ML19344A078

Exhibit a to 710930 Motions,Providing List of Documents Re Motion 9 for Production

ML19344A078
Person / Time
Site:	Midland
Issue date:	09/30/1971
From:	Saginaw Intervenor
To:	Atomic Safety and Licensing Board Panel
Shared Package
ML19344A073	List: ML19344A072 ML19344A077 ML19344A078 ML19344A080
References
NUDOCS 8007290952
Download: ML19344A078 (6)

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• T1 UNITED STATES or AMEnICA sirn er me renwy r.u: tre.ams

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DEFORM Tile ATOMIC SAFETY AND LICENSING BOARD In the Matter of )

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CONSUMER POWER COMPANY ) Docket Nos. 50-329 ,

) 50-330 I (Midland Plant, Units 1 and 2) ) '

3 EXHIBIT A TO INTERVENORS, MOTIONS FILED SEPTEMBER 30, 1971* ,

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The following documents are the subject of Int.crvenors k

Motion IX to produce documents, filed on September 30, 1971.

A. All documents.which fairly fall within or have reference to Sections 101(b) and 102 of the National' Environmental Policy Act or the Atomic Energy Commission's Draft Guide to the Preparation of Environmental Reports incued in February,.1971; B. All documents dealing.with currently availab]e

-or to be available,ipment anti-pollution equ capable of beingwithin the next five year

-installed in convep'tional power plants, i.e.,

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.rThe documents-listed herein are required to be produced by each party.to this proceedineg who'has such documents in

'its possession or in its contgol, whether such production in duplicative-or not.

The Vord " document" as used in this Jetter should be.interprbted in the same manner an that word was defined in the last 'of each set of Int.ervenors' LInterrogatories,carlier addre,ssed to.each of the parties.,

8007290.857

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any power plant other than a nucicar power plant; ,

I C.. All. documents dealing with the need over the next ten years for electricity in Applicant's franchised.tcrrit'ory. This category also calls for all documents dealing wjth the basis for any such need, including but.'not limited to, amounts of money spent to pronote use of electricity and/or to create a need; D. All documents dea' ling with the availab311ty of alternatives to any need for electricity including, but not limited to the opportunity to Applicant to purchase all or part of said needed electricity from utilities which have a peak period different from Applicant or have or will have electricity available for sale. This-category also calls for any documents dealing .with costs of interconnection with utilities from whom electrici ty could be purchased in the event an interconnection with Applicant were accomplished; E. All documents dealing with the determination to site the proposed Midland Units including ~

documents dealing with alternative sites and alternative types of power plants, including all costs and projected completion dates; F. All documents dealing with short and long range supplies of coal, oil and gas in the possension and control of or purchaseable by Applicant over the next ten years for use in conventional power plants; ,

'G.. All documents dealing with short and long renne supplies of uranium in the possession or control of or purchaseable by Applicant for use in nuclear power plants. This category fairly calls for information dealing-with the fast broeder program to the extent that.the fast breeder is to be relied upon'for the production of uranium (or nuclear fuel) Ito be used in nuclear power plants; H. All documents dealing with the projected .

construction of power plants, of any kind, for the generation of electricity by.any utiiity

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from whom Applicant.would purchase, or is capable of purchasing by reason of inter-cioncction, electricity over the next ton years; ,

I. All docur.'ents don' ling with arrangementn with utilities or others, to whom or from whom Applicant sells:or purchases electricity or is, under certain conditions oblig;.hed by contract to sell or purchase electricity.

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This category fai'rly calls for copics of all contracts, se.tting forth Applicant's interconnection agreements as well as, for example, agreements with municipalities; J. All documents dealing with analyses of the balancing and rationalization, both long and short term, o.f natural resourcca which arc or can be used in any kind of power plant; K. All documents dealing with Dow's present facilities for the production of proccus steam and electricity in Midland, insofar as they reflect analgses, studies or deter-dinations dealing,with the retrofitting of such facilities with anti-pollution equin- .

ment, including the specifica and costs thereof; L. All' documents dealing with Dow's need for process steam and electricity, assuming first that it shuts electricity.and steamdownfacilitics its current andMidland then that it does not, ,specifying all alternatives, including costs and projected completion dates'available to it, (whether such alternatives include the availability of gas or other natural resources to use as a power supply) including but not' limited to the ability of Dow to expand elsewhere than Midland, Michigan.l This category fairly calls.for documents, studies and oconomic statistics dealing'with the growth or

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inhibition.of growth of Midland, Michigan to the extent that Dok's desire for process steam effects.a dep'ision to expand in Midland, Michi'gan rather than, for example, in Freeport, ,

Texas;'and documents-dealing with the relative t

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cost of electricity and process steam in the geographic area of possible Doa

. expansion; M. All documents deal'ing-with chemical explosionn

• at Dow's Midland. complex and elsewhere, whether at a Dow facility or not, within tho

-pa'st 20 years. This.-category. fairly calls

' for the source of'each such cxolosion, the

1. character of the q'xplosion, th'c chemicals or other explosivos involved, the damages incurred and the physical. characteristics .

• of the explosion such as the direction of th'c blast and the geog,raphic area offected by the blast; l

{ N. 'All documents dealing with the type and' character of the expalslon Dow intends to make in Midland, including t he products uhich will

' be produced in and thc p'ollution which will be generated by such e :panded plants;

0. All documents dealing rith or showing the  !

reliability, in terms of maintenance and f'orced outage, of erah nuclear power plant in the United States.and for.cach fossil fuel -

plant in the Uni'ed States. There in no timo limitation with respect to nuclear power i

plants, but w* ch respect to fossil fuel plants,

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documents ro'.lecting information earlier than 1955 are nec called for;

- P. All' documents dealing with the Applicant's L plans for the next ten years for power pro-duction by any means, that is, whether by.

- nuclear power or more conventional means, nuch '

as fossil fuel facilities;

! Q. All--documents. dealing with releases by Dow l 7

L Chemical in normal and abnormal circumstances l l '

of any chemical,' solid or substance, to the' )

l 2 atmosphere or to the rivers and streams over l the last ten years. .This category calls for i a specific description of cach suph chemical, solid'or substance, whether released normally or abnormally, how such. chemical was released, what steps 1were taken to prevent any such .

futurc release and whether such steps have

-been" successful. This category of documents also-fairly calls--for the'cencontration of C

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such r'eleases andI the effects it han had upon rivers and' streams and the atmosphere; R. Alldocumentsfdeakingwiththeinteraction and/or additive effect, synergistically, mutagenically, carcinogenically, or otherwi.se of chemicals with radiation; S. A13 documents dealing with each analysis, in connection with the: proposed Midland Unita, for each section of the Nationa] Environmental Policy Act required to be so analyzed, including but not limited to review or analysis pursuant to Section 102(2) (D) of the National Environmental Policy Act; T. All documents dealing with thermal or other effects.of any kind which are created, aided or abetted by the_ proposed cooling towers and cooling pond; ,

U. All documents, analyscs and studica dealing with thc.cffects, if any, as a result of Applicant's proposed use of water from the Tittabawassco River, upon users'of water from the Tittabawassee River, other than Applicant and for any purpose, whether industrial or not; V. All documents earlier called by each of the Intervenors' Interrogatories which were not produced upon_the; grounds that production was not relevant because the Interrogatories or documents related 'to environraental . matters ;

W. All documents dealing with storage, transporta-tion and disposal'of radioactive waste products and spent fuel used or created by operation of

-the proposed Midland Units. This category fairly calls for information dealing with the entire question of xadioactive waste dispocal including what provisions will be made for off-site storage.

X. All documents showing the status of procurement and manufacture of each componcat or system to be used or instal 4ed'at the proposed Midland Units. This' category fairly calls for all ,

information dealing with how far anyone har. gone in ' building or commiting to build a f acility not yet' authorized by law in order'to determine whether NEPA or this Board 's authority- 1.s bei ng-infringed upon by.the: expenditure of funda and

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. t Y. Al1'lotters issued by the Advisory Cammittcc on Reactor Safegu'ards to the . Direct.or of Re:qulation at any. tinc in connection with each pressurized water reactor whether already ' licensed or whether. the subject of an in-houno application or liconninJ hearing. ,

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Z. Sufficient documents which set forth each.

'so-called-ACRS asterisked items regarding pressurized water reactors, which are

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