ML19330A168

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Requests That Timm & Mm Cherry Be Served W/Any Gunderson Testimony.Informs NRC That Intervenors Will Object to NRC Filings W/Intent of Shoring Up Util Case.Discusses QA & QC Re Facility Const
ML19330A168
Person / Time
Site: Midland
Issue date: 04/27/1977
From: Cherry M
CHERRY, M.M./CHERRY, FLYNN & KANTER
To: Hoefling R
NRC OFFICE OF THE EXECUTIVE LEGAL DIRECTOR (OELD)
References
NUDOCS 8007150938
Download: ML19330A168 (1)


Text

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CHICAGO. lLLINolS Go6il (312) $ 6 5 - f 0 7 7 4

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4 April 27, 1977 h

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N Richard K.

Hoefling, Esq.

b Counsel for NRC Staff os U.

S. Nuclear Regulatory Commission s

Washington, D. C.

20555

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Consumers Power Company (Midland Plant)

Suspension Hearing

Dear Mr. Hoefling:

Please be sure to serve Dr. Timm as well as myself with any Gunderson testimony.

Please also be prepared to file a Motion with the Gunderson testimony since we will object to any more filing of Staff papers with the sole intent of shoring up a sagging case for the utility.

Let me put the Regulatory Staff on notice of a letter dated April 22, 1977 from Mr. Renfrow to the Board which shows that the quality assurance and quality control at the Midland site is so far below adequate standards that the Midland plant is probably best dubbed an accident under construction.

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Quality assurance and quality control are supposed to be the first line of defense at the Commission---rather because of lax enforcement, it has become the last avenue of inquiry.

As prelude to my reopening the entire question of quality assur-a ance and quality control before the Midland hearing, I ask whether the Regulatory Staff is going to do anything about the constant problems of construction at the Midland site.

By carbon copy of this letter, I am informing the Board that absent effective action by the Commission, concerning these quality assurance problems, Intervenors will once again take up the task of regulating nuclear power and will bring the matter to issue.

The Regulatory Staff cannot claim with injured innocence or sincerity in regulation unless action is attached to those lofty platitudes.

80 Sincyrely, h#

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Atomic Safety & Licensing Board Panel N