ML20079Q249
| ML20079Q249 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 01/30/1984 |
| From: | Weiss E HARMON & WEISS, UNION OF CONCERNED SCIENTISTS |
| To: | Buck J, Edles G, Kohl C NRC ATOMIC SAFETY & LICENSING APPEAL PANEL (ASLAP) |
| References | |
| NUDOCS 8402010064 | |
| Download: ML20079Q249 (2) | |
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()CCH.ii!HG & SUViv DE AN R. TOV $ LEY Janaury 30, lbNCF' Gary J.
Edles, Chairman John H. Buck N Christine M. Kohl Administrative Law Judges Atomic Safety and-Licensing Appeal Board United States Nuclear Regulatory Commission Washington, D.C.
20555 RE:
Metropolitan Edison co.
Docket No. 50-289 SP (Restart),
Three Mile Island, Unit 1
Dear Member of the Board,
By letter dated January 19, 1984, Counsel for GPU sent the Appeal Board and parties a Licensee Report entitled." Lessons Learned Work shop."
This was supposedly sent for your "information".
It is a far from subtle attempt to influence the Appeal Board's decision by freighting it with self-serving, of f-the-record submissions intended to convince the Board that the ineptly designed and administered training and testing.
program documented on the record has been transformed.
This is consistent with my observation throughout the oral argument that GPU and the Staff attempted to deflect discussion of the evidence on the record by referring constantly to alleged changes and improvements since that time.
In general, they failed even to indicate when their arguments departed from the record and entered the realm of extra re. cord assertions.
If this proceeding has demonstrated anything, it is the
. untrustworthiness of assertions which are untested by the probing which can only take place in hearings.
You will certainly recall the Licensing Board's chagrin when it
' discovered that the expert panel's high opinion of the TMI-l training program, which it had-accepted, was great'y at odds with the reality that later emerged.
Its remarks about the 8402010064 840130 PDR ADOCK 05000209 0
}l A R M ON. W!il S S & sIOli1>A N
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Administrative Law Judges Page Two' belated lif ting -of the " paper curtain" are telling and particularly apt to this situation.
We object to the = Appeal _ Board's consideration of this i
latest document and those similar that have preceded it.
They have no ~ status in this case, no evidentiary value and most certainly no inherent reliability.
They are an attempt to improperly influence the decisions. of this Board, which is bound to make its rulings on the basis of a record fairly and openly compiled.
Ver truly yours, lih>f El yn R. Weiss General Counsel Union of Concerned Scientist ERW:cpk.
cc:
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