ML20064E585

Submits Addl Contentions in Support of 780906 Contentions Objecting to Subj Facil Re Illegal Charges & Spills, Geological Conditions & Storage of Spent Fuel Rods. Certificate of Svc Encl

ML20064E585
Person / Time
Site:	Midland
Issue date:	10/31/1978
From:	Marshall W MAPLETON INTERVENORS
To:	Smith I Atomic Safety and Licensing Board Panel
References
NUDOCS 7811210040
Download: ML20064E585 (5)

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NRC PUBLIC DOCUMENT ROOM 00CET 4W2.1 MAPLETON INi?.RVENORS 7' O , & tm l J/t I M 3 2' CVMg g Route 10 Midland, Michigan 48640

\ M j October 31, 1978 )

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Mr. Ivan W. Smith, Chairman TT, , /* 'g Atomic Safety & Licensing Scard t .# 's Nuclear Regulatory Commission ei'#

Washington, DC 20555  %,,

Dear Mr. Smith:

In ccmpliance with requests by Mr. William Olmstead of this date ed in accordance with Nuclear Regulatory Commission Rule 2.714, the Mapleton Intervenors are submitting the following additional contentions to support our previous contentions submitted on September 6, 1978.

Under the rules, the Mapleton Intervenors contend that:

1) Illegal radioactive charges and spills frem the Palisades Nuclear Power Plant cperation probably is indicative of the operation that will take place at the Midland Nuclear Power facility.

2) Present geological conditiens, according to newspaper accounts, is causing the settling of the generator building at the Nuclear Power Plant site.

3) Michigan law prevents the licensing of a nuisance. Cite Marshall vs. Censumers Pcwer Company in Michigan Court of Appeals on nuisances.

4) The Mapleten Intervencrs contend that the creratien of the Plant will cause nuisance that will disturb their peace and tranquility guaranteed by the United States Constitution and by the State of Michigan laws.

5) Icing and fogging will interfere with Mapleten Intervencrs I lives and will damage their property. This was pointed I

cut in Midland, Michigan recently when the Suclear Regula-l tcry Ccnmission was obtaining information concerning the cperation of the Plant.

6} 5:crage of spent fuel reds frcm cperaticn Of the Plant will impose a health and safety hazard en the citizens and seecifically en Macle:cn Intervencrs who reside wi_hin l'-1/2 miles'cf the' Plant. 7811210pq0-A N -

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Mr. Ivan W. Smith l' Atcaic Safety & Licensing Board October 31, 1978 P:.ge 2

7) Present technology prevents nuclear power plants operation with zero emission, therefore, the creation of a continuous nuisance and health ha:ard to the Mapleton Intervenors.

With the above contentions which will be properly formulated for the Operating Hearing, the Mapleton Intervenors respectfully request that these be considered.

Sincerely,

$'< WN' Y Wendell H. Marshall f 4, dSG

President Mapleton Intervenors WHM:mc i'

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1 SERVICE LIST IN THE MATTER OF CONSUMERS PCWFR CCMPANY, MIDLAND PLANTS, UNIT 1 and 2, DCCKET 450-329 OL and 450-330 OL.

Judd L. Bacon, Esq.

Consumers Power Company Legal Department 212 W. Michigan Avenue

' Jackson, MI 49201 1

Mr. Lester Kornblith, Jr.

Atomic Safety & Licensing Board United States Nuclear Regulatory Commission Washington, DC 20555 Dr. Frederick P. Ccwan 6152 North Verde Trail Apt. B-125 Bcca Raton, Florida 33433 Counsel for the Neclear Regulatory Staff United States Regu'.atory Commission Washington, DC 20155 Mr. Frank J. Kelly Attorney General State of Michigan Lansing, MI 48913 t

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