ML20052B481
| ML20052B481 | |
| Person / Time | |
|---|---|
| Site: | Midland |
| Issue date: | 04/28/1982 |
| From: | Charnoff G CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.), SHAW, PITTMAN, POTTS & TROWBRIDGE |
| To: | NRC ATOMIC SAFETY & LICENSING APPEAL PANEL (ASLAP) |
| References | |
| ISSUANCES-CP, NUDOCS 8204300478 | |
| Download: ML20052B481 (2) | |
Text
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HECEIVED UNITED STATES OF AMERICA 23 APR291982% -t a arm um ewer:
NUCLEAR REGULATORY COMMISSION uam curam
.gg M 29 no 3 e
cy
_ 4t he Atomic Safety and Licensing Appeal Board n' \\
g In the Matter of
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)
Docket Nos. 50-329 CP CONSUMERS POWER COMPANY
)
50-330 CP
)
(Remand Proceeding)
(Midland Plant, Units 1 and 2)
)
CONSUMERS POWER COMPANY'S ANSWER TO THE MOTION BY SAGINAW VALLEY NUCLEAR STUDY GROUP TO TERMINATE ORAL ARGUMENT By Motion served on April 22, 1982, the Saginaw Valley Nuclear Study Group requested the Appeal Board to cancel the oral argument in this matter, now set for May 13, 1982.
Consumers Power Company has no reason to request oral argument in this proceeding.
Its position with respect to the factual and legal issues has been made clear in its brief filed in opposition to Intervenor's Exceptions dated April 5, 1982.
Nevertheless, Consumers recognizes that the underlying facts in this proceeding are not simple and, therefore, to the extent that the Appeal Board believes that it would be helpful to its understanding of the facts and the issues in this case to have oral argument, we would be pleased to be present and to participate.
Respectfully submitted, SHAW, PITTMAN, POTTS & TROWBRIDGE O
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Gera'l'd 'Charno f f, P. C [//
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Counsel for ConsumerhYPower Company 1800 M Street, N.
W.
N gp Washington, D.
C.
20036 820430097/
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION Before the Atomic Safety and Licensing Appeal Board In the Matter of
)
)
DQcket Nos. 50-329 CP CONSUMERS POWER COMPANY
)
50-330 CP
)
(Remand Proceeding)
(Midland Plant, Units 1 and 2)
)
CERTIFICATE OF SERVICE I hereby certify that copies-of " Consumers Power Company's l
Answer to the Motion by Saginaw Valley Nuclear Study Group to Terminate Oral Argument" were served this 28th day of April, 1982, by U.
S. mail, first class, postage prepaid, upon the following:
1 Christine N.
Kohl, Esquire William C. Potter, Jr., Esquire Chairman Fischer, Franklin, Ford, Atomic Safety and Licensing Simon & Hogg Appeal Board 1700 Guardian Building U.
S. Nuclear Regulatory Commission Detroit, Michigan 48226 Washington, D.
C.
20555 R.
L.
Davis, Esquire Gary J.
Edles, Esquire Michigan Div'ision Legal Atomic Safety and Licensing Department Appeal Board Panel Dow Chemical U.
S.
Nuclear Regulatory Commission Midland, Michigan 48640 Washington, D.
C.
20555 William J.
Olmstead, Esquire Dr. W.
Reed Johnson William D.
Paton, Esquire Atomic Safety and Licensing Appeal Office of the Executive Board Panel Legal Director U.
S.
Nuclear Regulatory Commission U.
S. Nuclear Regulatory Commission Washington, D.
C.
20555 Washington, D.
C.
20555 Docketing and Service Section Myron M. Cherry, Esquire Office of the Secretary Suite 4501 U.
S.
Nuclear Regulatory Commission One IBM Plaza Washington, D.
C.
20555 Chicago, Illinois 60611 O
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/
~
Gerald Charnoff
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