Q

Directing your attention to the sentence, 6

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

was stripped out of the program (especially 8

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

crossed out

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

l

)

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

15 A

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

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

18 and changes that took place relative to them.

19 Q

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

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

1 Zochman 242

()

2 MR. MacDONALD:

He just answered the 3

question a minute ago.

4 A

I answered the question to the best I know ll 5

how.

I told you I didn't recognize the framework 6

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

recollection of how I expressed myself at that time.

8 Q

Did you say to Mr. Keaten in words or 9

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

13 MR. MacDONALD:

Objection.

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

15 Q

You may answer.

16 A

I believe I just answered that question, i

17 sir.

18 Q

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

20 A

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

9 22 Q

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

24 A

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

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

- - ' ' - ' =

~ ~ - - ' ' '

1 Zechman 243 2

meeting.

3 Q

Do you know any reason why the person who 4

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

elimination of formal classroom training in the basics 7

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

Mr. McCormick?

9 MR. MacDONALD:

Objection.

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

14 You are asking him to speculate.

15 MR. FIS KE :

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

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

i 21 had said it.

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

23 MR. MacDONALD:

It is a present-sense i

24 impression.

s' 25 A

For all I know, he could have written it L

1 Zechman 244 O

2 some time after the meeting.

It would be pure 3

speculation on my pa'rt.

I don't know.

4 MR. MacDONALD:

Is this a good time h

5 to break for lunch?

6 MR. FISKE:

Sure.

4 7

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

a 8

lunch recess was taken.)

9 10 11 12 13 14 15 16 3

f 17 l

18 l

19 20 i

21 22 23

' O 25

1 245 t(,)

2 AFTERNOON SESSION 3

(2 : 3 0 p.m. )

4 R I CHARD W.

ZECHMAN, resumed.

lll 5

MR. FISKE:

Could we have the last question 6

and answer.

7 (Record read back.}

8 MR. FIS KE :

I would like to mark as the 9

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

12 (Memorandum to Mr. Zechman dated f;

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

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

16 EXAMINATION (Continued) 17 BY MR. FISKE:

18 Q

Are you reading that memorandum, 19 Mr. Zechman?

20 A

Yes, I am.

I have not read it entirely.

21 Q

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

Yes, I did.

V 25 Q

Had you received that memorandum by the

1 Zechman 246-247

'N

)

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

September 17, 1979 which was marked as the previous 4

B&W exhibit?

gg) 5 A

Yes, I did.

6 Q

Referring to again your memorandum of 7

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

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

that in front of you?

10 A

Yes.

11 Q

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

(~')

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

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

15

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

Some evidence of l

I 19 carelessness appeared during the review and this j

20 is often the sign of overworked conditions.'"

l l

21 Do you remember writing that sentence?

22 A

Yes, I do.

l 23 Q

Did you underline " understaffed and I

24 l overworked"?

O I

s

25 A

I underlined that.

I

1 Zachman 248 2

Q The reference to Frank Kelly's audit 3

report, is that to the PSQ?

4 A

PQS.

lll 5

Q The report that you identified earlier 6

in your testimony?

7 A

Yes.

8 Q

And that was a review as your memorandum 9

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

11 A

To the best of my recollection.

12 MR. FIS KE :

Let me mark as the next

/

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

14 Pedagogical Review of Operator Training" 15 withdrawn.

16 It was marked as B&W 234.

17 Start again.

t l

18 Q

I will show you a document which has i

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

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

O 22 Do you have that in front of you?

23 A

Yes.

l 24 Q

Do you recognize this as the final O

25 report of the college of Engineering from Pennsylvania

~

1 Zachman 249 2

State that you referred to earlier?

3 A

I recognize this as the document --

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

5 review of operator training at Three Mile Island.

6 I have no recollection at this time if 7

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

O Q

But in any event, you recall that Met Ed 9

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

11 A

I recall they received a report of that 12 title.

13 Q

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

16 A

We discussed some things about it.

I 17 Q

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

21 MR. MacDONALD:

Are you asking whether 9

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

24 MR. FISKE:

Yes.

O.

25 A

If that is your question, the answer is

1 zochman 250

/'N 2

yes.

3 Q

Did you receive a draft of this report at 4

some point before it b e came final?

ll) 5 MR. MacDONALD:

I object.

I don't know 6

whether Mr. zechman established that as a final 7

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

final report.

9 Your question assumes it is.

10 Q

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

,(

14 A

To the best of my recollection, we did.

15 MR. FISKE:

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

10

Thorpe, subject:

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

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

Thorpe, subject:

23 "Penn State Committee - Initial Draft Report,"

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

l l

1 Zechman 251 2

this date.)

3 Q

Do you recognize that?

4 A

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

6 Whether this is the one I reviewed at 7

that time, I have no recollection.

O Q

Looking at Mr.

Lawyer's cover memorandum, 9

that is directed to Mr.

J.

Tho rp e, is it not?

10 A

Yes, it is.

11 Q

Who is Mr. Thrope?

12 MR. MacDONALD:

At what time?

(}

13 MR.

FIS KE :

At that time.

14 A

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

16 Q

He was with GPU nuclear?

i 17 A

To the bes t of my recollection.

I0 Q

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

20 A

Yes.

21 Q

Mr. Keaten we have talked about before.

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

24 A

To the best of my recollection, he worked O

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

1 Zschman 252

()

2 Mr. Keaten.

3 Q

Who was D.

E.

Hetrick?

4 What was his position at that time?

ggg.

5 A

I don't recall his title.

6 Q

Mr.

R.

W.

Zechman, what was your position 7

at that time?

8 A

Supervisor of training.

9 Q

A.

M.

Dowbert?

10 A

Anne Dowbert.

I believe she was 11 administrative assistant.

I forget what her title 12 was.

13 Q

Who was O.

Smith?

14 A

NUS contractor working in our department i

15 at the time.

16 Q

Who was G.

A.

Sullivan?

i 17 A

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

I forget what company he 19 was from.

20 Q

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

22 me with comments on the attached document.

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

O 25 You were a ce recipient of the attachment

1 Zochman 253

(

'2 to Mr. Lawyer's memorandum?

3 A

According to the cover letter I was, yes.

4 Q

Did you understand from this memorandum, lll 5

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

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

to make whatever comments you wanted to make on the 8

draft that they had prepared and that they would take 9

those comments into account in preparing their final 10 report?

11 MR. MacDONALD:

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

14 MR. FIS KE :

I think he said he did.

15 MR. MacDONALD:

Your question assumes it.

16 MR. FISKE:

Read the question again.

17 (Record read back.)

18 MR. MacDONALD:

My objection stands.

I 19 Q

You may answer.

i 20 A

It was my understanding that comments 21 were invited.

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

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

[~'\\

l

\\/

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

E 1

Zechman 254 2

Q Did you understand that the people at 3

Penn State were going to listen to your comments, 4

consider your comments in determining what final lll 5

conclusions they were going to reach in the final 6

report?

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

you thought they were going to accept them all or 9

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

13 A

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

II Q

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

22 programs" 23 Do you see that sentence?

1 24 A

Yes, I do.

25 Q

I would like to then direct your i

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

1 Zechman 255 (3

2

(_)

attention to the next page, paragraph C.

3 MR. MacDONALD:

Mr. Zechman, read A and 4

B first.

ggg 5

Q Have you read that?

6 A

Yes.

7 Q

The second sentence says, "For example, 8

most of the present CRO training programs (500" 9

A Where are you at?

10 Q

Paragraph C.

11 A

I'm sorry.

I didn't read C yet.

My l~a apologies.

()

Now I'm ready.

13 14 Q

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

17 Do you see that?

10 A

I see that statement.

19 Q

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

21 I will withdraw that question and see if G

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

23 I will put the question again.

I 24 I will read the whole paragraph to you.

25 "A large portion of the training is accomplished e

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Zechman 256

,;()

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

3 For example, most of the present CRO training

(_500 4

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

self-study on the job.

Such a technique is 6.

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

p ro c edures, system design descriptions and system 8

schematics.

It's completely inadequate for reactor 9

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

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

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

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

17 A

I recall making comments to Penn State on i

18 this report.

At this time I have no recollection i

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

i 20 MR. FISKE:

I will mark as the next f

21 exhibit, which is

568, a document entitled 22

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

Zechman, supervisor of training.

O 25 (Doc umen t entitled " Comments Penn

1 Zechman 257 2

State Review Committee Report,"

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

Richard W.

Zechman, supervisor of training, 5

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

as of this date.)

7 Q

Have you had a chance to look at this 8

three-page document, Mr. Zechman?

9 MR. MacDONALD:

I don't think he is 10 finished.

11 Q

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

()

13 A

It' doesn ' t balance, sir.

That is why 14 I am looking.

15 MR. MacDONALD:

Give him a few moments, 16 if you will.

17 MR. FISKE:

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

19 MR. MacDONALD:

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

Please give him that 21 opportunity.

9 22 MR. FISKE:

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

O 25 MR. MacDONALD:

That is fine.

l

1 Zechman 258

)

2 Q

You had had an opportunity to look at 3

B&W Exhibit 568, is that correct?

t 4

You have just had an opportunity to g

5 review that?

6 A

I was reviewing -- well, yes.

I scanned 7

this one and tried to match it against 567.

8 Q

Let's take Exhibit 568 and turning to 9

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

" Richard W.

Zechman"?

11 A

That is my signature.

12 Q

And you were a supervisor of training i

i 13 on February 6, 1980?

14 A

That is correct.

15 Q

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

17 A

That is correct.

18 Q

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

'80?

20 A

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

G 22 Q

Is he the same as the O.

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

24 A

That is correct.

O 25 Q

I would like to direct your attention

1 Zechman 259 2

to page 2 of Exhibit 568, item 7.

3 Do you see that?

4 A

I see item 7.

ll) 5 Q

It reads, "PSU.

Comment

'C' and

'D',

6 page 6."

7 Do you see that?

8 A

I see that.

9 Q

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

11 A

There is one word.

12 Q

What is that one word?

()

13 A

" Agree."

14 Q

Mr. Zechman, I would like you to look at

)

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

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

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

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

(~)%

that training in basics was lacking."

\\.

25 Do you see that?

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1 Zachman 260

(~}

2 Did you say to Mr. Keaten at the meeting

%.J 3

in words or substance that the training department 4

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

supervisors that training in the basics was lacking?

6 A

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

recall making that statement.

8 Q

You don't recall saying anything then to 9

Mr. Keaten?

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

I L./

14 in the basics was lacking?

15 A

Not to the best of my recollection.

16 Q

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

18 A

I think I already testified that I don't l

19 recall their statements at that meeting.

l l

20 Q

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

23 based on assumption that Navy nukes would have a l

24 basic background"?

(~h

(/

25 A

I see that.

1

1 Zachman 261 2

Q Did you say anything like that?

3 A

Not to the best of my recollection.

4 Q

Did Mr. McCormick or Mr. Beers?

5 A

I have no recollection what Mr. Beers ggg 6

or Mr. McCormick said at that meeting.

7 Q

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

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

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

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

12 It reads, "A review of the topics covered

(~%

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

(

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

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

19

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

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

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

25 programs."

1 zochman 262 i

t V(~T 2

Do you see that paragraph?

3 A

I see it.

4 Q

Did you agree with the statement, gg 5

Mr. zachman, to understand the technical basis 6

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

must be familiar with not only reactor theory but 8

also heat transfer and fluid flow?

Y 9

A That was a long statement.

10 THE WITNESS:

Could I have that read 11 back, please?

12 (Record read back.1 13 Q

I will phrase it a different way.

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

19 MR.

MacDONALD:

Express it to whom?

20 MR. FISKE:

To anybody.

21 THE WITNESS:

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

23 (Record read back.)

1 24 i

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

E

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1 zochnen 263 2

in writing, relative to that relative to what 3

you just asked.

4 Q

Wouldn't it be a pretty acceptable ggg 5

proposition for someone involved in training nuclear 6

operators that in order to understand the technical 7

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

an operator should be familiar with not only the 9

reactor theory, but heat transfer and fluid flow?

10 A

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

14 Q

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

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

21 MR. MacDONALD:

His recollection at the G

22 time he read it?

23 MR. FIS KE :

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

25 A

I would agree that one would have to be l

1 zochman 264 j

)

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

reactor operator needs to know, the system dynamics 4

and expected responses as taught by the vendor who ggg 5

designed that reactor.

6 Q

I am perfectly willing to let that 7

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

asking you.

9 MR. MacDONALD:

You can let any answer 10 you want stand.

11 Q

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

18 A

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

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

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

24 Q

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

-r--

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

ry--,. _

m m

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

(

3 described?

4 MR. MacDONALD:

His answer is what it g

5 was.

6 MR. FISKE:

I don't believe it's responsive 7

to the question.

8 MR. MacDONALD:

Whatever your thought, 9

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

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

13 MR. FISKE:

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

15 Q

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

19 MR. MacDONALD:

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

It has nothing to do with what O

22 he understood.

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

24 MR. FISKE:

Maybe the need for the break O

25 continued on to the next question.

1 Zochnan 266

(

2 MR. MacDONALD:

He asked for the break 3

five minutes ago.

4 MR. FISKE:

I don't think there is any ggg 5

dispute.

6 A

I think I answered your question.

7 Q

You have not.

I will ask it again.

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

all right with me.

10 A

Let's finish the question first.

11 Q

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

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

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

20 A

Not exactly, sir, i

21 Q

Whether I state it' correctly or not' I O

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

1 zochaon 267

(

2 reactor plant."

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

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

that basic proposition.

6 MR. MacDONALD:

He answered your question.

7 Do you want to ask it again?

I 8

A I stand firm in the way I answered that 9

question just previously, sir.

10 Q

The last sentence of this paragraph --

11 A

May I have a break, please?

12 Q

Sure.

I thought we were going to finish 13 the paragraph.

14 MR. MacDONALD:

I thought it was a 15 question.

16 MR. FISKE:

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

18 THE WITNESS:

Go ahead.

19 Q

The last sentence of the paragraph says, i

20 "Accordingly, sections covering this material should l

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

9 22 A

I see that.

23 Q

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

on page 6 and ask you if I am correct

1 zochman 268 2

that your written comment with respect to that 3

entire paragraph was " Agree that heat transfer and 4

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

lll-5 MR. MacDONALD:

I object.

You have built 6

in an assumption.

7 MR. FISKE:

Read the question again.

8 LRecord read back.)

9 Q

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

()

13 A

Sir --

14 Q

What is the answer?

15 A

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

They don't match, sir.

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

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

20 Q

We can go through that some more after I

21 the break.

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

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

l 24 A

Can we do that after the break, sir?

O 25 Q

Sure.

i i

1 Zechman 269

()

2 (Recess taken.)

3 MR. FISKE:

I think the record should 4

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

hour, and now Mr. MacDonald wants to put 6

something on the record.

7 MR. MacDONALD:

I am just saying that 8

the witness is finished for the day, he informs 9

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

11 I apologize.

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

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

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

17 MR. FISKE:

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

19 MR. MacDONALD:

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

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

G 22 MR. FISKE:

We will resume at 9:30 23 tomorrow morning.

24 MR. MacDONALD:

If we can resume at

~

\\-

25 (continued on next page.)

i 1

zochann 270 1

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

3 (Time noted:

3:55 p.m)

{

4 RICHARD W.

ZECHMAN

(

I 6

subscribed and sworn to before me this day 7

1 g

of

1982, i

9 t

10 11

~

12 I

13 4

i

)

14 e

15 16 I

17

+

18 s

f-19

'!. v

'[

20 21 9

22

s 24 25 I

s.

1 271 I

CERTIFICATE b

STATE OF NEW YORK

)

3y

ss.:

l COUNTY OF NEW YORK

)

4 i

I, ROBERT CAPUZELo

, a Notary l

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

6 i

certify that the continued deposition of I

l RICHARD w. ZECHMAN 8

was taken before 1

me on March 11: 1982 consisting of pages 157 through_

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

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

of the counsel.

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

day of

/ i u a in

, 1982 20 li i

g l

21 nn l

~

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

ROBERT CAPUZELO '

C 24,l 25 i

i f

272

\\'~

INDEX WITNESS PAGE Richard W.

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

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

L.

Lawyer 564 Copy of a memorandum from 199 James P.

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

L.

L.

Lawyer l

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

l McCormick and Mr. Beers I

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

Thorpe, subject:

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

256 l

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

(

)

Smith from Richard W.

Zechman, supervisor of training.

e e

i