ML20065A066
| ML20065A066 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 09/09/1982 |
| From: | Weiss E UNION OF CONCERNED SCIENTISTS |
| To: | NRC ATOMIC SAFETY & LICENSING APPEAL PANEL (ASLAP) |
| References | |
| NUDOCS 8209130122 | |
| Download: ML20065A066 (6) | |
Text
V t
. i o@
UNITED STATES'OP AMERICA j2 g 10 N0UO NULEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING APPEAL BOARD pv OC C
)
in the Matter of
)
)
METROPOLITAN EDISON COMPANY
)
Docket No. 50-289
)
(Restart)
(Three Mile Island Nuclear
)
Station, Unit No. 1)
)
)
UNION OF CONCERNED SCIENTISTS REPLY TO TMIA MOTION FOR EXTENSION OF TIME AND TO AAMODT MOTIONS OF SEPTEMBER 3, 1982 The Union of Concerned Scientists supports TMIA's and the Aamodts' requests for extensions of time to brief exceptions.
These parties have participated without uttorneys throughout these proc 5edings and have done a particularly remarkable job in building a record on issues concerning which both GPU and the Staff were negligent.
It should be remembered in this context that the cheating episodes as well as the many other instances of what the Licensing Board refers to in its latest PID as failures of " quality assurance" of the training and testing program are attributable to GPU and the Staff which are responsible for assuring the integrity of the training program.
TMIA and the Aamodts, whose participation ensured an airing of these issues, are entitled to the necessary amount of time to review the several months worth of hearing hohg9 ggd)
CK O PDR
f transcript, the three pertinent decisions (two by the Board and one by the Special Master) and to prepare their briefs.
If Appeal Board review is on the " critical path" to restart, as GPU asserts, (without support, so far as we are aware)
TMIA and the Aamodts should not be penalized for that.
As for UCS, our attention was until September 1, directed toward preparation for the oral argument on design and operational safety issues; we were unab'le to turn to the issues covered by the UCS exceptions until this time.
The UCS issues are not as broad as those raised by TMIA and the Aamodts.
We would therefore not for our own part have required the same amount of time as is needed by TMIA.
The Appeal Board has also asked for responses to the Aamodt Motion for the NRC Staff and Licensee to Show Good Cuase and/or Reopening of Record, September 3, 1982.
UCS believes that the motion and attached material raise very disturbing questions, particularly with respect to the 3 1/2 month period of time that passed between the discovery of these facts by GPU and their disclosure to the Appeal Board.
It is particularly troubling that this evidence was not transmitted to the Licensing Board during this time.since the Staff and GPU knek full well that the Board was then writing its decision
~
on the cheating questions.
Since a major question to be determined by the Appeal Board is whether the assurances of GPU and the Staff regarding their future conduct can be relied upon to ensure the integrity and adequacy of the
s i
s operator training and testing program, their failure to bring pertinent facts forward until after the ASLB decision and after the filing of immediate effectiveness comments is extremely significant.
UCS supports the Aamodt's motion.
Respe.ctfully submitted, D
Y. ] :
V Y
Ellyn.;R. Weiss General Counsel, UCS -
Dated:
September 9, 1982
_s N
f q
s
\\
I:
s I
l l
l I
i.
i m
m.
TIN J TI:11 :;T AT1::i t'l' AHl:l(l(* A N t'C1.E AR H D;til.ATol( Y Cofitt l i;;; t utt 00LKETED
}
'82 SEP 10 A10:30 J
In the M.itter of
)
I GFFICE OF SECRETAH
]
METROPOt.lTAN EDISON COMPANY
)
!)o c k s.-
()6 i
TCt.
(Three Mile Island Nucicar
)
Station, Unit No. 1) 1
]
CERTI FICATE OF tiKl(VICK p
I hereby certify that copies df'the foregoing UNION OF CONCERNED SCIENTISTS REPLY TO TMIA MOTION FOR EXTENSION OF TIME AND TO A7diODT MOTIONS OF SEPTEMBER 3, 1982, have been delivered this 9th day of September, 1982, first-class, postage paid, to the following:
Ivan'W. Smith, Chairman
- Judge John H. Buck Atomic Safety and Licensing Atomic Safety and Licensing Board Panel Appeal board Panel 3
t, S. Nuclear Regulatory U. S. Nuclear Regulatory Commission Commission Washington, D.C. 20555 Washington D.C. 20555 Dr. Wal ter H. Jc' dan Judge Christine N. Kohl Atomic Safety ar.d Licensing Atomic Safety and Licensing Board Panei AppealBoard Panel nial West Outer 1 rive ti.S. Niscl ear Reg ulatory Oak Ridge, Tenat.ssee 37830 Commission Washing ton, D.C. 20555 Dr. Linda W. Little Atomic Safety and Licensing Thomas Roberta, Commissione.
Board Panel 11.S. Nisclear Regulatory 5000 Hermitage Drive Commission i
Halc.igh, North Carolina 27612 Washing ton, D.C. 20555 Professor Gary L. M11hollin Nunzio.Palladino, Chairman 1815 Jefferson Street (1.S. Nuclcar llegulat.ory Madison, Wisconsin 53711 Comminaion Washington, D.C. 20555 Judge Gary J. Edles, Chairman Atomic Safety and Licensing Mrs. Marjoric Aamodt Appeal Board R.D. #5 U.S. Nuclear Regulatory Coatsville, Pennsylvania 19:
Commission W.ishington, D.C. 20555 s
2
~~
Robert Adler, Esq.
Mr. Marvin I. Tewis Assistant Attorney General 6504 Bradford Terrace 505 Executive House Philadelphia, PA 19149 P.O. Box 2357 Harrisburg, Pennsylvania 17120 Louis Bradford Ms. Gail B. Phelps Three Mile Island Alert 245 West Philadelphia Street 325 Peffer Street York, Pennsylvania 17404 Harrisburg, PA 17102 David E.
Cole, Esq.
Smith & Smith, P.C.
2931 North Front Street Harrisburg, PA 17110 Jordan D.
Cunningham, Fsq.
C'ounsel for NRC Staf f Fox, Farr & Cunningham Office of Executive Legal 2320 North Second Street Director Harrisburg, PA 17110 U.S. Nuclear Regulatory Commission Thomas J. Germaine, Esq.
Washington, D.C.
20555 Deputy Attorney General Division of Law - Room 316 George F. Trowbridge, Esq.
1100 Raymond Boulevard Shaw, Pittman, Potts 5 Newark, New Jersey 07102 Trowbridge 1000 M Street, N.W.
Dr. Judith H. Johnsr'ud Washington, D.C.
20036 Dr. Chauncey Kepford Environmental Coalition on Docketing and Service Section Nuclear Power Office of the Secretary 433 Orlando Avenue U.S. Nuclear Regulatory State College, PA 16801 commission
- Judge Reginald L. Gotchy Atomic Safety and Licensing Appeal Board Panel U.S. Nuclear Regulatory Commission Washington, D.C.
20555 Victor Gilinsky, Commissioner John A. Levin, Esq.
U.S. NRC i
Assistant Counsel Washington, D.C.
20555 Pennsylvania Public Utility Commission J.ames Asselstine, commiss, loner P.O. Box 3265 U. S. NRC Harrisburg, Pennsylvania 17120
~ Washington, D.C.
20555 John Ahearne, Commissioner U.S. NRC washington, D.C.
20555 e
9
a i
l e
4 Mr. Steve 11 rook!<
Mi eli.u l l'.
McIlr ielts, l'si g.
Publ}c information anil I.ello..n I, l.a mli, i.eilsy & Macitac Rerource Center 1131 New Itampnhi re livenue, N.W.
1037 Maclay Street
- In i i e 1100 liarrisbu rgi, l'A 17103 W.u:li i mit on, ll. C.
2 0 0 H.
Mr. Ilenry D.
IlukilI Vice President GPU Nuclear Corporation P.
O.' Dox 480 Middletown, PA 17057 x
L A
/i / '
September 9, 1980
<We'iss Ellyn R.L.J
- !iand-delivered l
f I
I l
I i
L r