ML19346A203

Supplemental Response to Porter Connty Chapter Intervenors Third Request for Production of Documents.Provides New Cost Estimate & Documents.Wh Eichhorn 810529 Ltr to Jm Whicher Encl.Related Correspondence

ML19346A203
Person / Time
Site:	Bailly
Issue date:	05/29/1981
From:	Eichhorn W EICHHORN, EICHHORN & LINK, NORTHERN INDIANA PUBLIC SERVICE CO.
To:	PORTER COUNTY CHAPTER INTERVENORS
Shared Package
ML19346A199	List: ML19346A198 ML19346A203 ML19346A206
References
NUDOCS 8106050386
Download: ML19346A203 (2)

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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION :d :JUN 1 19 M ' E iA c-,

BEFORE THE ATOMIC SAFETY AND LICENSING BOARD 'j\'U;".7[:.,...,..,l~ .

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-QdM In the Matter of ) Docket No. 50-367

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NORTHERN INDIANA PUBLIC ) (Construction Permit SERVICE COMPANY ) Extension)

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(Bailly Generating Station, ) May 29, 1981 Nuclear-1) )

NORTHERN INDIANA PUBLIC SERVICE COMPANY'S SUPPLEMENTAL RESPONSE TO PCCI'S THIRD REQUEST TO NIPSCO FOR PRODUCTIOh OF DOCUMENTS Northern Indiana Public Service Company (NIPSCO) hereby supplements its response to item 6 (a) of PCCI's Third Request to NIPSCO for Production of Documents by providing the new cost estimate and related documents.

Respectfully submitted, EICHH'ORN, EICHHORN & LINK 5243 Hohman Avenue Hammond, Indiana 46320 By: > > /h William H. Eichh6'rn Attorneys for Northern Indiana Public Service Company LOWENSTEIN, NEWMAN, REIS

& AXELRAD 1025 Connecticut Avenue, N.W.

Washington, D.C. 20036 8106050 3 %

?.EL.iTED CORRESPONDENCE C!CHHORN, EICHHORN & l INK FR E taE RICE F. CICMMOGN,JR. ATTORNEYS A71.AW weLLIAM M. CacMMORN Sa43 MONM AN AVCNU C

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KtCMARO A. M ANNING May 29, 1981 MAUREEN JoMNS OReMMER C O,7*,- h

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109 North Dearborn Street Suite 1300 ' , j j 5 g ,'e Chicago, Illinois 60602 Re: In the Matter of Northern Indiana Public Service Company (Bailly Generating Station, Nuclear 1)

Docket No. 50-367 (Construction Permit Extension)

Dear Ms. Whicher:

I refer to your letter of May 19, 1981, regarding your April 20 Motion to Compel Answers to your First Set of Interrogatories to NIPSCO.

Your Motion to Compel alleged that NIPSCO's answers to Inter-rogatories 19, 20 (a) and 20 (c) were "non-responsive." My letter of April 28 was an att :mpt to resolve your expressed concerna by explaining our views as to why your allegation is incorrect and why NIPSCO's answers to the interrogatories are indeed responsive.

Since my letter of April 28 was dispatched, the new cost estimate for Bailly N-1 has been completed. We are therefore filing supple-mentary answers to (First Set) Interrogatories 9 (b) and 20 (a) as well as a supplementary response to Item 6 (a) of your Third Request for Production of Documents. I trust you will agree that no motion to compel is required with respect to Interrogatory 20 (a) .

l With regard to the answers to Interrogatories 19 and 20 (c) ,

l our April 28 effort to resolve your concerns is apparently unsuccessful. Unfortunately, it is therefore necessary to rely upon the Board for resolution and we are filing our Answer to the Motion to Compel.

Yours very truly, EICHHORN, EICHHORN & LINK By: M Wi'lliam H. Eichhor'n l WHE/dgg e - ,