ML19211A087
| ML19211A087 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 11/16/1979 |
| From: | Chilk S NRC OFFICE OF THE SECRETARY (SECY) |
| To: | |
| Shared Package | |
| ML19211A080 | List: |
| References | |
| NUDOCS 7912170019 | |
| Download: ML19211A087 (18) | |
Text
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t UNITED STATES CF A" ERICA NUCLEAR REGULATCRY COMMISSION
@t, COMMISSIONERS:
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-p Jcseph M. Hendrie, Chaiman 2
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Victor Gilinsky Richard T. Kenned:-
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'1 epay Peter A. Bradfor-John F. Ahearne 4
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In the Matter of
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Mm0POLITAN EDISON CCMPANY Decket ?;o. 50-239 (Three Mile Island Nuclear Station,
)
Unit No.1)
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ORDER AND NOTICE OF HEARING I.
The Metropolitan Edison Company (the licensee) is holder of Facility Operating License No. OPR-50 which authorizes the operation of the nuclear power reactor kncwn as Three. Mile Island Nuclear Station Unit No.1 (the facility or TF.I-1), at steady state power levels not in excess of 2535 megawatts themal (rated power).
The facility is a Sabcock and Wilcox (B&'rl) designed presa'Jrized water reactor (PWR) located at the licensee's site ten miles southeast of Harrisburg, Pennsyl-vania.
II.
On July 2,1979, the Cemission ordered that the fadlity remain in a cold shutdown condition until further order cf the Ccemissicr. and stated t..at a hear'--
will be c nducted prior :c any restart of the facility.
On the basis of that hearing the Ccemissien will dete-:ine whether any further coeration will be per-
=i;;ed and, if se, under what c:nditions.
ne Cc=ission herein scecifies tne basis for its cencerns and the procedures to govern 'ur-her pecceedings in this matter.
For the reasons later set forth, :ne C =issicn has determined that em o
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satisfactory ccepletion of cartain short-tem actions and resolution of various concerns described herein are required to provide reasonable assurance that the s
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 promptly as practicable,
'and that reasonable progress on the completion of such actions prior to restart is required, in order to provide reasonable assurance that the W 'ility can be operated safely over the long tem.
This Order and notica of hearing further establishes procr.aures for a hearing.and decision on the particular issues
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identified in Section V of this Order.
The Commission has determined that hearing and decision with review thereof (as provided in Sectiorr.s 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 completed prior to any Corrission Order lifting the suspension of operation.
Accordingly, the Atomic Safety and Licensing Board designated to conduct this pro-ceeding should give priority to consideration of those issues which are related directly to suspension of operation. To the extent feasible, the Board should defer full review of the issues related to the longer-tem actions until after the rendering of a partial initial decision regarding the suspensien-related issues.
The Commission's July 2,1979 Order recited that 'the Cormission presently lacks the requisite reasonable assurance that the... Licensee's Three Mile Island Unit No.1 Facility... can be coerated without endangering the health and safe:.
of the public." The bases for that conclusion (which remains valid) are:
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n.
In the course of its evaluation to date of the accident et the Three Mile Island Unit No. 2 facility, which utilizes a B&W designed PWR, the Nuclear Regulatory Co= mission staff has ascertained that E&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 t: this sensitivity are:
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.(1) design $f the steam generators to coerate with relatively smaT1 liquid volume in the secondary side; (2) the lack of direct initiation crf reactor trip upon the occurrence of off-nomal conditions in the feedwater system; (3) reliance on an integrated control system (ICS) to automatically regulate feedwate:r flow;
- (4) accuation before reactor trip of a pilot-operated relief valve on the primary system pressurizer (which, if the valve sticks open, 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 feat:res, B&W designed reactors place mere relian:ce on the reliability and 'perfomance characteristics of the auxiliary feedwater system,' the
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integrated control system, and the emergency core cooline system ( ECCS) perfomance to recover from frecuent anticipated transients, such as less of effsite power and less of normal feedwater, than do other PWR designs. This, in turn, places a large burden on the plant operators in the event of off-nomal s;ystem behavior during suci anticipated transients.
As a result of a preliminary review of the Three P.ile Island Unit No. 2 acc[ dent chronology, the NRC staff initially identified several human errors that occurred during the accident and centributed significantly to its severity.
All holders cf
~ - - - operating licenses, exceo Petropclitan Edison, whose plar.ts were already shut-e subseoue.tiy instructec to take -
umber of icrediate actions to avoic 0
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4 repetition of errors, in accordance with bulletins issued by the Comission's Office of Inspection and Enforcement (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 improvements were necessary with respect to the2e reactors.
Tnis evaluation involved numerous meetings with S&W and certain of the affected licensees.
Tne evaluation identified design features as discussed above which indicated tha: B&W designed reactors are unusually sensitive to.certain off-nomal transient conditions originating in the secondary system.
As a result, an additional bulletin was issued by IE which instructed hoiciers 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 pressurizer pilot-operated relief valve setting.
Also, as a result of this
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evaluation, the NRC staff identified certain other safety concerr.s that warranted additional short-tem design and crocedural changes at operating facilities having E&W designed reactors.
Tnese were identified as items (a) through (e) on page 1-7 of the Office of Nuclear Reactor Regulation Status Report to the Commission of April 25,1979.
In addition to the items identified for the other S&W reactors, the unique circut-stances at 7.I recuire that additional safety concerns icentified by the NRC sta#'
be resolved prior to restart.
Tnese concerns result from (1) potential inter-acticn between Unit 1 and the damaged Unit 2, (2) cuestions about the manageren:
cacabilities and technical resour:es of Metropolitan Ediscn, including the im:ac: Of tne Unit 2 accident on these, (3) the potential effect of operations o
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O necessary to decontaminate the Unit 2 facility on Unit 1, and (4) recognized deficiencies in acergency plans and station operating precedures.
Based on the above, the Commission's Director of Nuclear Reactor Regulation (NPR) has recim-mended that the following a'ctions (the "short-tenn actions")'be required of the li'censee to resolve the concerns stated herein and pemit a finding of reasonable assurance that the facility can safely resume operation.
1.
Tne licensee shall take the following actions with res=ect to TMI-1:
(a)
Upgrade the timeliness and reliability of the Emerge =y Feedwater (EFW)
. system by perfoming the itens specified in Enclosure ~1 of the licensee's June 28,1979 letter.
Changes in design will be subadtted to the NRC staff for review.
(b)
Develop and imolement operating procedures for initiating and controlling ER: independent of Integrated Control System (ICS) centrol_
(c)
Install a hard-wired control grade reactor trip on less of main feedwater and/or on turbine trip.
(d)
Complete analyses for potential small breaks and deve' lop and implement operating instructions to define operator action.
(e)
Augment the retraining of all Reactor Operators and Senior Reactor Operators assigned to the control room including training -in the areas of natural circulation and small break loss of coclant accidents includ-ing revised procedures and tne TMI-2 accident.
All coerators will also receive training at the SW simulator on the TMI-2 accident and tne licensee will conduc a 100 percent reexanination of all operators in these areas.
NRC will acminister cocolete examinations to all licensed personnel in accedance with 10 CFR 55.20-23..
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The licensee shall provide for NRC review and approval of all applicable action:
specified in IE Sulletins 7g-05A,79-053, 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 parameters.
(b)
Establish an Emergency Operations Center for Federal, State and Local Officials and designate a location and an alternate location and pro-vide cc: munications to plant.
(c)
Upgrade offsite rnonitoring capability, including additional thermo-luminescent dosimeters or eauivalent.
(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.
4.
The licensee shall demonstrate that decontamination and/or restoration operations at TMI-2 will not affect safe operations at TMI-1.
The licensee shall provide separation and/or isolation of THI 1/2 radioactive liquid transfer lines, fuel handling areas, ventilation systems, and sampling lines.
Effluent monitoring instruments shall have the ca;; ability of discriminating between effluents resulting from Unit 1 or Unit 2 operations.
ine licensee shall demonstrate that tne waste management capability, including storap and processing, for solid, licuid, and gaseous wastes is adequate to 1594 132
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O assure safe operation of iMI-1, and that TMI-1 waste handling capability is not relied on by operations at TMI-2.
6.
The licensee shall demonstrate his manageria1' capability and resources to operate Unit 1 while maintaining Unit 2 in a safe configuration and carryi1g out planned decontamination and/or restoration activities.
Issues to be addressed include the adequacy of groups providing safety review and operational advice, the management and technical capability and training of operations staff, the aceouacy of the operational Quality Assurance pro; ram and the facility procedures, and the capability of important support organizations such as Health Physics and Plant Maintenance.
7.
Tne licensee shall demonstrate his financial cualifications to the extent relevant to his ability to operata TMI-l safely.
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8.
Tne licensee shall co ply with the Category A recommendations as specified in Table B-1 of NUREG-0578.
Tne Commission has additional concerns, which, th: ugh they need not be resolved prior to resumption of operation at Three Mile Island Unit 1, must be satisfac-torily addressed in a timely manner.
The Comission's Director of Nuclear Reactor Regulation (NRR) has recommended that the following actions ('he "leng-tem actions") be recuired of the licensee to resolve these concerns and pemit a finding of reasonable assurance cf the safety of long-tem cperation. These are:
1.
submit a failure mode and e#fects analysis c# :.*.e ICS tc the NRC s aff as soon as practicable; 1594 133 9
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give continued attention to transient analysis and procedures for management of small breaks by a formal program set up to assure timely action of these matters; 3,
ccr. ply with the Category B recommendations 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 appropriate 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 the Com-ission's rules and regulations in 10 CFR, it is hereby ordered that:
(1) the licensee shall maintain TMI-1 in a cold shutdown condition until further order of the Commission which will be issued following satis-factory completion of the required short-term actions and reasonable progress toward satisfactory completion of those required long-tenn actions referred to in section IV (such sh, ort-ter:t and lor.3-term actions to be considered " required" for purpcses of this clause which are cetermined by the Commission, after review of the Licensing Board's decision, to be necessary and sufficient to :rovide adequate c otection of the public health and safety); and 1594 134
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o (2) the licensee shall satisfactorily complete the long-tem actions listed in Table B-1 of NUREG-0578 on the schedule set out in such table and such other long-tem actions listed above as promptly as practicable.
IV.
The Ccemission has determined that, in light of the 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-tem actions referred to in such clause shall be those icng-term actions listed in section II as to which the Commission, prior to the date of this order,
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has issued immediately effective orders against other licensees.
If the Cor:aissier issues immediately effective orders against other licensees ic csing requirements with respect to other long-term actions, it will, to the extent appropriate in the
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circumstances, issue orders, effective imediately, to require that the licensee demonstrate reasonable progress toward completion of such other actions as a cendi-tion to restart.
If the Board detemines that operation can be resumed upon comple-tion of certain specific short-term actions by the licensee, it shall consider the extent to which the licensee has demonstrated reasonable progress toward completten of the long-tem actions described in this section.
If it finds that the licensee has demonstrated reasonable progress, it shall recommend resumption of operation upon completion of the short-tem actions.
If it cannet r.ake such a finding, it shall recommend that operation be resumec at a date that it believes appropriately reflects the importance of the action involved, the tice lost because such progres nac not been made on the prescribed schecule and tne overriding need to provide acecuate protection for the public health anc safecy.
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9 10 V.
An Atomic Safety and Licensing Board consisting of Ivan W. Smith, Esq., Chair-man, Dr. Walter H. Jordan, Member, and Dr. Linda W. Little, fiember, 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 CR 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 evening or on weekends to pemit the caxiet= possible 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.
Tne 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 this proceeding.
Tne Commissien's primary cox.itment is to a fair and thorough hearing and decision.
Given this overriding imperative, it is the Ccamission's expectation that the Board will conduct the proceeding 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 e.ttached for the Board's pcssib7e use, althouch the Board should not be constrained by it. Tre 5 card is instracted to ex: lore cocc-tunities to shorten the time limits provided in the Rules ;:ursuant
- 1C CFP 2.711. Tne Licensing Board is hereby instructed to consolidate participation of parties pursuant to 10 CFR 2.715a to the maximu-' axtent prac-ticable consu '
- with the provisions of that regulation.
In its review cf the Initial Decision, the Ccamission will invoke 10 CFR 2.711 to shorten time limits D " f" P'
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where feasible.
It is hereby directed, pursuant to 2.760(a), that, upon issuance of the initial decision (or partial initial decision) in this matter, the record be certified to the Commission itself for final decision.
Any party may take an appeal dire:tly with the Commission by filing exceptions to the initial decision (or partial initial decision) in accordance with the provisions of 10 CFR 2.752.
00c=ission review of the initial decision will be conducted in accordance with 10 CFF. 2.770.
Ir. the : cuc cf tnis proceeding the Licensing Board shculd exercise its authority
- seek t: er.sure that it receives all information necessary to a thorough investi-gation an: -esolution of the questions before it.
However, it should use its authority unter 10 CFR 2.757 to prevent any undue delay to the proceeding resulting
- rc any :r ss-examination not required for the full and true disclosure of the
- acts or #rc= other sources mentioned in that section.
The provisiens for pre-hearing discovery set forth in ~10 CFR 2.740-2.742 shall a: Ply t: -h's pro:eeding.
Furthemore, in several locations, including the Cor-
-issi:n's.3:.:b'.ic Document P.ocm and the TMI Local Cocument Room in Harrisburg, the
- =missier will maintain and continuously update a ecmoilation of all publicly available ir.f:rration on the Three Mile Island accident and related catters, and it will als: cemit infor al access to NRC staff considerations of the issues dnvolve: in this hearinc in the manner in wnich such access is permitted in sa:::r licensine oreceedings.
It shall be an adequate res;:ense to any dis-
- very -e: ss :: state that the infomation or document requested is available
'n the :ubli: ::::ilation and to crovide sufficient inforta-icn tc locate the
- u e.: :r ir.fer ation. Moreover, as provided by 10 CFF. 2.740(c) and 10 C R l
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12 2.740(d), the licensing board may and should, when not inconsisEent with fairness to all parties, limit the extent or control the sequence of discovery to prevent undue delay or imposition of an undue burden on an'y party.
The subjects to be considered at the hearing shall include:
(1)
Whether the "short term actions" recommended by the Director of Nuclear Reactor Regulation (set forth in Section II of this Order) are necessary and sufficient to provide reasonable as Jrance that the Three Mile Island Unit 1 facility can be operated without endangering the health and safety of the public, and should be required before resumption of operation should be peraitted.
(2)
Whether the "long-tem actions" recommended by the Director of Nuclear Reactor, Regulation (set ferth in Section II of this Order) are necessary and sufficient to provide reasonable assur'ance that the facility can be operated for the long ter i without endangerinc the health and safety of the oublic, and should be recuired of the licensee as soon as practicable.
As to the issue of financial qualifications mentioned above, a party wishing to raise this subject as a contention must clearly indicate why the licensee's financial condition might undermine tne licensee's ability to operate the plant safely.
Parties raising this issue should do so before the 5:ecial Prehearing Conference.
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9 13 7 nile real and substantial concern attaches to issues such as psychological distress and others arising from the continuing impact of aspects of the Three Mile Island accident unrelated directly to exposure to radiation on the cart of citizens living near the plant, the Commission has not detemined whether such issues can legally be relevant to this proceeding.
Any party wishing to raise such subjects as contentions, or as aspects of separate contentions, should brief the Atemic Energy Act and National Environmental Policy Act issues ne believes a: ore;riate to the Board as part of the contentfen acceptance process set out ir. the Comission's regulations.
The Soard should t'ren certify such issues to tne Comnission for final decision prior to the issuance of its pre-nearing c:nference order pursuant to 10 CFR 2.752(c), either with or without its
-ecemrendat'on on such issues, as it deems appropriate under the circumstances.
A :M tire the Ccemission reaches a decision on these issues, it will also con-sider whether it can and should grant financial assistance to parties seeking to
'-aise these issues in this case.
Iatisfacter;. cocpletion of the required actions will be determined by the Director of fiuclear Feactor Fegulation.
However, prior to issuine its decision the Board shall have authority to require staff to inform it of the detailed steps staff
- elieves necessary to implement actions the Board may recuire and to approve or cisas: rove cf the adecuacy of such measures. With respe:t to any uncompleted
'te. s :ne 5 card shall have authority similar to that provided in 10 CFR 50.57(b)
- :ske such acti:ns or :: in;ose such limi;ations or conditions as it believes e:essary :: Oro act the :ublic health and safety:
Provided, that, as provided 1594
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t 14 elsewhere in this order, restart shall not be permitted until satisfactory com-pletion of all uncompleted short-tem actions.
An'y affimative deter:nination by the Director will be based upon his finding that the actions specified by the Board, or by the Commission on review, have been taken, that the specified icplementing procedures employed are appropriate, that the licensee satisfies the financial qualification criteria imposed on an applicant for an operating license, and tnat there is reasonable assurance that the facility can safely resume opera-tion.
As no:ed above, the Atomic Safety and Licensing Board should accord pr-iority to the censideration of matters relating to the need for continued suspe:2sion of opera-ing authority. Within the limitatiens of 10 CFR 50.59 and 2.717(b) of the Cc=ission's regulations, the licensee may cormence modifications, such as those recomcended above by the Director of Nuclear Reactor Regulation, during the pendency of this pr'oceeding at its own risk.
VI.
If the. Licensing Board should issue a decision authorizing resumption of oceration upon completion of certain short-term actions by the licensee and a finding that in its judgment the licensee is making reasonable progress toward completien of the long-term actions specified in -his Order as to which the Com-
-issicn has issued immediately effective orcers a ains ctner licensees, and subse:uently if staff certifies that those shcrt em actions have been completed
- 't: sa-isfaction, the C:=ission will issue an :-dea within 35 days after suc cer-ification deciding whether tne provision c' nis orcer recuiring Nh D "2%
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35 the licensee to remain shut down shall remain immediately effective.
Any motions relhting to the lifting of immediate effectiveness, must be received by the Secretary of the Commission within 10 days of issuance of the certification, and an'y responses to such motions must be received by tne Secretary 7 days later.
The Co=ission shall issue an order lifting immediate effectiveness if it deter::ine:
that the public health, safety or interest no longer recuire 1cunediate effective-The Co:. mission's decision on that ouestion shall not affect its direct ness.
appella:e review of the merits of the Board's decision.
V:I.
'y Sectember 4,1979, the licensee may file a written answer to this Order and any person whose interest may be affected by this preceedirig may file a written petition to intervene.
Petitions for leave to intervene must be filed in ac:ordance with th,e Commission's " Rules of Practice for Domestic Licensing Proceedings" in 10 CFR Part 2.
If a petition for leave to intervene is filed by the above date, the Atomic Safety and Licensing Board established by this Order will rule on the petition and issue an appropriate further order.
An order wnolly denying a petition for leave to intervene shall be appealable by the petitioner tb the Commission itself within ten days after senice of the order.
An order gran'ing a petition 'for leave to intervene shall be appealable to the Co=ission itself by a party other than the petitioner on the cuestion of whether the petitf or. should have been wholly denied.
4 re:uired by 10 CFR 2.73, a petition for leave to inte vene shall set fortn with ;articularity the interest of the petitioner i.n the proceeding, and hcw 1594 1:41 w
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0 16 that interest may be affected by the results of the proceeding.
The petition should specifically explain the reasons why intervention should be pereitted with particuiar reference to the 'ollowing factors:
(1) the nature of the petitioner'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 etner intercst in the proceeding; and (3) the possit>1e effect of any order which may be entered in the proceeding on the pe:itioner's interest.
The petitier should identify the specific aspect (s) of the subject ma :ter of the croceedine as, to which petitioner wishes to intervene.
Not later than fifteen days prior to the first prehearing' conference scheduled in the proceeding, the petitioner shall file a supplement to the petitiert to inter-
. vene wnich cust include a list of contentions which are sought to be T itigated in the ratter, and the bases for each concern set forth with reasonable specificity.
A petitior.er who fails to file such a supplement which satisfies these recuire-eents with respect to at least one contention will not be permitted to participate as a : arty.
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17 An answer to this Order or petition for leave to intervene should be filed with the Secretary of the Cocmission, U.S. Nuclear Reguf atory Ccamission, Washington, D..C. 20555, Attention:
Docketing and Service Section, or may be delivered to the Ccamission's Public Document Room,1717 H Street, N.W., Washington, D.,C. by Septe.7.ber 4,1979.
A copy of the petition should be sent to the Executive Legal Director, U.S. Nuclear Regulatory Comrission, Washington, 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 licensee.
An'y questions or recuests for additional information regarding the content of this Notice should be addressed to the Chief Hearing Counsel, O'fice of the Executive Lecal Director, U.S. Nuclear Regulatsry Comission, Washington, 'D.C. 20555.
Nontimely filings of ' petitions for leave to intervene, arended petitions or supplemental 1:etitions will not be entertained absent a cetemination that the petitioner has made a substantial showing of good cause for the granting of a later petition.
Tnat detemination will be based on a balancing of the factors specified in,10 CFR 2.714(a)(f)-(v) and 2.714(d).
VIII.
Copies of the following documents are availaole for inspection at ne Ccmmission's Public Document Room at 1717 H Street, N.V., Washington, D.C.
and are being placed in the Ccmmission's local public document room at the State Library of Pennsylvania, Government Publications Secticn, Education Building, Ccmmonwealth anc Walnut Streets, iiarrisburg, Pennsylvania 17125.
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o 18 August 1 Commission Order April 16 Ltr. Herbein to Denton (prior notice will be given before restart)
June 28 Ltr. Herbein to Denten (modifications to be completed before TMI-1 restart)
June 28 fiRC Staff Meeting summary on T14I-1 restart NUREG-0578
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I&E Bulletins79-05A
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79-058 79-05C For t.ie Commis,sien i
f csk I O SAMUEL d. ! Ch.L:'
Secre ary of the Co.:nissicm i
Dated at Washington, D.C.
this 9th day of Aucust
, 1979.
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C O-Milestone 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 kaending Petitions 25 60 and for Negotiations re Contentions Time between filing Amended 15 75 Petitions and Contentions and Special Prehearing Conference Publication of Special Prehearing 5
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80 Conference Order (Discovery begins)
Discovery completed 60 140 During discovery period:
-Objections to Special Prehearing Conference Order.10 days
-Possible further refinement of contentions 140 Prehearing Conference Prehearing Conference Order 5
145 Filing of Testimony 20 165 (Assumes " objections to prehear-ing Conference Order filed simultaneously) 5egin Hearings 15 180
- mplete Hearings 50 240 Filing of Proposed Findings 40 280 crocosed Fincings 1C 290 Ee:1y :o
- e:isien by 5 card 45 335 1594 145
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