ML20031D290

First Set of Interrogatories Directed to Util.Certificate of Svc Encl

ML20031D290
Person / Time
Site:	Crane
Issue date:	10/08/1981
From:	Bradford L THREE MILE ISLAND ALERT
To:	METROPOLITAN EDISON CO.
References
NUDOCS 8110130215
Download: ML20031D290 (13)

Text

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UNITED STATES OF AMERICA O

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NUCLEAR REGULATORY COMMISSION y g.

Before the Atomic Safety and Licensting Board In the Matter of

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TMIA's FIRST SET OF INTERROGATORIES ADDRESSED TO LICENSEE

1. Has the Licensee, or anyone acting in your behalf, including any independent contractors, and including any member of the Penn State University-Capitol Campus faculty, conducted any investigation or review of test results to detect possible cheating or management integrity problems concerning any NRC or Licensee administered exam, other than the April 2and 3, 1981 " mock" SRO/R0 exams, the April 21-24, 1981 SRO/R0 exams, the Kelley Cat-T exam, the 1980 requalification exam, all make-up exams of the above-mentioned exams as well as the July 1979 make-up exam?

2. If so, by shat means do you identify such investigations or l

review of test. results?

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3. What individual requested or suggested that Licensee, or anyone acting in your behalf, including any independent contractor, l

investigate any incident of cheating on any NRC or Licensee

" mock" exam, or whether any such incident exits which may reflect upon management integrity, or review test results to detect possible incidents of cheating, including investigations into the April 2 and 3, 1981 " mock SRO/R0 exams, the April 21-24 1981 SRO/R0 exam, the Kelly Cat-T exam, the 1980 requalification

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exam, all make-up exams of the above-mentioned exams as well as the July-1979 make-up exam, as well as any investigation or review of test results which are the subject of question 1, above?

4.

For each person, state:

a. His name and address.

b. What he requested or suggested.

c. The date and place he made the request or suggestion,

d. For what reason he made the suggestion.

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e. What action was taken as a result of the request or suggestion?

f. Whether the request was written and if so, the name l

and address of theperson who has custody of it.

5. Who ordered or authorized any of these investigations or review of test results?

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6. For each person, state:

a.

His name and address.

b. What authoriaztion or order he gave.

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c. The time, date, and place he gave the authorization or order.

d. The name and address of each person to whom he gave the authoriaztion or order.

e.

The reason he gave the authorization or order.

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f. Whether he gave the authorization or order in writing i

and if so, the name and address of the person who has custody of it.

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7. If not already supplied to TMIA, atach a copy of each request suggestion, authorization or order t-the investigation or review or test resulta to your e

'r: to these interrogatories.

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8. For each person who conducted or was' engaged in the investigation i

or review or test results,-state:

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a. His name and address.

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b. His occupation and qualifications.

c. The name and address of his employer.

d. What duties or part he had in the investigation.

e. The number of hours he spent on the investigation or t

review of test results.

9. Was any person who conducted or was engaged in the investigation i

or review of test results your agent or employee?

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10. If so, for_each such person, state:

1 a.

His name, and. address.

b. His j ob title.

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11. Was any person who conducted or was engaged in the investigation I

or review of test results an indep'endent contractor?

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12. If so, for each such person, state:

a. His name and address.

~b. By what means he was contracted or employed.

c. The terms or his employment, including.the amount of l

compensation.

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d. The nature, extent, circumstances, and date of each

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prior employment of a similar nature in which he has i

been engaged by you.

13. Was any person who conducted or was engaged in the investigntion s or review or test results an expert?

14. If so, for each such person, state:

a.

His name, and address,

b. His field of specialization ~and qualifications therein.

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15. Did you, or anyone acting in your behalf, give instructions

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or review of test results?

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16. If so, for each' set of instructions, state:

a. The name of the person who gave them.

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b. The name of each person to whom they were given.

c. The time, date, and place they were given.

d. What instructions were given i

e. Whether they were given in writing or orally.

f. If given in writing, the name and address of the. person who has custody of them.

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17. Attach a copy of each set of instructions to your answerc j

to these interrogatories.

18. What was the date and time of each investigation or review 1

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5 of test results, including when commenced, when completed, and during what dates and hours such investiga6ons or reviews were made?

19. How many working hours were spent in making the investigations or review of test results?

20. State the itineraryfollowed in making the investigations or review of test resul ta, including the exact location where made and name of each person who conducted the investigations or review there.

21. Identify what test results were investigatied or reviewed.

22. Identify any other record, report, or memorandum reviewed during the course of the investigation or review of test results.

23. If not already supplied to TMIA, attach a copy of euch such record, report, or memorandum or your answers to these interrogatories?

24. Was any person interviewed or questioned in the course I

of the investigationsor review or test results by Licensee?

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25. If so for each person, state:

a. His name, address, or letter designation.

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b. The time, date, place he was interviewed.

c. The name of each person who interviewed or questioned him.

d. The name of each person who sat in on the interview or 4

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q'uestioning, and any statements made by that individual.

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e. For what reason or concerning what facts he was interviewed j

or questioned.

f. Any statements made by Licensee management or employees cr agents of Licensee to the intervicwee concerning t

I such interview, before or after such interview or questioning.

26. In making the investigations, were any statements obtained concerning any matter relevant to'this action?

27. If so, for each statement, state:

a. The name and address, or letter designation or the person who made it.

b. The name of the person who obtained it.

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c. The time, date, and place it was obtained.

d. Whether it was written, eound-recorded, or oral.

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If written or' sound-recorded, the name and address of the-e.

person who has custody or control of it.

f. If oral, the substance of it.

28. If not already supplied to TMIA, attach a copy of each wrie. ten statement to your answers to these interrogatories.

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29. In making _the investigations or review of test results, were any diagrams, charts, photographs, drawings, or other graphic representaticns made or o btained?

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30. A?ttach a copy of each such diagram, chart, photograph, drawing, or other graphic representation to your answers to these interrogatories.

31. Do you have custody or control of any object or substance, which is relevant to the subject matter of this action?

32. If so, describe each such object or substance.

33. Was any oral report made in connection with the investigations or review of test results?

34. If so, for each oral report, state:

The date and place it was made.

a.

b. The name of ich person who made it.

c. The name and address of each person who received or heard it.

d. The substance of it.

e. Whether any notes or record were made of it, and if so, the name and address of the person who has custody j

or control of such notes or record.

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35. Was any written report made in connection with the l

investigations or review of test results?

36. If so, for each written report, state:

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The date and place it was made.

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b. The name of each person who made it.

c.The name and address of each person who received it.

d. The subj ect matter covered.

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e. The name and address of each person who has custody or control of it.

37. If not already supplied to TMIA, attch a copy of each written report to your answers to these interrogatories.

38. If no oral or written report was made, describe the results 4

of the investigations or review of test results.

39. What was the total cost of each investigation or review of test results conducted?

40. Does Licensee havu reason to believe that any other exams,.other than the ones already dicussed in these interrogatories i

above, either for TMI-l or TMI-2, before or after the Unit 2 accident, should be scrutinized for possible cheating or irregularities or management integrity problems?

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41. If so, state what exams you believe should be scrutinized?

42. Were any Licensee employeesor agents, or former employees or agents, interviewed in the course of the NRC investigations into exam cheating incidents?

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43. If so, for each person, state:

a. His name, address, or letter designation.

b. The time, date, place he was interviewed.

c. The name of each person who interviewed or questioned him.

d. The name of each Licensee representative who sat in on the interview or questioning, and any statements made

• by that individual during the course of the interview or questioning.

e. Any statements made by Licensee management or employees or agents of Licensee to the intervieweeconcerning such interview, before or after such interview or questioning.

44. Was any sound recording made by you in the course of any NRC or Licensee investigation or review or test results.

45. If co, for each sound-recording, state:

a. The time, date, and place it was made.

b. What method of sound-recording was employed.

c. The name or description of the apparatus used.

d. The location in which such apparatus was placed.

e. The name and address or letter designation or each person whose conversation was listened to or recorded.

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f. The locaton of each such person at the time it was made.

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g. Wh'at was.being said c.d done by each such person at the time it was made.

h. The name of each person who made it.

1. For what reasons it was made.

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j. The name and address of each person who has custody or control of any record of it.

46. Did any person suggest that a representative of Licensee management sit in on any NRC investigation in the cheating incidents?

47. For each person, state:

a.His name and address.

b. What he requested or suggested.

c. The date and place he made the request or suggestion.

d.For what reason he made the suggestion.

e.What action was taken as a result of the request or suggestion.

48. Did any person authorize that a representative of Licensee madhement sit in on any NRC investigation into the cheating incidents?

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49. For each such person, state:

a.

His name and address,

b. What quthorization or order he gave.

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c. The time, date, and place he gave the quthYization or l

order.

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d. The name and address of each person to wnom he gave the authorization or order.

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j why a company or outside attorney was not chose. to sit-in on these interviews instead of Licensee management?

50. For each person who sat in on any NRC interview with respect to these cheating incidents, state:

a. His name and address.

b. His occupation and qualifications,

c. What part he had in the investigation.

51. Describe any statements, comments, or questions which NRC staff persons had concerning the propriety of Licensee management personnel sitting in on the NRC investigations into the cheating incidents.

52. Did any such Licensee management personnel make any statements to anyone questioned or interviewed by the NRC before the interview with respect to the interview, or during the interview?

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53. If so, for each statement, state:

aThe date and place it was made.

b. The name of each person who made it.

c. The name and address of each person who received or heard it.

d. The substance of it.

e. Whether any notes or record were made of it, and if so,.

the name and address of the person who has custody or control of such notes or record.

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Dated: October 8, 1981

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Louise Bradford

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TMIA

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4 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD i

l In the Matter of

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l METROPOLITAN EDISON COMPANY )

Docket No. 50-289

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(Restart)

(Three Mile Island Nuclear

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Station, Unit No. 1)

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t CERTIFICATE OF SERVICE I hereby certify that copies of the' attached TMIA'S 1

FIRST SET OF INTERROGATORIES ADDRESSED TO LICENSEE were served on the parties on the service list below, on or before October 8,1981, by hand or by deposit in the U.S. Mail, first 2

class, postage prepaid.

u,d un Louise Bradford 4

TMIA Docketing ano Service Branch Office of the Secretary c

U.S. Nuclear Regulatory Commission Washin gron, D.C.

20555 George F. Trowbridge, Esq.

Shaw, Pittman, Potts & Trowbridge 1800 M St. M.W.

Washington, D.C. 20006 i

l Ms. Marj orie M. Aamodt R.D. #5 l

Coatesville, PA 19320 t

James A. Tourtellotte, Esq.

Office of the Executive Legal Director U.S. Nuclear Regulatory Commission Washington, D.C.

20555 Mr. John Clewett 1324 North-Capitol St.

Washington, D.C.

20055 l

Mr. Robert W. Adler Assistant Attorney General 505 Executive House l

P.O. Box 2357 l

Harrisburg, PA 17120 I

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