ML20073E590

Recants Encl 830319 Addendum to Procedural Reasons for Acceptance of Gillman Five Proffered Contentions

ML20073E590
Person / Time
Site:	Zimmer
Issue date:	04/08/1983
From:	Gillman D AFFILIATION NOT ASSIGNED
To:	Barth C NRC OFFICE OF THE EXECUTIVE LEGAL DIRECTOR (OELD)
Shared Package
ML20073E584	List: ML20073E590
References
NUDOCS 8304150243
Download: ML20073E590 (4)

Text

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,, 831887 April 8, 1983 gl fei****

• Mr. Charles Barth ad ,ff Counsel for NRO Staff ep ,

United States Nuclear Regulatory Commission r '

Washington, D.C. 20555 . .

Dear Mr. Barths I wculd like to recant the addendum I sent to you dated March 19, 1983 and replace it with the add.endum enclosed herein.

Sincerely, j 14 O Gillman 2109 $t. James Pl.

Cincinnati, Ohio 45206 8304150243 830413

• PDR ADOCK 05000358 O PDR s l

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( PROCEDURAL REASONS FOR A00EPTANOE OF DOUG GILIMAN'S FIVE PROFFERED 00NTEITIONS

"(1) Good ,Icause, 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 engineering 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 availability of other means whereby the petitioner's interest will be protected."

Doug Gillman does not have the funds or legal knowledge to raise the questions of engineering problems in a court of law that would address design problems at the Zimmer Power Station -

Unit 1 ( ZPS-1 ) .

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"(iii) The extent to which the petitioner's participation may " i reasonably be expected to assist in developing a sound record. l Doug Gillman's participation as a petitioner will develope a '

sound record because his five proffered contentions are directly concerned with the engineering design, construction and alterations of ZPS-1. .

"(iv) The extent to which the petitioner's participation will be represented by existing parties."

At the present time Doug Gillman maintains that the issues he has raised in his five contentions are not being represented by any of the parties involved in the ZPS-1, nor is Doug Gillman himself being represented by any of the existing parties.

"(v) The extent to which the petitioner's garticipation will broaden the issues or delay the proceeding The proceeding accepting the logic of Contention 2 alone would disburse all remaining funds slated to the Zimmer plant to a set of solar furnaces and a seasonal industrial experience. The other contentions serve to address the obsolescent structures viewable in the Zgamer plant.

The interest or standing of Doug Gillman in filing his five contentions is many-fold. Any individual capable or engaging any ~

possible mechanisms of discussion or due process regarding some fuel cycle nommonly accepted as being potentially damaging of the biosphere or humans strengthens the notions of individual responsibility in any governmental setting by engaging any available mechanisms of due process. Secondly, the question of accepting wanton consumerism e

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l or striving towards responsible consumerism is a question of l j decisive standing. Thirdly, the neohanisms of accountability by l l

individuals for any institutions of which the individuals are consumers 'is such that those mechanisms of accountability by individuals j for institutions of their consumption or others consumption ara

! capable of disintegration following lack of interest or standing .

! by any individuals.

The matter of standing to intervene involves finding a socially

! acceptable forum to recognize the evolutional structure of some eminent domain consumer item such as centralized electricity l

distribution by the National Grid (Institute of Electronio and

Electrical Engineers, Transactions in Power Apparatus and Systems).

i Within this evolutional structure the power of the individual as entrepreneur to engage industry and commerce to create popular consumption raises the spectre of encroachments of areas of human habitation by long lived mutagenic and disease causing by-products which thus decrease the area of habitable earth. This is an injury which Doug Gillman allows will irreparably damage the quality of his life. In addition, those measures used to safeguard the fuel t

cycle of the ZPS-1 and the financial interests of the utilities and electricity reliability councils and the investors have damaged Doug G111 man's physical and mental health and the physical and mental health of friends and relations of Doug Gillman and will continue to do so unless checked.

l The matter of standing to intervene with respect to an interest

! ' arguably wit,hin the zone of interest 8 is addressed by noting

, that the Constitution of the United States mandates two eminent domain structures post roads construction for the post office l

and the raising and supporting of indivduals for the army.

centralized electricity is a structure which has achieved the i

status of eminent domain much as the telegraph, telephone, cable television and other consumer moieties. There is nothing l

constitutional about centralized electricity or the other non-

mandated eminent domains. All that is reasonably apparent is

that people are displaced and their lives ruined by the wanton i

consumerism inherent in non-mandated eminent domains. Further, i it may be the case that eminent domain structures are undergoing i a structural evolution to provide services for technological ecialists engaged in political, social or information othe harassment and flow sp/or control, and buy-ins by organized elements of the society of people unaware of information flow structures, i in particular the advertising sector, by using certain eminent domain structures as antennas for bioelectromagnetic radiation propagation for the purpose of psychophysical signalling or an eleotzumagnetic hookup of machinery to the non-consenting human sensorium. Although the main problem of the ZPS-1 plant is structural defects and poisonous by-products, failing to address -

the evolution of The National Grid is most certain to be disastrous.

Doug Gillman, the novant, claims that his motion is timely because the obsolescence demonstrated by the references of his contentions did not exist until 1982. .The motion is directed to a significant safety -

or environment set of issues becuase the allegations regarding structural alterations to the ZPS-1 suppression pool deal with a W .

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! safety related structure, and the obsolescence of theldes tions gn-i-

' of the 'Zimmer plant is critical _with. respect _.to_ alleged a tera of a safetpr. structure. . ._. _ _ .

..._ . - _ ___ h been reached initially if these five contentions Dou6

'l issues had been considered in weighing the notion of industrial-- _.___

j self-sufficiency.dn a. seasonal basis.

Finally, these iss a could not have been raised earlier because - t ral__

Doug Gillman was awy.iting confizzation Secondly, these of reports o j._. issues---

alterations to the g Radiological ~~

materialize in the NRO inspector reports. ~ ~ ' ~

could not have bead raised earlier because til after-the Bu l published Finally any%hing these issues about bioelectromagnetic oculd not have been radiation raised un earlier because_ resin 1980.

tue Three Mile Island incident established that the ion exchange --

(polisher) system ic moutally a safety related systemforth and _that .

assimilation bf this fact by Doug Gillman leads him to bring h nge

_. . Oontentions 3,4, and 5 which deal with the fact that thed ion exc a i

resin transfering system in the ZPS-1 plant is safety-relate .M-g h =6

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