ML20150F982
| ML20150F982 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 04/01/1988 |
| From: | Baxter T GENERAL PUBLIC UTILITIES CORP., SHAW, PITTMAN, POTTS & TROWBRIDGE |
| To: | Atomic Safety and Licensing Board Panel |
| References | |
| CON-#288-6006 OLA, NUDOCS 8804060117 | |
| Download: ML20150F982 (5) | |
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000KETED U5HRC April 1, 1988 18 NH -4 P7 :36 UNITED STATES OF AMERICA
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NUCLEAR REGULATORY COMMISSION BRANCH BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of
)
)
GPU NUCLEAR CORPORATION
)
Docket No. 50-320-OLA
)
(Disposal of Accident-(Three Mile Island Nuclear
)
Generated Water)
Station, Unit 2)
)
LICENSEE'S ANSWER TO INTERVENORS' MOTION TO COMPEL DISCOVERY on March 29, 1988, Licensee received a copy of "SVA/TMIA's Motion to Compel GPU Nuclear to Present Documents for Discovery."
In the motion, Intervenors seek an order from the Atomic Safety and Licensing Board to compel Licensee to produce for inspection "all Technical Specifications."
Motion at 2.
Licensee opposes the motion because, as explained below, all of the technical specifications have already been produced.
In their first set of interrogatories, Intervenors asked Licensee to "(i]dentify all Technical Specifications relevant to the diaposal of the water."
In reply, Licensee stated that
"(t]he Technical Specifications will be produced for inspec-tion."1/
Subsequently, Licensee provided for Intervenors' 1/
Licensee's Answers to SVA/TMIA's Interrogatories to GPU Nuclear Corporation, Feb. 19, 1988, at 6 (Interrogatory G3).
8804060117 880401 PDR ADOCK 05000320 f Oh 0
I inspection the TMI-2 license and all accompanying technical spec-ifications.
Excerpts were copied at Intervenors' request.
Intervenors later appear to have formed the impression that there are technical specifications relevant to the disposal of accident-generated water other than the plant technical specifi-cations.2/.This is not the case, and there is no issue of "in-terpretation" of Intervenors' interrogatory.
The words "techni-cal specifications" are well understood NRC terminology.
They form a part of licenses issued by the NRC.
See 10 C.F.R. 5 50.36(b).
The only other technical specifications GPU Nuclear has at Three Mile Island are for Unit 1.
While some day there no 4
doubt will be changes to the TMI-2 technical specifications di-rectly addressing the approved method for disposal of the AGW, Licensee does not have them to produce at this time.
It is unfortunate that this unnecessary motion has been filed.
In an effort to avoid disputes over discovery and the accompanying schedule delays, Licensee has not objected to any discovery requests.
In our telephone conversation, the under-signed attempted to explain to Ms. Skolnick that Licensee has produced the only technical specifications which exist.
2/
In conversation, Intervenors have referred to one of the GPU Nuclear bid solicitation documents sent to potential disposal system vendors, apparently because its title includes, among others, the words "technical specifications for processed water disposal."
Intervenors seem to refuse to accept Licensee's ex-planation that this bid invitation document does not represent technical specifications.
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l The motion should be denied because Licensee responded fully to the discovery request.
Respectfully submitted, SHAW, PITTMAN, POTTS & TROWBRIDGE Thomas A.
- Baxter, P.C.
Maurice A.
Ross Counsel for Licensee 2300 N Street, N.W.
Washington, D.C.
20037 (202) 663-8000 Dated:
April 1, 1988 0
April 1, 1988 UNITED STATES OF AMERICA
. NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of
)
)
GPU NUCLEAR CORPORATION
)
Docket No. 50-320-OLA
)
(Disposal of Accident-(Three Mile Island Nuclear
)
Generated Water)
Station, Unit 2)
)
CERTIFICATE OF SERVICE I hereby certify that copies of the foregoing "Licensee's Answer to Intervenors' Motion to Compel Discovery" were served this 1st day of April, 1988, by U.S. mail, first class, postage prepaid, upon the parties identified on the attached Service List.
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Thomas A. Baxter, P.C.
4 00(MEiff U3NHC UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION 18 Am -4 P7 :36 0FHCE J 5Etitt l An f 00CKETiNG A SEindCL BEFORE THE ATOMIC SAFETY AND LICENSING BOARD BRANCH In the Matter of
)
)
GPU NUCLEAR CORPORATION
)
Docket No. 50-320-OLA
)
(Disposal of Accident-(Three Mile Island Nuclear
)
Generated Water)
Station, Unit 2)
)
SERVICE LIST Sheldon J. Wolfe, Esquire Richard P.
Mather, Esquire Atomic Safety and Licensing Department of Environmental Board Panel Resources U.S.
Nuclear Regulatory Commonwealth of Pennsylvania Commission 505 Executive House Washington, D.C.
20555 Harrisburg, Pennsylvania 17120 Mr. Glenn O.
Bright Ms. Frances Skolnick Atomic Safety and Licensing 2079 New Danville Pike Board Panel Lancaster, Pennsylvania 17603 U.S.
Nuclear Regulatory Commission Ms. Vera L.
Stuchinski Washington, D.C.
20555 315 Peffer Street Harrisburg, Pennsylvania 17102 Dr. Oscar H.
Paris Atomic Safety and Licensing Dr. William D. Travers Board Panel Director, Three Mile Island U.S. Nuclear Regulatory Cleanup Project Directorate Commission P.O.
Box 311 Washington, D.C.
20555 Middletown, Pennsylvania 17057 Stephen H.
Lewis, Esquire Colleen P. Woodhead, Esquire Office of the General Counsel U.S. Nuclear Regulatory Commission Washington, D.C.
20555 Docketing and Services Branch Secretary of the Commission U.S. Nuclear Regulatory Commission Wasnington, D.C.
20555
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