ML20052F402

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Initial Response to Applicant 820422 Motion for Protective Order.Aslb Should Defer Ruling on Motion Until Notified of Parties' Inability to Resolve Issues & State of Il Filed Substantive Response.Certificate of Svc Encl
ML20052F402
Person / Time
Site: Clinton Constellation icon.png
Issue date: 05/06/1982
From: Neuman R
ILLINOIS, STATE OF
To:
NRC COMMISSION (OCM)
References
ISSUANCES-OL, NUDOCS 8205120426
Download: ML20052F402 (5)


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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION IN THE MATTER OF '

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) i ILLIN0IS POWER COMPANY, )

50YLAND POWER COOPERATIVE, )

INC. and WESTERN ILLIN0IS ) Docket No. 50-461 OL POWER COOPERATIVE, INC., ) q (Opera ting License for

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/ 1 ILLIN0IS' INITIAL RESPONSE TO k'N,h5

^ APPLICANTS' MOTION FOR A PROTECTIVE ORDER f

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The State of Illinois (Illinois) by Tyrone C. Fahner, Attorney General of the State of Illinois, hereby makes its initial response to the Applicants' Motion For a Protective Order, filed April 22, 1982. In support nereof, Illinois states as follows:

1. Applicants' Motion For a Protective Order concerns documents relating to Illinois Power's " Quality Report System" described in the Answer to Interrogatory No. 24 of the Supple-mental Response of Illinois Power to the State of Illinois'

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Second Set of Interrogatories, dated March 16, 1982.

2.

Pursuant to statements made on the record by counsel for Applicants at the second special prehearing conference held l

May 4, 1982 in Champaign and discussions had thereafter between counsel for Applicants and for Illinois, those named parties wish to explore the possibility of reaching an agreement on the question of disclosure and the conditions thereof. With-in two weeks of the date of this response, these parties plan 13503f 8205120426 820506 PDR ADOCK 05000461 // )

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to meet and attempt to work out a disclosure agreement.

3. Given such events, Illinois requests that the Board defer its ruling on Applicants' Motion, until and unless the parties are unable to resolve voluntarily this disclosure question. Should the parties fail to resolve this matter, counsel for Illinois will so advise the Board and will contemporaneously file its substantive response to Applicants' Motior,.

WHEREFORE, Illinois prays that the Board defer its ruling on Applicants' Motion for a Protective Order, until such time as it is notified of the parties' inabili ty to otherwise resolve the matter and Illinois has filed its substantive response.

Respectfully submitted, TYRONE C. FAHNER ATTORNEY GENERAL

, STATE OF ILLIN0IS BY: 11 L} , M Eu.ca Reed W. Neuman L i Assistant Attorney General Environmental Control Division Southern Region 500 South Second St.

Springfield, IL 62706 (217) 782-9031 DATED: May 6, 1982

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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION IN THE MATTER OF )

ILLIN0IS POWER COMPANY, )

S0YLAND POWER COOPERATIVE, )

INC. and WESTERN ILLIN0IS ) Docket No. 50-461 OL POWER COOPERATIVE, INC. )

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(Operating License for Clinton )

Power Station, Unit 1) )

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N0TICE T0: Hugh K. Clark, Esq., Chairman P.O. Box 127A Kennedyville, Maryland 21645 Dr. George A. Ferguson School of Engineering l Howard University 2300 Sixth Street, N.W.

Washington, D.C. 20059 Dr. Oscar H. P a ri s-Atomic Safety and Licensing Board U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Sheldon Zabel Schiff, Hardin & Waite .

7200 Sears Tower 233 South Wacker Drive Chicago, Illinois 60606 Jan L. Kodner Tutt and Kodner 173 W. Madison St.

Suite 1004 Chicago, Illinois 60602 l

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! Atomic Safety and Licensing Board Panel i

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 today mailed for filing
with the Secretary, United States Nuclear Regulatory Com-mission, Washington, D.C. 20555, Attention
Chief Docketing and Service Section, one original and two conformed copies 1 of Illinois' Initial Response to Applicants' Motion for a Protective Order. A copy of this document is attached and served upon you.

2- [N k i- 1 c u n a REED W. NEUMAN I l Assistant Attorney General Environmental Control Division Southern Region 500 South Second St.

.7ringfield, IL 62706 (217) 782-9031 DATED: May 6, 1982 .

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i' UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION IN THE MATTER OF )

ILLIN0IS POWER COMPANY, )

S0YLAND POWER COOPERATIVE, )

INC. and WESTERN ILLIN0IS ) Docket No. 50-461 OL POKER COOPERATIVE, INC. )

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(Operating License for Clinton )

Power Station, Unit 1)

CERTIFICATE OF SERVICE I hereby certify that I served copies of Illinois' Initial Response to Applicants' Motion for a Protective Order on the persons listed on the attached Notice by causing same to be deposited in the United States Mail, first class, postage prepaid, on this 6th day of May, 1982.

I bW.b EAMcoi REED W. i4 EUMAN O