ML19329F040: Difference between revisions

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8006190          [3<f                  &
8006190          [3<f                  &


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The Interrogatories below are to be considered your continuing obligation. Accordingly, after you have answered these Inter-r ogatories, if additional information comes to your attention with respect to one or more of your Interrogatories or your answers thereto, then you are required to amend your answers to provide such additional information, l.-232. You have received a set of Interroga-tories addressed to the Applicant, Consumers Power Company.
The Interrogatories below are to be considered your continuing obligation. Accordingly, after you have answered these Inter-r ogatories, if additional information comes to your attention with respect to one or more of your Interrogatories or your answers thereto, then you are required to amend your answers to provide such additional information, l.-232. You have received a set of Interroga-tories addressed to the Applicant, Consumers Power Company.
Those Interrogatories were designed to ascertain inforta-tion which forms the basis for various opinions or conclusions or assertions contained within the Preliminary Safety Analysis Report for the proposed Midland Units ("PSAR"). Presumably you already have considered and have been privy to such information in the course of your evaluation of the proposed Midland Units or the drafting of your Petition to Intervene or, alternatively, you have not found it necessary or desir-able to make such a review in connection with such evaluation or Petition. Accordingly, with respect to each Interroga-tory asked of Applicant, if in your evaluation or during the preparation of your Petition to Intervene you have con-sidered the information in whole or in part which is called for by each such Interrogatory, then answer that Interrogatory    ;
Those Interrogatories were designed to ascertain inforta-tion which forms the basis for various opinions or conclusions or assertions contained within the Preliminary Safety Analysis Report for the proposed Midland Units ("PSAR"). Presumably you already have considered and have been privy to such information in the course of your evaluation of the proposed Midland Units or the drafting of your Petition to Intervene or, alternatively, you have not found it necessary or desir-able to make such a review in connection with such evaluation or Petition. Accordingly, with respect to each Interroga-tory asked of Applicant, if in your evaluation or during the preparation of your Petition to Intervene you have con-sidered the information in whole or in part which is called for by each such Interrogatory, then answer that Interrogatory    ;
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                                                              .                    ,
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  ..
      '
                                            .
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to the extent of your knowledge as if specifically asked of you; alternative]y, if any such Interrogatory calls for infor-nation uhich yo' have not considered in your evaluation or during the preparation of your Petition to Intervene, then you do not have to ansuer such Interrogatory, but in such case                  .
to the extent of your knowledge as if specifically asked of you; alternative]y, if any such Interrogatory calls for infor-nation uhich yo' have not considered in your evaluation or during the preparation of your Petition to Intervene, then you do not have to ansuer such Interrogatory, but in such case                  .
with respect to such Interrogatory and the information it calls for, state:
with respect to such Interrogatory and the information it calls for, state:
(a)    Why you did not find it necessary or desirabic to consider such information in connection with your evaluation of the proposed Midland Units; (b )'  Why you did not find it necessary or desirable to consider such information in connection uith the preparation of your Petition to Intervene; and (c)      Do you intend to offer any evidence, written or oral, or introduce any documents in the course of the pending hearing with regard to any of
(a)    Why you did not find it necessary or desirabic to consider such information in connection with your evaluation of the proposed Midland Units; (b )'  Why you did not find it necessary or desirable to consider such information in connection uith the preparation of your Petition to Intervene; and (c)      Do you intend to offer any evidence, written or oral, or introduce any documents in the course of the pending hearing with regard to any of the information called for by each such Interrogatory. If so, list the names and ad-            ;
                                                                                  .
the information called for by each such Interrogatory. If so, list the names and ad-            ;
i dresses of each person who will be called upon      ,
i dresses of each person who will be called upon      ,
                                                                                        '
your behalf to offer testimony together with a summary of what each such person's testimony will be and also identify in detail each docu-nent or writing which you intend to introduce.
your behalf to offer testimony together with a summary of what each such person's testimony will be and also identify in detail each docu-nent or writing which you intend to introduce.
                                                                              .
.
    .
  .
233. Unlecc otheruice covered by your ancuers to other Interrogatoriec (in uhich cace specify cuch ancuercj, state in detail the followinC:
233. Unlecc otheruice covered by your ancuers to other Interrogatoriec (in uhich cace specify cuch ancuercj, state in detail the followinC:
(a)  The names, titloc and positions of each person uhom you procently plan to call upon to intro-duce oral or written tectimony upon your behalf in the cource of the pendinC hearing; (b)  The area or arcac uhich uill be the subject of each such person's testimony; and (c ) A description of each document or uriting (ac that term is defined in Interrogatory No. 243 below) uhich you intend to introduce in the cource of the pending hearing in support of your Petition to Intervene or for any other purpoco.
(a)  The names, titloc and positions of each person uhom you procently plan to call upon to intro-duce oral or written tectimony upon your behalf in the cource of the pendinC hearing; (b)  The area or arcac uhich uill be the subject of each such person's testimony; and (c ) A description of each document or uriting (ac that term is defined in Interrogatory No. 243 below) uhich you intend to introduce in the cource of the pending hearing in support of your Petition to Intervene or for any other purpoco.
If in your ancuer you make reference to other than textual (exclusive of footnote) matter in the PSAR, then cet forth completely the text of each such other reference or attach a copy.
If in your ancuer you make reference to other than textual (exclusive of footnote) matter in the PSAR, then cet forth completely the text of each such other reference or attach a copy.
234. In connection uibh Paragraph A.2. of your Petition to Intervene, have you or any of your members, in any of said environmentally related activities studied or con-cidered thermal or nuclear polludion, effects of radiation (uhether lou level or not), effects of an MHA or LOCA and the
234. In connection uibh Paragraph A.2. of your Petition to Intervene, have you or any of your members, in any of said environmentally related activities studied or con-cidered thermal or nuclear polludion, effects of radiation (uhether lou level or not), effects of an MHA or LOCA and the i
 
citing of nu61 car pcuer planto in Michigan or c1ceuhere.
    ..      -_              _                              .                -  .
    ..                                -
                                                                                    -
  .
          .
                                                                                                '
        .
                                          '
i citing of nu61 car pcuer planto in Michigan or c1ceuhere.
If co, doccribe in detail each such activity including a deceription and identification of each report which unc pre-pared or ic bein; prepared in connection with such activities.
If co, doccribe in detail each such activity including a deceription and identification of each report which unc pre-pared or ic bein; prepared in connection with such activities.
If no cuch studice have been made, then state why not.          If in your ancuer you make reference to other than textual (exclu-4
If no cuch studice have been made, then state why not.          If in your ancuer you make reference to other than textual (exclu-4 cive of footnote) matter in-the PSAR, then cet forth completely the tent of each such other reference or attach a copy.
,
235    In connection with Paragraph B.l. of your Petition to Intervene, are the " fruits ar.d benefits of the most modern technolocy in c .fety and security" related solely to nuclear poner plants or are they related to modern tech-nology in general.        If the latter, list each step you have taken directly or indirectly, other than your intervention in this proceeding, to require industry in Midland to use modern
cive of footnote) matter in-the PSAR, then cet forth completely the tent of each such other reference or attach a copy.
'
235    In connection with Paragraph B.l. of your Petition to Intervene, are the " fruits ar.d benefits of the most modern technolocy in c .fety and security" related solely to nuclear poner plants or are they related to modern tech-
,
nology in general.        If the latter, list each step you have taken directly or indirectly, other than your intervention in this proceeding, to require industry in Midland to use modern
           ' technology in safety and security and in the abatement of 2
           ' technology in safety and security and in the abatement of 2
pollution.        If in your answer you make reference to other than 3          textual (exclucive of footnote) matter in the PSAR, then set i
pollution.        If in your answer you make reference to other than 3          textual (exclucive of footnote) matter in the PSAR, then set i
forth completely the text of each such other reference or at-tach a copy.
forth completely the text of each such other reference or at-tach a copy.
236. With respect to your. statement in Paragraph B.4. of your Petition to Intervene that the decision taken byLthe Ccmmission in this matter uill affect the health and safety of the.nenberc of'the Petitioner organication and their
236. With respect to your. statement in Paragraph B.4. of your Petition to Intervene that the decision taken byLthe Ccmmission in this matter uill affect the health and safety of the.nenberc of'the Petitioner organication and their
!
                                                                                                              . .. _,    -_. .-      . . - , -


                                              .
families, state in detail each effect,,uhether adverse or otheruise, which such decision will have upon the health and safety of the members of the Petitioner organication and their families. Also include within your answer what steps your environmentally conscious organization or its members has taken with ' respect to abating pollution problems (other than your intervention in this proceeding) from the present indus-trial installations within the City of Midland, Michigan.
  .
    .
      .
families, state in detail each effect,,uhether adverse or otheruise, which such decision will have upon the health and safety of the members of the Petitioner organication and their families. Also include within your answer what steps your environmentally conscious organization or its members has taken with ' respect to abating pollution problems (other than your intervention in this proceeding) from the present indus-
,
trial installations within the City of Midland, Michigan.
For example, did you or your members oppose, support or take any position regarding Dow Chemical Company's and/or Dow-Corning Company's variances from the standards set forth by the Michigan authorities having jurisdiction over air pollu-tion effluents. If in your ansuer you make refereace to other than textual (exclusive of footnote) matter in the PSAR, then_ set forth completely the text of each such other refer-ence or attach a copy.
For example, did you or your members oppose, support or take any position regarding Dow Chemical Company's and/or Dow-Corning Company's variances from the standards set forth by the Michigan authorities having jurisdiction over air pollu-tion effluents. If in your ansuer you make refereace to other than textual (exclusive of footnote) matter in the PSAR, then_ set forth completely the text of each such other refer-ence or attach a copy.
237. State in detail each fact, calculation and assumption upon uhich you base the conclusion reached in the second sentence of Paragraph B.S. of-your Petition to Intervene.
237. State in detail each fact, calculation and assumption upon uhich you base the conclusion reached in the second sentence of Paragraph B.S. of-your Petition to Intervene.
'
If in your ansuer you make reference to other than textual (exclusive of footnote) matter. in the PSAR, then set forth com-
If in your ansuer you make reference to other than textual (exclusive of footnote) matter. in the PSAR, then set forth com-
       .pletely the text of each such other reference or attach a copy.
       .pletely the text of each such other reference or attach a copy.
238. State in detail each fact, calculation and assumption upon which you make each of the conclusions,
238. State in detail each fact, calculation and assumption upon which you make each of the conclusions,
                                                                    ..          .- -      _-          .-      -- -


                                      ._ _        _ _.
_
        ..
                                                                                .
  -
          .
            .                  .
                      .
                                                            ,
    '
contentions and allocations set forth in Paragraphs C.1-7 of your Petition to Intervene., Include uithin your ansucr I
contentions and allocations set forth in Paragraphs C.1-7 of your Petition to Intervene., Include uithin your ansucr I
,
a doccription and identification of and the substance con-tained in each report, analysis, study or review that you have made, including any report, analysis, study or review of the PSAR, in connection uith such conclusions, contentions and allegations. If in your answer you make reference to other than. textual (exclusive of footnote) matter in the PSAR, then set forth completely the text of each such other reference or.
a doccription and identification of and the substance con-tained in each report, analysis, study or review that you have made, including any report, analysis, study or review of the PSAR, in connection uith such conclusions, contentions and allegations. If in your answer you make reference to other than. textual (exclusive of footnote) matter in the PSAR, then set forth completely the text of each such other reference or.
attach a copy.
attach a copy.
;
;
239.-    With respect to the sentence beginning at the
239.-    With respect to the sentence beginning at the bottom of page 4 and ending at the top of page 5 of your Petition to Intervene, state and. describe in detail the " expert testimon'/" referred to therein uhich you presently intend to introduce in the proceeding, and describe in detail what you mean by your use of the words, " official notice."    If in your answer you make reference to other than textual (exclusive of footnote) matter in the PSAR, then set forth completely the text of each such other reference or attach a copy.
                                                                                  <
bottom of page 4 and ending at the top of page 5 of your Petition to Intervene, state and. describe in detail the " expert testimon'/" referred to therein uhich you presently intend to
-
introduce in the proceeding, and describe in detail what you mean by your use of the words, " official notice."    If in your answer you make reference to other than textual (exclusive of
-
footnote) matter in the PSAR, then set forth completely the text of each such other reference or attach a copy.
240. State the date upon which the Midland Nuclear  l Pouer'Cc=mittee was first conceived, the date of its actual formation and the date of its first organisational meeting.
240. State the date upon which the Midland Nuclear  l Pouer'Cc=mittee was first conceived, the date of its actual formation and the date of its first organisational meeting.
l If in your answer you make reference to other than textual          l
l If in your answer you make reference to other than textual          l (exclusive of footnote) matter in the PSAR, then set forth          j l
                                                                                  .
(exclusive of footnote) matter in the PSAR, then set forth          j l
                                                                                  ,
                                                                               )
                                                                               )
:
1
1
      .            .      -        .      .-- - .  ..


                                    .
_
  -
      .
        *
    .
                  .
completely the tent of'ench'such other reference or attach a copy.
completely the tent of'ench'such other reference or attach a copy.
241. State in detail each fact, calculation and assumption upon which you base your statements, conclusions
241. State in detail each fact, calculation and assumption upon which you base your statements, conclusions
           'and assertions contained in the paragraph on page 5 of your Petition tb Intervene which begins, "The Petitioner concludes" and ends "the Consumers Power Ccmpany."    If in your answer you make. reference to other than textual (exclusive of foot-note) matter in the PSAR, then set forth completely the text
           'and assertions contained in the paragraph on page 5 of your Petition tb Intervene which begins, "The Petitioner concludes" and ends "the Consumers Power Ccmpany."    If in your answer you make. reference to other than textual (exclusive of foot-note) matter in the PSAR, then set forth completely the text of each such other reference or attach a copy.
,
242. Have Applicant, Don Chemical Company, Dow-Corning Company or any subsidiary of Dow Chemical or Dow-Corning ever been cited for or investigated about a violation or alleged violation of the Atomic Energy Act, any of its rules, regulations or orders, an Atomic Energy Commission licence or any of its te1hnical. specifications or the rule, order, decree, regulatiot of any state or other federal agency or official having any manner of jurisdiction over any of their operations which are the subject of an Atomic Energy Commission license. If so, then:
of each such other reference or attach a copy.
242. Have Applicant, Don Chemical Company, Dow-Corning Company or any subsidiary of Dow Chemical or Dow-Corning ever been cited for or investigated about a violation or alleged violation of the Atomic Energy Act, any of its rules, regulations or orders, an Atomic Energy Commission
,
licence or any of its te1hnical. specifications or the rule,
'
order, decree, regulatiot of any state or other federal agency or official having any manner of jurisdiction over any of their operations which are the subject of an Atomic Energy Commission license. If so, then:
(a)  D3 scribe in detail each instance of each such citation or investigation; (b)  List and identify in sufficient detail a des-cription of each uriting as defined in Inter-rogatory No. 243 below which is in your
(a)  D3 scribe in detail each instance of each such citation or investigation; (b)  List and identify in sufficient detail a des-cription of each uriting as defined in Inter-rogatory No. 243 below which is in your
                                                                        --            -            ,_        .    .- -


_
_
    -          ...
.
      .
        .
                    .
possession or control with respect to each such citation or investigation; (c) State and describe the resolution, if any, of each such citation or investigation; and (d)  State shat steps you have taken or suggested or intend to take or suggest to prevent cir-
possession or control with respect to each such citation or investigation; (c) State and describe the resolution, if any, of each such citation or investigation; and (d)  State shat steps you have taken or suggested or intend to take or suggest to prevent cir-
   ,                        cumstances which led to each such citation or investigation from occurring again or occurring at the proposed Midland Units.
   ,                        cumstances which led to each such citation or investigation from occurring again or occurring at the proposed Midland Units.
Line 173: Line 87:
(a)  Your participation in any way in the designing, constructing or operating of the proposed Midland Units; i
(a)  Your participation in any way in the designing, constructing or operating of the proposed Midland Units; i
(b)  Your evaluation of the proposed Midland Units      i l
(b)  Your evaluation of the proposed Midland Units      i l
                                                                              '
regarding its siting, its designing, its con-struction, its safety or its proposed operation; (c)  Financial aspects of the building, designing or constructing of the proposed Midland Units, w
regarding its siting, its designing, its con-struction, its safety or its proposed operation; (c)  Financial aspects of the building, designing or constructing of the proposed Midland Units,
                                                      .
                                                        -
w


                              -
including but not limited to the sale of processed steam; to anyone, for industrial purposes; (d) Your decision to approve of a participation in any uay in the posigning, constructing or securing of a construction permit for the pro-posed Midland Units; and (c) Any Interrogatory or ansuer to any Interrogatory filed herein.
%  .
As used uithin these Interrogatories, the word "uritings" or words of similar import shall include all written, typed, printed and photostated matter, including photographs, dupli-4 cate originals, carbon copics, Thermofax copies, photostatic                3 copics and other copies thereof, including drafts thereof, in your possession, custody or control, written, made, delivered                ;
        -.
or received at any time.up to and including March 22, 1971,                  l including, without limiting the generality of the definition, all correspondence, telegrams, memoranda, minutes of meetings,
      -              -
                                    .
including but not limited to the sale of processed steam; to anyone, for industrial purposes;
,
(d) Your decision to approve of a participation in any uay in the posigning, constructing or
,
securing of a construction permit for the pro-posed Midland Units; and (c) Any Interrogatory or ansuer to any Interrogatory
'
filed herein.
As used uithin these Interrogatories, the word "uritings" or words of similar import shall include all written, typed, printed and photostated matter, including photographs, dupli-4 cate originals, carbon copics, Thermofax copies, photostatic                3
'-
copics and other copies thereof, including drafts thereof, in your possession, custody or control, written, made, delivered                ;
or received at any time.up to and including March 22, 1971,                  l
.
including, without limiting the generality of the definition, all correspondence, telegrams, memoranda, minutes of meetings,
  ;          client' memoranda,_ account cards, leases, documents of title, receipts, cancelled checks, bank statements, records of tele-phone calls, summaries of meetings, agreements, contracts and notes, uhether formal or informal.
  ;          client' memoranda,_ account cards, leases, documents of title, receipts, cancelled checks, bank statements, records of tele-phone calls, summaries of meetings, agreements, contracts and notes, uhether formal or informal.
At your option, depending upon convenience to all other' parties thereof, instead of ansucring this Interrogatory              l
At your option, depending upon convenience to all other' parties thereof, instead of ansucring this Interrogatory              l 10-
                                              -
10-
                                  .
     ,              .-  ,      -    --  ,-r    .---g-+ -m- y            , , , - , , -,
     ,              .-  ,      -    --  ,-r    .---g-+ -m- y            , , , - , , -,


o  .
o  .
        -
  .
      ,                        .
                .
you inay' chcone to rollou elt.her t.he uong.en t, t ori inutte tit n 1 t t.. r by Myron Cherry to all counsel dated March 8, 1971, or the more formal method of depositionc under oath.            If you do not so choose by notice to us within ten days after receipt of these Interrogatorics, you shall be required to answer this Interrocatory.
you inay' chcone to rollou elt.her t.he uong.en t, t ori inutte tit n 1 t t.. r by Myron Cherry to all counsel dated March 8, 1971, or the more formal method of depositionc under oath.            If you do not so choose by notice to us within ten days after receipt of these Interrogatorics, you shall be required to answer this Interrocatory.
Finally, thic Interrogatory or any other alternative methods of identifying relevant uritings are not intended to call for writings uhich are cubject to a valid privilege; however, you shall be required to describe generally the uritings as to which you may clain privilege in order that opportunity for argument thereon may be had.
Finally, thic Interrogatory or any other alternative methods of identifying relevant uritings are not intended to call for writings uhich are cubject to a valid privilege; however, you shall be required to describe generally the uritings as to which you may clain privilege in order that opportunity for argument thereon may be had.

Revision as of 19:26, 31 January 2020

First Set of Interrogatories Directed to Midland Nuclear Power Committee Re Nonpriveleged Documents
ML19329F040
Person / Time
Site: Midland
Issue date: 03/22/1971
From: Cherry M
CHERRY, M.M./CHERRY, FLYNN & KANTER, Saginaw Intervenor, Sierra Club
To:
CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.)
References
NUDOCS 8006190834
Download: ML19329F040 (11)
v • d • e


Text

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' UCCKET tiUMBER q PROD. & UTR, EAC. 30 'Y[rh3

s. 00CElicG 2 US!EC 1

I MAR 231971

  • h g  %'sYrNe'Y UIIITED STATES OF AMERICA -

ag ATOMIC EHERGY COMMISSIOIT b

o>

  • In The Matter of * .

COIISUMERS POWER COMPANY Docket Hos. 50-329 (MIDLAITD PLAliT UHITS 1 and 2) 50-330 FIRST SET OF IHTERROGATORIES OF CERTAIN IIiTERVEHORS DIRECTED TO MIDLAND HUCLEAR POWER COMMITTEE Pursuant to part 2 of the Rules of Practice of the Atomic Energy Commission and the itomic Energy Safety and Licensing Board's order permitting the serving of these Inter-rogatories and requiring their a,nswer, Intervenors request the following Interrogatories be answered fully in writin6 and under oath by one or more representatives of Midland Huclear Power Committee (hereinafter " Committee") who has personal knowledge thereof or is the closest to having personal knowl-edge thereof. If the Interrogatories are answered by more than one person, whether or not he verifies the answers, and whether or not he is a representative of Committee, such person's name and title should be set forth together with an identification of which Interrogatories he is responsible for answering. To the extent it is applicable, and unless your answer specifically states otherwise, it shall be assumed that each of these answers applies equally to each of the proposed Midland Units 1 and 2.

8006190 [3<f &

The Interrogatories below are to be considered your continuing obligation. Accordingly, after you have answered these Inter-r ogatories, if additional information comes to your attention with respect to one or more of your Interrogatories or your answers thereto, then you are required to amend your answers to provide such additional information, l.-232. You have received a set of Interroga-tories addressed to the Applicant, Consumers Power Company.

Those Interrogatories were designed to ascertain inforta-tion which forms the basis for various opinions or conclusions or assertions contained within the Preliminary Safety Analysis Report for the proposed Midland Units ("PSAR"). Presumably you already have considered and have been privy to such information in the course of your evaluation of the proposed Midland Units or the drafting of your Petition to Intervene or, alternatively, you have not found it necessary or desir-able to make such a review in connection with such evaluation or Petition. Accordingly, with respect to each Interroga-tory asked of Applicant, if in your evaluation or during the preparation of your Petition to Intervene you have con-sidered the information in whole or in part which is called for by each such Interrogatory, then answer that Interrogatory  ;

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to the extent of your knowledge as if specifically asked of you; alternative]y, if any such Interrogatory calls for infor-nation uhich yo' have not considered in your evaluation or during the preparation of your Petition to Intervene, then you do not have to ansuer such Interrogatory, but in such case .

with respect to such Interrogatory and the information it calls for, state:

(a) Why you did not find it necessary or desirabic to consider such information in connection with your evaluation of the proposed Midland Units; (b )' Why you did not find it necessary or desirable to consider such information in connection uith the preparation of your Petition to Intervene; and (c) Do you intend to offer any evidence, written or oral, or introduce any documents in the course of the pending hearing with regard to any of the information called for by each such Interrogatory. If so, list the names and ad-  ;

i dresses of each person who will be called upon ,

your behalf to offer testimony together with a summary of what each such person's testimony will be and also identify in detail each docu-nent or writing which you intend to introduce.

233. Unlecc otheruice covered by your ancuers to other Interrogatoriec (in uhich cace specify cuch ancuercj, state in detail the followinC:

(a) The names, titloc and positions of each person uhom you procently plan to call upon to intro-duce oral or written tectimony upon your behalf in the cource of the pendinC hearing; (b) The area or arcac uhich uill be the subject of each such person's testimony; and (c ) A description of each document or uriting (ac that term is defined in Interrogatory No. 243 below) uhich you intend to introduce in the cource of the pending hearing in support of your Petition to Intervene or for any other purpoco.

If in your ancuer you make reference to other than textual (exclusive of footnote) matter in the PSAR, then cet forth completely the text of each such other reference or attach a copy.

234. In connection uibh Paragraph A.2. of your Petition to Intervene, have you or any of your members, in any of said environmentally related activities studied or con-cidered thermal or nuclear polludion, effects of radiation (uhether lou level or not), effects of an MHA or LOCA and the i

citing of nu61 car pcuer planto in Michigan or c1ceuhere.

If co, doccribe in detail each such activity including a deceription and identification of each report which unc pre-pared or ic bein; prepared in connection with such activities.

If no cuch studice have been made, then state why not. If in your ancuer you make reference to other than textual (exclu-4 cive of footnote) matter in-the PSAR, then cet forth completely the tent of each such other reference or attach a copy.

235 In connection with Paragraph B.l. of your Petition to Intervene, are the " fruits ar.d benefits of the most modern technolocy in c .fety and security" related solely to nuclear poner plants or are they related to modern tech-nology in general. If the latter, list each step you have taken directly or indirectly, other than your intervention in this proceeding, to require industry in Midland to use modern

' technology in safety and security and in the abatement of 2

pollution. If in your answer you make reference to other than 3 textual (exclucive of footnote) matter in the PSAR, then set i

forth completely the text of each such other reference or at-tach a copy.

236. With respect to your. statement in Paragraph B.4. of your Petition to Intervene that the decision taken byLthe Ccmmission in this matter uill affect the health and safety of the.nenberc of'the Petitioner organication and their

families, state in detail each effect,,uhether adverse or otheruise, which such decision will have upon the health and safety of the members of the Petitioner organication and their families. Also include within your answer what steps your environmentally conscious organization or its members has taken with ' respect to abating pollution problems (other than your intervention in this proceeding) from the present indus-trial installations within the City of Midland, Michigan.

For example, did you or your members oppose, support or take any position regarding Dow Chemical Company's and/or Dow-Corning Company's variances from the standards set forth by the Michigan authorities having jurisdiction over air pollu-tion effluents. If in your ansuer you make refereace to other than textual (exclusive of footnote) matter in the PSAR, then_ set forth completely the text of each such other refer-ence or attach a copy.

237. State in detail each fact, calculation and assumption upon uhich you base the conclusion reached in the second sentence of Paragraph B.S. of-your Petition to Intervene.

If in your ansuer you make reference to other than textual (exclusive of footnote) matter. in the PSAR, then set forth com-

.pletely the text of each such other reference or attach a copy.

238. State in detail each fact, calculation and assumption upon which you make each of the conclusions,

contentions and allocations set forth in Paragraphs C.1-7 of your Petition to Intervene., Include uithin your ansucr I

a doccription and identification of and the substance con-tained in each report, analysis, study or review that you have made, including any report, analysis, study or review of the PSAR, in connection uith such conclusions, contentions and allegations. If in your answer you make reference to other than. textual (exclusive of footnote) matter in the PSAR, then set forth completely the text of each such other reference or.

attach a copy.

239.- With respect to the sentence beginning at the bottom of page 4 and ending at the top of page 5 of your Petition to Intervene, state and. describe in detail the " expert testimon'/" referred to therein uhich you presently intend to introduce in the proceeding, and describe in detail what you mean by your use of the words, " official notice." If in your answer you make reference to other than textual (exclusive of footnote) matter in the PSAR, then set forth completely the text of each such other reference or attach a copy.

240. State the date upon which the Midland Nuclear l Pouer'Cc=mittee was first conceived, the date of its actual formation and the date of its first organisational meeting.

l If in your answer you make reference to other than textual l (exclusive of footnote) matter in the PSAR, then set forth j l

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completely the tent of'ench'such other reference or attach a copy.

241. State in detail each fact, calculation and assumption upon which you base your statements, conclusions

'and assertions contained in the paragraph on page 5 of your Petition tb Intervene which begins, "The Petitioner concludes" and ends "the Consumers Power Ccmpany." If in your answer you make. reference to other than textual (exclusive of foot-note) matter in the PSAR, then set forth completely the text of each such other reference or attach a copy.

242. Have Applicant, Don Chemical Company, Dow-Corning Company or any subsidiary of Dow Chemical or Dow-Corning ever been cited for or investigated about a violation or alleged violation of the Atomic Energy Act, any of its rules, regulations or orders, an Atomic Energy Commission licence or any of its te1hnical. specifications or the rule, order, decree, regulatiot of any state or other federal agency or official having any manner of jurisdiction over any of their operations which are the subject of an Atomic Energy Commission license. If so, then:

(a) D3 scribe in detail each instance of each such citation or investigation; (b) List and identify in sufficient detail a des-cription of each uriting as defined in Inter-rogatory No. 243 below which is in your

possession or control with respect to each such citation or investigation; (c) State and describe the resolution, if any, of each such citation or investigation; and (d) State shat steps you have taken or suggested or intend to take or suggest to prevent cir-

, cumstances which led to each such citation or investigation from occurring again or occurring at the proposed Midland Units.

If in your anstrer you make reference to other than textuc '.

(exclusive of footnote) matter in the PSAR, then set forth completely the text of each such other reference or attach a copy.

243 List and describe in sufficient detail so that it can be identified, each document which is in your possession or under your control which relates to, refers to or concerns any of the follouing:

(a) Your participation in any way in the designing, constructing or operating of the proposed Midland Units; i

(b) Your evaluation of the proposed Midland Units i l

regarding its siting, its designing, its con-struction, its safety or its proposed operation; (c) Financial aspects of the building, designing or constructing of the proposed Midland Units, w

including but not limited to the sale of processed steam; to anyone, for industrial purposes; (d) Your decision to approve of a participation in any uay in the posigning, constructing or securing of a construction permit for the pro-posed Midland Units; and (c) Any Interrogatory or ansuer to any Interrogatory filed herein.

As used uithin these Interrogatories, the word "uritings" or words of similar import shall include all written, typed, printed and photostated matter, including photographs, dupli-4 cate originals, carbon copics, Thermofax copies, photostatic 3 copics and other copies thereof, including drafts thereof, in your possession, custody or control, written, made, delivered  ;

or received at any time.up to and including March 22, 1971, l including, without limiting the generality of the definition, all correspondence, telegrams, memoranda, minutes of meetings,

client' memoranda,_ account cards, leases, documents of title, receipts, cancelled checks, bank statements, records of tele-phone calls, summaries of meetings, agreements, contracts and notes, uhether formal or informal.

At your option, depending upon convenience to all other' parties thereof, instead of ansucring this Interrogatory l 10-

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you inay' chcone to rollou elt.her t.he uong.en t, t ori inutte tit n 1 t t.. r by Myron Cherry to all counsel dated March 8, 1971, or the more formal method of depositionc under oath. If you do not so choose by notice to us within ten days after receipt of these Interrogatorics, you shall be required to answer this Interrocatory.

Finally, thic Interrogatory or any other alternative methods of identifying relevant uritings are not intended to call for writings uhich are cubject to a valid privilege; however, you shall be required to describe generally the uritings as to which you may clain privilege in order that opportunity for argument thereon may be had.

Saginaw Valley.Huclear Study Group Citizens Committee for the Environ-mental Protection of Michigan Sierra Club United Auto Workers of America Trout Unlimited West Michigan Environmental Action Council, Inc.

Environmental Lau Society of the University of Michigan Law Students I

Y By / U AE" F f [H Myron iu Cherry, their at" rney Dated: March 22, 1971. ,

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