|
---|
Category:INTERROGATORIES; RESPONSES TO INTERROGATORIES
MONTHYEARML20148P2031988-04-0404 April 1988 NRC Staff Response to Supplemental Interrogatories from TMI Alert/Susquehanna Valley Alliance.* Related Correspondence ML20150F8851988-03-30030 March 1988 Answers to Sva/Tmi Alert Second Set of Interrogatories to Util.* Submits Responses to Sva/Tmi Alert 880315 Interrogatories.W/Certificate of Svc.Related Correspondence ML20150D0561988-03-21021 March 1988 Valley Alliance/Tmi Alert Second Set of Interrogatories & Request for Production of Documents to NRC Staff.* Certificate of Svc Encl.Related Correspondence ML20150D0441988-03-21021 March 1988 Valley Alliance/Tmi Alert Second Set of Interrogatories & Request for Production of Documents to Gpu Nuclear.* Related Correspondence ML20149N0461988-02-22022 February 1988 NRC Staff Response to Interrogatories from TMI Alert/Sva.* Responds to Interrogatories Filed by TMI Alert/Sva on 880207.NRC Waived Requirement for Order from Presiding Officer Directing Discovery.Related Correspondence ML20196F1181988-02-22022 February 1988 Responses to NRC Interrogatories.* All Responses Re Disposal of Accident Generated Water by Intervenor F Skolnick. Certificate of Svc Encl.Related Correspondence ML20149M8671988-02-22022 February 1988 Licensee Response to Sva/Tmi Alert Request for Production of Documents.* Documents Re Disposal of accident-generated Water Will Be Made Available for Insp & Copying as Listed. Certificate of Svc Encl.Related Correspondence ML20149M8621988-02-19019 February 1988 Licensee Answers to Sva/Tmi Alert Interrogatories to Gpu Nuclear Corp.* Responds to Sva/Tmi Alert Interrogatories Re Disposal of accident-generated Water.Related Correspondence ML20149K8801988-02-15015 February 1988 Valley Alliance/Tmi Alert Responses to Licensee Interrogatories & Request for Documents.* Info Will Be Provided Upon Availability & Listed Documents Being Sent to Licensee.W/Certificate of Svc ML20196D3731988-02-0303 February 1988 Valley Alliance/Tmi Alert Interrogatories & Request for Production of Documents to Util.* Original Documents Identified in Answers to Listed Interrogatories Requested.W/Certificate of Svc.Related Correspondence ML20196D3921988-01-31031 January 1988 Valley Alliance/Tmi Alert Interrogatories & Request for Production of Documents to Nrc.* NRC Must Produce Any Addl Documents Responsive to Request.Certificate of Svc Encl.Related Correspondence ML20148U5331988-01-29029 January 1988 Licensee Interrogatories & Request for Production of Documents to TMI Alert & Susquehanna Valley Alliance.* Joint Intervenors Should Produce Original Documents Noted in Interrogatories.W/Certificate of Svc.Related Correspondence ML20235B6151987-09-18018 September 1987 NRC Staff Sixth Supplemental Response to Gpu Nuclear Corp First Set of Interrogatories.* Staff Intends to Call C Barus as Rebuttal Witness.W/Certificate of Svc.Related Correspondence ML20214S0551987-06-0202 June 1987 Gpu Nuclear Response to NRC Staff Request for Production of Documents.* Request 1 Overly Broad,Burdensome & of Limited Relevance.Request 2 Vague.Related Correspondence ML20207S5861987-03-18018 March 1987 NRC Staff Response to Gpu Nuclear Corp Second Set of Interrogatories to NRC Staff & Fourth Request for Production of Documents.* W/Certificate of Svc.Related Correspondence ML20212N4831987-03-0505 March 1987 Gpu Nuclear Corp Response to NRC Staff Second Request for Documents.* Notes of Interviews Conducted by Stier or Associates & Certificate of Svc Encl.Related Correspondence ML20212K3891987-03-0303 March 1987 NRC Response to Gpu Nuclear Corp Third Request for Production of Documents.* Certificate of Svc Encl.Related Correspondence ML20212F9481987-03-0202 March 1987 Gpu Nuclear Corp Second Set of Interrogatories to NRC Staff & Fourth Request for Production of Documents.* NRC Should Produce All Documents Required to Be Identified by Listed Interrogatories.W/Certificate of Svc.Related Correspondence ML20211F5331987-02-19019 February 1987 Gpu Nuclear Corp Response to NRC Second Set of Interrogatories.* Persons Attending 830323 Meeting Re R Parks Public Statement Listed.Certificate of Svc Encl. Related Correspondence ML20211D6811987-02-19019 February 1987 NRC Fifth Supplemental Response to Gpu Nuclear Corp First Set of Interrogatories & Request for Production of Documents.* Affidavit of MT Masnik Encl.Related Correspondence ML20212R6771987-01-29029 January 1987 NRC Staff Second Set of Interrogatories & Request for Documents to Gpu Nuclear Corporation.* Requests Info on 830323 Meeting W/Bechtel & Transfer or Removal of R Parks. W/Certificate of Svc.Related Correspondence ML20212R6501987-01-27027 January 1987 Gpu Nuclear Corp Third Request for Production of Documents.* W/Certificate of Svc.Related Correspondence ML20207P7141987-01-13013 January 1987 Gpu Second Request for Production of Documents.* Gpu Requests That NRC Identify Title,General Subj Matter,Date, Author & Reason Why Documents Requested Being Withheld. Related Correspondence ML20207N6721987-01-0909 January 1987 NRC Staff Fourth Supplemental Response to Gpu Nuclear Corp First Set of Interrogatories & Request for Production of Documents.* Certificate of Svc Encl.Related Correspondence ML20207N7081987-01-0909 January 1987 Second Supplemental Response of Gpu Nuclear Corp to NRC Staff First Request for Production of Documents.* Certificate of Svc Encl.Related Correspondence ML20207N6911987-01-0909 January 1987 Third Supplemental Response of Gpu Nuclear Corp to NRC Staff First Set of Interrogatories.* Related Correspondence ML20207L9041987-01-0505 January 1987 NRC Staff Third Supplemental Response to Gpu First Set of Interrogatories & Request for Production of Documents.* MT Masnik & Me Resner 870105 Affidavits & Certificate of Svc Encl.Related Correspondence ML20207C4711986-12-22022 December 1986 Second Supplemental Response to NRC First Set of Interrogatories Re Util Organization & Witnesses.Certificate of Svc Encl.Related Correspondence ML20212D6651986-12-15015 December 1986 NRC Staff Second Supplemental Response to Gpu Nuclear Corp First Set of Interrogatories & Request for Production of Documents.* Unexecuted Affidavit of RA Meeks & Certificate of Svc Encl.Related Correspondence ML20211K2771986-11-13013 November 1986 Response to First Request for Production of Documents Re Basis for R Parks Removal from Test Working Group on 830223 & Parks Involvement W/Quiltech Co.Certificate of Svc Encl. Related Correspondence ML20215M9901986-10-29029 October 1986 First Supplemental Response to NRC First Set of Interrogatories Re Suspension of R Parks Employment at Facility Site.W/Certificate of Svc.Related Correspondence ML20211G5101986-10-28028 October 1986 Response to Interrogatories Re Bechtel Oct 1984 Rept, Rept of Bechtel North American Power Corp Re Allegations of Rd Parks & Eh Stier 831116 Rept, TMI-2 Rept-Mgt & Safety Allegations. Related Correspondence ML20215D8681986-10-0909 October 1986 First Request for Production of Seven Categories of Documents Re Basis for R Parks Removal from Testing Working Group on 830223 & Investigation of Parks Involvement W/ Quiltech Co.Related Correspondence ML20215D8781986-10-0909 October 1986 First Set of Interrogatories for Documents Re Identification of Util Employees Providing or Receiving Info Leading to Interrogation of Rd Parks Re Quiltech Co.Related Correspondence ML20215D8821986-10-0909 October 1986 Supplemental Response to Gpu First Set of Interrogatories & First Request for Documents Re Enforcement Action EA-84-137. Supporting Documentation & Certificate of Svc Encl.Related Correspondence ML20214R6291986-09-23023 September 1986 Response to Util First Set of Interrogatories & Partial Response to First Request for Production of Documents. Affidavits Encl.Related Correspondence ML20209G1681986-09-0404 September 1986 First Request for Production of Documents Identified in NRC Responses to Listed Interrogatories,Including Interrogatory 1(e) Re Protected Activity Engaged in by Parks Resulting in Alleged Discrimination Against Parks.W/Certificate of Svc ML20209G3181986-09-0404 September 1986 First Set of Interrogatories Re Removal of Rd Parks from Employment.W/Certificate of Svc ML20211E6311986-06-11011 June 1986 First Supplemental Answer to NRC First Interrogatories & Request for Production of Documents to C Husted.Rl Long Notes Produced Indicating Husted Met W/J Herbein on 811005. Related Correspondence ML20211E6601986-06-11011 June 1986 First Supplemental Answers to TMI Alert First Request for Production of Documents & First Interrogatories to C Husted. Rl Long Notes of 820527 Conversation W/Newton Encl.W/ Certificate of Svc. Related Correspondence ML20197C1931986-05-0808 May 1986 Answers to TMI Alert,Inc 860501 Supplemental Interrogatories.Certificate of Svc Encl.Related Correspondence ML20203L6011986-04-28028 April 1986 Responses to TMI Alert First Request for Production of Documents & First Interrogatories.Certificate of Svc Encl. Related Correspondence ML20141J3171986-04-23023 April 1986 Response to Util First Interrogatories & Request for Production of Documents Re Senior Reactor Operator Licensing Exams.Certificate of Svc Encl.Related Correspondence ML20141J4071986-04-23023 April 1986 Response to Husted First Interrogatories & Request for Production of Documents Re Alleged Cheating During Apr 1981 OL Exams.Certificate of Svc Encl.Related Correspondence ML20155F5471986-04-18018 April 1986 Supplemental Response to NRC Interrogatories 3 & 4 & Request for Production of Documents to Util.Certificate of Svc Encl. Related Correspondence ML20203B4121986-04-15015 April 1986 Response to First Interrogatories & Request for Production of Documents.Certificate of Svc Encl.Related Correspondence ML20203B6311986-04-14014 April 1986 Answers to Staff First Interrogatories & Request for Production of Documents.Related Correspondence ML20202G5381986-04-0909 April 1986 First Interrogatories & Request for Production of Documents to TMI Alert Re Apr 1981 Senior Reactor Operator Exam. Certificate of Svc Encl.Related Correspondence ML20202G7361986-04-0909 April 1986 Response to TMI Alert,Inc First Request for Production of Documents & First Interrogatories.Certificate of Svc Encl. Related Correspondence ML20202G6651986-04-0808 April 1986 C Husted Answers to NRC First Interrogatories & Request for Production of Documents.Certificate of Svc Encl.Related Correspondence 1988-04-04
[Table view] Category:LEGAL TRANSCRIPTS & ORDERS & PLEADINGS
MONTHYEARML20210B8491999-07-21021 July 1999 Exemption from Certain Requirements of 10CFR50.54(w),for Three Mile Island Nuclear Station Unit 2 to Reduce Amount of Insurance for Unit to $50 Million for Onsite Property Damage Coverage ML20206D4141999-04-20020 April 1999 Exemption from Requirements of 10CFR50,App R,Section III.G.2 Re Enclosure of Cable & Equipment & Associated non-safety Related Circuits of One Redundant Train in Fire Barrier Having 1-hour Rating ML20206T7211999-02-11011 February 1999 Memorandum & Order (CLI-99-02).* Denies C George Request for Intervention & Dismisses Subpart M License Transfer Proceeding.With Certificate of Svc.Served on 990211 ML20198A5111998-12-11011 December 1998 Comment Opposing Proposed Rule 10CFR50.65 Re Requirements for Monitoring Effectiveness of Maintenance at Nuclear Power Plants.Proposed Rulemaking Details Collaborative Efforts in That Rule Interjects Change ML20154G2941998-09-17017 September 1998 Transcript of 980917 Public Meeting in Rockville,Md Re License Transfer of TMI-1 from Gpu Nuclear,Inc to Amergen. Pp 1-41 ML20199J0121997-11-20020 November 1997 Comment on Pr 10CFR50 Re Financial Assurance Requirements for Decommisioning Nuclear Power Reactors.Three Mile Island Alert Invokes Comments of P Bradford,Former NRC Member ML20148R7581997-06-30030 June 1997 Comment on NRC Proposed Bulletin 96-001,suppl 1, Control Rod Insertion Problems. Licensee References Proposed Generic Communication, Control Rod Insertion, & Ltrs & 961022 from B&W Owners Group ML20078H0431995-02-0101 February 1995 Comment Opposing Proposed Rule 10CFR50 Re Shutdown & Lowpower Operations for Nuclear Reactors ML20077E8231994-12-0808 December 1994 Comment Supporting Proposed Rules 10CFR2,51 & 54 Re Rev to NRC NPP License Renewal Rule ML20149E2021994-04-20020 April 1994 R Gary Statement Re 10 Mile Rule Under Director'S Decision DD-94-03,dtd 940331 for Tmi.Urges Commissioners to Engage in Reconsideration of Author Petition ML20065Q0671994-04-0707 April 1994 Principal Deficiencies in Director'S Decision 94-03 Re Pica Request Under 10CFR2.206 ML20058A5491993-11-17017 November 1993 Exemption from Requirements in 10CFR50.120 to Establish, Implement & Maintain Training Programs,Using Sys Approach to Training,For Catorgories of Personnel Listed in 10CFR50.120 ML20059J5171993-09-30030 September 1993 Transcript of 930923 Meeting of Advisory Panel for Decontamination of TMI-2 in Harrisburg,Pa.Pp 1-130.Related Documentation Encl ML20065J3461992-12-30030 December 1992 Responds to Petition of R Gary Alleging Discrepancies in RERP for Dauphin County,Pa ML20065J3731992-12-18018 December 1992 Affidavit of Gj Giangi Responding to of R Gary Requesting Action by NRC Per 10CFR2.206 ML20198E5581992-12-0101 December 1992 Transcript of Briefing by TMI-2 Advisory Panel on 921201 in Rockville,Md ML20210D7291992-06-15015 June 1992 Exemption from Requirements of 10CFR70.24 Re Criticality Accident Requirements for SNM Storage Areas at Facility Containing U Enriched to Less than 3% in U-235 Isotope ML20079E2181991-09-30030 September 1991 Submits Comments on NRC Proposed Resolution of Generic Issue 23, Reactor Coolant Pump Seal Failure. Informs That Util Endorses Comments Submitted by NUMARC ML20066J3031991-01-28028 January 1991 Comment Supporting SECY-90-347, Regulatory Impact Survey Rept ML20059P0531990-10-15015 October 1990 Comment Opposing Proposed Rules 10CFR2,50 & 54 Re Nuclear Power Plant License Renewal ML20059N5941990-10-0404 October 1990 Transcript of 900928 Public Meeting in Rockville,Md Re Studies of Cancer in Populations Near Nuclear Facilities, Including TMI ML20055F4411990-06-28028 June 1990 Comment Supporting Petition for Rulemaking PRM-50-55 Re Revs to FSAR ML20248J1891989-10-0606 October 1989 Order.* Grants Intervenors 891004 Motion for Permission for Opportunity to Respond to Staff Correspondence.Response Requested No Later That 891020.W/Certificate of Svc.Served on 891006 ML20248J1881989-10-0303 October 1989 Motion for Permission for Opportunity to Respond to Staff Correspondence in Response to Board Order of 890913.* Svc List Encl ML20248J0301989-09-29029 September 1989 NRC Staff Response to Appeal Board Order.* Matters Evaluated in Environ Assessment Involved Subjs Known by Parties During Proceeding & Appear in Hearing Record & Reflect Board Final Initial Decision LBP-89-7.W/Certificate of Svc ML20247E9181989-09-13013 September 1989 Order.* Requests NRC to Explain Purpose of 890911 Fr Notice on Proposed Amend to Applicant License,Revising Tech Specs Re Disposal of Accident Generated Water & Effects on ASLB Findings,By 890929.W/Certificate of Svc.Served on 890913 ML20247G0361989-07-26026 July 1989 Transcript of Oral Argument on 890726 in Bethesda,Md Re Disposal of accident-generated Water.Pp 1-65.Supporting Info Encl ML20247B7781989-07-18018 July 1989 Certificate of Svc.* Certifies Svc of Encl Gpu 890607 & 0628 Ltrs to NRC & Commonwealth of Pa,Respectively.W/Svc List ML20245D3651989-06-20020 June 1989 Notice of Oral Argument.* Oral Argument on Appeal of Susquehanna Valley Alliance & TMI Alert from ASLB 890202 Initial Decision Authorizing OL Amend,Will Be Heard on 890726 in Bethesda,Md.W/Certificate of Svc.Served on 890620 ML20245A5621989-06-14014 June 1989 Order.* Advises That Oral Argument on Appeal of Susquehanna Valley Alliance & TMI Alert from Board 890202 Initial Decision LBP-89-07 Authorizing OL Amend Will Be Heard on 890726 in Bethesda,Md.W/Certificate of Svc.Served on 890614 ML20247F3151989-05-22022 May 1989 NRC Staff Response to Appeal by Joint Intervenors Susquehanna Valley Alliance/Tmi Alert.* Appeal Should Be Denied Based on Failure to Identify Errors in Fact & Law Subj to Appeal.W/Certificate of Svc ML20246Q2971989-05-15015 May 1989 Comment Opposing Proposed Rule 10CFR50 Re Ensuring Effectiveness of Maint Programs for Nuclear Power Plants ML20246J6081989-05-12012 May 1989 Licensee Brief in Reply to Joint Intervenors Appeal from Final Initial Decision.* ASLB 890203 Final Initial Decision LBP-89-07 Re Deleting Prohibition on Disposal of accident- Generated Water Should Be Affirmed.W/Certificate of Svc ML20247D2761989-04-20020 April 1989 Transcript of 890420 Briefing in Rockville,Md on Status of TMI-2 Cleanup Activities.Pp 1-51.Related Info Encl ML20244C0361989-04-13013 April 1989 Order.* Commission Finds That ASLB Decision Resolving All Relevant Matters in Favor of Licensee & Granting Application for OL Amend,Should Become Effective Immediately.Certificate of Svc Encl.Served on 890413 ML20245A8381989-04-13013 April 1989 Transcript of Advisory Panel for Decontamination of TMI-2 890413 Meeting in Harrisburg,Pa.Pp 1-79.Supporting Info Encl ML20245A2961989-04-13013 April 1989 Transcript of 890413 Meeting in Rockville,Md Re Affirmation/Discussion & Vote ML20248H1811989-04-0606 April 1989 Valley Alliance/Tmi Alert Motion for Leave to File Appeal Brief out-of-time.* W/Certificate of Svc.Served on 890411.Granted for Aslab on 890410 ML20248G0151989-04-0606 April 1989 Valley Alliance/Tmi Alert Motion for Leave to File Appeal Brief out-of-time.* Requests to File Appeal Brief 1 Day Late Due to Person Typing Document Having Schedule Problems ML20248G0261989-04-0606 April 1989 Susguehanna Valley Alliance/Tmi Alert Brief in Support of Notification to File Appeal & Request for Oral Argument Re Appeal.* Certificate of Svc Encl ML20248D7211989-04-0404 April 1989 Memorandum & Order.* Intervenors Application for Stay Denied Due to Failure to Lack of Demonstrated Irreparable Injury & Any Showing of Certainty That Intervenors Will Prevail on Merits of Appeal.W/Certificate of Svc.Served on 890404 ML20247A4671989-03-23023 March 1989 Correction Notice.* Advises That Date of 891203 Appearing in Text of Commission 890322 Order Incorrect.Date Should Be 871203.Certificate of Svc Encl.Served on 890323 ML20246M2611989-03-22022 March 1989 Order.* Advises That Commission Currently Considering Question of Effectiveness,Pending Appellate Review of Final Initial Decision in Case Issued by ASLB in LBP-89-07. Certificate of Svc Encl.Served on 890322 ML20236D3821989-03-16016 March 1989 Valley Alliance & TMI Alert Motion for Extension of Time to File Brief in Support of Request for Appeal in Matter of 2.3 Million Gallons Of....* Certificate of Svc Encl.Served on 890316.Granted for Aslab on 890316 ML20236D3121989-03-15015 March 1989 Licensee Answer to Joint Intervenors Motion for Extension of Time to File Brief on Appeal.* Motion Opposed Based on Failure to Demonstrate Good Cause.W/Certificate of Svc ML20236D2901989-03-11011 March 1989 Valley Alliance/Tmi Alert Motion for Extension of Time to File Brief in Support of Request for Appeal in Matter of Disposal of 2.3 Million Gallons of Radioactive Water at Tmi,Unit 2.* Svc List Encl ML20236A3761989-03-0808 March 1989 Licensee Answer Opposing Joint Intervenors Motion for Stay.* Stay of Licensing Board Decision Pending Appeal Unwarranted Under NRC Stds.Stay Could Delay Safe,Expeditious Cleanup of Facility.Certificate of Svc Encl ML20236C2441989-03-0808 March 1989 NRC Staff Response in Opposition to Application for Stay Filed by Joint Intervenors.* Application for Stay of Effectiveness of Final Initial Decision LBP-89-07,dtd 890202 Should Be Denied.W/Certificate of Svc ML20235V2641989-03-0202 March 1989 Notice of Aslab Reconstitution.* TS Moore,Chairman,Cn Kohl & Ha Wilber,Members.Served on 890303.W/Certificate of Svc ML20235V2161989-02-25025 February 1989 Changes & Corrections to Susquehanna Valley Alliance/Three Mile Island Alert Documents Submitted on 890221.* Certificate of Svc Encl 1999-07-21
[Table view] |
Text
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'*- UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION Before the Atomic Safety and Licensik B r In the Matter of -)
) ~
METROPOLITAN EDISON COMPANY ) Docket No. 50-289
) (Restart-Management Phase)
(Three Mile Island Nuclear }
' Station, Unit.1) )
THREE MILE ISLAND ALERT'S SUPPLEMENTAL RESPONSE TO LICENSEE'S FIRST SET OF INTERROGATORIES Interrogatory Nos. T-4 and T-5 (a) 12323-2328; 2335-2347.
(b) Inspection Report 50-289,-84-05, which identified
" weaknesses" at p. 4-5; Notice of Violation dated July 22, 1983,
- p. 3.
(c) No disciplinary action was taken voluntarily or in
-some cases:at all, by Licensee against the following individuals for conduct described. in the following paragraphs:
Special Master Report 2d PID Robert C. Arnold 1237 John Herbein 1233 2306
. Gary Miller 1220-237 2272-2320 -
Jim Floyd 1220-237 2272-2320 Michael Ross 1137-178 Henry Shipman 194-110- 2139-2146 Charles Husted 1101-111 2148-2168 Mr.'I 124 Mr. A 124 Mr. P 1107-108 Mr. V 1112-132 Mr. GG 182-93 2133-2137
- Mr. G 126-77 2096-2121 Mr. H 126-77 2096-2121 Mr. MM 182-93
8409260283 840924 gDRADOCK 05000289 PDR
-- . .- . ~ -- -. . _ - , _ , . . .
, x. ,
ci-2-
4: i
~
l Interrogatory No. T-7 (a) i These pages ,,are referenced in the OARP Special Report at Fages 10-12.
Interrogatory Nos. T-14 and T-15(a) l 1
- (1) .12 - ALAB-772, p. 71, note 56.
(2)- 13~- ALAB-772, p. 71, note 56, in light of the OARP Special Report, pp. 45; 75, 11; 76, 16.
(3) 14 - ALAB-772, p. 71, note 56.
(4) 110.- ALAB-772, p. 71, note 56.
-Interrogatory No. T-19(a)
(1) The quality of instruction:
Milhollin Report, 1126-77, 241-248, 251; ASLB PID 12324; 2334-2347.
(2) The quality of instructors:
Milhollin Report, 1126-77; 101-111, 241-248; ASBL PID 12148-2168; 2334-2347.
(3) Poor training department management integrity and attitudes:
Milhollin Report, 194-111, 183, 316-317, 137-178.
ASLB PID 111138-2163, 2324, 2396, 2401-2403, 2407, 2411-2412.
1s_t ASLB PID - 1110 NUREG-0680, Supp. 5 at 11-8.
ALAB 772 at p. 71, note 56.
(4) Poor integrity and attitude of overall licensee management:
Milhollin Report, 1338 NUREG-0680, Supp. 5, Table 3.1.
- t. )
O TMIA's Response to Licensee's Interrogatories T-4 and T-5, paragraph 9.
(5) Management's failure to adequately respond to training problems:
Milhollin Report 1184-237, 250-254, 332-335.
ASLB PID - 12252, 2246, 2270, 2306-2307, 2318-2319, 2323-2328, 2331, 2411-2412.
I NUREG-06 80, ' Supp. 5 at 7-1 to 7-11.
Special Report at 130, 169.
ALAB-772 at 63, 64, 70, note 54, 71, 72, 75.
(6) Lack of integrity by the overall operations staff:
Milhollin Report at 18, 137-178,94-110, 24, 107-108, 112-132, 82-93, 338. .
ASLB PID - 12110, 2065, 2135, 2119, 2139-21d6, 2133-2137.
(7) Lack of respect for training by operators, training instructors, and training department personnel:
Milhollin Report, 119, 220-237, 248, 322-331, 338.
ASLB PID 12325-2328, 2416, 2396-2407, 2411-2412.
ALAB 772, at 64 and 75.
And citations listed in subsections 1, 2, 3, 4 above.
In addition, each criticism listed in Interrogatory 67 of TMIA's Second Set of Interrogatories to Licensee, except subsections (x), (aa) and (bb) , as cited in the RHR Report, and each criticism listed in Interrogatory 70 at TMIA's Second Set of Interrogatories to Licensee, at the pages cited therein.
a .
t 3>
Interrogatory No. T-19(b)
WhileLthe Special Master considered it to be the Licensing A
. Board's duty to develop specific recommendations regarding the tultimate' restart decision, and presumably whatever license condi-
.tionsishould-be. imposed to allow restart -(see, Milhollin Report at '1343) , , he . recognized that his~ conclusions would have " potential for determining the ultimate issues before the Licensing Board."
~ Iji . To the extent the Special Master's conclusions influenced tJus Licensing Board's decision to impose license conditions (PID,' ' 12347) , .these can ' be - found .at Milhollin, 1251.
Interrogatory No. T-25 i . (1) ' Stiff sanctions for drug abuse -- RHR at: II Explanatory E . Material, Motivation ~(Disciplinary Sanctions for Violating Regulations).
(2) Double standard for-disciplinary practices -- RHR at:
. II, Explanatory Material, gotivation (Disciplinary Sanc-tions for Violating Regulations).
(3) Insufficient supply of trainees - .RHR at: .II Explanatory
. Material, Supply of Trainees.
Interrogatory No.-T-29
- The'RHR and BETA reports.
Interrogatory Nos . T- 30 TMIA has relied upon the foilowing portions of the
.Special_ Report in formulating its response to Interrogatory T-29: l l
'n
-5.
9: 1 (1)
SpecialfReport at 1-3.
t
'(2)- Id. at?3-4,:71-73 (understanding of individuals who c'h eated derives -from GPUN -management) ; 81. (uncritical accept-ance.of management. memoranda); 84- 86.
- See also, Special. Report at 67 (GPU Nuclear has removed all
~
individuals to whom NRC . Boards lor . Commission raised objections) ;:
19 (best way;to' evaluate training programnis to lool. at steps GPU l
has taken'to develop: training program). !
'(3). Id.' at 7 (confidenceLin innovative approach has been fulfilled and justified); 7-8 -(cheating of operators different
'than for professionals); . 10 (steps.taken by GPU in response to .
'first OARP Report sufficient to solve problems); 16' (Committee not privyito:information about assignments and promotions within GPU: Nuclear-and therefore does not consider whether discipline appropriately taken and/or current management-of-Training Depart .
~
t 4 -ment ~ appropriately assigned);_25-27'(security measures will prevent-
~
cheating, rather than'a-program which commands respect by opera-tors); 28-37, (implementing the recommendations made by10ARP Review Committee in June, 1980-would resolve.the, problems found by the Appeal LBoard, -the ASLB and Judge _ Milhollin, although these problems had'not even been detected.by the OARP Review Committee in June, 3
- 1980); 44-45 (no indication that new programs rely less on memori-
- zation:oriemploy different teaching methods); 45 (no' indication -
~that management audits without operator confidence in integrity ,
of manag ment sufficient to cure lack of integrity in' training
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o program); 46 (no answerf to ' ALAB concern that operators' skills deteriorating from lack of use); 46 (premise in last paragraph
~
that high morale bf operators is demonstrated by low turnover where decisions and other audits indicate other indicators / evidence of morale problems); 47 (answer to ALAB concern about numerous
_ violations of operating procedures was that in narrow sense the
. violations were not attributable to improper / inadequate training);
47-48-(no support for statement that management totally supports 4
operators, when evidence cited in decisions indicates the reverse) ;
48-49 (no indication of basis / methodology for Kelly evaluation, in light of criticism formerly of GPU evaluation of exams) ; 48-49 (no indication of basis / evidence to support statement that program no longer overly emphasizes memorization); 52 (failed to answer adequately NRC Staff criticism that some operators needed additional training to improve operational skills which. declined during prolonged shutdown) ; 53-54 (no analysis of how program will resolve important problem that memorization previously stressed in training program); 55-57 (no analysis of serious question of whether or not format of GPU and NRC exams are adequate to test operators' skills) ;
65-68 (Review Committee appears to de-emphasize the importance of the cheating incidents by stating that cheating can be motivated by good intentions; does not state the root cause for the cheating; demonstrates no understanding of the particular individuals who were found to have participated in the cheating incidents; offers no guidance regarding appropriate discipline against these individuals; answers the Appcal Board's question by repeating its opinion that GPU training program has made " extra-ordinary progress": suggests that Special Master acted imprudently
by making judgments.about witnesses' credibility on the basis of their demeanor; and suggests that GPU has taken the cheating incidents and related NRC decisions too seriously); 69 (Dr.
Gardner fails to answer question about how cheating incidents, if known prior to 1980 opinion, would have influenced that opinion);
70-71 (Dr. Gardner's answers to questions posed on these pages indicate .that he does not believe operators' adherence to regula-tions and procedures and integrity are necessarily important in-dependent of whether or not they possess the skills necessary to operate the reactor safely) ; 72-73 (Committee could not answer ALAB question because little. time available and did-not speak with operators or monitor classes; reviewed only materials s.
prepared by GPU Nuclear); 73-74 (Committee refuses to answer
! ALAB question because subject to pending enforcement action; Committee appears to take its responsibilities to evaluate program 1
less seriously than GPU's best interest with regard to enforcement action); 75-79 ~(Committee largely relies on management's repre-sentations to determine whether or not adequate communication b'etween top management and operational staff; indicates it does not' take finding seriously that operators feel there exists a lack of communication which creates poor operator attitude).
(4) Id. at 7-8; 65-68; 70 (Gardner's primary concern is evaluation of- operator skills; shows little concern for operator integrity) ; 72.(little appreciation' demonstrated of importance .
of. adequate discipline; no understanding of participation by
- specific individuals in cheating incidents) . ,
(5) Id. at 72-73 (little time to speak to operators or monitor classes); 20-21 (indicates only review of paper program) .
r-
, i
>. -(6) See TMIA response to subpart (2) above.
TMIA also believes that the Reconstituted OARP Review Commit-tee ' evaluation of the training program varies radically from the l
evaluation of'the program which are drawn in the BETA and RHR Reports. By comparison, it is obvious that if the Review Commit-
. tee' did not find the same problems it did not address these criticisms and problems.
(7) Special Report at 25-27. This portion of the report appears to conclude that security procedures will solve the cheating. problems detected in the past. It does not analyze and/or examine whether poor operator attitudes were responsible for cheating and whether structural problems and lack of manage-ment. attention and integrity fostered these problems, as indicated in the relevant NRC decisions. See also Special Report at 46 and 80 regarding operator attitudes.
(8) jgg. at 28-41. The Review Committee states;that GPU has implemented most of the Review Committee recommendations but does-not examine that implementation to determine if in fact the -
underlying problems have been resolved. The BETA and RHR Reports indicate that even though corrective actions recommended by the Review Committee have been taken, the program is still inadequate to resolve the-underlying problems.
(9) See citations listed'in TMIA's Response to Licensee's First Set of Interrogatories and TMIA response to subpart (3) above.
(10). See citations in TMIA's Response to Licensee's First Set of Interrogatories; id. at 53-54 (no analysis of whether new program will resolve problems concerning memorization method of teaching); 55-57 (no analysis of whether current format of GPU
p- . .
- e. l
. and NRC exams adequate to test operators' skills) ; 65-69 (no analysis of root cause of cheating); 75-79 Ono analysis of com-munication betweq'n management and operators) .
'(11) See citations in TMIA's Response to Licensee's First I
Set of Interrogatories; id at 20; 44-45, 72-73 (Review Committee's l
limited time and failure to speak to operators or monitor classes adequately);
l (12) See citations in TMIA's Response to Licensee's First Set of Interrogatories.
(13) See citations in TMIA's Pesponse to Licensee's First Set of Interrogatories.
(14) Id. at 75-81; 72-73.
(15) See TMIA response to subparts 6, 9, 10. Further, the purpose of the Report, apparently to convince the Commission to permit restart prior to a decision on the merits on the training issue, indicates GPU's orientation to solve only those problems it is required by the NRC.to address and its lack of appreciation of the necessity to develop the capacity itself to identify problems. Id. at 3.
Respectfully submitted, O'3L W.G SIM Joanne Doroshow The Christic Institute 1324 North Capitol Washington, D.C. 20002 (202) 797-8106 A.M wb Ly(ne Bernabei vhrnment Accountability Project 5 Connecticut Ave. N.W.
l hington, D.C. 20036 l (202) 232-8550 DATED: September 24, 1984 Attorneys for Three Mile Island Alert
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