ML20040C066

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Affidavit of Christa-Maria Re Military Plane Flights Over Facility.Certificate of Svc Encl
ML20040C066
Person / Time
Site: Big Rock Point File:Consumers Energy icon.png
Issue date: 12/31/1981
From: Christamaria
BIER, MILLS, CHRISTA-MARIA, ET AL
To:
Shared Package
ML20040C064 List:
References
ISSUANCES-OLA, NUDOCS 8201270227
Download: ML20040C066 (3)


Text

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s mITED STm:S OF ABERICA NICEEAR REGUIA'IORY CIMESSION ATOMIC CAFErf AND LICENSING BOARD In The Matter Of I

Docket' No. 155 CDNSUMERS POKER CDPANY (Spent Fuel Pool Modification)

(Big Rock Point Nuclear Plant)

)

STATE OF MIGIGAN

)

(DUNIY of

)

Christa-Maria, being duly sworn, deposes and says:

I am an intervenor in this case.

This affidavit is submitted in support of the motion by Intervenors Christa-Maria, Mills and Bier to add a contention by expanding the admitted contention IID of Intervenor O'Neill concerning a crash of a B-52 bomber into the plant.

The expanded conten-tion.would take into account crashes of other planes as well.

This affidavit a' Iso is submitted in opposition to pending motions for summary disposition on cont.ention IID.

During the second weePJ of November 1981, I was standing i

in the town of Charlevoix and observed an overflight by military planes similar to those flown by the Ohio National Guard.

These planes were flying very low, probably only severl hundred feet high.

They were headed in the direction of the Big Rock Plant.

Unless there was a quick change of route, I believe they passed over the plant.

This is at least the second time that such 1

h G

s, military planes have flown over the plant, the prior known occasion being on July 27, 1981 as set forth in detail in Intervenors' motion.

[

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D Christa-Maria Sworn to before me this#1,\\. Q day of December, 1981.

ogh, evs w NOTARY PUBLIC 4

DARDADA r. FINT.ET NOTARY PUBLIC, CilARLETOIX C3., ?TT MY COMMISSICN EXPIUCS stay 06.1985 CERTIFICATE OF SERVICE I certify that the above affidavit.of Christa-Maria was served on the attched list by United States Mail, first class, postage prepaid, on the 19th day of January, 1982.

[

!l y / &a r Herbert Semmel (

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y At -ic Safety and Licensing JeespF Callr, T.nqui re Ishe, Lintn3n and Beale E:ard Panel U.S. Nu:3 ea r Regulatory 1120 Connecticutt' Ave, N.W.

3 Suisc 325 Cor.= scien Washingten, D.C.

20555 Washington, D.C.

20036 Herbert Grossman, Esq., Chairman Atomic Safety and Licensing I

.c Board Panc1 U.S. Nuclear Regulatory

.~.p' Commission Washington D.C.

20555 t.

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Dr. Oscar H. Paris Atomic Safety and Licensing l

Board Panel

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U.S. Nuclear Regulatory Docketine and Service Section Commission offace of the Secretarv Washington D.C.

20555 U.S. Nuclear Regulato:5-Corr.ission Mr. Fredrick J. Shon Washington, D.C.

20555 Atomic Safety and Licensing John O'Neill, II Bohrd Panel Reute 2, B0x 44 U.S. Nuclear Regulatory Maple City, MI 49664 Commission Washington D.C.

20555 Janice E.

Moerc, Esq.

Counsel for NFC Staf f

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U.S. Nuclear Re gulatory

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Corr.ission 1:a s hing to n, D.C.

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