ML19309C116
| ML19309C116 | |
| Person / Time | |
|---|---|
| Site: | Big Rock Point File:Consumers Energy icon.png |
| Issue date: | 03/14/1980 |
| From: | Gallo J CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.), ISHAM, LINCOLN & BEALE |
| To: | Oneill J AFFILIATION NOT ASSIGNED |
| Shared Package | |
| ML19309C110 | List: |
| References | |
| NUDOCS 8004080186 | |
| Download: ML19309C116 (6) | |
Text
3/14/80 O
UNITED STATES 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 Power Plant))
LICENSEE' S FIRST SET OF INTERROGATORIES TO JOHN O'NEILL, II Pursuant to 10 C.F.R.
S 2.740b, Consumers Power Company
(" Licensee") requests that Intervenor John O'Neill, II answer each of the following interrogatories separately and fully, in writing, and under oath or affirmation, in accord-ance with the Definitions and Instructions provided herein.
Interrogatories 1.
Identify all documents including any Licensee Event Reports which serve as the bases for the contentions filed by John O'Neill in this proceeding and accepted by the Atomic Safety and Licensing Board in its " Order Following Special Prehearing Conference" dated January 17, 1980.
2.
With regard to each contention and Board Question that has been accepted by Atomic Safety and Licensing Board in its " Order Following Special Prehearing Conference" dated January 17, 1980:
(a)
Identify each person whom John O'Neill expects to call as a witness with respect to each and every such con-tention or Board question; 80e4080 pJrs
(b)
State the subject matter on which the witness is expected to testify; (c)
State the substance of the facts and opinions to which any witness is expected to testify and summarize the grounds for each opinion; (d)
Identify all documents relied upon or examined by any witness in answering subparagraph (c) above; (e)
Identify all documents not identified in sub-paragraph (d) above which the witness expects to put into evidence or to rely upon in support of his or her testimony in this proceeding.
3.
Answer Interrogatory 2 above with respect to each contention identified as being withdrawn subject to reassertion in the Atomic Safety and Licensing Board's " Order Following Special Prehearing Conference" dated January 17, 1980.
Definitions and Instructions Unless otherwise indicated, the following definitions shall apply to these Interrogatories:
1.
" John O'Neill" shall include all agents, employees, attorneys, investigators and all other persons directly or indirectly subject to his control in any way.
2.
The words " Person" or " Persons" shall mean, without limitation, all entities including all predecessors in interest, individuals, associations, companies, partner-ships, joint ventures, corporations, subsidiaries, departments, bureaus, public agencies and boards.
i
3.
" Documents" shall mean all written or recorded material of any kind or character known to John O'Neill or in his possession, custody or control, including, without limitation, letters, correspondences, telegrams, memorandums, notes, records, minutes, contracts, agreements, records or notations of telephone or personal conversations or conferences, inter-office communications, microfilm, bulletins, circulars, pamphlets, studies, notices, summaries, reports, books, articles, treatises, teletype messages, invoices, tape recordings and worksheets.
4.
When used with respect to a document " Identify" means, without limitation, to state its date, the type of document (e.g.,
letter, memorandum, telegram, chart, photo-graph, sound reproduction, etc.), the author and addressee, the present location and the custodian, and a description of its contents.
1 5.
When used with respect to a person, " Identify" means without limitation, to state his or her name, address, occupation, and professional qualifications.
6.
As used herein, the terms "and" as well as
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"or" shall be construed either disjunctively or conjunctively l
as necessary to bring within the scope of these Interrogatories any information which might otherwise be construed to be out-side its scope.
7.
If any of the information contained in the answers to any of these Interrogatories is not within the
personal knowledge of the person signing the response to that Interrogatory, so state and ide'ntify each person, docu-ment, and communication on which he relies for the informa-tion contained in answers not based solely on his personal knowledge.
8.
If John O'Neill cannot answer any portion of any of the foregoing Interrogatories in full, after exercising diligence to secure the information to do so, so state, and answer to the extent possible, specifying the inability to answer the remainder and stating when John O'Neill expects to be able to answer the unanswered portions.
9.
These Interrogatories are continuing Inter-rogatories and require supplemental answers if John O'Neill obtains further information between the time the answers are served and the time of an initial decision in the proceeding.
Q-d
$$o g d6seph Gallo p
One of the Attorneys for Licensee j
i Isham, Lincoln & Beale
.1120 Connecticut Avenue, N.W.
Suite 325 Washington, D.C.
20036
'202/833-9730 Dated:
March 14, 1980 i
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UNITED STATES 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 Power Plant))
CERTIFICATE OF SERVICE I hereby certify that copies of the following:
LICENSEE'S FIRST SET OF INTERROGATORIES TO JOHN O'NEILL, II in the above-captioned proceeding was served upon the follow-ing persons by depositing copies thereof in the United States mail, first class postage prepaid, this 14th day of March, 1980.
Herbert Grossman, Esq.
Janice E.
Moore, Esq.
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 John A.
Leithauser i
Dr. Oscar H.
Paris Energy Resources Group Atomic Safety and Licensing General Delivery Board Panel Levering, Michigan 49755 U.S. Nuclear Regulatory Commission John O'Neill, II Washington, D.C.
20555 Route 2, Box 44 Maple City, Michigan 49664 Mr. Frederick J.
Shon Atomic Safety and Licensing Christa-Maria Board Panel Route 2, Box 108C U.S. Nuclear Regulatory Charlevoix, Michigan 49720 Commission Washington, D.C.
20555
Barbara J.
Godwin Mrs. W. W.
Schaefer, Chairman 306 Clinton Radioactive Waste Management Charlevoix, Michigan 49720 Study Committee Lake Michigan Foundation Ms. Marcy Brown c/o 3741 Koehler Drive 401 Alice Street Sheboygan, Wisconsin 53081 Charlevoix, Michigan 49720 Ms. JoAnne Bier Atomic Safety and Licening 204 Clinton Appeal Board Panel Charlevoix, Michigan 49720 U.S. Nuclear Regulatory Commission Mr. Bruce Janssen Washington, D.C.
20555 Box 1889 Lake Shore Drive Atomic Safety and Licensing Boyne City, Michigan 49712 Board Panel U.S. Nuclear Regulatory Karin P.
Sheldon, Esq.
Commission William S. Jordan, III Washington, D.C.
20555 Sheldon, Harmon & Weiss 1725 I Street, N.W.
Docketing and Service Section Suite 506 Office of the Secretary Washington, D.C.
20006 U.S. Nuclear Regulatory Commission Washington, D.C.
20555 Judd L. Bacon, Esq.
Consumers Power Company 212 West Michigan Avenue Jackson, Michigan 49201 lbo
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1 Jo pyn gdllo O W of the Attorneys for Consumers Power Company s
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