ML20094R143
| ML20094R143 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 08/16/1984 |
| From: | Bauser D METROPOLITAN EDISON CO., SHAW, PITTMAN, POTTS & TROWBRIDGE |
| To: | THREE MILE ISLAND ALERT |
| References | |
| SP, NUDOCS 8408200468 | |
| Download: ML20094R143 (10) | |
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-m August 16, 1984 UNITED STATES OF AMERICA hED NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSINO4B0680 7 P3:25.
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.In the Matter of
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+M:cn METROPOLITAN EDISON COMPANY
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Docket No. 50-289 SP
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(Restart-Management Remand)
(Three Mile Island Nuclear
)
Station, Unit No. 1)
)
LICENSEE'S FIRST SET OF INTERROGATORIES AND FIRST REQUEST POR PRODUCTION OF DOCUMENTS TO TMIA Pursuant to 10 C.F.R.
SS 2.740b and 2.741 and to the Atom-ic Safety and Licensing Board's " Memorandum and Order Following Prehearing Conference" of July 9, 1984, Licensee hereby re-quests that intervenor Three Mile Island Alert (TMIA) answer separately and fully in writing, and under oath or affirmation, each of the following interrogatories, and produce and permit inspection and copying of the original or best copy of all doc-uments identified in the responses to these interrogatories.
Licensee makes this request of TMIA in its capacity as a lead intervenor on the issue of training.
Licensee has tried to limit its interrogatories of TMIA to those areas of training in which TMIA has asserted an interest.
Licensee assumes that TMIA's response will reflect the collective knowledge of any intervenor who has an interest in, or desires to participate, in the areas of training in which TMIA intends to assume lead
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If Licensee is incorrect in its assumption, TMIA should promptly inform Licensee so that appro-priate discovery requests can be provided to other intervenors as well.
Licensee's interrogatories are intended to be continuing in nature, and the answers should promptly be supplemented or amended as appropriate, pursuant to 10 C.F.R.
S 2.740(e),
should TMIA or any individual acting on its behalf obtain any new or differing responsive information.
The request for pro-duction of documents is also continuing in nature and TMIA must produce immediately any additional documents it, or any indi-vidual acting on its behalf, obtains which are responsive to the request, in accordance with the provisions of 10 C.F.R. 5 2.740(e).
As used hereinafter, " document (s)" mean all writings and records of every type in the possession, control or custody of TMIA or any individual acting on its behalf, including, but not limited to, memoranda, correspondence, bulletins, minutes, notes, speeches, articles, transcripts, testimony, voice re-cordings and all other writings or recordings of any kind;
" document (s)" shall also mean copies of documents even though the originals thereof are not in the possession, custody, or control of TMIA.
Where identification of a document is re-quested, briefly describe the document (e.g., book, letter, memorandum) and provide the following information, as applica-ble:
document name, title, number, author, date of publication -
and publisher, addressee, date written or approved, and the name and address of the person or persons having possession of the document.
Also identify the specific portion or portions of the elocument (i.e., pages) upon which TMIA relies.
GENERAL INTERROGATORIES T-1(a)..
State the name, present or last known address, and present or last employer of each person, other than affi-ant, who provided information upon which TMIA relied in an-swering each interrogatory herein.
(b).
Identify all such information which was provided by each such person and the specific interrogatory response in which such information is contained.
T-2(a).
Identify all documents upon which you relied in answering each interrogatory herein.
(b).
Identify the specific interrogatory response (s) to which each such document relates.
T-3(a).
Identify any other source of information, not previously identified in response to Interrogatories T-1 or T-2, which was used in answering the interrogatories set forth herein.
(b).
Identify the specific interrogatory response (s) to which.each such source of information relates. :
~
r-4 INTERROGATORIES ON TRAINING T-4.
Identify the specific concerns TMIA has about the adequacy.of the licensed operator training program at TMI.
T-5.
Identify the basis for each of the concerns identi-fled in response to Interrogatory T-4.
T-6.
Identify the remedy that TMIA considers appropriate to respond to each of the concerns identified in response to Interrogatory T-4.
T-7.
Does TMIA consider memorization an inappropriate learning technique?
If so, explain why.
If not, explain the basis on which you would assess whether memorization is being used as an effective learning technique.
T-8.
How would TMIA determine what training is necessary to ensure that operators are able to run the plant?
T-9.
Identify the specific subject-area (s) in Licensee's i
licensed operator training program, if any, that TMIA believes j
require enhancement.
T-10.
For each subject-area identified in response to In-terrogatory T-9, explain the basis for TMIA's view that training in that area should be enhanced.
T-ll.
Explain how, in TMIA's view, each of the subjects identified in response to Interrogatory T-9 should be enhanced.
T-12.
In TMIA's view, does the format of Licensee's exams encourage cheating?
Provide the basis for your answer.
T-13.
Identify the standard on which TMIA relies to de-i termine whether the format of Licensee's exams encourage cheating.
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-T-14.
Identify every individual who, in view of the evi-dence in the reopened proceeding, TMIA believes is not quali-fled to serve in his current position in GPU Nuclear Corpora-tion.
T-15.
For every individual identified in response to In-terrogatory T-14, explain the basis for TMIA's view that the individual is not qualified to serve in his current position in GPU Nuclear Corporation.
T-16.
Is TMIA satisfied with Licensee's criteria for training instructors?
If not, identify each of the bases for its dissatisfaction.
T-17.
Does TMIA believe licensed operators should be re-quired to spend additional time at the simulator?
If so, explain the basis for your answer.
T-18.
Does TMIA believe licensed operators should be tested on the simulator?
If so, explain the basis for your an-swer.
T-19.
In TMIA's view, has GPU properly responded to the problems in its training program identified internally and/or by the Special Master, the Licensing Board and the Appeal Board?
If not, identify (a) each of the problems to which Li-censee has not properly responded, in TMIA's view; and (b) the proper response to each identified problem.
T-20.
What problems, if any, does TMIA perceive with the licensed operators' attitude toward the training program? )
b T-21.
Identify any documents or individuals on which you rely in formulating your response to Interrogatory T-20.
T-22.
Describe the appropriate attitude towards training that TMIA believes the TMI-1 operators should have.
T-23.
What steps should Licensee take in response to the problems enumerated in response to Interrogatory T-20?
T-24.
Is TMIA satisfied that Licensee's employees respon-sible for_the management and implementation of the training program are properly equipped by their experience and attitude to impart the information and values necessary for safe op-eration of TMI-l?
If not, identify (a) the employees about whom TMIA is dissatisfied; (b) each of the bases for its dis-satisfaction; and (c) how TMIA would resolve its concern about each employee identified in response to Interrogatory T-24(a).
T-25.
Identify the concerns TMIA has about the TMI li-censed operator training program, if any, based on its review of the RHR Report.
T-26.
Identify each specific portion (i.e., particular page(s) and particular statement (s)) of the RHR Report on which TMIA relies in formulating its response to Interrogatory T-25.
T-27.
Identify the concerns TMIA has about the TMI li-censed operator training program, if any, based on its review of the BETA Report.
T-28.
Identify each specific portion (i.e., particular page(s) and particular statement (s)) of the BETA Report on which TMIA relies in formulating its response to Interrogatory T-27.. _ _
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a T-29.
Identify any criticisms TMIA has of the Special Re-port of the Reconstituted OARP Review Committee, dated June 12, 1984.
T-30.
Identify each specific portion (i.e., particular page(s) and particular statement (s)) of the Special Report of the Reconstituted OARP Review Committee on which TMIA relies in formulating its response to Interrogatory T-29.
Respectfully submitted, m 4. A%
Ernest L.
Blake, Jr.,
P.C.
Deborah B.
Bauser SHAW, PITTMAN, POTTS & TROWBRIDGE 1800 M Street, N.W.
Washington, D.C.
20036 (202) 822-1215 Counsel lot Licensee Dated:
August 16, 1984 _
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-S August 16, 1984 00D;;ic' -
UNITED STATES OF AMERICA 7en
- hr NUCLEAR REGULATORY COMMISSION
'84 gn BEFORE THE ATOMIC SAFETY AND LICENSING BOARD n P3:p5 t;r-GCh,[-[C=- k'k.
In the Matter of
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e.
)
METROPOLITAN EDISON COMPANY
)
Docket No. 50-289
)
(Restart-Management Remand)
(Three Mile Island Nuclear
)
Station, Unit No. 1)
)
CERTIFICATE OF SERVICE I hereby certify that copies of " Licensee's First Set of Interrogatories and First Request for Production of Documents to TMIA" were served this 16th day of August, 1984, by hand de-livery to the parties identified with an asterisk and by depos-it in the U.S. mail, first class, postage prepaid, to the other parties on the attached Service List.
M h h Mt*4 Deborah B.
Bauser 1
7 5
1 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION Before the Atomic Safety and Licensing Board In the Matter of
)
)
METROPOLITAN EDISON COMPANY
)
Docket No. 50-289 SP
)
Restart (Three Mile Island Nuclear
)
Station, Unit No. 1)
)
Service List Administrative Judge Chairman, Atomic Safety &
Ivan W. Smith Licensing Board Panel Chairman, Atomic Safety &
U.S. Nuclear Regulatory Licensing Board Commission U.S. Nuclear Regulatory Washington, D.C.
20555 Commission Washington, D.C.
20555 Chair. nan, Atomic Safety &
Licensing Appeal Board Panel-Administrative Judge U.S. Nuclear Regulatory Sheldon J. Wolfe Commission Atomic Safety & Licensing Washington, D.C.
20555 Board U.S. Nuclear Regulatory Thomas Y. Au, Esq.
Commission Office of Chief Counsel Washington, D.C.
20555 Dept. of Environmental Resources 505 Executive House Administrative Judge P.O. Box 2357 Gustave A. Linenberger, Jr.
Harrisburg, PA 17120 Atomic Safety & Licensing Board U.S. Nuclear Regulatory Washington, D.C.
20555 Jack Goldberg, Esq.
Office of Executive Legal Dtr.
U.S. Nuclear Regulatory Commission Washington, D.C.
20555 l
r O
Docketing & Service Section Ellyn R. Weiss, Esq.
Office of the Secretary William S. Jordan, III, Esq.
U.S. Nuclear Regulatory Harmon, Weiss & Jordan Commission 2001 S Street N.W.,
Suite 430 Washington, D.C.
20555 Washington, D.C.
20009 Mr. Norman Aamodt
- Lynne Bernabei, Esq.
R.
D.
5 Government Accountability Coatesville, PA 19320 Project 1555 Connecticut Avenue
- Joanne Doroshow, Esq.
Washington, D.C.
20009 The Christic Institute 1324 North Capitol Street Washington, D.C.
20002 Ms. Louise Bradford TMI ALERT Mr. Henry D.
Hukill 1011 Green Street Vice President Harrisburg, PA. 17102 GPU Nuclear Corporation P.O.
Box 480 Administrative Judge Middletown, PA 17057 Gary J.
Edles, Chairman Atomic Safety & Licensing Michael F. McBride, Esq.
Appeal Board LeBoeuf, Lamb, Leiby & MacRae U.S. Nuclear Regulatory 1333 New Hampshire Avenue, N.W.
Commission Suite 1100 Washington, D.C.
20555 Washington, D.C.
20036 Administrative Judge Michael W. Maupin, Esq.
John H.
Buck Hunton & Williams Atomic Safety & Licensing 707 East Main Street Appeal Board P.O. Box 1535 U.S. Nuclear Regulatory Richmond, VA 23212 Commission Washington, D.C.
20555 Administrative Judge Christine N. Kohl Atomic Safety & Licensing Appeal Board U.S. Nuclear Regulatory l
Washington, D.C.
20555 l
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