ML20094J859

Second Request for Production of Documents to Gpu. Certificate of Svc Encl.Related Correspondence

ML20094J859
Person / Time
Site:	Three Mile Island
Issue date:	08/13/1984
From:	Bernabei L, Doroshow J CHRISTY, W., GOVERNMENT ACCOUNTABILITY PROJECT, THREE MILE ISLAND ALERT
To:	Atomic Safety and Licensing Board Panel
References
SP, NUDOCS 8408140479
Download: ML20094J859 (14)

Text

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' UNITED. STATES'OF AMERICA ' ' OEMy NUCLEAR REGULATORY COMMISSION Before the Atomic Safety and Licensing Board

'I O In the Matter of )

24 ggg 7 IMETROPOLITAN EDISON COMPANY . Docket No..t 0-289 SP '6

) [. ;fif.S'e, s (Three Mile Island Nuclear ) (Restart - Management' Phase)

Station, Unit No. 1) )

INTERVENOR THREE MILE ISLAND ALERT'S SECOND REQUEST FOR PRODUCTION TO GENERAL PUBLIC UTILITIES TO: GENERAL PUBLIC UTILITIES NUCLEAR CORPORATION Intervenor Three Mile Island Alert ("TMIA"), pursuant to 10 C.F.R. 2.741, hereby requests General Public Utilities Nuclear Corporation ("GPU") to produce and make available for inspection 1

and/or copying, each document in the possession or custody of GPU or subject to the control of GPU or its agents and attorneys, as requested below, by or before September 12., 1984.

DEFINITIONS (a) The Nuclear Regulatory Commission or "NRC" shall mean the Nuclear Regulatory Commission, its branches, departments, sections, offices, subdivisions, its present and former commissioners, admin-istrators, management, employees, staff, agents, representatives, consultants, officials, inspectors, investigators, auditors and accountants, attorneys or their agents, attorneys or representatives.

l (b) " General Public Utilities" or "GPU" shall mean General Public Utilities, any of its subsidiaries, including but not limited to GPU Nuclear Corporation and Metropolitan Edison Company, or its 8400140479 840813 '(

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t or its subsidiaries' branches, divisions, departments, sections,

'g affiliates, offices, present and former officers,. directors, management,' board of directors, employees, staff, officials, agents, consultants, attorneys, representatives or their attorneys, representatives and agents.

(c) " Babcock and Wilcox" or."B&W" shall mean the Babcock

& Wilcox Company, its subsidiaries, branches, divisions, depart-ments, sections, affiliates, offices, and its or its subsidiaries' present and former officers, directors, management, board of directors, employees, officials, staff, agents, consultants, attorneys, representatives or their attorneys, representatives and agents.

(d) " Document" shall mean every writing of every type or description, and every other instrument or device by which, through which or on which information has been recorded and/or preserved, including but not limited to memoranda, notes, letters, drawings, files, graphs, charts, photographs, slide presentations, hand-vritten notes, logs, ledgers, studies, data sheets, appointment calendars, telephone messages, meeting minutes, calculations, computations, financial statements, voice recordings and other data compilations or every other device or media on which or through which information of any type is transmitted, recorded or preserved.'

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" Person" shall rcfor to any natural person, firm, partnership, joint venture, trust, corporation, holding company or other entity, natural or legal, domestic or foreign.

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(f) " Communication" shall mean discussion, conversation,

. letter, memorandum, telephone call, message or direction, whether

. written or oral or whether in person, by telephone or by mail.

INSTRUCTIONS FOR USE A. .All documents are to be made available for inspection and/or copying which are in your possession or under your control, or in the possession or under the control of your officers, manage-ment, executitOs, employees, staff, directors, officials, attorneys, consultants, accountants, inspectors, investigators, or representa--

tives, or their agents, representatives or attorneys.

B. If GPU contends that any document responsive to any request for production listed below is privileged in whole or in part, or otherwise objects to any part of any request, state the reason for each objection or grounds for exclusion, and identify each person having knowledge of the factual basis, if any, on which the privilege or other ground is asserted.

C. If any documents responsive to any request for produc-tion is no longer in existence, then answer the following questions:

(1) identify what information was maintained in that document; (2) identify the type of document which contained such information; (3) state the time period during which such document j was maintained; l

(4) state the circumstances under which such document l

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ceased to exist;

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(5) state'the date when such document' ceased to exist; (6) identify all persons having knowledge of the circumstances under which such document ceased to exist; and (7) identify all persons who have knowledge or had knowledge of the. document and the contents thereof.

This Request for Production is deemed to be continuing such that GPU is requested to supplement production with all responsive documents which come into its possession, custody or control subsequent to production of documents pursuant to intervenor's request.

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ceased to exist; (5) state the date when such document ceased to exist; (6). identify all persons having knowledge of the circumstances under which such document ceased to exist; and (7) identify all persons who have knowledge or had knowledge of the document and~the contents thereof.

This Request for Production is deemed to be continuing such that GPU is requested to supplement production with all responsive documents which come into its possession, custody or control subsequent to production of documents pursuant to intervenor's request.

DOCUMENTS REQUESTED

1. Notes, reports, memoranda or other documents generated in connection with interviews and/or contacts made by members of the Reconstituted OARP Review Committee to prepare, research and/or write the Special Report of the Reconstituted OARP Review Committee

("Special Report").

2. All documents related to inspections and/or visits of facilities made by' members of the Reconstituted OARP Review Commit-tee to prepare, research and/or write the Special Report.

3. All documents related to the extensive program for train-ing and development of instructors referenced on page 20 of the Special Report, including but not limited to documents explaining the standardized method of instruction; written criteria for teach-ing instructors; and instructional materials.

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• 4. All documents related to interviews and/or classroom visits made by Dr. Long.and Dr. Coe, referenced on page 22 of the Special Report, including but not limited to interviews, reports, memoranda, and personal notes.

5. The TMI document " Control of Examinations for Units 1 and 2", referenced on page 23 of the Special Report.

6. Memorandum dated January 27, 1984, from B.P. Leonard, Operator Training Manager to the Operator Training Section with six attachments, referenced on pages 23 to 24 of the Special Report.

7, All documents related to the GPU Nuclear Training Advisory Council, referenced on page 22 of the Special Report, including but not limited to all minutes of meetings; reports; recommendations or suggestions; materials prepared for meetings of the Advisory Council; and internal memoranda establishing or instructing the Advisory Council.

8. All documents related to implementing procedures for security of all categories of exams, referenced on pages 25 to 27 of the Special Report.

9. All documents related to the current curricula for operators at TMI-1, including but not limited to course materials, curricula, testo, instructions or directions, and quizzes, i

10. All. documents related to meetings between new training instructors and the Director of Training and Education, including l but not limited to all written instructions or directions given the instructors; any memoranda written by the Director concerning such l l

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, I meetings, any' personal' notes of such meetings, and any recommenda- l tions, suggestion's or changes made as a result 'of such ; meetings.-

11.- All documents related to the Vice President / Director of '

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TMI-l's interviews with operators, ; including but not limited to the interview noted, memoranda-or reports of the-Director; notes, memoranda or minutes kept by theJoperators; reports issued'as'a-result of such interviews; and all recommendations, suggestions or.

changes made as a result of such interviews.

12. Data-Design Laboratories' assessment report of sel~ected TMI-l' training programs issued in 1982, referenced on page 29:of the'Special. Report.

i j 13. GPU's INPO accreditation review of.its STA Training Program 4

J during 1984, referenced on page-29 of the Special Report.

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. 14. All documents related to the Management Analysis Corpora-i l tion's decision analysis training course offered in 1980 or any modified programs offered after 1980, referenced on page 35 of the Special Report.

15.

All documents related to guidance GPU provides for prepara-- -

q tion of both oral and written examinations, including the matrix, 1

t referenced on page 36 of the Special Report.

16. The generic task analysis list prepared by INPO with GPU input, referenced on page 36 of the Special Report.

17. All instructor lesson plans used at any time at TMI-l from 1979'to the present, referenced on page 45 of the Special Report.

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All documents related to the weekly meetings between

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shift supervisors and the Training Department, refer ~en'ced on page 45 of the'Special Report, including but not limited to meeting minutes,' personal notes of the meetings, and written recommendations, suggestions or changes made as a result of those meetings.

19. All documents related to the audits, reviews or inspec-tions conducted by-management of all TMI training programs, referenced

'on page 45 of the Special Report, including but not limited to audits conducted by Dr. Long, Dr. Coe,_and Mr. Hukill.

20 All INPO evaluation findings from 1979 to'the present' concerning TMI-l's training program and management interface or management control over the training program, including but not limited to the evaluation finding referenced on page 47 of the Special Report.

21. The evaluations conducted by Mr. Kelly of the 1982 and 1983 written RO and SRO requalification examinations, answer keys and individual results on these written examinations, referenced on page 48 of the Special Report.

22. All documents related to management's observation of crews during the ATOG simulatory training at the B&W simulator, i

referenced on page 52 of the Special Report.

l 23. A ta ble of contents or listing of all sections of the Operations Plant Manual for operator training, referenced on page l

54 of the Special Report.

24. The informal job and task analyses completed by GPU

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Nuclear Staff.and the set constructed by INPO, both referenced on'page 55 of the. Spec'ial-Report.

25. All TM1'Self-Evaluation Reports from 1979 to the.prosent, including but not limited to the Self-Evaluation. Reports dated '

May 24, 1984, referenced on page 68 of the Special Report.

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26. .For the period 1982 to the present, all documents related to communications between top management and the training program,.

including but not limited to documents related to the following,

.all referenced on pages 75 to 77 of the Special Report:

4 (a) formal interviews of Mr. Hukill with license holders and with each license candidate as part of the certification process, referenced on.page 75 of the Special Report;

, (b) written certifications by Operations and Training

{ Management, including all evaluations of trainees' performance and f attitude; i

(c) " Management Interface" meetings held for, inter alia, training crews, (d) Mr. Hukill's attendance at four hours of training classes per month; i (e) bi-weekly reports of activities including training

) for upper management and of f-shif t tours by management; (f) Mr. Hukill'a periodic meetings with operators as a

. group and Dr. Long's employees' meetings at the site; (g) management and supervisory development training program, including seminars, including but not limited to seminar-

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. materials and curricula.for the' training program.=

-< 27. "All document's related to or generated in connection with-theifollowing; referenced.on;pages-77 to 78 of the Special Report

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(a). Off-shift tours by management; (b) .simulatory-training sessions attended by senior 1

managersifrom Nuclear Assurance,. Operations;and Training;.

(c) . meetings.between training and line functions to a

discuss training problems, including.but not limited to minutes of

=such meetings, memoranda generated in' connection with such meetings,

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and written' recommendations, suggestions or changes resulting from such meetings; l (d) TMI-1 managers' meetings which Mr. Newton attends, insofar as they touch in.any way on the training program, the B

qualifications of operators or training instructors, or management's interface and/or involvement with the training program.

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28. A memorandum dated December 8, 1983, from P.R. Clark to 1 ,

, S.L. Newton, referenced on page 78 of the Special Report, i

l 29. The letter dated October 9, 1981, from R.C. Arnold to f GPU employees, referenced on page 79 of the Special Report.

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30. All documents listed on pages 80, 81, 85, 86 and 87,

except items 2, 12, 14, 16, 17, 20, 24, and 25. .

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31. All documents related to Basic Energy Technology Associ-ates, Inc.'s "A Report on a Review of Current and Projected Expendi-4 tures and Manpower Utilization for GPU Nuclear Corporation" (Febru-4 1

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.ary 28, 1983) (" BETA Report") , including but not limited to all draft rep' orts, all corresponden'ce between BETA and.GPU concerning e

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the report; all instructions, directions or guidance given by GPU

. to BETA for preparation of the report; all GPU comments, remarks, criticisms'or evaluations of the report;.and all= documents relating-to actions taken by GPU in response to the BETA Report.

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32. All documents related to " Priority Concerns of Licensed Nuclear Operators at.TMI and Oyster Creek'and Suggested Action Steps", Paul F. D'Arcy, Ph.D. and John R. Sauer, Ph.D., Rohrer,

_Hibler & Replogle, Inc. (March 15, 1983) ("RHR Report") , including but not limited to all draft reports, all correspondence between RHR and GPU concerning the report; all instructions,.. directions,.

or guidance given by GPU to RHR for preparation of the report; all GPU comments, remarks, criticisms or evaluations of the report; and all documents relating to actions taken by GPU in response to the RHR Report.

4 I 33.. All documents related to "An Assessment of the GPU Nuclear Corporation Organization and Senior Management and Its Competence to Operate TMI-1", Admiral H.G. Rickover, USN (November j 19, 1983), including but not limited to all interview reports or notes; all drafts of the reports or sections of the report; all j- correspondence between Admiral Rickover and GPU concerning prepara-tion of the report; all instructions, directions or guidance given i

by GPU to Admiral Rickover for preparation of the report; and all documents relating in any way to actions taken by GPU in response to the Rickover Report.

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., 34. All documents GPU intends to introduce in this reopened management hearing on the training program issue.

35. Written criteria GPU has developed for training

-instructors and the NRC Staff's comments, evaluations, or conclu-sions about these criteria, referenced on page 68 of ALAB-772.

36. All docunents identified in response to Interrogatory Nos. 2,-3, 5, 6, 7, 8, 20, 27, 35, 38, 39, 42, 50, 51, 53, 55, 56, 57, 58, 59, 61, 62, 72, 74 and 75 in Intervenor TMIA's Second Set of Interrogatories.

Respectfully submitted, NJ 0 twve .  : . CT NW- [l$.

Joanne Doroshow The Christic Institute 1324 North Capitol Street Washington, D.C. 20002 Telephone: 202/797-8106 j7t c e. CW >

Lynn'e Bernabei Government Accountability Project 1555'TConnecticut Avenue Northwest Washington, D.C. 20036 elephone: 202/232-8550 DATED: August 13, 1984 Attorneys for Three Mile Island Alert i

s o UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION Before the Atomic Safety and Licensing Board In the Matter of )

) h;['

METROPOLITAN EDISON' COMPANY ) Docket No. 50-289 SP

)

(Three Mile Island Nuclear )

Station, Unit No. 1) ) (Restart - Managemhbk $@$gp)40.16 Yhf ECY I hereby certify that I have served this 13th day of AupSib3HVM* bt i,; .

1984 a copy of the foregoing Second Request for Production to GP0; and Second Set of Interrogatories to GPU on the following by mail, first-class, postage prepaid:

Administrative Judge Thomas Au, Esq.

Ivan W. Smith, Chairman Office of Chief Counsel Atomic Safety & Licensing Board Department of Environmental U.S. Nuclear Regulatory Ccmmission Resources Washington, D.C. 20555 505 Executive House

. P.O. Box 2357 Administrative Judge Harrisburg, PA 17120 Sheldon J. Wolfe Atomic Safety & Licensing Board John A. Levin, Esq.

U.S. Nuclear Regulatory Commission Assistant Counsel Washington, D.C. 20555 Pennsylvania Public Utility Commission Administrative Judge P.O. Box 3265 Gustave A. Linenberger, Jr. Harrisburg, PA 17120 Atomic Safety & Licensing Board U.S. Nuclear Regulatory Commission Ernest L. Blake, Jr.

Washingtcen, D.C. 20555 Shaw, Pittman, Potts & Trowbridge 1800 M Street, N.W.

Docketing and Service Section (3) Washington, D.C. 20036 Office of the Secretary U.S. Nuclear Regulatory Commission Mr. Henry D. Hukill Washington, D.C. 20555 Vice President GPU Nuclear Corporation Atomic Safety & Licensing Board P.O. Box 480 -

Panel Middletown, PA 17057 '

U.S. Nuclear Regulatory Commission j Washington, D.C. 20555 Mr. and Mrs. Norman Aamodt R.D. 5 Atomic Safety & Licensing Appeal Coatesville, PA 19320 Board Panel U.S. Nuclear Regulatory Commission Ms. Louise Bradford Washington, D.C. 20555 TMI ALERT 1011 Green Street  !

Jack R. Goldberg, Esq. Harrisburg, PA 17102 l Office of the Executive Legal l Director Joanne Doroshow, Esq.

U.S. Nuclear Regulatory Commission The Christic Institute Washington, D.C. 20555 1324 North Capitol Street Washington, D.C. 20002

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Michael F. McBride, Esq. Ellyn R. Weiss, Esq.

LeBoeuf, Lamb, Leiby & MacRae William S. Jordan, III,~Esq.

-1333 New Hampshire Avenue, N.W. Harmon, Weiss & Jordan Suite 1100 2001 S Street, Northwest Washington, D.C. 20036 Suite 430 Washington, D.C. 20009 Michael W. Maupin, Esq.

, Hunton & Williams 707 East Main Street Post Office Box 1535 Richmond, VA 23212 I/i M Ly n Bernabei A N

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