ML19331B018
| ML19331B018 | |
| Person / Time | |
|---|---|
| Site: | Midland |
| Issue date: | 12/24/1973 |
| From: | Bacon J CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.) |
| To: | Bender P US ATOMIC ENERGY COMMISSION (AEC) |
| References | |
| NUDOCS 8007250711 | |
| Download: ML19331B018 (2) | |
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LEGAL C E7 ARTMENT
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ceneres Arroiner Judd L. Secon t.Nen B. gese Genera Jffices: 212 West McMigan Avemue. Jackson Michigan 49201. Area Coce S17 788-0650 coo.rt J. Byere H. E. Ciert
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Decemb1r 24,1973 Stuart H. Redner WHlaam E. Wiener Senoor Attorneys C$UU $ **e'.'U',
RE: CONSUMERS POWER CCMPANY R F G'86**'
Midland Plant, Units 1 and 2 O.* I.TCc=
Construction Permits Nos. 81 and 82 Coyne A. Kirtiby Albert D. McCallum 0:vid A. Makedonio Richard L. Mintz crid R. R d I
Joan u s,nse.
Mr. Paul C. Bender
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Secretary of the Com:nission THIS DOCUMENT CONTAINS U. S. Atomic Energy Connnission POOR QUAUTY PAGES Washington, DC 20545
Dear Mr. Bender:
Transmitted herewith are the original and 20 copies of the following two documents addressed to the Commission with respect to the Order to Show Cause which was issued on December 3, 1973:
1.
" Answer to Order to Show Cause" subscribed and sworn to by Stephen H. Howell, Vice President, Consumers Power Company; and 2.
" Motion to Dismiss Order to Show Cause."
Consumers Power Company submits that, for the reacons set forth in the above-described Motion, the Order to Show Cause was illegally issued and must be dismissed; and that, in any event, the Answer shows that Consumers Power Company is in compliance with the Commission's regulations pertaining to quality assurance and that there is reasonable assurance that such ccxnpliance will continue throughout the construction process. Accordingly, Consumers Power Company believes that a hearing is neither required nor legally appropriate in the circumstances.
If, however, the Consnission (1) has not granted the Motion and (2) detemines that the Answer does not show cause why activities under the construction permits should not be suspended, then, pursuant to the terms of the Order to Show Cause and the Commission's regula-tions, Consumers Power Company hereby requests a hearing. Such request 80072509ll
u Mr. Paul C. Bender 2
Re: CONSUMERS POWER COMPANY Midland Plant, Units 1 and 2 Construction Pemits Nos. 81 and 82 December 24, 1973 is without prejudice to the rights of Consu:ners Power Company to continue to challenge the legality of the Order to Show Cause and of any related Counission action or proceedings and to seek such admin-istrative or judicial relief by such action as Consumers Power Company may consider appropriate.
Respectfully submitted,
/s/JuddL. Bacon
.JLB:ms Judd L. Bacon Counsel for Attachments Consumers Power Company
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