ML20058J150

From kanterella
Jump to navigation Jump to search
Response to 820608 Suppl to Applicant 820422 Motion for Protective Order.Aslb Ruling on Motion Should Be Deferred Unless Parties Disagree on Extent of Disclosure.Proposed Protective Order Encl.Certificate of Svc Encl
ML20058J150
Person / Time
Site: Clinton Constellation icon.png
Issue date: 08/02/1982
From: Willman P
ILLINOIS, STATE OF
To:
NRC COMMISSION (OCM)
References
ISSUANCES-OL, NUDOCS 8208090176
Download: ML20058J150 (7)


Text

f

't1 *

. UNITED STATES OF AMERICA h$h b NUCLEAR REGULATORY COMMISSION e

  • # -s a6s_ g.

IN THE MATTER OF )

ILLINOIS POWER COMPANY, ) , ; fcp g7 3 SOYLAND POWER COOPERATIVE, INC., ) Docket No. /

and WESTERN ILLINOIS POWER ) 50-4 61 'OL]lRM;csw;4f.

c COOPERATIVE, INC. )

)

(Operating License for Clinton )

Power Station, Unit 1) ) .

RESPONSE TO SUPPLEMENT TO MOTION FOR A PROTECTIVE ORDER The STATE OF ILLINOIS (Illinois), by TYRONE C. FAHNER, Attorney General of the State of Illinois, responds to the Supplement To Motion For A Protective Order, filed by Applicants, ILLINOIS POWER COMPANY, SOYLAND POWER COOPERATIVE, INC., and WESTERN ILLI.NOIS POWER COOPERATIVE, INC. and dated June 8, 1982, as follows:

1. On June 25, 1982, Illinois reached agreement by telephone with Applicants on the production of documents relating to the Quality Report System described in the answer to Inter-rogatory No. 24 of the Supplement Response of Illinois Power to the State of Illinois' Second Set of Interrogatories of March 16, 1982. Illinois accepts Applicants' proposal, described in para-graph 6 of the Supplement To Motion For A Protective Order of June 8, 1982, for the production of documents related to the Quality Report System.
2. Illinois also agrees to a protective order, which is attached hereto and filed with the Board.

8208090176 820802 PDR ADOCK 05000461 G PDR

. 3. Illinois reserves the right to. seek additional in-formation related to the Quality Report System, if it finds that Applicants' proposal has not provided the access necessary to develop through discovery the issues of this proceeding. There-fore, Illinois believes that-the Board should not rule on Applicants' Motion For A Protective Order, dated April 22, 1982,

! unless the parties notify the Board that they disagree on the extent of disclosure of information related to the Quality Report System.

WHE REFORE , Illinois requests that the Board defer ruling on Applicants' Motion For A Protective Order, unless the parties notify the Board that they disagree on the extent of disclosure of information related to the Quality Report System.

i

, Respectfully submitted, TYRONE.C. FAUNER I

Attorney General State of Illinois BY: - ~

PHILIP L./WILLMAN I Assistant Attorney General Environmental Control Division 188 West Randolph Street Suite 2315 2

Chicago, Illinois 60601 1

(312) 793-2491 t

DATED: August 2, 1982 i

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) )

AGREED PROTECTIVE ORDER Illinois Power Company, Soyland Power Cooperative, Inc.,

and Western Illinois Power Cooperative, Inc. (" Applicants"), and the State of Illinois (" Illinois"), by their attorneys , hereby agree that the production by Applicants of documents and other information related to the Quality Report System shall, with respect to documents and information not otherwise available to the general public, be subject to the following terms and con-ditions:

1. No information discovered by Illinois from such documents shall be communicated to any" person or entity not a party to this proceeding, and if to another party only upon execution of a protective order in substance comparable to this agreement, nor to any of Illinois' personnel, agent, consultants, or attorneys not actively participating in this proceeding, except as necessary in connection with Illinois' preparation for this proceeding, or upon written consent of Applicants, or upon order of the Nuclear Regulatory Commission ("NRC") nor to

4 any other party's p;rsonnel, agents, consultants, or attorneys not actively participating in this proceeding except upon written consent of Applicants, or upon order of the NRC.

2. Information discovered from such documents shall be subject to such further protection from disclosure as the NRC may order, and Illinois shall not oppose any petition for further protection on the grounds that the documents to which it relates have already been produced.
3. Information discovered from such documents shall be subject to such further displosure as the NRC may order, ar;d Applicants shall not oppose any petition for further disclosure on the grounds that the petitioner has signed this agreement.
4. This agreement shall be enforceable as if it were a protective order issued by the NRC under 10 CFR S 2.740 (c) .
5. This agreement shall apply to all documents pro-duced with respect to the Quality Report System.

APPLICANTS THE STATE OF ILLINOIS BY:

One of the Attorneys BY: .k One of hhe Attorneys r fr=

for Applicants for Illinois DATED: August 2, 1982

UNITED. STATES OF AMERICA NUCLEAR RESULATORY CO!O'ISSION IN THE MATTER OF )

ILLINOIS POWER COMPANY, )

SOYLAND POWER COOPERATIVE, )

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

)

(Operating License for Clinton )

Power Station, Unit 1) )

_N _O _T _I _C _E TO: Hugh K. Clark, Esq., Chairman P.O. Box 127A Kennedyville, Maryland 21645 Dr. George A. Ferguson School of Engineering Howard Univer,sity 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 Richard J. Goddard Office of the Executive Legal Director United States Nuclear Regulatory Commission Washington, D.C. 20555 Sheldon Zabel Schiff, Hardin & Waite 7200 Sears Tower 233 South Wacker Dridd Chicago, Illinois 60606 Jan L. Kodner Tutt and Kodner 173 West Madison Street Suite 1004 Chicago, Illinois 60602

Atomic Safety & Licensing Board Panel U.S. Nuclear Regulatory Commission Washington, D. C. 20555 Atomic Safety & Licensing Appeal Board Panel U. S. Nuclear Regulatory Commission Washington, D. C. 20555 PLEASE TAKE NOTICE that today I have filed with the Secretary of the United States Nuclear Regulatory Commission Illinois' Response To Supplement To Motion For A Protective Order and an Agreed Protective Order, copies of which are attached and served upon you.

TYRONE C. FAHNER Attorney General State of Illinois BY:

CO' PHILIP I/. WILLMAN Assistant Attorney General Environmental Control Division 188 W. Randolph Street -Suite 2315 Chicago, Illinois 60601 (312) 793-2491 DATED: August 2, 1982.

ha-ii- ii

O CERTIFICATE OF SERVICE I hereby certify that an original and two conformed copies of the forego'ing documents were served upon the following:

-Secretary of the Commission United States Nuclear Regulatory Commission Washington, D.C. 20555 and that one copy of each of the foregoing documents was-served upon the persons to whom the attached Notice is directed, by placing them in envelopes addressed to said persons,-by first class mail, postage prepaid, with the United States Postal Service located at 160 North La Salle Street, Chicago, IL 60601.

^

.b.

PHILIP L. WILLMAN SUBSCRIBED AND SWORN TO BEFORE ME THIS 2nd-DAY OF AUGUST, 1982.

Notary Public

.