ML19329G117

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Petition in Opposition to Util Motion for Consolidation Re 791206 Order Modifying Cps.Urges Postponement of Response & Requests That Activities Be Stopped Due to Deficiencies in Const & safety-related Structures
ML19329G117
Person / Time
Site: Midland
Issue date: 06/30/1980
From: Marshall W
MAPLETON INTERVENORS
To:
Atomic Safety and Licensing Board Panel
References
NUDOCS 8007140017
Download: ML19329G117 (2)


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,,,r' June 30, 1980 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORF THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of

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Docket Nos. 50-329-OM

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50-330-OM CONSUMERS POWER COMPANY

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(Midland Plant, Units 1 and 2)

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Mapleton Intervenors Petition to the Board The Mapleton Intervenors feel that the board should not. consider Consumers Power Company's motion for any consolidation because Q k

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Proper notice has not previously been given or e

g afforded to Mapleton Intervenors and probably

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Mapleton Intervenors were not informed of Con-

- 4 0359 sumers Power Company's request for a hearing oggsn with request to a December 6, 1979, order modi-gggcot fying the construction permits which would have 0,

been objected to by Mapleton Intervenors had they been notified.

The Mapleton Intervenors moves the board to,rostpone staff response to Consumers motion until all parties have had proper opportunity under the law.

Mapleton In.arvenors further moves the board to stop construction of the Midland Plant as per 10 CFR 55. because of deficiencies in construction, lack of quality assurance related to soil construction activities under and around safety related structures and systems, the settlement of the Diesel Generation Building, the false state-ment in the FSAR, and the safety issue related to the structures which is still unresolved.

Respectfully Submitted, W/ Wendell H. Marshall President of Mapleton Intervenors

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  • Ivan W.

Smith, Esq.

Atomic Safety and Licensing Board l

U. S. Nuclear Regulatory Commission Washington, DC 20555 Frank J. Kelley Attorney General of the State of Michigan 720 Law Building Lansing, MI 48913

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Ms. Mary Sinclair 5711 Summerset Street Midland, MI 48640 l

Michael I.. Miller, Esq.

Isham, Lincoln & Beale One First National Plaza 42nd Floor i

Chicago, IL 60603 stcmic Safety & Licensing Board Panel U. S. Nuclear Regulatory Commission Washington, DC 20555 Atomic Safety & Licensing Appeal Panel U. S. Nr. clear Regulatory Commission Washington, DC 20555 Docketing and Service Section Office of the Secretary U. S. Nuclear Regulatcry Commission Washington, DC 20555

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