ML20004B447

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Forwards Ucs & Sc Sholly 810518 Joint Proposed Reply Procedural Findings.Adopts Some NRC & Licensee Proposed Findings,Revises Others & Adds Findings to Completely Explain Facts & Actions
ML20004B447
Person / Time
Site: Three Mile Island Constellation icon.png
Issue date: 05/18/1981
From: Sholly S, Weiss E
AFFILIATION NOT ASSIGNED, HARMON & WEISS, UNION OF CONCERNED SCIENTISTS
To: Jordan W, Little L, Smith I
Atomic Safety and Licensing Board Panel
Shared Package
ML20004B448 List:
References
NUDOCS 8105280251
Download: ML20004B447 (1)


Text

' DOCKET 1:U!.1BER PROD. & UTIL FAC.s ..s... .z. . , . . . .,

Mr. Ivan W. Smith, Esquire 18 May 1981 Administrative Judge Chairman, Atomic Safety and Licensing Bcard Panel U.S. Nuclear Regulatory Commission ,

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20555 Dr. Walter H. Jordan y s' Administrative Judge Atomic Safety and Licensing 9 Board Panel CCCKETm .

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CfEe::f S.e !:entary Dr. Linda W. Little g Mds;& anics J Administrative Judge Bud Atomic Safety and Licensing ci :7 Board Panel ~O 5000 Hermitage Drive Raleigh, NC 27612

Dear Board Members:

Enclosed please find copies of the Union of Concerned Scientists and Steven C. Sholly Joint Proposed Reply Procedural Findings, dated 18 May 1981. Where the proposed findings by the Staff and Licensee were adopted unchanged, such findings are reproduced herein for the sake of continuity. Many of the proposed findings of the Staff and Licensee were revised.

Additional findings were added to more completely explain facts and actions which were not highlighted or were ignored in the proposed findings filed by the Staff and Licensee.

In general, we found that some of the proposed findings of the Staff and Licensee, while characterized as " Procedural Findings" were in reality, when taken as a whole, a subtle alteration of the nature of the sequence of events which led to this proceeding, and subsequent events involving the rulings of the Board on specific contentions and motions. We therefore proposed these reply findings in order to set the record straight.

//

j/s', ,r [  ; Respectfully,

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Ellyn' R. Weiss, Esquire cowa Counsel for UCS g 4041 -

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Steven C. Sholly Intervenor pro se 810528088k G d /