ML20054N010

Statement of Good Cause for Late Intervention.Issues Raised Have Occurred Since Inception of 1978 OL Proceeding

ML20054N010
Person / Time
Site:	Midland
Issue date:	07/09/1982
From:	Stamiris B STAMIRIS, B.
To:	Atomic Safety and Licensing Board Panel
References
ISSUANCES-OL, NUDOCS 8207150265
Download: ML20054N010 (2)

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1 l_ U. S. Nuclear Regulatcry Commission i

i In the Matter of '

D'o'cke t Nos .

CPCo. Midland Plant 50-329 OL Units 1 & 2 50-330 OL BEF0PI THE ATOMIC SAFETY AND LICENSING BOAPS 4 Stamiris Statement of Good Cause for Late Intervention 3

7/9/82 i I have actively participated in the 50-329, 5-330 OM, OL Proceeding. Due

] to the established consolidation of OM-OL issues, I am an accepted OL intervenor 4

regarding soils issues. On 3/28/82, I sought to expand that participation to -

other matters due to the inadequacies in the NRC's Draf t Environmental Statement.

! The deceptively unfair cost benefit analysis and the denial of the existance -

of any significant environmental or safety concern since the construction per-j mit review (p. 3-1 DES) despite unresolved soil settlement issues destroyed my assurance that the NRC was protecting the realth and safety of my family and com-i munity in recommending an operating license for the Midland plant on such bases.

Af ter careful ' consideration of the personal ir.plications of a commitment to become an active OL participant, and contrary to my previous intentions, I decided l to submit my 3/28/82 request for full OL intervention. Subsequent to that deci-

sion, review of the NRC's SER and statements to the ACRS have confirmed my sense j of-obligation to intervene in the OL in the hopes of attaining a safe nuclear l plant. I have come to believe that the problems which concern me so deeply at t

the Midland Nuclear Plant are as much the result of inadequate NRC regulation i as of Consumer's Power Co. deficiencies.

i For these reasons, and because I believe my active participation can assist l in developing the sound and complete OL record necessary to insure a plant capable l of safe operation, I ask that the untimliness of my requested OL intervention l be considered less important than the public health and safety benefits of my l requested OL intervention. -

4 l 8207150265 820709 i

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2 The contentions I have submitted for the OL proceeding raise issues : tat will not otherwise be covered or represented by Intervenors Sinclair or Marshall.

Furthernore these Intervenors have expressed a need of assistance from me, indicat-ing that they would not adequately be able to represent my interests in my absence.

To the extent that some of my contentions do reflect issues already addressed -

by Sinclair or Marshall contentions, I will gladly consolidate my efforts with theirs for the greatest efficiency of all parties.

My contentions deal with issues which have occuzied since the 1978 inception, 7

of the OL proceeding.* As such they represent issues which could not have been 3

raised at the beginning of the OL proceeding. Since'I was not or did not intend

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f 8 to become atfull OL intervenor in 1980 and 1981, I did not raise 'is OL issues the specific design and construction deficiencies such'as the references to 55e reports, at that time. Furthermore until I was able to review the NRC assessment of these design and construction deficiencies in the SER, I could not know whether they had been adequately taken into account by the NEC in their OL review. s.,

In revising my 6/18/82 contentions I have consolidated the related or overlap-ping contentions and provided more specific bases including dates and sources wher-ever possible. Contentions 1, 3, 10, 13, 14, 16, and 19 have to do with my assess-f I

ment of specified b3C DES and SER statements. Contentions 4, 7, 8, 9, 11, 12, 15, 17, and 18 have to do with my perception of the failure of NRC DES and SER state--

cents to adequately consider these design and construction deficiencies. Conten-tions 5 and 6 are based on information new to ce in the spring of 1982. Contention 2 represents the culmination of my change in attitude toward NRC regulatica,~and also my overall decision to expand my OL intervention'. Contentions 18, 19, and 1

21 are new. Contention 18 from 6/18/82 is more properly considered in the OM-OL proceeding and is covered by Stamiris OM contention 4, and is therefore dropped.

Contentions 16 and 20 are subject to consolidation with'similar Sinclair contentions, d *except for reference to the 1974 containment fire, and 1977 t.cndon sheath omissions, contention 11.

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