ML20096D848
| ML20096D848 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 08/31/1984 |
| From: | Bauser D METROPOLITAN EDISON CO., SHAW, PITTMAN, POTTS & TROWBRIDGE |
| To: | THREE MILE ISLAND ALERT |
| Shared Package | |
| ML20096D844 | List: |
| References | |
| SP, NUDOCS 8409060320 | |
| Download: ML20096D848 (8) | |
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'!D REU,7za'c,., _ FGND5ncy August 31, 1984 UNITED STATES OF AMERICA 00CKETED NUCLEAR-REGULATORY COMMISSION WN'EC 4 SB -4 P3:59 BEFORE'THE ATOMIC SAFETY AND LICENSING. BOAR LFFICE 0FJEchtif..
In the Matter of CCCXE,
svg METROPOLITAN EDISON COMPANY
)
Docket No. 50-289 SP
)
(Restart-Management Remand)
~(Three Mile Island Nuclear-
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Station,: Unit No. 1)
)
LICENSEE'S THIRD SET OF INTERROGATORIES AND-THIRD REQUEST FOR PRODUCTION OF DOCUMENTS TO TMIA Pursuant to 10 C.F.R. SS 2.740b and 2.741 and to the,
Atomic Safety and Licensing Board's " Memorandum and Order Following Prehearing Conference" of July 9, 1984, Licensee hereby requests that intervenor Three Mile Island Alert (TMIA) answer separately and. fully in writing,-and1under oath or affirmation, 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 interrogatories.
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 TMIA or any individual acting on its behalf obtain any new or differing responsive information. -The request for
-production of documents is also continuing in nature and TMIA f
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<.; 0; must produce immediately any additional documents it, or any individual acting'on its. behalf, obtain which are responsive to the :requesti in Laccordance with the provisions of 10 C.F.R.
~2.740(e).
As used-hereinafter, " document (s)" mean al.1 writings and
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records of every type in the possession, control or custody of TMIA=orLany individual acting on its behalf, including, but not limited to, memoranda, correspondence, bulletins, minutes, notes,. speeches, articles, transcripts, testimony,. voice
-recordings 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 requested, briefly describe the document (e.g., book, letter, memorandum) and provide the following information, as applicable:
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 TMIA relies.
GENERAL INTERROGATORIES T-31(a).
State the name, present or last known address, and present or last employer of each person, other than affiant, who provided information upon which TMIA relied in answering each interrogatory herein..
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Identify all such information which was provided by each such_ person and the specific interrogatory response in whi'ch such information is contained.
Identify all documents upon which you relied in T-32(a).
answering'each interrogatory herein.
Identify the specific interrogatory response (s)
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to (b).
-which each such document relates.
Identify any other source-of information, not T-33(a).
previously identified in response to Interrogatories T-31 or T-32, which was used in answering the interrogatories set forth herein.
Identify the specific interrogatory response (s) to (b).
which each such source of information relates.
_ INTERROGATORIES ON TRAINING Does TMIA believe that the licensed operators are T-34.
capable of safely operating TMI-1 during normal operation or explain the basis for'its answer, accident conditions?
If not, especially as_it relates to any perceived deficiencies in the training program.
Identify any documents on which TMIA relies to T-35.
support its position in response to Interrogatory T-34.
What capabilities,_if any, would you require T-36.
operators to have that you believe they presently lack?
In TMIA's opinion, do Licensee's exams reliably T-37.
If.
measure the operators' ability to safely operate TMI-l?
not, why not?
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T-38.
Identify each deficiency TMIA believes exists in
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Licensee's. examinations.
U T-39.
Does TMIA believe the NRC exams should be relied upon as a reliable measure of an operator's ability to safely operate TMI-l?
If not, why not?
T-40.
Does TMIA believe.the-NRC exams are relied upon by Licensee as a reliable measure of an operator's ability to safely operate TMI-l?
Explain the basis for TMIA's view.
Respectfully submitted, MMih 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 31, 1984.
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R August 31, 1984 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION 000KETED UShRC BEFORE THE ATOMIC SAFETY AND LICENSING BOARIha SEP ~4 p3:59 In the Matter of
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oCCf't flNr; ; ypp~
5 50 28'94 METROPOLITAN EDISON COMPANY
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Docket No.
)
(Restart-Management Remand)
(Three-Mile Island Nuclear
)
Station, Unit No. 1).
)
CERTIFICATE OF SERVICE I'hereby certify that copies of " Licensee's Third Set of Interrogatories and Third Request for Production o'f Documents to TMIA" were served this 31st day of August, 1984, by deposit in the U.S. mail, first class, postage prepaid, to the. parties on the attached Service List.
2%&L b. $312&
Deb ~orah B. Ba6ser~
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r UNITED STATES OF. AMERICA NUCLEAR REGULATORY COMMISSION i
Before the Atomic Safety and Licensing Board i
In=the Matter of
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METROPOLITAN EDISON COMPANY
)
Docket No. 50-289 SP P
)
Restart (Three Mile Island Nuclear
)
Station, Unit No. 1)
)
i Service List t
Admin'istrative 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 Comatission Washington, D.C.
20555 Chairman, Atomic Safety &
Licensing Appeal Board Panel Administrative' Judge
.U.S. Nuclear Regulatory
-Sneldon J. Nolfa Conmiission.
Atomic Safety &' Licensing Washington, D.C.
20555 Board U.S.l Nuclear Regulatory Thomas'Y. Au, Esq.
Ccaunission 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 r
7 Jack Goldberg, Esq.
Office of Executive Legal Dtr.
U.S.-Nuclear Regulatory l
C a ission Nashington, D.C.
20555 e
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T 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 Washington, D.C.
20555 i
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=00, s Taccr. N.W.
SutTE 430 W' SHINGToNe D.C. aoooo A
CAIL McomatvY HARMON k
Q NE ELLYN A WEISS (2023328 3500 WILLIAM S JOMOAN. llt
. otAnt cunnAN DCAN N. TOUSLEY August 2p,*'1984-
' Ernest Blake, Jr. Esq.
Shaw, Pittman,.Potts and Trowbridge 1800 M Street,-N.W.
Washington, D.C.
20036 1
l Re:
GPU Igperrogat9 ties, TMI-1 Restart
Dear Mr. Blake,
On August 21, 1984, I received your first set l3f interrogatories and document requests to UCS.
You state that you " assume" that UCs's response "will reflect the collective knowledge of any intervenor who has an interest in or desires to participate" in the covered areas of training.
You ask us to inform you if licensee is ' incorrect in its assumption."
This is to inform you that UCs's responses will reflect UCs's knowledge regarding the issues in question.
While the agreement on lead.intervenors anticipates that UCS will act as lead.during the hearing on some training issues and we are in fact cooperating with other parties during disco,very, particularly to prevent insofar as possible serving duplicative requests on GPU, UCS does not have the resources nor is it obliged under any order to answer discovery requests with any but UCs's own knowledge'.. The intervenors maintain'their independent party status in this case as I am sure you are aware, just as GPU and the NRC staff do.
Very truly yours, f.- m Ellyn R. Weiss cc:
TMI-1 licensing Board service List ERWinf e'
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