ML20096B788

First Request for Production of Documents.Related Correspondence

ML20096B788
Person / Time
Site:	Three Mile Island
Issue date:	08/28/1984
From:	Jordan W, Jordann W, Weiss E HARMON & WEISS, UNION OF CONCERNED SCIENTISTS
To:	METROPOLITAN EDISON CO.
Shared Package
ML20096B789	List: ML20096B788 ML20096B811
References
SP, NUDOCS 8409040354
Download: ML20096B788 (8)

Text

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August 28, 1984 e

UNITED STATES OF. AMERICA NUCLEAR REGULATORY COMMISSION n-,w: rn Before the Atomic' Safety and Licensii1EiBbErd

.In'the-Matter of )

> '34 ISO 30 R2:25 METROPOLITAN EDISON COMPANY )' Docket No. 50-289 SP

_. ) (Restart _- Management Phase)

(Three Mile Island Nuclear ) ,

Station, Unit No. 1) ) i

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UNION OF. CONCERNED SCIENTISTS FIRST REQUEST TO GENERAL PUBLIC UTILITIES FOR PRODUCTION OF DOCUMENTS TO: GENERAL PUBLIC UTILITIES NUCLEAR CORPORATION l

Pursuant to 10 C.F.R. 2.741, the Union of Concerned ~ i l

l Scientists hereby requests General Public Utilities Nuclear j

!- Corporation ("GPU") to produce and make available for inspection l l

and copying, each document in the possession or custody of GPU or subject to the control of GPU or its agents'and attorneys, as I

l- requested below.

DEFINITIONS (a) The Nuclear Regulatory Commission or "NRC" shall mean the Nuclear Regulatory Commission, its branches, departments,

,i sections, offices, subdivisions, its present and'former commissioners, administrators, management, employees, staff,

. agents, representatives, consultants, officials, inspectors, investigators, auditors and accountants, attorneys or their agents, attorneys or representatives.

' - 8409040354 840829

- PDR ADOCK 05000289 DS03

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(b). '" General Public Utilities" or "GPU" shall'mean General

-Public Utilit'ies, any of its subsidiaries, including but not

-limited to GPU Nuclear Corporation and. Metropolitan Edison Company, Land'its-subsidiaries'. branches, divisions, departments, sections, affiliates, offices, present and former officers, directors, management, board ' of directors,- employees, staf f, o f f ici als ,, - age n t s , . consultants, attorneys representatives and their attorneys, representatives and agents.

(c) " Document" shall mean every writing of every type or description,.and every other instrument or device by which, through which or on_which information has been recorded and/or

-preserved, including but not limited to memoranda, notes, 4

letters, drawings, files,-graphs, charts, photographs, slide presentaticas, handwritten notes, logs, ledgers, studies, data sheets,.uppointment calendars, telephone messages, meeting minute' , calculations, computations, financial statements, voice-recordings and other data compilations or every.other device or i

media on which or.through which information of any type is 4

transmitted, recorded or preserved.

(d). " Person" shall refer to any natural person, firm, partnership, joint' venture,. trust, corporation, holding company or other entity, natural or. legal,. domestic or foreign.

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7 ~(e) " Communication: shal1 mean discussion, conversation,'

letter, memorandum,_ telephone-call, message or direction,-whether

.writt'en or oral _ or whether; in person, by telephone of by mail.

- ( f )' - "Special: Report" shall mean the Special Report or.the l Reconstituted'OARP Review Committee, dated June 12, 1984.

INSTRUCTIONS FOR USE A. .You:must make available for inspection or copying all.

documents that are in your possession orlunder your' control, or~

in the possession or under the control of your officers, management,.-executives, _ employees, staff, directors,_ officials, attorneys, consultants, accountants, inspectors, investigators, or representatives,1or their agents, representatives or attorneys.

B. If GPU contends-that any document responsive to any request forfproduction listed below is_priv_ileged in whole or in

part, or otherwise objects to any part of any request, state the reason for each objection or grounds for' exclusion, and identify each person having knowledge of the factual basis, if any, on which the privilege or other ground is asserted.

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C. _If_any document responsive to any request for production is no longer in existence'. then answer the following questions:

'(1)_ Lidentify what information was maintained in that

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document;

-( 2 ) _ identify the type of document which contained such information;_

l (3) state the time period during which such document )

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.was maintained; (4) stateLthe circumstances under which such document ceased to exist;  ;

(5) state the date when such document ceased to exist;

_(6) identify all persons having knowledge of the circumstances under which such document ceased to exist; and (7) identify all persons who have knowledge or had knowledge of the document and the contents thereof.

This Request for Production is deemed to be continuing such-that GPU is requested'to supp'lement production with all' responsive documents which'come into its possession, custody or control subsequent to production of documents pursuant to intervenor's_ request.

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~ _ NOTE ON-NONDUPLICATION UCS has-attempted to avoid. duplication of document requests maderby other intervenors.. Should such-duplication occur despite

, four: efforts, you-.may identify the duplicative document-request

-an'dhthe documents thattyou have provided in response to another

-intervenor's document request that you believe'are responsive to

-UCS ' document request. Should UCS document request be broader t

thancthe other intervenor's, you must provide the additional

. documents as well as identifying those that you have alrea6y provided.

DOCUMENTS REQUESTED ,

1. A11' documents identified pursuant to Interrogatory Nos.-2(c)

(testimony), 2(e), 2(f), and'8(d) in UCS' First Set of Interrogatories to GPU.

2. All operator examinations given under t,he 0 RP program or otherwise given since March 28, 1979, for the purpose of '

evaluating candidates for Reactor C,;erator or Senior Reactor Operator or for the-purpose of evaluating candidates for requalification for those positions. For each such examination, provide the following:

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• s a.; The1 examination as given to the can'didates.

b .' The~ answer key.

-c. All graded answers to the~examinati'on.

- Id. . -All' documents-ased in the development of the examination.

e. .All documents 1 reflecting'an evaluation.or opinion as toit he-effectiveness of the examination for its

. intended-purpose,

f. All documents related to the results of the

' examination, including, but not limited to documents

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evaluating the performance of individual ~ candidates on orcin light of the examination, and documents comparing or considering the results of this examination in connection with the~results of one or more.other examinations. .

3. The current versions of the following operating or emergency procedures (and the. equivalent in ATOG procedures if GPU has

- adopted ATOG procedures in the particular case):

a. Emergency Procedures 1202 -Station Blackout 1202-4 Reactor Trip 1202-5 OTSG. Tube Leak / Rupture

'1202-6A Loss of Reactor Coolant Pressure within Capability of Makeup System (RC Pressure above ESAS setpoint) i j

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• t c1202-6B Loss of' Reactor Coolant / Reactor Coolant

- Pressure'~(Small Break LOCA)

Causing Automatic High Pressure Injection

'1202-6CL-Loss.of Reactor Coolant / Reactor Coolant' Pressure Causing Automatic High Pressure-Injection, Core Flood and Low Pressure Injection.

1202-26A Loss of Steam. Generator Feed to both OTSG's.

'1202-29 " Pressurizer System-Failure"

-1202-39' Inadequate Core Cooling

b. Operating Procedures

• 1102-11 Plant Cooldown 1102-16 RCS Natural Circulation Cooling 4' . - Al1~ lesson plans, teaching materials, and study materials used cince March 28, 1979, with respect to the following:

a.- The subjects covered by the procedures indentified in Document Request No. 3.

b ~.- Use of the Emergency Feed Water (EFW) System.

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The condensate and main feed water systems under.

eme rgency conditions.

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d. High pressure. injection.

e. . Low pressure invection.

-(No te : May T overlap _with request ~No. 17 in TMIA's Second Request for Production).

5. Documents Numbered,6,7,8,9, and 11 on Table A-Z of the Specia'l Report. (May overlap with Request No. 30 of-TMIA's Second Request for Production).

6. All Drafts and manuscripts of the Special Report.

7. The' Documents Referred to in the paragraphs number 1-4 on pages 20-21 of the'Special. Report. (May overlap with Request No.

3 in TMIA's Second Request for Production).

8. The'" Detailed Rating Sheet" discussed.at page 21 of the Special Report.

9. All documents establishing or referring to "the scenarios required by NRR ( the so-called '

Denton Requ_irements')," discussed at page 60 of the Special Report.

Respectfully submitted,

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Ellyn R. Weiss jsf'M .

William. . Jord II Harmon, Weiss, & Jordan 2001 S Street, N.W.

• Suite 430 Washington, D.C. 20009 Date: August-28, 1984 Counsel for Union of Concerned Scientists t

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