ML20099A046

Third Set of Interrogatories & Document Requests Re Mgt Phase.Certificate of Svc Encl.Related Correspondence

ML20099A046
Person / Time
Site:	Three Mile Island
Issue date:	09/10/1984
From:	Weiss E UNION OF CONCERNED SCIENTISTS
To:	GENERAL PUBLIC UTILITIES CORP.
References
SP, NUDOCS 8409130115
Download: ML20099A046 (14)

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REUrTED CCRn5spcy9gygg September 10, 1984 CyyyJD UNITED STATES OF AMERICA

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E '~J NUCLEAR REGULATORY COMMISSION -

Behore'the'itomib'Sifetiand' Licensing' Board

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In the Matter of )

)

METROPOLITAN EDISON COMPANY ) Docket No. 50-289 SP

) (Restart - Management Phase)

.(Three Mile Island Nuclear )

Station, Unit No. 1) )

UNION OF CONCEANED SCIENTISTS! THIRD SET OF INTERROGATORI.ES AND .D.OC.U.M.SNT _R.EQUESTS TO GENERAL PUBLIC UTILITIES TO: GENERAL PUBLIC UTILITIES NUCLEAR CORPORATION Pursuant to 10 C.F.R. 2.740(b) and 2.741, the Union of Concerned Scientists hereby requests General Public Utilities Nuclear Corporation ("GPU" or_." licensee") to answer the .

following interrogatories separately, fully, in writing and under oath, and to provide access to the requested documents.

All persons who answered or assisted in answering the interrogatories should be_ identified and the answers to which (s)he _ contibuted -indicated.

These interrogatories and document requests are deemed to be continuing. And any additional information relating in any way to these interrogatories and any documents relating to these document requests that GPU acquires subsequent to the date of answering them, up to and including the time of

~ hearing, should be furnished to UCS promptly after such information is acquired.

'8409130115 840910 PDR ADOCK 05000289

The instructions and definitions to be used in answering these interrogatories and document requests.are the same as those stated in Union of Concerned-Scientists First Set of j Interrogatories to- General Public Utilities and First Request 7

to1 General Public Utilities for Production of Documents.

The following questions relate to the Special Report of the Reconstituted OARP Review Committee (hereafter "Special Report"); June 12, 1984. Unless otherwise indicated, page references are to that document.

' Recommendation K (p. 35) relates to INPO participation.

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3-1.

State what.INPO evaluations were actually reviewed by the

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committee and provide these.

3-2. .Has GPU's licensed operator training program been accredited by INPO?

3-3.: Recommendation M (p. 36) calls for the development of task. analyses for control room operators. Did the Commibtee review any task analyses? If so, a) identify which task analyses were reviewed, b) identify the reviewer (s), c) state what the review (s) consisted of, d) provide all documentation of the reviews.

4. Provide the task analyses referred to at p. 36 used by GPU for TMI-1.

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3-5. On page 42, the Committee states that its response to the issues addressed by ALAB-772 was limited by " time and information." Specify the limitations of "information" l referred to. Did the Committee j unsuccessfully seek any information? If so, specify the information sought and to whom the request was made.

'3 -6. . The Committee states that "most" TMI instructors "have or will hold either RO or SRO licenses...." How many licensed operator instructors are there and which licenses does each hold?

3-7. On page 44 the Committee mentions the implementation of "several new programs", including "special B&W simulator -

training programs. .. to provide operators experience with the use of major TMI procedural changes, steam generator tube rupture emergency procedures, and other Licensee Event Report

.(LER) lessons learned."

a. Identify the. programs referreo to and provide the documentation describing their content.

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b. State which such programs were reviewed as to their substance or content by the Committee during the preparation of

'the-Special Report.

c. Identify the reviewer (s).

d. Provide the material actually reviewed by the Committee o

relating to these programs.

y- e. Identify which currently licensed operators have been

, trained through these new programs.

1 3-8. On page 46, the Committee states that the TMI li;ensed operators' " competence has been evaluated periodically..."

state what the Committee-did during the preparation of the Special Report to itself evaluate the competence of any individual operators.

3-9. The Committee states on page 46 that its conclusion [that TMI-1 can be safely operated] "is further amplified and documented in the presentation of the ... results of the most recent NRC examination." State in precisely what manner the NRC exam-results a) " amplify" and b) " document" the Committee's conclusion. .

3-10 State precisely what the Committee considers to be the

. significance of the results of the NRC exams discussed at p. 46.

3-11. To what extent, if any, did the Committee review the content, substance or validity of the NRC exams discussed at p.

46 during the preparation of the Special Report?

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-s-3-13. If. the committee did review the content, substance or.

validity of the NRC exams discussed at p. 46:

a. Identify and provide the exams reviewed

b. Identify the re, viewer (s). ,

c. State what the review consisted of

d. Provide all documentation of the review (s) 3-14. The Committee cites as impressive the "high morale of the operators" (p.46). Did the Committee review the responses of the TMI operators as described in the so-called "RHR Report?"

If so, a) does the RER Report cause the Committee any concern

-about the content, implementation or effectiveness of the GPU training program? b) specify these concerns,-if any.

3-15. On page 4 7, the - Committee responds to the Appeal -Board 's comments regarding a Notice of Violation " citing numerous F instances where licensees' personnel failed to follow proper operating procedures." The Committee notes that GPU's response claimed that "none of-the violations were attributed to improper.or inadequate training."

a. Is it the personal opinion of_the members of the Committee that none of the violations were attributable to improper or inadequate training?

b. If the answer to a above is "yes," state how the Committee formed this opinion during the preparation of the

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i Special Report e.g.', what material was reviewed, who was

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c. What does the Commmittee believe caused the numerous 4-instances of failure of licensees' personnel to follow operating procedures, if the causes did not include improper or

(- -inadequate training?

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3-16'.- The Committee states at page 48 that "GPU Nuclear has conducted training on the examples cited by the ALAB."

a.. Identify the " examples" referred to here and the specific training which the committee believes to have been directed to these " examples."

b.-State whether the Committee reviewed the content of the

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training directed toward these examples in'any way during the preparation of the Special Report.

c. If the Committee did review the content of the training, provide'the material reviewed and all. documentation of the

. review.

3-17. The Committee also states, on page 48: "The ATOG Procedures... address most of them." State which ATOG procedures of the Committee believes to address each of the

" examples. cited by the ALAB."

5-3-18. On page 48, the Committee discusses Frank Kelly's evaluation of the 1982 and 1983 requalification exams, answer keys and individual results.- Provide all documentation of

-these evaluations, including but not limited to all reports containing and supporting Mr. Kelly's conclusions.

c 3-19. At pages 53-54, the Committee addresses the Appeal Boards concern regarding " undue emphasis on passing the examination, aus opposed to learning how to operate the particular- plant in question."- State what ,the Committeb itself d,id during the preparation of the Special Report to evaluate a) the consistency of the question and answer keys with actualLcurrent TMI-l design.

b) the consistency of- the current training information with actual current TMI-l design.

3-20. If any evaluation (s) as described in 3-19 were conducted by the Committee a) Describe the scope, nature and results of the evaluation (s) -

b) Provide all documentation of the evaluation (s) c) Identify the evaluator (s).

3-21. On page 55, the Committee addresses the Appeal Board's

question regarding whether the licensee and NRC examinations are "an effective way to measure an operator's ability to run

- the plant." state specifically what the Committee itself did during the preparation of the special Report to evaluate the

" format and content of the examinations." Identify the evaluator (s) and provide all written documentation of the evaluation (s). ,

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3-22.'The Committee states at page'6l that GPU is one of only 3 U.S. utilities where operators are trained on-both a BPTS and full-scale ~ simulator.- State how many U.S utilities currently have replica simulators.

3-23. State what the Committee itself did during the preparation of the Special Report to evaluate the content or

. quality of the-training given on the BPTS. Provide all documentation of any such evaluation (s).

3-24. State what the Committee itself did during the preparation of the Special Report to evaluate the content and quality of the training given in the B&W simulator. Provide ~

all'documentatio'n of any such evaluation (s).

3-25. State what the Committee itself did during the preparation of the Special Report to evaluate the degree to which the B&W simulator is consistent with the actual current TMI-1 design.-

3 -2 6. : On page 65, the Committee' notes " disagreements between the ASLB and the Special Master." State specifically the disagreements referred to therein.

3-27. On page 65, the Appeal Board's comments are reproduced regarding " subsequently acknowledged deficiencies in licensee's

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training' program." State what the Committee believes to be the deficiencies in. licensee's training program in the 1979-1981 time period. State how each deficiency has been corrected.

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3-28./The Committ.ee states at page 66 that appropriate disciplinary action should be taken against individuals who have " engaged in, condoned, or encouraged cheating in any form."- Identify all persons whom the Committee believes to have'" engaged in, condoned, or encouraged cheating in any form."

3-29. - As to each person identified in 3-28, state whether, in the Committee's opinion, the person received appropriate disciplinary = action and provide the basis for your answer.

< 3-30. Does the Committee believe that failure by a utility to take appropriate disciplinary action against persons who engaged in, condoned or encouraged cheating in the past could undermine the effectiveness of current training and/or the respect of operators for the training program? Explain the basis for your opinion.

3-31. The Committee states at page 67 that "GPU Nuclear may have beenidenied the services of some very talented people on the basis of little more than rumor, hearsay, or demeanor judgments.'" Identify specifically the people referred to l herein.

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13-32. On page 72P the Appeal Board's comment is repro d uced

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a. ;regarding Mssrs." Kelly and Christensen's previous observations Lon the "prideLand enthusiasm"'found~among employees in the.

p . training program. ,In Kelly and Christensens' 1

opinions how does 6 .g Ethe " widespread. disrespect" found by the ASLB and Special

.Masterf " bear on their previous -assessment of' the effectiveness of.the training. program." ALAB-772 at 66, emphasis added.

,3-33. The Committee states at p. 73 that there was "little opportunity to visit with operators or to monitor classes."

state what the committee actually did during the preparation of

.the Special Report to a)Lvisit with operators and b) monitor

' classes.

3-34. On page 75, the Appeal: Board's-note regarding the Special l

" ... with regard to Master's-following comment is. reproduced:

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the poor administration of licensee's examinations,...if

. licensee was not'awareLof these conditions, its management was out of.t' ouch with the training program." Does the Committee agree-that if GPU was'not so aware, its management was out of touch with the traning' program? Explain the basis for your answer.

3-35.iWasithe- Committee aware during the preparation of its original-testimony given in 1981 of the poor administration of flicensee's examinations? Specify what the Committee was aware of during.that time period in-this regard. -

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3-36. The Committee states at page 83: "The bottom line as far as the Committee is concerned is that the GPU Nuclear training program produces qualified operators and is adequate to support

, the restart of TMI-1. " j Identify the specific facts which the ,

Committee considered and believes to' support the conclusion that the GPU training program actually " produces qualified operators."

3-37. To what extent does the Committee rely on the TMI i operators' performance on NRC exams as support for the conclusion that the GPU training program actually " produces qualified operators."

By: ,

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I~ \%Elly4 A. Weiss Gene. 4 1 Counsel Union of Concerned Scientists

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tLLAtl. .; _ ' : ; , D,: , ;cg K

.,ETED D O.C.:i_-

September 10, 1984'"

84 SEP 12 M1:30 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY- AND LICENSING BOARD In the Matter of )

/

r

)

METROPOLITAN EDISON COMPANY ) Docket No. 50-289

) (Restart Remand on (Three Mile Island Nuclear ) Management)

Station, Unit No. 1) )

)

CERTIFICATE OF SERVICE I hereby certify that copies of UNION OF CONCERNED SCIENTISTS' THIRD SET OF INTERROGATORIES AND DOCUMENT REQUESTS TO GENERAL PUBLIC UTILITIES was served this 10th day of September 1984, as follows: (1) by hand on all parties marked by an asterisk on the attached service list, and (2) by U.S. mail, first c'Jass postege prepaid, to the other parties on the attached service list.

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m .. .. .. . . _ . . , , . . . . . . . . , _ . . _ ... .. . . . . . . _ . ... . _.

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 Remand on (Three Mile Island Nuclear ) Management)

Station, Unit No. 1) )

)

SERVICE LIST Administrative Judge Gary J. Edles, Chairman . Jack R. Goldberg, Esq.s Atomic Safety & Licensing Appeal Bd. Office of tne Executive Legal Dir.

U.S. Nuclear P.egulatory Commission U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Washington, D.C. 20555 Administrative Judge Jonn H. Buck '

• Ernest L. Blake, Esauire Atomic Safety & Licensing Appeal Bd. Shaw, Pittman, Potts & Trowbridge U.S. Nuclear Regulatory Commission 1800 M Street, N.W.

Washington, D.C. 20555 Washington, D.C. 20036 Administrative Judge Christine N. Kohl s Mr. Louise Bradford -

Atomic Safety & Licensing Appeal Bd. TMI Alert U.S. Nuclear Regulatory Commission 1011 Green Street Washington, D.C. 20555 Harrisburg, PA 17102 Administrative Judge Ivan W. Smith, Chairman Joanne Doroshaw, Esquire Atomic Safety & Licensing Board The Christic Institute U.S. Nuclear Regulatory Commission 1324 North Capitol Street Washington, D.C. 20555 Washington, D.C. 20002 Administrative Judge Sheldon J. Wolfe -

Mr. and Mrs. Norman Aamodt Atomic Safety & Licensing Appeal Bd. R.D. 5 U.S. Nuclear Regulatory Commission Coatesville, PA 19320 Washington, D.C. 20555 Administrative Judge Lynne Bernabei, Esq.

Gustave A. Linenberger, Jr.~ Government Accountability Pr7 ject Atomic Safety & Licensing Board 1555 Connecticut Ave.

U.S. Nuclear Regulatory Commission Washington, D.C. 20009 Washington, D.C. 20555 Docketing and Service Section Michael F. McBride, Esq.

Office of the Secretary LeBoeuf, Lamb, Leiby & MacRae U.S. Nuclear Regulatory Commission 1333 New Hampshire Ave, N.W. #1100 Washington, D.C. 20555 Washington, D.C. 20036

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Michgal W.':Maupin,.Eng.-

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Hunten & Willicas ,

707-Engt Mein ~ Street *

~P.O.-Box 1535-

' Richmond,.VA- '23212" ..

Thomas --Y. _ Au, - Esq.

Office of Chief-Counsel-Department of Environmental Resources .

'505' Executive Houses

.P.O. Box 2357 .i' ~

-Harrisburg, PA. 17120 - < ?7- .

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