ML19320D778

Motion to Compel Production of Licensee Emergency Plan Implementing Document.Means by Which Licensee Intends to Effectuate Plan Must Be Reviewed

ML19320D778
Person / Time
Site:	Three Mile Island
Issue date:	07/08/1980
From:	Bradford G ANTI-NUCLEAR GROUP REPRESENTING YORK
To:	Atomic Safety and Licensing Board Panel
Shared Package
ML19320D779	List: ML19320D778 ML19320D785 ML19320D789
References
NUDOCS 8007220203
Download: ML19320D778 (2)

Text

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ANGRY 7/8/80 '"

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UNITSD STATES OF AMERICA . 3*A m7

.m NUCLEAR REGULATORY C0f",IISSION a su '

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BEFORE THE ATO?.IIC SAFETY AND LICENSING BOAR g '$h?? h ^

In the Matter of METROPOLITAN EDISON CO.

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f Docket No. 50-289 qy 9[ '

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MOTION TO- TVE BOARD TO C07.tPEL LICENSEE TO SERVE THE "E?SRGENCY PLAN II."FLE'.TITING 27.TTO" TO THE ANTI-NUCLEAR GROUP REPRESENTING YCRK As the Board agreed at the first Special Prehearing Conference ~

in November, 1979. "the development and effectuation of adequate and effective Emergency Response Plans by the Licensee and by state and local governmental units are necessary for the public health and safety to be adequately protected and therefore should be made a pre-condition to the restart of T!. I-1. "

The Board will remember this .

as ANGRY's Contention 1, which was ruled a statement no one would disagree with. ANGRY submits that the existence of any plan, no matter how good does nothing to protect the public health and safety in time of emergency unless the plan canWand is implemented effectively.

For this reason we request that the Board require the Licensee to furnish all portions of the Implementing Document so that we may review the means by which the Licensee intends to effectuate its Emergency Plan. Our request specifically includes all potions of the Implementing Document, including those sections which have been reviewed by the Licensee's "PORC" and those sections which have not yet been reviewed by "PCRC."

Having the portions of the Implementing Document that have been reviewed by "PORC" drift into th.e Licensee 's Discovery Reading Room as they are complated is not very helpful to us. How can we tell when a new portion as arrived? Like all other parties, we are now snowed with reading matcrial and do not have the time to travel to Middletown on the chan% that a new section may have been put out.

Unless the Board is willing to delay the Emergency Planning schedule further, which we have no objection to, the Licensee should produce

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the entire Document as is and send revisions as they are completed by "PORC . " As the Board will understand, having the Regulations and the Emergency Plans change as they have requires quite a bit of work if we are to do our job properly as we intend, we need access, prompt andacamplete access.to the documents in the case.

July 8, 1980. Respectfully submitted,

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RGail P . Bradford, legal coordinatbr for ANGRY. 717/843'~7705

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