ML20054K486
| ML20054K486 | |
| Person / Time | |
|---|---|
| Site: | Midland |
| Issue date: | 07/01/1982 |
| From: | Sinclair M SINCLAIR, M.P. |
| To: | Atomic Safety and Licensing Board Panel |
| References | |
| NUDOCS 8207020247 | |
| Download: ML20054K486 (2) | |
Text
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UNITED STATES OF AMERICA
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, _2 NUCLEAR REGULATORY COMMISSION 0
Before the Atomic Safety and Licensing Board
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- r In the Matter of:
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Docket Nos. 50-329 g
CONSUMERS POWER COMPANY
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50-330 e
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(Midland Plant, Units 1 and 2
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Operating License i
M. SINCLAIR'S RESPONSE TO BOARD'S REQUEST h
FOR REASONS FOR LATE FILING OF NEW CONTENTIONS E
According to the Board's Order that resulted from the telephone conference on June 25, 1982, I am providing reasons for good cause for filing my new con-i tentions late, f
I am complying under protest because this is a needlessly burdensome Order since it is clear from my contentions that these matters concern new and signifi-cant information developed since the original contentions were filed on October 28, f
1978 Contentions 1 and 2 deal with recent decisions of the U.S. Court of Appeals, g
3 April 27,1982, and May 14, 1982, respectively.
T Contention 3 is based on information reported in Science April 9,1982 Contention 4 refers to testimony provided in August,1981.
j.k Contention 5 refers to licensing recommendations by Dr. S. Hanauer after 3
the TMI-2 accident and not covered by Midland SER (NUREG-0703) May,1982 d
Contention 6 has been identified as a problem since TMI-2 accident of March 28, 1979.
Contention 7 refers to erroneous data base for cooling pond as provided in 3
Midland DEIS issued March,1982 Contention 8 refers to deficiency in Midland SER (NUREG-0793), of May,1982.
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FR Contention 9 refers to new information since TMI;2, March 28,1979.
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55-Cor.tention 10 refers to information in Midland SER (NUREG-0793) of May,
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Contentica 11 refers to disclosures made in connection with licensing of the iTin2 hazardous waste dump in July,1981.
fit Contention 12 refers to information disclosed during hearings as described
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in Contention 11 and failure of NRC Staff and Applicant to deal with it in Midland SER (NUREG-0793) of May,1982.
I also wish to give notice at this time that I will file further new contentions dp based on the disclosures of the June 21, 1982 meeting between Consumers Power ti ti Co. staff and Region III staff as well as the extensive documentation of quality g=-
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control and safety problems which have been disclosed by workers at the Midland s
!T nuclear plant to the Government Accountability Project.
p Respectfully submitted,
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ah Mary Sinel r
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cc: Charles Bechhoefer, Esq.
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Mr Ralph S. Decker
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Dr. Frederick P. Cowan
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Jerry Harbour, Esq.
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Secretary, U.S. Nuclear Regulatory Commission Michael I. Miller, Esq., Ronald G Zamarin, Esq., Alan S. Farnell, Esq.
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r Mr. Wendell Marshall Ms. Barbara Stamiris William Paton, Esq.
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