ML20076J094

Responds to P Amico Rept Re Recommendations for Addl Testimony on Pra.Reopening Record on PRA Would Unduly Prolong Proceeding

ML20076J094
Person / Time
Site:	Indian Point
Issue date:	06/10/1983
From:	Hartzman R FRIENDS OF THE EARTH, NEW YORK CITY AUDUBON SOCIETY
To:	Gleason J, Paris O, Shon F Atomic Safety and Licensing Board Panel
References
NUDOCS 8306200324
Download: ML20076J094 (2)

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FRI E N DS OF T H E E A RT H 2o.westi,6sraver.shw vo. stwvoax@ik. E 1,s ii X Qlh a

Jun 10, f983 fNS a

ci James P. Gleason, Esq. Chairman Dr. Oscar.H. Paris Administrative Judge Administrative Judge 513 Gilmore Drive' Atomic Safety and Licensing Silver Springs, MD 20901 Board U.S. Nuclear Regulatory Mr. Frederick J. Shon Commission Administrative Judge Washington, D.C.

20555 Atomic Safety and Licensing Board U'.S. Nuclear Regulatory Commission Washington, D.C.

20555

<} g In the Matter of Consolidated Edison Company of New York Indian Point, Unit 2 Power Authority of the State of New York Indian Point, Unit 3

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Dear Administrative Judges:

This letter is in response to the May 2, 1983 letter report of Paul Amico, concerning his recommendations for additional testimony with respect to PRA.

FOE /Audubon sees no reason to reopen the evidence on PRA, a step that would unduly prolong this proceeding.

Although Mr. Amico's suggestions might be of academic interest, the additional information is unnecessary for the ASLB's determination and conclusions.

His proposals offer nothing that would eliminate the fundamental arbitrariness, uncertainty and incompleteness which permeate both the IPPSS and NRC Staff PRA estimates.

Nor do his recommendations even cover the full range of defects in the Indian Point PRA estimates identified in the hearing record.

For example, no recommendation is made regarding the systems interaction issue or the method of calculation suggested by Dr. Levi.

But even if these matters were added to Mr. Amico's list. of recommendations, there is no reason to believe that there would be adequate bottom line estimates of risk resulting from the PRA analysis.

Mr. Amico's efforts simply confirm our contentions about the basic inadequacy of PRA.

What has been learned from the tremendous amount of time, effort and money invested in PRA is its inability to provide reliable and trustworthy estimates of nuclear plant 8306200324 830610

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y risks.

Far too much attention has already been placed on it.

The ASLB must come to terms with the gaps, the uncer-

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tainties and arbitrariness of PRA in reaching its conclusions.

The additional testimony recommended by Mr. Amico will not eliminate this need and will only serve to unnecessarily g

prolong the hearing.

We therefore oppose the reopening of the evidence for additional testimony o n Commission Question 1 and related Board Contentions and Questions.

Si cerely yours,

)Yf-Richard M. Hartzman, Esq.

Crunsel for FOE /Audubon cc:

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