ML19209B132

Notice & Order That Facility Remain in Cold Shutdown Until short-term Actions Have Been Satisfactorily Completed & Reasonable Progress Has Been Made Toward Completing long-term Requirements.Aslb Will Conduct Hearing

ML19209B132
Person / Time
Site:	Crane
Issue date:	08/09/1979
From:	Chilk S NRC OFFICE OF THE SECRETARY (SECY)
To:
References
NUDOCS 7910090211
Download: ML19209B132 (19)

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NUCLEAR REGULATCRY CCPMISSION

@IA FUBLIC DOCUMENT ROOM CCfiMISSIONERS:

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Joseph M. Hendrie, Chair an C6$

F.3 Victor Gilinsky hh

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Ricnard T. Kennedy W

Peter A. Bradford e;.6. $

John F. Ahearne 4

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In the Matter of

)

)

METROPOLITAN EDISON COMPANY

)

Docket ?;o. 50-239

)

(Three Mile Island Nuclear Station,

)

Unit No. 1)

)

900RORGEL

)

ORDER AND NOTICE OF HEARING I.

The Fe ropcittan Edison Ccmpany (the licensee) is holder of Facility Operating License No. DFR-50 gnich authori:es the cceration of the nuclear power reactor known as Three Mile Island Nuclear Station, Unit No.1 (the facility or TMI-1), at steady state ;cwer levels not in excess of 2535 megawatts thermal (rated ;cwer).

The facility is a Sabccck and Wilecx (3&'r!) designed cressuri:ed water reacter (PWR) Iccated at' the licensee's site ten miles scutheas: cf Harrisburg, ?ennsyl-vania.

On July 2,1979, the Ccemission ordered that tne facility remain in a Ocid snu-dcwn conditien until further order cf :ne Ccmmissien and stated that a hearing will be conducted prior :: any restar: Of the facility.

Cn the basis cf tha-hearing :he Ccemissien will detemine wnether any further cceration will be cer-mitted and, if so, under wna: conditions.

The Ccemission herein sceci'ies tne basis fcr i s concerns and tre ;r:cedures c ;cvern fur-her :receedings in :nis atter.

cr the eascns later set for e Cp ssion has determinec :na:

7910090

P003 ORGINA 2

satisfactory completion of certain short-tem actions and resolution of various cencerns described herein are recuired to provide reasonable assurance that the facility can be operated without endangering the health and safety of the public.

The Commission has detemined that certain additional long-term actions are, for the reasons given below, required to be completed as prcmptly as practicable, and that reasonable progress on the completion of such actions prior to restart is recuired, in order to provide reasonable assurance that the facility can be operated safely over the long term.

Tnis Order and notice of hearing further establishes procedures for a hearing and decision on the particular issues identified in Section V of this Order.

Tne Commission has detemined that hearing and decision with review thereof (as provided in Sectiorrs V and VI below) on the issues specified in this order is required and that such hearing, decision and review on the issues relating to the actions required prior to restart of the facility must be comoleted prior to any Cormission Order lifting the suspensicn of operation.

tccordi1 gly, the Atomic Safety and Licensing Scart designated to conduct this pro-ceeding should give priority to c:nsiceration of those issues wnich are related directly to suspension of operation.

To the extent feasible, the Board should defer full review of the issues related to the longer-ter a actions until after the rendering of a partial initial decision regarding the sus ensien-related issues.

The Commissien's July 2,1979 Orcer recited that 'the Cecmission cresently lacks the requisite reasonable assurance that the... Licensee's Three Mile Island Uni t No. I racility... can be coerated witneut endangering the health and safety of the ::ublic." Tne bases for that conclusion (wnich remains valid) are:

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~

P00R ORG M

~

3 In the course of its evaluatien to date of the accident at the Three Mile Island Unit No. 2 facility, which utilizes a B&W designed pWR, the Nuclear Regulatory Cc= mission staff has ascertained that S&W designed reacters appear to be unusually sensitive to certain off-normal transient conditions originating in the secondary system.

The features of the B&W design that contribute to this sensitivity are:

(1) design of the steam generators to coerate with relatively smail liquid volume in the secondary side; (2) the lack of direct initiation of reactor trip upon the occurrence of off-non al conditions in the feedwater system; (3) reliance on an integrated control systen (IC5) to automatically regulate feedwate.r flow; (4) actuation before reactor trip of a pilot-operated relief valve: on the primary system pressuri:er (wnich, if the valve sticks cpen, can aggravate the event);

and (5) a low steam generator elevation (relative to the reactor viessel) which provides a smaller driving head for natural circulation.

Because of these features, B&W designed reactors place more relian;ce on the reliab111ty and performance characteristics of the auxiliary feedwater system, the integrated control system, and the emergency core cooling system ( ECCS) performance to recever free frecuent anticipated transients, such as loss of Offsite power and less of normal feedwater, than do other ?PR designs.

Thir., in turn, places a large burden on the plant operators in the event of off-normal s.ystem behavior during such anticipated transients.

As a result of a preliminary review cf the Three M.ile Island Unit No. 2 accident chronology, the NRC staff initially identified several human errors tnat occurred during the accident and c:ntriouted significantly to its severity.

Ali holders of operating licenses, excec: Ve:rooclitan Edison, wncse plants were already shut-dcwn, were subsecuently inscructec to take a numcer of im: ediace actions to avoid ii12

.750

J j-4 repetition of errors, in accordance with bulletins issued by the Commission's Office of Inspection and.Enforcemer.: (IE).

In addition, the NRC staff began an immediate reevaluation of the design features of B&W reactors to determine whether additional safety corrections or 1[nprovements were necessary with resper,t to these reactors.

This evaluation involved numerous meetings with S&W and certain of the affected licensees.

Tne evaluatio., identified design features as discussed a'ove which indicated c

that E&W designed reactors are unusually sensitive to certain off-normal transient conditions originating in the secondary system.

As a result, an additional bulletin was issued by IE which instructed homers of operating licenses for B&W designed reactors to take further actions, including immediate changes to decrease the reactor high pressure trip point and increase the pressuri:er pilot-operated relief valve setting.

Also, as a result of this evaluation, the NRC staff identified certain other safety concerr:s that warranted additional short-tem design and crocedural changes at operating facilities having B&W designed reactors.

These were identified as items (a) through (e) on page 1-7 of the Office of Nuclear Reacter Regulation Status Report to the Commission of April 25,1979.

In addition to the items identified for the other a&W reactors, the unique circum-stances at TMI require that additionti safety concerns icentified by the NRC staff be resolved prior to restart.

Tnese concerns result frca (1) potential inter-action between Unit 1 and the dacaged Unit 2, (2) cuestions about the management cacabilities and technical rescurces cf Metropolitan Ediscn, including the impcet of the Unit 2 accident on :nese, (3) the octentiai effect of operation.

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5 necessary to decontaminate the Unit 2 facility on Unit 1, and (4) recognized deficiencies in emergency plans and station coerating precedures.

Based en the above, the Commission's Director of Nuclear Reactor Regulation (NRR) has recom-mended that the folicwing actions (the "short-tenn actiord) be required of the licensee to resolve the concerns stated herein and pennit a finding of reasonable assurance that the facility can safely resume operation.

1.

The licensee shall take the following actions with respect to TMI-1:

(a)

Upgrade the timeliness and reliability of the Emergerry Feedwater (EFW) system by perfor-ing the ite.9s specified in Enclosure 1 of *be licensee's June 28,1979 letter.

Changes in design will be subsdtted to the NRC staff for review.

(b)

Develop and implement coerating procedures for initiating and controlling ER! independent cf Integrated Control System (ICS) ccritrol.

(c)

Install a hard-wired control grade reactor trip on loss of ma'in feedwater and/or on turbine trip.

(d)

Complete analyses #cr potential small breaks and develop and implement operating instructions to define operator action.

(e) Augment the retraining of all Reactor Operators

.nior Reactor Operators assigned to the control room including training in the areas of natural circulation and small break loss of coolant accidents includ-ing revised precedures and the FI-2 accident.

All cperators will also receive training at the En' simulator on the BI-2 accident and tne licensee will conduct a 100 percent reexamination of all operators in these areas.

NRC will administer comoiste examinations to all licensed personnel in accordance with 10 CFR 55.20-22..

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6 2.

The licensee shall provide for NRC review and a;: proval of all applicable actions s:ecified in IE Sulletins79-05A, 79-058, and 79-05C.

3.

The licensee shall improve his emergency preparedness in accordance with the following:

(a)

Upgrade emergency plans to satisfy Regulatory Guide 1.101 with special attention to action level criteria based on plant pa'ameters.

(b)

Establish an Emergency Operations C' enter for ~ederal, State and Local Officials and designate a location and an alternate location and pro-vide conmunications to plant.

(c)

Upgrade offsite monitoring capability, including additional thermo-luminescent dosimeters or equivalent.

(d)

Assess the relationship of State / Local plans to the licensee plans so as to assure the capability to take emergency actions.

(e)

Conduct a test exercise of its emergency plan.

a.

Tne licensee shall demonstra?

that decontamination and/or restoration c:erations at TMI-2 will not affect safe operations at TMI-1.

The licensee shall provide separation and/or isolation of TMI 1/2 radioactive liquid transfer lines, fuel handling areas, ventilation systems, and sampling lines.

Effluent monitoring instruments shall have the capability of discriminating between effluents resulting from Unit 1 or Unit 2 ocerations.

5.

Tne licensee shall demonstrate that the waste management capability, including storage and :rocessing, for solid, licuid, and gaseous wastes is adecuate to 1112 253

P00R BRMIL T

assure safe operation of TMI-1, and that TMI-l waste handling capability is not relied on by operations at D'I-2.

6.

The licensee shall demonstrata his managerial capability and resources to operate Unit I while maintaining Unit 2 in a safe configuration and carrying cut planned decontamination and/or restoration activities.

Issues to be addressed include the adecuacy of groups croviding safety review and operational advice, the management and technical capability and training of operations staff, the adecuacy of the operational Cuality Assurance pregram and the fracility precedures, and the capability of important support organi:ations such as Health Physics and Plant Maintenance.

7.

Tne licensee saall demonstrate his financial tualifications to the extent relevant to his ability to operate DiI-l safely.

S.

The licensee shall comply witn the Category A recccmendations as specified in Table E-1 of NUREG-0573.

The Cor :ission has additional con: erns, wnich, th: ugh they need not be re3cived Orior to resumption of coeration at Three Mile Island Unit 1, must be satisfac-torily addressed in a timely manner.

The Commission's Direct:r of Nuclear Reactor Regulation (NRR) has recommended that the following actions (the "long-tem actions") be required of the licensee to resolve these concerns and ;;ert'

=

finding of reasonable assurance of the safety of long-tem cperation.

Tnet are:

1.

submit a failure ecde and effects analysis of the ICS tc :ne NRC staff as soon as practicable; 1112 254

8 2.

give continued attention to transient analysis and procedures for management of small breaks by a femal program set up to assure timely action of these matters; 3.

cceply with the Category B reccamendations as specified in Table B-1 of NUREG-0578; and, 4

improve emergency preparedness in accordance with the following:

(a) modify emergency plans to address changing capabilities of plant instrumentation, (b) extend the capability to take acpropriate emergency actions for the population around the site to a dis-tance of ten miles.

III.

Accordingly, pursuant to the Atomic Energy Act of 1954, as amended,, and tne Cem.-issien's rules and regulations in 10 CFR, it is hereby ordered that:

(i) the licensee shall maintain DtI-1 f r. a cold shutdown condition until

'urther order of the Commission which will be issued folicwing satis-

1. actory completion of the required short-term actions and reasonable Oregress toward sitisfactory ccmpletien of those required 1cng-tenn actions referred to in section IV (such short-ter:1 and long-term actions to be considered "recuired" for purposes of tnis clause which are detemined by the Ccamission, after review of the Licensing Board's decision, to be necessary and sufficient to orovide adecuate

rotection of the public health and safety); and

<n r.)

9 (2) the licensee shall satisfactorily complete the long-term actions listed in Table B-1 of NUREG-0573 on the schedule set out in such table and such other long-tem actions listed above as promptly as practicable.

IV.

The Commission has deter.nined that, in light of tne concerns listed above, the public health, safety and interest require that the portion of the order referred to in clause (1) of Section III shall be immediately effective.

The long-term actions referred to in such clause shall be those Teng-tem actions listed in section II as to which the Comnission, prior to the date of this order, has issued immediately effective orders against other licensees.

If the Commission issues immediately effective orders against other licensees icposing requirements with respect to other long-tem actions, it will, to the extent appropriate in the circumstances, issue orders, effective immediately, to require that the licensee demonstrate reasonable progress toward concletion of such other actions as a condi-tion to restart.

If the Board determines that oceraticn can be resumed upon ccmple-tion of certain specific short-term actions by the licensee, it shall consider the extent to wnich the licensee has demonstrated reasonable progress toward completion of the long-tem actions described in this section.

If it finds that the licensee has demonstrated reasonable progress, it shall reccmmend resumption of operation upon completion of the short-tem actions.

If it cannot make such a finding, it shall reccmmend that operation be resumed at a date that it believes acprocriately reflects the importa.ve of the action involved, the tice lost because such progress had not been made on the prescribed schedule and t.ne overriding need :o ::revide acecuate protection for the public heale and safe y.

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10 V.

Ali Atocic Safety and Licensing Board consisting of Ivan W. Smith, Esq., Chair-can, Dr. Walter H. Jordan, Member, and Dr. Linda W. Little, Member, is hereby established to rule on petitions to intervene, to conduct the hearing ordered herein, and to render an initial decision in accordance with 10 CFR 2.760.

The Atomic Safety and Licensing Board will issue a further order specifying the date and place of the hearing and any prehearing conferences.

The Board should hold its sessions in the vicinity of the facility and it should attempt to schedule seme of its sessions in the vening or on weekends to permit the taximurn oossible public attendance.

The hearing will be conducted in accordance with the applicable provisions of subpart G of the Commission's Rules of Practice set forth in 10 CFR Part 2.

The provisions of 10 CFR 2.715a (consolidation of parties), 2.751a (special prehear-ing conference and order), 2.752 (prehearing conference and order) shall apply to tnis proceeding.

The Ccemission's primary coccitnent is to a fair and thorough hearing and decision.

Given this overriding imperative, it is the Comission's expectation that the Scard will conduct the proceedir) expeditiously.

The Board should as early as possible publish an appropriate schedule and attempt to meet it.

A tentative schedule composed by the Commission is attached for the Board's cessibTe use, although tne Board should not be constrained by it. The Board is instructed to explore cocortunities to shorten the ti":e limits provided in the Rules ::ursuant to 10 CFP 2.711.

The Licensing Board is hereby instructed to cons:lidate particioation of parties pursuant to 10 CFR 2.715a to the maximum extent :rac-ticable c:nsistent with the provisions of that regulation.

In its review of the Initial Decision, the Ccemission will invoke 10 CFR 2.711 to snorten time limits 1112 257

?0DR ORGINAL where feasible.

It is hereby directed, pursuant to 2.750(a), that, upon issuance of the initial decision (or partial initial decision) in this matter, the record se certified :o the Commission itself for final decision.

Any party may take an acpeal directly with the Commission by filing exceptions to the initial decision (or partial initial decision) in accordance with the previsions of 10 CFR 2.762.

Cermission review of the initial decision will be conducted in accordance with 10 CFR 2.770.

Ir the conduc cf this proceeding the Licensing Board should exercise its authority

seek t: ensure that it receives all information necessary to a thorough investi-gation an:

escV1on of the questions before it.

However, it should use its authority ur. der 10 CFR 2.757 to prevent any undue delay t) the proceeding resulting

'ro: any Orcss-examination not required for the full and true disclosure of the faces or #rce ocher sources centioned in that section.

Tr.e crovisiens for pre-hearing discovery set forth in 10 CFP. 2.740-2.742 shall a:::1y t; W s pro:eeding.

Furthe more, in several locations, including the Com-

-issi:n's ? b:ic Document Poem and One TMI Local Cccument Roce in Harrisburg, the

---issier wi'l maintain and continuously ucdate a cccoilation of all publicly available infcn ation on the Three Mile Island accident and related matters, and it will aisc cermit infor a1 access to MC staff considerations of the issues involvec in tnis hearing in the manner in wnich such access is pern:itted in eact:r licensing prcceedings.

shall be an adequate response to any dis-

very e:ues ce state tna: the information or cocument requested is available 3- :ne :::it: ccc:ilation and to cr vide sufficient information to locate the

cu: an :r irfer ation..voreover, as provided by 10 CFR 2.740(c) and 10 CFR 1 1 *I u) 7 t; '

sI a

12 2.740(d), the licensing board may and should, wilen not inconsistent with fairness to all parties, limit the extent or centrol the secuence of discovery to prevent undue delay or imposition of an undue burden on any party.

Tne subjects to be censidered at the hearing shall include:

(1) Whether the "short tenn actions" recommended by the Director of Nuclear Reactor Regulatton (set forth in Section II of this Order) are necessary and sufficient to provide reascnable assurance that the Three Mile Island Unit 1 facility can be opera *.ed without endangering the health and safety of the public, and should be required before resuription of operation should be permitted.

(2) Whether the "long-term actions" recorrended by the Director of Nuclear Reactor Fegulation (set forth in Section II of this Order) are necessary and sufficient to provide reasonable assurance that the facility can be operated for the long tem without endangerinc

ne health and safety of the :ublic, and should be recuired cf the licensee as soon as practicable.

As to the issue of financial qualifica* ions centioned above, a party wishing to raise this subject as a contention must clearly indicate why the licensee's financial condition might undennine tne licensee's ability to coerate the olant safely.

Parties raising this issue should do so before the Scecial Prehearing Conference.

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13 7 nile real and substantial cencern attaches to issues such as psychological distress and others arising from the continuing impact of aspects of the Three Mile :sland accident unrelated directly to exposure to radiation or the oar of citizens living near the plant, the Commission has not determined whether such issues can legally be relevant to this preceeding.

Any party wishing to

-aise such subjects as cententions, or as aspects of separate contentions, should brief the Atomic Energy Act and National Environmentai Policy Act issues 1e elieves a:prc:riate to the Board as part of the contention acceptance process set out in the Cc :nission's regulations.

The Board should then certify such issues to tre Comission for final decision prior to the issuance of its pre-nearing c:n'erence order :ursuant to 10 CFR 2.752(c), either with or without its e:ca endat'en en such issues, as it deems appropriate under the circumstances.

't tne tire the C:mmission reaches a decision en these issues, it will also con-sider whe:her it can and should grant financial assistance to parties seeking to

-aise these issues in this case.

Iat'sfacter;. corpletion of the required actions will be determined by the Director

f Wclear Feactor Fegulation.

However, prior to issuing its decision the Board shall have authority to require staff to inform it of the detailed steps staff celieyes necessary to imolement actions the Board may recuire and to approve or cisaoprove cf the adecuacy of such measures.

'dith respect to any uncompleted

' ers the 3 card snail have authority similar to that provided in 10 CFR 50.57(b) c: take su:h acticns or :: impose such limitations or cenditions as it believes s:essary :: Orctec: the :ublic heal:n and safe:y:

Prcvided, that, as provided t-l 100 1

14 elsewnere in this order, restart shall not be pemitted until satisfactory com-pletion of all uncompleted short-term actions.

Aay affirmative detennination by the Cirector will be based upon his finding that the actions specified by the Board, or by the Ccmmission on review, have been taken, that tne specified implementing procedures employed are appropriate, that the licensee satisfies the financial qualification criteria imposed on an a;olicant for an cperating license, and tnat there is reasonable assurance that the facility can safely resume opera-tion.

As noted above, the Atomic Safety and Licensing Scard should accord priority to the censideration of matters relating to the need for continued sus::ension of o;;erating authority. Within the limitations of 10 CFR 50.59 and 2.717(b) of the Cc=cission's regulations, the licensee may cc mence ecdifications, such as those recomrended above by the Director of Nuclear Reactor Regulation, during the cendency of this proceeding at its own risk.

V;.

If 11e Licensing Board should issue a decision authorizing resumption of oceraMan upon completion of certain short-tera actions by the licensee and a finding that in its judgment the licensee is making reasonable progress toward c:mpletion of tne long-tem actions specified in this order as to which the Ccm-missien has issued immediately effective orders against other licensees, and subsecuently if staff certifies that those shcrt term actions have been comcletec to its satisfaction, the Occmission will issue an order within 35 days after such certification deciding whether the provision of this order recuiring

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i a

the licensee to remain shut down shall remain immediately effetive.

Any motions relating to the lifting cf immediate effectiveness mus+.

esceived' by the Secretary of the Ccemission within 10 days of issuance of the certification, and any responses to such motions must be received by the Secretary 7 days later.

The Ccccission shall issue an order lifting immediate effectiveness if it determines that the public health, safety or interest no longer require immediate effective-ness.

The Commission's decision en that question shall not affect its direct appellate review of the merits of the Board's decisien.

VII.

By Sectember 4,1979, the licensee may file a written answer to this Order and any persen whose interest may be affected by this prcceeding may file a written cetition to intervene.

Petitions for leave to intervene must be filed in accordance witn th,e Commission's " Rules of ?ractice for Domestic Licensing 3roceedings" in 10 CFR Part 2.

If a petition for leave to intervene is fiTed by the acove date, the Atenic Safety and Licer. sing Board establi.hed by this Order will rule ca the ;etiticn and issue an aporocriate further order.

An erder shelly denyin; a petition for leave to intervene shall be appealable by tne

etitioner to the Commission itself within ten days after service of the order.

An crder granting a petition for leave to intervene shall be appealable to the Ccenissicn itself by a party other than the petitiener en the cuestion of whether the petition should have been wholly cenied.

As recuirec by 10 CFR 2.714, a petition for leave to intervene shall set forth witn ;articularity the interest of the petitioner in the ::roceeding, and how 1j9

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16 that interest cay be affected by the results of tne proceeding.

The petition should specifically explain the reasons why intervention should be pemitted with particular reference to the following factors:

(1) the nature of the petizioner's right under the Atomic Energy Act to be made a party to the proceeding; (2) the nature and extent of the petitioner's procerty, financial, or other interest in the proceeding; and (2) the possible effect of any order which may be entered in the proceeding on the petitioner's interest.

The petit:or should identify the specific aspect (s) of the subject matter of the croceeding as to which petitioner wishes to intervene.

Not later trar fifteen days prior to the first prehearing conference scheduled in the p*0ceeding, the petitioner snall file a supplement to the petition to inter-vene wnich cust include a list of contentions which are scught to be T itigated in the natter, and the bases for each concern set forth with reasonable spe:ificity.

A petitioner who fails to file sucn a supplement wnich satisfies these recuire-ments with respect to at least one contention will not be perritted to participate as a party.

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17 An answer to this Order or petition for leave to intervene shouid be filed with the Secretary of the Ccemission, U.S. Nuclear Regulatory Commission, Washington, D.C. 20555, Atcention:

Cocketing and Service Section, or ::ay be delivered to the Commission's Public Cocument Room,1717 H Street, N.W., Washington, D.C. by September 4,1979.

A copy of the petition shculd be sent to the Executive Legal Director, U.S. Nuclear Regulatory Ccemission, 'Jashington, D.C. 20555 and to Mr.

George F. Trowbridge, Shaw, Pittman, Potts and Trowbridge,1800 M Street, N.W.,

Washington, D.C. 20036, attorney for the liconsee.

Any questions or rectests for additional infernatio.' regarding the content of this Notice should be addressed to the Chief Hearing Cou. ' 21, Office of the Executive Legal Director, U.S. Nuclear Regulatory Ccemission, Washington, D.C. 20555.

Nontimely filings of ' petitions for leave to intervene, amended petitions or supplemental petitions will not be entertained absent a determinaticn that the cetitioner has made a substantial showing of good cause fe:r the granting of a later cetition.

That deter-inaticn will be based on a balancing of the facters specifi'd in 10 CFR 2.714'a)(1)-(v) and 2.711(d).

VIII.

Copies of tne following documents are available for inspecticn at the Ccemission's Public Cocument Rocm at 1717 H Street, N.W., Wasoingten, D.C.

and are being placed in the Ccemission's local public doct: ment rocm at the State Library of Pennsylvania, Covernment Publications Section, Education Building, Ccmmonwealth and 'dainut Streets, riarrisburg, Pennsylvania 17125.

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18 August 1 Ccemission Order April 16 Ltr. Herbein to Denton (prior notice will be given before restart)

June 28 Ltr. Herbein to Centon (modifications to be completed before DiI-l restart)

June 28 NRC Staff Meeting summary on T74I-1 restart HUR2G-0578 I&E Bulletins.79-05A 79-058 79-05C For tne Comission S/#UEL J..Ch:L:s Secre ary of the Commissicm Cated at Washington, D.C.

i this 3 cay 'f aucust

, 1979.

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Mile. stone Time Consumed Total Days Into (Days)

Proceeding Publication of Notice 0

0 (Detailed Order)

Filing of Intervention 20 20 Petitions Answers to Petitions 15 35 Time for Amending Petitions 25 60 and for Negotiations re Contentions Time between filing Acended 15 75 Petitions and Contentions and Special Prehearing Conference Publication of Special 0 rehearing 5

80 Conference Order (Discovery begins)

Discovery completed 60 140 During discovery period:

-Objections to Scecial Prehearing Conference Order.10 days

-Possible further refinement of contentions Prehearing Conference 140 Prehearing Conference Order 5

145 Filing of Testimony 20 165 (Assumes objections to prehear-ing Conference Order filed simultaneously) 5egin Hearings 15 180 Complete Hearings 50 240 Filing of Procosed.:incings 40 280 Recly to ?rocosed Findings 10 290 Decision by 5 card 45 335 1ii2 266