ML20009G909
ML20009G909 | |
Person / Time | |
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Site: | Bailly |
Issue date: | 07/31/1981 |
From: | Eichhorn W EICHHORN, EICHHORN & LINK, NORTHERN INDIANA PUBLIC SERVICE CO. |
To: | CONCERNED CITIZENS AGAINST BAILLY NUCLEAR SITE |
References | |
NUDOCS 8108050220 | |
Download: ML20009G909 (2) | |
Similar Documents at Bailly | |
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Category:INTERROGATORIES; RESPONSES TO INTERROGATORIES
MONTHYEARML20049K0821982-03-23023 March 1982
[Table view]First Interrogatory Re Site Restoration ML20030B8941981-08-19019 August 1981 Responses to Porter County Chapter Intervenors Fourth Set of Interrogatories.Certificate of Svc Encl.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 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 ML20010D1181981-08-18018 August 1981 Response to People of State of Il Second Set of Interrogatories.Related Correspondence 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 ML20010C5911981-08-13013 August 1981 First Set of Interrogatories Directed to NRC ML20010C1531981-08-11011 August 1981 Third Set of Interrogatories Directed to Nrc.Related Correspondence 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 ML20010C2391981-08-11011 August 1981 Fifth Set of Interrogatories Directed to Util.Related Correspondence ML20010C1421981-08-11011 August 1981 Application to ASLB for Discovery on Listed NRC Documents. Certificate of Svc Encl.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 & Encl.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 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 ML20009H4891981-07-31031 July 1981 Second Set of Interrogatories Directed to NRC Re Site Dewatering & Replacement Water Levels.Related Correspondence ML20009H4911981-07-31031 July 1981 Fourth Set of Interrogatories Directed to Util Re Site Dewatering.Related Correspondence ML20009H4921981-07-31031 July 1981 Fourth Request for Production of Documents Directed to Nrc. 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 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 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 ML20030B1271981-07-31031 July 1981 First Request for Production of Documents Directed to Util. Certificate of Svc Encl ML20030B1231981-07-31031 July 1981 Second Set of Interrogatories Directed to Util.Topics Include Sheet Piling,Slurry Wall,Hydrostatic Pressure, Excavation,Dewatering,Pumphouse & Gravity Drains.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 ML20009G9531981-07-30030 July 1981 First Request for Production of Documents Upon Which Businessmen for Public Interest 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 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 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/Dappolonia Assessment of Dewatering Influence.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 ML20009H0451981-07-30030 July 1981 Third Set of Interrogatories Directed to Util.Related Correspondence ML20009G9561981-07-30030 July 1981 First Request for Production of Documents Upon Which Je Newman Relied on 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 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 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 ML20009E2841981-07-24024 July 1981 Answers to Porter County Chapter Intervenors First Set of Interrogatories.Affidavit & Certificate of Svc Encl 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 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 Category:LEGAL TRANSCRIPTS & ORDERS & PLEADINGS MONTHYEARML20126M8141985-05-23023 May 1985
[Table view]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 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 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 ML20053E6841982-06-0303 June 1982 Affidavit of Rl Graham Re Reasonable & Customary Charges of Attys ML20052F5251982-05-0606 May 1982 Memorandum & Order Granting Util Motion to Terminate Proceeding W/O Prejudice.Application for Extension of CP Deemed Withdrawn W/Listed Conditions 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 ML20052C8431982-04-12012 April 1982 Memorandum & Proposed Order Terminating CP CPPR-104 Extension Proceeding,W/Certain Conditions for Site Restoration 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 ML20049K0821982-03-23023 March 1982 First Interrogatory Re Site Restoration 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 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 ML20040D5891982-01-29029 January 1982 Order Approving Util Revised Site Restoration Plan & Directing Implementation of Plan ML20040D4151982-01-28028 January 1982 Response Opposing Porter County Chapter Intervenors 820108 Motion for Order Imposing Condition for Withdrawal of Util Application.Commission W/O Authority to Condition Withdrawal Upon Payment of Intervenor Atty Fees.W/Certificate of Svc 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 ML20039C9581981-12-29029 December 1981 Response Opposing Porter County Chapter Intervenors 811209 Motion to Compel Util to Implement Revised Plan for Site Restoration.Aslb Should Grant Util 810826 Motion to Terminate,Mooting Pcci Motion.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 ML20032E4961981-11-18018 November 1981 Response to Porter County Chapter Intervenors 811001 Motion Re Excavation.Portion of Motion That Util Submit Plan Is Moot.Opposes Portion Requesting ASLB to Determine If Plan Satisfactorily Completed.Certificate of Svc Encl ML20032E5081981-11-17017 November 1981 Order Granting NRC 811104 Motion to Extend Time to Respond to Porter County Chapter Intervenors Motion Re Excavation. Time Extended Addl 2-wks ML20032B7721981-11-0404 November 1981 Motion for Further Extension of Time Until 811118 to Respond to Porter County Chapter Intervenors 811001 Motion Re Excavation.Parties Have Reached Agreement on Restoration Plan But Need Time to Execute Plan.Certificate of Svc Encl ML20011A6701981-10-26026 October 1981 Order Granting NRC 811021 Motion for 2-wk Extension to Respond to Porter County Chapter Intervenors Motion Re Excavation ML20031G5391981-10-21021 October 1981 Motion for Extension of 2 Wks to Respond to Porter County Chapter Intervenors 811001 Motion Concerning Excavation. Extension Would Allow Parties Opportunity to Reach Agreement on Restoration Plan.Certificate of Svc Encl ML20031E7151981-10-12012 October 1981 Response to Porter County Chapter Intervenors 811001 Motion for Order Directing Util to Submit Plans Re Site Excavation. Motion Moot Due to Util 811008 Rept on Const & Restoration Work.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 ML20031A7841981-09-17017 September 1981 Response Opposing ASLB 810901 Order.Withdrawal of Application Should Be Granted W/O Prejudice.No Prejudice to Public Interest or Other Party Shown.Aslb Has Not Identified Basis for Condition & No Condition Apparent from Record ML20030D9191981-09-15015 September 1981 Response to Util 810826 Motion to Terminate Proceeding.Aslb Should Not Grant Motion Until Site Restored to Preclude Offsite Impacts.Util Should Be Required to Submit Restoration Plans for NRC Approval.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 ML20010E4141981-09-0101 September 1981 Order Suspending Proceeding Until ASLB Issues Order Terminating Proceeding.Also Orders Util to Respond within 10 Days Re Objections to Termination W/Prejudice ML20030D2511981-08-28028 August 1981 Motion for Order Postponing Due Date of Any Pending Responses Until ASLB Rules on Util 810827 Motion to Terminate Proceeding.Certificate of Svc Encl ML20030C5531981-08-26026 August 1981 Response Opposing Porter County Chapter Intervenors 810810 Motion to Compel NRC Answers to First Set of Interrogatories.Parties Cannot Discover Nonexistent Documents.Certificate of Svc Encl ML20030C5791981-08-26026 August 1981 Response to Porter County Chapter Intervenors 810731 Motion for Order Compelling NRC Answers to Second Set of Interrogatories.Motion Should Be Denied Re Interrogatories 13 & 16.Question Unclear.Certificate of Svc Encl ML20030D2571981-08-26026 August 1981 Motion to Terminate All Pending Proceedings Re Facility ML20030C5651981-08-25025 August 1981 Order Extending Until 810930 Time for Noticing Depositions & Until 811030 for Taking Depositions.State of Il & Porter County Chapter Intervenors May Notice No Depositions Until Agreement Reached on Util Deposition of Read & Osann 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 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 ML20030C5581981-08-24024 August 1981 Memorandum & Order Denying Porter County Chapter Intervenors 810511 Motion to Compel Production of Documents by Util Per Intervenors Third Request to Util.Intervenors Failed to Show Relevancy of Documents ML20030C1751981-08-21021 August 1981 Order That Permittee Not Install Piles Pending Completion of Adjudication of Pilings Issue ML20030B8601981-08-21021 August 1981 Response Opposing Porter County Chapter Intervenors 810811 Third Application for Order Requiring Attendance & Testimony of Lg Hulman,Lm Bykoski & Wf Lovelace at Deposition. Certificate of Svc Encl ML20030B9511981-08-21021 August 1981 Amended Notice of Opportunity for Hearing Re Licensee Plan to Drive Foundation Piles Into Glacial Lacustrine Deposits Underlying Site ML20030B9001981-08-21021 August 1981 Response in Opposition to Porter County Chapter Intervenors (Pcci) 810810 Second Motion to Compel Further NRC Response & Production of Documents.No Deficiency Exists in Response to Pcci Second Request.W/Certificate of Svc ML20030C4361981-08-20020 August 1981 Motion for Extension of Time Until 810928 to File Responses to Util Fourth Set of Interrogatories.Certificate of Svc Encl.Related Correspondence 1985-05-23 |
Text
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CJ UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION D
AUG b 1981 > q
.[ 2 Ci BEFORE THE ATOMIC SAFETY AND LICENSING BOARD C'r.Q
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In the Matter of
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Docket No. 50-367
)
NORT!!ERN INDIANA PUBLIC
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(Construction Permit
/ ('v, SERVICE COMPANY
)
Extension)
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3 (Bailly Generating Station,
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July 31, 1981 C
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nga o 093,.
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e p ov AMENDMENT TO NORTHERN INDIANA PUBL FOURTII SET OF INTERROGATORIES TO CONCERNED CITIZENS AGAINST BAILLY NUCLEAR SITE q;f
. J 9..N On July 30, 1981, Northern Indiana Public Service Company (NIPSCO) served its Fourth Set of Interrogatories to Concerned Citizens Against Bailly Nuclear Site.
Two of those Interroaa-tories have incorrect references to other Interrogatories.
Accordingly, NIPSCO hereby amends its Fourth Set of Interroga-tories to Concerned Citizens Against Bailly Nuclear Site as l
follows:
1.
Interrogatory 42 (c) is hereby amended to read as follows:
"42 (c).
Please specify the basis for your answer to 1
Interrogatory 42 (b). "
2.
Interrogatory 45 (c) is hereby amended to read as follows:
"45 (c).
Please provide the basis for your answer to l
Interrogatory 45 (b). "
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8108050220 810731
-PDR ADOCK 05000367
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/ All other Interrogatories and other matters contained in NIPSCO's Fourth Set of Interrogatories to concerned Citizens Against Bailly Nuclear Site remain unchanged.
Respectfully submitted, EICHHORN, EICHHORN & LINK 5243 Hohman Avenue llammond, Indiana 46320 f
]
By:
William H.
E'ichhorn Attorneys for Northern Indiana Public Service Company E
LOWENSTEIN, NEWMAN, REIS
& AXELRAD 1025 Connecticut Avenue, N.W.
Washington, D.C.
20036
.