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Category:INTERROGATORIES; RESPONSES TO INTERROGATORIES
MONTHYEARML20049K0821982-03-23023 March 1982 First Interrogatory Re Site Restoration ML20010D1191981-08-18018 August 1981 Objections to Porter County Chapter Intervenors' Third Set of Interrogatories 9,10,11 & 42.Requests Protective Order Providing That No Further Response to Interrogatory 42 Is Required.Related Correspondence ML20010D1181981-08-18018 August 1981 Response to People of State of Il Second Set of Interrogatories.Related Correspondence ML20010D2441981-08-18018 August 1981 Objection to State of Il Second Set of Interrogatories, Interrogatories 12(c),13(b) & 13 (C).Matters Already Reviewed in Original CP Proceeding & Irrelevent to Instant Proceeding.Related Correspondence ML20010D1201981-08-18018 August 1981 Response to Porter County Chapter Intervenors' Third Set of Interrogatories.Related Correspondence ML20010C5911981-08-13013 August 1981 First Set of Interrogatories Directed to NRC ML20010C5901981-08-13013 August 1981 Application for Discovery Directed to NRC Re NRC Staff Evaluation of Bailly CP Extension Request. ML20010C5921981-08-13013 August 1981 First Set of Interrogatories Directed to Util.Certificate of Svc Encl ML20010C1581981-08-11011 August 1981 Seventh Request for Production of Documents,Directed to Util.Related Correspondence ML20010C2481981-08-11011 August 1981 Fifth Request for Production of Documents Directed to Nrc. Related Correspondence ML20010C4921981-08-11011 August 1981 First Request for Production of Documents Directed to NRC ML20010C4971981-08-11011 August 1981 First Request for Production of Documents Directed to Util ML20010C1421981-08-11011 August 1981 Application to ASLB for Discovery on Listed NRC Documents. Certificate of Svc Encl.Related Correspondence ML20010C1531981-08-11011 August 1981 Third Set of Interrogatories Directed to Nrc.Related Correspondence ML20010C2391981-08-11011 August 1981 Fifth Set of Interrogatories Directed to Util.Related Correspondence ML20010B3221981-08-0303 August 1981 Supplemental Answers to Util Second Set of Interrogatories. Lists Some Rare Species Which Could Disappear from Dunes Ecosystem.Change in Shape of Cone of Depression Is Relevant in Determining Water Changes.Certificate of Svc Encl ML20010B3201981-08-0303 August 1981 Answers to Util Third Set of Interrogatories Re Dewatering.Experiences at River Bend Units 1 & 2 & Caorso,Italy Suggest That Water Infiltration Consititutes Problem Needing Remedial Steps.Related Correspondence ML20009H2371981-08-0303 August 1981 Answers & Objections to Util Third Set of Interrogatories Re Const Dewatering,Util Mitigation Plan & Water Tables. Certificate of Svc,Affirmation & 810803 Ltr Encl.Related Correspondence ML20009G9031981-07-31031 July 1981 Amend to Fourth Set of Interrogatories Directed to State of Il.Interrogatories 42(c) & 45(c) Have Incorrect Ref to Other Interrogatories.Related Correspondence ML20009G9011981-07-31031 July 1981 Amend to Fourth Set of Interrogatories Directed to M Warner. Interrogatories 42(c) & 45(c) Have Incorrect Ref to Other Interrogatories ML20009H4891981-07-31031 July 1981 Second Set of Interrogatories Directed to NRC Re Site Dewatering & Replacement Water Levels.Related Correspondence ML20009G9061981-07-31031 July 1981 Amend to Fourth Set of Interrogatories Directed to Businessmen for Public Interest.Interrogatories 42(c) & 45(c) Have Incorrect Ref to Other Interrogatories.Related Correspondence ML20009H4921981-07-31031 July 1981 Fourth Request for Production of Documents Directed to Nrc. Related Correspondence ML20009H4911981-07-31031 July 1981 Fourth Set of Interrogatories Directed to Util Re Site Dewatering.Related Correspondence ML20009G9041981-07-31031 July 1981 Amend to Fourth Set of Interrogatories Directed to Je Newman.Interrogatories 42(c) & 45(c) Have Incorrect Ref to Other Interrogatories.Related Correspondence ML20009G9091981-07-31031 July 1981 Amend to Fourth Set of Interrogatories Directed to Concerned Citizens Against Bailly Nuclear Site.Interrogatories 42(c) & 45(c) Have Incorrect Ref to Other Interrogatories. Related Correspondence ML20009G9101981-07-31031 July 1981 Amend to Fourth Set of Interrogatories Directed to Porter County Chapter Intervenors.Interrogatories 42(c) & 45(c) Have Incorrect Ref to Other Interrogatories.Related Correspondence ML20009G8741981-07-30030 July 1981 Fourth Set of Interrogatories Directed to State of Il Re Basis for Allegations,Identification of Investigations NRC Did Not Perform & Disagreements W/Nrc Evaluation of Request for CP Extension.Related Correspondence ML20009H0451981-07-30030 July 1981 Third Set of Interrogatories Directed to Util.Related Correspondence ML20009G8931981-07-30030 July 1981 Fourth Set of Interrogatories Directed to Porter County Chapter Intervenors Re Basis for Allegations & Disagreement W/Nrc Evaluation of Request of CP Extension.Related Correspondence ML20009G9561981-07-30030 July 1981 First Request for Production of Documents Upon Which Je Newman Relied on in Formulating Contentions.Related Correspondence ML20009G8791981-07-30030 July 1981 Fourth Set of Interrogatories Directed to M Warner Re Basis for Allegations & Basis for Answers Supporting Conclusions That Good Cause Does Not Exist to Extend Cp.Related Correspondence ML20009G8731981-07-30030 July 1981 Fourth Set of Interrogatories Directed to Je Newman Re Basis for Allegations & Disagreements W/Nrc Evaluation of Request for CP Extension & W/D'Appolonia Assessment of Dewatering Influence.Related Correspondence ML20009G9531981-07-30030 July 1981 First Request for Production of Documents Upon Which Businessmen for Public Interest Relied on in Formulating Contentions.Related Correspondence ML20009H0491981-07-30030 July 1981 Fifth Request to Northern in Public Svc Co for Production of Documents Described in Response to Intervenor Third Set of Interrogatories.Related Correspondence ML20009G9451981-07-30030 July 1981 First Request for Production of Documents Upon Which Porter County Chapter Intervenors Relied on in Formulating Contentions.Related Correspondence ML20009G9471981-07-30030 July 1981 First Request for Production of Documents Upon Which Concerned Citizens Against Bailly Nuclear Site Relied in Formulating Contentions.Related Correspondence ML20009G9931981-07-30030 July 1981 First Request for Production of Documents Upon Which M Warner Relied in Formulating Contentions.Related Correspondence ML20009G9501981-07-30030 July 1981 First Request for Production of Documents Upon Which State of Il Relied on in Formulating Contentions.Related Correspondence ML20009G9171981-07-30030 July 1981 Fourth Set of Interrogatories Directed to Concerned Citizens Against Bailly Nuclear Site Re Basis for Allegations & Disagreements W/Nrc Evaluation of Request for CP Extension. Related Correspondence ML20009G8711981-07-30030 July 1981 Fourth Set of Interrogatories Directed to Businessmen for Public Interest,Inc Re Basis for Allegations & Disagreements W/Nrc Evaluation of Request for CP Extension.Related Correspondence ML20009E3061981-07-23023 July 1981 Response Opposing Porter County Chapter Intervenors' 810519 Fourth Request for Production of Documents.Request Is W/O Merit & Should Be Denied ML20009D0441981-07-15015 July 1981 Response Opposing Util Second Motion to Compel Answers to Second Set of Interrogatories.Certificate of Svc Encl ML20009B5391981-07-10010 July 1981 Motion for Extension Until 810803 to File Answers or Objections to Util 810622 Third Set of Interrogatories. Extension Will Not Prejudice Any Party.Certificate of Svc Encl ML20009B7001981-07-0808 July 1981 Response to State of Il First Set of Interrogatories Directed to Util.Certificate of Svc Encl ML20004G1111981-06-22022 June 1981 Third Set of Interrogatories Directed to M Warner Re Permit to Extend Period of Const Dewatering & Proposed Water Replacement Program.Related Correspondence ML20004G1041981-06-22022 June 1981 Third Set of Interrogatories Directed to Je Newman Re Permit to Extend Period of Const Dewatering & Proposed Water Replacement Program.Related Correspondence ML20004G1071981-06-22022 June 1981 Third Set of Interrogatories Directed to State of Il Re Depth of Dewatering Required After Completion of Foundation.Certificate of Svc Encl.Related Correspondence ML20004G1161981-06-22022 June 1981 Third Set of Interrogatories Directed to Businessmen for Public Interest,Inc Re Dewatering Effects on Lakeshore. Related Correspondence ML20005A1021981-06-22022 June 1981 Third Set of Interrogatories Directed to Porter County Chapter of Izaak Walton League of America,Inc Re Permit to Extend Period of Const Dewatering & Proposed Water Replacement Program.Related Correspondence 1982-03-23
[Table view] Category:LEGAL TRANSCRIPTS & ORDERS & PLEADINGS
MONTHYEARML20126M8141985-05-23023 May 1985 Order Denying Business & Prof People for Public Interest Application for Atty Fees Under Equal Access to Justice Act. Commission FY82 Appropriation Act Prohibited Funding of Intervenors.Served on 850523 ML20058J0861982-08-0606 August 1982 Order Holding Intervenor Business & Prof People for Public Interest Request for Award of Atty Fees & Expenses Under Equal Access to Justice Act Until Question of Availability of Funds Solved.Nrc Will Seek Comptroller General Opinion ML20054J0811982-06-18018 June 1982 Notice of ASLB Reconstitution.H Grossman,Chairman & K Mccollom & Rl Holton,Members ML20054F9471982-06-0707 June 1982 Memorandum Supporting Business & Prof People for Public Interest Application for Award of Atty Fees & Expenses ML20053E6801982-06-0404 June 1982 Application for Award of Fees & Expenses Under Equal Access to Justice Act.Fees Requested for Svcs Re Proceedings on Proposed Amend to CP to Extend Completion Date & Proposed Amend to Allow Foundation of Short Pilings ML20053E6821982-06-0404 June 1982 Affidavit of Rj Vollen Re Costs & Legal Svcs Provided ML20053E6831982-06-0404 June 1982 Affidavit of Jm Vollen Re Costs & Legal Svcs Provided ML20053E6851982-06-0404 June 1982 Memorandum of Law Supporting Application for Award of Fees & Expenses Under Equal Access to Justice Act.Proceedings Pending on Effective Date of Act,Party Prevailed & Amount of Fees & Expenses Compensable.Certificate of Svc Encl ML20053E6841982-06-0303 June 1982 Affidavit of Rl Graham Re Reasonable & Customary Charges of Attys ML20052C7281982-04-29029 April 1982 Answer Objecting to & Proposing Mods to ASLB 820412 Memorandum & Order.Objects to Proposed Order Calling for Immediate Termination of Proceedings.No Assurance Util Will Comply If Proceedings Terminated.W/Certificate of Svc ML20050A5201982-03-29029 March 1982 Response Opposing Porter County Chapter Intervenors 820323 Pleading.No Legal Authority Shown for Intervenor Attempt to Exercise NRC Responsibility for Monitoring Compliance W/Aslb Orders.Certificate of Svc Encl ML20049K0791982-03-23023 March 1982 Motion for Leave to Take Limited Discovery.Suppls Position Re Timing of Termination of Proceeding.Util Refusal to Supply Intervenors W/Info Re Compliance W/Aslb 820129 Order Illustrates Need for Jurisdiction.W/Certificate of Svc ML20049K0821982-03-23023 March 1982 First Interrogatory Re Site Restoration ML20069B8901982-03-0101 March 1982 Response Opposing Util 820210 Motion for Reconsideration of 820129 Order.No Legal Basis Presented for Util Argument That ASLB Exceeded Jurisdiction.Certificate of Svc Encl ML20041A4721982-02-16016 February 1982 Motion for Reconsideration of ASLB 820129 Order Requiring Implementation of Revised Plan.Aslb Course Falls Short of ASLB Responsibility to Issue Timely Rulings,Is Unfair to Util & Exceeds ASLB Authority.Certificate of Svc Encl ML20040C7011982-01-25025 January 1982 Responses Opposing Porter County Chapter Intervenors 820108 Motion for Order Imposing Condition of Withdrawal.Nrc Unauthorized to Require Applicant to Pay Intervenors' Fees & Expenses.Certificate of Svc Encl ML20039G0811982-01-0808 January 1982 Motion for Order Imposing Condition Upon Withdrawal of Util Application.Expenses Incurred by Intervenor Were Substantial & Info Developed in Discovery Cast Doubt on Merits of Util Application.Certificate of Svc Encl ML20039C2601981-12-22022 December 1981 Response Opposing Porter County Chapter Intervenors 811209 Motion to Compel Util to Implement Revised Plan for Restoration.Util Will Act When Termination Order Issued, Weather Permitting.Certificate of Svc Encl ML20062L9641981-12-0909 December 1981 Motion to Compel Util to Implement Revised Plan for Site Restoration.No Valid Reason Exists for Further Delay. Certificate of Svc Encl ML20011A2391981-10-0101 October 1981 Motion for Order Directing Util to Submit Plans to ASLB Re Site Excavation.Excavation Should Be Filled W/Matl Comparable to Removed Matl to Preclude Possibility of Harm to Natl Lakeshore.Certificate of Svc Encl ML20010G5041981-09-10010 September 1981 Response Supporting Util 810826 Motion to Terminate Proceeding.Termination Should Be W/Prejudice to Assure Finality of Util Decision & That Issues Raised Need Not Be Litigated ML20010E0331981-08-25025 August 1981 Response in Opposition to Porter County Chapter Intervenors 810817 Motion to Extend Time for Reply to Util Fourth Set of Interrogatories.Also Submits Motion to Compel Response. Related Correspondence ML20010E0321981-08-25025 August 1981 Motion to Compel Appearance of Ew Osann & Read for Deposition Re Facts Upon Which State of Il Has Based Contentions.Porter County & State of Il Are Attempting to Delay Completion of Proceeding.Related Correspondence ML20010E0171981-08-25025 August 1981 Renewed Motion for Protective Order Providing Hiple & Kulawinski Not Be Required to Appear for Depositions on 810915 & 22,respectively.Refusal to Reschedule Unwarranted. W/Ltrs & Certificate of Svc.Related Correspondence ML20010E0341981-08-25025 August 1981 Response in Opposition to State of Il 810820 Motion for Extension of Time to Respond to Util Fourth Set of Interrogatories.Requests That Order Be Issued to Compel Response.Related Correspondence ML20010D2381981-08-18018 August 1981 Response in Opposition to State of Il 810813 Motion to File Application for Discovery & Interrogatories Instanter & for Protective Order. General Allegations Insufficient to Extend Deadline.Certificate of Svc Encl.Related Correspondence ML20010D2291981-08-18018 August 1981 Motion to Compel Answers to 810622 Third Set of Interrogatories Directed to Porter County Chapter,Concerned Citizens Against Bailly Nuclear Site,Businessmen for Public Interest,Et Al.Related Correspondence ML20010D1201981-08-18018 August 1981 Response to Porter County Chapter Intervenors' Third Set of Interrogatories.Related Correspondence ML20010D1191981-08-18018 August 1981 Objections to Porter County Chapter Intervenors' Third Set of Interrogatories 9,10,11 & 42.Requests Protective Order Providing That No Further Response to Interrogatory 42 Is Required.Related Correspondence ML20010D1181981-08-18018 August 1981 Response to People of State of Il Second Set of Interrogatories.Related Correspondence ML20010D2441981-08-18018 August 1981 Objection to State of Il Second Set of Interrogatories, Interrogatories 12(c),13(b) & 13 (C).Matters Already Reviewed in Original CP Proceeding & Irrelevent to Instant Proceeding.Related Correspondence ML20010D2341981-08-18018 August 1981 Request for Motion to Compel Response to 810622 Third Set of Interrogatories Directed to State of Il.Answers Were Nonresponsive.Related Correspondence ML20010C8961981-08-17017 August 1981 Motion for Extension of Time Until 810910 to File Answers or Objections to Util 810730 Fourth Set of Interrogatories. More Time Needed for Adequate Preparation.No Party Will Be Prejudiced by Extension.Certificate of Svc Encl ML20010C8231981-08-17017 August 1981 Response Opposing Porter County Chapter Intervenors' 810810 Motion for Extension of Time to Take Depositions.Intervenors Had Ample Opportunity for Discovery.Board Should Not Allow Delaying Tactics ML20010C8251981-08-17017 August 1981 Response Opposing State of Il 810811 Motion for Extension of Time to Take Depositions.Hardships Under Discovery Schedule Are self-imposed ML20010C5031981-08-14014 August 1981 Second Application for Order Requiring Attendance & Testimony at State of Il Noticed Depositions of Lm Bykoski & Lg Hulman.Exceptional Circumstances Exist & Listed Personnel Should Be Required to Appear ML20010C5881981-08-13013 August 1981 Motion for Leave to File Application for Discovery Re NRC Documents,First Set of Interrogatories Directed to NRC & Third Set of Interrogatories Directed to Util.Discovery Could Not Be Completed by 810811.Related Correspondence ML20010C5911981-08-13013 August 1981 First Set of Interrogatories Directed to NRC ML20010C5181981-08-13013 August 1981 Motion for Protective Order That Ew Osann Deposition Not Be Taken on 810820.Osann Will Be Unavailable for Util Deposition Due to Other Business Commitments.Good Cause exists.W/810813 Ltr to Util Law Firm & Certificate of Svc ML20010C5901981-08-13013 August 1981 Application for Discovery Directed to NRC Re NRC Staff Evaluation of Bailly CP Extension Request. ML20010C5921981-08-13013 August 1981 First Set of Interrogatories Directed to Util.Certificate of Svc Encl ML20010B2941981-08-12012 August 1981 Renewed Application for Subpoenas Directed to Rf Brissette, s Dobrijevic & Personnel at Sargent & Lundy,Ground/Water Technology,Inc & Dames & Moore.Related Correspondence ML20010C3261981-08-11011 August 1981 Third Application to ASLB for Order Requiring Attendance & Testimony at Deposition of Lg Hulman,Lm Bykowski & Wf Lovelace.Exceptional Circumstances Exist.Related Correspondence ML20010C4971981-08-11011 August 1981 First Request for Production of Documents Directed to Util ML20010C4921981-08-11011 August 1981 First Request for Production of Documents Directed to NRC ML20010C5001981-08-11011 August 1981 Notice of Lm Bykoski & Lg Hulman 810824 & 26 Depositions, Respectively,Re Theoretical & Empirical Basis of NRC 810717 Eia & Documents,Info & Personnel Used in Preparing Eia ML20010C5071981-08-11011 August 1981 Amended 810720 Notice of MD Lynch Deposition,Including Listed Matters for Exam ML20010C2391981-08-11011 August 1981 Fifth Set of Interrogatories Directed to Util.Related Correspondence ML20010C5111981-08-11011 August 1981 Motion for Extension of Time for Taking Depositions.Supports Porter County Chapter Intervenors' 810810 Motion for Extension of Deadline Until 810803.Schedule Places Burden on Parties W/O Benifit to Anyone.Certificate of Svc Encl ML20010C2821981-08-11011 August 1981 Conditional Withdrawal of Motions for Protective Orders Re Hiple & Kulawinski Depositions.If Depositions Rescheduled for Suggested Dates,Util Will Withdraw Objections. Certificate of Svc Encl 1985-05-23
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BEFORE THE ATOMIC SAFETY AND LICENSING BOARD g "'"
Docket No. 50-367
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In the Matter of )
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NORTHERN INDIANA PUBLIC SERVICE ) (Construction Permit COMPANY ) Extension) & co
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NORTHERN INDIANA PUBLIC SERVICE COMPANY' d II SECOND SET OF INTERRDGATORIES TO PORTER COUNTY CHAPTER INTERVENORS 4 '
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- Northern Indiana Public Service Company (NIPSCO) hereby serves its Second Set of Interrogatories to Porter County Chapter Intervenors (hereinafter "PCCI"), pursuant to 10 C.F.R. S 2.740b.
Each interrogatory is to be answered fully in writing, under oath or affirmation, by an officer or agent of PCCI and is to include all pertinent information known to PCCI. Each answer should clearly indicate the interrogatory to which it is intended to be responsive.
Under NRC regulations (10 C. F. R. S 2.740(e)) parties are required to supplement responses to interrogatories under cer-l tain circumstances when new and/or different information becomes available.
"PCCI" shall include all agents, employees, attorneys, in-vestigators, and all other persons directly or indirectly subject to its control in any way.
"Documentu" means all written or recorded material of any i
! kind or character known to PCCT or in its peccession, custody, 810505 0 %D G
or control, including, without limitation, letters, correspon-dence, telegrams, memoranda, notes, records, minutes, contracts, agreements, records or notations of telephone or personal con-versations or conferences, inter-office communications, micro-film, bulletins, circulars, pamphlets, studies, notices, sum-maries, reports, books, articles, treatises, teletype messages, invoices, tape recordings, and work-sheets.
When used with respect to a document, " identify" means, without limitation, to state its date, the type of document (e.g., letter, memorandum, telegram, chart, photograph, sound reproduction, etc.), the author and addressees, the present location and the custodian, and a description of its contents.
When used with respect to a person, " identify" means, without limitation, to state his or her name, address, occupation, and professional qualifications.
If PCCI cannot answer any portion of any of the Interrogatories in full, after exercising due diligence to do so, so state, and answer to the extent possible, specifying the inability to answer the remainder and stating when PCCI expects to be able to answer the unanswered portions.
NIPSCO'S INTERROGATORIES 1!
- 9. (a) For what period of time do you contend that the Bailly site will be dewatered during the extended period of construction?
II Numbering of the following Interrogatories continues from NIPSCO'S First Set of Interrogatories to PCCI (April 10, 1981).
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(b) For what period of time do you contend that the Bailly site was dewatered between May 1, 1974, and September 1, 1979?
(c) What period of dewatering of the Bailly site was assessed in connection with issuance of Construction Permit No. CPPR-104?
(d) By what incremental period does the sum of your answers to 9(a) and 9(b) exceed your answer to 9 (c) ?
(e) Please provide the bases for your answers to 9 (a),
9 (b) and 9(c).
- 10. (a) What total volume of water do you contend will be removed from the Bailly site as a result of dewatering during the extended period of con-struction?
(b) What total volume of water do you contend was removed from the Bailly site as a result of de-watering between May 1, 1974, and September 1, 1979?
(c) What was the total volume of water removal from '
the Bailly site which was assessed in connection with issuance of Construction Permit No. CPPR-104?
(d) By what incremental volume does the sum of your answers to 10(a) and 10(b) exceed your answer to 10(c)?
- - ' ~ '
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(e) Please provide the bases for your answers to 10(a),
10(b) and 10 (c) .
- 11. (a) The environmental assessment at the construction permit stage contemplates dewatering to what elevation?
(b) For what period of time is dewatering to the elevation specified in your answer to 11(a) contemplated?
(c) Please provide the bases for your answer to ll(a) and ll(b).
- 12. (a) If the Bailly site is continuously dewatered to the elevation ,pecified la your answer to 11(a),
how long after the onset of such dewatering will the groundwater levels in the Bailly r,ite area reach equilibrium as a result of dewatering (dis-counting variations in the groundwater levels from factor's other than dewatering)?
(b) Please specify the depth of drawdown of the ground-water levels in the area around the Bailly site which you contend will result from continuous dewatering to the elevation specified in your answer to Interrogatory ll(a) at distances of l 700 feet, 1/2 mile, and 1 mile from the excavation.
(c) Please specify the rate of dewatering (vol/ min.)
which you contend will occur as a result of con-tinuous dewatering to the elevaticn specified in your answer to Interrogatory 11(a) .
- 13. If the Bailly site is continuously dewatered to the elevation specified in your answer to Interrogatory ll(a), how long after the onset of such dewatering will the environmental impacts as a result of such i dewatering reach an equilibrium (discounting variations in environmental impacts from factors other than de-watering)?
- 14. Do your answers to Interrogatory 12(a), 12(b), 12(c),
and 13 bound the results which would be obtained if the Bailly site is dewatered to an elevation higher than that specified in your answer to Interrogatory 11 (a) ?
- 15. (a) Do you contend that an incremental environmental impact during the extended period of construction will result from (1) dewatering during the incremental period specified in your answer to Interrogatory 9 (d) ?
(2) dewatering of the incremental volume of water i
specified in your answer to Interrogatory l
l 10 (d) ?
l (3) other causes? If yes, please specify the
! cause[s].
(b) Please describe in detail the incremental environ-mental impact which will result from each of the causes specified in your answer to Interrogatory 15(a).
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- 16. Are the incremental environmental impacts described in your answer to Interrogatory 15(b) irreversible
'n whole or part once dewatering during the extended period of construction is completed?
- 17. If your answer to Interrogatory 16 is yes, please specify which impacts are irreversible.
- 18. If the incremental environmental impacts described in your answer to Interrogatory 15(b) are reversible in whole or part once dewatering during the extended period of construction is completed:
(a) please specify which impacts are reversible in whole or part; (b) please specify the degree to which the impacts are reversible; (c) Please specify the time required to complete the reversal process for each impact.
- 19. (a) Are you contending that dewatering of Bailly during the extended period of construction will cause different groundwater levels at distances of 700 feet, 1/2 mile, and 1 mile from the excavation than occurred as a result of dewatering prior to September 1, 1979?
(b) Are you contending that dewatering of Bailly during the entended period of construction will cause different direction or rates of groundwater flow at distances of 700 feet, 1/2 mile, and 1 mile from the excavation than occurred as a result of dewatering prior to September 1, 1979?
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4 (c) Are you contending that dewatering of Bailly during the extended period of construction will cause the groundwater at distances of 700 feet, 1/2 mile, and 1 mile from the excavation to exhibit different chemical characteristics than occurred as a result of dewatering prior to September 1, 1979?
(d) Are you contending that dewatering of Bailly during the extended period of construction will cause the groundwater to be different in any other respects than occurred as a result of dewatering prior to September 1, 19797 (e) If your answer to Interrogatories 19 (a), 19 (b) ,
19 (c) or 19 (d) is yes, (1) please describe each difference, specifying, -
e.g., its magnitude, geographic extent, and duration; (2) please describe the bases for contending that each difference will occur; (3) please describe the incremental environmental I impact which will be caused by each difference.
(f) If your answers to Interrogatories 19 (a) , 19 (b) ,
19 (c) , and 19 (d) are no, please describe why the envir.onmental. impacts attributable to dewatering during the extended period of construction of Bailly will differ in kind or degree from those impacts, if any, which occurred as a result af ,
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l dewatering prior to September 1, 1979.
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- 20. (a) Are you contending that-the extra period of de-watering of Bailly (as distinct from any changes in the parameters of the groundwater which will allegedly occur after September 1, 1979, as a result of dewatering during the extended period of construction) will cause an incremental environ-mental impact? ~
(b) If yes,
- i. please describe the impact,
- 11. please provide the bases for your contention.
- 21. You have contended that the " additional period of con-struction time [ sought) is sufficient to cause some of the rare species, particularly the ' Bog Indicator'
[ Indicator] plants to disappear from the dunes eco-system."I/ - - '
(a) Please identify the " rare species" mentioned above.
(b) Please specify the periods and rates of dewatering of the Bailly. site which are required to cause the above plants "to disappear.'
(c) Please provide the bases for your contention.
- 22. You have. contended that the Indiana Dunes National Lakeshore would be adversely affected by "a deficiency of water,~or a surplus of water; a change in water
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characteristics; an increase in the rate or direction of water flow; dilution of existing water. . . ." II (a) Pir.1se specify the " water" to which you are re-ferring.
(b) Please specify the numerical values for the para-meters of the water which you are using as a re-ference in order to determine whether a deficiency, surplus, or a change in the water occurs.
(c) Please describe the adverse effects upon the Indiana Dunes National Lakeshore which will result from
- 1. deficiencies of water;
- 11. surpluses of water; iii. changes in water characteristics; iv. changes in water flow direction;
- v. changes in water flow rates; and vi. dilution.
(d) Using the values specified in your answer to Inter-rogatory 22(b) as a reference, please specify the magnitude of change in the following para-meters of the groundwater of the Indiana Dunes National Lakeshore which can occur before any adverse im' pact will result in the Indiana Dunes National Lake' shore:
- i. groundwater level;_.'
- 11. groundwater flow rate;
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iii. groundwater. flow direction; . .
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iv. groundwater characteristics.
-*/ " Joint Intervenors' First Supplement to Petition for Leave to Intervene," Contention 4, p. 10 (Feb. 26, 1980).
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(e) Using the values specified in your answer to Inter-rogatory 22(b) as a reference, please specify the magnitude of change in the following parameters of the groundwater in the Indiana Dunes National Lakeshore which you allege will occur as a result of dewatering during the extended period of construction:
- 1. groundwater level;
- 11. groundwater flow rate; iii. groundwater flow direction; iv. groundwater characteristics.
(f) Please describe the environmental impact which you allege will result from the change in items specified in Interrogatory 22(e).
(g) Please identify all documents upon which you relied and persons whom you consulted in answering Inter-rogatories 22(b) through 22(f).
(h) Please provide calculations upon which your answers to Interrogatories 22(b) through 22(f) are based.
- 23. You have contended that "had NIPSCO, and its contractors and subcontractors, known more about what they were doing, much of the delay (in construction) could not have occurred."I/ -
(a) Please identify the tasks associated with construction of Bailly which you contend were performed in an incompetent manner by NIPSCO, its contractors, or its subcontract _ ors, and which' thereby resulted
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in a delay'of'c'onstruction of Bailly.
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ddoint . Intervenors?.First Supplement to Petition for Leave to Interveng" Contention 7, p. 14 (Feb. 26, 1980).
_11 (b) For each task identified in the answer to Inter-rogatory 23(a):
(1) Specify the period of delay associated with the task.
(2) Identify the companies which are responsible for the delay associated with the task.
(3) Identify the individuals within the companies identified in your answer to Interrogatory 23 (b) (2) who are responsible for delay associated with the task.
(4) Specify which actions associated with the tasks were performed in an incompetent manner.
(5) Specify those actions which a competent person would have performed but which were not performed in connection with the task. ,
(6) Specify those actions which a competent person would not have performed but which were performed in connection with the task.
(c) For each individual identified in your answer to Interrogatory 23 (b) (3),
(1) Specify the information which he did not know but should have known in order to perform the' task competently.
(2) Specify the training which he did not receive but should have r ceived in order to perform
~,the task compet_ently. ""
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. l (3) Specify the ability wh'.ch he did not possess but should have possessed in order to perform the task competently.
(d) For each task identified in your answer to Inter-rogatory 23(a),
(1) Specify whether or not the delay is attributable to the need to repeat actions which were initially performed in an incompetent manner.
(2) Specify whether or not the delay is attributable to the failure to perform actions as quickly as a competent person would have performed the actions.
- 24. With regard to each PCCI contention admitted in this proceeding:
(a) Identify each person whom PCCI-expects to call .
as an expert witness in respect of each contention.
(b) State the subject matter on which the expert witness is expected to testify.
(c) State the substance of the facts and opinions to which the expert witness is expected to testify and summarize the ground for each opinion.
. ;... .~. - ..:- . . .. .. . . . . -
Identify all documents relied upon or examined (d) by the expert witness in answering subparagraph
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24(c) above. -- '
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(e) Identify all.documentsinot identified in answering 7 , . . pp: v; . -
subparagraph 24(d) above which the~ expert witness
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expects to put intofevidence;39f:or ,to rely upon in-
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support ~of his or her testimony in this proceeding.
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- 25. With respect to each PCCI contention admitted in this proceeding:
(a) Identify any person having knowledge of the facts f
relating to each PCCI contention (other than the l 1
expert witnesses identified in response to Inter- )
rogatory 24 (a)) . This question is limited to those persons whom PCCI expects to call as witnesses other than expert witnesses in this proceeding, or with whom PCCI has consulted or expects to consult in connection with this proceeding.
(b) For each person who has been consulted, state 4
when he or she was consulted and by which representa-tive of PCCI and summarize the substance of any facts or opinions communicated by such person to the representative of PCCI relating to the subject matter of each PCCI contention.
(c) If PCCI expects to call any person identified in response to Interrogatory 25(a) above to testify, state the substance of his or her testimony, summarize the basis for any opinions contained in such testi-mony, and identify all documents which will be introduced as evidence or relied upon by such person in support of such testimony.
l
- 26. Please identify all documents which PCCI expects to introduce in evidence or use for impeachment or other cross-examination purposes in this proceeding, other than those identified in the responses to the previous Interrogatories.
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- 27. Please identify the documents upon which PCCI relies ,
which relate to each PCCI contention admitted in this proceeding, other than those documents identified in responses to previous Interrogatories.
Respectfully submitted, EICHHORN, EICHHORN & LINK 5243 Hohman Avenue Hammond, Indiana 46320 By jf 12 'L
~ William H. Richhorn Attorneys for Northern Indiana Public Service Company LCWENT,TEIN, NEWMAN, REIS
& AXELRAD 1025 Connecticut Avenue, N.W.
Washington, D.C. 20036 i
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