ML20077N739

Requests Depositions of CM Erb & Je Foster,For Defense in Lawsuit Re Claimed Failures of Structural Support Bolts

ML20077N739
Person / Time
Site:	Midland
Issue date:	09/01/1983
From:	Myers T BRISTOL STEEL & IRON WORKS, INC., GARAN, LUCOW, MILLER, SEWARD, COOPER & BECKER
To:	James Keppler NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
References
NUDOCS 8309130209
Download: ML20077N739 (1)

Text

LAW O FFIC E S OF GrnAx, Lrcow, M LLEn,SEWAND. COOPER N llEcKEN PROFES59ONAL C O R p O e a fiO N 5 61 EAST JEFFERSON AVENUE D ET ItOET, MICII1G A N SUWWG T HoM As F. MYERS (313) 962-5180 September 1st, 1983 PRINCJPAL STAFF i V U A L/ENF 3fRA S_CS &% -f- 3 Mr. James G. Keppler, Director -MA1 PA0 T U.S. Nuclear Regulatory Commission }EUI--

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w; Region III [h'fg RC 4 799 Roosevelt Rd, 9g Glen Ellyn, Illinois 60137 gt  ; ,

Re: Docket No. 50-329, 50-330 Midland Plant, Consumer Power Co, Our File No. 82 1260 9

Dear Mr. Keppler:

The undersigned represents Mississippi Valley Structural Steel Company (Bristol Steel) a co-defendant in a lawsuit brought by Consumer Power 03. and the Bechtel Power Company against my client and others (Southern Bolt Co. and Rex Heat Treating), as a result of claimed failures of structural support bolts for the nuclear reactors at the Midland Nuclear Plant of Consumer Power Company.

It is my understanding that the U.S. Nuclear Regulatory Commission prepared a report, subsequent to the investigation of your investigator and inspector, Mr. J.E. Foster and Mr. C. M, Erb respectively, I also understand there was some support from your Engineering Section II by Mr. D. H. Danielson, I would like to take the depositicn of Mr. Erb and Mr. Foster at a time and place convenient to them and to your office as well as to all counsel in this matter, I would like to review the Nuclear Regulatory Commission's report with them at the time of deposition, Especially their findings, We would appreciate hearing from you or someone from your office regarding the possibility of taking these depositions in the near future and on a mutually agreeable basis.

Thank you, ery truly yours, F309130209 830901 PDR ADOCK 05000 2 fggyg O

TFM/cb T IOMASJYERS [j cc: Ronald F. DeNardis, Esq.

Roger F. Wardle, Esq.

Mr. George Schraut ' g~ I Mr. Norman Cohn .

Mr. Ralph Corrin 6 YO3 se