ML20035B511
| ML20035B511 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 03/25/1993 |
| From: | Dow R AFFILIATION NOT ASSIGNED |
| To: | NRC COMMISSION (OCM) |
| Shared Package | |
| ML20035B512 | List: |
| References | |
| CON-#293-13798 CPA, NUDOCS 9304020101 | |
| Download: ML20035B511 (4) | |
Text
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. 03-25-1993 '11:45AM FROM ACCU-PRINT S17-573-0353 TO 13015041672.
P 02 :
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UNITED STATES OF AMERICA ~
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NUCLEAR REGULATORY COMMISSION COMMISSIONERS:
'93 Wa 26 AS 25 Ivan Selin. Chairman j
Kenneth C. Rogers j
James R. curtiss i
Forrest 3.
Remick E. Gail de Planque 3
}
- n the Matter of:
)
TEXAS UTILITES ELECTRIC
)
COMcANY. et al.
)
Occhet Nos. 50-446. 50-446-CPA
)
i
( Cama nc hc-Peak Steam
)
Electric Station. Unit 2 )
)
)
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l MOTION FOR LEAVE TO FILE OUT-OF-TIME
'l SY oETITIONER R.
MICKY DOW i'
Comes now. R. Micky Dow. cetitioner and movant. as well as representative for Ron Jones, Yvonne Wil ki nso n,
anc
- othere, i
r nereinafter movant, and files this, his Motion For Leave To File I
Out-Of-Time. and for cause would sr.ow that:
i 1.
t Your movant was aware of Petitioners' Motion To Stay 4
Issuance of _icense, but felt tnat responsive pleadings already l
F on file would be sufficient with regard to a showing of support i
s for any manner of stay was concernec.
l Movant. however. receivec. by regular U.S. Mail, a cleading l
entitled Cace 's Motion For Leave o File Response And Case's i
Response to Portions of Petitioners' Motion To S'ay Issuance of L
Full Power License. and.
as the cleading was produced March 22.
i 1993. it was.
quita naturally, received out-of-time.
- eecause, r
however. a great deal cf time and space was spent on this movant i
DQ,W Q
fiQlI_ON FOR LEAVE TO FILE OUT-OF-TIME BY R.
MICKY 1
3 I
9304020101 930325
)
PDR ADOCK 05000446 O
03-25-1993 11WA1 -FROM ACCU-PRINT 817-573-0053-
.TO 13015041672 P.03 and the organization he is an officer of, and. therefore, movant
-f
?
I faels thAre, now, asists-a naad, and certainly a rignt, for a-response, to this Pleading.-
ll 1
II.
a
- nstead of cuoting Twain.
CASE would be better to become
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more mindful of Shakespere.
who.
In.rulius
- ceaser, stated
" Methinks thou dotn Drotest too mucn!*,
a more fitting : a ted f
~
acroccs statment.
This movant could care less how much money, the method, the I
means. the direction. or the result. that CASE might or might not t
have received frcm the acclicant, that. is " kicking a dead horse"
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t 5
and totally immaterial for the pvpuded of what is present before
]
I the Commission at thic time.
7 What IS present before the Commission are multiple motions l
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fcr leave to intervene, and, in some menner prevent the extension i
of the construction permit on Unit 2. and now that the Commission has usuroec constitutional guarantees and granted the extension
. l t
anyway, there are cleadings in place to stay the granting of a l
full-power license.
The reason for all that litigation is that
[
i there still are ollegations and contentions with regard to the
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construction und defety violations on the-Unit i portion.
which
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i the RECORD WILL SHOW were withdrawn, and the list of current i
allegations and contentions will support the fact that Unit 2 is also unsafe, eno substandard in its construction.
3 F
10 1/2 Million Dollars won't fix that, or change that; j
r.either will "does it exist, or who got it, or where is it";-but, I
MOTION FOR LEAVE TO FILE OUT-OF-TIME BY A.
MICKY DOW.l 1
t
03-25-1993 11'46AM FROM. ACCU-PRINT 817-573-0053 TO 13015041672 P.04 ~
-r E
WHAT WILL WORK, WHAT SHOULD HAPCE.N, is Due Process, the filing of h
allegations, the investigation into those contentions, the hearings process in order to corroborate those contentions, and,
[
i then.
adjudication on the merite.
It is imperativo for all i
remember a,d understand that while this utility is carties to laughing at this ludicrous showing of bickering over a SECRET l
SETTLEMENT AGREEMENT, they are, ever to slowly easing through the t
r system with a catastrophe both in its tragic ultimate result.
l f
but, also, in rne 20 Eillion
+ cost over-run, and the ucurious t
rate increases that these characterless, and incomoetent applicants intend on sticking the oublic at larse with, while tney glean nothing save crofit. and some bad press, both being nothing but wrinkled cacer.
}
WHEREFORE, PREMISES CONSIDERED, and, in view of the fact that the pleading, the subject of this motion, was not received l
by movant until after time had expired, and that, oc much of it i
concerr.s this movant; he be allowed to file his response out-of-time.
_n the i nteT ed'. of justice.
Rescectfully submitted.
l
\\.t R.
MICKY COW, cro se 506 Mountain View Estates Gr u nbu r y. Temas 76046 (017) 575-0923 r
Movant
(
1 s
1 s
t MOTION FOG LEAVE TO F I LE____OUT - OF - T I M E QY R _MICKY DOW '
3
- _ ~.
l 03-25-1993 li:46At1 FROM ACCU-PRINT 817-573-0053 TO 13015041672 P.05
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CERTIFICATE OF SERVICE This is to certify that a true and correct copy o'93 #F! 26 A9:Cl I
t t
foregoing was, this 25tn day of Maren, 1993, telefaxed.to the-
,. v
. ;.f Office of the General Counsei for the NRC. anc, to the offices"of j
1 George L. Edgar. attorney for acclicant, with a true and correct 1
copy being mailed. by regular First Class mail,.to the parties h
listed below.
i
\\.
R.
MICKY DOW, hffiant f
l e
Emile Julian Charles A. Mullins, Escuire Docketing Section Of# ice of the General Counsel U.S.
Nuclear Regulatory Comm.
U.S. Nuclear Regulatory Comm.
11555 P.ock Pike 11555 Roch Pike Rockville. Marylard 20852 Rockville. Maryland 20852 i
George L.
Edgar Mike Kohn Newman & Holtzinger Nonn. Kohn & Calapinto 1615 L.
- Street, N.W.
517 Florida..N.W.
Washiripton, D.C. 20036 Washi ngt on,
D.C.
20001 i
I Juanita Ellis Robert A.
Wooldridge Citizens Association for Wctsham, Forsyt he, Sarnpels Sound Energy
& Woolcridge i
1426 5. Polh 2001 Bryan Tower, Suite 3200 Dallas. Texas 75224 Dalles, Texas 75201 i
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