ML19323G652
| ML19323G652 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 05/19/1980 |
| From: | Sholly S AFFILIATION NOT ASSIGNED |
| To: | Atomic Safety and Licensing Board Panel |
| References | |
| NUDOCS 8006060420 | |
| Download: ML19323G652 (7) | |
Text
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SHOLLY, 5/19/80 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD
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METROPOLITAN EDISON COMPANY t,{ l g j
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INTERVENOR STEVEN C. SHOLLY
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g RECOMMENDATIONS ON CONTENTION GROUPING f:
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Pursuant to discussion at the Prehearing Conference on 13 May 1980, Intervenor Steven C. Sholly offers the following suggestions for grouping of contentions in the TMI-1 Restart proceedings. Due to time constraints, it has not been possible to analyze the contentions for the purpose of comparison with Staff recommendations. What is offered herein is a possible grouping of contentions around certain issues which are shared in common.
It should be made clear that this grouping is not meant to represent the views of any other party to this proceeding. The grouping presented herein simply represents the manner in which the contentions in this proceeding seem to me to be related for the purposes of functional grouping.
PSYCHOLOGICAL DISTRESS PANE,#1 and #2)
NEWBERRY TSC (#1 and #2)
AAMODT (#9)
TMIA (#3)
ECNP (#6)
CEA (#4)
SHOLLY (#12)
Notes:
Sholly contenrion involves the issue only as it relates l
to the NEPA issues.
CEA involves the issue only with regard to public trust in radiation monitoring procedures and results. Newberry's contentions also invoke NEPA.
LO+
CLASS 9 ACCIDENTS 79o SHOLLY (#17)
UCS (#13)
ANGRY (#6)
ECNP (#4B and #4C)
Notes: Sholly and ECNP contentions specify sequences. ANGRY specifies consideration of multiple failures in accident analyses. UCS contention was accepted for discovery pending specification.
8006060@D 4
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SHOLLY, 5/19/80 CONTENTION GROUPINGS 1
HUMAN FACTORS QUESTIONS
... _:. _. m..u ECNP,(#1I)
SHOLLY (#15)
ANGRY (#5C)
Notes: ECNP contention was admitted for specification. ANGRY contention requires' completion of modifications suggested in NUREG-0560.
Sholly contention calls for general human factors engineering review of TMI-1 control room as it relates to man / machine interface.
MANAGEMENT ISSUES ECNP (#3)
TMIA (#5)
SHOLLY (#14)
CEA (#8)
ANGRY (#4)
AAMODT (#2)
Notes: Aamodt contention also deals with operator training.
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RADIATION MONITORING AAMODT (#3 and #6)
CEA (#3 and #7)
SHOLLY (#4, #5, and #9)
' ANGRY (#2F)
Notes: The status of these' contentions is unclear. To my knowledge, Licensee.has not modified its radiation monitoring programs since dhe contentions were submitted, yet the Board deferred rulings on at least "
some of these contentions pending analysis of future Licensee submittals for redrafting the contentions.
Entire issue is clouded as a result.
QUALIFICATION OF COMPONENTS AND CONTROLS UCS (#3-6, and #12)
SHOLLY (#2)
Notes: Sholly contention limited to PORV and safety valves.
FINANCIAL ISSUES
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TMIA (#6)
CEA (#9)
NEPA QUESTIONS AAMODT (#11-1)
SHOLLY (#12)
CEA (#1)
TMIA (#8)
NEWBERRY (#1 and #2)
Notes: Several contentions also related to psychological distress.
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SHOLLY, 5/19/80 CONTENTION GROUPING
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LOCA ANALYSIS 5
SHOLLY (#7)
UCS (#8)
ECN? (#1E)
HYDROCEN CAS CONTENTIONS SHOLLY (#11)
UCS (#11)
ANGRY (#5A I
Notes: Awaiting decision from Commission on certification.
4 OPERATOR TRAINING AAMODT (#2)
CEA (#13)
TMIA (#5)
Notes: TMIA contention fits in here insofar as it addresses maintenance practices.
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SEPARATION ISSUES i
SHOLLY (#10 and #16)
AAMODT (#8)
TMIA (#7)
Notes: CEA #7 relater, to ability to discriminate between TMI-1 l
and TMI-2 effluents (radioactive)--it may also be placed
'3 under Radiation Monitoring issues. Sholly #16 relates to
,5 security.
CONTAINMENT ISOLATION
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ECNP (#1H)
SHOLLY (#1) i PLANT COMPUTER SYSTEM SHOLLY (#13)
ECNP (#1A)
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SAFETY SYSTEM BY-PASS i
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l UCS (#10)
SiOLLY (#3)
INSTRUMENTATION ISSUES ANGRT (#5B)
ECNP (#1C and #1D) i UCS (#7)
Notes: This category is not well-defined. Indeed, some contentions may be more easily grouped under human factors and Class 9 considerations.
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,e SHOLLY, 5/19/80 CONTENTION GROUPINGS MISCELLANEOUS CONTENTIONS ECNP (#1B)-unsure whether this contention would require design modifications to eliminate low water volume problem or require additional operator. training /better instrumentation to prevent problems related to the low water volume.
In any event, the contention does not fit well into any of the categories which I have established.
ECNP (#1G)-this may be fit in with the hydrogen gas contentions.
ANGRY (#5D)-the rapid filtration question may be best fit in under Class 9 consideration since this is the sort of accident
' "under which such a system would most likely be used.
UCS (#1 and #2)--both deal with heat removal systems and do not fit in with the categories as established.
UCS (#9)--deals with~ inoperable safety systems. Does not fit in established categories.
UCS (#14)-safety VS non-safety-grade. Does not fit categories.
LEWIS CONTENTION-does not fit categories.
SHOLLY (#6)-dealing with need to complete "long-range" items in the "short' term" time period (i.e., before restart). Does not fit categories.
It is hoped that this aides the Board in sorting out the best possible contention grouping. I regret any errors regarding contentions which may have been dropped, modified by the Board, or modified by the parties. Time considerations did not permit an exhaustive recanting of all the orders regarding contentions in order to make such a grouping of contentions.
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Steven C. Sholly DATED
- 19 Ma7 1980 Mechanicsburg, PA 17055 H--717-766-1857 W--717-233-6855 233-4241
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4 DocMErED 9
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UNITED STATES OF AMERICA 1.iAY 2 71980 > 3 l NUCLEAR REGULATORY COMMISSION Clite cf the Secett:y 'IE BEFORE THE ATOMIC SAFETY AND LICENSING BOARD Occhethg a Se,tg I
In the Matter of
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METROPOLITAN EDISON COMPANY es art (Three Mile Island Nuclear
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Station, Unit No. 1)
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CERTIFICATE OF SERVICE I hereby certify that copies of Intervenor Steven C. Sholly Recommendations on Contention Grouping dated May 19, 1980, which was hand delivered to Licensee at Three Mile Island Observation Center, Middletown, Pennsylvania, on May 20, 1980 were served upon those persons on the attached Service List by deposit in the United States mail, postage paid, this 21st day of May, 1980.
f#L fohnF. Wilson Dated: May 21,1980 9
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMI N ND LICENSING BOARD In the Matter of DOCKETED
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USNRO j
Docket No. 50-289 METROPOLITAN EDISON COMPAQ )P.W 2 7 E >
(Restart)
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(Three Mile Island Nuclear.9
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Station, Unit No.1) g,,, c
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4 SERVIC ST Ivan W. Smith, Esquire Karin W. Carter, Esquire
.ssictant Attorney General A
Chairman
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Atomic Safety and Licensing Commonwealth of Pennsylvania Board Panel 505 Executive House
-..P.O.
Box 2357
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U.S. Nuclear Regulatory Commission Harrisburg, Pennsylvania 17120 Washington, D.C.
20555 Robert L. Knupp, Esquire Dr. Walter H. Jordan Assistant Solicitor Atomic Safety and Licensing County of Dauphin Board Panel P.O. Box P 881 West Outer Drive 407 North Front Street Oak Ridge, Tennessee 37830~
Harrisburg, Pennsylvania 17108 Dr. Linda W. Little-John E. Minnich Atomic Safety and Licensing Chairman, Dauphin County Board of Board Panel Commissioners j
5000 Hermitage Drive Dauphin County Courthouse j
Raleigh, North Carolina 27612 Front and Market Streets j
Harrisburg, Pennsylvania 17101 i
James A. Tourtellotte, Esquire Office of the Executive Legal Walter W. Cohen, Esquire Director Consumer Advocate U.S. Nuclear Regulatory Commission Department of Justice Washington, D.C.
20555 14th Flocr, Strawberry Square Harrisburg, Pennsylvania 17127 u
i Docketing and Service Section Office of the Secretary Jordan D. Cunningham, Esquire U.S. Nuclear Regulatory Commission Attorney for Newberry Township
- j Washington, D.C.
20555 T.M.I. Steering Committee
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2320 North Second Street John A. Levin, Esquire Harrisburg, Pennsylvania 17110
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Assistant Counsel Pennsylvania Public Utility theodore A. Adler, Esquire Commission Widoff Reager Selkowitz & Adler P.O. Box 3265 P.O. Box 1547 Harrisburg, Pennsylvania 17120 Harrisburg, Pennsylvania 17105
- Person on whose behalf service is being made. Only Certificate of Service is enclosed.
Ellyn Weiss, Esquire Chauncey Kepford Sheldon, Harmon & Weiss Judith H. Johnsrud Environmental Coalition on Nuclear Power Suite 506 3
1725 Eye Street, N.W.
433 Orlando Avenue Washington, D.C.
20006 State College, Pennsylvania 16801 Steven C. Sholly*
Marvin I. Lewis 304 South Market Street 6504 Bradford Terrace Mechanicsburg, Pennsylvania 17055 Philadelphia, Pennsylvania 19149 Holly S. Keck Marjorie M. Aamodt R. D. 5 Legislation Chairman I
Anti-Nuclear Group Representing Coatesville, Pennsylvania 19320 York 245 West Philadelphia Street George F. Trowbridge, Esquire g
York, Pennsylvania 17404 Shaw, Pittman, Potts & Trowbridge 1800 M Street, N.W.
4 Karen Sheldon, Esquire Washington, D.C.
2002 P;
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Sheldon, Harmon & Weiss Suite 506 Susan Barley 129 Cocoa Avenue 1725 Eye Street, N.W.
Washington, D.C.
20006 Hershey, Pennsylvania 17033 Robert Q. Pollard Chesapeake Energy Alliance 609 Montpelier St'reet i
Baltimore, Maryland 21218
- Person on whose behalf service is being made. Only Certificate of Service
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is enclosed.
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