ML19318D204

Petition to Intervene Re Order for CP Mod,Alleging That Unresolved Soil Settlement Issue Will Create Adverse Safety Problems & Will Result in Inefficient Exercise of Atomic Energy Use.Certificate of Svc Encl

ML19318D204
Person / Time
Site:	Midland
Issue date:	06/26/1980
From:	Reist S AFFILIATION NOT ASSIGNED
To:	Atomic Safety and Licensing Board Panel
References
NUDOCS 8007080054
Download: ML19318D204 (3)

Text

.. UNITED STATES OF AMERICA NUCLEAR .7 L *' MISSION M DOCKETED 9

% USNRc In the Matter of CONSUM3RS POWER COMPANY -

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e.m:e ci et S***f Docket No. 50-329-0M 50-330-0M Midland Plants I & II q, // (Hearing on Order for

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h# Modification of CP)

N @ e PETITIO!T- [v INTERVENE Petitioner, Sandra D. Reist petitions to intervene in this pro.?eeding pursuant to Section 2.714 and other pertinent sections of tne Nuclear Regulatory Commission's Rules of Practice and states:

I IDENTIFICATION OF PETITIONER

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AND ITS INTERESTS TO BE AFFECTED Sandr_a D. Reist -

1. Sandra D. Reist is a life-long resident of the State of Michiran, a resident of Midland County for eighteen years and currently resides ,

in Bay City, County of. Bay, '

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Petitioner resides within **"t7 .niles of the Midland Units T & II./

This petitioner has studied, to the extent that information has been avail'able, the proposed Midland Plants I & II and is concer-ned as set forth in more specific detail below, that the unresolved soil settlement problems at the Midland site will result in an unsafe a"d inefficient exercise of the use of atomic ~ energy; that it will create adverse effects upon the County of Bay. The safe and efficient operation of these atomic plants in dependent upon the reliability and stability of the foundation of the generator buildings which house the wiring for the back up safety systems. Due to the past record for quality control assurance displayed by Consumers Power Company, the petitioner finds that to grant them the right to continue construction of this

• portion of the plant a serious threat to the well being of petitioners hcme and f amily.

II INTERESTS ADVERSELY AFFECTED BY ACTION OF THE COMMISSION .

2. Based uoon the interests and concerns of the petitioner identified in (I) above, one or more of the direct interests of the petitioner will be adversely affected by the outcome of this hearing.

These interests and how they may be affected are as follows:

( a) The economic interests of the petitioner will be affectd by the construction of this portion of the plant in the following ways:

(1) All construction work in progress (CMIP) is already in the rate base QS6 9*I 8007oggg ,q .

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, (2) Any modifications of the ccnstruction calling for re-con-struction of the generator buildings complex will add to I the cost overruns which have already occurred and will add an even mora unf air burden upon ratepayers (3) As a homeowner petitioner feels that the soil bettlement and related problems would eventually lead to unsafe and undesireable conditions that will adversely affect the value of petitioners residential property.

(4) Finally, petitioner questions the integrity of the installations beneath the sinking buildings and their role in the operation of this nuclear plant thereby threatening the health and safety of .the petitioners three children.

III STATZ4ENT OF CONTENTIONS

3. Under Sec. 2.714 Petitioner is not required to frame specific contentions until fif teen (15) days prior to the hol, ding of a special prehearing conference or the hearing conference if no special prehearing conference is held. The petitioner reserves his right under 2.714 to file contentions within the time limits specified in the section identified above.

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- - e UNITED STATES OF AMERICA *

, EUCLEAR REGULATORY COMMISSION In the Matter of Docket Nos. 50-329-0M CONSUMERS POWER COMPANY 50-330-0M Midland Plants I & II (Hearing on Order for Modification of CP) e CERTIPICATE OF SERVICE I hereby certify that I have served copies of the foregoing document entitled " Petition to Intervene" by deposit in the United States Mail, first class this 26 th day of June, 1980 on the following:

Secretary of the Commidsion U.S Nuclear Regnlatory Commission Washington, D.C. 20555 Attention: Docketing and Service Branch Executive Legal Director .

U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Michael I. Miller, Esq.

Isham, Lincoln, and Beale One First National Plaza

. Chicago, Illinois 60690 t%ythl% 0 h Sandra D. Reist On this 25th day of June, 1980, before me personally appeared Sandra D. Reist to me known to be the person described in and who executed the foregoing instrument, and acknowle,dged that he execu-ted the same as his free act and deed.

/L > t nk Arb f hazi Dat[ Nota [yPublic

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