|
---|
Category:INTERVENTION PETITIONS
MONTHYEARML20072H6581983-03-24024 March 1983 Answer Opposing D Gillman late-filed Petition to Intervene. Proposed Contentions Lack Discernable Meaning.Coherent Presentation Not Made Re Interest & Late Contentions or Reopening Record Requirements.Certificate of Svc Encl ML20069G4671983-03-19019 March 1983 Procedural Reasons for Acceptance of D Gillman 830228 Five Contentions ML20065B8041983-01-21021 January 1983 Contentions 1 - 5 Re Diesel Generator Transmission Gears, Suppression Pool Structural Matls,Boiling Water Transports, Ion Exchange Resin Sys & Electrolyte Accretion Problem ML20054K6241982-06-0707 June 1982 Submission of Contention Re Mark II Owners Group Suppression Pool Safety Analysis ML19327A3231980-07-31031 July 1980 Response in Opposition to Intervenor DB Fankhauser Motion for Admission of Addl Contentions Re Escalating Costs.Party Status as Util Ratepayer Is Insufficient Basis.No Good Cause Shown for Late Submission.Certificate of Svc Encl ML19321A1751980-07-16016 July 1980 Motion & Memorandum Seeking Admission of Addl Contentions. Questions Applicant Financial Capablities & Alleges Errors in FES,NUREG-0625.Process Used for Cost/Benefit Analysis Is Contrary to Nepa.Certificate of Svc Encl ML19323J2321980-06-16016 June 1980 Response in Opposition to Zimmer Area Citizens 800515 Proposed Contentions.Intervenors Failed to Demonstrate Good Cause Under Policy Stated in Commission Decision Overruling ALAB-590.Certificate of Svc Encl ML19329F7721980-06-13013 June 1980 Contentions Per Discussions W/Nrc & Applicant Re OL Application.Alleges Absence of Adequate Communication Sys for Coordination & Direction of Evacuation.Certificate of Svc Encl ML19323H7601980-05-23023 May 1980 Answer to Clermont County,Oh 800512 Petition to Participate as Interested State in Proceeding.Urges Imposition of Same Conditions Imposed on City of Mentor & State of Ky,If Participation Granted.Certificate of Svc Encl ML19323G0641980-05-15015 May 1980 Proposed Contentions Alleging Inadequacy of Evacuation Plans for Plume Exposure Pathway,Due to Absence of Emergency Operations Facility.Certificate of Svc Encl ML19323H9631980-05-12012 May 1980 Petition to Participate in Proceeding by Political Subdivision of State of Oh Having Greatest Population Concentration within 10 Mile Radius of Plant.W/Board of County Commissioners Resolution & Certificate of Svc ML19305E0241980-04-0707 April 1980 Requests Denial of Zimmer Area Citizens & Zimmer Area Citizens in Ky Petitions to Intervene as Interested Person. Petitioner Has Failed to Demonstrate Good Cause for Late Filing.Certificate of Svc Encl ML19309B2561980-03-19019 March 1980 Response to State of Ky 800304 Petition to Intervene as Interested State.If Participation Granted,Re Emergency Planning,State of Ky Must Enter Proceeding in Present Stage of Development.Certificate of Svc Encl ML19312D8021980-03-0404 March 1980 Petition to Intervene as Interested State in OL Proceeding. Plant Located on Ohio River Bank Adjacent to States of Ky/Oh Boundary.Participation of Interested State,Although Late,Is Desirable Per Case Law.Certificate of Svc Encl 1983-03-24
[Table view] Category:RESPONSES & CONTENTIONS
MONTHYEARML20072H6581983-03-24024 March 1983 Answer Opposing D Gillman late-filed Petition to Intervene. Proposed Contentions Lack Discernable Meaning.Coherent Presentation Not Made Re Interest & Late Contentions or Reopening Record Requirements.Certificate of Svc Encl ML20069G4671983-03-19019 March 1983 Procedural Reasons for Acceptance of D Gillman 830228 Five Contentions ML20065B8041983-01-21021 January 1983 Contentions 1 - 5 Re Diesel Generator Transmission Gears, Suppression Pool Structural Matls,Boiling Water Transports, Ion Exchange Resin Sys & Electrolyte Accretion Problem ML20054K6241982-06-0707 June 1982 Submission of Contention Re Mark II Owners Group Suppression Pool Safety Analysis ML19327A3231980-07-31031 July 1980 Response in Opposition to Intervenor DB Fankhauser Motion for Admission of Addl Contentions Re Escalating Costs.Party Status as Util Ratepayer Is Insufficient Basis.No Good Cause Shown for Late Submission.Certificate of Svc Encl ML19321A1751980-07-16016 July 1980 Motion & Memorandum Seeking Admission of Addl Contentions. Questions Applicant Financial Capablities & Alleges Errors in FES,NUREG-0625.Process Used for Cost/Benefit Analysis Is Contrary to Nepa.Certificate of Svc Encl ML19323J2321980-06-16016 June 1980 Response in Opposition to Zimmer Area Citizens 800515 Proposed Contentions.Intervenors Failed to Demonstrate Good Cause Under Policy Stated in Commission Decision Overruling ALAB-590.Certificate of Svc Encl ML19329F7721980-06-13013 June 1980 Contentions Per Discussions W/Nrc & Applicant Re OL Application.Alleges Absence of Adequate Communication Sys for Coordination & Direction of Evacuation.Certificate of Svc Encl ML19323H7601980-05-23023 May 1980 Answer to Clermont County,Oh 800512 Petition to Participate as Interested State in Proceeding.Urges Imposition of Same Conditions Imposed on City of Mentor & State of Ky,If Participation Granted.Certificate of Svc Encl ML19323G0641980-05-15015 May 1980 Proposed Contentions Alleging Inadequacy of Evacuation Plans for Plume Exposure Pathway,Due to Absence of Emergency Operations Facility.Certificate of Svc Encl ML19323H9631980-05-12012 May 1980 Petition to Participate in Proceeding by Political Subdivision of State of Oh Having Greatest Population Concentration within 10 Mile Radius of Plant.W/Board of County Commissioners Resolution & Certificate of Svc ML19305E0241980-04-0707 April 1980 Requests Denial of Zimmer Area Citizens & Zimmer Area Citizens in Ky Petitions to Intervene as Interested Person. Petitioner Has Failed to Demonstrate Good Cause for Late Filing.Certificate of Svc Encl ML19309B2561980-03-19019 March 1980 Response to State of Ky 800304 Petition to Intervene as Interested State.If Participation Granted,Re Emergency Planning,State of Ky Must Enter Proceeding in Present Stage of Development.Certificate of Svc Encl ML19312D8021980-03-0404 March 1980 Petition to Intervene as Interested State in OL Proceeding. Plant Located on Ohio River Bank Adjacent to States of Ky/Oh Boundary.Participation of Interested State,Although Late,Is Desirable Per Case Law.Certificate of Svc Encl 1983-03-24
[Table view] 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 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 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 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 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 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 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 1993-08-11
[Table view] |
Text
.
i Procedural Reasons for Acceptance of Doug Gillman's Five Proffered Contentions
"(1) Good cause, if any, for failure to file on time" There was no outstanding alleged and uncorroborated structural alteration existing prior to October 24, 1975 Secondly, '
the en51 neering validity of the Zimmer Power Station - Unit.1 may not have been in question in 1975 whereas 1982 engineering research raises serious questions addressed by Doug G111 man's five contentions and, responsibly, must be raised belatedly.
"(11) The availadlity of other means whereby the petitioner's interest will be protected." ,
At the present time, lack of funds makes a suit for fraud or endangerment impossible. A letter to the Ethics Commision of the State of Ohio mailed March 9,1983 and stating:
"What is the . procedure for some statement by the Commission to be proffered and by what record of the question of whether it is ethical for any spokesperson of the owner's group of the '
Miami Fort Power Station to call the Miami Port Power Station
'a coal fired power plant if the Miami Port Power Station is made from coal fired refined, alloyed and shaped parts but uses nuclear energy to heat steam for the turbine driven dynamos?"
This letter has not been answered as of March 19, 1983. ..
"(111) The extent to which the petitionerb participation may reasonably be expected to assist in developing a sound record." -
For some structural alteration of the Zimmer Power Plant the five proffered contentions strive to show that serious generic and existential defects of the plant are now critical if the -
~ alleged structural alteration of the suppression pool is not addressed properly and will thus serve to create a record that will encompass the desires of all parties for a society 's, of aware consumers as opposed to a society of duped consumers i of which a sound record shall serve aware consumers.
"(iv) The extent to which the petitioner's participation will be represented by existing parties'.'
I At the present time Doug Gillman maintains that the issues he has raised in his five contentions are not being represnted me by any of the parties involved in the Zimmer plant, nor is ggy Doug Gillman himself being represented by any existing parties.
MO 88 "(v) The extent to which the petitioner's participation will mg broaden the icsues or delay the proceeding '
o 05 The proceedin5 accepting the logic of Cestantion2 alone would disblrse all remaining funds slated to the Zimmer plant to Og a set' of solar furnaces and a seasonal industrial expe -
mac viewable in the Zimmer plant.
---.--r.,- . - - - , , - - , , _ . - _ , -- , - - - - , - , - - - - . . .. - - , _ _
$ , '. I-The interest or standing of Doug Gillman in filing his five contentions is many-fold. Any individual capable of engaging any possible mechanisms of discussion or due process regarding some fuel cycle commonly accepted as existing as potentially damaging of the biosphere or humans strengthens the notions of individual responsibility in some governmental settingthe Secondly, byquestion engaging any available mechanisms of due process.
of accepting wanton consumerism or striving towards responsible Thirdly, the consumerism is a question of decisive standing.
mechanisms of accountability by. individuals for any institutions of which the individuals are consumers is such that those mechanisms of accountability by individuals for institutions of their consumption are capable of disintegration without interest or standing by any individuals.
The matter of standing to intervene involves finding a socially acceptable forum to recognize the evolutional structure distribution by the National Grid (Institute of Electronic and Electrical Engineers, Transactions in Power Apparatus and Systems). Within this evolutional structure the power of the entrepreneur engaging commerce and industry to create popular consumer items raises the spectre of encroachments of human habitability by long-lived mutagenic and disease causing This is by-products an thereby decreasing the area of habitable earth.
injury which Doug Gillman allows will irreparably damageIn addition, the quality of his life.
to safeEuard the fus1 cycle of the Zimmer plant have damaged Doug G111 man's phycical and mental health and will continue to unless checked. -
' The matter of standing to intervene with is respect t$oby addressed annoting interest- .
' arguably within the zone of interest'that any usurpation o right of individuals to be free of search or seizure or displacement by some 12ny Corps of Engineers in restructuring .
- the bed of the Ohio River so as to achieve displace without any Public Document Room raises thespectre of a s precedental mechanism which if unaddressed and unchecked create a society in which all persons could be potentially displaced and especially challenges the notion of individual freedoms which Doug Gillman claims under this government and by those statutes which Doug Gillman exercises in the proffe of his five contentions.
claims that his inotion is timely Doug Gillman, the movant,becauce the obsolescence The motion is demonstra his contentions directed did not safety to a significant exist until 1982.
or environmental issue because the allegations regarding structural alterations t is ft structure <
and the obsolescence of the design of the Zim i Y ._
o Doug Gillman, the covant, maintains that a different result would have been reached initially if the,se five contentions and these legal issues been considered .in weighing the notion of industrial self-sufficiency on a seasonal basis.
Finally, these issues could not have been raised earlier because Doug Gillman was awaiting confination of reports of alleged structural alterations to the supression pool of the Zitmer plant which did not materialize in the inspector reports;- Doug Gillman has only recently become aware of the realization of 2 units at Miami Fort which were projected in the Zimmer Preliminary Safety Analysis Report and possible complicity by the Amy Corps of Engineers involving a possible loss of freedoms of Doug Gillman if the Azuy claims that a Public Document Room on military property would be superfluous, and by recently Doug Gillman means the third week of November when he made an impromptu sales trip to Lawrenceburg, Indiana; and also these issues could not have been raised earlier (i.e. in 1975) because the 3 Mile Island incident established that the piisher (ion exchange resin) transfering system is actually a safety related system and that assimilation of this fact by Doug Gillman leads him to bring forth Contentions 3,4 & 5 which deal with the fact that the ion exchange resin transfering~ system at 1
the Zimmer plant is safety-related.
l
.s e
e 9