ML20073P999

Request for Production of Documents.Certificate of Svc Encl.Related Correspondence

ML20073P999
Person / Time
Site:	Midland
Issue date:	04/22/1983
From:	Marshall W MAPLETON INTERVENORS
To:	NRC OFFICE OF THE EXECUTIVE LEGAL DIRECTOR (OELD)
References
78-389-03-OL, 78-389-3-OL, 80-429-02-SP, 80-429-2-SP, ISSUANCES-OL, ISSUANCES-OM, NUDOCS 8304280020
Download: ML20073P999 (5)

Text

-

.2 - *)#~ .

UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION Before the Atomic Safety and Licensing Board 8

IlP127 gg 4, In the Matter of ) ASLBP Nos. 78-389-03'0L

) 80-429-02 SP .

CONSUMERS POWER COMPANY Docket Nos. 50-329 OL (MidlandPlant, Units 1and2) )

)

hh 50-330 OM INTERVENOR WENDELL H. MARSHALL'S REQUEST FOR PRODUCTION OF DOCUMENTS TO THE NUCLEAR REGULATORY COMMISSION STAFF T0: Nuclear Regulatory Comission Staff Intervenor Wendell H. Marshall, pursuant to the Atomic Safety and Licensing Board's Order of April 6,1983, hereby requests the Nuclear Regulatory Commission

(" Commission" or "NRC") Staff to produce and make available for inspection and/or copying each document in the possession or custody of the NRC Staff or subject to the control of the NRC Staff, its agents, or its attorneys, as requested below.

DEFINITIONS As used herein, and unless the context otherwise requires, the terms:

(a) The Nuclear Regulatory Commission or "NRC" shall mean the Nuclear Regu-latory Commission, its branches, departments, offices, sections, subdivisions, its present and former commissioners, administrators, management, employees, agents, representatives, consultants or officials, or their agents, attorneys, or representatives.

8304280020 830422 PDR ADOCK 05000329 g PDR mso3

(b) " Document" shall mean every writing of every type or description, and every other instrument or device by which, through which, or on which information

\

has been recorded and/or preserved, including but not limited to memoranda, notes, letters, drawings, files, graphs, charts, photographs, slide presentations, hand-written notes, logs, ledgers, studies, data sheets, appointment calendars, telephone messages, voice recordings and other data compilations or other media on which or through which information of any type is transmitted, recorded or preserved.

(c) " Communication" shall mean communication, discussion, conversation, letter, memorandum, telephone call, message or direction whether written or oral, or whether in person, by telephone, or by mail.

DOCUMENTS TO BE PRODUCED

1. Any and all documents relating in any way to any inspections conducted by the Office of Special Cases, Midland Section, concerning the dewatering wells at the Midland nuclear power plant, all NRC Inspection and Enforcement Reports and any other investigation of water systems which affect in any way the dewatering program, including, but not limited to, ongoing NRC investigations. Describe the nature and scope of any ongoing NRC investigation.

2. Any and all documents relatirg in any way to communications between Region III and any other office, or branch of the NRC, or between offices, branches or divisions of the NRC, concerning (a) the reports mentioned in Document Request No.1 above, or (b) the investigations listed in Document Request No.1 above.

3. Any and all documents prepared by Region III in the 1980 to 1983 period which relate in any way to comparisons of the Midland nuclear power plant to other nuclear plants in terms of the following:

(a) the number of wells reported to NRC

(b) the size of wells filed by Consumers Power Company ("CPC") with NRC (c) the overall rating of the dewatering pumps at Midland plant as compared

\

to other plants in Region III and other plants under construction in the United States and the amount of electricity to be used in the dewatering pro-gram at Midland.

4. Any and all documents, including any technical analysis performed by or submitted to the NRC, relating to: ,

(a) the-NRC decision to allow underpinning work to commence in December, 1982, at the Midland plant and its relation to the dewatering program (b) the total number of 6" and 8" wells and depth (c) the total number of longer wells and depth (d) total amount of water to be pumped

5. Any and all documents relating in any way to independent water audits at Midland; the NRC's acceptance criteria for these audits; and NRC actions on these audits.

6. Confirm in writing the NRC Staff's previous representations that no documents exist which relate in any way to:

(a) Dewatering Program (b) Number and size of wells (c) Quantity of water to be pumped (d) Electricity demand for all wells and the 1982 stop-work orders issued by CPC and the CPC decisions to lift these stop-work orders concerning the dewatering program Respect ly submitted, x $ f&

Wendell H. Marshall DATED: April 22,1983

e . .

4 UNITED STATES OF AMERICA

. NUCLEAR REGULATORY COMMISSION ' ?4 ? c-Before the Atomic Safety and Licensing Board - .

'83 AR?27 In the Matter of Docket Nos. 50-329-OL Al0l47 50-330-OL CONSUMERS POWER COMPANY 50-329-0M~ . ;. _,

-)

50-330-0M 4//l F i -

(Midland Plant, Units 1 and 2)

)

CERTIFICATE OF SERVICE' I here by certify that copies of the foregoing Intervenor Wendall Marshall's Request for Production of Documents to the Nuclear

~

Regulatory Comission Staff- were mailed, proper postage pre-paid, this 22nd

. day of April ,1983, to:

~ Michael I. Miller, Esq. Mr. R. B. Borsum Isham, Lincoln & Beale Nuclear Power Generation Division Three First National Plaza-51st fir.

~

Babcock & Wilcox Chicago, Illinois 60602 7910 Woodmont Avenue - Suite 220 Bethesda, Maryland 20814 James E. Brunner, Esq.

Consumers Power Company U. S. Nuclear Regulatory Comission 212 West Michigan Avenue Resident Inspectors Office Jackson, Michigan -49201 Route 7 Midland, Michigan 48640 Ms. Mary Sinclair 5711 Summerset Drive Mr. James G. Keppler, Regional Admin.

Midland,-Michigan 48640 U. S. Nuclear Regulatory Commission Region III Stewart H. Freeman 799 Roosevelt Road L . Assistant Attorney General Glen Ellyn, Illinois 60137 I State of Michigan Environmental H Protection Division Lee L. Bishop 720 Law Building Harmon & Weiss Lansing, Michigan 48913 1725 I Street N.W. - Suite 506 Washington, D. C. 20006 Mr. Steve Gadler, P.E.

2120 Carter Avenue Mr. Ron Callen St. Paul, Minnesota 55108 Michigan Public Service Commission 6545 Mercantile Way P. O. Box 30221 Lansing, Michigan 48909 l

1

~

William D. Paton Executive Legal Director Nuclear Regulatory Commission Washington, D. C. 20555-Mr. Paul Rau Midland Daily News

.124 Mcdonald Street Midland,' Michigan 48640 Charles Bechhoefer, Esq.

Atomic Safety & Licensing Board U. S. Nuclear Regulatory Commission

. Washington, D. C. 20555 Dr. Frederick P. Cowan

. Apt. B-125 6125 N. Verde Trail Boca Raton, Florida 33433 Jerry Harbour, Esq.

Atomic Safety and Licensing Board U. S. Nuclear Regulatory Commission Washington, D. C. 20555 Docketing and Service Branch U. S. Nuclear Regulatory Commission Washington, D. C. 20555 LYNNE BERNABEI I

l l

l l

i l

l

.