ML20004B706

From kanterella
Jump to navigation Jump to search
Second Set of Interrogatories Directed to Util Re Reasons Const Was Not Completed by Date Specified in CP & Whether Reasons Were within Util Control
ML20004B706
Person / Time
Site: Bailly
Issue date: 05/19/1981
From: Whicher J
PORTER COUNTY CHAPTER INTERVENORS, VOLLEN, R.J. & WHICHER, J.M.
To:
NORTHERN INDIANA PUBLIC SERVICE CO.
Shared Package
ML20004B703 List:
References
NUDOCS 8105290325
Download: ML20004B706 (6)
v • d • e


Text

,

Nhp ~~ [N, v ,.

O l'NITED STATES OF AMERICA EUCLEAR REGULATORY COMMISSION 0^~~~'

f.:; y;N 2 219@

  • eG

\

BEFORE THE ATOMIC SAFETY AND LICENSING BOARD \ g , ,;.. t ,- 7

\g t.au. . . - . -  :

In the Matter of ) e g

) os NORTHERN INDIANA PUBLIC ) Docket No. 50-367 SERVICE COMPANY ) (Construction Permit (Bailly Generating Station, ) Extension)

Nuclear-1) )

)

PORTER COUNTY CHAPTER INTERVENORS' SECOND SET OF INTERROGATORIES TO NIPSCO Porter County Chapter Intervenors (PCCI), by their attorneys, pursuant to 10 CFR $2.740b, hereby serve upon Northern Indiana

' ~

Public Service Company (NIPSCO) the tc1.!owing Interrogatories

  • o be answered separateJv and fully in writing under oath by

~

its officer or agent, within 14 days of the date of service.

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 record-ings, 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 arc in the actual or constructive possession, custody or control of NIPSCO or its agents. The term "NIPSC0" includes Northern Indiana Public Service Company, its agents, employees, representatives, subsidiaries, and tuar: cor.sultants, attorney contractors or subcontractors over whom NIPSCO retains control.

1810529 U N

2_

1. Please state each reason NIPSCO contends that construction of the Bailly plant was not completed by the latest completion date contained in the construction permit and, for each reason stated, whether NIPSCO contends that the reason was beyond its control or within its control.
2. Does NIPSCO contend that." good cause" exists for the fact that construction of the Bailly plant was not completed by the latest completion date contained in the construction permit?
3. If the answer to Interrogatory 2 is "yes", please state each fact which NIPSCO contends contributes to a conclu-sion that " good cause" exists and the basis for the contention that each fact contributes to " good cause".

4 Does NIPSCO contend that " good cause" exists for an extension of the Bailly construction permit?

S. If the answer to Interrogatory 4 is "yes", please state each fact which NIPSCO contends contributes to a conclusion that " good cause" exists for an extension and the basis for the contention that each fact contributes to " good cause".

6. With respect to the slurry wall installed on the Eailly site, please state:

(a) the date on which NIPSCO first learned that a slurry wall could be installed at the Bailly site; (b) the name, address and employer of the person who communicated this information to NIPSC0; (c) the person at NIPSCO who received this information; (d) all inv.estigation and inquiry. before the date of I .

issuance of ths construction permit, by or on behalf of NIPSCO, to learn of any technique which could be used to mitigate or alleviate the effects of construction dewatering on the Indiana Dunes National Lakeshore.

7. Please describe in detail every geologic investigation performed by or for N!PSCO, or available to NIPSCO, prior to the date of issuance of the construction permit, stating the date thereof, and by whom it was performed.
8. Does NIPSCO contend that it lacked authority to perform any geologic tests or investigations other than those listed in the response to Interrogatory 77 . . .

(a) If the answer is that NIPSCO contends that it lacked authority to perform any tests or investigations other than those so listed, state the basis for the answer.

(b) If the answer is that NIPSCO contends that it lacked authority to perform any tests or investigations other than those so listed, state what, if anything, NIPSCO could have done to get the authority to do what it could not do.
9. If the answer to Interrogatory 8 is that NIPSCO was authorized to perform geologic tests and investigations other than those listed in the response to Interrogatory 7, please describe each test or investigation which NIPSCO was authorized to, but did not, perform and the reason each such test or inves-tigation was not performed.
10. With respect to each person whom NIPSCO expects to call as an expert witness, please.

4-(a) state the name, address and employer of each person; (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 summarice the ground for each opinion; (d) describe all documents relied upon or examined by the expert witness in answering subparagraph 10(c) above, giving the date, author, custodian and a summary of the contents of each document.

(e) state whether the witness has prepared a -written report and if so, please give a summary of the contents of the report.

(f) state whether the witness has given anyone an oral _

report, and if so; (i) identify each person to whom such oral report was given; (ii) give a summary of the contents of the oral report; and (iii) state whether any notes or memoranda concerning tne report have been prepared and if so, describe cach document containing such notes or memoranda, giving the date, the author and the custodian of each such document.

11. With respect to each expert whom NIPSCO has consulted or retained, and whom NIPSCO does not expect to call as an expert witness, please:

(a) state the name, address and employer of each expert; 6 (b) state the subject matter with respect to which each exp:vt was consulted or retained;

(c) describe all documents relied on or examined by each expert, giving the date, author, custodian and a su= mary of the contents of each document; (d) state whether the expert has prepared a written report and if so, please give a sum =ary of the contents of the report; (e) state whether the expert has given anyone an oral rap'rt, and if so:

(1) identify each person to whom such oral report was given; (ii) give a summary of the contents of the oral report; and . .

(iii) state whether 4,y notes or memoranda concerning the report have been prepared and if so, describe each document .

containing such notes or memoranda giving the date, the author, and the custodian of each such document.

12. With respect to each person whom NIPSCO expects to call as witness other than as an expert witness, please:

(a) state that person's name, address and employer; (b) state the substance of his or her testimony; (c) give a summary of the basis for any opinions contained in such testimony; and (d) describe each documeat which will be introduced as evidence or relied upon by such person in support of such testimony, giving the date, author, custodian and summary of its contents.

13. Please give the following information for the person swearing to the answers to these interrogatories:

(a) Name (b) Address (c) Title (d) Capacity

14. Please give the following information of each person who has provided or furnished information to the person identified in Interrogatory 13, consulted with that person in the preparation of the responses to these Interrogatories, or othewise aided in the preparation of the responses:

(a) Name (b) Address .

(c) Title (d) Number (including subpart) of each Interrogatory with respect to which that person consulted, aided or provided or furnished information; and (e) The nature of the information or aid furnished.

Dated: May 19, 1981 Robert J. Vollen Jane M. Whicher Jane . hh ch r by: +^ . ( -

109 North Desrborn Jane M. Whicher '

cago llinois 60602 ACU{nehen s (312) 641-5570

. . .., - -. ...

Retrieved from "https://kanterella.com/w/index.php?title=ML20004B706&oldid=2340109"