ML20023D631
| ML20023D631 | |
| Person / Time | |
|---|---|
| Site: | Midland |
| Issue date: | 05/23/1983 |
| From: | Sinclair M SINCLAIR, M.P. |
| To: | NRC OFFICE OF THE SECRETARY (SECY) |
| References | |
| NUDOCS 8305250215 | |
| Download: ML20023D631 (2) | |
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5178351303 DOM TDBN MIDLAND MI 522 05-23 0251P EST TWX 7108240412 NRC-BHD WSH USNUCREO 3737 USNUCREO ATTN SECRETARY OF DOCKETINO AND SERVICES THIS IS IN THE MATTER OF CONSUMERS POWER COMPANY MIDLAND PLANTS UNITS 1 KFTh0-32EAND5 THE DATE IS MAY 23, 1983. THE HEADING IS 2NTERVENOR MARY SINCLAIR'S RESPONSE TO CONSUMER POWER COMPANY'S REVISED MOTION TO REQUIRE SUBMISSION OF CROSS EXAMINATION PLANS DESIONATION OF LEAD INTERVENORS AND ESTABLISHMENT OF TIME LIMITS ON CROSS EXAMINATION.
i IN RESPONSE TO THE POINTS THAT ATTORNEY MICHAEL MILLER HAS RAISED ON
- CROSS EXAMINATION FOR THE EVIDENTIARY HEARINGS BEGINNINO JUNE 1, 1983 AND SUBSEQUENT HEARINOS I HAVE THESE COMMENTS.
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I DO NOT AOREE WITH THE BASIC PREMISE MICHAEL MILLER IS MAKING I.E..
THAT IT IS THE INTERVENORS WHO ARE CONTRIBUTING MOST TO THE EXTENSIVE RECORD OF THIS HEARING.
IF CONSUMER'S POWER COMPANY AND BECHTEL HAD NOT MADE THE GRIEVOUS ERROR IN COMPACTING THE SOIL PROPERLY AT THE MIDLAND SITE THIS PROCEEDING WITH ALL IT'S TIME CONSUMING AND COSTLY ASPECTS WOULD NOT BE NECESSARY.
THE FACT THAT THEY kNOW THE SOIL TO BE COMPACTED PROPERLY AND YET WENT AHEAD TO BUILD 5 SAFETY RELATED BUILDINOS ON IT, HIS SHOCKING PROOF OF WHAT
- LITTLE CONCERN THEY HAVE FOR PUBLIC HEALTH AND SAFETY AND THE BASIC INTEORITY OF THIS PROJECT. THE FACT THAT THE NUCLAR REGULATORY
- COMMISSION WAS AWARE IN 1978 OF THE SOIL COMPACTION PROBLEM AND YET STOOD BY AND ALLOWED CONSUMERS POWER COMPANY TO CONTINUE CONSTRUCTION OF SAFETY RELATED BUILDINGS ON THIS FAULTY SOIL, IS ANOTHER REASON FOR DEEP CONCERN ON THE PART OF CITIZENS. WITH THIS BACKGROUND OF NEOLIGENCE, NO
- ONE SHOULD WONDER WHY THE CITIZENS WHO ARE MAKING THE EXTRAORDINARY
- EFFORT NEEDED TO PARTICIPATE IN THESE HEARINGS SHOULD BE EXAMINING ALL
~ THE ISSUES AS CAREFULLY AS POSSIBLE. AFTER ALL IT WAS CONSUMERS POWER CONPANY THAT CALLED FOR THE HEARINGS IN ORDER TO FORSTALL FURTHER CORRECTIVE ACTION ATTEMPTED BY THE NRC IN THEIR DECEMBER 6, 1979 ORDER.
WHAT SHOULD BE SCRUTINIZED? AS A REAL WASTE OF TIME ARE THE CONSTANT AN LENGTHY OBJECTIONS OF THE COSUMER POWER COMPANY'S ATTORNIES TO ANY SUBSTITUTE ISSUE THAT CITIZEN INTERVEINERS WISH TO RAISE.
IT IS THAT TAHOLE OF WORDS IN THEIR ATTEMPT TO DEFEND THE INDEFENSIBLE THAT IS BURDENING THE RECORD.
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I l-IN RESPONSE TO THE PLAN OFFERED BY THE APPLICANT I HAVE THE FOLLOWINO
- REPLIES.r
)' 01. I WILL ATTEMPT TO FILE, IF POSSIBLE, CROSS EXAMINATION PLANS WITH THE BOARD IN ACCORDANCE WITH THE COMMISSION'S MAY 20. 1981 POLICY
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STATEMENT. IT IS NOT ALWAYS POSSIBLE TO DETERMINE THE DIRECTION THAT i
CROSS EXAMINATION SHALL TAKE HOWEVER. THAT DEPENDS ON THE ANSWERS.
- 2. I EXPECT TO DO MY OWN CROSS-EXAMINATION IN AREAS THAT ARE SEPARATE FROM THOSE COVERED BY OTHER INTERVENORS UNLESS IT APPEARS TO NE THAT THEY HAVE NEGLECTED SIGNIFICANT POINTS.#3. I DO NOT AGREE TO THE ATTEMPT TO LIMIT OR FORECLOSE BARBARA STAMIRIS PARTICIPATION.
C4. I WILL MAKE SOME ATTEMPT TO ESTIMATE THE TIME NEEDED FOR CROSS EXAMINATION, BUT I CAN NOT BE HELD TO THIS TIME FRAME IF THE OBJECTIONS OF THE CONSUMERS' ATTORNIES OR OF THE STAFF ARE SO FREQUENT AND LENGHTHY THAT THE SUBSTANTIVE ISSUES I AM TRYING TO ARRIVE AT ARE MADE DIFFICULT TO OET INTO THE RECORD. RESPECTFULLY SUBMITTO,
MARY SINCLAIR 1502 EST "U
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