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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] |
Text
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co os NRC PUBLIC DOCIDIENT ROOM 4 S
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]D #T Lb UNITED STATES OF AMERICA mNUCLEAR REGULATORY CCMMISSION 4 M+ /!
e 6 Ju e
/
In the Matter cf )
)
METROPOLITAN EDISON COMPANY ) Dceket No. 50-289
) (Restart)
(Three Mile Island Nuclear Station, )
Unit No.1) )
REVISED CONTENTIONS OF THREE MILE ISLAND ALERT INC .
Pursuant to the Board's Memorandum and Order dated September 21, 1979, intervenors were directed to file revised contentions by October 22,1979.
Accordingly, Three Mile Island Alert Inc. (TMIA) files the following contentions.
REVISED CONTENTION 1.
It is contended that the short ters actions proposed by the licensee wG nct adequately protect the members of TMIA, whose tambers live within twenty (20) miles of the Mant, from abnormal and unhealthy additional releases cf radiation.
As a result cf the accident at TMIUnit #2, radicactive gases in excess of permissible limits were released into the atmosphere. These releases incitt.ed:
(a) I-133, which was released cver a thirty-fcur (34) day period following the accident in a*.aounts in excess cf 26.84 Ci; (b) Krypton-88, which, during the first day cf the accident alone, was discharged into the atmosphere in an amount cf 6.lE + 4 Curies; 1302 ?21 7911000C
(c) Xenon releases cf at least 10 million Curies, far in excess of NRC regulations. For mple: 0 r D g[D9 P l i y LU ij (1) Xenon 133M: 170,000 Curies over a ten day period ul t L, (ii) Xenon 135: 1.5 million Curies over a seven (7) day pericd (iii) Xenon 135M: 140,000 Curdes over a three (3) day period Other radioactive gases released as a result cf the accident at Unit #2 include Rutheniuim - 103, - 106; Tritium; and Bremine -82, -83, -84, -85.
These releases will have Icnq term health effects on ther members of TMIA.
If TMI Unit #1 were to be recpened, the adverse health effects to the members of TMIA would be magnified since Unit #1 will release additional amcunts cf radiation into the environment. Since radiation affects the bcdy in a cumulative manner, the additional releases frem Unit #1 will have a direct adverse health effect on the members cf TMIA.
In addition,' the cleanup cf Unit #2 will undcubtedly result in both planned and unplanned discharges of radiation into the environment. Since the members cf TMIA have already received desages cf radiation far in excess cf that which would have been received had there been no accident,the cumulative effect as described above may ultimately cause sickness ar d death to scme members of TMIA.
It is contended that the short term acticns proposed by licensee do not adequately deal with this problem.
1302 325
-1
b REVISED CONTENTION 2.
TMIA contends that the additional low-level radiological discharges from Unit #1, in addition to these high-level discharges that have and will be discharged as a result of the TML accident, will have a sigr* ant adverse effect on the water quality in the Susquehanna. During decontaminatien, there exists the real possibility of discharges of radicactive wastewater into the Susquehanna. Even if decontamination is done acccrding to present plan, the system, Epicere II, cannet recove radicactive tritium frem the decentaminated water. This tritium will be discharged into the Susquehanna River. If Unit #1 were to reopen while decentamination cf Unit #2 was continuing, additional discharges of radiation into the Susquehanna will occur. Radioactive releases into the river as a result of the accident at TMI #2, have resulted in presently ascertainable damage to the fish and wildlife in and around the river, thereby increasing the probability of radiation in the feed chain. Therefore, it is contended that no consideration be given to reopening Unit #1 until 'I?.fI Unit #2 is decontaminated to pre-March 23, 1979, levels, and the effects cf the accident and subsequent decontaminaticn on the water quality in the river have been thoroughly analy::ed.
REVISED CONTENTION 3.
It is contended that if Unit #1 is reopened, fear cf another Unit #2 type accident will cause mental health problems, in varying degrees, to many pecple living near the plant. This fear will also adversely affect the ecenemy cf the region because empicyees will be absent from work due to mental anxiety, pecple 1302 526
willleave thee jobs and =cve from the area, and new businesses will refuse to locate in the area. It is contended, therefore that the health and economic consequences brought about by the fear and anxiety which wi!!
cccur, and increase, if Unit #1 is reopened, cutweigh the benefits that will be obtained thereby.
REVISED CONTENTION 4.
It is contended that if Unit # 1 is reopened many people from all over the country will be fearful and angry. Many cf these people will ccme to Middletown and attempt to keep Unit #1 closed by using both vicJent and non-violent means. As a result, censiderable civil disruption will occur in the area surrounding the plant. Lccal and State authorities are not presently equipped to deal with the types of civil disruptions that may very well occur.
it is contended that the additional costs which will have to be incurred by the State and the local municipalities involved, in order *a deal with the civil disruptions, have not been evaluated at all. Furthermorez it is contended that this disruption, added to a crippled #2 reactor that will be contaminated with highly radicactive matcrial for years to come, is an unreascnable and unacceptable cost nct outweighed by the benefits of reopening Unit #1. The short term actions proposed by the licensee do not deal with this eventuality.
797 002 e 1
m
w b.. .=a REVISED CONTENTION 5.
It is contended that Met-Ed has negligently. and on occasion, willfully viciated NRC regulations concerning the safe operaticn cf both Units #1 and #2, in that it has deferred necessary maintenance and repairs in order to minimize reactor downtime, to the detriment cf the integrity of the nuchar facility itself. The licensee has, in the past, allowed work orders to go undene in order to avoid shutting Unit A down to perform necessary maintenance. The licensee would allcw werk crders to pile up unul refueling, at which time Se licensee wculd attempt to do all the work required. Just to ccmplete essential maintenance in the short time available, employees were worked to a point where they were no longer effective because cf fatigue. These actions, and actions cf this t'ipe, reflect negatively upon the ability of the licensee to safely operate c nuclear facility.
Ccnsequently, it is centended that Met-Ed is incapable of safely operating TMI A and that its operating license should be reveked permanently.
REVISED CONTENTION 6 It is contended that Met-Ed dces not have the financial capability to:
(1) comply with technical changes that may be demanded as a result cf the accident at Unit 42, and (2) comply with requiations cf the NRC requiring the expenditure of additional sums cf =cney either fcr mandated design changes or changes in the financial protecticn requirements of ICCFR Part 140.
1302 52'i
D D^]f oo %]N@h_$~
6th nk, Because cf the I!censee's problems with Unit #2, it has been unable to meet its energy obligations to the PD1 interconnect. As a consequence, the licensee's deferred energy balance owed PIM may very well exceed its t'ert term debt by February,1980. If this occurs, the licensee's ability to borrow money will cease, and thereis the real possibility cf the licensee going bankrupt. It is centended, therefore, that the licensee does not presently, or for the foreseeable future, have the financial requirements necessary to operate a nucicar facility.
REVISED CONTENTION 7.
It is contended that the licensee will be unable to adequately deal with a design basis accident cf class one through eight if one should cccur at Unit # 1 while decentamination continues at Unit #2. The Unit #2 containment building and vessel today hcuse in excess cf half a million gallens of highly contaminated wastewatir, and another 250,000 gallons are stored in auxiliary storage buildings on the island. Presently, there is no approved timetable for the safe decontamination of Unit #2. It is centended that the wastewater storage capability cf Unit 4 if an accident were to occur, wculd be insufficient , since a large portion cf this capacity may ult' anately be ccmmitted to the safe decontaminaticn cf U:3t #2. Furthermore, even if no accident should cccur at Unit #1 there is a possibility of an accident cccurring at Unit
- 2 during decontamination which wculd result in the diversicn of all Unit #1 storage capacity to U-it #2, thereby leaving Unit a unable to cope with any 1302 329
type of accident that would produce abnormal an.mnts cf radicactive wastewater.
If an accident of the magninide of that which occurred at Unit #2 were to occur at Unit #1, wastewater stcrage facilities at Unit #2 wculd have to be borrowed, just as Unit #1 facilities have been borrowed to deal with the accident at Unit #2. Since there is presently insufficient storage capacity on the island to deal with a Unit #2 accident at Unit #1 it is an unreasonable and unacceptable risk to the public health and safety to reopen Unit #1 until Unit #2 has been safely deconta=1:ated. The short term acticns preposed by the licensee do not adequately deal with the scanaries described herein.
REVISED CONTENTION 8.
The invcivement cf the NRC in any decision to restart Unit #1 is critical.
The plant cannot recped without NRC approval. There can be no reasonable basis to deny that sucn wtions are covered by the National Environmental Policy and it is centended therefore, that a decision to reopen Unit #1 is a major federal action significantly affecting the quality of the human environment.
Accordingly, it is contended that an environmental impact statement must be filed prior to restarting Unit #1.
The FES must consider, among other things, the socio-ecencmic ccsts of 1302 330
reopening the plant versus the benefits; whether the plant is necessary to the energy needs of the licensee's customers; and, finally, the costs of converting Unit No. I to a coal-fired plant.
Respectfully submitted, Three Mile Island Alert Inc.
By: Me c /
Thecdore A. Adler, Esquire Wideff Reager Selkcwit:: & Adler Post Office Box 1547 Harrisburg, Pa.17105
- Telephone: (717) 763-1383 1302 ';31
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION
)
In the Matter of )
)
METROPOLITAN EDISON COMPANY ) Decket No. 50-289
) (Restart)
(Three MileIsland Nuclear )
Station, Unit No.1) )
)
CER"'IFICATE OF SERVICE I hereby certify that ccpies of Revised Contentions of TMIA, 20.
dated 22 Cctober 1979 have been served upon the fc11owing by deposit in the United States mail, postage prepaid, this 22nd day cf October,1979:
Ivan W. Smith, Esquire C hief, Chairman Docketing and Service m Atcmic Safety and Licensing Section Board Panel Office cf the Secritary p ,pg g U.S. Nuclear Regulatory -
U.S. Nuclear Regulatory % T# y, Commission Commission ,
Washington, D.C. 20555 Washington, D.C . 20555 gg %g$1g$
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