ML20063A685
| ML20063A685 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 08/20/1982 |
| From: | Weiss E HARMON & WEISS, UNION OF CONCERNED SCIENTISTS |
| To: | |
| Shared Package | |
| ML20063A688 | List: |
| References | |
| NUDOCS 8208240454 | |
| Download: ML20063A685 (3) | |
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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE NUCLEAR REGULATORY COMMISSION In the Matter of
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METROPOLITAN EDISON COMPANY
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Docket No. 50-289 (Restart)
(Three Mile Island Nuclear
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Station, Unit No. 1)
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UNION OF CONCERNED SCIENTISTS' COMMENTS ON IMMEDIATE EFFECTIVENESS The Commission has asked for comments on whether it should make the Board's Partial Initial Decisions authorizing restart of TMI-2 immediately effective.
UCS believes such action would be ill-advised and urges the Commission not to do so.
Perhaps the most important consideration is that there is now no reason for the Commission to act before the Appeal Board reviews the Licensing Board's decisions.
TMI-2 is in no condition to start operation.
Therefore, there is no reason not to allow the Appeal Board, which is well into its l
review of the full record of the hearing, to resolve the many important substantive issues involved.
If restart is authorized before those disputes are resolved, many of the issues concerning whether the plant can safely be restarted may effectively be mooted.
As to the latest PID on the cheating at TMI, the Commission should be aware that it represents a near wholesale and unjustified reversal of the most important findings of the D
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'trie'r of fact the Special Master, Professor Milhollin.
Professor Milhollin found, inter alia, that the integrity of the entire TMI operations staff has been deeply compromised.
We believe that he was plainly correct.
He also found that 4
the training and testing program, even in the aftermath of TMI-2 and at the very facility which one would have expected to be most concerned about retraining, tests primarily the i
operators' ability to memorize and has very little to do with testing the operators' ability to cope with an accident.
Special Master's Report, 11 247-249, 251, 287.
In this he was also correct.
Contrary to the equivocations of the Licensing Board, this has a direct relationship to safety and calls profoundly into question the conclusion that TMI-l can safely restart.
In addition, UCS, in its Comments on the Special Master's Report which are attached, specifically delineated the many points at which the Board's PID of December 14, 1981, on design and operational safety issues is explicitly or implicitly dependent on the outcome of the issues reserved for the reopened proceeding. The Board did not deal with these questions seriously; it dismissed them summarily at 11 2408-2410 of the July 27, 1982 PID.
The fact is that, as UCS demonstrated in its May 18, 1982, filing, the Board's resolution of the design and operational safety issues is heavily dependent at critical points on
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the premise that the TMI-1 operators, after their " intensive" post-TMI training, can be fully relied upon to diagnose plant failures and to take the correct action.
The operators are in critical cases relied upon to do so as a substitute for adequate safety equipment.
The Special Master's findings fatally undermined the Board's conclusion in these respects.
We urge the Commission not to make the Licensing Board's decisions immediately effective.
Respectfully submitted, N
l Ellyn R. Weiss Date:
August 20, 1982 HARMON & WEISS 1725 I Street, N.W.
Suite 506 Washington, D.C.
20006 (202) 833-9070 Counsel for Union of Concerned Scientists
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