ML20004B711

Fourth Request for Production of Documents Directed to Util. Requests Written Communications Between Util Employee or Officer & Any Number of Util Board of Directors & Minutes of Board of Director Meetings.Related Correspondence

ML20004B711
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: ML20004B702 ML20004B706 ML20004B711 ML20004B715 ML20004B718 ML20004B720 ML20004B723 ML20004B724 ML20004B726
References
NUDOCS 8105290333
Download: ML20004B711 (4)

Text

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s UNITED STATES OF AMERICA 6 cttggrg3 s 1 NUCLEAR REGULATORY COMMISSIOh - USNP.O I. l BEFORE THE ATOMIC SAFE 2Y AND LICENSING BOARD '

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In the Matter of )

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

Nuclear-1) )

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PORTER COUNTY CHAPTER INTERVENORS' FOURTH REQUEST TO NIPSCO FOR PRODUCTION OF DOCUMENTS Porter County Chapter of the Izaak Walton League of America, Inc.; Concerned Citizens Against 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 CFR $2.741, hereby request that Northern Indiana Public Service Company ("NIPSC0") produce for inspection and copying on Tuesday, June 23, 1981, at 10:00 A.M.

at the offices of Business and Professional People for the Public Interest, Suite 1300, 109 North

Dearborn,

Chicago, Illinois 60602, the documents described herein.

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, 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 er construc-

., tive possession.. custody or control of NIPSCO.

A described 810329o3 n

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document includes all other documents which are attached to or relate to such document. The term "NIPSC0" includes Northern Indiana Public Service Company, its agents, employees, represen-tatives, subsidiaries , and those consultants , contractors or subcontractors over whom NIPSCO retains control. The term "Bailly" refers to the Bailly Genercting Station, Nuclear 1.

The term "NRC" includes the United States Nuclear Regulatory Commission, its staff, members, attorneys, employees, consultants, divisions or subdivisions, contractors and subcontractors. The term " Interrogatory" refers to Porter County Chapter Intervenors' Second Set of Interrogatories to NIPSCO, filed May 19,.1981.

1. All written communicatiens, and all notes and records of all oral communications, between any employee or officer of _

NIPSCO and any or all members of NIPSCO's Board of Directors concerning the Bailly nuclear plant.

2. All minutes of all meetings of NIPSCO's Board of Directors from the earliest meeting at which the possibility of construction of any nuclear power plant, including but not limited to Bailly, was mentioned.

3. All records of corporate action with respect to the Bailly plant authorized, director, approved, or ratified by SIPSCO's Board of Directors.

4. All documents described in PCCI's First, Second and Third Requests to NIPSCO for Production of Documents which have been generated, or which have come to NIPSCO's attention 4

or possession, since NIPSCO's responses to those requests were filed.

5. All documents on which NIPSCO's responses to Interrog-atory 3 is based.

6. All documents on which NIPSCO's response to Interrog-atory 5 is based.

7. All documents related to NIPSCO's response to Interrogatory 6.

8. All documents related to the geological investigations described or referred to in NIPSCO's responses to Interrogatories 7, 8, and 9. _

9. All documents desc;-ibed in NIPSCO's responses to Interrogatories 10 (d) , 10(e) and 10(f)(iii) . .

10. All documents described in NIPSCO's responses to Interrogatories ll(c) , ll(d), and 11(e)(iii) .

11. All documents described in NIPSCO's responses to Interrogatory 12(d).

12. The letter from William H. Eichhorn to Dr. J.K.

McClusky of the NIPSCO Nuclear Staff dated April 29, 1974, which was produced to PCCI on May 4, 1981 and subsequently withdrawn by NIPSCO.

13. " Contract Between Northern Indiana Public Service Company and General Electric Company for Nuclear Fuel and Related Services for Bailly Generating Station, Nuclear 1" dated September 5, 1969 (Draf t 1/27/72) produced to PCCI on May 4, 1981'and subsequently withdrawn by NIPSCO.

14 All meeting notes of NIPSCO's nuclear staff meetings.

15. All documents in the file labeled " Estimates - N1".

Dated: May 19, 1981 Respectfully submitted, Robert J. Vollen Jane M. Whicher BY: 'A _'

Jane M. Whicher Attorneys for Porter County Chapter Intervenors Robert J. Vollen Jane M. Whicher c/o BPI 109 North Dearborn - -

Chicago, Illinois 60602 (312) 641-5570 6