ML20052B564

Forwards Util Response to B Stamiris Proposed Supplemental Findings of Fact & Conclusions of Law for Partial Decision on QA & Mgt Attitude Issues.Findings Address Evidence at 811215-17,820202 & 19 Hearings

ML20052B564
Person / Time
Site:	Midland
Issue date:	04/26/1982
From:	Fitzgibbon R, Fitzgibbons R CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.), ISHAM, LINCOLN & BEALE
To:	Atomic Safety and Licensing Board Panel
Shared Package
ML20052B565	List: ML20052B564 ML20052B571
References
ISSUANCES-OL, ISSUANCES-OM, NUDOCS 8205030294
Download: ML20052B564 (2)

Text

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ISHAM, LINCOLN & BEALE COUNSELORS AT LAW ,

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C April 26, 1982 i RECEtygg 2- -

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\ M u' M u n n UNITED STATES OF AMERICA W NUCLEAR REGULATORY COMMISSION g C

BEFORE THE ATOMIC SAFETY AND LICENSING BOARD 4

In the Matter of )

) Docket Nos. 50-329-OM CONSUMERS POWER COMPANY ) 50-330-OM

) 50-329-OL (Midland Plant, Units 1 ) 50-330-OL and 2) )

Dear Administrative Judges:

4 We have enclosed Consumers Power Company's Response to Intervenor Barbara Stamiris Proposed Supplemental Findings of Fact and Conclusions of Law for Partial Decision on Quality Assurance and Management Attitude Issues in the above captioned case.

These proposed findings address the quality assurance and management attitude issues raised by the December 6, 1979 Order Modifying Construction Permits and related Contentions of Intervenor Barbara Stamiris. In particular, they involve (1) the National SALP report; (2) the MPQAD modifications; (3) Audit Report F-77-32; and (4)

Quality Control Inspector qualifications. Consumers Power Company, Intervenors Barbara Stamiris, Wendell Marshall and

Mary Sinclair and the Staff of the NRC presented evidence concerning those issues at hearings held in Midland, Michigan on December 15 through 17, 1981, February 2, 1982 and February 19, 1982.

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Although it was not originally designated as one of the issues to be addressed in the Supplemental Findings, Ms. Stamiris also addresses the issue of managerial attitude in her Supplemental Findings. Accordingly, Consumers Power felt it necessary to respond to Ms. Stamiris' additional discussion.

Respectfully, kY .Q -

Robert G.71tzgibbons Jr.

One of the Attorneys for Consumers Power Company

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