ML20099B899
| ML20099B899 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 03/07/1985 |
| From: | Bernabei L GOVERNMENT ACCOUNTABILITY PROJECT, THREE MILE ISLAND ALERT |
| To: | Asselstine, Palladino N, Roberts T NRC COMMISSION (OCM) |
| References | |
| CON-#185-955 SP, NUDOCS 8503110152 | |
| Download: ML20099B899 (2) | |
Text
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GOVERNMENT ACCOUNTABILITY PROJECT 1555 Connecticut Awmue, N.W., Suite 202 (202)232-8550 Washington, D.C. 20036 Hand-De. livered ei March 7, 1985 h
spC0KET NUMSEt Nunz.to Palladino, Chairman m s ' t, ', F 4 0.............._. ;
Thomas Roberts, Commissioner James Asselstine, Commissioner Frederick Bernthal, Commissioner Lando Zech, Commissioner U.S.
Nuclear Regulatory Commission Washington, D.C.
20555
Dear Commissioners:
Yesterday, in accordance with the Commission's order, Three Mile Island Alert filed its Appeal of Judge Ivan W.
Smith's Order Denying Motions to Disqualify Him.
I noted that page 23 was inadvertently omitted.
Enclosed please find page 23.
On page 32 of the Appeal, TMIA stated, "TMIA representa-tive Louise Bradford has represented TMIA since the main hearings, beginning in January 1981.
and participated in most of the hearings on training issues."
I wish to clarify that I mean by participation that Ms. Bradford attended the main hearings on training and actively represented TMIA in both the reopened and the remanded training hearings.
On page 48, the citations which appear in the third paragraph should be placed at the end of the first sentence of that paragraph.
l I regret any inconvenience this may have caused you.
I Sincerely yours, l
/*, Q kis &
W-Lyn e Bernabei Attohney for Three Mile Island Alert cc:
Service List
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k Second, Judge Smith admits that he learned of Floyd's conviction and inferred that Floyd had been publicly humiliated and his career damaged outside the restart proceeding.
Memorandum and Order at 23. Yet he mysteriously terms this fact "a quibble--an irrelevant one at that."
Id. at 22.
Clearly, Judge Smith's statements about Floyd's motivation for cheating and his conclusions about the injuries Floyd has suffered from his conviction are derived f rom sources outside the restart proceedings.
Since Judge Smith's letter was based on extrajudicial sources, and demonstrates bias in f avor of Licensee and prejudment of the training issue, it requires his removal.
/s