ML19336A566
| ML19336A566 | |
| Person / Time | |
|---|---|
| Site: | 07001308 |
| Issue date: | 10/24/1980 |
| From: | Rorem B AFFILIATION NOT ASSIGNED |
| To: | Atomic Safety and Licensing Board Panel |
| References | |
| NUDOCS 8010300084 | |
| Download: ML19336A566 (5) | |
Text
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24 Octob2r 198 c4 Il~
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UNITED STATES OF AMERICA coh"'?: 3 NUCLEAR REGULATCRY COMMISSION
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BEFORE THE ATOMIC SAFETY AND LICENSING BOARD 7p 4
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6 kn the Matter of
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GENERAL ELECTRIC CCMPANY
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Docket No. 70-1308 Renewal of Materials License
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No. _ N-1265 issued to G.E.
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Morr:.s Operation Fuel Storage
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Installation
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RES?ONSE OF ROREM ET AL. TO MCTION OF G.E.
TO DISMISS ROREM ET AL. AS INTERVENOR Rorem dt al.,
intervenors,'do not wish to be dismissed as a party to the intervention.
They have been struggling to complete the interrogatories propounded by G.E. and by the NRC staff.
They would like to remind the Atomic Safety and Licensing Board that, of all the parties to this proceeding, they alone are not b1ing paid for participation in it.
They are not lawyers for a large corporation.
They are not lawyers for a federal agency, paid for by pub-lic tax money.
They are not lawyers for a state office.
They are not, as other parties have pointed out, lawyers.
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e Consequently, they are not only not funded to participate in this intervention, but also lack the research
- aff, copying machines, typists, and time with which to work at the required speed.
They, quite frankly, lack the financial resources to comply with some of the demands of both G.E.and the NRC staff.
It was, no doubt, with an awareness of this lack that G.E.
requested of them copies of all of the materials they used in formation of contentions.
They had already made it clear in both their amended contentions and re-amended contentions that they were not financially able to supply these mater-ials.
They have been unable to find expert witnesses who are willing to testify at minimal cost, particularly since they are not able to supply any information as to when hearings are likely to take place.
Furthermore, they are upset at two clai=s which G.E. nakes:
one, that Rorem et al. have contributed nothing to the reli-censing but delays.
They would like to remind the Board that most of the delays have been on the part of the NRC staf f due to procedural changes and changes within the Cetmission.
Further, the language and content o f two
. contentions are largely those of Rorem et al.
They also contributed their insistence that the hearings take place near the site of the G.E. Morris Operation.
Secondly, G.E. claims that Rorem et al. shows a lack of interest by not being in attendance when depositions are taken.
This is not only untrue, but it is unfair to make such an allegation.
Intervenors have fmmilies, and jobs, are far from the places in which the depositions are being taken, and are not paid for time and expenses to attend such occasions.
Intervenors feel that it is already made extremely difficult for citizens to involve themselves in the licensing or re-licensing process.
A citizen who wishes to participate must first of all have access to, and read,the Federal Register.
H,e must file, on time, and in the proper format, a petition for leave to intervene.
He must have access
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to the information as to how this is to be done properly, or he must have the financial means to hire the services of a lawyer.
If he does not have the money to hire a lawyer, he must be able to pay the costs of paper, reprinting, costage, phone, gas, and child-care in order to participate.
- As the only indis% al citizen participants, intervenors wish to continue As this proceeding aven if they ara only able to cross-examine t2ose witnesses presented by the cther parties.
In addition, the new regulation, 10 CFR Part 72, may influence the Safety Evaluation Report and may therefore influence the contentions accepted by the Board.
If the Board is willing, intervenors will file immediately their answers to the interrogatories propounded both by the NRC staff and by G.E.,
insofar as they are cumplete at this time.
Respectfully submitted, I
SW dof& Yu kwg, dridgy Little Rorem
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UNITED STATES OF AMERICA S
NUCLEAR REGULATORY CCMMISSION
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GENERAL ELECTRIC COMPANY
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Docket No. 70-1308 Renewal of Materials License
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No. SNM-1265 issued to G.E.
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Morris Operation Fuel Storage
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Installation
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I have sent of G.E. to Dismiss Rorem etcopies of " Response of Rorem et al. to Motion following, having mailed them from the U.S. Postal. as Intervenor" to the in Kankakee, Office Illinois, on the afternoon of 24 October 1980:
Andrew C. Goodhope, Esq.,
Chairman Susan N. Sekuler, Esq.
George William Wolff, Esq.
Atomic Safety and Licensing Board Office of the Attorney General 3320 Estelle Terrace 188 West Randolph Street Wheaton, Maryland 20906 Suite 2315 Chicago IL 60601 Dr. Linda N. Little Atomic Safety and Licensing Atomic Safety and Licensing Board Board Panel U.S. Nu lear Regulatory 5000 Hermitage Drive c
No th Carolina 27612 Commission
- Raleich, r
Washington, D.C. 20555 Dr. Forrest J. Remick Atomic Safety and Licensing Atomic Safety and Licensing Board Appeal Panel 305 East Hamilton Avenue U.S. Nuclear' Regulatory State College, Pennsylvania Commission Washington, D.C.
20555 16801 Ronald Srwajkowski Esq.
Marjorie Ulman Rothschild, Esq.
Matthew A. Rooney,,Esq.
United States Nuclear Regulatory Conmission Mayer, Brown & Platt 231 South LaSalle Street Washington, D.C. 20555 Chicago IL 60604 Everett J. Quigley Docketing and Service Section R.R. 1 Box 378 Office of the Secretary Kankakee IL 60901 U.S. Nuclear Regulatory Commission Washington, D.C. 20555
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