ML20094R270
| ML20094R270 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 08/16/1984 |
| From: | Bauser D METROPOLITAN EDISON CO., SHAW, PITTMAN, POTTS & TROWBRIDGE |
| To: | UNION OF CONCERNED SCIENTISTS |
| References | |
| SP, NUDOCS 8408200515 | |
| Download: ML20094R270 (9) | |
Text
7 attf r o = m s N Eo UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION
!@N" BEFORE THE ATOMIC SAFETY AND LICENSING BOARD
'84 ASO 17 P3:25 In the Matter of
)
)
- J,- Q " r E,
METROPOLITAN EDISON COMPANY
)
Dock'etiNo. 50-289 SP
)
(Restart!-Management Romand)
(Three Mile Island Nuclear
)
Station, Unit No. 1)
)
LICENSEE'S FIRST SET OF INTERROGATORIES AND FIRST REQUEST FOR PRODUCTION OF DOCUMENTS TO UCS Pursuant to 10 C.F.R.
$$ 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 Union of concerned Scientists (UCS) an-swer separately and fully in writing, and under oath or affir-mation, each of the following interrogatories, and produce and permit inspection and copying of the original or best copy of all documents identified in the responses to these interrogato-ries.
Licensee makes this request of UCS in its capacity as a lead intervenor on the issue of training.
Licensee has tried to limit its interrogatories of UCS to those areas of training in which UCS has asserted an interest.
Licensee assumes that UCS's response will reflect the collective knowledge of any in-tervenor who has an interest in, or desires to participate, in the areas of training in which UCS intends to assume a lead i
p mront 3>so3
F.
O intervenor role.
If Licensee is incorrect in its assumption, UCS should promptly inform Licensee so that appropriate discov-ery 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. 5 2.740(e),
should UCS 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 UCS must produce immediately any additional documents it, or any indi-vidual acting on its behalf, obtain which are responsive to the request, in accordance with the provisions of 10 C.F.R. 2.740(e).
As used hereinafter, " document (s)" m,ean all writings and records of every type in the possession, control or custody of UCS 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 UCS.
Where identification of a document is re-quested, briefly describe the document (e.g., book, letter, memorandum) and provide the following information, as applica-bles 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 document (i.e., pages) upon which UCS relies.
GENERAL INTERROGATORIES U-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 UCS 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.
U-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.
U-3(a).
Identify any other source of information, not previously identified in response to Interrogatories U-l or U-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.
INTERROGATORIES ON TRAINING U-4.
Identify the concerns UCS has about the adequacy of the licensed operator training program at TMI.
-3
U-5.
Identify the basis for each of the concerns identi-fled in response to Interrogatory U-4.
U-6.
Identify the remedy that UCS considers appropriate to respond to each of the concerns identified in response to Interrogatory U-4.
U-7.
Does UCS consider memorization an inappropriate learning technique?
If so, explain why.
If not, explain the l
basis on which UCS would assess whether memorization is being used as an effective learning technique.
U-8.
How would UCS determine what training is necessary to ensure that operators are able to run the plant?
U-9.
Identify the specific subject-area (s) in Licensee's licensed operator training program that UCS believes require l
enhancement.
U-10.
For each subject-area identified in response to In-1 l
terrogatory U-9, explain the basis for UCS' view that training in that area should be enhanced.
U-ll.
Explain how, in UCS' view, each of the subjects identified in response to Interrogatory U-9 should be enhanced.
U-12.
In UCS' view, does the format of Licensee's exams encourage cheating?
Provide the basis for your answer.
U-13.
Identify the standard on which UCS relics to deter-mine whether the format of Licensee's exams encourage cheating.
U-14.
Does UCS believe licensed operators should be re-quired to spend additional time at the simulator?
If so, explain the basis for your answer.
! \\
U-15.
Does UCS believe licensed operators should be test-ed on the simulator?
If so, explain the basis for your answer.
U-16.
Does UCS believe that the licensed operators are capable of safely operating TMI-1 during normal operation or accident conditions?
If not, explain the basis for your an-swer, especially as it relates to any perceived deficiencies in the training program.
U-17.
Identify any documents on which UCS relies to sup-port its position in response to Interrogatory U-16.
U-18.
What capabilities, if any, would you require opera-tors to have that you believe they presently lack?
U-19.
In UCS' opinion, do Licensee's exams reliably mea-l sure the operators' ability to safely operate TMI-l?
If not, why not?
U-20.
Identify each deficiency UCS believes exists in Li-censee's examinations.
i l
U-21.
Does UCS believe the NRC exams should be relied i
]
upon as a reliable measure of an operator's ability to safely operate TMI-l?
If not, why not?
U-22.
Does UCS believe the NRC exams are relied upon by i
Licensee as a reliable measure of an operator's ability to j
safely operate TMI-l?
Explain the basis for UCS' view.
I U-23.
Identify the concerns UCS has about the TMI li-censed operator training program, if any, based on its review of the RHR Report.
i
A U-24.
Identify each specific portion (i.e., particular page(s) and particular statement (s)) of the RHR Report on which UCS relies in formulating its response to Interrogatory U-23.
U-25.
Identify the concerns UCS has about the TMI li-censed operator training program, if any, based on its review of the BETA Report.
U-26.
Identify each specific portion (i.e., particular page(s) and particular statement (s)) of the BETA Report on which UCS relies in formulating its response to Interrogatory U-25.
U-27.
Identify any criticisms UCS has of the Special Re-port of the Reconstituted OARP Review Committee, dated June 12, 1984.
U-28.
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 UCS relies in formulating its response to Interrogatory U-27.
Respectfully submitted, OLS.ere.h b. $"M*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 for Licensee Dated:
August 16, 1984
4
.a August 16, 1984 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
)
(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 UCS" were served this 16th day of August, 1984, by deposit in the U.S. mail, first class, postage prepaid, to the parties on the attached Service List.
l h & h. h "'^* %
Deborah B.
Bauser i
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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 Chairman, 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 1
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
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Docketing & Service Section Ellyn R. Weiss, Esq.
Office of the Secretary William S. Jordan, III, Esq.
U.S. Nuclear Regulatory Narmon, Weiss & Jordan Commission 2001 S Street N.W.,
suite 430 Washington, D.C.
20555 Washington, D.C.
20009 1
Mr. Norman Aamodt Lynne Bernabei, Esq.
R. D.
5 Government Accountability i
Coatesville, PA 19320 Project i
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. Nukill 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 i
i 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 j
Administrative Judge 1
Michael W. Maupin, Esq.
John H. Buck l
Hunton & Williams Atomic Safety & Licensing i
707 East Main Street Appeal Board P.O. Box 1535 U.S. Nuclear Regulatory I
Richmond, VA 23212 Commission Washington, D.C.
20555 Administrative Judge
.i Christine N. Kohl Atomic Safety & Licensing i
Appeal Board U.S. Nuclear Regulatory
.l Washington, D.C.
20555 l
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