ML19344A095

Motion for Entry of Encl Draft Order Extending Time for Motions for Document Production.R Renfrow 740329 Ltr to M Cherry Requesting Formal Request for Documents Be Served Prior to 740429 Encl

ML19344A095
Person / Time
Site:	Midland
Issue date:	04/22/1974
From:	Cherry M CHERRY, M.M./CHERRY, FLYNN & KANTER, Saginaw Intervenor
To:	Atomic Safety and Licensing Board Panel
Shared Package
ML19344A096	List: ML19344A095 ML19344A100 ML19344A104 ML19344A108 ML19344A111
References
NUDOCS 8007310603
Download: ML19344A095 (4)

Text

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, , g DocIETED 1 09.Es 6-APR2 61974 > 53 .-

April 22, 1974 c, : c :9 9:mri I~

r.: : :c: .xu g a :a 1 UNITED STATES OF AMERICA MA ATOMIC ENERGY COMMISSION N g

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_BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of ) C

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CONSUMER POWER COMPANY ) . Construction Permits Nos. 81

) 82 (Midland Plant, Units 1 and 2))

L EXTENSION OF TIME RE:

MOTION FOR PRODUCTION OF DOCUMENTS -

THE SAGINAW GROUP hereby moves the Atomic Safety and 4 i-Licensing Board for the entry of an order extending the time h.

within which it may file a Motion for Production of Documents i

or other information from the present due date of April 29, 1974 until ten (10) days after all of the parties have answered inter-rogatories today filed by the Saginaw Group. In support of this motion the Saginaw Group states as follows: t.

t A. The Board had originally set April 29, 1974 for  :

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i the filing of a Motion for Production of Documents;

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B. April 22, 1974 is the date for filing interrogatories ,

and interrogatories being filed by the Saginaw Group includes interrogatories to identify which documents are in existence and also to identify how documents are maintained by the various parties:

C. Without the answers to.these interrogatories the Saginaw Group is not in a position to request document .

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D. Types of documents which probably will be requested

. are-known to at least two of the parties herein

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(the utility and the Regulatory _ Staff) by virtue of' prior communication.. See Exhibit A hereto.

j (A similar- request was 'made of the Regulatory ' Staff) .

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! Thus, these parties are in a position to gather

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these documents notwithstanding the absence of a for-mal motion to produce.

4 WHEREFORE the Saginaw Group request the entry of an I

order permitting the filing of a' Motion to Produce Documents

. l ten-(10) days Jafter the parties have answered the Saginaw Group's

interrogatories dealing with document identification.

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Myrong. Cherry /

Attornpy for Saginaw Grou 4

i Myron M. Cherry ,

4 One IBM Plara- .

Chicago, Illinois 60611'

'(312) 222-9350 l

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' UNITED STATES OF AMERICA '

A'10MIC - ENERGY COMMISSION D R A'F T ORDER The Saginaw Group has filed a motion for an extension of time to file documents production requests until 10 days after 1-interrogatories have been answered by .various parties dealing 1

with the identification of documents. Having considered the  !

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-matter and being convinced of. the merits of the Saginaw Group's 1

i motion: .

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It is hereby ordered that the Saginaw Group may file )

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a motion for. production of documents directed to each of the ,

j parties'herein within 10 days after each of said parties-has answered interrogatorics directed to it dealing with document identification.

2 Dated:

~ Chairman, ASLB

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i IS* \M. LINCOLN & BEALE COUNSELOR $ AT LAW

, ONC FIRST NATIONAL PLAZA FOMf v* SCCONO FLOOM CHICAGO.8LLINCIS 60070

• TELCPMONC 3t2*780*7500 CABLCa M AMS8 March 29, 1974 o

BY MESSENGER Myron M. Cherry, Esq., .

Jenner & Block One IBM Plaza Chicago,_ Illinois 60611

Dear Mike:

Pursuant to our telephone conversation today, I have sent,-by messenger, the amendments to the PSAR and the- Quality.

Assurance manuals for Consumers Power Company. It is my under-standing that the Eechtel manuals are in the mail to me and I will transmit them to you as soon.as I receive them. -

You have also requested that we begin to gather for you the documents in the possession of Consumers referring to'any violations or apparent violatiens of AEC regulations which have occurred at any of the Consumer nuclear plants. We are obtaining the documents for you referting to.such violations at Midland on an expedited basis. However, insofar as other Consumer. nuclear projects are concerned, we will wait until your formal request 3 for these documents.is served since as we stated at the prehearing, we do not, at this time,.see the relevance of those documents to this proceeding. We hope that you will be able to serve your formal request -for such documents prior to April 29 so that we

.may either begin to collect the documents or object to the request  !

and obtain. prompt resolution of this issue, l Very tru curs,

,ff RRR/je-Ry {~' W Renfrow, III cc: Mr. T.r > nce Scoville  !

Mr. Su6d L. Bacon =

Mr. Paul Koval Mr.' Harold Reis .

Mr. James P. Murray.  !

I EXHIDIT A~