ML19318D065

Petition to Intervene in CP Mod Proceeding,Alleging That Unresolved Soil Settlement Problems Will Create Adverse Safety Problems.Certificate of Svc Encl

ML19318D065
Person / Time
Site:	Midland
Issue date:	06/25/1980
From:	Miller T AFFILIATION NOT ASSIGNED
To:	Atomic Safety and Licensing Board Panel
References
NUDOCS 8007070282
Download: ML19318D065 (3)

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In the Matter of k

JUL i 1980 > 'T, grp:, et the secteury 4

Docket No. 50-329-0M CONSUMERS POWER COMPANY

• pse:m & servics 50-330-0M Midland Plants I & II 5:8d 8 (Hearing on Order for Modification of C?)

g /ly \j PETITION TO INTERVENE, Petitioner, Terry R. Miller, petitions to intervene in this proceeding pursuant to Section 2.714 and other pertinent sections of the Nuclear Regulatory Commission's Rules of Practice and states:

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I IDENTIFICATION OF PETITIONER AND ITS INTERESTS TO 33 AFFECTED Terry R. Miller

1. Terry R. Miller is a life-long resident of the State of Michigan, an owner of residential property within the County of Bay, Township of Bangor, and the f ather of three school age children.

Petitioner resides within eighteen miles of the Midland Units I & II.

This petitioner has studied, to the extent that information has been available, the proposed Midland Plants I & II and is concer-ned as set forth in more specific detail below, that the unresolved soil settlement problems at the Midland site will result in an unsafe and inefficient exercise of the use of atomic energy; that it will create adverse effects upon the County of Bay. The safe and efficient operation of these atomic plants is dependent upon the reliability and stability of the foundation of the generator buildings which house the wiring for the back up safety systems. Due to the past record for quality control assurance displayed by Consumers Power Oompany, the petitioner finds that to grant them the right to continue construction of this portion of the plant a serious threat to the well being of petitioners home and family.

II INTERESTS ADVERSELY AFFECTED BY ACTION OF THE COMMISSION

2. Based uDon the interests and concerns of the petitioner identified in (I) above, one or more of the direct interests of the petitioner will be adversely affected by the outcome of this hearing.

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

- ( a) The economic interests of the pet'tioner will De affectd by the construction of this portion of the plant in the following ways:

(1) All construction work in progress (CMIP) is already in the rate base g00 s 0//

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- ( 2) Any modifications of the construction calling for re-con-struction of the generator buildings complex will add to the cost overruns which have' already occurred and will add an even = ore unf air burden upon ratepayers.

(3) As a homeowner petitioner feels that the soil settlement and related problems would eventually lead to unsafe and undesireable conditions that will adversely aff ect the value of. petitioners residential property.

(4) Finally, petitioner questions the integrity of the installations beneath the sinking buildings and their role in the operation of this nuclear plant thereby threatening the health and safety of .the petitioners three children.

Ill STATZ4ENT OF CONTENTIONS

3. Under Sec. 2*.714 Petitioner is not required to frame specific contentions until fif teen (-15) days prior to the holding of a.

special prehearing conference or the hearing conference if no special prehearing conference is held. The petitioner reserves his right under 2.714 to file contentions within the time limits specified in the section identified above.

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UNITED STATES OF AMERICA NUCLEAR REGULATORY COIGIISSION Docket Nos. 50-329-0M In the Matter of CONSUMERS POWER COMPANY 50-330-0M (Hearing on' Order for Midland Plants I & II

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Modification of CP)

CERTIFICATE OF SERVICE

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I hereby certify that I have served copies of the foregoing document entitled " Petition to Intervene" by deposit in the United Stat,es Mail, first class this 25th day of June, 1980 oa'the following:

Secretary of the Commission

- U.S Nuclear Regnlatory Commission Washington, D.C'. 20555 Attention: Docke' ting and Service Branch Executive Legal Director .

U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Michael I. Miller, Esq.

Isham, Lincoln, and Beale One First National Plaza Chicago, Illinois 60690 Terry R. Miller, On this 25th day of June, 1980, before me personally appeared Terry R. Miller to me known to be the person described in and who executed the foregoing instrument, and acknowle,dged that he execu-ted the same as his free act and deed.

h f 8 ,A [w.j/ b- E Date' / Notary Public b ,w,c 24' ;

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