ML19320A730
| ML19320A730 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 06/16/1980 |
| From: | Hager R AFFILIATION NOT ASSIGNED |
| To: | NRC COMMISSION (OCM) |
| Shared Package | |
| ML19320A731 | List: |
| References | |
| NUDOCS 8007020550 | |
| Download: ML19320A730 (1) | |
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, POOR QUAUTY PAGES DO*KET NUMBER p00.8.JITIL FAC3b M....
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CHRISTIC IMSTITLTE A ReLigiou4 Public Policy Cente,s 1524 Non.th Capitc4 St, tee.t J,;
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'JUN 161980 *.
Officeof theStesbsy 5 NRC
\\\\ Csciski & Smice 1717 H Street, N.W.
Washington, D.C.
Centlement We are submitting undar this cover a copy of a report prepared by the Institute for Energy and Environmental Research of Heidelberg, TRG, under the auspices of Bernd Franke. The summary of this report was submitted to Commissioner Aheanne during the public meeting held on June 5,1980 by the NRC concerning venting of radioactive particulates and gases from
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the D11 Unit 2 reactor cantainment building. The report contains naterial that shows the proposed venting procedures to create significant hazards considerations that would be appropristely subject to the fact finding procedures of a public hearing.
We note with concern that your Order for Temporary Modification of License docketed on June 12, 1980 does not contemplate compliance with 10 CTR 2.105 as would normally be required where an amendment raises significant hazards considerations. While the question of whether or not the action proposed by the NRC will in fact present a significant hazard is still subject to debate, we firmly believe that the enclosed study by internationally recognized expert on the effects of radiation clearly shows beyond any doubt that there are significant considerations of hazard to the public health that deserve a full hesring before they may be adequately resolved.
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We also note that the NRC in its Order of June 12, 1980 purported to rely upon 10 (,TR 2.204 for the apparade authority to make its order immediately effective. While we have serious reservations whether this provision applies to others than the licensee it is clear that inmediate i
effectiveness of the Order would depend upon a finding that the public~3 health, safety and interest so requires. Not only has such a find.ing not been ma& by the NRC but we contend that the Heidelberg: study
- makes abundantly clear that the public interest lies in according-this issue of intentional release of radioactive materials int'o the atmosphere the full scale public hearing which its possibly profound consequences ~~'l deserve.
We would appreciate your response to the issues we have raised in regard a
to the significant new light which the Heidelberg study casts on this y
issue.
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Robert Hager
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