ML19331A798
| ML19331A798 | |
| Person / Time | |
|---|---|
| Site: | Midland |
| Issue date: | 01/09/1978 |
| From: | Cherry M CHERRY, M.M./CHERRY, FLYNN & KANTER, Saginaw Intervenor |
| To: | Atomic Safety and Licensing Board Panel |
| Shared Package | |
| ML19331A795 | List: |
| References | |
| NUDOCS 8007230829 | |
| Download: ML19331A798 (3) | |
Text
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UNITED STATES OF AMERICA
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NUCLEAR REGULATORY COMMISSION
"'I Before the Atomic Safety and Licensing Board.
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In The Matter of
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CONSUMERS POWER COMPANY
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Docket Nos. 50-329
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50-330 Midland Plant, Units 1 and 2
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AMENDMENT TO SECOND REQUEST FOR DISCOVERY Putsuant to 10 C.F.R. 5 2.741, Saginaw Intervenors amend their "Second Request for Discovery" (served and filed under date of January 5,1978) by adding thereto the following additional requests for production of documents, directed to Consumers Power Company and to Dow Chemical e
Company:
I.
As to Dow Chemical Company d.
All documents, writings, drawings, graphs, charts, photographs, tape or other recordings, memoranda, correspondence, notes, computer printouts, document compilations, or other physical records or compilations of data from which information can be obtained, recording, describing, summarizing, or referring or relating to the relative costs and/or benefits of the purchase of process steam by Dow from Consumers' proposed Midland nuclear power plant as opposed to the purchase or generation by Dow 80072308Af G
a of process steam from any other source (including without c
limitation the upgrading or renovation of existing Dow facilities or the construction or acquisition by Dow of other facilities).
You are requested to produce documents as de-scribed above from the period January 1, 1976 to the date of production of documents, but you may exclude from production any documents you have already produced.
The foregoing document production request is in addition to, and not in lieu of, the document production request served upon you under date of January 5, 1978.
II.
As to Consumers Power Company i.
All documents, writings, drawings, graphs, charts, photographs, tape or other recordings, memoranda, correspondence, notes, computer printouts, document compilations, or other physical records or compilations of data from which information can be obtained, recording, describing, smmnarising, or referring or relating to the relative costs and/or benefits of the purchase of process l
steam by Dow frcm Consumers' proposed Midland nuclear l
power plant as opposed to the purchase or generation by Dow l
l of process steam from any other source (including without limitation the upgrading or renovation of existing Dow facilities or the construction or acquisition by Dow of j
other facilities).
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You are requested to produce documents as de-scribed above from the period January 1, 1976 to the date of production of documents, but you may exclude from production any documents you have already produced.
The foregoing document production request is in addition to, and not in lieu of, the document production request served upon you under date of January 5, 1978.
Respectfully submitted, i
L H T0k Myron
. Cherry ff-MYRON M. CHERRY Law Offices One IBM Plaza-Suite 4501 Chicago, Illinois 60611 (312) 565-1177 s
PROOF OF SERVICE I hereby certify that I mailed a copy of the foregoing Amendment to Second Request for Discovery to members of the Atomic Safety & Licensing Board, the Secretary of the Nuclear Regulatory Commission, counsel for the Regulatory Staff, counsel for Dow Chemical Company and counsel for Consumers Power Company, postage prepaid and properly addressed before the close of business on January _9, 1978.
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