ML19318D187

Petition to Intervene in CP Mod Proceeding,Alleging That Unresolved Soil Settlement Problems Will Adversely Affect Safety & Will Create Inefficient Exercise of Atomic Energy Use.Questions Integrity of Const.Certificate of Svc Encl

ML19318D187
Person / Time
Site:	Midland
Issue date:	06/25/1980
From:	Race M AFFILIATION NOT ASSIGNED
To:	Atomic Safety and Licensing Board Panel
References
NUDOCS 8007080039
Download: ML19318D187 (3)

Text

UNITED STATES OF AMEKJ.UA NUCLEAR REGU OMMISSION o\ .y/c o 7 coexETED 9 us a:: F In the Matter of N Docket No. 50-329-0M CONSUMERS POWER COMPANY 'D JUL 1### 50-330-0M Midland Plants I & II q Cit::e et u 358$7 h (Hearing on Order for

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5 Modification of CP) y/, 64f,52 7 PETITfdN'rn0tII$ERVENE Petitioner, , Michael A. Race ., petitions to intervene in this proceeding pursuant to Section 2.714 and other pertinent sections of the Nuclear Regulatory Commission's Rules of Practice and states:

IDENTIFICATION OF PETITIONER

. AND ITS INTERESTS TO BE AFFECTED Michael A. Race I am a long time resident of Bay City, Michigan..I own property in Bay City,-

Michigan and have a wife and three children 'who. live with ms at 2015 Seventh' '

Street. .The Nuclear power plants in Midland, Michigan will affect my property and family when they operate. ,

i This petitioner has studied, to the extent that information has been available, 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 and inefficient exercise of the use of atomic energy; that it will create adverse effects upon the County of 3ay. The safe and efficient  !

operation of these atomic plants is dependent upon the reliability l and stability of the foundation of the generator buildings which Due to the past l

house the wiring for the back up safety systems.

record for quality control assurance displayed by Consumers Power l Company, the petitioner finds that to grant them the right to continue construction of this portion of the plant a serious threat to the l well being of petitioners home and f amily.

II INTERESTS ADVERSELY AFFECTED 3Y ACTION OF THE COMMISSION

2. Based upon the interests and concerns of the petitioner identified in (I) above, one or more of the direct interests of the petitioner will be adversely a.ffected 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 (C' DIP) is already in the rate base J1 007080o3$ ,

(2) Any modificationc of the construction ca]lM;; for re-con-struction of the generator buildings complex will add to the cost overruns which have already occurred and will add an even more unf air burden upon ratepayers.

(3) As a homeowner petitioner feels that the soil settlement 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 bui'. dings and their role in the operation of this nuclear plant thereby threatening the health and safety of the petitioners three children.

III -

STATEMENT OF CONTENTIONS

3. Under Sec. 2.714 Petitioner is not required to frame specific contentions until fifteen-(15) days prior to the holding of a special prehearing conference or the hearing conference if no  !

special prehearing conference is held. The petitior.er reserves his right under 2.714 to file contentions within the time limits specified in the section identified above. l l

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UNITED STATES OF M4 ERICA NUCLEAR REGULATORY COMMISSION In the Matter of Docket Nos. 50-329-0M CONSUMERS POWER COMPANY 50-330-0M Midland Plaats I & II (Hearing on Order for Modification of CP)

CERTIFICATE 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 25th day of June, 198 on t'te foll wing:

Secret.cy of the Ocmmiss..on U.S Nuclear Regulatory Commission Washington, D.C. 20555 Attention: Docke' ting and Service Branch Executive Legal Director .

l U.S. Nuclear Regulatory Commission  ;

,3 IN W ashington, . D.C. 20555 I

\ 03 1 COOKETED 9 ustmc l E.- JUL 11980 > g Michael I. Miller, Esq. '

Isham, Lincoln, and Beale

\ Office of t.is se:retary One First National Plaza

. 10, C::ke:M; & Smi:e Bran:5 p

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Chicago, Illinois 60690 l

, . t , p Michael A. Race 3

On this 25th day of June, 1980, before me personally appeared

- P.ichae l A. Race 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.

G /1r /Fv

/o/A /Yd1/m Date Notary Public l

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