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Category:LEGAL TRANSCRIPTS & ORDERS & PLEADINGS
MONTHYEARML20210B8491999-07-21021 July 1999 Exemption from Certain Requirements of 10CFR50.54(w),for Three Mile Island Nuclear Station Unit 2 to Reduce Amount of Insurance for Unit to $50 Million for Onsite Property Damage Coverage ML20206D4141999-04-20020 April 1999 Exemption from Requirements of 10CFR50,App R,Section III.G.2 Re Enclosure of Cable & Equipment & Associated non-safety Related Circuits of One Redundant Train in Fire Barrier Having 1-hour Rating ML20206T7211999-02-11011 February 1999 Memorandum & Order (CLI-99-02).* Denies C George Request for Intervention & Dismisses Subpart M License Transfer Proceeding.With Certificate of Svc.Served on 990211 ML20198A5111998-12-11011 December 1998 Comment Opposing Proposed Rule 10CFR50.65 Re Requirements for Monitoring Effectiveness of Maintenance at Nuclear Power Plants.Proposed Rulemaking Details Collaborative Efforts in That Rule Interjects Change ML20154G2941998-09-17017 September 1998 Transcript of 980917 Public Meeting in Rockville,Md Re License Transfer of TMI-1 from Gpu Nuclear,Inc to Amergen. Pp 1-41 ML20199J0121997-11-20020 November 1997 Comment on Pr 10CFR50 Re Financial Assurance Requirements for Decommisioning Nuclear Power Reactors.Three Mile Island Alert Invokes Comments of P Bradford,Former NRC Member ML20148R7581997-06-30030 June 1997 Comment on NRC Proposed Bulletin 96-001,suppl 1, Control Rod Insertion Problems. Licensee References Proposed Generic Communication, Control Rod Insertion, & Ltrs & 961022 from B&W Owners Group ML20078H0431995-02-0101 February 1995 Comment Opposing Proposed Rule 10CFR50 Re Shutdown & Lowpower Operations for Nuclear Reactors ML20077E8231994-12-0808 December 1994 Comment Supporting Proposed Rules 10CFR2,51 & 54 Re Rev to NRC NPP License Renewal Rule ML20149E2021994-04-20020 April 1994 R Gary Statement Re 10 Mile Rule Under Director'S Decision DD-94-03,dtd 940331 for Tmi.Urges Commissioners to Engage in Reconsideration of Author Petition ML20065Q0671994-04-0707 April 1994 Principal Deficiencies in Director'S Decision 94-03 Re Pica Request Under 10CFR2.206 ML20058A5491993-11-17017 November 1993 Exemption from Requirements in 10CFR50.120 to Establish, Implement & Maintain Training Programs,Using Sys Approach to Training,For Catorgories of Personnel Listed in 10CFR50.120 ML20059J5171993-09-30030 September 1993 Transcript of 930923 Meeting of Advisory Panel for Decontamination of TMI-2 in Harrisburg,Pa.Pp 1-130.Related Documentation Encl ML20065J3461992-12-30030 December 1992 Responds to Petition of R Gary Alleging Discrepancies in RERP for Dauphin County,Pa ML20065J3731992-12-18018 December 1992 Affidavit of Gj Giangi Responding to of R Gary Requesting Action by NRC Per 10CFR2.206 ML20198E5581992-12-0101 December 1992 Transcript of Briefing by TMI-2 Advisory Panel on 921201 in Rockville,Md ML20210D7291992-06-15015 June 1992 Exemption from Requirements of 10CFR70.24 Re Criticality Accident Requirements for SNM Storage Areas at Facility Containing U Enriched to Less than 3% in U-235 Isotope ML20079E2181991-09-30030 September 1991 Submits Comments on NRC Proposed Resolution of Generic Issue 23, Reactor Coolant Pump Seal Failure. Informs That Util Endorses Comments Submitted by NUMARC ML20066J3031991-01-28028 January 1991 Comment Supporting SECY-90-347, Regulatory Impact Survey Rept ML20059P0531990-10-15015 October 1990 Comment Opposing Proposed Rules 10CFR2,50 & 54 Re Nuclear Power Plant License Renewal ML20059N5941990-10-0404 October 1990 Transcript of 900928 Public Meeting in Rockville,Md Re Studies of Cancer in Populations Near Nuclear Facilities, Including TMI ML20055F4411990-06-28028 June 1990 Comment Supporting Petition for Rulemaking PRM-50-55 Re Revs to FSAR ML20248J1891989-10-0606 October 1989 Order.* Grants Intervenors 891004 Motion for Permission for Opportunity to Respond to Staff Correspondence.Response Requested No Later That 891020.W/Certificate of Svc.Served on 891006 ML20248J1881989-10-0303 October 1989 Motion for Permission for Opportunity to Respond to Staff Correspondence in Response to Board Order of 890913.* Svc List Encl ML20248J0301989-09-29029 September 1989 NRC Staff Response to Appeal Board Order.* Matters Evaluated in Environ Assessment Involved Subjs Known by Parties During Proceeding & Appear in Hearing Record & Reflect Board Final Initial Decision LBP-89-7.W/Certificate of Svc ML20247E9181989-09-13013 September 1989 Order.* Requests NRC to Explain Purpose of 890911 Fr Notice on Proposed Amend to Applicant License,Revising Tech Specs Re Disposal of Accident Generated Water & Effects on ASLB Findings,By 890929.W/Certificate of Svc.Served on 890913 ML20247G0361989-07-26026 July 1989 Transcript of Oral Argument on 890726 in Bethesda,Md Re Disposal of accident-generated Water.Pp 1-65.Supporting Info Encl ML20247B7781989-07-18018 July 1989 Certificate of Svc.* Certifies Svc of Encl Gpu 890607 & 0628 Ltrs to NRC & Commonwealth of Pa,Respectively.W/Svc List ML20245D3651989-06-20020 June 1989 Notice of Oral Argument.* Oral Argument on Appeal of Susquehanna Valley Alliance & TMI Alert from ASLB 890202 Initial Decision Authorizing OL Amend,Will Be Heard on 890726 in Bethesda,Md.W/Certificate of Svc.Served on 890620 ML20245A5621989-06-14014 June 1989 Order.* Advises That Oral Argument on Appeal of Susquehanna Valley Alliance & TMI Alert from Board 890202 Initial Decision LBP-89-07 Authorizing OL Amend Will Be Heard on 890726 in Bethesda,Md.W/Certificate of Svc.Served on 890614 ML20247F3151989-05-22022 May 1989 NRC Staff Response to Appeal by Joint Intervenors Susquehanna Valley Alliance/Tmi Alert.* Appeal Should Be Denied Based on Failure to Identify Errors in Fact & Law Subj to Appeal.W/Certificate of Svc ML20246Q2971989-05-15015 May 1989 Comment Opposing Proposed Rule 10CFR50 Re Ensuring Effectiveness of Maint Programs for Nuclear Power Plants ML20246J6081989-05-12012 May 1989 Licensee Brief in Reply to Joint Intervenors Appeal from Final Initial Decision.* ASLB 890203 Final Initial Decision LBP-89-07 Re Deleting Prohibition on Disposal of accident- Generated Water Should Be Affirmed.W/Certificate of Svc ML20247D2761989-04-20020 April 1989 Transcript of 890420 Briefing in Rockville,Md on Status of TMI-2 Cleanup Activities.Pp 1-51.Related Info Encl ML20244C0361989-04-13013 April 1989 Order.* Commission Finds That ASLB Decision Resolving All Relevant Matters in Favor of Licensee & Granting Application for OL Amend,Should Become Effective Immediately.Certificate of Svc Encl.Served on 890413 ML20245A8381989-04-13013 April 1989 Transcript of Advisory Panel for Decontamination of TMI-2 890413 Meeting in Harrisburg,Pa.Pp 1-79.Supporting Info Encl ML20245A2961989-04-13013 April 1989 Transcript of 890413 Meeting in Rockville,Md Re Affirmation/Discussion & Vote ML20248H1811989-04-0606 April 1989 Valley Alliance/Tmi Alert Motion for Leave to File Appeal Brief out-of-time.* W/Certificate of Svc.Served on 890411.Granted for Aslab on 890410 ML20248G0151989-04-0606 April 1989 Valley Alliance/Tmi Alert Motion for Leave to File Appeal Brief out-of-time.* Requests to File Appeal Brief 1 Day Late Due to Person Typing Document Having Schedule Problems ML20248G0261989-04-0606 April 1989 Susguehanna Valley Alliance/Tmi Alert Brief in Support of Notification to File Appeal & Request for Oral Argument Re Appeal.* Certificate of Svc Encl ML20248D7211989-04-0404 April 1989 Memorandum & Order.* Intervenors Application for Stay Denied Due to Failure to Lack of Demonstrated Irreparable Injury & Any Showing of Certainty That Intervenors Will Prevail on Merits of Appeal.W/Certificate of Svc.Served on 890404 ML20247A4671989-03-23023 March 1989 Correction Notice.* Advises That Date of 891203 Appearing in Text of Commission 890322 Order Incorrect.Date Should Be 871203.Certificate of Svc Encl.Served on 890323 ML20246M2611989-03-22022 March 1989 Order.* Advises That Commission Currently Considering Question of Effectiveness,Pending Appellate Review of Final Initial Decision in Case Issued by ASLB in LBP-89-07. Certificate of Svc Encl.Served on 890322 ML20236D3821989-03-16016 March 1989 Valley Alliance & TMI Alert Motion for Extension of Time to File Brief in Support of Request for Appeal in Matter of 2.3 Million Gallons Of....* Certificate of Svc Encl.Served on 890316.Granted for Aslab on 890316 ML20236D3121989-03-15015 March 1989 Licensee Answer to Joint Intervenors Motion for Extension of Time to File Brief on Appeal.* Motion Opposed Based on Failure to Demonstrate Good Cause.W/Certificate of Svc ML20236D2901989-03-11011 March 1989 Valley Alliance/Tmi Alert Motion for Extension of Time to File Brief in Support of Request for Appeal in Matter of Disposal of 2.3 Million Gallons of Radioactive Water at Tmi,Unit 2.* Svc List Encl ML20236A3761989-03-0808 March 1989 Licensee Answer Opposing Joint Intervenors Motion for Stay.* Stay of Licensing Board Decision Pending Appeal Unwarranted Under NRC Stds.Stay Could Delay Safe,Expeditious Cleanup of Facility.Certificate of Svc Encl ML20236C2441989-03-0808 March 1989 NRC Staff Response in Opposition to Application for Stay Filed by Joint Intervenors.* Application for Stay of Effectiveness of Final Initial Decision LBP-89-07,dtd 890202 Should Be Denied.W/Certificate of Svc ML20235V2641989-03-0202 March 1989 Notice of Aslab Reconstitution.* TS Moore,Chairman,Cn Kohl & Ha Wilber,Members.Served on 890303.W/Certificate of Svc ML20235V2161989-02-25025 February 1989 Changes & Corrections to Susquehanna Valley Alliance/Three Mile Island Alert Documents Submitted on 890221.* Certificate of Svc Encl 1999-07-21
[Table view] Category:OTHER LEGAL DOCUMENT
MONTHYEARML20149E2021994-04-20020 April 1994 R Gary Statement Re 10 Mile Rule Under Director'S Decision DD-94-03,dtd 940331 for Tmi.Urges Commissioners to Engage in Reconsideration of Author Petition ML20065Q0671994-04-0707 April 1994 Principal Deficiencies in Director'S Decision 94-03 Re Pica Request Under 10CFR2.206 ML20247B7781989-07-18018 July 1989 Certificate of Svc.* Certifies Svc of Encl Gpu 890607 & 0628 Ltrs to NRC & Commonwealth of Pa,Respectively.W/Svc List ML20245D3651989-06-20020 June 1989 Notice of Oral Argument.* Oral Argument on Appeal of Susquehanna Valley Alliance & TMI Alert from ASLB 890202 Initial Decision Authorizing OL Amend,Will Be Heard on 890726 in Bethesda,Md.W/Certificate of Svc.Served on 890620 ML20247A4671989-03-23023 March 1989 Correction Notice.* Advises That Date of 891203 Appearing in Text of Commission 890322 Order Incorrect.Date Should Be 871203.Certificate of Svc Encl.Served on 890323 ML20235V2641989-03-0202 March 1989 Notice of Aslab Reconstitution.* TS Moore,Chairman,Cn Kohl & Ha Wilber,Members.Served on 890303.W/Certificate of Svc ML20235V2161989-02-25025 February 1989 Changes & Corrections to Susquehanna Valley Alliance/Three Mile Island Alert Documents Submitted on 890221.* Certificate of Svc Encl ML20235N2241989-02-21021 February 1989 Licensee Comments on Immediate Effectiveness.* Requests That Commission Speak & Approve Proposed accident-generated Water Disposal Method by Making Licensing Board Decision Effective Immediately.Certificate of Svc Encl ML20235N1431989-02-20020 February 1989 Valley Alliance/Three Mile Island Alert Comments to Commission Re Whether Decision of 890203 Should Await Administrative Appellate Review.* Motion for Stay Permitting Appeal to Be Heard Prior to Amend Being Granted Encl ML20235N1891989-02-20020 February 1989 Response of Cw Huver to Final Initial Decision of ASLB in Matter of Disposal of Accident Generated Water from TMI-2 on Behalf of Susquehanna Valley Alliance.* ML20235N1371989-02-20020 February 1989 Notice to Appeal Final Initial Decision Concerning Request for Amend to Dispose of Accident Generated Water by Gpu.* Notice Will Be Followed by Brief Supporting Joint Intervenor Position on Appeal.Notification of Address Change Encl ML20155H4401988-10-11011 October 1988 Valley Alliance/Tmi Alert Submittal of Expert Testimony.* Forwards Testimony of Kz Morgan,R Piccioni & Cw Huver.Related Correspondence ML20155G9441988-10-0606 October 1988 Fr Notice (Schedule of Hearings).* ASLB Will Hold Limited Appearance Session on 881103 in Lancaster,Pa.Written Statements of Intention to Appear May Be Filed W/Board Prior to 881028.Served on 881007 ML20155H0031988-10-0404 October 1988 Notification of Parties as to Subj Matter of R Piccioni Testimony.* Joint Intervenors Suppls Interrogatory Responses Re Witness,R Piccioni Testimony on Contentions 2 & 3. Certificate of Svc Encl.Related Correspondence ML20154P4691988-09-27027 September 1988 Fr Notice (Schedule of Hearings).* Public Hearings Scheduled for Listed Dates,Per 880825 Order.Limited Appearance Statements May Be Filed W/Aslb Prior to 881028.Served on 880928 ML20151N5911988-07-29029 July 1988 Notice of Reconstitution of Board.* Pb Bloch Appointed Administrative Judge in Place of Sj Wolfe.Served on 880801 ML20154E3001988-05-12012 May 1988 Erratum to Licensee Motion for Summary Disposition of Contentions 4b (in part),4c & 4d.* Stated Parenthetical Entry Should Be Deleted from Licensee 880509 Motion,Page 7. Certificate of Svc Encl ML20154E3521988-05-11011 May 1988 Memorandum (Memorializing Conference Call).* Discusses 880511 Telcon in Which Board Granted NRC Request for Extension of Time Until 880523 to File Motion for Summary Disposition.Served on 880512 ML20150A9441988-03-14014 March 1988 Notice of Appearance.* RP Mather Will Enter Appearance in Proceeding on Behalf of Commonwealth of Pa.Certificate of Svc Encl ML20237E4791987-12-14014 December 1987 Notification of Temporary Change of Address.* Author Can Be Reached at Listed Address from 871216 Through 880106 as Representative for Susquehanna Valley Alliance & TMI Alert ML20236N9181987-11-0505 November 1987 Settlement Agreement.* Settlement Will Constitute Bar to Any Future NRC Proceeding or Action Involving Same Claims & Allegations Raised in NRC 850812 Notice of Violation ML20235F4681987-09-22022 September 1987 Notice of Deposition of AB Beach.* Requests AB Beach Appearance in Washington,Dc on 871005 to Give Testimony by Deposition on Oral Exam Re Allegations by R Parks Concerning TMI-2.W/Certificate of Svc.Related Correspondence ML20235F4271987-09-18018 September 1987 Notice of Deposition.* Notice for D Feinberg to Give Testimony by Deposition Upon Oral Exam on 870928 Re R Parks Allegations Concerning TMI-2 & Util.W/Certificate of Svc. Related Correspondence ML20235F2861987-09-18018 September 1987 Util Supplemental Memorandum.* Util Confirmed That Substantial Renumerations Made Annually to All TMI-1 Licensed Personnel Which Husted Forfeited Due to Termination of License.W/Certificate of Svc ML20235B4341987-09-15015 September 1987 Establishment of Aslb.* Board Comprised of Sj Wolfe, Go Bright & Oh Paris.Served on 870921 ML20234D2771987-09-14014 September 1987 Notice of Appearance in Proceeding.Certificate of Svc Encl ML20238E4671987-09-0808 September 1987 Notice of Appearance.* Advises That Author Will Represent TMI Alert,Inc at Oral Argument Scheduled for 870909. Certificate of Svc Encl ML20238A5611987-08-18018 August 1987 Notice of Oral Argument.* Argument on Appeal of C Husted from 870402 Initial Decision Will Be Heard on 870909 in Bethesda,Md,Per Aslab 870811 Order.Served on 870819 ML20236P0661987-08-0404 August 1987 Notice of Deposition of Hl Hofmann.* Notice of 870820 Deposition in San Francisco,Ca Re Matters Set Forth in Paragraphs 2-5 of Encl 860813 Prehearing Order.W/Certificate of Svc.Related Correspondence ML20236E6831987-07-28028 July 1987 Notice of Deposition of Rd Parks.* Deposition Will Be Taken on 870818 in San Francisco,Ca Re Allegations & Activities Related to TMI-2.Certificate of Svc Encl.Related Correspondence ML20235Y8601987-07-20020 July 1987 Comments of Numerous Employees on Recommended Decision.* Numerous Employees Include 25 Present or Former TMI-2 Employees Commenting on Inquiry Into Facility Leak Rate Data Falsification.Certificate of Svc Encl ML20216D0881987-06-22022 June 1987 Inquiry Into TMI Unit 2 Leak Rate Data Falsification.* Notice of Reconstitution of ASLB Appointing Sj Wolfe in Place of Jl Kelley.Served on 870623 ML20215D5761987-06-10010 June 1987 Affirmation.* Pr Clark Sworn Statement Indicating That Gpu Subscribes to Reasons Stated in Response for Denying or Not Being Able to Admit or Deny Particular Requests.W/ Certificate of Svc.Related Correspondence ML20214P2911987-06-0101 June 1987 Request for Clarification & Mod.* in Appearances Section of Board Recommended Decision, Applicants Should Be Changed to Numerous Employees & Listed Individuals Be Added Following Moeller Name.Certificate of Svc Encl ML20214S0271987-06-0101 June 1987 Notice of Deposition of Rd Parks.* Notice of Deposition for Rd Parks to Appear in Newport Beach,Ca on 870622 to Give Testimony by Deposition Upon Oral Exam Re Investigations of Allegations.W/Certificate of Svc.Related Correspondence ML20214P0661987-05-29029 May 1987 Notice of Deposition of Rd Parks.* Parks Requested to Appear at Ofcs of Thelen,Marrin,Johnson & Bridges in Newport Beach, CA to Testify Re Allegations & Activities Concerning Plant. Certificate of Svc Encl.Related Correspondence ML20214N2551987-05-26026 May 1987 Notice of Deposition of AB Beach.* Instructs AB Beach to Testify Re Knowledge of Allegations Made by R Parks Re Util, Facility,Bechtel Employees & NRC Investigation of Allegations.W/Certificate of Svc.Related Correspondence ML20215K9941987-04-30030 April 1987 Notice of Appeal.* Appeal of ASLB 870402 Initial Decision Requested.Certificate of Svc Encl ML20209E9051987-04-23023 April 1987 Notice of Withdrawal of Appearance in Proceeding.Certificate of Svc Encl ML20206T0501987-04-20020 April 1987 Assignment of Aslab.* as Rosenthal,Chairman, & TS Moore & Ha Wilber,Members.Served on 870421 ML20206S8011987-04-17017 April 1987 Notice of Appeal of C Husted from Administrative Law Judge 870402 Initial Decision.W/Certificate of Svc ML20205F2721987-03-24024 March 1987 Certificate of Svc.* Certifies That Comments of Numerous Employees in Response to ASLB 870202 Request & Order Served on Mm Aamodt on 870302 ML20204B8011987-03-19019 March 1987 Notice of Deposition of Rc Arnold.* Arnold Given Notice & Requested to Appear in Gaithersburg,Md on 870407 to Give Testimony Re Issues Discussed in 860813 Memorandum & Order. Certificate of Svc Encl.Related Correspondence ML20204B6831987-03-19019 March 1987 Notice of Deposition of Jj Barton.* Barton Given Notice & Requested to Appear in Gaithersburg,Md on 870407 to Give Testimony Re Issues Discussed in 860813 Memorandum & Order Following Prehearing Conference.Related Correspondence ML20212D0721987-02-27027 February 1987 Clarification Re Numerous Employees Memorandum of Law.* Discusses Numerous Employees 870123 Position That Surveillance & Administrative Procedures Were Not Legal Requirements.Certificate of Svc Encl.Related Correspondence ML20212N5121987-02-22022 February 1987 Notice of Withdrawal of Appearance.* Certificate of Svc Encl ML20212N4991987-02-22022 February 1987 Notice of Withdrawal of Appearance.* Certificate of Svc Encl ML20212D0561987-02-20020 February 1987 Errata to Aamodt Reply Findings to Those of Other Parties (Submitted in Form of Recommended Decision).* W/Certificate of Svc ML20212D0201987-02-17017 February 1987 Aamodt Reply Findings to Those of Other Parties (Submitted in Form of Recommended Decision).* W/Certification of Svc ML20211A9351987-02-16016 February 1987 Comments of Numerous Employees in Response to ASLB 870202 Request & Order.* Defendant Memorandum of Law Supporting Motion to Dismiss Indictment & Certificate of Svc Encl 1994-04-07
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. 4 q* tbtKETED UsuM' UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION &g 7g gg) g6
,s1 BEFORE THE ATOMIC SAFETY AND LICENSING BOARD ;E?,2 DEh i[j}yf In the Matter of )
)
METROPOLITAN EDISON COMPANY ) Docket No. 50-289
)
(Three Mile Island Nuclear )
Station, Unit No. 1) ) g UCS RESPONSE TO BOARD ORDER ON HPI QUESTIONS AND ANSWERS Introduction By its Memorandum and Order dated December 16, 1981, the Board adopted as its order the proposal by Licensee in its letter of December 16, 1981, relative to the High Pressure Injection (HPI) questions and answers on the TMI-1 operator license examinations. The portion of the Licensee's letter applicable s s to this filing is item number 3 beginning on page 2 of the December 16, 1981, letter:
On or before December 24, 1981, any party may file with the Special Master and the Board comments on this proposal, on the significance of previously distributed answers to the HPI question and on the relevance of such answers to the reopened hearing or to any other issues in the proceeding.
Such comments may include a request by any party that the record of the hearing on non-cheating issues-be reopened for receipt in evidence of the above listed documents and/or that witnesses be called to address such documents.
- Such comments shall be hand delivered to the Board, the NRC staff, Licensee, UCS and Sholly by those parties having counsel or offices in the District of Columbia metropolitan area. Other filings may be made by regular mail on or before December 24, 1981.
The "above listed documents" referred to by the Licensee are:
- 1. The NRC answer keys (including any revisions) to the HPI questions; O$dOh% 0\
PDR
T
- 2. The answers of all examinees to the HPI questions; and
- 3. Licensee's Emergency Procedures relevant to the question of throttling or terminating HPI. 1 On December 17, 1981, Licensee distributed to the Board and a
parties the following emergency procedures: EP 1202-6B, Revision 7, dated 03/19/81; EP 1202-6C, Revision 7, dated 03/31/81; EP 1202-2, Revision 7, dated 06/29/81; and EP 1202-5, Revision 13, dated 08/11/81.
UCS's Comments and Requests for Additional Information and to Reopen the Record UCS concludes that the . operating license exam questions on emergency operating procedures, the answers to those questions by all examinees, the NRC answer keys to those questions, and the Licensce's emergency procedures relevant to those questions are significant and relevant to UCS Contention No. 10. Therefore, UCS requests that the record be reopened to receive this information into evidence.
However, UCS does not believe that the documents previously distributed by the Staff and Licensee represent the complete set of all such information. Furthermore, we question whether the versions of the emergency procedures distributed by the Licensee are the appropriate revisions. The issues of significance, relevance, completeness, and appropriateness are discussed more fully below.
l l
Completeness The Staff has distributed'information only on question E3 on the "A" reactor operator examination, question E6 on the "B" reactor operator examination, and the oral examinations. These three examinations were administered in October 1981. UCS believes that, at a minimum, the identical scope of information concerning the written and oral examinations administered in April 1981 should be distributed and received into evidence. For example, question F.5.c on the "A" reactor operation examination administered in April 1981 was as follows: "Under what conditions may HPI be throttled after ESAS initiation during a LOCA?" 'Nhile -bot identical to the wording of questions E3 and E6 on the October exams, perusal of the answer key and the grading of the answers to geustion F.5.c on the April exam shows that the questions are, for a l'1 practical purposes, identical.
In addition, UCS has been served with no information concerning the content or results of the oral examinations administered in April 1981, all of which have a bearing on the adequacy of operator training and the validity of the operator examinations themselves, as discussed below.
Therefore, UCS requests that the relevant question (s), answers of all. examinees, the NRC answer keys, and the relevant oral examinations administered in April 1981 be served on the Board and the parties.
We also belive that the Board or the Special Master should inquire into the reasons for: 1) Shifting the HPI question from Category F, " Standard and Emergency Operating Procedures," on the April exam to Category E, " Safety and Emergency Systems," on the October exam and 2) changing the value of the question from 1 out of
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14 points on the April exam to 3 out of 13 points on the October exam.
A brief review of the exams shows that if the HPI question had remained in Category F (the appropriate category in UCS's view) on the October exam, the results of the exam would have changed from passing to failing for at least one examinee (e.g. individual "AA") regardless of whether the point value was 1 or 3. We also believe that repeating f
a question from the April exam in the OctobLc exam casts doubt on the "alidity of the re-exam. Furthermore, considering the TMI-2 accident, the subsequent operator training, and the fact that the identical question was asked on two sequential exams, we believe that any individual who still does not know under what conditions it is permissible to throttle HPI is not qualified to be a reactor operator or a senior reactor operator regardless of his grade on the exam.
Appropriateness UCS questions whether the versions of the emergency procedures distributed by the Licensee are the appropriate versions. We believe that the versions of the Energency Procedures that should be distributed to the Board and parties are the approved versions in l effect at the time the exam was administered and the latest approved ver'sions. The former is necessary to judge whether the answers are correct and the latter is necessary to judge the extent to which the training and operator knowledge conform to the actual emergency l
l procedures now in effect for TMI-1.
EP 1202-6B', Revision 7, dated 03/19/81 is already in evidence as Licensee Exhibit 48. Licensee should specify whether this is the
latest' version and, if not, the latest version should be distributed and received into evidence.
EP 1202-6C, Revision 7, dated 03/31/81, EP 1202-2, Revision 7, dated 06/29/81, and EP 1202-5, Revision 13, dated 08/11/81 are all marked "For Infcirmation Only" (which does not appear on Licensee Exhibit 48) and all lack the stamp "Rev. Review Book Controlled Copy" (which does appear on Licensee Exhibit 48). EP 1202-6C also lacks the stamp " Controlled Copy for Use in Unit 1 Only" which appears on the other three emergency procedures distributed by Licensee.
Furthermore, EP 1202-2 and EP 1202-5 postdate the April 1981 exams.
Therefore, UCS requests that, for each emergency procedure which Licensee believes is relevant t$ throttling or termination of HPI, the version (s) that was (were) fully approved at the time the April and October 1981 exams were administered and the latest fully approved version be distributed and received into evidence. It is possible that from one to three versions of each relevant emergency procedure are the appropriate versions to be distributed aand received into
. evidence.
Relevance The material discussed above is relevant to UCS Contention No.
- 10. In essence, UCS argued that a lesson learned from the TMI-2 accident is that safety systems at TMI-l should be designed so that the operator can not terminate operation of a safety system until its safety function' has been completed. Licensee and Staff argued, in essence, that the operator can be relied upon not to terminate prematurely the operation of a safety system, in part, because of the m -
_ _ _ _ _ . . _ _ _ _ _ _ _ _ _ _ - . _ _ _ _ _ _ . _ _ _ _ _ -..__-_J
add iti'onal training given since the TMI-2 accident. Licensee and Staff also asserted that operators would be capable of assessing unforeseen accident sequences and taking correct action.
UCS believes that the information discussed above is relevant because it demonstrates that the arguments advanced by the Licensee and the Staff are not valid.
f Significance The significance of the HPI questions, answers, answer keys, oral examination notes, and emergency procedures is that they provide the most valid basis available. for"judgirig the adequacy of the operators' knowledge'concerning safe operation of TMI-1. The record to date only contains evidence which is primarily of a hypothetical or theoretical nature concerning the extent to which' operators will perform correctly during future accidents at TMI-1. Whether the actions taken since the TMI-2 accident are sufficient to provide reasonable assurance- that operator action will be correct during f.2ture accidents is an important issue in this proceeding and the best available evidence should be in the record.
UCS believes that the HPI documents in question raise a "significant safety (or environmental) issue" which would have led to "a different result . . . had the newly proffered material been considered initially." Pacific Gas and Electric Company (Diablo Canyon Nuclear Power Plants, Units 1 and 2), ALAB-598, 11 NRC 876, 879 (1980). The premature termination of HPI during the TMI-2 accident was unquestionnably a majot factor in the accident. The TMI-2 accident has been the subject of intensive study by the Licensee and
________m___m____ _ _ _ _ _ _ _ _ . _ _ _ - - - - - - - - . _ _ _ . - - . _ . - - - - _ - _ _ - _ _ - _ _ - - - - - - - _ _ _ - - - - - - - - --
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others' for the last three years. Operator training conducted since the accident has emphasized the conditions which must be achieved prior to throttling or terminating HPI. An identical question was asked on both the April and October 1981 examinations concerning this subject. The exam results indicate'that some candidates for Reactor Operator and Senior Reactor Operator licenses still do not know under f what conditions it is permissible to throttle or terminate HPI. The signilicance of the HPI documents in question is that they would change the decision on UCS Contention No. 10. Furthermore, this demonstrates beyond reasonable doubt the futility of information hoping that operators will be able to analyze and take proper corrective action during unforeseen a'ccident sequences. Thus, one of the principal arguments advanced by the Licensee and the Staff against the TMI-1 design advocated by UCS is shown to be without merit.
Accordingly, the record must be reopened to receive the HPI documents identifed above.
December 24, 1981 RESPECTFULLY SUBMITTED, DATED:
[ W f d//a ,
Ellyf R. Weiss f /
AM&s WilliameST Jo'rdan , III Harmon and Weiss 1725 I Street, N.W.
Suite 506 Washington, D.C. 20006 Counsel for UCS l
l
- l. _ _ _ __ - _ _ . . _ _ _ _ - - , _ _ _ _ _ , _ . _ . , _ _ - , _ . _ _
h{f ,
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION '81 DEC 28 All :56 BEFORE THE ATOMIC SAFETY AND LICENNSING BOARD- . '
NChiiid[kI5fbCE i;RAICH In the Matter of )
) -
METROPOLITAN EDISON COMPANY ) Docket No. 50-289 ,
) , (Restart) ~
(Three Mile Island Nuclear
) .
Station, Unit No. 1) ) x s
CERTIFICATE OF SERVICE I hereby certify that copies of "UCS RSSPONSE'TO BOARD. ORDER ON )?
HPI QUESTIONS AND ANSWERS" have been served on the .following -persons by deposit in the United States mail, first clas's postage prepaid this -
24th day of December 1981. .
a
! ,~. . ; .
Nunzio Palladino, Chairman *
- D r ._Wa l,te r' H c J,o r d a n '
U. S.. Nuclear Regulatory Atomicf$afety and Lic,ensing Board Panel
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Commission .
Washing ton , D.C. 20555 881 We'st Ou6er Drive Oak Ridge, Tennessee'37830- -
Victor Gilinsky, Commissioner _
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U. S. Nuclear Regulatory **Dr. Linda WQctittle Commission Atomic Sifety;tnd Licensing -
Washing ton , D .C . 20555 . Board Panel' 5000LHormitage Drive Peter Bradford, Commissioner Raleigh,; North Carolina 27612 U. S. Nuclear Regulatory ~Y
,,s h ' l - p Commission *
- Pro fessor Gary '.L.'lMi,lhollin -
Washington D.C. 20555 1815 Jefferson Streete2 ,
Madison, Wisconsip 53711 s John Ahearne, Commissioner (Tj Judge Gary J. Edles,j,Chaidman U. S. Nuclear Regulatory ~
Commission Atomic Safety an6 LicCnsing r T'
Washington, D.C. 20555 Appeal Board %F U. S. Nuclear Regulatory p" s s
Thomas Roberts, Commissioner Commission '_ - w ; ; w ,.
U. S. Nuclear Regulatory Washington, D.C. 20555 ff .y '
Commission 7 ,
Washington, D.C. 20555 Judge John H. Buck- : ' - '
,. J Atomic Safety and Lic,encling. -
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- Ivan W. Smith, Chairman Appeal Board Panel 4 --
s Atomic Safety and Licensing U. S. Nuclear Regulatory .; -
Board Panel Commission g .
U. S. Nuclear Regulatory Washington D.C. 20555 ,.
Commission .
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Judge Christine N. Kohl' .i # -
Washington, D.C. 20555 Atomic Safety and Licensi.ng
~ e Appeal Board Panel , '12 '
U. S. Nuclear Regulatory .
. Commission 'l ;;
/4.R x Washington, D.C. 20555
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6304 Bradford Terrace
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Deard Pane d Philadelphia,
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. ,' (U h %? Nuclear-RegOlatory
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'N "Cosmissio'n Ms. Gail B. Phelps
- i Washington D'C. 20555 . < 245LWes't Philadelphia Street
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'- M York', Pennsylvania 17404
, ' ' ' IMr s . < Ma r j or ic- Elmod t" 'M O 1" Lw- TR.D. 95 s > MG Robet;t O. Pollard a [ Co a t sv ille ,j Pe nn .;ylv ani a l.19320 's,,1609 Mont'phlier Street 1, ,
~'" Ba l t imo're , Maryland 31218
- Robert"Adlet ,j Es,q. .? J [, _. Q. , .
Assistant-Attorney General tMr . Steven ..C. 3 holly
'505 Executine' Hor.se'C ' Union of Cpnce'rned Scientists i P.O.J. Box ~2,357 1725.Ey'eN Gte, N.W., Suite 601
, Harrist?brg N ennsylvania 11120 Wash i'ngon ,) D. C . 20006
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! Louise Biadfof:d
- MThree Mile Island Alert ';
Office of Executive Legal s
, ; 325 Pef Rer., St;rcet Director
"~ Harrisburg, Perinsy.lvania 17102- , 'U m S . Nuclear Regulatory
,v' 9, Commission, '
j cy ,
Walter W. CohenfEsq N Washin D.C. 20555
- c Of fice 'of Const4ner' Advo~cated s
[ T [ gton, 's e 1425 Strawberry bquare' *Gerge F. Trowbridge, Esq.
Harrisburg, P annsylvani:i l'U 27 s 'Sh hw , .1)i ttman , Potts &
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Jordan D.? Cunnirigham, E s q . ' ' - 180'O ' M St'r e e t , N.W.
- Washington, D.C. 20036
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]; . ^~ ; Fo?. [ Far r is 'LCunningham. 2 "
,E . 2320 North Mecond Street
'2 Hat t.istf ulg', Pennsylvania 1, s , DocR/atir[and Service Section 1 , .
. m s Office.of the Secretary i Thohtas lJ. Germ 7iine , Esq.' U.'S.' huclear Regulatory Commission
- ' Deputy / Attorney Gene 1~31/ . .
H Y ,Divicion of; Law - Room 316' WashingtCn,*D.C. 20555
- 7 1100 Raymond Boulevard '
- Newark, New Jersey 07102 ' - -
.v.
C- Dr. Judith Hi Johnsrud A
- ' ' Dr. Chauncey Kepford _b _ #CMM
- Environmential Coalition on X,' # /
ia Nuclear;Po9er s 5'
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433 Orland'oLAvenue
- Hand delivered December 24, State College, PA 16801 1981. Staff copy delivered'to
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K, residence of Mary Wagner, Esq.
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- William S. / Jordan, I I I ,- Esq.
b' Ha'rmon & Weiss * ** On advice of Doris Moran,
[,1'i 1725 Eye St. DN.W., Suite 506 the Board and Special' Master Washington, D.C. 20006, . copies will be hand delivered early a.m. on Monday, December s
< .-N .-
John A. Levin, Esq. -C 28, 1981.
i}
T Assistant Counsel , ,
< Pennsylvania Public Utility Commission P.O. Box 3265 Harrisburg, Penngylvania 17120 n
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