ML20054L522

Response to CPC First Interrogatories.Related Correspondence

ML20054L522
Person / Time
Site:	Midland
Issue date:	07/02/1982
From:	Sinclair M SINCLAIR, M.P.
To:	CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.)
References
NUDOCS 8207080207
Download: ML20054L522 (3)

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NUC LEAR llEGULATORY CO:. I.11SSION j l'~ A Before the Atomic Safety :;nd Lico ch; Boart

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In the Matter of: ) .

) Doc. Nos. 50-33 CONSUMERS POWER COMPANY, ) 50-330

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(Midland Plant, Units 1 and 2 ) Operating License

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MARY SINCLAlH'S HEPLIES TO FIRST SET OF INTERROG ATORIES FROM CONSUMERS POWEll CO, Contention C

1. a. The extensive hearing record of the poor quality control at Midland and Palisades support this contention and those documents will be used,

b. I have no witnesses, but I expect to rely on the witnesses that the Nuclear Heaulatory Commission will call. I am sure the NRC will call ,

upon competent witnesses for this contention since the NHC already has a

$1 billion law suit against it for failure to regulate adequately and assess the safety of the TMI-2 plantj and it will not want to risk this again at the Midland nuclear plant. In the event that I do raise funds for witnesses.

I will choose well-qualified persons who will be able to address these c.

issues in a competent way and make a significant centribution to the record.

c. I do not expect to call Dr. Charles Anderson o an expert witness in The extraordinary rude-the~ Operating License proce dings at this time.

ness with which he was treated during the ACHS review in Midland was ,

too stressful for both of us to be a';1e to consider another encounter of If matters change, I will advise the Applicant and this kind at this time.

the NHC.

d.,e. No itnesses are planned at this time.

above.

In rerponse to interrogatories 2 am! 3 see d. ..nd c.

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1. a, nets :hrt support this contention inclu:'e all the events that led to the show cause hearing on ouality control (the first such henring in the U.S. )

in regard to the Slidiand nuclear plant ordered in December,1973 and held in 1974. The key document for initiaing this proceeding is the letter of Rosenthal, et al to L. Af anning Muntzing, AEC Director of Licensing, November 20, 1973. Other documents are;

1. The record of the Applicant in the suspension proceedings as well as in the soil settlenient hearings.

2. The memos indicating that ti e Applicant never could make their rad waste holding tanks work at Palisades but operated the plant anyway, and that they withheld that information from the NIlC during many months but also, in fact, lied to the NI!C (then AEC) about this matter, will be further documents relied upon for this contention. (SIemos dated AIarch 1G,1972; SIarch 22, 1972; Letter to Sir. Boyce H. Grier, April 10, 1972; A EC, January January 20,1976)

1. b throu;;h c. Same as Contention G.

Contention 24 - OL-OM Procecriing .

Contention 27

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1. a. Documents on emergency planning f rom FE3fA; TMI Pt.blic interest Ilecource Center, June,1980: Jocuracnts from state cod local emergency planning teams; also from interrogatories, b through e. Same as Contention G.

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Contention 28 through 57 - Facts are as e tated in these cor.tentions.

1. a. Documents - Draft copy of NUR EG-0410; Black Fox Testimony; Final copy of NUI!EG-0410; all documents requested in interrogatories; all new informa-tion available through responsible current publications as identifi a through continuing research.

b. throu;;h e. Same as Contention G.

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4. I du r.U. l:no.' their names or whether they work for Ccnsumers Power Co.

or ? x!.tel or other contractors. The Government !.ccountability Project m:nters have been handled by other people in the Lone Tree Council,

5. See No. 4.

G. I have prepared the answers to these interrogatories myself, i.w .. \ 2 c]vj

?Iary Sineg((r ec: William Paton, 3Iichael I. Miller, Ilonald G. Zamaring, Alan S. Farnell TIr. Wendell Marshall Ms.13nrbara Stamiris Secretary, U.S.~ Nuclear llegulatory Commission

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