ML20081M221
| ML20081M221 | |
| Person / Time | |
|---|---|
| Site: | Midland |
| Issue date: | 10/25/1983 |
| From: | Brunner J CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.) |
| To: | Bernabei L GOVERNMENT ACCOUNTABILITY PROJECT |
| References | |
| ISSUANCES-OL, ISSUANCES-OM, NUDOCS 8311170147 | |
| Download: ML20081M221 (3) | |
Text
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s ogyo A consumers 9 power 4
- company M im 16 Pl2:03 General offices: 1945 West Parnell Road, Jackson, MI 49201 + (517) 788-0550 0FFICE OF SECPiTAF, 00CKETING & SERVIC!
BRANCH October 25, 1983 ocaw+sa 50-399 33o OM,0L PROD. n Lin'. 7:,..
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Ms Lynne Bernabei Government Accountability Project
,1901 Q Street Washington, DC 20009 Dear Ms Bernabei The following states my understanding of our agreement of October 24, 1983 relating to your discovery request of October 11 and Consumers Power Company's response of 10/20/83.
General Objections 1.
I stated that I am unaware of anyone having information on the relevant subject who is a former employee, apart from John Donnell.
I have not, however, conducted a search to confirm this.
I also have not read the l
investigation reports specifically to determine if anyone mentioned is a former employee. However, I do not believe there is such a person. We agreed that the problem is probably academic, but if you wish to pursue l
the catter further, you would do so.
L 2.
This will be taken up with the Board.
l 3.
I agreed to negotiate on this point, but do not waive the objection.
i l
4.
Not discussed.
Interrogatories l
l l
1-5.
I agreed to provide a response.
6-9.
I agreed to provide a response.
16.
I stand on my objection.
17.
I agreed to provide a response.
The question is interpreted as applying only to discussions in which Ronk was involved.
8311170147 831025 PDR ADOCK 05000329 oc1083-0650a100 0
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.e 18 & 19.
I stand on my objection.
23.
I agreed to provide a response.
24 b-d.
I agreed to provide a response bared solely on the current status of John Schaub's knowledge.
.32.
A response will be provided but will be limited to Glenn Murray's knowledge.
i.
33.
A response will be provided on the basis that the question is a general interrogatory, rather than directed to a specific person.
34.
I stand on my objection.
Document Requests 1.
Objection remains.
4 2-3.
I withdraw my objection on the basis that the question is now limited to notes about the meeting made by people who attended the meeting either at the meeting or after the meeting.
4.
Objection remains.
5.
Covered under 3, above.
7.
Objection remains.
10.
CPCo will identify the privileged documents.
15.
Objection remains.
16.
We will respond, but the request is limited to any memos between l
Kostielney and Ronk on the placement of asterisks.
Of course, I' reserve all objections on items not agreed upon.
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l J E Brunner i
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e OM/0L SERVICE LIST Mr Frank J Kelley, Esq Atomic Safetf & Licensing Attorney General of the Appeal Board State of Michigan U S Nuclear Regulatory Commission Ms Carole Steinberg, Esq Washington, DC 20555 Assistant Attorney General Environmental Protection Division w Mr;C R Stephins~(3) g 720 Law Building Chief, Docketing & Services Lansing, MI 48913 U S Nuclear Regulatory Commission Office of the Secretary Washington, DC 20555 Mr Myron M Cherry, Esq Suite 3700 Ms Mary Sinclair Three First National Plaza 5711 Summerset Street Chicago, IL 60602 Midland, MI 48640 Mr Vendell H Marshall Mr William D Paton, Esq
-RFD 10 Counsel for the NRC Staff Midland, MI 48640 U S Nuclear Regulatory Commission
- Mr Charles Bechhoefer, Esq Atomic Safety & Licensing Atomic Safety & Licensing Board Panel Board Panel U S Nuclear Regulatory Commission U S Nuclear Regulatory Commission Washington, DC 20555 Washington, DC 20555 Dr Frederick P Cowan Ms Barbara Stamiris 6152 N Verde Trail 5795 North River Road Apt B-125 Rt 3 Boca Raton, FL 33433 Freeland, MI 48623 Mr Fred Williams Mr Jerry Harbour Isham, Lincoln & Beale Atomic Safety & Licensint 1120 Connecticut Avenue, NW, Suite 325 Board Panel Washington, DC 20036 U S Nuclear Regulatory Commission Washington, DC 20555 Mr James E Brunner, Esq Mr M I Miller, Esq Consumers Power Company Isham, Lincoln & Beale 212 West Michigan Avenue Three First National Plaza Jackson, MI 49201 52nd Floor Chicago, Il 60602 Mr D F Judd Mr John Demeester, Esq Babcock & Wi!cox Dow Chemical Building PO Box 1260 Michigan Division Lynchburg, VA 24505 Midland, MI 48640 Mr Steve Gadler, Esq Ms Lynne Bernabei 2120 Carter Avenue Government Accountability Project St Paul, MN 55108 1901 Q Street, NW Washington, DC 20009 9/3/83 miO583-0429a100
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