ML20008G166
| ML20008G166 | |
| Person / Time | |
|---|---|
| Site: | Clinton  |
| Issue date: | 06/25/1981 |
| From: | Neuman R, Samelson A ILLINOIS, STATE OF, PRAIRIE ALLIANCE |
| To: | NRC COMMISSION (OCM) |
| Shared Package | |
| ML20008G150 | List: |
| References | |
| ISSUANCES-OL, NUDOCS 8107020379 | |
| Download: ML20008G166 (3) | |
Text
en r UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION IN THE MATTER OF ILLINOIS
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POWER COMPANY, S0YLAND POWER
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DOCKET NOS. 50-461 OL COOPERATIVE, INC. and WESTERN
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50-462 OL ILLIN0IS POWER COOPERATIVE,
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INC.
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JOINT MOTION FOR EXTENSION OF TIME TO COMPLETE DISCOVERY PRAIRIE ALLIANCE, INC. (Prairie Alliance), and THE PEOPLE OF THE STATE OF ILLIN0IS (Illinois), by Tyrone C. Fahner, Attorney General of the State of Illinois,'ereby jointly move n
for an extension of the completion date for initiating discovery as established by the Memorandum and Order issued by the Atomic Sa'fety and Licensing Board (Board) on June 1, 1981.
In support of this motion, Prairie Alliance and Illinois state as follows:
1.
On June 1, 1981, the Board issued & Memorandum and Order admitting certain contentions filed by Prairie Alliance, ordering a hearing on the operating license application, and admitti.ng Prairie Alliance as~ a party to the proceeding and Illinois as an " interested state".
2.
In that same Memorandum and Order, the Board ordered that all first round discovery requests were to be filed by June 26, 1981, with responses thereto due no later than the earlier of July 27, 1981 or 4 weeks after receipt of the requests.
3.
Since receiving that Memorandum and Order, both Prairie Alliance and Illinois have endeavored to file firs t round discovery requests by June 26, 1981.
Indeed, under separate cover, 8107020399. u.
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Prairie Alliance and Illinois each are filing certain discovery requests by the deadline imposed.
However, for reasons set forth below, the time allotted by the Board in its Memorandum and Order has not been sufficient for either of Prairie Alliance and Illinois to complete initial discovery.
4.
As a reading of the admitted contentions indicates, the issues involved are many and complex.
In large part, consul-tation with experts in the field will be necessary to fully explore the questions raised by the admitted contentions.
Neither Prairie Alliance nor Illinois have had the benefit of the full-time services of any expert consultants for discovery matters prior to their admissica to this proceeding.
In light of their admission, Prairie Alliance and Illinois have arranged to retain experts for the full range of issues involved and will be consulting them as soon as, possible regarding both discovery and evidentiary matters.
5.
The initial discovery requests that are being filed by Prairie Alliance and Illinois by the original due date were prepared virtually without benefit o' expert counsel, and consumed the available resources of Prairie Alliance and Illinois.
- However, the magnitude of the task is such that Prairie Alliance and Illinois, i
without expert counsel, simply could not complete the desired dis-l l
covery program within the allotted time.
It is submitted t, hat an extension of time to complete 6.
this round of discovery would not seriously feopardize the timely completion of this proceeding, given the anticipated dates of completion of final Staff Reports and the hearing itself.
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Prairie Alliance and Illinois suggest that 30 days would be an appropriate extension of.the filing date for first round discovery requests, with a corresponding extension of the due dates for responses thereto.
7.
The joint Affidavi't of Prairie Alliance and Illinois is attached.
WHEREFORE, Prairie Alliance and Illinois jointly pray that the Board grant an extension of 30 days, or until July 27, 1981, or any other period the Board deems appropriate, of the deadline for the filing of first round discovery requests, with a corresponding extension of the due dates for responses thereto.
Respectfully submitted, PRAIRIE ALLIANCE, INC.
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Allen Samelson
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109 North Dearborn Street ute 1300 Chicago. !!:inmS 6C602 Teleonone- (312) 641-5570 j
June 24, 1981 Mr. William H. Eichhorn Eichhorn, Eichhorn & Link 5243 Hohman Avenue Hammond, Indiana 46320 Re:
Northern Indiana Public Service Company (Bailly Generating Station, Nuclear-1) Dceket No. 50-267
Dear Bill:
(Construction Parnit Extension)
We have received your letter of June 23, 1981, responding to our letter of June 15, 1981, concerning any document filed with the NRC pursuant to Generic Letter No. 81-23, for the Bailly Gener-ating Station, Nuclear-1.
We request that if any such document comes into er.istence a copy of it be furnished to us.
Verv tru.y lv v o.u>r s.
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Robert J.
1' allen One of cl'e Attorneys for Pdrter County Chapter intervenors Administrative Judge Herbert Grossman cc:
Administrative Judge Robert fiolton Administrative Judge Venn Leeds Maurice Axelrad/Kathleen H. Shea Diane B. Cohn/ William B. Schultz Atomic Safety & Licensing Board Panel Atomic Safety & Licensing Appeal Board Panet George & Anna Grabowski Dr. Geo ge Schultz Mike Olszanski/Clifford Mezo Stephen H. Lewis Anne Rapkin/ John Van Vranken Docketing & Service Section - U.S.
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AFFIDAVIT Reed W. Neuman, and Terri Iang depose and state as follows:
1.
Reed W. Neuman is an Assistant Attorney General for the State of Illinois.
2.
Terri Iang is a Representative of Prairie Alliance, Inc.
3.
The contents of the foregoing motion are t?ue to the best of their kn'owledge and belief.
FURTHER AFFIANTS SAYETH NOT.
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NE E-(.N. /\\./6 n yt' 41 Reed W.
Neuman SUBSCRIBED AND SWORN T0 before me this #5/2 day o f (bs _.
1981.
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Wotrary Public Terra. Lanaf SUBSCRIBED AND SWORN TO V
before me this.74 d day, of hna 1981.
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NOT/.RY PU3LIC, STATE OF ILLINols MY COMMIS$10N EXPtRES JUNE 26, 1985
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CERTIFICATION OF SERVICE I certify that I caused an original and two conformed copies of the foregoing document.to be served on the following:
Secretary of the Commission United States Nuclear Regulatory Commission Washington, D.C.
20555 Atta:
Docketing and Servicing Branch and that I caused one copy of the foregoing document to be served upon each of the following:
Hugh K. Clark, Esq. Chairman Dr. George A. Ferguson P.O. Box 127A School of Engineering Kennedyville, Maryland 21645 Howard University 2300 3ixth Street, N.W.
Dr. Oscar H. Paris Washington, D.C.
20059 Atomic Safety & Licensing Board Richard J. Goodard, Esq.
U.S. Nuclear Regulatory Office of the Executive Commission
. Legal Director Washington, D.C.
20555 U.S. Nuclear Regulatory Commission Atomic Safe cy & Licensing Washington, D.C.
20555 Appeal Board Panel U.S. Nuclear Regulatory Peter V. Fazio, Jr., Esq.
Commission Schiff, Hardin & Waite Washington, D.C.
20555 7200 Sears Tower 233 South Wacker Drive Chicago, Illinois 60606 i
in each case by deposit in the United States Mail, postage prepaid M ' Ni ! hf on b
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Allen Same~lson, Represensativ'e for Prairie Alliance, Inc.
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