ML19309G140

Interrogatories Directed to CPC Re Cost Estimate,Const Schedule & Unresolved Safety Problems.Certificate of Svc Encl

ML19309G140
Person / Time
Site:	Midland
Issue date:	04/02/1980
From:	Cherry M CHERRY, M.M./CHERRY, FLYNN & KANTER
To:	CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.)
Shared Package
ML19309G138	List: ML19309G137 ML19309G140 ML19309G143
References
NUDOCS 8005050027
Download: ML19309G140 (6)

Text

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UNITED STATES OF AMERICA t;R a ti n 'E ' f, ,-

NUCLEAR REGULATORY COMMISSION g C; u e;;g, 4 n, .

Before the Atomic Safety and Licensing Board In the Matter of: ) Dkt Nos. 50-329

) 50-330 CONSUMERS POWER COMPANY, )

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(Midland Plant, Units 1 and 2) ) Operating License INTERROGATORIES DIRECTED TO CONSUMERS POWER COMPANY Intervenors, by their attorneys, request that Consumers Power Company answer the following Interrogatories, under oath, within 14 days after service.

DEFINITIONS AND INSTRUCTIONS Please observe the definitions and instructions which are attached hereto as Exhibit A.

Interrogatory No. 1 l Identify with particularity each document and communication within your possession or control (or of which you have knowledge) which relates to:

a. The $3.1 billion cost estimate and the revised construction schedule for the Midland nuclear power units l

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referred to in letters dated February 8, 1980 and i March 27, 1980, from Martha E. Gibbs, Esq., counsel for Consumers Power Company, to Marshall E. Miller, Esq., et al.

i Interrogatory No. 2 State in particular detail each uncertainty which could affect the cost estimate or construction schedule referred to in Martha E. Gibbs' letter of March 27, 1980, to Marshall E. Miller, Esq.

Interrogatory No. 3 l

i State with specific particularity each unresolved safety problem which Consumers Power Company or the Regulatory Staff presently believes applicable in any way whatsoever to the Midland nuclear power units. As used within this Interrogatory the term " unresolved safety problem" includes but is not limited to any safety problem applicable to Midland and identified by the Advisory Committee on Reactor Safeguards, any component of the United States Nuclear Regulatory Commission, any employee of Consumers Power Company, any employee of any consultant to, or contractor with, Consumers Power Company, and any item which was not resolved in the construction permit stage but was left for resolution at the operating stage. l Myron M. Cherry MARY SINCLAIR INTERVENORS,.'t e al.

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l Peter Flynn CHERRY, FLYNN & KANTER J One IBM Plaza , f ff ,m l Suite 4501 By: ( r () / //\ / N Chicago, Illinois 60611 Oh5\fi Their Attorneys (312) 565-1177 U l

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EXHIBIT A DEFINITIONS AND INSTRUCTIONS The following definitions and instructions shall be used and applied by you in connection with the requested information:

1. " Communications" shall mean and include all

" documents" as hereinafter defined and all written, oral, telephonic or other inquiri as, discussions, conversations, negotiations, agreements, understandings, meetings, letters, notes, telegrams, advertisements, press releases, publicity l l

releases, trade releases, and interviews.

2. As used herein, " documents" includes, but is not limited to, written " communications' (as defined), in any form,  ;

i papers, photographs, films, recordings, memoranda, books, records, 1

accounts, communications, writings, letters, telegrams, mail-grams, correspondence, notes of meetings or of conversations or of phone calls, interoffice memoranda or written communi-cations of any nature, recordings of conversations either in writing or upon any mechanical or electronic or electrical l recording devices, notes, accountant's statements or swnmaries, budgets, exhibits, appraisals, work papers, r eports, projects, l 1

tabulations, purchase orders, invoices, canc elled c. 3cks or l check stubs, receipts, studies, surveyr, legal opinions, affi-

davits, interrogatories, legal briefs, legal motions, judgments, complaints, legal complaints, answers, legal answers, counter-claims, vouchers, minutes of meetings, designs, drawings, manuals, notebooks, worksheets, cont acts, agreements, letter agreements, bills of lading, warehouse receipts, timesheets, promissory notes, diaries, desk calendars, circulars, charts, ledgers, schedules, transcripts, news releases, advertisements, press books, advertising materials, publicity releases, trade -

releases, press releases, teletype messages, licenses, /

financial statements, appointment books, payment records, stenographers' notebooks, punchcards and computer printout sheets, computer data, telecopier transmissions, article.s of incorporation, articles of association, by-laws, rules, expense records, regulations, directives, hotel charges, stock transfer books, proposals, prospectuses, offers, orders, logs, objections, video tapes, video cassettes, releases to television stations, video tapes, video cassettes, releases to television stations, evaluations, promotional material, production and sales or license material, whether formal or informal; and all drafts, revisions, and differing versions (whether formal or informal) of any of the foregoing, and also all copies of any of the foregoing which differ in any way (including handwritten notations or other

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written or printed matter of any nature) from the original.

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3. The terms " relate to" or " relating to" shall mean: consist of, refer to, reflect or be in any way logically or factually connected with the matter discussed.

4. The words "and," and "or" shall be read herein in the conjunctive or disjunctive or both, as the case may be, all to the end that the interpretation be applied which results in the more expansive production.

CERTIFICATE OF SERVICE I certify that the foregoing was mailed, postage prepaid and properly addressed, to the Secretary of the Nuclear Regulatory Commission, Washington, D.C. 20555 on April 2, 1980, and on the same day copies of the foregoing were mailed by first-class mail, postage prepaid, to members of the Licensing Board, counsel for Consumers Power Company, and counsel for Dow Chemical Company.

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