ML20091A046
| ML20091A046 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 03/13/1992 |
| From: | Dow R, Dow S DISPOSABLE WORKERS OF COMANCHE PEAK STEAM ELECTRIC |
| To: | NRC COMMISSION (OCM) |
| References | |
| CON-#192-12716 CPA, OL, NUDOCS 9203260028 | |
| Download: ML20091A046 (5) | |
Text
l tm - 13. '92 15: 00 QUICK OFFICE _ SUPPLY 412-E29-7269 P.i 1
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';LtriiED UNITED STATES OF AMERICA
!6HkC NUCLEAk REGULATORY COMMISSION cOMHisSIONERS:
- 92. tia 13 P2 :34 Ivan Salin,' Chairman Kcaneth C. Rogers
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James R. Curtiss
-Forrest J. Remick E. Gail de Planque 6
In>The Matter oft O
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. TEXAS UTILITIES ELECTRIC COMPANY Docket hos. 50-445-OL O
50-446-OL (Comanche Peak. Steam Electric 0
50-44$-CPA 6
Station, Units'1 and 2) 5 SUPPLEMENT TO MOTION TO REOPEN THE RECORD Comes now, Sandra Long Dov dba Disposable Workers of Comanche
-Peak Steam Electrio. Station, and R. Micky Dow, hereinafter inter-venort, and file this, Their supplement to the motion to reopen the L
record, and would show, that, L
I.
l Sionificance of original Whistleblowers_ Paramount
- It is'important'that the Commission take special notice-of Lhu
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exhibits attached to<the original motion, and the_ applicant'sLresponse p
thereto, nat only in this proceeding.but in the collateral proceed-ing inLthe D.C. Circuit Court of Appeals.
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It-has.been : the :consistant, and continuing,.practise of th 3 ap-pJicant to~make mention:of the age:of;the-violations,-reports, ance
--memorandum, but'do.not make any reference to-the validity of these
- reports.
The_ applicant hac.never~ denied the existence of:these vio-lations, nor haventhey1ever;made notice of the correction of any of these violations.-
The applicant _uses this theory in an attempt to destroy the case
' SUPPLEMENT TO MOTTON TO REOPEN-THE RECORD ~1-
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9203260028 3RO315 h 3; PDR ADOCK 05000445
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of those intervonors, and turns its back to the importance of the in-formation itrelf.
The whistleblevers mentioned (i.e. Hatley, Joneu, et al.) have inf ormation ol' major safety and construction violations that have never been placed on the record, addressed, or corrected.
It is true that this informandon, for some part, lo quite old, and that is why it has such import nov.
This information was kept from the original ASLD by an illegal settlement agreement that these c
individuals signed without knowing Lha' when they signed they scaled this information trom the record.
None o# their information has ever been placed on the record, and these individuals were never allowed to testify, even though both the applicant and the NRC knew they had this information to present.
II.
FULL MEASURE OF ORIGTNAL HRARIMCS_NOT REAC1IED One of the most important criteria which is addressed by any of the licensing hearings is the integrity, the ability, and the com-petance of the_ applicant to safely operate a nuclear facility.
The past record of this applicant is clearly contrary to these criteria, as was evidenced by the double procedurcs. The present conduct of the applicant is not only contra-indicative of those abilities, but will show a clear downward spiral that is prima facia of the applicants' inability to adhere to those critoria, as well au the applicant's at-titudo of ignoring those criteria completely when needed.
EVTDENCE OF CRIMINAL. INTENT Not only can these movants provide the Commission with proof of material false statements and perjury, made by both the applicant, and t-the intervenor group CASE, at the original hearings, but vill intro-duce a handwritten memo, in the handwriting of one Billie Pirner Garde,
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SUPPLEMENT 70 MOTTON TO REOPEN THE RECnRp l
1%R 13 '9219 07 OUIO: OFFICE SUPPLY C-sis-i'269 "a
vhich paraphrased here, will state that "The only way ve can hope to ever rea112e any money out of this lu to drag out the hearings and i
bleed-TU.".
III.
ENVIRONMENTAL ISSUES NEED f3POSURE The m itters of the toxic en-site and off-si?e vaste dumps need a
much closet scrutiny.
The evidence of these dumps has been kept from the NRC for a period in excess of two years, and the EPA is currently conducting criminal investigations legarding the withholding of evi-dence by both Linda Porter and CASE.
The fact thal fuel has been on-site cince 1982, without public knowladge needs to be addressed.
CONCLUSIONS There is no doubt that these movants vill prevail in their at-tempts to intervene or have the record of this matter reopened.
The evidence la f complete perponderanco, and corroborative.
That a great harm vill cone to all who live near this facility is evidenced by the construction and operation violations which vill ultimately culminato in an accident.
The utility vill suffer moderate-financial damage, but solely as a result of their own ineptitude.
This facility.can be easily-converted into a lignite coal plant, allowing the applicant to recoup their-Josses from the bungled construction and operation of the present facility.
To prevent an accident is certainly in the public good, but also the conversion-and operation of a lignite facility will not only increase the labor need on *.he ahort term, for the conversion process; but, vill also increasu thL labor need for the long-term day-to-day operation of such a f acility, bringing more jobs to the commun-ity, and more mcney_in the local economy.
WHEREFORE, PREMISES ~ CONSIDERED, it is imperative that the Commis-SUPPLEMENT TO MO 70N TO_ REOPEN THE RECORD !
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mR 13 '92 15:03 OUICK OrrICE if PLY 412 ca -id 8
^5 cion roopen the record of this matter, and suspend the license pending new hearings en the issues.
Two very important features remain, the Texas Public Utilities Commission has refused to disallov 1.38 Billion dollars due to mis-management by this applicant, and, although the Commission thates in its pleadings to the D.C. Circuit Court of Appealo that the matter of the nine NCR's has been resolved, they base that on inspection of the WRITTEN records in the TU files, and as we have demonstrated hereina-hovo, Dobie Hatley physically altered those documents in the TU files with such import that she was granted immunity by the Department of Justice for her part in those activities.
The inspection of the ree-ords alone, with this testimony still untendered is useless, and most certainly, not reliable.
To simply accept this written information, having the certain knowledge of alterations, and not have a physical inspection is to compound the first violation completely.
Respectfully uubmitted, m d /t a.
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A SANDRA LONG DOW dba Q' POSADLE' WORKERS OF COMANCHE PRK STEAM ELECTRIC STATION, pro se 8 Great Southern Shops, Suite 200 Bridgevill, Pennsylvania 15017 (412) 221-5319 k\\
R. MICKY DOW, pyo 'ie" 8 Great Southern Shops, Suite 200 Dridgeville, Pennsylvania 15017 (412) 221-5319 SUPPLEMENT TO MOTTON TO REOPEN THE RECORD tw.;
- H 15:09 01)ICK OFFICE' SUPPLY 412 c s ic?
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CERTIFICATE OF SERVICE This is to certify that a true and correcp2c4tl9 M ESd3doregoing Supplement To Hotion To Reopen The Record vaa sont by telefax to the
. i t ' t;. y parties listed below, on this the 13, day of M$$$hs.'.l1992.
m Afriant
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SAMUEL J. CHILK Secretary of the Commi.uion U.S. Nuclear Regulatory Commiosion 11555 Rock Pike F,0 c kvil10, Maryland 20852 JANICE MOORE, ESQUIRE office of the General Counsel U.S. Nuclear Regulatory Commission 11555 Rock Pike Rockville, Maryland 20852 GEORGE L. EDGAR, ESQUIRE Newman & Holtzinger, P.C.
1615 L Streoc, N.W.,
suite 1000 Washington, D.C.
20036 l
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