ML19309D380

Objects to Interrogatories Included in Intervenor Aamodt Contention 2 Interrogatories,Fourth Set.Info Requested Is Either Beyond Scope of Contention 2 or Irrelevant to Contention 2.Certificate of Svc Encl

ML19309D380
Person / Time
Site:	Three Mile Island
Issue date:	03/13/1980
From:	Trowbridge G METROPOLITAN EDISON CO., SHAW, PITTMAN, POTTS & TROWBRIDGE
To:	Atomic Safety and Licensing Board Panel
References
NUDOCS 8004100308
Download: ML19309D380 (8)

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March 13, 1980 UNITED STATES OF AMERICA -

NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD f

In the Matter of )

)

METROPOLITAN EDISON COMPANY ) Docket No. 50-289

) (Restart)

(Three Mile Island Nuclear )

. Station, Unit No. 1) )

LICENSEE'S OBJECTIONS TO AAMODT CONTENTION NO. 2 INTERROGATORIES (FOURTH SET)

Licensee objects to the following interrogatories included

in Intervenor Aamodt's Contention No. 2 Interrogatories, Fourth' Set

Interrogatory No. 4. This interrogatory requests a copy of tests proposed to be used by Licensee to test retention of certain operator training course materials. The documents Intervenor Aamodt requests in Interrogatory No. 4 cannot be divulged without effectively precluding their use'as operator tests. Licensee therefore objects to their public disclosure

! at this time. Licensee will make them available in Licensee's I

Discovery Reading Room once their disclosure would not damage their utility as tests, as early as April or-May, 1980.

Interrogatory No. 16. In this interrogatory, Licensee i.s asked whether it plans to introduce " stress" into simulator

. training and/or operator performance' testing. . Interrogatory-8 0 0 410 01kys

. No. 16 is beyond the scope of Contention No. 2, which challenges the technical competency of Licensee technicians 4

- and management and the adequacy of their technical training.

Through this interrogatory, Intervenor Aamodt appears to ,

, be attempting to broaden the scope of Contention No. 2 to include issues which would have been relevant to Aamodt Con-tention No. 1. However, Contention No. 1, which required a program for psychological testing and counselling for TMI-l operator personnel and management, was rejected by the Licens-ing Board as "without basis and outside the scope of the proceeding." Interrogatory No. 16 is therefore not only f irrelevant to resolution of Contention No. 2, but is generally beyond the scope of the TMI Unit 1 restart proceeding.

Interrogatory No. 17. In this interrogatory, Licensee is asked whether before the TMI-2 accident, it screened for its operators' and supervisors' ability to reason under stress.

For the reasons stated in Licensee's objections to Interrog-atory No. 16, this information is irrelevant to resolution of Contention _No. 2 and not subject to discovery.

Interrogatory No.-18. This interrogatory questions whether Licensee will screen for its operators' and super- ,

visors' ability to reason under. stress for the proposed

. restart of TMI Unit 1. For the reasons stated'in Licensee's objections.to Interrogatory No. 16, this information is irrelevant to resolution'of-Contention No..-2 and not subject to discovery.

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Interrogatories No. 21 through 26. The subject matter of each of these interrogatories, stated below, is beyond the scope of Aamodt Contention No. 2 and irrelevant to reso-lution of that contention, which challenges the technical competency of TMI Unit 1 technicians and management and the adequacy of their technical training. Licensee therefore

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objects to the numerous extraneous requests for information and documents contained in the following interrogatories, none of which question or relate to technical competency or adequacy of training for TMI Unit 1 operators and management.

Interrogatory No. 21. This interrogatory inquires what Licensee plans to do to eliminate the repair tags on control room consoles.

Interrogatory No. 22. This interrogatory requests the criteria by which Licensee determines the suitability of six hour operator shifts. Licensee is also asked whether these- ,

shifts have been established to be consistent with alertness required for all jobs, and the number of hours the personnel, including those in the control room, maintenance and guards, had been on duty at the commencement of the TMI-2 accident.

Interrogatory No. 23. This interrogatory asks Licensee.why recommendations for-limiting maximum time on duty to two shifts of twelve hours has been made by Licensee and NRC,.and whether it has been determined how well personnel can . perform as trained and under unanticipated conditions as

'a function of time on the' job.

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Interrogatory No. 24. This interrogatory asks l Licensee to provide data on length of' shift for all operators

! and supervisors at TMI Units 1 and 2 for the month of March, 1979. Licensee is also asked whether these shift lengths are [

i l typical and, if not, Licensee is to provide times of year or '

] other factors which'have influenced the length of shift.

Interrogatory No.,25. This interrogatory asks ,

Licensee to identify the longest shift any person was allowed

to work at TMI~ Units 1 or 2 prior to the accident, and re-

! quests the name of that person, his/her position and reason.  ;

Interrogatory No. 26. This interrogatory asks i

Licensee to "(p]rovide incidents at TMI-l from beginning of j '

4 operation." Licensee is asked to give the date, time, names of operators and supervisors on duty, number of days each had been on duty at the time of incident, and number of days'each-had been on duty since a day off. This interrogatory also 1 .

, asks Licensee whether it has .made "any analysis of this kind-prior to TMI-2 accident or since the accident" ~ and if so, to provide this analysis.

r Interrogatory No. 36. In Interrogatory No. 36,  ;

. Intervenor Aamodt asks to depose 10 (or less) employ ~ees at l TMI-l and 2 at each job level, selected by_~intervenor in a statistically random. manner.. Interrogatory No. 36 fails in several respects to conform to the requirements of the.NRC Rules of Practice (10 CFR S2.740(a)); governing depositions..

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Specifically, Interrogatory No. 36 fails to identify the

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l time and place of deposition or a sufficient identifice tion i of the individuals to be deposed, fails to indicate tru  !

matters upon which each person will be examined, and fails

! to name the officer before whom the depositions are to be taken. Licensee therefore objects to this interrogatory /  !

I i deposition request.

. Respectfully submitted, SHAW, PITTMAN, POTTS & TROWBRIDGE i

1 l m -

mak ,

W Gj(orge F. Trowbridcfe t

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Dated: March 13, 1980 '

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l March 13, 1980 i

1 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION 3

BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of )

)

METROPOLITAN EDISON COMPANY ) Docket No. 50-289

, ) (Restart)

, (Three Mile Island Nuclear )

l Station, Unit No. 1) )

i i

CERTIFICATE OF SERVICE

) I hereby certify that copies of " Licensee's Objections to Aamodt Contention No. 2 Interrogatories (Fourth Set) , were served upon those persons on the attached Service List by deposit i in the United States mail, postage prepaid, this 13th day of March, 1980.

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/$M / 4

' ' " ~ GW'orge F. Trowbridge/

1-l Dated: March 13, 1980 1

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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION t BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of )

)

METROPOLITAN EDISON COMPANY ) Docket No. 50-289

) (Restart)

(Three Mile Island Nuclear )

l Station, Unit No. 1) )

SERVICE LIST Ivan W. Smith, Esquire John A. Ievin, Esquire Chairman Assistant Counsel

• Atcmic Safety and Licensing Pennsylvania Public Utility Ccmn'n Board Panel Post Office Box 3265 U.S. Nuclear Pcqulatory Ccmnission Harrisburg, Pennsylvania 17120 Washington, D.C. 20555 Karin W. Carter, Esquire Dr. Walter H. Jordan Assistant Attorney General Atcmic Safety and Licensing . 505 Executive Fause Board Panel Post Office Box 2357 881 West Outer Drive Harrish"rg, Pennsylvania 17120 Oak Ridge, Tennessee 37830 John 2. rtinnich i

Dr. Linda W. Little Chairman, Dauphin County Board Atcmic Safety and Licensing of Ccmnissioners Board Panel Dauphin County Courthouse 5000 Hermitage Drive Front and Market Streets Raleigh, North Carolina 27612 Harrisburg, Pennsylvania 17101 James R. Tourtellotte, Esquire Walter W. Cohen, Esquire Office of the Executive Ingal Director Ccrisumer Advocate U. S. Nuclear Regulatory Catmission Office of Consumer Advocate Washington, D.C. 20555 14th Floor, Strawberry Square Harrisburg, Pennsylvania 17127 Docketing and Service Section Office of the Secretary U. S. Nuclear Regulatory Ca: mission Washington, D.C. 20555

4 Jordan D. Cunningham, Esquire Karin P. Sheldon, Esquire Attorney for Newberry Township Attorney for People Against Nuclear T.M.I. Steering Ccmnittee Energy 2320 North Second Street Sheldon, Harmon & Weiss Harrisburg, Pennsylvania 17110 1725 Eye Street, N.W., Suite 506 Washington, D.C. 20006

'Ihoodore A. Adler, Esquire Widoff Reager Selkowitz & Adler Robert Q. Pollard  ;

Post Office Box 1547 Chesapeake Energy Alliance Harrisburg, Pennsylvania 17105 609 Mxitpelier Street  ;

Baltinere, Maryland 21218 E13yn R. Weiss, Esquire Attorney for the Union of Concerned Chauncey Kepford Scientists Judith H. Johnsrud Sheldon, Harmon & Weiss Environmental Coalition on Nuclear 1725 Eye Street, N.W., Suite 506 Power Washington, D.C. 20006 433 Orlando Avenue State College, Pennsylvania 16801 Steven C. Sholly 304 South Market Street Marvin I. Icais Mechanicsburg, Pennsylvania 17055 6504 Bradford Terrace i

, Philadelphia, Pennsylvania 19149

Call Bradford Holly S. Keck Marjorie M. Aamodt i

Icgislation Chairman R. D. 5 '

Anti-Nuclear Group Representing York Coatesville, Pennsylvania 19320 L 245 West Philadelphia Street York, Pennsylvania 17404 t

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