ML20031C552
| ML20031C552 | |
| Person / Time | |
|---|---|
| Site: | Big Rock Point File:Consumers Energy icon.png |
| Issue date: | 10/09/1981 |
| From: | Oneill J O'NEILL, J. |
| To: | |
| References | |
| NUDOCS 8110070282 | |
| Download: ML20031C552 (1) | |
Text
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Unitcd State of America Ut. clear Rom 1atory Cornmission S
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Docket No.
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I urget the Board to N d.M Yur.ers Power the requested protective order and to homnel it to resncnu to the interreratories filed by Christa-Maria and friends and not subsequently withdc we in their MCTICH TO-CCMPEL ANS'.nX T: TNTERRCCATCRIES AND RLSt ( 53E TC LICENSEL:.i MOTICH FOR A PRCTECTIVE DRDER. of Sent 1R,
- 791. I'd like to express ry astonishment at the nility's unwillinaness to answer any of these interregatories.
A reply to these queries is essential to developing a full record.
These adnissable questions were not answered satisfactorily in C.P's untimely renlies to Christa-Maria's two t arlier interroFatories.
It has been well poi: ted out thrit the method or answerb g the ouestions was the major factor in the tining of intervenors'. Interrogatories of August 31, 1081.
I also urge the Board to compel the URC Staff to answer Christa-Maria's Interrogatories of Aur,ust 31, 1991.
Intervenors' i nterrogatori es are submitted to help develop a full reccrd, and an unwilline Staff sometimes nust be compelled to fulfi'! i to duty to the public.
I Several original Cor.tentionc of bo th O'%111 and Chr sta-l Maria were withdrawn at the Special FreHearine Conference of December 5,1979 pen'iirg discovery.
The right of Christa-Maria to submit contentions and reintrnduce contentions was acknowledged by the Board in its order of January 17, 1980 These would be based upon facts uncovered in discovery.
To expidite the proceedirg, some contentions that the intervienors Christa-Maria will have a right to introduce following URC Staff and C.'.'s responses to the last wt of interrogatories were nubmitted S3ptember h, 1981.
The interrarato"ies are also based upon facts already revealed.
Ahitting these contentions now is tc everyone's advantage because it will svold the delay of waitirg for resnonses to the August oth Interrogate 'os.
I urge the Board to admit Christa-Maria's Contentiens of September 4,1091.
There are issues o c suh.ltance here that are of vital importance to public health and safety.
Por exannle, the Pe tosky News Review of September 31, 1981, and the Charlevoix Courier of Sentember 30, 1981 report of two fus1 pool drain isolation valves tb tt exceeded the criteria for leakage rates during n t.est. on Septenicer 19 These valves to recycle nool water when waste is removed, and to relieve e.v y c reactor nressur: Curing plant start-un.
No incident report is yet availab2e.
I strongly urge the Eoard to Fulfil it-responsibility to protect public health and safety, and admit the above mentioned Interrogntories and Contentions to nake sure any rool nodification is safe.
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,Q 8110070282 811009-aineerely.
y DRADOCK050 cog 5 g[
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J hn O'Neill II Pro se Dated: October 1, 1981 Please admit this motion if it is cut of time.
Any delay can be laid upon the shoulders of my daughter Erin Kathleen, who entered thin worla bst1Hn. kukmL= '"
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