ML19256G463

Requests Hearing,On Behalf of Util,Re Amend 72 to Application for CPs & OLs

ML19256G463
Person / Time
Site:	Midland
Issue date:	12/26/1979
From:	Mark Miller ISHAM, LINCOLN & BEALE
To:	Case E, Stello V NRC OFFICE OF INSPECTION & ENFORCEMENT (IE), Office of Nuclear Reactor Regulation
References
NUDOCS 7912310339
Download: ML19256G463 (3)

Text

ISHAM. LINCOLN & BEALE COUNSELORS AT LAW CNE Ff #ST N Af TON AL PLAZA FORTY-5 ECON D FLOOR CHICAGO. lLLINoes 60803

'C LE PwC N E 312-558-7500 TELEX 2-5288 WASHINGTON OFriCE 1060 I F_* STR E ET, N . W.

SEVENTH FLOOR WA S HINGTON. D. C. 2O O 36 December 26, 1979 202 =22-=72o Mr. Edson G. Case Acting Director, Office of Nuclear Reactor Regulation United States Nuclear Regulatory Commission Washington, D.C. 20555 Mr. Victor Stello, Jr.

Director, Office of Inspection and Enforcement United States Nuclear Regulatory Commission Washington, D.C. 20555 Re: Consumers Power Company (Midland Plant, Units 1 and 2)

. Docket Nos. 50-329, 50-330 Request for Hearing Gentlemen:

Consumers Power Company (" Licensee"), by its attorneys, hereby requests a hearing in accordance with Part V of the Order Modifying Construction Permits issued in these dockets and dated December 6, 1979.

On December 19, Licensee filed Amendment No. 72 to its application for construction permits and operating licenses for the Midland Plant; the Amendment seeks Nuclear Regulatory Commission approval for remedial actions associated with the soil activities for safety related structures and systems founded in and on plant fill material. In addition, the Atomic Safety and Licensing Board constituted to conduct the operating license stage evidentiary hearing for the, Midland Plant, by Order dated February 23, 1979, admitted Mary Sinclair's Contention 24 and intervenor Wendell Marshall's Contention 2, both of which deal with the subject of the diesel generator building settlement.

Licensee believes that the issues to .e heard in connection with this Request for Hearing, Contentions 24 and '

2 in the operating license hearing and any hearing which may be required in connection with Licensee's Amendment No. 72 to its application for construction permits and operating '

licenses are substantially identical. At an appro e 322 7912310 3 3 I g

. *a Mr. Edson G. Case Mr. Victor Stello, Jr.

December 26, 1979 Page Two stage in this proceeding, Licensee will move, pursuant to 10 C.F.R. 5 2.716, to consolidate all the proceedings which are considering these issues. In this way one evidentiary presentation may be made on this subject.

Very truly yours, U Ju Michael I. Miller MIM:cem cc: Service List 1663 323

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