ML19241B290

Forwards Motion Seeking Preliminary Injunction,W/Complaint & Memo of Particulars in Support of Motion & W/Supporting Documentation

ML19241B290
Person / Time
Site:	Davis Besse
Issue date:	07/09/1979
From:	Lodge T TOLEDO COALITION FOR SAFE ENERGY
To:	Harold Denton Office of Nuclear Reactor Regulation
Shared Package
ML19241B291	List: ML19241B290 ML19241B292 ML19241B293
References
RTR-NUREG-0396, RTR-NUREG-396 NUDOCS 7907130513
Download: ML19241B290 (1)

Text

P.O. Box 2091 Toledo, OH 43603 July 9,1979 Mr. Harold Denton, Director Office of Nuclear Reactor Regulation RE: Davis-Besse Nuclear Power Station U.S. Nuclear Regulatory Commission Cocket No. 50-346 1717 H Street, N.W.

Washington, D.C. 20555

Dear Mr. Denton:

Thank you for your correspondence of June 27, 1979. I believe that the enclosed might be of assistance to the Commission in revisiting its decision to allow Davis-Besse to restart.

Please find herein a verified copy of (1) a motion by the Toledo Coalition for Safe Energy to this Commission seeking a prelininary ine junction or any NRC order having the practical effect of closing down Davis-Besse pending sweeping revisions to emergency plans for the plant; and (2) a Complaint c 1d Memorandum of Particulars in support of that motion. We have included a number of documentary appendices in supoort of our allegations which we hooe will facilitate NRC staff assessment and verification of our conclusions.

In light of the chaos that prevailed among the public and state emergency preparedness officials during the Three tiile Island crisis, it is imperative that the NRC place increased stress upon emergency preparations in the event of nuclear accidents. To do less is to ignore the threat to public health and safety which is posed by nuclear power.

With particular respect to Davis-Besse, the incredibly poor operator and technical performance record of the plant underscores the need for emergency plans to be revised and proven workable now, before they micht be required.

~

MM l 3OS (3 Because of the imminent threat to health and safety which is posed by lax arrangements for emergencies at Davis-Besse, I hereby request that the NRC take all steps to expedite TCSE's comolaint.

If we do not have confirmation of definitive action by the NRC within fourteen (14) days of this date, we will be forced to examine the options of federal court facilitation. However, I am certain that the NRC is not willing to see the chaotic emergency preparations during the TMI crisis repeated, and will adopt the same dim view of Davis-Besse emergency plans that TCSE has, and that the Commission will act quickly and responsibly.

We await your earliest processing'of our complaint and reouest for restraining order. Thank you for your timely consideration. 0g 0 '

7\ \ s Respectfully, -

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Terry J. Lodge cc: Mr. Stephen Burns , CELD Counsel for TCSE pb40 Mr. Bruce Churchill, Counsel for Licensees O/

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