ML19344A199

Affidavit Supporting Saginaw Intervenors' Petition for Expert Witnesses' & Attys' Fees.Large Funds Expended to Help Ensure Operation & Const W/O Qa/Qc Violations.Organizations Comprising Group Mainly Nonprofit.Certification Encl

ML19344A199
Person / Time
Site:	Midland
Issue date:	05/08/1974
From:	Sinclair M Saginaw Intervenor
To:
Shared Package
ML19344A194	List: ML19344A193 ML19344A197 ML19344A198 ML19344A199
References
NUDOCS 8008060534
Download: ML19344A199 (4)

Text

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Rc Show Cause Hearing -

. Construction Pennit Nos. 81 and 82 AFFIDAVIT OF MARY P. SINCLAIR IN SUPPORT OF PETITION FOR FEES AND EXPENSES MARY P. SINCLAIR, being first sworn on oath, says:

1. My name is Mary P. Sinclair and I am'a resident of Midland, Michigan. I am a member of two of the organizations which com-prise the Saginau Group. As such,'I have been actively involved in the intervention concerning Dockets 50-329 and 50-330, and this Show Cause proceeding and the developments which preceded it. I make this' Affidavit on behalf of the Saginaw Group and its consti-

,tuent organizations.

2. The Saginaw Group has been interested in, inter alia, making sure that Consumers Power Company is not permitted t1 operate or construct nuclear power plants in violation of applicable Q.A.-

Q.C. regulations. I, as well as the Saginaw Group, have a con-tinuing interest in the safety and safe construction of nuclear power plants generally and particularly in respect to Consumers Power Company's Midland facility;

3. The Saginaw Group has expended large amounts of funds in connection with the intervention in Dockets 50-329 and 50-330, and little, if any, funds remain avai able to prosecute that

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l Eintervention through the U. - S. Court of Appeals .cnr the District of Columbia and on remand before the Commission, if such romand occurs; .

4. Of the organizations which comprise _the Saginaw Group, only two . (Sierra Club and U.A.W.) have dues paying members. The re-mainder are not-for-profit organizations which do not have an

, income available to them; l 5. I have' reviewed the finances available to the Saginaw Grcup and have also spoken.to representatives of each of the organiza-tions which comprise the Saginaw Group. There are no funds avail-

'able at all for continuation of the Saginaw Group's participation in this proceeding, either to retain experts in support of the Saginaw Group's position or to pay attorney's fees.- The member groups which do not have funds or dues available to them have not been able to raise funds and the two dues paying member organiza-tions do,not have funds, in addition =to that required for their normal-operations,' available to pay all or any part of the costs and. fees in connection.with this proceeding; L 6 .' Although Sierra Club and U.A.W. areLdues paying organizations,

. they have not been able to ' contribute substantially to the ' funds which-the Sagindw Group has used in its esrlier participation in Dockets 50-329'and 50-330.-- This is because these organizations do not have sufficient filnds over and above those necessary for 1 . 2 --

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their normal duties. To the best of my knowledge, the Sierra Club has .been unable to contribute any funds at any time to this proceeding or the proceedings in connection with Dockets 50-329 and 50-330, and the U.A.W. has been able to contribute only a nominal sum. Substantially all of the funds which were used by the Saginaw Group in connection with the intervention in Dockets 50-329 and 50-330 were raised by donations. The Saginaw Group has made additional efforts to seek contributions and donations for this~ proceeding but has been unable to do so; s

7. The Saginaw Group does not have the fees and expenses neces-sary to continue in this Show cause proceeding and cannot do so '

meaningfully without assistance from the Atomic Energy Commission.

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[ AfaryP.hinclair Saginaw Intervenors Sta t e of ',fichi;ran )

County of .'fidland )

On this eighth day of 5?ay, 1974, before me perionally appeared A'ary P. Sinclair, to me known to be the person who

-executed the same as her free act and deed. _f

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~ e l'y Commission Exniros Notary Public, .2.'idland County,

September 10, 1974.  !!ichigan l

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) CERTIFICATION

. I certify th'at copies of the foregoing Petition and attachments were serve,d, postago prepaid and properly addressed, upon the Atomic Energy Commissioners by service upon the Secre-tary (original and five copies), counsel for the various parti-

' cipants.and Chairman Glaser of the Atomic Safety and Licensing Board on May. 11, 1974.

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