ML19257D744

Response to NRC First Set of Interrogatories.Intervenor Planned Testimony Will Involve Proposed Redesign to Minimize Operator Error,Stress Situations & Related Issues.Cites Names of Witnesses Expected to Be Called.Affidavit Encl

ML19257D744
Person / Time
Site:	Three Mile Island
Issue date:	01/15/1980
From:	Aamodt M AFFILIATION NOT ASSIGNED
To:	NRC OFFICE OF THE EXECUTIVE LEGAL DIRECTOR (OELD)
Shared Package
ML19257D745	List: ML19257D744 ML19257D748
References
NUDOCS 8002060021
Download: ML19257D744 (4)

Text

..

'

/ DCC "TED \

.

• pm conRESPONDDCE [ USNAC

,' , , UNITED S1'AIES OF AFERICA 7 21E0>$; '

< NUCliAR REGUT ATORY COMMISSION Off;ceof thafacretut BEIORE THE ATOMIC SAFETY AND IICERSING BOARD In the.'datter of ,7

$ han I

h g

MEIRGIOLITAN EDISCN COMPANY, et. al. Docket 50-239

,

(Three Mile Island, Unit -1 AK4GDT RESIONSE TO FIRST SET OF KRC STAFF INTERROGATORIsS TO INTERVEHORS The following information is provided for each admitted Aamodt contention: individuals that we intend to present as witnesses, a description of the substance of testimony of these witnesses, and identification of documents to be relied;upon in testimony. This information is as complete as we can make prior to discovery. We reserve the right,:if possible, to add or delete as new information becomes available or is discovered by us through interrogatories. We understand that this information should not be supplied for deferred contentions at this time.

Contention 2 relates to performance of technicians and management o f TMI-1. Witnesses expected to be called are personnel of NRC, Metropolitan Ediecn and Eabcock and Wilcox who are involved in the training or have been involved in the training of operating personnel and management of the nuclear generating plants at Three Mile Island.

NRC ' personnel involved in the licensing of nuclear generating plant personnel. TMI: operators, technicians and aanagers, lenn State employees proposed to oversee man-machine interface. Expert witnesses in the fields of human engineering and nuclear engineering, possibly, in &ddition to Fenn State personnel. NRC and Babcock and Wilcox engineers in area of system reliability.and safety.

Specific identity of all individuals is not possible before completion of discovery, however they would include Bruce A. Boger, Walter Haas, B. L. Grenier, R. M. Satterfield, Earrell Eisenhut, Harold Denton, Rbg~er. Mattson of IIRC; Leland Rogers, Ron Finnin, L. 1. Voyner, Gary Bennett of .3abcock and 'wilcox; James Seelinger, Joseph Logan, Michael Ross, Geroge Kunder, Gary Miller, Fred Scheimann, William Zewe, Edward Frederich, Craig Faust and John Herbein of Met Ed; Robert D. Pollard of Union of Concerned Scientists, Russell W. Peterson.

Testimony would be relative to 1) proposed redesign to minimize operator error, 2) types of accidents and probabilties of occurrence,

3) past and proposed training, testing and licasing of operators and

-. ~ . ._ : I '.

1927 007 G s002000 ozi

2

.

managers, 4) types of operator errors, 5) stress situations, 6) theory

'

• and documentation of proposed training and testing in context of established concepts of learning principles, 7) credentials and experience of trainers prior and proposed, .8) hiring interview, examination of operators and managers and 9) practices past and proposed for promotion.

Documents to be relied upon include those implied above as well as Reg. Guide 1.47, Kemeny Report including Staff Reports II, III, IV, 1;UREG 0578, 0600, 0616, NUREG/CP 0009, SECY 79-330 A thru F; Summary of Meeting Held on October 23, 1979 with Representatives of Babcock and Wilcox Owners' Group, B&W and Oak Ridge National Laboratory to Discuss the " Integrated Control System Reliability Analysis" EAW1564, Minutes of geeting August 23, 1979; October 25, 1979 letter of Harold Denton to H. G. Parris including enclosure; December 17, 1979 letter of Darrell Eisenhut to licensees and enclosures; draft report "Frelic-inary Human Factors Analysis of Zion Nuclear Fower 11 ant October,1975 Contention 3 relates to assessment of risk. Witnesses expected to be called are Dr. Roger E. Linneman, Radiation Management Corp.,

University City Science Center, 3508 Market St., Suite 400, Philadelphia, Fa.19104 and Dr. Mancuso, University of littsburgh on assessment of low-level radiation effects; also Russell W. Feterson, Audubon Society.

Documents to be reli,ed upon will include NUREG 0396, 0578, 0585 and 0616, licensee's emergency proposa), TDR -TMI -116 (Rev. 0 7/31/79),

Heidelberg Report, Kemeny Eeport Contention 4 relates to information. Witnesses expected to be called are Robert Arnold of Met Ed regarding time lag in dissemination of data and Roger Mattson and Dr. Joseph Hendrie of NRC regarding the impact of institv:ional considerations on timing of release of inform-ation; also Governor Richard Thronburgh and Oran Henderson, Director of Pennsylvania Emergency Management E A ency to define timeliness for various localities as a function of distance and population density dnd to describe Conditions that would prevent them from informing the public, i. e., restraints on disclosure relative to institutional judgements; also Fenrose Hallowell, Secretary of Agriculture of Penn-sylvania regarding what is timely to protect health and safety.of animals and keepers; also. Edward G. Elester, Attorney General of ~

Fennsylvania regarding whats effect the absence.of punitive enforce-ment has on the flow of information: This is relative to August 9 notice of hearing "to provide reasonable assurance.. ; al

3

.

Gary S,nyder, ERC Region 1 office relative to telephone conversations March 30, 3979 and prior; Iublic Affairs office lhiladelphia 31ectric Company regarding news releases January 1980 regarding shutdown of leach Bottom reactor.

Contention 5 relates to evacuation of livestock. Witnesses expected to be called include Penrose Hallowell relative to movement of cattle; also dairy farmers.

Documents to be relied upon include EUREG 0585, 0396, licensee's e,nergency plan, TDR-TMI 116(Rev 0 7/31/79), Kemeny Report Staff Report IV, Heidelberg Report.

Contention 6 relates to radwaste. Witnesses expected to be called-include ERC staff,and Walter Creitz and Robert Arnold of Met Ed to explain the lack of reliability of earlier projections relative to radwaste quantities and the lack of reliability in assessing future radwaste management capabilities. Ahso Russell W. Peterson, President.

of Audubon Society and member of Kemeny Commission and individual from Union of Concerned Scientists, yet to be identified, to explore reliability of onsite storage and projected transportation.

,

Documents to relied upon include NUREG C552, c575 Vol.1, 2xecutive Summary, Kemeny Report Contentions 6 and 11, part A have been deferred.

Respectfully submitted, __

'lLL % LL Ni. fl/.L:uY Marjddie M. Aamodt v

Lated, January 15, 1980 1927 009

.

'

,

UNITED STATES OF EERICA EUCLEAR REGULATORY COMMISSION BEFORE THE A'IOMIC SAFETY AND LICENSING BOARD

.

In the; Matter of )

"

EETROIOLITAN EDISON COMPANY ) Docket No. 50-289 (Three Mile Island Nuclear )

Station, Unit No. 1) ) .

AFFIDAVIT OF MARJORIE M. AMODT Commonwealth Pennsylvania County of Chester MARJORIE M. AAMODT, being duly sworn according to law, deposes and says that she is a resident of Chester County, wife of Norman O.

Aamodt and mother of Norman O. Aamodt, Jr. , Susan E. Aamodt and Jason B. Aamodt, formerly employed'by Bell Telephone Laboratories, Murray; Hill, New Jersey and the school district of Coatesville, Pennsylvania, graduate of Rutgers University and Brown University with B. S. mid M. S. degrees in Experimental Esychology; that the informatita contained in her Response to Interrogatory of NRC is true and correct to the best--of-her knowledge and belief. .

> -

~

t S .w.iul . /: . {ll%U

~Marjori'e M. Aamodt, Intervenor

-

..

Sworn and subscribed

.

,

before me this 15 day ,

of January,1979

,

c=ed L ur:  ::r; ca;c Ent Fd:dy.J Tc.. cW;. CL :ur Co..-ty

/ !.!y Co-cr.r. Ex;: :tr.1,192 -

Notary Iublic i Pe-ber, Pa=yh:a. 2w:bWn of Nc:: ,es 2 ' /- - p. 1927 010 My Commission expires s

4