ML20084M786
| ML20084M786 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 06/01/1983 |
| From: | Doroshow J THREE MILE ISLAND ALERT |
| To: | Ahearne J, Gilinsky V, Palladino N NRC COMMISSION (OCM) |
| References | |
| NUDOCS 8306020355 | |
| Download: ML20084M786 (4) | |
Text
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T a Tunct MILE ISLAND Attar, Inc.
315 Peifor St Herrisburg. Pen'na.17102 (717)233-7897 June 1,
1983 Nunzio J.
Palladino, Chairman
~d3 USI -l Ell ll4 Victor Gilinsky, Commissioner John F.
Ahearne, Commi s s i~one r Thomas J.
Roberts, Commissioner James K.
Asselstine, Commissioner U.S. Nuclear Regulatory Commission Washington, D.C.
20555 In the Matter of METROPOI,ITAN ED' SON COMPANY (Three Mile Island Nuclear Station, Unit No, 1)
Docket No. 50-289
Dear Chairman Palladino and Commissioners:
This letter is to notify the Commission that despite TMI A's attempts to review the D&W trial record and prepare written comments by the June 1 deadline set by the Commission, we can not and will not risk physical exhaustion in an attempt to do so.
Nor are we prepared to supply the Commission with comments which are poorly done or based sloppy research, merely to moet on an arbitrary deadline.
This should como as no >; uprise to the Commission.
By comments dat ed Apri1 1 II, I9111, TMIA : eque s t od at loant Iwo to tbree montus to compieto Ihis t.as k.
This was io response to the NRC staff's assertion that it took several individuals working 70-80 hours a week, two to three months examining a mere portion of the material which we are to now review, just to prepare the slip-shod report presented to the Commission last March.
In further comments dated May 23, TMIA notified the Commission that it would be unable to meet this June 1 deadline, noting the virtual impossibility of using mcst of the docu-ments in the Harrisburg PDR until mid-May.
(See attached letter).
By the NRC's estimate, there are over 67 feet of documents involved in this review.
Even the NRC staff is having difficulty j
coping with the enormity of this task.
By any objective standard, the deadline imposed on the i n te rv eno r s in particular, whose time and resources are severly limited, is simply inhuman.
At TMIA, for example, there are basically two individuals who have sustained this case and who are familiar enough with the res t a r t. record to conduct an intelligent review of the B&W record -- both of whom have other full-time jobs.
In addition, because the intervepors are forced to share the documents located in the PDR, and often must remove them l
for overnight or weekend use, there are many times when particular documents or transcripts are simply not available when needed.
This problem has added considerably to TMIA's delay in reviewing portions of the record.
TMIA will make a sincere offort to get comments to the Commis-sinners somot imo ne x t work.
Anything we preparo, however, is guaren-tved t o be i nadequat o by TMIA's standards.
But. we note that it is the Commission',s legal duty to deal with this information in a non-arbitrary manner, not TMIA's.
Forcing us to rush through this i
process shows a how unmindful the Commission is of this duty.
Respectfully, 9306020355 030601 M
PDR ADOCK 05000289 h
G PDR Joanne Doroshow, TMIA
Here ipt o f !!a t e r ia l f y ou NRC Re la t,inj; t o CPlL_B & W T r ial_
April 7, 1983 - llearings f or CPU - B 5 W Trial received, organized in accordion folders and shelved in Reference Room.
April 22, 1983 - Three boxes of Exhibits from GPU/B&W Trial received. The boxes had numbered lists of the Exhibits as the only index.
The lists were not numbered consecutively, but in an un-explained random order.
April 26, 1983 - Twenty-four boxes of Exhibits, Depositions, etc., received f roir NRC withaut an Index.
The boxes had several numbering systems on them, such as 1 to 24 of 24, 1 to 3 of 3, and some of the boxes were gIven numbers that did not fit ir (see b[to the sequence, o f 1 t o.'4 Another set of numbers low) was concealed by paper attached with Scotch tape to the lops of the boxes.
May 6, 1983
- Index of B&W - GPU Lawsuit Exhibits Provided by CPU received.
The nain body of this index is a list, but with no indication of where the items on the list are to be found in the 24 boxes.
At the back of the list is an index of Depositions, telling in which of seven boxes the Depositions are to be found.
In helping Mrs, liradford wit h t he Index, I found that a Deposition she want.ed was in box 7 01 7.
There was no set of boxes labelled on the outside 7 of 7.
By carefully taking of f the top sheetu of paper with a knife, I ultimately found Box 7 of 7.
This box had the following numbers on it: 22 of 24; Box 24; 1 of 2; and underneath the label and not visibic without removing the label:
Box 7 of 7.
The Deposi t ions inside llox 7 were not labelled so that you would net know where to put them back without consulting the Index again.
May 12, 1983
- Receipt of boxes f rom 1.PDR orgimized in accordion fol'ders, plus other boxes.
The material received fron the 'RC (with the exception of the llearings) could nat be shelved and u*,cd separately from the boxes without destroying the only obvious order, that of the boxes themselves.
In the cases of the twenty-four boxes, the numbering sequence necessary to find Depositions had been concealed by pieces of paper attached on top when the whole set was renumbered ene to twenty-four, i
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'f'
/g l.awrence 11. I eterson[
8 N
o Reference 1.ibrarian State Library of Pennsylvania 5/13/83 u
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE COMMISSION In the Matter of
)
)
METROPOLITAN EDISON COMPANY
)
Docket No. 50-289
)
(Three Mile Island Nuclear
)
Station, Unit No. 1)
)
CERTIFICATE OF SERVICE I hereby certify that copies of the attached letter to the Commission dated June 1, 1983, was served this 1st day of June,.1983, by deposit in the U.S. Mail, first class, postage prepaid, or hand delivered, to those on the attached serv ice list.
01AD W (JJdANNE DOROBi!0W j
a
.....m
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a SERVICE LIST Chairman Palladino Commissioner Gilinsky U.S.
N.R.C.
U.S.
N.R.C.
Washington, D.C.
20555 Washington, D.C.
20555 Commissioner Ahearne Commissioner Roberts U.S. N.R.C.
U.S. N.R.C.
Washington, D.C. 20555 Washington, D.C. 20555 Commissioner Asselstine Judge Gary Edles, ASLAB U.S.
N.R.C.
U.S. N.R.C.
Washington, D.C. 20555 Washington, D.C.
20555 Judge John H.
Buck, ASLAB Judge Christine Kohl, ASLAB U.S.
N.R.C.
U.S.
N.R.C.
Washington, D.C.
20555 Washington, D.C.
20555 Judge Reginald Gotchy, AS L AB Professor Gary Milhollin U.S.
N.R.C.
4412 Greenwich Parkway, N.W.
Washington, D.C. 20555 washington, D.C.
20555 Harry Voigt Jack Goldberg LeBoeuf, Lamb, Leiby & MacRae Office of Executive Legal Director 13 33 New llamshi re Ave.
N.W.
U.S.
N.R.C.
Washington, D.C.
20555 Wanhington, D.C.
20555 George F.
Trowbridge, Esq.
Ms. Marjorie Aamodt Shaw, Pittman, Potts & Trowbridge R.D. 5 1800 M St.
N.W.
Coatesville, PA 19320 Washington, D.C.
20036 l
Ivan W. Smith,.Esq., ASLB Dr. Walter Jordon, AS LB U.S. N.R.C.
881 Outer Drive Washington, D.C.
20555 Oak Ridge, TN 37830 l
Docketing and Service Dr. Linda Little U.S.
N.R.C.
5000 Hermitage Drive Washington, D.C.
20555 Raleigh, NC 27612 Gail Phelphs Robert Adler PIRC Assistant Attorney General 1037 Maclay St.
505 Executive House Harrisburg, PA 17102 P.O.
Box 2357 Harrisburg, PA 17120 Steve Sholly Judith Johnsrud Dupont Circle Building ECNP 1346 Connecticut Ave.
N.W.
433 Orlando Ave.
l Washington, D.C.
20036 State College, PA 19320 Jordon Cunningham, Esq.
Fox, Far, & Cunningham 2320 North Second St.