ML19332B226
| ML19332B226 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 07/18/1980 |
| From: | Trowbridge G METROPOLITAN EDISON CO., SHAW, PITTMAN, POTTS & TROWBRIDGE |
| To: | |
| References | |
| ISSUANCES-SP, NUDOCS 8009260301 | |
| Download: ML19332B226 (11) | |
Text
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LIC 7/18/80 4
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c,4g Memorandum
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3 44)A jge To:
All Parties in TMI-l R st t
aring S
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George F. Trowbridge 4
Re:
Grouping and Sequenc'e of Hearing Issues At the prehearing conference held on May 13, 1980, I distributed to the Board and to all parties a three page draft document dated April 14, 1980, containing a suggested grouping by subject matter of the Commission's August 9,
- 1979, Order items and of the contentions in the proceeding.
Some of the parties subsequently commented on the groupings in filings with the Board.
For your convenience an additional copy of the April 14 document is attached.
The April 14 document did not suggest the order in which the subject matter groups should be taken up in the hearing.
Attachment A to this memorandum reflects Licensee's present view as to the order in which the groups should be considered.
Note that the subject of offsite monitoring cap-ability (treated as a separate topic in the April 14 document) would now be covered under emergency planning and prepared-ness.
Every effort should be made to complete testimony and cross-examination by all parties on each of the groups before taking up the next group.
B0092009
Memorandum to All Parties in TMI-l Restart Hearing July 18, 1980 Page Two For three of the five subject matter groups (Groups B,
C and E) Licensee plans a single piece of testimony which will address all of the August 9 Order items and contentions associated with each group.
We feel this is necessary to provide continuity to our testimony and because of tne inter-relationship of issues and contentions.
Two subject matter groups, however, contain a number of reasonably discrete issues and contentions which in our view call for further subgrouping, namely Group A - Analysis and Modification of Plant Design and Procedures and Group D -
Management Capability.
Attachments B and C to this memorandum reflect Licensee's present plans both as to the subgrouping of Groups A and D, respectively, and the order in which the subgroups will be treated in Licensee's testimony.
As to Group A, Licensee visualizes an introductory piece of testimony followed by separate pieces of testimony for each subgroup.
The introductory piece of testimony would contain a general description of TMI-l reactor design.
To the extent cross-examination of the introductory testimony antic-ipates cross-examination as to specific contentions, we will urge the Board to defer the cross-examination until after tes-timony covering the contention has been presented.
Following
Memorandum to All Parties in TMI-l Restart Hearing July 18, 1980 Page Three the introductory testimony, testimony relating to each of the proposed subgroups would be presented.
We propose that cross-examination proceed and be completed on Licensee's testimony for each subgroup before turning to Licensee's testimony on the next subgroup.
We hope that other parties will give ser-ious consideration to a parallel grouping of their own direct testimony.
In the case of Group D - Management Capability, Licensee is developing testimony which is organized to track the management area issues contained in CLI-80-5 of March 6, 1980.
Related contentions would be dealt with in the appro-priate pieces of testimony addressing the issues identified by the Commission.
Our present outline for testimony in the area of Management Capability is reflected in Attachment C to this memorandum.
To give the parties more time to think about the hearing agenda, I am distributing Attachments B and C without waiting for revisions in contentions which may hereafter be submitted pursuant to Board orders.
However, the attachments do reflect that since the May 13 prehearing conference sev-eral intervenors have dropped selected contentions and that certain of the ECNP contentions have been dismissed.
In the
1 Memorandum to All P,arties in TMI-l Restart Hearing July 18, 1980 Page Four.
case of ANGRY and Mr. Sholly, contention references are to proposed revisions as recently distributed to the Board and parties.
It is my hope that a meeting with the Staff and Intervenors' representatives can be arranged prior to the prehearing conference on August 12 to discuss and hopefully agree on recommendations to the Board as to the order in which issues should be considered and testimony presented.
Meanwhile, comments on the attachments would be welcome.
cc w/ attachments:
Members of the ASLB
?
GROUPING OF STAFF RECOMMENDATIONS AND INTERVENOR CONTENTIONS Staff Intervenor Recommendations Contentions Analysis ST-1 (a) : EFW Timeliness & Re-ECNP (10/22/79)
& Modification liability Nos. 1(a) of Plant Design ST-1 (b) : Independence of EFW from ICS 1(b)
ST-1 (c) : Reactor Trip or Loss of 1(c)
Main Feedwater and/or 1(d)
Turbine Trip 1(e) 1(g) l ST-1 (d) : Analysis of Small Breaks ST-2:
Compliance with IE 1(h)
Bulletins'79-05 A,B&C 1(i)
ST-8:
Compliance with Lessons 4
j Learned Category A Items
' Sholly Nos.
LT-1:
ICS Failure Made and Effects Analysis 1
g LT-2:
Small Break Analysis and 2
Procedures 3
LT-3:
Compliance with Lessons Learned; 5
Category B Items 6
7 11*
13 15 17
" Lewis contention i
ANGRY No. 5 (A)
- 5 (B)-(D
! UCS Nos. 1&2 8
3 4
l 5
6 7
8 9
10 11*
12 i
13 f
14 i!
l* Hydrogen control
& contentions certi fied to the Commission
z-Staff Intervenor Recommendations Contentions TMI-l and ST-4: Separation of TMI-2 ECNP (10/5/79) No. 19 TMI-2 Operations from TMI-l Separation ST-5: Waste Management Capability CEA Nos. 5 6
7 Sholly Nos. 10 16 TMIA No. 7 Aamodt No. 8 Off-Site Radiation ST-3(c): Emergency Preparedness --
Monitoring Upgrade Offsite Monitoring Capability Sholly.
Nos. 4 9
Emergency Plans 'ST-3 (a), (b), Emergency Prepared-ECNP (10/22/79) No. 2 (d) and (e) : ness
,LT-4:
Emergency Prepared-ness Sholly No. 8 Newberry Township No. 3 t
Aamodt Nos. 4 5
ANGRY Nos. 1 2
3 Elanagement ST-6 :
Managerial Capability and ECNP (10/22/79)
No. 3 Resources
' Capability and Resources CEA No. 8 Sholly No. 14 i
Staff Intervenor Recommendations Contentions TMIA No. 5 Management Capability and Resources Aamodt No. 2 (cont.)
ANGRY No. 4 CEA No*
- '3 Operator ST-1 (e ) : Retraining of Operators Training (natural circulation &
Aamodt No. 2 small break LOCA; B&W simulator)
ST-2:
Compliance with IE Bulletins 79,-05 A,B,C ST-6:
Managerial Capability &
Resources (Training of Operations Staff) i i
LT-3:
Compliance with Lessons Learned Category B Items (training-shift safety engineer) 1 i
l l
Financial ST-7:
Financial Qualifications CEA No. 9 Qualifications TMIA No. 6 1
Cumulative ECNP No. 5 l
Radiation Effects TMIA Nos. 1 2
CEA No. 4 i
Aamodt No. 9 Psychological Distress ECNP No. 6 Newberry Nos. 1 2
PANE Nos. 1 2
TMIA Mo. 3 Shollv No. 12 CEA No. 1 EIS Required (deferred)
Sholly No. 12 TMIA No. 8
A-1 Attachment A Sequence of Subject Matter Groups Group A Analysis and Modification of Plant Design and Procedures i
Separation of TMI-l and TMI-2 Group B Group C Emergency Planning and Preparedness (including off-site monitoring capability)
Group D Management Capability Group E Financial Qualifications
B-1 Attachment B Division of Group A into Subgroups and Related Contentions Subgroup 1 - Core Cooling a.
Natural and Forced Circulation UCS-1 UCS-2 b.
Additional LOCA Analysis UCS-8 ECNP-1(e) c.
Detection of Inadequate Core Cooling UCS-7 ANGRY-V(B)
Sholly-6(b) d.
EPCS Bypass and Override UCS-10 Sholly-3 Subgroup 2 - Equipment Design & Modifications a.
Safety Classification UCS-12 UCS-14 UCS-3 b.
Valves and valve Testing UCS-5 UCS-6 c.
Integrated Control System Sholly-6 (a) d.
Connection of Pressurizer Heater to Diesel UCS-4 l
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B-2 e.
Containment Isolation Sholly-1 f.
Filters Lewis ANGRY-V(D) g.
Control Room Design -
Human Factors Engineering Sholly-15 ANGRY-V(C) h.
Computer Sholly-13 ECNP-1 (a) i.
Safety System Status Panel UCS-9 ECNP-l (c) j.
Instrument Ranges (in plant)
Sholly-5 ECNP-1(d)
Subgroup 3 - Accident Design Bases a.
Accident Sequences to be Considered in Plant Design / Class 9 UCS-13 Sholly-17 ECNP-4b & c b.
Hydrogen Generation and Control UCS-ll Sholly-ll Sholly-6 (c) & (d)
ANGRY-V(A)
C-1 Attachment C Division of Group D into CLI-80-5 Issues and Related Contentions Commission Related Subgroup Issue
- Contentions Command and Administrative Structure (1)
Sholly 14 ANGRY IV CEA 8 Unit Staff (2) / (5)
Aamodt 2 ANGRY IV Sholly 14 CEA 8 CEA 13 TMIA 5 Health Physics Program (4)
Sholly 14 CEA 8 ANGRY IV Financial / Technical Interface (6)
Safety Review Groups (7)
ANGRY IV Sholly 14 CEA 8 Infraction History (8)
LER History (9)
Management Response to Accident (10)
Technical Resources (11)
Sholly 14 CEA 8
- Licensee does not plan to present testimony on Commission Issue 3.
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