ML20010F893

Petition to Reopen Record for Further Investigation Re Apr 1981 Exam Cheating Incidents.Events Are Relevant & Matl to Issue of Mgt Capability to Operate TMI-1 Safely.Certificate of Svc Encl

ML20010F893
Person / Time
Site:	Three Mile Island
Issue date:	09/08/1981
From:	Bradford L THREE MILE ISLAND ALERT
To:	Atomic Safety and Licensing Board Panel
References
NUDOCS 8109150084
Download: ML20010F893 (6)

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BEFORE THE ATOMIC SAFETY AND LICENSING BOA SEP 1. I 1980 *  ?;

c - , ' " , c.- -e . 7 In the Matter of ) 4kf h' ' ',

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

(Restart) D\g / @'I19, Station, Unit No. 1) ) .

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N PETITION OF THREE '

C. .l MILE ISLAND ALERT TO c o, d.

REOPEN THE RECORD c) W /

4 TMIA petitions the Atomic Safety and Licensing Board to reopen the record of this matter for the purpose of further

) investigation of certain events leading up to and surrounding the April 1981 cheating incident, as such events are relevent and material to the issue of management capability to operate TMI-l safely, and respectfully represents in support thereof the following.

(1) The Board issued on the 20th day of August, 1981 an Order Relative to the Submission of Views on the Investigation of Cheating, providing parties the opportunity to submit their views on how this matter should be treated in the above docketed proceeding. This submission is pursuant to the August Order.

(2) We seek to prove that the cheatir incident of the 21st day of April, 1981 (a) was not an isolated event unrelated 3

to management practices at GPU (b) was fostered by prior manage D SO y I ment response to similar and/or related events (c) was further j [

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) induced by a lax, almost inviting atmosphere of careless and I haphazard monitoring.

(3) Certain evidentiary questions must be explored through discovery and cross-examination, as follows:

(a) Further investigation is needed of management's 4 handling of the July, 1979 incident of false submission of examination answers.

1 l In July, 1979 an employee of GPU (who subsequently has admitted to cheating on an NRC examination) submitted as his own work, the work product of another employee. Although GPU reportedly removed this individual from licencesed activ-ities, there is no indication in materials made available to parties, that this was other than a temporary action. See August 11, 1981 NRC 1E Report at page 18.

This incident occurred when there were already strong indications that operator error and lack of training had been a major contributing factor in the escalation of the TMI-II accident.

By his own admission, Mr. Robert C. Arnold was aware of the incident, and by his mild response, projected an attitude that GPU management was more concerned that candidates passed the examinations than whether they had mastered the course materials. See Id. at page 7.

There is no evidence that GPU made clear to other candidates for thG RO/SRO examinations, that similar instances ,

1 of misrepresentation or cheating, would not be tolerated by

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the utility.

(b) Further examination is needed of management's knowledge of.and/s . responsibility to know of, possible cheat-ing on the 2nd and 3r_ days of April, 1981 ' mock' RO/SRO examination n' aistered to GPU employees, and lack of respcase thereto.

There is no evidence that GPU or their agent ATT reviewed candidates answer sheets for cheating although

" distinct similarities" of approach were readily discerned by IE investigators. See Id. at page 17.

(c) Further investigation is needed of GPU management's lack of response to complaints received as to cheating during the 21st day of April, 1981 RO/SRO exams, l On the 28th day of July, 1981- Arnold advised investigators Baci and Gilbert that two RO's had complained l about cheating and ' crib' sheets during the subject examinations.

l L The lith day of August, 1981 REPORT OF INVESTIGATION t i is not clear from this statement, when this information became available to GPU, and what, if any actions they took to investigate the complaints.

(d) Further examination is needed of RO/SRO requalificat-ion examinations, dated the 2nd day of April, 1980 and the 3rd

, day of April, 1980 respectively. Although the report states that " a comparison of the two individuals' answers revealed no obvious similarities or other indications of improprieties",

it does not i..dicate whether the two individuals in questica

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passed or failed the examination. See Id. at page 18.

(e) If in the one to one relationship between inter-viewer and interviewee there evolves a free and uninhibited investigation, management intrusion into that relationship 1

effectively stifles that relationship. 8ec ]Ud AI page 7.

For all the foregoing reasons it is requested that the Board reopen the recorti to consider GPU management practices that led to the cheating incident and that are relevent to GPU managements' ability to manage the operation of TMI-I

! as requ, ired by the 9th day of August, 1979 Order, CLI-79-8, J

10 NRC 141 (1979).

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l Respectfully submitted, ,

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Louise Bradford Dated September 8, 1981 i

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UNITED STATES OF AMERICA NUCLEAR REGULATORY COletISSION i BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of )

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METROPOLITAN EDISON COMPANY )

) Docket No. 50-289 (Three Mile Island Nuclear ) (Restart)_

Station, Unit No. 1) )

r CERTIFICATE OF SERVICE I hereby certify that copies of the attached "TMIA's Motion to Reopen the Record" were served this 8th day of September, 1981, by deposit in the U.S. Mail, first class postage prepaid to the parties identified on the attached Service List, except that the following parties were served by express mail: the Board members and Professor Milhollin.

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LOUISE BRADFORD /'

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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION

. BEFORE THE ATOMIC SAFETY AND LICENSING E R_D In the Matter of )

Metropolitan Edison Company, Docket No. 50-289 Three Mile Island Nuclear ) (Restart)

Station. Unit No. 1) )

i SERVICE LIST

• George F. Trowbridge , Esquire Dr. Linda W. Little Shaw, Pittman, Fatts & Trowbridge Atomic Safety & Licensing 1800 M. Street, N.W.

Washington, D.C. 20006 Board Panel 5000 Hermitage Drive Ms. Margorie M. Aamodt Raleigh , North Carolina , 27612 R.D. # 5 Coatsville, Pa., 19320 Docketing & Service Section '

Office of the Secretary U.S. Nuclear Reglatory Com.

Ms. Gail Bradford Wanhington, D.C. 20555 ANGRY .

245 W. Philadelphia St. Ellyn R. Weiss York, Pa., 17404 Sheldon, Harmon, Roisman & Weisc 1725 I Street ,

Robert Q. Pollard & Steven C. Sholly Washington, D.C.N.W. Suite 506 20006 Union of Concerned Sciq$ists 1725 I Street, N.W., Suite 601 Washington, D.C. 20006 James A. Tourtellotte Esauire Office of the Executive Ldgal Dir.

Walter W. Coher., Esquire U.S. Nuclear Regulatary Commission Washington , D.C. 20555  !

Consumer Advocate Department of Justice John A. Levin, Esquire Strawberry Equare,14th Floor Assistant Counsel Harrisburg, Pa. ,17127 Pennsylvania Public Utility Com.

Dr. Chauncey Kepford P.O. Box 3265 Harrisburg , Pa . , 17120 Dr. Judith H. Johnsrud ECNP Jordan D. Cunningham, Esquire 433 Orlando Avenue Attorney for Newberry Townshp State College, Pa., 16801 T.M.I. Steering Committee Ivan W. Smith, Esquire, Chairman 2320 North Second Street Harrisburg, Pa., 17110 Atomic Safety & Licensing Board Panel U.S. Nuclear Regulatory Commission Karin W. Carter, Esquire Washington, D.C. 20555 Robert Adler, Enquire Assistant Attorney General Dr. Walter H. Jordan 505 Executive House Atomic Safety & Licensing Board Panel P.O. Box 2357 881 West Guter Drive Harrisburg, Pa. ,17120 Oak Ridge, Tennessee, 37830 Professor Gary L. Milhollin 1815 Jefferson St.

Madison, Wisconsin 53711