ML20093H622
| ML20093H622 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 10/11/1984 |
| From: | Bauser D GENERAL PUBLIC UTILITIES CORP., SHAW, PITTMAN, POTTS & TROWBRIDGE |
| To: | UNION OF CONCERNED SCIENTISTS |
| References | |
| CON-#484-468 SP, NUDOCS 8410160330 | |
| Download: ML20093H622 (8) | |
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UNITED STATES OF AMERICA 45/4/
NUCLEam RaGULATORY COnnISSION h.hm' u[j E
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BEFORE TME ATOMIC 8AFETY AND LICEN8ING BOARD In the Matter of
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METROPOLITAN EDISON COMPANY
)
Docket No. 50-289 SP
)
(Restart-Management Romand)
(Three Mile Island Nuclear
)
Station, Unit No. 1)
)
LICENSEE'S ANSWERS TO UNION OF CONCERNED SCIENTIST 8' SIXTH SET OF INTERROGATORIES AND DOCUMENT REQUEST 8 TO GENERAL PU1LIC UTILITIES Licensee General Public Utilities Nuclear Corporation (GPU Nuclear), pursuant to 10 C.F.R. 5 2.740b, hereby submits the following answers to " Union of Concerned Scientists' Sixth Set of Interrogatories and Document Requests to General Public Utilities."
License ='s answers and objections were discussed by counsel for Licensee and counsel for the Union of Concerned Scientists ("UC8") yesterday.
The provision of arswers to these interrogatories is not to be deemed a representation that Licnnsee considers the information sought to be relevant to the issues to be heard in this remanded proceeding.
INTERROGATORIE8 6-1.
Mas the Reconstituted CARP Committee or any men-bers thereof undertaken any analyses, or investigations, gathered any further information or done any further work since the preparation of the special Report to prepare for the re-manded proceedings?
If so, h0kgO sse
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' Describe specifically the nature of the-a.
l analyses, investigations, information gathering or other work.
1 b.~
Identify the person (s) who performed the work.
1 c.
State when the work was performed.
7 d.
Provide all documentation of the work, including notes, memoranda, or any other docu-i ments.
e.
If further documents were reviewed, identi-fy each and state the purpose for which it was reviewed.
6-2.
Has the ROARP Committee or any members thereof, since the preparation of the Special Report, interviewed or contacted individuals beyond those listed.in the Appendix to the Report?
If so:
o a.
Identify each person interviewed or con-tacted.
b.
State the purpose of the contact.
c.
State the topic and cubstance of.the con-tact.
d.
State when the interview or contact took place.
e.
State who in the ROARP Committee conducted the interview or contact.
f.
Provide all documentation of the interview or contact, including the notes of all parties-and any other documentation.
ANSWER & OBJECTION.
On September 21, 1984, Licensee reached an agreement with UCS, reflected in Licensee counsel's September 26, 1984 letter to counsel for UCS, as to the infor-mation Licensee would provide to UCS concerning the preparatory work of Licensee's expert witnesses, the members of the Reconstituted OARP Committee.
Consistent with the agreement reached, that information will be provided by October 15, 1984. '
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To-the extent UCS now seeks more information about Licens-ee's expert witnesses, in a discovery request that was served one day after the September 26, 1984 agreement letter was re-ceived by UCS, Licensee objects.
To the extent UCS Interroga-tories 6-1 and 6-2 request additional information, that infor-mation is beyond the scope of permissible discovery of expert witnesses, see Fed. R. Civ. P. 26(b)(4), or constitutes non-disclosable trial preparation or attorney work product ma-terials, see 10 C.F.R.
S 2.740(b)(2).
Like UCS, Licensee ob-jects to the. disclosure of such information.
See UCS' Response to Licensee's Second Set of Interrogatories to UCS, September 28, 1984, response to Interrogatory U-44.
6-3.
Provide all evaluations of Mr. Frederick since 1981, including but not limited to evaluations by Messrs. Long, Newton, Knief and Ross.
6-4.
Provide all evaluations of Mr. Long since 1981.
6-5.
Provide all evaluations of Mr. Newton since 1981.
6-6.
Provide all evaluations of the current GPU li-censed operator instructors since 1981.
OBJECTION.
Licensee objects to Interrogatories 6-3, 6-4, 6-5 and 6-6.
These interrogatories fall outside the scope of interest of UCS in the remanded proceeding on training.
All of these interrogatories seek evaluations of training or manage-ment personnel (Mr. Frederick, Dr. Long, Mr. Newton, and li-censed operator instructors) since 1981.
It is TMIA and not UCS who is the lead intervenor on the' issues of (i) GPU Nucle-I ar's response to the problems in its training program, and (ii) l
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O adequacy of personnel responsible for the management and imple-mentation of the training program.
Interrogatories 6-3, 6-4, 6-5 and 6-6 fall squarely within TMIA's training issues.
Furthermore, Interrogatories 6-3 through 6-6'are signifi-cantly redundant with previous TMIA interrogatories Licensee already has answered.
See Licensee's Answers to Intervenor Three Mile Island Alert's Second Set of Interrogatories to Gen-e eral Public Utilities (Training), September 12, 1984, answers to Interrogatories 2-5, 2-6, 2-7, 2-9, 2-14 and 2-15.
6-7.
Provide all evaluations of Mr. Olive since 1981, i
including but not limited to evaluations by Messrs. Long, Newton, Knief, Ross and Frederick.
1 ANSWER & OBJECTION.
Licensee already has provided, in re-sponse to UCS' (First Set) of Interrogatories, Interrogatory 3(e), special training evaluations of Mr. Olive since 1981.
Also, of course, the requalification exams taken by Mr. Olive, which are training evaluations, already have been made avail-able to UCS.
In addition, Licensee has produced in the discov-ery reading room in response to UCS' (First Set) of Interroga-tories, Interrogatory 3(d), the available oral examination records for Mr. Olive since 1981.
Licensee also will make available in the discovery reading room the Employee Perfor-mance Review procedure and (blank) form used at GPU Nuclear.
Using this form, Operations management has appraised Mr. Olive.
To the extent UCS seeks the completed Performance Reviews of Mr. Olive, Licensee has provided its most recent completed an-nual evaluation of Mr. Olive in response to TMIA (second set) i
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a document production' request 26.
Because of the highly confi-dent'ial nature of Performance Reviews, and the absence of a showing by UCS of the need-for other evaluations of Mr. Olive in order to pursue the issue of the adequacy.of the TMI-1 li-censed operator training program, Licensee objects to the dis-closure of any other evaluations of Mr. Olive.
6-8.
State specifically what Mr. Frederick's duties were during his assignment to the training program, when they began and when they terminated.
State whether Mr. Frederick prepared and/or approved any examinations and, if so, identify.
ANSWER & OBJECTION.
Licensee objects to the first part of Interrogatory 6-9 for_the reasons stated in its objection to Interrogatories 6-3 through 6-6.
In sum, the question is not within the scope of issues on which UCS is the lead intervenor; moreover, see Licencee's response to TMIA (second set) Inter-rogatory 2-16.
Respectfully submitted, bMb.
" to 4 --
Ernest L. Blake, Jr.,
P.C.
Deborah B.
Bauser John N. Nassikas, III SHAW, PITTMAN, POTTS & TROWBRIDGE 1800 M Street, N.W.
Washington, D.C.
20036 (202) 822-1000 counsel for Licensee Dated:
October 11, 1984
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October 11, 1984
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'84 g y5 N0:41 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION GFFic:.w :... [2f BEFORETHEATOMICSAFETYANDLICENSINGBdkRb[h-In the Matter of.
)
)
METROPOLITAN EDISON COMPANY
)
Docket No. 50-289 I
)
(Restart-Management Remand)
(Three Mile Island Nuclear
)
Station, Unit No. 1)
)
CERTIFICATE OF SERVICE I hereby certify that copies of " Licensee's Answers to Union of Concerned Scientists' Sixth Set of Interrogatories and Document Requests to General Public Utilities" were served this lith day of October, 1984, by depcsit in the U.S. mail, first class, postage prepaid, to the parties on the attached Service List.
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Deborah B. Bauser I
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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD
_In the Matter
)
)
METROPOLITAN EDISON COMPANY
)
Docket No. 50-289 SP
)
(Restart Romand on Management)
(Three Mile Island Nuclear
)
i Station, Unit No. 1)
)
SERVICE LIST Nunzio J.
Palladino, Chairman Administrative Judge U.S. Nuclear Regulatory Commission John H.
Buck Washington, D.C.
20555 Atomic Safety & Licensing Appeal Board Thomas M. Roberts, Commissioner U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Commission Washington, D.C.
20555 washington, D.C.
20555 Administrative Judge James K. Asselstine, Commissioner Christine N. Kohl U.S. Nuclear Regulatory Commission Atomic Safety & Licensing Appeal Washington, D.C.
20555 Board U.S. -Nuclear Regulatory Commissior Frederick Bernthal, Commissioner Washington, D.C.-
20555 U.S. Nuclear Regulatory Commission Washington, D.C.
20555 Administrative Judge Ivan W.
Smith, Chairman Lando W.
Zech Jr., Commissioner Atomic Safety & Licensing Board U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Commission Washington, D.C.
20555 Washington, D.C.
20555 i
Administrative Judge Adminissrative Judge Gary J. Edles, Chairman Sheld.on J. Wolfe Atomic Safety & Licensing Appeal Atomic Safety & Licensing Board Board U.S. Nuclear Regulatory Commissior U.S. Nuclear Regulatory Commission Washington, D.C.
20555 Washington, D.C.
20555 l
n
-4 Administrative Judge Mr. H:nry D. Nukill Gustave A. Linenberger, Jr.
Vice President Atomic Safety & Licensing Board GPU Nuclear Corporation U.S. Nuclear Regulatory Commission P.O. Box 480 Washington, D.C.
20555 Middletown. PA 17057 Docketing and Service Section (3)
Mr. and Mrs. Noman Aamodt Office of the Secretary R.D. 5 U.S. Nuclear Regulatory Cormaission Coatesville, PA 19320 Washington, D.C.
20555 Ms. Louise Bradford Atomic Safety & Licensing Board TMI ALERT Panel 1011 Green Street U.S. Nuclear Regulatory Commission Harrisburg, PA 17102 washington, D.C.
20555 Joanne Doroshow, Esquire Atomic Safety & Licensing Appeal The Cnristic Institute Board Panel 1324 North Capitol Street U.S. Nuclear Regulatory Commission Washington, D.C.
20002 l
Washington, D.C.
20555 Lynne Bernabei, Esq.
^
Jack R. Goldberg, Esq. (4)
Y pr ct Office of the Executive Legal
.F55 Connecticut Avenue Washington, D.C.
20036 U.S u
ear Regulatory Commission Washington, D.C.
20555 Ellyn R. Weiss, Esq.
Harmon, Weiss & Jordan Thomas Y.
Au, Esq.
2001 S Street, N.W.,
Suite 430 Office of Chief Counsel Washington, D.C.
20003 Department of Environmental Resources Michael F. McBride, Esq.
505 Executive House LeBoeuf, Lamb, Leiby & MacRae P.O.
Box 2357 1333 New Hampshire Avenue, N.W; Harrisburg, PA 17120 Suite 1100 Washington, D.C.
20036 Michael W.
Maupin, Esq.
Hunton & Williams 707 East Main Street P.O. Box 1535 i
Richmond, VA 23212 William T.
Russell Deputy Director, Division of Human Factors Safety Office of NRR Mail Stop ARS200 U.S. Nuclear Regulatory 1
Commission Washington, D.C.
20555 i
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