ML19327A061

Response to NRC Second Set of Interrogatories.Objects to Interrogatories 1-3 Due to Untimeliness & Irrelevancy to NUREG-0680.NRC Evaluation of Proposed Retraining Is Not Adequate.W/Certification of Svc.Related Correspondence

ML19327A061
Person / Time
Site:	Three Mile Island
Issue date:	07/23/1980
From:	Aamodt M AFFILIATION NOT ASSIGNED
To:	NRC OFFICE OF THE EXECUTIVE LEGAL DIRECTOR (OELD)
References
ISSUANCES-SP, NUDOCS 8008010113
Download: ML19327A061 (3)

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THIS DOCUMENT CONTAINS REMDW CORRNONDEC2 AAMODT 7/23/80

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In the Matter of Metrouolitan Edison Company, et. al. cm:s sf tr.e Se@rf (Ihree Mile Islanii Nuclear Station, Uni No. 1) 6 cocketig & semcs stanca e

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AAMODT RESPONS2 TO SECOND SET OF NRC INTERROGATORIES My husband, Nor:an Aamodt, spoke with Mr. James A. Tourtellotte Esquire of NRC legal staff to request an extension of time in which to make this response until July 23, 1930 in the absence of Mr. Ivan W. Smith, Esquire from his office last week.

Mr. Tourtellotte had no objection to this request.

I object to General Interrogatories 1 through 3 on the basis of unticeliness. They inquire into general discovery matters, time for which is long since past. I understand that the only acceptable interrogatories at this point, unless specially permitted by the Board, are those concerning NUREG-0650 and the Restart Report.

j Response to Interrogatory 2-1:

Contention is continued that 100% test perforcance of technicians be made by an independent engineering firm and i that this is necessary to assure safe operation of TMI-1.

The key word in the Board Crder was " assurance". The require-ment of " assurance" makes independent verification necessary.

1 l Why would NRC select 90% as an acceptable grade en the i

special exa (IMI-2 ac id::t sequences) p. Cl-16? What caterial included in the exa= would not be necessary for an operator to I

know? I contend that all parts of the eran and all other exans l

should be answered cc=pletely and correctly as an initial in- Db f L

i dication that the material tresented was mastered. In order

- I/O to achieve 1C0% test score, "c 7erlearning" is generally required.

There are many experiments in the body of learning theory which show that where there is " overlearning" there is greater retention 8008010//3 as a function of ti=e. "Cverlearning" also provides for core G '

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2 correct responses during periods of stress.

2-2.: All 2-3: -

I would prefer not to believe, but to knqw whether the operator training program initiated at TMI-1 is adequate.

The only way we can know that training is adequate is through test evaluation of operators' responses in a variety of situations that simulate all possible predictable events. That test ,

evaluation needs to be cade by people who understand the function of. testing in predicting perfor ance.

2-4: .

I object to the word "believe". I studied human behavior as a scientist, trained in mathematical analysis, testing techniques and measurement of physical and = ental characteristics of hucan beings.

I do not find NRC's evaluation of the licensee's proposed retrainin6 either adequate or informative. For instance, there is no analysis of how the station training department was increased o,ther than in si5e, assuming the bigger is better. There is no analysis of the qualifications of 7ersonnel Qualification Services, the independent consultant chosen by Met Ed. . The final paragraph on p. C6-7 under Training of Operating Staff is a leap of faith in an area for which the tools of evaluation have been available for some time.

4-1 through 4-4 deal with eter6ency planning. I need to study the revised e ergency plan in more detail before answering.

8-1 through 8-3 : Eo response as this contention chould be withdrawn as the area of major concern was not considered as included in the Board's interpretation en acceptance.

Respectfully submitted, <

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/I]? Marjorie 2 -Aamodt, '

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.' I hereby certify that copies of AAMODT RES?ONSE TO SECOND SET OF NRC _ IHTERROGATORIES dated July 23, 1980 weri served upon those persons on the Service List below by deposit in the United States = ail, postagenpaid, this 23rd day of July, 1980.

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?(LU bk hl) h J-i Marjo;rde M. Aamodt v

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!' Service List Ivan W. Scith, Esquire, Chairman Atomic Safety and Licensing Board Fanel U. S. Nuclear _ Regulatory Coccission Washington, D. C. 20555 Dr. Walter H. Jesdan Atomic Safety and Licensing Board Fanel 881 West Outer Drive Oak Ridge, Tennessee 37830 Dr. Linda W. Little Atomic Safety and Licensing Board Fanel 5000 Hermitage Drive R2leigh, North Carolina 27612 James A. Tourtellotte, Esquire Cffice of the Executive leEal Director U. S. Nuclear Regulatory Co==ission Washington, D. C. 20555 Docketing and Service Section Office of the Secretary U. S. Nuclear Regulatcry Commission Washington, D. C. 20555 George ?. Trowbridge, Esquire Shaw, Pittman, 20t s & Trowbridge 1800 M Street, N. W.

Washington, D. C. 20036

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