ML20204F677

Submits Proposed Questions Re 860908 Evidentiary Hearing & 860721 Leak Rate Inquiry.Served on 860731

ML20204F677
Person / Time
Site:	Three Mile Island
Issue date:	07/30/1986
From:	Atomic Safety and Licensing Board Panel
To:	Capra R, Kirkpatrick D, Rockwell W NRC
References
CON-#386-150 LRP, NUDOCS 8608040274
Download: ML20204F677 (2)

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o NUCLEAR REGULATORY COMMISSION 3 ~$ ATOMIC SAFETY AND LICENSING BOARD PANEILKETED USNRC

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'86 JL 31 P2 :28 July 30, 1986 0FFICE OF :.: ar. ; An Y 00CKETINt3 & St RVICf.

BRANCH MEMORANDUM FOR: Robert A. Capra Donald C. Kirkpatrick Winthrop A. Rockwell William T. Russell Edwin H. Stier SERVEDJUB(pd Jared S. Wermi 1 FROM: The P ding oard TMI-2 eak Rate Inquiry (Docket No. LRP)

SUBJECT:

QUESTIONS FOR THE EVIDENTIARY HEARING On July 21, 1986, two parties in the TMI-2 Leak Rate Inquiry filed sets of questions which they propose be put to you by the Board. Under previously established procedures, the Board has reviewed these questions primarily to detemine whether they are within the scope of the issues in this proceeding. As a result of that review, w~e are transmitting to you for your review all but a few of the questions suggested to us. Specifically, of the questions proposed by the Numerous Employees, the Board rejected those listed below:

i Questions for Kirkpatrick 1, 3, 4, 19, 37, 67, 82, and Wemiel 253, 262 Questions for Russell and 1, 3, 4, 19, 37, 66, 139, Capra 143, 255, 264 Questions for Rockwell 1, 3, 4, 19, 37, 40-43, 67 Questions for Stier 1, 3, 4, 19, 37, 40-43, 67, 82, 95-97, 101, 151, 155, 1 265, 267, 268, 276, 277.

We have added new Board Wermiel and Stier questions 66 and(questions 67 of 67A in the case and 68A to the Kirkpatrick-Russell-Capra).

( In the case of the Aamodt questions, we have rejected only question 1 for Mr. Russell.

The Numerous Employees' questions appear to cover the technical issues comprehensively. We expect to be active in putting follow-up 8608040274 860730 PDR ADOCK 05000320

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questions to the witnesses. Therefore, we are not posing questions of our own at this juncture.

Each of the Numerous Employees' four sets of questions raise over 250 questions that are identical or virtually identical to questions in the other three sets. To put it another way, most of the questions being put to you individually are also being asked of the other witnesses. While that approach can be quite helpful, we think it virtually requires us to employ the panel technique for testimony, whereby all six of you, plus technical experts to accompany Rockwell and Stier, would be sworn in to testify at the same time. The only apparent alternative would be to put over 250 technical questions to four sets of witnesses consecutively, which would take much longer and lose the benefit of on-the record-exchanges between you.

In these circumstances, we expect to begin the hearing on September 8 with a panel consisting of all of you plus technical experts accompanying Rockwell and Stier. We will focus first on the 250-plus connon questions, which may take several days. Following that, we will put the relatively few individual questions to Rockwell and then to Kirkpatrick and Wermiel. The bulk of the individual questions are for Stier and Russell and Capra. The timing of their appearance on individual questions can be worked out on the basis of convenience and other relevant factors.

Most of the 250-plus common questions are not directed toward particular parts of your testimony or reports. Thus, there may be i questions for which one or more of you have no present basis for an answer. In such a case, we do not expect you to do significant additional research to develop an answer; an "I don't know" response will be acceptable. Furthermore, we have restricted to the Staff

witnesses certain broad questions relating to other reactors or to Staff practice. As to such questions, it is not necessary that all the Staff witnesses respond. Furthermore, Staff counsel should advise us if

! development of answers to any of the questions would be unreasonably burdensome.

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Enclosures cc: Service List w/o Enclosures ,

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