ML19331B167

Submits Mapleton Intervenors' Preliminary Views on Environ Issues,In Response to ASLB 710826 Order.Concurs W/Saginaw Intervenors' Views.Environ Issues Will Be Stated in Greater Detail After Applicant & NRC Submissions

ML19331B167
Person / Time
Site:	Midland
Issue date:	09/28/1971
From:	Like I REILLY & LIKE
To:	Murphy A Atomic Safety and Licensing Board Panel
Shared Package
ML19331B168	List: ML19331B167 ML19331B169
References
NUDOCS 8007250857
Download: ML19331B167 (3)

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September 28, 1971 -

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Arthur W. Murphy, Esq., Chairman Atomic Safety and Licensing Board s .,

Columbia University School of Law .

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Ret In the Hatter of Consumers Power Compan Midland Plant, Units 1 and 2 Docket Nos. 50-329 and 50-330 Dear Professor Murphys Mapleton intervenors hereby submit under protest, their pre-liminary statement of views on environmen,tal questions, as re-quested by the Board in its order of August 26, 1971. Mapleton reserves its right to present its views on environmental questions and to raise environmental issues at an appropriate stage of this proceeding after the applicant has filed its supplementary environ.

mental report and the Staff has filed its detailed environmental statement on environmental issues, in accordance with the require-ments of the Calvert Cliffs decision and the post-Calvert Cliffs

• implementing regulations of the AEC.

In general, Mapleton believes that all adverse environmental effects fuel cycle, and social and economic costs associated with the nuclear fuel enrichment, to wit, mining, milling, feed material preparation, fuel fabrication, reactor operation, transpor-tation, fuel reprocessing, and ultimate high-level radioactive waste storage and disposal should be considered in this proceeding.

Each phase of the nuclear energy technology is interdependent with the ones which precede and follow it, and each has an immediate or long-term effect on the environment. Each is relevant to the issues in a reactor licensing proceeding.

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l The proposed nuclear reactor is a point in the nuclear fuel cycle spectrum. The effluent which comes out of the plant in the l wastes discharged. to the atmosphere or receiving body of water, or I removal from the plant, and which is shipped from the plant, has an immediate and long-term effect on the environment, and constitutes a drain upon scarce uranium retources.

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. September 28, 1971 Arthur W. Murphy, Esq., Chairman Atomic Safety & Licensing Board The Board should request from the applicant and the Staff evidence of the probable impact and long-term effect of the wastes to be shipped away from the proposed reactor on the in-transit environment through which the wastes are transported, the environ-ment of the fuel reprocessing plant which will handle such wastes, and on the environment of the perpetual care repository of the long lived high-level radioactive wastes generated by such re-actor.

The intervention of the State of Kansas in this proceeding requires the Board to consider the issue of ultimate disposition of such high-level radioactivt wastes.

Mapleton concurs with Saginaw intervenors in their views as to the environmental issues involved in this proceeding.

We believe, however, it is prematurs to specify the environ-mental issues in any gre-ter detail until we have received appli-cant's and Staff's environmental submissions.

• We intend to presert substantial evidence on environmental*

issues. ,

As evidence of this intent, we served (although we were not obliged to) Professor Eckert's tastimony.

As further evidence that Mapleton has undertaken to assemble further environmental evidence, as stated in our letter of September 14, 1971, we serve now, without prejudice, the statement of Dr.

Charles W. Huver.

Discovery For the reasons stated in our letter of September 14, 1971, Mapleton believes motions for discovery are premature at this time.

We however serve notice that we will, af ter the filing of appli-cant's and Staff's further environmental submissions, move for discovery of all documents underlying such submissions or relied m--m- = -.+d ,a 4 mm....m, g,a.eem ww., .,m , , ,

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' l Arthur W. Murphy, Esq., Chairman l Atomic Safety & Licensing Board 3

upon in the preparation thereof, or referred to therein by appli-cant and Staff.

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ILLY LIKE & SCI ER g Like ILame Enc.

l copy tos ASLB members Secretary All counsel of record e

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