ML19329F247
| ML19329F247 | |
| Person / Time | |
|---|---|
| Site: | Midland |
| Issue date: | 03/03/1971 |
| From: | Cherry M, Roisman A BERLIN, ROISMAN, KESSLER & CASHDAN, CHERRY, M.M./CHERRY, FLYNN & KANTER, ENVIRONMENTAL DEFENSE FUND, Saginaw Intervenor, Sierra Club |
| To: | Atomic Safety and Licensing Board Panel |
| Shared Package | |
| ML19329F248 | List: |
| References | |
| NUDOCS 8006230767 | |
| Download: ML19329F247 (2) | |
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eUnd 'BEFORE THE Usl;4 UNITED STATES OF AMERICA ATOMIC ENERGY COMMISSION d " ' 7!'
In the Matter of
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CONSUMERS POWER COMPANY
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Docket Nos. 50-329 (Midland Plant, Units 1 and 2)
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50-330
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MOTION OF ENVIRONMENTAL DEFENSE FUND, INC.
AND SAGINAW VALLEY NUCLEAR STUDY GROUP, ET AL. 1/
FOR DETERMINATION OF ENVIRONMENTAL ISSUES Intervenors, Environmental Defense Fund, Inc. and Saginaw Valley, et al. hereby request that this Board determine that:
1)
This hearing will include consideration of all aspects of the environmental impact of Midland Nuclear Power Plant Units 1 and 2 prior to issuance of an initial decision for a permit to construct the plant as required by law.
2)
The Board will fully explore all environmental issues related to the Midland Plant regardless of whether these issues are raised by intervenors and regardless of whether the applicant has submitted certificates of compliance with state, regional or federal environmental standards or require-monts and in connection with such exploration the applicant, the staff or any intervenor supporting the application have the burden of proof.
1/
Insofar as Saginaw Valley, et al. are concerned this motion and supporting authority is in addition to the Motions of Saginaw Valley filed herein on December 1, 1970 dealing with environ-mental matters.
(See Motions of Saginaw Valley, et al. Nos.
3-1 (a), (b) ; 3-2; 3-3; 4;5;6.)
THIS DOCUMENT CONTAINS 7b9 4
POOR QUAUTY PAGES 3
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Upon granting of this Motion the Board will allow all intervenors a reasonable period of time following the receipt of the Detailed Environmental Statement to permit full pre-hearing discovery.
Respectfully submitted, Berlin, Roisman and Kessler Counsel for Intervenor Enviro me 1 Defens Fund'
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By,
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- LO.v V Anthony.Z.
o(sman Wdb We Myrbn Mr erry, Esq.1 Counsel!
r Interveno'Ps Saginaw Valid Nuclear Study Group
' Citizens Committee fqy the Environ-mental Protection of Michigan Sierra Club
- United Auto Workers of America Trout Unlimited West Michigan Environmental Action Council, Inc.
Environmental Law Society of the University of Michigan Law Students Dated:
March 1, 1971 w
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