ML19341B434
| ML19341B434 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 01/21/1981 |
| From: | Adler R PENNSYLVANIA, COMMONWEALTH OF |
| To: | Atomic Safety and Licensing Board Panel |
| References | |
| NUDOCS 8102020191 | |
| Download: ML19341B434 (6) | |
Text
,1) !i c I e iIFs C
UNI'IED STAES OF AMERICA m
NUGIAR REG'u'ICRY 01 MISSION tem-u EEFCRE EE A'IGIC SAFEIY AND LICE 3EU BOARD N>
otrmte,4 j
In the Matter of
)
% '3cfSe e
~
)
MEIRoPOLITAN EDISON CUEANY,
)
gw
)
Docket No. 50-289
('Ihree Mile Island Nuclear
)
(Restart) sy Station, thit No.1)
)
p' F p.t 5
- y A
lh CntDNiEALE OF PD23YLVANIA'S PCSlTICN E.
REPORT ON ISSUES PENDEU E EE PROCEEDHU-E, l 2 7 7987 h.
~. 3 *
- E **u T ^' "
At the January 14, 1981 sessicn of the evidentiary ba/ g, the J
n Board requested a report one14nMg those ret:nirb.g issues that Ccesealth feels %2rrant srcisl attention. 'Ihis position report responds to the Board's request.
Pe=sylvania's basic positions on cententiens were stated in the "Cumsealth of Pemsylvania's Feport en Positiens Femlated Based ca Infer::ntien Avn41nble as of July 25, 1980." thfort=ately, some of the cententiens en which the C-eealth adcpted a positica have been withdrawn from the proceeding. But it is i= perative that the Board not neglect i=portant safety issues due to the lack of intervenor resorces.
'Iherefore, the Cu.waalth urges the Board to give full consideration to the following issues:
1)
Class 9 Accidents: Despite the withdrawal of all Class 9 cententicas, the Board has elected to pursue UCS 13.
Pe=sylvania encourages the Board's cc:plete evaluatica of this issue. Althcugh Pe=sylvania originally stated that the specific scenaries set forth in Sholly 17 and ECNP 4 should be addressed, it is now felt that tFa generic analysis called for in UCS 13 will satisfactorily'enec= pass these concerns. As stated in Pe msylvania's July Positicn Report, "a reevluation in light of the EI-2 accident of the NRC's method of dete=ining which possible accWnts fall within the cesign basis is necessary to provide a reasonable assurance that a Class 9 accident will not occur at M-1."
~Id. at 4.
Q0$
.S oj s.10 2on o IM
2)
Radiation Mcnitoring: "It must be denonstrated tbt the inadequacies in Licensee's management of radiation conitoring during the M-2 accident will not be repeated at M-1."
Id. at 5.
Accordingly, Pennsylvania fully supports AIGY's
~cotion to adopt Shally 9,* without which the offsite radiation conitoring issue may not be adequately ad&essed.
3)
M-1/'IMI-2 Seoaration: Pennsylvania wishes to reiterate the positions stated in both the July Position Report and at the January 14, 1981 evfdanHanf session, that both the Staff and the Licensee are obligated to dazonstrate that total offsite radiation doses from the simultaneous operation of 'IMI-l and decontamination of M-2 will not exceed acceptable limits as defined by IRC and EPA regulations. Moreover, it is imperative that this infer::ntion be made available to the public as part of both *he M-2 cla=T and the M-1 restart processes.
It is notable that even the two thmrf asioners who voted to deny the admission of psychological stress contentions mandated that the public be assured that 'IMI-l can be operated safely if permf.tted to restart.
m=4m=n Ahearne wrote that "the best way to decrease such stress is to insure the plant is safe if it is approved for operation.. I believe the IRC (Coccission and staff) cust insure clear and acerate informaticn is provided regarding whac is being done."
(emphasis added). Metropolitan Edison Co., (Three Mile Island thclear Station, lhit 1), CLI-80-39, Deca::cer 5,1980 (Chairman Ahearne's Separate Views at 2). Sinflarly, Cocmissioner Hendrie asserted that "the cost appwg&iate way for the Cocmission to take account of fears related to 'IMI-l is, first, to assure that the technical decision on restart is sound; and second, if the decision is to armi.e restart, to make sure that the public understands, trough accurate and cocorehensible information, fully disseminated, the basis for the Cocmission's deter:nnation that the plant can coerate safely." (ecohasis adced). M. (Separate views or Cor:nassioner Hendrie at 2).
It 1.9 clear from the Board's original ad=ission of 'IMIA Contentions 1 and 2 that the issue of total offsite doses from M-1 and 'IMI-2 is properly within the scope of this proceeding.
'Iherefore, although the Board elected not to litigate these l
issues in a formal sense by deciding not to adopt 'IMIA l
ContanHms 1 and 2, it is nevertheless ira:= bent on the Board l
to assure itself that the aggiopciate total dose analysis is j
performed and that the results are made fully available to the public.
4)
Managenent Issues: 'Ihe Cocr:onwealth has already indicated to the Board its intention to participate in the litigation of all managenent issues with the exception of purely finarmial issues (Items 6 and 12 of the Cocnission's March 6,1980 Order, CLI-80-5). 'Ihe Cocronwealth views the question of Licensee's l
'Ihis is not meant to imply that the Cocuenwealth has any objections to AICRY's cocion to adopt the ram =4ning Sholly contentions. -
maragement co petence to be of particular cencern in 94 proceeding since this is one of 8.e issues (along with plant separation and isolation) which most clearly distinguishes T4I-1 from other operating nuclear pcwer plan s.
Since all intervenors with management cententiens Frie e.cres. sed 6.eir intent to pu* sue these cententicas, the issues rtfised therein should be addressed adequately. In additien, the C - 4 th urges the Board to pursue its policy of hearing live testimeny on all of the CLI-80-5 issues (inc1"M*g Health Physics) that are not ccvered by specific re::aining contentions.
In addition to the issues listed above, the n W th has cutstandL*g its precise to report to the Board regarding the issue of postulated steam generator tube rupture. g.at8046-47. 2 4 Can:enwealth sub:itted to Licensee a series of techtical questiens (by way of infomal discovery). Per:nsylvania's daim on whether to pursue this issue will be based on the responses to these questicas.
Respectfully sub::itted, N
o ROBERT W. MR Assistant Attcrney General c-aalth of Fer:nsylvania O
e.
UNITED STAIES OF AMERICA IUCEAR REGULAIOiG CDFlSSION udunt 'IHE AIUEC SAFEIY AND LICENSING BOARD In the Matter of
)
)
METROPOLITAN EDISON C T PANY,
)
1 Docket Ib. 50-289
('Ihree lif.le Island Ibclear (Restart)
Station, Lhit Ib.1)
)
u.tuuJ.CNIE OF SERVICE' I hereby certify that copies of the attached "c-=1 h of t
Pemsylvania's Position Report on Issues Pending in the Prrv aadh,"
we served, by deposit in the U.S. mail, postage prepaid, on the persons on the attached service list.
/
),
/
ROSEKI W. ADLER Assistant Attorney General Cocr:oruealth of Pemsylvania l
Dated: Januarf 21, 1981
., ~, -,., -
,n.-
n
,-a
,,,,,---,n-
l LhTIED STAIES OF AMERICA NLX22AR RFET.AICRY C3EISSION PEDRE *IEE ATQ4IC SAFETY AND LICESIIC BOARD In the & tter of
)
)
MEIROPOLITAN EDISON CITANY,
)
)
Docket Ib. 50-289 (Three Mile Island Ibclear
)
(Restart)
Station, Lhit Ib.1)
)
SERVIG LIST George F. Tr dridge, Es@e Mr. Steven C. Sholly Shaw, Pittman, Potts & T.W4e niicn of Concerned Scientists 1800 M Street, N.W.
1725 Eye Screet, N.W., Suite 601 i
W shington, D.C. 20006 W shington, D.C.
20006 Ms. Marjorie M. Aamodt Theodore A. Adler, Esquire R.D. #5 Widoff, Reager, Selkcwit: & Adler coatesville, Pennsylvania 19320 P. O. Box 1547 Harrisburg, PemsylvanLa 17105 Ms. Holly S. Keck, Iag. 01airran Anti-Nuclear Gr::.:p Representing Ivan W. Sczi.th, Esquire c
York (.C URY)
CM -=n 4
245 W. Philadciphia Street Atomic Safety and Licensing Board Panel York, Pennsylvania 17404 U.S. tbclear Regulatory rMsion Washirgton, D.C. 20555 C,alition for Nuclear Power Dr. W lter H. Jordan
?lant Postponement Atad.c Safety and Licensing Board Panel 2610 Grendon Drive 881 West Outer Drive Wilmington, Delaware 19808 cak Ridge, Tennessee 37830 Mr. Robert Q. Pollard Dr. Lirda W. Little 609 }batpelier Street Atcx:d.c Safety and Licensing Scard Panel Balti::nre, Maryland 21218 5000 Hermitage Drive Raleigh, North Carolina 27612 W lter W. Cohen, Esquire.
Consumer A h te Docketing and Service Section j
Depart:aent of Justice Office of the Secretary Strawberry Square, 14th Floor U.S. Nuclear Regulatory Cact::ission Harrisburg, Pennsylvania 17127 Washington, D.C. 20555 Dr. Chauncey Kepford Ellyn R. Weiss Judith H. Johnsrud Sheldon, Harmon, Rof an & Weiss Envi:unmental Coaliticxt on Nuclear 1725 I Street, N.W.
Power Suite 506 433 Orlando Avenue W==ht,eton, D.C. 20006 State College, Pennsylvania 16801
.__.,__4.
, ~,
l' i
Karin P. Sheldon, Esq.
(PRE)
Shelden, Ham., Roiman & Weiss 1725 I Street, N.W., Suite 506 Washington, D.C. 20006 Jacas A. Tourtellotte, Esquire Office of the Executive Iagal Director U.S. Nuclear Regulatory en=f-t5 ion Washington, D.C.
20555 John A. Iavin, Esquire Assistant Counsel Pennsylvania Public Utility Cocmission -
P.O. Box 3265 Harrisburg, Pennsylvania 17120 Robert L. Knt=p, Esquire Assistant Solicitor County of NThin P.O. Box P 407 North Front Street Harrisburg, PA 17108 John E. Minnich Chair::nn, Dauphin County Board of Ilmi4sioners Dauphin Courry Courthouse Front and Market Streets Harrisburg, Pennsylvania 17101 Jordan D. Cunningham, Esquire Attorney for Newberry Township T.M.I. Steering Caceittee 2320 North Second Street Har 6 burg, Pennsylvania 17110 Marvin I. Ia # s 6504 Bradford Terrace Philadelphia, Pennsylvania 19149 Jane Ime R.D. 3, Bo:t 3521 j
Etters, Fer.nsylvania 17319 e. _ _.
- -