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Category:INTERROGATORIES; RESPONSES TO INTERROGATORIES
MONTHYEARML20049K0821982-03-23023 March 1982 First Interrogatory Re Site Restoration 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 ML20010D1181981-08-18018 August 1981 Response to People of State of Il Second Set of Interrogatories.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 ML20010C5911981-08-13013 August 1981 First Set of Interrogatories Directed to NRC 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 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 ML20010C1421981-08-11011 August 1981 Application to ASLB for Discovery on Listed NRC Documents. Certificate of Svc Encl.Related Correspondence ML20010C1531981-08-11011 August 1981 Third Set of Interrogatories Directed to Nrc.Related Correspondence ML20010C2391981-08-11011 August 1981 Fifth Set of Interrogatories Directed to Util.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 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 & 810803 Ltr Encl.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 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 ML20009H4891981-07-31031 July 1981 Second Set of Interrogatories Directed to NRC Re Site Dewatering & Replacement Water Levels.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 ML20009H4921981-07-31031 July 1981 Fourth Request for Production of Documents Directed to Nrc. Related Correspondence ML20009H4911981-07-31031 July 1981 Fourth Set of Interrogatories Directed to Util Re Site Dewatering.Related Correspondence 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 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 ML20009H0451981-07-30030 July 1981 Third Set of Interrogatories Directed to Util.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 ML20009G9561981-07-30030 July 1981 First Request for Production of Documents Upon Which Je Newman 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 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/D'Appolonia Assessment of Dewatering Influence.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 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 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 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 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 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 ML20004G1111981-06-22022 June 1981 Third Set of Interrogatories Directed to M Warner Re Permit to Extend Period of Const Dewatering & Proposed Water Replacement Program.Related Correspondence ML20004G1041981-06-22022 June 1981 Third Set of Interrogatories Directed to Je Newman Re Permit to Extend Period of Const Dewatering & Proposed Water Replacement Program.Related Correspondence ML20004G1071981-06-22022 June 1981 Third Set of Interrogatories Directed to State of Il Re Depth of Dewatering Required After Completion of Foundation.Certificate of Svc Encl.Related Correspondence ML20004G1161981-06-22022 June 1981 Third Set of Interrogatories Directed to Businessmen for Public Interest,Inc Re Dewatering Effects on Lakeshore. Related Correspondence 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
[Table view] Category:LEGAL TRANSCRIPTS & ORDERS & PLEADINGS
MONTHYEARML20126M8141985-05-23023 May 1985 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 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 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 ML20053E6841982-06-0303 June 1982 Affidavit of Rl Graham Re Reasonable & Customary Charges of Attys 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 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 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 ML20049K0821982-03-23023 March 1982 First Interrogatory Re Site Restoration 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 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 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 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 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 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 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 ML20010D2381981-08-18018 August 1981 Response in Opposition to State of Il 810813 Motion to File Application for Discovery & Interrogatories Instanter & for Protective Order. General Allegations Insufficient to Extend Deadline.Certificate of Svc Encl.Related Correspondence ML20010D2291981-08-18018 August 1981 Motion to Compel Answers to 810622 Third Set of Interrogatories Directed to Porter County Chapter,Concerned Citizens Against Bailly Nuclear Site,Businessmen for Public Interest,Et Al.Related Correspondence ML20010D1201981-08-18018 August 1981 Response to Porter County Chapter Intervenors' Third Set of Interrogatories.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 ML20010D1181981-08-18018 August 1981 Response to People of State of Il Second Set of Interrogatories.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 ML20010D2341981-08-18018 August 1981 Request for Motion to Compel Response to 810622 Third Set of Interrogatories Directed to State of Il.Answers Were Nonresponsive.Related Correspondence ML20010C8961981-08-17017 August 1981 Motion for Extension of Time Until 810910 to File Answers or Objections to Util 810730 Fourth Set of Interrogatories. More Time Needed for Adequate Preparation.No Party Will Be Prejudiced by Extension.Certificate of Svc Encl ML20010C8231981-08-17017 August 1981 Response Opposing Porter County Chapter Intervenors' 810810 Motion for Extension of Time to Take Depositions.Intervenors Had Ample Opportunity for Discovery.Board Should Not Allow Delaying Tactics ML20010C8251981-08-17017 August 1981 Response Opposing State of Il 810811 Motion for Extension of Time to Take Depositions.Hardships Under Discovery Schedule Are self-imposed ML20010C5031981-08-14014 August 1981 Second Application for Order Requiring Attendance & Testimony at State of Il Noticed Depositions of Lm Bykoski & Lg Hulman.Exceptional Circumstances Exist & Listed Personnel Should Be Required to Appear ML20010C5881981-08-13013 August 1981 Motion for Leave to File Application for Discovery Re NRC Documents,First Set of Interrogatories Directed to NRC & Third Set of Interrogatories Directed to Util.Discovery Could Not Be Completed by 810811.Related Correspondence ML20010C5911981-08-13013 August 1981 First Set of Interrogatories Directed to NRC ML20010C5921981-08-13013 August 1981 First Set of Interrogatories Directed to Util.Certificate of Svc Encl ML20010C5901981-08-13013 August 1981 Application for Discovery Directed to NRC Re NRC Staff Evaluation of Bailly CP Extension Request. ML20010C5181981-08-13013 August 1981 Motion for Protective Order That Ew Osann Deposition Not Be Taken on 810820.Osann Will Be Unavailable for Util Deposition Due to Other Business Commitments.Good Cause exists.W/810813 Ltr to Util Law Firm & Certificate of Svc ML20010B2941981-08-12012 August 1981 Renewed Application for Subpoenas Directed to Rf Brissette, s Dobrijevic & Personnel at Sargent & Lundy,Ground/Water Technology,Inc & Dames & Moore.Related Correspondence ML20010C4971981-08-11011 August 1981 First Request for Production of Documents Directed to Util ML20010C5111981-08-11011 August 1981 Motion for Extension of Time for Taking Depositions.Supports Porter County Chapter Intervenors' 810810 Motion for Extension of Deadline Until 810803.Schedule Places Burden on Parties W/O Benifit to Anyone.Certificate of Svc Encl ML20010C2821981-08-11011 August 1981 Conditional Withdrawal of Motions for Protective Orders Re Hiple & Kulawinski Depositions.If Depositions Rescheduled for Suggested Dates,Util Will Withdraw Objections. Certificate of Svc Encl ML20010C2621981-08-11011 August 1981 Amend to Porter County Chapter Intervenors' 810717 Notice of Deposition of MD Lynch,Adding Addl Subjs to Deposition. Related Correspondence ML20010C2391981-08-11011 August 1981 Fifth Set of Interrogatories Directed to Util.Related Correspondence ML20010C1591981-08-11011 August 1981 Third Application for Order Requiring NRC to Answer Porter County Chapter Intervenor'S Third Set of Interrogatories. Related Correspondence ML20010C1531981-08-11011 August 1981 Third Set of Interrogatories Directed to Nrc.Related Correspondence ML20010C5071981-08-11011 August 1981 Amended 810720 Notice of MD Lynch Deposition,Including Listed Matters for Exam 1985-05-23
[Table view] |
Text
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, n n. m c., cur s c: m NCt /(< T E- D/ y s- /
. \ QN UNITED STATES OF AMERICA 4 T.
~
NUCLEAR REGULATORY COE4ISSION .
REFORE TliE ATOMIC SAFETY AND LICENSING B06@
p, A23 31981 >
- 9i R C - ' ".= 3: :uri ~
g . .: . 7- L hai:t 9 In the Matter of
)
) N/r M &
NORTHERN INDIANA PUBLIC ) Docket No. 50-367 .- s SERVICE COMPANY ) (Construction P /g Extension)
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(Bailly Generating Station, ) ,
Nuclear-1) ) M Ik 9' NI 1 S '((@e PORTER COUNTY CHAPTER INTERVENORS' -
FIFTH SET OF INTERROGATORIES 'Is NIPSCO k. '
- v. '[
y
.h ,/ i . : -rd s 6 'i Porter County Chapter Intervenors (PCCI), by .t heir attorneys, pursuant to 10 CFR 52.740b, hereby serve upon Northern Indiana Public Service Company (NIPSCO) the following interrogatories to be answered separately and fully in writing under oath by its officer or agent, within 14 days of the date of de Board's granting of PCCI's application for discovery filed August 11, 1981.
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 recordings, computer printouts, photographs, calendar and diary entries, minutes, pamphlets, notes, charts, tabulations, and records of meetings, conferencer and telephone or other conversations or meetings, which are in the mtual or constructive possession, custody or control of JIPSCO or its agents. The term "you" an d "NIPSC0" include Northern Indiana Publ'ic Service Company, its gCd
. agents, employees, representatives, subsidiaries, and those consultants, attorneys, contractors or subcontractors over whom !
NIPSCO retains control. The terms " staff" and "NRC" include the 0108190274 81081I PDR ADOCK 05000367 C PDR_
-2 I
United States Nuclear Regulatory Commission, Atomic Energy Commission, its staff, members, attorneys, employees, consultants, divisions or subdivisions, contractors and subcontractors, and consultants.
The term " evaluation" refers to the "NRC Staff Evaluation of the Request for an Extension of Construction Permit No. CPPR-104 for
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- he Bailly Generating Station, Nuclear-1, Docket No. 50-367" dated
- ,;_ July 17, 1981. The term " negative declaration" refers to the U 'RN " Negative Declaration Supporting the Extension of the Expiration c
i Date for Construction Permit No. CPPR-104 Bailly Generating Statit-
- e , , .
Nuclear-1, Docket No. 50-367". The term " appraisal" or "EIA"
-;7 refers to the " Environmental Impact Appraisal Prepared by the Division of Licensing Regarding the Excension of Construction Permit No.
CPPR-104 Bailly Generating Station, Nuclear-1, Docket No. 50-367" dated July 17, 1981.
- 1. Uith respect to the " evaluation", the " negative declara-tion", and the " appraisal", please state:
(a) Whether NIPSCO has had any communication, either orally or in writing, with any member of the NRC staff or its consultants concerning the contents of those reports.
(b) If your answer to (a) is yes, for each such conmunication, please state:
- 1. The date of the communication
- 11. The person (s) at NIPSCO who participated in the communication 4
iii. The person (s) at the NRC staff who parti-cipated in the communication i v. The substance of the communicat' ion
5 y . 9 1 l
- 3- !
1
- , v. Whether the communication was oral or q,k in writing a
M.;I vi. A description of all documents relating
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, ----- to the cournunication 3'; -
-" 2. In the " appraisal", at page 10, is stated:
- y. c -
(,. ~
g While.the permittee has verbally agreed
.,:L to submit the appropriate program modifi-
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Mc x cations to the NRC staff for review, it has not yet;done so. --
4 .
7 jgge With respect to this statement, please state:
. g.. .
('R (a) The manner in which HIPSCO has " verbally agreed to submit the appropriate program modifications to the NRC j;-f stqff for review".
] ~
(b) The person (s) t NIPSCO who participated in making this verbal agreement.
(c) The person (s) at the NRC staff who participated in making this verbal agreement.
(d) The date of the agreement.
(e) The substance of all conversation during which this c verbal agreement was made, discussed, or negotiated.
(f) Whether the agreement is memorialized or referred to in any document and, if so, a description of each such document.
- 3. L'.th respect to the sentence quoted in Interrogatory 2, please state a description of the " program modifications" which you have agreed to submit. If there exist any documents pertaining to the " program modification", please describe each document.
~
- 4. In the " evaluation", at p. 3 it is stated:
4
-4 To have kept specialized, capital intensive contractors "on call" for either en 18 month or a 25 month period attributable to the judicial. stay of
. construction would have resulted in inordinately large economic penalties.
With respect to this statement, please state:
(a) What you contend it would have cost to keep such contractors "on call" for an 18 month period.
w
, 4 (b) What you' contend it would have cost to keep such contractors "on call" for a 25 month period.
(c) Whether it is your position that your answers to 2 (a) and (b) amount to " inordinately large economic penalties"
, and the basis for your position.
(d) The amount of expenditure which NIPSCO attributes to
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any delay caused by the judicial stay referred to.
- 5. Is it your position that, if the staff review of the short pilings proposal had been initiated at some time prior to March 1978, the review would have been completed prior to the date
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upon which it was completed? Please state the basis for your -
answer.
i
- 6. Is it your position that, had the accident at Three Mile Island not occurred, the NRC staff review of the NIPSCO short pilings proposal would have taken less time than it did in fact I take? If your answer is yes, please state:
, (a) The basis for your answer.
! (b) The length of time which you contend the staff l
review would have taken if the accident at,Three Mile Island had not occurred.
, l 4
- 7. In the " appraisal", at page 2, is stated:
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,F' . That permittee estimates that at the time
-iaj'- -of peak. labor demand, :there would be 1200 H 95^ construction workers enterini, the Bailly 11 fa~cility.through this intersection for the
'.,A morning shift in about 800 vehicles in
.- addition to those vehicles used by the "Gijl Bethlehem Steel work force.
t .n a.
[ ;{p}if With respect to this statement, please state:
p ,~e (a) Whether the de cribed ' estimates" are memorialized 6 J? in any writing, and if so, a description of each document.
89%
yf, (b) The basis for your estimate that there would be 1,200 construction workers entering the Bailly facility through this
$ intersection.
(c) The basis for your estimate that there would be 1,200 construction workers entering the Bailly facility through this intersection for the morning shift in about 800 vehicles.
(d) The number of vehicles used by the Bethlehem Steel work force as rcferred to in the above quoted sentence.
(e) The capacity of the intersection.
(f) The basis for your aaswer to Interrogatories 7(d) and (e) .
- 8. In the " appraisal", at page 3, is stated:
Specifically, construction dewatering of the excavation will be performed while the safety-related foundation piles are placed, the concrete base mat is p'oured and the outer walls of the various buildings are built above the " natural" level of the groundwater at the Bailly site. These construction phases should be completed about two to three years after construction has resumed.
With respect to these statements, please state:
(a) Whether you agree or disagree with each of these statements.
(b) The basis for your agreement or disagreement.
(c) What you contend is the " natural" level of the groundwater referred to in the sentence.
L 9. In the " appraisal", ar page 5, is stated:-
The permittee has undertaken a number of activities which have altered ground-water movement.
With respect to this statement, please state:
-(a) Whether you agree or disa;ree with the statement.
(b) The basis for your agreement or disagreement.
- 10. Is it your position that ' reactor fccility excavation'has altered groundwater movement? If your answer is yes, please state in what respect, groundwater movement has been altered, and the location of the alterations referred to in your answer.
- 11. Is it your position that 'Youndation pilingd' have altered groundwater movement? If your answer is yes, please state in what respect groundwater movement has been altered, and the locations of the alterations referred to in your answer.
- 12. Is it your position that the'plurry and sheet pile walls" have altered groundwater movement? If your answer is yes, please state in what respect groundwater movement has been altered, and the locations of the alteratio: s referred to in your answer.
e i13. Is it your position that the 'hsh pondd' have altered ground-water movement? If your answer.is yes, please state in what respect
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groundwgter movement has been alt,yered, and the locations of the
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g.g alterations referred to in your answer.
~.14 (a) Is it your position that the dewatering program assessed in the construction permit hearing is identical 4-
.~1to the dewatering program considered in the " appraisal"?
- 3
- f;_ :- . .
J,;pt r ~ - ..-
(b) If your answer is no fstate in what respects they
,, ., ~;
f differ.
- .u:"" (c)- Please state the basis for your answers to (a) and
.I (b).
n
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15.(a) Is it your position that the mitigation program considered in the construction permit. hearing is identical to the mitigation program considered in the " appraisal"?
(b) If your answer is no, state in what respects they differ.
(c) Please state the basis for your answers to (a) and (b).
- 16. Is it your position that the proposed extension of the Bailly construction permit is a " major federal action" as that term is used in the " negative declaration" and the " appraisal"?
Please state the basis for your answer.
- 17. Is it your position that the proposed extension of the Bailly construction permit "significantly affects the quality of the human environment" as that term is used in the " negative declaration" and the " appraisal"? State the basis for your answer. .
-18 (a) Is it your position that the proposed extens' ion of the Bailly construction permit affects the quality of the human environment in any respect?
(b) If your answer to (a) is yes, state in what respect.
- (c) Please state the basis for your answer to (a).
- 19. Please give the following information for the person swearing to the answers to these Interrogatories:
(a) Name (b) Address (c) Title
- (d) Capacity
- 20. Please give the following information of each person who has provided or furnished information to the person identified in Interrogatory 19, consulted with that person in the preparation of the responses to these Interrogatories, or otherwise aided in the preparation'of the responess:
(a) Name (b) Address (c) Title (d) Number (including subpart) of each Interrogatory with respect to which that person consulted, aided or provided or furnished information; and -
(e) The nature of the information or aid furnished.
f .
[
- 21. For each of the 3bove Interrogatories, please describe each document referred to or relied on in fomulating your responses.
DATED: August 11, 1981 Robert J. Vollen Jane M. Whicher t By: -
%s_ . _@
Jane.M. Whicher~
Attorneys for Porter County Chapter Intervenors Robert J. Vollen Jane M. Whicher c/o BPI 109 N. Dearborn Suite 1300 Chicago, IL 60602 l
(312) 641-5570 t .
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