ML19320B210
| ML19320B210 | |
| Person / Time | |
|---|---|
| Site: | Big Rock Point File:Consumers Energy icon.png |
| Issue date: | 06/26/1980 |
| From: | Jordan W BIER, MILLS, CHRISTA-MARIA, ET AL, SHELDON, HARMON & WEISS |
| To: | NRC OFFICE OF THE EXECUTIVE LEGAL DIRECTOR (OELD) |
| Shared Package | |
| ML19320B201 | List: |
| References | |
| NUDOCS 8007100042 | |
| Download: ML19320B210 (5) | |
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UNITED STATES OF AMERICA USNRO NUCLEAR REGULATORY COMMISSION:gl g 3 g gg y : -
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,L BEFORE THE ATOMIC SAFE V AND LICENSING 3 0$$D1fjj; (J[! %
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CONSUMERS POWER COMPANY
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Docket No. 50-155
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(Big Rock Point Nuclear Power
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Station)
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INTERROGATORIES TO THE NRC STAFF Pursuant to 10 CFR $2.720, Intervenors Chris ta-Maria, JoAnn Bier, and James Mills request that these interrogatories be answered fully, in writing, and under oath by any employees r
i or representatives of the Nuclear Regulatory Commission Staff
(" Staff") who have personal knowledge of the facts or issues in question.
The answer to each interrogatory'should contain the name and identification of each person supplying or contri-buting to the answer, whether or not he or she has verified the answer.
The answer should also explain the role of each individual in preparing the answer.
Each question is to be answered in four parts as follows:
l A.
Provide the uirect answer to the question.
B.
Identify and provide all documents and studies, and the particular parts thereof, relied upon by the Staff as the basis for the answer.
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.. C.
Identify and provide all documents and studies, and the particular parts thereof, examined but not relied upon by the Staff, which pertain to the subject matter in question.
D.
Explain whether the Staff or any independent contractor is presently engaged in further research or work that may bear on the issues covered in the interrogatory.
If so, please identify the research or work and the people responsible for it.
General
- 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 FOLLO"ING SPECIAL PREHEARING CONFERENCE" dated January 17, 1980, or its
" MEMORANDUM Ah.' ORDER REGARDING TWO ADDITIONAL BOARD QUESTIONS" dated March 27, 1980:
(a)
Identify each person whom the Staff expects to call as an expert witness in respect of such conten-tion or Board question; e
(b)
State the subject matter on which the expert witness is expected to testify; (c)
State the substance of the facts and opinions to which the expert witness is expected to testify and summarize 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 subparagraph (d) above which the expert witness expects to put into evidence or to rely upon in support of his or her testimony 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 PREHEARING 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 l
(other than the expert witnesses identified in response to Interrogatory 1).
This question is limited to those persons whom the Staff expects to call as witnesses other than expc f : witnesses in this pro-ceeding, or with whom the Staff has consulted or expects to consult in connection with this proceeding.
(b)
For each person who has been consulted, state when he or she was consulted anc summarize the substance of any facts or opinions communicated i
by such person to the Staff relating to the subject matter of any contention or Board Question.
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f (c)
If the staff expects tu 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 contained in such testimony, and 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 reassertion in the Licensing Board's " ORDER FOLLOWING SPECIAL PREHEARING CONFERENCE" dated January 17, 1980.
5.
Identify all documents which the Staff expects to introduce in evidence or use for impeachment or othef cross-i-
examination purposes in this proceeding, other than those identified in the responses to the previous Interrogatories.
6.
Please identify and provide copies of all NRC Staff memoranda, reports or other documents or memoranda discussing the progress of the Systematic Evaluation Program at the Big Rock Plant.
Please include any reports or other documents or memoranda that discuss the progress of the SEP in general, without specific reference to Big ~ Rock.
Respectfully submitted, 0
William S.
Jordan, III 1
HARMON & WEISS
[
1725 I Street, N.W.
i Suite 506 Washington, D.C. 20006 l
-(202) 833-9070 DATED:
June 26, 1980
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 Station)
)
)
i CERTIFICATE OF SERVICE I hereby certify that copies of the Interrogatories to Licensee and Interrogatories to Staff have been mailed postage pre-paid this 26th day of June, 1980, to the follow-ing parties:
i Herbert Grossman, Esq.
Janice E. Moore, Esquire Atomic Safety & 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 e
Atomic Safety & Licensing Isham, Lincoln & Beale Board Panel 1120 Connecticut Ave., N.W.
U.S. Nuclear Regulatory Commission Suite 325 Washington, D.C.
20555 Washington, D.C.
20036 Mr. Frederic J.
Shon John O'Neill, II Atomic Safety & Licensing Route 2, Box 44 Board Panel Maple City, Michigan 49664 U.S. Nuclear Regulatory Commission Washington, D.C.
20555
' Docketing & Service Section (2)
U.S. Nuclear Regulatory Commission Washington, D.C.
20555
/E5N (h b,5 William,S.~ Jordan, III
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