ML19329F394

Midland Nuclear Power Committee Petition to Intervene at Hearings Re CP Application.Cp Should Be Granted Due to Safe Design of Plant.Existing Radiation Stds & Regulatory Practices Are Adequate to Protect Health & Safety of Public

ML19329F394
Person / Time
Site:	Midland
Issue date:	11/10/1970
From:	Kendall J CURRIE & KENDALL
To:
Shared Package
ML19329F392	List: ML19329F391 ML19329F394
References
NUDOCS 8006270444
Download: ML19329F394 (9)

Text

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t 86ClEi!8 O mit 2 UNITED STATES OF AMERICA

, NOV121970 *I 3 i 6'- ira e Ma**F ATOMIC ENERGY COMMISSION

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IN THE MATTER OF }

CONSUMERS POWER COMPANY, )

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) Docket No. 50-329 (License Application, ) Docket No. 50-330 Midland, Michigan Plant) )

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PETITION FOR INTERVENTION Midland Nuclear Power Committea, on its own behalf, and on behalf of its members, hereby petitions the ATOMIC ENERGY COMMISSION for leave to intervene in the above captioned proceeding.

The Petitioner is an unincorporated membership organi-zation comprised of approximately fif ty (50) persons who reside in and about the City of Midland, Michigan, and who represent trades, professions, businesses, organizations and industry other than Petitioner in the area to be served by the proposed facility.

These members, working together so as to evaluate the problem from many technical, environmental and economic aspects, have been studying the impact of the construction and operation of the pro-posed facility. The organization was formed as a consequence of the concerns of the individual members regarding the subject appli-cation. Attached hereto and made a part hereof is a list of Petitioner's present membership.

A. The interests of the Petitioner are as follows:

1. Members of the Petitioner organization as repre-sentative residents of the area most prcximate to the location of the proposed facility, have therefore a special concern,that the

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American people and the citizens of Midland County and surrounding I area benefit from the most advanced technology consistent with public safety and security.

2. Menbers of the Petitioner organization have been engaged in various environmentally related activities for several l

years in the area and thereby have special awareness of the neces-sity and urgency of limiting and reducing all sources of environ- i i

mental pollution.

3. Members of the Petitioner organization work in l

and around the area proximate to the location of the proposed facility, and thereby will be affected in many practical aspects by the decision of the Atomic Energy Safety and Licensing Board.

4. Members of the Petitioner organization are custo-mers of CONSUMERS POWER COMPANY, and are now and will be in the future dependent upon that company for electrical power, both in their homes and in their respective business establishments, and as such, have a real monetary interest in the business as-pects of providing electrical power.

5. Members of the Petitioner organization and their familias are predominately dependent, directly and indirectly, on the industrial future of the industries to be served by the proposed facility and are thereby affected by the future energy requirements of these industries.

B. Effect of the Atomic Energy Commission decision on the interests of the Petitioner:

1. The Petitioner believes that the decision taken in this natter will affect decisions taken in regard to additional, future power plants not only in Michigan, but elsewhere throughout the United States. The decision of the Commission will determine I

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whether the present and future members of the Petitioner organi-1 j

zation, their families and their fellow citizens from throughout t

the area affected by this decision will be allowed to enjoy the j I

fruits and benefits of the most modern technology in safety and )

i security.

2. The decisions taken by the saission in this matter will have significant impact on the environment and ecology of Midland County and its neighboring counties and will thereby affect the members of Petitioner organization.

3. The decision taken by the Commission will affect the cost of electricity which must be borne by the members of the Petitioner organization.

4. The decision taken by the Commission in this matter will affect the health and ssfety of the members of the Petitioner organization and their families. In particular, if the license is denied or a decision is long-delayed, the pro-posed facility will probably be replaced by additional fossil-f fueled plants in the immediate vicinity and present fossil-fueled energy producing facilities will not be retired. It is Petitioner's firm conviction that such installations, because of their noxious, polluting emissions into the atmosphere and environment, will jeopardize materially the health and well-being of the members, their f amilies and their fellov citizens.

5. The decision taken by the Commission will affect importantly the economic future of the area in which Petitioner's members work and play. Specifically, the high costs of energy from fossil-fueled facilities in the area are not competitive with such costs found elsewhere and as such result in competitive disadvantages to local industries.

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C. Contentions of the Petitionert i

1. The Petitioner believes the proposed nuclear l

power plants are of safe design and do not constitute a threat to the residents of the area surrounding the proposed plants.

2. The Petitioner believes that radiations and radioactive effluents from the proposed plants will not jeopardize the health and well-being of the residents of the area surrounding the proposed plants, nor the ecology.

3. The Petitioner believes that existing radiation standards and regulatory practices are adequate to protect the health and safety of the public.

4. The Petitioner believes that the transport of fuel to the plants, and the transport of radioactive wastes, and spent fuel elements from the plant will not endanger the public.

5. The Petitioner believes that the proposed nuclear power plants will produce less atmospheric and water pollution, and will cause less disruption to the natural surroundings, and less risk to the health and welf are of the public than any alter-native means for producing electricity.

6. The Petitioner believes that applicant's design for disposal of waste heat in the operation of its f acility is consistent with the highest environmental and ecological consid-erations.

7. The Petitioner believes that the proposed facility is needed to provide adequate comp 2titive energy services to the State of Michigan and the Midland area.

The Petitioner may present expert testimony on each of the above contentions, avoiding repetitious testimony and

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. r testimony on matters of " official notice" except where challenged f by other intervenors.

The Petitioner concludes that it is in its best in-terest and in the best interest of all citizens of the area sur-rounding the proposed plants that the Board render a favorable decision as to this application, and grant licenser for construc-tion of Midland Plant Units 1 and 2 to the Consumers Power Company.

The name and address of the person on whom service may be mader JAMES A. KENDALL, ESQ. of CURRIE AND KENDALL, ESOS.

135 North Saginaw Road Midland, Michigan 48640 tGEREFORE, Petitioner respectfully requests the Commission to issue an Order permitting its intervention as a party in this proceeding.

Dated: Midland, Michigan November 10, 1970 MIDLAND NUCLEAR POWER C0tC4ITTEE by. .suf b Jr s A. Kendall, Esq.

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IE AND KENDALL, ESQS.

Attorneys for Petitfoner 135 North Saginaw Load Midland, Michigan 48640 (517) 839-9985 l

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OPcjET NUMBER l

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STATE OF MICHIGAN ) ss COUNTY OF MIDLAND) i WAYNE E. NORT11, being duly sworn, deposes and says that he is Chairman of MIDLAND NUCLEAR POWER COMMITTEE, the Petitioner herein; that he has read the foregoing Petition and knows the contents thereof, and that the same are true to the best of his knowledge, information and belief.

N Z//wz 7-WAYNB'E. NORT11 On the 10th day of November,1970, before me personally came WAYNE E. NORTH, to me knou to be the individual described in and who executed the foregoing instrument and acknowledged that he executed the same.

M M- h Gwyneth kl. Satterlee, Notary Public, y , Midland County, Michigan.

My wmmission expires: September 20, 1974

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m Con muusa doo.t.unt rm 70439,W0 CERTIFICATE OF SERVICE 1

i I hereby certify that a copy of this Petition for L

Intervention has been served on the following by deposit thereof in the United States mail, postage prepaid, to the address shown:

CONSUMERS POWER COMPANY Jackscn Michigan 49201 Attn H.P. Graves, General Counsel  !

1 GERALD HADLOCK, ESQ. ]

Trial Counsel for the Regulatory Staff 1 United States Atomic Energy Commission Washington, D.C. 20545 ,

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JA S A. KENDAlL '

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Sworn to before me D' - l this 10th day of November, 1970.

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Anita Phillips, Notary Pyblic Midland County, Michigan My commission expires: 3-15-71 l

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• DOCUT NUZBER EL &UIlL,fAL b N T, D 1

MIDLAND NUCLEAR POWER COMMITTEE I OCCUPATION NAME ADDRF.53 Sr. Minister, First Methodist Church Dr. Wayne Ncrth, Chm. Midland Midland VicePres. & Treas., Alden B. Dow Assoc.

H. C. Allison Ned Arbury Midland Pres. A. S. Arbury & Sons Ins.

Bruce Benway Midland V. Pres. First National Bank & Trust Co.

Dr. Robert L. Blackhurst Midland Opthanologist Charles Blacklock Midland Architect, Black!ock & Schwart z Julius Blasy Midland Mayor, City of Midland Daniel N. Brown Midland Ass't, V. Pres. Frist National Bank & Trust Stuart Branson Midland Great Lakes Photo Color Service Robert Chatterton Midland Supervisor Midland Township Midland Pastor, Church of the Nazarene J. D. Cook John Costa Midland New Prod. Mgr. , Dow Chemical Co.

Fred Yockey Midland Nidland City Manager I

Don Coultrip Midland Mgr. Administrative Services, Dow Corning Corporation Dale Dean Midland President, le-D Builders Midland J. C. Edwards Bldg. & Reelty Co; J. C. Edwards Robert Ferries Midland Partner. Ferries & Maxwell Insurance Midland Pres. Fisher Contracting Co.

Arthur J. Fisher Adolph Fossum Midland Chancellor, Northwood Institute Louis Garl Midland Dist. Agent - Northwestern Mutual Life Insurance Dr. W. C. Goggin Midland President, Dow Corning Lorporation Robert Graham Midland Pres. & Treas. A. C. f.raham Motors Mrs. Dorothea Graves Midland Mgr. Sch ace City Mobile Homes Rev. T. M. Greenhoe Midland Pastor, Hemerial Presbyterian Church Jackson B. Hallett Midland Architect, Jackson D. Hallett Ben Hines Midland Mgr. Sears, Roebuck & Co. , Midland Charles Holteamp Midland Pres., Michigan Building Assoc.

Lee Horsley Midland Research Scientist Dow Chemical Co.

Lyle G. Howe, Jr. Midland Mgr., Howe's T.V.

David J. Jackson Midland Pres., Jackson Insurance Agency Donald R. Kasper Midland Owner, Al's Sport Shop Marville Kent Midland Realtor Edward Kern Midland Pres., High Performance Technology Midland Dir. of Elementary Education l Robert Kingsley Midland Public Schools l Roy Lanham Midland Pres, & Gen.Mgr. , Drown Lumber Inc.

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! Committee NAME ADDRESS OCC1'PA TION Dr. Kuneth Larson Midland Optometrist - Pres. Jaycees Howard Ledbetter Midland Tax Dept., Dow Chemical Co.

Robert J. Lee Midland Mgr., American Cleaners Denjamin Lerner  !!idland Pres., Lerner Building Co.

C. L. Marcoux Midland Pres., First National Bank & Trust James A. May Midland Process Eng., Dow Chemical Co.

William H. Meier Midland Pres. , Meier Studio & Camera Shop John Miller Midland Retired Construction Worker Richard Miller Midland Pres., Miller-Christensen Real Estate John Moeggenberg Midland Owner, Moeggenberg Men & Boys Wear William Nugent Midland Nugent Valgreen Drugs & Wingate Apts.

Frank Olds Midland Chm. , County fid. of Commissioners Alan Ott Midland V. Pres. & Cashier, Chemical Dank

& Trust Co.

Dr. George Owen Midland Supt. of Midland Public Schools Robert L. Parker Midlar.d Exec. Mgr. & V. Pres. Midland Area Chamber of Commerce John Prior Midland Financial Sec., Dist. $O Union John Rapanos Midland Pres., Rapanos Enterprises Robert Robison Midland Owner, Robison's Jewelry Paul Schreiber Midland Mgr. Public Relations Midland Area Chamber of Commerce James Scovic Midland Mgr. of Dist. & Purch. Dow Chemical Richard Schmidt Midland Asst. V. Pres., Mutual Savings & Loan Sidney Schneider Midland Attorney Mrs. Sidney Smock Midland Housewife Harold Steinke Midland V. Pres. Chemical Bank & Trust Co.

Marvin Stein Midland Pres., Steins Shoes Dr. William Straub Midland Radiologist, Midland Hospital Richard Todd Midland Pres., Chemical Bank & Trust Co.

f Charles Vosburg Midland Chm. Board Trustee's Elks Architect, Dow Chemical Co.

Ted Williams Midland Pres. & Gen. Mgr. Bailey Lumber Co.

Mrs. Joanne Williams Midland Sec., High Performance Technology I

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