ML19332B124
| ML19332B124 | |
| Person / Time | |
|---|---|
| Site: | Bailly |
| Issue date: | 09/18/1980 |
| From: | Osann E, Vollen R IZAAK WALTON LEAGUE OF AMERICA, PORTER COUNTY CHAPTER, OSANN, E. W., VOLLEN, R.J. & WHICHER, J.M. |
| To: | Atomic Safety and Licensing Board Panel |
| References | |
| ISSUANCES-CPA, NUDOCS 8009260011 | |
| Download: ML19332B124 (8) | |
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Q vem-N UNITED STATES OF AMERICA
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BEFORE THE ATOMIC SAFETY AND LICENSING BOARD y[S$[
ic.x In the Matter of
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NORTHERN INDIANA PUBLIC
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Docket No. 50-367 SERVICE COMPANY
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(Bailly Generating Station,
)
(Construction Permit Nuclear-1)
)
Extension)
PORTER COUNTY CHAPTER INTERVENORS' FIRST REQUEST TO THE NRC FOR PRODUCTION OF DOCUMENTS Porter County Chapter of the Izaak Walton League of America, Concerned Citizens Against the Bailly Nuclear Site, Businessmen for the Public Interest, Inc., James E. Newman and Mildred Warner
(" Porter County Chapter Intervenors") by their attorneys, pursuant to 10 C.F.R 52.944, hereby request that the Staff of the Nuclear Regulatory Commission produce, for inspection and copying on October 14,1980 at 10:00 A.M. at the offices of Business and Professional People for the Public Interest, Suite 1300, 109 N.
Dearborn,
Chicago, Illinois 60602, those of the documents des-cribed herein which are not available to Porter County Chapter Intervenors pursuant to 10 CFR $2.790 in the Public Document Room of the NRC.
The term " document" means any writing or recording of any kind, however produced or reproduced, including but not limited to letters, telegrams, memoranda, reports, studies, tape recordings,
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computer printouts, photographs, calendar and diary entries, minutes, pamphlets, notes, charts, tabulations, and records of meetings, conferences and telephone or other conversations or meetings, which are in the actual or constructive possession, custody or control of the NRC.
A described document includes all other documents which are attached to or relate to such document, including but not liuited to drafts of the described document.
The term "NIPSCO" includes Northern Indiana Public Service Company, its agents, employees, representatives, subsidiaries, consultants,
contractors or subcontractors.
The term "Bailly" refers to the Bailly Generating Station, Nuclear 1.
The term "NRC" includes the United States Nuclear Regulatory Commission, its staff, members, attorneys, employees, consultants, divisions or subdivisions, con-tractors and subcontractors.
1.
All documents which tend to prove or disprove, or which relate to the assertion that "because of a variety of delays beyond NIPSCO's control, NIPSCO has been able to achieve only the equivalent of approximately 14 months of construction" as asserted in the letter dated February 7, 1979 from NIPSCO by E. M. Shorb to Harold R. Denton (hereinafter the " February 7 letter.")
2.
All documents showing, referring to, or giving reasons why " construction was not resumed until after the Supreme Court finally denied petitions for certiorari on November 8, 1976" as asserted in the February 7 letter.
3.
All documents showing or referring to the date after November 8, 1976 dhen NIPSCO did resume construction of the Bailly plant, and the reasons why it did not do so earlier. O u.___
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All documents which tend to prove or disprove that at or about the time of November 8, 1976, "two months were required for remobilization of contractors" as asserted in the February 7 letter.
5.
All documents pertaining to the ins tallation of the slurry wall as described in the February 7 letter including all documents showing why plans for said slurry wall were not included in earlier construction plans or schedule.
6.
All documents which refer or relate to the assump-tion in the February 7 letter that pile placement would be resumed not later than March 1,1979.
7.
All documents which tend to prove or disprove that as of March 1,1979 there would have been an aggregate delay in construction of approximately 44 months, as asserted in the February 7 letter.
8.
All documents which tend to prove or disprove, or which relate to the assertion in the February 7 letter, that
" lengthier construction periods are required because of the additional engineering effort necessary to complete final design and corresponding construction work," including but not limited to "more numerous _and more d_etailed regulatory guides."
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9.
All documents which tend to prove or disprove, and all documents referring to or relating to the conclusion that the reasons stated in the February 7 letter constitute " good cause" for the requested extension of the latest completion date of the Bailly facility.
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10.
All documents which tend to prove or disprove, or relate to the assertion that the requested amendment has "no safety or environmental significance," as asserted in the February 7 letter.
11.
All drafts of, and notes and memoranda made in connection with, or documents which refer or relate to, the drafting of the February 7 letter.
12.
All documents which refer or relate to the assumption in the letter dated August 31, 1979 from NIPSCO by E. M. Shorb to Harold R. Denton (hereinafter the " August 31 letter")
that the NRC would complete its review of the foundation pilings proposal by October 1,1979, or which refer to the comnletion of such review.
13.
All documents which tend to prove or disprove or which relate to the assertion in the August 31 letter that delay resulting from the NaC review of the pile foundation proposal would be greater than seven months, including but not limited to 4
1 the reasons of remobilization of contractors and the impact of winter weather on driving activities.
14.
All documents which reflect, describe or show any " indications that NRC reviews arising from the Three Mile Island incident will extend the schedule of all plants under construction" as asserted in the Augus t 31 letter.
IS.
All documents which reflect or support, or which refer to the assertions that " delays have apparently... occurred with respect to Bailly N-1, in that members of the NRC Staff have extended the period for their review of the piles because they had to undertake generic reviews arising from TMI" as o e
asserted in the August 31 letter.
16.
All documenta referring to, reflecting or otherwise relating to all "ddditional information" referred to in the first sentence of the sixth paragraph of the August 31 letter.
17.
All documents which tend te prove or disprove or which refer to the assertion in the August 31 letter that 74 months from the commencement of concrete placement is a " reasonable estimate" of the time required to complete construction of the Bailly plant.
18.
All documents which tend to prove or disprove or which relate to the assertion that "9 months would be required to reach concrete placement after the NRC concurs in resumption of pile placement" as stated in the August 31 letter.
19.
All documents which tend to prove or disprove or which relate to the assertion that "approximately 15 months should be added to the requested extension to provide for uncer-tainties" as asserted in the August 31 letter.
20.
All documents which tend to prove or disprove or which relate to the assertion that December 1, 1987 is a " prudent projected completion date" for the requested Bailly facility permit amendment as asserted in the August 31 letter.
21.
All drafts of, and notes and memoranda made in con-nection with, or documents which refer or relate to, the drafting of the August 31 letter.
22.
All documents which describe or relate or refer to, or which evidence the reasons why, construction of the Bailly plant was not completed by September 1, 1979.
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23.
All documents related, referring or pertaining to the sealing of the ash ponds at the Bailly site.
24.
All analyses of or reports pertaining to seepage from the ash ponds, together with all documents upon which said analyses or reports were based or which were referred to in the preparation of said analyses or reports.
25.
All documents related, referring or pertaining to construction site dewatering, including but not limited to the effects of dewatering in the Indiana Dunes National Lakeshore, together with all records of monitoring showing pH changes, the presence of chemicals, changes in water levels, and any other changes in the flow, quality or quantity of ground water.
26.
All documents related, referring or pertaining to plans for construction dewatering or other means of controlling ground water flow on and near the Bailly plant site which were not or have not b'een undertaken.
27.
All documents describing, referring to or relating to the point or points of introduction, levels and charac-teristics of replacement water to be discharged in or near the Bailly site.
28.
All documents referring to, or relating to the rate of growth of demand for electric power on NIPSCO's system since May 1, 1974.
29.
All documents reflecting or showing any change in the estimated or predicted cost of construction or operation of the Bailly plant since May 1,1974.
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30.
All documents which tend to show, prove or
. disprove the competence, study, preparation, technical knowledge, and design ability of NIPSCO and its contractors and sub-contractors to construct the Bailly plant.
31.
All documents which tend to show, prove or disprove NIPSCO's financial capability to complete construction of the Bailly plant.
32.
All documents which tend to show, prove or disprove NIPSCO's ability to comply with all NRC regulations and other requirements which have come into effect since the issuance of the Bailly construction permit.
33.
All documents describing, referring to, or relating to the manner of installation of pilings, including the effects of the manner of installation, together with all analyses, tests and studies of any method of pile installation, whether or not such methods have been or will be used by NIPSCO.
34.
All documents related to, prepared in connection with, or referring to NIPSCO's response to the July 11, 1980 memorandum from Darrel G.
Eisenhut, a copy of which is attached hereto and marked " Exhibit A" for convenience.
35.
All documents related to, referring to or prepared in connection with the NRC evaluation of NIPSCO's requests for an extension of the latest completion date for the Bailly facility.
36.
All documents which identify persons or organi-zations who have possession, custody or control, or have knowledge of the existence of any'of the documents described in paragraphs 1 through 35 of this request. O
37.
All documents which identify persons who have knowledge of the matters referred to in paragraphs 1 through 36 of this request.
DATED:
September 18, 1980 Respectfully submitted, Robert J. Vollen Jane M. Whicher Edward W. Osann, Jr.
Robert L. Graham By:
/
Robert J.
V611en Attorneys for Porter County Chapter Intervenors Robert J. Vollen Jane M. Whicher 109 N. Dearborn St.
Chicago, IL 60602 (312) 641-5570 Edward W. Osann, Jr.
l One IBM Plaza Suite 4600 Chicago, IL 60611 (312) 822-9666 Robert L. Graham One IBM Plaza Chicago, IL 60611 (312) 222-9350
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j NUCLEAR REGULATORY COMMISSION WASMNGTON, D. C. 20066 July 11, 1930
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NJ TO ALL APPLICANTS FOR OPERATING LICENSES AND CONSTRU In the process of establishing priorities for the licensing reviews of operating license applications, we rely principally on the best estimater of the construction conpletion date of utilities.
In most cases, this date will be confirmed or modified by our Caseload Forecast Panel which usually visits a specific plant site no more than once a year.
Because of a number of recent slippages in dpplicants' Construction completion schedules, we believe it is appropriate at this time to request up-to-date schedules from all appitcants.
Accordingly, we are requesting you to advise us of your present best estimate of the construction completion date for your facility (facilities) and fuel load target date so that we may establish our licensing priorities based on the latest available l
data.
For your information I have enclosed a listing provided to the House Appropriations Subcomittee of target schedules for those plants seeking
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operating licenses in the next three years. Those appitcants not listed in License Application (FSAR and ER) to the NRC.the enclosure should p Upon receipt of your response, we anticipate a potential revision to our present licersing review priorities.
influenced by a hearing which is required for some of the OL appite Inasmuch as we are still limited in our casework by our manpower resources.
we request that your response be as up-to-date as possible.
Please provide your response within thirty days of receipt of this letter
- incerely, I
p 1h Divisiona[Osenhut, re 1 rector s Licensing Office of Nuclear Reactor Regulation Fnclosure:
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