ML20073B801

Third Set of Interrogatories.Certificate of Svc Encl

ML20073B801
Person / Time
Site:	Midland
Issue date:	04/08/1983
From:	Proctor S CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.), ISHAM, LINCOLN & BEALE
To:	Sinclair M SINCLAIR, M.P.
References
ISSUANCES-OL, ISSUANCES-OM, NUDOCS 8304120556
Download: ML20073B801 (10)

Text

.t e -l DOCKETED USHRc UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION APR 11 P1:49 BEFORE THE ATOMIC SAFETY AND LICENSING BOARD.,b;h' U CH '

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 t

CONSUMERS POWER COMPANY'S THIRD SET OF INTERROGATORIES TO INTERVENOR MARY SINCLAIR Consumers Power Company (" Consumers"), by its attorneys and pursuant to 10 C.F.R.

S2.740b, requests In-tervenor Mary Sinclair to answer separately and fully under oath or upon affirmation, each of the following interrogatories-within 14 days of service.

f 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," chall be construed either disjunc-tively or conjunctively as necessary to bring within the scope of these Interrogatories any information which might 1

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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:

4 the original, any copies 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.can be obtained, translated,.if necessary through

' detection devices into reasonably usable form..

6.

In answering these Interrogatories, you shall furnish such information as is.available to you.

The. term "you" shall include any agents, attorneys or representatives.-

7.

If.any of the information contained in the answers to.these Interrogatories is not within the personal 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.

8.

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.

i 9.

.If you claim privilege with respect to any information which is requested by these Interrogatories, specify the privilege claimed, the communication and/or 2

- answer,as to which that claim is made,.the parties to the communication, the topic discussed inLthe communication and

, the basis for your claim.

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4 INTERROGATORIES 15.

With respect to.Sinclair Contention 1, 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 s

' facts are relied-'upon in support of this

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Contention; d.

a concise explanation of all facts concerning w

quality control and quality assurance at,

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'i s within or by MPQAD which facts are relied

.up'on 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 reliedLupon inisupport of this Contention.

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16.

With'resphet to Sinclair Contention'8, please l'

state the followinh:i'b a concise'erpi,cacion of all facts concerning-a.

quali.ty c'

.re and quality assurance at, within; T r2,,

et Company:whichifacts are

relie{ upon in.r,upport of.this1Contentio~n;-.

7 b..

a-concise explanation of allLfacts concerning quality control'and:qualityfassurance'at, within or,by.Bechtel'PowerLCorporation which' facts are relied:upon in: support:of-this Cdntention; s:

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a a concise explanation of all facts concerning

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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.

id_entify 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 concise explanation of all facts concerning a.

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 i

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

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

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upon in support of this Contention;

. identify ~all persons having any information e.

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

identify all documents whien, either in whole 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 re, lied 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; a concise explanation of all facts concerning c.

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;

-identify all persons having any information e.

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 concise explanation of all facts _concerning a.

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,

~,

i 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, i

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

a concise explanation of all facts concerning qu.ality 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.

20.

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

a concise explanation of all facts concerning a.

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

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; i

a concise explanation of all facts concerning_

c.

guality control and quality assurance at, within or by Consumers Power Company which facts are relied upon in support of this-Contention;L t

d.

a concise explanation of all facts concerning quality control and quality assurance at, within or.by-MPQAD which1 facts are relied-upon in' support of this Contention;

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identify all persons having any information or knowledgefof facts relied upon in support of this Contention; and i

f.

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

l-21.

'With respect to Sinclair contention 17, 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 j-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.

CONSUMERS POWER COMPANY' ar s

s By Maud..hh One of its Attorneys David M. Stahl, Esq.

Susan D; Proctor,cEsq.-

1ISHAM,L. LINCOLN &.BEALE Three1First National. Plaza

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Suite 5200 Chicago,. Illinois 60602 (312) 558-7500'

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 1 & 2)-

)

50-330 OL CERTIFICATE OF SERVICE I,,

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h/exTjc,oneof..theattorneysfor Consumers Power Company, hereby certify that a copy of Consumers Power Company's Third Set Of Interrogatories To Intervenor-Mary Sinclair was served upon all persons shown-in the attached service list by deposit in the United ~ States mail, first class, this I

day of April, 1983.

Ar b ISHAM, LINCOLN & BEALE

.Three First National Plaza Suite 5200

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Chicago',1 Illinois

60602,

(312) 558-7500 q

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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 Comm.

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 WestLMichigan 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.

1. 506 Lynchburg, Virginia 24505 Washington; ~ D.'C.

20006 Barbara Stamiris Ms. Lynne Bernabei!

5795 North River Road-Mr. Thomas Devine

. Route 3

'Mr. Louis Clark Freeland,-Michigan 48623 Government Accountability Project ofLthe Institute for Policy Studies-1901 O' Street,'N.W.

Washington, DC ~20009

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