ML20063G678

Reply to First Set of Interrogatories.Certificate of Svc Encl

ML20063G678
Person / Time
Site:	Midland
Issue date:	07/28/1982
From:	Marshall W MARSHALL, W.H.
To:	CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.)
References
NUDOCS 8207290182
Download: ML20063G678 (4)

Text

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. s" y't-United States of America Nuclear Regulatory Commission ...L.

3 n3dv I -- -r -r $5 In ,the Matter of: I DocZ No's;~:$0-329 CONSUMERS POWER COMPANY, ""'50-330 f

(Midland Plant, Units 1 and 2) Operating Licensing Wendell-H. Marshall's reply to first set of Interrogatories from Consumer's Power Company.

a. There was an extensive hearing concerning bad quality control,

b. I wish to state and place you on notice that I waive no rights of any kind or nature whatsoever. I also wish to place you on notice

' that I intend to cross examine and recross an'y and all witnesses, experts or otherwise, produced to testify regardless of who they are testifying for or against on any future hearings of the matter.

While at this time I am unaware that I will produce witnesses to re-butt testimony given in the hearings I do not waive any rights to do so. When I know persons to be produced as witnesses upon behalf of myself and the Mapleton Intervenors I will place all interested.

I parties on notice and produce the names and describe their qualifica-tions as well as their expertise. At this time, I do not foreclose but keep my options open in this regard. At the same time I will assure you of proper time and hotice that you should have to plead

" surprise" outline as to the subjects they would address.

I intend to proceed and participate in future remedia1 ' soils hearings and further, like the fly on the bulldog's nose, great importance and significance is attached to the presently sinking Generator Building which is a safety-related building. I intend to participate to the fullest extent and bring about 'any and all types of inquisition that would offer a contribution to assist the deliberation of the A.S.L.B. Board to arrive at a proper determination in the disposition of this problem which threatens public health and safety to the citi-zenry in a 50-mile circumference from the vortex.

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Moreoever, I wish to-reaffirm cur inter et in th9 fciluro cf the applicants provision of Cooling Towers and, moreover, we wish to re-state and confirm the applicants contention as stated under oath by Mr. Cook of CensNrs Power Ccspany personnel to the effect "that the prime contractor, hetal Conpany, furnished the bodies" and that the Bectal' Companyaupplied all of the construction know-how, and that, unlike Caesar's wife, they can do some wrong and that we stand $ greed and that all of Ingersol Township, Midland Co., MI, as a matter of official record, stands' agreed.

I have prepared these answers and this paper myself.

Signed, A

M ndell H. Marshall /

Pro Se i

certificate Moreoever that all members of the attached list have been furnished .

copies by being deposited personally by myself in the U.S. Mail, j

properly addressed and with sufficient postage.

I Wendell H. Marshall i f I

i i

ATTACHED JURAT , .

In and before me, a notary public of Midland County, Michigan, appeared Wendell H. Marshall; and in my presence affixed his signature to -

the foregoing certificate.

~ dhL (7.w O HollgA. Franko l

1 My conunission expires January 10, 1984.

I

_ SERVICE LIST Frank J. Kelley, Esq. William D. Paton, Esq.

Attorney General of the Counsel for the NRC Staff State of Michigan U. S. Nuclear Regulatory Comm.

Lansing, MI 48913 Washington, D.C. 20555 Charles Bechhoeffer, Esq.

Atomic Safety & Licensing Atomic Safety & Licensing Board Panel Board Panel U. S. Nuclear Regulatory Comm. U. S. Nuclear Regulatory Comm.

Washington, D.C. 20555 Washington, D. C. 20555 Dr. Frederick P. Cowan Barbara Stamiris 6152 N. Verde Trail 5795 North River Road Apt. B-125 Route 3 Boca Raton, FL 33433 Freeland, MI 48623 Admin. Judge Ralph S. Decker Jerry Harbour Route No. 4, Box 190D Atomic Safety & Licensing Cambridge, Maryland 21613 Board Panel U. S. Nuclear Regulatory Comm.

Carroll E. Mahaney Washington, D.C. 20555 Babcock & Wilcox P.O. Box 1260 Mr. Philip Steptoe, Esq.

Lynchburg, VA 24505 Isham, Lincoln & Beale Three First National Plaza James E. Brunner,. Esq. Suite 5200 Consumers Power Company Chicago, IL 60602 212 West Michigan Avenue Jackson, Michigan 49201 Steve J. Gadler, P.E.

2120 Carter Avenue St. Paul, MN 55108 Atomic Safety & Licensing Appela Panel ,

U. S. Nuclear Regulatory Comm.

, Washington, D.C. 20555 l

Mr. C. R. Stephens Chief, Docketing & Services U. S. Nuclear Regulatory Comm.

Office of the Secretary

• Washington, D.C. 20555 -

Ms. Mary Sinclair -

5711 Summerset Street Midland, MI 48640

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00'; .~f i l jyt .1 o.. a..e I have seen most of the world and have been in its high- '

est mountains. I have walked the valleys of all the conti-nents and seen their wonders. Now and then I have come across a sanctuary equal to our liest. But when a full ac-counting is made there is no continent on earth egaal in natural wonders and glories to what we have here.

We must learn to love it and cherish it. We must put our arms around it and protect it as we would a fragile but precious child. Technology can destroy it. But it can also save it. Only we the people, not technology, have

" values " Love respect, admiration, tenderness-these must be our attitude toward this biosphere ifit is not to meet the technological Armaggedon.

-Justice William O. Douglas The New York Times July I,1973, t 4, p.13 4

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