ML19211A130

Revised Contention 4 Alleging Licensee Unreadiness to Deal W/Specialized Nature of Civil Disruption That May Occur Due to Restarting of Facility.Certificate of Svc Encl

ML19211A130
Person / Time
Site:	Three Mile Island
Issue date:	11/13/1979
From:	Adler T THREE MILE ISLAND ALERT, WIDOFF, REAGER, SELKOWITZ & ADLER
To:	Atomic Safety and Licensing Board Panel
Shared Package
ML19211A126	List: ML19211A125 ML19211A130
References
NUDOCS 7912170070
Download: ML19211A130 (2)

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4 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION h

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BEFORE THE ATOMIC SAFETY AND LICENSING BOARD #:' ,h

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In the Matter of )

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METROPOLITAN EDISON COMPANY ) Docket No. 50-289

) (Restart)

(Three Mile Island Nuclear )

Station, Unit No. 1) )

LEVISED CONTENTION 4 It is contended that if TMI-1 is restarted, demonstrations will occur that will threaten the security of the entire Island, thereby presenting a clear and present danger to both TMI-l and the damaged TMI-2 reactors. Local and State authorities are not trained nor equipped to deal with these types of civil disrup-tions, nor do they have the financial resources to become so equipped and trained. Licensee has not developed any plans to deal with the specialized nature of such civil disruption. If the security of TMI-l or TMI-2 were breached, the consequences would be the release of high levels of radiation into the air and water, causing sickness and death. It is contended that it will be virtually impossible to secure the integrity and insure the safety of TMI-l and TMI-2 when widespread civil disruption occurs.

Respectfully submitted, a

/O. "

Theodore A. Adler Widoff, Reager, Selkowitz & Adler, P.C.

P. O. Box 1547 Harrisburg, PA 17105 (717) 763-1383 1596 117 Dated: November 13, 1979 '

7912170

.' l UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of )

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METROPOLITAN EDISON COMPANY ) Docket No. 50-289

) (Restart)

(Three Mile Island Nuclear )

Station, Unit No. 1) )

SERVICE LIST Ivan W. Smith, Esquire Chairman Atomic' Safety and Licensing Board e Y' bgyp;,f'k[7

-, - h's U.S. Nuclear Regulatory Commission E.7 5? " ' ~-  ;:1-Washington, DC 20555 , _2[ , , -c e; m:.- a '

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Dr. Walter H. Jordan, Member {i,  :

Atomic Safety and Licensing Board -Is 881 West Outer Drive ,'N s_ __% ' , '

Oak Ridge, TN 37830 v, .0 Dr. Linda W. Little, Member Atomic Safety and Licensing Board 5000 Hermitage Drive Raleigh, NC 27612 James A. Tourtellotte, Esquire .

Office of the Executive Legal Director U.S. Nuclear Regulatory Commission Washington, DC 20555 1596 118 Docketing and Service Section Office of the Secretary U.S. Nuclear Regulatory Commission Washington, DC 20555 George F. Trowbridge, F. squire Shaw, Pittman, Potts & Trowbridge 1800 M Street, N.W.

Washington, DC 20036