ML20031C556
| ML20031C556 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 10/01/1981 |
| From: | Swartz L NRC OFFICE OF THE EXECUTIVE LEGAL DIRECTOR (OELD) |
| To: | AAMODTS |
| References | |
| NUDOCS 8110070288 | |
| Download: ML20031C556 (14) | |
Text
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ST:WF 10/1/81 4
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of
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METROPCt.ITAN EDISON COMPANY, ET AL.)
Docket No. 50-289C 6t.b, l
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(Restart)
T; 0y (Three Mile Island, Unit 1)
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9 cm NRC STAFF INTERR0GATORIES TO INTERVENOR AAMODTS In accordance with 10 CFR 992.740 and 2.740b, the following interrogatories are directed to Mr. and Mrs. Aamodt as intervening parties in the above-captioned proceeding.
Each interrogatory not objected to is to be answered separately and fully in writing under oath or affirmation by the individuals having personal knowledge of the answers. The Staff assumes that a date when responses to these interrogatories must be filed will be set by Judge Milhollin at the conference of parties scheduled for October 2, 1981.
The interrogatories posed deal with the issues on which the Aamodts have indicated they will present testimony in the reopened hearing to be conducted with respect to the cheatirl incident at TMI-1. The designation of issues corresponds to the numbered issues contained in
" Statement of Issues for Reopened Hearing Proposed By Licensee, the NRC l
Staff, the Cornonwealth of Pennsylvania, the Aamodts, and TMIA" attached to the. Licensee's letter to the Board dated September 24, 1981.
In the event the Aamodts later decide to present direct testimony on other issues,
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the Staff reserves its right to pose subsequent interrogatc*ies with
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DESIGUATED ORIGIIIAL 8110070288 811001 Certified Ey _
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regard to those additional issues.
It should be noted that, under 10 CcR 62.740(e), supplementation of discovery responses is required with respect to: (1) any question directly addressed to the ident.ty and location of persons having knowledge of discoverable matters and to the identity of persons expected to be called as expert witnesses at the hearing and (2) new aformation ot'af ned which indicates that the original response was not correct when made or is no longer correct.
Responses to certain of the interrogatories posed below may require the disclosure of names of individuals alleged to be involved in impro-prieties at TMI. The Staff believes, as exp essed in its September 24, 1981 "Brief on Need for Protective Order," that disclosure of such information is an imposition on the privacy of the individuals concerned. Thus, disclosure of the names by the Aamodts should be made only to the NRC Staff and the Licensing Board.
Issue 6 1.
Do you believe that the Licensee's management was involved in i
cheating on a test given at TMI-1 since the TMI-2 accident?
2.
Identify by name and address each person you rely upon in any way to substantiate your belief that the Licensee's management personnel was involved in cheating by personnel on a test given at TMI-1 since the TMI-2 accident.
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l 3.
Ide.ntify by name and address each person you intend to call as a w'eness in the reopened hearing to substantiate your belief that i
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the Licensee's management personnel was involved in cheating by personnel on a test given at TMI-1 since the THI-2 accident.
4.
Provide a summary of the views relative to Issue 6 of each person identified in response to Interrogatcries 2 and 3.
5.
Identify by author and title any document relied upon by the individuals identified in response to Interrogatories 2 and 3 to substantitte their position.
6.
Identify by author and title any document you intend to use as an exhibit or as evidence at the hearing with respect to Issue 6.
7.
Specify the test or tests given at TMI-1 since the TMI-2 accident on which you contend personnel cheated and in which you contend the Licensee's management personnel was involved.
8.
Identify by name and position each of tt e Licensee's management personnel which you contend was involved in cheating by personnel on a test or tests identified in response to Interrogatory 7.
9.
Identify by name and position each of the individuals which you contend cheated on a test or tests identified in response to Interrogatory 7.
- 10. Describe in detail the extent of the involvement of the Licensee's management personnel in the cheating by personnel in a test or tests identified in response to Interrogatory 7.
- 11. Describe in detail the extent of the cheating which you contend occtitred during the test or tests identified in response to In'terfhgatory 7.
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- 12. Describe in detail the effect of the alleged cheating during the l
l test or tests identified in Interrogatory 7 on the ability of the l
Licensee to operate TMI-1 safely.
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- 13. Describe in detail the effect of the alleged involvement of the Licensee's management personnel in the alleged cheating during the test or tests identified in the Interrogatory 7 on the ability of the Licensee to operate TMI-1 safely.
Issue 13*
- 14. Do you believe that TMI-2 operators cher sd on NRC licensed examir?.tions?
15.
Identify by name and address each person you rely upon in any way to substantiate your belief that TMI-2 operators eneated on NRC licensed operator examinations.
16.
Identify by name and address each person you intend to call as a witness in the reopened hearing to substantiate your belief that TMI-2 operators cheated on NRC licensed operator examinations.
17.
Pio/ide a summary of the views relative to Issue 13 of each person identifed in response to Interrogatories 13 and 14.
18.
Identify by author and titic any document relied on by the individuals identified in response to Interrogatories 15 and 16 to substantiate their position.
19.
Identify by author and title any document you intend to use as an exhibit or as evidence at the hearing with respect to Issue 13.
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- 20. Specify each TMI-2 licensing examination conducted by the NRC on which you contend there was cheating.
In the event this issue is not accepted for litigation in the proceeding, these interrogatories need not be answered.
21.
Identify by name, address, and position each individual you contend cheated on the examinations identified in response to Interrogatory 20.
- 22. Describe in detail the manner in which the alleged incident or incidents of cheating on TMI-2 operating license examinations occurred.
- 23. Ucscribe in detail the effect of allegad cheating during TMI-2 operator licensing examinations conducted by the NRC on the ability of the Licensee to operate TMI-1 safely.
- 24. Do you believe th&t Licensee's management personnel was involved in cheating by THI-2 operatnrs on NRC licensed operator examinations?
25.
Identify by name and address each person you rely upon in any way to substantiate your belief that Licensee's management personnel was involved in cheating by TMI-2 operators on NRC licensed operator examinations.
26.
Identify by name and address each person you intend to call as a witness in the reopened hearing to substantiate your belief that Licensee's management personnel was involved in cheating by TMI-2 operators on NRC licensed operator examinations.
27.
Provide a summary of the views relative to Issue 13 of each person identified in response to Interrogatories 22 and 23.
28.
Identify by author and title any document relied upon by the 1
individuals identified in response to Interrogatories 25 and 26 to I
subs'tEntiate their position, f
- 29. Specify each TMI-2 licensing examination in which you contend the Licensee's management personnel was involved in cheating by THI-2 operators, l
30.
Ideqtify by name, address, and position each of the Licensee's maqagement personnel whoa you contend were involved in cheating on the examinations identified in response to Interrogatory 29.
31.
Describe in detail the extent of management involvement which you contend occurred during the examinations identified in response to Interrogatory 29.
- 32. Describe ir, detail the effect of the alleged management involvement in the examinations identified in response to Interrogatory 29 on the ability of the Licensee to operate TMI-1 safely.
33.
Do you believe that the NRC or its Staff was involved in irregularities present in TMI-2 licensing examinations-34.
Identify by name and address each person you rely upon in any way to substantiate your belief that the NRC or its staff was involved in irregularities present in TMI-2 licensing examinations.
35.
Identify by name and address each person you intend to call as a witness in the reopened hearing to substantiate your belief that the NRC or its Staff was involved in irregularities present in l
THI-2 licensing examinations.
36.
Provide a summary of the views relative to Issue 13 of each person identified in response to Interrogatories 30 and 31.
37.
Identify by author and title each document relied upon by the persons identified in response to Interrogatories 34 and 35 to substantiate their position.
- 38. Sdecify each TMI-2 licensing examination in which you contend the NRC or its staff was involved in irregularities.
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39.
Identify by name, address, and position each of the NRC's members or staff members whom you contend were involved in irregularities during the examinations identified in response to Interrogatory 38.
- 40. Describe in detail the irregularities which you contend the NRC or its staff were involved in during the examinations identified in response to Interrogatory 38.
41.
Describe in detail the effect of the alleged NRC involvement in irregularities on the THI-2 examination identified in response to Interrogatory 38 on the ability of the Licensee to operate TMI-1 safely.
Issue 14*
42.
Do you believe that TMI non-licensed personnel cheated on Licensee-administered tests given since the TMI-2 accidenc?
43.
Identify by name and address each person you rely upon in any way to substantiate your belief that TMI non-licensed personnel cheated on Licensee-administered tests given since the TMI-2 accident.
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44.
Identify by name and address each person you intend to call as a witness in the reopened hearing to substantiate your belief that TMI non-licensed personnel cheated on Licensee-administered tests given since the TMI-2 accident.
I 45.
Provide a summary of the views relative to Issue 14 of each person i' dent 3fied in response to Interrogatories 43 and 44.
In the event this issue is not accepted for litigation to the proceeding, these interrogatories need not be answered.
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Identify by author and title any docuaent relied on by the individuals identified in response to Interrogatories 43 and 44 to substantiate their position.
47.
Identify by author and title any document you intead to use as an exhibit or as evidence at the hearing with respect to Issue 14.
48.
Specify each Licensee-administered test given since the TMI-2 accident on which you contend TMI non-licensed personnel cheated.
49.
Identify by nane, address, and position each TMI non-licensed person you contend cheated on the Licensee-administered tests identified in response to Interrogatory 48.
50.
Describe in detail the manner in which the alleged incident or incidents of cheatir.g on the Licensee tests identified in response to Interrogatory 48 administered to TMI non-licensed persoanel occurred.
51.
Describe in detail the effect of alleged cheating during Licensee tests administered to TMI non-licensed personnel on the ability of the Licensee to operate TMI-1 safely.
Issue 15*
52.
Do you believe that inadequate training contributed to cheating at THI?
53.
Identify by name and address each person you rely upon in any way to substantiate your belief that inadequate training contributed to cheating.
. I!1 In the event Issue 1G is not accepted for litigation in this proceeding, these interrogatories need not be answered.
i 54.
Identify by name and address each person you intend to call as a witness in the reopened hearing to substantiate your belief that inadequate training contributed to cheating.
55.
Provide a summary of the views relative to Issue 15 of each person identified in response to Interrogatories 53 and 54.
56.
Identify by author and title any document relied on by the individuals identified in response to Interrogatories 53 and 54 to substantiate their position.
57.
Identify by author and title any document you intend to use as an exhibit or as evidence at the hearing with. aspect to Issue 15.
- 58. Specify each and every way in which you contend training is l
inadequate.
- 59. Specify which aspects of training at TMI you contend are inadequate.
- 60. Describe in detail the manner in which you contend inadequacies identified in respense to Interrogatories 58 and 59 contributed to cheating at TMI.
- 61. Describe in detail what additional training you contend needs to be done in order to preclude cheating.
- 62. Specify why you believe the additional measures identifed in response to Interrogatory 61 will prevent cheating at TMI in the future.
x Issue 16*
Do js-believe that the criteria used by the Licensee's management 63.
e In the event Issue 16 is not accepted for litigation in this proceeding, these interrogatories need not be answered.
personnel to certify operator license candidates to HRC were not sufficient?
64.
Identify by name and address each person you rely upon to substantiate your belief that the criteria used by the Licensee's management personnel to certify operator license candidates to NRC were not sufficient.
65.
Identify by name and address each person you intend to call as a witness in the reopened hearing to substantiate your belief that the criteria used by the uicensee's management personnel to certify operator license 08 iates to NRC were not sufficient.
66.
Provide a summary L' the views relative to Issue 16 of each person identified in reponse to Interrogatories 64 and 65.
67.
Identify by author and title any document relied on by the individuals identified in response to Interrogatories 64 and 65 to sut,stantiate their position.
68.
Identify by author and title any document you intend to use as an exhibit or as evidence at the hearing with respect to Issue 16.
- 69. Describe in detail the ways in which you contend the criteria used I
by the Licensee to certify op?rator license candidates to NRC were not sufficient.
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- 70. Specify the criteria which you believe the Licensee should use to certify operator license candidates to NRC.
l Destribe in detail the ways-in which you believe the inadequacies 71.
ideiiilfied in response to Interrogatory 69 contributed to the l
cheating at TMI.
- 72. Describe in detail tne reasons why you believe the criteria identified in response to Interrogatory 70 would prevent further instances of cheating at TMI.
Issue 17*
- 73. Do you believe that the NRC Staff's plan for retesting operators and monitoring its examinations is not adequate?
74.
Identify by name and address each person you rely upon to substantiate your beliei that the Staff's plan for retesting operators and monitoring its examinations is not adequate.
75.
Identify by name and address each person you intend to call as a witness in the reopened hearing to substantiate your belief js that the Staff's plan for retesting operators and monitoring its examinations is not adequate.
- 76. Provide a summary of the views relative to Issue 17 of the persons identified in response to Interrogatories 74 and 75.
77.
Identiff by author and title any document relied upon by the individuals identified in response to Interrogatories 74 and 75 to substantiate their position.
78.
Identify by author and title any document you intend to use as an exhibit or as evidence at the hearing with respect to Issue 17.
- 79. Describe in detail the ways in which you believe the Staff's plan for' retesting operators and monitoring its examinations is fnadequate.
t In the event Issue 17 is not accepted for litigation in this proceeding, these interrogatories need not be answered.
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- 80. Specify the procedures which you believe the Staff should employ with respect to its operator licensing examinations to provide reasonable assurance that TMI-1 will be operated safely.
81.
Specify why ycu believe the procedures you describe in response to Interrogatory 80 are more effective than the Staff's plan for retes. ag operators and monitoring its examinations.
- 82. Specify why you believe that adherence to NRC testing requirements will not provide reasonable assurance that THI-1 will be operated safely.
Respectfully submitted, O
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LJci a Low Swartz /
Counsel for NRC Staff Dated at Bethesda, Maryland this 1st day of October, 1981.
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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Metter of METROPOLITAN EDISON COMPANY, ET AL.)
Docket Ho. 50-289
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(Restart)
(Three Mile Island, Unit 1)
)
(ReopenedManagementIssues)
CERTIFICATE OF SERVICE I hereby certify that copies of "NRC STAFF INTERROGATORIES TO INTERVENOR AAM0DTS" in the above-captioned proceeding have been served on the following by deposit in the United States mail, first cuss, or, as indicated by an asterisk, by deposit in the Nuclear Regulatory Commission's internal mail system, this 5th day of October,1981, or, as indicated by double asterisks, were hand-delivered on October 2,1981:
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- Stephen F. Eilperin, Chairman Dr. Linda W. Little Atomic Safety & Licensing Appeal Administrative Judge Board Panel 5000 Hermitage Drive U.S. Nuclear Regulatory Comission Raleign, North Carolina 27612 Washington, DC 20555
- George F. Trowbridge, Esq.
- Dr. John H. Buck Shaw, Pittman, Potts & Trowbridge Atomic Safety & Licensing Appeal 1800 M Street, N.W.
Board Panel Washington, DC 20006 U.S. Nuclear Regulatory Comuission l
l Washington, DC 20555
- Robert Adler, Esq.
l 505 Executive House
- Christine N. Kohl P. O. P;x 2357 l
Atomic Safety & Licensing Appeal Har,*isburg, Pennsylvania 17120 Board Panel U.S. Nuclear Regulatory Comission Honorable Mark Cohen Washington, DC 20555 512 D 3 Main Capital Building Harrisburg, PA 17120
- Ivan W. Smith, Esq.
l Adminis-trative Judge Atomic Safety & Licensirg Board Panel
- Ms. Marjorie Aamodt U.S. NuCIdar Regelatory Conraission R.D. #5 Washington, DC 20555 Coatesville, PA 19320 Dr. Walter H. Jordan Mr. Thomas Gerusky Administrative Judge Bureau of Radiation Protect'on 881 W. Outer Drive Dept. of Environmental Resources l
Oak Ridge, Tennessee 3783' P. O. Box 2063 l
Harrisburg, PA 17120
Mr. liarvin I. Lewis 6504 Bradford Terrace
- Atomic Safety acd Licensing Appeal Board Philadelphia, PA 19149 U.S. Nuclear Regslatory Commission Washington, DC 20555 Metropolitan Edison Company ATTH:
J. G. Herbein, Vice President
- Atomic Safety and Licensing Board Panel P. O. Box 542 U.S. Nuclear Regulatory Comission Reading, PA 19603 Washington, DC 20555 Ms. Jane Lee
- Secretary R.D. 3; Box 3521 U.S. Nuclear Regulatory Comission Etters, PA 17319 ATTN:
Chief, Docketing & Service Br.
Washington, DC 20555 Walter W. Cohen, Consumer Advocate Department of Justice William S. Jordan, III, Esq.
Strawberry Square,14th Floor Harmon & Weiss Harrisburg, PA 17127 1725 I Street, N.W.
Suite 506 Thomas J. Germine Washington, DC 20006 Depe*" Attorney General Divis..,n of Law - Room 316 John Levin. Esq.
1100 Raymond Boulevard Pennsylvania Public Utilities Conrn.
Newark, New Jersey 07102 Box 3265 Harrisburg, PA 17120 Allen R. Carter, Chairman Joint Legislative Committee on Energy Jordan D. Cunningham, Esq.
Post l'ffice Box 142 Fox, Farr and Cunningham Suit; 513 2320 North 2nd Street Ser.dte Gressette Building Harrisburg, PA 17110 C;1umbia, South Carolina 29202
- Louise Bradford Robert y. Pollard Three Mile Island Alert 609 Montpelier Street 1011 Green Street Baltimore, Maryland 21218 Harrisburg, PA 17102 Chauncey Kepford Ms. Ellyn R. Weiss Judith Johnsrud Harmon & Weiss Environmental Coalition on Nuclear Power 1725 I Street, N.W.
433 Orlando Avenue Suite 506 State College, PA 16801 Washington, DC 20006 Ms. Frieda Berryhill, Chairman Mr. Steven C. Sholly Coalition for Nuclear Power Plant Union of Concerned Scientists Postponement 1725 I Street, N.W.
2610 Grendon Drive Suite 601 Wilmington, Delaware 19808 Washington, DC 20006 GaiiPheks
- Gary L. Milhollin, Esq.
ANGRY 1815 Jefferson Street 245 W. Philadelphia Street Madison, WI 53711 York, Pennsylvania 17401 btb 7 bl. 6ed D.
Lucinda Low Swartz Counsel for NRC Staff
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