ML20207Q008
| ML20207Q008 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 11/24/1986 |
| From: | Aamodt M AAMODTS |
| To: | Atomic Safety and Licensing Board Panel |
| References | |
| CON-#187-2225 LRP, NUDOCS 8701210057 | |
| Download: ML20207Q008 (16) | |
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N iY UNITED STATES OF AMERICA
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In the Matter of
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INQUIRY INTO THREE MILE ISLAND
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Docket No. LRP UNIT 2 LEAK RATE DATA
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FALSIFICATION
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AAMODY RESPONSE TO EMPIAYRES NOTION TO DISMISS TM AAMODTS AS A PARTY TO THE PROCEEDING l
Introduction On November 12, 1986, the last day of the hearing, the Employees 4
(formerly " Numerous Empicyees") filed a motion to dismiss the Aamodes as a party to the proceeding. The Employees' notion was' based on their c'ontention that the Aamodts have failed to contribute to the record of the proceeding. The Aamodts oppose the Employees' notion.
I The Employees, acknowledging that the NRC rules of conduct do not apply to the instant proceeding (a special legislative format established by a Commission order of December 18, 1985) have articulated two standards for parties, i.e.,
interest and ability to contribute to the record.
.These standards appear to be those the Commission intended and were applied by the Presiding Board in ruling favorably on the Aamodts' petition to participate. The Aamodes do not contest these standards.
The Employees find that the Aamodes have failed to live up to one of
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the standards, that of contributing to the record.(Employees, p.4).
The Employees are wrong. The Employees demand the Board's dismissal of the Aamodts. The Aamodes oppose the Employees' request.
50 8701210057 861124 PDR ADOCK 05000320 G
4 1.
Rebuttal of Employees' Evidence e
The Employees cite, sa their chief evidence, that the Aamodes did not attend the hearing and s'averal. questions submitted by the Aamodts were Leproper (Employees, pp.4-5).
Neither citation supports the Employees' contention that the Aamodts did not contribute to the hearing.
No more than seven weeks prior to the Employees' notion, the Employees stated on the record (Tr. 2081) that the Aamodes' physical presence in the hearing was not requisite to their development of evidence on the record.
(The Employees were opposing the Aamodts motion for postponement of the hearing until they were able to attend.) Counsel for the Employees stated:
I would like to say that because this is a legislative proceeding, Mrs. Aamodt or Mr. Aamodt or whoever would participate on behalf of the Aamedts, could have participated by mail in sendina questions into the Board, along the way. She has done so with respect to a few witnesses and there has been no explanation as to why she could not have continued to do so.
(Emphasis added.)
Therefore, since the Aamodts sent questions for the witnesses through-out the hearing, the Employees cannot now assert that the Aamodts did not f
participate because they were not physically present in the hearing room.
I No party disagreed with the Employees' apprisal, supra, nor supported the Aamodes' notion for postponement to facilitate their physical presence in the hearing room (Tr. 2082-3). The Board ruled against a postponement in favor of providing for the Aamodes' participation, in absentia, by facilitating the Aamodes' submission of questions for the witnesses.
(The Board waived deadlines, agreed to take questions by telephone and by mail (Tr. 2084-6);)
Hence, the Employees, by their own statement, have admitted that the Aamodts could participate in the hearing, in absentia, thereby contributing to the record. The Employees cannot have it both ways. Neither can other parties who agreed with the Employees' apprisal and opposed l --
s Aamodts' rsquest fcr o p stpetemelt in crdcr to ho prce:st at tha hearing.
The Aamodts diligently submitted questions throughout the remainder of the hearing. They were hampered by inaccess to the transcript and not being present at the hearing. Nevertheless, they made a contribution. Its significance is yet to be seen when the Aamodts file findings of fact, and the Board makes it decision.
Had the Aamodts sent a single question, which was asked by the Board
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and which produced information critical to the resolution of the issue before the Board, the Aamodts would have contributed more to the record than a thousand questions provided by some other party with the interest of pro-tacting clients under investigation.
The Aamodts sent questions for 9 witnesses who appeared after the Board's decision that it would not postpone the hearing in order to facili-tate the Aamodes' attendance. Many of these questions were asked of the witnesses by the Board. The Employees' attempt (p.5) to denigrate the quality of the Aamodes' questions by pointin3 to a few instances, where-the' Board ruled against them,-
does not prove that other questions, the Board asked, did not contribute to the record.
In at least one instance, the Board specifically noted that the Aamodes' questions were " extensive" and " perfectly proper" (Tr. 3410, 3500).
Prior to their request for postponement, the Aamodts sent questions for technical witnesses, as requested by the Board. The Asmodt questions were directed to Messrs. Steir, Rockwell, Capra, Kirkpatrick, Christopher, and Russell. The Board found a single question objectionable (see Board Memorandum, July 30, 1986).
It shoul'd be noted that the Aamodts were the only party, other than the Ebployees, who submitted questions for the technical witnesses (Id.). !
S II.
Rebuttal of Empicymn' Arguments 4-The Employees claim that their motion is supported by NRC policy and practices. Nothing could be further from the truth.
The Ehployees acknowledge that NBC policy cited in their motion does not govern the instant proceeding. Thus, the Employees have selected certain principles, from policy governing other proceedings and assert i
that these principles apply to the Aamodes' behavior and that this should practices.
result in their dismissal (Employees, pp.6-7). The Employees provide no/
The principles the Employees cite (and which the Commission has ruled could lead to an imposition of a sanction in adjudicatory and licensing proceedings) are "unnet obligation", " potential harm to other parties",
and a " recurring pattern" of offending behavior.
The Employees state that the Aamodts have not met their obligation because they have not contributed to the record. However, as has been shown, supra, the geployees' evidence (attendance, quality of a few questions) does not support their finding.
The Employees argue that the Aamodts' absence from the hearing room was "a recurring pattern". This is a simplistic interpretation of a sinale aspect of the Aamodts' participation in gross contrast to other aspects. The Aamodts were present for two pre-hearing conferences, con-forence calls and two hearing discussions (via telephone and speaker).
The Aamodes made timely (and extensive) comments concerning the NRC's investigations in response to the Board's orders. The Aamodts made several motions concerning preliminary matters, including the provision of supplementary legal research as requested by the Board, and suggested witnesses and_ documents to be included in the hearing. These actions of the Aamodes were in addition to the provision of questions for the witnesses discussed, supra.
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s The Employ 3co' crgument, that the Aamod:s would crusa harm to oth:r parties by their filing of findings of fact, is particularly c:anfused.
(See Employees, pp. 5, 7.) The Employees argue that the Aamodes will not base their findings on the record of the proceeding because they are "with-out access to a complete transcript" and "have not... purchased a transcript of the hearing or borrowed a copy for their use."
This is not only untrue (the Asmodes had 8 days' transcripts in-hand at the time of the Employees' motion, and more are on the way), but the Employees should have been aware --
from the Aamodes' expressed interest in obtaining the transcript (Tr. 2074-5)--
that the Asmodts had taken necessary steps to obtain the transcript, or would, prior to filing findings of fact. The Employees should have been aware, from the findings of fact the Aamodes filed in the THI-Unit 1 proceeding and served on the Employees, that the Aamodts are fully aware of the general legal and NRC requirement that findings be referenced to the record.
(This Board has ruled that it will not consider any findings not referenced to the record, rendering moot the Employees' concerns (Order, November 14, 1986).)
However, the Employees' assertion that the Aamodes would use the record of another proceeding (the THI-Unit i restart proceeding), where the issue of the instant hearing was barely addressed, is simply preposterous.
(It was, in fact, the Employees who have interjected a relevant portion of the NRC's Safety Evaluation Report from the Unit 1 proceeding into the instant proceeding and who have raised the matter of practices at Unit 1!)
Most convoluted is the Esployees' assertion that other parties would be harmed should the Aamodes file findings while the Employees acknowledge that they and other parties have the opportunity to rebut any and all findings. _. - _
e Thus, the Employees have failed to show how the Aamodts' parti-o cipation is characterised by any of the three principles that could lead to a sanction in another hearing. The Employees utterly fail to support their demand for a sanction of the severity of dismissal. The h ployees provide no examples of NRC practice.
There are, however, eY.amples of NRC practices, with which the Employees should have been familiar, which are relevant to the Employees' notion. These fly in the face of the Employees' position.
The Union of Concerned Scientists (UCS) was permitted to file findings before the Commission (concerning the cheating of TMI operators) although UCS did not attend a single day of the hearing on this issue. UCS chen went on to argue this issue before the NRC Appeal Board and participate in a remanded hearing on the training of operators although UCS had not attended a single session of the hearing of the training issue.
The Licensing Board, which made the final decision concerning the 1
cheating of THI-Unit 1 operators, did not attend a single day of the hearing. The Board's decision and findings were preferred by the Commission to those of the judge who presided over the hearing.
UCS and the Commonwealth of Pennsylvania filed findings before the Commission and the Third Circuit Court concerning the NRC's foreclosure of a hearing on GPU management involvement in falsifications of leak rate reports at Unit 2.
Neither party was present at the initial hearing before the NRC Appeal Board when the issue was argued and from which the hearing they subsequently sought had been granted. Nevertheless, the Appeal Board invited parties, not present, to participate in the hearing granted. The Appeal Board believed that the resolution of the issue required all resources available (ALAB-738, August 31, 1983). !
Discussion The Aamodte sincerely regret their inability to attend the hearing of this proceeding. Theirrabsence was primarily due to the unforseen circumstances of their daughter's sudden illness on September 5, 1986, three days prior to the commencement of the hearing. As was explained, this led to three hospitalisations, two in distant cities, and the kind of disunition of resources and subsequent events that were responsible for the Aamodes' continued absence.
4 Had their motion for a postponement of two weeks been granted, the Aamodte believe that they would have been able to " catch-up" and attend the remainder of the hearing or have found a representative. As it was, the Aamodts struggled to participate, in absentia. Had they added the burdens of travel to and from Bethesda, Maryland and the extensive organi-sation that entailed, they would not have been able to provide as many qusstions for witnesses as they did.
Had the Aamodts believed that they would have succeeded in making a second motion for a postponement, they would have done so.
The Aamodes never abandoned their hope that they would be able to attend the hearing. They kept the Board informed concerning their problem =.
Even when a single witness remained to be hear, the Aamodes completed plans to travel to the hearing (1). Extremely hasardous road conditions on Tuesday, November 11, 1986 terminated those plans (2). The closest public i
means of transportation (a noon train), that would have made the trip pos-l sible, required at least 50 miles of travel on country roads. The airport, with a number of flights to Washington, D.C., would have required a hasardous trip of about 130 miles.
(1) Aamodt letter, November 12, 1986, to the Board, appended.
(2) News clippings describing hazardous road conditions, appended. L
a The Aamodes vero d:cply disrppoint:d that circumstancos b3y:nd chair control prevented their attendance from the beginning to the end of the hearing. They were particularly anxious to be at the final session for the questioning of John Herbein and to provide their questions for this witness to the Board. Their absences were in no way due to a lack of interest as can be attested by their continual submission of questions, purchase of transcripts, calls to the Board, and this response to the Baployees' notion.
Judge Kelly noted (Tr. 4614) that the Aamodts might not be able to attend a single session of the hearing. He stated that whether or not the Ammodes appeared was a matter of their choice. Neither the Board nor any of the parties warned the Aamodes that their continued absence would lead to any consideration of their dismissal. Clearly, the Employees' notion is too late.
Only the Employees have initiated an action to dismiss the Aamodes.
The Employees' notion reeks of insincerity. The Employees make no attempt to explain why they suggested to the Board that the Aamodes could as well i
participate in absentia (see p. 2, supra) if they now believe that the Aamodte needed to "see and hear the witnesses, to evaluate the candor and i
credibility of each individual" (Employees, p.8).
Why did the Employees wait until the last day of the hearing to state, for the first time, they objected to the Aamodes' absence? Why didn't the Employees object to the Aamodes' absence from the beginning if the Employees believe, as they now state, that the Aamodes needed to personally observe each witness in order to make findings on his_ testimony? Would the Employees ha e invited the Aamodts' subjective evaluation of the witnesses' (the Employees) credibility from their demeanor on the stand if the Aamodte had, indeed, been present to observe the witnesses? How would the Employees, allegedly concerned i
about the Aamodts' referencing of findings, have proposed that subjective..
evaluations of credibility be rafsrcnced to ths rcccrd?
The apparent answers to all of the above questions reveal the transparency of the Employees' motives in making their motion. The Employees have siesed upon the unfortunate opportunity of the Aamodts'-
absence on the last day of the hearing to attempt to accomplish what the Employees wanted from the beginning. The Employees were the single party to oppose the Aamodes' petition for leave to be a party.
The Employees should know that there are better ways of determining the credibility of witnesses 1than the subjective judgements of court room observers. The use of polygraphs would have provided more probative evidence l
than the subjective judgements the Employees suggest. The evidence on the record should be sufficient to determine the credibility of the witnesses.
The Board must have been satisfied with the record evidence since it ordered that all findings be referenced to the record.
The Aamouts take this opportunity to assure the Board that they are interested in filing findings of fact. They understand the arduous task that is involved. However, they have no other opportunity for their interests to be represented before the Board. The Board has ruled (November 14, 1985) that it need not consider record evidence not presented in findings by a party.
The Board explained how a party, not filing findings would be af fected:
... failure to file would result in your not having anything con-sidered, as far as we are concerned. This includes the intervenor I
party...the Aamodes.
"(Tr. 5326).
)
The deadline for filing -findings for all parties, January 9,1987, is not sufficient, upon reconsideration of the amount of work required and the Aamodt family schedule for December.
(Making this response has taken considerably longer than expected.) The Aamodts request until February 9,198T eo file findings. These will be chiefly directly at individual responsibility and will, coincide in time with the deadline.-
for the Employees.
We request GPU's provision of the complete Steir report.
Conclusions TheeEmployees' notion should be denied. The Employees have not provided a single reliable basis for the action they seek. The Employees' notion is untimely. The Employees' request for dismissal of the Aamodts would serve no purpose other than to deny the Aamodes' interest in the outcome of the proceeding. The Aamodes have participated and contributed to the record,,in good faith, to the full extent of their resources.
THEREFORE, the Aamodes ask this Board to deny the Employees' notion.
Respectfully submitted, A
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Harjo(ie M. Aesodt November 24, 1986
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I BOX 652, Lake Placid, N.Y. 12946 Tel. 518-523-2370 DESTINATION: 301-492-7285 THE FOLLOWING 8 PAGES ARE FOR JUDGE JAMES KELLEY. KINDLY NOTIFY AT HIS EXTENSION 927922) AND/0R. DELIVER IMMEDIATELY TO HIS OFFICE OR TO HIM AT THE NRC HEARING ROOM, FIFTH FLOOR, EAST-WEST TOWERS BLDG., BETHESDA, MD.
fNKYOU.sz 4..M Marjori( M. Aamodt l
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Box 652.
Lake Placid, N.Y. 12946 November 12, 1986 Judge James Kelley Atomic Safety & Licensing Board U.S. Nuclear Regulatory Commission Washington, D.C. 20555
Dear Judge-Kelley:
Our plans to travel to Washington yesterday were interrupted by snowfall which began about 8. a.m. and continued all day. The roads were slippery on the N.Y. Thruway, the only' exit route. Therefore, we considered the trip too risky to venture. We have other plans in the Philadelphia area for the rest of the week, therefore, we will be starting out today. If the hearing continues past today, we would appreciate a call to our home in Lake Placid to leave a meassage.
I trie_ to reach your office yesterday to notify you of our change in plans; however the holiday was in effect. I called to speak with Ms. Davis this morning or to you; however neither of you were available.
We,had hoped to carry a few questions for Mr. Herbein. They are being provide'd with this letter in the event that they will not arrive too late.
1 l
In the event that there is no further opportunity to address open matters, I take this opportunity to again bring my concern that the i
evidence that exists in the minutes of meetings during the time peried in question is not being utilized. In view of the lapses of memory of witnesses and incredible denials, the minutes could provide resolution.
Mehler and Chastywk admitted'(Ex.12,22, CI Report) that the minutes of 1
the shift supervisors' meeting likely contain discussions of leak rate testing problems. If minutes of POD and PORC meetings exist, they would be clearly relevant. The PORC minutes for October and November 1978 meetings may close some gaps in the Seelinger testimony.
1 We would appreciate the opportunity to provide the Board with l
our findings and conclusions. In that regard, we would 'suggest a.
j realistic schedule in view of the voluminous amount of information.
We find, in reading portions of the transcript of the hearing, that we do not have relevant sections of the Steir Report. We would appreciate GPU's provision of the complete report (less the introductory and summary volume).
incerely yours l
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Ja 931 t
( Marjorfe M. Aamodt
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4-4 QUESTIONS FOR JOHN HERBEIN 1.
When did you first become aware of the loop seal in the makeup tank level instrumentation' of Unit 2?
I 2
What was the function of a loopseal in the makeup tank level instru-mentation?
3.
In your deposition by the NRC on February 15, 1984, you stated at p.23 (attached) that "(you) don't fully understand -the physics" of the effect of the addition of hydrogen on the makeup tank level.
In light of the interests of the Department of Justice and the NRC in determining whether or not hydrogen additions were made to falsely obtain " good" leak rates, why had you not developed this understanding by 19847 i
4.
What is your present understanding of the effect of hydrogen additions on the makeup tank level?
5.
According.to the,Faegra and Benson investigation (Report Vol.2, pp.93-107), the oscillations and lack of control of plant parameters existed throughout the operation of Unit 2.
What was your knowledge of these conditions prior to the accident and what did -these condi-tions, if known to you, indicate concerning the capability of the operators to obtain valid tests of unidentified leakage?
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6.
What was your. knowledge, prior to the accideat, of leakage problems at Unit 27 7.
If the code safety valves,apd/or the PORY were scheduled for replace-ment, what would your responsibilities have been in making that decision? What would have been the budgetary considerations in making major valves replacements? Was your advise and approval mandatory?
8.
Were either the code safety valves or the PORV scheduled for replace-ment?
9.
Shortly before the accident, had you been advised by the manufacturer of either the valves or the plant, that you should shutdown to replace or repair the valves? Did this advise come with the urgency of a telegram communication?
- 10. Could you distinguish between leakage from the code safety valves and the PORV7 If not, could the combined leakage from these valves be properly classified as " identified"?
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. e HERBEIN (Page 2)
Refer the witness to testimony of February 15, 1984, p.14 (attached) where he states that Unit 1 was a tight plant in 1978-79 and "that we didn't have particular problems with leak ' rates", and p.15 (attached) where he implies that the leakage at Unic 1 during startup cobid have caused problems
-in leak ra,te surveillance'.
ii. How should'your knowledge of extensive and increasing leakage.from the code safety valves and/or'PORV at Unit 2,*:if you had such knowledge, have alerted you to inquire about. leakage surveillance in view of your testimony in 1984 that you were. aware of the relevance at Unit I?
- 12. Did you accept as valid the negative leak rate test results that you received on the daily plant status report?
- 13. What was your total knowledge concerning the operators' problems in performing the surveillance of unidentified leakage at Unit 2?
- 16. What impor'tance did you assign to the test for unidentified leakage?
- 15. What information, other than the leak rate report, did you have available to quantify boundary leakage?
- 16. On p.25 pf your NRC interview (February 15, 1984), you stated that "I!m still no't sure that I fully understand all of the alleged moti-vations that are supposedly to have taken place on Unit II."
Did you attempt to gain understanding? If so, how? Did you speak with any of the operators about their problems with the leak rate surveil-lance?
(P. 25 is attached.)
- 17. What part do you have, if any, in the company's decision to limit the Faegre & Benson investigation to the technical aspects of the leak rate surveillance?
Are you aware of these investigators' expressed frustration in being unable to interview the operators?
- 18. On p.22 of your February 15, 1984 NRC interview (attached), you claim that you had only read " portions" of the Faegre and Benson report of 9/80.
How do you explain this seeming disinterest in a matter that was under investigation by the Department of Justice and NRC and which involved you and your company?
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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION I,'].h BEFORE THE PRESIDING BOARD
'86 DEC 18 A10:3 In the Matter of
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Docket No. LRP CFic:
E iI INQUIRY INTO THREE MILE ISLAND
)
DON i 'gu g'.
,j' UNIT 2 LEAK RATE DATA
)
FALSIFICATION
)
This is to certify that copies of AAMODT RESPONSE TO EMPLOYEES MOTION TO DISMISS THE AAMODTS AS A PARTY TO THE PROCEEDING were served on the Service List by deposit in U.S. Mail, first class, postage prepaid, November 24p, 1986. Service to the Board was by Express Mail, overnight delivery gauranteed.
s Ac'IPdy Service List Chief, Docketing & Service Section Office of the Secretary U.S.
Nuclear Reyd.!atory Conunission Washington, D.C.
20'>S $
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James D.'Iturns, Esq.
I shatu, Lincoln & Beale Presiding Board, the I!oriorables 3 First National Plaza James L. Kelley Chairman Suite.5200 Glenn O.
Bright Chicago, IL 60602 Jerry R. Kline Atomic Safety and Licensing Board Pane)
Michael W.
Maupin U.S.
Nuclear Regula tory Comtnission llunton & Williams Washington, D.C.
20SSS 707 E.
Main St.
P.O.
Box 1535 Ernest L.
Blake, Huq.
Itichmond, VA 23212 Shaw, Pittman, Ibtts & Trowbridge 1000 M Street, ii. '. l.
Washington, D.C.
20036 li a r r y' II. VolyL, E: 4;.
LeBoeuf, Lamb, Leiby & Placitae 1333 New Itampshire Ave.,
N. / W.
Su i t.e 1100 l
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, buf0I Marjorile M. Aamodt November 24, 1986
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