ML20071J209
| ML20071J209 | |
| Person / Time | |
|---|---|
| Site: | Midland |
| Issue date: | 05/23/1983 |
| From: | Sinclair M SINCLAIR, M.P. |
| To: | Atomic Safety and Licensing Board Panel |
| References | |
| NUDOCS 8305260169 | |
| Download: ML20071J209 (2) | |
Text
f/z 3 /f 3 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION 00LKETED "pFC Before the Atomic Safety and Licensing Board
'83 MY 25 P1 :57 In the Matter of:
)
Docket Nos. 50-329.. _ _...
CONSUMERS POWER COMPANY
)
h_
)
Midland Plants, Units 1 and 2
)
Operating License INTERVENOR MARY SINCLAIR'S RESPONSE TO CONSUMERS POWER CO'S REVISED MOTION TO REQUIRE SUBMISSION OF CROSS-EXAMINATION PLANS, DESIGNATION OF LEAD INTERVENORS, AND ESTABLISHMENT OF TIME LIMITS ON CROSS-EXAMINATION In response to the points that Attorney Michael Miller has raised on cross-examination for the evidentiary hearings beginning June 1,1983 and sub-sequent hearings, I have these comments.
I do not agree with the basic premice Michael Miller is making 1.e., that it is the intervenors who are contributing most to the extensive record of this hearing.
If Consumers Power Co. and Bechtel had not made the grievous error in compacting soll' improperly at the Midland site, this proceeding with all its time consuming and costly aspects would not be necessary. The fact that they knew the soil to be compacted improperly in 1978 and yet went ahead to build 5 safety related buildings on it, is shocking proof of what little con-cern they have for public health and safety and the basic integrity of this project. The fact that the Nuclear Regulatory Commission was aware in 1978 of the soil compaction problem and yet stood by and allowed Consumers Power Co. 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 negligance, no one should wonder why the citizens who are making the extraordinary effort needed to participatein these hearings should be examining all the issues as carefully as possible. After all, it was Consumers Power Co. that called for the hearings in order to forestall further the corrective action attempted by the hTC in their December 6,1979 Order.
8305260169 830523 O-)
gDRADOCK05000
~
What should be scrutinized as a real waste of time are the constant and lengthy objections of the Consumers Power Co.'s attorneys to any substantive issue that citizen intervenors wish to raise. It is that tangle of words in their attempt to defend the in' efensible that is burdening the d
record.
In response to the plan offered by the Applicant, I have the following responses.
- 1) I will attempt to file, if possible, cross-examination plans with the Board in accordance with the Commission's May 20, 1981 Policy Statement.
It is not always possible to determine the direction that cross-examination shall take, however. That depends on the answers.
- 2) I expect to do my owm cross-examination in areas that are separate from those covered by other intervenors unless it appears to me that they have neglected significant points.
- 3) I do not agree to this attempt to limit or foreclose Barbara Stamirls' participation.
- 4) I will make some attempt to estimate the time needed for cross-examination, but I cannot be held to this time frame if the objections of the Consumers' attorneys or of the Staff are so frequent and lengthy that the substantive issues I am trying to arrive at are made difficult to get into the record.
Respectfully submitted, l.A. -sLA v.
U Mary Sinclair/}'
cc: Charles Bechhoefer, Esq.
Dr. Frederick P. Cowan Dr. Jerry Harbour James E. Brunner William D. Paton, Esq.
Ms. Barbara Stamiris l
Mr. Wendell H. Marshall Secretary, Docketing & Services Michael I. Miller, Esq.
l Lynne Bernabei i
l i
(
-