ML20009B732

Forwards Ucs Proposed Findings of Fact on Contention 12 & Reply Findings on Contentions 1,2,3 & 5.Certificate of Svc Encl

ML20009B732
Person / Time
Site:	Three Mile Island
Issue date:	07/13/1981
From:	Weiss E HARMON & WEISS, UNION OF CONCERNED SCIENTISTS
To:	Jordan W, Little L, Smith I Atomic Safety and Licensing Board Panel
Shared Package
ML20009B733	List: ML20009B732 ML20009B734 ML20009B736
References
NUDOCS 8107170104
Download: ML20009B732 (4)

Text

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b SutTE 506 h h oAiL u.sAnwoN WAS HINGTON, D. C. aooo6 y ,, .33 8070 ELLYN R. WEtSS M,

'- WILLIAM S. JORD A N, Ill /[ OF COUNSEL

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l July 13, 1981 Ivan W. Smith, Esquire /s

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Chairman p / g

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U.S. Nuclear Regulatory Commission [N d.

Washington, D.C. 20555 [C/ , N , $.; % 3 pq 4 , 4 ;. g u Dr. Walter H. Jordan M S g O 7,

Atomic Safety and Licensing Board Panel  %\ '{ph,h" t 1/9.(

881 West Outer Drive \O d' Oak Ridge, Tennessee 37830  %

Dr. Linda W. Little l Atomic Safety and Licensing Board Panel i 5000 Hermitage Drive Raleigh, North Carolina 27612 Re: TMI-l Restart, Docket No. 50-289

Dear Members of the Board:

Enclosed are UCS's Proposed Findings of Fact on UCS Conten-tion 12 and reply findings on UCS 1, 2, 3, and 5.

l As you will recall, UCS proferred Exhibit-39, which consists

of selected pages from the Licensee's worksheets on the qualification l of particular components. A ruling on its admissibility was deferred j pending discussio1. among the parties to identify which of'the sheets are already in Staff Exhibit 16 and the purpose which UCS intends to make of the remainder of the sheets.

The following pages of UCS 39 are duplicated in Staff Exhibit

( 16: 4, 27-37, 40, 41, 46-50, 54-B, 80 and 82-84. Thus, there is no need to include these separately in the UCS Exhibit.

3 Pages 13 and 39 were used during cross-examination by UCS

l. and no party objects to their admission.

In addition, the following pages contain information identified by the Licensee in its master list for cold shutdown and indicate deficiencies in qualification: 8-12, 26, 42-45 and 74-79. My under-standing is that no party objects to the admission of these at least i for the purpose of arguing for a remedy.

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8107170104 810713 / [

PDR ADOCK 05000289 G PDR L_

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July 13, 1981 Page 2 i yo 2 4

! Pages 1, 2 and 3 of UCS Exhibit 39 pertain to equipment located inside containment and thus exposed to the SBLOCA environ-

ment. The purpose of this equipment is to isolate feedwater in the event of a steam line rupture. However, if they fail during a SBLOCA, they could isolate feedwater inappropriately and thus hamper mitigation of the SBLOCA. The Licensee reserves its right to argue in its reply findings that'these pages are inadmissible. We

have cited page 1 at paragraph 683 of our enclosed findings and, '

we believe, made the case for its relevance therein. Pages 2 and 3 are explanations of Page 1. In essence, the parties-request the Board to rule on admissibility on the basis of the findings and reply j findings of the parties, in order to obviate the need for additional pleadings.

4 The same arrangement has been made with respect to pages 5, 6, 7, 22, 24, 25, 38, 51, 52 and 81. These pages pertain to equip-ment needed to mitigate a SBLOCA which are not exposed to a harsh environment, but must be qualified to ambient conditions. The pages indicate that it has not been demonstrated that the components are qualified to ambient conditions, including aging. We have discussed these at paragraph 702 and, we believe,. shown their relevance. The Licensee and Staff reserve their rights to object to their admis-sibility.

! The remainder of the pages of Exhibit 39 have not been cited j and may therefore be withdrawn.

Very truly yours, C" . h

. Ellyn R. Weiss i

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f 'y" UNITED STATES OF AMERICA A Wg NUCLEAR REGULATORY COMMISSION .<

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' .. , Q BEFORE THE ATOMIC SAFETY AND LICENSING BOARD %. 4 7 L/

In the Matter of )

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METROPOLITAN EDISON COMPANY ) Docket No. 50-289

) (Restart)

(Three Mile Island Nuclear )

Station, Unit No. 1) )

I hereby certify that copies of " Union of Concerned Scientists Proposed Findings of Fact and Rulings of Law on UCS Contention 12" and " Union of Concerned S::ientists Reply Findings on UCS Contentions 1,2,3, and 5" have been mailed postage pre-paid

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this 13th day of July, 1981, to the parties listed below.

SERVICE LIST Ivan W. Smith, Esquire John A. Levin, Esquire .

Chairman Assistant Counsel Atomic Safety and Licensing Pennsylvania Public Utility Commission Board Panel Post Office Box 3265 U. S. Nuclear Regulatory Harrisburg, Pennsylvania 17120 Commission Washington, D. C. 20555 Dr. Walter H. Jordan Robert Adler, Esquire Atomic Safety and Licensing Assistant Attorney General Board Panel 505 Executive House 881 West Outer Drive Post Office Box 2357  ;

Oak Ridge, Tennessee 37830 Harrisburg, Pennsylvania 17120 Dr. Linda W. ' Little Walter W. Cohen, Esquire Atomic Safety and Licensing Consumer Advocate Board Panel Office of Consumer Advocate 5000 Hermitage Drive 14th floor,. Strawberry Square Raleigh, North Carolina 27612 Harrisburg, Pennsylvania 17127

James R. Tourtellotte, Esq. Docketing and Service Section Office of the Executive Office of the Secretary

, Legal Director U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Washington, D. C. 20555 Commission Washington, D. C- 20555 i

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Jordan D. Cunningham, Esquire William S. Jordan, III, Esquire Fox, Farr & Cunningham Harmon & Weiss, 2320 North Second Street 1725 Eye Street, N.W., Suite 506 Harrisburg, Pennsylvania 17110 Washington, D. C. 20006 Mrs. Louise Bradford Chauncey Kepford/ Judith Johnsrud TMI ALERT Environmental Coalition on Nuclear 315 Peffer Street Power Harrisburg, Pennsylvania 17102 433 Orlando Avenue State College, Pennsylvania 16801 Steven C. Sholley Union of Concerned Scientists Marvin I. Lewis 1725 I Street, N.W., Suite 601 6504 Bradford Terrace Washington, D. C. 20006 Philadephia, Pennsylvania 16801 i

Gail Bradford Attorney General of New Jersey ANGRY Attention: Thomas J. Germine, Esq.

245 West Philadelphia St. Deputy Attorney General York, Pennsylvania 17404 Division of Law - Room 316 1100 Raymond Boulevard Marjorie M. Aamodt Newark, N. J. 07102 R.D. 5 Coatesville, Pennsylvania 19320 George F. Trowbridge, Esq.

Shaw, Pittman, Potts & Trow-bridge 1800 M Street, N.W. -

Washington, D. C. 20036 l

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l Ellyn R. Weiss l

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