ML19309C718

Motion to Compel Responses by Licensee to Fourth Set of Interrogatories & Document Requests.Licensee 800311 Objections Attempt to Carve Out Scope of Restart Contentions.Certificate of Svc Encl

ML19309C718
Person / Time
Site:	Three Mile Island
Issue date:	03/19/1980
From:	Sholly S AFFILIATION NOT ASSIGNED
To:	Atomic Safety and Licensing Board Panel
References
NUDOCS 8004090189
Download: ML19309C718 (17)

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INTERVENOR STEVEN C. SHOLLY "0 TICS TO COMPEL X:S'4EP BY LICENSEE C TO I" TERR 0GATCRIES Sy respon.se dated 1/11/80, received 3/15/80, entitled " Licensee's Cbjections to Sho117 Fourth Set of Interrogatories and Docur.ent Requests to Licensee," Licensee objects to forty-four interrogatories filed by this Intervenor on 2/25/80. The objections fall generally into the category of " scope." This is a tired and well-worn topic, a topic which this Intervenor feels the Board has spoken eloquently upon on numerous occasions. Licensce's views of the scope of the proceeding and the scope of many contentions have been nearly completely repudiated at every turn.

Nonetheless, Licensee persists in twisting the intent of contentions to serve its own narrow mission, attempting to restrict the scope of contentions in this proceeding to the point where certain contentions would be stripped of all substance.

It is past time for the Licensee to cease exercising the function of interpreting contentions and their scope. The Board is charged with this responsibility, not the Licensee. Yet, Licensee persists in attempting to carve out a scope of contentions which f avors its own viewpoint. This necessitates a censiderable effort and expenditure of time on the part of unfunded Intervenors to obtain responsive answers to interrogatories and 8004090 / N

uoeument requests. Because Lic eas ec ;arsists ia cujce cla; 2n the ::anneat of S2cnnte11" grcunds to substantial numbers of interracacorice. .;a Intervenor is lef t eith no altern:i;tve but to move the Board ca ;carel Licensee to respond.

Pursuant to 10 CFR 2.740(f) . Intervenor Sho11y moves the Board compel Licensee to answer the following interrogatories and document. requests from the Fourth Set for the reasons explained herein:

16-008,16-009, 16-010,16-011, 16-012,16-013, 16-014,16-015, 15-006,15-009, 15-010,15-024, 15-025,15-026, 15-027,15-029, 15-030,15-031, 15-032,15-033, 15-034,15-036, 15-037,15-038, 15-041,15-042, 15-044,15-049, L5-053,15-061, 15-002,15-063, 15-064,15-065, 15-066,13-067, 15-063,15-069, 15-070,15-071, 15-072,15-073, 15-074, and 15-075.

SECURIIT CONTENTION INTERRCGATORIES (Contention 16)

There is a consistent pattern developing with regard to Licensee's respense to nearly all interrogatories on this contention. Licensee objects continuously on the basis of scope. The interrogatories in the Fourth Set n Contention 16 are primarily aimed at discovering what steps Licensee has taken to ensure that its Site Security force is capable of preventing a sabotage attempt at Unit 2 (by insiders) from impacting on the safe operation at Unit 1.

It is not necessary at this point in the proceeding for this Intervenor to prove that sabotage events at Unit 2 can impact on the safe operation l

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cf Unit 1, al: hough this Intervener ocvicusly holds this to be crue or che contantica Md : ru no casts. Evidence will be presented on this isste

! lurin; :5e ?r:22eding. I: i; :nly necessary that intarroga:ories be posed zehich alcher deal lir actl" tith the subs:ance of the contention, or, and this la an in.partant gE. which can be reasonably expected to lead to i

i-discoverable information.

It is clear to this Intervenor, and presumably to numerous other ,

groups and agencies, including NRC, that conditions at TMI as a whole are i

1 clearly not " normal", especially at the damaged Unit 2 reactor. The presence i i of far more numbers of employees, including contractor employees, and the 3 presence of the damaged reactor take this plant out of the normal category.

Special precautions, ar, at the very least, special awareness of the situation which exists is necessary to adequately protect the public health and safety.

J' and the safe operation of Unit 1.

The primary crganization at TMI for dealing with internal sabotage t

i. events is the Site Security organization. It is therefore quite reasonable '

that the capabilities of the Site Security Force, the training received by members of that force, and Licensees rules, procedures, and practices as

, they pertain to site security should all come under scrutiny in the course i

of litigating this contention. Licensee obviously seeks to avoid such a-i scrutiny; in the view of past events dealing with site security at' TMI,

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such a stance is understandible. There exists a continuing history of l j security problems at TMI, not the least of which is the recet.t incident in ,

I Lwhich a reporter from a local weekly newspaper posed, under f sise identification, asf an applicant for a security force position, Land was subsequently hired

• and worked. forfa period of time at TMI-2. This was permitted, quite obviously,.

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eithcut a sufficient backcraund check. ehich uculc hava ratner easilc:

rc ac the uncomplicated method used by the re,crter te u' -t, identificatter.

The public inter 2;t, c. ;weve r , la far bettar served by a the-  ;. airing af th e sccurit: situation at T'!! so that there is m urance that Se purlic safety and health wtll be adequately protected. As Chairman Richard S.

Salzman, of the Appeala Board in the Matter of Diablo Can; ion (3 :;RC 139d.

1977) stated,

". . . I an unable to credit the suggestion that these determined to injure nuclear power plants will be significantly aided in their purposes by the limited types of disclosure contemplated, or much hindered in their purposes if that disclosure is proscribed. The roccs of industrial sabotage will hardly wither if we withdraw such plans from public scrutiny; rather, it is the public safety that is more likely to suffer if we do so."

The public interest demands a full exploration, within the constraints of this proceeding, of the internal security situation at TMI in order to determine whether or not Licensee has taken suf ficient precautions to ensure that internal sabotage will not impact on the safe operation of TMI-1. Contention 16, as admitted by the Board subject to further specification, is the sole vehicle for so doing. If Licensee persists in refusing to answer the most elementary interrogatories about the TMI security plan and organization, such a full airing of the f acts will be impossible.

Licensee has objected to each of the interrogatories on Centention 16 in the Fourth Set of interrogatories and document requests on the basis of lack of scope; i.e., "Such information is not at issue or subject to discovery in this proceeding." Other than a capsule summary of each of the interrogatories, this is the sole substantive objection to each interrogatory on Contention 16. Licensee fails to discuss why each request

5 is ebjecticeable. ether then :o nake a blanket condemnation on the basis

.i ;c;7s.  :: a :h :. : :2r ar.or's positicn that each of the interregatories is closely related to cae issues raised by Contencien 10 and should therefore ,

be respcoded ca in substantive rcra by the Licensee. Theraf e re , this I

Intervenor has mos ad the Board to compel Licensee to respond to each of -

1 the Contention 16 interrocatories listed en page 2 of this filing. Each-of the interrogatories is reproduced in full in the attachmen.t to this i document. An F rief e::planation of the specific relevance of each of the 1

Contention 16 interrogatories follows:

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Interrocatory 16-008  :

l This interrogatory requests Licensee to provide certain information

! related to hardware and procedures used to prevent, detect, and/or mitigate r

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internal sabotage. Each of these areas of information are taken from

, pages 1409-1410 from ALAB-410 (5 NRC 1398,1977) . wherein the majority of the Appeals Board suggest a list of types of information from a nuclear ,

i power plant security plan which, in their opinion, would be suitable for l

release, under a protective order, to an intervenor raising a security i

t contention in a proceeding.  ;

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The information requested is specific to internal security, with the "g",

exception of items "h", and "1" which are more general in nature, but which are central to a review of Licensee's security plan and procedures and their sufficiency with regards to dealing effectively with internal .

security problems. - Intervenor here notes that such requests are necessary in part becausel Licensee has failed to pose interrogatories which would

serve to focus this Contention, as was suggested by. the Board's conditional e 4--- ,- ,.,,---3-.a.,--.- ,&i.wm- - , -,,...+v- te ,ww-, - - - a ~-i,+w -- ---y+ -w-- -- - v-e-- ~

approval of the contenticn. Sa:her. Licensee has sci:unt indirectly by Y;jecting to interro;:atories rosed bf this Interverrr ta li-it the inform tien aecilacle upon :Sica :: base a scre focuaca :.1:;ntica hich sot ld be suitable for litigation. 0"vicusly, Lic.nsee~nas no desire to '.itigaqe this contention in any form in this proceeding. It is my firm intention to Litigate the issue of internal security in the context of this proceeding. In doing so, this Intervenor will of necessity require responses to interrogatories on this contention. The Board is urged to compel Licensee to answer these interrogatories.

Interroaatory 16-009, niis interrogatorf requests Licensee to identify persons who have left the security force since the accident, for whatever reason. The purpose in receiving a listing of such persons would be to contact them for the purposes of arranging depositions or retaining them as witnesses, or, as a last resort, requestn.g the Board to issue a subpoena to appear at the hearings on Contention 16. Licensee has supplied similar information on other groups of employees, and there is no reason why Licensee should not be required to supply this listing which is requested in Interrogatory 15-009.

Interrogatory 16-010 l This interrogatory is an attempt to gain a historical perspective on possible internal sabotage activity at TMI in order to assess the potential for future incidents. Such incidents could easily be expected to occur due to labor problems. In fact, there has already been one job action l

initiated by a contractor union (a brief strike related to the firing of

-7 s ne centr:u tar omple: ees f or violating radiolez;;2; safety practicas).

. ; - : is t beer asc ;c;ated ' ith violence, especially tr;'l er't.,'. ~ila tharc is nothing at pr2aent ta suggest t ' u *. C:ia "'i , m  ; sit . er :t n!: , it cer tainly cannot be ruled

. . i;.._r. in st. cical inf ormation relating to thsi contentien is surely subject ta discovery, and Licensee should be cor.pelled to supply the information requested.

Interrogatory 16-011 10 CFR 73.55(a) soecifically requires Licensee to establish and maintain an onsite security organization and physical protection system which will provide protection with high assurance against sabotage by un employee in any position. Surely, this includes security force employees, whether Licensee or contractor security personnel. This interrogatory socks information on how Licensee's physical protection system and security organization protect against internal sabotage by a security force member. Certainly, the security force as a source of internal sabotage represents an unusually vulnerable position, due to the intimate knowledge of security porcedures and hardware, and the capabilities and limitations of the same. There fore , this issue is especially relevant to this contention.

Interrogatory 16-012 ,

, 10 CFR 73.55(d)(1) requires that all Licensees implement physical search provisions by 11/1/80. This very simple interrogatory, which is quite relevant to preventing or mitigating internal sabotage attempts,

3 asks shen Licensee e111 impienent these prccecures. This i.ntervenor is frankly at a loss why Licensee ob ject :d--it could have t i.: = :1 less effort to type in t?_ lata and be .: ne :ith it.

Interrogatory 16-013 10 CTR 73.53(d)(7) requires that all unprotected vital areas be locked and protected by an active intrusien alarm system. This interregatory simply requests confirmation by Licensee that these provisions are in effect at TMI, and, in the event that they are not, explain why in detail. The interrogatory is clearly related to Licensee's ability to protect TMI-2 against sabotage and is therefore relevent to the contention and should be responded to in a substantive manner.

Interrogatory 16-014 This interrogatory is another attempt at obtaining historical data on security problems at TMI. As stated above, such historical data is relevent to assessing future trends, and is therefore relevent to the subject matter of the contention and should be answered.

Interrogatory 16-015 This interrogatory is based directly on security force training areas of knowledge specified in 10 CFR 73 Appendix B. Each of the requested areas of knowledge which should be covered in the Licensee's security force training program is closely related to internal security, rather than requesting confirmation that all the areas listed (some 100 separate areas).

The interrogatory is properly limited and should therefore be answered.

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HDIAM F14CTORS ENGI' EERITG INTERRCCATCRIES (Contention 15) l

is ',-o. :t f rr- Licensee 's ob jections to the interrogatories pcsed uosed ca Centantion 13 tha Licensee does not undaratand what human factors j Licensee objects I en:ine:riaa means, or the ac pe of its areas of concern.

, to cany of the Contention 15 interrogatories because they relate to I i operating procedures and practices, and to operator training. Contention i

15 calls for a " thorough human factors engineering evaluation of the Unit 1  ;

Control Room". It is becoming obvious from responses (and lack of responses)'

4 to other interrogatories that the Staff and Licensee do not share my position i

i on the need for such a review; it is therefore necessary for this Intervenor: ,

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I to establish that good reason for such an evaluation exists and that public -'

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j health and safety would be best served by having such an evaluation performed ,

t prior to restart of Unit 1. In order to make my case on this Contention,- ,

it is necessary to have pertinent information on human factors questions- t i

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related to Unit l's Control Room supplied in response to interrogatories, i By Licensee's objections, much of the necessary information would be ,

f denied to this Intervenor. Because of the relevance of the interrogatories i

dealing with operating procedures and practices, and training to the contention i i

. as admitted (as explained below), the interrogatories so related should be ,

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t l answered by Licensee, and the Board should compel those answers.

i Human factors engineering has been ably defined in NUREG/CR 1270, Volume 1, '

which is a human factors evaluation of TMI-2 performed under NRC contract. [

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by the Essex Corporation for the Special Inquiry. Group, headed by Mitchell, [

i I_ Rogovin. At pages 1 and 2 of. Volume I of NUREG/CR '1270, the following

- discussion of the scope of human factors engineering is found:

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l " Human faltera engineering is the scian2= ef 2;ci~in; 3(ravicral

prineicles te systems. It is xncerned ai;n ;ata;;ating i the human element with systen .

aruar.:. Kftwacc. r n ren-I ments, and inf o rmation . "he c revince cfBurm factors .

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in systema develocuent lies in tra general l areas: human en;ineering design and evaluatian; and human resources development. Human engineerin; inv.cives tne

research, development, test and evaluation necessary to ensure that systems hardware, software, environments,  ;

atd information are designed to support and enhance human  !

performance capability. Human ennineerinh nrovides the I design and evaluation methods and criteria to ensure that equipment, procedures, documentation. environment s. 3

, and information are designed in terms of human operator capabilities, limitations, and requirements. Human I resources development is directed at specifyine the role of people in the system as well as the number of people (manning), job entry skills and knowledge (selection),

and development of required skills and knowledge (training)."

"The overall objective of human factors engineering is to prevent 1 human error. This is largely achieved by ensuring that systems l are developed which are compatible 'with the capabilitier and limitations of personnel who operate, control, maintain, i repair, manage, or otherwise use them. The scope of human .

j engineering involves all of the interfaces between the human '

4 operator and systems hardware, software, information, procedures,  ;

environments, and other operators. The scope of human resources development involves the establishment of requirements for ,

i manning the system with fully qualified personnel in sufficient t numbers to ensure optimal human performance."  !

(emphasis added)

Human error is further defined in this document at page 11:

" Human errors result from a variety of causes including:

i the operator himself; conditions under which he is operating; design of equipment and information required for the performance of tasks; design of procedures which support the completion of task sequences; and training."

(emphasis added)

With respect to TMI-2, .and probably equally applicable to TMI-1 due to similarities in design, procedures, and training, the Essex report  ;

t at page 27 of Volume I is particularly revealing:

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'; .t e nera h eunclusions are. ( ;; era: ors di2 c c r.i t a a r caini- a; a entrt: t:~  :.  :

. . . _ . . . _ :e m a in t.x r. ants of the accicent: ana (_!

1 j rasulted frc- :rasal; inade cu ate co-. tral room new, ,n* t r a in in-2 -n e r enn frcm inherent de iciewis nn the mart et tne aperators."

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It is clear then that procedures and training are certainly central to the issue of human f actors engineering. Therefore, interrogatories

'enich request information on training and procedures are sub act to discovery under Ccatention 15, and the Board abould therefore compel f.icensee to respond to these interrogatories.

. There are many interrogatories f rom Contention 15 to which Licensee has objected solel; on the basis of scope due to the fact that the interrogatories are related to procedures and training. Due to the in-depth discussion above, this Intervenor does not feel it is necessary or purposeful to list each such interrogatory and explain its importance; rather, each interrogatory which was objected to on the basis of scope because they dealt with training or procedures is listed below. The Board is urged to compel Licensee to answer each of them in substantive form:

15-006,16-009, 15-010,15-025, 15-026,15-027, 15-028,15-030, 15-033,15-036, 15-037,15-038, 15-041,15-042, 15-044,15-049, 15-061,15-062, 15-063,15-064, 15-065,15-066, 15-067,15-068, 15-070,15-071, 15-072,15-073, 15-074,15-075.

For other interrogatories to which Licensee objected from Contention 15, these interrogatories are discussed individually below.

interrogatory 15-G_.

This interre ntory asks Licensee tc 4 ;c c i f :. eaa. in s t r u dere p r c e u .n: rc _ and instrum_::: 11; plays in tha Unit 1  :'.tr;l ?;c9 1^ 12:

describe the data in the same units of measurement. Licansee objects on the bas,is that this does not have anything to do with control roem des 12n.  :!athing could be further f rom the truth sa basic functica of control room desir;n from a human f actors engineering standpcint is to ensure that there is compatibility between procedures and display panels in terms of terminology and units of measurement. Lack of such compatibility hampers response to complex transients and accidents, and has the added tendency to introduce human error when incompatible units are misinterpreted or not properly ccmpensated tor in assessing conditions. This problem was identified as important in the Essex report (NUREG/CR-1270, Volume I) at page 11 as a f actor in the incidence of human error. It is therefore quite relevant to the question of a human factors engineering review of the Unit 1 Control Room and to control room design in general. Therefore, Licensee should be compelled to respond to this interrogatory.

Interrogatory 15-031 This interrogatory has to do with the working environment, a topic cognizable under human factors engineering. Even if Licensee views this as stretching the point, this question is also engnizable under Contention 16, and should therefore be responded to by Licensee. The Board should compel Licensee to respond.

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this i n t e r ro .;.4 t o r' does not f all witnin the scope of Contention 15. The infor atien

< ,.m :his int.:rreptery will assist in connt11ar, a listory of vrmin f actars engineering problems at Unit 1, and could suggest possible changes to be made in design and/or procedures which would eliminate some scurces of human error. Such a listing is central and crucial to this centention. The listing requested is quite centrally related to human factors engineering, and should therefore be answered by Licensee. The Board is urged to comple Licensee to respond to this interrogatory. As written, this interrogatory does not limit the request to IMI-1; that is what was intended, and Licensee need not provide such a listing for TMI-2.

Interrogatory 15-034 This Intervenor concedes that the portion of the Interrogatory which requests Licensee to discuss whether the pressurizer is safety-grade and if not, why not is not related to Contention 15. However, the remainder of the interrogatory is related to the contention and should be answered by Licensee. It is not clear whether Licensee intends to respond to the first portion of this interrogatory based on Licensee's objection. Therefore, the Board is urged to compek Licensee to respond.

l Interrogatory 15-053 .

1 l This interrogatory is not overly bread as charged by Licensee--it requests identification of only those critical operating paraneters which must be .inferrect f rom associated parameters, rather than from a direct measurement.

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Licenuaa i; sur/_7 .r. cre of these cri

icai parace:ers as a result  ;

cf :he appilcatica to IEEE 5tandard U" d4 Ling :lth irec: .:usur2 ment f of operatin:; parameters. Such a parameter which has been tridely iden:ified and discust ed is the level of water in the reacter core.

j Licensee should be compelled to respond to this interrogatory; it is j not overly broad and responding would not be burdensc e. Indeed, identificatica i

j of such parami ters would serve a very worthwhile purpose in identifying which parameters cust be inferred and then assessing which should be available directly in order to minimize the chance for human error in misinterpreting indirect measures, such as pressurizer level, which caused TF1I-2 operators to permit the core to become uncovered when they misinterpreted data which were associated with adequate core water level, but which did not

-easure this level directly.

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Interrocatory 15-069

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All of the medical and physical requirements called for in this interrogatory are related to the operators's environment and the operator / operator interface, both of which are cognizable under the domain of human factors engineering.

t 3 Licensee should therefore be compelled to respond fully to this interrogatory. .

f DATED: 19 March 1980 Respectfully submitted, r

i i ) eO J. ))Mt., .

V Steven C. Sholly ,. 7

304 South Market StreetV  ;

i Mechanicsburg, PA . 17055 i  :

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CERTIFICATE OF SER'!!CE I hereby certify that copies of Intervenor Steven C. Shell-

ation to Compel Answer by Licensee to Interrogatories dated :: arch 19, 1980, which was hand delivered to Licensee at Three Mile Island Observation Center,!!iddletown, Pennsylvania, on March 20, 1980, were served upon those persons on the attached Service List by deposit in the United States mail, postage paid, this 21st day of March, 1980.

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/ John F. Wilson Dated: March 21, 1989

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• r UNITED STATES OF AMERICA fJ NUCLEAR RECULATCRY CCMMISSION i {j-

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BEFORE THE ATCMIC SAFETY A':D LICENSING ECARD .

u 9 16-In the "atter of ) ,

1 METROPOLITAN EDISON COMPA:Y ) Docket No. 50-23?

) (:las tart; (Three Mile Island Nuclear )

Station, Unit No. 1)

SERVICE LIST Ivan W. Smith, Esquire Karin'W. Carter, Eaquire Chairman Assistant Attorney General Atomic Safety and Licensing Commonwealth of Pennsylvania Board Panel 505 Executive House U.S. Nuclear Regulatory P.O. Box 2357 I

Commission Harrisburg, Pennsylvania 17120 Washington, D.C. 20555 Robert L. Knupp, Esquire Dr. Walter H. Jordan Assistant Solicitor ,

Atomic Safety and Licensing County of Dauphin Board Panel P.O. Box P 881 West Outer Drive 407 North Front Street Oak Ridge, Tennessee 37830 Harrisburg, Pennsylvania 17108 Dr. Linda W. Little John E. Minnich Atomic Safety and Licensing Chair =an, Dauphin County Board of ,

Board Panel Commissioners 5000 Hermitage Drive Dauphin County Courthouse Raleigh, North Carolina 27612 Front and Market Streets Harrisburg, Pennsylvania 17101 ,

James A. Tourtellotte, Esquire Office of the Executive Legal Walter W. Cohen, Esquire Director Consumer Advocate U.S. Nuclear Regulatory Commission Department of Justice -

Washington, D.C. 20555 14th Floor, Strawberry Square Harrisburg, Pennsylvania 17127 Docketing and Service Section Office of the Secretary Jordan D. Cunningham, Esquire U.S. Nuclear Regulatory Commission Attorney for Newberry Township Washington, D.C. 20555 T.M.l. Steering Committee 2320 North Second Street John A. Levin, Esquire Harrisburg, Pennsylvania 17110 Assistant Counsel Pennsylvania Public Utility Theodore A. Adler, Esquire Commission Widoff Reager Selkowitz & Adler

! P.O. Box 3265 P.O. Box 1547 Harrisburg, Pennsylvania 17120 Harrisburg, Pennsylvania 17105 i

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• Person on whose behalf service is being made. Only Certificate _of l- Service is enclosed.

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Ellvn Weisa, Esquire Rcbert Q. Pollard Shaldon. Harmon 6 Weiss Chesapeake Energy Alliance Suite 506 609 Montpelier Street

.! ., Iye o t.r c e : , N.W. caltiacre, Mar ilan-a l .' 1 :

Lu; h i n m n . 3.0 "CO: 3 Chauncey 4 :pford J r . / ~. ~. 311 - . Judith ri. Jchnsrud W --u

.str-et invironmental Coalition on Nuclear Pcwer Sechanicsburg, rennsylvania 17055 433 Orlando Avenue State college, Pennsylvania 16501

.47 J. ' e c .,

Le p.;;..tia. Chairman Marvin I. Lewis Anti-Nuclear Group Representing 6504 Bradford Terrace York Philadelphia, Pennsylvania 19149

.'45 West Philadelphia Street York, Pennsylvania 17404 Marjorie M. Aamodt R.D. 5 Karen Sheldon, Esquire Coatesville, Pennsylvania 19320 Sheldon, Harmon & Weiss Suite 506 George F. Trowbridge, Esquire 1725 Eye Street, N.W. Shaw, Pittman, Potts & Trowbridge Washington, D.C. 20006 1800 M Street, N.W.

Washington, D.C. 20036

• Person on whose behalf service is being made. Only Certificate of Service is enclosed.

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