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Category:LEGAL TRANSCRIPTS & ORDERS & PLEADINGS
MONTHYEARML20056E5101993-08-11011 August 1993 Comment Opposing Proposed Rule 10CFR20 Re Radiological Criteria for Decommissioning ML20059P0531990-10-15015 October 1990 Comment Opposing Proposed Rules 10CFR2,50 & 54 Re Nuclear Power Plant License Renewal IR 05000358/19820101986-06-24024 June 1986 Applicant Exhibit A-49,consisting of Forwarding Partially Withheld Safety Insp Rept 50-358/82-10 on 820607- 0818 (Ref 10CFR2.790) & Notice of Violation ML20129A3751985-05-16016 May 1985 Order Revoking CPPR-88,based on Util 840127 Plan to Convert Facility to Coal Fuel ML20133N3621985-03-14014 March 1985 Unexecuted Amend 3 Terminating Indemnity Agreement B-85 ML20094C3571984-08-0202 August 1984 Transmittal of Info Re Util 840320 Motion for Withdrawal of OL Application.Fuel Removed from Site,Steam Supply Sys Modified & CRD Mechanisms Removed.Certificate of Svc Encl ML20087H7881984-03-20020 March 1984 Motion Requesting Issuance of Order Authorizing Withdrawal of Application.Plant Will Be Used as Part of New Fossil fuel-fired Electric Generating Plant.Certificate of Svc Encl ML20087N2281984-03-0101 March 1984 Endorsement 25 to Nelia Policy NF-249 ML20079F8181984-01-16016 January 1984 Response Opposing Miami Valley Power Project 831231 Proposed Issues & Support for Contentions Re Qa.Issues Not Specific or Litigable.Certificate of Svc Encl ML20083J5321983-12-31031 December 1983 Proposed Issues & Prospective Witnesses Supporting Miami Valley Power Project Proposed Contentions Re Qa,Character & Competence.Certificate of Svc Encl ML20079H6901983-12-14014 December 1983 Petition Per 10CFR2.206 to Defer Judgment or Decision on Proposed Course of Action for Completion of Facility Until Suppl Created for Record of J Keppler 831215 Briefing.W/O Encls ML20082P8501983-12-0606 December 1983 Response Opposing City of Mentor 831115 Memorandum in Support of NRC 831031 Motion to Defer Rulings on Miami Valley Power Project Motion to Reopen Record.Motion W/O Merit.Certificate of Svc Encl.Related Correspondence ML20082M5791983-12-0202 December 1983 Response Opposing Applicant 831115 Answer to NRC 831031 Motion to Defer Ruling on Petition for Reconsideration & Motion for Leave to File Addl Evidence Prior to 831215 Conference of Counsel.Certificate of Svc Encl ML20082L0991983-11-30030 November 1983 Memorandum in Support of City of Mentor Motion to Further Defer Rulings Until Completion of Investigation Into Matl False Statements by NRC & Applicants.Certificate of Svc Encl ML20082D6991983-11-15015 November 1983 Memorandum in Support of NRC Motion to Defer Rulings on Miami Valley Power Project Motion to Reopen & City of Mentor Motion to Further Defer Rulings Until Completion of Investigation.Certificate of Svc Encl ML20081M7951983-11-15015 November 1983 Answer Opposing NRC Motion to Defer Rulings on Miami Valley Power Project (MVPP) 831003 Motion to Reopen Record.Decision Should Not Be Deferred to Await Completion of Investigation. Certificate of Svc Encl ML20085K7841983-10-18018 October 1983 Answer Opposing Miami Valley Power Project 831003 Petition for Reconsideration of ASLB 830915 Memorandum & Order Denying Project Motion to Reopen Record to Admit Eight Late Filed Contentions on Qa.Certificate of Svc Encl ML20078K5621983-10-13013 October 1983 Memorandum in Support of Miami Valley Power Project (MVPP) Petition for Reconsideration of ASLB 830915 Order.Mvpp Urges ASLB to Address Stds for Reopening Record.Issues Should Be Included to Ensure Complete Record.Certificate of Svc Encl ML20078F9641983-10-0606 October 1983 Notification to Commission of Miami Valley Power Project Misrepresentation in 831003 Motion for Reconsideration of ASLB 830915 Order.No Util Counsel Communicated W/Govt Accountability Project.Certificate of Svc Encl ML20078F8891983-10-0606 October 1983 Notice of Jh Laverty Employment W/Conner & Wetterhahn,Pc. Laverty Will Not Participate in Matters Leading to OL Issuance Due to Previous Employment W/Commissioner Roberts. Certificate of Svc Encl ML20078F8751983-10-0606 October 1983 Notice of Jh Laverty Employment W/Conner & Wetterhahn,Pc. Previous Employment W/Commissioner Roberts Eliminates Any Contribution to Zimmer Case ML20080P0771983-10-0303 October 1983 Motion for Extension to File Appeal Until 10 Days After Svc of ASLB Decision on Miami Valley Power Project Petition for Reconsideration.Certificate of Svc Encl ML20080P0141983-10-0303 October 1983 Petition for Reconsideration of ASLB 830915 Order Denying Miami Valley Power Project Motion to Reopen Record for Admission of Eight Proposed Contentions.Addl Info Provided Since Original Decision.Certificate of Svc Encl ML20080P0481983-09-26026 September 1983 Affidavit of T Devine Summarizing 830919 Discussion W/ C Weaver Re Summary of Interview in Torrey Pines Rept. Weaver Seriously Challenges Completeness of Interview Summary ML20080P0291983-09-26026 September 1983 Affidavit of D Jones for Govt Accountability Project Protesting Torrey Pines Rept Chapter on Cases Studies.Ref to Author Interviews Incomplete & Thus Inaccurate.Analysis of Whistleblower Missed Real Problem of Lack of Freedom ML20080P0671983-09-24024 September 1983 Affidavit of R Reiter for Govt Accountability Project Expressing Dissatisfaction of W/Summarized Interview in Torrey Pines Rept ML20080F2451983-09-13013 September 1983 Memorandum Supporting Miami Valley Power Project 830603 Motion to Reopen Record for Admission of Eight Contentions. Torrey Pines Mgt Review & NRC Repts Confirm Project Substantially Correct on Qa.Certificate of Svc Encl ML20080E6921983-09-12012 September 1983 Answer Opposing Miami Valley Power Project 830826 Motion for Leave to Submit New Documents & for ASLB Review of Pending Investigations.Motion Unjustified Attempt to Bend Rules on Late Contentions.W/Certificate of Svc ML20080D2791983-08-26026 August 1983 Motion for Leave to Submit New Evidence in Support of 830603 Proposed Contentions & for ASLB Review of Significant Pending Investigations.Certificate of Svc Encl ML20080C7171983-08-25025 August 1983 Answer Opposing Miami Valley Power Project 830811 Motion for Leave to File Reply Brief to Util & NRC Answers to Project 830712 Motion to Compel Discovery.Project Had Opportunity to Brief Issue in Original Motion.Certificate of Svc Encl ML20076A6451983-08-15015 August 1983 Notice of Substitution of Counsel for Amicus Curiae Brief & Appearance Before Aslb.Certificate of Svc Encl ML20024E5591983-08-11011 August 1983 Motion for Leave to File Reply Brief to Applicant & NRC 830803 & 01,respectively,answers Opposing Miami Valley Power Project Motion to Compel Discovery.Assertion of Boundary on Discovery Should Be Briefed.Certificate of Svc Encl ML20024E3941983-08-0505 August 1983 Motion for Leave to File Reply Brief & for Clarification of Responsibility to Duplicate Previous Analysis & Evidentiary Submissions.Util Challenge Frivolous,Heavy on Chutzpah & Deficient on Common Sense.Certificate of Svc Encl ML20077L5161983-08-0303 August 1983 Response Opposing Miami Valley Power Project 830707 Reply Brief Supporting Project 830603 Motion to Reopen Record.Aslb Lacks Jurisdiction to Hear Motion to Reopen to Admit Eight late-filed Contentions.Certificate of Svc Encl ML20024D1381983-07-27027 July 1983 Answer Opposing Miami Valley Power Project 830712 Motion for Protective Order to Withhold Identity of Persons Upon Whose Allegations Project Relied in Seeking to Reopen Record.Motion W/O Merit.Certificate of Svc Encl ML20024D1261983-07-27027 July 1983 Answer Opposing Miami Valley Power Project 830712 Motion to Reopen Record for Admission of Eight QA Contentions. Motion Actually Is Untimely Appeal from Earlier ASLB Rulings.Relief Sought Contrary to Commission Orders ML20024D1171983-07-27027 July 1983 Answer Opposing Miami Valley Power Project 830712 Motion to Defer Ruling on Review of ALAB-727 Pending Ruling on Motions to Reopen.No Justification Given to Delay Review for Unrelated Matters ML20080A2721983-07-21021 July 1983 Response to Applicant Motion for Leave to Respond to Miami Valley Power Project Reply Brief.Applicant Should Respond Only to Substance of Proposed Contentions Re QA Program Inadequacy.Certificate of Svc Encl ML20076L4691983-07-15015 July 1983 Motion for Leave to Respond by 830729 to Miami Valley Power Project (MVPP) Reply Brief Re Applicant Opposition to Eight QA Contentions.Mvpp Reply Distorts Record & Applicant Position.Certificate of Svc Encl ML20072N4501983-07-12012 July 1983 Reply Brief Supporting Miami Valley Power Project 830603 Motion to Reopen Record for Admission of Eight Contentions on QA & Corporate Character & Competence & Motion to Compel Discovery on Contentions ML20072N4631983-07-12012 July 1983 Motion to Reopen Record for Admission of Eight Contentions on QA & Corporate Character & Competence.Aslab Has Jurisdiction Even If ASLB Lacks Jurisdiction to Reopen Record ML20072N4741983-07-12012 July 1983 Motion to Defer Ruling on Whether to Review ALAB-727 Until ASLB & Aslab Rule on Miami Valley Power Project 830603 & 0712 Motions to Reopen Record to Admit Contentions on QA & Character & Competence,Or Alternatively,To Reopen Record ML20072N4901983-07-12012 July 1983 Motion for Protective Order to Shield Identity of Affiants Providing Portion of Basis for Miami Valley Power Project Eight Proposed Contentions.Certificate of Svc Encl ML20072K7331983-07-0101 July 1983 Answer Opposing Miami Valley Power Project 830629 Motion for Leave to File Reply Brief to Util & NRC Answers to Project 830603 Motion to Reopen Record.No Purpose Would Be Served by Permitting Redundant Discussion.Certificate of Svc Encl ML20024B0591983-06-29029 June 1983 Motion for Leave to File Reply Brief,By 830706,to NRC & Util 830630 Answers to Miami Valley Power Project 830603 Motion to Reopen Record to Admit Eight Contentions on QA & Util Character & Competence.Certificate of Svc Encl ML20072F4481983-06-22022 June 1983 Memorandum Supporting Miami Valley Power Project 830602 Motion to Reopen Record to Admit Eight Contentions on QA & Lack of Corporate Character & Competence.Reopening Necessary to Foster Public Confidence in Nrc.W/Certificate of Svc ML20024A6661983-06-20020 June 1983 Response Opposing Motions to File Amicus Curiae Brief in Support of Miami Valley Power Project Motion to Reopen Record for Admission of Eight QA Contentions.Certificate of Svc Encl ML20024A6621983-06-20020 June 1983 Response Opposing Miami Valley Power Project 830603 Motion to Reopen Record for Admission of Eight QA Contentions. Motion Untimely ML20076J1201983-06-16016 June 1983 Petition for Leave to File Amicus Curiae Brief Re Miami Valley Power Project Motion to Reopen Record to Admit Eight Contentions on QA & Character & Competence.Requests Extension of Time.Certificate of Svc Encl ML20076J1361983-06-16016 June 1983 Ohio Sierra Club Amicus Curiae Brief Supporting Miami Valley Power Project Motion to Reopen Record to Admit Eight Contentions.Contentions Provide Evidence That QA Problems Exist.Certificate of Svc Encl 1993-08-11
[Table view] Category:TRANSCRIPTS
MONTHYEARML20136E0751983-05-16016 May 1983 Transcript of 830516 Interview of Ga Phillips in Glen Ellen,Il Re Allegations in MG Malsch 821116 Memo ML20062E3311982-07-30030 July 1982 Transcript of Commission 820730 Public Meeting in Washington,Dc Re Affirmation/Discussion Session on SECY-82-318.Pp 1-7 ML20062E2151982-07-26026 July 1982 Commission Determination Withholding Transcript of 820607 Briefing Re Status of Zimmer Investigation.Meeting Closed Per 10CFR9.108(c) & 10CFR9.104(a)(5) & (7) ML20054H1251982-06-16016 June 1982 Unofficial Transcript of 820616 Public Meeting in Washington,Dc Re Cincinnati Gas & Electric Govt Accountability Project on Qa/Qc & Related Matters at Facility.Pp 1-126 ML20054L4641982-06-16016 June 1982 Transcript of 820616 Meeting in Washington,Dc W/Util & Govt Accountability Project Re Qa/Qc & Related Matters. Pp 1-126 ML20052E5221982-05-0606 May 1982 Proposed Corrections to Transcript of Evidentiary Hearings on Emergency Planning Issues.Certificate of Svc Encl ML20040A9431982-01-19019 January 1982 Testimony of RW Meyer,Pt Frost & Jc Heard Re Contentions on Adequacy of State of Oh & Clermont County Radiological Emergency Response Plans ML20040B1261982-01-15015 January 1982 Testimony of Applicants Re Emergency Planning Contentions. Prof Qualifications & Certificate of Svc Encl ML20039G1991982-01-12012 January 1982 Direct Testimony of Hd Gideouse Addressing ZAC-ZACK, D Fankhauser & Mentor Contentions.Related Correspondence ML20039G2501982-01-12012 January 1982 Direct Testimony of DC Gandola Addressing ZAC-ZACK Contentions 21(b)(2).Related Correspondence ML20039G2141982-01-0808 January 1982 Direct Testimony of D Brown Re ZAC-ZACK & City of Mentor,Ky Contentions 20c (7),(8),(9) & 10 & 36 (B),(C),(D) & (I). Discusses Roads in Evacuation Routes.Related Correspondence ML20039G1841982-01-0808 January 1982 Direct Testimony of M Erbe Addressing ZAC-ZACK Contentions 20,20b,21,21b,21c,21d,21e & 23.Related Correspondence ML20039G2391982-01-0808 January 1982 Testimony of M Reder Re ZAC-ZACK & City of Mentor,Ky Contentions 34,35 & 36 B,C,D,I & K.Interim County Radiological Emergency Plans Unworkable.Related Correspondence ML20039G0741982-01-0808 January 1982 Direct Testimony of s Slemmer Addressing ZAC-ZACK Contentions 20c(5),23(1)-(5) & 24(10).Related Correspondence ML20039G0701982-01-0808 January 1982 Direct Testimony of T Nishiyama Addressing ZAC-ZACK Contention 20x.Related Correspondence ML20039G1921982-01-0707 January 1982 Direct Testimony of J Wesseler Addressing ZAC-ZACK Contention 20x.Related Correspondence ML20039G0611982-01-0707 January 1982 Direct Testimony of J Goode Addressing ZAC-ZACK Contentions 20c(5) 20e(4),24(6) & (10).Related Correspondence ML20039G2131982-01-0707 January 1982 Direct Testimony of R Arthur,Addressing ZAC-ZACK & D Fankhauser Contentions 4(12),23(4) & (5).Related Correspondence ML20039G2081982-01-0707 January 1982 Direct Testimony of R Beiting Re ZAC-ZACK & City of Mentor, Ky Contention 35 (B).Discusses Road Conditions Re Evacuation Route.Related Correspondence ML20039G2181982-01-0707 January 1982 Direct Testimony of R Mccormick & R Smith Addressing ZAC-ZACK & City of Mentor Contentions 20e,(7),(8),(9),34,(G) & (H).Related Correspondence ML20039G2211982-01-0707 January 1982 Direct Testimony of G Nelson Re ZAC-ZACK & City of Mentor,Ky Contentions 20c (2),(7),(8),(10),36 (B)(C) & (D).Discusses Roads in Evacuation Routes.Related Correspondence ML20039G2321982-01-0707 January 1982 Direct Testimony of H Kennedy Addressing ZAC-ZACK Contentiions 20b(4),20c(2),(3),(5),(6),(12),(14),20e(3),(4), (5),(6),20f(1),20g(1),23(1),(2),(4) & (5).Related Correspondence ML20039G2161982-01-0606 January 1982 Direct Testimony of Rl Sutton Addressing ZAC-ZACK Contentions 25(3) & (4).Related Correspondence ML20039G2521982-01-0606 January 1982 Direct Testimony of C Mcmillian Addressing ZAC-ZACK Contentions 20,20(c)(2),(3),(5),(6),20(g)(1) & 23.Related Correspondence ML20039G2051982-01-0606 January 1982 Direct Testimony of J Mcintosh Addressing ZAC-ZACK Contentions 20,20c,20e & 24.Related Correspondence ML20039G0781982-01-0606 January 1982 Direct Testimony of R Feldkamp Addressing ZAC-ZACK Contentions 20c(3),(5),20e(3),(4),20g(1) & 24(6) & (7). Related Correspondence ML20039G2421982-01-0606 January 1982 Direct Testimony of G Wolff Addressing ZAC-ZACK Contention 23(3) & Fankhauser Contention 4(12) Re Circle of Safety Publication.Related Correspondence ML20039G2471982-01-0606 January 1982 Direct Testimony of E Erbe Addressing ZAC-ZACK Contentions 20x,20(b),20(c),20(e),20(f) & 20(g).Related Correspondence ML20039G2121982-01-0505 January 1982 Direct Testimony of G Sell & W Voelker Addressing City of Mentor Contention 84 Re Campell County School District. Related Correspondence ML20039G0681982-01-0505 January 1982 Direct Testimony of C Jackson Addressing ZAC-ZACK Contentions 20c(5) & 20e(6).Related Correspondence ML20039G0341982-01-0404 January 1982 Direct Testimony of G Sell,M Reinhardt & W Voelker Addressing ZAC-ZACK & City of Mentor Contentions Re Campbell County School District Contentions.Related Correspendence ML20039G1141981-09-29029 September 1981 Transcript of 810929 Facility Evacuation Plan Meeting in Cold Springs,Ky ML19346A1811981-05-29029 May 1981 Proposed Corrections to Transcript of Evidentiary Hearings Held to Date ML20003C0581981-02-11011 February 1981 Testimony Re Miami Valley Power Project Contention 13 on Applicants Financial Qualifications & Potential Financial Effects of Decommissioning.Prof Qualifications & Certificate of Svc Encl.Related Correspondence ML20125A7231979-08-10010 August 1979 Transcript of 790810 Hearing in Cincinnati,Oh. Pp 3,043-3,149 ML20136B0971979-08-0909 August 1979 Transcript of 790809 Hearing in Cincinnati,Oh. Pp 2,713-3,042 ML20125A6911979-08-0707 August 1979 Transcript of 790807 Hearing in Cincinnati,Oh. 2,222-2,427 ML20125C0591979-06-28028 June 1979 Transcript of 790628 Hearing in Cincinnati,Oh.Pp 1,817- 1,818 ML19225A4041979-06-0808 June 1979 Testimony Concerning Contention 14 Re Cable Trays Welding ML19225A4181979-06-0808 June 1979 Testimony Concerning Contentions 15 & 16 Re Procedures Involving Control Rods & Control Blades ML19225A4221979-06-0808 June 1979 Testimony Re Presence of Foreign Matter in Control Rods. Certificate of Svc Encl ML19225A6561979-06-0101 June 1979 Summary of Intervenor Fankhauser-prepared Testimony for June 1979 Hearing Re Contention 6 Relating to Spent Fuel Pool at Facility ML20148S6071978-11-17017 November 1978 Transcript of 781117 Zimmer Subcommittee Meeting.Pp 1-213. 213 1983-05-16
[Table view] Category:DEPOSITIONS
MONTHYEARML20136E0751983-05-16016 May 1983 Transcript of 830516 Interview of Ga Phillips in Glen Ellen,Il Re Allegations in MG Malsch 821116 Memo ML20062E3311982-07-30030 July 1982 Transcript of Commission 820730 Public Meeting in Washington,Dc Re Affirmation/Discussion Session on SECY-82-318.Pp 1-7 ML20062E2151982-07-26026 July 1982 Commission Determination Withholding Transcript of 820607 Briefing Re Status of Zimmer Investigation.Meeting Closed Per 10CFR9.108(c) & 10CFR9.104(a)(5) & (7) ML20054H1251982-06-16016 June 1982 Unofficial Transcript of 820616 Public Meeting in Washington,Dc Re Cincinnati Gas & Electric Govt Accountability Project on Qa/Qc & Related Matters at Facility.Pp 1-126 ML20054L4641982-06-16016 June 1982 Transcript of 820616 Meeting in Washington,Dc W/Util & Govt Accountability Project Re Qa/Qc & Related Matters. Pp 1-126 ML20052E5221982-05-0606 May 1982 Proposed Corrections to Transcript of Evidentiary Hearings on Emergency Planning Issues.Certificate of Svc Encl ML20040A9431982-01-19019 January 1982 Testimony of RW Meyer,Pt Frost & Jc Heard Re Contentions on Adequacy of State of Oh & Clermont County Radiological Emergency Response Plans ML20040B1261982-01-15015 January 1982 Testimony of Applicants Re Emergency Planning Contentions. Prof Qualifications & Certificate of Svc Encl ML20039G1991982-01-12012 January 1982 Direct Testimony of Hd Gideouse Addressing ZAC-ZACK, D Fankhauser & Mentor Contentions.Related Correspondence ML20039G2501982-01-12012 January 1982 Direct Testimony of DC Gandola Addressing ZAC-ZACK Contentions 21(b)(2).Related Correspondence ML20039G2141982-01-0808 January 1982 Direct Testimony of D Brown Re ZAC-ZACK & City of Mentor,Ky Contentions 20c (7),(8),(9) & 10 & 36 (B),(C),(D) & (I). Discusses Roads in Evacuation Routes.Related Correspondence ML20039G1841982-01-0808 January 1982 Direct Testimony of M Erbe Addressing ZAC-ZACK Contentions 20,20b,21,21b,21c,21d,21e & 23.Related Correspondence ML20039G2391982-01-0808 January 1982 Testimony of M Reder Re ZAC-ZACK & City of Mentor,Ky Contentions 34,35 & 36 B,C,D,I & K.Interim County Radiological Emergency Plans Unworkable.Related Correspondence ML20039G0741982-01-0808 January 1982 Direct Testimony of s Slemmer Addressing ZAC-ZACK Contentions 20c(5),23(1)-(5) & 24(10).Related Correspondence ML20039G0701982-01-0808 January 1982 Direct Testimony of T Nishiyama Addressing ZAC-ZACK Contention 20x.Related Correspondence ML20039G1921982-01-0707 January 1982 Direct Testimony of J Wesseler Addressing ZAC-ZACK Contention 20x.Related Correspondence ML20039G0611982-01-0707 January 1982 Direct Testimony of J Goode Addressing ZAC-ZACK Contentions 20c(5) 20e(4),24(6) & (10).Related Correspondence ML20039G2131982-01-0707 January 1982 Direct Testimony of R Arthur,Addressing ZAC-ZACK & D Fankhauser Contentions 4(12),23(4) & (5).Related Correspondence ML20039G2081982-01-0707 January 1982 Direct Testimony of R Beiting Re ZAC-ZACK & City of Mentor, Ky Contention 35 (B).Discusses Road Conditions Re Evacuation Route.Related Correspondence ML20039G2181982-01-0707 January 1982 Direct Testimony of R Mccormick & R Smith Addressing ZAC-ZACK & City of Mentor Contentions 20e,(7),(8),(9),34,(G) & (H).Related Correspondence ML20039G2211982-01-0707 January 1982 Direct Testimony of G Nelson Re ZAC-ZACK & City of Mentor,Ky Contentions 20c (2),(7),(8),(10),36 (B)(C) & (D).Discusses Roads in Evacuation Routes.Related Correspondence ML20039G2321982-01-0707 January 1982 Direct Testimony of H Kennedy Addressing ZAC-ZACK Contentiions 20b(4),20c(2),(3),(5),(6),(12),(14),20e(3),(4), (5),(6),20f(1),20g(1),23(1),(2),(4) & (5).Related Correspondence ML20039G2161982-01-0606 January 1982 Direct Testimony of Rl Sutton Addressing ZAC-ZACK Contentions 25(3) & (4).Related Correspondence ML20039G2521982-01-0606 January 1982 Direct Testimony of C Mcmillian Addressing ZAC-ZACK Contentions 20,20(c)(2),(3),(5),(6),20(g)(1) & 23.Related Correspondence ML20039G2051982-01-0606 January 1982 Direct Testimony of J Mcintosh Addressing ZAC-ZACK Contentions 20,20c,20e & 24.Related Correspondence ML20039G0781982-01-0606 January 1982 Direct Testimony of R Feldkamp Addressing ZAC-ZACK Contentions 20c(3),(5),20e(3),(4),20g(1) & 24(6) & (7). Related Correspondence ML20039G2421982-01-0606 January 1982 Direct Testimony of G Wolff Addressing ZAC-ZACK Contention 23(3) & Fankhauser Contention 4(12) Re Circle of Safety Publication.Related Correspondence ML20039G2471982-01-0606 January 1982 Direct Testimony of E Erbe Addressing ZAC-ZACK Contentions 20x,20(b),20(c),20(e),20(f) & 20(g).Related Correspondence ML20039G2121982-01-0505 January 1982 Direct Testimony of G Sell & W Voelker Addressing City of Mentor Contention 84 Re Campell County School District. Related Correspondence ML20039G0681982-01-0505 January 1982 Direct Testimony of C Jackson Addressing ZAC-ZACK Contentions 20c(5) & 20e(6).Related Correspondence ML20039G0341982-01-0404 January 1982 Direct Testimony of G Sell,M Reinhardt & W Voelker Addressing ZAC-ZACK & City of Mentor Contentions Re Campbell County School District Contentions.Related Correspendence ML20039G1141981-09-29029 September 1981 Transcript of 810929 Facility Evacuation Plan Meeting in Cold Springs,Ky ML19346A1811981-05-29029 May 1981 Proposed Corrections to Transcript of Evidentiary Hearings Held to Date ML20003C0581981-02-11011 February 1981 Testimony Re Miami Valley Power Project Contention 13 on Applicants Financial Qualifications & Potential Financial Effects of Decommissioning.Prof Qualifications & Certificate of Svc Encl.Related Correspondence ML20125A7231979-08-10010 August 1979 Transcript of 790810 Hearing in Cincinnati,Oh. Pp 3,043-3,149 ML20136B0971979-08-0909 August 1979 Transcript of 790809 Hearing in Cincinnati,Oh. Pp 2,713-3,042 ML20125A6911979-08-0707 August 1979 Transcript of 790807 Hearing in Cincinnati,Oh. 2,222-2,427 ML20125C0591979-06-28028 June 1979 Transcript of 790628 Hearing in Cincinnati,Oh.Pp 1,817- 1,818 ML19225A4041979-06-0808 June 1979 Testimony Concerning Contention 14 Re Cable Trays Welding ML19225A4181979-06-0808 June 1979 Testimony Concerning Contentions 15 & 16 Re Procedures Involving Control Rods & Control Blades ML19225A4221979-06-0808 June 1979 Testimony Re Presence of Foreign Matter in Control Rods. Certificate of Svc Encl ML19225A6561979-06-0101 June 1979 Summary of Intervenor Fankhauser-prepared Testimony for June 1979 Hearing Re Contention 6 Relating to Spent Fuel Pool at Facility ML20148S6071978-11-17017 November 1978 Transcript of 781117 Zimmer Subcommittee Meeting.Pp 1-213. 213 1983-05-16
[Table view] Category:NARRATIVE TESTIMONY
MONTHYEARML20136E0751983-05-16016 May 1983 Transcript of 830516 Interview of Ga Phillips in Glen Ellen,Il Re Allegations in MG Malsch 821116 Memo ML20062E3311982-07-30030 July 1982 Transcript of Commission 820730 Public Meeting in Washington,Dc Re Affirmation/Discussion Session on SECY-82-318.Pp 1-7 ML20062E2151982-07-26026 July 1982 Commission Determination Withholding Transcript of 820607 Briefing Re Status of Zimmer Investigation.Meeting Closed Per 10CFR9.108(c) & 10CFR9.104(a)(5) & (7) ML20054H1251982-06-16016 June 1982 Unofficial Transcript of 820616 Public Meeting in Washington,Dc Re Cincinnati Gas & Electric Govt Accountability Project on Qa/Qc & Related Matters at Facility.Pp 1-126 ML20054L4641982-06-16016 June 1982 Transcript of 820616 Meeting in Washington,Dc W/Util & Govt Accountability Project Re Qa/Qc & Related Matters. Pp 1-126 ML20052E5221982-05-0606 May 1982 Proposed Corrections to Transcript of Evidentiary Hearings on Emergency Planning Issues.Certificate of Svc Encl ML20040A9431982-01-19019 January 1982 Testimony of RW Meyer,Pt Frost & Jc Heard Re Contentions on Adequacy of State of Oh & Clermont County Radiological Emergency Response Plans ML20040B1261982-01-15015 January 1982 Testimony of Applicants Re Emergency Planning Contentions. Prof Qualifications & Certificate of Svc Encl ML20039G1991982-01-12012 January 1982 Direct Testimony of Hd Gideouse Addressing ZAC-ZACK, D Fankhauser & Mentor Contentions.Related Correspondence ML20039G2501982-01-12012 January 1982 Direct Testimony of DC Gandola Addressing ZAC-ZACK Contentions 21(b)(2).Related Correspondence ML20039G2141982-01-0808 January 1982 Direct Testimony of D Brown Re ZAC-ZACK & City of Mentor,Ky Contentions 20c (7),(8),(9) & 10 & 36 (B),(C),(D) & (I). Discusses Roads in Evacuation Routes.Related Correspondence ML20039G1841982-01-0808 January 1982 Direct Testimony of M Erbe Addressing ZAC-ZACK Contentions 20,20b,21,21b,21c,21d,21e & 23.Related Correspondence ML20039G2391982-01-0808 January 1982 Testimony of M Reder Re ZAC-ZACK & City of Mentor,Ky Contentions 34,35 & 36 B,C,D,I & K.Interim County Radiological Emergency Plans Unworkable.Related Correspondence ML20039G0741982-01-0808 January 1982 Direct Testimony of s Slemmer Addressing ZAC-ZACK Contentions 20c(5),23(1)-(5) & 24(10).Related Correspondence ML20039G0701982-01-0808 January 1982 Direct Testimony of T Nishiyama Addressing ZAC-ZACK Contention 20x.Related Correspondence ML20039G1921982-01-0707 January 1982 Direct Testimony of J Wesseler Addressing ZAC-ZACK Contention 20x.Related Correspondence ML20039G0611982-01-0707 January 1982 Direct Testimony of J Goode Addressing ZAC-ZACK Contentions 20c(5) 20e(4),24(6) & (10).Related Correspondence ML20039G2131982-01-0707 January 1982 Direct Testimony of R Arthur,Addressing ZAC-ZACK & D Fankhauser Contentions 4(12),23(4) & (5).Related Correspondence ML20039G2081982-01-0707 January 1982 Direct Testimony of R Beiting Re ZAC-ZACK & City of Mentor, Ky Contention 35 (B).Discusses Road Conditions Re Evacuation Route.Related Correspondence ML20039G2181982-01-0707 January 1982 Direct Testimony of R Mccormick & R Smith Addressing ZAC-ZACK & City of Mentor Contentions 20e,(7),(8),(9),34,(G) & (H).Related Correspondence ML20039G2211982-01-0707 January 1982 Direct Testimony of G Nelson Re ZAC-ZACK & City of Mentor,Ky Contentions 20c (2),(7),(8),(10),36 (B)(C) & (D).Discusses Roads in Evacuation Routes.Related Correspondence ML20039G2321982-01-0707 January 1982 Direct Testimony of H Kennedy Addressing ZAC-ZACK Contentiions 20b(4),20c(2),(3),(5),(6),(12),(14),20e(3),(4), (5),(6),20f(1),20g(1),23(1),(2),(4) & (5).Related Correspondence ML20039G2161982-01-0606 January 1982 Direct Testimony of Rl Sutton Addressing ZAC-ZACK Contentions 25(3) & (4).Related Correspondence ML20039G2521982-01-0606 January 1982 Direct Testimony of C Mcmillian Addressing ZAC-ZACK Contentions 20,20(c)(2),(3),(5),(6),20(g)(1) & 23.Related Correspondence ML20039G2051982-01-0606 January 1982 Direct Testimony of J Mcintosh Addressing ZAC-ZACK Contentions 20,20c,20e & 24.Related Correspondence ML20039G0781982-01-0606 January 1982 Direct Testimony of R Feldkamp Addressing ZAC-ZACK Contentions 20c(3),(5),20e(3),(4),20g(1) & 24(6) & (7). Related Correspondence ML20039G2421982-01-0606 January 1982 Direct Testimony of G Wolff Addressing ZAC-ZACK Contention 23(3) & Fankhauser Contention 4(12) Re Circle of Safety Publication.Related Correspondence ML20039G2471982-01-0606 January 1982 Direct Testimony of E Erbe Addressing ZAC-ZACK Contentions 20x,20(b),20(c),20(e),20(f) & 20(g).Related Correspondence ML20039G2121982-01-0505 January 1982 Direct Testimony of G Sell & W Voelker Addressing City of Mentor Contention 84 Re Campell County School District. Related Correspondence ML20039G0681982-01-0505 January 1982 Direct Testimony of C Jackson Addressing ZAC-ZACK Contentions 20c(5) & 20e(6).Related Correspondence ML20039G0341982-01-0404 January 1982 Direct Testimony of G Sell,M Reinhardt & W Voelker Addressing ZAC-ZACK & City of Mentor Contentions Re Campbell County School District Contentions.Related Correspendence ML20039G1141981-09-29029 September 1981 Transcript of 810929 Facility Evacuation Plan Meeting in Cold Springs,Ky ML19346A1811981-05-29029 May 1981 Proposed Corrections to Transcript of Evidentiary Hearings Held to Date ML20003C0581981-02-11011 February 1981 Testimony Re Miami Valley Power Project Contention 13 on Applicants Financial Qualifications & Potential Financial Effects of Decommissioning.Prof Qualifications & Certificate of Svc Encl.Related Correspondence ML20125A7231979-08-10010 August 1979 Transcript of 790810 Hearing in Cincinnati,Oh. Pp 3,043-3,149 ML20136B0971979-08-0909 August 1979 Transcript of 790809 Hearing in Cincinnati,Oh. Pp 2,713-3,042 ML20125A6911979-08-0707 August 1979 Transcript of 790807 Hearing in Cincinnati,Oh. 2,222-2,427 ML20125C0591979-06-28028 June 1979 Transcript of 790628 Hearing in Cincinnati,Oh.Pp 1,817- 1,818 ML19225A4041979-06-0808 June 1979 Testimony Concerning Contention 14 Re Cable Trays Welding ML19225A4181979-06-0808 June 1979 Testimony Concerning Contentions 15 & 16 Re Procedures Involving Control Rods & Control Blades ML19225A4221979-06-0808 June 1979 Testimony Re Presence of Foreign Matter in Control Rods. Certificate of Svc Encl ML19225A6561979-06-0101 June 1979 Summary of Intervenor Fankhauser-prepared Testimony for June 1979 Hearing Re Contention 6 Relating to Spent Fuel Pool at Facility ML20148S6071978-11-17017 November 1978 Transcript of 781117 Zimmer Subcommittee Meeting.Pp 1-213. 213 1983-05-16
[Table view] |
Text
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f 1, IUl&TED COE!ESPOND?'"
! l
- jpEXEr UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION 82 J.Ul12 P3:26 l ATOMIC SAFETY AND LICENSING BOARD
C:: . ~. _ ; ~
In the Matter of : ..
CINCINNATI GAS & ELECTRIC : DOCKET NO. 50-358 COMPANY, et al. :
(William H. Zimmer Nuclear :
Power Station) : APPLICATION FOR AN OPERATING-L-MNi;(SE cas DIRECT TESTIMONY OF RICHARD ARTHUR ADDRESSING T Y ZIMMER AREA CITIZENS-ZIMMER AREA CITIZENS OF . gs nECEIVED KENTUCKY AND DAVID FANKHAUSER CONTENTIONS 4 (12 g 23(4) and (5). 9- g 3 3 jgp State of Ohio ) " E"%y " '
) SS: tcc f County of Butler )
Richard Arthur, being first cautioned and sworn, as m, I
testimony state as follows: ..
My home address is 978 Columbia Road, Hamilton, Ohio 45013.
I hold a Bachelor of Science degree in education and a Master of Arts degree in English from Bowling Green State University, Bowling Green, Ohio. My professional experience includes, from 1963 to 1965, graduate assistant in English, Bowling Green State University, Bowling Green, Ohio, teaching freshman English and remedial English; from 1965 to 1966, Wayne State College, Wayne, Nebraska, teaching
< freshman English and English Literature; from 1966 to 1968, Ohio Northern University, Ada, Ohio, instructor of English, freshman English, American Literature; from 1968 to 1972, the University of Cincinnati, Cincinnati, Ohio, instructor of English, 1968 .to 1972, assistant director of freshman English, 1970 to 1972; 1972 to the present, head, Department of English, William Henry Harrison High 8201150389 820107 80 PDR ADOCK 05000359 .
T PDR
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School, Harrison, Ohio, director, 1972 to'1974, Title II reading
.1 project. Additional professional experience: from 1971 to thi present I have appeared some. fifteen times as an expert witness in litigation, both in the federal and state courts. My testimony has been on contemporary community standards, literary values and readability of material at issue in these.various cases.
From 1972 to 1974 I was Title II reading project director. I implemented a program designed to establish and improve the reading skills of high school students. The program was fou,nded on the assumption that reading problems occur because of poor vocabulary and lack of interest, which is caused by material too difficdlt i ;
for the student or the reader to handle. Publications: Clifton I
Magazine, winter 1974, "The Victorian Backlash".
- The analysis of " Circle of Safety" was given four tests.
I The first test is called the Fry Readability Test and the results .
were plotted on Fry's readability graph. The second test' was a vocabulary level test. The third test was a structural or organi-zational test. The fourth test was an analysis aof -the effects of the. handbook " Circle of Safety", followed by conclusions regarding these various tests. .
First, the Fry Readability Test. The Fry Readability Test
- involves an analysis of three 100-word' passages selected at random.
These passages were selected from page 5, page 9 and page 14.
The f total number of sentences in each 100-word passage is counted and
- then the three passages are averaged tc come up with an average number of sentences per 100-word passage. The average for the three 1
e s
l
. l 1
samples taken from " Circle of Safety" is 4.6 sentences per 100-word passage. The second part of this test is the counting of the 1
number of syllables for each passage. For example, the werd " cat" l l
has one syllable, the word " blackboard" has tso syllables, the l
' l word " continental" has four syllables. The number of syllables )
1 is determined from each vowel sound in a word. Proceeding thus with the three samples, the sample on page 5 has 175 syllables; j the sample on page 9 has 189 syllables; the sample on page 14 has i
168 syllables. These are then totaled and averaged to come out with an average number of syllables per 100-word p'assage of 177 l syllables. These two conclusions -- the 4.6 sentences and the 177 syllables -- are then plotted on_ Fry's readability graph, which gives an approximate grade level of the readability of the material under examination. My conclusion, based on this analysis, l is that the material is greater than college level reading. The I meaning of this is that people with a college education would be likely to have difficulty in understanding the material contained-in the " Circle of Safety". People with less than a college education would have considerable difficulty understanding the material contained therein.
The second test is the vocabulary test. This test is based on the assumption and recognition that a vocabulary level which is l too high for the average person to grasp easily creates difficulty for the reader. Thus, the reading soon becomes dull. .A person is not likely to read the book because he will become bored by it, or can not understand it. While it is true that a person might figure l
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out the Meaning of a particular vocabulary wo'rd from context, ' the e interest level of this naterial is so low that a real effort to find meaning is not likely to occur. Also, if there is a real need, frustration from the lack of understanding of the material is likely to cause panic in the reader. Approximately 157 words and phrases, some of which are used more than once, are indicated
, in the text as being of sufficient difficulty to cause a lack of understanding or frustration in the average reader.'
The third test involves structure and organization and'is based on three principles. The first principle'is that in any
, reading the interest of the reader declines as the reading proceeds.
The second principle is the location in the handbook of valuable .
information. The third principle is the ease of location of important material. With respect to the first principle, interest declines as a person reads. The ma'terial being read must counteract '
that declining interest. In the " Circle of Safety" it is unlikely that many readers will get to Section IV, the most crucial part of the handbook, because the first three sections are either too dull or too difficult. With respect to the second principle, the central va1ue of this handbook is buried at the end.
The end is the least likely place the reader would get to because of the readability factor and is the least likely place a reader would look for valuable information. With respect to the third principle, a handbook should give specific information quickly, accurately and simply. For example, a telephone book or the yellow pages or the dictionary uses the principle of alphabetical order. Anyone knowing
the principle can use the book easily. In spite of the ease of using a telephone book, nowever, many avoid the work involved.
Thus, we have to pay for more than three directory assistance calls per month. This example shows that people are not likely
- to use ' handbooks which are relatively easy and, by implication, not likely to understand or be able to use handbooks such as this which are quite difficult.
The fourth test involves the effects of the handbook as it is now written. The first effect, as I see it, would be confusion for the readers. The purpose of this " Circle of Safety" is cloudy. Throughout Part I, Introduction, Part II, Radiological Emergencies, and Part III, Radiological Planning, there is frequent reference to the likelihood that there will never be a significant emergency, or that the emergency won't be important enough to involve the public. The intention seems to be to keep the reader calm, but that attitude contradictsSection IV, Notification and Protective Actions. The likely result is confusion. Should the .
reader worry or not? What should the reader do if- he is worried?
The place for editorials on how safe the plant is, and the place for assurances that the power company / government complex is interested in safety, is not in the handbook on what to do in case-of emergencies. The second effect, the visuals presented in the left hand margins are inadequate. Some visuals do not clearly illustrate the points because of the vocabulary on the visual or what it is trying to depict: page 2, " engineered safeguards";
page 3, " cooperative interplay", page 4, state county organizations; 9
0 1
page 5, ' alpha, beta, gamma rays"; page 9, the first visual; pgge 11, " neighborhood cooperation"; page 12, bags packed; page 13, both visuals.
l It is my professional opinion that the " Circle of Safety" is a failure in five ways. First, it can not be read or understood by the audience to whom it is presumably aimed, an audience, based on my experience, which is likely to include people who have a reading ability from the third grade through the cbliege level.
~
Second, the vocabulary in the book is too sophisticated, which creates a lack of reading interest and, therefore, frustrates the audience. Third, the book is poorly structured. The worthwhile information is hidden under jargon, bureaucratic acronyms, con- ,
descension and editorializing. Fourth, the book is boring and confusing in its effect. And, finally, the audience won't or can't
~
read the book, therefore the audience is not likely to take the matter very seriously. The audience can not respond to an emergency
, because it has not really received the communication. The medium, after all, is the message.
5 l CNs' tr "
Richard Arthur Sworn to and subscribed in my presence this 7th day of January, 1982.
%% S %-
- MAXINE 5. LOUX Notar 'ublic, Stats of On My Commissian Ex;kes laa. 29, 1985
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