ML19305A063

Forwards Limited Appearance Statement by Rd Pollard of Ucs. W/Encls

ML19305A063
Person / Time
Site:	Trojan File:Portland General Electric icon.png
Issue date:	12/18/1978
From:	Roisman A National Resources Defense Council
To:	NRC ATOMIC SAFETY & LICENSING APPEAL PANEL (ASLAP), Atomic Safety and Licensing Board Panel
Shared Package
ML19305A064	List: ML19305A063 ML19305A070
References
TAC-11299, NUDOCS 7901020496
Download: ML19305A063 (2)

Text

%,,.. m..~.9. s,.ese-sa se Natural Resources Defense Council,Inc.

917 15TH STREET, N.W.

WASHINGTON, D.C. 20o05 son 737-5000 wastam osee

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"*"Y****"Y" 87 PALO A1.TO, CAWF. 943o6 December 18, 197 485 Ss7-io8o e

4 sas 949-oo49 Members of the Atomic Safety and Licensing Board Panel and I

i the Atomic Safety and Licensing Sr 6

7p Appeal Panel gyVd U.S. Nuclear Regulatory Commission g

Washington, D.C.

20555 Co sta Gentlemen and Ladies:

Enclosed is a copy of a recent limited appearance statement prepared and submitted by Robert Pollard of the Union of Concerned Scientists at hearings being held on the Trojan Nuclear Plant operating license.

No single document better illustrates the serious dilemma now faced by each of you in attempting to fulfill your statutory responsibilities at hearings where a thorough substantive input from citi::en N

cpponents of the proposed action is not presented.

I am sending Mr. Pollard's statement to you not because I believe he is correct, although I do, but because it illus-trates with reference to only a few of the issues relevant to decid3nc on whether to license a nuclear plant the kind of inquiry that could be made and which is not made absent the appearance of a person of Mr. Pollard's competence, integrity and commitment.

Mr. Pollard advises me that preparation of this document required more than 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />, exclusive of the time he spent as an AEC employee, examining the Trojan operating license application.

No citizen group can afford to hire Mr. Pollard or anyone of his calibre to competently present even a small percentage of the legitimate issues which should be resolved prior to deciding on whether to issue a construc-tion permit or an operating license.

As I did at the ASLB Training Seminar, I again raise with you the question of how you can legally and morally allow hearings to be concluded and decisions issued when you must be j

aware from your own experience and after reading Mr. Pollard's statement that you do not have presented to you all of the relevant information required to make a sound decision.

Surely the experiences in North Anna, St. Lucie, Shearon Harris, to mention only a few, have provided ample evidence that, in the heat and pressure of a proposed construction permit and operating T\\o \\ o2 o43G,

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o Members of ASLB and ASLAP December 18, 1978 Page Two proceeding, neither the Staff nor the applicant can be relied upon to provide you with the whole truth about the proposed action.

Without the benefit of an adequately funded citizen opponent to the proposal, no board has had or can ever expect to have an adequate record for decision.

I therefore urge all of you as a body to speak out to the Commissioners and to Congress in favor of an immediate provision for funding of qualified and relevant presentations by citizens in licensing proceedings.

While I fully believe similar funding is needed to provide legal assistance to citizens in these proceedings, I believe that including that in my recommendation would substantially reduce its chances of success.

Because success of this recommendation is so long overdue and so desperately needed, I only urge you to take the easy course.

You, more than anyone, need the benefit of funding of technical experts for citizens.

Please make the effort needed to obtain that benefit.

Sincerely, f

YM Anthon Z. Roismart enclosure I

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