ML20096B811

First Set of Interrogatories.Certificate of Svc Encl. Related Correspondence

ML20096B811
Person / Time
Site:	Three Mile Island
Issue date:	08/28/1984
From:	Jordan W, Weiss E HARMON & WEISS, UNION OF CONCERNED SCIENTISTS
To:	METROPOLITAN EDISON CO.
Shared Package
ML20096B789	List: ML20096B788 ML20096B811
References
SP, SPS, NUDOCS 8409040360
Download: ML20096B811 (15)

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'E Augu s fiE28',Ul984 - ! ZEEE5 UNITED STATES'OF AMERICA NUCLEAR REGULATORY COMMISSION %f;U

Before the Atomic Safety and- Licensing ebb 80d R2

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In the Matter of )

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

) (Restart - Management Phase)

(Three Mile Island Nuclear )

' Station,' Unit No. 1)

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UNION OF CONCERNED SCIENTISTS' FIRST SET OF INTERROGATORIES-TO GENERAL PUBLIC UTILITIES TO: GENERAL'PUBLIC UTILITIES NUCLEAR CORPORATION Pursuant to 10 C.F.R. 2.740(b), the Union of Concerned

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Scientists hereby requests General Public Utilities Nuclear Corporation ("GPU" or " license")-to answer the following interrogatories separately, fully, in writing and under oath.

LAll persons who answered or assisted in answering-these interrogatories should be identified and the answers to which (s)he contributed indicated.

These interrogatories are deemed to be continuing, and any additional information relating in any way to these

interrogatories which GPU acquires subsequent to the date of answering them, up.to and including the time of hearing, should tur furnished to UCS promptly after such information is acquired.

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- INSTRUCT' IONS 1 p

A. You musto divulge all information that is in your 5 possession or! under your : control, or is in the possession or' unde ~r'the ' control.of your present or.former managers, officers, directors, executives, employees, staff, attorneys, consultants, accountants, or their agents, representatives or attorneys.

B.- Where~ identification of a meeting, conversation,

-l l . discuss' ion or communication is required, the following shall be j l " separately stated as to each such meeting, conversation,

~ discussion or communication: the date, . place, persons present or participating; ~ the method of communication,:whether oral or written; the identity of each participant; the substance of'each person's participation;.the substance or subject discussed or communicated; the purpose of the meeting or communication; the i identity of any person who possesses information concerning such 1

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(. meeting, conversation, discussion or communication; the substance

.of any decision made at such meeting, discussion or conversation; i any minutes, correspondence, notes, memoranda or other writing which resulted-from or memorialized such meeting, discussion or L conversation or communication, and the location of any .such correspondence,-notes, memoranda or other document.

L C.. 'Where identification of a document is required, state the following: ;its'date; ' its exact title; the general. subject L

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-matter Eofrthe' document; the; author and his/her-' affiliation, office;or business,. presently 0and at the' time the. document was.

p'repared; and whethernthe' document will-be made.available.for ins'pection9and copying, and the site of such voluntary production.

-D. Where 7identification of a person is sought,' persons

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working for GPU' may be n. identified by name and. job title. Other

. persons shall be identified.by'name, job and-address.

E. If:GPU-contends that.the answer to any interrogatory is privileged, in whole or in part', or otherwise Lobjects to any part of any interrogatory, state the reasons for each objection or

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-grounds vor exclusion, and identify each person having knowledge

.of the factual basis, if any, on which the privilege or other

. ground is asserted. .

F. If an interrogatory could, at one time, have been

answered by consulting documents that are no longer in existence,

, in answer to such interrogatory:

1. identify what information was maintained;

2. -identify all documents that contained such information; 1

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~3. - state the time period during which-such' documents-

-were maintained;

4. stateEthe circumstances under which documents ceased '

l to" exist;.

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5.- - state the date when such documepts ceased to exist;

16.  : identify all persons having knowledge'of the

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circumstances under1which such documents ceased to exist; and

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7. = identify all'~ persons who have knowledge or had

. knowledge of the documents and = their contents.

G. As used herein..and unless the context otherwise requires, the terms: ,

(i); "NRC" sh'all mean the Nuclear Regulatory Commission, its branches, departments, sections, offices, subdivisions, its present and^ former commissioners, ad mini s t_r a to r s , officials, inspectors, investigators', staff, consultants,. contractors, attorneys, employees, agents, representatives'and accountants, or their agents, attorneys and representatives.

(ii) " General Public Utilities" or "GPU" shall mean _

i? General Public: Utilities, any of its subsidiaries, including but not limited to;GPU' Nuclear' Corporation'and Metropolitan Edison

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s ~ Company, itsior'its subsidiaries' branches, divisions, departments. sections, affiliates, offices, present and former

. officers. directors,-management, board-of. directors, employees, staff) officials,. agents, consultants,.-attorneys, representatives oritheir;. attorneys, representatives and. agents.

'(iii) " Document" shall mean every writing of every. type and description,'and every other instrument or device by which, through which or on'which1information has been recorded and/or

preserved, including but not limited to memoranda, includ i ng --

. those reflecting meetings, discussions or conversation.s, notes,

-letters, drawings, files, graphs, charts,: maps, photographs, deeds, agreements, contracts, ha dwritten notes, diaries, logs, ledgers, studies, data sheets, notebooks, books, appointment calendars, telephone bills, telephone messages, receipts,

' vouchers, minutes of meetings, pamphlets, computations, devices or media on which or through which information of any type is

- transmitted, recorded or preserved. The term " document" also means every mopy of a document when such copy is not an identical i-duplicate of the original.

(iv) Person" shall refer to any natural person, firm, partnership, joint venture, trust, corporation, holding company, or any other~ entity. natural or legal, domestic or foreign.

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(v') " Communication" -shal'1 mean communication, discussion, conversation, contact,-letter, memorandum, telephone.

call, telegram, message or. direction, 'whether written or oral, .

and'whether in person', by-telephone or by mail.

NOTE ON NONDUPLICATION UCS has~ attempted to avoid duplication of interrogatories posed by'other intervenors. Should such duplication. occur despite our efforts, you may identify the duplicative interrogatory'and the-answer (s) that'you have provided in' response to another 'intervenor 's interrogatory that you believe are' responsive to UCS' interrogatory be broader than the other-intervenor's, .you must provide the additional information as well as identifying what you have already provided.

INTERROGATORIES ,

l.. Regarding any document responsive to UCS' First Request for' Production of Documents of whose existence GPU is aware, or that GPU knew existed in the past, and that is not now within GPU 's cusrody or control, state the following:

(a)' the current ~ location of the document; (b) the custodian of the document; (c) the title and substance of the document;

'(d) Lthe document request to which the document is responsive; and-

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- (e)~ ifLthe document no longer exists, the last.known j .- . location of the : document and the- circumstances under shich the

. document.ce'ased to exist. .

2.- Identify all~ individuals'whom GPU intends to call as h:. witnesses-on .the remanded.iss'ues related to the GPU training i

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. program. For'each.such witness, state or identify the-following:

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a.. The individual's qualifications, -includir g educational l and. employment history and publications.

l l b. All:of the-individual's contracts, consulting l arrangements, advisory positions, and other

- relationships with GPU.

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c '. All regulatory. proceedings of any type in which the individual has testified. For each proceeding, state

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l - theLpurpose of the hearing, the subject of the

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testimony, and the date, time, and place of the l-l testimony, i:

l- d. All documents reviewed by the individual in the course I of preparing testimony for this proceeding.

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e .- -All.other persons whom the individual interviewed or consulted in the ' course of preparing testimony for this proceeding. In each case, state the-subject of the interview or conversation and the advice or information

- obtained from the person in question.

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h. i All documents thatethe.lindividua'l intends to use' in connection .with forming-1the opinions contained in

'his/heritestimony in-this proceeding.

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g. The topics 1to'be covere'd'in the individual's testimony.

.h. The conclusions ~ reached"in the individual's testimony and the basesEfor those conclusions.

-(Note: Overlaps.with,;but is broader than' Interrogatory.75 in TMIA's'Second, Set of Interrogatories.)

-3. Identify.all individuals-who'currentlyLhold licenses as

'ReactorLOperators or-Senior Reactor Operators for Three MileL Island-1.- For each such individual, state or identify the

-following:

a. The dates.of ~t h.e individual's employment by GPU.

b. Each position. held by the individual at GPU, the dates he/she held that position, and the responsibilities of the position.

c .. All training activities in which the individual has been

-enrolled or involved that are related to qualifying to

' hold:a license as a Reactor Operator or Senior Reactor Operator.' For each such training activity, state the date-or dates of the activity, the dates the individual-

!- ' actually, attended the activity, the purpose and scope of the activity, the number of hours required for the

. activity, and the actions required of the individual during the activity.

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'd.. ' The dates.of all examinations or tests of any type

~(including quizzes'and oral examinations or tests) that

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.the -in~dividual has- t akens during the : training re f erred' to inithe previous paragraph-(c) or th'a t the individual has:

taken for the.' purpose of' obtaining or maintaining a

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license.as a.. Reactor Operator or a Senior Reactor Operator for GPU.- For each such examination o'r test,

. state -the purpose, the subject matter or matters, the individual's grade, and the consequence (e.g.,

promotion,. licensing, retraining) o_f L:. 2 individual's grade.

.e. The dates of all examinations or tes ts of - any' type' that

-the individual has taken for the purpose of obtain'ing or maintaining a license as a Re' acto _r Operator or.a Senior

. Reactor Operator before the individual was employed by GPU. For.each such examination or test, state the purpose, the subject matter or. matters, the individual's grade, and the consequence (e.g., promotion, licensing, retraining)'of the. individual's grade.

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L4. _ Answer all parts of . Interrogatory #3 for all individuals who-r have held' licenses'to act as Reactor Operators or Senior Reactor Operators for_.TMI-l since March T 28,.1979, but-who either no

' longer. hold.such a license orfare_no' longer employed at TMI-1.

In_ addition,~if'the. individual is no. longer employed at TMI-1,

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state the-date.the individual's employment was terminated and the reason ' for ' the termination.'

5. For.each examination or test identified in response to

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Interrogatories ## 3 orJ4,-state the name_of the person or

- persons who prepared the. examination or test, the name of the person or. persons who administered the' examination or test, and the name of thepersonorpersokswhograded the examination or test.

6. For each week from March 28, 1979, to _the present, describe all training activities carried out at TMI-l during the week, including the purpose and subject matter of each activity, the number of hours involved in the activity, the. number of people i

for whom the training was intended, the actual attendance at the training activities, the. names and positions of the people who administered the training, and any examinations or tests that.

were part of the training or for which the training was intended

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-to prepdre the. participants.

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'7.-iWhen did'GPU.have enough(qualified personnel at TMI-l~to

~begin_the six-shift 1 rotation described in the special report of the--reconstructed'OARP Review Committee atipage 87. When did it actually begin theLrotation?

8. Identify :all individuals currently serving as instructors for training 1 pro'videdLat TMI-1.. For each such individual, state the

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following:

r f a .- .If individual-holds-a college degree, his/her educational and employment history and -qualifications _ to serve 1 as an instructor.

b. 'The' subject matter for which the individual serves as an instructor, c.- If the instructor holds an RO or SRO--license, when was it received? .

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d. -Has the instructor ever failed a utility or IJRC-administered examination, including those for RO, SRO, OARP or annual requalification? If so, identify and provide each failed examination.

e. How long has each individual served as an instructor?

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Identify.all individuals who prepare examination questions for GPU training programs and provide their-educational and

- employment history and qualifications to design _ examinations.

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10. . Identify all individuals who prepared examination questions-for the OARP program and provide their edycational and employment I history and qualifications to design examinations. .

11. Identif,y all individuals who grade examinations and provide their educational and employment history and qualifications to i .

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grade" examinations. -

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12. Identifyallindividualswhhgrade the OARP examinations and provide their educational and employment history and .

qualifications to' grade examinations.

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13. Describe the process, if any, by which cxaminations are evaluat_ad by GPU for difficulty or;ior validit'.r.

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14. Describe the process by which' written and oral examinations are designed and questions prepared .by GPU.

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Respectfully submitted,

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HARMON, WEISS, & JORDAN

,' 2001 S Street, J.W.

Suite 430

," Washington, D.C. 20009 (202) 328-3500 i + Counsel for the Union of Concerned Scientists Dated: August 28, 1984

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1 9 August 28,L1984 UNITED STATES;OF AMERICA NUCLEAR. REGULATORY COMMISSION ,

y BEFORE'THE ATO'MIC' SAFETY AND LICENSING B.OARD

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In the Matter-of'- )

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METROPOLITAN EDISON COMPANY. ) 'gQcifg3 30.RPES289 -

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~(Three Mile Island Nuclear .) _ Management)

Station, Unit No.1)' )' 'Qg,ffgy,,

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~ CERTIFICATE OF SERVICE I.hereby certify that copies of UNION OF CONCERNED SCIENTISTS' FIRST SNT OF INTERROGATORIES TO GENERAL PUBLIC UTILITIES-AND' UNION OF.-CONCERNED SCIENTISTS' FIRST REQUEST TO GENERAL PUBLIC UTILITIES FOR PRODUCTION OF DOCUMENTS were served this.28th day:of August,,1984, by depositing them in the U.S.

mail, first classJpostage prepaid,. to the parties on the attached

-service: list.

& 'fW ,p William . Jordan, III

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SERVICE LIST v- ,

5dministrative Judoe'- K' hryFJ'. IEdles ,-- Cha[rman ..

Jack R. Goldberg, Esq.

htomic Safety & Li/ censing Appeal'Bd. Office of the Executive Legal Dir.

%S.' Nuclear P,egulatory Commission U.S. Nuclear Regulatory Commission

?ashington, D.C. 20555' Washington, D.C. -20555 3dmin15trative Jtidg'e- ,

John-H.-Bucki 7 , .

-George F. Trowbridge, Esq.

$tomic 'Saf etyS& Licensfr.g Appeal Bd. Shaw, Pittman, Potts & Trowbridge NSkNuclear.Regul'atory. Commission ,1800 M Street,'N.W.  ?

$nch i'ng ton , D'.CF .20555 ,

., Washington, D.C. -20036 s

$dministrative Judge '

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shristine N._ Kohl .- Mr. Louise Bradford

Stomic' Safety & Licensing Appeal Bd. TMI Alert R.S., Nuclear (Regulatory Commission 1011-Green' Street. ,

$tshington,~D;C., 20555 Harrisburg, PA 17102 3dministrative Judge?

3 von W. Smith,-Chairman' Joanne Doroshaw, Esquire 3tomic' Safety &. Licensing Board- The Christic Institute 9.S..~ Nuclear Regulatory " Commission 1324 North Capitol Street . '

?cchington, D.C.- '20555 Washington, D.C. 20002 a ldministrative Judge.

Bh61 don J.;Wolfe Mr. and Mrs. Norman Aamodt Stomic' Safety &' Licensing Appeal Bd.-

R.D. 5

$.S.' Nuclear.. Regulatory Commission Coatasville, PA.19320 Sash ington., r D.C. 20555 1 d ..

Edmi'n[strative Judge.

Lynne Bernabei, Esq.

{0pftselA'. Linenberger,,Jr. . Government Accountability. Project 3tomic^ Safety &1Licens' g? Board 1555 Connecticut Ave.

WS./ Nuclear: Regulator.' Commission 20009

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Washington, D.C. '

Drr;h in g ton , o D . C .- '20555;

)o'cketing land. Service' Section Michael F. McBride, Esq.

o j)ffica ofJtheLSecretary LeBoeuf, Lamb, Leiby & MacRae j).S. Nuclear" Regulatory Commission 1333.New Hamp. shire Ave, N.W3.#1100

% hin_gton',"D.C. =20555- Washington, D.C. 20036c

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' Michi 11 EM::upin, E::q.

3 Hunten & Willicm3 2

707 East Main Street -

P' O. Box-1535 Richmond,LVA 23212

. Thomas Y. . Au , Esq.

Office of Chief Counsel

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. Department of Environmental Resources 505 Executive Houses P.O.. Box 2357 - '

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Harrisburg, PA 17120 P

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