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Category:INTERROGATORIES; RESPONSES TO INTERROGATORIES
MONTHYEARML20078N9451983-10-27027 October 1983 Responses to 831011 Interrogatories.Questions 1-5 Will Be Answered at Later Date.Certificate of Svc Encl.Related Correspondence ML20078M1581983-10-20020 October 1983 Objections to 831011 Interrogatories & Document Production Requests.Certificate of Svc Encl ML20078K3221983-10-13013 October 1983 Errata to Instructions for Interrogatories & Requests for Production Filed on 831011.Related Correspondence ML20080R1771983-10-11011 October 1983 Request for Production of Documents.Certificate of Svc Encl ML20080R1591983-10-11011 October 1983 Interrogatories Re Ofc of Investigations Rept.Certificate of Svc Encl ML20080R4041983-10-11011 October 1983 Request for Production of Documents.Certificate of Svc Encl ML20078J3491983-10-11011 October 1983 Interrogatories Directed to Util.Certificate of Svc Encl ML20073R7191983-04-28028 April 1983 Renewed Amended Objections to Interrogatories Directed to Util on Zack Issues & Renewed Motion for Protective Order. Certificate of Svc Encl.Related Correspondence ML20073P9991983-04-22022 April 1983 Request for Production of Documents.Certificate of Svc Encl.Related Correspondence ML20073B7051983-04-0808 April 1983 Second Set of Interrogatories.Certificate of Svc Encl ML20073B8011983-04-0808 April 1983 Third Set of Interrogatories.Certificate of Svc Encl ML20072T4811983-04-0707 April 1983 Request for Production of Documents,Per ASLB 830406 Order. Certificate of Svc Encl ML20064C7481982-12-29029 December 1982 Responses to 821126 Discovery on Stamiris Cost/Benefit Contention.Certificate of Svc Encl ML20067C5061982-12-0202 December 1982 Interrogatories Re Nonfuel Operation & Maint Cost Considerations.Related Correspondence ML20067A8601982-11-26026 November 1982 Interrogatories & Request for Production of Documents on Stamiris Cost/Benefit Contention,Per ASLB 821029 Memorandum & Order.Related Correspondence ML20067A8551982-11-26026 November 1982 Interrogatories & Request for Production of Documents on Stamiris Cost/Benefit Contention,Per ASLB 821029 Memorandum & Order.Related Correspondence ML20063N7561982-10-0606 October 1982 Response to Request for Production of Documents ML20065C0981982-09-22022 September 1982 Interrogatories on Contentions 6,8 & 16.Related Correspondence ML20065C1331982-09-20020 September 1982 Interrogatories on Zack Issues Re Sinclair Contentions 6,8 & 16.Certificate of Svc Encl.Related Correspondence ML20065C1401982-09-20020 September 1982 Response to 820830 Second Set of Interrogatories.Related Correspondence ML20065C1081982-09-20020 September 1982 Response to 820830 Interrogatories.Certificate of Svc Encl. Related Correspondence ML20071M5451982-09-18018 September 1982 Response to 820830 Interrogatories & Document Requests. Related Correspondence ML20071M5561982-09-18018 September 1982 Response to 820831 Interrogatories.Related Correspondence ML20071M8641982-09-17017 September 1982 Objections to 820913 Second Set of Interrogatories Based on New Info.Interrogatories Do Not Pertain to Any Admitted Contention & Are Untimely.Certificate of Svc Encl ML20063N1941982-09-14014 September 1982 Response to Requests for Admission of Truth of Relevant Matters of Fact.Related Correspondence ML20069D5531982-09-13013 September 1982 Responses to 820814 Discovery Questions Based on New Contentions Accepted by ASLB Order.Certificate of Svc Encl ML20027B2621982-09-13013 September 1982 Discovery Based on New Info in Fes.Related Correspondence ML20027B2531982-09-13013 September 1982 Second Set of Interrogatories Based on New Info.Related Correspondence ML20063J3611982-08-30030 August 1982 First Set of Interrogatories.Certificate of Svc Encl. Related Correspondence ML20063J3521982-08-30030 August 1982 Request for Production of Documents.Certificate of Svc Encl. Related Correspondence ML20063M2781982-08-30030 August 1982 Interrogatories & Document Requests Re Contentions on Cost/Benefit,Qa,Effects of Dewatering & Independent Design Audit.Related Correspondence ML20063J3381982-08-30030 August 1982 Request for Production of Documents.Certificate of Svc Encl. Related Correspondence ML20063J2431982-08-30030 August 1982 Second Set of Interrogatories.Certificate of Svc Encl. Related Correspondence ML20065H7161982-08-30030 August 1982 Request for Admission of Truth of Relevant Matters of Fact Re Contention 5.Certificate of Svc Encl ML20063J7441982-08-25025 August 1982 Discovery Questions on New Contentions Accepted by ASLB 820814 Order.Related Correspondence ML20063N1961982-08-14014 August 1982 Objections to Certain B Stamiris 820830 Interrogatories & Document Requests.Certificate of Svc Encl.Related Correspondence ML20058E5741982-07-28028 July 1982 Partial Responses to 820618 Interrogatories.Certificate of Svc Encl ML20063G6781982-07-28028 July 1982 Reply to First Set of Interrogatories.Certificate of Svc Encl ML20054L5221982-07-0202 July 1982 Response to CPC First Interrogatories.Related Correspondence ML20054H5841982-06-18018 June 1982 Discovery Questions Pursuant to ASLB 790226 Special Prehearing Conference Order.Proof of Svc Encl.Related Correspondence ML20054G4661982-06-16016 June 1982 First Set of Interrogatories.Certificate of Svc Encl ML20054G4531982-06-16016 June 1982 First Set of Interrogatories.Certificate of Svc Encl ML20078K1951982-05-12012 May 1982 Response to Interrogatory IV Re Contention 8 on Independent Design Audit ML20005C1751981-11-11011 November 1981 Request for Admission of Genuineness & Authenticity of Encl Audit Repts.Related Correspondence ML20009B6331981-07-10010 July 1981 Correction to Interrogatory Response to B Stamiris 810114 Discovery Request 9.Certificate of Svc Encl.Related Correspondence ML20005B4121981-06-30030 June 1981 Reply to B Stamiris Answers to Util Interrogatories Re Contention 2 on Soil Settlement Issues.Certificate of Svc & Affidavit Encl ML19350E2701981-06-10010 June 1981 Supplemental Responses to NRC 801126 Interrogatories Re Extent of Design Safety Margins,Wall Footing Design, Structural Analyses & Diesel Generator Bldg Analysis. Affidavit & Certificate of Svc Encl.Related Correspondence ML20004E5081981-06-0303 June 1981 Request for RO Documents Directed to Applicant ML19346A2271981-05-27027 May 1981 Responses to B Stamiris Discovery Requests Re Bldg Const,Per ASLB 810508 Order.Affidavits & Certificate of Svc Encl. Related Correspondence ML19347D8851981-03-30030 March 1981 Response to Intervenor B Stamiris 810114 Interrogatories. Provides Info Re IE Insp Repts 50-329/78-12 & 50-330/78-12, Audits Re Soil Settlement & Administration Bldg.A Boos & N Swanberg Affidavits Encl.Related Correspondence 1983-04-08
[Table view] Category:LEGAL TRANSCRIPTS & ORDERS & PLEADINGS
MONTHYEARML20070E4671991-02-26026 February 1991 Comment Opposing Petition for Rulemaking PRM-73-9 Re Upgrading Design Basis Threat for Radiological Sabotage of Nuclear Reactors.Recommends That NRC Deny Petition to Increase Design Basis Threat for Security ML20207C1331986-12-18018 December 1986 Order Terminating CPPR-81 & CPPR-82,per Util 860711 Motion to Withdraw Applications for OLs ML20215E7301986-12-17017 December 1986 Memorandum & Order Authorizing Withdrawal of OL Application & Dismissing OL Proceeding,Per Applicant 860711 Motion. Served on 861218 ML20215B2071986-12-11011 December 1986 Responds to Questions Posed in ASLBP 861203 Memorandum & Order Re Conversion to gas-fired Facility.Imposition of Conditions on Withdrawal of OL Application Unnecessary. Certificate of Svc & Svc List Encl ML20211L6391986-12-11011 December 1986 Affidavit of Gb Staley Re Preparation of Answers to Board 861203 Questions on Termination of OL Proceeding. Certificate of Svc Encl ML20211L6181986-12-11011 December 1986 Response to Board 861203 Questions Re Util Request to Terminate OL Proceeding ML20214Q4431986-12-0303 December 1986 Memorandum & Order Granting Motion to Expedite Completion of Withdrawal Proceedings & Posing Questions to Parties.Served on 861204 ML20214G7941986-11-24024 November 1986 Motion to Expedite Completion of Withdrawal of Licensee OL Application & Terminate Pending OL & CP Mod Proceedings. Certificate of Svc Encl ML20214T7361986-09-26026 September 1986 Memorandum & Order Dismissing OM Proceeding as Moot & Deferring Action on Applicant Motion for Authorization to Withdraw OL Application Pending NRC Preparation of Environ Assessment.Served on 860929 ML20212M7661986-08-25025 August 1986 Response to Util 860711 Motion for Authorization to Withdraw OL Application & for Dismissal of OL & Order of Mod Proceedings.Board Should Hold Motion in Abeyance Pending NRC Review of Stabilization Plan.Certificate of Svc Encl ML20206M8171986-08-15015 August 1986 Response to ASLB 860716 Order Requesting Responses Re Termination of OM Proceeding.Termination of OL Proceeding & Withdrawal of OL Application Requested.Om Proceeding Should Be Considered Moot.Certificate of Svc Encl ML20212B0311986-08-0101 August 1986 Memorandum & Order Withdrawing Retention of Jurisdiction Over Radon Issue Presented in Facility CP Proceeding & Vacating ASLB Partial Initial Decision on Remedial Soils in Consolidated CP Mod & OL Proceeding.Served on 860801 ML20212B0521986-07-31031 July 1986 Order Extending Time Until 860815 for Util & Other Parties to Respond to Questions Posed by 860716 ASLB Order.Time Extended Until 860825 for NRC Response to ASLB Questions & Util Motion.Served on 860801 ML20203F8791986-07-28028 July 1986 Response Supporting Util 860711 Motion for Termination of Appeal Board Jurisdiction Over Proceeding.Certificate of Svc Encl ML20207H6871986-07-22022 July 1986 Motion for Extension Until 860815 to File Responses to Four Questions Re Util Motion to Dismiss OL & OM Proceedings. Certificate of Svc Encl ML20207E2851986-07-16016 July 1986 Order Presenting Questions in Response to Util 860711 Motion to Dismiss OL Proceeding & to Terminate Order of Mod Proceeding.Served on 860717 ML20202G1621986-07-11011 July 1986 Notice of Change of Address for Washington Ofc of Isham, Lincoln & Beale,Attys for Util.Certificate of Svc Encl ML20202G0121986-07-11011 July 1986 Motion for Authorization to Withdraw OL Application & Dismissal of OL & Order of Mod Proceedings ML20202G1201986-07-11011 July 1986 Motion for Termination of Aslab Jurisdiction to Facilitate Termination of Cps,Withdrawal of OL Application & Dismissal of Consolidated OM-OL Proceeding ML20202G0491986-07-10010 July 1986 Affidavit of JW Cook Re Conversion of Plant Into combined- cycle,gas-fired Power Plant.Plant Never Operable as Nuclear facility.Nuclear-related Equipment Will Be Sold ML20202G0281986-07-0808 July 1986 Affidavit of Ta Mcnish Re True & Correct Extracts of 860408 & 0618 Minutes of Meetings.Resolutions Recited Therein in Full Force & Effect ML20198J3861986-05-27027 May 1986 Notice of ASLB Reconstitution.C Bechoefer,Chairman & J Harbour & Ga Linenberger,Members.Served on 860529 ML20198J4651986-05-27027 May 1986 Notice of ASLB Reconstitution.C Bechhoefer,Chairman & J Harbour & Ga Linenberger,Members.Served on 860529 ML20137E0041985-11-21021 November 1985 Notice of Appearance in Proceeding ML20137D9651985-11-21021 November 1985 Notice of Withdrawal of Appearance in Proceeding.Certificate of Svc Encl ML20133F6421985-10-0909 October 1985 Notice of Withdrawal of Appearance in Proceeding.Certificate of Svc Encl ML20134N3771985-08-30030 August 1985 Notice of Withdrawal of Appearance in Proceeding.Certificate of Svc Encl DD-84-17, Order Affirming 840724 Director'S Decision DD-84-17 Denying Bp Garde 10CFR2.206 Petition for Action Against Util Re Plant Const.Const Abandoned on 840910.No Further Enforcement Action Required.Served on 8506241985-06-24024 June 1985 Order Affirming 840724 Director'S Decision DD-84-17 Denying Bp Garde 10CFR2.206 Petition for Action Against Util Re Plant Const.Const Abandoned on 840910.No Further Enforcement Action Required.Served on 850624 ML20127N7591985-06-20020 June 1985 Transcript of Commission 850620 Affirmation/Discussion & Vote in Washington,Dc Concerning Denial of 2.206 Petition for Midland plant,SECY-85-60 Concerning Pressurized Thermal Shock Rule & Shoreham Order.Pp 1-4 ML20133D9481985-05-13013 May 1985 Response to Aslab 850423 Order.Aslab Should Cancel OL Application & CPs Because Compliance W/Nrc Basic Requirements Not Met ML20116G5181985-04-29029 April 1985 Response to Memorandum of City & County of Midland,Mi Re ASLB 850405 & 0313 Orders on CP Mod Proceedings.Bechtel Should Not Be Granted Admission to Proceedings ML20115J5551985-04-19019 April 1985 City & County of Midland,State of Mi Response to Aslab 850313 Order to File Memoranda Re Whether Aslab Should Vacate ASLB Decision Re Certain Mods to CP Due to Mootness. Proof of Svc Encl ML20115J4751985-04-19019 April 1985 Memorandum in Response to Aslab 850405 Order Re Dismissal of OL Application.Application Neither Abandoned Nor Delayed in Dilutory Manner.Certificate of Svc Encl ML20115J5501985-04-19019 April 1985 Response Opposing Aslab 850405 Memorandum & Order Re Dismissal of OL Applications.Urges Board to Permit OL Applications to Continue in Suspension Until Applicant Affirmatively Resolves Disposition ML20116G5321985-04-19019 April 1985 Motion to Participate as Amicus Curiae in Resolution of Issue to Involuntary Dismissal of License Application,Per Aslab 850405 Memorandum & Order.Granted for Aslab on 850422. Served on 850429 ML20115J4351985-04-19019 April 1985 Motion for Leave to Participate as Amicus Curiae,Per Aslab 850313 & 0405 Memoranda & Orders Requesting Response to Questions Re Proceeding ML20115J5461985-04-19019 April 1985 Motion to Participate Amici Curiae in Resolution of Issue of Involuntary Dismissal of License Application as Identified in Aslab 850405 Memorandum & Order ML20115J5421985-04-19019 April 1985 City & County of Midland,State of Mi Motion for Leave to Participate as Amicus Curiae in Aslab Request for Responses to Questions Presented in 850313 & 0405 Memoranda Orders. Proof of Svc Encl ML20112J5281985-04-0101 April 1985 Memorandum in Response to Aslab 850313 Order LBP-85-2. Decision Should Not Be Vacated.Ol Should Be Dismissed.Based on Listed Changes,New OL Review Required ML20112J6301985-04-0101 April 1985 Memorandum Requesting Aslab Not Take Any Action to Vacate LBP-85-2 or Dismiss OL Applications,Per 850313 Order,Based on Current Intent to Hold CPs & Attempt to Sell Plant. Certificate of Svc Encl ML20112H0981985-03-27027 March 1985 Response to Aslab 840313 Order Re Whether ASLB Decision to Review Issues in Soils Hearing Appropriate Use of Public Resources.Concurs W/Decision to Remand OL W/Instructions to Dismiss OL Application for Failure to Pursue Soils Issue ML20106F6531985-02-0808 February 1985 Response Opposing Intervenor B Stamiris 841224 Motion for Evidentiary Hearings Re Litigation Between Applicant & Dow Chemical Co.Supporting Documentation & Certificate of Svc Encl ML20106D6631985-02-0808 February 1985 Response Opposing B Stamiris 841224 Pleading Requesting Evidentiary Hearing on Matter Raised in applicant-Dow Chemical Trial & Referral of Certain Matters to Ofc of Investigations.Certificate of Svc Encl ML20101S9111985-02-0101 February 1985 Motion for Extension of Time within Which to File Notice of Appeal of ASLB 850123 Partial Initial Decision.Certificate of Svc Encl ML20101S9421985-02-0101 February 1985 Motion for Extension Until 850306 to File Notice of Appeal of ASLB 850123 Partial Initial Decision.Granted by Aslab on 850201 ML20101F3191984-12-24024 December 1984 Request for Evidentiary Hearings on Matter Raised in CPC-Dow Trial & Referral of Certain Matters to Ofc of Investigations.Certificate of Svc Encl ML20107K8011984-11-0101 November 1984 Affidavit of Jd Selby Re Plans Concerning Facilities.Const Will Be Resumed Only If Proposed by Appropriate Governmental Agencies & Officials & If Funds from Some Other Source Become Available.Related Correspondence ML20106F5241984-10-24024 October 1984 Motion to Request ASLB to Cancel Const License & Application for OL ML20092J0241984-06-22022 June 1984 Reply to B Stamiris Second Supplemental Proposed Findings of Fact & Conclusions of Law on QA & Mgt Attitude Issues. Certificate of Svc Encl ML20092J0361984-06-22022 June 1984 Reply to NRC Further Supplemental Findings of Fact & Conclusions of Law Re QA 1991-02-26
[Table view] |
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N 2800. & Ull! EAG. 8. N - d/,9 + -
- ^ g 30CIETED April 2:< , 1974 & WEC ,
3 UNITMU STATH:; OF M1 ERICA 6" APR2 S 1974" ATOMIC ENERGY COMMISSION ep,{*,',y]$7' q -
tan BMFORE Tild ATO*IIC SAFETY AND - 1.ICENSIMC COI.R n, ,,, g In The Ma.tter of ) -
)
CONSUMERS PbMER COMPMPI ) Construction Permits Nos. 81
) 82 (Midland Plant, Units 1 and 2). )
PIRST SET OF INTERROGATORIES DIRECTED TO DOpl CIIEMICA'. COMPANY Pursuant $to.3cction 2.740b, Dow Chemical company is requested to answer the 'following interrogatories timely, separ- .
ately, in writing and, under -oath. ,
't
- . DEFINITIONS :
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- 1. As used in those interrogatories the wora document, documentary informati'on, 'or word of similar import is to be inter- l preted in the~ broadest possible manner and.is to include, with-out limitation, documents, writings, reports, studies, analyses, ,
1
. memoranda, communications, letters, summaries, ropeets of tele- !
i phonc conversations or meetings' and as to cach of those ca tegorics, 1
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l i I
. 8007316 Q ,
7
7, whether draft or final, formal or informal, accepted or ' rejected, sped'or.mimcographed or xeroxed, handwritten, and is also to 'in-
- clude' 'copics , however reproduced, of all such categories.
- 2. :In connection .with your answer to each category, and
.unless the facts are stated in your answer, include within your-answer the' facts upon . vhich you rely for your answer. This direc-tive- is meant to preclude answering any interrogatories with "yes"
<n: "no"'and requests that you set forth the facts upon which you base any such answer. Unicss otherwise stated, cach answer calling for' information concerning Consumers Power Company is intended to call .for .information concerning each of its activities which are or may be subject - to regulation by the Atomic Energy' Commission.
In the event that you . object to providing information for other than tho Midland. power facili*ty, please supply thc information for the Midla~nd Cacility and stalc your reasons you believo:infor-mation.au-to Dig. Rock,. Palisadua, Permi-1 and Quanicanuce are not
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relevant: or1 appropriate to tho . issues which are subject to this .
. proceeding.- In . connection with the answer to cach~~of thcsc inter- f f
-t "A"
w
rogatories, identify th'e names nndLaddresses of persons 'having
. knowledge of the facts set forth (if different), the names and addresses of persons who participated in the preparations of or prepared each of said answers. ~
o.
-INTERROGATORIES
- 1. Recently you have renegotiated your agreements with Consumers Power Company. To what extent were you influenced.
in your renegotiation by the difficulties which Consumers Power i
Company has had in constructing the Midland facility, or in y operating the Big Rock and/or Palisades facility. This inter-rogatory is intended to solicit your opinion as to whether your '
decision'to maintain your own facilities for the production of L
steam or electricity, whether on a primary or standby basis, had ;
anything to do, whether in whole' or in part,, with such difficulties of Consumers Power Company and' is specifically intended to solicit your concern, if any, as to the method and manner by which Consumers Power Company is constructing or operating any of its facilities.
e 3
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- 2. Based upon your knowledge of' the activities of the Midland facility and your own experience in constructing facilities have you formed an opinion as to the compentency of Consumers Power Company to property construct and/or operate a nuclear power facility. If not, state why not and if yes, set forth your answer including underlying facts in
-reasonable detail. - -
- 3. Identify and describe in detail the following:
(a) Set forth the names and addresses of each per-son within your organization who has responsi-bility,_whether analytical, original or liaison, for protecting the Company's interests in con-nection with the Company's relationship with '
Consumers Power Company dealing with the Midland .
nuclear power facility; (b) Identify the categories and classifications of !
documents which you maintain in your possession dealing with:
, l (i) your relationship with Consumers Power '
Company regarding the Midland plant, ;
(ii) environmental or safety aspect of the pro-posed Midland plant; (iii) - Qu'ality Assurance and Quality control at
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the Midland facility; t
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(iv) : discussions concerning the competence and reliability of Consumers Power Company'at
- the Midland or any other facility; and:
_(v) any other definable Leategory -shich relates to-the Midland facility. If possible,-in -
connection ~with this answer, identify the documents within each category _ sufficient sol that: they may be subject to a motion to produde.
-(c) 'The names and addresses of persons, if _ any, with-in-your~ organization or outside your organization who have done an analysis of the capability;of Consumers Power Company properly to contruct or
, operate -a nuclear facility including but not limi- ,
.ted to the area of Q.A.-Q.C.
4.. _ Explain in detail'the reasons why your Company with- -
drew as- an intervenor before the United States ccurt of Appeals for the District of Columbia in the case which is1 reviewing an earlier decision by. the Atomic' Energy Commission to permit con-struction of the Midland facility. ,
- 5. Describe -in detail each irrevocable commitment which you have made in your agreements with. Consumers Pcwer Company con-cerning the Midland facility. - Irrevocable commitment means one
.which lif not executed would re'sult in your Company being liable
- for breach of' contract,i some penalty of som"e lfo'rfeiture . Relate ..
your answeritofthe_most recent' contracts between your Company.and.
' Consumers; Power Company.
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6 '. Do you;believe that Quality Assurance and Quality Control.at.the Midland ! facility should be controlled or reviewed- . <
.l' by~an' organization-independent from' Consumers Power Company, Bechtel. [l or;the. Atomic Energy Commission. If not, state Why not in light of the' historical problems which consumers 1-awer Company and-Bechtel have- had at Midland,and' Palisades and the fact that une f
- s Atomic Energy commission can only inspect.1-2% of construction ~!
..actiivity at any-_ given nuclear facility.
Identify and list each communication relating.to i 7.- ,
Quality Assurance, Quality . Control and/or the method of construc-tion or proposed operation-at the Midland facility which you have sent to anyone or-received from'anyone (including inter-office
- memoranda) at any: time from December 12,-1972, to the present.
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- 8. Define the.words " compliance with quality assurance . -l i regulations" as 'those -words are employed and as you understand i them:in-the Commission's Show Cause order in this proceeding. In-.
clude_ with your answer each fact which you claim must exist in-
. order to'i::onclude . that . compliance with quality; assurance regula--
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4 tions exists. ;
4 9..
Have' you ' concluded' that Consumers" Power ( ompany' is' i in' compliance with quality-assurance regulations concerning each 'E
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' . of eitsi facilitics . ' If. you havo, . please . set forth the regulations l
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4with which you asscrt that- Consumers- Powor Company- is in compliance ..
and ?statd. Leach fact- upon which you base -your . judgment.s h .-
9 .-; g e
910. Have you ever concluded that'Consumcrs' Power Company
-i's not in . compliance with Quality Assurance regulations in con- .
hection with any of its facilities. If 'so, please setforth each '
fact upo'n which you base your judgment cogether with each relevant o
regulation,
- 11. Have you concluded that there is reasonable assurance that Consumers Power Company will be able to comply with quality assurance regulations through the construction process in Midland.
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If you have, please state each' fact upon which you base. your con-clusion. Include within your answer whether you have_ considered the activities of Consumers Power Co.apany at any of its other facil- -
ities and if not, state why not.
12 :
Have you ever concluded that there is no reasonable
. assurance that . Consumers Power Company will comply with quality assurance regulations during the -construction of the Midland facil-ity.' If so, please set forth each fact upon which you' base your
- answer. :In connection with your . answer, state whether you have
- l. - ever considered in connection with your conclusion any activities i
of 'Consumcrs Powcr Company at any othcr facility and if not, state 2
why not. -
13..'In-your' judgment,1which ,of the following_is respon- 1 sible Jfor assuring reasonable assurance with Q. A.-Q.C. regulations
- at the1 Midland plant facility:
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(a) Consumers Pswer Company;- '
_( b) Certain named individuals at Consumers
-Power _ Company; .
e (c) Be chtel Corporation;
,(d) Certain named individuals at Bechtel Corporatien-(e) Atomic Energy Commission or any part thereof; and (f) Certain named: individuals at the Atomic l Energy Commission or any part thereof.
Please explain your answer in detail.
- 14. Identify i'n connection with each of consumers Power Company facilities as set forth in the definitional section each !
i document ever received or reviewed,.each meeting'you have-had (in- i i
clude dates 'and names of attendees) and cach physical structure I you:have reviewed in connection with your analysis of first com-plianco-with quality assurance regulations and second reasonable
. assurance of continuation with compliance with quality assurance regulations. '
15..
Do you believe bhat evidence of willfu) failure by
. Consumers Power. Company to report any violation o- ..:.' Atomic .
Energy _ Commission regulation 'is ' relevant evidence as to whether:
thereI i s' reasonable,, assurance that Consumers Power Company will
. comply or continue.to comply with-quality assuranco regulations.
-t concerning .the Midland' facility. 'If not, state why_not. .!
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< s 16 . - Define the words " reasonable assurance" as those words are used, and as you understand them in the Show cause -
. order in this proceeding. Include with your answer each fact which you claim must exist in order to conclude that reasonable
' assurance exists.
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- 17. .
With respect to the Midland facility quality- l
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assurance, state: '
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'(a) Do you agree with the allegations set forth in the Show C. use order and the referenced documents? If not, st. ate-each allegation with which you do not agrco and explain why; (b). As a resdit'of the Show.cause order,
' have you recommended 1or taken any action , i to-change your--role or consumers role'at I the Midland facility? If not, state why
' Enot,Jand if yes, explain such changes.in implementations and recommendations in detail. -
- 18. What~is your opinion of Consumers a's a utility
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, in the quality-assurance, quality-control area in light of your .
knowledge and experience with other utilities? Please include within.your answer the' facts upon-which you base your answer
, and an identification of other utilities cont'ained in your com-parative answer.
- 19. -Describe in detail each classification or cate-(gory of document (as defined herein) which you maintain in
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- connection with quality-assurance or quality-control regarding the Midland-site, whether maintained at the Midland site or elsewhere.
- This Interrogatory is intended to solicit informa-
: ion for a motion to produce and is intended to have you describe documents whether of a formal or in'ormal f nature, and whether they are documents internal to your company or not, and also whether or not they.are documents which are or are not disclosed to someone other than persons in your . company.
- 20. Please list the name and address of each witness
'whoso-testimony you intend to offer at.the proceeding. Includo with your answer a summary of the scope of each witness's tes-i timony. In the event that you do not presently know who your witnesses will- be, please list the areas of evidence or testi-many which you~ presently believe you will introduce. If you cannot answer this Interrogatory, please explain in detail why you cannot.
- 21. Please list all of the documentary evidence .
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which you -presently plan to introduce at the proceeding. If
, you are not in a position Lto- presently; state what : documentary evidence'you willLintroduce, please state what categories of
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documentary ovidence you will introduce. If you are not in a position ~to answer this. Interrogatory, please explain why not.
- 22. - Please set: forth~ in detail' both why you are par-i
- ticipating'in this proceeding and what positions'you intend to ;
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sponsor or oppose. - If you are not in.a position'to answer this Interrogatory, please explain why and 'also . state what interest
. you have'in. participating in .this proceeding if you have not to'rmed a-position either in support or opposition'to any issues :
)
that are relevant to these proceedings.
- By: 3 '
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- Myron'/py.
Attorn forCherry Saginaw Group ,
~ Myron M; Cherry One.I B M Plaza Chicago, Illinois 60611 (312)- 222-9350 i O
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