ML19309D725

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Requests Hearing to Determine Whether Requirements Set Forth in Proposed Tech Specs Are Necessary & Sufficient to Protect Public Health & Safety.Tech Specs Do Not Take Into Account Hazards Posed by Continuing Accident at TMI-2
ML19309D725
Person / Time
Site: Crane Constellation icon.png
Issue date: 03/21/1980
From: Sholly S
AFFILIATION NOT ASSIGNED
To:
NRC COMMISSION (OCM)
References
NUDOCS 8004110184
Download: ML19309D725 (2)


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UNITED STATES OF AMERICA g

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In the Matter of

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IGIROPOLITAN EDISON COMP!dri, Er AL..

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Docket No. 50-320

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(Three Mile Island Nuclear

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Station, Unit No. 2)

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REQUEST EUR HEARING Pursuant to the Commission's Order of 2/11/80 a d the n

provisions of 10 CFR 2i?14, I, Steven C. Sholly, hereby file this request for a hearing on.whether the requirements set forth in the proposed Technical Specifications are both necessary and sufficient for the maintenance of the facility to protect the public health and safety and minimize the danger to life and property and1whether the provisions of r

'this Order would significantly affect the quality of the human environment.

I am a resident of Mechanicsburg, Pennsylvania, which is within fif teen. miles of the TMI-2 facility, and am employed at present in Hershey, which is some eight miles distant.

Most of the places to which I travel within the normal conduct of daily living are within fifteen miles of the facility.

I have, in addition established standing in the THI-1 Rester t Proceeding.

My interest in this proceeding is that of a private citizem concerned with the fine.ncial, technical, and management competance of Metropolitan Edison Company to safely maintain the TMI-2 reactor in safe confi uration.

The proposed Technical 6

Specifications as propounded in appendix I to the Commission's 8004110/

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.. Order of 2/11/80 do not take sufficient consideration of the unique hazards posed by the continuing accident at Three Mile Island Unit 2, nor do the proposed Technical Specifications take adequate note of the profound inability of Metropolitan Edison Company to write te.chnically sufficient procedures for operating TMI-2, to provide for sufficient training of reactor operators to implement proper procedures and ensure coupliance with Technical Specific tions, or to provide the a

technical, financial, and mana6ement skills required to safely conduct operations at TMI-2 while the plant is in the so-called

" Recovery Mode" of operations.

The p'roposed Technical Specifications provide for insufficient monitoring, surveillance, and reporting requirements.

The public health and safety is not adequately protected by the proposed Technical Specifications, and therefore rep-resent an. insufficient basis for ensuring the safe operation o f TMI-2.

Because of this,.the liklihood of significant impact on the human. environment is very high, unacceptably so..

A copy of this request for hearing has been sent to the Commission's Executive Legal Director and to the Counsel for the Licensee.

DATED:

21 March 1980 Respectfully submitted, l

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Steven C. Sholly l

304 South Market St.

Mechanicsbur$c, PA 17055 Ph.

(717) 7 6-1857 l

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