ML20063J361

First Set of Interrogatories.Certificate of Svc Encl. Related Correspondence

ML20063J361
Person / Time
Site:	Midland
Issue date:	08/30/1982
From:	Mark Miller CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.), ISHAM, LINCOLN & BEALE
To:	Stamiris B STAMIRIS, B.
References
ISSUANCES-OL, ISSUANCES-OM, NUDOCS 8209020365
Download: ML20063J361 (7)

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00CKETED u USHRC UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION k N -l M

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$'l OFFICE 0F SECRE.

DOCKETuG & SE BEFORE THE ATOMIC SAFETY AND LICENSING BOARD BP.ANCH In the Matter of: )

) Docket Nos. 50-329-OM CONSUMERS POWER COMPANY ) 50-330-OM

) 50-329-OL (Midland Plant Units 1 and 2) ) 50-330-OL CONSUMERS POWER COMPANY'S FIRST SET OF INTERROGATORIES TO INTERVENOR BARBARA STAMIRIS Pursuant to 10 CRF S2.740b and the Atomic Safety and Licensing Board's Prehearing Conference Order of August 14, 1982, Consumers Power Company (" Consumers Power") requests Intervenor Barbara Stamiris to answer separately and fully in writing under oath or affirmation, each of the following Interrogatories regarding contentions admitted at the pre-hearing conference, within 14 days of service.

INSTRUCTIONS AND DEFINITIONS

1. As used in these Interrogatories, whenever appropriate, the singular. form of a word shall be inter- -

preted $s plural and the masculine gender shall be deemed to includ$ the feminine.

2. As used in these Interrogatories, the term "and," as well as "or," shall be construed either disjunc-tively or conjunctively as necessary to bring within the 8209020365 820830 PDR ADOCK 05000329 G PDR 3 S03

o Th scope of these Interrogatories any information which might otherwise be construed to be outside their scope.

3. As used in these Interrogatories,.the term

" person" includes, without limiting the generality-of its meaning, every natural person, corporate entity, partner-ship, association, governmental body or agency.

4. As uscd in these Interrogatories,.the term

" identification" of a person or entity includes stating his, her, or its full name, his or her most recent home address and telephone number, his, her, or its most recent known business address and telephone number, his or her present position, and his, her, or its connection or association with any party to this proceeding.

5. If any of the information contained in the

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l answers to these Interrogatories is not within the personal l knowledge of the person signing the Interrogatory, so state and identify each person, document and communication on which he relies for the information contained in answers not solely based on his personal knowledge.

6. If you cannot answer any portion of the following Interrogatories in full, after exercising dili-gence to secure the information to do so, so state and answer to the extent possible, specifying your inability to answer the remainder and stating whatever information or knowledge you have concerning the unanswered portions.

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7. If you claim privilege with respect to any information which is requested by these Interrogatories, -

specify the privilege claimed, the communication and/or answer as to which that claim ic made, the parties to the communication, the topic discussed.in the communication and the basis for your. claim. __

INTERROGATORIES

1. With. respect to each. contention advanced by Intervenor Barbara Stamiris which has been admitted by the Atomic Safety and Licensing Board in Prehearing Conference Order of August 14, 1982, in the above-captioned proceeding, subject to restatement, list the following:

a.- a concise statement of the-facts supporting each Contention together with references to the specific sources and documents and por-tions thereof which have been or will be l relied upon to establish such facts;

b. the identity of each person expected to be l called as a witness at the hearing; 1

c. the subject matter on which each witness is expected to testify;

d. the substance of each witness' testimony.

2. With respect to each witness identified in l Intervenor's response to Interrogatory No. 1 above, identify each d6cument which the witness will rely upon in whole or in part in the preparation of his testimony or in the de-j velopment of his position.

3. With respect to each witness identified in

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Intervenor's response to Interrogatory No. 1 above, identify the witness's qualifications to testify on the subject matter on which the witness will testify.

4. With respect to Contention 1.b., identify all inconsistencies and all reasons which Intervenor Stamiris believes support her contention that the NRC's economic cost benefit analysis underestimates decommissioning costs.

5. With respect . to the first part, of Inter-venor's Contention 2 which the Licensing Board consolidated with Sinclair Contention 6, identify any and all examples of which Intervenor is aware, with the exceptions of Dartey and Howard, where Intervenor contends that disciplinary action resulted from QA/QC reporting. For each instance,- identify the employee by name a'nd address and state the date of the disciplinary action, the QA/QC problem which the employee sought to report, and the disciplinary action taken against the employee.

6. Identify all persons who participated in the preparation of the answers, or any portion thereof, to the Interrogatories.

We respectfully remind Intervenor Stamaris of her ongoing duty, under certain circumstances, to supplement responses to this discovery request in accordance with 10 C.F.R. S2.740(e).

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WI'chael ~I. ilT6rs CounselforCnsumers}'~

Power Company ISHAM, LINCOLN & BEALE Three First National Plaza

Suite 5200 --

Chicago, Illinois 60602 (312) 558-7500 b

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L UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION _

BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of: )

) Docket Nos. 50-329-OM CONSUMERS POWER COMPANY ) 50-330-OM

) 50-329-OL (Midland Plant Units 1 and 2) ) 50-330-OL CERTIFICATE OF SERVICE I, Mich'ael I. Miller, one of the attorneys for Consumers Power Company, hereby certify that a-copy of

" Consumers Power Company's First Set of Interrogatories to Intervenor Barbara Stamiris" was served upon all persons shown in the attached 5service list by deposit in the United i States mail, first class, this 30th y of u t, 962.

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\.) Michael'l M YN

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ISHAM, LINCOLN & BEALE Three First National Plaza Suite 5200 Chicago, Illinois 60602 (312) 558-7500 l

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. I SERVICE LIST r

Frank J. Kelley, Esq. Steve Gadler, Esq.

Attorney General of the 2120 Carter Avenue State of Michigan St. Paul, Minnesota 55108 Carole Steinberg, Esq. . -

Assistant Attorney General Atomic ~ Safety & Licensing Environmental Protection Div. Appeal Panel 720 Law Building U.S. Nuclear Regulatory Comm.

Lansing, Michigan 48913 Washington, D.C. 20555 Myron M. Cherry, Esq. Mr. C. R. Stephens One IBM Plaza Chief, Docketing & Services Suite 4501 U.S. Nuclear Regulatory Comm.

Chicago, Illinois 60611 Office of the Secretary Washington, D.C. 20555 Mr. 'Wendell H. Marshall RFD 10 Ms. Mary Sinclair -

Miqlland, Michigan 48640 5711 Summerset Street Midland, Michigan 48640 Charles Bechhoefer, Esq.

Atomic Safety & Licensing William D. Paton, Esq.

Board Panel Counsel for the NRC Staff U.S. Nuclear Regulatory Comm. U.S. Nuclear Regulatory Comm.

Washington, D.C. 20555 Washington, D.C. 20555 Dr. Frederick P. Cowan Atomic Safety & Licensing 6152 N. Verde Trail Board Panel Apt. B-125 U.S. Nuclear Regulatory Comm.

Boca Raton, Florida 33433 Washington, D.C. 20555 Admin. Judge Ralph S. Decker ' Barbara Stamiris Route No. 4, Box 190D 5795 North River Road

Cambridge, Maryland 21613 Route 3 l Freeland, Michigan 48623

! Carroll E. Mahaney Babcock & Wilcox Jerry Harbour P.O. Box 1260 Atomic Safety & Licensing i Lynchburg, Virginia 24505 Board Panel l -

, U.S. Nuclear Regulatory Comm.

James E. Brunner, Esq. Washington, D.C. 20555

~~ Consumers Power Company 212 West Michigan Avenue Lee L. Bishop -

Jackson, Michigan 49201 Harmon & Weiss 1725 "I" Street, NW #506 Mr. D. F. Judd Babcock & Wilcox Washington, DC 20006 P.O. Box 1260 '

Lynchburg, Virginia 24505 l

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