ML20073B705

Second Set of Interrogatories.Certificate of Svc Encl

ML20073B705
Person / Time
Site:	Midland
Issue date:	04/08/1983
From:	Proctor S CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.), ISHAM, LINCOLN & BEALE
To:	Stamiris B STAMIRIS, B.
References
ISSUANCES-OL, ISSUANCES-OM, NUDOCS 8304120516
Download: ML20073B705 (10)

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00tKETED i;WC UNITED STATES OF AMERICA .g NUCLEAR REGULATORY COMMISSION' - g j j -pj $0 4

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BEFORE THE ATOMIC SAFETY AND LICENSING BOARD.

In the Matter of: ) Docket Nos. 50-329 OM

) 50-330 OM CONSUMERS POWER COMPANY ) Docket Nos. 50-329 OL (Midland Plant, , Units 1 & 2) ) 50-330 OL CONSUMERS POWER COMPANY'S SECOND SET OF INTERROGATORIES TO INTERVENOR BARBARA STAMIRIS Consumers Power Company (" Consumers"), by its attorneys and pursuant to 10 C.F.R. S2.740b, requests In-tervenor Barbara Stamiris to answer separately and fully under oath or upon affirmation, each of the following inter-rogatories 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 as plural and the masculine gender shall be deemed to include 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 withi~n.the scope of these Interrogatories any information which might E'

8304120516 830400 PDR ADOCK 05003329 O PDR. _ .

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I 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 used 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. As used in these Interrogatories, the term

" identification of a document" includes stating the type of document, date, author, addressee and recipients of all copies or in the alternative, providing a copy of, or making available for copying, each such document. The term " document" means:

the original, any copics when an original is-unavailable and any non-identical copies (whether different from the original because of notes made on such copies or otherwise),.

regardless of origin or location, of any handwritten, typewritten, printed, recorded, transcribed, punched, taped, photocopied, photostatic, " telexed", filmed, microfilmed or otherwise prepared matter, however--pro-duced or reproduced. The' term document shall include all writings, drawings, graphs, charts,.

photographs,-phonographs and other data.

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compilations from'which'information canibe

. obtained, translated,'if necessaryfthrough:

t detection devices into' reasonably 1 usable .

form..

' 6. In answering these' Interrogatories, you,shall' furnish-such'information~'as is available to you. 1The: term ,

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"you"1shall include any agents, attorneys or representatives.

7.  : If any of the information contained =in the i answers-to these Interrogatories is not within the personal. i knowledge of the person signing the Interrogatory, so' state.

and identify each person, document'and communication on 2

which he relies 1for the information contained in answers not.

i p - solely based on his personal knowledge.

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8. If you cannot answer any portion of the-f following Interrogatories in full,~after exercising dili-gence to secure the information to do so, so state and f answer to the extent'possible, specifying your.~ inability to i answer the remainder and stating whatever-information or

{ knowledge you have concerning the unanswered portions. '

9. If you claim privilege with respect .tx) any' i

information which is requested by-these Interrogatories, t

specify the privilege claimed, the communication and/or!-

answer as to which that claim is made, the parties'to the _

e communication, the topic discussed in the communicationJand.

the; basis for-your claim. '

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l INTERROGATORIES

15. With respect to Sinclair Contention 1, please I state the following:

a. a concise explanation of all facts.concerning-quality control and quality assurance at, within or by Zack Company which facts are relied upon in support of this Contention; a

b. a concise explanation of all facts'concerning quality control and. quality assurance at, within or by Bechtel Power Corporation which facts are relied upon in support of this Contention;

c. a concise explanation of all facts concerning quality control and quality assurance at, within or by Consumers Power Company which facts are relied upon in support of this Contention;

d. a concise explanation of all facts concerning quality control and quality assurance at, within or by MPQAD which facts are relied upon in support of this Contention;

e. identify all persons having any information-or knowledge of facts relied upon in support of this Contention; and-

f. identify all documents which, either in:whole or in part, are relied upon intsupport of this Contention.

16. With respect to Sinclair Contention 8,'please state the following:

1 a.. a concise explanation'of all facts concerning~

quality control and quality assurance at,.

within or by Zack Company which facts are relied upon in support of this Contention;

b. a concise explanation vf all facts concerning l quality control and quality _ assurance at, within~or by Bechtel Power Corporation which facts are relied upon in support of this Contention;

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c. a concise' explanation _of'all: facts concerning-quality control and quality assurance:at, within or by Consumers Power Company which facts are' relied upon in support of this

! Contention;

.. a concise explanation of all: facts concerning-quality control-and quality assurance at, within cn by MPQAD which facts are relied upon in support"of this Contention;

e. identify all~ persons having any information or knowledge of facts relied upon in support of this Contention; and

f. identify all documents which, either in whole or in part, are relied upon in support of this Contention.

17. With respect to Sinclair Contention 10, please state the following:

a. a concise explanation of all facts concerning quality control and quality assurance at,

, within or by Zack Company _which facts are

relied upon in support of this Contention;

b. a concise explanation of all facts concerning quality control and-quality assurance at, within or by Bechtel Power Corporation which facts are relied upon in support of this Contention;

c. a concise explanation of all facts concerning quality control and quality assurance'at, within or by Consumers Power Company which facts are relied upon in support of this i Contention; a concise. explanation of all facts concerning

d.

quality' control and quality assurance at,-

within or by.MPQAD which~ facts are relied upon in support of this Contention;

c. identify all persons:having any information.

or knowledge of facts relied upon in support of this Contention; and-

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f. identify all documents which, either in whole l or-in.part, are relied upon in support of this Contention.

18. .With respect to Sinclair Contention 11, please state the following:

a. a concise explanation of all facts concerning

~ quality control and quality. assurance at, within or by Zack Company which facts are relied upon in support of this Contention;

b. a-concise explanation of all facts concerning quality control and' quality assurance at, within or by Bechtel Power Corporation which facts are relied.upon in support of this Contention;

c. a concise explanation of all facts concerning quality control and quality assurance at, within or by Consumers Power Company which facts are relied upon in support of this Contention;

d. a concise explanation of.all facts concerning quality control and quality assurance at, within or by MPQAD which facts are relied upon in support.of this Contention;

e. identify all persons having any information or knowledge of facts relied upon in support of this Contention; and

f. identify all documents which, either in whole or in part, are relied upon in support of-this Contention.

19. With respect to Sinclair Contention.15, please state the following:

a. a concise' explanation of all facts concerning quality control and quality assurance at, within or by Zack Company which~ facts are relied upon in support of this' Contention;

b. a concise explanation of.all facts concerning quality .cc:: trol and quality. assurance at, L

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i within or by Bechtel PowerLCorporction which-facts are relied upon in support of this Contention;

c. a concise explanation of all-facts concerning quality control and quality assurance at, within or by Consumers Power Company which facts are relied upon in support of this Contention;

d. a concise. explanation of all facts concerning quality control and quality assurance at, within or by MPQAD which~ facts are. relied ,

upon in support of this Contention;

e. identify all persons having any information oor knowledge _of facts relied upon in support >

of this Contention; and

f. identify all documents which, either in whole or in part, are relied upon in support of this Contention.

20. With respect to Sinclair Contention 16, please state the following:

l a. a concise explanation of all facts concerning l quality control and quality assurance at,

! within or by Zack Company which facts are L relied upon in support of this Contention;

b. a concise explanation of all' facts concerning l quality control and quality assurance at, l

within or by Bechtel' Power Corporation which facts are relied upon in support of this Contention;

c. a concise explanation of all facts concerning quality control and quality.' assurance at, within or by Consumers Power Company which facts are relied upon in support of this Contention;

d. a concise explanation of all~ facts concerning-quality ~ control and quality assurance at, within or by MPQAD which facts are relied upon in support of this Contention;

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Di , 'l le.- Lidentify all persons 1having any-information

-or knowledge of facts. relied uponlin support:

'of this contention; and

. identify allfdocuments which, eithercin~whole f.:

lor-in part, are relied upon in support of-this Contention.

l 21.- With respect-to Sinclair' Contention:17, please state the following:

V A concise explanation of.all facts concerning

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l quality-control and quality assurance at,

[. within or by Zack Company which facts:are i

relied upon in support 1of this-Contention;

b. a concise explanation of all' facts-concerning l quality control and quality assurance at, .

L within or by Bechtel Power Corporation which facts are relied upon in support of this -

Contention;

c. a concise explunation of all facts.concerning quality control and quality. assurance at,-.

within or by Consumers Power Company which facts are relied upon in support of-this Contention;

d. a concise explanation of all facts concerning- ~

quality control and quality assurance at, within or by MPQAD which facts are-relied upon in support of this Contention;

e. identify all persons'having any information ~

or knowledge of facts relied upon in support' of this' Contention; and ,

f. identify all. documents which, either in whole or in part, are relied upon inLsupport of this Contention.

CONSUMERS POWER 1 COMPANY-4.

By " 4 b / 7.. u .< 4 7 One of.its-Attorneys David M. Stahl,:Esq.

Susan D. ProctorjJEsq.

ISHAM, LINCOLN & BEALE o Three'First National' Plaza Suite 5200 ~ l- 1 Chicago, Illinois--60602 . .

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' UNITED: STATES OF' AMERICA-

= NUCLEAR REGULATORY. COMMISSION BEFORE-THE ATOMIC' SAFETY AND LICENSING BOARD In the Matter of: -)' Docket Nos. 50-329.OM-

) 50-330 OM CONSUMERS POWER COMPANY '). Docket Nos. 50-329 OL (Midland' Plant, Units ~l &'2) ) .50-330 OL CERTIFICATE:OF SERVICE-I,,vs44- /l%r/nf,- one of the attorneys - for Consumers Power company, hereby certify that a copy of Consumers Power Company's Third Set Of Interrogatories 'To =

Intervenor Barbara Stamiris was served upon all persons shown in the attached service list by deposit in the' United States mail, first class, this <[ day of April, 1983.

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0_-' _ ='. .re.wO ISHAM, LINCOLN & BEALE Three First National Plaza Suite 5200 Chicago, Illinois 60602 (312) 558-7500 k

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~ SERVICE LIST Frank J. Kelley, Esq. Steve Gadler 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 Conn.

Lansing, Michigan 48913 Washington, D.C. 20555 Cherry & Flynn Mr. C.. R. Stephens Suite 3700 Chief, Docketing & Services 3 First National Plaza U.S. Nuclear. Regulatory-Comm.

Chicago, Illinois 60602 Office of the. Secretary Washington, D.C.'20555 Mr. Wendell H. Marshall 4625 S. Saginaw Road Ms. Mary Sinclair Midland, Michigan 48640 5711.Summerset Street Midland, Michigan 48640 Charles Bechhoefer, Esq. William D. Paton, Esq.

Atomic Safety & Licensing Counsel for the NRC Staff Board Panel 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 James E. Brunner, Esq. Jerry Harbour ,

Consumers Power Company Atomic Safety.& Licensing 212 West Michigan Avenue Board Panel Jackson, Michigan 49201 U.S. Nuclear Regulatory Comm.

Washington, D.C. 20555 Mr. D. F. Judd Lee'L. Bishop-Babcock & Wilcox Harmon & Weiss P. O. Box 1260 1725'"I" Street, N.W. #506 Lynchburg, Virginia 24505 Washington, D.C. 20006 Barbara Stamiris Ms. LynnelBernabei' 5795 North River Road .Mr. Thomas Devine Route 3 Mr. Louis Clark-Precland, Michigan 48623 Government' Accountability Project of the: Institute for;PolicyJStudies' 1901-Q Street,'N.W.

, ~ Washington, DC l20009 e