ML20063N959

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Objections to Util Refusal to Answer B Stamiris Interrogatories 6 Through 11 & 18.Issues Relevant to Scope of Contentions.Meeting Should Be Scheduled to Finalize Decommissioning Plans.Related Correspondence
ML20063N959
Person / Time
Site: Midland
Issue date: 10/02/1982
From: Marshall W
MAPLETON INTERVENORS, MARSHALL, W.H.
To:
Atomic Safety and Licensing Board Panel
References
ISSUANCES-OL, ISSUANCES-OM, NUDOCS 8210070398
Download: ML20063N959 (2)


Text

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l UNITED STATES OF AMERICA DOCKETED NUCLEAR REGULATORY COMMISSION USNRC BEFORE ATOMIC SAFETY AND LICENSING BOAB[1 OCT -6 N0:17

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Before Administrative Judges:

j Charles Bechhoefer, Chairman OFFICE OF SECREIAE

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Dr. Frederick P. Cowan 00CKETING & SERVICE l

Dr. Jerry Harbour BRANCH

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Docket Nos.

50-329 OM In the Matter of

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50-330 OM CONSUMERS POWER COMPANY

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50-329 OL (Midland Plant, Units 1 and 2) )

50-330 OL

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October 2, 1982 MAPLETON INTERVENORS OBJECTIONS TO CONSUMERS POWERS REFUSAL TO ANSWER BARBARA STAMIRIS INTERROGATORIES Mapleton Intervenors agree with question 6 through 11 and part of 18 under " Cost / Benefit:

Contention lb and lc" in "Stamiris' Inter-1 rogatories and Document Requests to Consumers Power Company, August I

30, 1982."

1.

Mapleton Intervenors agrees with Question 6 because it is per-tinent to the scope of the contention.

The question inquires into the method of financing and collecting decommissioning costs which is important to the Licensing procedures.

The contention, deals with the accuracy of the staff's decommissioning cost estimate, which in our opinion is too low.

Mapleton Intervenors also objects to Consumers Power Companys refusing to admit this contention because financing, in our opinion.and collection of required monies to decommission and decontaminate are environmental issues and are within the scope of the NRC's review.

CP Co. probably will claim that this question is a matter for NRC and not within the jurisdiction of the Michigan Public Service Commission (MPSC) when appearing before the MPSC.

2.

CP Co. objects to Question 7 on the same grounds as Question 6.

3., Mapleton Intervenors agrees with Intervenor Stamaris on all ques-tions from 6 through 7, 8, 10 11 and 18.

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p-Mapleton Intervenors are concerned with the decommissioning and decontaminating of the Midland Nuclear Plant because this became a public safety and health matter and should be resolved before any license is forthcoming from NRC.

Consumers Power Company in its objection to the above listed Stamaris contentions is attempting to pass off to future generations the environment costs from the dangers that will eminate from the radioactive plant.

Mapleton Intervenors contend that Nuclear plants are a threat to the environment and to the public health and safety, as an example TMI, and that therefore the costs of decontaminating and decommis-sioning the Midland Nuclear plant is a matter to be resolved by the ASLB and by the NRC.

Costs should be determined in hearings before the ASLB.

The Mapleton Intervenors reaffirm its strong support of Intervenor Stamaris in the above matters and request that the ASLB set meetings to finalize decommissioning and decontaminating plans and costs thereof.

We also reserve the right to object to any or all other CPC illegal attempts on Stamaris.

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v Wendell H. Marshall President of Mapleton Intervenors

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