ML19331B002

Informs That Mapleton Intervenors Inadvertantly Left Off Svc List Re Oncoming Licensing Proceedings.Outlines Reasons to Be Admitted as Intervenors.Certificate of Svc Encl

ML19331B002
Person / Time
Site:	Midland
Issue date:	09/08/1978
From:	Marshall W MAPLETON INTERVENORS
To:	NRC COMMISSION (OCM)
Shared Package
ML19331B000	List: ML19331B002
References
NUDOCS 8007240582
Download: ML19331B002 (5)

Text

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,Q MAPLETON INTERVENORS Route 2 gi a y' '

Midland, Michigan 48640 d' '

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(- Y 7 $4 September 8, 1978 -

Nuclear Regulatory Commission t [%9[c -

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Washington, DC 20555

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Dear Sirs:

It has come to the attention of the Mapleton Intervenors that th'ey were inadvertantly left off of the service list concerning the oncoming licensing proceedings for the Consumer Power Company's Midland Nuclear Power Plant at Midland, Michigan.

Justice David Bazolon, Chief Justice of the Federal District Court of Appeals, Washington, DC, by his order, consolidating the Mapleton and Saginaw Intervenors, resulted in Myron Cherry being attorney for both groups. However, Mr. Cherry was notified of his severence by letter dated 2nd of February, 1977, from the Executive Secretary, Steve J. Gadler, P.E., of the Mapleton Intervenors. The NRC was notified of this fact by myself by phone call to NRC in Washington and by appearance of our new attorney, Norton Hatlie, Esq.

of Minneapolis, MN, at the on-going hearing in Chicago, IL at that time. Since it is possible that NRC failed to take notice of these facts, we were.probably left off of the service list, thus an over-sight.

In accordance with 10 CFR 2.714, the Mapleton Intervenors requested mission as intervenors as explained in the Federal Register #43 on the 4th of May, 1978, Page 19304. I, as President of the Mapleton Intervenors, live approximately 1-1/2 miles downwind and downriver from the nuclear plant. The other Mapleton Intervenors live in the same general vicinity.

l l Under the rules, the Mapleton Intervenors contend that: .

l 1) Radiological releases from the nuclear plant will interfere with their health and safety and violates their constitutional rights; la) the air will be contaminated with airborne radioactive nuclides, lb) these nuclides may combine with discharges from Dow Chemical Company to synergestically complicate and add greater dangers because of increased toxicity and hazards to downwind residences, Ic) discharges (radioactive) to the Tittabawasse River will interfere with health, safety and mental tran-quility.

8007240 F M EV wn _ .

Nuclear Regulatory Commission September 6, 1978 Page 2

2) The possible contamination of Dow Products from nuclear "

plant steam; as an example, aspirin is manufactured by a steam process and has great safety and health implications for the general public and for the Mapleton Intervenors, since we use Dow products.

3) The danger from the transportation of radioactive materials over the various roads leading into the City of Midland.

These roads include both Federal, State, City and County.

4) Ice hazard, especially during winter, caused by condensation and icing of the roads and bridges downwind from the plant and the " cooling pond".

5) The fog hazards to highway driving for the same reason as Item 4 above.

6) Spent fuel. Since the Federal Government does not now nor in the foreseeable future have disposable or reprocessing facilities, the spent fuel must be stored at plant site probably in expanded fuel pools which will create serious danger to the City of Midland and to the people therein

, and to the persons and residences of the Mapleton Inter-venors, which includes myself.

7) The plants location within Midland City and Midland County

with its large population areas violates the Nuclear Regulatory Commission siting rules.

8) The plant releases of radiological nuclides both to the air and water environments will subject us to radiation endangering our health and safety and our well being.

9) The general nuisance that will be created by the operation -

of the plant will interfere with our human rights, with our dignity and with the rights we have to maintain our health and safety.

For the above reasons we respectfully request to be admitted as Intervenors.

l Your very truly, l (enBell H. Marshall pl/ Yf fkb i President Mapleton Intervenors WHM:mc

SERVICE LIST Ivan W. Smith, Esq. -

Chairman of the Board Atomic Safety Licensing Board United States Nuclear Regulatory Commission Washington, DC 20555 Lester Kornblith Atomic Safety Licensing Board United States Nuclear Regulatory Commission Washington, DC 20555 Dr. Frederick Cowan 6152 North Verde Trail Apt. B125 Boca Roton, Florida 33433 Michael Milles Isham, Lincoln and Beale One First National Plaza 42nd Floor Chicago, IL 60603 William J. Olmstead Council for NRC Staff Nuclear Regulatory Commission Washington, DC 20555 i Norton Hatlie, Esq. .

l Attorney for Mapleton Intervenors l P. O. Box 103 Navarre, MN 55392

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UNITED STATES OF A> ERICA ,

. NUCLEAR REGULATORY CO>DIISSION In the Matter of ) -

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CO:iSU'.ERS POWER COMPANY ) Docket No.(s) 50-329 OL

) 50-333 OL (Midland Plant, Units 1 and 2)

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CERTIFICATE OF SERVICE I hereby certify that I have this day served the foregoing document (s) upon each person designated on the official service list compiled by the Office of the Secretary of the Commission in this proceeding in accordance with the requirements of Section 2.712 of 10 CFR Part 2 -

Rules of Practice, of the Nuclear Regulatory Commission's Rules and Regulations.

r Dated at Washington, D.C. this

/ day of M 197 .

A M a [/ b a m w Offios /o'/ the Sec'retary of the Commissiort w-

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UNITED STATES OF A! ERICA NUCLEAR REGULATORY COMMISSION

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In the Matter of ) -

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CONSUMERS POWER COMPANY ) Docket No.(s) 50-329 OL

) 50-330 OL Ciidland Plant, Units -1 and 2) )

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SERVICE LIST Ivan W. Smith, Esq., Chairman Joseph Gallo, Esq.

Atomic Safety and Licensing Board Isham, Lincoln & Belae U.S. Nuclear Regulatory Commission 1050 - 17th Street, N.W., Suite 701 Washington, D.C. 20555 Washington, D.C. 20036 Mr. Lester Kornblith, Jr. Myron M. Cherry, Esq.

Atomic Safety and Licensing Board One IBM Plaza U.S. Nuclear Regulatory Cocnission Chicage, Illinois 60611 Washington, D.C. 20555 Gregory T. Taylor. Esq.

Dr. Frederick P. Cowan Assistant Attorney General 6152 N. Verde Trail, Apr. B-125 Environmental Protection Division Boca Raton, Florida. 33433 720 Law Building Landing, Michigan 43913 Counsel for NRC Staff U.S. Nuclear Regulatory Commission Judd L. Bacon, Esq.

Washington, D.C. 20555 Consumers Power Company Legal Department Michael I. Miller, Esq. 212 West Michigan Avenue Isham, Lincoln & Beale Jackson, Michigan 49201 .

One First National Bank Plaza Chicago, Illinois 60603 e

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