ML20010C590
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| ML20010C590 | |
| Person / Time | |
|---|---|
| Site: | Bailly |
| Issue date: | 08/13/1981 |
| From: | Rapkin A ILLINOIS, STATE OF |
| To: | Atomic Safety and Licensing Board Panel |
| Shared Package | |
| ML20010C589 | List: |
| References | |
| NUDOCS 8108200219 | |
| Download: ML20010C590 (2) | |
Similar Documents at Bailly | |
|---|---|
Category:INTERROGATORIES; RESPONSES TO INTERROGATORIES
MONTHYEARML20049K0821982-03-23023 March 1982
[Table view]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 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 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 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 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 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 ML20010C3261981-08-11011 August 1981 Third Application to ASLB for Order Requiring Attendance & Testimony at Deposition of Lg Hulman,Lm Bykowski & Wf Lovelace.Exceptional Circumstances Exist.Related Correspondence ML20010C4971981-08-11011 August 1981 First Request for Production of Documents Directed to Util ML20010C4921981-08-11011 August 1981 First Request for Production of Documents Directed to NRC ML20010C5001981-08-11011 August 1981 Notice of Lm Bykoski & Lg Hulman 810824 & 26 Depositions, Respectively,Re Theoretical & Empirical Basis of NRC 810717 Eia & Documents,Info & Personnel Used in Preparing Eia ML20010C5071981-08-11011 August 1981 Amended 810720 Notice of MD Lynch Deposition,Including Listed Matters for Exam ML20010C2391981-08-11011 August 1981 Fifth Set of Interrogatories Directed to Util.Related Correspondence 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 1985-05-23 |
Text
[ ~
e UNITED STATES OF AMERICA i
- NUCLEAR REGULATORY' COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of )
)
' NORTHERN INDIANA PUBLIC ) Docket No. 50-367 SERVICE COMPANY (Bailly ) (Construction Permit Generating-Station, ) Extension)
Nuclear-1) )
PEOPLE OF THE STATE OF ILLINOIS' APPLICATION FOR DISCOVERY REGARDING STAFF DOCUMENTS People of the State of Illinois, by its attorney, Ty rone C.
Fahner, Attorney General of the State of Illinois, pursuant to the Board's order of July 10, 1981, hereby applies to the Board for leave to serve discovery on the NRC Staff regarding the Staff documents-issued on July 17, 1981 entitled: "NRC Staff Evaluation of the Bailly Construction Permit Extension Requcst". The discov-ery necessitated by the staff documents consists of the two sets of Interrogatories filed herewith and several pleadings filed on August 11, 1981:
- 1. Illinois' First Set of Interrogatories to the NRC Staff.
- 3. Illinois' First Request to the NRC Staff for Production-of Documents.
- 5. Illinois' Second Application Pursuant to 10 C.F.R.
S2. 720 (h) (2) (i) .
- 6. Illinois'. Notice of Depositions.
- 7. Illinois' Amended Notice of Deposition of M. David Lynch.
0108200219 810813_
DR ADOCK 0500036
F. .
0
- 8. Illinois' Motion for Extending Time f6r Taking Depositions.
The importance of this discovery is self-evident. -Therefore, Illinois respectfully requests that the Board grant this applica-tion and that the parties respond to the discovery requests filed today and on August 11, 1981.
Respectfully submitted,
- TYRONE C. FAHNER Attorney General State of Illinois
/
/[ /'
BY.La J ' <
ANNE RAPKIN Assistant Attorney General 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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