ML19309D362
| ML19309D362 | |
| Person / Time | |
|---|---|
| Site: | Big Rock Point File:Consumers Energy icon.png |
| Issue date: | 03/13/1980 |
| From: | Gallo J, Steptoe P CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.), ISHAM, LINCOLN & BEALE |
| To: | BIER, MILLS, CHRISTA-MARIA, ET AL |
| Shared Package | |
| ML19309D363 | List: |
| References | |
| NUDOCS 8004100293 | |
| Download: ML19309D362 (6) | |
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3/13/80 i
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of
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CONSUMERS POWER COMPANY
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Docket No. 50-155
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(Big Rock Point Nuclear Power Plant))
LICENSEE'S FIRST SET OF INTERROGATORIES TO CHRISTA-MARIA, ET AL.
Pursuant to 10 C.F.R.
S 2.740b, Consumers Power Company
(" Licensee") requests that Intervenor Christa-Maria answer each of the following interrogatories sep-arately and fully, in writing, and under oath or affirma-tion, in accordance with the Definitions and Intructions provided herein.
i Interrogatories 1.
With regard to each contention and Board Question admitted for litigation in this proceeding by the Atomic Safety and Licensing Board in its " ORDER FOLLOWING SPECIAL PREHEARING CONFERENCE" dated January 17, 1980:
(a)
Identify each person whom Christa-Maria expects to call as an expert witness in respect of such contention or Board question; (b)
State the subject matter on which the expert witness is expected to testify; 2_933 S004100
h (c)
State the substance of the facts and opinions to which the expert witness is expected to testify and sum-marize the grounds for each opinion; (d)
Identify all documents relied upon or examined by the expert witness in answering subparagraph (c) above; (e)
Identify all documents not identified in sub-paragraph (d) above which the expert witness expects to put-into evidence or to rely upon in support of his or her testi-many in this proceeding.
2.
Answer Interrogatory 1 above with respect to each contention identified as being withdrawn subject to reassertion in the Atomic Safety and Licensing Board's " ORDER FOLLOWING SPECIAL PREllEARING CONFERENCE" dated January 17, 1980.
3.
With respect to'each contention and Board Question admitted in litigation in this proceeding:
(a) Identify any person having knowledge of the facts relating to such contention or Board Question (other than the expert witnesses identified in response to Inter-rogatory 1).
This question is limited to those persons whom Christa-Maria expects to call as witnesses other than expert witnesses in this proceeding, or with whom Christa-Maria has consulted or expects to consult in connection with this proceeding.
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(b)
For each person who has been consulted, state when he or she was consulted and summarize the substance of any facts or opinions communicated by such person to Christa-Maria relating to the subject matter of any contention or Board Question.
(c)
If Christa-Maria expects to call any person identified in response to Interrogatory 3(a) above to testify, state the substance of his or her testimony, summarize the basis for any opinions continued in such testimony, and
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identify all documents which will be introduced as evidence or relied upon by such person in support of such testimony.
4.
Answer Interrogatory 3 above with respect to each contention identified as being withdrawn subject to reasser-tion in the Licensing Board's " ORDER FOLLOWING SPECIAL PREHEARING CONFERENCE" dated January 17, 1980.
5.
Identify all documents which Christa-Maria expects to introduce in evidence or use for impeachment or other cross-examination purposes in this proceeding, other than those identified in the responses to the previous Interrog-atories.
Definitions and Instructions Unless otherwise indicated, the following defini-tions shall apply to these Interrogatories:
1.
"Christa-Maria" shall include not only the Intervenors Christa-Maria, JoAnn Biers, and James Mills
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but also all agents, employees, attorneys, investigators and all other persons directly or indirectly subject to their 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, depart-ments, bureaus, public agencies and boards.
3.
" Documents" shall mean all written or recorded material of any kind or character known to Christa-Maria or in Christa-Maria's possession, custody or control, including, without limitation, letters,' correspondence, telegrams, 1
memorandums, notes, records, minutes, contracts, agreements, records or notations of telephone or personal conversations or conferences, inter-office communications, microfilm, i
bulletins, circulars, pamphlets, studies, notices, summaries, reports, books, articles, treatises, teletype messages, in-voices, 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.
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h 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 "or" shall be construed either disjunctively or conjunctively 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 identify 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 the Intervenor cannot answer any portion of any of the following 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 Christa-Maria expects to be able to answer the unanswered portions.
9.
These Interrogatories are continuing Inter-rogatories and require supplemental answers if Intervenor obtains further information between the time the answers are served and the time of an initial decision in the pro-ceeding.
10.
If you have any questions concerning the proper interpretation of these Interrogatories, please call one of the Licensee's attorneys.
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- 70sefhGallo PA2tAsik2a6ce/1wi Paj/.ip' P. Stdptoe f ~
Two of the Attorneys-for Licensee Dated:
March 13, 1980 Isham, Lincoln & Beale 1120 Connecticut Avenue, N.W.
Suite 325 Washington, D.C.
20036 202/633-9730 Isham, Lincoln & Beale One First National Plaza Suite 4200 Chicago, Illinois 60603 312/558-7500