ML20069D509

Requests ASLB Direct Pj Amico,Independent Consultant to Aslb,To File Complete Resume.Amico 830301 Ltr Raises Questions of Independence Which Must Be Resolved

ML20069D509
Person / Time
Site:	Indian Point
Issue date:	03/14/1983
From:	Weiss E UNION OF CONCERNED SCIENTISTS
To:	Gleason J, Paris O, Shon F Atomic Safety and Licensing Board Panel
References
NUDOCS 8303180393
Download: ML20069D509 (3)

Text

. ..

I 1

1

e----

[Jnion of Comcensso 'a3 m ie an :og ScismrisTs *

.iG.

m ,

i March 14, 1983 l

l James P. Gleason, Chairman l Frederick J. Shon, Member Oscar H. Paris, Member Atomic Safety and Licensing Board U.S. Nuclear Regulatory Commission Washington, D.C. 20555 RE: Indian Point Special Proceeding Docket Nos.50-24V, 286 Gentlemen:

We have just received a copy of a letter sent to you from Paul J. Amico, a copy of which is attached. Mr. Amico has been hired by the Board to review ~the evidence in this record concern-ing accident probabilities for Indian Point and to make recommen-dations with regard to its " completeness."

Mr. Amico writes to " clarify" and " document" his independence from issues relating to the Indian Point Probabilistic Safety Study. The language used in his letter raises questions which we believed must be resolved before one could conclude that Mr.

Amico brings the requisite independence to this assignment. In particular, we are concerned about the notable qualifications con-tained in two statements. First, he writes that he was not "in-volved in any meetings with [ Con ED or PASNY) during which discus-sions were held of the IPPSS results or strategy regarding the use g of IPPSS during these hearings." This raises the obvious question

' of whether Mr. Amico has had any relationship with Con ED or PASNY (or the NRC Staff) and, if so, its precise nature.

The second general area of concern is Mr. Amico's statement that he knows some of the witnesses "quite well" and has " worked closely with some of them in the past." The parties are entitled to know the precise nature of Mr. Amico's relationship with any witnesses in this case.

8303180393 830314 PDR ADOCK 05000247 PDR 0

1384 Massachusetts Avenue

• Cambridge, Massachusetts 02233

• Tel. (617) 547 5552 1346 Connecticut Avenue, N.W.

• Suite 1105

• Washington, D.C. 20036

• Tel. (202) 296 5G00

.s Ltr. to Judges Gleason, Shon, & Paris, March 14, 1983 Page 2 We therefore request that the Board direct Mr. Amico to file a complete resume, stating his past work experience, whether he has testified in any forum on related subjects, and including a full discussion of any current or past relationship with Con ED, PASNY or the NRC Staff. In addition, Mr. Amico should be directed to state which witnesses he has worked with and the nature of the projects involved.

The above information is necessary in order for the parties and the Board to evaluate the degree of independence Mr. Amico brings to his evaluation of the evidence in this case.

Ver truly yours,

u Ellyn R. Weiss Jeffrey M. Blum Counsel for the Union of Concerned Scientists

Enclosure:

As stated cc: Indian Point Service List b

1

+

9 jD Applied Risk Technology Corporation P.O. Box 175. Columbia, MD 21045 (301) 964 3769

% g {^ d/

March 1, 1983

'83 WR 10 mo:25 James P. Gleason, Esq., Chairman Mr. Frederick J. Shon . ; . ,7 , . ,

Dr. Oscar H. Paris L A 3Et M d

Administrative Judges Atomic Safety and Licensing Board U.S. Nuclear Regulatory Commissinn

,hd Washington, D.C. 20555 . .. .

..-- . . v .- m -. . , ,

Dear Administrative Judges:

As requested, I am writing this letter to clarify and document my independence from issues relating to the Indian Point Probabilistic Safety Study (IPPSS) prior to being engaged by the ASLB as a technical consultant. Specifically, I wish to assure you of my independence in four areas.

1) At no time vas I involved in either the IPPSS work itself or in any of the NRC staff or intervenor reviews of the IPPSS.

2) At no time was I involved in the analysis or preparation of NUREG/CR-2497, generally known as the precursor study.

3) At no time was I involved in any meetings with representatives of Consolidated Edison or the Power Authority of the State of New York during which discussions were held of the IPPSS results or

^

strategy regarding the use of the IPPSS during these hearings.

4) I have reviewed the list of witnesses and, although I know some of them quite well and have worked closely with some of them in the past, I am not now involved in any work with them and hold no bias with regard to critiquing any of their testimony.

I declare the above statements to be true and would be willing to submit them as sworn testimony at any time if the board feels it to be necessary.

b Sincerely, ,

,-Q;Lg/L N ul g M co PJA/dba I

I e

. . _ . . _ .