ML20033F607
| ML20033F607 | |
| Person / Time | |
|---|---|
| Site: | Seabrook  |
| Issue date: | 03/14/1990 |
| From: | Curran D HARMON, CURRAN, SPIELBERG & EISENBERG, LLP., MASSACHUSETTS, COMMONWEALTH OF, NEW ENGLAND COALITION ON NUCLEAR POLLUTION, SEACOAST ANTI-POLLUTION LEAGUE |
| To: | Carr K, Curtiss J, Roberts T, Rogers K NRC COMMISSION (OCM) |
| Shared Package | |
| ML20033F608 | List: |
| References | |
| CON-#190-10076 OL, NUDOCS 9003220184 | |
| Download: ML20033F607 (2) | |
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uNDRA K. PIAU March 14, 1990 Ak GAUAGHER KATHERINE A. METER' ERIC R GUTZENSTILN
- Also admitted in Maryland Kenneth M.
Carr, chairman Thomas M. Roberts Kenneth C. Rogers
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a James R.
Curtiss U.S. Nuclear Regulatory Commission Washington, D.C.
20555
SUBJECT:
Emercency Petition for Extension of Stav Dear Commissioners on behalf of Intervenors New England Coalition on Nuclear Pollution, Seacoast Anti-Pollution League, and Commonwealth of
- Massachusetts, I am enclosing an emergency petition for an exten-sion of the stay of full power operation of the Seabrook reactor.
The motion is supported by the affidavit of Robert D. Pollard, a L
nuclear safety engineer with the Union of concerned Scientists, and his testimony to be delivered today before the Subcommittee on General Oversight and Invegtigations of the House Committee on Interior and Insular Affairs.
The Intervenors' notion is based on recent, proviously L
undisclosed industry reports of extensive and serious regulatory i
noncompliance at Seabrook.
The reports, some of which were prepared by the Institute for Nuclear Power Operations ("INPO"),
J-and 'others prepared -jointly by INPO and Public Service gD. py of mgaPol-l
'New Hampshire ("PSNHd), were provided anogymously to Mr.$dge, lard on the afternoon of Monday March 12.
To our knowl I
l 1
l Due to time constraints, Mr. Pollard was unable to obtain notarization for his signature of the affidavit.
A notarized copy of the affidavit will be hand delivered to the Commission as early tomorrow as possible.
2 The source of the documents has refused to allow the INPO reports to be copied.
Therefore, the contents of the docu-ments are summarized in the attached pleading, and the testimony and affidavit of Mr. Pollard.
Pursuant to the Memorandum of Agreement between NRC and INPO, such reports are available to NRC upon request.
l 9003220184 900314 1-PDR ADOCK 05000443 AC O
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5-o HARMON, CURRAN & TOUSLEY NRC Commissioners March 14, 1990 Page 2 they have not previously been provided to the NRC or to any party to the Seabrook case other than PSNH.
The Commission has repeatedly stressed that it places reliance on INPo's safety assessments and conclusions.
The INPO reports raise such grave new issues of regulatory noncompliance as to completely undermine the NRC's previous conclusion that the Seabrook reactor is ready for safe operation at full power.
In light of these revelations, Intervenors respectfully move that the Commission extend its stay of full power operation until it has had the opportunity to fully investigate the issues raised by the report and obtain assurance that the Applicants are in com-pliance with NRC regulations and safety requirements; and until the Intervenors have had an opportunity to address these issues on the record.
Because the stay is due to expire this evening, we request your expedited consideration of this motion.
Copiec have been hand-delivered or telefaxed to the Applicants and the NRC Staff.
Sincerely, Diane curran Encl.
cc w/ encl.:
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