ML20073S882

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Motion for Summary Disposition of B&W/Gpu Trial Record.No Genuine Issue of Matl Fact Exists & TMI Alert Entitled to Favorable Decision.Svc List Encl
ML20073S882
Person / Time
Site: Crane Constellation icon.png
Issue date: 05/03/1983
From: Bradford L
THREE MILE ISLAND ALERT
To:
NRC ATOMIC SAFETY & LICENSING APPEAL PANEL (ASLAP)
References
NUDOCS 8305100212
Download: ML20073S882 (5)


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UNITED STATES OF AMERICA

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NUCLEAR REGULATORY C0bD11SSION 4.

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In the Matter of

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Docket No. 50-289 F-

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(Three Mile Island Nuclear

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TMIA'S MOTION FOR PRODUCTION OF DOCUMENTS 1.

On April 18, 1983 TMIA filed its comments on the Babcock and Wilcox - GPU trial transcripts.

2.

It was not udtil April 22, 1983, that the complete transcripts and exhibits were available to TMIA after being placed at the State Library in Harrisburg.

3.

The transcripts and exhibits are so voluminous that a review thereof has been impossible, especially since 67 feet of unentered exhibits were not available until April 26, 1983.

4.

The NRC staff acknowledged in its March 28, 1983 memorandum to the Commissioners that it "did not examine these supplemental documents".

5.

TMIA believes and therefore alleges that these documents con-tain significant factual information that is critical to the primary l

obj e ctive, i.e., whether there is information from the trial that affects the TMI-l restart.

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6.

TMIA is unable to comment fully on the trial because there was not been enough time to review all documents prior to April 18, 1983 and especially because its access to the documents is/nowseverely limited.

7.

The severe limitations are the result of the State Library policy not to allow the removal of any documents from its premises.

Additionally, the hours of operation of the Library being only 9 o' clock a.m. to 5 o' clock p.m. on weekdays restricts TMIA membership from full access.

8.

The State Library has indicated it will permit the temporary removal of documents on an overnight basis if so ordered by this Commission.

9.

TMIA tvould request this Commission to allow the removal of documents by TMIA from 3:30 p.m.

to 9:00 a.m.

the following working day.

10.

TMIA's request will allow it to make a thorough review of the trial documents, which the NRC staff refused to do, with minimal adverse impact to the public, and will also promote the analysis and review previously ordered by the Commission.

11.

Alternatively, TMIA requests that it be provided with a complete copy of the transcripts and documents including the total number of exhibits developed during the trial and including those not admitted inte evidence.

12.

No prejudice to any of the parties will result from the granting of this motion.

Wherefore, TMIA respectfully requests the NRC to enter an Order extending its time to comment on the Babcock and Wilcox - GPU trial record and to either Order the State Library to permit the removal of documents on an overnight basis or provide TMIA with a complete copy to permit a reasonable review of these proceedings.

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Respectfully submitted, May 3, 1983 Louise Bradforc

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Joanne Doroshow TMIA i

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UNITED STATES OF AMERICA m

1 NUCLEAR REGULATORY COMMISSION

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a BEFORE THE ATOMIC SAFETY AND LICENSING APPEAL BOARD

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In the Matter of

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METROPOLITAN EDIS0N COMPANY, ET AL.)

Docket No. 50-289

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(Restart)

(Three Mile Island Nuclear Station,)

Unit No.1)

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SERVICE LIST

  • Gary J. Edles, Chairman Dr. Linda W. Little Atomic Safety & Licensing Appeal Administrative Judge Board 5000 Hermitage Drive U.S. Nuclear Regulatory Commission Raleigh, North Carolina 27612 Washington, DC 20555 George F. Trowbridge, Esq.
  • Christine N. Kohl Shaw, Pittman, Potts & Trowbridge Atomic Safety & Licensing Appeal 1800 M Street, NW Board Washington, DC 20036 U.S. Nuclear Regulatory Comission Washington, DC 20555 Robert Adler, E'sq.

505 Executive House

  • Dr. John H. Buck P. O. Box 2357 Atomic Safety & Licensing Appeal Harrisburg, PA 17120 Board U.S. Nuclear Regulatory Comission Gary L. Milhollin, Esq.

Washington, DC 20555 4412 Greenwich Parkway, NW Washington, DC 20007

  • Ivan W. Smith Administrative Judge Ms. Marjorie Aamodt Atomic Safety & Licensing Board R.D. f5 U.S. Nuclear Regulatory Comission Coatesville, PA 19320 Washington, DC 20555 Ms. Ellyn R. Weiss Dr. Walter H. Jordan Hr.nnon & Weiss Administrative Judge 1725 I Street, NW 881 W. Outer Drive Suite 506 Oak Ridge, Tennessee 37830 Washington, DC 20006 epp e o g ems w

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' Docketing & Service Section Office of the Secretary U.S. Nuclear Regulatory Commission Washington, DC 20555

  • Dr. Lawrence R. Quarles Atomic Safety & Licensing Appeal Board U.S. Nuclear Regulatory Commission Washington, DC 20555
  • Judge Reginald L. Gotchy Atomic Safety & Licensing Appeal Board U.S. Nuclear Regulatory Commission Washington, DC 20555
  • Atomic Safety & Licensing Appeal Board Panel U.S. Nuclear Regulatory Commission Washington, DC 20555
  • Atomic Safety & Licensing Board Panel U.S. Nuclear Regulatory Commission Washington, DC 20555 f

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