ML19318D202
| ML19318D202 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 06/26/1980 |
| From: | Pollard R UNION OF CONCERNED SCIENTISTS |
| To: | |
| Shared Package | |
| ML19318D195 | List: |
| References | |
| NUDOCS 8007080050 | |
| Download: ML19318D202 (4) | |
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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION 3'50MIC SAFETY AND LICENSING BOARD In the Matter of
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METROPOLITAN EDISON COMPANY
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Docket No. 50-289
( estard (Three Mile Island Nuclear
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Station, Unit No. 1)
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AFFIDAVIT OF ROBERT D.
POLLARD ROBERT D. POLLARD, being duly sworn according to law, deposes and says:
JLt my deposition on April 11, 1980, I was unable to answer two questions by Mr. Tourtellotte because I had not had sufficient time to review the relevant materials necessary to form a basis for my answers.
At the request of Mr. Tourtellotte, I now submit my answers to the following questions:
Question #1:
"Could you take a look at NUREG-0660, Task II D, and'see whether or not it does meet the concerns that you express in Contention 6?" (Tr. 4 6)
Response #1:
I have read Task II.D in the Task Action Plan, Draft 3 dated March 5, 1980 and in the final version dated May, 1980.
The information presented there does not meet the concerns addressed in UCS Contention 6.
In fact the" information provided by the staff confirms that appropriata qualification has not 80070s0egtg
been done to verify the capability of the relief and safety valves to function during normal, transient and accident conditions.
The Task II D description also demonstrates that" the staff does not know what should constitute an adequate test plan or what criteria will be used to determine whether the test results are acceptable.
Rather than " meeting" the concerns expressed in UCS Contention 6, the Task Action Plan demonstrates that the staff
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is currently unable to show compliance with GDC 1,4,15, and 30.
The staff will not be able to establish such compliance until some unspecified time af ter the test program is completed, and that is not required until July 1, 1981.
4 Question #2:
"Do you have any misgivings about what position the staff is taking [regarding UCS Contention #14 as you know it at this point?" ***
"Can you review the latest submittals that we have given you again, and with that question in mind tell me whether or not you believe the staff's approach is adequate or inadequate?"
(Tr.81-82)
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Response #2:
I I have read the staff's response, dated March 31, 1980, to UCS interrogatories 150,151,152, and 153.
The " misgivings" I have are that the staff's approach is precisely that stated in UCS Contention 14, i.e. the staff proposes to study the problem further but not require TMI-l to remain shutdown until their study is completed.
The staff confuses identification of that problem and reasonable progress in resolving that problem with actually solving the problem.
In other words, the staff's position is that the health and safety of the public
may be endangered provided the staff has plans to study how that' threat can be allpviated.
That approach is inadequate and unacceptable..
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ROBERT D. POI 1ARD Union of Concerned Scientists
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.i.;p' Sworn to and subscribad before me this 26th day of June, 1980 Mb s/
Notary Public l
Tfy Commission Evices Deee-.ber 14.198+
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UNITED STATES OF AMERICA
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NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD
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In the Matter of
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METROPOLITAN EDISON
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COMPANY, et al.,'
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Docket No. 50-289
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(Restart)
(Three Mile Island
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Nuclear Station, Unit
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No. 1)
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CERTIFICATE OF SERVICE o
- I hereby certify that a copy of the " Affidavit of Robert D. Collard" was mailed first class postage pre-paid this 26th day of-Jul 1980' to the following parties:
Secretary.of the Commission ATTN:
dhief, Docketing and Service Section U.S. Nuclear Regulatory Commission Washington, D.C.
20555 Ivan W. Smith, Esquire Atomic Safety & Licensing Board Panel U.S. Nuclear Regulatory Commission Washington, D.C.
20555 Dr. Walter H. Jordan 881 W. Outer Drive Oak Ridge, Tennessee 37830 Dr. Linda W. Lit *cle 5000 Hermitage Drive Raleiegh, North Carolina 27612 George F. Trowbridge, Esquire Shaw, Pittman, Potts & Trowbridge 1800 "M" Street, N.W.
Washington, D.C.
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, James Tourtellotte, Esquire Office of the Executive Legal Director U.S. Nuclear' Regulatory Commission Washington, D.C.
20555 O
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El' lyn"R. Weiss
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