ML20098F039

Answer to Ucs First Request for Production of Documents. Related Correspondence

ML20098F039
Person / Time
Site:	Three Mile Island
Issue date:	09/28/1984
From:	Bauser D GENERAL PUBLIC UTILITIES CORP., SHAW, PITTMAN, POTTS & TROWBRIDGE
To:	UNION OF CONCERNED SCIENTISTS
Shared Package
ML20098F040	List: ML20098F039 ML20098F051 ML20098F056
References
CON-#484-148 SP, NUDOCS 8410020252
Download: ML20098F039 (5)

Text

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i lWG tJS.W2 n du gg 4- September 28, 1984?

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'* l ' l F??:p; UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION M

$ b-I BEFORE THE ATOMIC SAFETY AND LICENSING BOARD i

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 ANSWERS TO INTERVENOR UNION OF CONCERNED SCIENTISTS' FIRST REQUEST FOR PRODUCTION OF DOCUMENTS TO GENERAL PUBLIC UTILITIES Licensee General Public' Utilities Nuclear Corporation (GPU Nuclear), pursuant to 10 C.F.R. 5 2.741(d), hereby submits the

following responses to " Union of Concerned Scientists First Re-quest to General Public Utilities for Production of Documents."

Documents will be made available in the discovery reading room located at the offices of Shaw, Pittman, Potts & Trowbridge,

-1800 M Street, N.W., Washington, D.C. 20036.

DOCUMENTS REQUESTED f 1. All documents identified pursuant to Interrogatory L Nos. 2(c) (testimony), 2(e), 2(f), and 9(d) in UCS' First Set I of Interrogatories to GPU.

RESPONSE AND OBJECTION. Licensee will respond to the UCS Interrogatory 2(c) as specified in its agreement with UCS, me-l morialized by letter dated September 26, 1984, which contem-l l plated that UCS would be given information available to Licens-L l ee's witnesses about their previous testimony so that UCS could t- f 841002O252 840928 ,

PDR ADOCK 05000289

g. PDR ~

retrieve the information. Insofar as UCS would require Licens-ee to go through this effort for UCS, Licensee objects to UCS discovery request 1. Licensee will provide in the discovery reading room a copy of documents referred to in its future sup-plemental response to UCS Interrogatory 2(f). Documents listed in response to UCS Interrogatory 8(d) are available in the dis-covery reading room in response to UCS (first set)

Interrogatory 3.

2. All operator examinations given under the OAR! pro-gram or otherwise given since March 28, 1979, for the purpose of evaluating candidates for Reactor Operator or Senior Reactor Operator or for the purpose of evaluating candidates for requalification for those positions. For each such examina-tion, provide the following:

a. The examination as given to the candidates.

b. The answer key.

c. All graded answers to the examination.

d. All documents used in the development of the examina-tion.

e. All documents reflecting an evaluation or opinion as to the effectiveness of the examination for its in-tended purpose.

f. All documents related to the results of the examina-tion, including, but not limited to documents evaluating the performance of individual candidates on or in light of the examination, and documents comparing or considering the results of this examina-tion in connection with the results of one or more other examinations.

R3SPONSE. Those documents included in the agreement be-tween the parties, set forth in the September 11, 1984 letter from coonsel for UCS to counsel for Licensee, will be provided in the discovery reading room.

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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 1202-2 Station Blackout 1202-4 Reactor Trip 1202-5 OTSG Tube Leak / Rupture 1202-6A Loss of Reactor Coolant Pressure within Ca-pability of Makeup System (RC Pressure above ESAS setpoint) 1202-6B Loss of Reactor Coolant / Reactor Coolant Pressure (Small Break LOCA) 1202-6C Loss of Reactor Coolant / Reactor Coolant Pressure Causing Automatic High Pressure Injection, Core Flood and Low Pressure In-jection.

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 i

RESPONSE. Documents will be provided in the discovery reading room.

l 4. All lesson plans, teaching materials, and study mate-rials used since March 28, 1979, with respect to the following:

I a. The subjects covered by the procedures identified in Document Request No. 3.

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

c. The condensate and main feed water systems under l

emergency conditions.

d. High pressure injection.

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e. Low pressure invection.

RESPONSE. Those documents included in the agreement be-tween the parties, set forth in the September 11, 1984 letter from counsel for UCS to counsel for Licensee, will be provided in the discovery reading room.

5. Documents Numbered 6,7,8,9, and 11 on Table A-2 of

-the Special Report.

RESPONSE. These documents are available in the discovery reading room in response to TMIA (first set) document produc-tion request 2.

6. All drafts and manuscripts of the Special Report.

RESPONSE. These documents are available in the discovery reading room in response to TMIA (first set) document produc-tion request 1.

7. The Documents referred to in the paragraphs number 1-4 on pages 20-21 of the Special Report.

RESPONSE. The document, Operator Training Instructor Indoctrination / Qualification, is document #.4 provided in re-sponse to TMIA (first set) document production request 2. The document, GPUN Instructor Development Program, is document #30 provided in response to TMIA (first set) document production request 2. The document, Training Systems Development, is document #21 provided in response to TMIA (first set) document production request 2. The document, TMI Training Department Instructor Evaluation Procedure, is document #31 provided in response to TMIA (first set) document production request 2.

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

RESPONSE. Document will be provided in the discovery reading room.

9. All documents establishing or referring to "the sce-narios required by NRR (the so-called 'Denton Requirements'),"

discussed at page 60 of the Special Report.

RESPONSE. Documents will be provided in the discovery reading room.

4 Respectfully submitted, kM d .bMt!V Ernest L. Blake, Jr., P.C.

Deborah B. Bauser SHAW, PITTMAN, POTTS & TROWBRIDGE 1800 M Street, N.W.

Washington, D.C. 20036 (202) 822-1215 Counsel for Licensee Dated: September 28, 1984 l

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