ML20005C069
| ML20005C069 | |
| Person / Time | |
|---|---|
| Site: | Susquehanna  |
| Issue date: | 10/29/1981 |
| From: | Perkins J AFFILIATION NOT ASSIGNED |
| To: | NRC COMMISSION (OCM) |
| References | |
| NUDOCS 8111180351 | |
| Download: ML20005C069 (3) | |
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October 29, 1981 m
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OFFICE OF SECRETU Commissioners DOCKETlHG & SERVE U. S. Nuclear Regulatory Commission BRANCM Washington, D. C.
20555 Commissioners:
I am writing to you in a mood of consternation arter attending the final day of hearings, a day set aside for limited appearance statements, regarding the application for an operating license for the nuclear plant Susquehanta.
The source or my mood is my realization following the hearings that the ASLB is not exercising its proper role in assuring the compilation of a full record.
As a case in point please consider the following chronology:
May 22, 1981 - I sent comuents to the OIrice or Nuclear Reactor Regule? en on the draft Supplement 2 to the DES for Susquehanna.
I questioned several specifics in the draft, but particularly cuc11enged the Staff's " Estimated Economic Riska calculation on several grounds.
Or these 1%e u st significant was the use of an unacceptab.ly low probability factor for a one billion dollar accident at Susquehanna.
- c. July 15, 1981 - I received a copy of the section of the 7ES in which the StarI addressed my comments.
The Staff identified three alleged errors in my comments: an improper probability factor, an improper application of fixed charges, and double counting of certain costs.
The author of the rebuttal justified the Staff's position by oIrering a trivial and irrelevant comparison with the casting or cice, by mi? characterizing tcstimony given bercre the Subcommittee on Oversight and Inves-tigations or the House Committee on Energy and Commerce by Susan shanaman, nean of the Pennsylvania Public Utility Commission, and by asserting that I could not differentiate between lost fuel savings and lost revenues due to decreased sales to the PJM grid, respectively.
July 19, 15101 - Not knowing te whom I should communicate my concern regarding the Staff's unwillingness to mocity its position on this issue and sensing tnat tne release of the ?ES represented a significant piece or evidence in the record of the proceeding, I wrote to the Board Chairman, whose name I did not then know.
In my letter I summarized the errors tne staff had made in addressing my comments ana urged the Chairmar 0
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Pago 2 to contact the 8ttII acout the matter.
I half-expected to receive some acknowedgment of my letter.
At the least I expected my letter of concern to be added to the docket.
To the best oI my rnowledge, the Chairman never triec to contact me nor was my letter distributen to tne parties.
September 25, 1981 - I sent s. seconc Letter to Mr. Gleason, who, I hac learnec, was serving as Chairman.
I saic I nac sent hin a letter but had receivec to assurance it had arrived.
I mistarenly used the word, record, out or ignorance, rather than docket, but I Ieel I was clearly indicating my concern that my comments on the erroneous rrs were of interest to all tne parties.
In particular I asked Mr. Gleason Ior a response so I would know the cisposition of my letter.
October 23, 1981 - Having received no acrnowledgment of either letter, I attended the hearings held in Berwicz, Pa., on the day set aside Ior 12mited appearance statements.
In my turn I asked why my letter nan not been added to the recora, again using the wrong worc, but with a clear intent.
Ultimately Mr.
01eason pointed out tnat tne only way I could have anytning added to the record was to rean it that day.
Not having a copy or my letter I asked him to acc it to the record, a request ne seld ne would fulfill.
After 1 returnec to my seat it struck me tnat II 1 nac not been able to attent tne 12mitec appearance hearings my concerns r<ould never have surIacen in tue record or even in tne cocret of this proceeding, cespite tne fact that the Boara
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Onalrman had had the matter pointecly brought to nis attention twice prior to tue commencement of the neurings.
It seems to
___me tnat since the FES is part ol Ine recoru any geon faita e:1';rt to point out deficieneses in as 12meAy a manner as possicAe ehculd Seserve evennancec treatment.
At tne very leest nil parties should De not1Alea tnat some coubtu rre concerns have been expressed.
I believe it is the duty of the Board to ensure that the record and, by implication, its components are complete and correct to the best of its ability.
Is that not the case?
In this relativ317 s=all instance and in more substantive issues in this case, including the prohibition from cross examination of the most experienced Intervenor in the aftermath of some sharp, if not unethical, practices by the lead attorney for the Applicants, I urge you to use your oversight powers to prevent the ASLB from deciding this case.
There are several issues of controversy regarding the manner in which this case has been handled by th3 criginal and the reconstituted ASLB which demand a review by the NRC before the granting of any license.
O Page 3 Thank you very much for your consideration of this letter and my concern.
As evidenced by headlines in local papers referring to the hearings as a steamroller process, public perception of the NRC's role lacks any confidence.
I urge you to begin to rebuild that confidence by thoroughly investigating the actions of this Applicant and thir ASLB before authorizing start-up of the plant.
Sincerely,
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Jim Perkins copies:
Commissioners Palladine, Bradford, Gilinsky, Ahearne and Roberts Senators Heinz and Specter Representatives Ertel and Nelligan Samuel Chilk, Secretary of the NRC
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