ML20070M069

Response in Opposition to Commonwealth 821213 Withdrawal of Exception Re TMI-1 Training Instructor Certification Deadline.Motion Does Not Reflect Record.Implications on Training Sufficiency Misleading.Certificate of Svc Encl

ML20070M069
Person / Time
Site:	Three Mile Island
Issue date:	01/06/1983
From:	Aamodt M AAMODTS
To:	NRC ATOMIC SAFETY & LICENSING APPEAL PANEL (ASLAP)
References
NUDOCS 8301120254
Download: ML20070M069 (3)

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UNITED STATES OF AMERICA r NUCIEAR REGULA TORY COMMISSION BEFORE 'IHE A'IOMIC SAFETY AND LICENSING A PPEAL BOA RD 00gE}ED In the Matter of METR'O PGLITAN EDISON COMPANY Docket No. 50-Z$f JM 10 P2:03 (Three Mile Island Nuclear Sta tion, Unit 1) ) . . . -

$$' TidsYhME A AMODT OBJECTION TO COMMONWEALTH'S BRM CH WITHDRAWAL OF EXCEPTION CONCERNING TMI-1 INSTRUCTORS The Commonwealth, in a motion of December 13,,,1982, ha s withdrawn its exception to the Licensing Board's decision, concerning a deadline for certification of training instructors.

The NRC Staff subsequen tly indicated their concurrence with this Commonwealth cove.

We object to the Commonwealth's withdrawal as contrary to the public health and safety, to the NRC concurrence, and to ahy implica tiona concerning TMI management implied in this motion and specifically in foo tnote (1) . .

} A RGUMENT Implied in the Commonwealth's withdrawal is the assumption of the trustworthiness of TMI management to meet their commitments.

The Commonwealth has no basis for implying trustworthiness, nor do they present any. The evidence of the record is to tne contra ry.

Whether the training instructors are qualified prior to restart has no bearing on whether the operation personnel are appropria tely trained. The NRC Staff made just this point in opposing the Commonwealth's brief of September 30, 1982.

The Commonwealth is willing to limit their concern to the quality of instructors of licensed operators (Footnote 1).

It is clearly contrary to reason that a training department that failed in an area of focus (operator training) can be assumed to

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have adequa te instructors 6f unlicensed operators, maintainance and other personnel.

8301120254 830106 PDR ADOCK 05000289 O PDR bJ-2

We objected in July 1981 (our filing, July 27, 1981) to a similar withering of Commonwealth objections following the main hearing on restart. In tha t instance, the Licensee was allowed to delay the hearing for several weeks in order to force negotia tions with the Commonwealth. The Commonwealth withdrew 35 pages of findings, highly critical of the Licensee's training and staffing of licensed operators in return for an agreement with the Licensee, which became Condition 9 of the Board's decision (August 27, 1981) As was clearly revealed by the cheating incident and subsequent hearing, Licensee had not kept its agreement, nor had the NRC Staff monitored compliance (as they had agreed).

For instance, in an area of great interest to the Commonwealth a t the time of the agreement, TMI-2 events training and testing, the Reopened Hearing showed that the Licensee continued to use coaching techniques to prepare the opera tors to pass the test.

Even af ter the focus of the Reopened Hearing and Licensee's verbal assurances of reform in test administra tion, Licensee gave but a single version of the TMI-2 test at a number of testing sessions.

CONCLUSION' We find the Commonwealth's motion does not reflect the record of evidence and that the implica tions of sufficiency concerning licensing opera tor and other training are misleading.

We find the NRC position of sa tisfaction with the Common-wealth's withdrawal consistent with their prior positions, however reprehensible.

Respectfully submitted,

, N)^dd. '

Marjorie M. Aamodt January 6, 1982

" ihi% 10 to cartify thet tha decum:;nto AAMODT COMMENTS T0 ME COMMISSION MEETING OF DECEMBER 17, 1982 and A;.MoDT OBJECTION TO COMMONWEALW'S WITHDRAWAL OF EXCEPTION CONCERNING TMI - 1 INSTRUC'IORS were served by Express Mail on the Commissioners and by deposit in U. S. Mail first class to the following: I l

• Atomic Safety and 1icensing Appeal Board Ms. L uise Bradford U. S. Nuclear Regulatory Commission . U^

Washington, D. C. 20555 32 Peffer Street Harrisburg, PA 17102

• Atomic Safety and Licensing Board Panel U. S. Nuclear Regulatory Comission ,, ' -

Washington, D. C. 20555

• Docketing and Service Section U. S. Nuclear Regulatory Commission Washington, D. C. 20555 Mr. Jack Goldberg, Esq.

Nuclear Regulatary Commission Washington, D. C. 20555 Robert Adler. Esa.

505 Executive House

'P. O. Box 2357 Harrisburg, Pennsylvania 17120 Gary L. Milhollin, Adr.:inis tra tive Judge 4412 Greenwich Parkway, NW Wa shington, D. C. 20007 G. F. Trowbridge, Esq.

Shaw, Pittman, Potts & Trowbridge 1800 M Street, N.W.

Washington, D. C. 20036 Ellyn R. Weiss, Esq.

William S. Jordan III, Esq.

-Harmon & Weiss i i ho 3 D. 2006 Served on January 6, 1983.

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Marjorfe M. Aamodt

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