ML20052A474
| ML20052A474 | |
| Person / Time | |
|---|---|
| Site: | Clinton  |
| Issue date: | 04/22/1982 |
| From: | Fox C ILLINOIS POWER CO., SCHIFF, HARDIN & WAITE |
| To: | NRC COMMISSION (OCM) |
| References | |
| ISSUANCES-OL, NUDOCS 8204280364 | |
| Download: ML20052A474 (7) | |
Text
.
O UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION IN THE MATTER OF
)
ILLINOIS POWER COMPANY,
)
SOYLAND POWER COOPERATIVE, INC. )
and WESTERN ILLINOIS POWER
)
COOPERATIVE, INC.
)
Docket No. 50-461 OL
)
(Operating License for Clinton
)
Power Station, Unit 1)
)
MOTION FOR A PROTECTIVE ORDER Illinois Power Company
(" Illinois Power"), Soyland Power Cooperative, Inc., and Western Illinois Power Coopera-tive, Inc.,
(" Applicants"), pursuant to Section 2.740(c) of the Rules of Practice of the Nuclear Regulatory Commission
("NRC"), hereby move that discovery not be had with respect to the production of any documents relating to the Quality Report System described in the Answer to Interrogatory No, i
24 of the Supplemental Response of Illinois Power to the State of Illinois' ("the State") Second Set of Interroga-tories of March 16, 1982.
In support of their Motion, Applicants state as follows:
1.
As noted in Illinois Power's answer to Interrogatory No. 24, a Quality Report System was imple-l mented at the Clinton Power Station as of February 24, 1982.
This system provides a means by which all Clinton l
,p s o 3 8 2 0 4 2 g o 3 r, cf 5,
Power Station personnel may inform Illinois Power management of quality problems or concerns.
To protect the confiden-tiality of the Clinton Power Station personnel making Quality Reports and eliminate any fear of reprisal, all Quality Reports are transmitted directly to William C.
Gerstner, Illinois Power Executive Vice President.
Mr.
Gerstner then personally investigates the matters raised in the Quality Reports and implements any necessary action.
Mr. Gerstner is the only Illinois Power official who has access to the completed Quality Reports.
2.
During document production at the offices of Illinois Power on April 13, 1982, the representatives of the State asked to examine the Quality Reports.
As Applicants had previously moved for a protective order with respect to any documents pertaining to Interrogatory No. 24 (Motion for Protective Order of December 15, 1981),
Applicants refused to produce the Quality Reports.
3.
The Quality Reports System is based on a firm agreement between William C. Gerstner and the Clinton Power Station personnel that the Quality Reports would be confidential and that only he would have access to the completed reports.
Any disclosure of the Quality Reports would breach the trust that presently exists between Mr. Gerstner and the Clinton Power Station i
personnel and thereby destroy the system.
4.
At present, William C. Gerstner is out of Decatur and unavailable.
Upon his return, Applicants will supplement this motion,to indicate further the need for a protective order.
WHEREFORE Applicants move, for the reasons listed above, that the Board enter a protective order that discovery not be had with respect to the production of any documents relating to the Quality Report System.
Respectfully submitted, bhbo 3
dX N One of the Attorneys for Applicants Sheldon A.
Zabel i
William Van Susteren Charles D.
Fox IV SCHIFF HARDIN & WAITE 7200 Sears Tower 233 South Wacker Drive Chicago, Illinois 60606 (312) 876-1000 Dated:
April 22, 1982 t
I !
l CERTIFICATE OF SERVICE I hereby certify that an original and two con-formed copies of the foregoing document _were served upon the following:
Secretary of the Commission United States Nuclear Regulatory Commission Washington, D.C.
20555 Attention:
Docketing and Service Branch and that one copy of the foregoing document were served upon each of the following:
Hugh K. Clark, Esq., Chairman P.O. Box 127A Kennedyville, Maryland 21645 Dr. George A.
Ferguson School of Engineering Howard University 2300 Sixth Street, N.W.
Washington, D.C.
20059 Dr. Oscar H.
Paris Atomic Safety and Licensing Board U.S. Nuclear Regulatory Commission Washington, D.C.
20555 Executive Legal Director United States Nuclear Regulatory Commission Washington, D.C.
20555 Philip L. Willman Assistant Attorney General Environmental Control Division 188 West Randolph Street Suite 2315 Chicago, Illinois 60610 Jan L. Kodner Tutt and Kodner 173 W. Madison Street Suite 1004 Chicago, Illinois 60602 Atomic Safety and Licensing Board Panel U.S. Nuclear Regulatory Commission Washington, D.C.
20555 i
- I l
[
Atomic Safety and Licensing Appeal Board Panel U.S. Nuclear Regulatory Commission Washington, D.C.
20555 in each case by deposit in the United States Mail, postage prepaid on April 22, 1982.
0 C/X N One of the Attorneys for Applicants.
Sheldon A.
Zabel William Van Susteren Charles D.
Fox IV SCHIFF HARDIN & WAITE 7200 Sears Tower 233 South Wacker Drive Chicago, Illinois 60606 (312) 876-1000 4
4 a
t a
& ;]!f' 6 P1:j UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION IN THE MATTER OF
)
ILLINOIS POWER COMPANY,..
)
SOYLAND POWER COOPERATIVE, INC.
)
and WESTERN ILLINOIS POWER
)
Docket No. 50-461 OL COOPERATIVE, INC.
)
)
(Operating License for Clinton
)
Power Station, Unit 1)
)
NOTICE TO:
, 9 g,c, Hugh K. Clark, Esq., Chairman 6
(,
f.ga\\gr\\r P. O. Box 127A s
y Kennedyville, Maryland 21645 p
,(J o
pL 9
.y Dr. George A.
Ferguson
- cS
Y' b
School of Engineering k
I )' (8$ jNQ:-
Howard University
/
2300 Sixth Street, N.W.
Washington, D.C.
20059 Dr. Oscar H. Paris Atomic Safety and Licensing Board U.S. Nuclear Regulatory Commission Washington, D.C.
20555 Executive Legal Director United States Nuclear Regulatory Commission Washington, D.C.
20555 Philip L. Willman Assistant Attorney General Environmental Control Division 188 West Randolph Street Suite 2315
{}503 Chicago, Illinois 60610 s
Jan L. Kodner jf Tutt and Kodner 173 W. Madison Street Suite 1004 Chicago, Illinois 60602
Atomic Safety and Licensing Board Panel U.S. Nuclear Regulatory Commission Washington, D.C.
20555 Atomic Safety and Licensing Appeal Board Panel U.S. Nuclear Regulatory Commission Washington, D'.' C.
20555 PLEASE TAKE NOTICE that I have filed with the Secretary of the United States Nuclear Regulatory Commis-sion MOTION FOR A PROTECTIVE ORDER in the above-captioned matter.
A copy of this document is attached hereto and hereby served upon you.
G_'\\
O c'A b One of the Attorneys for Applicants Sheldon A.
Zabel William Van Susteren Charles D.
Fox IV SCHIFF HARDIN & WAITE 7200 Sears Tower 233 South Wacker Drive Chicago, Illinois 60606 (312) 876-1000 Dated:
April 22, 1982