ML20082R482
| ML20082R482 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 12/09/1983 |
| From: | Weiss E UNION OF CONCERNED SCIENTISTS |
| To: | NRC COMMISSION (OCM) |
| Shared Package | |
| ML20082R474 | List: |
| References | |
| NUDOCS 8312130188 | |
| Download: ML20082R482 (5) | |
Text
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DOCKETED USNnC
'83 DEC 12 Pl2:1b 12/9/83 UNITED STATES OF AysfjtICA0F SECRETAP NUCLEAR REGULATORY CCMtISSION& SERVICT BRANCH BEFORE THE COMMISSION In the Matter of
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METROPOLITAN EDISON COMPANY
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Docket No. 50-289
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(Restart)
('Ihree Mile Island Nuclear
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Station, Unit No.1)
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REQUEST EOR OPPORTUNITY 'IO RESPOND 'IO STAFF PROPOSAL FOR RESTART OF TMI-l On December 5, 1983, the Comnission held a session to allow response by Intervenors ard the NEC Staff to the GIU June 10, 1983, proposal for restart of
'IMI-l and subsequent GPU modifications of that proposal. At that meeting, after the Intervenors' opportunity to speak, the Staff presented a totally new l
proposal to restart the reactor at 25% power initially, to ascend to full power after OI concludes its ongoing investigations of leak rate falsification and other matters bearing on GPU's competence and integrity.
This Staff proposal was made for the first time in the Staff's oral presentation.
It was not even made available in writing on the day of the meeting in the form of a SECY paper, as is ncmally the case.
Therefore, Intervenors were completely prevented from considering the proposal or voicing their views to the Comnission.
GPU, which was provided an opportunity to speak after the Staff (and was presunably aware in advance of the substance of the Staff proposal), did connent on the proposal.
The Intervenors are entitled to an equal opportunity to address the Comnission orally.
8312130188 831209 PDR ADOCK 05000289 G
-2 he Staff's proposal would place essentially no restrictions on the operation of m I-l beyond those that are necessary in any case for start-tp of a reactor that has been out of operation for almost five years. We testing would simply be at a maximm of 25% power rather than 40% as GPU would prefer.
The Staff conceded that the 24-hour inspector presence is a public relations necessity - a man on the scene to answer public queries. The Staff prcposal in no way responds to the questions of GPU management integrity and competence.
It simply assmes that there are-none.
In addition, the Staff proposal completely overlooks the fact that the public is entitled to a role in the process of consideration of the evidence bearing on GPU's integrity.
This insensitivity is perhaps the most remarkable aspect of the proposal.
It is proposed that the Staff -- which failed for over three years to notify the Licensing and Appeal Boards of the nature of the evidence of leak rate falsification and continued to endorse GPU managment in the adjudication throughout that time -- will " resolve" these issues by authorizing full power operation without the public ever having had the opportunity to present any evidence or question any witnesses.
Two questions the Staff did not explicitly address are: 1) If the OI investigation concludes that widespread leak rate falsification took place, is mI-l to then shut down? and 2) Do the reopened hearings take place after the plant goes to full power and if the Board concludes that GPU lacks the requisite cmpetence and integrity, does mI-l then shut down?, The proposal makes no provision at all for the occurrence of these contingencies, neither of which is unlikely, which makes it clear that it is not an interim restart proposal, but an ultimate restart proposal.
If we " face facts," as counseled by Admiral Rickover, the Staff's proposal is in all significant respects the same as GPU's.
It allows GPU to restart the
, reactor first and later determines whether the company has the competence and integrity to do so.
Moreover, once operation has restaned, we can be sure that the formalities involved in resolving the competence and integrity questions will become an empty gesture.
These and other questions concerning the Staff proposal should be addressed in an open meeting where the public has the opportunity to be heard.
Conclusion For the above-stated reasons, UCS urges the Comnission to schedule a meeting for the purpose of allowire responses to the Staff's proposal of Decernber 5,1983.
Respectfully subnitted, L
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Ellyn(f. Weiss N
General Counsel Union of Concerned Scientists Dated: December 9, 1983 s
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3 00!.KETED UshRC UCS 12/9/83
'83 DEC 12 Pl2:14 UNITED STATES OF AMERICA NUCLEAR REGULATORY CDPfilSSION OFFICE OF SELRETAii' 00CKETING & SERV!CI BRANCH In the Matter of
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METROPOLITAN EDISON CDMPANY
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Docket No. 50-289
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(Restart)
(Three Mile Island Nuclear
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Station, Unit No.1)
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CERTIFICATE OF SERVICE I hereby certify that copies of " UNION OF CONCERNED SCIEtfrISTS RESPONSE 10 GPU LE' ITER OF DECEMBER 6,1983 REGARDING EMERGENCY FEEDWATER FLOW INSTRUMENTATION" and " REQUEST FOR OPPORTUNITY 70 RESPObD TO STAET PROPOSAL FOR RESTART OF 1NI-1" have been served on the following persons by deposit in the United States mail, first class postage prepaid, this 9th day of December 1983, except as noted by an. asterisk.
Nunzio Palladino, Chairman Gary J. Edles, Chairman U.S Nuclear Regulatory Conmission Atomic Safety and Licensing Appeal Board Washington, D.C. 20555 U.S. Nuclear Regulatory Conmission Washington, D.C. 20555 Victor Gilinsky, Conmissioner U.S. Nuclear Regulatory Conmission Dr. John H. Buck Washington, D.C. 20555 Atomic Safety and Licensing Appeal Board U.S. Nuclear Regulatory Conmission James Asselstine, Conmissioner Washington D.C. 20555 U.S. Nuclear Regulatory Conmission Washington, D.C. 20555 Dr. Reginald L. Gotchy Atomic Safety and Licensing Appeal Board Frederick Bernthal,Conmissioner U.S. Nuclear Regqlatory Conmission U.S. Nuclear Regulatory Cmmission Washington D.C. 20555 Washington, D.C. 20555 Judge Christine N. Kohl Thomas Roberts, Connissioner Atomic Safety and Licensing Appeal Board U.S. Nuclear Regulatory Cmmission U.S. Nuclear Regulatory Conmission
. Washington, D.C. 20555 Washington, D.C. 20555 Docketirg and Service Section Ivan W. Smith, Chairman Office of the Secretary Atomic Safety and Licensing Board U.S. Nuclear Regulatory Conmission U.S. Nuclear Regulatory Conmission Washington, D.C. 20555 Washington, D.C. 20555
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. Sheldon J. Wolfe, Alternate 01 airman William S. Jordan, III Atanic Safety and Licensing Board Harmon & Weiss U.S. Nuclear Regulatory Comnission 1725 I Street, N.W.
Washington, D.C. 20555 Suite 506 Washington, D.C. 20006 Professor Gary L. Milhollin 4412 Greenwich Parkway John A. Levin, Assistant Counsel Washington, D.C. 20007 Pennsyivania Public Utility Comnission P.O. Box 3265 Mrs. Marjorie Aamodt Harrisburg, Pennsylvania 17120 R.D. #5 Coatsville, PA 19320 ANGRY /'INI PIRC 1937 Maclay Street Douglas R. Blazey, Chief Counsel Harrisburg, PA 17103 Department of Environmental Resources 514 Executive House, P.O. Box 2357
- Steven C. Sholly Harrisburg, PA 17120 Union of Concerned Scientists 1346 Connecticut Ave.,
N.W., Suite 1101 Ms. Louise Bradford Washington, D.C. 20036 Three Mile Island Alert 1911 Green Street Richard J. Rawson Harrisburg, PA 17102 Office of Executive Legal Director U.S. Nuclear Regulatory Comnission Dr. Judith H. Johnsrud Washington, D.C. 20555 Dr. Chauncey Kepford Envirorynental Co61ition on Thanas A. Baxter, Esq.
Nuclear Power Shaw, Pittman, Potts & Trowbridge 433 Orlando Avenue 1800 M Street, N.W.
State College, PA 16801 Washington, D.C. 20036 1
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- Hand delivered.