ML19331B078

Response to Saginaw Intervenors' First Set of Interrogatories.Objects to Interrogatories 1-19.Dow Chemical Co Position Re Interrogatories 20-22 Stated in Statement of Position & Addendum to Statement of Position

ML19331B078
Person / Time
Site:	Midland
Issue date:	04/26/1974
From:	Gleeson J DOW CHEMICAL CO.
To:
References
NUDOCS 8007250774
Download: ML19331B078 (5)

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b*Yf636 April 26, 1974 UNITED STATES OF AMERICA ATOMIC ENERGY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In The Matter of X X

CCNSUMERS POWER COMPANY X Construction Permits Nos. 81 X 82 (Midland Plant, Units 1 and 2)X i

RESPONSE TO FIRST SET OF INTERROGATORIES .

DIRECTED TO DOW CHEMICAL COMPANY l

The Dow Chemical Company presents the following in response to the written interrogatories propounded by the Saginaw group pursuant to Section 2.7406.

PREFACE While Dow has made varied objections to many of the interrogatories propounded by the Saginaw group, it wishes

. to make it clear from the outset that Dow has satisfied itself that it was in all ways proper to enter into the contract with Consumers Power Company relating the Midland l l

Nuclear Facility, and that had Dow not been so satisfied, it l would not have entered into the said contract. l l

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RESPONSE TO INTERROGATORIES

1. Dow objects to the contents of the first interrogatory.

This question attempts to solicit conclusions and opinions from Dow which are not only totally irrelevant, but quite outside the quality assurance issues specified in the order to show cause.

2. Dow objects to the contents of interrogatory 2.

Dow's bases for objecting are those set forth in the response to interrogatory number 1, and, in addition, Dow points out the non sequitur of making comparison between construction of non-nuclear facilities and construction of nuclear power facilites. .

3. Dow objects to the contents of interrogatory 3 for

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reasons set forth in the response to interrog5' tory number 1.

In addition, Dow specifically objects on the basis that it is not undertaking any responsibility in the area for quality assurance and quality control at the Midland Nuclear Facility.

Dow is not qualified for such an undertaking, insofar as it presently lacks the proper analytical, scientific and other facilities and personnel necessary to such an endeavor.

4. Dow objects to the contents of interrogatory 4.

Dow's reasons for objection are those set forth in response to interrogatory number 1.

S '. .Dow objects to the contents of interrogatory 5.

Its bases for such objection are set forth in answers to interrogatories 1, 2 and 3.

6. Dow objects to the contents of interrogatory 6.

The bases for such objection are set forth in the responses to interrogatories 1, 2 and 3.

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7. Dow objects to the contents of interrogatory 7.

The bases for this objection are set forth in responses to interrogatories 1, 2 and 3. Dow further objects on the basis that, in addition to this question being irrevelant and immaterial, it is also duplicitive since the information therein sought is information already in the possession of Consumers Power Company and the regulatory staff.

8. Dow objects to the contents of interrogatory 8.

The bases for such objection are set forth in the responses to interrogatories 1, 2 and 3.

9. Dow objects to the contents of interrogatory 9.

The bases for such objection are set forth in the responses .

to interrogatories 1, 2 and 3. Dow again points out that it is not undertaking any responsibility in quality assurance or quality control. Dow lacks such capability at present, and does not intend to act in a supervisory manner in respect to the construction of the Midland Nuclear Facility.

10. Dow objects to the contents of interrogatory 10.

The bases for such objection are set forth in responses to interrogatories 1, 2, 3, and 9.

11. Dow objects to the contents of interrogatory 11.

The bases for such objection are set forth in the answers to interrogatories 1, 2, 3 and 9.

12. Dow objects to the contents of interrogatory 12.

The bases for such objection are set forth in the answers to interrogatories 1, 2, 3 and 9.

13. Dow objects to the contents of interrogatory 13.

The bases for such objection is that the question calls for information that is totally irrevalent and outside the scope of the order to show cause.

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14. Dow objects to the contents of interrogatory 14.

The bases for such objection has been set forth.in the answer to interrogatory 3.

15. Dow objects to the contents of interrogatory 15.

The bases for such objection have been set forth in the responses to interrogatories 1, 2 and 3.

16. Dow objects to the contents of interrogatory 16.

The bases for such objections have been set forth in the responses to interrogatories 1, 2 and 3.

17. Dow objects to the contents of interrogatory 17.

The bases for such objections have been set forth i.n the .

responses to interrogatories 1, 2 and 3.

18. Dow objects to the contents of interrogatory 18.

The bases for such objections have been set forth in the responses to interrogatories 1, 2 and 3.

19. Dow objects to the contents of interrogatory 19.

The bases for the objection have been set forth in the response to interrogatory 3.

20. Answering interrogatory 20, Dow points out that at present, it does not plan on presenting any witnesses at the proceeding. Dow's position in this respect has been set forth in its Statement of Position and the Addendum to its Statement of Position.

21. Answering question No. 21, Dow states ther at present it is not planning to introduce any documentary evidence at the proceeding. At present Dow plans on maintaining its position as set forth in' the above referenced Statement of Position and Addendum to Statement of Position.

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22. In response to question 22, Dow incorporates by reference its Statement of Position and Addendum to Statement of Position, both as expanded on at the pre-t:onference hearing.

I Date 79 THE DOW CHEMICAL COMPANY l

By ,

John Ge ald Glees n, ,

Attor STATE OF MICHIGAN )

COUNTY OF MIDLAND ) .

This day before me appeared John Gerald Gleeson, who, being duly sworn, deposes and says that he has read the Response to Interrogatories by him signed, and that they are true except as to those matters stated to have been answered on information and belief, and as to those matters, he believes them to be true.

Date e s < :2 .:' O sc 74 5 ,-, a 7), 8 L>,b. n.a.<_ )

Notary Public

, d.r Co,unty, Michigan aes,sa <n .w p c~~ a L 4 My Commission ExpiresJ.ra. m ifr/.

PXTRIC!A' M. DEMMLANDET Notary Public, Cay County, Mich!;2:x heting in Midland County My Ccmminion E: -1 > : octuber 16, D77 I

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