ML19338C344

Licensee Responses to TMI Alert Followup Interrogatories 1,3 & 4 (Second Set).Certificate of Svc Encl

ML19338C344
Person / Time
Site:	Three Mile Island
Issue date:	08/08/1980
From:	Bernstein D, Blake E METROPOLITAN EDISON CO., SHAW, PITTMAN, POTTS & TROWBRIDGE
To:	THREE MILE ISLAND ALERT
Shared Package
ML19338C343	List: ML19338C342 ML19338C344
References
NUDOCS 8008150182
Download: ML19338C344 (7)

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• Lic 8/11/80 l

UNITED STATES OF AMERICA '

NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of )

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METROPOLITAN EDISON COMPANY ) Docket No. 50-289

) (Restart)

(Three Mile' Island Nuclear )

Station, Unit No. 1) )

LICENSEE'S RESPONSES TO TMIA'S FOLLOW-UP INTERROGATORIES (Second Set)

In accordance with the Board's Memorandum and Order on TMIA's Motion to Compel Discovery of Licensee, dated July 22, 1980, Licensee proffers the following responses to Interroga-tories 1, 3 and 4 contained in TMIA's second set of follow-up interrogatories:

INTERROGATORY NO. 1 Based on the evaluation of Work Requests 25166, 24159, 24218, 21857 and 25110 (included in Licensee's Response to TMIA's Inter-rogatory 5-6) on June 11 and 12, 1980, please define the word

" purged" as used on the above work requests.

A. Who " purged" the above work requests?

B. Who has the authority to " purge" a work request?

C. What criteria are used in " purging" a work request?

D. What is the status of a work request after " purging"?

E. Are there ether definitions for the word " purged" with respect to work requests?

1. If so:

(a) Set forth each definition; (b) Identify how the correct meaning can be discerned from a visual inspection of the work request.

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RESPONSE

The word " purged," as used on the specified work requests, was a term coined by the Supervisor of Maintenance to indicate maintenance work that had either been completed, or was no longer necessary.

A. The work requests in question were purged by a mechanical foreman, under the supervision of the Lead Mechanical Foreman.

B. These specific work requests were purged under.

the direction of.the Supervisor of Maintenance. The present Maintenance Procedure 1407-1, 55.2.29, Rev. 6, provides that the Supervisor of Maintenance or his designee is authorized to fill in the " Sign Off Reasons Code" (which may include " purging"). See Answer to "E" below.

C. A work request is " purged" under any of the following circumstances:

1. Work completed while accomplishing a different task on the component.

2. Work completed und a duplicate work request for the same task.

3. The Lead Foreman, Supervisor of Main-I tenance or Supervisor of Operations determines that the job is not necessary.

4. The associated change modification re-quest, necessary to conduct the proposed mainten-ance work, is cancelled.

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D. A work request that is purged is cancelled, and is therefore no longer outstanding.

E. Yes. Under the current Maintenance Procedure 1407-1, Rev. 6, the term " purged" is defined as " low

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priority." The applicability of this definition can be discerned by examining the date that the work request was generated. If it was generated after January 1, 1980, the procedures contained in 1407-1 would apply.

INTERROGATORY NO. 3 Based on the evaluation of Work Request 24511 made on June 16, 1980, please explain what "M. Ross's leak list" is.

A. Provide a copy of "M. Ross's leak list".

RESPONSE

"M. Ross's leak list" was a temporary, informal list of leak-ing valves and components generated by the Supervisor of Operations, Mr. Ross, to assist Maintenance in generating job tickets for work that could be accomplished during a refueling outage when those systems a e available for work. Licensee has been unable to locate the "M. Ross's leak list."

INTERROGATORY NO. 4 TMIA based this interrogatory on an evaluation of the Mainten-ance Log (Volume 4 and 5 given in response to TMIA Interrogatory 7-10) on June 14, 1980. TMIA has identified a significant number of very recently completed work requests, including 16968, 19507, 19976, 21136, 21894, 22589, 22977 and 26000.

Therefore, TMIA requests that Licensee update its response to TMIA's Interrogatory 5-6 by supplying a cenputer summary of all work requests completed from January 1, 1980 to date.

RESPONSE

An update of the computer summary of work requests will be

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placed in Licen ' c's Discovery Reading Room.

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Respectfully submitted,

! SHAW, PITTMAN, POTTS & TROWBRIDGE t

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• By: h M [.

Ernest L. Blake, Jr.

h-Deborah L. Bernstein Dated: August 8, 1930

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. Lic 8/11/80 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of )

)

METROPOLITAN EDISON COMPANY ) Docket No. 50-289

) (Restart)

(Three Mile Island Nuclear )

Station, Unit No. 1) )

CERTIFICATE OF SERVICE I hereby certify that copies of " Licensee's Responses to TMIA's Follow-up Interrogatories (Second Set) " were served upon those persons on the attached Service List by deposit in the United States mail, postage prepaid, this lith day of August, 1980.

Mt.Wu Deborah L. Bernstein Dated: August 11, 1980

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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION

• BEFORE-THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of )

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METROPOLITAN EDISON COMPANY ) Docket No. 50-289

) (Restart)

(Three Mile Island Nuclear )

Station, Unit No. 1) )

SERVICE LIST Ivan W. Smith, Esqaire John A. Ievin, Esqture CMimn Assistant Counsel Atcznic Safety and Licensing Pennsylvania Public Utility Ccmn'n Board Panel Post Office Box 3265 U.S. Nuclear Regulatory Chmtission Harrisburg, Pennsylvania 17120 Washington, D.C. 20555 Karin W. Carter, Esquire Dr. Walter H. Jordan Assistant Attorney General Atcmic Safety and Licensing 505 Executive House Board Panel Post Office Box 2357 881 West Outer Drive HarrisbtLg , Pennsylvania 17120 Oak Ridge, Tennessee 37830 John E. Minnich Dr. Linda W. Little Chairman, Dauphin County Boa M

! Atcmic Safety and Licensing of Camissioners l

Board Panel Dauphin County Courthcuse .

l 5000 Hermitage Drive Front and Market Streets

( Paleigh, No.-th Carolina 27612 HarrisbtLg, Pennsylvania 17101 l

l Jarres R. 'Iburtellotte, Esquire Ualter W. Cohen, Esquire -

Office of the Executive Iegal Director consumer Mvocate l U. S. Nuclear Regulatory Ccmnission Office of Cbnsumer tW ocate Washington, D.C. 20555 14th Floor, Strawterry Square Harrisuurg, Pennsylvania 17127 Ibcketing and Service Section Office of the Secretary U. S. Nuclear Pegulatory Ctzmtission Washirgton, D.C. 20555 i

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Jordan D. Cunningham, Esquire William S. Jordan, III, Esquire Attorney for Neatxtrry Township Attorney for People Against Nuclear T.M.I. Steering Chmiittee Energy .

2320 North Second Street Har: Ton & Weiss Harrisburg, Pennsylvania 17110 1725 Eye Street, N.W., Suite 506 Washington, D.C. 20006 Theodore A. Adler, Esquire Widoff Peager Selkowit:: & Idler Robert Q. Pollard Post Office Box 1547 609 bbntpelier Street ',-

Harrisburg, Pennsylvania 17105 Baltirrore, Paryland 21218 ~

Ellyn R. Weiss, Esquire Chauncey Kepford Attorney for the thion of Conce.rned Judith H. Johnsrud Scientists Environmental cm1ition on hwlea-Har: ton & Weiss Power 1725 Eye Street, N.W., Suite 50f 433 Orlando Avenue Washington, D.C. 20006 State College, Pennsylvania 16801 Steven C. Sholly Marvin I. Luis 304 South Market Street 6504 Bradford Terrace 7

Mechanicsburg, Pennsylvania 17055 Philadelphia, Pe" W lvania 19149

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Cail Bradford Marjorie M. Aa::odt Holly S. Keck E. D. 5 Iagislation Chaimrt coatesville, Pennsylvania 19320 Anti-Nuclear Group Representing York 245 West PhilaM1phia Street York, Pennsylvania 17404

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