ML20010B293

Notice of Depositions for Dl Leone,Ga Chauvin,Ee Barnett, Tj Wysocky,Personnel at in Dunes Natl Lakeshore,W Meyer, P Tucci,Dc Gilles,Ww Lapham,Ma Hardy,J Marie,D Willard, Rf Brissette & s Dobrijevic.Related Correspondence

ML20010B293
Person / Time
Site:	Bailly
Issue date:	08/10/1981
From:	Whicher J PORTER COUNTY CHAPTER INTERVENORS, VOLLEN, R.J. & WHICHER, J.M.
To:
References
NUDOCS 8108140329
Download: ML20010B293 (7)

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UNITEDSTATES0[ AMERICA OfIO b d NUCLEAR REGULATORY COMMISSION. .A BEFORE Tile ATOMIC SAFETY'AND LICENSING BOARDf AUG 12198l p

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In the Matter of

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) Docket No. 50-367 M g

. NORTilERN INDIANA PUBLIC ) (Cons truction y A SERVICE COMPANY )' Permit Extension #

(Bailly Generating Station, ) j /?,

Nuclear-1) ) ff p6 MG13;gggh 1 PORTER COUNTY CllAPTER INTERVENORS' Ss. %soaws @ 4 'on NOTICE OF DEPOSITIONS FOR WHICH APPLICATION liAS BEEN MADE FOR SUBPOENAS 9 g

'v in Please take notice that, pursuant to 19 CFR S2.740a, and pursuant to subpoenas, for which application bas been made but-which have not been issued as of the.date of this notice, Porter County Chapter of the Izaak Walton League of America, Inc.; Concerned Citizens Against Bailly Nuclear Site; Businessmen for the Public Ir..erest, Inc.; James E. Newman and Mildred Warner (PCCI), by their attorneys, shall take the depositions of the persons named below, commencing at the times and on the dates set forth below and continuing thereafter from day.to day until completed. Each deposition shall be taken at the offices of Business and Professional People for the Public Interest, Suite 1300,.109 North

Dearborn,

Chicago, Illinois 60602, before a certified court reporter, an dfficer associated with the offices of Longoria and Goldstine Court Reporting Service, 10 South LaSalle Street, Suite 1118, Chicago, Illinois 460603.

Please take further notice that the subpoenas which have been applied for also will require the productic, of documents relevant to the matters upon which the persons will be examined.

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D.L. Leone, Sargent & Lundy Engineers, on Wednesday, September 2, 1981, at 10:00 a.m. Mr. Leone will be examined.

upon the following matters:

1. All matters set forth or referred to in letters dated February 7, 1979, August 31, 1979, and November 26, 1980', from NIPSCO, by E.M. Shorb, to Harold R. Denton.

2, All matters set forth, referred to,-or enclosed with Mr. Leone 's letter to NIPSC01 dated April 21, 1981.

3. The reasons why NIPSCO did not complete construction of the Bailly nuclear plant.by September 1, 1979.

4. All matters contained in or referred to in Contentions 1, 3, 4, 5, and 7 of the Joint Intervenors' First Supplcment to Petition for Leave'to Intervene filed in this proceeding on February 26,.1980, as admitted as contentions in this proceeding by the Order Following Special Prehearing Conference, dated- ,

August 7, 1980.

5. The. identity of persons who have or may have knowledge of the matters described in paragraphs 1 through 4.

6. The existence of documents which contain information concerning the matters described in. paragraphs 1_through 5.

G.A. Chauvin, Sargent & Lundy Engineers, on Thursday, September 3, 1981, at 10:00 a.m- Mr. Chauvin will be examined.

upon the following matters: ,

1. All matters set forth or referred to in letters dated February 7, 1979, August 31, 1979, and November 26, 1980, from "NIPSCO, by~E.M. Shorb, to llarold R. Denton.

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2. -The reasons wh. NIPSCO did not complete construction of the Bailly nuclear plant by September 1, 1979.

3. All: matters contained in or r'ferred e to in Contentions 1, 3, 4, 5, and 7 of the Joint Intervenors' First' Supplement; to_ Petition for Leave to Intervene filed in this proceeding on February 26, 1980, as admitted as conteations in this. proceeding by the Order Following Special Prehearing Conference, dated August 7, 1980.

4 The identity of persons who have or may have knowledge of the matters described in paragraphs l_through 3.

5. The existence of documents wh'ich contain information-concernin, the matters described in paragraphs 1 through 4.

Eugene E. Barnett, C.F. Braun & Co., on Friday, September _4, 1981, at 10:00 a.m. Mr._Barnett will be examined upon_the following matters:

1. The reasons why NLPSCO did not complete construction of the Bailly nuclear plant by September 1, 1979.

2. The reasonableness of a latest completion date of:

December 1. 1989 for the Bailly plant. -

Thomas J. Wysocky, Thatcher Engineering Corporation, on Tuesday, September 8, 1981, at 10:00fa'.m. Mr. Wysocky will be ,

examine'd on the following matters: ,

1. The reasons why NIPSCO did not complete construction of the Bailly nuclear plant by September 1, 1979.

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2. The reasonableness of a latest completion date'of December 1,'1989 for the Bailly. plant.

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.4-Superintendent,EIndiana Dunes National Lakeshore, on Thursday, September 10, 1981, at 10:00 a.m. The Superintendent will be examined on the impacts of construction o.f the Bailly plant on the Indiana Dunes National Lakeshore, itsfuse, enj oy-ment and value.

Chief Scientist, Indiana Dunes National Lakeshore, on Thursday, September'10, 1981, at 1:00 p.m. Th'e Chief Scientist:

will be examined on~the impacts of construction of the Bailly.

plant on the Indiana Dunes National Lakeshore, its use, enj oy-ment and value.

William Meyer, U.S. Geological Survey, on' Friday September 11, 1981, at 10:00 a.m. Mr. Meyer-will be' examined on a report, of which ha is an author, titled " Effects.of Seepage from' Fly-Ash dettling Ponds and Construction Dewatering on-Ground-Water Levels in the Cowles Unit, Indiana Dunes National Lakeshore, Indiana," prepared in cooperation with the National Park Service, U.S. Geological ~ Survey Water-Resources Investigations,78-138, dated January 1979.

Patrick Tucci, U.S. Geological Survey,;on Friday, September 11, 1981, at 1:00 p.m. Mr. Tucci'will be:cxamined on a report, of which he is an author, titled " Effects'of. Seepage from Fly-Ash Settling Ponds and Construction Dewatering on Ground-Water Levels in the Cowles Unit, Indiana Dunes National Lakeshore, Indiar. ." prepared in coopers -ion with the National Park Service, U.S. Geological Survey Water-Resources Investiga-tions,78-138, dated January 1979.

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Daniel C. Gilles, U.S. Geological Survey, on Monday, September 14, 1981, at-10:00 a.m. Mr. Gilles will be examined on a report, of which he is an author,- ticled " Reassessment of the Effects of Construction Dewatering on Ground-Water. Levels

'in the Cowles Unit, Indiana. Dunes National-Lakeshore~, Indiana,

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Supplement to GeologicalLSurvey Water-Resources ~ Investigations:

'78-138," prepared in cooperation with the National' Park Service.

U.S. Geological Survey, Open-File' Report 80-1105,Jdated' September.1980.

Wayne W. Lapham, U.S. Geological Survey, on: Monday, September 14, 1981, at 1:00 p.m. Mr. Lapham wil1<be examined' on a report, of which he is an author, titled " Reassessment of the Effects of Construction Dewatering on Ground-Water. Levels in the Cowles Unit, Indiana Dunes National Lakeshore,. Indiana, Supplement to Geological Survey Water-Resources Investigations.78-138," prepared in cooperation with the National Park. Service, U.S. Geological Surve.y. Open-File Report-80-1105,, dated September 1980.

Mark A. Hardy, U.S. Geological Survey, on Wednesday, September 16, 1981, at 10:00 a.m. Mr. Hardy will be examined on a report,of which he is the author, titled ""ffectsoof Coal Fly-Ash Disposal o'n Nster Quality In and Around the Indiana Dunes National Lakeshore, Indiana," U.S. Geological Survey.

Water-Resources Investigations 81-16, dated April 1981, t

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James Marie, U.S. Geological Survey, on Thursday, September 17, 1981, at 10:00 a.m. Mr. Marie will be examined ni a report, of which he-is the author, titled "Model Analysis of Effects on Water Levels at Indiana Dunes National Lakeshore Caused by Construction Dewatering," U.S. Geological Survey Water-Resources Investigations 76-82, dated 1976.

Daniel Willard, School of Public and Environmental Affairs, Indiana University, on Friday, September 18, 1981, at 10:00 a.m.

Dr. Willard will be examined on the final report of a panel.of.

which he is the chairman, titled " Effects of Dewatering on the Indiana Dunes National Lakeshore," submitted to Indiana Dune's

, National Lakeshore," submitted to Indiana Dunes National Lake .

shore, U.S. Department of the Interior, National Park Service, dated. November 26, 1980.

l Richard F. Brissette, D'Appolonia Consulting Engineers, 1

l Inc., on Wednesday, September 23, 1981, at 10:00 a.m. Mr. Bris .-

sette will be examined on two reports of which he'is the co-f author, titled " Preliminary Review, Soil Parameters'Used in i

USGS Report 78-138, ' Effects of Seepage from Fly-Ash Settling Ponds & Construction Dewattring on Ground-Water Level's in the Cowles Unit, Indiana-Dunes National Lakeshore, Indiana,'

Bailly Generating Station N'1 clear 1, Baileytown. Indiana,"

dated November 1980; and " Assessment of the Influence of De-watering at Bailly N-1, Bailly Generating Station Nuclear 1, Baileytown, Indiana," dated November 1980.

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• Stevo Dobrijevic, D'Appolonia Consulting Engineers, Inc.,

on Thursday, September 24, 1981, at 10:00 a.m. Mr. Dobrij evic will~be examined on two-reports, of which he ~s the co-author.,

titled " Preliminary Review, Soil Parameters used in.USGS' Report 78 1.38, ' Effects of Seepage from Fly-Ash Settling Ponds & Con-struction Dewatering on Ground-Water' Levels in the Cowles' Unit, Indiana Dunes National Lakeshore, Indiana,'_Bailly Generating ,

Station Nuclear 1, Baileytown, Indiana,"' dated. November 1980; and " Assessment of the Influence-of Dewatering at Bailly N-1,.

Bailly Generating Station Nuclear 1, Baileytown, Indiana,"

dated November 1980. ,

The person or persons at Ground / Water Technology, Inc.

responsible for or having input into " Supplementary Information, Hydrogeologic Evaluation of Construction Dewatering," dated i October 27, 1979, on Friday, September _25, 1981, at 10:00 a.m; l That person or persons will be examined on that report.

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DATED: August 10, 1981 Respectfully submitted, Robert J. Vollen Jane M. Whicher.

by: c:k_ % __- .

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Jane M. Whicher' Attorneys for_ Porter Codnty Chapter Intervenors Robert J. Vollen Jane M. Whicher

-c/o BPI 109 North Dearborn Suite 1300 Chicago, Illinois 60602

.(312) 641-5570