ML19329F507
| ML19329F507 | |
| Person / Time | |
|---|---|
| Site: | Midland |
| Issue date: | 12/29/1971 |
| From: | Like I MAPLETON INTERVENORS, REILLY & LIKE |
| To: | Atomic Safety and Licensing Board Panel |
| References | |
| NUDOCS 8006300714 | |
| Download: ML19329F507 (9) | |
Text
- _ ___
- 3. L uni., Eac.5M 7th9'30 W
Q C'
ls O C 0 l' E 6 i O 9
-u (7
J/\\N 31972 * ;
UNITED STATES 'OF AMERICA e.t,..i.:,, usius
""* y[]#'"
ATOMIC ENERGY COMMISSION
,% lN In the Matter of
)
NY/- 7/.
Doc h Nos CONSUMERS POWER COMPANY 0 33
)
Midland Plant, Units 1 and 2
)
MAPLETON INTERVENORS ' RESPONSE TO CERTAIN PORTIONS OF BOltRD ORDER i
DATED DECEMBER 22. 1971 On December 26, 1971, the undersigned, counsel to Mapleton Intervenors, received a copy of the Board's order dated December 22, 1971 requiring opposing intervenors to serve and file, on or before December 31, 1971, their en-vironmental contentions and discovery requests with respect to applicant's environmental report. (p. 13)
Coming as it did, in the midst of the Christmas holiday week, the order does not afford a reasonable period of time in which to comply with its directions, including the one regarding environmental contentions, etc.
However, Mapleton Intervenors are willing, without pre-judice, to exercise its best effort and good faith to comply with the Board's direction to the extent that it can in the five day period allowed for such purpose.
q THIS DOCUMENT CONTAINS 80063007lY h P00R QUAUTY PAGES
Z-i 1.
Mapleton Intervenors reaffirms its previously filed
" Statement of Legal and/or Factual Contentions" and, in par-ticular, the environmental contentions therein,. to wi :
Paragraphs IV, IV-A, IV-B, IV-C, IV-D, IV-E, IV-F, IV-G, IV-H, IV-I, IV-J and IV-L.
2.
Mapleton Intervenors reaffirms its " Offer of Proof of More Specific Factual Contentions, etc.", dated July 8, 1971 and, in particular, the environmental contentions con-tained therein, to wit: Contentions I, II, III*, IV* and V.
3.
Mapleton Intervenors reaffirms as its environmental contentions the testimony given or served in its behalf by Dr. Edward S. Epstein, Druce F. Watson, Dr. Charles W. Huver, Dr. Ernest Eckert, Dr. Orie L. Loucks and Professor Richard Robert Meierotto.
i 4.
The applicant's Supplemental Environmental Report i
and amendments thereto do not contain an adequate benefit-cost analysis as required by 10 CFR 50, Appendix D, Subsec-tion A.3, and, in particular, but without limiting the gener-ality of the foregoing:
a) Benefits are not sufficiently quantified and l
consistently evaluated; i
l b) Generating costs are inadequately assessed; c) Environmental cost computations are not speci-l
- Intervonors claim that Contentions III and IV are both radiological and environmental contentions, and intervenors intend to challengo the radiation standards.
' * = ' = = -
we, 3.
fied'in such a manner as to provide a comprehen-sive enumeration of the primary environmental im-pacts and the environmental sectors affected by the project; d) The validity of applicant's methodology for assess-ing environmental. cost is not substantiated'by sufficient empirical evidence; e) Applicant has failed to adequately (1)' evaluate the feasible alternative approaches with available technology; (2) demonstrate its effort to internalize-environ-t mental costs; (3) document its process of formulating alterna-tive designs by neans of supplementary infor-4 mation regarding viable alternative subsystem modifications it has considered.
The alleged benefits pf' the Midland nuclear plant 5.
will not adequately compensate,for its huge environmental Costs.
i 6.
The Midland nuclear plant is unnecessary and is not l
.a sa e, economical reliable generator of electric power and L
f process steam.
7.
.Its liquid and gaseous radioactive waste releases L
~
i W
w We -
rT7Tf-t-r-Tr u-r->-
esw-#
vri F
w--my-
--i-g y
N
- ---5r4 7-e---+'
+
4.
4 1
will caute a significant adverse environmental impact.
i 8.
The plant will degrade state and local air quality, will not enable Dow Chemical to close down inefficient fossil-fired pla'nts, and will not enable applicant to operate its older, less efficient units a smaller percentage of the time.
q i
9.
Applicant's ecological study of the site is of dubious validity because of the ecological damage caused by applicant's activity in the course of site clearing and pre-liminary construction.
- 10. The validity of applicant's ecological study, the environmental surveillance program and its studies of area water quality, is not supported by sufficient theoretical and experimental data.-
- 11. Applicant has not utilized the best av,ailable tech-nology to minimize the environmebtal effects of the plant, and to reduce to near absolutejzero the radiological releases to be expec'ted under normal and accident conditions.
?
I
- 12. Applicant has failed to adequately consider the
?
alternative gaseous radioactive, waste control systems and alternate means of disposing of Jaundry wastes.
- 13. The operation of the plant will result in signifi-cant chemical discharges and dissolved solids will be concen-t trated by the pond so as to impair the water quality of the l
Tittabawassee River.
m.
'T 5.
t i
4 14.
The hazards and enviEonmental effects of the trans-portation of spent fuel and nuclear wastes from the Midl&nd plant to the reprocessing and ultimate storage sites are real and significent.
+
15.
As compared to the alternatives, a Midland nuclear I
plant suffers cost and environmental disadvantages.
16.
A Midland nuclear plant would result in the highest
)
cost electricity.
17.
Applicant has failed to make a thorough and accurate cost comparison of a nuclear vs. fossil fuel plant to ' meet the '
alleged base load power needs of Midland; for example, appli-cant has failed to cons'ider the comparative cost of de-commissioning both types of plants after their useful lives are over, a comparison which would disclose the significantly higher cost of decommissioning a nuclear plant.
Applicant has also failed to take into account the fact that the c os ts i
of control 11hg fossil fuel plant pollution are lower, more predictable, and the technology for dealing with same more i
available, than for nuclear pl' ants.
18.
The adverse environmental effects of the nuclear fuel cycle exceed those of the fuel cycle of any alternative to the Midland plant.
y
.r y
-.-.r
1 j
6.
~
i 19.
The environmental effects from a fossil fired plant f
the same size as the Midland nuclear plant are less severe and long lasting than those fro'm such nuclear plant.
1
- 20.
- Applicant has failed to adequately consider the t
alternative cooling systems that might be employed instead of a cooling pond.
21.
Applicant has failed to adequately assess the addi-tional burden of radioactivity which would be added to the environment, and in the production of various substances, including industrial, commercial and pharmaceutical products because of the possibility of radioactive steam which will be discharged to the environment through numerous vents.
22.
The operations of Midland and Dow will contribute to the environment a heavy burden of chemicals, radioactive l
substances and heat, the combination of which at best is highly unpredictable with regard to the. distribution of specific radionuclides; applicant has failed to adequately evaluate their interaction with living organisms in the river and in the surroundingf biosphere, and in potential syner-gistic action with other chemicpls, the heated water and used steam, all of which will be dumped into the river, and which have not been sufficiently studied.
23.
In addition to the total radioactivity in the solid,
c 7.
i liquid and gaseous effluents, ;the concentrations and activities of each specific nuclide to be discharged will have its poten-tial' damaging effect upon living organisms; applicant has failed to adequately assess the extent to which the radio-active effluents from the Midland reactors will cause harm or damage to living organisms in the environment.
-24.
The maximum permissible concentration values tabu-lated in Title 10 of the Code of Federal Regulations,,which govern the discharges of radioactivity from the Midland plant, lead to an unacceptable risk estimate to man and the en-vironment; the applicant has failed to reliably estimate the quantity (number of curies) of.each and every radionuclide that is released to the environment, the distribution of these radionuclides within the biosphere and the resultant dosage s
to various organisms and to man, and applicant has failed to adequately assess the potential damage to the biosphere and to man.
I 25.
The lack of a, comprehensive study that takes into account both physical and biological concentrating mechanisms and is based upon quantitative data on each and every radio-nuclido in the inventory of the Midland plant precludes appli-
. cant from accurately assessing' the environmental impact of the Midland plant.
1
.~.
_. -. _~..- __. _..- __...,... -....,.,,,,.,._.._,,_ _,....~. -.
m==..
..m u.
- ~"..~
,~
8.
I Intervenors contend applicant's Supplemental Environ-mental Report and amendments thereto do not sustain appli-cant's burden of proving that the Midland plant will not _
have an undue adverse impact upon the environment.
Intervenors reserve the right to serve. ard file additional environmental contentions.
j
\\
i Dated: December 29, 1971 Respectfully submitted WILLI
. GINSTER, ESQ.
IRVIN LI
,ESQ.
by-fryingLke Attorneys for Mapleton I
Intervenors l
- I l
A e
b
.-----e y
g_
g-9
.- -+
-qy-rwt m
--e-e-'e-
-. ~. _., _.. _
A uGCKET liUMBLR PROD. & UTIL, gg 6*C -)2],93zy CERTIFICATION _
I certify that a copy of the foregoing document was inailed December 29, 1971, postage prepaid and properly addressed, to the members of the Atomic Safety and Licens-ing Board, the Secretary of the commission, and all counsel of record.
1 Irving Like Attorney for Mapleton Intervenors G
c) l DOCKETED S
DI&EC C
JAN 31972
- L S-
..r.e o = =an h
g',e Procrtcap In.m 9
4%
/
4 N
i r
E I
.