ML19305E812
| ML19305E812 | |
| Person / Time | |
|---|---|
| Site: | Big Rock Point File:Consumers Energy icon.png |
| Issue date: | 04/11/1980 |
| From: | Jordan W BIER, MILLS, CHRISTA-MARIA, ET AL, SHELDON, HARMON & WEISS |
| To: | CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.) |
| References | |
| NUDOCS 8005200467 | |
| Download: ML19305E812 (6) | |
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APR 14sS0 7 UNITED STATES OF AMERICA
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NUCLEAR REGULATORY COMMISSION ct, c BEFORE THE ATOMIC SAFETY AND LICENSING BOARD c3 6
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In the Matter of
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Docket No. 50-155 CONSUMERS POWER COMPANY
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(Spent Fuel Pool Expansion) i (Big Rock Point Nuclear
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1 Power Plant)
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RESPONSE TO LICENSEE'S FIRST SET OF INTERROGATORIES Christa-Maria, et al., (referred to as Christa-Maria) hereby respond to Licensee's First Set of Interrogatories.
Affidavits in support of these answers will be supplied shortly.
Interrogatory 1 Licensee's first interrogatory calls for the identifi-cation of all persons whom Christa-Maria expects to call as expert witnesses in this proceeding, and it requests certain information concerning those witnesses.
At this time, due to a lack of funds to compensate experts, Christa-Maria does i
not expect to call any specific expert witnesses.
- However, Christa-Maria is attempting to find experts who will be able to testify and will respond further to this interrogatory if she is successful.
Interrogatory 2 The answer to Interrogatory 1 app.ies equally to Interrogatory 2.
1
Interrogatory 3 Licensee's third interrogatory requests certain informa-
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tion concerning each of the contentions an'd Board Questions admitted in this proceeding.
Christa-Maria has not yet identified witnesses with respect to contentions or Board Questions other than Contentions 8 and 9.
The responses for those two contentions follow:
Contention 8 (a) Persons with knowledge of the facts whom Christa-Maria expects to call as witnesses:
1.
JoAnne Bier 204 Clinton Street Charlevoix, Michigan 49720 Occupation:
Social Worker 2.
Shirley J. Johns Rt. 1, Box 88 Ellsworth, Michigan 49729 Occupation:
Carpenter (b) Substance of testimony and documents relied j
upon:
1.
JoAnne Bier expects to testify that the*
occurrence of a TMI-2 type accident would render it impossible to maintain the expanded spent fuel pool, thereby creating an unaccept-able risk to the public health and safety if increased fuel storage is permitted. As of the date of this response, she expects to rely upon or introduce the following documents:
-1
. a. Licensee-NRC (AEC) correspondence 1963 to date.
- b. Licensee Event Reports, 1963 to date.
', Requirements Resulting From Review of TMI-2 Accident:
Criteria to Be Used for Implementation, October 30, 1979..
- d. Requirements Resulting from Review of TMI-2 Accident:
Action to Be Taken In Response - Transmittal of Updated Pages, January 18, 1980.
- e. Short-Term Lessons Learned from TMI-2 Accident:
Additional Information Requested From NRC During Site Visit, March 14, 1980.
2.
Shirley J. Johns expects to testify to the same effect as Ms. Bier and to rely upon the same documents.
Contention __9 (nj Persons with knowledge of the facts whom Christa-Maria expects to call as witnesses; 1.
JoAnne Bier 2.
Shirley J.
Johns 3.
Christa-Maria Box 108C Charlevoix, Michigan 49720 Occupation:
Artist, Waitress i
(b) Substance of testimony and documents relied l
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upon:
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All three witnesses will testify to the effect tha*: it is not possible to evacuate the
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area surrounding the Big Rock plant quickly and kb safely in the event of an accident.
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- c, 2.
As of the date of this response, these wit-
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nesses expect to rely upon or introduce the following documents:
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- a. Three Mile Island, Volume I, A Report I.,
to the Commissioners and to the Public, 9.
January 1980.
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- b. Unacceptable Risk, by McKinley'C. Olson, fl x
1976, 1979.
- c. Nuclear Power:
The Unviable Option, by G
John J. Berger, October 1977, May 1979.
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- d. Short-Term Lessons Learned from TMI-2 y;.
c.
Accident:
Additional Information lff i
hk Requested From the NRC During Site Visit, E,
k)l hl March 14, 1980.
Wl Subparts (a) and (b) of Interrogatory 3 request information
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gl' about all persons consulted by Christa-Maria concerning the d
Nt facts and issues of this proceeding.
Christa-Maria objects to
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ki these requests as intrusions on Christa-Maria's preparation Fjf,
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,..i for litigation, which is protected from discovery.
Interrogatory 4 t-bil Christa-Maria has not yet identified. witnesses that she Idi W, !
expects to call with respect to the c ntentions identified in g
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, this interrogatory.
Christa-Maria objects to questions con-cerning persons with whom she has consulted for the reasons stated in response to Interrogatory 3.
Interrogatory 5 Christa-Maria has not yet identified any documents that would be the subject of this interrogatory.
Respectfully submitted, fN William s'. Jordan, III Counsel for Christa-Maria Sheldon, Harmon & Weiss 1725 I Street, N.W.
Suite 506 Washington, D.C.
20006 DATED: % //-p
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UNITED ST'TES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD
)
In the Matter of
)
)
CONSUMERS POWER COMPANY
)
Docket No. 50-155
)
(Big Rock Point Nuclear
)
i Power Station)
)
)
CERTIFICATE OF SERVICE I hereby certify that copies of "Christa-Maria, et al.,
Response to Licensee's first set of Interrogatories,$'were mailed postage pre-paid this lith day of April, 1980, to the following:
Herbert Grossman, Esq.
Janice E. Moore, Esquire Atomic Safety and Licensing Counsel for NRC Staff Board Panel U.S Nuclear Regulatory U.S. Nuclear Regulatory Commission Commission Washington, D.C.
20555 Washington, D.C.
20555 Dr. Oscar H. Paris Joseph Gallo, Esquire Atomic Safety and Licensing Isham, Lincoln & Beale Board Panel 1050 17th Street, N.W.
U.S. Nuclear Regulatory Commission Suite 701 Washington, D.C.
20555 Washir.gton, D.C.
20036 Mr. Frederic J.
Shon John O'Neill, II Atomic Safety and Licensing Route 2, Box 44 Board Panel Maple City, Michigan 49664 U.S. Nuclear Regulatory Commission Washington, D.C.
20555 Docketing and Service Section (2)
U.S Nuclear Regulatory Commission washington, D.C.
20555 l
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William S.cdordan, III, Esquire i
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.