ML19331B012
| ML19331B012 | |
| Person / Time | |
|---|---|
| Site: | Palisades, Fermi, Big Rock Point, Midland, 05000475, 05000476  |
| Issue date: | 05/03/1974 |
| From: | Jenny Murray US ATOMIC ENERGY COMMISSION (AEC) |
| To: | |
| References | |
| NUDOCS 8007250697 | |
| Download: ML19331B012 (4) | |
Text
i IMts DOCUtAENT COMTAlHSM 9 /' 3 S O 1
POOR QUAUTY PAGES
@ 3 -72V UNITED STATES OF AMERICA ATOMIC ENERGY COMMISSION l
BEFORE THE ATOMIC SAFETY AND LICENSING B0Ag In the Matter of
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CONSUMERS POWER COMPANY C
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(Midland Plant, Units 1 and 2)
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r AEC REGULATORY STAFF OBJECTIONS TO M
SCOPE OF SAGINAW GROUP INTERROGATORIES
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On January 23, 1974, the Comission published in the Federal Register a notice of hearing on an order to show cause issued b/ the Director of Regulation to Consumers Power umpany (licensee) concerning quality assurance compliance in the construction of its Midland Plant (39 F.R. 2619).
In the notice the Comission specified so issues to be decided by the Atomic Safety and Licensing Board (3aard) designated to preside at the hearing.
These issues are 1)whether the licensee is implementing its quality assurance program in compliance with Comission regulations, and 2) whether there is a reasonable assurance that such implementation will continue throughout the construction process.
On April 22, 1974, the Saginaw Group, a party to the proceeding mailed what was captioned as the "First Set of Interrogatories Directed to the Regulatory Staff." At page 2, in numbered paragraph 2, it is stated that:
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"In the event that you object to providing infomation for other than the Midland power facility. please supply the infomation for the Midland facility and state your reasons you believe information as to Big Rock, Palisades, Femi-1 and Quanicassee are not relevant or appropriate to the issues which are subject to this proceeding."
The AEC Regulatory Staff (Staff) believes it appropriate at this juncture to register with the Board its formal objection to providing such information rather than setting forth such object. ions in the format proposed by the Saginaw Group.
In the interest of expediting this proceeding we believe that this matter should be resolved at the earliest possible moment so that' discovery and other appropriate matters can be undertaken with a clearer understanding by all parties to the proceeding as to the scope of the subject matter to be dealt with in this proceeding.
The Big Rock, Palisades and Fermi-1 facilities have all been licensed for operation by the Commission.
The Big Rock and Palisades facilities have been operating pursuant to such licenses for a considerable period of time. O Fermi-1 is a facility which has been licensed for operation for even a longer period than the other two facilities. U Furthermore, with respect to Fermi-1, Consumers Power Company has never been the licensee for that facility.
Its only involvement with the construction and operation of that facility was as a member of a combined group 1 & 2/ The Big Rock facility was licensed 5/1/64 (DPR-6); the Palisades facility was licensed 3/24/71 (DPR-20), and the Femi-1 facility was licensed 5/10/63 (DPR-9).
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known as the Power Reactor Develepaent Corporation. As to Quanicassee, the application for construction permits submitted by the licensee was docketed by the Conmission en February 25, 1973, an d is currently in the early stages of review by tne Staff.
A fair reading of the Saginaw Grcup interrogatories gi.es no indicatien as to the relevance or =ateriality of the aforecentioned facilities to the issues before the Board in this proceeding. Ncne f the named facilities are under constructicn and for those of the facilities operated by this licensee all were licensed suoject to Ouality assurance requirements applicable at the tire these facilities were licer. sed for construction and operation.
Accordingly, it is the position of the Staff that unless the Saginaw Group can =ake a clear showing that infor=aticn as to ese facilities is relevant and material to the issues before this Soard the Staff should not be required to provide infor=ation with respect to these facilities in respending to the Saginaw Group interroga: cries.
For the reascns set forth above, the Staff cbjects to providing answers to the Saginaw Group's interrogatories with respect to lig Reck, Palisades, Fermi-1 and Quanicassee facilities.
Respectfully submittet, oares P. Murray, r.
Counsel for AEC Regulatory Staff Dated at Bethesda, Maryland this 3rd day of May,1974.
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UNITED STATES OF AMERICA ATOMIC ENERGY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of C
t etion Permit CONSUMERS POWER COMPANY N
(Midland Plant, Units 1 and 2)
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CERTIFICATE OF SERVICE I hereby certify that copies of "AEC Regulatory Staff Objections to Portions of Saginaw Group Interrogatories" dated May 3,1974 in the captioned matter have been served on the following by hand delivery or by deposit in the United States mail, first class or air mail, this 3rd day of May,1974:
Michael Glaser, Esq., Chaiman Milton R. Wessel, Esq.
Atomic Safety and Licensing Board Kay, Scholer, Fierman, Hays and 1150 - 17th St., N.W.
Handler Washington, D.C.
20036 425 Park Avenue New York, New York 10022 Mr. Lester Kornblith, Jr.
Atomic Safety and Licensing Board James N. O' Conner Panel The Dow Chemical Company U.S. Atomic Energy Commission 2030 Dow Center Washington, D.C.
20545 Midland, Michigan 48640 Dr. Enuneth A. Luebke Myron M. Cherry, Esq.
Atomic Safety and Licensing Board Jenner and Block Panel One IBM Plaza U.S. Atomic Energy Commission Chicago, Illinois 60603 Washington, D.C.
20545 Atomic Safety and Licensing Appeal Secretary Board U.S. Atomic Energy Corrmission U.S. Atomic Energy Cornission ATTN: Mr. Frank W. Karas Washington, D.C.
20545 Chief, Public Proceedings Staff Washington, D.C.
20545 Laurence M. Scoville, Jr.
Clark, Klein, Winter, Parsons &
Michael I. Miller, Esq.
Prtwitt Isham, Lincoln & Beale 1600 First Federal Building One First National Plaza 1001 Woodward Avenue Chicago, Illinois 60670 Detroit, Michigan 48226 games P. Murray, Jr. Counsel for AEC Regula/
tory Staff