ML19322D369
| ML19322D369 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 02/04/1980 |
| From: | Chandler L NRC OFFICE OF THE EXECUTIVE LEGAL DIRECTOR (OELD) |
| To: | Buck J, Johnson W, Rosenthal A NRC ATOMIC SAFETY & LICENSING APPEAL PANEL (ASLAP) |
| Shared Package | |
| ML19322D370 | List: |
| References | |
| NUDOCS 8002120300 | |
| Download: ML19322D369 (2) | |
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UNITED STATES
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NUCLEAR REGULATORY COMMISSION 3e y
WASHINGTON, D. C. 20555
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February 4, 1980 Alan S. Rosenthal, Esq., Chairman Dr. W. Reed Johnson, Member Atomic Safety and Licensing Appeal Atomic Safety and Licensing Appeal Board Board U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Commission Washington, D. C.
20555 Washington, D.C.
20555 Dr. John H. Buck, Member Atomic Safety and Licensing Appeal Board U.S. Nuclear Regulatory Commission Washington, D.C.
20555 In the Matter of Metropolitan Edison Company, et al.
(Three Mile Island Nuclear Station, Unit 2)
Docket No. 50-320 Gentlemen:
This Appeal Board, in its Memorandum and Order, ALAB-570 (November 2, 1979),
rescheduling the postponed further hearing on the aircraft crash probability issue in this proceeding, provided that additional affirmative evidence any party deems warranted should be filed and served by February 4, 1980.
In accordance with that direction, the NRC Staff is filing, with this letter:
1.
Affidavit of Jacques B. J. Read and attached " Analysis of Addition of 1978 Air Traffic and Accident Ratec and Revi-sions to 1976 and 1977 Estimates to 'NRC Staff Testimony Regarding U.S. Air Carrier and Military Accident and Traffic Data' and ' Evaluation of Aircraft Crash Potential for Nuclear Plants'";
2.
Joint Affidavit of Roger H. Moore and Lee R. Abramson and attached "Analycis of the Effects of Updated Data on the Previously Submitted Testimony and Supplemental Testimony of R. Moore and L. Abramson"; and, 3.
Supplemental Testimony of R. Mooresand L. Abramson in Response to ALAB-525.
Items 1 and 2 described above (Attachment 1) reflect the Staff's analysis of updated information including the year 1978 tc account for the period of time which has elapsed since this hearing connenced in December 1978. As antici-D6 1
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- pated by the Appeal Board (ALAB-570, slip op, at 11-12), the effect of this new information on the Staff's earlier testimony is believed to be insignifi-cant insofar as the Staff's conclusions are concerned. Accordingly, the Staff does not propose to have Dr. Read available to testify further in this pro-ceeding unless specifically requested by the Appeal Board or other parties.
Drs. Moore and'Abramson will be present for purposes of presenting item 3 above.
We do, however, intend to offer both items 1 and 2 as exhibits in this proceeding, we assume without objection unless the Appeal Board or other parties have reauested an opportunity to examine Dr. Read and Drs. Moore and Abramson on these items.
Item 3 described above (Attachment 2), the Supplemental Testimony of R. Moore and L. Abramson in Response to ALAB-525, was previously filed with the Appeal Board and parties on March 16, 1979, Another copy is being filed with this letter as a convenience to the Appeal Board and parties.
In an effort to facilitate the hearing with respect to the testimony of the four subpoenaed airline pilots, the Staff sent each pilot a list of preliminary questions, asking that each fill in his answer. A copy of the questions sent is attached (Attachment 3).
We anticipate that these questions will constitute the bulk of the Staff's direct examination of each pilot and we intend to offer the completed questionnaire for incorporation in the transcript as if read as with other prefiled testimony. To date, we have received responses from Captain Donald L. Ufford and Captain Clark Billie. Copies of these completed questionnaires are enclosed as part of Attachment 3.
As the remaining questionnaires are received, we will promptly forward them to the Appeal Board and parties.
In this way, we expect that the need for any substantial direct examination will be avoided, and, since the Appeal Board and parties will have an opportunity to review the information well in advance of the hearing, any cross-examination by the parties will be better focused and more quickly accomplished.
As indicated in Mr. Bordenick's letter of this date to the Secretary to the Appeal Board, the Staff will call, as witnesses regarding the aircraft crash probability issue, Drs. Moore and Abramson of the Staff, and Captains Eillie, Beuerlein, Lithgow and Ufford or Clishman. With respect to this issue, the Staff will be represented by the undersigned and Mr. Stuart A. Treby.
Sin erely.
Lawrence c.
Chandler Counsel for NRC Staff
Enclosures:
As stated cc w/encls: Service List
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