ML20010B294

Renewed Application for Subpoenas Directed to Rf Brissette, s Dobrijevic & Personnel at Sargent & Lundy,Ground/Water Technology,Inc & Dames & Moore.Related Correspondence

ML20010B294
Person / Time
Site:	Bailly
Issue date:	08/12/1981
From:	Marc-Anthony Murray ILLINOIS, STATE OF
To:
References
NUDOCS 8108140330
Download: ML20010B294 (2)

Text

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h p ce d'.usadny q\ BEFORE THE ATOMIC SAFETY AND LICENSING BOARD e MJ 8 Q

In the Matter of )

) Docket No. 50-367 NORTHERN INDIANA PUBLIC ) (Construction Permit Extension)

SERVICE COMPANY )

(Bailly Generating )

Station, Nuclear-1) )

PEOPLE OF THE STATE OF ILLINOIS' RENEWED APPLICATION FOR SUBPOENAS People of the State of Illinois, by its attorney, Tyrone C.

Fahner, Attorney General, pursuant to 10 C.F.R. S2.720 (a) , hereby renews its June 23, 1981 application to the Board for subpoenas directed to each of the following persons. In accordance with

, the Board order, issued during the conference, call of August 3, 1981, requiring the Intervenors to make statements of general relevancy in support of this renewed application, Illinois presents its vieu of the general relevancy of the deponents' testimony.*

1. Richard F. Brissette, of D'Appolonia Consulting Engineers, Inc.

2. Stevo Dobrijevic, of D'Appolonia Consulting Engineers, Inc.

Relevancy: Because Mr. Brissette and Mr. Dobrijevic signed the D'Appolonia report entitled " Assessment of the Influence of Dewatering at Bailly N-1", Illinois s assumes that ' hey were primarily responsible for its preparation. This report is apparently the theoretical

• Illinois' original application for ubpoenas did not include a statement of general relevance because that is not necessary under 10 C.F.R. 52. 72 0 (a) unless the Board specifically requires it. In addition, this renewed application is accompanied by a Notice Of Depositions because the Board ordered during the said conference call that depositions be scheduled for the individuals for whom subpoenas are requested even though the Board has not yet ruled on the subpoena requests.

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basis for NIPSCO's current dewatering plan and for NIPSCO's position that construction dewatering _will not adversely affect the Indiana-Dunes National <

Lakeshore.

3. The p' ~on at Sargent & Lundy who supervised or was -

primarily responsible for preparation of'the' August.27, 1979' report entitled: " Supplementary Information, Hydro-geologic Evaluation of Construction Dewatering, Bailly Nuclear GeneratingStation, Nuclear 1".

4. The person at Ground / Water Technology, Inc. who super-vised or was primarily. responsible _for preparation of the August 27, 1979 report entitled: " Supplementary Informa-tion, Hydrogeologic Evaluation of Construction Dewatering, Bailly Nuclear Generating Station, Nuclear 1".

5. The person at Dames & Moore who supervised or was pri--

marily responsible for preparation of the August 27, 1979 report entitled: " Supplementary Information, Hydrogeologic Evaluation of Construction _ Dewatering, Bailly Nuclear Generating Station, Nuclear 1".

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Relevancy: -Sargent & Lunday, Ground / Water Technology, Inc., and Dames & Moore prepared the report mentioned above. This report contains NIPSCO's current dewatering plan and other matters relating to dewatering. The individuals for whom subpoenas are requested should have knowledge of the history of NIPSCO's dewatering plans and efforts and of many matters relating to NIPSCO's current dewatering and monitoring plan.

8eepectfully submitted, TYRONE C. FAHNER ATTORNEY GENERAL STATE OF ILLINOIS BY: 7 MARY JO MUR' RAY ANNE RAPKIN MARY JO MURRAY Assistant Attorneys General Environmental Control Division 188 West Randolph Street Suite-2315 Chicago, Illinois 60601 312-793-2491

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