ML19318A561

Petition to Intervene Re Order for Mod of Cps.Alleges Inefficient Exercise of Atomic Energy Use Which Will Create Adverse Environ Effects on Cities of Midland,Saginaw & Bay City.Certificate of Svc Encl

ML19318A561
Person / Time
Site:	Midland
Issue date:	06/16/1980
From:	Gilbert C AFFILIATION NOT ASSIGNED
To:	NRC COMMISSION (OCM)
References
NUDOCS 8006230365
Download: ML19318A561 (3)

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, UsNeo )f JUN 181980 > C OE UNITED STATES OF AMERICA 8!ySge NUCLEAR REGULATORY COMMISSION Br y In the Matter of ) s @

CONSUMER POER COMPANY ) Docket No. 50-329-u Midland Plant, Units 1 and 2) No. 50-330-0M PETITION TO INTERVENE Petitioner, Carol Gilbert, petitions to intervene in this proceeding pursuant to Section 2 714 and othe?? pertinent sect-ions of this Nuclear Regulatory Commission's Rules of Practice and states:

I IDENTIFICATION OF PETITIONER AND ITS INTERESTS TO BE AFFECTED Carol Gilbert

1. Carol Gilbert is a resident of Saginaw, Michigan inte-rested in the dissemination of information and stimulation of public awareness and involvement in the study of nuclear power and alternative sources of safe, electrical energy generating sources.

Carol Gilbert resides within twenty five miles of the Mid-land plant.  !

This petitioner has analyzed and studied to the extent that information has been available the proposed Midland plant and is concerned that the order for modification of construction permits for Midland Plant Units 1 and 2 will result in an un-

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safe and inefficient exercise of the use of atomic energy, that it will create deleterious and adverse effects upon the Cities of Midland, Saginaw, Bay City, other parts of Michigan and else-where will contribute to and create adverse environmental ef-fects which can be avoided: and will result in irretrievable and irreversible commitments of natural and other resources, which, considering all of the alternatives and circumstances including the alleged need for electrical power, would not be advantageous.

II INTERESTS ADVERSELY AFFECTED .

3Y ACTION OF THE CCMMISSION

2. Based upon the interests and concerns of the petitioner identified in (I) above, one or more of the direct interests of l the petitioner will be adversely affected by the. order for modi-fication of construction permits for Midland Plant, Units 1 and

2. These interests and how they may be affected are as follows:

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4 (a) The health and safety interests of petitioner will be affected by-the excessive settlement and soil defici-encies of the disel generator building through releases of radiation by)an (b accident releases Radiation at the plant.

as specified in (a) above will adversely affect the property interests (both real and personal) of petitioner residing within twenty five miles from the plant.

(c) Radiation releases as specified in (a) above will adversely affect the mental and physical health of pe-titioner, lifespan.

resulting in medical bills and the shortening of (d) The economic interests of the petitioner who is a ratepayer of Consumer Power Company will be adversely affected due to the raise in rates that will be caused by operation (or inability to operate) of the proposed plant.

WHEREFORE, Petitioner requests that a hearing be held on order for modification of construction permits and that she be permitted to intervene in the proceedings.

Respectfully submitted, l

Carol Gilbert 4

f 9C3 N r t.

$oginow, M148601

W UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION In the Matter of )

CONSUMER PO'ER COMPANY ) Docket No. 50-329-0M Midland Plant, Units 1 and 2) No. 50-330-0M l CERTIFICATE OF SERVIC" I hereby certify that I have served copies of the foregoing l document entitled " Petition to Intervene" by deposit in the 1 United States mail, first class this 16th day of June,1980 on the following:

Secretary of the Commission U.S. Nuclear Regulatory Commission g Washington, DC 20555 9 Attn Docketing and Service Branch g ff  : p US E Executive Legal Director ~i ,

U.S. Nuclear Regulatory Commission 05 JUN 1 8 $80 > -4 Washington, DC 20555 ~

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omce sien seaen l pocketint &W g/ .

Michael I. Miller, Esq. 6 pand Isham, Lincoln and Beale #

One First National Plaza

• y Chicago, Illinois 60690 .

b Carol Gilbert On this 16th day of June, 1980, before me personally appeared Carol Gilbert, to me known to be the person described in and who executed the foregoing instrument, and acknowledge that she executed the same as her fact act and deed.

My commission expires: 11-5-1983 June 16, 1980  % et%d Date Notary Pub 4c Mary Lou VanWormer Exp: 11-5-1983 Saginaw County, Michigan