ML20005A621
| ML20005A621 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 06/19/1981 |
| From: | Weiss E HUNTON & WILLIAMS |
| To: | Cutchin M NRC |
| References | |
| NUDOCS 8106300507 | |
| Download: ML20005A621 (4) | |
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Mac Cutchin, Esquire t /
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RE:
TMI-Restart. Docket No. 50-289
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Dear Mac:
We have been reviewing the testimony of Zoltan Rosztoczy dated 6/15/81.
Beause of the very brief and conclusory nature of the testimony, in order for UCS to determine the nature and length of our cross-examination, we need to know the answers to the following questions :
1)
Will the s taff present with Mr. Rosztoczy a witness who was personally involved in the environmental qualification review for TMI-l and can testify on particular equipment in TMI-l?
Mr. Rosztoczy indicated at the previous hearing session that he was not so personally involved (Tr. 6929) 2)
Will the s taf f present any documents beyond those distributed on June 15?
In particular, will the staff intro-duce the M, arch 24 SER and the April 23 revision on environ-mental qualification?
They are neither attached to nor re-ferenced in the testimony, 3)
The March 24 SER requires the licensee to provide certain f urther information and analyses within 90 days -
approximately June 24 - on the f ollowing :
a) a description of a pathway to cold gg f p 4 //*hs shutdown, and a demons tation that equipment
[E so used is qualified.
(p. 10)
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b) compliance with TMI Lessons Learned
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modifications with respect to environmental r.__
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qualification (p. 10).
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C.;)'*. kwy c) a complete list of instrumentation ',
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mentioned in the emergency procedures, plus equipment qualification information.
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HARMON & WEISS Mac Cutchin,-Esquire June 19, 1981 Page 2 instrument not classified saf ety-related but mentioned in the procedures, justification is to be provided for not considering the instru-ment saf ety related and assurance provided that its f ailure will not mislead the operator
( p. 3 ).
d) inf ormation on qualification of TMI-1 equipment against the eff ects of chemical spray (p. 5) e)
consider the eff ects of aging by esta-
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blishing a program to identify age-related de-gradations and to replace such components ( p. 5 -6 )
So far as we can tell, the staff testimony deals with none of the above, nor has the SER been supplemented to resolve these open items.
Will the staff present any testimony on these subjects by a witness prepared to answer questions about specific equipment?
Will any documentation of resolution of these issues ba offered into evidence?
. As you may have deduced, UCS considers the prefiled testimony to be virtually completely conclusory without even any indication of the specific areas related to THI-i which the witness will be prepared to address.
At the risk of exposing our plans for cross-examination to you, we have concluded that the only way the hearing cession will be useful is if we have the answers to the above questions a s quickly as possible.
I also wish to notify you that unless a witness is presented with direct personal knowledge of the equipment in TMI-l and the status of its qualification including the status of issues left open by the March 24 SER, CCS will object to those portions of Mr. Rosztoczy's testimony which contain conclusory statements to the ef f ect that the equipment necessary to cope with a loss of f eedwater/SBLOCA event has been or will be demonstrated to be quali f ied.
I will phone you soon to discuss this further.
Very truly yours, Ellyn R. Weiss ERW/dmw -
cc:
TMI-Service List
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UNITED STATES OF AMERICA NUCLEAR REGUL,\\ TORY COMMISSION BEFORE Tile ATOMIC SAFETY AND LICENSING BOARD
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In the Matter of
)
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MCTROPOLITAN EDISON COMP ANY, et al.,
)
Docket No. 50-289
)
Restart
( Thr ee Mil e Isl and Nuclear Sta tion,
)
Unit No. 1)
)
)
CERTIFICATE OF SERVICd I hereby certify that on this 19th d.ly of June 1981 a copy of the June 19th letter to Mac Cutchin, Esquire was mailed first class postage pre-paid tu the f ollowing :
Secretary of the Commission Jordan D. Cunningham, Esq.
U.S. Nuclear Regulatory Commission Fox, Farr & Cunningham Wa s h ing to n,
D.C. 20555 2320 North Second Street ATTN:
CF. l e f, Decketing &
Harrisburg, PA 17110 Service Section James A. Tourtellotte, Esq.
Frieda Berryhill Office of the Executive Coalition for Nuclear Power Legal Director Pos tpo neme nt U.S.
Nuclear Regulatory Commission 2610 Grendon Drive Washington, D.C.
20555 Wilmington, Delaware 19808 Karin W.
Carter, Esquire Wal ter W. Cohen, Consumer Advc Assis tant Attorney General Department of Justice 505 Executive House Strawberry Square P.O.
Box 2 35 7 14th Floor lla r ris bu rg, PA 17120 lia r r isbu rg, PA 17127 Daniel M.
Pell Ste ven C.
Sholly 32 Sou th Beaver Street Union of Concerned Scientis ts Yor k, Pennsylvania 17401 1725 I Street,
N.W.
6th Floor Was hi ngto n.
D.C.
20006
Cert. of Service Docket No. 50-289 Robert L.
Knupp, Esquire Chauncey Kcpford Assistant Solicitor Judith H. Johnsrud County of Dauphin Environmental Coalition on P.O. Box P Nuclcar Power 407 North Front Street 433 Orlando Avenue Harrisburg, PA 17108 Stato College, PA 16801 John A. Levin, Esquire Robert Q. Pollard Assistant Counsel Chesapeako Energy Alliance Pennsylvania Public Utility 609 Montpelier Street Commission Baltimore, Maryland 21218 Harrisburg, PA 17120 Theodore Adler Marvin I. Lewis Widoff, Reager, Selkowitz 6504 Dradford Terrace
& Adler Philadelphia, ?A 19149 3552 Old Gettysburg Road Camp Hill, PA 17011 Ms. Marjorie Aamodt Ivan W. Smith, Chairman RD #5 Atomic Safety & Licensing Board Coatesville, PA 19320 U.S. Nuclear Regulatory Commissi Washington, D.C.
20555 Dr. Walter H. Jordan h,','T [itkiN eNsociates 881 W. Outer Drive 1712 Annanolls Drive Oak Ridge, Tennessee 37830 Raleigh, North Carolina 27608 George F. Trowbridge, Esquire Ms. Jane Lee Shaw, Pittman, Potts &
R.D.
93, Box 3521 Trowbridge Etters, Pennsylvania 17319 1800 M Street, N.W.
Washington, D.C.
20036 Robert W. Adler Dept. of Environmental Resources 505 Executive House P.O.
Box 2357 Harrisburg, Pennsylvania 17120 fn /
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Ellyn' R. Weiss y