ML20009H498

Sixth Request for Production of Documents Directed to Util. Related Correspondence

ML20009H498
Person / Time
Site:	Bailly
Issue date:	07/31/1981
From:	Whicher J PORTER COUNTY CHAPTER INTERVENORS, VOLLEN, R.J. & WHICHER, J.M.
To:	NORTHERN INDIANA PUBLIC SERVICE CO.
References
NUDOCS 8108100187
Download: ML20009H498 (8)

Text

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cVN TED CORREspmogygg Il UNITED STATES OF AMERICA '7!31/8 I NUCLEAR REGULATORY COMMISSION .

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BEFORE THE ATOMIC SAFETY AND LICENSING BOARD 7 h -:Ce:7 k*-

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NORTHERN INDIANA PUBLIC ) Docket No. 50-367 SERVICE COMPANY ) (Construction Pemit (Bailly Generating Station, ) Extensio Nuclear-1) ) g .

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{ NLL I[ h b PORTER COUNTY CHAPTER INTERVENORC AU;. 0 71981 m 1  ;

SIXTH REQUEST TO NIPSCO tr u,,, , caw .w

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FOR PRODUCTION OF DOCUMENTS co= m a -

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/h-Porter County Chapter of the Izaak Walton Lea - rica, 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 S2.741, hereby request that Northern Indiana Public Service Company ("NIPSC0") produce for inspection- and copying 'on Friday , September 4, 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 1

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 re cordings , computer printouts, photographs, calendar and diary entries , minutes , pamphlets , notes , chartes, tabulations- and records of meetings, conferences and telephone or other conversations or meetings, which are in the actual or construc-tive possession, custody or control of NIPSCO. A described O

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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

" Interrogatory" refers to Porter County Chapter Intervenors '

Fourth Set of Interrogatories to NIPSCO, filed July 31, 1981.

1. Attached hereto, as " Attachment 1" is a memorandum prepared by C.F. Braun dated September 9,1974. References therein

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are certain Thatcher " proposals". Please produce copies of all proposals and amended proposals by Thatcher. .

2. Attached hereto is a document marked " Attachment 2" entitled " General Survey of Area Adjacent to Bailly Site".

Please produce copies of all photographs referenced in that document.

( 3. All documents showing the inj ection points for NIPSCO's proposed dewatering mitigation program.

4. All documents indicating water table levels and/or interdunal pond levels, on NIPSCO property and on property within.

the Indiana Dunes National Lakeshore, as such levels exist'ed prior to any construction activity at the Bailly site (whether of any existing coal-fired units or any other units)-including but not limited to contour maps , site maps , maps prepared by you or on your behalf or relied on by you for constructi'on l

l of the coal-fired units .

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5. All documents indicating water table leveic and/or interdunal pond levels, on NIPSCO property and on property within the Indiana Dunes National Lakeshore, as such levels existed subsequent to construction of the coal-fired units at the Bailly site and prior to the construction of the ash-settling basins .

6. All documents indicating water table levels and/or interdunal pond levels, on NIPSCO property and on property within the Indiana Dunes National Lakeshore, prepared in connection with the application for the Bailly N-1 construction permit.

7. All documents which show the location, elevation, and sizes of all underground piping, electrical connections ,

pump house, water intake piping, water discharge piping, cooling tower foundation, and piping between cooling tower and all elements of the proposed Bailly plant.

8. All documents on which you base your answer to Illinois Interrogatory 8(a) of the People of the State of Illinois ' First Set of Interrogatories to NIPSCO of the estimated 18 to 30 months necaed to bring construction to grade level, including but not limited to construction schedules.

9. A current NIPSCO nuclear staff manual.

10. A current NIPSCO nuclear staff filing index, described by Russell J. Bohn during his deposition on .

i October 21, 1980, at pages 79-80.

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11. All documents listed in NIPSCO's response to Interrogatory 15(f) of PCCI's Fourth Set of Interrogatories to NIPSCO.

12. All documents listed in NIPSCO's response to Inter-rogatory 32.

DATED: July 3) , 1981 Robert J. Vollen Jane M. Whicher by:  % i, t

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Jane M. Whicher-i Attorneys for Porter County Chapter Intervenors .

Robert J. Vollen Jane M. Whicher c/o BPI 109 North Dearborn Suite 1300 -

i Chicago, Illinois 60602 (312) 641-5570 i- ,

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ATTACHMENT 1 '

s C F BRAEN & C0

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4LHAMSAA C A L t r' O R % I A . 9 s 8 0 2 September 9, 1974

? J 3chn, Profect Encineer Northern Indiana Tublic Service Company 840 3 roadway /

Gan , Indiana 46401 /j, ENL-105 PR03or" o?':0RT BAILLY Gr 5Ea.a.;- Er aICK N-1

?ROJECT 4015-?

Dear Mr Sohn Here is cur. third weekly prosress report. It covers the period from August 31, 1974 throurh September 7, 1974.

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WEATHER Clear and cool. No time lost.

MANPO'iER Calumet Construction 1 J W Sncok (Calumet Subcontractor) 4 Calumet Trucking Company 13 Thatcher Encineering Company 8 Total 26 -

3RAUN STAFF 3raun 4 Clerical 1 5

CANSTRUCTION ACTIVITIES

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EXCAVATION Main building excavation work continued all week with an averace of 4 scrapers working a 10 hour1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br /> day. Total of 17,900 yards this week, brinting a total of 77,300 yards excavated to date. Total excavation is 350,300 ya_Ms. 3raun has advised Calumet that earth =cving troduction cust be increased. Calumet will respon6.

With a plan of action on Septe=ber 9 The bat::h plant fill is substantially cc=plete. Calumet is concentrating on denositing backfill caterial at the cooling tovtr area.

PILING MATERIAL The first 20 railcars from the September rolling of H-piles arrived September 5. Thatcher started off-loadine on Septe=ber 6.

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s Project h915-?

Mr R J Fohn Face 2 September 9, 1974 TE'?0RART CCNSTRUCTICN FACIIIT. TIS Work on the office and warehouse remains stopped. We =et with S & L and Calumet Construction Cen any on September 3 to resolve desien sub=ittal and approval problens.

J W Sncok started sanitary sewer work from the lift station northward . They also are erectinr heatine water piping in the base-nent of Unit No S.

FIPSCO is continuing installatien of the construction substation. Completion has slipped to later in September.

CONTRACTIEG We met with Thatcher Engineering Cc=pany and Sargent and Lundy to review Thatchers amended proposal. Many misunderstand-ines were cleared up. Thatcher will re-submit their proposal.

BRAUN SCOPE We met with NIPSCO to establish 3rauns scope of work in the receivinc and storare of equipment and materials.

SAFETT No injuries were reported. - -

100EAEEAD Main building excavation will continue, on a 10 hour1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br /> day.

Foundation work for the office and warehcuse will start.

Work on the sanitary sewer will continue. ,

H-pile offloadine will centinut.

Sincerely yours, ldh GMC .DI G M Crall Project Manager CC: Sarcent & Lundy .

G C Zuhlman, Project Director 55 East Monroe Street, Floor 31 Chicaco, Illincis 60603 9

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, ATTACHMENT 2.

GINERAL TUF.VEY OF AREA ADJACENT "'O BAILLY f.ITF On Friday, September lb, 1973, Dale Holt:scher and I, Bobert -

Eraser, walked through the area to the east of the Bailly site. The Eeneral purpose of this trip was te gain mere infornction relating to the interdunal ponds that are to be included in the devatering monitoring pregram. The recion van entered frem the beach about 500 feet east of the NIPSCO property line.

The enclosed map (f4L Mf-150) shows the locations of the ponds that are shown on the attached photographs.

Pond 1 is chevn in phc.tecraph fl . The picture was taken from -

the vest end cf the pond.

Fond 2 is shown in photograph #2. The photograph was taken frem the north cide of the pond. Surface water flev vas noted by both-Mr. Holt:scher and myself from Pond 2 into Fond 3. .

Pond 3 is shown in photographs #3(a) and #3(b). Surface water flow was noted by both Mr. llolt scher and myself from pond 3(a) into pond 1. Pond 3(b) eppears to have been formed because of lov vater.

Fond 3(a) is approximately 60 ft. long and 30 ft. vide. Pond 3(b) appears to be about one foot lover than 3 (a).

Pond 6 in c.hown ir. photocrnphs'C(a) and 4(b). Ponds (a).is te the vent ( : por.d h ( b ) . 1 owl h(b) appearr te bnve been formed by low water level. Fond h(a) in opproxirately 160 feet leng and'65-feet vide.

Fond .I(b) is typroxinately 65 feet leng and LO feet vide. Pend f(b) appears te te abcut ^ feet 3rver t'rne pond 1(s).

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,I . ATTACHMENT'2 TJI;TFA' TUEVEY OF AREA ADJACEIC "'O liATLLY P.ITE On Friday, September IL ,1973, Dale Helt:scher and I, Robert Eramer, valked throur,h the area to the ennt of the Bailly site. The general purpose nf thic trip was to gain tere information relatinE to the interdunal ponoc that are to be included in the devatering tenitorin6 pregram. The recion vns entered frem the beach about 500 feet east of the NIPSCO property line.

'The enclosed map (S&L MS-150) shows the locations of the ponds that are chown on the sLcached photographs.

Pond 1Eis chewn in photecruph #1. The picture was taken froy.,

the vest end of the pond.

Fond 2 in shcvn in photor,raph #2. The photograph was taken frer the north ci.le of the pond. Ourface water flov was noted by both' Mr. Holt:scher and cycelf frem Fond 2 into Fond 3.

Fond 3 is chovn in photographc #3(a) and #3(b). Surface water-flow was noted by both Mr. !!olt:scher and myself from pend. 3(a) into pond 1. Pond 3(b) appearc to have been formed tecause of lov vater.

Pond ~ 3(a) is approximately 60 ft. long and 30 ft. vide.

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Pond 3(b) appears to be about one foot lower than 3 (a).

Pond D in chovn in photographs F(a) and S(b)^. Pond 8(a) ic-to the ver.t c.f pm.d h (b) . Inn.1 h(b) appearr. te have been formed by lov vnter. level. Fond h(a) ir opproximately 160 feet lone and 65 feet vide.

Fond j(b) is approximately 65 feet long and'LO feet vide. Fond,f(b) appears to be about ? rect ]cwer than pond 1(a).

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