ML19331B004
| ML19331B004 | |
| Person / Time | |
|---|---|
| Site: | Midland |
| Issue date: | 09/07/1976 |
| From: | Lowenstein R CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.), LOWENSTEIN, NEWMAN, REIS, AXELRAD & TOLL |
| To: | NRC OFFICE OF THE SECRETARY (SECY) |
| References | |
| NUDOCS 8007240583 | |
| Download: ML19331B004 (2) | |
Text
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c' September 7, 1976 Sam.'el J. Chilk, Secretary U.
S. Nuclear Regulatory Commission Washington, D. C.
20555 Re:
Consumers Power Company Midland Plant,, Units 1 and 2 Docket Nos. 50-32 330
Dear Sir:
We have today received "Intervenors' Motion to Halt Construction of the Midland Facility, or in the Alternative to Clarify NRC Order of August, 1976 Establishing an Atomic Safety and Licensing Board" (Intervenors' Motion), dated September 3, 1976.
That document discusses issues also addressed in the " Motion of Consumers Power. Company to Recall Show Cause Proceedings", dated August 26, 1976 (Licensee's Motion), concerning which responses were directed to be filed today.
In general the common issues relate to the interpretation of the Commission's General Statement of Policy of August 13, 1976, astd its Memorandum and Order of August 16, 1976, initiating proceedings in these dockets.
In particular, both motions address the nature of the action the Commission should take, if any, pending the adoption of the interim fuel cycle rule and while further judicial review is available.
Both motions deal with the propriety of suspension of construction and the scope of the pro-ceeding in these dockets before the Atomic Safety and Licensing Board.
Accordingly, we request the Commission to consolidate its consideration of Licensee's Motion and the Intervenors' Motion.
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I'OWENSTr.IN, N'EWMAN, REss & Ax. RAD t
Samuel J. Chilk
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September 7, 1976 Page Two Consumers Power Company will file a prompt and appropriate response to Intervenors' Motion.
Finally, in connection with this suggestion for consolidation, we repeat our request for oral argument and request the Commission to defer action on the motions until such argument has been held on them.
Sincerely yours,
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Robert Lowenecein LOhENSTEIN., NEmiAN, REIS & AXELRAD 1025 Connecticut Avenue, N. W.
Washington, D. C.
20036 Counsel for Consumers Power Company O
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