ML19329F397
| ML19329F397 | |
| Person / Time | |
|---|---|
| Site: | Midland |
| Issue date: | 01/07/1971 |
| From: | Lowenstein R, Rich Smith CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.), LOWENSTEIN, NEWMAN, REIS, AXELRAD & TOLL, SMITH & BROOKER |
| To: | Atomic Safety and Licensing Board Panel |
| Shared Package | |
| ML19329F398 | List: |
| References | |
| NUDOCS 8006270447 | |
| Download: ML19329F397 (3) | |
Text
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.p ITED STATES OF R4 ERICA e
ATOMIC ENERGY COMMISSION
,- g - g l.
In the Matter of
)
Docket No.
0-329
)
CONSUMERS POWER COMPANY
)
Docket No. dU-33u
)
(Midland Plant)
)
MOTION OF APPLICANT CONSUMERS POWER COMPANY FOR AN ORDER REQUIRING S AGINAW VALLEY NUCLEAR STUDY GROUP, ET AL, TO ANSWER WRITTEN INTERROGATORIES Applicant Conseners Power Company (hereinaf ter Applicant) hereby moves before the Atomic Safety and Licensing Board, pursuant to 10 C.F.R. 552.730 and 2.740 of the Atomic Energy Commission's Rules of Practice, for an order requiring inter-
~
venors Saginaw Valley Nuclear Study Group, Citizens Committee for the Environmental Protection of Michigan, Sierra Club, United Auto Workers of America, Trout Unlimited, West Michigan Environmental Action Council, Inc. and Environmental Law Society of the University of Nichigan Law Students (sometimes referred to as University of Michigan Environmental Law Society) to answer Applicant's interrogatories to them dated and served January 7, 1971 by January 21, 1971.
The answering by the aforesaid intervenors of these inter-rogatories is required in order to permit Applicant to make adequate preparation for the hearings and to permit the hearings to proceed more quickly and expeditiously by giving Applicant notice of and familiarity with the evidence supporting said intervenors' contentions.
Moreover, it would be unfair to provide THIS DOCUMtRT CONTAINS MWM 800gggy
Q r said intervenors with the right to compel answers to interro-gatories from Applicant without giving a similar right to Applicant.
This morion is made because the Ioard's order of December 8, 1970 failed to rule upon so much of Applicant's motion as requested the Board to establish dates for the filing of Applicant's interrogatories and of responses thereto.
The due date proposed in this motion for th,e filing of answers to, the attached interroga-tories (January 21, 1971) is the same date as was proposed in Applicant's motion dated November 30, 1970.
It is also the same date'as was fixed in the Board's order of December 8, 1970, for Applicant to respond to the interrogatories of Saginaw Valley Nuclear Study Group, et al.
Respectfully submitted, Dated:
January 7, 1971 s
.k a "
j s 'W RICHARD G.
SMITH Smith & Brooker, P.C.
730 Washington Avenue Bay City, Michigan 48706 (517) 892-2595 i
.A i
W~
L ROBERT LOWENSTEIN Lowenstein and Newman 1100 Connecticut Avenue, N.W.
Washington, D.C.
20036 (202) ~ 296-7585 Attorneys for Applicant Of Counsel:
Consumers Power Company Harold P. ' Graves John K.
Restrick i
Jerome E. Sharfman J
~
("HITED STATES OF AMERICA F
ATOMIC ENERGY COMMISSION In the Matter of
)
}
Docket Nos. 50-329 CONSUMERS PONER COMPANY
)
50-330 I
i' (Midland Plant)
)
CERTIFICATE OF SERVICE I hereby certify that copies 'f a " Motion of Applicant Consumers o
Power Company for an order requiring Saginaw Valley Nuclear Study Group, et al, to answer written interrogatories", dated January 7, 1971 and the interrogatories of the same date, in the above-captioned matter have been served on the following by deposit in the United States mail, first class or airmail, this 7th day of January, 1971.
Arthur W. Murphy, Esq., Chairman Atomic. Safety and Licensing Board Milton R. Wessel, Esq.
Columbia University School of Law Kay, Scholer, Fierman, Hays and Handler Box 38, 435 West 116th Street 425 Park Avenue New York, New York 10027
'New York, New York 10022 Dr. Clark-Goodman James N. O'Connor, Esq.
Professor of Physics The Dow Chemical Company University of Houston 2030 Dow Center 3801 Cullen Boulevard Midland, Michigan 48640 Houston, Texas 77004 Myron M.
Cherry, Esq.
Dr. David B.
Hall 111 West Monroe Street Los Alamos Scientific Laboratory Chicago, Illinois 60603 P. O. Box 1663 Los Alamos, New Mexico 87544 Algie A. Wells, Esq., Chairman Atomic Safety and Licensing Board Pan William J. Ginster, Esq.
U.S. Atomic Energy Commission Suite 4 Washington, D.C.
20545
)
Merrill Building i
Saginaw, Michigan 48602 Mr. Stanley T.
Robinson, Jr.
Chief, Public Proceedings Branch l
James A. Kendall, Esq.
Office of the Secretary of the j
j 135 N. Saginaw Road Commission l
i Midland, Michigan-48640 U.S. Atomic Energj Commission ~
Washington, D.C'.
20545 Anthony Z. Roisman, Esq.
j Berlin,-Roisman, and Kessler L
1910 N Street, N.W.
Washington, D.C.
20036
_M erome,E. Sharfman Thomas F. Engelhardt, Esq.
p U.S. Atomic Energy Commission Washington,'D.C.
20545 s
.