ML19347A632

Requests Permission to File Suppl Response to ASLB 770513 Proposed Findings of Fact & Conclusions of Law.Aslb Should Consider Encl Document in Decisionmaking

ML19347A632
Person / Time
Site:	Midland
Issue date:	07/11/1977
From:	Cherry M CHERRY, M.M./CHERRY, FLYNN & KANTER
To:	Coufal F, Leeds J, Luebke E Atomic Safety and Licensing Board Panel
Shared Package
ML19347A633	List: ML19347A632 ML19347A634
References
NUDOCS 8007300706
Download: ML19347A632 (1)

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%l c mJuly 11, 1977

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Dr.~Ecceth A. Luebke. Dr. J. Venn Leeds

• Atomic Safety and Licensing Board Atomic Safety and Licensing Board U.S. Nuclear. Regulatory Commission U.S. Nuclear Regulatory Commission Washington. D. C. 20555 Washington, D. C. 20555 Frederic J. Coufal, Esq., Chairman

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Atomic Safety and Licensing Board U.S . -Nuclear Regulatory Commission Washington, D. C. 20555 Re: Censumers Power Com any

Dear Chaircan Coufal and Drs. Leeds and Luebke:

We received the Legulatory Staff's Proposed Findings to the Board and were incredibly disillusioned by that document.

The docueent distorts the record, seeks to have the Board make findings' contrary to rulings already made , fails to set forth any support for many ofits statetents and regurgitates whole- '

hog positions of Consumers ' and Staff witnesses which were des troyed (or at the least neutralized) by cross-exacination by Intervenors as well as the Board. Equally so , the Staff Findings are based upon an erroneous view of the law. -

vinally, when one looks at the admissions which the Staff cakes in its Findings, it is abundantly clear that, not-withstanding the Staff's " desire" to help cut Consumers , it cannot.do so. ,

We are mindful that the Board has been besieged by a raft of paperwork; but we would be remiss in our duties if we did not file thezshort document attached which speaks to the ramoant~ crrors of fact and breaches of responsibility made t by-the 5taff in its Findings.

Therefore; _we seek formal parmission to file the

' attached docucent and request that the Board consider it in

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eepectfully, j

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