ML19274D713

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Consumer Power Co'S Motion for Extension of Time Until 790330 to Submit Info Re Disclosure Due to Recent Retention of Counsel.Certificate of Svc Encl
ML19274D713
Person / Time
Site: Midland
Issue date: 02/05/1979
From: Charnoff G, Reynolds W
SHAW, PITTMAN, POTTS & TROWBRIDGE
To:
References
NUDOCS 7902220222
Download: ML19274D713 (3)


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' :0.\f UUITED STATES OF AMERICA NUCLEAR REGULATORY COf1 MISSION Before the Atomic Safety and Licensing Board In the Matter of )

) Docket Nos. 50-329CP CONSUMERS POWER COMPANY ) 50-330 (Midland Plant, Units 1 and 2) ) (Remand Proceeding)

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MOTION FOR EXTENSION OF TIME On January 4, 1979, the Atomic Safety and Licensing Board in the above proceeding ordered the parties to provide the Licensing Board with certain information relevant to the remanded disclosure issue. Following receipt of this order, Consumers Power Company (" Consumers") retained the undersigned attorneys to assist Consumers in the evidentiary hearing to be held on this matter.

Counsel has already begun review of prior record materials in an effort to familiarize themselves with the dis-closure issue as expeditiously as possible. It is clear, how-ever, that, due in part to the press of other matters which require immediate attention and in part to the preparation effort required here, additional time will be needed in order to respond in a meaningful and comprehensive manner to the four items set forth in the Licensing Board's order. Accordingly, the present motion is being made for an extension of the filing date for submitting the requested information to and including March 30, 1979.

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In view of the fact that the Licensing Board ha's directed simultaneous filings, we would ask that the March 30 date also be made available to the other parties hereto.

Respectfully submitted,

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f By: , M /

Gerald Charnoff j Nm. Bradford Reynolds F SHAW, PITTMAN, POTTS & TRCWBRIDGE 1800 M Street, N.W.

Washington, D. C. 20036 Tel.: (202) 331-4100 Counsel for Consumers Power Company Dated: February 5, 1979.

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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION Before the Atomic Safety and Licensing Board In the Matter of ) Docket Nos. 50-329CP

) 50-330 CONSUMERS PCWER COMPANY ) (Remand Proceeding)

(Midland Plant, Units 1 and 2) )

CERTIFICATE OF SERVICE I hereby certify that copies af the foregoing " Motion For Extension Of Time" were served on the following, by deposit in the United States mail, first class postage prepaid, on this 5th day of February, 1979:

Marshall E. Miller, Esq. Mr. C. R. Stephens Chairman Chief, Docketing & Service Secticn Atomic Safety and Licensing Board Office of the Secretary U.S. Nuclear Regulatory Comm. U.S. Nuclear Regulatory Comm.

Washington, D. C. 20555 Washington, D. C. 20555 Dr. J. Venn Leeds, Jr., Esq. Richard Hoefling, Esq.

Atomic Safety and Licensing Board Counsel for NRC Staff 10807 Atwell U.S. Nuclear Regulatory Comm.

Houston, Texas 77096 Washington, D. C. 20555 Dr. E.meth

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A. Luebke Myron M. Cherry, Esq.

Atcmic Safety and Licensing Board One IBM Plaza U.S. Nuclear Regulatory Comm. Suite 4501 Washington, D. C. 20555 Chicago, Illinois 60611 Michael I. Miller, Esq. L. F. Nute, Esq.

Ronald G. Zamarin, Esq. Legal Department Isham, Lincoln & Beale Dow Chemical U.S.A.

One First National Plaza Michigan Division, Bldg. 447 Suite 4200 Midland, Michigan 48640 Chicago, Illinois 60603 Atomic Safety a.M Licensing P. card Panel U.S. Nuclear Regulatory Comm.

Washington, D. C. 20555

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