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Category:LEGAL TRANSCRIPTS & ORDERS & PLEADINGS
MONTHYEARML20210B8491999-07-21021 July 1999 Exemption from Certain Requirements of 10CFR50.54(w),for Three Mile Island Nuclear Station Unit 2 to Reduce Amount of Insurance for Unit to $50 Million for Onsite Property Damage Coverage ML20206D4141999-04-20020 April 1999 Exemption from Requirements of 10CFR50,App R,Section III.G.2 Re Enclosure of Cable & Equipment & Associated non-safety Related Circuits of One Redundant Train in Fire Barrier Having 1-hour Rating ML20206T7211999-02-11011 February 1999 Memorandum & Order (CLI-99-02).* Denies C George Request for Intervention & Dismisses Subpart M License Transfer Proceeding.With Certificate of Svc.Served on 990211 ML20198A5111998-12-11011 December 1998 Comment Opposing Proposed Rule 10CFR50.65 Re Requirements for Monitoring Effectiveness of Maintenance at Nuclear Power Plants.Proposed Rulemaking Details Collaborative Efforts in That Rule Interjects Change ML20154G2941998-09-17017 September 1998 Transcript of 980917 Public Meeting in Rockville,Md Re License Transfer of TMI-1 from Gpu Nuclear,Inc to Amergen. Pp 1-41 ML20199J0121997-11-20020 November 1997 Comment on Pr 10CFR50 Re Financial Assurance Requirements for Decommisioning Nuclear Power Reactors.Three Mile Island Alert Invokes Comments of P Bradford,Former NRC Member ML20148R7581997-06-30030 June 1997 Comment on NRC Proposed Bulletin 96-001,suppl 1, Control Rod Insertion Problems. Licensee References Proposed Generic Communication, Control Rod Insertion, & Ltrs & 961022 from B&W Owners Group ML20078H0431995-02-0101 February 1995 Comment Opposing Proposed Rule 10CFR50 Re Shutdown & Lowpower Operations for Nuclear Reactors ML20077E8231994-12-0808 December 1994 Comment Supporting Proposed Rules 10CFR2,51 & 54 Re Rev to NRC NPP License Renewal Rule ML20149E2021994-04-20020 April 1994 R Gary Statement Re 10 Mile Rule Under Director'S Decision DD-94-03,dtd 940331 for Tmi.Urges Commissioners to Engage in Reconsideration of Author Petition ML20065Q0671994-04-0707 April 1994 Principal Deficiencies in Director'S Decision 94-03 Re Pica Request Under 10CFR2.206 ML20058A5491993-11-17017 November 1993 Exemption from Requirements in 10CFR50.120 to Establish, Implement & Maintain Training Programs,Using Sys Approach to Training,For Catorgories of Personnel Listed in 10CFR50.120 ML20059J5171993-09-30030 September 1993 Transcript of 930923 Meeting of Advisory Panel for Decontamination of TMI-2 in Harrisburg,Pa.Pp 1-130.Related Documentation Encl ML20065J3461992-12-30030 December 1992 Responds to Petition of R Gary Alleging Discrepancies in RERP for Dauphin County,Pa ML20065J3731992-12-18018 December 1992 Affidavit of Gj Giangi Responding to of R Gary Requesting Action by NRC Per 10CFR2.206 ML20198E5581992-12-0101 December 1992 Transcript of Briefing by TMI-2 Advisory Panel on 921201 in Rockville,Md ML20210D7291992-06-15015 June 1992 Exemption from Requirements of 10CFR70.24 Re Criticality Accident Requirements for SNM Storage Areas at Facility Containing U Enriched to Less than 3% in U-235 Isotope ML20079E2181991-09-30030 September 1991 Submits Comments on NRC Proposed Resolution of Generic Issue 23, Reactor Coolant Pump Seal Failure. Informs That Util Endorses Comments Submitted by NUMARC ML20066J3031991-01-28028 January 1991 Comment Supporting SECY-90-347, Regulatory Impact Survey Rept ML20059P0531990-10-15015 October 1990 Comment Opposing Proposed Rules 10CFR2,50 & 54 Re Nuclear Power Plant License Renewal ML20059N5941990-10-0404 October 1990 Transcript of 900928 Public Meeting in Rockville,Md Re Studies of Cancer in Populations Near Nuclear Facilities, Including TMI ML20055F4411990-06-28028 June 1990 Comment Supporting Petition for Rulemaking PRM-50-55 Re Revs to FSAR ML20248J1891989-10-0606 October 1989 Order.* Grants Intervenors 891004 Motion for Permission for Opportunity to Respond to Staff Correspondence.Response Requested No Later That 891020.W/Certificate of Svc.Served on 891006 ML20248J1881989-10-0303 October 1989 Motion for Permission for Opportunity to Respond to Staff Correspondence in Response to Board Order of 890913.* Svc List Encl ML20248J0301989-09-29029 September 1989 NRC Staff Response to Appeal Board Order.* Matters Evaluated in Environ Assessment Involved Subjs Known by Parties During Proceeding & Appear in Hearing Record & Reflect Board Final Initial Decision LBP-89-7.W/Certificate of Svc ML20247E9181989-09-13013 September 1989 Order.* Requests NRC to Explain Purpose of 890911 Fr Notice on Proposed Amend to Applicant License,Revising Tech Specs Re Disposal of Accident Generated Water & Effects on ASLB Findings,By 890929.W/Certificate of Svc.Served on 890913 ML20247G0361989-07-26026 July 1989 Transcript of Oral Argument on 890726 in Bethesda,Md Re Disposal of accident-generated Water.Pp 1-65.Supporting Info Encl ML20247B7781989-07-18018 July 1989 Certificate of Svc.* Certifies Svc of Encl Gpu 890607 & 0628 Ltrs to NRC & Commonwealth of Pa,Respectively.W/Svc List ML20245D3651989-06-20020 June 1989 Notice of Oral Argument.* Oral Argument on Appeal of Susquehanna Valley Alliance & TMI Alert from ASLB 890202 Initial Decision Authorizing OL Amend,Will Be Heard on 890726 in Bethesda,Md.W/Certificate of Svc.Served on 890620 ML20245A5621989-06-14014 June 1989 Order.* Advises That Oral Argument on Appeal of Susquehanna Valley Alliance & TMI Alert from Board 890202 Initial Decision LBP-89-07 Authorizing OL Amend Will Be Heard on 890726 in Bethesda,Md.W/Certificate of Svc.Served on 890614 ML20247F3151989-05-22022 May 1989 NRC Staff Response to Appeal by Joint Intervenors Susquehanna Valley Alliance/Tmi Alert.* Appeal Should Be Denied Based on Failure to Identify Errors in Fact & Law Subj to Appeal.W/Certificate of Svc ML20246Q2971989-05-15015 May 1989 Comment Opposing Proposed Rule 10CFR50 Re Ensuring Effectiveness of Maint Programs for Nuclear Power Plants ML20246J6081989-05-12012 May 1989 Licensee Brief in Reply to Joint Intervenors Appeal from Final Initial Decision.* ASLB 890203 Final Initial Decision LBP-89-07 Re Deleting Prohibition on Disposal of accident- Generated Water Should Be Affirmed.W/Certificate of Svc ML20247D2761989-04-20020 April 1989 Transcript of 890420 Briefing in Rockville,Md on Status of TMI-2 Cleanup Activities.Pp 1-51.Related Info Encl ML20244C0361989-04-13013 April 1989 Order.* Commission Finds That ASLB Decision Resolving All Relevant Matters in Favor of Licensee & Granting Application for OL Amend,Should Become Effective Immediately.Certificate of Svc Encl.Served on 890413 ML20245A8381989-04-13013 April 1989 Transcript of Advisory Panel for Decontamination of TMI-2 890413 Meeting in Harrisburg,Pa.Pp 1-79.Supporting Info Encl ML20245A2961989-04-13013 April 1989 Transcript of 890413 Meeting in Rockville,Md Re Affirmation/Discussion & Vote ML20248H1811989-04-0606 April 1989 Valley Alliance/Tmi Alert Motion for Leave to File Appeal Brief out-of-time.* W/Certificate of Svc.Served on 890411.Granted for Aslab on 890410 ML20248G0151989-04-0606 April 1989 Valley Alliance/Tmi Alert Motion for Leave to File Appeal Brief out-of-time.* Requests to File Appeal Brief 1 Day Late Due to Person Typing Document Having Schedule Problems ML20248G0261989-04-0606 April 1989 Susguehanna Valley Alliance/Tmi Alert Brief in Support of Notification to File Appeal & Request for Oral Argument Re Appeal.* Certificate of Svc Encl ML20248D7211989-04-0404 April 1989 Memorandum & Order.* Intervenors Application for Stay Denied Due to Failure to Lack of Demonstrated Irreparable Injury & Any Showing of Certainty That Intervenors Will Prevail on Merits of Appeal.W/Certificate of Svc.Served on 890404 ML20247A4671989-03-23023 March 1989 Correction Notice.* Advises That Date of 891203 Appearing in Text of Commission 890322 Order Incorrect.Date Should Be 871203.Certificate of Svc Encl.Served on 890323 ML20246M2611989-03-22022 March 1989 Order.* Advises That Commission Currently Considering Question of Effectiveness,Pending Appellate Review of Final Initial Decision in Case Issued by ASLB in LBP-89-07. Certificate of Svc Encl.Served on 890322 ML20236D3821989-03-16016 March 1989 Valley Alliance & TMI Alert Motion for Extension of Time to File Brief in Support of Request for Appeal in Matter of 2.3 Million Gallons Of....* Certificate of Svc Encl.Served on 890316.Granted for Aslab on 890316 ML20236D3121989-03-15015 March 1989 Licensee Answer to Joint Intervenors Motion for Extension of Time to File Brief on Appeal.* Motion Opposed Based on Failure to Demonstrate Good Cause.W/Certificate of Svc ML20236D2901989-03-11011 March 1989 Valley Alliance/Tmi Alert Motion for Extension of Time to File Brief in Support of Request for Appeal in Matter of Disposal of 2.3 Million Gallons of Radioactive Water at Tmi,Unit 2.* Svc List Encl ML20236A3761989-03-0808 March 1989 Licensee Answer Opposing Joint Intervenors Motion for Stay.* Stay of Licensing Board Decision Pending Appeal Unwarranted Under NRC Stds.Stay Could Delay Safe,Expeditious Cleanup of Facility.Certificate of Svc Encl ML20236C2441989-03-0808 March 1989 NRC Staff Response in Opposition to Application for Stay Filed by Joint Intervenors.* Application for Stay of Effectiveness of Final Initial Decision LBP-89-07,dtd 890202 Should Be Denied.W/Certificate of Svc ML20235V2641989-03-0202 March 1989 Notice of Aslab Reconstitution.* TS Moore,Chairman,Cn Kohl & Ha Wilber,Members.Served on 890303.W/Certificate of Svc ML20235V2161989-02-25025 February 1989 Changes & Corrections to Susquehanna Valley Alliance/Three Mile Island Alert Documents Submitted on 890221.* Certificate of Svc Encl 1999-07-21
[Table view] Category:PLEADINGS
MONTHYEARML20065J3461992-12-30030 December 1992 Responds to Petition of R Gary Alleging Discrepancies in RERP for Dauphin County,Pa ML20248J1881989-10-0303 October 1989 Motion for Permission for Opportunity to Respond to Staff Correspondence in Response to Board Order of 890913.* Svc List Encl ML20248J0301989-09-29029 September 1989 NRC Staff Response to Appeal Board Order.* Matters Evaluated in Environ Assessment Involved Subjs Known by Parties During Proceeding & Appear in Hearing Record & Reflect Board Final Initial Decision LBP-89-7.W/Certificate of Svc ML20248H1811989-04-0606 April 1989 Valley Alliance/Tmi Alert Motion for Leave to File Appeal Brief out-of-time.* W/Certificate of Svc.Served on 890411.Granted for Aslab on 890410 ML20248G0261989-04-0606 April 1989 Susguehanna Valley Alliance/Tmi Alert Brief in Support of Notification to File Appeal & Request for Oral Argument Re Appeal.* Certificate of Svc Encl ML20248G0151989-04-0606 April 1989 Valley Alliance/Tmi Alert Motion for Leave to File Appeal Brief out-of-time.* Requests to File Appeal Brief 1 Day Late Due to Person Typing Document Having Schedule Problems ML20236D3821989-03-16016 March 1989 Valley Alliance & TMI Alert Motion for Extension of Time to File Brief in Support of Request for Appeal in Matter of 2.3 Million Gallons Of....* Certificate of Svc Encl.Served on 890316.Granted for Aslab on 890316 ML20236D3121989-03-15015 March 1989 Licensee Answer to Joint Intervenors Motion for Extension of Time to File Brief on Appeal.* Motion Opposed Based on Failure to Demonstrate Good Cause.W/Certificate of Svc ML20236D2901989-03-11011 March 1989 Valley Alliance/Tmi Alert Motion for Extension of Time to File Brief in Support of Request for Appeal in Matter of Disposal of 2.3 Million Gallons of Radioactive Water at Tmi,Unit 2.* Svc List Encl ML20236A3761989-03-0808 March 1989 Licensee Answer Opposing Joint Intervenors Motion for Stay.* Stay of Licensing Board Decision Pending Appeal Unwarranted Under NRC Stds.Stay Could Delay Safe,Expeditious Cleanup of Facility.Certificate of Svc Encl ML20236C2441989-03-0808 March 1989 NRC Staff Response in Opposition to Application for Stay Filed by Joint Intervenors.* Application for Stay of Effectiveness of Final Initial Decision LBP-89-07,dtd 890202 Should Be Denied.W/Certificate of Svc ML20235N1621989-02-20020 February 1989 Application for Stay of Effectiveness of Final Initial Decision LBP-89-07 Dtd 890202.* Licensee Would Not Be Harmed by Granting of Stay ML20205D8451988-10-24024 October 1988 Licensee Motion to Strike Portions of Proposed Testimony of Kz Morgan.* Proposed Testimony Should Be Ruled to Be Not Admissible as Evidence in Upcoming Hearing.Supporting Info & Certificate of Svc Encl.W/Copyrighted Matl ML20205D6801988-10-20020 October 1988 Valley Alliance/Tmi Alert Notification to Parties That Kz Morgan Apps to Testimony Should Be Accepted as Exhibits.* Apps Listed.Svc List Encl.Related Correspondence ML20155G9981988-10-0404 October 1988 Valley Alliance/Tmi Alert Motion for Reconsideration of Part of Judge Order (880927) Re Limited Appearance Statements by Public.* Certificate of Svc Encl ML20155G9921988-10-0404 October 1988 Valley Alliance/Tmi Alert Motion to Submit Witness Testimony as Evidence W/O cross-exam at Hearing in Lancaster.* Requests That Cw Huver Testimony Be Accepted as Evidence ML20151S0261988-07-28028 July 1988 Valley Alliance/Tmi Alert Response to Licensee Notification of Typo in Bid Procurement Document.* Explanation for Change in Document Inadequate.W/Svc List ML20196G7801988-06-23023 June 1988 Motion of NRC Staff for Leave to File Response Out of Time.* Encl NRC Response in Support of Licensee Motion for Summary Disposition Delayed Due to Equipment Problems ML20196G9051988-06-23023 June 1988 NRC Staff Response in Support of Licensee Motion for Summary Disposition.* Motion Should Be Granted on Basis That No Genuine Issue Before ASLB or to Be Litigated.Supporting Documentation & Certificate of Svc Encl ML20196B5091988-06-20020 June 1988 Valley Alliance/Tmi Alert Response to Licensee Motion or Summary Disposition on Contentions 1-4,5d,6 & 8.* Affidavits of Kz Morgan,R Piccioni,L Kosarek & C Huver & Supporting Documentation Encl ML20154E2301988-05-16016 May 1988 Licensee Statement of Matl Facts as to Which There Is No Genuine Issue to Be Heard (Contentions 1,2,3 & 8).* ML20154E2081988-05-16016 May 1988 Licensee Motion for Summary Disposition on Alternatives (Contentions 1,2,3 & 8).* Motion Should Be Granted Based on Licensee Meeting Burden of Showing That Alternatives Not Superior to Licensee Proposal ML20154E3491988-05-16016 May 1988 Licensee Statement of Matl Facts as to Which There Is No Genuine Issue to Be Heard (Contention 5d).* ML20154E2851988-05-16016 May 1988 Licensee Statement of Matl Facts as to Which There Is No Genuine Issue to Be Heard (Contentions 4b in Part & 6 on Chemicals).* ML20154E3251988-05-16016 May 1988 Licensee Motion for Summary Disposition of Contention 5d.* Motion Should Be Granted in Licensee Favor ML20154E2681988-05-16016 May 1988 Licensee Motion for Summary Disposition of Contentions 4b in Part & 6 (Chemicals).* Licensee Entitled to Decision in Favor on Contentions & Motion Should Be Granted ML20154E1631988-05-0909 May 1988 Licensee Statement of Matl Facts as to Which No Genuine Issue to Be Heard (Contentions 4b in part,4c & 4d).* Lists Matl Facts for Which No Genuine Issue Exists ML20154E1281988-05-0909 May 1988 Licensee Motion for Summary Disposition of Contentions 4b (in part),4c & 4d.* Requests That Motion for Summary Disposition Be Granted on Basis That No Genuine Issue of Matl Fact Exists to Be Heard Re Contentions ML20154E1761988-05-0909 May 1988 Licensee Memorandum of Law in Support of Motions for Summary Disposition.* Requests Ample Notice Should Board Decide to Deny Summary in Part or in Whole ML20151E9491988-04-0707 April 1988 Licensee Answer to Intervenor Motion for Order on Production of Info on Disposal Sys Installation & Testing.* Intervenor 880330 Motion Should Be Denied Due to Insufficient Legal Basis.W/Certificate of Svc ML20150F9821988-04-0101 April 1988 Licensee Answer to Intervenors Motion to Compel Discovery.* Motion Should Be Denied on Basis That Licensee Responded Fully to Discovery Request.Certificate of Svc Encl ML20148P3931988-03-30030 March 1988 Valley Alliance & TMI Alert Motion to Request That Presiding Judge Order Gpu Nuclear to Provide Addl Info & Clarify Intentions to Install Test & Conduct Experiments W/Evaporator Prior to Hearings.* ML20196D2801988-02-12012 February 1988 NRC Staff Response to Motion by TMI Alert/Susquehanna Valley Alliance for Extension of Discovery.* Motion Should Be Denied.Certificate of Svc Encl ML20196D3541988-02-10010 February 1988 Licensee Response Opposing Susquehanna Valley Alliance/Tmi Alert Intervenor Motion for Extension of Time for Discovery.* Joint Intervenors Failed to Show Good Cause for Extension of Time for Discovery.Certificate of Svc Encl ML20148D4661988-01-19019 January 1988 Licensee Objection to Special Prehearing Conference Order.* Board Requested to Clarify 880105 Order Consistent W/ Discussed Description of Board Jurisdiction & Scope of Proceeding.W/Certificate of Svc ML20236N9081987-11-0505 November 1987 Joint Motion for Approval of Settlement Agreement & for Termination of Proceeding.* Termination of Proceeding Should Be Granted ML20235F3651987-09-23023 September 1987 Util Response Opposing NRC Staff Motion to Rescind Protective Order.* Response Opposing Protective Order Guarding Confidentiality of Document Re Methodology of Bechtel Internal Audit Group ML20235B3911987-09-18018 September 1987 NRC Staff Motion for Extension of Time.* Staff Requests Short Extension of Time Until 870925 to File Responses to Pending Petitions.Certificate of Svc Encl ML20235F4401987-09-18018 September 1987 Util Supplemental Response to NRC Staff First Request for Admissions.* Util Objects to Request as Vague in Not Specifying Time Frame or Defining Proprietary, Pecuniary.... W/Certificate of Svc.Related Correspondence ML20238E6001987-09-0404 September 1987 NRC Staff Motion to Rescind Protective Order.* Protective Order Should Be Rescinded & Presiding Officer Should Take Further Action as Deemed Appropriate.W/ Certificate of Svc ML20238E6391987-09-0303 September 1987 Commonwealth of PA Statement in Support of Request for Hearing & Petition to Participate as Interested State.* Susquehanna Valley Alliance 870728 Request for Hearing, Notice of Appearance & Certificate of Svc Encl ML20237J9931987-08-12012 August 1987 Joint Gpu & NRC Staff Motion for Protective Order.* Order Will Resolve Discovery Dispute ML20237K0431987-08-11011 August 1987 Gpu Response Opposing Parks Motion to Quash Subpoena Duces Tecum.* Exhibits & Certificate of Svc Encl ML20236P1871987-08-0505 August 1987 Formal Response of Rd Parks to Subpoena Duces Tecum of Gpu &/Or,In Alternative,Motion to Quash/Modify Subpoena Due to Privileged Info.* Documents Are Communications Protected by Atty/Client Privilege.Certificate of Svc Encl ML20236E7101987-07-28028 July 1987 Joint General Public Utils Nuclear Corp & NRC Staff Motion for Protective Order.* Adoption & Signature of Encl Proposed Order Requested ML20216J7871987-06-29029 June 1987 Opposition of Gpu Nuclear Corp to Aamodt Motion for Reconsideration.* Motion Asserts Board Did Not Consider Important Evidence on Leakage at TMI-2.W/Certificate of Svc ML20216D2311987-06-23023 June 1987 Response of Jg Herbein to Aamodt Request for Review & Motion for Reconsideration.* Opportunity for Comment Should Come After NRC Has Made Recommendations to Commission.Certificate of Svc Encl ML20215J8981987-06-19019 June 1987 Response of Numerous Employees to Aamodt Request to File Comments on Recommended Decision.* Numerous Employees Do Not Agree W/Aamodt That Recommended Decision Is Greatly in Error.Certificate of Svc Encl ML20215K2121987-06-17017 June 1987 (Motion for reconsideration,870610).* Corrections to Pages 3 & 4 Listed ML20215J7551987-06-15015 June 1987 Gpu Response to Motion to Quash Subpoena.* Dept of Labor 870601 Motion to Quash Subpoena Served on D Feinberg Should Be Denied.W/Certificate of Svc 1992-12-30
[Table view] |
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- s. . > -ENVIRONMENTAL COALITION ON NUCLEAR POWER Co Owoetors: Mr. George 8comsme-R.D. et,Peoch Bottom,Pa.17563 737 548-2836
- p3 ]Dr. Judith Johnsrud-433 orfendo Avenue, State College, Pa.16801 814 2374900
=t q,-! ., 1 f [p;. p ,e3 UNITED STATES OF AMERICA
.NUCLEAR REGULATORY COMMISSION
'~/*5 In the Matter of
- g^METROPOLITAN EDISON COMPANY, et al.
'(Three Mile Island Nuclear Statioii, ,p Docket No. 50-289 Unit 1),'g.'ADDITIONAL DRAFT CONTENTIONS OF THE ENVIRONMENTAL COALITION ON NUCLEA;! POWER The Environmental Coalition on Nuclear Power (ECNP), in compliance with the September 21, 1979 Memorandum and Order of the Atomic Safety and Licensing Board (Board), submits the following draft contentions. These draft conteations supplement the contegtions already raised and dis' cussed
,- :-in the June 29 and March 29[l 79, ECNP Petitions to NRC incorporated in
., the ECNP Petition to Intervene.
,, These two sets of contentions maf be supplemented 4with additional
- .contentions that may be raised in the October 22, 1979 ECNP filing of
-final contentions.
For example, these Petitioners have only ir. the last few days received NUREG-0600, the NRC Staff Report on the THI-2 accident,.'.and the Suspended Licensee's Report inlCesponse to NRC Staff Recommended Requirements for Restart of Three Mile-Island Nuclear Station Unit 1; -
we have had, therefore, no opportunity. to review those docun.3nts wiich .
l may contain information pertinent to additional issues which we wifl need to litigate in this proceeding on the proposed reopening of TMI-1.
In addition, the ECNP legal representatives in this proceeding have requested from the Staff documents and data pertaining to THI-2 during the early weeks of the accident and subsequently. Although the ECNP representatives had
'made these requests'in their capacity as the legal representatives of the
.1312 271?onnost/C..... . . .9 L 'd- h/yu
..
,...,_-2-.public-interest intervening organizations (member grcups ECNP) in the still ongoing Operating License proceedings for TMI-2, their requests have been totally ignored by the NRC Staff in the six months since the accident began. The information requested--when and if the NRC Staff deigns to respond to these Intervenors in TMI-21'may also lead to additional con-tentions in these THI-1 proceedings.
,-.. . ..m 1.Pursuant to the April 11, 1978, Order of the Comissioners which voided the 14.5 curies per year value of emissions of radon-222 in Table S-3 (10 CFR 51.20(e)) and opened all reactor licenses to litiga-tion on radon and its health effects, the ECNP Petitioners contend that TMI-1. should n3t be allowed to operate until Table S-3 contains a value of radon-222 emissions consistent with NRDC v. USNRC,547 F.2d 633, 639, at n.12 (which requires that the Comission evaluate the full period
.of toxicity of residual by-products of the nuclear fuel cycle). Since radon-222 emissions from abandoned mines, mill tailings, and depleted uranium have the potential for being far larger a source of radioactivity ta the environment than all other sources of radioactivity combined (all per annual fuel requirement), this suspended Operating License should not be reinstated; the Operating License was granted in tha first place by ignoring these prodigious emissions of radon-222, in
-violation of the National Environmental Policy Act of 1969. Furthermore, ignoring the radon eaissions is inconsistent with the Comission's legal obligation to protect the health and safety of the public.
2.The Operating License of THI-1 should not be reinstated -- if at all -- until Table S-3 (10 CFR 51.20(e)) is full and complete, which it now is not. For example, one large source of environmental contamination in the fuel cycle comes from technetium-99, which has until recently also been ignored by the Staff.
In addition, the Staff has seriously and irresponsibly underestimated the hazards to human beings resulting from the ingestion of technetium-99.
3.The Staff of the Commission, in i ts publication Regulatory -
Guide 1.109, sets forth conversion factors for calculating exposures to humans as a result of ingestion of, inhalation of, or imersion in a cloud of radioisotopes. For a number of radioisotopes of biological importance, these conversion factors have been underestimated by factors ranging from 10 to over 1000. The Operating License for TMI-1 should not be reinstated until the true and full environmental effects for the entire fuel cycle have been properly, fully, and accurately detemined, without omission or s0bterfuge.
4.The Operating License for TMI-1 should remain in suspension until the full range of accidents, including risk (sequences and consequences 1312 272..
~,.,-3-4. (cont'd.) of events) of Class 9 accidents, has been fully
-analyzed for the TMI site, with due consideration to the applicable populations, previous accident experience, local weather conditions, and local geography.
ECNP contends that there can be no justification for further jeopardizing the lives, the mental, physical, and genetic health, and the properties and economic security of all individuals
-within the lethal zone of THI.
- 5. ~ ECNP contends that the suspension of the Operating Libense for THI-l should remain in effect until 'a full and unbiased investigation
'has been completed to answer the question: Was perjury comitted by- -
witnesses for the Applicant, the NRC Staff, or the Commonwealth of Pennsylvania during the evidentiary proi:eedings which led to the licensing of either TMI-l or TMI-27. ECNP believes that perjury.kas comitted by witnesses for the above mentioned parties. A refusal
,-by the Comnission to investigate this matter would further undermine' public confidence in the Commission's objectivity and would also represent a violation of the Comission's legal obligation to protect the heal.th and safety of the public above all else.
---..6.ECNP contends, that the emissions from the normal operation of THI-l have had an obsenable and adverse effect on the reproductive success of farm animals and domestic pets (notably cats) in certain areas around the facility. These problems with fauna have been sub-stantially worsened by the accident at TMI-2 which has also been followed by observable damage to local! flora, including, but not limited to,?
the deaths of local apple, pear, and pjne trees. No further operation of this facility should be pennitted, 'as'it may lead to the economic-decline of the local agricultural comunity.
!7.The recent Class 9 accident at TMI-2 vividly demonstrated
_the inability of all parties involved -- Met. Ed. management and station operators, state and local Civil Defense personnel, and NRC personnel at n any and all levels -- to comprehend the nature of the TMI-2 accident as it unfolded, to comunicate the necessary informatica to one another, the public, and the President in an honest, accurate, and timely manner, , and to decide in a timely manner what course to take to protect the health and safety of the public.
ECNP' contends that timely evacuation of large populations to areas which would not be threatened by changing weather conditions is a physical impossibility.
Furthermore, ECNP believes that any reprssentation by th6se parties that evacuation in the event of a Class.9. accident -- as THI-2 was -- is a possible or practical preventative measure lies somewhere among self-delusion, falseMod, and willful deception.
In addition, we note that the only way to a:sure 2e safety.of the residents of the area around TMI from future 'tecidents at either reactor is to remove permanently the THI nuclear i ctlities tnemselves. It is these facilities, in conjunction wi.th the slipshod management, operation, and
-regulation of them, which pose the threat to this area and its residents.
8.ECNP contends that any representation by any Met. Ed. official averring that emergency preparedness or emergency procedures have been adequately augmented since the TMI-2 accident must be viewed with extreme skepticism.
Similar assurances of the adequacy of emergency preparedness and emergency procedures were testified to under oath at the TMI-2 Operating License 1312 273..-..-.-.-....-_ _
.,.'.-4-~8. (cont'd.) hearings in 1977 and were found to be wholly with-out m&it in March and April,1979, when the accident tooE11 ace. Further assurances under cath at this time in this WI-l proceeding that problems have been solved must be viewed in conjunction with past assurances also made under oath that problems could not exist.
In addition, the credibility of the officials of Met Ed has been destrtyed by tne public statements of these officials throughout the course of the TMI-2 accident which is still in progress. Therefore, the testimony under oath of the Suspended Licensee in this proceeding cannot be accepted as credible by the Licensing Board in reaching its decision concerning the possibility of reopening TMI-1 or the permanent revocation of the Operating License for TMI-1.
.. . . -9.ECNP contends that TMI-l cannot be operated with . reasonable assurance that the health and safety of the public can be adequately protected because of the possibility of further radiological contamination of the THI plant site durirg the clean-up and decomissioning of the damaged THI-2 reactor. The very presence of the damaged reactor and the experimental nature of all decontamination and repair operations at the damaged 1MI-2 preclude reasonable assurance of safe operation of TMI-1. Unforeseen problems, difficulties, and accidents at TMI-2 at unpredictable times in the future may require emergency use of the TMI-l facility to prevent release of radioactive traterials into the offsite environment. The present uncertainty concerning the safe operability of the experimental Epicor II deconta:nination system, plus the pending overflow of intermediate and high-level radioactive waste water, and the potential for increased leakage of reactor coolant or other contaminated water in quantities requiring utilization of THI-l for storage purposes exemplify the issue raised in this contention.
-10. ECNP contends that THI-l is presently as vulnerable to the crash of a larger-than-design-basis aircraft as was TMI-2 prior to the accident.
In the TMI-2 eYidentiary proceeding the potential crash of a larger-than-design-basis aircraft into TMI-2 was conceded by all parties to lead to offsite consequences greater than those allowed under 10 CFR 100. Even though TMI-2 is disabled and inoperable at the present time, the Unit and THI-l tray be even more susceptible to any aircraft crash now than was the case before the accident. This increased susceptibility is due to the successive loss of protective barriers between the fission and activation products and the outside environment as a result of the TMI-2 accident.
We note too that a system called Epicor II has been designed and built in order to decontaminate the approximately one million gallons of highly contaminated water at TMI-2. We are unable to detennine whether or not this system is protected against any aircraft crash, because ECNP, although represented by the same Intervenors as in the TMI-2 proceeding, has not yet been served any information whatsoever concerning Epicor II, despite the relevance of such infonnation to the still unresolved aircraft crash issues in the ongoing TMI-2 Operating License proceeding.
11 . ECNP contands that concrete of the TMI-1 containment building is of uncertain quality and has not been appropriately tested to ascertain the 1312 274..-.- . . - - .
-.. . ...- . ._.
,--..-5-capability of the TMI-1 containment to withstand either externally or internally propagated events (e.g., aircraft crash, hydrogen explosion, or static design basis pressure). Construction irregularities contribute to the uncertainty that the THI-1 contairraent is capable of withstanding a Class 9 accident sequence equal to or greater than the Class 9 accident that occurred at the
.adjacent TMI-2 reactor. For these reasons, the TTiI-1 reactor should not be pensitted to operate.
., , i2.In consequence of the denonscrated deficiencies of design, cow
~: struction, management, operation, maintenance, monitoring, energency resionse, evacuation capabili>y, licensing, inspection, and other regulation by al'1 parties associated with the Three Mile Island Nuclear Station, Units 1 and 2 ECNP contends that the licenses to operate either nuclear reactor should be permanently revoked, in order to protect the health, safety, psychological, economic, and political well-being of the people of Central Pennsylvania.
The Suspended Licensee, Met Ed, has demonstrated conclusively that it has no concern for the safety or the health or the very lives of members of the public., ECNP reserves the right to alter, amend, or add to this list of draft contentions as well as the contentions raised in the June 29 and March 29, 1979, petitions when the final contentions are submitt'ed on October 22, 1979.
Respectfully submitted, usei A*Chauncey KepoV4"/'
and'/.i/2d /kie0 Jddith Johnsrud Representatives of the ECNP Petitioners of October,1979
...1 M 2175. . . .. . . .-..._.-._
4-."n q m O'CERTIFICATE OF SERVICE ss s ,.: h I certify that copies of ADDITIONAL DRAFT CONTENTIONS OF THE ENVIRONMENTAL COALITION ON NUCLEAR POWER have bepenerved on the folloding by deposit in the US Mail, postage paid, this g day of October,1979 u/M R aVni:ey KepKd f_.,'. . . . .H norable Mark Cohen
'Co m el for NRC S f 512 E-3 Main Capital Buf Tding
,~~office of the Executive Legal Director Barrisburg, Pennsylv=2,4m - 17120 U.S. Eclear Regulatory C**sion Washington, D.C.
20555 Robert Q. Pollard Esl. -
-.Chesapeake Energy Alliance
- George 7. Trowbridge, Esq.
609 Montpelier Street
- Shav Pittnan, Potts & Trowbridge re, Madand U2
20006-**-*.**'. . .,, Walter' W. Cohen, Cons-smer* Advocata
,. T.arin U. Carter, Esq.
-4 Assistzsc J.ctorney General, Department of Justice r Strawberry Square,14M Floor Deparrnent of Environnental Resources 709 Health and Welfare Building Harrisburg, Pa.
1712"7 'Earrisburg, Pennsylvania 17120 d**Ms. Jane Lee
-.R.7. 3, Box 3521
-Ellyn veiss, Esq.
Sheldon, Har .on, Reis=an and Etters, Pennsylvania 17319 , reiss..Robert L. Knupp. Esq.
102515ch Screets J.W.
..hshington, D.C.
20005 Assistant Solicitor
-~Knupp and Andrevs P.O. Box ?
-President's Co---4 ssion on the Harrisburg, Pennsylv:mia 17108
Accident at Three Mile Island Mrs. Barbara J. HeivLy
-15 Redwood Building Eashington, D.C.
20037 Middleto.n, Pennsylv= min 17057
-.Mr. Thenas Gerusky
~-Bureau of Radiation Protection' Dr. Walter E. Jordan
.,-881 West Outer Drive
-Department of Invironnental Resources Oak Ridge,'renne.ssee 37830 P.O. Box 2063
-.Earrisburg, Pennsylvania 17120 Dr. Linda W. Little 5000 Her=itage Drive Ivan W. S=ith, Isq. , Chair =an a 27612 Ato_-ic Safety and Licensing Board Raleigh, { orth Car
_,__ _I U.S. Nuclear Regulatory Ce
'=sion Mr. John E. Minnich
$Washington, D.C. 20555 .
Dauphin County Board of
- !: Ms. Frieda Berryhill- - -Comissioners f-, Ccalition for Nuclear Power Plant Dauphin County Courthouse ,s4 Postpone:ent Front and Market Streets
.;'$2 2610 Grendon Drive- Harrisburg; Pennsylvania-17iO1---
-.-i:4 Wilmington, DE 19808 1312//6*-J rdan D. Cunningham, Esq.
DN Hs. Holly S. Keck
-Fox, Farr and Cunningham
.(.I Legislation Chair =an
-2320 North Second Street.g: NY 9.em ania M f 2t.5 West Philadciphia Street i Tork. Pe=ns71vania 17404 - - - .
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