ML20031C569

Interrogatories Directed to Licensee.Certificate of Svc Encl

ML20031C569
Person / Time
Site:	Crane
Issue date:	10/02/1981
From:	Swartz L NRC OFFICE OF THE EXECUTIVE LEGAL DIRECTOR (OELD)
To:	METROPOLITAN EDISON CO.
References
NUDOCS 8110070307
Download: ML20031C569 (8)

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STAFF 10/2/81 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of

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Docket No. 50-289p

-r METROPOLITAN EDIS0N COMPANY, ET AL.

(Restart) (.

y is (Three Mile Island, Unit 1) 7-1 0CT G 198W 9;44 v.5.'$$N,rn,u NRC STAFF INTERR0GATORIES TO LICENSEE In accordance with 10 CFR 592.740 and 2.740b, the followin'i.

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interrogatories are directed to Licensee in the 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 tiled will be set by Judge Milhollin at the conference of parties scheduled for October 2,1981.

These interrogatories are directed to certain of the issues contained in " Statement of Issues for Reopened Hearing Proposed by Licensee, the HRC Staff, the Commonwealth of Pennsylvania, the Aamodts, and TMIA" (" Statement of Issues") attached to the Licensee's letter to the Licensing Board dated September 24, 1981.

The designation of issues in these interrogatories corresponds to the designation in the

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" Statement of Issues."

1 Pursuant to 10 CFR 52.740(e), supplementation of responses to these interrogatories is required with respect to:

(1) any question directly

'7 addressed to the identity and location of persons having knowledge of

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. discoverable matters and to the identity of persons expected to be called as expert witnesses at the hearing; and (2) new information obtained which indicates that the original response was not correct when made or is no longer correct.

Responses to certain of these interrogatories ray require the disclosure of names of individuals alleged to be involved in improprieties at TMI. The Staff believes, as expressed in its September 24, 1981 "Brief on Need for Protective Order," that disclosure of such information i

is an imposition on the privacy of the individuals concerned. Thus, disclosure of the names should be made only to the NRC Staff and the Licensing Board.

Interrogatories Issues 1 and 3 1.

What was management's involvement in the Licensee's investigation of possible cheating or improprieties on (a) the Kelli examinations (including Category Ti in April 1980; (b) Category T make-up examinations subsequently administered by the Company; and (c) the ATTS Mock examinations in early April 1981?

2.

Who participated in the Licensee's investigation of possible cheating or improprieties cn the examinations referenced in interrogatory l?

4 3.

Describe the Licensee's investigations into possible cheating or improprieties on the examinations referenced in interrogatory 1.

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Issue 4 4.

Describe the Licensee management actions taken in connection with information developed in the Licensee's investigation of cheating and rumors of cheating in the NRC April 1981 examinations.

5.

Apart fran those actions taken by the Licensee as described in response to interrogatory 4, were any other actions considered?

If so, (a) What other actions were considered?

(b) Explain why those actions were not taken.

Issue 6 6.

What information does Licensee management have regarding the subject of the proposed Aawodt testimony on management's involvement or complicity in cheating or otherwise thwarting the intent of the examinations?

Issue 8 7.

Describe the incident in July 1979 referred to in the l'&E investigation report.

8.

As to the July 1979 incident referred to in the I&E investigation report:

(a)

Identify the Licensee employees involved.

(b) Describe the actions taken by the Licensee in response to the incident.

i (c) Were other actions considered by the Licensee?

If so, i

describe those other actions and explain why they were not taken.

9.

After discovery of the July 1979 cheating incident, what actions were taken by Licensee's management to assure that all employees

were aware of their responsibilities regarding honesty on all examinations? What actions were taken b; Licensee's management to preclude further cheating on examinations?

Issue 9

10. Describe the manner in whicii Company qualification examinations and Company certification examinations have been administered in the past.

11. Was a single examination given to all personnel even though, because of shift rotation, certain personnel might have the opportunity to pass examination information on to other examinees?

If not, describe how the examinations differed.

12. Were the examinations proctored?

13. Were examinees permitted to take examinations or portions of examinations home?

14. Were examinees permitted to complete examinations or portions of examinations on shift?

15. How were re-examinations for areas of deficiency conducted?

In this regard, were take-home examinations, open-book examinations or

" group effort" examinations utilized?

16. Vere consultants used in giving requalification examinations?

17. Has the Licensee certified for NRC examination purposes any personnel who failed or performed unsatisfactorily on certification or audit examinations? If so, indicate when such certification to NRC took place, identify the examinees thus certified and state why in each instance the Licensee would certify personnel for NRC i

examinations wha had failed or performed unsatisfactorily on certification or audit examinations.

18. Were examinations administered immediately after lectures?

Issue 12

19. Describe the criteria used by Licensee management to evaluate the 4

integrity of candidates for NRC licenses.

20.

Describe the pre-selection criteria used to select candidates for training for NRC licenses.

21. How does Licensee management judge the integrity of candidates for l

NRC licenses.

22. What does Licensee intend when it certifies operator license candidates to the NRC? What should the NRC conclude with respect to certified candidates' honesty and integrity and why?

i Respectfully submitted, JfY

'I

1. u nda Low arty L

Counsel for NRC Staff Dated at Bethesda, Maryland this 2nd day of October,1981.

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UNITED STATES OF INERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of METROFOLITAN EDISON COMPANY, ET A',.)

Docket No. 50-289

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(Restart)

(Three Mile Island, Unit 1)

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(ReopenedManagementIssues)

CERIIFICATE OF SERVICE I hereby certify that copies of "t:RC STAFF INTERROGATORIES TO LICENSEE" in the above-captioned proceeding have been served on the following by deposit in the United States mail, first class, or, as indicated by an asterisk, by deposit in the Nuclear Regulatory Commission's internal mail system this 2nd day of October,1981:

• Stephen F. Eilperin, Chairman Dr. Linda W. Little Atomic Safety & Licensing Appeal Administrative Judge Board Panel 5000 Hermitage Drive U.S. Nuclear Regulatory Commission Raleigh, 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 Commission Washington, DC 20555 Karin W. Carter, Esq.

l 505 Executive House

• Christine N. Kohl P. O. Box 2357 Atomic Safety & Licensing Appeal Harrisburg, Pennsylvania 17120 Board Panel U.S. Nuclear Regulatory Commission Honorable Mark Cohen Washington, DC 20555 512 D-3 Main Capitel Building Harrisburg, PA 17120

• Ivan W. Smith, Esq.

j Administrative Judge Atomic Safety & Licensing Board Panel Ms. Marjorie Aamodt U.S. Nuclear Regulatory Commission R.D. #5 Washington, DC 20555 Coatesville, PA 19320 Dr. Welter H. Jordan Mr. Thomas Gerusky Administrative Judge Bureau of Radiation Protection 881 W. Outer Drive Dept. of Environmental Resources l

Oak Ridge, Tennessee 37830 P. O. Box 2063 Harrisburg, PA 17120

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. Mr. Marvin I. Lewis 6504 Bradford Terrace

• Atomic Safety anJ Licensing Appeal Board Philadelphia, PA 19149 U.S. Nuclear Regulatory Commission Washington, DC 20555 Metropolitan Edison Company ATTN:

J. G. Herbein, Vice President

• Atomic Safety and Licensing Board Panel" P. O. Box 542 U.S. Nuclear Regulatory Commission Reading, PA 19603 Washington, DC 20555 Ms. Jane Lee

• Secretary R.D. 3; Box 3521 U.S. Nuclear Regulatory Commission 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 Deputy Attorney General Division of Law - Room 316 John Levin, Esq.

1100 Raymond Boulevard Pennsylvania Public Utilities Comm.

Newark, New Jersey 07102 Box 3265 Harrisburg, PA 17120 Allen R. Carter, Chairman Joint Legislative Committee on Energy Jordan D. Cunningham, Esq.

Post Office Box 142 Fox, Farr and Cunningham Suite 513 2320 North 2nd Street Senate Gressette Building Harrisburg, PA 17110 Columbia, South Carolina 29202 Louise Bradford Robert Q. Poard Three Mile Island Alert 609 Montpelier Street 315 Peffer Street Baltimore, Maryland 21218 Harrisburg, PA 17102 Chauncey Kepford Ms. Ellyn R. Weiss Judith Johnsrud Harnon & 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 Gail Phelps Gary L. Milhollin, Esq.

ANGRY 1815 Jefferson Street 245 W. Philadelphia Street Madison, WI 53711 York, Pennsylvania 17401

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l-In addition, service was made to Licensee by hand delivery to the office of Licensee's counsel at 1800 M. St., N.H., Washington, D.C. this 2nd day of October, 1981.

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