ML20039E130
| ML20039E130 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 12/30/1981 |
| From: | Trowbridge G METROPOLITAN EDISON CO., SHAW, PITTMAN, POTTS & TROWBRIDGE |
| To: | Atomic Safety and Licensing Board Panel |
| References | |
| NUDOCS 8201060563 | |
| Download: ML20039E130 (3) | |
Text
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i DOCKETED UNITED STATES OF AMERICA U9mr NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD 3-Orf!CE OF SECRET...
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In'the Matter of
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METROPOLITAN EDISON COMPANY
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Docket No. 50-2
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(Restar O /g (Three Mile Island Nuclear
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Station, Unit No. 1)
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D, k kN kh LICENSEE'S REPLY TO UCS RESPONSE TO BOARD ORDSR' k5
[/I ON HPI QUESTIONS AND ANSWERS
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On December 24, 1981, UCS filed a response to the Board's Memorandum and Order dated December 16, 1981, approving Licensee's proposal dated December 16, 1981, relative to con-sideration of the High Pressure Injection (HPI) questions and answers on the TMI-l operator license examinations administered by the NRC last October.
The UCS response embodies three distinct requests:
1.
That the HPI answers and answer keys for the t.dC October examinations, and related emergency procedures, previously.distrib-uted by the Staff and Licensee, be admitted in evidence in connection with UCS Conten--
tion 10 and that the hearing record be re--
opened for this purpose.
2.
That copies of the " relevant question (s),
answers of all examinees, the NRC answer keys, and the relevant oral examinations administered in April 1981 be served on the Board and the parties" and that the record be reopened to receive these additional doc-uments.
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3.
That the versions of relevant Licensee emergency procedures (a) in effect at the time of the April examinations, (b) in effect at the time of the October examinations and (c) currently in effect, be provided and received in a reopened hearing.
Licensee addresses each of these requests sequentially.
October Examination Documents.
UCS relies on the HPI answers as the basis for its assertion that TMI-l operators "do not know under what conditions it is permissible to throttle or terminate HPI."
UCS offers no substantive analysis whatsoever of the answers on which it bases this assertion.
It ignores the fact that 31 out of 32 examinees correctly identified the basic criteria (50*F subcooling and/or LPI flow) for throttling HPI, neglects the fact that the emergency procedure in question is a follow-up written procedure which operators are expected to pull out and follow, and fails to consider the degree of memori-zation needed for such procedures.
Licensee discussed all of these factors in its December 24, 1981 response to the Board's December 18, 1981 Memorandum and Order.
UCS has simply not made the kind of substantive showing required under NRC practice for reopening the record of this proceeding.
Pacific Gas and Elec, tric Company (Diablo Canyon Nuclear Power Plants, Units 1 and 2),
ALAB-598, 11 NRC 876, 879-(1980).
April Examination Documents.
It is apparent from the UCS response that UCS already has copies of the April HPI answers
.4 and answer keys, and representatives of UCS so stated in the conference call with the Board and Special Master on December 14, 1981.
UCS offers no explanation for waiting until December 24, 1981, to assert that these documents should now be considered in a reopened hearing.
In any event UCS has failed to provide any description, much less analysis, of the answers to the HPI ques-tion on the April examinations and has thus failed to establish any basis for reopening the record.
Licensee has advised its counsel that those sections of emergency procedures previously distributed by Licensee's counsel which relate to throttling of HPI were in effect at the time of the April and October examinations and re-main currently in effect.
Since Licensee objects to reopening the record to include the April and October HPI questions and answers, its objection extends to reopening the record to receive additional Licensee emergency procedures.
Accordingly, Licensee objects to UCS' request to reopen the record for receipt of the HPI documents identified in UCS' December 24, 1981 response.
Respectfully submitted, s
SHAW, P TTMAN, POTTS &
ROWBRIDGE b/
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Trowbridge
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Dated: December 30, 1981
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