ML20003C340
| ML20003C340 | |
| Person / Time | |
|---|---|
| Site: | Midland |
| Issue date: | 02/25/1981 |
| From: | Paton W NRC OFFICE OF THE EXECUTIVE LEGAL DIRECTOR (OELD) |
| To: | CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.) |
| References | |
| ISSUANCES-OL, ISSUANCES-OM, NUDOCS 8102270763 | |
| Download: ML20003C340 (5) | |
Text
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BEFORE THE ATOMIC SAFETY AND LICENSING BOARD
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In the Matter of
)
)
Docket Nos. 50-329-0M CONSUMERS POWER COMPANY
)
50-330-0M
)
50-329-0L (Midland Plant, Units 1 and 2)
)
50-330-0L NRC STAFF OBJECTIONS TO INTERR0GATORIES FILED BY CONSUMERS POWER COMPANY The Staff is today filing answers to interrogatories filed by Consumers. Power Company except for interrogatories 13 through 16.
For the reasons stated below, the Staff ob.fects to interrogatories 13 through 16 which read as follows:
13.
State with particularity each acceptance criteria with Consumers Power Company had up until December 6,1979 provided to the Staff.
14.
As of December 6,1979 with regard to each criteria identified in your answer to interrogatory 13 state whether Consumers had submitted sufficient infomation to justify each acceptance criteria.
If Consumers had not submitted sufficient infomation, state with particularity which infomation Consumers had failed to supply.
15.
Excluding the acceptance criteria identified in response to interrogatory 13, state with particularity each acceptance criteria which Consumers has to date provided to the Staff.
- 16. With regard to each criteria identified in your answer to interrogatory 15 state whether Consumers has submitted sufficient infomation to justify each acceptance criteria.
If Consumers has not submitted sufficient infor-mation, state with particularity which infomation Consumers has failed to supply.
18102270 703 g
l The Staff ob,iects to these interrogatories. The interrogatories are directed to information which was originally provided by Consumers. To select the requested information would require the Staff to sort through all of the voluminous documents provided by Consumers since the soil settlement problem was first reported in August 1978, and tabulate any acceptance criteria that may be found therein.
In the course of the Staff's normal review, it considers all the information submitted by Consumers, but would not ordinarily and did not in this case tabulate any acceptance criteria found in Consumers' documents.
If the purpose of these interrogatories is to obtain the definition of the expression acceptance criteria, that has been provided in the answer to interrogatory 1.
The Staff has provided, in answers to other interrogatories, specific ir. formation concerning the adequacy of Consumers' responses, details as to specific information needed by the Staff, and the relevance of acceptance criteria to those matters.
In light of the above, the Staff submits that forcing the Staff to sort through voluminous documents provided by Consumers for the purpose of tabulating any acceptance criteria that may be found therein would be
- an inappropriate burden on the Staff.
If Consumers believes such a tabulation would assist the resolutio,i of the issues in this proceeding, it would be more appropriate that it extract this infomation from documents it prepared in the first instance.
Respectfully submitted
'o i Y
/
n William D. Paton Counsel for NRC Staff Dated at Bethesda, Maryland this 25th day of February, 1981
i j
UNITED STATES OF AMERICA NUCLEAR REGULATORY C0". MISSION BEFORE THE ATOMIC SAFETY AND LICENSING C0ARD In the Matter of i
LONSUMERS POWER COMPANY
)
Decket Nos. 50-329-0M t OL t
50-330-0M & OL i
(Midland Plant, Units 1 and 2)
CERTIFICATE OF SERVICE I hereby certify that copies of.NRC STAFF OBJECTIONS TO INTERR0GATORIES FILED BY CONSUMERS POWER COMPANY in the above-captioned proceeding have been served on the following by deposit in the United States mail, first class or, as indicated by an asterisk, through deposit in the Nuclear Regulatory Commission's internal mail system, this 25th day of February 1981.
- tharles Bechhoefer, Esq.
Ms. Mary Sinclair Atomic Safety and Licensirig Board 5711 Summerset Street U. S. Nuclear Regulatory Commission Midland, Michigan 48540 Washington, D.C.
P0555
- Mr. Gustave A. Linenberger Michael I. Miller, Esq.
-Atomic Safety and Licensing Board Ronald G. Zamarin, Esq.
V. S. Nuclear Regulatory Commission Alan S. Farnell, Esq.
Uashington, D.C.
20555 Isham, Lincoln & Beale One First National Plaza Dr. Frederick P. Cowan 42nd Floor CiS2 N. Verde Trail Chicago, Illinois 60603 Apt. B-125 Doca Raton, Florida 33433-
- Atomic Safety and Licensing Board Panel Frank J. Kelley U. S. Nuclear Regulatory Commission Attorney General of the State Washington, D.C.
20555 of Michigan Steward H. Freeman _
- Atomic Safety and Licensing Assistant Attorney General
_ Appeal Board Panel
' Gregory T. Taylor U. S. Nuclear Regulatory Commission Assistant Attorney General.
Washington, D.C.
20555 Environmental-Protection Division i
720 Law Building
- Docketing and Service Section Lansing, Michigan 4S913 Office of the Secretary U. S. Nuclear Regulatory Commission Myron M. Cherry, Esq.
Washington, D.C.
20d55 1 IBM Plaza Chicago, Illinois 60611 1
. Ja;..es E. Crunner, Esq.
Jeann Linsley Consu:acrs Power Company Bay City Times 212 L'est Michigan Avenue 311 Fifth Street Jackson, Michigan 49201 Bay City, Michigan 48706 T*s. Barbara Stamiris 5/95 N. Rivcr freeland, Michigan 48623 Mr. Steve Gadler 2120 Carter Avenue St. Paul, Minnesota 55108 h'endell H. Marshall, Vice President Midwest Environmental Protection Associates RFD 10 l:idland, Michigan 48640 J ;es R. Kates F 03 S.
'..*a s h ing to n Avenu e S3ginaw, Michigan 48605 d.
D,1dho William D. Paton Counsel for NRC Staff