ML19344A162
| ML19344A162 | |
| Person / Time | |
|---|---|
| Site: | Midland, Shoreham File:Long Island Lighting Company icon.png |
| Issue date: | 06/02/1978 |
| From: | Scott Freeman, Kelley F, Gabe Taylor MICHIGAN, STATE OF |
| To: | |
| Shared Package | |
| ML19344A163 | List: |
| References | |
| ISSUANCES-OL, NUDOCS 8008060461 | |
| Download: ML19344A162 (4) | |
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NUCLEAR REGULATORY COMMISSION
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9 In the Matter of CONSUMERS POWER COMPANY Docket Nos. 50-32904 and 50-330cL I
(Midland Plant, Units 1 and 2)
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VERIFIED PETITION OF FRANK J. KELLEY, ATTORNEY GENERAL OF THE STATE OF MICHIGAN, FOR LEAVE TO INTERVENE and i'
AFFIDAVIT IN SUPPORT OF THE PETITION OF l
FRANK J. KELLEY, ATTORNEY GENERAL OF THE t
STATE OF MICHIGAN, FOR LEAVE TO INTERVENE FRANK J. KELLEY Attorney General Stewart H. Freeman Assistant Attorney General l
in Charge Environmental Protection Division l
Gregory T. Taylor Assistant Attorney General BUSINESS ADDRESS:
720 Law Building Lansing, MI 48912 (517) 373-7780 t
t Dated: June 2, 1978
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l UNITED STATES OF AMERICA NUCLEAR REGULATORY CCMMISSION i
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Docket Nos. 50-2 CONSUMERS POWER COMPANY and 50-330 (Midland Plant, Units 1 and 2) 4
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VERIFIED PETITICN OF FRANK J. KELLEY, ATTORNEY l
GENERAL CF THE STATE OF MICHIGAN, FOR LEAVE TO INTERVENE.
NOW COMES Frank J. Kelley, Attorney General for the State of Michigan, by Stewart H. Freeman and Gregory T. Taylor, Assistant Attorneys General, and petitions this Comission for leave to intervene in this matter on behalf of the People of the State of Michigan.
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INTEREST CF THE PETITIONER.
Frank J. Kelley is the Attorney General of the' State of Michigan holding such office pursuant to the provisions of Michigan Const 1963, art 5, $21.
He is the head of the j
Department;Jf the Attorney General created by the Executive Organization Act, Chapter 3, 1965 PA 380; MCLA j
l 16.150 et seq; MSA 3.29(50) el m. The Attorney General I
files this petition on behalf of the People of the State of Michigan and its governmental agencies.
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t The Attorney General, as the chief law enforcement of ficial for the State of Michigan, represents the 19 principal
-departments of state government, nany of which have a direct interest in the operating procedures of the Midland plant.
Among the departments with a direct interest are the Michigan Department of Natural Resources, the primary agency for 4
enforcement of environmental laws, and the Michigan Department of Public Health.the primary department for enforcement of laws relating to public health.
The Attorney General possesses both statutory and common law authority to protect the public health, safety and welfare.
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B.
L HOW PETITIONER'S INTEREST WILL BE AFFECTED.
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NATURE OF PETITICNER'S RIGHT UNDER THE ACT 'TO BE MADE A PARTY TO THE PRCCEEDING.
l The Atomic Energy Act of 1954 expressly recognizes the interest of the States in the regulation and operation of nuclear plants. See 42 USC 2021. The Attorney General, as the legal representative of the citizens of Michigan
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has the right to represent the people of Michigan and its agencias in all actions, including federal administrative f
actions.
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2.
THE EXTENT OF PETITIONER'S PROPERTY, FINA'1CIAL, i
OR OTHER INTEREST IN THE PROCEEDING.
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The State of Michigan has been blessed with 1,396 square miles of inland water and 38,575 square miles of Great Lakes j
water area. Michigan Manual, 1977-78, p. 1.
Additionally, Michigan has 56,818 square miles of land, 12% of which are State-owned. Clearly, the operations of the Midland plant, with the possibility of affecting the surrounding land, water, and air is of interest to the State.
More bnportantly, the health, safety and welfare of Michigan's nearly 9 million citizens is likely to be affected by the operation of the Midland plant.
3.
THE POSSIBLE EFFECT OF ANY ORDER WHICH MAY BE ENTERED IN THE PROCEEDING CN THE PETITIONER'S INTEREST.
The Commission will be entering orders regarding the operating regulations for the Midland plant. Naturally, these orders will have an impact upon the citizens of Michigan and its agencies. The Attorney General asserts that the State of Michigan should be grented intervention in order to have its concerns addressed in this forum.
FRANK J. KELLEY Attorney General Stewart H. Freeman Assistant Attorney General Grego Taylor Assistant Attorney General Environmental Protection Division
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720 Law Building Lansing, MI 48913 (517) 373-7780 Dated: June 2, 1978 4
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