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Third Round of Interrogatories Propounded to Nrc.Requests Info Re Items of Noncompliance,Imposition of Civil Penalties & Regulatory Authority.Certificate of Svc Encl
	ML18046A180
Person / Time
Site:	Palisades
Issue date:	11/18/1980
From:	Bielawski A; CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.)
To:	; NRC OFFICE OF THE EXECUTIVE LEGAL DIRECTOR (OELD)
References
	NUDOCS 8011250628
	Download: ML18046A180 (5)
	v • d • e

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            ,1, 'If' e          Nov       IS'/ 19      s--o UNITED STA'J. -:.'::-; OF AMERICA NUCLL~:'\R  REGUJ~_'\TORY COKMISSION BEFORE THE ADMINIS'rRli.TIVE LAW JUL:GE In the     ~atter    Of:

r;*, (J"J CONSUMERS POWER COMPANY Docket No. 50-255 :::~ i~:*< (?alisades Nuclear Power License No.. DPR-2 0 < ;:t;-r.,~

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                                                                                                                               --1 THIRD ROUND OF INTERROGATORIES TO BE ANSWERED ~                                             0 z:

BY THE NUCLEAR REGULATORY COMMISSION ~ Consumers Power Compa_ny ("CPCo") hereby resuests

                     ':.he Nuclear Reg:_:latory              Cornmi~3sion       ("NRC"),   er the appropriate
                     ~RC   personnel,         to answer separately and fully in                  writi~g, u 1der oc::th or 1
                                          ~1. :=: f irrna ti on,  ec ch of the followins:; Interroga '.::o:c* -~,.:_~c::

within 30 days of service. INSTRUCTIONS A~D DEFINITIONS Consumers incorporates by reference the instruct~~ns and definitions contained in "C~onsurner Power Company 1 s First Round of Interrogatories and Request for the Production of Documents by the Nuclear ReguL.ttory Commission", datcc~ Februar~* 21, 1980, as the ins~cuctions and definitio~s applicnble to the interr-:icjatoric~s set fc 1 :_ '_ h belov...

INTERROGATORIES

1. Identify each instance where the Director of Inspection and Enforcement (IE) determined that an NRC licensee committed an item of noncompliance, where the noncomplying condition continued for more than one day.

2. For each instanc~ identified in response to Interrogatory l above, state whether the Director of IE pro-

. posed the imposition of a civil penalty.

3. For each instance identified in response to Interrogatory 2 above, state whether the Director of IE pro-posed the imposition of a civil penalty for each day of non-compliance.

4. Identify each instance where the Director of IE proposed the imposition of a civil penalty for each day of a noncomplying condition whic~ continued for more than one day.

5. For each ~nstance identified irt response to Interrogatory 3 or 4 above, state the basis upon which the Di~ector proposed civil penalties for each day of the continuing noncompliance.

6. If the seriousness of the noncompliance was used, in whole or in part, as ~he basis for proposing civil penalties for each day of the continuing noncompliance iden-tified in response to Interrogatory 5( identify the factors or criteria considered by the Director in classifying the continuing noncompliance as serious in nature.

7. Identify the specific statutory and/or regulatory authority which confers the Director with the discretion to impose civil penalties for each day of a noncomplying con-dition on the basis that the Director has determined that the noncompliance is serious in nature.

8. Provide an explanation as to how the authority cited in response to Interrogatory 7 confers the Director with the discretion to impose civil penalties f6r continuing noncompliances which the Director determines are serious in nature.

DATED: November 18, 1980.

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                                 " *.Alan P. '-BJ.elawskl'-

one of the Attorneys for Consumers PoweT Company Michael I. Miller Paul M. Murphy ISHAM, LINCOLN & BEALE One First National Plaza Suite 4200 Chicago, Illinois 60603 (312) 558-7500 UNITED STATES OF AMERICA NUCLEAR REGUL.:,TORY COMMISSION BEFORE THE ADMINISTRATIVE LAW JUDG.E In the Matter Of: CONSUMERS POWER COMPANY Docket No. 50-255 (Palisades Nuclear Power License No. DPR~20 Facility) CERTIFICATE OF SERVICE I, Alan P. Bielawski,_ one of the attorneys for Consumers Power Company, certify that copies of "Consumers Powex Company's Third Round of Interrogatories To Be Answered By The Nuclear Regulatory Co:mmission" have been serveo in the above-captioned matter on the following by depositing same in United States mail~ postage prepaid, this 18th d~y of November, 1980: Honorable Ivan W. Smith Administrative Law Judge Atomic Safety and Licensing Board U.S. Nuclear Regulatory Commission Washington, D.C. 20555 James P. Murray, Esq. Director and Chief Counsel Rulemaking and Enforcement Division Office of the Executive Legal Director U.S. Nuclear Regulatory Commission Washington, D.C. 20555 James Lieberman,. Esq. U.S. Nuclear Regulatory Commission Office of the Executive ~egal Director Washington, D.C. 20555 Stephen G. Burns, Esq. U.S. Nuclear Regulatory Commission Of £ice of Executive Legal Director Washington; D.C. 2055 . S

Docketing and *service Section Off ice of the Secretary U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Atomic Safety and Licensing Appeal Board Panel U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Judd L. Bacon, Esq. Consumers Power Company 212 West Michigan Avenue Jackson, Michigan 49201 D.7.\TED: November 18, 1980. "/ I

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ML18046A180

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