ML20050N666
| ML20050N666 | |
| Person / Time | |
|---|---|
| Site: | Midland |
| Issue date: | 04/09/1982 |
| From: | Potter W DOW CHEMICAL CO., FISCHER, FRANKLIN, FORD, SIMON & HOGG |
| To: | NRC ATOMIC SAFETY & LICENSING APPEAL PANEL (ASLAP) |
| Shared Package | |
| ML20050N661 | List: |
| References | |
| ISSUANCES-CP, NUDOCS 8204140403 | |
| Download: ML20050N666 (4) | |
Text
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION 22 (( ' 12~ ["1f ATOMIC SAFETY AND LICENSING APPEAL BOARD
)
IN THE MATTER OF
)
)
Docket Nos. 50-329 CP CONSUMERS POWER COMPANY
)
50-330 CP
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(Midland Plant,
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Units 1& 2
)
)
)
MOTION OF THE DOW CHEMICAL COMPANY FOR EXTENSION OF TIME TO RESPOND TO BRIEF OF CONSUMERS POWER COMPANY IN OPPOSITION TO INTERVENOR'S EXCEPTIONS 1.
On April 5, 1982, Consumers Power Company filed with this Board a "Brief of Consumers Power Company In Opposition To Intervenor's Exceptions".
Under the existing Board procedure, the final Staff Reply Brief is due on April 15, 1982.
l 2.
Dow has reviewed the Brief filed by Consumers Power Company.
Rather than simply taking issue with exceptions filed by the Intervenor, the Consumers Brief goes on to take excep-tion to certain facts found by the Licensing Board below and also contains a recitation of facts on which the Licensing Board below made no finding.
In several cases, Dow does not agree with Consumers that the Board made the finding that Consumers claims it did and Dow also disagrees with certain i
i 8204140400 G20400 PDR ADOCK 03000329
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PDR G
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factual assertions made by Consumers regarding the testimony clicited at the hearing below and upon which the Licensing Board made no specific finding.
3.
Dow respectfully requests an extension of time to April 30, 1982 in which to prepare and file a brief in reply to the Brief filed by Consumers Power Company.
4.
Dow has consented to requests for extensions of time sought by other parties in this proceeding and respectfully submits that a two-week extension of time within which to file its reply brief will not materially delay the proceedings before this Appeal Board.
Dow also believes that its reply brief will be an essential ingredient to a full explication of the issues involved in the proceeding before this Board.
Dow has not previously sought any extension of time from either the Li-censing Board or this Appeal Board within which to take any necessary action.
WIIEREFO RE, The Dow Chemical Company respectfully prays that the Board enter an order extending the time within which The Dow Chemical Company may file a reply brief to the Brief filed by Consumers Power Company to April 30, 1982.
DATED: April 1982 Respectfully submitted, T.
J. Cresswell, Esq.
Division Counsel Michigan Division The Dow Chemical Company 47 Building Midland, Michigan 48640 (517) 636-4781 Fischer, Franklin, Ford, Simon
& IIogg A
By:
%L e
/
William C.
Potter, Jr.
/
1700 Guardian Building
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Detroit, Michigan 48226 (313) 962-5210
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/
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Attorneys representing
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The Dow Chemical Company
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t -
'37~
"N 17~ DI O9 CERTIFICATE OF SERVICE
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I hereby certify that true copies of the foregoing; Motion were served upon each of the following persons by first class mail, postage fully prepaid:
Christine N.
Kohl, Chairman Atomic Safety and Licensing Appeal Board U.
S. Nuclear Regulatory Commission Washington, D.
C.
20555 Gary J.
Edles, Esq.
Atomic Safety and Licensing Appeal Board U.
S. Nuclear Regulatory Commission Washington, D.
C.
20555 Dr.
W.
Reed Johnson Atomic Safety and Licensing Appeal Board U.
S. Nuclear Regulatory Commission Washington, D.
C.
20555 Docketing and Service Section Office of the Secretary U.
S. Nuclear Regulatory Commission Washington, D.
C.
20555 Gerald Charnoff, Esq.
Shaw, Pittman, Potts & Trowbridge 1800 M Street, N.W.
Washington, D.C.
20036 William J. Olmstead, Esq.
Staff Attorney U.
S. Nuclear Regulatory Commission Washington, D.
C.
20555 Myron M. Cherry, Esq.
One IRB Plaza, Suite 4501 Chicago, Illinois 60611 A
./
ob WILLIAM C.
POTTER, JR.
/
DATED: April f,1982
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