ML19329F510
| ML19329F510 | |
| Person / Time | |
|---|---|
| Site: | Midland |
| Issue date: | 12/20/1971 |
| From: | Gadler S AFFILIATION NOT ASSIGNED |
| To: | US ATOMIC ENERGY COMMISSION (AEC) |
| References | |
| NUDOCS 8006300717 | |
| Download: ML19329F510 (9) | |
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UNITED STATES OF AMERIUA ATOMIC ENERGY COMMISSION In the Matter of Docket Nos. 50-329 50-330 CONSUMERS POWER COMPANY PETITION FOR LEAVE (Midland Plant, Units 1 & 2)
TO INTERVENE Steve J.
- Gadler, P.E.
hereby petitions the Atomic Energy Commission (Commission) for leave to intervene as a party in the above-captioned natter pursuant to 10 Code of Federal Regulations (CFR), Section 2.714 and SUPPLEMENTARY NOTICE OF HEARING ON APPLICATION FOR CONSTRUCTION PERMITS issued by the Commission, in the above-captioned matter, on November 29, 1971
- 3IHIS DOCUMENT CONTA POOR QUAUTY PAGES I.
INTEREST OF PETITIONER Your Petitioner has direct interests affected by this proceeding.
The high quality of life enioyed bv all citizens in the United States, which is chared by vour Petitioner, is directly dependent upon the preservation, protection, and improvement of the physical environment in which your Petit-ioner lives, travels, and conducts his daily activities.
Your Petitioner, and other persons similarly situated, would suffer serious harm from environmental dooredation 8006300'7/} h
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The interest of your Petitioner, therefore, in-cludes but is not limited to the prevention of the follow-ing environmental degredation:
the addition of radiation in the hydrologic cycle, the addition of radiation to the earth's atmosphere, the addition of radiaticn to the earth's soil, and the interest of your Petitioner to use and enjoy all of the foregoing together with the flora and fauna found therein.
Your Petitioner reserves the right to extend his interest to any findings of fact, disclosures of any kind, or other evidentiary matters that arise with-in the scope of the proposed public hearing, or are in any way incident to the proposed public hearing.
II.
CONTENTIONS Your Petitioner submits the following contentions as being in reasonably specific detail, which substantiate his interest and which are clearly within the jurisdiction of the Commission as set forth in the SUPPLEMENTARY NOTICE OF IIEARING 'ON APPLICATION FOR CONSTRUCTION PERMITS and in Appendix D to 10 CFR, Part 50 1.
Your Petitioner contends that, with respect to the environment, no threshold has been established below which no damage from radiation may occur.
Objective evidence l'
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contrary to this proposition does not now exist. 'Indeed, evidence which supports this allegation is now being deve-loped on an increasing scale.
Therefore,'all radiation must be viewed as an agent of environmental degredation and no additional radiation should be added to the radiation burden presently found in the environment.
2.
Your Petitioner contends that the projected radio-active releases from Midland Plant, Units 1 & 2 have not been and must be evaluated, for purposes of protecting the environment, in the full context of the total annual radio-active releases occurina from all sources.
Your Petitioner contends further that these releases and the releases from all other sources must be projected into the future far enough to deternine that at no time will they contribute a harmful burden of radiation exposure to the environment.
3.
Your Petitioner contends that the radioactive dis-charges and wastes resulting from the operation of Midland
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Plants, Units 1 & 2, to the air, the water, and the soil l
present a long-term hazard to the environnent when con-sidered along with other sources of radiation planned, being built, and those to be planned and built in the future in the United States.
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Your Petitioner contends that the procedures and precautions to be employed for the handling, transporting and storage of high-level radioactive wastes which will be generated by the Midland Plant, Units 1 & 2, will not pre-vent, nor can reasonably be expected to prevent the addit-ion of radiation to the environment.
5.
Your Petitioner contends that the procedures and precautions to be employed for the containment of low-level radiation emissions associated with the day-to-day operation of the Midland Plant, Units 1 & 2 will not adequately prevent, nor can reasonably be expected to pre-vent the addition of radiation to the environment.
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Your Petitioner contends that the procedures and precautions to be employed in' connection with the manu-facture of those products by Dow Chemical Company, which include in the manufacturing process steam to be generated at the Midland Plant, Units 1 & 2, will not adequately pre-vent, nor can reasonably be expected to prevent the addition of radiation to the environment.
7.
Your Petitioner contends that the Emergency Core Cooling System (ECCS) to be installed in the Midland Plants, Units 1 & 2 represents the main line of defense for the environment in the event of a loss of coolant accident.
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p're s en t, your Petitioner contends, that the simulated tests on small scale models of the ECCS do not present a proper data base from which to extrapolate the conclusion that the full scale ECCS would perform properly under actual con-ditions in the event of a loss of coolant accident.
Your Petitioner contends further that the research and develop-ment conducted on the ECCS has been insufficient to date and thus cannot form the basis for any conclusion as to the reliability of the ECCS to perform its assigned mission in the event of a loss of coolant accident.
Consequently, your Petitioner contends that the tresent state of develop-ment of the ECCS is insuf ficient to nrovide assurance that no environmental deqredation will occur in the event of a loss of coolant accident.
Your Petitioner, Steve J. Gadler, P.E., on this IO $k day of December, 1971, in accordance with the Comnission's Rules of Practice and 10 CFR, Part 2, submits this petition as a request for leave to intervene in the !! EARING ON APPLI-CATION FOR CONSTRUCTION PERMITS which would authorize the Applicant Consumers Power Company to construct the Midland Plant, Units 1 & 2 as published in the Federal Register (35 F.R. 16749).
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,o Your Petitioner, therefore, does request a public hearing on all the contentions included in this petition, and any other matters that affect the interest of your Petitioner, to protect the legal interest of your Petitioner as well as the public interest.
All correspondence relat-ing to this petition are to be addressed to the following persons:
Steve J. Gadler, P.E.,
2120 Carter Avenue, Saint Paul, Minnesota - 55108 and Itoward J. Vogel, Esq., 814 Flour Exchange Building, Minneapolis, Minnesota - 55415,.
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Steve
- dler, P.E.
Subscribe and sworn to before..me this p "
day of Deconher, 1971
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Notary Pfblic. Hennepin County. Minn.
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/ MY CosVnission Expires May 20,1923
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VERIFICATION s...........',...
STATE OF MINNESOTA COUNTY OF IIENNEPIN ss.
Steve J. Gadler, P.E.,
being first duly sworn and unon oath deposes and says that he is the Petitioner naned within the forcqoing Pet' tion; that he has read the foregoing Petition and knows the contents thereof; and that he agrees l
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with the facts in said petition and that the same are true to his knowledge except to those matters alleged on information and belief and to those matters he believes them to be true.
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- Gadler, P.E.
Subscribed and sworn to befor me thisf.o D day of Decemb 1971 W
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UNITED STATES OF AMERICA ATOMIC ENERGY CONISSION In the Matter of
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CONSUMERS POWER COMPANY
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Docket Nos. 50-329, 330 (Midland Plant, Units 1 and 2)
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C'ERTIFICATE OF SERVICE I hereby certify that copies of a letter fr a Howard J. Vogel dated December 22, 1971 with attached Petition for Leave to Intervene of Steve J. Gadler dated December 20, 1971 in the captioned matter have been served on the following by deposit in the United States mail, first class or air mail, this 27th day of December 19,1:
Arthur W. Murphy, Esq., Chair: nan Robert Lovenstein, Esq.
Atmic Safety and Licensing Board Jerome E. Sharfman, Esq.
Columbia University School of Iav Harold F. Reis, Esq.
435 West 116th Street, Box 38 Lovenstein, Newman & Reis New York, New York 10027 1100 Connecticut Avenue Washington, D. C. 20036, H. W.
Dr. Clark Goodman Professor of Physics Richard G. Smith, Esq.
University of Houston Smith & Brooker, P. C.
3801 Cullen Boulevard 703 Washington Avenue Housten, Texas 77004 Bay City, Michigan 48706 Dr. David E. Hall Harold P. Graves, Esq.
Los Alamos Scientific IAboratory Vice President and General P. O. Box 1663 Counsel Ice Alamos, New Mexico 87544 John K. Restrick, Esq.
Consumers Power Company Dr. Stuart G. Forbes 212 West Michigan Avenue 100 Tennessee Avenue, Apt. 37 Jackson, Michigan 49201 4
Redlands, California 92373 Mr. R. C. Youngdahl i
Thomas F. Engelhardt, Esq.
Senior Vice President David E. Kartalia, Esq.
Consumers Power Company j
Robert Newton, Esq.
212 West Michigan Avenue Regulatory Staff Counsel Jackson, Michigan 49201
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U. S. Atomic Energy Commission i
Washington, D. C. 20545 Honorable Frank Olds, Chairman l
Midland County Board of Supervisors i
623 St. Charles Street j
Midland, Michigan 48640 l
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1 50-329, 330 page 2 Honorable Jerome Maslovski Milton R. Wessel, Esq.
Assistant Attorney General J. Richard Sinclair, Esq.
State of Michigan Allen Kezsbom, Esq.
Seven Story Office Building Kaye, Scholer, Fierman, Hays 525 West Ottava and Handler Lansing, Michigan 48913 425 Park Avenue i
New York, New York 10022 Honorable Curtis G. Beck Acsistant Attorney General William A. Groening, Jr., Esq.
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State of Michigan James N. O 'Connor, Esq.
Seven Story Office Building The Dow Chemical Company 525 West Ottava 2030 Dov Center Lansing, Michigan 48913 Midland, Michigan 4C640 Myron M. Cherry, Esq.
William J. Ginster, Esq.
Suite 1005 Merrill Building, Suite 4 109 North Dearborn Street Saginav, Michi an h8602 E
Chicago, Illinois 60602 Mr. Wendell H. Marshall Anthony Z. Roisman, Esq.
RFD No. 10, Mapleton Berlin, Roisman and Kessler Midland, Michigan 486ho 1712 N Street, N. W., 4th Floor Washington, D. C. 20036 Irving Like, Esq.
Reilly, Like and Schneider James A. Kendall, Esq.
200 West Main Street Currie and Kendall Babylon, New York 11702 135 North Saginav Road Midland, Michigan 48640 Honorable William H. Ward Assistant Attorney General Dr. Wayne E. North, Chairman State of Kansas Midland Nuclear Power Cc=mittee Topeka, Kansas 66612 P. O. Box 335 Midland, Michigan 486ho Senn /, 7)? /d <$L Of' ice of the Secretary of the {6::: mission
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f cc: Mr. Murphy Mr "agelhardt ASLBP N. Brown H. Smith k.