ML20052A266
| ML20052A266 | |
| Person / Time | |
|---|---|
| Site: | Midland |
| Issue date: | 04/22/1982 |
| From: | Cherry M CHERRY, M.M./CHERRY, FLYNN & KANTER, SAGINAW VALLEY NUCLEAR STUDY GROUP |
| To: | NRC ATOMIC SAFETY & LICENSING APPEAL PANEL (ASLAP) |
| References | |
| ISSUANCES-CP, NUDOCS 8204280090 | |
| Download: ML20052A266 (3) | |
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Be ore the"Atcmic Safety ard Licensing Appeal Board In the Ibtter of
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CQ;SUMERS PGER COMPANY
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Docket Nos. 50-329 CP
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50-330 CP (Midland Plant, Units 1 and 2)
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SAGINAW VALILY NUCLEAR STUDY GROUP'S ICTIQJ 70 TERMINATE ORAL AME"r The Saginira Valley Nuclear Study Group, by its attorneys, hereby requests the Appeal Board to cancel oral argument in this matter set for May 13, 1982 upon the following grcunds:
1.
Oral argument in this cause is unnecessary. Voluminous briefs have been filed by the parties to this cause, including a brief pennitted to be filed on behalf of the Atomic Industrual Forun, Inc.
as Amicus Curiae.
2.
In addition to the briefs, the record is also available to the Appeal Board and this Intervenor respectfully subnits that the time and expense which counsel and tha Appeal Board will incur in having oral argument in this cause is not warranted.
3.
Ib the extent that the Appeal Board has any questions of counsel, the Appeal Board could direct such questions to counsel which could be answered more efficiently by letter.
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4.
The issue before the' Appeal Board is rel'tively simple a
and involves the legal issue as to whether the Licensing Board erred 997 8 2 0 4 28 oc.cio 9a/
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in not issuing sanctions based upon the findings it trade. All of the available law has been sulmittod to the Appeal Board.
l MEREFORE, the Saginaw Valley Nuclear Study Group subnits that oral argutent is unnecessary and respectfully requests that it be canceled.
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4 Respectfully subnitted, SAGINAW hW h11 CLEAR STUDY GROUP By:
One of Their Attorneys 4
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Myron M. Cherry, p.c.
Peter Flynn, p.c'.
CHERRY & FLYNN Three First National Plaza Suite 3700 Chicago, Illinois 60602 (312) 372-2100 i
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'02 IF. 25 P' PFOOP OF SDNICE i
I certify that a copy of the foregoing bbtion was served upon counsel for Consumers Power Company, Dow Chanical Ompany, The Atanic Industrial Forum, Inc., the Regulatory Staff and the Secretary of the Nuclear Regulatory Ctanission (docketing) by mailing a copy of same, postage prepaid and properly addressed, on April 22, 1982. On the same date an original and three copies of the foregoing Fbtion were served upon the Secretary of the Appeal Board by express mail, postage prepaid and properly addressed.
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