ML20097C537
| ML20097C537 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 09/12/1984 |
| From: | Bauser D GENERAL PUBLIC UTILITIES CORP., SHAW, PITTMAN, POTTS & TROWBRIDGE |
| To: | UNION OF CONCERNED SCIENTISTS |
| Shared Package | |
| ML20097C487 | List: |
| References | |
| SP, NUDOCS 8409170132 | |
| Download: ML20097C537 (6) | |
Text
.
RELATED CC:i'. LTOnciNCF.
September 12, 1984 UNITED STATES OF AMERICA
- M NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of
)
)
METROPOLITAN EDISON COMPANY
)
Docket No. 50-289 SP
)
(Restart-Management Remand)
(Three Mile Island Nuclear
)
Station, Unit No. 1)
)
LICENSEE'S SECOND SET OF INTERROGATORIES TO UCS (TRAINING)
Pursuant to 10 C.F.R.
SS 2.740b and 2.741 and to the Atom-ic Safety and Licensing Board's " Memorandum and Order Following Prehearing Conference" of July 9, 1984,, Licensee hereby re-quests that intervenor Union of Concerned Scientists (UCS) an-swer separately and fully in writing, and under oath or affirmation, each of the following interrogatories, and produce and permit inspection and copying of the original or best copy of all documents identified in the response to these interroga-tories.
Licensee makes this request of UCS in its capacity as a lead intervenor on the issue of training.
Licensee has tried to limit its interrogatories of UCS to those areas of training in which UCS has asserted an interest.
Licensee's interrogatories are intended to be continuing in nature, and the answers should promptly be supplemented or amended as appropriate, pursuant to 10 C.F.R.
S 2.740(e),
MO9170132 840912 PDR ADOCK 05000289 e
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should UCS or any individual acting on its behalf obtain any new or differing responsive information.
The request for pro-duction of documents is also continuing in nature and UCS must produce immediately any additional documents it, or any indi-vidual acting on its behalf, obtains which are responsive to the request, in accordance with the provisions of 10 C.F.R.
S 2.740(e).
Licensee notes UCS's continuing obligation applies to interrogatories and requests for production of documents previously filed, particularly, questions to which UCS did not know the answer.
See UCS responses to Licensee Interrogatories U-6, U-9, U-10, U-ll, U-14, U-15, U-23, U-24, U-25, U-26, U-27 and U-28.
As used hereinafter, " document (s)" mean all writings and records of every type in the possession, control or custody of UCS or any individual acting on its behalf, including, but not limited to, memoranda, correspondence, bulletins, minutes, 4
i notes, speeches, articles, transcripts, testimony, voice re-cordings and all other writings or recordings of any kind;
" document (s)" shall also mean copies of documents even though the originals thereof are not in the possession, custody, or control of UCS.
Where identification of a document is re-quested, briefly describe the document (e.g., book, letter, memorandum) and provide the following information, as applica-bles document name, title, number, author, date of publication and publisher, addrassee, date written or approved, and the name and address of the person or persons having possession of,
the document.
Also i antify the specific portion or portions of the document (i.e., pages) upon which UCS relies.
INTERROGATORIES ON TRAINING U-29.
In view of UCS' response to Licensee's Interrog-atory U-4, please identify or provide UCS' definition or under-stand of the following standards:
(1) the skills and knowledge that are necessary to oper-ate the plant under accident or unusual conditions; (2) tests that are adequate to accurately evaluate wheth-er the operators possess the necessary skills and knowledge; (3) when memorization constitutes too great a role in the t
training and testing programs; (4) the specific " plant procedures and design" about with 4
which UCS is concerned that the licensed operator training and tests conform; (5) what constitutes a proper test review for difficulty and validity; (6) the " appropriate attitude" in the training and op-erations staff; d
(7) what constitutes " proper implemention of the licensed operator training program; (8) what constitutes adequate first-hand knowledge and observation by the Reconstituted OARP Review Committee; and (9) when instructors are " qualified and effective."
U-30.
For each item (1) through (9) identified in re-sponse to Interrogatory U-29, provide the basis on which UCS' l )
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identification, definition, or understanding is based, including but not limited to (a) the individuals on which opin-ions the answers are based; (b) all documents relied upon; (c) any criteria that form the basis for UCS' answers.
U-31.
Identify all of the specific changes in plant procedures to which UCS refers generally in its answer (subpart
- 4) to Licensee's Interrogatory U-5.
U-32.
For each change identified in response to Inter-rogatory U-31, identify all of the documents on which you rely in determining that it constitutes a procedural change.
U-33.
Identify the specific page or pages of the
" Speaker Report" on which UCS relies in its answer to Licens-ee's Interrogatory U-5, subpart 6.
U-34.
Identify the specific factors which constitute the " combination" to which UCS refers in its answer to Licens-ees Interrogatory U-5, subpdrt 7.
U-35.
Identify the specific " exams as described on the evidentiary record" to which UCS refers in its answer to Li-censee's Interrogatory U-19.
U-36.
Explain the basis for your statement, in re-sponse to Licensee Interrogatory U-28, that "UCS questions whether the qualifications of the committee members are ade-quate to permit them as a committee to reach many of the con-clusions contained in Chapter V."
U-37.
Identify all of the specific qualifications that you believe are lacking among the Reconstituted OARP Committee members. _
i r
P U-38.
Identify all of the statements or conclusions in Chapter V which form the basis for UCS' questioning of the qualifications of the Reconstituted OARP Committee members.
U-39.
Identify by name and/or title all individuals in GPUNC that UCS believes the Reconstituted OARP Committee mem-bers should contact in order to assess the adequacy of the cur-rent licensed operator training program.
U-40.
With respect to each individual identified in response to Interrogatory U-39, explain why, in UCS' view, it is necessary that the Committee contact the individual.
U-41.
Identify all expert consultants on whom UCS has or will rely in preparing a case on cross-examination of Li-censee's witnesses.
U-42.
For each individual identified in Interrogatory U-41 above, identify the specific subject area or areas of ex-pertise of the individual on which UCS is relying.
U-43.
Identify all persons UCS intends to call as a witness on the remanded issue of training, including individu-als UCS may seek to subpoena.
For each such person identified above, identify the following:
(a) the nature or substance of his testimony; (b) his qualifications, access to information, or other reason that he is being asked to testify as to the infor-mation identified in response to subpart (a) above; (c) his position or relationship to UCS at any time, including but not limited to any contracts, consulting 1,
arrangements, advisory positions or other relationships with UCS he has held or holds currently; (d) all technical documents he has reviewed or will review to prepare his testimony; (e) all persons (aside from counsel) whom he has consulted or will consult to prepare his testimony; (f) the nature and substance of any discussions, conversations, communications, and other contacts he has had or will have with the persons identified in response to subpart (e) above; (g) all documents he intends to rely on or use in support of any opinions, evaluations, conclusions, or recommen-dations he makes in his testimony; (h) the current location and custodian of all docu-
\\
l ments identified in response to subparts (d) and (g) above.
I U-44.
Identify and produce all documents which UCS in-tends to introduce in the hearing or through prefiled testimony on the remanded issue of training.
Respectfully submitted,
.i 2> M /h. W i
Ernest L. Blake, Jr.,
P.C.
Deborah B. Bauser SHAW, PITTMAN, POTTS & TROWBRIDGE 1800 M Street, N.W.
Washington, D.C.
20036 i
(202)922-1000 Counsel for Licensee -
RELATED CC;C.dC;; DEN,CE SIptcmber 12, 1984 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION
'84 M? I 4 b BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of
)
)
METROPOLITAN EDISON COMPANY
)
Docket No. 50-289
)
(Restart-Management Remand)
(Three Mile Island Nuclear
)
Station, Unit No. 1)
)
CERTIFICATE OF SERVICE I hereby certify that copies of " Licensee's Answers to In-tervenor Three Mile Island Alert's Second Set of Interrogato-ries to General Public Utilities (Training)," accompanied by Affidavits of Richard P. Coe, Eric Gardner, Robert E. Uhrig, Philip R. Clark, Robert L. Long, E. R. Frederick, H. D.
- Hukill, Samuel L. Newton, Michael J. Ross, Sr., Deborah B.
Bauser; "Li-censee's Answers to Intervenor Three Mile Island Alert's Second Request for Production of Documents to General Public Utilities (Training)"; " Licensee's Answers to Union of Concerned Scien-tists' First Set of Interrogatories to General Public Utilities (Training)"; and " Licensee's Second Set of Interrogatories to UCS (Training)" were served this 12th day of September, 1984, by hand delivery to the party identified with an asterisk and by deposit in the U.S. mail, first class, postage prepaid, to the other parties on the attached Service List.
i h u /5./ L ~
Deborah B.
Bauser
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION Before the Atomic Safety and Licensing Board In the Matter of
)
)
i METROPOLITAN EDISON COMPANY
)
Docket No. 50-289 SP
)
Restart (Three Mile Island Nuclear
)
Station, Unit No.,1)
)
Service List Administrative Judge Chairman, Atomic Safety &
1 Ivan W.
Smith Licensing Board Panel Chairman, Atomic Safety &
U.S. Nuclear Regulatory Licensing Board Commission U.S. Nuclear Regulatory Washington, D.C.
20555 Commission Washington, D.C.
20555 Chairman, Atomic Safety &
Licensing Appeal Board Panel Administrative Judge U.S. Nuclear Regulatory Sheldon J. Wolfe Commission Atomic Safety & Licensing Washington, D.C.
20555 Board U.S. Nuclear Regulatory Thomas Y. Au, Esq.
Commission Office of Chief Counsel Washington, D.C.
20555 Dept. of Environmental Resources 505 Executive House j
Administrative Judge P.O. Box 2357 Gustave A. Linenberger, Jr.
Harrisburg, PA 17120 Atomic Safety & Licensing l
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Board U.S. Nuclear Regulatory Washington, D.C.
20555 Jack Goldberg, Esq.
Office of Executive Legal Dtr.
U.S. Nuclear Regulatory Commission Washington, D.C.
20555 I
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Docketing & Service Section Ellyn R. Weiss, Esq.
Office of the Secretary William S. Jordan, III, Esq.
U.S. Nuclear Regulatory Harmon, Weiss & Jordan Commission 2001 S Street N.W., Suite 430 Washington, D.C.
20555 Washington, D.C.
20009 Mr. Norman Aamodt
- Lynne Bernabei, Esq.
R.
D.
5 Government Accountability Coatesville, PA 19320 Project 1555 Connecticut Avenue Joanne Doroshow, Esq.
Washington, D.C.
20009 The Christic Institute 1324 North Capitol Street Washington, D.C.
20002 Ms. Louise Bradford TMI ALERT Mr. Henry D. Hukill 1011 Green Street Vice President Harrisburg, PA 17102 GPU Nuclear Corporation P.O.
Box 480 Administrative Judge Middletown, PA 17057 Gary J. Edles, Chairman Atomic Safety & Licensing Michael F. McBride, Esq.
Appeal Board LeBoeuf, Lamb, Leiby & MacRae U.S. Nuclear Regulatory 1333 New Hampshire Avenue, N.W.
Commission Suite 1100 Washington, D.C.
20555 Washington, D.C.
20036 Administrative Judge Michael W. Maupin, Esq.
John H. Buck Hunton & Williams Atomic Safety & Licensing 707 East Main Street Appeal Board P.O. Box 1535 U.S. Nuclear Regulatory Richmond, VA 23212 Commission Washington, D.C.
20555 Administrative Judge Christine N.
Kohl Atomic Safety & Licensing Appeal Board U.S. Nuclear Regulatory Washington, D.C.
20555 l
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