ML19331D412
| ML19331D412 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 08/26/1980 |
| From: | Widoff M THREE MILE ISLAND ALERT, WIDOFF, REAGER, SELKOWITZ & ADLER |
| To: | Atomic Safety and Licensing Board Panel |
| References | |
| ISSUANCES-SP, NUDOCS 8009020407 | |
| Download: ML19331D412 (3) | |
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UNITED STATES OF AMERICA USNRC 1
NUCLEAR REGULATORY COMMISSION
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@ gg BEFORE THE ATOMIC SAFETY AND LICENSING BOARD M escf h Seattay Doctonig 1 Semce bud V
In the Matter of
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METROPOLITAN EDISON COMPANY
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Docket No. 50-289
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(Restart)
(Three Mile Island Nuclear
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Station, Unit No. 1)
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REVISION OF TMIA CONTENTION 5 Putauant to the board order of August 20, 1980, TMIA is hereby revising Contention 5 to conform to this order.
It is contended that Licensee has pursued a course of con-duct 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, thereby demonstra-ting that Licensee is not " technically... qualified to" operate TMI Unit 1 "without endangering the health and safety of the public. "
This course of conduct includes:
a.
deferring safety-related maintenance and repair beyond the point established by its own procedures (see e.g. A.P.
1407);
b.
disregarding the importance of maintenance in safely op-erating a nuclear plant in that it:
1.
uses supervisory and other personnel to perform main-tenance; 2.
proposed a drastic cut in the maintenance budget; 3.
fails to keep accurate maintenance records; I
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has inadequate and understaffed QA/QC programs as re-lated to maintenance; 5.
extensively uses overtime in performing maintenance.
Assurances given by Licensee's employees and officials as well as assurances given in the SER that all NRO regulations have been and/
or will be adhered to are not credible ~.
The same emplo aes and
. officials who were responsible for the violations numerated above remain in responsible positions with Licensee.
Reorganization of the same people does not correct the problem.
Under these circumstances, Licensee cannot demonstrate by a preponderance of the evidence that it is "te'chnically... qualified to" operate TMI Unit 1 "without endangering the health and safety of the public."
Res ctfully submitted,
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ark P. 'Widoff, Esquirs Dated:
August 26, 1980 4
r CERTIFICATE OF SERVICE I hereby certify that I caused a true and correct copy of the foregoing document, Revision of TMIA 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
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Dr. Walter H. Jordan S
881 West Outer Drive
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Oak Ridge, TN 37830
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Dr. Linda W.
Little 5000 Hermitage Drive
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Raleigh, NC 27612 Gbh'
,,f George F. Trowbridge, Esquire
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Shaw, Pittman, Potts & Trowbridge 1800 M Street, N.W.
Washington, DC 20006 Docketing and Service Section U.S. Nuclear Regulatory Commissicn Washington, DC 20555 Executive Legal Director U.S. Nuclear Regulatory Commission Washington, DC 20555
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'bb/f iMark P. Widoff
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1 Dated:
August 26, 1980 I
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