ML20027E512
| ML20027E512 | |
| Person / Time | |
|---|---|
| Site: | Midland |
| Issue date: | 11/08/1982 |
| From: | Steptoe P CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.), ISHAM, LINCOLN & BEALE |
| To: | Atomic Safety and Licensing Board Panel |
| References | |
| ISSUANCES-OL, ISSUANCES-OM, NUDOCS 8211150446 | |
| Download: ML20027E512 (5) | |
Text
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11/8/82
!$NED UNITED STATES OF AMERICA
'd2 A'0V 12 An 77 NUCLEAR REGULATORY COMMISSION BEFORETHEATOMICSAFETYANDLICENSINGBOEkb[j,!Eggyj.'r URAllC Hv'UE In the Matter of
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Docket Nos. 50-329-OM CONSUMERS POWER COMPANY
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50-330-OM
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50-329-OL (Midland Plant, Units 1
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50-330-OL and 2)
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APPLICANT'S MOTION FOR EXTENSION OF TIME TO FILE Q.A. TESTIMONY AND DEFERRAL OF Q.A. HEARINGS SCHEDULED TO BEGIN ON NOVEMBER 30, 1982 On October 29, 1982 the NRC Staff filed extensive testimony concerning quality assurance issues to be offered at the hearing presently scheduled to begin on Tuesday, November 30, 1982.
This testimony had been several months in preparation.
While Applicant had originally agreed to provide responsive testimony by November 15, 1982, upon receipt of the Staff's testimony it has become apparent that it will not be possible to prepare a response in so short a time frame.
This is because of the unexpected length of the Staff's testimony and the need to involve upper level Company management, who have other pressing responsibilities, in the formulation and review of Applicant's response.
Accordingly, Applicant respectfully requests that the quality assurance hearings presently scheduled to begin 8211150446 82110s
{DRADOCK 05000329 PDR bD
. V on November 30 be postponed until the week of December 13.
Applicant also requests that it be allowed until December 1 to file its responsive testimony to be offered at the hearings beginning December 13.
If the week of December 13 is not available, Applicant requests the Board to reschedule the Quality Assurance hearings for as early as possible in 1983.
Applicant understands that the Board is not able to make a decision concerning postponement of the quality assurance hearings at this time.
We would expect that to be determined by the parties and the Board during the hearings in Midland beginning on November 15.b/
In the interim, however, Applicant requests that it be granted relief from the present November 15 filing deadline.
Applicant would be prepared to hand-deliver its testimony to the Board and parties in Midland on November 22.
This represents the earliest possible time by which Applicant could prepare a response to the voluminous testimony filed by the Staff.
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Applicant understands that the Staff has no objection to the week of December 13; however, at least one of the other parties has expressed reluctance to hold hearings so close to the holiday season.
Thus we asFume that the Board will want to hear from all parties before it makes such a scheduling decision.
. (Applicant's preference, of course, is the December 1 filing deadline, December 13 hearing schedule proposed above.)
In an attempt to avoid a lengthy conference call, I have contacted the other parties to obtain their views with respect to an extension of the November 15 filing deadline.
The Staff is opposed to any extension of the November 15 filing deadline unless the quality assurance hearings are post-poned to the week of December 13.
Mrs. Stamiris similarly believes that any extension of the November 15 filing deadline should be tied to a corresponding extension of the hearing schedule; however, she wished me to emphasize her strong, over-riding concern that underpinning work not be allowed to proceed until the quality assurance hearings can be completed.
Mrs.
Sinclair did not object to the requested extension of the November 15 filing deadline.
I was not able to contar;t Mr.
Marshall.
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Philip P.
Step oe
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Isham, Lincoln & Beale 3 First National Plaza Chicago, Illinois 60602 (312) 558-7500 November 8, 1982
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of
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)
Docket Nos. 50-329-OM CONSUMERS POWER COMPANY
)
50-330-OM
)
50-329-OL (Midland Plant, Units 1
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50-330-OL and 2)
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CERTIFICATE OF SERVICE I,
Philip P.
Steptoe, one of the attorneys for Consumers Power Company, hereby certify that a copy of
" Applicant's Motion For Extension of Time to File Q.A.
Testimony and Deferral of Q.A. Hearings Scheduled to Begin on November 30, 1982" was served upon all persons shown in the attached service list either by Federal Express or by deposit in the United States mail, first class, as indicated, this 8th day of November,1982.
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\\W (UJS w h(h /t Philip P.
Ste toe
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SUBSCRIBED AND SWORN before me this 8th day of November, 82.
Notary Public My Commissbn Expires January la,1933
SERVICE LIST hb Frank J. Kelley, Esq.
Steve Gadler, Esq.
Attorney General of the 2120 Carter Avenue State of Michigan St. Paul, Minnesota 55108 Carole Steinberg, Esq.
Assistant Attorney General Atomic Safety & Licensing Environmental Protection Div.
Appeal Panel 720 Law Building U.S. Nuclear Regulatory Comm.
Lansing, Michigan 48913 Washington, D. C.
20555 Myron M. Cherry, Esq.
Mr. C.
R.
Stephens Cherry & Flynn Chief, Docketing & Services Suite 3700 U.S. Nuclear Regulatory Comm.
Three First National Plaza Office of the Secretary Chicago, Illinois 60602 Washington, D.
C.
20555 Mr. Wendell H. Marshall FE Ms. Mary Sinclair 4625 S. Saginaw Road 5711 Summerset Street Midland, Michigan 48640 Midland, Michigan 48640 FE Charles Bechhoefer, Esq.
FE William D.
Paton, Esq.
Atomic Safety & Licensing Counsel for the NRC Staff Board Panel U.S. Nuclear Regulatory Comm.
U.S. Nuclear Regulatory Comm.
Washington, D. C.
20555 Washington, D. C.
20555 Atomic Safety & Licensing FE Dr. Frederick P. Cowan Board Panel 6152 N. Verde Trail U.S. Nuclear Regulatory Comm.
Apt. B-125 Washington, D.
C.
20555 Boca Raton, Florida 33433 FE Ms. Barbara Stamiris Mr. D. F. Judd 5795 North River Road Babcock & Wilcox Route 3 P. O. Box 1260 Freeland, Michigan 48623 Lynchburg, Virginia 24505 FE Dr. Jerry Harbour FE James E.
Brunner, Esq.
Atomic Safety & Licensing Consumers Power Company Board Panel 212 West Michigan Avenue U.S. Nuclear Regulatory Comm.
Jack'>n, Michigan 49201 Washington, D. C.
20555 FE Lee L. Bishop, Esq.
Harmon & Weiss 1725 "I"
Street N.W.
- 506 Washington, D.
C.
20006 FE - Federal Express balance sent by first class mail