ML19330A246
| ML19330A246 | |
| Person / Time | |
|---|---|
| Site: | Midland |
| Issue date: | 02/04/1972 |
| From: | Ginster W GINSTER, W.J., MAPLETON INTERVENORS |
| To: | Atomic Safety and Licensing Board Panel |
| References | |
| NUDOCS 8007151032 | |
| Download: ML19330A246 (4) | |
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THIS DOCUMENT CONTAINS P00R QUAL.lTY PAGES J
UNITED STATES OF AMERICA ATOMIC ENERGY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD in the Matter of
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CONSUMERS POWER COMPANY )
Docket Nos. 50-329
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50-330 Midland Plant, Units 1 and 2
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MOTION FOR DISCOVERY l
MAPLETON INTERVENORS, by their counsel, WILLIAM J. GINSTER and 1RVING LIKE, move the Honorable Saf ety and Licensing Board for an
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Order compelling discovery and production of all documents consulted or i
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relied upon by the Regulatory Staff in the preparation of its" DRAFT DETAILED STATEMENT ON ENVIRONMENTAL CONSIDERATIONS BY THE U. S. ATOMIC ENERGY COMMISSION DIVISION OF RADIOLOGICAL AND ENVIRONMENTAL PROTECTION RELATED TO THE PROPOSED ISSUANCE OF A CONSTRUCTION
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l PERMIT FOR THE MIDLAND PLANT UNITS 1 and 2 (DOCKET NOS. 50-329 an.d 50-330)", dated January 7,1972, including but not limited to the following:
The Environmental Effects on the Midland Plant " Cooling Pond-Interim lleport " llechtel Company Job 7720; June,1971 (included in ASER). Subsequently referred to as the Bechtel Report. (Page 81).
It is necessary that these documents or things be produced so that counsel, consultants, and experts for the MAPLETON INTERVENORS may in-quire into the validity of the Regulatory Staff's conclusions and the data upon which such conclusions were based.
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-2e It is further necessary that the name, address, and qualifica-tions of any person who compiled the " DRAFT DETAILED STATEMENT ON ENVIRONMENTAL CONSIDERATIONS BY THE U. S. ATOMIC ENERGY COM-MISSION DIVISION OF RADIOLOGICAL AND ENVIRONMENTAL PROTECTION RELATED TO THE PROPOSED ISSUANCE OF A CONSTRUCTION PERMIT FOR TIIE MIDLAND PLANT UNITS 1 and 2 (DOCKET NOS. 50-329 and 50-330)",
elated. January 7,1972, be disclosed to counsel and further that the name addrens, and qualifications of the author / authors of the aforesaid Bechtel Report be disclosed tocounsel.
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That this information is not available to counsel, consultand's, f
or experts by any other means.
That such information is necessary to prepare an affirmative CB Sc.
COMMENTS ON REGULATORY STAFF'S DRAFT DETAILED STATEMENT ON ENVIRONMENTAL CONSIDERATIONS Counsel for MAPLETON INTERVENORS make the following comments on the Regulatory Staff's " DRAFT DETAILED STATEMENT ON EN-VIRONMENTAL CONSIDERATIONS BY THE U. S. ATOMIC ENERGY COM-MISSION DIVISION OF RADIOLOGICAL AND ENVIRONMENTAL PROTECTION RELATED TO THE PROPOSED ISSUANCE OF A CONSTRUCTION PERMIT FOR THE MIDLAND PLANT UNITS 1 and 2 (DOCKET NOS. 50-329 and 50-330)":
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s t.it ernent failerl t o.irlerju:st ely eliscus s:
'I lin envire,ninental ellert.inel cre,nrimis cost. of each aspect of t he nuclea r fuel cycle inclutling those stages which precede I: e placement of fuel in t.he proposed Midland reactor, and subsequent to the removal of irradiated fuel from this reactor.
b - The environmental effect and economic cost of decommissioning the Midland reactor after it has served its usefullife, and the feasibility of applicant's plans, if any, for such decommissioning, The extent to which the projected demand for electric power in c-applicant's servicq area is caused by its own advertising and promotion of the sale of electric power, and whether a discon-tinuance or reduction of such advertising and promotion would obviate the need for the proposed reactor, or would warrant a reactor of smaller size.
d-The. relative environmental and economic costs of meeting t$1e real demand for electric power in the applicTnt's service a Aa th rough the proposed nuclear facility, or the alternatives thereto.
Counsel hereby respectfully reaffirni Mapleton's comments regarding applicant's environmental report as also being applicable to the Regulatory Staff's" DRAFT DETAILED STATEMENT ON ENVIRONMENTAL CONSIDbRATIONS DY TITE U. S. ATOMIC ENERGY COMMISSION DIVISION OF RADIOLOGICAL AND I:tlVil(ONMENT Al, I'llOTECTION ltEI.ATED TO TIIE l>llOl'OSED TSSUANCE OF A t.t)NSTitlit: TION l'EllMIT 1'Olt Tile MIDLAND PLANT UNITS 1 anel 2 (DOCK ET i-NOS. 90- 129 and 50-330)".
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WII,lJA M.l. ( ; INST Ei!.
Alto'rney (.ir Mapleton Int ervenors Dated: Februa ry 4,1972
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i u rtify that a copy of the foregning document was m il d a e Feb ru.t ry 4,'
1972, postage prepaid and properly addressed, to the inembers of the Atomie Safety and Licensing Board
, the Secretary of the Cummission, and all costnset of record.
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VILLIA M,J,. -GINSTTC R
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