ML19330C130
| ML19330C130 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 07/28/1980 |
| From: | Widoff M THREE MILE ISLAND ALERT, WIDOFF, REAGER, SELKOWITZ & ADLER |
| To: | Atomic Safety and Licensing Board Panel |
| Shared Package | |
| ML19330C125 | List: |
| References | |
| ISSUANCES-SP, NUDOCS 8008070606 | |
| Download: ML19330C130 (3) | |
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l Revised Contention 5 It is conterided that Licensee has pursued a course of conduct that is in violation of 10 CFR 50.57,10 CFR 50.40,10 CFR 50.36,10 CFR 50.71 and 10 CFR 50 Appendix B, th?reby demonstrating that Licensee is not " technically
... qualified to" operate TMI Unit 1 "without endangering the health and safety cf the public." This course of conduct includes:
- a. deferring maintenance and repair beyond the point established by its own procedures (see e.g. A.P.1407);
- b. disregarding the importance cf maintenance in safely operating a nuclear plant in that it:
a 1.
uses supervisory and other personnel to perform maintenance; 2.
proposed a drastic cut in the maintenance budget; 3.
fails to follow its own maintenance procedures for the timely correction of maintenance problems; 4.
fails to keep accurate maintenance records; 5.
has inadequate and understaffed QA/QC programs; 6.
extensively uses overtime in performing maintenance.
Assurances given by Licensee's employees and officials as well as assurances given in the SER that all NRC regulations have been and/or will be adhered to are not credible. The same employees and efficials who were responsible for the violations numerated above remain in responsible pcsitiens with Licensee.
Reorgani::ation of the same people does not correct the problem.
8008070 h b
M Under these circumstances, Licensee cannot demonstrate by a prepon-derance of the evidence that it is " technically... qualified to" operate TMI Unit 1 "without endangering'the health and safety of the public."
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CERTIFICATE OF SERVICE I hereby certify that I caused a true and correct copy cf the foreg~oing document, TMIA's Correction Of Errors In Its Motion For Revision Of Contention 5, to be placed in the United States mail, first-class, postage prepaid, addressed to the persons listed below:
Ivan W. Smith, Chairman Atomic Safety & Licensing Board Panel U.S. Nuclear Regulatory Commission Washington, DC 20555 Dr. Walter H. Jordan 881 West Outer Drive Oak Ridge, TN 37830 Dr. Linda W. Little 5000 Hermitage Drive Raleigh, NC 27612 George F. Trowbridge, Esquire Shaw, Pittnan, Potts & Trowbridge 1800 M Street, N.W.
Washington, DC 20006 Docketing and Service Section U.S. Nuclear Regulatory Commission Washington, DC 20555 Executive Legal Direc:or U.S. Nuclear Regulatory Commission Washington, DC 20555
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O Mark P.' Widoff Dated: July 31,1980