ML20010C592

First Set of Interrogatories Directed to Util.Certificate of Svc Encl

ML20010C592
Person / Time
Site:	Bailly
Issue date:	08/13/1981
From:	Rapkin A ILLINOIS, STATE OF
To:	NORTHERN INDIANA PUBLIC SERVICE CO.
Shared Package
ML20010C589	List: ML20010C588 ML20010C590 ML20010C591 ML20010C592
References
NUDOCS 8108200221
Download: ML20010C592 (10)

Text

-

' UNITED STATES OF AMERICA-l NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD _

In-the Matter of )

)

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

'(Bailly Generating ) Extension)

Station, Nuclear-1) )

PEOPLE OF THE STATE OF ILLINOIS' THIRD SET OF INTERROGATORIES TO NIPSCO People-of the State of Illinois, by its attorney, Tyrone C.

Fahner, Attorney General of the State of Illinois, pursuant to 10 C.F.R. 52 740b, heraby serves upon Northern Indiana Public Service Company ("NIPSCO") the following Interrogatories, to be.

answered under oath within 14 days of the date of.the Board's granting of PCCI's application for discovery filed this date.

These Interrogatcries refer to the Staff's report issued July 17, 1981 entitled:' "NRC Staff Evaluation of the Bailly Construction 1

' Permit Extension Request".

The-term "you" and "NIPSCO" include Northern Indiana Public Service Company, its_ agents, employees, representatives, subsi-diaries,-and those consultants, attorneys, contractors or subcon-

, tractors over'whom NIPSCO retains control. The terms "St'aff" and "NRC" include the United States' Nuclear Regulatory Commission, Atomic Energy Commission, its staff, members, attorneys, employees, consultants, divisions or subdivisions, contractors and subcontrac-tors,-and consuluants.

t

'0NA 0

1

1. With respect to section "B. NRC Staff Evaluation of the

~Specified Delays":

a. With reference to the phrase "NIPSCO's presently

. proposed and conditionally accepted program", appearing in the last paragraph of page 4, is it NIPSCO's understanding that the NRC Staff will not permit construction until the QA/QC manual for pile installation is revised to reflect the final driving criteria established by the Staff?

b. When did the Staff first indicate to NIPSCO, formally or informally, by any means whatsoever, that revisions wou d be required to the QA/QC pile installation manual, and to whom and by whom was such indication given?

c. Has NIPSCO submitted to the Staff any revisions or proposed revisions to the said QA/QC manual, and if so, when were they submitted?

d. When does NIPSCO expect that all revisions to the said QA/QC manual will be completed by NIPSCO and submitted to the Staff?

e. Is it your understanding that the Staff will not permit construction to resume until NIPSCO's revisions to the.QA/QC pile installation manual are appro ed or accepted

> by the Staff, and it so, how did you reach such an under-standing?

f. When does NIPSCO expect that all revisions to the said QA/QC manual will be accepted or approved by the Staff?

g. With reference to thn last sentence of the first paragraph of the section "A. Irtroduction":

9

i. Is it your understanding that the Staff will not recommend extension of the Bailly N-1 Construction Permit unless NIPSCO submits modifications to the con-struction dewatering program?

ii. Is it your understanding that the Staff will not allow construction to resume until NIPSCO submits modifications te the construction dewatering program?

iii. Is it your understanding that the Staff will not allow construction to resume intil the Staff approves or accepts the modifications to the construction dewatering program submitted by NIPSCO, and if so, how did you reach such an understanding?

h. The first full sentence on page 5 includes the state-ment that "NIPSCO made a one-sentence reference to the use of jetting as part of its pile placement program in a letter submitted to the Staff in December 1976".

i. Was there an attachment to said letter entitled:

" Northern Indiana Public Service Company Bailly N-1 Nuclear Station, Category I- Structures--Pile Driving Criteria"?

ii. When did NIPSCO first indicate to the Staff, either formally or informally, by any means whatsoever, that NIPSCO would use or was considering using jetting as a means, alone or in-combination with other means, of placing piles?

iii. When did NIPSCO first inform the Staff, either formally or informally, by any means whatsoever, that

-NIPSCO would test and/or evaluate or hadttested a'd/or*evaluatedijetting n as a means, alone or in combination with other.means, of placing piles?

iv. Did NIPSCO have any. communications with the Staff regarding jetting between summer.1975 and December 29,'1976?

1. Did you at any time ~ prior to issuance of the Bailly-N-1 Construction Permit deliver to the Staff a copy of a  !

'1972' report by Dames & Moore, #5676-005-07, or a report or communication from Sargent & Lundy or NIPSCO describing the contents of said Dames & Moore report, and if so, when?

j. Did the Staff indicate to NIPSCO in 1974, either p formally or informally, by any means whatsoever, that a ,

short piles foundation plan might require or involve a pub-lic hearing, and if so, when did the Staff so indicate?

k. Did the Staff indicate to NIPSCO in 1974, either

formally or informally, by any means whatsoever, that a short piles foundation plan would require or involve a pub-i lic hearing, and if so, when did the Staff so indicate?

I

l. Did the Staff ever indicate to NIPSCO either for-j mally or informally, by any means whatsoever, that a short piles foundation plan might require or involve a public hearing, and if so, when did the Staff so indicate?

m. - Did the Staff ever indicate to NIPSCO either for-mally'or-informally, by any means whatsoever, that a short piles foundation plan would require or involve a public

- 4'-

IL 1 hearing, and if so, when did the Staff so indicate?

n. Did the Staff ever recommend to NIPSCO prior to issuance of the construction permit that short rather than long pilings be installed under Bailly's Class I structures, and if so, when?

o. Did the Staff ever recommend to NIPSCO after issuance af the construction permit but before December 1976 taat short rather than long pilings be installed

. under Bailly's Class I structures, and if so, when?

p. Identify the NIPSCO persons who were present at the meeting vith the Staff regarding pile design and placement on July 26, 1974?

q. Did NIPSCO in 1974 have any meetings with the Staff other than the July 26, 1974 meeting, during which pile design and placement were discussed, and if so, when was such meeting (s) held and which NIPSCO persons were present?

r. When did NIPSCO first indicate to the Staff, either formally or informally, by any means whatsoever, that NIPSCO was considering placing short piles under Class I structures, and to whom and by whom was such indication given?

2. With respect to the Environmental Impact Appraisal:

a. What was the original estimate of the time necessary to complete the construction phases described in the second paragraph on page 3?

b. If the present estimate of two to three years, given in the second paragraph on page 3, for completion of the said construction phases is longer than the ori-ginal estimate, what is tne basis for the new longer esti-mate?

c. On page 5 under subsection "i. Reactor facility excavation" the Staff states: " Dewatering of the lower unit 3 sands will be performed as part of the pile place-ment program." How long and at what rate will the lower unit 3 sands be dewatered?

d. With reference to the las sentence of the first full paragraph on page 7, what document reflects the con-clusion of NIPSCO and its consultants that "no drawdown from construction dewatering of the Bailly site should occur at distances greater than about 1,500 feet from the excavation"?

e. Did the Staff prior to issuance of the Environ-mental Impact Appraisal ever indicate, formally or infor-mally, by any means whatsoever, to NIPSCO that appropriate modification of the monitoring and mitigation program might be necessary?

f. If the answer to Interrogatory #2 (e) is yes, when did the Staff first so indicate to NIPSCO, and by whom and to whom was such indication given?

g. The first sentence on page 10 states: "While the permittee has verbally agreed to. submit the appropriate ,

program modifications to the NRC Staff ~for review, it has I

II no'i yet done so." When was the said verbal agreement made and to.whom and by whom?

h. . Identify, by date, type of communication, and par-ties to communication, all communications between NIPSCO and the Staff regarding modifications to NIPSCO's moni-

~

toring and mitigation program with respect to dewatering unit 3.

i. Has NIPSCO begun developing or working on modifi-catiens to the monitoring and mitigation-program?

j. Has NIPSCO submitted to the Staff any revisions or proposed revisions to the monitoring and mitigation program, and if so, when were they submitted?

k. When does NIPSCO expect that all revisions to the monitoring and mitigation program will be completed by NIPSCO and submitted to the Staff?

1. When does NIPSCO expect that all revisions to the monitoring and mitigation program will be accepted or approved by the Staff?

3. Please state the name, address, and title of the person swearing to the answers to these Interrogatories.

4. Please state the name , address , title, relevant Interro-gatory number, and the nature of the information provided, for each person who provided information utilized in the answering of these Interrogatories.

5. For each of these Interrogatories, please identify each document referred-to or used in formulating the answer.

Respectfully submitted, TYRONE C. FAHNER Attcrney. General State of Illinois N

BY: '-

ANNE RAPKIN Assistant Attorney General I

ANNE RAPKIN MARY JO MURRAY Assistant Attorneys General Environmental Control Division 188 West Randolph Street Suite 2315' Chicago, Illinois 60601

[312] 793-2491-4 4

j I

l

-UNITED STATES OF' AMERICA NUCLEAR RP24 TORY COMMISSION BEFORE THE ATOMIC SAFZTY AND LICENSING BOARD In the Matter of )

)

NORTHERN INDIANA PUBLIC ) Docket No. 50-367 SERVICE COMPANY ) (Construction Permit (Bailly Generating' ) Extension)

Station Nuclear-1) )

CERTIFICATE OF SERVICE I hereby certify that I served copies of People of the State of Illinois' Application for Discovery Regarding Staff Documents, First Set of Interrogatories to the lihC Staff, and Third Set of Interrogatories to NIPSCO, on the persons on the attached Service List by causing them to be deposited in the U.S. Mail, first class, postage prepaid, on this 13th day of August-1981.

\

ANNE RAPKIN

o

~

.. SERVICE LIST Herbert Grossman, Esq. George & Anna Grabowski Administrative Judge , 7413 N. 136th Lane Atomic Safety & Licensing Cedar Lake, Indiana 46303 Board Panel U.S. Nuclear Regulatory , Dr. George Schult:

Commission 807 E. Coolspring Road Washington, D.C. 20555 Michigan City, Indiana 46360

.Ch . Robert L. Holton Laurence M. Kamer Administrative Judge Lake Michigan Federation School of Oceanography 53 W. Jackson Soulevard l

Oregon State University Chicago, Illinois 60604 Corvallis, Oregon 97331 Mr. Mike Olszanski Dr. J. Venn' Leeds Mr. Clifford Mezo Administrative Judge Local 1010 - United Steel-10807 Atwell workers of America Houston, Texas 77'J6 3703 Euclid Avenue East Chicago, Indiana 46312 Maurice Axelrad, Esq.

Kathleen H. Shea, Esq. Stephen H. Lewis, Esq.

Lowenstein, Newman, Reis, Office of the Executive Axelrad and Toll Legal Director 1025 Connecticut Avenue, N.W. U.S. Nuclear Regulatory Washington, D.C. 20036 Commission Washington, D.C. 20555 William H. Eichhorn, Esq.

Eichhorn, Eichhorn & Link Robert J. Vollen 5243 Hohman Avenue Jane M. Whicher Hammond, Indiana 46320 c/o BPI 109 North Dearborn Diane B. Cohn, Esq. Suite 1300 William P. Schultz, Esq. Chicago, Illinois 60602 Suite 700 2000 P Street, N.W. Docketing & Service Section (3)

Washington, D.C. 20036 Office of the Secretary s U.S. Nuclear Regulatory Atomic' Safety & Licensing Commission Bo,ard Panel Washington, D.C. 20555 U.S. Nuclear Regulatory Commission Stephen Laudig, Esq.

Washington, D.C. 20555 21010 Cumberland Road Noblesville, Indiana 46060 i Atomic Safety and Licensing i Appeal Board Panel H U.S. Nuclear Regulatory Comn'ission

• Washington, D.C. 20555 I

l

- _ .J