ML19329E853
| ML19329E853 | |
| Person / Time | |
|---|---|
| Site: | Midland |
| Issue date: | 03/22/1971 |
| From: | Cherry M MCDERMOTT, WILL & EMERY, Saginaw Intervenor, Sierra Club |
| To: | Atomic Safety and Licensing Board Panel |
| References | |
| NUDOCS 8006180648 | |
| Download: ML19329E853 (57) | |
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In The Matter of CONSUIIERS PO'fER COMPAITY Docket Ilos. 50-329 (MIDL4IID PLAIiT UIIITS 1 AND 2) 50-330 FIRST SET OF IIITERROGATORIES OF CERTAIN IIITERVENORS DIRECTED TO DOW CHEMICAL COMPANY Pursuant to part 2 of the Rules of Practice of the Atomic Energy Commission and the Atomic Energy Safety and Licensing Board's order permitting the serving of these Inter-rogatories and requiring their answer, Intervenors request the following Interrogatories be answered fully in writing and un-der oath by one or more persons or employees of Dow Chemical Ccmpany (hereinafter "Dow") who has personal knowledge thereof or is the closest to having personal knowledge thereof.
If the Interrogatories are answered by more than one person, whether or not he verifies the answers, and whether or not he is an officer or employee of Dow, such person's name and title should be set forth together with an identification of which Interrogatories he is responsible for answering.
To the extent it is applicable, and unless your answer specifically states otheruise, it shall be assumed that each of these answers ap-plies equally to each of the proposed Midland Units 1 and 2.
8006180 [ h
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The Interrogatories below are to be considered your con-tinuing obligation.
Accordingly, after you have answered those Interrogatorics, if additional information comes to your attention with respect to one or more of your In-.
terrogatories or your answers thereto, then you are required to amend your answers to provide such additional informa-tion.
l.-232.
Y'u have received a set of Interro-o gatories addressed to the Applicant, Consumers Power Company.
Those Interrogatories were designed to ascertain informa-tion which forms the basis for various opinions or conclusions or assertions contained within the Preliminary Safety An-alysis Report for.the proposed Midland Units ("PSAR").
Presumably you already have considered and have been privy to such information in the course of your evaluation of the proposed Midland Units or the drafting of your' Petition to Intervene or, alternatively, you have not found it neces-sary or desirable to make such a review in connection with such evaluation or Petition.
Accordingly, with respect to each Interrogatory asked of Applicant, if in your evaluation or during -the preparation of your Petition to Intervene you have considered the information in whole or in part which is called for by each such Interrogatory, then answer that Interrogatory 6.
to the extent of your knowled e as if specifically asked of G
you; alternatively, if any such Interrogatory calls for infor-matien which yo" have not considered in your evaluation or during the preparation of your Petition to Intervene, then you do not have to answer such Interrogatory, but in such case with respect to such Interrogatory and the information it calls for, state:
(a)
Why you did not find it necessary or desirable to consider such information in connection with your evaluation of the propoced Midland Unitc; (b )'
Why you did not find it necessary or desirable to consider such information in connection uith the preparation of your Petition to Intervene; and (c)
Do you intend to offer any evidence, written or oral, or introduce any documents in the course of the pending hearing with-regard to any of the information called for by each such Interrogatory.
If so, list the names and ad-dresses of each person uho will be called upon your behalf to offer testimony together with a summary of what cach such person's testinony will-be and also identify in detail each docu-ment or writing which you intend to introduce.
233 Unless otherwise covered by your answers to othe:
Interrogatories (in which case specify such answers), state in detail.thc.following:
(a)
The names, titles and positions of each persor
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whom you presently plan to call upon to intro-duce oral or written testimony upon your behalf in the course of the pending hearing; (b)
The area or areas whic'n will be the subject of each such person's testimony; and (c)
A description of each document or writing (as-that term is defined in Interrogatory No. 311 below) which you intend to introduce in the course of the pending hearing in support of your. Petition to Intervene or for any other purpose.
If in your. answer you make reference to other than textual (exclusive of footnote) matter in the PSAR, then set forth ccmpletely the text of each such other reference or attach a copy.
234.
With respect to your current supply of process
~steam and-electricity, answer, describing in detail each fact, calculation and assumption thereof, the following:
(a)
What is the current co'st of such process
. steam and electricity in g/lb./hr. and mills /kwh respectively; (b)
What would be the cost of producing process steam and electricity'if your present coal plants were remodeled to abate its current
. pollution effluent.
Include within your answer a comparison of the schedule for com-pletion of such remodeling with your belief as to the schedule for completion of the proposed Midland Units; (c)
How long would it take to remodel your current plants to meet current and anticipated air pollution standards and what would be the capital costs; and (d)
Would you support the construction of the proposed Midland Units if you could operate your present plants without regard to air pollution standards and if so, why.
If in your answer you make reference to other than textual (exclusive of footnote) matter in the PSAR, then set forth completely the text of each such other reference or attach
- a. copy.-
235 With respect to the process steam proposed to be produced by the proposed Midland Units, state:
(a)
What is the expected cost of such process steam and electricity in g/lb./hr. and mills /
kwh respectively;
.(b) iihat would be the cost of supplying process steam and electricity in g/lb./hr. and mills /
kuh respectively using:
(1)'. Coal;
.(2) 011; and (3)
Gas.
.(c)
- ihat would be the capital cost of construct-ing a plant at the Midland site which could supply the necessary process steam and electricity using:
(1)
Coal (2)
Oil; and (3)
Gas; and satisfying all associated pollution requirements.
Describe in detail each fact, calculation and assumption upon which you base your ansuer.
If in your answer you make reference to other than textual
'(exclusive of footnote) matter in the PSAR, then set forth completely the text of each such other reference or attach a copy.
236.
Describe in detail the basis upon which you con-
.clude, if you do, stating each fact, calculation and assump tion thereof, that you cannot remain competitive at your Midland location unless~you obtain nuclear-produced process steam.
If,
in your-answer you make reference to other than textual (exclusive of footnote) matter in the PSAR, then set forth completely the text of each such other reference or attach a copy, 237 With respect to the variance issued to you by the MichiCan Air Pollution Control Commission by which you are committed to shut down your present power plants upon the start of operation of the proposed Midland Units, when could these plants meet the air pollution requirements if the proposed Midland Units are not granted a construction permit.
Additionally, on what date or upon what occurrence or circum-sta.cc would you exercise your contractual right, if any, with Consumers Power.Co. to terminate your obligation to purchase process steam from the proposed Midland Units and/
or to terminate your support of the proposed Midland Units.
Include within your answer the date or occurrence beyond which if the proposed Midland Units are not (i) granted a construction permit, (ii) in the. process of construction, (iii) constructed and (iv).in operation you would make alternate arrangements, describing such alternate arrangements.
If in your answer you make reference to other than textual (cxclusive of foot-note) matter in the PSAR, then set forth completely the text of each such other reference or, attach a copy.
238.
'dith respect to your consideration, if any, of each type of plant which could be built at the proposed Midland-site to supply-process steam and electricity, state what analysis, if any, was performed by you, stating each fact, calculation and assumption thereof, to determine what type of plant uould be best suited for such site.
If'in your answer you make reference to other than textual.(exclusive of footnote) matter in the PSAR, then set forth completely the text of each such other reference or attach a copy.
239.
With respect to your waste burner, answer the
.following:
(a)
What is each material which is discharged as an effluent; (b)
What is each material which is burned; and (c)
What is the quantity of unburned material which is released to the atmosphere and what is the concentration and toxicity of each such compound.
If in your answer you make reference to other than textual
'(exclusive'of footnote)' matter in the PSAR, then set forth completely the text of each such other reference or attach a copy.
240.
Describe in detail the types of monitoring equipment and. systems which you employ or shall employ to de-tect and control the emission of chemicals into the atmosphere.
If in your answer you make reference to other than textual j
i (exclusive of footnotc) matter in the PSAR, then set forth completely the text'of each such other reference or attach a copy. 9*--
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O 241.
Describe in detail each complaint from any
-source which you have received with respect to chemical
-releases, specifying the di'ection, time, type of chemical, r
source.and resolution thereof.
If in your answer you make reference to other than textual (exclusive of footnote) matter in the PSAR, then set forth conpletely the text of such other reference or attach a copy.
242.
State the names and position of each Dow en-ployee who has been given time off from his job or has been permitted as part of his employment with or without the ap-proval of Dow to promote the proposed Midland Units.
" Pro-motion" in this Interrogatory means other than technical work
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directly.related to the design and construction of the pro-posed Midland Units.
If in your answer you make reference to other-than textual (exclusive of footnote) matter in the PSAR, then set forth completely the text of each such other refer-ence or attach a copy.
243.
Describe and identify in detail the substance of each analysis, report and review, if any, of the proposed Midland Units and any part.or operation thereof, made by Dou or on behalf of Dow.
Include within your answer, the name, the position and-the crea of expertise of each person, firm and corporation who was consulted with or who worked on each such analysis, report and review.
If in your answer you make reference to other than textual (exclusive of footnote) matter in the PSAR, then set forth completely the text of
-each such other reference or attach a copy.
_9
244.
State the name, position and. background of each~ full-time employee whom you employ whose position is in or whose area of expertice is nuclear technology.
If in your answer you make reference to other than textual (exclusive
-of footnote) matter in the PSAR, then set forth completely the text of each such other reference or attach a copy.
245 Describe and identify in detail, stating each fact, calculation and assumption, each Dow Biochemical
.Research Laboratory report which relates to, refers to or concerns the proposed Midland Units.
If in your answer you make reference to other than textual (exclusive of footnote) matter in the PSAR, then set forth completely the text or each such other reference or attach a copy.
246 Describe and identify in detail, stating each fact, calculation and assumption, each statement and report issued by the Dow Radiochemistry Laboratory which re-lates to, refers to, concerns or makes recommendations to the Dow Board of Directors with regard to the proposed Mid-land' Units and/or Dow's-participation therein uhether as a user of process steam or otherwise.
If in your ansuer you make reference to other than textual (exclusive of footnote) matter in the PSAR, then set forth completely the text of each such other reference or attach a copy.
247 State each question and your answer thereto, if an answer was given, which were respectively received and made by you: respectin g your: invitation to all Midland citizens concerned.
about the proposed Midland Units to cond questions to you.
If in your_ answer you make reference to other than textual (onclusive.of footnote) matter in the PSAR, then set forth completely the text of each such other reference or attach a copy.
248 State the name of each federal, state and local unit of covernment, including each individual and his position, with whom you have had contact during your consideration of the proposed Midland Units.
For each such contact, describe in detail the content of each con-versation, letter and/or telegram.
If in your answer you make refer'ence to other than textual (exclusive of footnote) matter in the PSAR, then set forth completely the text of each such other reference or attach a copy.
249.
Describe in detail the content of the conver-sation which occurred between a Dow spokesman and a Detroit consultant to the Midland Planning Commission as reported by Bruce C. Brown in the Midland Daily News, January 29, 1971.
If-in your answer you make reference to other than textual (exclusive of footnote) matter in the PSAR, then set forth completely the text of each such other reference or attach a copy.
250
.dere all the Dow Board of Directors in. favor of the proposed Midland Units.
If not, list the name and substantive: position of each such dissenting Director, in-cluding uithin your answer the basis of the Board's decision "
to participate in any way in the proposed Midland Units.
If in your answer you make reference'to other than textual (exclusive of footnote) matter in the PSAR, then set forth completely the text of each such other reference or attach a copy.
251.
Unless completely set forth in your answer to Interrogatory number 243 above, describe and identify in detail each safety analysis, if any, which was done by you or by a consultant retained by you concerning the proposed Midland Units.
If in your answer you make reference to other than textual (exclusive of footnote) matter in the PSAR, then set forth completely the text of each such other reference or attach a copy.
252.
Witu respect to your statement at page 4 of your Petition to Intervene that "for various reasons, Dow must developa different source of process steam and electri-cal energy for its Midland location", describe in detail each such reason stating each fact, calculation and assump-tion thereof.
If in your answer you make reference to other than textual (exclusive of footnote) matter in the PSAR, then set forth completely the text of each such other reference or attach a copy.
253.
Describe and identify in detail the variance granted tojyou by the Michigan Air Pollution Control Commis-sion under which the Dow Midland Plants are presently operat--
ing.
If in your answer you make reference to other than -__
textual.(exclusive of footnote) matter in the PSAR, then set forth completely the text of each such other reference or attach a copy.
254 Describe in detail the basis, stating each fact, calculation and assumption, upon which you state at page 4 of your Petition to Intervene that " fossil-fuel costs are escalating so rapidly [and] Dou cannot remain competi-tive at its Midland location unless it substitutes nuclear-produced process steam."
If in your ansuer you make reference to other than textual (exclusive of footnote) matter in the PSAR, then set forth completely the text of each such other reference or attach a copy.
255.
Describe in detail, stating each fact, calcu-lation and assumption, the basis upon which you state at page 5 of your Petition to Intervene that " Refusal to grant a_ permit to construct this proposed nuclear power plant...
may -require Dou to minimize the future role of its Midland plant and to construct chemical plants in other areas of the country and the world where sources of energy are available which are' economically and environmentally acceptable."
If in your answer you make reference to other than textual (enclusive of footnote) catter in the PSAR, then set forth cocpletely the text of each such other reference or attach a copy.
256'.
Describe in detail each event uhich led to the fire which burned through building 776-777 at the AEC's.
Rocky Flats plant near Denver, Colorado, on May 11, 1969 State'the_ magnitude of the off-site contamination which-resulted from the plutonium which was burned.
Describe in detail each fact,' calculation and assumption upon which you base your answer.. If in your answer you make reference to other than textual (exclusive of footnote) matter in the PSAR, then set forth completely the text of each such other reference or attach a copy.
257.
Describe in detail each affiraative and direct health benefit you contend, if you do, will be received from a person exposed to radiation from the proposed Midland Units.
If in your ansser you make reference to other than textual (exclusive of footnote) matter in the PSAR, then set forth j
completely the text.of each such other reference or attach
)
a copy.
258.
With respect to the operations of the Rocky Flats. plant, did you store 1,400 55-gallon drums of machine 3
cutting oil.containing high concentrations of plutonium near the aforesaid plant.
Did-these drums corrode and allow their contents.to contaminate the surrounding soils and wind.
De-scribe in detail what events led to such storage, who approved the methods of. storage and.what is currently being done to dispose such waste and what is being done with the aforesaid leakincdrpms. ' Describe in. detail each document, letter,
. telegram and conversation'uhich is_related to or which con-cerns.this incident which is in your possession or control.
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With respect to this incident uould you discuss your under-standing of the statement "...This would be a very serious thing if Dow uns taking upon itself the burial of plutonium unstes without going through established procedures..." made by Rep. Chet Holifield in a discussion with members of the Rocky Flats Union, AEC, and others at the Joint Committee on Atomic Encrcy office,c in Washington on April 10, 1970.
If in your answer you make reference to other than textual (exclusive of footnote) matter in the PSAR, then set forth completely the text of each such other reference or attach a copy.
259.
Uith respect to your proposed use of process steam proposed to be generated by the proposed I11dland Plant, describe in detail, stating each fact, calculation or assump-tion, hou the following products could come in contact with radioactive contaminants of the process steam:
(a)
Aspirin and other pharmaceutical salicylates; (b)
Glycerine; (c)
Urethane polyols; (d)
Floc culating agents; (e)
Ion exchance resins; (f)
Vaccines; and (g)
I!utritional feed additives.
Also state in detail uhat procedures you contemplate to prevent each such contact and uhat procedures you contemplate in the event of such contact.
If in your answer you make reference to other than textual (exclusivo of footnote) natter in the PSAR, then set forth completc19 the text of each such other reference or attach a copy.
260 With respect to your statement at page 3 of your Petition to Intervene that you desire to assure that "the construction permit will issue and be in such form as to assure that stringent requirements for the quality of Dow's process steam will be met," state the following:
(a)
Do the words " stringent requirements" have any different meaning than the words " stringent standards" also used at page 3 of your Petition to Intervene and if so, state the difference; and (b)
Describe what " form" the construction permit will'have to issue so as to assure such strin-gent requirements.
l If in your answer you make reference to other than textual (exclusive of footnote) matter in the PSAR, then set forth completely the text of each such other reference or attach i
a copy.
9 j
261.
With respect to the statement at page 4 of your Petition to Intervene that the proposed Midland Units' site was selected by the fact that "the process steam to be sup-plied to Dow must be produced in proximity to its point of 1
use," explain whether the aforesaid reason was the sole and o,_
overriding consideration for the selection of the site of the proposed Midland Units.
Include within your answer a listing of each other consideration, if any, which was made.
in connection with the selection of such proposed site and the weight given to each such other consideration as coqpared to the weight given to the purchase of process steam.
If in your answer you make reference to other than textual (exclusive of footnote) matter in the PSAR, then set forth ccmpletely the text of each such other reference or attach a copy.
262.
Have you ever considered the cost and feasibility of locating the proposed Midland Units underground, and if not, why not.
If in your answer you make reference to other than textual (exclusive of footnote) matter in the PSAR, then set forth completely the text of each such other reference or attach a copy.
263 List each of the " relevant factors" which are encompassed in your use of those words at page 5 of your Petition to Intervene.
With respect to each such relevant factor, describe in detail the analysis and substance of the review thereof made by you as stated at page 5 of your Petition to Intervene.
If in your answer you make reference to other than textual (exclusive of footnote) matter in the PSAR, then set forth completely the' text of each such other reference or attach a-copy..
264 List each alternative to a nuclear-generating facility in Midland which you contend at page 5 of your Peti-tion to Intervene that you have considered.
If in your answer you cake reference to other than textual (exclusive of footnote) matter in the PSAR, then set forth completely the text of each such other reference or attach a copy.
265.
With respect to your statement at page 6 of your Petition to Intervene that you are " uniquely affected by the planning and engineering of the proposed facility," state each step, procedure, test or experiment which you have taken in such regard in addition to those taken by Consumers Power Company and the Atomic Energy Commission.
If in your answer you make reference to other than textual (exclusive of foot-note) matter in the PSAR, then set forth completely the text of each such other reference or attach a copy.
266.
At page 6 in your Petition to Intervene you assert that Dow's interest in assuring " stringent requirements" could not be adequately represented by any other party to this proceeding.. Please explain this statement including whether you mean that uithout your presence Consumers Power Company and/or the Atomic Energy Commission would not assert a position to meet requirements or standards as " stringent" as you wish them to.
Include w:. thin your answer a description of each 4.
.O conversation or uriting (as that term is used in Interrocatory No.311 below) which refers to, relates to or concerns any con-versation you had with anyone wherein you insisted that stand-ards or requirements _with respect to the generation of the process steam should be or must be higher than had theretofore been planned, if you nere to participate in the proposed Midland Units.
If in your answer you make_ reference to other than textual (exclusive of footnote) matter in the PSAR, then set forth completely the text of each such other reference or at-tach a copy.
267.
With respect to your statements at pages 6 and 7 of your Petition to Intervene that yea are concerned "about the timing of this project" and that your planning requires the availability of a nuclear facility "at the' earliest prac-ticable time," state in detail each concern you have about timing including relevant dates, and also state the date or dates which you have determined are "the latest practicable time" and the latest practicable time.
If in your answer you make reference to other than textual (exclusive of footnote) matter in the PSAR, then set forth completely the text of each such other reference or attach a copy.
268.
Describe in detail the accident concerning radioactive material which tock place at Dow Corn $ng Company on or about. December 22, 1970, which involved James.Mathews, i
Donald'Helson and Stanley McCann.
Include within your answer whether all necessary alarm systems were working as designed and functioned according1'y thereto in connection with the accident;-whether the men were wearing protective clothing before, during and after the ae ident; what procedures were followed, and how immediately they were followed, in connection with_the health and safety of the men affected by the accident involving radioactive material.
Also include within your answer a description of the resolution of the accident including whether or not Dow Corning was cited or investigated for an AEC license violation and whether or not Dow Corning was forced to reapply to the AEC to receive a license to handle the radioactive material in a " loose" state rather than a " contained" or
" encased" state. If in your answer you make reference to other than textual (exclusive of footnote) matter in the PSAR, then set forth completely the text of each such other reference or attach a copy.
269 Regarding the proposed Midland Units and their
. proximity to your Midland facilities, answer the following:
(a)
Does there presently exist a survey of the natural radiation background in the area in-cluding but not limited to your Chemical plant which will~be affected by radiation releases of any magnitude from the proposed Midland Plants.
If there is such a survey, then state the following:
(1)
When was the survey taken; (11)
The namec and addroscen of the pernons, firma or corporations who participated in making the survey and analyzing its results.
(iii)
The scientific procedure followed in connection with the survey; (iv)
The results of the survey in terms of total natural background of significant radionuclides in each significant geo-graphic part of the total geographic area which uas the subject of the sur-vey, explaining in detail the reasons, if any, why the background radiation differed, if it did, from one geographic part to another in the total geographic area-surveyed.
Be sure to include in your answer the contribution to natural background from co-called man-made radiation such ac, for example, radio-active fallout and radiation from other possible sources.
(v)
If any of your.mcacurements vary at dif-ferent times of the year, please state the differences and varianecc, and in-clud'e uithin your answer the total annual -
dose due to natural and man-made radiation, in terms of roms, which a person will re-ceive each year in the area surveyed prior to the construction of the proposed Midland Units.
State what differences, if any, in dose which will be received by a person in different geographic parts of the geographic area surveyed on a yearly basis subsequent to the proposed Midland Units.
(b)
If you have not made a survey of the natural background in anticipation of the construction of such proposed Midland Units, then answer the following:
(i)
Why have you not made such a survey and include within your answer whether or not you think it important to have such a survey prior to the construction of the proposed Midland Units in order to assess the effect, if any, upon persons living in the relevant area and working at your chemical plant from the contri-bution to radiation dose frc= the proposed Midland Units.
4 (ii)
Did_you ever discuss with any person, firm, corporation or federal and state.
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agency the possibility or desirability of making such a survey in connection with the proposed Midland Units and your support and evaluation thereof.
If not, why not.
If yes, then provide:
(a)
The names of such persons, firms, corporations or state or federal agencies; (b)
A listing of all correspondence had between them or among them which are in your possession or control; (c)
The dates of relevant conferences, conversations or discussions and the substance of each such conference, conversation or discussion.
(iii)
The PSAR indicates that the Consumers Power Company intends to make such a sur-vey prior to completion of the Units.
Do you contemplate that if a certain level of background radiation is demonstrated that you vill request the Consumers Power Co. to nodify the~ proposed Midland Units in some fashion or nanner to account for that specific level and, if not, why not.
(iv)
Is there any level of natural radiation I
4 background which would cast doubt upon h
the proposed Midland Units and your sup-port and evaluation thereof.
Explain 1
your answer.
(v)
If there is no specific level of natural radiation background which would cause you to reconsider support for conctruction of the proposed Midland Units, then of what significance is the aforesaid back-ground radiation survey.
(c)
Do you consider a survey of background radiation a necessary prerequisite to a decision to con-struct a nuclear power plant in a given area.
If not, why not.
(d)
Is it true that you support the construction of the proposed Midland Units without regard to the results, of whatever nature, of_the proposed background radiation survey.
Explain your answer.
(e)
Do you intend, subsequent to the initial back-ground radiation survey, to continue to make background radiation surveys of your plant on a regular basis.
If not, why not; if so, then state the following:
(1)
The procedures you will use in making such surveys. -
lL...
(ii)
What level of increase in natural back-ground radiation, if any, would cause you:
(a)
To requ.st curtailing of operations of the proposed Midland Units to account for such increase; and (b)
To request cessation of operations of the proposed Midland Units to account for such increase.
If in your answer you make reference to other than textual (ex-clusive of footnote) matter in the PSAR, then set forth completely the text of each such other reference or attach a copy.
270.
Have you informed the persons living in the Greater Tri-City arca, the persons living in Midland, Michigan, your em-playecs who will work for you uithin the exclusion area and low population cone of fhe proposed Midland Units, the employees uho will vork at Dow Corning in Midland, Michigan, or any of them, of the,following:-
(a)
The amount of radiation each such person could
' receive from the proposed Midland Units; (b)
The-amount of total radiation each such person could receive considering contributions to radiation from any source; and (c)
The possible consequences of danger of genetic Lnd other diseases as a result of being exposed to radiation-over a long period of time.-._
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(d)
The possibic syncrgyctic effects of exposurc
.to both radioactive and chemical pollutanto.
In connection uith your ancwcr, unless it is no, stato in detail how you have accompliched informing the various persons listed horcin of such information.
If your answer is no, state your basis for not having done so.
If in your answer you make re-ference to other than textral (exclusive of footnote) matter in the PSAR, then set forth completely the text of each such other reference or attach a copy.
271.
Is it your position that there is absolutely no danger of any adverse effect over a 40-year period or any lesser period, to a person at the boundary of the proposed Midland Units as a result of being exposed on a continuing basis of radiation from the proposed Midland Units.
Would your answer be any different considering the present relevant natural back-ground of radiation and, if not, would your answer be any different if the present natural background of radiation had any increase in its concentration.
If you feel you cannot answer this question
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yes or no, then state your answer in detail and terms of proba-bilitics, including uithin your answer each fact, calculation and assumption upon uhich you base such probabilitics.
If in your-answer you make reference to other than textual (exclusive of footnote) matter in the PSAR, then set forth completely the
' tent of eac'.7 cuch other reference or attach a copy.
272. -Uhat stcps have you taken.to inform persons living in the Greater Tri-City arca as to how each such percon can protect himself from receiving an overdose of radiation.
What measures have you provided to determine whether any such person has or will receive an overdose of radiatior, considering all radiation sources to which each such person will be exposed, -
and what steps have you taken to inform each such person how he would know if he had received an overdose of radiation at any given time from all sources.
The phrase " overdose of radiation" is to be interpreted in this. answer in two ways:
first, it is to be assumed that an overdose of radiation is anything which at least doubles the natural background radia-tion; and second, an overdose of radiation also means more radiation than 170 millirems per ye'ar.
Your answer should direct itself to answering the questions separately for each definition of overdose of radiation and should include all sources of radiation to which each such person.will be exposed and not just that amount of radiation to be released from the proposed Midland Units, including but not limited to such things as periodic X-rays from dentists, doctors, etc.
If in your answer you make reference to other than textual (exclusive of footnote) matter in the PSAR, then set forth completely the text of each such other reference or attach a copy.
273 In connection with the operation of the proposed Midland Units, do you intend to constantly meter the amount of radiation, o.ther than released from the proposed Midland Units, which the persons living in the Greater Tri-City area will
receive and, if so, state in detail how and in what fashion.
Include within your answer whether you will attempt to require doctors, dentists and other health related facilities to koop a continuous record of patients' total e::posure to radiation including but not limited to X-rays and background radiation from natural and man-made sources of radiation.
If in your answer you make reference to other than textual (exclusive of footnote) matter in the PSAR, then set forth completely the text of each such other reference or attach a copy.
274.
Have you made any projections of the amount of down-time of the proposed Midland Units for any of the follow-ing cate6 cries:
(a)
Normal maintenance; (b)
Puel loading; (c)
Abnormal maintenance such as, for example, tur-bine and generator failure which result in the proposed Midland Units having outages for sig-nificant periods of time such as, for example, 50 days or more;'and (d)
Involuntary shutdown due to accidents other than MHA's or LOCA's such as described in Section 14 of the PSAR.
If you have not made such projections, state why not.
If you have made such projections, then set them forth in detail
-including each fact, calculation and assumption upon which you..
have based ~your projection and include within your ancuer, al-though not meant in a limiting manner, the-following:
(a)
How you will be supplied with processed steam in each of the above events; and (b)
What amounts of financial loss, inability to market products and unemployment would be caused by each such shutdoun and loss of ability to supply processed steam.
If in your answer you make reference to other than textual (exclusive of footnote) matter in the PSAR, then set forth completely the text of each such other reference or attach a copy.
275 In your contract with Consumers Power Company concerning the construction of and the generation of electricity i
and processed steam from the proposed Midland Units, state the following:
(a)
Are you contractually obligated to purchase such steam over a long period?
If so, state the period and the method of payment; and (b)
If the proposed Midland Units at any time deviate _significantly from its schedule, ex-isting as of December 1, 1970, for building and construction, does your contract with Consumers Power Company permit you to relieve yourself from any obligation to cooperate in the proposed venture of tlua proposed construction of the l,
~
Midland Units and make whatever other arrangements you wish for the purchase, if at all, of processed steam?
If yes, then state in detail tha rights and obligations of the parties with respect to such cir-cumstances.
If in your ansuer you make reference to other than textual (exclusive of footnote) matter in the PSAR, then set forth completely the text of each such other reference or attach a copy.
276.
What plans or projections are you aware of for selling or proposing to sell processed steam from the proposed Midland Units to other than yourself, whether or not such future user is presently situated in Midland, Michigan?
If'in your answer you make reference to other than textual (exclusive of footnote) matter in the PSAR, then set forth completely the text of each _such other reference or attach a copy.
277.
Has any consideration of any kind been given to the adding of additional units to the proposed Midland nuclear power station.
If any such consideration of any kind has been given, then state the following:
~~
(a)
Each fact an'd detail concerning additions to and expans'ons of the proposed Midland Units.
(b)
The projected dates and projected costs of such expansions or additions.
(c )
The name of each person, firm or corporati m, including industrial concerns other than Dow, which you have communicated with or intend to ccmmunicate with in connection with such expan-sion or addition, including relevant dates and a listing and description of relevant documents; and (d)
List and describe each document in your posses-sion or your control dealing with the financ!.a1 and economic questions of the proposed Midland Units, not including scientific questions, which are in existence to date beginning with the day of the first discussion within your organization dealing with the constructing and operating of the proposed Midland Units.
If in your answer you make reference to other than textual (ex-clusive of footnote) matter in the PSAR, then set fo'rth completely the text of each such other reference or attach a copy.
278.
Does your agreement or arrangement with the Consumers Power Company concerning the proposed Midland Units contemplate or involve ownership in any thay of any of the pro-
posed Midland Units or part or interest thereof by you or any company which'is related by stockholdings to you.
If in your answer you make reference to other than textual (ex-clusive of footnote) matter in the PSAR, then set forth completely the text of each.such other reference or attach
'a copy.
279 Will you or any of your personnel be involved in any decision to shut down or scram the proposed reactors in light of the fact that such shutdown or scram will prevent, for a period of time, the sale of processed steam to you.
If in your. answer you make reference to other than textual (ex-clusive of footnote) matter in the PSAR, then set forth completely the text of each such other reference or attach a copy.
280'.
Have you considered whether or not persons living or working in the Greater Tri-City area will become more susceptible to radiation danger or effects as a result of having been living or working in an industrial community such as Midland, Michigan, and having been exposed to pollu-tants of any kind over a long period, especially having been exposed to chemical and other toxic releases.
Include within your answer whether you consider that radiation can be-more or less harmful to a person who has been subjected to such conditions as presently exist in Midland, Michigan due to the operation of all of your facilities.
If in your answer ~
)
j
~
you make reference to other than textual (exclusive of foot-note) matter in the PSAR, then set forth completely the text of each such other reference or attach a copy.
281.
Have you taken into consideration with res-pect to the building of the proposed Midland Units, surveys or studies, if any, regarding the risks of emphysema and lung diseases in the Midland, Michigan area compared to other geo-graphic parts of the State of Michigan in which there is no chemical or industrial waste discharged.
If you have not made any such surveys, state why not.
If you have, then state the' nature, extent and results of your considerations.
If in your answer you make reference to other than textual (ex-clusive of. footnote) matter in the PSAR, then set forth completely the text of each such other reference or attach a copy.
282.
Have you taken into consideration in connection with the proposed Midland Units the results of any surveys or studies-in Midland and surrounding counties dealing with incidence of luekemia, cancer and other radiation-induced diseases.
If not, state why not; and if you have, state the nature, extent and results of your considerations.
If in your answer-you make reference to other than textual (exclusive of footnote) matter in the.PSAR, then set forth completely the text'of each such other reference or attach a copy.
283. - State how much money has been spent or is planned to be ' spent separately by you and Consumers Power
+.,
1 Company with respect to the ~ promotion of the proposed Midland Units.
For.the: purposes of this question, the term promotion is limited solely to efforts made to explain, influence or propagandize the public with respect to the need for and safe operation of the proposed Midland Units.
Include within your answer uhether you or Consumers Power Company contributed any funds in connection with the cost of a trip by certain per-sons, later to become members of intervenor Midland Nuclear Committee, to oak Ridge, Tennessee, in 1970.
If in your answer you make reference to other than textual (exclusive of footnote) matter in the PSAR, then set forth completely the text of each such other reference or attach a copy.
284.
State whether any officer or officers of Dow 4
ever asked Consumers Power Company to contribute proportion-ately or to contribute' any amount to the cost of the trip described in Interrogatory 283 above.
If in your answer you make reference to other than textual (exclusive of footnote) matterinthePSqR,thensetforthcompletelythetextof each such other reference or attach a copy.
283 In terms of your last fiscal-year, state what percentage of your net income was spent upon research and development separately for nuclear power and all other areas
' and then state what percentage of your net income for your last fiscal' year was spent, separately, for promotion of the use of. electricity and for the promotion of the use of nuclear W - -
power.
Answer the same questions based upon projections for your next fiscal year.
If in your answer you make reference to other than textual (exclusive of footnote)' matter in the PSAR, then set forth completely the text of each such other reference or attach a copy.
286.
Do you contend that radioactive emissions which synercize with air and water pollutants will not result in any adverse health consequences.to persons living in or near the Greater Tri-City area.
If your answer is yes, list what data you have compiled in connection with your determination, speci-fying each face, calculation and assunption upon which you base your answer.
State.in your answer if you have considered each of the various pollutants emitted by industries, including those emitted by you, in the Greater Tri-City area into the air and water.
Also include within your answer separately for each chemical, radioactive and nonradioactive' pollutant which you have considered, a detailed description, specifying each fact, calculation and assumption thereof, how any reaction, chemical or otherwise, may occur so as to:
(a)
Increase the overall toxicity of each such pollutant; (b)
Produce other toxic substances; and (c)
Yield substance or substances which are-trans-ferable through new pathways or at increased rates.
If in your ansucr you make reference to other than textual (en-l clusive of footnote) matter in the PSAR, then set forth com-pletely the text of each such other reference or attach a copy.
287 Have you considered any accident or the maximum accident possible involving train shipments of chemicals or any other products passing on the C&O railroad tracks which pass l
through your plant which are adjacent or near to the site of the proposed plants.
If not, why not.
If you did so consider l
such train accidents, set forth the accident analysis in detail l
specifying each fact, calculation and assumption thereof.
Include within your answer what consideration was 6 ven, if any, 1
to a combination accident involving such train shipments and l
I chemicals stored or manufactured by you.
Also set forth whether you have given or intend to give any special consideration to preventive procedures and safeguards re5arding h16h combustible I
chemicals s..ch as butane, in light of their combustibility and if yes, then describe such precedures and safeguards.
If in your answer you make reference to other than textual (exclusive of footnote) matter in the PSAR, then set forth completely the text of each such other reference or attach a copy.
288.
What alternatives do you contemplate to provide yourself steam power in the event of inability at any time to receive or purchase processed steam from the proposed Midland Units.- Include uithin your answer a discussion of each accident, either at your plant or at the proposed Midland Units, which could occur, subsequent to operation, if any, of the proposed 136-
~
Midland Units, from a total cessation of processed steam which would or might result in the cessation of such equipment as steam driven pumps and other storace and/or shipping equipment which rely upon steam for operation.
If in your answer you
~
make reference to other than textual (exclusive of footnote) matter in the PSAR, then set forth comp 3etely the text of each such other reference cr attach a copy.
289.
In the even't an accident of reactor origin is of " sufficient ma5nitude to prsduce the necessity of evacuation of the area surrounding the Low-Consumer area," as is stated at p' age 2C-11 of the PSAR, who is responsible for making this decision and on what basis, written or oral, shali it be made?
In addition, describe in detail the following:
(a)
The working agreement which is referred to on page 2C-11 of the PSAR between the City of Midland and you; and (b)
The arrangements with state and local civil defense officials which you have made to handle such an event.
If in your answer you make reference to other than textual (ex-clusive of footnote) matter in the PSAR, then set forth com-pletely the text of each such other reference or attach a copy.
290.
Describe in detail the " Evacuation' plans" which are referred to.at page 2C-11 of the PSAR~as "in existence" and which will cover " Midland I uclear Plant Accidents and will cover.
s 9 g
evacuation routes to be tphen away from the plant."
If in your answer you make reference to other than textual (ex-clusive of footnote) matter in the PSAR, then set forth com-pletely tho text of each such other reference or attach a copy.
291.
Describe in detail the " Discussions" which
" indicate no Dow Corning accident" could have a "possible effect on the Midland IIuclear Plant" as is stated at page 2C-11 of the PSAR.
Include within your answer whether you believe such effects impossible and each fact, calculation and assumption upon which you base your belief.
If in your answer you make reference to other than textual (exclusive of footnote) matter in the PSAR, then set forth completely the text of each such other reference or attach a copy.
292.
Describe in detail, stating each fact, calcula-tion and assumption, the basis upon which you accept, if you do, that the "Officialc of the City of Midland have indicated that the cenveyance of automobile transporting the evacuated employees of the Dow and Dow Corning Companies to outside the City boundary could be accomplished within about one hour." If in your answer you make reference to other than textual (exclusive of footnote) material in the PSAR, then set forth completely the text of each such other reference or attach.a copy..
293 Describe ~1n detail, stating each fact, calcula-tion and assumption, how each of the following coordinate so as to o
prevent the traffic congestion which "would make evacuation impossible" as st&ted on page 2C-30 of the PSAR:
(a)
City Iolice; (b)
Dow Safety Services; (c)
City Fire Department;
-(d)
Don Fire Department; (e)
Dow Corning Plant Protection;
.(f)
Civil Defense; f
(g)
Service Station; and (h)
State Police.
If in your answer you make reference to other than te::tual (exclusive of footnote) material in the PSAR, then set forth completely the text of each such other reference or attach a copy.
294.
State and describe each emergency and/or evacu-ation plan you have used or relied upon in developing emergency and/or evacuation plans in connection with the proposed Midland Units.
Have any of such relied upon plans ever been put to a real emergency test within the last five years and if so describe in detail the emergency and the then evaluation of the effect-iveness of the relied upon plans.
If in your answer you make reference to other than te::tual (exclusive of footnote) matcrial in the PSAR, then set forth completely the text of each such other reference or attach a copy.
295 With respect to the " site emergency plan" as mentioned on page 2C-8 of the PSAR, answer the following:
(a)
Uho is responsible for the development, review-ing and testing of the " site cmergency plan";
(b)
What is the content of the " detailed written instructions and indoctrination of the desig-nated civil and Dow Chemical Company authoritics";
(c)
Who are the designated civil and Dow Chemical Company authorities and what are their respective positions within their own organizations; and (d)
Does Consumers Power Company have authority over Dow to implement, if and when necessary, evacua-tion from Dou premises necessitated by an accident originating from the proposed Midland Units.
If not, describe your role and its implementation in such a' circumstance.
If in your answer you make reference to other than textual (ex-clusive of footnote) material in the PSAR, then set forth completely the text of each such other reference or attach a copy.
296. With respect to the prcposed Midland Units and your support and evaluation thereof, state, assuming the occurrence at the site of the proposed Midland Units of a full scale accident as examined in WASH-740 for a single unit of the size of either of the propos'ed Midland Units, and describing in detail, each fact,. calculation'and assumption upon which you base your answer, _
the following:
(a) 'How much land would be contaminated and for how long a period of time; (b)
How much property damage, in dollars, would occur; (c)
How many pregnant women might be exposed to more than half a rem of radiation, if the acci-dent occurred in each of the years 1980, 1990 and 2000 considering population projections for each of such years; (d)
How many people might be exposed to at least 25 rems of radiation if the accident occurred in each of the years 1980, 1990 and 2000, considering population projections for each of such years; (e)
How many cancer and leukemia deaths might one such accident cause; (f)
Approximately how many genetic deaths and re-tarded children could result in later generations from one such accident; (g)
Approximately hou many extra cases of coronary heart disease and schizophrenia could result from one such accident.
What differences would there be to your F.nswers if the acci-
~
dent occurred and the proposed Midland Units were 100 or more
_41_
e ye
'w 4
feet underground.
Also state whether these calculations have ever been made for this docket number or another docket number I
with similar circumstances and, if not, why not.
If in your answer you make reference to other than textual (exclusive of
~
footnote) matter in the PSAR, then set forth completely the text of each such reference or attach a copy.
297. With respect to the proposed Midland Units and your support and evaluation thereof, and to the substance and con-tents of the letter dated IIovember 12, 1969, addressed to Chairman Seaborg by Joseph Hendrie of the Advisory Committee on Reactor Safe-guards, within which Mr. Hendrie called attention to the exis-tence of " urgent need for additional research and development" in safety features of the reactors already going into production, describe in detail, stating each fact, calculation and assumption, whether you-believe such needed safety features are sufficient as are contemplated to be a part of the proposed Midland Units.
If they are not, state why not, including whether you agree with the remarks of I:r. Hendrie.
If in your answer you make reference to other than textual (exclusive of footnote) matter in the PSAR, then' set forth completely the text of each such reference or attcch a copy.
.298.
State whether your support for and your evalua-tion of the construction of the proposed Midland Uni';s relics upon the efficiency of the Iodine Removal Spray System in light of Technical Information Document 14884.
In connection with your answer, state whether if any critical assumptions set forth in the PSAR concerning your Iodine Removal Spray System are proven unsound.or unfounded, then whether you would not sup-port the construction of the proposed Midland Units.
If in your answer you make reference to other than textual (exclu-sive of footnote) matter in the PSAR, then set forth completely the text of each such other reference or attach a copy.
299. State each fact, calculation and assumption, including the criterion and design philosophy or design basis upon which you would support the conclusion that "a system to mitigate the consequences of a vessel failure due to thermal shock following a Loss of Coolant Accident is not justified."
(PSAR) p. 4-15)
In addition:
(a)
If your answer is based in whole or in part upon historical precedent, identify:
(1)
Each document which refers or relates to or demonstrates this precedent; (2)
Each oral communication which refers or relates to or demonstrates this precedent and give, regarding each such communication, the date and place thereof, the identity (by name, address, by whom employed, with what group or organization affiliated and for whom acting) of each person involved therein, and the complete _.
substance of what was said by and to each person.
(b)
If your answer is based in whole or in part upon financial, economic or engineering factors, identify:
(1)
Each document which refers or relates to or demonstrates each such factor; (2).Each oral communication which refers or relates to or which demonstrates each such factor and give, regarding each such com-munication, the date and place thereof, the identity (by name, address, by whom employed, u"ith what group or organization affiliated and for whom acting) of each person involved therein, and the completc substance of what was said by and to cach person.
If in your answer you make reference to other than textual (ex-clusive of footnote) matter in the PSAR, then set forth completely the text of each such other reference or attach a copy.
300. With respect to page 4-15 of the PSAR, state what quantitative and calculated influence the fact of proximate pop-ulation. density should have in the design of engineering safety j
systems contained in or proposed to be contained in the proposed Midland Units.
Include uithin your answer what population density wotild have to be present, in your opinion, for you not to sup-port the proposed site.
If in your answer you make reference to other than textual (exclusive of footnote) matter in the PSAR, then set forth completely the text of each such other reference or attach a copy.
301. Regarding your support and evaluation of the design and performance of the pressure vessel as described in the PSAR 3ections 3 2.2.1.7, 4.3.1., 4.3 1.1 and 4.3 9 1.1, and the possibility of adding systems to assure continued core cooling, state in detail:
(a)
What information is expected to become " avail-able in the future to demonstrate" the necessity of such a system; (b)
What information, if available, do you consider would require such a system; and (c)
Why, if such a system will add to the integrity or safety of the engineering safeguards, you have not requested that such a system be included in the present design.
If in your answer you make reference to other than textual (ex-clusive of footnote) matter in the PSAR, then set forth completely the text of each such other reference or a'ttach a copy.
302.
With respect to the radioactive waste analysis of Section 11 of the PSAR, give an estimate, specifying each fact, calculation and assumption thereof, during normal opera-tion of the proposed I:idland Units of the following: -
(a)
The quantity of each of the principal radio-nuclides expected to be released annually to unrestricted areas in liquid effluents; (b)
The quantity of each of the principal radio-nuclides of the cases, halides and particulates expected to be released annually to unrestricted areas in gaseous effluents; (c)
The range of maximum potential annual radiation doses to individuals and suitable samples of population groups in Midland and surrounding population areas or centers resulting from these releases; and (d)
The quantitative percentage contribution to the total present background dose of the dose or doses set forth in (c) above.
If in your answer you make reference to other than textual (ex-clusive of footnote) matter in the PSAR, then set forth com-pletely the text of each such other reference or attach a copy.
303. With respect to the statement in Section 3.3.3.3.3 on page 3-105 of the PSAR, state each experiment, test, fact, calculation and assumption upon which you support the conclu-sion, if you do, that "the information is essential for advance-ment of the art, but is not considered critical in the sense that all of the programs must be completed to insure safe
. operation."
Also state what you understand to be " essential for ady'ncement of the art, but not... ' critical.
." to a
safety.
If you do not support this conclusion state why not.
O.
~
If in your answer you make reference to other than textual 4
(exclusive of footnote) matter in.the PSAR, then set forth completely the text of each such other r.eference or attach a copy.
304. Describe in detail each test, including each fact, calculation and assumption thereof, mentioned at page 12-2 of Amendment No. 8 of the PSAR which will be conducted to determine. decontamination factors for each radionuclide on each piece of equipment which will be encountered by the process steam 'to be generated from the proposed Midland Units.
If in your answer you make reference to other than textual (exclusive of footnote) matter in the PSAR, then set forth completely the text of each such other reference or attach a copy.
305. With respect to item No. 12, pages 12-1 and 12-2 of Amendment No. 8 of the PSAR, describe in detail each piece of the machinery, its use and locatlon, whether contained or to be contained in a Dow, Dow Corning or Consumers Power facility, which will come in contact with the process steam proposed to be generated from the proposed Midland Units.
For each such piece of machinery describe in detail the expected rates of decontamination of each of the available radionuclides, their equilibrium concentration and the total radiation source each machine could become.
If in your answer you make reference to other than textual (exclusive of footnote) matter in the PSAR, i
.J
~ _ _ _. _
then set forth completely the text of each such other reference or attach a copy.
356. With respect to item No.12, pages 12-1 and 12-2 of Amendment.No. 8 of the PSAR, describe in detail all products and/or uses of the process steam which may cause the beholder and/or user to be exposed to radiation originating in whole or in part from the process steam.
If in your answer you make reference to other than textual (exclusive of footnote) matter in the PSAR, then set forth completely the text of each such other reference or attach a copy.
307. What limits are or will be imposed upon your expansion plans beyond which would require a review or evaluation of such expansion upon the safetly of the proposed Midland Units.
.If in your answer you make reference to other than textual (exclusive of footnote) matter in the PSAR, set forth completely the text of each such reference or attach a copy.
308. Regarding generation of processed steam for you, as described in Section 11 of the PSAR, answer the fol-lowing, specifying each fact, conclusion, and assumption upon which you base your answer:
(a)
How many insoluble tertiary heat exchanger units are provided for in the high pressure steam.section and how many of these are out i
of service under normal high pressure steam-l load to Dow;.
(b)
How many insoluble te'tiary heat exchanger r
units are provided for in the low pressure steam section and how many of these are out of service under normal low pressure steam-load to Dow; (c)
What is the normal gross gamma range in the tertiary steam supply system and at what gamma level will the tertiary steam supply system be shut down?
Include within your answer to this sub-paragraph a state-ment of the specific procedures to be followed to accompl'ish this result; and (d)
Specify each isotope and its level of radioactive concentratio2. which is expected to be in the discharge monitor tanks and controlled discharge.
At what level of radioactive concentration would you propose, if at all, to reprocess such i
radioactive waste.
If in your answer you make reference to other than textual (ex-cl.usive of footnote) matter in the PSAR, then set forth completely the text' of each such other reference or attach a copy.
309 With respect to sa.botage at the Dow plant which could or might affect the proposed Midland Units, answer the following:
(a)
What possible acts of industrial sabotage which could occur have you considered in the formulating of y.our procedures to pre-vent industrial sabotage; (b)
Have you experienced industrial sabotage 1.1 any of your facilities, whether nuclear or otherwise, which give you experience in the formulation of preventive measures; (c)
Have you made any studies with respect to industrial sabotage generally to determine whether your procedures are sufficient to prevent industrial sabotage and, if not,
. why not; and (d)
State what ccnsequences you believe could possibly occur for other than simple acts of industrial sabotage.
If in your answer you make reference to other than textual (ex-clusive of footnote) matter in the PSAR, then set forth completely the text of each such other reference or attach a copy.
310.-
Separat..ly for Applicant, Dow Chemical Company, Dow-Corning Company or any subsidiary of Dow Chemical or Dou-Corning, Babcock & Wilcox Company and Bechtel Corporation, state if they have.ever been cited for or investigated about a violation or alle;;ed violation, at any time, of the Atomic Energy Act, any of -
its rules, regulations or orders, an Atomic Energy Commission license or any of its technical specifications or the rule, order, decree, regulation of any state or other federal agency or official having any manner of jurisdiction over any of their operations which are the subject of an Atomic Energy Commission license or other Atomic Energy Commission jurisdiction.
If so, then:
(a)
Describe in detail each instance of each such citation or investigation; (b)
List and identify in sufficient detail a des-cription of each writing as defined in Inter-rogatory No. 311 below which is in your possession or control with respect to each such citation or investigation; (c)
State and describe the resolution, if any, of each such citation or investigation; and (d)
State what steps you have taken to prevent circumstances which led to each such citation or investigation from occurring again or occur-ring at the proposed Midland Units.
If in your answer you make reference to other than textual (exclusive.of footnote) matter in the PSAR, then set forth completely the text of each such reference or attach a copy.
311. List and describe in sufficient detail so that it can be identified, each document which is in your possession or'under your control which relates to, refers to or concerns any of the following:
(a)
Your participation in any way in the designing, constructing or operating of the proposed Mid-1,and Units; (b)
Your evaluation of the proposed Midland Units regarding its siting, its designing, its con-struction, its safety or its proposed operation; (c)
Financial aspects of the building, designing or constructing of the proposed Midland Units, including but not limited to the sale of pro-cessed steam, to anyone, for industrial purposes; (d)
Your decision to approve of a par ticipation in any way in the designing, constructing or secur-ing of a construction permit for the proposed Midland Units; and (e)
Any Interrogatory or answer to any Interrogatory filed herein.
As used within these Interrogatories, the word " writings" or words of similar import shall include all written, typed, i
printed and photostated matter, including photographs, duplicate w'
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originals, carbon copies, Thermofax copies, photostatic copies and other copies thereof, including drafts thereof, in your possession, custody or control, written, made, delivered or received at any time up to and including March 22, 1971, including, without limiting the generality of the definition, all correspondence, telegrams, memoranda, minutes of meetings, client memoranda, account cards, leases, documents of title, receipts, canc.elled checks, bank statements, records of tele-phona calls, summaries of meetings, agreements, contracts and notes, whether formal or informal.
At your option, depending upon convenience to all other parties thereof, instead of answering this Interrogatory you may choose to follow either the suggestion made in a let-ter by Myron Cherry to all counsel dated March 8, 1971, or the more formal method of depositions under oath.
If you do not so choose by notice to us within ten days after receipt of these Interrogatories, you shall be required to answer this Interrogatory.
Finally, this Interrogatory or any other alternative methods of identifying relevant writings are not intended to call for writings which are subject to a valid privilege; however, you shall be required to describe generally the 9.
~.
,..,s
uritings ac to which you may claim privilege in order that opportunity for argument thereon may be had.
Saginaw Valley Nuclear Study Group Citizens Committee for the Environ-mental Protection of Michigan Sierra Club United Auto Workers of America Trout Unlimited West Michigan Environmental Action Council, Inc.
Environmental Law Society of the.
University of Michigan Law Students h
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I,;
f'
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By
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Myron FL.
Cherry, their' attor ey Dated:
March 22, 1971.
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11EFORt. T!!E UNITED STATES OF AMERICA ATOMIC ENERGY COMMISSION In the Matter of
)
)
CONSUMERS POWER COMPANY)
Docket Nos. 50-329 '
(Midland Plant, Units 1 and 2 )
50-330
)
/
' q CERTIFICATE OF SERVICE
,s,
,i,
.. V I HEREBY CERTIFY that copies of the attached INTERROGATORIES TO APPLI-CANT were mailed, postage prepaid, to the following law firms on the 22nd day of Ma rch, A. D. 1971:
RICHARD G. SMITH. ESQ.
SMITH & BROOKER, P. C.
730 Washington Avenue Bay City, Michigan LOWENSTEIN AND NEWMAN 1100 Connectu.at Avenue, N.
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Washington, D. C. 20036 Attorneys for Applicant Consumers Power Company I FURTHER CERTIFY that copies of INTERROGATORIES TO APPLICANT were mailed, postage prepaid, to the following individuals on the 23rd day of March, A.D.
1971:
ARTHUR W. MURPH,X ESO.
Dr. CLARK GOODMAN Chairman, Atomic Safety and Professor of Physics Licensing Board University of Houston Columbia University School of Lav 3801 Cullen Boulevard Box 38, 435 West 116th Street Houston, Texas 77004 New York, New York 10027 JAMES A. KENDALL, ESQ.
Dr. DAVID B. HALL 135 N. Saginaw Road Los Alamos Scientific Laboratory Midland, Michigan 48640 P. O. Box 1663 Los Alamos, New Mexico 87544 ANTHONY Z. ROISMAN, ESQ.
BERLIN, ROISMAN, AND KESSLER THOMAS F. ENGELHARDT, ESQ.
1910 N. Street, N. W.
U. S. ATOMIC ENERGY COMMISSION Washington, D. C. 20036 Wa shington, D. C. 20545
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MILTON R. WESSEL, EEO.
JAMES N. O'CONNOR, ESO.
KAY, SCHOLER, FIERMAN, HAYS THE DOW CHEMICAL COMPANY AND HANDLER 2030 Center 425 Park Avenue Midland, Mich.gan New York, New Y.tk 10022 MYRON M. CHERRY, ESO.
ALGIE A. WELLS, ESQ.
111 West Monroe Street Chairman, Atomic Safety and Chicago, Illinois 60603 Licensing Board Panel U. S. ATOMIC ENERGY COMMISSION Washington, D. C.
STANLEY T. ROBINSON, JR.,
Chief, Public Proceedings Branch Office of the Secretary of the Commis sion U.S. ATOMIC ENERGY COMMISSION Washingtan, D. C.
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' ' WILLIAM J. GJN5fER-Attorney for Napleton Intervenors, I
Dated: March 23, A. D.1971.
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Docket Nos. 50-32?
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CoriSlJMI:HS POWER. COMPANY) e
..Mielland Plant,Jilnits I and 2)
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50-330
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h4 INTERROGATORIES TO APPLICANT 5.
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TO: RICHARD G. SMITJI, 'Esq.
LOWENSTEIN AND NEWMAN
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SMIT 11 &ROOKER,' P. C., 1100 Connecticut Avenue, N. W. 74 730 Washington-Avenue Washington, D. C. 20036 M*3 13ay City, Michigan. s ., Atto rneys for> Applicant
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,, { - Consumerb Pm.ier Co. ~ ' w y: M ~ PLEASE TAKE NOT. ICE that the foHowing interrogatories are directed to the applicant, Consumers Power ~Co.:. n,gg n., y{ Does Conrumers P6wer. Company and/ot Dow Chemical Company have a present plan 1. to make a futttre 4pplicatiim to the Michigan Water Resources Commission to construct a dam across the Tittahawastcc River for' the purpoen of creating a reservoir should a con-3P struction per~mit,and/or: operating license he granted by the AEG? , w '~"M Y 2. What comp.ments of'gd o ts effhtents will be discharged into the atmosphere'from the - . operation of. the proposed plants? .sv 4(.f Can the applicantialasolvtely guarantee that release of radioactive effluents (gases, 3 steam and waste licat) into the air at the site of the propose <1 nuclear plants will not accurn. W ulate and be ha::a rdmis to' human health?- W
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'Q 4. Has the applicant made a detailed study of meteorological conditions in the Saginaw g Valley for th' past ten years? c ~, hf 3 -a. If Llye answer to No. 4 is "yes"; is such data available for inspection? W J u ~K .b.... linder whose custody. and cons.rol and where located? ?M ~ rj ' g 5.7 Have any scientific, calentations.been made by the applicant as to the frequency and M degree of; fogging canditions which are likely t, be creattd by the operation of the proposed % ' plants, shoisld a cn,n::truction permit and/or, operating license be granted by the AEC? l l J ,l n% g V."* ~i. c f, * <> s,.. -l~ gg <y . ~ ~ f-1 r;, f a 7". - [ y WILLIAM '.l. GINSTER, 1 W,s e>'.,. ~1; . Attorney for Mapleton Intervenors, t. c .y ;, c-F~ ..' -~~L. . ; Q. J '; - x y .; Dated: Ma reh. 22, 'A. D. f)71.- i-n , y:f-4 : g ):q y :yy n L.., g@gww 7_ _ %,.gghd 8 W $[;h5;y[h [d b kh,f h hbkkk$ d k /hA5}}1p*Wir&&M?M#"fMT@[T bs%iffEMM#dNSNM}}